REMEDIATION SYSTEM EVALUATION
CLAREMONT POLYCHEMICAL SUPERFUND SITE
OLD BETHPAGE, NEW YORK
Report of the Remediation System Evaluation,
Site Visit Conducted at the Claremont Polychemical Superfund Site
June 26-27, 2001
Final Report Submitted to Region 2
March 7, 2002
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NOTICE
Work described herein was performed by GeoTrans, Inc. (GeoTrans) and the United States Army Corps
of Engineers (USAGE) for the U.S. Environmental Protection Agency (U.S. EPA). Work conducted by
GeoTrans, including preparation of this report, was performed under Dynamac Contract No. 68-C-99-
256, Subcontract No. 91517. Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
This document (EPA 542-R-02-008n) may be downloaded from EPA's Technology Innovation Office
website at www.epa.gov/tio or www.cluin.org/rse.
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EXECUTIVE SUMMARY
The Claremont Polychemical Superfund Site, located in a light industrial area of Old Bethpage, Nassau
County, New York, is approximately 10 acres in area. The site addresses contamination stemming from
the operations of a former manufacturer of pigments for plastics, inks, coated metallic tanks, and vinyl
stabilizers. Leaking drums of hazardous chemicals, primarily volatile organic compounds (VOCs) were
discovered by the Nassau County Health Department (NCHD) in 1979, and soil and groundwater
contamination beneath the site were discovered in 1980. A series of remedial actions by the property
owners began later that year, but subsequent investigations revealed additional contamination. The site
was placed on the National Priorities list in June 1986.
Two Records of Decision (RODs) were issued documenting the selection of several distinct remedial
actions for the Claremont Site. The first ROD addresses the contamination of soil and groundwater. The
second ROD addresses the removal of wastes found in drums, storage tanks, and treatment basins. The
excavation and on-site treatment of contaminated soil under the first ROD was completed in March 1997.
The removal of wastes specified in the second ROD was completed in 1990.
The groundwater treatment portion of the first ROD involves two phases. The first phase, which
addresses the contaminated groundwater on the Claremont property with a pump-and treat system, began
in February 2000. The second phase, which involves extraction and treatment of the contaminated
groundwater that has migrated beyond the Claremont property boundary, was to originally involve the
installation of an additional extraction and treatment system. However, a September 2000 Explanation of
Significant Differences (BSD) acknowledged that contaminated groundwater has migrated from the
Claremont property to another nearby Superfund site, namely the Old Bethpage Landfill (OBL) Site.
The OBL groundwater treatment system has been treating contaminated groundwater which migrated
from the Claremont Site. The Town of Oyster Bay (TOB) is the potentially responsible party for the
OBL Site and is responsible for operating the OBL groundwater treatment system pursuant to an
enforcement agreement with the New York State Department of Environmental Conservation
(NYSDEC). The ESD also acknowledged that three (3) extraction wells associated with the OBL
treatment system captured the groundwater plume emanating from the Claremont property (note: the
Claremont site managers report that these wells are no longer capturing OBL contamination and would
otherwise be decommissioned) and stipulated that these OBL extraction wells could operate in lieu of
installing and operating the additional extraction and treatment system originally specified in the
Claremont ROD.
The differences highlighted by the ESD are being implemented through a cooperative agreement with
NYSDEC and EPA to provide funding for the long-term response action related to the cleanup of the
groundwater plume. In addition, NYSDEC is planning to enter into a separate agreement with the TOB
for the implementation of this effort. EPA and NYSDEC will reimburse the Town of Oyster Bay 60% of
the OBL operating costs for up to 10 years, or until remedial action goals are achieved, whichever occurs
first. In the opinion of site managers, the Claremont Site has received the benefit of the OBL system's
treatment of the contaminated groundwater for several years, and in the opinion of site managers, it
would be fair, equitable, and reasonable to pay for the costs of this treatment. In the opinion of site
managers, it is more cost-effective to continue to use the OBL Site's treatment system in the future than
to construct a new treatment facility.
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This Remediation System Evaluation (RSE) report focuses primarily on the onsite Claremont pump-and-
treat system but also considers, to some degree, the efficiency and cost-effectiveness of the OBL
treatment system, as these factors influence the second phase of the Claremont groundwater remedy.
However, the RSE team did not visit the OBL treatment plant or meet with the managers of that system.
In general, the RSE team found a well-operated system. For example, after recognizing consistently low
influent iron and manganese concentrations, the plant operators discontinued metals removal treatment to
reduce the use of oxidizing chemicals and the associated hazards. The RSE team suggests the following
recommendations to improve system effectiveness:
• The depths-to-water in the monitoring wells are measured quarterly. These measurements should
be converted to water levels by subtracting the depths-to-water from the reference points of the
measurements (i.e., the elevations of the tops of the well casings).
• The process data and the quarterly aquifer data should be analyzed and the results and
conclusions should be reported (including an interpretation of the results with respect to progress
toward remediation goals).
• The Claremont VOC plume should be more thoroughly delineated, potentially through sharing
data with nearby sites, and the capture zone should be analyzed, potentially through development
and use of a groundwater flow model.
These recommendations might require approximately $76,000 in capital costs and might increase annual
costs by approximately $37,000 per year.
Recommendations to reduce life-cycle costs include the following:
• The unused metals removal system should be removed and the associated process monitoring and
labor should be eliminated. This would likely require an estimated capital investment of
approximately $500,000 to restructure the plant but would likely result in an estimated potential
savings of approximately $248,000 per year.
• The treatment system can also be simplified by eliminating the liquid phase carbon treatment
because the air stripper alone is capable of meeting the discharge requirements. Removing or
bypassing the units would likely require approximately $25,000 in capital costs; however,
approximately $23,000 per year could potentially be saved.
• Even if the treatment system is not simplified by removing the metals treatment system or the
liquid phase carbon, excess process monitoring chould be eliminated resulting in estimated
potential savings of approximately $5,000 per year.
• The pH discharge requirement should be relaxed so that the treatment process is not required to
increase the pH of the extracted water above natural background levels. This potentially would
lead to estimated savings of approximately $24,000 per year in chemical and supply costs and
would eliminate hazards associated with the transport and handling of caustic and acid.
• If the resulting risks associated with air emissions are sufficiently low, the vapor phase carbon
treatment could be eliminated if approved by NYSDEC and considered appropriate by US EPA.
Removing the vapor phase carbon treatment would result in estimated potential savings of $5,000
per year in utilities because operation of an offgas blower and a heater would not longer be
11
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required. Additional, but unquantified, savings would arise as future carbon replacement would
not be required. Site managers indicate that data from the monitoring of the influent and effluent
of the vapor phase carbon unit will determine if the vapor phase carbon unit can be eliminated.
• Finally, given that a portion of the operation costs of the OBL pump-and-treat system will be
incurred by the Claremont Site in exchange for the OBL system extracting and treating
Claremont-related contamination, the OBL treatment system should be optimized to determine if
operation costs can be reduced. Estimated potential cost savings from an RSE for the OBL
system have not been quantified.
Implementing the recommendations to reduce costs would require initial investments, but savings from
operations and maintenance could offset these initial investments as well as the costs associated with
recommendations for enhanced system effectiveness and technical improvement.
An approach to implementing these recommendations is provided in Section 6.6, and a summary of
recommendations, including estimated costs and/or savings associated with those recommendations is
presented in Section 7.0 of the report.
in
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PREFACE
This report was prepared as part of a project conducted by the United States Environmental Protection
Agency (USEPA) Technology Innovation Office (TIO) and Office of Emergency and Remedial Response
(OERR). The objective of this project is to conduct Remediation System Evaluations (RSEs) of pump-
and-treat systems at Superfund sites that are "Fund-lead" (i.e., financed by USEPA). RSEs are to be
conducted for up to two systems in each EPA Region with the exception of Regions 4 and 5, which
already had similar evaluations in a pilot project.
The following organizations are implementing this project.
Organization
Key Contact
Contact Information
USEPA Technology Innovation
Office
(USEPA TIO)
Kathy Yager
11 Technology Drive (ECA/OEME)
North Chelmsford, MA 01863
phone: 617-918-8362
fax: 617-918-8427
yager.kathleen@epa.gov
USEPA Office of Emergency and
Remedial Response
(OERR)
Paul Nadeau
1200 Pennsylvania Avenue, NW
Washington, DC 20460
Mail Code 5201G
phone: 703-603-8794
fax:703-603-9112
nadeau.paul@epa.gov
GeoTrans, Inc.
(Contractor to USEPA TIO)
Doug Sutton
GeoTrans, Inc.
2 Paragon Way
Freehold, NJ 07728
(732) 409-0344
Fax: (732) 409-3020
dsutton@geotransinc.com
Army Corp of Engineers:
Hazardous, Toxic, and Radioactive
Waste Center of Expertise
(USAGE HTRW CX)
Dave Becker
12565 W. Center Road
Omaha, NE 68144-3869
(402) 697-2655
Fax:(402) 691-2673
dave.i.becker(S>nwd02.usace. army.mil
IV
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The project team is grateful for the help provided by the following EPA Project Liaisons.
Region 1 Darryl Luce and Larry Brill
Region 2 Diana Curt
Region 3 Kathy Davies
Region 4 Kay Wischkaemper
Region 5 Dion Novak
Region 6 Vincent Malott
Region 7 Mary Peterson
Region 8 Armando Saenz and Richard Muza
Region 9 Herb Levine
Region 10 Bernie Zavala
They were vital in selecting the Fund-lead P&T systems to be evaluated and facilitating communication
between the project team and the Remedial Project Managers (RPM's).
