United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-89/090
September 1989
SEPA
Superfund
Record of Decision
Claremont Polychemical, NY
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-89/090
3. Recipient1* Accession No.
4. Title md Subtitle
SUPERFUND RECORD OF DECISION
Claremont Polychemical, NY
Second Remedial Action - Final
5. Report Date
09/22/89
7. Authors)
Performing Organization Name md Address
8. Perioiming Organization Rept No.
10. Pro(ecVTask/Work Unit No.
11. Contract(C) or Gr«nt(G) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
IX Type of Report a Period Covered
800/000
14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
The Claremont Polychemical site is a 9.5-acre abandoned chemical production facility
in central Long Island, Town of Oyster Bay, Nassau County, New York. Land use in the
area is devoted primarily to light industrial and commercial operations. Contamination
at the site took place between 1968 and 1980 and resulted from ink and pigment
manufacturing operations, which generated.wastes including organic solvents, resins,
and wash wastes. The site consists of a one story building with a contaminated sump,.
five 5,000-gallon wastewater treatment basins containing sludge, and six above-ground
tanks, three of which still contain waste materials. The initial discovery of site
contamination occurred in 1979 when the county found 2,000 to 3,000 waste drums, some
uncovered and others leaking. By the following year many of these drums were either
removed or reused in the plant; however, the county had by this time identified an area
of organic solvent contamination east of the building. Subsequently, a 10-foot layer
of soil in the area of contamination was excavated and placed on a plastic liner. The
liner has since deteriorated and monitoring has identif-ied ground water contamination
under the site. In October 1988 a removal action was conducted which included the
removal of liquids in the treatment basins and the classification, separation, and
storage of the approximately 700 bags and drums of waste. (Continued on next page)
17. Document Analysis a. Descriptors
Record of Decision - Claremont Polychemical, NY
Second Remedial Action - Final
Contaminated Media: solids, liquids, debris, sludge
Key Contaminants: VOCs (benzene, PCE, toluene, TCE), other organics, metals (arsenic,
chromium, lead)
b. Identifiere/Open-Ended Terms
c. COSATI Reid/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None
21. No. of Pages
53
22. Price
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bound reportfor example, each volume In a multivolume setshall have Its unique Report Documentation Page.
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an organizational hlerachy. Display the name of the organization exactly aa It should appear In Government indexea such as
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of... Presented at conference of... To 39 published In... When a report Is revrsedpnclude a statement whether the new -
report supersedes or suppleraent4»Ujgo»derreport .'"".... - - ^^ >'-. -i - , . - '
f - ' +*ir' '": ~:: - :.. ' ' '' ;X
16. Abstract Include a brief (200 words or Inss) factual summary of Vie moat significant information contained In the report If the
report contains a significant bibliography or literature survey, mention 4t here. '
17. Document Analysis, (a). Descriptors. Select from the Thesaurus of Engineering'and Scientific Terms the proper authorized terms
that Identify the major concept of the research and are sufficiently specific end precise to be used aa Index entries for cataloging.
(b). Identifiers and Open-Ended Terms. Use Identifiers for project names, code names, equipment designators, etc. Use open-
ended term i written In descriptor form for those subjects for which no descriptor exists. . "
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A GPO: 1983 o - 381-526(8393) " OPTIONAL FORM 272 BACK
<«r77)
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1,6- Abs.txact....J-Qo.ntinued).
EPA/ROD/R02-89/090
Claremont Polychemical, NY
The first operable unit for this site will address soil and ground water contamination
and will be initiated after the second operable unit. This second operable unit
addresses the wastes in containers above-ground tanks, wastewater treatment basins, and a
sump. The total volume of wastes at the site could be as high as 100,000 pounds of solid
materials, 10,000 gallons of liquids, and 25,000 pounds of sludge. The primary
contaminants of concern in drummed and packaged liquids and solids, and in treatment
basin sludge are VOCs including benzene, toluene, TCE, and PCE; other organics; and
metals including arsenic, chromium, and lead.
The selected remedial action for this site includes compatibility testing on the
contents of each treatment basin-, above-ground tank, sump, drum, and bag with bulking and
consolidation of compatible wastes and pumping the contents of the above-ground tanks,
treatment basins, and sump into storage tanks; analytical testing of composite samples of
drums or bulked wastes to determine appropriate treatment or disposal methods; and
transporting the wastes for offsite treatment or disposal as appropriate. The estimated
present worth for this remedial action, assuming treatment using incineration, is
$1,339,000 with no O&M costs.
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Claremont Polychemical, Old Bethpage, Nassau County, New York
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the second operable unit at the Claremont Polychemical site, in
Nassau County, New York, developed in accordance with the
Comprehensive Environmental Response, Compensation and Liability
Act, as amended by the Superfund Amendments and Reauthorization
Act and, to the extent practicable, the National Contingency
Plan. This decision is based on the administrative record for
this site. The attached index (Appendix C) identifies the items
that comprise the administrative record upon which" the selection
of the remedial action is based.
The State of New York has concurred with the selected remedy.
Assessment of the Site
Actual or threatened releases of hazardous substances from this
operable unit, if not addressed by implementing the response
action selected in this Record of Decision, may present an
imminent and substantial endangerment of public health, welfare,
or the environment.
Description of the Selected Remedy -
This operable unit is one of two being conducted at the site. It
addresses the wastes in containers (drums, bags, etc.),
aboveground tanks , wastewater treatment basins,, and a sump
discovered at the site. The other operable unit will involve
overall site remediation including soil and groundwater.
The major components of the selected remedy include:
o Compatibility testing of all wastes;
o Bulking and consolidation of compatible wastes;
o Transportation of wastes to an off-site .treatment, storage
or disposal (TSD) facility; and
o Treatment as appropriate at the TSD facility (e.g.
incineration, solidification, landfilling> etc.)
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Declaration
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost effective. This remedy utilizes
permanent solutions and alternative treatment (or source
recovery) technologies to the maximum -extent practicable and
satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a
principal element. Because the remedy for this operable unit
will not result in hazardous substances remaining on-site above
health based levels, the five-year review will not apply to this
action.
William J.^usayns^T, P.E.
Acting Regional Administrator
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DECISION SUMMARY
CLAREMOMT POLYCHEMICAL SITE
UNIT II
OLD BETHPAGE, NASSAU COUNTY
NEW YORK
United States Environmental Protection Agency
Region II, New York
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TABLE OF CONTENTS
SECTIONS
SITE NAiiE AND LOCATION 1-
SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
SCOPE AND ROLE OF OPERABLE UNIT 3
SITE CHARACTERISTICS 3
SUMMARY OF SITE RISKS 5
DESCRIPTION OF ALTERNATIVES 5
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 8
SELECTED REMEDY 12
STATUTORY DETERMINATIONS 13
DOCUMENTATION OF SIGNIFICANT CHANGES 15
APPENDICES
""*."
APPENDIX" A. FIGURES
APPENDIX B. TABLES
APPENDIX C. ADMINISTRATIVE RECORD INDEX
APPENDIX D. NYSDEC LETTER OF CONCURRENCE
APPENDIX E. RESPONSIVENESS SUMMARY
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SITE NAME AMD LOCATION
The Claremont Polychemical site is an abandoned production
facility located in central Long Island, Village of Old Bethpage,
Town of Oyster Bay, Nassau County, New York (see Figure 1). The
facility is situated in an area comprised of light industrial,
commercial and institutional properties (Oyster Bay Solid Waste
Disposal Complex, SUNY Agricultural and Technical College at
Farmingdale, and Bethpage State Park). Adjacent to the site at
its southwest corner is Park Stables where privately boarded
horses and publicly available mounts are maintained. Bridle
paths exist in the State park. The Suffolk County line is
approximately 800 feet east of the site.
In 1985, Old Bethpage had a population of 5,881 persons and
Oyster Bay had a population of 305,750 .persons, according to the
Current Population Report (U.S. Bureau of Census, 1987). The
closest residences are less than 1/2 mile away on the west side
of the landfill. The nearest public water supply well is located
3,500 feet northwest of the site. Farmingdale water district
wells, N1937, N6644, and N7852, are located more than 7,000 feet
south, and possibly downgradient, of the site. Groundwater
recharge basins are located 1^800 and 2,500 feet north, and 1,000
feet south of the site.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A historical summary of activities associated with the Claremont
Polychemical site is presented in Table 1. From 1968 until its
closure in 1980, Claremont Polychemical was dedicated to the
manufacture of inks and pigments for plastics, vinyl stabilizers,
and coated metallic flakes (Durogold). This was the second such
facility operated by Claremont Polychemical, as the original
plant was located in Roslyn, New York.
The principal wastes generated were organic solvents, resins and
wash wastes .(mineral spirits). A summary of chemicals known to
be used and/or produced on site is presented in Table 2.
