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