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Drake Chemical

Fact Sheet: September 1996

EPA to Resume the Incinerator Trial Burn

The U.S. Environmental Protection Agency (EPA) learned on August 14, 1996 that U.S. District Court Judge Malcolm Muir dismissed the complaint filed against the Agency on February 1, 1996 by the Clinton County Commissioners and Arrest the Incinerator Remediation (AIR). The suit sought to halt the trial burn at the Drake Chemical Company Superfund Site.

EPA will, as, promised, hold a public meeting prior to the beginning of the incinerator trial burn. EPA will explain the trial burn Risk Assessment and answer any questions from the public. Additionally, the National Ombudsman will be present, along with EPA technical personnel and senior management.

On Thursday, September 19, 1996, EPA will hold the public meeting for the Drake Chemical Site. The meeting will begin at 7:00 p.m. at the Ulmer Planetarium on the Lock Haven University campus.


The purpose of this fact sheet is to explain EPA's decision to proceed with the trial burn process for the rotary kiln incinerator constructed to treat the contaminated soil, sludge, and sediments at the Drake Chemical Superfund Site.

Background Information

The Drake Chemical Site is an inactive chemical manufacturing facility that operated from the 1940s through 1982. The Drake Chemical Company manufactured chemicals and intermediates used in the dye, cosmetic, textile, pharmaceutical, and pesticide industries. The materials made and/or used at the facility include hazardous substances, such as aniline, toluene, and xylene, and carcinogenic compounds, such as benzene and beta-naphthylamine.

The site contains a wide variety of contaminants. Contaminants distributed throughout the soil at the Drake Chemical Site include volatile and semi-volatile organic compounds, base/neutral acid extractables, and herbicides. The uniformity of contamination, the presence of complex chemical mixtures, and the public's desire that the site be available for reuse were key factors in EPA's decision to incinerate all site soils. EPA issued the decision to incinerate in the September 29, 1988, Record of Decision (ROD).

In September 1993, following extensive design, testing, and review of numerous proposals, EPA awarded an incineration contract. The features of the contract include:

Since the contract was awarded, the incinerator project has undergone a rigorous development process to ensure that it will remediate the site soils effectively and operate safely. EPA ensures that the incinerator project must either meet or surpass environmental standards established by the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), the National Contingency Plan (NCP), EPA and Pennsylvania hazardous waste incinerator regulations, and Pennsylvania air quality regulations.

The next step in the incineration project is the trial burn process. During this process, EPA will feed site soils into the incinerator for the first time. EPA will test stack emissions to verify that the incinerator destroys specified organic hazardous substances described in the incinerator design standards. In addition, EPA will conduct a "risk burn" to generate data about stack emissions, including dioxins and products of incomplete combustion ("PICs"). EPA will use this data to evaluate the risks during full incinerator operation.

Prior to conducting the trial burn, EPA must determine that the trial burn will not threaten human health or the environment. Normally, EPA bases this determination on whether or not the facility will be able to comply with regulatory standards. However, EPA agreed to conduct a Risk Assessment for the trial burn at the request of the public.

The December 1995 Trial Burn Risk Assessments

On December 8, 1995, EPA released a draft Direct Risk Assessment which evaluated the potential inhalation effects of emissions from the trial burn process. The draft Indirect Risk Assessment followed on December 22, 1995. This report evaluated the potential effects of emissions from the trial burn process on the local food chain. Both Risk Assessments were initial screening level risk assessments based on estimated stack emissions and air dispersion modeling.

EPA invited public comments and held a public meeting on January 23, 1996, to answer questions about the Risk Assessments. The comment period ended January 26, 1996. After responding to written comments, EPA directed the contractor to proceed with the trial burn.

Temporary Restraining Order and Preliminary Injunction Hearing

On February 1, 1996, a group of individuals opposed to incinerators, named Arrest the Incinerator Remediation, Inc. (AIR) and the Clinton County Commissioners filed a law suit and a motion against EPA. The law suit requested the Federal court in Williamsport, Pennsylvania, to issue a temporary restraining order immediately to halt the trial burn process at the Drake Site. For reasons unrelated to the case, EPA decided to postpone the start of the trial burn for several weeks. Subsequently, the court withdrew the motion against EPA.