The site occupiers 9.5 acres on which a -35,000 square foot, one
story/ concrete building is located (see Figure 2). Located
inside the building were a solvent recovery system (steam
distillation),.two pigment dust collectors and a sump. To the
west of the building there are five treatment basins, each with
capacity for 5,000 gallons, which contain sludge. Six
aboveground tanks, three of which contain wastes, are located
east of the building. Other features found include: an
underground tank farm, leaching basins, dry wells, and a water
supply well.
Concern for contamination was linked to a discovery in 1979 by
the Nassau County Department of Health (NCDH) of approximately
2,000 to 3,000 drums scattered about, some uncovered and others
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leaking. By September 1980, most of the drums were sorted and
either removed from the site, or reused in the plant. Some of
the material was burned in the plant's boiler. NCDH inspectors
noted at the time that an area east of the building (spill area)
was contaminated with organic solvents as a result of accidental
and/or incidental spills and discharges. A subsequent remedial
action excavated the upper ten feet of a seventy-five foot by
seventy-five foot area. The excavated material was placed on a
plastic liner. Over the years, this liner has degraded and no
longer forms an impermeable layer. Groundwater samples from a
monitoring well installed at the time indicated the presence of
groundwater contamination directly under the site.
Claremont Polychemical and its affiliated companies entered into
receivership in 1980. In 1983, Woodward-Clyde Consultants, under
the direction of the New York State Department of Environmental
Conservation, conducted a preliminary investigation of the site.
In 1984, Velzy Associates conducted a limited study of the site
for the property owners. Additional work was performed by C.A.
Rich Consultants in response to a request for information by the
U.S. Bankruptcy Court. For the last four to five years and under
the supervision of the New York Bankruptcy Court, two tenant
businesses have been operating at the site.
On December 4, 1987, EPA issued a special notice letter to Mr.
Walter Neitlich (Claremont Polychemical officer) requesting a
good faith offer to undertake or finance the remedial
investigation and feasibility study (RI/FS). No response was
received from Mr. Neitlich or a company representative and in
March 1988, EPA obligated funds and started a comprehensive
RI/FS. On June 7, 198H, EPA conducted a site visit, and later
completed an inventory of the approximately 700 drums and bags
found on-site. EPA sanpled the content of the treatment basins,
aboveground tanks, some of the drums, the floors and the air
inside the building. The drums and bags hold numerous chemicals,
including aluminum metal powder, flammable solvents, cadmium,
zinc, antimony and lead based pigments, epoxy, acrylic and vinyl
resins, organic based inks, and other unknown compounds. At the
time many of the containers were open, leaking, or in poor
.condition.
During the removal action conducted in October 1988, the liquid
contents of the treatment basins were removed, and the structures
covered and snow-fenced. The drums and bags were classified in
general categories (i.e. organic, explosive, acid, etc.) based on
their labels and information obtained from Mr. Neitlich,
overpacked as necessary, staged, and secured inside the building
pending disposal.
A second operable unit (OU-II) was initiated on March 1989 to
deal with the disposal of the wastes storage in the containers,
aboveground tanks, basins, and a sump.* Twenty percent (20%) of
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the unknown containers and ten percent (10%) of all the other
categorized containers were sampled to determine and/or confirm
their constituents. Samples were also collected from the small
sump found inside the building.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS and Proposed Plan for the Claremont Polychemical site
were released to the public in July 1989. These two documents
were made available to the public in both the administrative
record and the information repository maintained at the EPA
Docket Room in Region 2 and at the Plainview-Old Bethpage Public
Library. A press release concerning the availability of the
RI/FS reports, the Proposed Plan, and the initiation of the
public comment period was issued on July 14, 1989. A notice of
the availability of these two documents was published in the
Plainview-Old Bethpage Herald on July 27, 1989, This Week on July
22, 1989, and the Bethpage Tribune on July 21, 1989. A public
comment period was held from July 14, 1989 through August 14,
1989. In addition, a public meeting was held on August 1, 1989.
At this meeting, representatives from EPA and the New York State
Department of Environmental Conservation answered questions about'
problems at the site and the remedial alternatives under
consideration. A response to the comments received during this
period is included in the Responsiveness Summary, which is part
of this Record-of Decision. This decision document presents the
selected remedial action for the Claremont Polychemical site, in
Old Bethpage, Nassau County, New York, chosen in accordance with
CERCLA, as amended by SARA and, to the extent practicable, the
National Contingency Plan. The decision for this site is based
on the administrative- record.
SCOPE AND ROLE OF OPERABLE UNIT
EPA divided the remedial work being conducted at the Claremont
Polychemical site into two operable units. The first operable
unit addresses overall site remediation (soil and groundwater
contamination) and is presently being conducted by Ebasco
Services, under EPA supervision. The second operable unit deals
only with the wastes held in containers, aboveground tanks,
treatment basins, and a sump discovered at the site. These
wastes pose a direct threat to human health and the environment
because of the risks from possible releases into the environment.
The purpose of this action is to eliminate present and future
exposure to the identified wastes.
SITE CHARACTERISTICS
Data generated during past and present investigations were
evaluated and incorporated into the present study. In general,
the wastes present at the Claremont Polychemical site
(containers, tanks, basins and sump) are a combination of raw
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materials, finished products and process wastes typical of this
type of production facility. The materials contained in the
tanks and basins are clearly associated with the Durogold
process. Runoff produced inside the building as a result of the
leaking roof appears to be the principal source of the liquid
found in the sump. , Although some process wastes may be present,
the assortment of containers appears to be dominated by raw
materials and finished products of high organic and inorganic
content.
It is difficult to assess the total volume of wastes at the site
because of the assortment of container sizes and the extent to
which they are completely full. The total amount of solid
material could be as high as one hundred thousand (100,000)
pounds. Liquid wastes and sludge are estimated at approximately
ten thousand (10,000) gallons and twenty-five thousand (25,000)
gallons, respectively. The .chemical composition of the wastes is
discussed below.
Containers %
In order to facilitate the discussion of the containers' sampling-
conducted as part of this operable unit, the results will be
presented as a function of the staging categories developed
during the removal action (see Table 3). One hundred and six
(ID'S) containers were sampled, at a rate of twenty (20%) percent
of the unknown and ten (10%) percent of each of the other known
categories. Each was analyzed for one or more of the following
parameters: volatile organic aromatic compounds (VOA's), base
neutral or extractable aromatic compounds (BNA's), metals,
cyanide and ignitability. A generalized summary of the hazardous
substances detected in containers is presented in Table 4.
Containers classified as organic solid consisted mostly of resins
and other polymers, some containing 1,2,4-trichlorobenzene. The
acid solid samples showed a high concentration of benzoic acid
and low concentrations of heavy metals. Of the caustic solid
samples analyzed, some contained zinc, lead, and chromium.
Inorganic pigment solid samples contained chromium, nickel and
lead. The chemical composition of the unknown solid samples
included arsenie and lead. Of the miscellaneous solid samples
analyzed, one contained 2-butanone and aluminum.
Organic liquid wastes consist mostly of resins and polymers
containing benzoic acid, toluene, xylene and methylene chloride.
Acid liquid samples were high in extractable organics. The
containers in the unknown liquid group presented concentrations
of compounds such as toluene, bis(2-ethylhexyl)phthalate,
chloroform, methylene chloride, tetrachloroethene, cadmium and
lead; two thirds of the samples tested were ignitable.
Miscellaneous liquid samples contained lead and chromium.
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Abovearound Tanks and Treatment Basins
Although there was some variation in the relative concentration
of the compounds found, the wastes held in the aboveground tanks
and treatment basins appear to have a common origin since their
chemical compositions are similar (see Table 5). Significant
amounts of both organic and inorganic compounds were detected
including several CERCLA hazardous substances such as methylene
chloride, bis(2-ethylhexyl)phthalate, copper, lead and zinc.
None of the samples analyzed exhibited characteristics of acidity
or reactivity.
Sump
With the exception of bis(2-ethylhexyl)phthalate (360 ug/kg), no
organic or inorganic compounds were detected.
SUMMARY OF SITE RISKS
The removal of the characterized wastes would reduce the threat
of release to the environment. The major concerns addressed in
this operable unit include:
o Threat of exposure and/or fire due to the presence of
explosive (aluminum powder) and flammable (e.g. 2-butanone)
substances;
o Release of hazardous substances into the environment as a
result of the continued deterioration of the containers
(drums, bags, etc.); .
o OverflOT of treatment basins and release of their hazardous
contents onto the ground with subsequent migration into the
aquifer; and
o Formation of atmospheres immediately dangerous to life and
health inside the building due to the escape of volatile
substances from deteriorated containers.
The risks considered in this operable unit were related to. the
safety of the workers on-site, and the safe transport of .wastes
to an off-site TSD facility. Any risk resulting from residues
left on-site will be evaluated in the risk assessment for the
RI/FS currently being conducted as part of the overall site
remediation. .
