EPA/ROD/R03-84/002
1984
EPA Superfund
Record of Decision:
DRAKE CHEMICAL
EPA ID: PAD003058047
OU01
LOCK HAVEN, PA
09/30/1984
-------
DRAKE CHEMICAL SITE, LOCK HAVEN, PENNSYLVANIA.
#DR
DOCUMENTS REVIEWED
I AM BASING MY DECISION PRINCIPALLY ON THE FOLLOWING DOCUMENTS DESCRIBING THE ANALYSIS OF COST EFFECTIVENESS
AND FEASIBILITY OF REMEDIAL ALTERNATIVES FOR PHASE I (LEACHATE STREAM AREA) FOR THE DRAKE CHEMICAL SITE:
"REMEDIAL INVESTIGATION REPORT (PHASE I) LEACHATE STREAM AREA" VOLUMES I AND II, DRAKE CHEMICAL
SITE, LOCK HAVEN, CLINTON COUNTY, PENNSYLVANIA (NUS CORPORATION, JULY 1984).
"FEASIBILITY STUDY (PHASE I) LEACHATE STREAM AREA," DRAKE CHEMICAL INC. SITE, LOCK HAVEN,
CLINTON COUNTY, PENNSYLVANIA (NUS CORPORATION, JULY 1984).
EPA'S ENVIRONMENTAL RESPONSE TEAM "EXTENT OF CONTAMINATION STUDY" REPORT (APRIL 1982).
"A TOXICOLOGICAL IMPACT ASSESSMENT OF THE DRAKE CHEMICAL SITE" (NUS CORPORATION, MAY 1983).
STAFF SUMMARIES AND RECOMMENDATIONS.
RECOMMENDATIONS BY THE PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES.
#DE
DECLARATIONS
CONSISTENT WITH THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT OF 1980 (CERCLA),
AND THE NATIONAL CONTINGENCY PLAN (40 C.F.R. PART 300), I HAVE DETERMINED THAT THE STREAM REMEDIATION ACTIONS
DESCRIBED ABOVE TOGETHER WITH TEMPORARY ON-SITE DISPOSAL FOR THE EXCAVATED SEDIMENTS IS A COST-EFFECTIVE
REMEDY AND PROVIDES ADEQUATE PROTECTION OF PUBLIC HEALTH, WELFARE AND THE ENVIRONMENT. THE REMEDIAL ACTION
ELIMINATES THE POSSIBILITY OF DIRECT PUBLIC CONTACT WITH CONTAMINATED MATERIALS IN THE LEACHATE STREAM AND IS
GENERALLY CONSISTENT WITH ANTICIPATED SUBSEQUENT REMEDIAL ACTIONS AT THE SITE. THE REMEDIAL ACTION WILL BE
DESIGNED SO AS NOT TO ALTER LOCAL FLOOD STAGES OR OTHERWISE IMPACT THE FLOODPLAIN. A FLOODPLAIN ASSESSMENT
WILL BE PERFORMED PRIOR TO ANY FURTHER REMEDIAL ACTION AT THE SITE. THE STATE OF PENNSYLVANIA HAS BEEN
CONSULTED AND AGREES WITH THE APPROVED REMEDY. IN ADDITION, THE ACTION WILL REQUIRE FUTURE OPERATION AND
MAINTENANCE ACTIVITIES TO ENSURE THE CONTINUED EFFECTIVENESS OF THE REMEDY. THESE ACTIVITIES WILL BE
CONSIDERED PART OF THE APPROVED ACTION AND ELIGIBLE FOR TRUST FUND MONIES FOR A PERIOD OF SIX MONTHS.
I HAVE DETERMINED THAT THE ACTION BEING TAKEN IS APPROPRIATE WHEN BALANCED AGAINST THE AVAILABILITY OF TRUST
FUND MONIES FOR USE AT OTHER SITES.
9/30/84
DATE LEE M. THOMAS
ASSISTANT ADMINISTRATOR
OFFICE OF SOLID WASTE AND EMERGENCY RESPONSE.
-------
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
DRAKE CHEMICAL SITE - PHASE I
#SLD
SITE LOCATION AND DESCRIPTION
THE DRAKE SITE IS LOCATED IN LOCK HAVEN, CLINTON COUNTY, PENNSYLVANIA (FIGURE 1). THE EIGHT-ACRE SITE, NO
LONGER ACTIVE, CONTAINS SIX MAJOR BUILDINGS INCLUDING FORMER OFFICES, PRODUCTION FACILITIES AND A WASTEWATER
TREATMENT BUILDING. ALSO ON THE SITE ARE TWO LINED WASTEWATER TREATMENT LAGOONS, AN UNLINED SLUDGE LAGOON
AND AN UNLINED LIQUID LAGOON. CHEMICAL SLUDGE COVERS MUCH OF THE OPEN AREA ON SITE. DRUMS AND BULK WASTE MAY
ALSO BE BURIED ON-SITE.
CONSTRUCTION DEBRIS IS STREWN ABOUT THE SITE (FIGURE 2). ALL OF THE ABOVE WILL BE ADDRESSED IN PHASE II OF
THE DRAKE FEASIBILITY STUDY.
IT WAS DETERMINED THAT IN ORDER TO EXPEDITE THE REMEDIATION OF THE LEACHATE STREAM, WHICH POSES THE GREATEST
THREAT OF DIRECT CONTACT TO THE PUBLIC, A PHASED APPROACH SHOULD BE IMPLEMENTED. THE PHASED APPROACH WOULD
ALLOW DESIGN AND CONSTRUCTION WORK TO PROCEED FOR PHASE I WHILE REMEDIAL ALTERNATIVES WERE STILL BEING
DEVELOPED FOR THE MORE TECHNICALLY COMPLEX PHASE II AND PHASE III WHICH DEAL WITH ON-SITE SOIL CONTAMINATION
AND REGIONAL GROUNDWATER CONTAMINATION, RESPECTIVELY.
OF CONCERN FOR THIS RECORD OF DECISION DOCUMENT IS THE "LEACHATE STREAM" WHICH RUNS OFF-SITE FROM THE
RAILROAD EMBANKMENT TO BALD EAGLE CREEK (FIGURE 3). FROM THE EMBANKMENT, THE STREAM FLOWS SOUTH FOR
APPROXIMATELY 1600 FEET BEFORE DISCHARGING INTO BALD EAGLE CREEK. DURING THE COURSE OF THE FLOW, THE STREAM
PASSES THROUGH CONDUITS UNDER PINE STREET, U.S. ROUTE 220, A CONDUIT IN CASTANEA TOWNSHIP PARK, AND THE PARK
ROAD. ADJACENT TO THE PROPERTY (WITHIN 1/4 MILE) IS A LARGE APARTMENT COMPLEX (INHABITED MOSTLY BY SENIOR
CITIZENS), A LARGE SHOPPING CENTER, AND A MUNICIPAL PARK. LOCK HAVEN UNIVERSITY, ELEMENTARY SCHOOLS, AND
SEVERAL CHURCHES ARE LOCATED WITHIN A ONE-MILE RADIUS OF THE SITE. BALD EAGLE CREEK IS LOCATED LESS THAN 1/2
MILE SOUTH OF THE SITE AND THE WEST BRANCH OF THE SUSQUEHANNA RIVER IS LOCATED APPROXIMATELY 3/4 MILE NORTH
OF THE SITE.
#SH
SITE HISTORY
DRAKE CHEMICAL, INC. PURCHASED THE SITE IN 1962. THE EARLY HISTORY OF PRODUCTION AT DRAKE CHEMICAL, INC. IS
UNCLEAR, BUT THE SITE HAD BEEN INVOLVED FOR MANY YEARS IN THE MANUFACTURE OF SMALL BATCHES OF SPECIALTY
INTERMEDIATE CHEMICALS FOR PRODUCERS OF DYES, PHARMACEUTICALS, COSMETICS, TEXTILES, PLANT ADDITIVES, AND
PESTICIDES. THESE PRODUCTS WERE SYNTHESIZED USING THE PROCESS OF SULFONATION, CONTAMINATION, CHLORINATION,
AND CYANATION. MOST PROCESSES AT DRAKE CHEMICAL WERE NEVER HIGHLY AUTOMATED AND REQUIRED HAND CHARGING OF
CHEMICALS INTO REACTOR VESSELS. THE ORGANIC COMPOUND 2,3,6-TRICHLOROPHENYLACETIC ACID (TCPAA), ALSO KNOWN AS
THE HERBICIDE FENAC, WAS MANUFACTURED AT THE PLANT AND IS A MAJOR SITE CONTAMINANT.
DURING THE TIME OF ACTIVE PRODUCTION AT THE DRAKE CHEMICAL FACILITY, PROCESS WASTEWATER AND SLUDGE WERE
PLACED IN THE LAGOON FOR STORAGE ON SITE. OVERFLOW FROM THE LAGOON PASSED THROUGH A CULVERT, INTO THE
LEACHATE STREAM AND THENCE TO BALD EAGLE CREEK. THE OVERFLOW AND LEAKAGE FROM THIS LAGOON HAVE TRANSPORTED
HAZARDOUS WASTE TO THE TRIBUTARY. HOWEVER, THE MAIN SOURCE OF STREAMBED FLOW IS FROM CONTAMINATED
GROUNDWATER WHICH SURFACES AT LOW AREAS ALONG A PART OF THE LEACHATE STREAM.
#css
CURRENT SITE STATUS
AS STATED ABOVE, THE MAIN SOURCE OF THE LEACHATE STREAM IS BASE FLOW DERIVED FROM GROUNDWATER DISCHARGE. THE
MAIN GROUNDWATER DISCHARGE AREA IS LOCATED WEST OF HIGHWAY 220, APPROXIMATELY HALFWAY BETWEEN PINE STREET AND
THE RAILROAD TRACKS. THE STREAMBED WEST OF HIGHWAY 220 VARIES IN WIDTH BETWEEN 10 AND 25 FEET AND IS DEVOID
OF VEGETATION. THE PRIMARY SOURCES OF THE STREAM DURING DRY PERIODS ARE: (FIGURE 4).
SMALL SEEPS OF LESS THAN 1 GPM AT THE BASE OF THE RAILROAD TRACKS ORIGINATING FROM THE MOUND
AROUND THE LEACHATE LAGOON.
SURFACE RUNOFF FROM WET AREAS WEST OF HAMMERMILL BALLFIELD.
GROUNDWATER DISCHARGE ALONG THE STREAM.
HIGHWAY 220 SEEPS AND STORM RUNOFF.
-------
EAST OF HIGHWAY 220, THE STREAM BED WIDTH DECREASES TO ABOUT 2 FEET IN WIDTH AT THE BASE AND IS VEGETATED.
