Robintech Inc./ National Pipe Co. EPA ID: NYD002232957 OU 03 Town of Vestal NY


                                    EPA/ROD/R02-97/056
                                    1997
EPA Superfund
     Record of Decision:
     ROBINTECH, INC./NATIONAL PIPE CO.
     EPA ID: NYD002232957
     OU03
     TOWN OF VESTAL, NY
     07/25/1997

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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 with the reguirements 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 that 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 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 aguifer 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 aguifer 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.

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•      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 guality 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.

      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 freguency 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 guality.

•      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 reguirements 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 reguirements (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.

Because this remedy will result in contaminants remaining on-site above health-based limits until the
contaminant levels in the aguifer 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 adeguate protection
to human health and the environment.

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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

                              TABIiE  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 	   12

COMPARATIVE ANALYSIS OF ALTERNATIVES 	   17

DESCRIPTION OF THE SELECTED REMEDY 	   24

STATUTORY DETERMINATIONS  	   27

DOCUMENTATION OF SIGNIFICANT CHANGES 	   30

     ATTACHMENTS

     APPENDIX I    FIGURES
     APPENDIX II   TABLES
     APPENDIX III  ADMINISTRATIVE RECORD INDEX
     APPENDIX IV   STATE LETTER  OF CONCURRENCE
     APPENDIX V    RESPONSIVENESS SUMMARY

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SITE 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 Susguehanna 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 Susguehanna River. Consistent with
this, EPA field observations and examination of topographic contours indicate that the superficial
(overland) flow of surface water across the Site is to the west, controlled by a series of conduits and
drainage ditches which direct the flow to the river, located approximately a half mile to the north and
west.

The area has two distinct aguifers which are sources of drinking water. The upper aguifer 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 aguifer unit 6-20 feet below the ground surface. The lower
aguifer 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.

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 aguifer, but has been removed from operation, also due to low yield. The eight
remaining wells derive water from fractures in the shale bedrock aguifer. These wells discharge into a

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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.

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. (a
successor of Robintech),  Buffton, Buffton Electronics  (now named Electro-Mech, Inc.), and National Pipe
Company.  General Indicator Group, Inc. subseguently 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 EPA 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.  Conseguently,  a no action ROD was signed for the second operable unit
in March 1993.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The RI 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 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 guestions 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.  Conseguently, it became necessary to consider reevaluating 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 aguifer, 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

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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 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 aguifer, The movement of groundwater in the bedrock aguifer 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 Susguehanna River.

Groundwater in the bedrock aguifer 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 RI, 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 RI identified elevated concentrations of trichloroethene (TCE) (54 micrograms per liter [Ig/1]) 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 RI showed
concentrations of 1,1,1-trichloroethane (TCA) up to 760 Ig/1. No other VOCs were detected in this area.

The majority of contamination was found in the PW-2 Area. Groundwater samples collected during the RI
contained TCA concentrations up to 1,100 Ig/1 in the overburden and up to 8,800 Ig/1 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 RI data, along with the attendant risk assessment and FS, ultimately led to the selection of pumping
and treatment of the contaminated overburden and bedrock aguifers 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.

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Northeastern Site Boundary Area Investigation

The results of the RI 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 Ig/1.
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 Ig/1), 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 Ig/1 in the overburden
groundwater in the vicinity of the entrance to the gravel lot area (as compared to 760 Ig/1 found during
the RI) and exceeding 6,000 Ig/11 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 Ig/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
Ig/1) and other VOCs in the overburden of the PW-2 Area. Concentrations up to 1,100 Ig/1 were detected
during the RI.

The data also revealed that subsurface soils in the area are contaminated with TCA (concentrations up to
2,800,000 Ig/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.

While the data collected during the RI 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
RI.

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

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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 RI. 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 RI, 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 such as toxicity, frequency of occurrence, and 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 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
j_ _ j. _ ._ _ _ .,_ _ _ j. ._

Potential carcinogenic risks were evaluated using the cancer slope factors developed by EPA for
the

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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 10 -6(i.e., a one-in-ten-thousand to a one-in-a-million excess cancer risk) and a
maximum health Hazard Index (HI)(which reflects noncarcinogenic effects for a human receptor) egual 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 egual or greater risks.

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. Conseguently, 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 aguifer 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 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

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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 processes, including chemical degradation, dilution, and dispersion) and
production well pumping to address the contaminated groundwater in the overburden and bedrock aguifers,
respectively.

This alternative would, however, include a long-term groundwater monitoring program. Under the monitoring
program, water guality 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).

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.

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Under this alternative, intrinsic remediation would address the contamination in the overburden groundwater
in downgradient areas. Water guality 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, freguency, 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 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 monitoring, 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 guality 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
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

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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
groundwater, 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 reguirements, 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
       adeguate 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 reguirements of other federal and state environmental statutes and    reguirements
       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 reguired 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
       implementation 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.

•      Cost includes estimated capital and operation and maintenance costs,  and net present-worth costs.

•      State 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 contaminants would occur.  Alternative 1 would rely solely on intrinsic

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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 aguifers, 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 reguire
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
reguirements, 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 aguifer, thereby reducing and minimizing the downgradient migration of
contaminants within that aguifer, 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 aguifer.

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 aguifer into the bedrock aguifer and would lead to the cleanup of the
bedrock aguifer 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 aguifer within a reasonable
time frame. Under Alternatives 2, 3, and 4, institutional controls would limit the 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 aguifer, 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 aguifer as no current or future overburden
groundwater exposure is possible because that aguifer 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 aguifer 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 aguifer.  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 reguirements would be met for the overburden groundwater
treated under Alternatives 3(groundwater entering the excavation and pumped into mobile holding tanks) and

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4 (groundwater from the dual-phase extraction system).  For all of the alternatives, it is anticipated that
surface water discharge reguirements 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 reguirements, including air emission standards.

Long-Term Effectiveness and Permanence

With regard to the overburden aguifer, 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 aguifer being remediated and is expected to prevent the downward migration of contaminants
from the overburden aguifer into the bedrock aguifer.

All of the alternatives, including No Action, would be effective with regard to the bedrock aguifer, since
they all include the extraction of contaminated bedrock groundwater until such time as MCLs 6re
achieved.

Sludges and residuals from the treatment processes for Alternatives 2, 3, and 4 would be collected and
disposed of off-site.

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 aguifer 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 soils 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 aguifer 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

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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 contaminants 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 guantities of treatment byproducts that
would have to be handled by on site workers and removed off-site for treatment/disposal.

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 eguipment.

It is estimated that Alternative 1 would reguire one month to implement, since developing a long-term
groundwater monitoring program would be the only activity reguired. 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 aguifer, 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 reguire 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 reguired 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 reguire readily available
materials and services. Effecting institutional controls until groundwater guality has been restored under
Alternatives 2, 3, and 4 can be readily implemented.

Cost

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 Capital Operation and Present-Worth
No. Cost Maintenance Cost Cost
1 $0 $114,125 $935,870
2 $1,171,584 $114,125 $2,107,454
3 $2,101,054 $114,125 $3,036,924
4 $967,998 $218,818 $2,504,884

As can be seen by the cost estimates, Alternative 1 (No Action) is the least costly remedy with a

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present-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.

State 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 SEIiECTED 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:

• 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 aguifer 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 aguifer (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 guality has been restored.

• Development of a contingency plan 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 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 freguency and location of groundwater monitoring will be determined during
the RD stage. Monitoring will include a network of groundwater monitoring wells (including the

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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 aguifer
into the bedrock aguifer), intrinsic remediation of the overburden aguifer, 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 guickly, or as guickly, 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 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(cl)(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's 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

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

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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 aguifer.

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.

-------
                                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

SRC 970560
SRC 97056D>
SRC 97056E>
SRC 97056F>
SRC 97056G>
SRC 97056H>
SRC 97056I>

-------
                             APPENDIX II
                                TABIiES
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

-------
                                                  Table 1
Sample ID
Dilution Factor
Sample Matrix
Sample Interval  (feet)
Sample Date
Analysis Date

Volitale Organic Compounds  (ppm)

1,1,1-Trichlorethane
Trichloroethene
Toluene
Tetrachloroethene

Sample ID
Dilution Factor
Sample Matrix
Sample Interval  (feet)
Sample Date
Analysis Date

Volatile Organic Compounds  (ppm)

1,1,1-Trichloroethane
Trichloroethene
Toluene
Tetrachloroethene
                                  Robintech, Inc./National Pipe Co. Site
                                              Vestal, New York

