United States
Environmental Protection
Agency
Office of
Emergency and
Retnedial Response
EPA/ROO/R03-46/033
May 1986
Superfund
Record of Decision
 Drake Chemical, PA
   (Second Remedial Action)

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                                   TECHNICAL REPORT DATA
                            /fleatt rttd Intt/venoni on iHt ftvtnt btfcrt eompltungi
 I. RiPO«T NO.
 EPA/ROD/R03-86/033
                                                           3. RECIPIENT'S ACCESSION NO.
4. TITLE ANO
 SUPERFUND RECORD OP DECISION
 Drake Chemical, PA
 (Second Remedial Acti'on)
                                                           s. REPORT OATI
                                                                      May 13. 1986^
                                                             PERFORMING ORGANIZATION CODE
7. AUTMORIS)
                                                           • . PERFORMING ORGANIZATION REPORT so
) PERFORMING ORGANIZATION NAMf ANO ADDRESS
                                                            to. PROGRAM ELEMENT NO.
                                                                  (ACT/GRANT NO
12. SPONSORING AGENCY NAMf ANO ADDRESS
 U.S...-Environmental Protection  Agency
 401 M Street, S.w.
 Washington,  D.C.  20460
                                                            13. TYPE OF REPORT AND PERIOD
                                                                      Final  ROD Retort
                                                            14. SPONSORING AGENCY CODE

                                                                      800/00
19. SUPPLEMENTARY NOTES
16. AiSTRACT
    The Drake Chemical site  is  located in Lock Haven, Clinton County,  PA.   Between 1962
 and 1982 Drake Chemical, Inc.  (DCI)  manufactured batches of specialty,  intermediate
 chemicals for producers of  dyes,  Pharmaceuticals, cosmetics, herbicides,  and
 pesticides.   The herbicide  Fenac,  manufactured at the plant, is  a  major site
 contaminant.  The eight-acre  inactive site contains six major  buildings.   Inside and
 surrounding  the process buildings  are approximately sixty process  tanks and reactors.
 Approximately ten large tanks  used for bulk storaae of acids,  bases,  and  fuel oils are
 outside.  Also located onsite  are  two lined and three unlined  wastewater  treatment
 lagoons.  Chemical sludge and  contaminated soil cover    underlie  much  of the open area
 while construction debris is  strewn  about.  Drums and bulk waste may  be buried at "he
 site.  The primary contaminants of concern include:  inorganics  and organics including
 toluene, benzene, TCE, and  xylene.
    The selected interim remedy is  the second phase of a three  phase cleanup action.   :-
 includes:  drainage and removal of the two lined lagoons and treatment  of drained IIG-J:-:
 and sludge in an offsite RCRA-permitted facility; removal of all tanks, buildings, ar-.rt
 debris;  decontamination of  all metal structures that can be salvagable  as scrap:
 disposal in  a RCRA facility any material not decontaminated and  treatment of any liquids
 removed to a RCRA-permitted treatment facility; incineration of  warehouse-stored
 (See Attached Sheet)                          .        	
                                   WORDS ANO DOCUMENT ANALYSIS
                  DESCRIPTORS
                                                             ENDED TERMS
                                                                         c.  COSATi Field.C(0uj
 Record of Decision
 Drake Chemical, PA
 (Second Remedial Action)
 Contaminated Media: soils, sludaes,  qw
 Key contaminants: organics,  inoraanics
IS. DISTRIBUTION STATEMENT
                                              19 SECURITY CLASS i Hiu Kiponi
                                                        None
NO O*"AGES
        47
                                              20. SECURITY CLASS . Tint pagti
                                                        None
                                                                         27. PRICE
EPA
       2270-1 (ft**. 4-77)   »RCviou« lO'

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EPA/ROD/RO3-86/033
Drake Chemical, PA
(Second Remedial Action)

16.  ABSTRACT  (continued)


chemicals at an offsite RCRA-permitted incinerator? and analysis and disposal  (if
needed) of the decontamination fluid in a RCPA-permitted facility.  The estimated
baseline capital cost for this remedy is $3,143,000 with no anticipated O&M costs.

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                            Record of Decision
                  Remedial Action Alternative Selection

Site:  Drake Chemical Site (Phase II), Lock Haven, Clinton County,
       Pennsylvania

Documents Reviewed:

     The underlying technical information, unless otherwise specified,
used for analysis of cost-effectiveness and feasibility of remedial
alternatives is included in the following documents and project
correspondence.  I have been briefed by my staff on their contents, and
they form the principal basis for my decision on the appropriate extent
of remedial action.

     -  "Remedial Investigation Report" - Phase II (Draft), Drake Chemical
        Site, Lock Haven, Clinton County, Pennsylvania.  (NUS Corporation,
        January, 1985, Revised April, 1985)

     -  "Feasibility Study of Alternatives - Phase II Building and
        Contaminated Structures" (Draft) - Drake Chemical Site, Lock Haven,
        Clinton County, Pennsylvania (NUS Corporation, March, 1986)

        Recommendations by the Pennsylvania Department of Environmental
        Resources.

        Staff summaries and recommendations, including the attached
        "Summary of Remedial Alternative Selection, Drake Chemical Site"
        (Phase II)

Description of Selected Remedy:

        Drain and remove two lined wastewater treatment lagoons.  Treat
        drained liquiJ and sludge In an offsite RCRA-pennltted treatment
        facility.

        Remove all tanks, buildings and debris.  Decontaminate all metal
        structures that can be salvaged as scrap.  Any material not
        decontaminated will be transported and disposed of in a RCRA-
        permitted landfill.  Any liquids removed will go to a RCRA-
        pennitted treatment facility.

        Incineration of chemicals stored in warehouse in an offsite
        RCRA-permitted incinerator.

     -  Analysis and disposal  'if- needed) of the decontamination fluid in
        a RCRA-pennitted facility.

Operation and Maintenance;

     No operation and maintenance is necessary for this phase of the
Drake Superfund Project.  This is an Interim phase to the ultimate remedy.
Phase III will address the remaining contaminated soils, chemicals,'
sludges and ground water contamination.

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                                    -2-
 Declaracion:
      Consistent with the Comprehensive Environmental Response, Compensation
 and Liability Act of 1980 (CERCLA) and the National Contingency Plan
 (40 CFR Part 300), I have determined that the remedial actions described
 above constitute a cost-effective remedy which mitigates and minimizes
 damage to the public health, welfare and the environment.  The remedial
 action will be designed to minimize any temporary inconveniences to the
 local population during the construction phase.

      The State of Pennsylvania has been consulted and agrees with the
 approved remedy.  No operation and maintenance is required for this phase
.of  the project.

      I have determined that the action being taken is appropriate when
 balanced against the availability of Trust Fund monies for use at other sites.
          Datfi
James
Self/
                                           Regional Adminisorator
                                               EPA Region IIf

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                -3-
        DRAKE CHEMICAL SITE
             (PHASE II)

      LOCK HAVEN, PENNSYLVANIA
             SUPERFUND
         RECORD OF DECISION
U.S. ENVIRONMENTAL PROTECTION AGENCY
             REGION III
          PHILADELPHIA, PA
                             William A. Hagel
                             Remedial Project Manager
                             April, 1986

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                                   -4-
                                 CONTENTS
Section                                                            Page

1.   Sice Background  Information	  5
2.   Nature and Extent of Problems	  7
2a.  Buildings, Tanks, and Debris	  7
2b.  Lined Lagoon	 16
3.   Health and Environmental Concerns	 21
.4.   Screening of Remedial Action  Technologies	 21
5.   Remedial Action Alternatives	 24
33.  Alternative 1	'.	 24
Sb.  Alternative 2...	 25
5c.  Alternative 3	 25
5d.  Alternative 4	 26
5e.  Alternative 5	 27
6.   Recommended Alternative	 27
7.   Compliance with Other Environmental Laws	 31
8.   Evaluation of Alternatives Not Selected	 31
8a.  Alternative 1	.	 31
8b.  Alternative 3	 32
8c.  Alternative 4	 32
8d.  Alternative 5	 32
9.   Proposed Action	 33
10.  State Concurrence	 34
11.  Responsiveness Summary	 35
12.  Alternative Matrix	 45

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                Summary of Remedial  Alternative  Selection

                        Drake Chemical  (Phase  II)
 1".  Site Background  Information;

     The Drake Chemical Site is  located  in  Lock  Haven,  Clinton  County,
 Pennsylvania.  The Drake Chemical  Site is bounded on  the west by  the
 American Color and Chemical Company.  An apartment  complex,  a shopping
 center, and Castanea Tornship Park are located within 1/4  mile  of  the
 site.  Bald Eagle Creek is located less  than  1/2 mile south  of  the  site,
.and the West Branch  of the Susquehanna River  is  located approximately 3/4
 mile north of the site.  A leachate stream  originates at the leachate
 lagoon and flows through Castanea  Township  to Bald  Eagle Creek.

     The eight-acre  site, shown  on Figure  I,  is  inactive and contains six
 major buildings, including former  offices,  production facilities,  and a
 wastewater treatment building.   Inside and  surrounding the process
 buildings are approximately 60 process tanks  and reactors.   Outside these
 buildings are approximately 10 large  tanks  that  were  used  for bulk storage
 of acids, bases, and fuel oils.  Also located on site are  two lined
 wastewater treatment lagoons, an unlined lagoon  (leachate  lagoon) from
 which a leachate stream originates, a second  small  unlined lagoon (canal
 lagoon), and an unlined sludge lagoon.   Chemical sludge and  contaminated
 soil covers or underlies much of the  open area on site and was. detected
 as deep as 20 feet below the ground surface.  Drums and bulk waste may
 also be buried at the 'site.  Construction debris is strewn about  the site.

     Drake Chemical, Inc., purchased  the site in 1962. Site use  before
 1962 is not completely known, but  it  is  reported that the  site  was used
 for the production of chemicals.   Aerial photographs  show  that  tanks,
 buildings, and a lagoon were located  on  the site between  1951 and 1959.