STREAM FLOW WHICH PRIMARILY ORIGINATES EAST OF HIGHWAY 220 FLOWS THROUGH A CULVERT UNDER THE HIGHWAY AND INTO
CASTANEA TOWNSHIP PARK. THE STREAM LIMITS INFILTRATION INTO THE GROUNDWATER IN THIS STRETCH DURING NORMAL
FLOW CONDITIONS DUE TO THE LOW HYDRAULIC CONDUCTIVITY OF THE BASE OF THE STREAM BED. THE STREAM, AS WELL AS
GROUNDWATER IN THE TOWNSHIP PARK, DISCHARGES INTO BALD EAGLE CREEK.
DURING MARCH OF 1982, THE ENVIRONMENTAL RESPONSE TEAM (ERT) OF THE EPA CONDUCTED AN EXTENT OF CONTAMINATION
(EOC) STUDY OF THE LEACHATE STREAM AREA. THE PURPOSE OF THIS STUDY WAS TO DETERMINE THE DEGREE AND EXTENT OF
HAZARD ASSOCIATED WITH TOXIC RELEASES TO THE SOIL AND SURFACE WATERS FROM THE DRAKE CHEMICAL SITE PROPERTY.
THE INVESTIGATION DISCOVERED CONTAMINANTS IN THE LEACHATE STREAM SEDIMENTS AND BANK SOILS. THESE
CONTAMINANTS WERE:
CONTAMINANT
TRICHLOROPHENYLACETIC ACID
(ALL ISOMERS)(TCPAA)(FENAC)
1,2-DICHLOROBENZENE AND
1,4-DICHLOROBENZENE (DCB)
DICHLOROANILINE (ALL ISOMERS)(DCA)
NITROBENZENE
PHENOL
NITROTOLUENE (ALL ISOMERS)
NAPHTHOL
2,4-DICHLOROPHENOL (DCP)
4,6-DINITRO-O-CRESOL
CHLOROMETHYL ANILINE (ALL ISOMERS)
METHYL NITROANILINE (ALL ISOMERS)
DIETHYLENE GLYCOL
ND - NON-DETECTABLE
PPB - PARTS PER BILLION.
SURFACE AND CENTERLINE DEPTH DISTRIBUTION FOR FENAC IS EXHIBITED IN FIGURE 5.
A REMEDIAL INVESTIGATION OF THE SITE AND SURROUNDING AREA, UNDER THE SPONSORSHIP OF THE EPA (SUPERFUND), WAS
CONDUCTED FROM MAY 1983 TO MARCH 1984 TO SUPPLEMENT THE PREVIOUS FINDINGS AND TO PROVIDE DATA TO PERFORM
FEASIBILITY STUDIES.
EXPLORATORY BORINGS WERE DRILLED AND MONITORING WELLS WERE INSTALLED IN ORDER (1) TO DEFINE THE GEOLOGY OF
THE UNDERLYING SITE IN THE CONTEXT OF CONTAMINANTS BEING CARRIED BY SURFACE WATER INTO DEEPER SOIL HORIZONS
AND (2) TO ESTIMATE THE EXTENT OF CONTAMINATION OF DEEPER SOILS AND GROUNDWATER BENEATH THE SITE. MULTILEVEL
GAS-DRIVEN SAMPLER SYSTEMS WERE USED TO OBTAIN VERTICAL HEAD AND CONTAMINANT DISTRIBUTION INFORMATION. WELL
POINTS PLACED ALONG THE STREAMBED WERE ALSO EMPLOYED.
A SAMPLING PROGRAM WAS CONDUCTED TO DEFINE THE VOLUME, EXTENT, AND CHARACTERISTICS OF ON-SITE AND OFF-SITE
CONTAMINATION. SHALLOW HAND-AUGER BORINGS WERE PERFORMED TO SAMPLE LOCAL SOILS AND TO ASSIST IN DESCRIBING
THE SHALLOW GEOLOGY AND HYDROGEOLOGY. SURFACE WATER AND SEDIMENT SAMPLES WERE COLLECTED TO OBTAIN
INFORMATION ON THE POSSIBILITY OF OFF-SITE MIGRATION OF CONTAMINATION.
AN AQUATIC SURVEY WAS PERFORMED TO ESTABLISH THE IMPACTS OF POSSIBLE WATER CONTAMINATION UPON THE FISH
POPULATION. SIMILARLY, A TERRESTRIAL SURVEY ESTABLISHED THE IMPACTS UPON THE SURROUNDING PLANT LIFE.
THE GROUNDWATER SAMPLES WERE ANALYZED FOR PRIORITY POLLUTANTS, ALONG WITH FENAC, TOH, TOC, SULFATE, CHLORIDE,
PH, CONDUCTIVITY, AND AMMONIA. FIGURE 6 SHOWS THE LOCATIONS OF THE MONITORING WELLS.
LEVEL OF CONTAMINATION
ND TO 21,000 PPB
ND TO 18,100 PPB
ND TO 1,400 PPB
ND TO 360 PPB
ND TO 1,800 PPB
ND TO 1,770 PPB
ND TO 3,200 PPB
ND TO 210 PPB
UNKNOWN
UNKNOWN
UNKNOWN
UNKNOWN
-------
FENAC WAS OBSERVED TO BE A GOOD INDICATOR OF CONTAMINATION AT THE SITE. FENAC WAS DETECTED IN THE ONSITE
WELLS AT CONCENTRATIONS RANGING FROM 2,300 TO 57,000 MICROGRAMS PER LITER (UG/L) (PARTS PER BILLION). FENAC
CONCENTRATION IN THE OFFSITE MONITORING WELLS RANGED FROM NONDETECTABLE TO 389 UG/L. TABLE 1 PRESENTS A LIST
OF OTHER ORGANICS AND INORGANICS DETECTED BOTH ON-SITE AND OFF-SITE.
THE HIGHEST LEVELS OF CONTAMINATION ALONG THE LEACHATE STREAM WERE ENCOUNTERED NEAR THE ORIGIN OF THE STREAM.
ANALYSIS OF SAMPLES IN THIS AREA INDICATES THAT CONTAMINATION IS HIGHEST IN THE SHALLOW SAMPLE AND QUALITY
IMPROVES WITH DEPTH. AT THE LOWER END OF THE STREAM, THE CONTAMINANT ANALYSIS INDICATES A WATER QUALITY
SLIGHTLY POORER THAN ENCOUNTERED IN BACKGROUND SAMPLING. THE CONTAMINANT INDICATOR FENAC WAS NOT ENCOUNTERED
IN A SAMPLE OBTAINED FROM THE CONFLUENCE OF THE LEACHATE STREAM AND BALD EAGLE CREEK. THE ORGANIC
CONTAMINANT FOUND WAS DI-N-BUTYL PHTHALATE, AT A CONCENTRATION OF LESS THAN 10 UG/L.
THE INORGANIC CONTAMINANTS INCLUDE:
ELEMENT CONCENTRATION
ALUMINUM 208 UG/L
BARIUM 110 UG/L
CADMIUM 1 UG/L
IRON 133 UG/L
MANGANESE 240 UG/L
ZINC 18 UG/L.
DURING PERIODS OF ELEVATED GROUND WATER CONDITIONS, AND THUS INCREASED STREAM FLOW, THE CONTAMINANTS PRESENT
IN THE SHALLOW GROUNDWATER RAVINE MAY BE TRANSFERRED TO THE LEACHATE STREAM.
AS PART OF THE RI, ONE SEDIMENT SAMPLE WAS OBTAINED FROM THE LEACHATE STREAM, NEAR THE CONDUIT OUTLET ON THE
SOUTHERN SIDE OF U.S. ROUTE 220. THE RESULTS OF THE ANALYSIS OF THIS SAMPLE ARE LISTED IN TABLE 2. PREVIOUS
SAMPLING OF THE LEACHATE STREAM WAS CONDUCTED BY THE EPA ENVIRONMENTAL RESPONSE TEAM IN 1982. THE RESULTS OF
THIS SAMPLING EFFORT WERE USED TO ESTIMATE VOLUMES OF CONTAMINATED SEDIMENT.
IT APPEARS THAT FENAC CAN BE USED AS AN INDICATOR OF SUBSURFACE SOIL CONTAMINATION. WHERE FENAC
CONCENTRATIONS ARE ELEVATED, OTHER CHEMICAL CONCENTRATIONS ARE ELEVATED. THE OPPOSITE ALSO SEEMS TO BE
TRUE; THAT IS, LOW CONCENTRATIONS OF FENAC ARE ACCOMPANIED BY LOW CONCENTRATIONS OF OTHER CHEMICALS.
OFF-SITE SURFACE SOIL SAMPLES DID NOT CONTAIN DETECTABLE LIMITS OF FENAC. ONLY SMALL AMOUNTS OF ORGANICS AND
METALS WERE FOUND IN SELECTED SAMPLES.
FENAC WAS NOT DETECTED IN OFF-SITE SAMPLES EXCEPT IN THE BORING SOILS FOR THE MONITORING WELL AT THE HEAD OF
THE LEACHATE STREAM, WHERE THE CONCENTRATIONS RANGED FROM NOT DETECTABLE TO 2,100 UG/KG.
A MONITORING WELL INSTALLED 400 FEET DOWNSTREAM FROM THE HEAD WATERS DOES NOT SHOW SOIL CONTAMINATION FROM
FENAC. TABLE 3 SHOWS ANALYSIS OF SUBSURFACE SOIL INDICATORS IN AND AROUND THE LEACHATE STREAM.
ENDANGERMENT ASSESSMENT
UNDER A DIRECTIVE FROM THE EPA, REGION III FIT (NUS CORPORATION) INVESTIGATED THE TOXICOLOGY OF THE CHEMICALS
AT THE SITE AND PREPARED A TOXICOLOGICAL IMPACT ASSESSMENT OF THE LEACHATE STREAM. IN ADDITION, THE DRAKE
REMEDIAL INVESTIGATION REPORT INCLUDED A HEALTH RISK ASSESSMENT SECTION WHICH, AS WITH THE FIT REPORT, GAVE
AN ASSESSMENT OF THE CRITICAL COMPOUNDS FOUND IN THE LEACHATE STREAM AND SEDIMENT.
THE FINDINGS OF THE RISK ASSESSMENT INDICATE THAT THE GREATEST RISK OF EXPOSURE, ALTHOUGH RELATIVELY LOW, IS
POSED BY DIRECT CONTACT WITH DERMALLY ACTIVE OR ABSORBENT COMPOUNDS PRESENT IN THE LEACHATE AREA. OF
SECONDARY IMPORTANCE WERE RISKS POSED BY COMPOUNDS THAT MAY BE DISCHARGED INTO BALD EAGLE CREEK AND
ACCUMULATED BY AQUATIC LIFE. TO DATE, SIGNIFICANT IMPACTS ON AQUATIC LIFE IN BALD EAGLE CREEK DUE TO THE
DRAKE SITE HAVE NOT BEEN FOUND. ALTHOUGH OF LESS IMPORTANCE FROM THE STANDPOINT OF EXPOSURE PATHWAY
SIGNIFICANCE, GROUNDWATER WAS FOUND CONTAMINATED WITH HIGHLY TOXIC, CARCINOGENIC COMPOUNDS THAT MAY BE
SIGNIFICANT TO FURTHER EVALUATION OF MITIGATIVE MEASURES IN THE LEACHATE STREAM AREA. TABLE 3 PRESENTS THE
CRITICAL COMPOUNDS AND THE MEDIA IN WHICH THEY ARE FOUND.
