EPA/ROD/R03-84/002
                                    1984
EPA Superfund
     Record of Decision:
     DRAKE CHEMICAL
     EPA ID: PAD003058047
     OU01
     LOCK HAVEN, PA
     09/30/1984

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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.

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                                        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.

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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

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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

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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

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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.

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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

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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).

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#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

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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

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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).

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#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.

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#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.

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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

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                   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.

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                             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.

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                            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.

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