Five-Year Review Report Town of Vestal, New York

Five-Year Review ReportRobintech, Inc./National Pipe Co. Site

Broome CountyTown of Vestal, New York

Prepared by:

United States Environmental Protection AgencyRegion 2

New York, New York

September 2006

EXECUTIVE SUMMARY

This is the first five-year review for the Robintech, Inc./National Pipe Co. site. The site is locatedin the Town of Vestal, Broome County, New York. Currently, the remedy is functioning as intendedby the decision documents and is protecting human health and the environment.

Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name (from WasteLAN): Robintech, Inc./National Pipe Co. site

EPA ID (from WasteLAN): NYD002232957

Region: 2 State: NY City/County: Town of Vestal/Broom e County

SITE STATUS

NPL Status: O Final G Deleted G Other (specify)

Remediation Status (choose all that apply): G Under Construction O Operating G Complete

Multiple OUs? O YES G NO Construction completion date: September 28, 2001

Are portions of the site in use or suitable for reuse? O YES G NO G N/A

REVIEW STATUS

Lead agency: O EPA G State G Tribe G Other Federal Agency

Author name: Mark Granger

Author title: Remedial Project Manager Author affiliation: EPA

Review period: 09/28/2001 - 09/28/2006

Date(s) of site inspection: June 12, 2006

Type of review:G Post-SARA G Pre-SARA G NPL-Removal onlyG Non-NPL Remedial Action Site G NPL State/Tribe-lead

G Regional Discretion O Policy G Statutory

Review num ber: O 1 (first) G 2 (second) G 3 (third) G Other (specify)

Triggering action:

G Actual RA Onsite Construction at OU #1 G Actual RA Start at OU #

O Construction Completion G Previous Five-Year Review Report

G Other (specify)

Triggering action date (from WasteLAN): 09/28/2001

Due date (five years after triggering action date): 09/28/2006

Does the report include recomm endation(s) and follow-up action(s)? O yes G no

Acres in use or suitable for use: restricted: 0.7 unrestricted: 12

Five-Year Review Summary Form (continued)

Issues, Recommendations, and Follow-Up Actions

The selected remedy, described in three RODs, has been fully implemented. There are ongoing operation,

maintenance, and monitoring activities included in the selected remedy. As was anticipated by the decision

documents, these activities are subject to routine modification and adjustment. Table 3 includes

suggestions for improving, modifying and/or adjusting these activities. New York State requires annual

certifications that institutional controls are in place and that remedy-related operation and maintenance

(O&M) is being performed. Annually, the potentially responsible parties will need to certify that the existing

institutional controls remain in place and that remedy-related O&M is being perform ed. In addition, some

actions may be necessary to maintain site protectiveness in the long term. Table 6 conta ins

recomm endations and follow-up actions which will ensure long term protectiveness, including a follow-up

assessment of the soil-vapor intrusion pathway.

Protectiveness Statement

The implemented actions at this site protect human health and the environment in the short term.

Currently, there are no exposure pathways that could result in unacceptable risks and none are expected,

as long as the site use does not change and the implemented engineered and institutional controls are

properly operated, monitored, and maintained. In order to be protective in the long-term the monitoring

recommendations contained in Table 6 need to be addressed.

I. Introduction

This five-year review for the Robintech, Inc./National Pipe Co. site, located in the Town of Vestal,Broome County, New York, was conducted by United States Environmental Protection Agency(EPA) Remedial Project Manager (RPM) Mark E. Granger. The review was conducted inaccordance with the Comprehensive Five-Year Review Guidance, OSWER Directive 9355.7-03B-P(June 2001). The purpose of five-year reviews is to ensure that implemented remedies protect publichealth and the environment and that they function as intended by the site decision documents. Thisreport will become part of the site file.

In accordance with Section 1.3.2 of the five-year review guidance, a policy five-year review istriggered by the signature date of the preliminary close-out report (PCOR). The trigger for this firstfive-year review is September 28, 2001, the approval date of the PCOR. This five-year reviewprovides background information, covers the site history, discusses past data-collection efforts alongwith information collected in the past five years, re-evaluates risk and remedy protectiveness basedon updated assumptions, and makes recommendations for follow-up actions.