SINCE DIRECT CONTACT WITH THESE CHEMICALS POSES THE MOST SERIOUS THREAT TO HUMAN HEALTH IN THIS AREA, THE
FOLLOWING DISCUSSION IS LIMITED TO THOSE COMPOUNDS FOUND IN THE STREAM AND ITS SEDIMENT.
FENAC IS A PERSISTENT HERBICIDE THAT HAS BEEN CLASSIFIED AS MODERATELY TOXIC TO HUMANS, WITH AN ORAL DOSE OF
0.5 TO 5 GRAMS PER KILOGRAM OF BODY WEIGHT. IN LABORATORY EXPERIMENTS A DERMAL DOSAGE OF 3,160 MG/KG OF BODY
WEIGHT HAS PROVED FATAL TO 50 PERCENT OF EXPOSED RABBITS. THE LONG-TERM CHRONIC TOXIC EFFECT OF FENAC ON
HUMANS IS YET UNKNOWN. FENAC IS A PERSISTENT COMPOUND AND DELAYED EFFECTS FROM LONG-TERM EXPOSURE IS A
-------
POSSIBILITY.
PENTACHLOROPHENOL IS A VERY TOXIC COMPOUND THAT MAY BE ABSORBED THROUGH THE SKIN AND THE GASTROINTESTINAL
TRACT. THE LETHAL DOSE FOR 50 PERCENT OF LABORATORY RATS AND HAMSTERS IS 50 AND 168 MG/KG RESPECTIVELY.
DERMAL PENETRATION IS THE MOST DANGEROUS EXPOSURE PATHWAY. ACUTE SKIN EXPOSURE MAY RESULT IN CONTACT
DERMATITIS, WHILE EXTENSIVE CONTACT WITH THIS COMPOUND HAS RESULTED IN PERSISTENT CHLORACNE. BECAUSE OF
PENTACHLOROPHENOL'S PRESENCE IN THE LEACHATE STREAM AND BECAUSE OF ITS DERMAL ABSORPTION CHARACTERISTICS,
THERE IS A RISK POSED TO PERSONS USING THE RECREATIONAL AREAS NEAR THE CONTAMINATION.
DICHLOROBENZENES WERE ALSO FOUND IN HIGH CONCENTRATIONS IN THE LEACHATE SEDIMENT. THE DIFFERENT ISOMERS OF
THIS COMPOUND ARE MODERATELY TOXIC VIA THE INHALATION AND DERMAL ROUTE AND MAY PRODUCE PAINFUL IRRITATING
EFFECTS TO THE SKIN AND MUCOUS MEMBRANES.
COMPARISON OF CONCENTRATIONS OF THE ABOVE COMPOUNDS WITH KNOWN CRITERIA FOR THOSE COMPOUNDS ARE GIVEN IN
TABLE 4.
#ENF
ENFORCEMENT
IN APRIL OF 1979, A CONSENT DECREE WAS SIGNED BETWEEN DRAKE CHEMICALS AND THE PENNSYLVANIA DEPARTMENT OF
ENVIRONMENTAL RESOURCES CONCERNING WASTEWATER AND SLUDGE DISPOSAL AT THE SITE. IN JANUARY OF 1982, A
NOTICE OF VIOLATION WAS ISSUED BY THE STATE BASED ON VIOLATIONS OF THE APRIL 1979 CONSENT DECREE. AFTER
DRAKE FILED FOR LIQUIDATION UNDER CHAPTER 7 OF THE BANKRUPTCY ACT, EPA CONDUCTED EMERGENCY ACTIVITIES AT THE
SITE. NOTICE LETTERS CONCERNING THESE EMERGENCY ACTIONS WERE SENT TO: ERNEST DION, PRESIDENT/OWNER DRAKE
CHEMICALS INC; AMERICAN COLOR AND CHEMICAL COMPANY AND MR. WILLIAM KNECT, THE TRUSTEE FOR THE BANKRUPT
ESTATE. NO POSITIVE RESPONSE WAS RECEIVED SO CERCLA FUNDS WERE USED IN THE CLEANUP.
IN OCTOBER OF 1982, NOTICE LETTERS WERE AGAIN SENT TO THE THREE POTENTIALLY RESPONSIBLE PARTIES INFORMING
THEM THAT A REMEDIAL INVESTIGATION AND FEASIBILITY STUDY WERE ABOUT TO BE UNDERTAKEN BY EPA AT DRAKE.
ALTHOUGH AMERICAN COLOR AND CHEMICAL MET WITH EPA ON THE MATTER, NO FINAL SETTLEMENT WAS REACHED.
IN AUGUST OF 1984, NOTICE LETTERS WERE ISSUED TO ERNEST DION AND AMERICAN COLOR AND CHEMICAL INFORMING THEM
THAT PHASE I REMEDIATION WAS ABOUT TO BEGIN AT DRAKE AND OFFERING THEM THE OPPORTUNITY TO PERFORM THE NEEDED
ACTIONS. AMERICAN COLOR AND CHEMICAL RESPONDED TO EPA'S NOTICE LETTER ON SEPTEMBER 13, 1984. THE COMPANY
DECLINED TO UNDERTAKE RESPONSE ACTION, MAINTAINING THAT IT WAS NOT RESPONSIBLE FOR LEACHATE STREAM
CONTAMINATION. WE WILL NOTIFY AC&C BEFORE INITIATING PHASE III. THE COMPANY MAY BE INTERESTED IN
UNDERTAKING A PORTION OF PHASE III ACTIONS.
CONCLUSIONS
THE FOLLOWING CONCLUSIONS ARE BASED ON THE RESULTS OF THE RI, THE EOC REPORT, AND THE TOXICOLOGICAL IMPACT
ASSESSMENT:
THE PRIMARY SOURCE OF WATER IN THE STREAM IS PROBABLY DUE TO GROUNDWATER SEEPAGE INTO THE
TRIBUTARY. THE MAJORITY OF THIS INFLUX PROBABLY OCCURS WITHIN THE UPPER 400 FEET OF STREAM.
THE PRIMARY MODES OF ENVIRONMENTAL CONTAMINANT TRANSPORT FROM THE LEACHATE STREAM ARE VIA
SURFACE AND GROUNDWATER MOVEMENT OF SUSPENDED OR DISSOLVED CONTAMINANTS.
DATA INDICATE THAT THE HIGHEST CONTAMINANT CONCENTRATIONS OF FENAC AND OTHER SELECT CHEMICALS
ARE IN THE SEDIMENTS.
SURFACE SOILS IN THE AREA OF THE LEACHATE STREAM IN THE PUBLIC PARK APPEAR TO BE RELATIVELY
DEVOID OF THE CONTAMINANTS FOUND ELSEWHERE. HOWEVER, FLOOD EVENTS CAN TRANSPORT CONTAMINANTS
FROM THE LEACHATE STREAM ONTO THE SURROUNDING FLOODPLAIN.
OFF-SITE SURFACE WATER ANALYSES INDICATE THAT THERE IS PRESENTLY LITTLE IMPACT OF LEACHATE
CONTAMINATION ON AQUATIC LIFE AND WATER QUALITY IN BALD EAGLE CREEK.
THOSE PERSONS SUBJECT TO THE GREATEST RISK FROM THE LEACHATE STREAM ARE THE LOCAL POPULATIONS
WHO MAY COME INTO DIRECT CONTACT WITH THE LEACHATE OR SEDIMENTS.
#AE
ALTERNATIVES EVALUATION
THE ALTERNATIVES EVALUATED IN THE FEASIBILITY STUDY ARE CONSIDERED OFF-SITE MEASURES AS DEFINED UNDER 40 CFR
-------
PART 300. 68 (E) (3) .
ALTERNATIVES IDENTIFIED IN THE FEASIBILITY STUDY HAVE BEEN DEVELOPED IN ORDER TO MEET A SET OF SITE-SPECIFIC
REMEDIAL ACTION OBJECTIVES. FOR PHASE 1 OF THE DRAKE CHEMICAL SITE THESE OBJECTIVES ARE:
TO MAINTAIN THE PUBLIC HEALTH AND SAFETY. THE LEACHATE STREAM POSES A THREAT TO THE PUBLIC
THROUGH POSSIBLE CONTACT WITH CONTAMINATED WATER AND SEDIMENTS. THIS THREAT CAN BE DECREASED
BY REMOVING THE POTENTIAL FOR EXPOSURE.
TO ATTEMPT TO MAKE THE PUBLICLY-OWNED LAND SAFE FOR HUMAN ACCESS. THE CASTANEA TOWNSHIP PARK
HAS BEEN CLOSED BECAUSE OF THE PRESENCE OF THE LEACHATE STREAM. REMEDIAL ACTION OPTIMALLY
SHOULD ALLOW THE PARK TO BE SAFELY REOPENED FOR ITS FORMER USE.
TO DEVELOP REMEDIAL ACTIONS WHICH ARE BOTH TECHNICALLY FEASIBLE AND COST-EFFECTIVE.
NUMEROUS REMEDIAL ALTERNATIVES ARE AVAILABLE FOR USE AT THE DRAKE CHEMICAL SITE. ALTHOUGH MANY ALTERNATIVES
ARE APPLICABLE, IT IS APPARENT THAT A NUMBER OF ALTERNATIVES CAN BE REMOVED FROM CONSIDERATION.
THE SCOPE OF THE PHASE I FEASIBILITY STUDY IS LIMITED TO ALTERNATIVES ADDRESSING THE PROBLEMS SURROUNDING THE
LEACHATE STREAM. ALTERNATIVES RELATING TO SOURCE CONTROL AND GROUNDWATER TREATMENT WERE CONSIDERED BEYOND THE
SCOPE OF STUDY AND THEREFORE THIS ROD. THE RATIONALE FOR ELIMINATION OF VARIOUS ALTERNATIVES IS PRESENTED IN
TABLE 5. THIS SCREENING IS BASED ON THE INFORMATION OBTAINED DURING THE RAMP, THE REMEDIAL INVESTIGATION AND
ADDITIONAL INVESTIGATIVE EFFORTS. THESE INVESTIGATIVE TASKS INCLUDE:
A SITE VISIT PERFORMED BY THE RSPO AND NUS PROJECT ENGINEER.
MEETINGS WITH THE RSPO AND THE NUS PROJECT ENGINEER.
REVIEW OF THE SITE SOIL, ROCK, AND GROUNDWATER CONDITIONS IDENTIFIED DURING THE SUBSURFACE
OPERATIONS.