     The early production history  at  Drake  Chemical,  Inc., is unclear,
 but the facility had been involved for many years in  :he manufacture of
 batches of specialty, intermediate chemicals  for producers of dyes,
 oharraaceuticals, cosmetics, herbicides,  and pesticides.   The organic
 compound, 2,3 ,6-trichlorophenylacetic acid  (Fenac), a herbicide manufactured
 at the  plant, is a major site contaminant.   The  chemical  products were
 produced using the processes of  chlorination, cyanation,  sulfonation, and
 amination.  Most processes at Drake Chemical,  Inc., were not highly
 automated and required hand charging  of  chemicals  into reactor  vessels.
 Many waste streams produced during the various manufacturing processes
 were either treated  or placed directly in  drums  and stored on site. Much
 of the  former lagoon area onsite was  filled with treated and untreated
 process wastes and sludges, along  with demolition debris  and other
 miscellaneous fill materials.

     Drake Chemical, Inc., was cited  several time  between  1973  and 1982
 for violations of environmental  and health  and safety regulations.  After
 Drake  Chemical,  Inc.,  failed  to  respond  to a request  for  voluntary cleanup,
 the United States Environmental  Protection Agency  (EPA),  began  emergency

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HAMMENMLL MKR COMWNT
                                                                                                                            ),   *
                                                              AMERICAN OOUM AND CHEMCAL
                                                                                           FIGURE 1
                                            GENERAL ARRANGEMENT
                                    DRAKE CHEMICAL. INC. SITE. LOCK HAVEN. PA


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                                    -7-
cleanup activities at the site on February 28, 1982.  During the emergency
cleanup, surface drums and sludges and liquids from process and storage
tanks were removed from the site.  A fence was also erected around the
site.  The cleanup was completed on April 21, 1982.  The Environmental
Response team (ERT) of EPA perfsrmed an Extent of Contamination (EOC)
Study in March, 1982, which focused on the area around the leachate stream.
The results of this study were summarized in the Phase I Record of Decision
(September 30, 1984).

     In August, 1982, the EPA initiated remedial action studies at the
Drake Chemical site.  A Phase I (leachate stream) Remedial Investigation
Report was completed in August, 1984.  A draft RI report on the remainder
of the,site was released in April, 1985, while the Phase II (Buildings and
Structures) Feasiblity Study Report was completed in March, 1986.

2.  Nature and Extent of Problems

2a:  Buildings, Tanks, and Debris:

     Samples from buildings, process equipment and indoor and outdoor
tanks were collected during October, 1983 Co determine Che chemical
compounds contained in and about the buildings at the Drake Chemical Site.
Sampling points for the building samples included tanks, drippings on
floors and soil, rafters, sweepings, decomposed bags, ovens, centrifuges,
baths, open drums, filter presses, drains, and outdoor debris.

     Figure 2 shows building locations on site.  Figure 3 shows the layout
of Building I.  Figures 4 and 5 show the first and second floors of
Building 2.  Figures 6 and 7 show layouts of Building 3 and 4 respectively.

     Analysis for the building samples included the organics. on the
Hazardous Substances List (HSL), Fenac, Total Organic Halogens (TOH), and
beta-naphchylamine.  Fenac was detected in all but four of Che samples
analyzed for the compound.  Beta-naphthylamine was detected only in
Building I.  These samples were collected from ovens, the top of Tank
1-1, Tank 1-2, and a filter press.

     Building samples and analysis for the indicator compounds show
contamination in a concentration range of <0.1-460,000 ug/g of Fenac
(2,4,6 trichlorophenyl acetic acid), 30-232,000 ug/g of TOH and No
Detection - 3,800 ug/g of beta-naphthylamine.

     A wide range of organic compounds was detected during the investigation
at concentrations which varied from part-per-billion to percent levels.
Compounds with the highest concentrations were detected mostly in samples
from Buildings 1 and 2 and in debris samples from outside the buildings.

     The compounds detected are listed on Tables 1 and 2.

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                                                                       I  TRAILER  j
                                                                         •CVANIOC TANK
                                                                          LOCATION
   WASTEWATER TREATMENT BLOC
   LEGEND
*«O TANK NUMBER
           00
           I
                      BUILDING  LOCATIONS
           DRAKE CHEMICAL. INC. SITE. LOCK HAVEN. PA
                           SCALE l" = 60'
FIGURE 2

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  OVEN
OFFICES
                BASE FOR I-2
                BASE FOR 1-1-
              OVEN
               OVEN
              OVEN
                    BASE FOR 1-7—,
                                i	BASE FOR 0-1
BASE FOR Ml
                                                                      BASE FOR MO

                                                                  BASE FOR 1-9
LAB AND LAB STORAGE
                                                                 10  9       8
                                                                oo     o
                        BASE FOR I-4
                        BASE FOR I -5
                        BASE FOR 1-6
                                                     1   ICE CONVEYOR
                                                          13  14
                                                         OO
                                                                               »]—STEAM ROOM
                                                                      TOWER
                                                           ICE
                                                          8LDO.
                GENERAL ARRANGEMENT
                      BUILDING N« I
      DRAKE CHEMICAL. INC. SITE. LOCK HAVEN. PA
                       NOT TO SCALE
                                                                              FIGURE 3

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                       ICE CONVEYOR
2-26
o°"O
^-^ C J2-?*  *-»-•
           -26  2-24
                         oo
                         2-22 2-21
                  DOWN
                               T-3 T-2
                              CO
V_xfc-2O^-—^2-M
QQ
•o
  ^ri   2-4  2-5
-O OQoo
                                         DOWN
                      T-5  T-4
       GENERAL ARRANGEMENT
      BUILDING N«2 - SECOND FLDQR
  DRAKE CHEMICAL. INC. SITE. LOCK HAVEN. PA
           NOT TO SCALE
                                   FIGURE 6

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           DOOR
                                        CM
          DRUMS
       STACKED 2 S3 HIGH
SLIDING DOOR
                                    1 DOOR)
         GENERAL ARRANGEMENT
        BUILDING N« 3 - WAREHOUSE
DRAKE CHEMICAL. INC. SITE. LOCK HAVEN. PA
                NOT TO SCALE
                                                               FIGURE 6

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CAST LAGOON
          TANK 3
         CONCRETE
         OFT. HIGH
 WEST LAGOON
                                   HEAVY
                                  MACHINERY
                                                     TANK
                                                      4
                                                     4FT
                                                     HIGH
CONCRETE
                       PUMP
                                                                  FIGURE 7
           GENERAL ARRANGEMENT
      BUILDING N« 4 -TREATMENT BUILDING
  DRAKE CHEMICAL. INC. SITE. LOCK HAVEN.PA
                  NOT TO SCALE

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                                    -14-
                                  TABLE  1
                              BUILDING SAMPLES
  MAXIMUM CONCENTRATIONS OF BASE/NEUTRAL EXTRACTABLE ORGANICS (yg/g)
                            DRAKE CHEMICAL SfTE
         Parameter
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(ghi)perylene
Benze(k)fluoranthene
Bis(2-ethylhexyl) phthalate
Butyl benzyl phthalate
Chrysene
1,2-Oichlorobenzene
1,3-Oichlorobenzene
1,4-Dlchlorobenzene
Dimethyl phthalate
Oi-n-butyl phthalate
Di-n-octyl phthalate
1,2-Diphenylhydrazine
Fluoranthene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
lndeno(1,2,3-cd) pyrene
Isophorone
Naphthalene
(Nitrobenzene
Phenanthrene
Pyrene
1,2,4-Trichlorobenzene
Aniline
4-Chloroaniline
2-Methylnaphthalene
Maximum Concentration

      <2Q
      42,0000
      6.5Q
      14Q
      <5Q
      14Q
      78
      9.9
      25Q
      22. OOOQ
      27, OOOQ
      48Q
      23Q
      <600Q
      <2
      <4
      11Q
      1,381
      120Q
      110,OOOQ
      <2
      <5Q
      64Q
      2.000Q
      1.5Q
      850O
      8.4Q
      2,705
      61O
      29,504
      4.500Q
Building Number

    1
    1
    1
    1
    1
 .   1
    2
    2
    2
    1
    2
    1
    1
    outside
    2
    2
    1
    outside
    outside
    2
    outside
    1
    outside
 .   outside
    2
    outside
    1
    outside
    5
    2
    outside
           micrograms per gram
Q:         questionable'analysis based on resu'ts of data validation
<:         less than
outside:    outside tank, exterior of building, or debris surrounding building

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                                    -15-
                                   TABLE 2
                             BUILDING SAMPLES
              MAXIMUM CONCENTRATIONS OF ACID EXTRACTABLE.
                  VOLATILE. AND PESTICIDE  ORGANICS (U8/Q)
                            DRAKE CHEMICAL SITE
         Parameter
2-Chlorophenol
2,4-Dimethylphenol
Phenol
Benzole acid
2-M«thylphenol
Benzene
Chlorobenzene
Chloroform
Ethyl benzene
Methyl chloride
Methyfene chloride
1.1,2,2-Tetrachloroethane
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
Trichloroethylene
Trichlorofluoromethane
Acetone
2-Hexanone
4-Methyl-2-pentanone
Xylenes (total)
beta-BHC
gamma-BHC
delta-BHC
4,4'-ODT
4,4'-ODE
4,4'-DDD
Dieldrin
alpha-Endosulfan
beta-Endosulfan
PCS-1254
Maximum Concentration

      0.32Q
      430,0000.
      <10,OOOQ
      300,OOOQ
      <10,OOOQ
      <2,500Q
      32,130
      <2,500Q
      <2,500Q
      35Q
      7.440Q
      <0.005
      33Q
      <2.500Q
      0.009
      0.029  .
      < 5, OOOQ
      0.97
      0.031
      0.024
      <2,500Q
      190Q
      62Q
      140Q
      200Q
      5.1Q
      100Q
      3.3Q
      67Q
      5.3Q
      11Q
Building Number

   2
   outside
   outside
   1
   outside
   2
   outside
   2
   2
   outside
   outside
   2
   outside
   2
   4
   2
   2
   4
   2
   2
   2
   2
 -  2
   2
   outside
   outside
   outside
   outside
   2
   outside
   2
ug/g:      micrograms per gram
<:         less than
Q:         questionable analysis based on results of data validation
outside:    outside tank, exterior of building, or debris  surrounding building

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                                   -16-

     Organic compounds detected in 10 or more samples are  listed  below.   The
number of times detected is in parentheses:

     0  Chlorobtnzene (26)
     0  Bis(2-ethylhexl)phthalate (20)
     0  Toluene (19)
     0  Methylene chloride (17)
     0  Benzo(a)anthracene (16)
     0  Acetone (14)
     0  Benzoic acid (13)
     0  Benzene (13)
     0  Trichloroethylene (13)
     0  1,3-Dichlorobenzene (12)
     0  Chloroform (10)
     0  Ethyl benzene (10)
   •  -* - Total xylenes (10)

     The cyanide tank beside Building'2 (see Figure 4) was not sampled.
The material in the tank was thought to be a solid; the level in  the tank
was estimated by tapping the side of the tank.  The difficulty in obtaining
a sample of the material inside the tank and the danger of opening a
sealed cyanide tank to the atmosphere led the samplers to conclude that
it would be unsafe to*open the tank.   A former employee stated that the
tank contained cyanide salts.