The selected remedy, described in three RODs, has been fully implemented. This five-year reviewcovers the entire site and has determined that the implemented remedy is functioning as intendedand continues to protect human health and the environment.

II. Site Chronology

Table 1 (attached) summarizes the site-related events from discovery to the present.

III. Background

Site Location

Vestal is located within a regionally important industrial center adjacent to Binghamton, New Yorkin the Susquehanna River basin. An estimated 5,350 people live within a one mile radius of the site.The site, which occupies 12.7 acres, is bordered by Commerce Road and several warehouses andlight industrial buildings to the east, Old Vestal Road and several residences to the south, anamusement facility (known as the Skate Estate) and fuel storage tanks (Mobil Tank Farm) to thewest, and by Conrail railroad tracks and Parkway Vending Inc. to the north.

Physical Characteristics

The site is located approximately half-way down the westerly face of a hill that slopes gently towardthe Susquehanna River. Consistent with this, EPA field observations and examination oftopographic contours indicate that the superficial (overland) flow of surface water across the site isto 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.

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The area where the site is located is not known to contain or impact any ecologically significanthabitat, wetlands, agricultural land, or historic or landmark sites.

Site Geology/Hydrogeology

The area has two distinct aquifers. The upper aquifer is comprised of overburden material consistingmainly of gray and brown till which becomes harder with depth. In addition, fill material associatedwith extensive grading on-site for storage and parking space ranges from 0-6 feet. Groundwater wasencountered within the upper aquifer unit 6 to 20 feet below the ground surface. The lower aquiferis shale bedrock with a weathered zone 7 to 10 feet thick. The primary permeability of this materialis low, but the secondary permeability is much higher. Fractures along the horizontal bedding planesand vertical joints in the shale allow for groundwater flow. Groundwater was encountered in thiszone 10 to 60 feet below the ground surface.

Groundwater flow in the study area is primarily toward the west, with minor components trendingto the northwest and southwest, and is recharged from rainfall. There are no private drinking waterwells in the vicinity of the site. All residents are supplied with drinking water by the Vestal wellfields. One of these well fields is located downgradient of the site near the river. Severalinvestigations in the area have indicated that groundwater contamination from the site is notimpacting this area.

Land and Resource Use

The area surrounding the site is commercial, industrial, and residential. Several residences arelocated across Old Vestal Road from the site. Tank farms, a gas station, and a commercialamusement facility are the prominent features in the downgradient area of the site. A railroad right-of-way services the property and separates the site from other side and downgradient areas in thevicinity of the site. With the strong presence of commercial and industrial infrastructure, it is likelythat the site will continue to operate as a manufacturing operation well into the foreseeable future.

With respect to water use, there are no private drinking water wells in the vicinity of the site. Allresidents are supplied with drinking water by the Vestal well fields. None of the wells in the Vestalwell fields are hydraulically affected by site-related contamination.

History of Contamination

Eight production wells were drilled on-site between 1983 and 1984. These six-inch diameter wellswere installed with steel casing through the overburden formation and then finished as open bedrockholes down to an average of 300 feet below ground surface. The eight wells provided cooling waterin the pipe production process, which was then discharged to surface water at a permitted effluentdischarge point. An effluent sample collected at the site by the New York State Department ofEnvironmental Conservation (NYSDEC) in 1984 to verify discharge permit compliance foundorganic constituents that were not covered under the permit. Further investigation resulted in the

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conclusion that the source of the contamination was the groundwater beneath the site. Furtherinvestigations determined that there were three soil source areas in the overburden that wereaffecting groundwater in both the overburden and bedrock geologic units.

Initial Response

Sampling was conducted by EPA in 1985 to provide information for a hazard ranking. Groundwatermonitoring revealed elevated concentrations of volatile compounds in the soil and groundwater.Based on the results of this monitoring, the site was placed on the National Priorities List (NPL) inJune 1986.

