United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R02-93/198
March 1993
PB94-963825
SEPA Superfund
Record of Decision;
Robintech/National Pipe, NY
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R02-93/198
3. Recipient's Accession No.
THIt and Subtitle
SUPERFUND RECORD OF DECISION
Robintech/National Pipe, NY
Second Remedial Action - Final
5. Report Date
03/30/93
6.
7. Author(s)
8. Performing Organization Rept. No.
9. Performing Organization Name and Address
10 Project Task/Work Unit No.
11. Contraet(C) or Grant(Q) No.
(C)
(G)
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report & Period Covered
800/800
14.
15. Supplementary Notes
PB94-963825
16. Abstract (Limit: 200 words)
The 12.7-acre Robintech/National Pipe site is a light industrial facility located in
Vestal, Broome County, New York. Land use in the area is predominantly industrial,
residential, and recreational with an estimated 5,350 people living within a one mile
radius of the site. The facility is situated in a regionally important industrial
center adjacent to Binghampton, NY in the Susquehanna River basin. The Susquehanna
River is located one-half mile north and west of the site; however, the site does not
contain or impact any ecologically significant areas. The site overlies two aquifers
that are used as water supplies, however there are no private water wells in the
vicinity of the site. In 1966, Robintech Inc., constructed the main building that
currently exists onsite. The first floor of the building was used to manufacture
aircraft engine mounts and automobile accelerator cables, while the second floor housed
an assembly area for electronic cable. In 1970, the first floor activities were
replaced with polyvinyl chloride (PVC) pipe extrusion operations. Since that time, and
until 1991, successive owners of the site have used the facility for PVC pipe extrusion
operations. Prior to 1983, municipal water was used as cooling water. After 1983, when
10 production wells were installed onsite, ground water was used as cooling water
during the extrusion operations. Wastewater from the process was released onsite under
(See Attached Page)
17. Document Analysis a. Descriptors
Record of Decision - Robintech/National Pipe, NY
Second Remedial Action - Final
Contaminated Medium: None
Key Contaminants: None
b. Identifiers/Open-Ended Terms
c. COSATI Field/Group
18. Availability Statement
19. Security Class (This Report)
None
20. Security Class (This Page)
None .
21. No. of Pages
132
22. Price
(SeeANSI-Z39.18)
SM Instructions on Riveras
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
Department of Commerce
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EPA/ROD/RO2-93/199
Robintech/National Pipe, NY
Second Remedial Action - Final
Abstract (Continued)
a discharge permit issued by the State. In 1984, the State detected organic constituents
at levels above permitted standards in a wastewater effluent sample. Further
investigation indicated that onsite ground water used in the extrusion process was the
source of the contamination in the effluent. In 1987, EPA required a detailed site
investigation, which confirmed the presence of organic contaminants in ground water and
indicated the presence of lead at levels above Federal cleanup standards in soil and
sediment. However, because of inconsistencies in the data associated with lead levels in
soil and sediment, the site was separated into two OUs. A 1992 ROD addressed the ground
water, surface water, and air, as OU1. This ROD addresses the soil and sediment, as OU2.
Soil and sediment sampling conducted by EPA prior to 1987, as well as confirmatory
sampling conducted after the detailed site investigation, indicated that onsite levels of
lead were not above Federal cleanup standards, and that the data set containing the
elevated levels of lead was erroneous. Based on the results of the confirmatory sampling
and the subsequent evaluation of the potential threats to human health and the
environment, previous activities at the site have not impacted onsite soil or sediment/-
therefore, there- are no contaminants of concern affecting this site.
The selected remedial action for this site is no action. EPA has determined that the
levels of lead at the site are below the Federal cleanup level of 500 mg/kg and the
potential human health risk for exposure to soil and sediment are within EPA's acceptable
limits.
PERFORMANCE STANDARDS OR GOALS:
Not applicable.
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ROD FACT SHEET
SITE
Name: Robintech, Operable Unit 2
Location/State: Vestal, Broome Co., New York
EPA Region: II
HRS Score (date): 30.76 (6/86)
NPL Rank (date): Not Applicable
ROD for OU-2
Date Signed: March 30, 1993
Selected Remedy for OU-2
Soil and Sediment: No Action
Capital Cost: N/A
O & M: N/A
Present Worth: N/A
LEAD
Enforcement, PRP Lead
Primary Contact (phone): Mark Granger (212-264-9588)
Secondary Contact (phone): Melvin Hauptman (212-264-7681)
WASTE (OU-2)
Type: Lead (Suspected).
Medium: . Soil and Sediments.
Origin: Unknown, suspected erroneous data: of
200 samples collected to verify elevated
concentrations none of Site-related data
was elevated
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RECOUP or DECISION
ROBINTECH, INC./NATIONAL PIPE CO. SITE
OPERABLE UNIT 2
TOWN OF VESTAL
BROOMS COUNTY, NEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AOENCY
REGION II
NEW YORK
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Robintech, Inc./National Pipe Co. Site, Town of Vestal, Broome
County, New York.
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Robintech, Inc./National Pipe Co. Site (hereinafter, the
"Site" or the "Robintech Site"), Operable Unit Two (OU-2),
located in the Town of Vestal, Broome County, New York, which was
chosen in accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA),
42 U.S.C. SS 9601-9675, as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA), and the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR
Part 300. This decision document explains the factual and legal
basis for selecting the no action remedy for OU-2 of the Site.
The New York State Department of Environmental Conservation
("NYSDEC") concurs with the selected no action remedy. A letter
of concurrence from NYSDEC is attached as Appendix III to this
document.
The information supporting this no action decision is contained
in the Administrative Record file for the Site. The
Administrative Record file index is attached as Appendix V.
Description of the Selected Remedy: No Action
The United States Environmental Protection Agency (EPA) has
determined that no action is necessary for the suspected lead
contamination of Site-related soil and sediment at the Robintech
Site. EPA bases this decision, in part, on the Remedial
Investigation (RI) report dated September 1991; Appendices A and
D of EPA's 1987 RI Work Plan; as well as the EPA reports entitled
"Skate Estate Soil Sampling Investigation" dated March 1992;
"Report on Suspected Lead Contamination in Surface Soils,
Subsurface Soils, and Sediments" dated December 1992; and "Soil
Sampling Investigation, Robintech Site" dated December 1992.
Confirmatory sampling of the suspected Site-related lead
contamination of soil and sediment was conducted in both February
and September 1992. The concentrations of lead in Site-related
soil and sediment were found to be acceptable for protection of
human health and the environment. Thus, "No Action" is the
selected remedy for the second operable unit for the Site.
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Declaration Statement
In accordance with the requirements of CERCLA, as amended, and
the NCP, EPA, in consultation with the State of New York, has
determined that the suspected lead contamination of soil and
sediment at the Robintech, Inc. /National Pipe Co. Site does not
pose a significant threat to human health or the environment and,
therefore, remediation of the Site-related soil and sediment is
not necessary.
The alternative selected for the first operable unit of the Site
will result in contaminants remaining on-site above health based
limits until the contaminant levels in the aquifer are reduced
below MCLs. CERCLA requires that this action be reviewed at
least once every five years after commencement of the remedial
action, and every five years thereafter, to ensure that the
remedy continues to provide adequate protection of human health
and the environment.
.
'
William J. Mu^yngXixpffE. Date
Acting Regional Administrator
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TABLE OP CONTENTS
I. SITE NAME, LOCATION AND DESCRIPTION ........ 1
IX. SITE HISTORY AMD ENFORCEMENT ACTIVITIES ...... 2
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION ....... 3
IV. SCOPE AND ROLE OF RESPONSE ACTION ......... 3
V. SUMMARY OF SITE CHARACTERISTICS .......... 4
VI. SUMMARY OF SITE RISKS ............... 7
VII. STATE ACCEPTANCE ................. 9
VIII. COMMUNITY ACCEPTANCE ............... 9
IX. DESCRIPTION OF THE "NO ACTION*1 REMEDY ....... 10
Z. DOCUMENTATION OF SIGNIFICANT CHANGES ....... 10
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX III. HY8DEC LETTER OF CONCURRENCE
APPENDIX IV. RESPONSIVENESS SUMMARY
APPENDIX V. ADMINISTRATIVE RECORD FILE INDEX
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I. SITE MAKE. LOCATIOM AMP DESCRIPTIOM
The Robintech Inc./National Pipe Co. Site (hereinafter, the
"Site1* or the "Robintech Site1*) is located at 3421 Old Vestal
Road in the Town of Vestal, Broome County, New York (see Figure
1). Vestal, with a population of 27,238 (U.S. Census, 1980), is
located within a regionally important industrial center adjacent
to Binghamton, N.Y. in the Susquehanna River basin. An estimated
5,350 people live within a one mile radius of the Site. A Site
location map is included in Appendix I as Figure 1.
The Site occupies 12.7 acres, and is bordered by Commerce Road
and several warehouses and light industrial buildings to the
east; Old Vestal Road and several residences to the south; an
amusement facility (known as the Skate Estate) and fuel storage
tanks (Mobil Tank Farm) to the west; and by Conrail railroad
tracks and Parkway Vending Inc. to the north. The Site is
located approximately half-way down the westerly face of a hill
that slopes gently toward the Susquehanna River. Consistent with
this, EPA field observations and examination of topographic
contours indicate that the superficial (overland) flow of surface
water across the Site is to the west, controlled by a series of
conduits and drainage ditches which direct the flow to the river,
located approximately a half mile to the north and west. A Site
layout map is included in Appendix I as Figure 2.
The area has two distinct aquifers which are sources of water
supply. The upper aquifer is comprised of the overburden
material above bedrock. This material consists mainly of gray
and brown till which becomes harder with depth. In addition,
fill material associated with extensive grading on-site for
parking spaces and storage ranges from 0-6 feet. Groundwater was
encountered within the upper aquifer unit 6-20 feet below the
ground surface. The lower aquifer is shale bedrock with a
weathered zone 7-10 feet thick. The primary permeability of this
material is low but the secondary permeability is much higher.
Fractures along the horizontal bedding planes and vertical joints
in the shale allow for groundwater flow. Groundwater was
encountered in this zone 10-60 feet below the ground surface.
Groundwater flow in the study area is primarily toward the west,
with minor components trending to the northwest and southwest,
and is recharged from rainfall. There are no private drinking
water wells in the vicinity of the Site. All residents are
supplied with drinking water by the Vestal public water supply
system.
The area where the Site is located is not known to contain any
ecologically significant habitat, wetlands, agricultural land, or
historic or landmark sites which are impacted by the Site.
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In 1966, Robinson Technical Products, Inc. constructed the main
building that currently exists at the Site. The first floor of
the building was used for the manufacture of aircraft engine
mounts and automobile accelerator control cables. The second
floor was used for the assembly of electronic cable. In 1970,
Robinson Technical Products was renamed Robintech, Inc., and
first floor production activities were replaced with PVC pipe
extrusion operations. Between 1966 and 1979 the present pipe
staging area was paved in four successive stages to the north.
The warehouse was constructed in 1974. Ten production wells were
installed on-site in 1983 to supply cooling water for the PVC
pipe extrusion process. Pipe production had previously relied on
municipal water for this purpose.
The Site was bought by Buffton Corporation, the current owner, in
1982, and was occupied by its subsidiaries National Pipe Company
(National Pipe) and Electro-Mech, Incorporated (Electro-Mech).
Electro-Mech has continued the assembly of electronic cable on
the second floor of the facility located at the Site. National
Pipe continued the PVC pipe extrusion operations until 1991, when
substantially all of National Pipe's assets were sold to LCP
National Plastics, Inc. (LCP). LCP is currently occupying that
portion of the plant at the Site that previously was used by
National Pipe.
An effluent sample collected in 1984 by The New York State
Department of Environmental Conservation ("NYSDEC") to verify
discharge permit compliance found certain organic constituents
above standards that were not covered under the existing permit.
Further investigation resulted in the conclusion that the source
of contamination was coming from the groundwater beneath the
Site. This groundwater was being pumped from the newly installed
on-site production wells, used as cooling water in the PVC pipe
extrusion process, and then discharged at the permitted effluent
point. The Robintech Site was placed on EPA's National
Priorities List (NPL) in 1986. An Administrative Order on
Consent (AOC) for a Remedial Investigation and Feasibility Study
(RI/FS) was issued in 1987 to General Indicator Group, Inc. (a
successor of Robintech), Buffton, Buffton Electronics
(subsequently renamed Electro-Mech, Inc.), and National Pipe
Company. McLaren/Hart, retained by Buffton, implemented the EPA
approved work plan. The RI Report was approved by EPA in October
1991. The FS Report was approved by EPA in March 1992.
In response to inconsistencies of data associated with levels of
lead in soils and sediments, the Site was separated into two
operable units (OUs), or phases, on February 12, 1992. The first
OU (OU-1) addressed groundwater, surface water and air; the
second OU (OU-2), which is the subject of this ROD, addresses
Site-related soils and sediments suspected to be contaminated
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with lead. Only groundwater was found to be of concern for OU-1.
A Record of Decision (ROD) was issued on March 30, 1992 which
calls for the pumping of groundwater from three on-site locations
to an air stripper and discharge of the treated groundwater to
the facility's permitted outfall. Treated groundwater may be
used in the facility's production process before being discharged
to the outfall, if so desired. Depending on contaminant load, air
pollution controls may be added to the treatment system. EPA
issued a Unilateral Administrative Order (UAO) to Buffton
Corporation and Electro-Mech, Inc. on September 29, 1992,
requiring those companies to conduct the groundwater remedial
design and remedial action (RD/RA). The RD is expected to be
completed in the Fall of 1994.
III. Hlfi^tfTCgTB OF COMMUNITY PARTICIPATION
EPA is basing the no action decision for suspected lead
contamination of Site-related soils and sediments, in part, on
the Remedial Investigation (RI) report dated September 1991;
Appendices A and D of EPA's 1987 RI Work Plan; as well as the EPA
reports entitled "Skate Estate Soil Sampling Investigation" dated
March 1992; "Report on Suspected Lead Contamination in Surface
Soils, Subsurface Soils, and Sediments" dated December 1992; and
"Soil Sampling Investigation, Robintech Site" dated December
1992. These and other significant documents, as well as the OU-2
Proposed Plan for the .Site were released to the public for
comment on December 31, 1992. These documents were made
available to the public in both the OU-2 Administrative Record
file and information repositories maintained at the EPA Docket
Room in the Region II New York City office and at the Town of
Vestal Public Library located at 320 Vestal Parkway East, Vestal,
New York. The notices of availability for these documents were
published in the Binqhamton Press & Sun Bulletin on December 31,
1992. A public comment period was held from December 31, 1992
through January 30, 1993. A public meeting was held on January
12, 1993 at the George F. Johnson Memorial Library in Endicott,
New York. At this meeting, representatives from EPA presented
the findings of the comprehensive analysis of all data collected
since 1985 as it relates to lead in Site-related soils and
sediments and answered questions from the public about the Site
and the no action remedy under consideration. Responses to the
comments received during this comment period are included in the
Responsiveness Summary, which is attached to this ROD as Appendix
IV.
IV. SCOPE AND ROLE OT RESPONSE ACTION
This ROD focuses on EPA's selection of a no action decision for
the Site-related soils and sediments. As noted previously, a ROD
was issued on March 30, 1992 for OU-1. The OU-1 ROD calls for
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the pumping of groundvater from three on-site locations to an air
stripper and discharge of the treated groundvater to the
facility's permitted outfall. Treated groundvater may be used in
the facility's production process before being discharged to the
outfall, if so desired. Depending on contaminant load, air
pollution controls may be added to the treatment system. EPA
issued a Unilateral Administrative Order (UAO) to Buffton
Corporation and Electro-Mech, Inc. on September 29, 1992,
requiring those companies to conduct the groundvater remedial
design and remedial action (RD/RA). The RD is expected to be
completed in the Fall of 1994. This action vill reduce the
threat to the environment by removing contaminated groundvater
from the aquifer and reducing or eliminating the threat to human
health and the environment of groundvater contaminant migration
from the Site.
Based on EPA's analysis of data generated as relevant to OU-2,
and on EPA's Risk Assessment and other supporting documentation,
the Site-related soils and sediments do not pose a threat to
human health or the environment.
V. SUMMARY OP SITE CHARACTERISTICS
of Soil and Sediment Data as Related to OU— 2;
Under the supervision .of EPA, sampling of sediment, surface and
subsurface soils, air, surface vater and groundvater vas
conducted by McLaren/Hart during the RI. As mentioned
previously, groundvater, air and surface vater vere addressed as
part of the OU-1 ROD and, as such, are not addressed in the OU-2
ROD. Further information related to OU-1 may be found in the OU-
1 Administrative Record file.
The topography in the vicinity of the Site slopes primarily to
the vest and to a lesser extent to the north. Surficial soils
that vere suspected of being disturbed or revorked during
construction activities vere classified as fill. Typically,
these materials vere encountered to a maximum depth of 6 feet
belov ground surface. The composition of the fill is similar to
other surficial soils encountered on-site.
Several volatile organic compounds (VOCs) vere detected in soil
in the northern portion of the paved pipe staging area of the
Site at levels belov concern. Levels of semi -volatile
contaminants in this area are associated vith the asphalt paving.
The only VOC detected in on-site sediment samples vas 1,1,1-
trichloroethane ("1,1,1-TCA") . Reported values ranged from 14 to
28 parts per billion ("ppb") . No Federal or State standards
exist for contaminants in sediment.
Based upon the McLaren/Hart data set from the RI report, lead in
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on-site and dovngradient soil and sediment was the sole
contaminant of concern. Soil and sediment samples analyzed by
McLaren-Hart shoved lead levels exceeding the EPA interim lead
cleanup level of 500-1000 ppm in 24 of 64 samples collected down
to a depth of 10 feet. Elevated concentrations ranged from 2,000
to 56,000 ppm. In addition, a small off-site area located on the
Skate Estate property displayed elevated lead levels in surface
soil. All other reported lead values from this data set were
below 100 ppm. EPA conducted confirmatory split sampling at
several locations at the time these samples were collected. The
EPA split samples failed to confirm the elevated lead
concentrations. Concentrations for the EPA split samples ranged
from 12-61 ppm. RI data summary tables are included in Appendix
II (see Tables 1 thru 3). EPA's split sample data summary tables
are included as Tables 4 and 5. In addition, a map of split
sample and RI sampling locations can be found in Appendix I as
Figures 3 and 4.
S'MTHTnary of Other Soil and Sediment Data as Related to OU— 2;
Two other sets of data, one before the McLaren/Hart RI and one
after, were collected by EPA and included over 250 samples
analyzed for lead and other compounds.
EPA initiated sampling events in July 1985 as part of developing
an RI/FS Work Plan for the Site. These events are summarized
(including maps of sampling locations) in Appendices A and D of
the 2/10/87 RI/FS Work Plan developed for EPA by CDM-FPC, an EPA
contractor. This document is included in the Administrative
Record file for the Site. A total of five sediment samples at
four locations were collected as part of this investigation.
McLaren/Hart split three of these samples with EPA. All eight
analyses were below 80 ppm for lead. Of 58 subsurface and
surface soil samples collected both on- and off-site, all were
below 50 ppm for lead, with the exception of one reported value
of 143 ppm from a sample collected from a drainage ditch located
in the extreme northern portion of the Site between the paved
pipe-staging area and the gravel lot area. Maps of sampling
locations associated with these events can be found in Appendix I
(see Figures 5 thru 7). Data summary tables can be found in
Appendix It (see Table 6).
In response to the elevated detections of lead in the Skate
Estate surface soils reported in the McLaren/Hart RI data, EPA
tasked its Environmental Response Team (ERT) to determine if the
property qualified for a removal action. The assessment,
initiated in February 1992, analyzed 155 surface soil, subsurface
soil and sediment samples associated with the Skate Estate
property and, to a lesser extent, the western perimeter of the
Site. Three background samples were collected at nearby
locations unassociated with either the Skate Estate or Robintech
properties. Analysis was by portable X-Ray Florescence (XRF)
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methodology. XRF methodology is a truck mounted field screening
analytical method which generates real-time data. In addition,
21 split samples were lab-analyzed using Contract Lab Program
(CLP) methodology to provide confirmation of XRF sampling data.
The McLaren/Hart soil and sediment sampling locations associated
with elevated lead detections were duplicated as closely as
possible. Results indicated 120 samples below 50 ppm, 26 samples
within 50-100 ppm, 4 samples within 100-150 ppm, and 3 samples
within 200-250 ppm (or 153 out of 155 samples below 250 ppm).
One detection was recorded at 344 ppm, well below the EPA interim
cleanup level of 500 ppm for lead in soil. A single detection of
2,550 ppm was recorded in the off-site background location and is
considered anomalous. This detection was recorded in a location
described by ERT as being characterized by "historical disposal
of household debris and automotive waste materials, including oil
cans and used oil filters.1* The split samples, analyzed by CLP
methodologies, confirmed the accuracy of the XRF samples.
In September 1992 a second sampling event was initiated by ERT to
reanalyze areas where elevated detections of lead had been
indicated by the McLaren/Hart data set in an effort to confirm
the validity of that data. The original locations were checked
against known landmarks and confirmed by the EPA Project Manager
for the Site. In the case of the McLaren/Hart subsurface soil
borings, the original bore holes had been grouted to grade with
concrete and were especially easy to locate. A total of 39
samples were collected from 16 relevant surface soil, subsurface
soil, and sediment RI-related locations. Analysis was by
portable XRF methodology. Where an elevated detection had been
made during the course of the McLaren/Hart sampling rounds in a
particular horizon, samples were collected down to that horizon
using a drill rig. All but 2 of the 39 samples collected were
below 50 ppm and all samples recorded lead values below 100 ppm.
Split samples analyzed in the lab using CLP methodologies
confirmed the accuracy of the XRF sampling results. All 10 of
these lab samples were below 50 ppm.
