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R~RT DOCUMENTATION
\~ - PAGE
14. Tit;r Ind Subtitle
~VPERFUND RECORD OF DECISION
Drake Chemical, PA
rhird Remedial Action - Final
'7. Author(.)
":i.. ., REPORT NO.
I EPA/ROD/R03-88/058
. 2.
3. Recipient". AccI.sion No.
5. ~~~~~8
6.
8. Plrforminl Orlanizetion AIPt. No.
9. Performlnl O,.anization Name and Addre..
10. Project/Task/Work Unit No.
.- -- ----
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Soon.o"nl Orlanization Name Ind Addres.
U.S. Environmental Protection
401 M Street, s.w.
Washington, D.C. 20460
13." Ty;' 0' Rloort & -P;;;~-Covered - -.-
Agency
800/000
14.
15. Supplementary Notl.
16. Ab.tract (Limit: 200 words)
The Drake Chemlcal Site (DCS) is a 12.5-acre inactive chemical manufacturing facility
located in Lock Haven, Clinton county, Pennsylvania. The area surrounding the site
includes American Color and Chemical company to the west, Hammermill Paper company to
the southwest, Bald Eagle Creek to the south, the west branch of the Susquehanna River
to the north, and an apartment complex and a shopping center to the east. Bald Eagle
Creek and the Susquehanna River are wetland areas and are used for recreation and
lishing. Lock Haven residents do not use ground water for drinking purposes. The
facility operated between 1951 and 1982 manufacturing chemical intermediates used in
producing dyes, cosmetics, textiles, pharmaceuticals, and pesticides. The DCS facility
includes two synthetic-lined wastewater treatment lagoons, an unlined leachate lagoon,
and a dry unlined sludge lagoon. The water and sediments within the two lined
impoundments are highly contaminated with site-related organic and inorganic
contaminants. The site surface is covered with debris, chemical sludge, and
contaminated soil. Approximately 252,000 yd3 of soil, sludges and sediments are
contaminated. The Drake Chemical company was cited several times by state and Federal
agencies for violating environmental and health and safety regulations. In 1982, EPA
began an emergency removal action in which surface drums, surface sludges, and liquids
(See Attached Sheet)
lke~6't"1rnb ~~i~ i ~'i 'Ow:rtptors
Drake Chemical, PA
Third Remedial Action - Final
contaminated Media: gw, sediments, soil, sw
Key Contaminants: metals (arsenic, chromium,
b. Identlfilrs/OPln.Endld Term. (benzene, TCE, toluene)
lead), organics (PAHS, phenols), VOCs
c. COSATI Field/Group
Availability Statement
19. Security Class (Thi. Report)
None
21. No. 0' Pa.es
53
- ------
20. Security CIIS. (Thi. Pall)
None
22. Prica
(5.. ANSI-Z39.18)
SII Instructions on Reve"e
O..,.'ONAL FORM 272 (4-7n
(Formerly NTI~3S)
Olpartment of Commerce'
-------
~PA/ROD/R03-88/058
~rake Chemical, PA
Third Remedial Action - Final
16.
ABSTRACT (continued)
contained in process and storage tanks were removed and disposed of, and the site was
fenced. A ROD signed in 1982 addressed the leachate stream that ran offsite towards
Bald Eagle Creek, and remediation was completed in 1987. A subsequent ROD signed in May
1986 required demolition of onsite contaminated buildings and tanks and disposal in an
offsite landfill. This work currently is being undertaken. The focus of the remedial
action addressed in this ROD is remediation of the contaminated soil, sludges, and
ground water at the site. The primary contaminants of concern affecting the ground
water, surface water, soil, and sediments are VOCs including benzene, toluene, TCE, and
xy1enes, other organics including fenac, phenols, and PARs, and metals including lead,
chromium, and arsenic.
The selected remedial action for this site includes: excavation of approximately
252,000 yd3 of contaminated sludge, soil, and sediments, followed by treatment in an
onsite mobile rotary kiln incinerator, backfilling (possibly using the incinerator ash
as backfill material), and installation of a vegetative cover; design and construction
of an onsite wastewater biological activated carbon treatment plant with pump and
treatment of the surface water, ground water, storm water, and aqueous wastes from the
leachate lagoon at the treatment plant, followed by discharge to a local stream or POTW;
and ground water monitoring. The estimated present worth cost for this remedial action
~.s $97,363,000 with an average annual O&M of $787,000.
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RECORD OF DECISION
Drake Chemical Site
Lock Haven, Pennsylvania
Statement of Basis and Purpose
This decision document presents the selected remedial action
for the Drake Chemical Site in the City of Lock Haven, Clinton
County, Pennsylvania. This decision is developed in accordance
with the Comprehensive Environmental Response, Co.pen.atioR and
.
Liability Act of 1980 (CERCLA) as amended by the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and to the
extent practicable, the National Contingency Plan. The deci.ion
is based on the data derived from the past seven years of site
investigations and coordination with the Commonwealth of
Pennsylvania and local agencies. This information has been
compiled into the Administrative Record for the site investigations
and an index of the Administrative Record is attached. After
review of the site investigations, the Administrative Record,
and a public comment period, the Agency is selecting this
remedial action. The Commonwealth of Pennsylvania has concurred
in the selected remedy and a copy of its letter is attached.
Description of the Selected Remedy
The purpose of this alternative is to excavate the contami-
nated soils, sludges, and leachate lagoon sediments at the site
and decontaminate this material using a transportable, onsite
incinerator. The following tasks will be performed as part of
this remedial action.
- install necessary flood control measures
- remove aqueous wastes from leachate lagoon area and treat
- install permanent stormwater management controls in the leach-
ate lagoon area and other areas to be excavated
- excavate approximately 252,000 cubic yards of contaminated
sludge/soils/sediments and decontaminate using a transport-
able, onsite, rotary kiln incinerator ( The thermal treatment
unit must comply with incineration permit requirements
including air emissions and monitoring.)
analyze incinerator ash and use as
accordance with State requirements
ash unsuitable for backfill maybe
disposal.)
backfill if acceptable in
(Further treatment of
necessary for onsite
- remove unnecessary obstacles, such as water and sewage lines
from the facilities and maintain local lines that are presently
in use
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- backfill excavated areas with suitable material, regrade to
provide positive drainag~, and revegetate the topsoil to control
erosion
- collect and treat all contaminated water that enters the
site (e.g., groundwater, Btormwater, and decontaminated
water) at the groundwater treatment system
In addition to decontamination of the sludge/soils/sediments
this remedial action will include pumping and treating the contaa-
.
inated groundwater at the site to an acceptable level for discharge.
The following tasks will be implemented as part of this reaedial
action.
- install necessary flood control measures
- design and construct an onsite wastewater treatment plant
- install extraction wells in the areas of groundwater contam-
ination within the property boundaries of the former Drake
Chemical facilities and in the properties adjacent to the
facility in the south and east directions
- pump groundwater to the treatment system
- treat by using Biological Activated Carbon (BAC)
- discnarge effluent to Bald Eagle Creek either through the
underground conduit constructed for the Phase I leachate
stream or through the. Lock Haven sewage treatment facility
(The water treatment unit must comply with permit requirements
for discharge of treated water)
- analyze residuals (e.g., sludgecake) and use as backfill if
acceptable in accordance with State requirements (Further
treatment may be necessary for onsite disposal.)
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are appli-
cable or relevant and appropriate for this remedial action, and is
cost effective. This remedy satisfies the statutory preference for
remedies that employ treatment that reduces toxicity, mobility, or
volume as a principal element and utilizes permanent solutions and
alternative treatment technologies to the maximum extent practicable.
/
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Date
Laskowski, Acting Regional Administrator
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The Decision Summary
Drake Chemical Site
Lock Haven, pennsylvania
SITE DESCRIPTION AND HISTORY
The Drake Chemical Site is an inactive chemical
manufacturinq facility that operated from 1951 to 1982 (see
Fiqure 1, Site Location Map). Durinq its. operation, the
Drake Chemical Company manufactured chemical intermediates
used in the dye, cosmetics, textiles, pharmaceuticals, and
pesticides industries.
Immediately adiacent to and west of the Drake Chemical
Site is the American Color and Chemical Company which is
currently underqoinq a Resource Conservation and Recovery Act
(RCRA) cleanup. The Hammermill Paper Company operates an
industrial facility l/2-mile southwest of the site. within
1/4-mile are an apartment complex, a shoppinq center, and
Castanea Township Park. A maior tributary of the Susquehanna
River, Bald Eaqle Creek, flows less than 1/2 mile south of the
site: 3/4-mile north, the creek flows into the West Branch of
the Susquehanna River.
Site features at the l2.5-acre Drake Chemical Site
include two synthetic-lined wastewater treatment laqoons, an
unlined leachate laqoon, a dry and unlined sludge laqoon, a a
trailer and five buildinqs that were used at the facility
(see Fiqure 2, Site Plan). Much of the site surface is covered
by assorted debris, chemical sludqe, and contaminated soils.
Buildinqs, tanks, an~ surface impoundments remaininq onsite
are currently slated for demolition and removal in 1988 as
part of the phase II site remediation.
The Drake Chemical Company was cited many times, by
State and Federal aqencies, for violatinq environmental and
health and safety requlations. In 1982, after the company
failed to respond to EPA's requests to clean up the site, the
EPA beqan an emerqency removal action. As a result, surface
drums, surface sludqes, and liquids contained in process and
storaqe tanks were removed and disposed of, and the site was
fenced. Subsequently, a Superfund Remedial Investiqation/
Feasibility Study (RI/FS) was initiated in 1983. The RI/FS
was divided into two areas of concentration: Phase I focused
on a leachate stream that ran offsite towards Bald Eaqle
Creek. Followinq completion of the Phase I RI/FS in 1984, a
3
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CLINTON COUNTY
~SITE
1000
I
PENNSYLVANIA
SITE LOCATION MAP
DRAKE CHEMICAL SITE
LOCK HAVEN. PENNSYLVANIA
FIGURE 1
o
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TRAILER
APPROXIMATE PROPERTY UNE
BUILDING NI2
MAINTENANCE
BUILDING NI 3
BUILDING Nil
ACCESS ROAD
BUILDING NI5
EFFLUENT TREATMENT BUILDING
LINED LAGOONS
SLUDGE LAGOON
LEACHATE
LAGOON
RAILROAD
APPROXIMATE LOCATION
. OF CHEMICAL SLUDGE
DRAKE
CHEMICAL
SITE~
CLINTON
COUNTY
5
SITE PLAN
DRAKE CHEMICAL SITE
LOCK HAVEN, PENNSYLVANIA
NOT TO SCALE
FIGURE 2
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Record of Decision (ROD) was siqned and led to remediation of
the leachate stream. The remediation involved coverinq the
upper reaches of the stream with natural soils and a clay cap
and installinq a conduit drain from the site to Bald Eaqle
Creek. Contaminated sediments that were excavated from the
area were placed onsite in a temporary storaqe impoundment.
The phase I remediation was completed in 1987.
The phase II RI/FS was divided into two operable units,
one addressinq onsite buildinqs and surface features, and
the other addressinq soils, sludqes, and qroundwater.
However only the first unit lead to an Aqency decision. The
Phase II RI/FS concluded that buildinqs and other surface
features onsite were contaminated and required remediation.
Based on the Phase It RI/FS, the phase II ROD was siqned in
May 1986. It recommended draininq and removinq two lined
laqoons and disposinq of the materials. The Phase II ROD
also included demolition of the buildinqs and tanks for
disposal in an offsite landfill. The phase II site
remediation work is currently underway. In 1986, no
decision was made for remediation of the soil, sludqes, and
qroundwater and this became the focus of this Phase III .
RI/FS and ROD.
PHYSICAL CHARACTERISTICS OF STUDY AREA
Surface Features
At least three backfilled sludge laqoons are present at
the Drake Chemical Site as shown on Fiqure 2. In addition,
sludqe was found in the area south of the former office
trailer and decontamination pad. The qround surface reflects
the extent of the three laqoons, whereas the area near the
trailer and buildinq No 1 has no surface expression to
indicate lateral extent of the sludqe material.
A slow, but continuous leachate seep was observed at
the base of the dike near the southeast corner of the east
laqoon (See Fiqure 2). The leachate infiltrated the qround
approximately 10 feet from the seep, leavinq surface stains
alonq a linear flow path, up to the point of infiltration.
The leachate laqoon at the southern tip of the site
contains water to an approximate depth of 5 feet. The other
unlined laqoons were dry throuqhout the field investiqation
fro~ October 1987 to January 1988.
6
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Surface Water
Offsite surface water includes Bald Eaqle Creek, south
of the site, and the West Branch of the Susquehanna River,
north of the site. Three of the laqoons onsite also contained
water and were included in the field samplinq activities.
A total of 13 surface water and sediment sample pairs
were collected from surface water bodies durinq the Phase
III field investiqations. These locations are shown on
Fiqure 3.
Both Bald Eaqle Creek and the West Branch of the
Susquehanna River are clearly wetland areas and are used for
recreation and fishinq. The three on site laqoons were not
considered as wetlands. An examination of aerial
photoqraphs from Environmental photoqraphic Interpretation
Center (EPIC) reveals that the three onsite surface water
bodies were constructed durinq the late 50's probably as
waste impoundments. The shape of the impoundments has
chanqed as fill material was added to displace their contents.
There is no knowledqe of aquatic species habitatinq
these impoundments. The two lined impoundments clearly do
not support any terrestrial flora. Flora surroundinq the
unlined leachate laqoon is typical of the surroundinq area.
The water and the sediments within the two lined
impoundments are hiqhly contaminated by site related orqanic
and inorqanic contaminants. The leachate laqoon at the
south end of the site is the topoqraphical low and is felt
to be the recipient of all precipitation not lost to
infiltration or evaporation.
Soils and Overburden Material
The alluvial deposits which underlie the site and
ad;acent areas consist of clay to sandy clay floodplain
deposits. These coarsen in qrain size at depth to sand and
qravel stream channel deposits, then finally to medium to
coarse qrained sands mixed with qravel-sized sandstone
fraqments. The clay and sandy clay layer occurs from qround
surface to an averaqe depth of 15 feet, based on both onsite
and offsite soil borinqs throuqhout the study area. This
clay-rich layer varies laterally throuqhout the study area
from brown and qray sandy clay to an almost pure clay lense,
colored qray with oranqe mottlinq. Based on the new and
existinq data, the qeneral litholoqy of the upper 15 feet of
overburden material interrelated as floodplain deposits, may
be thouqht of as a layer of sandy clay with various lenses
of clay dispersed throuqhout.
7
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0>
.
~tJo.\..O
o
.
FIGURE 3
3000
6000
SCALE IN FEET
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Below approximately 15 feet, the alluvial sediments
increase in qrain size with increasinq depth to sand and
qravel and then to sand with qravel and cobble-sized
sandstone fraqments. These sandstone fraqments may have
oriqinated from the adjacent Bald Eaqle Mountain.
Buried Channel
Based on the phase II and phase III Rls, there is a
buried alluvial channel oriented in an east-west direction
parallelinq Bald Eaqle Creek. The sediment within the
erosional channel contains quartz and feldspar qravel, which
is unique to the area. The quartz and feldspar qravel infer
an iqneous source material that is not common to the area
bedrock. This qravel may be qlaciofluvial in oriqin.
Bedrock
The study area is situated on the north limb of a
northeast trendinq anticline that is part of the Valley and
Ridqe Physioqraphic province. The West Branch Valley is the
result of differential erosion of non-resistant sedimentary
rock units (i.e. shale, claystone, limestone). The
underlyinq bedrock throuqhout the Drake Chemical site study
area has a reqional dip of 200 to 500 to the northwest
(Vendel Enviro-Ind~strial Consultants, Inc., 1987).
Accordinq to a local study performed by the U.S. Army
Corps of Enqineers, the Drake Chemical Site is underlain by
shales of the Marcellas Formation.
Six bedrock wellp were drilled and installed durinq the
Phase III RI field investiqation to further investiqate
qroundwater conditions within bedrock. The bedrock is a
soft qray claystone to shaley claystone and medium hard
limestone ranqinq from less than 1 foot to more than 10 feet
in thickness occur from a depth of 110 feet (onset of rock
corinq operations) to the total depth of the borinq at 141
feet below qround surface. This 3l-foot interval ranqes
from very broken to blocky in the alternatinq sequences of
claystone and limestone. portions of the blocky limestone
reveal former hiqhly fractured zones bound within a
secondary, calcite-cement matrix. Based on rock core data,
the Keyser/Oldport Limestone Formation contains a variety of
litholoqies throuqhout the study area.
