REMEDIAIKACTION MASTER PLAN

Prepared forDrake Chemical CompanyLock Haven, Pennsylvania

9 December 1982

Revised21 January 1983

Prepared byROY F. WESTON, INC.

Weston WayWest Chester, Pennsylvania

EPA Contract No.: 68-03-1613Work Assignment No.: 2-2-14.4

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TABLE OF CONTENTS

Section Title Page

LIST OF TABLES v

LIST OF FIGURES vi

EXECUTIVE SUMMARY S-l

1 INTRODUCTION 1-1

1.1 Purpose 1-11.2 Background and Need 1-11.3 Scope of Work 1-3

2 BACKGROUND' 2-1

2.1 Location 2-12.2 Site History 2-12.3 Physical Characteristics and

Environmental Setting 2-112.4 Waste Characteristics 2-11

3 EXTENT OF CONTAMINATION 3-1

3.1 Soils 3-13.2 Buried Material 3-13.3 Groundwater 3-13.4 Lagoons 3-33.5 Air 3-53.6 Off-Site Contamination 3-5

3.6.1 Soil and Sediment 3-53.6.2 Groundwater Off-Site 3-53.6.3 Surface Water . 3-63.6.4 Air Off-Site 3-6

4 EVALUATION OF EXISTING SITE INFORMATION 4-1

4.1 Major Problems 4-14.1.1 Groundwater Contamination 4-14.1.2 Soil Contamination 4-44.1.3 Buried Materials 4-54.1.4 Surface Water 4-54.1.5 Above-Ground Materials 4-54.1.6 Off-Site Problems 4-6

iii

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iv

TABLE OF CONTENTS(continued)

Section " Title

4.2 Data Gaps4.2.1 Groundwater4.2,. 2 Soil4.2.3 Buried Material4.2.4 Surface Water4.2.5 Air

4.3 Summary

5 APPROACH TO SITE CLEANUP 5-1

5.1 Site Remedial Objectives 5-15.2 Fast-Track Leachate Lagoon 5-1

5.2.1 Limited Remedial Investigation/Feasibility Study 5-1

5.2.2 Fast-Track Remedial Design 5-25.2.3 Fast-Track Source Control Measures 5-25.2.4 Cost Estimate and Schedule 5-2

5.3 Remedial Investigation 5-25.4 Feasibility Study 5-35.5 Remedial Design 5-65.6 Implementation of Source Control and

Off-Site Measures 5-75.7 Post-Closure Monitoring 5-75.8 Alternative Comparison 5-75.9 Schedule 5-9

APPENDIX A - DETAILED STATEMENT OF WORK

APPENDIX B - ANNOTATED BIBLIOGRAPHY

APPENDIX C - BACKGROUND DATA

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LIST OF TABLES

Table No." Title Page

S-l Preliminary Cost and Time Estimates S-4

2-1 Chronology of Events at Drake 2-9

2-2 Partial Listing of Chemicals Used by DrakeChemical Company 2-12

2-3 Summary of Toxicity Data 2-14

4-1 Analysis of Groundwater 4-3

5-1 Implementation Cost Estimate 5-8

5-2 Costs and Schedules for AlternativeApproaches to Remedial Activity 5-10

AR30000U

LIST OF FIGURES

Figure No. Title Page

2-1 Location Map 2-2

2-2 Site Plan , 2-3

2-3 Area Plan 2-4

2-4 Aerial Inspection of 13 November 1980 2-6

3-1 Sample Locations 3-2

4-1 Groundwater Profile 4-2

5-1 Site Cleanup Schedule 5-11

VI

EXECUTIVE SUMMARY

The Drake Chemical Company operated a chemical manufacturingplant in Lock Haven, Pennsylvania from 1962 until they filed forbankruptcy in August 1981. EPA and PA DER undertook an emergencyremedial project from 28 February through 21 April 1982 to con-tain the site and remove drums and tanks of hazardous waste.

*The purpose of this report is to produce a Remedial Action Mas-ter Plan (RAMP) which will identify the type, schedule, and costof any additional remedial actions required. Major problems re-maining at the site include the following:

• Groundwater beneath the site is heavily contami-nated with organics.

• Soils are similarly contaminated.

• Drums of chemical waste have been buried.

• An unlined lagoon contains high concentrations oforganic materials.

• Buildings and on-site debris may be contaminated.

• A leachate stream emanating from the site has con-taminated downstream soils and caused a public parkto be closed.

The aforementioned leachate stream presents a unique problem inthat the source of the contamination cannot be clearly defined.The American Color and Chemical Company operates a manufacturingfacility contiguous to and upgradient from Drake. Existing in-formation is simply inadequate to clearly distinguish sourcesof contamination.

The proposed RAMP includes the following:

• A Remedial Investigation (RI) to obtain additionalinformation necessary to assess the feasibility ofremedial actions. The RI includes:

Preparation of a grid map.

Sampling of surface debris.

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- Soil and sediment sampling.

Sampling of on-site lagoons.

- A detailed hydrogeologic survey to define move-ment of contaminants.

A geophysical survey to locate buried drums andbulk waste.

Fast Track activities (potential) centering on thecharacterization and potential removal of the con-tents of the leachate lagoon.

A feasibility study to develop and evaluate reme-dial alternatives to the problems outlined above.This study will identify those cost-effective re-medial actions which best protect the public healthand environment from chemical contaminants.

A remedial design project to design and preparecontract documents for the remedial actions rec-ommended by the feasibility study.

An implementation phase to carry out the recommen-dations from the feasibility study in accordancewith the contract documents prepared in the designphase. The following potential activities may benecessary for the cleanup of this site. (This listof activities will be revised in the feasibilitystudy outlined previously.)

Several on-site buildings may require demolitionand removal.

Groundwater may require collection and treat-ment.

A cut-off slurry wall may be required to preventmovement of contaminants.

Extensive excavation and removal of off-site andon-site contaminated soils and sediments may berequired.

S-2

• The Community Relations Plan (CRP) is being devel-oped by the U.S. Environmental Protection Agency(U.S. EPA) , Region III, in conjunction with thePennsylvania Department of Environmental Resources(PA DER) . A CRP for the emergency work has beencompleted for this site. All community relationsactivities will be implemented jointly by U.S. EPAand PA DER.

i

The following preliminary cost and time estimates (Table S-l)have been developed for the two alternatives that were consider-ed. These include the removal of on-site debris as an initialremedial action, and the "Fast Track" removal of lagoon con-tents. The phasing of the feasibility, design, and implementa-tion of off-site contamination to allow contaminated soils tobe excavated as quickly as possible was also considered.

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SECTION 1

INTRODUCTION

1.1 PURPOSE

The purpose of this Remedial Action Master Plan (RAMP) is toprovide the U.S. Environmental Protection Agency (U.S. EPA) andthe 'Pennsylvania Department of Environmental Resources (PA DER)with a general plan for overseeing the continuing remedial ac-tion activities at the Drake Chemical Company site in LockHaven, Pennsylvania. This plan will also be utilized to assistin negotiations with responsible parties and to provide EPAheadquarters with a general program oversight and the develop-ment of cash flow requirements.

1.2 BACKGROUND AND NEED

The following summary is from the Action Memorandum dated 3August 1982.

Drake Chemical Company is an eight-acre site* used tomanufacture various organic compounds such as 2,4,5- .,trichlorophenylacetic acid (TCPAA) and other chemicals 'used as chemical intermediates. „.

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On February 23 and 24, 1982, a site entry team composedof personnel from Region III, DER Bureau of SolidWaste, ERT and Region III TAT** observed the followingat Drake:

• Approximately 1,700 drums (these were removed inMarch of 1982) filled with process wastes andsludge. Many drums were rusted .through, leaking,and bulging. Drums of cyanide reactant were beingstored outside of the buildings in a haphazard man-ner.

*Action memo mentioned site size of 20 acres.**ERT is the Environmental Response Team, U.S. EPA, Edison, NewJersey; TAT is the Technical Assistance Team, U.S. EPA.

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• A pond known by earlier sampling to contain prior-ity pollutants is located at the rear of the prop-erty. Effluent from this pond is seeping through arailroad bed adjacent to the pond, creating aleachate stream which flows through a high-use rec-reational area (including a municipal park) andeventually empties into Bald Eagle Creek, a majortributary of the Susquehanna River. Sediment sam-ples taken along the stream bed and in the mouth ofBald Eagle Creek show contamination by TCPAA, di-chloroaniline, dichlorobenzene, and phenol.

• Prior to shut down of operations in the Fall of1981, pretreatment of process wastewater producedapproximately 3,000 Ib of sludge per day which wascontaminated by various organic species. Sludgeswere deposited in unlined impoundments located onthe property. The property now contains two linedpretreatment impoundments and three large unlinedlagoons which were filled with demolition debris.Drums are presently emerging at the surface ofthese large lagoons. Hazards are known to be passedthrough various media, including air, groundwater,surface water, run-off, and soil.

The release of various kinds of organic compounds hasbeen detected in sediment and lagoon samples. Core sam-ples taken in the lagoon and drainage system leadinginto Bald Eagle Creek indicate a presence of TCPAAthroughout the system. Bald Eagle Creek sediments justdownstream from the drainage ditch are also contami-nated with TCPAA. Other compounds detected in the la-goon sediments include:

Halogenated BenzenesHalogenated AnilinesNitro BenzenesNitro ToluenesNitro AnilinesPhenols

The potential for exposure of the public to contam-inants on-site was minimized when a fence was con-structed around the property; however, human and animalexposure to the migrating leachate stream remains high.In addition, because Drake is located in a flood-pronearea, city officials are concerned that high waters mayflush out hazardous waste into the local community.

