Tucked away in the rolling Knobs region of northern Bullitt County, Kentucky, lies one of the most infamous Superfund sites in EPA history: The A. L. Taylor Superfund site, informally and perhaps more appropriately referred to as, the "Valley of the Drums". It is here that Mr. Arthur L. Taylor operated an uncontrolled and unregulated industrial chemical waste dump. ^{36, 37, 38} 

EPA records assert that site operations were active from 1967 to 1977.

Despite the initial involvement of the state of Kentucky in late 1967, officials failed to follow up with Mr. Taylor. As a result, Mr. Taylor never applied for the proper permits and continued to receive and dispose of wastes illegally until his death in 1978. ^{36, 37, 38, 39} 

Records show that improper dumping at the site predates both the EPA and the State's timeline of events, and that the boundaries of the site itself may not be accurate as overlooked waste debris and drums have been discovered near the site on multiple occasions.

George P. Stober & his wife Vera Z. Stober acquired property in Bullitt County, Kentucky. Part of the parcel lies in Jefferson County, Kentucky. ²  Their property was bordered by municipally owned Jefferson Memorial Forest to the north, and the A. L. Taylor Superfund site (aka Valley of the Drums) to the south.

Jefferson County was in negotiations with Mr. Taylor to lease a portion of Jefferson Memorial Forest as a possible municipal landfill site:

"I have been studying the possibility of some type of waste disposal program to be entered into by Jefferson County which would possibly make available some additional park land." ¹⁹  -Jefferson County Director of Works to the Superintendent of Jefferson County Playground & Recreation Board

"We will agree to build an access road to the property and we will build it at our expense. We will further agree that Jefferson County may dump land fill there at no expense." ³³  -Mr. Taylor's lease offer to the Jefferson County Assistant Attorney

Jefferson County notified the Stobers that they had no right to use the access road, which ran over and across both of their lands. Jefferson County claimed that by using the road the Stobers had been trespassing, while the Stobers asserted their right to use the road, since it ran across their property. Jefferson County erected obsructions which blocked the Stobers from utilizing the driveway. ⁶  This is when Mr. Stober initially discovered evidence of the illegal dumping on his property.

Jefferson County Police Department along with local Louisville Fire Department were dispatched to the dump due to reports of a fire. A Bullitt County Sheriff was also summoned, but he stated that, "to the best of his knowledge", the access road to the dump was located in Jefferson County. ¹ 

King & Pitan civil engineers of Louisville, Kentucky conducted a survey of Mr. Stober's property. The survey (pictured left) shows the approximate location of the old access road, located in Jefferson County and crossing over onto the Stober property. ⁷  

Public Health Representatives from the Jefferson County Air Pollution Control Program and the Solid Waste Program visited Mr. Taylor's property. The purpose of this visit was to inform Mr. Taylor of the Air Pollution Control Commission Regulation on open burning which had gone into effect that day. ¹⁴   While the EPA's timeline begins with this incident, it was clear to the public health representatives that operations at the site had been active for some time:

During this visit, Mr. Taylor had informed the public health representatives that he had recently acquired more land with the intention of operating a sanitary landfill.

Action No. 106150 George P. Stober & Vera Z. Stober vs Jefferson County et. al, was settled. Terms of the settlement included: "3. Jefferson County agree to remove, dispose, or by other appropriate means, clean the debris from the George P. Stober tract and return the tract to as natural a condition as possible... 4. It is further agreed by Jefferson County that this work shall be ... completed within six months from the date of this agreement and if same is not completed, Plaintiff, George P. Stober, may have the work done and the County agrees to reimburse him for any costs incurred." ⁸ 

The Stober's attorney sent a letter to the Jefferson County Fiscal Court, stating that Jefferson County had failed to clean the debris from the Stober tract (agreed under Action No. 106150), and that Jefferson County Public Works had once again, illegally entered onto the Stober's property "for the purpose of building a rifle and gunnery range." ²⁸ 

Gaps in administrative records make it impossible to say with certainty whether any portion of the settlement under Action No. 106150 was ever upheld, though the physical evidence that remains on the Stober tract would suggest not.

After receiving several complaints of multicolored chemical spills and an oily sheen on the surface of Wilson Creek (a tributary of the Ohio River which runs adjacent to the Valley of the Drums) state representatives became involved with the Valley of the Drums once again in 1975. This was the first documentation of hazardous substances being released from the A. L. Taylor site. The exposed drums and hazardous materials buried at the site had leached contaminants into soil and groundwater. According to the Division of Water Quality Laboratory, "there was no reason to analyze samples as they were almost pure oil and/or paint. ^{"34, 36, 37, 38, 42} 

Mr. Taylor purchased the Valley of the Drums property, Parcel 034-000-00-011 from Gilbert E. Wooden and Mary Charlene Wooden. ³ 

George P. Stober passed away.