Basis for Taking Action

An Administrative Order on Consent under Sections 104 and 122 of the ComprehensiveEnvironmental Response, Compensation, and Liability Act, as amended, 42 U.S.C. §9601 et seq.(CERCLA), for the performance of a remedial investigation and feasibility study (RI/FS) was issuedby EPA in 1987 to General Indicator Group, Inc. (a successor of Robintech), Buffton, BufftonElectronics (now named Electro-Mech, Inc.), and National Pipe Company. General Indicator Group,Inc. subsequently changed its name to CompuDyne, Inc. All of the above parties have beenidentified as Potentially Responsible Parties (PRPs) pursuant to CERCLA. The results of this effortrevealed numerous volatile organic compounds (VOCs) in the overburden and bedrock groundwaterand in overburden soils, most notably 1,1,1-trichloroethane (1,1,1-TCA) and toluene.

IV. Remedial Actions

Remedy Selection

Following the completion of the RI/FS, a ROD (Operable Unit One) was signed (on March 30,1992), selecting extraction of the contaminated bedrock and overburden groundwater.

Soil and sediment investigations in order to assess suspected elevated lead concentrations on boththe site and Skate Estate properties were the subject of a second operable unit. These investigationsdid not reveal any potential health threats. Consequently, a no action ROD was signed for the secondoperable unit in March 1993.

In September 1992, a Unilateral Administrative Order was issued by EPA to the PRPs to design andimplement the selected groundwater remedy. Based upon pre-design investigation related to thegroundwater remedy, it was determined in 1996 that the groundwater extraction and treatmentremedy for the overburden was not appropriate due to the low yields (less than 1 gallon per minute).It was also determined that VOCs that were present in on-site soils were a source of groundwatercontamination. Consequently, a ROD (Operable Unit Three) was signed in March 1997, calling for:

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C excavation of unsaturated and saturated soils in three areas of the site, and treatment forVOCs using low temperature thermal desorption;

C monitored natural attenuation of contaminated overburden groundwater;

C institutional controls to restrict the installation and use of groundwater wells at anddowngradient of the site until groundwater quality has been restored;

• long-term groundwater monitoring; and

• operation and maintenance of the bedrock groundwater extraction and treatment system.

The extraction of the contaminated bedrock aquifer, as called for in the Operable Unit One ROD,remained in place. However, since pumping of the groundwater from the facility’s active productionwells, in combination with VOC losses through the plant’s storage and distribution system, resultedin the effluent discharge being in conformance with NYSDEC State Pollutant Discharge EliminationSystem standards for VOCs since 1984, treatment was determined to be unnecessary to meet surfacewater discharge requirements.

Remedy Implementation

Consent Decree negotiations between EPA and the PRPs to carry out the remedial design (RD) andconstruction of the selected remedy were successfully completed in April 1998. The RD wascompleted in 1999.

The source removal began in 2000 and continued into 2001, with more than 10,000 cubic yards ofVOC-contaminated soil being excavated, treated, and redeposited.

Construction of the bedrock groundwater extraction remedy was also completed in 2001. This workincluded all new pumps, piping, wiring, and instrumentation for the production well system. Itbecame evident shortly after this work was completed that the production wells requiredrefurbishing. This work was completed in 2002 and the system ran well into 2003. A combinationof circumstances, not the least of which being the refusal of the pipe-production facility to continueto use the extracted groundwater in its manufacturing process, forced the system to shut down in2003. In 2005, the system, which included a treatment system, became operational. The system hasrun reliably since that time.

While the release of additional contaminants to the groundwater has been effectively reduced bythese actions, subsequent groundwater monitoring data indicate that site-related contaminants arestill present in the groundwater and that these contaminants are still present downgradient. Whilemonitoring has shown a demonstrable decline over time, and, more importantly, significant declineswith distance from the site, monitoring has also shown that contaminant values in groundwaterremain above standards for VOCs.