9
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Hvdroqeoloqy
Groundwater flows north, east, and south from the Drake
Chemical Site, then qradually heads to the south and
southeast toward Bald Eaqle Creek, based on the January 1988
water level elevations taken from new and existinq monitorinq
wells screened at or near the water table.
An analysis of the flow patterns based solely on the
monitorinq wells screened in bedrock shows a less detailed
but similar qroundwater flow direction. The buried channel
apparently does not affect or influence qroundwater flow
direction or contaminant miqration.
There is no indication of a vertical hydraulic qradient,
a1thouqh there are minor differences in water level
elevations within well clusters that are screened in various
litholoqies and at different depths. Reqardless, no set
pattern is observed.
.
Field Activities
Forty-one test pits were excavated durinq the field
investiqation to collect information necessary to
characterize the contaminated soils and sludqes accordinq to
contaminant type and concentration, mass-volume, and
physical location. Each test pit was excavated to the water
table or a maxim~~ of 15 feet. The pits were located as
near to the proposed 100-foot by 100-foot qrid spacinq as
possible, althouqh minor adjustments were made. Fiqure 4
depicts the 41 test pit locations. Thirty-two of the test
pits were located within the fenced area of the Drake
Chemical Site and nine test pits were situated on the Gorham
Property, immediately northeast of the former Drake
facility. In addition, six test borinqs were drilled
adiacent to areas where the excavation of test pits was
difficult because of sidewall collapse. A total of 28
borinqs were drilled and 22 monitorinq wells installed
durinq phase III. Monitorinq well MW-M108 was installed in
one of the onsite test borinqs and was the only onsite well
installed durinq the Phase III RI. Two soil borinqs were
drilled offsite to explore for the buried erosional channel
which was discovered durinq the previous RI. Both borinqs
successfully located the channel soil borinq and one was
converted to monitorinq well MW-M125. An additional 20 soil
borinqs and monitorinq wells were installed in 13 locations
throuqhout the study area as shown in Fiqures 4 & 5. Several
locations have wells at different depths.
10
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150
300
--
- -
SCAL.E IN FEET
FIGURE 4
SOIL SAMPLING LOCATIONS
DRAKE CHEMICAL SITE
LOCK HAVEN, PENNSYLVANIA
11
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Observations from Test pit Operations
Durinq field operations various observations were made.
Buried wastes were identified outside the fenced
portion of the Drake property. For example:
- A 6-inch drain pipe, uncovered in test pit number
T-44, was transportinq leachates from an unknown
source on Drake Chemical site off site to the
Gorham property.
- A partially buried baq of a red substance was
uncovered near the well cluster near MW-M107.
. A blue plastic buried liner material was observed at
about 11.5 feet in soil borinq SB-31. Durinq drillinq,
the drill water was draininq beneath a partially
buried piece of blue plastic "liner" at the surface
ad;acent to the borinq.
. Three distinct sludqe-filled laqoons were located.
An area of soil covered sludqe was located iust south
of the decon pad in test pit TP-28. (This may be
part of the Old Pennsylvania Canal.)
. The sludqe appeared to be layered as follows:
- Alternatinq layers of cream-white and red-stained
material that was sliqhtly odorous ranqed from
very viscous to a hard crust
- Less distinct layerinq of dark blue to qreen
material had a more distinct color and was viscous
to liquid.
- A black layer of hiqhly odorous material ranqed
from liquid to very liquid.
. The southern end of the site contains buried debris
resemblinq possible flood debris. This area served
as a dump site for the debris cleaned up followinq
the ma;or flood that took place durinq 1972.
12
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EXTENT OF CONTAMINATION
Overview
site associated contaminants were found throuqhout the
study area in soil. surface water, sediment, and qroundwater
samples. The deqree of contamination, however, varies
throuqhout the site. Analysis of the various media detected
an unusually lonq list of organic compounds and metals. The
entire list is presented in the RI, but a summary of
the hiqh and low detection ranqe is included here as
Table 1. In qeneral. the occurrence and concentration of
contaminants within a qiven media is qreatest on site and
immediately off site, particularly on the Gorham property,
which is in the direction of qroundwater flow.
To facilitate the assessment of the extent of qroundwater
contamination and to provide a basis for identifyinq the
scope of qroundwater remediation strateqies, the study area
has been divided into three zones which are depicted in
piqure 7. Zone 1 qroundwater is more severely affected
immediately under the site. Contamination was also detected
in qroundwater samples taken from monitorinq wells located
between the Pennsylvania Railroad track bed and the northern
berm of Route 220 (Zone 2) and monitorinq wells between the
southern berm of Route 220 and the Bald Eaqle Creek (Zone
3). site-related contaminants showed a qeneral attenuatinq
of concentration in Zone 2. as would be expected with
miqration in the direction of qroundwater flow. Some
contamination is present in Zone 3 qroundwater but the
extent of pollution is less than that found in Zones 1 and
2.
Area surface waters and sediment are also affected by
site related contaminants. These medias are most likely to
be affected by qroundwater recharqe to surface waters, not
by an overload flow of contaminants. However, it is probable
that site related contamination measured in river reach
sediments below the site is larqely throuqh the former
leachate stream. Contaminants occurrinq upstream. however,
may be a result of reqional floodinq events or from
industrial applications of pesticides.
SOILS AND SLUDGES
Site soil is contaminated by volatile organic compounds,
base/neutral acid extractables, fenac, B-napthylamine and
inorqanics. Some very hiqh and consistent concentrations of
orqanics of (i.e., fenac) are observed.
13
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Table 1 presents the results of field screeninq data
for volatile orqanic analyses and fixed base phenolic
analyses obtained from samples taken durinq test pittinq
activities.
The field screeninq revealed that the bulk of the
vadose zone on the site is contaminated at varyinq
concentrations by chlorinated solvents, benzene, toluene,
xylenes, and ethylbenzenes. Substituted chlorinated phenols
and alkyl phenols are also present.
These compounds occur throuqhout the site reqardless of
samplinq depth: therefore, no one particular area of the
site or the adiacent Gorham property can be considered a
more likely source of contamination to the surroundinq
environment.
The siqnificance of this findinq has maior implications
for soil (source) remediation strateqies. Since
contaminants are homoqeneously distributed throuqhout the
soils and sludqes in the vadose zone, the total quantity of
material requirinq treatment would be approximately 252,000
cubic yards.
Inorqanics, includinq cyanide, mercury, nickel, lead,
chromium, and cadmium, were ~lso detected and mayor may not
occur as a result of site contamination. The compounds
lead. nickel, chromium, barium, aluminum, iron, manqanese,
and maqnesium occur with qreatest frequency and in larqe
concentrations. Heavy metals includinq mercury and selenium
were present but did not occur in qreat concentrations or
frequency.
The RI indicates that cadmium clearly exceeds expected
ranqes and is ~robably site related. The contrast is less
dramatic for cobalt, copper, lead, and silver: however, it
cannot be concluded that they are not residual contaminants
from past waste practices at the site..
SURFACE WATERS
Results of surface water samplinq and analysis for
offsite surface waters in the reqional water shed are
presented in Table 1. Evidence that offsite surface waters
are affected by site-related contamination is demonstrated
in samples collected downstream of the site. The detection
of fenac in samples collected from locations 5, 6, and 7 on
Bald Eaqle Creek and locations 8, 11, and 12 on the West
Branch Susquehanna River support this assessment.
14
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SUMMARY OF REPRESENTATIVE CONTAMINANTS
CONCENTRATIONS AND OBSERVATIONS
OBSERVED AT THE DRAKE CHEMICAL SITE
PHASE III RI/FS
Media Compounds Concentration Number of
Range Observations
Surface Fenac 0.9 - 4,900 ug/l 7 of 13
Water
Benzoic Acid 36 ug/l 1 of 13
2,4-dimethylphenol 7 ug/l 1 of 13
2,4,5-trichlorophenol 6 ug/l 1 of 13
Nickel 16 - 35 ug/l 11 of 13
Silver 10 -17 ug/l 2 of 13
.
Lead 16 ug/l 1 of 13
Chromium 13 ug/l 1 of 13
Cobalt 12 - 25 ug/l 12 of 13
Aluminum 97 - 3,910.ug/l 12 of 13
Barium 36 - 89 ug/l 13 of 13
Sediments Chlorobenzene 2 - 9,100 ug/l 4 of 13
Fenac 24 - 1,500,000 ug/l 9 of 13
Toluene 710 - ug/kg 1 of 13
Benzene 100 ug/kg 1 of 13
1,2-diChlorobenzene 70 - 8,600 ug/kg 4 of 13
1,4-dich1orobenzene 290 - 140,000 ug/kg 3 of 13
1,2,4-trichlorobenzene 170 - 140,000 ug/kg 3 of 13
Tetrachloroethene 3 - 47 ug/kg 3 of 13
8enzoic Acid 45G - 1,800 ug/kg 3 of 13
Phenol 740 - 2,700 ug/kg 2 of 13
Total Xylenes 20,000 ug/kg 1 of 13
Benzo{b) fluoranthene 210 - 100,000 ug/kg 13 of 13
Benzo{a) anthracene 130 - 1,200 ug/kg 2 of 13
Napthalene 370 - 43,000 mg/kg 2 of 13
15
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SUMMARY OF REPRESENTATIVE CONTAMINANTS,
CONCENTRATIONS AND OBSERVATIONS
OBSERVED AT THE DRAKE CHEMICAL SITE
PHASE III RI/FS
PAGE TWO
Media Compounds Concentration Number of
Range Observations
Sediments Aluminum 2,320 - 35,500 mg/kg 13 of 13
.( con t. )
Barium 47 - 257 mg/kg 13 of 13
Chromium 8.6 - 69 mg/kg 13 of 13
Lead 13 - 113 mg/kg 13 of 13
Mercury 290 - 820 mg/kg 4 of 13
Nickel 12 - 373 mg/kg 13 of 13
.
Cyanide 2.4 - 766 mg/kg 3 of 13
Arsenic (total) 5.5 - 27 mg/kg 10 of 13
Benzo(k) fluoranthene 210 - 3,300 ug/kg 9 of 13
Pluoranthene 110 - 3,200 ug/kg 5 of 13
-
Pyrene 150 - 3,400 ug/kg 4 of 13
Chrysene 140 - 2,300 ug/kg 9 of 13
Benzo(a) pyrene 91 - 1,800 ug/kg 8 of 13
Pentachlorophenol* 150 - 1,200 ug/kg 5 of 13
So il's Fenac 3.8 - 8,200 ug/kg 32 of 42
Ethylbenzene 1 - 27,000 ug/kg 11 of 42
Total Xylenes 3 - 220,000 ug/kg 15 of 42
Chlorobenzene 2 - 14,000 ug/kq 24 of 42
Benzo(a) anthracene 100 - 42,000 ug/kg 15 of 42
.
1,2-dichlorobenzene 200 - 100,000 ug/kg 10 of 42
1,4-dichlorobenzene 190 - 12,000 ug/kg 12 of 42
(Total) Arsenic 2 - 21 mg/kg 29 of 42
Nickel 3 - 41 mg/kg .37 of 42
Chromium 6.8 - 269 mg/kg 40 of 42
16
-------
SUMMARY OF REPRESENTATIVE CONTAMINANTS,
CONCENTRATIONS AND OBSERVATIONS
OBSERVED AT THE DRAKE CHEMICAL SITE
PHASE III RI/FS
PAGE THREE
Media Compounds Concentration Number of
Range Observations
Soils Lead 3.3 - 1,170 mq/kq 31 of 42
(Cont. )
naphthalene 74 - 7, 000 ~q/kq 8 of 42
B-napthylamine 470 - 1,500,000 uq/kq 18 of 42
1,2,4-trichlorobenzene 98 - 21,000 uq/kq 8 of 42
Pentachlorophenol 1,200 - 130,000 uq/kg 3 of 42
Pi1enanthrene 120 - 140,000 ug/kg 6 of 42
Ground-
vater
Zone 1 Fenac 20 - 20,000 ug/1 12 of 15
B-napthy1amine 1 - 3,000 ug/l 8 of 15
Arsenic (total) 5.5 - 400 uq/l 6 of 15
Barium 28 - 14,800 uq/l 10 of 15
Chromium 10.3 - 448 ug/l 10 of 15
Lead 15,000 - 23,700 uq/l 4 of 15
Mercury 0.2 - 1 uq/l 4 of 15
Mickel 31. 5 - 424 uq/l 6 of 15
Silver 19 uq/l 1 of 15
Cyanide 10 -6,780 ug/l 4 of 15
Toluene 1.3 - 8,100 uq/l 10 of 15
.
Chlorobenzene 72 - 18,000 ug/l 12 of 15
1,2-dichloroethane 0.1 - 5,100 ug/l 14 of 15
trichloroethene 1.4 - 500 uq/l 11 of 15
1,2-dichlorobenzene 4.7 - 440 ug/l 8 of 15
1,4-dichlorob~nzene 3.4 - 100 ug/l 9 of 15
17
-------
SUMMARY OF REPRESENTATIVE CONTAMINANTS,
CONCENTRATIONS AND OBSERVATIONS
OBSERVED AT THE DRAKE CHEMICAL SITE
PHASE III RI/FS
PAGE FOUR
Media Compounds Concentration Number of
Range Observations
Ground-
water
Zone 2 Fenac 7.6 - 9,200 ug/1 5 of 13
B-napthy1amine 12 ug/1 1 of 13
Ch1orobenzene 2.4 - 11,000 ug/l 6 of 13
1,2-dichloroethane 6.7 - 6,800 ug/l 6 of 13
Trichloroethene 23 - 130 uq/l 3 of 13
Arsenic (total) 3.9 - 35.4 uq/l 6 of 13
Nickel 17 - 260 ug/l 11 Of 13
Chromium 5 - 125 ug/l 9 of 13
Mercury 0.3 -0.5 ug/.l 2 of 13
Lead 49 - 139 ug/l 4 of 13
Cadmium 4.3 - 100 ug/l 4 of 13
Ground-
water
Zone 3 Fenac 0.6 - 700 ug/1 7 of 13
Cyanide 16 ug/l 1 of 13
1,2-dichloroethane 0.1 - 950 ug/l 8 of 13
Ch1orobenzene 40 ug/l 1 of 13
Barium 35 - 5,390 uq/l 12 of 13
.
Cadmium 5 - 34 ug/l 7 of 13
Cobalt 10 - 679 uq/l 9 of 13
Mercury 0.2 - 1. 7 ug/l 6 of 13
Nickel 11.6 - 1,400 uq/l 8 of 13
Chromium 9.5 - 468 ug/l 6 of 13
Lead 1.4 - 535 ug/l 4 of 13
*
Not attributed specifically to the Drake Site.
18
-------
Evidence that site-related contaminants occur in surface
waters in the watershed above the site (up qradient) is also
indicated. The site-specific contaminant detected in both
upstream Susquehanna River and Bald Eaqle Creek samples is
fenac which, because of area hydroloqy, is not likely to
have occurred from site drainaqe, but may have occurred from
.reqional floodinq events.
Inorqanic compounds includinq aluminum, barium, calcium,
cobalt, chromium, iron, lead, nickel, potassium and sodium
are found at varyinq concentrations in samples taken
throuqhout the area but, because of their random distribution
includinq upqradient samples (locations 4 and 13) and
possible natural occurrence, they cannot be attributed
specifically to the Drake Chemical Site.
Site surface laqoons are contaminated by inorqanics,
base/neutral acid extractables and fenac. The observed,
site-related contamination (i.e., orqanics, especially fenac)
is not unexpected since th~ two lined laqoons are used for
the impoundment of wastewater from the site. Contamination
observed in surface water from the leachate laqoon is also
not unexpected. This laqoon is at the topoqraphical low
point of the site and is believed to be the recipient of
surface runoff.
SEDIMENTS
The most siqnificant site-related contaminants (i.e.,
fenac, phenol, chlorobenzene, 4-methylphenol) are detected in
samples taken from points that are part of the normal
downstream hydroloqic flow pattern of the watershed as
expected. The compound fenac is found in upstream samples as
well. Its occurrence in these locations may be a result of
deliberate application for plant control purposes and/or
distribution durinq reqional floodinq events. The occurrence
of chlorobenzene in upstream sediment samples supports the
assessment that reqional floodinq events were probably major
contributors to the miqration of site-related compounds to
upstream locations.
. Fenac, chlorobenzene, and other site-related compounds
were observed in upstream samples on Bald Eaqle Creek
and the West Branch, Susquehanna River.
. Fenac and chlorobenzene were not observed in the West
Branch, Susquehana River north of the site above the
confluence.
19
-------
. All samples contain varying amounts of polynuclear
aromatic hydrocarbons and inorqanics which mayor may
not be associated with the Drake Chemical Site.