IDENTIFICATION, REVIEW, AND ASSESSMENT OF CRITICAL SITE ENGINEERING FEATURES, INCLUDING
CULVERTS UNDER ROADWAYS, BANK SLOPES, ELEVATIONS AND STREAM PROFILES AND GRADIENTS.
REVIEW OF OTHER FEASIBILITY STUDIES USING THE TYPES OF ALTERNATIVES CONSIDERED FOR THIS SITE.
AFTER COMPLETION OF THE INITIAL SCREENING OF TECHNOLOGIES, A DETAILED EVALUATION OF ALTERNATIVES WAS
CONDUCTED IN ORDER TO IDENTIFY THOSE ALTERNATIVES THAT ARE MOST APPLICABLE FOR THE DISPOSAL PROBLEMS AT THE
SITE. THE COST-EFFECTIVE ALTERNATIVE IS THE LOWEST COST ALTERNATIVE THAT IS TECHNOLOGICALLY FEASIBLE AND
RELIABLE AND THAT EFFECTIVELY MITIGATES OR MINIMIZES DAMAGE TO AND PROVIDES ADEQUATE PROTECTION OF PUBLIC
HEALTH, WELFARE, AND THE ENVIRONMENT (NATIONAL CONTINGENCY PLAN).
THE CRITICAL COMPONENTS OF EFFECTIVENESS MEASURES WERE SELECTED TO BE TECHNICAL FEASIBILITY, PUBLIC HEALTH,
AND INSTITUTIONAL AND ENVIRONMENTAL EFFECTS. PARTICULAR EMPHASIS WAS PLACED ON THE FOLLOWING:
TECHNICAL FEASIBILITY:
PROVEN OR EXPERIMENTAL TECHNOLOGY.
RISK OF FAILURE.
PUBLIC HEALTH EFFECTS:
REDUCTION OF HEALTH AND ENVIRONMENTAL IMPACTS.
DEGREE OF CLEANUP.
INSTITUTIONAL EFFECTS:
LEGAL REQUIREMENTS, INSTITUTIONAL REQUIREMENTS.
COMMUNITY IMPACTS.
EFFECTS UPON LAND USE.
ENVIRONMENTAL EFFECTS:
IMPACT OF FAILURE.
LENGTH OF TIME REQUIRED FOR CLEANUP.
AMOUNT OF ENVIRONMENTAL CONTAMINATION WITH RESPECT TO ACCEPTABLE LEVELS.
-------
BASED ON THESE COMPONENTS, A SET OF INDEPENDENT "EFFECTIVENESS MEASURES" WERE DEVELOPED, AS FOLLOWS:
TECHNOLOGY STATUS.
RISK AND EFFECT OF FAILURE.
LEVEL OF CLEANUP OR ISOLATION ACHIEVABLE.
ABILITY TO MINIMIZE COMMUNITY IMPACTS.
ABILITY TO MEET RELEVANT PUBLIC HEALTH & ENVIRONMENTAL CRITERIA.
ABILITY TO MEET LEGAL AND INSTITUTIONAL REQUIREMENTS.
TIME REQUIRED TO ACHIEVE CLEANUP OR ISOLATION.
ACCEPTABILITY OF LAND USE AFTER ACTION.
NO ACTION ALTERNATIVE
IN THE ENDANGERMENT ASSESSMENT SECTION, THE RISK OF ADVERSE HEALTH EFFECTS DUE TO DERMAL EXPOSURE TO, OR
INGESTION OF, FENAC, PENTACHLOROPHENOL, OR DICHLOROBENZENES WAS ESTABLISHED. THE NO ACTION ALTERNATIVE WOULD
ALLOW THE RISK OF PUBLIC EXPOSURE TO THESE CHEMICALS TO CONTINUE.
THEREFORE, THE NO ACTION ALTERNATIVE WAS REMOVED FROM CONSIDERATION.
THE TECHNOLOGIES REMAINING AFTER THE INITIAL SCREENING PROCESS WERE GROUPED INTO TWO CATEGORIES:
SITE-RELATED ACTIVITIES AND DISPOSAL-RELATED ACTIVITIES. THE TECHNOLOGIES REMAINING WERE:
SITE-RELATED
EXCAVATION FOR DISPOSAL
GRANULAR OR ROCKFILL DRAINAGE SYSTEM
PERFORATED CONDUIT DRAINAGE SYSTEM
PROTECTIVE COVER
IMPERMEABLE CHANNEL LINING
GRADING
REVEGETATION.
DISPOSAL-RELATED
INTERIM ON-SITE LANDFILL
OFF-SITE LANDFILL.
THESE TECHNOLOGIES WERE COMBINED IN THE FOLLOWING LOGICAL GROUPS THAT WOULD BE APPLICABLE TO THIS SITE:
EXCAVATE SEDIMENT - REPLACE WITH AN IMPERMEABLE LINING.
CONSTRUCT GRANULAR DRAIN - COVER TO ELEVATION OF SURROUNDING LAND.
CONSTRUCT CONDUIT DRAIN - COVER TO ELEVATION OF SURROUNDING LAND.
COVER STREAM - PROVIDE FOR SURFACE WATER DRAINAGE.
TEMPORARY ON-SITE DISPOSAL.
OFF-SITE DISPOSAL.
DESCRIPTION OF REMEDIAL ALTERNATIVES
STREAM REMEDIATION ALTERNATIVES:
1. EXCAVATION OF CONTAMINATED SEDIMENTS - REPLACE WITH IMPERMEABLE LINING
IN THIS ALTERNATIVE, THE CONTAMINATED SEDIMENTS IN THE STREAMBED AND ON THE BANKS WILL BE EXCAVATED. TOTAL
REMOVAL OF APPROXIMATELY 7,500 CUBIC YARDS OF SEDIMENT IS ANTICIPATED FOR THIS OPTION IN ORDER TO PROPERLY
PROTECT THE PUBLIC FROM DIRECT CONTACT IN CASE OF FAILURE OF THE LINER. THE EXCAVATED AREA WILL BE BACK
FILLED WITH A COMPACTED CLAY, OR A SYNTHETIC MEMBRANE/SOIL COVER COMBINATION, TO THE ORIGINAL GRADES AND
CONTOURS. THE PURPOSE IS TO REDUCE GROUNDWATER SEEPAGE INTO THE CHANNEL. THE LINING WILL EXTEND UP THE
EMBANKMENTS BEYOND THE POINT OF SEEPAGE ANTICIPATED DURING HIGH GROUNDWATER CONDITIONS.
2. CONSTRUCT GRANULAR DRAIN - COVER TO ELEVATION OF SURROUNDING LAND
FOR THIS ALTERNATIVE, A ROCKFILL DRAIN ENVELOPED IN FILTER FABRIC WILL BE PLACED IN THE EXISTING STREAM
-------
CHANNEL. INLET AND OUTLET STRUCTURES WILL BE CONSTRUCTED TO CONNECT THE DRAIN WITH THE EXISTING CONDUIT AND
TO PROVIDE INLETS FOR SURFACE WATER RUNOFF. THE DRAIN WILL BE COVERED WITH SOIL TO PROTECT THE DRAIN AND
PROMOTE SURFACE WATER MANAGEMENT. SINCE THE CONTAMINATED SEDIMENTS WILL BE EFFECTIVELY COVERED TO ELIMINATE
THE RISK OF PUBLIC CONTACT, ONLY THE VOLUME OF CONTAMINATED SOILS NEEDED TO CONSTRUCT THE DRAIN PROPERLY WILL
BE REMOVED. AN ESTIMATED 2,000 CUBIC YARDS OF CLEAN ROCKFILL AND 6,000 SQUARE YARDS OF FILTER FABRIC WILL BE
REQUIRED FOR CONSTRUCTION. IN ADDITION, 12,000 CUBIC YARDS OF NATIVE SOILS WILL BE REQUIRED AS COVER
MATERIAL.
THE ENCLOSED DRAIN AND COVER WILL REDUCE EXPOSURE OF THE PUBLIC BY CONTAMINATED SEDIMENTS AND WATER FLOW.
THE FILTER FABRIC RETARDS THE MOVEMENT OF THE SEDIMENTS BY PERMITTING ONLY THE WATER TO PASS.
3. CONSTRUCT CONDUIT DRAIN - COVER TO ELEVATION OF SURROUNDING LAND
THIS ALTERNATIVE CALLS FOR A REINFORCED CONCRETE OR CORRUGATED METAL PERFORATED OR SLOTTED CONDUIT DRAINAGE
SYSTEM TO BE INSTALLED TO REPLACE THE STREAM. THE PIPE WILL BE IN A GRAVEL BED, WHICH WILL BE CONSTRUCTED
USING FILTER DESIGN CRITERIA TO REDUCE THE MOVEMENT AND PIPING OF THE SEDIMENTS. THE DRAIN WILL BE COVERED
WITH NATIVE SOILS FOR PROTECTION. ONLY THOSE SOILS NECESSARY TO PERFORM THE PROPER ENGINEERING WILL BE
EXCAVATED. APPROXIMATELY 1,300 LINEAR FEET OF CONDUIT WILL BE REQUIRED, ALONG WITH 4,500 CUBIC YARDS OF
GRANULAR MATERIAL. 12,000 CUBIC YARDS OF NATURAL SOILS ARE REQUIRED FOR USE AS A COVER. THE ENCLOSED DRAIN
AND COVER WILL REDUCE EXPOSURE OF THE PUBLIC TO CONTAMINATED SEDIMENTS AND WATER FLOW. THE GRAVEL FILTER WILL
RETARD THE MOVEMENT OF THE SEDIMENTS.
4. COVER STREAM - PROVIDE FOR SURFACE WATER DRAINAGE
THIS ALTERNATIVE IS A MODIFICATION OF THE PREVIOUS ALTERNATIVE USING A CONDUIT DRAIN TO REPLACE THE OPEN
CHANNEL. THE CONDUIT DRAIN WOULD BE USED TO TRANSPORT SURFACE WATER FROM CATCH BASINS INSTALLED BETWEEN PINE
STREET AND BALD EAGLE CREEK. THE STREAMBED BETWEEN THE RAILROAD EMBANKMENT AND PINE STREET WOULD BE COVERED
WITH SOIL. THIS SOIL COVER WILL REDUCE THE RISK OF GROUNDWATER REACHING THE SURFACE IN THIS AREA. A
GRANULAR DRAIN WILL BE INSTALLED ALONG THE TOE OF THE RAILROAD EMBANKMENT IN ORDER TO COLLECT THE SEEPAGE SO
THAT IT DOES NOT APPEAR AS SURFACE RUNOFF. THIS OPTION WILL BE REEVALUATED IN PHASE II TO CONFORM WITH THE
SELECTED ALTERNATIVE FOR THE 82,000 CUBIC YARDS STILL ON-SITE.