A more detailed discussion of these sampling events, including
maps of sampling locations, can be found in Appendices A and D of
EPA's 1987 RI Work Plan, as well as in the EPA reports entitled
"Skate Estate Soil Sampling Investigation" dated March 1992;
"Report on Suspected Lead Contamination in Surface Soils.,
Subsurface Soils, and Sediments" dated December 1992; and "Soil
Sampling Investigation, Robintech Site" dated December 1992.
Data summary tables can be found in Appendix II (see Tables 7
thru 9). Maps of sampling locations associated with these events
can be found in the EPA reports entitled "Skate Estate Soil
Sampling Investigation" dated March 1992 and "Soil Sampling
Investigation, Robintech Site" dated December 1992. These
documents may be found in the Administrative Record file for the
Site.
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Although the exact reason is not apparent, a comprehensive
analysis of all sampling data collected since 1985 for the Site
indicates that the McLaren/Hart data set is erroneous and
inaccurate as it relates to reported lead values in soil and
sediment.
VI. SUMMARY Of BITE RISKS
EPA conducted a Risk Assessment to estimate the health and
environmental risks of all potentially affected media at the
Site. The Risk Assessment began by selecting indicator chemicals
which would be representative of Site risks. These chemicals
were identified based on factors such as potential for exposure
to receptors, toxicity, concentration and frequency of
occurrence. These contaminants included VOCs, semi-volatiles,
and metals in various media.
The Risk Assessment evaluated the health effects which could
result from exposure to contaminated or potentially contaminated
media including groundwater, surface water, air, surface and
subsurface soils, and sediment. Risks associated with
groundwater, surface water and air are the subject of OU-1 and as
such are not addressed as part of this ROD.
The results of the Baseline Risk Assessment are contained in the
Draft Final Risk Assessment. Robinteeh. Inc./National Pipe Co.
Site dated February 1992 and prepared by Alliance Technologies
Corporation under contract to EPA. This document is included in
the Administrative Record file for the Site.
Current federal guidelines for acceptable exposures are a maximum
health Hazard Index (HI) equal to 1.0 and an individual lifetime
excess carcinogenic risk in the range of ICT* to 1CT6 (or »
1:10,000 to 1:1,000,000). The Hazard Index reflects
noncarcinogenic health effects for an exposed population and is
calculated by dividing the chronic daily intake of a chemical by
the daily dose believed to be protective of human health
including sensitive sub-populations. If the HI exceeds one
(1.0), there is a possibility of adverse health effects.
For soil and sediment, the exposure pathway demonstrating the
greatest risk was ingestion of on-site soils by a trespasser.
This risk value (1.0 x 10's) is, however, within the target
carcinogenic risk range of 10*4 to 10"6 discussed above and in the
NCP. Risk for this scenario was due primarily to PAHs which were
detected in a single sample underlying the pavement. None of the
His exceeded 1.0 for soils or sediments. Quantifiable risks,
therefore, have been determined to be insignificant.
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It should be noted that EPA has temporarily withdrawn the
toxicity values used to quantitatively evaluate risks associated
with lead exposure in soil and sediment. In the meantime EPA has
set an interim cleanup level of 500 to 1,000 ppm for the maximum
allowable concentration of lead in soil in residential areas.
This range is designed to protect sensitive sub-populations
(i.e., children). While the Site and most of the surrounding
area is zoned for industrial use, this range has at times
provided a basis for remedial action at industrial sites as well.
For the Robintech, Inc./National Pipe Co. Site, the lower and
more protective value of 500 ppm is considered the threshold
value. Employing this value at the Site affords an added layer
of safety.
The 500 ppm threshold value was significantly exceeded in Site-
related soils and sediments from one of the three data sets
collected for the Site (i.e., the data set collected as part of
the McLaren/Hart RI). As summarized previously (see "RI Summary
of Soil and Sediment Data as Related to OU-2" and "Summary of
Other Soil and Sediment Data as Related to OU-2" sections,
above), data collected before the McLaren/Hart data set, split
samples collected concurrently with the McLaren/Hart data set,
and data collected in response to the McLaren/Hart data set have
failed to detect even a single elevated concentration of lead in
Site-related soil or sediment. The 2,550 ppm value reported in a
background sample and discussed on Page 6 of this ROD was not
collected from soil or sediment related to the Site. A
comprehensive analysis of all sampling data collected since 1985
for the Site indicates that the McLaren/Hart data set is
erroneous and inaccurate as it relates to reported lead values in
soils and sediments. Therefore, based on the data sets relied on
by EPA in evaluating Site conditions, there is no significant
human health hazard due to Site-related lead levels in soils and
sediments.
In terms of environmental risk, it is important to consider that
the area where the Site is located is not known to contain any
ecologically significant habitat, plant and animal species, or
wetlands. Though no measurable evaluation criteria are available
to quantify and assess potential environmental risk, it should be
noted that, from a qualitative perspective, the threshold value,
designed to be protective of children (who are extremely
sensitive to lead exposure), by extension would be protective of
most environmental receptors. Thus, children as an indicator
species combined with the absence of sensitive ecological factors
leads to the conclusion that there are no significant
environmental risks due to Site-related lead levels in soils and
sediments.
8
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Areas of Uncertainties
The procedures and inputs used to assess risks in this
evaluation, as in all such assessments, are subject to a vide
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. Environmental chemistry analysis
uncertainty 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
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 mentioned previously,
lead is currently undergoing a toxicological reevaluation. while
issues of toxicological uncertainty are being resolved, EPA has
established an interim soil cleanup level (500-1,000 ppm) as
protective of the most sensitive sub-population, that being
children.
VII. STATE ACCEPTANCE
The State of New York concurs with EPA's selected no action
remedy. Their letter of concurrence is attached as Appendix III.
VIII. COMKUNITY ACCEPTANCE
The community had a few questions about the no action remedy.
Inquiries generally regarded lead concentrations present in Site-
related soils and sediments. EPA addressed these questions at
-------
the public meeting and assured those present that the lov lead
concentrations in Site-related soils and sediments did not
require action. In general, the community appeared satisfied
with the no action remedy. All comments that were received from
the public during the public comment period, including all
questions and comments raised during the public meeting, are
addressed in the Responsiveness Summary attached as Appendix IV.
II. DESCRIPTION OF THE "HO ACTION" REMEDY
Based upon the review of all available data and the findings of
the RI conducted at the Site, a no action decision for OU-2 of
the Site is protective of human health and the environment. The
no action decision complies with Federal and State requirements
that are legally applicable or relevant and appropriate to the
remedial action and is cost effective.
A comprehensive review of all data collected at the Site
indicates that there are no concentrations of lead in Site-
related soils and sediments above the 500 ppm threshold value.
As such, there is no significant threat to human health or the
environment due to Site-related lead levels in soils and
sediments.
1. DOCUMENTATION OP SIGNIFICANT CHANGES
There are no significant changes from the preferred alternative
presented in the Proposed Plan.
10
-------
FIGURES
-------
BASE MAP IS A PORTION OP THE FOLLOWING 7£" U.S.G.S. QUADRANGLES:
ENDICOTT, NY, 1969; BINGHAMTON WEST, NY, 1976
1000 2000 3000 fMt
OUAO>UNOL£ LOCATION
LOCATION MAP
LOCATION OF THE ROBINTECH, MCJNATIONAL PIPE CO. 8TTE
VESTAL, NEW YORK
Figure 1.
-------
N
LJ
LEGEND
---- PROPCRTV 80UMVWV
— sromi SCWCR
— — ORMMCC «1CM
R RCSOCNCC
B BUSINCSS
• PRODUCTION WCU
SCALB IN FEET
240
120
FIGURE 2
SITE LAYOUT
NATIONAL PIPE. VESTAL. NY
-------
O Monitoring We* Location
Qj] RetMano* • Sol Boring Location
|¥] BuskwM 0 Sediment Samptng Location
O Fu^StoragaTank • Manhote
Storm Water Sewer
Fence
Property Boundary
Oralnaganicti
SITE LAYOUT INCLUDING SOIL BORING. SEDIMENT
SAMPLING. AND MONITORING WELL LOCATIONS
ROBMTECH, WC7NATIONAL PIPE CO. SITE
VESTAL, NEW YORK
Figures
-------
MHI&
KOMCK WCUSMC OCVOMMCO
mi -»" rOUOMNG INC Mil IJIMK>
Ml fWOOUCIMM «U1S MH M
or f»-i» MV KOKKH «
SOIL AND CROUNDWATCR SAMPUNC
LOCATIONS
NATIONAL PIPE. VESTAL. NY
-------
-------
N
VXMOXXS VMM •ZtTOUCAL
noToouns
f
l
8
I
o
o
-------
H
• snaGWi«**B*B* •*»*«!• i i
*n>rexl»ittly 10* JVC flf«
K Aksvt Ston $«vtr Cttcb tetia
IS* «14« frceact Oaaenta
Carfcec ftnia^t ffctbwj
Utek Bwimi.
Sopla Aaibtr fed toeatiw
««tUl-«»Mta
100
Seeie
ftet
COM
flgur* 7 •
10BINTECR/KATXQNAL PIPE CO. SITE
CHLARCDIEMT OF SURFACE SOIL,
SEDIMENT AMD UATEH SAMPLING LOCATIONS
ZN SV SITE AKEA
-------
APPENDIX
TABLES
-------
TABLE 1
SUMMARY OF SOIL ANALYTICAL 1ESULTS
METALS AND CYANIDE
NATIONAL RPE, VESTAL, NY
BORING NUMBER
DE7TH(FT)
DATE
11
2-4
4-20-11
•I-D
a-4
4-20-tt
•1
•-10
4-20-11
B2
2-«
4-21-U
B2
4*4
4-21-U
•2
»-10
4-21-U
B2A
4-6
4-21-U
•2A-D
4-6
4-21-M
B2A
•-10
4-21-U
B2B
3-4
4-21-U
B2B
«-«
4-21-U
METALS
Alttmmwn
Aetimoey
Annie
Iviiia
B«yO>uB
Ctd&18&
Ctldsa
Chromium
Cebdt
Copper
IfOB
lad
M*fnetium
Muiaacac
Merewy
Hided
ntftmuBB
Sclcnha
MVB
Sodium
ThiUim
Vaaidius
Zfec
15.719
-
•
2I.3Q
.
-
3.4)4
-
l».4
26.4
26.764
29
4.091
711
0.10)
24.3
923Q
•
2.4
133Q
•
.
«6.0
11.925
.
.
-
042Q
-
141
»
.
20.3
22.114
25
3,182
435
O.OSI
41.7
472Q
.
UQ
93. 1Q
l.»Q
.
•1.1
5.515
.
.
.
.
.
21.139
.
27.1
19.1
13.912
10.4J
2,617
C72
QMJ
16.6
SS3Q
-
UQ
50Q
-
11.9
45.2
NA
MA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
7,110
.
.
29.9Q
.
•
2,297
-
-
12.1
15.131
21.4J
1JOO
425
0.24J
12.1
271Q
-
-
60.7Q
-
-
50.4
C.692
.
-
-
.
•
129Q
-
.
11.6
14.940
12.100
1.693
2S6
0.05Q
15.0
237Q
-
-
67.1Q
-
-
93.9
1,0*0
.
-
42.7
-
•
2,145
-
-
20.4
16.111
31J
1.S31
S34
0.167
16.1
441Q
-
-
II6Q
.
.
41.1
6.692
-
r
S6Q
.
-
1.719
•»
-
14.3
12414
26J
1J76
451
. 0.1U
11.4
301Q
-
-
I9.6Q
•»
19.7
r.i
•.944
-
-
S2.7Q
.
-
1.711
-
-
17J
16.611
24
2.060
172
040)
16.2
»1Q
•
-
SS.1Q
-
•
47.4
6.160
V
-
«
•
-
13.263
•
•
77.2
10.169
15.600
3,117
461
O.MQ
13.7
295Q
•
UQ
93.3Q
-
-
774
10.205
•
•
•
-
-
354Q
-
•
19.3
16.038
7.270
3.210
405
0.05Q
22.1
156
0.44
14Q
67.3Q
-
-
67.7
ICYANPE
-------
TABLE 1
SUMMARY OF SOS. ANALYTICAL RESULTS
METALS AND CYANIDE
NATIONAL PIPE, VESTAL, NY
BORING NUMBER
DEPTH (FT)
DATS
B2B
•-10
4-2i-u
13
J-4
4-20-U
•3
4-6
4-20-U
B4
2-4
4-14-41
•4
•-10
4-14-U
BS
0-2
4-1441
B5
4-6
4-14-tt
BS
6-1
4-14-U
BS
1-10
4-14-U
B6
0-2
4-14-U
B6
4-6
4-14-U
METALS
AlBBtaa
Artoay
Amok
Bnfea
BtryUiaa
<-,~l..i~-
Ctfdaa
Ckieolaa
Cetoh
Ccppw
Irao
L^
MT—'°IB .
MtflflM*
fttecoy
Nkfcd
PoUMua
Main
SOvcr
Serfiaa
TbiQius
Vaudiaa
Zte
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
12.192
.
.
22.4Q
.
.
9.206
-
>
15.9
24.224
31.2J
4.66*
771
0.02)
29.7
I30Q
-
.
144Q
-
I0.9Q
77.2
91.034
.
.
137J
.
.
6.960
>
-
20.4
20.795
2U
1.752
112
O.MJ
r.7
1JS2
-
2.1
I40Q
.
-
120.7
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
10.300
.
13.00
42.1
0.02
11.3
2,190
-
-
12.2
M.JOO
1.620
1400
411
0.10
•2.0
765Q
•
.
1S2Q
-
—
•4.7
13.000
.
-
22.6Q
•
O.OIQ
54JOO
-
•
11.7
29.100
13.4J
5.610
533
OJ4
37.1
994Q
-
-
1S5Q
-
-
aj
10.900
-
i07
42.9
-
3.49J
1.600
-
-
17.9
26.100
10.700
3.240
•59
0.10
54.0
760Q
-
•
I69Q
•
«
61.3
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
13100
•
-
61.4
-
1U
4*70
•
-
1S.6
26.100
37
3.400
365
0.10
37.2
•SIQ
-
•
203Q
-
-
69.6
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
I NAl -I -I NA I -I -I -I NA I
NA
.NAj
-------
TABLE 1 (cGBtaaedQ
SUMMARY OF SOIL ANALYTICAL RESULTS
METALS AND CYANIDE
NATIONAL PIPE, VESTAL, NY
10WNG NUMBER
DEPTH (FD
DATE
•6
»-10
4-14-41
•7
2-4
4-14-tt
•7
4-6
4-M-ll
17
«-•
4-14-41
•9
2-4
4-15-11
99
4-6
4-15-tl
BIO
*4
4-15-11
•10
4-«
4-15-11
•11
4-6
4-lt-St
•11-D
4-6
4-lt-lt
•12
2-4
4-n-n
METALS
JJnyfrttMK
Antimony
Anaic
Itriua
•ejylliuffl
Cftd&itt&
Catena
Chranina
Cebih
Copper
1m
Lwi
Mtponia
Mutism
Mcnny
Nickd
PotftvinB
SBC&IU&
Sflver
Sodiua
Thallium
Vaaiditn
Zinc
10,300
-
-
42.0
-
ft
5.560
-
-
11.9
21.600
9.600
3.900
342
0.09
66.3
676Q
-
-
449Q
-
.
71.2
NA
NA
NA
MA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.050
.
-
29 JQ
•»
1.6V
14.300
-
-
25.2
19,000
9,400
5,100
167
0.07
52.1
946Q
-
-
IflQ
-
.
56.3
7.550
.
.
504
-
0.90Q
40.500
-
-
15.6
15.100
100
4.630
S19
.
14.1
4I1Q
-
-
66.6Q
.
-
50.6
10.400
-
-
C5.5
-
1.2
4.600
-
-
19.4
21.200
14
2.600
Ml
0.02Q
61.7
455
-
-
99
-
-
47.9
10.900
.
-
43.0
-
1.1
2,0*0
•
.
25.0
23.900
19
3.240
914
0.03Q
17.1
691Q
-
-
40.2Q
.
-
62.6
9.310
-
-
4S.7
•
3.7
1.660
-
-
20.1
22.700
22
3,040
495
0.07
26J
560Q
-
-
56.3Q
.
-
57.2
11,700
-
-
27 JQ
•
5J
1.290
-
-
12.9
35.700
22
107Q
11
0.07
37.2
1S.1Q
-
-
129Q
-
-
61.2
11^00
^
.
30.9Q
-
2.0
1050
.
.
12.6
32.900
17,900
3.040
393
0.07
34.5
956Q
-
-
126Q
-
-
70.0
17.700
-
-
«OJ
•
205.0
1.660
•
-
14.4
22.200
22.200
1010
462
0.42
16.6
1.010
•»
-
157Q
-
-
77.1
I »1 HA] NAl -I -T -I -I
•Net
mat aatfyud
-------
TABLE 1
SUMMARY OF SOIL ANALYTICAL RESULTS
METALS AND CYANIDE
NATIONAL PIPE, VESTAL, NY
IBORIHG NUMBER
[DEPTH (Fo
{DATE
•13
«-t
4-19-tt
BU
4-6
4-19-11
•15
a-4
4-19-U
•16
4-6
4-20-tl
•1?
0-2
4-25-tl
•11
0-2
4-25-tt
•19
0-2
4-2S-U
•20
0-2
4-25-tl
METALS
AludBBD
AauBMy
Amok
•vita
BoyOaB
Ctdofan
OUin
CbofflJM
Cob.lt
COR«
free
UK)
Mtpate .
MOSUMC
Moray
Nfckd
frfrrfi rriiiM
mURUB
M«iaa
SSvtr
tedium
niCioffl
V«a*diaa
Zhe
6.336
-
-
23.6Q
•
-
S13Q
.
.
-
14.106
2S
1,276
169
0.11J
I«Q
240Q
-
-
151Q
-
lt.1
25.0
12,3*4
.
.
42.4
.
^
96t
.
.
.
11.463
22
I,t9t
915
0.04)
tJQ
-------
TABLE 2
SUMMARY OP SOIL ANALYTICAL RESULTS. METALS AND CYANIDE
NATIONAL PIPE, VESTAL. NY
MMUNONUMBE*
MW-7
MW-4D
MW-II
MW-12
MW-M
MW-IS
n-t
m.i
DETTHflT)
0-10
MM2
•-10
15-17
4-4
4-5
5-t
DATE
9-13-M
0-30-U
0-31-M
9-n-u
f-l-M
MBTALS
1(1111
4.UO
Tl.30
XJI
S.SO
4.1S
J0.4Q
11.7
JO.*
W.M
17.11
J4.JI
JS.7I
Ft?
M.I
W.I
12.1
41.9
I7.J
11.4
11.0
11.4
11.7
M.I
25.100
11.1
W.JOO
IJ.JOO
I5.MO
IS.100
M.OOO
M.IOO
17.000
7U
401
31*
200
324
297
2M
0.11
2.91
1.71
5.71
13*
2.27
2.31
2.43
2.47
J4.7
21.5
11.9
J5.IQ
II.4Q
1.7IQ
I0.2Q
S.WQ
3.70Q
•50
•77
517
I.400Q
I.400Q
Tttl
I.040Q
Til
j.O«OQ
I.I70Q
I.HOQ
0.731
OJ2
0.99
133
till
Mil
1211
IUI
•.0
IJ.J
4«.4
44.T
53.4
49.* 43.1
43.*
52.5
49.1
JlL
O.ll I
CMW-0
D
Q
I V*Mba««
R DM MM to i
-------
TABLI>
SUMMARY OP SEDIMENT ANALYTICAL IESULTS
NATIONAL WE, VBSTAL, NY
^AMB|C Alt
4-J7-U
•D-JD
4-r-u
D-2
4-a-u
4-2*»U
•D-4
4>2t-W
4-27>U
4-n-u
B&-*
4-a-u
S&-10
4-9-U
4-77-U
4-a-u
VOU7ILI OtOANia tell)
1 1 n«tinMflnii
T«bai
l.l.l-TrickloracUu*
XyhBQMl)
^TlTllUlhl
•
-
•
•
0
•ft
•BflVCCATBJt OMAMKP* to/fc)
M*0-&ferlteqr»ptakiliti
TICtN^ko*
•
•
15.400
4»
.
•
*
2
22
*
4
5.UO
*
4ft
12
*
e
.
1.400
11
45.400
.
2»X
.
U
7
1,0*1
4.400
21
401.100
»
»
M
4ft
0
•
2S.OOO
t
jo.no
.
.
17
4ft
0
•
-
M
104.100
•
•
•
•
0
•
45.000
U
144400
•
•
20
•
e
•
•
2.100
5
9400
-
-
•
•
0
•
•
>
7400
-
-
2*
-
0
-
2.000
0
-
10
-
-
-
0
-
-
t
55.MD
MRAU (Bt/kO
"— -TT
AKIMV
Anait
Btri«
^_^ji* ^_
Hiyunv
Ck4Bia
Ciki^
Ckrww
Crtifc
C^pv
Im
UU
MlfMfeM
MopBut
Mdoqt
Nitkil
Nuaivi
tttmim
titm
ttHm
ntUim
Vmtiim
Zte
S.01J
•
•
44.t
•
4ft
44.*t
•
•
I7.S
11JM
10.100
4.M*
M?
O.JQ
•J3Q
JJ3Q
4»
t.»0
M4
*
•
M».0
4.141
•
•
10.4Q
«
•
«JO
.
•
•
1IJM
41.100
s.n
4fl
OMQ
rnq
JJ4Q
4>
X1Q
74J
•
•
e.t
S.17I
.
.
»JQ
LKQ
»
M.OU
.
•
lt.7
17.1M
10.100
«.OM.«Q
m
»
JJQ
40S.IQ
•
-
UK
•
•
817
1.00
•
*
».7Q
•
U
8.0M.V
-
•
1M
Mjn
»J«J
4j»:
8>
-
•
4M.IQ
•
•
1W.1Q
*
4ft
1M.»
