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
   ANSI-Z39.18)
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                                                     Department of Commerce

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                  DO NOT PRINT THESE INSTRUCTIONS AS A PAGE IN A REPORT


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     the performing organization.            .                                        .

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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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 14.  Performing Organization Code. Leave blank.                   .

 15.  Supplementary Notes. Enter Inforrmitlor not Included elsewhere but useful, such as:^repared In cooperation with... Translation
     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-
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     majority of documents are multldlsclpllnary In nature, the primary Field/Group assignments) will be the specific discipline,
     area of human endeavor,, or type of physical object The applications) will be cross-referenced with secondary Field/Group
     assignments that will follow the primary posting(s).                              -_•-

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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
                                                              SanapH—v'  ("*/"-
                                                                    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

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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.

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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

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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
-------
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.

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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.

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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.

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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

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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,

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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 Site—or  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

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      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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