EPA/AMD/R02-95/246
                          September 1995
EPA  Superfund
       Record of Decision Amendment:
       Hooker (102nd Street)
       Niagara Falls, NY
       6/9/95

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    RECORD OF DECISION AMENDMENT




           102nd STREET LANDFILL



          NIAGARA FALLS, NEW YORK
UNITED STATES  ENVIRONMENTAL PROTECTION AGENCY




                REGION II




            NEW YORK, NEW YORK

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                      DECLARATION STATEMENT
                   RECORD OF DECISION AMENDMENT
SITE NAME AND LOCATION

102nd Street Landfill
Niagara Falls, New York


STATEMENT OF BASIS AND PURPOSE

This decision document  presents the selected modification to the
original remedial action  for  the 102nd Street .Landfill Site  (the
"Site"), located in Niagara Falls, New York.  The original remedial
action was selected in the Record of Decision  (ROD) issued by the
United States Environmental Protection Agency  (EPA) on September
26, 1990.

The modification to the  original remedy was chosen in accordance
with the requirements  of the Comprehensive  Environmental Response,
Compensation, and Liability Act  of 1980  (CERCLA) , as amended by the
Superfund Amendments  and  Reauthorization Act of 1986 (SARA) ,. and
the National  Oil and Hazardous Substances Pollution Contingency
Plan (NCP).   This decision document  explains the factual and legal
basis for selecting the modification to the remedy  for the Site.

The  New  York  State   Department of   Environmental  Conservation
(NYSDEC) concurs with the selected modification.   A  letter of
concurrence from the NYSDEC is attached to  this  document (Appendix
!)•

The  information  supporting  this  remedial  action  decision  is
contained in the administrative  record  for the Site. The index for
the administrative record is  attached  to this document (Appendix
2).
ASSESSMENT OF THE SITE

Actual or  threatened releases  of  hazardous  substances  from the
Site,  if  not  addressed  by  implementing  the response  actions
selected in the September 26, 1990 ROD, as revised by this Record
of Decision  Amendment,  may  present  an imminent  and substantial
threat to the public health, welfare, or the environment.

DESCRIPTION OF MODIFICATION TO THE SELECTED REMEDY

The  modification  to the  selected  remedy  addresses  the  river
sediments  within  the  shallow  embayment  of  the Niagara  River
adjacent to the Site.

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The major  components  of the modification to  the selected remedy
include:

     Dredging the Niagara  River sediments to the  "clean line" with
     respect to Site-related contamination.  These sediments, after
     dewatering, will NOT  be  incinerated, but will be consolidated
     on the landfill.   Any NAPL found within theses sediments will
     be extracted, and will be incinerated at an off-site facility.

All of the other components of the original remedy as selected in
the September  1990 ROD are  NOT  affected  by this  modification.
These components are:

     Capping of the Site
     A synthetic-lined  cap,  constructed in accordance  with
     federal and state standards,  will be installed over the
     landfill and perimeter soils.

     Consolidation of Soils
     All off-site  soils above cleanup  thresholds,  will  be
     consolidated beneath  the cap.

     Erection of a Slurry  Wall
     A slurry wall, completely surrounding the Site's perime-
     ter,  will be constructed and keyed  into  the underlying
     clay/till  geologic formation.  The precise  location  of
     the slurry wall will be based  upon data from geotechnical
     borings which have determined the  extent  of the  NAPL
     plume(s).   The NAPL  plume(s)  will  be contained  by  the
     slurry wall.

     Recovery and Treatment of Ground  Water
     Ground water  will be recovered  using an  interception
     drain  installed  at the seasonal low-water table  in  the
     fill materials.   Recovered ground water will be treated.
     Although the  recovery  of ground water  does include  a
     treatment  component, the primary function of ground-water
     recovery in general,  is to create and maintain an inward
     gradient across  the slurry wall.

     Recovery and Treatment of NAPL
     NAPL beneath the  Site will be recovered using dedicated
     extraction wells,  and will be incinerated at an  off-site
     facility.

     Storm  Sewer
    The existing storm sewer,  which  crosses the Site, will be
     cut into pieces.   The pieces  will be  filled  with  grout,
     and  left in place  on  the  Site.   These remnants  of  the
     existing storm sewer  will then  be covered with  fill  and
     eventually will be covered by the cap.

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      (Note:  The September 1990 ROD called for the slip-lining of
      the on-site storm sewer.   In 1993, the EPA decided to re-route
      the storm sewer around the Site to the east rather than slip-
      lining it in place.  This decision was embodied in an Explana-
      tion  of  Significant Differences  (ESD) issued  by  the EPA in
      1993.)

      Monitoring
      Post-remedial monitoring shall be performed to determine
      the effectiveness of the remedial alternatives which have
      been  selected.

      Restriction of Access
      A 6-foot high chain-link fence will be installed around
      the perimeter of the cap in order  co restrict access to
      the Site.

      Institutional Controls
      The EPA will  recommend  to local agencies that institutional
      controls be undertaken to ensure tnat future land use at the
      Site  is restricted so as to preclude certain uses of the Site,
      such  as restricting certain  types of  access to the Landfill
      and eliminating groundwater use for human consumption at the
      Site.
EXPLANATION OF FUNDAMENTAL CHANGE

The September  1990  ROD called for  dredging  and incinerating any
highly contaminated embayment sediments if they were left outside
the final positioning of the slurry wall.  Any sediments with lower
levels of contamination [that are still in excess of action levels]
which would remain  outside the  slurry  wall,  would be dredged and
placed beneath the  cap.   The  preliminary  remedial design had the
slurry wall positioned in a  straight-line direction, outside the
two areas of highly  contaminated sediments.  Due to concerns raised
by the natural resource trustees  about the area of the embayment
that  would be  filled  in by  constructing  the  slurry  wall  as
currently  designed,  the  EPA  decided  to  evaluate modifying  the
design to move the  slurry wall  closer  to  the shoreline.   The net
effect of this re-design would be to "save" approximately three (3)
acres  of the  embayment.   As part  of this  evaluation,  it  was
determined that if the slurry  wall  was  moved  and the sediments had
to be  incinerated,  the costs  had  risen  such that  the  original
remedy was no longer cost effective.

Therefore, as described in this Record of Decision Amendment,  all
of the contaminated sediments in  excess of action levels will be
dredged and placed  beneath the  cap,  rather than incinerating the
highly contaminated sediments.

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DECLARATION OF STATUTORY DETERMINATIONS

The original remedy,  as  revised by the selected modification, is
protective  of  human  health and  the environment,  complies with
federal  and  state requirements  that are  legally  applicable,  or
relevant  and  appropriate to the  remedial actions,  and is cost-
effective.  This modified remedy utilizes permanent  solutions and
alternative treatment technologies to the maximum extent practica-
ble for  the Site.   However,  because treatment of the principal
threats of the Site  was  not found to be practicable, this remedy
does  not satisfy  the statutory  preference  for  treatment  as  a
principal element.   Because the  selected remedy  will  result in
hazardous substances remaining on-site above health-based levels,
a review will be  conducted within  five years after  commencement of
the remedial action to ensure that the selected remedy continues to
provide adequate protection of human health and the  environment.
Jeanne M. Fox
Regional AdjjKfnistrato

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                        TABLE OF CONTENTS

                                                             Page
DECISION SUMMARY	  1

I. -       Introduction	  1

II.-      Highlights of Community Participation	  2

III.-     Reasons for Issuing Record of Decision Amendment....  3

IV. -      Description of Alternatives	 .  5

V.-       Evaluation of Alternatives	  7

VI.-      Selected Remedy	 11

VII.-     Statutory Determinations	 11



APPENDICES:

1.-  Concurrence Letter from the NYSDEC	

2.-  Index for the Administrative Record	

3.-  Responsiveness Summary	

     1. -  Overview	  1

     2.-  Background on Community Involvement
          and Concerns	  1

     3.-  Summary of Questions and Comments Received
          During the Public Meeting and the Responses
          of the EPA	  2

     4.-  Summary of Written Comments Received During
          the Public Comment Period and the Responses
        .  of the EPA	  5
4.-  1990 Record of Decision.

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                         DECISION SUMMARY
                   RECORD OF DECISION AMENDMENT
                    102nd Street Landfill Site
                    Niagara Falls/ New York
I.- INTRODUCTION
The  102nd  Street Landfill Site  (the  "Site"),  presently owned by
Occidental Chemical Corporation  (OCC), and Olin Chemicals  (Olin),
is a 22.1 acre landfill on the eastern edge of  the  City  of  Niagara
Falls  (the  "City")  and borders  the  Niagara  River (the  "River").
OCC, formerly Hooker Chemicals and Plastics Corporation, operated
its  15.6 acre portion of the  Site as  an industrial waste landfill
from approximately 1943 to 1970.  Olin operated its 6.5  acre por-
tion of the Site as an industrial waste landfill from 1948 to 1970.
During these periods, OCC and Olin (the "Companies") deposited at
least 159,000 tons of waste,  in both liquid  and solid form, into
the  landfill.  This included  approximately 4,600 tons of benzene,
chlorobenzene, chlorophenols  and hexachlorocy-.lohexanes  (HCCHs) .