•.!<»
-
-
U.*Q
•
-
4».»IU
•
•
HI
14.097
BJMJ
*4J»
an
O.U
7.«IQ
41I.IQ
•
-
UOQ
4»
•
71.4
*.MO
•
•
l»-»Q
-
•
»JM
4»
*
M.<
it.vr
u.to
IJO
Mi
O.U
17.10
MOQ
•
J.70
•*4Q
4ft
4ft
1914
tfJ07
•
4ft
«.}
4»
»
1.B2
1.1
4
a.i
•.117
7JO*
4.4K
1.70J
-
21.40
tio
4ft
4J»
Mf.f
•
»
1444
UJM
•
-
lt.»Q
O.HQ
•
»
•
m
XJ
I4.7M
».ns
2.712
1.171
•
17.30
MJ»Q
-
IJ4
X4JQ
-
4ft
2M.O
10JM
4»
•
40.1
1JQ
-
1.1511
-
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224
a.M*
jt.nu
2,H>
MO
O.M
w.n
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4ft
4»
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13.121
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41 1Q
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1.41
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•
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ll.MO
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to
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27J4Q
•
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5M.5Q
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M.O
ll
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uxssttststssssitssststts
Mil 'MSu MS;i
TABLE 4
X SIUTCAKPLB
I**UtMUMMMMtMCMSMtttM»MM*MltlMnS*>UC*MtSSM«MS*«IS
K-2|i
fc'ulaia
tkreiiui
fcriu
ItrylUvt
Ctfiiut
CrtiH
CnpK
ttCrll
lltfir.ltl
VMItikl
::J«r
•stilt:.*
Sefui
•ipttict
ntoep woo P wiott r
14 EP 14 EP 1070 E*P
47 P I3SJP 2t40P
Il.DP {.31) P 19 IP
1.2 DP 1.2 DP 12 P
II.2J P ».ll P ffO I*PJ
22P
20300 P
22P
«20»*
2500CP 2.921 P
14JOOP
34.3 P
0.47 If
1.2 WP
11.3 IP
r.i r
WOO P
17 P
90P
It If
i;
*c»
.!* SXf)
C,«4jJ?
9.«4
yea.li
21? MSP 4.4 P
!OP IISi: > 2*5503 P
i: P ::so P 1:400 P
(415) P 22500 E?
F 2710 El
29.1 if
n EP
20.4 P
7^ UUP
'c.5P
0.1 KV
<}40P
t.lP
"iBP
S6P
731 P
IBP
14.7 Jt
77.: ^
I/
2.9 ^
2.: 2?
c.:;tv
124 P
46P
25.3 IP
1VP
9V
IV
12.3 IP
1110 P
47.1 P
41.3 J»
JB»
2C«
7I20P
12.3 P
J4.3 UP
1.31 IP
1.2 WP
A.9IP
23 P
11000 P
14.3 »MF
IMP
427 P
14 n
12.2 {»
».i i;f
7.2 IX"
2.0 U*
C.2VCV
«.C UN."
3ftOOP
14209 P
11400 P
27P
M4|P
2.2 IMP
13.1 IP
3!.4P
41400 P
41.3 P
3MJP
212 EP
:I.SP
24.4 S.*r
o.5o wr
0.14 UF
9.2 «V
3*400 P
119 V
4!10P
144 U*
4720 P
970 P
10 PU
700 PJ
1UP
9UP
19 DP
191?
2100 PJ
3C*
29 UP
1900 PE
U09 PE
2! 9
20*
45 3»
4l«
4.0 PK
0.2 WV
39 9.
IDP
940P
1IIP
9D>
ISP
1140 P
2.1 KJ*
15S9P
:.o^
0.2 KV
u u? 4.:. t\::
104000 »£ li:^» P
24009 PJ 27t;: P
11:00 PJ ir::P
0.43 U 0.44 U 10 U (.42 IMS 10.0 M
0.42 U4S 1.1 U*S 10 U 10.9 3
sim*nitustiitti
in
*M*«nsMm(tms**MMmm
wttd
8 IfJ:u:ti iJnrt m >»ilr:r< far lut Mi IttKtitf. Thi t»»ir ibe«n :» tJ* cttittiot Jiiit.
( J viui ii jrutK thie v fuil te imtrnM«t ftticticn l:«:t 4«t Itii V-K. Mm ewtrut tfitictiea ln;t.
I :n:er.u it Mtiutrtf »*:-» M U ptHKt •< mirfrtnt.
FM :wir»t« wiiriit tiiltt EPI BMlitr Asurtnci min.
-------
TABLE 5
Mima
NMWCMII
•mi MM tofU
iwniwmi
l mm unitMi
SMMtoM
! MlMH
llriNlf
tterlM
llmllta*
! tiMlta
! fait!*
1 MrMtai
: Mtii
IbfMY
t In*
tlMl
tbtmlw
I taMMM
Ifcrart
1 Metal
IMmlM
1 fclMtei
IlllWr
t Ml* .
! ttalltei
• VewtlM
tltac
: CIMIM
t
1
UK •.HIM
•nu
•10
7MM
M.MM
I.MI
If. Ml
I.MI
f.MI
MMM
If. Ml
II.MI
IMMI
H*.M
I.MI
NMM
I.MI
•.Ml
II.MI
MM.MI
l.tfl
M.MH
Mf.MI
I.MW
H.MI
iMt
M.MI
/
•Hit /
•fa Y
MM.M ^
M.MI
ff.M
HI.M
I.MI
I.MI
IMM.M
H.M
II.MI
If. Ml
MMf.MI
I.M
IMM.M
IMM*
•.Ml
n.Mi
HM.M i
I.MIM
M.MM
IMM.M 1
I.M MM
II.M I
Iff. Ml
M.MI
smwn f
•i>i> \ ,: •mi'
un ' 7*:«tiiV
' IIJM S M.«V-^
MM : D.MI
1.1 1 M I
M.I ; 1.1 1
f.JI 1 > I.M
1.1 i M I
im i »» •
if .1 : M •
H.I ! Ml
M.I : i.t •
JMM ! M.1 1
ii.i u : 1.1 1
MIM : iff i
m.i : • I.M
Ml U S •.» II
n.» : i*.* •
in*.* j : MI •
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I.I It f.M
in.* • t u« i
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H.I : IMI
M.* II t 1*1 J
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•
1
.^ "N.
CMf M. ItM) ^
••MM f\ i
-Uttt.tf S
i.**M :
I*.M i :
II.M t
f.tJI !
•.MM :
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II.M S
f.Mi :
II.M 1 !
I*M*.M t
I*.N H S
UM.M t
ni.M :
».!» I !
I*.N :
III.M w :
M*M :
I.MI :
II.M :
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II.M 1
M.MI :
i.i* • :
i
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•
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i :
: i
,
•
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j
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5
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j
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5
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1
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I
S
•
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•
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•
,
•
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t
i
•*••*•
-------
•MMBCN/MTKM. MMF OB. SHE
MM! WU. 9DMM . NO 3WMI *NL SMUS
MIIOML MR man
muwc Munir
MtMfc
JlMtg*
Ml Ml M Mt SO Ml
am* vnm Hum warn vsm tt»m n*m
HUM WM
U
u
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m.
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4
U
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M
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M
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M
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mm
m
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•
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M
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M
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Ml »•
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M
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Ml
kVJ
M
M
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m*
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MM
MtfJH MV.IS
M M
MVJS MVtl
M Ml
MMJM/^MV W^MM/il^P
M m
MV.M MAM
M M
ft
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MM MM
• M
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II
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M
W
xa»
M
tt
II
I*
IM
MB* BM 1MB MM
M -
NVJI mim
m M
MVJI MVJI
M»/U
M
M
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4
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14
II
IfN
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»
19
MI
•.MM
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•.01
M
Mt
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IN
m
HI
H
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m
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tl
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t.M
u««*>« *i«ttai IMI tenmai to rim
•• IMKttal IWU Mluta* ly Ift wrtyttl. ta-
•« Aw fill •tarM ta
tai to «rt I*M ttt Atadtai tMK «fftn
Mr Atattai IMI MI Mt (
34^7 f
-------
MU 6 (cont'd)
m c&sm
jurat so*, sums
iiMustt
PkA A^M ^^A ^^&^~^^^ ^ f^^
MM> •••MEHiW ••
• ••MKttai IWt Mutaf fcr l*Mlyito (M.. MWv • Ml)
M !!• IWt* 1t» 4HMIIM IWt Mt Ml
4-
03VMMI
•t wnMrattai taMutal< Wt ntoitai to
.ta» IWt f«r M> Mrtjnlt Mtfcn In* «• U*MT< *uato» IWt
toflrrtafcM.
MllfMiMlifrachtai
-------
6 (cont'd)
HBMBHNMRM. MC Ol SIC
UUMS sm. suits - SUMM ism
IMC*
MUSIS
JMMI SWMI SMMT JMMI S4MI
100
U-M
U-U
M
a
M)
u
41-41
U-U
U-2*
31-31
U-U
U
44
II
to
to
n
0»
n
39
II
M
H
U
II
a
M
I
U
an
u
in
ut
10
14
ai
4
IU
M
V
J
II
M
J
as
u
CM
10
a
IM
•
10
0
as
30V
m
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3LC«
3390B
M*
a
M
n
u
. a
UK
*»•
IK
M
IS
J
II
M)
M
10
a
10
j
IU
44*
M
•
a
M
10
»
U
ft
J
at
u
M
a
DM
t
341
a
M
Jut
m
a
ii
B»
m
•
a
M
u
a
n
11
41
at
CD
10
a
•4
u
10
at
______
llM IMt
to^MlfM (Ml pvfctai MH|
^^^^ ^^^^^^^^^^ v^^^^
OvlHnMllMt
-------
6 (cont'd)
IMC*
HIC OL m
MMS-IONM
MUSIS
3MUI JMMI MMt
Cttcta
n-a
u-u
t*-u
u-u
Ji-JI
**•
•
a
•
M
&•
M
M
mi
•
M
tt
U
a
••
ii
U
tt
a
a
a
a
a
a
n
u
*
M
U
tt
IM
a
a
301
M
M
J
tt
M
K
n
8
J
M
U
B
1MB
U
mi
u
m
a
a
M
M
41
J
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M
w
K»
U
•
V*
M
3J
a
ai
a
a
M
11
M
M
a
M
AS
M
WSI
a
a
a
j
•A
a
•
w
tt
A
J
a
a
30
»
a
n
a
M
a
u
w
M
«
a
a
a
a
a
a
o
a
US
3M
a
u
a
a
«K
a
a
o
a
a
u
a
M
IV
tt
IV
30
tfBtMt.
-------
TAIL! 6 (cont'd)
••Mitt to
otr ktltlM
•MINflCN/NATIONAL MFC CO. Sift
SMSIMFACC SOIL VMH.1% • UCSICM SECTION
IMMMMIC ANALYSIS
0*t«
NtKtlM
Malt*
)/•?/*•
SS-04-04 SS-OS-OI
SS-OS-OI
3/07/M
AtMlMa
AriMlc
0«rl«a
OtryltlW
CkrtalM
Ctktlt
lr«*
tta*
NMMtla*
Mircary
NUktl
Sllvtr
mi IlM
Tin
IlM
Cyaaltft
Mrctflt Mlltt
I.O-l.t
t.l-t.S
•at
t.4-3.1
33-3S
0.1-0.4
K
ss
NO
NO
IftM
14
It
t3
•010
NO
9.t
ISS
NO
NO
is
13
t.7
I4SOO
14
13400
NO
It
43
NO
NO
DIM
17
II
M
HMO
14
ItOOt
NO
0.»
33
I.I
NO
0740
13
It
n
303
ts
1040
NO
1.4
NO
NO
NO
17
13
J
M.t
ISM
IlM
NO
NO
M
NO
NO
It
40
J
M.7
MO
M
n
NO
NO
109
NO
NO
10
J
•I.*
9.7
43M
S44
NO
tt
044
NO
1.4
SS
• NO
NO
IS
73
•4.1
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31
17
tt
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n
13
a
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13
M)
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a
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ON
a
no
a
M
BJ
a
tt
a
«
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a
17
n
M
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a
a
HI
M
4M
431
10
9
no
31
N)
a
4U
10
«u
1*
400
n
40
•JJS
MM tMtjrtt* ftr Mt MM «tt
M Halt
tkt
ilt* llaltt l«tflC4tt4 kf l«k Mtlfttt (l.«.| tatlaMf • IN)
ftr tktM iMrtMlci cktvt tkt Halt, tkt rftttctltt Halt vat Mt 9!*
4 • CtatMM* It arcMflt kiit CMMt kt «jtattlflt4 «ltk trtcltlt* Mraal
••V'lKwVf)
tkat
1140/11)
-------
6 (cont'd)
UMNK M. SHIO - ttsam KHOI
MOMC MUSIS
II
•4
a
u
u
OB
N
U
a
19
4?
»
13
U
MB
M
39
•V
»
U
3S
t.l
IIM
14
».»
21
tt«M
14
Ml*
3*4
M
13
fit
•
t.l
U
M
M
•9.2
MI4tt
22
9.4
41
M
t.t
ISM
14
It
19
M3M
>••
M04)
US
M
2*
•IS
S*
14
•4
a
B
M
l»
m
»
M
II
41
U
U
M
Itf
a
M
•
•
43
»
»
M
U
AS
fcr Nut
AM *• IMt. ••
I Mt w»
-------
p«ge1 c'6
Sp«ctr»c* WOO (XRf) Uad Rtsutts in Soil
jr
AW*
Aiaes
A13W7
AUMB
ABM.
AUTO
A13770
AUK
AUMP
A1SB7
A137W
A13CI
Aum
A13B9
AW*
A13OO
A1S77»
A13KM
A137IO
Aim
Aim
Aiats
AI37B
A120
AW9
AtWM
ATWH
A1STD
AXKB
Ann
AU7M
Aism
AUDf
toeuiea /Depth
A- V
A- r
A- T
A- r
A- 4*
A- r
A- r
A- r
A- r
A- r
A- r
A-4 r
A-4 r
A-s r
A-S r
A-4 r
A-4 r
A-7T
A-7 «•
A-» r
A-4 r
A-» r'
A-* r
A-» r
A-ior
A_«» 9VBIUF\
— W •\i»W»J
A-M r
A-U r
A-U r
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A-n r
r»
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37
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V
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21
2)
22
4tf
2f
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41
41
51
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•
91
41
47
29
25
44
44
27
• >43
21
. 25
r
25
n
(Btte)
433
273
453
4*3
253
423
. 313
233
223
4«3
293
243
233
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413
Si 2
U
KD
213
413
473
293
253
44
443
Ǥ t
49 4)
273
433
. 213
253
17
253
-------
pcge 2 of 6.
I9- ':>\iC.«-.?.-:..
pCRF) tMd FuitsuttB In Soil
AUNI
AU7B
AU7V
AU07
AUTOS.
AUMt
AUMS
AU7S7
AU701
AU70I
AU7IO
AUK
Aum
AU»O
AU7B
AI37B
AUMf
AU7M
AUK
AUM7
A-O f
A-a r
A-ur
A-U r
.-M r
A-S42*
A-14 7
A-14 r
A-15 r
A-15 C
A-U r
A-17 r
A-U r
A-U r
A-U r
A-ur
,-u r
A-9 r
A-921CDUT)
1-9 r
>—a 2*
,-a r
A-a r
A<« r
•a r
A-a 3*
9
9
10
9
51
91
91
341
4*1
271
271
10
91
51
371
Ml
91
Ains
52
34
9
24
9
40
9
*2
99
40
39
9
37
17
41
51
11
91
241
401
91
99
401
99
91
371
S7J
221
91
411
51
ND
-------
page 3 of'
Uad Rtsutts in Soil
•Cn.'3?.v?.:s->:--w •:
• • •• :»-". A* f' •' • - '* -'.. ;
ki +*''&.**..£%£:£*'•:'?:
2:
Aim
AUM9
A1S797
AttSO
AisTM
AiaSl
A1S79J
A13852
AUMD
AUHD
A1300
Aim
A13I8
A13BM
AUMB
AUU5
AUK)
Aiasf-i
AlStSt-2
AUUt-3
Aim
A13B7
AUH5
A13t9
A1SHM
Fvvvvw
AW9
AUM
A1JM7
AUM4
AUM3
Aum
Aura
l^Mte/DiBb
^^^^^•w* ^rvy>^
A-23 T
A-34 r
A-34 r
A-3S r
A-25 T
A-K r
-2< r
-27 r
-27 2XDUF)
-2» r
-3t V
-2i r
-3i r
-2» r
-2» r
-jo r
-so r
-si r
-» r
-si r
-si r
t
-a r
-a r
-ar
-a r
-S4T
-J4 2TDUP)
-si r
A-a r
A-S5 «•
A-st r '
A-S< r
n
teite)
r
a
24
23
94
SS
a
M
IS
a
a
is
a
20
19
90
«5
53
49
44
a
a
24
43
27
U
17
f*
49
a
20
a
li
(•rtc)
rj
33 J
34 J
a;
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JSJ
aj
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ND
aj
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a)
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49 J
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43)
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-------
page 4 of 6
Spectrace 9000 (XRF) Uad Results In Soli
;*obint»ch^^j;?r;::^ "::
February. 1992
fa**
Aiar?
Aiar»
AUTO
AUHO
AUTO.
AU75t-l
A13T0-2
AW*-3
A137S
Aiaw>
Aiano
AUBI
AIMS
A13TM
AJS7S
A1S7JB
AUTO
A1379
Aians
A1S7B
A13JM
AUW4
AUKT
AUIU
A137S7
AUM7
Anm
xtm
AUHi
AUMI
A19MD
A1S9C
LaariBilPtpt
A-M y
A-S* r
A-M r
A-M 5"
A-M r
i-ssr
t-ssr
•-»«•
B-MT
•-M r
B-M7
•-M r
B-M IT
»-r r
i-» r
B-» C
B-40 <*
B-4i r
B-4i r
B-4i r
B-4i r
B-41 4*
B-41 4>
B-41 T
c-« r
c-« r
c-3
203
»J
SJ
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S4J
a»
21J
24 J
233
25 J
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ND
25)
4SJ
1YJ
54
B44
4B2
145
W
M
-------
page 5 of 6*
7(con't)
ftoutts in Son
AUTO
AUN4-1
AUfM-2
ABM4-S
ABNfel
AlSNt-2
A8M5
A1SW
A070
ASM
Aiani
AISB
AI3U3
A13H4
AUU5
C-50 r
c-5i r
c-5i r
c-5i r
c-a r
c-a r
c-a r
c-sj r
C-54 r
C-55 r
D-JC r
D-57 r
•5§ r
D-» r
E-« r
E-43 r
r
AOU9
E-45 r
r
r
-i
i
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F-» r
r
r
F-57 r
r
r
S4
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-------
APPENDIX in
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL
CONSERVATION LETTER OF CONCURRENCE
-------
New York State Department of Environmental Conservation
60 Wolf Road, Albany, N«w York 12233
MAR 1 2 1993
Thomas C. Jorllng
Commissioner
Mr. George Pavlou, P.E.
Acting Director
Emergency & Remedial Response Division
U.S. Environmental Protection Agency
Region n
26 Federal Plaza
New York, New York 10278
Dear Mr. Pavlou:
Re:
Robintech Site, Vestal, Broome County,
New York, Site No. 7-04-002
The Record of Decision (ROD) for the Robintech site operable unit No. 2 (OU2) was received
by this office on March 3,1993. Bom the New York State Department of Environmental Conservation
(NYSDEQ and the New York State Department of Health (NYSDOH) have reviewed mis document.
OU2 addresses she related contamination of soil and sediment suspected to be contaminated with
lead. The recommended alternative in mis ROD for OU2 is no action. This remedy was selected
because confirmatory data performed by the U.S. Environmental Protection Agency (USEPA) determined
that lead contamination is not present at levels requiring remediation.
By means of this letter, the NYSDEC and the NYSDOH concur with the remedy recommended
by the March, 1993 ROD.
If you have any questions, you may contact Mr. Robert W. Schick, P.E., of my staff, at
518/457-4343.
Sincerely,
Ann Hill DeBarbieri
Deputy Commissioner
Office of Environmental Remediation
cc: C. Petersen, USEPA
M. Hauptman, USEPA
M. Granger, USEPA
A. Carlson, NYSDOH
-------
APPENDIX IV
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
FOR OPERABLE UNIT 2
OF THE
ROBXNTBCH, INC./NATIONAL PIPE CO. 8UPERFUMO SITE
TOWN OF VESTAL, HEW YORK
Section Pao*
INTRODUCTION 1
I. OVERVIEW 2
II. BACKGROUND OH COMMUNITY INVOLVEMENT AND CONCERNS 3
III. SUMMARY OF QUESTIONS AND RESPONSES FROM THE
PUBLIC MEETING CONCERNING THE ROBINTECH, INC./
HATIOHAL PIPE CO. 8UPERFUMD SITE ..4
-------
RESPONSIVENESS SUMMARY FOR THE
ROBXNTECH, INC./NATIONAL PIPE CO. 8UPERFUND SITE
OPgRABLB UNIT 2
TOWN OF VESTAL, MEW YORK
INTRODUCTION
This Responsiveness Summary provides a summary of citizen's
comments and concerns and the U.S. Environmental Protection
Agency's (EPA's) responses to those comments and concerns regarding
the Proposed Plan for the Robintech, Inc./National Pipe Co. Site
("the Robintech Site" or "the Site"), Operable Unit 2 (OU-2). EPA,
in consultation with the New York State Department of Environmental
Conservation (NYSDEC), will make a final determination regarding
the proposed no action alternative for OU-2 of the Robintech Site
only after reviewing and considering all public comments received
during the public comment period.
EPA held a public comment period from December 31, 1992 through
January 30, 1993 to provide interested parties with the opportunity
to comment on the Proposed Plan for OU-2 of the Robintech Site. A
public meeting was held to discuss the investigatory history for
OU-2 of the Site and to present EPA's preferred no action
alternative. The meeting was held at the George F. Johnson
Memorial Library in Endicott, New York on January 12, 1993 at 7:00
p.m.