2b:  Lined Lagoons:

     The two lined wastewater treatment lagoons located near the  center of
the site were sampled during August,  1983.

     Lagoon surface water samples were analyzed for the organics  and
inorganics on the HSL, Fenac, TOH, TOG, sulfate, chloride, ammonia, pH,
and conductivity.  Lagoon sediment samples were analyzed for the  organics
and inorganics on the HSL and Fenac.

     The surface t-ater and sediment analysis for these lagoons are
summarized in Tables 3,4,5 and 6.

     Based on the chemical analyses,  it appears that water and sediment
in the lined lagoons are contaminated with metals, Fenac, and other
organic compounds.  The waters are also acidic with pH values of  2.3. and
2.4.

     The integrity of the liners is not known.  A leak in a liner could
cause contaminants to migrate to soil beneath the lagoons, then to
ground water, or could cause migration as a seep from the banks of the
lagoon.  A large amount of. rainfall could cause the lagoons to overflow.
Bald Eagle Creek could flood to an extent that would inundate the lagoons.
The site is in the 100-year floodplain.  Flooding could cause contaminants
to migrate to surface water, sediment, soil, and/or ground water.
Contaminant migration to the air was not evidenced during the investigation.

     The estimated total volume of liquid and sediments in the two lagoons
is 192,000 gallons.

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                                    -17-

                                  TABLE  3
                   LINED LAGOONS - AQUEOUS PHASE DATA
      CONCENTRATION RANGES OF INORGANIC AND INDICATOR PARAMETERS
                            DRAKE CHEMICAL SITE
 Parameter
Aluminum
Antimony
Cadmium
Chloride
Chromium
Conductivity
Copper
Cyanide
Iron
Lead
Manganese
Mercury  .
Nickel
pH
Sulfate
Zinc
Fenac
TOH
TOC
       On Site
6,000 - 6,810
<20 - 118
4.2 - 7.0
776,000 - T, 170,000
39 - 120
5,600 - 6,400
679 - 1,130
17 - 53
20,800 - 25,500
26 - 38
505 - 591
0.7 - 1.1
60 - 122
2.3 - 2.4
850,000 - 1,000,000
398 C - 429 C
13.100Q - 15.275Q
48.560 - 55,900
3.000 - 255.000
Field Blanks
<100
<20
 5.8
< 1,000
< 5,000
<50
 25
<50
<5
 0.3
<40
 NA
<5,000
 32 C
 ND
 NO
< 1,000
All  analyses  expressed   in  ug/l   (micrograms  per  liter)  except  conductivity
(umhos/cm) and ph (units).          --.
<:    less than
C:    corrected for lab blank
Q:    questionable data based on data validation
NA:   not analyzed
TOH:  total organic halogen
TOC:  total organic carbon

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                                   -18-
                                  TABLE  4
                   UNEO LAGOONS - AQUEOUS PHASE DATA
                    CONCENTRATION RANGES OF ORGANICS
                            DRAKE CHEMICAL SITE
         Parameter
Acenaphthene
Benzo(a)anthracene
Benzo(a)pyrene
B's(2-ethylhexyl)phthalate
Dl-n-butyl phthalate
Di-n-octyl phthatate
Naphthalene
Phenanthrene
Pyrene
Benzyl alcohol
4-Chloroaniline
2,4-Oimethylphenol
Pentachlorophenol
Phenol
Benzole acid
2-Methylphenol
4-Methylphenol
2,4,5-Trichlorophenol
Chlorobenzene
Ethyl benzene
Methylene chloride
Toluene
Acetone
Carbon disulfide
  On Site

NO - <4Q
NO - <1Q
NO - <1Q
NO - <1Q
NO
NO
NO - 80Q
NO - <3Q
NO - <2Q
NO - <4Q
NO - <10Q
60Q - 946
NO - <3Q
NO - 155C
NO - <40Q
NO - <2Q
NO - 10Q
NO - <25Q
13 - 120
NO - 0.8
NO - 57
NO - 25
1  - 180
NO - 10
Field Blanks

    NO
    NO
    NO
 NO - 10.3
 NO - 13.4
 ND-- 1.5
    NO
    NO
    NO
    NO
    NO
    NO
    NO
 NO - 8.2
    NO
    NO '
    NO
    NO
    NO
    NO
    NO
    NO
    NO
    NO
All analyses expressed in yg/l (micrograms per liter).

NO:   not detected
<:    less than
Q;    questionable concentration based on data validation
C:    corrected for lab  blank

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                              -19-
                            TABLE 6
                 UNEO LAGOONS - SEDIMENT DATA
              CONCENTRATION RANGES OF INORGANICS
                       DRAKE CHEMICAL SITE
  Parameter
 Aluminum
 Arsenic
 Barium
. Beryllium
 Cadmium
 Chromium
 Copper
 Cyanide
 Iron
 Lead
 Manganese
 Mercury
 Nickel
 Selenium
 Tin
 Zinc
    On Site
875 - 2,190
1.8 - 2.5  .
17.9 - 36.8
<0.25 - 0.3
0.34 - 1.0
6.6 - 7.8
189 - 218
219 - 300
2,900 - 4,540
4.8 - 6.3
12 - 29.1
0.7 - 0.85
5.3 - 11.4
0.1
<1 - 4.4
8.8C - 16C
 All analyses expressed in mg/kg (milligrams per kilogram)
 <:  less than
 C:  corrected for lab blank

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                                    -20-

                                 TABLE  6
                      UNED LAGOONS - SEDIMENT DATA
                    CONCENTRATION RANGES OF ORGANICS
                            DRAKE CHEMICAL SITE
         Parameter
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(ghi)perylene
Benzo(k)fluoranthene
Butyl- benzyl phthalate
Chrysene
1,4-Dichlorobenzene
Fluoranthene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Phenanthrene
Pyrene
1,2,4-Trichlorobenzene
Benzene
Carbon tetrachloride
Chlorobenzene
2-Chloroethylvinyl ether.
Chloroform
Ethyl benzene
Methylene chloride
Tetrachloroethylene
Toluene
Acetone
o-Xylene
Dieldrin
Fenac
     Onstte
ND - 105.000O
ND - 250
ND - 450
ND - 100
ND - 340
ND - 110
ND - 270
ND - 70,0000.
ND - 360
ND - 120.000Q-
ND - 350,0000
ND - 160
ND - 290
ND - 71.000Q
ND - 600
ND - 800
90.000 -  5,000,000
ND - 21,000
ND - 9,400
8,000 -  100,000
3,000 - 6,000
3,000 - 8,000
ND - 4,500
ND -.13,000
64,000 -  1,000,000
ND - 2,400
1.04 - 3.156Q
All analyses expressed in ug/kg (micrograms per kilogram)

Q;  questionable analysis based on data validation
ND: not detected

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                                    -21-

 3:  Health and Environmental Concerns;

      Present impacts of  Che lined lagoons are negligible, except from
 direct contact.  Potential impacts could arise in the event of flood,
 lagoon overflow, 'or liner failure.

      Of greater  importance is the widespread building contamination.  The
 greatest risks to human health are associated with direct contact with
 the contaminants, many of which are highly toxic or carcinogenic.  Beta-
 naphthylamine is a potent human bladder carcinogen which has been detected
 at high levels in Building 1.  This compound has been the focus of a
 health screening being performed in the Lock Haven Area by the Pennsylvania
-'Department of Health, Division of Environmental Epidemiology.

      The buildings are presently in a dilapidated condition and continue
 to deteriorate, causing a hazard from collapse.  A fire could cause
 contaminants to be released to the air.  A flood could wash away contaminants
 present in the buildings, debris piles, and contaminated structures.

      There has also been recent evidence of trespass at the site even
 though the site is fenced and the gates are locked.  A portion of the
 fence has been cut out and a hole large enough for human entry is present.

      The objective of remedial action for Phase II at the Drake Chemical
 Site is to reduce or eliminate exposure pathways by which building
 contaminants may reach potential receptors.  The exposure pathways of
 most concern are as follows:

      0  Direct contact with contaminated areas on site
      0  Potential migration of contamination via fire or flood

      General response actions and associated remedial technologies have to
 be developed to meet the stated objectives.

 4:  Screening of Remedial Action Technologies:

      Feasible remedial technologies for che buildings at the Drake. Chemical
 Sice have been identified by screening general response actions for
 application co site problems caused by che buildings and contaminated
 structures and by evaluating site-specific information obtained for the
 buildings during the Remedial Investigation (RI).  Each general response
 action consists of one or more associated technologies that are also
 considered for applicability.   The Drake Chemical Site general response
 actions and associated technologies for the buildings and contaminated
 structures are presented in Table 7.

    .  The technologies were then studied and reviewed in depth using the
 following criteria:
      0  Technical
      0  Environmental/Public Health
         Institutional
         Cost

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                                                      TABLE 7
                                PHASE II - BUILDINGS AND CONTAMINATED STRUCTURES
                                      PRELIMINARY SCREENING OF TECHNOLOGIES
                                                DRAKE CHEMICAL SITE
   General Response Actions and
 Associated Remedial Technologies

1.    No Action
     Capping
3.    Pumping

4.    Collection
     a.  Sedimentation Basins
     b.  Gas Vents
     c.  Gas Collection System

5.    Diversion
     a.  Grading and Revegetatlon
     b.  Dikes and Levees
     c.  Diversion Ditches. Trenches
     d.  Benches. Chutes

6.    Co.mplete Removal
Applicable    Excluded
Comments
                         Retained to meet the requirements of the National
                         Contingency Plan (NCP).
                         Not applicable because of site characteristics
                         (insufficient space on site).

