United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-90/123
September 1990
oEPA
Superfund
Record of Decision:
Claremont Polychemical, NY
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT Na
EPA/ROD/R02-90/123
3. Recipient. Accaulon No.
4. TMeendSubMe
SUPERFUND RECORD OF DECISION
Claremont Polychemical, NY
Second Remedial Action - Final
i. Report Dste
09/28/90
7. AiMiorte)
a Performing Organization Rspt No.
9. Performing OrgdrriaUon Nun* end Address
10. Pfo|ect/Tssk/Work Unit No.
11. ContrsctfC) or Grsnt
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EPA/ROD/R02-90/123
Claremont Polychemical, NY
Second Remedial Action - Final
Abstract (continued)
water and soil/wastes contained onsite in drums and holding basins. The primary
contaminants of concern affecting the soil, debris, and ground water are VOCs including
PCE, TCE, toluene, and xylenes; other organics; metals including arsenic, chromium, and
lead; and inorganics including asbestos.
The selected remedial action for this site includes excavation and onsite treatment of
1,600 cubic yards of contaminated soil using low temperature enhanced volatilization,
followed by redeposition of the treated soil in the excavated areas; decontaminating
the building, which includes removal, offsite disposal, and treatment of the asbestos
insulation; excavating, treating, and disposing of the underground tanks, tank
contents, associated equipment, liquid wastes, and contaminated soil offsite;
backfilling the excavated area with clean soil; and pumping and treatment of ground
water using air stripping, with carbon adsorption to control offgasses, followed by
onsite reinjection of the treated ground water. The estimated present worth cost for
this remedial action is $16,800,00, which includes an annual O&M cost of $1,100,400 for
years 0-10 and $701,900 for years 11-17.
PERFORMANCE STANDARDS OR GOALS: No chemical-specific cleanup levels were provided.
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ROD FACT SHEET
SITE
Name:
Location/State:
EPA Region:
HRS Score (date)
NPL Rank (date):
ROD
Date Signed:
Selected Remedy
Soils:
Groundwater:
Building:
Underground Tanks:
Capital Cost:
O & M:
Present Worth:
LEAD
Claremont Polychemical
Old Bethpage, Nassau County, New York
II
31.62 (June 86)
915 (August 90)
September 28, 1990
Excavation and treatment via on-site low
temperature enhance volatilization
Extraction and treatment via air stripping
and carbon adsorption and reinjection of
treated groundwater into the ground
Decontamination via vacuuming, dusting and
asbestos removal
Excavation, removal and off-site
treatment/disposal of tanks and associated
equipment
$ 6,200,000
$ 1,100,400 (first ten years)
$ 701,900 (next six years)
$ 16,800,000
Remedial, EPA
Primary Contact (phone): Carlos R. Ramos (212-264-5636)
Secondary Contact (phone): Douglas Garbarini (212-264-0109)
WASTE
Type:
Soil - tetrachloroethene
Groundwater - trans-l,2-dichloroethene,
trichlbroethene, 1,1,1-trichloeoethane
Building - copper, zinc
Underground tanks - toluene, xylenes,
2-butanone
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Medium: Soil, groundwater, building, underground
tanks
Origin: Pollution originated during the operation of
the Claremont Polychemical Corporation. The
processes used resulted in the generation,
storage and disposal of hazardous waste
products.
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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 Claremont Polychemical site, in Old Bethpage, Nassau County,
New York, developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980,
as amended by the Superfund Amendments and Reauthorization Act of
1986, and, to the extent practicable, the National Contingency
Plan. 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
site, 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
The remedy addresses the principal threat posed by the Site
through a combination of source control alternatives including
treatment of contaminated soils (SC-4), tank removal and
treatment (T-2), active restoration of the groundwater (GW-3B),
and building decontamination (BD-2).
This action complements the previous work conducted as part of
the second operable unit developed to address wastes contained in
several holding units (i.e., drums, aboveground tanks, basins,
and a sump).
The major components of the selected remedy include:
• Excavation and on-site treatment of approximately 1,600
cubic yards of contaminated soils via low temperature
enhanced volatilization and redeposition of treated soils
into the excavated areas.
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• Extraction and treatment of the contaminated groundwater at
the Site via air stripping and carbon adsorption and
reinjection of the treated water into the ground.
Decontamination of the building via vacuuming and dusting of
the contaminated surfaces and.removing the asbestos .
insulation for off-site treatment and disposal.
Excavation, removal and off-site treatment/disposal of the
underground tanks, associated equipment, tank contents, and
highly contaminated soil.
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 resource
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.
53
/ *
Hnstantine Sidamon-Eristoff
egional Administrator
~~
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DECISION SUMMARY
CLAREMONT POLYCHEMICAL SITE
OLD BETHPA6E
NASSAU COUNTY, NEW YORK
United States Environmental Protection Agency
Region II, New York
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TABLE OF CONTENTS
SECTION PAGE
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION 2
SCOPE AND ROLE OF OPERABLE UNIT 3
SUMMARY OF SITE CHARACTERISTICS 4
SUMMARY OF SITE RISKS 8
DESCRIPTION OF ALTERNATIVES 11
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 19
SELECTED REMEDY 30
STATUTORY DETERMINATIONS 31
DOCUMENTATION OF SIGNIFICANT CHANGES 33
APPENDICES
APPENDIX A. FIGURES
APPENDIX B. TABLES
APPENDIX C. ADMINISTRATIVE RECORD INDEX
APPENDIX D. NYSDEC LETTER OF CONCURRENCE
APPENDIX E. RESPONSIVENESS SUMMARY
ii
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LIST OF FIGURES
Number Name
1 Claremont Polychemical Site Location Map
2 Claremont Polychemical Site Plan
3 Surface Soil Sampling Locations
4 Soil Boring Sampling Locations
5 Estimated Area of Soil Contamination
6 Monitoring Well Location
7 Approximate Extent of Groundwater
Contamination
iii
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LIST OF TABLES
Number Name
1 Site History Summary
2 Summary of Chemicals Detected in Surface
Soil
3 Summary of Chemicals Detected in Soil
Borings
4 Summary of Chemicals Detected in
Groundwater Samples
5 Summary of Chemicals Detected in Air
samples
6 Summary of Chemicals Detected in Building
Samples
7 Indicator Chemicals
8 Summary of Exposure Pathways
9 Toxicity Data for Non-Carcinogenic Effects
10 Summary of Human Non-Cancer Risk Estimates
11 Toxicity Data for Carcinogenic Effects
12 Summary of Cancer Risk Estimates
13 List of ARARs Associated with the Selected
Remedy
IV
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SITE NAME/ LOCATION AND DESCRIPTION
The Claremont Polychemical site is an abandoned production
facility located in central Long Island, in the community of Old
Bethpage, Town of Oyster Bay, Nassau County, New York (see Figure
1). The facility is located in an area comprised of light
industrial, commercial and institutional properties (Old Bethpage
Landfill, SUNY Agricultural and Technical College at Farmingdale,
and Bethpage State Park). The Suffolk County line is approxim-
ately 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 approximately half a mile away on the west
side of the Old Bethpage Landfill ("Landfill"). The closest
public supply well is located 3,500 feet northwest of the Site.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A chronological summary of activities associated with the
Claremont Polychemical site is presented in Table 1. The Site
occupies approximately 9.5 acres on which a 35,000 square foot,
one story, concrete building is located (see Figure 2). Other
features include: treatment basins, aboveground tanks,
underground tanks, leaching basins, dry wells, and water supply
wells.
From 1968 until its closure in 1980, Claremont Polychemical
manufactured 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 (NCDOH) of 2,000 to 3,000
drums scattered throughout the Site, 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. NCDOH
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 by the property owners, in 1980,
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 is
an impermeable layer. Groundwater samples from a monitoring well
installed at the time (1980) indicated the presence of
groundwater contamination directly under the Site.
Claremont Polychemical and its affiliated companies (Winding Road
Estates and Winding Road Properties) entered into receivership in
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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 sampling was performed and a report was
written by C.A. Rich Consultants in response to questions by the
U.S. Bankruptcy Court. For the last four to five years two
tenant businesses have been operating at the Site.
The Claremont Polychemical site was first proposed for inclusion
on the National Priorities List (NPL) in October 1984 and was
listed in June 1986. 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. No response
was received from Mr. Neitlich or a company representative, so in
March 1988 EPA obligated funds and started a comprehensive
Remedial Investigation and Feasibility Study ("RI/FS") for the
first operable unit.
A preliminary evaluation by EPA in July 1988 revealed the
presence of hazardous waste held in containers (e.g. drums) and
other holding units (treatment basins, aboveground tanks, and a
sump). In September 1988, EPA performed work consisting of the
overpacking and/or stabilization of deteriorated containers and
holding units. A second operable unit RI/FS (OU-II) dealing with
the ultimate disposal of the above mentioned hazardous wastes was
completed by EPA in July 1989. The Record of Decision for OU-II
was issued in September 1989. The selected remedy is currently
being implemented and consists of compatibility testing,
bulking/consolidation, and treatment/disposal of the wastes at
off-site, EPA-approved, treatment facilities.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS Reports, and the Proposed Plan for remedial action were
released for public comment on August 24, 1990. These documents
were available to the public in both the administrative record
file and the information repository maintained at the EPA docket
room in Region 2 and at the Plainview-Old Bethpage Public
Library. A press release announcing the availability of these
documents was issued on August 4, 1990. The public comment
period set by EPA concluded on September 25, 1990.
During the public comment period EPA held a public meeting to
present the RI/FS Report and the Proposed Plan, answer questions,
and accept both oral and written comments. The public meeting
was held in the auditorium of the Old Bethpage Village Restora-
tion, Old Bethpage, New York on September 5, 1990. Comments
received be EPA are addressed in the Responsiveness Summary
(Appendix E) appended to the Record of Decision. This decision
document presents the selected remedial action tor the Claremont
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Polychemical site, in Old Bethpage, New York, chosen in
accordance with CERCLA, as amended by SARA and to the extent
practicable, the National Contingency Plan ("NCP"). The decision
for this site is based in 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 the overall site remediation (groundwater and
soil) and is the focus of this document. The RI/FS for the first
operable unit contains the detailed information and data used in
determining the nature and extent of the problem and the
development of remedial alternatives to address the problem.
The second operable unit deals only with the wastes held in
containers and holding units. In September 1989, EPA decided to
remove these wastes and treat/dispose of the materials off-site.
This action, which includes the containers found inside the
building (e.g. drums) and the wastes contained inside the holding
units (e.g. treatment basins, aboveground tanks), is currently
ongoing.
The overall objective of the remediation is to reduce the
concentrations of contaminants in various media and structures at
the Site to levels which are protective of human health and the
environment. The remedy selected should eliminate long-term
sources of contamination of groundwater and other media, and will
achieve this objective through:
o Soil Treatment. On-site treatment of the soil to remove the
mobile organic contamination will result in the elimination
of a long-term source of contamination of the groundwater.
o Groundwater Treatment. Extraction and treatment of the
contaminated groundwater will contain the migration of the
plume and, in time, will achieve federal and state standards
for the volatile organic contaminants.
o Building Decontamination. Removal of all hazardous
materials from the building will eliminate any potential
risk to human health and the environment.
o Removal and Treatment of Underground Tanks, Liquid Wastes.
and Associated Soils. Removal and off-site treatment of
these wastes will result in the elimination of the threat to
human health and the environment from possible contact with
the wastes. It also will result in the eradication of a
potential long-term source of groundwater contamination.
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SUMMARY OF SITE CHARACTERISTICS
SOILS
Soil samples for chemical characterization collected at the
Claremont Polychemical site consisted of two types: surface
soils and subsurface soils. Surface soil samples were obtained
from the upper six inches of soil whereas subsurface soil samples
were obtained from two foot intervals at various depths below
grade up to a depth of 82 feet beneath the Site.
Surface Soil
Surface soil samples collected on-site were analyzed for metals.
Soil sample results were compared with typical background levels
and are summarized in Table 2. Of the metals detected, only
cadmium (33.1 ppm), copper (230 ppm), lead (327 ppm), magnesium
(29,200 ppm), and zinc (3,200 ppm) exceeded typical eastern U.S.
soil background levels at a few of the surface soil sampling
locations, primarily in the soils adjacent to the treatment
basins (see Figure 3). These metals are most probably found in
surface soil due to overflow from the treatment basins and
current site use (i.e., vehicular traffic, storage of
construction debris).
Subsurface Soil
Volatile organic compounds detected in the subsurface soil
samples included tetrachloroethene (26,000 ppb), 1,2-
dichloroethene (71 ppb), trichloroethene (17 ppb), acetone
(14,000 ppb), toluene (82 ppb), 2-butanone (3,300 ppb), xylenes
(150 ppb) and 4-methyl-2-pentanone (360 ppb). In general, total
volatile organic concentrations were greatest to the east of the
process building in proximity to the former spill area at boring
locations SB-19 and SB-21 which are shown in Figure 4. Overall,
the volatile organic concentrations decrease rapidly with depth.
A summary of the results is presented in Table 3.
Several base/neutral acid extractable organic compounds (BNA)
were detected within soil boring samples, a majority of which
were polynuclear aromatic hydrocarbons (PAH's) that are
constituents of fuel, oil and grease. In addition, phthalates
(270,000 ppb), benzoic acid (120 ppb), 2-chloronaphthalene
(33,000 ppb) and pentachlorophenol (360 ppb) also were found in
some samples. The greatest concentrations of the three most
prevalent phthalates; bis(2-ethylhexyl)phthalate (BEHP) at 70,000
ug/kg, di-n-butylphthalate at 3,900 ug/kg and butylbenzyphthalate
at 8,200 ug/kg were found at 0-2 ft at SB-19 in the spill area.
Relatively low levels of five pesticides, i.e., dieldrin {26
ppb), heptachlor (18 ppb), DDT (88 ppb), ODD (180 ppb), and DDE
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(110 ppb) were detected, predominantly in the western and
northern portions of the Site. PCBs were detected only at soil
boring locations S6-02, 08, and 25 with a maximum concentration
of 1,100 ppb. Surficial oil spillage in these areas appears to
be the most likely source of these PCBs since elevated PNAs,
typically associated with oil, were also present at these
locations.
Metals detected in soil boring samples which exceeded typical
eastern U.S. soil background levels included arsenic (35 ppm),
cadmium (14.1 ppm), copper (152 ppm), lead (90.8 ppm), magnesium
(29,100), and selenium (2.0 ppm). Selenium, lead and magnesium
exceeded background at several locations, generally at the 0-4
feet depth, but with no apparent spatial distribution. The
elevated levels of these metals could be associated with the
presence of fill material, vehicular emissions and surficial
spills of fuel-related products.
Volume of Contaminated Soil
Tetrachloroethene (PCE) is identified as the only chemical of
concern in soil due to the leaching of PCE from the soil to the
underlying groundwater. The estimated volume of contaminated
soil that requires remediation is based on the extent of PCE
contamination in the soil. Soil-to-groundwater models have
indicated the potential for PCE to contaminate the aquifer above
potable water standards. In order to minimize the impact of the
PCE on the groundwater and enhance the groundwater treatment
remedy, the first two feet of soil in the spill area will be
treated. Treatment to a depth of two feet will remove the
significant contamination from the soil, including the location
where the highest level of contamination, 26 ppm of PCE, was
found. Based on soil boring information collected from the Site,
this will reduce the average PCE contamination in the soil to
much less than 200 ppb. A 21,000 ft2 area of soil, generally
located in the spill area, as shown in Figure 5, is identified as
requiring remediation. The preliminary volume of contaminated
soil from this area which requires remediation is estimated to be
1,600 cubic yards.
GROUNDWATER
Two rounds of groundwater sampling were conducted, the first was
conducted in April 1989 and the second in June 1989. The wells
were distributed upgradient, in the immediate vicinity, and
downgradient of the Site in order to define the nature and extent
of contamination originating at the Site. In addition, three
wells were located to the west of the Site to define the
contaminant plume emanating from the Old Bethpage Landfill.
Figure 6 shows the location of these wells and the approximate
extent of the contaminated groundwater plume. The groundwater
flow in the region was generally from the north-northwest -to the
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south-southeast.
Groundwater samples were analyzed for volatile organics, semi-
volatile organics, pesticides and PCBs, inorganics and several
standard water quality parameters. A summary of the results is
presented in Table 4. .
Results
Tetrachloroethene had the greatest spatial extent and highest
groundwater concentrations of any contaminant found in site
groundwater. Figure 7 shows the maximum groundwater
concentrations for tetrachloroethene in all wells analyzed for
during this investigation. The maximum detected concentration
occurs near the property's boundary and the concentration
gradually attenuates to the southeast. Maximum detected levels
of tetrachloroethene (1,300 ppb), trans-l,2-dichloroethene (830
ppb), trichloroethene (260 ppb), 1,1,1-trichloroethane (100 ppb),
ethylbenzene (160 ppb), acetone (540 ppb), benzene (60 ppb), 1,1-
dichloroethane (17 ppb), methylene chloride (14 ppb), total
xylenes (40 ppb) and vinyl chloride (7 ppb) were found which
exceeded federal and/or New York State Maximum Contaminant Levels
("MCLs"). Maximum detected values were generally found in the
shallow portion of the aquifer (0-45 ft).
The frequency and levels of semivolatiles and pesticides detected
were much lower than those generally found for volatile organics.
The highest concentration found was 92 ug/1 for bis(2-
ethylhexyl)phthalate (BEHP) however, this level was comparable to
that found (88 ug/1) in an upgradient well. No PCBs were found.
Several metals were detected in concentrations exceeding federal
and state standards including arsenic (56.5 ppm), chromium (159
ppm), lead (464 ppm) and manganese (3,130 ppm). However, of
these metals chromium and lead also occurred above MCLs in
upgradient wells.
AIR
The ambient air samples collected show low concentrations of
volatile contaminants namely chloroform (0.07 ppb), 1,1,1-
trichloroethane (0.7 ppb), carbon tetrachloride (0.12 ppb),
trichloroethene (1.14 ppb), tetrachloroethene (3.42 ppb), toluene
(2.1 ppb), and styrene (0.37 ppb). However, these concentrations
were generally comparable, and in several cases lower, than
upwind concentrations (i.e., chloroform, carbon tetrachloride,
1,1,1 trichloroethane, toluene and styrene). Table 5 presents a
summary of the analytical results.
UNDERGROUND STORAGE TANKS
An underground tank farm consisting of fourteen tanks was
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uncovered and sampled. Of the fourteen tanks, ten were made of
steel and four were made of fiberglass. Eleven contained
sufficient materials to obtain liquid and/or sludge samples. The
amount of material contained in the tanks (approximately 16,000
gallons) varied from a few inches to several feet deep. Samples
were analyzed for one or more of the following parameters: TCL
volatiles, semivolatiles, inorganics and pesticide/PCB compounds,
total recoverable petroleum hydrocarbons (TRPH), corrosivity,
flash point, reactive cyanide and reactive sulfide.
In general, results show that the number of organic compounds
detected in any given sample was usually less than three
compounds with a maximum of eight compounds. The maximum number
of water immiscible organic compounds was found in the eastern
steel tank EST-04. The contents in three of the tanks were
dominated by: 2-butanone (92%) in western steel tank WST-03;
toluene (2.6%) and xylenes (3.6%) in the water immiscible phase
in eastern steel tank EST-04; and bis(2-ethylhexyl)phthalate
(BEHP) (23%) in eastern steel tank EST-06. No pesticides or PCBs
were detected in any tank investigation samples analyzed for
these compounds.
For most of the tanks, the TRPH was less than 40 mg/1. However,
for western steel tank WST-03 and eastern steel tank EST-06, the
levels were 1.4% (14,000 mg/1) and 14.5% (145,000 mg/1),
respectively. These tanks contain high levels of 2-butanone and
BEHP, respectively. Most of the corrosivity results fell in the
range of 3 to 5.8 mm/yr. The flash points of most of the tank
fluids fell above 100°C. Western steel tank WST-03 and eastern
steel tank EST-04 contained fluids having flash points below
15°C. Fiberglass tank FG-04 contains fluid with a flash point of
30°C.
Four organic compounds were found in the soil directly next to
the tanks, however, three of them, tetrachloroethene, chloroform
and di-n-butylphthalate, occurred at trace levels (less than 26
ppb). The fourth compound, bis(2-ethylhexyl) phthalate (BEHP),
occurred at substantially higher levels, in the range of 50 to
3,000,000 ppb (i.e. up to^O.3%), in all samples.
BUILDING
Within the Claremont process building, samples were collected to
characterize any contamination associated with accumulated dust,
standing water (in floor drains and previously operating
condensers), and insulation materials. Results are summarized in
Table 6.
Building Dust Wipes
Analysis of wipe samples taken from floors and walls show the
widespread presence of metals within the building. Inorganics
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8
were detected at consistently high concentrations - aluminum at
1,696 ug/ft2 to 45,013 ug/ft2 and copper from 142 ug/ft2 to 2,091
ug/ft2. BNA and pesticide analysis showed bis(2-
ethyhexyl)phthalate as the principal contaminant at
concentrations of 107 to 3,200 ug/ft2.
Condensers and Floor Drains
Water samples were collected from two condensers and two floor
drains within the building. A wipe sample was also taken from
one condenser. All samples showed elevated levels of inorganics.
Principal contaminants include copper (17.9 - 43,900 ug/1) and
zinc (up to 12,200 ug/1 in water samples, and 77,653 ug/ft2 in
the condenser).
Pipes
Analyses of 17 samples of insulating material collected from the
pipes within the building showed that 14 out of 17 samples had
greater than 5% asbestos. Asbestos concentrations in the
building materials analyzed ranged from non detect to 25%
asbestos.
SUMMARY OF SITE RISKS
EPA conducted an Endangerment Assessment (EA) of the "no action"
alternative to evaluate the potential risks to human health and
the environment associated with the Claremont Polychemical site
in its current state. The EA focused on the contaminants in the
air, building dust, soil, and ground water which are likely to
pose the most significant risks to human health and the
environment (indicator chemicals). The summary of "indicator
chemicals" in sampled matrices is listed in Table 7.
EPA's EA identified several potential exposure pathways by which
the public may be exposed to contaminant releases at the Site.
Potential pathways were developed based on current (residential,
industrial) and future land use (residential, industrial)
scenarios at the Site. Several pathways (Direct contact,
inhalation and ingestion) were evaluated for each scenario.
Under the present land use, ingestion of ground water, inhalation
of fugitive dust, and contaminated air were considered complete
exposure pathways. Ground water downgradient of the Site was
used for present and future off-site land use exposure scenarios,
whereas site ground water was used, for on-site future land use
scenario. Site air and soil concentrations, were used for both
scenarios, as applicable. These pathways and the populations
potentially affected are shown in Table 8. Potentially exposed
populations include on-site and off-site residents, farm workers,
and construction workers. Two risks were calculated,
corresponding to the average and maximum plausible case.