On  December  20,  1979,  a complaint,  pursuant  to the Resource
Conservation and Recovery Act (RCRA),  the Clean Water Act  (CWA),
and the Rivers and Harbors Act of 1899 (RHA),  was filed against the
Companies in the U.S.  District Court  in Buffalo, New York,  seeking
injunctive relief and civil penalties for  an  imminent and substan-
tial endangerment to the public health and welfare.  The Site was
formally,  listed as  a  National Priorities  List  (NPL) site  on
September 8, 1983.

The  EPA  and the Companies prepared  a Work Plan for  the Site in
1984, and thereafter the Companies commenced the Remedial Investi-
gation  (RI) ,  a  study  of the  nature  and  extent of contamination.
The Feasibility Study (FS) Work Plan, as defined in a Stipulation
and Decree entered with the U.S. District Court in Buffalo on May
15, 1989, was prepared by the EPA and the NYSDEC and agreed to by
the Companies.  The Work Plan provided the guidance  under which the
Companies conducted the  FS; the FS report describes  the development
and evaluation of all of  the  remedial alternatives for the Site.
Throughout the  RI/FS  process, the EPA, in consultation with the
NYSDEC, reviewed all of the interim documentation and monitored the
collection and analysis of samples from the Site.

The  Site  is bounded to the south  by a shallow  embayment  of the
River.   A stone-faced bulkhead, constructed in the early 1970s to
minimize soil erosion to the  River,  runs  along the length of the
shoreline at the Site.  The embayment lies at the upstream end of
the  Little  Niagara  River which  flows around the  north shore of
Cayuga Island before discharging into the River approximately 1.5
miles downstream from  the Site.  To the west of  the  Site  is Griffon
Park, which was formerly used  as a landfill for municipal waste by
the City.  A number of recreational facilities formerly existed at

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the park,  including  a  baseball  diamond and a boat ramp.   Only the
boat ramp remains functional.  Griffon Park is bordered on the west
by the  Little Niagara  River.   Across the Little Niagara  River  is
Cayuga  Island, which is  a  residential community.  The  property  to
the east  of the Site  (the "Belden Site")  is zoned  "residential"
with one current residence, but is otherwise  an unimproved densely
brushed field.   A drainage ditch runs  through  the Belden  Site,
parallel to the eastern edge of  the 102nd Street Site, and into the
River.

The  100th  Street  storm sewer  presently  crosses  the  Site and
discharges  to the  River.  Ground water was observed and  measured
infiltrating  the storm  sewer both during  the RI  and in earlier
investigations.  The storm sewer carries runoff from the Love  Canal
area and  drains  Buffalo Avenue  in the  immediate vicinity of the
Site.

In September  1990, the EPA issued  a Record of Decision  (the  "ROD"
or the  "September 1990  ROD")   which  selected,  as  a remedy, the
capping of the  landfill,  the   construction  of  a circumferential
slurry  wall  to  encapsulate  the  landfill   (and  any  NAPL   plume
migrating  from the  landfill),  the installation  of ground-water
controls to eliminate contaminant  migration from the encapsulated.
landfill,  the slip-lining  of  the on-site  storm sewer,  and the
dredging of contaminated sediments from the adjacent embayment  in
the River.  In 1993, the EPA  decided to re-route the storm  sewer
around the Site rather  than slip-lining it in place.   This  decision
was embodied  in  an Explanation  of Significant  Differences  (ESD)
issued  by the EPA in 1993.

The ROD also  called  for  dredging and  incinerating  any highly
contaminated embayment sediments if they were left outside of the
final positioning of the slurry  wall.  Sediments with lower levels
of contaminants which would remain outside the slurry wall,  would
be dredged and placed beneath the  cap.

As  described  in   this  Record  of  Decision   Amendment  (the
"Amendment") ,   the  EPA  will be  dredging all of  the contaminated
sediments out  to  a "clean line" where contaminants in the sediments
no longer  exceed action  levels  developed to  assure protection  of
the aquatic environment and will be placing such sediments beneath
the cap,  rather  than incinerating the  highly  contaminated  sedi-
ments .

JJ.- HIGHLIGHTS OF COMMUNITY PARTICIPATION

The Post-Decision Proposed Plan  (PDPP) for the Site was released  to
the public in  early December 1994.  The PDPP, along with all  other
site-related  documents,  are available to the public at both the
administrative record and the information repository  locations.  A
summary of the PDPP  and  a  notice as  to  the availability of  these
documents  and the  administrative record  was  published in The
Niagara Gazette on Friday, December 2, 1994.

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The public comment period began on December 2, 1994, and ended on
January 25, 1995.  A public meeting was held on December 14,  1994
at  the Red Jacket Inn  located in Niagara Falls,  New  York.   The
purpose of the public meeting was to discuss the proposed amendment
to the September 1990 ROD.

The responses  to the  comments  received during the public comment
period as well as those expressed verbally at the public meeting,
are stated in the Responsiveness Summary, which is an attachment to
this Record of Decision Amendment.

This decision document, meaning the Record of Decision Amendment,
presents the  selected  remedial action for the disposition of the
contaminated sediments found in the embayment adjacent to the Site,
chosen in accordance with CERCLA  as  amended  by  SARA,  and,  to the
extent practicable, the NCP,  40 CFR Part 300.   The 'decision as made
for the Site,  is based upon the administrative  record.   An index
for the administrative record is included  as an attachment to this
document.  This Record of Decision Amendment will become a part of
the administrative record file.

The administrative  record file,  containing the  information upon
which  the  modification  to  the  original  remedy  is  bas.ed,  is
available at the following locations:

               U.S.  Environmental  Protection Agency
                 290  Broadway  - Records Center
                  New York,  New York 10007-1866
                          212-637-3000         .            .
          Hours: Monday -  Friday:  9:00 a.m. to 4:30 p.m.

               U.S. EPA Public Information Office
                 Carborundum Center  - Suite 530
                         345  Third Street
                  Niagara Falls, New York 14303
                          716-285-8842
          Hours: Monday -  Friday:  9:00 a.m. to 4:30 p.m.

III.- REASONS FOR ISSUING THE RECORD OF DECISION AMENDMENT

After the September 1990 ROD was signed, the EPA commenced negotia-
tions  with  the Companies for  their  undertaking of  the  remedial
design and remedial action phases of  the  project.   When negotia-
tions  failed,  in  September 1991,  the EPA  issued a  Unilateral
Administrative Order for implementation of the  remedy.  The remedi-
al design began  in 1991 and was  at  the  65% completion  stage in
August 1993.  With  the 1993  design, the slurry wall was positioned
outside  the  two areas of  highly contaminated  sediments.    The
decision to place the  slurry wall  outside  these areas was based on
several factors: the technical practicalities of a straight-line
design;  the  fact  that  incineration  which   was  the  source  of
considerable concern to the  community  would not be required with a
straight-line design;  and an anticipated savings of the projected

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 cost  in incineration,  which in 1990 dollars, was estimated to be
 approximately  $2  million.   It should be noted that the  straight-
 line  design  of the  slurry wall would have impacted 6 acres of the
 embayment.

 In August 1993, the  natural resource trustees raised concerns about
 the area of  the embayment that would be filled in by constructing
 the  slurry wall  as currently designed.   These concerns  of the
 natural resource  trustees were based upon the prospective loss of
 irreplaceable  habitat  as  found  in the  embayment.  Based on these
 concerns, the EPA decided to evaluate modifying the design to move
 the slurry wall closer to the shoreline.

 The Companies agreed to conduct a supplemental borings program in
 order  to  determine if  the NAPL  plumes had  extended  past the
 shoreline.  It should be noted that the primary aim of the selected
 remedy  is  to contain the NAPL plumes  within the slurry wall and
 thereby prevent further migration of the NAPL.

 The results of the supplemental  borings program indicated that the
 NAPL did not extend  beyond the shoreline.  This meant then that the
 slurry  wall  could be designed  to run  along the contours  of the
 shoreline.   The  net effect of this  re-design would  be to "save"
 approximately three  (3) acres of the embayment,  while at the same
 time  requiring the excavation  and incineration  of  the  highly
 contaminated sediments since they now would .be outside the slurry
 wall.

 Under the original remedy, the realignment of the  slurry wall would
 require incineration of sediments at an approximate fifteen fold
 increase over the costs projected  in 1990.  The increase in cost is
 due to the following factors:

 1.  The original cost estimate in  1990  to incinerate 6,440 tons of
 highly  contaminated sediments came to  approximately  $2 million.
 This figure was based on a unit cost of  $200 to $300 per ton.  This
 assumes an excavation depth of two  (2)  feet in order to arrive at
 6,440 tons (4,600 cubic yards).

 2.  The anticipated cost of  $2  million also was  projected on the
 basis of incremental operational costs  for the solids incinerator
which OCC is  obligated to build at its Buffalo Avenue Niagara Falls
 facility pursuant to the requirements of the  Partial Consent Decree
 entered in U.S. District Court for the Love Canal  Landfill, as well
 as pursuant to similar requirements  for  the S-Area  Landfill.   It
was anticipated that this OCC solids incinerator would also have
 been available for  the treatment  of any sediments  from the 102nd
 Street Site that would have required incineration pursuant to the
 September 1990 ROD.