                         Applicable for the lined wastewater treatment lagoons.
                         a.  Applicable to new landfill.
                         b.  Not applicable to site conditions.
                         c.  Not applicable to site conditions.
                         a.  Applicable for general site Improvement.
                         b.  Applicable for flood protection.
                         c.  Applicable for surface water control for landfill.
                         d.  Applicable for surface water control for landfill.

                         Tanks, buildings, debris, and the lined lagoons can be
                         completely removed from the site.
                                                                                                                    i
                                                                                                                    to
                                                                                                                    K>

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TABLE 7 (cent.)

PHASE II - BUILDINGS AND CONTAMINATED STRUCTURES
PRELIMINARY SCREENING OF TECHNOLOGIES
DRAKE CHEMICAL SITE
   General Response Actions and
  Associated Remedial Technologies

7.    Partial Removal
      (Same as General Response
      Action 6)

8.    Onsite and Offslte Treatment
      a.  Incineration
      b.  Solidification

      c.  Land Treatment

      d.  Biological Treatment (On site)
      e.  Physical/Chemical Treatment
         (On site)

9.    Storage

10.   Offslte Disposal
 11.   Onsite Disposal

 12.   Relocation
Applicable    Excluded
Comments
                         Applicable only If site characteristics preclude complete
                         removal.
                         a.  Applicable for some waste material.
                         b.  Not applicable because of site and waste
                            characteristics.
                         c.  Not applicable because of site and waste
                            characteristics.
                         d.  Not applicable because of waste characteristics.
                         e.  Not applicable because of waste characteristics.
                         Temporary storage during construction only.

                         Applicable to this site using a commercial facility or a
                         newly constructed landfill nearby.

                         Not applicable because of site characteristics.

                         Not applicable to this site.
                                U)
                                 I

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                                    -24-

     -Feasible remedial technologies chat remained after this screening
 process were then combined into Remedial Action Alternatives that can be
 applied to the remediation of the buildings and contaminated structures
 at the Drake Chemical Site.

 5:  Remedial Action Alternatives;

      Various remedial action alternatives were developed by assembling
 appropriate remedial technologies into groups of actions to address the
 objectives of the remedial action.  The development of remedial action
 alternatives to remove the contaminated buildings and structures onsite
 is consistant with the various categories of cleanup as required by the
 NCP, Section 300.68.  However, some of these categories may not be filled
^since the only practical alternatives, except no action, must be designed
 to meet RCRA requirements (i.e. transportation and ultimate disposal).

   •  Tfie* referenced categories are as follows:

      0 I   - Alternatives for treatment or disposal at an offsite facility
              approved by EPA.

      0 II  - Alternatives that attain applicable or relevant and appropriate
              Federal public health or environmental standards.

      0 III - Alternatives that exceed applicable or relevant and appropriate
              public health or environmental standards.

      0 IV  - Alternatives that reduce the likelihood of present or future
              threat and  meet CERCLA objectives of adequately protecting
              public health, welfare, and the environment.

      0 V   - No action alternative.

      In addition,  the remedial action alternatives must be further defined
 as a source control remedy, or a management of migration remedy, as required
 in the NCP (40 CFR 300.68'(d)).

      Alternatives  that include provisions for flood protection  assume
 chac flood protection measures for Lock Haven proposed by the U.S. Army
 Corps of Engineers (USACOE) will noc be implemented before remedial action
 cakes place at the Drake Chemical Site.

 5a:   Alternative 1 - Tank, Building, Debris, and Lined Lagoon Removal
      with Offslte  Disposal at a RCRA-Approved Facility;

      The purpose of this alternative Is to dismantle all structures for
 offsite disposal.   Included are the  following tasks:

      0  Draining and removal of the  two lined wastewater treatment lagoons,
         with offsite treatment of liquid and sludge in a RCRA-approved
         treatment  facility.

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                                    -25-

      0   Removal  of  canks,  buildings,  and debris.
      0   Incineration  of  chemicals  stored in  warehouse.
      0   Disposal of all  other materials, without decontamination, in an
         offsite, RCRA-approved  landfill.

      Remedial Action  Alternative 1  is classified as a source control
remedy.  This alternative  calls for the dismantling of all buildings in a
controlled fashion.   Tanks, debris, and the  lined lagoons would also be removed.

      All dismantled buildings,  tanks, etc.,  will be loaded onto trucks,
without decontamination, and hauled to the nearest offslte, RCRA-approved
landfill for disposal.   Liquid wastes will be hauled away for appropriate
treatment or disposal.   Precautions would be taken to minimize any release
d'f contaminants during transport.

     .This alternative's  baseline capital cost is $3,632,000.  There are
no operation and maintainence costs anticipated.

5b:   Alternative 2 -  Tank, Building, Debris, and Lined Lagoon Removal.
      Decontamination, and  Offsite Disposal;

      The purpose of this alternative is to dismantle all structures,
decontaminate salvageable  material (metals), dispose of all other
structures in an offsite RCRA-approved landfill.  Included are the
following tasks:

      0  Draining and  removal of the two lined wastewater treatment lagoons
        with offsite  treatment of liquid and sludge in a RCRA-approved
        treatment facility.                                     •
      9  Removal of tanks,  buildings, and debris.
      0  Incineration  of  chemicals stored in warehouse.
      0  Decontamination  of salvageable material (metals, steril structures,
        etc.)
      0  Disposal of decontamination fluids and other liquid wastes.
      0  Disposal of all  materials, other than decontaminated netals, in a
      RCRA-approved landfill.

      Remedial Action  Alternative 2 is classified as a source control
remedy.  This alternative  calls for the dismantling of all buildings in a
controlled fashion.   Tanks, debris, and the  lined lagoons would also be
removed.  Salvageable materials (metals) would be cleaned and decontaminated,
as required, prior to being turned over to the contractor.  All other
material or structures would be loaded onto trucks and hauled to an
offsite, RCRA-approved facility.  This alternative's baseline capital cost
is $3,143,000.  There are  no operation and maintenance costs anticipated.

5c:   Alternative 3 -  Tank, Building, Debris, and Lined Lagoon Removal
      with Offslte Disposal Dependent on the Amount of Contamination:

      The purpose of this alternative is to dismantle all structures,
separate contaminated and  uncontaminated materials based on wipe sampling,
dispose of all contaminated materials in an offsite, RCRA-approved
landfill, and dispose of all uncontaminated material in an offsite demolition

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                                    -26-

 wasce landfill or other approved offsite facility.  Included are the
 following tasks:

      9  Draining and removal of the two lined wastewater treatment lagoons
         with offsite treatment of liquid and sludge in a RCRA-approved
         treatment facility.
      0  Incineration of chemicals stored in warehouse.
      9  Sampling of the tanks, buildings, and debris to determine which
         materials are contaminated and which materials are not contaminated.
      0  Removal of tanks, buildings, and debris.
      0  Disposal of contaminated materials in an-offsite, RCRA-approved
         landfill.
./     °  Disposal of non-contaminated materials in an offsice, demolition
         waste landfill or other approved offsite facility.

      Remedial Action Alternative 3 is classified as a source control
 remedy.   This alternative calls for the dismantling of all buildings in a
 controlled.fashion.  Tanks, debris, and the lined lagoons will also be
 removed.  All materials will be loaded onto trucks and hauled to an
 appropriate offsite facility according to the amount of contamination
 present  on the various materials involved with this operable unit.
 This alternative's baseline capital cost is $3,488,000.  There are no
 operation and maintenance costs anticipated.

 5d:   Alternative 4 - Tanks, Building, Debris, and  Line Lagoon Removal;
      Offsite Disposal in a New Landfill Constructed Adjacent to the Site:

   •  The purpose of this alternative is to dismantle all structures,
 construct a new RCRA-designed landfill adjacent to the site, and dispose
 of all materials in this landfill.  Lagoon waste and chemicals In the
 warehouse would be treated offsite.

      The following tasks will be implemented as part of this alternative:

      0  Draining and removal of the two lined wastewater treatment lagoons
         with offsite treatment of liquid and sludge in a RCRA-approved
         treatment facility.
      0  Incineration of chemicals stored in warehouse.
      3  Construction of a flood protection dike to protect against a
         100-year flood.
      0  Construction of a double liner landfill within the area protected
         by the flood dike.
      0  Removal of tanks, buildings, and debris with disposal in the newly
         constructed landfill.
      0  Capping, grading, and revegetation of the landfill and adjacent
         areas.
      0  Performance of post closure monitoring.

      Remedial Action 4 is classified as a source control remedy.  This
 alternative calls for dismantling of all buildings in a controlled fashion.
 Tanks, debris, and the lined lagoons would also be removed.  A landfill
 would be constructed on property located between the railroad tracks and
 the Route 220 embankment.

-------
                                    -27-

      Thls alternative requires the constru.-.rion of a levee to protect the
 landfill from potential floods.  This compacted, earthen levee would be
 covered with vegetation and rip-rap as floodwater velocity protection
 measures.  The elevation of the flood protection dike would be 565.5 MSL
 and  would be based on the USACOE 100-year flood stage developed for the
 proposed Lock Haven Flood Control Project.-

      The first step would be the construction of the flood protection
 dike since this area is prone to flooding.  A RCRA-style,  double-liner
 landfill would then be constructed within the flood protection dike (see
 figure  8).  As the buildings and contaminated structures are dismantled,
 they would be graded and capped with a multimedia cap.   The impervious
 zones of the cap and the liner would be connected to encapsulate  the waste.
-The  area would then be revegetated.

      Leachate generation from the new landfill  is expected to be  minimal
 because  of the nature of the wastes  (dismantled building materials).  Any
 leachate that is generated would be  collected and hauled away for
 appropriate treatment or disposal.