1-2

Between March 2 and April 23, 1982, Region III, in co-operation with PA DER, ERT, and TAT, conducted emergen-cy tasks in order to abate the imminent threat to pub-lic health and the environment posed by Drake Chemical.The total cost of the project reached $950,000 and wasfunded through Superfund.

Although EPA's emergency actions have reduced the im-mediate tlireat from fire and explosion and/or directcontact, a dangerous situation still remains at Drake.Eyewitness accounts of massive drum burying, more thanlikely of the same hazardous materials removed from thesurface, can be documented. The municipal park remainsclosed due to the hazardous leachate stream which even-tually enters into heavily-fished Bald Eagle Creek.

1.3 SCOPE OF WORK

The following specific tasks were included in the "Statement ofWork" provided to WESTON at the start of the project:

The Contractor will conduct the necessary backgroundwork and prepare a Remedial Action Master Plan for thedesignated sites. Master plans will be prepared at theproject level of detail and will incorporate institu-tional requirements to complete the projects. The Con-tractor will identify remedial implementation projectswhich can be fast-tracked to expedite the cleanup, andwill consider phasing the cleanup for sites requiringlarge, costly remedial actions. The Master Plan willinclude a detailed schedule for the site, and a narra-tive summary explaining key points on the schedule andhighlighting areas requiring close management over-sight. Order-of-magnitude cost estimates (ranges) willbe provided for each project included in the plan.

At the direction of the Regional Project Monitor (RPM),the Contractor will also prepare detailed work state-ment (s) for the initial project(s) to be undertaken atthe site. The work statement(s) will be sufficientlydetailed to clearly define the objectives and scope ofthe project and the various tasks needed to completethe work. The Contractor will also prepare a cost es-timate and time schedule with each work statement. Asample of a Remedial Action Master Plan will be pro-vided and should be used as a guide for conductingwork under the assignment.

1-3

The following specific tasks are included in this workassignment:

Task One; Document the Sites

• Review existing information provided by the Regionfor the site and conduct a site visit to becomefamiliar with the problem.

• Discuss the site problems and preliminary reme-dial objectives with EPA regional personnel.

• Coordinate background activities with the appro-priate state as directed by the RPM.

• Prepare fact sheets and/or action memoranda to se-cure funding allocations for the site, as directedby the RPM.

Task Two; Provide the Remedial Action Plan

• Develop phasing options and identify all planningand implementation projects to be undertaken at thesite.

• Identify fast-track projects to expedite remedialimplementation.

• Prepare an overall remedial action schedule at theproject level of detail.

• Prepare order-of-magnitude cost estimates for eachproject on the schedule.

• . Prepare detailed work statements and cost estimates(including work hours) for the immediate projectsto be initiated.

• Prepare input forms for the EPA Site Response Man-agement System.

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SECTION 2

BACKGROUND

2.1 LOCATION

Drake Chemical is located in Lock Haven, Clinton County, Penn-sylvania and is within an area that is both residential andcommercial (see Figure 2-1). The eight-acre site contains 10major buildings, including offices, production facilities, andan effluent treatment building (Figure 2-2). The site containstwo waste treatment ponds and a lagoon at the southern end.Much of the open space on the site is covered with constructiondebris.

Adjacent to the property (within 1/4 mile) is a large apartmentcomplex (inhabited mostly by senior citizens), a large shoppingcenter, and a municipal park. Lock Haven State College, elemen-tary schools, and several churches are located within a one-mileradius of the site (Figure 2-3).

The site is situated between the west branch of the Susquehannato the north, and Bald Eagle Creek to the south. Both water-courses are less than one mile from the study site.

2.2 SITE HISTORY

The use of the Drake site during the period between 1951 and1962 has been inferred from the analysis of sequential aerialphotographs compiled by the EPA Environmental Photographic In-terpretation Center (EPIC) (2).

Prior to 1951 there is little evidence of industrial activity atthe site. Vegetation is viewed in a natural state, and growth isactive in the dry stream bed on-site. Two structures are vis-ible, but no information is available regarding their function.

From 1951 to 1959, several changes are noted. The dry stream bedhas become a standing lagoon, and several tanks are visible nearthe buildings on the site, which have been expanded by an addi-tion to the larger structure. Some regrading is detected duringthis interim, as well as the existence of a dam-type structureat the southern end of the site.

2-1

AKoUUUI2-2

ORIGIN,(Red)

2-4

Aerial photos taken in 1963 show still further development ofthe site as a lagoon area. Nearly the entire site appears asstanding water, but no qualitative determinations can be madefrom the photographic data. A new building is evidenced by 1963,and details observed near this new structure indicate some scat-tered debris.

There is no way to determine the chronology of development ofthe site from the photos taken between 1959 and 1963; the sitewas purchased by Drake Chemical Corporation, Inc. in 1962.

The early history of production at Drake is unclear, but thesite has been involved for many years in the manufacture ofsmall batches of specialty intermediate chemicals for producersof dyes, pharmaceuticals, cosmetics, textiles, plant additives,and pesticides. These products were produced using the synthesisschemes of sulfonation, amination, chlorination, and cyanation.Most processes at Drake were never highly automated and requiredhand "charging" of chemicals into reactor vessels. More recenton-site inspection reports note a generally poor state of repairof the physical plant, with leaking pipes, dripping tanks,spills, and corrosive attack in areas where production synthesishad taken place. Structural damage to steel roof trusses in onebuilding was documented by 1980.

Little is known of the first 10 years of operation at Drake.The first environmental incident recorded was a 1973 citation bythe PA DER for violation of the Clean Streams Act due to heavyflooding in June of 1972. The company was cited again for non-compliance in November of 1973, and ordered to remedy, the situ-ation. No infractions are noted from 1973 until January of 1977,when Drake was again cited for noncompliance.

On 4 April 1979, a Consent Order and Agreement (0/A) was exe-cuted between Drake Chemical, Inc. and the PA DER for the pur-pose of interim handling of waste. On 7 September 1979, Drakewas notified by PA DER that they were found to be in violationof this Order.

On 4 June 1980, an on-site inspection was made by the EPA forthe purposes of preliminary assessment. In August, samples weretaken by the EPA (Samples 1-5) . Figure 2-4 is from an aerialphotograph of the site taken by EPIC on 13 November 1980. (2)

In March of 1981, the Company was cited for health violationsby NIOSH (10 counts). Reports were made concerning workers' com-plaints of bleeding gums. In April, a monitoring well boring wasmade at the baseball field near Drake.

2-5

AA30Q018

ORIGIMAi(Red)

FIGURE 2-4 AERIAL INSPECTION OF 13 NOVEMBER 1980

2-6

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On 5 January 1982, a second order was issued against Drake Chem-ical by PA DER, and the company was again cited for noncompli-ance of the 1979 0/A.

The chronology of the emergency cleanup of Drake begins with a26 February 1982 demand letter by EPA for Drake or AC&C to vol-untarily clean up the site. No response was made by Drake orAC&C; therefore, on 28 February 1982, a contract for the clean-up was executed by the EPA with OH Materials of Findley, Ohio.On 3 March 1982, the 'contractor began site setup and preliminaryinventory work. On 5 March 1982, the perimeter cyclone fenceerection commenced. March 9, 1982 was the date for the firstoff-site removal; a load of crushed debris was sent to the Clin-ton County Landfill at McElhatten, Pennsylvania. An incident on9 March 1982 necessitated a safety evacuation of the site; work-ers found a drum marked "cyanide," but tests proved negative andwork continued. On 10 March 1982, a structural engineer consult-ing for the Contractor found unstable girders and attached fi-berglass panels which were deemed a hazard for cleanup activi-ties; these were removed by the Contractor.

The removal of the reactor tanks was initiated on 10 March 1982.Vessels with chemicals in them were scheduled for on-site neu-tralization.

On 15 March 1982, an acid mist cloud was allowed to escape inthe dilution/stabilization of an oleum tank. The cloud movedoff-site and five Penndot workers reported respiratory irrita-tion at a spot over 1.5 miles from the site. Many cases of paintpeeling and blistering were reported, and an insurance claimprogram was initiated. The next day a two-in. gas main was acci-dentally ruptured. This was turned off after one hour, and near-by stores and buildings were evacuated as a safety precaution.The leak was corrected and work proceeded. On 17 March 1982, afuming drum was encountered which was found to contain hydro-chloric acid and was neutralized on-site.

On 23 March 1982, another drum tank release sent acid mist intothe air, and fire safety vehicles were necessary to form a waterstream curtain. Residents were alerted to stay indoors, therebycausing some alarm in the local community.

On 12 April 1982, another fuming tank was neutralized after labanalysis confirmed the contents to be chlorosulfonic acid.

2-7

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On 15 April 1982, the demobilization of the effort began with10 truckloads of sludge wastes being sent to CECOS Inc., NY. Atank truck was also dispatched to carry liquid materials. Rol-lins Environmental Services, Inc. received and handled the drum-med wastes from the site, which included all but the most haz-ardous compounds of the cleanup. Action ceased on the site on21 April 1982, when this phase of the project was deemed fin-ished.

On 16 June 1982, the EPA legal office recommended initiation ofa civil action against Drake for cost recovery against DrakeChemical, and against Ernest Dion, President. In August, the EPArequested to proceed with a remedial action study of the Drakesituation. Drake had previously filed for bankruptcy (August1981) and is presently in receivership.

