United States
           Environmental Protection
           Agency
              Office of
              Emergency and
              Remedial Response
EPA/ROD/R02-90/140
September 1990
« EPA
Superfund
Record of Decision
           Hooker Chemical S-Area, NY

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60272-101
REPORT DOCUMENTATION 1. REPORT NO. 2.
PAGE EPA/ROD/R02-90/140
4. TO* and Subtitle
SUPERFUND RECORD OF DECISION
Hooker Chemical S-Area, NY
First Remedial Action - Final
7. Auttior(a)
8. Performing Organization Name Mid Addreaa
12. Sponaoring Orginlzitlon Name and Addraaa
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
a. Redpienfe Accaaaion No.
S. Report Date
09/21/90
6.
8. Performing Organization RepL No.
10. Protectrraak/Work Unit No.
11. ContractJC) or Grarrt(G) No.
(C)
<0)
13. Type of Raporl & Period Covered
800/000
14.
 15. Supplementary Note*
 16. Abatract (Limit: 200 worda)
   The Hooker Chemical S-Area site is a  former landfill area located in Niagara Falls,
   New York.  The  site lies adjacent to  the  Niagara River.  Approximately 63,000 tons of
   chemical processing wastes were disposed  of at the landfill.  Ground water beneath
   the site also has  been contaminated from  aqueous phase and non-aqueous phase liquid
   chemicals.  Chemicals have migrated toward the Niagara Falls Drinking Water Treatment
   Plant  (DWTP) which lies to the east of  the site, contaminating  the Bedrock intake
   structures.  This  Record of Decision  (ROD)  addresses the landfill,  a contaminated
   ground water plume,  bedrock contamination,  and the DWTP.  The primary contaminants of
   concern affecting  the soil, sediment, and ground water are VOCs  including PCE; and
   other organics  including chlorinated  organics and pesticides.

   The selected remedial action for this site includes abandoning  in place,  underground
   utility and service lines; closing and  capping onsite lagoons;  capping the landfill
   and surrounding area; constructing a  site barrier wall containment system; installing
   a drain tile collection system; pumping and treatment of ground  water and/or leachate
 •  from the landfill  area,  overburden, and bedrock using gravity separation to separate

   (See Attached Page)
                                                  NY
17. Document Analyaia a. Deacriptora
  Record of Decision - Hooker Chemical  S-Area,
  First Remedial  Action - Final
  Contaminated Media:   soil, sediment,  gw
  Key Contaminants:   VOCs (PCE), other  organics (chlorinated organics,  pesticides)
  b. Identifiera/Open-Ended Terma
   c. COSAT1 Field/Group
18. Availability Statement
19. Security Claaa (Thia Report)
None
20. Security Claaa (Thle Page)
None
21. No. ol Pagea
337
22. Price
(See ANS1-Z39.18)
                                     See Instruction* on Revene
                                                                           OPTIONAL FORM 272 (4-77)
                                                                           (Formerly NTIS-35)
                                                                           Department of Commerce

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EPA/ROD/R02-90/140
Hooker Chemical S-Area, NY
First Remedial Action - Final

Abstract  (Continued)

aqueous phase liquids  (APLs) from non-aqueous phase liquids  (NAPLs); treating APL at an
onsite carbon treatment facility with onsite discharge to a permitted outfall;  treating
NAPL and any associated sediment at an onsite incinerator; monitoring ground water;
closing and demolishing part of the adjacent drinking water treatment plant, and
constructing a new drinking water treatment facility at another location.  The present
worth cost for this remedial action is $117,000,000, which includes an annual O&M cost
of $2,600,000 for 30 years.

PERFORMANCE STANDARDS OR GOALS:  Action levels for bedrock ground water include PCE
5 ug/1 and 2,3,7,8-TCDD 0.0005 ug/1.  If these levels are exceeded, operational
modifications may be implemented.

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                         ROD FACT SHEET
SITE
Name:
Location/State:
EPA Region:
HRS Score  (date):
NPL Rank:
Hooker Chemical S-Area
Niagara Falls, New York
USEPA Region II
51.62; 9/83
177
ROD
Date  Signed:
Remedy/ies:
Capital Cost:
O & M/Year:
Present Worth:
RA; 09/21/90
Landfill; Barrier wall containment
system, drain tile collection system
and recovery wells, clay cap of
landfill, carbon adsorption
groundwater treatment, incineration of
non-aqueous phase chemicals at
Occidental Chemical Corporation's
Buffalo Avenue Plant
Water Treatment Plant: Construction of
a new drinking water treatment plant
at a new location
$ 25 Million (Landfill)
$2.6 Million annual (Landfill)
$ 50 Million (Landfill),  $ 67 Million
(City Drinking Water Treatment Plant)
LEAD
Remedial/Enforcement:
Primary Contact  (phone):

Secondary Contact  (phone)
FE
Mark-D. Purcell, Project Manager,
WNYCS-ERRD (212) 264-6282
Kevin Lynch,  Section Chief, WNYCS-
ERRD (212) 264-6194
WASTE
Type (metals/ PCB, &c) :
Medium (soil, g.w./ &c):
Origin:
Est. Quantity cu.yd.:
Volatile Organic Compounds, Pesticides
Soil and groundwater
Landfill (chemical processing waste)
63,000 tons

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         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                            REGION II
                        26 FEDERAL PLAZA
                    NEW YORK,  NEW YORK  10278
                      LETTER OF TRANSMITTAL
TO:
FROM:
                                          DATE:  April  10,  1991
          Irene Johnson
          USEPA - Headquarters
          401 M Street, Southwest
          Washington,  D.C.   20460
          Mark D. Purcell,  Project Manager
          New York/Caribbean Superfund Branch, Western New  York
          Section II
SUBJECT:  Consent Decree entitled "Stipulation  on Requisite
          Remedial Technology (RRT)  Program," for the Hooker
          Chemical S-Area Landfill,  Niagara  Falls, New York
                 Description
                                               Date
                                                        Copies
  1.  Stipulation on Requisite Remedial
     Technology (RRT)  Program
     Volumes I and II
                                              9/12/90

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                           VOLUME  I
              IN THE UNITED STATES DISTRICT COURT
              FOR THE WESTERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,              )
THE STATE OF NEW YORK,                 )

                   Plaintiffs,         )

              v.                       )     Civil Action No.
                                       )     79-988 (JTC)
OCCIDENTAL CHEMICAL CORPORATION and    )
THE CITY OF NIAGARA FALLS, NEW YORK,   )     (S-Area Landfill)

                   Defendants.         )
                         STIPULATION ON
          REQUISITEREMEDIAL TECHNOLOGY (RRT) PROGRAM
         STIPULATION

         APPENDIX I     -    S-AREA RRT REMEDIAL PLAN

         APPENDIX II    -    ENVIRONMENTAL HEALTH AND SAFETY

         APPENDIX III   -    CITY DRINKING WATER TREATMENT
                             PLANT REMEDIAL PROGRAM

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               IN THE UNITED STATES DISTRICT COURT
               FOR THE WESTERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
THE STATE OF NEW YORK,

                     Plaintiffs,
                V.
OCCIDENTAL CHEMICAL CORPORATION and
THE CITY OF NIAGARA FALLS, NEW YORK,

                     Defendants.
Civil Action No.
79-988 (JTC)

(S-Area Landfill)
                          STIPULATION ON
           REQUISITE REMEDIAL TECHNOLOGY (RRT) PROGRAM
                              8/16/90
                        DRAFT FOR SETTLEMENT
                      AND REVIEW PURPOSES ONLY
                         SUBJECT TO APPROVAL
                           BY EACH PARTY

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   I    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                             REGION I I
                          26 FEDERAL PLAZA
                      NEW YORK. NEW YORK  1O278
                    TO WHOM  IT MAY CONCERN

                        HOOKER S-AREA

The  attached  "Stipulation of Requisite Remedial Technology
Program"  (signed Sept. 12, 1990 by the Regional Administrator)
is for all technical purposes the equivalent of a Superfund
Record of Decision and should be so treated and entered into
the  RODS  System.

The  document  concerns the Hooker S-Area dump, listed on the
National  Priorities List, making it a Superfund site.  The
document  contains specific remedies, making it the functional
equivalent of a ROD. The document is the result of a negotiated
settlement that began before the enactment of CERCLA and was
therefore negotiated under RCRA, the Safe Drinking Water Act,
and  the Clean Water Act.  There has been public comment and
the  settlement also complies with all applicable and relevant
and  appropriate requirements. There is a proposed remedial
action plan (although it is not part of the attached document).
This document has been included in the CERCLIS system along
with all the other RODs.  This document takes the place of a
ROD and there will be no separate ROD published later.

Accordingly,  the attached document is submitted for inclusion
into the RODS system.
       Date                     /  Richard L. Caspe, P.E.
                               f*~ Director
                               t   Emergency and Remedial
                                  Response Division

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                                 CONTENTS
                                                            Page


A.  INCORPORATION OF RRT STIPULATION. . . .......       4

B.  MODIFICATION ..........  . .........       5

C.  COMMITMENT TO PERFORM REMEDIAL ACTIVITIES
     AND TO COMPLY WITH APPLICABLE LAW .........       7

D.  SCHEDULES .....................        7

E.  CITY DRINKING WATER TREATMENT PLANT .......  .        15

F.  REMEDIAL WASTE MANAGEMENT PLAN ...........       22

G.  ENVIRONMENTAL HEALTH AND SAFETY PLAN ........       30

H.  ENGINEERING AND CONSTRUCTION OVERSIGHT .......       30

I.  ASSESSMENT REPORTS .................       32

j.  CWTP IMPACTS ....................       36

K.  RETENTION OF RECORDS. . . ........ .....       36

L.  RESERVATION OF RIGHTS ................      39

M.  INDEMNIFICATION AND INSURANCE ...... ......      42

N.  NOTICES .............. .........      44

0.  PUBLIC PARTICIPATION ................      46

P..  EFFECTIVE DATE ............. ......      49

Q.  EXECUTION OF RRT STIPULATION ..........  .  .      49

                        LIST OF  APPENDICES

     APPENDIX I —  S-AREA RRT REMEDIAL PLAN

     APPENDIX II — ENVIRONMENTAL HEALTH AND SAFETY PLAN
                               -1-

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APPENDIX III -  CITY DRINKING WATER TREATMENT PLANT REMEDIAL
                PROGRAM

          ATTACHMENT A - PLAN A MILESTONE SCHEDULE
          ATTACHMENT B - CITY DRINKING WATER TREATMENTK
                         PLANT CLOSURE/REMEDIAL PLAN
          ATTACHMENT C - DRINKING WATER TREATMENT PLANT
                         CLOSURE/REMEDIAL PLAN
          ATTACHMENT D - CITY DRINKING WATER TREATMENT PLANT
                         PROJECT COST ESTIMATE

APPENDIX IV -  REMEDIAL WASTE MANAGEMENT PLAN

          ATTACHMENT A - REMEDIAL WASTE TREATMENT MILESTONE

APPENDIX V - OCC S-AREA PKOJECT SCHEDULE

APPENDIX VI - INSURANCE CERTIFICATE FORM
                         -11-

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     (1)  Whereas, the parties to this action are described and
set out in Paragraph 1 of the document captioned "Stipulation and
Judgment Approving Settlement Agreement" ("Judgment"), except
that Hooker Chemicals & Plastics Corp. is now called Occidental
Chemical Corporation ("OCC"), and that all named defendants other
than OCC and the City were dismissed in consideration of
Occidental Petroleum Corporation's agreement, pursuant to the
terms and conditions of Paragraph 12 of the Judgment, to execute
a guarantee, which was filed with the Court on or about August
13, 1985;
     (2)  Whereas, the signatory parties to this action — EPA,
the State, tho City, and OCC — agreed and stipulated that the
settlement agreement embodied in the Judgment should be entered
and, therefore, the signatory parties signed and lodged that
document with the Court on January 10, 1984;
     (3)  Whereas, the Court, after a hearing, concluded that the
Judgment provides for appropriate programs to protect against
endangerment to human health or the environment in and about the
S-Area Landfill Site ("Landfill Site"), and to protect the users
of the City of Niagara Falls' drinking water from endangerment,
see Judgment, at 1-2; and that the Judgment is fair, adequate,
and consistent with public policy, United States v. Hooker
Chemical & Plastics Corp.. 607 F.Supp. 1052, 1070  (W.D.N.Y.
1985);
                              - 2 -

