OVERVIEW OF
ENVIRONMENTAL POLLUTION IN THE
NIAGARA FRONTIER,
NEW YORK
March 1982
James Vincent
Arthur Franzen
         U.S. Environmental Protection Agency
         Region 5, Library (PL-12J)
         77 West Jackson Boulevard, 12th Floor
         Chicago, IL  60604-3590
UNITED STATES  ENVIRONMENTAL PROTECTION AGENCY

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                ACKNOWLEDGEMENT
This  report  was  prepared  at  the  National  Enforcement
Investigations  Center, Denver,  Colorado.

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                                 CONTENTS


EXECUTIVE SUMMARY  	      1

   I  INTRODUCTION 	      9

  II  SUMMARY OF FINDINGS	     13
       ENVIRONMENTAL CONDITIONS  	     13
       SOURCES OF CHEMICAL SUBSTANCES  	     19
       ENVIRONMENTAL CONTROL PROGRAMS  	     32

 III  BACKGROUND	     37
       DESCRIPTION OF STUDY AREA	     37
       PREVIOUS STUDIES  	     44
       STUDY METHODS	     46

  IV  ENVIRONMENTAL CONDITIONS 	     51
       INACTIVE HAZARDOUS WASTE DISPOSAL SITES 	     54
       FISH CONTAMINATION	     55
       WATER QUALITY	     63
       AIR QUALITY	     94
       RADIOLOGICAL ASPECTS  	    100

   V  SOURCES OF CHEMICAL SUBSTANCES 	    101
       POINT SOURCES	    101
       NON-POINT SOURCES 	    105
       DEVELOPMENT OF AN INVENTORY OF POINT SOURCES  	    108

  VI  MAJOR SOURCES OF CHEMICAL SUBSTANCES,
      BUFFALO-LACKAWANNA SUBAREA   	    129
       INDUSTRIAL POINT SOURCES  	    129
       MUNICIPAL POINT SOURCES 	    140
       NON-POINT SOURCES 	    141

 VII  MAJOR SOURCES OF CHEMICAL SUBSTANCES,
      TONAWANDA-NORTH TONAWANDA SUBAREA  	    147
       INDUSTRIAL POINT SOURCES  	    147
       MUNICIPAL POINT SOURCES 	    160
       HAZARDOUS WASTE DISPOSAL SITES  	    161
       NON-POINT SOURCES 	    162

VIII  MAJOR SOURCES OF CHEMICAL SUBSTANCES,
      NIAGARA FALLS SUBAREA  	    163
       INDUSTRIAL POINT SOURCES  	    163
       MUNICIPAL POINT SOURCES 	    179
       HAZARDOUS WASTE MANAGEMENT FACILITIES 	    181
       NON-POINT SOURCES 	    185

  IX  ENVIRONMENTAL CONTROL PROGRAMS 	    187
       ENVIRONMENTAL STANDARDS 	    187
       ENVIRONMENTAL MONITORING  	    190
       REGULATION OF WASTEWATER DISCHARGES 	    192
       REGULATION OF HAZARDOUS WASTES  	    196

REFERENCES	    201

BIBLIOGRAPHY 	    211
APPENDIX

SELECTED WATER QUALITY OBJECTIVES FROM THE INTERNATIONAL JOINT
COMMISSION, GREAT LAKES WATER QUALITY AGREEMENT OF 1978

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                                  TABLES

 1   Multi-Media Ratings  of Major Industrial  Sources  of
       Chemical  Substances  	    21
 2   Major Wastewater Discharges  of  Priority  Pollutants   	    22
 3   Hazardous Waste Disposal  Sites  of  Concern  Not at Major
       Industrial  Plants  	    27
 4   PCBs and Organochlorine Pesticides Changes in Young-of-the-Year
       Spottail  Shiners Samples  at Niagara-on-the-Lake,  Ontario   ....    58
 5   PCBs and Organochlorine Pesticides in  Young-of-the-Year
       Spottail  Shiners - 1980	    60
 6   Public Drinking Water  Supplies   	    73
 7   Comparison  of Concentration  of  Some  Trace  Organics  Detected
       in Treated Water at  Municipal  Intakes  with  Suggested Drinking
       Water Limits	    76
 8   Mean Annual Concentration of Trace Metals  in  Water  Samples
       Collected in the Niagara River at  Niagara-on-the-Lake
       and in Lake Ontario  at the Mouth of  the  Niagara River
       during 1975-1980  	    83
 9   Percentage  of Weekly Water Samples Violating  1978 Agreement
       Objectives in the Niagara  River  at Niagara-on-the-Lake
       during 1975-1980  	    84
10   Mean Concentration of  PCBs,  Pesticides,  Arsenic, Cyanide
       and Heavy Metals in  Niagara River  Surface Water during 1980 ...    85
11   Summary of  1979 Upper  Niagara River  Mean Trace Metal  Data
       (Water)	    86
12   Summary of  1979 Organic Contaminants Data  in  Upper  Niagara
       River Water Samples	    87
13   Summary of  Trace Element Concentration in  Suspended Sediment
       at Niagara-on-the-Lake  	    88
14   Mean Concentrations of Organic  Contaminants in Suspended
       Sediment  at Niagara-on-the-Lake  -  1980	    89
15   Summary  of  1979 Environment Ontario  (MOE) Analytical  Results for
       PCBs,  Organochlorine  Pesticides,  Chlorophenoxy  Acid  Herbicides
       and Chlorophenols, Arsenic and Heavy Metals in Niagara River
       Bottom Sediments  	    91
16   PCBs  and Organochlorine  Pesticides  Accumulated  by  Freshwater Clams
       (Elliptic complanatus) After  16  Day's  Exposure -  1980  	    92
17   Heavy Metals and Arsenic in  Attached Filamentous Algae
       (Cladophora sp.) - 1980	93
18   Wastewater  Discharge Rating  Criteria  	   Ill
19   Air Emission Ratings	114
20   ICS Rating  Criteria	114
21   Hazardous Waste Management Rating  Criteria  	   117
22   Site Contamination Rating Criteria  	   118
23   Multi-Media Ratings of Major Industrial  Sources  of
       Chemical  Substances  	   119
24   Major Wastewater Discharges  of  Priority Pollutants   	   122
25   Hazardous Waste Disposal  Sites  of  Concern  Not at Major
       Industrial Plants 	   125
                                  FIGURES

1    Locations of Major Point Sources of Chemical  Substances  	    23
2    Hazardous Waste Disposal Sites of Concern  	    28
3    Study Area	    38
4    Niagara River Biomonitoring Locations - 1980  	    59
5    Public Drinking Water Supply Intakes 	    74
6    Niagara River Water Quality Monitoring Locations - 1979/80 ....    80
7    Niagara River Bottom Sediment Sampling - 1979  	    81
8    PCB Concentrations in Surface Sediments of Lakes Huron,
     Erie, and Ontario	    95
9    Mirex in Sediments of Lake Ontario - 1968	    96
10   Locations of Major Point Sources of Chemical  Substances  	   120
11   Hazardous Waste Disposal Sites of Concern  	   126
12   Lackawanna Area	   130
13   Buffalo River - Buffalo Harbor Area  	   134
14   South Portion of Tonawanda Area	   148
15   North Portion of'Tonawanda Area	   155
16   East Niagara Falls Area	   164
17   Niagara Falls Industrial Area  	   166
18   North Niagara Falls Area	   177
19   Lake Ontario Ordinance Works 	   184

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                             EXECUTIVE SUMMARY
     A multi-media study  of  the occurrence of chemical substances  in the
environment of the western New  York area  (Erie and Niagara Counties), com-
monly called  the Niagara  Frontier,  was  conducted  from August through
December 1981.  The study primarily concentrated on the Buffalo and Niagara
Falls urban areas.   Available  information in published literature  and in
State and  Federal  agency  files  was compiled by an extensive computerized
literature search and manual  file review.

     This  report provides  an objective overview of the available informa-
tion on environmental conditions, sources of chemical substances, and regu-
latory programs  to control these substances.  The report focuses primarily
on the specific group of chemical substances which are commonly called toxic
substances — those  substances  which pose a potential or actual hazard to
human health  when present  in relatively small quantities or low concentra-
tions.  Because  the  term  "toxic substances"  is often  used indiscriminately
to describe a wide  variety of  chemical substances, many of which may not
pose a hazard, the report  uses  specific terminology keyed to environmental
laws whenever possible  to identify the substances present in the environ-
ment.

     Specific objectives of the study were:

     1.    Define present  environmental  conditions and associated trends.

     2.    Define major  sources  of  chemical  substances that impact environ-
          mental  conditions.

     3.    Define remedial  measures and programs to control  chemical
          substances.

     4.    Define any additional  or revised measures  or programs that are
          needed to  adequately  manage  chemical  substances and meet inter-
          national  environmental objectives.

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ENVIRONMENTAL CONDITIONS

     Air and water quality have improved markedly during the past 10 years.
Present ambient conditions compare favorably with criteria defining accept-
able quality.  Most  air and  water contaminants occur at levels well below
established regulatory limits at most locations.

     Although general environmental  quality  has  improved, inadequate con-
trols on releases  of chemical  substances to the  environment  in the past
have resulted in several environmental  conditions of concern:   (1) the move-
ment of chemical  substances  into the environment from  inactive  hazardous
waste disposal sites, (2) the presence of low levels of chemical substances
in public drinking water supplies, and (3) the contamination of sports fish
resulting in restrictions on consumption of fish.

     At a number  of  inactive hazardous waste disposal sites, chemical  sub-
stances have  seeped  out of the  disposal area into surface and  groundwaters
and  have contaminated the surrounding environment.   This occurred because
large volumes of hazardous wastes were disposed of in the past in dumps and
landfills which were not adequately designed, constructed, or maintained to
provide secure containment of the concentrated chemical  substances present.
Remedial measures  have  eliminated some but not all  of the more serious en-
vironmental contamination.

     The quality of drinking water obtained from the Niagara River and east-
ern  Lake Erie and supplied to  more than a million persons meets  applicable
U.S. and Canadian drinking water criteria designed to protect  human health.
Drinking water criteria  have not been established for several organic  chemi-
cals detected on occasion at trace levels in some supplies.

     Comparison of  the  City of Niagara Falls water supply with other  U.S.
cities using  river water  indicates that the Niagara Falls supply is of bet-
ter  chemical  quality than many.  Other New  York  and Ontario  supplies  ob-
tained from the Niagara  River also compared favorably in quality.

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     Contamination of sport fish in Lake Ontario and the Niagara River with
DDT, mercury,  polychlorinated biphenyls  (PCBs),  and mirex has declined
markedly (30 to  90%)  over the past 5  to  10  years.   However,  the PCB and
mirex contamination, coupled  with  recently detected dioxin contamination,
is considered  serious  enough  that  health advisories have  been  issued by
both New York and Ontario that limit consumption of the fish.   This contami-
nation results from bioaccumulation of persistent chemical  substances pres-
ent in the water and sediments.

     Extensive monitoring of chemical  substances in surface waters over the
past 3 years indicated that average water quality meets New York water qual-
ity standards and international  water quality objectives established by the
International Joint Commission.   Some substances occasionally exceed maximum
limits.  Water quality standards have  not  been  established for  a  number of
chemical substances observed in the Niagara River.

     Although water quality met the objectives, the Niagara River continues
to be  a major  source of  PCBs, pesticides,  heavy metals, and other persist-
ent chemical substances present in suspended sediments discharged into Lake
Ontario.

SOURCES OF CHEMICAL SUBSTANCES

     Industrial manufacturing plants are the most important sources of chem-
ical substances  in  the Niagara  Frontier.   The plants release chemical  sub-
stances to  the environment in wastewaters that are discharged directly to
surface waters or indirectly through municipal  wastewater treatment plants,
in  spills  and  leaks at plant sites that  contaminate surface runoff  and
groundwater, in  the  disposal  of hazardous wastes,  and  in  air emissions.

     There are 33  major  industrial sources of  chemical substances  in the
study area.  These  sources were selected by the use of multi-media rating
criteria that  evaluated  the relative  significance of releases of chemical
substances from several hundred industrial plants.

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     Fifteen major industrial  wastewater dischargers in the study area col-
lectively discharge about 95% of the total  direct industrial  discharge of
priority pollutants.*  In a total  flow of 460 mgd, these 15 sources dis-
charge daily maximum loads of  558 Ib of organic priority pollutants, 237 Ib
of total phenols, and 682 Ib of heavy metals.

     Four municipal wastewater treatment plants that receive major flows of
industrial wastes are estimated to discharge about 90% of the chemical sub-
stances discharged by municipal plants in the study area.   In a flow of 268
mgd, these  four  plants  discharge about 328 Ib of organic priority  pollu-
tants, 525 Ib of phenols, and  566 Ib of heavy metals.

     The City of Niagara Falls wastewater treatment plant  is  the largest
point source of chemical substances, discharging about 800 Ib/day of prior-
ity pollutants.   Failure of activated carbon beds in 1978 has resulted in
inadequate treatment of  industrial  wastes.   Reconstruction of the beds in
1983 is  expected to reduce  the discharge of priority  pollutants by about
70%.

     Canadian industrial  and  municipal  wastewater discharges tributary to
the Niagara  River are  reported to collectively discharge  about 23  Ib of
organic  priority pollutants,  3 Ib of phenols, and  156 Ib of heavy  metals
daily in a flow  of 62 mgd.

     Inadequately contained hazardous wastes at inactive disposal sites are
believed to  be major sources  of  chemical  substances transported to  surface
waters  by  contaminated  groundwater  and  surface  runoff.  There  are 155 dis-
posal sites  within 3 miles of the Niagara River.   Sixty-eight  of these are
at  the  33  major industrial  sources.  Contributions of chemical substances
from these sites are not quantified.
*  Priority pollutants are the specific group of toxic pollutants defined
   by Sec. 307 of the Clean Water Act.

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     There are  two major regional hazardous waste  management facilities
(CECOS and SCA) in the  study area.  Extensive multi-media monitoring indi-
cates these facilities release only small amounts of chemical substances to
the  environment consistent  with  current hazardous  waste   management
technology.

     Estimated total  discharges  of organic priority pollutants and phenols
from industrial and  municipal  point sources were in the same range as the
observed loads at  the mouth of the Niagara River.  Estimated point source
discharges of heavy metals were only about 5% of the river load.

     Groundwater contaminated  by spills  and leaks of chemicals at indus-
trial plants and by  inadequate hazardous waste  disposal  is  a major non-
point source of chemical  substances transported  to  surface waters.  Infil-
tration of contaminated groundwater  into industrial and municipal sewers
and  into  industrial  water supply wells may account for about half of the
organic priority pollutants discharged by point sources.

     Bottom sediments contaminated with  PCBs, mercury, DDT,  and other per-
sistent chemical substances were dredged  from the Buffalo River and Harbor
in the past  and  disposed of in shallow Lake Erie waters.   Resuspension of
this dredged spoil  during major storms on Lake  Erie may be  a significant
non-point  source of  suspended  sediments contaminated with chemical
substances.

ENVIRONMENTAL CONTROL PROGRAMS

     Environmental  control programs administered by the New  York  State De-
partment of Environmental Conservation, the Environmental  Protection Agency,
the Ontario Ministry  of the Environment, and Environment Canada have been
effective in achieving  major improvements in environmental quality.  These
programs have achieved  a high  degree of  control  over traditional air and
water pollutants and are now concentrating on control  of chemical  substances.
Control  methods include establishment  of environmental  standards, ambient
and point source monitoring, permit programs,  and enforcement actions.   The

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International Joint Commission and the American-Canadian Niagara River Tox-
ics Committee assist in coordination of programs  between the two countries.

     Comprehensive limits on priority pollutants  consistent with best avail-
able technology (BAT)  are  needed in State Pollutant Discharge Elimination
System (SPDES) permits to achieve adequate control of chemical substances.
These permits are  the  principal  means of controlling releases of chemical
substances to surface waters in industrial and municipal wastewaters.  Pre-
sent SPDES permits contain only a few such limits.

     Issue of a comprehensive  SPDES permit to the  City of Niagara Falls
wastewater treatment plant  is  a  high priority need  because  of the large
volume of priority  pollutants  discharged and the need  for treatment and
sewer system  improvements.  High priority SPDES permits for  industrial fa-
cilities  include  Ashland Petroleum,  Bethlehem Steel,  Donner-Hanna Coke,
DuPont (Niagara Falls), Hooker Chemical (Durez and Niagara Falls), National
Steel (Hanna  Furnace), 01 in,  Republic Steel, and Spaulding  Fiber.   These
industries should achieve the majority of expected reductions in discharges
of priority pollutants when BAT permit limits become effective.

     Revision of the New York water quality standards to include additional
chemical  substances  consistent with  international water quality  objectives
is needed to provide a basis for establishing wastewater discharge permit
limits.    Present  standards  do not include several  chemical  substances of
concern in the Niagara River.

     Litigation pursued  by  the Environmental  Protection Agency and the New
York Department of Environmental  Conservation against  owners  of inactive
hazardous waste disposal  sites  which have caused environmental contamina-
tion has  resulted in remedial actions to abate hazards  at  several  key sites.
Long-term remedial  actions  are being negotiated  at  major  sites.   Voluntary
remedial  action by  site owners has been performed to remove actual or poten-
tial environmental  hazards  at a number  of sites.   Site investigations to
determine the need  for additional remedial actions are  continuing.

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     Operating permits issued to the two large active hazardous waste dis-
posal sites by the Department of Environmental Conservation contain strin-
gent operating  and monitoring  requirements  that should assure adequate
environmental  protection.  All  hazardous waste generators and transporters
and operators of hazardous waste treatment,  storage or disposal facilities
are required to meet comprehensive requirements now being implemented which
were promulgated under the Resource Conservation and Recovery Act.

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                             I.   INTRODUCTION

     A variety of environmental problems  in the Niagara Frontier have been
publicized with increasing frequency in the past few years.   Love Canal, an
inactive hazardous waste disposal site that exposed the occupants of adja-
cent homes to chemical substances, focused national and international  atten-
tion on the area in 1978.   The Love Canal  incident resulted in an accelera-
tion of the already numerous investigations of the environmental effects of
past and present hazardous waste disposal  practices, of releases of chemical
substances from industrial plants, of the quality  of public drinking water
supplies and of the  contamination of fish in Lake Ontario and the Niagara
River.  These  investigations  have been and are being conducted by  local,
State and  Federal agencies, municipalities, industrial companies, environ-
mentalists, public interest groups  and (because the Niagara  River  is  an
international boundary) the Canadian government.

     Ironically, this  concern about  the  effects of chemical  substances on
Niagara Frontier residents and the environment comes at a time when environ-
mental pollution control  programs have achieved major improvements in air
and water  quality.   There  are understandably many  doubts in  the minds  of
area residents concerning the  safety of the water they drink,  the fish they
catch and  the  very  environments of their homes and workplaces.   There are
also concerns  among  regulatory  agencies  of both countries with respect to
the pace of environmental  improvement,  the continuing adverse  publicity and
the adequacy of existing  scientific  knowledge and  regulatory programs  to
effectively achieve control of chemical substances.

     Much of the emotional response to public announcements concerning  the
presence of chemical  substances  in any environmental media is  due to a lack
of understanding concerning the  significance of the levels detected.  Recent
improvements in analytical techniques  now make it possible to detect some
chemical  substances  at very low levels, well below  the levels at which  the
substance might cause  harmful effects.   Thus,  because a substance  can  be
detected does not  necessarily  mean it is  a hazard.

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       This  report  is  the result of a multi-media  study,  initiated by the
  National  Enforcement  Investigations  Center  (NEIC) in August  1981,  of  the
  occurence of chemical substances in the environment of the Niagara Frontier.
  The  report  provides  an objective overview of the available information on
  environmental  conditions,  sources of  chemical  substances and regulatory
  programs  to  control  these substances.   The report, as well  as the study
  were designed to meet the following objectives:

  1.   Define present environmental conditions and any identifiable trends as
       characterized by  the quality of ambient air, surface waters, ground-
       waters, and  drinking water  supplies  and  by biological data  on  aquatic
       life  including contamination of edible fish.
  2.   Define major  sources of chemical  substances  that  impact  environmental
       conditions.
  3.   Define  past,  present,  and proposed future remedial  measures and pro-
       grams for control  of chemical substances.
  4.   Define  any  additional  remedial  measures and/or programs or revisions
       of  existing  programs that appear to be  needed  to adequately manage
       chemical  substances  and meet international environmental objectives.

       The  report  focuses primarily on toxic  substances, those  chemical  sub-
  stances which pose a substantial potential or actual hazard to human health
  or  the environment when present  in relatively small  quantities or low  con-
  centrations.  The  term  "toxic  substances" is often used indiscriminately to
  describe  a wide variety of  chemical  substances, many of which may not  pose
  a  hazard but are perceived  to pose a hazard.   Various  references discussed
  in  this  report use the term "toxic substances"  in a  broad context;  in  such
  discussions, the  term  is used in  the  context explicitly  expressed  in  the
  reference.  Whenever possible, however, the report uses specific terminology
  keyed  to  environmental  laws  to identify the substances present in the  envi-
  ronment.   For  example, when discussing  wastewater discharges or surface
  water  or groundwater,   "priority pollutants"  refers to the group of 65  or-
  ganic  and inorganic  chemical  substances and heavy metals classified  as

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                                                                             11
toxic pollutants*.  "Hazardous wastes,"  another term frequently misused,
in this report refers  to specific types of industrial, municipal and commer-
cial solid or liquid wastes that have been identified as hazardous  wastes by
EPA** or New York State***.

     Geographically, the study concentrated on the Buffalo and Niagara Falls
urban areas.   The broader study area encompassed the western New York coun-
ties of Erie  and  Niagara (commonly called the Niagara Frontier) and, to a
limited extent, the adjacent  eastern portion of the Regional Municipality
of Niagara Falls in the Canadian Province of Ontario.

     The scope of  the  study consisted of evaluating of available data and
information compiled from  the  published literature and from local, State,
and Federal regulatory  agency  files.   A  substantial  data  base existed from
studies conducted  before the  Love Canal incident.   Studies  subsequent to
Love Canal provided specialized data on  sources of chemical  substances and
related environmental  effects.   New data from ongoing studies and  routine
regulatory activity continued to become available during the course of this
study and were incorporated into this report.

     Section  II summarizes  the findings of this  study  including the most
significant environmental problems, the causes or sources of these  problems,
existing environmental  control programs,  and needed program revisions and
additions.   Background data are presented in Section III including  a descrip-
tion of the study area, condensed descriptions of selected previous studies
and a summary of study methods.
  *  Defined by Section 307(a) of the Clean Water Act and listed in 40 CFR
     Part 401.15.
 **  Identified in lists promulgated under Section 3001 of the Resource Con-
     servation and Recovery Act (RCRA) of 1976 and codified in 40 CFR Part 261.
***  Identified in lists promulgated under Section 27-0903 of the New York
     Environmental Conservation Law.

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12
       Environmental conditions  are  summarized  in Section IV.  Conventional
  air  pollution  parameters  are used to define present  air quality  and  show
  trends.  Data developed by a variety of short-term studies and by long-term
  monitoring by Canadian agencies that document levels of chemical substances
  in surface waters are summarized.  Areas of known groundwater contamination
  are  discussed.  Contamination of fish with chemical substances and observed
  trends are also discussed.

       There are  a  large  number  of known  or  potential sources  of  potentially
  toxic  chemical  substances in the Niagara Frontier including municipal and
  industrial wastewater discharges,  industrial  air emissions  and hazardous
  waste  disposal sites.  Section V discusses how an inventory of such sources
  was  prepared and major sources identified.

       Sections VI  through  VIII  discuss major sources of chemical substances
  for  each of three study subareas (Buffalo-Lackawanna, Tonawanda-N. Tonawanda
  and  Niagara  Falls).   Chemical  substances handled at the facility, emitted
  to the air, discharged in wastewaters and/or stored, treated or disposed  of
  in hazardous wastes are defined within the scope of available data.

       The final section (Section  IX) discusses State and EPA regulatory pro-
  grams  for  control  of chemical  substances,  their current status  and sugges-
  tions  for additions and modifications.

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                       II.   SUMMARY OF FINDINGS
ENVIRONMENTAL CONDITIONS

     Air and water  quality  in the Niagara Frontier have improved markedly
during the past 10 years.  Present environmental conditions compare favor-
ably with criteria defining acceptable air and water quality.   Most air and
water contaminants occur at levels well below established regulatory limits
at most  locations.   Many chemical  substances that are used or produced in
the area's commerce  are either not detectable in the environment or occur
at trace levels.

     Although general environmental conditions have subtantially  improved,
inadequate controls in the past over releases of chemical substances to the
environment have resulted in several  environmental  conditions of major con-
cern to  the  public  and to environmental  regulatory  agencies.   The three
environmental conditions of most concern are:  (1) the movement of chemical
substances from inadequate hazardous waste disposal sites into the adjacent
environment with  exposure  of  local  residents to potential health hazards,
(2) the  presence  of low levels of chemical  substances  in public  drinking
water supplies, and (3) the contamination of sports fish with elevated lev-
els of chemical substances that has resulted in prohibitions or limitations
on fish consumption.

Environmental Contamination at Inactive Hazardous Waste Disposal Sites

     At a  number  of  inactive  hazardous waste disposal  sites, chemical  sub-
stances have seeped  from the  disposal area  into surface  and groundwaters
and have contaminated  the  surrounding environment.  This occurred because
large volumes of hazardous wastes were disposed of in the past in dumps and
landfills which were not adequately designed, constructed, or maintained to
provide secure containment of  the concentrated chemical  substances present
in the wastes.

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14
     Remedial measures have been taken at the most hazardous  sites  to elimi-
nate health hazards by removing environmental contamination and/or  contain-
ing the wastes.   However,  these are not always long-term  solutions.   At
some sites with  known  environmental  problems, remedial measures have not
been completed.   Other sites with potential  problems  await  detailed investi-
gations to define problems and develop ,a^euidf  measures.

Public Water Supplies

     The quality of drinking water supplies  obtained  from the Niagara River
and eastern  Lake  Erie  and supplied to more  than a million  persons  in U.S.
and Canadian urban areas along the river meets applicable U.S.  and  Canadian
drinking water criteria.  These criteria, based on scientific studies, are
designed to  protect  human health.   The criteria  specify allowable levels
for several chemical substances detected in  the Niagara River and,  on occa-
sion, at trace levels in some treated water  supplies.   The  quality  of public
drinking water supplies is of particular concern because this is the princi-
pal means through which people can be exposed to chemical substances in the
water environment.

     Drinking water  criteria  have  not  been established  for several organic
chemical substances detected on occasion at  trace levels in some water sup-
plies.  EPA  and  the New York Department of  Health are  considering adding
criteria for other organic chemicals.

     Comparison of  the  level  of organic  chemical  substances  in  the City  of
Niagara Falls water supply with other U.S.  cities using river water indi-
cates that the Niagara Falls supply is of better quality than many  of them.
An Ontario  study  of trihalomethanes in 40 surface water supplies  in  that
province in 1977  indicated that the quality  of the Niagara-on-the-Lake sup-
ply  (downstream  of all  U.S. sources of  chemical  substances) was close to
the  median  of  all 40 supplies.  A  1978 New York Department of Health  study
of trihalomethanes in eight water supplies in the study area found that the
range of 0 to 73  ppb observed was below many supplies in other areas of the

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                                                                         15
state and below the 100 ppb average of an EPA national study.   Trihalometh-
anes are chemicals  formed  during water treatment by chlorination of trace
organic chemicals in the incoming water supply.

     The City  of Niagara Falls  regularly  monitors  its  water supply for
trace organic substances.  The City has modified its intake system and also
its  treatment  process (by the addition  of powdered activated carbon to
absorb organic chemicals) following the discovery of chemical contamination
in the  intake  system.   This  contamination is alleged to  originate at an
adjacent hazardous waste disposal site.

     The locations  of public water supply  intakes in the Niagara River and
Lake Erie were  selected to obtain the best water quality available in the
vicinity and avoid  higher  pollutant  levels.   Hydrologic conditions in the
Niagara River,  in  combination  with the  locations of  sources  of chemical
substances,  produce significant  area! differences  in concentrations of
chemical substances in the River.

Fish Contamination

     Adult sport fish  in Lake Ontario and the  Niagara River  are contami-
nated with persistent chemical substances  to the extent that  both  New York
and  Ontario have issued health advisories  that  effectively prohibit or se-
verely  limit fish  consumption.   Substances of most concern  include poly-
chlorinated biphenyls (PCBs), mirex  (a highly toxic pesticide), and dioxin
(a highly toxic  byproduct  of trichlorophenol production).  Contamination
with DDT (an organochlorine  pesticide) and mercury were  problems  in  the
past.

     Contamination  of fish in  the Niagara River and  Lake  Ontario  is  the
result  of  bioaccumulation  of persistent chemical substances  through  the
aquatic food chain.   Point  sources of the five substances of most concern
have been eliminated or, in the case  of mercury, reduced to a nominal  level
consistent with the best available treatment technology.   This has  resulted
in major decreases  (30  to 90%) in  the  levels of contamination in fish over
the  last 5 to 10 years.

-------
16
     Elevated levels of persistent chemical  substances  are present in bottom
sediments throughout much of the area's waterways.  This contamination, in
combination with non-point source contributions such as contaminated ground-
water and landfill leachate, provides a reservoir which continues to supply
contaminated suspended  sediments and  direct  water  contamination in the
Niagara River system and Lake Ontario.   Bioaccumulation of persistent chem-
ical substances can  thus  be expected to remain  a problem that decreases
with time as non-point  sources  are abated and the  sediment  reservoir is
depleted.

Surface Water Quality

     Extensive monitoring of surface waters  over the last 3 years indicates
that average water quality meets New York water quality standards and inter-
national water  quality  objectives  established by the  International Joint
Commission for  protection of beneficial  water uses.   However, concentra-
tions of several substances in specific water samples from the Niagara River
occasionally (less than 10% of the samples)  exceed applicable maximum limits.
Waters of the Niagara River and Lakes Erie and Ontario are used for a vari-
ety of beneficial purposes of which public drinking water supplies and pro-
pagation of aquatic life have the highest water quality needs.

     Although water  quality met the objectives, analyses of  suspended and
bottom sediments  and aquatic  life  indicated that the Niagara  River  contin-
ues to be a major source of chemical substances discharged into Lake Ontario.
Substances of concern transported  on river sediments included PCBs, pesti-
cides, and heavy metals.  There are no water quality objectives specifically
applicable to suspended sediments.   However,  concentrations of these pollu-
tants  in  the suspended  sediments exceeded allowable  limits for disposal  of
dredged spoil in open waters.

     Environmental monitoring detected significant  spatial differences in
concentrations  of  chemical  substances  in the water, sediments, and biota.
Highest  concentrations  were generally  present in the Tonawanda Channel  and
the  Lower  Niagara River.  These data suggested the  presence  of significant

-------
                                                                       17
sources of chemical  substances  along the Tonawanda Channel.   An alternate
interpretation of the  data,  based on hydrologic considerations, suggests
that at least part of  the increased  contamination  in the Tonawanda Channel
may actually originate  in the Buffalo River-Buffalo Harbor area and near-
shore waters of Lake Erie.

     Various special studies have detected localized areas of chemical sub-
stances pollution in small  Niagara River tributaries and the Buffalo River.
This pollution has been related to specific sources such as landfill  leach-
ate in some  cases;  in others, investigations are continuing.  Tributaries
with detected elevated  levels of  chemical  substances include Smokes Creek,
the Lackawanna and  Union  Canals,  and portions of the Buffalo River in the
Buffalo-Lackawanna area, Two Mile Creek in Tonawanda, and Black, Bergholtz,
Bloody Run,  Cayuga,  and Gill  Creeks  in the Niagara Falls area.  Cleanup of
the more seriously contaminated areas, such as Gill Creek, has been completed,

Groundwater Quality

     Groundwater has been contaminated with chemical substances at several
known locations adjacent to or near the Niagara River.   Other areas of con-
tamination will  likely be  found  as  investigations of  inactive hazardous
waste sites continue.

     Groundwater has been contaminated by  spills and leaks of  chemicals at
manufacturing plants and by  improper disposal of hazardous wastes, both at
plant sites and at offsite disposal areas.   Contaminants in the groundwater
thus reflect the broad  spectrum of chemical substances  used  or produced by
area industries.

     The largest known area of contamination extends under most of the Buf-
falo Avenue  industrial  complex  in Niagara Falls.   Chemical  substances in
the groundwater  infiltrate  industrial  plant sewers and are discharged di-
rectly to  the  Niagara  River or are  discharged to  the Niagara  Falls sewer
system.  Groundwater also flows  directly to the river.   This contaminated
groundwater thus is a significant source of chemical substances.

-------
18
     Other known or probable areas of groundwater contamination include the
Hyde Park, Love  Canal,  and 102nd Street landfill areas in Niagara Falls,
portions of the Tonawanda-North Tonawanda industrial  areas,  and the Buffalo
waterfront industrial areas.

Air Qua!ity

     Air quality in  the Niagara Frontier,  as measured by traditional  air
pollution parameters, has  improved  markedly  over the past 15 years.   With
the exception  of a few  stations  in  the industrialized areas of Buffalo and
Niagara Falls,  ambient  air quality is well  below maximum concentration
limits specified in primary air quality standards designed to protect human
health.  At  the  few  stations, air quality only infrequently exceeds  stand-
ards and then by relatively low amounts.

     Available data  on  ambient  levels of chemical substances are limited.
Several studies  have suggested  possible  localized problems related to in-
dustrial emissions of benzo(a)pyrene,  chlorine,  and vinyl chloride.   Con-
trol of these  situations  is being handled on a case-by-case basis by DEC.

Radiological Contamination

     Several sites in the Niagara Frontier were contaminated with low  level
radioactivity  as a result of  Federal  government  activities associated  with
the Manhattan  Project during  World War  II.  Remedial measures have  since
reduced the  contaminated  areas  to four sites.  Uranium ore residues  (tail-
ings)  are  stored at  the Niagara Falls Storage Facility (NFSF) located at
the old Lake Ontario Ordinance  Works  and in  Tonawanda at  a landfill  and  an
industrial site.  Contaminated  earth and debris from remedial measures at
other  sites  are  also  stored at the  NFSF.   Low-level radioactive wastewaters
were injected  into the  groundwater  at a Tonawanda industrial site.

          Recent environmental monitoring indicated that these sites do not
pose any radiological hazard to area residents.  However, the contamination
limits the use of the four  sites and long-term remedial measures are needed.

-------
                                                                       19
SOURCES OF CHEMICAL SUBSTANCES

     Chemical  substances  are released to the environment  of the Niagara
Frontier from numerous point and non-point sources.  Important point sources
include  industrial  manufacturing plants, municipal  wastewater treatment
plants, and  hazardous  waste management and/or disposal  sites.   Important
non-point sources include contaminated groundwater, dredged spoil disposal,
contaminated lake and river bottom sediments, and urban runoff.

Industrial Point Sources

     Industrial manufacturing plants are the most important sources of chem-
ical substances  in  the  Niagara  Frontier.  Because  some  of  these  plants use
or produce  large quantities of chemical substances, the release of some
chemicals into  the  environment  is inevitable and  unavoidable.   These re-
leases occur in industrial wastewaters that are discharged directly to sur-
face waters or indirectly through municipal  wastewater treatment plants,  in
spills and leaks at plant sites that contaminate surface runoff and ground-
water, in the  disposal  of hazardous wastes either at the plant site or at
some other location, and in air emissions.

     There are  several  thousand industrial  facilities  in  the  study area.
Most of  these  use little or no  chemical  substances  or have processes or
products that  result in no  releases of  chemical substances to  the  environ-
ment.  Most  either  have dry processes that generate  no  wastewaters  or dis-
charge small volumes containing minimal chemical  substances to  municipal
sewer systems.   The collective load of chemical substances from these numer-
ous wastewater  sources  is  significant,  but this load is  included  in that
attributed to municipal point sources.

     There are  33 major industrial  sources  of chemical  substances  in the
study area.   These  sources  were selected through the use of a multi-media
rating system that ranked the relative significance of releases of chemical
substances to the environment through air,  water,  and hazardous waste path-
ways for several  hundred  industrial  facilities.   (See  Section V for more

-------
20
detail on the rating criteria.)  In general, these major sources discharge
significant loads  of  chemical  substances (at least  1  Ib/day of organic
priority pollutants and/or heavy metals) in their wastewaters (either di-
rectly to surface waters or through municipal  sewage  systems); emit chemical
substances to the air;  use or produce large  volumes of  chemical substances;
generate, manage, and/or dispose of large volumes of hazardous wastes; and
have significant site  contamination such as  inadequate  hazardous waste dis-
posal sites or groundwater contamination.

     The 33 major  industrial  sources  are listed alphabetically in Table 1
with their associated  ratings.   Their locations  are shown in Figure 1.  The
individual and  total rating  values assigned to each source  indicate the
relative magnitude  of  activities associated with  chemical  substances at
that  source  in  comparison with other industrial  sources.   Higher rating
numbers  are assigned to facilities with higher  relative potential for re-
lease of chemicals to  the environment.   A high total  rating is not a measure
of "good" or "bad" nor does it necessarily indicate the facility has an ac-
tual adverse effect on the environment.

     Fifteen major  industrial  sources listed  in Table 2 were  identified  as
having  the  largest direct discharges of chemical substances to  surface
waters.  The 15 majors are estimated to discharge more  than 95% of the prior-
ity  pollutants  from industrial  point sources.  These sources  discharge  a
total average flow of about 460 mgd.  Based on recent SPDES permit applica-
tions and  EPA and DEC monitoring,  these  sources are  estimated  to  discharge
maximum  loads of  organic priority  pollutants totalling 558 Ib/day.  Total
maximum  discharges  of  heavy  metals and total phenols are estimated at 682
and  237  Ib/day, respectively.

      Improvements in wastewater  treatment or  controls necessary to achieve
effluent  limitations based on  the  best  available  technology  (BAT)  for each
type  of  industry should reduce total discharges of organic priority pollut-
ants  and heavy  metals by more than 50% below reported maximum levels.  These
reductions will  primarily occur at a few sources with  the  largest loads.
Most priority pollutants at  most sources are already discharged at  levels

-------
21
















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-------
22
                                                          Table 2
                                      MAJOR WASTEWATER DISCHARGES  OF  PRIORITY  POLLUTANTS
Facility City
Organic
Flow Priority Pollutants Phenols Heavy Metals
(mgd) (lb/day)a (lb/day)a (lb/day)a
Industrial
Allied Chemical Buffalo
Ashland Petroleum Tonawanda
Bethlehem Steel Lackawanna
Buffalo Color Buffalo
Chevrolet Tonawanda
Donner-Hanna Coke Buffalo
DuPont Niagara Falls
FMC Tonawanda
Hooker Chemical
(Durez) North Tonawanda
Hooker Specialty
Chemical Niagara Falls
National Steel
(Hanna Furnace) Buffalo
01 in Niagara Falls
Republic Steel Buffalo
Spaulding Fiber Tonawanda
Tonawanda Coke Tonawanda
Industrial Subtotal

Buffalo Sewer
Authority Buffalo
City of
North Tonawanda North Tonawanda
City of
Niagara Falls Niagara Falls
Town of Tonawanda Tonawanda
Municipal Subtotal
12.
19.
233
10
23
9.
10.
7.

0.

38.

38.
6.
42.
4.
2.
460


180

9.

64
15
268
2 <1
3 0
65
0
0
8 69
8 69
1 0

7 17

5 100

8 3
8 274
8 2
7 0
6 2
558
Municipal

60d
r|
2 14d
p
252d
2d
328
0.5
2.3
0
OK
55b
25C
2.4
0

119

4

22
4
0
p
1.3C
237


<15d
H
od
b f
510°
od
525
3
242
38
9

id
5
5

4

69

65
8
53
175
5
682

J
520d
H
3d
Ct
42d
ld
566
Hazardous Waste Management
CECOS Niagara Falls
SCA Model City
Hazardous Waste Subtotal

Canadian Industrial and
Municipal Subtotal
SUBTOTAL - Known Point
Sources
Assumed Contribution of Minor
Point Sources
TOTAL
<1
<1
<1


62

791




-------
                                           RlO
                                                                  -N-
                                                                         LEGEND
                                                                    •    INDUSTRIAL POINT SOURCE
                                                                    •    MUNICIPAL POINT SOURCE
                                                                    A    HAZARDOUS WASTE MANAGEMENT FACILITY
                                                                         SOURCE NUMBER SEE TABLE I,
                                                                         FOR IDENTIFICATION
                    LAKE
FIGURE \.   LOCATIONS OF MAJOR POINT SOURCES  OF CHEMICAL SUBSTANCES

-------
 24
meeting expected BAT  limitations.   At  such sources,  no further reductions
are anticipated.