THE CONSTRUCTION OF THIS ALTERNATIVE WILL REQUIRE APPROXIMATELY 900 LINEAR FEET OF CONDUIT AND 3,100 CUBIC
YARDS OF GRANULAR MATERIAL. SLIGHTLY MORE THAN 200 CUBIC YARDS OF CONTAMINATED SEDIMENT MUST BE EXCAVATED TO
INSTALL THE CONDUIT PROPERLY. APPROXIMATELY 12,000 CUBIC YARDS OF NATURAL SOILS ARE REQUIRED FOR USE AS A
COVER, AND 1,000 CUBIC YARDS OF GRANULAR MATERIAL WILL BE NECESSARY FOR THE GRAVEL BED.
DISPOSAL ALTERNATIVES:
1. TEMPORARY ON-SITE DISPOSAL
THIS ALTERNATIVE PROVIDES FOR THE CONSTRUCTION OF A TEMPORARY ON-SITE HAZARDOUS WASTE DISPOSAL FACILITY.
THIS FACILITY WOULD BE USED FOR THE TEMPORARY DISPOSAL OF CONTAMINATED MATERIALS LOCATED IN THE STREAM. THE
FACILITY WILL BE DESIGNED TO ADEQUATELY CONTROL THE HAZARDOUS WASTE ON A TEMPORARY BASIS UNTIL THE SITE
PROPER IS REMEDIATED IN PHASE II. SUCH A FACILITY WOULD INCLUDE A SINGLE IMPERVIOUS LINER FOR LEACHATE
MIGRATION CONTROL, A COVER TO DECREASE SURFACE RAINFALL INFILTRATION, AND RUNOFF CONTROL SYSTEM. THE
PROPOSED ON-SITE DISPOSAL AREA WILL BE DESIGNED TO CONTAIN THE WASTES FROM CONTAMINATED SOIL EXCAVATION AND
FROM THE SURFACE DEBRIS.
THE ON-SITE FACILITY WILL BE DESIGNED TO ADEQUATELY CONTROL THE SEDIMENTS UNTIL THE METHOD OF ULTIMATE
DISPOSAL, DETERMINED DURING PHASE II, IS IMPLEMENTED.
2. OFF-SITE DISPOSAL
OFF-SITE DISPOSAL INVOLVES LOADING EXCAVATED SOILS ONTO TRUCKS AND TRANSPORTING THIS MATERIAL TO A SECURE
WASTE DISPOSAL FACILITY. THESE WASTES ARE DEFINED AS HAZARDOUS WASTE; THUS ADEQUATE SHIPMENT AND DISPOSAL
PRECAUTIONS WILL BE REQUIRED. THE SOILS AND DEBRIS WILL BE TRANSPORTED USING 20-TON DUMP TRUCKS.
MANIFESTS WILL BE REQUIRED FOR THE TRANSPORTATION OF HAZARDOUS WASTES. OTHER PERMITS OR PERMISSIONS THAT MAY
BE CONSIDERED INCLUDE POSSIBLE LOCAL REQUIREMENTS AND SITE ACCESS (FROM OWNERS).
COSTS:
THE COSTS OF EACH ALTERNATIVE HAVE BEEN ESTIMATED BASED ON CONSTRUCTION RATES AND TREATMENT PRICES
CHARACTERISTIC OF THE AREA. A TOTAL COST IS GIVEN FOR EACH ALTERNATIVE, ALONG WITH A BREAKDOWN OF CAPITAL
VERSUS OPERATION AND MAINTENANCE (O&M) COSTS (SEE THE ALTERNATIVES MATRIX).
-------
#CR
COMMUNITY RELATIONS
THE DRAFT FEASIBILITY STUDY WAS MADE AVAILABLE FOR PUBLIC COMMENT BETWEEN AUGUST 21 AND SEPTEMBER 11, 1984.
COPIES OF THE DOCUMENT WERE PLACED IN REPOSITORIES IN THE LOCK HAVEN AREA. A NOTICE WAS PLACED IN THE LOCAL
NEWSPAPER REGARDING THE AVAILABILITY OF THE FEASIBILITY STUDY REPORT FOR PUBLIC REVIEW, AND TO ANNOUNCE THAT
A PUBLIC MEETING WAS SCHEDULED FOR SEPTEMBER 6, 1984. THE MEETING WAS HELD AT LOCK HAVEN UNIVERSITY ULMER
PLANETARIUM AND WAS ATTENDED BY REPRESENTATIVES OF EPA, THE PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL
RESOURCES, THE NUS CORPORATION, THE CITY OF LOCK HAVEN, THE COUNTY OF CLINTON, THE PENNSYLVANIA HEALTH
DEPARTMENT, CITIZENS AND LABORERS FOR ENVIRONMENTAL ACTION NOW (CLEAN), AND LOCAL CONCERNED CITIZENS.
FOR THE MOST PART, COMMENTS RECEIVED FROM THE PUBLIC AT THE MEETING WERE OF A GENERAL NATURE. SOME QUESTIONS
WERE RAISED OVER THE ACTUAL STARTING DATE OF CONSTRUCTION OF PHASE I AND THE TIMING OF THE PHASE II PORTION
OF THE PROJECT. MEETINGS WERE HELD BEFORE THE PUBLIC MEETING WITH TOWNSHIP AND COUNTY OFFICIALS, AND THE
LOCAL CITIZENS GROUP (CLEAN) WAS BRIEFED ON THE REMEDIAL ALTERNATIVES. THE CITIZENS GROUP STRONGLY
RECOMMENDED AN ALTERNATIVE THAT PROVIDES FOR AS LITTLE SOIL AND SEDIMENT REMOVAL AS POSSIBLE BUT STILL
PROVIDED FOR ADEQUATE PROTECTION OF THE PUBLIC FROM A DIRECT CONTACT THREAT. COMMENTS AND QUESTIONS FROM
THESE MEETINGS ALONG WITH ALL OTHER COMMENTS ARE ATTACHED AS PART OF THE RESPONSIVENESS SUMMARY FOUND
ATTACHED TO THIS DOCUMENT.
#RA
RECOMMENDED ALTERNATIVE
SECTION 300.68(J) OF THE NATIONAL CONTINGENCY PLAN (NCP) (47 FR 31180; JULY 16, 1982) STATES THAT THE
APPROPRIATE EXTENT OF REMEDY SHALL BE DETERMINED BY THE LEAD AGENCY'S SELECTION OF THE REMEDIAL ALTERNATIVE
WHICH THE AGENCY DETERMINES IS COST-EFFECTIVE (I.E. THE LOWEST COST ALTERNATIVE THAT IS TECHNICALLY FEASIBLE
AND RELIABLE) AND WHICH EFFECTIVELY MITIGATES AND MINIMIZES DAMAGE TO AND PROVIDES ADEQUATE PROTECTION OF
PUBLIC HEALTH, WELFARE AND THE ENVIRONMENT. BASED ON OUR EVALUATION OF THE COST-EFFECTIVENESS OF EACH OF THE
PROPOSED ALTERNATIVES, THE COMMENTS RECEIVED FROM THE PUBLIC, INFORMATION FROM THE FEASIBILITY STUDY AND
INFORMATION FROM THE PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES, WE RECOMMEND THAT THE "COVER STREAM
- PROVIDE FOR SURFACE WATER DRAINAGE" ALTERNATIVE COMBINED WITH THE "TEMPORARY ON-SITE DISPOSAL" ALTERNATIVE
BE IMPLEMENTED. THIS ALTERNATIVE INCLUDES: COVERING THE UPPER REACH OF THE LEACHATE STREAM WITH SOIL TO THE
CONTOURS OF THE SURROUNDING LAND; PLACING A CONDUIT IN THE LOWER REACH OF THE LEACHATE STREAM TO FACILITATE
SURFACE WATER RUNOFF FROM FIELDS AND HIGHWAYS, AND COVERING THE PIPE WITH SOIL; PLACING A FRENCH DRAIN AT THE
TOE OF THE RAILROAD EMBANKMENT TO PREVENT SEEPAGE FROM THE PERCHED WATER TABLE; EXCAVATION OF ONLY ENOUGH
SEDIMENT IN THE LOWER REACH FOR ENGINEERING PURPOSES; TEMPORARY STORAGE OF THIS EXCAVATED SEDIMENT ON THE
DRAKE CHEMICAL SITE IN AN APPROVABLE MANNER.
THE RECOMMENDED ALTERNATIVE IS THE LEAST COST ALTERNATIVE THAT IS TECHNICALLY FEASIBLE AND RELIABLE, AND
WHICH EFFECTIVELY MITIGATES AND MINIMIZES DAMAGE TO AND PROVIDES ADEQUATE PROTECTION OF THE PUBLIC HEALTH,
WELFARE AND THE ENVIRONMENT. THE RECOMMENDED ALTERNATIVE WILL SATISFY ALL THE OBJECTIVES DEVELOPED FOR PHASE
I OF THE DRAKE PROJECT. THE ALTERNATIVE WILL (1) DECREASE THE THREAT TO PUBLIC HEALTH AND SAFETY BY
EFFECTIVELY REMOVING THE DIRECT CONTACT THREAT POSED BY THE LEACHATE STREAM, (2) ALLOW THE CASTANEA PUBLIC
PARK TO RE-OPEN FOR RECREATIONAL USE BY THE PUBLIC, AND (3) BE BOTH TECHNICALLY FEASIBLE AND COST-EFFECTIVE.
IT SHOULD BE EMPHASIZED THAT THE RECOMMENDED ALTERNATIVE MAY PROVE TO BE AN INTERIM MEASURE WHICH ADDRESSES
THE THREAT OF DIRECT CONTACT WITH THE CONTAMINATED SEDIMENTS. THIS ALTERNATIVE CALLS FOR LEAVING IN PLACE
AND COVERING SOME OF THE CONTAMINATED SEDIMENTS, ESPECIALLY IN THE UPPER REACH OF THE LEACHATE STREAM. THE
FINAL SOLUTION FOR THE LEACHATE STREAM AREA WILL BE PRESENTED IN PHASE II WHEN THE ON-SITE CONTAMINATION IS
ADDRESSED. SHOULD RE-EXCAVATION OF THE STREAM CHANNEL BE NECESSARY, THE ADDITIONAL VOLUME INVOLVED WOULD BE
SMALL WHEN COMPARED TO THE VOLUME OF MATERIALS TO BE DEALT WITH IN PHASE II.
ANY CONTAMINATED SEDIMENTS LEFT IN PLACE THAT MAY COME IN CONTACT WITH GROUNDWATER WILL BE OF LITTLE
SIGNIFICANCE AT THIS TIME BECAUSE OF THE ALREADY GROSSLY CONTAMINATED CONDITION OF THE GROUNDWATER IN THE
REGION. BECAUSE OF THIS HIGHLY CONTAMINATED CONDITION OF THE AQUIFER, IT IS DOUBTFUL THAT ANY REMEDIAL
ACTION TAKEN ON THE GROUNDWATER IN THE FUTURE WILL RESTORE THE AQUIFER TO A PRISTINE, POTABLE CONDITION.