                                             ANALYTICAL RESULTS
                                  PAVED PIPE STAGING AREA - SOIL SAMPLING
                                                 RDWP/RDWPA
GP-01
1 X
SOIL
5-7
10/11/95
10/12/95
0.023
0.005 U
0.005 U
0.500 U
GP-15
50 X
SOIL
8.5-9
10/16/95
10/17/95
0.584
0.025 U
0.025 U
0.025 U
GP-01
10 X
SOIL
9-10
10/11/95
10/13/95
0.189
0.005 U
0.005 U
0.500 U
GP-19
1 X
SOIL
0-4
10/17/95
10/17/95
0.048
0.011
0.048
0.005 U
GP-02
1 X
SOIL
6-7
10/12/95
10/12/95
0.005 U
0.021
0.005 U
0.500 U
GP-19
5 X
SOIL
10-12
10/17/95
10/17/95
0.078
0.025 U
0.025 U
0.025 U
GP-13
100 X
SOIL
6-6.5
10/16/95
10/16/95
1.138
0.005 U
0.005 U
0.500 U
GP-20
2 X
SOIL
3-4
10/17/95
10/17/95
0.074
0.010 U
0.010 U
0.010 U
GP-13
100 X
SOIL
6.5-7
10/16/95
10/16/95
1.135
0.005 U
0.005 U
0.500 U
GP-20
10 X
SOIL
6-7
10/17/95
10/17/95
0.225
0.050 U
0.050 U
0.050 U
GP-13
200 X
SOIL
10.5-11
10/16/95
10/16/95
6.876
1.000 U
1.000 U
1.000 U
GP-21
1 X
SOIL
0-1
10/17/95
10/17/95
0.024
0.005 U
0.005 U
0.005 U
GP-13
200 X
SOIL
12.5-13
10/16/95
10/16/95
4.231
1.000 U
1.000 U
1.000 U
GP-23
1 X
SOIL
7-8
10/17/95
10/18/95
0.023
0.005 U
.0025 U
0.005 U
GP-14
2 X
SOIL
7-8
10/16/95
10/16/95
0.027
0.010 U
0.010 U
0.010 U
GP-23
5 X
SOIL
10-12
10/17/95
10/18/95
0.153
0.025 U
0.025 U
0.025 U
GP-15
100 X
SOIL
5-7
10/16/95
10/16/95
2.927
0.005 U
0.005 U
0.005 U
GP-24
1 X
SOIL
4-4.5
10/18/95
10/18/95
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 Quantitation Limits
NA = Not Analyzed

-------
                                                  Table 1
Sample ID
Dilution Factor
Sample Matrix
Sample Interval  (feet)
Sample Date
Analysis Date

Volitale Organic Compounds  (ppm)

1,1,1-Trichlorethane
Trichloroethene
Toluene
Tetrachloroethene

Sample ID
Dilution Factor
Sample Matrix
Sample Interval  (feet)
Sample Date
Analysis Date

Volatile Organic Compounds  (ppm)

1,1,1-Trichloroethane
Trichloroethene
Toluene
Tetrachloroethene
                                  Robintech, Inc./National Pipe Co. Site
                                              Vestal, New York

                                             ANALYTICAL RESULTS
                                  PAVED PIPE STAGING AREA - SOIL SAMPLING
                                                 RDWP/RDWPA
GP-24
5 X
SOIL
12-14
10/18/95
10/18/95
0.046
0.025 U
0.025 U
0.025 U
PPA-28
5 X
SOIL
0-2
12/14/94
12/20/94
0.025 U
NA
NA
NA
GP-25
2.5 X
SOIL
0-4
10/18/95
10/18/95
0.0125 U
0.0125 U
0.0125 U
0.0125 U
PPA-31
5 X
SOIL
6-8
12/14/94
12/15/94
0.0748
NA
NA
NA
GP-25
2 X
SOIL
11.5-12
10/18/95
10/18/95
0.16
0.010 U
0.010 U
0.010 U
PPA-32
5 X
SOIL
0-2
12/14/94
12/15/94
0.025 U
NA
NA
NA
OW-06 PPA-06 PPA-06 PPA-06
IX 10 X 10 X 10 X
SOIL SOIL SOIL SOIL
8-9 1.5-2.0 2.5-3.0 3.0-3.5
10/12/95 12/9/94 12/9/94 12/9/94
10/16/95 12/9/94 12/9/94 12/9/94
0.048 0.050 U 0.050 U 0.107
0.025 U NA NA NA
0.025 U NA NA NA
0.025 U NA NA NA
PPA-44
10 X
SOIL
4-6
12/21/94
12/21/94
0.1497
NA
NA
NA
PPA-15 PPA-15
1 X 12.5 X
SOIL SOIL
1-3 3-5
12/8/94 12/8/94
12/8/94 12/8/94
.109 E 0.501
NA NA
NA 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 Quantitation Limits
NA = Not Analyzed

-------
                                                  Table 2

                                  Robintech, Inc./National Pipe Co.  Site
                                              Vestal, New York

                                             ANALYTICAL RESULTS
                              PAVED PIPE STAGING AREA - GROUNDWATER  SAMPLES
                                                    RDWP
Sample ID
Dilution Factor
Sample Matrix
Sample Interval  (feet)
Sample Date
Analysis Date

1,1,1-Trichlorethane  (ppb)

Sample ID
Dilution Factor
Sample Matrix
Sample Interval  (feet)
Sample Date
Analysis Date

1,1,1-Trichloroethane  (ppb)
PPA-01
1 X
WATER
8-9
12/6/94
12/6/94
60
PPA-09
-
DRY
11-12
12/7/94
-
PPA-02
50 X
WATER
8-9
12/6/94
12/6/94
4,471
PPA-10
20 X
WATER
11-12
12/7/94
12/7/94
PPA-03
10 X
WATER
7.5-8.5
12/6/94
12/6/94
340
PPA-11
1 X
WATER
7-9
12/7/94
12/7/94
PPA-04
4 X
WATER
7-8
12/6/94
12/6/94
130
PPA-12
16.66
WATER
10.5-12.5
12/7/94
12/7/94
PPA-05
1 X
WATER
6-7
12/7/94
12/7/94
5 U
PPA-13
1 X
WATER
8-10
12/8/94
12/8/94
PPA-06
250
WATER
9-11
12/7/94
12/7/94
19,421
PPA-14
5 X
WATER
11-12
12/9/94
12/9/94
PPA-07
5 X
WATER
6-9
12/7/94
12/7/94
57
PPA-15
250 X
WATER
5-7
12/8/94
12/8/94
PPA-08
100 X
WATER
7-9
12/7/94
12/7/94
5,628
PPA-16
10 X
WATER
9.5-10.5
12/8/94
12/8/94
DRY
         395
                     13
                               271
                                         148
                                                  25
                                                            13,080
                                                                       292
NOTES
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                                  Table 2

                                  Robintech, 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 Date
Analysis Date

1,1,1-Trichlorethane  (ppb)

Sample ID
Dilution Factor
Sample Matrix
Sample Interval  (feet)
Sample Date
Analysis Date

1,1,1-Trichloroethane  (ppb)
PPA-17
1 X
WATER
11-12
12/9/94
12/9/94
183
PPA-25
-
DRY
7-8
12/14/94
-
PPA-18
10 X
WATER
8-9
12/9/94
12/9/94
9
PPA-26
20 X
WATER
12-14
12/14/94
12/15/94
PPA-19
1 X
WATER
11-12
12/12/94
12/14/94
5 U
PPA-27
1 X
WATER
10-12
12/14/94
12/15/94
PPA-20
50 X
WATER
11-12
12/13/94
12/15/94
2,480
PPA-28
-
DRY
11-12
12/15/94
-
PPA-21
5 X
WATER
8-9
12/13/94
12/15/94
83
PPA-29
5 X
WATER
12-14
12/14/94
12/15/94
PPA-22
10 X
WATER
11-12
12/14/94
12/15/94
476
PPA-30
10 X
WATER
10-12
12/14/94
12/15/94
PPA-23
1 X
WATER
7-8
12/14/94
12/15/94
5 U
PPA-31
5 X
DRY
11-12
12/14/94
12/15/94
PPA-24
25 X
WATER
11-12
12/14/94
12/15/94
5,080 E
PPA-32
1 X
WATER
11-12
12/14/94
12/15/94
DRY
         284
                     30
                              DRY
                                        116
                                                  217
                                                            DRY
NOTES
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits
                                                                       5 U

-------
                                                  Table 2

                                  Robintech, Inc./National Pipe Co. Site
                                              Vestal, New York

                                             ANALYTICAL RESULTS
                              PAVED PIPE STAGING AREA - GROUNDWATER SAMPLES
                                            TEMPORARY WELL POINTS
                                                    RDWP
                                   PPA-33
Sample ID
Dilution Factor
Sample Matrix
Sample Interval  (feet)
Sample Date
Analysis Date

1,1,1-Trichlorethane  (ppb)

Sample ID
Dilution Factor
Sample Matrix
Sample Interval  (feet)
Sample Date
Analysis Date

1,1,1-Trichloroethane  (ppb)
NOTES
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits
                                             PPA-34
            250 X
   DRY      WATER
  10-12     9-11
12/14/94  12/14/94
          12/14/94

   DRY     6,587

  PPA-41    PPA-42

  REFUSAL   REFUSAL

12/19/94  12/19/94
  PPA-35

   DRY
  10-12
12/14/94
                                                                 PPA-36
                                                                            PPA-37
                                                                                      PPA-38
                                                                                                PPA-39
             IX
   DRY      WATER
11.5-13.5   12-14
12/15/94  12/15/94
          12/15/94
   DRY

  PPA-43-*
   DRY

  PPA-44
                      5 U
                      PPA-45
                       50 X
    NOT     REFUSAL   WATER
  SAMPLED      -      10-12
             IX
   DRY      WATER
  12-14     14-16
12/15/94  12/15/94
          12/15/94
   DRY

  PPA-46
                                           5 U
                                PPA-47
                                 IX
                      REFUSAL   WATER
                                11-13
           12/21/94  12/21/94  12/21/94  12/21/94
                     12/21/94      -     12/24/94
                                           473
                                                                32
  PPA-40A
   1 X
  WATER
   8-10
12/15/94
12/15/94

  5 U

  PPA-48

    NOT
  SAMPLED

-------
                                                  Table  2

                                  Robintech,  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 Date
Analysis Date

1,1,1-Trichlorethane  (ppb)
PPA-49
-
DRY
13-15
12/21/94
-
PPA-50
50 X
WATER
10-12
12/21/94
12/24/94
PPA-51
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
-
DRY
         2,176
                   5 U
4,611
                                       DRY
NOTES
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                                  Table 2

                                  Robintech, Inc./National  Pipe  Co.  Site
                                                Vestal, NY