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3.   At the present  time,  the schedule for  construction of this
incinerator has  been suspended,  upon notice to  the  Court,  by an
informal agreement of the parties to these Consent Decrees pending
efforts by OCC to secure approval of incineration of  its wastes at
a facility in the State of Utah.  The incineration facility in Utah
has  been  constructed  but  has  not yet  been  fully tested  and
permitted  for commercial operation.   Once  it  is permitted  for
commercial operation,  it must still receive special permits and
approvals for incineration of the remedial wastes such as dioxin-
contaminated sediments.

4.  At the present time, if incineration of the highly contaminated
sediments were a  requirement,  it would be  necessary  to truck the
sediments  to  the only facility  in  the United  States  currently
permitted  for the incineration  of  these types  of waste.   This
facility is  located  in the  Midwest.   The cost  for  incineration
alone  at this facility would be $4,000  per  ton.  This  does not
include transport costs or  preparation expenses.  At  $4,000 per
ton, the incineration  costs  alone would approximate  $26 million.
The total costs including preparation and transport are projected
to approximate $30 million.

Due to the  change  in costs, incineration of the highly contaminated
sediments is  no longer  considered to  be  cost-effective.  Therefore,
the EPA  decided  that  the September  1990  ROD must be  amended to
eliminate the incineration contingency.
IV.- DESCRIPTION OF ALTERNATIVES

The  Comprehensive   Environmental   Response,   Compensation,   and
Liability  Act  (CERCLA)  requires  that  each  selected remedy  be
protective of human health and the  environment, be cost-effective,
comply with other statutory laws, and utilize permanent solutions
and  alternative  treatment technologies  and  resource  recovery
alternatives to the maximum extent practicable.  In addition, the
statute includes a preference  for treatment as a principal element
for the reduction of toxicity, mobility,  or volume of the hazardous
substances.

The costs  presented below  for  each alternative include  capital
costs and operation and maintenance (0 & M)  costs over a ten-year
period.

ALTERNATIVE I.-  EXISTING REMEDY  AS SELECTED IN THE SEPTEMBER 1990
RECORD OF DECISION (AS MODIFIED BY THE 1993  ESP):

Capping/  Consolidation  of Soils/  Erection  of  a  Slurry  Wall/
Recovery and Treatment of Ground Water/  Recovery and Treatment of
NAPL/ Embayment Sediments  (Incineration Contingency)/ Re-Routing of
Storm  Sewer/   Post-Remedial  Monitoring/  Restriction  of  Access/
Institutional Controls

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This  alternative,  which is defined as the selected remedy  in  the
September  1990  ROD,  consists  of  a  containment system  for  the
landfill, and in the case of the embayment sediments,  incineration
of  the highly contaminated  sediments  if  they remain outside  the
final  positioning  of the slurry  wall.

The  component  for the  recovery and  treatment of  ground  water
relates  only  to the plan to create an inward gradient across  the
slurry wall.  This  will  prevent the escape of any contaminants from
the  landfill.   The  final  positioning  of  the slurry  wall  was
determined by the approval by the EPA and the NYSDEC of the 65%  re-
medial design.

In order to make an appropriate comparison, it must be  assumed that
the  incineration  contingency  has  been  triggered,  and  that  the
additional incineration costs are included.

The following  cost figures are  from the  September  1990 ROD,  and
hence  are stated in 1990 dollars.

Estimated Capital  Cost:                               $22,870,000
Estimated O & M Costs:                                  7,210,000
Estimated Present-Worth Cost
      (in 1990 dollars):                                30,080,000
Estimated Present-Worth Cost
      (in 1994 dollars):                                39,429,000
Additional Cost Due to Incineration
      (in 1994 dollars):                                30,000,000
Estimated TOTAL Present-Worth Cost
      (in 1994 dollars):                                69,429,000

Times  to Implement -
Remedial Design:                                            1 year
Remedial Action:                                      5 to 7 years

ALTERNATIVE II.-   MODIFIED REMEDY  AS  SELECTED  IN  THIS RECORD OF
DECISION AMENDMENT

Capping/  Consolidation  of  Soils/  Erection  of  a  Slurry  Wall/
Recovery and Treatment of Ground Water/ Recovery and Treatment of
NAPL/ Embayment Sediments/ Re-Routing of Storm Sewer/ Post-Remedial
Monitoring/ Restriction of Access/  Institutional Controls

This alternative,  which  is  defined as  the selected remedy in the
Record of Decision  Amendment, consists of all of  the features found
in the remedy selected in the September 1990 ROD, except that the
incineration contingency has been eliminated, and the slurry wall
will be moved shoreward and run along the general contours of the
shoreline.  The  primary purpose of the September  1990 ROD (contain-
ing the NAPL plumes) will still be  maintained.

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The  increased costs  of constructing  the  slurry wall  along  the
contours of the shoreline and the dredging of additional  volumes of
sediments, will  be  offset by  the cost savings due to the reduced
size of the cap.

Estimated Capital Cost:                               $22,870,000
Estimated O & M  Costs:                                  7,210,000
Estimated Present-Worth  Cost
     (in 1990 dollars):                                 30,080,000
Estimated Present-Worth  Cost
     (in 1994 dollars):                                 39,429,000

Times to Implement-
Remedial Design:                                           1 year
Remedial Action:                                          3 years


V.- EVALUATION OF ALTERNATIVES

In  accordance with  the  National  Oil  and  Hazardous   Substances
Pollution  Contingency Plan  (NCP),  a  detailed analysis  of  each
alternative is  required.  The  detailed analysis consists  of  an
assessment of the two alternatives  against  each of nine  evaluation
criteria and  a  comparative analysis  focusing upon  the relative
performance of each alternative against those  criteria.

The  following  "threshold" criteria  must  be  satisfied  by   any
alternative in order to be eligible for selection:

1.   Overall  protection  of human health  and  the  environment
     addresses whether or not a remedy  provides adequate protection
     and describes how  risks posed through each exposure pathway
     (based on a reasonable maximum exposure scenario)  are elimi-
     nated, reduced, or controlled through treatment, engineering
     controls, or institutional controls.

2.   Compliance with ARARs addresses whether or not a remedy would
     meet all  of  the applicable  (legally enforceable), or relevant
     and appropriate federal and state environmental statutes  and
     requirements (i.e., those that pertain to similar situations
     encountered at  a Superfund site  so  that their use  is  well
     suited to the Site)  or provide grounds for invoking a waiver.

The  following "primary  balancing"  criteria  are used to  make
comparisons and to identify the major trade-offs between alterna-
tives:

3.   Long-term effectiveness and permanence refers to the ability
     of a remedy to maintain reliable protection  of  human health
     and the environment  over time, once cleanup  goals  have been
     met.   It also addresses the magnitude and effectiveness of the
     measures  that  may  be required to  manage the risk posed by
     treatment of residuals and/or untreated wastes.

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4.   .Reduction  of  toxicity,  mobility,  or volume  via  treatment
     refers to the remedial technology's expected ability to reduce
     the  toxicity,  mobility,  or  volume  of hazardous  substances,
     pollutants or  contaminants at the site.

5.   Short-term  effectiveness  addresses  the  period  needed  to
     achieve protection and any adverse impacts on human health and
     the environment that may be posed during  the  construction and
     implementation periods until cleanup  goals are achieved.

6.   Implementability  refers  to  the technical and administrative.
     feasibility  of a remedy, including  the  availability of the
     materials and  services needed.

7.   Cost includes estimated capital and  operation and maintenance
     costs, and the present-worth cost.

The following "modifying" criteria are considered fully  after the
formal public comment period on  the  Post-Decision  Proposed Plan is
completed:

8.   State acceptance indicates whether, based on its review of the
     RI/FS and  the Proposed  Plan,  the  State  supports,  opposes,
     and/or has  identified any  reservations with  the  preferred
     alternative.

9.   Community acceptance refers to the public's general  response
     to the alternatives  described in the Proposed Plan and the
     RI/FS reports.   Factors  of community acceptance to be dis-
     cussed include support,  reservation,  and  opposition by the
     community.

A  comparative analysis   of  the  alternatives  based   upon these
evaluation criteria follows.  The comparative analysis  focuses upon
the essential  difference in the two alternatives:   the  incineration
of dredged  sediments versus  the  reconsolidation of  the dredged
sediments within the slurry wall and beneath the capped  landfill.

1.- Overall Protection of Human Health and the Environment:

Both  remedies,  (existing   and modified)   are  considered to  be
protective of  human health and the environment.  Both remedies will
require  the   same  type of  dredging  operations.    However,  the
proposed Alternative  II  will require  the dredging of a greater
volume of sediments.  The relative volumes of the sediments to be
dredged, more  in  the case of the modified remedy, will have  no
impact on the analysis within this criterion.

The consolidation of dredged sediments within the slurry wall and
beneath the landfill  cap  will effectively isolate  the sediments
from the environment.   It  should be noted  that thousands of tons of
waste material will remain within the landfill following closure
and final capping.  These wastes will be physically contained by

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the  slurry  wall and  cap;  these wastes  will  be  hydraulically
contained  by the ground-water pumping and treating components of
the remedy.   Monitoring  is required to ensure that these physical
and hydraulic systems are effective in containing the wastes in the
landfill.

2.- Compliance  with Applicable/  or Relevant  and Appropriate Re-
quirements  (ARARs):

Applicable  or relevant and  appropriate  requirements (ARARs) are
those federal or state environmental and  public health regulations
that apply to remedial activities at a site.