Community interest regarding the Site and EPA's Proposed Plan was
moderate. Questions on OU-2 were oriented toward clarification of
EPA's assessment of the total data set for soils and sediments and
there were several inquiries of a technical nature. Several
questions were raised regarding the status of the OU-1 groundwater
remedy. Approximately 15 people attended the meeting. The
audience consisted of local businessmen, residents, and state and
local government officials. The question and answer session lasted
approximately 40 minutes. A summary of the questions posed during
the meeting is provided in Section III, below.
This community relations responsiveness summary is divided into the
following sections:
I. OVERVIEWx This section briefly outlines the EPA's
preferred alternative.
II. BACKGROUND: This section provides a brief history of
community concerns and interests regarding OU-2 of the
Robintech Site.
III. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS,
CONCERNS AND RESPONSES: This section summarizes comments
received by EPA at the public meeting for OU-2 of the
Robintech Site.
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Z. OVERVIEW
At the time of the public comment period, EPA published its
preferred alternative for OU-2 of the Robintech, Inc. /National Pipe
Co. Site ("the Robintech Site" or "the Site") located in the Town
of Vestal, New York. EPA screened possible alternatives, giving
consideration to the following nine key criteria:
• Threshold Criteria, including:
~ overall protection of human health and the
environment; and
compliance with Federal and State
environmental laws.
• Balancing Criteria, including:
long-term effectiveness;
— short-term effectiveness;
reduction of mobility, toxicity, or volume;
ability to implement; and
cost.
• Modifying Criteria, including;
— state acceptance; and
~ local acceptance.
EPA weighed State and local acceptance of the remedy prior to
reaching the final decision regarding the remedy for OU-2 of the
Site.
The Agency's selected remedy for OU-2 is no action. This decision
is based upon the review of all available data and the Risk
Assessment. Based on a comprehensive review of all data generated
for the Site, a no action decision is protective of human health
and the environment.
This plan satisfies the threshold criteria for remedy selection and
obviates the need for long-term treatment and management.
-------
II.
Community concern has not been high regarding the Site-related
contamination of soils and sediments. It appears generally
understood that a full assessment of all data generated for the
Site indicates that the data upon which the suspicion of elevated
lead concentrations in soil and sediment had been based was
erroneous.
EPA's community relations efforts began in August 1986. At that
time a community relations plan (CRP) was formulated, including an
outline of community concerns and a comprehensive list of federal,
state, and local contacts. Also at that time, site information
repositories were established, one located at the EPA Region II
office in New York City and the other located at the Vestal Public
Library in Vestal, New York. The information repositories, which
contain the RI/FS Report and other relevant documents, were updated
periodically.
Revising and updating the CRP, including an updated outline of
community concerns and an updated contact list was initiated in
April 1991. The CRP was finalized on Nay 1,1992.
To obtain public input on the proposed remedy, EPA held a public
comment period from December 31, 1992 through January 30, 1993.
The EPA Proposed Plan, describing the Agency's proposed no action
decision for OU-2 of the Site, was sent to the information
repository and distributed to citizens and officials on EPA's site
mailing list for review at the opening of the public comment
period.
A public meeting notice appeared in the December 31, 1992 edition
of the Binahamton Press & Sun Bulletin, and a public meeting was
held on January 12, 1993. Community interest regarding the Site
and EPA's Proposed Plan was moderate. Questions on OU-2 were
oriented toward clarification of EPA's assessment of the total data
set for soils and sediments and there were several inquiries of a
technical nature. Several questions were raised regarding the
status of the OU-1 groundwater remedy. Approximately 15 people
attended the meeting. The audience consisted of local businessmen,
residents, and state and local government officials. The question
and answer session lasted approximately 40 minutes. A summary of
the questions posed during the meeting is provided in Section III,
below.
-------
ZZZ. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS, AND
CONCERNS, AND EPA1 8 RESPONSES
This section addresses comments received by EPA during the
public comment period (December 31, 1992 to January 30, 1993) .
The following verbal comments were from the public meeting
held at the George F. Johnson Memorial Library in Endicott,
New York on January 12, 1993, and are categorized by topic.
No written comments were received during the public comment
period.
Lead Copt *"i
Several comments and questions were received regarding the
perceived lead contamination at the Site. Throughout the
meeting EPA emphasized that a comprehensive analysis of all
data generated for the Site since 1985 indicates that there is
no lead problem in soils and sediments. Specific inquiries
and EPA's responses are summarized below.
1. Several citizens, including the Vestal Town Supervisor,
the Chairman of the Vestal Advisory Commission, and a
resident who lives within 100 yards of the site, inquired
about the levels and possible sources of lead at the
Site. The Town Supervisor suggested that numerous leaded
gasoline storage tanks which were used in Vestal from the
1940s to the mid-1970s may have been a potential source
of contamination. He also expressed concern about
improperly handled gasoline spills which occurred during
this period.
EPA Response. The highest lead concentration detected in
Site-related soils and sediments during EPA's two 1992
resampling events at the Site, which included the analysis of
over 200 samples, was 350 parts per million (ppm) with most
values under 100 ppm. The 2,550 ppm value reported in a
background sample and discussed on Page 6 of the ROD was not
collected from soil or sediment related to the Site.
Regardless of the history of the area, a comprehensive
analysis of all data generated for the Site since 1985
indicates that there is not a lead problem in soils and
sediments associated with the Site. This analysis further
indicates that the McLaren/Hart samples reporting extremely
high lead levels were in error.
2. A resident asked if EPA had considered the possibility
that facility activities had resulted in contamination
other than lead, particularly tin or oil. He reported
that circuit board printing, soldering, and processes
-------
involving hydraulic damping equipment have occurred at
the Site in addition to the manufacture of PVC pipe.
EPA Response. A historical search is conducted as a routine
step in the RI process. EPA reviews historical information
about a site in order to identify possible past sources of
contaminant release. Depending on what operations have
occurred at a site, different contaminants are more likely to
be found than others. At the Robintech Site, the risk
assessment for the Site (written by an EPA contractor) as well
as available Federal and State guidance values had indicated
that lead was the only contaminant of concern for soils and
sediments. The result of this finding was to create a second
operable unit to further investigate this suspected
contamination.
3. The Chairman of the Vestal Advisory Commission requested
clarification of the nature of the error associated with
the McLaren/Hart data. The Chairman went on to ask if
the error in calculation could be pinpointed.
EPA Response. Upon suspicion of an error in the McLaren/Hart
data, EPA requested McLaren/Hart to recheck their data
validation. McLaren/Hart reported that the data had been
validated properly. Still suspecting an error, the next step
was to request McLaren/Hart to recalculate their data from
scratch. When the data were recalculated, the results
differed from those originally reported by an order of
magnitude. Although this discrepancy was sufficient to
question the validity of the McLaren/Hart data as it related
to reported lead values in soil and sediment, EPA made the
decision to resample the exact locations, including the exact
vertical horizons, from where the McLaren/Hart samples had
been collected in order to ensure that no significant lead
levels existed at the Site. EPA collected new samples from
virtually all of the McLaren/Hart sampling locations where
elevated lead concentrations had been reported. Because most
of the Site is paved, suspected elevated lead concentrations
in the soil would have been unlikely to diminish between the
McLaren/Hart and the EPA sampling events. EPA's results,
which included collection and analysis of almost 200 samples,
did not indicate elevated lead levels in soil and sediment.
In terms of uncovering the exact nature of the calculation
error, it would be a very complicated and time consuming
endeavor to unravel the exact nature of such an error. EPA
opted to return to the sampling locations where elevated lead
concentrations had been reported (analyzing many more samples
in addition to these locations while in the field) rather than
pursue the exact nature of the calculation error. In this
way, EPA was able to produce tangible, reliable, and most
-------
importantly, timely evidence that the elevated concentrations
reported in the McLaren/Hart data set were in fact erroneous
and that conditions at the Site, with respect to OU-2, were
protective of the community.
4. A representative from the Broome County Health Department
asked about the results from background samples collected
near the Site during EPA's two 1992 sampling events.
EPA Response. Of the three background samples collected in
soil near the Site, one sample contained an elevated
concentration of lead. Since this sample was collected from
an area where it was evident that household refuse and motor
oil, cans, and filters had been disposed, this contamination
was not considered Site-related. Lead levels in the other two
samples were both under 100 ppm.
5. A citizen asked who had originally analyzed the
McLaren/Hart samples.
EPA Response. McLaren/Hart used Enviropact Services, Inc. to
analyze their samples.
6. The Chairman of the Vestal Advisory Commission asked
about the effects of lead on children who might come into
contact with soils when playing at the Site.
EPA Response. A comprehensive analysis of all data generated
for the Site since 1985 indicates that there is not a lead
problem in soils and sediments associated with the Site.
Further, this assessment indicates that the McLaren/Hart
samples reporting extremely high lead levels were in error.
In a hypothetical scenario involving lead contamination in
soils, a risk assessor would calculate risk by assuming
exposure to a certain amount of contaminated soils at a
certain frequency over a certain length of time. These
assumptions would depend on the age of the exposed individual,
the depth of the contaminated soils, and other factors. For
lead, EPA currently adheres to guidance that specifies a range
of 500-1000 ppm to protect human health. For lead in soils
and sediments this guidance range was designed to be
protective of children. The lower and more protective value
of 500 ppm was selected by EPA as a threshold value for the
Site.
Though the Site is not considered a source of risk as far as
lead is concerned, citizens are encouraged to contact the
local Health Department for more information should they be
-------
interested in learning more about the risks associated with
lead-related exposures.
7. The Town Supervisor asked if lead concentrations in soil
could contaminate the vater supply; he also asked if
there are any safe levels of lead in drinking vater.
BPA Response. A comprehensive analysis of all data generated
for the Site since 1985 indicates that there is not a lead
problem in soils and sediments associated with the Site.
Further, this assessment indicates that the McLaren/Hart
samples reporting extremely high lead levels were in error.
Hence, EPA has concluded that there is not a source of lead in
Site-related media that would contribute to groundwater
contamination. Please note that Site-related ground water
will be retested for metals (including lead) before being
treated, as metals may interfere with the operation of the air
stripper.
EPA has established an action level for lead in groundwater of
15 parts per billion (ppb) . Simultaneous filtered and
unfiltered samples were collected from all monitoring wells
during the course of the RI. Sampling results from two
unfiltered samples were slightly above the action level (MW-
10, 23.5 ppb/MW-ll, 29.2 ppb). Results from the corresponding
filtered samples from these monitoring wells, however,
indicated no lead present whatsoever. For the remaining
groundwater samples most lead results indicated that no lead
was present. For the few detections of lead reported in
groundwater, all were at or below 10 ppb.
8. Several citizens asked if EPA would conduct any future
sampling or monitoring of soils at the Robintech Site.
EPA Response. EPA has completed its investigation of
suspected soil and sediment contamination at the Robintech
Site. Lead was the sole contaminant of concern for OU-2 of
the Site, and EPA has concluded that there are no elevated
concentrations of lead in Site soils and sediments. Further
sampling or monitoring activities are considered unnecessary.
Unit l (OU— l) Contamination COroynfl Water)
A citizen asked about the distinction between the two
operable units at the Site. Another citizen asked if the
ground water monitoring schedule described in the Record
of Decision (ROD) for OU-1 would be affected by a No
Action decision for OU-2.
-------
EPA Response. The ROD issued for OU-1 (ground water
contamination) will not be affected by the ROD for OU-2. The
ROD for OU-2 relates to soils and sediments only. Ground
water monitoring activities will be conducted as stated in the
ROD for OU-1. EPA made a distinction between the operable
units so that the known problem (ground water contamination)
could be addressed as soon as possible while at the same time
allowing further investigation of the suspected lead-
contamination of soil and sediment. Currently, the
groundwater remedy is in the early stages of the design
process.
2. A Vestal Town Councilman asked if ground water at the
Site would be pumped out of the aquifer and treated with
an air stripper.
EPA Response. EPA will proceed with the ground water
remediation as described in the ROD for OU-1. The process
will involve pumping ground water out of the aquifer and using
an air stripper to remove volatile organic compounds (VOCs).
Treated groundwater can either be used in the plant processes
or discharged at the facility's permitted outfall.
3. The Vestal Town Supervisor expressed concern about the
discharge of ground water into the river. He cited past
problems that the town has had with discharges into the
river. He also asked how the pumping system would be
structured.
EPA Response. All discharges from the plant, including the
discharge from the air stripper, must comply with the
facility's existing State Pollutant Discharge Elimination
System (SPDES) permit. The permit takes into consideration
the fact that the effluent ultimately enters the Susquehanna
River. The State of New York has designated the river as a
Class A water body, which means that it is considered
protected.
Three areas requiring treatment have been established at the
Site. Water will be pumped from these three areas to the air
stripper for treatment. The extraction and treatment systems
will be fully modeled and tested before implementation. Air
discharges from the air stripper must comply with NYSDEC
standards.
4. A citizen asked where the ground water will go after
treatment.
8
-------
EPA Response. Once the ground water is treated, the plant has
the option to use the water in the pipe production operation
or to discharge it under their SPDES permit. EPA anticipates
the plant will decide to reuse the treated water in their
operations.
5. A citizen asked if the plant currently holds an SPDES
permit.
EPA Response. The Robintech plant has held an SPOES permit
since 1981. The plant is required to have this permit because
their operations include using water to cool newly formed PVC
pipe.
6. A citizen asked how often the aqueous discharge from the
air stripper will be monitored, and whether the plant
would be informed beforehand. He also asked what type of
corrective action would occur if the plant was not in
compliance with standards.
EPA Response. EPA will be involved throughout the remedial
process, overseeing the PRPs during sampling, testing of
equipment, and other aspects of the design, construction, and
operation of the extraction and treatment system. In
addition, EPA Will be approving or disapproving any
modifications to the system. The aqueous discharge from the
air stripper will be periodically monitored with EPA
collecting split samples for verification purposes.
Monitoring will be conducted using 10 to 15 wells, including
some new wells constructed specifically for the remedial
project. In addition, the regular monthly monitoring of plant
discharges associated with the SPDES permit will supplement
the new monitoring program. Should the groundwater extraction
and treatment system fail to achieve the level of removal of
contaminants required, EPA would require the PRPs to modify
the system to achieve these goals.
7. A citizen requested clarification of the relationship
between the SPDES permit and the Superfund investigation
at the Site.
EPA Response. From 1966 to 1983, the Robintech plant used
public water in their operations. In 1981, the plant obtained
an SPDES permit. The plant installed its own wells in
December 1983. A routine analysis of the plant's effluent
collected by NYSDEC in 1984 showed contaminants'present that
were not listed in the permit. Further investigation into the
source of these contaminants led to the conclusion that they
originated in the groundwater beneath the Site. The Site was
-------
placed on EPA'a Superfund National Priorities List in June of
1986.
8. A citizen asked which series of analytical method is used
to evaluate the plant's SPDES parameters, as different
series are associated with different detection levels.
EPA Response. According to NYSDEC personnel, the series of
analytical method utilized by NYSDEC for the Site pipe
production facility's SPDES permit in their grab samples is
the 600 series. This is the series associated with
vastewater. The specific analytical methodology would be
either 601 or 624. This is in accordance with 40 CFR Part 136
of the federal guidelines regarding the testing of such
effluent. The analytical method utilized by the pipe
production facility to monitor their effluent for their SPDES
permit would follow suit accordingly.
Other Issues
1. The Vestal Town Supervisor asked why the meeting was
being held in Endicott, New York as opposed to Vestal,
New York. He stated that residents from the Town of
Vestal were not well informed of the meeting and so were
unable to respond properly, as evidenced by the small
turnout compared to that for a previous public meeting
for OU-1 which was held in Vestal Town Hall. He said
that he could have secured a room in Vestal to conduct
the public meeting. He requested that the EPA conduct a
second hearing for OU-2 in the Town of Vestal.
EPA Response. In December of 1992 EPA attempted to secure a
meeting place for January of 1993 in the Town of Vestal.
Several town representatives of Vestal informed EPA that no
meeting spaces were available. While the preferable location
for the meeting would have been in Vestal, EPA concluded it
was appropriate under the circumstances to accept a nearby
location in order to present the findings in a timely manner.
EPA uses a variety of approaches to disseminate information to
the public. Approaches used for informing the public about
the Robintech Site meeting and public comment period for OU-2
included press releases to local newspapers, announcements on
radio and television, mailing information directly to local
officials and concerned citizens included in the mailing list
for the Site, and paid public notices published in local
newspapers. The press release, mailing list/ and public
notice information was communicated clearly, accurately, and
within an appropriate time frame. For the most part the radio
and television information was communicated correctly and
10
-------
accurately, though the Town Supervisor pointed out that he had
seen a television announcement that had communicated the wrong
meeting location. This was the basis of his request for a
second hearing and his basis for claiming a low turnout.
EPA does not feel that a second meeting is justifiable or
necessary. In almost all instances, information concerning
the location and time of the public meeting was communicated
correctly. EPA cannot control or be held accountable for the
accuracy or content of the public media.
2. A citizen expressed concern about other contaminant
releases by the plant. He described a contaminant
release to the air that had occurred on Thanksgiving
night, 1992. The release was reported to the Broome
County Health Department as a discharge of a large volume
of chemicals into the air, described as butyltin
mercaptide ethyl sulfide. He was concerned that the
plant was not being governed properly and felt that the
EPA should work closely with the local agencies to ensure
the plant's compliance.
EPA Response. Butyltin mercaptide ethyl sulfide is not a
hazardous substance listed under Section 102(a) of the
Comprehensive Environmental Response, Compensation, and
Liability Act ("CERCLA"), and does not appear to be a
substance the release of which would trigger the reporting
requirements of CERCLA §103 or Section 304 of the Emergency
Planning and Community Right-to-Know Act ("EPCRA").
Nevertheless, the November 26, 1992 release of butyltin
mercaptide ethyl sulfide at the Site was reported to NYSDEC's
Region 7 office located in Kirkwood, New York, who responded
to the scene. This particular release does not appear to be
one which required a response action by EPA under CERCLA.
As a general matter, where a hazardous substance is released
from a facility in an amount which equals or exceeds the
reportable quantity for that substance, the person in charge
of the facility, or the owner or operator of the facility,
must immediately notify the National Response Center, the
State Emergency Response Commission, and the Local Emergency
Planning Committee and provide certain information. Such
notification helps insure that federal, state and local
officials can properly respond to environmental emergencies.
Not all releases of substances require a response action.
The pipe production and electronic cable assembly facilities
are periodically inspected by NYSDEC under various
environmental statutes. The effluent from the pipe production
process is sampled and sent to a lab for analysis on a monthly
basis under the SPDES program. The cable assembly operation
11
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operates tinder a NYSDEC air permit. The pipe production
facility operates under 15 air permits which are inspected
annually by NYSDEC or upon a reported release. In addition,
EPA regulates the pipe production and electronic cable
assembly facilities as small generators under the RCRA
program. Both facilities are inspected annually under this
program.
12
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APPENDIX V
ADMINISTRATIVE RECORD FILE INDEX
-------
01/05/93 Index DooiMnt Muter Order Page: 1
tOilHTECH INC./HAT10NAL PIPE CO. SITE, OU 2 DoeuMnts
Oocusant Huafeer: UT-001-0001 To 0297 Date: 03/01/92
Tftltt Skate Estate SeU Sampling Investigation. Robintech Site, Vestal. New York, Final Report
Typt: REPORT
Category: 2.2.0.0.0 Sampling and Analysis Data/Chain of Custody
. Author: Millar, David N.: Environmental Raspoma Taaai (ERT)
Sprcngar, Nark 0.: Environmental Rasponsa Teaa (ERT)
Recipient: nena: US EPA
Oonaant Htobar: R1T-001-0298 To 0450 Data: 12/01/92
Titla: final Raport Soil Saipling Invastigation, Robintaeh Sita, Vastal, NT
Type: REPORT
Catagory: 3.2.0.0.0 Sampling and Analysis Dsts/Chain of Custody Forw
Author: Nunnay, Kannath L.: Environwntal Rasponsa Taaa (ERT)
Sprangar, Nark 0.: Environmntal Rasponsa Taa* (ERT)
Racipiant: none: us EPA
eocuaant Nudaar: UT-001-0451 To 051S Data: 12/21/92
Titla: Robintaeh Inc./National Pipe Co. Sita Raport on Suspected Lead Contamination in Surface Soils,
Subsurface Soils, and Sediments
Type: REPORT
Catagory: 3.4.0.0.0 RI Reports
Author: none: none
Recipient: none: nena
Oocuaent Umber: RtT-001-0516 To 0518 Data: 09/07/89
Title: (Man discussing establishing an Interim guidance for soil lead cleanup levels at Superfund
sites)
Type:
Category: 11.1.0.0.0 EPA Headquarters Guidance
Author: Oieaond, truce: US EPA
Longest. Henry L. II: US EPA
Recipient: directors: US EPA
-------
5/93 Indue Docuatnt mmbtr Ordar
IOBINTECN INC./NATIONAL PIPE CO. SITE, OU 2 OocUHnta
OeciMnt Mfear: fJT-001-0519 To 0527 Data: 12/01/92
Titlt: Ct^trfind Propond Plan, lebintach, Ine./MatiorMl Pip* Co. S
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ROD FACT SHEET
SITE
Name: Robintech, Operable Unit 2
Location/State: Vestal, Broome Co., New York
EPA Region: II
HRS Score (date): 30.76 (6/86)
NPL Rank (date): Not Applicable
ROD for OU-2
Date Signed: March 30, 1993
Selected Remedy for OU—2
Soil and Sediment: No Action
Capital Cost: N/A
O & M: N/A
Present Worth: N/A
LEAD
Enforcement, PRP Lead
Primary Contact (phone): Mark Granger (212-264-9588)
Secondary Contact (phione) : Melvin Hauptman (212-264-7681)
WASTE (OU-2)
Type: Lead (Suspected).