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Institutional Controls Implementation

The Operable Unit Three ROD called for the implementation of institutional controls to restrict theinstallation and use of groundwater wells at and downgradient of the site until groundwater qualityhas been restored. These controls were incorporated into the deed in 2006.

Drinking water is provided by public supplies for the entire town, including the affecteddowngradient area.

Operation and Maintenance

The Operation and Maintenance (O&M) Manual for the site contains the procedures for operating,inspecting, and evaluating the bedrock groundwater extraction and treatment system along with thelong-term monitoring of groundwater. Repairs are to be made to the extraction and monitoringnetwork, as necessary, to control the effect of any event that might interfere with the performanceof the remedy.

The site is inspected annually as follows:

C The bedrock groundwater extraction and treatment system is inspected to ensure that it isoperational and that the critical path of groundwater through the carbon has not beentampered with or redirected; and

C Groundwater monitoring wells are inspected for ease of locating, operation of locks,damage/vandalism, and the condition of the surface seals.

V. Five-Year Review Process

Administrative Components

The five-year review team consisted of Mark Granger (RPM), Robert Alvey (hydrogeologist), JulieMcPherson (human health risk assessor), and Mindy Pensak (ecological risk assessor).

Community Involvement

The EPA Community Involvement Coordinator for the Robintech, Inc./National Pipe Co. site,Cecilia Echols, published a notice in the Binghamton Press & Sun Bulletin, a local newspaper, onApril 23, 2006, notifying the community of the initiation of the five-year review process. The noticeindicated that EPA would be conducting a five-year review of the site to ensure that the site isprotective of public health and the environment and that the implemented components of the remedyare functioning as designed. It also indicated that once the five-year review is completed, the results

1 WQSGVs and MCLs are the highest levels of a contaminant that are allowed in drinking water.They are promulgated standards that apply to public water systems and are intended to protecthuman health by limiting the levels of contaminants in drinking water.

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will be made available in the local site repository. In addition, the notice included the RPM’saddress and telephone number for questions related to the five-year review process or the Robintech,Inc./National Pipe Co. site.

Document Review

The documents, data, and information which were reviewed in completing the five-year review aresummarized in Table 2 (attached).

Data Review

Groundwater monitoring data from this five-year review period exceeded NYSDEC Water QualityStandards and Guidance Values (TOGS 1.1.1)(WQSGV) or EPA Maximum Contaminant Levels(MCLs)1 for a number of contaminants in a number of groundwater monitoring wells.

Specifically, the data show that the number of VOCs detected and their concentrations havestabilized at lower levels than previously reported during the RI. This decrease is attributable to thesuccessful soil source removal (more than 10,000 cubic yards excavated down to bedrock)component of the remedy. Currently, while values remain stable, data from the downgradientmonitoring wells show that contamination in groundwater remains above standards.

Site Inspection

On June 12, 2006, a five-year review-related site inspection was conducted by EPA RPM MarkGranger along with technical-team members Robert Alvey and Julie McPherson.

Interviews

No interviews were conducted during the review period.

Institutional Controls Verification

Institutional controls have been verified as being in place as of a March 2006 review of the deed.

With respect to drinking water, the entire town, including the affected downgradient area, hasdrinking water provided by public supplies.Other Comments on Operation, Maintenance, and Institutional Controls

Table 3 (attached) summarizes several observations and offers suggestions to resolve these issues.

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VI. Technical Assessment

Question A: Is the remedy functioning as intended by the decision documents?

The ROD called for, among other things, excavation, treatment, and redeposition of VOCcontaminated source-area soils and bedrock groundwater extraction and treatment. The purpose ofthe excavation component was to reduce the risk to human health and the environment due tocontaminants leaching from the soil into the groundwater. The purpose of extracting and treatingthe contaminated groundwater was to control its migration and assure that groundwater beyond thesite boundary meets Applicable or Relevant and Appropriate Requirements (ARARs) in the shortestpossible time. It is anticipated that groundwater ARARs will be met through the implementation ofthe groundwater remedies (i.e., monitored natural attenuation for the overburden aquifer andextraction and treatment for the bedrock aquifer), thus effecting restoration of groundwater as aresource.