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Under current EPA guidelines, the likelihood of carcinogenic
(cancer causing) and non-carcinogenic effects due to exposure to
site chemicals are considered separately. It was assumed that
the toxic effects of the site related chemicals would be
additive. Thus, carcinogenic and non-carcinogenic risks
associated with exposures to individual indicator compounds were
summed to indicate the potential risks associated with mixtures
of potential carcinogens and non-carcinogens, respectively.
Non-carcinogenic risks were assessed using a hazard index (HI)
approach, based on a comparison of expected contaminant intakes
and safe levels of intake (Reference Doses). Reference doses
(RfDs) have been developed by EPA for indicating the potential
for adverse health effects. RfDs, which are expressed in units
of mg/kg-day, are estimates of daily exposure levels for humans
which are thought to be safe over a lifetime (including sensitive
individuals). Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated
drinking water) are compared with the RfD to derive the hazard
quotient for the contaminant in the particular media. The hazard
index is obtained by adding the hazard quotients for all
compounds across all media. A hazard index greater than 1
indicates that potential exists for non-carcinogenic health
effects to occur as a result of site-related exposures. The HI
provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a single
medium or across media. The reference doses for the indicator
chemicals at the Claremont Polychemical site are presented in
Table 9.
The hazard indices for non-carcinogenic effects from the Site are
listed in Table 10. All total His listed under current and
future off-site and on-site land uses are greater than 1,
suggesting that non-cancer effects may occur.
Potential carcinogenic risks were evaluated using the cancer
potency factors developed by the EPA for the indicator compounds.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Risk Assessment Verification Endeavor for estimating
excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. CPFs, which are expressed in
units of (mg/kg-day) ', are multiplied by the estimated intake of
a potential carcinogen, in mg/kg-day, to generate an upper-bound
estimate of the excess lifetime cancer risk associated with
exposure to the compound at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated
from the CPF. Use of this approach makes the underestimation of
the risk highly unlikely. The CPFs for the indicator chemicals
are presented in Table 11.
For known or suspected carcinogens, the USEPA considers excess
upper bound individual lifetime cancer risks of between lO'4 to
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10
10"6 to be acceptable. This level indicates that an individual
has not greater than a one in ten thousand to one in a million
chance of developing cancer as a result of exposure to site
conditions.
The potential risks due to carcinogens at the Site are listed in
Table 12. The estimated risk for the current use of the
recreational areas located downgradient of the Site ranged
between 1.88 x 10"6 and 1.4 x 10 . Under future off-site land use
conditions, inhalation of the site air and ingestion of
unfiltered downgradient ground water posed a total risk varying
between 1.2 x 10s and 5.0 x 10s. Higher risks were estimated for
future on-site land use. The risks from all pathways range from
1.84 x lO'4 to 6.61 x 10~*. The primary risk to workers was due to
inhalation of resuspended dust inside the building (2.37 x 10* to
5.09 x 103). The risk for inhalation of building resuspended
dust is above the risk range for carcinogens at the Site and the
remaining risks fall within EPA's acceptable risk range.
Uncertainties
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subject to a wide
variety of uncertainties. In general, the main sources of
uncertainty include:
- environmental chemistry sampling and analysis
- environmental parameter measurement
- fate and transport modeling
- exposure parameter estimation
- toxicological data
Uncertainty in environmental sampling arises in part from the
potentially uneven distribution of chemicals in the media
sampled. Consequently, there is significant uncertainty as to
the actual levels present. Dermal adsorption and ingestion of
soil were not included in the exposure pathways for future off-
site land use because of the lack of off-site soil data.
Environmental chemistry analysis error can stem from several
sources including the errors inherent in the analytical methods
and characteristics of the matrix being sampled.
Uncertainties in the exposure assessment are related to estimates
of how often an individual would actually come in contact with
the chemicals of concern, the period of time over which such
exposure would occur, and in the models used to estimate the
concentrations of the chemicals of concern at the point of
exposure.
Uncertainties in toxicological data occur in extrapolating both
from animals to humans and from high to low doses of exposure, as
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11
well as from the difficulties in assessing the toxicity of a
mixture of chemicals. These uncertainties are addressed by
making conservative assumptions concerning risk and exposure
parameters throughout the assessment. As a result, the EA
provides upper bound estimates of the risks to populations near
the Landfill, and is highly unlikely to underestimate actual
risks related to the Site.f,
More specific information concerning public health risks,
including quantitative evaluation of the degree of risk
associated with various exposure pathways is presented in the Rl
Report.
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF ALTERNATIVES
Following a screening of remedial technologies in accordance with
the NCP, ten remedial alternatives were developed for
contaminated groundwater; five remedial alternatives were
developed for treatment of soil; and two alternatives were
developed to remediate the building and underground tank areas,
respectively.
These alternatives were screened based on implementability,
effectiveness, and cost. The screening resulted in remedial
alternatives upon which a detailed analysis was performed. The
remedial alternatives not retained for a detailed evaluation
were: capping (SC-2); and, groundwater alternatives which relayed
solely on carbon adsorption (GW-4A and 4B) and carbon
adsorption/enhanced activated sludge treatment (GW-6A and 6B).
Those alternatives considered in detail are discussed below. The
time to implement as used herein means the time required for site
preparation and for actual on-site construction, start-up
activities and cleanup except for groundwater alternatives which
do not include actual remediation time. It includes the remedial
design phase which typically takes 2-3 years to complete and
starts from the signing of the ROD. The remedial alternatives
are organized according to the media or specific structures which
they address: soil (SC), groundwater (GW), building (BD) and
underground tanks (T).
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SOILS
Alternative SC-1: No Further Action
Capital Cost: none
O & M Cost: $34,900 per year
Present Worth Cost: $564,300
Time to Implement: 1 month
The No Action alternative provides the baseline case for
comparison with other soil alternatives. Under this alternative,
the contaminated soil is left in place without treatment. A
long-term groundwater monitoring program would be implemented to
track the migration of contaminants from the soil into the
groundwater. Existing monitoring wells would be used for
monitoring. Five year reviews would be performed to assess the
need for further actions.
Roll-off containers and drums containing soils and drilling mud
generated during the remedial investigation would have to be
transported off-site for treatment and disposal in accordance
with state and federal regulations.
Alternative SC-3: Excavation/Off-Site Incineration/Backfill with
Clean Soil
Capital Cost: $5,000,000
0 & M Cost: none
Present Worth Cost: $5,000,000
Time to Implement: 3.5 years
Site preparation for the remedial implementation would include a
parking area, equipment staging area and stockpile area. Support
facilities (e.g. offices) also would also be installed on the
Site. An estimated total of 1,600 cubic yards (cy) of soil would
be excavated. Excavation would be conducted under moistened
conditions by spraying water over the surface to minimize
fugitive dust and volatile contaminant emissions. The soil would
be stockpiled prior to transportation to an off-site facility.
The excavated soil would be transported to an off-site, EPA-
permitted incineration facility for treatment and disposal. The
roll-off containers and drums containing soil from the remedial
investigation also would be re-packed into the same type of
containers and transported for off-site incineration along with
the excavated soil. Clean soil would be used to backfill the
excavated area. Site restoration would include the application
of topsoil and seeding.
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Alternative SC-4: Excavation/On-8ite Low Temperature Enhanced
Volatilization/on-Site Redeposition
Capital Cost: $700,000
0 & H Cost: none
Present Worth Cost: $700,000
Time to Implement: 3.5 years
Site preparation and soil excavation would be performed as in
Alternative SC-3. An estimated 1,600 cy of contaminated soil
would be treated in a mobile enhanced volatilization (low
temperature thermal extraction) unit brought on site. Low
temperature thermal extraction consists of a feed system, thermal
processor, afterburner, and scrubber. The excavated contaminated
soil is placed in the feed hopper with a backhoe. The soil is
then conveyed from the hopper to the thermal processor. Hot air
from an air heater is injected into the thermal processors at a
normal operating temperature of 260°C (500°F) which is well above
the boiling points of most volatile organic compounds (VOCs).
The volatilized compounds and moisture in the contaminated soil
is then burned at 1,090°C (2,000°F) in an afterburner operated to
ensure complete destruction. A portion of the off-gas is
recirculated as combustion air to minimize fuel usage. The
off-gas is then treated at the scrubber for particulate removal
and acid gas adsorption. The off-gas leaves the system at a
temperature of less than 93°C (200°F) .
The volatilized contaminant-laden gas also can be treated by an
activated carbon adsorption unit instead of an afterburner for
PCE removal. A bag filter would be used to remove particulates
from the gas before it enters the carbon adsorption unit. The
treated soil would be free of volatile organics and would be
stored for sampling and then used as backfill in the excavated
areas. Site restoration would be performed as in Alternative
SC-3. The roll-off containers and drums containing RI soil also
would be treated with the excavated soil.
Alternative 8C-5: In-Situ Vacuum Extraction
Capital Cost: $385,600
O & M Cost: none
Present Worth Cost: $385,600
Time to Implement: 4 years
Site preparation would be performed as in Alternative SC-3.
However, the soil is left in place undisturbed, therefore no
excavation would be required. This alternative involves the
installation of vacuum extraction wells over the contaminated
soils. Each well would have a maximum depth of 10 feet. The
vacuum wells would be connected via a pipe system to a
skid-mounted high volume vacuum pump. The vacuum would pull air
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through 'the contaminated soils, within a radius of approximately
20 feet from the wells, depending on soil composition and
volatility of the contaminant. The air containing the stripped
VOCs from the soil would be fed through a condenser to recover
the free product and moisture, and then through an emissions
control system, i.e., a vapor phase carbon adsorption system. The
condensed product would be drummed and transported to an off-site
treatment and disposal facility (most likely an incinerator).
The roll-offs and drums containing soil would also be treated
on-site via this technology by using a one-pipe system within the
drum connected to a vacuum pump. The treated soils would be used
on-site for backfilling and regrading.
GROUNDWATER
Alternative GW-l: No Further Action
Capital Cost: none
0 & M Cost: $28,400
Present Worth Cost: $464,400
Time to Implement: 1 year
This alternative includes the use of existing wells to conduct a
long-term groundwater sampling program which would monitor the
migration of contaminants of concern in the aquifer. A total of
ten wells, including existing upgradient, on-site and
downgradient wells, would be utilized in order to sample the
groundwater from the shallow to deeper portions of the aquifer
and to track contaminant migration off-site. Regular five-year
reviews would be performed to assess the need for additional
remedial actions. Under this alternative, it would take 100
years to achieve groundwater remediation.
Alternative GW-2: Pumping/Pretreatment/Air Stripping/Carbon
Adsorption/Reinjection; Pumping at the Site Boundary (0.2 mgd)
Capital Cost: $214,800
O & M Cost: $378,700
Present Worth Cost: $3,350,500
Time to Implement: 3 years
This alternative includes the installation of three extraction
wells downgradient of the Site in order to extract 0.2 million
gallons per day (mgd) of groundwater from the site contaminant
plume. This groundwater would be.piped to the Old Bethpage
Landfill groundwater treatment system for treatment and disposal.
The Landfill groundwater treatment system is currently under
construction and scheduled to be completed in 1991. The 0.2 mgd
is the maximum allowable input from the Claremont site to fhe
Landfill pump and treatment system due to design limitations of
the Landfill system. The treated effluent would be reinjected
into the aquifer through a recharge basin being constructed as
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basin being constructed as part of the Landfill system. This
flow rate is below the modeled maximum pumping rate of 1.9 mgd
estimated for removal and treatment of the Claremont contaminant
plume. (The original estimate of the volume of contaminated
groundwater to be treated was much less than the current
estimate.) In addition, the landfill treatment system is only
planned to operate for 10 years based upon the time estimated for
remediation to be completed for the Old Bethpage plume.
Long-term monitoring using the new extraction wells and existing
wells would be performed for 30 years in order to monitor any
continued migration of remaining contamination in the
groundwater, both during and* after the operation of the landfill
treatment system.
Alternative 6W-3A: Pumping/Pretreatment/Air Stripping/Carbon
Adsorption/Reinjaction; Pumping at the Leading Edge of the Plume
(1.9 mgd)
Capital Cost: $4,044,700
O & M Cost: $1,622,900
Present Worth Cost: $28,978,000
Time to Implement: 3 years
In this alternative, three extraction wells would be installed
downgradient of the site on the Bethpage State Park property in
order to capture the entire site contaminant plume.
Approximately 1.9 mgd would be pumped to an on-site treatment
facility. The treated groundwater would be pumped to a discharge
system for reinjection to the aquifer via three reinjection
wells. The siting of the extraction wells would be completed
during the design phase based* on technical criteria.
The groundwater treatment facility would consist of two major
processes: pretreatment to remove metals (iron, manganese,
arsenic, and thallium) and air strippers followed by a carbon
adsorption system to remove volatile and semivolatile organics.
The pretreatment system would be designed to effectively reduce
the metal concentrations in the groundwater below the federal and
New York State Groundwater Standards. This pretreatment system
would consist of a metals precipitation system and dual media
pressure filter. The resulting sludge would require off-site
treatment and disposal.
Two air strippers in series followed by liquid phase carbon
adsorption would be used to lower the levels of organic
contamination below the state groundwater standards.
Approximately 95 to 99 percent of the volatile organics would be
removed by air stripping. The stripped groundwater would be
pumped to a two-stage liquid phase carbon adsorber for removal of
the remaining volatiles and BEHP, and phenol. The volatile
organic emissions from the air stripping would be adsorbed on a
vapor phase activated carbon system in order to meet air quality
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standards. Spent carbon would be removed for off-site
regeneration or incineration, thus destroying all organic
contaminants. Two treatment trains (parallel systems for
treating the groundwater) rated at 660 gallons per minute (gpm)
each would be required.
Environmental monitoring would be required during the life of the
treatment plant operation (i.e., 30 years). Air emissions would
be monitored to confirm compliance with the air discharge limit.
Groundwater samples would be taken every six months to monitor
groundwater contamination migration and the effectiveness of
remediation. Under this alternative it is estimated to take 62
years to achieve remediation^of the groundwater plume.
Alternative GW-3B: Pumping/Pretreatment/Air Stripping/Carbon
Adsorption/Reinjaction; Pumping at the site Boundary and
Downgradient (1.0 mgd)
Capital Cost: $4,936,000
O & M Cost: $1,100,400 (first;-t^n years)
$701,900 (next six years)
Present Worth Cost: $15,620,400
Time to Implement: 3 years
In this Alternative, two extraction wells would be installed at
the boundary of the Site to capture the most contaminated
groundwater. Additional extraction wells would be located
downgradient from the Site to capture the off-site migrating
plume. Sufficient information exists at this time to locate the
on-site wells which would pump the concentrated contaminant plume
for treatment, however additional information would be required
before the downgradient extraction wells could be sited. These
information needs include information regarding the actual extent
of the downgradient plume, as well as potential impacts the Old
Bethpage Landfill may have on this plume once it begins
operation. Additional sampling would be conducted to obtain this
information. For these reasons it is likely that the on-site
extraction wells would be installed (0-2 years) prior to the off-
site and downgradient wells.
During the first phase extraction wells would be installed at the
site boundary, requiring two treatment trains each rated at 250
gpd to treat the concentrated groundwater plume. During the
second phase the downgradient groundwater plume would be
extracted, requiring the installation of two additional treatment
trains also rated at 250 gpd.' The treatment trains would be
located on-site and operated in parallel. The extracted
groundwater would be treated as in Alternative 3A. The on-site
and off-site extraction wells would treat 1 mgd for approximately
10 years. After 10 years it is anticipated that the downgradient
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plume would be significantly treated. Thereafter, on-site
extraction and treatment of 0.5 mgd would continue for
aproximately six additional years.
Implementing this remedy in two phases would provide increased
overall efficiency and flexibility. This optimized extraction
and treatment system design would be better able to address the
remediation of the Claremont site plume.
Alternative GW-5A: Pumping/Pretreatment/UV-Chemical
Oxidation/Reinjection; Pumping at the Leading Edge of the Plume
(1.9 mgd)
Capital Cost: $4,088,900
O & M Cost: $1,108,000
Present Worth Cost: $21,121,100
Time to Implement: 3 years
This remedial alternative is%similar to Alternative GW-3A except
that a chemical oxidation process rather than air
stripping/adsorption process would be used to remove the volatile
and semivolatile organics in the groundwater. An ultraviolet
light-hydrogen peroxide oxidation system is selected as the
representative process to treat the contaminated groundwater.
This oxidation system would employ a combination of hydrogen
peroxide (H202) and ultraviolet (UV) light to chemically oxidize
the organic contaminants in the groundwater to carbon dioxide,
water and chlorides. Multiple units would be required. The
treated groundwater would have organic concentrations below state
and federal standards. The time necessary to achieve remediation
would be 62 years. *
Alternative GW-5B: Pumping/Pretreatment/UV-chemical
Oxidation/Reinjection; Pumping at the Site Boundary and
Oowngradient (1.0 mgd)
Capital Cost: $4,069,800
0 & M Cost: $1,008,600 (first ten years)
$656,000 (next six years)
Present Worth Cost: $13,902,300
Time to Implement: 3 years
Groundwater extraction, pretreatment, and reinjection would be
accomplished as in Alternative GW-3B. The UV-H202 system would
operate as in Alternative GW-5A except that smaller treatment
units would be used. The time necessary to achieve groundwater
remediation would be 16 years-.
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BUILDING
Alternative BD-1: No Further Action
Capital Cost: $8,800
O & M Cost: $2,100 per year
Present Worth Cost: $41,100
Time to Implement: 1 month
The No Action alternative provides the baseline against which
other alternatives can be compared. It would result in leaving
the contaminated dust, asbestos insulation, and contaminated
water in floor drains and condensers intact in the building. The
only additional security measure implemented to completely seal
the building would be waterproofing of the building ceiling.
A long-term maintenance program, including site inspections,
would be implemented in order to ensure that the building is
completely sealed and is not accessible to the public in the
future.
Alternative BD-2: Building Decontamination
Capital Cost: $186,200
O & M Cost: none
Present Worth Cost: $186,200
Time to Implement: 6 months
The inside contaminated surfaces of the building (i.e., walls,
floors, and hoods) would be decontaminated using dusting,
vacuuming and wiping procedures. In addition three dust
collectors on the roof would be emptied. The collected dust
would be transported to an off-site EPA-permitted treatment and
disposal facility. The contaminated water in the floor drains
and condensers also would be removed and disposed of off-site.
UNDERGROUND STORAGE TANKS
»
Alternative T-l: Mo Further Action
Capital Cost: $2,600
O & M Cost: $2,200 per year
Present Worth Cost: $64,300
Time to Implement: 1 month
Under this alternative the underground tanks and contents would
be left in place. The large amounts of hazardous materials
contained in the tanks would continue to constitute a potential
source of soil and groundwater contamination. A monitoring
program using the existing monitoring wells would be established
to detect the movement of these compounds into the groundwater.
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Alternative T-2: Removal and Off-Site Treatment/Disposal
Capital Cost: $336,300
O & M Cost: none
Present Worth Cost: $336,300
Time to Implement: 6 months
This alternative entails excavation of overburden soils, pumping
of tank contents, tank cleaning, removal of tanks and associated
equipment, off-site disposal/treatment of tanks, equipment and
liquid waste, and backfilling with clean soil. A portion of the
wastes (tank content) could be reused if practical.
The underground tanks and associated piping would be drained and
cleaned of any residual sludge. Tanks would be hoisted and
subsequently loaded on trucks and hauled off-site for disposal.
Other components of the tank farm, such as pumps, concrete pads,
and the pumphouse, would be demolished and transported off-site
for disposal. At the disposal facility, the steel tanks would be
retested for hazardous waste contents. Nonhazardous tanks would
either be sold for scrap or landfilled, depending on the extent
to which they could be decontaminated. Hazardous tanks and tank
contents would be disposed of at an off-site EPA-approved
hazardous waste treatment and disposal facility.
Contaminated soils discovered during tank excavation would be
stockpiled in roll-off containers and subsequently transported to
an off-site EPA-permitted treatment and disposal facility.
Alternately, the contaminated soils could be treated on-site
using the low temperature thermal treatment unit. After
treatment, the soils would no longer be deemed to contain listed
RCRA hazardous constituents because the soils would be treated to
below health-based levels and would be treated in accordance with
the treatment standards required by RCRA Land Disposal
Restrictions (LDRs). Because the soils would no longer contain
any listed RCRA hazardous constituents above health-based levels,
they would not be subject to regulation under Subtitle C of RCRA
and may be used to backfill the excavated areas on-site.
Sampling of the soils underlying the tank farm would be conducted
as part of this alternative to further delineate the nature and
extent of soil contamination within this area and to assess
effectiveness of the remedy.
A description of the remedial alternatives retained and evaluated
in detail is provided below.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
*
EPA has developed nine criteria in "The Feasibility Study:
Detailed Analysis of Remedial Action Alternatives" (OSWER.
Directive 9355.3-01) to evaluate potential alternatives to ensure
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all important considerations are factored into remedy selection
decisions. The major objective of this section is to .evaluate
the relative performance of the alternatives with respect to the
criteria so that the advantages and disadvantages associated with
each cleanup option are clearly understood.
The evaluation criteria are noted and explained below.
o Overall protection of human health and the environment
addresses whether or not a remedy provides adequate
protection and describes how risks posed through each
exposure pathway (based on a reasonable maximum exposure
scenario) are eliminated, reduced, or controlled through
treatment, engineering controls, or institutional controls.
o Compliance with applicable or relevant and appropriate
requirements (ARAR's) addresses whether or not a remedy
would meet all of the applicable or relevant and appropriate
requirements of other federal and state environmental
statutes and requirements or provide grounds for invoking a
waiver.
o Long-term effectiveness and permanence refers to the ability
of a remedy to maintain reliable protection of human health
and the environment over time, once cleanup goals have been
met. It also addresses the magnitude and effectiveness of
the measures that may be required to manage the risk posed
by treatment residuals and/or untreated wastes.
o Reduction of toxicity. mobility, or volume through treatment
is the anticipated performance of the treatment
technologies, with respect to these parameters, a remedy may
employ.
o Short-term effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human
health and the environment that may be posed during the
construction and implementation periods until cleanup goals
are achieved.
o Implementability is the technical and administrative
feasibility of a remedy, including the availability of
materials and services needed to implement a particular
option. »
o Cost includes estimated capital and operation and
maintenance costs, and net present worth costs.
o State acceptance indicates whether, based on its review of
the RI/FS and Proposed Plan, the State concurs with,
opposes, or has no comment on the selected remedy at; the
present time.
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o Community acceptance refers to the public's general response
to the alternatives described in the Proposed Plan and the
RI/FS reports.