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TABLE OF CONTENTS
EXECUTIVE SUMMARY i
PREFACE iv
TABLE OF CONTENTS vi
1.0 INTRODUCTION 1
1.1 PURPOSE 1
1.2 TEAM COMPOSITION 1
1.3 DOCUMENTS REVIEWED 2
1.4 PERSONS CONTACTED 2
1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS 3
1.5.1 LOCATION 3
1.5.2 POTENTIAL SOURCES 4
1.5.3 HYDROGEOLOGIC SETTING 4
1.5.4 DESCRIPTION OF GROUND WATER PLUME 5
2.0 SYSTEM DESCRIPTION 6
2.1 SYSTEM OVERVIEW 6
2.2 EXTRACTION SYSTEMS 6
2.2.1 CLAREMONT POLYCHEMICAL SITE EXTRACTION SYSTEM 6
2.2.2 OLD BETHPAGE LANDFILL SITE EXTRACTION SYSTEM 6
2.3 TREATMENT SYSTEMS 7
2.3.1 CLAREMONT POLYCHEMICAL SITE TREATMENT SYSTEM 7
2.3.2 OLD BETHPAGE LANDFILL SITE TREATMENT SYSTEM 7
2.4 MONITORING SYSTEMS 7
2.4.1 CLAREMONT POLYCHEMICAL SITE MONITORING SYSTEM 7
2.4.2 OLD BETHPAGE LANDFILL SITE MONITORING SYSTEM 8
3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE CRITERIA 9
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA 9
3.2 TREATMENT PLANT OPERATION GOALS 9
3.3 ACTION LEVELS 9
4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT 10
4.1 FINDINGS 10
4.2 SUBSURFACE PERFORMANCE AND RESPONSE 10
4.2.1 WATERLEVELS 10
4.2.2 CAPTURE ZONES 10
4.2.3 CONTAMINANT LEVELS 10
4.3 COMPONENT PERFORMANCE 11
4.3.1 EXTRACTION WELLS AND PUMPS 11
4.3.2 EQUALIZATION TANK 11
4.3.3 METALS REMOVAL SYSTEM AND PH ADJUSTMENT 11
4.3.4 AIR STRIPPER FEED TANK, AIR STRIPPER, AND BLOWER 11
4.3.5 LIQUID GRANULAR ACTIVATED CARBON UNITS 11
4.3.6 VAPOR GAC UNITS 12
4.3.7 REINJECTIONWELLS 12
4.3.8 CONTROLS 12
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF MONTHLY COSTS 12
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4.4.1 UTILITIES 13
4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS 13
4.4.3 LABOR 13
4.4.4 CHEMICAL ANALYSIS 13
4.5 RECURRING PROBLEMS ORISSUES 13
4.6 REGULATORY COMPLIANCE 13
4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL CONTAMINANT/REAGENT RELEASES
14
4.8 SAFETYRECORD 14
5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT
15
5.1 GROUND WATER 15
5.2 SURFACE WATER 15
5.3 AIR 15
5.4 SOILS 15
5.5 WETLANDS AND SEDIMENTS 15
6.0 RECOMMENDATIONS 16
6.1 RECOMMENDED STUDIES TO ENSURE EFFECTIVENESS 16
6.1.1 CONVERT DEPTHS-TO-WATER TO WATER LEVELS 16
6.1.2 ANALYZE AQUIFER AND OPERATIONS DATA AND REPORT RESULTS AND CONCLUSIONS 16
6.1.3 DEVELOP GROUNDWATER FLOW MODEL 17
6.2 RECOMMENDED CHANGES TO REDUCE COSTS 17
6.2.1 ELIMINATE METALS REMOVAL SYSTEM 17
6.2.2 SIMPLIFY REMAINING TREATMENT PROCESS TRAIN 18
6.2.3 ELIMINATE UNNECESSARY PROCESS MONITORING 19
6.2.4 ATTEMPT TO ELIMINATE DISCHARGE REQUIREMENT FOR PH 19
6.2.5 CONSIDER REMOVAL OF THE VAPOR PHASE CARBON TREATMENT 19
6.2.6 OPTIMIZE TREATMENT FACILITY AT THE OLD BETHPAGE LANDFILL SITE 19
6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT 20
6.3.1 REPLACE THE FAULTY INFLUENT FLOW METERS 20
6.3.2 MONITOR VAPOR PHASE CARBON UNIT INFLUENT WITH A PID 20
6.3.3 DETERMINE CAUSE OF THE PRESSURE BUILDUP OF THE LIQUID PHASE CARBON UNITS 20
6.5 DONATE UNUSED EQUIPMENT 21
6.6 SUGGESTED APPROACH TO IMPLEMENTATION 21
List of Tables
Table 7-1.
List of Figures
Figure 1-1
Figure 1-2
Figure 1-3
Cost summary table
The Claremont Polychemical Superfund Site and the surrounding area surrounding
Select well locations for the Old Bethpage Landfill Superfund Site, the Nassau County Firemen's
Training Center, and the Claremont Polychemical Superfund Site.
The Claremont Polychemical Site layout
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1.0 INTRODUCTION
1.1 PURPOSE
In the OSWER Directive No. 9200.0-33, Transmittal of Final FYOO - FY01 Superfund Reforms Strategy,
dated July 7,2000, the Office of Solid Waste and Emergency Response outlined a commitment to
optimize Fund-lead pump-and-treat systems. To fulfill this commitment, the US Environmental
Protection Agency (USEPA) Technology Innovation Office (TIO) and Office of Emergency and
Remedial Response (OERR), through a nationwide project, is assisting the ten EPA Regions in
evaluating their Fund-lead operating pump-and-treat systems. This nationwide project is a continuation
of a demonstration project in which the Fund-lead pump-and-treat systems in Regions 4 and 5 were
screened and two sites from each of the two Regions were evaluated. It is also part of a larger effort by
TIO to provide USEPA Regions with various means for optimization, including screening tools for
identifying sites likely to benefit from optimization and computer modeling optimization tools for pump
and treat systems.
This nationwide project identifies all Fund-lead pump-and-treat systems in EPA Regions 1 through 3 and
6 through 10, collects and reports baseline cost and performance data, and evaluates up to two sites per
Region. The site evaluations are conducted by EPA-TIO contractors, GeoTrans, Inc. and the United
States Army Corps of Engineers (USAGE), using a process called a Remediation System Evaluation
(RSE), which was developed by USAGE. The RSE process is meant to evaluate performance and
effectiveness (as required under the NCP, i.e., and "five-year" review), identify cost savings through
changes in operation and technology, assure clear and realistic remediation goals and an exit strategy,
and verify adequate maintenance of Government owned equipment.
The Claremont Polychemical Superfund Site was chosen based on initial screening of the pump-and-treat
systems managed by USEPA Region 2 as well as discussions with the EPA Remedal Project Manager for
the site and the Superfund Reform Initiative Project Liaison for that Region. This site has high operation
costs relative to the cost of an RSE and a long projected operating life. This report provides a brief
background on the site and current operations, a summary of the observations made during a site visit,
and recommendations for changes and additional studies. The cost impacts of the recommendations are
also discussed.
A report on the overall results from the RSEs conducted for this system and other Fund-lead P&T
systems throughout the nation will also be prepared and will identify lessons learned and typical costs
savings.
1.2 TEAM COMPOSITION
The team conducting the RSE consisted of the following individuals:
Rob Greenwald, Hydrogeologist, GeoTrans, Inc.
Ed Mead, Chemical Engineer, USAGE HTRW CX
Peter Rich, Civil and Environmental Engineer, GeoTrans, Inc.
Doug Sutton, Water Resources Engineer, GeoTrans, Inc.
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1.3
DOCUMENTS REVIEWED
Author
US EPA
US EPA
Rust Environmental &
Infrastructure
Rust Environmental &
Infrastructure
Lockwood, Kessler &
Bartlett, Inc.
NYSDEC
US EPA
Lockwood, Kessler &
Bartlett, Inc.
Lockwood, Kessler &
Bartlett, Inc.
Severn Trent Services
Severn Trent Services
Lockwood, Kessler &
Bartlett, Inc.
Date
8/1990
9/28/1990
5/3/1994
8/30/1994
8/1997
1998
9/2000
12/2000
1/2001
2/27/2001
2/28/2001
3/2001
Title/Description
Superfund Proposed Plan, Claremont Polychemical Site, Old
Bethpage, Nassau County, New York
Record of Decision, Claremont Polychemical Site, Old
Bethpage, New York
Operable Unit 1, Phase I Design, Claremont Polychemical
Corp. Superfund Site, Old Bethpage, New York, Vol. 1-6.
100% Final Design Submittal, Phase 1 Remedial Design Plans,
Claremont Polychemical Corp., Old Bethpage, New York
Report on the Extent of the Capture and Treatment of the
Claremont Site Plume
Final Effluent Limitations and Monitoring Requirements for
1/1/1998 through 12/31/2002, Claremont Polychemical
Superfund Site
Explanation of Significant Differences, Claremont
Polychemical Corporation Superfund Site, Town of Oyster Bay,
Nassau County, New York
2000 Third Quarter Report, Old Bethpage Solid Waste Disposal
Complex Groundwater Treatment Facility
2000 Fourth Quarter Report, Old Bethpage Solid Waste
Disposal Complex Groundwater Treatment Facility
Analytical Results of Process Monitoring Samples Received
2/13/2001 through 2/16/2001.