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      (4)  Whereas, the Court approved and entered that Judgment
on April 15, 1985, and the Second Circuit affirmed the approval
and entry, 776 F.2d 410  (2d Cir. 1985);
      (5)  Whereas, the Judgment approved and entered by the Court
provided, among other things, that OCC and the City (where
appropriate) must implement containment, monitoring and
maintenance programs at and in the vicinity of the Landfill Site,
see Judgment f 6, at 8, and Addendum I $ A; Addendum II J A,
Addendum III J A; that OCC must conduct further surveys and
studies concerning the migration of chemicals into the
environment at and in the vicinity of the Landfill Site, see
Judgment, Addendum I J B(l)(a), at 1-1; and that, if chemicals
are identified migrating from the Landfill Site in areas not
addressed by the containment system, OCC must conduct and submit
to the Governmental Parties a study to determine what Requisite
Remedial Technology ("RRT"), if any, is required to address such
chemicals, see Judgment, f 4, at 6, and Addendum I 55 B(6), B(8),
at 1-8-9, 1-13;
      (6)  Whereas, on or about November 1, 1988, OCC submitted to
the Governmental Parties a document captioned "Requisite Remedial
Technology Study of Chemicals in the Overburden and Bedrock,
S-Area Landfill, S-Area Remedial Program";
      (7)  Whereas, on or about February 28, 1989, EPA/State and
the City submitted a response to OCC's RRT Study, and OCC
subsequently submitted a rejoinder to the governments' response;
                              - 3 -

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      (8)  Whereas, after lengthy and comprehensive negotiations
and technical discussions, the undersigned have determined that
OCC and the City will meet their respective obligations under the
Judgment by implementing the remedial, monitoring, and remedial
waste management programs and other activities described in the
addenda and appendices to the Judgment and the RRT Stipulation
(as defined below) and that these programs and other activities
are necessary and appropriate to protect human health and the
environment, and are consistent with the goals of the Judgment;
      (9)  Whereas, the RRT Stipulation (as defined below)
provides that the public have an opportunity to comment on the
programs and other activities specified herein during the notice
and comment period after this RRT Stipulation's lodging with the
Court and before the parties move the Court to approve and enter
the RRT Stipulation;
     NOW THEREFORE, IT IS STIPULATED, ADJUDGED, ORDERED, AND
DECREED as follows:
         a*
                                A.
                 INCORPORATION OF RRT STIPULATION
     1.  Upon its effective date, this document captioned
"Stipulation on Requisite Remedial Technology (RRT) Program"
("RRT Stipulation") shall be incorporated into, and become
enforceable as a part of, the Judgment in accordance with
Subparagraph B(9)(c) of Addendum I of the Judgment.  As used
herein, the term RRT Stipulation shall include this document and
the following appendices to this document and any attachments

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thereto:  S-Area RRT Remedial Plan (Appendix I); the
Environmental Health and Safety Plan (Appendix II); the City
Drinking Water Treatment Plant Remedial Program, including the
attached Plan A and Plan B Schedules and the Drinking Water
Treatment Plant Closure/Remedial Plan (Appendix III); the
Remedial Waste Management Plan (Appendix IV); the OCC S-Area
Project Schedule (Appendix V); and the Insurance Certificate Form
(Appendix VI).  All documents submitted to the Governmental
Parties and which are required to be approved by them pursuant to
the Judgment (including without limitation, any attachments,
plans, specifications, and protocols) shall also be incorporated
into and become enforceable as part of the Judgment upon
approval.
     2.  Unless otherwise specified herein, words and phrases
used in this RRT Stipulation shall be defined as they are in the
Judgment.  To the extent that the provisions of the Judgment are
explicitly inconsistent with this RRT Stipulation, the provisions
of the RRT Stipulation shall control and the Judgment shall be
deemed to be so modified or superseded.  Those provisions of the
Judgment not so modified or superseded remain in full force and
effect.
                               B.
                          MODIFICATION
     3.  (a)  Modifications to pages 1-36 of the Judgment, pages
1-49 of this RRT Stipulation or any non-technical sections of
future stipulations or modifications that materially alter the

                              - 5 -

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addenda or appendices to those documents shall be accomplished in
written form, either by agreement of OCC and the Governmental
Parties with the approval of the Court, or by order of the Court
upon the petition of any signatory party.  When agreement is
reached by the appropriate signatory parties, OCC shall promptly
file such written consent with the Court.
          (b)  Non-material modifications to addenda or
appendices shall be accomplished by written consent of the
Project Coordinators for OCC and the Governmental Parties.
Thereafter, OCC shall promptly file such written consent with the
Court.
          (c)  Modifications to any other documents approved by
the Governmental Parties, including plans, specifications and
protocols, shall be accomplished by written consent of the
Project Coordinators for OCC and the Governmental Parties.
During field activities such modifications may also be
accomplished by oral agreement of the field representatives of
OCC and the Governmental Parties, under the following
circumstances:
               (i)  where emergency conditions exist
               at the Project Site, or
               (ii)  where unexpected conditions are
               encountered at the Project Site and
               time is of the essence.
Such oral modifications shall be confirmed in writing by the OCC
Project Coordinator to all other Project Coordinators within
three (3) working days.  Such confirmations shall be deemed
                              - 6 -

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 consented to unless objected to by any Project Coordinator within
 five  (5) working days of receipt.  All modifications pursuant to
 this  subparagraph  (c) shall be consistent with the objectives and
 goals of the Judgment and good engineering practice.
          (d)  No  oral modifications of the Judgment shall be
 effective except as provided in subparagraph  (c) above.
          (e)  All modifications made pursuant to this Section
 shall be incorporated into and made enforceable as a part of the
 Judgment .
          (f)  Nothing in this Section shall be deemed to alter
 the Court's power  to supervise or modify the Judgment.

                                C.
            COMMITMENT TO PERFORM REMEDIAL ACTIVITIES
            AND TO COMPLY WITH APPIJCAPLE L*jW _
      4.  The Governmental Parties have determined that the
 activities required under this Judgment are consistent with
 applicable laws and regulations.  OCC and the City shall perform
 their respective activities required by the Judgment pursuant to
 the terms and conditions of the Judgment and in accordance with
 applicable Federal, State and local laws and regulations.
                                D.
     5. (a)  The OCC S-Area Project Schedule is attached hereto as
Appendix V.
                              - 7 -

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      (b)  The City Drinking Water Treatment Plant Plan A
Milestone Schedule ("Plan A Milestone Schedule") (as described in
Section E herein), containing milestone dates for the financing,
permitting, design, and construction of a proposed new City
Drinking Water Treatment Plant  ("CWTP11) is Attachment A to
Appendix III.  During the implementation of Plan A, EPA/State may
propose that additional Milestone dates be added to the Plan A
Milestone Schedule.  Such dates will be added either by agreement
of the EPA/State  and the City or by order of the Court.  All
documents to be submitted to the State for permits and other
authorization for the new CWTP shall also be submitted to EPA for
concurrent review and comment.  Additionally, documents
constituting the  Facilities Plan and Detailed Design plans and
specifications shall be submitted to EPA for concurrent review,
comment and approval as per this subparagraph.  EPA's approval of
the Facilities Plan and Detailed Design plans and specifications
shall be limited  to those systems and structures which, if
needed, are intended to prevent contamination of the City's
drinking water to a level of assurance equal to or greater than
the remedial programs for the existing CWTP as set forth in the
Judgment.  EPA shall, within 60 days of receipt of either the
Facilities Plan or the Detailed Design plans and specifications,
provide written comments, and/or approval or disapproval to all
signatory parties.  If the New York State Department of Health
has approved the  Facilities Plan or the Detailed Design plans and
specifications and EPA does not provide its comments, approval or

                              - 8 -

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disapproval for the document in question within such sixty (60)
day period, that document shall be deemed approved by EPA.  Any
disputes among the signatory parties concerning such EPA
comments, approval, or disapproval which cannot be promptly
resolved informally, will be submitted to the Court for
resolution.
      (c)  No later than 90 days after the lodging of this RRT
Stipulation with the Court, the City shall submit, for
informational purposes only, to the signatory parties a City
Drinking Water Treatment Plant Plan A Project Schedule ("Plan A
Project Schedule") detailing implementation dates for Plan A
which will be no later than the dates contained in the Plan A
Milestone Schedule.  Such schedule shall be provided to all
signatory parties but will not be subject to EPA/State approval
in this proceeding; provided, however, that EPA/State reserve any
right they may have to require approvals as part of their usual
regulatory functions outside this proceeding.
      (d)  The City Drinking Water Treatment Plant Plan B Bar
Sequencing Schedule ("Plan B Bar Sequencing Schedule") (described
in Section E herein), containing the sequencing of, and time
frames for, the implementation of Plan B, is Attachment B to
Appendix III.
      (e)  No later than sixty (60) days after a determination
either by agreement of the signatory parties or by order of the
Court that Plan B shall be implemented, pursuant to Paragraph 15
of Section E, the City and OCC shall jointly prepare and submit a

                              - 9 -

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City Drinking Water Plant Plan B Project Schedule ("Plan B
Project Schedule").  The implementation dates set forth in the
Plan B Project Schedule shall be consistent with the Plan B Bar
Sequencing Schedule, unless it is determined by agreement of the
signatory parties or by order of the Court that such consistency
would be inappropriate under specific circumstances.  Thereafter,
the parties shall proceed as provided in Paragraphs 6(c) and (d)
of the Judgment.  After the Plan B Project Schedule is adopted
either by agreement of the signatory parties or by order of the
Court, it shall be made an attachment to Appendix III and (if
adopted by agreement) filed with the Court.
     (f)  The Remedial Waste Treatment Milestone Schedule
("RWTMS") is Attachment A to Appendix IV.  If OCC and EPA/State
cannot resolve any dispute concerning OCC submissions or
EPA/State responses under the RWTMS within thirty (30) days, any
signatory party may seek Court resolution of any such disputes
which relate to compliance with the provisions of subparagraph
                                 •*
5(g).  If the Court decides that delay in meeting the RWTMS is
attributable to EPA/State's non-compliance with
subparagraph 5(g), then OCC's time for compliance with the RWTMS
may be extended in the Court's discretion, as appropriate.  If
the Court decides that delay in meeting the RWTMS is attributable
to OCC's non-compliance with subparagraph 5(g), then OCC may be
subject to any appropriate penalty or action under this Judgment,
in the Court's discretion, as appropriate, including the
possibility of providing additional storage capacity per

                              -  10  -

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subparagraph 20(d) to meet the starting date provided by the OCC
S-Area Project Schedule for operation of Phase II remedial
systems.  For purposes other than this Judgment, nothing herein
shall be construed to limit the authority or alter any legal
standard or time period of review regarding EPA/DEC processing of
OCC's incinerator permit applications, including but not limited
to the ability to require additional information or revised
submissions, and shall not limit or alter OCC's rights applicable
thereto.
     (g)  With respect to all the above schedules, OCC and the
City will use their best efforts to supply, in an expeditious
manner, complete permit applications and other submissions
required by this Judgment, including all information required by
EPA/State to process such permit applications and submissions.
In accordance with Paragraph 8(d) of the Judgment, EPA and the
State shall use their best efforts, consistent with their legal
authority, to expeditiously review and make timely final
determinations on permit applications and other submissions of
the City and OCC required by the.OCC S-Area Project Schedule, the
Plan B Project Schedule, the Plan A Milestone Schedule and the
Remedial Waste Treatment Milestone Schedule.  The signatory
parties will take all actions, consistent with their legal
authority, to assure compliance with the aforementioned
schedules.  To the extent that applicable statutory and
regulatory requirements and this Judgment provide the signatory
parties with discretion to act in a timely manner, such actions