ANALYSIS
Comparison Among Soil (SC) Alternatives
o Overall Protection of Human Health and the Environment
Alternative SC-1 does not meet the remedial objectives, thus it
is not protective of human health and the environment. As a
result of this alternative, the groundwater would continue to be
contaminated directly or indirectly by the soil (groundwater
percolating through soil into the groundwater) for some unknown
period. Alternatives SC-3, SC-4 and to some extent SC-5 would
meet the remedial objective of protecting the groundwater from
the soil source by achieving the cleanup levels in soils.
Therefore, alternatives SC-3, SC-4 and SC-5 (to a lesser extent)
are protective of human health and the environment.
o Compliance with ARARs
All technologies proposed for use in Alternative SC-3 through
SC-5 would be designed and implemented to satisfy all ARARs.
federal and state regulations dealing with the handling and
transportation of hazardous wastes to a fully EPA-approved off-
site treatment facility would be followed. Under Alternative SC-
4, treated soils would not longer constitute a potential source
of groundwater contamination and could therefore, be redeposited
on-site in compliance with all RCRA standards.
o Long—Term Effectiveness and Permanence
Alternative SC-1 would only monitor the migration of the
contaminants and would not provide treatment or containment.
Therefore, it would not provide effective or permanent long-term
protection of groundwater at the Site.
Alternatives SC-3, SC-4 and SC-5 have similar abilities to
mitigate the risks through the removal and treatment of site
contaminants to meet the required cleanup levels. Alternatives
SC-3 and SC-4 are highly effective, since they effectively can
remove the contaminants from the soil. Alternative SC-5 is
intended to have a similar ability to mitigate soil
contamination, however due to the technical limitations of the
in-situ process, SC-5 may not leisure complete remediation of
soils. The technical limitations inherent in this technology
include decreased efficiency for very shallow contamination, and
because of the possible need for supplementation with other
treatment methods.
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o Reduction in Toxicity. Mobility, or Volume
Alternative SOI would provide a very slow and gradual reduction
in toxicity through rainfall percolation, but there would be no
treatment to reduce the mobility, toxicity or volume of
contamination in a reasonable timeframe. It would provide no
reduction in contaminant mobility or volume.
Alternatives SC-3, SC-4, and'SC-5 are similar in that each would
result in significant reductions in the toxicity, mobility, and
volume of the treated material through treatment. Material
toxicity would be reduced by thermal destruction of contaminants
in Alternatives SC-3 and SC-4 and by off-site treatment of the
condensed organic product in SC-5. Alternative SC-3 would
provide the greatest degree ofttreduction in toxicity of the
contaminants followed by SC-4 and SC-5.
o Short-Term Effectiveness
The implementation of Alternative SC-1 would not result in
additional risk to the community during implementation, since no
action would be taken. Alternatives SC-3, SC-4, and SC-5 include
activities such as contaminated soil excavation and off-site
transport or on-site treatment that could potentially expose
residents to volatilized contaminants and contaminated dust.
Engineering controls and other measures (e.g. restricting access
to the Site to authorized personnel only) would effectively
eliminate any significant impact these activities would have on
nearby residents. Alternative SC-5 includes in-situ treatment of
contaminated soils, so exposure risks to residents from
excavation is much less of a concern for this alternative than
SC-3 and SC-4. Under alternatives SC-4 and SC-5, proper air
emission control units would .be installed to minimize the
potential for public health exposures because of low-level
emissions from the on-site treatment units.
Alternative SC-1 would result in a lower overall risks to workers
than other alternatives, since^subsurface soil is not disturbed.
Alternatives SC-4 and SC-5 provide treatment on-site, thereby
reducing potential risks to residents along transportation
routes. Alternatives SC-3, SC-4, and SC-5 would present a
potential for worker exposure to volatilized contaminants during
waste excavation and/or handling. To minimize and/or prevent
such exposures, use of personal protection equipment would be
necessary.
SC-1 would be implemented in approximately one month.
Alternatives SC-3, SC-4 and SC-5 would be implemented in about
3.5, 3.5 and 4 years, respectively.
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o Implementability
Components of Alternatives SC-1, SC-3, SC-4 and SC-5 would
utilize relatively common construction equipment and materials.
Little construction difficulty would be encountered with any of
the alternatives. However, Alternative SC-1 would be the easiest
to implement.
The technologies proposed for use in the alternatives are proven
and reliable in achieving the specified process efficiencies and
performance goals. Low temperature thermal enhanced
volatilization and in-situ vacuum extraction have been
successfully tested at other Superfund sites. However, there is
a greater degree of uncertainty regarding the achieving of
cleanup levels using in-situ vacuum extraction, since this
technology only has been utilized on a limited full-scale basis
at similar contaminant concentration levels.
o Cost
The total present worth costs *for the alternatives evaluated
range from $385,600 (in-situ vacuum extraction) to $5,000,000
(off-site treatment and disposal). The present worth calculation
uses a 5% discount rate, and a 30-year operational period in the
case of SC-1. All other source control alternatives would not
require any operation and maintenance cost. Therefore, present
worth for these alternatives (SC-3, SC-4 and SC-5) would be the
same as the capital cost. SC-4 provides the same protection as
Alternative SC-3 at a fraction of the cost ($700,000 versus
$5,000,000). Although Alternative SC-5 is significantly less
expensive than SC-3 and SC-4, it may not provide the same level
of protection.
o State Acceptance
NYSDEC concurred with the selection of Alternative SC-4.
o Community Acceptance
The community have expressed support for the alternative selected
for the remediation of the soils.
Comparison of the Groundwater (GW) Alternatives
o Overall Protection of Human Health and the Environment
The no-action alternative would not protect human health and the
environment. Existing contamination would continue to degrade
the aquifer and migrate off-site.
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Alternative GW-2 would not ensure protection of the health of
future users of the aquifer nor would it improve the overall
quality of the aquifer or prevent the continued migration of
contamination.
Each of the alternatives GW-3A, GW-3B, GW-5A and GW-5B would be
significantly more protective than GW-1 or GW-2, since they would
reduce the toxicity, mobility, and volume of contaminants in the
aquifers. Each treatment alternative considered would equally
protect human health and the environment; however, the amount of
time required to achieve the ARARs varies greatly among
alternatives.
o Compliance with ARARs
Alternatives GW-1 and GW-2 would result in contaminant
concentrations remaining above ARARs (for drinking water or
protection of the groundwater resources) for a long period of
time (estimated at 100 years).
Alternatives GW-3A, GW-3B, GW-5A and GW-5B would be designed to
achieve all drinking water standards as well as those required
for groundwater protection in the treated water stream which is
to be reinjected. Each of the^e alternatives would be capable of
providing the required contaminant removal levels. Because
experience with UV-chemical systems is limited, its effectiveness
is slightly less certain but considered achievable. Each of the
alternatives would comply with federal and state air emission
standards as well as regulations for the handling and disposal of
the generated wastes (e.g. spent carbon).
o Lona-Term Effectiveness and Permanence
Alternative GW-1 does not provide treatment but would attempt to
restrict usage of contaminated groundwater. Alternative GW-2
provides short-term treatment, but would not restore the
contaminated aquifer for its best beneficial future use.
Alternatives GW-3A, GW-3B, GW-5A, and GW-5B all reduce the
potential risks associated with groundwater ingestion by
extracting, treating, and recharging the treated groundwater to
remove contaminants from the aquifer. The time required to
achieve these risk reductions depends on the effective extraction
rates from the aquifer and limitations on extraction system
placement due to the large area of the contaminant plume.
Long-term effectiveness of each system is dependent on monitoring
and maintenance of the treatment system.
Alternatives GW-l and GW-2 would take approximately 100 years to
achieve the remedial action objectives. Alternatives GW-3A and
5A would theoretically achieve the remedial action objectives in
-------
25
62 years, whereas GW-3B and 5B would achieve the remedial action
objectives in approximately 16 years.
Proper air pollution control measures would be established under
alternatives GW-3A and GW-3B to offset potential risks from the
air stripper(s), while no air pollution control measures are
deemed necessary for alternatives GW-5B and 5A. Alternatives
GW-3A and GW-3B require the disposal of more spent carbon than
GW-5A and GW-5B, since carbon- adsorption is used.
o Reduction in Toxicity, Mobility, or Volume
Alternative GW-1 would very slowly and gradually reduce the
toxicity of contaminants through dilution but there would be no
treatment to reduce toxicity, mobility or volume. Alternative
GW-2 would reduce the toxicity and volume of contaminants more
rapidly than GW-l. Neither Alternative GW-l nor GW-2 would
permanently reduce the mobility of the contaminants. For
alternative GW-2, the off-site portion of the contaminated
groundwater plume would continue to migrate downgradient, and
reduction of toxicity, mobility and volume would be achieved only
by natural attenuation.
Alternatives GW-3A, GW-3B, GW-5A and GW-5B would reduce the
toxicity, mobility, and volume of contaminants in the aquifers to
a greater extent than GW-l and GW-2. Alternatives GW-3B and 5B
would reduce the toxicity, mobility, and volume to a greater
extent and at a much faster rate than the other alternatives.
Alternatives GW-3A and GW-3B would use air stripping and carbon
adsorption to remove the contaminants, while GW-5A and GW-5B
would oxidize most of the organic compounds.
o Short-Term Effectiveness^
Implementation of Alternative GW-l would result in no additional
risk to the community during remedial activities, since no
treatment would occur. Alternative GW-2 could present additional
risks to the community resulting from the installation of the
extraction wells and pipelines for transportation of contaminated
groundwater. Alternatives GW-3A, GW-3B, GW-5A and GW-5B include
excavation activities, installation of the collection and
reinjection system, and construction of the treatment plant which
could result in potentially exposing residents to volatilized
contaminants and contaminated dust. The treatment plant would be
constructed on-site. Proper ei»girieering controls would ensure
that the impact of such activities would be insignificant. All
alternatives except Alternatives GW-l and GW-2 would provide a
process residual requiring proper handling and disposal.
Alternative GW-l would result in no additional risk to workers,
and GW-2 would result in a lower overall worker risk than other
alternatives because of the limited soil disturbance activities.
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26
Personal protection equipment would be used under alternatives
GW-3A, GW-3B, GW-5A and GW-5B to minimize the worker's potential
exposure to volatilized contaminants during installation of the
collection, treatment, and recharge systems.
GW-1 would be implemented in approximately one year. Each of the
remaining alternatives would be implemented in about 3 years.
o Implementability
*'
Alternative GW-l would be easily implemented. Alternative GW-2
would require institutional management to maintain and operate
the pumping system and to coordinate with the Old Bethpage
Landfill treatment system. Alternatives GW-3A, GW-3B, GW-5A and
GW-5B would utilize relatively common construction equipment and
materials. Little construction difficulty would occur with any
of the alternatives.
The air stripping and carbon adsorption technologies proposed for
use in Alternatives GW-3A and GW-3B are proven and reliable in
achieving specified process efficiencies and performance goals.
While there has been limited experience with UV-chemical
oxidation, it has been successful in several groundwater
treatment facilities.
All proposed technologies are readily available from a number of
sources, with the exception of UV-chemical oxidation.
Alternatives GW-3A, GW-3B, GW-5A, and GW-5B would require
institutional management of the operation and maintenance of the
treated groundwater reinjection systems. Siting the treatment
facility would not present any problems as there is enough space
available on-site. Location of associated off-site facilities
(e.g. piping, pumps, extraction wells and reinjection wells)
would be more complex as both technical and land use factors
would be considered.
Off-site disposal facilities are available for the disposal of
the pretreatment sludge and spent carbon generated from
Alternatives GW-3A, GW-3B, GW-5A and GW-5B.
o Cost
The present worth costs of all GW.alternatives ranged from
$464,400 (GW-1) to $28,987,000 (GW-3A). Alternative GW-1 would
be least expensive followed by GW-2, GW-5B, GW-3B, GW-5A and
GW-3A. Of the alternatives providing complete remediation of the
groundwater contamination, Alternative GW-3B provides the lowest
present worth cost, $15,620,400.
-------
27
o State Acceptance
NYSDEC concurs with the selection of Alternative GW-3A for
groundwater treatment.
o Community Acceptance
The community have expressed support for the alternative selected
for the remediation of the groundvater.
Comparison of Building Alternatives (BD)
o Overall Protection of Human Health and the Environment
In Alternative BD-1, hazardous material would be left in the
building. Human health and the environment remain protected only
as long as building security could be effectively enforced and
building integrity maintained. Alternative BD-2 would remove all
hazardous material from the building, so it would be fully
protective of human health and the environment. In addition,
Alternative BD-2 allows for future reuse of the building.
o Compliance with ARARs
Alternative BD-1 would not contravene any ARARs, since no action
would be taken. Alternative BD-2 would comply with the ARARs
including RCRA land disposal restrictions as well as those
regulations related to the transport of the wastes to an off-
site facility. The off-site treatment facility would be fully
EPA-permitted and therefore meet applicable regulations.
o Long-Term Effectiveness and Permanence
Alternative BD-1 would not alter conditions within the building;
hazardous materials would remain in the building. Public
protection would rely on maintaining building security which
might be difficult to enforce. The building could not be used
for any purpose. Alternative BD-2 would remove all hazardous
materials from the building for off-site treatment and disposal
so that long-term exposure risks from the building would be
eliminated. Painting and sealing the building (Alternative BD-2)
would provide additional protection and would allow for
unrestricted use of the building in the future.
o Reduction in Toxicity. Mobility or Volume
Alternative BD-1 would provide no reduction in toxicity or volume
of contaminants; mobility is not an issue since the building is
self-contained. Alternative BD-2 would provide for complete
reduction in toxicity and volume, since all contaminated material
would be removed from the building.
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28
o Short-Term Effectiveness
Implementation of BD-1 would result in no additional risks to the
community or the environment as long as building security and
integrity could be maintained. Alternative BD-2 involves removal
and transport of the contaminants from the building, so there
would be some minimal public exposure risks as well as
environmental impacts from potential waste spills resulting from
possible transport accidents during remedial activities. Worker
exposure risks would be minimized through the use of personal
protection equipment. Long-term maintenance would continue
indefinitely for Alternative BD-1. Building decontamination,
Alternative BD-2, could be accomplished in approximately 3
months.
o Implementability
Both alternatives are readily ^Lmplementable; neither involves any
major construction activities. Methods and services for building
decontamination are technically feasible and readily available.
Alternative BD-1 would require institutional management i.e., a
long-term building maintenance program, whereas Alternative BD-2
would not require any long-term management.
o Cost
The present worth costs for Alternatives BD-1 and BD-2 are
$41,100 and $186,200, respectively.
o State Acceptance
NYSDEC concurs with the preferred building alternative selected.
o Community Acceptance
The community have expressed support for the alternative selected
for the remediation of the building.
Comparison of the Underground Tank (T) Alternatives
o Overall Protection of Human Health and the Environment
Alternative T-l would not protect human health and the
environment as the threat of soil and groundwater contamination
would not be reduced. The excavation and removal of contaminated
tanks and their contents from the Site (T-2) would significantly
reduce the potential human health and environmental risks
associated with potential leaking of contaminants from tanks into
the .soil and groundwater.
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29
o Compliance With ARARs
Alternative T-l would not facilitate compliance with groundwater
ARARs,.as a continual source*of contamination would not be
removed. The disposal of the underground tanks (T-2) would
eliminate the source of contamination and would satisfy state and
federal ARARs. The tanks wastes would be removed, transported,
and disposed of in accordance with all regulations. Contaminated
soils would be disposed off in accordance with all applicable
state and federal ARARs. Soils would be transported to an off-
site EPA-permitted treatment and disposal facility; or in the
alternative, the soils could be treated on-site using the low
temperature thermal treatment unit. After treatment, the soils
would not longer be deemed to contain listed RCRA hazardous
constituents because it would be treated to below health-based
levels and would be treated in accordance with the treatment
standards required by RCRA Land Disposal Restrictions.
o Lona-Term Effectiveness and Permanence
Under Alternative T-l, the tanks and their associated hazardous
wastes would remain as a potential source of soil and groundwater
contamination. Alternative T-2, excavation and removal of the
underground storage tanks, tank debris, and highly contaminated
soil from the Site, would reduce the potential human health and
environmental risks associated with the tanks' potential for
leaking contaminants into the soil and groundwater in the future.
o Reduction of Toxicitv. Mobility or Volume
No significant reduction of toxicity, mobility or volume would
result from the implementation of the no-action alternative.
Alternative T-2, excavation and off-site treatment, would result
in a permanent reduction of toxicity, mobility and volume. The
wastes would be completely removed and either destroyed at the
treatment facility or reused if practical.
o Short-Term Effectiveness
Alternative T-l would result in no additional risk to the
community during implementation.
The potential public health threats to workers and area residents
associated with the implementation of Alternative T-2 include:
direct contact of workers with tank contents and potentially
contaminated soils; inhalation of fugitive dust, organic vapors,
and emissions generated during construction and excavation
activities; and improper handling of soil and hazardous liquids.
Several steps would be taken to minimize these threats including:
Site access would be restricted to authorized personnel only;
and, dust control measures such as wind screens and water sprays
-------
30
would be used to minimize fugitive dust emissions.
The risk to workers during excavation would be minimized by the
use of adequate personal protection equipment to prevent direct
contact with potentially contaminated soil, liquids, and
inhalation of fugitive dust and volatile organic compounds.
Other potential short-term impacts contemplated as part of T-2
would be an increase in traffic and noise pollution resulting
from hauling soils (as necessary), hazardous liquids, and tanks
to an off-site treatment facility, as well as the traffic
associated with transporting new soil for backfill to the Site.
Transportation of excavated hazardous liquids might introduce
short-term risks with the possibility of spillage along the
transport route and potential exposure of the public to hazardous
material. A spill contingency plan would be developed to address
and minimize the likelihood and potential impact of this
occurrence. The actual remediation period for this alternative
is estimated to be 8 weeks.
o Implementab i1ity
Alternative T-l is easily implementable, since no action would be
taken. All the components of Alternative T-2 are well developed
and commercially available. The contained tanks and related
wastes would have to undergo a series of analyses prior
to acceptance for treatment at the EPA-permitted off-site
facility. Sufficient land is available at the Site for
mobilization and temporary storage of the excavated soil and
materials awaiting pre-transport decontamination. Excavation,
treatment tank decommissioning, transportation to an off-site
treatment facility, solid and liquid waste disposal, and
restoration of the Site can be performed without any major
difficulties.
6 Cost M
The total present worth cost of Alternative T-l is $64,300. The
total present worth cost of Alternative T-2, which represents the
estimated construction cost for the eight week remediation
program, is estimated at $336,300. Operation and maintenance
costs have not been included in the cost estimate since the
duration of the remediation program is less than one year.
o State Acceptance
NYSDEC concurs with the selection of underground tank alternative
T-2.
o Community Acceptance
The community has expressed support for the alternative selected
-------
31
for the remediation of the underground tanks.
SELECTED REMEDY
The preferred alternative will achieve substantial risk reduction
through a combination of source control alternatives SC-4 (low
temperature enhanced volatilization of soil contaminants) and T-
2 (tank removal and off-site treatment), with active restoration
of the groundwater (GW-3B), and building decontamination (BD-2).
The preferred alternative achieves this risk reduction more
quickly and at substantially less cost than the other options.
Therefore, the preferred alternative will provide the best
balance of trade-offs among alternatives with respect to the
evaluating criteria. Based on the information available at this
time, EPA and the NYSDEC believe that the preferred alternative
will be protective of human health and the environment, will
comply with ARARs, will be cost effective, and will utilize
permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable.
The remedy also will meet the statutory preference for the use of
treatment as a principal element.
STATUTORY DETERMINATIONS
1. Protection of Human Health and the Environment
The selected remedy is considered fully protective of human
health and the environment. The treatment of the contaminated
soils through the low temperature enhanced volatilization process
will remove the organic contaminants from the soil. When
combined with the removal of the underground tanks, it will
result in the elimination of both long-term sources of
groundwater contamination. The extraction and treatment of the
contaminated groundwater using^air stripping and carbon
adsorption will provide excellent protection of both human health
and the environment. Decontamination of the building will ensure
that public health is protected.
2. Compliance with ARARs
The soil portion of the remedy (SC-4: excavation and on-site
treatment of the contaminated soils) will comply with all action-
specific ARAR's. Contaminated soils will be treated to health-
based levels. Since the treated soils no longer will constitute
a source of groundwater contamination, they will be redeposited
on-site in compliance with all RCRA standards. The groundwater
portion of the selected remedy (GW-3B: extraction and treatment
of the contaminant plume) will comply with all related ARARs
including NY Groundwater Quality Standards and Federal Maximum
Contaminant Levels.
-------
32
The building decontamination (BD-2) and underground tank removal
(T-2) will comply with all ARAR's. The off -site treatment
facility will be fully RCRA permitted and, therefore, will meet
all applicable regulations. Wastes will be treated using
specific technologies or specific treatment levels. The remedy
will comply with regulations including RCRA Standards Applicable
to Owners and Operators of TSD Facilities, RCRA Standards
Applicable to Transport of Hazardous Wastes, NY Air Quality
Standards, NY Hazardous Waste Manifest System Rules, and NY
Hazardous Waste Treatment Storage and Disposal Facility
Permitting Requirements.
A summary of ARARs associated with the selected remedy is
presented in Table 13.
3. Cost Effectiveness
The selected remedy is cost effective in that it provides overall
effectiveness proportional to its cost. The total capital and
present worth costs of the remedy are $6,200,000 and $16,800,000,
respectively. In proportion to the total capital cost, 11 per
cent is attributed to the soil portion; 80 per cent to the
groundwater portion; and the remaining 9 per cent to the building
and underground tank portion. The cost of the soil component is
higher than the in-situ vacuum, extraction option; however, low
temperature treatment provides complete certainty with regard to
efficiency, at a fraction of the cost associated with the off-
site treatment option. Likewise, although the cost of the air
stripping/carbon adsorption is higher than the UV/oxidation, air
stripping/ carbon adsorption provides a higher degree of certainty
that all groundwater contaminants will be removed.
4. Utilization of Permanent Solutions and Alternative Treatment
Technoloies to the Maximum Extent Practicable
The selected remedy utilizes permanent solutions and treatment
technologies to the maximum extent practicable. Of those
alternatives which are protective of human health and the
environment, and comply with ARARs, the selected remedy best
balances the goals of long-term effectiveness and permanence,
reduction of toxicity, mobility or volume achieved through
treatment, short-term effectiveness, implementability, cost, and
also achieves the statutory preference for treatment as a
principal element and has state and community acceptance.
• •
After the soil is treated and the underground tanks are removed,
the potential for future releases of waste to the environment
will be eliminated. The indirect and direct risks posed by the
soil and tanks as a continued source of groundwater contamination
will be eliminated. This action, in conjunction with the
groundwater extraction and treatment component, will restore the
aquifer to its most beneficial use and will meet all federal and
-------
33
state standards.
No short-term adverse impacts and threats to human health and the
environment are foreseen as the result of implementing the
selected remedy. However, to minimize and/or prevent worker
exposure to contaminants, personal protection equipment will be
used.