A detailed chronology of events at the Drake site is presentedin Table 2-1.

2-8

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Table 2-1

Chronology of Events at Drake

1951 Aerial Photo: Little activity on Drake site. Site closeto natural state - vegetation growing in all areas,including stream bed.

1959 Aerial Interpretation: Dry stream bed has become standinglagoon, and two tanks are visible near Building No. 2.

1962 Site purchased by Drake Chemical.

1963 Lagoon expansion to almost all of Drake site. New build-ing. No other data available.

1973 January 18: Inspection and subsequent citation for viola-tion of Clean Streams Act as a result of 22 June 1972flood.

1973 November 30: Inspection and subsequent citation for viola-tion of Clean Streams Act and order to comply.

1977 January 9: Inspection and subsequent citation for viola-tion of Clean Streams Act, with request/order for compli-ance.

1978 November 21: Letter from Daniel Atter, Chief, OperationsSection, Bureau of Waste Control Management regardingsolid waste management.

1978 December 13: Letter from Drake outlining HC-24 unit out-put and result. Gypsum cake produced.

1979 April 4: Consent Order and Agreement executed betweenDrake and PA DER.

1980 June 4: Site inspection of Drake by EPA (for preliminaryassessment).

1980 August 31: Samples 1 thru 5 taken at Drake by EPA.

1981 March 11: Citation for health violation (10 counts).

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ORIGINAL(Red)

Table 2-1(continued)

1981 March 13: NIOSH received letter from Teamsters Local No.764 of Milton - report of medical problems (gum-bleeding,etc.) .

1981 April 27: Monitoring well boring taken at baseball field.Lock Haven.

1981 August: Drake Chemical files for bankruptcy.

1982 January 5: Second order issued against Drake by DER fornoncompliance.

1982 February 23 and 24: Site entry team composed of OSC*, PADER, Bur. of S.W., ERT, TAT personnel entered site.

1982 February 26 to April 21: Emergency removal project on-going at Drake.

1982 March 8: Drake alerted that EPA plans to initiate emer-gency response action at Drake site.

1982 June 26: Request to initiate civil action suit againstDrake is made by Robert Perry (EPA).

1982 August 3: Request to proceed with remedial action studyfor Drake.

*OSC - On-Site Coordinator

2-10

2.3 PHYSICAL CHARACTERISTICS AND ENVIRONMENTAL SETTING

The Drake site is located on a large alluvial deposit which isa product of erosion effects from the Susquehanna. The soil isclassified as a mottled, silty-clay that extends to a depth of15 to 40 ft, where it then merges with the limestone bedrockformation. The bedrock formation extends to approximately 110ft.

The groundwater table generally follows the surface gradient atan average depth of 5 to 15 ft and a gradient of less than 5percent. Actual gradients may be as low as 0.1 percent, but nospecific data on the- Drake site are available. A groundwatermonitoring study of AC&C indicates that flow of groundwatercomes from the AC&C site to the Drake site and then to BaldEagle Creek.

Surface water in the area consists of Bald Eagle Creek to thesouth (1/2 mile), and the west branch of the Susquehanna to thenorth (3/4 mile).

Land use of the area is predominantly commercial, but residen-tial development is found to the west and north of Drake. Com-munity recreational areas may be found to the west and south ofthe site (baseball fields) as well. Drake Chemical is contiguousto the American Color and Chemical production facilities to thewest. A section of Penn Central Railroad track winds to thesouth of both Drake and AC&C, thereby cutting the leachatestream before it enters Bald Eagle Creek.

There are no reported groundwater uses on or near the Drakesite, but the leachate does enter Bald Eagle Creek. This creekflows past Castenea Township Park, is actively fished, and isused for other recreation. The creek enters the Susquehanna Riv-er to the east of Lock Haven, and the river flows northeasttoward Williamsport. Average annual precipitation is 40 to 50in. Evapotranspiration in this area ranges from 20 to 30 in. peryear. Temperature ranges for Central Pennsylvania are OOF to90°F, with average frost depths estimated to be 10 to 15 in.

2.4 WASTE CHARACTERISTICS

According to a list provided by the owner, the Drake ChemicalCompany manufactured over 150 different chemicals at the plantin Lock Haven. Table 2-2 provides a partial list of thesechemicals. Many of these chemicals may be classified as pesti-cides or pesticide precursors. Table 2-3 summarizes toxicityinformation for those chemicals found in soil and water samplescollected to date.

2-11

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(Red)

Table 2-2

Partial Listing of Chemicals Used by Drake Chemical Company

Ortho Toluidine HydrochlorideSchaffer's Acid5-Nitro Isophthalic AcidChrome OxideBroenner's AcidPotassium Chloride5-Hydroxy Isophthalic Acid5-Hydroxy Trimellitic AnhydridePotassium IodideBenzoic AcidSodium ChlorideSodium SulfateCelite 545 (Filter Aid)Sodium NitriteZinc Benzoate5-Sulfo Isophthalic AcidCarbonHexamethylene TriamineChlorophenoxy PropionamideSulfuric AcidAnhydrous AmmoniaOleumMethanolHydrochloric AcidNitric AcidHydrochromic Acid

2-12

The most prevalent contaminant is 2,3,6 trichlorophenyl aceticacid (TCPAA). TCPAA is a herbicide commonly known as Fenac. Itis commonly used for season-long control of weeds in both crop(e.g., sugar cane) and non-crop (e.g., railroad and highway) ap-plications. The compound exists as a white crystalline powder atambient temperatures and is not very soluble in water. It ismoderately toxic when compared to the other compounds in Table2-3.

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Other compounds found in abundance in and around the Drake siteare isomers of dichlorobenzene. These compounds are used as sol-vents, fumigants, insecticides, and intermediates in other syn-thesis schemes. The 1,2 isomer (0 - dichlorobenzene) exists as acolorless liquid at room temperature and is not soluble in wa-ter. The 1,4 isomer has a higher melting point, and exists as awhite or colorless crystal at normal temperature and pressure.The threshold limit for both isomers (TLV-TWA) is listed as 50to 75 ppm (4) .

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SECTION 3

EXTENT OF CONTAMINATION

3.1 SOILS

Soil in the area is a mottled, silty clay. The depth of soil tobedrock is estimated to be approximately 15 to 40 ft based onlimited off-site information. There are presently no known soilboring data for the site.

The soil on-site is believed to be contaminated with trichloro-phenyl acetic acid (TCPAA), dichlorobenzene (DCB), and otherorganic chemicals used by the Drake Chemical Company. No sam-pling of on-site soils for chemical analyses has been done todate, and contaminant levels are unknown. Based on off-sitemeasurements of TCPAA and DCB exceeding 10,000 ppb, it is rea-sonable to suspect that on-site levels may exceed these values.

3.2 BURIED MATERIAL

On-site inspection and remarks from local citizens indicatethat drums containing chemical waste have been buried on theDrake site. A number of drums were observed penetrating the sur-face. The contents of the drums, their location, and presentconditions are not known.

3.3 GROUNDWATER

The groundwater profile in the area is relatively shallow (5 to15 ft below grade) and slopes to the east. One estimate placesthe slope of the water table in the range of 0.1 to 0.8 percent.

The only on-site well sampled at Drake was the well located atthe base of the northern-most wastewater lagoon (see Figure3-1). Laboratory analysis (Sample No. 2H) has yielded limitedquantitative results on contamination, but qualitative analysisindicates a complex list of organic chemicals in the ground-water. These include: chlorobenzene, methylene chloride, variousisomers of chlorophenol, methyl phenol, and other organics (Ap-pendix C) .

Significant analytical data are available from the wells locatedto the west of Drake on the AC&C site. These results may serveas a model for preliminary estimation of groundwater contamina-tion at the Drake site.

3-1

ftR30Q029

3-2

ORIGINAL(Red)

The following compounds appear in the AC&C wells at concentra-tions greater than one mg/L, and it is reasonable to predictthat they may be in the groundwater on the Drake site at similarlevels:

1,2 DichlorobenzeneChlorobenzeneBenzideneNitrobenzeneToluene

Several other compounds, identified as significant contaminantsin the "Extent of Contamination Report" (Reference 19) , arelikely to be present on the Drake site as well. These include:

• Trichlorophenyl Acetic Acid• Dichloroaniline• Phenol• Nitrotoluene• Dichlorophenol

Ortho-dichlorobenzene (1,2 DCB) is the most toxic isomer, withmaximum permissible concentrations in water of 0.002 mg/L (2ppb) . The toxicological effect involves injury to the liver andkidneys. (4)

Chlorobenzene is a central nervous system depressant and hasbeen shown to cause degeneration of liver and kidney tissue.The maximum allowable concentration in water is 0.02 mg/L (20ppb). (26)

Benzidine is listed as a human carcinogen by OSHA. (4)

Toluene has a maximum allowable concentration in water of 0.1mg/L (100 ppb) .

3.4 LAGDONS

As shown in Figure 2-2, there are three lagoons on the Drakesite. The two rectangular lagoons located in the center of thesite are lined with a heavy plastic material and were construct-ed as part of a waste treatment system. The lined lagoons wereused to neutralize wastes during the Emergency Action in Marchof 1982. The third lagoon has been characterized as a "leachatelagoon" and lies within the triangular section at the southernend of the site.

3-3

SB30003I

Several dry lagoons are located on the site and are believed tocontain chemical sludges. No analytical data are available as tothe characteristics of these sludges.