                              -  11  -

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shall be undertaken in a manner which is consistent with the
aforementioned schedules; provided, however, that nothing herein
shall be construed to require any party hereto to act in a manner
which is arbitrary and capricious or otherwise unlawful.  If any
signatory party completes an activity required under the Judgment
on a date earlier than scheduled or otherwise required, the
parties shall use best efforts to correspondingly move up
subsequent activities under the Judgment dependent on such
completed activity, to the extent practicable, consistent with
the other activities on that schedule.  To the extent that the
Uniform Procedures Act, New York Environmental Conservation Law,
Article 70, is applicable to State permits required under this
Judgment, nothing herein shall alter the obligations of the New
York State Department of Environmental Conservation to meet the
requirements of that Act.
     6.(a)  Whenever OCC believes that revisions to the OCC
S-Area Project Schedule or its portion of the Plan B Project
Schedule should be made, OCC shall submit proposed revisions in
writing to the Governmental Parties for their respective review
and approval, as appropriate.  In proposing revisions to those
Project Schedules due to any delays, including failure to obtain
timely governmental authorizations and/or approvals, OCC shall
propose only an additional amount of time necessary to perform
the activities in a professional manner and pursuant to the terms
of the Judgment.  OCC's submission of proposed revisions shall be
accompanied by a report which fully explains why such revisions

                              -  12  -

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are necessary.  If OCC or any signatory party has already fully
advised EPA/State or the Court of a particular period of delay
pursuant to the terms of Paragraph 8(a) or 8(c), as appropriate,
of the Judgment, then OCC may cross-reference that submission.
Proposed schedule revisions pursuant to this subparagraph shall
be reviewed by the Governmental Parties pursuant to Paragraphs
6(c) and (d) of the Judgment.  Upon agreement of the Governmental
Parties and OCC or order of the Court, OCC shall promptly file
with the Court all revisions to the OCC S-Area or Plan B Project
Schedule, together with a complete explanation of the revisions.
Revisions to the RWTMS shall be addressed pursuant to
subparagraph 5(f) of this Section.
     (b)  Whenever the City believes that revisions to its
portion of the Plan B Project Schedule should be made, the City
shall submit proposed revisions in writing to the EPA/State for
their review and approval.  At such time, the City shall also
provjde copies of such proposed revisions tp OCC.  In proposing
revisions to those schedules due to any delays, including failure
to obtain timely governmental authorizations and/or approvals,
the City shall propose only an additional amount of time
necessary to perform the activities in a professional manner and
pursuant to the terms of the Judgment.  The City's submission of
proposed revisions shall be accompanied by a report which fully
explains why such revisions are necessary.  If the .City or any
signatory party has already fully advised EPA/State or the Court
of a particular period of delay pursuant to the terms of

                             - 13 -

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Paragraph 8(a) or 8(c), as appropriate, of the Judgment, then the
City may cross reference that submission.  Proposed schedule
revisions pursuant to this subparagraph shall be reviewed by
EPA/State pursuant to Paragraphs 6(c) and (d) of the Judgment and
Section E herein.  Upon agreement of the Governmental Parties and
OCC or order of the Court, the City shall promptly file with the
Court all revisions to its Plan B schedule, together with a
complete explanation of the revisions.  Proposed changes to
milestone dates in the Plan A Milestone Schedule shall be
addressed pursuant to Section E.
       (c)  Nothing in the Plan A or Plan B Schedules shall
affect the scheduling and implementation of any activities
required pursuant to the OCC S-Area Project Schedule; provided,
however, that advancing the scheduled date for the installation
of portions of the eastern Barrier Wall that cross service lines
to the CWTP shall be evaluated, if after installation of all
other portions of the Barrier Wall and the collection systems
adjacent to 53rd Street, response actions are triggered by the
monitoring criteria for NAPL presence and inward hydraulic
gradient set forth in subsection 2.3, Appendix I of the KRT
Stipulation.
     7.(a)  No later than March 15, 1991, and no later than March
15 of each succeeding year, OCC will submit to all other
signatory parties and the Court a complete report describing the
progress of its activities during the previous twelve (12) months
under the Judgment and this RRT Stipulation.

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      (b)   On such dates, the City shall also submit to all other
 signatory parties and  the  Court a complete report describing the
 progress  of its  activities during the previous twelve  (12) months
 under the Judgment and this  RRT Stipulation, including, without
 limitation,  its  progress under the Plan A Milestone Schedule.
      (c)   Any signatory party may submit to the Court its own
 progress  report  at such times as  it deems appropriate, and any
 signatory party  may submit a response to a progress report
 submitted pursuant to  this Section.
                                E.
               CITY DRINKING WATER TREATMENT PLANT
      8.   OCC and the City  will implement activities relating to
 the City  Drinking Water Treatment Plant (CWTP), as described in
 this  Section and in Appendix III.  As described below and in
 Appendix  III, this Program consists of the Interim CWTP
 Monitoring and Response Action Plan and a plan for either (a)
 construction of  a new  water  treatment plant and closure of the
 existing  CWTP ("Plan A"),  (b)  re-lining of the raw water intake
 system and other remedial  actions at the existing CWTP ("Plan
 B"),  or (c)  an alternative drinking water supply plan and closure
 of the existing  CWTP ("Plan  C").
      9.   Plan A  will be implemented to completion and no portion
 of either Plan B or C  will be implemented, unless and until a
determination is made  pursuant to Paragraph 15 of this Section
that either Plan B or  Plan C will be implemented.
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     10.  The obligations and responsibilities of the signatory

parties with respect to Plan A shall be as follows:

          (a)  The City shall construct and operate a
          new City Drinking Water Treatment Plant ("new -
          CWTP") on property located east of the
          existing CWTP.

          (b)  The City shall use its best efforts to
          initiate construction and "full-scale operation"
          of the new CWTP consistent with the requirements
          of the Plan A Milestone Schedule.  As used herein,
          "full-scale operation" is defined as the date
          upon which the new CWTP has received its Completed
          Works Approval from the New York State Department
          of Health.

          (c)  The City shall use its best efforts to make
          timely submission of applications and submissions,
          which it believes in good faith to be complete,
          relating to permits and other required governmental
          authorizations and approvals, consistent with the
          Plan A Milestone Schedule.

          (d) The City shall obtain and/or provide financing
          to build the new CWTP.

          (e)  OCC shall make payments to the City to help
          pay for construction of the new CWTP, in accordance
          with the provisions of a contemporaneous separate
          agreement between OCC and the City.

          (f)  Upon initiation of full-scale operation
          of the new CWTP or Plan C, as appropriate, OCC
          and the City, will implement the Drinking Water
          Treatment Plant Closure/Remedial Plan,
          Appendix III, Attachment C.  Any modification,
          reassessment, reduction, or termination of the
          plan's remedial systems or monitoring programs
          shall be made as provided in Sections 5.2 through
          5.5 of Appendix I.

     11.  Based on the fact that the Court is ordering Plan A to

be implemented pursuant to this RRT Stipulation, no environmental

impact statement and no other processing under the State

Environmental Quality Review Act, or any State or local
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regulations or enactments pursuant thereto, shall be required
regarding permits and authorizations or any other governmental
approval or action required for implementation of Plan A, or
regarding selection of the site for a new CWTP or associated
property transfers.
     12.  As used herein, "Plan B" will consist of the
implementation by OCC and the City of the remedial systems and
associated activities described in the following provisions of
the Judgment, as modified by Section 2.0 of Appendix III:
Paragraph E of Addendum I; Paragraphs C through I of Addendum II;
and Paragraphs C, D(l) and E of Addendum III.
     13.  The signatory parties have determined that the
implementation of either Plan A or Plan B, as set forth in the
Judgment, would be consistent with the goal of the Judgment to
protect the users of CWTP drinking water from endangerment.
     14.(a)  During the implementation of Plan A, the City shall,
or another signatory party may, promptly notify the other
                      *4>
signatory parties in writing in the event one of the following
circumstances occurs prior to the City's issuance of the notice
to proceed for the first major construction contract for the new
CWTP:
          (i)  A milestone date set forth in the Plan A
          Milestone Schedule is not met or facts exist
          which demonstrate a milestone date will
          not be met;
          (ii)  Facts exist which demonstrate that full
          scale operation of the new CWTP will be
          delayed for at least two years beyond the date
          for such operation set forth in the Plan A
          Milestone Schedule, Attachment A of Appendix III,
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           as  a result  of  "force majeure" or other cir-
           cumstances beyond the City's control;

           (iii)  Despite  the best efforts of the signatory
           parties, the City is not able to obtain real
           property rights, permits, or other authorizations
           required to  construct and operate the new CWTP;

           (iv)  Facts  exist vhich demonstrate that it is
           technically  infeasible to construct or initiate
           operation of the new CWTP substantially as
           designed; or

           (v)  The estimated cost for completing the project
           will be "unreasonably high" and, based on this cost
           estimate, the City has decided not to implement Plan
           A.  As used  herein, such costs may be deemed
           "unreasonably high" only if the product of (i) the
           estimated project costs for the new CWTP (in millions
           of  dollars)  and (ii) the estimated true interest cost
           (in percent) on fixed rate debt obligations to finance
           the project  exceeds the following:

           651 if contract award is to occur in 1992,

           678 if contract award is to occur in 1993, or

           705 if contract award is to occur in 1994 or
           thereafter.

           In  estimating the project cost and the true
           interest cost for the purpose of this sub-
           paragraph, the  same methodology shall be used
           as  was utilized by the City in calculating the
           June, 1990 estimates, Attachment D, Appendix III.
           In  that attachment the City estimated that the
           project cost is $67.8 million and the true interest
           cost is 8.0  percent; and the product of these
           parameters is 542 (67.8 x 8.0).

      (b)   Following the City's issuance of the notice to proceed

for the first major construction contract for the new CWTP, the

City will  finance and  implement the remaining portions of Plan A

to completion according to the Plan A Milestone Schedule and the

provisions of Paragraphs  14(a) and 15 shall be inapplicable;

except however, the events described in subparagraphs 14(a)(iii)


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 and 14(a)(iv)  shall continue to trigger notifications  and actions
 pursuant to Paragraphs 14  and 15 until  full  scale  operation of
 the new CWTP.
      15.   Within 30 days following notification  that any one of
 the circumstances set forth in Paragraph  14(a) has occurred,  the
 party providing the notice shall submit to the other signatory
 parties a complete written description  of the particular
 circumstances  and the basis upon which  the notification  was
 given.  If the signatory parties determine by agreement  that a
 subparagraph 14(a)  circumstance has occurred, but  nonetheless
 Plan A should  continue to  be implemented, the signatory  parties
 shall confirm  said agreement in writing and  make any appropriate
 revisions to the Plan A Milestone Schedule,  RRT  Stipulation,  and
 any other documents necessary to reflect  such agreement.
 Thereafter,  the City shall promptly file  such revisions  with the
 Court.  If the signatory parties determine by agreement  that a
 subparagraph 14(a)  circumstance has occurred and that  Plan A    ^
 should not continue to be  implemented,  the signatory parties
 shall confirm  said agreement in writing and  the  City shall
 promptly file  said agreement with the Court.  Thereafter,  Plan A
 shall be terminated and Plan B shall be implemented pursuant to
 Paragraph 5(e)  of this Stipulation, unless a Plan  C is
 implemented pursuant to the requirements  of  Paragraph  15(d).   If
 no  such determination by agreement among  the signatory parties
 can be reached,  any signatory party may,  within  30 days  following
.submission of  the aforementioned written  description of  the

                              - 19 -

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subparagraph 14(a) event, petition the Court for a determination

that Plan A should be terminated and that Plan B or Plan C should

be implemented.  It the petitioning party demonstrates to the

Court that any of the circumstances described in subparagraph

14(a) has occurred, the Court shall order that Plan A shall be

terminated and Plan B shall be implemented unless a signatory

party demonstrates to the Court that:

          (a)  with respect to an occurrence described in
          subparagraph 14 (a) (i) that:

               (i)  Despite failure to meet one of the
               milestone dates, the City will be able to
               meet the milestone date for initiation of
               full-scale operation of the new CWTP;

               (ii)  The city's failure to meet its
               milestone date was primarily the result
               of the failure of the EPA/State to use
               best efforts, consistent with subparagraph
               5(g), to make timely determinations on
               permits, authorizations and/or approvals;

               (iii)  The City's failure, despite its
               best efforts to meet its milestone date,
               was primarily the result of the failure
               to obtain approvals or authorizations
               from any party other than EPA/State and
               any resultant delay will be less than two years;
               or

               (iv)  There is good cause to extend the
               milestone dates for construction and
               initiation of full-scale operation for a
               period not to exceed two years; or

          (b)  Notwithstanding any occurrence described in
          subparagraphs 14(a)(ii);(iii) or (iv), there is good
          cause to proceed with the implementation of
          Plan A and such implementation shall not cause an
          unreasonably high project cost as defined in sub-
          paragraph 14(a)(v), unJess the City agrees to proceed
          despite such cost; or

          (c)  Notwithstanding the occurrence described
          in subparagraph 14(a)(v), there is good cause

                              - 20 -

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          to proceed with the implementation of Plan A
          and the City so agrees; or

          (d)  The City demonstrates, that subject to
          achievement of an agreement with OCC pursuant
          to paragraph 16, it is willing and able
          to promptly implement a Plan C to obtain
          its drinking water supplies from a source other
          than from the existing CWTP or the new CWTP
          described in Plan A and that Plan C is:

               (i)  Technically and financially feasible;

               (ii)  Capable of being implemented and
               meeting all the then-existing CWTP supply
               requirements within, substantially the
               same time frame as that remaining for
               completion of Plan A pursuant to the
               Plan A Milestone Schedule; and

               (iii)  Consistent with the goal of the
               Judgment to protect users of the CWTP
               drinking water from endangerment.

