National Electric Coil/Cooper Industries

• Site Profile
• Administrative Record Index (All PDF): OU1 (5 pp., 213K), Removal (5 pp., 251K)
• Complete Semi-Annual 2002 Remedial Action Status Report (PDF, 170 pp., 4.1M)
• Text Only Semi-Annual 2002 Remedial Action (PDF, 25 pp., 121K)
• Text Only Semi-Annual 2001 Remedial Action Status Report (PDF, 19 pp., 105K)
• Text Only Semi-Annual 2001 Remedial Action Status Report (PDF, 22 pp., 105K)
• Text Only Semi-Annual 2000 Remedial Action Status Report (PDF, 21 pp., 637K)
• Text Only Semi-Annual 2000 Groundwater Treatment System Report (PDF, 23 pp., 110K)
• Sampling Database (PDF, 30 pp., 118K)
• Additional Site Documents including Five Year Reviews, Records of Decisions (ROD) and Explanation of Significant Differences (ESD).
• For documents not available on the website, please contact the Region 4 Freedom of Information Office (http://www.epa.gov/region4/foiapgs/submit.htm).

Site Background:
The 3 ½-acre National Electric Coil Co./Cooper Industries (Site) is located adjacent to the Cumberland River in the town of Dayhoit, Harlan County, Kentucky, on Old U.S. Route 119. From 1951 to 1987 the National Electric Coil Company (NEC), operated under the ownership of McGraw Edison Co. The business involved rewinding electric motors, manufacturing coils, and rebuilding machinery used in the coal mining industry. Cooper Industries purchased McGraw Edison in 1985 and continued operations until August 1987 when the facility was sold to Treen Land Company. Cooper Industries, Inc., assumed the role of potentially responsible party (PRP).

Past practices at the facility involved the use of a trichloroethylene (TCE)-based solvent to remove oil and tar from the used motors, capacitors, transformers, and other equipment prior to their being rebuilt. Activities performed to clean the equipment and the equipment-dipping tank resulted in on-site and off-site contamination. Namely, liquid solvent, waste sludges and polychlorinated biphenyl (PCB)-laden transformer oils were allowed to flow overland and/or through a drainage pipe to the Cumberland River. These disposal practices, which continued until the mid-1980s, resulted in volatile organic contaminant (VOC) contamination of the groundwater drinking water supply near the Site. VOC contamination consisted mainly of TCE and its degradation by-products. Contamination of the Site's drainage channels, river embankment property, and facility grounds also occurred. Contaminated drinking water was detected at the adjacent Holiday Mobile Home park in February 1989, during a routine Kentucky Division Water community well sampling event. Twelve of the fifty (50) wells sampled indicated the presence of VOCs. Contaminated well users were initially provided with bottled water and water from temporary above-ground storage tanks and were later (August 1989) connected to municipal water supply.

Cleanup Progress: Construction Complete
A phased clean-up approach at the Site has been conducted under authority of three Unilateral Administrative Orders (UAOs). From October 1990 through October 1991, an early action removal was carried out, consisting of the excavation and off-site disposal of approximately 5,100 tons of contaminated source soils. Preliminary groundwater pump-and-treat activities were begun, in July 1993, as delineated in the September 1992 "Interim" Record of Decision (ROD), in order to minimize VOC plume migration during the remedy selection/implementation period. The remedial investigation/feasibility study (RI/FS) and associated Site studies were finalized in January 1995. The final selected remedy was implemented according to the April 1996 ROD, which consisted primarily of the following: (1) expansion of the existing bedrock extraction system to include extraction of contaminated ground water from the two more shallow zones; and (2) replacement of the granular activated carbon (GAC)-based air pollution control (APC) system, with that of a catalytic oxidation unit in order to mitigate release of vinyl chloride in the air stream to atmosphere. Site construction was completed in August 23, 1998.
 
Operation and Maintenance                                                 
Since RA Startup in February 1998, approximately 2,900 pounds of VOCs have been removed from the ground water and approximately 4,566 pounds of Vocs have been removed since July 1993.  The first five year review was completed September 2003.  The five year review concluded that the remedy remained protective since the system was still operating to achieve the remedial action objectives (RAOs).  Also, municipal water is the source of drinking water and other household uses for the nearby community.  However, the five year review did include a recommendation to improve the effectiveness of the groundwater remediation system.  The recommendation suggested that alternate pumping and / or periods be used and evaluated to optimize contaminant recovery from the surficial and underlying aquifers.

Since the first five year review was completed, the PRP has been evaluating pulsing cycles and its effects on the removal of contaminants and overall system efficiency.  The groundwater recovery and treatment system continues to operate as designed and is effectively removing and treating contaminants from the shallow and deeper aquifers.  The site is monitored semi-annually with the collection of 20 ground water samples from source and downgradient monitoring wells as well as a sample from the onsite interceptor trench.  The PRP is continuing to explore ways to optimize the groundwater treatment system and is currently considering pilot testing other remedial enhancement techniques.  Natural attenuation parameters have been added to the ground water monitoring program. 

The second five year review was completed September 2008.  The ground-water remedy is expected to be protective of human health and the environment, and in the interim, exposure pathways that could result in an unacceptable risks are being controlled.  The ground-water exposure pathway that may potentially result in unacceptable risk has been controlled since residences within the path of the ground-water plume have been provided with municipal water via water lines.  The vapor intrusion pathway was evaluated; a thorough evaluation of specific data indicated that the VI pathway is not a complete pathway and will not be evaluated further.  The direct exposure soil pathway has been addressed through excavation and removal of contaminated soils along the fence line between the NEC property and the Holiday Mobile Home Park.    

Additionally, Cooper Industries is actively working with all the neighboring property owners to adopt institutional controls to restrict the use of groundwater for drinking water purposes until the drinking water aquifer is returned to its beneficial use.  The institutional controls will be in the form of an environmental covenant that was prepared in accordance with guidelines provided by the Kentucky Division of Environmental Protection.  A detailed analysis of off-gases from the treated ground water was conducted at the beginning of 2008.  Based on current and historical data, the EPA has concluded that off-gases from the air stripper do not require treatment via the catalytic oxidizer to be protective of human health and the environment.   Changes to the remedy to include institutional controls and remove catalytic oxidation of the VOC-laden off gas from the air stripper in an enforceable decision document are planned in the upcoming fiscal year.