. The compound pentachlorophenol is found sporadically
throuqhout the area and in three onsite samples. Due to
the occurrence of this compound in the upstream
Susquehanna River sediment and its apparent absence in
downstream Bald Eaqle Creek sediments the occurrence of
the compound is not believed to be site related.
Onsite sediment samples taken from the holdinq laqoons
are hiqhly contaminated by volatile orqanics, fenac, and
base/neutral acid extractable compounds. As previously
stated for the onsite surface waters, this observation is in
aqreement with expectations.
GROUNDWATER
VOAs
As previously mentioned. to facilitate assessment of the
extent of qroundwater contamination and to provide a basis for
identifyinq the scope of qroundwater treatment and remedial
technoloqies, the study area has been divided into three
loqical zones. Zones are based on physical boundaries and
levels of contamination. Fiqures 5, 6 and 7 show the
location of the monitorinq wells and the physical boundaries
for these zones.
Zone 1 represents qroundwater beneath the site and
the Gorham Property. Groundwater in Zone 1 have
been the most severely impacted.
Zone 2 qroundwater include those underlyinq the
area between Zone 1 (i.e., the site) and State Route
220. This area south of the site has been less
severely impacted by site related contamination than
Zone 1.
Zone 3 qroundwater are those south of State Route
220 to Bald Eaqle Creek.
Table 1 presents the summary of the results of volatile
orqanic compound analysis obtained from both rounds of
qroundwater samplinq activities.
In qeneral. samples taken from monitorinq wells in all
three zones are affected by site-related contaminants.
Groundwater in the Zone 1 area is characterized by
trichloroethene, chlorobenzene, ethylbenzene,
20
-------
MW-M106---,
..~ 8MW-M2
~ ~
lc.. ~. -Mw-M3
--,,L.,\ --MS 1'1\_-
J) ~ '-vi MW-E2f8MW-
V MW-MI8
.. t::::J MW-84
~ jr7r"l 8MW-MI08 ,.
1/ : ,.' / j
eJ(J ~
/ MW-MS8 ~
... ./ ..8MW-MI
,- J MW-M68
--J MW.M~",
ro" )
\\
,\
l\
.,~
---
,,-
o
.
200
400
J
SCALE IN FEET
FIGURE
5
ONSITE GROUNDWATER SAMPLING LOCATION
DRAKE CHEMICAL SITE
LOCK HAVEN, PENNSYLVANIA
21
-------
MW-MIOI
MW-MI02
r'~
L.~
I'V
IV
o
.
600
SCALE IN FEET
1200
.
FIGURE
6
,
OFFSITE GROUNDWATER SAMPLING LOCATIONS
DRAKE CHEMICAL SITE
LOCK HAVEN. PENNSYLVANIA
-------
e
r'-'
;8
~ 1
L .---.--'
'r-
\,- I
N
W
LEGEND
ZONE 1
ZONE 2
800
SCALE IN FEET
1600
.
~
ZONE 3
FIGURE
7
GENERAL ARRANGEMENT FOR GROUNDWATER REMEDIATION
DRAKE CHEMICAL SITE
LOCK HAVEN. PENNSYLVANIA
-------
1,2-dichloroethane, 1,2-dichlorobenzene, 1,3-dichlorobenzene,
and 1,4-dichlorobenzene in varyinq amounts. These compounds
are detected in the first and the second samp1inq rounds.
In both cases ch1orobenzene was detected with the qreatest
frequency. Solvents inc1udinq benzene, toluene, and
ethylbenzene were also detected.
Offsite qroundwater taken from Zone 2 monitorinq wells
displays the same characteristic orqanic contamination.
Compounds, includinq benzene, ch1orobenzene,
1,2-dichloroethane, tetrach1oroethene, and trichloroethene
are present in varyinq amounts.
Samples taken from further downqradient of Zone 3
monitorinq wells show that site-related orqanic contamination
is extendinq toward the Bald Eaqle Creek. Consistently,
chlorobenzene was detected in both rounds but at lower
levels of ccintamination than 1, 2-dich1oroethane. This
observation is consistent with the expected contaminant
miqration pathway in the direction of qroundwater flow and
the increased mobility in soils of 1, 2-dich1oroethane
(lower Koc and Kow) over ch1orobenzene.
BNAs, Pesticides/PCBs
Table 4 presents the results of base/neutral-acid
extractab1es, pesticides, and PCB analyses obtained from the
first and second rounds of qroundwater samp1inq. Samples
taken from monitorinq wells in all three zones are affected
by site-related contaminants. No TCL pesticides or PCBs
were detected in any qroundwater samples collected throuqhout
the study area. This observation is consistent with results
obtained for the soi1/s1udqes (i.e., source materials).
Groundwater in the Zone 1 area is contaminated with
compounds includinq 1, 2-dich1orobenzene, 1,3-dichlorobenzene,
1,4-dich1orobenzene, nitrobenzene, 1, 2, 4-trich1orobenzene,
phenol, and alkyl and chlorinated phenolics. The compound
phenol is detected at the hiqhest level of contamination:
however, the concentration is lower than that found in Zone
1 samples. 2,4-Dimethy1pheno1, 1,2-dichlorobenzene, and
1,4-dich1orobenzene occur with qreatest frequency in the
first round of samples. No positive results are reported in
Zone 2 second round samples.
24
-------
Only two extractable compounds were detected in Zone 3
monitorinq well samples. Bis(2-ethylhexyl) phthalate was
detected in four samples at low concentrations and may have
occurred as a result of laboratory contamination. The
compound 3,3-dichlorobenzidine was detected in only one
sample and, since it is an orqanic dye precursor, may be
present as a result of activities at the Drake Chemical
Site.
The compounds phenol and 4-chloroaniline were compounds
with the hiqhest concentration in the first and second
rounds, respectively: however, the frequency of occurrence
for anyone compound is somewhat inconclusive since all
compounds were detected in either one or two samples.
Fenac, B-naphthvlamine, Cyanide
Table 1 displays the results of analyses for fenac
B-naphthylamine and cyanide obtained f~om both the first and
second rounds of qroundwater samplinq activities.
Samples taken from monitorinq wells in all three zones
are contaminated bv one or more site-related contaminants.
Both rounds of samplinq indicate that Zone 1 qroundwater is
contaminated by both fenac and B-naphthylamine. Cyanide is
detected in the first, more comprehensive samplinq round but
not in the second round samples. Fenac was detected at the
hiqhest level of contamination and with the qreatest
frequency. B-napthylamine was also detected in siqnificant
amounts.
Fenac and B-naphthylamine were also detected in offsite,
Zone 2, monitorinq well samples. Fenac was aqain found at
the hiqhest levels and with qreatest frequency. Analytical
values for both B-napthylamine and fenac were lower in
downqradient Zone 2 samples that those reported in Zone 1.
This attenuatinq effect is consistent with the expected
contaminant miqration pathway and correspondinq dilutinq
effects of uncontaminated qroundwater. The compound cyanide
was not detected in either. round of Zone 2 samples.
Samples taken from downqradient Zone 3 monitorinq wells
display further dilution in the concentration of fenac,
while B-naphthylamine was not detected in any Zone 3 sample.
The compound cyanide was detected in a single sample:
however, no case can be made for its occurrence as a result
of site contamination.
25
-------
Total Metals
In qeneral, samples acquired from monitorinq wells in
all three zones demonstrated the presence of metals as would
be expected in a qeochernical settinq. Groundwater in Zone 1
is contaminated with aluminum, arsenic, beryllium, cadmium,
chromium, nickel, iron, and vanadium. These compounds are
detected in the first samplinq round, but not in the more
selective second samplinq round samples.
The metals aluminum, iron, maqnesium, manqanese,
potassium, and sodium occur at the hiqhest concentrations
and with the qreatest frequency but do not appear to be site
related. Heavy metals, includinq mercury, lead, barium,
cadmium, chromium and cyanide are also detected at varyinq
levels.
Offsite qroundwater samples taken from Zone 2 monitorinq
wells display the same type of contamination present in
Zone I samples. Aqain, aluminum, iron, maqnesium,
manqanese, potassium, and sodium occur at the hiqhest
concentrations and with qreatest frequency but their
relationship to the site is not readily discernible. The
heavy metals, however, occur in somewhat lower concentrations
and cyanide is not detected.
Zone 3 samples show the aluminum, iron, maqnesium,
potassium, and sodium occur at the qreatest concentrations
and frequency but the heavy metals seem to increase in
concentration with distance from the site, hence, they are
probably not site related. as opposed to Zone 2. These
trace amounts of metals occur in samples upqradient of the
site and may be indiqenous to the area and may occur as
natural constituents of qroundwater.
Antimony and arsenic are also detected in low
concentrations in Zone 3 samples but occur with limited
frequency. Due to their erratic occurrence and distribution
these elements mayor may not occur as a result of activities
at the site.
26
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PUBLIC HEALTH AND ENVIRONMENTAL ASSESSMENT
Contaminated sludges, soils, and qroundwater remain on
the Drake Site and adjacent Gorham property. These form a
sinqle source that continues to release contaminants to the
environment, presentinq a potential risk to human health.
Human and environmental receptors that may potentially
be exposed to hazardous site associated contaminants are as
follows:
people who may, at some time in the future, reside
on or near the site and use site-contaminated
qroundwater as a source of drinkinq water or those
who currently reside offsite and consume clean
qroundwater that may be affected by site associated
contamination at some future time. No Lock Haven
residents use qroundwater for drinkinq purposes.
Those involved in recreational water activities such
as swimminq. boatinq or fishinq at the Bald Eaqle
Creek and downstream Susquehanna River (below the
Bald Eaqle confluence) .
Those who consume fish taken from both Bald Eaqle
Creek and below the creek confluence with the
Susquehanna River.
Aquatic flora and fauna in Bald Eaqle Creek and the
Susquehanna River.
The qroundwater beneath the site contains relatively
hiqh levels of volatile orqanics, phenolics, B-naphthylamine,
inorqanics, and fenac that exceed relevant requlatory
standards and/or quidelines established specifically for
these compounds. Their presence (especially in Zones 1 and
2) presents siqnificant public health risks to potential
qroundwater users under several exposure scenarios mentioned
above.
The main carcinoqenic risks are from B-naphthylamine,
l,2-dichloroethane, vinyl chloride and arsenic. The RI
estimates the total carcinoqenic risk to be 5.69 X 10 -1
if the hiqhest c~ncentrations are combined to form the worst
case senario.
The bulk of the risk (Zones 1 and 2) is. a result of the
presence of orqanic contaminants, B-naphthylamine, and fenac.
As these contaminants miqrate away from the site (zone 3)
via qroundwater the risks decrease due to the dispersive and
adsorptive effects of transport.
27
-------
Inorganic contaminants including chromium, cadmium,
cvanide, and total arsenic are found throughout the study
are~ (Zones 1, 2, and 3) and account for a sizeable portion
of risk in Zone 3. Analytical values for these compounds
are, however, from total inorganic analyses (i.e., unfiltered
sample media). The presence of contaminants such as antimony,
lead, cadmium, and nickel are most likely a result of
suspended particulate material in the aqueous samples from
drilling and well development operations. A clear pattern
of inorganic contamination is not evident and mayor may not
be related to activities at the Drake Chemical Site.
Surface water samples contained inorganic analytes and
the compound Fenac. Analytical values for. these constituents
do not exceed MCLs. The contaminants copper and zinc,
however, do exceed the AWOC chronic toxicity values for
aquatic organisms. Both zinc and copper occur in upgradient
sampling locations and are detected throuqhout the study
area. Their presence in surface waters cannot be attributed
specifically to activities at the Drake Site.
COMMUNITY RELATIONS
EPA has been involved in site remediation at Drake
Chemical since 1982 when the first removal action occurred
and the Agency has always made pubLic announcement of the
onsite activities. There was a Community Relations Plan for
the entire RI/FS activities since 1983 when the first RI
began and these activities have included several public
meetings. Specific community relations activities for phase
I and Phase II are outlined in their respective RODs and
will not be repeated here. Therefore, this decision document
will gO over all community relation activities for the third
phase of the remedial action selection in this ~OD.
The first attempt to select a remedial clean up
standard was in the Phase II RI/FS where the technical data
was collected and reported in the Phase II RI report. This
was made available to the public in March 1986 and copies
were placed in the local repositories. The four repositories
were located at the Lock Haven City Hall, the Clinton County
Commisioner's Office, the Lock Haven Public Library and the
Lock Haven University Library. The Phase II FS, however,
did not address the soil. sludges and groundwater because no
.firm decision could be made at that time about the source
remediation.
At that time PADER was in the middle of negotiating a
consent decree with the neighboring American Color and
Chemical facility for a RCRA closure and it was felt that
EPA's selected alternative for the soils, sludges and
28
-------
qroundwater should be consistent with the PADER closure
requirements. Therefore the Aqencies waited until September
of 1986 to present the Phase III FS for the soil, sludges
and qroundwater.
On September 7, 1986, the Aqency held another public
meetinq to present a "preferred alterriative" for the site.
EPA selected an option which would leave the soil and sludges
in place. The "preferred alternative" would be to lower
the water table by extraction wells and to place a RCRA type
cap to cover the site and prevent further infiltration of
water. The public reaction was extremely neqative. This
reaction prompted the Aqency to chanqe its "preferred.
alternative" to a complete new RCRA type landfill onsite.
Then further discussion were held with local officials and
PADER. Shortly thereafter, PADER selected its "preferred
alternative" which was to excavate the soil and sludges and
place them in an offsite landfill. Therefore the aqencies
disaqreed on the location for the proposed containment-
facility.
This disagreement was not resolved and by October 1986
Conqress passed the Superfund Amendments and Reauthorization
Act. This new law specifically stated a stronq preference
for permanent treatment methods and also stated that
landfills were the least preferred alternative. The result
was to reinvestiqate the site and potential treatment
technoloqies which could provide a permanent solution.
The phase III RI and subsequent FS were initiated in
January 1987 and have lead to the present set of RI/FS
documents which are part of the administrative record and in
the local repositories. Throuqhout this process we have
kept the local and State officials informed of our activities
and have had some newspaper coveraqe durinq the field
activities.
EPA's proposed plan was published in an advertisement
on Auqust 31, 1988 and included the alternative selected
herein. The advertisemen~ in the Lock Haven paper announced
the beqinninq of a 30 day public comment period and a public
meetinq which was held on September 7, 1988 in Lock Haven.
The public meetinq was preceded by a meetinq with the City
and County officials and the minutes from both meetings are
attached as part of the Responsiveness Summary.
In qeneral, the community appears to be in agreement
with the remedies selected in this ROD and are pleased with
the permanent destruction of the soil and sludges. They
also are pleased that the site will possibly be available
for some other use when the selected remedial actions are
completed.
29
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DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVES (RAAs)
Durinq the phase III FS, remedial technoloqies were
studied to determine which would be applicable to the
specific conditions at the Drake Chemical Site. Screeninq
of the technoloqies was based on data from the Phase III RI
and on Applicable or Relevant and Appropriate Requirements
(ARARs), as described by the NCP as amended by SARA. ARARs
can be loosely defined as requirements of state or federal
.environmental laws. EPA must ensure that the Superfund
response action attains all pertinent state and federal
environmental requirements. ARARs applied to the site fall
into three broad cateqories: Contaminant-specific ARARs
qovern the level of cleanup to be attained. For example,
MCLs concern individual substances and identify concentration
levels for each that can not be exceeded. Location-specific
ARARs are those concerninq natural or man-made site
characteristics, such as wetlands, scenic rivers, historic
districts, and aquifer desiqnations. Of special concern at
the Drake Chemical Site are the location of the site in the
floodplains of both the Susquehanna River and Bald Eaqle
Creek and the desiqnation of the qroundwater aquifer as a
protected potential drinkinq water supply. ARARs that
pertain to the implementation of a particular remedy are
action-specific ARARs. Examples include monitorinq
requirements, effluent discharqe limitations, and
occupational health and safety requirements. In addition to
these considerations, each remedial technoloqv selection
must also be quided by an evaluation of the followinq
criteria: short-term effectiveness: lonq-term effectiveness
and permanence: reduction of toxicity, mobility, or volume:
ease of implementation: cost: protection of human health and
the environment: and acceptability to the state and community.
Durinq the FS, many technoloqies were evaluated for the
Drake Chemical Site. Those that were iudqed applicable were
combined into process schemes, called RAAs. For Operable
unit A, several alternatives were selected for continued
consideration. Some are sinqle technoloqy alternatives that
have been sufficiently developed and tested so that their
use at the Drake Chemical Site should be hiqhly successful.