      The area required for the construction  of  :he flood protection dike
 and  the  landfill will require the purchase of land adjacent to the  site.
 This property is in Castanea Township in the Clinton County Renewal Area.
 This  area is  the former residential  area where  the housing was removed
 when the area was dedicated as a corridor for Route 220.  This option's
 baseline capital cost is $2,894,000.   The operation and  maintenance cost
 for  this alternative is estimated to be $41,000 annually.
                                               *                   - '

 5e:   Alternative 5 - No Action:                                 :

      Remedial Action Alternative 5 involves  taking no remedial action to
 remove  tanks,  buildings, debris,  or  the lined lagoons.   The buildings and
 tanks would continue to deteriorate,  presenting a hazard from collapse.
 The  direct contact risk and the  possibility  of  contaminant migration by
 airborne particulates would remain.   Contaminants present  in the  buildings
 and  contaminated structures could migrate during a fire  or a flood  causing
 potential exposure to downstream or; downwind receptors.

 6:   Recommended  Alternative:

      Section  300.68 (i) of the NCP states that  the appropriate extent of
 remedy shall  be  determined by the lead  agency's selection  of a remedial
 alternative which the agency determines is cost-effective  and which
 effectively mitigates or minimizes damage to and provides  adequate
 protection of the public health,  welfare and the environment.  In selecting
 a remedial .alternative EPA considers  all environmental laws that  are
 applicable or relevant and appropriate.  Based  on the evaluation  of cost-
 effectiveness of each of the proposed alternatives,  the  comments  received
 from the public, information from the Feasibility Study  and recommendations
 from the Pennsylvania Department  of  Environmental Resources,  we recommend
 that Alternative No. 2 as  described  above, be designed and implemented
 as Phase II of the Drake Chemical Superfund  Project.

-------
LANDFILL AND FLOOD PROTECTION DIKE PLAN VIEW
    DRAKE CHEMICAL.INC.SITE. LOCK HAVEN.PA
                                                                                                 Fiaum •

-------
                                    -29-

     -This  selected  remedy will  be  designed  to meet  the  Phase  II  remedial
action objective  of reducing  or eliminating exposure  pathways by which
building contaminants  may reach potential receptors.

     For this alternative,  the  dismantling  and  removal  of  the buildings,
process equipment,  tanks,  debris and  lined  wastewater lagoons will utilize
common, well-established  methods that  involve standard  engineering
practices.

     Building floors,  foundations,  roofing, and walls and  all process
equipment  and other building  contents  would be dismantled  using  conventional
construction practices.   The  use of explosives would not be permitted.
Shoring and bracing would  be  provided  during the dismantling.  Walls
would be removed  from  one  story at  a  time.  Masonry walls  would  be
dismantled in small sections.   Structural steel would be removed  in
individual pieces and  lowered carefully to  the ground.  Constant  dust
control* would be maintained during  all operations.  Walls  and other
structures would  be wetted down prior  to dismantling.   Water used for
dust control would  be  collected where  possible.

     Salvageable material, such as  metal tanks or steel beams, would be
cleaned and decontaminated, then turned over to the contractor for salvage
as scrap metal.   One of the building  pads can be used as a decontamination
pad if a curb is  installed to contain  decontamination fluids; however,
it may be more cost-effective to use  the decontamination pad which will
be constructed onsite  as  part of the  Phase  I remedy.

     It is anticipated that a low-volume, high-pressure water spray system
would be used for decontamination.  This method minimized  the volume of
decontamination water  requiring offslte treatment.  For cost estimating
purposes,  the volume of material that  can be decontaminated for disposal
as non-hazardous waste were estimated  based on building use and  type of
material.  Tanks and structural steel  were considered as salvageable or
as scrap.

     It is estimated that  a total of  3,900  cubic yards  of  building
material and site debris  wil_ need  to  be removed.  Of this, approximately
200 tons of metals  may be  decontaminated and salvaged as scrap.   Quantity
estimates  for each  building are shown  in Table 8.

     All materials  that are not metal  and therefore not decontaminated
will be loaded on trucks  and  transported to a RCRA-permitted hazardous
waste landfill for  ultimate disposal.

     The chemicals  which  were stored in the warehouse on site will be
removed, loaded onto trucks and transported to a RCRA-permitted hazardous
waste incinerator for  destruction.  These stored chemicals were  the Drake
Chemical Co. stockpile that were to be used in their processing.  However,
since they have been stored for over  four years, determination of their
salvage value would, be difficult at best.

     There are currently  two  lined  wastewater lagoons onsite which
Drake used for a  short period of time  in an effort to pre-treat  the
facility's effluent  before discharge.  The  amount of liquid which is in

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                                               TABLE 8
                               ESTIMATED BUILDING DISMANTLING QUANTITIES
                                           DRAKE CHEMICAL SITE
Building
Material
Floor
Footer
Wall
Roof
Misc.
Total
Building
1
203
117
160
217
178
875
Building
2
413
129
127
51
638
1.358
Building
3
154
69
71
6
27
327
Building
28
19
72
8
	 6
133
Building
5
105
49
67
15
82
318
Building
6
14
23
67
1
5
110
Site
Dubrls
-
-
-
779
779
Total
917
406
564
298
1.715
3.900
                                                                                                             OJ
                                                                                                             O
                                                                                                             I
All value expressed as cubic yards.

For transportation cost estimation, volumes were multiplied by a factor of
1.45 to account for void spaces after bulking.

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                                    -31-

 che  lagoons at-any given time is dependent upon the balance of precipitation
 as opposed to evapotranspiration and possibly leakage.   The lagoons were
 sampled and analyzed and the sediment was found to be grossly contaminated
 with a variety of organic compounds.  These lagoons will be drained and
 all  sediment will be removed and taken to a RCRA-permitted treatment
 facility.   The liner of the lagoon will be removed and  loaded onto trucks
 for  disposal at a RCRA landfill.   The earthern lagoon structure will then
 be sampled and, if necessary, leveled, transported and  disposed of properly.

      The location of some buried pipelines is known at  this time;  however,
 there may  be other unidentified  pipelines.  Utilities that serviced the
 buildings, especially sewers, are assumed to  be contaminated.   These
.utilities  would be abandoned, and the pipes would  be plugged.   Buried
 pipes associated with plant operations will be addressed during the Phase
 III  remediation.

      Utilities that cross the site and serve  other properties  would be
 temporarily or permanently moved or replaced  if they interfere with
 implementation of remedial actions.

 7.   Compliance Witt? Other Environmental Laws:
      The  selected  remedial  action  alternative  was  evaluated  in  the  context
of site remediation  in  compliance  with  the  NCP which  requires that  Federal,
State and local  laws and  regulations  be considered.

      Applicable  Federal regulations include the following:

      0  Resource Conservation  and  Recovery  Act (RCRA)
      8  Occupational Safety and  Health  Administration  (OSHA) guidelines
      0  Department of Transportation  (DOT)  hazardous materials  transportation
        regulations.

      All  disposal  of hazardous material,  aqueous or  solid, will  be  hauled
by licensed  operators and will be  disposed  of  at RCRA-permitted  hazardous
waste facilities.  All  manifest  requirements will  be  implemented for
loaded hauls.

      All  licensed  haulers must meet all DOT equipment  and  transportation
requirements.

      All-work  will be performed  under OSHA  guidelines  for  work  at hazardous
waste facilities.

8:   Evaluation of  Alternatives Not Selected;

8a:   Alternative 1 • Removal with  Offsite Disposal at  a RCRA-Approved  Facility.

      Although  this alternative gives  the same  results  as the selected
option it does not attempt  to  decontaminate salvagable metal, and therefore
allows for the maximum capacity  of on-site  material  to be  disposed  in  a RCRA
facility.

-------
                                    -32-

 8b;   Alternative  3  -  Removal  with Offsite Disposal Dependent on the Amount
      of  Contamination.

      In  this  option wipe  samples  would  be taken of all materials to
 determine  the extent  of building  contamination.  Based on this  analysis,
 a  determination will  be made  as  to the  location of ultimate disposal.
 The  problem of sampling a representative  amount of material for contamination
 determination would make  implementation of this option slow and tedious.
 Sample verification through quality assurance  checks  would need to  be
 completed  before  any  onsite material is transported offsite.  Verification
 that material is  not  contaminated (even with wipe sample  analyses)  for
 disposal in a municipal landfill  would  be difficult.   Since there is not
-a  lot of room onsite  for  a staging area,  dismantling  of the buildings
 would be slow, and  at times stopped waiting for sample analysis. Continuity
 of work  would be  solely dependent upon  laboratory efficiency.

 8c:   Alternative  4  -  Offsite  Disposal in  a New Landfill Constructed Adjacent
      to  the Site.

      One of the problems  with the option  is the aqulsition of  land  to
 build tne  landfill.   EPA  would have to  rely on local  government to  dedicate
 land for a construction.   Realization of  that  scenerio is not  very
 plausible.  In addition,  because  the landfill  would be constructed  within
 a  100-year floodplain, a  flood protective dike/levee  system would need
 to be constructed.  This  may  conflict with the U.S. Army  Corps  of Engineers,
 which is currently  planning a flood control levee in  the  Lock  Haven
 Area.  Thirdly, this  option has met with  great opposition from local
 officials  and the public  when discussed at the public meeting.

 8d:   Alternative  5  -  No Action.

      The purpose  of reviewing the no action alternative is to  estimate
 the  effect of not performing  remedial actions  on the  buildings  and
 contaminated  structures.

      Under the no action  alternative, the buildings would remain standing.
 This alternative  does not address the remediation of  Che  buildings, nor
 does it  address  the potential threat to the environment or public health
 via  uhe  associated  contamination  oathways.

      The potential  for direct contact with contaminants in the buildings
 and  contaminated  structures would not be  addressed.  There is  also  the
 possibility of offsite migration  via ^airborne  particulates or  by a  fire
 or flood.

      If  No Action was chosen  at  this time it would only delay the
 inevitability of  building removal, probably until Phase III.  Removal of
 the  buildings and structures  now  would  also enhance any remedial action
 taken in Phase III.

      A comparison of  all  alternatives can be  found in the Alternatives
 Matrix (Table 9).