HOWEVER, IF GROUNDWATER COULD BE RETURNED TO A POTABLE STATE AND COULD BE USED AS A DRINKING WATER SOURCE IN
THE AREA, IT IS BELIEVED THAT THE SEDIMENT FOR NOW LEFT IN THE LEACHATE STREAM WOULD HAVE A MINOR IMPACT ON
THE REGIONAL GROUNDWATER SCHEME DUE TO THE BINDING NATURE OF THE COMPOUNDS TO THE SOILS AND SEDIMENTS, THE
LOW PERMEABILITY OF THE SOILS ALONG THE STREAMBED, AND THE RELATIVELY INSOLUBLE NATURE OF THE STREAM
CONTAMINANTS. THESE ASSUMPTIONS ARE SUPPORTED EMPIRICALLY BY THE VERY LOW CONCENTRATIONS OF FENAC IN THE
GROUNDWATER IN THE LOWER REACH OF THE LEACHATE STREAM WHERE CONTAMINATION WOULD COME MAINLY FROM
CONTAMINANTS LEACHING FROM THE STREAM SEDIMENTS INTO THE GROUNDWATER. AGAIN, THE QUESTION OF LEAVING
CONTAMINATED SEDIMENTS IN PLACE WILL BE ADDRESSED MORE FULLY IN THE SUBSEQUENT FEASIBILITY STUDIES.
THIS OPTION WOULD ELIMINATE THE RISK OF PUBLIC EXPOSURE TO THE CONTAMINATED SEDIMENTS BY FILLING IN THE
-------
STREAM CHANNEL WITH NATURAL SOILS UP TO THE CONTOURS OF THE SURROUNDING LAND. A CLAY CAP OF THE FILLED
LEACHATE CHANNEL ALONG WITH PROPER GRADING WILL PREVENT RAINFALL INFILTRATION AND REGIONAL SURFACE WATER FLOW
FROM RECREATING THE CHANNEL PATH. WHEN THE DEPRESSIONAL AREA IS REMOVED, THE GROUNDWATER WILL NOT SURFACE
BUT WILL REMAIN IN THE REGIONAL GROUNDWATER FLOW AND EVENTUALLY DISCHARGE, AS ALL GROUNDWATER DOES, INTO BALD
EAGLE CREEK. AGAIN, IT IS EMPHASIZED THAT THERE IS NO PRIVATE OR PUBLIC USE OF THE GROUNDWATER IN THE LOCK
HAVEN AREA. IN ADDITION, ANY FUTURE USE OF THE AQUIFER IS UNLIKELY DUE TO A LOCAL ORDINANCE WHICH REQUIRES
ALL ESTABLISHMENTS TO HOOK UP TO THE LOCK HAVEN WATER SYSTEM FOR THEIR POTABLE NEEDS.
THE GREATEST RISK OF FAILURE IN THIS SYSTEM IS CLOGGING OF THE CONDUIT IN THE LOWER REACH OF THE LEACHATE
STREAM. EVEN IF THIS SHOULD OCCUR, RECONTAMINATION OF THE AREA WILL NOT TAKE PLACE SINCE THE CONDUIT WILL
ONLY HANDLE NON-CONTAMINATED SURFACE WATER.
THE FOLLOWING REGULATIONS WILL BE CONSIDERED DURING THE STREAM REMEDIATION PORTION OF THIS ALTERNATIVE:
REGULATIONS GOVERNING REMEDIAL ACTIONS IN A FLOODPLAIN.
STATE LEACHATE CONTROL REGULATIONS.
STATE STREAM ENCROACHMENT REGULATIONS.
GROUNDWATER MANIPULATION REGULATIONS.
LOCAL HAULING, GRADING, AND RUNOFF PERMITS.
CORPS OF ENGINEERS REGULATIONS REGARDING FILLING OF STREAM CHANNELS.
IN THE DISPOSAL PORTION OF THE RECOMMENDED ALTERNATIVE, THE ON-SITE FACILITY WILL BE DESIGNED TO CONTROL THE
SEDIMENTS ADEQUATELY UNTIL THE METHOD OF ULTIMATE DISPOSAL, DETERMINED DURING PHASE II, IS IMPLEMENTED. THIS
MAY REQUIRE VARIATIONS TO THE REGULATIONS GOVERNING THE STORAGE OF WASTE. THIS IS DETAILED IN THE
"CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS" SECTION OF THIS DOCUMENT.
DEPENDING ON THEIR CAPACITY AND STRUCTURAL INTEGRITY, EXISTING LINED WASTEWATER LAGOONS ALREADY ON THE SITE
MAY BE USED TO STORE THE EXCAVATED SOILS AND SEDIMENTS. THESE LAGOONS WOULD BE MODIFIED TO INCLUDE A COVER TO
DECREASE SURFACE RAINFALL INFILTRATION AND TO PROVIDE FOR A RUNOFF CONTROL SYSTEM.
ANY SOILS PLACED ON-SITE FOR TEMPORARY STORAGE WILL BE ADDRESSED IN THE PHASE II PORTION OF THIS PROJECT.
PHASE II MUST DEVELOP ALTERNATIVES WHICH WILL ADDRESS AN ESTIMATED 82,000 CUBIC YARDS OF CONTAMINATED SOILS
AND SLUDGES THAT EXIST ON-SITE. SINCE THE PHASE I SEDIMENTS WILL TOTAL APPROXIMATELY 300 CUBIC YARDS, THE
TECHNICAL AND COST CONTROL EFFECT OF TEMPORARY STORAGE IS BARELY SIGNIFICANT. ANOTHER ADVANTAGE TO ADDRESSING
THE SOIL CONTAMINANTS IN PHASE II IS THAT IT PROVIDES FOR A CONSISTENT APPROACH TO REMEDIATION OF ALL
CONTAMINATED SOILS, SEDIMENTS OR SLUDGES FOR BOTH PHASE I AND PHASE II.
ALTERNATIVES NOT SELECTED
THE "EXCAVATE SEDIMENTS - REPLACE WITH AN IMPERMEABLE LINER" ALTERNATIVE APPEARS TO BE LOWER IN COST;
HOWEVER, COUPLED WITH THE DISPOSAL OPTION FOR TOTAL SEDIMENTS, THE COST FOR THIS ALTERNATIVE IS ESTIMATED AT
$2,650,000. ADDITIONALLY, FAILURE OF THE CHANNEL LINING BY NATURAL OR MECHANICAL REASONS WILL RESULT IN A
RECONTAMINATION OF THE STREAM CHANNEL THROUGH INFLUX OF CONTAMINATED GROUND WATER.
THE "GRANULAR DRAIN" OPTION COST ALSO APPEARS LOWER WHEN ISOLATED AS A STREAM REMEDIATION ALTERNATIVE.
HOWEVER, THIS OPTION WOULD REQUIRE A GREATER VOLUME OF EXCAVATED MATERIALS (7500 CUBIC YARDS AS OPPOSED TO
300 CUBIC YARDS FOR THE RECOMMENDED ALTERNATIVE) WHICH WILL INCREASE THE DISPOSAL COSTS. IN ADDITION, THIS
ALTERNATIVE HAS THE GREATEST CHANCE FOR FAILURE DUE TO CLOGGING OF THE GRANULAR MATERIAL. THIS OPTION WILL
NOT REDUCE THE FLOW OF CONTAMINATED GROUNDWATER INTO BALD EAGLE CREEK.
AS WITH THE GRANULAR DRAIN OPTION, THE CONDUIT DRAIN WOULD REQUIRE ADDITIONAL EXCAVATION OF CONTAMINATED
MATERIALS. ANY FAILURE OF THE DRAINAGE SYSTEM, BY CLOGGING OF THE CONDUIT, WILL RESULT IN BACK-UP OF
CONTAMINATED WATER AT THE INLETS TO THE SYSTEM.
THERE IS A LOWER RISK TO THE LOCAL COMMUNITY ASSOCIATED WITH THE OFF-SITE DISPOSAL OPTION AS COMPARED TO
TEMPORARY ON-SITE DISPOSAL, PROVIDED THAT THE CONTAMINATED MATERIAL IS PROPERLY LOADED ONTO THE HAULING
TRUCKS. IN THE EVENT THAT SOME HAZARDOUS MATERIAL REMAINS OR IS SPILLED DURING LOADING, CONTINUED
ENVIRONMENTAL CONTAMINATION MAY OCCUR. ANOTHER RISK INVOLVES THE LONG-DISTANCE TRANSPORT OF THE MATERIAL.
IN THE EVENT OF A VEHICLE ACCIDENT DURING TRANSPORT, THE HAZARDOUS MATERIAL MAY BE DUMPED ONTO THE GROUND.
OF COURSE, ANOTHER DISADVANTAGE TO THE OFF-SITE DISPOSAL OPTION IS THAT HAZARDOUS WASTE IS NOT CHEMICALLY OR
PHYSICALLY ALTERED, ONLY TRANSFERRED FROM ONE COMMUNITY TO ANOTHER. THE OFF-SITE DISPOSAL OPTION IS ALSO
CONSIDERABLY MORE EXPENSIVE THAN THE ON-SITE DISPOSAL OPTION.
COST OF RECOMMENDED ALTERNATIVE
THE CAPITAL COST OF THE RECOMMENDED STREAM REMEDIATION ALTERNATIVE IS ESTIMATED TO BE $445,311. THE TEMPORARY
ON-SITE DISPOSAL ALTERNATIVE WITH MINIMUM SEDIMENT REMOVAL IS ESTIMATED TO BE $44,014. THE CORPS OF
-------
ENGINEERS' COST FOR OVERSIGHT ON CONSTRUCTION WORK BASED ON 7 OF THE REMEDIAL ACTION COST IS ESTIMATED AT
$34,300. COST OF DESIGN IS ESTIMATED TO BE $75,000. THE TOTAL CONSTRUCTION COST FOR PHASE I IS $523,625 AND
THE TOTAL FOR PHASE I, INCLUDING DESIGN, IS $598,625.
#OEL
CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
SINCE EXCAVATION OF SOME CONTAMINATED MATERIALS IS NECESSARY FOR ALL THE STREAM REMEDIATION ALTERNATIVES
EVALUATED, DISPOSAL ALTERNATIVES MUST BE PART OF THE OVERALL REMEDIAL ACTION. THE OFF-SITE DISPOSAL
ALTERNATIVE WOULD FULLY COMPLY WITH ALL APPLICABLE ENVIRONMENTAL LAWS. ON-SITE ACTIVITIES ARE NOT LEGALLY
REQUIRED TO COMPLY WITH OTHERWISE APPLICABLE ENVIRONMENTAL LAWS, BUT EPA'S POLICY IS TO MEET SUBSTANTIVE
REQUIREMENTS NONETHELESS, WITH LIMITED EXCEPTIONS. THE TEMPORARY ON-SITE STORAGE AREA IS NOT REQUIRED TO
MEET RCRA LANDFILL SPECIFICATIONS BECAUSE IT IS AN INTERIM MEASURE. THE PHASE I EXCAVATED MATERIALS WILL BE
PLACED INTO A SECURE ENVIRONMENT WITH APPROPRIATE SAFEGUARDS, AND THE STORAGE WILL BE TEMPORARY (ADDRESSED IN
PHASE II). THE TEMPORARY STORAGE AREA WILL BE LINED AND CAPPED, AND PROVISIONS WILL BE MADE TO DIVERT
SURFACE RUNOFF AWAY FROM THE CAP. THE INCONSISTENCIES WITH RCRA ARE THAT THE TEMPORARY STORAGE IS ON THE
DRAKE SITE WHICH IS ALSO WITHIN THE 100-YEAR FLOODPLAIN. IN ADDITION, A RCRA MONITORING WELL PLAN WILL NOT
BE USED FOR THIS FACILITY.
