PB97-963805
EPA/541/R-97/056
November 1997
EPA Superfund
Record of Decision:
Robintech, Inc.,/National Pipe Co.,
Town of Vestal, NY
7/25/1997
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RECORD OF DECISION
Robintech, Inc./National Pipe Co. Site
Vestal, New York
U.S. Environmental Protection Agency
Region II
New York, New York
July 1997
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DECLARATION FOR RECORD OF DECISION
SITE NAME AND LOCATION
Robintech, Inc./National Pipe Co. Site, Vestal, New York
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) documents the U.S. Environmental
Protection Agency's selection of a source control remedy and amends
a previous groundwater remedy for the Robintech, Inc./National Pipe
Co. Superfund Site (the Site) in accordance withjhe requirements of the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980, as amended (CERCLA), 42 U.S.C. §9601-9675, and to the
extent practicable, the National Oil and Hazardous Substances Pollution
Contingency Plan, 40 CFR Part 300. This decision document explains
the factual and legal basis for selecting the remedy for the Site. The
attached index (Appendix III) identifies the items fhat comprise the
Administrative Record upon which the selection of the remedial action
is based.
The New York State Department of Environmental Conservation
(NYSDEC) was consulted on the proposed remedial action in accordance
with CERCLA §121(f), 42 U.S.C. §9621(f), and it concurs with the
selected remedy (see Appendix IV).
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the Site,
if not addressed by implementing the response action selected in this
ROD, may present an imminent and substantial endangerment to public
health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The major components of the selected remedy include the following:
• Excavation and treatment, using low temperature thermal
desorption (LTTD), of unsaturated and saturated soils in two areas
of the Site (the PW-2 and Paved Pipe Staging Areas) which exceed
the NYSDEC recommended soil cleanup objectives identified in the
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Technical and Administrative Guidance Memorandum (TAGM)
objectives for VOCs. Post-excavation confirmatory sampling will
be conducted to assure that the entire source areas are removed.
Treated soils will be backfilled into the excavation from which they
were removed after confirmatory sampling indicates that they meet
the remediation goals (i.e., TAGM objectives). Treated soil above
Toxicity Characteristic Leaching Procedure (TCLP) levels will
either undergo additional treatment or be disposed of at an
approved off-site facility, as appropriate. Groundwater entering
the excavation will be pumped into mobile holding tanks for future
testing and treatment, if necessary.
Extraction of contaminated groundwater from the bedrock aquifer
through the existing production well network. Extraction will
continue until Maximum Contaminant Levels (MCLs) are achieved.
Provisions to periodically evaluate the entire system, and repair
or upgrade, as necessary, will be included in an operation and
maintenance plan. .
Elimination of any plant-related sources of water to the overburden
aquifer in order to further mitigate contaminant mobility.
Intrinsic remediation of contaminated overburden groundwater
(natural attenuation processes, including chemical degradation,
dilution, and dispersion) at the Site and in downgradient areas.
These natural mechanisms will be monitored regularly to verify
that the level and extent of contaminants in the overburden
groundwater are declining from baseline conditions and that
conditions are protective of human health and the environment.
Taking steps to secure institutional controls, such as deed
restrictions and contractual agreements, as well as local
ordinances, laws, or other government action, for the purpose of,
among other things, restricting the installation and use of
groundwater wells at and downgradient of the Site until
groundwater quality has been restored.
Development of a contingency plan during the remedial design
(RD) to ensure the continuation of the pumping of contaminated
bedrock groundwater from the existing production well network in
the event of temporary or permanent plant closure or to adjust the
rate of such pumping in the event that existing pumping rates do
not effectively control the migration of contaminated groundwater.
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The contingency plan will also address the treatment of the
production well network effluent should contaminant levels exceed
surface water discharge standards.
• Long-term groundwater and production well effluent discharge
monitoring to evaluate the selected remedy's effectiveness. The
exact frequency and location of groundwater monitoring will be
determined during the RD stage. Monitoring will include a network
of groundwater monitoring wells (including the installation of new
monitoring wells, as necessary) sampled for volatile organic
compounds (VOCs) and intrinsic remediation indicator parameters.
The groundwater effluent discharge will be monitored for VOCs.
In addition, a monitoring well cluster (one overburden and one
bedrock) will be installed downgradient of the PW-2 Area to further
assess groundwater quality.
• Reevaluation of Site conditions at least once every five years to
determine if a modification to the selected remedy is necessary.
This will include all areas of the Site, including the Northeastern
Site Boundary Area.
In addition, further investigation will be necessary in an area with
elevated groundwater concentrations in the vicinity of the warehouse in
order to determine if this area is an additional source area. If such a
source area is located, contaminated soil will be excavated and treated
along with contaminated soils from the Paved Pipe Staging Area.
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy meets the requirements for remedial actions set
forth in CERCLA §121, 42 U.S.C. §9621 in that it: (1) is protective of
human health and the environment; (2) attains a level .or standard of
control of the hazardous substances, pollutants and contaminants,
which at least attains the legally applicable or relevant and appropriate
requirements (ARARs) under federal and state laws; (3) is
cost-effective; (4) utilizes alternative treatment (or resource recovery)
technologies to the maximum extent practicable; and (5) satisfies the
statutory preference for remedies that employ treatment to reduce the
toxicity, mobility, or volume of the hazardous substances, pollutants or
contaminants at a site.
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Because this remedy will result in contaminants remaining on-site above
health-based limits until the contaminant levels in the aquifer are
reduced below MCLs, a review of the remedial action pursuant to
CERCLA §121(c), 42 U.S.C. §9621(c), will be conducted five years after
the commencement of the remedial action, and every five years
thereafter, to ensure that the remedy continues to provide adequate
protection to human health and the environment.
Jeanne,
Regiq
Date
IV
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DECISION SUMMARY
Robintech, Inc./National Pipe Co. Site
Vestal, New York
U.S. Environmental Protection Agency
Region II
New York, New York
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TABLE OF CONTENTS
page
SITE LOCATION AND DESCRIPTION * 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 3
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION 4
SUMMARY OF SITE CHARACTERISTICS 4
SUMMARY OF SITE RISKS : 8
REMEDIAL ACTION OBJECTIVES 12
SUMMARY OF REMEDIAL ALTERNATIVES ! I 12
COMPARATIVE ANALYSIS OF ALTERNATIVES 17
DESCRIPTION OF THE SELECTED REMEDY 24
STATUTORY DETERMINATIONS 27
DOCUMENTATION OF SIGNIFICANT CHANGES 30
ATTACHMENTS
APPENDIX I FIGURES
APKENDIXII TABLES
APPENDIX III ADMINISTRATIVE RECORD INDEX
APPENDIX IV STATE LETTER OF CONCURRENCE
APPENDIX V RESPONSIVENESS SUMMARY
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S/7E LOCATION AND DESCRIPTION
The Robintech, Inc./National Pipe Co. Site (the Site) is located at 3421
Old Vestal Road in the Town of Vestal, Broome County, New York (see
Figure 1). Vestal is located within a regionally important industrial
center adjacent to Binghamton, New York in the Susquehanna River
basin. An estimated 5,350 people live within a one mile radius of the
Site.
The Site, which occupies 12.7 acres, 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 (see Figure 2). 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 th-at 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.
The area has two distinct aquifers which are sources of drinking water.
The upper aquifer is comprised of overburden material consisting mainly
of gray and brown till which becomes harder with depth. In addition, fill
material associated with extensive grading on-site for storage and
parking space 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 well fields. One of these well fields is located downgradient of
the Site near the river. Several investigations in the area have
indicated that groundwater contamination from the Site is not impacting
this area.
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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.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
In 1966, Robinson Technical Products 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, 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.
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, Inc. ("Electro-Mech"). Electro-Mech, which
has since ceased operations at the Site, assembled electronic cable on
the second floor of the main building. National Pipe conducted PVC
pipe manufacturing operations on the first floor of the main building.
Currently, National Pipe & Plastics, Inc., which is owned by Japanese
corporations, conducts the PVC pipe manufacturing operations at the
Site.
Ten production wells (labeled PW-1 through PW-10) were drilled on-site
between 1983 and 1984. These six-inch diameter production wells were
installed with steel casing through the overburden formation and then
finished as open bedrock holes down to an average of 200 feet below
ground surface. One well (PW-7) was abandoned and grouted to the
surface with cement due to poor yield. Production well PW-10 was
screened within the overburden aquifer, but has been removed from
operation, also due to low yield. The eight remaining wells derive water
from fractures in the shale bedrock aquifer. These wells discharge into
a distribution tank located near the rear of the production facility and
are automatically activated and deactivated in response to plant
demand. Water from the distribution tank is used as both contact and
noncontact cooling water in the pipe production process, then
discharged to surface water at the permitted effluent discharge point.
The production wells currently extract approximately 250,000 gallons of
water per day.
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An NYSDEC effluent sample collected at the Site in 1984 to verify
discharge permit compliance found certain organic constituents 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. The Site was placed on the EPA
National Priorities List (NPL) in 1986. An Administrative Order on
Consent under Sections 104 and 122 of CERCLA, 42 U.S.C. §§9604,
9622 for the performance of a Remedial Investigation and Feasibility
Study (RI/FS) was issued by EPA in 1987 to General Indicator Group,
Inc. Oa successor of Robintech), Buffton, Buffton Electronics (now
named Electro-Mech, Inc.), and National Pipe Company. General
Indicator Group, Inc. subsequently changed its name to CompuDyne,
Inc. All of the above parties have been identified as Potentially
Responsible Parties (PRPs) pursuant to CERCLA.
McLaren/Hart, retained by Buffton, implemented the EPA-approved
RI/FS work plan. Following the completion of the RI/FS, a ROD was
signed (on March 30, 1992), selecting pumping and treatment of the
contaminated bedrock and overburden groundwater in three areas of the
Site (discussed in more detail below). In September 1992, a Unilateral
Administrative Order was issued by EPA to the PRPs to design and
implement the selected remedy. Pre-RD-related field work, to collect
additional data for the design of the selected remedy, was completed in
December 1995. Based upon the results of this investigation, a
Remedial Design Investigation Report (RDIR) was submitted to EF*A in
August 1996.
Soil and sediment investigations in order to assess suspected elevated
lead concentrations on both the Site and-Skate Estate properties were
the subject of a second operable unit. These investigations did not
reveal any potential health threats. Consequently, a no action ROD was
signed for the second operable unit in March 1993.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Rl report, dated September 1991, which describes the nature and
extent of the contamination at and emanating from the Site, the Risk
Assessment, dated February 1992, which discusses the risks associated
with the Site, the FS report, dated December 1991, which identifies and
evaluates various remedial alternatives, the 1992 ROD, the August 1996
RDIR, and the April 1997 Proposed Plan were made available to the
public in both the Administrative Record and information repositories
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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 Binghamton Press & Sun Bulletin on
April 25, 1997. A public comment period was held from April 25 through
May 25, 1997. A public meeting was held on May 14, 1997 at the Vestal
Public Library in Vestal, New York. At this meeting, representatives
from EPA presented the findings of the RDIR and answered questions
from the public about the Site and the remedial alternatives under
consideration.
Responses to the comments received at the public meeting and in
writing during the public comment period are included in the
Responsiveness Summary (see Appendix V).
SCOPE AND ROLE OF OPERABLE UNIT OR RESPONSE ACTION
Information gathered during the design of the 1992 remedy (operable
unit 1) made it apparent that the geology of the overburden was
unsuitable for the implementation of a groundwater extraction system.
Further, design data indicated the presence of definable sources of
groundwater contamination within the overburden. Consequently, it
became necessary to consider reevalgating the 1992 remedy and
providing modifications, as appropriate. The primary objectives of this
action (the final action for the Site) are to control the source of
contamination at the Site, to reduce and minimize the downward
migration of contaminants to the bedrock aquifer, and to minimize.any
potential future health and environmental impacts.
Soil and sediment investigations in order to assess suspected elevated
lead concentrations on both the Site and Skate Estate properties were
the subject of a second operable unit. These investigations did not
reveal any potential health threats. Consequently, a no action ROD was
signed for the second operable unit in March 1993.
SUMMARY OF SITE CHARACTERISTICS
Results of the 1991 Remedial Investigation
The topography in the vicinity of the Site slopes primarily to the west
and to a lesser extent to the north. Surficial geology (hereinafter
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referred to as "overburden") is comprised of glacial till overlain by fill.
Typically, fill materials were encountered to a maximum depth of 6 feet
below ground surface.
The area has two distinct water-bearing zones. The upper zone is
comprised of overburden soils above bedrock. The lower zone is shale
bedrock. The average depth to water encountered in the overburden
was 12 feet below the ground surface. The glacial till overburden
appears to restrict the downward movement of water to the bedrock
aquifer. The movement of groundwater in the bedrock aquifer is
controlled primarily by the fractures in the shale bedrock. Water levels
measured in bedrock monitoring wells and production wells during static
(nonpumping) conditions averaged approximately 34 feet below ground
surface.
The overburden groundwater flows predominantly toward the west; minor
flow components to the northwest and southwest are also possible. The
direction of groundwater flow is generally consistent with the
topography, i.e., both tend toward the Susquehanna River.
Groundwater in the bedrock aquifer flows predominantly to the north-
northwest. Westerly and southerly groundwater flow components within
the southern one-third section of the Site indicate an apparent
groundwater divide trending east-west in this portion of the Site.
During the Rl, air, surface water, sediment, groundwater, surface soils,
and subsurface soils were sampled; however, only the groundwater was
found to be adversely affected. Concentrations of VOCs exceeding
federal and/or state MCLs were detected in both the overburden and
bedrock groundwater. Impacted areas include the "Northeastern Site
Boundary Area," the "Paved Pipe Staging Area," and the "Production
Well No. 2 Area" (hereinafter called the "PW-2 Area"). Figure 3
identifies each of these areas.
The Rl identified elevated concentrations of trichloroethene (TCE) (54
micrograms per liter [^g/l]) in overburden groundwater samples near the
Northeastern Site Boundary Area. No other VOCs were detected in this
area.
Overburden groundwater samples collected from the Paved Pipe Staging
Area during the Rl showed concentrations of 1,1,1-trichloroethane
(TCA) up to 760 //g/l. No other VOCs were detected in this area.
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The majority of contamination was found in the PW-2 Area.
Groundwater samples collected during the Rl contained TCA
concentrations up to 1,100 //g/l in the overburden and up to 8,800 fj.g(\
in the bedrock. Other VOCs were also detected at elevated levels.
Since the level of VOC contamination detected in bedrock groundwater
in the PW-2 Area was not detected in downgradient monitoring well
locations, it appears that the constant pumping of the production wells
is likely curtailing the migration of groundwater contamination. Figures
4 and 5 display the distribution of 1,1,1-TCA concentrations in the
overburden.
The Rl data, along with the attendant risk assessment and FS, ultimately
led to the selection of pumping and treatment of the contaminated
overburden and bedrock aquifers in the Northeastern Site Boundary,
Paved Pipe Staging, and PW-2 Areas.
Results of the Pre-Remedial Design Investigation
Pre-RD activities included investigations of the Northeastern Site
Boundary, Paved Pipe Staging, and PW-2 Areas to provide data
sufficient to design the ROD-selected remedy.
Northeastern Site Boundary Area Investigation
The results of the Rl identified low-level concentrations of TCE in
overburden groundwater samples near the Northeastern Site Boundary
Area. On-site levels of TCE at this location ranged from 14 to 54 fj.gl\.
TCE was not detected in on-site soil samples from this area. Upgradient
groundwater samples exhibited higher concentrations of TCE than were
detected at this portion of the Site (up to 1,410 jug/I), indicating the
probability of an off-site source of TCE contamination. NYSDEC is
currently overseeing an investigation related to this potential off-site
source of contamination (a non-NPL site). As a result, this area is not
currently being considered for remediation by EPA. Remediation of this
area may be considered in the future based upon the results of the
ongoing investigation related to the potential off-site source or upon the
results of any long-term monitoring conducted at the Site.
Paved Pipe Staging Area Investigation
During the pre-RD sampling, TCA concentrations were found exceeding
13,000 /zg/l in the overburden groundwater in the vicinity of the entrance
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to the gravel lot area (as compared to 760 /^g/l found during the Rl) and
exceeding 6,000 //g/l near the warehouse (see Figure 5).
The data also indicated that subsurface soils in the vicinity of the
entrance to the gravel lot area are contaminated with TCA
(concentrations up to 6,900 //g/kg). A source area of VOCs in
subsurface soils was delineated here consistent with the location of the
highest levels of VOCs in overburden groundwater (see Figure 6). Soil
samples collected near the warehouse were inconclusive as to the
existence of a source area associated with the elevated overburden
groundwater concentrations there. Tables 1 and 2 summarize the pre-
RD soil and groundwater data, respectively, for the Paved Pipe Staging
Area.
The results of a slug test and step-drawdown test in an extraction well
identified the presence of a relatively low permeability overburden
formation with extremely low groundwater yield in the Paved Pipe
Staging Area, which apparently has limited the migration of dissolved
organic constituents in overburden groundwater.
PW-2 Area Investigation
Pre-RD sampling results revealed the presence of a localized source of
TCA (concentrations up to 222,000 i*gl\) and other VOCs in the
overburden of the PW-2 Area. Concentrations up to 1,100 //g/l were
detected during the Rl.
The data also revealed that subsurface soils in the area are
contaminated with TCA (concentrations up to 2,800,000 /zg/kg) and
other VOCs. A source area of VOCs in subsurface soils was delineated
in the PW-2 Area consistent with the location of the highest levels of
VOCs in overburden groundwater (see Figure 7). Tables 3 and 4
summarize the pre-RD groundwater and soil data for the PW-2 Area.
Additionally, within this area of high contamination was discovered a
small area of groundwater much closer to the ground surface than that
for the remainder of the PW-2 area. The source of this groundwater
could not be determined at the time of this investigation, but may be
related to plant operations.
As in the Paved Pipe Staging Area, the results of a slug test and step-
drawdown test in an extraction well indicated the presence of low
permeability soils with extremely low groundwater yield; this appears to
have limited the migration of VOCs in the overburden.
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While the data collected during the Rl exhibited higher concentrations
of VOCs in the bedrock than in the overburden, the more extensive pre-
RD data indicated far more significant contamination in the overburden
than in the bedrock, and far more significant contamination in the
overburden than was exhibited during the Rl.
Packer testing revealed that contaminated groundwater was moving
downward from the overburden into PW-2 via an artificial conduit
created when the unsealed casing of the production well was installed
through the overburden formation into the upper level of bedrock.
Figure 8 shows 1,1,1-TCA concentrations in bedrock. Table 5 presents
groundwater sampling data from the bedrock groundwater. In response,
EPA authorized Buffton to replace this well with a new, properly-sealed
production well similar in diameter and depth to PW-2, followed by the
sealing and abandonment of PW-2. Construction and abandonment work
was completed in December 1996, effectively eliminating a groundwater
migration pathway which allowed contaminated groundwater to enter the
bedrock from the overburden.
In summary, the results of the pre-RD investigation indicated that
overburden groundwater and subsurface soils were contaminated at
levels much greater than those detected during the Rl. In addition, the
pre-RD investigation identified the presence of a relatively low
permeability overburden formation with extremely low groundwater yield.
Therefore, the extraction of contaminated groundwater from the
overburden formation (the remedy selected for the overburden formation
in the 1992 ROD) was determined not to be feasible.
SUMMARY OF SITE RISKS
Based upon the results of the Rl, a baseline risk assessment was
conducted to estimate the risks associated with current and future Site
conditions. The baseline risk assessment estimates the human health
and ecological risks which could result from exposure to the
contamination at the Site, if no remedial action were taken.
Human Health Risk Assessment
A four-step process is utilized for assessing Site-related human health
risks for a reasonable maximum exposure scenario: Hazard
Identification—identifies the contaminants of concern at the Site based
on several factors s.uch as toxicity, frequency of occurrence, and
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concentration. Exposure Assessment—estimates the magnitude of
actual and/or potential human exposures, the frequency and duration of
these exposures, and the pathways (e.g., ingesting contaminated
well-water) by which humans are potentially exposed. Toxicity
Assessment—determines the types of adverse health effects associated
with chemical exposures, and the relationship between magnitude of
exposure (dose) and severity of adverse effects (response). Risk
Characterization—summarizes and combines outputs of the exposure
and toxicity assessments to provide a quantitative assessment of
Site-related risks.
The baseline risk assessment began with selecting contaminants of
concern which would be representative of Site risks. Contaminants were
identified based on factors such as potential for exposure to receptors,
toxicity, concentration, and frequency of occurrence (see Table 6).
Several of the VOCs, including TCE and vinyl chloride, are known to
cause cancer in laboratory animals and are suspected or known to be
human carcinogens. The baseline risk assessment evaluated the health
effects which could result from exposure to contaminated or potentially
contaminated groundwater. Table 7 shows the potential exposure
pathways. As there is not a completed exposure pathway under either
current or reasonably anticipated future land use scenarios, risks due
to VOC levels in subsurface soil were not evaluated.
The results of the Risk Assessment indicate that contaminated
groundwater at the Site poses an unacceptable risk to human health due
to the presence of VOCs above MCLs.
The results of the baseline risk assessment are contained in the Draft
Final Risk Assessment, Robintech, Inc./National Pipe Co. Site, dated
November 4, 1991, prepared by Alliance Technologies Corporation
under contract with EPA. This document is included in the
Administrative Record file for the Site.
Non-carcinogenic risks were assessed using a hazard index (HI)
approach, based on a comparison of expected contaminant intakes and
safe levels of intake (Reference Doses). Reference doses(RfDs) have
been developed by EPA for indicating the potential for adverse health
effects. RfDs, which are expressed in units of mg/kg-day, are estimates
of daily exposure levels for humans which are thought to be safe over
a lifetime (including sensitive individuals). Estimated intakes of
chemicals from environmental media (e.g., the amount of a chemical
ingested from contaminated drinking water) are compared with the RfD
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to derive the hazard quotient for the contaminant .in the particular
medium. The hazard index is obtained by adding the hazard quotients
for all compounds across all media that impact a particular receptor
population. The RfDs for the compounds of concern are presented in
Table 8.