Three aqueous samples have been taken from the lagoons on theDrake siCte. Two samples (CO 518 and CO 519) are from the westernand eastern shore of the "leachate lagoon." The third sample isfrom the eastern-most lagoon near the center of the site; how-ever, this sample was collected before the Emergency Action inthe spring of 1982. The present contents of the lined lagoonsare believed to be rainwater.

Although quantitative data are sparse, analysis of the leachatelagoon samples shows concentrations of the following compoundsabove detectable limits:

• Methylene Chloride - 81 ug/L• Chlorobenzene (various isomers) - 22 ug/L

These compounds correlate positively with the lab analysis forthe leachate stream from the south end of Drake.

The eastern untreated wastewater lagoon showed concentrationsabove detection limits for the following:

• Phenol• Chlorobenzene• Methylene Chloride• Chlorophenol• Methyl Benzene

No quantitative data are available regarding any of the compo-nents of this lagoon.

There are two data irregularities concerning lagoon samplestaken from the Drake site. First, the index and site map ofsample series CO 211 to CO 214 are not intact, and the site de-scriptions are not sufficient to place these samples. These foursamples are marked "Lagoon," but no indication is given as towhere these lagoons might be located. It is conceivable thatthey are AC&C lagoon samples.

Another data problem concerns sample CO 253 - "Surface Water -Sludge Lagoon" - which is located on the sampling site map asthe dry, unlined sludge lagoon. Both the log of this particularsample and the facts concerning its origin are not resolved.

3-4

£8300032

ORIGINAL(Red)

3.5 AIR

Available air sampling data consist solely of the air qualitymonitoring log for the emergency cleanup of Drake, which occur-red from 5 March to 11 March 1982. The usefulness of this logis limited due to the unusual circumstances of the cleanup.

3.6 OFF-SITE CONTAMINATION

3.6.1 Soil and Sediment

The "Extent of Contamination Report" provided by the EPA Envi-ronmental Response Team (ERT) included an extensive survey ofthe soils in the leachate stream bed southeast of the site.This report estimates that 7,500 cubic yards of soil and sedi-ment are contaminated and must be removed.

Measured values in the soils range up to 10,000 ppb of trichlo-rophenylacetic acid (TCPAA) and dichlorobenzene (DCB). The ERTselected these two contaminants to describe the range of contam-ination at the site. The movement of TCPAA is believed to be bysediment transport in that TCPAA is a solid at ambient tempera-tures (m.p. = 161°C).

DCB is present as three different isomers: 1,2 DCB, 1,3 DCB, and1,4 DCB, with corresponding melting points of -17°C,-24.8°C, and 53.1°C, respectively. 'Only the third isomer isa solid at ambient temperatures, and all three are biodegrad-able. The toxicity of these compounds is described in Subsection3.3 and Table 2-3.

3.6.2 Groundwater Off-Site

No data have been found for off-site groundwater contamination,with the exception of the analysis of the AC&C wells discussedabove, and the well on the municipal property northwest of AC&C.These sampling sites are one dimensional with regard to theoff-site groundwater status, that is, they provide clear dataonly in the west and northwest directions from Drake. The leach-ate stream under study proceeds from Drake in a generallysouth-easterly direction and there are no wells in this direc-tion.

3-5

6B300033

3.6.3 Surface Water

The EPA ERT "Extent of Contamination Report" (19) includes acompilation and interpretation of the available data for theleachate stream southeast of Drake. No documentation of largersurface waters such as Bald Eagle Creek or the west branch ofthe Susquehanna is presented. Discussions with the EnvironmentalResponse Teair indicate that no downstream water samples weretaken in Bald Eagle Creek. Aqueous samples in the leachatestream were tested only for TCPAA. Sediments had a full screen.The West Branch of the Susquehanna River was not sampled. ERTconcluded that contamination sediment was entering Bald EagleCreek.

The ERT report addresses the contamination in the leachatestream and the probable mechanism for transport. Also includedare maps showing concentration levels (see Appendix C).

3.6.4 Air Off-Site

There are no off-site air monitoring data available regardingthe Drake site, nor is there available evidence of any on-goingmonitoring activities in the area.

3-6

ORIGINAL(Red)

SECTION 4

EVALUATION OF EXISTING SITE INFORMATION

4.1 MAJOR PROBLEMS

The major purpose of this section is to review available data insufficient detail to evaluate major environmental problems atthe site and identify gaps in the data that must be correctedprior to evaluating remedial actions. A secondary purpose of da-ta evaluation is to assess the adequacy of procedures for quali-ty assurance/quality control, chain-of-custody, and sampling andanalysis. Unfortunately, this latter evaluation could not beperformed because the documentation submitted to WESTON is in-complete. While it is reasonable to assume that TAT and ERT fol-lowed standard procedures, this report could not evaluate theadequacy of such procedures. ERT has stated that QC/QA data isnot a problem and that all OC information is available from ERT.

4.1.1 Groundwater Contamination

Existing information on the chemical characteristics of thegroundwater is shown in Figure 4-1 and Appendix C. Based on thislimited information, it is clear that the groundwater is contam-inated. A summary of quantitative information is presented inTable 4-1.

The groundwater gradient in the area is generally in the easter-ly direction, with some variations due to changes in soil per-meability and water table fluctuations. Evaluation of Figure 4-1and Table 4-1 makes it difficult to ascertain the source (s) ofcontamination; however, it is clear that the groundwater upgrad-ient of the Drake site is contaminated. ERT has indicated thatthe city well was not contaminated.

The source of the present contamination (leachate stream) leav-ing the site (Figure 4-1) is either the Drake Chemical Company,the American Color and Chemical Company, or both. The existinginformation is simply not adequate to provide a clear assess-ment.

The extent of the contamination has been summarized in Subsec-tion 3.3. Potential solutions to the problem of contaminatedgroundwater include elimination of the source followed by:

• Pumping and treatment for removal of organics.

4-1

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4-2

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• Diverting groundwater flow around the site throughthe use of impermeable barriers.

• Permeable treatment beds.

• Interceptor trenches followed by treatment.

Alternative solutions for the leachate stream contamination arediscussed in Subsection 4.1.6.

4.1.2 Soil Contamination

As noted in Subsection 3.1, the soils on the Drake site are be-lieved to be heavily contaminated with organics, including tri-chlorophenylacetic acid (TCPAA). As noted in Subsection 3.4,there are several dry lagoons presumed to contain chemicalsludges. While there is no clear evidence that this contamina-tion is being transported off-site by soils, TCPAA is a solid atambient temperatures (m.p. = 161°C). R.J. Nadeau, in the Ex-tent of Contamination Report, notes that "it is likely thatboth particulate TCPAA and TCPAA adsorbed to soil particles movemainly as part of the bedload solids in the tributary." There-fore, sediment transport appears to be a mechanism for carryingcontaminants off-site.

Due to the extreme toxicity of some of these compounds (see Ta-ble 2-3), their presence in the soil is a problem independent ofexternal transport. The toxicities shown are for exposure toeach individual compound. There is no information available asto possible synergistic effects.

In summary, there is an extremely contaminated soil on-sitewhich is probably a continuing source of off-site contamination.Potential solutions to this problem include:

• Removal of the contaminated material to a better-engineered or environmentally less sensitive area.

• Detoxification of the soil.

• Excavation and stabilization of the organics torender them insoluble and prevent their transportand re-burial on-site.

• Encapsulation of the site to preclude contaminanttransport.

4-4

RB300038

ORIGINAL(Red)

4.1.3 Buried Materials

Buried drums of chemical waste present a unique problem in thatit is not possible to assess alternative disposal methods with-out excavating the drums and determining their contents. Themagnitude of the problem may be better defined when the investi-gations recommended in Subsection 4.2.3 are completed. The mostconservative approach is to assume that the drums contain mostof the chemicals listed in Table 2-2, and that the contents areboth highly soluble and highly toxic.

Alternatives for the problem of buried materials must follow theoutline provided in Subsection 4.1.2 for handling contaminatedsoil. If an excavation alternative is selected, then the drumsand soil may be separated and handled independently.

4.1.4 Surface Water

The lagoons on-site must be drained and the contents either re-moved to a waste disposal site or treated on-site. Evaluation ofdisposal options must await better characterization of the con-tents, following the investigations outlined in Subsection4.2.4.

Alternative methods for on-site treatment of the lagoon contentsinclude:

• Pretreatment and discharge to the municipal sewersystem.

• Chemical oxidation of organics.

• Carbon adsorption.

After the lagoons are emptied, the site will need to be regradedto prevent the collection of surface waters.

4.1.5 Above-Ground Materials

The emergency cleanup in the Spring of 1982 removed drums andchemicals in tanks, and this material was properly disposed ofoff-site; however, construction debris and other solid waste re-main on-site. All of this remaining material must be categorizedas either hazardous or non-hazardous and removed from the site.Since these materials may interfere with the performance of the

4-5

ftRSO"

Remedial Investigation, it is recommended that they be removedas part of an initial remedial measure.

Each of the buildings will have to be evaluated independently todetermine if they should remain standing. As shown in Figure2-2, there are six buildings on the Drake site:

• Buildings 1 and 2 which comprise the main produc-tion facilities and the laboratory.

• Building 3, believed to be a storage building.

• Buildings 1, 2, and 3 are in very poor conditionstructurally and are believed to be contaminated.

• A large warehouse still contains many drums andcartons of chemicals. This building is newer thanthe first three and appears in reasonably goodrepair.

• The newest building on the site is the EffluentTreatment Building. This building contains fairlynew equipment, such as mixers and chemical feedpumps used for liquid waste treatment.