The selected remedy will require construction of on-site soil and
groundwater treatment facilities. No technological problems
should arise as all the treatment technologies are well
established, readily available and possess a proven track record.
<
5. Preference for Treatment as the Principal Element
The selected remedy fully satisfies this criterion for the source
of contamination (soil and underground tanks), groundwater, and
building contamination which are considered the principal threats
at the Site. Therefore, the statutory preference for remedies
that employ treatment as a principal element is satisfied.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Claremont Polychemical site was
released to the public on August 24, 1990. The Proposed Plan
identified Alternative SC-4 combined with Alternatives GW-3B,
BD-2 and T-2 as the preferred alternative. EPA reviewed all
written and verbal comments submitted during the public comment
period. Upon review of these comments, EPA determined that no
significant changes to the selected remedy, as it was originally
identified in the Proposed Plan, are necessary.
-------
APPENDIX A. FIGURES
-------
V- y^'-x\';V/.'**J
.o^
NASSAU COUNTY
FIREMEN'S TRAINING
CENTER \/ j • /: '••;.
-3 T =——J\ 7...-, .il/. ."
• ^
s.
>
SCALE IN FEET
R • RECHARGE BASIN
ENVIRONMENTAL PROTECTION
AGENCY
CLAREMONT POLYCHE^CAL FACILITY
FIGURE 1
SITE LOCATION
E3A5CO SERV^CJI
-------
U.S. ENVIRONMENTAL rflOUCTION
AGENCY
ClAflEUONT PtXTCHfMICA! SITE
KALI
•4 104
Mir
FIGURE 2
BITE RAP
-------
» U
» U »~
II IT
H-
OQ
C
>-t
n
u>
-------
(X)
c
n>
*-
-------
PROCESS
BUILDING
EXTENT OF PCC CONTAMINATION
MS OftAMMC OUSTS ON A CAM) fH£. DO HOI RTMSf If UANUAU.Y
EBASCO SERVICES INCORPORATED
us DcvnrainitNTAL PROTFCTION
P1LFS OF RECOITIY
otpoarn) DEBRIS OR son.
nun* orrsin:
MTt . 9<0 W
D.K . OSW „
CURE MOW f POLYUICUICAL SITE
ClARfTSJDWR "»"
-------
Figure 6
_12_
&MOMKT ML1MMCM. ft
miautf^e auTaa
-------
Figure 7
STATl UMVWSTT
AGDlCULTUKE AND
i Tt.CH COUXSt
U • NON-OETECT
ii ESTIMATED CONCENTRATION CONTOURS
NOTE: COK.TOUH INTERVALS INCHEAS»«T A »*CTO* OF 1« •— •
' HIGHEST CONTOUR LEVEL REPRESENTS 1000 ug/1
-------
APPENDIX B. TABLES
-------
Table 1
Site History Summary
CONSTRUCTION OF THE CLAREMONT POLYCHEMICAL FACILITY BEGAN IN
1966
PLANT OPERATION BEGAN IN 1968
MORE THAN A THOUSAND DRUMS WERE DISCOVERED IN 1979 BY THE
NASSAU COUNTY DEPARTMENT OF HEALTH (NCDOH)
MUST OF THE DRUMS WERE GONE AND AREA OF CONTAMINATED SOIL
(SPILL AREA) WAS DISCOVERED IN 1980 BY NCDOH
SOILS WERE EXCAVATED AND PLACED ON PLASTIC LINERS IN 1980 BY
THE COMPANY
COMPANY ENTERED INTO CHAPTER 11 PROCEEDINGS IN 1980
NEW YORK DEPARTMENT OF LAW ASSUMES THE LEAD ON THE SITE AND
ATTEMPTS TO NEGOTIATE AN AGREEMENT WITH RESPONSIBLE PARTY
SITE RECOMMENDED FOR PLACEMENT IN NATIONAL PRIORITY LIST IN
OCTOBER 1984
SITE WAS FINALLY INCLUDED IN NATIONAL PRIORITY LIST IN JUNE
1986 (RANKED 614)
EPA ASSUMES THE LEAD IN 1986 AND SENDS OUT NOTIFICATION
LETTER TO POTENTIALLY RESPONSIBLE PARTY (PRP) IN NOVEMBER
1987
NO RESPONSE WAS RECEIVED AND FUNDS FOR REMEDIAL
INVESTIGATION/FEASIBILITY STUDY (RI/FS) ARE ALLOCATED IN
MARCH 1988
EBASCO SERVICES IS CONTRACTED BY EPA TO CONDUCT RI/FS (l"
OPERABLE UNIT) IN MARCH 1988
EPA CONDUCTS REMOVAL ACTION IN OCTOBER 1988 TO STABILIZE
fc'ASTES
SECOWD RI/FS (2nd OPERABLE UNIT) IS OPEN IN APRIL 1989 TO
ADDRESS THE DISPOSAL OF WASTES CONTAIN IN HOLDING UNITS
(DRUMS, BASINS, ETC)
IMPLEMENTATION OF REMEDY FOR 2- OPERABLE UNIT STARTS IN
SEPTEMBER 1989
RI/FS FOR 1" OPERABLE UNIT IS FINALIZED AND REPORTS ARE
RELEASED FOR PUBLIC CCMKENT IN AUGUST 1990
-------
TABLE 2
COMPARISON OF CONCENTRATION RANGKS Ol:> METALS IN
SURFACE SOIL TO TYPICAL REGIONAL IIACKOKOUW) I.KVIiL
Concentration Rnngc in
Typical Eastern U.S.
Conccn t rn I i on
Su i T m.'c So i I
n
Al
Sb
As
Ba
Be
Cd
Ca
Cr
Co
Cu
Fe
Pb
Mg
Mn
Wg
Ni
K
Se
Na
V
Zn
<")
c.>
(ND)
10000-300000
<1-500(1)
5-15(1)
100-3500
<1-7(1)
0.01-7
100-400000
10-00(1)
<3-70(1)
2-100
7000-550000
3-30U)
GOO-GOOO
100-4000
0.2-O.G(1)
4-30(1)
400-30000
0.1-2.0
750-7500
20-500
10-300
- Dragun, 1900.
- Conner, J.J. and II. T. Shacklcttc,
- Not detected
J72u-5n:i<)
NU-(iO
2.2-9.3
G.H--?.:.U
HD-J .2
ND-33. J
7Q.7-4'J700
3.0-75.'}
NO-3. 1
(..4-230
2'1GO-J3'.»00
7.2-377
31.4-29;! 00
](). (.-203
ND-0.22
NH- 14 . 1
ND-331>
ND-1 .3
ND-2G3
'J.2-2G. 0
6.7-32UO
1'JTj .
-------
Vp 1 a I i 1 e 0 rg an ?cs
Methylen? Chloride
Tetrachloroe1. r.ene
'. -1,2-Oichloroethene
Trichloroelher.e
1,1.2-Trichloroe th
Acetone
Toluene
2-Bu'.anone
Xy>nes
9en2e!a)anthracene
Chrysone
?enzo(b)f1uoranlhene
3enzo( k ) '1 uoranlhene
Senio!a)pyr?ne
indenol 1 ,2.3-C,d)pyrene
0 i benzol a. b) anthracene
Benzulg.h. . )perylene
Oimeti-.ylphthalal*
?i -o-hut ylphthalat J
3ut yi ipniylr'hthala'.S
?i -n-oc t ylphthalat*
3ii(2«elhyl»>exyl Jphthalate
5enj» c Ac i d
HO- 130
NO- jbO
NO-63
HO- 130
HO- 3 3
ND-33000
NO-390
NO- 90
NO- 130
MO- 170
NO- 7 5
HO-150
NO- 1100
HO-590
MD-2000
MO- 1900
NO- 7 80
"0-960
MO-8BO
•10-880
NO-820
HD-330
ND-200
HD-420
_
NO-3900
HO-8200
NO-87
NO-270000
NO-120
-
ND-11
_
-
-
ND-3 10
NO- 140
ND-67
-
ND-200
NO- 110
HO- 180
NO- 1500
ND-340
NO- 1500
NO-950
ND-700
ND-700
NO- 700
NO-580
NO- 7 40
NO-260
ND-KO
NO- 2 80
NO-48
NO-2100
NO- 1500
-
ND-4QOOI
-
Table 3
CLARF.MONT I'OLYCHF.MICAL SITE
Subsurface Soil Borings (ug/kg)
Unsaturated Saturated
Soi1 Soi1
>55 rtgt
HD-8
HD-26000
ND-1
HO- 1 1
NO- 11
NO-82
_
NO- 150
ND-7
NO- 100
HO- 36
-
ND-270
NP-55
NO- 10
-
'
HD-210
HO -3
ND-1 7
ND-6
ND-7
NO-26
NO- 2 7
ND-3
W-19
NO-
NO-5
ND-170
HD-1
ND-70
no-s
NO- 3 A
ND-7
HO-15
NO-20
110-15
_
NO-: 3
HO- 18
ND-3
-
_
ND-200
NO- 2 5
NO- 13
ND-4
ND-5
ND-110
ND-71
ND-9
_
NO-32
ND-H
NO-110
NO II
NO-J300
NO-360
NO--J1
NO-/10
ND-270
NO-7 4
NO-62
NO-100 NO-1SOO
ND-53
ND-1600
NO-1300
ND-50
NO-190
ND-65
NO-150
NO-170
ND-17
NO-520
NO-390
-------
TABLE J tlont-oi
Etsiic ii«i
HeptacMor
Oieldrin
DOE
ODD
00 T
KB'3
PCB 1218
PCB 1254
PCB 1260
CONCENTRATION RANGES OF ORGANIC COMPOUNDS IN
SUBSURFACE SOIL DOR INGS (ug/kg)
Unsaturaled Saturated
Soil Soil
5-10 Feet 10-15 Teet 15=2P_fj.ei 2JblO_r«A 30-dQ Feet 4Jb5.0_F{ei 50-65 Feet >65 Feet >6S Feet
NO-18
NO-26
ND-70
ND-35
NO-61
ND-660
NO-120
HO-650
NO-110
NO-IBO
ND-88
NO-1)00
(NO) or (-) - Not delected.
)_i All concentration*
-------
TABU 3
CONCENTRATION RANGES Of METAIS IM
SUBSUHrACE SOIL BORINGS AND IHEIR COMPARISON 10 TYPICAL REGIONAL BACKGROUND LEVELS
Oncent rat • DO
Ranoe
LL?!>?'
Sb
As
Ba
Ee
Cd
Ca
Cr
Co
Cu
fe
rb
Mg
Mn
Ho
Mi
K
Se
Ag
Na
V
2n
Typical
;.. T Iqroun;)
:'. S ;i 1 ' Ippir.j*
t; 00-300000
,: 500">
t.15M)
100-3500
65_£isA
201-1330
MO-5.3
1.0-13.2
NO-15.2 *•
-
ND-2.0 '
25.1-1070
ND- 1 . 9
NO- ' . 7
2. £-1:2
1200-7070
1.2-5.S
NO- 103
3.1-13.6
-
HO-2.5
NO-233
NC-0 . 51
ND-0: 65
-
2.7-10.9
ND-31.1
(•) - Oragun, J.. 1963.
(1) - Conner, J. J. and H. T. Shacklett*. 1975.
-------
TABLE 4
CONCENTRATION RANGES OF VOLATILE ORGANIC COMPOUNDS
IN GROUNOUATER BY AREA AT THE CLAREMONT SITE
Rounds I & 2 Combined
Safe Drinking
Water Act
C'.MinO'jnd . HCl (ua/l)
A-:eAfl.ne.
0' nzene.
('.. rbon 0:sulf ide
O lorobpniene
Ci loroeH-ane
(. 'orofr .a
j. L-0'ff uroethanj
• ('-Oic!'. oroethane
• '. '-Oich'-oroethene
! J-nicl. ropropane
E'.'iy ibe*"' ene
£ Methyl 2-Pentanone
ML thirl Chloride
L. irachl . roethene
Tc luene
LI tal Xylenes
L ans-l .'• -Oichloroethent
.1 . 1 , l-Trl chloroethane
Lc ichloroethene
Vinyl Chipride
.
5
_
-
-
-
-
5
7
-
-
-
-
_
_
«
_
200
5
2
HYS OOH
MCL (ua/l)
50
5
SO
9
5
100' '
5
5
5
S
5
SO
5
S
5
5
S
S
5
2
NYS Ambient Water
Quality Criteria - Upgradient
Class GA Groundwater (uq/1) Wells (ua/1)
NO
_
20('»
_
100.,
5°r 1
0.8< »,
0.07' '
50;
50< '
-
so*;!.
07''
50 ')
50
SO
50< )
10
2
NO-2
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO-2.0
NO
NO-0. 8
NO
NO
NO
NO-0.2
NO-0 . 3
NO
Site Vicinity
•nd Downgradient
Wells (ua/l)
NO-540
NO-60
NO-0.2
NO-0 . 4
ND-0.8
ND-I
NO- 17
NO-6
NO-4
NO
NO- 160
NO-6
NO- 14
NO- 1300
NO-2
NO-40
ND-830
NO- 100
NO-260
ND-7
landfill/
Off-Site
Plume We,Us (uq/11
ND-7 10
NO-24
ND-4
NO- 19
NO- 7
NO-0 . 2
NO- 12
NO-2
NO
NO-0. 3
NO-0. 6
NO
NO
NO-3.0
NO-0 . 4
NO-0. 6
NO-8
ND-0.6
NO-0. 6
NO-4
(NO) Not detected.
(*) Guidance value.
(I) Applies to sum of trihalomethanes.
(-) Standard currently not available.
''Underlined compounds w«r» found In concentrations exceeding the Federal or New York State Maiimum Concentration Levels (."CLs) or Ambient Water
Quality Criteria (AWQC).
-------
TABLE 4
CONCENTRATION RANGES OF SEMI VOLATILE ORGANIC!
AND PESTICIDES IN GROUNOWATER BY AREA
Rounds I ft 2 Combined
Safe Drinking
Water Act
Comooui J MCL (ug/1)
Semi voi.it i les
Benzoir. Acid
Bis(2-» chylhe, yMphthalate -
"Chrysene -
"1 .4-Q-; chlorpl;en*ene 75
1,2-Oi nlorot niene
Diethyl,ihthal, te
Oi-n-butylphthalate
Fluorai Ihene —
Isopho. jne —
2-Meth; inaphtlialene
Naphih; Lsofi
2-Nitr HvioV.
4-Nlt;-. -henol
Pentacr . oroph nol
Phenri.. ire:'. -
Phenoi .
Pyrene
Pestic ies
XA1 h "HC
A "d" nf T —
'Heptaciilor
NYS DOH
MCL Jug/1)
50
4200
SO
s
5
50
770
SO
SO
SO
50
SO
50
21
50
1
SO
NO
NO
NO
NYS Ambient Water
Qual i ty Criteria -
Class GA Grojtndwater (ug/1)
^
4200
0.002J >
1 ft t
50« >
770
50' '
ioc.
-
50<'>
50«'>
NO
NO
NO
Upgradient
Wells (ug/H
NO
NO-88
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO- 13
NO
NO
NO
NO
Site Vicinity
and Oowngradient
Wells fuo/11
NO-5
NO-92
NO
NO
NO
NO-2
NO-3
NO
NO-4
NO-4
NO-SI
NO- 13
NO-6
NO-2
NO
NO- 30
NO
NO
NO-0 . 1 1
NO
Landfill/
Off-Site
Plume Wells (ug/1)
NO
NO-27
NO-3
NO- 15
NO-3
ND-2
NO
NO-6
NO
NO
NO- 7
NO
NO
NO
NO-4
NO
NO-5
NO-0. 16
NO
NO-0. 047
(NO) Not detected.
(•) Guidance value.
(I) Applies to sum of para (1.4) and ortho (1,2) isowers only.
(-) Standard currently not available.
Underlined compounds *er* found in concentrations exceeding the Federal or New York State Maximum Concentration Levels (*Cls) or Ambient Water
Qualit/ Criteria (AWQC).
<• compounds found above MCLs/AWQC in Landfill Plume wells only.
2-l-HK
-------
TABLE 4
CONCENTRATION RANGES OF TOTAL METALS
IN GROUNOWATER 8V ARF.A
Rounds I & 2 Combined
Element
Aluminum (A1 )
Antimony (Sb)
Arsenic (As)
Barium (Ba)
Beryllium (Be)
Cadnrum (Cd)
Calcium (Ca)
Chroiiiiun (Cr)
Coba't (Co)
Copper (Cu)
Iron (Fe)
Lead (Pb)
Magnesium (Mg)
Manganese (Mn)
Mercury (Hg)
Nick 1 (Ni)
Pota- sium (K)
Sel; um (Se)
Sodio.n (Na)
Thai mm (T1)
Van* um (V)
Zinc (In)
Safe Drinking
Water Act
MCL luo/n
—
-
50
1000
-
10
.
so
-
-
-
so
-
-
2
-
-
10
-
-
-
™
NYS Ambient Water
Qual i ty Criteria -
Clais GA Groundwater (ua/1)
—
3*"*
25
1000
3'*)
10
-
SO
-
1000
300
25
35000* *>
300
2
.
-
20
-
,)(•)
-
5000
Upgradient
Wells lud/l)
NO-43.700
NO
NO-2 1.3
46.2-305
NO-6.6
NO-4.9
37.600-72.100
NO- II 2
NO-45.8
NO- 165
204-90.700
NO-55.1
6,910-15,800
218-549
NO
NO-86.7
10,500-28.200
NO-3.2
9.900-148.000
NO-8.5
NO-465
30.2-650
Site Vicinity and
Oowngradient
Wells (uo/1)
NO-50.800
NO-82.2
NO-29 . 7
NO-310
NO-10.1
NO-IO.I
NO-95.300
NO- 159
NO-76.4
NO-2 14
NO-374.000
NO-464
838-16.100
12.6-2.900
NO-2 . 4
NO-92.7
604-21.300.
NO- 7
NO-93.400
NO-17.3
NO-595
NO-838
Landrill/Off-Site
Plume Wells
(uo/1)
NO-8.400
NO-36.4
N6-S4.7
27.2-15.2
NO-2 . 4
NO-4.2
2.110-66,600
NO-28.6
NO-IS. 3
NO-43.5
79.1-83.200
NO-346
8.580-32.000
80.2-3.130
NO-I
NO-29
924-13.5000
NO
3.900-274.000
NO
NO-2 3. 7
NO- 1 40
(*) - Guidance value.
(MOJ - Note detected.
(-T - None currently available.
2449K .
-------
TABLE
CLAREHEONT POLYCHEHICAL SITE
AIR QUALITY SAMPLING (CHARCOAL) RESULTS FOR VOLATILE ORGANIC* (PPB)1
SAMPLE 1.0.
LOCATION
vinyl chloride
1.1-dichlorotthene
•ethylene chloride
acrylonltrile
chloroform
1,1,1-trlcMorotthane
carbon tetrachlorlde
benzene
toluene*
1,2-dtchloroethane
trlchlorofluoromethane
I.l,2-trlch1oro-1.2.2-
trifluoroethane
trlchloroethene
tetrachloroethene
ethylbenzene
m- ft p-xylene
o-xylene
cyclohexanone
propylbenzene
J - estimated
N - tentative Identification
R - rejected
U - non-detect due to presence In blank
222SK
CHS 154
Spill Area
'',',
1.2u
(Q ( |
<0. 1
0.7
<0.1
0.6u
1.8
3. OR
0.3NJ
2.1NJ
4.6NJ
0.5NJ
1.4NJ
0.7NJ
0.7NJ
0.1NJ
CMS 193
Treatment
Basins
<0. 1
<0. 1
3.7U
0.6
<0.l
0.8u
2.4
2.4R
0.3NJ
2.INJ
3.INJ
O.BNJ
2.3NJ
I.ONJ
0.5NJ
<0.1
CMS 158
Downwind
!!'.!
2.6u
0.6
<0.1
O.Su
1.7
2.4R
0.3NJ
2.1NJ
2.6NJ
0.4NJ
I.3NJ
0.6NJ
O.BNJ
<0.1
CHS 190
Upwind
<0 . 1
<0. 1
9.3u
0.7
0.1
0.7u
2.1
7.2R
0.3NJ
I.ONJ
2.7NJ
0.6NJ
1.8NJ
0.9NJ
0.9NJ
0.2NJ
CHS070
Malnten-
enance Room
-------
TABLE 5
CLAREMONT POLYCHEM1CAL SITE
ANALYTICAL RESULTS OF AIR SAMPLES - (TENAX) VOLATILE ORGAMICS
Concentration (ppb)">
SAMPLE ID.
LOCATION
l.l-dlcMarotthene
l.l-dtcfcloroetfcant
1.2- than*
1 ,2-dichlorop'oMne
cis-1,3 dlch1on>propene
trlchloroethfn*
dlbroMochloronethane
1.1.2-tricMoroethane
trans-1,3-dlch)oropropene
bronofom
2-Jiexanone
tetrachloroethent
1 , 1 ,2.2-telracM rooethene
chlorobenzene
styrene
U
Spill Area
BOL
BOL
BOL
0.0668J
BOL
0.1 16J
BOL
BDL
BOL
R
BOL
BOL
BDL
BOL
BOL
3.42J
BOL
BDL
0.374J
12
Treatnent
Basin*
BOL
BOL
BOL
BDL
BOL
0.112J
BDL
BDL
BOL
l.12Jb
BOL
BDL
BDL
BDL
BDL
1.76J
BOL
BOL
0.243J
D
Downwind
BOL
BDL
BOL
0.0338J
BOL
0.0941J
BDL
BDL
BDL
I.HJb
BDL
BDL
BDL
BDL
BDL
1.56J
BDL
BDL
O.I74J
14
Upwind
BDL
BOL
BOL
O.OS82J
BDL
0.117J
BDL
BDL
BDL
0.448Jb
BOL
BDL
BDL
BOL
BOL
1.54J
BDL
BOL
0.261J
16
Maintenance
ROOM
BOL
BDL
BOL
BOL
BDL
BDL
BDL
BDL
BOL
U
BOL
BOL
BDL
BOL
BOL
0.184J
BOL
BDL
0.117J
u
Maintenance
ROOM
BOl
BOL
BDL
0.0258J
BDL
BDL
BOL
BOL
BDL
0.16Ub
BDL
BDL
BOL
BDL
BDL
0.405J
BDL
BOL
0.295J
BDL - below detection 1t*it
J - estimated
u - non-detect due to presence in blank
R - rejected due to presence in blank
1 - values (including BOL) qualified as estimates
because sample holding time exceeded
2225K
-------
TABLE 6
CLAREMONT POLYCHEMICAL SITE
ANALYTICAL RESULTS FROH WIPE SAMPLES IN THE PROCESS BUILDING - ORGANIC (og/wlpe)'
Sample
Location
SNA
Behzoic Acid
Phenanthreie
Dt-n-Buty1phtha1«t«
Fluaranthene
IhexyDPhthalatt
Di-i-Octy. PhthaUl*
EEST.CIPE/PCJ
CONCENTRATION
CPS
WP09-1
Wall
NO
CPS
WP09-Z
Floor
2J
2J
2J
IJ
230
CPS
WPflfl-J
Wall
5J
22
CPS
WPOB-4
Floor
2400
CPS CPS
WP07-5 WP07r6
Wall Floor
NO
1400
1SOO
CPS CPS CPS
WP06-7 WP06-8 WPQ6-9
Hood Hood Floor
NO NO
270
CPS CCS CPS
WPQ6-10 WPQ5-11 WP05-12
Hood Wall Floor
V
420 100 3000
1 *,pproxi"Wtely 63 \fi wiped per sample
NO lot detected
J - tstirred concentration
-------
TABLE 6
(Cont'd.)