     Many of the major industrial sources also discharge significant loads
of priority pollutants to municipal sewer systems for treatment, primarily
to the  City of Niagara Falls and the Buffalo Sewer Authority.  These loads
are  included  in  those reported  for the major municipal point sources.

Municipal Point Sources

     Four municipal wastewater treatment plants that  receive major flows of
industrial wastes  containing chemical   substances  were designated major
sources.  These four [listed in Table 2] are estimated to collectively con-
tribute more than 90% of  the priority pollutants  discharged by the 20 munic-
ipal wastewater treatment plants serving the study area.

     Based on EPA  monitoring in May and June  1981,  the  four plants dis-
charge  about 328 Ib/day of  organic  priority pollutants, 525  Ib/day of phe-
nols, and 566  Ib/day  of  heavy metals.   These  loads are 59,  222, and 83%,
respectively,  of the  maximum loads  reportedly discharged by major indus-
trial sources.

     The majority  of  the organic priority pollutants and almost all of the
phenols are discharged by  the City of  Niagara Falls  plant.   Key treatment
units of  this plant,  the activated  carbon beds,  have been inoperable since
they failed in 1978.   Reconstruction of the carbon beds is  scheduled for
completion in 1983.  Addition of the beds and other treatment improvements,
coupled with changes  in industrial  loads on the  plant, are expected to re-
duce organic priority pollutant loads  discharged to about 100  Ib/day and
phenols to about 80 Ib/day.

     The Buffalo Sewer Authority plant discharges nearly half  of the re-
ported  heavy metals  from  industrial and municipal sources.  The plant  is
currently experiencing some operation  and maintenance problems, primarily
related to its older primary treatment units and instrument malfunctions in

-------
                                                                       25
recently constructed secondary  treatment  units.   Improvements and repairs
on these units should achieve higher removal of heavy metals but the total
discharged will  remain high because of the large flow discharged.

Canadian Industrial and Municipal Point Sources

     A 1981 Environment  Ontario survey of industrial and municipal point
sources (including two  combined sewer overflows)  tributary to the Niagara
River in Ontario  detected  a total discharge of about 23 Ib/day of organic
priority pollutants and  156 Ib/day of heavy metals.   The organic priority
pollutants were less than 3% of the U.S. point source load while the heavy
metals were about 13% of the U.S. load.

Hazardous Waste Disposal Sites

     Releases of  chemical substances from  inadequately  contained hazardous
wastes at inactive disposal  sites are believed to  be a major source of per-
sistent chemical  substances that are detected at  low levels in the Niagara
River system and  that contribute to fish contamination.  Investigations by
the Interagency Task Force  and  DEC identified 155 hazardous waste disposal
sites within 3 miles  of the Niagara River.  These sites have the highest
potential for contributing  chemical substances to the River.  Although the
sites themselves  are point  sources,  their contributions of chemical sub-
stances through contaminated  surface  runoff and groundwater are analagous
to sources traditionally considered to be non-point sources.

     Monitoring data on surface and groundwater and hydrogeological  assess-
ments have been completed  at  37 sites.  An additional  22 sites are under
litigation, recommended for litigation, or are under investigation.   Detailed
site investigations have been proposed for 73 sites.   Preliminary investiga-
tions indicate the remaining 23 sites do not warrant further investigation.

     Although monitoring and  site data have been obtained on many of the
155 sites, it has not  been compiled into a form that allows definition of
the contributions  of chemical  substances from these sources with the excep-
tion of two commercial  sites.

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 26
     There are two  major  active commercial  hazardous waste disposal  sites
in the study area.   The large CECOS site in  Niagara Falls discharges  process
wastes to the  City  of Niagara sewer system after  extensive pretreatment
including activated carbon columns.   Peripheral  surface drainage from the
site, which  is discharged to the Niagara River, reportedly contains negli-
gible priority pollutants  [Table 2].

     The SCA hazardous waste  disposal  facility at Model City provides ex-
tensive treatment of  process wastewaters before controlled batch discharge
to the Lower Niagara River.   The maximum discharge reported was 5 Ib/day of
heavy metals and less than 1 Ib/day of organic priority pollutants and phe-
nols (based  on a 1  mgd discharge rate).  Only 6 million gal. of wastewater
were discharged in 1981.

     A comparison of  the 155 hazardous waste disposal sites within 3  miles
of the Niagara River with the list of 33 major industrial sources indicates
that 68 of these sites are located at major industrial sources.  Sixty-seven
sites located  at minor industrial  facilities  or other  off-site  locations
have significant potential for release of chemical  substances to the environ-
ment.  These hazardous waste  sites of concern are  listed in Table 3 and
shown in  Figure 2.  No attempt  has been made to rank  the  relative environ-
mental significance of the sites listed in Table 3 because of inadequate data.

Comparison of Point Source and River Loads

     A comparison of the estimated total loads from U.S. and Canadian point
sources with the  reported loads in the Niagara River at its mouth in 1980
indicates that point sources account  for major  portions of the  organic
priority  pollutants  and phenols  in the  river, but  only  a  small  fraction of
the heavy metals.   The 1980 Canadian data indicated that mean organic prior-
ity pollutant  loads in the river increased from about 1,070 Ib/day at  the
inlet to Chippawa Channel to 1,570 Ib/day at the river mouth, an increase of
500  Ib/day.  The  estimated total point source load was 970 Ib/day, 62% of
the  total  river  load at the mouth and 194% of the downstream  increase  in
load.

-------
                                                                         27
               Table 3
HAZARDOUS WASTE DISPOSAL SITES  OF CONCERN
      NOT AT MAJOR INDUSTRIAL PLANTS
Task Force
No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
a See
b A =
c I =
M =
Site No.
103
82
A
162
111
113
£
128
83
6
84
167
207
173
67
21
242
68
85
219
72
39
182
86
136
190
38
137
76
138
140
141
77
93
14
87
81
196
94
95
144
79
147
149
B
201
150
151
100
203
63
62
C
204
206
241
91
208
220
89
160
90
88
2*4
245
40
56
Figure 2
Active, I
a
Site Name
R. P. Adams
Adams Generating Plant
Allied Chemical - Hopkins Street
Altift
Aluminum Matchplate
Anoconda Company
Basic Carbon
Bell Aerospace - Textron
Buffalo Avenue, 52-60 Street
Buffalo Pump Division
Cayuga Island
Chemical Leaman Transit Lines
City of Tonawanda
Empire Waste
Frontier Chemical
Frontier Bronze
Charles Gibson Site
Gratwick Park
Griffon Park
Hartwell Street Landfill
Holiday Park
Hooker - Hyde Park Landfill
Huntly Power Station
Hydraulic Canal
IWS Equipment
Lehigh Valley
Love Canal
Lucidol of Pennwalt
Lynch Park
MacNaughton - Brooks
Manzel Division
Mobil Oil Corporation
Modern Disposal
Nash Road Site
Necco Park (DuPont)
New Road
Niagara County Refuse Disposal
Niagara Frontier Port Authority
Niagara River Site
Old Creek Bed (Dibaco Site)
Otis Elevator
Power Authority of New York
Ramco Steel - Hopkins Street
Robbin Steel
Rodeway Inn
Seaway Industrial Park
Shavco Plastics
Shavco Plastics
Silbergeld Junk Yard
Squaw Island
Stauffer Chemical (Art Park)
Stauffer Chemical (North Love Canal)
St. Mary's School (60th Street)
William Strassman
Tifft Farm
Times Beach
Town of Niagara
Veteran's Park
West Seneca Transfer Station
Whirlpool Site
J.H. Williams (TRW)
Witmer Road
64th Street
93rd Street School
97th Street Methodist Church
102nd Street Landfill (Hooker)
102nd Street Landfill (01 in)
for site locations.
= Inactive
At an industrial plant 0 = Offsite industrial
Municipal
site P = Private site

City
Tonawanda
Niagara Falls
Buffalo
Buffalo
Tonawanda
Buffalo
Niagara Falls
Porter
Niagara Falls
North Tonawanda
Niagara Falls
Tonawanda
Tonawanda
Tonawanda
Pendleton
Niagara Falls
Niagara Falls
North Tonawanda
Niagara Falls
Tonawanda
North Tonawanda
Niagara Falls
Tonawanda
Niagara Falls
Tonawanda
Buffalo
Niagara Falls
Tonawanda
Niagara Falls
Buffalo
Buffalo
Buffalo
Model City
North Tonawanda
Niagara Falls
Niagara Falls
Wheat Field
Niagara Falls
Niagara Falls
Niagara Falls
Buffalo
Niagara Falls
Buffalo
Tonawanda
Niagara Falls
Tonawanda
Tonawanda
Tonawanda
Niagara Falls
Buffalo
Niagara Falls
Lewiston
Niagara Falls
Tonawanda
Buffalo
Buffalo
Niagara Falls
Tonawanda
Buffalo
Niagara Falls
Tonawanda
Niagara Falls
Niagara Falls
Niagara Falls
Niagara Falls
Niagara Falls
Niagara Falls


disposal site


Statusb
I
I
I
A
I
I
I
I
I
I
I
A
A
I
I
A
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
A
I
I
I
I
I
I
I
I
I
I
I
I
A
I
I
I
I
I
I
I
I
I
I
A
I
I
I
A
I
I
I
I
I
I





Typec
P
I
0
P
I
I
I
I
M
I
P
I
M
P
0
I
P
P
M
P
P
0
I
M
I
0
0
I
0
I
I
I
P
M
0
M
M
M
0
0
I
M
I
I
I
P
I
I
I
M
0
0
0
P
P
M
M
M
M
M
I
M
M
0
0
0
0





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28
                           ONTARIO
             LAKE
ERIE
    FIGURE 2.  HAZARDOUS WASTE DISPOSAL SITES OF CONCERN

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                                                                      29
     The estimated phenol  point  source load of 829 Ib/day was larger than
the mean phenol  load  of 680 Ib/day at the mouth of the Niagara River.   An
incremental increase  in the river could not be computed because all phenol
measurements at  the  upstream  location were below  the  detection  limit.

     The estimated total point source  load of 1,495 Ib/day of heavy metals
was less than  5% of  the reported heavy metals  load in the river of more
than 34,000 Ib/day.   The river load is suspect,  however, because about half
the load was for two  metals which were below detection limits in all  sam-
ples.   Because the river flow  is very  large and concentrations of chemical
substances are at very low levels near the detection limit of analytical
methods used, estimates of component loads are subject to significant errors
(±50%  or  more)  due to small  errors in the absolute  value of a sample
concentration.

     Based on  a  mean  river flow of 202,000 cfs, the estimated point source
loads  would  produce  a  calculated  incremental  concentration increase of
0.9 ug/Ji organic priority  pollutants,  0.7 ug/£ phenols, and 1.3 ug/£ total
heavy  metals.  These  concentrations are below the detection limit for most
of the component substances, especially phenols and heavy metals.

Non-Point Sources of Chemical  Substances

     Contaminated Groundwater

     Large areas of the Niagara  Falls industrial  complex, other scattered
smaller industrial sites,  and  several  large inactive hazardous waste dis-
posal  sites are  known  to be underlain  by groundwater contaminated with or-
ganic  priority pollutants  and,  sometimes,  heavy metals.  Other industrial
areas  and  hazardous waste  disposal  sites are suspected of having contami-
nated  groundwater.  Investigations have been proposed to more fully define
this problem.

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 30
     Concentrations of organic priority pollutants in some groundwaters are
several orders  of magnitude  higher  than  current wastewater discharges.
Thus, small volumes of infiltration into industrial  sewers can significantly
increase the load of organic priority pollutants discharged.

     The known  discharge  of contaminated  well  water and engineering esti-
mates of contaminated infiltration to industrial sewers in the Niagara Falls
area indicate that contaminated groundwater is  the source of more than half
of the  organic  priority pollutants present in direct industrial wastewater
discharges in the study area.

     Dredged Spoil Disposal

     Contaminated sediments averaging more than 500,000 ydVyear were dredg-
ed from the  heavily  polluted Buffalo  River, Buffalo Harbor, and Black  Rock
Canal  navigation  channels  and dumped in the shallow open waters of Lake
Erie near  Bethlehem  Steel  until  1968.  Open water disposal of part of the
spoil  continued  until  1972.   These sediments contained elevated levels of
persistent chemical  substances such  as  PCBs, mercury,  and DDT.  These  con-
taminated dredged spoils are exposed to resuspension by wave action in Lake
Erie during  wind storms.   Surface  and littoral  drift currents  in this  area
could move pollutants along shore to the inlet of the Niagara River.

     Dredged spoil is currently disposed of in a large diked disposal area.
Any  organic  priority pollutants  present in the  dredged  spoil  could leach
out  through  the porous  dikes as  the  spoil dewaters.  This potential  source
of chemical  substances has not been defined.

     Current monitoring  locations  in Lake Erie  and  the Upper  Niagara River
are  not designed to  monitor any  residual  pollution  from  the  spoil  disposal
areas  or  from  dredging activity.  The contribution of chemical substances
from spoil disposal  activities (past  and present) is not  defined.

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                                                                       31
     Contaminated Lake and River Bottom Sediments

     Sampling of bottom sediments during the past decade, as well  as recent
sampling, have demonstrated  that large areas of bottom sediments  in Lakes
Erie and Ontario and  in the  slower current areas of the Niagara River have
elevated levels of persistent chemical substances including PCBs,  DDT,  mer-
cury, and mi rex.   The extent to which these sediments may be resuspended by
wave action or high river flow during major wind storms and provide a major
source of suspended sediments contaminated with chemical substances has not
been defined.  The fact that suspended sediment loads in the river increase
during wind  storms  with no  significant surface  runoff strongly  suggests
this possibility.

     Urban Runoff

     Urban runoff contributes  chemical  substances  to the river system by
direct discharges through storm drainage systems and through combined sewer
overflows.   The  urban runoff contains low levels of  heavy-metals,  pesti-
cides, and  other  chemicals  widely used in urban areas and also present in
air  pollution  fallout.   When storm runoff overloads  combined  sewers,  it
also causes  industrial  and  municipal  wastes to be discharged through com-
bined sewer  overflows.  This problem  occurs  in Buffalo, Niagara Falls, and
North Tonawanda.   The contributions of chemical substances in storm drainage
and combined sewer overflows are not defined.

     Summary of Non-point Sources

     Except for  the  well  water and sewer  infiltration  in Niagara Falls,
contributions of chemical substances from non-point sources are not defined.
The  large  loads  of heavy metals  and persistent chemical substances  on sus-
pended sediments in  the river system in comparison to known point sources
strongly suggest non-point  sources  as major contributors.  Additions and
modifications to the current monitoring program are needed to better define
the  significance  of  non-point sources  and to identify possible  control
measures.

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32
 ENVIRONMENTAL CONTROL PROGRAMS

      Environmental programs directed toward  the  control  of chemical sub-
 stances are administered by both American and Canadian agencies at the fed-
 eral and state  (province)  level.   These programs establish environmental
 standards,  conduct extensive ambient and point source monitoring,  and regu-
 late point sources of chemical substances through permit  programs  and other
 means including enforcement actions.  Activities  of the International Joint
 Commission (IJC)  and  the  American-Canadian  Niagara River Toxic Substances
 Committee serve to coordinate activities between  the two  countries.

 Environmental Standards

      New York water quality standards need revision to include criteria for
 all chemical  substances of concern for which recommended criteria exist.
 Such a  revision would provide a basis for assessing present water quality
 for those  substances  and  provide a basis for establishing wastewater dis-
 charge  permit  limits.  Water  quality standards which  specify water quality
 that must  be maintained in the  Niagara  River  and  Lakes Erie and Ontario to
 protect beneficial water  uses have been established  by  the NYDEC.   Water
 quality objectives for specific chemical substances in international  bound-
 ary waters  have been established by the  IJC.  Recommended  water  quality
 criteria have been published by EPA for many priority pollutants present  in
 the Niagara  River system.   The  New York water quality standards are  not as
 comprehensive  or as  stringent as  the  IJC objectives  and EPA-recommended
 criteria.

      Drinking  water  criteria (state and  federal) for additional  organic
 chemical substances  are  needed to  provide a  basis  for evaluating present
 quality  and to  provide additional  protection of public water  supplies.
 Present  criteria do  not contain limits  on some chemical  substances of con-
 cern in the  Niagara River  system.

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                                                                       33
Environmental Monitoring

     A comprehensive  study  of existing ambient data  (water, sediments, and
biota) and  their  relationships  to location, meteorologic, and  hydrologic
factors is  needed  to  better define these  relationships,  help  define the
relative contributions from the various point and non-point sources of chem-
ical substances, and  guide  future monitoring efforts.  Existing data show
large temporal and spatial variations in observed concentrations of chemical
substances.   The comprehensive data evaluation is needed  to identify prob-
able causes  of  these  variations  so that sources can be isolated by future
monitoring and remedial programs or measures developed.

Regulation of Wastewater Discharges

     Issuance of SPDES permits containing  comprehensive limits  on  priority
pollutants  consistent with  best available  technology (BAT) to all  signifi-
cant sources  of such  pollutants is needed  to achieve comprehensive control
of wastewater discharges and reduce priority pollutants from these sources.
Present SPDES permits contain only a  few limits on priority pollutants be-
cause they  were given only limited attention in the early EPA guidelines.
Reissue of expiring permits has been delayed by DEC to allow new EPA guide-
lines containing priority pollutant limits  to be promulgated.

     The new  SPDES permits  should be  developed and issued as soon  as prac-
ticable based on existing data,  DEC development work completed to date, and
EPA effluent  guidelines  program  data.  Early issuance is needed to allow
permittees  time to meet  the July 1,  1984 BAT deadline.  DEC has completed
detailed evaluations of many major sources  of priority pollutants.   EPA has
completed major phases of the effluent guidelines development work.  Avail-
able data should be adequate in many cases  to prepare permits based on best
professional judgment (BPJ) procedures.

     Permits should include provisions requiring the development and imple-
mentation of best management practices (BMPs) when there  is known  or prob-
able contamination of groundwater or  surface runoff  by priority pollutants

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34
     from  leaks  and  spills,  solid or hazardous waste  disposal  practices,  raw
     material storage,  or  other ancillary activities.   The use of BMPs has al-
     ready been  initiated  at  some problem areas.  Clarification of EPA guidance
     and regulations  for BMPs  is needed to facilitate  acceptance by permittees.

          Development of comprehensive  priority pollutants limitations for the
     City  of  Niagara  Falls wastewater treatment plant  permit  is a high priority
     need  because  of  the  large quantity of chemical substances discharged and
     the need for treatment and sewer system improvements.  High priority indus-
     trial wastewater discharge permits  include  Ashland  Petroleum,  Bethlehem
     Steel, Donner-Hanna Coke,  DuPont  (Niagara Falls), Hooker Chemical  (Durez
     and Niagara  Falls), National  Steel (Hanna Furnace),  01 in, Republic Steel,
     and Spaulding Fibre.   These  industries  should achieve the majority of ex-
     pected  reductions  in  discharges of  priority pollutants  when BAT permit
     limits become effective.

     Regulation of Hazardous Wastes

          Operating permits for the two large  active  hazardous waste  disposal
     sites (CECOS  and SCA) issued under DEC's  Part  360 permit program contain
     monitoring  and  operating  requirements  more  stringent than RCRA  Interim
     Status Standards (40 CFR Part 265) applicable to the facilities.   DEC moni-
     toring of these  sites should assure adequate environmental protection until
     final disposal regulations can be promulgated by EPA and RCRA permits issued
     by  EPA  or  DEC.   The present  DEC permits may  contain  requirements  as  strin-
     gent  as  RCRA requirements when promulgated.

           All hazardous waste generators and transporters and operators of hazard-
     ous waste  treatment,  storage,  or disposal facilities, as defined by RCRA,
     must  meet  RCRA  Interim Status Standards (40 CFR Parts 262, 263, and 265).
     These standards  can  be enforced by  EPA or DEC  and provide the basis for
     regulating  generators, transporters,  and  treatment or storage facilities.

           Major  industrial  sources  with high hazardous waste  management  ratings
     in  Table 1 are  candidates for  early  requests for  submission  of Part B RCRA

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                                                                       35
permit applications and  issuance of RCRA permits for treatment and storage
facilities.   These facilities  are  the largest treatment and storage faci-
lities and thus  have  the greatest potential  for release of chemical sub-
stances to the environment.  Permit requirements for treatment and storage
facilities (40 CFR Part  264) have been promulgated and the permit process
can now begin.

     Litigation pursued by EPA and/or DEC against owners of inactive hazard-
ous waste disposal sites which  have caused  environmental contamination  has
resulted in  remedial  actions to abate hazards at several  key sites.   Long
term remedial actions are being negotiated at the major sites.

     EPA and New York State have expended millions of dollars on actions to
mitigate the environmental and cultural effects of the Love Canal and other
disposal sites.  These sites are also under  consideration for additional
cleanup under Superfund financing.

     The DEC program for investigation of inactive hazardous waste disposal
sites has resulted in the voluntary conduct of remedial work by site owners
to remove actual or potential environmental hazards.   Investigation of  re-
maining sites with the higher potential environmental impacts is continuing.

Regulation of Air Emission Sources

     Sources of  emissions of chemical  substances are being reviewed by  DEC
on a case-by-case basis  to define any abatement needs.  Major industrial
sources with high air emission  ratings in Table 1 are  candidates  for early
review in this program.  Sources of chlorine, vinyl chloride, and benzo(a)
pyrene are of the most environmental  concern.

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                                                                       37
                             III.   BACKGROUND

DESCRIPTION OF STUDY AREA

Demography

     The Niagara Frontier  is  the  name commonly given  to  the  western New
York counties of Erie  and Niagara abutting the Niagara River.   These same
two counties comprise  the  Buffalo Standard Metropolitan Statistical Area
(SMSA) and also the Niagara Frontier Air Quality  Control  Region (AQCR).
The Buffalo and Niagara  Falls urban areas dominate  the western edges of
Erie and Niagara Counties, respectively [Figure 3].  The 1980 population of
the SMSA was about 1,243,000, of which about a million were in Erie County.1*
Buffalo, with a population of about 358,000,  is the largest city.2  Buffalo
suburbs account for  an additional 460,000 population.   Populations of the
City of Tonawanda and Town of Tonawanda total about 108,000.

     The City of Niagara Falls is the largest in Niagara County with a popu-
lation of about 71,000.  Suburbs add another 48,000.   The  City of North Tona-
wanda population is about 36,000.   The Buffalo-Lackawanna, Tonawanda, North
Tonawanda, and Niagara Falls urban areas account for about 90% of the popula-
tion of the SMSA.

     For the purposes  of this study, the southeastern two-thirds  of Erie
County was excluded because it has a small population, has little industrial
development, and exerts little influence on environmental  conditions in the
study area.  For similar reasons,  the eastern two-thirds of Niagara County,
including  Lockport,  was  excluded.   Lockport  has significant industrial  de-
velopment  and hazardous  wastes  from the study area have been disposed  near
there.   However, air emissions  generally  do not affect the study area and
water pollutants  are tributary to  Lake Ontario  rather than the Niagara
River.   The  Canadian communities of Fort Erie,  Wei land,  Niagara  Falls,
  *  Superscripts refer to specific sources of information listed in the
     References section at the end of this report.

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38
      Figure  3.   Study  Area

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                                                                       39
Queenston, and Niagara-on-the-Lake in the Regional Municipality of Niagara
Falls were included  because  they are tributary to the  Niagara River and
generally upwind of  the  study area.   Study area  boundaries  are  shown in
Figure 3.

Hydrology

     Lakes Erie and  Ontario  and the Niagara River are  the dominant water
features.  Lake Erie  is  a relatively shallow basin  with  a  mean depth of
about 90 ft.   The bottom slopes gently from shore with the 30 ft depth con-
tour about a  mile  offshore.   In the Buffalo Harbor area,  water depths are
greater in the dredged channels near shore.

     Lake Erie is subject to sudden storms because of its  position with re-
spect to  storm tracks.   Prevailing storm winds parallel to its long axis,
coupled with  the shallow average depths, cause wide fluctuations in water
levels over a short  period of time.   Fluctuations in water levels of more
than 10 ft at Buffalo due to storms have been observed.3

     The Niagara River flows  in  a northerly direction from the east end of
Lake Erie to  Lake  Ontario, a distance of about 37 miles  [Figure  2].   The
total catchment area  of  the Great Lakes tributary to  the river is about
265,000 sq mi.  The  drainage area tributary to the  river itself  is about
1,700 sq mi  with nearly three-fourths in the United States.

     The  Upper  Niagara River (above Niagara Falls)  is  divided into two
channels by Grand Island:  the Tonawanda (East) and Chippawa (West) Channels.
About 60% of  the river flow  follows  the  Chippawa  Channel,  The gradient of
the Upper River is  relatively flat except in the inlet area leaving Lake Erie.

     At Niagara Falls, the river drops about 50 ft in the rapids  above the
Falls and then plunges another  160 ft into the lower gorge.  An additional
100 ft of elevation are lost in rapids upstream and downstream of the Whirl-
pool.  The river flows  in the gorge for about 7  miles, emerging  from  the

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40
 Niagara Escarpment to  flow  on  a low gradient to Lake Ontario.   Total  ele-
 vation difference between Lakes Erie and Ontario is about 326 feet.

      Hydroelectric power development has  altered  flow patterns and rates
 at the Falls  and  in  the gorge by diverting  flow  through powerplants  and
 storage reservoirs.

      Outflow from the Niagara River  disperses outward from the mouth of the
 river into  Lake Ontario and then generally flows  eastward along the south
 edge of the Lake.   Lake Ontario is  a very deep lake with depths in excess
 of 500 feet.   A  delta has been created off the mouth of the river by de-
 posited sediments.

      Average flow of  the  Niagara River is about  202,000  cfs.   Lake Erie
 acts as a reservoir to dampen flow fluctuations due to runoff in the water-
 shed of the Great Lakes.   However,  lake  level fluctuations due to storms
 cause rapid changes in river flow rates.   Flow rates ranging from 90,000 to
 375,000 cfs have been observed.4  Additional  information on hydrologic char-
 acteristics of the river system are  discussed in Section IV.   The principal
 tributaries of the  river  are the Buffalo River, Ellicott Creek, and Tona-
 wanda Creek in the U.S. and the Welland River in Ontario [Figure 2].

      The Buffalo  River flows through the  Buffalo  Outer Harbor and into the
 inlet of the Niagara River.   Principal  tributaries of the Buffalo River in-
 clude Buffalo, Cazenovia, and  Cayuga Creeks.  Average stream flow is about
 400 cfs but very low flows occur in summer.  Flows in the lower reaches are
 augmented by discharges of industrial wastewaters, primarily cooling water.
 For many years,  industrial  plants along  the  Buffalo River obtained their
 water supply  from the  river  and  returned  wastewaters to  it.  The river was
 a trap for  pollutants during low flow conditions and was highly polluted.
 Now, process  wastewaters are  primarily  discharged to the Buffalo Sewer
 Authority and  cooling  water is obtained  from the Buffalo Outer Harbor by
 the Buffalo River Improvement Corporation.

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                                                                       41
     Tonawanda and  Ellicott  Creeks  join about one-half mile  above their
confluence with the  Niagara  River at Tonawanda.   Their combined drainage
area is about 650 sq mi.   The lower few miles of  the Tonawanda Creek channel
are part  of  the Erie Canal (New York State Barge Canal) that  connects Lake
Erie with eastern New York waterways.   Depending  on flow rates in Tonawanda
Creek and Erie Canal operations,  "vhj f"!c - frcm Tonawanda Creek may ba either
into the Niagara River or into the Canal toward Lockport.

     Other minor tributaries  in  the U.S. of interest because of pollution
sources or problems include Smokes Creek in Lackawanna, Scajaquada Creek in
Buffalo, Two Mile  Creek  in Tonawanda,  and Cayuga,  Bergholtz, Black, Gill,
and Bloody Run Creeks  in  Niagara  Falls.  These are  all basically intermit-
tent streams, especially in their upper reaches.

     In Ontario, the main tributary is the Welland River with a drainage
area of about 370 sq mi.   Historically, the Welland River discharged to the
Niagara River above Niagara Falls.  Flow in the lower 4 mi has been reversed
by a power development and the Well and River now discharges through a power
canal and plant to the Lower River gorge.

     Portions of the Niagara  River  and  tributaries  are maintained  as navi-
gation channels.   The lower 3 mi  of the Buffalo River is navigable.  Buffalo
Harbor and the Lackawanna and Union Canals are navigation channels and har-
bor works  in the  Buffalo waterfront area of  Lake Erie.  Black Rock Canal
and the  locks  at  Squaw Island bypass the rapids  in the inlet of the Upper
Niagara River.  A  navigation  channel  is maintained in the Upper River and
Tonawanda Channel  to Tonawanda where it connects  with the Erie Canal.   Main-
tenance dredging is performed annually  in most of these channels.  A navi-
gation channel was  formerly maintained  in the Tonawanda Channel from Tona-
wanda to  Niagara Falls but dredging was  stopped about 20 years ago.  Great
Lakes navigation bypasses Niagara Falls and the entire Niagara River system
through the  Well and  Canal  in Ontario at the west edge of the study area.

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42
 Topography

      The topography of the study area \$  relatively  flat,  consisting of the
 Lake Erie and Lake Ontario plains separated by the east-west trending Nia-
 gara Escarpment near  Lewiston.   The  Escarpment  is about 200 ft high.  In
 New York, drainage south  of  the Escarpment is either  to the  south or west
 to the Niagara River.   To the north  of the Escarpment, drainage is to the
 north into Lake Ontario.

 Geology

      The study area is underlain by relatively flat  sedimentary rock forma-
 tions that dip to  the south-southeast at a rate of about 30 ft per mile.
 Bedrock  in the  southern portion of the study area  around Lackawanna is
 Marcel!us Shale.5  Most of the Buffalo area is  on Onondaga Limestone bed-
 rock.  Grand  Island  and the  Tonawandas are on Camillus Shale.   Bedrock in
 the  Niagara  Falls  area south of the  Niagara Escarpment  is the Lockport
 Dolomite.6  North of the Niagara Escarpment, the bedrock  is Queenston Shale.

      None of the bedrock formations are good aquifers.7  Most water movement
 occurs in unconsolidated materials overlying bedrock.   Some water movement
 occurs in vertical and horizontal  bedding joints in the  Lockport Dolomite
 and Onondaga Limestone.

      The Lackawanna  area  has  lacustrine  deposits of clay, silt, and  sand
 overlying bedrock at depths of 20 to 80 feet.8   Most of Buffalo is on about
 20 to 80 ft of glacial till over bedrock.   This  formation  also extends under
 the Town of Tonawanda.

      Lacustrine deposits  cover  the Camillus Shale to depths of  20  to  80  ft
 in the cities of Tonawanda and North Tonawanda.   In  the  Niagara Falls area,
 unconsolidated deposits are relatively thin, only 5  to 20  ft thick over the
 Lockport Dolomite  south of the Niagara Escarpment.   To the  north of the
 Escarpment,  the deposits  are  about 80 ft  thick  over  the  Queenston Shale
 bedrock.

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                                                                       43
     The permeability of the unconsolidated deposits is relatively low but
varies widely by  location  as  does permeability of specific bedrock zones.

     In the Buffalo and Tonawanda areas, groundwater movement is toward the
Buffalo River, Tonawanda Creek,  and the Niagara River.   In Niagara Falls,
groundwater flow patterns have been disrupted by construction of power pro-
jects and by industrial  pumping.

Industrial Development

     Industrial  development in Buffalo  and Niagara Falls began around the
turn of the century.  Cheap hydroelectric  power and an abundant water sup-
ply attracted industries such as  electrochemical,  electrometallurgical,  and
iron and steel that capitalized on these resources.  Major portions of many
of the present industrial plants  were built prior to the 1930s.   The age of
these plants is  a major factor in the characteristics of the pollution prob-
lems presently observed in the Niagara Frontier.

     Growth of the organic chemical industry nationally has been paralleled
by growth in the same industry in the study area.   This growth has occurred
over the  last 40 years.  The presence of major chlorine production facili-
ties in Niagara Falls resulted in  the development  of industrial facilities
for a wide  range  of chlorinated  chemicals.  Organic and  inorganic chemi-
cals, plastics,  iron and steel, automobile parts,  carbon products, electro-
metallurgy, synthetic dyes, petroleum refining, abrasives, and grain milling
are all important area industries.

     Industrial  facilities are primarily concentrated along  the lower Buf-
falo River, the  Buffalo Harbor, and Lackawanna waterfront areas in Buffalo,
the Upper Niagara River waterfront in the  town of  Tonawanda, the  Tonawanda
Channel in the  cities  of Tonawanda and North Tonawanda and along the Nia-
gara River in Niagara Falls.  Canadian  industries  in the  study area  are  in
Welland and Niagara Falls.

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44
 PREVIOUS STUDIES

      There have been many studies of environmental  pollution in the Niagara
 Frontier.   The wide variety of types of studies and investigators is shown
 by the variety  of  publications  listed  in  the  References  and Bibliography.
 Until about  1975,  most of the studies evaluated environmental  pollution
 with respect  to traditional  pollutant parameters.   Since  1975,  chemical
 substances have received much more attention.   Because this current inves-
 tigation focussed on the group of chemical  substances  commonly called  toxic
 substances, the later  studies were  the most applicable.   Earlier reports,
 however,  provided  valuable background  data on the  broader environmental
 setting of the  Niagara Frontier.   Selected studies which provided part of
 the  input  for  this  report are discussed below.   The reader is referred to
 the  Bibliography at  the  end  of this report for  additional  references of
 interest.   In addition, specific references are used throughout this report
 to identify  the  source of particular facts or data.  These are  listed  in
 References at the end of this report.

      An early study by the U.S.  Public  Health  Service  for the IJC conducted
 in 1948-1949 was particularly useful in defining the effects of  hydrologic
 factors on pollution dispersion patterns  in Lake Erie  and the Niagara  River
 system.9  The  study  was  primarily limited to  conventional pollutants but
 included data on total phenols taken at many locations over a 16-month per-
 iod.   It  also  identified dredged  spoil disposal practices  in effect during
 the  1940s  that  may be currently adding priority pollutants  to the river
 system.

      An extensive  amount  of  water-resource and water-quality planning was
 conducted  in the early and mid-1970s.  Planning  reports were numerous with
 the  various  documents providing  background information on  surface and
 groundwater  resources, hydrology,  geology,  and sources of pollution.   The
 two  water  quality  management plans and the comprehensive water  resources
 plan covering the study area were particularly useful.10 1X 12

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                                                                             45
     A  report on a 1970-75 study of New York drinking water supply quality
was  published in 1980 by the U.S.  Geological Survey.13  This provided com-
parative  data for various priority pollutants  for water supplies in the
study area  and at  other  New  York locations.

     A  very useful compilation of  sources of data on the Niagara River was
prepared  by EPA  in 1980.14  This was  used to identify various other refer-
ences to  be obtained  and reviewed.

     In  1979, the Interagency Task Force on Hazardous Wastes, composed of
representatives  from  New York State agencies and EPA, completed  a study of
hazardous waste  disposal sites in  Erie  and Niagara Counties. This draft
report15  has  been widely used as the basis for  other studies of  hazardous
waste disposal.

     There  have  been  several  followup reports to the  Interagency  Task Force
draft report  that provide data on  hazardous waste generation and disposal.
An  inventory  of  hazardous waste generation was  released shortly  after  the
"draft report.16   An update  on the  inventory of hazardous waste  disposal
sites was published in June  1980.17

     The  New  York DEC has given specific attention  to toxic  substances in
the  environment  in several  reports.  An interim report on toxic  substances
in  New  York was  released  in 1979.18  A  report  specific  to  Erie County was
completed in  I960.19  Reports summarizing levels of toxic substances  in
fish and wildlife and associated trends were completed in 1980 and 1981.20
21

     Interim  reports  summarizing a  variety of toxic substances information
on  six  study  area  segments were prepared in 1981 by  the  Great Lakes  Labora-
tory of the State University  College at Buffalo under an EPA contract as
part of a Niagara River  toxics study.22 23 24 2S 26 27  Unpublished drafts
were obtained for  use in this  study.

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46
      In 1981 the New York Public Interest Research  Group  (NYPIRG)  completed
 a 3-year study  in 1981 of available data on toxic chemicals in the Niagara
 River and their effects.28  The report included an  extensive  and comprehen-
 sive compilation of information extracted from regulatory agency files.   It
 also included the  results of  limited environmental sampling conducted by
 NYPIRG.

      A preliminary report by DEC on toxic substances  control  in the Niagara
 River was completed  by  DEC  in June 1981.29  It summarized DEC regulatory
 activity with respect to wastewater discharges and  hazardous  waste disposal.
 It also discussed activities of the American-Canadian Niagara River Toxics
 Committee.   A  detailed  work plan,  completed in September  1981, provided
 additional  details on committee environmental  studies.30

      A report on  an  EPA-NEIC  evaluation of the Niagara  Falls  wastewater
 treatment plant was  completed in November 1981.31  This  study evaluated
 various aspects  of the Niagara  Falls  industrial waste  disposal  system.

 STUDY METHODS

      Because the  environmental  problems  of the Niagara Frontier have re-
 ceived much publicity in  recent years, numerous studies of various aspects
 of the area environment have been conducted by a wide variety  of research-
 ers, government scientists, and  industrial consultants.   Numerous  reports,
 technical papers,  newspaper articles,  memoranda,  letters, and other docu-
 ments  have been generated containing data on the  presence of toxic sub-
 stances in the  environment, their sources  and effects, regulatory  require-
 ments, and a wealth of other information of use to  this  study.  The Niagara
 Frontier would  appear to  be one  of the most extensively studied geographi-
 cal areas in the country with respect to toxic substances.

      An extensive  literature  and file  search was conducted to  compile this
 available information.  A key element in the literature  search was a com-
 puter search of selected commercial literature data bases.   Major  data bases
 searched (with  the  number of references identified shown  in parentheses)

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                                                                       47
included:  APTIC  (51),  Pollution  Abstracts (26), ENVIROLINE  (53), GEOREF
(69), NTIS  (172), DOE  Recon (124), GEOARCHIVE  (2), and  SSIE  Current
Research (2).

     The  literature  search yielded more  than  400 references, most with
abstracts.  Geographical,  as  well  as  subject,  search terms  were  used to
yield the broadest possible  literature coverage.  Thus, a  number of refer-
ences meeting the geographical criteria were retrieved which were not appro-
priate subject matter.  However, this was minimized by searching data bases
containing only appropriate subject matter.

     A review of  the  abstracts indicated about half of the references ap-
peared to be  applicable to the study.   These documents were then obtained
from numerous libraries around the country.  About one-third of the docu-
ments were already in the  NEIC  library microfiche holdings.   The documents
were reviewed as  received  and categorized.  Secondary references cited by
the documents were also obtained when appropriate.

     Most published documents and several other document types compiled for
this study are  listed in either the Bibliography or References section at
the end  of this report.  All  documents which were reviewed for  content  and
application but were  not cited in this report are listed in the Bibliography.
A separate References section lists all items cited.

     The second major element of the data collection activity was a detailed
file search.   The file  search encompassed air, water, and hazardous waste
regulatory program files maintained by the  New York Department  of Environ-
mental  Conservation and by the  Environmental Protection Agency.  Files  re-
viewed by the study  team  were maintained at DEC offices  in Albany and
Buffalo,  New  York, and  at  EPA offices in  New  York City and  Edison,  New
Jersey.    Additional file materials were  obtained from EPA  offices in  Wash-
ington,  D.C., Chicago,  Illinois, and Warrenton, Virginia.

     The  file search  concentrated  on compiling data on ambient  air, water,
sediment, biota,  and  fish  to aid in defining environmental conditions and

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48
 on compiling data on  air  emissions,  wastewater discharges, and hazardous
 waste management at  major  sources  of  chemical  substances.

      Available data  on chemical substances in ambient air and water, sedi-
 ments, and aquatic  life collected primarily  during the past 6 years were
 evaluated and summarized to define existing  environmental  conditions and
 identifiable trends. A major  portion  of the  recent data on chemical sub-
 stances in the aquatic environment was collected  by the Ontario Ministry of
 the Environment and Environment Canada.  Additional data were collected by
 DEC,  several EPA offices, and a variety of researchers.  Much of this data
 was generated by coordinated studies  guided by a  work plan  developed by the
 joint American-Canadian Niagara River Toxics  Substances Committee.   Data on
 groundwater contamination was obtained from DEC files.  The limited avail-
 able data on chemical  substances in ambient air was obtained from DEC files
 and the literature search.