• The final building on the site is an office trail-er.

4.1.6 Off-Site Problems

The major off-site problems involve the leachate stream emanat-ing from the site, and the contaminated soil downgradient fromthe site. As discussed in Subsection 4.1.1, the existing dataare insufficient to identify the source of the leachate stream,and the off-site control measures that follow must await the de-termination and interdiction of the leachate source. Once theleachate source is identified, the following measures may be ap-propriate for controlling leachate:

• Groundwater controls (see Subsection 4.1.1).

• Leachate trenches or other collection schemes.

• Surface controls such as regrading, surface seal-ing, etc.

4-6

RR300QM)

ORIGINAL(Red)

If it is necessary to collect leachate, the following treatmentmethods may be considered:

• Transfer to lagoons and treatment with existing la-goon wastes (Subsection 4.1.4).

• Separate treatment of leachate (following the al-ternatives outlined in Subsection 4.1.4).

As noted in Subsection 3.6, soils downstream of the site havebeen severely contaminated, and control measures are necessaryto preclude public exposure. Potential control measures include:

• Excavation of contaminated soils and transport to abetter-engineered or environmentally less sensitivearea.

• Sealing the contaminated area with asphalt or anatural material such as clay.

4.2 DATA GAPS

4.2.1 Groundwater

The lack of groundwater data for the Drake site is a major de-ficiency which must be corrected before additional remedial ac-tions can be undertaken. A groundwater monitoring system devel-oped for the adjacent industrial site (Americal Color and Chemi-cal Company (AC&C)) indicates a groundwater gradient from thewest, directly from the AC&C site under the Drake site towardBald Eagle Creek. This greatly complicates the determination ofthe.actual pollution source.

A sampling well matrix consisting of several on-site wells (newuncontaminated upgradient wells in addition to the existing AC&Cmonitoring wells) is required for the Drake site. Additionalsampling of Bald Eagle Creek must be performed as well. Morecomprehensive quantitative analysis of organics is necessary inthe areas where only qualitative analysis exists.

This would be a complement to the geotechnical data-gatheringand would include sediment migration, aquifer flow estimates,and other factors affecting soil/groundwater interaction.

4-7

RR30GQM

4.2.2 Soil

A comprehensive soil profile for the Drake site is lacking atthis time. Definition of the nature and characteristics of thesoils on-site is necessary for further development of groundwa-ter transport modeling and estimating soil contaminant interac-tions. In addition, the nature and extent of contamination ofon-site soils has not been determined to date.

Several samples, core borings, and test pits are necessary forcontaminant analyses and classification.

The off-site soil data compiled and reviewed by the EPA Environ-mental Response Team (19) appears to be adequate for the pres-ent. Further off-site sampling will be required after the pri-mary source of contamination is contained and prior to any off-site excavation. The remedial investigation (Section 5) will de-termine the specific need for additional off-site sampling.

4.2.3 Buried Material

There is no information concerning the nature, location, andstability of any buried material on the Drake site. This infor-mation is essential for the development of any further remedialactions. Options for data gathering include:

Electrical resistivity of soils.Ground penetrating radar.Magnetometry.Test pits.Sampling and analysis of buried materials.Electromagnetic induction monitoring.

4.2.4 Surface Water

Very little information exists on the levels of contaminants inthe leachate lagoon. A sampling and analysis program must be de-veloped to characterize this material before any options forthe disposal can be addressed.

Additional sampling will be required for Bald Eagle Creek, bothupstream and downstream of the Drake site. The creek is current-ly used for recreational purposes, a fact which adds to the ur-gency of this evaluation.

4-8

H83000W

ORIG/ftAL(Red)

There is no information indicating that any contamination hasreached the Susquehanna River; however, as recommended by ERT,samples should be collected to verify this. (Note: additionalinformation can be found in the ERT "Extent of Contamination"report completed after this RAMP was prepared.)

4.2.5 Air

The only available source of air monitoring data is the logmaintained throughout the emergency cleanup. These data and thefact that several state employees were hospitalized for irrita-tion due to organic vapors indicate that an air survey is re-quired.

All of the aforementioned information relates to the site priorto and during the emergency cleanup. The present levels of or-ganics in the air are not known; however, if a monitoring surveyreveals volatile organics are present, then a more substantialsampling and analysis program will have to be undertaken to pro-vide the information necessary to evaluate the extent of theproblem.

4.3 SUMMARY

The major environmental problems at the Drake Chemical Companysite may be summarized as follows:

• Groundwater beneath the site is heavily contaminat-ed with organics.

• The soils are similarly contaminated.

• There is clear evidence that drums of chemicalwaste have been buried; the amount and nature ofthis material is unknown.

• The leachate lagoon contains high concentrations oftoxic organics, is unlined, and appears to be leak-ing.

• There is considerable construction debris on thesite. This material must be treated as hazardousuntil information is developed to the contrary.

• Buildings at the site may be contaminated.

• A leachate stream emanating from the Drake proper-ty has severely contaminated downstream soils andcaused the closing of a park operated by CastaneaTownship. The source of this leachate has not beenclearly identified.

4-9

RR30QQW

SECTION 5

APPROACH TO SITE CLEANUP

5.1 SITE REMEDIAL OBJECTIVES

Based on the review of information presently available for theDrake Site (as presented in Sections 3 and 4) , the followingactivities for the Remedial Action Master Plan have been con-sidered:

• Fast-track activities centering on characterizationand potential removal of the contents of the leach-ate lagoon.

• Remedial investigations and implementation for theremainder of the site (including off-site meas-ures) .

All remedial activities have been described in Subsections 5.3to 5.7. Leachate lagoon fast-track activities, Subsection 5.2,have been described briefly with references to more-detailedpresentations in later sections.

5.2 FAST-TRACK LEACHATE LAGOON

The Fast-Track project for the leachate lagoon will include alimited remedial investigation/feasibility study, a limited re-medial design, and implementation of the lagoon control meas-ures.

5.2.1 Limited Remedial Investigation/Feasibility Study

As mentioned previously, it is not clear at this time that theleachate lagoon is the sole source of the leachate stream thathas contaminated off-site soils and groundwater. For this rea-son, the limited remedial investigation for the Fast-Track workincludes all hydrogeological-related studies included in thefull-scale remedial investigation (see Subsection 5.3). Thefeasibility study will follow the outline presented in Subsec-tion 5.4, but will only evaluate alternatives relative to theleachate lagoon.

5-1

RR3000UU

ORIGINAL(Reef)

5.2.2 Fast-Track Remedial Design

The remedial design will follow the outline presented in Subsec-tion 5.5, but will apply only to activities related to theleachate lagoon.

5-2.3 Fast-Track Source Control Measures

The source control measures projected for the leachate lagooninclude the removal of the liquid contents and either treatmenton-site by activated carbon or conveyance to an off-site hazard-ous liquids disposal facility.

5.2.4 Cost Estimate and Schedule

A cost estimate for the Fast-Track activities is $2,040,000 to$2,690,000. The Fast-Track activities are expected to take up to20 months. See Subsection 5.8 for details.

5.3 REMEDIAL INVESTIGATION

A remedial investigation at the site is considered necessary be-cause of the limited site-specific information. The remedial in-vestigation will include:

• Pre-sampling activities (review of existing data,development of site safety, sampling and analysis,and mobilization plans).

• Topographic survey.

• Sampling of debri.s.

• Soil sampling.

• Sample collection.

• Sample lagoon water.

• Hydrogeology survey.

• GPR/magnetometer survey.

The remedial investigations are estimated to cost from $98,000to $138,000 and are projected to take up to four months. See Ap-pendix A for a detailed statement of work.

5-2

5.4 FEASIBILITY STUDY

The purpose of the feasibility study for the Drake Chemical Com-pany site is to develop and evaluate remedial alternatives forthe final disposition of contaminated soils, sediments, and sur-face and groundwater found in and around the site. The studywill select the cost-effective remedial action which best pro-tects the public health and environment from chemical contami-nants. The feasibility study for Drake can be subdivided intofive tasks.

1. Selection of remedial response objectives for eval-uation of alternatives.

2. Selection of remedial response factors for evalua-tion of alternatives - Develop technical, environ-mental, and economic factors to evaluate remedialalternatives under the following criteria:

Operation and maintenance.Environmental concerns.Safety.Reliability.Implementability.Cost.

3. Identification of alternatives - Develop alterna-tives which incorporate remedial technologies, re-sponse objectives, and other appropriate considera-tions into a comprehensive site-specific approach.A preliminary list of potential alternatives hasbeen included in Subsection 4.1. These alternativeswill be screened to eliminate non-feasible alterna-tives and alternatives that present a potentialrisk to public health, welfare, or the environment.

The development of remedial alternatives shall in-clude as a minimum:

• Description of appropriate treatment and dispos-al technologies.

• Special engineering considerations required toimplement the alternative.

• Potential risks to the environment and proposedmethods for eliminating any adverse effects.

5-3

RR3QOQU6

(Red)

• Operation and maintenance requirements of thecompleted remedy.

• Off-site disposal needs and transportation plan(as specified by RCRA) .

• Temporary storage requirements.

• Safety plans.

• Review of potential off-site facilities to en-sure compliance with RCRA requirements.

• Cost estimate for each alternative.

• Post-closure monitoring requirements.

• Any necessary laboratory and/or bench-scalestudies required to evaluate the effectivenessof a remedial technology and establish relevantengineering criteria.

4. Report submittal - A report on the preliminaryscreening of alternatives will be submitted to U.S.EPA for review prior to implementing a detailedevaluation of alternatives as described below.