Potential carcinogenic risks were evaluated using the cancer slope
factors developed by EPA for the contaminants of concern. Cancer
slope factors (SFs) have been developed by EPA's Carcinogenic Risk
Assessment Verification Endeavor for estimating excess lifetime cancer
risks associated with exposure to potentially carcinogenic chemicals.
SFs, which are expressed in units of (mg/kg-day)"1, are multiplied by the
estimated intake of a potential carcinogen, in mg/kg-day, to generate an
upper-bound estimate of the excess lifetime cancer risk associated with
exposure to the compound at that intake level. The term "upper bound"
reflects the conservative estimate of the risks calculated from the SF.
Use of this approach makes the underestimation of the risk highly
unlikely. The SFs for the compounds of concern are presented in Table
8. • • -
Current federal guidelines for acceptable exposures are an individual
excess lifetime carcinogenic risk in the range of 10~4 to 1Q6 (i.e., a
one-in-ten-thousand to a one-in-a-million excess cancer risk) and a
maximum health Hazard Index (Hl)(which reflects noncarcinogenic
effects for a human receptor) equal to 1.0. (An HI greater than 1.0
indicates a potential of noncarcinogenic health effects.)
Because the overburden till is tightly packed such that resulting
groundwater yields are extremely low (approximately 0.1 gallons per
minute), the overburden aquifer is not usable. Hence, no current or
future overburden groundwater exposure is possible. The greatest
carcinogenic risk value at the Site is associated with the future-use
bedrock groundwater ingestion scenario (4.1 x 10"3). Significant risk
was also associated with the inhalation of VOCs from groundwater while
showering under a future-use scenario. A summary of the carcinogenic
risks is provided in Table 9. The HI is 1.4 when the maximum VOC
contaminant concentrations in groundwater samples are evaluated.
Table 10 summarizes the non-carcinogenic risks. While these risk
values do not take into consideration the pre-RD data, the inclusion of
these data in risk calculations would lead to equal or greater risks.
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The ecological risk assessment concluded that no habitats or species
of special concern would likely be affected by Site-related contaminants.
In summary, actual or threatened releases of hazardous substances
from this Site, if not addressed by the selected remedy or one of the
other active measures considered, may present a current or potential
threat to public health, welfare, and the environment.
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 will actually come in contact with the chemicals
of concern, the period of time over which such exposure will 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 a result, the Risk Assessment provides upper bound estimates of the
risks to populations near the Site, and is highly unlikely to
underestimate actual risks related to the Site.
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REMEDIAL ACTION OBJECTIVES
Remedial action objectives are specific goals to protect human health
and the environment. These objectives are based on available
information and standards such as ARARs and risk-based levels
established in the risk assessment. The results of the pre-RD
investigation identified the need to re-evaluate the ROD-selected
remedy and establish new remedial action objectives for the Site.
The results of aquifer testing in the Paved. Pipe Staging Area identified
the presence of a relatively low permeability overburden formation with
extremely low groundwater yield, apparently limiting the migration of
dissolved organic constituents in overburden groundwater. The aquifer
testing also raised a question as to the ability of sustaining a
groundwater flow rate in the overburden necessary to implement the
pumping remedy selected in the 1992 ROD in this area.
An alternative approach to address overburden contamination was
determined to be necessary. Considering the aforementioned findings,
the following remedial action objectives were established:
1. Mitigate the potential for contaminants to migrate from the soil into
the overburden aquifer and reduce soil contamination to meet the
NYSDEC recommended soil cleanup objectives identified in the
Technical and Administrative Guidance Memorandum (TAGM).
2. Mitigate the potential for contaminants to migrate from the
overburden aquifer into the bedrock aquifer.
3. Reduce or eliminate the threat to public health and the
environment posed by groundwater contamination by remediating
groundwater to MCLs for VOCs.
4. Reduce or eliminate the potential for off-site migration of
contaminants.
SUMMARY OF REMEDIAL ALTERNATIVES
CERCLA requires that.each selected site remedy be protective of human
health and the environment, be cost-effective, comply with other
statutory laws, and utilize permanent solutions and alternative treatment
technologies and resource recovery alternatives to the maximum extent
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practicable. In addition, the statute includes a preference for treatment
as a principal element for the reduction of toxicity, mobility, or volume
of the hazardous substances.
While the bedrock groundwater is contaminated to varying degrees, it
appears that the pumping of the groundwater from the facility's eight
active production wells, in combination with losses through the plant's
storage and distribution system, has resulted in the effluent discharge
being in conformance with NYSDEC State Pollutant Discharge
Elimination System (SPDES) standards for VOCs since 1984. Therefore,
while the treatment of the extracted bedrock groundwater is a viable
alternative, it was eliminated from further consideration, since treatment
is unnecessary to meet surface water discharge requirements.
As discussed above, investigations have shown significant VOC
contamination in subsurface soils that act as a source of contamination
to overburden groundwater, and, to a lesser extent, the bedrock
groundwater. This ROD evaluates, in detail, remedial alternatives for
addressing the contamination in the various media.
The operation and maintenance costs reflect the annual costs to
operate, monitor, and maintain the remedy for 10 years, as preliminary
findings indicate that this is a reasonable time frame for cleanup. The
construction time for each alternative reflects only the time required to
construct or implement the remedy and does not include the time
required to design the remedy, negotiate the performance of the remedy
with the responsible parties, or procure contracts for design and
construction.
The alternatives are:
Alternative 1: No Action
Capital Cost: $ 0
Operation and Maintenance Cost: $114,125
Present-Worth Cost: $935,870
Construction Time: 1 month
The Superfund program requires that the "no-action" alternative be
considered as a baseline for comparison with the other alternatives.
The no-action remedial alternative does not include any physical
remedial measures that address the problem of contamination at the Site
and would rely solely on intrinsic remediation (natural attenuation
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processes, including chemical degradation, dilution, and dispersion)
and production well pumping to address the contaminated groundwater
in the overburden and bedrock aquifers, respectively.
This alternative would, however, include a long-term groundwater
monitoring program. Under the monitoring program, water quality
samples would be collected seasonally from upgradient, on-site, and
downgradient groundwater monitoring wells. The specifics of monitoring
locations, frequency, and parameters would be determined during the
remedial design.
The no-action response also would include the development and
implementation of a public awareness and education program for the
residents in the area surrounding the Site. This program would include
the preparation and distribution of informational press releases and
circulars and convening public meetings. These activities would serve
to enhance the public's knowledge of the conditions existing at the Site.
This alternative would also require the involvement of local government,
various health departments, and environmental agencies.
Under this alternative, the existing production well network would
continue to extract contaminated bedrock groundwater for use in plant
operations. Sampling at the effluent discharge point would be
conducted to confirm that concentrations continue to meet permit
specifications.
Because this alternative would result in contaminants remaining on-site
above health-based levels, CERCLA requires that the Site be reviewed
every five years. If justified by the review, remedial actions may be
implemented to remove or treat the contamination.
Alternative 2: Excavation of Contaminated Unsaturated Soils, Treatment
via Low Temperature Thermal Desorption (LTTD), and Redeposition
Capital Cost: . $1,171,584
Operation and Maintenance Cost: , $ 114,125
Present-Worth Cost: $2,107,454
Construction Time: 1 year
This alternative would include the excavation of unsaturated soils in the
PW-2 and Paved Pipe Staging Areas which exceed NYSDEC's soil TAGM
objectives for VOCs (estimated at,approximately 1,000 cubic yards).
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The actual extent of the excavations and the volume of the excavated
material would be based on post-excavation confirmatory sampling.
Shoring of the excavations and extraction and treatment of any water
that enters the trench would be necessary. The excavated soil would be
fed to a mobile LTTD unit brought to the Site, where hot air injected at
a temperature above the boiling points of the organic contaminants of
concern would allow them to be volatilized into gases and escape from
the soil. The organic vapors extracted from the soil would then be
either condensed, transferred to another medium (such as activated
carbon), or thermally treated in an afterburner operated to ensure
complete destruction of the volatile organics. The off-gases would be
filtered through a carbon vessel. Once the treated soil achieved soil
TAGM objectives, it would be tested in accordance with the Toxicity
Characteristic Leaching Procedure (TCLP) to determine whether it
constitutes a Resource Conservation and Recovery Act hazardous waste
and, provided that it passes the test, it would be used as backfill
material for the excavated area. Soil above TCLP levels would either
undergo additional treatment or be disposed of at an approved off-Site
facility, as appropriate.
Under this alternative, intrinsic remediation would address the
contamination in the overburden groundwater in downgradient areas.
Water quality samples would be collected from upgradient, on-site, and
downgradient groundwater monitoring wells to verify that the level and
extent of contaminants in overburden groundwater are declining from
baseline conditions and that conditions are protective of human health
and the environment. The specifics of monitoring locations, frequency,
and parameters would be determined during the design of the selected
remedy.
This alternative would also include taking steps to secure institutional
controls, such as the placement of restrictions on the installation and
use of groundwater wells at and downgradient of the Site.
Under this alternative, the existing production well network would
continue to extract contaminated bedrock groundwater for use in plant
operations. Sampling at the effluent discharge point would be
conducted to confirm that concentrations continue to meet permit
specifications. This alternative would also include the development of
a contingency plan for the pumping and treatment of contaminated
bedrock groundwater from the existing production well network in the
event of temporary or permanent plant closure. The contingency plan
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would also address the treatment of the production well network effluent
should contaminant levels exceed discharge standards.
Alternative 3: Excavation of Contaminated Unsaturated and Saturated
Soils, Treatment Via LTTD, and Redeposition
Capital Cost: $2,101,054
Operation and Maintenance Cost: $ 114,125
Present-Worth Cost: $3,036,924
Construction Time: 1 year
This alternative is identical to Alternative 2, except that it would also
include the excavation of the impacted saturated soils below the water
table which exceed NYSDEC's soil TAGM objectives for VOCs
(estimated at approximately 2,000 cubic yards). The actual extent of the
excavations and volume of excavated material would be based on post-
excavation confirmatory sampling data. Groundwater entering the
excavation would be pumped into mobile holding tanks for future testing
and treatment, if necessary.
Although the overburden groundwater cannot be effectively extracted,
it is expected that the excavation of saturated soils will result in the
removal of a significant portion of the overburden groundwater
contamination. Intrinsic remediation would address the contamination
in the overburden that has migrated downgradient from the source
areas. Similar to Alternative 2, Alternative 3 would also include long-
term groundwater monito/ing, use of the existing production well
network to continue extracting contaminated bedrock groundwater,
development of a contingency plan, and taking steps to secure
institutional controls until the groundwater quality has been restored.
Alternative 4: Dual-Phase Extraction
Capital Cost: $ 967,998
Operation and Maintenance Cost: $ 218,818
Present-Worth Cost: $2,504,884
Construction Time: 2 years
Under this alternative, a dual-phase high-vacuum extraction system
would be used to address contaminated overburden soils in the PW-2
and Paved Pipe Staging Areas. A series of extraction wells would be
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installed in these areas and a strong vacuum applied to the extraction
wells would draw in contaminated groundwater from the saturated zone
and contaminated soil vapor from the unsaturated zone. As groundwater
is removed, soil vapors in the previously saturated soil would be
extracted by the vacuum as well. Contaminated soil vapors and
groundwater would be piped to an on-site carbon adsorption treatment
system. The treated groundwater would be discharged to surface water.
The soil vapor and groundwater treatment residues would be sent to an
off-site treatment/disposal facility.
Intrinsic remediation would address the contamination in the overburden
that has migrated downgradient from the source areas. Similar to
Alternative 2, Alternative 4 would also include long-term groundwater
monitoring, use of the existing production well network to continue
extracting contaminated bedrock grpundwater, and development of a
contingency plan.
This alternative would also include taking steps to secure institutional
controls, such as the placement of restrictions on the installation and
use of groundwater wells at and downgradient of the Site.
COMPARATIVE ANALYSIS OF ALTERNATIVES
During the detailed evaluation of remedial alternatives, each alternative
is assessed against nine evaluation criteria, namely, overall protection
of human health and the environment, compliance with applicable or
relevant and appropriate requirements, long-term effectiveness and
permanence, reduction of toxicity, mobility, or volume through
treatment, short-term effectiveness, implementability, cost, and state
and community acceptance.
The evaluation criteria are described below.
• Overall protection of human health and the environment addresses
whether or not a remedy provides adequate protection and
describes how risks posed through each exposure pathway (based
on a reasonable maximum exposure scenario) are eliminated,
reduced, or controlled through treatment, engineering controls, or
institutional controls.
• Compliance with ARARs addresses whether or not a remedy would
meet all of the applicable or relevant and appropriate
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requirements of other federal and state environmental statutes and
requirements or provide grounds for invoking a waiver.
• Long-term effectiveness and permanence refers to the ability of a
remedy to maintain reliable protection of human health and the
environment over time, once cleanup goals have been met. It also
addresses the magnitude and effectiveness of the measures that
may be required to manage the risk posed by treatment residuals
and/or untreated wastes.
• Reduction of toxicity, mobility, or volume through treatment is the
anticipated performance of the treatment technologies, with
respect to these parameters, a remedy may employ.
• Short-term effectiveness addresses the period of time needed to
achieve protection and any adverse impacts on human health and
the environment that may be posed during the construction and im-
plementation period until cleanup goals are achieved.
• Implementability is the technical and administrative feasibility of
a remedy, including the availability of materials and services
needed to implement a particular option.
• Cosf includes estimated capital and operation and maintenance
costs, and net present-worth costs.
• Sfafe acceptance indicates whether, based on its review of the
RI/FS reports, RDIR, and the Proposed Plan, the State supports,
opposes, and/or has identified any reservations with the selected
alternative.
• Community acceptance refers to the public's general response to
the alternatives described in the Proposed Plan. Factors of
community acceptance to be discussed include support,
reservation, and opposition by the community.
A comparative analysis of the remedial alternatives based upon the
evaluation criteria noted above follows.
Overall Protection of Human Health and the Environment
Under Alternative 1 (No Action), contaminants would continue to leach
from the soil into the groundwater and continued off-site migration of
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contaminants would occur. Alternative 1 would rely solely on intrinsic
remediation to address the contaminated overburden groundwater.
Consequently, this alternative would not address the remedial action
objectives established for the Site and would, therefore, be the least
protective of human health and the environment.
Alternative 2 (Excavation and Treatment of Contaminated Unsaturated
Soils) and Alternative 3 (Excavation and Treatment of Contaminated
Saturated and Unsaturated Soils) would both be protective by removing
the primary source of contamination to the overburden and bedrock
aquifers, although Alternative 3 would be considered more protective
because it would result in the removal of contaminated soils both above
and below the water table. Theoretically, Alternative 4 (Dual-phase
Extraction) would also be protective, although its effectiveness would
need to be demonstrated through treatability studies and would require
several years or more to reach the remediation goals.
Further, as discussed above, no current or future overburden
groundwater exposure is possible because the overburden is not usable.
Hence human health and environmental receptors are not threatened by
exposure to overburden groundwater.
Since the groundwater from the. production well network is in
conformance with SPDES effluent permit requirements, continued
bedrock groundwater extraction would be protective of public health and
the environment. All of the alternatives, including No Action, would
include the extraction of contaminated groundwater from the bedrock
aquifer, thereby reducing and minimizing the downgradient migration of
contaminants within that aquifer, and minimizing any potential future
health and environmental impacts. In contrast with the other
alternatives, however, Alternative 1 would not address the overburden
source of the contamination to the bedrock aquifer.
With Alternatives 2, 3, and 4, it is anticipated that the remediation of
the source areas, the elimination of the PW-2 conduit, the continued
extraction of contaminated groundwater from the production well
network, and intrinsic remediation of the overburden groundwater would
reduce the downward migration of contaminants from the overburden
aquifer into the bedrock aquifer and would lead to the cleanup of the
bedrock aquifer within a reasonable time frame. Since it would not
address the source of the contamination, Alternative 1 would not result
in the cleanup of the bedrock aquifer within a reasonable time frame.
Under Alternatives 2, 3, and 4, institutional controls would limit the
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intrusiveness of future activity that could occur until the groundwater
quality has been restored.
Compliance with ARARs
While there are no federal or New York State soil ARARs for VOCs, one
of the remedial action goals is to meet TAGM objectives. Alternative 1
(No Action) would not be effective in meeting these objectives. While
it is anticipated that" Alternative 2 (Excavation and Treatment of
Contaminated Unsaturated Soils) would meet soil TAGM objectives
through the excavation and treatment of the unsaturated soils in the
overburden aquifer, Alternative 3 (Excavation and Treatment of
Contaminated Saturated and Unsaturated Soils) would meet soil TAGM
objectives in the unsaturated and saturated soils. Alternative 4 (Dual-
phase Extraction) should also be able to meet these values, although
this would need to be demonstrated through treatability testing.
Federal MCLs are not ARARs with respect to the overburden aquifer as
no current or future overburden groundwater exposure is possible
because that aquifer is not usable. In addition, NYSDEC has indicated
that since the overburden is of such low permeability, making the
overburden groundwater unusable, achievement of the state drinking
water standards in this aquifer is not considered to be practical at the
Site.
As the bedrock aquifer is usable, federal MCLs and state drinking water
standards are ARARs with respect to that.aquifer. It is anticipated that
all of the alternatives would be effective in meeting these ARARs, since
they all include the extraction of contaminated bedrock groundwater
until such time as the ARARs are achieved.
It is anticipated that surface water discharge requirements would be met
for the overburden groundwater treated under Alternatives 3
(groundwater entering the excavation and pumped into mobile holding
tanks) and 4 (groundwater from the dual-phase extraction system). For
all of the alternatives, it is anticipated that surface water discharge
requirements would continue to be met for the extracted bedrock
groundwater.
All of the technologies that would be used in Alternatives 2, 3, and 4
would be designed and implemented to satisfy all action-specific
requirements, including air emission standards.
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Long-Term Effectiveness and Permanence
With regard to the overburden aquifer, Alternative 1 (No Action) would
not maintain reliable long-term effectiveness and permanence, since the
contaminants in the soil would be left untreated and contaminated
groundwater would continue to migrate unabated.
Alternative 2 (Excavation and Treatment of Contaminated Unsaturated
Soils) would effectively treat the contaminated unsaturated overburden
soils, thus, reducing the hazards posed by these soils and permanently
removing a major source of groundwater contamination. It is anticipated
that Alternative 4 (Dual-phase Extraction) would be more effective than
Alternative 2 (depending on the results of treatability studies), since it
would also address contaminants in the saturated zone. Alternative 3
(Excavation and Treatment of Contaminated Saturated and Unsaturated
Soils) would be the most effective, since it includes complete removal
of the contaminated saturated and unsaturated overburden soils.
Alternative 3 also includes the pumping of contaminated-groundwater
from the excavation, an element which would provide an added level of
contaminant removal. The institutional controls associated with
Alternatives 2, 3, and 4 would provide an additional element of
effectiveness in preventing exposure of on-site and downgradient
receptors to contaminated groundwater.
The treatment of the contaminated soils (Alternatives 2, 3, and 4) in
conjunction with the sealing of the PW-2 conduit and intrinsic
remediation of the overburden groundwater is expected to, over time,
result in the overburden aquifer being remediated and is expected to
prevent the downward migration of contaminants from the overburden
aquifer ipto the bedrock aquifer.
All of the alternatives, including No Action, would be effective with
regard to the bedrock aquifer, since they all include the extraction of
contaminated bedrock groundwater until such time as MCLs are
achieved.
Sludges and residuals from the treatment processes for Alternatives 2,
3, and 4 would be collected and disposed of off-site.
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Reduction of Toxicity, Mobility, or Volume through Treatment
Alternative 1 (No Action) would not actively reduce the toxicity, mobility,
or volume of contaminants through treatment: Under this alternative,
contaminant migration in the overburden aquifer would continue.
Alternative 2 (Excavation and Treatment of Contaminated Unsaturated
Soils) and Alternative 3 (Excavation and Treatment of Contaminated
Saturated and Unsaturated Soils) with identical soil treatment
approaches, would reduce the toxicity, mobility, and volume
permanently through the excavation of source soi|s and treatment using
LTTD. Alternative 3 would, however, be more effective because the
excavation of the contaminated soil would extend into the saturated
zone and would include the pumping of contaminated groundwater from
the excavation (an element which would provide an added level of
contaminant removal). It is anticipated that Alternative 4 (Dual-phase
Extraction) would reduce the toxicity, mobility, and volume more than
Alternative 2 (depending on the results of treatability studies), since it
would also address contaminants in the saturated zone. All of the
alternatives would reduce the toxicity, mobility, and volume of
contaminants in the bedrock aquifer by providing for the extraction of
contaminated bedrock groundwater.
Short-Term Effectiveness
Since Alternative 1 (No Action) does not include physical construction
measures, it would not present a risk to on-site workers or the
community as a result of its implementation. Alternative 2 (Excavation
and Treatment of Contaminated Unsaturated Soils) and Alternative 3
(Excavation and Treatment of Contaminated Saturated and Unsaturated
Soils) would include activities such as contaminated soil excavation and
transport that could result in potential worker exposure to volatilized
contammants and contaminated dust. However, mitigative measures to
reduce the possibility of exposure would be implemented. The
installation of the extraction system associated with Alternative 4 (Dual-
phase Extraction) might include activities that could result in potential
exposure of workers to volatilized contaminants during construction;
however, mitigative measures to reduce the possibility of exposure
would be implemented. Alternatives 2, 3, and 4 would generate
quantities of treatment byproducts that would have to be handled by on-
site workers and removed off-site for treatment/disposal.
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All of the alternatives might present some risk to on-site workers
through dermal contact and inhalation related to groundwater sampling
activities. These .can, however, be minimized by utilizing proper
protective equipment.
It is estimated that Alternative 1 would require one month to implement,
since developing a long-term groundwater monitoring program would be
the only activity required. Alternatives 2 and 3 could each be
implemented in about one year. Alternative 4 would take an estimated
two or more years to implement.