DESCRIPTION OF ALTERNATIVES ,
Following a screening of remedial technologies in accordance with
the NCP, three remedial alternatives were developed. Those
technologies not incorporated into the alternatives were
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eliminated due to technical considerations such as effectiveness,
implement ability and cost. The alternatives considered are
detailed below:
ALTERNATIVE 1 - NO ACTION
o No remedial measures would
be implemented
ALTERNATIVE 2 - CONTAINMENT
o Compatibility testing
o Bulking and consolidation
o On-site storage
ALTERNATIVE 3 - OFF-SITE TREATMENT
o Compatibility testing
o Bulking and consolidation
o Transportation off-site
o Treatment at off-site TSD facility; incineration,
solidification, landfill
A. Alternative 1 - No Action
Capital Cost: $ 0^
Annual O & M Cost: 0*
Present Worth Cost: 0*
Time to Implement: Immediately
Periodic evaluation and monitoring vould be conducted as
the overall remedy for the site and, therefore, would not
be included in the O & M cost for the alternatives considered for
this operable unit.
The no action alternative provides a baseline for comparing other
options. In this case, "No Action" would nean that no specific
remedial measures (i.e. treat, remove or contain) would be
implemented to minimize the threat posed by the wastes held in
the containers, -basins, aboveground tanks, and sump.
No attenuation of the source of contamination would be provided.
The threat to human health and the environment would persist as
the treatment basins continue to fill and possibly overflow; the
containers would continue to deteriorate. Reduction of toxicity,
mobility and volume would not be achieved.
The no action alternative is not considered protective of human
health and the environment.
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B. Alternative 2 - Containment
Capital Coat: $ 325,000^
Annual O & M Cost: 0*
Present Worth Cost: 325,000
Time to Implement: 6 months
*NOTE: Periodic evaluation and monitoring would be conducted as
part of the overall remedy for the site and, therefore, would not
be included in the O & M cost for this alternative.
The containment alternative entails performing on-site
compatibility testing involving the contents of each of the
holding units to determine which wastes would be consolidated.
Bulking and consolidation would segregate the wastes into general
disposal categories based on their physical and chemical
characteristics. Temporary storage tanks would; be brought to the
site and the holding units contents would be consolidated into a
relatively small number of tanks. The material which could not
be consolidated would be overpacked (if necessary) in 55-gallons
drums. The empty drums would be crushed and stored on-site. '
Interactions between the various components of the bulked waste
which could not be foreseen by the original compatibility testing
could occur during extended periods of storage.
This alternative was rejected for further evaluation in the FS
because it was not effective in protecting human health and the ;
environment. Containment of wastes on-site does not provide a
permanent solution to the problem as no significant reduction of
toxicity or volume of wastes would be achieved.
c. Alternative 3 - Off-site Treatment
Capital Cost: $ 1,339,000
Annual O & M Cost: 0
Present Worth Cost: . 1,339,000.
Time To Implement: 6 months
This alternative involves.performing on-site compatibility tests
on the contents_of each treatment basin, aboveground tank, sump
and container. ^Based on the information provided by the
compatibility check, the wastes would be segregated into general
disposal categories according to their physical and chemical
characteristics, and consolidated. The contents of the
aboveground tanks, basins and sump would be pumped into storage
tanks. Composite samples of the drums and/or bulked chemicals
from each waste stream would undergo rigorous analytical testing
to determine the most appropriate treatment/disposal methods.
The analytical results of the one hundred and six (1.06) samples
collected as part of RI/FS for this operable unit would be used
to -limit the amount of sampling.
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Once EPA selects the treatment technology and TSD facility most
appropriate for each waste stream, the contaminated material
would be transported to an approved Resource Conservation and
Recovery Act (RCRA) facility or to an appropriate waste disposal
facility. Several types of technologies (solidification,
stabilization, incineration, chemical/biological treatment,
landfill, etc.) would be used due to the variety of wastes
present (organic, inorganic and mixed wastes). The selected
treatment technologies would reduce or eliminate the toxicity,
mobility and volume of wastes.
Treatment technologies are well developed and highly effective
means of disposing of the types of hazardous wastes found at the
site. Lead time for acceptance at TSD facilities is dependent
upon the availability of capacity at commercial facilities, and
could extend the implementation period of this alternative.
However, long-term management would not be required since the
wastes would be removed from the site. This alternative is most
feasible when small volumes of hazardous waste are present, as is
the case at Claremont Polychemical. Monitoring would only be
required during sampling and handling operations. Permits for v
transportation to an off-site TSD facility would be obtained.
Treatment and/or disposal would be performed at a fully permitted
RCRA hazardous waste treatment and disposal facility. Wastes
would be disposed of in accordance with land disposal
restrictions. Since all the wastes would be treated/disposed
off-site, no treatment residue would be left on-site.
The empty drums would be crushed and sent to an off-site
facility. In order to prevent future accumulation of rainwater
in the>. treatment basins and sump, the connecting trenches/drains
would be covered or filled.
Since the specific types of technologies and the precise volume
of waste to be treated within each technology would be determined
at a later stage, the cost estimate has been conservatively based
assuming incineration is the means of treatment. Incineration is
usually the most cost intensive of the treatment technologies
considered and, therefore, would provide a conservative estimate
of the costs to be incurred as part of this remedy. The total
cost f.or this aetion is $1,339,000. This includes mobilization,
sampling, handling, disposal, demobilization, and other expenses.
SUMMJUY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
EPA has developed nine criteria (OSWER Directive 9355.3-01) to
evaluate potential alternatives to ensure all important
considerations are factored into remedy selection decisions.
They are summarized below:
o Overall protection of human health and the environment
8
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o Compliance with applicable or relevant and appropriate
requirements (ARARs)
o Long-term effectiveness and permanence
o Reduction of toxicity, mobility, or volume
o Short-term effectiveness
o Implementability
o Cost
o State acceptance
o Community acceptance
A summary of the comparative analysis of the alternatives is
presented in Table 6.
1. Overall Protection of Human Health and the Environment
Alternative 3 is considered fully responsive to this criterion
and to the identified remedial response objectives.
Removal of the wastes and treatment at an off-site facility
(alternative 3) would prevent their release to the environment
and would constitute excellent protection of both public health
and the environment. Whereas, the no action alternative would
not be protective of human health or the environment.
2. Compliance with ARARs Jk
Remedial alternative 3 would include the on-site testing of
wastes and some consolidation (as needed). Activities related to
the on-site handling and transportation/treatment of wastes at an
off-site TSD facility would be in compliance with the following
ARARs:
o RCRA 40 CFR Subpart 268 - Land Disposal Restrictions
o RCRA 40 CFR Part 263 - Standards Applicable to
Transport of Hazardous Wastes
o RCRA 40 CFR Part 264 - Standards for Owners and
Operators of Hazardous Waste Treatment., Storage, and
Disposal Facilities
o 6 NYCRR Part 372 - Hazardous Waste Manifest System &
Related Standards for Generators, Transporters and
Facilities
-------
o 6 NYCRR Subpart 373-1,2,3 - Final State Standards for
Owners and Operators of Hazardous Waste Treatment,
Storage and Disposal Facilities
o 6 NYCRR Part 371
The transportation and treatment of wastes at an off-site TSD
facility would be accomplished in accordance with New York State
hazardous waste management requirements. The off-site TSD
facility would be fully RCRA permitted and, therefore, would meet
applicable regulations. RCRA listed wastes would be treated
using specific technologies or specific treatment levels, as
appropriate, to comply with land disposal restrictions.
Alternative 1 (no action) would not meet ARARs related to the
storage of hazardous wastes.
3. Long-Term Effectiveness
Alternative 3 would aid in the long-term remediation of the site
as wastes would be removed, eliminating the potential threat to
human health and the environment. Any adverse impact on human
health associated with any remaining concentration of wastes
would be addressed as part of the overall RI/FS. There are no
adverse long-term effects on human health that would result from
the implementation of this alternative.
Off-site treatment (alternative 3) provides a permanent remedy,
and no long-term monitoring would be required after
implementation. Alternative 1 would not result in long-term
remediation of the site as deterioration of containers and
overflow of basins intodthe soil and groundwater could occur in
the future. W
4. Reduction of Toxicity. Mobility and Volume
Treatment represents a permanent remedy. Treatment would reduce
the toxicity, mobility and volume of the contaminants from the
basin, tanks,-sump and containers. The no action alternative
would not result in a reduction of toxicity, mobility or volume.
5. Short-Tarn Effectiveness
The short-term effectiveness concerns for the off-site treatment
alternative include human health threats, adverse impacts on the
environment, and safety of workers during implementation
activities. The major activities of this alternative are the
pumping of sludge contained in the sump, tanks and basins, the
consolidation of wastes, and the transport of wastes for off-site
treatment. A potential health threat to area residents would be
direct contact with spilled wastes. However, this exposure
pathway will be eliminated by restricting access to the site to
authorized personnel only. The implementation of the alternative
10
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would be monitored to ensure that all regulations are followed
and to minimize worker exposure. Therefore, the short-term human
health threat resulting from this alternative would not be
significant.
