Valley of the Drums

The A. L. Taylor site, also known as "Valley of the Drums," is an uncontrolled industrial waste dump located in a small valley in northern Bullitt County just south of the Jefferson County line off Kentucky state highway 1020 outside the community of Brooks, Kentucky.

The topography of the north-central portion of Bullitt County is characterized by steep slopes, particularly in that portion of the county bordering Jefferson County. The A. L. Taylor site falls within this general characterization having 20 to 30 percent slopes on the western and northern sides of the site and 10 percent on the southern and eastern sides. The site is not within any 100 year flood plain. Most of the surface area of the site has been graded so that the land gradually slopes eastward toward Wilson Creek, located adjacent to the site. There are five residences and a private country club located within a few thousand feet of the site.

Groundwater at the site occurs in two aquifers: a shallow unconfined perched aquifer and a deeper confined limestone aquifer. Groundwater monitoring wells drilled on site in both water-bearing units show that both are unusable as drinking water supplies due to poor quality and low yield. Local populations around the site use cisterns and public water supplies.

Wilson Creek, located adjacent to the site, is a small stream subject to seasonal low flow conditions. The stream lies within the Salt River drainage basin and is classified for recreational use.

The A.L. Taylor site was first identified as a waste disposal site by the Kentucky Department of Natural Resources and Environmental Protection (KDNREP) in 1967. The actual disposal site covers 13 acres of the 23-acre tract owned by Mr. Taylor. The surface features of the site have been substantially disturbed. Mr. Taylor excavated pits on site and emptied the contents of the drums into them and recycled the drums. Soil from nearby hillsides was eventually used to cover the pits after KDNREP stopped Mr. Taylor from burning solvents. Thousands of drums were also stored on the surface, especially during later years of operations. During the remedial investigation, four or five major cells of buried wastes containing chemical liquids, sludges and crushed drums were identified.

Throughout the history of site operations from 1967 to 1977 Mr. Taylor never applied for the required state permits. The KDNREP first documented releases of hazardous substances from the site in 1975. They pursued legal actions against Mr. Taylor until his death in late 1977.

In January 1979, at the request of the KDNREP, the Environmental Protection Agency (EPA) responded to releases of oil and hazardous substances at the A. L. Taylor site. Under the authority of section 311 of the Clean Water Act, the EPA emergency response branch on-scene coordinator prevented further releases of pollutants into nearby Wilson Creek by constructing interceptor trenches and a temporary water treatment system, securing leaking drums, and segregating and organizing drums on site.

In 1980 the KDNREP contacted six responsible parties who identified and removed approximately 30 percent of the waste remaining on the surface of the site. Following this removal an estimated 4,200 drums remained.

In 1981 EPA again inspected the site and discovered deteriorating and leaking drums and discharges of pollutants into Wilson Creek occurring once again. EPA, responding under the emergency provisions of The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), upgraded the existing treatment system and removed the remaining 4,200 drums of surface wastes off site for recycling or disposal. There remains, however, an unknown amount of waste buried on site.

The paints and coatings industries of the Louisville area were the primary waste generators using the A. L. Taylor site. Some of the drums were emptied into open pits, cleaned and recycled. Other drums were buried on site, and during the later years of operation many drums were stored on the surface. The open pits which were once used for burning solvents had been covered over prior to EPA's involvement.

The initial drum inventory conducted in 1979 showed 17,051 drums on the surface and of those, 11,628 were empty. During the 1979 emergency response, several disposal pits were discovered. Over the next three years several investigations were conducted to define those disposal pits, including exploratory test pits and the use of geophysics.

Analytical data has been collected during several site actions including the two immediate removals and the remedial investigation. Hazardous substances detected on site include the following classes of compounds: heavy metals, ketones, phthalates, polychlorinated biphenyls (pcb), chlorinated alkanes and alkenes, aromatics, chlorinated aromatics, and polynuclear aromatics. In all, approximately 140 compounds have been identified. The chemicals found most often and in highest concentrations were Xylene, Methyl Ethyl Ketone, Methylene Chloride, Acetone, Phthalates, Anthracene, Toluene, Fluoranthene, Alkyl Benzene, Vinyl Chloride, Dichloroethylene, and Aliphatic Acids.

PCBs were detected in low concentrations and several metals including barium, zinc, copper, strontium, magnesium and chromium were detected in concentrations exceeding background levels.

Groundwater is not currently a source of drinking water in the vicinity of the site. The five homes located closest to the site are on cisterns, other nearby residences and businesses are either on cisterns or are connected to municipal water supplies. Poor water quality and low yield account for the low use of both shallow and deep aquifers near the site. An adjacent landowner had a well drilled but it was never used because of low yield. This well was sampled during the remedial investigation and found to contain concentrations of iron and manganese that were approximately 30 and 3 times national drinking water standards, respectively.

Similarly, a deep well installed in the limestone aquifer during the remedial investigations had a flow rate of four gallons per minute and contained concentrations of chloride that exceeded national drinking water standards by a factor of five.

Another factor limiting future human exposure risks is the limited population growth projected in the vicinity of the site. Topographic features of the area surrounding the site make it largely unsuitable for development.

Geohydrologic studies of the site show that migration of contaminants off site is likely to be very slow. The annual volume of groundwater moving through the site is calculated to be low and assuming the fastest rate of groundwater flow, 2.41 Feet/year, and no attenuation of contaminants in the site soils, any contaminant plume might take 20 years to move 50 feet.

A deep well drilled on site revealed up to 85 feet of unweathered shale isolating the limestone aquifer from the contaminated overburden. Pressure permeability tests performed on both shale units indicated little or no fracturing in the formations reducing the likelihood of contaminants moving into the deeper limestone aquifer.

Surface water, like groundwater, is not believed to be a severe potential exposure route. The Salt River drainage basin which drains into the Ohio River is not a source of drinking water in the vicinity of the Salt-Ohio River confluence. Louisville does get its drinking water from the Ohio River but at a location upstream of the Ohio-Salt River confluence. No other water intakes are located along the Ohio River for many miles downstream but even if there were, the dilution factor (a million fold) should be great enough to prevent any measurable effects.

Potential exposure through recreational use of surface waters also is low due to the dilution factor. Recreational use of the streams leading from the site, although not documented, is believed to be low until the Salt River confluence is reached.