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.
-------
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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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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-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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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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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.
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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 •
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-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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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.
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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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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.
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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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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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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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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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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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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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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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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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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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• 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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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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