CLARCMONT POLYCHEMICAL SITE
ANALYTICAL RESULTS FROM WIPE SAMPLES IN THE PROCESS BUILDING - ORGANIC (ug/wipe)1
CONCENTRATION
Samp «
Locati.-n
CPS
wppi-ia
Wall
CPS
WP04-14
Floor
CPS
WPQ2rJ$
Wall
CPS
WP02-16
Wall
CPS
WP02-17
Floor
CPS
WP01-19
Wall
NO
CPS
WP01-20
Floor
CPS
WP03-21
Floor
CPS
Floor
CPS
WP02-23
Wall
B.NA,
Phenol
Benzoic Acid
Di-n-bijtylpht'nalat*
bii(2-lthy1hn«y1)Phtha1al«
Oi-n-Octyl Phthalat*
PESTIC^DE/PTB
17J
59J
110
5200J
90J
I10J
1300
6100
1300
43J
340
24J
4200
75J
6600
1300
72J
Undetected
63 in* wiped per sa«ple
NO Nut detected
J - Estimated concentration
-------
TABLE 6
CLAREHONT POLYCHEMICAL SITE
ANALYTICAL RESULTS FROM WIPE SAMPLES IN THE PROCESS BUILDING - INORGANIC (ug/wipe)
Sample
Locr.tlon
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
SeKnium
SlUer
Sodium
Thaclium
Vanuatu*
Zinc "
CPS
WPQ9-1
Wall
114.0
.98
79.0J
2500.0
28.6
4.2J
218.08
4.4J
271. OB
CPS
WP09-2
Floor
2850.0
24. 1J
4.5
549.0J
117.0
7340.0
172.0
1840.0
9200.0
1600.0
1600.0
95.2
1S.4J
1290.0
13.0
929.0
CPS
Wall
341.0
2380. OJ
406.0
4900.0
15.3
519.0
1010.0
99.6
293.08
15.8
474.08
0.6BB
816.0
CPS
WP8-4
Floor
8980. OJ
59.6
8.1
1180.0
0.688
590.0
18.300.0
566.0
11.1
1040.0
65,600.0
3030. OJ
4130. OJ
443. OJ
72.4
3080.0
38,400.0
28.4
38,400.0
CPS CPS
WP07-5 VP07-6
Wall Floor
1180.0J
35. BJ
7.0
7.38
5.0
4.6
1290
395.0
186. OJ
216.08
5.9J
6.78
656.08
17,700.0
CPS
WP06-7
Hood
224.0
19. 3J
11. OB
4.0
9.7
438.0
182.0
77.3
133.08
3. OB
0.62
248.08
3610.0
CPS
WP06-8
Hood
1080.0
39.6BJ
2.1J
3290.0
25.2
1760.0
980.0
121.0
764.08
11.3
384.08
719.0
CPS
WP06-9
Floor
42.200.0
59.4
8.5
747. OJ
0.74J
186.0
16.200.0
486.01
11.6
1960.0
135.000
1810.0
2970.0
709.0
0.68
91.3
2630.0
21.6
23,000.0
CPS
WP06-10
Hood
75.9
5.5B
1.5J
20.4
201.0
99.1
191.08
2.4B
203.08
1230.0
CPS
WPQ5-11
Wall
327.0
41.0
104. OJ
21.9
5130.0
534.0
253.0
611.0
2410.0
246. OB
8.2J
294.08
217.0
CPS
WPOS-12
Floor
3280.0
183.0
7.3
807. OJ
585.0
9380.0
5940.0
10.9
3710.0
67.400.0
29.900.0
1200.0
432.0
49.0
1340.0
1430.0
CPS
WP04-13
Wall
117.0
12. OJ
28.5BJ '
4.6
22.5
iar.0
194.0
112.0
188.0
4.5J
338. OB
CPS
WP04-14
Floor
5210.0
182.0
1.6B
4020. OJ
1070.0
4990.0
1570.0
6.68
1570.0
20.900.0
6100.0
1860.0
140.0
22. OJ
3690.0
8.08
937.0
??69K
-------
TABLE 6 (Cont'd)
CLAREMONT TOLYCHEM1CAL SITE
Sample
Location
Aluminum
Antimony
Arsenic
BariuM
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
CPS
WP02-15.
Wall
77.6
15. OJ
87.1
13.0
30.8
54.2
270.0
368. OJ
427.08
2.38
225.08
1
CPS
iJM/D ic
•^**y t ^ i o
Wall
51.8
10.2
45. 7 J
S.4
18.6
33.6
167.0
203.0
307. OB
2.08
0.55
4.6
202.08
ANALYTICAL RESULTS FROM WIPE SAMPLES
CPS
WP02-17
Floor
6380.0
114.0
4.3
1120. OJ
0.83B
397.0
13,000.0
1650.0
7.5B
6030.0
32.100.0
12.400.0
4030.0
242.0
1.11
23. 9 J
27,300.0
19.0
4420.0
IN I HE PROCESS BUILDING •
- INORGANIC
CONCENTRAJJON
CPS
WPQ1-19
Wall
294.0
71. U
3.1
3290.0
29.4
133.0
440.0
162.0
300.08
8.4J
294.08
149.000
107.0
CPS
WP01-20
Floor
1840.0
2.8J
86. 4 J
9.4
8970.0
123.0
154.0
4190.0
523.0
947.08
28.0
2560.0
3.28
138.0
CPS
WP03-21
Floor
1740.0
25. 7 J
13. 2J
339. OJ
82.2
4670.0
264.0
1100.0
17.900.0
1220.0
740. OB
92.7
8.08
905.08
5.98
1270.0
CPS
WP03-22
Floor
1590.0
28. U
4.0
275. OJ
87.3
4120.0
250.0
1140.0
15,200.0
1200.0
644.08
86.3
8.08
564.08
7.2B
1280.0
CPS
WP03-23
Wall
911.0
23. 7 J
2.3
147. OJ
5.6
5650.0
73.6
1500.0
1370.0
357.0
903.08
17.3
520. OB
3.4B
454.0
' Approximately 135 in2 wiped per sample.
8 - The concentration listed It below the analysis required detection limit but above the instrument detection limit.
J - Estimated concentration.
-------
Table 7
Summary of Indicator Chemicals in
Sar.pled Matrices at Claremont Polychemical Site
Antimony
Arsenic
Barium
Benzene
Benzoic Acid
Beryllium
Bi s (2-e thy IhexyDph thai ate
Butyl benzyl phthalate
Cadmium
Chlorobenzene
Chloroethane3
Chloroform
Chromium
Cobalt
Copper
1,2-Dichlorobcnzene(a/
4-Dichlorobenzene(a)
1-Dichloroethane
1-Dichloroethene
1,2-Dichloroethane
Diethylphthalate
Di-n-butylphthalate
Di-n-octyl-phthalate(a)
Ethylbenzene
Iron
Isophcrone
Lead
Manganese
Mercury
Nickel
PAHs - Naphthalene
- Benzo(a)pyrene
Pentachlorophenol
Pesticides - 4,4'-DDT
4,4'-DDD
1
1
c
o
c
0
0
0
c
o
0
0
0
o
o
0
o
0
0
0
o
o
c
0
o
o
o
o
o
0
c
0
0
Alpha-BKC
o Phenol
c Seier.ium
c Tetrachioroethene
o Thalium
o Toluene
b 7rans-l,2-Dichic roethene*
c Trichloroethcne
o Vanadium
o Zinc
X
X
BuiIding
Ryit 5.0_i.l
X X
X
X
V
X
X
X
X
X
X
X
X
X
•f
*«
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A
X
X
X
X
X
X
X
X
X
V
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
V
X Selected chemical of potential concern
— Net selected az a chemical of potential cToncern
(a) No Toxicity data
-------
Exposure Hediuit/
_ Sciriarjg _
I • PMjenLJ,*niLJhe
Air
Soli
Groundwater
2.
A. On-Slle
Air
Building
Soli
Groundwater
B. QfJbSitt
Air
Soil
Groundwater
Table 8
CLAREMONT POLYCHEMICAL SITE
SlimARY OF EXPOSURE PATHWAYS UNDER CURRENT AND FUTURE LAND USE
Potentially Exposed
_Pj)P.o. J.3 LUM
Residents, workers, students
Residents, workers, students
Residents, workers, students
Residents, construct Ion-workers
Workers InsIHe building
Residents, construction workers
Residents, construction workers
Residents, construction workers
Residents
Inhalation of Volatile*
Inhalation of Fugitive Oust
Incidental Ingestlon
Inhalation of Volatile!
Inhalation of dust
Inhalation of Fugitive Dust
Dernal contact
Ingestlon
Inhalation of Volatlles while
showering
Dermal contact while showering
Ingest ion
Inhalation of Volatlles
Inhalation of Fugitive Dust
Inhalation of Volatiles while
showering
Dermal contact while showering
Ingestlon
Residents, workers
Residents, workers
Residents
Residents
-------
Table 9
Toxicity Data for Non-Carcinogenic Effects
Dose Response Evaluation (a)
Chemical Name
Volatile*:
Benzene
Ch I orobenzene
Chloroform
1,1-Dichtoroethane
1,2-0ichtoro« thane
1,1'Dichloroethene
Ethytbenzene
Toluene
Tetrachloroethene
1,1.1-Trfchloroethane
Trichloroethene
Vinyl Chloride
Xylene*
Seni volatile*:
•enioic Acid
1 sophorone
Pent ach I orophenol
Phenol
8enzo(a)pyrene >
Naphthalene
HONCARC IMOGENS
Oral RfO
(ing/kg-day)
-
3.00E-02
1.00E-02
1.00E-01
-
9.00E-03
1.00E-01
3.00E-01
1.00E-02
9.00E-02
-
-
2.00E»00
*.00€»00
2.00E-01
3. 006-02
6.00E-01
-
4.00E-01
Bis(2-ethytheiyl)phtha(ate 2.006-02
Butyl benzyl phthalate
Oi -n-butylpftthalate
OiethytpMhalat*
Pesticides:
Alpha «HC
4.4'-DDT
Inorganics:
Ant iMony
Arsenic
•ariuM
•cry Him
Cadmiui
Chromiin (VI)
Copper (a)«
lead***
Xaogane**
Mercury
MiekcV
Seleniun
Th«Uitn
Vanadim
Zinc
2.00E-01
1.00E-01
8.00C-01
8.00E-W
5.00E-04
4.00E-04
1.00E-03
S. 006-02
S. 006-03
1E-03 (food)
SE-Ot (Mater)
S. 006 -03
3. 706-02
1.436 -04
2.00E-01
3.00E-04
2.00E-02
3.006-03
7.006-05
7.006-03
2.001-01
: Reference Doses
Inhalation RfO
(mg/kg-day)
.
5. 006-03
NO
1.006-01
-
NO
NO
1.006*00
HO
3.006-01
-
•
A. 006-01
NO
NO
NO
NO
.
NO
NO
NO
NO
NO
NO
NO
NO
- •
1.006-04
NO
NO
NO
NO
1.006-02
NO
3.006-04
NO
NO
1.006-03
NO
NO
NO
(•) Health effects Assessment Surmary Tables - Second and Third Quarters. USEPA. 1989.
/i (USEP*-
-------
Table 10
Claremont Polychemical Site _
Summary of Human Non-cancer Risk Estimates
Hazard Index for
Noncareinedenie Effects
Eioosur* Pathway
Average
Cai*
Kaximum
Plausible
Cast
Inhalation of air
Ingestion of soil
Dermal adsorption of soil
Inhalation of Fugitive Oust
Ingestion of ground*ater
0.8
0.15
0.01
15.2
3.2'/•>
Total 10 II*
Futuri Qn-Site Land Use Conditions
PCE
Pb
PC-
Sb. TL. ?CE
Dermal adsorption of ground»atfr — 0.01
Inhalation or uround«ater Volatile* 2.83 N/A
PC-
Total
Inhalation of resuspendsd building
dust
rutun 6ui IJinT Use
2:*
Barium, iron.
H[ Jbo./e \ |.id''«Jf •l».al risk or HI is
—15 'Jltd
-------
Table 11
Toxicity Data For Carcinogenic Effects
Dose Response Evaluation (a)
volatile*:
Benierw
Chlorobenzene
Chloroform
1,1-Oichlorotthifw
1,2-Dichloro«th«nt
1,1-Dichloroethene
Ethylbetutnt
Toluene
Tetrachloro»th«nt
1, 1.1 -Inch loroethane
Trichtorocthent
Vinyl Chloride
Seanvol •til**:
Benzoic Acid
Isophorone
Pemach 1 orophenol
Phenol
8enzo(a)pyrene (b)
Naphthalene
Cere i nog ens:
Or* I CPF
(mg/kg-day)'
2.90E-02
6.10E-03
9.10E-02
9.106-02
6.00E-01
™
5.10E-02
-
1.10E-02
2.30E«00
-
4.10E-03
-
•
1.15E-01
•
8is<2-ethylhexyl)phthalat* 1.40E-02
Butyl benzyl pri thai ate
Di-ri-butytphthalate
Oiethylphthal««
Pesticides :
Alpha BHC
4,4'-ODT
Inorganics:
Ant iseny
Arsenic
••ritM
Beryl I ium
Cadmium
Chromium (VI)
Copper
lead
Manganese
Mercury
nickel (c)
Sri mum
thai 1 iuai
VanadiuB
Zinc
HO
HO
HO
1 . 70E*00
3.40E-01
-
1.50E*00 (b)
•
«>
HO
MO
-
HO
-
-
HO
•
•
-
Cancer Potency
Weight of
•1 Evidence
A
12
•2
•2
C
•2
"
•2
A
-
C
0
•
•2
•
•2
C
D
0
•2
•2
•
A
•
•2
•
.
-
•2
•
•
•
•
•
-
•
Factors
Inhalation CPF
(i»9/k9-dayr-1
2.90E-02
8.10E-02
HO
9.10E-02
1.20E»00
3.30E-03
"
1.30E-02
2.9SE-01
^B..
.
HO
-
.
6.10E*00
•
MO
MO
NO
NO
1.70E-00
3.406-01
-
S.OOE*01
-
a.*OE*oo
6. 10E*00
«.10E*01
•
HO
•
-
1.70E*00
•
•
•
•
Weight of
Evidence
A
82
MO
82
C
82
82
A
.
.
C
0
.
82
.
82
.
0
0
82
82
.
A
.
82
81
A
-
82
•
-
A
•
-
-
-
C?A Weight of Evidence Claitifieations are as follows:
Croup A • Muwn Carcinogen. Sufficient evidence fro* epideaiologic studies to sipport a causal association between exposure
and cancer.
Croup II - Probable Hunan Carcinogen. United evidence of carcinogenic!ty in himans fron epidenioiogtcal studies.
Croup 12 - Probable Hunan Carcinogen. Sufficient evidence of carcinogenicity in animals. Inadequate evidence of
careirvogsrii-i- • in hir?r...
Croup C - Posiible Human Carcinogen. Limited evider:e of circinogenicity in animals. """
Group 0 - Hot Classified. Inadequate evidence of carcinogenicity in animals.
!. ' :'.c.--' . ~f-;- . . Astis-r-nt '- •—-r;- r-*ilc.- ' -•• ' " ' :. . ... .j;PA, "589.
(a:* Calculated froi the current drinking water standard of 1.3 nj/l assuming an ingest ion of 2.0 I/day for a 70 kg person.
(b) Integrated llsk Information System. 1987.
(c) The CPF represents the nickel subsulfide font of the chemical.
-------
Table 12
Claremont Polychemical Site
Summary of Cancer Risk Estimates
Excess Lifetime Cancgr Bisk
Exoosur" Pathway
Averagt
Case
flaxinuo)
Plausible Case
Predominant
Chemical s
Current Land Use Conditions
Inhalation of air
Inhalation of soil
Ingestion of Groundwatcr
1.81E-06
I.05E-09
4.23E-OS
1.38E-06
9.48E-08
Total 1.88E-06
Future Off-Sit? Land Use Conditions
1.40E-05
Total
fulur» On-$ite Land Us* Conditions
1.20E-05
5.0E-05
Inhalation of a
-------
Table 13. List of Applicable or Relevant and Appropriate Requirements (ARARs) for the Selected
Remedy.
SOILS
Regulatory Level
Federal
State
GROUNDWATER
Federal
State
OTHERS
Description
National Ambient Air Quality Standards for Hazardous Air
Pollutants (NAAQS)
40 CFR 52
RCRA - Land Disposal Restrictions (40 CFR 268)
RCRA - Standards Applicable to Transport of Hazardous
Waste (CFR 263.11, 263.20-21
and 263.30-31)
RCRA - Standards for Owners/Operators of Permitted
Hazardous Waste Facilities (40 CFR 264.10-264.18)
RCRA - Preparedness and Prevention (40 CFR 264.10-
264.18)
RCRA - Contingency Plan and Emergency Procedures (40
CFR 264.50-264.56)
DOT - Rules for Transportation of Hazardous Materials (49
CFR Parts 107, 171.1-172.558)
New York Hazardous Waste Manifest System Rules (6
NYCRR 372)
New York Hazardous Waste Treatment Storage and Disposal
Facility Permitting Requirements
(6 NYCRR 370 and 373)
SDWA Maximum Contaminant Levels (MCLs)
Groundwater Quality Regulations (6 NYCRR Part 703.5)
Drinking Water Standards (10 NYCRR Part 5)
OSHA - Safety and Health Standards (29 CFR 1926)
OSHA - Record Keeping, Reporting and Related Regulations
(29 CFR 1904)
-------
APPENDIX C. ADMINISTRATIVE RECORD INDEX
-------
89/27/9B Index Docuient Nuiber Order Page: 1
CLAREHONT POLYCHEHICAL Oocuients
Docuient Nuaber: CLR-001-8801 To 0151 Date: 07/01/90
Title: Draft Final Reaedial Investigation Report: Clareiont Polycheiical Site, Volute 1 of 6: Sections
1, 2 and 3
Type: PLAN
Condition: DRAFT
Author: Nivargikar, Rao: Ebasco Services
Recipient: none: US EPA
Docuient Nuiber: CLR-001-0152 To 0356 Date: 07/01/90
Title: Draft Final Reiedial Investigation Report Clareiont Polycheiical Site, Volute 2 of 6: Sections
4 and 5
Tyoe: PLAN
Condition: DRAFT
Author: none: Ebasco Services
Recipient: none: US EPA
DocLeer.t Nuabe-: CLR-aZi-Z357 To 0557 Date: 07/81/90
Title: Craft Final RBsedia! Investigation Report, Clarenont Polycheiical Site, Voluie 3 of 6: Sections
i, 7 and References
Type: PLAN
Condition: DRArT
fijthor: none: Ebasco Services
Recipient: none: US EPA
Docuaent Nuiber: CLR-001-055S To 0845 Date: 07/01/90
Title: Draft Final Reiedial Investigation Report, Clareiont Polycheiical Site, Voluie 4 of 6: Appendices
A-H
Type: PLAN
Condition: DRAFT
Author: none: Ebasco Services
Recipient: none: US EPA
-------
B9/27/9B Index Docuient Nueber Order Page: 2
CLAREHONT POLYCKEHICAL Docuients
Docuient Nuaber: CLR-8B1-8846 To 1889 Date: B7/B1/9B
Title: Draft final Reiedial Investigation Report, Clareiont Polycheiical Site, Volute 5 of 6: Appendices
I-L
Type: PLAN
Condition: DRAFT
Author: none: Ebasco Services
Recipient: none: US EPA
Docuient Nuiber: CLR-B81-1B98 To 1460 Date: B7/B1/9B
Title: Draft Final Reaediai Investigation Report, Claresont Polycheiical Site, Voluie 6 of 6: Chesical
Results Appendices
Type: PLAN
Condition: DRAFT
Author: none: Ebasco Services
Recipient: none: US EPA
Docuaer.t NaiDer: CLR-B81-146i To 1914 Date: 87/81/98
Titls: Draft rinal Feasibility Study Report - Clareiont Polyche»i:al Site
Type: PLAN
Condition: DF>."
Author: Nivarcitar, Rao: Ebasco Services
Recipient: none: US EPA
Docuient Nuiaber: CLR-881-1915 To 1929 Date: 88/81/98
Title: Superfund Proposed Plan - Clareiont Polycheiical Site
Type: PLAN
Author: none: US EPA
Recipient: none: none
-------
89/27/90 Index Document Nuaber Order Page: 3
CLARENONT POLYCHEHICAL Docuients
Docutent Nusber: CLR-BB1-193B To 1931 Date: 88/29/98
Title: (Letter advising of concurrence with proposed reaedial action alternatives for Clareiont Polycheaical
site)
Type: CORRESPONDENCE
Author: O'Toole, Michael J Jr: NY Dept of Environmental Conservation
Recipient: Casoe, Richard L: US EPA
Docuaent Nuaber: CLR-081-1932 To 1985 Date: 89/22/89
Title: Declaration for the Record of Decision and Decision Suaaary - Clareiont Polycheiical Site
Operable Unit II
Type: LE6AL DOCUMENT
Author: Hiisiynsfci, Hiliiaa J: US EPA
Re::oient: none: none
-------
APPENDIX D. NYSDEC LETTER OF CONCURRENCE
-------
SEP-25-1990 08=04 FROM NYS.ENUIR.CONSERUfiTI ON TO 6-55265?2i2ib466«
New York State Department of Environmental Conservation
SO Wolf Road, Albany, New York 12233*7010
Thomas C. Jortlno.
Conunte»ion«r
Mr. Richard L. Caspe, P.E.
Di rector
Emergency & Remedial Response Division
U.S. Environmental Protection Agency .oEP 2 4 1990
Region II
26 Federal Plaza
New York, NY 10278
Dear Mr. Caspe:
Re: Claremont Polychemical Site - ID. No. 130015
Old Bethpage, Nassau County, New York
The New York State Department of Environmental Conservation (NYSDEC) has
reviewed the draft Operable Unit One Declaration for the Record of Decision
(ROD) for the above-referenced site. The NYSDEC concurs with the selected
remedies which include:
1. Alternative SC-4, Contaminated Soils - Excavation of approximately
1600 cubic yards of contaminated soil, on-site Low Temperature Enhanced
Volatilization and on-site redeposition.