      An inventory of more than 10,000 manufacturing, wholesale, and retail
 trade, commercial, and service facilities in Erie and Niagara Counties was
 prepared from EPA and New York computer files.  This inventory was used to
 define the boundaries  of  the  detailed study area.  A second inventory of
 about 1,000 facilities in the detailed study  area was prepared with computer
 assistance to identify those facilities (primarily industrial  manufacturing
 plants) with the potential  to be significant  sources of chemical substances.
 This inventory was compared with EPA  and DEC  lists of wastewater dischargers,
 air pollution sources, hazardous waste disposal sites (active and inactive),
 hazardous waste management permit applications and the DEC  Industrial Chem-
 ical  Survey (ICS) to eliminate facilities with no significant chemical  sub-
 stance activity.  The  resulting  list of facilities with known or probable
 chemical substance activity was used  as a guide in the file search to iden-
 tify facilities for  which information was collected on wastewater discharges,
 air emissions,  hazardous waste  management,  and chemical substance use or
 production.

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                                                                       49
     Where available, the most  recent SPDES permit application containing
priority pollutant  data (EPA Form  2C) was obtained and  used  to define
current wastewater discharges of chemical  substances.  Unfortunately, only
a  single  sample was  often  reported  in  the permit application.  Other
sources of data  on  priority pollutants in wastewater discharges included
self-monitoring data where  the  existing permit contained limits on these
substances, results of  special engineering studies conducted by permittees
as a basis for evaluating sources and  control methods for significant dis-
charges of priority pollutants and  compliance monitoring  investigation re-
ports where priority pollutant analyses had been run.   EPA had evaluated 11
major sources in May 1981.

     Initially, an attempt to prepare a mass balance for each priority pol-
lutant frequently reported in discharges was considered.   This was discard-
ed because of  the  large data manipulations that would have been involved
and the lack of  priority pollutant data at all sources of interest.  In-
stead, a simplified mass balance was prepared for major sources with totals
of groups  of priority pollutants.   These groups included organic priority
pollutants (volatile, base-neutral,  and acid  extractable priority pollut-
ants), phenols,  and  heavy  metals.   Cyanides were not included in the mass
balances because only a few sources discharge significant amounts.   Pest-
icides were also omitted because there were no significant discharges of
pesticides.

     Rating criteria were developed and used to define the relative magni-
tude of chemical substance  releases to the environment through wastewater
discharges and air emissions, the volumes of chemical  substances used, pro-
duced, and stored as  indicated by the  ICS, and the hazardous waste manage-
ment activities.  The rating results were used to develop a list of major
point sources  (industrial,  municipal,  and hazardous waste sites) of chem-
ical substances.

     Available information on non-point sources of chemical  substances from
EPA and DEC  files and  from published  research results  was  summarized.
Relative ratings of  the contributions of the important non-point sources

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50
 (contaminated groundwater,  dredged spoil  disposal,  contaminated  bottom sedi-
 ments,  and urban runoff)  were not possible  because  of  a  lack  of  data  defin-
 ing the contributions from  each source.

      Information on past,  present,  and  proposed future  environmental pro-
 grams applicable to  the  regulation and  control  of chemical substances in
 the Niagara Frontier was compiled  from government documents and interviews
 with EPA and DEC personnel.

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                                                                       51
                     IV.   ENVIRONMENTAL CONDITIONS
     Chemical substances  are  present in large quantities  in  the Niagara
Frontier.   The bulk of this volume is raw material or products of the vari-
ous manufacturing plants, especially chemical  manufacturers.   Chemical sub-
stances are  also  used by many non-chemical manufacturers,  by commercial
establishments and by  residents  in and around their homes in many common
products including pesticides, cleaning agents, and paints.  This situation
is not unique to the Niagara Frontier but is shared with other areas of the
country which have concentrations of chemical  manufacturing plants.

     Releases of chemical  substances to the environment from the various
industrial, commercial,  and residential  activities are inevitable and un-
avoidable.   Both the quantity  of such releases and the pathways they follow
are important in determining environmental  impacts and resulting effects on
man.

     Within the Niagara  Frontier,  chemical  substances are present to some
degree in  ambient air; the inside  air of homes and industrial plants;  sur-
face waters  including  the Niagara  River and its tributaries and  Lakes  Erie
and Ontario;  the  suspended  and bottom sediments  of these  surface waters;
contaminated groundwater aquifers; public drinking water supplies; and fish
and other  aquatic life.  All  of  these media are important  because they  re-
present pathways by which  chemical substances are transported through the
environment and by which they  may ultimately impact on man.

     In the past, controls  on releases of chemical substances to the  en-
vironment were inadequate and  serious environmental impacts occurred.  Large
volumes of chemical substances were  discharged to  surface waters  in  indus-
trial   and  municipal  wastewaters  and in contaminated stormwater  runoff.
Improper disposal of  large  volumes of hazardous  wastes also contaminated
surface and groundwaters  and  surface soils near disposal  sites.   This re-
sulted in  serious contamination  of Lakes Erie and Ontario and the Niagara
River with adverse impacts on  public drinking  water supplies and on aquatic
life.

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52
 Migration of chemical substances from  inadequate  hazardous waste  disposal
 sites caused serious contamination  of several  residential  areas  and  created
 potential health hazards.   Inadequate controls on  emissions of air contami-
 nants also produced air  pollution problems.

      Over the past  15 years, implementation of various pollution abatement
 measures to control traditional  air and water  pollutants  (such as  suspended
 particulates in air and  oxygen  demanding substances  in water) have resulted
 in major  improvements in  air and water quality.   Concurrent with  this  im-
 proved control of  traditional pollutants  has  been a reduction in  releases
 of chemical substances to  the environment.

      Recent improvements  in man's  understanding of  the adverse  health  and
 environmental  effects of low levels of  chemical  substances have  led  to  leg-
 islation, regulations, and activities directed toward minimizing the presence
 of hazardous chemicals in  the environment.   This regulatory thrust,  coupled
 with improved control technology and disposal  practices,  has also resulted
 in major reductions in releases of chemical  substances  to the Niagara
 Frontier environment.  However, because of past disposal  practices and the
 persistence of  many chemical  substances, several environmental problems
 remain.

      The environmental problem  of most  concern to  the public  and to  the en-
 vironmental agencies  is the migration  of hazardous  wastes from inactive
 disposal  sites with subsequent  environmental  contamination  and potential
 health hazards for area residents.   Love Canal is  the best known problem of
 this type, but other less  populated areas of contamination have  been identi-
 fied.  Remedial measures  have been taken at a number  of sites to  abate any
 imminent  health  hazards.   However, long-term solutions  to  most  problem
 sites remain to be completed.

      Contamination  of edible sport fish with  PCBs,  mirex, dioxin, mercury,
 and DDT  (all persistent toxic substances) is a well-documented  environmental
 problem.   Although  this contamination  has been reduced over the past years

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                                                                             53
by controls on sources of these substances, the contamination is still seri-
ous enough that  both  New York and Ontario continue to ban or restrict the
consumption of several  species  of fish from Niagara River or Lake Ontario
waters.

     Of perhaps  greater  concern to the public is the low-level contamina-
tion of public water  supplies with a variety of chemical substances.   The
extent of the contamination is fairly well defined.  Its significance, how-
ever, is controversial.

     Water quality objectives  have been established to protect water uses
of the Canadian-United States  boundary waters in  the  Great  Lakes by the
International Joint  Commission (IJC).  Although  water quality generally
meets these objectives, concentrations of several chemical substances occa-
sionally do not meet the objectives.

     Government activity during World War II, as part of the Manhattan Pro-
ject to develop  an atomic  bomb, resulted  in  the  low-level radioactive con-
tamination of several  sites  in the study  area.   Full  decontamination of
these sites has not been completed.

     Because of the widespread public attention focused on the Niagara Fron-
tier area  over the  past 5 years,  numerous environmental studies have been
conducted.  This  has  resulted in  an extraordinary availability of data on
the presence of chemical substances in the environment of a particular geo-
graphic area.  This  fact,  coupled with the  emotional  public response to
problems such as  the Love Canal incident, tend to produce a general impres-
sion that  the entire  Niagara Frontier  is  grossly  contaminated with toxic
substances, the environment is seriously degraded, and these conditions are
steadily worsening.   In  fact,  available data  indicate  that  environmental
quality has  substantially  improved over the  last  10  years  and that this
improvement is continuing.

     Much  of  the  emotional response to  public announcements  concerning the
presence of  potentially  toxic chemical  substances  in  any  media  is  due to a
lack of understanding  concerning  the  significance of the levels detected.
Recent improvements in analytical  techniques now make it possible to detect

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54
     some chemical  substances  at  very low levels.  Because a substance can be
     detected does  not  necessarily  mean it is a hazard.   In the following dis-
     cussion an  attempt is  made to put available data in their proper perspec-
     tive.  Where criteria or standards exist defining acceptable levels of chem-
     ical substances in any media, present conditions are compared to these cri-
     teria.   Trends in environmental quality are also discussed.

     INACTIVE HAZARDOUS WASTE DISPOSAL SITES

          Hazardous wastes  containing  highly  toxic substances from Hooker  Chem-
     ical Company and other generators were disposed of for years in an abandoned
     power canal segment known as the Love Canal in eastern Niagara Falls.   After
     cessation of disposal activity in 1952, the site was covered with earth and
     deeded to  the  Niagara  Falls  School Board.  A school was subsequently  built
     near the center of the site and adjacent lands were developed as a residen-
     tial area.

          In 1978,  it was discovered that chemical substances from the Canal had
     migrated outward  from  the site into the residential area and had contami-
     nated yards and basements.  The same chemical substances were also found to
     have migrated  offsite in storm drains and surface runoff.

          Understandably, the  discovery of  the  contamination in  the  residential
     area caused much public concern.  Allegations  of  various  serious health
     problems were  made.   New York State declared an  emergency  and evacuated
     about 240  families.   The State then took control of the vacated homes ad-
     jacent to the  disposal area.

          Today, the environmental and public problems concerned with Love Canal
     continue.   The site is the  subject of  active litigation between  EPA, DEC
     and  others, and the Hooker Chemical Company.  Remedial measures including a
     new  clay  cap  on the disposal site and a leachate collection and treatment
     system have been completed.  However,  the  problems  associated with the va-
     cated residences  and public  concern  over the safety of other nearby resid-
     ences continue.  Both New York State and EPA have spent millions of dollars

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                                                                             55
on the Love Canal emergency and followup activities.   Ultimate solutions to
Love Canal environmental conditions probably will be determined by the  re-
solution of the active litigation.

     The Love  Canal  incident spawned various investigations into hazardous
waste disposal practices  in  the Niagara Frontier.  Investigations by the
Interagency Task Force in 1978-79 identified 215 sites in the Niagara Fron-
tier where hazardous wastes may have been disposed of.   Followup investiga-
tions at these sites have resulted in the initiation of litigation on sever-
al sites and the implementation of remedial measures at sites with the most
serious environmental problems.  Investigations of additional  sites contin-
ue.  The status  of many of these sites  are  discussed in the following sec-
tions of this report.

     As a  result of  this  activity, environmental problems associated with
inactive hazardous waste  disposal  sites have been reduced but not elimi-
nated. Substantial investigation  and  implementation of remedial measures
remains to be completed before these sites are fully controlled.

FISH CONTAMINATION

     Contamination of edible fish  in Niagara Frontier waters, although  re-
duced in the last 5 years, remains of major concern.   Levels of PCBs, mirex,
and dioxin in  adult  sport and edible fish are such that both New York and
Ontario have  issued  health  advisories  and/or consumption guidelines that
have the effect  of  restricting or prohibiting the consumption of certain
species or sizes of fish.32 33  Contamination of fish with DDT and mercury,
formerly a major problem,  has been reduced to the point that it is no longer
a problem by itself.

     Extensive monitoring of fish to assess levels of contamination is con-
ducted by  both  Canadian  and  U.S.  agencies.  Monitoring of both sport and
forage fish conducted by Environment Canada and the Ontario Ministry of the
Environment is reported in  the 1980 and 1981 Baseline Reports.34 3S  The
New  York  DEC  monitoring  results  are  published  in  various technical
reports.36 37 38 39  Unpublished preliminary DEC data were also obtained for

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56
 this study.40 41  42  Other U.S.  agencies  have  also  done  some  periodic  anal-
 ysis of fish from the area including EPA  and the  Fish  and Wildlife  Service.43

      Contamination of fish in the  Niagara  River  and Lake Ontario  is  the
 result of bioaccumulation of persistent  chemical  substances.   These sub-
 stances are picked up through the food chain and  accumulated  in  body tissue,
 especially fats.   The large predator sport  fish are at the top of the  aqua-
 tic food chain and tend to have  the most  body  fat.   Consequently, they have
 the highest  level  of  contamination.   They  also are older fish and  reflect
 accumulation of chemical  substances  over a period of several years.   In
 contrast, small forage fish are  young and have little  fat.  Accumulation of
 chemical substances in  forage fish thus  reflects  recent exposure to these
 substances.   Both types of fish  are monitored  to  detect  short- and  long-term
 trends.

      Ambient levels of  chemical  substances are generally below  concentra-
 tions considered acutely  or chronically  toxic to  fish.  Therefore, direct
 toxicity is  no longer of  major  concern.  Fish kills sometimes occurred in
 the past  as the  result of toxic levels  following  spills of chemicals.

      Low levels of chemical substances in ambient water, suspended  sediments,
 and bottom  sediments  contribute to the  bioaccumulation of chemical  sub-
 stances in  the aquatic  food chain.  Therefore,  it  is desirable to reduce
 the release of persistent chemical  substances  to  the aquatic  environment to
 the minimum consistent with available control  technology.

      High concentrations  (up to 100 ppm  in edible flesh of  Lake Trout) of
 the persistent chlorinated hydrocarbon pesticide  DDT, the  result of wide-
 spread agricultural use,44 were  discovered  in  fish throughout New York state
 in  the  1960s.  Adverse  environmental effects  led to restricted  use of DDT
 in  1965  and a complete ban on  its  use in  New York  in 1971.    Ontario  also
 restricted DDT use to limited  non-agricultural purposes  in  1969.45

      Since  1969,  DDT  levels  in  Lake Ontario  sport  fish have declined by
 80-95%.46   Canadian  monitoring  of  forage fish in  the Lower Niagara River

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                                                                       57
showed an 89% decline in DDT contamination between 1975 and 1979 and then a
slight increase  in  1980 [Table 4].47  Detected concentrations  were well
below the  IJC  objective for protection of  fish-consuming  aquatic  birds.
The 1980 increase was small but of concern because it reflected an  increase
in parent  DDT  detected  in both the forage fish and suspended sediments in
the Lower Niagara River.45  The source of this unexpected increase  in fresh
DDT is unknown because of the restrictions on DDT use.

     Analysis  of  forage fish from eight  locations  in  Lake Erie and the
Niagara River showed substantial spatial  variations in DDT levels [Figure 4
and Table 5].48  Highest levels were detected in the lower River and in the
Tonawanda Channel at  the mouth of Little Niagara River near Cayuga Creek.

     Contamination of fish with mercury was discovered about 1970.   Mercury
discharges from  industrial  sources  in the Niagara Falls area were  reduced
by about 99%  in  the early 1970s.   Mercury concentrations in fish have de-
clined about 30%  since  197049 and are below the Food and Drug Administra-
tion (FDA) allowable limit of 1.0 ppm for edible flesh.

     Essentially all  fish  samples  collected from Niagara  Frontier waters
show contamination  with polychlorinated biphenyls (PCBs).  Elevated  levels
of PCBs in fish in Lake Ontario and the Niagara River are a major factor in
restrictions or prohibitions on their consumption.

     PCB levels  in  most fish sampled peaked about 1977 following a ban on
manufacture in the  U.S.  and earlier use restrictions but remain elevated.
PCBs may now only be used in closed systems with no discharge such  as elec-
trical transformers.  However,  earlier losses of PCB  to  the environment
from a variety of sources resulted in widespread contamination  of bottom
sediments in area waterways.  PCB concentrations in excess of 100 ppb exist
in large areas of Lakes Erie and Ontario bottom sediments.50  PCBs  are also
present in suspended  and bottom sediments in the Niagara River.   Leachate
from landfills containing PCBs may also be a continuing source.

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58
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                                                                        59
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FIGURE 4  .  NIAGARA RIVER BIOMONITORING  LOCATIONS- 1980.

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                                                                             61
     PCB levels in  edible  portions  of sport fish in Lake Ontario declined
about 46%  in  DEC  samples between 1976 and 1978.51  Between 1975 and 1979,
Canadian monitoring detected a decline of 78% in  PCB levels in  forage fish
at the mouth  of  the Niagara River [Table 4].  However, a substantial in-
crease was observed  in  the forage fish in 1980.   The significance of this
increase is not clear.   All  of the samples of forage fish taken from 1975
to 1980 contained PCB concentrations  from 1.3 to  9 times the IJC objective
for protection of birds and animals consuming fish.

     As shown  in  Table  5,  major spatial variations  were  observed in PCB
concentrations in forage fish.   The  highest levels were detected  in the
Tonawanda Channel  in the Love Canal  vicinity.

     Essentially all mature  game fish from  Lake  Ontario are contaminated
with the persistent pesticide mirex.  This  is the major health  concern as-
sociated with  consumption  of these fish.  This contamination is associated
with losses of mirex from  its producer, Hooker Chemical Company in Niagara
Falls, and from a smaller  user of a fire retardant chemically the same as
mirex in Oswego,  near the east end of Lake Ontario.

     Manufacture of mirex stopped in 1967 and grinding of the product stop-
ped  in 1977,  eliminating the point sources.  However, contaminated  sedi-
ments and  possibly  landfill  leachate continue to contribute some mirex to
the Niagara River and Lake  Ontario.

     Contamination of  fish with  mirex  appears  to have peaked  in 1977.
There have been small  declines  (16%) in the levels of mirex in adult game
fish except Lake  Trout.52   However,  mirex in most gamefish  continues  to
average above the FDA action level of 0.1  ppm.   At the mouth of the Niagara
River, contamination of  forage  fish  showed a decline  till  1979 and then
increased  in  1980 [Table 4].  Concentrations in 1980 were about double the
IJC objective.

     Spatial  differences in  mirex  concentrations  in forage fish were also
detected [Table 5].   Highest concentrations  were  at one  Tonawanda Channel
station and in the Lower River.

-------
62
      Contamination of sportfish  from  western  Lake Ontario by 2, 3, 7, 8-
 tetrachlorodibenzo-p-dioxin (TCDD or commonly  dioxin),  a highly toxic trace
 byproduct of  2,4,5-trichlorophenol  production,  was detected in 23  of 61
 fillet samples collected by Canadian agencies  in 1980.53  This  contamination
 was below Health  and  Welfare Canada's limit for public consumption of 20
 parts per trillion (ppt) in  most samples but was above the DEC recommended
 maximum limit of 10 ppt in some samples.   No dioxin was detected in Canadian
 samples from Lake Erie or the Niagara River.

      The U.S.  Fish and Wildlife Service reported substantially  higher dioxin
 levels in two whole fish samples from the Niagara River.53  For carp  taken
 from the junction of Cayuga Creek and Little Niagara River,  the dioxin level
 was 417 ppt.  For fish taken near the mouth of the Niagara River,  the dioxin
 level was 53 ppt.

      There  are  no  known point sources of dioxin in the Niagara Frontier.
 Trichlorophenol wastes are reportedly landfilled at several  locations along
 the Niagara River.53
                                                    f
      Trends in  dioxin contamination of fish are not established.  However,
 comparison  of analysis of archived samples of herring gull eggs with recent
 analyses indicates that dioxin contamination  of the eggs decreased about
 tenfold over the last 10 years.

      Analysis of  forage fish for other organochlorine pesticides  in  1980
 [Table 5] indicates that concentrations are higher at  most upper and  lower
 Niagara River locations sampled than at the background station in Lake Erie.
 No  specific IJC objectives have been established for the other pesticides
 in  Table 5  except lindane,  an isomer of BHC.   All isomers of BHC totalled
 well  under  the IJC objective  of 300  ppb.   BHC  is detected routinely at
 Niagara River water sampling stations.

      One study  has  shown an  apparent  link  between  exposure of  fish  to con-
 taminants in the aquatic environment (polyaromatic hydrocarbons or PAH) and
 fish  tumor  pathology.54  Samples of bottom sediments  from one  segment of

-------
                                                                       63
the industrialized portion  of  the Buffalo River were found to be contami-
nated with mutagenic  substances  as determined by the Ames test.   Analysis
of the  sediments detected a variety of PAH compounds.  Fish taken from the
same area were  contaminated with similar compounds.  Bottom-feeding fish
were found to have a high incidence of fish tumors.

WATER QUALITY

     Surface waters  are  the principal pathway for  transport  of  chemical
substances in the  Niagara  Frontier environment.   Chemical substances from
point and non-point sources in the Buffalo, Tonawanda, North Tonawanda,  and
Niagara Falls areas are dispersed by surface waters throughout the far east-
ern end of  Lake Erie, the Niagara River system,  and much of Lake Ontario.
These substances are transported both in dissolved form in the water and as
part of the suspended sediments.   The extent of this pollutant transport is
effectively demonstrated by the contamination of fish with persistent toxic
substances discussed in the previous section.

     Waters of  the  Niagara  River and the two lakes arc used for a variety
of beneficial purposes,  most  of which are water quality dependent.   These
uses include public water supply,  water-based  recreation  (contact and non-
contact), industrial  process  and cooling water supplies,  propagation and
growth  of  aquatic life,  and navigation  and  transport of  industrial and
municipal wastewaters.   The outstanding  scenic values of  Niagara Falls and
the lower River gorge are also, to an extent, dependent upon water quality.

     Water quality of public water supplies is of particular concern.  This
is the  major means  by which chemical substances  in  the water environment
can be  transported  to humans.   Acceptable levels of a variety of chemical
substances in public water supplies have been established based on scienti-
fic studies and health risks.

     All public water  supplies in  the study  area  obtained from the Niagara
River and Lake  Erie are believed to meet applicable drinking water criteria.
Canadian monitoring during  1979  and 1980  indicated that all Canadian water

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64
 supplies met  existing  and proposed Canadian and  Ontario  objectives for
 drinking water.55  The Niagara-on-the-Lake, Ontario,  supply  obtained from
 the Lower Niagara River is downstream  of all sources  of  chemical  substances
 in the study area.   Because of variations in hydrologic  conditions  discussed
 below, supplies obtained from the Tonawanda Channel may  have  higher concen-
 trations of specific pollutants  at  times.  Public water supply quality is
 discussed in more detail  below.

      Water quality is also of concern  with respect to its  effects on aquatic
 life.  As previously discussed in the section on fish contamination, chem-
 ical substances have been bioaccumulated by the aquatic  food  chain  resulting
 in unacceptably  high levels  of  persistent toxic substances  in sport fish.
 Although water quality  generally meets objectives  for protection of aquatic
 life, these chronic  contamination problems continue, in most cases in de-
 clining levels.  Water quality  is also adequate in most cases to prevent
 any acute toxicity problems or chronic effects on propagation or growth of
 aquatic life.

      Water quality is adequate for other beneficial uses of  surface waters.
 The most critical  requirements  are  for public  drinking  water supplies and
 protection of aquatic life.

 Applicable Water Quality Objectives

      Section 303 of  the  Clean Water Act requires the states to establish
 water quality  standards  applicable  to the surface waters of their  state.
 These standards  consist  of classifications of each stream segment or water
 body based on water uses to be protected and water quality criteria applic-
 able to each  classification.   New York has established  water quality cri-
 teria which are  published  in  their  environmental conservation  regulations,
 Parts 701 and 702.   The Niagara River has been assigned  a  classification of
 Class A -  Special  Waters applicable to international boundary waters. The
 small tributaries  of the River have a variety of classifications assigned.

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                                                                       65
     The Class A - Special Waters criteria are keyed to the Great Lakes Water
Quality Agreement of 1972, an agreement between the United States and Canada
setting forth general and specific objectives for water quality in boundary
waters.56  Because this agreement was primarily directed toward minimizing
contributions of  nutrients into  the Great  Lakes and gave limited attention
to toxic substances,  the New York water quality criteria for Class A - Special
Waters also have limited application to toxic substances.

     A narrative criterion applies to "Taste and odor-producing substances,
toxic wastes and deleterious substances".57  Such substances are limited as
follows:

          None in amounts that will interfere with use  for primary contact
          recreation or that will be injurious to the growth and propagation
          of fish, or which in any manner shall adversely affect the flavor,
          color or odor  thereof  or impair the waters  for  any other best
          usage as determined for the specific waters which are assigned to
          this class.

     In  addition,  numerical  criteria  are applicable  to  five chemical
substances.

          Cyanide        -    Not greater  than 0.1 mg/£ expressed  as CN
          Ferro- or      -    Not greater than 0.4 mg/£ expressed as Fe(CN)g
          ferricyanide
          Copper         -    Not greater  than 0.2 mg/£ expressed  as Cu
          Zinc           -    Not greater  than 0.3 mg/£ expressed  as Zn
          Cadmium        -    Not greater  than 0.3 mg/S. expressed  as Cd

     The Great Lakes Water  Quality Agreement of  1978 superseded the  1972
agreement.58  It gives much more attention to toxic substances, establishing
policy, programs, and general and specific objectives for control of  toxic
substances in boundary waters.   Annex 1 of the 1978 Agreement contains Spec-
ific Objectives specifying levels of numerous toxic substances in water and
fish flesh designed  to  protect  water uses.  Annex 10 establishes lists of

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66
 hazardous polluting substances.  Annex  12  sets forth policy and programs
 for control of persistent toxic substances.   These three annexes are repro-
 duced in the appendix of this report.

      The 1978 Specific Objectives are more  stringent than the New York Water
 Quality Criteria.   They cover more toxic substances and specify lower limits
 for cadmium, copper,  and zinc than the New York criteria.   The 1978 water
 quality objectives are   used  in  the following discussion to assess present
 water quality.   They are also useful  in evaluating the adequacy of effluent
 limits in SPDES discharge permits.

 Hydro!ogic Considerations

      At first look, the Niagara River may appear to be a relatively straight-
 forward hydraulic  connection  between  Lake Erie  and  Lake Ontario.  As  shown
 in Figure  4, the River  flows  northward  out of the east end of  Lake Erie at
 Buffalo.  About 5  miles  downstream it divides into  the Chippawa  (West) and
 Tonawanda  (East) Channels.   About 60% of the  flow  goes to the  Chippawa
 Channel.  The two channels meet downstream of Grand Island to form the Grass
 Island Pool above Niagara Falls.   The 20 mile segment of the River extending
 from  Lake  Erie to  Niagara Falls  is known as  the Upper Niagara  River.  This
 river segment has  a  low gradient  except for the  first 2 miles  downstream
 from  Lake Erie.

      At Niagara Falls, the River drops about 50 feet in the rapids upstream
 of the Falls and then plunges another 160 feet over the F'alls into the Lower
 River Gorge.  Another 50 feet of elevation are  lost in the Whirlpool  Rapids.
 The River  then  flows  at a low gradient through the remainder of the  lower
 Gorge and  into Lake Ontario.  The  total River length between lakes is about
 37 miles.   The average  elevation difference  between Lakes  Erie and  Ontario
 is about 326 feet.

       Hydro!ogic conditions  are more  complex than they  appear.   The  Upper
 River is  navigable from Lake  Erie to  Niagara  Falls,  New York.   The  Black

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                                                                       67
Rock Canal along the east side of Bird and Squaw Islands bypasses the shal-
low rapids at the head of the River.   A lock is present at the north end of
Squaw Island.   A navigation channel extends downstream through the Tonawanda
Channel to the  Niagara  Falls industrial complex.  The  Erie  Canal in the
Tonawanda Creek channel  connects with this navigation channel at Tonawanda.
These navigation improvements affect flow distribution in the river channels.
Dredging of the channels results in movement of bottom sediments.

     At Niagara  Falls,  major flow diversions  are  made  for hydroelectric
power generation.  On the U.S. side, flow is diverted from the Grass Island
Pool through two large  underground conduits to the Robert  Moses  Powerplant
near Lewiston.    This  flow  is  either  directed to  the plant  in the Gorge and
discharged to the Niagara  River  or is pumped to  a  large  storage  reservoir.
At  times  of  peak power  demand,  the  stored  flow  is discharged through the
pumping plant (now a generating station) and the Moses Powerplant in series.

     A similar  power  project operates on the  Canadian  side.  Part of the
river flow is diverted by reversing flow in the lower 4 miles of the Well and
River and diverting  it  through the Queenston-Chippawa Power Canal.   Other
Canadian diversions occur  through  intakes and power  plants at the Falls.
The International Niagara  Control  Works,  a system of gates extending from
the Canadian side to mid-river upstream from the Falls controls water levels
in the Grass Island Pool.  Power diversions are controlled by International
Treaty which specifies  minimum flows  over Niagara  Falls.   Lower  flows over
the Falls are permitted at night.

     The effect  of  the  power developments are to cause diurnal variations
in  flow in the  lower  River.   Pollutants and sediments from the upper River
may also be stored in the power reservoirs.

     For a large river,  flow variations in the Niagara River are relatively
small  except for those  in  the lower  River induced  by  the power operations.
The average flow is about 202,000 cfs.  Extremes are  in the range of 90,000
to 375,000 cfs.  Seasonal  variations occur as a result of flow changes in

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68
 the upper Great Lakes system with higher flows  occurring in spring and early
 summer and low flows in fall and winter.  Short term changes in flow occur
 as the result  of  wind  or storm induced changes in Lake Erie water levels.

      Water quality conditions in Lake Erie and  the Niagara River are influ-
 enced by several  natural  and man-made hydrologic conditions.   This is demon-
 strated by the observed variations in concentrations of a number of chemical
 substances that can  only  be partially explained by temporal  and spatial
 variations in  discharges  of these substances  from known point sources.
 Hydrological  factors believed to affect the movement of chemical substances
 in these surface waters include wind-induced storm surges on Lake Erie, the
 level of  Lake  Erie,  surface runoff tributary to the Niagara River and the
 eastern end of  Lake  Erie produced by precipitation or snowmelt,  seasonal
 changes in precipitation, and  the large diversions of river flow through
 both Canadian and U.S.  hydroelectric power projects.

      A comprehensive study  of  water  quality in Lakes Erie and Ontario and
 the Niagara River was  conducted during  1948-1949 by the U.S. Public Health
 Service  for  the IJC59   This study documented  the  temporal  and spatial
 variations in  water  quality that  resulted  from  changes  in  these  hydrologic
 conditions.  The  study found that the Buffalo  River  and  other tributary
 discharges and pollutants from point sources on the U.S.  shoreline had a
 strong tendency to follow and  remain  along  the  U.S. shoreline  of  the  Upper
 Niagara River.  Dispersion  of  this pollution across the river channel  in-
 creased with increased outflow from the Buffalo River.  However, at no time
 did the  pollution  from the  Buffalo River  and  U.S.  point sources in  the
 Buffalo area  (when  wind mixing of Lake  Erie was  not a factor)  disperse
 across the upper  river to the degree where it entered the Chippawa (West)
 Channel.   In  fact,  under fair weather  conditions, the  band of pollution
 from  the  Buffalo  waterfront area was usually  less  than 200 feet wide  at
 Bird  Island.   At Squaw Island, the pollutant band exceeded 700 feet in width
 under adverse weather conditions  (high  local runoff).

       Strong winds from the west were  found  to produce substantial mixing of
 the  east  end  of Lake  Erie.   Under these conditions,  pollutants  normally

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                                                                       69
confined to the  near  shore waters of Lake Erie  and transported down the
east edge of the River were instead dispersed out into Lake Erie for several
miles.   This resulted  in the detection of pollutants across the full width
of the upper river and in the Chippawa Channel.

     There have  not been major changes in the hydraulic characteristics of
the Niagara River  system  since  the 1948 study with the  exception of the
changes in U.S.  power  projects.   For this reason,  it seems reasonable to
assume  that similar  flow and pollutant dispersion  patterns exist today.
Based on this assumption,  it appears that four general hydrological  situa-
tions occur which  would  produce  different effects  on observed concentra-
tions of chemical  substances  in  the Upper Niagara River and the Tonawanda
Channel,  These can be described as follows.

1.   Fair Weather Condition

     This condition occurs  when  Lake Erie is relatively quiescent and has
not been subjected to wind-induced mixing or water level  changes for several
days.  Tributary stream flows (Buffalo River, Tonawanda Creek, etc.) are at
normal seasonal  levels and are  not influenced by recent precipitation or
snowmelt (no active  surface runoff).   The Niagara  River is at a  seasonal
flow rate,  relatively  stable except where affected by  power  diversions.
Under these conditions,  variables in inputs of  pollutants from point and
non-point sources should be at a minimum.   Essentially all  short-term changes
in water quality should be attributable to variations in pollutant discharges
from point sources.

     It would be expected  that  pollutants from  the Buffalo River-Buffalo
waterfront area  and along  the east  shore of  the  Tonawanda Channel would be
concentrated in  a  narrow band along the east shore of the upper river and
Tonawanda Channel, gradually mixing in the lateral direction until the Falls.
This set of conditions would produce the most severe lateral  stratification
in the  River.   However,  total  pollutant loads in the river would probably
be the lowest of the four conditions.

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70
          At Niagara-on-the-Lake, the river is always completely mixed,  with the
     exception of  pollutants  discharged  to the river downstream of the whirl-
     pool.60  Variations  in concentrations of pollutants observed at this loca-
     tion under these conditions should reflect variations  in point-source loads
     only although some variations might be due to operations of the power proj-
     ects and associated pumped storage.   The relative concentrations of pollut-
     ants at Niagara-on-the-Lake are also affected by total  river flow.

     2.   Local Runoff Conditions

          Lake Erie  is  at the same steady-state conditions  as for fair weather
     condition No.  1.   In contrast to fair weather,  significant local surface
     runoff  is occurring  due  to precipitation and/or snowmelt.  Niagara  River
     flow is  the  same as  the fair weather condition  except  for the slight  in-
     crease from tributary inflow.

          Under these conditions, pollutant levels in the main body of Lake Erie,
     on the western side of the Upper Niagara River, and in  the Chippawa Channel
     would be expected to be the same as for the fair weather condition.   Lateral
     stratification of  pollutants  in the east side  of  the Upper River and  the
     Tonawanda Channel  would  still  exist but lateral mixing would  be greater.
     Pollutant concentrations and loads in the stratified area and the Tonawanda
     Channel  would be higher  because of the increased loads in the runoff.   At
     Niagara-on-the-Lake, pollutant  loads  and probably concentrations would be
     higher.  Variations  in pollutant concentrations would be a function of both
     point source  variations and fluctuations in runoff loads.

     3.   Lake Erie Wind  Storm

          This condition  is  associated with strong westerly winds on Lake Erie
     without  associated precipitation and/or  snowmelt runoff.   Sustained  strong
     winds generally  parallel to the axis of the Lake produce several conditions
     which  apparently have  major effects on water  quality  in the  Lake and  the
     Niagara  River.   Increased wave action stirs up bottom sediments, especially
     in the  shallow eastern edge.  This effect would also be  important in larger
     portions of the  Lake during major storms.  Pollutants from point sources in

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                                                                       71
the Buffalo-Lackawanna area,  the  Buffalo River and the resuspended sedi-
ments are dispersed throughout the eastern end of the Lake.   The lake level
at the east end is elevated by a storm surge.   This elevation is a function
of wind speed, direction, and duration.   Storm-induced lake elevation changes
of more than 10 feet above low water have occurred.  Changes in lake eleva-
tion in turn  substantially alter  flow in the Niagara River with 50% flow
increases possible over a few days'  time span.

     These conditions substantially alter the water quality patterns in the
Niagara River.  Because of the mixing in the Lake, water quality across the
Upper River and in both  the Tonawanda and Chippawa Channels would be rela-
tively uniform.  Some stratification along the east shore could be expected
because of point source contributions but lateral mixing would be more rapid
than the  first two conditions because of higher  river flow.  Substantially
higher concentrations of suspended  sediments would be present throughout
the river.  It would appear probable that pollutants detected  in bottom
sediments would increase in the water column as well.   Increased movement
of bottom sediments would occur because of the higher river flow.  Pollutant
loads would be expected  to be significantly higher at Niagara-on-the-Lake
for most  pollutants,  especially those found  in river and lake bottom sedi-
ments.   Pollutant concentrations  could be expected to increase at Niagara-
on-the-Lake for pollutants  found  in sediments but decrease for those con-
tributed only by point sources.

4.   Major Storm Condition

     This condition  is the  same as  the Lake  Erie Wind Storm condition with
the addition  of local surface runoff from precipitation and/or  snowmelt.
The runoff would  be  expected to  increase overall  pollutant levels by  in-
Creased pollutant dispersion  in  Lake Erie and by increased pollutant dis-
charges to the River.  This would produce greater lateral stratification in
the Upper River and Tonawanda Channel than Condition 3 and the highest pol-
lutant loads  in Tonawanda Channel and at Niagara-on-the-Lake of the four
conditions.

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72
      There are  other  hydro!ogic conditions  that  also affect  pollutant
 levels in the Niagara River.   River flows vary seasonally and from year to
 year as the result  of  seasonal  variations  in runoff  from the entire  Great
 Lakes drainage above Lake  Erie.   Longer  term flow variations  also occur
 because of drought cycles.

      Seasonal  and long-term variations in  precipitation  in  the area  imme-
 diately tributary to the Niagara River and  the east end of Lake Erie  affect
 the frequency and magnitude of  surface runoff events.  These same varia-
 tions  in  precipitation  affect  recharge of  groundwater systems  and cause
 seasonal and long-term variations in the contribution of pollutants to the
 river from landfill leachates and  from contaminated  groundwater aquifers.
 For landfills and aquifers adjacent  to the river  or  lakeshore, changes in
 groundwater levels produced by changes in lake or river levels may produce
 rapid changes in the contributions  of pollutants  by these sources.

 Public Drinking Water Supplies

      Ten public  drinking water  systems obtain their  supply directly from
 the Niagara River.  In  addition,  the City of  Buffalo obtains  its supply
 from  Lake  Erie at the  entrance  to  the Niagara River.   The  smaller  St.
 Davids  system  in Ontario obtains its  supply  by  induced  infiltration of
 Niagara River water from  a power canal.  Average volume  treated and  popu-
 lation served by  each  system  is shown in Table 6, arranged in  downstream
 order.  Intake locations are  shown in Figure 5.

      These water  supply  systems  distribute more  than 250 mgd  of treated
 water  to  a population  of more  than a  million persons.   The water supply
 systems thus have the potential  to transport chemical substances present in
 the Niagara River to a large  population.

      None of the nine U.S.  water treatment  plants are specifically designed
 to remove potentially toxic chemical  substances.   The City of Niagara Falls
 uses  powdered  activated carbon  chemical to remove  organic chemicals.61
 Information on Canadian treatment systems was not obtained.

-------
73





















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-------
74
                                                                 N TONAWANDA
              LAKE
       FIGURE 5. PUBLIC DRINKING WATER SUPPLY INTAKES

-------
                                                                            75
     The settling and  filtration  processes  employed remove substantially
all suspended solids present in the raw water supply.   Because many chemical
substances found  in the Niagara River are present in the suspended solids,
solids removal in tha traatment process produces incidental removal of chem-
ical substances.  Except  for  the  Niagara Falls plant, however, dissolved
(usually organic)  chemical  substances may not  be  significantly removed.
Therefore, the presence and concentration of dissolved chemical substances
in the  raw water  supply are of importance to the quality of treated water.

     Chlorination of the  water supply for disinfection purposes during the
treatment process can  produce chemical substances known as trihalomethanes
(THMs) if organic chemicals are present in the raw water supply.  Limits  on
allowable total THMs in treated water have been established by  both Canada
and the  U.S.   As  shown in Table 6, total THMs at eight U.S.  supplies sam-
pled in July 1978 were all below the allowable limit of 100 ppb.  The ranges
of total THMs observed at the two Canadian sources in 16 samples taken dur-
ing 1978-80 were all well  below the Canadian limit of 350 ppb.62   The U.S.
and Canadian  THM  limits  are comparable because different  test  procedures
are used.