The Federal court held a hearing from March 5, 1996, through March 8, 1996, to address the plaintiffs' remaining motion to halt the trial burn process. At that time, EPA notified the court that the Agency had decided to further delay the trial burn process and reevaluate the December 1995 Risk Assessments due to public concerns and an internal Agency review. On June 21, 1996, EPA issued a new Risk Assessment which was filed with the court and placed in the information repositories for the site.

On August 14, 1996, the United States District Court dismissed the complaint and the lawsuit. The dismissal enables EPA to resume clean-up efforts at the site. On September 19, 1996, EPA will hold a public meeting, as promised to the public, prior to beginning the incinerator trial burn. At the meeting, EPA will explain the June 1996 Integrated Risk Assessment and answer any questions from the public. Additionally, Robert J. Martin, the National Ombudsman, will be present at the meeting, as well as technical officials and senior management. Details about the meeting are listed on page one of this fact sheet.

The June 1996 Integrated Risk Assessment

As discussed above, EPA has substantially revised the 1995 Risk Assessment reports and issued a new Risk Assessment on June 21, 1996. The new Risk Assessment is more comprehensive and site-specific than the previous reports. The report still is based on highly conservative estimates of stack emissions and includes numerous other conservative assumptions to ensure the trial burn will be protective of public health. EPA gave the revision particular attention to make this document more readable, both for the general public and for technical reviewers. Some of the key changes in this Risk Assessment include:

The Risk Assessment, based on numerous highly protective assumptions, concludes that the cancer risks range from a low of two chances in 100 million for the child of the recreational fisher to a high of about six chances in one million for the child of the subsistence farmer.

The risk for carcinogenic chemicals is expressed as a probability from 1 in 10,000 (10-4 ) to 1 in 1,000,000 (10-6). In evaluating the potential risks of carcinogenic health effects, EPA uses the 10-4 to 10-6 risk range as a target. All carcinogenic risk calculations in the June 1996 Risk Assessment are within or below this acceptable carcinogenic risk range.

To evaluate the non-cancer human health effects at Superfund sites, a "hazard index" is generally used. The non-cancer health effects hazard indices range from 0.0013 to 0.38. EPA evaluates the potential risks for non-cancer health effects based on a hazard index of 1.0. All calculations of the hazard index in the June 1996 Risk Assessment are less than one.

Risks of Potential Health Effects from Dioxin

Dioxins occur throughout the environment as unintended by-products of certain manufacturing processes and combustion activities. They also are formed during forest fires and domestic wood burning. Of the known sources of dioxin, medical and municipal incinerators appear to be the major contributors of dioxins.

EPA's Office of Research and Development (ORD) currently is reassessing the risks of dioxin to provide EPA with an updated evaluation of the health effects of dioxin and the potential pathways of exposure. A draft Dioxin Reassessment was issued in 1994, but EPA has not finalized the document. Since ORD began its reassessment, activities and decisions related to dioxin have continued in accordance with existing EPA policies. EPA believes that this approach remains appropriate in light of the information contained in the draft Dioxin Reassessment. It is particularly important that EPA continue to proceed with cleanup at Superfund sites, such as the Drake Chemical Site, because these sites present immediate hazards and a limited range of clean-up options exist.

The Superfund program has initiated a number of measures to ensure that on-site incinerators remain protective of human health. One of these measures includes performing screening levels and/or in-depth site-specific risk analyses for both direct and indirect exposures where warranted. A second measure includes performing comprehensive trial burns under controlled conditions to conduct stack analysis for dioxin and a wide range of other constituents.

Protection of Health

On June 21, 1996, EPA released the Integrated Risk Assessment which evaluates the potential risks from the site trial burn process. The Integrated Risk Assessment includes consideration of the potential risks from dioxin exposure. The new Risk Assessment concludes that the risk of carcinogenic health effects from dioxin exposure will not exceed the Superfund cancer risk benchmark. Based upon the findings of ORD's draft Dioxin Reassessment, the Intermediate Risk Assessment also evaluated the risk of non-carcinogenic health effects from dioxin exposure. This evaluation utilized a "margin of exposure" approach to determine whether dioxin exposure from the trial burn process will add significantly to estimated background levels of dioxin in the environment. The Risk Assessment concludes that the trial burn process will not significantly add dioxins to existing background levels. Thus, any dioxins emitted from the Drake incinerator are not expected to cause a significant increase in non-carcinogenic health effects from existing dioxin background levels.