          In the event the City makes such a demon-
          stration pursuant to this subparagraph (d) and
          reaches an agreement with OCC, pursuant to
          paragraph 16, within thirty (30) days, OCC
          and the City shall not be required to implement
          Plan B, unless Plan C is not implemented as per
          paragraph 17, below.  If no such City/OCC agree-
          ment is reached within thirty (30) days. Plan B  ~
          shall be implemented pursuant to Appendix III,
          unless the City demonstrates to the Court that
          despite not having reached an agreement with OCC,
          Plan C will be implemented as per the time
          requirements of subparagraph 15(d)(ii).

     15.  OCC shall have no obligation with respect to Plan C,

other than its obligations under the CWTP Closure/Remedial Plan,

unless it enters into a separate agreement with the City, which

sets forth specific obligations with regard to Plan C.  Any

disputes arising regarding the achievement, interpretation or

implementation of such agreement which OCC and the City cannot

promptly resolve .informally will be submitted to the Court for


                              -  21 -

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resolution.  Any such agreement shall not affect the obligations
of the City and OCC, as appropriate, under this Judgment.
EPA/State shall have no financial obligations with regard to Plan
C; provided, however, that this provision will not be construed
to affect the City's eligibility for any otherwise-available
State or federal assistance.
     17.  If the Court determines pursuant to Paragraph 15(d)
that Plan C shall be implemented and if an agreement pursuant to
Paragraph 16 between OCC and the City has been achieved, the city
shall promptly implement such plan in accordance with the Court's
order.
     18.  The Interim CWTP Monitoring and Response Plan set forth
in Appendix III, Section 3.0 will be undertaken until either (a)
the initiation of full-scale operation described in Plan A;  (b)
the installation and initial operation of remedial systems
described in Plan B; or (c) the provision of a satisfactory
drinking water supply pursuant to Plan C, whichever first occurs.
           •V •

                                F.
                  REMEDIAL WASTE MANAGEMENT PLAN
     19.  (a)  All solid, semi-solid, and liquid waste generated
as a result of programs and activities described in the Judgment
shall be managed as described therein, as modified by the RRT
Stipulation and Appendix IV and in accordance with the Remedial
Waste Treatment Milestone Schedule attached thereto.
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          (b)  Except as provided herein below and in
Paragraph 20, OCC shall initiate operation of remedial systems as
provided in the OCC S-Area Project Schedule.  However, nothing in
the Judgment shall be construed to require OCC to:
          (i)  install or operate remedial systems
          which generate solid or semi-solid wastes
          until a waste cell(s) at the Landfill Site,
          as described in Appendix IV, has been
          constructed by OCC and approved by EPA/State
          to accept such wastes;
          (ii)  conduct Phase I remedial activities
          described in Section 4.3 of Appendix I until
          the APL/NAPL Storage Facility described in
          Appendix IV has been constructed and has
          received written governmental authorization
          to accept liquid wastes;
          (iii)  operate remedial systems which
          generate liquid wastes until (a) the APL/NAPL
          Storage Facility has been constructed and has
          received written governmental authorization
          to accept such wastes, and (b) the APL
          Carbon Treatment Facility has been
          constructed by OCC per approvals by EPA/State
          and authorized by the appropriate parties, at
          that time, to discharge effluent from the
          facility.  (Nothing herein modifies any EPA

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          authority to regulate such discharge to the
          City waste water treatment plant under U.S.
          v. Citv of Niagara Falls. Civ. No. 81-
                                       \
          363 (C».
     20.  The starting operation date for the remedial systems
which generate NAPL (other than Phase I activities described in
Section 4.3, Appendix I) shall be governed by the OCC S-Area
Project Schedule and by the determinations, activities, and
conditions relating to the storage and treatment of NAPL as set
forth in this Paragraph.
          (a)  OCC's existing incinerator at its Niagara Plant
("OCC Liquids Incinerator") is currently permitted to incinerate
certain process and remedial hazardous liquid wastes.  OCC has
also applied for governmental authorizations to construct and
operate a thermal destruction unit at its Niagara Plant ("OCC
Solids Incinerator") to incinerate hazardous solid wastes
generated at OCC-associated remedial sites in Western New York.
OCC shall submit revised applications for permit modifications to
allow incineration of liquid remedial wastes, including S-Area
NAPL, at the OCC Solids Incinerator in accordance with RWTMS
Schedule C.  If these incinerators are determined, separately or
in combination, to have sufficient capacity and be capable of
incinerating NAPL generated by activities under the Judgment in
accordance with all applicable permitting requirements designed
to protect human health and the environment, EPA and the State
have agreed with OCC that these incinerators will be the

                              -  24  -

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preferred facilities for the incineration of NAPL generated by
activities under this Judgment; provided, however, as follows:
          (i)  The foregoing preference shall not be
          construed to limit or delay OCC's obligations
          described in subparagraphs (b) or (c)  below
          or to preclude utilization of available
          capacity at permitted facilities described in
          subparagraph (c)  for the incineration of NAPL
          generated by activities under the Judgment,
          if, separately or in combination, the OCC
          Liquids Incinerator and/or the OCC Solids
          Incinerator are unavailable to accept NAPL
          from the remedial system as provided in the
          OCC S-Area Project Schedule;
          (ii)  The foregoing preference shall be
          terminated if, following either the
          assessment described in subparagraph (b)
          =«
          below or the EPA/DEC determination on OCC's
          application for approval to incinerate S-Area
          NAPL (Item A5 of the RWTMS) it is determined
          that, separately or in combination, the OCC
          Liquids Incinerator and/or the OCC Solids
          Incinerator do not have technical capability
          or sufficient capacity to incinerate NAPL in
          accordance with applicable permitting
          requirements;

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          (ill)  Termination of the preference
          described in subparagraph (ii) shall not be
          construed to limit or delay the obligations
          of any party under Paragraph 5(g).
          (b)  Within 90 days following completion of the Phase I
pump tests as provided by the OCC S-Area Project Schedule, OCC
shall submit to EPA/State an assessment report described in this
subparagraph.  The purpose of this assessment is to evaluate
whether there will be sufficient incineration capacity authorized
by permit and, if such capacity is not available by the date for
initiation of operation of Phase II remedial systems provided by
the OCC S-Area Project Schedule, when and by what means OCC will
obtain sufficient capacity to treat NAPL to be generated by
activities under the Judgment.  Such assessment shall also
consider, among other things, the characterization and the
projected volumes of NAPL to be generated by remedial systems
installed under the Judgment and by other sources of liquid
remedial waste which OCC plans to incinerate; and the permitted
projected capacity of the OCC Liquids Incinerator, the OCC Solids
Incinerator and permitted storage facilities .to treat or store
NAPL to be generated by activities under the Judgment.  If this
assessment indicates that, separately or in combination, OCC's
Liquids Incinerator and/or OCC's Solids Incinerator will not be
available or will not have sufficient capacity for treating
S-Area NAPL generated by activities under the Judgment by the
scheduled start of operation of remedial systems that will

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generate NAPL, OCC shall/ by the scheduled start date, have
available 316,000 gallons of NAPL storage (inclusive of NAPL
storage provided pursuant to Section 4.4.6(a) of Appendix IV) to
allow for start-up of the Phase II remedial system.
     (c)  If it is determined (either under the subparagraph (b)
assessment or under Item A5 of the RWTMS) by agreement of OCC and
EPA/State or by order of the Court that there will not be
sufficient permitted incineration capacity to accommodate NAPL
generated by activities under the Judgment within six months
after scheduled initial remedial system operation start-up, or
within the period of time for which there will be available NAPL
storage capacity, whichever is longer, OCC shall proceed as
described in this subparagraph (c).  OCC will conduct an
assessment which evaluates obtaining NAPL treatment capacity from
among the following alternatives:
     (i)  a commercial incinerator permitted by EPA and the
          State;
     (ii) an on-site mobile incinerator able to be permitted or
          authorized by EPA and the State; or
     (iii) on-site pre-treatment and subsequent incineration at
          an incinerator permitted or authorized by the State.
                                          M t
     As part of that assessment, OCC shall also include
evaluation of the following:
     (i)  Subject to subparagraph (d) below, installation of
          additional storage capacity.
                              -  27  -

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     (ii) Deferral of scheduled start-up of remedial system
          operations or start-up of remedial system operations
          under modified conditions (including modified
          performance monitoring criteria).
    (iii) Some combination of the five alternatives set forth
          above.
The assessment report shall be submitted to EPA/State within 90
days after the aforementioned determination.  The report shall
include proposed milestone dates for obtaining sufficient NAPL
treatment capacity from the alternative(s) recommended in the
assessment.  Upon EPA/State approval of the assessment report,
the RWTMS Schedule D shall be amended to include milestone dates
to implement such alternative(s).  Once the RWTMS is amended
pursuant to this subparagraph, OCC shall proceed with best
efforts to expeditiously obtain sufficient treatment capacity,
pursuing those alternatives set forth in subparagraphs (a) and
(c) on parallel paths according to the schedules for those
alternatives under the RWTMS unless otherwise agreed to by
EPA/State or ordered by the Court.
     (d)   If it is determined by agreement of EPA/State and OCC
or by order of the Court that NAPL storage capacity beyond
316,000 gallons installed pursuant to subparagraph (b) is
reasonable and necessary to satisfy the goals of the Judgment,
the total combined APL/NAPL storage capacity will be increased to
a maximum of 948,000 gallons.  In installing APL/NAPL storage up
to 948,000 gallons, OCC shall also reevaluate the APL Treatment

                              - 28 -

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 Facility operational needs and the APL storage installed pursuant
 to Section 4.4.6(a) of Appendix IV.  Based on that evaluation,
 the amount of APL storage may be reduced or increased, as
 appropriate.  Additional APL/NAPL storage capacity, beyond
 948,000  gallons, may be ordered by the Court, in its discretion,
 only if  it determines that delays in the RWTMS were the result of
 OCC's unjustified non-compliance with its obligations under
 Paragraph 5(g) and the RWTMS.  Likewise, if the Court determines
 that NAPL treatment capacity is unavailable and that
 unavailability is the result of EPA/State's unjustified non-
 compliance with its obligations under paragraph 5(g) and the
 RWTMS, the scheduled date for initial remedial system operations
 may be extended by such time period as the Court deems
 appropriate, in its discretion.
     (e)  If, following submission of the assessment reports
 described in subparagraphs (b) and (c) and the resolution of all
 issues relating thereto, it is determined, by agreement of OCC
 and EPA/State or by order of the Court, that none of the
 alternatives set forth in subparagraphs (a) and (c) can or will
be implemented by December 31, 1995, OCC shall submit to
EPA/State an assessment described in this subparagraph.  This
assessment will include an evaluation of the availability of
permitted incineration, its performance equivalent, and treatment
facilities other than those described in subparagraph (c) and the
installation of additional storage capacity notwithstanding the
limitation described in subparagraph (d).  OCC's assessment

                             - 29 -

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report shall be submitted within 90 days following the
aforementioned determination.  The appropriate action to be taken
thereafter will be determined by agreement of EPA/State and OCC
or order of the Court and shall be consistent with the goals of
the Judgment.
                                G.
               ENVIRONMENTAL HEALTH AND SAFETY PLAN
     21.  The Environmental Health and Safety Plan set forth in
Addendum V of the Judgment shall be applicable to activities
(other than Plan A; Plan C; and activities on the Eastern Portion
of the Treatment Plant, as defined in Appendix III, Section 4.0)
undertaken pursuant to the Judgment,  except as modified pursuant
to Appendix II of this RRT Stipulation.