Mr. Arthur L. Taylor passed away. Despite the initial involvement of the state of Kentucky, Mr. Taylor continued to illegally store and dispose of chemical industrial waste up until his death in 1978.

The drum inventory for the site showed "17,051 surface drums and of those, 11,628 were empty." ³⁶ 

Potentially Responsible Parties (PRPs) performed voluntary cleanup at the A. L. Taylor/Valley of the Drums site and removed approximately 30% of the surface drums. ^{34, 36, 37, 38} 

Emergency Response and Removal Actions were conducted at the Valley of the Drums, after it was discovered that the remaining surface drums had deteriorated and leaked contaminants. ^{34, 36, 37, 38} 

Valley of the Drums was listed on the National Priority List (NPL). ^{34, 36, 37, 38} 

Vera Stober passed away.

The Record of Decision (ROD) was signed for the A. L. Taylor/Valley of the Drums site. It was decided that on-site containment was the most cost-effective remedy. ³⁶ 

EPA completed the remedial design for the Valley of the Drums. ³⁷ 

EPA completed remedial action at the Valley of the Drums site. ^{37, 38} 

The Valley of the Drums achieved "Construction Complete" designation from EPA. ^{37, 38} 

PRPs and EPA signed Consent Decree (CD). The PRPs agreed to repay the EPA for costs incurred during the initial response actions at the site and would also fund the ongoing operations and maintenance. ^{37, 38} 

EPA published an 8 page newsletter titled, "Superfund At Work", which exemplified the story of the Valley of the Drums as proof of the success of the Superfund program. In the newsletter, the EPA claimed that the contamination at the Valley of the Drums had been "contained" and that the cleanup was a "success". ³⁴ 

The newsletter also stated that they anticipated the site to be deleted from the NPL that same year since "the long-term cleanup of the site had been successful." ³⁴  The newsletter noted that the NPL deletion would be contingent upon the findings from the first five-year review (FYR), also due out the same year.

According to the report, the site was not recommended for deletion from the NPL "for several reasons," (United States Environmental Protection Agency, Region IV, 1992, p. 29).

Jefferson County, Kentucky merged with the city of Louisville, Kentucky, consolidating the two entities into one unified government: Louisville Metro Government.

KDWM conducted a site inspection along with the Park Manager of the forest and the EPA On-Site Coordinator (OSC). During the inspection, the OSC acknowledged that there had been a release of hazardous materials at the site. The OSC pointed out that “as the current property owners, they (Louisville Metro Government) could be a PRP themselves, but that EPA had no plan to hold them responsible; they just want to see the site cleaned up.” ²³ 

Inspectors for the EPA have found about four dozen rusted metal drums on land just outside the part of the dump including a portion of Jefferson Memorial Forest...spokesman for Louisville Metro Parks, which manages the Jefferson Memorial Forest, said his office...has been aware of old drums on its property near the Superfund site since the late 1990s.

EPA discovered hardened paint sludge and drum carcasses in Wilson Creek. ³⁸ 

The state of Kentucky began investigation into Wilson Creek. ³⁸ 

A state-led investigation of the Gully of the Drums occurred and Shield Environmental Associates, Inc. was contracted to characterize the waste and develop a remediation plan. According to the site investigation work plan, "Based on the elevated levels of lead and hexavalent chromium in some of the existing waste, and its location in a public forest, Shield anticipates the most protective eventual remedial alternative for this site to be excavation and disposal of the impacted material in an appropriately permitted sanitary landfill." ³¹ 

As part of the remedial action plan, Shield Environmental installed four groundwater monitoring wells and staged the surface drums and debris for removal. ^{16, 17, 31}  

Because the exact amount of buried waste in the forest was not known, Shield submitted a preliminary cost estimate for remedial action based on the known and assumed extent of waste material for one area.