2. Alternative GW-3B, Groundwater - Extraction of 1.0 mgd of contaminated
groundwater, followed by treatment (metal precipitation, air stripping
and carbon adsorption) and reinjection of the treated water into the
aquifer.
3. Alternative BD-2 - Building decontamination and off-site treatment/
disposal of collected dust, asbestos insulation, and contaminated water
from the floor drains and condensers.
4. Alternative T-2, Underground Storage Tanks: Removal and Off-Site
Treatment/Disposal - This alternative includes excavation of overburden
soil, pumping of the tank contents, tank cleaning, removal of tanks and
appurtenant equipment, off-site disposal/treatment of tanks, equipment
and liquid waste, and backfilling with clean soil.
If you have any questions, please call Mr. Kama! Gupta, of my staff, at
(518) 457-3976.
Sincerely,
Edwirjn OTstrtTTvan
Deputy Commissioner
cc: C. Ramos, USEPA, Region II
R. Tramontane, NYSDOH
-------
APPENDIX E. RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
Claremont Polychemical sit*
Old Bethpage, Nassau County
New York
The U..S. Environmental Protection Agency (EPA) held a public
comment period from August 25, 1990 through September 25, 1990 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 (Site).
A public participation meeting was conducted by EPA on
September 5, 1990 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 for the interested parties to
present oral comments and questions to EPA.
This responsiveness summary provides a synopsis of citizen's
comments and concerns about the Site as raised during the public
comment period, and EPA's responses to those comments. All
comments summarized in this document were 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 Involvement and 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 Purina
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 responses to these comments.
IV. Appendices. This section includes a copy of the agenda
for the public meeting (Appendix A), Proposed Plan
(Appendix B), public meeting sign-in sheet (Appendix
C), and the overhead transparencies used at the public
meeting (Appendix D).
-------
Z. RESPONSIVENESS SUMMARY OVERVIEW
Site Background
The Claremont Polychemical Site is an abandoned production
facility located in central Long Island, in the community of Old
Bethpage, Town of Oyster Bay, Nassau County, New York. 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 Far-
mingdale, and Bethpage 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 approximately half a mile away on the west
side of the landfill. The closest public supply well is located
3,500 feet northwest of the Site.
The Site occupies approximately 9.5 acres on which a 35,000
square foot, one story, concrete building is located. Other
features include: treatment basins, aboveground tanks,
underground tanks, leaching basins, dry wells, and water supply
wells.
From 1968 until its closure in 1980, Claremont Polychemical
manufactured 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 (NCDOH) of 2,000 to 3,000
drums scattered throughout the Site, 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. NCDOH 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 by the property owners, in 1980, 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 degraded and no longer is 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. For the last four to five years two tenant
businesses have been operating at the Site.
The Claremont Polychemical Site was first proposed for inclusion
on the National Priorities List (NPL) in October 1984 and
received a final listing status in June 1986. 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. No response was received from Mr. Neitlich or from the
company. In March 1988 EPA obligated funds and started a
comprehensive RI/FS for the first operable unit.
A preliminary evaluation by EPA in July 1988 revealed the
presence of hazardous waste held in containers (e.g. drums) and
other holding units (treatment basins, aboveground tanks, and a
sump). In September 1988, EPA performed work consisting of the
overpacking and/or stabilization of deteriorated containers and
holding units. A second operable unit RI/FS (OU-II) dealing with
the ultimate disposal of the above mentioned hazardous wastes was
completed by EPA in July 1989. The Record of Decision for OU-II
was issued in September 1989. The selected remedy is currently
being implemented and consists of compatibility testing,
bulking/consolidation, and treatment/disposal of the wastes at
off-site, EPA-approved, treatment facilities.
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 to as operable unit one). Those
alternatives considered are detailed below:
Remedial Alternatives for Contaminated Soils (SC)
o SC-l No Further Action
o SC-3 Excavation/Off-Site Incineration/Backfill with Clean
Soil
o SC-4 Excavation/Low Temperature Enhanced Volatilization/On-
Site Redeposition
o SC-5 In-Situ Vacuum Extraction
Remedial Alternatives for Contaminated Groundwater (GW)
o GW-l No Further Action
o GW-2 Pumping/Air Stripping/Reinjection; Site Boundary (0.2
mgd)
o GW-3A Pumping/Air Stripping/Reinjection; Leading Edge of
Plume (1.9 mgd)
-------
o GW-3B Pumping/Air Stripping/Reinjaction; Site Boundary and
Downgradient (1.0 ingd)
o GW-5A Pumping/UV-Chemical Oxidation/Reinjaction; Leading Edge
of Plume (1.9 mgd)
o GW-5B Pumping/UV-chemical Oxidation/Reinjaction; Site
Boundary and Downgradient (1.0 mgd)
Remedial Alternatives for Building (BD)
o BD-1 No Further Action
o BD-2 Building Decontamination/Waste Treatment and Disposal
Remedial Alternatives for Underground Storage Tanks (T)
o T-l No Further Action
o T-2 Removal and Off-Site Disposal
EPA, with concurrence from the New York State Department of
Environmental Conservation, chose a remedy which addresses the
principal threats posed by the Site through a combination of
source control alternatives - treatment of contaminated soils
(SC-4) and tank removal and treatment (T-2), with active
restoration of the groundwater (GW-3B), and building
decontamination (BD-2). Based on the current information, these
alternatives provide the best protection of human health and the
environment.
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 (OBL), Liberty Industrial Finishing Site,
and the Nassau County Fire Service Academy. Several remedial
activities are currently being conducted at the landfill,
including extraction and treatment 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. Organized groups
include the Citizens for Pure Water in South Farmingdale.
The major concern expressed by the community is migration of
contaminants through groundwater. Local officials and the public
in general have focused 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'8 RESPONSES
Comments raised during the public comment period for the
Claremont Polychemical Site are summarized below.
COMMENT: Local officials inquired about whether or not EPA
foresees any problems reinjecting the volume of groundwater to be
treated as part of the groundwater remedy.
RESPONSE: EPA does not foresee any technical problems related to
the reinjection of the treated groundwater into the aquifer. Our
current hydrogeological model indicates that the aquifer should
be able to assimilate this volume of water (1.0 million gallons
per day). Construction and operation of the proposed groundwater
reinjection wells is technically feasible at the Site. Normal
potential problems such as clogging of the well screens due to
suspended matter will be taken into account in the facility
design.
COMMENT: A resident asked whether a risk assessment has been
prepared which calculates the overall risk to the population
exposed to contaminated groundwater, not only from the Claremont
Polychemical Site, but from the combination of all Superfund
sites in the vicinity.
RESPONSE: The risk assessment developed by EPA for the Claremont
site addresses potential risk to human health and the environment
from exposure to the Claremont Polychemical Site-related
contamination only. Calculation of a "global or regional" risk
figure would be difficult to accomplish since relationships
between sources and exposed population would need to be
determined for a variety of sources. However, due to the
proximity of Claremont Polychemical with the Old Bethpage
Landfill (OBL), and the potential for overlapping plumes, the
risk calculated by EPA for exposure to groundwater at Claremont
Polychemical may be influenced by contamination from the
Landfill. Remediation of the Claremont Polychemical contaminant
plume takes into consideration the potential impact of remedial
activities taking place at OBL (i.e., groundwater extraction and
treatment) in order to restore the aquifer to its best potential
use.
COMMENT: A resident asked whether the remedial action taken by
the company's owners in 1980 (i.e., excavation of soils and
placement on plastic liner), and the use of liners in general,
constitutes a good remedial action.
RESPONSE: It is difficult to assess the effectiveness of the
1980 action, since air and groundwater monitoring was not
conducted concurrently with the action. Although liners are
effective in reducing the potential for soil contaminants to
-------
leach into the groundvater, they do not control the spread of
leachate unless a collection system is in place. They also allow
for the volatilization of contaminants into the air phase without
treatment. Such releases are generally not acceptable to EPA or •
New York State. Generally speaking, liners without proper
controls are not standard EPA response techniques.
COMMENT: Concern was expressed about other sources of
groundwater contamination (e.g., the high number of Superfund
sites in the area), and how all these affect the groundwater
remediation.
RESPONSE: When EPA takes action at superfund sites, it takes
into account potential upgradient or off-site contributions to
the site groundwater contamination.
In other cases, EPA selected a remedy to address site
contamination which is followed by a second operable unit to
address remediation of an upgradient source, if one has been
identified. If a source has not been identified, EPA may conduct
a second operable unit investigation to assist in the
identification of an off-site source.
When EPA takes action at Superfund sites, it takes into account
potential upgradient or off-site contributions to the site
groundwater contamination. In the case of the Claremont
Polychemical Site, a great amount of communication and
coordination has taken place between EPA and the Town of Oyster
Bay (which is in charge of remedial activities at OBL). The
groundwater remedy selected at Claremont Polychemical foresees a
close coordination between the remedial activities taking place
at both the OBL and Claremont Polychemical Sites.
-------
APPENDIX A. PUBLIC MEETING AGENDA
-------
<° «•«»,
(SB
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I I
26 FEDERAL PLAZA
NEW YORK. NEW YORK 1O278
AGENDA
Public Meeting
Claremont Polychemical Superfund sit*
Old Bethpage Village Restoration
Old Bethpage, Mew York
September 5. 1990
7:00 P.M.
I. Welcome & Introduction
II. Overview of Superfund
III. Remedial Investigation/
Feasibility Study and
Preferred Alternative
VI. Questions and Answers
V. Closing
Cecilia Echols
Community Relations
Coordinator
U.S. EPA, Region 2
Douglas Garbarini
Chief, Eastern New York &
Caribbean Remedial Action
Section
U.S. EPA, Region 2
Carlos R. Ramos
Remedial Project Manager
Claremont Polychemical
Superfund Site
U.S. EPA, Region 2
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APPENDIX B. PROPOSED PLAN
-------
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Superfund Proposed Plan
Claremont Polychemical Site
Old Bethpage, Nassau County, New York
EPA
Region 2
August 1990
ANNOUNCEMENT OF PROPOSED PLAN
The Proposed Plan describes the remedial alternatives
considered for the Claremont Polychemical Superfund
site and identifies the preferred remedial alternative
wfth the rationale for this preference. The Proposed
Plan was developed by the U.S. Environmental
Protection Agency (EPA) with support from the New
York State Department of Environmental Conservation
(NYSDEC). EPA is issuing the Proposed Plan as part
of its public participation responsibilities under Section
117(a) of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of 1980. as
amended and Section 300.430(f) of the National
Contingency Plan (NCP). The alternatives summarized
here are described in the remedial investigation and
feasibility study (RI/FS) for this operable unit (referred
to as operable unit one in the RI/FS), which should be
consulted for a more detailed description of all the
alternatives.
This Proposed Plan is being distributed to solicit public
comments pertaining to all the remedial alternatives
evaluated, as well as the preferred alternative.
COMMUNITY ROLE IN SELECTION PROCESS
EPA and NYSDEC rely on public input to ensure that
the concerns of the community are considered in
selecting an effective remedy for each Superfund site.
EPA has set a public comment period which concludes
on September 25, 1990. The public comment period
includes a public meeting at which EPA will present the
RI/FS Report and the Proposed Plan, answer
questions, and accept both crci and wiiHen ccmrne; its.
A public meeting will be held in the auditorium of the
Old Bethpage Village Restoration, Round Swamp Road,
Old Bethpage, New York on September 5, 1990 at 7:00
p.m. to allow EPA to present the conclusions of the
.RI/FS. to further elaborate on the preferred remedial
||fterric..;ve, a;'.j to receive
Documentation of the final remedy selection will be
presented in the ROD after consideration of all the
public comments. Comments will be summarized in
the Responsiveness Summary Section of the Record of
Decision.
The administrative record file, which contains the
information upon which the selection of the
response action will be based, is available at the
following location:
Plainview-Old Bethpage
Public Library
999 Country Road
Plainview, New York
Tel. (516) 938-0077
Hours: Mon-Fri., 9:00 a.m to 9:00 p.m.
Sat., 9:30 a.m. to 5:30 p.m.
Sun., 1:00 p.m. to 9:00 p.m.
Dates to remember
MARK YOUR CALENDAR
August 25 to September 25, 1990
Public comment period on remedies
September 5, 1990
Public meeting at the Old Bethpage
Restoration Auditorium, Old Bethpage, New
York at 7:00 p.m.
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SHE BACKGROUND
The Claremont Polychemical site is an abandoned
production facility located in central Long Island, in the
community of Old Bethpage, Town of Oyster Bay,
Nassau County. New York. 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). The
Suffolk County line is approximately 800 feet east of
the site.
The Site occupies approximately 9.5 acres on which a
35,000 square foot, one story, concrete building is
located (see Figure 1). Other features include:
treatment basins, aboveground tanks, underground
tanks, leaching basins, dry wells, and water supply
wells.
From 1968 until its closure in 1980. Claremont Polych-
emical manufactured inks and pigments for plastics,
coated metallic flakes, and viny' stabilizers. The
principal wastes generated wer- 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 were scattered
throughout the Site; 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 mat
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, in 1980, 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 is 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. Additfonal wort; 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 Bankruptcy court
A preliminary evaluation by EPA on July 1988 revealed
the presence of hazardous waste held in containers
(e.g. drums) and other holding units (treatment basins,
aboveground tanks, and a sump). In September 1988,
EPA performed work consisting of the overpacking
and/or stabilization of deteriorated containers and
holding units. A second operable unit RI/FS (OU-II)
dealing with the ultimate disposal of the above
mentioned hazardous wastes was completed by EPA in
July 1989. The Record of Decision for OU-II was
issued on September 1989. The selected remedy is
currently being implemented and consists of
compatibility testing, bulking/consolidation, and
treatment/disposal of the wastes at off-site, EPA-
approved, treatment facilities.
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 the overall site
remediation (groundwater and soil) and is the focus of
this document. This RI/FS contains the detailed
information and data used in determining the nature
and extent of the problem, and the development of
remedial alternatives to address the problem.
As discussed above, the second operable unit deals
only with the wastes held in containers and holding
units. In September 1989, EPA decided to remove
these wastes and treat/dispose of the materials off-site.
This action, which includes the containers found inside
the building (e.g. drums) and the wastes contained
inside the holding units (e.g. treatment basins,
aboveground tanks), is currently ongoing.
The overall objective of the remediation is to reduce
the concentrations of contaminants to levels which are
protective of human health and the environment The
remedy selected will achieve this objective by:
o Soil Treatment. Treatment of the soil to remove
the mobile organic contamination will result in
the elimination of a long-term source of
contamination of the groundwater.
o Groundwater Treatment. Extraction and
treatment of the contaminated groundwater will
contain the migration of the plume and in time
will achieve Federal and State standards for the
volatile organic contaminants.
o Building Decontamination. Removal of all
hazardous materials from the building will
eliminate any potential risk to human hearth
and the environment, and will allow for
unrestricted use of the building in the future.
o Removal/Treatment of Underground Tanks.
Liquid Wastes, and Associated Soils.
Removal and treatment of these wastes will
result in the elimination of the threat to human
health and the environment from possible
contact with the wastes. Also will result in the
eradication of a long-term source of
groundwater contamination.
SUMMARY OF SfTE RISKS
A baseline risk assessment was developed as part of
the remedial investigation for Claremont Polychemical.
The risk assessment evaluates the potential impacts on
human health and the environment if the contamination
at the site is not remediated. This information is used
by EPA to make a determination as to whether
remediation of the site may be required.
Two basic scenarios were developed based on present
(industrial) and possible future (residential) land use at
the Site. Under both scenarios several pathways
(direct contact, inhalation and ingestion) were
evaluated for exposure to surface and subsurface soils,
air, resuspended building dust, and ground water used
for drinking and domestic purposes. The populations
evaluated included on-site residents; off-site residents
(including students and recreational users); and
workers. Two estimates were developed,
corresponding to the maximum concentration detected
or 'worst case scenario* and a representative exposure
or 'most reasonable case'. EPA considers risks in the
range of 10"4 to 10* to be acceptable. This risk range
can be interpreted to mean than an individual may
have a one in ten thousand to a one in a million
increased chance of developing cancer as result of
site-related exposure to a carcinogen over a 70-year
lifetime under the specific exposure conditions at the
Site.
Based on the Rl report some of the contaminants of
concern are: tetrachloroethene (PCE) and bis(2-
ethylhRxynphthalate (BEHP) in soil; 1,1.1-
trichloroethane, tetrachloroethene and bis(2-
ethylhexyOphthalate in groundwater; cadmium,
chromium and copper in the building; and 2-butanone.
toluene and bis(2-ethylhexyQphthalate in the
underground storage tanks.
rDYs bnselinc :n^=ngerment assessment indicates
^l the most significant--public health risk results from
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Maximum Concentration of Selected
Contaminants Delected in Soil. '
Groundwater. Building a/id Underground
Tank Content
CONCEN-
MATRIX COMPOUND TRAT1ON
SOIL
(ma/Kg)
GROUND
WATER
(ug/Kg)
BUILDING
(ug/wipe)
TANKS
(mg/Kg)
bi((2-«thylhexyl)
phthalole
tetrachloroelhen*
toad
1.1.1-
tiichloroethana
trichloroethen*
letrachloroelhene
•Ihylbenzen*
bis(2-ethylhexyl)
phthalate
chromium
bis(2-ethylhexyl)
phthalate
cadmium
chromium
copper
lead
2-bu:anon«
toluene
xylene
bis(2-ethylhexy<)
Dhthalate
270
26
98
100
260
1.300
160
50
159
70
313
1.103
24.600
7.974
92.000
2.600
3.600
23.000
the ingestion of grounbwater, inhalation of groundwater
volatiles (e.g. wh'i'.e showering), and the inhalation of
resuspended dust inside the building under the future
use scenario. Under the representative and worst-
case scenario, the lifetime excess cancer risk of
drinking the on-site groundwater are 1.36 x 10" and
4.53 x 10", respectively. This indicates that an
individual has a one in ten thousand and, a five in ten
thousand chance a' developing cancer as a result of
drinking this water. Similarly, the representative and
worst-case risk for people inhaling the on-site
groundwater volatiles are 4.36 x 10s and 1.45 x 10",
respectively. Under the representative-case scenario,
the potential excess cancer risk associated with
exposure to rssuspended building dust is 2.37 x 10",
and 5.09 x 103 under the worse-case scenario. For
ingestion of off-site groundwater the representative-
case risk is 9.59 x 10*; the worst-case risk is
3.20 x 10".
The risk assessment contains the conclusion that direct
exposure to site soils does not represent a significant
risk to human health and the environment. However,
they do pose a significant indirect risk by being a
continuous source of groundwater contamination.
Contaminants in excess of Federal and State standards
were detected in the site groundwater plume. EPA
policies and regulations allow remedial actions to be
taken whenever cross-media impacts result in the
exceedance of one or more Maximum Contaminant
Levels. Consequently, soil remediation is warranted to
remove this continuous source of contamination into
the groundwater and expedite compliance with Federal
and State groundwater standards.
Actual or threatened releases of hazardous substances
from this site, if not addressed by the preferred
alternative or one of the other active measures
considered, may present a current or potential threat to
the environment through the groundwater pathway.
SUMMARY OF REMEDIAL ALTERNATIVES
The remedial alternatives are organized according to
the media areas which they address: soil (SC),
groundwater (GW), building (BD) and underground
tanks (T). These alternatives were screened based on
implementability, effectiveness, and cost. The screening
resulted in remedial alternatives upon which a detailed
analysis was performed. Those alternatives considered
in detail are discussed below. Time to implement* is
defined as the period of time needed for the alternative
to be started (e.g. amount of time needed for the
construction of a treatment facility). It does include the
time required for remedial design activities which is
assumed to take 2 years.
SOILS
Remedial Alternatives for Contaminated Soils (SC)
o SC-1 No Further Action
o SC-3 Excavation/Off-sit e
'mcineration/Sackfiu with Clean Soil
o SC-4 Excavation/Low Temperature
Enhanced Volatilization/On-Site
Redeposition ; : : : ;;
o SC-5 In-Situ Vacuum Extraction
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Alternative SC-1: No Further Action
Capital Cost: none
O & M Cost: $34,909 per year
Present Worth Cost: $564,300
Time to Implement: 1 month
The No Action alternative provides the baseline case
for comparison -with other soil alternatives. Under this
alternative, the contaminated soil is left in place without
treatment. A long-term groundwater monitoring
program would be implemented to track the migration
of contaminants from the soil into the groundwater.
Existing monitoring wells would be used for monitoring.
Five year reviews would be performed to assess the
need for further actions.
Remedial investigation-related roll-off containers and
drums containing soils and drilling mud would have to
be transported off-site for treatment and disposal.
Alternative SC-3: Excavation/OfT-Site
Incineration/Backfill with Clean Soil
Capital Cost: $18,535,100
O & M Cost: none
Present Worth Cost: $18,535,100
Time to Implement: 3.5 years
i Site preparation for the remedial implementation would
include a parking area, equipment staging area and
stockpile area. Support facilities (e.g. offices) would
also be installed on the site. An estimated total of
6,240 cubic yards (cy) of soil would be excavated.
Excavation would be conducted under moistened
conditions by spraying water over the surface to
minimize fugitive dust and volatile contaminant
emissions. The soil would be stockpiled prior to
transportation to an off-site facility. The excavated soil
would be transported to an off-site, EPA-permitted
incineration facility for treatment and disposal. The
roll-off containers and drums containing soil can also
be re-packed into the same type of containers and
transported for off-site incineration along with the soil.
Clean soil would be used to backfill the excavated
area. Sits restoration would include the application of
topsoil and seeding.
Alternative SC-4: Excavatton/On-Siie Low Temperature
Enhanced Volatilization/OrhStte Redfeposftion
Capital Cost: $2,262,500
0 & M Cost: none
Present Worth Cost: $2,262,500
Time to Implement 3.5 years
ftSite preparation &nd sou excavation would be
performed as in Alternative SC-3. An estimated 6,240
cy of contaminated soil would be treated in a mobile
enhanced volatilization (low temperature thermal
extraction) unit brought on site. Low temperature
thermal extraction consists of a feed system, thermal
processor, afterburner, and scrubber. The excavated
contaminated soil is placed in the feed hopper with a
backhoe. The soil is then conveyed from the hopper
to the thermal processor. Hot air from an air heater is
injected into the thermal processors at a normal
operating temperature of 260°C (500°F) which is well
above the boiling points of most volatile organic
compounds (VOCs). The volatilized compounds and
moisture in the contaminated soil is then burned at
1090°C (2000°F) in an afterburner operated to ensure
complete destruction. A portion of the off-gas is
recirculated as combustion air to minimize fuel usage.
The off-gas is then treated at the scrubber for
paniculate removal and acid gas adsorption. The
off-gas leaves the system at a temperature of less than
93°C (200°F).