In the September 1990 ROD, the EPA had determined  that the original
remedy  would comply with federal and state  ARARs.    During the
subsequent  design phase  in  1993 for  the implementation  of the
remedy,  the  federal and  state  natural resources trustees raised
concerns that the remedy, as then designed,  would  result in the
loss of  approximately  six acres  of irreplaceable habitat in the
embayment  area.    The  trustees  requested  that the  design  be
reassessed to determine if it would be feasible from an engineering
perspective  to  modify the design so  that any such habitat losses
would be minimized.  A reassessment was conducted as described in
more detail in Section III.  above. The modification of the remedy
as selected  in  this Record  of  Decision.  Amendment was  the direct
result  of  this  reassessment  process.   The modified  remedy will
avoid the destruction of  somewhat  more than half of these six acres
of habitat.   The  modified remedy will  more fully comply with the
ARARs identified in  the 1990  ROD for minimizing the loss of habitat
as well as for implementing the remedy  in a manner consistent with
state coastal plans as  required by the Coastal Zone Management Act
(CZMA) .  The evaluations required by the CZMA as well  as by the
cultural  resource  reports  required   by the  National  Historic
Preservation Act  (NHPA) are  currently being developed.

In all  other respects, the analysis contained in the September 1990
ROD that the remedy complies with all  federal  and state ARARs
substantially remains unchanged for the modified remedy.

3.- Long-Term Effectiveness and Permanence:

Incineration  of  highly   contaminated  sediments  offers  greater
permanence  because  the  contaminants  are  actually  destroyed.
However, if  the sediments are  placed  on  the landfill,  completely
encapsulated within the slurry wall and the cap,  and if long-term
monitoring controls are  properly  implemented,  there  should be an
equivalent degree of effectiveness with either alternative.

It should be noted that the estimated mass of contaminants within
these  sediments would  increase the  total  mass of  contaminants
already in the  landfill by less than  1%.

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 4.- Reduction  of  Toxicity/ Mobility, or Volume:

 Both  alternatives will control or reduce the toxicity, mobility,
 and  volume of the contaminants  through  treatment (i.e., ground-
 water treatment  and  NAPL  incineration)   and   encapsulation  of
 landfill residuals.  With the original ROD remedy, the toxicity and
 the volume of the sediments would be reduced through  incineration.
 In the case of the modified  remedy,  there will be no reduction in
 the toxicity or the volume of  the contaminated sediments, but the
 contaminated sediments will be immobilized through encapsulation.

 5.- Short-Term Effectiveness:

 Any alternative involving incineration will be least effective over
 the  short  term due  to the  anticipated  delays  in  procuring the
 availability  of   an  incinerator.   In  the  case  of  the modified
 remedy, once the incineration contingency is  removed,  the prospects
 over  the short term will  improve significantly.

 Any dredging work  associated  with the removal of sediments from the
 River can have short-term impacts on the River due to the release
 of contaminated sediments  into the  River.   However,  prior to the
 initiation of any dredging work,  a berm will be constructed beyond
 the area of contamination so as to effectively retain any loosened
 sediments, thereby preventing their transport into the River proper
 from the embayment.

 6.- Implementability:

 In comparing the  two  remedies,  there are  significant problems in
 terms of implementing the incineration contingency mainly because
 of the lack  of availability of  a local incinerator  and the fact
 that there is  only one incinerator  nationwide  which  has both the
 capability and all required permits,  approvals, and authorizations
 to handle dioxin-containing sediments.

 Both the  modified  remedy and the original remedy may encounter some
 technical problems with regard to sediment control, dewatering, and
 berm installation. However these types of problems are manageable
with existing technology.

 7.- Costs:

The present-worth cost for the existing remedy,  in  1994 dollars,
with the incineration contingency operative, is $69,429,000.

The present-worth cost  for  the  modified   remedy,  also in  1994
dollars,  is $39,429,000.

8.- State Acceptance:

The State of New  York  (NYSDEC)  has  concurred on  the  selection of
the modified remedy.
                                10

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9.- Community Acceptance:

The community's reaction to the modified remedy as received during
the public  comment period,  as well as  at  the  public meeting, is
contained in the Responsiveness Summary which is included as a part
of this decision document.

In  general,  the  public appeared  to  be receptive  to  the  EPA's
decision to modify the selected remedy.

VI.- SELECTED REMEDY

Based on consideration of the requirements  of CERCLA, the detailed
analysis of the alternatives, and the comments received during the
public comment period, the EPA has determined that Alternative II
is the most appropriate remedy for the Site.

As described above, Alternative II, which is the remedy selected in
this Amendment,  consists of  all the features  found  in the remedy
selected in the  September  1990 ROD, except that the incineration
contingency has been eliminated, and the slurry wall will be moved
shoreward and will run along the general contours of the shoreline.
The primary purpose of the  September 1990 ROD (containing the NAPL
plumes) will still be maintained.

VII.- STATUTORY DETERMINATIONS

Under its legal  authorities,  the  EPA's primary  responsibility at
Superfund sites  is  to  undertake  remedial actions  that achieve
adequate protection   of  human health  and   the  environment.    In
addition, Section 121  of CERCLA establishes  several other statutory
requirements and preferences  that  the  selected  remedy must meet.
Section 121 of CERCLA specifies that when  complete,  the selected
remedial action  for  the Site must comply  with  ARARs established
under  federal  and state  environmental  laws  unless  a  statutory
waiver is justified.   The  selected remedy, also, must  be  cost-
effective and utilize  permanent solutions and alternative treatment
technologies  or  resource  recovery technologies  to the  maximum
extent practicable. Finally, the statute includes a preference for
remedies that employ treatment that permanently and significantly
reduce the volume, toxicity,  or mobility  of hazardous  wastes as
their principal  element.  The  following sections  discuss how the
selected remedy meets these statutory  requirements.

Protection of Human Health and the Environment;

Since .both  the  original  remedy   and  the   modified  remedy  will
necessitate the  same type  of  dredging operations,  the  modified
remedy will have  no impact within this statutory determination, and
thus is protective of human health and  the  environment.
                                11

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While the  modified  remedy will require the dredging of a greater
total volume  of sediments since the  slurry  wall will be reposi-
tioned along the shoreline, this again should have no impact  on the
overall protection  of  human health and the environment since the
contaminated sediments will, in both cases, be  encapsulated  within
the slurry wall and beneath the cap.

Compliance with Applicable,  or Relevant and Appropriate Require-
ments fARARs):

The original analysis  with respect to ARARs,  as contained  in the
September 1990 ROD, held that the  original remedy did comply with
all federal and state ARARs.

Since the modified remedy  will change only the volumes and types of
sediments  to  be  dredged,  i.e., a  greater  total volume  will be
dredged,  which will   consist   of  both  contaminated and   highly
contaminated sediments, there  should be no substantive variation
from the original analysis which found a positive compliance with
all federal and state ARARs.

Cost-Effectiveness:

Cost-effectiveness is  a critical coiuponent used in the balancing of
the evaluation criteria.  Superior cost-effectiveness was therefore
a factor which eventually  led to the selection  of the modification
as opposed to the unmodified original remedy.

The present-worth cost  for the  original remedy,  in 1994 dollars,
with the incineration contingency operative,  is $69,429,000.

The present-worth cost for the  selected  modification,  also in 1994
dollars, is $39,429,000.

Utilization  of  Permanent  Solutions and  Alternative  Treatment
Technologies  (or  Resource Recovery Technologies) to the  Maximum
Extent Practicable:

There  is  no  change  in  this  statutory  determination  when  the
original remedy is compared to the selected modification.

The EPA and the NYSDEC believe that the  original .remedy as well as
the selected modification, represents the maximum extent to which
permanent solutions and treatment technologies can be utilized in
a cost-effective manner at the Site.

Preference for Treatment as a Principal Element;

There  is  no  change  in  this  statutory  determination  when  the
original remedy is compared to the selected modification.
                                12

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In  the case  of  the  original  remedy as  well  as the  selected
modification, the preference for treatment as a principal element
is  not satisfied since  treatment of  the  principal  threat  (the
landfill residuals)  was found to be distinctly impractical.

However, the  material containing  the highest  concentrations  of
contaminants, meaning the  recovered  NAPL,  will  still be treated
through off-site incineration.
                               13

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            APPENDIX 1




Concurrence Letter from the NYSDEC

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New York State Department of Environmental Conservation
50 Wolf Road, Albany, New York 12233-7010
                                              MAY  I 2 I995               Michael Za?au
                                                                        Commissioner
  Mr. William J. McCabe
  Deputy Director
  New York/Caribbean Programs
  Emergency and Remedial Response Division
  U.S. Environmental Protection Agency
  290 Broadway, 20th Floor
  New York, New York  10007-1866

               Re:  102nd Street Landfill (Site #932022, 932031)
                   Amended Record of Decision

  Dear Mr. McCabe:

        The State has reviewed the draft Amended Record of Decision (AROD). dated
  May 1, 1995, for the remediation of sediments at the 102nd Street Landfill.  The draft AROD
  eliminates the requirement to incinerate sediments dredged from the "hot spot" areas, instead
  allowing reconsolidation of the "hot spot" sediments within the landfill containment and under
  the final cap.  The State comments on a previous draft AROD were submitted by the State on
  March 31, 1995 and have been adequately incorporated into the AROD.