Medium: . . Soil and Sediments.
Origin: Unknown, suspected erroneous data: of
200 samples collected to verify elevated
concentrations none of Site-related data
was elevated
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RECORD OF DECISION
ROBINTECH, INC./NATIONAL PIPE CO. SITE
OPERABLE UNIT 2
TOWN OF VESTAL
BROOKE COUNTY, HEW YORK
UNITED STATES ENVIRONMENTAL PROTECTION AQENCY
REGION II
NEW YORK
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DECLARATION FOR THE RECORD OF DECISION
Site Name and Location
Robintech, Inc./National Pipe Co. Site, Town of Vestal, Broome
County, New York.
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Robintech, Inc./National Pipe Co. Site (hereinafter, the
"Site" or the "Robintech Site"), Operable Unit Two (OU-2),
located in the Town of Vestal, Broome County, New York, which was
chosen in accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA),
42 U.S.C. SS 9601-9675, as amended by the Superfund Amendments
and Reauthorization Act of 1986 (SARA), and the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR
Part 300. This decision document explains the factual and legal
basis for selecting the no action remedy for OU-2 of the Site.
The New York State Department of Environmental Conservation
("NYSDEC") concurs with the selected no action remedy. A letter
of concurrence from NYSDEC is attached as Appendix III to this
document.
The information supporting this no action decision is contained
in the Administrative Record file for the Site. The
Administrative Record file index is attached as Appendix V.
Description of the Selected Remedy; No Action
The United States Environmental Protection Agency (EPA) has
determined that no action is necessary for the suspected lead
contamination of Site-related soil and sediment at the Robintech
Site. EPA bases this decision, in part, on the Remedial
Investigation (RI) report dated September 1991; Appendices A and
D of EPA's 1987 RI Work Plan; as well as the EPA reports entitled
"Skate Estate Soil Sampling Investigation" dated March 1992;
"Report on Suspected Lead Contamination in Surface Soils,
Subsurface Soils, and Sediments" dated December 1992; and "Soil
Sampling Investigation, Robintech Site" dated December 1992.
Confirmatory sampling of the suspected Site-related lead
contamination of soil and sediment was conducted in both February
and September 1992. The concentrations of lead in Site-related
soil and sediment were found to be acceptable for protection of
human health and the environment. Thus, "No Action" is the
selected remedy for the second operable unit for the Site.
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Declaration Statement
In accordance with the requirements of CERCLA, as amended, and
the NCP, EPA, in consultation with the State of New York, has
determined that the suspected lead contamination of soil and
sediment at the Robintech, Inc. /National Pipe Co. Site does not
pose a significant threat to human health or the environment and,
therefore, remediation of the Site-related soil and sediment is
not necessary.
The alternative selected for the first operable unit of the Site
will result in contaminants remaining on-site above health based
limits until the contaminant levels in the aquifer are reduced
below NCLs. CERCLA requires that this action be reviewed at
least once every five years after commencement of the remedial
action, and every five years thereafter, to ensure that the
remedy continues to provide adequate protection of human health
and the environment.
,
/
.
William J. Mu^yfsTttXJfE. Date
Acting Regional Administrator
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TABLE OF CONTENTS
I. SITE NAME, LOCATION AND DESCRIPTION 1
ZI. SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION ....... 3
IV. SCOPE AND ROLE OF RESPONSE ACTION 3
V. SUMMARY OF SITE CHARACTERISTICS 4
VI. SUMMARY OF SITE RISKS 7
VII. STATE ACCEPTANCE 9
VIII. COMMUNITY ACCEPTANCE 9
IZ. DESCRIPTION OF THE "NO ACTION" REMEDY 10
Z. DOCUMENTATION OF SIGNIFICANT CHANGES 10
ATTACHMENTS
APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX III. NYSDEC LETTER OF CONCURRENCE
APPENDIX IT. RESPONSIVENESS SUMMARY
APPENDIX V. ADMINISTRATIVE RECORD FILE INDEX
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I. SITE HMOS, LOCATIQM MID DESCRIPTION
The Robintech Inc./National Pipe Co. site (hereinafter, the
"Site" or the "Robintech Site") is located at 3421 Old Vestal
Road in the Town of Vestal, Brooms County, New York (see Figure
l). Vestal, with a population of 27,238 (U.S. Census, 1980), is
located within a regionally important industrial center adjacent
to Binghamton, N.Y. in the Susguehanna River basin. An estimated
5,350 people live within a one mile radius of the Site. A Site
location map is included in Appendix I as Figure 1.
The Site occupies 12.7 acres, and is bordered by Commerce Road
and several warehouses and light industrial buildings to the
east; Old Vestal Road and several residences to the south; an
amusement facility (known as the Skate Estate) and fuel storage
tanks (Mobil Tank Farm) to the west; and by Conrail railroad
tracks and Parkway Vending Inc. to the north. The Site is
located approximately half-way down the westerly face of a hill
that slopes gently toward the Susguehanna River. Consistent with
this, EPA field observations and examination of topographic
contours indicate that the superficial (overland) flow of surface
water across the Site is to the west, controlled by a series of
conduits and drainage ditches which direct the flow to the river,
located approximately a half mile to the north and west. A Site
layout map is included in Appendix I as Figure 2.
The area has two distinct aquifers which are sources of water
supply. The upper aquifer is comprised of the overburden
material above bedrock. This material consists mainly of gray
and brown till which becomes harder with depth. In addition,
fill material associated with extensive grading on-site for
parking spaces and storage ranges from 0-6 feet. Groundwater was
encountered within the upper aquifer unit 6-20 feet below the
ground surface. The lower aquifer is shale bedrock with a
weathered zone 7-10 feet thick. The primary permeability of this
material is low but the secondary permeability is much higher.
Fractures along the horizontal bedding planes and vertical joints
in the shale allow for groundwater flow. Groundwater was
encountered in this zone 10-60 feet below the ground surface.
Groundwater flow in the study area is primarily toward the west,
with minor components trending to the northwest and southwest,
and is recharged from rainfall. There are no private drinking
water wells in the vicinity of the Site. All residents are
supplied with drinking water by the Vestal public water supply
system.
The area where the Site is located is not known to contain any
ecologically significant habitat, wetlands, agricultural land, or
historic or landmark sites which are impacted by the Site.
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II. SITE HISTORY AHP gMFORCKMBMT ACTIVITIES
In 1966, Robinson Technical Products, Inc. constructed the main
building that currently exists at the Site. The first floor of
the building was used for the manufacture of aircraft engine
mounts and automobile accelerator control cables. The second
floor was used for the assembly of electronic cable. In 1970,
Robinson Technical Products was renamed Robintech, Inc., and
first floor production activities were replaced with PVC pipe
extrusion operations. Between 1966 and 1979 the present pipe
staging area was paved in four successive stages to the north.
The warehouse was constructed in 1974. Ten production wells were
installed on-site in 1983 to supply cooling water for the PVC
pipe extrusion process. Pipe production had previously relied on
municipal water for this purpose.
The Site was bought by Buffton Corporation, the current owner, in
1982, and was occupied by its subsidiaries National Pipe Company
(National Pipe) and Electro-Mech, Incorporated (Electro-Mech).
Electro-Mech has continued the assembly of electronic cable on
the second floor of the facility located at the Site. National
Pipe continued the PVC pipe extrusion operations until 1991, when
substantially all of National Pipe's assets were sold to LCP
National Plastics, Inc. (LCP). LCP is currently occupying that
portion of the plant at the Site that previously was used by
National Pipe.
An effluent sample collected in 1984 by The New York State
Department of Environmental Conservation ("NYSDEC") to verify
discharge permit compliance found certain organic constituents
above standards that were not covered under the existing permit.
Further investigation resulted in the conclusion that the source
of contamination was coming from the groundwater beneath the
Site. This groundwater was being pumped from the newly installed
on-site production wells, used as cooling water in the PVC pipe
extrusion process, and then discharged at the permitted effluent
point. The Robintech Site was placed on EPA's National
Priorities List (NPL) in 1986. An Administrative Order on
Consent (AOC) for a Remedial Investigation and Feasibility Study
(RI/FS) was issued in 1987 to General Indicator Group, Inc. (a
successor of Robintech), Buffton, Buffton Electronics
(subsequently renamed Electro-Mech, Inc.), and National Pipe
Company. McLaren/Hart, retained by Buffton, implemented the EPA
approved work plan. The RI Report was approved by EPA in October
1991. The FS Report was approved by EPA in March 1992.
In response to inconsistencies of data associated with levels of
lead in soils and sediments, the Site was separated into two
operable units (OUs), or phases, on February 12, 1992. The first
OU (ou-l) addressed groundwater, surface water and air; the
second OU (OU-2), which is the subject of this ROD, addresses
Site-related soils and sediments suspected to be contaminated
-------
with lead. Only groundwater was found to be of concern for OU-l.
A Record of Decision (ROD) was issued on March 30, 1992 which
calls for the pumping of groundwater from three on-site locations
to an air stripper and discharge of the treated groundwater to
the facility's permitted outfall. Treated groundwater may be
used in the facility's production process before being discharged
to the outfall, if so desired. Depending on contaminant load, air
pollution controls may be added to the treatment system. EPA
issued a Unilateral Administrative Order (UAO) to Buffton
Corporation and Electro-Mech, Inc. on September 29, 1992,
requiring those companies to conduct the groundwater remedial
design and remedial action (RD/RA). The RD is expected to be
completed in the Fall of 1994.
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
EPA is basing the no action decision for suspected lead
contamination of Site-related soils and sediments, in part, on
the Remedial Investigation (RI) report dated September 1991;
Appendices A and D of EPA's 1987 RI Work Plan; as well as the EPA
reports entitled "Skate Estate Soil Sampling Investigation" dated
March 1992; "Report on Suspected Lead Contamination in Surface
Soils, Subsurface Soils, and Sediments" dated December 1992; and
"Soil Sampling Investigation, Robintech Site" dated December
1992. These and other significant documents, as well as the OU-2
Proposed Plan for the .Site were released to the public for
comment on December 31, 1992. These documents were made
available to the public in both the OU-2 Administrative Record
file and information repositories maintained at the EPA Docket
Room in the Region II New York City office and at the Town of
Vestal Public Library located at 320 Vestal Parkway East, Vestal,
New York. The notices of availability for these documents were
published in the Binqhamton Press & Sun Bulletin on December 31,
1992. A public comment period was held from December 31, 1992
through January 30, 1993. A public meeting was held on January
12, 1993 at the George F. Johnson Memorial Library in Endicott,
New York. At this meeting, representatives from EPA presented
the findings of the comprehensive analysis of all data collected
since 1985 as it relates to lead in Site-related soils and
sediments and answered questions from the public about the Site
and the no action remedy under consideration. Responses to the
comments received during this comment period are included in the
Responsiveness Summary, which is attached to this ROD as Appendix
IV.
IV. SCOPE AMD ROLB OF RESPONSE ACTION
This ROD focuses on EPA's selection of a no action decision for
the Site-related soils and sediments. As noted previously, a ROD
was issued on March 30, 1992 for OU-l. The OU-l ROD calls for
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the pumping of groundvater from three on-site locations to an air
stripper and discharge of the treated groundvater to the
facility's permitted outfall. Treated groundvater may be used in
the facility*s production process before being discharged to the
outfall, if so desired. Depending on contaminant load, air
pollution controls may be added to the treatment system. EPA
issued a Unilateral Administrative Order (UAO) to Buffton
Corporation and Electro-Mech, Inc. on September 29, 1992,
requiring those companies to conduct the groundvater remedial
design and remedial action (RD/RA). The RO is expected to be
completed in the Fall of 1994. This action vill reduce the
threat to the environment by removing contaminated groundvater
from the aquifer and reducing or eliminating the threat to human
health and the environment of groundvater contaminant migration
from the Site.
Based on EPA's analysis of data generated as relevant to OU-2,
and on EPA's Risk Assessment and other supporting documentation,
the Site-related soils and sediments do not pose a threat to
human health or the environment.
V. SUMMARY OP BITE CHARACTERISTICS
f Soil and Sediment Data as Related to OU-2 :
Under the supervision of EPA, sampling of sediment, surface and
subsurface soils, air, surface vater and groundvater vas
conducted by McLaren/Hart during the RI . As mentioned
previously, groundvater, air and surface vater vere addressed as
part of the OU-1 ROD and, as such, are not addressed in the OU-2
ROD. Further information related to OU-l may be found in the OU-
1 Administrative Record file.
The topography in the vicinity of the Site slopes primarily to
the vest and to a lesser extent to the north. Surficial soils
that vere suspected of being disturbed or revorked during
construction activities vere classified as fill. Typically,
these materials vere encountered to a maximum depth of 6 feet
below ground surface. The composition of the fill is similar to
other surficial soils encountered on-site.
Several volatile organic compounds (VOCs) vere detected in soil
in the northern portion of the paved pipe staging area of the
Site at levels belov concern. Levels of semi-volatile
contaminants in this area are associated vith the asphalt paving.
The only VOC detected in on-site sediment samples vas 1,1,1-
trichloroethane ("1,1,1-TCA") . Reported values ranged from 14 to
28 parts per billion ("ppb"). No Federal or State standards
exist for contaminants in sediment.
Based upon the McLaren/Hart data set from the RI report, lead in
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on-site and downgradient soil and sediment was the sole
contaminant of concern. Soil and sediment samples analyzed by
McLaren-Hart shoved lead levels exceeding the EPA interim lead
cleanup level of 500-1000 ppm in 24 of 64 samples collected down
to a depth of 10 feet. Elevated concentrations ranged from 2,000
to 56,000 ppm. In addition, a small off-site area located on the
Skate Estate property displayed elevated lead levels in surface
soil. All other reported lead values from this data set were
below 100 ppm. EPA conducted confirmatory split sampling at
several locations at the time these samples were collected. The
EPA split samples failed to confirm the elevated lead
concentrations. Concentrations for the EPA split samples ranged
from 12-61 ppm. RI data summary tables are included in Appendix
II (see Tables 1 thru 3). EPA's split sample data summary tables
are included as Tables 4 and 5. In addition, a map of split
sample and RI sampling locations can be found in Appendix I as
Figures 3 and 4.
yi^'fliflry of Other Soil and Sediment Data as Related to OU—21
Two other sets of data, one before the McLaren/Hart RI and one
after, were collected by EPA and included over 250 samples
analyzed for lead and other compounds.
EPA initiated sampling events in July 1985 as part of developing
an RI/FS Work Plan for the Site. These events are summarized
(including maps of sampling locations) in Appendices A and D of
the 2/10/87 Rl/FS Work Plan developed for EPA by CDM-FPC, an EPA
contractor. This document is included in the Administrative
Record file for the Site. A total of five sediment samples at
four locations were collected as part of this investigation.
McLaren/Hart split three of these samples with EPA. All eight
analyses were below 80 ppm for lead. Of 58 subsurface and
surface soil samples collected both on- and off-site, all were
below 50 ppm for lead, with the exception of one reported value
of 143 ppm from a sample collected from a drainage ditch located
in the extreme northern portion of the Site between the paved
pipe-staging area and the gravel lot area. Maps of sampling
locations associated with these events can be found in Appendix I
(see Figures 5 thru 7). Data summary tables can be found in
Appendix II (see Table 6).
In response to the elevated detections of lead in the Skate
Estate surface soils reported in the McLaren/Hart RI data, EPA
tasked its Environmental Response Team (ERT) to determine if the
property qualified for a removal action. The assessment,
initiated in February 1992, analyzed 155 surface soil, subsurface
soil and sediment samples associated with the Skate Estate
property and, to a lesser extent, the western perimeter of the
Site. Three background samples were collected at nearby
locations unassociated with either the Skate Estate or Robintech
properties. Analysis was by portable X-Ray Florescence (XRF)
-------
methodology. XRF methodology is a truck mounted field screening
analytical method which generates real-time data. In addition,
21 split samples were lab-analyzed using Contract Lab Program
(CLP) methodology to provide confirmation of XRF sampling data.
The McLaren/Hart soil and sediment sampling locations associated
with elevated lead detections were duplicated as closely as
possible. Results indicated 120 samples below 50 ppm, 26 samples
within 50-100 ppm, 4 samples within 100-150 ppm, and 3 samples
within 200-250 ppm (or 153 out of 155 samples below 250 ppm).
One detection was recorded at 344 ppm, well below the EPA interim
cleanup level of 500 ppm for lead in soil. A single detection of
2,550 ppm was recorded in the off-site background location and is
considered anomalous. This detection was recorded in a location
described by ERT as being characterized by "historical disposal
of household debris and automotive waste materials, including oil
cans and used oil filters." The split samples, analyzed by CLP
methodologies, confirmed the accuracy of the XRF samples.
In September 1992 a second sampling event was initiated by ERT to
reanalyze areas where elevated detections of lead had been
indicated by the McLaren/Hart data set in an effort to confirm
the validity of that data. The original locations were checked
against known landmarks and confirmed by the EPA Project Manager
for the Site. In the case of the McLaren/Hart subsurface soil
borings, the original bore holes had been grouted to grade with
concrete and were especially easy to locate. A total of 39
samples were collected from 16 relevant surface soil, subsurface
soil, and sediment RI-related locations. Analysis was by
portable XRF methodology. Where an elevated detection had been
made during the course of the McLaren/Hart sampling rounds in a
particular horizon, samples were collected down to that horizon
using a drill rig. All but 2 of the 39 samples collected were
below 50 ppm and all samples recorded lead values below 100 ppm.
Split samples analyzed in the lab using CLP methodologies
confirmed the accuracy of the XRF sampling results. All 10 of
these lab samples were below 50 ppm.
A more detailed discussion of these sampling events, including
maps of sampling locations, can be found in Appendices A and D of
EPA's 1987 RI Work Plan, as well as in the EPA reports entitled
"Skate Estate Soil Sampling Investigation" dated March 1992;
"Report on Suspected Lead Contamination in Surface Soils,
Subsurface Soils, and Sediments" dated December 1992; and "Soil
Sampling Investigation, Robintech Site" dated December 1992.
Data summary tables can be found in Appendix II (see Tables 7
thru 9). Maps of sampling locations associated with these events
can be found in the EPA reports entitled "Skate Estate Soil
Sampling Investigation" dated March 1992 and "Soil Sampling
Investigation, Robintech Site" dated December 1992. These
documents may be found in the Administrative Record file for the
Site.
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Although the exact reason is not apparent, a comprehensive
analysis of all sampling data collected since 1985 for the site
indicates that the McLaren/Hart data set is erroneous and
inaccurate as it relates to reported lead values in soil and
sediment.
VI. SUMMARY Of BITE RISKS
EPA conducted a Risk Assessment to estimate the health and
environmental risks of all potentially affected media at the
Site. The Risk Assessment began by selecting indicator chemicals
which would be representative of Site risks. These chemicals
were identified based on factors such as potential for exposure
to receptors, toxicity, concentration and frequency of
occurrence. These contaminants included VOCs, semi-volatiles,
and metals in various media.
The Risk Assessment evaluated the health effects which could
result from exposure to contaminated or potentially contaminated
media including groundwater, surface water, air, surface and
subsurface soils, and sediment. Risks associated with
groundwater, surface water and air are the subject of OU-1 and as
such are not addressed as part of this ROD.
The results of the Baseline Risk Assessment are contained in the
Draft Final Risk Assessment. Robintech. Inc./National Pipe Co.
Site dated February 1992 and prepared by Alliance Technologies
Corporation under contract to EPA. This document is included in
the Administrative Record file for the Site.
Current federal guidelines for acceptable exposures are a maximum
health Hazard Index (HI) equal to 1.0 and an individual lifetime
excess carcinogenic risk in the range of 10"* to 10"6 (or »
1:10,000 to 1:1,000,000). The Hazard Index reflects
noncarcinogenic health effects for an exposed population and is
calculated by dividing the chronic daily intake of a chemical by
the daily dose believed to be protective of human health
including sensitive sub-populations. If the HI exceeds one
(1.0), there is a possibility of adverse health effects.
For soil and sediment, the exposure pathway demonstrating the
greatest risk was ingestion of on-site soils by a trespasser.
This risk value (1.0 x 10*J) is, however, within the target
carcinogenic risk range of 10"* to 10"6 discussed above and in the
NCP. Risk for this scenario was due primarily to PAHs which were
detected in a single sample underlying the pavement. None of the
His exceeded 1.0 for soils or sediments. Quantifiable risks,
therefore, have been determined to be insignificant.
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It should be noted that EPA has temporarily withdrawn the
toxicity values used to quantitatively evaluate risks associated
with lead exposure in soil and sediment. In the meantime EPA has
set an interim cleanup level of 500 to 1,000 ppm for the maximum
allowable concentration of lead in soil in residential areas.
This range is designed to protect sensitive sub-populations
(i.e., children). While the Site and most of the surrounding
area is zoned for industrial use, this range has at times
provided a basis for remedial action at industrial sites as well.
For the Robintech, Inc./National Pipe Co. Site, the lower and
more protective value of 500 ppm is considered the threshold
value. Employing this value at the Site affords an added layer
of safety.
The 500 ppm threshold value was significantly exceeded in Site-
related soils and sediments from one of the three data sets
collected for the Site (i.e., the data set collected as part of
the McLaren/Hart RI). As summarized previously (see "RI Summary
of Soil and Sediment Data as Related to OU-2" and "Summary of
other Soil and Sediment Data as Related to OU-2" sections,
above), data collected before the McLaren/Hart data set, split
samples collected concurrently with the McLaren/Hart data set,
and data collected in response to the McLaren/Hart data set have
failed to detect even a single elevated concentration of lead in
Site-related soil or sediment. The 2,550 ppm value reported in a
background sample and discussed on Page 6 of this ROD was not
collected from soil or sediment related to the Site. A
comprehensive analysis of all sampling data collected since 1985
for the Site indicates that the McLaren/Hart data set is
erroneous and inaccurate as it relates to reported lead values in
soils and sediments. Therefore, based on the data sets relied on
by EPA in evaluating Site conditions, there is no significant
human health hazard due to Site-related lead levels in soils and
sediments.