THE ON-SITE STORAGE OF CONTAMINANTS WILL BE ADDRESSED WITH OTHER ON-SITE CONTAMINATION WITHIN 6-8 MONTHS
AFTER ITS DISPOSAL. THE PROBABILITY A 100-YEAR FLOOD EVENT OCCURRING DURING THIS INTERVAL IS LESS THAN 1
PERCENT. IN ADDITION, IF A FLOOD EVENT SHOULD OCCUR DURING THIS PERIOD, THE POTENTIAL CONTAMINATION FROM THE
APPROXIMATELY 82,000 CUBIC YARDS OF CHEMICAL SOILS AND SLUDGES ALREADY EXISTING ON-SITE MAKE THE 300
ADDITIONAL CUBIC YARDS TO BE STORED RELATIVELY INSIGNIFICANT. FINALLY, THE STORED SOIL WILL BE ISOLATED BY A
LINER AND CAP SYSTEM, MITIGATING CONCERNS OF EFFECTS FROM FLOODING.
THERE ARE 30 MONITORING WELLS IN THE AREA THAT WERE DRILLED DURING THE REMEDIAL INVESTIGATION. HOWEVER,
THESE WELLS MAY NOT MEET RCRA REGULATORY REQUIREMENTS FOR GROUNDWATER MONITORING AT STORAGE FACILITIES.
SINCE THE GROUNDWATER FLOWING BENEATH THE SITE IS GROSSLY CONTAMINATED IT WOULD BE NEARLY IMPOSSIBLE TO
DETECT LEAKAGE FROM THE STORAGE FACILITY INTO THE AQUIFER.
THIS ALTERNATIVE DOES INCLUDE MANY RCRA REQUIREMENTS SUCH AS: A LINER TO PREVENT LEAKAGE OF CONTAMINANTS; A
SURFACE CAP TO REDUCE RAINWATER INFLUX, AND GRADING AND EXCAVATION TO FACILITATE SURFACE WATER FLOW INTO A
SURFACE WATER DRAINAGE SYSTEM.
IN THE STREAM REMEDIATION ALTERNATIVE, CONTAMINATED SOILS AND SEDIMENTS WILL BE LEFT IN PLACE,
COVERED WITH NATURAL SOILS AND A CLAY CAP, GRADED AND RESEEDED. THE CONCERN HERE IS THAT THE SEDIMENTS WILL
REMAIN WITHIN THE 100 YEAR FLOODPLAIN, ALBEIT POSSIBLY FOR ONLY A SHORT DURATION (LESS THAN 1 YEAR). THIS
OPTION CAN BE REEVALUATED AND, IF NECESSARY, MADE TO CONFORM WITH THE PHASE II DECISION REGARDING THE
REMEDIAL ALTERNATIVE WHICH ADDRESSES THE CONTAMINATED SOILS AND SLUDGES LOCATED ON THE SITE. THE PROPOSED
PHASE I REMEDIAL ACTION WILL NOT ALTER FLOODSTAGES OR SUBSTANTIALLY IMPACT THE FLOODPLAIN, BECAUSE MEASURES
WILL BE TAKEN IN ORDER TO NOT DISRUPT SURFACE RUNOFF IN THE VICINITY OF THE LEACHATE STREAM. A FLOODPLAIN
ASSESSMENT WILL BE CONDUCTED AS PART OF THE FEASIBILITY STUDY FOR PHASE II.
#OM
OPERATION AND MAINTENANCE
THE OPERATION AND MAINTENANCE ASSOCIATED WITH THE RECOMMENDED ALTERNATIVE IS LIMITED TO SEMI-ANNUAL
INSPECTIONS OVER A THIRTY YEAR PERIOD (UNLESS CIRCUMSTANCES ARE CHANGED IN PHASE II). ANY EXCAVATED MATERIAL
WILL BE STORED ON-SITE AND ADDRESSED IN PHASE II AND THEREFORE SUBJECT TO WHATEVER THE OPERATION AND
MAINTENANCE REQUIREMENTS WILL BE FOR THE CHOSEN ALTERNATIVE IN THAT PHASE.
IF THE INTEGRITY OF THE CONSTRUCTION SHOULD DETERIORATE IN THE FUTURE, THE STATE WOULD BE RESPONSIBLE FOR
REPAIRS AND UPKEEP. HOWEVER, OPERATION AND MAINTENANCE COSTS ASSOCIATED WITH THE DRAINAGE SYSTEM AND THE
STREAMBED COVER ARE NOT PRESENTED, SINCE THESE ITEMS CANNOT BE ADEQUATELY ESTIMATED AT THIS TIME.
THE COST FOR PHASE I O&M IS THE PRESENT WORTH OF A VISUAL INSPECTION OF THE AREA ON A SEMI-ANNUAL BASIS FOR
30 YEARS. THE ASSUMPTION IS 10 PERCENT INTEREST AND 0 PERCENT INFLATION OVER THIS PERIOD. THE TOTAL O&M
COSTS FOR THIS ALTERNATIVE IS ESTIMATED TO BE $9,427. IF EPA IS TO PROVIDE FOR THE FIRST SIX MONTHS OF
OPERATION AND MAINTENANCE, THIS WOULD ONLY BE ONE INSPECTION COSTING APPROXIMATELY $200 (UNTIL THE
IMPLEMENTATION OF PHASE II).
-------
#SCH
PROJECT SCHEDULE
APPROVE REMEDIAL ACTION OCTOBER 1, 1984
START DESIGN DECEMBER 1, 1984
COMPLETE DESIGN MARCH 1, 1985
AWARD CONSTRUCTION CONTRACT JUNE 1, 1985
START CONSTRUCTION JUNE 15, 1985
COMPLETE CONSTRUCTION SEPTEMBER 15, 1985.
#FA
PROPOSED ACTION
WE REQUEST YOUR APPROVAL OF THE RECOMMENDED REMEDIAL ALTERNATIVE AS DESCRIBED ABOVE. THIS ACTION WILL
COMPLETE CONSTRUCTION FOR PHASE I OF THE DRAKE SUPERFUND PROJECT. THE ESTIMATED TOTAL COST OF DESIGN AND
CONSTRUCTION FOR THIS FEDERAL LEAD PROJECT IS $600,000.
-------
#TMA
TABLES, MEMORANDA, ATTACHMENTS
#RS
RESPONSIVENESS SUMMARY
DRAKE CHEMICAL FEASIBILITY STUDY
PHASE I/LEACHATE STREAM AREA
THE EPA AND THE PADER HELD THREE MEETINGS ON SEPTEMBER 6, 1984, IN ORDER TO OUTLINE PHASE I OF THE DRAKE
CHEMICAL SITE AND ACCEPT COMMENTS ON THE FEASIBILITY STUDY. ATTENDING THE MEETINGS WERE TOM VOLTAGGIO, BILL
HAGEL, RAY GERMANN AND JOE DONOVAN FROM EPA, RICH NINESTEEL AND ANN CARDINAL FROM NUS, DICK BITTLE AND TONY
CAPUTO FROM DER, AND THE PA. DEPARTMENT OF HEALTH.
MEETING NO. 1 - PUBLIC OFFICIALS BRIEFING AT LOCK HAVEN CITY HALL. ATTENDING THE MEETING WERE LOCK HAVEN
CITY COUNCIL MEMBERS AND THE CITY'S DIRECTOR OF PUBLIC WORKS, CLINTON COUNTY COMMISSIONERS, AND VARIOUS LOCAL
OFFICIALS. THE MEETING BEGAN AT 1 P.M. AND ENDED AT 3 P.M.
CITIZEN CONCERNS AND EPA RESPONSES
CONCERN - NO HEAVY METAL ANALYSES WERE PERFORMED ON FISH TISSUE
IN THE AQUATIC SURVEY. AL HOBERMAN, CITY COUNCILMAN,
WANTED TO KNOW IF WE PLANNED TO DO SO IN THE FUTURE.
RESPONSE - ONLY FENAC WAS ANALYZED IN FISH TISSUE BECAUSE THE
FILLETS WERE TOO SMALL FOR EXTENSIVE ANALYSIS.
FENAC WAS CHOSEN BECAUSE OF ITS ABUNDANCE IN THE
LEACHATE STREAM. FURTHER TESTING IS POSSIBLE, BUT
WILL REQUIRE A FUNDING/SCOPE INCREASE IN THE DRAKE
BUDGET. WE WILL LOOK FURTHER INTO THE MATTER.
CONCERN - RICH ARDNER, DIRECTOR OF PUBLIC WORKS, SAID EPA
SHOULD CONSIDER THE PROPOSED FLOOD CONTROL PROJECT
ON OUR DESIGN OF THE ALTERNATIVE. THE AREA OF THE
LEACHATE STREAM IS A PROPOSED PONDING AREA IN THE
INITIAL PLANS OF THE U.S. ARMY CORPS OF ENGINEERS,
BALTIMORE DISTRICT. THIS ISSUE WAS ALSO RAISED IN A
LETTER FROM ROBERT YOWELL, PROGRAM DIRECTOR FOR THE
FLOOD PROTECTION PLANNING BOARD.
RESPONSE - BECAUSE THE ARMY CORPS OF ENGINEERS WILL BE WORKING
ON BOTH DESIGN PROJECTS, WE WILL RECOMMEND THAT THE
DISTRICT OFFICES COORDINATE ON THE TWO DESIGNS.
GENERAL COMMENTS - THE LOCAL OFFICIALS SEEM TO FAVOR THE "COVER
STREAM", WHICH PROVIDES FOR SURFACE WATER DRAINAGE
WITH TEMPORARY ON-SITE STORAGE.
MEETING NO. 2 - CITIZENS AND LABORERS FOR ENVIRONMENTAL ACTION NOW BRIEFING WAS HELD AT CLEAN
HEADQUARTERS, LOCK HAVEN. ATTENDING THE MEETING WERE FRANK FURL AND CHRIS CLEMENS FROM CLEAN, ALONG WITH FIVE
OTHER CLEAN MEMBERS. THE MEETING BEGAN AT 3 P.M. AND ENDED AT 5:45 P.M.