The site is zoned industrial, however, residential properties are located directly sidegradient to theproperty. In addition to the on-site deed restrictions, all residents side and downgradient of the siteare connected to the municipal public supply. Therefore, the exposure pathway via ingestion of thegroundwater has been interrupted. Groundwater use is not expected to change in this area within thenext five years, the period of time considered in this review.

The constructed portions of the remedy appear to be functioning as intended by the RODs,eliminating all potentially-completed and hypothetical exposure pathways; thus, the remedy isprotective.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial actionobjectives used at the time of the remedy still valid?

The selection of contaminants of potential concern (COPCs) and the exposure assumptions used toestimate the potential risks and hazards at the site in the 1991 risk assessment followed acceptableEPA guidance. Although using current guidance may result in some differences in the COPCselection, if the assessment were to be revised using current guidance, the results of the riskassessments and exposure pathways evaluated would still be valid.

The toxicity values for several COPCs have changed since the RI. In order to account for thesechanges in toxicity values, the maximum detected concentrations of COPCs detected in the on-sitemonitoring wells during the sampling period 2001-2006 were compared to their respectiveresidential groundwater Preliminary Remediation Goals (PRGs), MCLs, and WQSGVs. PRGs area human-health risk-based value that is equivalent to a cancer risk of 1 x 10-6 or a hazard index of1. The MCL is the highest level of contaminant that is allowed in drinking water. Both MCLs andWQSGVs are promulgated standards that apply to public water systems and are intended to protecthuman health by limiting the levels of contaminants in drinking water. Note that federal MCLs are

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not applicable with respect to the overburden aquifer as no current or future overburden groundwaterexposure is possible because that aquifer is not usable. In addition, NYSDEC has indicated thatsince 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 atthe site. As the bedrock aquifer is usable, federal MCLs and state WQSGVs remain applicable withrespect to that aquifer.

While levels have generally significantly decreased in the overburden from those seen prior toconstruction of the remedies, most of the constituents detected in the monitoring wells havecontinued to exceed their respective criteria since the initiation of the post-construction quarterlygroundwater-monitoring program (see Table 4, attached). The maximum detected concentration ofTCE, PCE, cis-1,2-DCE, and 1,1-DCE are the only constituents that have exceeded the cancer riskrange or noncancer threshold. The concentrations of VOCs detected in the monitoring wells haveremained consistent since post-construction quarterly sampling was initiated in 2004.

In summary with respect to toxicity values, the toxicity data that were used in the risk assessmentwere valid at the time the assessments were conducted and the use of these data indicated that aremedy was needed. Since then, many of the toxicity values have been changed, generally becomingmore stringent. The result of the changes in toxicity values would have a net effect of increasing theestimated potential risks and hazards, which would also support the decision that the selected remedywould still be needed if an assessment were conducted at this time. Thus, even though toxicityvalues have changed, the resulting remedies that were supported by the older toxicity values are stillvalid.

The remedial action objectives identified in the 1997 ROD as they pertain to the remedy used at thetime are still valid. Additionally, there are no changes in the physical conditions of the site or siteusage that would affect the protectiveness of the selected remedy, and there are no significantchanges in site use expected over the next five years. Excavation and treatment of source area soilsat the Robintech, Inc./National Pipe Co. site has removed direct contact exposures to the public aswell as ecological receptors (i.e., ingestion or dermal contact with soil).

While the remedial action objectives of reaching state and federal groundwater standards have notbeen achieved, this does not affect the protectiveness of the remedy at this time. It is anticipated thatgroundwater standards will be reached in the future. Provision of publicly-supplied drinking water,along with PRP control of the property and local laws, has effectively prevented residents fromcoming in contact with groundwater affected by site-related contaminants.