Analytical Results of Aquifer Monitoring Samples Received
2/8/2001 through 2/9/2001
2000 Annual Report, Old Bethpage Solid Waste Disposal
Complex Groundwater Treatment Facility
1.4
PERSONS CONTACTED
The following individuals were present for the site visit:
Rob Alvey, Hydrogeologist, EPA Region 2
Shewen Bian, USAGE, New York District
Bob Burns, Plant Operator, URS
Maria Jon, RPM, EPA Region 2
Diana Cutt, Project Liaison, EPA Region 2
James Jackson, Plant Operator, URS
Samy Said, Project Manager, USAGE New York District
Ken Sullivan, Project Manager, URS
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1.5 SITE LOCATION, HISTORY, AND CHARACTERISTICS
1.5.1 LOCATION
The Claremont Polychemical Superfund Site is approximately 10 acres in area and is located in a light
industrial area of Old Bethpage, New York. The remedy at the site addresses contamination from
volatile organic compounds (VOCs) resulting from the operations of the Claremont Polychemical
Company, which manufactured pigments for plastics, dyes and other materials between 1966 and 1980.
The Claremont Polychemical Site is bordered to the south and southeast by the Bethpage State Park and a
golf course, to the east by the State University of New York- Farmingdale Campus, and to the north by a
commericial and light industrial area. To the west, the Claremont Polychemical Site is bordered by the
Oyster Bay Solid Waste Disposal Complex (Old Bethpage Landfill), which is a Superfund Site with the
Town of Oyster Bay as the responsible party. The Nassau County Fireman's Training center, which has
also contributed to soil and groundwater contamination in the area, is located approximately 500 feet
south of the OBL site. Figure 1-1 shows the location of the site and the area surrounding it.
Two Records of Decision (RODs) were issued documenting the selection of several distinct remedial
actions for the Claremont Site. The first ROD addresses the contamination of soil and groundwater. The
second ROD addresses the removal of wastes found in drums, storage tanks, and treatment basins. The
excavation and on-site treatment of contaminated soil under the first ROD was completed in March 1997.
The removal of wastes specified in the second ROD was completed in 1990.
The groundwater treatment portion of the first ROD involves two phases. The first phase, which
addresses the contaminated groundwater on the Claremont property with a pump-and treat system, began
in February 2000. The second phase, which involves extraction and treatment of the contaminated
groundwater that has migrated beyond the Claremont property boundary, was to originally involve the
installation of an additional extraction and treatment system. However, a September 2000 Explanation of
Significant Differences (BSD) acknowledged that contaminated groundwater has migrated from the
Claremont property to another nearby Superfund site, namely the Old Bethpage Landfill (OBL) Site.
The OBL groundwater treatment system has been treating contaminated groundwater which migrated
from the Claremont Site. The Town of Oyster Bay (TOB) is the potentially responsible party for the
OBL Site and is responsible for operating the OBL groundwater treatment system pursuant to an
enforcement agreement with the New York State Department of Environmental Conservation
(NYSDEC). The ESD also acknowledged that three (3) extraction wells associated with the OBL
treatment system captured the groundwater plume emanating from the Claremont property (note: the
Claremont site managers report that, these wells are no longer capturing OBL contamination and would
otherwise be decommissioned) and stipulated that these OBL extraction wells could operate in lieu of
installing and operating the additional extraction and treatment system originally specified in the
Claremont ROD.
The differences highlighted by the ESD are being implemented through a cooperative agreement with
NYSDEC and EPA to provide funding for the long-term response action related to the cleanup of the
groundwater plume. In addition, NYSDEC is planning to enter into a separate agreement with the TOB
for the implementation of this effort. EPA and NYSDEC will reimburse the Town of Oyster Bay 60% of
the OBL operating costs for up to 10 years, or until remedial action goals are achieved, whichever occurs
first. In the opinion of site managers, the Claremont Site has received the benefit of the OBL system's
treatment of the contaminated groundwater for several years, and in the opinion of site managers, it
would be fair, equitable, and reasonable to pay for the costs of this treatment. In the opinion of site
managers, it is more cost-effective to continue to use the OBL Site's treatment system in the future than
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to construct a new treatment facility. The estimated cost to EPA for over this 10-year period for these
reimbursements is expected to be approximately $12 million.
Figure 1-2 shows both the Old Bethpage Landfill Site and extraction wells and the Claremont Site
extraction, monitoring, and reinjection wells.
1.5.2 POTENTIAL SOURCES
The principle wastes generated in the production of pigments at the Claremont Polychemical facility
consisted of volatile organic compounds (VOCs) such as tetrachloroethylene (PCE), trichloroethylene
(TCE), resins, and mineral spirits. Contaminated soil and groundwater likely resulted from daily
operations and from leaks in chemical drums, storage tanks, and treatment basins. Leaking drums
containing hazardous chemicals were first discovered by the Nassau County Health Department (NCHD)
in 1979. The drums were removed or their contents reused by 1980, and the property owners excavated a
75-foot by 75-foot area of contaminated soil east of the process building to a depth of 10 feet. Figure 1-3
shows the Claremont Site layout, identifies the former spill area, and notes the location of nearby wells.
An EPA Remedial Investigation conducted in 1988 revealed extensive soil and groundwater
contamination. The highest PCE concentration in soil was 26,000 ppb and was found in an identified
spill area to the east of the process building. Other site-related contaminants found in the soil included
acetone, 2-butanone, 4-methyl-2-pentanone, xylenes, toluene, dicholorethylene (DCE), and
trichloroethylene (TCE). Polyaromatic hydrocarbons, pthalates, and pesticides were also discovered in
subsurface soils; however, PCE is listed as the only chemical of concern in the soil in the ROD due to its
ability to leach into the groundwater. In this 1988 Remedial Investigation concentrations of all
contaminants was found to decrease significantly with depth. However, more recent data suggest an
increase in TCE concentration with depth approximately 50 feet to the east of the identified spill area.
The stabilization and removal of waste under OU2 was completed in 1990, and the excavation and onsite
treatment of soil was completed by March 1997. Additional soil contamination beneath the chemical
process building, however, was discovered during building decontamination. EPA is currently evaluating
options to address this contaminated soil.
1.5.3 HYDROGEOLOGIC SETTING
The Cretaceous Magothy Formation, a sole-source aquifer for central Long Island, underlies the
Claremont Polychemical site. Near the Claremont Site, this formation extends approximately 300 feet
below ground surface (bgs) and consists of well-stratified unconsolidated sand, silt, and clay. The silt
and clay content dominates the northwestern portion of the site and the proportion of sand increases
toward the southern boundary of the site. The water table is typically at 65 to 70 feet bgs and
groundwater flows to the south-southeast. Thus, the Old Bethpage Landfill lies upgradient of the
Claremont Site, and the golf course and Bethpage State Park lie downgradient of the Claremont Site.
A number of extraction wells exist in the area which complicates the hydrogeology. The Claremont
Polychemical Site has three extraction wells that collectively pump approximately 325 gpm on average.
The Old Bethpage Landfill Site has five extraction wells that collectively pump approximately 1,000
gpm. The Fireman training center also has a pump-and-treat system, and the golf course uses water for
irrigation. Municipal water supply wells exist over 3,500 feet to the north.
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1.5.4 DESCRIPTION OF GROUND WATER PLUME
The Remedial Investigation (1989) identified PCE as the groundwater contaminant with the greatest areal
extent. Samples from that investigation showed migration of PCE 2,100 feet to the southeast of the site
and the highest concentrations (1,300 ppb) occurred at the property boundary. The plume was estimated
to be approximately 800 feet wide. Trans 1,2 DCE (830 ppb), TCE (260 ppb), and other contaminants
were also found in the groundwater in concentrations exceeding the maximum contaminant levels
(MCLs).
Subsequent analyses found increases in the groundwater PCE concentration. In a 1992 sampling event,
well SW2 had a PCE concentration of 3,400 ppb and well EW-2A had a concentration of 2,200 ppb. The
highest concentrations were found at an elevation of approximately 60 feet above mean sea level (60 feet
MSL), which is just below the water table. Contamination, however, extends much deeper. The ROD
estimated the PCE plume extended approximately 164 feet below ground surface (bgs) which translates
to an elevation near sea level (0 feet MSL). As of February 2001, the highest concentration of PCE in
groundwater was 4,200 ppb (measured in SW-1). PCE concentrations in other sampled wells did not
exceed 400 ppb. This same sampling event also revealed a TCE concentration of 4,200 ppb in well EW-
4C located approximately 50 feet to the east of the identified spill area. A plume map with recent site-
related data has not been developed as part of the site activities.
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2.0 SYSTEM DESCRIPTION
2.1 SYSTEM OVERVIEW
The Claremont Poly chemical Site pump-and-treat system (first phase of the groundwater remedy)
became operational and functional in February 2000 consists of an extraction system, above-ground
treatment, and a reinjection system. On average the extraction system, which consists of three extraction
wells, pumps approximately 325 gpm of groundwater to the treatment system. The combined influent
concentration for PCE and TCE from the February 2001 sampling event was 640 ug/L. With this average
flow rate and influent concentration, that treatment plant removes approximately 2.5 pounds of PCE and
TCE (combined) from the extracted groundwater each day.