The volatilized contaminant-laden gas also can be
treated by an activated carbon adsorption unit instead
of an afterburner for PCE removal. A bag filter would
be used to remove particulates from the gas before it
enters the carbon adsorption unit. The treated soil
would be free of volatile organics and would be stored
for sampling and then used as backfill in the excavated
areas. Site restoration would be performed as in
Alternative SC-3. The roll-off containers and drums
containing Rl soil can also be treated with the soil.
Alternative SC-5: In-Situ Vacuum Extraction
Capital Cost: $385,600
O & M Cost: none
Present Worth Cost: $385,600
Time to Implement: 4 years
Site preparation would be performed as in Alternative
SC-3. However, the soil is left in place undisturbed,
therefore no excavation would be required. This
alternative involves the installation of vacuum extraction
wells over the contaminated soils. Each well would
have a maximum depth of 10 feet. The vacuum wells
would be connected v\t> a pipe system to a
skid-mounted high volume vacuum pump. The vacuum
would pull air through the contaminated soils, within a
'rad/us of approximately 20 feet from the wells,
depending on soil composition and volatility of the
contaminant. The air containing the stripped VOCs
would be fed through a condenser to recover the free
product and moisture, and then through an emissions
control system, i.e., a vapor phase carbon adsorption
system. The condense, prcc'uc.'. wouj;J be drummed
and transported to an off-site treatment and disposal
-------
facility (most likely to be an incinerator). The roll-offs
and drums containing soil can also be treated on-site
via this technology by Using a one-pipe system within
the drum connected to a vacuum pump. The treated
soils would be used on-site for backfilling and
regrading.
GROUNOWATER
Remedial Alternatives for Contaminated
Groundwater (GW)
o GW-1 No Further Action
o GW-2 Pumping/Air Stripping/Reinjection;
:: Southern Site Boundary (0.2 mgd)
o GW-3A Pumping/Air Stripping/Reinjection;
:: Leading Edge of Plume (1.9 mgd)
••'• o GW-3B Pumping/Air Stripping/Reinjection;
Southern Site Boundary and Downgradient
(1.0 mgd)
o GW-5A Pumping/UV-Chemical
Oxidation/Reinjection; Leading Edge of
Plume (1.9 mgd)
o GW-5B Pumping/UV-Chemical
Oxidation/Reinjection; Southern Site
Boundary and Oowngradient (1.0 mgd)
Alternative GW-1: No Further Action
Capital Cost: none
0 & M Cost: $28,400
Present Worth Cost: $464,400
Time to Implement: 1 year
This alternative includes the use of existing wells to
conduct a long-term groundwater sampling program
which would monitor the migration of contaminants of
concern in the aquifer. A total of ten wells, including
existing upgradient, on-site and downgradient welts,
would be utilized in order to sample the groundwater
from the shallow xo deeper portions of the aquifer and
to track contaminant migration off-site. Regular
five-year review's wo-jld be performed to assess the
need for additional remedial actions.
Anemaflve GW-2: Purapng/Prefrealment/Air
Stripping/Carbon AdsorpforVReinjeciion; Pumping at
the Southern Site Boundary (0.2 rogd)
Capital Cost: $214,800
0 & M Cost: $378,700
Present Worth Cost: $3,350,500
Time to Irrplsmp?': i -5 years
This alternative includes the installation of three
extraction wells downgradient of the site in order to
extract 0.2 million gallons per day (mgd) of
groundwater from the site contaminant plume. This
groundwater would be piped to the Old Bethpage
Landfill groundwater treatment system for treatment
and disposal. The Landfill groundwater treatment
system is currently under construction and scheduled
to be completed in 1991. The 0.2 mgd is the
maximum allowable input from the Claremont Site to
the Landfill pump and treatment system due to design
limitations of that system. The treated effluent would
be reinjected into the aquifer through a recharge basin
being constructed as part of the Landfill system. This
flow rate is below the modeled .maximum pumping rate
of 1.9 mgd estimated for removal and treatment of the
site contaminant plume. (The original estimate of the
volume of contaminated groundwater to be treated was
much less than the current estimate). In addition, the
landfill treatment system is only planned to operate for
10 years based upon the time estimated for
remediation to the completed for the Old Bethpage
plume. Long-term monitoring using the new extraction
and existing wells would be performed for 30 years in
order to monitor any continued migration of remaining
contamination in the groundwater, both during and
after the operation of the landfill treatment system.
AJtematfve GW-3A: Pumping/Pretreatment/Air
Stripping/Carbon Adsorption/Reinjection; Pumping at
the Leading Edge of the Plume (1.9 mgd)
Capital Cost: $4,044,700
O & M Cost: $1,622,900
Present Worth Cost: $28,978,000
Time to Implement: 3 years
In this alternative, three extraction wells would be
installed downgradient of the site on the Bethpage
State Park property in order to capture the entire site
contaminant plume. Approximately 1.9 mgd would be
pumped to an on-site treatment facility. The treated
groundwater would be pumped to a discharge system
for reinjection to the aquifer via three reinjection wells.
The siting of the extraction wells would be completed
during the design.phase based on technical criteria
The groundwater treatment facility would consist of two
major processes: pretreatment to remove metals (iron,
manganese, arsenic, and thallium) and air strippers
followed by a carbon adsorption system to remove
volatile and semivolatile organics. The pretreatment
system is designed to effectively reduce the metal
concentrations in the groundwater below the Federal
and New York State Groundwater Standards. This
pretreatment system would consist ci - .nelais
precipitation system and'dual media pressure filter.
-------
The resulting sludge would require off-site treatment
and disposal.
Two air strippers in series followed by liquid phase
carbon adsorption would be used to lower the levels of
organic contamination below the state requirement for
groundwater standards. Approximately 95 to 99
percent of the volatile organics would be removed by
air stripping. The stripped groundwater would be
pumped to a two-stage liquid phase carbon adsorber
for removal of the remaining volatiles and BEHP, and
phenol. The volatile organic emissions from the air
stripping would be adsorbed on a vapor phase
activated carbon system in order to meet air quality
standards. Once the vapor phase and liquid phase
carbon is exhausted, it would be removed for off-site
regeneration or incineration, thus destroying all organic
contaminants. Two treatment trains (parallel systems
for treating the groundwater} rated at 660 gallons per
minute (gpm) each would be required.
Environmental monitoring would be required during the
life of the treatment plant operation (i.e., 30 years). Air
emissions would be monitored to confirm compliance
of the air discharge limit. Groundwater samples would
be taken every six months to monitor groundwater
contamination migration and effectiveness of
remediation. Under this alternative it is estimated to
take 62 years to achieve remediation of the
groundwater plume
Alternative GW-3B: Pumping/Pretreatment/Air
Stripping/Carbon Adsorption/Reinjection; Pumping at
the Southern Site Boundary and Downgradient (1.0
mgd)
Capital Cost: $4,936,000
0 & M Cost: $1,100,400 (first ten years)
$701,900 (next six years)
Present Worth Cost. $15,620,400
Time to Implement 3 years
in this Alternative, two extraction wells would be
installed slightly downgracltent of the southern
boundary ol me ste to capture the most contaminated
grounctwater. Two additional extraction wells would be
located downgradient from the site to capture the off-
site (diluted) migrating plume. Groundwater would be
pumped at a rate of 1 mgd and_traat»d on-site as in
Alternative GW-3A. In ihfs alternative four treatment
trains rated at 175 gpm would be used. Treated
groundwater would be reinjected into the aquifer.
This alternative would be implemented m two phases.
During the first phase extraction wells wca/d be
.installed at the southern bound-: •/ requiring two
Itreatmetit trains to treat the concentrated groundwater
plume. During the second phase the diluted
groundwater plume would be extracted, requiring the
installation of two additional treatment trains. In
between these phases (approximately 1-2 years),
critical information would be developed concerning the
impact of neighboring pump and treatment systems
(e.g. Old Bethpage Landfill) on the Claremont
Polychemical plume. Additional sampling would be
conducted to further delineate the extent of the
Claremont plume. Implementing this remedy in two
phases would provide increased overall efficiency and
flexibility. This optimized extraction and treatment
system design would be better able to address the
remediation of the Claremont site plume. It is
estimated that 16 years of pumping and treatment
would be required to complete the groundwater
remediation.
Alternative GW-5A: Pumping/Pretreatment/UV-Chemical
OxJdation/Reinjection; Pumping at the Leading Edge of
the Plume (1.9 mgd)
Capital Cost: $4,088,900
0 & M Cost: $108,000
Present Worth Cost: $21,121,100
Time to Implement: 3 years
This remedial alternative is similar to Alternative GW-3A
except that a chemical oxidation process rather than air
stripping/adsorption process would be used to remove
the volatile and semivolatile organics in the
groundwater. An ultraviolet light-hydrogen peroxide
oxidation system is selected as the representative
process to treat the contaminated groundwater. This
oxidation system would employ a combination of
hydrogen peroxide (H,Oj) and ultraviolet (UV) light to
chemically oxidize the organic contaminants in the
groundwater to carbon dioxide, water and chlorides.
Multiple units would be required. The treated
groundwater would have organic concentrations below
State and Federal standards.
Alternative GW-5B: Pumping/Pretreatment/UV-ChemicaJ
Oxidaijon/Retnjection; Pumping at the Southern Site
Boundary and Downgradient (1.0 mgd)
Capital Cost: $4,069,800
O & M Cost: $1,008,600 (first ten years)
656,000 (next six years)
Present Worth Cost $13,902,300
Time to Implement: 3 years
Groundwater extraction, pretreatment, and reinjection
would be accomplished as in Alternative GW-3B. The
UV-H202 system would, operate as in Alternative GW-5A
except that smaller tr?.-tment units ryculd be used.
-------
BUILDING
Alternative T-1: No Further Action
Remedial Alternatives for Building (BD)
. o BD-1 No Further Action
o BD-2 Building Decontamination/Waste
Treatment and Disposal
Alternative BD-1: No Further Action
Capital Cost: $8,800
O & M Cost: $2,100 per year
Present Worth Cost: $41,100
Time to Implement: 1 month
The No Action alternative provides the baseline against
which other alternatives can be compared. It would
result in leaving the contaminated dust, asbestos
insulation, and contaminated water in floor drains and
condensers intact in the building. The only additional
security measure implemented to completely seal the
building would be waterproofing of the building ceiling.
A long-term maintenance program, including site
inspections, would be implemented in order to ensure
that the building is completely sealed and is not
accessible to the public in the future.
Alternative BD-2: Building Decontamination
Capital Cost: $186,200
0 & M Cost: none
Present Worth Cost: $186,200
Time to Implement: 1 month
The inside contaminated surfaces of the building (i.e.,
walls, floors, and hoods) would be decontaminated
using dusting, vacuuming and wiping procedures. In
addition three dust collectors on the roof would be
emptied. The collected tfjsl wou/d be transported to
an off-site treatment aid tfsposaf facility. The
contaminated water in the floor drains and condensers
also would be removed and disposed of off-site.
UNDERGROUND STORAGE TANKS
Remedial AftemaiNes for Underground
Tanks (T)
o T-1 No Further Action
o T-2 Removal and Off-Site Disposal
Capital Cost: $2,600
O & M Cost: $2,200 per year
Present Worth Cost: $64,300
Time to Implement: 4 months
Under this alternative the underground tanks and
contents would be left in place. The large amounts of
hazardous materials contained in the tanks would
continue to constitute a potential source of soil and
groundwater contamination. A monitoring program
using the existing monitoring wells would be
established to detect the movement of these
compounds into the groundwater.
Alternative T-2 Removal and Off-Site
Treatment/Disposal
Capital Cost: $336,300
O & M Cost: none
Present Worth Cost: $336,300
Time to Implement: 4 months
This alternative entails excavation of overburden soils,
pumping of tank contents, tank cleaning, removal of
tanks and appurtenant equipment, off-site
disposal/treatment of tanks, equipment and liquid
waste, and backfilling with clean soil.
The underground tanks and appurtenant piping would
be drained and cleaned of any residual sludge. Tanks
would be hoisted and subsequently loaded on trucks
and hauled for off-site disposal. Other components of
the tank farm, such as pumps, concrete pads, and the
pumphouse, would be demolished and transported off-
site for disposal. At the disposal facility, the steel
tanks would be retested for hazardous waste contents.
Nonhazardous tanks would either be sold for scrap or
landfilied, depending on the extent to which they can
be decontaminated. Hazardous tanks and tank
contents would be disposed of at an off-site EPA-
approved hazardous waste treatment and disposal
facility.
Highly contaminated soils discovered during tank
excavation would be stockpiled in roll-off containers
and subsequently transported to an off-site EPA-
. licensed treatment and disposal facility. Sampling of
the soils underlying the tank farm would be conducted
as part of this alternative to further delineate the nature
and extent of soil contamination within this area and to
assess effectiveness of the remedy.
-------
ALUAT1ON OF THE REMEDIAL ALTERNATIVES
The preferred alternative* for the remediation of the site
combines source control alternatives with active
restoration of the groundwater. Alternative SC-4,
excavation of the contaminated soils, on-srte low
temperature thermal treatment, and on-site redeposition
is the preferred alternative to clean up the soils. The
preferred alternative for remediation of the groundwater
contamination is alternative GW-3B, extraction of the
groundwater at the site perimeter and downgradient,
followed by treatment (metal precipitation, air stripping
and carbon adsorption) and reinjection of the treated
water into the aquifer. Alternative BD-2 and T-2 are the
preferred alternatives for the building and underground
tank areas. Alternative BD-2 entails removal of
contaminated dust from the building by vacuuming and
wiping, and removal of the liquid wastes from drains
and condensers. Under alternative T-2, the
underground storage tanks, tank contents, and the soil
around it would be excavated and disposed of at an
off-site treatment facility.
Based on current information, this combination of
alternatives provides the best balance among the nine
criteria that EPA uses to evaluate alternatives and to
Censure that all important considerations are factored
into remedy selection decisions. The Analysis section
profiles the performance of the preferred alternative
against the nine criteria, noting how it compares to
other options under consideration.
The evaluation criteria is noted below and explained
below.
o Overall protection of human health and the
environment addresses whether or not a
remedy provides adequate protection and
describes how risks posed through each
exposure pathway (based on a reasonable
maximum exposure scenario) are eliminated,
reduced, or connoted through treatment,
engineering controls, or institutional controls.
o . Compliance with applicable or relevant and
appropriate requirements (ARAR's) addresses
whether or not a remedy would meet all of the
applicable or relevant and appropriate
requirements ol other Federal and State
environmental statutes and requirements or
provide grounds for invoking a waiver.
o Long-term effectiveness and permanence refers
to the ability of a remedy to maintain reliable
protection of human health and the
environment over time, once cleanup goals
have been met It also addresses the
magnitude and effectiveness of the measures
that may be required to manage the risk
posed by treatment residuals and/or untreated
wastes.
o Reduction of toxicitv, mobility, or volume
through treatment is the anticipated
performance of the treatment technologies,
with respect to these parameters, a remedy
may employ.
o Short-term effectiveness addresses the period
of time needed to achieve protection and any
adverse impacts on human health and the
environment that may be posed during the
construction and implementation period until
cleanup goals are achieved.
o Implementabilitv is the technical and
administrative feasibility of a remedy, including
the availability of materials and services
needed to implement a particular option.
o Cost includes estimated capital and operation
and maintenance costs, and net present
worth costs.
o State acceptance indicates whether, based on
its review of the RI/FS and Proposed Plan, the
State concurs with, opposes, or has no
comment on the selected remedy at the
present time.
o Community acceptance will be assessed in
the Record of Decision (ROD) and refers to
the public's general response to the alterna-
tives described in the Proposed Plan and the
RI/FS reports.
ANALYSIS
Comparison Among Sofl (SC) Alternatives
The following discussion compares the relative
performance of each soil alternative using the specific
evaluation criteria listed previously.
o Overall Protection of Human Health and the
. Environment
Alternative SC-1 does not meet the remedial objectives,
thus it is not protective of human health and the
environment. As a result of this alternative, the
groundwater would continue to be contaminated by the
soil source for some unknown period. Alternatives
SC-3, SC-4 and to some extent SG-5 would meet the
remedial objective of .protecting the groundwater from
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10
the soil source by achieving the cleanup level in soils.
Therefore, alternatives SC-3, SC-4 and SC-5 (to a
lesser extent) are protective of hunan hearth and the
environment
o Compliance with ARARs
All technologies proposed for use in Alternative SC-3
through SC-5 would be designed and implemented to
. satisfy all ARARs. Federal and State regulations
dealing with the handling and transportation of
hazardous wastes to an off-site treatment facility would
be followed. The off-site treatment facility would be
fully EPA-approved. RCRA wastes would be treated
using specific technologies or specific treatment levels,
as appropriate, to comply with land disposal
restrictions.
o Long-Term Effectiveness and Permanence
Afternatfve SC-1 would only monitor the migration of
the contaminants and does not provide treatment or
containment. Therefore, it does not provide effective or
permanent long-term protection of groundwater at the
site.
Alternatives SC-3, SC-4 and SC-5 are similar in their
ability to mitigate the risks through the removal and
treatment of site contaminants to meet the required
cleanup levels. Alternatives SC-3 and SC-4 provide a
high degree of effectiveness since they can effectively
remove the contaminants from the soil. Although
Alternative SC-5 is intended to have a similar ability to
mitigate soil contamination, due to the technical
limitations of in-situ process, SC-5 may not ensure
removal of contaminants to the cleanup level.
O Reduction in Toxicity, Mobility, or Volume
Alternative SC-1 would provide a very slow and gradual
reduction in toxicity through rainfall percolation, ft
would provide no reduction in contaminant mobility.
Alternatives SC-3, SC-4, and SC-5 again are similar, in
that each would result in significant reductions in the
toxicity, mobility, and volume of the treated material. .
Material toxicity would be reduced by thermal
destruction of contaminants in Alternatives SC-3 and
SC-4 and by off-site treatment of the condensed
organic product in SC-5. Alternative SC-3 would
provide the greatest degree of reduction in toxicity of
the contaminants followed by SC-4 and SC-5.
o Short-Term Effectiveness
The implementation of Alternative SC-1 would not result
in additional risk to the community during
implementation. Alternatives SC-3, SC-4, and SC-5
include activities such as contaminated soil excavation
and off-site transport or on-site treatment that could
potentially expose residents to volatilized contaminants
and contaminated dust Engineering controls and
other measures (e.g. restricting access to the site to
authorized personnel only) would effectively eliminate
any impact these activities would have on nearby
residents. Alternative SC-5 includes in-situ treatment of
contaminated soils, so exposure risks to residents from
excavation is much less of a concern for this alternative
than SC-3 and SC-4. Under alternatives SC-4 and
SC-5, proper air emission control units would be
installed to minimize the potential for public health
exposures because of low-level emissions from the
on-site treatment units.
Alternative SC-1 would result in a lower overall risk to
workers than other alternatives since subsurface soil is
not disturbed. Alternatives SC-4 and SC-5 provide
treatment on-site, thereby reducing potential risk to
residents along transportation routes. Alternatives SC-
3, SC-4, and SC-5 would present a potential for worker
exposure to volatilized contaminants during waste
excavation and/or handling. To minimize and/or
prevent such exposures, use of personal protection
equipment would be necessary.
SC-1 would be implemented in approximately one
month. Alternatives SC-3, SC-4 and SC-5 would be
implemented in about 3.5, 3.5 and 4 years,
respectively.
o Implementabilitv
Components of Alternatives SC-1, SC-3, SC-4 and SC-5
would utilize relatively common construction equipment
and materials. Little construction difficulty would be
encountered with any of the alternatives. However,
Alternative SC-1 would be the easiest to implement.
The technologies proposed for use in the alternatives
are proven and reliable in achieving the specified
process efficiencies and performance goals. Low
temperature thermal enhanced volatilization and in-situ
vacuum extraction have been successfully tested at
other Superfund sites. However, there is a greater
degree of uncertainty regarding the achieving of
cleanup levels using in-situ vacuum extraction since
this technology has only been performed on a limited
full-scale basis at similar contaminant concentration
levels.
The tntqi nretjqnt worth costs for the alternatives
evaluated ranged from $385,600 (in-situ vacuum
-------
11
faction) to $18,535.100 (off-site treatment and
'disposal). Present worth considers a 5% discount rate.
and a 30-year operational period in the case of OC-1.
All other source control alternatives would not require
any operation and maintenance cost. Therefore,
present worth for these alternatives (SC-3, SC-4 and
SC-5) would be the same as the capital cost SC-4
provides the same protection as alternative SC-3 at a
fraction of the cost (52,262,500 versus $18,535,100).
Although alternative SC-5 is significantly less expensive
than SC-3 and SC-4, it may not provide the same level
of protection.
o State Acceptance
MYSDEC concurs with the preferred alternative
selected.
Comparison of the Groundwater (GW) Alternatives
The following section compares the relative
performance of each groundwater alternative.
o Overall Protection of Human Health and the
Environment
The no-action alternative would not protect human
health and the environment. Existing contamination
would continue to degrade the aquifer and migrate
off-site.
Alternative GW-2 would not ensure protection of the
health of future users of the aquifer nor would it
improve the overall quality of the aquifer or prevent the
continued migration of contamination.
Each of the alternatives GW-3A. GW-3B, GW-5A and
GW-5B would be significantly more protective than GW-
1 or GW-2 since they would reduce the toxicity,
mobility, and volume of contaminants in the aquifers.
Each treatment alternative considered would equally
protect human health and the environment however,
the amount of time required to achieve the ARARs
varies greatly among alternatives.
o Compliance with ARARs
Alternatives GVV-1 and GW-2 would result in
contaminant concentrations remaining above ARARs
(tor drinking water or protection of the groundwater
resources) for a long period of time (100 years).
Alternatives GW-3A, GW-3B. GW-5A and GW-5B would
be designed to achieve all drinking water standards as
well as those required for groundwater protection in the
r^ated water stream which is to be reinjected. Each of
these alternatives would be capable of providing the
required contaminant removal levels. Because
experience with UV-chemical systems is limited, its
effectiveness is slightly less certain but considered
achievable. Each of the alternatives would comply with
air emission standards as well as regulations for the
handling and disposal of the generated wastes (e.g.
spent carbon).
o Long-Term Effectiveness and Permanence
Alternative GW-1 does not provide treatment but would
attempt to restrict usage of contaminated groundwater.
Alternative GW-2 provides short-term treatment, but
would not restore the contaminated aquifer for its best
beneficial future use.
Alternatives GW-3A, GW-3B, GW-5A, and GW-5B all
reduce the potential risks associated with groundwater
ingestion by extracting, treating, and recharging the
treated groundwater to remove contaminants from the
aquifer. The time required to achieve these risk
reductions depends on the effective extraction rates
from the aquifer and limitations on extraction system
placement due to the large area on the contaminant
plume. Long-term effectiveness of each system is
dependent on monitoring and maintenance of the
treatment system.