In terms of environmental risk, it is important to consider that
the area where the Site is located is not known to contain any
ecologically significant habitat, plant and animal species, or
wetlands. Though no measurable evaluation criteria are available
to quantify and assess potential environmental risk, it should be
noted that, from a qualitative perspective, the threshold value,
designed to be protective of children (who are extremely
sensitive to lead exposure), by extension would be protective of
most environmental receptors. Thus, children as an indicator
species combined with the absence of sensitive ecological factors
leads to the conclusion that there are no significant
environmental risks due to Site-related lead levels in soils and
sediments.
8
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Areas of 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. Environmental chemistry analysis
uncertainty 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
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 mentioned previously,
lead is currently undergoing a toxicological reevaluation. While
issues of toxicological uncertainty are being resolved, EPA has
established an interim soil cleanup level (500-1,000 ppm) as
protective of the most sensitive sub-population, that being
children.
VTI. STATE ACCEPTANCE
The State of New York concurs with EPA's selected no action
remedy. Their letter of concurrence is attached as Appendix III.
VIII. COMMUNITY ACCEPTANCE
The community had a few questions about the no action remedy.
Inquiries generally regarded lead concentrations present in Site-
related soils and sediments. EPA addressed these questions at
-------
the public meeting and assured those present that the low lead
concentrations in Site-related soils and sediments did not
require action. In general, the community appeared satisfied
with the no action remedy. All comments that were received from
the public during the public comment period, including all
questions and comments raised during the public meeting, are
addressed in the Responsiveness Summary attached as Appendix IV.
II. DESCRIPTION OF THE "HO ACTION1' REMEDY
Based upon the review of all available data and the findings of
the RI conducted at the Site, a no action decision for OU-2 of
the Site is protective of human health and the environment. The
no action decision complies with Federal and State requirements
that are legally applicable or relevant and appropriate to the
remedial action and is cost effective.
A comprehensive review of all data collected at the Site
indicates that there are no concentrations of lead in Site-
related soils and sediments above the 500 ppm threshold value.
As such, there is no significant threat to human health or the
environment due to Site-related lead levels in soils and
sediments.
1. DOCUMEKTATION OP SIGNIFICANT CHANCES
There are no significant changes from the preferred alternative
presented in the Proposed Plan.
10
-------
FIGURES
-------
BASE MAP IS A PORTION OF THE FOLLOWING 74' U.S.G.S. QUADRANGLES:
ENDICOTT, NY, 1969; BINGHAUTON WEST, NY, 1976
1000 2000 3000 fMt
OUAOfUNOLE LOCATION
LOCATION MAP
LOCATION OF THE ROBINTECH, MCJNATIONAL PIPE CO. 8TTE
VESTAL, NEW YORK
Flgurtl.
-------
LEGEND
---- PROPERTY BOUNOMY
-- stomi S£»CR
— — WMMACC WfCM
R RtSttCNCC
e BUSIMCSS
• PKOOUCHON MIL
740'
FIGURE 2
SITE LAYOUT
NATIONAL PIPE. VESTAL. NY
-------
O Monitoring WeN Location •-
• Sol Boring Loeaton
• Sediment Sampang Location —
O FualStaraoaTanli • Manhola -
Storm Water Sower
Fenoa
Properly Boundary
SITE LAYOUT INCLUDING SOIL BORING. SEDIMENT
SAMPLING. AND MONITORING WELL LOCATIONS
ROBMTECH, MC7NAHONAL PIPE CO. SITE
VESTAL, NEW YORK
FlQUTO 3
-------
fMMCNONMU
S4M. MAMO
*MVL<
•an*
eu* ««
•r -*•• rouoMNO we MU
MI maoucnoM «cu« WIN BC
CKCTMM or fV-t* MK
SOIL AND CROUNDWATER SAMPUNG
LOCATIONS
NATIONAL PIPE. VESTAL. NY
-------
-------
$0-09-91 MKPLZ tOCATZOB
• AID
-------
• irmnrtmnmiumfm MUB. I I
ttctra
10* JVC WH M»eh«»la» to HM
•V Afeovt Stes* Ccwtr Citch tetia.
^ IS* Vid« rr«u»t Oracrct*
^ Sarfcet Brai&M* Kctbrny
S tetiaagt trait.
Cown4 Catch tesiu.
fopl* Aabtr Aad toectiw
••ttliat Buia
100
Scote
f«tf
COM
-7 •
lOBdTECH/NATXONAL PIPE 00. SITE
•EKLAKCDffMT OF SURFACE SOU.,
SEDZMEKT AMD UATEH SAMPLING LOCATIONS
XN SV SITE AREA
-------
APPENDIX
TABLES
-------
TABU 1
SUMMARY OF SOIL ANALYTICAL RESULTS
METALS AND CYANIDE
NATIONAL FIFE. VESTAL, NY
BORING NUMBER
DEPTH (FT)
DATE
Bl
2-4
4-20-11
Bl-D
*-4
4-20-tt
Bl
1-10
4-20-U
B2
2-4
4-21-41
B2
4-6
4-21-11
B2
f-10
4-21-M
B2A
4-6
4-21-U
B2A-D
4-6
4-21-41
B2A
1-10
4-21-41
B2B
2-4
4-21-U
B2B
6-1
4-21-11
METALS
Afaffiinitni
Aatiaaey
Amok
BvfaB
BeyOiuB
Cftd&tB&
Cilctoa
Chromium
Cebah
Copper
Ira
IMA
Mtfntfira
MaapAMc
**
pnwvtj
Nkkd
^^V^ftVfeSrtHVt
•titBRRD
Sflvtr
Sedioa
Tkafliaa
V(Bidins
2fec
15.719
-
-
21 JQ
-
-
3.434
-
19.4
26.4
26.764
29
4,091
Tit
0.10J
24.3
923Q
-
24
133Q
-
-
66.0
11.925
.
.
.
042Q
.
141
*»
.
20.3
22.1M
25
S.162
435
o.ow
41.7
472Q
-
UQ
93.1Q
1-»Q
-
•14
5315
.
.
.
m
-
21.199
.
J7.1
19.1
13.912
10.41
2.617
672
C.26J
16.6
»3Q
.
UQ
SOQ
-
11.9
45^
KA
NA
MA
KA
NA
MA
MA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
7.110
.
.
29.9Q
.
«•
M97
-
«»
12.1
15,131
21.41
1JOO
425
04MJ
12.1
271Q
.
W
60.7Q
-
-
50.4
•,692
.
.
-
.
-
129Q
-
OTt
11.6
14,940
12.100
1,693
216
0.05Q
15.0
237Q
-
*
67.IQ
-
.
«.»
t.oto
-
.
42.7
.
-
2445
-
•»
30.4
16,ttl
31J
1431
S34
0.161
16.1
441Q
-
.
116Q
-
.
41.1
6.6W
-
^
S6Q
-
-
1.719
-
-
14.3
12414
361
1426
451
. 0.1V
114
301Q
•
-
I9.6Q
-
19.7
S7.1
6.944
-
-
32.7Q
-
•ft
1.711
•
-
174
16.611
24
2.060
S72
0401
16.2
391Q
-
-
St.lQ
-
-
474
6.160
-
.
-
-
••
134163
-
-
77.2
10.169
15.600
3.1S7
461
O.OIQ
13.7
29SQ
-
2JQ
93.3Q
-
-
774
10.205
-
-
-
•
-
354Q
-
«•
19.3
16.03S
7.270
3JIO
405
0.05Q
22.1
156
0.44
14Q
61.3Q
-
-
€7.7
[CYANIDE (ai/kt) \
NA| »]
-i 'I -I -I
-------
TABLE 1
SUMMARY OF SOIL ANALYTICAL RESULTS
METALS AND CYANIDE
NATIONAL PIPE, VESTAL, NY
IOR1NC NUMBER
DEPTH (FT)
DATE
KB
1-10
4-21-11
B3
2-4
4-20-tt
13
4-6
4-20-U
B4
2-4
4-14-41
•4
»-10
4-14-U
BS
0-2
4-14-tt
BS
4-4
4-14-U
B5
+4
4-14-tt
BS
1-10
4-14-41
16
0-2
4-14-tt
B6
4-4
4-14-U
METAU
/hnimB
Aatiaaqr
Arwfc
Btriaa
BoyUte
Gbfata
Ctldoa
ChnafaoB
Cotah
Coppw
bee
IMA
MuBcnia .
ftfaiuae
M0c0y
Nfcfad
POCMRBB
Main
Urn
Sodius
TkiUimo
V.wdiaa
Zte
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
12.192
«•
.
22.4Q
-
-
9.206
-
-
1S.9
24,224
31.2J
4.664
771
0.02)
23.7
S30Q
.
.
M4Q
-
10.9Q
77.2
31,034
.
.
137.5
-
-
6.960
-
-
20.4
20/79S
2V
1.752
SS2
0.9SI
27.7
1052
-
2.1
140Q
-
-
120.7
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
10,300
•
13.00
42.1
0.02
ItJ
2.190
-
-
12.2
21.300
S.620
3400
411
0.10
62.0
76SQ
-
-
152Q
-
—
44.7
13,000
-
-
22.6Q
•
O.OIQ
54.500
-
-
11.7
29.100
13.4J
5,610
533
0.54
S7.1
994Q
-
-
155Q
-
-
«J
10.900
-
2.07
42.9
. -
349J
1.600
-
-
17.9
26.100
10,700
1.240
659
0.10
54.0
760Q
-
-
169Q
-
-
ttJ
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
13100
-
•
61.4
-
11.5
4S70
-
-
15.6
26,100
J7
3.400
365
0.10
37.2
S5tQ
-
-
203Q
-
-
69.6
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
JCTANIDEtet/fcl) I NAi -I -\ NA | -| -| -| NA I NA I -I NA I
-------
TABLE 1 (ccotmned)
SUMMARY OF SOIL ANALYTICAL RESULTS
METALS AND CYANIDE
NATIONAL PIPE, VESTAL, NY
BORING NUMBER
DEPTH (FT)
DATE
•6
1-10
4-14-U
•7
2-4
4-14-U
•7
4-6
4-14-SI
17
6-4
4-14-41
•9
2-4
4-15-IS
19
4-6
4-15-N
•10
2-«
4-15-11
•10
4*
4-15-11
•11
4-6
4-ll-U
Bll-D
4-6
4-ll-SS
•12
2-4
4-ll-U
METALS
yUupjputt
Antimony
Await
•tfiaa
•eryBiuin
Cidmiina
CticiBB
Chromium
Cebih
Cppjw
Im
Lad
Wt fTlff ilflfi
Mufuoe
Mmwy
Nifikd .
tawiBa
Selenium
Silver
Sodium
Thallium
Vuudium
Zac
10.JOO
4»
-
42.0
.
ft
5.560
-
-
ItJ
21,600
9.600
3.900
142
0.09
66J
«76Q
*
•
449Q
-
-
7U
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1,050
.
.
29 JQ
.
1.6W
14.900
• -
-
25.2
19.000
9.400
5.100
167
0.07
52.1
946Q
-
-
ItlQ
-
-
56.9
7.550
.
.
50.4
.
0.90Q
40400
-
-
156
15,100
100
4.630
S19
«•
14.1
4S1Q
-
-
C6.6Q
-
-
50.6
10.400
.
-
•5.5
.
1.2
4.600
-
• -
19.4
21.200
31
2.600
Ml
0.02Q
61.7
455
-
-
99
•»
-
47.9
10.900
.
-
43.0
-
1.1
2,010
-
-
25.0
23.900
19
3,240
3*4
0.03Q
17.1
»1Q
-
-
40.2Q
-
-
•2.6
9.310
-
-
41.7
-
3.7
1.660
-
-
20.1
22.700
22
3.040
495
0.07
26J
560Q
-
•
56.3Q
-
-
57.2
11.700
-
-
27 JQ
-
5J
1^90
•
-
12.9
35,700
22
107Q
11
0.07
37.2
It.lQ
-
-
129Q
•»
-
«J
11400
-
-
30.9Q
•
2.0
1050
-
-
12.6
32,900
17.900
3,040
393
0.07
34.5
956Q
-
-
126Q
-
4M>
70.0
17.700
-
-
60.3
-
205.0
1.660
-
-
14.4
22.200
22,200
U10
462
0.42
16.6
1.010
«w
-
157Q
<•»
-
77.1
(CYANIDE (at/kl) | -I NAJ NA I -I -I "I -1 -i -I -I -I
-Not
tok
NA FuuMttr ad mlyud
-------
TABLE 1 (cottmaed)
SUMMARY OF SOIL ANALYTICAL RESULTS
METALS AND CYANIDE
NATIONAL PIPE, VESTAL, NY
(BORING HUMBER
[DEfThffT)
PATE
•13
*-«
4-1*41
B14
4-6
4-19-41
BIS
2-4
4-19-41
B16
4-6
4-20-U
BIT
0-2
4-25-11
Bit
0-2
4-25-M
B19
0-2
4-25-U
B20
0-2
4-25-U
METALS
MV&iBQD
Aotiaoar
Amnfc
Btiiua
BoyOim
Cadate
Cridua
Cbreoam
Cebih
&W«
baa
IMA
JfipinriM .
MBPMK
Mcrcar
Nfckd
fttiifim
fataiua
SOW
Sodium
Tlulliaa
Vtttdte
Zte
«4J6
-
.
29.6Q
-
.
SUQ
-
.
-
14.106
2t
1076
169
o.m
I.IQ
240Q
-
•»
151Q
-
U.I
25.0
I2J84
.
.
42.4
.
.
967
.
.
.
11.463
22
1.S9I
MS
O.MJ
I^Q
6I2Q
.
4.1
155.9Q
-
-
39J
ll.MO
.
.
24.1Q
.
.
1.616
-
•
17.2
16.952
22JJ
1J7I
313
OJ4J
7.9Q
793Q
-
XI
M.3Q
-
.
44.7
114Q
.
.
S3.9Q
•
-
902Q
.
-
-
15.920
I0.6J
450Q
114
OM1
6.3Q
379Q
-
2.1Q
172Q
-
M.7
2U
13.621
-
.
57.9
-
U
241Q
OJ:Q
.
154
41.061
26.100
2,432
925
0.10Q
21J
267
.
1.7Q
65.4Q
.
.
S9J
13.614
-
-
27.7Q
0.4Q
-
1^99
.
-
15.5
27.149
14,100
4.941
657
0.20
23.6
49SQ
-
1.7Q
67.7Q
-
.
66.4
14.165
-
—
47.7
-
-
1I9Q
-
-
12.2
27.610
13.400
3.120
1,001
0.75
19.6
51IQ
-
1.6Q
103Q
-
.
69.0
12437
•
•
30.1
-
•
S50Q
OJ1Q
-
16.0
22.905
2.220
2,162
639
0.1Q
20.9
449Q
-
14Q
75Q
-
-
90.4
I -I
-1 -1 »l -I •] -I
-------
TABLE 2
SUMMARY OP SOIL ANALYTICAL RESULTS. METALS AND CYANIDE
NATIONAL PIPE. VESTAL. NY
BOMNQ NUMBER MW-1 MW-4
•5 MW-4 MW-7 MW-I MW-ID
MW-IO
MW-II
MW-12
IIW-U
MW-IS
n-t
DEPTH (FT)
§-10
10-12
1-10
4-4
15-17
4-4
4-S
5-7
40-41
DATS
12
9-ll-M
9-ll-U
-11-11
9-12-U
9-I-II
9-7-II
9-12-09
METALS
4
.
.
J.JI
J.SO
4.75
7.71
t.22
M.4Q
12.7
7i M
50.4
2*.M
27.11
14.31
25.71
4.3
.
.
.
.
11.4
11.7
M.3
II.
12.1
41.1
17.5
12.4
12.0
11.4
M.I
s.ioo
MJOO
W.J
11.500
I5.MO
15.200
14.900
10.300
19.300
MJOO
17.000
10.2
•.241
11.41
12. iq
2I.1Q
27.
•M.4
15.1
15.4
KM
W.9
1.MO
4.410
9.440
2.MO
1.739
1.740
1.770
4.250
2410
W30
M40
1.220
7U
497
404
154
IM
417
200
124
297
294
0.12
2.91
1.71
2.24
5.71
2.14
2.27
2.11
2.41
2.47
Nkfcd
94.7
M.I
21.5
12.9
5. IQ
II.4Q
I.72Q
M.2Q
1.99Q
1.70Q
r
.Q
I.40BQ
0.731
0.99
124
117
in
Mil
1941
1411
151
I2U
1451
I4.t
9.0
15.5
4IT 1M MS
44.1
51.4
49.9
41.1
11.5
41.4
52.5
49.0
1.1
-• -I -I -I
-I
-T -I 0.111 -I
"I
-I "I
-------
TABLB»
SUMMARY OP SEDD4EHT ANALYTICAL IESULTS
NATIONALIVE. VBSTAL. NY
-ID
•D-J
•D-7
- 10
I
-13
>27»M
4»z>»u
4-»-M
4»2»»M
4-2»-M
4»zr-M
-77-U
TcbBi
UJ-TncfctaraUm
XytaQMiI)
TKiNMta*
TMI MMiiiM
-
•
•
0
*
.
•
-
•
2
21
.
»
12
*
0
-
.
2MOE
.
12
7
1.0M
.
.
14
-
0
•
•
17
•
0
•
•
-
•
0
•
•
•
20
-
0
•
•
- •
•
0
•
•
21
•
0
•
10
•
-
•
0
•
4.00
9.000
41.000
t<00
3.000
11
U
11.400
1.110
4S.HO
40t.nO
»,no
to«.«o
IMJOO
MTTALt
S.OI5
4.141
5.171
1.00
•.)«*
•.MO
ltJD7
DOW
IOJM
U.U1
4.M*
44.«
J0.4Q
JD.7Q
M«Q
1MQ
40.1
0-fC
11. JQ
O.HQ
1.41
U
44.TO
u.ua
•JM
1.0
S.151I
VJQ
4W.MU
1.1
lt.7
ii.t
u.t
211
M.1
22.J
U.7
1S.I
mot
UJM
17.1M
14,007
».I07
20.117
M.7JO
2I.M*
11.145
11.HO
M.IOO
41.100
10.100
«.HJ
7JO*
20.7U
M.IMI
20.100
4.M*
S.OM.IQ
1J03
4.410
2.712
J.J»
Ml
4tl
if*
S2S
S4S
1.70)
1.171
MO
M*
Ml
OJQ
0.0*5
0.21
0.15
O.M
0.1 JQ
NitUI
•4*9
7.MQ
SJQ
17.10
21.40
17.29
20.10
2I«Q
4U.IQ
4M.IQ
4U.IQ
MOQ
110
SS1.IQ
»*Q
m.xj
lihw
11Q
J.70
•M
»M
1.4Q
MJ
74.«
m.iq
JJOQ
MM
M«.«Q
MS.IQ
411Q
1M.JQ
ZiM
MI.O
71.4 1114 M4J 2104 244.1 llf.7 M.O
-I
"I ''
"I
rflD-1
-------
TABLE 4
XBXN1BCB mSB X SPLIT SMfFLE CA3X
«tMSBt****IS(SSI»SSSStSSS»tSt*SSttl
i-lSu MS{i l-2Cn «-9 »-4 R-4 SMO 1-2|i
ttulaia 1IIOCP 10100 P 94100C P 14300 P 342 P 424 P 7920 P 19400 P 970 P 33 V.
ArMitti 14 EP 14EP1070E«P 34.3 P t.l V IV 12.3 P 27 P 10 PU IV
llMU 17 P 139) P 2940 P 92.4 JF 7M V 29.3V 24.3 MP 91.4 }P 700 PJ SHP
n.n P t,9i) P 19 IP 0.47 v iv i v o.si IP 0.44 v i v i v
1.2V 1.2V 12 P 1.2 W SV 9V 1.2 U«P 2.2 (HP 9V 9V
CoiVit 11.2) P t9.n P 990 I*PJ 11.3 IP IV IV *.9 V 19.1 IP !9V IV
Ceiptr 22 P 13 P 2990 P 77.1 P 1!* > 12.3V 23 P 3!.4 P 19V «|P
Iran 20300 P 23000 P 2.021 P 29700 P 751 P 1110 P 11000 P 41400 P 2100 PJ 1940 P
lilt 22 P .11 *F 1940HH «9.M«F 5.9 KJF «.2 V& 11.3 ««F 41.3 P 3 P 1.1 W*
19» J7F 20»E«P 23.1 JP IV IV 11.9 J> 31.9 J* 25 V IV
4:0»' & IP 24»o P 149 P u.7;« 17.9 p 127 P 179 p isco PE is» p
I? • 90 P 1195 P 19 EP 77.: JP 4I.J JP 14 EP 212 EP I'.OJ Pt 1« i*
17 V III' KM • 20.4 P •/ SV 12.2 i* 31.5 P 2! SP ! .?
4'iiwr 3.S F :.l* *(A It KF 2.9^* 2 P 9.1 & 24.4 S.'» 20 F ?F
:: VN^J i; JK»J FSA 7^ WJP :* ^ 29 v 7.2 ix* i:.s LUP D v ? i-
.!* Sffl .14 vK»i FJ» (.29 tv 2.3 W1 1 7 0.25U? J.4J UF 11* «.9 JST
c.44 i? 0.44 UF t:.4:«Fj c.s i? 2.: w 2.0 & o.so WF o.u v 4.0 i?x; 2.) s»
.joSBVM:w;v; »:» 0.1 KV c.:;tv uvcv o.iucv 0.2KV 0.2atv 0.20-
•u
V.lttr 2 i? 1.9 a? 4.4 9 2.2 KJ* l.t:.«» 4.C CS." l.t- IW» 3.1!«» 1C U? 4.: R."