                                H.
              ENGINEERING AND CONSTRUCTION OVERSIGHT
     22.  All the design and construction work to be performed by
OCC under the Judgment shall be under the direction and
supervision of a qualified professional engineer licensed and
currently registered to practice in the State of New York.
Within 30 days of the lodging of this RRT Stipulation, OCC shall
notify the Governmental Parties in writing of the name, title,
and qualifications of the engineer who will be responsible for
directing or supervising such work.  EPA/State, by written notice
to OCC, may disapprove any such engineer based upon professional
qualifications and other reasonable and appropriate criteria.

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EPA/State's approval shall not be unreasonably withheld.  Nothing
in this Section shall preclude OCC from hiring a field manager,
who does not meet the above engineering requirements, provided
that the field manager is otherwise qualified and is under the
direction and supervision of a qualified engineer who meets the
licensing and registration requirements of this Paragraph.  At
least 30 days prior to the commencement of remedial system
construction activity, OCC shall provide the name and
qualifications of OCC's selected field manager.
     23.  At least 30 days prior to the commencement of each
construction activity identified on the OCC S-Area Project
Schedule, OCC shall notify the Governmental Parties, in writing,
of the name and qualifications of any civil, mechanical or well
drilling contractor who has been retained to perform or
participate in any portion of such work.  EPA/State, by written
notice to OCC, may disapprove any such contractor(s) based upon
professional qualifications and other reasonable and appropriate
criteria.  EPA/State's approval shall not be unreasonably
withheld.
     24.  Except if previously set forth in the OCC S-Area
Project Schedule, OCC shall give the Governmental Parties at
least 14 days advance notice of all field activities (including,
without limitation, sampling activities, but not including
routine operational and maintenance activities) to be performed
pursuant to the Judgment.  If it is not possible for OCC to give
at least 14 days advance notice, OCC shall provide written

                              -  31  -

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notice to the Governmental Parties on the earliest working day
possible.
     25.  OCC shall, following the installation of each remedial
system described in the Judgment, provide the Governmental
Parties with a certification from a licensed professional
engineer currently registered to practice in the State of New
York that the system was installed in conformance with the plans
and specifications and any approved revisions for that work.
                                I.
                       ASSESSMENT  REPORTS
     26.  Whenever the Judgment requires OCC to assess a
situation or condition (other than a study conducted pursuant to
Paragraph B(8), Addendum I of the Judgment) or conduct a focused
feasibility study, OCC shall submit an assessment report pursuant
to the provisions of Paragraphs 27 through 32 of this RRT
Stipulation unless otherwise specified in Appendix I or Appendix
III.
     27.  Each assessment report shall be prepared in accordance
with appropriate professional standards and shall include,
without limitation, the following:
          (a)  a title sheet and a table of contents;
          (b)  a complete statement of why the assessment
               report is required,  including a clear statement
               of the problem addressed;
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(c)  a complete discussion of how the assessment
     was performed, including assumptions made and the
     technical and computational methods and procedures
     used for all assessments;
(d)  all data used in the assessment and an
     explanation of how the data was collected; or,
     in the alternative, reference to the data .if
     that data was previously provided;
(e)  a description and evaluation of all action (s.)
     analyzed;
(f)  all conclusions drawn by the assessment;
(g)  a recommendation for actions, if any, to be
     taken;
(h)  a complete discussion of the basis for OCC's
     recommendation;
(ij  estimated implementation costs of any action(s)
     (including no-action alternatives) recommended
     in the assessment report; and
(j)  an implementation schedule for all recommended
     actions.
(k)  an assessment report for a focused feasibility
     study shall evaluate all applicable alternatives
     utilizing the same criteria used to evaluate the
     recommended alternative and shall report such
     evaluation in a fashion that allows for a full
     comparison between alternatives.

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     28.  Unless submission of an assessment report is otherwise
scheduled, or unless notification is first provided by the
Governmental Parties/ OCC shall notify the Governmental Parties
in writing within 7 days after determining that an assessment
report is required by the Judgment.  OCC shall complete and
submit an assessment report to the Governmental Parties within 30
days after such notification, unless otherwise specified.
     29.  The Governmental Parties shall review each submitted
assessment report and, within 30 days, notify OCC in writing of
its agreement or disagreement with the assessment or the
assessment report.  In the case of disagreement, the Governmental
Parties will provide the basis for that disagreement -- including
a complete statement of the disagreement, assumptions made, data
used, analyses performed, and conclusions drawn — and, in the
discretion of the Governmental Parties, may provide a
recommendation for action by OCC.
     30.  If the Governmental Parties notify OCC either that the
                                                    •*
assessment or the assessment report is incomplete or otherwise
fails to comply with this Section, or that the Governmental
Parties disagree with the report's conclusions, OCC shall revise
the assessment report to address the Governmental Parties'
concerns and recommendations and shall resubmit the report,
within 21 days of receipt of the Governmental Parties' response.
In the alternative, OCC may, by the required resubmittal date,
petition the Court to resolve the dispute.
                              - 34 -

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   •  31.  Upon receiving OCC's revised assessment report/ the
Governmental Parties shall within 30 days of receipt of OCC's
revised assessment report, notify OCC in writing of their
position regarding the revised report.  If the Governmental
Parties do not approve the revised assessment report the
Governmental Parties will provide a recommendation for what is
required to address their concerns and a complete discussion of
the basis for their recommendations.  If the Governmental Parties
do not approve the revised report (or portions of the revised
report), OCC shall promptly implement the Governmental Parties'
recommendation unless, within 14 days following receipt of the
Governmental Parties' response to the resubmitted report, OCC
petitions the Court to resolve the dispute.
     32.  Prior to the submittal of any assessment report or
during any review period any signatory party may request that
informal meetings or negotiations be held within the specified
time frames.  Furthermore, the time frames for submittals, review
                                      •w
and approval specified in this Section may be extended by
agreement of OCC and the Governmental Parties or order of the
Court, for good cause shown.
                              -  35  -

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                              J.
                           CWTP IMPACTS
     33.  Whenever the Judgment requires OCC to:
          (a) conduct an assessment or focused feasibility study
of Operational Modifications, System Modifications and
supplements, Monitoring Program Reassessments and Modifications,
System Operation Reductions, or Terminations; or
          (b) conduct an RRT Study or focused RRT Study;
the impact of any alternative actions analyzed upon the existing
CWTP remedial systems, structures, underground pipelines or
utilities shall be included in the assessment.  If the existing
CWTP remedial systems, structures, underground pipelines or
utilities may be adversely affected by the proposed actions
pursuant to such assessment study, OCC shall include in its
assessment an evaluation of measures designed to eliminate or to
mitigate, as appropriate, such impacts.  The Governmental Parties
shall consider these impacts and any proposed measures in their
review and approval process for any proposed actions.
                                K.
                       RETENTION OF RECORDS
     34.  (a)  Except as provided in subparagraphs (b) or (c)
below, following the lodging of this RRT Stipulation, each
signatory party shall keep, as "Retained Records," all data,
records, documents and information of any kind which are in, or
                              - 36 -

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which nay cone into, its possession or control and which provide
information on or relate to:
               (i)  the disposal or presence of chemicals
                    in, or the migration of chemicals at or
                    from, the Landfill Site;
               (ii) any analysis or evaluation of actual
                    or potential health or environmental
                    impacts due to the disposal, presence,
                    or migration of chemicals at or from
                    the Landfill Site;
              (iii)  geology, hydrogeology, remediation, or
                    regulation of the Landfill Site, and
               (iv) any activity in the Area of Concern (AOC)
                    required under the Judgment,
regardless of any document retention policy to the contrary.  As
used herein, Retained Records shall include, without limitation,
originals, and duplicate copies with informational marks or.
notations or microfiche or microfilm of originals, whether
privileged or non-privileged.  A party shall, upon written
request of any other signatory party, make available for
inspection and copying any non-privileged Retained Records and
identify privileged Retained Records, as per subparagraph (d) of
this Section, within fourteen (14) days of such request, except
where the party with Retained Records is otherwise specifically
required to provide such material under other provisions of the
Judgment.
                              -  37  -

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           (b)  A party nay at any tine destroy Retained Records
which have been photocopied, microfilmed, microfiched or
duplicated using equivalent techniques provided that ninety (90)
days prior notice is given to all other signatory parties and
that upon request such parties are afforded the opportunity to
take custody of any non-privileged Retained Records proposed for
such destruction, and all privileged Retained Records proposed
for destruction have been identified as per subparagraph (d) of
this Section.
           (c)  A party may, after May 1, 2000, destroy Retained
Records which are at least ten (10) years old provided that at
least ninety (90) days prior notice is given to all signatory
parties and that upon request such parties are afforded the
opportunity to take custody of such non-privileged Retained
Records; and all privileged Retained Records proposed for
destruction have been identified as per subparagraph (d) of this
Section.  If such Retained Records consist of OCC's "as-built"
drawings of remedial systems described in the Judgment, OCC shall
submit such drawings to EPA without a request having been made.
           (d)  Any signatory party shall have the right to
contest the validity of any other party's assertion that certain
Retained Records are privileged.  The party claiming a privilege
shall produce, upon request of another signatory party, a list of
such Retained Records with sufficient information about those
records to permit an evaluation of the validity of the assertion
of privilege.

                              -  38  -

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                                L.
                    RESERVATION OF RIGHTS
     35.  The signatory parties hereto acknowledge that OCC is
undertaking certain surveys and investigations regarding chemical
migration from areas of its Niagara Falls Buffalo Avenue Plant,
(separate from the surveys and investigation undertaken for the
Landfill Site) pursuant to the requirements contained in permits
issued by EPA and the State and pursuant to a stipulation
approved by this Court in the State of New York and Henry G.
Williams. Commissioner of Environmental Conservation of the State
of New York v. Occidental Chemical Corporation, et al.. Civil
Action No. 83-1393.  OCC is also required to take appropriate
remedial action, in response to such chemical migration.
EPA/State reserve all rights in the aforementioned proceedings to
require that any identified plumes from the Landfill Site not
addressed by remedial systems under this Judgment which commingle
with Buffalo Avenue Plant Site plumes be addressed in conjunction
with those Plant Site plumes under the Buffalo Avenue Plant Site
remedial programs, as appropriate.  Furthermore, EPA/State
reserve all rights in the aforementioned proceedings to require
that Buffalo Avenue Plant Site remedial programs, otherwise
installed pursuant to those proceedings, be operated in a manner
which address chemicals migrating in an identified plume from the
Landfill Site where such action is Requisite, as defined in
Paragraph 4 of the Judgment, or where such migration triggers

                              -  39  -

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response actions developed to address Buffalo Avenue Plant Site
plumes.
     36.  Similarly, nothing herein is intended to preclude the
signatory parties from assessing the effectiveness of remedies
implemented under the Buffalo Avenue Plant Site remedial programs
in meeting the goals of the Judgment and the objectives of the
remedial systems implemented at the Landfill Site pursuant to
this RRT Stipulation, or from petitioning this Court to modify
the Judgment/ in accordance with applicable lav, based on the
results of any such assessment.  If OCC proposes such a
modification to the Court, it shall first prepare an assessment
report for the Governmental Parties pursuant to Section I of this
RRT Stipulation.  OCC may not move to modify the Judgment
pursuant to this Section until:
          (i)  the Site Containment System and RRT
          Overburden Containment System as set forth
          in Appendix I, Section 2.0 have been installed
          and are operating, and
          (ii)  the Bedrock System (including the Prototype
          and/or Bedrock RRT System) described in the
          Judgment has been installed and operating for
          at least ten (10) years after initial operation
          of the Prototype System.
     37.(a)   EPA/State have determined that any presently known
or reasonably anticipated conditions which are associated with
chemicals that have migrated from the Landfill Site into the