5. Detailed evaluation alternatives - Evaluate andpresent the most effective alternative remedies andidentify a selected alternative. Each alternativewill be evaluated in accordance with the objectivesand factors established in paragraphs one and twoabove. A cost evaluation will be developed forfeasible alternatives, including total implementa-tion cost and any associated annual operation andmaintenance costs. The least-cost alternative thatsatisfies the greatest number of response objec-tives and evaluation factors will be considered therecommended cost-effective alternative.

5-4

RR30QQU

Cost Estimate/Feasibility

Hours HourlyClassification

Principal Engineer/ScientistSenior Engineer/ScientistEngineer/ScientistTechnician/Draftsman

TotalTotal(yses,

TOTAL

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400

1,200

2,080

400

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1,600

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480

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5-5

RR3000U8

ORJGINAl(Red)

5.5 REMEDIAL DESIGN

The purpose of the remedial design for the Drake Site is to de-sign and prepare complete contract documents for the cost-effec-tive, long-term remedial action recommended by the feasibilitystudy. The remedial design will include the following:

1. Engineering approach.

2. Implementation schedule.

3. Special implementation requirements.

4. Institutional requirements.

5. Phasing and segmenting considerations.

6. Design criteria.

7. Preliminary site and facility layouts.

8. Budget.

9. Cost estimate, including operation and maintenancecosts.

10. Operation and maintenance requirements and dura-tion.

11. Outline of safety plans, including cost impacts ofimplementation.

The specific elements of the remedial design for Drake are de-pendent upon the results of the feasibility study outlined inSubsection 5.6.

Cost Estimate/Remedial Design

Hours Hourly ___Total_____Classification______Low High Rate______Low______High

Principal Engineer/ 380 460 60 23,000 28,000ScientistSenior Engineer/ 760 910 50 38,000 46,000ScientistEngineer/Scientist 3,700 4,400 45 166,000 198,000Technician/Draftsman 1,900 2,300 25 48,000 58,000

Total Project Labor Cost ....... 275,000 330,000Total Project Direct Cost (Anal-(yses, Travel and Per Diem) .... 15,000 20,000

TOTAL PROJECT COST ............. 290,000 350,000

5.6

5.6 IMPLEMENTATION OF SOURCE CONTROL AND OFF-SITE MEASURES

The purpose of this activity is to implement the remedial meas-ures recommended by the feasibility study (outlined in Subsec-tion 5.4) in accordance with the contract documents preparedduring the design phase (described in Subsection 5.5).

Cost estimates for this phase must be considered preliminary or-der-of-magnitude estimates. More accurate estimates of the ulti-mate costs of cleanup must await completion of the studies out-lined in Subsections 5.3 through 5.5.

A cost estimate for the implementation phase is included in Tab-ble 5-1. The following assumptions were made to provide a basisfor the cost estimates:

• Several buildings on-site are assumed to be contam-inated and will require demolition and removal ofmaterial to a secure landfill.

• The groundwater under the site is contaminated andwill require installation of a well-point system,groundwater pumping, and physical-chemical treat-ment of groundwater removed.

• Extensive excavation, assumed to exceed 36,000 cu-bic yards of contaminated soil and sediment, mustbe undertaken. This material will require transpor-tation to a secure landfill.

The above assumptions lead to an estimated implementation costin the range of $4.9 MM to 10.4 MM.

5.7 POST-CLOSURE MONITORING

The purpose of this task is to develop a permanent monitoringsystem after closure of the site. The schedule and cost of thistask are dependent upon the findings of the remedial investiga-tion. An order-of-magnitude cost estimate for a hazardous wastesite of this type would be approximately $16,000 to $24,000 peryear.

5.8 ALTERNATIVE COMPARISON

Table 5-1 provides a comparison of costs and schedules for al-ternative approaches to remedial activity, in particular, thebenefits that may or may not exist by performing the work asso-ciated with the leachate lagoon on a fast-track basis concurrent

5-7

ORIGINAL(Red)

Table 5-1

Implementation Cost Estimate

Item Worst Case Best Case

Surface cleanup and disposal(debris) $ 78,000 $ 38,000Demolition/removal of buildings 110,000 99,000Remove/dispose liquid in lagoons 428,000 119,000Excavate/dispose on-site 4,269,000 1,601,000contaminated soilExcavate/dispose lagoon sediments 617,000 309,000Excavate/dispose off-site 1,350,000 1,350,000contaminated soil

Excavate/dispose buried drums 175,000 88,000Groundwater treatment 597,000Collection/disposal of water 67,000 35,000from excavationsFinal cover and site closure 495,000 170,000Contractor lump sum costs 1,672,000 774,000Engineering and bid-and-construction 330,000 290,000consultation _________ ________

GRAND TOTAL $10,188,000 $4,873,000

5-8

with the remainder of the work as opposed to simply includingit with the overall remedial action.

The only apparent benefits include reducing the schedule of re-medial actions (associated specifically with the leachate la-goon) by up to 12 months, with the feasibility study completed 4months earlier, remedial design - completed 5 months earlier,and implementation completed 12 months earlier. This can be ac-complished at approximately the same overall project costs (seeTable 5-2) . It should be noted that the overall project schedulewould only be shortened by two months.

5.9 SCHEDULE

A proposed schedule for the cleanup of the Drake site is shownin Figure 5-1. If the EPA elects to remove the lagoon contentson a Fast-Track basis, this removal can probably be accomplishedwithin 20 months.

The full-scale remedial investigation will require approximatelyfour months to complete. This schedule assumes a 30-day turn-around time on samples sent for laboratory analyses.

The exact nature of the feasibility study cannot be determineduntil the results of the field investigation are evaluated. As-suming no dramatic change in direction, the feasibility studyshould take approximately six months.

The schedules shown for design (4 months) and implementaion (14months) are very crude estimates that will be refined as a partof the feasibility study.

The work statement for the remedial investigation in Appendix Adoes not include fast tracking.

The overall schedule reduction (projected at two months) doesnot appear to warrant the extra cost entailed in breaking upthe project into two parts; however, it is possible that localconsiderations relative to the acceleration of lagoon cleanup by12 months may be perceived as being worth the extra money.

5-9

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APPENDIX A

DETAILED STATEMENT OF WORKFOR REMEDIAL INVESTIGATION (RI)

APPENDIX A

DETAILED STATEMENT OF WORKFOR REMEDIAL INVESTIGATION (RI)

The purpose of this phase is to conduct a sufficiently detailedsite investigation to list and evaluate remedial action con-cepts. A primary need in this phase is to address those criticaldata gaps identified in Subsection 4.2.

The scheduling of the RI is contingent upon whether initial re-medial measures and Fast-Track activities take place at thesite; if this is the case the RI would proceed concurrently withthe Fast-Track project.

The following tasks are identified for the RI.

1. GRID MAP

A grid base topographic map should be drawn and a permanent sitegrid should be developed. The site grid should include a suffi-cient number of nodes to encompass the primary site and a lineof grid monuments to include the off-site contaminated sedimentarea. The grids should be at least at 100 ft nodal centers andinclude at least 25 percent permanent markers (pipe centered ina concrete base), thus ensuring easy re-access to the site and acommon datum should some stakes be removed. The topographic mapshould be developed at a 1":100' and include one ft contours.

2. SAMPLING OF DEBRIS

(Note: This sampling may be conducted as an initial remedialmeasure - see Subsection 5.2) The debris on-site should be sam-pled in a statistical fashion to identify whether this debrispresents a hazard. Figure A-l is an example of a type of accept-able sampling using diagonal sampling stations. The debrisshould be sampled as a soil or by using wipe techniques similarto sampling environmental surfaces. Initial analyses of this ma-terial should include priority pollutants and TCPAA.

If this material is found to be non-hazardous, it should be re-moved to a municipal landfill to allow the remainder of the siteinvestigation to proceed unencumbered. All off-site disposal ac-tivities must be coordinated with the lead agency public affairspersonnel in order to maintain conformity with the Community Re-lations Plan.

A-l

ORIGINAL(Red)

FIGURATIVE REPRESENTS 10 M OF DEBRIS

PERSPECTIVEPROJECTION

SAMPLE Si-LOCATED AT PROJECTED CEMTER OF PILESAMPLES Sz-Ss - LOCATED AT MIDPOINTS OF TRANSECTS5,-A, S.-B, 5,-C, S.-D

SAMPLING OF DEBRIS

A.-2< -; -t i •' • . ' \

Ol*aHim\lî / CCrKATMfll

USEPA CONTRACT NO.68-03-1613

WORK ASSIGN. NO.Z-2-14.4

SCALE^ONQ|D^rmflftA~1

3. SOIL SAMPLING

As noted in subsection 3.1 of this report and the EOC report(19) , the soils on the Drake site are believed to be heavilycontaminated with organics, including TCPAA. Since the EOC re-port did not find a significant contamination decrease in soilconcentrations with depth for TCPAA, DCB, and other site contam-inants, soil sampling would include the following.

• Forty grid nodes would be sampled at zero to threeft depths, running discrete core samples at eachft. Number of cores = 120.

• Of these 40 core sites, 10 would be selected foradditional depth sampling from three to six ft withdiscrete analyses for these samples. Number of ad-ditional cores = 30.