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                                   -33-

9:  Proposed Action

     We request your approval of the recommended alternative.  The
estimated base capital cost for this option Is $3,413,000.  There are
no operation and maintenance costs for this alternative.

-------
                            -34-
k                    COMMONWEALTH OF PENNSYLVANIA                '««lfji
                 DEPARTMENT OF ENVIRONMENTAL RESOURCES
                             Po«t Offlca Box 2063                  /
f                        Haniaburg, Pennsylvania 17120             ^
 MafMganwnt                       April 15, 1986
                                                               717-787-7816
L Wassersug, Director                                   r               |[
iste Management Division                             |f                  'J
icntal Protection Agency                                 APR 2' ':: - J

Building
:nut Street
PA 19107

sersug:                                              ;

»e draft Record of Decision document for the Phase II cleanup at the Drake
erfund site  was received on April 11, 1986. The draft document has been reviewed
:ment staff. The Department concurs with the EPA's decision for this phase of the
selected alternative, which removes the buildings and lagoons while decontaminating
;1,  will best protect the public health and the environment while minimizing the
terials that will need to be disposed of at a RCRA  landfill.

ir ' -stand that the estimated cost of this phase of  the project is $3,^13,000,  and
     juire any operations and maintenance activities. The Department, of course,
3 c. Contract to provide  10 percent of the cost of the project.

us site has been a major concern for the people of Lock Haven for many years and I
vill continue to be a high priority site  for both the Department and EPA. This
iruction project will be a major step in the process of successfully completing a
janup of the site.  I can assure you that the Department wilf continue to cooperate in
ble in order to expedite  the cleanup of this site.  If you have any questions regarding
ilease do not hesitate to contact me.
                                   Sincerely,
                                            Snydery^Assistant Director

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                                     -35-


                            RESPONSIVENESS SUMMARY
                             DRAKE CHEMICAL SITE
                           LOCK HAVEN, PENNSYLVANIA
     This community relations  responsiveness summary is divided into  the
following sections:

Section I.      Overview.   A discussion  of  the  EPA's preferred alternative  and
               the public's expected response  to  this  alternative.

Suction II.     Background  of Community  Involvement and Concerns.  A discussion
               of the history of community  interest and concerns raised during
               the remedial planning activities at the Drake Chemical  Site.

Section III.    Summary of  Major Comments Received  during the Public   Comment
               Period and  Agency Responses.
               responses categorized by topic.
               Period and  Agency Responses.summaryof commentsand
                               •1z<
Section IV.     Remaining Concerns.   A discussion of community  concerns  that
            the EPA and the Pennsylvania  Department of Environmental Resources
            (PADER) should  consider  In the remedial  design  and construction
            phases at  the Drake Chemical Site.

I.  OVERVIEW

At the time of  the public comment period, the EPA had Identified a preferred
alternative  for Phase  II  remediation of the Drake Chemical  Site.  Although the
agency expressed a preference,  1t  presented  a  total  of  five remedial  action
alternatives  1n  the  draft  feasibility  study   report.   The  preferred
alternative,  referred to as Alternative 2,  consists of the removal  of all
tanks, buildings,  and debris; drainage and removal  of the lined  lagoons;
removal  and  Incineration   of  the  chemicals 1n  the onslte warehouse;
decontamination of metals and removal  from  the  site as scrap; and disposal of
all contaminated materials  in an  offsite, RCRA-permitted, secure landfill.

Comments received during the  public comment period indicate that residents and
local  officials,  as  well  as the  PADER,  strongly  support Alternative 2.
Comments also  showed  that  the community and community  officials  vehemently
oppose Alternative  4 which  provides  for construction of a new landfill on land
adjacent to the Drake Chemical  Site and presently  located within a  flood
plain.

II.  BACKGROUND OF COMMUNITY  INVOLVEMENT AND CONCERNS

Community  interest  1n the Drake Chemical  Site was  originally  attracted by
fires at the site dating back to the 1960s.   Flooding of ttie  site also raised
concern 1n  the community that hazardous  substances from the site might spread

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                                     -36-
throughout the town.  During emergency actions at the site 1n March of 1982,
add mist clouds escaped  from the site and  caused problems ranging from
peeling paint on vehicles to respiratory  Irritations.  The cleanup contractor
had  to  set up an/Insurance program to handle the  numerous  claims that
resulted.

In April 1983,  the  Rural  Development Committee, a group established In 1982 by
representatives of  local  agencies  Interested 1n furthering rural  development,
sent a  11st of their concerns about the  Drake Chemical  Site to  the EPA,
government officials,  and the media.  They  requested  that  their  concerns  be
addressed  at the  next scheduled public meeting.

A "second citizens' group was formed 1n April  1983.  Called CLEAN (Citizens  and
Laborers for Environmental Action  Now), the group was composed of former site
workers -wd Interested  citizens.   Its  atm was  to secure- health screening  for
former Drake Chemical Company employees.

At a public meeting held 1n May 1983, the primary concerns of the 250 people
who attended were  health related.   However, Interest has dwindled since that
time, perhaps because of  Phase I progress.   At  the latest public meeting,  held
April 3,  1986  to discuss the feasibility  study for Phase II, less than  30
community  members  attended.  None  of  these  Individuals  voiced  concern  about
health  Issues.  No representatives  of the Rural  Development Committee or CLEAN
attended.    The  primary concerns  at this  meeting  Included  methods   of
decontamination,  offslte disposal,  the  remedial action time-frame,  and  the
shortcomings of Alternative  4.

III.  SUMMARY OF  PUBLIC COMMENTS RECEIVED DURING THE  PUBLIC COMMENT PERIOD AND
AGENCY  RESPONSES

Comments  received  during the- Drake  Chemical Site public comment  period  are
summarized 1n. this  section.   The  comment  period opened on March 27,  1986  and
concluded April  17.    Although  the EPA  presented  five remedial action
alternatives for  consideration,  the agency expressed a  preference  for
Alternative 2.   This alternative was also preferred by the PADER.

Remedial Alternatives

     1.      Several  people  spoke against Alternative 4.  They were  concerned
            that  the proposed location of a new  landfill on property adjacent
            to the  site, between Route 220  and the railroad embankment,  lies
            within  a flood  plain.  This location would move  the contaminants
            200 or  300  yards closer  to Bald  Eaqle Creek, creating a situation
            that  the community  perceives as an Increased risk.

            EPA Response:   The  National  Contingency Plan (NCP) requires  that
            the  cost and technical   feasibility of  onslte  treatment  and
            disposal be  evaluated, If remedial alternatives that  Include
            offslte disposal are  proposed.   Originally,  building  and sludge
            remediation  were part  of Phase  II,  and the EPA Intended to propose
            dismantling the buildings,  spreading them on  the ground,  and
            capping the  sludge and  the buildings  together.   However,  sludge

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                                    -37-


            remedlatlon has been seoarated into a  third  ohase,  and  It  1s  no
            longer possible to  dispose of  the  structures on site.  Since that
            option 1s not  available,  the next ootlon  1s to acquire land  as
            close to  the site as possible.   The plans are only conceptual now,
            but the land owned  by Castanea  Township and located between Route
            220 and the railroad embankment 1s the proposed  landfill  site.

            The landfill would  be built only to a capacity  that would handle
            the building  materials,  and  1t  would be an  elevated,  lined,
            federally-approved facility.  The contaminants would not be burled
            in  the ground   because the groundwater  1s  too high  1n this area.
            The landfill  would  be  capped  according to Resource Conversation
            and Recovery Act  (RCRA) regulations,  and then, to  protect 1t from
            flooding,  a dike and levee system  would  have to  be built around
            the facility.   There 1s a flood protection system  proposed by the
            U.S.  Army Corps of  Engineers  for  construction  sometime  1n  1988,
            but we cannot assume construction of this system.   There  are many
            administrative  concerns with this alternative; however, 1t 1s the
            least expensive option.

     2.      A  local  official  suggested that, havlnq  satisfied the NCP  by
            presenting Alternative 4,  EPA should "scrap Alternative 4  from the
            record."   He asked that  1t  be  made  part of the record  that
            Implementation of  Alternative 4 would be met  with "militant
            resistance." This statement  was supported by other public meetinq
            participants.

            EPA Response;   EPA  1s  going  to  present  Alternative  2 to  the
            Regional  Administrator as the  preferred alternative, unless there
            is  adverse public comment on Alternative 2.  If  no   strong support
            for Alternative 4 develops,  it Is  unlikely to  be selected.

     3.      Citizens  and  officials inquired  whether Alternative 5,   the  no-
            action alternative, might be selected.

            EPA Response;   The selection of Alternative  5  is an  unlikely
            possibility.   If  it  is  chosen,  action  on  the  buildings  and
            structures  will,  most  likely,  revert back to Phase III.

Questions About Project Phases

     1.      Officials requested a summary of remedial actions  and  the time
            frame for  Phase I  at  the  Drake  Chemical Site.   Interest was
            primarily focused on the leachate stream remediation (Phase  I).

            EPA Response;   Phase I  is  Intended to eliminate  direct contact
            with  the leachate  stream.   The stream Is caused  by contaminated
            groundwater  that  comes  up in  low-lying areas  according  to
            fluctuations of the water table.   There  1s some  seepage through
            the railroad embankment.   EPA  plans to eliminate  this seepage  bv
            installing a  French drain  system  that  will drain  the perched
            aquifer into the  regional aquifer.   The pipe that comes out of the

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                                -38-
       railroad embankment will be  sealed and the  upper half of the
       leachate stream, above Pine Street,  will be filled  1n, contoured
       to  the  surrounding  land,  and  capped with clay.  Clean  surface
       water flow  in  that  area  will  be facilitated  by a pipe that runs
       from P1ne Street through  the Route 220 culvert and Into Bald Eagle
       Creek.   Once  the groundwater cannot surface 1n the  low-lying
       areas,   1t  will  retain the course  Into  the normal  aquifer flow.
       Some sediments will  have  to be excavated  to  Install the pipe below
       Route 220,  and  since  the  sediments are partially  contaminated,
       they will be placed  1n a temporary surface  Impoundment that will
       be  constructed on the Drake Chemical Site.   The Impoundment will
       be dealt with 1n Phase III.