For the bedrock aquifer, continued contaminated bedrock groundwater
extraction would not present any short-term adverse impacts on human
health and the environment. Since the bedrock extraction system is
already in place, there would be no implementation time.
Implementability
The technologies proposed for use in all of the alternatives are proven
and reliable in achieving the specified process efficiencies and
performance goals.
Alternative 1 (No Action) would be the easiest to implement in that it
would require only monitoring. LTTD (Alternatives 2 and 3) has been
successfully performed on a full-scale basis with similar contaminants.
Pumping groundwater entering the excavation into mobile holding tanks
under Alternative 3 is easily implemented. A dual-phase extraction
system (Alternative 4) would be relatively easy to implement and has
been successfully performed on a full-scale basis with similar
contaminants, although treatability testing would be required to verify
its effectiveness in this particular geologic setting. In addition, the air
stripping and carbon adsorption technologies that may be used for
Alternative 4 are proven and reliable in achieving the specified
performance goals and are readily available. The air stripping and
carbon adsorption technologies that would be utilized for the.
contaminated groundwater under Alternative 4 are proven treatment
methods. The continued extraction of contaminated bedrock
groundwater is easily implemented.
All of the alternatives are technically and administratively feasible and
require readily available materials and services. Effecting institutional
controls until groundwater quality has been restored under Alternatives
2, 3, and 4 can be readily implemented.
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Cosf
The present-worth costs are calculated using a discount rate of 7
percent and a 10-year time interval. The estimated capital, annual
operation and maintenance, and present-worth costs for each of the
alternatives are presented below.
Alternative
No. ;!.:
1
2
3
4
Capital
Cost
$0
$1,171 ,584
$2,101 ,054
$967,998
Operation and
Maintenance Cost
$114,125
$1 14,1 25
$1 14,1 25
$218,81 8
Present-Worth
Cost
$935,870
$2,107,454
$3,036,924
$2,504,884
As can be seen by the cost estimates, Alternative 1 (No Action) is the
least costly remedy with a pres-ent-worth cost of $935,870. Alternative
3 (Excavation and Treatment of Contaminated Saturated and
Unsaturated Soils) is the most costly remedy at $3,036,924.
Sfafe Acceptance
NYSDEC concurs with the selected remedy.
Community Acceptance
Comments received during the public comment period indicate that the
public generally supports the selected remedy. Comments received
during the public comment period are summarized and addressed in the
Responsiveness Summary, which is attached as Appendix V to this
document.
DESCRIPTION OF THE SELECTED REMEDY
Based upon an evaluation of the various alternatives, EPA and NYSDEC
have determined that Alternative 3 (Excavation of Contaminated
Unsaturated and Saturated Soils, Treatment via LTTD, and
Redeposition) is an appropriate remedy for the Site. Specifically, this
will involve the following:
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Excavation and treatment, using LTTD of unsaturated and
saturated soils in the PW-2 and Paved Pipe Staging Areas which
exceed NYSDEC's soil TAGM objectives for VOCs. Post-
excavation confirmatory sampling will be conducted to assure that
the entire source areas are removed. Treated soils will be
backfilled into the excavation from which they were removed after
confirmatory sampling indicates that they meet the remediation
goals (i.e., TAGM objectives). Treated soil above TCLP levels will
either undergo additional treatment or be disposed of at an
approved off-Site facility, as appropriate. Groundwater entering
the excavation will be pumped into mobile holding tanks for future
testing and treatment, if necessary.
Extraction of contaminated groundwater from the bedrock aquifer
through the existing production well network will continue until
MCLs are achieved. Provisions to periodically evaluate the entire
system, and repair or upgrade, as necessary, will be included in
an operation and maintenance plan.
Elimination of any plant-related sources of water to the overburden
aquifer (as described in the "Results of the Pre-Remedial Design
Investigation" section, above) in order to further mitigate
contaminant mobility.
Intrinsic remediation of contaminated overburden groundwater
(natural attenuation processes, including chemical degradation,
dilution, and dispersion) at the Site and in downgradient areas.
These natural mechanisms will be monitored regularly to verify
that the level and extent of contaminants in overburden
groundwater are declining from baseline conditions and that
conditions are protective of human health and the environment.
Taking steps to secure institutional controls, such as deed
restrictions and contractual agreements, as well as local
ordinances, laws, or other government action, for the purpose of,
among other things, restricting the installation and use of
groundwater wells at and downgradient of the Site until
groundwater quality has been restored.
Development of a contingency pran during the RD to ensure the
continuation of the pumping of contaminated bedrock groundwater
from the existing production well network in the event of temporary
or permanent plant closure or to adjust the rate of such pumping
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in the event that existing pumping rates do not effectively control
the migration of contaminated groundwater. The contingency plan
will also address the treatment of the production well network
effluent should contaminant levels exceed surface water discharge
standards.
• Long-term groundwater and production well effluent discharge
monitoring to evaluate the remedy's effectiveness. The exact
frequency and location of groundwater monitoring will be
determined during the RD stage. Monitoring will include a network
of groundwater monitoring wells (including the installation of new
monitoring wells, as necessary) sampled for VOCs and intrinsic
remediation indicator parameters. . The groundwater effluent
discharge will be monitored for VOCs. In addition, a monitoring
well cluster (one overburden and one bedrock) will be installed
downgradient of the PW-2 Area to further assess groundwater
quality.
• Reevaluation of Site conditions at least once every five years to
determine if a modification to the selected remedy is necessary.
This will include all areas of the Site, including the Northeastern
Site Boundary Area.
In addition, further investigation will be necessary in an area with
elevated groundwater concentrations in the vicinity of the warehouse in
order to determine if this area is an additional source area. If such a
source area is located, contaminated soil will be excavated and treated
along with contaminated soils from the Paved Pipe Staging Area.
It is believed that the sealing of the PW-2 conduit, in conjunction with
the remediation of the contaminated overburden soils (which will result
in the removal of a significant portion of the overburden groundwater
contamination and reduce the downward migration of contaminants from
the overburden aquifer into the bedrock aquifer), intrinsic remediation
of the overburden aquifer, and the continued extraction of the
contaminated bedrock groundwater will result in the bedrock
groundwater meeting the remediation goals in a reasonable time frame.
The selected remedy is believed to achieve the ARARs more quickly, or
as quickly, as the other alternatives, and is cost-effective. Therefore,
the selected remedy will.provide the best balance of trade-offs among
alternatives with respect to the evaluating criteria. EPA and NYSDEC
believe that the selected remedy will treat principle threats, be
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protective of human health and the environment, comply with ARARs, be
cost-effective, and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent
practicable. The selected remedy also will meet the statutory
preference for the use of treatment as a principle element (i.e., the
soil).
STATUTORY DETERMINATIONS
As was previously noted, CERCLA §121(b)(1), 42 U.S.C. §9621(b)(1),
mandates that a remedial action must be protective of human health and
the environment, cost-effective, and utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to
the maximum extent practicable. Section 121(b)(1) also establishes a
preference for remedial actions which employ treatment to permanently
and significantly reduce the volume, toxicity, or mobility of the
hazardous substances, pollutants, or contaminants at a site. CERCLA
§121(d), 42 U.S.C. §9621(d), further specifies that a remedial action
must attain a degree of cleanup that satisfies ARARs under federal and
state laws, unless a waiver can be justified pursuant to CERCLA
§121(d)(4), 42 U.S.C. §9621(d)(4).
For the reasons discussed below, EPA has determined that the selected
remedy meets the requirements of CERCLA §121, 42 U.S.C. §9621.
Protection of Human Health and the Environment
The selected remedy protects human health and the environment by
reducing levels of contaminants in the groundwater and soil through
extraction and treatment, respectively, as well as through the
implementation of institutional controls. The selected remedy will
provide overall protection by reducing the toxicity, mobility, and volume
of contamination permanently, through treatment of the contaminated
soil and by meeting federal and state MCLs in the bedrock aquifer.
Compliance with Applicable or Relevant and Appropriate Requirements
of Environmental Laws
While there are no federal or New York State soil ARARs for VOCs, one
of the remedial action goals is to meet TAGM objectives. The selected
remedy will meet soil TAGM objectives in the unsaturated and saturated
soils.
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Federal MCLs are not ARARs with respect to the overburden aquifer as
no current or future overburden groundwater exposure is possible
because that aquifer is not usable. In addition, NYSDEC has indicated
that since the overburden is of such low permeability, making the
overburden groundwater unusable, achievement of the state drinking
water standards in this aquifer is not considered to be practical at the
Site.
As the bedrock aquifer is usable, federal MCLs and state drinking water
standards are ARARs with respect to that aquifer. The selected remedy
would be effective in meeting these ARARs, since it includes the
extraction of contaminated bedrock groundwater until such time as the
ARARs are achieved.
It is anticipated that surface water discharge requirements will be met
for the overburden groundwater treated under the selected remedy
(groundwater entering the excavation and pumped into mobile holding
tanks) and that they will continue to be met for the extracted bedrock
groundwater.
A summary of action-specific; chemical-specific, and location-specific
ARARs which will be complied with during implementation is presented
below. A listing of the chemical-specific ARARs is presented in Tables
11 and 12.
Action-specific ARARs:
• National Emissions Standards for Hazardous Air Pollutants
6 NYCRR Part 257, Air Quality Standards
6 NYCRR Part 212, Air Emission Standards
6 NYCRR Part 373, Fugitive Dusts
40 CFR 50, Air Quality Standards
• State Permit Discharge Elimination System
• Resource Conservation and Recovery Act
28
-------
Chemical-specific ARARs:
Safe Drinking Water Act (SDWA) MCLs and MCL Goals (MCLGs)
40 CFR Part 141
• 6 NYCRR Parts 700-705 Groundwater and Surface Water Quality
Regulations
• 10 NYCRR Part 5 State Sanitary Code
Location-specific ARARs:
Clean Water Act Section 404, 33 U.S.C. 1344
Other Criteria, Advisories, or Guidance To Be Considered:
• New York Guidelines for Soil Erosion and Sediment Control
• New York State Air Cleanup Criteria, January 1990
• New York State Technical and Administrative Guidance
Memorandum (TAGM)
• New York State Air Guide-1
Cost-Effectiveness
The selected remedy provides for overall effectiveness in proportion to
its cost and in mitigating the principal risk posed by contaminated
groundwater. The estimated cost for the selected remedy has a capital
cost of $2,101,054, annual operation and maintenance of$114,125, and
a 10-year present-worth cost of $3,036,924.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy utilizes permanent solutions and alternative
treatment technologies to the maximum extent practicable by employing
LTTD to treat source area soils and a groundwater extraction system to
remove contaminated groundwater from the bedrock aquifer.
29
-------
Preference for Treatment as a Principal Element
The selected remedy's utilization of LTTD to treat source area soils
satisfies the statutory preference for remedies employing treatment that
permanently and significantly reduces the toxicity, mobility, or volume
of hazardous substances.
DOCUMENTATION OF SIGNIFICANT CHANGES
There are no significant changes from the selected alternative
presented in the Proposed Plan'.
30
-------
FIGURES
FIGURE 1 SITE LOCATION MAP
FIGURE 2 SITE LAYOUT MAP WITH MONITORING WELL LOCATIONS
FIGURE 3 AREAS OF CONCERN
FIGURE 4 DISTRIBUTION OF 1,1,1-TCA IN OVERBURDEN
GROUNDWATER (PW-2 AREA)
FIGURE 5 DISTRIBUTION OF 1,1,1-TCA IN OVERBURDEN
GROUNDWATER (PPS AREA)
FIGURE 6 DISTRIBUTION OF 1,1,1-TCA IN OVERBURDEN
SOIL (PPS AREA)
FIGURE 7 DISTRIBUTION OF 1,1,1-TCA IN OVERBURDEN
SOIL (PW-2 AREA)
FIGURE 8 DISTRIBUTION OF 1,1,1-TCA IN BEDROCK WELLS
-------
ai.x trtc./lWinnzi l~ine (.
Stte Location Map
ROBINTECH
NATIONAL
Figure 1
-------
Current Site Layout
Parkway
Vending
Company
LEGEND
-ff-f- Rallm«d
noiidenca
B Builnatt
Monitoring Wei
PW Pnxluei)onW»ll
Building //
•- -• Slomi Waler Sow«
Fanca
•• • — • Properly Oourxtary
Figure 2
o
p
co
-------
Jf.
NORTHEASTERN SITE
BOUNDARY AREA
IfCTMO
su*f*cr CONTOUR
WTOMCD OKXMMAtOI SUKTACC
CONtOUft UMC
---- PMOKRIY eOUMOMT
-- r -- STOmi SOrW
— -- ORMNMX «TCH
itcsooce
CNO«mmoo« MOMICWNC wtu.
8OWOCX UOMTOANC «tU
MltRUCDuTT UOMrc^xC WtLL
PTOOUCTON WQX
PW-2AREA
APPROXIMATE SCALE IN FHET
I
250
500
U.S.E.P.A. REGION I!
ROeiNTECH/NATICNAL PIPE
APPROXIMATE BOUNDARIES OF AREAS OF CONCSnN
FIGURE 3
-------
swn-oe
1.013
-SWO-JJ
15
SWO-IO
• 090
SWB-OI
SWB-JI -SWO-07
sc-oj , \x
575 I I/I SWO-21
<«~
500
SKME M02
SE-02
156
5QILSQURCLARBA.
9 SWO-15
DHY
PW2 ARCA
AQUEOUS TCA ISOCOHCENTRATION MAP
UOfllNIECH. IMC./MAIIOMAl. PIPE SUPCRFUND SHE
VESIAI.. NEW YORK
J.ECLMD
f) OvntfUJRIini MOinlORIIIC WCII.
ICA cniirrriiRAiioiis iisitn HI IAOIC
EI-IVIRONMEWTAL
ENCINECRlHC
CORPORATION
uoinromiic WCIL #swn-i9 CEtipRonc niiRinc IOCAIIOII
un.irm.in wta 4 ICA COHCDIIRMION
— loo— ICA isni:nin:r.niiiAiH)ti CONIOUII (ppi.)
XLL-
-------
""X rpA-o><\n».«i
PPA-fM • S7 • |k '
I .«> •' PPA-52 ' "^^
OVCRDURDEN MOHUORING V/ELL
BEOROCK MONITORING WELL
PRODUCTION WELL
LATERAL EXIEXI Or IMPACT AREA
* PPA- 1 2 CEOPRODE GORING LOCATION
TCA CONCENTRATION (ppli)
NO OEIECIlON
— 100— ICA ISOCOflCEMIHAIIOH COHlOUR
--- pnOPCRTY BOUNDARY
PAVED PIPE STAGING AREA
AQUEOUS TCA ISOCONCEMTRA7ION MAP
ROniNICCII. INC./NATIONAL PIPE SUPfRfUMO SHE
VCSFAI.. NEW YORK
ESMP
* ENVIRONMENTAL
ENGINEERING
CORPORATION
FIGURE 5
-------
r,(>. in.
us
i.nv - 11
OW-07
IK)
OW-08
NS
PAVCO
SOIL SOURCE AREA
WITH TCA CONCENTRATIONS ABOVE
MYS TAG!.! VALUE (0.76 pprn)
LEGEND
& OvtRBUROCH UOHIIORlllC WCll
O . BCOROCK MONITORING WCLl
• CP-?0 BORII1C lOCAtiOll
• Cw-OI CxIRACIiOH WCll
• Uw-06 OOSCRvAliOIJ PiC?6uCICR
0 01 ICA COllCCNIRAliOII (ppm) ill SOIL
NO ICA, not onCCICO OR fiflO
fiOOiliC mOiCAICS HO luPACI
US NOI SAiiPiCD
PAVED PIPE STAGING AREA
RDWPA BORING LOCATION MAP
ROOINTECII. INC./NATIONAL PIPE CO
VESTAL. NEW YORK
ENGINEERING
CORPORATION
-------
CP-17
NO *
PAVED
JO f£i
SOIL SOURCE AREA
WITH TCA CONCENTRATIONS ASOVc
NYS TAGM VALUE (0.76 opm)
f»w-5
Figure 7
OvESSURCEN uONirCHiNC
• :'-3 so»iNC '.ccAfiON
• -:«-o:
• •"••-01
PW-2 AR
Rpy/PA SPRING ^ WELL P',OT LOCATION MA?
R06INTECH. INC./NAriONAL r!F£ CO.
VESTAL. N£'«v YORK
NO rc* nor ocrccrco o«
NO
IN SO'l.
.3 "Q
,liN~AI_
u j 2.
I C:-K'0: 0 K
-------
GROU40WAKR StmrA.CC CONIOlXI LIIIC
UlffRRfO CROIINDWA1CR SURfACC
CONIOUR I INC
— •. --- PROPtflnr BOUNDARY
---- SIORU SEWER
— — — DRAttMCC 0»ICM
tf.
0 250 500
IIOTE: BASE MAP FROM McLAREN HART
R RESIDENCE
B BUSINESS
6» OvtHUUROlll MOHIIORiKG WEIL
BEDROCK UONHOnmC WELL
IIIERUEDIAIE MOIIIIORINC WEIL
PRODUCTION WEIL
1.1.1 TCA CONCENTRA1ION (ppb)
• 1.1.1 TCA ISOCONCENTRATION LINE
NOTrS:
1. FIGURE BASED ON ANALYTICAL DATA FROM
t.KOUNDWATER SAMPLING ROUND PERFORMED
IN SEPTEMDER. 1995.
2. TCA CONCENTRATION IN'PW-2 FROM I99S
DISCRETE INTERVAL SAMPLING (45-53 FEEf).
3: TCA CONCENTRATION IN PW-3 FROM 1994
DISCRETE INTERVAL SAMPLING (50-55 FEET).
PIRNIE
U.S.E.P.A. REGION II (ARCS)
RODINTECH/NATIONAL PIPE RD/RA
AQUEOUS TCA ISOCONCENTRATION MAP- BEDROCK
COPYRIOir
-------
APPENDIX II
TABLES
-------
TABLES
TABLE 1 SOIL SAMPLING DATA, ORGANIC PARAMETERS (PPS AREA)
TABLE 2 OVERBURDEN GROUNDWATER SAMPLING DATA, ORGANIC
PARAMETERS (PPS AREA)
TABLE 3 OVERBURDEN GROUNDWATER SAMPLING DATA, ORGANIC
PARAMETERS (PW-2 AREA)
TABLE 4 SOIL SAMPLING DATA, ORGANIC PARAMETERS (PW-2 AREA)
TABLE 5 BEDROCK GROUNDWATER SAMPLING DATA,
ORGANIC PARAMETERS
TABLE 6 CONTAMINANTS OF CONCERN
TABLE 7 SUMMARY OF EXPOSURE PATHWAYS
TABLE 8 TOXICITY VALUES
TABLE 9 SUMMARY OF CARCINOGENIC RISKS
TABLE 10 SUMMARY OF NON-CARCINOGENIC RISKS
TABLE 11 FEDERAL AND STATE MAXIMUM CONTAMINANT LEVELS
FOR DRINKING WATER
TABLE 12 NYSDEC TAGM OBJECTIVES FOR ORGANICS IN SOIL
-------
Sihlc.l
Rohinlcch, Inc./National Pipe Co. Site
Vestal, New York
ANALYTICAL RESULTS
PAVED PIPE STAGING AREA - SOIL SAMPLING
RDWP / RDWPA
Sample ID
Dilution Factor
Sample Matrix
Sample Interval (reel)
Sample Dale
Analysis Dale
GP-fll
IX
SOIL
5-7
10/1 1/95
10/12/95
GP-OI
10 X
SOIL
9- 10
10/1 1/95
10/13/95
GP-02
IX
SOIL
6-7
10/12/95
10/12/95
GP-13
100 X
SOIL
6-6.5
10/16/95
10/16/95
GP-13.
100 X
SOIL
6.5-7
10/16/95
10/16/95
GP-13
200 X
SOIL
10.5-11
10/16/95
10/16/95
GP-13
200 X
SOIL
12.5-13
10/16/95
10/16/95
GP-14
2X
SOIL
7-8
10/16/95
10/16/95
GP-15
IOOX
SOIL
5-7
10/16/95
10/16/95
Volilale Organic Compounds (ppm)
I.l.l-Trichloroelhane
Trichloroelhcnc
Toluene
Tclrachloroclhcne
0.023
0.005 U
0.005 U
0.500 U
0.189
0.005 U
0.005 U
0.500U
0.005 U
0.021
0.005 U
0.500 U
1.138
0.005 U
0.005 U
0.500 U
1.135
0.005 U
0.005 U
0.500 U
6.876
I.OOOU
I.OOOU
.I.OOOU
4.231
I.OOOU
1.000 U
I.OOOU
r^H^r^^^sm^f^^ ••' •••i:zxKWi®i*'£%
0.027
0.010 U
0.010 U
0.010 U
SBffiltMftiirMlltfIBB
2.927
0.005 U
0.005 U
0.500 U
Sample ID
Dilution Factor
Sample Matrix
Sample Interval (feel)
Sample Dale
Analysis Dale
GP-15
50 X
SOIL
8.5-9
10/16/95
10/17/95
GP-19
1 X
SOIL
0-4
10/17/95
10/17/95
GP-19
5X
SOIL
10-12
10/17/95
10/17/95
GP-20
2X
SOIL
3-4
10/17/95
10/17/95
GP-20 .
10 X
SOIL
6-7
. 10/17/95
10/17/95
GP-21
IX
SOIL
0-1
10/17/95
10/17/95
GP-23
IX
SOIL
7-8
10/17/95
10/18/95
GP-23
5X
SOIL
10-12
10/17/95
10/18/95
GP-24
1 X
SOIL
4-4.5
10/18/95
10/18/95
Volilale Organic Compounds (ppm)
1,1.1-Trichloroclhanc
Tricliloroelhenc
Toluene
Tetrachloroclhene
0.584
0.025 U
0.025 U
0.025 U
0.048
0.011
0.048
0.005 U
0.078
0.025 U
0.025 U
0.025 U
0.074
0.010 U
0.010 U
0.010 U
0.225
0.050 U
0.050 U
0.050 U
0.024
0.005 U
0.005 U
0.005 U
0.023
0.005 U
.0025 J
0.005 U
0.153
0.025 U
0.025 U
0.025 U
0.015
0.005 U
0.005 U
0.005 U
NOTES
J = Outside Linear Working Range (Low)
E = Outside Linear Working Range (High)
B = Compound Found in Method Blank.