Soil vapor intrusion was not previously evaluated as a potential future exposure pathway. Based onthe conservative (health-protective) assumption that buildings are located above the maximumdetected concentration of the contaminants of concern in the groundwater; the health based screeningcriteria provided in EPA’s Draft Guidance for Evaluating the Vapor Intrusion to Indoor AirPathway from Groundwater and Soils (USEPA, 2002) was used to initially evaluate this exposurepathway. This guidance provides calculations of concentrations in groundwater associated with

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indoor air concentrations at acceptable levels of cancer risk and noncancer hazard. This reviewcompared the maximum detected concentrations of the chemicals of potential concern with the vaporintrusion screening criteria (see Table 5, attached). The maximum detected concentrations of severalVOCs have exceeded their respective risk-based criteria (1 x 10-6) but did not exceed the upperbound of the risk range (1 x 10-4). Vinyl chloride is the only constituent that exceeded the risk range.This does not indicate that a vapor intrusion problem would occur in buildings located above theplume; it merely indicates that further investigation would be necessary, which includes site-specificconsiderations such as the type of building, the location of the building to the maximum detectedconcentration, and the subsurface characteristics of the site.

Question C: Has any other information come to light that could call into question the protectivenessof the remedy?

Vapor intrusion into indoor air has been identified as a potentially important route of exposure atsites that contain VOCs. It is recommended that this pathway be further evaluated to determine ifthere is a risk to human health.

Some monitoring wells that are not currently sampled may provide relevant groundwater data withrespect to contaminant migration. To ensure that site-related contamination is not migrating off theproperty and that the remedy is functioning as intended, it is recommended that select wells notcurrently being sampled be included in future sampling efforts. It is also recommended thatadditional wells be installed to monitor the migration of contamination in the overburden.

It was identified during this review that 1,1,1-TCA was detected in several wells and is consideredone of the primary COPCs. The compound 1,4-dioxane is used as a stabilizer for chlorinatedsolvents such as 1,1,1-TCA. Because of its unique characteristics (it is highly mobile, highly toxic,and is resistant to biodegradation), 1,4-dioxane has become a concern at many sites. It isrecommended that groundwater samples be analyzed for 1,4-dioxane in addition to the full suite ofVOCs. If it is determined that 1,4-dioxane is a concern at the site, the extraction and treatmentremedy selected for the site should be reassessed in this light.

Technical Assessment Summary

Based upon the results of the five-year review, it has been concluded that:

C The bedrock groundwater extraction and treatment system is operating as designed;

C The monitoring wells are securely locked and functional, with one exception;

C The remedy has prevented residents from drinking contaminated groundwater; and

C No additional measures are needed to protect public health.

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During the five-year review site inspection, it was observed that one monitoring well was unsecured.This well should be secured.

The scope of natural attenuation parameters in the overburden aquifer is insufficient to determinewhether or not monitored natural attenuation is occurring. Natural attenuation parameters shouldbe added to future analytical efforts.

VII. Issues, Recommendations and Follow-Up Actions

The selected remedy, described in three RODs, has been fully implemented. There are ongoingoperation, maintenance, and monitoring activities included in the selected remedy. As wasanticipated by the decision documents, these activities are subject to routine modification andadjustment. Table 3 includes suggestions for improving, modifying and/or adjusting these activities.New York State requires annual certifications that institutional controls are in place and that remedy-related operation and maintenance (O&M) is being performed. Annually, the potentially responsibleparties will need to certify that the existing institutional controls remain in place and that remedy-related O&M is being performed. In addition, some actions may be necessary to maintain siteprotectiveness in the long term. Table 6 contains recommendations and follow-up actions which willensure long term protectiveness, including a follow-up assessment of the soil-vapor intrusionpathway.

VIII. Protectiveness Statement

The implemented actions at this site protect human health and the environment in the short term.Currently, there are no exposure pathways that could result in unacceptable risks and none areexpected, as long as the site use does not change and the implemented engineered and institutionalcontrols are properly operated, monitored, and maintained. In order to be protective in the long-termthe monitoring recommendations contained in Table 6 need to be addressed.