       Design  of Phase  I 1s  complete.  Bid opening 1s scheduled  for May
-..--..  6,  1986.  Once  the  Corps of Engineers 1s satisfied  that  the  low
       bidder   1s responsible,  that  contractor  will   be  given notice  to
       proceed.  If no problems  arise,  work should start 1n late May or
       early June and  should take  about two or three  months.

2.     Several  questions were asked  about  Phase II.   Most of these were
       about the duration  of the.project,  the expected Implementation
       schedule, and whether the costs quoted  In the fact  sheet  and the
       feasibility  study Included  design and construction.

       EPA Response:    It  1s difficult to attach  a  date to Phase  II
       because   Superfund authorization ran out  on October  1,  1985,  and
       the incremental  funding  Congress provided  has  been  committed  to
       sites that  have already had Records of Decision (RODs) signed.
       Any new  ROD  sites will have to wait for funding.   EPA wants to get
       the Drake Chemical  Site ROD  signed now so  that as soon as the
       money is available,  funds can be obligated for Phase II.

       Once a  contractor is selected  and  money is ava-llable,  the EPA
       estimates the  implementation  of Phase  II  will  take  six  months.
       There shouldn't be  any  hidden variables  associated  with this
       project.

       At  worst,  the  EPA  anticipates  a  new Superfund  bill   by  the
       beginning of the new fiscal  year.  This is an assumption.  The
       implementation of Phase.II  would then occur 1n the spring  of 1987.
       The project will probably  continue  through the  entire  1987
       construction period.   Design  and construction costs are  Included
       1n  figures quoted in the  feasibility study.

  3.    Concern was expressed that  the Drake Chemical  Site, Phase II,
       might not be a high  enough priority to be funded as soon as monies
       are made available.

       EPA Response:    When  the  Superfund  bill   1s passed,  money can  be
       appropriated if the  ROD 1s  signed.

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                                    -39-


      4.    The town  of Lock Haven  1s  on schedule  with Its plans  for the
            construction  of  a  dike-levee  system  and  expects  to  beqln
            construction  by   mid-1988.    Since  Superfund  has  not  been
            reauthorized,  It appears that the EPA cleanup at Drake may exceed
            this schedule.

            EPA Response;  EPA  expects that Phase II will be under way before
            1988,  but  as far  as Phase  III  1s concerned,  that may be  correct.
            Phase  III  1s the most  complex phase.   There are  many  Issues  to
            resolve,  and the  EPA wants to be consistent with  the closure  at
            American Color  &  Chemical  (AC&C).  Phase  III  may-take awhile, but
            Phase  II  1s an  opportunity  to do  some  cosmetic  work.   The
            buildings  are an eyesore, and people want  them  removed.  EPA hopes
            to begin work  soon.

Decontaalnation and Salvage

     1.      Several questions concerned decontamination  of metals.   Citizens
            wanted to  know what the  decontamination  process  Involves,  how
            decontamination of  metals 1s determined, and  why  Alternative  2,
            with decontamination required,  was  cheaper than  Alternative  1,
            which  called for removal of all wastes and contaminated structures
            to a RCRA  permitted  landfill.

                                       {
            EPA Response:  The decontamination process  Involves  spraying  the
            metals with  a  low volume,  high pressure spray.   This  1s  done on  a
            decontamination pad,  and the flow from the spray 1s collected in  a
            sump and put into a tank.   It  1s  then tested, and  if  it  is found
            to  be  contaminated,  it  goes  to  a RCRA-permitted treatment
            facility.    After being  decontaminated, the  metals  are wipe
            sampled.   This  is  in  the preferred alternative  only.   If  the
            metals are determined to be decontaminated,  they can be  sold  as
            scrap.

            Decontamination of  the  metals eliminates  a lot o.T  tonnage that
            would,  in Alternative  1,  have  to be hauled several  hundreds  of
            miles  to a landfill.  At  the landfill, the price will be based on
            volume.

     2.      The quantity of chemicals left  in the warehouse and  the  salvage
            value  of those chemicals was requested.  Also, Inquiries  were made
            about  salvageable equipment that  might remain on site.

            EPA Response:  The  chemicals 1n the warehouse  are not  waste
            chemicals but were used  in  the product  being  manufactured;
            however,   EPA  1s not  going to evaluate the salvage  value of these
            materials  at this point.  They will be treated as waste  materials
            since they  have  been  sitting  for  5 years,  and  th'ey will be
            Incinerated.

            Equipment  remaining  in  the building  has also  been  sitting Idle
            for years;  the  roofs of the  buildings are caving  1n,  and  the
            elements have probably damaged  whatever remains.  It may cost more
            .pa

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                                    -40-
            to salvage  that equipment than to buy new equipment.  However, as
            the work progresses salvageable  Items may be discovered,  and
            decisions  win  be made at  that  point,  especially  1n  the case of
            the warehouse  and  water  treatment  buildings  which  are  less
            contaminated.

     3.      Several questions addressed the  decontamination of  building
            materials  other than metals.   It was  suggested  that some sort of
            core  sampling may be preferrable to wipe sampling for bricks and
            wood.  One person expressed concern  that  bricks might go  to a
            municipal  landfill.  He  mentioned  that a health study reportedly
            found beta-naphthylamlne leaching out  of contaminated  bricks  and
            wood.

      ..    EPA Response:  There are no plans to decontaminate bricks or  wood
            at this  time.   In  Alternative 2, the  EPA will  assume  all bricks
            and wood are contaminated,  and they will be disposed  at  a RCRA -
            permitted  landfill.  If Alternative  3 1s  chosen, there are methods
            to sample these materials  to be sure they  are not contaminated
            before sending them to a municipal  landfill.

     4.      Concern  was  expressed that salvaged  metals might be  sold  to buyers
            who are  unaware of the origin of the metals.

            EPA Response;  The EPA  does not  want these  decontaminated metals
            to be sold and  used  for the  same  purposes  they formerly  served.
            The EPA  wants these  things to be  recycled  1n  another form.
            Probably,  the metals will  be  sold as  scrap  and  melted  down.   The
            buyers  will  be    informed  about  the origin  of the  metals and the
            decontamination process.

Disposal  and Lagoon  Concerns

     1.      Several  questions were raised regarding the  lined" laqoons on site.
            Citizens asked If the EPA intended to drain  the  lagoons and if the
            contents of  the  lagoons  were  known.   One woman reported  that her
            son,  a  former Drake employee,  told her that barrels  containing
            both  liquids and solids were dumped  into  the  laqoons.   She  was
            concerned that the lagoon contents might  be  unstable and  also  that
            the barrels  might  be allowed  to  remain in the lagoons  and simply
            be covered over in Phase III.

            EPA Response:   There are  two lined  lagoons on site that were
            Installed in the  late 1970s  to treat effluent from the Drake
            facility.  There 1s still some liquid  in those  lagoons,  dependent
            upon  evaporation and precipitation.   Any remaining  liquid will be
            pumped  Into a tank and  sent  to  a RCRA landfill.   We  tested  the
            lagoons, and we do have a chemical  analysis  of them.

            There 1s a  liquid  lagoon on site that  will be dealt with 1n Phase
            III.   Also  remaining until  Phase  III  is an  Intermittent lagoon
            that occasionally dries up.   The lagoon that  the barrels were

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                                    -41-
             thrown  Into  1s  probably on the eastern side of the sUe.   The EPA
             has  been told that barrels  were thrown  Into that lagoon.  One
             alternative  would  be  to leave the sludge  lagoons  fntact  and cap
             them; however,  the EPA does not want to speculate  about Phase III
             at this  time.

      2.      A citizen asked If the soils around  the  lined lagoons had been
             tested and If  the  lagoons  were  leaking.   The Inference  was that
             the  chemicals  1n the  lagoons  may have  caused  any  leaks that were
             occurring and  that It was therefore unwise  to  place  those same
             chemicals Into  a lined landfill.

••'            EPA Repsonse:  These lagoons  are elevated so samples were taken of
             the  embankments.   Anything outside the- embankments will  become
             part of  Phase  III.   In Phase II the EPA will  drain the liquids,
             remove the lagoon liners,  and possibly level  the embankments.

             At this time, 1t 1s not known whether  the lagoons are leaking, but
             1t seems probable.  However,  lined landfill  regulations are now
             completely different than when  this site was lined.  The new
             landfill liners are double, they  have new protection systems, and
             they are  monitored.   Furthermore,  liquid wastes will not  be sent
             to a landfill;  they will be sent  to a treatment facility.

      3.      Inquiries were  made   about the  types  of  landfills that  would be
             used  for offsite  disposal  and about the  specific  names and
             locations of the landfills th£ EPA Intends  to  use.

             EPA  Repsonse;  At this time,  the EPA 1s not talking about a
             specific landfill.   If  the preferred alternative  1s  chosen,
             materials will  be hauled to a RCRA-perm1tted  landfill.   There are
             2 or 3  RCRA landfills to handle  the entire Northeast.   These
             landfills are  secured,  hazardous waste  facilities.  They are
             governed by the Resource Conservation  and  Recovery Act, a  Federal
             Taw  that regulates hazardous waste  landfills and   prescribes
             certain types of liners, and monitoring  systems.

             In Alternative 3, disposal  will  be  1n  appropriate  facilities
             dependent upon the  amount  of  contamination  in the waste materials.
             This means that materials  found  to be contaminated will  go to a
             RCRA-permltted  facility and  materials  shown  to be uncontaminated
             will be  sent  to a subtitle B  municipal landfill.   Based on  level
             of contamination much would probably go  to an unllned,  state-
             permitted facility that provides  leachate collection and treatment.

 Cements Related to Proposed D1ke/Levee Systea

      1.      A representative of the local  flood control board expressed relief
             that Alternative 4 was  not preferred  and  called attention  to the
             fact that  the  level of protection  for  the  flood control   project
             had  been  changed from 500-year protection to  200-year protection.

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                                   -42-


            He  then  inquired about  the  liability  of the  Army Corps of
            Engineers for any impact their flood control measures might  have
            on  the  EPA  Phase  I  remedial  measures.   He  also  requested
            assurances that the  Phase  I  plan  to  cap the leachate stream will
            not be affected by ponding 1n the area.   A resident Inquired about
            the Corps of  Engineers' feelings toward Alternative 4.