        The New York State Department of Health has also reviewed the draft AROD and
  concurs  with  the recommended  changes.  As such, the  State agrees  with  the AROD as
  amended and recommends that it  be executed as soon as possible.

        The State recognizes and supports the EPA decision to retain the 200 ug/kg cleanup
  level for mercury in  the sediments of the embayment as set forth  in the 1990 Record of
  Decision.   In light of  this decision,  the State requests EPA's  commitment to  make
  rehabilitation of the embayment habitat a high  priority for this project.  The final remedial
  design for this  site must include a comprehensive mitigation plan to return habitat that will be
  affected by the sediment dredging  to its current condition, that is one which supports the fish
  and wildlife currently within the habitat.  The mitigation plan must have clearly defined
  performance objectives and  must include both  an aggressive planting plan and a long term
  requirement for replanting should performance  objective not be met or maintained.

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                                                                            Page 2
       The mitigation plan must be accompanied by a pre-construction inventory to accurately
define the habitat vegetation species composition and the percentage of area! coverage and
plant  density for each species in the embayment.  The pre-construction inventory nmsj be
completed this year while the vegetation is showing and readily identified. Further, design
and implementation of the dredging of the sediments must not impact any more of the habitat
than is absolutely necessary.

       Thank you for the opportunity to review .the draft AROD.  We are prepared to assist
in any way that we can with EPA's efforts to complete a comprehensive habitat rehabilitation
program.

                                         Sincerely,
                                         Michael J. O'Tdble, Jr.
                                         Director
                                         Division of Hazardous Waste Remediation
cc:     G. Anders Carlson, NYSDOH
       C. Petersen, USEPA
       K. Lynch, USEPA '
       P. Olivo," USEPA
       N. Spiegel, NYSDOL

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            APPENDIX 2




Index for the Administrative Record

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                       102 STREET LANDFILL
                     NIAGARA FALLS.  NEW YORK
                   ADMINISTRATIVE RECORD FILE
                       INDEX OF  DOCUMENTS
SITE IDENTIFICATION

Background - RCRA and Other Information
P. I - 57A          A Computer Print Out of 102nd Street Landfill
                    Documents.  May 18,  1990.


REMEDIAL INVESTIGATION

Sampling and Analysis Plans

P. 58 - 164         Report:  Site Operations Plan (Task 4).
                    Draft.  102nd Street Landfill site, prepared
                    by Olin Chemicals Group- Occidental Chemical
                    Corporation. June 1984.

P. 165 - 177        Report:  Addendum No.  1. Site Operations
                    Plan.  102nd Street Landfill Site, prepared by
                    Woodward-Clyde Consultants, May 28, 1985.

P. 178 - 203        Report:  Addendum No.  2. Site Operations
                    Plan.  102nd Street Landfill Site, prepared by
                    Olin Chemical Group- Occidental Chemical
                    Corporation, June 13,  1985.


P. 204 -243         Letter to Mr. Paul J.  Olivo, U.S. EPA, and
                    Mr. Murray E. Sharkey, Department of
                    Environmental Conservation from D. L.
                    Cummings, Olin Chemical Group, and J. A.
                    Cull,  Occidental Chemical Corporation, re:
                    Assessment of Chemical Monitoring Program.
                    November 30, 1987.  The Quality Assurance
                    Plans & Analytical Protocols for the
                    Assessment Chemical Monitoring program is
                    attached.

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Sampling and Analysis Data/Chain of Custody Forms

P. 244 - 341        Report:  102nd Street Landfill. Hvdrogeologic
                    Evaluation, prepared by GTC  Geologic Testing
                    Consultants LTD., June 1, 1984.  References
                    are listed on P.

P. 343 - 374        Memorandum to R. L. Comboy, from E.A. Dietz,
                    Occidental Chemical Corporation, re:  Results
                    from Determination of Organic Vapors Trapped
                    on Charcoal Tubes- 102nd Street Air
                    Monitoring of Worker Exposure.  November 21,
                    1985.  The results are attached.

P. 375 - 393        Report:  Monitoring Well Inspection. 102nd
                    Street Landfill, Niagara Tails. New York.
                    prepared by Woodward-Clyde Consultants,
                    January 10, 1986.

P. 394 - 498        Report:  Geologic and Well Construction Logs,
                    102nd Street Landfill Remedial Investigation
                    Niagara Falls. New York, prepared by
                    Geotrans,  Inc., May 15,  1986.

P. 499 - 546        Report:  OCC NAPL Analysis. Part I. 102nd
                    Street Landfill Site, prepared by Occidental
                    Chemical Corporation, September 12; 1986.


P. 547 - 677        Report:  Monitoring Well/Borehole
                    Stratigraphic & Instrumentation Logs, 102nd
                    Street Landfill Remedial Investigation.
                    Niagara Falls. New York, prepared by
                    Occidental Chemical Corporation. Date is
                    unknown.

P. 678 - 920        Report:  Information Report No. 2. 102nd
                    Street Landfill. Remedial Investigation.
                    Niagara Falls. New York, prepared by 01in
                    Chemicals Group and Occidental Chemical
                    Corporation,  June 1987.

P. 921 - 947        Report:  Quality Assurance Evaluation of Site
                    Specific Parameters Extended Survev-
                    Groundwater.  First Iteration. 102nd Street
                    Landfill,  prepared by unknown, September 8,
                    1987.

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P. 948 - 998
P.  999 - 1078
P. 1079 - 1094
P.  1095 - 1211
P.  1212 - 1248
Letter to Mr. Alan A. Fuchs, Department of
Environmental Conservation, and Mr. Paul J.
Olivo, U.S. EPA, from Mr. David L. Cummings,
Olin Corporation, and Mr. Jay A. Cull,
Occidental Chemical Corporation, re:  Quality
Assurance Evaluation.  September 29, 1987.
The Quality Assurance Evaluation,
Chlorobenzoic Acid Data on First and Third
Iteration Samples Extended Survey-Groundwater
and Bulkhead Investigation Report, September
1987, is attached.

Report: OCC NAPL Analyses, Part 3. 102nd
Street Landfill Site, prepared by Occidental
Chemical Corporation, October 16, 1987.

Letter to Mr. Paul J. Olivo, U.S. EPA, and
Mr. Alan A. Fuchs, Department of
Environmental Conservation, from Mr. David L.
Cummings, Olin Corporation, and Mr. J. A.
Cull, Occidental Chemical Corporation, re:
Quality Assurance Evaluation.  October 26,
1987.  The Quality Assurance Evaluation,
General Parameters for extended Survey of
Groundwater, Fifth Iteration Report, October
29, 1987 is attached.

Letter to Mr. Paul J. Olivo, U.S. EPA, and
Mr. Alan A. Fuchs, Department of
Environmental Conservation, from Mr. Alan F.
Weston, Occidental Chemical Corporation, re:
Quality Assurance Data Review.  November 4,
1987.  The Quality Assurance Data Review,
102nd Street Landfill Soil, and Sediment
Analysis, Rounds 4 and 5 is attached.

Letter To Mr. P. J. Olivo, U.S. EPA, and Mr.
Murray E. Sharkey, Department of
Environmental Conservation, from Mr. D. L.
Cummings, Olin Chemical Corporation, and J.
A. Cull, Occidental Chemical Corporation, re:
Supplementary NAPL Investigation.  December
11, 1987.  The Supplemental NAPL
Investigation Report is attached.

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P. 1249 - 1300
Letter to Mr. Paul J. Olivo, U.S. EPA, and
Mr. Thomas R. Christoffel, Department of
Environmental Conservation, from Mr. D. L.
Cummings, Olin Chemicals Group, and Mr. J. A.
Cull, Occidental Chemical Corporation, re:
Niagara River Borehole Drilling Program.
March 31, 1988.  The Niagara River Borehole
Drilling Program Report, March 18, 1988, is
attached.
P. 1301 - I400c
P. 1401 - 1425
P. 1426 - 1433
P. 1434 - 1485
Letter to Mr. Paul J. Olivo, U.S. EPA, and
Mr. Thomas R, Christoffel, Department of
Environmental Conservation, from Mr. Alan F.
Weston, Oxychem, re:  OCC NAPL Analyses, Part
4.  April 14, 1988.  A revised version of
Analytical Report 29 and the OCC NAPL
Analyses, Part 4 are attached.

Letter to Mr. Paul J. Olivo, U.S. EPA, and
Mr. Thomas r. Christoffel, New York State
Department of Environmental Conservation,
from Ms. L. M. Miller, Olin Corporation, and
Mr. Alan F. Weston, Occidental Chemical
Corporation, re:  Quality Assurance
Evaluation.  April 18, 1988.  The Quality
Assurance Evaluation of Site Specific
Parameters, Extended Survey, Groundwater,
Sixth Iteration, November 1987 report is
attached.

Report:  Quality Assurance Evaluation of
Chlorobenzoic Acid, Off-Site Wells.
Groundwater. February 1988-April 1988. 102nd
Street Site Investigation, prepared by Olin
Chemicals Group, April, 1988.