The short-term impacts of alternative 3 on the environment would
consist mostly of traffic-related problems during transportation.
Although decontaminated and covered, passage of trucks through
communities might raise community concerns.
Workers on-site during activities could be potentially exposed to
contaminants. To minimize and/or prevent such exposures, use of
personal protection equipment would be necessary.
No adverse impacts and threats to the human health or the
environment are foreseen as the result of implementing
alternative 3.
Alternative 1 would not directly improve the site environment or
minimize the exposure pathways.
6. Implementability
Alternative 3 would not require substantial construction,
institutional controls or a monitoring program since the bulk of
the activities would be conducted off-site. Commercial treatment
facilities are already in existence. No technological problems
should arise as all the treatment technologies are well
established and possess proven track records.
The quantity of waste to be treated from this site is relatively
small and is not expected to be affected by the general market
availability. However, depending on the TSD facility, a lead
time for waste acceptance at the treatment facility may be
needed.
7. Cost .
As several treatment technologies would be used, assumptions need
to be made in order to develop a conceptual cost for alternative
3. The most significant assumption is the use of incineration as
the treatment technology to treat/dispose of all the wastes.
Incineration is usually the most cost intensive treatment
technology and, therefore, will provide a conservative estimate
of the costs to be incurred as part of this remedy. The total
cost for this action is $1,339,000. A summary of the cost is
provided below.
Mobilization ,«... $ 14,000
Sampling, Handling & Disposal
Containers (drums, bags, etc.) $ 612,000
Tanks, Basins and Sump.. <, $ 258,000
11
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Demobilization $ 7,000
Contingency $ 345, ooo
Other Costs $ 103.000,
Total $ 1,339,000
O & M costs (evaluation, monitoring, etc.) for the alternatives
considered in this operable unit would be conducted under the
overall remedy. ;
8. State Acceptance
The State of New York concurs with the preferred alternative
selected, off-site treatment (see Appendix D). This alternative
is in agreement with the State's interest in public and
environmental protection, since the remedy utilizes permanent
treatment to the maximum extent practicable.
9. Community Acceptance :
The community has expressed its preference for Alternative ;3:
off-site treatment. Several concerns were raised during the
public comment period. These concerns are addressed in detail inv
the Responsiveness Summary (Appendix E). In general, the
principal concerns are related to potential health risk to the
people living or working around the s.ite.
SELECTED REMEDY
The selected remedy for the remediation of the wastes stored in
the containers, basins, aboveground tanks, and a sump located at
the Claremont Polychemical Superfund site.is Alternative 3: Off-
site Treatment. .
This remedy addresses one of the principal threats at the site,
namely, the potential release of contaminants to the environment
by removing the materials and treating them at an off-site TSD
facility.
Under this remedy, action would be taken to remove the wastes
held in the containers, basins, aboveground tanks, and sump from
the site and properly dispose of them in the most efficient and
least expensive manner. Bulking would be conducted to the extent
practical prior to disposal. Water movement into the basins
would be severed in order to avoid overflows and accumulation of
runoff. .
This action mitigates potential for explosion, deterioration of
containers, and overflow of treatment basins. Further
deterioration of the containers greatly increases the likelihood
that atmospheres immediately dangerous to life and health will be
exceeded inside the building, affecting the nearby workers. In
the event of fire and/or explosion, a toxic plume could develop
12
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threatening nearby residents or travelers.
The estimated cost for all tasks associated with this remedy is
$1,339,000. The tasks identified as part of this remedy are:
mobilization, sampling, handling, disposal and demobilization.
STATUTORY DETERMINATIONS
The remedy selected by EPA in consultation with NYSDEC, off-site
treatment, meets the statutory requirements of CERCLA section
121. A brief description of how the remedy complies with the
statutory requirements is presented below.
1. Overall Protection of Human Health and the Environment
Removal of the wastes and treatment at an off-site facility will
prevent their release to the environment and will constitute
excellent protection of both human health and the environment.
This action mitigates the potential for fire/explosion,
deterioration of containers, overflow of basins, and development
of hazardous atmospheres inside the building. The selected
remedy will not pose unacceptable short-term risks or cross-media
impacts.
2. Compliance with ARARs
This remedy will include the on-site testing of wastes and some
consolidation (as needed). Activities related to the
implementation of the selected remedy will be in compliance with
the following federal and State applicable regulations:
o RCRA 40 CFR Subpart 268 - Land Disposal Restrictions
o RCRA 40 CFR Part 263 - Standards Applicable to
Transport of Hazardous Wastes
o RCRA 40 CFR Part 264 - Standards for Owners and
Operators of Hazardous Waste Treatment, Storage, and
Disposal Facilities
o * NYCRR Part 372 - Hazardous Waste Manifest System &
Related Standards for Generators, Transporters and
Facilities
o 6 NYCRR Subpart 373-2 - Final State Standards for
Owners and Operators of Hazardous Waste Treatment,
Storage and Disposal Facilities
o 6 NYCRR Part 371
The transportation and treatment of wastes at an off-site TSD
facility will be accomplished in accordance with New York
13
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hazardous waste management requirements. The off-site TSD
facility will be fully RCRA permitted and, therefore, will meet
applicable regulations. RCRA listed wastes will be treated using
the best demonstrated available technology (BOAT) or to specific
treatment levels, as appropriate, in order to comply with RCRA
land disposal restrictions.
3. Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy, off-site treatment, utilizes permanent
solutions and treatment technologies to the maximum extent
applicable. Alternative 3 is considered to be a permanent
remedial action since the wastes will be permanently removed from
site. The potential for future release of the waste to the
environment will be eliminated. Treatment will reduce and/or
eliminate the toxicity, mobility and volume of the contaminants
from the basin, tanks, sump and containers.
No adverse impacts and threats to the human health and
environment are foreseen as the result of implementing this
alternative. Workers on-site during activities could potentially
be exposed to contaminants. However, to minimize and/or prevent
such exposures, personal protection equipment will be used.
This alternative will not require substantial construction,
institutional administration or a monitoring program since the
bulk of the activities will be conducted off-site. Commercial
facilities are already in existence. No technological problems
should arise as all the treatment technologies are well
established and possess a proven track record.
4. Preference for Treatment as the Principal Element
The selected remedy fully satisfies this criterion. The variety
of wastes found at the site indicates that several treatment
methods (e.g. incineration, solidification, etc.) will need to be
used. Incineration will be the preferred technology for those
materials high in organic content but low in metal content.
Those materials^primarily high in inorganics (metals) will be
treated and possibly landfilled in a RCRA approved facility.
5. . Cost Effectiveness
The selective remedy is the most cost effective of the
alternatives considered, and provides excellent protection of
human health and the environment. Based on the information
generated during the RI/FS, the estimated present cost for this
alternative is $1,339,000.
14
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DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Claremont Polychemical site was
released to the public in July 1989. The Proposed Plan
identified Alternative 3, off-site treatment, as the preferred
alternative. EPA reviewed all written and verbal comments
submitted during the public comment period. Upon review of these
comments, it was determined that no significant changes to the
selected remedy, as it was originally identified in the Proposed
Plan, were necessary.
15
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APPENDIX A: FIGURES
-------
COMMERCIAL
UQKT IhOUSTRY
S
SanapHv' ("*/"-
A" Sf
1000
1000
SCALE IN FEET
R » RECHARGE BASIN
ENVIRONMENTAL PROTECTION
A6ENCY
CLAAEMDNT PCUOCMJCAL FACILITY
FIGURE i
SITE LOCATION
-------
currtv witt
WASTE TREATMENT
DIFFUSION WELLS
CAtl
100
=a
fffi
0.8. ENVIRONMENTAL PROTECTION
AGENCY
CLANEMONT POLYCHEMICAL SITE
FIODRB
BITS
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APPENDIX B: TABLES
-------
Table 1. Historical summary of activities associated with the
Claremont Polychemical site
1966
Property
Activity
Fabrication/erection of
structural steel of lot 267
1967
1968
1969
1973
197.7
1979
1980
Profit Sharing Plan & Trust
Agreement of Claremont Poly-
Chemical Corp acquires
mortgage for lot 267 ($31,254)
Winding Rd Properties Inc.
becomes owner in fee of lot
267
Claremont Polychemical Corp.
releases/assigns to Winding Rd
Estates, Inc., land, buildings
and improvements: parts of
lot 267 & 286 ($!.)
Claremont Polychemical Corp.
grants/releases to Winding
Rd. Estates, Inc. lots 283 &
295 ($10).