                              - 40 -

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Bedrock beneath the Niagara River will be addressed by the
remedial programs, associated response actions, monitoring
programs, assessments and studies described in the Judgment.  If
new data or information reveal conditions associated with these
chemicals which have migrated into the Bedrock beneath the
Niagara River which are not presently known or could reasonably
be anticipated by EPA/State, and if those conditions are not
adequately addressed pursuant to the Judgment, EPA/State reserves
its rights under Paragraph ll(c)(i) of the Judgment to seek
appropriate relief, including requiring OCC to study and/or
remediate such conditions.
          (b)  This subparagraph (b) is subject to the provisions
of subparagraph (a), including specifically, but not limited to,
the EPA/State reservation of rights under Paragraph ll(c)(i) of
the Judgment.  Implementation of all the requirements and
activities of the Judgment and the RRT Stipulation shall satisfy
OCC's obligations under Paragraphs B(6)(a) and (b) of Addendum I
of the Judgment.  Except as provided in subparagraphs E(9)-(14),
Addendum I of the Judgment and in the Drinking Water Treatment
Plant Remedial/Closure Plan (see RRT Stipulation, Appendix III,
Attachment C), OCC shall not be required pursuant to this
Judgment (including the RRT Stipulation) to install wells, take
samples, or conduct surveys in the Bedrock beneath the Niagara
River.  Any RRT study, associated actions, or operational or
system modifications which may be required pursuant to the plans
and programs described in the Judgment shall not include

                              -  41  -

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technologies which require installation in or beneath the Niagara
River, or which address the issues described in subparagraph
(7)(a) of Addendum I of the Judgment.
     38.  All signatory parties reserve their rights to assert
any rights or make any arguments that otherwise may be available
to  them prior to the date on which this RRT Stipulation is signed
by  the parties; provided/ however, nothing herein shall modify
any explicit waiver, discharge, or release set forth in the
Judgment approved by the Court in 1985, including but not limited
to, those set forth in Paragraphs 3(b) and 11 of that Judgment.
     39.  To the extent that any signatory party reserves rights
pursuant to this Section, all other signatory parties reserve all
rights and defenses relating thereto.

                                M.
                  INDEMNIFICATION AND INSURANCE
     40.  OCC agrees to defend, indemnify and hold harmless the
United States and the State (including their officers, agents,
employees, contractors and subcontractors or representatives) for
any and all claims and causes of action asserted against the
United States or the State, arising from or on account of
tortious acts or omissions of OCC, its officers, directors,
employees, contractors, subcontractors or any persons acting on
its behalf or under its control in carrying out activities
pursuant to the Judgment.  OCC shall not hold out the United
States or the State as a party to any contract entered into by or

                              - 42  -

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on behalf of OCC in carrying out obligations pursuant to this
Judgment.  OCC shall not be considered an agent of the United
States or the State for any purpose under the Judgment.
     41.  OCC waives, and agrees to defend, indemnify and hold
harmless the United States and the State, in respect to any
claims for damages or reimbursement from the United States or the
State (or for set-off of any payments made or to be made to the
United States or the State) arising from any agreement or
arrangement between OCC and another party arising out of OCC's
obligations under the Judgment, including but not limited to
claims arising out of construction delays.
     42.  Within 20 days after the effective date of this RRT
Stipulation and thereafter so long as activities under the
Judgment require, OCC shall name the United States and the State
as additional insureds on OCC policies for comprehensive general
liability and automobile insurance which are applicable to OCC
activities in Western New York.  Such policies shall contain
liability limits no less than those specified on the Insurance
Certificate Form (Appendix VI).  Within 30 days after the
effective date of this RRT Stipulation, OCC shall submit to
EPA/State a certificate of such insurance.  OCC shall resubmit to
EPA/State such a certificate if the previously submitted
certificate becomes inoperative.  In addition, for so long as
activities under the Judgment require, OCC shall require that its
contractors and subcontractors satisfy all applicable laws
regarding provision of workers compensation insurance for all

                              -  43  -

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persons performing activities on behalf of OCC in furtherance of
this Judgment.
                               N.
                             NOTICES
     43.  Written notices, reports or other documents referenced
in the Judgment shall be sent to the following individuals at the
addresses specified below (unless those individuals or their
designated successors give written notice of a change of
identities or addresses to the other signatory parties) where
such documents (a) are required to be submitted to the Court or
to the signatory parties pursuant to the Judgment; (b) relate to
modifications or proposed modifications to the Judgment described
in Paragraph 3(a) and written confirmations pursuant to 3(c)
supra; (c) provide notice of delays in the performance of work
required under the Judgment; or (d) relate to disputes under the
Judgment which are under discussion by counsel for the parties or
under consideration by the Court.  All other written notices,
       ««
reports, and other documents referenced in the Judgment may be
forwarded only to the Project Coordinators at the addresses set
forth below, and, in those instances, the Project Coordinators
will take responsibility for assuring that all such documents are
appropriately disseminated.
                              - 44  -

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          a.  As to -the United States;

1 copy:       Chief, New York/Caribbean Superfund Branch
              Office of Regional Counsel
              U.S. Environmental Protection Agency, Region II
              26 Federal Plaza, Room 437
              New York, N.Y. 10278
               Attention:  S-Area Attorney

5 copies:     Chief, New York/Caribbean Compliance Branch
              Emergency and Remedial Response Division
              U.S. Environmental Protection Agency, Region II
              26 Federal Plaza, Room 747
              New York, New York 10278
               Attention S-Area Site Project Coordinator

1 copy:       Chief, Special Litigation Branch
              Office of Enforcement-Superfund (LE-134S)
              U.S. Environmental Protection Agency
              401 M Street, S.W.
              Washington, D.C. 20460
               Attention:  S-Area Attorney

          b.  As to the State;

4 copies:     Director
              Bureau of Western Remedial Action
              Department of Environmental Conservation
              50 Wolf Road
              Albany, New York 12233
               Attention:  S-Area Site Project Coordinator

2 copies:     Director
              Bureau of Environmental Exposure Investigation
              New York State Department of Health
              2 University Place
              Albany, New York 12203

1 copy:       New York State Department of Law
              Environmental Protection Bureau
              120 Broadway
              New York, New York 10271
               Attention:  S-Area Attorney
                              -  45  -

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          c.  As to OCC;

5 copies:     Mr. John Nichter
              S-Area Project Coordinator
              Special Environmental Programs
              Occidental Chemical Center
              360 Rainbow Boulevard South
              P.O. Box 728
              Niagara Falls, New York 14302

1 copy:       J. Alan Mack, Esquire
              Associate General Counsel
              Occidental Chemical Corporation
              5005 T-R-T Freeway
              Dallas, Texas 75244

          d.  As to the City;

3 copies:     Mr. John R. Westendorf
              S-Area Project Coordinator
              City of Niagara Falls Water Treatment Plant
              53rd Street & Buffalo Ave.
              P.O. Box 69
              Niagara Falls, New York 14302

1 copy:       Michael B. Gerrard, Esquire
              Berle, Kass & Case
              45 Rockefeller Plaza
              New York, New York 10111


                                O.

                       PUBLIC PARTICIPATION

     44.  Court approval and entry of this RRT Stipulation are

subject to the public participation requirements set forth in

this Section.  The consent of EPA and the State to this RRT

Stipulation is on the condition that an opportunity be afforded

persons (natural or corporate) who are not signatories hereto to

comment on the RRT Stipulation.  Promptly after the filing of the

RRT Stipulation by the parties, notice of the filing will be
                              - 46 -

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provided in the Federal Register and copies of the RRT
Stipulation will be made available to the public at the EPA
Public Information Office, Carborundum Center, Suite 530, 345
Third Street, Niagara Falls, New York 14303, and at the
Department of Environmental Conservation, Region 9 Office,
Buffalo, New York.  EPA and the State may withdraw or withhold
consent to this RRT Stipulation, or propose modifications to the
RRT Stipulation, if comments received disclose facts or
considerations that indicate that the RRT Stipulation is
inappropriate, improper, or inadequate.  EPA/State will receive
public comments for sixty (60) days after the date the RRT
Stipulation is filed with the Court.  Within sixty (60) days
thereafter, EPA/State will respond in writing to public comments
received during the comment period and submit any public comments
received and responses to those comments to the Court.  Within
ten (10) days of that submission, EPA/State will advise the Court
by letter or motion whether they wish to withdraw from, to
       <*>
withhold consent to, to propose modifications or to move to have
the RRT Stipulation entered and incorporated into the Judgment.
     45.  In the event that EPA/State withdraws or withholds its
consent to the entry of this RRT Stipulation, or proposes
modifications to the RRT Stipulation, the signatory parties shall
promptly initiate discussions relating to the comments received
or to any proposed modifications to the agreement embodied in the
lodged RRT Stipulation and shall notify the Court and the public
of these discussions.  In the event that the signatory parties

                              -  47  -

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are able to agree to the proposed modifications within 30 days of
the date of notification of the Court pursuant to this paragraph,
they shall lodge the RRT stipulation, as modified, with the
Court.  In the event that the signatory parties are unable to
agree to any proposed modification within said 30 days the RRT
Stipulation lodged with the Court shall be deemed withdrawn, null
and.void, and shall be inadmissible in this or any other action;
however, nothing herein shall preclude agreement between OCC and
the Governmental Parties that certain portions of the RRT
Stipulation shall become effective.  In the event that the RRT
Stipulation is deemed withdrawn, in whole or in part, the
Judgment which was approved and entered in 1985, together with
any stipulations filed with the Court pursuant to that Judgment,
shall continue to have full force and effect, and any disputes
shall be resolved by the Court.
     46.  The 60-day public comment period may be extended by
EPA/State for an additional 30 days, in their discretion, and if
prior to the granting of such extension, EPA/State notifies the
Court of its intent to grant the extension.  The 30-day period
for discussing any proposed modifications may. be extended by
agreement of the signatory parties, with prior notification to
the Court, or by order of the Court.
     47.  OCC and the City consent to the entry of this RRT
Stipulation, unless the withdrawal or modifications provisions of
Paragraphs 44 and 45 become applicable, without further notice.
                              - 48  -

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                                p.
                         EFFECTIVE DATE
     48.  The effective date of this RRT Stipulation shall be the
date on which it is entered by the United States District Court
for the Western District of New York.  The activities set forth
in any applicable schedule or in any revised schedule to be filed
pursuant to Section D shall not be affected by the effective date
of this RRT Stipulation or by the pendency of any appeal from
such entry, unless the Court orders otherwise.
                                Q.
                   EXECUTION OF RRT STIPULATION
     49.  This RRT Stipulation nay be executed in two or more
identical counterparts, each of which shall be deemed an
original, but all of which together shall constitute one and the
same instrument.  The parties represent to the Court that counsel
of record have authority to signify the parties' consent and
approval of this RRT Stipulation, subject to the provisions of
Section 0, above, by signing below.
UNITED STATES OF AMERICA
UNITED STATES DEPARTMENT OF JUSTICE
By:.
     RICHARD STEWART
     Assistant Attorney General
     Land and Natural Resources Division
                              -  49  -

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By:
     DENNIS C. VACCO
     United States Attorney
     Western District of New York
     MICHELE GIULIANI
     TriaA Attorney - Environmental
      Enforcement Section
                             - 50 -

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U.S. ENVIRONMENTAL PROTECTION AGENCY
     
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STATE OF NEW YORK


By:.
     ROBERT L. OSAR
     Assistant Attorney General
     NEW YORK STATE DEPARTMENT OF LAW
     EDWARD 0. SULLIVAN-J
     Deputy Commissioner
     NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION
     Commissioner
     NEW YORK STATE DEPARTMENT OF HEALTH
                                   • 52 -

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CITY OF NIAGARA FALLS
     ' -    •      ;
By;  ;/'.-/  ..•/ //
     MICHAEL 0 • LAUGHLIN
     Mayor
Bv:
     CARL E. MOORADIi
     Corporation Counsel
By;
     MICHAEL B. GERRARD
     BERLE, KASS & CASE
                              -  53  -

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OCCIDENTAL CHEMICAL CORPORATION
By:_
          fc*
     THOMAS H. TRUITT
     KEITH S. WATSON
     PIPER & MARBURY
By;   ffNtt^JUx
     LOUIS NIZER
     MARTIN B. WASSER
     PHILLIPS, NIZER, BENJAMIN,
       KRIM & BALLON
By:
     DMTfD K. FLOYD      /
     PHILLIPS, LYTLE, HITCHCOCK,
       ELAINE & HUBER
Dated:  September 12, 1990
ENTER:
                                  Stipulation is hereby approved  in
                                  accordance with the foregoing.
                                    UNITED STATES DISTRICT JUDGE
                                - 54 -