Letter to Mr. Paul J. Olivo, U.S. EPA, and
Mr. Thomas R. Christoffel, New York State
Department of Environmental Conservation,
from Mr. David L. Cummings, Olin Corporation,
and Mr. Jay A. Cull, Occidental Chemical
Corporation, re:  Revision 1 of the Niagara
River Borehole Drilling Program.  May 6,
1988.  The Niagara River Borehole Drilling
Program, Revision 1, May 5, 1988, is
attached.

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P. 1486 - 1510      Letter to Mr.  Paul J. Olivo, U.S. EPA and Mr.
                    Thomas R. Christoffel, New York State
                    Department  of Environmental Conservation,
                    from Ms.  Lorraine M. Miller, Olin
                    Corporation, and Mr. Alan F. Weston,
                    Occidental Chemical Corporation, re:  Quality
                    Assurance Evaluation.  May 9, 1988.  The
                    Quality Assurance Evaluation of General
                    Parameters for Extended Survey-Groundwater,
                    Sixth Iteration- November 1987 report is
                    attached.

P. 1511 - 1557      Letter to Mr.  Paul J. Olivo, U.S. EPA, and
                    Mr.  Thomas R.  Christoffel, New York State
                    Department of Environmental Conservation,
                    from Mr.  David L. Cununings, Olin Corporation,
                    and  Mr. Jay A. Cull, Occidental Chemical
                    Corporation, re:  Assessment Chemical
                    Monitoring Program.  May 25, 1988.  The
                    Response to EPA/State.  April 21, 1988
                    Comments and the Quality Assurance Plans and
                    Analytical Protocols -for the Assessment
                    Chemical Monitoring Program report is '
                    attached.

P. 1558 - 1593      Letter to Mr.  Paul J. Olivo, U.S. EPA, and
                    Mr.  Thomas R.  Christoffel, New York State
                    Department of Environmental Conservation,
                    from Mr.  David L. Cummings, Olin Corporation,
                    and  Mr. Jay A. Cull, Occidental Chemical
                    Corporation, Re:  Revision of Supplementary
                    NAPL Investigation.  June 3, 1988.  The
                    Supplemental NAPL Investigation, Revision 1,
                    102nd Street Landfill, Remedial Investigation
                    report, June 3,  1988, is attached.

P. 1594 - 1622      Letter to Mr.  Paul J. Olivo, U.S. EPA, and
                    Mr.  Thomas R.  Christoffel, from Mr. Alan F.
                    Weston, Occidental Chemical Corporation, and
                    Ms.  L. M. Miller, Olin Corporation, re:
                    Quality Assurance review of Soil, Sediment,
                    and  Sewer bedding data.  June 6, 1988.  The
                    Quality Assurance data, May 18, 1988, is
                    attached.

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P. 1623 - 1633      Letter to Mr. Paul J. Olivo, U.S. EPA, and
                    Mr. Thomas R. Christoffel, New-York State
                    Department of Environmental Conservation,
                    from Ms. Lorraine M. Miller, Olin
                    Corporation, and Mr. Alan R. Weston,
                    Occidental Chemical Corporation, re:  Quality
                    Assurance Evaluation.  June 14, 1988.  The
                    Quality Assurance Evaluation of
                    Chloraobenzoic Acid Extended Survey-
                    Groundwater, Sixth Iteration, November 1987
                    report is attached.

P. 1634 - 1646      Letter to Mr. Paul J. Olivo, U.S. EPA, and
                    Mr. Thomas R. Christoffel, New York State
                    Department of Environmental Conservation,
                    from Ms. Lorraine M. Miller, Olin
                    Corporation, re:  Quality Assurance
                    Evaluation- General Parameters for Off-Site
                    Wells.  June 24, 1988.  The Quality Assurance
                    Evaluation of General Parameters for Off-
                    Site Wells- Groundwater, February 1988-April
                    1988 report is attached.
P. 1645 - 1664      Letter to Mr. Paul J. Olivo, U.S. EPA, and
                    Mr. Thomas R. Christoffel, New York State
                    Department of Environmental Conservation,
                    from Ms. Lorraine M. Miller, Olin
                    Corporation, re:  Quality Assurance
                    Evaluation.  June 24, 1988. The Quality
                    Assurance Evaluation of Site Specific
                    Parameters, Off-Site Wells, Groundwater,
                    February 1988, April 1988 report is attached.

P. 1665 - 1677      Report:  102nd Street Landfill Site Project.
                    Quality Assurance Report. NAPL Analysis Parts
                    3 and 4. prepared by Occidental Chemical
                    Corporation, William E. Lesoux, Quality
                    Assurance Officer, September 1, 1988.

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P. 1678 - 1716
P. 1717 - 1857
P. 1858 - 1869
Work Plans
P. 1870 - 1936
P. 1937 - 2145
P. 2146
Letter to Mr. Paul J. Olivo, U.S. EPA, and
Mr. Thomas R. Christoffel, New York State
Department of Environmental Conservation,
from Mr. David L. Cummings, Olin Corporation,
and Mr. Jay A. Cull, Occidental Chemical
Corporation, Re:  Revision 2 of the
Supplemental NAPL Investigation report.
December 20, 1988.  The Supplemental NAPL
Investigation Revision 2 report, December
1988, is attached.

Report:  Final Report Assessment Chemical
Monitoring Program, prepared by Woodward-
Clyde Consultants, June 27-, 1989.

Report: Air Quality Impacts Modeling
Analysis. Excavation Under Alternative OU1,
5C, prepared by Sirrine Environmental
Consultants, July 1990.
Report:  Work Plan for the Remedial
Investigation 102nd Street Landfill Site.
Niagara Falls, New York, prepared by unknown.
June 1984.  References are cited at end of
report.

Report:  Project for Performance of Remedial
Response Activities at Uncontrolled Hazardous
Substance Facilities-  Zone 1. prepared by
NUS Corporation, Superfund Division.  March
28, 1985.

Work Chart:  102nd Street Remedial
Investigation Schedule. Prepared by CRA, work
tasks graphed against time schedule,
Revision. November 26, 1985.
Remedial Investigation Reports
P. 2147 - 2250
P. 2251 - 2257
Report:  102nd Street Landfill Site. Remedial
Investigation. Environmental Health and
Safety Plan, prepared by Occidental Chemical
Corporation and Olin Corporation. March 1,
1985.

Report:  Resident Engineering Services. 102nd
Street Spoils cell Construction. Niagara
Falls, New York, prepared by Woodward-Clyde
Corporation.  Date Unknown.

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P. 2258 - 2710
 Report:  Remedial Investigation Final Report.
 Volume 1- Text.  102nd Street Landfill Site.
 Niagara Falls. .New York, prepared by
 Conestoga-Rover & Associates, and Woodward-
 Clyde Consultants.  July 1990.  A copy of
 report is attached.
P. 2711 - 2874
Correspondence
P. 2875 - 2881
 Report:   Remedial Investigation Final Report,
 Volume 2- Appendices & Plans.  102nd Street
 Landfill Site.  Niagara Falls.  New York.
 prepared by Conestoga- Rover & Associates,
 and Woodward-Clyde Consultants.  July 1990.
 A copy of report is attached.
 Letter to Mr.  Paul J.  Olivo,  U.S. EPA, and
 Mr.  Thomas R.  Christoffel,  New York State
 Department of  Environmental Conservation,
 from Mr.  Alan  F.  Weston,  Occidental Chemical
 Corporation, re:   Response to the EPA/State
 November 21,  1988, on  the Quality Assurance
 Plans and Analytical Protocols for the
 Assessment Chemical Monitoring Program.
.December 12,  1988.  The response and the
 report is attached.
FEASIBILITY STUDY
Feasibility Study Work Plans

P. 2882 - 2932
 Report:   102nd Street Feasibility Study Work
 Plan.   December. 6,  1988.
Feasibility Study Reports

P. 2933 - 3057
P. 3058 - 3214
Proposed Plans
 Report:   Feasibility Study Final Report.
 102nd Street Landfill Site.  Volume I, July
 1990.

 Report:   Feasibility Study Final Report,
 102nd Street.  Volume II and Appendices. July
 1990.
                                8

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p. 3215 - 3233
Superfund proposed plan. Includes
announcement of propsed plan, site
background, scope of response action, summary
of site risks and a summary of alternatives
for the 102nd Street Landfill Site, Niagra
Falls, New York. July, 1990. Three operable
unit plans are attached.
ENFORCEMENT
Endanaerment Assessment
P. 3234 - 3392
P. 3393 - 3568
P. 3569 - 3772
P. 3773 - 3932
Consent Decrees
P. 3933 - 3945
P. 3946 - 3960
Correspondence

P. 3961
Report:  Baseline Human Health Risk and
Environmental Endangerment Assesment for the
102nd Street Landfill, prepared by Gradient
Corporation.  May 25, 1990.

Report:  Baseline Human Health Risk and
Environmental Endangerment Assesment for the
102nd Street Landfill. Appendices, prepared
by Gradient Corporation.  May 25, 1990.

Report:  Evaluation of Potential Contaminant
Releases and Human Health Risk Associated
with Excavation and Incineration of the 102nd
Street Landfill.  July 11, 1990.

Report:  Baseline Risk Assessment - Final
Report, prepared by Sirrine for OCC and 01in,
July 1990.
Stipulation.  Signed By Court on June 26,
1984.  A fact sheet and site location is
attached.