Winding Rd Estates Inc. &
Winding Rd. Properties Inc.
enter into mortgage with
William Otte (trustee) to
secure payments ($55,754,62)
to creditors by Winding Rd
Recycling Corp., involving
lots 267 and 296 (receivership)
Fabrication/construction
on lot 267
Claremont Polychemical
operations commence at
Winding Rd facility
Claremont Polychemical
operations continue:
waste water treatment -
sanitary and metals from
Durogold process;
discharges via septic and
leaching systems; buried
tanks & piping used for
process solvents;
Leaching pools sampled
(Bureau of Water
Pollution Control.)
2000-3000 drums of
solvents, resins, inks
discovered on site.
October: Excavation of
discolored soil layer
(75 x 75 x 10 ft) and
spreading of it on plastic
sheeting; Nassau County
Health Dept. sampling
(soil, groundwater);
excavation stopped due to
receivership.
-------
1983 L&L Excavation & Maniac Woodward-Clyde Consultants
Leasing establish operations investigation of spill area
on site (approximate) for NY State DEC hazard
ranking.
1984 Velzy Associates
investigation of spill area
for Winding Rd. properties
1986 CA Rich Consultants
hydrogeolic investigation
of Claremont Polychemical
Facility for NY State Dept.
of Law; Nassau County
Health Dept. sampling
(soils)
1988 EPA starts RI/FS (OU-I) to
assess extent of soil and
groundwater pollution
(March)
1988 EPA conducts Removal Action
(October)
1989 EPA starts RI/FS (OU-II) to
evaluate disposal/treatment
of drums, bags, and content
of aboveground tanks and
treatment basins
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Table 2. Chemicals associated with the manufacturing processes at
Claremont Polychemical1, Old Bethpage, New York
PRODUCT
pigments &
ink/
Durpgold
RAW
MATERIALS
phthalates
vinyl resins
polyethylene
resins
ketones
alcohol
high flash
naphtha
copper
zinc
WASTE
PRODUCTS
mineral spirits
vinyl resins
solvents
solids
WASTE
TREATMENT
solvent recovery
zinc
bronze
coated alum-
inum powder
vinyl
stabilizers
aluminum solids in
sodium silicate low volume
barium oxide "none"
cadmium oxide
high flash
naphtha
ethyl-hexanoic
acid
para, tertiary- -.
butyl
benzoic acid
toluene
tetrachloroethy1ene
phosphoric acid,
soda ash for neu-
tralization
produced Cu & Zn
carbonates &
phosphates
none-dry process
Source: M. Neitlich, vice-president, meeting of. 6/20/88.
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Table 3. Classification used during drum staging and ovezpacking
at Claremont Polychemical, Old Bethpage, New York (7/12/88)
Liquid Solid
Organic Liquid Organic Solid
Unknown Liquid Unknown Solid
Miscellaneous Liquid Miscellaneous Solid
Acid Liquid Acid Solid
Caustic Solid
Inorganic Pigment Solid
Other
Explosive
Empty
-------
Table 4. Generalized summary of selected hazardous substances
detected in containers (drums, bags, etc.) sampled at Claremont
Polychemical, Old Bethpage New York (4/89)
Category
Organic Solid
Acid Solid
Caustic Solid
Inorganic Pigment
Solid
Unknown Solid
Organic Liquid
Unknown Liquid
Compound
Concentration
(mg/kg)
9,800
2,520
100
74
Benzoic Acid
1,2,4 Trichlorobenzene
Phenol
1,4 Dichlorobenzene *
Benzoic Acid 47,000
Zinc 620,000
Lead 5,336
Chromium 3,861
Zinc 440,000
Lead 78,000
Chromium 67,000
Lead 460,000
Arsenic 140,000
Cadmium 2,290
Bis(2-ethylhexyl)Phthalate 16,000
Phenol 6,000
Toluene 230,000
Xylene 130,000
Methylene Chloride 6,250
Bis(2-ethylhexyl)Phthalate 912,000
2-Butanone .- 220,000
Toluene 199,850
Tetrachloroethene 65,620.
Methylene Chloride . 3,125
Zinc 56,500
Lead 3,867
Arsenic 1,068
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Table SB. Chemical composition of the sludge contained in the
treatment basins at Claremont Polychemical, Old Bethpage, New
York (6/7/88)
Concentration
Basin D Basin C
Basin B
Volatile Oraanics (ug/kg)
Vinyl Chloride*
Acetone*
Methylene Chloride*
1,2-Dichloroethene*
Trichloroethene*
2-Butanone*
4-Methyl,2-Pentanone*
Tetrachloroethene*
Toluene*
Benzene*
Semi-volatile Oraanics (ug/kg)
Pyrene* 1,800J
Bis(2-ethyIhexy1)
phthalate* 130,00
Diethylphthalate* BD
Pesticides (ug/kg)
None detected
Metals (m
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Table 6. Summary of comparative analysis of .remedial alternatives
Remedial Alternative
Protection of Human
Health and the
Environment
Compliance with ARARs
Long-Term Effectiveness
Alternative 1
No Action
Does not contribute to
protection of human
health and the
environment
Does not comply with
ARARs
No long-term beneficial
effectiveness results
from this alternative
Alternative 3
Off-Site Treatment
Destroys and/or treats
contaminants resulting
in significant reduction
of risks to human health
and environment
All ARARs would be meet
Eliminates risks by
eliminating wastes
No long-term adverse
impacts on the
environment
No long-term monitoring
required
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Table 6. Summary of comparative analysis of remedial alternatives (continued)
Remedial Alternative
Reduction of Toxicity,
Nobility and Volume
Short-term effectiveness Implementability
Alternative 1
No Action
Alternative 3
Off-Site Treatment
No reduction of
toxicity, mobility and
volume would be attained
Alternative results in
elimination and/or
reduction of toxicity,
mobility and volume
No short-term beneficial
or adverse impacts on
public health ^nd.the :,.,
environmeri^s result from
this alternative
Attains immediate risk
reduction to human
health and environment
Short-term effectiveness
relative to public
health risks, the
environment and safety
to workers are limited
to those resulting from
sampling, handling and
transportation of the
wastes. These can be
easily mitigated by
implementation of
control measurements
such as confining the
operation area and use
of personal protection
equipment.
Traffic control and
spill preventive
measures will minimize
any adverse
environmental impact.
No substantial
construction,
institutional ;.~:
administration or
monitoring is required
Treatment techniques are
well developed, proven
and commercially
available
Commercial availability
may be limited for a
large quantity of waste,
but would not pose a
problem for the
relatively small
quantity of wastes found
at the Claremont site.
-------
Table 6. Summary of comparative analysis of remedial alternatives (continued)
Coat (thousands)
remedial Alternative Capital o * M North State Acceptance Community Acceptance
Alternative 1 kO 0 0 Low State acceptance Low community acceptance
Jo Action
Alternative 3 $ 1,339 0 $ 1,339 High State acceptance High community
iff-Site Treatment acceptance
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APPENDIX C: ADMINISTRATIVE RECC&D INDEX
-------
CLAREMONT POLYCHEMICAL SITE
SECOND OPERABLE UNIT
ADMINISTRATIVE RECORD FILE*
INDEX OF DOCUMENTS
REMOVAL RESPONSE
Correspondence
P. 1-136 Report:: On-Scene Coordinator's Report. Claremont
Polychemical Corporation. Old Bethpaae. Nassau
County. New York, prepared by Mr. Nick Magriples,
U.S. EPA, (undated).
REMEDIAL INVESTIGATION
Remedial Investigation Reports
\
P. 137-262 Report: Final Remedial Investigation Report.
Second Operable Unit OU-II. Clareroont Polycheaical
Site. New York, prepared by U.S. EPA, 7/89.
References are listed on P. 190.
FEASIBILITY STUDY
Feasibility Study Reports
P. 263-346 Report: Final Feasibility Study Report. Second
Operable Unit OU-II. Clarenont Polychemical
Superfund Site. Old Bethpacre. Nassau County. New
York, prepared by U.S. EPA, 7/89. References are
listed on P. 312.
Correspondence
P. 347-347 Letter to Mr. Carlos Ramos, U.S.. EPA, from Mr.
William G. Lowden, State of New York Department of
Health, re: Comments on the Draft Proposed
Remedial Action Plan and the Draft Feasibility
Study Report, 7/10/89.
* Administrative Record File available 8/22/89.
-Note: Company or organizational affiliation is mentioned only
when it appears in the record.
-------
P. 348-349 Letter to Mr. Carlos R. Ramos, U.S. EPA, from Ms.
Patricia Primi, State of New York Department of
Law, re: Comments on the Draft Remedial
Investigation Report OU-II and the Draft
Feasibility Study Report, 7/12/89.
P. 350-350 Letter to Mr. Carlos R. Ramos, U.S. EPA, from Mr.
Michael J. O'Toole, Jr., New York State Department
of Environmental Conservation, re: Comments on
the Draft Remedial Investigation and the Draft
Feasibility Study Report, 7/14/89.