U = Below Method Quanlitation Limits
NA = Not Analyzed
IPPSSOILXLWJl007.XLS
-------
Tjiblc 1
Rohinlech, Inc/Nalional Pipe Co. Site
Vesjal, New York
ANALYTICAL RESULTS
PAVED PIPE STAGING AREA - SOIL SAMPLING
RDWP/RDWPA
Sample ID
Dilution Factor
Sample Matrix
Sample Interval (feet)
Sample Date
Analysis Date
OP-24
5X
SOIL
12- 14
10/18/95
10/18/95
GP-25
2.5 X
SOIL
0-4
10/18/95
10/18/95
GP-25
2X
SOIL
11.5- 12
10/18/95
10/18/95
OW-06
1 X
SOIL
8-9
10/12/95
10/16/95
PPA-06
IOX
SOIL
1.5-2.0
12/9/94
12/9/94
PPA-06
IOX
SOIL
2.5-3.0
12/9/94
12/9/94
PPA-06
IOX
SOIL
3.0-3.5
12/9/94
12/9/94
PPA-15
1 X
SOIL
1-3
12/8/94
12/8/94
PPA-15
12.5 X
SOIL
3-5
12/8/94
12/8/94
Volatile Organic Compounds (ppm)
I.l.l-Tricliloroethane
Tricliloroelhene
Toluene
Telrachloroclhene
0.046
0.025 U
0.025 U
0.025 U
0.0125 U
00125 U
0.01 25 U
0.0125 U
0.16
0.010 U
0.010 U
0.010 U
0.048
0.025 U
0.025 U
0.025 U
0.050 U
NA
NA
NA
0.050 U
NA
NA
NA
0.107
NA
NA
NA
.109E
NA
NA
NA
0.501
NA
NA
NA
lw>3^tm^^wmvmM*%ffi^*%it^
Sample ID
Dilution Factor
Sample Matrix .
Sample Interval (feel)
Sample Dale
Analysis Dale
PPA-28
5X
SOIL
0-2
12/14/94
12/20/94
PPA-3 1
5X
SOIL
6-8'
12/14/94
12/15/94
PPA-32
5X •
SOIL
0-2
12/14/94
12/15/94
. PPA-44
IOX
SOIL
4-6
12/21/94
12/21/94
Volatile Organic Compounds (ppm)
1,1,1-Trichloroethane
Tricliloroelhene
Toluene
Telrachloroctlicne
0.025 U
NA
NA
NA
0.0748
NA
NA
NA
0.025 U
NA
NA
NA
0.1497
NA
NA
NA
NOTES
J = Outside Linear Working Range (Low)
E = Outside Linear Working Range (High)
B =• Compound Found in Method Blank
U = Below Method Qiianlilalion Limits
NA = Not Analyzed
jrrssoi
|r007.XLS
-------
able 2
Robinlccli, Inc. / National Pipe Co. Site
Vestal, New York
ANALYTICAL RESULTS
PAVED PIPE STAGING AREA - CROUNDWATER SAMPLES
TEMPORARY WELL POINTS
RDWP
Sample ID
Dilution Factor
Simple Matrix
Sample Interval (feet)
Sample Dale
Analysis Date
PPA-OI
1 X
WATER
8-9
12/6/94
12/6/94
PPA-02
50 X
WATER
8-9
12/6/94
12/6/94
PPA-03
10 X
WATER
7.5-8.5
12/6/94
12/6/94
PPA-04
4X
WATER
7-8
12/6/94
12/6/94
PPA-05
IX
WATER
'6-7
12/7/94
12/7/94
PPA-06
250
WATER
9-11
12/7/94
12/7/94
PPA-07
5X
WATER
6-9
12/7/94
12/7/94
PPA-08
100 X
WATER
7-9
12/7/94
12/7/94
1,1,1 -Trichloroethane (ppb)
Sample ID
Dilution Factor
Sample Matrix
Sample Interval (feet)
Sample Dale
Analysis Dale
PPA-09
-
DRY
11-12
12/7/94
-
PPA-IO
20 X
WATER
11-12
12/7/94
12/7/94
PPA-ll
IX
WATER
7-9
12/7/94
12/7/94
PPA-12
16.66
WATER
10.5-12.5
12/7/94
12/7/94
PPA-I3
1 X
WATER
8-10
12/8/94
12/8/94
PPA-14
5X
WATER
11-12
12/9/94
12/9/94
PPA-15
250 X
WATER
5-7
12/8/94
12/8/94
PPA-16
IOX
WATER
9.5-10.5
12/9/94
12/9/94
1,1
, l-Trichloroelliane (pph)
| DRY |
395
13
271
148 |
25
lA |
13,080 j
292 1
NOTES
J = Outside Lineiir Working Rungc (Low)
E = Outside Linear Work in i; Range (Miuli)
I) = Compound Found in Method Dliink
II =- ndow Mclluul Qiianliliilinn Limits
-------
'I able 2
Rohinlech. Inc. / National Pipe Co. Site.
Vestal, New York
. ANALYTICAL RESULTS
PAVED PIPE STAGING AREA - GROUNDWATER SAMPLES
TEMPORARY WELL POINTS
RDWP
Sample ID
Dilution Factor
Sample Matrix
Sample Interval (feet)
Sample Dale .
Analysis Date :
PPA-17
1 X
WATER
11-12
12/9/94
' 12/9/94
PPA-IB
IOX
WATER
8-9
12/9/94
12/9/94
PPA-19
1 X
WATER
11-12
12/12/94 •
12/14/94
PPA-20
SOX
WATER
11-12
12/13/94
12/15/94
PPA-21
5X
WATER
8-9
12/13/94
12/15/94
PPA-22
IOX
WATER
M-12
12/14/94
12/15/94
PPA-23
1 X
WATER
7-8
12/14/94
12/15/94
PPA-24
25 X
WATER
M-12
12/14/94
12/15/94
11,1.1 -Trichloroelhane (ppb)
5.080 E
Sample ID
Dilution Factor
Sample Matrix
Sample Interval (feel)
Sample Dale
Analysis Date
PPA-25
. • -
DRY
7-8
12/14/94
• -
PPA-26
20 X
WATER
12-14
12/14/94
.12/15/94
PPA-27
1 X
WATER
10-12
12/14/94
12/15/94
PPA-28
-
DRY
11-12
12/14/94
-
PPA-29
5X
WATER
12-14
12/14/94
12/15/94
PPA-30
IOX
WATER
10-12
12/14/94
12/15/94
PPA-31
5X
DRY
11-12
12/14/94
12/15/94
PPA-32
1 X
WATER
11-12
12/14/94
12/15/94
DRY
[j,|.l-Trichloroelliane(ppb)
284
30
DRY
116
217 J DRY
SU
NOTES
J = Outside Linear Working Range (Low)
R = Outside Linear Working Range (High)
R = Compound Found in Method Blank
II •-- llclitw Mclluul Qiiiiiililiilion Limits
i' V^V|i,
-------
able 2
Rohinlech. Inc. / National Pipe Co. Site
Vestal. New York
ANALYTICAL RESULTS
PAVED. PIPE STAGING AREA - GROUNDWATER SAMPLES
TEMPORARY WELL POINTS
RDWP
Sample ID
Dilution Factor
Sample Matrix
Sample Interval (feel)
Sample Dale
Analysis Date
PPA-33
•
DRY
10-12
12/14/94
-
PPA-34
250 X
WATER
9-1 1
12/14/94
12/15/94
PPA-35
-
DRY
10-12
12/14/94
-
PPA-36
.-
DRY
11.5-13.5
. 12/15/94
•
PPA-37
1 X
WATER
12-14
12/15/94
12/15/94
PPA-38
• -
DRY
12-14
12/15/94
•-
PPA-39
1 X
WATER
14-16
12/15/94
12/15/94
PPA-40A
I X
WATER
8-10
12/15/94
12/15/94
I, I, l-Trichloroelhane (ppb)
Sample ID
Dilution Factor
Sample Matrix
Sample Interval (feet)
Sample Dale
Analysis Dale
PPA-41
-
REFUSAL
12/19/94
-
PPA-42
-
REFUSAL
-
12/19/94
•
PPA-43*
-
NOT
SAMPLED
'-
.
PPA-44
REFUSAL
-
12/21/94
-
PPA^S
50 X
WATER
10-12
12/21/94
12/21/94
PPA-46
-
REFUSAL
-
12/21/94
. -
PPA-47
1 X
WATER
11-13
12/21/94
12/24/94
PPA-48
-
NOT
SAMPLED
- '
-
11.1, l-Trichloroelhane (pph)
473
32
''
NOTES
* PPA-43-vvas drilled for lillioloyic dclerminjilion only; no Siimplcs were collected Irom the horiny.
J = Outside Linear Working Ranye (Low)
I: = Outside Linear Working Riinge (Uiyh)
li - Compound Found in Method Rlank
II - llelou' Method Qiiiiiiiilaiiuii Limits
-------
Table 2
Robiniecli. Inc. / National Pipe Co. Site
Veslal, New York
ANALYTICAL RESULTS
PAVED PFPE STAGING AREA - GROUNDWATER SAMPLES
TEI\fPORARY WELL POFNTS
RDWP
Sample ID
Dilution Factor
Sample Matrix
Sample Interval (feet)
Sample Date
Analysis Date
PPA-49
-"
DRY
13-15
12/21/94
-
PPA-50
SOX
WATER
10-12
12/21/94
12/24/94
PPA-5!
1 X
WATER .
6.5-8.5
12/21/94
12/24/94
PPA-52
250 X
WATER
7-9
12/22/94
12/24/94
PPA-53
-
DRY
7.5-9.5
12/8/94
.
{l.l.l-Trichloroethane
NOTES
J = Outside Linear Working Range (Low)
E •= Outside Linear Working Range (High)
B = Compound Found in Method Blank
U = Below Method Quanlilalion Limits
-------
Table 2
Robinlech. Inc. / National Pipe Co. Siiperfimd Sile
Vestal, New York
ANALYTICAL RESULTS
PAVED PIPE STAGING AREA - GROUNDWATER SAMPLES
MONITORING WELLS
RDWP
Sample ID
Dilution Factor
Sample Matrix
Sample Interval (feet)
Sample Date
Analysis Dale
MW-ll
10 X
WATER
8-18
12/6/94
12/7/94
MW-12
IX
WATER
10-20
12/12/94
12/12/94
I.I.I -Trichloroethane (ppb)
165 E ] 5 U ]
NOTES
J = Outside Linear Working Range (Low)
E = Outside Linear Working Range (High)
0 = Compound Found in Method Blank
U = Below Method Quanlilfllion Limits
-------
Table 3
Rohintccli, Inc. / National Pipe Co. Site
• Vestal, NY
ANALYTICAL RESULTS
PW-2 AREA - UN-SITE GROUNDWATER SAMPLES
TEMPORARY WELL POINTS
RDWP / RDWPA
Sample ID
Dilution Factor
Matrix
Sample Intctval (feet)
Sample Date
Analysis Dale
SWB-17
100 X
WATER
18.5
12/15/94
12/19/94
SWD-18
500 X
WATER.
18-20
12/16/94
12/19/94
SWB-19
1 X
WATER
20
12/16/94
12/19/94
SWB-20
5X
WATER
19.
12/16/94
12/19/94
SWB21
2500 X
WATER
18-20
12/16/94
12/16/94
SWB-21
500 X
WATER
18-20
12/16/94
' 12/19/94
SWB-21 A
I7X
WATER
17
12/16/94
12/19/94
SWD22
250 X
WATER
17-19
12/19/94
12/19/94
Volatile Organic Compounds (p
1.1,1-Trichloroethane
1.1-Dichloroethane
1,1-Dichloroethene
Chloroform
Tetrachloroethene
Toluene
Trichloroethene
Vinyl Chloride
pb)
1125
1543
869
500U
500U
500U
2517
500U
3683
2129 J
2500 U
2500 U
2500 U
2500 U
1706J
2500 U
41
8 '
13
5U
5U
5U
27 .
5U
195
65
29
. .2511
65
25 U
209
25 U
180005
49465
73669
I2250U
12250 U
175218
34326
12250 U
222129 E
53166
60052
2500
2500
2500
15565
2500
1288 E
85 U
230
85 U
54 J
4587 E
85 U
85 U
104192 E
60232
34568 E
1250 U
I250U
2920
10929
1250 U
NOTJ-S
J = Outside Linear Working Range (Low)
H - Outside Linear Working'Runge (High)
I) — Compound Found in Method Dl.uil;
II llvlmv NUllinil Qu:inlil:iiioii Liiuils
l'.nv
-------
Table 3
Rohinlech, Inc. / National Pipe Co. Site
Vestal. NY
. ANALYTICAL RESULTS
PW-2 AREA - ON-SITE GROUNDWATER SAMPLES
TEMPORARY WELL POINTS
RDWP/RDWPA
Sample ID
Dilution Factor
Matrix
Sample Interval (feet)
Sample Date
Analysis Date
SWB-09
SOX
WATER
14-16
12/12/94
12/14/94 .
SWB-IO
20 X
WATER
17-19
12/13/94
12/15/94
SWB-II
250 X
WATER
11-13
12/13/94
12/14/94
SWB-12
5X
WATER
19-21 '
12/13/94
12/15/94
SWB-13
5X .
WATER
19-21
12/13/94
12/15/94
SWB-14
5X
WATER
18-20
12/13/94
12/14/94
SWB-15
-
DRY
24.
12/15/94
'
SWB-16
20 X
WATER
18.5
12/15/94
12/19/94
Volatile Organic Compounds (p
1,1,1-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
Chloroform
Tetrachloroethene
Toluene
Trichloroelhene
Vinyl Chloride
pb) . • ' •• ' ' • .
562
132 J
250 U
250 U
250 U
250 U
859
250 U
990
113
159
100 U
100 U
100 U
111
100 U
4070
2891
1250U
1250 U
I250U
I250U
1250 U
1250 U
93
25 U
15J
25 U
22J
25 U
101
25 U ;
117
20 J
I5J
25 U
25 U
25 U
. 104
25 U
54
25 U
25 U
25 U
25 U
25 U
65
25 U
-
-
-
•-
-
.
-
1614
1750
771
100 U
100 U
100 U
208
. 100 U
NOTFS
J = Outside Linear Working Range (Low)
I: = Outside Linear Working Range (High)
II = Compound found in Method Bl;mk
I! •• IK'loxv Mclliuil Quanlilaliiin Limits
invifi\v.xf.w|i(ii!.xi.s
-------
Tnhle 3
Rohinlixli, Inc. / National Pipe Co. Site
Veslal, NY
ANALYTICAL RESULTS
PW-2 AREA - ON-SITE GROUNDWATER SAMPLES
TEMPORARY WELL POINTS
RDWP/RDWPA
Sample ID .
Diliition Factor
Matrix
Sample Interval (feet)
Sample Date
Analysis Date
SWD-OI
500 X
.WATER
18-20
12/6/94
12/7/94
SWB-02
500 X
WATER
18-20
12/7/94
12/7/94
SWD-03
20 X
WATER
17
12/9/94 '
12/9/94
SWD-04
100 X
WATER
16.5
12/9/94
12/9/94
SWB-05
100X
WATER
18
'12/9/94
12/9/94
SWB-06
100 X
WATER
14-16
12/12/94 .
12/15/94
SWD-07
5 X
WATER
19-21
12/12/94
12/12/94
SWD-08
500 X
WATER
14-16
12/12/94
12/12/94
Volatile Organic Compounds (p
1.1,1-Trichlu.oethane
1,1-Dichloroethane
1,1-DichIoroethene
Chloroform
Tetrachloroethene
Toluene
Trichloroethene
Vinyl Chloride
pb)
24733
29433 E
17782
2500 U
2500 U
2500 U
2500 U
2500 U
25368
8910
3429
2500 U
2500 U.
4222
2500 U
'5379
152
90 J
100 U
52 J
57 J
100 U
272
100 U
1402
1002
500 U
500 U
429 J .
500 U
399 J
500 U
1243
1676
556
1067
500 U
500 U
500 U
500 U
1013
1255
500 U
500 U
891
500 U
500 U
500 U
129
25 U
51
25 U
25 U
25 U
25 U
25 U
13943
8132
2974
2500 U
2500 U
2500 U
2500 U
2500 U
MOTHS
J = Oulsidi! Linear Working Range (Low)
I: = Ouisidc Linear Winking Himije
I) = Compound Found in Method Dlank
• (' • Hi-low Mi-thudQii;nilii;\liim l.iiniis
-------
Table 3
Roliiniech. Inc. / Nuionil Pipe Co. Site
Veslil. NY
ANALYTICAL RESULTS
PW-2 AREA • ON-SITE GROUNDWATER SAMPLES
TEMTORARY WELL POINTS
RDWP/RDWPA
Sample ID
Dilution Factor
Matrix
Sample Interval (reel)
Sample Date
Analysis Date
SWB-22
SOX
WATER
17-19
11/19/94
12/19/94
SWB-23
0.5 X
WATER
18
12/20/94
12/21/94
SWB24
2500 X
WATER
19-21
12/20/94
12/20/94
SWB-25
20 X
WATER
14.5-16.5
12/20/94
12/20/94
SWB-26
DRY
15
12/20/94
-
SWB-27
-
DRY
19.6
12/20/94
.
SWB-28
250 X
WATER
17-19
12/20/94
12/20/94
SWB-29
5 X
WATER
14.5^16.5
12/20/94
12/20794
Volatile Organic Compounds fa
1,1,1-Trichloroethane
I.l-Dichloroethane
I.l-Dichloroelhene
Chloroform
Telrachloroethene
Toluene
Trichloroelhene
Vinyl Chloride
pb) ' : • . • '
18457 E
6741 E
3269 E
250 U
250 U
250 U
878
250 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
101279
15405
14161
12250 U
122 SOU
116800
12250 U
122 SOU
800
262
214
100 U
100 U
100 U
75 J
IOOU
'
-
.
- •
-
.
-
- •-
• -
-
-
-
-
•
-
39565
18249
14766
I2SOU
12 SOU
I250U
I2SOU
I250U
55
25 U
20 J
25 U
25 U
25 U
24 J
25 U
NOTES
I - Oiilxidti Linear Working R«nge (Liiw)
H « Outside Linear Working Ringc (High)
n •» Coin|MMind runnel in Method fllmik
II llclinv MclliiMl Quiinlihiliini I
l'Jr. 1.40
-------
Table 3
Robinlech, Inc. / National Pipe Co. Site
Vestal.'NY
ANALYTICAL RESULTS
PYV-2 AREA - ON-SITE GROUNDWATER SAMPLES
TEMPORARY WELL POINTS
RDWP / RDWPA
Sample ID
Dilution Factor
Matrix
Sample Interval (feet)
Sample Date
Analysis Date
SWB-30
250 X
WATER
6-8
12/20/94
12/20/94 .
SWB-31
20 X
WATER
19-21
12/20/94
12/21/94
: SWB-32
20 X
WATER
21-23
12/20/94
12/21/94
SWB-33
1 X
WATER
16-18
12/20/94
12/20/94
SWB-34
IX
WATER
16-18
12/21/94
12/21/94
SWB-35
IX '
WATER
7-9
12/21/94
12/21/94
Volatile Organic Compounds (p
1 , 1 , 1 -Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
Chloroform
Tetrachloroethene
Toluene
Trichloroethene
Vinyl Chloride
>b)
1546
967 J
334 J
I250U
1299
1250 U
1250 U
1250 U
426
1064
202
100 U
100 U
100 U
208
100 U
162
487
61J
100 U
100 U
100 U
256
100 U
15
5U
5U
5U
5U
5U
5
5U
5U
5U
5U
5U
5U
5U
5U
5U
6
5
5U •
5U
5U
5U
5U
5U
NOTES
J = Outside Linear Working Range (Low)
I: = Outside Linear Working Range (High)
I) = Compound Found in Method Blank
I1 llcloiv Mi-Hind Qii:iiiiil:iiinii l.iiuils
M1\v»i;w.\i.W'|niu.\i.s
-------
Table 3
Rohinlech, Inc. / National Pipe Co. Site
Vestal. NY
ANALYTICAL RESULTS
PW-2 AREA - ON-SITE GROUNDWATER SAMPLES
TEMPORARY WELL POINTS
RDWP/RDWPA
Sample ID
Dilution Factor
Matrix
Sample Interval (feet)
Sample Date
Analysis Date
GP-05
500 X
WATER
22 - 24 .
10/12/95
10/13/95
GP-05
5,000 X
WATER
22 - 24
10/12/95
12/161/94
GP - 06
500 X
WATER
15- 17
10/12/95
10/13/95
GP-06
1 0,000 X
WATER
15- 17
10/12/95
10/18/95
Volatile Organic Compounds (p
1 , 1 , 1 -Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
Chloroform
Tetrachloroethene
Toluene
Trichloroethene
Vinyl Chloride
pb)
44.288E
NA
NA
NA
2,500 U
9,781
2,500 U
NA
66,275
NA
NA
NA
NA
NA
NA
NA
196,869E
NA
NA
NA
2,500 U
155.152E
14,000
NA
376,030
NA
NA
NA
NA
191,090
NA
NA
NOTES
j = Outside Line:ir Working Range (Low)
I- = Outside Linear Working Range (I Ik-li)
U = Compound Found in Method Blank
II l)elo\v Method Qiiiiniiiiiiiiui Limits
-------
Tnble. 3
Itoliinlcclt, Inc./ National Pipe Co. Site
Veslal. NY
ANALYTICAL RESULTS
PW-2 AREA - OFF-SITE SAMPLES
TEMPORARY WELL POINTS
RDWP • . •
Sample ID
Dilution Factor
Malrix
Sample Interval (feet)
Sample Date
Analysis Date
SE-01
' 5 X
WATER
7-9
12/13/94
12/13/94
SE-02
25 X
WATER
: 7-9 ,
12/13/94
12/13/94
SE-03.