Stipulation and Decree.  Date unknown.
Letter to Judge John T. Curtin, United States
District Court, from Mr. Bruce S. Gelber,
U.S. Department of Justice, re:  Stipulation
and Decree, February 9, 1989, is attached.
Letter to Mr. Robert M. Cohen, GeoTrans Inc.,
Mr. David Bass, Gradient Corporation, and
Mrs. Mary Ann Storr, U.S. EPA Public
Information Office, from Mr. Paul Olivo, U.S.
EPA, re:  Notice of Lodging and Proposed
Stipulation and Decree.  February 17, 1989.

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NATURAL RESOURCES TRUSTEES

Findings of Facts
P. 3962 - 4009
Report:  Biological Indicators of
Environmental Contaminants in the Niagara
River, prepared by the U.S. Fish and Wildlife
Service, May 1990.
PUBLIC PARTICIPATION
Community Relations Plans
P. 4010 - 4033
Public Notices
P. 4034
P. 4035
P. 4036
Report:  Community Relations Plan, 102nd
Street Site. Niagara Falls. Niagara County.
New York, prepared by NUS Corporation.
February 1985.
Invitation for public comment. Released by
the US EPA as appears in the Niagara Gazette.
July 25, 1990, p. 4B.

Invitation for public comment. Released by
the US EPA as appears in the Buffalo News,
July 25, 1990, p. D - 4.

Public Service Announcement released by John
Anderson, U.S. EPA, Public Information
Office, re: Availability of representatives
of the New York State Department of
Environmental Conservation.  Date unknown.
Public Meeting Transcripts
P. 4037 - 4096
Transcript of a public meeting held at the.
Red Jacket Inn, Niagara Falls , New York, on
August 15, 1990.
Fact Sheets and Press Releases
P. 4097 - 4101



Correspondence

P. 4102
News Release from the US EPA, Region II,
Re: $30 Million clean up remedy, July
26, 1990.
Letter to 102nd Street Site Mailing List,
from U.S. EPA, re:  Results of EPA dioxin
screening and field activities being taken at
the site.  September 13, 1985.

           '10

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P. 4103
P. 4104
P. 4105
P. 4106
P. 4107
P. 4108
P. 4109
P, 4110
P. 4111
P. 4112
P. 4113
P. 4114
Letter to 102nd Street Site Mailing List,
from Mr. Kevin Lynch, U.S. EPA, and Mr. Alan
Fuchs, New York State Department of
Environmental Conservation, re:  Progress of
Remedial Investigation at site.  December 9,
1985.  A copy of letter is attached.

Letter to Concerned Citizen, from Mr. Matthew
J. Forcucci, U.S. EPA, re:  Documents
available for public review.  September 12,
1986.

Letter to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  August 31, 1987.

Letter to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  September 30, 1987.

Letter to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  October 30, 1987.

Letter to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  November 25, 1987.

Letter to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  November 30, 1987.

Letter to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  December 31, 1987.

Letter to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  December 31, 1987.

Letter to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  January 19, 1988.

Letter to Concerned Citizen, from Ms. Barbara
C. Taylor, U.S. EPA, re:  Documents available
for public review.  February 29, 1988.

Letter to Concerned Citizen, from Ms. Barbara
C. Taylor, U.S. EPA, re:  Documents available
for public review.  March 17, 1988.
                                11

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P. 4115
P. 4116
P. 4117
P. 4118
P. 4119
P. 4120
P. 4121
P. 4122
P. 4123
Letter to Concerned Citizen, from Ms. Barbara
C. Taylor, U.S. EPA, re:  Documents available
for public review.  April 15, 1988.

Letter to Concerned Citizen, from Ms. Barbara
C. Taylor, U.S. EPA, re:  Documents available
for public review.  April 29, 1988.

Letter to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  June 8, 1988.

Letter -to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  June 29, 1988.

Letter to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  July 27, 1988.

Letter to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  August 22, 1988.

Letter to Concerned Citizen, from Ms. Mary
Ann-Storr, U.S. EPA, re:  Documents available
for public review.  October 18, 1988.

Letter to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  November 18, 1988.

Letter to Concerned Citizen, from Ms. Mary
Ann Storr, U.S. EPA, re:  Documents available
for public review.  March 16, 1989.
                               12

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                   102nd STREET LANDFILL SITE
                  ADMINISTRATIVE RECORD FILE
                      INDEX OF DOCUMENTS
                            UPDATE*
RECORD OF DECISION

Record of Decision

P. 4124 - 41%      Report Declaration Statement, Record of Decision.
                102nd Street Landfill Site, (Operable units One,
                Two, and Three).
* Administrative Record File Update Available 10/8/90.

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                    102nd STREET LANDFILL SITE
                    ADMINISTRATIVE RECORD FILE
                        INDEX OF DOCUMENTS
                              UPDATE
RECORD OF DECISION

Correspondence

P.   4285-     Letter to Mr. Paul J. Olivo, Project Manager, New
     4289      York/Caribbean Superfund Branch II, Emergency and
               Remedial Response Division, U.S. EPA, from Messrs.
               David L. Cummings, Manager, Environmental
               Remediation, Olin Corporation, and Alan F. Weston,
               PhD, Manager, Analytical Services, Special
               Environmental Programs, re: 102nd Street Landfill
               Site, Niagara Falls, NY - Offshore Slurry Wall
               Alignment, August 17, 1994.  (Attached are: Figure
               1: Plan of Slurry Wall Alignment, and Figure 2:
               Typical Cross Section Through Slurry Wall
               Alignment, August 15, .1994.)

Reports

P.   4290-     Report:  Addendum - Predesiqn Field Activity
     4359      Report; Supplemental Offshore Boring Program,
               102nd Street Landfill Site, Niagara Falls. New
               York, prepared by Fluor Daniel, Inc. on behalf of
               Occidental Chemical Corporation and Olin
               Corporation, August 17, 1994.

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      APPENDIX 3




Responsiveness Summary

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                      RESPONSIVENESS SUMMARY
                   RECORD OF DECISION AMENDMENT
                    102nd Street Landfill Site
                     Niagara Falls,  New York
1.-  Overview

The U.S. Environmental Protection Agency (the  "EPA") established a
public  comment period  which ran  from  December 2,  1994 through
January 25, 1995 so as to allow interested parties to comment upon
the EPA's Post-Decision Proposed Plan (PDPP) for the modification
of the  remedy  originally selected for  the  102nd Street Landfill
(the "Site").

The EPA also held a public meeting on Wednesday,  December  14, 1994,
at the  Red  Jacket Inn located at  7001  Buffalo  Avenue  in Niagara
Falls, New York.  The purpose of the public meeting was to review
the  PDPP,  to  present  the  EPA's  preferred  modification  to  the
original  remedy  as   defined in  the  September 1990  Record  of
Decision,  and  to solicit,  record,  and consider  all  comments
received from  interested  parties  during the course  of  the actual
meeting.

This responsiveness  summary describes  the  comments  and concerns
raised by concerned citizens  during the comment period with respect
to the proposed modification to the original remedy,  as well as the.
EPA's  responses to  those  comments and concerns.   All  comments
summarized in this document were .given full consideration in terms
of selection of the modification to the original remedy as stated
in the Record of Decision Amendment.  The New York State Department
of  Environmental Conservation   (NYSDEC)  also  concurs  with  the
selected modification.

2.-  Background on Community Involvement and Concerns

The Site initially became  an issue of  public  concern  in December
1970, when the  Buffalo District of the U.S. Army  Corps of Engineers
(COE)  notified  Occidental  Chemical  Corporation  and  the  Olin
Corporation  (the "Companies")  that no further construction  or
landfilling could occur until  a  bulkhead was  installed along the
shoreline.  Although  the bulkhead was completed in 1973, no further
landfilling  at  the   Site  occurred  after  construction  of  the
bulkhead.    A   series  of   investigations  regarding  sub-surface
conditions at the Site led to the filing of a complaint in December
1979,  in  the U.S. District  Court in Buffalo,  New York,  by  the
United States  of  America,  on behalf of  the Administrator  of  the
EPA,  against  the Companies  seeking  injunctive  relief  and civil
penalties for an imminent and substantial endangerment to the
public health and welfare.   In November  1980, a complaint pursuant
to the New York State Conservation Law and the state's common law
                                1.

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of  public nuisance,  was  filed  by  the State  of New  York  (NYS)
seeking  civil  penalties.    These   lawsuits   are  still  pending
contingent upon the final remediation of the Site.

During the public  comment period in 1990  concerning the proposed
remedy for the Site, the citizens' comments and  concerns focused on
issues of incineration of contaminants  from the landfill and the
public's  access to  the  shoreline   following  completion  of the
remedy. More recently, beginning  in 1993, federal and state natural
resource trustees  requested the  EPA to  consider a realignment of
the slurry wall in the embayment  in  order to avoid the destruction
of wetland/embayment habitat resources.

The 1990 ROD called for the dredging and incinerating of any highly
contaminated embayment sediments if they were left outside of the
final positioning  of  the  slurry wall.  Any  sediments  with  lower
levels of  contaminants  which  remained  outside  the  slurry wall,
would  be dredged  and placed  beneath the  cap.   Therefore,  the
proposed realignment of  the  slurry wall  would not only necessitate
a modification  to the existing  remedial  design, but  would also
affect the incineration contingency  as  contained in the original
remedy.