IX. Next Review

The next review is due within five years of the signature date of this report, or before September2011.

Approved:

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Table 1: Chronology of Site Events

Event Date(s)

Manufacturing operation begins 1966

Production wells installed 1983

NYSDEC discovers unauthorized VOCs in discharge 1984

Site placed on National Priorities List 1986

Remedial Investigation and Feasibility Study Administrative Order on Consentwith PRPs

1987

Remedial Investigation/Feasibility Study 1987-1992

OU-1 Record of Decision 1992

Remedial Design/Remedial Action Unilateral Administrative Order with PRPs 1992


Groundwater Remedial Design 1994-1995

Remedial Design Investigation Report 1996


Remedial Design/Remedial Action Consent Decree 1998

OU-1/OU-3 Remedial Design 1999

OU-1/OU-3 Construction start 2000

OU-1/OU-3 Construction completed 2001

OU-1 Bedrock Groundwater Extraction System Start 2001

Bedrock Groundwater Rehabilitation, System Restart 2003

Bedrock Groundwater System Evaluation 2004

Permanent Bedrock Groundwater Extraction and Treatment SystemConstructed and Running

2005

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Table 2: Documents, Data, and Information Reviewed in Completing the Five-Year Review

Document Title, Author Submittal Date

Remedial Investigation/Feasibility Study (McLaren/Hart) 1992

Baseline Risk Assessment (McLaren/Hart) 1994


Remedial Design Investigation Report (McLaren/Hart) 1996


RD/RA Consent Decree 1998

OU-3 Remedial Design (McLaren/Hart) 1999

Remedial Construction Report (Vertex) 2001

Stipulation and Order 2005

O&M Manual (Ground Water Treatment & Technology, Inc.) 2005

EPA guidance for conducting five-year reviews and other guidance andregulations to determine if any new Applicable or Relevant and AppropriateRequirements relating to the protectiveness of the remedy have beendeveloped since EPA issued the ROD.

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Table 3: Other Comments on Operation, Maintenance, Monitoring, and Institutional Controls

Comment Suggestion

Flush-mounted upgradient monitoring well MW-14 was observed to be open andunsecured.

Monitoring well MW-14 should be assessed for internal damageand should be closed and secured.

Due to the presence of 1,1,1-TCA in the groundwater, 1,4-dioxane should beincluded in future analytical efforts.

The sampling plan should be modified to include 1,4-dioxane infuture analytical efforts.

The scope of natural attenuation parameters in the overburden aquifer isinsufficient to determine whether or not monitored natural attenuation is occurring.

The sampling plan should be modified to include monitored naturalattenuation parameters in future analytical efforts.

New York State now requires annual certifications that institutional controls thatare required by RODs are in place and that remedy-related operation andmaintenance (O&M) is being performed.

On an annual basis, the site will continue to be inspected todetermine whether any groundwater wells have been installed atthe site. The annual O&M report should include a certification thatthe institutional controls are in place and that remedy-related O&Mis being performed.

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Table 4: Comparison of the maximum detected concentrations of COPCs detected in the on-sitemonitoring wells to their respective human health risk based screening criteria (Preliminary RemediationGoal), Primary Drinking Water Standard (Maximum Contaminant Level or MCL), and New YorkDepartment of Environmental Conservation Water Quality Regulations (NYSDEC WQR)

COPC

Maximum

Detected

Concentration

(ug/l)

Region 9

Preliminary

Remediation Goal

(ug/l)

Primary Drinking

Water Standard -

MCL

(ug/l)

NYSDEC

WQR

(ug/l)