325 gallons 640 ug (PCE & TCE) 3.785 liters 1440 minutes 2.2 Ibs 2.5 Ibs
Y Y Y Y —
minute liter gallon day Ixl09ug day
As specified in the September 2000 Explanation of Significant Differences (ESD) for the Claremont
Poly chemical site, the second phase of the groundwater extraction and treatment will involve extraction
of water from recovery wells RW-3, RW-4, and RW-5 of the Old Bethpage Landfill Site and treatment of
that water at the OBL treatment facility.
2.2 EXTRACTION SYSTEMS
2.2.1 CLAREMONT POLYCHEMICAL SITE EXTRACTION SYSTEM
The Claremont extraction system consists of three extraction wells approximately 150 feet apart south of
the site oriented in a southwest-northeast line. The pumps in the wells are controlled by the level in the
equalization tank and are turned on and off simultaneously. Although each well is capable of pumping
up to 200 gpm individually, when they are all on, EW-1, EW-2, and EW-3 respectively extract 190 gpm,
188 gpm, and 175 gpm for a total of approximately 553 gpm. Because the wells are off part of the time
as controlled by the level in the equalization tank, the average flow rate over the course of a month is
approximately 325 gpm. This average flow rate translates to approximately 470,000 gallons per day
which is very close to the onsite remedy goal of treating 500,000 gallons per day.
2.2.2 OLD BETHPAGE LANDFILL SITE EXTRACTION SYSTEM
According to the documents reviewed by the RSE team, the Old Bethpage Landfill Extraction System
consists of five recovery wells located downgradient of the Claremont Site in Bethpage State Park. The
wells are connected to a treatment system via a common transmission line and are designed to extract
approximately 1.5 million gallons per day (approximately 1,050 gpm). Based on hourly logs of the flow
rates of each recovery well, it appears that wells RW-3 and RW-5 were not operational for a significant
portion of the third and fourth quarters of 2000. With these two wells down, RW-1, RW-2, and RW-4
pumped approximately 250 gpm, 260 gpm, and 245 gpm, respectively, for a total of approximately 755
gpm or 1.1 million gallons per day. With only RW-5 down, total system flow increased to approximately
875 gpm or 1.25 million gallons per day. Based on these flow rates, it is reasonable to assume that
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pumping from RW-3, RW-4, and RW-5 as part of the Claremont remedy could be as high as
approximately 200 gpm from each of the three wells for a total of 600 gpm or 860,000 gallons per day.
Given that the Claremont ROD requires pumping of offsite at 500,000 gpd, these three wells should meet
this requirement.
2.3 TREATMENT SYSTEMS
2.3.1 CLAREMONT POLYCHEMICAL SITE TREATMENT SYSTEM
Water from the extraction system enters a 60,000 gallon equalization tank situated adjacent to the
treatment building. Water from the equalization tank flows through two parallel metals-removal trains
that are each rated for 250 gpm. Each train includes a reaction tank, a flocculation tank, a clarifier, and a
filter and is followed by air-stripper feed tanks. These feed tanks send the water through a single packed-
tower air stripper rated at an average rate of 500 gpm and then through parallel liquid phase carbon units
each rated at 250 gpm. The air emissions from the air stripper are treated with vapor phase carbon. In
addition to removing metals and VOCs from the extracted water, the treatment system also raises the pH
of the extracted water from pH 5, which is the background pH for groundwater in the area, to between
pH 6.5 and 8.5. The treated water is then transferred to treated-water storage tanks before it is reinjected
to the subsurface through four reinjection wells located on the SUNY Farmingdale property (see Figure
1-2).
After the first nine months of operation the addition of oxidizing chemicals (potassium permanganate) to
the metals removal system was discontinued as the influent to the plant already met discharge standards
for metals. Water continues to flow through this system and caustic is still added to raise the pH.
2.3.2 OLD BETHPAGE LANDFILL SITE TREATMENT SYSTEM
Extracted water from all of the Old Bethpage Landfill recovery wells is treated in a single treatment
facility that consists of a packed tower air stripper. Based on hourly logs, water flows through the air
stripper at approximately 1,300 gpm and a blower provides approximately 8,000 standard cubic feet of
air per minute (scfm). The treated water is discharged into recharge basins and the offgas from the air
stripper exits through a stack. Chemical addition is used to reduce metals fouling of the air stripper.
2.4 MONITORING SYSTEMS
2.4.1 CLAREMONT POLYCHEMICAL SITE MONITORING SYSTEM
Thirteen monitoring wells of various depths are sampled and analyzed for VOCs and inorganics
quarterly. All of these wells are either on or adjacent to the site and do not address the extended plume.
The depths to water in each of these wells is also recorded quarterly. The elevations of the tops of the
well casings, however, are not used to convert these measurements to water levels so potentiometric
surface maps have not been generated.
During the first twelve weeks of operation, samples were collected weekly between each of the treatment
train processes. Since the end of that initial period of operation, the samples between each process have
been collected quarterly. The influent and effluent, however, are still sampled weekly for VOCs and
monthly for metals and base-neutral-acid extractables as required by NYSDEC. The plant operator
regularly samples the effluent of the vapor phase carbon with a photoionization detector (PID).
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2.4.2 OLD BETHPAGE LANDFILL SITE MONITORING SYSTEM
The monitoring program for the Old Bethpage Landfill Site consists of the following:
• Water levels are measured quarterly from 54 wells in the area.
• Groundwater quality, including analysis for VOCs and inorganics, are measured quarterly from
approximately 15 wells.
• Ambient air and soil-gas are measured up and down wind of the plant annually.
• Three samples from the influent and effluent and one sample from each well are collected weekly
and analyzed for VOCs and inorganics such as ionization potential, manganese, and dissolved
oxygen.
• Onsite staff monitor on an hourly basis, the flow rate from each of the wells, the flow rates of
water and air through the air stripper, and the air pressure drop across the air stripper.
• The offgas of the air stripper is determined by calculating a mass balance based on
concentrations of extracted and treated groundwater and flow rates.
• Monthly samples of the influent and effluent are sent to an offsite certified laboratory for
analysis for the monthly State Pollution Discharge Elimination System (SPDES) reports. The
effluent samples are analyzed for both organics and inorganics and the influent is only analyzed
for organics.
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3.0 SYSTEM OBJECTIVES, PERFORMANCE AND CLOSURE
CRITERIA
3.1 CURRENT SYSTEM OBJECTIVES AND CLOSURE CRITERIA
The ROD stipulates that the overall remedy 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."
Specifically referring to remediation of groundwater, the ROD states that "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 compounds." The selected groundwater remedy involves
pumping, pre-treatment, air stripping, carbon adsorption, and reinjection of groundwater. The pumping
is to occur both at the site boundary and downgradient to address the extended plume. Collectively, the
onsite and offsite wells are to pump approximately 1 million gallons per day or almost 700 gpm. The
September 2000 BSD stipulates that the offsite pumping and the treatment of the associated water would
be accomplished through operation of recovery wells RW-3, RW-4, and RW-5 of the Old Bethpage
Landfill Site.
Both the ROD and BSD estimate that pumping from onsite and offsite wells will continue for 10 years at
which point pumping from the offsite wells could be discontinued and pumping from onsite wells would
continue for another 6 years.
3.2 TREATMENT PLANT OPERATION GOALS
The treatment system at the Claremont Polychemical Site has a goal of treating and reinjecting 500,000
gallons per day. Treated water must comply with both the Federal maximum contaminant levels (MCLs)
and the New York State Groundwater Quality Standards for the contaminants of concern. The air
emissions from the vapor phase carbon must also meet State standards.
3.3 ACTION LEVELS
The effluent limitations and monitoring requirements for the treated water specify weekly sampling for
pH, PCE, TCE, and cis-1,2 DCE and monthly sampling for other VOCs, BNAs, or inorganics. The
discharge limit for PCE, TCE, and cis-1,2 DCE is 5 ug/L (ppb) for each contaminant, and although
background water in the area is pH 5, the permit requires the plant effluent is pH 6.5 to 8.5. Given that
the treatment plant was designed and originally operated to remove metals such as iron and manganese, it
is pertinent to note that the discharge limit for each of those metals is 600 ug/L. The combined
concentration for iron and manganese may not exceed 1,000 ug/L.
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4.0 FINDINGS AND OBSERVATIONS FROM THE RSE SITE VISIT
4.1 FINDINGS
The RSE team found a well-operated treatment plant. The observations and recommendations given
below are not intended to imply a deficiency in the work of the designers, operators, or site managers but
are offered as constructive suggestions in the best interest of the EPA and the public. These
recommendations obviously have the benefit of the operational data unavailable to the original designers.
4.2 SUBSURFACE PERFORMANCE AND RESPONSE
4.2.1 WATER LEVELS
The depth to water is measured quarterly from thirteen wells; however, these have not been converted to
water levels or a potentiometric surface map since plant operation began. The depth to the water from
these thirteen wells varies between 67 feet bgs and 98 feet bgs depending on the location and depth of the
well. The depth to water in each of the wells in the EW-1 cluster is approximately 67 feet bgs, and the
depth to water in the EW-4 cluster is approximately 98 feet bgs.
4.2.2 CAPTURE ZONES
The capture zones of the extraction wells cannot effectively be evaluated without reliable water-level
maps or without consistent monitoring of contaminants in downgradient wells. Because reliable water
level measurements have not been interpreted and downgradient monitoring of the contaminants is not
conducted as part of site activities, the actual capture of site-related contaminants are not known.