These recommended alternatives for Operable unit A
(Alternatives A-I and B-1) have the proven ability to treat
all contaminant types present at the site for the full ranqe
of contaminant concentrations. Other alternatives
(Alternatives C-l and D-I) will require moderate to extensive
treatability tests, because they are emerqinq technoloqies
for hazardous waste applications. The mixture of organic
and inorqanic contaminants present in the qroundwater
requires a combination of treatment technoloqies to achieve
treatment qoals for Operable unit B. All the RAAs developed
involve qroundwater pumpinq and treatinq methods, but each
RAA features a different secondary treatment step in the
wastewater treatment process.
30
-------
The RAAs considered for Operable Units A and Bare
described below. For each unit, a No-Action Alternative
is considered. as required by law. All of the other RAAs will
include flood protection for the soil/sludqe treatment unit
and the qroundwater treatment system.
Operable Unit A - Sludqe, Soil, and Sediment "RAAs
1) No action with monitorinq.
2) A-l - Excavatinq all sludqes/soils/sediments: treatinq
with rotary kiln incineration: disposinq of incinerator
ash: backfillinq. reqradinq. and reveqetatinq the site.
3) B-1 - Excavatinq all sludqes/soils/sediments: treatinq
with infrared incineration: disposinq of incinerator ash:
backfilling. reqradinq. and reveqetatinq the site.
4) C-l - Treatment usinq in-situ vitrification to immobilize
contaminants: backfillinq. reqradinq. and reveqetatinq
the site.
5) 0-1 - Installinq injection and extraction wells above the
water table for in-situ soil washinq. usinq effluent from
the Operable Unit 3 Wastewater Treatment plant (WWTP) as
a flushinq aqent, then treatinq the resultinq contaminated
wastewater stream.
Operable Unit B - Groundwater RAAs
1) No action with monitorinq.
2) Modified RAA-l - Installinq extraction wells: buildinq a
treatment plant featurinq sand filtration and carbon
adsorption: treatinq extraction stream: discharqinq
effluent: disposinq of residuals: monitorinq qroundwater.
3) RAA-4 - Installinq extraction wells: buildinq a treatment
plant featurinq Bioloqical Activated Carbon (BAC):
treatinq extraction stream: discharqing effluent:
disposing of residuals: monitoring qroundwater.
4) RAA-5 - Installinq extraction wells: building a treatment
plant featurinq sand filtrat~on and ozone/UV: treatinq
and discharqinq effluent to a Publicly Owned Treatment
Works (POTW) for post treatment: disposing of residuals:
monitoring qroundwater.
5) RAA-5A - Installing extraction wells: building a treatment
plant featuring sand filtration, ozone/UV, and activated
sludqe: treatinq extraction stream: disposinq of
residuals and monitoring qroundwater.
31
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TABLE 2
Operable unit A - Summary of Comparisons Among Alternatives
Drake Chemical Site, Lock Haven, Pennsylvania
** ~O ACTION WITH MONITORING
Deed restrictions to prevent direct contact with the source.
possibly install flood protection. Onqoinq monitorinq.
Short-Term Effectiveness
protection will not be achieved.
Lonq-Term Effectiveness and Permanence
Situation unchanqed.
No reduction of existinq risk.
Reduction of Toxicity, Mobility or Volume
None
Implementability
Groundwater monitorinq would be easy to implemdnt and construct
Cost (Present Worth)
$654,000
Compliance with ARARs
Does not meet state health department criteria for qroundwater
Quality.
Overall protection of Human Health and the Environment
Risk of direct contact with contaminated soils/sludqes
currently controlled by fence.
Environmental deqradation will increase as leachinq from
onsite soils/sludqes to the qroundwater continues.
State Acceptance
Not acceptable
Community Acceptance
Not acceptable
32
-------
TABLE 2 continued
Operable unit A - Summary Of Comparisons Amonq Alternatives
Drake Chemical Site, Lock Haven, Pennsylvania
** ALTERNATIVE Al
ROTARY KILN INCINERATION
Short-Term Effectiveness
.
3-5 years to incinerate 252,000 cubic: yards.
.
Well proven and reliable technoloqy for destruction of
orqanics.
. protection of community durinq remedial action will need
to be addressed.
Protection of workers durinq remedial actions is also
needed.
Lonq-Term Effectiveness and Permanence
NO risk remains associated with orqanics. Minor risk
remains from residuals remaininq on site, includinq metals
in the incinerator ash.
Reduction of Toxicity, Mobility or Volume
Toxicity and volume of essentially all orqanics destroyed.
Metals remain in incinerator ash: volume reduction is
minimal. Treatment is irreversible.
Implementability
Incineration would require special equipment and operators.
Residuals require testinq to verify treatment.
Limited treatability testinq required.
Mobile incinerator and specialized operators needed.
locally available.
Not
Cost (present Worth)
$81,284,000
. Operation and Maintenance Costs not applicable
33
-------
TABLE 2 continued
Operable Unit A - Summary Of Comparisons Arnonq Alternatives
Drake Chemical Site, Lock Haven, Pennsylvania
Compliance with ARARs
.
All ARARs will be met or exceeded. EP toxicity or TCLP
testinq of "incinerator ash leachate will be required.
.
Compliance with criteria, advisories and quidance.
Complies with Federal, state, and local criteria.
Overall protection of Human Health and the Environment
Risks of direct contact with contaminated soils, sludqes,
and dust eliminated by treatment.
For orqanics, risk ~o human health and the environment
from qroundwater contamination permanently eliminated by
treatment of soils/sludqes/sediments and qroundwater.
Elimination, reduction or control of risks. For metals
in the residual ash leachate, testinq is required to
determine applicability to use as backfill.
For o~fsite incineration, all risks are eliminated.
State Acceptance
Acceptable
Community Acceptance
Acceptable
** ALTERNATIVE Bl
INFRARED INCINERATION
Short-Term Effectiveness
Time until protection is achieved.
incinerate 252,000 cubic vards.
4-1/2 to 7 years to
Well proven and reliable technoloqy for destruction of
orqanics. Some treatability testinq required.
Protection of community durinq remedial actions needed.
Protection of workers durinq remedial actions needed.
34
-------
TABLE 2 continued
Operable Unit A - Summary Of Comparisons Arnonq Alternatives
Drake Chemical Site, Lock Haven, pennsylvania
Lonq-Term Effectiveness and Permanence
.
No risk remains associated with orqanics. Minor risk
remains from residuals remaininq on site, includinq metals
in the incinerator ash.
Reduction of Toxicity, Mobility or Volume
.
Toxicity and volume of essentially all organics would be
destroyed. Metals remain in the incinerator ash: volume
reduction is minimal. Treatment is irreversible.
Implementability
.
Incineration would require special equipment and operators.
Residuals require testinq to verify treatment effectiveness.
Commercial technoloqy.
Limited treatability testinq required.
Cost (present Worth)
$171,912,000
Compliance with ARARs
All ARARs will be met or exceeded. EP toxicity or TCLP
testinqof incinerator ash leachate will be required.
Overall protection of Human Health and the Environment
Risks of direct contact with contaminated soils, sludqes,
and dust eliminated by treatment.
For orqanics, risk to human health and the environment
from qroundwater contamination per~anently eliminated by
treatment of soils/sludqes/sediments and qroundwater.
For metals in the residual ash leachate, testinq is
required to determine applicability to use as backfill.
For offsite incineration, all risks are eliminated.
State Acceptance
Acceptable
Community Acceptance
Acceptable
35
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TABLE 2 continued
Operable Unit A - Summary Of Comparisons Amonq Alternatives
Drake Chemical Site, Lock Haven, Pennsylvania
** ALTERNATIVE Cl
IN-SITU VITRIFICATION
Short-Term Effectiveness
3 to 11 1/2 years to vitrify 252,000 cubic yards.
.
Protection of a community durinq remedial actions needed
Protection of workers durinq remedial actions needed
Lonq-Term Effectiveness and Permanence
No risks should remain associated with orqanics or metals.
Treatability testinq will be required to confirm.
Reduction of Toxicity, Mobility or Volume
Essentially all orqanic toxicity is destroyed throuqh
pyrolysis or immobilized. with metals, in the vitrification
matrix. Confirmation throuqh treatability testinq is
requ~red. Treatment is irreversible.
Implementability
Vitrification would require special equipment and
operators. pilot plant scale for hazardous waste
applications.
Limited excavation and staqinq operations.
Cost (Present Worth)
$117,564,000
Compliance with ARARs
All ARARs will be met or exceeded.
Compliance with criteria, advisories, and quidance
Complies with Federal, state, and local criteria.
36
-------
TABLE 2 continued
Operable unit A - Summary Of Comparisons Amonq Alternatives
Drake Chemical Site, Lock Haven, Pennsylvania
Overall protection of Human Health and the Environment
.
Risks of direct contact with contaminated soils, sludges
and dust eliminated by treatment.
Risk to human health and the environment from qroundwater
contamination permanently eliminated by treatment of
soils/sludqes/sediments and qroundwater.
State Acceptance
Acceptable
Community Acceptance
. Acceptable
** ALTERNATIVE Dl
SOIL WASHING
Short-Term Effectiveness
Remediation not attained. even in 30 years for
B-Napthylamine and metals.
Short term reliability of technoloqy
protection of community durinq remedial actions needed
Protection of workers durinq remedial actions needed
Lonq-Term Effectiveness and Permanence
Siqnificant risk remains, primarily from B-napthylamine.
Residual contamination may contaminate qroundwater.
Groundwater may be adversely affected by soil additive
- aqents (if required).
Proper maintenance is very important.
replacement.
PU!TIPS may need
Reduction of Toxicity, Mobility or volume
Residual and volume of some orqanics removed throuqh soil
washinq and treated bv the WWTP. Insiqnificant amounts
of metals would be removed. Treatment is irreversible.
37
-------
TABLE 2 continued
Operable Unit A - Summary of Comparisons Amonq Alternatives
Drake Chemical Site, Lock Haven, pennsylvania
Implementability
.
Most likely implementable for the soils but not the
sludqes because of hydraulic conductivity considerations.
Barrier walls or interceptor trenches may be required to
prevent off site miqration. Soil additives may be required
to enhance the process.
Cost (present Worth)
$26,856,000
Compliance with ARARs
Contaminant-specific ARARs will not be met for certain
contaminants in the soil. particularly B-naphthyamine.
Does not meet state health department criteria for all
contaminants.
Overall Protection of Human Health and the Environment
Risks of direct contact partially reduced by treatment.
Risk to human health and the environment from qroundwater
contamination partially reduced by treatment of soils/
sludqes/sediments and qroundwater.
Remaininq risk primarily due to B-naphthylamine.
State Acceptance
Not Acceptable
Community
Acceptance
Not Acceptable
38
-------
TABLE 2 continued
Operable unit B - Summary Of Comparisons Among Alternatives
Drake Chemical Site, Lock Haven, pennsylvania
** NO ACTION WITH MONITORING
Short-Term Effectiveness
Protection will not be achieved.
Lonq-Term Effectiveness-
Situation unchanqed; no reduction of existinq risk.
Reduction of Toxicity, Mobility, or Volume
No amount of hazardous materials destroyed or treated
No deqree of expected reduction in toxicity, mobility or
volume
No type and auantities of residual remaininq after
treatment
Implementability
Groundwater monitorinq would be easy to implement and
construct.
Zone 1, 2 and 3 pu~pinq Option Costs
Present worth - $654,000
Operatinq and Maintenance costs - $66,000
Compliance with ARARs
Does not meet state health department criteria for
qroundwater quality.
Overall protection of Human Health and the Environment
No controls.
Environmental deqradation will increase as the
qroundwater plume spreads.
State Acceptance
. Not acceptable
39
-------
TABLE 2 continued
Operable unit B - Summary Of Comparisons Amonq Alternatives
Drake Chemical Site, Lock Haven, Pennsylvania
Community Acceptance
Not Acceptable
Deed restrictions to prevent on site or off site use of
contaminated qroundwater. Onqoinq monitorinq.
** ALTERNATIVE Ml - SAND & FILTRATION & CARBON ADSORPTION
Short-Term Effectiveness
APproximately 30 years for treatment to be completed.
Well proven and reliable treatment technoloqies.
Protection of Worke~s Durinq Remedial Actions needed
Lonq-Term Effectiveness
.
Existinq risk eliminated.
Excellent lonq-term reliability based on performance of existi
similar systems.
Reduction of Toxicity, Mobility, or Volume
Toxicity removed from qroundwater.
Implementability
Sizeable undertaking but quite feasible to desiqn, construct and
operate treatment.
Spent qranular activated carbon will require reqeneration by
pyrolysis.
Zones 1, 2 and 3 - Pumpinq Option Costs
Present Worth - $26,203,000
Operatinq & Maintenance Costs - $1,528,000. (averaqe)
Compliance with ARARs
All ARARs will be met.
Complies with state and local criteria
and Federal advisorie~
40
-------
TABLE 2 continued
Operable unit B - Summary Of Comparisons Among Alternatives
Drake Chemical Site, Lock Haven, pennsylvania
Overall protection of Human Health and the Environment
.
Risks to humag health and the environment significantly
reduced lxlO- risk level, by extraction and treatment
of the qroundwater.
State Acceptance
Acceptable
Community Acceptance
Acceptable
** ALTERNATIVE 4 - BIOLOGICAL ACTIVATED CARBON - (BAC)
Short-Term Effectiveness
Time until protection is achieved - APproximately 30 years.
BAC is expected to have an excellent short-term reliability.
Treatability testing is required.
Protection of community durinq remedial actions needed
protection of workers durinq remedial actions needed
Lonq-Term Effectiveness
Reduction of existinq risks - Existinq risk eliminated.
Only lonq-term risk is qeneration of residue.
Lonq-Term Effectiveness
Lonq-term reliability - Excellent long-term reliability
based on performance of existinq related systems.
Reduction of Toxicity, Mobility or Volume
Toxicity removed from qroundwater.
Implementability
Technical Feasibility - Sizeable undertaking but quite
feasible to desiqn, extract and operate treatment.
41
-------
TABLE 2 continued
Operable Unit B - Summary of Comparisons Among Alternatives
Drake Chemical Site, Lock Haven, Pennsylvania
Zones 1, 2 and 3 Pumping Option Costs
Present worth - $16,079,000
Operating & Maintenance Costs - $787,000 (average>
Compliance with ARARs
All ARARs will be met.
Complies with state and local criteria and Federal
advisories.
Overall Protection of human health and the environment
Risk to human health and the environment significantly
reduced to lxlO-5 risk level, by extraction and treatment
of the qroundwater.
State Acceptance
Acceptable
Community Acceptance
Acceptable
** ALTERNATIVE 5 - SAND FILTRATION AND OZONE/UV
Short-Term Effectiveness
Time until protection is achieved - approximately 30 years.
Reliability is expected to be excellent. Treatability
testing is required to verify efficiency and desiqn of
ozone/uv process.
Protection of Workers during remedial actions needed
Lonq-Term Effectiveness
Existing risk eliminated although some nontoxic organic
pollutants may remain, which will be treated by the local
POTW.
Only long-term risk is qeneration of residue.
42
-------
Reduction of Toxicity, Mobility, or Volume
Toxicity removed from qroundwater.
Implementability
Sizable undertakinq but quite feasible to desiqn,
extract and operate treatment
Zones 1, 2 and 3Pumpinq option Costs
.
Present worth $22,874,000
Operatinq and Maintenance Costs $ 1,110,000
Compliance with ARARs
Complies with state and local driteria and Federal
advisories.
Overall Protection of human health and the environment
Risk to human health siqnificantly reduced.
State Acceptance
Acceptable
Community Acceptance
Acceptable
43
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Recommended Alternative
After extensive review by EPA and PADER the Aqencies
have chosen to remediate the soil and sludges by treatment
with an onsite mobile rotary kiln incinerator and to
remediate the qroundwater in Zones 1 and 2 by an onsite
water treatment unit featurinq the Bioloqical Activated
Carbon, The followinq tasks will be performed as part of
the remedial action.
- install necessary flood control measures
- remove aqueous wastes from leachate laqoon area and
treat
- install permanent stormwater management controls in
the leachate lagoon area and other areas to be excavated
excavate approximately 252,000 cubic yards of
contaminated sludge/soils/sediments and decontaminate
usinq a transportable, onsite, rotary kiln incinerator
(The thermal treatment unit must comply with
incineration permit requirements including air
emissions and monitorinq.)
- analyze incinerator ash and use as backfill if
acceptable in accordance with State requirements
(Further treatment of ash unsuitable for'backfill may
be necessary for' onsite disposal.)