:*;:u* :JID P :«n»245903 P 1340 P 3"--o P 39^00 P 99400 P 4J7& p wooo u n:^»
•stiit:.* :ii9: p ::w p ::wo P «ot IP 9i« i> :m P no i* 131; P 2050 UP zx v
Uiui :457j P U9S) P 22500 EP «U UP »t?0;; » |4W P 499 V 1*4 U» 24003 PJ 27US P
•ipnia 27itEP 2710 EP W9» P 3740 P |43J P ^M IP IMO P 4720 P 1I2GO PJ ir» P
Irtxlt 0.43 U 0.44 U 10 U 6.42 IMS 10.0 M IS.I U 0.42 U*S 1.1 U»S 10 U 10.0 m
tftnBt*tsusst(sswtt»x«ss(sts«ssttss*tm*MM*Mn*MMMMSttMMnusns*tuiMMttsnMMi««tssnss**ttsn(ntt»ssnt*t
ti»: * AK vil.it iri in uj/1 enlist wltt etJir«;n
8 ir.i;:itri ilnrt «•* I»*IT:>< <» >vt Mt t&< wtettiw 3iiit.
{ J ViM it griatir tftic or ta*tl t» instritMit Utictiw l;«:t tut 1m V-tf. tM cwtritt litictiea hut.
E >::cr.i( it titiutrd nl*t
-------
TABLE 5
Minim
MMMICMH
HUM Ml* IMAI
MBUMMRi
Mtllll
MMlM
MlMt
•rwlc
liriM
fctvllMt
tlMtol
ClIflM
OTMM*
bMlt
bpMT
ttm
Ittt
hfHtlM
•HMMM •
tmtrni
Mttri
MllllM
kintal
•liar
Mlw
tMlltei
tMftai
Itac
CwlM
CM! •. HIM
•mi
•m
JMM
M.MN
I.MI
IMM
I.MI
I.MI
IM.MI
M.MI
IMM
M.MH
W.M
I.MI
MI.MI
MM
••Ml
I*.M •
MM.MI
MH
M.MM
MI.MI
l.MM
M.MI
It.M
M.MI
. /
ntn V
MM.N ^
M.MI
M.M
Ml.M
I.MI
I.MI
HMt.M
n.M
II.MI
If. Ml
MM.MI
J.M
INM.M
IMI.M
•.Ml
n.M •
«M.MI
I.MMM
M.MM
IMM.MI
I.MMi
II.MI
Wf.MI
M.MI
/«BT»MWII
Mil */
! — ifiM
MM
1.1
11.1
I.UI
M
HM
ii.i
M.I
M.I
IWM
IMM
MM.!
tfM
MIM
n.t
IIW.1 1
•.»•
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m.iM
•.in
ii.i
M.I II
1.11
s
Mltll
' M.lV-~«
».IM
Ml
Ml
Ml
Ml
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Ml
Ml
Ml
M.t 1
I.M
IMI
' Ml
•.MM
M.M
Mil
Ml
Ml
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11.11
till
11.11
CtffM. IMM
IMtt ' ,
>44M*:M"
I.M M
M.MI
(I.M
•.til
•.MM
IMI.M
Il.M
f.MI
II.MI
MJM.M
M.MM
UM.M
Ml.M
•.Ml
n.M
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Il.M
•.MM
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1.11 1
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ME 6
r»c <& snc
umi nun. XDMM . «o SUFMX SM.
MIIOM. MK mum
90ffiKfm.ni f
KMtM.
MUeHM Itoltt*
Ml
Mt
Ml
IAW i/ian i/*m
mm*
bMt
ftn«y
Mewl
ftUMMl
U
u
u
u
tt
J
A
M
torn mtM
m
StlMT
tto
tMJ
ttac
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MMI
M
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M
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mm «Mt
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m/M
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mat
M
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mm
M
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mm
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M
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m *
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JM1/M)
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m
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M
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10
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M
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M
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m
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tt
1ST
2.M
^ ^^^fc ^^^^^^^^^.A ^A A^^^ ^^^k^^^^A^^K fl^^^Mk ^^^^^bAtfA^^ft ^^
1 Mi Mi MMEMi • Ml MHRMI I MR MKIf Mi VI
•MtratlM MtauC M>MUtwiH«MliMratw*UctMilMn«rhnfrMtM
tUwkri «tca«M IMt Mlfc AM fill MUrt*l to iMttmii MjraMta*. «MrMlMtely M/7 tat Mo* MMM*.
k« MM nwlU *««rr«Mt MtMM MlM MMte Mk IMrfU M MtlUM. (IA MthCDTl MlFX.
• •
fUVMlMr
-------
(cont'd)
MMMMfMTIOML WC COL SHE
SAK ESMK MOraOT
vr/a so* UNUS
UOEMNC AMLKtt
•^^^^^^^•W ^^^^»W^Ww
Illtai
MMi VW*
3/MVK 3/ll/8>
I/MI 3/ii/at in/*
Ctt»lt
ftranr
M4I
LM
U
.MM»
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t.M.t
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M
n
a
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f.M
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w
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13
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sn
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n
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M
1131
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M
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31
1MB
MM
IMJ
W
M
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n
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31
4)J»
nt
u
w
a
41
IM
u
330
MU
urn
Ml
M
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M
IMM
«n
m
a
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MTU
41
H4
HI
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II
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to
M
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14
133
Ml
Ml
a.3
M
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a
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j
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MI
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e
•
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Ml
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14
a
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IH4
• • iMKttai IMt taMoUtf * t* mlytH (U..
Ufl
Ow.l MU «• AUAtai Italt Ml Mt flv*.
Urn *tacttai IMt to IMt MlyiU «ffv» Av IM
talMt
-------
*•£ 6 (cont'd)
MMMBHIMIN1 MPf COL $Wf
saw/an, smis - OWN imtsaaf
BODMCMiaiS
ilWt
-------
MI 6 (cont'd)
IMC*
MMI MMI WM MMI «4MI
VttM HUM MM
HUM
Ml/01
yarn
vam
an*-
MIMl
Ik
nc
u-u
u-u
u-u
Ji-Jl
u-u
u-u
s
u-u
U-tt
M
u
M
n
mi
•
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tt
at
B
on
n
U
tt
U
M
M
J
tt
«
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0
4
nm
B
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M
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B
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ID
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n
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9
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fcl
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tv
N
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M
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4.4
9
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8
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IV
tt
IV
on
tv
40
SI
MS itt «kcM « •• AWItai IWk
It
I MB IMt.
IMtMuMfcJM
-------
UM.E 6 (cont'd)
•MINfCCN/MTIOWU. Hfl CO. SUC
SWSMFMC SOIL SAMPLES - MSTCIN SECTION
IMMfiANIC MM.VS1S
••Mitt !• Mrtt per MIIlM
taaatt M.
Ml*
NtMtlM
SS-04-Ot SS-04-M SS-Ot-OI SS-M-01
3/07/M 3/OI/M
9MT4I
SAMI
MM*
Ar*a«tc
•aria*
OarylllM
Calclwa
(Malt
N»rc«ry
•Ickal
NtaulM
S«lMla>
Sllvar
IkalllM
flu
IlM
Cyaala*
farcaat
1.3-l.t
t'.iV.t
ItMO
IftM
U
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t3
MM
M
t.t
ISS
•.II
t.t-3.1
l.t-l.t
11-3S
It-lt
Ik
3tM
3t3
tk
I.*
ir
13
M.t
13
9.1
n
MO
14
MO
IS30
. M
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IlM
it
M
J
•9.1
IMM
M
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43
HIM
ir
II
M
IMM
M
t.t
31
I.I
M
•740
II
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t3
U
31
II
tt
t
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II
0
•
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tt
a
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n
a
14
MM
Mt
M
23
9.1
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Mt
tt
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s
to
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4
tl.t
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t N)
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M 74
10
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tu tu
10 10
1M 04
1I«U
f*T Mt
tM
• • ftaUcttwi Halt* l»4lcal*4 ky Uk M«ly*l« (I.*.. Ant1«*«y • IM|.
f«r IMM l«*r»Mtc« «Mff« tto Matt* tM Ottc(l«i Halt «•• Mt (I«M.
•€•
Mt
!• prctMt Mt MWMt M fjM«tlfl«4 vlth »r«€ltlM MrMl ff«r that
(I4t/lt)
-------
6 (cont'd)
uumn. SNUS - usan tan
SS-IS-tl
I/U/M
i/um
11
u
a
a
V
II
a
•a
•
a
9J
9
«• I
•
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a
«
a
M
U
tt
Ml
•
a
M
•
»
•
10
»
tt
u
41
M
t.l
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14
t.i
fl
tt»M
14
WlOt
tt
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41
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14
If
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tittf
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8
•
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M
or
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•
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JM
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fl
lit
•
f.l
U
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M
17.1
M
MB
m
sts
M
M
91ft
M
t.t
M
14
•4
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U
u
N
M
10
a
u
10
as
CntM* H fmM M OMOt It
IM«ttailMt»MU
l» »*
(MMHV
-------
p»ge1 c'6
-:- * * -^-vlp, -'<; ••*• !?x •«...' ** *^ .. , -....-•''•! :•••»•»- •>«»'>.»:'. »•'.
Sptctrmc««000 (XRF) Uad Rtsutts in Soil
•^
Aum
A13C5
A13907
AUNB
A13M9.
A13W3
AOTIO
A13C6
A13W
A13827
A13TJ*
A13BB
A13777
AUO
A137»
A13CQ
A13779
AUO4
A1S7B
AUDI
A137B
A13GB
AU7B
AUO)
AU0
AUDI
AU7B
AUDI
Auas
AU7M
AUKM
AUDI
Ij^attta/Dnh
•^••MMf 4VWJ^H
A- r
A- r
A- r
A- r
- 4*
-1 S1
-i r
-ar
-a r
-sa-
-» r
A-42"
A-4 r
A-S r
A-5 r
A-« r
A-4 f
A-ir
A-7 r
A-tr
A-t r
A-t r-
A-» f
A-10 T
A-» r
A-J»3^DUT)
A-ie r
A-U r
A-XI r
A-II r
A-s r
A-n r
i*
tacta)
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ar
4S
4*
*
43
at
as
32
4i
a»
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41
41
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44
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9
V
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a
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r
as
lUpocud
fb
(ktAt)
433
a?3
4S3
4<3
as3
423
. 93
93
93
*3
93
93
93
•m
•
413
513
«
ND
313
413
473
93
93
44
443
93
913
4S3
23 J
as3
•7
as3
-------
psge2of 6.
ifcXvit-; t:Tibto i (con$ -i7.. •
^Spectmet 9000 (XRF) Uad R»»utt» in Soil
:^^SfeS^v^.1N.v^B^
.*.„•*•• "I. • .' JJJJ-- * ••" *-X- •' - • -"- -jigy^ '* "'"".• % . • . \ •••••x- f* £* ...
^^•^"^^•bruary.1992'^-r
/Dcptt
A1M1
A1S7B
Aasns
A1SW.
AUN5
A1STV
A13M
Aisno
A13H5
Aim
AJJ7B
Aim
AUMC
A137M
A1S7B
,-n r
A-B r
A-B r
A-U r
*—11 ^
A-M r
A-M r
A-M r
A-M r
A-IS r
A-U r
A-M r
A-M r
.-» r
A-W ««
A-M r
A-M r
A-M r
>—if a*
.—if ^
A-3D r
A-ao axpur)
A-ao r
A-a r
a r
A-a r
A-ar
A-a r
A-ar
A-a r
A-a r
A-a> r
aoj
3»J
34J
?»
27
90
90
» J
51
S7J
MJ
81
52
S4
a
34
8f
40
a
8
59
40
59
80
87
17
41
51
11
8
343
aj
34}
40J
aj
8
59
40}
59
80 J
S7J
81
3JJ
41}
51
ND
-------
page 3 of(
^Spactrac* 9000 (XRF) Laad Results in Soil
:<«peciFBCa 9000 pw
.S^ft ^ iW vftob
. •;-.•• ••"••:.v.': •"•.:>*••••
• ••;•-.. • . *• A '•• A--.
n
/
A1S7K
AUM9
AUW7
Aasm
AUBS
AUHD
Aum
AUIS
AUBS4
AUHB
AUKS
AUKD
AUttf-1
AUUt-2
A13B7
A-24 r
A-24 r
A-25 r
A-25 C
A-2C r
A-M r
A-27 r
A-r
>-r r
,-at r
A-a r
-a r
,-a> r
-» r
,-jo r
A-SO r
A-SI r
,-9i r
,-a r
A-n r
,-92 r
,-92 r
A-93 r
,-as r
A-94 r
AM07
Aism
AUTO
r
A-9S r
A-S5 r
A-* r
A-s« r
97
21
24
as
24
25
as
a«
is
35
21
IS
21
20
It
90
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92
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24
43
27
U
17
ao
25
r)
21)
24)
2S)
20
95)
2S)
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25)
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20 J
It)
90)
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92
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2t)
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27)
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22)
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22)
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as)
-------
page 4 of 6
Speetrace 9000 (XRF) Uad Results In Soli
4 : Mlobintech \; :?' ^
^"•".
February, 1992
s:
A13T7
AUI*
A13T»
A13HO
AUKB.
Airat-i
AUMt-2
A137a(-9
A1DS5
Aian>
Auno
A13XO
A»B
AI37J4
AI37SJ
AI37S
AUTO
A137S9
AUM5
A13TB
Aun<
AUM4
Aum
Aum
Aisnr
A13K7
Aim
A0Z9
AUM
A13NI
A1IMD
AU96
l^Mte/Doik
^^•^v^OT » ^rvy^v
A-M r
A-M 9
A-M r
A-M r
A-M r
i-»r
i-isr
B-tsr
•-MT
•-M r
B-M r
»-M r
B-M IT-
»-r r
B-M r
B-9 r
B-40 «•
1-41 r
B-4i r
B-4i r
B-4i r
B-41 4*
B-41 C
B-41 r
c-« r
C-42 V
C-4J «*
c-44 r
C-44 1*
C-43 f>
C-4C r
c-«i r
fft
(VtEt)
24
25
8
a
tt
V
8
$4
M
27
If
30
a
8
90
M
1M
31
24
21
29
8
19
29
41
17
54
»«
41
MS
•n
M
fb
Cw/kc)
244
29J
82
8J
24J
193
211
MJ
M;
713
19J
20 J
23 J
8J
9*J
24J
1M
MJ
24 J
212
292
82
MD
292
4)J
1TJ
54
244
412
149
71
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ND-
2-
Nel
-------
page 5 of 61
7{eon't)
S^£^jN9 ex**) **•* Rwute In Son
flobintt-ch
A13K)
AUMf-1
A137M-2
A1W4-J
A8Nfel
AlSMf-2
ABHt-S
AX37C7
AIM
AUTO
C-50
C-51
C-51
C-51
C-fi
c-a
c-a r
C-53 r
C-54 r
C-55 r
r
D-57 r
r
104
40
40
St
a*
40
M
S4
ss
41
45
30
3B
104
40
40
342
55
41
'45 3
30J
AUTO
AUR4
Aians
A13OD
AI3B7
Aunt
r
B-« r
E-43 r
r
E-44
E-45 T
r
E-47 r
37J
2§J
u
24
a
A13M5-1
F-S7 r
i r
F-5t r
r-5f »•
r-5t r
r-5f €
V
f*
ISJ
24 J
2>J
20 J
SJ
2IJ
» i
25 J
77
311
2JJ
S5J
fta
-------
Table 7 {con'i) ,._ .
^Sp«ctrtc« 9000 {XRF) UadJRtaults in Soil
Jtoblntech
ft.
(•**«)
A13NO
Aiano
AUTO.
A1JIK
Aiano
AUIM
f
F-«o r
F-40 C1(DXJ7}
F-« ir
ip
F-O r
r
r
0*^0 r
REF-J r
HEF-2 r
MEF-s r
11
n
•5
SI
UB
S4
S»
SP
2550
J2
fl
ND
fl
15
103
7)3
341
S»J
50 J
2350
S
ts
ND*
J-
-------
CORFZBATXQR SAMPLE SRCRACB 9000 XR7 AMD METAL ANALYSIS 1ZSULTS
•g/kg LEAD (Pb)
ftOlXNTECB SITE
ISB&OARY 4-«. 1992
SAMPLE
NUMBER
A13832
A13791
A13851
A13799
A13755
A137S1
A13775
A13759
A13761
A13763
A13766
A13809
A13816
A138C8
A13898
A13900.
A13765
A13750
A13B86
A13889
A13924
DRXCTZOK
SAMPLE
LOCATION
•9 2"
•IB €•
•26 2*
•26 €•
•36
•40
B-41 3-
C-44 .
C-45
C-50
C-52
D-57
E-64
F-59 1*
F-59 3*
F-59 5'
C-53
B-41
F-63 1'
F-60 6MDUP)
REF-1 2*
LIMIT
8FBCTRACS
ZRF ag/kg Pb
>9
19
3)5
23
16
131
21
144
145
104
216
Cl
19
18
15
11
40
18'
27
•5
2550
15
METAL ANALYSIS
•g/kg Pb
22
9
11
14
18
140
29
190
160
100
200
110
•
10
7
5
24
21
. €
68
2100
5
-------
Tabb 9
9000 XRF
Xante (at/kj)
|tefriii*fh. Inr
V«ul, Nw Y«k
9-11,1992
Rf-SAMPLE ID
SD-1
SD-1
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-2
B-4
B-4
B-5
B-5
B-5
SD-6
SD4
B-6 .
B-6
B4
B-6
B-7
B-7
B-7
B-7
SD4
SD4
—
SD-9
SD-10
SD-11
B-ll
B-ll
B-ll
SD-12
B-12 -
B-12
B-12
REAC CAMPLE ID
1SD
• 1ASD
2-0*5
2-1* S
2-rs
2-24* S
2-3' $
2-5' S
2»rs
24'S
2-9* S
2-10' S
44* S '
4-10* S
5-4* S
5-5' S
5-6* S
6SD
6SDDUP
64' S
64'SDUP
6-10' S
6-10' S DUP
74* S
74* S DUP
74* S
74' SOUP
SSD
ISDDUP
IASD
9SD
10 SD
USD
IW S
ii-rs
114' S
USD
12-2' S
U-J'S
12-4' S
CLIENT SAMPLE ID
B17242
B17243
B17251
B17252
B17253
B17254
B17264
B1726S
B17266
B172C7
B17268
B17269
B17270
B17271
B17258
B172S9
B17260
B17244
B17244
B17274
B17274
B17275
B17275
B17272
B17272
B17273
B17273
B17245
B17245
B17246
B17247
B1724I
B17249
B17261
B172fi2
B17263
B17B50
B1725S
B17256
B17257
Pb
ND»
ND
ND.
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
44 1»
ND
ND
ND
ND
ND
ND
ND
ND
79J
19 J
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Dtfi ttta fiomdnft
MeOana/Hift
J-dtootH tthebbdow
bvwtifiiioo Import,
1990.
Uate
tititica Unit
Pk » 42
Pk » 140
Pip* Co. Site.
-------
APPENDIX
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL
CONSERVATION LETTER OF CONCURRENCE
-------
New York State Department of Environmental Conservation
50 Wolf Road, Albany, Ntw York 12233
Thomas C. Jorilrig
Commissioner
1 2 1993
Mr. George Pavlou, P.E.
Acting Director
Emergency & Remedial Response Division
U.S. Environmental Protection Agency
Region n
26 Federal Plaza
New York, New York 10278
Dear Mr. Pavlou:
Re:
Robintech Site, Vestal, Broome County,
New York, Site No. 7-04-002
UK Record of Decision (ROD) for the Robintech site operable unit No. 2 (OU2) was received
by mis office on March 3, 1993. Bom the New York State Department of Environmental Conservation
(NYSDEC) and the New York State Department of Health (NYSDOH) have reviewed this document.
OU2 addresses site related contamination of soil ^4 sediment suspected to be contaminated with
lead. Hie recommended alternative in this ROD for OU2 is no action. This remedy was selected
because confirmatory data performed by the U.S. Environmental Protection Agency (USEPA) determined
that lead contamination is not present at levels requiring remediation.
By means of this letter, the NYSDEC and the NYSDOH concur with the remedy recommended
by the March, 1993 ROD.
If you have any questions, you may contact Mr. Robert W. Schick, P.E., of my staff, at
518/457-4343.
Sincerely,
Ann Hill DeBarbieri
Deputy Commissioner
Office of Environmental Remediation
cc: C. Petersen, USEPA
M. Hauptman, USEPA
M. Granger, USEPA
A. Carlson, NYSDOH
-------
APPENDIX TV
RESPONSIVENESS SUMMARY
-------
RESPONSIVENESS SUMMARY
FOR OPERABLE UNIT 2
OF THE
ROBXHTZCH, INC./NATIONAL FIFE CO. 8UFERFUHD SITE
TOWN OF VESTAL/ HEW YORK
Section Paa«
INTRODUCTION 1
I. OVERVIEW. ....2
ZZ. BACKGROUND OH COMMUNITY INVOLVEMENT AND CONCERNS 3
ZIZ. SUMMARY OF QUESTIONS AND RESPONSES FROM THE
PUBLIC MEETING CONCERNING THE ROBZNTECH, INC./
NATIONAL FIFE CO. BUFERFUND 8ZTE 4
-------
RESPONSIVENESS SUMMARY FOR THE
ROBINTECH, INC./NATIONAL PIPE CO. SUPERTUND SITE
OPERABLB UKIT 2
TOWN OF VESTAL, MEW YORK
INTRODUCTION
This Responsiveness Summary provides a summary of citizen's
comments and concerns and the U.S. Environmental Protection
Agency's (EPA's) responses to those comments and concerns regarding
the Proposed Plan for the Robintech, Inc./National Pipe Co. Site
("the Robintech Site" or "the Site"), Operable Unit 2 (OU-2). EPA,
in consultation with the New York State Department of Environmental
Conservation (NYSDEC), will make a final determination regarding
the proposed no action alternative for OU-2 of the Robintech Site
only after reviewing and considering all public comments received
during the public comment period.