100 X
WATER
.9-11
12/13/94
12/13/94
SE-04 .
REFUSAL
8'
. 12/19/94
' - .
SE-05 .
.' - . '
REFUSAL
.7'
•12/19/94
- .
SE-06 .
IX
WATER
8:10
'12/21/94
12/21/94
SE-07
IX
WATER
10-12
12/21/94
12/21/94
SE-08
SOX
WATER
12-14
12/21/94
12/21/94
SE-09
5X
WATER
12-14
12/21/94
12/23/94
Volatile Organic Compounds (pph)
I.l.l-Tricliliuoelhane
1, l-Dicliloroclhane
I.I-Dichloroelhene
Chlorofonn
Telrachloroelhene
Toluene
Trichlnroelhene
Vinyl Chloride
69
25 U
25 U
25 U
25 U
25 U
199 .
25 U '
156
I2i U
125 U
125 U
100 J
125 U
532
125 U
575
398 J :
' 500 U
500 U .
500 U
500 U
500 U
500 U
. ••
:
- •-•.''
' •»
.•• . .
•
.
•- • -
.
.
. -
' ' •
•
•
• '• -
5U
5U
5U
5U
5U
SU
5U
5U
5U
5U
5U
5U
5U
5U
5U
5U
£02
4604
250 U
250 U
250 U
250 U
250 U
250 U
64
227
25 U
25 U
25 U
25U
25 U
25 U
I *> Ouliidc Uncir Worklnj R«n|e (Low)
E » Ouliide Unttt Working Rjnfc (Itlgb)
n » Conic—irkl Found In Method Blink
II - lulow Method Qvunliltlioo Umiti
. P«g«lof2
-------
Tiiblc 3
Robinlech. Inc. / Nitionil Pipe Co. Site
VeaUl. NY
ANALYTICAL RESULTS
PW-2AREA - OFF-SITE SAMPLES
TENfPORARY \VELL POINTS
. RDWP
Sample ID
Dilution Factor
Matrix
Sample Interval (feel)
Sample Date
Analysis Dale
SI:- 10.
IX.
WATER
13-15
12/21/94
12/23/94
SE-1I
.
REFUSAL
8 '
12/21/94
DRY
SE-12
IX -
WATER
1Q-12
12/21/94.
U/23/94
. SE-13
1 IX .'
WATER .
10-12
12/21/94
12/23/94 .
SE-I4
. -
REFUSAL
8
. 12/21/94
DRY
SE-15
IX
. WATER
14-16
12/21/94
12/23/94
SE-16
IX
WATER
12-14
12/22/94
12/23/94
SE-17
.IX
WATER
12-14
12/22/94
12/23/94
SE-18
10 X .
WATER
11-13
12/22/94
12/23/94
Volatile Organic Compounds (ppb) - .
I.I.I -Triuhlorocllmne
1, l-l)iclilocoelliine
1 . 1 -Dichtnnxthene
Chloiuform
Telr*chlon>cfhene
Toluene
Trichloroelhene
Vinyl Chloride
32
II
4J
SU
' 5U
5U
28
5U
••
.
-
-
.
-'
•
- •
15 "
51
4/
SU "
5U
SU
10
SU
5U
4J
5U
SU
SU
5 11 ' '
5U
5U
' • . .• •
- •
.
. •
.
.
.
-
5U
SU
SU
5U
5U
5U
SU
SU
12
140 E
5U
SU
SU
. 5 U
SU
SU
SU
SU
SU
SU
SU
SU
SU
SU
312
208
54
SOU
SOU
SOU
55
SOU
I - Outiidc Until Wuikinf tUoft (Low)
E - Ouitidc UoMf Wojkinf IUn|C OI'lM
B • Coaipourfc! Pound In Mctliutl Blink
U - Below M«lhod QuanliUlion UmiU '
r>M 2 of]
-------
Table 3
Robintech, lac. / National Pipe Co. Site
Vestal, NY
ANALYTICAL'RESULTS
PW-2 AREA - GROUND WATER SAMPLES
MONITORING WELLS
RDWP/RDWPA
Sample ID
Dilution Factor
Matrix
Sample Interval (feet)
Sample Date
Analysis Date
MW-6
.IX
WATER
35-45
12/22/94
12/23/94
MW-7
200 X
WATER
13-23
12/6/94
12/7/94
MW-8
20 X
WATER
17-27
12/6/94
12/7/94
. MW-9
ix
WATER
15-25
' 12/19/94
12/19/94
Volatile Organic Compounds (p
1.1,1-Trichloroethane
l.l-Dichloroethane
1 , 1 -Dichloroethene
Chloroform
Tetrachloroethene .•
Toluene
Trichloroethcne .
Vinyl Chloride
*) -
5U
5U •
5 U
5U
5U
5U
1 5U '
5U
5392
11080
2668 J
3090J
1000 U
1000 U
1000 U
1000 U
328 -
182
141
168
- 202
100 U
670
100U
5U
5U
: 5u .
5U
5U
5U
5U
5U
NOTES
J m Ouuide L!n**r Working Hioge (Low)
E • Ouuide Une*r Working Range (High) "
B - Compound Found in Method BUnk '
U -Below Method Quantiucion Limit*
[PWlGW.XLW]mw WELLS
i,
-------
Tnble 4
Robinlccli, Inc. / National Pipe Co. Site
Vestal, New York
ANALYTICAL RESULTS
PW-2 AREA . SOIL SAMPLING
RDWP / RDWPA
Sample ID
Sample Interval (reel)
Dilution Factor
Sample Matrix
Sample Date
Analysis Date
EW-02
10-12
IX
SOIL
10/10/95
s 10/18/95
EW-02
14-16
. 100 X .
SOIL
10/10/95
10/11/95
EW-02
4-6
100X
SOIL
10/10/95
10/12/95
OW-03
4-6
100 X
SOIL
10/1 1/95
10/12/95
OW-03
6-8
12.5 X
SOIL
. 10/11/95
10/12/95
OW-3
14-16
5X
SOIL .
10/11/95
10/12/95
GP-05
2-2.5
5,000 X
. SOIL
10/12/95
10/12/95
GP-05
3.5-4
5,000 X
SOIL
. 10/12/95
10/13/95
Volatile Organic Compounds i
1,1,1-Tricnloroelhanc
Trichloroelhcnc
Toluene
Tetrachloroelhcnc
ppm) •'-•':' .
0.013
0.005 U
0.005 U
0.005 U
4.499
0.5 U
0.5 U
1.187
. 4.205
0.321 J
2.009
3.46
1.39
0.500 U
• 0.500 U
2.35
0.27125
0.0625 U
0.1325
O.I 15
0.025 U
0.08
0.025 U
0.025 IT
55.5
25 U
1 6.500 J
25 U
1,961 E
45.225
l,lf>8 E
25 U
' ?.1^^:^S'f-S:>SV <'«-*W£;'4^
Sample ID
Sample Interval (reel)
Dilution Factor
Sample Matrix
Sample Dale
Analysis Dale
GP-05
3.5-4
50,000 x;
SOIL
10/12/95
10/13/95
; GP-05
6-6.5 ,
4,000 X
SOIL
10/12/95
10/12/95
GP-05
6-6.5
1 00,000 X
•SOIL
10/12/95
10/18/95
GP-05
.8-8.5
400 X
SOIL ,
10/12/95
10/13/95
GP-05 :
13-14
400 X
SOIL
10/12/95
10/13/95
GP-05
16-17 '
200 X
SOIL
10/12/95
10/13/95
GP-05.
18-20
200 X
SOIL
10/12/95
10/13/95
GP-06
3.5-4
400 X
SOIL
10/12/95
10/13/95
Volatile Organic Compounds (ppm)
1,1.1-Trichloroelhane
1,226.90
2,475.600 E
2,842.60
2U
7.748
2.36
4.4
25.296 E
Trichloroelhene
250 U
154.400 E
500 U
2U
2U
1 U
IU
2U
Toluene
967.75
2,234.400 E
1,758.20
3.62
7.064
3.066
4.54
13.642
Telrachloroellicne
250 U
20 U
500 U
2U
2U
I U
I U
9.324
Notes ' ... . .
J = Outside Linear Working Range (Low)
E = Outside Linear Working Range (Hig'O
D = Compound Found in Method Blank
11 = Rrlnw Mclhnd Ojianlilajinn Limits
P.gc I of 4
|PW2SOIL.XLW|RIR.XLS
-------
Tnhle 4
' Robiatcch, Inc. / National Pipe Co. Site
, Vestal. New York
ANALYTICAL RESULTS
PW-2 AREA - SOIL SAMPLING
RDWP / RDWPA
Sample ID
Sample Interval (feet)
Dilution Factor
Sample Matrix
Sample Date
Analysis Date
GP-06
3.5-4
1.000 X
SOIL
10/12/95
10/12/95
GP-06
4-8
5.000 X
SOIL
10/12/95
10/12/95
GP-06
4-8
50.000 X
SOIL
10/12/95
10/13/95
GP-06
8-10
5,000 X ..
SOIL,
10/12/95
10/12/95
GP-06
,10-12
400 X
. SOIL
10/12/95
10/13/95
GP-06
16-17 '
400 X
SOIL
10/12/95
10/13/95
GP-07
4^5
/10X
SOIL
10/13/95
10/13/95
GP-07
10
IX
SOIL
10/13/95
10/13/95
Volatile Organic Compounds (ppm)
I.l.l-Trichloroethane
Trichlorocihene
Toluene •
Teirachloroclhene
31.257
5U
5U
5U
989.50(1 E
42.5
508.50(1 E
25 U
1,282.50
250 U
• 578.45
. • 250 U
46.275
25 U
63.79
- 25 U .
6.728
. 2 U
7.348
2U
5.48
1.036J
. 8.08
2U
0.050 U
0.134
0.050 U
0.050 U
0.025
0.080 E
0.005 U
0.005 U
Sample ID
Sample Interval (feet)
Dilution Factor
Sample Matrix
Sample Dale
Analysis Dale
GP-07
10
2.5 X .
SOIL
10/13/95
10/13/95
GP-08
0-0.5
IX
SOIL
10/13/95
10/13/95
GP-08
•: 8
IX
SOIL
10/13/95
10/13/95
GP-08
8.5-9
IX
SOIL
10/13/95
10/13/95
GP-08
16-18
' IX
SOIL
10/13/95
10/13/95
GP-09
10-12
10 X
SOIL
10/13/95
10/16/95
GP-IO
5-6
10X
SOIL
10/13/95
10/16/95
GP-IO
15.5
5X
SOIL
10/13/95
10/16/95
Volatile Organic Compounds I
ppm)
1,1,1-Trichloroelliane
0.01 25 U
0.005 U
0.008
0.005 U
0.03
0.057
0.054
0.025 U
Trichlorocthenc
0.087
0.022
0.008
0.005 U
0.005 U
0.050 U
0.050 U
0.035
Toluene
0.0125 U
0.005 U
0.043
0.005 U
0.03
0.050 U
0.028 J
0.025 U
Teirachloroclhene
0.0125 U
0.005
0.023
0.005 U
0.0029 J
0.050 U
0.050 U
0.025 U
Notes
J = Outside Linear Working Range (Low) .
E - Outside Linear Working Range (High)
B = Compound Found in Method Blank
11 •= Rclo\^y£lhod Ounntilnlinn Limits
Page 1 of4
(PW2SOIL.XLW|RIR.XLS
-------
Table 4
. Robinicch. Inc. / Naiional Pipe Co. Sile
Vestal. New York
i
ANALYTICAL RESULTS
PW-2 AREA - SOIL SAMPLING
RDWP/RDWPA
Sample ID
Sample Interval (reel)
Dilution Factor
Sample Matrix
Sample Dale .
Analysis Dale
GP-ll
8
1,000 X
SOIL
10/13/95
10/17/95
GP-ll
8 .
, 10,000 X
SOIL
10/13/95 .
10/17/95
GP-16
0-2
IX
SOIL
10/16/95
10/17/95
GP-16
4-6
IX
SOIL .-
10/16/95
10/17/95
GP-17
. 3.5-4
2.5 X
SOIL
10/17/95
10/17/95
Volatile Organic Compounds (ppm)
I.I.I -Trichloroelhane
46.717
50 U
0.005 U
0.01
0.0125 U
Trichloroeihene
5U
50 U
0.005 U
0.009
0.0125 U
Toluene
115.679 E
382.04
0.006
0.005 U
0.0125 U
Tclrachloroclhene
5U
50 U
0.005 U
0.005 U
0.0125 U
j = Outside Linear Working Range (Low)
E = Outside Linear Working Range (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits
Page 3 of4
IPW2SOIL.XLWIRm.XLS
-------
Tnhlc 4
Robiniech. Inc. / National Pipe Co. Site
Vestal. New York
ANALYTICAL RESULTS
PW-2 AREA - SOIL SAMPLING
RDWP / RDWPA
Sample ID
Sample Interval (reel)
Dilution Factor
Sample Matrix
Sample Dale
Analysis Dale
SWB-02
2-4
3.33 X
' SOIL
12/19/94
12/19/94
SWB-ll
1-2
10 X .
SOIL
12/13/94
12/14/94
SWB-ll
6-7
5X
SOIL
12/13/94 .
12/14/94
SWB-ll
11-12
5X
SOIL
12/13/94
12/14/94
SWB-I7
10-12
, 17 X
SOIL
12/15/94
12/16/94
SWB 18A
: 5-7
20X
SOIL
12/15/94
12/24/94
SWB-30
2-4
20 X
SOIL
12/20/94
12/20/94
SWB-30
6-8
10 X
SOIL
12/20/94
12/21/94
SWB-31 ,
5-7
10 X
• SOIL
12/20/94
12/21/94
Volatile Organic Compounds I
1,1,1 -Trichloroelhane
I.l-Dichloroelhane
1,1-Dichloroethene
Chloroform
Telrachloroelhene
Trichloroelhene
Toluene
Vinyl Chloride
ppm) '
0.269 E
0.231
0.026
0.01665 U
0.076
0.01665 U .-
1.892E
0.01665 U
0.050 U
0.050 U
0.050 U
0.050 U
0.050 U
0.050 U
0.050 U
0.050 U
0.025 U
0.025 U
0.025 U
0.025 U.
0.025 U
0.025 U
0.025 U
0.025 U
0.025 U
0.025 U
0..025 U
0.025 U
0.025 U
0.025 U
0.025 U
0.025 U
0.116
0.085 U
0.085 U
0.085 U
0.085 U
0.085 U
2.326 E
0.085 U
0.535
2.342 E
O.IOOU
O.IOOU
0.428
0.468
0.063 J
O.IOOU
0.217
0.163
0.060 J
O.IOOU
0.573
0.699
O.IOOU
O.IOOU
0.148
0.2
0.031 J
0.050 U
0.067
2.556 E
0.050 U
0.050 U
0.050 U
0.131
0.050 U
0.050 U
0.050 U
0.050 U
0.050 U
0.050 U
Notes '
J - Outside Linear Working Range (Low)
E = Outside Linear Working Range (High)
B = Compound Found in Method Blank
U ° Below Method Quantitalion Limits
P.gc4 of4 .
(PW7SOIL.XLW|Rm.XLS
-------
Table . 5
Robimcch, Inc. /National Pipe Co. Site
Vestal, New York
Analytical Results •
Bedrock Groundwater Sampling
RDWPA
Samoie ID
Matrix
SaniDle Date
Analysis Date
MW-3*
WATER
9/26/95
10/5/95
MW-3A
WATER
9/26/95
10/5/95
MW-4
WATER
9/27/95
10/5/95
MW-4A
WATER
9/27/95
10/5/95
MW-4A*
WATER
9/27/95
10/5/95
MW-5
WATER
9/26/95
9/27/95
VOCs (ppb)
Ciloromethane
Bro mo methane
Vinvl Chloride
Chloroethane
Methylene Chloride
Tricfaloro fluoromethane
1.1-Dichloroethene
1 . 1 -Dicoloroethane '
cis-l .2-Dichloroethene
trans- 1 ,2-Dichloroethene
Chloroform
1.2-Dichloroe thane
1.1.1 -Trichloroethane
Carbon TetrachJoride
SromodichJorornethane .
1 ,2-Dichioroorooane
c:s-l .3-DichJoroorooece
Trichloroethene
Dtbromocaloromethane
1 . 1 .2-Trichloroe±ane
trans- 1 ,3-DtchlorooroDeae
Bromofonn
1 . 1 ,2.2-Tetrachloroe'Jiane
7:'.rachloro:theae " .
Chlorobeazsne
1 .3-DichJorobcozsce
!.2-Dichlorobeaz2ce
1 . •l-D ichlorobenzsce
rreca 1 13
<4
• <4
-------
Table ,5-
Robintech, Inc. / National Pipe Co. Site
Vestal, New York .
Analytical Results
Bedrock Groundwater Sampling
RDWPA
SamoJe ID , I MW-5A
Matrix
Sarcole Date
WATER
9/26/95
.Analysis Date I 9/27/95
MWnS
WATER
9/25/95
9/25/95
MW-6A
WATER
9/25/95
9/26/95
MW-13A
WATER
9/27/95
10/3/95
PW-1
WATER
• 9/27/95
10/3/95
PW-4
WATER
12/12/95
12/13/95
VQCs (ppb)
Chloromethane
Bromomethane
VLnvl Chloride
Chloroetbane
<4
<4
<1
- <4
Methvleae Chloride •' < 10
TrichlorofluoromeJhane
l.l-Dichloroetheae
'l.l-Dichlorocthane
c:s-1.2-Dichloroethene
trans- 1 .2-Dichloroetheae
Chloroform
1 ,2-Dichloroethane
1 . 1 . 1 -Trichloroethane
Carbon Tetrachloride
3 romodichloromelhane
1 .2-DtchloroDrooane
c:s- 1 .3-Dichloroorooece
THchloroethese
Dibrorcochlorc methane
1 . 1 .2-Trichloroethane
!rans-l ,3-DichJoroorcoese
Hromofonn
1 . 1 .2.2-Tetrachloroethane
TeJrachloroeiheae •
Chlorobeazeae
t ,3-Dichlorobeazsne
: .2-Dichlorobeazeae
1 .4-DicaIorofaeazsne
Frson 113
<0.5
- <0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
-------
Tables
Robintech, Inc. / National Pipe Co. Site
' Vestal, New York
Analytical Results
Bedrock Groundwater Sampling
RDWPA
Sample ID
Matrix
Sample Date
Analysis Date
PW-5
WATER
9/27/95
10/4/95
PWn6
WATER
9/27/95 '
10/3/95
PW-8
WATER
9/28/95'
10/3/95
PW-9
WATER
9/29/95
10/4/95
PW-10
WATER
9/28/95
10/3/95
VOCs'(ppb)
Chloromethane
Brotnomethane
Vinyl Chloride
Chloroethane
Methylene Chloride
Trichlorofluoromethane
1.1-Dichloroethene
1 . 1-Dichloroethane
cis-1 ,2-Dichloroethene
trans- 1 ,2-Dichloroethene
Chloroform
1.2-Dichloroethane
1.1.1-Trichloroethane
Carbon Tetrachloride
Bromodichloromethaoe •
1 ,2-Dichloropropane
cis-l,3-Dichloropropene
Trichloroethene
Dibromochlorome thane
1 . 1 ,2-Trichloroethane
trans- 1 ,3-Dichloropropene
Bromofonn
1 . 1 ,2.2-Tetrachloroethane
Tetrachloroethene
Chlorobeazene
1 ,3-Dichlorobenzene
1 ,2-Dichlorobenzene
1 ,4-Dichlorobenzene
Freonll3
<4
<4
1.5
: <4 ;
~ <10
<0.5
23
75
8.2
<0.5
<0.5
<0.5
60
• <0.5 .
<0.5
<0.5
<0.5
16
<1
<0.5
<0.5
<1 • "
<1
<0.5
<0.5
<0.5 .
<0.5
<0.5
<2
<4
<4
<1
<4
<10
<0.5
1.9
8.9
<0.5
<0.5
<0.5
<0.5
5.7
<0.5
<0.5
<0.5
<0.5
<0.5
<1
<0.5
<0.5
<1
<1
<0.5
<0.5
,<0.5
<0.5
-------
SUMMARY STATISTICS FOR SITE, BY CHEMICAL AND MEDIUM/AREA
TABLE 6
Num. . Num. - Lowest Highest
• . Times Samples Detected Detected.
Chemical Class Analyte Detected Analyzed Cone.
Volatllee vinyl Chloride
Chloroethane , .
1, 1-Dichloroethene
1, 1-Dlchloroethane
1,2-Dlchloroethene (total)
' .- chloroform . •
1,2-Dichloroethane
1, 1,1-Trlchloroe thane
Trlchloroethene
1,1,2-Trlchloroethane
Benzene '
: . ' Tetrachloroethene
Inorganics Aluminum
•Arsenic ' ' ' ••
Barium .. .
Calcium
Chromium '• • . " "
Cobalt • .
• •" . Copper"
Iron
Lead
• ' Magnesium " ' ••
Manganese ' .
Nickel
Potassium
" • Sodium
Vanadium .
Zinc
2
2
2
4
2
2
.2 •/ ..
5
3
1
3
2
11
1
10
11
2 ' . .
• 1
' 7
11
6
11
11
6
10
11
.1
10
11 .
11
11
11
11
11
11
11
11
11
11
11
11
10
. 11
11
11
11
11
11
10
11
11
11
10
11
11
11
17
: 23
52
.. ' • '3
210
' . . 1
3
'2
31
' ' . 4
. 2
17
466
36
145
49000
• ." 8
40
31
2780
. • " 1
890Q
424
14
542
5740
24
4
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.70 -
.00
.00
.80.
;00
.00
.00
.69
.00
.00
.20-
.00
.00
.00
. 10
Cone.'