- remove unnecessary obstacles, such as water and sewaqe
lines from the facilities and maintain local lines
that are presently in use
- backfill excavated areas with suitable material, reqrade
to provide positive drainage, and reveqetate the
topsoil to control erosion
- collect and treat all contaminated water that enters
the site (e.q. qroundwater, stormwater, and decontam-
inated water) at the qroundwater treatment system
- desiqn and construct and onsite wastewater treatment
plant
- install extraction wells in the areas of qroundwater
. contamination within the property boundaries of the,
former Drake Chemical facilities and in the properties
adjacent to the facility in the south and east
directions
- pump qroundwater to the treatffient systeffi
44
-------
- treat by usinq Bioloqical Activated Carbon (BAC)
- discharge effluent to Bald Eaqle Creek either throuqh
the underqround conduit constructed for the Phase I
leachate stream or throuqh the Lock Haven sewaqe
treatment facility (The water treatment unit must
comply with permit requirements for discharge of
treated water)
- analyze residuals (e.q. sludqecake) and use as
backfill if acceptable in accordance witn State
requirements (Further treatment may be necessary for
onsite disposal.)
This alternative is selected for the soil and sludges
onsite because it will provide for contaminants and potential
health threats from known carcinoqens and other toxic
chemicals. The ash will be analyzed for possible metal
concentrations which may require further treatment. All
acceptable materials will be placed back on the site as fill
material after excavation.
The entire site of 12 1/2 acres will be excavated to
the water table and will be treated by the thermal treatment
unit. The aqency has selected this alternative because the
chemical analysis has shown that the level of contaminants
throuqhout the site do present a health risk and it is known
that some of the specific compounds could be present even if
they are no specifically detected by analytical methods.
Therefore the entire site which includes the Drake Chemical
property and the Gorham property are slated for excavation
and incineration.
No specific chemical levels are established because the
excavatinq should continue to the water table where the
second portion of the remedy will address qroundwater
treatment.
The qroundwater treatment of Bioloqical Activated
Carbon was selected because it has been a proven technoloqy.
Also the system will have several components which can
address the variety of orqanic and inorqanic contaminants.
If the system as proposed is not as effective as required by
State or local standards, additional components can be added
to the proposed system.
45
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STATUTORY DETERMINATIONS
Protection of Human Health and the Environment
The operable remedial units selected in this ROD are
clearly as protective of human health and the environment .
as possible at this time since permanent destruction of onsite
materials will be conducted.
The qoal of qroundwater remediation would be to meet
the current drinkinq water standards for chemical specified
Maximum Contaminant Levels (MCLs) or Maximum Contaminant
Level Goals (MCLGs). Aqain, specific requirements must
comply with MCLs at the time of remediation. Since the
qroundwater remediation may take up to 30 years or lonqer,
the aqencies will be required to review the effectiveness of
the extraction and treatment system on a periodic basis. At
a minimum this review should occur every five years. In
this review the aqencies must consider the reduction of
chemical concentrations for each of the three zones of
qroundwater and possibly alter the placement of extraction
wells or consider any benefits from reinjection of cleaned
and treated water which could speed up or help to control
the rate of remediation.
Attainment of Applicable or Relevant and Appropriate
Requirements (ARARs)
The remedies will meet all ARARs for the federal and
state qovernments and no waivers are required at this time.
Local requirements must also be considered if the Lock
Haven POTW is used for the final treatment of the
qroundwater treatment system.
Some of these requirements will need to hi
chemical standards and will be further defined
desiqn staqe when the perraittinq requirements <
Some of these requirements will need to have specific
in the
are met.
The followinq table 3 provides a summary of the federal
and state ARARs. The primary requlations of concern are RCRA
requirements for incinerators, air requirements for incinerator
emissions, and NPDES requirements for discharqe or local
sewaqe plant pretreatment requirements. Additional requirements
are outlined here, but will not supersede any new or more
strinqent requirements which may be in effect at the time of
site remediation.
46
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TABLE 3
Action-Specific ARARs for Operable Units A and B
Requirement
FEDERAL
OSHA Requirements (29 CFR,
Parts 1910, 1926 and 1904)
Threshold Limit Values,
American Conference of
Governmental Industrial
Hyqenists *
DOT Rules for Hazardous
Materials Transport (49 CFR,
Parts 107, 171.1-5000)
Clean Water Act
NPDES Permit Requirements
Hazardous Waste Requirements
(RCRA.Subtitle C, 40 CFR
Part 264)
General Pretreatment
Requlations for Existing and
New Sources of Pollutants
(40 CRF Part 403)
Federal Manifest for Transport
of Hazardous Waste (40 CFR,
Part 262)
Safe Drinking Water Act
Underqround Iniection
Control Requlations
(40 CFR, Parts 144,145,
146, and 147)
Rationale
Required for workers engaged
in onsite remedial activities
May be appropriate for air
concentrations during remedial
activities
Remedial alternatives may
include offsite treatment and
disposal
Remedial alternatives may
include discharge of effluent
to surface waters.
Applicable to treating,
storing, and disposing of
hazardous wastes.
Remedial alternatives may
include discharge of effluent
to POTW
Hazardous wastes may be
transported offsite
May be appropriate for
discharge of effluent to
underground waters for soil
washing
47
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TABLE 3 (continued)
Requirement
STATE
Pennsylvania Solid Waste
Disposal Requlations, PA Code
Title 25, Chapter 75
Pennsylvania pollutant
. Discharqe Elimination System
(NPDES) Rules, PA Code
Title 25, Chapter 92
Pennsylvania Wastewater
Treatment Requirements, PA Code
Title 25, Chapter 95
Pennsylvania Industrial Waste
Requlations, PA Code Title 25
Chapter 97
pennsylvania Special Water
Pollution Requlations, PA Code
Title 25, Chapter 101
Pennsylvania Air Pollution
Control Requlations, PA Code
Title 25, Chapter 121
throuqh 143
Pennsylvania Storm Water
Manaqement Act of
October 4, 1978, Act No. 167
pennsylvania Erosion Control
Requlations, PA Code Title 25,
Chapter 102
Pennsylvania Hazardous
Substances Transportation
Requlations PA Code Title 25,
Chapters 121 - 143
Rationale
Standard for treatinq,
sortinq, and disposing of
hazardous wastes
Remedial actions may include
discharqe of effluent to
surface waters
Remedial actions may include
discharqe of effluent to
surface waters
Remedial actions may include
discharqe of effluent to
surface waters, or underqround
waters in the case of soil
washinq
Applicable for permitted solid
waste disposal facilities
Incineration is considered a
potential remedial action
Remedial actions may require
stormwater manaqement systems
Soil disturbances durinq
proposed remedial actions may
require erosion and
sedimentation control
measures
APplicable to waste shipped
offsite for analysis,
treatment, or disposal
*
Criteria, advisories, or other Quidelines to be
considered (TBCs)
48 .
-------
Cost Effectiveness
The remedies have been reviewed for the costs and are
cost effective under current technoloqies.
utilization of Permanent Solutions
The remedies use permanent solutions for the soils and
sludqes and will attempt longtermjpermanent treatment for the
qroundwater which will reduce the toxicity, mobility and
volume of contaminated sludqes, soils and qroundwater.
Under current statues the ten vear period of qroundwater
remediation will be part of the selected remedy after which
operation and maintenence will beqin.
If remediation qoals are met, or if no further benefit
in The extraction and treatment proqram can be obtained, the
aqencies may aqree to discontinue the qroundwater remediation
efforts.
Preference for Treatment as a Principle Element
Incineration is a treatment which can destroy the complex
chemical mixtures at the Drake Chemical site and will assure
the aqencies. that the contaminants found in the RI will be
removed from the site.
The qroundwater treatment is also a proven technoloqy
and construction of the multiple systems will allow any
necessary additions ~o assure effective treatment to meet
discharqe requirements.
49
-------
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-------
FINAL
RESPONSIVENESS SUMMARY
DRAKE CHEMICAL SITE
LOCK HAVEN, PENNSYLVANIA
SEPTEMBER 23, 1988
WORK ASSIGNMENT NUMBER 123-3L31
-------
SEPTEMBER 23, 1988
FINAL
RESPONSIVENESS SUMMARY
DRAKE CHEMICAL SITE
LOCK HAVEN, PENNSYLVANIA
EPA WORK ASSIGNMENT NUMBER 123-3L31
Contract Number 68-01-7250
Prepared By:
Ebasco Services Incorporated
Langhorne, Pennsylvania
Approved By:
Ebasco Services Incorporated
Langhorne, Pennsylvania
Prepared By:
ichard C. Evans, P.E.
Regional Manager, Region III
Ebasco Services Incorporated
~0 x-bO
Carrie Clain Deitzel
community Relations Coordinator
Ebasco Services Incorporated
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DRAKE CBEHICAL SITE
LOClt RAVEN, PENNSYLVANIA
PINAL
RESPONSIVENESS SUHMARY
SEPTEKBER 1988
. This Responsiveness Summary documents public concerns and
comments expressed during the public comment period. The
summary also documents the EPA's responses to the comments and
concerns that were received. Information is organized as
follows:
overview
Summary of Community Involvement
Summary of Comment~ and Responses Regarding the Phase III
Feasibility Study
4.0 Other Concerns and Responses
5.0 Re~aining Concerns
Attachment:
community Relations Activities at the Drake Chemical Site
1.0
2.0
3.0
1.0
OVERVIEW
The public comment period for t~e Drake Chemical site began on
Au g us t :J 0, 19 8 8 I and ext end e d to S e p t e mb e r 2 8, 19 8 8 . To
facilitate commenting, EPA briefed community officials in a
meeting at Lock Haven City Hall and held a public meeting at
Ulmer Planetarium, Lock Haven University of Pennsylvania, on
September 7, 1988. . .
At the meeting, EPA discussed the Phase III feasibility study
and presented EPA's preferred remedial alternatives. These
alternatives addressed contaminated soils, sludges, sediments,
and groundwater contaminated primarily with o~ganics, including
fenaci chlorobenzenei 1, 2 dichloroethene, and a variety of
other organics associated with the manufacture of dye. The
Agency recommended rotary kiln i~cineration of the soils,
sludges, and sediments and disposal of resultant ash on the site
by backfilling, covering with clean soil, and then regrading and
revegetating the site. The Agency's preferred alternative for
groundwater remediation consists of pumping groundwater and
treating it with a Biological Activated Carbon process prior to
discharging the effluent to local surface waters or to the
public sewage treatment facility.
1
-------
Officials of the Pennsylvania Department of Environmental
Resources (PADER) reportedly qave a preliminary indication that
the Aqency's preferred alternatives may be acceptable to them if
agreement can be reached regardinq the volume of materials to be
excavated and incinerated. Local officials supported the EPA's
preferred alternatives but strongly recommended that the Aqency
consider expanding the municipal sewage treatment facility
rather than building a groundwater treatment plant on-site. No
comments or concerns were expressed by private citizens or by
responsible parties.
2.0
SUKMARY OP COHHtJJfITY IIIVOLVEKBNT
Lock Haven residents became aware of the Drake Chemical Site as
early as 1962 because of numerous fires that occurred at the
site. Local officials have interacted closely with EPA and
PADER officials since a 1982 EPA emerqency action was conducted
at the site, followinq the 1981 closing of Drake Chemical
Company. Resident involvement peaked in 1983 when two citizens'
groups were active. In early 1983, the Rural Development
Committee, expressed CGncern about several issues, but the qroup
was not heard from thereafter. The second qroup, CLEAN
(Citizens and Laborers for Environmental Action Now) was
composed predominantly of former chemical company workers and
their families, and its primary qoal was to secure health
screeninq for former Drake employees. As a result of CLEAN's
efforts, a task force of local doctors, officials, and residents
was established, in 1983, to assist the Pennsylvania Department
of Health (PADOH) to conduct a medical study. CLEAN apparently
became inactive in late 1984 or early 1985. However, following
the initial health study, the Centers for Disease Control (CDC),
the National Institute of Occupational Safety and Health
(NIOSH), and PADOH initiated a lonq-term study of
occupationally-exposed former Drake workers. The study, funded
by the Federal Superfund proqram, is beinq conducted by the
Center for Environmental Epidemioloqy at the university of
Pittsburgh and will extend over a 5-year period. The University
reports a satisfactory level of participation in the proqram.
Several public meetings regarding the Drake Chemical site have
been held since 1982. Over time, public participation has
decreased, althouqh local officials have remained actively
involved, and the news media has continued its interest and
coveraqe. In addition to local gfficials and news media
representatives, less than 20 residents attended the Phase III
public meetinq on September 7, 1988.
2
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3.0
SUHHARY 01' COMKEN'l'S UID RESPOIISES
Virtually all of the comments and responses summarized in this
section were made during the briefing of officials on
September 7, 1988. One co..ent, indicated with an asterisk (*),
was repeated by an official at the public meeting also held on
September 7, 1988.
The primary concern expressed by local officials is the
final disposition of groundwater extracted from the site.
If EPA elects to send this water to the local sewage
treatment plant, the volume of water from the Drake
Chemical Site, combined with the volume from the adjacent
AC&C facil i ty, may' load the plant to capacity and make it
impossible to brinq in any new industrial clients.
Officials strongly suggested that EPA consider expanding
the capacity of the municipal plant, instead of building a
separate water treatment facility at the site. They
suggested that it may be much cheaper to do this and said
that the long-range benefits to the community from the
municipal facility expansion would be greater than those
derived from a facility built on site for relatively
short-term use.
*1. .
EPA ReSDonse:
EPA has considered both the option of
buildinq its own groundwater treatment plant
on site and discharging the effluent into
Bald Eagle Creek and the option of sending
the treated effluent to the municipal sewage
plant for finishing. If EPA elects to
extract groundwater from only Zone 1, th~
volume of water extracted will be about
30 gallons per minute (gpm). If groundwater
is extracted from Zones 1 and 2, the volume
of water extracted will be approximately
60 gpm. EPA does not want to impose on the
existing municipal facility and push it to
capacity. One advantage of the proposed
onsite groundwater treatment plant is that
the system can be expanded, as needed.
The Record Of Decision (ROD) will probably
raco..end either building an onsite
groundwater treatment and finishing facility
or treating th& water at the municipal
sewage treatment 'plant, depending upon which
option is most suitable at the time the
design is developed. The ROD will be worded
to leave either option open.
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There are some advantages to using the
municipal facility: EPA wouldn't have to
secure discharge permits or meet other
requirements and EPA wouldn't have to
monitor discharge on a regular or long-term
basis.
2.
Another ,priority concern for local officials and one which
has been raised throughout the remedial program, is the
question of property ownership and future use of the site.
City officials do not believe that they should have to
purchase the property from the court after the Federal
government spends money to clean it up. They believe the
Federal government should take steps to make it possible
for such properties to be returned to local tax bases and
that there should be some certification from the Agency
regarding the safe future use of such sites. Officials
pointed out that many activities, such as warehousing, can
be conducted above ground, and the ability to use the
property could be meaningful to the, city in the future.
EPA ReSDonse:
The ownership of the Drake Chemical site
will remain in the bankruptcy estate. After
cleanup, the estate has the option to sell
the property. Incinerator residuals are
likely to be placed on site, and the Agency
will consider the site remediated following
the proposed actions. Therefore, the
property could be used, if someone wanted to
buy it. The question is whether anyone
would elect to purchase the property,
knowing that there will be a 30-year
groundwater pumping and treating program in
progress and that under SARA the new owner
could be held liable, if additional problems
are discovered.
3.
Officials inquired about the projected remedial schedule
and whether there was a waiting period between the soil
remediation and the groundwater remediation. One official
suggested that a waiting period might make sense as the
removal ot the soils, in itselt, would possibly result in a
dramatic reduction in the concentrations ot contaminants in
the groundwater. .
.
EPA ReSDonse:
The excavation and incineration of soils,
sediments, and sludges will take
approximately 3 to 5 years, and the
groundwater remediation will take about
30 years. The 30-year estimate was obtained
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by a computer model using the groundwater
flow rate and the contaminant concentrations
to calculate the time needed to achieve
drinking water standards. Although the
aquifer in question is not expected to be
used as a drinking water supply, the Agency
decided to consider it a potential supply
source. However, it ~s possible that the
drinking water standard may not be
attainable at this site. Consequently, the
ROD will require that the goals for
groundwater remediation be reevaluated every
5 to 10 years. Groundwater pumping and
treating will occur for at least 10 years,
if not the entire 30 years currently
projected.
It is most likely that groundwater treatment
and excavation of soils will begin
simultaneously, although it will be easier
to design the pumping and treating scheme
than to bring in and setup the incinerator.
'When the two treatment systems are
operational, a dramatic lowering of
contaminant concentrations will probably
occur. The overall project schedule will be
affected by the volume of materials to be
excavated and by the number of groundwater
zones to be pumped.
Several officials wanted to know how EPA is going to
establish the extent of the cleanup and whether this would
be determined before or after the Record of Decision (ROD).
4.