However, aquifer sampling conducted as part of the Old Bethpage Landfill Site suggests decreasing
concentrations of PCE downgradient of the Claremont Site. PCE concentrations in MW-8A, located
immediately downgradient of the Claremont extraction system, had concentrations above 200 ppb in
January and April 2000 (prior to and shortly after the beginning of operation) but 40 ppb in July 2000
and 26 ppb in October 2000.
4.2.3 CONTAMINANT LEVELS
As stated previously, concentrations in the extended Claremont plume appear to have significantly
decreased during 2000 as determined by the sampling associated with the Old Bethpage Landfill Site.
VOC concentrations on the Claremont Site continue to be high according to the February 2001 aquifer
sampling conducted by the Claremont Site operators. EW-1A had a PCE concentration of 380 ppb and
SW1 had a PCE concentration of 4,200 ppb. This latter concentration exceeds by two to three orders of
magnitude the PCE concentration measured from the same well one year earlier. In addition, EW-4C,
which screens approximately 5 to 15 feet MSL (160 feet bgs), had a TCE concentration of 4,200 ppb.
This well typically has had higher values of TCE compared to the rest of the site or compared to
shallower depths in the same location, and this value of 4,200 ppb is higher than previous values in
documents reviewed by the RSE team. This increase suggests the migration of contamination or a
potential deep source of dissolved phase TCE.
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4.3 COMPONENT PERFORMANCE
The following subsections describe the component performance of the Claremont Polychemical pump-
and-treat system. The performance of the components of the Old Bethpage Landfill pump-and-treat
system were not reviewed as part of this RSE.
4.3.1 EXTRACTION WELLS AND PUMPS
The three extraction wells are screened from approximately 60 feet MSL (just below the water table) to -30
feet MSL and are outfitted with 10 horsepower pumps each capable of providing 200 gpm. The extraction
pumps are turned on and off simultaneously based on the level of water in the equalization tank. Flow is
typically limited by what the treatment system can accommodate rather than what the extraction wells can
produce.
4.3.2 EQUALIZATION TANK
The equalization tank can hold 60,000 gallons and is typically set to operate between 60% and 90% full.
When the level exceeds 90%, the extraction wells are shut down, and when the level falls below 60%, the
extraction wells are restarted. When this tank is 90% full, it allows for approximately 20 minutes of influent
if the rest of the treatment plant is shut down.
4.3.3 METALS REMOVAL SYSTEM AND pH ADJUSTMENT
The metals removal system consists of two parallel trains that each have a reaction tank, flocculation tank,
clarifier, and sand filter. By design metals are removed by the addition of caustic and potassium
permanganate that result in the formation of manganese and iron hydroxide which precipitate out of solution.
This process also increases the pH to meet the discharge limit of pH 6.5 to 8.5. After the first two months
of operation, the concentrations of the influent iron and manganese dropped below the discharge limits
suggesting the possibility of discontinuing the metals removal system. After nine months of operation, the
metals removal system was discontinued allowing water to flow through the associated tanks untreated. The
influent metals concentrations continue to meet the discharge requirements; however, to meet the pH
requirement, caustic is still added to increase the pH. Minimal sludge has been recovered, so the associated
filter press has remained unused.
4.3.4 AIR STRIPPER FEED TANK, AIR STRIPPER, AND BLOWER
Both metals removal trains are followed by air stripper feed tanks that send water to a single air stripper.
The air stripper is designed to treat 500 gpm and is provided with air from a 20 horsepower blower operating
across a pressure equivalent to 11 inches of water. The air stripper is operated in a semi-batch mode, and
at times, flow sent from the feed tanks through the air stripper exceeds 800 gpm.
4.3.5 LIQUID GRANULAR ACTIVATED CARBON UNITS
Two 15,000-pound granular activated carbon (GAC) units, each rated to a capacity of 250 gpm, are aligned
in parallel to polish the effluent water from the air stripper. The units are backwashed every few weeks due
to an increase in pressure across the units. Although the stripper typically meets the discharge requirements
without the need for subsequent carbon polishing, the plant operators found that the carbon effluent had a
concentration of 15 ug/L of PCE in June 2001. The breakthrough of the liquid GAC vessels was due to the
carbon being spent as per the expected design time frame of 1.5 to two years. As a result of this PCE
breakthrough of the GAC units, the units were scheduled for replacement in early July 2001.
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4.3.6 VAPOR GAC UNITS
Two vapor phase GAC units are available to treat the offgas from the air stripper. Currently, only one of the
10,000-pound units is used and breakthrough has not been detected by routine sampling of the effluent with
a PID. Influent concentration to this unit is not sampled.
4.3.7 REINJECTION WELLS
Water from the carbon polishers are stored in two 60,000-gallon vessels before reinjection to the subsurface.
Four reinjection wells fed by a single pump are used to reinject the treated water into the subsurface. The
wells, located on the adjacent SUNY Farmingdale campus, have high-level alarms and are regularly gauged.
4.3.8 CONTROLS
The plant is manned by two operators working 40 to 50-hour weeks, and an autodialer is installed to contact
the operators in case of plant alarms. The operators typically responds to alarms within 30 minutes.
4.4 COMPONENTS OR PROCESSES THAT ACCOUNT FOR MAJORITY OF
MONTHLY COSTS
The U.S. Army Corps of Engineers (USAGE), New York District, provides oversight for plant operations,
and a private contractor operates the plant. The contractor bills USAGE based on the number of gallons
treated. The rate for the second year of operation is $4.14 per 1,000 gallons treated, and the expected volume
of treated water is 165 million gallons. This translates to an estimated cost of approximately $680,000 for
the year without USAGE oversight, which brings the total cost of $740,000 for the year. For operation of
the Old Bethpage wells, EPA has agreed to reimburse 60% of the operation that facility's costs on a monthly
basis. EPA currently estimates its costs will be approximately $12 million over 10 years, or approximately
$1.2 million per year. Thus, the total cost to EPA for operating both phases of the groundwater remediation
is approximately $2 million per year.
The estimated breakdown of the approximate monthly operation and maintenance costs for the Claremont
Site (excluding the OBL system) are summarized in the following table.
Operator labor (45 hours per week) x 2 $27,000
Analytical (process water and air) $6,250
Analytical (monitoring wells) $3,750
Sampling supplies $2,000
Liquid GAC (replacement and disposal) $1,700
Chemicals $2,000
Electric $7,000
Gas (heat) $1,000
$50,700 per
month
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A monthly cost of almost $51,000 is approximately $6,000 less than the monthly cost derived from dividing
the expected annual cost of $680,000 by 12 months (approximately $57,000 per month). This $6,000 per
month is likely allocated to project management, overhead, and profit.
4.4.1 UTILITIES
The cost of utilities is predominantly electricity used to operate the 20-horsepower blower for the air stripper,
the transfer pumps within the facility, and the three 10-horsepower pumps in the extraction wells. This cost
estimate is based on review of the monthly electric bills.
4.4.2 NON-UTILITY CONSUMABLES AND DISPOSAL COSTS
Caustic and acid are used onsite for adjustment of the pH. Potassium permanganate is no longer required
as metals removal has been discontinued. The majority of the chemical costs are associated with the caustic
as acid is only used to lower the pH in rare instances when caustic is added in excess. The cost estimate for
the chemicals was provided by the plant operator. The cost of sampling supplies was estimated by the RSE
team based on the approximate number of collected samples (10 per month plus 15 per quarter translates to
approximately 15 per month). The estimated cost of carbon replacement was calculated using the
replacement cost provided by the plant operator (approximately $30,000 for both units), dividing by the
approximate 1.5 years the plant has been operating, and dividing the result by 12 months.
4.4.3 LABOR
Two plant operators staff the treatment facility between 6:30 AM and 3:30 PM on weekdays. Less than once
per month, additional visits to the site are required in response to the plant autodialer. The estimated costs
are based on 45 hours per week for each operator at approximately $75 per hour, estimated by the RSE team.
4.4.4 CHEMICAL ANALYSIS
Chemical analysis is required for both process monitoring and aquifer monitoring. These estimated costs
assume approximately $250 total for inorganic and VOC analyses of each sample.
4.5 RECURRING PROBLEMS OR ISSUES
The plant operators and site managers did not mention any recurring problems or issues. The plant operators,
however, were recently notified that young adults were tampering with the reinjection wells located on the
adjacent SUNY Farmingdale campus.
4.6 REGULATORY COMPLIANCE
The plant continually meets all of the discharge requirements.
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4.7 TREATMENT PROCESS EXCURSIONS AND UPSETS, ACCIDENTAL
CONTAMINANT/REAGENT RELEASES
The RSE team found no record of accidental contaminant or reagent releases.
4.8 SAFETY RECORD
According to the plant operators, only one accident has occurred during operation of the plant. It occurred
during the original shake-down period and involved a worker being sprayed with concentrated hydrochloric
acid. The worker was wearing the required safety equipment which mitigated injury.
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5.0 EFFECTIVENESS OF THE SYSTEM TO PROTECT HUMAN
HEALTH AND THE ENVIRONMENT
5.1 GROUND WATER
Although not demonstrated in a formal capture zone analysis, the Claremont and the Old Bethpage Landfill
remedies appear to collectively contain the majority of the contamination from the Claremont Site. Public
or private use of groundwater in the area does exist. The golf course located to the southeast of the site uses
groundwater for irrigation and this water may be impacted from site-related contamination. The closest
water supply wells are approximately 3,500 feet to the north and are not impacted by site-related
contamination.