                                             ANALYTICAL RESULTS
                              PAVED PIPE STAGING AREA  - GROUNDWATER  SAMPLES
                                              MONITORING WELLS
                                                     RDWP
Sample ID
Dilution Factor
Sample Matrix
Sample Interval  (feet)
Sample Date
Analysis Date

1,1,1-Trichlorethane  (ppb)
MW-11
10 X
WATER
8-18
12/6/94
12/7/94
MW-12
1 X
WATER
10-20
12/12/94
12/12/94
165 E
          5 U
NOTES
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                               Table 3

                              Robintech, 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
Volatile Organic Compounds  (ppb)
1,1,1-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
Chloroform
Tetrachloroethene
Toluene
Trichloroethene
Vinyl chloride
SWB-17
100 X
WATER
18.5
12/15/94
12/19/94
SWB-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
5 X
WATER
19
12/16/94
12/19/94
SWB 21
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- 2 LA
17 X
WATER
17
12/16/94
12/19/94
SWB 22
250 X
WATER
17-19
12/19/94
12/19/94
1125
1543
869
500
500
500
2517
500



U
U
U

U
3683
2129
2500
2500
2500
2500
1706
2500

J
U
U
U
U
J
U
41
8
13
5
5
5
27
5



U
U
U

U
195
65
29
25
65
25
209
25



U

U

U
180005
49465
73669
12250
12250
175218
34326
12250



U
U


U
222129 E
53166
60052
2500
2500
2500
15565
2500
1288
85
230
85
54
4587
85
85
E
U

U
J
E
U
U
104192 E
60232
34568 E
1250 U
1250 U
2920
10929
1250 U
NOTES
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                               Table 3

                              Robintech, Inc. / National Pipe Co. Site
                                            Vestal, New York

                                           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
Volatile Organic Compounds  (ppb)
1,1,1-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
Chloroform
Tetrachloroethene
Toluene
Trichloroethene
Vinyl chloride
SWB-09
50 X
WATER
14-16
12/12/94
12/14/94
SWB-10
20 X
WATER
17-19
12/13/94
12/15/94
SWB-11
250 X
WATER
11-13
12/13/94
12/14/94
SWB-12
5 X
WATER
19-21
12/13/94
12/15/94
SWB-13
5 X
WATER
19-21
12/13/94
12/15/94
SWB-14
5 X
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
562
132
250
250
250
250
859
250

J
U
U
U
U

U
990
113
159
100
100
100
111
100



U
U
U

U
4070
2891
1250
1250
1250
1250
1250
1250


U
U
U
U
U
U
93
25
15
25
22
25
101
25

U
J
U
J
U

U
117
20
15
25
25
25
104
25

J
J
U
U
U

U
54
25
25
25
25
25
65
25

U
U
U
U
U

U
1614
1750
 771
 100 U
 100 U
 100 U
 208
 100 U
NOTES
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                               Table 3

                              Robintech, Inc. / National Pipe Co. Site
                                            Vestal, New York

                                           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

Volatile Organic Compounds  (ppb)

1,1,1-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
Chloroform
Tetrachloroethene
Toluene
Trichloroethene
Vinyl chloride
SWB-22
50 X
WATER
17-19
12/19/94
12/19/94
r^lM
pDj
18457 E
6741 E
3269 E
250 U
250 U
250 U
878
250 U
SWB-23
0.5 X
WATER
18
12/20/94
12/21/94
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
2.5 U
SWB-24
2500 X
WATER
19-21
12/20/94
12/20/94
101279
15405
14168
12250 U
12250 U
116800
12250 U
12250 U
SWB-25 SWB-26
20 X
WATER DRY
14.5-16.5 15
12/20/94 12/20/94
12/20/94
800
262
214
100 U
100 U
100 U
75 J
100 J
SWB-27 SWB-28
250 X
DRY WATER
19.6 17-19
12/20/94 12/20/94
12/20/94
39565
18249
14766
1250 U
1250 U
1250 U
1250 U
1250 U
SWB-29
5 X
WATER
14.5-16.5
12/20/94
12/20/94
55
25 U
20 J
25 U
25 U
25 U
24 J
25 U
NOTES
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                               Table 3

                              Robintech, Inc. / National Pipe Co. Site
                                            Vestal, New York

                                           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
Volatile Organic Compounds  (ppb)
1,1,1-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
Chloroform
Tetrachloroethene
Toluene
Trichloroethene
Vinyl chloride
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
1 X
WATER
16-18
12/21/94
12/21/94
SWB-35
1 X
WATER
7-9
12/21/94
12/21/94
1546
967
334
1250
1299
1250
1250
1250

J
J
U

U
U
U
426
1064
202
100
100
100
208
100



U
U
U

U
162
487
61
100
100
100
256
100


J
U
U
U

U
15
5
5
5
5
5
5
5

U
U
U
U
U

U
5
5
5
5
5
5
5
5
U
U
U
U
U
U
U
U
6
5
5
5
5
5
5
5


U
U
U
U
U
U
NOTES
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                               Table 3

                              Robintech, Inc. / National Pipe Co. Site
                                            Vestal, New York

                                           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

Volatile Organic Compounds  (ppb)

1,1,1-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
Chloroform
Tetrachloroethene
Toluene
Trichloroethene
Vinyl chloride
GP-05
500 X
WATER
22-24
10/12/95
10/13/95
r^lM
pDj
44,288 E
NA
NA
NA
2,500 U
9,781
2,500 U
NA
GP-05
5,000 X
WATER
22-24
10/12/95
10/16/95
66,275
NA
NA
NA
NA
NA
NA
NA
GP-06
500 X
WATER
15-17
10/12/95
10/13/95
196,869
NA
NA
NA
2,500
155,251
14,000
NA
GP-06
10,000 X
WATER
15-17
10/12/95
10/18/95
E 376,030
NA
NA
NA
U NA
E 191,090
NA
NA
NOTES
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                               Table 3

                              Robintech, Inc. / National Pipe Co. Site
                                            Vestal, New York

                                           ANALYTICAL RESULTS
                                       PW-2 AREA - ON-SITE SAMPLES
                                          TEMPORARY WELL POINTS
                                                  RDWP
Sample ID
Dilution Factor
Matrix
Sample Interval  (feet)
Sample Date
Analysis Date

Volatile Organic Compounds  (ppb)

1,1,1-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
Chloroform
Tetrachloroethene
Toluene
Trichloroethene
Vinyl chloride
SE-01
5 X
WATER
7-9
12/13/94
12/13/94
, \
')
69
25 U
25 U
25 U
25 U
25 U
199
25 U
SE-02
25 X
WATER
7-9
12/13/94
12/13/94
156
125 U
125 U
125 U
100 J
125 U
532
125 U
SE-03 SE-04 SE-05
100 X -
WATER REFUSAL REFUSAL
9-11 8' 7'
12/13/94 12/19/94 12/19/94
12/13/94
575
398 J -
500 U -
500 U -
500 U
500 U
500 U
500 U
SE-06
1 X
WATER
8-10
12/21/94
12/21/94
5 U
5 U
5 U
5 U
5 U
5 U
5 U
5 U
SE-07
1 X
WATER
10-12
12/21/94
12/21/94
5 U
5 U
5 U
5 U
5 U
5 U
5 U
5 U
SE-08
50 X
WATER
12-14
12/21/94
12/21/94
602
4604
250 U
250 U
250 U
250 U
250 U
250 U
SE-09
5 X
WATER
12-14
12/21/94
12/23/94
64
277
25 U
25 U
25 U
25 U
25 U
25 U
NOTES
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                               Table 3

                              Robintech, Inc. / National Pipe Co. Site
                                            Vestal, New York

                                           ANALYTICAL RESULTS
                                       PW-2 AREA - ON-SITE SAMPLES
                                          TEMPORARY WELL POINTS
                                                  RDWP
Sample ID
Dilution Factor
Matrix
Sample Interval (feet)
Sample Date
Analysis Date
Volatile Organic Compounds
1,1, 1-Trichloroethane
1, 1-Dichloroethane
1, 1-Dichloroethene
Chloroform
Tetrachloroethene
Toluene
Trichloroethene
Vinyl chloride
SE-10
1 X
WATER
13-15
12/21/94
12/23/94
(ppb)
32
11
4 J
5 U
5 U
5 U
28
5 U
SE-11 SE-12
IX
REFUSAL WATER
8 10-12
12/21/94 12/21/94
DRY 12/23/94

15
51
4 J
5 U
5 U
5 U
10
5 U
SE-13 SE-14
IX
WATER REFUSAL
10-12 8
12/21/94 12/21/94
12/23/94 DRY

5 U
4 J
5 U
5 U
5 U
5 U
5 U
5 U
SE-15
1 X
WATER
14-16
12/21/94
12/23/94

5 U
5 U
5 U
5 U
5 U
5 U
5 U
5 U
SE-16
1 X
WATER
12-14
12/22/94
12/23/94

12
140 E
5 U
5 U
5 U
5 U
5 U
5 U
SE-17
1 X
WATER
12-14
12/22/94
12/23/94

5 U
5 U
5 U
5 U
5 U
5 U
5 U
5 U
SE-18
10 X
WATER
11-13
12/22/94
12/23/94

312
208
54
50 U
50 U
50 U
55
50 U
NOTES
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                               Table 3

                              Robintech, Inc. / National Pipe Co. Site
                                            Vestal, New York

                                           ANALYTICAL RESULTS
                                     PW-2 AREA - GROUNDWATER SAMPLES
                                            MONITORING WELLS
                                              RDWP / RDWPA
Sample ID
Dilution Factor
Matrix
Sample Interval  (feet)
Sample Date
Analysis Date
Volatile Organic Compounds  (ppb)