In addition, EPA is conducting various sampling efforts that will provide useful information about dioxin levels and air quality. The sampling methods EPA is using include:

Background Dioxin Sampling
Because dioxins are found naturally in the environment, EPA is conducting background sampling to determine the natural levels of dioxins in the Lock Haven area. EPA uses mosses and lichens, which absorb naturally occurring dioxins, to show the levels of dioxins present in the environment. Thus far, the lichens and mosses that EPA has tested revealed very low levels of dioxins in the environment.
Ambient Air Quality Sampling
Since September 1995, EPA has been collecting ambient air samples in four locations throughout Lock Haven. EPA will use the results of these samples as a base line to compare air quality during the trial burn as well as during full remediation. Also, during the full remediation, EPA will use specific equipment to monitor various meteorological conditions for the effects of stagnation and inversions.
Sound Detection and Ranging System (SODAR)
To determine whether pollutants from the Drake incinerator are moving through the air, EPA will use SODAR. The SODAR measures weather variables such as wind speed, wind direction, and turbulence, at heights of several hundred meters above the ground surface. The SODAR measures the variables by sending sound waves into the air which then are reflected back toward the ground and received and measured by the SODAR.

Additionally, EPA and state representatives will be on site during the entire trial burn process. The EPA representative will have immediate decision authority to stop the incinerator trial burn, if necessary.

Potential Effects on the Environment

EPA performed a screening level evaluation on the potential effects of the trial burn process on the environment. Chapter 4 of the Integrated Risk Assessment, which covered the surface water modeling work, included an evaluation of potential impacts to the water quality of Bald Eagle Creek, McElhattan Reservoir, and the West Branch of the Susquehanna River. EPA compared the estimated contaminant concentrations in the surface water of these three water bodies during the trial burn to state and Federal water quality criteria. Concentrations of all chemicals were below the ambient water quality criteria for the protection of aquatic life. Thus, EPA concluded that the trial burn posed no threat to the surface water habitats of the Bald Eagle Creek, the McElhattan Reservoir, and the West Branch of the Susquehanna River.

In addition, EPA evaluated the potential effects of emissions on the terrestrial habitat in the vicinity of the incinerator. EPA compared the model soil concentrations to ecological screening level benchmarks for soil contaminants. EPA concluded that the trial burn did not pose a threat to the terrestrial habitat in the vicinity of the incinerator.

Destruction Removal Efficiency (DRE) Quota

An incinerator burning hazardous waste generally must achieve a destruction and removal efficiency of 99.99% (4-9s) for each principal organic hazardous constituent (POHC) of the waste fed into the incinerator. Thus, the Drake incinerator must comply with the 4-9s DRE during the trial burn. EPA has received many comments, however, requesting that the POHCs in the Drake incinerator be treated at a 99.9999% DRE (6-9s).

The 6-9s DRE requirement is applicable only where an incinerator is burning "listed" hazardous wastes designated as such under the Resource Conservation and Recovery Act (RCRA). These listed wastes generally are associated with dioxin. In accordance with guidance, EPA determined that these dioxin listed wastes are not at the Drake Site. As a result, EPA specified a 4-9s DRE standard for the Drake incinerator.

In response to public concern about the potential presence of certain RCRA dioxin listed wastes at the Drake Site, EPA re-reviewed the Drake Chemical Company records and EPA's Drake Chemical Site files to determine if any such wastes are on site. This second investigation again failed to indicate that there are RCRA dioxin listed wastes at the Drake Site. EPA also examined dioxin sampling data taken at the site during 1983 and 1984. This analysis confirmed that no dioxin above normal background levels is present at the Drake Site.