5.2 SURFACE WATER
There is no permanent surface water bodies within a mile of the site in any direction.
5.3 AIR
Approximately 2.5 pounds of VOCs, primarily PCE, are removed from groundwater daily (mostly via the
air stripper) and the large majority of this is stored in vapor phase or liquid phase carbon units. A very small
fraction is lost to the ambient air as the process watertravels through the discontinued metals removal system
as it is open to the air. Because a slight vacuum is maintained in the treatment plant this minimal amount
of VOCs in the building air is released to the atmosphere and diluted. Thus, the area's air quality is not
significantly impacted by operation of the pump-and-treat system.
5.4 SOILS
At the time of the RSE site visit, surface soils did not appear to be affected by VOC contamination.
Additional subsurface VOC contamination was detected, however, during a recent investigation of the former
process building.
5.5 WETLANDS AND SEDIMENTS
There are no wetlands or surface water sediments within a mile of the site in any direction.
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6.0 RECOMMENDATIONS
6.1 RECOMMENDED STUDIES TO ENSURE EFFECTIVENESS
6.1.1 CONVERT DEPTHS-TO-WATER TO WATER LEVELS
As part of their scope of work, the plant operators measure the depth-to-water in each of the monitoring wells
on a quarterly basis. These measurements, however, are not converted to water levels, which are crucial for
understanding groundwater flow near the site. The necessary conversion can easily be accomplished by
subtracting the depths-to-water from the point of measurement, typically the elevations of the tops of the well
casings. Once these water-level measurements are obtained, potentiometric surface maps can be generated
and hydraulic models can be calibrated. Thus, it is recommended that the plant operators or site managers
convert the depths-to-water to water level measurements. The elevations forthe tops of the well casings and
other well-construction details are readily available as they were shared with the RSE team for a number the
monitoring wells (the EW series including EW-1A, B, C; EW-2A,B,C; etc.). If the equivalent information
for SW1, SW2, DW1, and DW2 is not available, a survey crew should be hired to determine the elevations
of the tops of the casings and the screened intervals for these wells. The costs of these evaluations should
be less than $2,000 per year. Capital costs for surveying should be less than $ 1,000, if required. Subsequent
to the RSE site visit, USAGE has been tasked with providing quarterly monitoring reports incorporating this
recommendation, and a draft annual report has been submitted.
6.1.2 ANALYZE AQUIFER AND OPERATIONS DATA AND REPORT RESULTS AND CONCLUSIONS
At the time of the RSE visit, water quality samples from multiple locations in the treatment process train and
from monitoring wells were being collected quarterly and analyzed for VOCs and inorganics, but the
resulting data were not evaluated or reported to the EPA or USAGE site manager. Thus, the site managers
did not have the information readily available to continually evaluate the progress of the remedy or any
opportunities for improvement. During the RSE site visit, the EPA and USAGE site managers, in addition
to the contractors, acknowledged that data analysis and reporting was not part of the scope of work for the
contractor. Subsequent to the RSE site visit, USAGE has been tasked with providing quarterly monitoring
reports, and a draft annual report has been submitted.
Although some of the process monitoring associated with the unused metals removal system may be
unnecessary to evaluate the effectiveness of the treatment plant, the weekly influent and effluent VOC and
metals concentrations should be compared to the discharge standards and provided to the site managers for
review. Any discrepancies between the effluent concentrations and the discharge standards should be
highlighted. In addition, the trend in the blended influent concentration should be plotted so the site
managers can continually evaluate the amount of mass currently extracted from the subsurface or expected
to be extracted from the subsurface in the near future. This will help site managers determine the
effectiveness of the current remedy and evaluate the potential for new technologies as they arise.
The results of the quarterly aquifer water quality monitoring and water level measurements also require
interpretation. Such analysis may include plotting plume maps and potentiometric surface maps and
evaluating changes in these maps with each sampling event. This analysis is a crucial element of evaluating
the degree of containment of the contaminants and the progress of the cleanup. Furthermore, the persistence
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or rise in contaminant concentrations in some monitoring wells may indicate the presence of additional
contaminant sources.
A more complete analysis of data should include data sharing between the Claremont Site and the Old
Bethpage Landfill Site. As the two extraction systems and monitoring systems address the same region, more
comprehensive plume maps and potentiometric surfaces could be generated if the data from both sites are
shared. This sharing of data is more relevant given the partial use of the Old Bethpage Landfill Site as the
second phase of the groundwater remedy.
The recommended data sharing and analysis would occur quarterly and would involve a few pages of
summarizing text as well as relevant tables and figures (including plume and potentiometric surface maps).
An initial cost of approximately $25,000 will be required for developing the template for the report,
generating the CADD drawings to be used with the figures, and analyzing past depth-to-water and water
quality samples. In addition, interpreting data on a quarterly basis and generating the accompanying reports
will likely cost $15,000 per year.
6.1.3 DEVELOP GROUNDWATER FLOW MODEL
The above recommendation for quarterly data analysis and reporting should incorporate continual evaluation
ofthe plume extent and capture zones. However, analysis ofthe present monitoring points forthe Claremont
Site alone may not be sufficient for these evaluations. Additional water quality data from the Old Bethpage
Landfill may provide the necessary information to determine the extent ofthe VOC plume, and specifically
the PCE and TCE plumes associated with the Claremont Site. Given the complexity ofthe subsurface water
use in the area (pumping from the golf course and from the remedies at the Claremont Polychemical Site,
Old Bethpage Landfill Site, and Fireman's Training Center Site) and the presence of multiple plumes, the
development of groundwater flow model may be warranted to analyze the capture zone and improve the
understanding of contaminant transport at the site.
If the domain ofthe model is sufficiently large, the hydraulic analyses it allows could also aid in evaluating
and potentially optimizing capture zones of other groundwater remediation sites in the area, primarily the
Old Bethpage Landfill Site and the Fireman's Training Center Site. In addition, if future monitoring or
extraction points are required for better resolution ofthe plume or the capture zone, lessons learned from the
model would help in identifying the preferred locations for these points. Funding for such a model could
potentially be shared among the three parties if the proper agreement were in place. The site managers
should check for an existing model (perhaps developed for the Old Bethpage Landfill Site). If such a model
is already developed and is of sufficient size and accuracy, an agreement to use and/or adapt this model may
prove more cost effective. A caveat may be required stating that the modeling or the results would not be
used to alter the agreement between the EPA and the Town of Oyster Bay regarding the partial use ofthe Old
Bethpage Landfill Site forthe second phase ofthe Claremont Site groundwater remedy. The recommended
modeling effort may require $50,000 in capital costs for model development and $20,000 in annual costs for
future updates based on comparison of model results to water level measurements over time.
6.2 RECOMMENDED CHANGES TO REDUCE COSTS
6.2.1 ELIMINATE METALS REMOVAL SYSTEM
Although the current operation ofthe plant does not include the addition of chemicals for metals removal,
the process water still travels through the two parallel metals removal trains. The use of these trains requires
onsite operators for maintenance and housekeeping and electricity for the feed pumps that transfer water
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from the equalization tank through the trains. In addition, samples are collected quarterly of the process
water from five locations in the metals removal system (two samples for each of the parallel trains and one
from the influent to the air stripper). If the metals removal system were bypassed or removed, the costs
associated with these three factors could be significantly reduced or eliminated. Without the metals removal
systems in place, the treatment facility is reduced to an air stripper with liquid phase carbon for polishing
and vapor phase carbon for the offgas. Such a system could operate unattended with weekly site visits by
an operator to check and maintain the system. As the plant operators currently conduct the quarterly
sampling events, labor for the reduced or simplified system should account for these sampling events. On
average, the monthly cost of labor could be reduced from the estimated $27,000 for the current system to
approximately $7,500 for a simplified system. In addition, a cost reduction of $750 per month for electricity
would be realized as two fewer 5-horsepower transfer pumps would be required. Reducing the associated
process monitoring may save up to $5,000 per year in analytical costs. Substantial capital costs would be
required for bypassing the metals system or removing it from the treatment facility. Excluding internal costs
associated with scoping and contracting the work, the RSE team estimates that this work may require
$500,000. This capital cost, however, would be compensated by savings of approximately $248,000 per year.
6.2.2 SIMPLIFY REMAINING TREATMENT PROCESS TRAIN
The air stripper is designed to treat 500 gpm, however, because the system operates in a semi-batch mode,
it operates intermittently at flows up to 800 gpm or more. As this temporary flow is higher than the designed
capacity, the air stripper at times is likely not operating at its peak efficiency. Despite repeated samples
showing the air stripper effluent below discharge standards the plant operators recently detected water with
15 ppb of PCE exiting the liquid carbon vessels. Decreased efficiency and reduced mass removal during
periodic flows of 800 gpm or higher through the air stripper coupled with fouling of the carbon could
potentially explain these unexpected high readings of the carbon effluent. It should be noted that although
effluent from the carbon units had a one-time PCE concentration of 15 ppb, this water was diluted below
the discharge limits in the treated-water storage tanks before reinjection to the subsurface.