1,1,1-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
Chloroform
Tetrachloroethene
Toluene
Trichloroethene
Vinyl chloride
MW-6
1 X
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
1 X
WATER
15-25
12/19/94
12/19/94
5392
11080
2668
3090
1000
1000
1000
1000


J
J
U
U
U
U
328
182
141
168
202
100
670
100





U

U
NOTES
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                                 Table 4

                                 Robintech, 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
EW-02
10-12
1 X
SOIL
10/10/95
10/18/95
EW-02
14-16
100 X
SOIL
10/10/95
10/11/95
EW-02
4-6
100 X
SOIL
10/10/95
10/12/95
OW-03
4-6
100 X
SOIL
10/11/95
10/12/95
OW-03
6-8
12.5 X
SOIL
10/11/95
10/12/95
OW-3
14-16
5 X
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 (ppm)
1,1, 1-Trichloroethane
Trichloroethene
Toluene
Tetrachloroethene
Sample ID
Sample Interval (feet)
Dilution Factor
Sample Matrix
Sample Date
Analysis Date
0.013
0.005 U
0.005 U
0.005 U
GP-05
3.5-4
50,000 X
SOIL
10/12/95
10/13/95
4.499
0.5 U
0.5 U
1.187
GP-05
6-6.5
4,000 X
SOIL
10/12/95
10/12/95
4.205
0.321 J
2.009
3.46
GP-05
6-6.5
100,000 X
SOIL
10/12/95
10/18/95
1.39
0.500 U
0.500 U
2.35
GP-05
8-8.5
400 X
SOIL
10/12/95
10/13/95
0.27125
0.0625 U
0.1325
0.115
GP-05
13-14
400 X
SOIL
10/12/95
10/13/95
0.025
0.08
0.025
0.025
GP-05
16-17
200 X
SOIL
10/12/95
10/13/95
U 55.5
25 U
U 16.500
U 25 U
GP-05
18-20
200 X
SOIL
10/12/95
10/13/95
1,961 E
45.225
J 1, 168 E
25 U
GP-06
3.5-4
400 X
SOIL
10/12/95
10/13/95
Volatile Organic Compounds (ppm)
1,1, 1-Trichloroethane
Trichloroethene
Toluene
Tetrachloroethene
1,226.90
250 U
967.75
250 U
2,475.600
154.400
2,234.400
20
E 2,842.60
E 500 U
E 1,758.20
U 500 U
2 U
2 U
3.62
2 U
7.748
2 U
7.064
2 U
2.36
1 U
3.066
1 U
4.4
1 U
4.54
1 U
25.296 E
2 U
13.642
9.324
Notes
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                                         Table 4

                                         Robintech, 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

Volatile Organic Compounds

1,1,1-Trichloroethane
Trichloroethene
Toluene
Tetrachloroethene

Sample ID
Sample Interval  (feet)
Dilution Factor
Sample Matrix
Sample Date
Analysis Date

Volatile Organic Compounds

1,1,1-Trichloroethane
Trichloroethene
Toluene
Tetrachloroethene
GP-06
3.5-4
1,000 X
SOIL
10/12/95
10/12/95
(ppm)
31.257
5 U
5 U
5 U
GP-07
10
2.5 X
SOIL
10/13/95
10/13/95
(ppm)
0.0125 U
0.087
0.0125 U
0.0125 U
GP-06
4-8
5,000 X
SOIL
10/12/95
10/12/95

989.500 E
42.5
508.500 E
25 U
GP-08
0-0.5
1 X
SOIL
10/13/95
10/13/95

0.005 U
0.022
0.005 U
0.005
GP-06
4-8
50,000 X
SOIL
10/12/95
10/13/95

1,282.50
250 U
578.45
250 U
GP-08
8
1 X
SOIL
10/13/95
10/13/95

0.008
0.008
0.043
0.023
GP-06
8-10
5,000 X
SOIL
10/12/95
10/12/95

46.275
25 U
63.79
25 U
GP-08
8.5-9
1 X
SOIL
10/13/95
10/13/95

0.005 U
0.005 U
0.005 U
0.005 U
GP-06
10-12
400 X
SOIL
10/12/95
10/13/95

6.728
2 U
7.348
2 U
GP-08
16-18
1 X
SOIL
10/13/95
10/13/95

0.03
0.005 U
0.03
0.0029 J
GP-06
16-17
400 X
SOIL
10/12/95
10/13/95

5.48
1.036 J
8.08
2 U
GP-09
10-12
10 X
SOIL
10/13/95
10/16/95

0.057
0.050 U
0.050 U
0.050 U
GP-07
4-5
10 X
SOIL
10/13/95
10/13/95

0.050 U
0.134
0.050 U
0.050 U
GP-10
5-6
10 X
SOIL
10/13/95
10/16/95

0.054
0.050 U
0.028 J
0.050 U
GP-07
10
1 X
SOIL
10/13/95
10/13/95

0.025
0.080 E
0.005 U
0.005 U
GP-10
15.5
5 X
SOIL
10/13/95
10/16/95

0.025 U
0.035
0.025 U
0.025 U
Notes
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                                          Table 4

                                         Robintech, 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

Volatile Organic Compounds

1,1,1-Trichloroethane
Trichloroethene
Toluene
Tetrachloroethene
GP-11
8
1,000 X
SOIL
10/13/95
10/17/95
(ppm)
46.717
5 U
115.679 E
5 U
GP-11
8
10,000 X
SOIL
10/13195
10/17/95

50 U
50 U
382.04
50 U
 GP-16
  0-2
  1 X
  SOIL
10/16/95
10/17/95
 0.005 U
 0.005 U
 0.006
 0.005 U
GP-16
4-6
1 X
SOIL
10/16/95
10/17/95
0.01
0.009
0.005 U
0.005 U
GP-17
3.5-4
2.5 X
SOIL
10/17/95
10/17/95
0.0125 U
0.0125 U
0.0125 U
0.0125 U
Notes
J = Outside Linear Working Range  (Low)
E = Outside Linear Working Range  (High)
B = Compound Found in Method Blank
U = Below Method Quantitation Limits

-------
                                                      Table 4
                                      Robintech, 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
Volatile Organic Compound
1,1, 1-Trichloroethane
1, 1-Dichloroethane
1, 1-Dichloroethene
Chloroform
Tetrachloroethene
Trichloroethene
Toluene
Vinyl Chloride
SWB-02
2-4
3.33 X
SOIL
12/19/94
12/19/94
(ppm)
0.269 E
0.231
0.026
0.01665 U
0.076
0.01665 U
1.892 E
0.01665 U
SWB-02
2-4
3.33 X
SOIL
12/19/94
12/19/94
SWB-11
1-2
10 X
SOIL
12/13/94
12/14/94
SWB-11
6-7
5 X
SOIL
12/13/94
12/14/94
SWB-11
11-12
5 X
SOIL
12/13/94
12/14/94
SWB-17
10-12
17 X
SOIL
12/15/94
12/16/94
SWB 18A
5-7
20 X
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
0.269
0.231
0.026
0.01665
0.076
0.01665
1.892
0.01665
E


U

U
E
U
0.
0.
0.
0.
0.
0.
0.
0.
,050
,050
,050
,050
,050
,050
,050
,050
U
U
U
U
U
U
U
U
0
0
0
0
0
0
0
0
.025
.025
.025
.025
.025
.025
.025
.025
U
U
U
U
U
U
U
U
0
0
0
0
0
0
0
0
.025
.025
.025
.025
.025
.025
.025
.025
U
U
U
U
U
U
U
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,
2,
0,
0,
0,
0,
0,
0,
.535
.342
.100
.100
.428
.468
.063
.100

E
U
U


J
U
0,
0,
0,
0,
0,
0,
0,
0,
.217
.163
.060
.100
.573
.699
.100
.100


J
U


U
U
0
0
0
0
0
2
0
0
.148
.2
.031
.050
.067
.556
.050
.050


J
U

E
U
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 Quantitation Limits

-------
                                                        Table 5

                                        Robintech, Inc. / National Pipe Co. Site
                                                    Vestal, New York

                                                   Analytical Results
                                               Bedrock Groundwater Sampling
                                                           RDWPA
Sample ID
Matrix
Sample Date
Analysis Date

VOCs  (ppb)

Chioromethane
Bromomethane
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
Bromodichloromethane
1, 2-Dichloropropane
cis-1,3-dichloropropene
Trichloroethene
dibromochloromethane
1,1,2-Trichloroethane
trans-1,3-Dichloropropene
Bromoform
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Chlorobenzene
1, 3-Dichlorobenzene
1,2-Dichlorobenzene
1, 4-Dichlorobenzene
Freon 113
MW-3*
WATER
9/26/95
10/5/95
MW-3 A
WATER
9/26/95
10/5/95
MW-4
WATER
9/27/95
10/5/95
MW-4 A
WATER
9/27/95
10/5/95
MW-4 A*
WATER
9/27/95
10/5/95
MW-5
WATER
9/26/95
9/27/95
<4
<4

<4
<4
<4
<1
<4
<4
<4

<4
<4
<4

<4
<4
<4
<1
<4
                              <2

                             * MW-3 is considered an overburden monitoring well.
                             ** Field duplicate sample.
<4
<4

5.4
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.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
<0 . 5
<0 . 5
<0.5
<0.5
<0 . 5
<0.5
<0 . 5
<0.5
<2
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<2
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5

<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<2
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.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
<0 . 5
<0 . 5
<0.5
<0.5
<0 . 5
<0.5
<0 . 5
<0.5
<2
<0
1.
14
1.
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<0
<2
.5
1