     Canadian monitoring  of raw water for PCBs, organochlorine  pesticides,
dioxin, various hydrocarbons,  and radionuclides was conducted at Fort Erie,
Niagara  Falls, and  Niagara-on-the-Lake on the Ontario side of the  River in
1979 and  1980  and at St.  Catharines, which receives Lake Erie water by the
Welland Canal, in 1980.6S  Treated water was monitored at the same locations
except Fort  Erie  for the  same parameters except radionuclides.  This moni-
toring found  that  essentially  all  samples met  drinking water limits that
have been established or suggested.  The frequency of detection and concen-
trations of chemical substances were higher at Niagara Falls and Niagara-on-
the-Lake than  at  Fort  Erie  and St. Catharines.  However,  most  substances
detected at all locations  were at trace levels.   Table 7 is a comparison  of
some of the trace organics detected with suggested limits.64

     A Canadian study in 1977  of THM3 in 40 surface water supplies in Ontar-
io indicated  that  the  Niagara-on-the-Lake  supply had concentrations close
to the median  value for all plants.65  No change was detected in 1978-79.

-------
              76
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-------
                                                                       77
     The U.S.  Geological  Survey periodically  monitored raw and treated
water for pesticides and heavy metals during the 5-year period 1970-7566 at
Buffalo, Grand Island, Lockport Niagara Falls,  Niagara County Water District,
North Tonawanda, and Tonawanda.   These data indicate that observed concentra-
tions met applicable drinking water standards with pesticides usually below
detection limits.

     Monitoring of the Buffalo water supply in 1976 and 1977 as part of the
EPA National Organics Monitoring Survey found most trace organics were below
detection limits except THMs which were less than 40 ppb.67

     The City of Niagara Falls water supply has received the most extensive
monitoring as  the  result of  the discovery  of various  organic chemical  sub-
stances in  the intake  system.  This  contamination  is  alleged to be the  re-
sult of the migration of hazardous  wastes  from an adjacent landfill  on
Hooker  Chemical Company property.   This contamination is part of ongoing
litigation.

     The first  discovery of  some chemical  contamination  in the intake  sys-
tem may have  occurred as  early as  1969.68   Additional  contamination was
detected in  1978 and  1979.   At least 38 organic  chemicals were detected in
one or  more  samples of finished drinking  water  in  concentrations ranging
from traces  less than 1  ppb to 55 ppb.69   The  higher concentrations were
THMs.

     The City has taken a number of steps to eliminate contamination of the
water supply  including blocking  off parts of the shore segment of the in-
take system,  cleaning  intake structures and lines,  and  installing an emer-
gency intake  line  into the Tonawanda Channel.   Raw water is now obtained
from both the Chippawa and Tonawanda Channels.

     The City  now  monitors  regularly for trace organics in the water sup-
ply.  Powdered activated carbon is added in the treatment process to remove
organic chemicals.   Finished water quality is reportedly better than most
water supplies  obtained from industrialized rivers in other parts of  the
country.61  The water also reportedly meets Department of Health standards.61

-------
78
      Because of the highly toxic nature of some of the substances known to
 be disposed of in the  Hooker  landfill  only 200  yards  away  and  the detection
 of these substances in the groundwater and the contaminated intake system,
 it may be necessary to relocate  or  reconstruct  the  intake  system  to  prevent
 future contamination.   The City  has developed  several  alternatives for  pro-
 tecting the water supply but  has not yet implemented  any of them.

      At most Niagara  River water supply systems,  the locations of the  in-
 takes directly affect the quality of the supply.  As previously discussed,
 pollutant levels  in the Niagara  River  are affected by hydrologic  conditions
 that concentrate  pollutants along the  east shore of the Upper  River  and the
 eastern half of the Tonawanda Channel.  Therefore, except when wind condi-
 tions cause mixing in  Lake Erie, the City of Buffalo, Town of  Grand  Island,
 Niagara County Water  District,  Niagara  Falls,  Ontario and St.  Davids sup-
 plies would be expected  to have the best water  quality  [Figure  5].   The
 Town of Tonawanda  and Erie County  Water Authority intakes are located at
 mid-channel in the Upper River and  should usually have water quality nearly
 the same as the above  intakes.

      The intakes  for  the  Cities of Tonawanda,  North Tonawanda and Lockport
 are all  located  just  west of center in the Tonawanda Channel.  This loca-
 tion in the river cross-section  results in the minimum intake  of  pollutants
 for this river segment, but water quality is not as favorable  as  in  the West
 Channel.  The City  of Niagara Falls intakes  from  both the Tonawanda and
 Chippewa Channels.  Water quality is influenced by the ratio of withdrawals
 from each  channel.  Since the River is well mixed at Niagara-on-the-Lake,
 water quality is a function of river quality,  not intake  location.

      The horizontal stratification  of the river and its  effects on the qual-
 ity of public water supplies  were known as early as 1913.70  Several intakes,
 including the City of Niagara Falls, were relocated and  new intakes  located
 farther away than the closest channel  during  the 1940's  and 1950's in order
 to obtain better water quality.

-------
                                                                             79
Surface Water Quality

     Within surface waters, chemical substances partition themselves among
the water, the suspended sediments in the water, and the bottom sediments.
In addition, a fraction  of the chemical substances may also be bioaccumu-
lated by  aquatic  life.   All  four components of the aquatic system must be
monitored  to  develop  a  complete  picture of  the  extent of  chemical
contamination.

     Extensive monitoring  data  for all  four components  sampled by Canadian
agencies  in 1979  and  1980  were  recently published  in the 1981 Baseline Re-
port Update.71  Selected tables from the report are presented here to define
present water quality.  Data on fish contamination and the quality of public
water supplies were discussed in earlier sections of this report.

     The monitoring was designed to assess the status of water quality with
respect to applicable objectives, to determine temporal and spatial varia-
tions in  water quality,  and to  assist in  defining  sources of  chemical  sub-
stances.  Water quality monitoring locations are shown in Figure 6.   Bottom
sediment sampling locations are shown in Figure 7.   Biomonitoring locations
were previously shown in Figure 4 in the section  on fish  contamination.

     The  Niagara-on-the-Lake station defines  the pollutant load entering
Lake Ontario from the entire Niagara River system.   Variations in observed
water quality are the function of variations in point source discharges and
numerous hydrologic factors.

     Other key monitoring stations are at Fort Erie, the Buffalo River, and
in the  Tonawanda  Channel.  Under most hydrologic conditions,  the Fort  Erie
samples are representative of  Lake Erie water  not  contaminated by releases
of chemical substances from point and non-point sources in the Buffalo area.
Water quality would  be expected to be  similar  for the Thunder Bay (Lake
Erie), Fort Erie and Niagara Falls,  Ontario monitoring stations,  and all  of
the Chippewa Channel.   The Buffalo River station reflects the higher levels
of contamination  present in the Buffalo area and is  representative of  some
or the  pollutants that move down  the ease, side of  tha  Upper River  into the

-------
80
         f
          N
LEGEND
                                                                — ---0.0  SURVEY RANGE
                                                                          WATER TREATMENT
                                                                          PLANT INTAKE
                                                                          MONITORING

                                                                          FIXED POINT
                                                                          STATION
                                              Fort Erie boat ramp &
                                              Niagara Christian College
                                                                                     LU
                      L A K
                                         E R
     FIGURE  6.   NIAGARA RIVER  WATER QUALITY  MONITORING  LOCATIONS - 1979/80.

-------
                                                                              81
                                                                 Sediment  Sampling
                                                                      Station
                                        NiL-2
                                         NIL-3
                                          YOUNGSTOWN
                                         NiL-4
FIGURE  7.  NIAGARA RIVER  BOTTOM SEDIMENT  SAMPLING - 1979.

-------
82
 Tonawanda Channel.   The Tonawanda Channel  stations  demonstrate the horizon-
 tal stratification that  is  present  in this  channel  and also reflect local
 point and non-point source contributions along the  channel.

      As shown in Tables 8 through 12 taken from the 1981 Canadian report,71
 average annual water quality conditions in the Niagara River over the period
 1975-1980 met 1978 Great Lakes Water Quality Agreement objectives* for trace
 metals, pesticides, and trace organics.  Concentrations of some organics and
 metals exceeded these objectives in  less than 10% of the samples.

      Copper and  iron were the only metals to  frequently exceed the object-
 ives.   As  shown  in Tables 8 and 9,  both annual average concentrations and
 the percent of samples not meeting objectives for copper declined signifi-
 cantly in  the  lower  River since 1977.   Iron concentrations were higher in
 1979 and  1980  than in  previous years.   In the upper River, the percent of
 samples exceeding objectives was about the same in  1979 as in 1975.

      Spatial  differences in  average  metal  concentrations  were  noted
 [Tables 10 and 11] with  higher values observed in  the upper River and the
 Tonawanda Channel than in the Chippawa Channel.

      Most  organic  substances were non-detectable in water.   As  shown in
 Tables 10 and 12, a-BHC was detected in all samples.  Cyanide, y-BHC
 (lindane), dieldrin, and PCB were also frequently detected.

      In contrast to  the  water samples, PCBs,  pesticides,  and metals  were
 more frequently  detected in  suspended  sediments.  Occurrence  of these sub-
 stances in suspended sediments at Niagara-on-the-Lake are shown in Tables 13
 and 14.   Concentrations  of  PCBs, HCB, lead, copper, and zinc are the most
 significant.  There are no water quality objectives specifically applicable
 to suspended sediment.
   *  These are shown in the tables as IJC objectives.  The tables also show
      Ontario Ministry of the Environment (MOE) objectives that are slightly
      different for some pollutants.

-------
                                                                                                                                                           83
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  84
  TABLE 9 .
PERCENTAGE OF WEEKLY WATER SAMPLES VIOLATING
1978 AGREEMENT OBJECTIVES IN THE NIAGARA RI-
VER, AT N1ACARA-ON-THE-LAK.K DURING 1975-1980
'ARAMETER
CADMHrM-T
CHKOMRfM-T
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ug/L
0.2
50
5
300
25
25
30
0.2


MOE
OBJECT
ug/L
0.2
100
5
300
25
25
30
0.2
5

% VIOLATIONS AT NIAGARA-ON-THE-LAKE
1975
0
0
16
0
0
0
0
-

1
1976
6
0
61
20
0
0
0
-


1977
6
0
79
15
0
2
2
-

•
1978
o
1
1979
5
0 ! 0
I
40 33
i
19 41
0 0
0
0
0
0
1
0

1
1
1980*
0
2
17
34
0
0
0
o

i
  - incomplete data sec (includes data from Jan 3- Oct 7/80)
Source:  Reference 32

-------
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-------
     86
    TABLE  11.
SUMMARY OF 1979 UPPER NIAGARA RIVER

    MEAN TRACE METAL DATA  (mg/L)
           ('WAT f K1
PARAMETER
            RIVER  RANGE

As-DTSS
SC-DISS
•ijz-EXT
C
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-------
    TABLE 13.
     fMMARY OF TRACE  ELF.MENT  CONCTr.'TTAT K>;i (nr./g)  IN  SUSPENDED
   SEDIMENT AT NIAGARA-ON-THE-LAKE
PARAMETER
CADMIUM-EXT
LEAD-EXT
CQBALT-EXT
COPPER-EXT
ZINC-EXT
NICKEL-EXT
CHROMIUM-EXT
1978
N.OBS.
13
13
13
13
13
13
13-
l
MEAN
2.4
80.0
6.6
4G.O
177.0
29.0
39.0
S.D.
0.8
28.6
3.3
15.1
44 .0
16.0
31.0
1979-80
N.OBS.
35
35
35
35
1
35
35
35
MEAiN
2. A
58.0
6.5
44.0
163.0
24.0
30.0
S.D.
1.3
18.9
2.3
37.0
50.0
. 12.0
12 .0
Source:  Reference  32

-------
                                                                                     89
TA:it.!: 14 MEAN CONCENTRATIONS OF  ORGANIC CONTAMINANTS  (ng/g) IN SUSPENDED
         SEDIMENT  AT  NIACAKA-ON-THE-LAKF.-1980
PARAMETER
PCB (TOTAL)
ALDR1N
DIELDFUN
«X-BHC
tf-BHC(LINDANE1
c*-CHLORDANE
t-CHLORDANE
o.p-DDT
p.p-DDT
p.p-DDE
p.y.-TUE(UDD)
ENDRIN
HEPTACHLOR
NO. OF
SAMPLES
24
24
24
24
24
24
24
24
24
24
24
24
24
HEPTACHLOR EPOXIDE 24
HCb(packed col)
HCB(CAP.COL)
M1REK
/3-ENDOSULFAN
METHOXYCHLOR
°<-ENDOSULFAN

* 24(23)
18
24
24
1 T_
24

CONFIRMED DETECTIONS
NO.
24
0
21
18
10
14
20
8
18
24
13
1
0
14
24(23)
18
17
0
17
1
MEAN (ng/R)
642
N.D.
4
11
2
1
2
3
13
19
2
L 1
N.D.
2
160(51)
83
6
L 1
10
L 1
i
ST. DEV.
534
—
2
15
4
3
2
5
16
10
2
—
—
3
535(58)
78
7
—
19
-^

            *     Oiu  hij'.'1 v;;liu'  olirun.ilril

          N.D.   Values net detected

          Data  set from Jan  5  - Auj; 19/1980

          IVtocLion Limit  v.ilm-s c-niori-d ns  zero in mean calculations

          L -  les-; than detoction limit
       Source:   Reference  32

-------
90
      Analysis of bottom sediments collected from 25 stations [Figure 7] in
 1979 detected the widespread  occurrence  of PCBs [Table 15].  Almost  all
 stations had PCB contamination exceeding Ontario Ministry of the  Environ-
 ment guidelines for prohibiting  disposal of  dredged  spoil in open waters.
 The highest concentrations  were detected  in Buffalo Harbor,  Tonawanda  Chan-
 nel, and the lower  River.

      Significant contamination of sediments with organochlorine pesticides
 was also detected.   In  the upper River,  only chlordane, DDE and DDT were
 frequently observed and then at low concentrations.   Additional pesticides
 and much higher concentrations were  observed in the lower River north of
 Queenston indicating that section is  an accumulation  point for  contaminated
 sediments.

      No chlorophenoxy acid herbicides or  chlorophenols  were  detected in the
 bottom sediments.

      Heavy metals were detected  in all bottom sediments.  Copper,  lead, and
 zinc exhibited the  highest concentrations  but all  metals reported except
 cadmium exceeded MOE  dredged  spoil  disposal  criteria at at  least  one  sta-
 tion.  The  highest  metal  concentrations  were detected  in the Upper Tona-
 wanda Channel.

      Freshwater clams were  exposed to Niagara River and Lake Erie waters
 for  16  days  in  1980 at several  locations  [Figure 4].  Contamination with
 PCBs and organochlorine pesticides was the  highest  in the Tonawanda  Channel
 [Table 16].

      Algae collected  from  similar Lake and River locations  [Figure 4] were
 analyzed for heavy  metals  and arsenic.   Again, the highest contamination
 was found in the Buffalo River and Tonawanda  Channel  [Table  17].

      The 1981 Baseline  Report Update concluded that "the major portion of
 the  loading  of  PCBs and some pesticides  occurs adjacent to  and downstream
 from Grand Island,  New York."72   The high concentration of  PCBs observed in

-------
                                                                                                                                           91
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94
 Buffalo Harbor in bottom  sediments  and of heavy metals  in  algae  suggest
 that this area could  also contribute significant loads of PCBs and heavy
 metals.

      Bottom sediments in  large  areas of Lake Erie  have elevated levels  of
 persistent chemical  substances  as shown for PCBs  in Figure 8.73

      Persistent toxic substances can be transported long distances by sedi-
 ments as shown by the distribution of mi rex in the  bottom sediments of Lake
 Ontario [Figure 9].73  Highly contaminated  bottom  sediments dredged from
 Buffalo Harbor and  the  Buffalo  River were disposed of in a  shallow, open-
 water  dumping area  west  of Bethlehem Steel in Lackawanna for many years.
 It appears possible that under  previously discussed adverse  hydrologic con-
 ditions on Lake Erie, bottom sediments in eastern Lake Erie  could  contribute
 significant loads of  persistent chemical  substances such as PCBs  to the
 Niagara River both  in the suspended sediments and  water.   Some of these
 sediments may then  be redeposited in quieter river  sections adding  to con-
 tamination from local point and non-point sources.

 AIR QUALITY

      Traditional  air  pollution  parameters  are used to define present air
 quality and to show the major  air quality improvements that have occurred
 over the past 15 years.   The limited data on chemical  substances in ambient
 air are discussed.   No  data on air  quality in homes were available  other
 than for homes involved in the  Love Canal litigation.   Because of the liti-
 gation, these data are not presented.  Occupational exposure to air pollution
 is beyond the scope of this study.

      The most recent published  data74 on air quality in the  Niagara Frontier
 Air Quality Control Region (Erie and Niagara Counties) showed that downward
 trends  in  air  pollution,  as measured by traditional parameters, continued
 through 1979.  Monitoring was  conducted by the DEC at 10 continuous moni-
 toring  sites and 47 manual sites in the AQCR in 1979.

-------
95
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96

-------
                                                                       97
     Sulfur dioxide  levels  have declined substantially over  the  past 10
years.   Whereas sulfur  dioxide  levels were in contravention of the annual
mean standard of  0.03  ppm prior to 1975  in  Niagara Falls, Buffalo,  and
Lackawanna, all  stations are below the standard.   The decline has been most
significant at stations where 1970 averages were about 0.05 ppm and are now
about half  that  level.   These declines are the results of  enforcement of
fuel regulations and application of industrial emission controls.

     Major reductions in total suspended particulate (TSP) levels have also
occurred over the past 15 years.  At Niagara Falls, average TSP levels have
decreased from about  120 ug/m3  to about  50 ug/m3  at one key station and
from 270 to 110 ug/m3 at another.  In  Buffalo, similar reductions from 260
to 95 ug/m3 at  one site and 80 to 46 ug/m3 at another were observed.  The
health-based ambient air standards  are 75 ug/m3 for the  annual geometric
mean and 260  ug/m3 for the 24-hour average.   Most stations now meet these
standards whereas major contravention of standards was common 10 years ago.

     These reductions  in TSP levels  are particularly significant with re-
spect to such substances as benzo(a)pyrenes, other organic chemicals, and
heavy metals which may  be present in  the  particulates.   Sources of such
particulates include chemical plants,  steel mills,  carbon product manufac-
turers, and coke ovens.   A study conducted from 1963 to 1970 showed a rela-
tionship between  air  pollution  from the coke oven industry and the health
of the  general population.75  Coke  ovens were identified as  a source of
high levels of suspended particulates which have since been reduced by con-
trols on the coke ovens and on other industrial and utility sources.

     Carbon monoxide (CO)  levels  have declined throughout  the  AQCR as a
result  of  auto  emission  controls.   Automobiles are  the  most important
source  of CO  although  there are significant  emissions of CO from carbon
products plants  in the Niagara Falls area.  There have been a few contraven-
tions of the  8-hour standard of 9 ppm in the Niagara Falls area in recent
years.   Contraventions  are  slightly more  frequent in the Buffalo  area.
Annual  CO averages are now low (1 ppm or less) areawide.

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98
      Nitrogen oxides are not a  problem  in the AQCR.  Most  sites  average
 less than half the  primary  standard  of  0.05 ppm.   Slightly higher levels
 occur in Buffalo  than in Niagara Falls.

      Lead monitoring began in 1973.  A decline in lead levels occurred be-
 tween 1973 and 1977 with relatively constant levels since 1977.   All loca-
 tions are well below the standard of 1.5 ug/m3.  There are no major indus-
 trial sources of  lead emissions  in the study area.

      Short-term ambient air monitoring for vinyl chloride was conducted in
 June 1974  in the vicinity of the Goodyear polyvinyl chloride plant  in
 Niagara Falls and at three  residential locations in Buffalo.76  Vinyl  chlor-
 ide was detected downwind of the Goodyear plant at concentrations up to 40
 ppb in a Niagara  Falls residential area.   One sample downwind of  the Buffalo
 Avenue industrial complex in Niagara  Falls reportedly contained 28 ppb vinyl
 chloride.   No vinyl  chloride was detected in the Buffalo  residential  areas.
 EPA has not established an  ambient air criterion for vinyl  chloride but has
 established National Emission Standards  for Hazardous Air Pollutants (NESHAP)
 for  industrial emissions of vinyl chloride.  Sources are required to limit
 their emissions to total volumes or concentrations dependent upon the source
 process involved,   The  emissions  concentrations allowed  are in the 10 ppm
 range.   New  York  DEC  uses  an Acceptable Ambient Level  (AAL) of 0.41 pg/m3
 to evaluate sources of vinyl  chloride emissions.77

      Goodyear is the  only  reported source of vinyl chloride emissions  in
 the  study area.   At the time of  the  1974 sampling,  Goodyear1 s emissions
 were estimated at 4 tons/year.76  They are  now  reported as 32 tons/year.78
 No current data were identified  to evaluate present ambient levels of vinyl
 chloride.

      During the 1974 vinyl  chloride sampling near the Buffalo Avenue indus-
 trial complex, the  study team experienced  eye,  nose, and throat irritation
 which they attributed  to emissions of chlorine  or  other chemicals  from  the
 nearby plants.76  They also observed corrosion and other damage  to aluminum

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                                                                       99
windows and doors and to paint in the residential area and to aluminum lamp
poles, iron guard  rails,  and telephone guy wires that they attributed to
emissions of chlorine in the industrial complex.

     There are several  plants  in the Niagara Falls  complex  that produce
large volumes of chlorine or chlorinated compounds.  Monitoring  of ambient
chlorine levels during  the past  several years by the Niagara County Health
Department indicates that maximum  levels  approximate and sometimes exceed
Acceptable Ambient  Levels.79  Ambient  levels were believed to be higher  in
the past.  The DEC has initiated a case-by-case evaluation of chlorine emis-
sions and  an associated abatement program.  Present  chlorine emissions are
estimated to be in the range of several hundred tons per year.78

     A Canadian study of ambient levels of benzo(a)pyrene (BaP)  and benzo-
(k)fluoranthene (BkF) in  11  Ontario communities was conducted in 1971 and
1972.80  The highest  levels  observed (116 |jg BaP and 176 jjg BkF/1,000 m3)
were in Wei land on the west edge of the Niagara Frontier study area.   These
were attributed to emissions from a graphite electrode production facility.
There are  several  similar  plants in the Niagara Falls  industrial  areas.
Coke oven  emissions are also known  to  contain BaP.   The DEC has  not estab-
lished Acceptable Ambient  Levels for either of  these substances although
BaP is considered a high toxicity air contaminant.77  The current DEC emis-
sions inventory does not list any significant sources of BaP.78   No current
ambient data on BaP were identified during this study.

     Atmospheric levels  of pesticides were evaluated at nine U.S. cities by
a 1970 study.81  Only low levels of DDT were detected at the four sampling
stations in the Buffalo  vicinity.  DDT use has been discontinued.  No recent
pesticide sampling data  were identified.

     More than 200  atmospheric  samples obtained during 1968 and 1969 from
the Buffalo area were analyzed  for 18 trace elements including  chromium,
copper, iron, lead, nickel,  and silver.82  Chromium, copper, nickel, and
silver concentrations were low  with maximum samples less than 0.5 pg/m3.
Lead ranged from 1.6  to 7.2 |jg/m3,  much higher than current levels.   Iron

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100
 was the highest,  ranging from 0.1 to 12.64 ug/m3.   These  samples  were taken
 during a  period  when total suspended particulates were  at least double
 present levels.   No comparable current data on  metals  were discovered during
 this study.

 RADIOLOGICAL ASPECTS

      Federal government activities  associated  with the Manhattan Project
 during World War  II to develop an atomic bomb left several sites  in the Nia-
 gara Frontier contaminated with low-level  radioactivity.   Remedial  measures
 have since  reduced  these  contaminated areas to four sites.  Three of the
 sites are in Tonawanda  and the fourth is north of Niagara Falls.   Uranium
 ore residues (tailings) are  stored  at the Niagara Falls Storage Facility
 (NFSF) on the site of the old Lake Ontario Ordnance Works and at  a landfill
 and an  industrial  site in Tonawanda.   Low-level  radioactive wastewaters
 were injected into  the  groundwater  at a Tonawanda industrial site.   These
 sites are discussed in more detail in Sections  VII and VIII.

      The potential environmental  hazards associated with  these contaminated
 sites include emissions of radon gas to the atmosphere and the contamina-
 tion of  surface  runoff  or groundwater with radium or uranium.   Recent en-
 vironmental  monitoring  has  indicated that offsite radiation levels do not
 pose a hazard to  area residents.83  84  Onsite  contamination  limits the  use
 of the sites and long-term remedial measures are needed  to insure that no
 spread of the contamination occurs.

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                                                                       101
                    V.   SOURCES OF CHEMICAL SUBSTANCES
     Chemical substances  are  released to the environment  of  the Niagara
Frontier  from  numerous point  and non-point  sources.   Important point
sources include industrial manufacturing plants, municipal  wastewater treat-
ment plants, and hazardous waste management and/or disposal sites.  Important
non-point sources include contaminated groundwater, dredged spoil disposal,
contaminated lake and river bottom sediments, and urban runoff.

     In the  following discussion, additional  details are presented on each
type of source  including  the pathways by which  chemical substances are re-
leased to the environment.  Details are presented  on the preparation of  an
inventory of all known and potential point sources and the subsequent rating
to identify major sources of chemical  substances.  Lists of major industrial,
municipal, and  hazardous  waste  facilities are presented.   Detailed discus-
sions  on  the major  sources  are presented by area in  Sections  VI-VIII.

POINT SOURCES

Industrial

     Industrial  manufacturing plants are the most important sources of chem-
ical substances  in the Niagara  Frontier.  Many  of  these facilities handle,
transport, consume, and produce large volumes of chemical  substances.   It is
inevitable and  unavoidable that some  of these  substances  are released to
the environment from such facilities.

     Industrial  wastewaters are a common pathway for transport of chemical
substances from industrial plants.   These include process  wastewaters,  cool-
ing water, and  miscellaneous  utility  and other waste streams.   The volume
and types of chemical  substances  in the wastewaters are  affected  by the
process/products, in-process  controls, and wastewater treatment units present
at the facility.

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       Wastewaters may  be either discharged  directly  to  surface waters  after
  treatment  (if  required) at the industrial plant or they may be discharged
  to  a  municipal  sewer system for treatment at a municipal wastewater plant
  (indirect  discharge).  In the  latter case,  the  volume and types  of chemical
  substances  reaching  surface waters  are  also  affected by the  type  and  effi-
  ciency of  treatment provided at the municipal plant.

       Because  large  volumes of  chemical  raw materials or products  are  often
  handled  or stored, spills  and  leaks of chemical substances may occur within
  an  industrial plant site.   Stormwater runoff or groundwater may become con-
  taminated  in  such  cases and transport these  substances off site.   This  was
  more of  a  problem in  the past  when material handling and maintenance proce-
  dures  were not adequate.  The  use of best management  practices (BMPs) for
  control  of spills and leaks has reduced this problem.   However, past spills
  and leaks  may have seriously  contaminated a plant  site, often with chemi-
  cals no  longer used or  produced at the site.

       Many  industrial  plants,   especially chemical manufacturers,  generate
  large  volumes of hazardous wastes  that  may  contain chemical substances.
  These  wastes are often  stored  and/or  treated on site prior to ultimate dis-
  posal.   Disposal may  be either at the industrial plant site or at some other
  location.   Both  storage and treatment activities are  potential sources  of
  spills or  leaks of chemical substances.  Disposal poses a  higher  hazard  for
  release  of chemical   substances to  the  air,  surface water or groundwater.
  This  was especially  true  of past on-site  disposal  practices that did not
  adequately contain hazardous wastes.

       Many  industrial  processes emit  air pollutants to the atmosphere.   As
  in  the case of industrial  wastewaters,  the  volumes and types of  chemical
  substances emitted  are a  function  of factors  such  as  process/product com-
  binations  and  air pollution controls.

  Municipal
        Municipal  wastewater treatment plants that receive significant indus-
  trial  wastewaters  are  also important  sources  of chemical  substances. Com-
  bined  sewer overflows and  sewer system  bypasses are also important.

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                                                                       103
     Municipal wastewater treatment  plants  usually treat wastewaters con-
sisting primarily  of domestic  sewage  and commercial wastewaters.   Such
wastewaters usually  contain  low levels of some chemical  substances used in
the home and  in commercial establishments.  If the volume of wastewater is
large, the contribution of chemical substances may be significant.

     In industrial areas  such  as Buffalo, Tonawanda, North Tonawanda and
Niagara Falls, the municipal  wastewater treatment plants also receive major
volumes of  chemical  substances  in industrial  wastewatars.  The types and
volumes of  these substances  discharged to surface waters  are a function of
the type  and efficiency  of  treatment provided  in the  municipal  plant.

     Parts of Buffalo, North Tonawanda and Niagara Falls are served by com-
bined sewer systems that convey storm runoff as well  as wastewaters.   During
dry weather, all sewer flows are usually treated.  During wet weather, how-
ever, the  sewer flows exceed the  treatment plant capacity and mixed  runoff
and wastewater overflow from the system to surface waters either at combined
sewer overflow points  or  in treatment plant  or  pumping  station bypasses.
This results  in the  discharge  of  untreated wastewaters  that  can  contain
significant volumes of chemical substances.

     Part of  the chemical  substances removed in the treatment process is
concentrated in sludges that may be classified as hazardous wastes if suffi-
cient toxic  substances  from  industrial  sources  are  present.  Sludge dis-
posal poses  a potential for  release  of these  substances  to the environment
in the same manner as hazardous waste disposal.

Hazardous Waste Disposal Sites

     Hazardous waste disposal sites  have the  potential to be major sources
of chemical  substances.  Many hazardous wastes contain high concentrations
of chemical  substances.  If  not adequately contained, these substances may
be released  to  the environment through ground and surface waters and air
emissions.

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104
      Most hazardous waste disposal sites in the Niagara Frontier are land-
 fills.   Hazardous wastes have been  placed  in the landfills  in  liquid  or
 solid form, in bulk,  or  in  containers.   Ultimately,  liquids  move  from  the
 landfills into the environment  unless  adequate containment measures have
 been used as is now required for active landfills.  This  movement  is in the
 form of  leachate which may  be  the hazardous waste liquid itself or, more
 commonly, the  liquids diluted by precipitation or groundwater percolating
 through the landfill.

      Because containment measures were not adequate at many of the earlier
 landfills, contamination  of  ground and  surface waters is  a major problem at
 a number  of locations.  If a landfill contains large volumes of persistent
 chemical substances, the landfill will  continue to be a  source of these
 substances for many years unless remedial measures are initiated to minimize
 or eliminate leachate migration.

      Inactive hazardous waste landfills  are  a major problem.  These were
 usually the earlier  sites that  had  the poorest containment.   Records  of
 what hazardous wastes are present  at  a site are often  sketchy or non-
 existent.  Because of the age  of the  landfills, chemical substances have
 had a longer time to migrate into the environment.

      Hazardous waste disposal sites  may be located at an industrial plant
 (onsite  disposal)  or at another non-industrial location  (offsite dis-
 posal).   The  offsite  disposal  facilities include sites operated by an  in-
 dustry  for their own waste  disposal; commercial or public landfills that
 primarily received non-hazardous wastes such as household trash and garbage,
 but also some hazardous wastes;  and the commercial hazardous  waste facilities
 receiving  wastes  from many  sources.   Onsite  disposal  is discussed with
 industrial point sources in  this  report while  the offsite disposal  facili-
 ties are discussed separately.

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                                                                       105
NON-POINT SOURCES

Contaminated Groundwater

     Contaminated groundwater  is an important non-point source of chemical
substances at several  locations  in the Niagara Frontier.   This contamina-
tion is  primarily the  result of spills or  leaks of chemicals at  industrial
plants or of  inadequate  hazardous  waste disposal practices (both on- and
offsite).

     A number of organic  chemical  substances used or produced at Niagara
Frontier industrial facilities are readily transported through groundwater
aquifers.  Thus, over time, these substances may be transported for substan-
tial distances from the point of contamination of the groundwater.

     Three major pathways for movement of chemical substances from contami-
nated groundwater to  surface  waters  are present  in  the  study  area.   The
most common  pathway is  the normal discharge of  groundwater to  surface
streams at the interface of the aquifer with the waterway.

     In  the Niagara Falls  industrial area, contaminated groundwater  infil-
trates into both industrial and municipal  sewers.  This results  in the di-
rect discharge  of chemical  substances  to the Niagara River through indus-
trial outfalls  and  the discharge of additional  chemical  substances to the
Niagara Falls wastewater treatment plant.

     At Niagara Falls, several industrial water supply wells draw contami-
nated groundwater.  Chemical  substances  present  in  the water  supply are
eventually discharged  directly to the  Niagara  River without treatment.

     As discussed in more  detail  in the following section  on  industrial
point sources,  infiltration of contaminated  groundwater  into  industrial
sewers and the use of contaminated well  water in the  Niagara Falls area may
account for more than one-half of the industrial direct discharges of organ-
ic chemical substances and  more  than one-third of the discharges of these
substances from all  point sources.

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106
      The extent of the  contaminated  groundwater problem is  only partially
 defined at this time.   Additional  studies  are  underway or proposed to deter-
 mine the area!  extent of contamination,  define what chemical  substances are
 present, define flow  paths  and rates,  and  develop plans for  remedial  measures.

 Dredged Spoil  Disposal

      Past and  present  dredging practices  associated with maintenance of
 harbors and navigation  channels are  believed  to be significant sources of
 chemical substances.   Contributions of chemical  substances from disposal of
 dredged spoil  and dredging  activity are not defined at this  time.

      Maintenance of the harbors in Buffalo and Tonawanda and the navigation
 channels in the Buffalo River,  the Upper  Niagara River, and the Tonawanda
 Channel requires annual dredging to remove accumulated  sediments and main-
 tain design depths.  The accumulated  sediments are contributed by surface
 runoff from upstream agricultural  areas,  urban runoff, industrial waste-
 water discharges,  and shifting of  bottom sediments from adjacent waterways.

      Sediments dredged  from the channels  are  known as  spoil  and must be
 disposed of.   The  early practice  was to  transport the  spoil  in hopper
 dredges to dumping grounds in shallow open-water areas where  it was dumped
 and allowed to settle to the bottom.   Two  disposal areas were used, a large
 area about 0.7  by  1.4  miles immediately west  of Bethlehem Steel in Lacka-
 wanna  and  a  smaller  area adjacent to Buckhorn  Island at Niagara  Falls.
 Spoil is now disposed of by pumping it into diked disposal areas.  Two diked
 areas in the Buffalo  Harbor area have been filled and a diked area adjacent
 to Bethlehem Steel  is in current use.

      Dredged spoil  in the study area is known  to be contaminated with chem-
 ical substances including  PCBs, mercury,  and  other heavy metals.  Samples
 of bottom  sediments  at locations  to be dredged have shown such contamina-
 tion.  As  discussed  in Section IV, bottom sediments  are  contaminated at
 most locations  within  the  study area as  detected  by  monitoring studies.

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                                                                       107
     Contamination of  bottom  sediments  was probably much  higher  than at
present during the time open-water disposal of dredged spoil was practiced.
Discharges of chemical  substances  to area waterways were  larger  than at
present because less  wastewater treatment was provided.   Gross pollution of
the Buffalo River was  present.   This pollution also impacted the Buffalo
Harbor and Black Rock Canal.

     The large volumes (more than 500,000 yd3/year) of contaminated dredged
spoil disposed of in  the past in shallow open waters continue to be exposed
to resuspension  in lake waters by  Lake  Erie  storms and associated wave ac-
tion.  During the time the disposal  area was active, a nearby water supply
intake was periodically affected by pollutants from the spoil area disturbed
by storms.  As discussed  in Section  IV, pollutants dispersed by storms can
be transported into the Niagara River by Lake currents.

     Dredged spoil is  currently disposed of  in a diked area  that serves as
a settling basin.  Solids settle to the bottom leaving free liquids  that
may contain chemical  substances present in the spoil.   Dikes are constructed
of relatively permeable  rock  rubble that would allow this  liquid to  seep
into adjacent waterways  (Buffalo  Harbor or  Lake Erie). The  settled spoil
has a  low  permeability but leaching of contaminants from  the spoil could
occur if precipitation is allowed to pond on the surface.

     Dredging of the  navigation channels to remove bottom sediments results
in the resuspension of some of these sediments.  This may  release chemical
sediments into the water.   Where currents exist,  as in the Niagara River,
the suspended sediments would be immediately swept away.   The significance
of current dredging and  spoil  disposal  practices as  sources of chemical
substances are not defined in any of the literature reviewed for this study.

Bottom Sediments

     Bottom sediments  in  Lakes  Erie and Ontario and in the  Niagara River
and its tributaries are contaminated with varying levels of persistent chem-
ical  substances  (see Section IV).  Heavy metals, PCBs and  persistent  pest-
icides are of importance because these substances are bioaccumulated in the

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108
 aquatic food chain.  Sediments  in  shallow areas of Lake Erie  and in the
 River and tributaries are  subject  to resuspension  and transport under ad-
 verse hydrologic conditions such as wind storms  and floods.

      Much of the chemical substances present in the sediments may have ac-
 cumulated years ago when discharges  of these  substances  were much larger.
 This would be especially true of PCBs, DDT, and mercury.   Substantial con-
 tamination of sediments still exists although point sources were basically
 eliminated years ago.

      Contaminated bottom sediments may be a major source of the persistent
 chemical substances currently observed in suspended sediments in the Niagara
 River.   None of the literature reviewed specifically addressed  this possibility.

 Urban Runoff

      Surface runoff from urban areas following precipitation events or snow
 melt is contaminated with low levels of chemical substances including heavy
 metals and pesticides.  This  runoff reaches surface waters through  storm
 sewers or drainage ditches.   It may also flow  through combined  sewers caus-
 ing overflows of untreated wastewaters as discussed in the municipal point
 source section.

 DEVELOPMENT OF AN INVENTORY OF POINT SOURCES

 Industrial

      The first step in the identification of major  industrial point sourcas
 of chemical  substances was to develop  an  inventory of all  known  industrial
 facilities in Erie  and Niagara  Counties.  This  was primarily done with the
 assistance of EPA and NYDEC computer files.

      The EPA Region II Facilities Index System (FINDS)85  was used to prepare
 a comprehensive  inventory  of more  than 10,000 manufacturing, wholesale and

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                                                                       109
retail trade,  commercial,  and  service  facilities in  Erie and Niagara
Counties.86  The inventory included all  facilities in the Dun and Bradstreet
file, all State Pollutant Discharge Elimination System (SPDES) permits, all
major sources  of air pollution, and  all  known hazardous waste disposal
sites.  The geographical distribution of these facilities was evaluated and
the boundaries of the detailed study area selected.   The inventory was also
reviewed to evaluate what types of facilities were present in the area that
could be potential sources of chemical substances.

     A second  FINDS  inventory,  containing about 940  selected  facilities in
the detailed study area, was prepared with computer  assistance to  identify
those facilities (primarily industrial manufacturing plants) with the poten-
tial to  be  significant  sources of chemical  substances.87  This inventory
was compared with EPA and DEC lists of wastewater dischargers (SPDES permit
holders), air pollution sources, hazardous waste disposal sites (active and
inactive), hazardous waste management permit applications, and the DEC In-
dustrial Chemical Survey (ICS)  to eliminate  facilities with no significant
chemical substances  activity.   This  reduced  list was used to select files
for detailed review during the file search.

     Another EPA Region II computer system, MAPS, was used to plot the loca-
tion  of  all  wastewater discharges, air emission  points,  hazardous waste
disposal sites, ambient air and water quality monitoring stations, and pub-
lic drinking water  supply  intakes on transparent overlays  keyed  to USGS
topographical maps.86  This facilitated identification of any duplicates in
the  inventory  and assisted  in  defining the  relationships between point
sources  and  monitoring points,  water intakes, and  other topographical
features.

     Rating criteria were then developed to define the relative significance
of actual or  potential  releases of chemical  substances to the environment
through air, water,  or hazardous waste pathways.  The criteria were develop-
ed for those specific pathways for which data were available for most signif-
icant sources.   These  included direct discharges of wastewater,  indirect
discharges to  municipal  sewer  systems,  air emissions,  chemical substances

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110
     used  or  produced,  hazardous  waste  generation,  management  and  disposal,  and
     site  contamination.