34
46
'no
370
400
3
.5
1100
1000
4
23
53
52500
36
1050
1710001
770
I 40
320
101000
29
51200
' 7480
121
14600
99100
24
276
.00
.00
.00.
.00
.00
.00
.00
.00
.00
.00
.00.
.00
.00
.70
.00
.00
.00
.00
.00
.00
.20
.00
.00
.00
.00
.00
.00
.00
t
Oeom. 95 Pet. Min. Max.
Mean Upp. Conf. Detect .. Detect .
Cone. Limit
6
7
4
6
5
2
2
." 10
' 8
2
. 3
3
4487
1
237
156101
'' . -'5
13
37
14442
2
22462
1784
19
2693
26943
4
- 30
.65 ..
.03 ' .
.65 . s
.82 .
.93
.34 .
.71
.87
.71
.61 .
.35 .
.93 .
.61 .
.52
.46
.77 .
.74
:eo . .
.13 .
.31 .
.90
.26 '
.09 .
.49
.25 ' " • .-
.23
.23
.97
Limit
10
10
5
5
5
5
5
5
5
5
5
5
2
43
3
20
14
0
8
6
2
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.
.12
.20
.30
.10
.00
.
.9i
.
.
.90
.
.34
.78
Limit
10.00
10.00
5.00
5.00
5.00
. 5.00
5.00
5.00
5.00
5.00
5.00
5.00
2.30
43.20
: . ' ,
8.80
38.50
17.30
2.60
.
•
17.80
.
.
11.20
2.78
-------
TABLE 6 SUMMARY
. • ..
Chemical Class Analyte
Inorganics • Aluminum
Arsenic • •
: ' Barium .
Calcium . '•-'..
i • . Chromium . !.
Iron • •
Magnesium
Manganese'
MlcJcel , '.
'• . . Potassium
Sodium .
: Thallium
Vanadium
Zinc ' ,.
STATISTICS FOR SITE, BY CHEMICAL ;
YPE-Qround Water ( Filtered) - Overt
Num.
Times
Detected
2
1
8
11
1
. . 8 .
11
10
3
11 ,
11 ~
1
. 1
' fl
Num.
Samples
Analyzed
. 11
11
11
'11.
1 1
11.
11
11
' 11 '
11
11 '
11
'11 :.'
11
Lowest
Detected
Cone.
230.00
20.00
48.00
13000.00
14.00
20.51
2960.00
110.00
15.80
44.00
5370.00
1.37
! 31.30
6.00
VND MEDIUM/AREA
>ur en
Highest
Detected
Cone.
1030.00
20.00
511.00
187000.00.
14.00
1630.00
50900.00
5060.00
23.00
14200.00
95900.00
..-•'• 1.37
31.30
. 180.00
. Qeom.
Mean
Cone.
100.99
1.41
81.74
87757.62
3.74
. 90.51
15073.96
502.72
10.33
1212.25
30950.86
1.17
4.33
21.75
95 Pctv Mln.
Upp. Conf. Detect.
Limit Limit
.' , 138.00
2.12
. ' : 43.20
' * • •
3.30
• 20/50
« .
5.13
8.90
• . . .
. , " . ' •
i:37
' . . 6.34
: . ,2.78
Max.
Detect.
Limit
159.00
2.30
46.00
B
8.80
68.00
.
5.13
17.80
.
/ *
7.80
11.20
34.00
-------
SUMMARY STATISTICS FOR SITE, DY
TABLE 6 :
CHEMICAL AND MEDIUM/AREA ' :
Num.- 'Num. ' Lowoet Highest
Chemical Claaa Aualyte
Volatllea Vinyl Chloride
Chloroethane
Acetone • .
1, 1-Dlchloroethene
'' 1, 1-Dlchloroethane
• 1,2-Dlchloroethene (total)
chloroform
1 , 2-Dlchloroethane
2-Butanone
. 1, 1, 1-Trlchloroethano .
• . Carbon Tetrachlorlde
Trlchloroethene
Benzene • • ' .
Tetrachloroethene
' . Toluene . ' .
Etliylbenzqne '•'•'.
. . • Styrene
. Xylene .(total)
semlvolatllea (BHAa) ble( 2-Ethylhexyl)phthalate
Inorganics • Aluminum ' .
Araonlc
• ' Barium
Cadmium . •' • '
Calcium • '
Chromium
cobalt .
Iron
Lead . ' .
Maunoolum " .
Maiiyaaeuo
Morcury • •
Hlckol
I'oLoeolum ....
Sodium
Zinc
Tlmea
Detected
5.
5
3
S
10
5
.. 1
2
5
8 '
1
7 :'
6 •.
!••''•
11
' 4- '
1
• 8
1 -
. 8 '
5
11
". 3
ll'
1
1 •'•
. 11
3
11
1°..
. ; 2
. 1
11
11
. ?
Samples
Analyzed
15
.15
. 15.
15 -
15
15
15
15 .
15
15
'. 15 '
is; '
.14 . .
15 r
15 '
' • . 15
15 ...
15
12
11
11
11
11
. 11
11
11
•11
' 0
11
11
11
11
11
11
11
Detected
Cone.
4.00
6.00
14.00
23.00
3.00
140.00
4.00 .
-.3.00
21.00
5.00
60.00
4.00
2.00 :
3.00
2.00 •' '
• ' • 2.00
0.00
' ;3.00
. . 97.00
170.00
6.00 .
•59.00. .''
: 5.00
12500.00
•30.00
21.00 '
' 332.00
5.39
7470.00
00.00
0.14
10.20
725.00
10500.00
23.00
Detected
Cone.
'a u.oo
36.. 00
2200.00
150.50
665.00
535.00
4.00
4.00
• 510.00
6950.00
6oioo
' 1350.00
11.00
.3.00
2250.00
' 73.00
6.00
. 460.00
97.00
1290.00
27.35
1360.00
6.00
197000. .00
30/00
21.00
42400.00
10.60
19300.00
1440.00
0.40
10.20
39.400.00
64900.00
1390.00
Oeom.- 95 Pet.
Mtian Upp. Conf.
Cone.. Limit
i •
0.75 . '
6.66
10.76 .
7.46 .
16.40
12.36
3.15
3.19
17.11
34.80
3.77
17.33
3.94 ' .
3.09
29.45
4.35
3.55
. 8.75.
6.40
241.95 .
5.01
254.17. • .
3.05
73761.09 .
2.22 ...
li.37 ' .. .
1540.38 ,
2.73. .
13650.16 < . .
292.18
0.04
. 0..92 . .
2123.73
32945.97
132.59
Mln.
Detoct.
. Limit
10.00
10.00
10.00
5.00
5.00
5.00
5.00
5.00
10.00
.5.00
5.00
5.00
5.00
,5.00
S.OO
5.00
5.00
5.00
10.00
130.00
2.12
,
4.60
*
2.06
20.00
.
0.91
.
14.70
0.03
• 6.90
.
.
2.78
Max.
Dotuct.
Limit
10.00
10.00
50.00
5.00
5.00
5.00
25.00
25.00
50,00
5.00
- 25.00
S.OO
25.00
25.00
5.00
25.00
. 25.00
25.00
10.00
130.00
6.00
.
5.00
.
.43.00
38.50
.
5.00
.
14.70 '
0. 10
17.80
.
m
2.70
-------
SUMMARY STATISTICS FOR SITE, BY CHEMICAL AND MEDIUM/AREA '
TABLE 6 .. . • .
m\/np_/*iB«.iinj-liii»*»>M»*/ot1^AUA.lt n A ,rl M** ««1* '
. Num. • . '• Num.- Lowest Highest
Chemical Class Analyto
Inorganics ' Arsenic
Barium
Calcium •
Iron . .
: Magnesium
< Manganese
Potassium.
Sodium
Zinc' . .
• Times Samples •' Detected
Detected Analyzed . Cone.
1 ; ' ' , 8.90
•-.-.' • 121.00
11000.00
•/ 630.00 .
: 7500.00
60.00
1030.00
• ; . 8200.00
1 --( "5.00
Detected'
Cone.
e;9o
1270.00
78000.00
630.00
15700.00
430.00
35900.00
58400.00
5.00
Ooom. 95 Pqt . •
Mean Upp. Conf.
. Cone. . Limit
i:eo
- 513.15 .
39951.52
: 38.54 . •
10003.03 ' .
90.58
. 4605.01 •
30599.21 . .
1.97
Mln.
.Detect .
Limit
2.12
. .
.
20.10
.•
14.70
,
.
2.78
Max.
Detect .
Limit
2.12
.
.
60.00
.
14.70
t
.
3.10
-------
_...,,„ , SUMMARY STATISTICS FOR SITE, DY CHEMICAL AND MEDIUM/AREA
1 AHI.r. 6 ' .
Num. Num. ' "Lowest •
Times •• Samples Detected
Chemical Class Analyto . . • ' Detected Analyzed
Volatllos Chloroothane
Muthylene Chloride
• Acetone
1, 1-Dlchloroethane
1, 2-Dichloroethene (total)
chloroform
1, 1, 1-Trlchloroe thane
Trlchloroethene
Tetrachloroethene
Toluene • _
Xyluue (total)
Semlvolatllea (DNAa) Naplithalene
2-Methylnaphthalene
. Phenanthruiie
Anthracene ' .
Ul-n-butylphthalate
- Fluoranthene
Pyrene
Denzo( a) anthracene
Chryeone
bls( 2-Ethylhexyl)phthalate
• Donzo(b) fluot anthene , •
Oenzot Ic) I luoranthene ,
Benzol a)pyrene
Inorganics Aluminum
Arsenic
Ilarliiin
I'uilinlum
Calcium ' •
Cobalt '
Copper
Iron '
Load
Magnesium . /
Nangaiiouo
1 '
9
10
6 ' •
3
2
5
5 . :
2
5 ' .
3
1.
2 .
1 •
1 ' .
7
1 .
2
2
2
15
1
•'•• 1
- 2
27
5
20
7.
27 '
1
23
27 ,
.27 •
27
27 .
27
27
27
27
27 .
27
27
27
27
27 ;
27
27
27
27 .
27
27 .
27
27
27
27
26
'27
27
27
27
27
27
27
27
27 '
27
27
27
27
27
Cone.
56
15
12
. 5
2
7
.5
2
3
2
2
130
150
1600
260
98
•950
120
. 75
86
64
470
540
100
4650
2
23
1
129
27
11
10300
0
650
• 114
.00
.00
.00
.00
.00
.00
.00 '
.00
.00
.00
.00
.00
.00
.00 •
.00
.00
.00 .
.00
.00
.00
.00
.00
.00 .
.00.
.00
.07
.60
.23
.00
.10
.60
.00
.24
.00
'.00
Highest
Detected
Cone.
58.00
53.00
. . 81.00
. 49.00
22.00
8.00
. 630.00
. 16.00
4.00
27.00
8.00
130.00
300.00
.1600.00
280.00
2100.00
; 950.00
. 2200.00
840.00.
950.00
18000.00
470.00
540.00.
630.00
142000.00
.13.00
137.. 50
' 18.30
21839.00
27.10
43.30
•' 34300.00
12000.00
5100.00
002.00
Oeora. 95 J>ct .
Mean Upp. Cont .
Cone .
6.54
6.61
. 12.73.
4.17'
3.46
3.31
4.25
3.28
3.08
3.60
.3.22
264.39
272.84
286.33
. 269.13
290.23
281.59
285.86
271.09
273.71
849.29
274.34
. 275.76
271.09
9652.01
1.72
23.27
0.91
2046.62
2.54
12.92
16027.39
09,65
2287.25
347.03
Limit
9
23
28
8
5
4
14
4
3
5
4
361
366
441
362
476
401
458
404
407
6787
374
378
387
15453
6
60
2
6983
3
25
20749
94920
2944
405
.30
.32
.72
.72
.13
.10
.65
.33
.63
.52
.05
.45
.68
.06
.89
.76
.72
.47
.53
.84
.33
.07
.34"
.11
.06
.64
.94
.34
.04
.42
.24
.49
.02
.55
.41
Mln.
Detect.
Limit
10
5
10
5
5
5
5
5
,• . 5
5
5
• 330
.330
330
330
340
330
330
330
330
360
330
330
330
1
9
0
' . 4
3
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.
.25
.55
.43
.
.15
.00
.
.
•
Max.
Dutoct.
Limit
' 53.00
110.00
210.00
6.00
26.00
26.00.
6.00
26.00
26.00
26.00
26.00
1700.00
1700.00
1700.00
1700.00
1700.00
1700 .00
1700.00
1700.00
1700.00
9000.00
1700.00
1700.00
1700.00
.
67.50
'10.30
1.60
.
• 6.30
29.70
.
.
.
•
-------
TABIE 6 SUMMARY STATISTICS FO
Chemical Class Analyta
Morcury
Nickel
Potassium •
. Selenium
.Silver
Sodium
'Vanadium
Zinc
Cyanide
Hum. •
Times
.Detected
. 26
24
27 .
. ,2
9
'27
S
27
•
R SITE, BY CHEMICAL, A
-Subsurface (Contlnu
'Num. . ', Lowest
' Samples
Analyzed
27
27
27
27.
27
-27 .
27
. 27 •
27
Detected
Cone.
0.02
3.70
2.71
-.0.44
0.09
.39.20
15.50
2.50
0.11
ND MEDIUM/AREA
lll&heat
Detected
. • Cone.
.5.70
66.30 •
1 '400. 00
0.73
.-4.80.
449.00
38.70
' 120.70
• 0.11
Oeom.
Mean
Cone.
0.31
13.79
512.92
0.33
0.37
120.50
5.93
46.97
0.31
95 Pet.
Upp. Conf.
Limit
4.41.
40.12
1954.15
• 0.52
2.14
177.65
9.45
76.81
0.71
Mln.
Detect .
Limit
0.11
.3.92
.
' 0.42-
0.07
.
5.40
: 0.05
Max.
Detect .
Limit
0.11
4.33
.
2.37
1.06
.
, 12.50
1 .60
-------
I
o
m
o
in
TADLE 7 UODINTECll/NATIONAL 1'IlTi CO., INC. SITE: SUMMARY OF EXPOSURE PATHWAYS
'nlhway
Tiiiic-l;r.iine Evaluated
Receptor > I'rcscnl Future
Degree of
Assessment
Qii.inl. Qu.il. Rationnlc for Selection
or Exclusion
Grpundwatcr: * " '
ngestion of Unfillered Ground Water
From Bedrock & Overburden
Aquifers)
nhalation of Ground Water
Contaminants During Showers
Inhalation of Ground
Water Contaminants
During Baths .
Dermal Contact with Ground
Water Contaminants During •
Showers/Oaths
Inhalation of Contaminants
that Volatilize from Ground water
and Seep in Basements
Dermal Contact with Onsite
Production Well Water
Inhalation of Volatilized
Contaminants from Production
Well Water
spiii - - '-;-", - ;
Dermal Contact With Onsile Soils
Surface Soils
Subsurface Soils
Ingeslion of Onsile Soils
Surface Soils
Subsuifacc Soils
L
Small Child Resident No Yes .
Adult Resident . No Yes
Axlull Resident No Yes
Small Child Resident No No.
Adult Resident No No
Small Child Resident
.Local Resident . No No
Onsite Worker . . No No
Onsile Worker No No
<•-!••.-' - 't-
Trespasser No "'• Yes
Gxcavation/Ulilily Worker Yes ' Yes
Trespasser • No Yes
Excavation/Utility Woikcr Yes Yes
X Residents currently obtain
X drinking water from public
drinking' water supply;
Assumes residents obtain
drinking water from local well
in (he future.
X ' ' , Assumes residents obtain
water from local wells in the
future; several volaliles
. '• present in ground water.
Volatilization not as great
as showering because less
aeration and lower temperature
Exposures assumed to be
insignificant in relation
to other ground water
pathways. v
. • Ground water table is shallow; but
low avg VOC cone. & westerly flow
'. • preclude significant exposure.
Data inadequate for assessment.
Data inadequate for assessment.
-
.X Assumes complete pavement
removal in the future;
. X Excavation or routine maintenance of
buried utilities may be necessary.
X Assumes complete pavement
reinov.nl in ilic future; l;xcay:iliuu or
X . routine cii.iinlcnnncc of buried
utilities may be necessary.
Ifl
-------
3J
m
o
o
K
o
m
TADLD 7 SUMMARY OF EXPOSURD PATI IWAYS -continued
Pathway
Soils cont. • - . -: ; •
Inhalation of Fugitive Soil
Emissions
Dermal Contact with Soils
West of Drainage Ditch '
(Skate Estate Property)
Ingestion of Soils
West of Drainage Ditch
(Skate Estate Property)
Se)dinIqtiy\A * $£-M «
Dermal Contact with
Sediments in Drainage Ditches .
Incidental Ingeslion of
Sediments in Drainage Ditches
SUriacl^WliiB^J4-^'^^;^'^ Y .
Dermal Contact With Surface
Water in Drainage Ditches .> •
Ingestion of Surface Water
in Drainage Ditches
Manhole and.
Settling Tank
Exposures
AlrV* -\ ^;'ii>K^dVv- '* '-'
Inhalation of Contaminants
in Air
Time-Frame Evaluated
Receptor Present Future
•• . . •• -
Onsile Worker , No No
Trespasser • . • '
Youth Residents Yes Yes
Youth Residents - Yes Yes
- .' - • -
&'>>~?\ *' t •> *s »s " * " $ " < '" *
Trespassera . • Yes . • . Yes
Youth Residents •
Trespassera Yes Yes
Youth Residents
*•'•><<< '%>£<>! 1 > > ' >>,'*»
Trespassers • No. : No
Local Residents . . v
. Trespassera No : No
Local Residents
Utility/Maintenance . • ' .No • No
Worker
" ^:'^&.\y-'l'- ",~';'-{ ' ' *''',, ' ' -«V«" . •
Local Resident No No
Trespasser . . .
Woiker'
Degree of , •
Quant. Qual. Rationale fur Selection
or Bxclusion
• • • Releases expected to be
insignificant.
X . Soils adjacent to drainage
. . . ditch are currently accessible
to Skate Estate users!
X Soils adjacent to drainage
: ditch are currently accessible
to Skate Estate usen.'
'7-V^-n*^V'V&!';l.'•• '",."
Unable to assess because of limited
and inconclusive sampling data;
•• sampling results may not be
representative of site sources.
-------
q
tit
u
Tl
in
U)
TABLE 8
TOXICITY VALUCS FOR ALL CONTAMINANTS DGTUCTUn ATI! 1C noniNTGCI! INC/NATIONAL PII'R CO.'SITU
DRAl.
FACTOR
INUAIATION
SUira FACTOR
DCftMAL
a-ora
FACTOR (o)
OKALRPD
INIIAIAT1OH
urn
PIWMAL
Rfl)(o)
ADV)SOHY(i)
lUMI.'UI
ADVlSORY(i)
'
In
sm
Actloiu .
IJciucru
IliumodlcJitufomcihini
7.90B42
IJOUOI
290R02
1 JOB 01
361B02
I 631101
I.63P.OI
Oiloiubcnlcni
Qilonxihin*
Oilorumcihuw
xllum (I.1-)
IJOU02 b
1.40002 b
9.101242
400GOI
«JOBO) b
llOflOJ ,
1.201! (00
I.62B-02
6.72D02
7.50BOI
lihylbcniuie
l>tchlococlliylui< '
Vln»l C3ilo|00
30nli(OI
V I.()OI!(PI
20011.01
20011)00
200HiOl'
7.001101
260l!iOO
4nnl:(OU
lOUIllM
7U1I: (00
SlKlliiOO
I.IXJIliOl
5001:02
IOOH(U2
-------
m
in
n
in
o
T)
•D
in
UJ
TABLE 8
TOXICITY VALUES FOU ALL CONTAMINANTS DGTUCTCn ATTIIG HOniNTDCII JNC./NAT10NAL1MPG CO. SHU (continued)
OOKTAt-flHANIS
Of CONCERN
ORAL
a am
FACTOR
IN1IAI.A110N
FACTOR (o) •
ORAI.RFO
INIIAIATION
RID
1 DAY
iU!Ai:m
lUtAI.IU
AUVISUHY (i)
(ingfl)
Ikiuo(b)nuonnihonnihldMtra(2-)
ll.plitiiitcnt
Hxrunthitni
Pyre 04
Aluujnura
Antimony
Antnla
Uayllluai
CiJmluiB
Ctlclum
;. Chropjluai
'cii.ii
Copptr
CytntJ*
Ltij"""''""
KUgncilum
Ktin|iA«M
I.IJCtOI c,U
' I.ISU.OI t
I.DUiOl c
'.'" "v" "ijioisibij"'.'**
, "-,J
i.ooo or
' 4 oon 01
I.?4C<00
"""'"""i'.jo'iiio'i"
'> A * > * A M f.
4000-01 I
4000-0) b,«
4000-01 •
100R42
4.000-04
I 001! 01 b
JOflllOl
I.UOD01 (
A<> ,- JOOB.O) |
. • .. h
2.000-02
^Miii^iiiili
i * i
loonoi
IOOIi-02
'.0}
9 OOP. 04 •
5001104
1.001! 04
SOOR04;:'
20011 41
i.onp.o}
5001! 01
' I 501! 01
jonfiioo .
iiiniiioi
4.00U01'
noc.oo I
200001.
20011.00
*»Sii5.Si8SS.':>
I SOI: ill
2U)l!iO|
20UI'.bl
; $ 000 01 J
1001! 01
-------
Ill
i'I
o
6
5
TJ
in
•ji
TABLE 8
VAI.UCS I-OU AI J, CONTAMINANTS DRTlJCn-l) ATTIIR honiNTCCli INC./NATIONAL PII'B CO, SITR (conllnueil)
COtfrAMINAmS
IV CONCI»N
"'"Nickel""'"""1 '"' "'""*>
Stlenhim
Silver
Viiudlua
: *:- 2 J nc : :: \ : '. :: .'. :'S"i ! ''V ; y? :- ^ :'•' -I ^ ?'>' :'^.: a.'
OMAI.
anm .
IMCIOR
W.M.*.