6
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5
.5

-------
                                            Table 5

                             Robintech, Inc. / National  Pipe Co.  Site
                                       Vestal, New York

                                       Analytical Results
                                  Bedrock Groundwater Sampling
                                              RDWPA
VOCs  (ppb)

Chioromethane
Bromomethane
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
Bromodichloromethane
1, 2-Dichloropropane
cis-1,3-Dichloropropene
Trichloroethene
Dibromochloromethane
1,1,2-Trichloroethane
trans-1,3-Dichlorpropene
Bromoform
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Chlorobenzene
1, 3-dichlorobenzene
1,2-dichlorobenzene
1, 4-dichlorobenzene
Freon  113
MW-5A
WATER
9/26/95
9/27/95
< 4
< 4
< 1
< 4
< 10
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 1
< 0.
< 0.
< 1
< 1
< 0.
< 0.
< 0.
< 0.
< 0.
< 2





5
5
5
5
5
5
5
5
5
5
5
5
5

5
5


5
5
5
5
5

MW-6
WATER
9/25/95
9/26/95
< 4
< 4
< 1
< 4
< 10
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 1
< 0.
< 0.
< 1
< 1
< 0.
< 0.
< 0.
< 0.
< 0.
< 2





5
5
5
5
5
5
5
5
5
5
5
5
5

5
5


5
5
5
5
5

MW-6A
WATER
9/25/95
9/26/95
< 4
< 4
< 1
< 4
< 10
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 1
< 0.
< 0.
< 1
< 1
< 0.
< 0.
< 0.
< 0.
< 0.
< 2





5
5
5
5
5
5
5
5
5
5
5
5
5

5
5


5
5
5
5
5

c 4
c 4
c 1
c 4
c 10
c 0.5
 1.9
 8.9
c 0.5
c 0.5
c 0.5
c 0.5
 5.7
< 0.
< 0.
< 0.
< 0.
< 0.
< 1
< 0.
< 0.
< 1
< 1
< 0.
< 0.
< 0.
< 0.
< 0.
< 2
PW-1
WATER
9/27/95
10/3/95
< 4
< 4
< 1
< 4
< 10
< 0.5
< 0.5
1.9
< 0.5
< 0.5
< 0.5
< 0.5
1.7
< 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
< 0.5
< 2
PW-4
WATER
12/12/95
12/13/95
< 4
< 4
< 1
< 4
< 10
< 0.5
< 0.5
17
3.1
< 0.5
< 0.5
< 0.5
17
< 0.5
< 0.5
< 0.5
< 0.5
0.63
< 1
< 0.5
< 0.5
< 1
< 1
< 0.5
< 0.5
< 0.5
< 0.5
< 0.5
< 2

-------
                                                Table 5

                              Robintech, Inc. / National Pipe Co. Site
                                            Vestal, New York

                                           Analytical Results
                                     Bedrock Groundwater Sampling
                                                 RDWPA
Sample ID
Matrix
Sample Date
Analysis Date

VOCs  (ppb)
Chioromethane
Bromomethane
Vinyl Chloride
Chloroethane
Methylene Chloride
Trichlorofluoromethane
1,1-Dichloroethene
1,1,1-Dichloroethane
cis-1,2-Dichloroethene
trans-1,2-Dichloroethene
Chloroform
1,2-Dichloroethane
1,1,1-Trichloroethane
Carbon Tetrachloride
Bromodichloromethane
1, 2-Dichloropropane
cis-1,3-Dichloropropene
Trichloroethene
Dibromochloromethane
1,1,2-Trichloroethane
trans-1,3-Dichloropropene
Bromoform
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Chlorobenzene
1, 3-Dichlorobenzene
1,2-Dichlorobenzene
1, 4-Dichlorobenzene
Freon 113
PW-5
WATER
9/27/95
10/4/95






<
<
1
<
<
<
4
4
.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
PW-6
WATER
9/27/95
10/3/95
< 4
< 4
< 1
< 4
< 10
< 0.
1.9
8.9
< 0.
< 0.
< 0.
< 0.
5.7
< 0.
< 0.
< 0.
< 0.
< 0.
< 1
< 0.
< 0.
< 1
< 1
< 0.
< 0.
< 0.
< 0.
< 0.
< 2





5


5
5
5
5

5
5
5
5
5

5
5


5
5
5
5
5

PW-8
WATER
9/28/95
10/3/95
< 4
< 4
< 1
8.5
< 10
0.92
6.9
29
5.4
< 0.
< 0.
< 0.
54
< 0.
< 0.
< 0.
< 0.
5.2
< 1
< 0.
< 0.
< 1
< 1
< 0.
< 0.
< 0.
< 0.
< 0.
< 2











5
5
5

5
5
5
5


5
5


5
5
5
5
5

PW-9
WATER
9/29/95
10/4/95
< 4
< 4
< 1
< 4
< 10
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 0.
< 1
< 0.
< 0.
< 1
< 1
< 0.
< 0.
< 0.
< 0.
< 0.
< 2
PW-10
WATER
9/28/95
10/3/95





5
5
5
5
5
5
5
5
5
5
5
5
5

5
5


5
5
5
5
5

< 4
< 4
< 1
< 4
< 10
< 0.
0.64
9.3
< 0.
< 0.
< 0.
< 0.
2.3
< 0.
< 0.
< 0.
< 0.
< 0.
< 1
< 0.
< 0.
< 1
< 1
< 0.
< 0.
< 0.
< 0.
< 0.
< 2





5


5
5
5
5

5
5
5
5
5

5
5


5
5
5
5
5

-------
TABIiE 6
Chemical Class   Analyte
                           SUMMARY STATISTICS FOR SITE, BY CHEMICAL AND MEDIUM/AREA

                                TYPE-Ground Water (Unfiltered) - Overburden
Volatiles
Inorganics
Vinyl Chloride
Chloroethane
1,1-Dichloroethene
1,1-Dichloroethane
1,2-Dichloroethene  (total)
Chloroform
1,2-Dichloroethane
1,1,1-Trichloroethane
Trichloroethene
1,1,2-Trichloroethane
Benzene
Tetrachloroethene
Aluminum
Arsenic
Barium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Potassium
Sodium
Vanadium
Zinc
Num.
Times
Detected
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
Num. Lowest Highest Geom. 95
Samples Detected Detected Mean Upp.
Analyzed Cone.
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.
486.
36.
145.
49000.
8.
40.
31.
2780.
1.
8900.
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.
110.
370.
400.
3.
5.
1100.
1000.
4.
23.
53.
52500.
36.
1050.
1710001.
770.
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
Pet. Min.
Conf. Detect.
Cone. Limit 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,
28943,
4,
30,
.65
.03
.65
.82
.93
.34
.71
.87
.71
.61
.35
.93
.61
.52
.46
.77
.74
.60
.13
.31
.90
.26
.09
.49
.25
.23
.23
.97
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

91


90


34
78
Max.
Detect
Limit
10,
10,
5,
5,
5,
5,
5,
5,
5,
5,
5,
5,

2,
43,

8,
38,
17,

2,


17,


11,
2,
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00

.30
.20

.80
.50
.30

.80


.80


.20
.78

-------
TABIiE 6
Chemical Class   Analyte
Inorganics
Aluminum
Arsenic
Barium
Calcium
Chromium
Iron
Magnesium
Manganese
Nickel
Potassium
Sodium
Thallium
Vanadium
Zinc
                           SUMMARY STATISTICS FOR SITE, BY CHEMICAL AND MEDIUM/AREA

                                TYPE-Ground Water  (Unfiltered) - Overburden
Num.
Times
Detected
2
1
8
11
1
8
11
10
3
11
11
1
1
8
Num. Lowest Highest Geom. 95
Samples Detected Detected Mean Upp.
Analyzed Cone.
11
11
11
11
11
11
11
11
11
11
11
11
11
11
230.
20.
48.
13000.
14.
20.
2960.
110.
15.
44.
5370.
1.
31.
6.
00
00
00
00
00
51
00
00
80
00
00
37
30
00
Cone.
1030
20
511
187000
14
1630
50900
5060
23
14200
95900
1
31
180
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.37
.30
.00
Pet. Min.
Conf. Detect.
Cone. Limit Limit
100,
1,
81,
87757,
3,
90,
15073,
502,
10,
1212,
30950,
1,
4,
21,
.99
.41
.74
.62
.74
.51
.96
.72
.33
.25
.66
.17
.33
.75
138.
2.
43.
.
3.
20.
.
5.
8.
.
.
1.
6.
2.
00
12
20

30
50

13
90


37
34
78
Max.
Detect
Limit
159,
2,
46,

8,
68,

5,
17,


7,
11,
34,
.00
.30
.00

.80
.00

.13
.80


.80
.20
.00

-------
TABIiE 6
Chemical Class
                      SUMMARY STATISTICS  FOR SITE,  BY CHEMICAL AND MEDIUM/AREA

                           TYPE-Ground Water (Unfiltered)  - Bedrock
Volatiles
Semivolatiles
Inorganics
      Analyte