3.-  Summary of Questions and Comments Received During the Public
     Meeting and the Responses of the EPA

At the public meeting which was held on December 14,  1994, the
major  issues  discussed  and concerns expressed  by the community
regarding the Site were  as follows:

     A.-  Comment:

          A resident stated his general concern  about the final use
          to which the land encompassing the Site might  be put.  He
          asked: "Will there be a park,  or is it just going to be
          dead land?"

          Response:

          The remedial plan  includes a flat area at the shoreline
          of the embayment  area  that will provide access  to the
          Niagara River.   Plans  are  now being  considered  for the
          design and  construction of a walkway  around the Site.
          The walkway will be  situated such that  a person can walk
          from the boat launch area,  along  the water's edge, and
          then back out to Buffalo Avenue along  the eastern side of
          the  Site.   The boat  launch  will continue   to  remain
          operational in its present location, however there may be
          some  reduction,  although  minor,  in  the  size  of  the
          ballfield located  on Griffon Park.

          The cap covering the actual landfill will be mounded with
          a certain number of  peaks  to it.   The EPA plans to have
          the area landscaped to shield the public's view of the
          mound from Buffalo Avenue  as well as from Cayuga Island.
                               2.

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     The landscaping plan,  in general,  will provide  for trees
     to be planted around the circumference of the  Site.  In
     the run along Buffalo  Avenue,  however, there may be some
     space restrictions due to the proximity of  the landfill
     cap and the  need  for  setback  of trees  from the road to
     maintain highway safety.  To the extent that  trees cannot
     be planted in the Buffalo  Avenue area,  the  landscaping
     plan will require lower-growing shrubs,  which will also
     shield the view of the landfill mounds.
B.-  Comment:
     The same resident asked if  remediation of the Site would
     also include the dredging of the Little Niagara River.

     Response:

     When the EPA investigated the extent of .contamination at
     the Site, no site-related contamination was found in the
     sediments of  the Little Niagara River.   Therefore the
     prospective  dredging  of the  Little Niagara  River was
     going  to be  treated  as  a  matter  separate  from  the
     remediation of the 102nd Street  Landfill.  See  Comment E
     and Response thereto,  below.
C.-  Comment:
     A reporter  from the  Buffalo News asked:   "What  is a
     slurry wall?"

     Response:

     A cofferdam is constructed outside the perimeter of the
     landfill and the slurry materials (soils and bentonite,
     a cement-like substance) which  are  less permeable than
     surrounding soils are  backfilled  behind the cofferdam.
     The slurry is  keyed  into.the relatively impermeable clay
     layer beneath  the landfill.  In this manner, the relative
     impermeability of the slurry and clay  layer, coupled with
     the hydraulic containment achieved through ground-water
     pumping, effectively achieves a total encapsulation of
     the hazardous wastes within the landfill.
D.-  Comment:
     A resident stated,  in part rhetorically/ that he did not
     see any benefit  to spending approximately  $40  million
     when the land could not be  put  to  any beneficial post-
     remediation use.

     Response:

     There  would be  a  benefit   from  preventing  hazardous
     materials  in  the  landfill  from  entering  the  Niagara
     River:  human health and the  environment will be protect-
     ed.
                          3.

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     In accordance with CERCLA, the evaluative criteria also
     derived from  CERCLA  were used to arrive  at a balanced
     decision that will assure the protection of  human health
     and the environment.

     An unrestricted post-remediation use would have required
     the excavation  of  the  entire landfill and the inciner-
     ation of its contents.   While it  would have  been techni-
     cally  possible  to  incinerate  the  entire  landfill,
     approximately 160,000 tons of hazardous wastes contained
     in additional tons of soil and debris, any such decision
     would not have been cost effective. The cost of inciner-
     ating  the entire  landfill would have  been  over  $500
     million.  Furthermore,  excavation would also present the
     risk of exposing the community  to the materials in the
     landfill that were being excavated.  The.selected remedy
     represented  the EPA's  balancing of  these evaluative
     criteria.
E.-  Comment:
     The same resident inquired about the piles of (dirt-like)
     materials being transferred to  the Site.   He  wanted to
     know what the materials were.

     Response:

     In  order  to  give  the  cap the  necessary support  and
     structure,  approximately  200,000  cubic yards  of  clean
     (non-hazardous)   fill  material  which  will  be  placed
     beneath the cap.   No hazardous wastes were or will be
     transferred to the  Site due to the EPA's insistence on a
     strict routine of pre-testing  and data-verification for
     all fill materials destined for the  Site.  The  use of
     available (but clean) fill materials  will be  a signifi-
     cant cost-saving factor,  when  compared to the cost of
     procuring  clean fill   from  a  standard  point-of-sale
     source.

     As  discussed  in Paragraph  B,   above,  the dredging  of
     Little  Niagara  River  sediments  is  not  part of  the
     remediation of  the landfill.   The analyses of samples
     that indicated that these sediments had not been contami-
     nated by the  102nd Street landfill,  also  demonstrated
     that these sediments could be utilizable  as clean fill
     for the construction of the landfill cap.  All parties
     (OCC,  the City  of  Niagara Falls,  EPA,  and the NYSDEC)
     were in  agreement that  it made good sense to explore the
     issue of dredging the Little Niagara  River sediments at
     the same time as the  dredging  of sediments  was  being
     conducted for  the 102nd Street remediation.  The presence
     of the dredge in the  immediate  area,  and the ability to
     use the  Little .Niagara River sediments  as fill  material
     in the construction of  the  102nd Street cap, represented
     a  cost-efficient opportunity for dredging the  Little
                          4.

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          Niagara  River.   OCC has  recently  reached an agreement
          with the  City  by  which OCC will voluntarily extend its
          dredging  operations   for  the  102nd  Street  landfill
          remediation to include  the dredging of the  Little Niagara
          River sediments.   The  EPA and the  NYSDEC have approved
          the use of these sediments for fill in the construction
          of the landfill cap.

     F.-  Comment:

          A citizen asked if  the  increased cost of incineration was
          due at all to Occidental's  (OCC's) plan to  not pursue the
          siting of an incinerator,  meaning at OCC's nearby plant.

          Response:

          No final  decision had been made on the  source  of in-
          cineration for materials from the landfill.   Because of
          permitting issues, OCC is no longer pursuing the siting
          of an incinerator on OCC's plant property.  The current
          efforts by OCC to find  an alternative to the siting of an
          incinerator on  its  plant  property  will take additional
          time to effectuate.  The only currently available source
          (out-of-state)  for  incinerating  the  sediments  would be
          prohibitively expensive in comparison to the alternative
          of siting an  incinerator  at OCC's  plant.   The  original
          cost estimates for incineration of contaminated sediments.
          from  the landfill  were  based  upon the  siting of  an
          incinerator on OCC's plant property.

4.-  Summary of Written Comments Received During the Public Comment
     Period and the Responses of the EPA

     There was only one written comment, a letter from the Compa-
     nies, which was submitted during the  public comment period.
     The letter is summarized below.

          Letter dated January 25,  1995  from the Companies

          Comment:

          The Companies concurred with the EPA's recommendation to
          place the dredged sediments  under  the cap within  the
          slurry wall.  The Companies concurred since the incinera-
          tion of the sediments in their  opinion, would be extreme-
          ly cost-ineffective when consideration is given  to the
          fact that  the  mass  of contaminants  in   the  sediments
          represents a minute fraction of the contaminants at the
          Site, and the cost to incinerate these sediments would be
          extremely high.  In  addition,  there  is apparently  only
          one facility nationwide which  may be able to incinerate
          the sediments, but  it  has  severe capacity limitations.
          The Companies concluded that containment of the sediments
          within the slurry wall and under the cap  was the appro-
          priate course of action.
                               5.

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                     ROD AMENDMENT FACT  SHEET
SITE-
Name:
Location:

HRS Score:
NPL Rank:
EPA I.D. Number
102nd Street Landfill
Niagara County
Niagara Falls, New York
30.48
973
NYD980506810
ROD AMENDMENT-
Date signed:
Remedy:
Capital Cost:
O&M/Year:
P-W Cost:

LEAD-
PRPs:

Primary contact:
PRPs contacts:
WASTE-
Type:
Media:
Origins:
Est. Quantity:
June 9, 1995
Synthetic-lined  cap   (covering   approx.  24
acres),  consolidation  of  "off-site"  soils
beneath cap,  containment via a circumferential
slurry  wall,   dredging   and   consolidation
beneath the cap of the contaminated embayment
sediments, recovery  and  treatment  of ground
water,  incineration  of  any recovered  NAPL,
post-remedial    monitoring,    fence,    and
institutional controls.
$29,978,000.  (1994 dollars)
 $9,451,000.  (1994 dollars)
$39,429,000.  (1994 dollars)
Occidental Chemical Corporation (OCC)
and Olin Corporation (Olin)
Paul J. Olivo .(212)-637-4280
OCC: Alan F. Weston (716)-286-3607
Olin: David L'. Cummings  (615)-336-4549
industrial    landfill.  .   Waste    included
approximately   4,600    tons    of   benzene,
chlorobenzene,    ch1 oropheno1s     and
hexachlorocyclohexanes (HCCHs).
ground water, soils and river sediments
landfill dumping
159,000 tons of liquid and solid wastes.

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