••:s^B~i:FJ
?fn?!.'!,^;a
. _
•::.V":"-"^;:::T^;?;«^v
INITIATION
a/impACitiK
(^1-a.iH
•••«^*»*^*^=
.^:i^:-Sf^:i^:i;
•'
.. ': •
'•?$£%**$$%&'?$:
,
. ORAI.RPO •
(.^^1.,)
•*' "iooh'o7 ;'i
t^>^&
JOOCO)
1.00E 01 b
i^Ti^/JOOC^l'nbl
t
INHAIATIOM
' . . ' RID
•-.(^•Wirt
««««lfSRI!C;>t:!-ft;T:V,
^..•^^.^.to.'i^-y*
' • •• ,'
. • .. .
ntmiAi.
, «n)(o)
(••MUr)
' '."•' i.ooi'.pi:
.K;;-;:;.:M;,;;.
. JOUB04
.
-;:1-' "^••jooii oi ^
(DAY
ni!Ai:ni
AD VISOR Y(»)
(01g/1)
"'. IOOD.OO
"
loonoi
• /
•«i:': :-K: -..-« •'
HJiicniaiM
iii!Ai:ui.
ADVISORY (i)
.(^1)
2oono)
. iooaui
loon 01
1 ,.
0
im
U.S. l:l'A.llulihUlccliAulM(lll!ASI')>llou11iQ>un>r. FY 1990. &|*cml»f. .••'.. '" . •
PI r PI' A galilincf, Uu buuc(iX>rnno «lop« (idar l« UM«| u i «yn>|U< (or oili« I'AI U *<«n lufnclinl ivliknci of c«iclna|cnlch|r t>l«u, u tlulgruut J In III1S or I IliAST.
IKHXIh»bhlUtecuA»iuiittMfurrulyrkttltwtreinUktiyMiiiipilon;fllO o/SOl! 04 It iKbllarw»iircoruum{>ilon.
Note DnliuoitxrwlMlnJIcjud, til a*u«fifrooi IRIS. '•• . r . .
HacivtllibUoriKKpcovlilBlb«cbr)-l>unllri>k(it|Au.incleO-li7Vk|i l/20cu.m/di)r I l/IO-3m|Aif. ' .. • ' • •
•pi S. lil-A. Rltk Awumini Ouldine* for Suf«i(nnd Vol.1 llumin Ikilih livihuiloo Mtmul (P«n AXp.7-11. ePA/S40/l-l9/aOZ Dw.1919)
Ifcrmtl tailclly vtlu<» wir« derived dura cxil loilclly viluti by ipplylnf in •biarplloa Itacr.
vulillluOlO ' ' .
tcnilvol. 0.10 . . . • . .
tnenlcOOO • . '
oilier luaif. 0.10 • '
(per •|t
-------
3-
in
o
5
TJ
9
TABLE 8
TOXICITY VALUGS FOR ALL CONTAMINANTS DETECTED AT 1110 ROniNTGCII INC./NATIONAL PIPE CO. SI'IT! (continued)
(rt
(q)
Dermal R(D» were cilculilcd uiln| lh« cqtullon: RfO i ibuxpllon («doc
([•PA.IM9. Rlik AucumcM QaUnnct lot Sujxtfund Vol.I Human llcnllh Ovohnllon M.iniul (I'ml A) P.P.VS-(0/I-89A)0:. Interim Flniil.Dai.IVSU.)
Oral
-------
TABLE 9 SUMMARY OF CARCINOGENIC RISK ESTIMATES
. FOR THE ROBINTECH SITE
Scenario
Receptor
Current/
Future
Incremental
Risk
Ground Water (overburden)
Ingestion . . • •
Volatiles Inhalation While Showering
Ground Water (bedrock)
Ingestion •.'
Volatiles Inhalation While Showering
•» .
Surface Soils . :
Ingesrion - On Site
Dermal Contact - On Site . . .
"Ingesdon - Skate Estate. ••" . •
Dermal Contact - Skate Estate
Subsurface Soils
Ingestion - On Site . • •
Dermal Contact - On Site
.Sediment — -
Ingestion - On Site , .
Dermal Contact - On Site
Ingestion - Off Site, Downgradient
Dermal Contact - Off Site, Downgradient
Resident
Resident
Resident
Resident
Trespasser
Trespasser
Youth •
Youth
Worker
Worker
Trespasser
Trespasser
Youth
Youth
F
F
F
F
.F .-.
F
OF
OF
OF
OF
C/F
C/F'
CVF
OF
3.8 x 10'3**
1.0 x 1CT3**
4.1 x 10'3**
1.4 x 10°**
1.2x 10'5
1.7 x 10:'
1.4 x 1Q-7
2.5 x 10'*
4.3 xlO'7
1.1 x 10'7
3.4 xlO'7
2.8 x iO'*
2.8 x lO'7
.1.7 x 10-*
**
Exceeds 104 risk.
ALLIANCE
'•c-roojes Corooruen
-------
TABLE 10 SUMMARY OF NONCARCINOGENIC HAZARD INDICES (ffl) FOR THE
ROBINTECH SITE '
Scenario
Ground Water (overburden)
Ingestion
Volatiles Inhalation While Showering •
Ground Water (bedrock)
Ingestion
Volatiles Inhalation While Showering .
Surface Soils . -..'.'
Ingestion - On Site . .
Dermal Contact - On Site
Ingestion - Skate Estate
Dermal Contact - Skate Estate
Subsurface Soils
Ingestion - On Site
Dermal Contact - On Site
Sediment
Ingestion - On Site .
Dermal Contact - On Site
Ingestion - Off Site, Downstream
Dermal Contact - Off Site, Downstream
Current/ Acute
Receptor Future HI
f
' .Resident
Resident
Resident
Resident -
Trespasser
Trespasser
Youth
Youth
Worker
Worker
Trespasser
Trespasser
Youth
Youth
F
F
F.
F
F
F
C/F
OF
OF
OF
C/F.
OF
OF
OF
3.5 x IQ-'Ca
8.0 x 10-1(c
N/A
2.7 x lO-'Ca
6.3 x KT'Cc
N/A
. 1.0 x 10'1
6.1 x 10'2
. 1.1 x 10'3
1.4 x 10'3
1.2 x 10'3 .
5.5 x 10*
6.4 x 10a
3.8 x 10"*
3.4 x 10a
2.0 x ID"4
Chronic .
HI
-' . •'"
i) 1.3 x 10'(a)*
:) 3.0 x 10l(c)*
1.0 x 10-l(a)
L) 1.4x lO'te)'".
:) 3.3 x 10l(c)*
5.4 x lO-'(a)
\
7.8 x 10'2
5.5 x 10'1
2.0 x 10°
4.4 x 10'2
5.4 x 10-4
: 1.5 xlO'3
. S.lxlO'3'
3.7 x 10'2
: 1.3 x 10'3
9.3 x 10'3
(a) - adult
(c) - child
* HI exceeds one (1).
A ALLIANCE
^•crroo^a Cor canon
-------
Table 11 '.
Robintech, Inc. /National Pipe Co. Site
•Vestal, NY
EPA and. New : York. Scate
.Contaminant Limits
Compound
EPA (ppb) | New York State (ppb)
1,1,1 - Trichloroethane
Trichloroechene
Toluene ••
Vinyl Chloride
1,1 - Dichloro«hene
1,1 - Dichloroethane ' .
1,2 - DicWoroethene (tocaJ)
Tecrachloroe±ene " • .
Benzene ' • .
Chloroediane
Carbon Te:rachloride . .
Ediylbenzene •
Styrene. / • • • . .
Xylene (total)
200'
5
. 1,000
. • 2.
. 7 •
>
70 -
' 5'--"
5 •
-
' • 5 '
700
100
10,000
• ' . •?
• 5
• -...- '5
5
•••'...' 5
• 5- .-• •
' "- . 5 "
.'.5
• .. •' 5 • '
. " 5 .
5 ' • '. •
5
• . • .5
•' - 5 •
Mote ••• . ; . . . ' • .'V; . -. .
Table reproduced from EPA-approved Remedial Design'Workplan.
-------
TAA« 12
il cttonc ofcioctlvw
VolitUe Oifonic ContMinenti
inioie Acid
luunent
-jrson Bisulfide
irbon Tttrtcfttoride
Morebensene
thono •
i ; 3 -0 1 di 1 oroboraon*
.:.l-0»rtftion coefficient It aUwiotort b* Mine in* f.itwinf equKion:
'•«l8e * •*•« >•• * * 3.64, *oro 1 it MiwBilUy
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APPENDIX III
ADMINISTRATIVE
RECORD INDEX
-------
26/27/97 Index Document Minber Order Page: 1
ROBINTECH INC./NATIONAL PIPE CO. SITE Documents
Doc'jnent Number: ROB-001-0001 To C007 Date: 09/20/85
Title: (Letter describing a sice reconnaissance and initial sampling effort at the Robintech site
in Vestal, Mew York)
Type: CORRESPONDENCE
Author: Ranney, Colleen A.: Camp Dresser i McJCee (COM)
Recipient: Leong, Sui: US EPA
Document Nunber: R08-001-0008 To 0083 Date: 09/01/84
Title: Preliminary Investigation of the Robintech Site, Toun of Vestal, Broone County, New York,
Phase I, Sumnary Report
Type: REPORT
Author: none: Ecological Analysts • '
Recipient: none: NY Dept of Environmental Conservation .
Oocunent Nunber: R08-001-0084 To 0111 Date: 08/01/89
Title: Work/Quality Assurance Project Plan - Remedial Investigation - Robintech, Inc./National Pipe
Company, Vestal, Hew York - Revised
Type: PLAJI
Author: Barker, Frances 8.: Fred C. Hart Associates
Recipient: none: US EPA
Oocunent Nunber: R08-001-0112 To 0293 . Data: 03/18/88
Title: Revised Project Operations Plan for the Remedial Investigation of the Robintech, Inc./National
Pipe Co., Site
.Type: PUU
Author: none: Fred C. Hart Auoclatea
Recipient: none: none
-------
0(5/27/97 . Index Document Nunber Order Page: 2
KOStNTECH INC./NATIONAL PIPE CO. SITE Oocunents
Ooc-iient Muaiber: R08-001-0294 To 0294 Date: 02/10/87
Title: (Letter forwarding the attached Work Plan for the Robinteeh, Inc./National Pipe Co. site.
Vestal, New York)
Type: CORRESPONDENCE
Author: Ranney, Colleen A.: Camp Dresser t MOCee (COM)
Recipient: Alvi, N. Shaheer: US EPA .
Attached: ROB-001-0295
Document Nunber: ROfl-001-0295 To 0507 Parent: ROB-001-0294 Date: 10/10/87
*
Title: Work Plan for the Remedial Investigation/Feasibility Study of the Robinteeh, Inc./National
Pipe Co., Site, Vestal, Neu York
Type: PLAN
Author: none: Caop Dresser I McKee (COM)
Recipient: none: US EPA
Oocunent Nuxbar: ROB-001-0508 To 0763 Date: 09/23/91
Title: Draft Remedial Investigation Report - Robinteeh, Inc./National Pipe Co. Site, 3421 Old Vestal
Road, Vestal, Neu York
Type: REPORT
Condition: DRAFT
Author: none: McLaren/Hart Environmental Engineering Corporation
Recipient: none: Buffton Corporation
Attached: 808-001-0764 R08-001-0982 R08-001-1SU ROB-001-1841
Oocunent Nufcer: ROB-001-0764 To 0981 Parent: 808-001-05(38 . Date: 04/19/91
Title: Draft Remedial Investigation Report.. Volume I: Appendix A-0, F-l, and K, Robinteeh, Inc./National
.Pipe Co. Site .
Type: REPORT
Condition: DRAFT
Author: none: McLaren/Hart Environmental Engineering Corporation
Recipient: none: Buffton Corporation
-------
:6/27/97 Index Document Umber Order Page: 3
R08INTECH INC./NATIONAL PIPE CO. SITE Documents
Number: ROS-001-0982 To 1513 Parent: ROB-001-0508 Date: 09/23/91
Title: Draft Remedial Investigation Report. Volume II: Appendix E, Robintech, Inc./National Pipe
Co. Site
Type: REPORT
Condition: DRAFT
Author: none: McLaren/Hart Environmental Engineering Corporation
Recipient: none: Buffton Corporation
Document Number: R08-001-15U To 1840 Parent: R08-001-0508 Date: 04/19/91
Title: Draft Remedial Investigation Report, Volune III: Appendix J, Robintech, Inc./National Pipe
Co. Site
Type: REPORT
Condition: DRAFT
Author: none: NcLaren/Harr Environmental Engineering Corporation
Recipient: none: Buffton Corporation
Oocunent Mutter: R08-001-1841 To 2179 Parent: ROB-001-0508 Date: 04/19/91
Title: Draft Remedial Investigation Report, Voluae IV: Appendix L-R, Robintech, Inc./National Pipe
Co. Site
Type: REPORT
Condition: DRAFT
Author: none: McLaren/Hart Envfronmental Engineering Corporation
Recipient: none: Buffton Corporation
Oocunent Nunber: R08-002-0001 To 0290 Date: 12/03/91
Title: Draft Feasibility Study Uport - Robintech, Inc./National Pipe Company Site. Vestal, Nm York
Type: REPORT .
Condition: DRAFT
Author: none: McLaren/Hart Environmental Engineering Corporation
Recipient: none: none
-------
.i/27/97
Index Document Nunber Order
RQBINTECH INC./NATIONAL PIPE CO. SITE Documents
Page:
ic-jnent Nunber: ROB-002-0291 To 0291
Date: 01/25/91
icle: (Letter forwarding the attached Feasibility Study Work Plan for the Robintech site. Vestal,
New York)
Type: CORRESPONDENCE
Author: Barber*, Michael: McLaren Hart Environmental Engineering
.eeipient: Granger, Mark: US EPA
Utaehed: ROB-002-0292
:ocument Number: R08-002-0292 To 0305
Parent: R08-002-0291
Date: 01/01/91
Title:^feasibility Study Work Plan, Robintech, Inc./National Pipe Co. Site, 3421 Old Vestal Road,
Vestal, New York
Type:. PLAN
Author: none: McLaren Hart Environmental Engineering
eeipient: none: US EPA
)ocunent Munber: ROB-002-03Q6 To 0318 Date: 02/01/92
I
Title: Superfund Proposed Plan - Robintech, Inc./National Pipe Co. Site, Vestal, New York
Type: PLAN
Author: none: US EPA
.eeipient: none: none
Jocunerit Nunber: ROB-002-0319 To 0340
ritle:.Adainistrative Order on Consent
Type: LEGAL DOCUMENT
Author: Daggett, Christopher J.: US EPA
Recipient: none: various PRPs
Date: 10/08/87
lacunent NuBfcer: ROB-002-0341 To 0341
Date: 07/18/89
Title: (MeaoranduB forwarding the enclosed Preliminary Health Assessment for the Robintech site.
Vestal, New York)
Type*: .CORRESPONDENCE
Author: Nelson, Ulllia* 0.: Agency for Toxic Substances * Disease Registry' (ATSDR)
Recipient: Kaplan, Dick: US EPA . '
Attached: ROB-002-0342
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:&/27/97 Index Document Number Order ' Page: 5
ROSINTECH INC./NATIONAL PIPE CO. SITE Documents
Dccunent Nunber: ROB-002-0342 To 0351 Parent: ROB-002-0341 Date: 06/30/89
Title: Preliminary Health Assessment for Robintech Site, CERCL1S Ho. NYD0022329S7, Broone County,
Vestal, NT
f
Type: PLAN
Author: none: Agency for Toxic Substances * Disease Registry (ATSOR)
Recipient: none: none
Document Nutter: ROS-002-0352 To 0746 . Date: 02/10/92
Title: Risk Assessment - Robintech, Inc./National Pipe Co. Site, Vestal, New York - Revision No.
1
Type: PLAN
Author: Fratt, David: Alliance Technologies Corporation
Recipient: Granger, Mark: US EPA
document NuBber: R08-002-0747 To 0747 ' Ditei 02/21/92
Title: (Public Notice:) The United States Environmental Protection Agency Invites Public Consent
on the Proposed Remedial Alternative for the Robintech Superfund Site, Vestal, Broone County,'
New rork . -
Type: CORRESPONDENCE
Author: none: US EPA
Recipient: none: Press * Sun Bulletin ,
Document Number: ROB-002-0748 To 0748 Date: 02/20/92
Title: (Letter stating that the New York State Department of Environmental Conservation and the New
York State Department of Health concur with the groundwater remedy for the February 18, 1992,
revision of the Superfund Proposed Plan)
Type: CORRESPONDENCE
Author: O'Toole, Michael J.: NY Oept of Environmental Conservation
Recipient: Callahen, Kathleen C.: US EPA
-------
06/27/97 Index Oocunent Nuaber Order Page: 6
ROB 111 TECH INC./NATIONAL PIPE CO. SITE Docunents
3oc-jnent Nunfcer: RC8-002-0749 To 0811 Date: 03/18/92
Title: (Transcript of "a Public Hearing) In the Hatter of Robintech, Inc. Superfund Site
Type: LEGAL DOCUMENT
Author: Holler, Dawn T.: Czerenda Court Reporting, Inc.
Recipient:
Document Nunber: R08-002-0812 To 0899 Date: 03/31/92
Title: Declaration for Record of Decision (for the Robintech Inc./National Pipe Co. site. Vestal,
New York)
Type: LEGAL DOCUMENT
Author: Sidaaon-Eristoff, C.: US EPA
Recipient: none: none - -
Jocuaent Muter: R08-002-0900 To 09U . Date: 04/01/97
Title: Superfund Proposed Plan, Robintech, Inc./National Pipe Co. Site, Town of Vestal, Neu York «
Type: PLAN
Author: none: US EPA
Recipient:
Jocunent Nunber: RCB-002-0915 To 1570 Date: / /
Title: Revised Remedial Design Work Plan, Robintech Inc./National Pipe Co. Superfund Site. Vestal,
Neu York
Type: PLAN
Autltbr: none: McLaren/Hart Environmental Engineering Corporation
Recipient: none: US EPA
:ocunent Nunber: R09-002-1571 To 1664 Date: / /
•itle: Remedial Design Work Plan Addendum, Robintech Inc./National Pipe Co. Superfund Site, Vestal,
New York '
Type* PLAN
Author: none: McLaren/Hart Environmental Engineering Corporation
Recipient: none: US EPA
-------
06/27/97 Index Document Nuober Ord«r Pag*: 7
ROBIMTECH INC./NATIONAL PIPE CO. SITE Doooents
Ooeunent Nu*er: ROB-002-1667 To 1878 Date: 08/01/96
Title: VoluM I of II, Draft Remedial Design Investigation Report I Evaluation of Remedial Alternatives
Type: REPORT
Condition: DRAFT
Author: none: Hclaren/Hart Environmental Engineering Corporation
Recipient: none: US EPA
-------
APPENDIX IV
STATE LETTER OF
CONCURRENCE
-------
NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
50 Wolf Road, Albany, New York 12233-7010
JUN 26 I997
John P. Cahfl]
Commissioner
Mr. Richard Caspe
Director
Emergency & Remedial Response Division
U.S. Environmental Protection Agency
Region II
290 Broadway - 19th Floor
New York, New York 10007 .
Dear Mr. Caspe:
Re: Robmtech Site, Broome County, N.Y., Site No. 7-04-002
The New York State Department of Environmental Conservation (NYSDEC) and New York
State Department of Health (NYSDOH) have reviewed the Record of Decision dated June 1997
for the above-referenced site. The preferred remedy consists of the excavation of and treatment
of saturated and unsaturated soils in the PW-2 and Paved Pipe Staging Areas. The contaminated
soil will be treated by low temperature thermal desorption and backfilled Groundwater entering
the excavations will be pumped into holding tanks and treated, if necessary. The existing
production well network will continue to extract contaminated groundwater from the bedrock
aquifer. The remedy will include a long term groundwater monitoring program and a
contingency plan related to the extraction of contaminated bedrock groundwater.
The NYSDEC and NYSDOH concur with the preferred remedy listed in the Proposed Plan. In
you. have any questions, please contact Robert W. Schick, of my staff, at (518) 457-4343.
Sincerely,
Director
Division of Environmental Remediation
cc: J. Singennan, USEPA
M. Granger, USEPA
A. Carlson, NYSDOH
-------
APPENDIX V
RESPONSIVENESS
SUMMARY
-------
RESPONSIVENESS SUMMARY
FOR THE
ROBINTECH, INC./NATIONAL PIPE CO. SUPERFUND SITE
TOWN OF VESTAL, NEW YORK
INTRODUCTION
This Responsiveness Summary provides a summary of citizens' comments and concerns
received during the public comment period related to the Remedial Design Investigation
Report (RDIR) and Proposed Plan for the Robintech, Inc./National Pipe Co. Site (the "Site")
and the U.S. Environmental Protection Agency's (EPA's) and the New York State
Department of Environmental Conservation's (NYSDEC's) responses to those comments
and concerns. All comments summarized in this document have been considered in EPA's
and NYSDEC's final decision in the selection of a remedial alternative to address the
contamination at the Site.
SUMMARY OF COMMUNITY RELATIONS ACTIVITIES
The August 1996 RDIR, which describes the nature and extent of the contamination at and
emanating from the Site and evaluates remedial alternatives.to address this contamination,
and the April 1997 Proposed Plan, which identified EPA's and NYSDEC's preferred
remedy and the basis for that preference, were made available to the public in both the
Administrative Record 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. Notices of availability of these documents
were published in the Binghamton Press & Sun Bulletin on April 25, 1997. A public
comment period was held from April 25 through May 25,1997 to provide interested parties
with the opportunity to comment on the RDIR and Proposed Plan. A public meeting was
held on May 14, 1997 at the Vestal Public Library in Vestal, New York to inform local
officials and interested citizens about the Superfund process, to review planned remedial
activities at the Site, to discuss and receive comments on the Proposed Plan, and to
respond to questions from area residents and other interested parties. Approximately 20
people, consisting of local businessmen, residents, representatives of the media, and state
and local government officials, attended the public meeting.