           The rating criteria were designed to group facilities by their relative
     degree of activity for each pathway.  The intent was to identify the facil-
     ities with the most significant potential for release of chemical substances
     to  the  environment so that they  could  be reviewed  in  detail.  The criteria
     were  not  designed  to  compare a facilities rating with any fixed numbers to
     suggest  that  the  facility  was "good" or  "bad".  A  high  rating number  indi-
     cates that the facility has a significant potential for release of chemical
     substances to  the  environment but does  not necessarily mean there are  any
     major environmental problems associated  with the facility.  For instance,
     both  major commercial hazardous waste management facilities received moder-
     ately high  ratings because of the  large  volumes of chemical substances  and
     hazardous  wastes  handled.   However, the  known  releases of chemical sub-
     stances to the environment from both sources are relatively small in compar-
     ison  with other major sources.

           Wastewater discharges to surface waters were assigned ratings based on
     the  relative  magnitude of  the total loads of organic priority  pollutants*
     and of heavy metals** discharged [Table  18].  The ratings were  based on data
     reported in recent SPDES permit applications.  These  data were  supplemented
     by  recent EPA and  DEC compliance monitoring samples and by engineering  stu-
     dies  performed  by  the permit applicant.   Daily maximum values  were used
     because  long-term  data were  only available  for a  few  sources  and then  only
     for  a few pollutants.   The daily maximum values  reported  in the permit ap-
     plications usually represented  only a few samples, often only  one.  Long-
     term  averages  could thus be  significantly different (higher or  lower)  than
     these single samples.
      *   Priority pollutants in this report are synonymous with the 65 toxic
          pollutants defined pursuant to Sec. 307(a) of the Clean Water Act and
          published in 40 CFR Part 401.15.
     **   As used in this report, heavy metals does not include iron as iron is
          not an EPA priority pollutant.

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                                                              Ill
                       Table 18

         WASTEWATER DISCHARGE RATING CRITERIA


           	Total Load (Ib/day)	
Rating*    Organic Priority Pollutants    Heavy Metals

              Direct Wastewater Discharge
0
1
2
3
4
5

Flow
(mdg)
50
Rating*
Organic Priority
Pollutants Present Heavy Metals
<1
1-2
2-5
5-10
10-25
>25


Present
Indirect Wastewater Discharges
<0.1
0.1-0.5
0.5-1.0
1.0-2.0
2.0-3.0
>3.0
0
1
2
3
4
5
0
1
2
3
4
5
   Rating values were assigned for both the organic
   priority pollutants and the heavy metals and summed
   to get the total rating for direct discharges.   The
   indirect discharge total is computed in the same
   manner.

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112
        Indirect  discharges of  priority pollutants to  municipal  treatment
   plants  were  also  rated.   Data were generally not available on priority pol-
   lutant  loads in these discharges.  The  flow rate was  known in most cases,
   however,  and the types  of  pollutants present  (organic priority pollutants
   and/or  heavy metals) could be inferred  from plant  operations  when specific
   data  were unavailable.  The rating criteria  [Table  18] were  based on  flow
   rate  and  presence  of pollutants.

        An EPA  Permit  Compliance System  (PCS) computer listing of SPDES  permits
   indicated there were 140 active  permits  for wastewater discharges in Erie
   County  and 61  in Niagara  County,  a  total of  201.   Sixty-six of  the  Erie
   County  permits were  in  the detailed  study  area as  were 42 Niagara County
   permits,  a total  of  108.   Most  of the  permits not in the detailed study
   area  were for  scattered  municipal  wastewater discharges or minor  industrial
   discharges.   Of the total of 201 permits, 57 were  for municipal  wastewater
   treatment plants  and the remainder for  industrial or  commercial facilities.
   In the  Erie County  portion of  the detailed study area,  9 of the permits
   were  for  municipal  facilities and 57  for industrial or commercial  facilities.
   In Niagara County, the corresponding figures were  11  municipal  permits  and
   31 industrial  or  commercial permits.

        Data on air emissions were obtained from the  DEC Air Pollution Source
   Management System,  a computerized file  of  all  air pollution  sources.  The
   file  was programmed to  identify all  air pollution  sources in Erie and Nia-
   gara  Counties and  to list  all  process  emissions for each source.  There
   were  828  sources  in the  Erie  County  inventory, of which only  344  had  process
   emissions.78  The remainder were primarily  combustion sources such as heat-
   ing boilers.  There  were  139 sources which listed some  emissions  of air
   pollutants of concern.*  The other  process  sources  emitted only criteria
   pollutants such as  particulates  or  sulfur  dioxide.   Process sources dis-
   charging  more than 1 ton per  year of air pollutants of concern  totalled  74.
     *  For this report,  air pollutants of concern are defined as those air
        pollutants listed by the New York Department of Environmental  Conserva-
        tion as low,  medium or high toxicity air contaminants77 plus carbon
        monoxide.

-------
                                                                       113
     There were 180 air pollution sources in the Niagara County inventory,
of which 99 had process emissions.   There were 57 sources emitting air pol-
lutants of concern with 39 sources each emitting more than 1 ton per year.

     Criteria used to assign relative ratings to emissions of air pollutants
of concern are shown  in Table 19.  No distinctions were made between types
of substances or  their relative potential toxicity.   The distribution of
sources by emissions volume is also shown in Table 19.

     The relative significance of the use, production,  storage, and handling
of chemical substances at a facility was assessed based on responses to the
DEC Industrial Chemical Survey (ICS).  This survey, begun in 1976 and period-
ically  updated,  requested industrial facilities to  report  their average
annual  use and average storage  volume of selected chemicals  of concern.
These chemicals include most of the  priority pollutants and hazardous sub-
stances defined by ~PA regulations plus a few chemicals of special  interest
in New  York.  Questionnaires  were initially sent to SPDES permit holders.
They have also been sent to industrial facilities that discharge wastewaters
to municipal  sewer  systems.   The  survey of these  indirect dischargers is
continuing and has not been completed.

     Some facilities  responded  negatively (they did not use chemicals of
concern).   Positive responders were those facilities indicating some use or
production of chemicals of concern.   The Industrial Chemical  Survey computer
file listed 131 positive responders in Erie County of which 117 were in the
study area.88  This is an incomplete list as DEC is in the process of enter-
ing into the  file additional  responders that discharge wastewaters to the
Buffalo Sewer Authority.   The ICS list for Niagara County included 42 posi-
tive responders with 30 in the study area.

     Rating criteria  based on  the ICS data are presented in Table  20.   A
rating value was  assigned both for the total average annual  use of chemicals
of concern used or  produced  and for  the  average quantity on hand and the
values summed to  yield the total rating.   No attempt was made to different-
iate between  the  relative  toxicity  or har..--c  .;f  the various chemicals of

-------
114
                                   Table 19

                             AIR EMISSION RATINGS
Emissions
(ton/year)
<1
1-5
5-10
10-25
25-50
50-75
75-100
100-150
150-300
300-500
>500

Rating
0
1
2
3
4
5
6
7
8
9
10
Total
Number
Erie County
65
23
10
16
12
5
2
1
1
1
1
137
of Sources
Niagara County
18
6
4
7
5
4
2
0
3
2
6
57
                                   Table 20
                              ICS RATING CRITERIA

Rating

0
1
2
3
4
5
Annual
Chemical Use
(lb)
0-1,000
1,000-20,000
20,000-100,000
100,000-1,000,000
1,000,000-5,000,000
>5,000,000
Chemicals
on Hand
(lb)
0-1,000
1,000-10,000
10,000-50,000
50,000-100,000
100,000-500,000
>500,000
              A rating number was assigned both for chemical use
              and chemicals on hand and the two ratings summed
              to obtain the total ICS rating.

-------
                                                                       115
concern.  The annual  use  rate gives some  indication of the relative poten-
tial for  spills and  leaks  in handling operations, process units and trans-
portation equipment, and other factors related to potential  site contamina-
tion and  the need for best management practices to minimize the effects of
such contamination.   The  quantity  stored is also related to the relative
magnitude of potential  spills,  leaks, and site contamination problems.  Of
the 147 positive  responders  in  the study area, 17 received a rating of 10
indicating  large  volumes  of chemical substances  are  handled or stored.

     Two sources of information were used to evaluate hazardous waste manage-
ment activity.   A Region II computer listing was prepared of all facilities
that notified EPA that  they generate, transport, treat,  store, or dispose
of  hazardous wastes  as  required by the Resource Conservation and Recovery
Act (RCRA).89   Because  the notification  form did  not  request the county in
which the facility  was  located, a retrieval by  county was  not possible.
This listing was  retrieved by postal  zip code areas that approximated the
study area.

     There were 283  facilities  that indicated  they were only generators of
hazardous wastes.   An additional  36 generators also transported hazardous
wastes and 62 generators operated treatment, storage,  and/or disposal faci-
lities (TSDFs).   There were 42 facilities that conducted all three types of
activity  (generator,  transporter,  TSDF).   Fifty-seven were transporters
only, 6 were transporters and TSDFs,  and 31 were TSDFs  only.   This is a
total of 517 facilities.

     It is  probable  that  the number of facilities in each category is too
high.   Many companies unfamiliar with the new regulations notified EPA when
they did  not need  to.   When permit applications  were required  at a  later
date for  TSDFs, the  numbers decreased substantially.  There were 141 TSDFs
in  the  inventory  that indicated their operations would be such to require
permits.  Only  67 permit  applications (Part As)  were received  for all of
Erie and  Niagara  Counties,  of which 47 were  in  the study area.90  It is
also probable that  some facilities stopped  treating,  storing, or disposing
of  hazardous wastes  because  of  the new requirements that went into effect
subsequent to the notification.

-------
116
      The computer lists  of  notifiers  and  permit  applicants were  compared  to
 the industrial inventory to identify facilities with significant hazardous
 waste management activity.   Relative ratings were  then  assigned using  the
 criteria in Table 21.  These criteria assign ratings based on the capacity
 of treatment,  storage, and  disposal  units and on the total volume of  wastes
 handled per year.  No ratings were assigned to  generators and transporters
 because the notification forms did  not specify  the volumes  of wastes han-
 dled, only types.  The  TSDF  rating  criteria did not distinguish between
 categories of  wastes  and their relative toxicities  or hazards.

      An evaluation of the potential  for site contamination to release chem-
 ical  substances to the  environment  was made.   For  those facilities  with
 inactive hazardous waste sites, ratings were keyed to the Interagency Task
 Force (ITF) priority rating [Table 22].   Additional rating points were as-
 signed if there was known groundwater or  surface runoff  contamination or  if
 there was a high probability of such contamination.

      Facilities which received non-zero  ratings in more than one category
 or ratings of  5  or more points in a  single category were assembled  on a
 work sheet  showing the  incremental  and  total   ratings  for  each source.
 Thirty-three facilities with  a  rating  total of 11  points or more were  se-
 lected as major  sources  [Table  23].   In  general, these were sources that
 discharge significant loads of  chemical  substances (at  least 1  Ib/day of
 organic priority pollutants and/or heavy metals) in their wastewaters  (ei-
 ther directly  to surface waters or through municipal sewage systems); emit
 air pollutants of  concern;  use  or produce  large volumes of chemical sub-
 stances;  generate, manage,  and/or dispose of  large  volumes  of  hazardous
 wastes; and have significant  site contamination such as  inadequate hazard-
 ous waste disposal sites or groundwater  contamination.   The locations of
 these sources  are shown in  Figure 10.

      There were  15 major industrial  sources among  the  33 in Table 23 that
 had  non-zero  ratings  for direct wastewater discharges.   These  15 sources
 are  estimated  to  discharge  about 95% of all organic priority pollutants,
 phenols,  and  heavy metals directly discharged by industrial point sources.

-------
                                                                 117
                            Table 21

           HAZARDOUS WASTE MANAGEMENT RATING CRITERIA
Rating
0
1
2
3
Volume Handled
Metric tons/year
10-50
50-100
>100
                        Storage Capacity

         Rating                        Capacity (gallons)

           0                                    <5,000
           1                               5,000-10,000
           2                              10,000-25,000
           3                                    >25,OOQ

                       Treatment Capacity

         Rating                        Capacity (gallons/day)

           0                                    <1,000
           1                               1,000-10,000
           ?.                              10,000-100,000
           3                                    >100,000

                        Disposal Capacity

Rating*
0
1
2
3
Land Application
(acres)
<1
1-10
10-25
>25
Landfill
,. (acre-feet)
<1
1-5
5-10
>10
Surface Impoundment
(gallons)
<1,000
1,000-5,000
5,000-10,000
>10,000
The highest rating value obtained for all three columns

-------
118
                                Table 22

                   SITE CONTAMINATION RATING CRITERIA
      Rating                             Conditions


                Inactive Hazardous Waste Onsite Disposal


        0            No onsite inactive disposal
        1            Disposal site has low probability of containing
                       hazardous wastes, ITF priority III
        2            Possible hazardous wastes, small area (< 1 acre),
                       ITF priority II
        3            Possible hazardous wastes, larger area, ITF
                       priority II
        4            Known hazardous wastes, ITF priority I
        5            Known hazardous wastes, known major environ-
                       mental problems

                        Groundwater Contamination

        0            No known or probable contamination
        1            Significant potential for contamination
        2            Known contamination

                      Surface Runoff Contamination

        0            No known or probable contamination
        1            Significant potential for contamination
        2            Known contamination

-------
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120
                                            |TARI°
                                                                              LEGEND


                                                                          •   INDUSTRIAL POINT SOURCE
                                                                          •   MUNICIPAL POINT SOURCE
                                                                          A   HAZARDOUS WASTE MANAGEMENT FACILITY
                                                                              SOURCE NUMBER SEE T ABIE 23 ,
                                                                              FOR IDENTIFICATION
                         LAKE
ERlE
     FIGURE 10. LOCATIONS OF MAJOR POINT SOURCES OF CHEMICAL SUBSTANCES

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                                                                       121
     To provide an estimate of the maximum discharges of priority pollutants
from industrial point sources, daily maximum values from SPDES permit appli-
cations were compiled in Table 24.   These data show that in an average daily
flow of about  460  mgd,  the 15 industries discharge reported maximum daily
loads of 558 Ib of organic priority pollutants, 237  Ib of phenols, and 682
Ib of heavy metals.

     Table 24 shows that a major portion of the chemical  substances is con-
tributed by a  few  sources.   This suggests a priority order for  new SPDES
permits containing best available technology (BAT) based effluent limits on
priority pollutants.   It  is  estimated that the improvements in wastewater
treatment or controls necessary to meet BAT permit limits could  achieve at
least a 50% reduction in  maximum priority pollutant  discharges from indus-
trial point sources.

     Table 23 indicates that many of the major industrial sources discharge
significant loads  of priority pollutants to municipal sewer  systems  for
treatment.   These  loads  are  included in the major municipal point source
loads.

Municipal

     There are about 20  municipal  wastewater treatment plants serving the
study area.  Only  four of these plants were found to discharge significant
loads of priority  pollutants  [Table 24].  These plants receive major  flows
of industrial  wastes containing  chemical  substances.  The four plants are
estimated to collectively contribute  more than 90% of all priority pollut-
ants discharged by municipal  sources.

     Based on EPA monitoring in May and June 1981, the four plants discharge
about 328 Ib/day of organic priority pollutants,  525 Ib/day of phenols, and
566 Ib/day of heavy metals.   These loads are 59,  222, and 83%, respectively,
of the  maximum loads reportedly discharged by major industrial  sources.

-------
122
                                                             Table 24
                                          MAJOR WASTEWATER DISCHARGES OF PRIORITY POLLUTANTS
Facility City

Allied Chemical Buffalo
Ashland Petroleum Tonawanda
Bethlehem Steel Lackawanna
Buffalo Color Buffalo
Chevrolet Tonawanda
Donner-Hanna Coke Buffalo
DuPont Niagara Falls
FMC Tonawanda
Hooker Chemical
(Durez) North Tonawanda
Hooker Specialty
Chemical Niagara Falls
National Steel
(Hanna Furnace) Buffalo
01 in Niagara Falls
Republic Steel Buffalo
Spaulding Fiber Tonawanda
Tonawanda Coke Tonawanda
Industrial Subtotal

Buffalo Sewer
Authority Buffalo
City of
North Tonawanda North Tonawanaa
City of
Niagara Falls Niagara Falls
Town of Tonawanda Tonawanda
Municipal Subtotal
Organic
Flow Priority Pollutants Phenols Heavy Metals
(mgd) (lb/day)a (1b/day)a (lb/day)a
Industrial
12.2
19.3
233
10
23
9.8
10.8
7.1

0.7

38.5

38.8
6.8
42.8
4.7
2.6
460
Municipal

180

9.2

64
15
268

<1
0
65
0
0
69
69
0

17

100

3
274
2
0
2
558

H
60d
rl
14°
p
252d
2d
328

0.5
2.3
0
°b
55b
25C
2.4
0

113

4

22
4
0
1 c
1.3C
237

A
<15Q
H
oa
h f
Sioj
oa
525

3
242
38
9
-
ld
5
5

4

69

65
8
53
175
5
682

H
520a
d
3a
p
42d
lu
566
Hazardous Waste Management
CECOS Niagara Falls
SCA Model City
Hazardous Waste Subtotal

Canadian Industrial and
Municipal Subtotal
SUBTOTAL - Known Point
Sources
Assumed Contribution of Minor
Point Sources
TOTAL
<1
<1
<1
Canadian

62

791




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                                                                       123
Canadian Industrial and Municipal Point Sources

     In early 1981,  Environment  Ontario conducted a survey of  industrial
and municipal point sources (including two combined sewer overflows) tribu-
tary to the Niagara River in Ontario which provided the only available data
on discharges of  priority  pollutants substances from  Canadian  sources.91
As shown in  Table 24,  the Canadian  loads were about 23  Ib/day  of organic
priority pollutants, 3  Ib/day  of phenols, and 156 Ib/day of heavy metals.
The organic  priority pollutants  were less than 3%  of the U.S. point  source
load while the heavy metals were about 13% of the U.S.  load.

Hazardous Waste Disposal Sites

     As shown in  Table  23, there were three major hazardous waste manage-
ment facilities in  the  study area.   One treats and reclaims wastes.   Only
two were active commercial  hazardous waste disposal sites.   As shown in
Table 24,  they  discharge only minor  amounts  of priority pollutants.  The
maximum daily values  shown for SCA  would occur on only  a  few days as the
facility only discharges a few days a year.   Although the maximum discharge
rate is 1  mgd,  SCA discharged only  6 mil gal. in  1981.  CECOS  discharges
process wastes to the  City of Niagara Falls after extensive pretreatment.
Only peripheral  drainage, reportedly containing negligible priority pollut-
ants, is discharged directly to surface waters.

     There are many other  active and inactive solid and hazardous  waste
disposal sites  in the study area.   Contributions  of chemical substances
from these sites  are not well defined.   In many cases, the disposal sites
may contribute to non-point sources of chemical substances such as contami-
nated groundwater and surface runoff.  For disposal sites located at indus-
trial plants, their contribution of chemical  substances may be partly re-
flected in the point source discharge.

     Of the  hazardous waste  disposal sites identified by  the Interagency
Task Force (ITF)  and followup DEC investigations,  155  are  located within 3
miles of the Niagara River.  These sites are considered to have the highest

-------
124
 potential to contribute chemical  substances  to the  River  because or  their
 location.

      Of these 155  sites,  68  are at major industrial  sources  of chemical
 substances specifically discussed in Sections VI, VII, and VIII.  An addi-
 tional 20 sites  were eliminated from consideration based on  DEC  preliminary
 investigations.   The remaining 67 sites are considered of concern with re-
 spect to their potential  for  release of chemical  substances  to the environ-
 ment.  These sites  are  listed  in Table 25 with locations shown in Figure
 11.

      No attempt was made to rank the significance of these sites.   Remedial
 measures have been  completed at some.   Others are scheduled for detailed
 site investigations.  A few are under litigation.

 Comparison of Point Source and  River Loads

      A comparison  of the estimated total  loads of priority pollutants from
 U.S. and Canadian point sources with the reported loads in the Niagara River
 at its mouth in 1980 indicates  that point sources account  for major portions
 of the organic  priority  pollutants  and phenols in  the river, but only a
 small fraction  of  the  heavy  metals.92  The 1980 Canadian  data  indicated
 that mean organic  priority pollutants  loads in the  river  increased  from
 about 1,070  Ib/day at the  inlet  to Chippawa Channel  to 1,570 Ib/day at the
 river mouth, an increase  of  500 Ib/day.  The estimated total  point source
 load was  970 Ib/day,  62% of the total  river load and 194% of the increase
 in load.

      The estimated  phenol  point source load of 829  Ib/day was larger than
 the  mean  phenol  load  of 680 Ib/day at the mouth of  the Niagara  River.  An
 incremental   increase in the river could not be computed because  all phenol
 measurements at the upstream  location were below  the detection limit.

      The estimated  total  point  source  load of  1,495  Ib/day of heavy metals
 was  less  than  5% of the  reported heavy metals load in the river of more

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                                                                 125
               Table 25
HAZARDOUS  WASTE DISPOSAL SITES OF CONCERN
      NOT  AT  MAJOR  INDUSTRIAL PLANTS
Task Force3
No.
1
2
3
4
5
6
7
8
9
1C
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
a
b
c

Site No.
103
82
A
162
111
113
4
128
83
6
84
167
207
173
67
21
242
68
85
219
72
39
182
86
136
190
38
137
76
138
140
141
77
93
14
87
81
196
94
95
144
79
147
149
B
201
150
151
100
203
63
62
C
204
206
241
91
208
220
89
160
90
88
244
245
40
56
See Figure 11
A = Active, I
Site Name
R. P. Adams
Adams Generating Plant
Allied Chemical - Hopkins Street
Altift
Aluminum Matchplate
Anoconda Company
Basic Carbon
Sell Aerospace - Textron
Buffalo Avenue, 52-60 Street
Buffalo Pump Division
Cayuga Island
Chemical Leaman Transit Lines
City of Tonawanda
Empire Waste
Frontier Chemical
Frontier Bronze
Charles Gibson Site
Gratwick Park
Griffon Park
Hartwell Street Landfill
Holiday Park
Hooker - Hyde Park Landfill
Huntly Power Station
Hydraulic Canal
IWS Equipment
Lehigh Valley
Love Canal
Lucidol of Pennwalt
Lynch Park
MacNaughton - Brooks
Manzel Division
Mobil Oil Corporation
Modern Disposal
Nash Road Site
Necco Park (DuPont)
New Road
Niagara County Refuse Disposal
Niagara Frontier Port Authority
Niagara River Site
Old Creek Bed (Oibaco Site)
Otis Elevator
Power Authority of New York
Ramco Steel - Hopkins Street
Robbin Steel
Rodeway Inn
Seaway Industrial Park
Shavco Plastics
Shavco Plastics
Silbergeld Junk Yard
Squaw Island
Stauffer Chemical (Art Park)
Stauffer Chemical (North Love Canal)
St. Mary's School (60th Street)
William Strassman
Tifft Farm
Times Beach
Town of Niagara
Veteran's Park
West Seneca Transfer Station
Whirlpool Site
J.H. Williams (TRW)
Witmer Road
64th Street
93rd Street School
97th Street Methodist Church
102nd Street Landfill (Hooker)
102nd Street Landfill (01 in)
for site locations.
= Inactive
I = At an industrial plant 0 = Offsite industrial
M = Municipal
site P = Private site
City
Tonawanda
Niagara Falls
Buffalo
Buffalo
Tonawanda
Buffalo
Niagara Falls
Porter
Niagara Falls
North Tonawanda
Niagara Falls
Tonawanda
Tonawanda
Tonawanda
Pendleton
Niagara Falls
Niagara Falls
North Tonawanda
Niagara Falls
Tonawanda
North Tonawanda
Niagara Falls
Tonawanda
Niagara Falls
Tonawanda
Buffalo
Niagara Falls
Tonawanda
Niagara Falls
Buffalo
Buffalo
Buffalo
Model City
North Tonawanda
Niagara Falls
Niagara Falls
Wheat Field
Niagara Falls
Niagara Falls
Niagara Falls
Buffalo
Niagara Falls
Buffalo
Tonawanda
Niagara Falls
Tonawanda
Tonawanda
Tonawanda
Niagara Falls
Buffalo
Niagara Falls
Lew is ton
Niagara Falls
Tonawanda
Buffalo
Buffalo
Niagara Falls
Tonawanda
Buffalo
Niagara Falls
Tonawanda
Niagara Falls
Niagara Falls
Niagara Falls
Niagara Falls
Niagara Falls
Niagara Falls


disposal site


Status13
I
I
I
A
I
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I
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I
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I
A
A
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A
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I
I
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I
I
I
I
I
I
I
I
A
I
I
I
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I
I
I
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A
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A
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I





Type0
P
I
0
P
I
I
I
I
M
I
P
I
M
P
0
I
P
P
M
P
P
0
I
M
I
0
0
I
0
I
I
I
P
M
0
M
M
M
0
0
I
M
I
I
I
P
I
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0
0
0
P
P
M
M
M
M
M
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0
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0





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126
                              ONTARIO
                LAKE
       FIGURE 11. HAZARDOUS WASTE DISPOSAL SITES OF CONCERN

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                                                                       127
than 34,000 Ib/day.   The river load is suspect, however, because about half
the load was  for  two metals which were below detection limits in all sam-
ples.   Because the river flow is very  large and concentrations of chemical
substances are at very  low levels near the detection  limit of analytical
methods used, estimates of component loads are subject to significant errors
(±50% or more) due  to small errors in the absolute value of a sample con-
centration.

     Basc~ of,  :: mean  river  flow of 202,000 cfs, the estimated point  source
loads would  produce an  incremental  concentration increase of  0.9  ug/£
organic priority pollutants, 0.7  H9/£ phenols, and 1.3  ug/£  total  heavy
metals.   These concentrations are below the detection limit for most of the
component substances, especially phenols and heavy metals.

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                                                                       129
              VI.   MAJOR SOURCES OF CHEMICAL SUBSTANCES,
                       BUFFALO-LACKAWANNA SUBAREA
     The Buffalo-Lackawanna subarea  encompasses  the cities of Buffalo and
Lackawanna and portions  of  the town of Cheektowaga,  all  in Erie County.
There are  seven major  industrial sources, one major municipal source  (Buf-
falo Sewer Authority),  no major active offsite  hazardous  waste disposal
facilities, and 20  hazardous  waste disposal  sites of  concern.   Seven of
these disposal sites are at major industrial sources.  Five of the indus-
trial sources and Buffalo Sewer Authority are major wastewater dischargers.
Combined sewer overflows, urban runoff, dredged spoil  disposal,  and contam-
inated bottom  sediments  are all  important non-point sources of toxic sub-
stances in this subarea.  With the exception of  two industrial  facilities,
all major  point sources  and major  non-point  source contributions are  along
the Buffalo  River,  the Lake Erie waterfront, or the  Upper  Niagara River.

INDUSTRIAL POINT SOURCES

Bethlehem Steel Corporation

     Bethlehem Steel Corporation operates  a  large, fully  integrated  iron
and steel  mill on a 1,200 acre site in Lackawanna [Figure 12].  This mill  is
the largest  industrial  facility  in the study area.  It began operation in
1922.   Processes include coke ovens, blast furnaces, basic oxygen furnaces,
and various rolling mills.

     Bethlehem Steel is the largest source of wastewater in the study area.
About 233  mgd  of cooling water, process wastewaters,  and other  wastewaters
are discharged through  five outfalls to Blasdell,  Rush, and Smokes Creeks
and to the Union  and Lackawanna Canals.  A  wide variety of treatment or
control processes are employed.

     A total  of 42 organic priority pollutants were reported as detected in
Bethlehem Steel wastewaters in the 1981 SPDES permit application.  Fourteen

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130
                           DIKED DREDGED <••
                          SPOIL DISPOSAL £fe\\ ^
                                              NATIONAL STEEL X^"^"1 V\\V\\ 2
                                              (HANNA FURNACE) ~^V "'' ' ' *N   "

                                     BETHLEHEM STEEL
                                                      *'-i\\\7i
      OLD OPEN WATER
    x-  DREDGED SPOIL
       DISPOSAL AREA
                                                           .Wood] awn  j
                        Figure 12.  Lackawanna Area

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                                                                       131
of these were reported at higher values in the intake water from Lake Erie
than in plant effluents.   The total  net load of organic priority pollutants
discharged was reported as 64 Ib/day.   The most significant organic priority
pollutants discharged were  (loads  in  Ib/day are in parentheses):   benzene
(3.2), acenaphthene (7.5), acenaphthylene (8.5),  2-chloronaphthalene (7.5),
dimethylphthalate (10.2),  dinitrotoluene (7.5), fluorene (7.2), hexachloro-
benzene (8.5), and pyrene (14.2).  Many of these substances are polycyclic
aromatic hydrocarbons (PAHs).   Screening  sampling  of various  stream loca-
tions around the Buffalo  study  area for PAHs in 1980 and 1981 detected me-
dium to high  relative  concentrations  in Smokes Creek  and  Lackawanna and
Union Canals.93

     Other priority pollutants  discharged as reported  in the permit  appli-
cation were 102 Ib/day of cyanide and 38  Ib/day of heavy metals (23  Ib/day
was zinc).

     Priority pollutant  analyses of  samples collected by EPA on May 8 and
9, 1981 from  Smokes  Creek and  the outfalls discharging to Blasdell  Creek
and the Lackawanna Canal  detected 15 organic priority pollutants at  levels
less than  10 ug/£.94  About 107 Ib/day of heavy metals  were  detected in
three discharges, of which  91  Ib/day was zinc  and  13  Ib/day was copper.

     The steel mill  has  other  liquid wastes which are not included in the
SPDES permitted outfalls.   Runoff  from raw material  storage piles goes to
surrounding waterways without monitoring.  Wastewaters from the coke  ovens
and byproduct plant  are  stripped and dephenolized and then used to quench
hot BOF slag  and  hot coke.   Waste pickle  liquors  are  neutralized on the
alkaline slag landfill that now covers a large area  of  former Lake Erie
shallows on the west edge of the mill  [Figure  12].   Dredged spoils from
Smokes Creek, process sludges,  and  waste treatment sludges are placed in
surface impoundments on the slag fill.   The ootential  contributions of pri-
oricy pollutants from these ancillary  activities to Lake  Erie waters was
not defined.  The  use  of best management practices (BMPs) to control con-
tributions from these sources was not defined.

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132
       Process emissions of air pollutants  of concern  to  the  atmosphere total
  about 97 ton/year.78  This included 85 tpy of phenolic  compounds  and smaller
  amounts of trichloroethane,  hydrogen  cyanide,  lead, copper,  and  zinc.   No
  emissions data on benzo(a)pyrenes were reported.

       The Industrial  Chemical  Survey (ICS) for Bethlehem listed 15 chemicals
  of concern with  more  than 25 mil gal. used or produced per year and more
  than 1.6 mil  gal.  in  storage on the average.88  Major  volumes of benzene,
  toluene, xylene, and  coal  tar were listed.   About 12,000  gal.  of PCBs are
  used in closed systems.

       Bethlehem Steel  has  applied for a RCRA permit  for its hazardous waste
  management activities.90  More than 67,000 metric tons of hazardous wastes
  are handled annually.   Onsite disposal  includes  a  240 acre-foot landfill
  and a  48,000  gal. surface impoundment.   Large volumes of blast furnace and
  EOF slags are landfilled onsite.   A May 1981 RCRA inspection by  EPA found
  the hazardous waste management activities and facilities to be essentially
  in compliance with Interim Status Standards.95  A June  1981 site  inspection
  by an EPA contractor did not resolve questions concerning  whether leachate,
  seepage, or runoff  from the  site could transport chemical  substances into
  Lake Erie.96

       This is  an  Interagency  Task Force (ITF) listed site.   An April 1980,
  assessment of environmental problems at the site by DEC indicated potential
  ground and surface water contamination.97  The site is  now operated under a
  DEC Part 360 permit.

       It is evident that a significant potential exists  for the discharge of
  priority pollutants from ancillary activities at this facility  including
  hazardous and industrial waste disposal  in the slag fill  area.  Permit con-
  ditions requiring Bethlehem  Steel  to  address  the  need  for BMPs to minimize
  such contributions are needed in the next SPDES permit.

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                                                                       133
National Steel (Hanna Furnace)

     National Steel operates a basic blast furnace operation producing about
1,000 to 1,930 ton/day of pig iron from iron ore.   The facility is adjacent
to the Union Canal northeast of Bethlehem Steel  [Figure 12].

     About 38.8 mgd of wastewaters (primarily non-contact cooling water) is
discharged to the  Union Canal when both blast furnaces are operating.  The
flow is  reduced  to 23.5 mgd when only one furnace is in use.   About 5 mgd
is scrubber  wastewater.   The permit application indicated this wastewater
contained major  loads  (daily maximum) of  heavy metals  (65 Ib), cyanide  (87
Ib), and phenolic compounds (22 Ibs) but only a small load of organic prior-
ity pollutants (3 Ib).   Only four organic priority pollutants were reported
present.  Lead (17.9  Ib)  and zinc (45 Ib) accounted for most of the heavy
metals.

     No wastewaters are discharged to a municipal  sewer system.

     Hanna Furnace  listed  only  small volumes of a  few  chemicals of concern
in their ICS response.88   They have not applied for  a  RCRA  permit for
hazardous waste management facilities.90

     Raw materials  and some solid waste materials including slag and flue
dust are stored  in piles  on the  north  side of Union Canal.  This area  is
reportedly curbed  and  relatively impervious and no  storm  runoff occurs.
This is an ITF listed site.98  The site has a DEC Part 360 permit.

     No emissions  of air  pollutants of concern were reported in the emis-
sions inventory.78

Allied Chemical

     Allied  Chemical on the Buffalo River [Figure 13] manufactures  acids
and industrial inorganic  chemicals.   Products  reportedly include ammonium
thiosulfate;  cadmium,  copper,  iron,  and nickel  nitrates; nitric, oxalic,

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134
         ^'///''F^^WL "«" ^f=s--T?/ /^-'/'r, '///
         i^^^w;^/'
         Itpv :.U$
-------
                                                                       135
and sulfuric acids; potassium nitrite; and sulfur trioxide."  However, the
permit application  indicates the metallic nitrates are no longer produced.
The plant began operation in 1930.

     Contact and  non-contact  cooling water and small  amounts  of  utility
wastewaters are  discharged to the  Buffalo  River through four outfalls.
Flow averages  12.2  mgd.  The only treatment for these wastewaters reported
in the permit  application was neutralization.  Cooling water supply is ob-
tained from the Buffalo River Improvement Corporation (BRIC).   Process waste-
waters are  pretreated  at the  adjacent Buffalo Color Company facility  and
discharged to the Buffalo Sewer Authority system.

     The permit application indicated that, based on three samples,  maximum
loads of  priority pollutants  in  the direct discharges were low,  with less
than 1 Ib/day  of  organic priority pollutants and phenols present and 3 lb/
day  of  heavy metals, primarily cadmium,  copper,  and zinc.   The organic
priority pollutants were about 0.2 Ib/day of various pesticides.

     No significant emissions of air pollutants of concern were reported.78

     Allied applied  for  a  RCRA permit to store  less  than 20,000 gal.  of
corrosive hazardous wastes in containers and tanks.90  Annual volume handled
was estimated at about 200 metric tons.

     An IFT-listed  disposal site at  this  facility was  a  sludge lagoon  that
has been excavated and filled with clean fill.100  No obvious environmental
hazards were present in  April 1980.   Monitoring wells  have been installed.

     The Allied Chemical and adjacent Buffalo Color Company plant (formerly
owned by  Allied  Chemical)  are along an area of the Buffalo River shown to
have elevated levels of chemical  substances in the sediments.   The hazardous
nature of  the  Allied Chemical  products and proximity  of the plant to  the
river indicate the  need  for BMP conditions  in  the SPDES  permit to minimize
contributions of priority pollutants from ancillary activities.

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136
  Buffalo Color Corporation

       Buffalo Color Corporation manufactures  a  variety of anilines, anhy-
  drides, dyes, dye intermediates,  and food colors.   The plant began operation
  in 1879 as  National  Aniline  and  Chemical  Corporation.   It was operated by
  Allied Chemical  prior to its  present ownership.

       About 10 mgd of non-contact cooling waters are obtained from BRIC and
  discharged along with minor amounts of boiler blowdown and steam condensate
  through two  outfalls to  the  Buffalo River.   The only  significant priority
  pollutants reported  in  the permit  application to be  in  these discharges
  were 9 Ib/day of heavy metals.   Process wastewaters (about 1 mgd), contain-
  ing about 6 Ib/day of 17 organic  priority pollutants and 20 Ib/day of heavy
  metals (primarily chromium),  are discharged to the Buffalo Sewer Authority
  after pretreatment.101

       Because of  the  nature of  their operation, Buffalo Color Corporation
  uses, produces,  and stores very large volumes of chemicals of concern.   The
  ICS response indicates  that  more than 50 mil Ib of more than 75 chemicals
  are used  or  produced each year.88   About a million pounds are in storage.
  About 20,000 Ib. of PCBs are  used in electric transformers.

       A wide variety of process  air  pollutant emissions are reported.78  The
  most significant emission of air pollutants of concern was 21 tons/year  of
  aniline.

       An application  was  filed  for  a RCRA permit  to store and treat (the
  pretreatment unit) hazardous  wastes.90  Container storage capacity of 75,000
  gal. was  requested.  About 1,500 metric tons of hazardous wastes are han-
  dled annually.   No onsite disposal  was requested.

       There has been disposal  of hazardous wastes on site in the past.  Three
  ITF  sites are  listed at this  location.102   The  most  significant is the
  "weathering  area" where  sludges were  stored  for many years  on the banks  of
  the Buffalo River.  A 500-foot deep well was used for  disposal of about 3.5

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                                                                             137
mil gal.  of ammonium sulfate solution from 1960 until the well collapsed in
1963.   This plant  produced  benzidene dyes until 1976.   Traces of the dyes
and intermediates  have  been found in Buffalo River sediments.  Fish tumor
pathology has been linked to this sediment contamination.103

     Contamination of the plant  site, possibly  including groundwater, from
past disposal  practices may be continuing to contribute to pollution of the
Buffalo River.102  An effective BMP plan with specific BMPs to control chem-
ical substances in runoff, leachate, etc. is needed.

Donner-Hanna Coke Joint Venture

     Donner-Hanna Coke produces metallurgical coke from coal and recovers a
variety of  byproducts including  phenols,  sodium phenol ate,  ammonia,  ammon-
ium sulfate, tars,  light oil  containing benzene,  toluene  and xylene, and
naphthalene.  Plant operations began in 1919.  The plant is adjacent to the
Buffalo River and Republic Steel [Figure 13].

     About  9.8 mgd of cooling water  and  process wastewaters are  discharged
through one outfall  to  the  Buffalo  River.   Most process wastewaters,  after
primary treatment, are  used for quenching of coke.  Treatment sludges are
recycled  to the  raw materials.   Other process  wastes  receive filtering,
solvent extraction and  distillation treatment before mixing  with cooling
waters for  discharge.   Sanitary  wastes are  discharged  to the  Buffalo Sewer
Authority.  Most of the water supply is obtained from BRIC.

     The SPDES permit application reported a daily maximum discharge (gross)
of organic priority pollutants of 69 Ib, of which 54 Ib was methylene chlo-
ride and  13 Ib was benzene.  These  two pollutants  were also present  in  the
BRIC supply.  The  maximum net discharge  was  about  30 Ib/day.  Maximum dis-
charges of  cyanides  and  phenols were reported as 16 and 25  Ib/day,
respectively.

     The May 8 and 9, 1981 EPA sampling detected only acenaphthene,  arsenic,
and selenium in  the  discharge at a  net  discharge  load of  less  than  2 Ib/
day.104  The concentrations observed by EPA sampling are below expected BAT

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138
  levels.  However,  reported  maximum values in the permit  application are
  above expected BAT concentrations indicating the need for additional  prior"
  ity pollutant  limits  in  the next SPDES permit.  The  facility produces a
  variety of organic  priority pollutants that should be controlled  by the
  permit.

       The ICS  response  indicates  the plant produces more than 15 mil gal.
  per year of  toluene,  phenol, xylene, coal tar, and light oil.88  Average
  storage is about  1.6 mil gal.  The  Company claims there is no surface  run-
  off or groundwater infiltration from their raw material  and product storage
  areas.105  The large volumes of organic priority pollutants stored indicate
  the need for BMP conditions in the SPDES permit.