4. SAMPLE COLLECTION

Soils and unconsolidated sediments will be sampled using a splitspoon sampler. It is standard practice to take split spoon sam-ples at the beginning of every change of stratum and at definedintervals. At these points, advancement of the bore hole isstopped and a sample of the undisturbed sediment below the augeris obtained by driving a 1-3/8 in. I.D., 24-inch long splitspoon into the sediment below the auger. The spoon is driven bystandard penetration methods which consist of dropping a 140-pound hammer 30 in. onto a drive rod attached to the spoon. Thenumber of blows the spoon requires to move 24 in. in six-in. in-crements are recorded. A representative sample from each splitspoon will be placed in an eight-ounce glass jar fitted with ascrew-on cap. Each jar will be labelled with the date, bore holenumber, and depth from which the sample was collected.

5. SURFACE WATER/LAGOON

The three on-site lagoons will be sampled using a similar sam-pling location technique as identified above (See Figure A-2) .The sampling technique to be utilized is described as follows.(Note: The contents of the leachate lagoon may be removed aspart of the Fast-Track activities, Subsection 5.2).

A-3

INFLOW

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SAMPLES TAKEKJ .AT LOCATIONSL,-PROJECTED FLOW CEUTEROF LAGOOWLii L3-PROJECTED MIDPOINTS OF TRANSECTS L,-ALI-A' FROM LAGOOM COR ME R TO LAGOON CORKIER

SAMPLING OF LAGOON

A-4&B3Q0059

Ott»O«lî ^̂ X̂ CO*ttULT«MTt

USEPA CONTRACT NO.68-03-1613

WORK ASSIGN. NO.Z-2-14.4

SCALE: NONE FIG.A-2

6. HYDROGEOLOGY SURVEY

A detailed survey of the hydrogeologic regime at the Drake siteshould be performed to define the following:

• The contaminant plume configuration (if any).

• The vectors of migration of contaminants.

• Geotechnical properties of the subsurface for im-plementing remedial actions, e.g., depth to astrict formation for sheet piling or curtaining,and transmissive properties.

In order to accomplish these goals of this phase, the followingtasks are recommended.

6.1 Evaluation of Data

The regional and local geology and hydrogeologic data will beevaluated to assess:

• Regional rock properties.• Regional transmissivities of sediment and bedrock.

6.2 Construction of Monitoring Wells

Twelve monitoring wells will be constructed in the site to eval-uate the plume configuration and migration. These wells wouldbe in addition to the existing wells on the AC&C property. TheAC&C wells should be included in this sampling program. The wellconstruction should include eight monitoring points screenedthrough the sediment zone and four screened within the underly-ing bedrock. At least two wells should be uncontaminatedupgradient wells. Properties of the subsurface should beevaluated by the following means.

• Downhole resistivity, spacial and gamma logging shouldbe conducted to cross reference the sediment characterand conductivities of the subsurface water.

A-5

ftR3QQQ60

ORIGINAL(Red)

• Physical properties of the underlying soils and bedrockshould be determined by:

- In-situ (hydraulic conductivity) testing of thesediment.

Laboratory permeability testing on at least 10representative sediment samples.

- In-situ (hydraulic conductivity) testing of thebedrock either by packer testing or pump/slugtesting.

6.3 Determination of Flow Vectors

The flow vectors of the groundwater from the installed wellswill be determined by:

• Surveying elevation of all wells with respect to aregional datum.

• Measuring groundwater elevation in these wells,separating the flow systems (if data supports) intobedrock (four wells) and unsaturated (eight wells)peizometric surface maps.

• Evaluating flow patterns and velocities by con-ducting seepage analyses in these zones.

6.4 Characterization of Subsurface Contamination

This pattern should be conducted by sampling and analyses ofgroundwater from the installed wells. Sampling and analysesshould include the EPA priority-pollutant list and indicatorionic constituents.

6.5 Evaluation of Contaminant Plumes

Any contaminant plumes that may exist will be evaluated by anal-yses of the contaminant groundwater elevation and flow vectordata, and a report will be prepared to include:

• Geohydrologic limitation to subsurface controlstrategies.

• Potential control strategies.

• Long-term (post-closure) monitoring.

A-6

7. FIXED GRID GEOPHYSICAL SURVEY

As an adjunct to the RI, a fixed grid geophysical survey of thedisposal area will be conducted to identify and evaluate theareal extent of subsurface disposal, including buried drums, andburied bulk waste. The fixed grid survey will include:

• A magnetometric survey.• Ground Penetrating Radar (GPR) survey. •• Mapping field data.

Cost Estimate - Remedial Investigation

Classification

Principal Engineer/Scientist

Senior Engineer/Scientist

Engineer/ScientistTechnician

Draftsman

HoursLow High

80 100

160 220

800 1,100

160 220

HourlyRate$

60

50

45

25

Total Project Labor CostTotal Project Direct Cost(Analyses, Travel and PerDiem) , Equipment

TOTAL PROJECT COST

TotalLow

5,000

8,000

36,000

4,000

53,000

45,000

98,000

, $High

6,000

11,000

50,000

6,000

73,000

65,000

138,000

A-7

AR300062

(Red)

APPENDIX B

ANNOTATED BIBLIOGRAPHY

APPENDIX B

ANNOTATED BIBLIOGRAPHY

1. Anderson, K.J., et al, "Evaluation of Herbicides for Possi-ble Mutagenic Properties," J.Agr. Food Chem., 1972.

Report suggests FENAC not found to increase mutationrate above spontaneous levels.

2. Baker, S.J., EPA Hazardous Waste Site Analysis - Drake Chem-ical Company, EPA Epic, April 1981.

Historical photography report from EPA's EnvironmentalPhotographic Interpretation Center showing changes onsite from 1950 to present.

3. Baker, S.J., EPA Hazardous Waste Site Analysis - AmericanColor and Chemical, EPA Epic, April 1981.

Historical photographic report showing land uses andhistorical development of site.

4. Clayton, G.E. and Clayton, F.E. (Eds.), Patty's IndustrialHygiene and Toxicology, Vol. 2, Toxicology. Wiley-Inter-science, 1981.

General reference on toxicology.

5. D.E.R., Air Quality Monitoring Log for the Drake ChemicalCompany Cleanup - Pennsylvania Department of EnvironmentalResources, Bureau of Solid Waste Management (Received 6October 1982).

Log of air monitoring for emergency cleanup action,March and April 1982.

6. EPA, Drake Chemical Company (PA-286), TDD F3-8007-52 (fivesamples collected 7/31/80).

Report on sampling by Ecology and Environment, Inc.

7. EPA, Drake Compatibility Tank Analytical Results (EPA), 12April 1982.

Results of analytic tests - tank Nos. 1 and 2 Drake.

B-l

(Red)

8. EPA, Fund Authorization Report, Drake Chemical Company.

Initial request for funding at Drake.

9. EPA, Handbook - Remedial Action at Waste Disposal Sites,EPA 625/6-82-006, June 1982.

10. EPA, Site Safety Plan, Drake Chemical Company, 1 March 1982.t

Safety plan for the on-site activities of the environ-mental response team during the emergency removal opera-tions.

11. Federal Register (FR 31180-31243), National Oil and Hazard-ous Substances Contingency Plan, 16 July 1982.

40 CFR 300.1 through 300.81 plus preamble. This is theNational Contingency Plan (NCP) pursuant to CERCLA.

12. Giddings, Todd, Groundwater Monitoring System - AmericanColor and Chemical Company, Lock Haven, Pennsylvania, 2November 1981.

This represents one source of groundwater data availableat the time this report was prepared. The report esti-mates the general groundwater flow pattern in the area,based on analysis of four wells.

13. Glenn, Garth - Field Investigations of Uncontrolled Hazard-ous Waste Sites - F.I.T. Project "Site Sampling of AmericanColor and Chemical Company and Drake Chemical Company," 27April 1981.

Several wells drilled; water and soil samples collected.

14. Glenn, Garth - Potential Hazardous Waste Site - Site Inspec-tion Report, 4 August 1980.

Initial report of F.I.T. team. Among the problems iden-tified were: leaking drums, liquid waste in lagoons,"Leachate leaving property has left a path five yardswide devoid of vegetation," lack of security fencing,etc.

15. Hagel, Wm. - Draft authorization to proceed with remedialactivities at the Drake Chemical site, 3 August 1982.

B-2

16. Hagel, Wm. - Mitre Model Worksheets for Drake Chemical Com-pany, June 1982.

Preliminary workup of site includes environmentalsetting.

17. Hedeman, Wm. - Action Memorandum to Rita Lavelle (undated) -received 21 October 1982.

Requests authorization of funds to undertake remedialinvestigation and feasibility study for source controlmeasures at Drake site.

Total Est. Cost = $475,000EPA share (90%) = $427,500

18. Hedeman, Wm. N. - Memo to regional superfund coordinates (22June 1982) providing guidance on preparation of RAMPS.

Outlines RAMP procedure and form.

18a. Kaschak, W.F. and Nadeau, P.F. "Remedial Action MasterPlans."

Undated technical paper providing guidance for RAMPpreparation.

19. Nadeau, R.J. and Alien, H. - EPA Extent of Contamination,Drake Chemical Company - EPA ERT (undated; received 14October 1982).

A detailed sampling and analysis program estimated that7,500 cubic yards of off-site soils are contaminated andmust be removed.

20. Nadeau, R.J. - Extent of Contamination Survey - Drake Chemi-cal Site - Interim Report No. 1, 13 April 1982.

21. Nadeau, R.J. to Tom Massey, O.S.C. - Extent of Contamina-tion Survey - Drake Chemical site - Interim Report No. 2, 4May 1982.