      Vinyl  Chloride
      Chloroethane
      Acetone
      1,1-Dichloroethene
      1,1-Dichloroethane
      1,2-Dichloroethene  (total)
      Chloroform
      1,2-Dichloroethane
      2-Butanone
      1,1,1-Trichloroethane
      Carbon Tetrachloride
      Trichloroethene
      Benzene
      Tetrachloroethene
      Toluene
      Ethylbenzene
      Styrene
      Xylene (total)
(BNAs) bis(2-Ethylhexyl)phthalate
      Aluminum
      Arsenic
      Barium
      Cadmium
      Calcium
      Chromium
      Cobalt
      Iron
      Lead
      Magnesium
      Manganese
      Mercury
      Nickel
      Potassium
      Sodium
      Zinc
Num.
Times
Detected
5
5
3
5
10
5
1
2
5
8
1
7
6
1
11
4
1
8
1
8
5
11
3
11
1
1
11
3
11
10
2
1
11
11
9
Num. Lowest Highest
Samples Detected Detected
Analyzed Cone.
15
15
15
15
15
15
15
15
15
15
15
15
14
15
15
15
15
15
12
11
11
11
11
11
11
11
11
8
11
11
11
11
11
11
11
4,
6,
14,
23,
3,
140,
4,
3,
21,
5,
60,
4,
2,
3,
2,
2,
8,
3,
97,
170,
8,
59,
5,
12500,
30,
21,
332,
5,
7470,
80,
0,
18,
725,
10500,
23,
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.80
.00
.00
.00
.00
.00
.00
.39
.00
.00
.14
.20
.00
.00
.00
Cone.
38.
36.
2200.
150.
865.
535.
4.
4.
510.
6950.
60.
1350.
11.
3.
2250.
73.
8.
480.
97.
1290.
27.
1360.
6.
197000.
30.
21.
42400.
10.
19300.
1440.
0.
18.
39400.
64900.
1390.
00
00
00
50
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
35
00
00
00
00
00
00
60
00
00
40
20
00
00
00
Geom. 95 Pet. Min.
Mean Upp. Conf. Detect.
Cone. Limit Limit
6.
6.
10.
7.
18.
12.
3.
3.
17.
34.
3.
17.
3.
3.
29.
4.
3.
8.
6.
241.
5.
254.
3.
73781.
2.
11.
1540.
2.
13650.
292.
0.
8.
2123.
32945.
132.
75
86
76
46
40
36
15
19
11
80
77
33
94
09
45
35
55
75
40
95
01
17
05
09
22
37
38
73
16
18
04
92
73
97
59
10
10
10
5
5
5
5
5
10
5
5
5
5
15
5
5
5
5
10
130
2

4

2
20

0

14
0
8


2
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.00
.12
.
.60
.
.08
.00
.
.91
.
.70
.03
.90
.
.
.78
Max.
Detect
Limit
10.
10.
50.
5.
5.
5.
25.
25.
50.
5.
25.
5.
25.
25.
5.
25.
25.
25.
10.
130.
6.
.
5.
.
43.
38.
.
5.
.
14.
0.
17.
.
.
2.
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00

00

00
50

00

70
10
80


78

-------
TABIiE 6




Chemical Class

Inorganics
Analyte

Arsenic
Barium
Calcium
Iron
Magnesium
Manganese
Potassium
Sodium
Zinc
                    SUMMARY STATISTICS FOR SITE, BY CHEMICAL AND MEDIUM/AREA

                            TYPE-Ground Water  (Filtered)  -  Bedrock
Num.
Times
Detected
1
4
4
1
4
3
4
4
1
Num. Lowest Highest
Samples Detected Detected
Analyzed Cone.
4
4
4
4
4
4
4
4
4
8.
121.
11000.
630.
7580.
60.
1030.
8280.
5.
,90
,00
,00
,00
,00
,00
,00
,00
,00
Cone.
8
1270
78800
630
15700
430
35900
58400
5
.90
.00
.00
.00
.00
.00
.00
.00
.00
Geom.
Mean
Cone.
1.
513.
39951.
38.
10003.
90.
4685.
30599.
1.
80
15
52
54
03
58
01
21
97
                                                                                     95  Pet.
                                                                                                 Min.
Upp. Conf.  Detect.
  Limit      Limit

              2.12
                                                                                                                       20.10

                                                                                                                       14.70


                                                                                                                        2.78
Max.
Detect.
 Limit

  2.12
                       68.00

                       14.70


                        3.10

-------
TABIiE 6
Chemical Class
                    SUMMARY STATISTICS FOR SITE, BY CHEMICAL AND MEDIUM/AREA

                            TYPE-Ground Water  (Filtered) - Bedrock
Semivolatiles (BNAs)
Inorganics
Analyte

Chloroethane
Methylene Chloride
Acetone
1,1-Dichloroethane
1,2-Dichloroethene  (total)
Chloroform
1,1,1-Trichlorethane
Trichloroethene
Tetrachloroethene
Toluene
Xylene  (total)
Napthaiene
2-Methylnaphthalene
Phenanthrene
Anthracene
Di-n-butylphthalate
Fluoranthene
Pyrene
Benzo(a)anthracene
Chrysene
bis (2-Ethylhexyl)phthalate
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Aluminum
Arsenic
Barium
Cadmium
Calcium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Num.
Times
Detected
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
Num. Lowest Highest
Samples Detected Detected
Analyzed Cone.
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
28
27
27
27
27
27
27
27
27
27
27
27
27
27
27
58,
15,
12,
5,
2,
7,
5,
2,
3,
2,
2,
130,
150,
1800,
280,
98,
950,
120,
75,
86,
84,
470,
540,
100,
4650,
2,
23,
1,
129,
27,
11,
10300,
8,
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
Cone.
58.
53.
81.
49.
22.
8.
630.
16.
4.
27.
8.
130.
300.
1800.
280.
2100.
950.
2200.
840.
950.
18000.
470.
540.
630.
142000.
13.
137.
18.
21839.
27.
43.
34300.
12800.
5100.
882.
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
00
50
30
00
10
30
00
00
00
00
Geom.
Mean
Cone.
6.
6.
12.
4.
3.
3.
4.
3.
3.
3.
3.
264.
272.
288.
269.
290.
281.
285.
271.
273.
849.
274.
275.
271.
9652.
1.
23.
0.
2048.
2.
12.
18027.
89.
2287.
347.
54
61
73
17
46
31
25
28
08
60
22
39
84
33
13
23
59
86
09
71
29
34
76
09
01
72
27
91
82
54
92
39
65
25
03
95 Pet.
Upp. Conf.
Limit
9,
23,
28,
8,
5,
4,
14,
4,
3,
5,
4,
361,
368,
441,
362,
476,
401,
458,
404,
407,
6787,
374,
378,
387,
15453,
8,
60,
2,
6983,
3,
25,
20749,
94920,
2944,
485,
.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
.84
.94
.34
.04
.42
.24
.49
.02
.55
.41
Min.
Detect.
Limit
10.00
5.00
10.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
330.00
330.00
330.00
330.00
340.00
330.00
330.00
330.00
330.00
360.00
330.00
330.00
330.00
.
1.25
9.55
0.43
.
4.15
3.00
.
.
.
.
Max.
Detect
Limit
53.00
110.00
210.00
8.00
26.00
26.00
8.00
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
.
.
.
.

-------
TABIiE 6
                                                 TYPE-Ground Water (Unfiltered) - Overburden
Chemical Class   Analyte

                 Mercury
                 Nickel
                 Potassium
                 Selenium
                 Silver
                 Sodium
                 Vanadium
                 Zinc
                 Cyanide
Num.
Times
Detected
26
24
27
2
9
27
5
27
1
Num.
Samples
Analyzed
27
27
27
27
27
27
27
27
27
Lowest Highest
Detected Detected
Cone.
0.
3.
2.
0.
0.
39.
15.
2.
0.
02
70
71
44
09
20
50
50
11
Cone.
5.
66.
1400.
0.
4.
449.
38.
120.
0.
78
30
00
73
80
00
70
70
11
Geom.
Mean
Cone.
0,
13,
512,
0,
0,
120,
5,
46,
0,
.31
.79
.92
.33
.37
.58
.93
.97
.31
95 Pet.
Upp. Conf.
Limit
4.
40.
1954.
0.
2.
177.
9.
76.
0.
,41
,12
,15
,52
,14
,65
,45
,81
,71
Min.
Detect.
Limit
0.11
3.92
.
0.42
0.07
.
5.40
.
0.05
Max.
Detect
Limit
0.11
4.33

2.37
1.08

12.50

1.60

-------


TABIiE 7  ROBINTECH/NATIONAL PIPE CO., INC. SITE:  SUMMARY OF EXPOSURE PATHWAYS
Pathway

Groundwater:
Receptor
                                                                     Time-Frame Evaluated
                                                                     Present       Future
                          Degree of
                          Assessment
                         Quant.   Qual.
                              Rationale for Selection
                              or Exclusion
Ingestion of Unfiltered Ground Water
(From Bedrock & Overburden
Aguifers)
Small Child Resident
Adult Resident
No
No
Yes
Yes
X
X
Residents currently obtain
drinking water from public
drinking water supply;
Assumes residents obtain
drinking water from local well
in the future.
Inhalation of Ground Water
Contaminants During Showers
Inhalation of Ground
Water Contaminants
During Baths

Dermal Contact with Ground
Water Contaminants During
Showers/Baths
Inhalation of Contaminants
that Volatilize from Ground water
and Seep in Basements

Dermal Contact with Onsite
Production Well Water
Adult Resident
Small Child Resident
Adult Resident
Small Child Resident
Local Resident
Onsite Worker
                               No
                               No
No
                               No
                               No
                                           Yes
                                           No
            No
                                           No
                                           No
                              Assumes residents obtain
                              water from local wells in the
                              future; several volatiles
                              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.

                              Ground water table is shallow; but
                              low avg VOC cone. & westerly flow
                              preclude significant exposure.

                              Data inadeguate for assessment.
Inhalation of Volatilized
Contaminants from Production
Well Water
Onsite Worker
                               No
                                           No
                                          Data inadeguate for assessment.

