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Drake Chemical

Fact Sheet: July 1995

EPA Issues an Explanation of Significant Differences

In June 1995, U.S. EPA Region III issued an Explanation of Significant Differences (ESD). The ESD describes changes that EPA has made to the document that details the remedy for the ground water contamination at the Drake Superfund Site.

EPA announced the completion of the ESD and summarized the changes in a public notice in the Lock Haven Express. Following is more detailed information about the ESD.

The Record of Decision

On September 25, 1988, EPA released a document called a Record of Decision (ROD). A ROD is a legal document that summarizes problems at a site, analyzes methods to address those problems, documents the process EPA used to choose one method as the remedy, and describes the selected remedy. The ROD issued in 1988 explained the remedy EPA had selected to clean up the contaminated ground water at the Drake Chemical Site. This was the third ROD for the Drake site.

What changes are being made to the ROD?

Changes to the ROD are listed in the shaded paragraphs at right.

What is the impact of these changes on the ground water remedy?

The changes do not alter the basics of the ground water remedy. The resulting cleanup will achieve the same level of decontamination in the ground water and will not affect the estimated cost.

CORRECTION: The June fact sheet mistakenly stated that EPA's chosen remedy for Drake included disposing of the ash from the temporary incinerator off-site. The remedy actually includes on-site disposal of the ash.

CHANGES TO THE ROD

Elimination of a Biological Treatment
The first change to the ROD replaces the biological activated carbon system for treating the ground water and replaces it with a system that uses granular activated carbon adsorption to remove contaminants. This system works much like a household water purifier that is attached to a kitchen tap.
Elimination of Extraction Wells in Zone 1
Because the soil, sludge, and sediment cleanups are not happening at the same time as the ground water cleanup as originally anticipated, EPA had to make some adjustments to the remedy. If extraction wells were placed in Zone 1 as required by the ROD, they would interfere with the soil cleanup. So EPA is eliminating this requirement. Instead, ground water in Zone 1 will be captured by the well system in Zone 2.
Disposal of Ground Water Treatment Residuals
Due to the timing of the soil and ground water cleanups, the ground water treatment residuals (contaminants removed from the ground water) will not be incinerated and backfilled at the site. EPA and the PennsylvaniaDepartment of Environmental Protection (formerly PADER) will determine how the residuals will be disposed during the ground water design phase.
Elimination of Control Measures
The ROD required flood control measures because the site was located within the 100-year flood plain. In 1995, the Army Corps of Engineers completed a flood control project for Lock Haven that makes the flood control measures unnecessary.
Discussion of Ground Water in Zone 3
The ROD did not discuss the installation of extraction wells in Zone 3. The ESD states that EPA will design the extraction well network to prevent further flow of contamination to Zone 3. EPA expects the water quality in Zone 3 to improve naturally, over time, due to the flushing effects of ground water through the aquifer.
Definition of On-Site
At this time, the ground water cleanup for the Drake site is expected to occur at the same time as the ground water cleanup at the nearby AC&C facility. If the ground water treatment facility is located on the AC&C property, it will be considered on-site at Drake for CERCLA purposes only.
Establishment of Performance Standards and Alternative Performance Standards
The ESD establishes concentration levels for benzene, 1,2-dichloroethane, and beta-naphthylamine. When these concentrations are reached during ground water extraction and treatment activities in Zone 2, treatment activities will stop and EPA will continue ground water monitoring in Zones 2 and 3. The ESD details the procedures for stopping treatment and conducting monitoring.
Invocation of Technical Impracticability Waiver
If hydrogeological and chemical evidence demonstrate that it will not be possible to meet Performance and/or Alternative Performance Standards, EPA may consider a waiver to revise the standards. The ESD details the criteria that EPA must follow when considering such a waiver.

LOOK FOR MORE SITE ACTIVITY UPDATES IN THE AUGUST FACT SHEET.

Keeping You Informed

Information Repositories

Copies of fact sheets, legal documents (such as the ROD and ESD), and other information relevant to the Drake Chemical Site are available for review at the following locations:

Lock Haven City Hall
20 East Church Street
717-893-5910

Ross Public Library
232 West Main Street
717-748-3321

Stevenson Library
Lock Haven University
717-893-2309

EPA Contacts

If you have questions or comments about the Drake Chemical Site, please contact:

Community Involvement Coordinator
Vance Evans (3EA30)
U.S. Environmental Protection Agency
1650 Arch St.
Philadelphia, PA 19103-2029
800-553-2509
evans.vance@epa.gov

Remedial Project Manager
Roy Schrock (3HW22)
U.S. Environmental Protection Agency
1650 Arch St.
Philadelphia, PA 19103-2029
215-814-3210
schrock.roy@epa.gov

Region 3 | Mid-Atlantic Cleanup | Mid-Atlantic Superfund |EPA Home | EPA Superfund Homepage


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