PUBLIC PARTICIPATION
Proposed Remedial Action Plans
P. 351-358 Report: Proposed Remedial Action Plan, prepared
by U.S. EPA, 7/89.
-------
APPENDIX D: NYSDEC LETTER OF CONCURRENCE
-------
New York State Department of Environmental Conservation
SO Wolf Road, Albany, New York 12233**>'0
Thomas C. Jorilng
Commissioner
QCp 0 9
Mr. Stephen D. Luftig, P.E. «tr * *
Director
Emergency & Remedial Response Division
U.S. Environmental Protection Agency
Region II
26 Federal Plaza
New York, NY 10278
Dear Mr. Luftig:
Re: Record of Decision (ROD)
Claremont Polychemical #130015
The New York State Department of Environmental Conservation (NYSDEC) has
reviewed the draft Record of Decision for the referenced site. I am
pleased to advise you that the NYSDEC concurs with the selected remedy.
Since the short schedule will not allow a review of the final ROD before
the September 29, 1989 deadline, my acceptance of the remedy is based on
our reading of the draft copy. In an effort to avoid a misunderstanding
between our offices, the remedy that will appear In the final ROD should
be as follows:
DESCRIPTION OF SEL»ED REMEDY
This-operable unit is one of two being conducted at the site. The
first operable unit.at this site involves overall site remediation,
including soil and groundwater. This operable unit addresses the
wastes held In containers (drums, bags, etc.), above-ground tanks,
wastewater treatment basins, and a sump discovered at the site.
The major components of the selected remedy include:
Compatibility testing of all wastes;
Bulking and consolidation of compatible wastes;
Transportation of wastes to an off-site treatment, storage
^and disposal (TSD) facility; and
Treatment at TSD facility by incineration, solidification,
landfill, etc.
-------
Mr. Stephen D. Luftig, P.E.
Page 2
Please contact Mr. Michael J. O'Toole, Jr., P.E., at (518) 457-5861 if
you have any questions.
Sincerely,
Edward 0. Sullivan
Deputy Commissioner
cc:
William McCabe, USEPA, Region II
Doug Garbarini, USEPA, Region II
Carlos Ramos, USEPA, Region II
-------
APPENDIX E: RESPONSIVENESS SUMMARY
-------
Claremont Polychemical Site
Old Bethpage, Nassau County
New York
The U.S. Environmental Protection Agency (EPA) held a public
comment period,from July 14, 1989 through August 14, 1989 to
receive comments from interested parties on the final Remedial
Investigation and Feasibility Study (RI/FS) reports and Proposed
Plan for the Claremont Polychemical Superfund site.
A public participation meeting was conducted by EPA on August 1,
1989 at the Old Bethpage Village Restoration, Old Bethpage, New
York to discuss the remedial alternatives, to present EPA's
preferred alternative for the remediation of the site, and to
provide an opportunity to the interested parties to present oral
comments and questions to EPA.
This responsiveness summary provides a summary of citizen's
comments and concerns about the site as raised during the public
comment period, and the EPA's responses to those comments. All
documents summarized in the document will be factored into EPA's
final decision for selection of the remedial activities for
cleanup of the Claremont Polychemical site.
This responsiveness summary is divided into the following
sections:
I. Responsiveness Summary Overview. This section briefly
describes the background of the Claremont Polychemical
site and outlines the proposed alternatives.
II. .Background on Community Involvem0"* ^ad Concerns. This
section-provides a brief history of community interests
and concerns regarding the Claremont. Polychemical site.
III. Summary of Major Questions and Comments Received During
the Public Comment Period and EPA's Responses. This
section summarizes comments submitted to EPA at the
public^meeting and during the.comment period and
provides EPA's response to these comments.
IV.. Written Correspondence Received During the Public
Comment Period and EPA's Responses. This section
presents written comments received by EPA and provides
EPA's responses to these issues.
I. RESPONSIVENESS SUMMARY OVERVIEW
Site Background . -.
The Claremont Polychemical site is an abandoned production
facility located in central Long Island, Village of Old Bethpage,
Town of Oyster Bay,.Nassau County, New York. The facility is
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situated in an area comprised of light industrial, commercial and
institutional properties (Oyster Bay Solid Waste Disposal
Complex, SUNY Agricultural and Technical College at Farmingdale,
and Bethpage State Park). The Suffolk County line is approxim-
ately 800 feet east of the site.
o
From 1968 until its closure in 1980, Claremont Polychemical was
dedicated to the manufacture of inks and pigments for plastics,
coated metallic flakes, and vinyl stabilizers. The principal
wastes generated were organic solvents, resins and wash wastes
(mineral spirits).
Concern for contamination was linked to a discovery in 1979 by
the Nassau County Department of Health (NCDH) of 2,000 to 3,000
drums scattered about, some uncovered and others leaking. By
September 1980 most of the drums were sorted and either removed
from the site, or reused in the plant. Some of the material was
burned in the plant's boiler. NCDH inspectors noted at the time
that an area east of the building (spill area) was contaminated
with organic .solvents as a result of accidental.and/or incidental
spills and discharges. A subsequent removal action excavated the
upper ten feet of a seventy-five foot by seventy-five foot area. »
The excavated material was placed on a plastic liner. Over the
years, this liner has degraded and no longer forms an impermeable
layer. Groundwater samples from a monitoring well installed at
the time indicated the presence of groundwater contamination
directly under the site.
Claremont Polychemical and its affiliated companies entered into
receivership in 1980. In 1983, Woodward-Clyde Consultants, under
the direction of. the New York State Department of Environmental
Conservation, conducted a preliminary investigation of the site.
In 1984, Velzy Associates conducted a limited study of the site
for the property owners. Additional 40rk was performed by C.A'.
Rich Consultants in response to a request for information by the
U.S. Bankruptcy Court. .For the last four to five years two
tenant businesses have been operating at the site under the
supervision of the New York'-Bankruptcy Court.
EPA started work on the overall site remediation RI/FS on March
1988. Oh June 77 1988 EPA conducted a site visit, and later
completed an inventory of the approximately 700 drums and bags
found on-site. The presence of five treatment basins and three
aboveground tanks containing liquid and sludge was confirmed.
The drums and bags hold numerous chemicals, including aluminum
metal powder, flammable solvents, cadmium, zinc, antimony and
lead based pigments, epoxy, {acrylic and vinyl resins, organic
based inks, and other unknown compounds. At the time many of the
containers were open, leaking, or in poor condition.
As part of a removal action conducted in October 1988, EPA
sampled the content of the treatment basins, aboveground tanks,
-------
some of the drums, the floors, and the air inside the building.
The liquid content of the treatment basins was removed, and the
structures covered and snow-fenced. The drums and bags were
classified in general categories based on their labels and
information obtained from the owner of the company (i.e. organic,
explosive, acid, etc.), staged, over-packed as necessary, and
secured inside the building pending disposal.
A second operable unit RI/FS was started on March 1989 to deal
with the wastes held in basins, aboveground tanks, containers and
a sump. The results of this RI/FS indicates that the chemicals
(drums, bags, tanks, etc.) are a combination of raw materials,
finished products, and process wastes typical of this type of
production facility. The chemical nature of the wastes varied
from completely inorganic (e.g. lead, chromium and aluminum) to
completely organic (e.g. phthalates and 2-butanone).
Summary of Remedial Alternatives
The remedial alternatives considered for the Claremont
Polychemical site are described in the RI/FS and Proposed Plan
for this operable unit (referred as operable unit two). Those
alternatives considered are detailed below:
ALTERNATIVE 1 - NO ACTION
o No remedial measures would
be implemented
ALTERNATIVE 2 - CONTAINMENT
o Compatibility testing of all wastes
o Bulking and consolidation of compatible wastes
o On-site storage
ALTERNATIVE 3 - OFF-SITE TREATMENT
o Compatibility testing of all wastes
o Bulking and consolidation of compatible wastes
o Transportation of wastes to an off-site treatment, storage
and disposal (TSD) facility; and
o Treatment at TSD facility by incineration, solidification,
landfill, etc.
EPA, in concurrence with New York State Department of
Environmental Conservation, chose alternative 3: Off-site
Treatment as the selected remedial action for the second operable
unit at the Claremont Polychemical site. Based on the current
information, this alternative provides the best protection of
human health and the environment.
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II. BACKGROUND OF COMMUNITY INVOLVEMENT
Community interest in the Claremont Polychemical site has been
moderate throughout the RI/FS process and removal actions.
Locally, the community has been active at public meetings related
to various environmental problems associated with the Old
Bethpage Landfill site and the Nassau County Fire Service
Academy. Several remedial activities are currently being
conducted at the landfill, including containment of groundwater
contamination. The community has been aware of the Claremont
Polychemical site through newspaper articles, fact sheets, press
releases, public notices, and public information meetings.