-------
Soil
Dermal Contact With Onsite Soils
 Surface Soils

 Subsurface Soils

Ingestion of On-site Soils
 Surface Soils

 Subsurface Soils
Trespasser                     No

Excavation/Utility Worker      Yes


Trespasser                     No

Excavation/Utility Worker      Yes
Yes

Yes


Yes

Yes
X

X


X

X
Assumes complete pavement
removal in the future;
Excavation or routine maintenance of
buried utilities may be necessary.

Assumes complete pavement
removal in the future; Excavation or
routine maintenance of buried
utilities may be necessary.

-------


TABIiE 7  ROBINTECH/NATIONAL PIPE CO., INC. SITE:  SUMMARY OF EXPOSURE PATHWAYS
Pathway
Receptor
                                                                     Time-Frame Evaluated
                                                                     Present       Future
                          Degree of
                          Assessment
                         Quant.   Qual.
Rationale for Selection
or Exclusion
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)

Sediment:

Dermal Contact with
Sediments in Drainage Ditches

Incidental Ingestion of
Sediments in Drainage Ditches

Surface Water:
Onsite Worker
Trespasser

Youth Residents
Youth Residents
Trespassers
Youth Residents

Trespassers
Youth Residents
No
                               Yes
                               Yes
             No
                                            Yes
                                            Yes
                               Yes
Yes
                                            Yes
             Yes
                                          Releases expected to be
                                          insignificant.

                                          Soils adjacent to drainage
                                          ditch are currently accessible
                                          to Skate Estate users.

                                          Soils adjacent to drainage
                                          ditch are currently accessible
                                          to Skate Estate users.
This area is accessible to
the general public.

This area is accessible to
the general public.
Dermal Contact With Surface
Water in Drainage Ditches
Ingestion of Surface Water
in Drainage Ditches
Trespassers
Local Residents
Trespassers
Local Residents
                               No
                               No
                                            No
                                            No
                                          Water is intermittent and
                                          shallow; exposure assumed
                                          to be insignificant.

                                          Ditches are too shallow to
                                          support swimming activities;
                                          thus, incidental ingestion is
                                          unlikely.

-------
Manhole and
Settling Tank
Exposures

Air:
Utility/Maintenance
Worker
                                                                        No
                                                                                     No
                                          Exposure likely to be
                                          insignificant.
Inhalation of Contaminants
in Air




Local Resident
Trespasser
Worker
No
             No
 Unable to assess because of limited
 and inconclusive sampling data;
 sampling results may not be
representative of site sources.

-------
                 TABIiE 9 SUMMARY OF CARCINOGENIC RISK ESTIMATES
                            FOR THE ROBINTECH SITE

                                                      Current/     Incremental
Scenario                                 Receptor     Future       Risk

Ground Water  (overburden)

Ingestion                                Resident     F            3.8 x 10 -3**
Volatiles Inhalation While Showering     Resident     F            1.0 x 10 -3**

Ground Water  (bedrock)

Ingestion                                Resident     F            4.1 x 10 -3**
Volatiles Inhalation While Showering     Resident     F            1.4 x 10 -3**

Surface Soils

Ingestion - On Site                      Trespasser   F            1.2 x 10 -5
Dermal Contact - On Site                 Trespasser   F            1.7 x 10 -6
Ingestion - Skate Estate                 Youth        C/F          1.4 x 10 -7
Dermal Contact - Skate Estate            Youth        C/F          2.5 x 10 -6

Subsurface Soils

Ingestion - On Site                      Worker       C/F          4.3 x 10 -7
Dermal Contact - On Site                 Worker       C/F          1.1 x 10 -7

Sediment

Ingestion - On Site                     Trespasser    C/F          3.4 x 10 -7
Dermal Contact - On Site                Trespasser    C/F          2.8 X 10 -6
Ingestion - Off Site, Downgradient      Youth         C/F          2.8 x 10 -7
Dermal Contact - Off Site, Downgradient Youth         C/F          1.7 x 10 -6

** Exceeds 10 -4 risk.

-------

     TABLE 10 SUMMARY OF NONCARCINOGENIC HAZARD INDICES  (HI) 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

(a) - adult
(c) - child
* HI exceeds one (1).
Receptor
 Resident
 Resident
 Resident
 Resident
             Current/
             Future
          Acute
          HI
      3.5 x 10 -1(a)
      8.0 x 10 -1(c)
      N/A
      2.7 x 10 -l(a)
      6.3 x 10 -1(c)
      N/A
 Worker
 Worker
C/F
C/F
1.2 x 10 -3
5.5 x 10 -4
                   Chronic
                   HI
                   1.3 x 10 1(a)*
                   3.0 x 10 1 (C)*
                   1.0 x 10 -1  (a)
                   1.4 x 10 1(a)*
                   3.3 x 10 1(c)*
                   5.4 x 10 -1(a)
Trespasser
Trespasser
Youth
Youth
F
F
C/F
C/F
1.0 x 10 -1
6.1 x 10 -2
1.1 x 10 -3
1.4 x 10 -3
7.8 x 10 -2
5.5 x 10 -1
2.0 x 10 -3
4.4 x 10 -2
5.4 x 10 -4
1.5 x 10 -3
Trespasser
Trespasser
Youth
Youth
C/F
C/F
C/F
C/F
6.4 x 10 -4
3.8 x 10 -4
3.4 x 10 -4
2.0 x 10 -4
3.1 x 10 -3
3.7 x 10 -2
1.3 x 10 -3
9.3 x 10 -3

-------
                                          Table 11

                          Robintech, Inc. / National Pipe Co. Site
                                         Vestal, NY

                      EPA and New York State Maximum Contaminant Limits
Compound
1,1,1-Trichloroethane
Trichloroethene
Toluene
Vinyl Chloride
1,1-Dichloroethene
1,1-Dichloroethane
1,2-Dichloroethene  (total)
Tetrachloroethene
Benzene
Chloroethane
Carbon Tetrachloride
Ethylbenzene
Styrene
Xylene (total)
 EPA (ppb)

   200
     5
 1,000
     2
     7

    70
     5
     5

     5
   700
   100
10,000
New York State (ppb)

    5
    5
    5
    5
    5
    5
    5
    5
    5
    5
    5
    5
    5
    5
Note
Table reproduced from EPA-approved Remedial Design Workplan.

-------
                                   APPENDIX III

                                  ADMINISTRATIVE
                                   RECORD INDEX

06/27/97                     Index Document Number Order                               Page:  1
                             ROBINTECH INC./NATIONAL PIPE CO. SITE Documents

Document Number:  R08-001-0001 To 0007                              Date:  09/20/85

Title:  (Letter describing a site reconnaissance and initial sampling effort at the Robintech site
        in Vestal,  New York)

     Type:  CORRESPONDENCE
   Author:  Ranney, Colleen A.:   Camp Dresser & McKee (COM)
Recipient:  Leong,  Sui:   US EPA

Document Number:  R08-001-0008 To 0083                              Date:  09/01/84


Title:  Preliminary Investigation of the Robintech Site, Town of Vestal, Broome County, New York,
        Phase I, Summary Report

     Type:  REPORT
   Author:  none:  Ecological Analysts
Recipient:  none:  NY Dept of Environmental Conservation


Document Number:  R08-001-0084 To 0111                              Date:  08/01/89

Title:  Work/Quality Assurance Project Plan - Remedial Investigation - Robintech, Inc./National Pipe
        Company, Vestal, New York - Revised

     Type:  PLAN
   Author:  Barker, Frances B.:   Fred C. Hart Associates
Recipient:  none:  US EPA


Document Number:  R08-001-0112 To 0293                              Date:  03/18/88

Title:  Revised Project Operations Plan for the Remedial Investigation of the Robintech, Inc./National
        Pipe Co., Site

     Type:  PLAN
   Author:  none:  Fred C. Hart Associates
Recipient:  none:  none

-------
06/27/97                     Index Document Number Order                               Page:  2
                             ROBINTECH INC./NATIONAL PIPE CO. SITE Documents

Document Number:  R08-001-0294 To 0294                              Date:  02/10/87

Title:  (Letter forwarding the attached Work Plan for the Robintech, Inc./National Pipe Co. site,
        Vestal, New York)

     Type:  CORRESPONDENCE
   Author:  Ranney, Colleen A.:   Camp Dresser & McKee (COM)
Recipient:  Alvi,  M. Shaheer:  US EPA
 Attached:  R08-001-0295


Document Number:  R08-001-0295 To 0507     Parent:  R08-001-0294    Date:  10/10/87

Title:  Work Plan for the Remedial Investigation/Feasibility Study of the Robintech, Inc./National
        Pipe Co.,  Site,  Vestal,  New York

     Type:  PLAN
   Author:  none:   Camp Dresser & McKee (COM)
Recipient:  none:   US EPA


Document Number:  R08-001-0508 To 0763                              Date:  09/23/91

Title:  Draft Remedial Investigation Report - Robintech, Inc./National Pipe Co. Site, 3421 Old Vestal
        Road, Vestal, New York

     Type:  REPORT
Condition:  DRAFT
   Author:  none:   McLaren/Hart Environmental Engineering Corporation
Recipient:  none:   Buffton Corporation
 Attached:  R08-001-0764  R08-001-0982  R08-001-1514  R08-001-1841


Document Number:  R08-001-0764 To 0981     Parent:  R08-001-0508   Date:   04/19/91

Title:  Draft Remedial Investigation Report, Volume I:  Appendix A-D, F-I, and K, Robintech, Inc./National
        Pipe Co. Site

     Type:  REPORT
Condition:  DRAFT
   Author:  none:   McLaren/Hart Environmental Engineering Corporation
Recipient:  none:   Buffton Corporation