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       APPENDIX I
S-AREA RRT REMEDIAL PT.AN

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                       TABLE OF CONTENTS


                                                           Page


1.0      INTRODUCTION	     1-1

2 . 0      OVERBURDEN REMEDIAL SYSTEMS	     1-3

         2.1  SITE CONTAINMENT SYSTEM	     1-3

              2.1.1  OBJECTIVES	     1-3
              2.1.2  REMEDIAL SYSTEM	     1-3

         2 . 2  OVERBURDEN RRT SYSTEM	     1-10

              2.2.1  OBJECTIVES	     1-10
              2.2.2  REMEDIAL SYSTEM	     1-10

         2 .3  OVERBURDEN MONITORING PROGRAM	     1-15

              2.3.1  NAPL MONITORING	     1-15
              2.3.2  OVERBURDEN HYDRAULIC MONITORING..     1-18

3.0      CAPPING	     1-22

         3.1	     1-22
         3.2	     1-22

4 . 0      BEDROCK RRT SYSTEM	     1-24

         4.1  OBJECTIVES	     1-24

         4 .2  PHASED APPROACH	     1-24

         4.3  PHASE I - INITIAL TESTING OF
              SHALLOW BEDROCK (Top 30 Feet)...........     1-25

              4.3.1  NAPL RECOVERY TESTING	     1-25
              4.3.2  HYDRAULIC TESTING
                     APL/NAPL CONTAINMENT	     1-26

         4.4  PHASE II - PROTOTYPE BEDROCK SYSTEM	     1-27

              4.4.1  PROTOTYPE BEDROCK SYSTEM
                     (Shallow Bedrock)	     1-27
              4.4.2  PROTOTYPE BEDROCK SYSTEM
                     (Intermediate and Deep
                     Bedrock Zones)	     1-40

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                            -  11 -
                                                           Paoe


         4.5  PHASE III - BEDROCK RRT SYSTEM
              (Shallow Bedrock, Intermediate/
              Deep Zones)	     1-43

              4.5.1  REMEDIAL SYSTEM	     1-43
              4.5.2  MONITORING PROGRAMS	     1-45

5.0      REMEDIAL SYSTEM -
         RESPONSE ACTIONS, REASSESSMENTS,  ETC	     1-57

         5.1  Procedures Regarding Response Actions...     1-57

              5.1.1  Operational Modifications	     1-57
              5.1.2  System Modifications  and
                     Supplements	     1-60
              5.1.3  RRT Study	     1-64

         5.2  Monitoring Program Reassessment
              and Modification	     1-65

              5.2.1  Reassessment	     1-65
              5.2.2  Modification	     1-65

         5.3  System Operation Reduction	     1-65

         5.4  Termination	     1-68

         5.5  City Review and Approval
              Responsibilities	     1-70

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                          - RRT PFMRHfAL PLAN
                       1.0  INTRODUCTION

         A.   To  attain  the goals  of  the Judgment  and  the RRT
Stipulation,  OCC shall design,  install, operate,  maintain and
monitor the  RRT remedial  systems to remediate  chemicals within
the  Landfill Site and chemicals which  have  migrated beyond the
Landfill  Site  and  beyond  areas  addressed  by other  remedial
systems  described   in  the  Judgment,   as  described  in  this
Remedial Plan.
         B.   The  RRT   remedial  systems   described   in  this
Remedial Plan consist of the following:
              0    Site Containment System
              0    Overburden RRT System
              0    Bedrock RRT System
         C.   The  design  objectives  of the   Site  Containment
System  are:   (1) to  contain  APL and NAPL;  (2) to maximize the
collection  of NAPL  within the  Site Barrier  Wall  (as  defined
below)  at  the Landfill Site; and  (3)  to minimize the migration
of chemicals toward the City's  Drinking Water  Treatment Plant
(hereinafter  "CWTP").   Subject to Section  1.0.F. below,  the
Site Containment System will be  operated to  attain these design
objectives.
         D.   The   design   and   remedial  objectives   of   the
Overburden RRT  System are:  (1) to  contain  APL and NAPL within

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                              1-2
the  existing S-Area Overburden NAPL  plume;  and  (2)  to collect
NAPL  outside  the  Site  Barrier  Wall  to  the  maximum  extent
practicable.   Subject  to Section  1.0.F.  below,  the  Overburden
RRT System will be operated to attain these objectives.
         E.   The design and  remedial  objectives  of the Bedrock
RRT  System  are:   (1)  to  contain  APL and  NAPL  within  the
existing S-Area Bedrock NAPL plume; (2)  to prevent further NAPL
migration  in the  bedrock  under the  Niagara  River; and  (3)  to
collect   NAPL   within   this   plume   to   the  maximum  extent
practicable.  The  Bedrock RRT System  will be operated to attain
these objectives.
         F.   The Bedrock RRT  System  will be operated to attain
its  objectives  even  if  doing  so  prevents  maintaining  the
specified upward  hydraulic  gradients  into the Site Containment
and Overburden RRT Systems.
         G.   The  design and  operating  objectives of  the City
Drinking Water Treatment Plant Remedial Program as set forth in
Appendix  III  of  this RRT Stipulation are to  prevent  chemicals
which have  migrated from the Landfill  Site  from  entering  the
CWTP  water  supply structures  and service  lines  in   order  to
protect the  users  of  the City of Niagara Falls'  drinking water
from  endangerment  and  to  minimize structural impacts  on CWTP
pipelines, utilities,  buildings,  or  other  CWTP  structures  due
to remedial activities.

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                              1-3

                2.0  OVKKBURDEN
 2.1      SITE CONTAINMENT SYSTEM
         2.1.1  OBJECTIVES
         The  design objectives of  the Site  Containment System
 are:    (1)  to  contain  APL  and  NAPL;  (2)  to  maximize  the
 collection  of NAPL  within the  Site Barrier  Wall  (as  defined
 below)  at  the Landfill Site; and  (3)  to  minimize the migration
 of  chemicals  toward the CWTP.   Subject to  Section  I.O.F.,  the
 Site  Containment  System will  be operated to attain these design
 objectives.

         2.1.2  REMEDIAL SYSTEM
         A.   Installation;
         Al.  The Overburden  area  at the  Landfill Site  will be
 addressed  by  a  remedial  system   (Site  Containment  System),
 consisting  of  barrier walls  (Site  Barrier Wall)/ a  drain tile
 system   (Tile  Collection  System),  seven   Overburden  (Site
 Containment)   purge   wells   installed   in  Confining   Layer
 Discontinuities and  a  cap.  The Site Barrier Wall shall consist
 of  a  slurry  wall  on  the  west/   north,   and  east.    These
 components/ except  the  cap,  are shown on Figure 1.  The Site
Barrier Wall refers to those  portions  of  the Overburden Barrier
Walls  (as  defined  in  Section  2.2.2.B1)   located north  of  the
Industrial Intake Pipe Trench (IIPT).

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                               1-4
          A2.   Site Barrier Wall:
               (a)   The Site Barrier Wall  shall be installed  at
 least  one foot below  the  top  of  the Confining Layer;  provided,
 however/  that in the  event any routes of  chemical migration are
 identified  which are  expected to  pass  under  the  Site  Barrier
 Wall   in  the  Overburden  after   Hydraulic   Stabilization  (as
 described in  Sec.  4.4.1.A3), the  depth  of  the Site Barrier Wall
 shall  be  lowered  so  as  to  intercept  any  such routes  in the
 Overburden.   If the   Site  Barrier Wall  traverses  a  Confining
 Layer  Discontinuity,   it shall be  installed to a depth and in a
 manner which  will  assure  the  integrity  and intended function  of
 the Site  Barrier Wall.
               (b)   The Site   Barrier   Wall   shall  consist   of
 material  or materials at  least  two feet  wide having  a maximum
 permeability   of   1   x   10     cif?/sec,   or   its   performance
 equivalent.   Prior to submission  of  plans  and specifications
 concerning  the   Site   Barrier  Wall,   OCC   shall   conduct   an
 accelerated   test   of  any  material  it  intends   to  use   to
 demonstrate to what  extent,   if  any,  the permeability  of  the
material  will   be  affected  by   chemicals   in  the  adjacent
Overburden.    The results  of   such testing  and  all  underlying
data related  thereto   shall accompany OCC's  submission of plans
and specifications concerning the Site Barrier Wall.
         A3.  Tile Collection System;
              (a)  The Tile Collection  System  shall  be located
and installed in a manner  which  will maximize  the containment

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                              1-5
of APL  and NAPL  located within  the  Site  Barrier Wall.   The Tile
Collection  System  drain  which  is  adjacent  to  the Industrial
Intake  Pipe  Trench  (IIPT)  shall  be hydraulically  connected to
the  bedding  of the IIPT in such a manner as to allow collection
of APL  and NAPL  from the IIPT bedding.
               (b)  The   Tile   Collection   System   shall   be
installed at least to the top of  the Confining Layer;  provided,
however,  that  it  shall  be  installed  to  a  depth which  will
maximize the collection of  NAPL located  within the Site Barrier
Wall.   If  the  Tile Collection  System  traverses  a  Confining
Layer Discontinuity,  it shall  be installed  to one foot  above
the  top of  Bedrock.  The drain tile  shall  be sloped toward Wet
Well A  at a minimum grade of 0.5%.
               (c)  OCC    shall    promptly    submit    to    the
Governmental  Parties plans,  specifications  and  protocols  for
the   accelerated   compatability   testing   of   all   permanent
materials,  (e.g..  pipe,  filter  fabric) associated  with  Tile
Collection  System  installation  that OCC   intends to  use  to
demonstrate  to  what extent,   if  any,  the  material  will  be
affected   by    chemicals    in   the    adjacent   overburden.
Implementation   of   the   testing   program   shall   commence
immediately  following the  Governmental  Parties  approval of the
plans,  specifications  and  protocols.   The  results  of  such
testing and  all  underlying  data related  thereto shall accompany

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                               1-6
 OCC's  submission of  plans, and  specifications  concerning  the
 Tile Collection System.
         A4.  Site Containment Purge Wells:
              The Site  Containment  Purge Wells shall be located
 approximately  as  shown  on  Figure  1.   The  wells  shall  be
 installed  in such a  manner and to  such depths  as  to  meet the
 objectives set forth  in Section 1.0.
         A5.  Cap;
              The Landfill  Site shall  be capped  in accordance
 with  the provisions  of the Waste  Management  Plan  and Section
 3.0 herein.
         A6.  Underground Utilities:
              Underground  utility  and  service  lines  located
 within   the  perimeter   of   the  Site  Barrier  Wall  shall  be
 abandoned  in  place.   Whenever  a   utilit*   or  service  line
 previously  abandoned  or  to  be  abandoned  pursuant  to  this
 subparagraph crosses  the Site  Barrier  Wall,  OCC  shall  remove
 that portion  of such line  crossing the Wall,  seal  the ends of
 each  line  remaining in place  by  plugging  with  appropriate
 grouting material,  or its  performance  equivalent,  and backfill
 the  trench  from   which  such   portion  was  removed.    If
 appropriate, utility and  service  lines abandoned  pursuant  to
 this  subparagraph  shall be  replaced  by  installations  above
ground or  outside the  Site  Barrier Wall.  The 003  storm sewer
outfall shall be relocated to the alignment shown on Figure 1.

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                              1-7
         A7.  Laaoons:
              OCC  shall terminate the  operation  and use of the
existing  lagoons,  and the  area  encompassed  by the  existing
lagoons  shall be capped  and closed in  accordance  with Section
3.0 and the Waste Management Plan.