OVERVIEW
The public, generally, supports the preferred remedy, which includes, among other things,
the excavation and treatment of the contaminated unsaturated and saturated soils in two
areas of the Site and the extraction of contaminated groundwater from the bedrock aquifer
through the existing production well network.
-------
The public's concerns, which relate to Site contaminants, treatment alternatives, the Site
investigation, alternative selection, drinking water contamination, and shallow groundwater
contamination, are summarized below.
SUMMARY OF COMMENTS AND RESPONSES FROM THE PUBLIC
MEETING CONCERNING THE ROBINTECH, INC./NATIONAL PIPE CO.
SUPERFUND SITE
The following summarizes the verbal comments that were received at the May 14, 1997
public meeting. -
Site Contaminants
Comment #1: A representative from the Vestal Conservation Advisory Commission
expressed concern related to the lead concentrations in the soil at the Site. The
commenter also asked what concentration of lead is permitted in soil.
Response #1: EPA has established a residential soil screening level of 400 ppm lead in
soil. As lead concentrations in soils exceed 400 ppm, there is increasing concern with
elevated blood levels in children (based on a six-year childhood exposure duration). Soil
lead concentrations less than 400 ppm have a negligible effect on blood lead levels.
Elevated lead concentrations reported for samples collected during the remedial
investigation (Rl) were determined to be due to laboratory error. This determination was
based upon available split sampling data and on EPA's resampling of all locations where
elevated concentrations had been found. The results of samples collected during the
resampling effort showed that lead concentrations were below the criterion (most
concentrations were below 100 ppm). In March 1993, EPA issued a Record gf Decision
indicating that no action was required to address bn-site soils for lead.
Comment #2: A question was raised concerning the proposed remedy's ability to remove
bis-2-ethylhexyl phthalate (BEHP) from the soil and water, since BEHP has a low volatility.
Concern was also expressed by the commenter that BEHP was not identified as a
constituent that presented a risk at the Site. Another commenter asked whether the most
recent samples collected at the Site were analyzed for BEHP.
Response #2: While BEHP was evaluated as a contaminant of concern in the risk
assessment conducted for the Site, it was determined to pose negligible risk based on
factors such as concentration and frequency of detection. Also, BEHP is unlikely to travel
in the groundwater and has not been detected in the groundwater downgradient of the Site.
V-2
-------
Samples collected as part of the RD investigation were not analyzed for BEHP, since
extensive sampling for BEHP was conducted during the Rl and the risk assessment
concluded that BEHP did not pose a risk at the Site.
Treatment Alternatives
Comment #3: A representative from the Broome County Environmental Management
Counsel asked whether the groundwater that will be pumped in order to excavate soil
below the groundwater table would be treated.
Response #3: Under Alternative 3, groundwater entering the excavation would be
pumped into mobile holding tanks for testing and treatment, if necessary, prior to disposal.
Comment #4: A question was asked concerning the treatment of metals in the soil treated
using low temperature thermal desorption (LTTD).
Response #4: LTTD is an effective means of treating organic contaminants in soils, not
inorganic contaminants (i.e., metals). To ensure that only soils that are within the
protective limits are backfilled, treated soils will be subjected to the Toxicity Characteristic
Leaching Procedure testing. Soils that pass the test will be used as backfill. Soils that fail
the test would either require additional on-site treatment prior to backfilling or would be
treated or disposed of at an approved off-site facility, as appropriate.
Site Investigation
Comment #5 : A commenter asked about the methods of sample collection and analysis.
Response #5: Sampling was performed using temporary well points installed with a
geoprobe unit. A mobile laboratory, equipped with a gas chromatograph-mass
spectrometer, was used for the analysis of the samples. All samples were analyzed in
accordance with EPA protocols.
Comment #6 : A commenter asked whether samples from the overburden included the fill
in the vicinity of the building or only native materials.
Response #6: Fill and native overburden materials were sampled for volatile organic
compounds (VOCs).
V-3
-------
Comment#7 : A commenter asked whether the production wells were acting as conduits
for contamination to migrate downward from the overburden aquifer to the bedrock aquifer.
The commenter also asked whether any plumes were observed in the vicinity of the
production wells.
Response #7: Based on the results of the Rl, it appears that the only production well
which was acting as a conduit was Production Well No. 2 (PW-2). (Apparently, the conduit
was created when the unsealed casing of the production well was installed through the
overburden formation into the upper level of bedrock.) Since significant levels of soil and
groundwater contamination are present in the vicinity of PW-2, to prevent further migration
of contamination, EPA authorized Buffton to replace this well with a new, properly sealed
production well, followed by the sealing and abandonment of PW-2. This work was
completed in December 1996, effectively eliminating this groundwater migration pathway.
Low levels of groundwater contamination have been observed in the production wells at
the facility. However, since no Site-related contamination was detected in downgradient
monitoring wells, it appears that the constant pumping of the production wells is controlling
the migration of groundwater contamination.
SUMMARY OF WRITTEN COMMENTS AND RESPONSES
CONCERNING THE ROBINTECH, INC./NATIONAL PIPE CO.
SUPERFUND SITE
The following summarizes the written comments received by EPA during the public
comment period.
Comments from the Buffton Corporation. Correspondence of 5/23/97
Alternative Selection
Comment #8: EPA should specify in the ROD that the preferred alternative, Alternative
3, and the expenditure of an additional $1 million required to perform Alternative 3, as
compared to Alternative 2, will result in a more expeditious deletion of the Site from the
National Priorities List (NPL) and a more expeditious return of the Site to a marketable
condition than would Alternative 2.
! «
Response #8: EPA determined that Alternative 3 was preferable to Alternative 2 when
weighed against all of the evaluation criteria. Although the timing issue was not
specifically considered by EPA, removing a greater volume of heavily contaminated soil
should lead to a more expeditious remediation of the Site. This should result in the ability
to delete the site from the NPL sooner than would be expected under Alternative 2.
V-4
-------
Comment #9: The ROD should address the change in understanding of the Site since the
signing of the 1992 ROD (in particular, the pumping and treatment of the groundwater and
the need for a remedy for the Northeastern Site Boundary Area).
Response #9: The findings of the RI/FS ultimately led to the selection of pumping and
treatment of the contaminated aquifers in the Northeastern Site Boundary Area, Paved
Pipe Staging Area, and PW-2 Area in the 1992 ROD. The results of the RD investigation,
however, identified the presence of a relatively low permeability overburden formation with
extremely low groundwater yield. Therefore, the extraction of contaminated groundwater
from the overburden formation was determined not to be feasible.
The results of the Rl identified low-level concentrations of trichloroethene (TCE) in
overburden groundwater samples near the Northeastern Site Boundary Area. Upgradient
groundwater samples collected during the RD investigation, however, exhibited higher
concentrations of TCE than were detected at this portion of the Site, indicating the
probability of an off-site source of TCE contamination. NYSDEC is currently overseeing
an investigation related to this potential off-site source of contamination. As a result, this
area is not currently being considered for remediation by EPA. Remediation of this area
may be considered in the future based upon the results of the ongoing investigation of the
potential off-site source, or upon the results of any long-term monitoring conducted at the
Site.
Comment #10: EPA should expedite its selection of the remedy and the issuance of a
ROD so that Buffton will be able to commence Site work this summer.
Response #10: The implementation of the selected remedy is contingent upon not only
the issuance of the ROD but the amendment of the existing Unilateral Administrative Order
or the execution of a Consent Decree for the RD/remedial action (RA) and the timely
submission of the necessary work plans, design documents, and reports for conducting the
RD and RA.
Comment #11: There is an absence of a complete soil exposure pathway under either
current or reasonably anticipated future land-use scenarios and, according to the Proposed
Plan, "no current or future overburden groundwater exposure is possible because the
overburden aquifer is not usable." Further, CERCLA moderates its emphasis on
permanent solutions and treatment through the addition of the qualifier "to the maximum
extent practicable" and contains a requirement for remedies to be cost-effective.
Therefore, the findings of the Proposed Plan, when considered in the context of the
requirements of CERCLA, raise questions as to whether CERCLA requires the selection
of Alternative 3 over Alternative 2.
V-5
-------
Response #11: Although there is no subsurface soil exposure pathway under current- and
future-use scenarios, the severely contaminated overburden soils constitute a
demonstrably unacceptable threat to the groundwater, as they are a source of
contamination to the usable bedrock aquifer. While risk reduction in the form of continued
bedrock groundwater extraction and the elimination of the PW-2 conduit may improve this
situation, it does not take into consideration the unknown nature of the transport of
severely contaminated overburden groundwater to the usable bedrock aquifer below.
The Proposed Plan statement that "no current or future overburden groundwater exposure
is possible because the overburden aquifer is not usable" is made as an explanation as to
why it is not necessary in this circumstance to apply federal Maximum Contaminant Levels
(MCLs) to the restoration of that aquifer. Section §300.430(a)(1)(iii)(F) of the NCP clearly
states that "when restoration of groundwater to beneficial uses is not practicable, EPA
expects to prevent further migration of the plume, prevent exposure to the contaminated
groundwater, and evaluate further risk reduction." Addressing the uncontrolled spread of
contamination in the overburden groundwater was a part of the rationale behind selecting
Alternative 3.
Regarding EPA's preference for permanent solutions and treatment to the maximum extent
practicable, Alternative 3 is well within the requirements of CERCLA and the NCP,
including the preference for treatment as a principal element and utilizing permanent
solutions. Regarding cost-effectiveness, cost was considered in evaluating all of the
alternatives against the nine criteria, as required by the NCP. The selected remedy,
Alternative 3, is cost-effective, even though its costs are greater than Alternative 2.
Drinking Water Contamination
Comment #12: The primary risk identified in the baseline risk assessment was the
potential risk associated with the future use of the bedrock groundwater as a source of
drinking water. This risk was evaluated using the conservative assumptions and posits a
hypothetical worst-case scenario. There are, however, two significant Site-related factors
that should be considered—the pumping of the production wells at the Site has curtailed
the migration of bedrock groundwater contamination and there is no indication that
contaminated bedrock groundwater is causing drinking water contamination. Thus, there
is no documented risk to human health from the Site bedrock groundwater.
Response #12: In accordance with the NCP, the basis for taking action at a site is a result
of current and future risk. While there is not a current risk to human health from the
bedrock groundwater, the risk assessment concluded that there was an unacceptable
.potential for future risk.
V-6
-------
The fact that it appears likely that the pumping of the production wells at the Site have
curtailed the migration of bedrock groundwater contamination has been weighed carefully
in EPA's remedy selection. That is, the remedy requires the continued extraction of
bedrock groundwater, regardless of the status of the pipe-production facility, until such time
as cleanup goals have been attained. The rationale for this element of the remedy is
based primarily on the continued protection of human health and the environment and on
the restoration and protection of groundwater resources. See Section 300.430(a)(1)(iii)(F)
of the NCR, which states that EPA expects to return usable groundwaters to their beneficial
uses wherever practicable. As previously stated, the bedrock aquifer at the Site is a usable
aquifer.
Shallow Groundwater Contamination
Comment #13: EPA has identified contamination in a small area of groundwater "much
closer to the ground surface" of the PW-2 Area. Although acknowledging that the source
of this groundwater is unknown, EPA has suggested that the groundwater may be related
to plant operations and that any plant-related sources of water to the overburden aquifer
need to be eliminated in order to mitigate contaminant mobility in this area. Even if the
source of this groundwater once was, in some way, related to plant operations, it is highly
unlikely that the condition or situation resulting in the contaminated groundwater still exists.
The RD investigation did not reveal that the shallow groundwater in the PW-2 Area was
naturally connected to the bedrock aquifer. Rather, the casing in PW-2 was determined
to be a conduit of water to the bedrock aquifer from the shallow fractures. Buffton's recent
abandonment and installation of a new PW-2 and the performance of the ROD remedy
should address any significant concerns that EPA may have about groundwater migration
in the PW-2 Area. Accordingly, under these circumstances, further investigation of the
source of the surface groundwater appears unwarranted. At most, the need for an
investigation of the source of the surface groundwater in the PW-2 Area might be
reevaluated at some time in the future after the remedy has had a chance to work.
Response #13: While the source of the shallow water is unknown, it appears unlikely that
it is simply perched water from natural sources. Much of the piping from the extraction-well
network runs through the severely-contaminated source area near PW-2 and other plant-
related piping may run through this area, as well. Given this situation, a plant-related
source of water appears likely. The fact that the shallow groundwater corresponds with the
PW-2 source area has potentially significant consequences in terms of contaminant
mobility in the overburden aquifer. An overburden groundwater plume of 1,1,1-
trichloroethane and other VOCs extends south to the far side of the adjacent Skate Estate
property. Unlike the Paved Pipe Staging Area plume, the PW-2/Skate Estate plume is not
bounded by nondetectable sampling results or locations where insufficient water was
available for sampling. Therefore, there is potential for still further migration.
V-7
-------
While EPA agrees that the recent abandonment and installation of a new PW-2, and the
performance of the remedy, should address EPA's primary concerns about groundwater
downward migration in the PW-2 Area, this effort does not address the lateral spread of
contamination in the overburden. Extraneous sources of water in the overburden should
be eliminated in order for the natural attenuation element of the selected remedy to be the
most effective, particularly, in stemming the spread of contamination downgradient of the
Site.
As such, further investigation of the source of this water appears consistent with the fourth
remedial action objective (i.e., reduce or eliminate the potential for off-site migration of
contaminants) which EPA believes is a relatively easily implemented and low-cost
endeavor. >
V-8
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APPENDIX V-a
RESPONSIVENESS SUMMARY
LETTER SUBMITTED DURING THE PUBLIC COMMENT PERIOD
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BUFFTON CORPORATION
12'* i):::ic. -venue. Suite SOI • Fnn Wiirh. Texus *f>IO*-l-.!) • ••-<','i 5^-r'M • Fax N<> ujl") jT'-'HlO
May 23. 1997
Via Federal Express
Mr. Mark Granger'
Project Manager
U.S. Environmental Protection Agency •
290 Broadway, 20th Floor
New-York, NY 10007-1866 ;
Re: Comments on Superfiind Proposed Plan for Robintech. Inc. /National Pipe
Company. Superfiind Site. Vestal. New York
Dear Mr. Granger: ' •
Bufnon Corporation (Bufflon), the current owner of the Robintech Inc./National Pipe Co.
Superfund Site (the Site), submits these comments on the remedial plan dated April 1997 that the
Environmental Protection Agency (EPA) has proposed for the Site. (Proposed Plan).
At the outset, Bufflon wants to make clear that its comments are not intended to challenge
the overall approach of the Proposed Plan. For a number of years, Bufflon has urged EPA to
correct the remedy for the Site and the Record of Decision (ROD) that EPA approved on March
30, 1992. We are pleased that EPA has now proposed the corrections that Buffton has
suggested. The Site has been on the Superfiind National Priorities List (NPL) since 1986, and
Buffton is ready, willing, and able to conduct the cleanup.1 Thus, Buffton's objectives for the Site
are as follows; namely to
• avoid any delay in the selection, design, and implementation of a remedy for the Site;
• proceed as expeditiously as possible to install the Site remedy, and
• perform an appropriate cleanup so that the Site may be deleted from the NPL and its
Superfund liability resolved, both as soon as possible.
The Proposed Plan is an important step in enabling Bufflon to fulfill these objectives.
Nevertheless, despite our general support for the overall approach that EPA has outlined, there
are several conclusions that EPA appears to have reached, about which Bufflon offers comment
or clarification. Each of these conclusions is discussed below.
EPA recsruly permitted Bufflon to begin Site work with the replacement of PW-2.
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1. Alternative 3 - Saturated Overburden Soil Excavation and Treatment
EPA's preferred remedy, Alternative 3, requires the excavation and treatment of an
estimated additional 2,000 cubic yards of saturated VOC-contaminated soil from the overburden
in the PW-2 and the Paved Pipe Staging Areas and removal and treatment of contaminated
overburden groundwater entering the excavation. Alternative 3 is projected to cost nearly $1
million more, or an additional 30 percent, than Alternative 22, which Buffion supported.
Although Alternative 3 goes further than CERCLA requires3, it fixes the problems with the
previous remedy. Accordingly, Buffion is willing to go forward with Alternative 3, at substantial
additional expense, with the following understandings:
a) EPA will specif)' in the amended ROD that Alternative 3 and the expenditure of the
additional SI million required to perform Alternative 3 will result in a more expeditious deletion of the
Site from the NPL and return the Site to a marketable condition, than would Alternative 2.
b) The amended ROD that EPA issues will address the problems in the 1992 ROD,
including the pump and treat groundwater remedy and the remedy for the Northeastern Site
Boundary Area.
c) EPA will expedite its selection of the remedy and the issuance of an amended
ROD, so that Buffton will be able to commence site work this Summer.
2. Risk of Drinking Water Contamination
The primary risk4 identified in the Baseline Risk Assessment that EPA conducted was the
potential risk associated with the future use of the bedrock groundwater as a source of drinking
Alternative 2 and Alternative 3 are identical \vith the exception that Alternative 2 does not require
excavation and treatment of saturated overburden soils and related groundwater.
1 The Proposed Plan indicates that there is little or no natural connection between the overburden aquifer
and the bedrock aquifer. It notes that the overburden formation is of "relatively low permeability" with "extremely
low groundwater yield" (page 6) and that the overburden formation limits the migration of dissolved organic
constituents to overburden groundwater. (page 8) The Proposed Plan reiterates the conclusion reached in the 1991
risk assessment that risks due to VOC's in subsurface soils need not be examined because of the absence of a
complete exposure pathway under either current or reasonably anticipated future land use scenarios and no current
or future overburden groundwater exposure is possible because the overburden aquifer is not usable, (page 12).
Further CERCLA moderates its emphasis on permanent solutions and treatment through the addition of the
qualifier "to the maximum extent practicable" and contains a requirement for remedies to be cost-effective. See
"The Role of Cost in the Superfund Remedy Selection Process". Publication 9200.3-23FS (September, 19%). page
2. EPA's "Superfund Administrative Reforms Annual Report Fiscal Year 1996" cites as an accomplishment that
all stakeholders involved in the Superfund process fully understand the important role of cost in remedy selection.
Page 4 of 8. Thus, the findings of the Proposed Plan, when considered in the context of the requirements of
CERCLA, raise questions as to whether CERCLA requires selection of Alternative 3 over Alternative 2.
EPA also identified a potential risk associated with the inhalation of VOC's if the groundwater were
used for showering, under a future use scenario. There is virtually no likelihood that the groundwater will be used
for showering and so we do not discuss that here.
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water. This risk was evaluated, as acknowledged by EPA, using the conservative assumptions
that an individual will consume a minimum of two liters of contaminated groundwater daily and
that the concentration of contaminants in the groundwater will be equal to the highest
'concentrations of contaminants that ever were detected in the groundwater at the Site. Although
Bufflon does not intend to minimize the need to protect the public from drinking contaminated
groundwater, that is not-the situation here. The risk assessment admittedly posits a hypothetical
worst case scenario that bears little or no relationship to reality. Thus, on this issue, there are two
significant site-related factors to consider: 1) the pumping of the production wells at the Site has
curtailed the migration of bedrock groundwater contamination and 2) the Proposed Plan does not
suggest that bedrock groundwater from the Site is entering the drinking water supply and causing
drinking water contamination, (page 4). Thus, there is no cited documented risk to human health
from the Site bedrock groundwater.
3. PW-2 Surface Groundwater Source Investigation
EPA has identified contamination in a small area of groundwater "much closer to the
ground surface" of the PW-2 area, (page 2). Although acknowledging that the source of this
groundwater is unknown, EPA has suggested that the groundwater may be related to plant
operations and that any plant-related sources of water to the overburden aquifer need to be
eliminated in order to mitigate contaminant mobility in'this area, (page 14). Even if the source of
this groundwater once was, in some way, related to plant operations, it is highly unlikely that the
condition or situation resulting in the contaminated groundwater still exists. EPA has confirmed
that the surface water effluent discharge, i.e.. water discharged from the plant after plant use, has
met State Pollutant Discharge Elimination System standards since 1984. The remedial design
investigation did not reveal that the shallow groundwater in the PW-2 area was naturally
connected to the bedrock aquifer. Rather the casing in PW-2 was determined to be a conduit of
water to the bedrock aquifer from the shallow fractures. Buffton's recent abandonment and
installation of a new PW-2, and the performance of the remedy, should address any significant
•concerns that EPA may have about groundwater migration in the PW-2 area. Accordingly, under
these circumstances, further investigation of the source of the surface groundwater appears
unwarranted. At most, the need for an investigation of the source of the surface groundwater in
the PW-2 area might be reevaluated at some time in the future after the remedy has had a* Chance
to work.
Bufflon would be pleased to meet with'EPA at the earliest appropriate time to discuss
these comments. We encourage EPA to resolve these issues expeditiously so that Buffton can
begin the work at hand. We appreciate the opportunity to provide these comments.
Sincerely,
Robert Korman
Vice President & Chief Financial Officer
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RECORD OF DECISION FACT SHEET
EPA REGION II
Site
Site name:
Site location:
MRS score:
Listed on the NPL:
EPA ID #
Record of Decision
Date signed:
Oprable Unit:
Selected remedy:
Capital cost:
Construction Completion:
O & M cost:
Present-worth cost
(10 year):
Lead
Primary Contact:
Secondary Contact:
Main PRPs
Waste
Waste type:
Waste origin:
Contaminated medium:
Robintech, Inc./National Pipe Company Site
Vestal, New York
30.63
6/1/86
NYD002232957
7/25/97
OU-3
Hot spot overburden soil excavation with treatment by low-
temperature thermal desorption; continued extraction of bedrock
groundwater
$2.1 million
1999
$115,000
$3.0 million
Site is PRP lead - EPA is the lead agency
Mark Granger, Remedial Project Manager, (212) 637-3955
Joel Singerman, Chief, Central New York Remediation Section,
(212)637-4258
BFX (formerly Buffton Corporation)
VOCs
Hazardous waste
Soil and groundwater
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