On average, the air stripper alone has proven to effectively reduce contaminant concentrations to below
discharge limits, and in general, air strippers, when used within specifications, effectively and reliably treat
water to below discharge limits. During the first three months of plant operation the influent combined
concentration of PCE and TCE to the air stripper ranged from 700 ppb to 910 ppb and the concentration
exiting the air stripper and entering one train of the liquid phase carbon polishers ranged from 1.4 ppb to 6
ppb (2 ppb of PCE and 4 ppb of TCE). It should be noted that the higher effluent levels did not correspond
with the higher influent levels. That is, high influent concentrations (910 ppb) often showed low effluent
concentrations (1.4 ppb). The higher effluent levels may have corresponded to periods when the air stripper
was operated above its designed flow. The February 2001 process monitoring results indicate that the
combined PCE and TCE influent concentration to the air stripper was 440 ppb and the analogous effluent
concentration from the air stripper was estimated at 1 ppb. Thus, during multiple sampling events the air
stripper alone met discharge requirements and the process water did not require polishing with GAC.
Resetting the air stripper feed pumps to ensure flow through the air stripper meets the design specifications
should allow the air stripper to reliably meet discharge requirements without the aid of carbon polishing.
Thus, replacement of the carbon vessels can potentially be discontinued without comprising system
effectiveness for annual savings approximating $1,700 per month. In addition, with the carbon treatment
discontinued, four process monitoring points could be removed or replaced by a single monitoring point.
That is, the influent and effluent of each carbon vessel could be eliminated and a single monitoring point
could be used to sample the effluent of the air stripper before it blends with the water in the treated-water
storage tanks. The net elimination of three process monitoring points could save up to $3,000 per year.
Thus, annual cost savings from eliminating the carbon polishing could amount to approximately $23,000 per
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year ($1,700 x 12 months/year +$3,000/year). A further significant advantage of eliminating the carbon is
that there would be a reduction in labor hours as backwashing the carbon would no longer be necessary.
Excluding internal EPA costs for scoping and contracting the work, repiping the system may cost
approximately $25,000.
6.2.3 ELIMINATE UNNECESSARY PROCESS MONITORING
Even if the treatment system remains unchanged, five process monitoring points (two from each of the metals
removal trains and one from the air stripper feed tank) could be eliminated. As the metals removal system
no longer operates, these monitoring points provide no information necessary for effective operation of the
plant. Elimination of these five process monitoring points would reduce the number of samples per year by
20 and could possibly save up to $5,000 per year.
6.2.4 ATTEMPT TO ELIMINATE DISCHARGE REQUIREMENT FOR pH
The groundwater in the region around the Claremont Polychemical Site is approximately pH 5 to 5.5.
However, the current discharge permit requires plant effluent to have pH 6.5 to 8.5. Thus, significant
expense and potential hazards associated with transporting and using acid and caustic are associated with
changing the extracted groundwater pH from its background value. In addition, adjusting the pH is actually
detrimental as it contributes to the addition of sodium and chloride to the water. This expense and the
potential hazards could be eliminated if the discharge requirement for pH is relaxed by NYSDEC, and this
should be requested. An annual savings of $24,000 per year in chemicals alone is expected if approval is
granted by NYSDEC.
6.2.5 CONSIDER REMOVAL OF THE VAPOR PHASE CARBON TREATMENT
Approximately 2.5 pounds of combined TCE and PCE are removed from the groundwater via the air stripper.
Thus, approximately 2.5 pounds of these contaminants would enter the atmosphere in the absence of vapor
phase carbon treatment. If the risks associated with this emission level are sufficiently low the vapor phase
carbon treatment could be eliminated if allowed by NYSDEC and considered appropriate by US EPA. In
addition to eliminating potential replacement of this carbon (cost savings not estimated), it also eliminates
the need for the offgas blower and heater which could translate to annual savings of up to $5,000 per year.
Site managers indicate that data from the monitoring of the influent and effluent of the vapor phase carbon
unit will determine if the vapor phase carbon unit can be eliminated
6.2.6 OPTIMIZE TREATMENT FACILITY AT THE OLD BETHPAGE LANDFILL SITE
A substantial cost savings to both EPA and the Town of Oyster Bay would likely result from optimization
of the Old Bethpage Landfill Site treatment facility. Current estimates by EPA suggest that reimbursing the
Town of Oyster Bay for 60% of the OBL operating costs will cost EPA approximately $1.2 million per year.
This suggests that the annual operating costs for the OBL facility are approximately $2 million per year. In
reading the annual and quarterly reports for the OBL treatment facility, the RSE team identified a number
of potential cost-reducing opportunities but cannot confirm these opportunities or quantify the savings
without visiting the facility and interviewing the operators. The most significant cost-reducing opportunities
may include reductions to onsite labor. For example, the RSE team noted that the system is staffed 24 hours
per day in order to record hourly flow and pressures through the air stripper. As air strippers typically
operate unattended with only weekly visits, this 24-hour staffing appears excessive. In addition, 11 VOC
samples are analyzed per week at onsite laboratory while the State only requires one monthly influent and
effluent result. The required number of VOC samples could likely be sent to an offsite laboratory for
analysis at a lower expense than the costs required for maintaining and operating the onsite laboratory.
19
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Due to the potential for cost savings to EPA and other parties involved with the OBL system, the RSE team
recommends an optimization evaluation of the Old Bethpage Landfill treatment facility. Estimated potential
cost savings from an RSE for the OBL system have not been quantified.
6.3 MODIFICATIONS INTENDED FOR TECHNICAL IMPROVEMENT
6.3.1 REPLACE THE FAULTY INFLUENT FLOW METERS
The influent flow meters have lasted less than two years. The expected lifetime of these meters is much
longer than two years, suggesting they should be replaced by the manufacturer at no additional cost. Site
managers indicate the faulty influent meters were replaced subsequent to the RSE visit.
6.3.2 MONITOR VAPOR PHASE CARBON UNIT INFLUENT WITH A PID
Currently, the plant operator measures the concentration of the vapor phase carbon effluent with a PID and
does not measured the influent concentration. VOCs have not yet been detected in the effluent of the
operational unit; however, the PID may not be able to detect even the influent concentration. A PID
measurement of the vapor phase carbon influent would serve as a scientific control for the measurement of
the effluent. If no discernible difference is apparent between the influent and effluent measurements, the
operators will be unable to determine the appropriate time to replace the vapor phase carbon or to switch
which vessel is being used.
The treatment plant removes approximately 2.5 pounds of VOCs per day. Given a design flow rate for the
air stripper of approximately 2,700 cubic feet per minute this translates to a VOC concentration of
approximately 2 ppm in the air stripper offgas or vapor phase carbon influent. A well calibrated PID should
be able to detect this concentration. If the PID cannot adequately detect this influent concentration and the
vapor phase carbon treatment is not eliminated from the treatment train (Section 6.2.5) the PID should be
recalibrated or samples of the influent and effluent may need to be periodically analyzed in an offsite lab.
6.3.3 DETERMINE CAUSE OF THE PRESSURE BUILDUP OF THE LIQUID PHASE CARBON UNITS
If the liquid phase carbon treatment is not eliminated (Section 6.2.2), the liquid phase carbon units should
be analyzed to determine the cause of the pressure buildup. It may be chemical or biological fouling. A
possible source of chemical fouling may arise when the pH rises through the air stripper causing metals in
the water to become insoluble and precipitate thereby partially plugging the liquid phase carbon units. To
determine what fraction of the material is biomass, the backwash should be analyzed for total suspended
solids (TSS) and volatile suspended solids (VSS). If it is a chemical precipitate, lowering the pH as it leaves
the stripper may correct this problem. To estimate how much to lower the pH and to determine the potential
for chemical and biological precipitates to form, a complete cation/anion analysis should be done for the
water entering the carbon units. The analysis should include the following parameters: pH, carbon dioxide,
oxidation reduction potential, total dissolved solids, total suspended solids, total organic carbon, dissolved
oxygen, common anions (chloride, fluoride, nitrite, nitrate, sulfite, sulfate, bicarbonate, carbonate), common
cations (calcium, magnesium, manganese, potassium, ferric iron, ferrous iron). This should not cost more
than $200 to $300.
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6.4 MODIFICATIONS INTENDED TO GAIN SITE CLOSE-OUT
6.4.1 BASED ON AQUIFER DATA CONSIDER APPROACHES TO ADDRESS HOT SPOT WELLS
The site managers may find it beneficial to address the contamination "hot spots" after further analysis of
the groundwater quality monitoring data, water-level measurements (and associated potentiometric surface
maps), and potential groundwater modeling studies. Primarily, the "hot spots" refer to the 4,200 ppb PCE
concentration detected in SW1 and the 4,200 ppb TCE concentration detected in EW-4C during the February
2001 sampling event. Although these hot spots may be captured by the current extraction system they are
located over 200 feet from the nearest extraction well. Thus, a substantial amount of time will be required
to transport the contamination from either of these locations to the extraction system. Furthermore, if sources
of VOCs remain in either of these locations, it will significantly increase the duration of the remedy. Further
analysis of the aquifer data and the trends of the concentrations in these two wells will help indicate the
appropriate remedy which may involve temporary or long-term pumping from these wells or in situ treatment.
6.5 DONATE UNUSED EQUIPMENT
The filter press has not been used and could be transferred to another Fund-lead pump-and-treat system.
Also, if the recommendations in Section 6.2 are implemented additional equipment may be unused at this
site. If the specifications of the unused equipment meets the specifications of the equipment needed at other
Fund-lead sites, the unused equipment should be transferred to those sites to reduce overall expense to US
EPA.
USAGE operates a program to help relocate unused equipment associated with Fund-lead groundwater
remedies to sites where the equipment is needed, and the site managers are encouraged to contact the
program. The contact person is Lindsey Lien who can be reached via the following contact information.