-------
06/27/97                     Index Document Number Order                               Page:  3
                             ROBINTECH INC./NATIONAL PIPE CO. SITE Documents

Document Number:  R08-001-0982 To 1513     Parent:  R08-001-0508    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:  R08-001-1514 To 1840     Parent:  R08-001-0508    Date:  04/19/91

Title:  Draft Remedial Investigation Report,  Volume III:  Appendix J, Robintech, Inc./National Pipe
        Co. Site

     Type:   REPORT
Condition:   DRAFT
   Author:   none:  McLaren/Hart Environmental Engineering Corporation
Recipient:   none:  Buffton Corporation


Document Number:  R08-001-1841 To 2179     Parent:  R08-001-0508    Date:  04/19/91

Title:  Draft Remedial Investigation Report,  Volume IV:  Appendix L-R, Robintech,  Inc./National Pipe
        Co. Site

     Type:   REPORT
Condition:   DRAFT
   Author:   none:  McLaren/Hart Environmental Engineering Corporation
Recipient:   none:  Buffton Corporation


Document Number:  R08-002-0001 To 0290                              Date:  12/03/91

Title:  Draft Feasibility Study Report - Robintech, Inc./National Pipe Company Site, Vestal, New York

     Type:   REPORT
Condition:   DRAFT
   Author:   none:  McLaren/Hart Environmental Engineering Corporation
Recipient:   none:  none

-------
06/27/97                     Index Document Number Order                               Page:  4
                             ROBINTECH INC./NATIONAL PIPE CO. SITE Documents

Document Number:  R08-002-0291 To 0291                              Date:  01/25/91

Title:  (Letter forwarding the attached Feasibility Study Work Plan for the Robintech site, Vestal,
        New York)

     Type:  CORRESPONDENCE
   Author:  Barbara,  Michael:  McLaren Hart Environmental Engineering
Recipient:  Granger,  Mark:  US EPA
 Attached:  R08-002-0292


Document 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
Recipient:  none:   US EPA


Document Number:  R08-002-0306 To 0318                              Date:  02/01/92

Title:  Superfund Proposed Plan - Robintech,  Inc./National Pipe Co. Site, Vestal, New York

     Type:  PLAN
   Author:  none:   US EPA
Recipient:  none:   none


Document Number:  R08-002-0319 To 0340                              Date:  10/08/87

Title:  Administrative Order on Consent

     Type:  LEGAL DOCUMENT
   Author:  Daggett,  Christopher J.:  US FPA
Recipient:  norm:   various PRPs


Document Number:  R08-002-0341 To 0341                              Date:  07/18/89

Title:  (Memorandum forwarding the enclosed Preliminary Health Assessment for the Robintech site,
        Vestal, New York)

     Type:  CORRESPONDENCE
   Author:  Nelson, William Q.:  Agency for Toxic Substances Disease Registry (ATSDR)
Recipient:  Kaplan, Dick:  US EPA
 Attached:  R08-002-0342

-------
06/27/97                     Index Document Number Order                               Page:  5
                             ROBINTECH INC./NATIONAL PIPE CO. SITE Documents

Document Number:  R08-002-0342 To 0351     Parent:  R08-002-0341   Date:   06/30/89

Title:  Preliminary Health Assessment for Robintech Site, CERCLA No. NYD002232957, Broome County,
        Vestal,  NY

     Type:  PLAN
   Author:  none:  Agency for Toxic Substances Disease Registry (ATSDR)
Recipient:  none:  none


Document Number:  R08-002-0352 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 Number:  R08-002-0747 To 0747                              Date:  02/21/92

Title:  (Public Notice:)  The United States Environmental Protection Agency Invites Public Comment
        on the Proposed Remedial Alternative for the Robintech Superfund Site, Vestal, Broome County,
        New York

     Type:  CORRESPONDENCE
   Author:  none:  US EPA
Recipient:  none:  Press & Sun Bulletin


Document Number:  R08-002-0748 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 Dept of Environmental Conservation
Recipient:  Callahan, Kathleen C.:  US EPA

-------
06/27/97                     Index Document Number Order                               Page:  6
                             ROBINTECH INC./NATIONAL PIPE CO. SITE Documents

Document Number:  R08-002-0749 To 0811                              Date:  03/18/92

Title:  (Transcript of a Public Hearing)  In the Matter of Robintech, Inc. Superfund Site

     Type:   LEGAL DOCUMENT
   Author:   Noller, Dawn Y.:   Czerenda Court Reporting, Inc.
Recipient:   none:  none


Document Number:  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:   Sidamon-Eristoff,  C.:  US EPA
Recipient:   none:  none


Document Number:  R08-002-0900 To 0914                              Date:  04/01/97

Title:  Superfund Proposed Plan,  Robintech,  Inc./National Pipe Co. Site, Town of Vestal, New York

     Type:   PLAN
   Author:   none:  US EPA
Recipient:   none:  none


Document Number:  R08-002-0915 To 1570                              Date:  / /

Title:  Revised Remedial Design Work Plan, Robintech Inc./National Pipe Co. Superfund Site, Vestal,
        New York

     Type:   PLAN
   Author:   none:  McLaren/Hart Environmental Engineering Corporation
Recipient:   none:  US EPA

Document Number:  R08-002-1571 to 1666                              Date:  / /

Title:  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

Document Number:  R08-002-1667 To 1878                              Date:  08/01/96

Title:  Volume I of II, Draft Remedial Design Investigation Report & Evaluation of Remedial Alternatives

     Type:   REPORT
Condition:   DRAFT
   Author:   none:  McLaren/Hart Environmental Engineering Corporation
Recipient:   none:  US EPA

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                                   APPENDIX IV

                                 STATE IiETTER OF
                                   CONCURRENCE

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                                  APPENDIX V

                             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 guestions 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 aguifer 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

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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 (RI) 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 of Decision indicating that no action was reguired to address on-site soils
for lead.
Comment #2: A guestion 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 freguency of
detection. Also, BEHP is unlikely to travel in the groundwater and has not been detected in the
groundwater downgradient of the Site.

Samples collected as part of the RD investigation were not analyzed for BEHP, since extensive sampling for
BEHP was conducted during the RI 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 guestion 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 reguire
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, eguipped 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).

Comment #7: A commenter asked whether the production wells were acting as conduits for contamination to
migrate downward from the overburden aguifer to the bedrock aguifer. The commenter also asked whether any
plumes were observed in the vicinity of the production wells.

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Response #7: Based on the results of the RI, 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 reguired 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.

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 aguifers 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 RI 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,

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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 aguifer is not usable."  Further, CERCLA moderates
its emphasis on permanent solutions and treatment through the addition of the gualifier "to the maximum
extent practicable" and contains a reguirement for remedies to be cost-effective. Therefore, the findings
of the Proposed Plan, when considered in the context of the reguirements of CERCLA, raise guestions as to
whether CERCLA reguires the selection of Alternative 3 over Alternative 2.

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 aguifer.  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 aguifer below.

The Proposed Plan statement that "no current or future overburden groundwater exposure is possible because
the overburden aguifer 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 aguifer.
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 reguirements 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 reguired 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.

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 reguires 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
NCP, which states that EPA expects to return usable groundwaters to their beneficial uses wherever
practicable.  As previously stated, the bedrock aguifer at the Site is a usable
aguifer.

Shallow Groundwater Contamination

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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 aguifer 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 aguifer. Rather, the casing in PW-2 was determined to be a conduit of water to the bedrock
aguifer 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 conseguences in terms of
contaminant mobility in the overburden aguifer. 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.

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.

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APPENDIX V-a

RESPONSIVENESS SUMMARY

LETTER SUBMITTED DURING THE PUBLIC COMMENT PERIOD

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 Superfund Proposed Plan for Robintech, Inc./National Pipe
Company, Superfund Site, Vestal, New York

Dear Mr. Granger:

Buffton Corporation (Buffton), 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, Buffton wants to make clear that its comments are not intended to challenge the overall
approach of the Proposed Plan. For a number of years, Buffton 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 Superfund 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 Buffton 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 Buffton offers comment or clarification. Each of these
conclusions is discussed below.

1 EPA recently permitted Buffton to begin Site work with the replacement of PW-2.

1. Alternative 3 - Saturated Overburden Soil Excavation and Treatment

EPA's preferred remedy, Alternative 3, reguires 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 2 2, which Buffton supported Although Alternative 3 goes further than CERCLA reguires 3, it
fixes the problems with the previous remedy. Accordingly, Buffton is willing to go forward with
Alternative 3, at substantial additional expense, with the following understandings:

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     a)     EPA Will specify, in the amended ROD that Alternative 3 and the expenditure of the additional
$1 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  Alternative 2 and Alternative 3 are identical with the exception that Alternative 2  does not
          require excavation and treatment of saturated overburden soils and related groundwater.

       3  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 over-burden 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, 1996),
         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 or 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.

       4  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.

     2.     Risk of Drinking Water Contamination

     The primary risk 4 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 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 Buffton 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 aroundwater.

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

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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 aguifer. Rather the casing in PW-2 was determined to be a conduit of water to the
bedrock aguifer 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.

Buffton 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.

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Site

Site name:

Site location:

HRS score:

Listed on the NPL:

EPA ID #

Record of Decision

Date signed:

Operable Unit:

Selected remedy:



Capital cost:

Construction Completion:

0 & M cost:

Present-worth cost
(10 year):

Lead

Primary Contact:

Secondary Contact:


Main PRPs

Waste

Waste type:

Waste origin:

Contaminated medium:
                               RECORD OF DECISION FACT SHEET
                                      EPA REGION II
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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