Because of the relatively close proximity of all the mentioned
sites, the community has been vocal and has viewed all these
sites as one comprehensive problem. Organized groups include:
Citizens for Pure Water in South Farmingdale, South Farmingdale
and Plainview Water Districts.
The major concerns and issues expressed by the community are:
o Health risks associated with the presence of the wastes
contained in the aboveground tanks, basins, containers
and a sump. Citizens expressed concern over possible ^
threats to their health and safety due to the above
mentioned wastes.
o Migration of contamination through crroundwater. Local
officials and public in general have focussed their
concern on the potential for groundwater contamination
and the impact on the drinking water supply wells
located in the area.
III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING
THE PUBLIC COMMENT PERIOD AND EPA'S RESPONSES
Comments raised during the public comment period are summarized
below by topic of relevance*. The public comment period was held
from July 14, 1989 to August 14, 1989 to receive comments on
EPA's final Remedial Investigation and Feasibility Study (RI/FS)
and Proposed Plan reports for the Claremont Polychemical site.
Health and Safety
Comment: A citizen noted that for the last twenty years he
has worked for a company located next to the Claremont
Polychemical site. He wanted to know how dangerous the
Claremont site is to the people working or living around
this area.
EPA Response: Precautions will be taken during the
implementation of the selected alternative. Access to the
property will be restricted to authorized .personnel only and
all actions will be coordinated with local and state
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agencies. By taking care first of the identified wastes
(containers, etc.) EPA reduces the risk to human health and
the environment due to releases of hazardous wastes. In
addition, on October 1988, EPA conducted air monitoring in
the property. The results indicate that the contaminants
found in the air do not pose a significant threat to the
health of workers on-site or in the vicinity of the site. A
comprehensive risk assessment being conducted as part of the
overall site remediation will address this issue in detail.
Groundwater Contamination
Comment: A local official asked how deep the groundwater
contamination was.
EPA Response: EPA has taken samples from existing and newly
installed monitoring wells on-site and off-site. The data
is currently in the data validation stage and, therefore,
not available at this moment. This information is not part
of the operable unit discussed, however it will be part of
the RI/FS for the overall site remediation.
Comment: A local official asked when the groundwater reportv
would be issued and how he could obtain a copy of this
information.
EPA Response: The RI and FS reports containing information
related to overall site remediation, including nature and
extent of soil and groundwater contamination, are scheduled
to be available next spring. EPA will notify the community
of the availability of this information through the issuance
of press releases; In addition, all interested parties.can
request that EPA include them in the site mailing list.'-.
Comment: A local official asked if EPA would .consider
treating any plume of groundwater associated with the
Claremont Polychemical site. . '
EPA Response: This issue will be addressed in the near
future once we get the RI/FS reports for the overall site
remediation. However, if a plume is found EPA will evaluate
all potential remedial actions needed including treating the
water to drinking water standards.
--
Selected Remedy
Comment: A local town official concurred with EPA selected
remedy for the treatment/disposal of the wastes held in the
basins, aboveground tanks, containers and a sump.
EPA Response: Comment noted.
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Comment: A local citizen group agreed with the selected
remedy. They also recommended soil sampling at the site,
and groundwater monitoring in and around the site.
EPA Response: EPA has completed extensive surface and
subsurface soil sampling at the site. Also sampled were
forty-one (41) new and existing monitoring wells on-site as
well as off-site. This information will be available as
part of the RI/FS for the overall site remediation.
Other Comments
Comment: A local resident asked why has taken EPA so long
to address the pollution problems related the Claremont
Polychemical site.
EPA Response: EPA involvement on the site started in 1984
when the site was originally proposed for the National
Priority List, and subsequently accepted in June 1986. EPA
got the site lead in 1986 and started the RI/FS in March
1988. It generally takes two (2) years to complete the
RI/FS. This time is needed in order to complete a good
characterization of the site. The implementation of the
current remedy (treatment of wastes off-site) is being
conducted in a shorter time frame and, therefore, will
positively impact site remediation by reducing potential
risks.
EPA Response: A resident inquired about.a notice he
received announcing the tax sale of the Claremont property.
He wanted to know why the Nassau County didn't notify him
that the property was contaminated.
EPA Response? EPA is unaware of any such notice and^could
not comment, on this in particular. However, it shourc be
noted that Claremont Polychemical and its affiliated
companies are in bankruptcy court, and' any transaction
related to this property will be overseen by the bankruptcy
court.
Comment: A resident asked how the work being, conducted at
the site will affect the current tenants.
EPA Response: To this moment EPA has been able to perform
its studies without disrupting present tenants* Future
status of. tenants will depend on the activities to be
conducted at the site. '-;=."
XV. WRITTEN CORRESPONDENCE RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND EPA'8 RESPONSES
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South Farmingdale Water District
4O Langdon Road
Farmingdale. N. Y. 1 1 735-30OO
Telephone 51 6-2 49-333O Fax 516-249-9O53
CorrvTMBionars Amid Lntriad. Superintendent
Leonard Conesartjnopoli, ^f^ffj
Gerard F. MoCormack ' Manager
John H. Bates OaraWine Batch. Office Manager
Robert J. Sumer
August 1, 1989
Carlos R. Ramos
Reaedial Project Manager
U. S. Environmental Protection Agency
26 Federal Plaza - Room 747
New York, NY 10278
Re: CLAREMONT POLYCHEMICAL
SUPERFUND SITE
' ". i
Dear Mr. Ramos:
The South Farmingdale Water District is municipal
Water District that provides a public water supply to 44,500
consumers from 11 deep magothy formation veils. We have
expressed concern in the past about the CLAREMONT POLY-
CHEMICAL SUPERFUND SITE since our Vater District with its
deep veils are located to the aouth or generally down-
gradient.
Plant 5 of the Water District vhich contains two
deep veils (N7515 ft N7516 are 347 ft 584 feet deep
respectively) are the closest to the Claremont Polychemical
Superfund Siteor about 11,500 feet to the aouth. With
the alow horizontal movement of groundvater of about 1/2
foot per day ' it vould take 62 years for a contaminated
plume to reach our Plant 5. If ve consider groundvater
pollution starting . vhen Claremont Polycheaical commenced
operation* in 1969 this pollution might reach the
District's Plant 5 by the year 2031. The saving grace for
the South Faraingdale Water District ia that the general
flov of groundvater in that area is south-southeast vhich
means that any plumes of contamination vill probably miss
the South Farmingdale Water District veil sites.
Hovever even if the South Farmingdale Water District
is not impacted in the future by the Clareaont Polychemical
Snperfund Site veils of water utilities to our north and
east may be contaminated by this groundvater pollution. We
understand that during its operation Claremont Chemicals
utilized many underground tanks including a 6,000 gallon
steel tank of toluene plus a 6,000 gallon steel tank of MEK
as part of their ink process.
CONSFRVF NOW FHR R F! (PC
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South Farmingdato Water District
Carlos R. Ramos, USEPA
August 1, 1989
Page Two
We understand that the Nassau County Health Department
discovered and had between 2,000-3,000 drums removed from
this Claremont Chemical site between May and September 1980.
A further June 1988 site inspection by E.P.A. uncovered an
additional 470 drums plus containers of pigments and
solvents plus 230 bags of dry chemicals plus 3 above
ground tanks plus a 5 section wastewater treatment basin.
With chemicals such as 71% weight/weight of 4-methyl 2-
pentanone WE AGREE that they should all be removed from
this Superfund Site.
With the "sole source" aquifer on Long Island and
the need to protect our groundwater for future generations -
- WE SUPPORT ALTERNATIVE 3 OJF-SITE TREATMENT to
commence immediately on the proposed six month time frame to
completion.
PLEASE ADVISE US of your decision and when the work
is completed.
THANK TOU.
Very truly yours,
BOARD OF WATER COMMISSIONERS
SOUTH FARMINGDALE WATER DISTRICT
Commissioner Gerard T. McCormack
Chairman
GFM:es
-------
8 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
V
* JACOB K. jAvrrs FEDERAL BULDING
NEW YORK. NEW YORK 10278
AUG 2 9 1933
Gerald F. McConnack
Chairman
Board of Commissioners
South Farmingdale Water District
40 Langdon Road
Farmingdale, NY 11735-3000
Re: Claremont Polychemical Site Remedial Investigation and
Feasibility Study, Second Operable Unit
Dear Mr. McCormack:
\
Thank you for your letter of August 1, 1989 regarding the
Remedial Investigation/Feasibility Study (RI/FS) for the second
operable unit performed at the Claremont Polychemical site. Your
comments have been incorporated in the Responsiveness Summary
prepared by EPA to document comments raised by the community
during the public comment period.
If you have additional questions or comments, please feel free to
contact me at (212) 264-5636.