EPA Re5conse:
The exact extent of the cleanup has not yet
been defined. However, the easiest way to
establish cleanup limits would be to set
them according to the physical boundary of
the site. It would be more difficult to
est~blish cleanup limits according to
specific chemical compounds which would
necessitate further laboratory testing.
It will be difficult to determine where to
stop excavating at the Drake Chemical Site,
unless a physical limit is set. Knowing the
history of the entire vicinity, many things
occurred over the last 50 years that could
contribute to contamination, but there is a
point where continuing to excavate soi15
5
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will cause more damage than good. Also~ it
is not the intent of this project to keep
expanding indefinitely. To whatever extent
possible, specific chemical cleanup
standards will be tied to the physical
limits of the site boundary. At this time,
EPA is proposing to excavate the entire
12~5-acre site down to the water table at a
depth of 12.5 feet. This represents 240,000
cubic yards of soil.
(An official supported the
physical limit, saying that
city's interest, as well as
see an end to this project.)
Several questions were asked about the type of fuel that
will be used to power the incinerator, the volume of ash
compared to that of the soils incinerated, and whether
metals in the ash, or air emissions from the incineration
process, presented risks. .
5.
EPA ReSDonse:
imposing of a
it was in the
the EPA's, to
Because soils do not burn easily, fuel with
a high BTU must be used. This fuel will
most likely be natural gas which is
available at the site. There will not be a
dramatic reduction in volume as a result of
soil incineration; the ash will represent
approximately 80' to 95' of the soil volume.
There will be some metals in the ash.
However, the specific metals that would
constitute a hazard are not significant at
this site. Cadmium and chromium are present
but not in high concentrations. The ash
will be tested, and if metals do present a
problem, the ash may have to be solidified
to prevent the metals from leaching back
into the groundwater. Organics are the main
concern, and they will definitely be
destroyed by incineration.
Air emissions f~om the incinerator are not
likely to pose a threat to human health or
the environment. . The incinerator unit will
be equipped with scrubbers that will capture
particulates in the smoke. Those
particulates will then become part of the
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residue that will be disposed. The
incinerator used at the site will have to
meet the same standards that any other
incinerator must meet -- 99.99' of all
Superfund-list contaminants will be
captured.
Officials wanted to know whether the State is in agreement
with EPA regarding the preferred remedial alternatives and
what the State's funding obligation will be, particularly
regarding the lengthy groundwater remediation.
6.
EPA ReSDonse:
EPAhas a preliminary indication from the
State that the EPA's preferred alternatives
are the options the State would recommend,
also. However, the State may not see the
need to excavate the entire site and may
prefer instead to decrease soil volumes and
thus decrease costs. Looking at a list of
site-related contaminants, the State finds
that the highest concentrations of each of
the contaminants are found in certain areas
that comprise a much sm~ller area than
12.5 acres. The health-risk figures will
have to be reevaluated to determine whether
the scope of the excavation can be reduced.
EPA and the State will share the cost of the
initial remedial work, including soils
excavation, extraction well installation,
and groundwater treatment facility
construction, on a 90/10 basis. The Federal
government would also assume 90' of the
first 10 years of operation and maintenance
costs, while the State would again assume
10'. During the remainder of the remedial
effort, the State would assume 100' of
operation and maintenance expenses.
Operation and maintenance for 20 more years
represents an additional $1 million the
State will be required obligate.
Two officials asked what would happen if cleanup criteria
changed during" the course of the long-term remedial program
or if hot spots are discovere& on or off the site during
the cleanup period?
7.
EPA ReSDonse:
Even if cleanup criteria change, EPA's goal
will still be to meet a drinking water
standard. EPA may find, after 10 years,
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that the kind of contaminant reduction
anticipated is not occurrinq and that a
drinkinq water standard may not be
attainable. This will have to be evaluated
over ti8e.
If hot spots are discovered within the site
area, &PA will probably have the
flexibility to address them, particularly if
chemical standards are established. It
probably will not be possible to attempt to
. remove a hot spot a mile or two offsite as
part of this site remediation, however.
An official wanted information about the depth of the
aquifer, whether bedrock or soils in the aquifer were
contaminated, and whether the soils in the aquifer were
sampled.
8.
EPA ReSDonse:
The aquifer extends to bedr~ck which is at a
depth of about 90 feet in most locations.
Excavation will not be below 12.5 feet, and
althouqh there are contaminated soils in the
aquifer, most of the contaminants are in the
upper portion of the aquifer. Bedrock is
not a problem, and it won't be necessary to
pump qroundwater from the bedrock.
EPA has taken soil samples from the wells.
When qroundwater is sampled, filtered and
unfiltered samples are collected. When the
samples are filtered, the sediments separate
and are analyzed, just as the water is
analyzed.
One official inquired how the site would be affected if a
flood occurs before the City of Lock Haven builds the
200-year levy system it is planninq. (A 200-year levy is
one capable of withstandinq a flood of a maqnitude that
statistically should not occur more than once in 200
years.)
9.
EPA ReSDonse:
EPA reaedial plans call for a dike to be
constructed around the onsite incineration
facility and around the onsite qroundwater
treatment plant sufficient to protect them
aqainst a 100-year flood. If the city's
200-year levy is constructed before the
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10.
11.
12.
13.
4.0
onsite treatment facilities are built, EPA
will qain some flexibility in its planninq,
but the EPA's remedial cost estimates
assumed that 100-year dikes will be
installed around the treatment facilities.
(The official requested the estimated costs
for buildinq the onsite dikes. EPA
forwarded the information in a letter on
September 19, 1988).
An official inquired about the possibility that the
lonq-term soil remediation work will create jobs for local
residents.
EPA Resconse:
A larqe company that owns a mobile
incinerator will come in and will, most
likely, sub-contract the excavation work.
However, any contractors hired will have to
be certified under the Occupational Safety
and Health Act (OSHA) to work with hazardous
wastes.
Another official asked if the Phase III desiqn will be done
.
by the Corps of Enqineers Baltimore District?
EPA Resconse:
The desiqn will be done by the Corps' omaha
District and will be implemented by the
Baltimore District. Omaha will prepare the
bid specifications, and Baltimore will award
the contract.
An official asked how onsite utility lines will be handled
durinq the soils excavation.
That is somethinq that can't be answered at
this time. It will have to be addressed
durinq remedial desiqn.
Several officials remarked that the Phase III preferred
alternatives are a siqnificant improvement over earlier
proposals.
EPA Resconse:
OTDR COIfCBUS All]) RBSPOIfSBS
.
.
The followinq concerns and responses were presented durinq the
officials' briefinq, Septeaber 7, 1988:
1.
One official requested an update on Phase II work and an
explanation of why the removal of Buildinqs 1 and 2 was
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separated from the removal of other surface structures and
debris specified by the Phase II ROD. The official also asked
why this separation was not brought to public attention earlier.
EPA ResDonse:
The Phase II ROD, signed in 1986, specified
the removal of onsite buildings, lagoons,
and other scattered debris, and it was
determined that these things should be
removed before the final Phase III cleanup
is initiated. The Phase II removal is now
in progress and is occurring under a new
Superfund initiative that requires the
removal program and the remedial program to
work together more closely than required
previously. The Drake Chemical site is the
first National Priorities List site in
Region III at which EPA's expanded authority
under SARA (Superfund Amendment and
Reauthorization Act) has been utilized.
The removal of Buildings 1 and 2 was
separated from the removal of other surface
structures and debris because of the
relative complexity involved in removing
Buildings 1 and 2, and also because of the
contractual mechanisms of the removal and
remedial programs. Contractors hired under
the removal contract are paid on a
time-and-materials basis, whereas
contractors for the remedial program are
hired at a fixed price. When a project is
complicated, it is generally to the Agency's
advantage to have a fixed-price contract.
The separation of the Phase II removal tasks
was not called out at the time the ROD was
signed because EPA had not yet considered
doing it that way. The goals of the ROD and
the work involved remain the same, although
the approach to the work is a bit different.
Removal actions are limited by statute to $2
million dollars and a 1-year duration. At
Drake, one exemption to the statute was
granted, but Regfon III did not have all of
the requested funds in its 1988 budget.
Currently, consideration is being given to
expanding the removal contractor's scope of
work to include Buildings 1 and 2. This
will require another exemption and
authorization of additional funds.
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A number of officials commented that if Buildings 1 and 2
remain on site, the public will not believe that
remediation of the site has occurred. These officials
believe that it is in everyone's best interest to see that
the buildings are included in the current removal action
and said that it is important to them to get public
recognition for the work that has been done.
2.
EPA ResDonse:
EPA agrees that the public will not perceive
that the work has been accomplished if
Buildings 1 and 2 stand, and their removal
during the current activities is being
considered.
Several questions were asked regarding work occurring at
the adjacent AC&C site which is currently undergoing a RCRA
(Resource Conservation and Recovery Act) cleanup.
Officials wondered it the AC&C and Drake remedial plans
were similar and whether AC&C's plans call for incinerating
soils to the extent that soils will be incinerated at the
Drake Chemical site. An official suggested that, if the
remedial plans are similar, the two sites might be able to
cooperate on the development of treatment facilities. ,
3.
EPA ReSDonse:
Both AC&C and the Drake Chemical site will
use activated carbon to remove organics from
the groundwater. The AC&C groundwater
treatment system will have a settling basin,
but the groundwater treatment system at
Drake will have other pretreatment steps
that will precipitate metals in the
groundwater and then remove organics.
Hammermill and AC&C are both located
upgradient of Drake and some residual
groundwater flow may be occurring. However,
with AC&C treating groundwater on one side
of the fence, under the State's RCRA
program, and EPA treating groundwater on the
other, an effective groundwater remediation
should occur. EPA and the state will
cooperate closely to be sure that all the
contaminated groundwater is being captured.
AC&C anticipates beginning its groundwater
pumping and treating operation in
Fall 1988. Pumping and treating at Drake
will probably not begin for about 2 years,
but there will probably be some overlap in
the two programs.
AC&C will not be initiating a soil
incineration plan like the Drake Chemical
Site incineration plan. Most of the soils
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trom AC&C were already excavated and removed
to an offsite landtill. What remains is
more ot a sludge material that can be
converted into a liquid slurry and run
through a carbon adsorption process. What
is present at the Drake Chemical site is a
mixture that resulted from sludge being
continually covered with soil tor the past
20 years.
5.0
REMAINING CONCERNS
Concerns not conclusively addressed during the comment period
include the aforementioned issues:
1.
Using Superfund monies to expand the municipal sewage
plant, instead ot building an onsite groundwater treatment
plant.
The need tor change in the tinal disposition ot remediated
Supertund sites, so that they could be returned to the
local tax base without the municipalities involved ~avinq
to purchase them trom the bankruptcy estates.
2.
3.
The need tor a change in Supertund legislation that would
protect purchasers of remediated Superfund sites trom
liability should historic problems re-emerqe.
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ATTACBKBHT
COMMmfITY RELATIONS ACTIVITIBS AT 'l'KB DRAD CDHICAL SITB
Community relations activities conducted to date:
o
EPA held a p~blic meetinq, in September 1982, ~o discuss
Superfund and the EPA emerqency action at the site.
Approximately 30 people attended.
EPA established local information repositories in 1982.
o
o
EPA held a public meetinq, in January 1983., to discuss the
Remedial Investiqation (RI) and the Remedial Action Master
Plan (RAMP). .
o
EPA, PADER, NIOSH, and CDC held a public meetinq, in
May 1983, to discuss health issues related to contaminants
associated with the site. At the meetinq EPA presented a
slide show coverinq proposed RI/FS activities, and NIOSH
discussed the bladder-cancer risk associated with
beta-naphthylamine .Cfenac) exposure. The meetinq was
attended by 250 former Drake employees and local residents.
EPA, PADER, NIOSH, and CDC held a second meetinq, in
May 1983, to discuss health issues associated with the
site. Media coveraqe was extensive and included a spot on
the nationally televised CBS Morninq News.
o
o
EPA distributed a fact sheet addressinq public concerns
raised at the May 1983 meetinqs.
EPA held a public meetinq, in late 1984, to discuss the
Phase I RI/FS.
o
o
EPA held a public meetinq, in e~rly 1986, to discuss the
Phase II RI/FS.
EPA held a public meetinq, in September 1987, to discuss
the status of Phase II work and the Phase III Work Plan. A
fact sheet was prepared and distributed at the meetinq.
o
o
EPA held a public meetinq, in September 1988, to discuss
the Phase III FS and Proposed P~an. Copies of the Proposed
Plan were prepared and distributed at the meetinq.
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ORIGINAL
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IN RE:
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DRAKE CHEMICAL
: COUNTY OF CLINTON,
: PENNSYLVANIA
SUPERFUND SITE
.
.
TRANSCRIPT OF PROCEEDINGS
EPA PUBLIC MEETING
BEFORE:
RAYMOND P. GERMANN, JR., PUBLIC
INFORMATION SPECIALIST
EDWARD M. POWELL, ENVIRONMENTAL
ENGINEER
ROY SCHROCK, REMEDIAL PROJECT
MANAGER
DATE:
SEPTEMBER 7, 1988, 7:00 P.M.
PLACE:
ULMER PLANETARIUM
LOCK HAVEN UNIVERSITY
LOCK HAVEN, PENNSYLVANIA
.
.
MAUREEN L. PRITCHARD, RPR
NOTARY PUBLIC
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MR. GERMANN:
My name is Ray Germann, and I
2
work for the Environmental Protection Agency, and as most
of you know, we are here to discuss the Drake Chemical
3
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Superfund Site right down the road, and the ongoing
5
cleanup of that site.
And with me to my right is Roy
6
~chrock, he is the Remedial Project Manager and will be
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doing most of the presentation here tonight.
And Marty
Powell, who is out at the site right now supervising work
that is going on at this time, is here to answer any
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questions you might have regarding that work.
11
I am just going to briefly summarize how we
12
have gotten to this point in the project, what we have
13
done in the past, and what we are doing right now.
And
14
then Roy is going to do the bulk of the presentation
15
concerning. this particular part of the project that we
16
are here to discuss tonight.
17
The EPA and the State Government got
involved in this site way back in the early 1980s when
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the plant closed down. There was some emergency action
taken there because of an immediate threat that was
ID
21
presented by the site.
And shortly thereafter, we
.
22
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started the process, long term type process, toward a
future permanent cleanup, and we are getting closer and
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closer to that permanent cleanup as the years go on.
25
We have basically broken the project down
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ID
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into three phases.
The first phase had to do with a
2
leachate stream which started at the site and ran down
3
through nearby Castanea Township Park and off. into Bald
Eagle Creek, which is a quarter mile or so from the site.
4
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About a year or so ago, we completed a project where
portions of that stream were excavated, other portions
7
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were covered to make sure that the contaminated
groundwater and the contaminated water from that site
9
that was comprised in that stream wasn't available for
public exposure, so that the public wouldn't come into
11
contact with it.
That was Phase I, and we finished that
12
about a year ago.
A couple years ago, we made a final
decision as to what Phase II was going to consist of.
And essentially, that is the buildings on site, the
lagoons, and other surface debris that you see scattered
17
throughout the site if you look at it from any elevated
18
point.
We made a decision to clear all that out before
19
we went for the final solution, which we are here to talk
about tonight.
21
Marty Powell, the on-scene coordinat~r,
.
.
is
22
in charge of running that Phase II, which is going on
right now" and clearing out that debris, knocking down
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the buildings, getting rid of basically all that surface
25
mess you see out there.
We are hoping for that to be
GEIGER 81 LORIA REPORTING SERVICE. INC.. 1000 MARKET ST.. HaG. PA 17101 717.23~.2109 PA 1.800.222.GLRS
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completed sometime at the end of this year, early next
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year.
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That brings us to Phase III, which is
4
undoubtedly going to be the most time consuming portion
5
of the project.
It has to do with cleaning several
6
thousand cubic yards of contaminated soil at the site and
7
the contaminated groundwater beneath the site.
We are
8
projecting that the initial construction for that Phase
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III is going to take several years by itself.
And then
10
the follow-up work, to clean the groundwater, which is
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probably going to be done through a process of pumping it
12
out, cleaning it, and treating it, could take anywhere
13
upward of ten years.
So we are not going to be finished
14
with the project anytime soon, by any means, but we are
15
reaching a point b~ initiating the very last phase.
And with that, I am going to let Roy go
16
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into a short discussion of what that last phase consists
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of.
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MR. SCHROCK:
The main thing that I want to
m
go over tonight is the pieces of paper over here, the
short document which we are calling the Proposed Plan,
21
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that is available in the repositories.
For anybody here
23
tonight who needs extra copies, we will certainly have
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more over here.
25
But what we are doing is basically
GEIGER a LORIA REPORnNG SERVICE. INC.. 1000 MARKET ST.. HIG. PA 17101 717.13...2101 PA 1-100.222.GLRS J
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informing the public and the local representatives of
2
what EPA is intending to do at the site.