Memo report noting sediments contaminated with TCPAA,DCB, DCA, nitrobenzene, phenol, and napthol. Preliminaryrecommendations indicate removal of contaminated sedi-ment required.

B-3

(Red)

22. Nadeau, R.J. - Preliminary Results from Extent of Contami-nation Investigation at Drake Chemical Site (EPA) - R.J.Nadeau, 13 April 1982.

23. Pesticide Dictionary - Farm Chemicals Handbook, 1971.

Provided limited information on FENAC (trichlorophenylacetic acid).

24. Spence Farm Remedial Action Master Plan and Project WorkStatements, URS Company, Inc., 16 March 1982.

Generic "Model RAMP" provided as guidance in preparationof the present report.

25. Wilding, D.A. - Trip Report and Preliminary Assessment In-spection Report of Drake Chemicals International, Inc., 18June 1980.

Lists contents of still bottoms.

26. Verschueren, Karel - Handbook of Environmental Data on' Or-ganic Chemicals, Van Nostrand, 1977.

Provided toxicological data on contaminants encountered.

27. UNI-TEC, Inc. - Test Boring Log for Monitoring Well In-stalled for Baseball Field, 27 April 1981.

Confirms other geologic data.

B-4

SR300067

APPENDIX C

BACKGROUND DATA

JACOBS LABORATORIES

APPENDIX C-l

Methods Of Analysis*

Analysis ' Method

Volatile organies in solids Modified method 621* (Lore Canal Protocol)Semivolatile organics in

solids (B/K and, A) Modified method 625 (Love Canal Protocol)Pesticides and PCB's Method 608, GC/EC vith GC/MS confirmation

C-l

ftR300069

- • JACOBS LABORATORIES

Serple: Station #1 - Baseball Field Westof A.C. 4 C. Soil Lao Ho. PBl-05-027

S=mary of Organic Priority Pollutants

C-2

Compounds Concentration,—————— ug/kg

I Volatile Components None Detected < 10

II Base /Neutral Coeponents Di-n-'butyl phthalate 2,̂ 00

HI Acid Components Bone Detected

sJACO3S LABORATORIES

V.

Sample: Station #2 - Southeast Baseball Field' ~~~~——— Lab Bo. P81-05-027

Sunmary of Organic Priority Pollutants

ConcentrationCompounds ___ug/kg___

I Volatile Components Bone Detected < 10

H Base/Keutral Coaponents Bis (2-ethyl hexyl)phthalate iB.^oo.QDoJ *££

Diethyl Phthalate 12,000X 4*33.wf ,Di-n-butyl phthalate 17,000 ."Vy ~;

HI Acid Components , Bone Detected < 1,000

TV Pesticides t PCB's • Bone Detected < 500

JACOBS LABORATORIES

Sample: Station 13 - Sediment fron Leachate Stream* SE Of Drake

Lab Bo. P81-05-027

ef Organic Pri(-7b ****Methyl-hexadecanoate _-9,Methyl isooctyl phthalate

C-4 RR300072

JACOBS LABORATORIES

Sample: Station #k - Sediment from LeachateStream Castauea Tvnp Park

Lab Bo. P81-05-027

Summary of Organic Priority Pollutants

ConcentrationCompound

I Volatile Components Bone Detected < 10

II Base/Bertral Coaponents Di-H-butyl phthalate 3,900 •"

HI Acid Ccrponents Hone Detected

APPENDIX C-2

Sam Die CO 516- ACkC Well # 1__________ — (Red)

2-Chlorophenol — ̂ y ' ' Benzenaceticacid2,4-Dimethylphenol - ' - BenzoicacidPhenol— 2.OO 9, 10-AnthracenedioneBenz idine — /G,nc\ Octansicacid1, 2-dichlbrobenzene- ;>Bis(2-ethylhexyl)phthalate «2oBenzene — 27.CChlorobenzene — ̂ /«?cO1, 2-diehloroethane _ 2.VOEthylbenzene *L toToluene > JoooTrichloroethylene -2.42-propanonePropanol, 2-Meihyl2-Butanone, 3- MethylDisulfide, DimethylCyclohexane, Methyl-2-HexanoneBenzene, Methoxy-Benzene. 1-Chloro- 3-NitroSulfur, Mol. (5;.)Benzenamine, 2-Chloro-4-MethylNitrobenzene2-Naphthalenol

Sample CO 517 - Leachate Stream S. E. of Drake

1, 2-dichloroethane — /3Benzene, Trichlorornethyl-O-Cresol, 3,4, 6-TrichloroBenzaldehyde, 2,4, 5-TrichloroBenzene, 2, 4-Dichloro-l-(Chloromethyl)

Sample CO 51£ - Western Shore of Triangular Impoundment, So. End of Drake

jMethylene 'chlo'rlde —Benzene, l-Chloro-2-(Trichloromethyl)2- Propenal, 3-(2, 2, 6-Trimethyl-7-Oxabicyclo/4. 1. 0/Hept-l-yl)-O-C*e5ol, 3,4, 6-TrichloroBenzaldehyde, 2, 4, 5-TrichloroBenzene, l-Chloro-4-(ethenylsulfonyl)-O-Cresol, 3,4, 6-TrichloroBenzene, l-Chloro-2-(Trichlpromethyl)

C-7

Sar.-•->)bis(2-ethylhexyl) phthalate-/^Benzene — ~7c,OChlorobenzene —//oo>Toluene f̂C2- PropanoneFurzji, TetrahydroEthane, 1, 2 Dichloro 'CyclohexaneCyclopropane (1-M ethylethyl)2- Britanone, 3-methylMethane, DimethoxyBenzenamine, 2-chloro7H-J5enz(De) Anthracen-7-one1, 2, 3-Benzotriazin-4{3H)-one, 39,10-AnthracenedioneBenraphenone, 3,4-Dichloro10- Cctadecenoicacid, MethylesterHexaiecanoicacid, MethylesterUndecanoicacid, 10-methyl-, MethBenzsnamine, 2-chloro, 4-MethylPyricine, 3-Ethyl-5-MethylBenzenamine

Sample CO 515- AC&C Well #2

1, 2-cichlorobenzene —Bis(2-ethylhexyl)phthalate —Chlorobenzene —Cs1/Furar., Tetrahydro2-Bua.none2-Buta.none, 3-MethylOxi razie, Me thyl2, 5-Cyclohexadiene-l-4-dioneBenzene, Ethoxy2, 5-Cyclohexadiene-l-4-dione, 2-ChloroBenzisothiazole1, 2-Bsnzisothio.zole, 3-Methyl2rP-ropanol, 3-(2, 2,6-trimethyl-7-O2abicylo/4 1 0/heot-lBenzcthiazole, 5-Chloro-, 2-Methyl u/Acpt-11,4- Kapthalenedione1, 3-lsobenzofuran-dione1, 2-Benzisothiazole, 3, MethoxySulfur, Mol. (5C)Dodecane, 1,1'-ThiobisPhenol, 2,4-Dichloro-6-MethylBenzenamine, 2-Chloro

c"8 RR300076

Sample CC 51V - E. Shore of Triangular impoundmerA So. End of Drake v' " '

1,2- Dich".;robenzene- 5>:Methylene chloride -B!Benzene, ;-Chloro-2-(Trichloromethyl)-9, 10-AnthracenidioneBenzenamine, 2-ChloroO-Cresol, 3,4, 6-TrichloroBenzene, l-Chloro-4-(Ethenylsulfonyl)-

Sample CC 512- Well on City Prop. , N. W. of ACkC.

Fluoranthene - 23Benzo(a)arihracene — 12,Benzo(a)pTrene — / 73 , 4 -benzofluoranthene — CL3Benzo(k)fî oranthene -"23chrysene — 13.Anthracers - (L/Phenanthrsne — / VPyrene - /^Furan, Te^ahydro-2-ButanoneCyclohexanone

Sample CO 513 - AC&C Well

Fluoranthene —ifBis(2-ethrlhexyl)phthalateBenzo(a)akthracene — //

3 , 4 -benzcfluoranthene — 1Benzo(k)fLaoranthene - /.fChrysene —//Anthracene — / oPhenanthrene — /oPyrene — /"SBenzene *.tQFuran, Terrahydro-2-PropancneBenzenemethanamine, N- ethylThiophene, Tetrahydro-l,l-dioxidePentadecanoicacid, 14-Methyl- MethylesterDodecanoicacid, MethylesterDodecanoicacid, Ethenylester-Tetradecaaoicacid, 12-Methyl-, Methylester9-Octadecanoicacid (2)-2, 3-DihydroxypropylesterDodecanoicacid

Sample CO 520 - BlankRR300077

C-9

Sample 11H- Easternmost Untreated Waste Water Lagoon

PhenolChlo robenzeneMethylene chloridePhenol, 4-ChlorcBenzene, Methyl -

Sample #2H- Well at Base of Easternmost Waste Water Lagoon.

ChlorobenzeneMethylene chloridePhenol, 4-Chloro-P,-chloro-m-cresol2-chlo rophenol2, 4-dichlorophenol2,4-dimethylphenolPhenolAce na phthen e1, 4-dicBlorobenzeneChlorobenzeneMethylene chlorideBenzamineBenzeneamine, 2-chloro-2-Cyclohexen-l-one, 3,5, 5-Trimethyl-6,10,14-Hexadecatriene-l-Ol, 3, 7,11,15-Tetramethyl-, /R-(E, E)/-

SamDle Blank -

Methylene Chloride 37. 7 mg/1

RB300078\*"~ IU

ORIGINAL(Red)

APPENDIX C-3

ON AND OFF SIT