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  • Automatic waste feed shut-offs (AWFSOs) were set on the key operating conditions, and the documents specified that the flame was to be maintained whenever it was safe to do so. The operating conditions and AWFSOs should ensure safe operation of the incinerator and prevent or minimize to the maximum extent possible exposure of the community.

  • The continuous monitoring and recording of the key operating conditions and stack emissions will provide continuous documentation of the operation of the incinerator and the causes of any releases that may occur.
  • The circumstances specified when the thermal relief valve (TRV) will be opened are only those that constitute true emergency situations, when it would be more protective of public health to vent the hot gases through the TRV than to allow catastrophic equipment failure that would release the hot gases at ground level.
  • Estimates of TRV emissions for full operation and modeling of those values would help investigators predict the public health impacts of upset conditions.
  • New dispersion modeling would be useful for evaluating the stack emissions measured during the trial burn. Dispersion modeling to date is not adequate to project the ambient air concentrations in the communities around the Drake incinerator during full operation.


  1. Conduct new modeling using five years of meteorological data and stack emissions rates measured during the trial burn and risk burn. Agency for Toxic Substances and Disease Registry (ATSDR) staff should review the draft modeling protocol before the modeling is conducted so that our input can be more pertinent and timely.
  2. Reevaluate and provide references for the following assumptions used in projecting the emissions that will be released when operating conditions cause the thermal relief valve (TRV) to open: (1) the assumption that after an initial puff of one minute duration the emissions will decrease exponentially to zero within 25 minutes and, (2) the assumption that during the first minute the destruction and removal efficiency will decrease from 99.99% to 99%.

    Note: 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, ATSDR will also evaluate the ambient air data for public health implications.


    Betty C. Willis, MS
    Environmental Health Scientist
    Program Evaluation, Records, and Information Services Branch

    Gregory M. Zarus, MS
    Environmental Health Scientist
    Exposure Investigation and Consultation Branch


    1. Agency for Toxic Substances and Disease Registry. Health consultation for Drake Chemical Superfund site thermal destruction facility, Lock Haven, Pennsylvania. Atlanta: US Department of Health and Human Services, Public Health Service. 1997 July 24.

    2. Dabberdt WF. Draft comments on Drake Chemical site incinerator trial burn risk assessment. 1997 Jan 24 .

    3. Roy F. Weston, Inc. Drake Chemical site incinerator trial burn risk assessment (volumes I, II, III). Prepared for Environmental Protection Agency Region III. 1996 June 21.

    4. Midwest Research Institute. Trial burn plan for the Drake Chemical Superfund site's mobile hazardous waste incinerator, volumes I and II. Prepared for OHM Remediation Services Corp. 1994 Oct 24 (revised 1996 Sept 20).

    5. Commonwealth of Pennsylvania, Department of Environmental Protection, Bureau of Air Quality. Air quality equivalency document. 1995 Dec 8.

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