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Drake Chemical

Fact Sheet: January 1996

THIS FACT SHEET PRESENTS

Any questions or comments regarding the information presented in this fact sheet should be addressed to Vance Evans, the EPA Community Involvement Coordinator. Mr. Evans' mailing address, telephone number, and e-mail address are listed on page 4 of this fact sheet.

On November 15, 1995, Lock Haven University sponsored a formal debate between the U.S. Environmental Protection Agency (EPA) and Arrest the Incinerator Remediation (AIR). The purpose of the debate was to discuss the proposed incinerator to be built at the Drake Chemical Site to destroy hazardous wastes on the site. Roy Schrock, the site's remedial project manager (RPM), and Leo Mullin, the site's civil investigator, represented EPA. Bill and Vicki Smedley represented AIR. Despite bad weather, approximately 280 people, including students and area residents, attended the meeting. The meeting began at 8:00 p.m. in Price Hall, an auditorium located on the campus of Lock Haven University.

The debate followed strict rules of conduct and procedure. Both sides alternately were allowed to present their viewpoints for seven minutes each, followed by a three-minute question and answer session. Following the debate, the audience participated in a one- hour question and answer period. Microphones were placed in the two aisles located in front of the teams. Audience members with questions lined up at the microphone situated near the parties to which their questions were directed.

AIR discussed five major points: human health effects, economic impacts, distrust of EPA, "violation of safety standards," and EPA's violation of its moral charge to protect human health.

EPA presented information about incineration designed to help the audience develop an informed opinion. EPA covered: 1) why incineration is the most appropriate remedy for this site, 2) site history and conditions at the site, 3) contamination present, and 4) particulars about the incinerator (e.g., the trial and risk burns).

Audience members asked questions of both EPA and AIR concerning topics discussed. Many of the questions focused on alternative clean-up methods, air inversion, and releases from the incinerator. During the question and answer period it became apparent (after taking obvious legitimate concerns into account) that a good portion of the audience would favor a safely operating incinerator to clean up the Drake Chemical Site over not cleaning up the existing contamination at the site. Following is a summary of the main questions and responses.

SUMMARY OF QUESTION AND ANSWER SESSION

ALTERNATIVE REMEDIES

What clean-up alternatives is AIR proposing should be used at the site?

AIR: AIR members are not technical experts. EPA, the experts, should determine the safest clean-up method for the site. However, AIR proposes that EPA conduct a new feasibility study to determine the best alternatives for removing the contamination.

Why is AIR advocating that citizens wait for a new technology, when there is no significant research or data available regarding these technologies, and yet contesting the use of incineration on the grounds that there is not enough data to prove its effectiveness?

AIR: AIR believes that EPA should conduct a new feasibility study and re-examine alternative technologies. Several of the new clean-up methods that EPA looked at in its original feasibility study are being used in other locations in the country.

Why can't bioremediation be used as a clean-up method for the site?

EPA: Bioremediation is not an acceptable clean-up method for the Drake Chemical Site for the following three reasons:

Because of these reasons, EPA has determined that bioremediation could not achieve a safe level of protection for the Lock Haven community.

What would happen to the chemicals used in the soil washing alternative proposed as a possible clean-up method by AIR?

AIR: In this alternative, soil is forced through a filter and cleaned. The contaminants remain in the filter which then must be incinerated at another location or disposed in a certified hazardous waste landfill. AIR stated that the soil washing alternative has undesirable aspects and that there is no ideal solution to the soil contamination problems at the site.

THERMAL AIR INVERSIONS

Do thermal air inversions in Lock Haven affect incineration? If they do, why didn't EPA consider them in its 1988 record of decision (ROD) formally selecting incineration as the clean-up method for the site?

EPA: EPA did modeling to assess the worst case weather conditions and a risk assessment of emission concentrations in 1991 before developing the bid specifications for the cleanup. When in full production, EPA will install a new modeling system to determine the inversion parameters. EPA will use this information to determine the concentration of particles released from the incinerator and other sources. If EPA finds a significant increase in the concentration of contaminants in the air while incineration and air inversions are happening simultaneously, EPA will stop incineration. EPA will resume incineration only when the inversions have passed.

THERMAL RELIEF VENT (TRV)

How can EPA assure the community that the TRV will not release material into the atmosphere if a power failure occurs?