Sincerely,
Carlos R. Ramos
Remedial Project Manager
Eastern New York/Caribbean
Remedial Action Section
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ggzCLAREMONT POLTCHEMICAL SITE August 11,1979
Mr. Carlo* R. Ramos/ Remedial Project Manager
U.S. Environmental Protection Agency
26 Federal Plaza, Room 747
Nev York, N.Y. 10278
Dear Sir;
My comments shall be in an entirely different vein than the
one requested. But in a vay I believe it is more important to
find out hov this site vas allowed to get into this condition
and finally vind up on a national priorities list of hazardous
vaste sites. Maybe then, ve could see vhere the system isn't work-
ing and vhat needs to be addressed. I would like to Jcnov which
agency or agencies should be held accountable for permitting
this company to operate ins.uch an irresponsible manner. There
seems to be a pattern in Nassau County where companies are
allowed to operate with little or no supervision and their
crimes are not discovered for many years. Then it seems to take
many more years before a cleanup is started.
In November 1975 or was it 1979, we are given both dates
Nassau County Health Department discovered 2,000/3,000 drums
scattered bout, some uncovered and others leaking or lying
on their sides. How many site inspections did the N.C.D.H. make
between 1968 and 1975 or 1979? This mess at this site wasn't
accomplished overnight. Why didn't the health dep't discover
this contamination a lot sooner and indoing so prevent it
from getting to this magnitude?
This company went out of business in 1980. Why did it
take E.P.A. 8 years to investigate this site? Has no one in-
spected the liner which held the excavated, contaminated soil
for the last 8 or 9 years? When was the groundwater contamin-
ation under the liner site discovered?
What are the steps taken before a site finds itself on a
superfund priority list? Are the accountable roles clearly
defined for those agencies that are supposed to be protecting
the peoples' health?
If you cannot answer some of the questions I have raised,
perhaps you can advise me who can.
I respectfully request that this inquiry also be made part
of the record and the answers to those questions I raised also
be made part of that same record.
.Hoping to receive a prompt reply, I am,
Line
>efden
216"Sullivan Ave.
Farmingdale, N.Y. 11735
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
JACOB K. JAVrrS FEDERAL BULGING
NEW YORK. NEW YORK 10278
>.«,-,
Betty Seiden
218 Sullivan Avenue
Farmingdale, New York 11735
Re: Claremont Polychemical Site Remedial Investigation and
Feasibility Study, Second Operable Unit
Dear Ms. Seiden:
Thank you for your letter of August 11, 1989 regarding the
Remedial Investigation/Feasibility Study (RI/FS) for the second
operable unit performed at the Claremont Polychemical site. Your
comments have been incorporated in the Responsiveness Summary v
prepared by EPA to document comments raised by the public during
the comment period.
As requested, summarized below are EPA's response to your
'comments.
Comment 1. Origin of contamination at the site
According to the information provided to EPA by the Nassau County
Department of Health (NCDH),' the presence at the site of 2,000-
3,000 drums was discovered during an inspection conducted by NCDH
officials in November 1979. A typographical error is responsible
for the inconsistency of dates you found between the executive
summary and the text of the RI/FS reports. We are sending an
errata sheet to the document repository (Old Bethpage-Plainview
Library) to be attached to these documents. Other questions
related to actions taken by NCDH during the operation of the
facility should be addressed to Mr. Joseph Schechter of the
Nassau County Department of Health at (516) 535-2406.
Comment 2. Chronology of events at the site
The Claremont Polychemical Corporation entered into bankruptcy
proceedings in 1980. From 1980 to 1986 the State of New York
attempted to negotiate an agreement with the site owners to fund
the RI/FS. The State of New York transferred the lead on the site
to EPA in 1986, and funds for the RI/FS were allocated in 1988.
This RI/FS is currently in progress and deals with overall site
remediation, including soil and groundwater. A second RI/FS (OU-
II) was completed in July 1989 to deal with wastes held in
containers, basins, aboveground tanks, and a sump. The selected
remedial action for handling the wastes identified in OU-II is
off-site treatment.
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nt 3. Condition of liner used to place excavated soils, anfl
first: indication of aroundwater contamination
In 1980 and under the supervision of NCDH, Claremont Polychemical
Corporation excavated the upper ten feet of a seventy-five foot
by seventy-five foot area. The excavated material was placed on
polyethylene liners. According to a C.A. Rich report prepared in
1986, (Hydrogeologic Investigation of the Former Claremont
Polychemical Facility, Old Bethpage, New York), the liners lost
their impermeability due to degradation. It should be noted that
the long term effectiveness of the synthetic liners is very
limited due to natural factors (e.g. weathering, microbial
activity, ruptures, etc.) and interactions with contaminants in
the soil. A limited number of groundvater samples collected in
1980 were the first to suggest the presence of groundvater
contamination directly below the spill area.
Comment 4. Process to get a site on the National Priority List
Remedial response is a long and complicated process. After
learning of a site, EPA1s first step is to review all available
information about the site. This process is called a preliminary
assessment, and if this study indicates that there may be a
hazardous waste problem that may pose a risk to human health and
the environment, EPA orders a site inspection. These inspections
include visiting the site, sampling, and documenting the site
layout and terrain. This information is used to rank the risks
associated with a site. Sites that exhibit risks which are
significant enough to warrant further investigation are proposed
to the National Priority List (NPL). After a public comment
period, sites that meet established criteria will be placed on
the final NPL.
Once again, thank you for your comments. If you have additional .
questions or comments, please feel free to contact m>» at (212)
264-5636.
Sincerely,
Carlos R. Ramos ,
Remedial Project Manager
Eastern New YorK/Caribbean
Remedial Action Section
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or COMMISSIONERS
FLAINVICW WATCH DISTRICT
to MANCTTO HILU HOAO
N. Y.
««
August 23. 1989
Mr. Carlos R. Ramos
Remedial Project Manager
U.S. Environmental Protection Agency
26 Federal Plaza, Room 747
New York. N.Y. 10278
Re: Claremont: Polychemical Sunerfund Site
Dear Mr. Raroo:
The Plainview Water District would like to ccmnent on the
Claremont Polychemical Superfund Site.
Considering the general flow of ground water In the area, the
Plainview Water District wells would most likely not be susceptible
to the Polychemical pollution plume. However, the Plainview Water
District has a history of being actively involved in fighting
pollution. As we are sure the E.P.A. is aware, our status as a
iter sole source aquifer makes us unique- we live on the water
drink. As a supplier of potable water to the residents of our
listrict, it would be .irresponsible for us to disregard this pollution
problem. We are strongly recuuiuendlng, ALTERNATIVE 3: OFF-SITE TREATMENT,
which should begin as soon as possible. Considering the magnitude of the
problem at Polychemical, this is the only alternative we can endorse.
We would like to bring to your attention one final thought
regarding the hearing notice. The Plainview Water District was
never notified about the scheduled.hearing. As an Interested party
in close proximity to the site, we find this to be unacceptable
and would request that the EPA notify all water districts in the
'affected and surrounding area well before when hearings such as this
are scheduled and provide necessary documentation In advance.
Sincerely,
BOARD OF COMMISSIONERS
PLAINVIEW WATER DISTRICT
Donald A. Rosen'. Chairman
Bernard Chetkof, Treasurer
John C. Edwards, Secretary
-O-M- P'-ft"
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II si
JACOB K. JAVITS FEDERAL BULGING $
NEW YORK. NEW YORK 10278 f
AUG 2 9 19S3 '!
Donald A. Rosen V
Chairman '>"
Board of Commissioners -
Plainview Water District ,
10 Maneto Hill Road
Plainview, NY 11803
Re: Claremont Polychemical Site Remedial Investigation and
Feasibility Study, Second Operable Unit K
Dear Mr. Rosed: f/
Thank you for your letter of August 11, 1989 regarding the
Remedial Investigation/Feasibility Study (RI/FS) for the second
operable unit performed at the Claremont Polychemical site. Your
comments have been incorporated in the Responsiveness Summary
prepared by EPA to document comments raised by the community
during the public comment period. X--. -
A Community Relations Plan (CRP) was prepared for. the Claremont
Polychemical site in order to provide the community with timely
information concerning developments at the site. As part of the
CRP, EPA has issued fact sheets and press releases. In addition
EPA published public notices in local newspapers)-.informing and
inviting the public to provide input on Superfund actions at the
tiite. A mailing list was also developed based on input from local
citizen groups, government officials, and direct.requests from
individual or interested parties. In the past, announcements
regarding the Claremont Polychemical site have been mailed to Mr.
Bernard Chetkof, treasurer, Plainview Water District. We will
ttlso add your name to our mailing list.
Once again, thank you for your comments. If you have additional
questions or comments, please feel free to contact me at (212)
264-5636.
Sincerely,
Carlos R. Ramos
Remedial Project Manager
Eastern New York/Caribbean
Remedial Action Section
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