We have now
3
completed our third phase of the study.
And what this
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was intended to do was address the soils and sludges
onsite, and the groundwater contam~nation onsite and
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around the site.
i
I don't know if many of you were here two
8
years ago, but we also looked at this whole option about
9
two years ago, and at that time we were looking more into
either containing it somehow -- I think the actual
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proposal was to lower the water table and put a cap on
it, and we met with pretty much resistance from all the
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local representatives and commissioners and things like
that, who felt it really wasn't a good solution.
15
Then we decided to think about maybe
16
putting in a landfill.
One option was onsite, one option
17
was offsite.
We really never came to a good agreement
18
between EPA and the State.
So what we really decided,
19
Superfund was reauthorized and required EPA to look into
:;n
much more permanent solutions, treatment technologies
21
that would take care of the problem.
And the least
22
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desirable option was to do some kind of landfilling.
So
23
that's sort of wha~ prompted us to go back and actually
redo our study and look into differe~t ways we might be
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able to treat and permanently take care of the site.
GEIGER 6 LORIA REPORTING SERVICE. INC.. 1000 MARKET ST.. HaG. PA 17101 717.;U..Z101 PA 1.800.ZZZ-GLRS .
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50 what we have done is prepared a whole
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new set of documents, the remedial investigation and
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feasibility study.
There is a total of seven volumes,
and they have sort of a bright blue cover, it sort of
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looks like this.
50 if you are ever going into one of
the libraries in town or the City .Hall or the county
courthouse, these are the kind of documents you will be
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looking for.
The most important pieces of those
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documents are the first volume of the remedial
o
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investigation and-the first volume of the feasibility
11
study-
But rather than requiring or expecting people to
12
read through hundreds and hundreds of pages, we have sort
of summarized it in this Proposed Plan so that somebody'
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can take a half hour and be able to understand what it is
15
we thought we were going to look at, and which one of
16
those options we were really going to suggest that we
17
implement.
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This meeting is mainly to present the
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ideas, we are calling this a Proposed Plan, and we do
intend to do this, but it isn't a final' decision yet,
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this is still part of the comment period, and I just want
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to draw your attention a little closer to what we have
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presented and the ideas we have looked at-
As I said, the purpose of this second Phase
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III study, looking at the soils and sludges, was to try I
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and see if we could determine if there were any hot spots
that we might be able to limit the treatment to the
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certain area of the site which would give us the best
cleanup without having to deal with the entire site.
50
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what we did is we laid a grid out over the site, pretty
much like this drawing would show here (Pointing.)
There
7
8
are some buildings there, so the points underneath the
buildings we couldn't look at, but we did with a backhoe
9
dig trenches at each of these locations, and we took
three different samples within the trench to try and get
11
an idea, is there a different chemistry on the surface or
12
in the middle or at the bottom part, as well as looking
over the entire site," whether there were sections that
were much different, or if they were all the same,
basically looking for the hot spots that we might be able
to limit the amount of soil that needed to be treated.
17
And what we found, unfortunately, is that
18
we do have contamination throughout the entire site.
I
19
will admit that there are areas where the chemicals that
21
we are looking for are in" higher concentrations generally
below the two surface lagooqs where they used to deposit
22
.
a lot of their sludges and soils in this area, and have a
higher level when we look at the comparison of actual
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numbers.
But we also looked at it statistically and felt
25
that there really was not a significant difference
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between any of the locations on site.
2
50 unfortunately, that has led EPA back to
3
. the position where we are looking at cleaning ,up the
entire site, including about twelve and a half acres, and
4
5
actually looking at the soil that is contaminated, down
to the water table, which is also .about twelve and a half
6
7
8
feet.
50 what that sort 6f boils down to is that we are
now thinking about treatment for 240 thousand cubic yards
9
of material.
That's quite a bit of material.
50 a
10
permanent solution is going to take quite a bit of work
11
and quite a bit of money to implement.
12
The purpose of the feasibility study, which
13
is the second set of documents, is to look at different
14
treatment te~hnologies, to see if we might be able to
come up with different ideas how we ,could treat it, make
15
16
it a permanently clean site, as well as get an idea of
17
what the cost estimates would be for each of those
18
different kind of alternatives.
And in this proposed
19
plan, on page seven, we actually have listed all of the
~
different options we have looked at.
We did break it
21
down into two components, the soil/sludges and sediments
22
.
as Operable Unit A, and the groundwater as a separate
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operable unit.
24
I will begin with the soil and sludges and
just briefly go over some of the alternatives we looked
25
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at.
2
Option number one is no action with
3
monitoring.
It is required for any of thes~ feasibility
4
studies to really take a good look at what will happen if
5
you do nothing.
Sometimes that could be a selective
6
alternative.
At.this site, however, knowing the history
7
of what we have found before, what we have proposed
8
before, we never really expected to choose a no action
9
alternative.
So the second alternative became the one we
10
really were lookinq at, and then comparing some of the
11
other alternatives to that.
12
And the first one would be excavating the
13
entire site for 240 thousand cubic yards and using a
14
rotary kiln incinerator to burn materials which would get
rid of the organic materials, those which are above the
15
16
health risk levels, those which are carcinogens of
concern, and the burning off would eventually get rid of
17
18
all that.
We would eventually be left with 'an ash type
19
material which we would expect to be able to put back on
~
the site.
So that would require backfilling, covering
21
over the ash material, regrading, and planting some kind
22
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of cover on the revegetation.
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The cost for this option was about $88
24
million.
We have contacted some private companies which
25
are building mobile incinerators, and we have based our
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cost estimates on what they give us.
Again, this is
2
something two years ago we really didn't have the option
to look at mobile incinerators as closely as we did this
3
4
time, because they just really hadn't built them yet.
5
Bringing the incinerator on site will
6
significantly save money, because transportation to an
7
offsite facility is really the most expensive portion of
8
an offsite option.
9
The second option we looked at closely,
number three on this list, would be incineration for
10
11
using a different kind of incinerator called infrared.
12
Again, it would basically do the same thing, burn the
13
materials, getting rid of the organic materials, and
14
leaving us with an ash, which we could backfill.
And the
15
price for this option was about $168 million.
16
The fourth one on this list was a
17
treatment called in-situ vitrification.
This is a
18
process where we would be using basically electrodes in
19
the ground, putting through high volumes of electricity
~
currents, that would actually melt the material and form
21
almost a glass-like substance that we would actually be
22
.
able to leave in place. The organics would be contained
within the glass-like material, and t~at would prevent
ZJ
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anything further going into the groundwater table.
The fifth option on this list is an option
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which we looked at as a very different type of approach,
2
which we are calling soil washing.
What it entails is
3 '
pumping the contaminated groundwater out of the ground,
4
treating that so it becomes clean water, recirculating
that back on top of the contaminated soils, and letting
5
6
that .perco1ate down through, and in a sense we would be
flushing the soils, trying to extract all of the
7
8
contaminates that are placed within the soils and sludges
9
onsite.
The total cost for the in-situ
11
vitrification was about $118 million; and this fifth
option, the soil washing, was about $27 million.
However, the fifth option, the soil
washing, it can be considered something that will
actually reduce the toxicity of materials onsite.
But it
very well may not be what I would call a permanent
solution, because it would take an extremely long ti~e to
be able to flush out the materials.
We are finding that
some contaminates are mobile and'will leave the soil more
readily than others.
One of the ones we are most
concerned about here 'are the color die compounds, which
.
are very large molecules, and would tend to be the last
materials to be flushed out of the system.
Before I go on to Operable Unit B, I want
to interject here that EPA has decided on a preferred
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alternative, and that would be for the onsite rotary kiln
2
incineration.
If we were to do that, the treatment
3
facility would actually be placed on the site, and the
4
excavation would occur within the fenced in boundaries
5
where we have the site, up to Myrtle Street, along the
railroad tracks, and then we would process the materials
6
7
8
through the incinerator, onsite, and then the ash would
be tested when we are done to see if there are any metals
9
which may be left in the ash -- the metals would not be
burned up -- and ~hose ash materials may have to be
10
11
solidified if we find a high metal content before we can
12
place it back onsite.
But in any rate, the idea would
13
to be to make sure that nothing would be leaching out
14
from it that are in concentrations that would affect the
15
groundwater, and ultimately, affect Bald Eagle Creek.
Are there any questions about that piece of
16
17
the discussion so far, Operable Unit A, on the soils and
18
sediment?
19
MR. ARDNER:
Which plan are you favoring?
ID
MR. SCHROCK:
We are favoring option number
21
two, which is labeled as A-l~ excavation all sludges/
22
.
soils/sediments: treating with rotary kiln incineration.
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Again, this is just the comment period.
I
24
want to make you feel comfortable that this is the time
and the place to be able to think about this option, and
25
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either make your comments at this meeting, or you could
2
write to EPA.
There is addresses at the end of this
3
But let us know what your feelings .are.
document.
Maybe
4
there is another option you feel should be looked at, or
5
6
maybe you would agree and support this alternative.
. The second Operable 'Unit is for the
7
groundwater cleanup.
Again, we had to look at a no
8
action with monitoring, but the basic idea here is that
9
EPA will consider that the groundwater table that is at
this site could possibly be used in the future if needed
10
11
for some kind of drinking water source.
It certainly
12
could not be used at this time because of level of
13
contamination in the groundwater, but knowing that we are
14
going to consider it a potential source really requires
EPA to look at doing some kind of a cleanup to the
15
16
groundwater at the site.
50 we have introduced several
17
different technologies which can be used for groundwater
18
treatment.
19
The thing I want to go over right now
:!)
doesn't change the alternatives, but it does change the
21
scope of the work which we ~ight be doing.
What we have
22
.
done is, we have divided the groundwater into three
Z3
different zones.
Zone 1, being right underneath the
24
Drake site, and by far that's where the highest
25
concentrations of the contaminates are found.
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Zone 2 goes from the border of the Drake
2
site up to Route 220.
And in this area we are finding
3
concentrations that are above protective EPA standards
4
that we have looked at to determine what kind of cleanup
5
6
goals we would want to reach.
And we definitely have
contamination in there which the agency would be looking
at for pumping and treating.
7
8
The third zone is outside Route 220 going
9
towards Bald Eagle Creek.
We do have one contaminate
10
that shows up in that area which is above EPA protectiv~
levels, therefore, we are considering the possibility of
11
12
pumping and treating in that zone.
And the way the
13
feasibility study has looked at it is crossing out each
14
of the three zones.
15
Overall, the different kind of treatment
16
technologies range somewhere between nine and fifteen
million, and we have looked at the different ones that we
17
18
have.
And the agency has decided that what we are
19
calling Operable Unit B, number 3, the RRA-4, the
ID
extraction wells, building a treatment plant, which would
use biological activated carbon as the primary treatment
21
22
,
to get rid of the organic materials in the groundwater.
23
The reason we chose this one is, one, because it is an
24
older proven technology, and it also has the ability that
we could add onto the system should we either find we
25
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need additional treatment to be able to clean up the
water to the goals that we are going to set, or if we
find that we are actually going to be pumping more water
than we expected, it has the ability to expand, and it is
also a proven technology which has been used for quite a .
while.
Some of the other ones are using relatively
new ideas with sand filtration and ozone/ultra violet
kind of treatments to get rid of the organics.
But
again, the agency is proposing to go with the third
alternative shown here, which is RRA-4, the Biological
Activated Carbon.
The price for this option when we are
looking at just Zones land 2 is about nine million, and
to include Zone 3 would be several hundred thousand
dollars more, not a significant increase.
At this point, we-are thinking we would
like to only pump and treat within Zones land 2, because
we feel Zone 3 will eventually move into Bald Eagle Creek
and that the concentrations will decrease in Zone 3.
What reaches Bald Eagle Creek would not be of any
.
concentrations which would affect the fish wildlife in
the creek, and would eventually clean itself, and that
problem would be solved.
The remaining zones, Zone 1 and Zone 2, we
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feel would have a much longer term pump and treat program
before we could reach the goals which would basically be
a drinking water standard, trying to clean up the water
so that some day it possibly could be used as a"drinking
water supply should it be needed.
One thing I didn't mention that I should do
now is that our time frames, I would hope to be able to
do both Operable Unit A and B within the same time frame,
I would not wait on one before, I started the other.
The
incineration onsite would take between three and five
years.
The groundwater pumping and treating program
would probably take twenty-five to thiry years, based on
the goals that we have set for cleanup.
The only other thing I would like to
mention is that again, we are still in the selecting
process here, and once we have made a decision, this is
only a conceptual idea, there is bound to be a number of
details which we have not addressed in this plan, which
we will have to address, and we will go into what we call
a design stage.
In that design stage we would probably
even make some test ferns to make sure that the
""
incinerators will accept the material.
I know we are
going to run into boulders and tree stumps and brick
walls and things like that.
There is going to be some
process difficulties in actually getting it into an
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incinerator, figuring out how to mix the burning material
with the soils that we are going to be putting in, and
2
3
then also testing the product, the ash, when we are done,
4
to see what kind of metal content that has.
That may, as
5
6
I said before, require us to do some kind of
solidification, so that the metalg that are left would
not ieach out into the groundwater table.
7
8
As we go further through the document,
9
there are some flow charts that sort of describe what a
10
rotary kiln incinerator is made of.
It certainly doesn't
11
give us a picture of it, but it shows some of the steps
12
that we would go through.
And also the same is true for
13
the water treatment facility.
We would be looking at
14
component parts,
each with their own specific area of
15
pretreatment, elimination of organics, and the polishing
16
step at the end.
One thing the agency has not decided
17
18
completely, we looked at two different options.
We may
19
be able to discharge and do the final polishing step of
~
any water we treated to the local sewage treatment plant,
21
or we could build the polishing step as part of our
22
.
treatment plant, and then meet the MPDES, or the state
Z3
requirements, for discharge into Bald Eagle Creek.
So
24
that is a piece yet we still have to. decide.
I am going
25
to be working with the local officials, and also, with
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our engineers who will be doing the design specifications
to work out the details on how that would actually look.
And then beyond that there is a.glossary
which goes over a lot of the terms.
I know this program
has a whole lot of acronyms, and I have pro~ably used
some of those that you may not be ,familiar with, but this
should help anyone who is trying to read the proposed
plan, just to get a better idea on what some of these
different technologies might look like, or what the terms
.
would mean as far as EPA and DER are concerned.
Other than that, I really don't have too
much more to say.
Like I say, the proposed plan is a
document by itself.
You can take more time to look at it
and feel free to write to us or raise any questions that
you might have at this time.
MR. HOBERMAN:
I am Al Hoberman, Lock Haven
City Counsel.
And most people know we met today with.
some of the elected city officials of EPA.
And as part
of the record today, I would like to encourge you to look
seriously at working with the sewage treatment plant in
the city of Lock Haven, peraaps adding to the plan as
.
part of this, to treat this water.
And we would get a
long term benefit to all of the citizens so that at the
end of the project we wouldn't have a plant you tore
down.
And if you just pumped a hundred
thousand gallons
\0.
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a day of basically low BOD water into the plant, all the
problems we get would not have any benefits at the end of
the treatment process.
So I would encourge you to consider in this
planning process the addition of passing the Lock Haven
plant, and have something permanent left after the
project is done.
MR. SCHROCK:
Since we do have Marty Powell
here for what we are calling Phase II, demolition of the
buildings, I also want to open up the floor for any
questions on that part of our work, if you are curious
about what he is doing down there, we have the
opportunity to ask Marty.
(No response.)
MR. SCHROCK:
The only other thing I can
think to mention is that we do have copies of the reports
in both libraries in town, the one across the s~reet and
the Lock Haven Library, there is one at City Hall, and
there is also one at the county courthouse in the
Commissioners' Office.
There is a separate document --
actually it is a set of documents called the
.
administrative record, and that includes all previous
studies that. we have done, starting back in the early
'80s.
And I did, just today, put a full set of the
administrative records at City Hall with an index and
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all.
If anybody really wants to get the complete
2
picture, the stack of papers is about as long as this
table, but I just want to let you know it is available at
3
4
City Hall that if somebody should want to go through that
5
6
much detail, it is there.
MR. ARDNER:
Roy, what is the shut off date
7
8
for comments on Phase II?
MR. SCHROCK:
I think it is the 28, I am
9
pretty sure.
We would like to make a decision sometime
10
before the end of this month.
So the earlier you can get
11
your comments, the better it would be for us to includQ
them and respond to them.
12
13
If there is really no further comm~nts,
14
. that's all I really came to say, we are going to be here
for a few minutes if you have any other kind of
15
16
questions.
Thanks for coming.
(The meeting was concluded at 7:30 p.m.)"