CITIZEN CONCERNS AND EPA RESPONSES
CONCERN - A QUESTION WAS RAISED BY FRANK FURL, PRESIDENT OF
CLEAN, ON WHETHER THE LEACHATE STREAM WAS A MAN-MADE
STREAM OR A NATURAL STREAM, WHICH WOULD FALL UNDER
THE AUSPICES OF THE PENNSYLVANIA CLEAN STREAMS ACT.
RESPONSE - DICK BITTLE OF PA. DER, WILLIAMSPORT, STATED THAT ALL
INDICATIONS ARE THAT THE STREAM CHANNEL IS MAN-MADE
AND NOT SUBJECT TO ANY PERMITTING.
CONCERN - FURL SAID THAT HE WAS CONCERNED ABOUT THE LOCATION
AND STATUS OF OLD UTILITY PIPES BURIED NEAR THE
LEACHATE STREAM AREA.
-------
RESPONSE - BEFORE ANY CONSTRUCTION BEGINS, MOST LIKELY IN THE
DESIGN PHASE, CITY ENGINEERS WILL BE CONSULTED AS TO
ANY UTILITY PIPES IN THE AREA.
CONCERN - THERE WAS CONCERN ABOUT SLUDGE RUNNING OFF-SITE
DURING HEAVY RAINFALL PERIODS AND IF THIS WOULD BE
ADDRESSED.
RESPONSE - BILL HAGEL STATED THAT THE PHASE II REMEDIAL ACTION
WILL BE FLEXIBLE ENOUGH TO EXTEND BEYOND THE
IMMEDIATE BORDERS OF THE SITE AND ADDRESS ANY RUNOFF.
CONCERN - DICHLOROBENZIDINE WAS FOUND IN ONE SAMPLE UPSTREAM
FROM THE LEACHATE STREAM DISCHARGE INTO BALD EAGLE
CREEK. CHRIS CLEMENS OF CLEAN SAID THAT IT MAY BE
COMING FROM PERIODIC RELEASES FROM AN OLD AC&C
DISCHARGE PIPE IN THAT AREA.
RESPONSE - THE STATE, WHICH IS COORDINATING THE AC&C RCRA
CLOSURE PLAN, WILL INVESTIGATE THIS INCIDENT.
CONCERN - IT WAS CALLED TO OUR ATTENTION THAT A FORMER WASTE
DISPOSAL AREA, NOW COVERED BY ROUTE 220, MAY EXIST
IN THE AREA OF THE LEACHATE STREAM.
RESPONSE - NUS AND THE STATE WILL CONDUCT A RECORD SEARCH TO
FIND EVIDENCE OF THE DISPOSAL AREA, HOWEVER, THIS
WOULD NOT AFFECT REMEDIAL ACTIVITIES IN PHASE I.
CONCERN - CLEAN REQUESTED THAT AN EXPECTED LIFE AND USEFULNESS
OF EACH ALTERNATIVE BE INCLUDED IN THE FEASIBILITY STUDY.
RESPONSE - NUS WILL DO THIS AND IT WILL BE PART OF THE FINAL
FEASIBILITY STUDY.
CONCERN - CLEAN RECOMMENDED THAT THE ENTIRE AREA BETWEEN THE
RAILROAD EMBANKMENT AND ROUTE 220 BE FILLED IN AND
REGRADED TO PREVENT FLOODING IN THAT AREA.
RESPONSE - THIS ACTION WOULD BE BEYOND THE SCOPE OF PHASE I.
THE AREA IN QUESTION IS A NATURALLY SWAMPY AREA AND
IT IS FELT THAT DURING HIGH WATER SITUATIONS SOME
PONDING WILL OCCUR. REGRADING OF THIS AREA WILL
JUST RELOCATE THE PONDING, PROBABLY IN THE HAMMERMILL
BALLFIELD AREA. SINCE PONDING IS FROM GROUNDWATER
SURFACING, THIS WILL BE ADDRESSED IN THE PHASE III
PORTION OF THE DRAKE PROJECT.
CONCERN - CLEAN SUGGESTED THAT IF TEMPORARY STORAGE IS
IMPLEMENTED, WE SHOULD CONSIDER USING THE EXISTING
LINED WASTEWATER LAGOONS ON THE DRAKE SITE IN LIEU
OF CREATING A NEW STORAGE FACILITY.
RESPONSE - NUS WILL CHECK THE STORAGE CAPACITY OF THE LAGOONS
AND THEIR STRUCTURAL INTEGRITY. THIS SUGGESTION
WILL BE EXPLORED FURTHER IN THE CONCEPTUAL DESIGN.
CONCERN - THERE WAS SOME CONFUSION OVER THE NATURE OF
GROUNDWATER FLOW IN THE AREA.
RESPONSE - BILL HAGEL DREW A DIAGRAM SHOWING THE NATURAL FLOW
AS N.E., TOWARD THE WEST BRANCH OF THE SUSQUEHANNA,
AND SOME VARIATIONS NEAR A PERCHED WATER TABLE IN
THE LEACHATE LAGOON. CLEAN SAID THAT THE EXPLANATION
COINCIDED WITH THEIR IDEAS ON GROUNDWATER MOVEMENT.
CONCERN - CLEAN WAS CONCERNED ABOUT SEVERAL INCONCLUSIVE
-------
SAMPLES RETURNED FROM EPA LAB CONTRACTOR. FRANK FURL
QUESTIONED HOW EPA CAN FORMULATE A FEASIBILITY STUDY
WITHOUT "COMPLETE DATA".
RESPONSE - BILL HAGEL AND RICH NINESTEEL EXPLAINED THAT SUCH
SAMPLES ARE NOT REANALYZED BECAUSE PREVIOUSLY
GATHERED DATA ALONG WITH QUALITY ASSURED SAMPLES
FROM THE PHASE I REMEDIAL INVESTIGATION PROVIDED
ENOUGH INFORMATION TO FORMULATE REMEDIAL ALTERNATIVES.
MEETING NO. 3 - THE FOURTH PUBLIC MEETING ON REMEDIAL MEASURES AT SITE. THE MEETING WAS HELD AT ULMER
PLANETARIUM, LOCK HAVEN UNIVERSITY, BEGINNING AT 7:15 P.M. AND ENDING AT 8:20 P.M. APPROXIMATELY 26 PEOPLE
ATTENDED THE MEETING INCLUDING EPA, DER, AND NUS. MEDIA COVERAGE INCLUDED 2 NEWSPAPERS, 1 TELEVISION STATION
AND 2 RADIO STATIONS.
CITIZENS CONCERNS AND EPA RESPONSES
CONCERN - QUESTIONS FROM THE PUBLIC MEETING WERE NOT MAJOR.
THEY INCLUDED TIMETABLE INFORMATION; START-UP OF
PHASE I (ACTUAL CONSTRUCTION); RELEASE OF THE PHASE
II REPORT AND THE POSSIBILITY THAT WE WILL BE MOVING
SEDIMENT FROM THE LEACHATE STREAM TWICE, ONCE DURING
PHASE I AND ONCE DURING PHASE II.
RESPONSE - ALL SCHEDULING INFORMATION GIVEN. IT IS POSSIBLE
THAT WE WILL BE MOVING SOIL TWICE BUT WHEN YOU
CONSIDER ON-SITE VOLUME OF 82,000 CUBIC YARDS, THE
300 CUBIC YARDS FOR PHASE I BECOMES INSIGNIFICANT.
DEALING WITH ALL THE SEDIMENT IN PHASE II ALSO
PROVIDES FOR A MORE CONSISTENT APPROACH TO
CONTAMINATED SEDIMENT REMEDIATION OVER THE ENTIRE PROJECT.
-------
TABLE 2
SEDIMENT CONTAMINANTS
LEACHATE STREAM
DRAKE CHEMICAL SITE
ORGANICS
UG/L
INORGANICS
UG/L
FENAC
ACENAPHTHYLENE
ANTHRACENE
BENZO(A)ANTHRACENE
BENZO(K)FLUORANTHENE
BIS(2-ETHYLHEXYL)PHTHALATE
BUTYL BENZYL PHTHALATE
CHRYSENE
DIETHYL PHTHALATE
DI-N-BUTYL PHTHALATE
DI-N-OCTYL PHTHALATE
FLUORANTHENE
INDENOd, 2, 3-CD) PYRENE
N-NITROSODIPHENYLAMINE
PHENANTHRENE
PYRENE
PENTACHLOROPHENOL
1,1,1-TRICHLOROETHANE
PCB-1242
2,
9,
LT
140
6
24
150
550
600
310
180
280
700
130
158
25
41
120
150
211
38
25
ALUMINUM
ARSENIC
BARIUM
BERYLLIUM
CADMIUM
CHROMIUM
COBALT
COPPER
IRON
LEAD
MANGANESE
MERCURY
NICKEL
TIN
VANADIUM
ZINC
25, 800
12.3
182
5.59
0.84
57.8
38.0
212
43, 100
71.6
627
0. 109
100
LT 13
60.0
712
LT - DENOTES LESS THAN.
-------
TABLE 3
CRITICAL COMPOUNDS DETECTED IN DRAKE
CHEMICAL SITE LEACHATE STREAM AREA (OFFSITE)
COMPOUND
MEDIA
CONCENTRATION RANGE
FENAC
GROUNDWATER
SUBSURFACE SOILS
SURFACE SOILS
SURFACE WATER
SEDIMENTS
SEDIMENTS (EOC)
SURFACE WATER (EOC)
SURFACE SOILS
ND-389 UG/LITER
LT 10 -- 2,100 UG/KG
LT 10 UG/KG (ALL SAMPLES)
ND -- 7 UG/LITER
ND -- 2,140 UG/KG
60 -- 13,000 UG/KG
ND -- 2, 080 UG/LITER
ND -- 810 UG/KG
ARSENIC
GROUNDWATER
SUBSURFACE SOILS
SURFACE SOILS
SURFACE WATER
SEDIMENTS
19 -- 2, 880 UG/LITER
5 MG/KG (ONE SAMPLE)
10 MG/KG (ONE SAMPLE)
LT 10 UG/LITER (ALL SAMPLES)
5.44 -- 14.0 MG/KG
DICHLOROBENZENE(TOTAL)
SURFACE WATER ND
SEDIMENTS ND
SURFACE SOILS (EOC) ND
SEDIMENTS (EOC) ND
(ALL SAMPLES)
-- 420 UG/KG (C)
-- 1,320 UG/KG
-- 18,100 U/KG
PENTACHLOROPHENOL
GROUNDWATER
SEDIMENTS
SUBSURFACE SOIL
ND (ALL SAMPLES)
ND -- 211 UG/KG
ND -- 4,400 UG/KG
ND = NOT DETECTED
C = CORRECTED FOR LAB BLANK
EOC = DATA FROM ERT MARCH 1982 EXTENT OF CONTAMINATION SURVEY
LT = LESS THAN.
------- |