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PETITIONED HEALTH CONSULTATION NO.2

THERMAL DESTRUCTION FACILITY

DRAKE CHEMICAL
LOCK HAVEN, CLINTON COUNTY, PENNSYLVANIA


FOREWORD

This health consultation evaluates the incinerator operational plans, trial burn protocols, and emissions modeling. Health Consultation #3 will provide an evaluation of data from actual sampling and monitoring of the incinerator during the trial burns and risk burns. In Health Consultation #3, the Agency for Toxic Substances and Disease Registry (ATSDR) will also evaluate the ambient air data for public health implications.


BACKGROUND AND STATEMENT OF ISSUES

This health consultation is the second in a series of consultations ATSDR is conducting to address public health issues relating to the Drake Chemical Superfund site in Lock Haven, Pennsylvania. The consultation evaluates emissions and modeling information used in the trial burn risk assessment and the operational plans and protocols for the incinerator. The first health consultation evaluated the trial burn risk assessment (excluding incinerator emissions and modeling information) and the ambient air sampling plans and activities [1]. ATSDR refers readers to that health consultation for general background information on the site. In the future, ATSDR will evaluate the public health implications of air and stack emissions sampling conducted during the trial burn process.

Since the incinerator trial burn is complete, and ATSDR did not become involved at the site until after the incinerator was operational, we have reviewed the documents to (1) evaluate the design and operational conditions that might affect public exposure and (2) look at the modeling and risk assessment approach. In this consultation, we comment on the risk assessment modeling approach and discuss changes we would like to have incorporated into the risk assessment for full operation based on the trial burn stack emissions testing. We also comment on the planned operating conditions, identified in the documents, that may affect public exposure. This consultation is not a critical review of the projected emissions for the trial burn period and the risk associated with those projected emissions. ATSDR does not consider it efficient to review and comment on hypothetical projected emissions when the actual emissions data from the trial burn and risk burn will soon be available. In another consultation, we will evaluate the emissions data and operational conditions during the trial burn and comment on the potential health effects of full operation based on the actual stack emissions. Comments provided in this consultation are intended to help the Environmental Protection Agency (EPA) develop the risk assessment for full operation.


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