After receiving the estimate, the state of Kentucky contacted the Dow Corning Corporation, identifying them as the primary waste generator for the Jefferson Memorial Forest Drum site. Representatives from Dow Corning visited the site on two separate occasions and submitted a proposal for response actions. ²⁶ 

It appears that the state of Kentucky once again failed to follow up with the site, because 4 years later, a second letter was sent to the Dow Corning Corporation, which stated that because "unknown materials" were leaking from the drums, Superfund personnel had concluded that there was "an imminent threat to human health and the environment". ¹⁵ 

Dow Corning responded, stating that since submitting a proposal for potential response actions in 2013, but they had received no response from the state. Dow Corning asserted that they would not assume responsibility for the site. ^{15, 26}  

The state completed investigations of Wilson Creek and cleaned up paint waste and drum carcasses. ³⁸ 

EPA Region IV requested a Title Search for the A. L. Taylor/Valley of the Drums Superfund site. ⁹ 

The state of Kentucky abandoned the monitoring wells in Jefferson Memorial Forest. ^{5, 12, 13} 

EPA published the seventh FYR for the Valley of the Drums. There was no mention of the Jefferson Memorial Forest Drum site. ³⁸ 

• (a) arranged for the disposal of hazardous waste on site
• (b) selected the site where the hazardous waste was transported to, and
• (c) are the current owners of the site.
  • U.S.C. 42 Chapter 103, CERCLA, § 9607: Liability

Resolution 058-24, sponsored by Councilman Dan Seum, Jr. of District 13, is passed by the Parks & Sustainability Committee of Louisville. The resolution is for the funding of an environmental investigation contract with Shield Environmental Associates, Inc. in the amount of $68,000.

During the investigation, approximately 600 linear feet of trenching will be accomplished, with each trench being approximately 6-feet in depth. Samples will be collected every 50 linear feet. Soil samples will be tested on-site in the field for Volatile Organic Compounds (VOCs). Waste and subsurface soil samples will be collected and tested for the contaminants of concern (COCs) that were detected in the 2011 investigation. This includes: Total Metals (Arsenic, Cadmium, Chromium, Lead), Hexavalent Chromium, Polynuclear Aromatic Hydrocarbons (PAHs), and Polychlorinated Biphenyls (PCBs). ⁴⁰  

The investigation will also include a waste characterization (i.e., solid waste, hazardous waste, special waste) in order to determine the most appropriate disposal method for the debris and impacted soil. ⁴⁰ 