       Donner-Hanna Coke applied for a RCRA permit to store and treat about
  3,300 metric tons of hazardous waste annually.90  Storage is in tanks and a
  surface impoundment with a  total  volume of 35,000 gal.  The DEC has  listed
  a possible solid  waste management site (ammonium sulfate) at  this  facility
  but the Company has denied this.106

       Process emissions of air pollutants of concern included about 12 tons/
  year of phenols  and miscellaneous organics,78  No specific emission rates
  were given for benzo(a)pyrene, known to be emitted by coke ovens.

  Republic Steel Corporation

       This iron and steel mill is  on about 120 acres adjacent to the Buffalo
  River  [Figure  13].   The mill has been in operation since 1906.  Processes
  include blast  furnaces  (2), basic oxygen furnaces  (2),  and  pickling and
  rolling mills.

       About 43  mgd of cooling and process wastewaters and storm runoff are
  discharged to  the Buffalo  River  through  four  outfalls.   Water supply is
  obtained from  Lake Erie.

       The SPDES permit application indicated  that maximum  discharges  of or-
  ganic  priority pollutants  and phenols were  nil but heavy metals were 53

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                                                                       139
Ib/day.   This was  primarily  copper,  lead, and zinc.  The May 4, 1981 EPA
sampling also indicated  organic  priority pollutant discharges were nil107
but heavy metals were 37 Ib/day with the same three metals dominant.

     The ICS response  indicated  relatively small use and storage of a few
chemicals of concern.88   A  RCRA  permit application was filed for the tank
storage of up to 5,250 gal.  of hazardous wastes.90  About 1,300 metric tons
are handled annually.  Waste treatment sludges are stored at a company-owned
site at another location and then shipped out of state for recovery of iron.
Slags are landfilled at the offsite location.

     The only emissions of air pollutants of concern reported were less than
1 ton/year of lead.78  The Company reports storm runoff from material storage
is essentially contained in a diked concrete area with no discharge.108  It
is not clear if there are any other ancillary activities that could contri-
bute priority pollutants.

Chevrolet (Harrison Radiator Division)

     This plant in northeast Buffalo manufactures automotive air condition-
ers, heaters, and  radiators.   It has no  direct  discharge of wastewaters.
Process wastewaters containing organic priority pollutants and heavy metals
are discharged to the Buffalo Sewer Authority system for treatment.

     The ICS response  indicates  this plant uses about 40,000 gal./year of
1,1,1-trichloroethane, toluene, xylene, and petroleum distillates.88  About
2,800 gal.  are stored at one time.

     The facility  is  a large RCRA generator, storage, and treatment faci-
lity.90  The application requested a  permit  for  tank  treatment capacity of
0.43 mgd, tank storage of 400,000 gal., and container storage of 2,000 gal.
About 730,000 metric tons of  hazardous  waste are handled  annually, primar-
ily spent electroplating bath solutions.   Emissions of air pollutants of
concern were reported as 14.5 tons/year of trichloroethane and 3.5 tons/year
of xylene.78

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140
       No site contamination  data were  located.

  MUNICIPAL POINT SOURCES

  Buffalo Sewer Authority

       The only major municipal wastewater  discharge  in  this  subarea  is  the
  large Buffalo Sewer Authority (BSA)  Bird  Island plant that serves  about
  550,000 persons in the City  of  Buffalo and parts of suburban  cities and
  towns.   A major portion  (14%  or 24  mgd) of the plant influent is  industrial
  wastes  contributed by about 620 industrial users.   About 96% of the tribu-
  tary area is served by combined storm and  sanitary sewers.   Located  on  Squaw
  Island  on the  Upper Niagara  River,  the plant discharges directly to the
  river.

       The plant's primary treatment units  were  built in the 1930s.   Acti-
  vated sludge secondary treatment units  were  completed  in 1980.   Sludge is
  incinerated on site;  however,  there have been frequent  malfunctions  in  these
  incinerators and associated equipment  and large quantities  of  sludge have
  been transported to approved  landfills.

       The secondary treatment units have experienced operational  problems
  since startup which have  been attributed to equipment failures, poor opera-
  tion and maintenance,  inadequate  operator  training,  and carryover of solids
  from the primary units.   Renovation  of the primary units was not started
  until after the secondary units were placed in operation.   Repairs  and re-
  placements of  equipment  and  operator training  programs directed at these
  problems are continuing with  completion scheduled by early  1983.

       Average dry weather wastewater  discharge  is  about 160 mgd.   Design
  flow is  180 mgd.   Sampling of the  discharge  by  EPA  in  May  1981 found that
  all  organic priority pollutants were  below detection limits  (ranging from  1
  to 10 ng/£) except for bis(2-ethylhexyl)phthalate discharged at 10  pg/£ (13
  lb/day).109  Department   of Health  analysis of  the  effluent  in  August 1980
  found four compounds at  detectable levels:  bromodichloromethane (6 |jg/£),

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                                                                       141
dibromochloromethane (1 ug/£), methylene chloride  (4 ug/£), and chloroform
(17 ug/£)-  This  is  equivalent to a total  toxic organics load of about 60
Ib/day.  EPA  heavy metals analyses showed a much larger load of about 520
Ib/day.109  Predominant metals were zinc (357 Ib), nickel (69 Ib), chromium
(60 Ib), and copper (30 Ib).

     Observed concentrations of organic priority pollutants are low.   Heavy
metals concentrations  are also low relative to BAT for heavy metals.   The
BSA pretreatment program  is not fully operational.  Completion of the plant
renovation plus implementation of the pretreatment program should achieve
some reductions in heavy  metals  loads but the magnitude of the reduction
cannot be predicted with present data.

NON-POINT SOURCES

Dredged Spoil  Disposal

     Navigation channels  dredged  deeper than the  historic  river  or  lake
bottom have been  constructed  in the  lower Buffalo  River, the Buffalo Outer
Harbor area,  the  Upper Niagara River, and Tonawanda Channel downstream to
the City of North Tonawanda.  Because these deepened channels serve as sedi-
ment traps, they  must  be  dredged annually to maintain  navigable  depths.

     Sediments trapped  in the  channels originate  in urban and agricultural
runoff, combined  sewer overflows, industrial wastewater discharges,  and
shifting bottom sediments.  Pollutants from these  sources,  including PCBs,
pesticides, and heavy  metals,  become trapped in the bottom sediments and
appear in the dredged spoil.

     The dredging process results in the immediate resuspension  of  some
sediments that can be  carried away by  river  currents.   Disposal  of the
dredged spoil  results in the transfer of polluted sediments from the  dredg-
ing site to the disposal site.   This can also result in the release of pol-
lutants.

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142
       Prior to 1968, all  dredged  spoil  from Buffalo River, Buffalo  Outer
  Harbor,  Black Rock Canal, and Tonawanda Harbor removed by the U.S.  Corps of
  Engineers was disposed of  in open waters of  Lake  Erie.110   The disposal
  area was adjacent  to  Bethlehem  Steel  in Lackawanna [Figure  12].   It was
  about 0.7 mi wide  and 1.4 mi long with its long axis parallel to the Beth-
  lehem Steel  plant.3 Water depths ranged from 6 to  25  feet.

       This disposal area  was  and  remains exposed to the full  force  of wave
  action from Lake  Erie  storms.   This could resuspend bottom  sediments into
  the lake waters.   A hydraulic model study performed by the Corps of Engin-
  eers in 1972  found that  both surface and littoral  drift currents  in the
  disposal area moved northward parallel to shore with some entering Buffalo
  Outer Harbor and others moving into the Upper Niagara  River.110   Thus, sedi-
  ments from the disposal area could be transported into the river.

       In the 1940s,  the open water disposal  caused  some pollution problems
  at a western New York water  company (later the Erie County Water Authority
  Wood!awn plant and now closed) water supply intake  at  the south  edge of the
  disposal area.3  The  Corps  of Engineers attempted  to  minimize the  problem
  by depositing coarser dredged materials from  the Black Rock Canal near  the
  intake.   The more  polluted  finer materials and sludges from Buffalo River
  and Buffalo Harbor were disposed of farther north.

       Before 1968,  dredged spoil  volumes were  probably  in excess of 600,000
  to 700,000 yd3/year.   All  except 90,000 to 100,000 yd3 from the Tonawanda
  Harbor were dredged from the Buffalo River,  Outer Harbor, and  Black  Rock
  Canal areas.  Additional  spoils  from private dredging were  also dumped in
  the open water area.

       The dredging  in  the Buffalo River was  and  is done  under contract  by
  clamshell dredge  with spoil placed on  barges for  transport to disposal
  areas.  This volume was about 125,000 ydVyear in 1973 and is the most pol-
  luted.  The remainder  of the public dredging  was  and  is done by Corps  of
  Engineers hopper dredges.  No information on private dredging practices was
  reviewed.

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                                                                       143
     Beginning  in  fall  1967, the more  polluted  spoil  (100,000 yd3) was
placed in a diked experimental disposal area (No. 9) near the  south end of
Buffalo Outer Harbor [Figure 13].110  Between 1968 and about 1973, the Buf-
falo River spoil and about 50,000 yd3/year of hopper dredge spoil from near
the mouth of the Buffalo River (classified as seriously polluted because of
mercury content) were disposed  of in the No.  9 diked area and a new diked
area at Times  Beach near the mouth  of  the  Buffalo  River [Figure 13].110
The remaining  spoil  (about  400,000 yd3/year) was dumped in the  Bethlehem
open water area.  Between 1974 and  1977,  all dredged spoil was disposed of
in the two diked areas.

     The disposal area  dikes were constructed of steel mill slag.  Engi-
neering studies  found the dike material to  be  relatively porous.111  Thus,
as the spoils  dewatered, the water  could  seep  out through the  dikes carry-
ing any soluble pollutants with it.  The dredged spoil in the No. 9 disposal
area was  found to  have low  permeability.   The extent to which  leaching
could still occur from  these diked  sites  would be reduced by this  low per-
meability but could still occur.

     In 1977, a new 107 acre diked disposal  area was completed at the south
entrance to Buffalo  Harbor  adjacent to Bethlehem Steel and just north of
the old open water disposal  area [Figure 12].   Dikes for this area were con-
structed of rubble  which would also be  expected  to  be  porous.  All dredged
spoil is now  disposed  of in  this  new area  (No.  4).  Expected  capacity is
10 years of spoil.

     Data on the presence of priority pollutants in the early dredged spoil
is nonexistent.  However, it can be assumed that pollutants in  the spoil
were higher than at present because the Buffalo River and Outer Harbor were
much more polluted than at present.  A comparison of conventional pollutant
levels in bottom sediments  from various Buffalo River-Outer Harbor loca-
tions taken in  1967 and 1972 showed the  sediments  were less polluted in
1972.112  However,  the  1972  data still  showed Buffalo River sediments to
have higher lead and zinc  levels than  EPA  criteria for open water spoil
disposal.

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144
       Samples of bottom sediments from  several  locations  in  Buffalo  River,
  Outer Harbor,  and  the Black Rock Canal  were  collected  in  August 1981 by the
  Great Lakes Laboratory under a  Corps  of Engineers  contract.113   The  sediment
  samples were analyzed for  heavy metals,  several  conventional pollutants,
  PCBs, and pesticides.  Elutriate tests  were also  run  on  the sediments.   A
  comparison of  the  metals  concentrations with EPA Region V sediment criteria
  indicated that all  stations were classified  as  heavily polluted for  at least
  one metal.  Most samples had high levels of four or five metals.  The most
  contaminated sediments were  found  in  the Buffalo  River  and  in the  Black
  Rock Canal near the mouth of Scajaquada Creek.

       Some PCB contamination  was  detected at most  stations,  usually below
  1.0 ug/g  dry weight  and  all below  10 M9/9-   Low levels of pesticides were
  detected  in some samples,  usually  less than 0.5 (jg/g with  a few samples
  exceeding 1.0  ug/g.

       Elutriate tests demonstrated that  some pollutants  are  released from
  the sediments  in the water column.  These include  mercury and phenols.   The
  report concluded that critical  releases  during dredging and disposal may
  not  initially exist  but  the potential  for long-term releases exists.   Be-
  cause of this  potential  for pollutants to be released  into the water column,
  alternative dredging and disposal  practices may have  to  be  considered.113

       The  current  environmental  monitoring program for the  Niagara  River
  system is  not designed to assess the magnitude of priority pollutants con-
  tributed  by past and present dredging and spoil disposal practices.   Based
  on the above information, a modification of the monitoring program to eval-
  uate this non-point source is needed.

  Contaminated Bottom Sediments

       As  indicated  in the previous  discussion on  dredged spoil disposal,
  bottom sediments in the Buffalo River, Buffalo Outer Harbor, and Black Rock
  Canal  are contaminated with persistent  priority  pollutants  above  levels
  acceptable  for  disposal  of dredged spoil in open waters.  Other areas  of

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                                                                       145
contamination were discussed in Section IV.  These sediments in stream and
river channels and in  shallow  water areas of Lake Erie are susceptible to
movement and resuspension  in the  water column by wave action and/or high
stream flow during storms.

     The extent to which contaminated bottom sediments are a source of the
persistent priority pollutants  observed in Niagara River suspended sediments
is not defined.   This  non-point  source needs to be evaluated to assist in
development of control  strategies.

Combined Sewer Overflows

     About 55  combined  sewer overflow points are  located along the Buffalo
River and  its  tributaries,  the Buffalo Waterfront, and the Upper Niagara
River.  These  overflows contributed significantly to pollution of the Buf-
falo River in the past with overflows occurring as often as every 5 days on
the average.   Overflows allow  untreated municipal and  industrial wastes to
enter the  river where priority pollutants may  settle into the bottom sedi-
ments in the  slow-flowing  lower  reaches,  adding to the contamination from
point sources and upstream runoff.

Urban Runoff

     The Buffalo River, Scajaquada Creek and the Niagara River receive large
volumes of urban  runoff from  the Buffalo area following precipitation or
snowmelt.   This runoff may contribute to the sediment contamination in Buf-
falo River and at the mouth of  Scajaquada Creek.

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                                                                     147
               VII.   MAJOR SOURCES OF CHEMICAL SUBSTANCES,
                     TONAWANDA-NORTH TONAWANDA SUBAREA
     This subarea extends along the Tonawanda Channel of the Niagara River
from the north boundary of the City of Buffalo to the north boundary of the
City of North Tonawanda.   It includes the west part of the Town of Tonawanda
and the Cities of Tonawanda and North Tonawanda.   All of the subarea except
the City of North Tonawanda (Niagara County) is in Erie County.  Tonawanda
Creek (Erie Canal) and Ellicott Creek enter the Niagara River near the mid-
dle of the subarea.

     There are 11 major industrial sources and two major municipal  sources
in  this  subarea.   Six of the industrial sources and  the  two  municipal
sources are major wastewater dischargers.  With the exception of the Hooker
Durez plant and the City of North Tonawanda wastewater treatment plant, all
of these facilities are in Erie County.   No major active commercial hazardous
waste disposal facilities are in the subarea but there are 55 hazardous waste
disposal sites of concern.  Thirty-three of these are located at major indus-
trial sources.   Important non-point  sources  in this subarea include urban
runoff and contaminated bottom sediments.

     Most of  the  major point sources are along the shore of the Tonawanda
Channel [Figure 10].

INDUSTRIAL POINT SOURCES

Chevrolet Motor Division

     The Chevrolet Motor  Division  of General Motors Corporation operates
three plants  (Forge  Plant,  Metal  Casting Plant,  and Motor Plant)  at one
site in  the  Town of  Tonawanda [Figure 14].   The facility makes automotive
motor assemblies and parts.

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148

                       !^U JK/^///
                                                
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                                                                     149
     About 23 mgd of treated process wastes and cooling water are discharged
to the Niagara River through one outfall.   The discharge contains low levels
of organic priority pollutants and heavy metals but daily maximum discharges
of phenols are about 55 Ib/day.   The high phenol loads occur during mainten-
ance problems in the treatment system.   The plant does not discharge waste-
waters to a municipal system.

     ICS responses were  submitted for  all three plants.88  A wide variety
of chemicals of concern are used in the plants with a use rate of more than
10 mil  Ib  annually.   More than 6,000  gal.  of PCBs are present in closed
systems.  Other  substances  used of  particular concern  include asbestos and
several degreasers.

     Emissions of  air  pollutants  of concern reported  include small  amounts
of trichloroethane and trichloroethylene,  54  tons/yr of organic solvents,
28 tons/yr of miscellaneous organics,  and 55,000 tons/yr of carbon monoxide.78

     A  RCRA  permit application  requested approval for  container  and  tank
storage  capacity of  660,000 gal.  of hazardous  wastes.90   Tank treatment
capacity of 0.735 mgd was also requested.   The plant reports annual hazard-
ous waste generation of more than 60,000 tons, primarily degreasing solvents.

     No site contamination data were reviewed for this facility.

Dunlop Tire and Rubber Corporation

     This facility in  the Town of Tonawanda [Figure 14] manufactures  motor
vehicle tires.  The plant began operation in 1920.

     About 4  mgd of  cooling water and  process wastes  are  discharged to the
Niagara River.   Most of  this  supply is obtained  from  the  River  and  Company
wells onsite.  Both  the  permit  application and EPA sampling indicate that
the effluent contains less than 1  Ib/day of organic priority pollutants.114
Because this effluent does contain process wastewaters, permit limits should
include priority pollutants used in the plant.

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150
        Some wastewaters (about 0.15 mgd) are discharged to the Town of Tona-
   wanda sewer system.

        Chemicals of concern used  in  the plant,  as reported in  the  ICS  re-
   sponse,  total  more than  300,000  Ib/yr  with 18,000  Ib  in  storage.88  Toluene
   and xylene were included.

        Process emissions of  air pollutants  of concern reportedly include small
   amounts  of  toluene,  trichloroethylene, zinc,  and  28 ton/yr  of  organic
   solvents.78

        Dunlop did not apply  for a  RCRA permit for hazardous  waste management.90
   For many years,  various industrial  solid wastes which may have contained
   hazardous wastes were disposed  of  in  pits and  piles  on  the  plant  site.115
   This may have resulted in  significant  groundwater  contamination.   Three ITF
   sites are designated at  this location  and are proposed for subsurface  inves-
   tigation.8

   FMC Corporation

        This plant in the Town of Tonawanda  [Figure 14]  is  an inorganic chemi-
   cals manufacturer.  Products  include  a variety of persulfates, paracetic
   acid, and  calcium, zinc, and hydrogen peroxides.  Perborates were produced
   until 1980.  FMC began operations at this site  in  1952.   From 1925 to  1952,
   the facility was the old Buffalo Electro-Chemical  Plant.

        About 7 mgd of river water  are used  for contact  and non-contact cooling
   and process (0.15 mgd) purposes.  Much of the process wastewater  and contact
   cooling water is recycled.   The  permit application indicates a daily maximum
   of 5 Ib of heavy metals  (primarily zinc)  is discharged to the Niagara  River.
   No other priority pollutants are discharged. EPA sampling in November 1980
   detected no priority pollutants.116

        Less than 5,000 Ib/year of  chemicals of concern  are used at  this  plant
   according  to  the ICS  response.88  About  180 gal.  of  PCBs are present  in a
   closed system.

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                                                                       151
     The plant  has  negligible process  emissions of  air  pollutants of
concern.78

     The RCRA permit application  indicates about 25,000 metric tons/year of
hazardous wastes are  handled,  primarily corrosives.90  Storage (tank and
container) totals 84,000  gal.  Treatment capacity in tanks is 0.066 mgd.
An EPA  inspection on  December 17, 1980,  found the facility in compliance
with RCRA Interim Status Standards.117

     About 100  tons of  various products and raw materials have been dis-
posed of in four pits  onsite.118   Remedial measures (closing the pits)  have
been completed.   This site  is proposed for subsurface investigations.8
Some zinc contamination may be present.

Polymer Applications

     This firm  produces phenolic  resins  for plastic manufacture.  It is on
a small site adjacent to Dunlop and FMC [Figure 14].

     About 0.25 mgd of non-contact cooling water and roof and yard drainage
are discharged  to a  ditch across a powerplant site to the Niagara River.
This discharge is contaminated with phenols reportedly from surface runoff.
The plant uses  large  volumes of phenols.  Contamination of the plant site
occurred in the  past  from a lagoon and  a leaky  waste storage tank.   The
tank and lagoon sites  have been excavated and contaminated material  removed
but site contamination still exists.  Process and sanitary wastewaters are
discharged to the Town of Tonawanda.

     Phenol  and  formaldehyde are  the  only chemicals of concern reported in
the ICS response.88   Volumes used and stored are large; 7.5 mil  Ib/year and
170,000 Ib in storage.  Because of the existing site  contamination and the
large volume stored and handled,  the facility should have a Best Management
Practices (BMP) Plan.
     No process  emissions  of air pollutants of concern were reported for
this facility.78  No RCRA hazardous waste management permit application was
listed.90

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152
   Allied Chemical  Corporation

        The Specialty Chemicals Division of Allied operates this plant in the
   Town of Tonawanda  [Figure  14]  for the production of polyethylene plastic.
   Process wastewaters are discharged to the Town of Tonawanda.   About 4.5 mgd
   of Niagara Riv^~ •./='-|-?~ <,'«°H  for non-contact cooling  is  mixed with small
   amounts of storm runoff and contact cooling water and returned to the river.
   The permit application  indicated  that organic priority pollutants in this
   effluent were all  below detection limits.   Negligible amounts of heavy met-
   als were detected.

        Chemicals of concern reported in the ICS response were confidential.88
   Air emissions were minor.78

        Allied's RCRA permit  application indicated that about 15 metric tons
   of hazardous waste are handled annually.90  Container storage capacity of
   about 14,000 gal.  was  requested.   An EPA inspection on May 7, 1981, found
   the facility in compliance with RCRA Interim Status Standards.119

        Quantities of coal  tar,  scrap polyethylene, and  spent  catalyst  have
   been disposed of at this location at three sites.120  Subsurface investiga-
   tions  have  been  proposed by  DEC  to evaluate  potential  groundwater
   contamination.8

   Tonawanda Coke Corporation

        This facility, adjacent to Allied Chemical [Figure 14], produces found-
   ry coke from coal  in 60 ovens.   Byproducts include light oil (benzene, tol-
   uene, xylene), tar, and coke oven gas.  Ammonia is no longer recovered as a
   byproduct.  This plant was formerly operated by the Semet-Solvay Division
   of Allied Chemical.

        About 2.6 mgd of cooling water and coke quenching wastewaters are dis-
   charged to the  Niagara River after treatment  in  two  lagoons.   The permit
   application indicated that this discharge contained a daily maximum load of

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                                                                        153
5 Ib of  heavy  metals [primarily lead], 7 Ib of cyanide and 22 Ib of phe-
nols.   Average phenol  discharges  are only 1 Ib/day.  No organic priority
pollutants were present  above  detection limits.   A second set of special
samples for benzene, xylene, and toluene indicated they were below detection
limits.

     The  ICS response  indicated  that about 0.9 mil gal.  of coal  tar,  ben-
zene,   toluene, and  xylene  are  produced annually with about 50,000 gal.  in
storage.88

     No  significant process emissions of air  pollutants of  concern were
reported.78  However, coke ovens are known to emit benzo(a)pyrenes.

     No  RCRA permit application  has been submitted from Tonawanda Coke.90
Unknown  quantities  of  coal  tar and rubble were disposed of at three sites
at this facility for several decades.121  Surface sediment samples indicate
contamination with  polycyclic  aromatic hydrocarbons.   Groundwater is  also
potentially contaminated.121  Subsurface investigation has been proposed by
DEC.8

Union Carbide, Linde Division

     Union Carbide  develops, designs,  and fabricates  cryogenic hardware  at
a plant in the Town of Tonawanda [Figure 14].  During World War II the plant
also refined uranium ores for the Manhattan Project.

     The  plant has  no  direct wastewater discharge.   Wastewaters are dis-
charged  to the Town of Tonawanda sewer system for  treatment.  During the
uranium refining operations, caustic wastewaters containing low-level  radio-
activity  were  initially  discharged  to  town  sewers.122  Because this caused
operational problems at  the treatment  plant, these  wastewaters were alter-
nately discharged to five 150 ft deep wells onsite or through a storm sewer
to Two-Mile Creek.   About 37 mil  gal. of wastewaters containing radioactive
materials were injected in the wells.

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154
        The ICS response indicates about 10,000 gal. of 1,1,1-trichloroethane
   are used annually.88  About  a thousand gallons of chemicals are stored at
   one time.

        Process emissions of air pollutants of concern total  about 30 ton/year
   and are primarily trichloroethane and xylene.78

        The RCRA application indicates about 250 mil tons of hazardous wastes
   are handled each year.90   Container storage for  100 drums  and treatment
   tank capacity of 0.03 mgd were indicated.

        Some residual  radioactive contamination of soils and building materials
   is present  in addition to the groundwater contamination.  Soil and ground-
   water samples were  taken  in  March 1981 by the Department of Energy.  The
   Department  reported  in  December  1981  that radioactive contamination of
   groundwater was not a problem.123

        The well initially  used for waste injection was  formerly used as a
   water supply.   It was  out of service because of groundwater contamination
   before wastes were  injected.  The type  or  source  of  this contamination was
   not defined.

   Ashland Petroleum Company

        This is a petroleum refinery with a capacity of 62,000 barrels of crude
   oil per day.  Products are gasoline, fuel oil, asphalt, and aromatic petro-
   chemicals.   The facility is on the Niagara River adjacent to the south Grand
   Island bridge in the Town of Tonawanda [Figure 15].

        Process wastewaters are discharged to the Town of Tonawanda sewer sys-
   tem for treatment,   The  refinery  has four  direct  discharges to the  Niagara
   River.  The main discharge  is about 19 mgd  of non-contact cooling water
   which flows through a circulation pond before discharge.  The permit appli-
   cation  indicates this discharge  is  a major source of heavy  metals with  re-
   ported  daily maximum loads  of 199  Ib  antimony,  3 Ib copper, 17 Ib lead,

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                                       155
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   15 Ib nickel, and 8 Ib zinc.  Phenols were only 2 Ib/day and other organic
   priority pollutants  were below detection limits.   Two discharges are storm-
   water runoff with reportedly low contamination.   The fourth discharge is an
   intake screen backwash.

        The heavy metais discharges are above levels expected for non-contact
   cooling water, especially the  antimony.   A BAT level SPDES permit should
   require reduction of the metal  discharges.

        About 1.5 mil  gal. of  benzene,  toluene, and  xylene  are produced
   annually and  stored at the refinery according to the ICS response.88  This
   storage, coupled  with the stormwater contamination potential  of a refinery,
   indicates the need  for  a BMP plan to minimize contributions  of priority
   pollutants from ancillary activities.

        Process emissions of air pollutants of concern from the refinery report-
   edly include benzene,  xylene, and organic solvents totalling about 17 tons/
   year.78

        Ashland  Petroleum applied  for a RCRA permit to  handle and treat about
   576 metric tons of hazardous waste annually.90  This is  primarily DAF float
   from the process  waste pretreatment unit.

        Three ITF hazardous waste  sites are at this facility.124  Ashland  now
   owns the former  Haist property that was used for disposal of uranium ore
   residue (tailings) from the processing of Colorado ore at the Union Carbide-
   Li nde facility in the 1940s.83  Ashland removed some of the  tailings to
   the adjacent Seaway Industrial  Park landfill  and built storage tanks on the
   site.  Low level  radioactive contamination is present in the remaining tail-
   ings.  Some movement  of  minor amounts of radioactive contamination offsite
   in surface runoff may be occurring.  The Department  of  Energy is  reviewing
   long-term remedial measures.

        The other two  sites are a lead sludge  disposal  area  and a concrete
   storage pit for  API sludges.  DEC  has proposed subsurface  investigation of
   the lead site.8

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                                                                        157
Spaulding Fibre Company

     Spaulding Fibre manufactures various vulcanized fibers and high-pressure
plastic laminates, and also several grades of resin and paper for in-plant
uses at their plant  in the west  side of  the City of Tonawanda [Figure 15].

     Cooling and process wastewaters totaling about 2.7 mgd and 2.0 mgd of
stormwater are discharged through two outfalls to the Niagara River.   These
discharges are  reported  in  the permit application to be major sources of
heavy metals  (175  Ib/day of zinc daily maximum).  Zinc chloride is used in
the vulcanizing  process.   Reported zinc concentrations were more  than  5
mg/£ indicating  that BAT for this  facility should reduce maximum zinc dis-
charges by 80%.  The facility  is reportedly currently meeting its permit
limit of  70  Ib/day of zinc.   Other priority pollutants  in the discharge
were nil.

     The ICS response indicates this plant is a large user of phenol  (1 mil
Ib), zinc, asbestos, toluene,  and other chemicals of concern totaling about
2.4 mil lb/year.88  Onsite storage exceeds 400,000 Ib.

     Process emissions of air pollutants of concern included chlorine, phe-
nol compounds, and miscellaneous organics totalling 24 tpy.78

     A RCRA permit application was filed for storage in containers and tanks
(15,000 gal.) and  waste  piles  (1,400 yard3).90  No significant hazardous
waste volumes were reported.

     Four ITF hazardous waste disposal  sites are located at this facility.125
One contains 20  tons of  asbestos and fiberglass.  Another was a concrete
tank that formerly stored metal  sludges.  A third site was several lagoons
that contained  zinc  chloride and phenolics.  These have been excavated and
filled with clean  fill.   The  fourth site contains 750 drums of varnishes
placed there in 1978.  Monitoring wells are present.   No additional  remedial
action has been recommended by DEC.8

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158
   Columbus-McKi'nnon Corporation

        This facility on Ellicott Creek in the City of Tonawanda manufactures
   chains and hoists.  A variety of metal processing steps are used including
   pickling, degreasing,  and zinc phosphating.

        City water  is used for cooling and processes.  This water is recycled
   in sumps with blowdown from the sumps  averaging 0.08 mgd discharged through
   two outfalls to the Creek.   Organic priority pollutants and heavy metals in
   the discharge were less than 1 Ib/day.

        A large number of chemicals were  reported in the ICS response.88  Most
   of these  were either very small quantities,  industrial  gases,  or oils.
   Cutting oils are of concern at this facility as 27,000 gal.  of waste cutting
   oils have been disposed of in a pit.126  DEC has proposed subsurface inves-
   tigation.8

        Emissions of 62 tpy of paint thinner that could include air pollutants
   of concern were reported.78

        A RCRA permit application was filed for storage in containers and tanks
   (11,000 gal.  capacity) and tank treatment (0.01 mgd capacity).90  About 500
   metric tons/year of hazardous wastes including corrosives, chromium wastes,
   and pickling wastes are handled.

   Hooker Chemical Corporation, Durez Division

        This plant  is a chemical manufacturing  facility producing phenolic
   resin, phenolic molding compound, hexamethylenetetramine, paratertiary-octyl
   phenol,  zinc  and calcium stearates, alkyd molding  compound,  and diallyl
   phthalate molding  compound.   Formaldehyde,  used in several processes, was
   formerly produced.  The plant is in the northeast part of the City of North
   Tonawanda about 1 h miles from the Niagara River.

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                                                                        159
     Water supply of about 0.7 mgd is obtained from the City of North Tona-
wanda.   Sanitary wastes are discharged to the City.  All other wastewaters
including cooling water, utility water,  process wastes, and stormwater run-
off are discharged through 14 outfalls to storm sewers.  These sewers dis-
charge to the  Little River branch of the Niagara  River at  the north  end  of
Tonawanda Island.

     Sampling data and  the  permit application show that concentrations of
toxic organics, phenols,  and heavy metals were above BAT levels  in several
of the discharges.   The permit application indicated  that a total  of 27
organic priority pollutants were  detected  in one or more discharges.  The
reported daily maximum  load  of organic priority pollutants was 17 Ib/day.
The  highest  concentrations  reported were 38 mg/S, chlorobenzene,  18 mg/Z
benzene,  3.6 mg/£ phenol, 5 mg/£ dichlorobenzene, and 11 mg/S. 1,4-dichloro-
benzene.   Concentrations  in excess  of 1  mg/S. were observed for these five
organics during the May 4 and 5,  1981 EPA sampling with a  total  of 16 com-
pounds detected.

     Total phenols as high as 150 mg/£ were reported in the permit applica-
tion.  The EPA sampling detected total  phenols of 24 mg/1  in one outfall.
A  total  daily maximum  load  of 119  Ib/day was reported in the permit
application.

     Heavy metals  totalled 4 Ib/day, primarily  zinc.   Concentrations as
high as 2.5 mg/£ were reported.

     In the  ICS  response, Hooker indicated that chemicals  of concern used
at this plant  exceed  50 mil  lb/year.88  Storage exceeds 5 mil Ib.  Phenol
use exceeds  30 mil  Ib/year.   Other high volume substances  include formal-
dehyde, aniline,  and styrene.   Asbestos was used until  1978.

     Air emissions from processes include 73 tpy of formaldehyde and 26 tpy
of phenol  compounds.78

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160
        A RCRA application was  submitted  for the  handling of about 1,200 mil
   tons/ year of hazardous wastes.90  Hazardous  waste  management units  include
   50,000 gal. of container  storage,  540,000 gal.  of  tank storage, a 720 gpd
   solvent recovery  unit,  and a 720 gph incinerator.

        There are 14  ITF  hazardous  waste  disposal  sites  at this facility.127
   Materials landfilled include about 250 tons of phenol  tar that may contain
   chlorobenzenes and 28,000 tons of phenol-bearing materials.  Hooker is in-
   stalling wells to  assess the  extent of  any groundwater contamination.

        Both surface  runoff  and  groundwater  contamination are known to occur
   at this  facility.  Contamination may be infiltrating  plant sewers.   This
   contamination is the  result of  past spills  as well as  waste  disposal.

        It  is apparent that permit limits need to be established for a number
   of organic priority pollutants observed in wastewater discharges to reduce
   concentrations discharged to  BAT levels.   The site also  has  significant
   contributions of priority pollutants from ancillary activities (primarily
   past waste disposal activities).  A comprehensive best management practice
   (BMP) plan is needed  to minimize these contributions.   The plant has some
   BMPs in use.

   MUNICIPAL POINT SOURCES

   Town of Tonawanda

        The Town of Tonawanda operates an advanced activated sludge wastewater
   treatment plant  that serves a population  of about 129,000  in both the  Town
   and the  City  of  Tonawanda and the Village of Kenmore  [Figure 15].  Waste-
   waters formerly treated at the City plant are now diverted to the Town plant
   and the  City  plant has been abandoned.  Design flow for the town plant is
   30 mgd  and dry weather flow is about 15 mgd.   Treatment units in addition
   to the standard activated sludge process include chemical clarification for
   phosphorus removal and  mixed media  filtration.  The plant  was  completed  in
   1978.

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                                                                        161
     At least 20 industrial plants are connected to this treatment facility
with about two-thirds  discharging some or all of  their process wastes to
the town for treatment.  Influent priority pollutants from these industries
are not defined.

     EPA sampling of the plant effluent in May 6 and 7, 1981, detected only
low  levels  of priority pollutants.128  Organic  priority  pollutants were
about 2  Ib/day,  heavy  metals  1 Ib/day  and phenols  essentially zero.   Seven
organic priority pollutants were detected in the  effluent,  most  at less
than 10 ug/£.

City of North Tonawanda

     This new wastewater treatment plant serves the City of North Tonawanda
and  at  least 10 industrial facilities.  Average  wastewater flow is  about 9
mgd; design  flow is 15 mgd.  Industrial inflow is  less than 1 mgd.

     The plant  uses  physical-chemical  treatment processes.   Units include
flow retention basins for stormwater surges, primary clarifiers with chemi-
cal addition, sand filters, and activated carbon filters.   Such a treatment
system design is effective in removing most priority pollutants.  The acti-
vated carbon filters have been plagued by construction delays and equipment
malfunctions and are not yet in service.

     Plant effluent  was  sampled  by EPA in May 1981.12S Total organic pri-
ority pollutants were about 14 Ib/day.  Heavy metals were only 3 Ib/day and
phenols were essentially zero.   Specific organic  priority pollutants de-
tected  included trichloroethylene, chlorobenzene,  1,1,1-trichloroethane,
chloroform,  1,2-trans-dichloroethylene,  methylene  chloride, tetrachloro-
ethylene, and toluene.   The  activated carbon filters would be expected to
substantially reduce the discharges of these organic substances.

HAZARDOUS WASTE DISPOSAL SITES

     There are  no active major commercial hazardous waste management/dispo-
sal facilities  in this study subarea.   There are 34 ITF-identified hazardous

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162
   waste disposal facilities at  major  industrial  point sources.  These were
   discussed under each point source above.

        An additional 21  hazardous  waste  disposal  sites have been identified
   at other  industrial  facilities or at  nonindustrial  (offsite)  locations.

   NON-POINT SOURCES

        Non-point sources of priority pollutants in this subarea appear to be
   less significant  than  in the  Buffalo-Lackawanna or Niagara Falls subareas.
   Contaminated bottom  sediments  have been detected in  the Tonawanda Channel.
   During high  flows  in the  Niagara River,  these  bottom sediments contribute
   to the load  of priority pollutants carried by suspended  sediments in the
   river.   Conversely, this area may be a sink for contaminated sediments dur-
   ing  low flows.   Contaminated  sediments dredged from the  Tonawanda Harbor
   channels are disposed of in the Buffalo spoil  disposal  areas.

        Urban runoff  from Tonawanda and North Tonawanda probably contribute
   some priority pollutants.   There are eight combined sewer overflows in North
   Tonawanda.

        The contributions of these non-point sources are not defined.

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                                                                       163
               VIII.   MAJOR SOURCES OF CHEMICAL SUBSTANCES,
                          NIAGARA FALLS SUBAREA
     This subarea extends  from the north boundary  of  the City of North
Tonawanda north to Lake Ontario.   It abuts the north shore of the Tonawanda
Channel and the east shore of  the  Lower Niagara River.  The entire subarea
is in Niagara County.

     There are 12 major  industrial sources and one major municipal  source
(the City of  Niagara  Falls wastewater treatment plant)  in this subarea.
Most of  the industrial sources are  in the City of Niagara Falls or Town of
Niagara.   There are three  major commercial hazardous waste management fa-
cilities.  Two of these  are large disposal sites.  An additional 61  haz-
ardous waste  disposal  sites  of concern have  been identified  in the study
area.  These  include   Love  Canal,  Hyde Park  Landfill, the 102nd Street
landfills, and the Niagara County Refuse Disposal  Site.  Twenty-eight of the
disposal  sites are at major industrial sources.

     Important  non-point sources  in  this subarea  include contaminated
groundwater,  combined  sewer  overflows,  contaminated bottom sediments, and
urban runoff.

INDUSTRIAL POINT SOURCES

Bell Aerospace Textron

     This facility,  adjacent to the  Niagara  Falls  International Airport
[Figure 16],  manufactures  and  tests missile and space vehicle components,
high-energy lasers, and  various  aircraft parts and electronic navigation,
communication, and guidance systems.

     Process wastewaters are discharged with sanitary wastes to the City of
Niagara  Falls for treatment.   Consideration  has been  given to diverting
these wastewaters to the Niagara County  Sanitary District No.  1 wastewater
treatment plant.

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     Cooling and  stormwaters  averaging  about 0.09 mgd are  discharged  to
Bergholtz Creek through two outfalls.  These discharges contain small vol-
umes of chromium and zinc from cooling tower blowdown.

     About 100 chemicals  of  concern were reported in the ICS response.88
Most of  these were  in small volumes of 100  Ib/yr or 10 Ib in storage.  The
largest  use and storage were  for trichloroethylene (16,000  Ib/yr and 6,500
Ib, respectively).

     Process emissions of air pollutants of concern include about 62 tpy of
trichloroethylene and small amounts of lead and zinc.78

     Bell Aerospace applied  for a  RCRA  permit for storage of hazardous
wastes in a 240,000 gal.  surface impoundment.90  This  is  a pretreatment unit
for plating wastes  discharged to the City.   Only about 2 metric ton/yr of
hazardous wastes are handled.

     The plating  waste  lagoon is an ITF hazardous waste  site and has been
proposed for subsurface  investigation  by DEC.8  There is a potential for
groundwater contamination by lagoon seepage.130

Hooker Specialty Chemicals Division

     This Hooker facility on Buffalo Avenue in Niagara Falls [Figure 17] is
the largest and most complex chemical manufacturing facility in the Niagara
Frontier.  It has received much public and regulatory attention as a result
of  Love  Canal and other Hooker  hazardous waste disposal  sites and  its dis-
charge of mi rex and other releases  of chemical  substances of environmental
significance.   Hooker's  past hazardous waste  disposal practices  are the
subject  of active litigation.   Extensive engineering studies and pollution
abatement activities  have been  undertaken  with respect  to  both hazardous
waste disposal sites  and  wastewater discharges.  The present SPDES permit
contains numerous limits  on  priority pollutants and  other  chemical  sub-
stances.   Because of all this activity, voluminous file materials and publi-
cations  are available on this facility.   To put the environmental  effects of
the Hooker plant  in the same perspective as other major industrial  sources of

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166

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                                                                        167
chemical substances, the  following  discussion will primarily consider the
same types of information as at other facilities.