EPA held a public comment period from December 31, 1992 through
January 30, 1993 to provide interested parties with the opportunity
to comment on the Proposed Plan for OU-2 of the Robintech Site. A
public meeting was held to discuss the investigatory history for
OU-2 of the Site and to present EPA's preferred no action
alternative. The meeting was held at the George F. Johnson
Memorial Library in Endicott, New York on January 12, 1993 at 7:00
p.m.
Community interest regarding the Site and EPA's Proposed Plan was
moderate. Questions on OU-2 were oriented toward clarification of
EPA's assessment of the total data set for soils and sediments and
there were several inquiries of a technical nature. Several
questions were raised regarding the status of the OU-1 groundwater
remedy. Approximately 15 people attended the meeting. The
audience consisted of local businessmen, residents, and state and
local government officials. The question and answer session lasted
approximately 40 minutes. A summary of the questions posed during
the meeting is provided in Section III, below.
This community relations responsiveness summary is divided into the
following sections:
I. OVERVIEW: This section briefly outlines the EPA's
preferred alternative.
II. BACKGROUND: This section provides a brief history of
community concerns and interests regarding OU-2 of the
Robintech Site.
III. COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS,
COMCERM8 AMD RESPONSES: This section summarizes comments
received by EPA at the public meeting for OU-2 of the
Robintech Site.
-------
Z. OVERVIEW
At the time of the public comment period, EPA published its
preferred alternative for OU-2 of the Robintech, Inc./National Pipe
Co. Site ("the Robintech site" or "the Site") located in the Town
of Vestal, New York. EPA screened possible alternatives, giving
consideration to the following nine key criteria:
• Threshold Criteria, including:
overall protection of human health and the
environment; and
compliance with Federal and State
environmental laws.
• Balancing Criteria, including:
— long-term effectiveness;
— short-term effectiveness;
reduction of mobility, toxicity, or volume;
— ability to implement; and
— cost.
• Modifying Criteria, including;
— state acceptance; and
— local acceptance.
EPA weighed State and local acceptance of the remedy prior to
reaching the final decision regarding the remedy for OU-2 of the
Site.
The Agency's selected remedy for OU-2 is no action. This decision
is based upon the review of all available data and the Risk
Assessment. Based on a comprehensive review of all data generated
for the Site, a no action decision is protective of human health
and the environment.
This plan satisfies the threshold criteria for remedy selection and
obviates the need for long-term treatment and management.
-------
II. BACKGROUND
Community concern has not been high regarding the Site-related
contamination of soils and sediments. It appears generally
understood that a full assessment of all data generated for the
Site indicates that the data upon which the suspicion of elevated
lead concentrations in soil and sediment had been based was
erroneous.
EPA's community relations efforts began in August 1986. At that
time a community relations plan (CRP) was formulated, including an
outline of community concerns and a comprehensive list of federal,
state, and local contacts. Also at that time, site information
repositories were established, one located at the EPA Region II
office in New York City and the other located at the Vestal Public
Library in Vestal, New York. The information repositories, which
contain the RI/FS Report and other relevant documents, were updated
periodically.
Revising and updating the CRP, including an updated outline of
community concerns and an updated contact list was initiated in
April 1991. The CRP was finalized on May 1,1992.
To obtain public input on the proposed remedy, EPA held a public
comment period from December 31, 1992 through January 30, 1993.
The EPA Proposed Plan, describing the Agency's proposed no action
decision for OU-2 of the site, was sent to the information
repository and distributed to citizens and officials on EPA's site
mailing list for review at the opening of the public comment
period.
A public meeting notice appeared in the December 31, 1992 edition
of the Binghamton Press & Sun Bulletin, and a public meeting was
held on January 12, 1993. Community interest regarding the Site
and EPA's Proposed Plan was moderate. Questions on OU-2 were
oriented toward clarification of EPA's assessment of the total data
set for soils and sediments and there were several inquiries of a
technical nature. Several questions were raised regarding the
status of the OU-1 groundwater remedy. Approximately 15 people
attended the meeting. The audience consisted of local businessmen,
residents, and state and local government officials. The question
and answer session lasted approximately 40 minutes. A summary of
the questions posed during the meeting is provided in Section III,
below.
-------
IZZ. COMPREHENSIVE SUMMARY OP MAJOR QUESTIONS, COMMENTS, AND
CONCERNS, AND BPA'S RESPONSES
This section addresses comments received by EPA during the
public comment period (December 31, 1992 to January 30, 1993) .
The following verbal comment* were from the public meeting
held at the George F. Johnson Memorial Library in Endicott,
New York on January 12, 1993, and are categorized by topic.
No written comments were received during the public comment
period.
Several comments and questions were received regarding the
perceived lead contamination at the Site. Throughout the
meeting EPA emphasized that a comprehensive analysis of all
data generated for the Site since 1985 indicates that there is
no lead problem in soils and sediments. Specific inquiries
and EPA's responses are summarized below.
1. Several citizens, including the Vestal Town Supervisor,
the Chairman of the Vestal Advisory Commission, and a
resident who lives within 100 yards of the Site, inquired
about the levels and possible sources of lead at the
Site. The Town Supervisor suggested that numerous leaded
gasoline storage tanks which were used in Vestal from the
1940s to the mid-1970s may have been a potential source
of contamination. He also expressed concern about
improperly handled gasoline spills which occurred during
this period.
EPA Response. The highest lead concentration detected in
Site-related soils and sediments during EPA's two 1992
resampling events at the Site, which included the analysis of
over 200 samples, was 350 parts per million (ppm) with most
values under 100 ppm. The 2,550 ppm value reported in a
background sample and discussed on Page 6 of the ROD was not
collected from soil or sediment related to the Site.
Regardless of the history of the area, a comprehensive
analysis of all data generated for the Site since 1985
indicates that there is not a lead problem in soils and
sediments associated with the Site. This analysis further
indicates that the McLaren/Hart samples reporting extremely
high lead levels were in error..
2. A resident asked if EPA had considered the possibility
that facility activities had resulted in contamination
other than lead, particularly tin or oil. He reported
that circuit board printing, soldering, and processes
-------
involving hydraulic damping equipment have occurred at
the Site in addition to the manufacture of PVC pipe.
EPA Response. A historical search is conducted as a routine
step in the RI process. EPA reviews historical information
about a site in order to identify possible past sources of
contaminant release. Depending on what operations have
occurred at a site, different contaminants are more likely to
be found than others. At the Robintech Site, the risk
assessment for the site (written by an EPA contractor) as well
as available Federal and State guidance values had indicated
that lead was the only contaminant of concern for soils and
sediments. The result of this finding was to create a second
operable unit to further investigate this suspected
contamination.
3. The Chairman of the Vestal Advisory Commission requested
clarification of the nature of the error associated with
the McLaren/Hart data. The Chairman went on to ask if
the error in calculation could be pinpointed.
BPA Response. Upon suspicion of an error in the McLaren/Hart
data, EPA requested McLaren/Hart to recheck their data
validation. McLaren/Hart reported that the data had been
validated properly. Still suspecting an error, the next step
was to request McLaren/Hart to recalculate their data from
scratch. When the data were recalculated, the results
differed from those originally reported by an order of
magnitude. Although this discrepancy was sufficient to
question the validity of the McLaren/Hart data as it related
to reported lead values in soil and sediment, EPA made the
decision to resample the exact locations, including the exact
vertical horizons, from where the McLaren/Hart samples had
been collected in order to ensure that no significant lead
levels existed at the Site. EPA collected new samples from
virtually all of the McLaren/Hart sampling locations where
elevated lead concentrations had been reported. Because most
of the Site is paved, suspected elevated lead concentrations
in the soil would have been unlikely to diminish between the
McLaren/Hart and the EPA sampling events. EPA's results,
which included collection and analysis of almost 200 samples,
did not indicate elevated lead levels in soil and sediment.
In terms of uncovering the exact nature of the calculation
error, it would be a very complicated and time consuming
endeavor to unravel the exact nature of such an error. EPA
opted to return to the sampling locations where elevated lead
concentrations had been reported (analyzing many'more samples
in addition to these locations while in the field) rather than
pursue the exact nature of the calculation error. In this
way, EPA was able to produce tangible, reliable, and most
-------
importantly, timely evidence that the elevated concentrations
reported in the McLaren/Hart data set were in fact erroneous
and that conditions at the Site, with respect to OU-2, were
protective of the community.
4. A representative from the Broome County Health Department
asked about the results from background samples collected
near the Site during EPA's two 1992 sampling events.
EPA Response. Of the three background samples collected in
soil near the Site, one sample contained an elevated
concentration of lead. Since this sample was collected from
an area where it was evident that household refuse and motor
oil, cans, and filters had been disposed, this contamination
was not considered Site-related. Lead levels in the other two
samples were both under 100 ppm.
5. A citizen asked who had originally analyzed the
McLaren/Hart samples.
EPA Response. McLaren/Hart used Enviropact Services, Inc. to
analyze their samples.
6. The Chairman of the Vestal Advisory Commission asked
about the effects of lead on children who might come into
contact with soils when playing at the Site.
EPA Response. A comprehensive analysis of all data generated
for the Site since 1985 indicates that there is not a lead
problem in soils and sediments associated with the Site.
Further, this assessment indicates that the McLaren/Hart
samples reporting extremely high lead levels were in error.
In a hypothetical scenario involving lead contamination in
soils, a risk assessor would calculate risk by assuming
exposure to a certain amount of contaminated soils at a
certain frequency over a certain length of time. These
assumptions would depend on the age of the exposed individual,
the depth of the contaminated soils, and other factors. For
lead, EPA currently adheres to guidance that specifies a range
of 500-1000 ppm to protect human health. For lead in soils
and sediments this guidance range was designed to be
protective of children. The lower and more protective value
of 500 ppm was selected by EPA as a threshold value for the
Site.
Though the Site is not considered a source of risk as far as
lead is concerned, citizens are encouraged to contact the
local Health Department for more information should they be
-------
interested in learning more about the risks associated with
lead-related exposures.
7. The Town Supervisor asked if lead concentrations in soil
could contaminate the water supply; he also asked if
there are any safe levels of lead in drinking water.
EPA Response. A comprehensive analysis of all data generated
for the Site since 1985 indicates that there is not a lead
problem in soils and sediments associated with the Site.
Further, this assessment indicates that the McLaren/Hart
samples reporting extremely high lead levels were in error.
Hence, EPA has concluded that there is not a source of lead in
Site-related media that would contribute to groundwater
contamination. Please note that Site-related ground water
will be retested for metals (including lead) before being
treated, as metals may interfere with the operation of the air
stripper.
EPA has established an action level for lead in groundwater of
15 parts per billion (ppb) . Simultaneous filtered and
unfiltered samples were collected from all monitoring wells
during the course of the RI. Sampling results from two
unfiltered samples were slightly above the action level (MW-
10, 23.5 ppb/MW-ll, 29.2 ppb). Results from the corresponding
filtered samples from these monitoring wells, however,
indicated no lead present whatsoever. For the remaining
groundwater samples most lead results indicated that no lead
was present. For the few detections of lead reported in
groundwater, all were at or below 10 ppb.
8. Several citizens asked if EPA would conduct any future
sampling or monitoring of soils at the Robintech Site.
EPA Response. EPA has completed its investigation of
suspected soil and sediment contamination at the Robintech
Site. Lead was the sole contaminant of concern for OU-2 of
the Site, and EPA has concluded that there are no elevated
concentrations of lead in Site soils and sediments. Further
sampling or monitoring activities are considered unnecessary.
* Pnit l (OU— 1) Conffiffipation
A citizen asked about the distinction between the two
operable units at the Site. Another citizen asked if the
ground water monitoring schedule described in the Record
of Decision (ROD) for OU-1 would be affected by a No
Action decision for OU-2.
-------
EPA Response. The ROD issued for OU-1 (ground water
contamination) will not be affected by the ROD for OU-2. The
ROD for OU-2 relates to soils and sediments only. Ground
water monitoring activities will be conducted as stated in the
ROD for OU-l. EPA made a distinction between the operable
units so that the known problem (ground water contamination)
could be addressed as soon as possible while at the same time
allowing further investigation of the suspected lead-
contamination of soil and sediment. Currently, the
groundwater remedy is in the early stages of the design
process.
2. A Vestal Town Councilman asked if ground water at the
Site would be pumped out of the aquifer and treated with
an air stripper.
EPA Response. EPA will proceed with the ground water
remediation as described in the ROD for OU-1. The process
will involve pumping ground water out of the aquifer and using
an air stripper to remove volatile organic compounds (VOCs).
Treated groundwater can either be used in the plant processes
or discharged at the facility's permitted outfall.
3. The Vestal Town Supervisor expressed concern about the
discharge of ground water into the river. He cited past
problems that the town has had with discharges into the
river. He also asked how the pumping system would be
structured.
EPA Response. All discharges from the plant, including the
discharge from the air stripper, must comply with the
facility's existing State Pollutant Discharge Elimination
System (SPDES) permit. The permit takes into consideration
the fact that the effluent ultimately enters the Susquehanna
River. The State of New York has designated the river as a
Class A water body, which means that it is considered
protected.
Three areas requiring treatment have been established at the
Site. Water will be pumped from these three areas to the air
stripper for treatment. The extraction and treatment systems
will be fully modeled and tested before implementation. Air
discharges from the air stripper must comply with NYSDEC
standards.
4. A citizen asked where the ground water will go after
treatment.
8
-------
EPA Response. Once the ground water is treated, the plant has
the option to use the water in the pipe production operation
or to discharge it under their SPDES permit. EPA anticipates
the plant will decide to reuse the treated water in their
operations.
5. A citizen asked if the plant currently holds an SPDES
permit.
BPA Response. The Robintech plant has held an SPDES permit
since 1981. The plant is required to have this permit because
their operations include using water to cool newly formed PVC
pipe.
6. A citizen asked how often the aqueous discharge from the
air stripper will be monitored, and whether the plant
would be informed beforehand. He also asked what type of
corrective action would occur if the plant was not in
compliance with standards.
EPA Response. EPA will be involved throughout the remedial
process, overseeing the PRPs during sampling, testing of
equipment, and other aspects of the design, construction, and
operation of the extraction and treatment system. In
addition, EPA will be approving or disapproving any
modifications to the system. The aqueous discharge from the
air stripper will be periodically monitored with EPA
collecting split samples for verification purposes.
Monitoring will be conducted using 10 to 15 wells, including
some new wells constructed specifically for the remedial
project. In addition, the regular monthly monitoring of plant
discharges associated with the SPDES permit will supplement
the new monitoring program. Should the groundwater extraction
and treatment system fail to achieve the level of removal of
contaminants required, EPA would require the PRPs to modify
the system to achieve these goals.
7. A citizen requested clarification of the relationship
between the SPDES permit and the Superfund investigation
at the Site.
EPA Response. From 1966 to 1983, the Robintech plant used
public water in their operations. In 1981, the plant obtained
an SPDES permit. The plant installed its own wells in
December 1983. A routine analysis of the plant's effluent
collected by NYSDEC in 1984 showed contaminants present that
were not listed in the permit. Further investigation into the
source of these contaminants led to the conclusion that they
originated in the groundwater beneath the Site. The Site was
-------
placed on EPA's Superfund National Priorities List in June of
1986.
8. A citizen asked which series of analytical method is used
to evaluate the plant's SPDES parameters, as different
series are associated with different detection levels.
EPA Response. According to NYSDEC personnel, the series of
analytical method utilized by NYSDEC for the Site pipe
production facility's SPDES permit in their grab samples is
the 600 series. This is the series associated with
wastewater. The specific analytical methodology would be
either 601 or 624. This is in accordance with 40 CFR Part 136
of the federal guidelines regarding the testing of such
effluent. The analytical method utilized by the pipe
production facility to monitor their effluent for their SPDES
permit would follow suit accordingly.
Other Issues
1. The Vestal Town Supervisor asked why the meeting was
being held in Endicott, New York as opposed to Vestal,
New York. He stated that residents from the Town of
Vestal were not well informed of the meeting and so were
unable to respond properly, as evidenced by the small
turnout compared to that for a previous public meeting
for OU-1 which was held in Vestal Town Hall. He said
that he could have secured a room in Vestal to conduct
the public meeting. He requested that the EPA conduct a
second hearing for OU-2 in the Town of Vestal.
EPA Response. In December of 1992 EPA attempted to secure a
meeting place for January of 1993 in the Town of Vestal.
Several town representatives of Vestal informed EPA that no
meeting spaces were available. While the preferable location
for the meeting would have been in Vestal, EPA concluded it
was appropriate under the circumstances to accept a nearby
location in order to present the findings in a timely manner.
EPA uses a variety of approaches to disseminate information to
the public. Approaches used for informing the public about
the Robintech Site meeting and public comment period for OU-2
included press releases to local newspapers, announcements on
radio and television, mailing information directly to local
officials and concerned citizens included in the mailing list
for the Site, and paid public notices published in local
newspapers. The press release, mailing list, and public
notice information was communicated clearly, accurately, and
within an appropriate time frame. For the most part the radio
and television information was communicated correctly and
10
-------
accurately, though the Town Supervisor pointed out that he had
seen a television announcement that had communicated the wrong
meeting location. This was the basis of his request for a
second hearing and his basis for claiming a low turnout.
EPA does not feel that a second meeting is justifiable or
necessary. In almost all instances, information concerning
the location and time of the public meeting was communicated
correctly. EPA cannot control or be held accountable for the
accuracy or content of the public media.
2. A citizen expressed concern about other contaminant
releases by the plant. He described a contaminant
release to the air that had occurred on Thanksgiving
night, 1992. The release was reported to the Broome
County Health Department as a discharge of a large volume
of chemicals into the air, described as butyltin
mercaptide ethyl sulfide. He was concerned that the
plant was not being governed properly and felt that the
EPA should work closely with the local agencies to ensure
the plant's compliance.
EPA Response. Butyltin mercaptide ethyl sulfide is not a
hazardous substance listed under Section 102(a) of the
Comprehensive Environmental Response, Compensation, and
Liability Act ("CERCLA"), and does not appear to be a
substance the release of which would trigger the reporting
requirements of CERCLA $103 or Section 304 of the Emergency
Planning and Community Right-to-Know Act ("EPCRA").
Nevertheless, the November 26, 1992 release of butyltin
mercaptide ethyl sulfide at the Site was reported to NYSDEC's
Region 7 office located in Kirkwood, New York, who responded
to the scene. This particular release does not appear to be
one which required a response action by EPA under CERCLA.
As a general matter, where a hazardous substance is released
from a facility in an amount which equals or exceeds the
reportable quantity for that substance, the person in charge
of the facility, or the owner or operator of the facility,
must immediately notify the National Response Center, the
State Emergency Response Commission, and the Local Emergency
Planning. Committee and provide certain information. Such
notification helps insure that federal, state and local
officials can properly respond to environmental emergencies.
Not all releases of substances require a response action.
The pipe production and electronic cable assembly facilities
are periodically inspected by NYSOEC under various
environmental statutes. The effluent from the pipe production
process is sampled and sent to a lab for analysis on a monthly
basis under the SPDES program. The cable assembly operation
11
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operates under a MYSDEC air permit. The pipe production
facility operates under 15 air permits which are inspected
annually by NYSDEC or upon a reported release. In addition,
EPA regulates the pipe production and electronic cable
assembly facilities as small generators under the RCRA
program. Both facilities are inspected annually under this
program.
12
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ADMINISTRATIVE RECORD FILE INDEX
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01/05/95 Indax Oocuaant Niafear Order Page: 1
ROMHTECH IMC./HATIONAL PIPE CO. SITE. OU 2 Oocuaants
Oocuaant Nwfear: MT-001-0001 To 0297 Data: 03/01/92
Titlt: Skatt Estata Soil Sailing Investigation, Robintach site, Vestal, Mm York, Final Report
Type: REPORT
Catagory: 2.2.0.0.0 Saopling and Analysis Data/Chain of Custody
. Author: Millar, David N.: Environmental Response Tea* (ERT)
Sprcngar, Nark 0.: Environaantal laapenaa Taa> (E«T)
toeipiant: nena: US EPA
Docuawt Mu*ar: UT-001-0298 To 0450 Data: 12/01/92
Titla: Final taport Soil Sampling Invastigatien, Robintacti Sita, Vaatal, NT
Typ»:
Catagory: 3.2.0.0.0 Sampling and Analysis Data/Chain of Custody form
Author: Numay. Kamath L.: EnvironaMttal lasponsa Tasai (ERT)
Sprangar, Nark 0.: Environaantal Rasporaa Taa* (ERT)
Racipiant: nona: US EPA
Docuaant Nuit»r: UT-001-0451 To 0515 Data: 12/21/92
Titla: Robintach Inc. /National Pipa Co. Sita Raport on Suspaetad Laad Contaaiination in Surfaea Soils,
Subsurfaea Soils, and Sadiaents
Typa: REPORT
Catagory: 3.4.0.0.0 RI Raports
Author: nona: nona
Racipiant: nona: nona
Oocuaant Nuabar: RtT-001-0516 To 0518 Data: 09/07/89
Titla: (MasB oHseusaing astabltsliing an Intarii guidanca for soil laad cleanup lavals at Suparfund
sitaa)
Typa: COUESPOHOENCE
Catagory: 11.1.0.0.0 EPA Nssdqusrtan ftjldanca
Author: Oiajsond, Iruea: US EPA
longast, Harry L. lit US EPA
Racipiant: diractors: US EPA
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Index OncuMnt lhater Ordtr
tOBINTECH IHC./MATIONAL PIPE CO. SITE, OU 2 DocUMntS
P»g«: 2
tutor: OT-001-0519 To 0527
Title: SiiJtrfw* PrapoMd Plan, leblntceh, Ine./Natiaral Pfpt Co. Sitt, VMUl,
Typt: PUW '
Cittgory: 4.3.0.0.0 PrapoMd Plan
Author: nent: US EPA
•aeipiant:
Data: 12/01/92
York
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