The procedures and results of these recent investigations are detailed in a document prepared by Frank Vavra of the U.S. EPA, entitled Dioxin Listed Wastes Report (August 7, 1996) and in the Dioxin Analysis File Search and Summary Report (June 25, 1996). EPA will place copies of these documents in all the information repositories for the Drake Chemical Site. Addresses for the repositories can be found on page XX of this fact sheet.

Decision Summary

After reviewing the Integrated Risk Assessment, public comments, and the Dioxin Listed Wastes Report, EPA determined that the trial burn process will not pose an unacceptable risk to human health or the environment.

Because the Integrated Risk Assessment evaluates an expanded list of chemicals and compounds, including products of incomplete combustion, EPA will update the trial burn plan to ensure that measurement of stack emissions data during the trial burn is consistent with this list.

EPA will conduct the trial burn in accordance with all relevant requirements and guidance, thus establishing the specific operating parameters for incinerating soils and sludges. EPA will use the results of the trial burn process to evaluate the risk of operation of the incinerator and determine whether that operation will be safe.

If the results of the trial burn meet the relevant requirements and guidance, and the Risk Assessment shows that the incineration remedy will not pose an unacceptable risk, EPA will conduct the remedial burn.

EPA developed the Integrated Risk Assessment under the assumption that the Agency will conduct the trial burn process over a 60-day period sometime during July through October 1996. If EPA is unable to conduct the trial burn during this time frame, the Agency will review the effects of a possible delay on the information described in the Integrated Risk Assessment. For example, if the trial burn is postponed until spring, EPA will review whether various environmental factors could alter the outcomes.

Response to Comments Document

EPA recently prepared a document that presents questions about the Risk Assessment reports and responses to those questions. The questions contained in this document are questions that EPA raised during review of the initial Risk Assessment. The information contained in this document will be covered in detail at the September 19, 1996, public meeting. EPA will provide copies of the document at the public meeting as well as place the document in all the Drake Chemical Site information repositories. Addresses for the repositories can be found on page XX of this fact sheet.

County Emergency and Evacuation Plans

County emergency and evacuation plans must be approved and made available to the public before the trial burn begins. Currently, the Clinton County Emergency Management Services has an emergency response plan for dealing with various emergency situations, such as floods. Evacuation plans also are included in this plan. EPA currently is working with Clinton County to prepare a specific emergency plan for dealing with the Drake Site. Upon completion of the emergency plan, EPA and the County will conduct a "table-exercise" that will test the emergency plan.

Additionally, EPA is providing Hazardous Waste Technician, Level Three, training to the Clinton Conty Emergency Response Committee. This training will take place on September 21 and 22, 1996. EPA also will provide money for a medical monitoring program.

Technical Assistance Grant (TAG)

EPA awarded a Technical Assistance Grant (TAG) to AIR on August 23, 1995. AIR selected a technical advisor and submitted a contract to EPA for review. EPA reviewed the contract to ensure that AIR will get full benefit of the contractor's expertise and that the contract is in compliance with all applicable Federal regulations. EPA then returned the contract to AIR for revisions. AIR will forward the revised contract to the EPA TAG coordinator upon completion.

EPA Communication Strategy

EPA will meet with representatives from the Pennsylvania Department of Environmental Protection (PADEP), the Department of Agriculture, and the Clinton County Commissioners to develop a communication strategy for dealing with issues related to the Drake Chemical Site. This communication strategy will outline the procedures that EPA and its contractors will use if PADEP representatives should determine that the incinerator is not meeting all required state regulations. If the incinerator does not meet state regulations, EPA is required to shut the incinerator down and correct any problems. By establishing a communication strategy with the involved county and state agencies, EPA will be able to meet state and local regulations quickly and to ensure the safety of local citizens.

Community Interviews

To gain a better understanding of community concerns and needs regarding the Drake Chemical Site, EPA is planning to conduct interviews during September 16, 17, and 18, 1996 with members of the community living near the site. EPA depends upon community input to address concerns quickly and accurately. EPA will use information from the community interviews to help develop the Drake Chemical Site Community Relations Plan. The Community Relations Plan discusses the site history, EPA activities at the site, and an overview of the community's involvement and concerns. The Community Relations Plan also details EPA's community relations goals and the activities EPA will conduct at the site to achieve these goals.