EPA: Opening the TRV during a power failure will cause the incinerator to shut down. All materials have been treated by the time they have reached the TRV and are safe to be discharged into the air. The automatic shutdown will prevent any new soil from being added to the incinerator. The incinerator will remain shut down until back-up power sources take over or the main power source is restored.

EMERGENCY SITUATIONS

How long would it take for the community to be made aware of a possible emergency situation at the site? How would the community be evacuated or notified to take safety precautions if necessary?

EPA: If an emergency situation were to occur at the site, the on-site contractors would immediately notify the Clinton County Emergency Planning Commission, fire departments, police, and other town offices as necessary. If evacuation or some other measure were required, the town of Lock Haven would follow the procedures outlined in the County Emergency Plan.

MONITORING SITE ACTIVITIES

Who will be in charge of monitoring EPA, EPA's contractor, and the Army Corps of Engineers, who will be performing the work at the site?

EPA: EPA has hired an oversight contractor for the Drake Chemical Site. This contractor, who is paid by EPA, will perform additional oversight activities, including working with the community Technical Assistance Grant (TAG) representatives. This contractor will ensure that all clean-up activities are conducted according to current environmental guidance and policy and that all operations related to the incinerator are carried out properly and safely. The oversight contractor also will work with the contractor hired through the community's TAG to review and monitor ongoing work at the site.

MISCELLANEOUS

Since Lock Haven is economically depressed, if the incinerator was commercial, bringing jobs and money to the town, would this debate still be held?

AIR: AIR believes that the Lock Haven community would respond to any incinerator being placed in their community. Other groups have opposed commercial incinerators in their communities. For example, a community group in Allenwood fought for four years to halt the construction of a commercial incinerator.

RISK ASSESSMENT RESULTS

Direct Risk Assessment

Roy F. Weston, Inc. prepared the Draft Drake Chemical Incinerator Risk Assessment, also called the direct risk assessment, to assess possible risks associated with breathing in emissions from the Drake Chemical Incinerator during the two-month trial burn period. The risk assessment evaluated risks to hypothetical adults and children to determine the possible harmful affects to local residents.

The results indicate that there are no harmful health impacts associated with breathing in emissions from the incinerator during the trial burn for either children or adults. The carcinogenic (cancer-causing) risk for both children and adults is less than one in one million, which is the low end of EPA's acceptable risk range. The noncarcinogenic risk for both children and adults is well below EPA's level of concern. EPA determined that the potential blood lead levels in children are below 10 micrograms per deciliter, the level established by the Centers for Disease Control (CDC) as protective of human health. Also, the predicted air concentrations due to incinerator emissions during the trial burn were below the National Ambient Air Quality Standards (NAAQS).

Indirect Risk Assessment

Roy F. Weston, Inc. also conducted the Screening Level Risk Assessment for Proposed Trial Burn at Drake Chemical Superfund Site also called the indirect risk assessment. This assessment focused on possible indirect exposures (i.e., not direct inhalation) to emissions released during the trial burn.

The indirect risk assessment evaluated five possible scenarios: a subsistence farmer, a child of a subsistence farmer, a subsistence fisher, a nearby resident, and a child of a nearby resident. The subject of each scenario was assumed to be exposed to contaminants from the incinerator through eating above ground vegetables, incidental eating of soil, drinking water, and skin contact with soil and with water while bathing. In addition, the subsistance farmer and child were assumed to eat contaminated beef and milk, the subsistance fisher was assumed to eat contaminated fish, and the child of the resident and the subsistence farmer were assumed to eat contaminated snow. The results demonstrated that both carcinogenic and noncarcinogenic risks were within EPA's acceptable range.

NEW INFORMATION REPOSITORY

CH2M Hill, EPA's oversight contractor, is staffing a new information repository at:

226 East Water Street (second floor)
Lock Haven, Pennsylvania

For more information, please call Roni Warren at 717-748- 2727.

REMEMBER!

CALL OR WRITE EPA WITH COMMENTS ON THE RISK ASSESSMENTS BY JANUARY 25, 1996.

If you have questions or comments or would like to know more about the Drake Chemical Site, please contact Vance Evans at the number or address below.

Vance Evans (3EA30)
U.S. EPA, Region III
1650 Arch St.
Philadelphia, PA 19103-2029
215-814-5526
800-553-2509
evans.vance@epa.gov

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