     More than 250 chemicals have been produced at this facility since 1930.
The plant produces  chlorine and  caustic by the diaphragm process (85%) and
by the mercury cell process (15%).   A wide variety of chlorinated compounds
also are or  have  been  produced.   These have  included various chlorinated
toluenes, dechlorane (a  fire  retardant),  and mi rex  (a pesticide with the
same formula  as dechlorane),  hexachlorocyclopentadiene (C-56), chlorinated
benzenes, and trichloroethylene.

     About 6  mgd  of process wastewaters containing a wide variety of pri-
ority pollutants  are discharged  to  the City  of Niagara  Falls wastewater
treatment plant.   Other  wastewaters,  primarily non-contact cooling water,
totaling about 38 mgd  are discharged to the  Niagara River.  Most of this
flow is  discharged directly to the River at  the plant site.  Part of the
flow goes to  the  Niagara Falls  Diversion Sewer that connects to the dis-
charge tunnel for the City wastewater treatment plant and discharges to the
Niagara River below Niagara Falls.

     Although the  direct  discharges are primarily  cooling water, they con-
tain major loads of chemical substances.   Total organic priority pollutants
reported in the permit application  have a daily maximum load of about 100
Ib.  Other organic chemical  substances not required to be reported in the
permit  application have been detected in these  discharges  in the past.
Heavy metals  daily maximum  loads totaled 69  Ib.  Phenols were only about 4
Ib/day.

     Extensive engineering  studies  by Hooker have indicated that up to
three-fourths of this priority pollutant load may be contributed by contam-
inated  surface  runoff  and by contaminated groundwater  infiltration into
sewers.   Higher loads were discharged in the past.   Various improvements to
reduce sewer  infiltration have been completed and  others are planned.  En-
gineering studies  have been completed by Hooker at DEC's request to form a
basis for systematic  further reductions in  these  discharges  of priority

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168
     pollutants  and  to develop the basis for additional, more stringent permit
     limits  for  a variety of chemical substances.   Major  reductions  in these
     discharges  of priority  pollutants are  expected  by mid-1984  as  BAT  require-
     ments become effective.

          Hooker's ICS response declared chemical  names  and  use  rates confiden-
     tial.88   It is  evident from the complexity  of  this facility's operations
     and  processes that large  volumes of numerous  chemicals  of concern  are  used
     and  stored.

          Process emissions  include at  least 10 air pollutants  of concern of
     which the emission of 110  tpy  of chlorine is the most significant.78  Other
     significant emissions are  chloroform, benzene,  ortho-chlorotoluene (22 tpy),
     and  mercury.  Total  emissions of air  pollutants of concern are about  140
     tpy.

          Data on the Hooker RCRA  permit application were not included in  the
     Region  II computer listing.90   It  is obvious,  however,  that Hooker is a
     major  generator of hazardous  wastes.   Large  volumes  of hazardous wastes
     have been disposed of in the past at Hooker-owned sites at  Love Canal, Hyde
     Park, and 102nd  Street.  About 75,000 tons of hazardous wastes have report-
     edly been landfilled on the Buffalo Avenue plant site.   Various hazardous
     waste  management facilities are present at  the site  including container,
     tank and  surface impoundment storage units, treatment units  and an incinerator.

          Contamination  of  the Hooker plant site  by  hazardous waste disposal  is
     the  subject of  active litigation.   It  is evident, however,  that much of the
     plant  site  and   the underlying groundwater are  contaminated with  chemical
     substances  and  these pollutants are being transported  offsite by  surface
     runoff  and  sewer infiltration.  A  comprehensive Best Management Practices
     (BMPs)  plan and  specific BMPs  should be required by the  new SPDES  permit to
     minimize  the contribution of  priority  pollutants from  existing contamina-
     tion of the site and to prevent future contamination by spills and leaks,
     hazardous  waste  management  activities,  and  other  ancillary activities.
     Hooker  has  already initiated a number  of BMPs.

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                                                                           169
     There are 10  ITF  hazardous  waste sites at  this  plant.131   They are
under active litigation.   More than 100 monitoring wells have been installed
and  voluminous  data collected.   Future monitoring  and  remedial  measures
will primarily be determined by the litigation.
DuPont
     This facility, west  of  Hooker adjacent to the Niagara River and Gill
Creek [Figure 17], manufactures inorganic and organic chemicals.  Products
include chlorine, sodium, copper and zinc cyanides, polytetramethylene ether
glycol from tetrahydrofuran, polyester, and electroplating bath additives.
An April  1979  ICS response indicated that until  about  1975  the facility
manufactured up  to 500  mil Ib/yr of chloroform,  carbon  tetrachloride (a
byproduct), methyl  chloride,  methylene chloride,  tetrachlorethane  and
trichlorethylene.

     About 2 mgd of process,  utility and sanitary wastewaters are discharged
to the City of Niagara  Falls wastewater treatment plant.  An additional  11
mgd of wastewater, primarily  non-contact cooling water, is discharged di-
rectly to  the Niagara River via two outfalls, to  Gill Creek  in one outfall
(3.1 mgd), or to the Diversion Sewer in one outfall  (5.5 mgd).  The permit
application indicates the  direct discharges have  daily maximum loads  of  26
Ib organic priority pollutants,  5  Ib heavy metals, and 2 Ib phenols.   The
organics  were  primarily carbon tetrachloride,  chloroform,  and methylene
chloride.

     DuPont1s latest  ICS response  declared the chemicals  used  and  their
volumes to be confidential.88   It  is evident, however,  that major volumes
of chemicals of  concern are used,  produced, and stored at this plant.  The
April 1979 ICS  response indicated  about 1500 gal. of PCBs were present in
transformers and  capacitors.   In the 1960's,  about  24,000 Ib/yr  of  PCBs
were used in a closed loop cooling  system with dirty oil sent to a reclaimer.

     Process emissions  of  air pollutants of concern  include  20 tpy of cop-
per, 2 tpy of zinc, and 14 tpy of  chlorine.78  Miscellaneous organic  emis-
sions of 11 tpy are also listed.

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170
          DuPont submitted a RCRA permit application which requested approval of
     tank storage capacity of 60,000 gal.90  About 154,000 m ton/yr of hazardous
     wastes were  handled,  primarily corrosives.   DuPont subsequently withdrew
     their permit application indicating that all hazardous wastes will  be moved
     offsite within 90 days.

          Five  ITF  hazardous  waste  sites are at this facility.132  Wastes dis-
     posed of  included  copper,  zinc and sodium  cyanides,  chlorinated organics
     (primarily volatiles), and barium salts.  Soil contamination by chlorinated
     organics,  cyanides,  and  metals was  possible.  One area contained soil con-
     taminated  by  PCB leaks.   In addition, sediments in the adjacent Gill Creek
     were found to  be contaminated  with  PCBs.  Most of this contaminated  mater-
     ial, including the Gill Creek channel, has been excavated and replaced with
     clean fill.  DEC has recommended a plant wide monitoring program for detec-
     tion of site contamination.

          Both  the nature of this plant's operations and the known contamination
     indicate the need for a comprehensive BMP plan.

     01 in Corporation

          01 in  operates  an inorganic  chemicals plant on 22  acres adjacent to
     DuPont and the Niagara River [Figure 17].  Sodium and chlorine are produced
     in a mercury cell.   Other products include calcium hypochlorite (HTH) and
     sodium chlorite and methylate.   Chlorine production began in 1897.

          About 0.5  mgd of process  wastewaters  are discharged  to the City of
     Niagara  Falls  for treatment.   Most mercury contaminated wastewaters are
     sent to the City after pretreatment for mercury removal.  Non-contact cool-
     ing water, boiler blowdown and uncontaminated, uncontrolled stormwater run-
     off totaling  about 7 mgd  is discharged to  the  Diversion Sewer via  four
     outfalls.

          01 in  obtains  its water supply from  the  Niagara  River  (70%) and from
     two 125  ft deep onsite  wells  (30%).  This well water is contaminated with
     organic  priority pollutants.   It is used for cooling  water  in the  HTH  pro-
     cess and  does  not  receive treatment.  Consequently, Olin's  discharges  con-
     tain a  large load  of organic priority pollutants  (274 Ib/day),  the largest

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                                                                           171
reported discharge in the Niagara Frontier.  A majority of this contamina-
tion is tetrachloroethylene, trichloroethylene,  trans-l,2-dichloroethylene,
and 1,1,2,2-tetrachloroethane.

     Heavy metals (primarily zinc; mercury is <0.1 Ib/day) at 8 Ib/day and
phenols at 4 Ib/day are also reportedly present.

     Olin and DEC are  negotiating a solution to this discharge of organic
priority pollutants through  the  SPDES permit process.   The current permit
contains limits on priority pollutants based on the  existing discharge.  A
new permit will  require  major  reductions.   This could be accomplished by
activated carbon filter  treatment of the well water or construction of a
recirculating cooling system using river water as makeup.  Costs of either
alternative are high.

     The ICS response indicated that Olin uses or produces large volumes of
chemicals of concern including 42 mil  Ib/yr of HTH.  About 7 mil Ib are in
storage.  About 250 gal.  of PCBs are in use in transformers and capacitors.

     Process air emissions from Olin include 65 tpy of chlorine and 0.3 tpy
of mercury.7S

     Hazardous waste management facilities  listed in the RCRA permit appli-
cation included 27,500 gal.  of container storage,  180,000 gal.  of tank stor-
age and 0.09 mgd of tank treatment capacity.90  About 600,000 tpy of hazard-
ous wastes are  handled,  primarily corrosives.  An EPA inspection on Decem-
ber 17,  1980  found  the  facility  in  compliance  with  RCRA Interim Status
Standards.133

     There are  five  ITF  hazardous waste sites at the Olin facility.134  A
125 ft deep well  was  used from 1963  to  1977  to dispose of about 130,000
tons of  C-2 end liquor.   Brine sludge possibly contaminated with mercury
and waste transformer oil that may have contained PCBs were spread at three
sites.   The old mercury  pond was excavated and refilled with clean fill.
Contamination of soil, surface,  and  groundwater with mercury is possible.
DEC has recommended subsurface  investigations at the Olin plant.8

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172
          Contamination of Gill Creek sediments with BHC (primarily Lindane) was
     detected.  The  contamination  was  removed by 01 in.  01 in produced BHC  and
     trichlorobenzene  from  1950 to  1956  but  did not manufacture  Lindane.135
     01 in attributed the Gill Creek contamination to a reported spill of chlori-
     nated benzenes from the old Solvent Chemical Company facility just upstream
     of the  contamination.   Olin also  indicated  that trichlorophenol contamina-
     tion in its well water may be related to Olin production of trichlorophenol
     from 1954  to  1956.   Other observed site  contamination  may be related to
     activities of at  least six other companies prior  to  1930 on this site.

          It  is evident  that site contamination is a major problem at Olin.  A
     comprehensive BMP plan is needed to minimize contributions of priority pol-
     lutants from the site.   Olin has been working on such a plan.

     Carborundum Company

          This facility at the west end of the Buffalo Avenue industrial complex
     [Figure 17] manufactures abrasives (silicon and boron carbides and aluminum
     oxide).  The plant has been in operation since 1895.

          About 3  to 4 mgd  of  process  wastewaters  are  discharged  to  the City  of
     Niagara  Falls for treatment.   About  4 mgd of  cooling  waters  and storm  run-
     off  are  discharged  to  the Niagara River  through  three  outfalls (50%)  and
     one  outfall  to  the  Diversion Sewer  (50%).  Water supply  is  obtained from
     the  river.  The discharges contain negligible priority pollutants.

          The  ICS  response  indicates the  plant is  a  major  user of phenol  (2 mil
     Ib/year)  and  also uses large  amounts of  trichloroethylene (18,500 Ib/year)
     and  coal  tar (140,000  Ib/year).88  Chemicals stored exceed 100,000 Ib.

          Process  emissions  of air pollutants of concern were  minor.78 No  haz-
     ardous waste management permit  application was listed.90

          An  ITF  site at this  facility was  a small coolant disposal  pit.136
     Remedial  measures will remove any contamination.   No  further investigation
     was  recommended by DEC.8

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                                                                           173
     Priority pollutant use  at  this  site suggests the need for a BMP plan
to prevent contamination of cooling water or surface runoff.

Goodyear Tire and Rubber Company

     This plant, at  the east edge of the Niagara Falls industrial complex
[Figure 17], manufactures vinyl chloride plastizol  resin, vinyl co-polymer
resin, and accelerators and anti-oxidant chemicals for the rubber industry.

     Process wastewaters averaging about 0.4 mgd are discharged to the City
of Niagara  Falls for treatment.   There are no direct discharges of waste-
waters from this plant.

     Goodyear uses  very large volumes of chemicals of concern totaling about
87 mil  lb/year.88  Vinyl  chloride (57 mil  Ib)  is the largest volume but
more than a million  Ib of each of the following chemicals are used:   ani-
line, o-toluidine,  nitrobenzene,  xylidene,  dioctyl  phthalate, mixed  tolui-
dines, and di-isooctyl phthalate.   Storage is about 1.7 mil Ib.

     Process air emissions include 32 tpy of vinyl chloride.78

     The RCRA permit application indicates that the facility has 1,000 gal.
of container storage  capacity  and an incinerator with a capacity of 0.116
ton/hr.90   Hazardous  wastes  handled  total  about  789  m ton/year.  This is
primarily hydrogen  sulfide that is incinerated.

     There are no ITF sites at this facility.137

Great Lakes Carbon  Corporation

     This facility at the northeast corner  of the Niagara Falls industrial
area [Figure 17] produces carbon  and graphite forms  from coke, coal  tar,
and petroleum pitch.

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174
          Sanitary wastes only are discharged to the City of Niagara Falls waste-
     water  treatment  plant.   There are no process wastewater discharges.  Non-
     contact cooling  water  and stormwater averaging 0.6 mgd are discharged  to
     Pike's Creek to  the 61st Street storm sewer to the Niagara River.  No prior-
     ity  pollutant  data  were  available  for this discharge, but pollutant levels
     are believed to  be negligible.

          The ICS response indicates the plant uses about 12 mil  Ib/year of coal
     tar, coal  tar  pitch,  and petroleum pitch.88  Storage is about 600,000 Ib.

          Process emissions  include  1,990 tpy of  carbon monoxide and  112 tpy of
     unspecified hydrocarbons.78

          No RCRA permit application was submitted.90  One ITF site is at this
     plant.138  Unknown  quantities of product and raw materials have been dis-
     posed  of  in  a  landfill.   DEC  has proposed  subsurface  investigations to  de-
     tect any  polynuclear aromatic  hydrocarbon contamination that  might be
     present.8

          A comprehensive BMP plan is needed for  this facility to  insure that
     priority pollutants  from raw material  storage do not enter the  untreated
     cooling water and storm  runoff.

     Airco  Carbon (Speer)

          This  facility  produces  carbon and  graphite  electrodes  and products
     from petroleum  coke,  coal, charcoal, carbon  black, and natural  graphite.
     Coal tar  pitch and other polymers  are  used  as  binders.   Chlorine  is also
     used in the process.

          The plant  has  no  direct wastewater discharge.   Wastewaters averaging
     about  1.5  mgd are sent to the City of Niagara Falls for treatment.

          No ICS  response was  listed for the Company.88  Chemical use similar to
     Great  Lakes Carbon  would be expected.

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                                                                           175
     Process emissions include 16,600  tpy of carbon monoxide, 0.3 tpy of
chlorine, and 0.02 tpy of benzo(a)pyrene.78

     No RCRA permit  application  was  listed for this facility.90   An ITF
listed site  reportedly received  asbestos  and large volumes of refractory
and sand.139  DEC has proposed subsurface investigations and monitoring for
polynuclear aromatics.8

Varcum Chemical Company (Reichhold Chemicals)

     This plant at  the  north edge of the Niagara Falls industrial complex
[Figure 17] produces phenolic  resins  used by the abrasive  industry.  Raw
materials include phenols and formaldehyde.

     Process wastewaters are  discharged  to the City of Niagara Falls for
treatment.  This discharge is a major source of phenols.   Phenol  discharges
as high  as  2,000  Ib/day  in the past have  been reduced  to about 100 Ib/day.
There  is  no direct  discharge of wastewaters.  However,  storm runoff may
have some phenol contamination.

     Varcum's  use of chemicals of concern  is  large with phenol/phenolic
compound use of more than 17 mil  lb/year.88  Xylene use is also significant.
Storage of phenols exceeds 1 mil  Ib.

     Process emissions of  air pollutants  of concern including phenol and
xylene are reportedly small,  less than 2 tpy.78

     The RCRA application indicates that Varcum has container storage capa-
city of 5,000 gal.,  tank storage capacity of 30,000 gal., and an incinerator
with a 400 gal./hr capacity.90  About 52 m ton/year of ignitable wastes and
spent solvents are incinerated.

     An ITF listed site at this plant was a settling pond used for phenolic
sludges and  resins.140   The  site has been excavated but there may be some
residual  phenolic contamination.   DEC  has proposed a  site investigation.8

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176
          Problems have  been  experienced in the past with material  spills  and
     runoff contamination.  A  BMP  plan is needed to minimize  any releases of
     priority pollutants.

     SKW Industries (formerly Airco Alloys)

          This facility  in north Niagara Falls [Figure 18] is a ferroalloy plant
     producing a variety of ferrosilicon, ferrochrome,  and ferromanganese alloys.

          The plant does not  have  any direct wastewater  discharges.   Sanitary
     wastewaters only are discharged to the City of Niagara Falls.  Storm runoff
     disposal was not defined.  The plant has large raw material piles including
     chrome ore.

          No  ICS  response was listed for SKW or Airco Alloys.88  Process emis-
     sions included 10.5 tpy of chromium oxide.78

          SKW did  not submit  a RCRA permit application.90  The facility has an
     active  industrial  solid  waste disposal  site  under  DEC permit.141   The  site
     has been  used for about  60 years  for  disposal  of large  volumes  of slag and
     flue dust.  The  dusts are moved in slurry form.  Groundwater monitoring has
     detected high levels of chromium.  Surface runoff is also contaminated with
     chromium.  This  is  an ITF listed site.

     TAM Ceramics (formerly NL Industries)

          This  Company in north Niagara Falls  [Figure  18]  produces specialty
     ceramic products  including dielectric materials, zirconium oxide  alloy, and
     electronic specialty products.

          The  facility has no direct wastewater  discharge.   About 0.4 mgd  of
     cooling  and  process water is  sent  to the City of Niagara Falls for treat-
     ment.   Infiltration of organic priority pollutants into plant sewers,  pos-
     sibly from the nearby Hyde Park Landfill, has been detected.

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                                                                        177
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178
        The ICS response lists about 1,400 Ib/year of asbestos  use.88  Process
   emissions include 29  tpy  of carbon monoxide and a small  amount of lead.78

        No RCRA permit application was listed.90  A 30-acre disposal site was
   used by NL  Industries to dispose of several thousand tons of various solid
   wastes (oxides, chlorides,  carbonates  containing zirconium,  and titanium).142
   This facility  is  adjacent  to the Hyde Park Landfill and related to that
   litigation.

   Union Carbide Corporation - Carbon Products Division

        The National and Republic plants  of this  Division  are in north Niagara
   Falls [Figure 18].  They manufacture carbon and graphite products from coal
   and coke mixed with coal tar and pitch binding resins.

        Wastewaters  (sanitary  and  contact and non-contact cooling)  are dis-
   charged to  the City  of Niagara Falls  for  treatment.  There are  no  direct
   wastewater discharges.

        The ICS  response  indicated that  about 32  mil  Ib of  petroleum and coal
   tars are used annually with about 2 mil Ib in storage.88

        Process  emissions  include  about  517  tpy  of  carbon  monoxide.78  The
   RCRA permit application indicated only nominal hazardous waste handling and
   storage.90

        An active industrial  solid waste disposal  site  (a  listed  ITF site)  is
   operated under DEC permit on 300 acres for disposal of carbonaceous material,
   air pollution  control dusts, fire brick, etc.143  There is possible contami-
   nation of ground  and surface water with coal tar derivatives.   DEC  has recom-
   mended monitoring for polynuclear aromatics.8  Monitoring wells are onsite.

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                                                                        179
MUNICIPAL POINT SOURCES

City of Niagara Falls

     The only  major  municipal  wastewater discharge in this subarea is the
new City  of Niagara Falls  advanced  wastewater treatment plant adjacent
to the Buffalo Avenue industrial complex and the Niagara River [Figure 17].
This plant  serves  the  City of Niagara Falls, part of the Town of Niagara,
and about 25 major industrial plants.

     Much of  the City  is  served by  combined  sewers.   Until 1978, dry
weather wastewaters  from  these combined sewers were  intercepted and  con-
veyed to a  primary treatment plant  in  the  Niagara River gorge about  1 mi
downstream  from the  American  Falls.   This plant provided  only  fine
screening and  chlorination.   Wet weather  flows were  bypassed  directly
to the  Niagara River at eight points  in the gorge.   By 1970, dry  weather
flows were about 70 to 90 mgd, far in excess of the plants 50 mgd capacity,
and continuous bypassing of excess flow occurred.

     During the  1930s,  the Diversion Sewer was built  to  collect cooling
water from  the Buffalo Avenue industries and  relieve  the  combined sewer
system.   The  Diversion Sewer  extends from 47th  Street westward  along
Buffalo Avenue  to  the  site of the present  treatment plant where it dis-
charges to  an  old  hydroelectric power plant tailrace tunnel.  This tunnel
discharges  to  the  Niagara  River below the Falls near Rainbow Bridge.   The
tunnel  now  also  receives  the effluent  from the new  wastewater  treatment
plant.

     In 1976 the  gorge pumping station at  the  site  of the old treatment
plant and a force  main to the  new treatment  plant were completed.   The
Southside Interceptor  was  also  completed  in  1976  to convey primarily
Buffalo Avenue industrial  wastes to the new plant.

     The new treatment plant was placed under construction in 1973 and com-
pleted in 1973.  It was and is one of the largest municipal advanced waste-
water treatment plants  in  the country.  It  is  a  physical-chemical plant

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180
     designed to handle a mixture of industrial-commercial-domestic wastewaters.
     Treatment  includes  chemical flocculation, pH  adjustment,  sedimentation,
     granular activated carbon contact, and chlorination.

          After a few months of operation, the carbon filter beds failed in 1978.
     Since July  1978  the  plant has provided only primary treatment.   The plant
     failure and  the  subsequent  delays  in  repairs have  resulted  in much  contro-
     versy  and  in  a  Federal-State suit  against the City.   Litigation  is
     continuing.

          Average dry weather  flow  to  the  treatment  plant  is  about 65 mgd, sub-
     stantially  above the  design flow of  48  mgd.   Wet  weather flows are much
     higher  and the combined  sewers  overflow at eight points  in  the gorge.

          Part of the cause of the excess  flow is sewer infiltration.  The plant
     was  designed  for  10  mgd of  infiltration.  Present infiltration estimates
     are  about 24 mgd.

          Analyses of the treatment plant  effluent in June 1981 by NEIC  found 26
     organic  priority  pollutants totalling 252  lb/day.31   Chloroform,   1,2,4-
     trichlorobenzene,  trichloroethylene,  and toluene concentrations were the
     highest at  36  to 72 ug/£.   Substantially lower concentrations  and loads
     would have been expected if  the carbon beds were in use.

          Heavy  metals  totaled 42 Ib/day, primarily copper.  This was substan-
     tially  below  design  limits because influent zinc  was well  below design.

          Total phenols were not  analyzed  by  NEIC.   City data indicate the plant
     discharged an average of 510 Ib/day of phenols  for the 12-month period end-
     ing  in  June 1981.

          Industrial wastes  are the source of most  of  the priority  pollutants
     discharged.   Contaminated groundwater infiltration  may also contribute
     priority  pollutants to the  system.

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                                                                        181
     Industrial wastes  discharged  to the system by  major  industries are
limited by contract  with  the City.  Flow is  limited to  26 mgd  in alloca-
tions to major  industries.   Waste  loads as defined by TSS and COD are also
allocated.   Specific priority  pollutants  are  not allocated.   The City has
undertaken a program to reduce phenol discharges to  the  system  from  indus-
try because this  is  the priority pollutant most difficult to remove  in the
treatment system.

     The SPDES  permit should include additional limits on priority pollut-
ants to provide adequate  control of  such  substances  in this discharge when
the carbon beds are  rebuilt.  The permit should also require other treat-
ment plant and  sewer system  improvement needs that have  been identified  to
be completed so that additional reductions in discharges of priority pollut-
ants can be achieved.

HAZARDOUS WASTE MANAGEMENT FACILITIES

CECOS (formerly Newco Waste Systems)

     This is a  very  large solid and hazardous  waste management facility
adjacent to the Niagara Falls  industrial  complex [Figure 17].   Waste dis-
posal areas cover  more  than 300 acres  and extend up to more than 50 ft in
elevation above the surrounding terrain.

     The facility accepts a wide variety of waste materials including muni-
cipal solid waste, industrial  solid wastes,  waste treatment sludges, and
hazardous wastes.   Activities  at  the site include a foundry sand reclama-
tion area,  a salvage yard, a sanitary landfill,  an intermediate landfill, a
secure landfill for  hazardous wastes, an  acid neutralization facility, and
an aqueous waste treatment facility.

     The site has  been  in operation  since 1896 and was initially a deposi-
tory for lime  wastes from an acetylene gas production plant.   These  lime
wastes are now used for acid neutralization.

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182
          The site  is  operated  under a DEC permit that requires extensive  envi-
     ronmental monitoring  including  surface  runoff,  groundwater,  leachate, and
     ambient air.

          There are two wastewater discharges from the facility.   Process waste-
     waters and landfill leachate are batch treated in the industrial wastewater
     facility that includes activated carbon filters.  Batch discharges are made
     to the  Niagara  Falls  sewer system about twice  a month.  Total  wastewater
     discharged averages about 0.5 mil  gal./month.

          Peripheral site  drainage receives  neutralization  and is  discharged  to
     a ditch leading to the 62nd Street storm sewer and the Niagara  River.  Neu-
     tralization  is  needed because  of  leachate or runoff from the lime wastes.
     EPA analysis  of this  flow (about 0.3 mgd) on May 5, 1981, detected phenol
     at 75 ug/£, methylene chloride at 10 ug/£ and seven heavy metals at concen-
     trations ranging  from <10  to 47 pg/£.144  Total toxics  load was <1  Ib/day.
     Sanitary landfill  leachate has  since been diverted  from  the  storm sewer
     system to the City of Niagara Falls for treatment.

     Frontier Chemical Company

          Frontier  Chemical  operates a hazardous waste management  facility in
     the Niagara Falls industrial complex under a DEC Part 360 permit [Figure  17].
     The Company treats aqueous wastes and operates a fuel recovery  process and a
     chlorinated  hydrocarbon  recovery  distillation unit.   No disposal  occurs  at
     this  facility.   Fuel  products,  recovered hydrocarbons, and residuals are
     sent elsewhere  for use or  disposal.

          The  RCRA permit application  listed container  storage  capacities as
     330,000 gal., tank storage capacities as 650,000 gal.,  and a 3,000 gal.  sur-
     face  impoundment.90   Total hazardous wastes handled  are  more  than 6,000
     tpy.  An EPA inspection on December 16, 1980 found the  facility in compli-
     ance with RCRA  Interim Status Standards.145

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                                                                           183
     The treatment system includes chemical  oxidation or reduction,  neutral-
ization, further oxidation, activated sludge, and a granular activated car-
bon column.  About  0.05  mgd of treated effluent is discharged to the City
of Niagara Falls.

     Infiltration of groundwater contaminated with organic priority pollut-
ants into  the  sewer system has been detected.   Soil borings also indicate
contamination is present.

SCA Chemical Services (formerly Chem-Trol Pollution Services)

     SCA operates this large  regional  hazardous waste management and dis-
posal  facility  on  630 acres  of  the  old Lake  Ontario  Ordnance Works
[Figure 19].  The facility has been in operation since 1972.

     A wide  variety of  hazardous wastes from western New York and other
states are treated,  recovered, or disposed of at this site.  In 1978, about
17% of the wastes were received from Erie and Niagara Counties and 42% from
New  York  State.146   Activities include  aqueous  waste  treatment, solvent
recovery,   fuel  recovery,  and  secure landfills.   A  liquid  incinerator was
operated until 1974.

     The RCRA application listed 43,000 gal. of container storage capacity,
54,000 gal. of tank storage capacity, 0.2 mgd of treatment capacity in tanks
and surface impoundments, other treatment processes with a capacity of 0.04
mgd, and 240 acres for land application.90  Hazardous wastes handled in 1978
were about 28 mil  gal.146

     The aqueous wastes (primarily landfill  leachate) are treated in a sys-
tem including biological  treatment, activated carbon filtration  oxidation,
lime precipitation,  sand filtration, and aeration.   The treated effluent is
stored in  large lagoons and tested before periodic batch discharges.

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184
                   Figure 19.  Lake Ontario Ordinance Works

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                                                                           185
     Two discharge paths have been used.   Prior to 1981 when a pipeline was
completed to the  Niagara  River west of the facility, wastewater was dis-
charged to Six Mile Swale at a controlled rate based on stream flow.  This
discharge began in 1977.  About 3 to 6 mil  gal./year were discharged.   Dis-
charges to Six Mile Swale have been terminated.

     Direct discharge to the Niagara River began in July 1981.  About 6 mil
gal. were discharged  in 1981.   Discharge occurs at a 1 mgd rate.  Based on
sampling of the lagoon  contents  and a 1 mgd discharge rate, this discharge
would contain about 1 Ib/day of organic priority pollutants and 5 Ib/day of
heavy metals.   Such a discharge would only occur a few days a year.

NON-POINT SOURCES

     Important non-point  sources in this subarea  include  combined  sewer
overflows, contaminated groundwater, urban runoff, and contaminated bottom
sediments.  Combined  sewer  overflows  occur  at eight points in the Niagara
River gorge along the west side of the City of Niagara Falls.   As discussed
in  the  section on  the City  sewer system, industrial wastewaters comprise a
large volume of Niagara Falls wastewaters.  Combined sewer  overflows would
thus be expected  to  be  significant sources of priority pollutants during
wet weather.

     Contaminated groundwater  is present  under most of the Buffalo  Avenue
industrial complex.  Specific conditions were previously discussed for each
major industrial  facility in that area.  Contaminated groundwater has also
been detected  in  north  Niagara Falls near landfills and industrial  plants
and in  the  Love  Canal-102nd Street landfill area.   Infiltration  of this
contaminated groundwater into industrial  sewers and wells may contribute as
much as one-third  of  organic priority pollutant discharges by industrial
and municipal point  sources in the study area.  Direct  groundwater flow
into surface waters  probably contributes  additional priority pollutants.

     Urban runoff from Niagara Falls through separate storm sewers directly
contributes some priority pollutants.   Another effect is the contribution
to combined sewer overflows.

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186
        Contaminated bottom  sediments  are  present in much of  the  Tonawanda
   Channel and the Lower Niagara River.   Concentrations  of priority pollutants
   are the highest  off  the  102nd Street landfill  area and the  Buffalo Avenue
   industrial complex waterfront.  Resuspension of these sediments  during high
   river flows can be a significant source  of contaminated suspended sediments.

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                                                                           187
                  IX.   ENVIRONMENTAL CONTROL PROGRAMS

     Environmental conditions,  their causes,  and  their effects  in the
Niagara Frontier  are  of local,  state,  national,  and international con-
cern.   Agencies at all  levels of government are thus involved in programs
to control and  regulate  activities that exert  an  effect on the environ-
ment.   This section reviews  the activities of  New York  State and  Federal
agencies  as  they  relate to  environmental  control  programs.   Several
Canadian  agency  activities  associated  with the Niagara River  are also
discussed.  Where needs  are  identified, suggestions are made for  program
changes or additions.

ENVIRONMENTAL STANDARDS

     Environmental standards  or criteria  have several  purposes.   They
form benchmarks  against which  existing environmental  conditions  can  be
measured.   They  specify  acceptable ambient air quality  to  protect human
health  and  acceptable water  quality to protect human  health  and other
beneficial water  uses.   They  are  often used  by regulatory agencies  to
determine the  need for  more  stringent  controls  on sources of air or
water pollution.  They  may  form the regulatory basis for specific limits
on sources of pollution.

     Environmental standards  are based  on  scientific  study and consider
health  risks  among other factors.   They are  defensible in regulatory
actions.  They  are useful  for objective evaluations  of environmental
problems  of  public concern.   This  is  especially important with  respect
to the  emotional  issues  surrounding toxic  substances in the environment.

Water Quality

     Section 303  of  the Clean Water Act  requires  that water  quality
standards be  established for all   surface  waters  of the  U.S.   These
standards consist  of  designated uses of stream segments based on  water
uses to be protected  and water quality  criteria for each designated use.
The crit?"-1'? -~*r.*fv  "levels  of water quality  that  must be  maintained or
exceeded to protect each water use.

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188
          EPA is given the  responsibility to develop and publish information on
     water quality required for various uses and other guidance for the develop-
     ment and promulgation of water quality standards.   The states are given the
     responsibility of  designating the water  uses to be  protected  in their
     streams and establishing associated water quality criteria.

          The NY Department of Environmental Conservation established water qual-
     ity standards for  the  waters of the Niagara  Frontier as  required by the
     Clean Water Act.  These were  subsequently approved by  EPA.  Specific water
     quality criteria included  in  these standards were discussed in Section  IV.
     These criteria give limited attention to chemical substances.

          Section 304 of the Clean Water Act amendments in 1977 required EPA and
     the states to give more attention to a series of specific toxic  pollutants
     known as priority pollutants.  EPA was required to develop and publish  re-
     commended criteria for 65 priority pollutants for protection of human health
     and aquatic life.  Recommended criteria were published  in a series  of cri-
     teria documents during 1980.   A summary of the water quality criteria was
     published in the Federal Register on November 28, 1980.

          In 1978, DEC  proposed revisions of their water  quality  criteria to
     include stringent  limits  on a number  of  additional  chemical  substances.
     There was much opposition to the proposed revisions and they were withdrawn.

          The International Joint Commission (IJC) has been active in establish-
     ing water quality objectives for boundary waters of the Great Lakes.  These
     objectives are not enforceable by either country but represent target water
     quality levels which  both countries have pledged to implement programs to
     achieve and maintain.   The Great  Lakes Water Quality  Agreement of 1972  es-
     tablished general  and  specific water quality objectives which addressed a
     few chemical  substances.   The 1972 agreement was superseded  by  the Great
     Lakes Water Quality  Agreement of 1978 which contained specific objectives
     for numerous chemical  substances.  The current New York water quality stand-
     ards are  keyed  to  the  1972 agreement and  do  not  reflect the more stringent
     1978 objectives or the recent EPA guidance.

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                                                                          189
     Revision of the  current  water quality standards is needed to include
specific criteria for  chemical  substances of concern in the Niagara River
consistent with IJC objectives and EPA guidance.  This would provide a ra-
tional basis  for programs to  control sources of these specific substances,
would ensure  protection  of  water uses, and would provide  benchmarks  for
assessing existing water quality.

Air Quality

     A similar  regulatory pattern  exists  with  respect to air quality.  The
Clean Air Act requires EPA to establish primary and secondary air quality
standards for  several  air  pollutants to protect human health.   The states
are required  to develop  implementation plans that prescribe control meas-
ures to achieve these standards.

     EPA promulgated  the required  air  quality  standards and New York deve-
loped an  EPA-approved  State Implementation Plan (SIP).  New York  also pro-
mulgated their own air quality standards which covered more pollutants than
the EPA standards.

     Coverage of specific  chemical  substances emitted to  the  air in  the
Niagara Frontier by  this  program was limited.  To offset this deficiency,
the DEC developed and  implemented  an approach  previously discussed  in Sec-
tion IV.   Lists of air contaminants  with high, medium, and  low toxicity
were prepared  and used to evaluate emission  inventories to identify speci-
fic sources  of  chemical  substances for review.  Acceptable ambient levels
were established for  some  air contaminants by the New York Department of
Health.    Published occupational  health limits were  used for  others with
appropriate  application  limits.   Simplified  air  modeling  techniques  are
used to identify sources that potentially cause ambient levels to exceed or
approach guidelines.   Any such sources are then required to conduct detailed
source and ambient studies  and develop and  implement control  measures as
needed.

     The DEC program for control  of toxic air contaminants  has only recently
been implemented in its present form.  The program appears  to have the poten-
tial to identify and control any significant sources of emissions of chemical
substances.

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190
     ENVIRONMENTAL MONITORING

          Monitoring of ambient environmental conditions and of pollution sources
     is an  important part of all environmental control programs.  Ambient moni-
     toring is needed to assess environmental quality with respect to the stand-
     ards previously discussed and to  identify trends and problem areas.  It is
     also useful  in  identifying  sources of pollution.   Monitoring of pollution
     sources  is  needed  to assess compliance  with applicable  limits on pollutant
     emissions or discharges, to define pollutant loads, to assist in interpreta-
     tion of  ambient data and to evaluate the efficiency of  pollution controls.

          Environmental monitoring has  been  conducted  for years in the Niagara
     Frontier by  both  American  and Canadian agencies.   Most U.S.  monitoring is
     done by  DEC  and  EPA while Canadian monitoring  is  primarily  conducted by
     Environment Canada and the Ontario Ministry of the Environment.

          Over the years, a gradual specialization and division of types of moni-
     toring primarily  performed has occurred for the Niagara River system.  Be-
     cause most water pollution sources are  located on the U.S. side of the River,
     DEC  and  EPA have  concentrated on  source monitoring.   The Canadians have
     concentrated  on  long-term ambient monitoring.  However,  all  agencies do
     some monitoring of all types.

          Because  of the growing international concern  over  chemical substances
     in the Niagara River, in early 1981 an  American/Canadian Niagara River Tox-
     ics  Committee was established to  oversee and  coordinate  a comprehensive
     investigation of  chemical  inputs  to the Niagara River.  The Committee  con-
     sists of representatives from DEC, EPA  (Region II - New York City and Great
     Lakes National Program Office - Chicago), Environment Canada, and the Ontar-
     io Ministry  of  the Environment.   The Committee developed a 2 h year work
     plan to  identify sources of chemical substances, recommend control programs,
     and  recommend long-term monitoring programs.

          Environmental monitoring  (both  ambient and source) was a  key element
     in the  work plan.   Ambient monitoring  of the  river designed to identify

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                                                                           191
areas of significant chemical substances input was proposed.   This included
water, sediment, and  biota  sampling.   Several special monitoring programs
were proposed to identify the occurrence and sources of specific substances
such as polyaromatic  hydrocarbons  (PAHs).  Some of the monitoring has been
completed and results are becoming available.  Data were  incorporated into
the preparation of  this  report as they became available.   Additional data
are expected  in the next few months that  should  assist in the design of
subsequent monitoring efforts.

     Monitoring of selected major  industrial  and municipal point sources of
toxic substances was  scheduled in the work plan.   EPA Region II conducted
monitoring of 11 sources in May 1981.   Preliminary results are used in this
report.   Monitoring of  the Niagara Falls  wastewater  treatment plant was
conducted by EPA-NEIC, Denver, in June 1981.   Data not restricted by litiga-
tion was incorporated in this report.   DEC has scheduled monitoring of addi-
tional sources.

     Contaminated groundwater  and  leachate from hazardous waste disposal
sites are important non-point sources of chemical  substances to the Niagara
River.  Some monitoring of these sources has occurred as part of the ongoing
DEC program  to  identify  disposal   sites requiring remedial measures  or  as
part of engineering studies  conducted by applicants for SPDES  permits dis-
cussed below.  However,  the  monitoring to date has not adequately defined
the significance of these non-point sources.

     A comprehensive  subsurface  investigation and groundwater monitoring
program has  been proposed  by DEC  to investigate  the  73 most significant
hazardous waste disposal sites remaining to be evaluated  and  to evaluate
contaminated groundwater conditions in the Niagara Falls industrial  complex.
This investigation  and monitoring program is needed to fill  critical gaps
in information on sources of chemical  substances.