1. Ammon, K. (November 13, 1966). Dump Fire, South Park Road. [Correspondence]. Jefferson County Police Department, Third District. 
2. Bullitt County, Kentucky, Deed Book 89: 5. (July 20, 1956). 
3. Bullitt County, Kentucky, Deed Book 195: 740-742. (March 5, 1976). 
4. Bullitt County, Kentucky, Deed Book 312: 86-87. (October 26, 1988).
5. Commonwealth of Kentucky. (2020, September 30). Purchase order 129 2100002484. 
6. George P. Stober vs Jefferson County, Jefferson County Fiscal Court, Jefferson County Department of Works. Action No. 106150. (Jefferson Circuit Court, Chancery Division, 1968). 
7. George P. Stober vs Jefferson County, Jefferson County Fiscal Court, Jefferson County Department of Works. Deposition of George P. Stober. (July 9, 1968). Jefferson Circuit Court, Chancery Branch, Third Division.
8. George P. Stober vs Jefferson County, Jefferson County Fiscal Court, Jefferson County Department of Works. Agreed Order Dismissing Settled. (1968, September 30). Jefferson Circuit Court, Chancery Branch, Third Division. 
9. Green, J. (May 25, 2018). A. L. Taylor Superfund Site Brooks, Bullitt County, Kentucky: Final Title Search Report. ACCURA Engineering and Consulting Services, Atlanta, GA. Retrieved July 18, 2022 from https://semspub.epa.gov/work/04/11126182.pdf
10. Haight-Maybriar, L. (1992, November 19). A. L. Taylor Superfund Site Brooks, Bullitt County, Kentucky. [Memorandum: Site Inspection]. Federal Superfund Section, Kentucky Department for Environmental Protection.
11. Haight-Maybriar, L. (December 1992). [Handwritten Correspondence]. Federal Superfund Section, Kentucky Department for Environmental Protection.
12. Hancock, N. (2020, May 13). Superfund Site Inspection Report. Energy & Environment Cabinet, Department for Environmental Protection, Division for Waste Management. 
13. Hancock, N. (2020, August 26). Superfund Site Inspection Report. Energy & Environment Cabinet, Department for Environmental Protection, Division for Waste Management.
14. Holland, W. D. (1967, December 13). A. L. Taylor Dump, Bullitt County. [Memorandum]. Solid Waste Program. 
15. Hughes, L. D. (2016, June 10). Energy & Environment Cabinet, Department for Environmental Protection, Division of Waste Management. [Correspondence].
16. Knox, B. (Spring, 2010). Historic “gully of the drums” site to be cleaned up. Jefferson Memorial Forest Newsletter: Natural Areas News, 4(4), 3. https://louisvilleky.gov/document/jmfnewsletterspring10pdf.
17. Knox, B. (Fall, 2010). Update on gully of the drums dumpsite. Jefferson Memorial Forest Newsletter: Natural Areas News, 5(2), 5. https://louisvilleky.gov/document/jmfnewsletterfall10pdf.
18. Lair, M. D. (May 1993). RE: Jefferson Forest Drum Site, Kentucky. [Correspondence]. United States Environmental Protection Agency, Emergency Response and Removal Branch. 
19. Lee, S. F. (February 8, 1966). Re: Proposed Landfill-Jefferson County Forest at South Park Road. [Correspondence]. Jefferson County Public Works. 
20. Lee, S. F. (March 8, 1966). Re: Lease – County Park Property South Park Road. [Correspondence]. Jefferson County Public Works.
21. MacLaren, P. (March 17, 1993). Jefferson Forest Drums Site Analytical Data TDD# 04-9302-L003-0704. Technical Assistance Team for Emergency Response Removal and Prevention. 
22. Mallette, S. L. (September 1, 2006). Jefferson Memorial Forest Drum Site. Commonwealth of Kentucky, Environmental and Public Protection Cabinet, Division of Waste Management. 
23. Mallette, S. L. (March 1, 2007). Site Inspection Report. Commonwealth of Kentucky, Natural Resources and Environmental Protection Cabinet, Division of Waste Management. 
24. Manka, M. (March 31, 1993). Jefferson Forest Drum Site Brooks, Bullitt County, Kentucky TDD# 04-9212-0012-4186 0012A-4288 TAT# 04-F-00958. Technical Assistance Team for Emergency Response and Removal Branch. 
25. Millanti, C. (November 30, 1992). Fwd: Copy of Field Report. Commonwealth of Kentucky, Natural Resources & Environmental Protection Cabinet, Superfund Branch.
26. Moser, S. V. (2016, June 30). Dow Corning, Inc. [Correspondence].
27. Nett, J. P. (October 20, 1994). Preliminary Assessment: Jefferson Forest Drum Site. B&V Waste Science and Technology Corp. 
28. Pike, J. P. (June 16, 1970). Judgement in Action No. 106150. [Correspondence].
29. Pike, J. P. (August 24, 1972). Re: Jefferson Circuit Court, Action No. 106150. George P. Stober et al. vs. Jefferson County. [Correspondence].
30. Shannon, S. R. (December 9, 1977). A. L. Taylor 10717 National Turnpike Fairdale, Kentucky. [Memorandum]. 
31. Shield Environmental Associates, Inc. (2011 October). Site Investigation Report: Jefferson Memorial Forest Drum Site. 
32. Taylor, A. L. & Gerkins, J. M. (March 4, 1966). Lease – County Park Property South Park Road [Correspondence].
33. Taylor, A. L. & Gerkins, J. M. (March 23, 1966). Lease offer. [Correspondence].
34. United States Environmental Protection Agency, Solid Waste and Emergency Response. (Fall 1992). Superfund at work: Hazardous waste cleanup efforts Nationwide. 
35. United States Environmental Protection Agency, Emergency Response & Removal Branch. (November 30, 1992). Removal Assessment Evaluation and Eligibility Form. 
36. United States Environmental Protection Agency, Office of Emergency and Remedial Response. (June 1986). Superfund Record of Decision: A. L. Taylor, KY. 
37. United States Environmental Protection Agency, Region IV. (2018). Sixth Five-Year Review Report for A. L. Taylor (Valley of the Drums) Superfund Site Brooks, Bullitt County, Kentucky. Region IV, Atlanta, GA; U.S. EPA. Retrieved from https://semspub.epa.gov/work/04/11111974.pdf
38. United States Environmental Protection Agency, Region IV. (2023). Seventh Five-Year Review Report for A. L. Taylor (Valley of the Drums) Superfund Site Brooks, Bullitt County, Kentucky. Region IV, Atlanta, GA; U.S. EPA. Retrieved from https://cumulis.epa.gov/supercpad/SiteProfiles/index.cfm?fuseaction=second.scs&id=0402072&doc=Y&colid=31315®ion=04&type=SC
39. White, J. C. (1979, March 29). United States Environmental Protection Agency. [Correspondence].
40. Shield Environmental Associates, Inc. (April 2024). Proposal for Additional Site Investigation Activities: Jefferson Memorial Forest Drum Site). Louisville, KY
41. Saliga, M. P. (2024, September 23). RE: AI # 51935 - Jefferson Memorial Forest Drum Site Work Plan. [Correspondence].
42. Commonwealth of Kentucky Department for Natural Resources & Environmental Protection, Bureau of Environmental Protection. (1978, March 29). Summary of Events: A. L. Taylor, Bullitt County.