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I hereby certify that the proceedings and
evidence are contained fully and accurately in the notes
2
3
taken by me on the within proceedings, and that this copy
4
is a correct transcript of same.
5
6
7
8
My commission expires
September 19, 1988
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LAWYER'S NOTES
Pale Line
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f)RAKE Oif101ICAL SITE
AC'MINISTRATIVE RECORD* **
INDEX OF rx:x::t.JMENrs
SITE IDENI'IFICATION
Pre1Lminary Assessment and Site Inspection Reports
1)
Potential Hazardous Waste Site Identification and Preliminary Assessment,
6/13/80. P. 1-4.
2)
Marorandum to Mr. Jeffrey Haas, U.S. EPA, fran Mr. . Duane A. Wilding,
U.S. EPA, re: Trip RepOrt of Drake Chemicals International, Inc.,
6/18/80. P. 5-12. T\roO site maps and a Potential Hazardous Waste Site
Identification and Pre1Lminary Assessment are attached.
3)
Potential Hazardous Waste Site Inspection Report, 8/4/80. P. 13-32.
The following are attached:
a) a Daily SUlTl'l\ary sheet fran Eco1cgy and Environment, Inc.:
b) a Sl..mnary of Action:
c) three site maps:
d) a Drum Inventory of Drake Chemical, Inc.:
e) three U.S. EPA Chain of Custody forms:
f) a letter rEr;1arding sanple data Sl..lrTrnary sheets.
Hazard Ranking Score Reports
1)
2)
Hazard Ranking ~ystem, 4/30/82.
P. 1-16.
Recort;: Hazard Rankinq System Model of Drake Chemical, prepared by Eco1cgy and .
Environment, Inc., 7/20/82. P. 17-37.
3)
Appendix E Model Worksheets, (undated).
P. 38-48.
Disposition/National Priorities List Rankinq
1)
Tentative Disposition, 4/9/81.
P. 1-1.
* Administrative Record available 8/31/88.
** Supporting Samplinq Data is stored at the Region III Central Regional
Laboratory in Annapolis, Maryland.
Note:
Canpany or organizational affiliation is identified in the index only
When it appears in the record.
1.
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10)
REMEDIAL RESPCNSE PLANNING
Work Plans
1)
ReJX>rt:
12/9/82.
Remedial Action Master Plan, prepared by Roy F. Weston, Inc.,
P. 1-84.
2)
Report: Work Plan, Remedial Investigation/Feasibility Study of Alternatives,
. Drake Chemical, Lock Haven, Clinton County, Pennsylvania, preoared by NUS
Corporation, 5/83. P. 85-195.
Remedial Investiqation/Feasibility Study Reports
1)
PeJX>rt: Remedial !nvestiaation ~eoort (Phase I), Leachate Stream Area, Drake
Chemical Site, Lock Haven, Clinton County, Pennsylvania, prepared by NUS
Corporation, 3/84. P. 1-242. References are listed on P. 171-176.
2)
RepOrt: Re!Tledial Investiqation Reoort (Phase I), Leachate Strean Area,
Volume II, Appendices, Drake Chemical Site, Lock Haven, Clinton County,
Pennsylvania, prepared by NUS Corporation" 7/84. P. 243-344.
RepOrt: l:'easibility' StudV' (Phase II), Leachate Stream Area, Drake Chemical,
Inc., Site, Lock Haven, Clinton County, Pennsylvania, prepared by NUS
Corporation, 7/84. P. 345-461. Tw::> transmittal letters are attached.
3)
4}
RepOrt: Remedial Investiqation Report (Phase II), Drake Chemical Site,
Lock Haven, Clinton County, Pennsylvania, prepared by NUS Corporation,
1/85. P. 462-595.
5)
RepOrt: Feasibility Study of Remedial Alternatives (Phase II), Drake
Chemical Site, Lock Haven, Clinton County, Pennsylvania, prepared by
NUS Corporation, 5/85. P. 596-801.
6)
Report: Feasibility Study of Remedial Alternatives (Phase II), Drake
Chemical Site, Lock Haven, Clinton County, Pennsylvania, prepared by
NUS Corporation, 8/85. P. 802-944.
7)
RepOrt: Feasihility Study of Remedial Alternatives (Phase II), Buildings
and Contaminated Structures, Drake Chemical Site, Lock Haven, Pennsylvania,
prepared by NUS Corporation, 3/86. P. 945-1071. A fact sheet 00 the
Proposed Remedial Alternatives is attached.
8)
ReJX>rt: Feasibility Study of Remedial Alternatives (Phase III), SludJe,
Soil, and GroundW!ter, Drake Chemical S'te, Lock Haven, Clintoo Count ,
Pennsylvarna, prepared by NUS Corporatidn, 8 86. P. 1072-1221.
RepOrt: Feasibility Study of Remedial Alternatives (Phase III), Sluckle,
Soil, and Ground'oeter, Appendices, Drake Chemical Site, Lock Haven, Clinton
County Pennsylvania, prepared by NUS Corporatioo, 8/86. P. 1222-1414.
9)
Report: Draft Feasibility Study ReJX>rt Phase IlIA [sic], Volume II, Appendices,
Ooerable Unit A and B, Drake Chemical Site, Lock Haven, Pennsylvania,
preoared by NUS Corporation, 7/18/88. P. 1415-1607.
2
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11)
Report: Final Phase III Remedial Investiqation, Volume I - Narrative,
Drake Chemical Site, Lock Haven, Pennsylvania, prepared by NUS Corporation,
8/88. P. 1608-1784. References are listed on p. 1782-1784.
RepOrt: Final Phase III Remedial Investigation, Volume II - Appendix A,
Drake Chemical Site, Lock Haven, Pennsylvania, prepared by NUS Corporation,
8/88. P. 1785-1826.
12)
13)
Report: Final Phase III Remedial Investiqation, Volume III - Appendices
S, C, D, E, F', and G, Drake Chemical Site, Lock Haven, Pennsylvania,
prenared by NUS Co~ration, 8/88. P. 1827-2181.
Re'port: Final Phase III Remedial Investiqation, Voll.lt1e IV, Acpendices
H-1 throLQh H-4, Drake Chemical Site, Lock Haven, Pennsylvania, prepared
by NUS Corporation, 8/88. P. 2182-2481.
14)
15)
Report: Final Phase III Remedial Investigation, Volume V, Appendices
H-5 thrOl.Qh H-8, Drake Chemical Site, Lock Haven, Pennsylvania, prepared by
NUS Corporation, 8/88. P. 2482-2747.
16)
Report: Draft Feasibility Study Report, Phase IlIA, Volt.me I, Narrative,
Operable Units A and a, Drake Chemical Site, Lock Haven, Pennsylvania,
prepared by NUS Corporation, 8/9/88. P. 2748-3005. A transmittal letter
is attached. References are listed on P. 3004-3005.
Correscondence and SUpPOrting Documentation
1)
Letter to Mr. WilliCltl Hagel, U.S. EPA, fran Mr. Richard Ninesteel, NUS.
Corporation, re: Transmittal of Dioxin Analytical Data, 2/24/84.
P. 1-141. The analytical data is attached.
Record of Decision/Enforcement Decision Document
1)
Record of Decision, Phase t - Remedial Alternative Selection, 9/30/84.
P. l-3~.
2)
Record of Decision, Phase II - Remedial Alternative Selection, 4/86.
P. 39-71.
3
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EMERGENCY REMOVAL RESPONSE PROJECTS
Operational Documents
1)
PolRep 13: CERCLA Removal Project, Drake Chemical Co., Lock Haven, PA,
3/3/82. P. 1-3.
2)
PolRep #4: . CERCLA Removal Project, Drake Chemical Co., Lock Haven, PA,
3/3/82. P. 4-7.~
3)
PolRep #5: CERCLA Removal Project, Drake Chemical Co., Lock Haven, PA,
3/5/82. P. 8-10.
4)
PolRep #6: CERCLA Removal Project, Drake Chemical Co., Lock Haven, PA,
3/6/82. P. 11-12.
5) PolRep #7: CERCLA Removal Project, Drake Chemical Co., Lock Haven, PA,
3/8/82. P. 13-13.
6) PolRep 119: CERCLA R~moval Proj~ct, Drake Chemical Co., Lock Haven, PA,
3/9/82. P. 14-16.
7)
Report: Safety Plan, prepared by Mr. Jack M. Peterson [sicl, 11/12/84.
P. 17-43.
8)
PolRep II: Drake Chemical Site, Lock Haven, PA, Emergency Removal Action,
9/2/86. P. 44-44.
9) PolRep 112: Drake Chemical Site, Lock Haven, PA, Emergency Removal Action,
9/3/86. P. 45-45.
10) PolRep /13: Drake Chemical Site, Lock Haven, PA, Emergency Removal Site,
9/4/86. P. 46-46.
11)
12 )
13)
14 )
15)
16)
Site/Safety Protocol, 9/4/86.
P. 47-57.
PolRep #4: Drake Chemical Site, Lock Haven, PA, Emergency Removal Site,
9/5/86. P. 58-58.
PolRep 15: Drake Cheacial Site, Lock Haven, PA, CERCLA Emergency Removal,
9/19/86. P. 59-59.
Memorandua to Mr. Jack Downie, U.S. EPA, from Mr. Mike
Report, 9/22/86. P. 60-69. A building tocations map,
Site Inve.tigation and Emergency Response.Safety Plan,
the chemical transport equipment are attached.
Mazelon re: Trip
a Hazardous Waste
and photographs of
PolRep #6 (Final):
Drake Chemical Site, Lock Haven, PA, 10/6/86.
P. 70-70.
Memorandum to File from Mr. Jack L. Downie, U.S. EPA, re:
Bulletin A, 10/30/86. P. 71-73.
Special
4
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17)
Memorandum to Dr. J. Winston Porter, U.S. EPA, from Mr. James M. Seif,
U.S. EPA,re: Time extension request for CERCLA Immediate Removal,
(undated). P. 74-78. A memorandum regarding a request for exemption
from the six-month limitation is attached.
18) Fund Authorization Report, (undated).
P. 79-8~.
A fact sheet is attached.
5
~
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CCHofUNITY INVOLVDtENT
Community Relations Plans
1)
Report: Draft Carmunity Relations Plan, Drake Chemical Site, Lock Haven,
Pennsylvania, crepared by NUS Corporation, 6/83. P. 1-27.
Recort: Draft Camtunity Relations Plan, Drake Chemical Site, Lock Haven,
Pennsylvania, prepared by NUS Corporation, 9/85. P. 28-59.
2)
3)
Recort: Draft Camtunity Relations Plan, Drake Chemical Site, Lock Haven,
Pennsylvania, prepared by NUS Corporation, 1/86. P. 60-92.
4)
Recort: The Citizen's Guidance Manual for the Technical Assistance Grant
Prooram, prepared by u.S. EPA, 6/88. P. 93-411.
5)
6)
Statanent of Work for Camtunity Relations Plans, (undated).
P. 412-413.
Recort: Cammunity Relations Plan for et1ergency Action at the Drake Chemical
Site, Clinton County, PA (no author cited), (undated). P. 414-417.
7)
8)
Handwritten References - Drake CRP, (undated).
P. 418-422.
Statanent of Work - Implementation of Community Relations Plans, (undated).
P. 423-424.
Fact Sheets, Press Releases, Public NOtices
1)
2)
Fact Sheet:
Issues Raised at the Public Meeting, 9/6/84.
P. 1-1.
Fact Sheet: Drake Chemical Site, Lock Haven, Clinton County, Pennsylvania,
Sludge and Soil Alternatives, 9/9/86. P. 2-2.
3)
Fact Sheet: Preferred Alternative, (undated).
P. 3-4.
Meeting SLmnaries, Trip Reports, Correspondence with the Public
1)
2)
Slmnary of Remedial Investiqatioo and Feasibility Study, 5/83.
P. 1-5.
Plblic Meeting Agenda, 5/24/83.
P. 6-6.
3)
4)
Meeting Attendance List,.5/25/83.
P. 7-8.
ME!!tDrancbn to File fran Mr. Gil Meyer re:
6/6/83. P. 9-10. .
Drake Chemical Site Public Meeting,
5)
Merorandlm to File fran Mr. R. M. Ninestee1, NUS Corporation, re:
conference, 8/17/83. P. 11-11.
Press-
6) Work Assiqnment Cover Sheet, 12/84.
P. 12-12.
7)
8)
Pre-meeting Attendance List, 9/9/86.
P. 13-13.
Handwritten Meeting Attendance List, (undated). P. 14-14.
6
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9)
10)
File Inventory, (undated). P. 15-15.
CRI Planning - First and Second Quarter FY '85, (undated).
7
"
P.
16-16.
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GENERAL GUIOOl:E IXX:lMEm's *
1)
2)
"Pranulgatioo of Sites fran Updates 1-4," Federal Register, dated 6/10/86.
"Proposal of Upda te 4," Federal Register, dated 9/18/85.
3 ) Mencrandum to u. S. EPA fran Mr. Gene Lucero regardil'9 carmuni ty relations
at Superfund Enforcement sites, dated 8/28/85.
4) Groondwater Contamination and Protection, undated by Mr. tbna1d V.
~ano on 8/28/85.
5} Merrcrandum to Toxic Waste Management Division Directors Regions I-X fran
Mr. William Hedeman and Mr. Gene Lucero re: Policy on Floodplains and
Wetlands Assessments for CER:1A Actions, 8/6/85.
6) Glidance on Remedial Investigations under CER:IA, dated 6/85.
. .
7) Glidance on Feasibility Studies under CER:IA, dated 6/85.
8} "PrCPOSal of Update 3," Federal Register, dated 4/10/85.
9} Mencrandum to Mr. Jack McGraw entitled "CamlJnity Relations Activites
at Superfund Sites - Interim Guidance," dated 3/22/85.
10)
"Proposal 'of Update 2," Federal Register, dated 10/15/84
11 } EPA GroJndwater Protectioo Strategy, dated 9/84.
12) Merrcrandum to U.5.. EPA fran Mr. William Heckman, Jr. entitled
"Transmittal at Superfunj RerrDva1 Procedures - Revisioo 2," dated 8/20/84.
13) "Proposal of Update 1," Federal Register, dated 9/8/83.
14} Camuni ty Relations in Superfund: A Handbook (interim venJioo),
~/8J.
dated
15)
"~ of First National Priority List," Federal Register, dated
12/30/82. . .
"Expanded Eligibility List," Federal ~ister, dated 7/23/82.
l6}
17)
.
. Interim Priori ties List," Federal Register, dated 10/23/81.
18} pncontrolled Hazardoos Waste Site Ranking System: A User's ManJal
(undated1. . .'
19) Field Standard ~rating Procedures - Air Surveillance (undated).
20) Field Standard ~rating Procedures - Site Safety Plan (undated).
* Located in EPA Region III office.
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DA
'ENNSYLVANIA
~
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
H'rri=::rg~~::n:;I:'=~ 7120 ~~U\!lW-.' \
September 29, 1988 ~t" ~OCT 1 198"
(717) 787-5028 -
t M-":!gerr . ..i~lan
Hazardous Wa",e r. -
EPA - aei10n ~
Deputy Secretary for
Environmental Protection
Stephen R.. Wassersug, Director
Hazardous Waste Management Division
EPA Region III
841 Chestnut Building
Philadelphia, PA 19107
Re: Letter of Concurrence
Drake Chemical Superfund Site, Record of Decision (ROD)
Dear Mr. Wassersugl
The Record of Decision for Phase III of the Drake
Chemical Superfund Site has been reviewed by the Department.
The major components of the selected remedy, as
described in the Record of Decision, include.
.
-!!
1
.
*
Excavation of contaminated sludge/soils/sediments and
incineration using a transportable, onsite, rotary
kiln.
Pumping of contaminated groundwater to a treatment
system utilizing Biological Activated Carbon.
I hereby concur with the BPA' s proposed remedy, with
the following condition81
*
*
The Depart8ent will be given the opportunity to concur
with decisiona related to the d..ign of the remedial
action to a..ure co.pliance with State ARARs.
.. will ...ure that the Deparaaent i8 provided an
1.f~rtUDity to fully participate in any negotiations
f-'~ Z88ponsible partie8. .
~ D8fart-nt will re8erv~ our right and .
re.pon8ibility to take independent enforcement actions
pursuant to state law.
*
*
*
This concurrence with the 8elected remedial action is
not intended to provide any a88urances pursuant to SARA
Section 104(c)(3).
-------
Stephen R. Wassersug, Director
2
September 29, 1988
Thank you for the opportunity to concur with this EPA
Record Of Decision. If you have any questions regarding this
matter, please do not hesitate to contact me.
Jt;;;;f;/L(U£d
Deputy Secretary
Environmental Protection
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