     In addition to normal  EPA and DEC program funds and personnel  resources,
the Niagara  River investigations  have been partially  funded by EPA's Great
Lakes National Program Office.  This has enabled several specialized studies

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192
     and investigations to be funded.  The Niagara River is currently one of the
     Great Lakes National Program Office's top priorities.

          Recent results  of  the  monitoring programs, evaluated in light of the
     various  hydro!ogic  conditions  that  occur in the Niagara  River  system as
     discussed  in  Section IV, suggest  several possible  changes and additions  to
     the monitoring  program.  The wide variations in the concentrations  of  some
     chemical substances  appear  to  be at least partially related to changes in
     hydrologic conditions.  A detailed  study of recent monitoring data  and hy-
     drologic data  is  needed to  develop  and  refine correlations between  the two
     factors.  This would assist in defining the relative inputs of point sources
     and non-point sources and in defining source locations.

          Additional monitoring  locations  in the Upper Niagara River and  Lake
     Erie are needed to separate the effects of pollution sources in the Buffalo
     River-Buffalo Harbor area and in  the nearshore waters of Lake Erie.  Previ-
     ous studies have shown  that pollution from the Buffalo area enters the Upper
     River  in a narrow band along the east shore that may be missed by present
     sampling locations.   Some  sources of chemical substances which (based on
     sent data) appear to be located along the Tonawanda Channel may actually be
     in the Buffalo area.

          Large volumes  of polluted bottom sediments dredged from  Buffalo  River
     and Buffalo  Harbor  navigation  channels  were dumped in a shallow open-water
     area of  Lake  Erie near Bethlehem Steel prior to 1972.  This spoil area  is
     exposed  to wave action during wind storms  that can  resuspend these sedi-
     ments.   This  spoil area may be an additional significant source of persist-
     ent  chemical  substances observed in Niagara River suspended sediments.
     Present  sampling  is  not designed  to evaluate this  possibility.

     REGULATION OF WASTEWATER DISCHARGES

          The primary  program  for  regulation of industrial and municipal waste-
     water  discharges  is  the National Pollutant Discharge Elimination System
     (NPDES)  permit  program established by Section 402 of the Clean Water  Act.

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                                                                           193
(In New York, this is known as the SPDES permit program.)  This is a joint
Federal-State program.  EPA is required to establish overall program guid-
ance and regulations  and  develop and publish various guidelines.  Permit
program regulations have been published by EPA in 40 CFR Parts 122 through
125.  Effluent guidelines  on  which  permits are based are contained in 40
C7R Parts 400 to 460.

     Administration of the SPDES permit program in New York has been dele-
gated by EPA to the Department of Environmental  Conservation.   DEC has  pro-
mulgated their own  regulations  governing operation of the  SPDES  program
(Title 6, Environmental Conservation,  Article 3,  Parts 750-757).   DEC  re-
ceives permit applications from  dischargers,  develops permit conditions,
issues the permits, monitors  compliance  with permit conditions,  and takes
enforcement actions to achieve compliance when necessary.

     EPA retains program overview.  This is conducted by the Region II of-
fice in New  York City.   Region II conducts selected compliance monitoring
inspections and  provides  technical  assistance to DEC.   In some cases,  EPA
can also initiate enforcement actions  against dischargers to achieve com-
pliance.

     At the national  level, EPA is required to develop and promulgate regu-
lation effluent guidelines that specify what pollutants must be limited for
each type of industry and what volume of each pollutant may be discharged.
Similar effluent standards are promulgated for municipal  discharges.

     EPA promulgated effluent guidelines for most industrial categories  in
the mid-19701s.   These guidelines gave limited attention to toxic substances
because analytical methods did  not  exist for many of them and little was
known of their presence in wastewaters or the environment.

     As the  result of  a  1976 court settlement concerning a suit  filed by
the Natural  Resources  Defense Council  (NRDC) and the 1977 amendments to the
Clean Water Act,  EPA  was  required to develop effluent  guidelines for  34
industrial  categories that gave  special  attention to 65 toxic pollutants.

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194
     This list of toxic pollutants was subsequently expanded to the 129 "priority
     pollutants" that  include  the organic priority pollutants, pesticides, and
     heavy metals discussed throughout this report.

          Development of effluent guidelines for priority pollutants has proven
     to be  a  difficult, complex,  and expensive task.  As a result, promulgation
     of guidelines  for most  industrial categories has slipped  several years be-
     hind the  original  schedule.   Final  guidelines are still not available for
     most major industry types.

          Beginning  in 1975, DEC  issued SPDES permits to industrial dischargers
     based  on  the  early  EPA effluent guidelines.  Most permits  had few if any
     limits on priority pollutants.

          In  1976,  DEC  initiated  the Industrial  Chemical  Survey (ICS) that re-
     quired industries to  report  what chemicals  they used or produced that were
     included  on a  list  of "chemicals of concern".   This  list included most of
     the priority pollutants.  Industry responses to the ICS survey gave DEC its
     first  comprehensive information on priority pollutants potentially present
     in wastewater discharges.

          As  the initial SPDES permits began to expire, DEC issued short  term
     permits  based  on  EPA  policy  requiring permits to be issued  with expiration
     dates  based on expected effluent guideline  promulgation dates for that in-
     dustry.   In some  cases, DEC  added priority pollutant limits  in the short
     term permits  based  on the ICS response, plant evaluations and/or selected
     effluent  sampling.  In  many  cases,  the permittee was required to conduct
     special  short  term effluent  monitoring  to evaluate the  actual discharge of
     priority  pollutants potentially  present.   For several  complex plants, de-
     tailed  engineering  studies were required to develop methods  for abating
     discharges of priority pollutants.

          In  May 1980, EPA revised  its NPDES permit regulations  to require most
     industrial dischargers  to submit data on priority pollutants in their ef-
     fluents  as  part of  their permit applications.  DEC has now received  such
     data from most  major  industrial dischargers in the Niagara  Frontier.

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                                                                           195
     The Clean Water  Act requires all industrial dischargers  to  achieve
effluent limitations for priority pollutants based on best available tech-
nology (treatment or process  control) (BAT) by July 1,  1984.   The EPA ef-
fluent guidelines  under development  are  to prescribe BAT  for priority
pollutants.

     DEC has delayed issuing  long term SPDES permits containing BAT limits
because of the delays in promulgation of effluent guidelines.   Permits based
on guidelines are much easier to prepare and are more defensible under chal-
lenge by the permittee.  The  alternative is to prepare permit  limits based
on the best professional judgment (BPJ) of  the permit writer and available
information.   The permit regulations  allow BPJ permits  when no applicable
guidelines are available.

     DEC has indicated  that  it will begin  issuing BPJ permits by July  1,
1982, if EPA guidelines are not yet available.   This issue date is necessary
to allow permittees time to construct any needed treatment or control  units
and meet the July 1, 1984 BAT deadline.

     It is probable  that many guidelines will not  be available prior to
mid-1982.   Also,  promulgated  guidelines will not cover  all  processes at
some of the  more complex plants necessitating preparation of  part of the
permits by BPJ procedures in any case.  DEC has done much of the development
work for many  of the permits.  EPA has compiled extensive data that could
be used for BPJ permit development.   Therefore, it appears that preparation
and issue of BPJ permits for many of the major industrial dischargers  should
begin as soon as practicable.

     Based on  an  evaluation  of existing discharges of priority pollutants
from the 15 major industrial  facilities, reductions  in these discharges  of
more than 50% should occur  when BAT limits are achieved.

     A special need  with respect to the permit program  is related to the
need for Best  Management Practices  conditions  in the permit.   As discussed
in Sections VI-VIII, BMP plans and/or specific BMPs  are  needed at a number

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196
     of  Niagara  Frontier industrial  plants to minimize discharges  of  priority
     pollutants  from ancillary activities such as spills and leaks, raw material
     storage, and solid or hazardous waste disposal.  This is especially true in
     the  Niagara Falls  area where extensive groundwater  contamination exists.
     Some plants have partial BMP programs but more formalized implementation is
     needed.

          EPA has  promulgated  permit regulations specific to BMPs  (40 CFR Part
     125, Subpart  K)  but the effective  date  has  been  suspended  indefinitely  be-
     cause  of  industry  objections and  litigation on the overall permit regula-
     tions.  The permit  regulations  (40 CFR  Part 122.62(k)) contain adequate
     authority  to  establish BMP  permit  limits  for  the types  of  problems encoun-
     tered  in  the Niagara Frontier.   Clarification of EPA policy,  guidance,  and
     regulations  on  BMPs would be helpful in  gaining permittee acceptance of
     such permit conditions.

     REGULATION  OF HAZARDOUS WASTES

          Hazardous wastes  (as defined  by 40 CFR Part 261 promulgated  in accord-
     ance with  Section  3001 of the  Resource Conservation and Recovery Act) are
     subject to regulation by provisions of RCRA  essentially  from the time  of
     their  generation until  ultimate disposal.  The storage, treatment, and dis-
     posal  of industrial  solid wastes,  including those classified as hazardous by
     New York regulations  (not necessarily RCRA hazardous wastes),  are regulated
     by  a New York program governed  by  Title 6, New York Codes, Rules  and Regula-
     tions,  Part 360.  These two  programs regulate essentially all  current hazard-
     ous waste  management  activity in the Niagara  Frontier.

          Neither  RCRA nor  the Part  360 program apply to  inactive hazardous waste
     disposal sites.  To abate environmental impacts  from  inactive  sites, alter-
     nate approaches  are used depending on the severity of environmental problems
     and cooperation  of site owners. These  include negotiating voluntary reme-
     dial  measures,  litigation of recalcitrant cases, and direct  Federal/State
     remedial action  in  severe cases.

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                                                                           197
Active Hazardous Waste Management Facilities

     EPA has promulgated regulations under RCRA that specify what chemicals
and industrial wastes are hazardous wastes  (40 CFR  Part  261) and  establish
operating procedures for waste  generators and transporters (40 CFR  Parts
262 and 263). Regulations have also been promulgated (40 CFR Part 265) that
specify procedures that facilities that store, treat, or dispose of hazard-
ous wastes  must  follow  in  the interim period until they are issued a RCRA
permit.  These  "interim status  standards" specify  general  operating  proce-
dures and minimum facility standards.   EPA can enforce these regulations or
delegate their  enforcement  to DEC.  These  regulations  are currently the
primary  EPA method of regulating  hazardous  waste  management  activities.

     All facilities  that store,  treat, or dispose  of RCRA  hazardous  wastes
(TSD facilities)  are  required to apply for a RCRA permit.   This is a two-
step operation.   All existing TSD facilities have submitted a simple permit
application  (Part A) that defines  their activities  in general terms.  Upon
EPA request,  the facility must  submit a much more  detailed permit applica-
tion (Part  B) within 6 months of the request.  A RCRA permit is then pre-
pared and issued.

     RCRA regulations have  been promulgated for facilities that  store  or
treat hazardous wastes in containers,  tanks, and waste piles.   These regula-
tions  cover about two-thirds of active  hazardous  waste TSD facilities.
Regulations have not been finalized for existing disposal  facilities or for
facilities  that  store or treat  hazardous wastes  in  surface impoundments  or
for incinerators.  Part B applications are now being requested from facili-
ties with containers, tanks, and waste piles.  A few permits have been issued.

     Major  industrial facilities that  were  assigned high  hazardous  waste
management ratings in this  study are candidates for early  requests for sub-
mission of  Part  B applications.   RCRA permits should be issued to these
facilities  as soon as practicable  to help ensure that releases  of chemical
substances to the environment from storage and treatment of hazardous wastes
are minimized.

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198
          All storage,  treatment,  and disposal of industrial solid wastes, in-
     cluding  hazardous  wastes,  is subject to  regulation  by operating permits
     issued by  DEC  under their Part  360 program.   The three major commercial
     hazardous  waste  management facilities in the  Niagara  Frontier have such
     operating  permits.   These  permits specify operating conditions,  facility
     standards  and  environmental  monitoring  requirements more  stringent than
     RCRA interim status standards.   DEC monitoring of these facilities  and  en-
     forcement  of permit conditions should assure adequate environmental protec-
     tion until disposal regulations are promulgated by EPA and RCRA permits can
     be  issued  by EPA or by DEC after program delegation  to New York.  The cur-
     rent DEC operating permits may  meet  RCRA requirements when promulgated.

          DEC has issued Part 360 operating permits to most active  major indus-
     trial hazardous waste  TSD  facilities.   In some cases the facilities must be
     upgraded  to  meet permit requirements.   All  active TSD facilities  should
     receive  permits  and upgrade  their facilities as  soon as practical to mini-
     mize potential or actual releases of chemical  substances.

     Inactive Hazardous Waste Disposal Sites

          Following discovery of  the  Love Canal problems  in  1978, various activ-
     ities by New York State  and  EPA  led to the identification of about  300 haz-
     ardous waste disposal  sites  in the Niagara Frontier.  About 155 sites within
     3  miles  of the Niagara  River were selected  by DEC for  priority attention.
     Active sites were brought  under  Part 360  permit requirements.  The  125 inac-
     tive sites received different attention.

          The primary approach  used by DEC was to conduct a  preliminary  investi-
     gation of  each site and,  where  environmental  impacts  or hazards were evi-
     dent, negotiate with the site owner to conduct voluntary remedial measures.
     This was successful  in a number  of cases.  Remedial measures have been com-
     pleted on  many of these  sites.

          Where negotiations were not successful, legal action  was  initiated by
     DEC and/or EPA to  force remedial  work to proceed.   Such cases were filed
     against  the Hooker  sites at  Love  Canal,  102nd  Street,  and Hyde Park and  part

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                                                                           199
of the  sites at Hooker's  Buffalo  Avenue plant.   A case  was  also filed
against Olin's 102nd Street site.

     At Love Canal, the environmental and human  impacts were  such that New
York and EPA took direct emergency actions to reduce the problem.  Residents
of the immediate area were evacuated and their homes purchased by the State.
Remedial measures  to  minimize infiltration  of precipitation  through the
site and to  collect and treat leachate were initiated.  The State and EPA
spent millions of  dollars  to mitigate the Love Canal  effects.  Love Canal
and the Niagara County Refuse Disposal site in Wheatfield are under consid-
eration for further cleanup under Superfund financing.

     The preliminary DEC  investigations  at many sites  indicated the  need
for further study including subsurface investigations and groundwater moni-
toring.   DEC has proposed such investigations for 73 priority sites.8  This
study is needed  to identify sites for which remedial  action is needed and
to better define the contributions of chemical substances from these sources.

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 REFERENCES



      &



BIBLIOGRAPHY

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                                                                        201
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   14.   Great Lakes National Program Office, Oct. 1980.  Data Sources for  the
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   16.   Division of Solid Waste  Management,  June 1979.  Industrial Hazardous
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   19.   New York State Department of Environmental Conservation, November  1980.
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   20.   Department of Environmental  Conservation, June 1980.  Trends in Levels
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   23.   Great  Lakes Laboratory,  June 19,  1981.  Niagara  River  Toxics Study,
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   24.   Great  Lakes  Laboratory,  August 21,  1981.  Niagara River Toxics Study,
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   25.   Great  Lakes Laboratory,  November 6, 1981.  Niagara River Toxics  Study,
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                                                                        203
26.   Great Lakes Laboratory, November 18, 1981.   Niagara River Toxics Study,
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28.   The New York Public Interest Research Group,  Inc.,  1981.  The Ravaged
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29.   New York State Department Environmental  Conservation, June 1981.  Toxic
     Substances Control in the Niagara River - A Preliminary Report.   Albany,
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30.   Sept.  14,  1981.   American/Canadian Niagara River Project:   Project
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32.   Ministry of the Environment,  November 16,  1981.   Environmental Base-
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33.   Department of Environmental Conservation, Oct. 1, 1981-Sept. 30, 1982.
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34.   Ministry of the Environment, June 1980.   Environmental Baseline Report
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35.   Ministry of the Environment, November 1981, op. cit.

36.   Department of  Environmental Conservation,  Mar.  20, 1978.  Monthly
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37.   Department of  Environmental Conservation,  Mar.  20, 1979.  Monthly
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38.   Department of Environmental Conservation, June 1980.  Trends in Levels
     of Several Known  Chemical  Contaminants  in  Fish  from New  York State
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   40.  October  1981.   Miscellaneous Tables:   Toxic Substances Monitoring
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   41.  August  1981.   Table:   Results  from Isomer Specific Determination of
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   43.  Undated.  Personal communication.  R. Sloan, New York DEC, Albany,  New
        York.

   44.  Department of  Environmental Conservation, June 1980.  Trends in Levels
        of Several Known  Chemical Contaminants in Fish  from  New York State
        Waters.  New York State, Technical Report 80-2, p.  15.

   45.  Ministry of the Environment, November 1981, op. cit., p. 4.

   46.  Department of  Environmental  Conservation,  June 1980,  op. cit.  p. 52.

   47.  Ministry  of  the Environment, November  1981,  op.  cit.,  Fig. 14  and
        Table 17.

   48.  Ibid, Table  16.

   49.  Department of  Environmental  Conservation,  June 1980,  op. cit., pp.  19
        and 53.

   50.  Ministry of the Environment, June 1980.  Environmental Baseline Report
        of the Niagara River.  Ontario, p. 29.

   51.  Department of  Environmental  Conservation,  June 1980,  op. cit., p. 29.

   52.  ibid., p. 45.

   53.  Ministry of  the Environment, November 1981, op. cit., p. 23.

   54.  Black, John  J., Margaret Holmes, Paul P. Dymerski, William F. Zapisek,
        1980.   Hydrocarbons  and  Halogenated Hydrocarbons in the  Aquatic
        Environment.   Fish  Tumor  Pathology and  Aromatic  Hydrocarbon Pollution
        in a Great Lakes Estuary.  Plenum Press:  New  York, 559 p.

   55.  Ministry of  the Environment, November 1981, op. cit., p. 3.

   56.  International  Joint Commission,  United States and Canada,  April  15,
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   57.  Undated.  New  York Water Quality Standards:   Part  701, Classifications
        and Standards  of Quality and Purity.

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                                                                        205
58.   International  Joint Commission, Canada and the United States, Nov.  22,
     1978.   Great Lakes Water Quality Agreement of 1978.  Ottawa.

59.   May 1950.  Report  of  the Board of Technical  Advisers  to the Inter-
     national Joint Commission  on  the Pollution of International Boundary
     Waters  1948-1949  Investigation.   Niagara  River,   Lake  Erie-Lake
     Ontario Section.

60.   Department of the Environment, Burlington, 1978.   Short-term variation
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61.   October 20, 1981.  Niagara Gazette:  Falls Report Claims Drinking Water
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62.   Ministry of  the  Environment,  November  1981, op.  cit.,  Table 22b.

63.   Ibid,  Tables 21-22.

64.   Ibid,  Table 23.

65.   Ministry of the Environment, June 1980,  op. cit., p. 9.

66.   Environmental  Protection Agency, Region II, Aug.  1981.   Finds and Maps,
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67.   Environmental  Protection Agency,  1976.  National Organics Reconnais-
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68.   The New  York  Public Interest  Research Group,  Inc.,  1981.   The Ravaged
     River:  Toxic Chemicals in the Niagara.   New York, pp 175.

69.   Ibid.

70.   International  Joint Commission, Canada and the United States, Nov.  22,
     1978.   Great Lakes Water Quality Agreement of 1978.  Ottawa.

71.   Ministry of the Environment, November 1981, op.  cit.

72.   Ibid,  p. 4.

73.   Ministry of the Environment, June 1980,  op. cit., Fig.  5 and 6.

74.   Department of  Environmental  Conservation,  1979.   Air Quality Report:
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75.   Armbrust,  Robert A.,  1973.   Coke Oven Pollution and Abatement in New
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76.   National Environmental Research Center,  May 1975.  Ambient Air Measure-
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     Park,  N.C., EPA/650/4-75/020, 19 pp.

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206
   77.  Undated.  Application of 6 NYCRR 212 - Toxic Air Contaminants.  Memo:
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   78.  New York Department  of  Environmental  Conservation, November 6, 1981.
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   79.  Personal communication.   Mr.  Art Fossa,  New York Department of
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   80.  Ontario Ministry of the Environment, September 1973.   Benzo (a) pyrene
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   81.  Stanley, Charles W.,  James E.  Barney II,  Michael R. Helton, and Anne R.
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   82.  Missouri University, 1970.  Determination of the Trace  Element Levels
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   83.  U.S.  Department of Energy, September 1980.   Description of the Formerly
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        p. 18-24, A-6  thru 44.

   84.  Office  of  Environmental  Compliance  and  Overview, September 1980.  A
        Background Report for the Formerly Utilized Manhattan Engineer District/
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        DOE/EV-0097, pp. 117-139.

   85.  Environmental  Protection Agency, Region II, Aug. 1981.  Finds and Maps,
        Data Element Dictionary.  New York,  70 p.

   86.  Environmental  Protection Agency, Region II, September 22, 1981.
        Facility Index System Listing of Facilities in Niagara and Erie
        Counties, New  York.  New York City.

   87.  Environmental  Protection Agency, Region  II.   Selected  Listing of
        Facilities  in  Niagara  and Erie  Counties, New  York.   New York City.

   88.  New  York State Department of Environmental Conservation, November 4,
        1981.   Industrial  Chemical  Survey:   Positive Responders  to Chemicals
        of Concern, Companies Located in Erie and Niagara Counties.  New York.

   89.  Environmental  Protection Agency, Region II, September 23, 1981.
        Computer Listing  of  RCRA Notifiers  in Selected Postal  Zip Codes in
        Western New York.  New York City.

   90.  Environmental  Protection Agency, Region  II.   HWDMS  Master Facility
        Listing:   RCRA Part  A,  Permit Applications  Erie and  Niagara Counties,
        New  York.

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                                                                        207
 91.  Ministry of the Environment, November 1981, op.  cit.,  Table 25.

 92.  Ibid,  Table 28.

 93.  New York State Department of Environmental  Conservation, 1981.
     Investigation of Polycyclic Aromatic  Hydrocarbons in the Vicinity of
     Buffalo,  New  York.   New York:   Third quarterly  report,  Great  Lakes
     Initiative Grant No.  R00556101, 15 p.

 94.  Region II, undated.   Priority  Pollutant Report, Bethlehem Steel  Cor-
     poration, Buffalo, New  York,  NY 0001368, May 6-8, 1981.  Environmen-
     tal Protection Agency, Edison,  N.J.

 95.  May 7, 1981.  RCRA  Treatment,  Storage, and Disposal Facility Form for
     TSD Facilities only,  Bethelehem Steel Corp.,  Environmental  Protection
     Agency, Region II,  Edison, NJ.

 96.  Fred C.  Hart  Associates,  Inc., June 15, 1981.   Hazardous Waste Site
     Investigation, Bethlehem  Steel Corporation,  Lackawanna,  N.Y.,  for
     Environmental Protection  Agency,  Region  II,  N.Y.,  TDD No. 02-8011-16.

 97.  Division of  Solid  Waste,  June  1980.  Hazardous  Waste Disposal Sites
     in New York State,  App.  Vol. 3.  New York State Department of Environ-
     mental Conservation,  p.  C-29-26.

 98.  Division of  Solid Waste,  June 1980,  op. cit.,  pp.  C-9-33  and  38.

 99.  SRI International, 1981.  Directory of Chemical Producers.  Menlo Park,
     Calif., 1120 p.

100.  Division of  Solid Waste,  June 1980,  op. cit.,  pp.  B-9-41  and  42.

101.  Region II,  September 1981.  Niagara  River  Toxic Monitoring Report,
     Buffalo  Color Corporation,  Buffalo,  New  York, May  7,  1981,  NY
     0002470.   Environmental  Protection Agency.   Edison, N.J.

102.  Division of Solid Waste, June 1980,  op.  cit., pp. B-9-51 to 56.

103.  Black, John J., Margaret Holmes, Paul P. Dymerski, William F. Zapisek,
     1980.   Hydrocarbons and Halogenated Hydrocarbons in the Aquatic
     Environment.   Fish Tumor Pathology and Aromatic Hydrocarbon Pollution.

104.  Region II, undated.   Compliance Monitoring  Report, Donner-Hanna Coke,
     Buffalo,  New  York, NY 0003310, May 4-5, 1981.  Edison,  N.J. Environ-
     mental Protection Agency.

105.  June 1,  1981  letter  from Mr.   Kevin D.  Mahar, Environmental Control
     Manager  to the  New York Dept.  of Environmental Conservation, Albany,
     New York.

106.  Division of  Solid  Waste,  June 1980,  op. cit.,  pp.  B-9-63  and  64.

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208
   107. Region II, September 1981.  Priority Pollutant Report,  Republic  Steel
        Corporation,  Buffalo, New  York,  May 4-5, 1981,  NY 0001881.  Environ-
        mental Protection Agency, Edison, N.J.

   108. June  30,  1980  letter  from Mr. J.M. Potivora, Supt.  of  Environmental
        Control to the New York Dept.  of Environmental Conservation.

   109. Region II, undated.  Compliance  Monitoring Report, Buffalo Sewer Au-
        thority,  Bird  Island Wastewater  Treatment Plant, Buffalo,  New York,
        NY 0028410, May  4-5, 1981.  Environmental  Protection Agency.  Edison,
        N.J.

   110. U.S.   Army Engineer  District,  February  16, 1973.   Final Environmental
        Statement:  Diked  Disposal Area  - Buffalo River,  Buffalo Harbor,
        Black Rock Channel,  Tonawanda Harbor,  Erie County, New York.
        Buffalo,  New York.

   111. State University of New York College at Buffalo,  December 1975.
        Buffalo  Harbor Diked Disposal  Sites:   Engineering  Properties  and
        Drainage Characteristics.  Buffalo:  12 pp.

   112. U.S.  Army Engineer District, October 1974.  Final Environmental
        Statement:  Black Rock Channel and Tonawanda Harbor, New York
        (Operation and Maintenance).  Buffalo,  New York,  Table 9.

   113. Great  Lakes  Laboratory,  October 1981.   Analysis  of Sediment,  Water
        and Elutriate  Water Collected and Processed from Buffalo Harbor, New
        York  Sampling  Sites.   State University College at Buffalo, New York,
        pp. 24-26.

   114. Region II, August 1978.   Priority Pollutants Monitoring Report, Dunlop
        Tire  and  Rubber  Corp.,  Buffalo,  New York, NY 0101575, January 24-25,
        1978, March 14-15,  1978.   Environmental  Protection Agency.  Edison,
        N.J.

   115. Division  of  Solid Waste,  Junr 1980,  op.  cit.,  pp. B-9-65 to 68,
        C-9-31 and 32.

   116. Region  II, undated.   Compliance  Monitoring Report,  FMC  Corporation,
        Tonawanda, New York, NY  0000337,  November 19-20,  1980.   Environmental
        Protection Agency.   Edison, N.J.

   117. Dec.   17,  1980.  RCRA TSD  Facility  Inspection Checklist, FMC Corp.,
        Tondawanda  Facility,  Environmental  Protection Agency,  Region  II,
        Edison, NJ.

   118. Division  of  Solid  Waste,  June 1980, op.  cit.,  pp.  B-9-79 and  80.

   119. May 7,  1981.  RCRA Treatment,  Storage and  Disposal  Facility Inspection
        Form  for  TSD Facilities only, Allied Corp., Allied  Fibers  and Plastics
        Co.,  Environmental  Protection Agency,  Region  II, Edison, NJ.

   120. Division  of Solid Waste, June 1980, op. cit., pp. B-9-35 to 40.

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                                                                        209
121.  Ibid, pp.  B-9-129 to 134.

122.  Task Force on Toxic Substances, January 29, 1981.  The Federal Connec-
     tion:  A History of U.S. Military  Involvement  in the  Toxic  Contamina-
     tion of Love  Canal  and the Niagara  Frontier Region,  Vol.  I  and  II.
     New York State Assembly.

123.  December 1981, Press Release, U.S.  Dept. of Engergy

124.  Division of  Solid  Waste,  June 1980, op. cit.,  pp.  B-9-47 and 48,
     C-9-21 and 24.

125.  ibid, pp.  B-119 to 124, C-9-45 and 46.

126.  iMd, pp.  B-9-61 and 62.

127.  Ibid, pp.  B-9-231 and 232,  371 and 372.

128.  Region II, undated.   Compliance  Monitoring Report, Town of Tonawanda
     WWTP #2,  Two Mile  Creek Road,  Tonawanda,  New  York,  NY 0026395,
     May 6-7, 1981.  Environmental Protection Agency.  Edison, N.J.

129.  Region  II,  August  1981.  Compliance  Monitoring Report,  North Tona-
     wanda  Wastewater  Treatment  Plant,  North Tonawanda,  New York,  NY
     0026280, May  4-5,  1981.   Environmental  Protection Agency.  Edison,
     N.J.

130.  Division of  Solid  Waste, June 1980,  op. cit.,  pp.  C-9-145 and 146.

131.  ibid, pp.  B-9-233 to 248.

132.  JMd, pp.  B-9-215 to 226.

133.  Dec. 17, 1980.  RCRA  TSD Facility  Inspection Checklist,  Olin Chemical
     Corp., Environmental Protection Agency, Region  II, Edison, NJ.

134.  Division of  Solid  Waste, June 1980,  op. cit.,  pp. B-9-273  to  276.

135.  January 16,  1980 letter from Olin to New York  Dept.  of Environmental
     Conservation, Buffalo, New York.

136.  Division of  Solid  Waste, June 1980,  op. cit.,  pp.  B-9-287 and 288,
     C-9-143 and 144.

137.  ibid.

138.  ibid, pp.  B-9-229 and 230.

139.  ibid, pp.  B-9-201 and 202.

140.  ibid, pp.  B-9-277 and 278.

141.  ibid, pp.  C-9-109 and 110.

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210
   142. Ibid, pp. B-9-259 and 260.

   143. iMd, pp. C-9-131 and 132.

   144. Region II,  undated.   Compliance  Monitoring  Report,  CECOS,  Inc.,
        May 5, 1981.  Environmental Protection Agency, Edison, NJ.

   145. Dec.  16,  1980.   RCRA  TSD Facility  Inspection Checklist,  Frontier
        Chemical,   Environmental  Protection Agency,  Region II,  Edison,  NJ.

   146. SCA  Chemical  Services,  Operating Report  for  the  SCA Chemical Waste
        Services, Inc., Model City, New York Facility, February 1979.

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                                                                        211
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                                                                        213
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214
   Industrial Source Information
   Fred C. Hart Associates, Inc., June 27, 1980.   Hazardous Waste Site Inves-
        tigation, S.K.W. Alloys, Inc., Niagara, N.Y.,  for Environmental Pro-
        tection Agency, Region II, N.Y.

   Hooker Chemicals & Plastics Corporation, March 1979.   Chlorocarbon Source
        Investigation Program, Niagara Plant.   Niagara Falls, N.Y.,  150 p.

   Hooker Chemicals and Plastics Corporation,  September 22, 1980.  Volume I -
        Executive Summary, Report on Wastewater Outfall  Sewers, Niagara Plant
        Comprehensive Water Management Study.   Niagara Falls, N.Y.,  41 p.

   Hooker Chemicals & Plastics Corporation, September 22, 1980.  Volume II -
        Field Investigation, Report on Wastewater Outfall Sewers, Niagara
        Plant Comprehensive Water Management Study.   Niagara Falls,  N.Y. ,
        150 p.

   Hooker Chemicals & Plastics Corporation, September 22, 1980.  Vol. Ill -
        Plates:  Report on Wastewater Outfall  Sewers,  Niagara Plant Comprehen-
        sive Water Management Study.  Niagara Falls,  N.Y., 25 p.

   Hooker Chemicals & Plastics Corporation, September 19, 1980.  Vol. IV -
        Chemical Loadings and Groundwater Quality:  Niagara Plant Comprehen-
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   New York Department of Environmental Conservation, undated.  Compliance
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        # NY  0002470, February 26-27, 1980.  Buffalo, N.Y.

   New York Department of Environmental Conservation, undated.  Compliance
        Monitoring Report, Dresser Industries, Inc., Depew, New York, May 15-16,
        1978.  Buffalo, N.Y.

   New York Department of Environmental Conservation, undated.  Compliance
        Monitoring Report, Hanna Furnace Corporation, Subsidiary of  National
        Steel Corporation, Buffalo, New York, NPDES Permit # NY 0001597,
        December 3, 15,9.  Bo. ."aio, N.Y.

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                                                                        215
New York Department of Environmental Conservation, September 1980.   Compli-
     ance Monitoring Report, Hooker Chemicals and Plastics Corp., Durez
     Division, North Tonawanda, New York, # NY 0001198, May 13-14,  1980.
     Buffalo, N.Y.

New York Department of Environmental Conservation, June 1981.   Compliance
     Monitoring Report, Westinghouse Electric Corp. ,  Cheektowaga, New York,
     SPDES Permit # NY 0001210, December 16-17, 1980.  Buffalo, N.Y.

Region II, undated.  Compliance Monitoring Report, Allied Chemical  Corp.,
     Buffalo, New York, NY 0002160, November 17-18,  1980.  Edison,  N.J.

Region II, undated.  Compliance Monitoring Report, Buffalo Color Corp.,
     Buffalo, New York, NY 0002470, November 17-18,  1980.  Environmental
     Protection Agency, Edison, N.J.

Region II, undated.  Compliance Monitoring Report, The Carborundum Company,
     Niagara Falls, New York, NY 0001376, November 19-20, 1980.  Environ-
     mental Protection Agency.  Edison, N.J.

Region II, June 1978.  Compliance Monitoring Report,  Dun!op Tire and Rubber
     Corporation, Buffalo, New York 14240, NY 0101575, January 24-25, 1978.
     Environmental  Protection Agency, Rochester, N.Y.

Region II, January 1979.  Compliance Monitoring Report, E.I. DuPont de
     Nemours and Co., Inc., Niagara Falls, New York.   August 2-3, 1978,
     NY 0003328.  Environmental Protection Agency, Rochester, N.Y.

Region II, May 1981.  Compliance Monitoring Report,  E.I. DuPont de Nemours
     and Co., Inc., Niagara Falls, New York,  NY 0003328, November 17-18,
     1980.  Environmental Protection Agency,  Edison,  N.J.

Region II, undated.  Compliance Monitoring Report, General Motors Corpora-
     tion, Tonawanda, New York, NY 0000574, November 17-18, 1980.  Environ-
     mental Protection Agency.  Edison, N.J.

Region II, September 1981.  Compliance Monitoring Report, Hooker Chemical
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Region II, February 1979.  Compliance Monitoring Report, Hooker Chemical
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     N.Y. 0003336,  September 13-14, 1978.   Environmental Protection Agency,
     Rochester, N.Y.

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     Tonawanda, New Jersey, (sic, N.Y.) NY 0002399,  November 17-18, 1980.
     Environmental  Protection Agency.  Edison, N.J.

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216
   Region II, February 1981.   Compliance Monitoring Report, Union Carbide
        Corp., Niagara, New York, NY 0000060, November 19-20, 1980.  Environ-
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                                                                        217
New York State Departments of Environmental Conservation and Health, May
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218
   Great Lakes Laboratory, 1980.  Water Quality and Bethlehem Steel Corporation.
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        Modeling and Simulation, April 19-22, 1976.  Waste Allocations in the
        Buffalo (New York) River Basin.  Cincinnati, p 126-128.

   Shaver, C. G. , J.A.C. Fortescue, P. A. Peach, S. A. Curtis, June 1977.
        Stream Sediment Geochemical Anomalies in Relation to Industrial En-
        vironmental Pollution and Geoepidemiology in the Niagara Peninsula.
        Columbia.

   October 11, 1981.  Sixty Minutes:  Don't Go Near the Water.  Mike Wallace,
        CBS Television Network.

   Sweeney, R.A. , 1973.  Water for the Human Environment, Vol. IV. Rejuvena-
        tion of the Buffalo River.  Chicago:  International Water  Resources
        Association, p 445-455.

   March 1980.  The Invisible Menace:  Contaminants in the Great Lakes.  WIS-
        SG-80-133, 58 p.

   U.S. Geological Survey, 1968.  A Reconnaissance of Stream Sediment  in
        the Erie-Niagara Basin, New York.  State of New York Conservation
        Department, Basin  Planning Report ENB-5, 33 p.

   U.S. Geological Survey, 1968.  Chemical Quality of Streams  in the Erie-
        Niagara Basin, New York.  State of New York Conservation Department,
        Basin Planning Report ENB-4, 104 p.

-------
                                                                        219
Water Supply
Carlo, George L. and Curtis J. Mettlin, May 1980.  American Journal of Pub-
     lic Health.  Cancer Incidence and Trihalomethane Concentrations in a
     Public Drinking Water System.  Buffalo.

Westerhoff, G. P.,  June 1971.   Journal of American Water Works Association,
     Vol. 63, No. 6.  Experience with Higher Filtration Rates.  New York,
     p 376-386.

-------
                 APPENDIX
     Selected Water Quality Objectives
  From the International  Joint Commission
Great Lakes Water Quality Agreement of 1978

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The concentration of tot
unfiltered water sample
microgram per litre to \
Chromium

14
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01
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10 Qj QJ
com
--1 x 3
P * *
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3 JJ 10
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o o
rH X; U
The concentration of tot
unfiltered water sample
micrograms per litre to
public water supplies.
Copper


41
in 1*4
T3 rH
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c a «i
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0 0
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10 10 Q.
The concentration of tot
unfiltered water sample
micrograms per litre to
Iron
•0
41
01 «
JJ 6
rH AI
•rH 14
144 O'-
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10 B
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C -rt
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The concentration of tot
water sample should not
per litre to protect aqu
Lead
TJ -4 rH
41 01 41 rH
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41 JJ 41
JJ W .rl C "*4
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144 V4 14 4t
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rH X 0 O (Ji
10 41 CM U
The concentration of tot
water sample should not
litre in Lake Superior,
in Lake Huron and 25 mic
remaining Great Lakes to
Mercury
TJ u
01 41 4t
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01 01 -n
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10 41 O O JJ '
The concentration of tot
water sample should not
litre nor should the con
mercury in whole fish ex
gram (wet weight basis)
and fish-consuming birds
Nickel


in 41
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The concentration of tot
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micrograms per litre to
Selenium


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40 01 01
41 4J

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The concentration of tot
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Zinc

ss.
41
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4J —
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of lindane in edib
exceed 0.3 microgr,
for the protection
Methoxychlor




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The concentration i
should not exceed I
the protection of i
Mirex



10
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10 <0 rH 10 E B 10
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For the protection
fish-consuming bin
degradation produc
absent from water
Sustantially absen:
detection levels a:
scientific methodo
Toxaphene


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The concentration •
not exceed 0.008 n
protection of aqua
Other Compounds
Phthalic Acid Este
JC M U O O 41
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The concentration
di(2-ethylhexyl) p
exceed 4.0 microgr
microgram per litr
protection of aqua
esters should not
in waters for the
Polychlorinated Bi
uaiuiO3 at ujjjjo)
r-4OIO C IOjOjjO34JrOJ3
&£. 5 B O m
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The concentration
biphenyls in fish
calculated on a we
exceed 0.1 microgr
of birds and anima
Unspecified Organi
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The concentrations
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micrograms per lit
public water suppl



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SURVEILLANCE AND MONITORING
Surveillance and monitoring activities shall be
for the following purposes:
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Corrpliance. To assess the degree to which
jurisdictional control requirements are being met.


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Achievement of General and Specific Objectives. To
provide definitive information on the location,
severity, areal or volume extent, frequency and
duration of non-achievement of the Objectives, as a
basis for determining the need for more stringent
control requirements.


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Evaluation of Water Quality Trends. To provide
information for measuring local and whole lake respo
to control measures using trend analyses and
cause/effect relationships, and to provide Informati
which will assist in the development and application
predictive techniques for assessing impact of new
developments and pollution sources. The results of
water quality evaluations will be used for;


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A joint surveillance and monitoring program necessai
the attainment of the foregoing purposes shall be
and implemented among the Parties and the State and
1 Governments. The Great Lakes International
nee Plan contained in the Water Quality Board Annual
1975 and revised in subsequent reports shall serve <
the development of the joint surveillance and ,
g program.
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The program shall include baseline data collection,
alysis, evaluation and quality assurance programs
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essments of the following:
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Inputs from tributaries, point source discharges,
otmonphere, and connecting channels;


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Khole lake data including that for nearshore areas
(such as harbours and embay^er.ts, general shoreline
cladophora growth areas), open waters of the Lakes,
fish contaminants, and wildlife contaminants; and

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U.S. Efwlronmcntal Protection Agwqr
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