Alternatives GW-1 and GW-2 would take approximately
100 years to achieve the remedial action objectives.
Alternatives GW-3A and 5A would theoretically achieve
the remedial action objectives in 62 years, whereas
GW-3B and SB would achieve the remedial action
objectives in approximately 16 years.
Proper air pollution control measures would be
established under alternatives GW-3A and GW-3B to
offset potential risks from the air stripper(s), while no
pollution control measures are deemed necessary for
alternatives GW-5B and 5A. Alternatives GW-3A and
GW-3B require the disposal of more spent carbon than
GW-5A and GW-5B since vapor phase carbon
adsorption is used.
o Reduction in Toxicitv. Mobility, or Volume
Alternative GW-1 would very slowly and gradually
reduce the toxicity of contaminants through dilution.
Alternative GW-2 would reduce the toxicity and volume
of contaminants more rapidly than GW-1. Neither
Alternative GW-1 nor GW-2 would permanently reduce
the mobility of the contaminants. For alternative GW-2,
the off-site portion of the contaminated groundwater
plume would continue to migrate downgradient and
reduction of toxicity, mobility and volume would be
achieved only by rv:rai ?tt?nuat:c?n.
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12
Alternatives GW-3A. GW-3B, GW-5A and GW-5B would
reduce the toxicity, mobility, and volume.of
contaminants in the aquifers to a greater extent than
GW-1 and GW-2. Alternatives GW-3B and SB would
reduce the toxicity, mobility, and volume to a greater
extent and at a much faster rate than the other
alternatives. Alternatives GW-3A and GW-3B would use
air stripping and carbon adsorption to remove the
contaminants, while GW-5A and GW-5B would oxidize
most of the organic compounds.
o Short-Term Effectiveness
Implementation of Alternative GW-1 would result in no
additional risk to the community during remedial
activities. Alternative GW-2 could present additional
risks to the community resulting from the installation of
the extraction wells and pipelines for transportation of
contaminated groundwater. Alternatives GW-3A, 3B,
and GW-5A and 5B include excavation activities,
installation of the collection and reinjection system, and
construction of the treatment plant which could result
in potentially exposing residents to volatilized
contaminants and contaminated dust. The treatment
plant would be constructed on-site. Proper
engineering controls would ensure that the impact of
such activities would be insignificant. All alternatives
except Alternative GW-1 and GW-2 would provide a
process residual requiring proper handling and
disposal
Alternative GW-1 would result in no additional risk to
workers, and GW-2 would result in a lower overall
worker risk than other alternatives because of the
limited soil disturbance activities. Personal protection
equipment would be used under alternatives GW-3A,
GW-3B, GW-5A and GW-5B to minimize the worker's
potential exposure to volatilized contaminants during
installation of the collection, treatment, and recharge
systems.
o tmptementabnitv
Alternative GW-1 would be easily implemented.
Alternative GW-2 would require institutional
management to maintain and operate the pumping
system and to coordinate with the Landfill treatment
system. Alternatives GW-3A, GW-3B, GW-5A and
GW-5B would utilize relatively common construction
equipment and materials. Little construction difficulty
would occur with any of the alternatives.
The air stripping and carbon adsorption technologies
proposed for use in Alternatives GW-3A and GW-3B
are proven and reliable in achieving specified process
efficiencies an* performance goals. While there has
been limited experience with UV-chemical oxidation, it
has been successful in several groundwater treatment
facilities.
All proposed technologies are readily available from a
number of sources, with the exception of UV-chemical
oxidation. It is expected that additional UV-chemical
equipment manufacturers would be available once this
technology becomes more mature.
Alternatives GW-3A, GW-3B, GW-5A, and GW-5B would
require institutional management of the operation and
maintenance of the treated groundwater reinjection
system. Siting the treatment facility would not present
any problems as there is enough space available on-
site. Associated off-site facilities (e.g. piping, pumps,
extraction wells and reinjection wells) would be
potentially more complex to locate as both technical
and land use factors would be considered.
Off-site disposal facilities are available for the disposal
of the pretreatment sludge and spent carbon
generated from Alternatives GW-3A, GW-3B, GW-5A
and GW-5B.
The present worth costs of all GW alternatives ranged
from $464,400 (GW-1) to $28,987,000 (GW-3A).
Alternative GW-1 would be least expensive followed by
GW-2. GW-5B, GW-3B. GW-5A and GW-3A. Of the
alternatives providing complete remediation of the
groundwater contamination, Alternative GW-3B provides
the lowest present worth cost, $15,620,400.
o State Acceptance
NYSDEC concurs with the preferred alternative
selected.
Comparison of Building Alternatives (BO)
Only two building alternatives: No-Action and Building
Decontamination were evaluated.
o Overall Protection of Human Health and the
Environment
In Alternative BD-1, hazardous material is left in the
building. Human health and the environment remain
protected only as long as building security can be
effectively enforced and building integrity maintained.
Alternative BD-2 removes all hazardous material from
the building so it is fully protective of human health
and the environment. In addition, Alternative BD-2
allows for future reuse of the building.
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13
o Compliance with ARARs
FAltemative BD-1 would not contravene any ARARs
since no action would be taken. Alternative BD-2
would comply with the ARARs relevant to the transport
of the wastes to an off-site facility. The off-site
treatment facility would be fully EPA-permitted and
therefore meet applicable regulations.
o Lono-Term Effectiveness and Permanence
Alternative BD-1 would not alter conditions within the
building; hazardous materials would remain in the
building. Public protection would rely on maintaining
building security which may be difficult to enforce. The
building could not be used for any purpose.
Alternative BD-2 removes all hazardous materials from
the building for off-site treatment and disposal so that
long-term exposure risks from the building would be
eliminated. Painting and sealing the building
(alternative BD-2) would provide additional protection
and would allow for unrestricted use of the building in
the future.
O Reduction in Toxicitv, Mobility or Volume
Alternative BD-1 provides no reduction in toxicity or
volume of contaminants; mobility is not an issue since
tthe building is self-contained. Alternative BD-2
(provides for complete reduction in toxicity and volume
since all contaminated material is removed from the
building.
o Short-term Effectiveness
Implementation of BD-1 should result in no additional
risks to the community or the environment as long as
building security and integrity can be maintained.
Alternative BD-2 involves removal and transport of the
contaminants from the building so there are some
minimal public exposure risks as well as environmental
impact from potential waste spills resulting from a
possible transport accidents during remedial activities.
Worker exposure risks would be minimized through the
use of personal protection equipment. Long-term
maintenance would continue indefinitely for Alternative
BD-1. Building decontamination, Alternative BD-2,
could be accomplished in approximately 3 months.
o . Implementabiliry
Both alternatives are readily implementable; neither
involves any major construction activities. Methods and
services for building decontamination are technically
feasible and readily available. Alternative BD-1 would
require institutional manager^nt i.e., a long-term
wilding maintenance program, whereas Alternative
BD-2 does not require any long-term management.
o
The present worth costs for alternatives BD-1 and BD-2
are $41,100 and $186,200, respectively.
o State Acceptance
NYSDEC concurs with the preferred alternative
selected.
Comparison of the Underground Tank CD Alternatives
o Overall Protection of Human Health and the
Environment
Alternative T-1 would not protect human health and the
environment as the threat of soil and groundwater
contamination would not be reduced. The excavation
and removal of contaminated tanks and their contents
from the site (T-2) would significantly .reduce the
potential human health and environmental risks
associated with potential leaking of contaminants from
tanks into the soil and groundwater.
o Compliance With ARARs
Alternative T-1 would not comply with groundwater
ARARs, as continual source of contamination would not
be removed. The disposal of the underground tanks
(T-2) would eliminate the source of contamination and
would satisfy applicable State and Federal ARARs, as
the tanks and related wastes would be removed,
transported, and disposed of in accordance with all
regulations.
o Long-Term Effectiveness
Under alternative T-1, the tanks and their associated
hazardous wastes would remain as a potential source
of soil and groundwater contamination. Alternative T-
2, excavation and removal of the underground storage
tanks, tank debris, and highly contaminated soil from
the site, would reduce the potential human health and
environmental risks associated with the tanks' potential
for leaking contaminants into the soil and groundwater
in the future.
o Reduction of Toxicitv. Mobility or Volume
No significant reduction of toxicity, mobility or volume
would result from the implementation of the no-action
alternative. Alternative T-2, excavation and off-site
treatment, would result in a permanent reduction of
toxicity, mobility and volume. The wastes wor'"1 ^e
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14
Summary of Alternative
REMEDY
SOIL
SC-1
SC-3
SC-4
SOS
GROUNDWATER
GW-1
GW-2
GW-3A
GW-3B
GW-5A
GW-5B
BUILDING
BD-1
BD-2
UNDERGROUND TANKS
T1
T2
Analysis.
CAPITAL COST
0
18.535.100
2.262.500
385.600
0
214,800
4,044.700
4,936.000
4,088.900
4,069.800
8,800
186,200
0
336,300
PRESENT
WORTH COST
564,300
18,535,100
2,262.500
385,600
464,400
3,350.500
28,978.100
15,620.400
21.121,100
13,902,300
41,100
186200
64,300
336,300
TIME TO ACHIEVE
REMEDY (years)
30
3.5
3.5
5
100
103
65
19
65
16
30
3.3
30
3.1
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15
completely removed and either destroyed at the
treatment facility or reused if practical.
o Short Term Effectiveness
Alternative T-1 would result in no additional risk to the
community during implementation.
The potential public health threats to workers and area
residents associated with the implementation of
alternative T-2 include: direct contact of workers with
tank contents and potentially contaminated soils;
inhalation of fugitive dust, organic vapors, and
emissions generated during construction and
excavation activities; and improper handling of soil and
hazardous liquids. Several steps would be taken to
minimize these threats including: site access would be
restricted to authorized personnel only, and dust
control measures such as wind screens and water
sprays would be used to minimize fugitive dust
emissions.
The risk to workers during excavation would be
minimized by the use of adequate personal protection
equipment to prevent direct contact with potentially
contaminated soil, liquids, and inhalation of fugitive
dust and volatile organic compounds.
Other potential short-term impacts contemplated as
part of T-2 would be an increase in traffic and noise
pollution resulting from hauling soils (as necessary),
hazardous liquids, and tanks to an off-site treatment
facility, as well as the traffic associated with
transporting new soil for backfill to the Site.
Transportation of excavated hazardous liquids may
introduce short-term risks with the possibility of spillage
along the transport route and potential exposure of the
public to hazardous material. A spill contingency plan
would be developed to address and minimize the
likelihood and potential impact of this occurrence. The
actual remediation period for this alternative is
estimated to be 8 weeks.
o ImplementabiVitv
All the components of both remedial alternatives are
we!) developed and commercially available. The
contained tanks and related wastes would have to
undergo a series of analyses prior to acceptance for
treatment at the off-site facility. Sufficient land is
available at the site for mobilization and temporary
storage of the excavated soil and materials awaiting
pre-transport decontamination. Excavation, treatment
tank decommissioning, transportation to an off-she
treatment facility, solid and liquid waste disposal, and
Restoration of the site can be performed without any
Pmajor difficulty.
o Cost
The total present worth cost of alternative T-1 is
$64,300. The total present worth cost of alternative T-
2, which represents the estimated construction cost for
the eight week remediation program, is estimated at
$336,300. Operation and maintenance costs have not
been included in the cost estimate since the duration
of the remediation program is less than one year.
o State Acceptance
NYSDEC concurs with the preferred alternative
selected.
SUMMARY OF THE PREFERRED ALTERNATIVE
In summary, the preferred alternative will achieve
substantial risk reduction through a combination of
source control alternatives SC-4 (low temperature
enhanced volatilization of soil contaminants) and T-2
(tank removal and off-site treatment), with active
restoration of the groundwater (GW-3B), and building
decontamination (BD-2).
The preferred alternative achieves this risk reduction
more quickly and at substantially less cost than the
other options. Therefore, the preferred alternative will
provide the best balance of trade-offs among
alternatives with respect to the evaluating criteria.
Based on the information available at this time, EPA
and the NYSDEC believe that the preferred alternative
will be protective of human health and the environment,
will comply with ARARs, will be cost effective, and will
utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the
maximum extent practicable. The remedy also will
meet the statutory preference for the use of a remedy
that involves treatment as a principal element.
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APPENDIX C. SIGN-IN SHEET
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UNITED BT>.TBL;
REGIOW XI
PUBLIC: MEETING
FOR
Claremont Polyche:*iccl Supcxfund Bite
., Kew York
5, 1990
MEETING ATTENDEEd
(PlWse Print)
NAME STREET
HAILING
CITY ZIP PHONE REPRESENTING LIST
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APPENDIX D. OVERHEAD TRANSPARENCIES
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Public Meeting
Claremont Polychemical
Superfund Site
United States
Environmental
Protection Agency
September 5, 1990
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Site History
CONSTRUCTION OF THE CLAREMONT
POLYCHEMICAL FACILITY BEGAN IN 1966
PLANT OPERATION BEGAN IN 1968
MORE THAN A THOUSAND DRUMS WERE
DISCOVERED IN 1979 BY THE NASSAU COUNTY
DEPARTMENT OF HEALTH (NCDOH)
MUST OF THE DRUMS WERE GONE AND AREA OF
CONTAMINATED SOIL (SPILL AREA) WAS
DISCOVERED IN 1980 BY NCDOH
SOILS WERE EXCAVATED AND PLACED ON
PLASTIC LINERS IN 1980 BY THE COMPANY
COMPANY ENTERED INTO CHAPTER 11
PROCEEDINGS IN 1980
NEW YORK DEPARTMENT OF LAW ASSUMES THE
LEAD ON THE SITE AND ATTEMPTS TO
NEGOTIATE AN AGREEMENT WITH RESPONSIBLE
PARTY
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Site History
(Cont'n 2 of 3)
SITE RECOMMENDED FOR PLACEMENT IN
NATIONAL PRIORITY LIST IN OCTOBER 1984
SITE WAS FINALLY INCLUDED IN NATIONAL
PRIORITY LIST IN JUNE 1986 (RANKED 614)
EPA ASSUMES THE LEAD IN 1986 AND SENDS
OUT NOTIFICATION LETTER TO POTENTIALLY
RESPONSIBLE PARTY (PRP) IN NOVEMBER 1987
NO RESPONSE WAS RECEIVED AND FUNDS FOR
REMEDIAL INVESTIGATION/FEASIBILITY STUDY
(RI/FS) ARE ALLOCATED IN MARCH 1988
EBASCO SERVICES IS CONTRACTED BY EPA TO
CONDUCT RI/FS (1" OPERABLE UNIT) IN MARCH
1988
EPA CONDUCTS REMOVAL ACTION IN OCTOBER
1988 TO STABILIZE WASTES
SECOND RI/FS (2nd OPERABLE UNIT) IS OPEN IN
APRIL 1989 TO ADDRESS THE DISPOSAL OF
WASTES CONTAIN IN HOLDING UNITS (DRUMS,
BASINS, ETC)
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Site History
(Cont'n 3 of 3)
IMPLEMENTATION OF REMEDY FOR 2nd OPERABLE
UNIT STARTS IN SEPTEMBER 1989
RI/FS FOR 1- OPERABLE UNIT IS FINALIZED AND
REPORTS ARE RELEASED FOR PUBLIC COMMENT
IN AUGUST 1990
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REMEDIAL INVESTIGATION
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Summary of Field
Investigation
SOIL-GAS SURVEY
GEOPHYSICAL INVESTIGATION
AIR MONITORING
SURFACE SOIL SAMPLING
SUBSURFACE SOIL SAMPLING
MONITORING WELL INSTALLATION
HYDRAULIC CONDUCTIVITY TESTING
WATER LEVEL MEASUREMENTS
GROUNDWATER SAMPLING
BUILDING SAMPLING
UNDERGROUND STORAGE TANK SAMPLING
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Summary of Samples
Collected by EPA
SOIL GAS SURVEY - 102 samples
SOIL - 325 subsurface samples (25 locations)
32 surface samples
GROUNDWATER - 72 samples
- OFFSITE WELLS - 27 locations
- SITE WELLS - 5 locations
AIR - 10 locations
BUILDING - 57 samples
UNDERGROUND STORAGE TANKS - 23 samples
PRIOR EPA WORK
- BASINS
- CONTAINERS (DRUMS, ETC)
-SUMP
- ABOVE GROUND TANKS
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Maximum Concentration of Selected
Contaminants Detected in Soil,
Groundwater, Building and Underground
Tank Content
CONCEN-
MATRIX COMPOUND TRATION
SOIL bis(2-ethylhexyl) 270
(mg/Kg) phthalate
tetrachloroethene 26
lead 98
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Maximum Concentration of Selected
Contaminants Detected in Soil,
Groundwater, Building and Underground
Tank Content
MATRIX
GROUND
WATER
(ug/Kg)
COMPOUND
1,1,1-trichloroethane
trichloroethene
CONCEN-
TRATION
100
260
tetrachloroethene
1,300
ethylbenzene
160
bis(2-ethylhexyl)
phthalate
50
chromium
159
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Maximum Concentration of Selected
Contaminants Detected in Soil,
Groundwater, Building and Underground
Tank Content
MATRIX
BUILDING
(ug/wipe)
TANKS
(mg/Kg)
COMPOUND
bis(2-ethylhexyl)
phthalate
cadmium
chromium
copper
lead
2-butanone
toluene
xylene
bis(2-ethylhexyl)
CONCEN
TRATION
70
313
1,103
24,600
7,974
92,000
2,600
3,600
23,000
phthalate
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RISK ASSESSMENT
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Exposure Routes
SOIL
- INGESTION
- DIRECT CONTACT
- INHALATION
GROUNDWATER
- INGESTION
- DIRECT CONTACT
- INHALATION OF VOLATILE EMISSIONS
BUILDING
- INGESTION OF RESUSPENDED DUST
• EXISTING ROUTES VS. POTENTIAL FUTURE
ROUTES
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Public Health Evaluation
Current Land Use Conditions
NON
CARCINOGENIC CARCINOGENIC
EXPOSURE ROUTES RISK RISK
SOIL ACCEPTABLE ACCEPTABLE
SITE GROUNDWATER ACCEPTABLE ACCEPTABLE
AIR ACCEPTABLE ACCEPTABLE
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Public Health Evaluation
Future Off-Site Land Use Conditions
NON
CARCINOGENIC CARCINOGENIC
EXPOSURE ROUTES RISK RISK
SOIL ACCEPTABLE ACCEPTABLE
GROUNDWATER UNACCEPTABLE ACCEPTABLE
AIR ACCEPTABLE ACCEPTABLE
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Public Health Evaluation
Future On-Site Land Use Conditions
NON
CARCINOGENIC CARCINOGENIC
EXPOSURE ROUTES RISK RISK
SOIL ACCEPTABLE ACCEPTABLE
GROUNDWATER UNACCEPTABLE ACCEPTABLE
AIR ACCEPTABLE ACCEPTABLE
BUILDING UNACCEPTABLE UNACCEPTABLE
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FEASIBILITY STUDY
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Remedial Alternatives
CONTAMINATED SOILS
o SC-1 No Further Action
o SC-3 Excavation/Off-site Incineration/Backfill with
Clean Soil
o SC-4 Excavation/Low Temperature Enhanced
Volatilization/On-Site Redeposition
o SC-5 In-Situ Vacuum Extraction
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Remedial Alternatives
CONTAMINATED GROUNDWATER
o GW-1 No Further Action
o GW-2 Pumping/Air Stripping/Reinjection;
Southern Site Boundary (0.2 mgd)
o GW-3A Pumping/Air Stripping/Reinjection;
Leading Edge of Plume (1.9 mgd)
o GW-3B Pumping/Air Stripping/Reinjection;
Southern Site Boundary and Downgradient (1.0
mgd)
o GW-5A Pumping/UV-Chemical
Oxidation/Reinjection; Leading Edge of Plume
(1.9 mgd)
o GW-5B Pumping/UV-Chemical
Oxidation/Reinjection; Southern Site Boundary
and Downgradient (1.0 mgd)
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Remedial Alternatives
BUILDING
o BD-1 No Further Action
o BD-2 Building Decontamination/Waste Treatment
and Disposal
UNDERGROUND STORAGE TANKS
o T-1 No Further Action
o T-2 Removal and Off-Site Disposal
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Detailed Analysis of
Alternatives
1. OVERALL PROTECTION OF HUMAN
HEALTH AND THE ENVIRONMENT
2. COMPLIANCE WITH ARARs
3. LONG-TERM EFFECTIVENESS AND
PERMANENCE
4. REDUCTION IN TOXICITY, MOBILITY, OR
VOLUME
5. SHORT-TERM EFFECTIVENESS
6. IMPLEMENTABIUTY
7. COST
8. STATE ACCEPTANCE
9. COMMUNITY ACCEPTANCE
TREATMENT TECHNOLOGIES AND RESOURCE
RECOVERY
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Summary of Alternative Analysis.
SOIL
REMEDY
SC-1
SC-3
SC-4
SC-5
CAPITAL
COST
0
18,535,100
2,262,500
385,600
PRESENT
WORTH
COST
564,300
18,535,100
2,262,500
385,600
TIME TO
ACHIEVE
REMEDY
(years)
30
3.5
3.5
5
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Summary of Alternative Analysis.
GROUNDWATER
REMEDY
GW-1
GW-2
GW-3A
GW-3B
GW-5A
GW-5B
CAPITAL
COST
0
214,800
4,044,700
4,936,000
4,088,900
4,069,800
PRESENT
WORTH
COST
464,400
3,350,500
28,978,100
15,620,400
21,121,100
13,902,300
TIME TO
ACHIEVE
REMEDY
(years)
100
103
65
19
65
19
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Summary of Alternative Analysis
BUILDING
PRESENT TIME TO
CAPITAL WORTH ACHIEVE
REMEDY COST COST REMEDY
(years)
BD-1 8,800 41,100 30
BD-2 186,200 186,200 3.3
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Summary of Alternative Analysis,
UNDERGROUND TANKS
REMEDY
CAPITAL
COST
PRESENT
WORTH
COST
TIME TO
ACHIEVE
REMEDY
(years)
T-1 0 64,300 30
T-2 336,300 336,300 3.1
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EPA's Preferred Alternative
SC-4 Excavation/Low
Temperature Enhanced
Volatilization/On-Site
Redeposition
GW-3B Pumping/Air
Stripping/Reinjection;
Southern Site Boundary
and Downgradient (1.0
mgd)
BD-2 Building
Decontamination/Waste
Treatment and Disposal
T-2 Removal and Off-Site
Disposal
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PREFERRED REMEDY
REMEDY
4SC-4
4GW-3B
«BD-2
*T-2
CAPITAL
COST
2.3
4.9
0.2
0.3
PRESENT
WORTH
COST
2.3
15.6
0.2
0.3
TIME TO
ACHIEVE
REMEDY
(years)
3.5
19
3.3
3.1
TOTAL
7.7
18.3
Costs are expressed in million dollars
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