If you would like to participate in the community interviews, please complete the form below and mail it to Vance Evans at: U.S. EPA (3HW43), 1650 Arch St., Philadelphia, PA 19103-2029. Please respond to EPA by September 10, 1996. You also can reach Vance by calling the EPA Superfund Hotline: 1-800-553-2509.

Questions?? Comments??

To ask a question or provide comments about the Drake Chemical Superfund Site, please complete the form below and mail it to EPA at the following address. Your comments and questions will be addressed in person by an EPA representative as soon as possible.

Vance Evans
Community Involvement Coordinator
U.S. EPA Region III (3HW43)
1650 Arch St.
Philadelphia, PA 19103-2029

Carrie Deitzel
Community Involvement Coordinator
U.S. EPA Region III (3HW43)
1650 Arch St.
Philadelphia, PA 19103-2029

John Armstead
Regional Ombudsman
U.S. EPA Region III (3HW00)
1650 Arch St.
Philadelphia, PA 19103-2029

Please add me to the mailing list:
I know someone who would like information about the Drake Chemical Site:

Information Repositories

The administrative Record File is available for review at the information repositories listed below. The Administrative Record File is a collection of documents EPA relied on when making decisions about the Drake Chemical Site.

Lock Haven City Hall
20 East Church Street

Stevenson Library
Lock Haven University

Ross Public Library
232 West Main Street

CH2M Hill Office
226 East Water Street


A colorless, oily liquid used to make rubber, dyes, and pharmaceuticals.
A naturally occurring, colorless liquid with a sweet odor used to make styrofoam, plastics, resins, nylon, and other synthetic fibers.
A chemical used to make red dyes, known to cause bladder cancer.
Community Relations Plan
A document that outlines EPA's community relations goals and the activities EPA will conduct to achieve these goals. Also included are descriptions of EPA and Superfund, the site history and background, a community profile, and community concerns.
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
A Federal law (commonly known as Superfund) passed in 1980 and modified in 1986 by the Superfund Amendments and Reauthorization Act (SARA). The law gives EPA the authority to investigate sites where there is a suspected threat to human health or the environment caused by the release or potential release of hazardous substances. The law also created special tax on the chemical and petroleum industries which is used to clean-up abandoned or uncontrolled hazardous waste sites.
The remaining particles that come out of smokestacks, incinerators, and other such vents.
Discharge from smokestacks, vents, incinerators, chimneys, cars, trains, or airplanes.
A chemical pesticide designed to control or destroy plants, weeds, or grasses.
National Contingency Plan (NCP)
The Federal regulation that guides the determination of the sites to be corrected under Superfund and the program to prevent or control spills
Organic Compounds
Animal or plant-produced substances consisting of mainly carbon, hydrogen, nitrogen, and oxygen.
Principal Organic Hazardous Constituent (POHC)
Hazardous compounds closely monitored during an incinerator's trial burn. Usually, POHCs consist of contaminants with high concentrations in the waste feed and are less easily burned.
Products of Incomplete Combustion (PICs)
Organic compounds formed by combustion that are usually generated in small amounts. PICs are heat-altered versions of original materials fed into an incinerator. For example, charcoal is a PIC from burning wood.
Record of Decision
A document that explains which clean-up alternative EPA will use at a site.
Resource Conservation and Recovery Act (RCRA)
A Federal law designed to protect human health and the environment from the potential hazards of waste disposal. In contrast to CERCLA, RCRA deals with active and operational waste facilities. RCRA establishes many regulations under which these facilities must operate. RCRA facilities are responsible for funding all clean-up actions.
Risk Assessment
An evaluation of the risk posed to human health and the environment by the presence of contaminants.
Soil, sand, and minerals washed away from land into water, usually after rain.
A semi-solid residue resulting from air or water treatment processes.
Surface Water
Bodies of water naturally open to the atmosphere, such as rivers, lakes, ponds, and oceans.
A naturally occurring, colorless liquid with a sweet, pungent odor used to make paints, paint thinners, lacquers, and adhesives.
A man-made, colorless liquid with a sweet smell used as in solvents, cleaning agents, paint thinners, and varnishes.

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