Location Date

1,2-DCA 4 0.12 (c) 5 0.6 MW-19 1/26/05

1,1,1-TCA 210 3200 (nc) 200 5* MW-7/PE-1 3/28/06

TCE 200 0.028 (c) 5 5* MW-8 3/28/06

PCE 48 0.1 (c) 5 5* MW-8 3/28/06

Benzene 7 0.35 (c) 5 1 MW-5 1/26/05

cis-1,2-DCE 160 61 (nc) 70 5* PE-1 7/19/05

1,1-DCE 79 340 (nc) 7 5* PE-1 7/19/05

chloroethane 100 4.6 (c) 5* PE-1 7/19/05

methyl tert butyl ether 16 11 (c) MW-5 1/26/05

1,1-DCA 580 810 (nc) 5* PE-1 7/19/05

vinyl chloride 35 0.02 (c) 2 2 MW-7 9/21/04

trichlorofluoromethane 8 1300 (nc) 5* PE-1 7/19/05

chloroform 3 0.17 (c) 7 MW-8 7/18/05

Footnotes:(c): Value is based on a Cancer endpoint(nc): Value is based on a Non-cancer endpoint*: Values are defaulted to 5 ug/l

Source:Region 9 Preliminary Remediation Goals (PRGs) are human health risk based screening criteria. This valuesare equivalent to a cancer risk of 1 x 10-6 or a hazard index of 1. Refer to:http://www.epa.gov/Region9/waste/sfund/prg/index.htm

National Drinking Water Standards (MCLs) are legally enforceable standards that apply to public water systems. Refer to: http://www.epa.gov/cgi-bin/epaprintonly.cgi

NYSDEC WQRs are the ARARs established in the ROD. Refer to:http://www.dec.state.ny.us/website/regs/part703.html

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Table 5: Comparison of the Maximum Detected Concentrations of COPCs Detected in the MonitoringWells to Their Respective Vapor Intrusion Screening Criteria

COPC

Maximum Detected

Concentration

(ug/l)

Vapor Intrusion Screening Value

(ug/l)

Vapor Intrusion Screening

Value (ug/l)

Cancer Risk = 1 * 10-6

Noncancer hazard = 0.1

Cancer Risk = 1 * 10-4

Noncancer hazard = 1

1,2-DCA 4 2.3 230

1,1,1-TCA 210 310 3100

TCE 200 5.3 530

PCE 48 1.1 110

Benzene 7 1.4 140

cis-1,2-DCE 160 21 210

1,1-DCE 79 19 190

chloroethane 100 2800 28000

methyl tert butyl ether 16 12000 120000

1,1-DCA 580 220 2200

vinyl chloride 35 0.25 25

trichlorofluoromethane 8 18 180

chloroform 3 8 8

Footnotes:bold: The maximum detected concentration has exceeded the cancer risk range (1 x 10-4)

Source:Vapor Intrusion Screening Values are used for screening purposes. Refer to:http://www.epa.gov/correctiveaction/eis/vapor.htm

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Table 6: Issues, Recommendations, and Follow-Up Actions

IssueRecommendations and

Follow-Up ActionsParty

Responsible

Over-sight

Agency

Mile-stoneDate

AffectsProtectiveness

(Y/N)

Current Future

A vapor intrusion evaluation needs tobe conducted.

Assess this pathway based oncurrent scientific approaches.

EPA EPA 6/07 N Y

Some monitoring wells not currentlysampled may provide relevantgroundwater data with respect tocontaminant migration.

The sampling plan should bemodified to include the sampling ofthose monitoring wells notcurrently being sampled which aredetermined to provide importantinformation.

PRP EPA 9/07 N Y

Additional overburden monitoringwells are necessary to monitor themigration of contamination in theoverburden.

Install and sample additionaloverburden monitoring wells.

PRP EPA 9/07 N Y

T-7

Table 7: Acronyms Used in this Document

ARAR Applicable or Relevant and Appropriate Requirement

EPA United States Environmental Protection Agency

FS Feasibility Study

MCLs Maximum Contaminant Levels

µg/l Micrograms per Liter

NPL National Priorities List

NYSDEC New York State Department of Environmental Protection

O&M Operation & Maintenance

PRG Preliminary Remediation Goal

PRP Potentially Responsible Party

RD Remedial Design

RI Remedial Investigation

ROD Record of Decision

RPM Remedial Project Manager

VOCs Volatile Organic Compounds

WQSGV Water Quality Standards and Guidance Values