Lindsey Lien, PE
USAGE, CENWO-HX-G
12565 West Center Road
Omaha, NE 68144-3869
(402) 697-2580
6.6 SUGGESTED APPROACH TO IMPLEMENTATION
Because some of the above recommendations may be contingent on the successful implementation of other
recommendations, consideration should be given to the order in which the recommendations are pursued.
Of primary importance are the recommendations to ensure effectiveness. Converting the depths-to-water to
water levels (6.1.1) should occur immediately. Once this has been achieved, analyzing aquifer and
operations data (6.1.2) along with delineating the plume and analyzing the capture zone (6.1.3) can be
pursued. Other recommendations that can be implemented immediately without conflicting with the
recommendations from 6.1 include eliminating excess process monitoring (6.2.3), attempting to eliminate
or relax the discharge requirement for pH (6.2.4), and optimizing the Old Bethpage Landfill treatment
system (6.2.6). The recommendations fortechnical improvement (6.3.1 through 6.3.2) are low cost and can
also happen immediately.
21
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The other recommendations for cost reduction (6.2.1, 6.2.2, and 6.2.5) and the recommendation to help gain
site closeout (6.4.1) should be considered after adequate data interpretation and a capture zone analysis have
occurred (6.1.1, 6.1.2, and 6.1.3). These recommendations to ensure effectiveness may reveal additional
data about the contamination "hot spots" and may also require increased pumping or additional wells.
However, once effectiveness is ensured and strategies for addressing the "hot spots" have been considered
and evaluated, recommendation 6.2.1 should take precedence followed by 6.2.2 and possibly 6.2.5. If
substantial delays are expected in implementing the effectiveness recommendations (6.1), it may be cost-
effective to implement recommendations 6.2.1 and 6.2.2 immediately, with appropriate engineering solutions
to address potential future re-use of the bypassed components.
Although the liquid phase carbon units may eventually be eliminated, determining the cause of pressure
buildup in those units (6.3.3) is inexpensive and may save significant money in the future.
22
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7.0 SUMMARY
In general, the RSE team found a well-operated treatment system. The observations and recommendations
mentioned are not intended to imply a deficiency in the work of either the designers or operators but are
offered as constructive suggestions in the best interest of the EPA and the public. These recommendations
have the obvious benefit of the operational data unavailable to the original designers.
Several recommendations are made to enhance system effectiveness, reduce future operations and
maintenance costs, improve technical operation, and gain site close out. The recommendations to enhance
effectiveness include converting depth-to-water measurements to water-level measurements, analyzing
quarterly the collected aquifer and process data, delineating the plume in conjunction with data from the Old
Bethpage Landfill Site, and analyzing the capture zone (perhaps with the aid of groundwater modeling).
Recommendations to reduce costs include removing or bypassing the unused metals removal system and
reducing the associated labor, eliminating liquid phase carbon polishing for volatile organic compounds,
attempting to relax the pH discharge requirement, eliminating unnecessary process monitoring, investigating
potential elimination of the treatment for the air stripper offgas, and optimizing the above-ground treatment
facility of the Old Bethpage Landfill Site which is partially funded with money from the Claremont
Poly chemical Site. Recommendations for technical improvement include replacing faulty influent flow
meters and improving the monitoring program for the air stripper offgas treatment (if it is not eliminated),
and determining the fouling cause of the liquid phase carbon units (if they are not eliminated). Finally,
recommendations regarding site closure include addressing "hot spots" of contamination after interpretation
of aquifer sampling data.
The table below itemizes all of the recommendations and provides feasibility-study level estimates for costs
(or cost savings) and reasons for each one. Details of the recommendations and the derivation of the cost
estimates are provided in Section 6.0.
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Table 7-1. Cost Summary Table
Recommendation
6.1.1 Convert depths-to-water to
water levels, survey if necessary
6.1.2 Interpret process data and
quarterly aquifer data, report results
6.1.3 Delineate plumes and analyze
capture zone (potentially with
groundwater modeling)
6.2.1 Eliminate unused metals
removal system
6.2.2 Simplify system
6.2.3 Eliminate unnecessary
process monitoring (also included
in 6.2.1)
6.2.4 Attempt to relax pH discharge
standard
6.2.5 Investigate eliminating the
vapor phase carbon treatment
(redundant if 6.2.2 is implemented)
6.2.6 Optimize above-ground
treatment facility of the Old
Bethpage Landfill Site
6.3.1 Replace faulty influent
flowmeters (under warranty)
6.3.2 Sample with a PID influent as
well as effluent for vapor phase
carbon unit
6.3.3 Determine the cause of the
pressure buildup of the liquid phase
carbon units
6.4.1 Address "hot spot"
contamination after analysis of
aquifer data
Total
Reason
Effectiveness
Effectiveness
Effectiveness
Cost
Reduction
Cost
Reduction
Cost
reduction
Cost
reduction
Cost
reduction
Cost
reduction
Technical
improvement
Technical
improvement
Technical
improvement
Gain site
closeout
Estimated Change in
Capital
Costs
$1,000
$25,000
$50,000
$500,000
$25,000
$0
$0
$0
Not
quantified
$0
$0
$300
Not
quantified
$601,300
Annual
Costs
$2,000
$15,000
$20,000
($248,000)
($23,000)
($5,000)
($24,000)
($5,000)
Not
quantified
$0
$0
$0
Not
quantified
($258,000)'
Lifecycle
Costs *
$61,000
$475,000
$650,000
($6,940,000)
($665,000)
($150,000)
($720,000)
($150,000)
Not
quantified
$0
$0
$300
Not
quantified
($7,138,700)'
Lifecycle
Costs **
$33,000
$267,000
$372,000
($3,496,000)
($346,000)
($81,000)
($387,000)
($81,000)
Not
quantified
$0
$0
$300
Not
quantified
($3,556,700)'
Costs in parentheses imply cost reductions.
* assumes 30 years of operation with a discount rate of 0% (i.e., no discounting)
** assumes 30 years of operation with a discount rate of 5% and no discounting in the first year
1 Total cost savings do not account for the costs associated with 6.2.3 and 6.2.5, because the costs associated with those
two recommendations are included in 6.2.1 and 6.2.2, respectively.
24
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FIGURES
-------
FIGURE 1-1: THE CLAREMONT POLYCHEMICAL SUPERFUND SITE AND THE SURROUNDING AREA.
J ~ ,'" \\ •• ' \ •--, ti ,'• I
4? '•- V ' ?' '/'' \
^i( L
i)W ila"^;)-' i\^^
"5 / ::'^4i T^^a,1^* » ^-"^^3^-=
#"" ' * 0-1• *J] s N$S"-*^Tr,
•1^ ' fx >*'JI«t\lK4< I! Ml « <;:A«i
=^~J.O .
;Wip *
•• t'.s%"tf^^i-' ^w>V.'-j>- ~ • 11 ~
J"?? "N,
V
, Old
^ Lan*«»
- - frf?r^i Su pert u n d S ite
'•"
/ r"
Claremont
Polyehemseal
-i Superfund
' Substat
N '.' S^TE UNIVERSITY
AND
ST
.T. ^
••' M ff^&fcray- • ; •.-•'
County j"'
Firemen's
Training [°
2000
SCALE IN FEET
(Note: This figure is adapted from the USGS topographic map, Huntington Quadrangle,
7.5 minute series.)
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FIGURE 1-2. SELECT WELL LOCATIONS FOR THE OLD BETHPAGE LANFILL SUPERFUND SITE, THE NASSAU COUNTY TRAINING CENTER,
AND THE CLAREMONT POLYCHEMICAL SUPERFUND SITE.
LEGEND
A CLAREMONT EXTRACTION WELL
S> CLAREMONT MONITORING WELL
C CLAREMONT REINJECTION WELL
® OLD BETHPAGE LANDEILL
RECOVERY WELL
• OLD BETHPAGE LANDEILL MONITORING
WELL REEERRED TO IN THE RSE REPORT
BETHPAGE
STATE PARK
/SW1/DW1 /EW6A-C
«® ,"
/«ft /
EX-3X-\.\ EW4A-C ;
® V V "^— K,
FW9A — P \ \ EW—5 x^
\SW2/DW2 CLAREMONT
eiN-1
eiN-2
N-4C t> IN-3
c/i
5ITE
RW-4
(Note: This figure is adapted from Figure 6 of the Report on the Extent of Capture and Treatment of the
Claremont Site Plume, LKB Inc., August 1997).
SCALE IN EEET
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FIGURE 1-3. THE CLAREMONT POLYCHEMICAL SITE INCLUDING SELECT WELLS, SITE BUILDINGS, AND THE FORMER SPILL AREA.
N
A CLAREMONT EXTRACTION WELL
CLAREMONT MONITORING WELL
._._ EORMER SPILL AREA
(Note: This figure is adapted from drawings 03-CR-3 and 03-CR-5 from the 100% Final Design Submittal, Phase 1 Remedial Design Plans, Claremont
Polychemical Corp., Old Bethpage, New York, U.S. Army Corps of Engineers, Kansas City District, 1994).
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Solid Waste and
Emergency Response
(5102G)
542-R-02-008n
October 2002
vwwv.clu-in.org/rse
www.epa.gov/tio
U.S. EPA National Service Center
for Environmental Publications
P.O. Box 42419
Cincinnati, OH 45242-2419
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