            EPA Response:   The Corps will Incur  liability  1f  1t disturbs
            burled contaminants;  in that case the  Corps would be considered
            the generator and would be held responsible. The EPA met with the
            design engineer for the Corps last year  in Baltimore and exchanged
            conceptual  plans.   The  only remaining  concern  is with  the
-f           backwater flap on the culvert.  There may be a need to install  a
            concrete structure in order  to  put that  flap over  1t.  There will
            be another meeting between  the EPA  and  the Corps  to discuss the
            location of this  backwater valve  and how deeply 1t  will penetrate
            the cap.   The EPA  wants to be sure that whatever 1s dug into  that
            area is properly shored.

            The ponding area's impact on the  Phase  I cap was  also discussed
            with the Corps at the Baltimore meeting.  There was concern  that
            the buildup of hydraulic  head  in  that area  might pop the cap, but
            apparently the engineers are  satisfied  that  ponding will  not
            affect 1t.  The  Corps has not commented on Alternative 4.

     2.     A representative of the  flood control  board  asked  if  the EPA
            planned to prepare  a  d1vision-of-costs  statement  concerning the
            degree of protection provided to the site by  the levee  and the
            resulting reduction  in the cost of  remedial actions at the  site.
            He stated that  this information might raise the  cost-benefit ratio
            of the dike-levee system  since the  cost of construction remains
            the same, but the  benefit of  removing the Drake Chemical Site from
            the flood plain is greater.

            EPA Repsonse:   The EPA  has no plans to do this at this  time.
                                    <
Costs and Funding

     1.     EPA representatives explained the  present lack  of funding for
            Phase II and  the  expected  sequence of events before new funds are
            made  available  as part of their presentation.   This  information
            was apparently well received  because little information was
            requested.   One person  requested  information about the amount of
            money spent or expected to be spent at Drake Chemical.

            EPA Response:   The Phase I leachate-stream construction will  cost
            approximately  1.2 million dollars;  Phase  II will  cost about  3.4
            million dollars,  and Phase III  could range  from 5  million dollars
            to 30 million dollars.  Emergency action at the  site Cost a little
            over a million dollars; and  the remedial investigation cost about
            750 thousand  dollars.   There was also a leachate stream study
            performed by  the Emergency  Response  Team (ERT) prior  to the
            emergency cleanup in 1982.

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                                     -43-


ttfscellineous Concerns

     1.     Lrttal officials  expressed  concern  that activities  at  the Drake
            Chemical  Site might  have a negative effect  on  summer events
            planned for the community.   These activities  Included a week-long
            event called a fly-In  at  the Piper  field 1n July and  a 4-day
            period at the Labor Day  weekend.

            EPA Response;   The EPA requested  the dates  of these activities so
            that any  negative  effect  of site activities  on  the community's
            festivities could be avoided.

   -* 2.     Local officials Inquired 1f It was necessary to submit a written
            comment to the  EPA regarding remedial alternatives or If no
            comment would be Interpreted as agreement with Alternative 2.

            EPA Response:  The EPA  does  not require written comments.  It will
            assume  agreement with  the preferred alternative.  However, 1f
            officials  do  write that  they support the preferred  alternative, 1t
            gives that much more credence  to that alternative when 1t 1s
            presented  to  the  Regional Administrator.

     3.     A public official's  aide said  that  he  was promised a copy of the
            feasibility study by a representative of the EPA.

            EPA Response:   Generally several  copies  of  the  report are sent to
            different  locations  In the  community so that everyone has access
            to them, but  anyone  wanting a personal  copy may contact  the EPA.

IV.  ROW IN INS CONCERNS

In general, the  community seemed  to be 1n complete agreement with  the EPA's
recommendation of Alternative 2,  and they did not appear to be alarmed about
the present  lack of  funding.   The  remaining concern  of local residents  and
officials regards future  development in the Drake Chemical Site vicinity.

     1.     To the west of the Drake Chemical Site,  Hammermill is considering
            building a waste-energy  plant.  Access to the plant will  probably
            have to cross  the leachate  stream cap.

            EPA Response;  The EPA  cannot stop Hammermlll  from  building there,
            but Hammermill  will  have  to keep in  mind  that the  area will be
            contoured for surface  water flow.   Any  construction  methods
            employed   will, have to facilitate  that flow  and  keep  it moving
            toward  catch basins that  go into the new  pipe.   An access road
            will also have to fee constructed  so that surface water flow 1s not
            impeded.

The EPA  spokesman summarized the  reasons that the  agency and the PAOER prefer
Alternative 2:

•    It  saves needed capacity in RCRA-permitted landfills.

•    Field decisions on decontamination are more accurate.

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                                    -44-
•    All  of the contaminated structures are removed.

•    The  cost differential with other  alternatives Is minor.

•    It satisfies the NCP.

Community relations support activities during  the  Phase  II  feasibility study
at the Drake Chemical  Site Included Issuing  press releases, updating  the
community  relations  plan,  distributing  a  fact sheet,  conducting  a public
meeting,  soliciting public  comments,  and  preparing  this responsiveness
summary.

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           -45-
                                          Tahle -.
                                     Alternatives
                                  Drake Chemical (Phase
                                                                        II)
Alternative
   Technical
  Feasibility
  Environmental
    Concerns
  Instltutlonal
     Issues
  Public Health
   Evaluations
Public Comments
Present
 Worth
I. Tanks,
Buildings and
Structures
Removal with
Dffsite Dis-
posal at a
*CRA Approved
~aciIIty.
The dismantling
and removal of
structures onslte
utilizes common,
well established
methods Involving
standard engin-
eering technology
and practice.

Time to Implement
this option Is
estimated at 6
months.
The potential for
environmental
receptor exposure
Is minimal.

Some risks Involved
in transportation
of wastes offsite.
Transport of waste
must meet DOT and
State shipping and
manifesting regu-
lations.

All waste material
will be disposed
of in a RCRA
approved facility.
Dismantling mid
removal activity
will generate dust
and wlI 1 Increase
the potetlal for
release of contam-
inants Into tlie air.
This risk ran he
controlled to accep-
table limits.

Work-related.safety
hazards would he
minimized by a site
safety plan.	
No significant
comments were
received on this
option.
$3,632,000
 .  Tanks,
 •ul 1 dings and
 t r'uctures
 emoval. De-
 ontamlnation
 f  Metal
 tructures for
 alvage. Off-
 Ite Disposal
 f  Non-Decon-
 amlnated
 aterlal in a
 CRA Approved
 aclllty.
Di smantllng
proceedure is
similar to Alt.
1.

Decontamination
proceedures are
well established
methods in the
hazardous waste
field.

Time to Implement
this option Is
estimated to take
6 months.
Similar to Alter-
native 1.

Decontatnl nation
fluid would be
contained and
analyzed to de-
termine the best
method of disposal
Same as Alterna-
tive 1 .
Similar to Alt. I .

Steam wl11 not be
used for deconf.im-
inatlon because of
the volatI 1f znt(on
potential of beta-
naphtbylamtiip.

A low volume, high
pressure water
system will ho used.
No sign!ficant
public comments
were received on
this option.
$3,143,000
 .  Tanks,
 i lid Ings and
 tructures  (
 emoval with*
I ffslte Dls-
 isal Depend-
1 it upon the
 lount of
 Hitamination.
The technical
feasibility is
similar to Alt.1.

The statistical
validity of wipe
samples used in
this option is
low.
The risk of
contaminated mat-
         i
erial aceldently
going to .a non-
hazardous waste
landfill Is greater
for this option
because of the low
statistical valid-
ity of the wi pe
sampl inf. •
Getting a demoli-
tion landfill to
accept waste from
a Superfund site,
even if the
material is deemed
non-contaminated,
will be difficult
at best.
Similar to Alt. 1
for the dismantling
and transportation
of contaminated
materials.
There was some
concern at the
public meeting
about some of
this material
going to a
non-hazardous
waste landfill.
$3,488,000

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          -46-
                                       Table 9 (Cont.)
                                     Alternatives Matrix
                                  Drake Chemical (Phase II)
Amative
   Technical
  Feasibility
  Envlronmental
    Concerns
  Instltutlonal
     Issues
   Public Health
    Evaluations
Public Comments
 Present
  Worth
 Tanks,
 I dings and
, ictures
 >val with
-)osal 11? a
 Landfill
 : trueted
 • cent to
 Site.
 'o Action
The technical
evaluation for
dismantling of
the buildings Is
the same for
Alternative 1.

Construction and
engineering for
the landfill are
based on common
practices and can
be performed
without special
equipment.
No long term
adverse environ-
mental effects If
the landfill Is
constructed
properly.

Location of the
landfill virtually
eliminates any
potential utiliz-
ation of the land
between the rail-
road and Route 220.
This alternative
must meet all
requirements of
RCRA and the State
for construction
of a hazardous
waste landfill.

Will Impact the
planned USCOE
flood control
project In the
area.

Dedication of the
land for a land-
fill would be very
difficult to get.
For ,dlsmantling
activities the
risks arp the snme
as In Alternative
I.

If properly con-
structed, thero
would he minimal
risk to public
health from tl»p
landfill.

A 200-year flood
event would likely
wash out the pro-
tective dike and
possibly carry
materials downstream
Not applicable
Would not reduce
the risk of
offslte contaminant
migration via fire
or flood
Would delay the
inevitability
of building
removal, probably
into Phase III
of the project.

Further physical
controls may need
to be employed In
order to prevent
trespass onto the
site.
Would not reduce
the risk of offslte
migration of the
contaminants via
fire or flood nnH
potentially affect-
Ing human population
in th-
                                                                         Direct contact
                                                                         threat from  poten
                                                                         tial  trespassers
                                                                         would  remain a
                                                                         possl bl 11 ty.
This option was
met with ex-
treme criticism
from both the
local citizens
and the local
government.

One local pol-
itician remarked
that If this
option were
Chosen it would
be fought with
militant
opposition.
$3,282,000
If no action
was the ROD
decision at this
point It .would
be met with
much anger and
frustration in
the community.
   $0

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