         B.   Operation?
         Bl.  The   Tile  Collection   System  and   seven   Site
Containment  purge wells will  be operated to  achieve  an inward
gradient  across the  Site Barrier  Wall, except  in  those  areas
where  the  installation or operation of  the CWTP  or  RRT systems
make  the  achievement  of  such  inward  gradients  impracticable.
In  those  areas where  an  inward gradient  is not  achieved,  any
migration  of S-Area  APL  and  NAPL will  be  addressed  by  other
installed remedial  system(s).
         B2.  The  Tile Collection System will be  operated  to
maximize  an  upward gradient  across  the Confining  Layer within
the area  encompassed  by the Site Barrier Wall such that the wet
well water level  is maintained at the  lowest  drain  tile invert
elevation at  the wet well.
         B3.  The  static  water  table  elevation  of  each  Site
Containment   Purge/Recovery   Well   measured   after  Hydraulic
Stabilization as  defined  in  Subsection 4.4.1.A3, will  be  used
to determine  the need  for  Site  Containment  Purge/Recovery Well
operation.   If  the static  water  table elevation at  a  Site

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                              1-8

Containment Purge/Recovery Well  is  greater than one  foot above
the  top of the  Clay/Till  Layer, or Bedrock  where no Clay/Till
Layer exists, and a nine foot upward head  differential does not
exist  at that well,  then that  Site Containment Purge/Recovery
Well will  be operated  to  maintain the  pumping  water  level  in
the  well at one  foot  or less above the Clay/Till Layer or top
of Bedrock where no Clay/Till Layer exists.

         C.   NAPL Recovery-Testing and Operation;
         Cl.  Identification of  Wells  for  Testing:  Thirty days
after   the  installation  of  the   7   Site  Containment  System
purge/recovery  wells,  each well  that  encounters NAPL  during
installation will be tested to evaluate NAPL recovery potential.
         C2.  Recovery   Testing   Procedure:     When   testing
purge/recovery wells,  the  objective  will  be  ~o  evaluate  the
capability  of   the  well  to   produce  NAPL   and  to  define
operational  requirements  needed  to  maximize  NAPL  recovery.
Initially,  each  purge/recovery  well  that encounters  NAPL upon
installation will be  pumped  for APL  and NAPL  at the maximum
rate achievable  (to a  maximum  of  5 gal/min)  for  a duration of
five days.  The test will be conducted  to  quantify the ratio of
NAPL to APL produced  as a function of time.   The radius of well
influence  on  NAPL  will also be evaluated  for  the  overburden
wells   that  are  tested.   No   additional  new  wells  will  be
installed  solely for  the  purpose  of  evaluating the  radius  of

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                              1-9

well  influence.   Test results  will  be  evaluated  during each
well  test,  and upon  approval  by the  Governmental  Parties,  the
pump   rates  and  duration  will   be   varied  to  enhance  the
effectiveness of the test.
         C3.  Operation  of NAPL  Recovery Wells:   Based  on the
results  of the  NAPL  recovery  testing,  any well  shown  to  be
capable  of  producing  reasonable   amounts  of  NAPL  will  be
operated  in such  a  manner as  to  recover  NAPL to  the maximum
extent  practicable.    In  evaluating whether the  amount of NAPL
which  can  be  recovered by  a  well  is  reasonable,  the  following
factors will be considered:
                   Ratio  of NAPL to APL collected
                   Depth  of NAPL in a well
                   Volume of water  pumped to recover NAPL
                   Radius of well influence
                   Production decline
                   Use   of    non-continuous   pumping,   i.e..
                   periodic pumping of NAPL.
Any  well   which   is   shown  not  to  be  capable  of   producing
reasonable  amounts  of   NAPL  and  which  is not   being  pumped
pursuant  to Subsection 2.I.2.B.  or 2.2.2.C. will  be  monitored
as described in Section 2.3.1.
              Based  on   the   results  of   the  NAPL  recovery
testing, OCC will, within 30 days  of test completion,  identify,
subject to  the  Governmental  Parties approval,  which wells will
be operated as  NAPL  recovery wells and how  and when those wells
will be operated to maximize NAPL recovery.

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                              1-10
 2.2      OVERBURDEN RRT SYSTEM
         The  Overburden   area   outside  the  Site  Containment
 System  will  be addressed  by  the RRT  system  (Overburden RRT
 System) described below.

         2.2.1  OBJECTIVES
              The   design  and   remedial  objectives   of   the
 Overburden  RRT  System are:   (1)  to contain  APL and NAPL within
 the  existing  S-Area Overburden  NAPL  plume;  and  (2)  to collect
 NAPL  outside   the  Site  Barrier  Wall  to  the maximum  extent
 practicable.   Subject  to Section  I.O.F.,  the Overburden  RRT
 System will be  operated to attain these objectives.

         2.2.2  REMEDIAL  SYSTEM
         A.   Introduction;
              This    Section     addresses    the   installation,
 operation  and  testing of  the components of the  Overburden RRT
 System.
         B.   Installation:
         Bl.  The  Overburden  RRT  System  shall   consist  of
 barrier walls   south  of  the  Site Barrier Wall and  the Robert
Moses  Parkway  (RRT  Barrier  Wall),  drain  tiles/   Grout  Plugs
 installed  across  the Industrial  Intake  Pipe Trench  (IIPT)  and
Robert  Moses   Parkway   (RMP),   Overburden  RRT  Purge/Recovery
Wells, and  a  cap.   These components,  except the  cap,  are shown
on Figure  1.    The  Site Barrier  Wall  and RRT  Barrier  Wall are

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                              1-11

referred to collectively in this Plan as  the  Overburden Barrier
Walls.
         B2.  RRT Barrier Wall:
              (a)  The RRT  Barrier  Wall  refers  to  that portion
of  the  Overburden  Barrier Wall  located  south  of  the  Site
Barrier Wall.  The  approximate location of the RRT Barrier Wall
is shown on Figure 1.
              (b)  All  design  and   installation  requirements
specified  for the  Site  Barrier Wall  under  Subsection  2.1.2
shall  apply  to  the design, installation  and  performance of the
slurry wall portion of the RRT Barrier Wall.
         B3.  Drain Tiles;
              Drain  tiles shall be  designed  and installed  in
accordance with  the criteria  specified  for the Tile Collection
System drain tiles under  Subsection 2.1.2.  The location of the
drain tiles shall be approximately as shown on Figure 1.
         B4.  Grout Plugs:
              (a)  Grout  Plugs  shall  be  installed  across  the
IIPT  and  RMP  at  the   location  where  these  facilities  are
intersected by the  centerline of the RRT Barrier Wall/ as shown
on Figure 1.
              (b)  The  depth  to  which  the  Grout  Plugs  are
installed  shall  be  in  accordance with the  criteria  specified
for Site Barrier Wall installation under Subsection 2.1.2.

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                              1-12
              (c)  The  Grout  Plugs  shall  be  installed  by  a
prescriptive grouting program  designed  and  implemented to allow
for  maintenance  of  the hydraulic gradients  specified  under
Subsection  2.2.2.C.   Once  the  Governmental  Parties-approved
prescriptive   grouting   program   has   been   implemented   the
installation of Grout Plugs shall be deemed complete.
              (d)  OCC   shall   promptly    submit   to    the
Governmental  Parties plans/  specifications  and  protocols  for
the accelerated testing  of grout material associated with Grout
Plug  installation that  OCC  intends  to  use.   The  objective of
the accelerated  testing is  to demonstrate to  what  extent,  if
any, the permeability of the grout material will be affected by
chemicals  in  the  adjacent  overburden.    Implementation  of  the
testing  program   shall  commence   immediately   following   the
Governmental Parties approval  of  the plans,  specifications  and
protocols.  In  lieu  of such  testing,  OCC may  promptly submit
technical  documentation that  adequately demonstrates,  subject
to  the Governmental  Parties  approval,  the  appropriateness of
grout  material  for  use in  the  prescriptive grouting  program
defined in  this  Section 2.2.2.54.   The  results  of  such testing
and all  underlying data related  thereto shall accompany  OCC's
submission  of  plans and  specifications concerning  the  Grout
Plugs.
         B5.  Overburden RRT Purge/Recovery Well Systems;
              (a)  Two  Overburden   purge/recovery  well  systems

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                              1-13
will  be installed  as shown  on Figure  1.   These  systems  will
consist of:
              (i)   a well  system consisting of  six wells
              located  immediately south  of  the  HPT  and
              north of the RMP; and
              (ii)  a well  system consisting  of ten wells,
              including  nine wells  located  south   of  the
              RMP  and one  well located  north  of  the  RMP
              and east of the HPT.
              (b)  The   Overburden  RRT  Purge/Recovery   Wells
shall  be  installed in such a manner and to  such  depths  as  to
meet the objectives set forth in Section 1.1.
         B6.  Cap;
              The Overburden  RRT  System area  shall  be capped in
accordance with the provisions of Section 3.0 herein.

         C.   Operation;
         Cl.  The  Overburden  RRT  purge/recovery  well  system
will be operated to achieve:
              (a)  an  inward gradient,   across  the  RRT Barrier
Wall and grout plugs on the west, south and east; and
              (b)  an  upward gradient  within  these walls  and
grout plugs, as described in Section C2. below.
         C2.  Each RRT  purge/recovery well will  be operated to
maintain  an  inward  gradient  and/or   to  increase  the  upward
gradient  cited   in  Subsection  Cl.  above,  if,  after  Hydraulic
Stabilization  (as  defined  in  Subsection  4.4.1.A3.),  but  no
later  than  12 months  after start of operation  of both the Tile

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                              1-14
Collection System  and  the  Prototype Bedrock System, any  of  the
following conditions exist:
              (a)  an inward gradient does  not  exist across  the
RRT Barrier Wall or the grout plugs shown on Figure 1;
              (b)  static water  levels  in  any of the  six wells
adjacent  to  the  IIPT  are  higher  than   one  foot  above  the
Clay/Till  Layer,  or  the  Bedrock  where  no  Clay/Till  Layer
exists,  and  there  is  less  than  a  nine  foot  upward  head
differential from the Bedrock;
              (c)  static  water   levels   in   any  of  the  ten
remaining wells  which are installed  in the defined  areas with
less  than  three  feet  of  Confining Layer  are  higher  than  one
foot  above  the Clay/Till  Layer  and there  is  less  than  a nine
foot upward head differential from the Bedrock; or
              (d)  static  water   levels   in   any  of  the  ten
remaining wells  which  are  installed in  the  defined  areas  of
greater than three  feet  of Confining Layer are higher  than  one
foot  above  the   Clay/Till Layer   and  indicate  no net  upward
gradient from the Bedrock.

         D.    NAPL  Recovery  Testing   in   the  Overburden  RRT
              Puroe/Recoverv Wells;
         Dl.  Identification of  Test Wells:  Thirty days after
the 16  P.RT  purge/recovery wells  are installed,  each  well that
encounters NAPL  during  installation  will  be tested by pumping
to evaluate NAPL recovery potential.

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                              1-15
         D2.  Recovery    Testing    Procedure:     When   testing
purge/recovery  wells,  the  objective will  be  to evaluate  the
capability   of   the  well   to   produce  NAPL   and   to  define
operational  requirements  needed to  maximize NAPL recovery.  The
testing  for  NAPL  recovery  by Overburden RRT  purge/recovery
wells will be as described in Section 2.1.2.C2, infra.
         D3.  Operation of NAPL Purge/Recovery Wells:  Based on
the  results  of  the NAPL recovery testing,  any well  shown  to be
capable  of   producing   reasonable   amounts  of  NAPL  will  be
operated as  described in  Section 2.1.2.C3,  infra.

2.3  OVERBURDEN MONITORING PROGRAM
         2.3.1  NAPL MONITORING
         A.   Monitoring Objective;
         The  objective   of  the   Overburden   NAPL  Monitoring
Program (ONP) is:
              0    to  evaluate the NAPL  recovery  by  the
                   Site   Containment  and   Overburden  RRT
                   Systems and  to  facilitate the selection
                   and/or addition  of Overburden  wells to
                   be pumped  for NAPL recovery pursuant to
                   Section 2.3.I.C.
              0    to assess  whether  the S-Area Overburden
                   NAPL   plume   is   contained  within  the
                   Overburden Barrier Walls.
         B. Program Implementation;
         Bl.  Each  purge/recovery  well within  the Overburden
Barrier Walls will be evaluated for NAPL recovery as  follows:

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                              1-16


              0    Monitoring  will  be  initiated  at  the
                   same   time   as   Overburden   Hydraulic
                   Monitoring   (see   Subsection  2.3.2.B1.
                   below).

              0    Quarterly frequency.

              0    Each well pumped  solely for the purpose
                   of  NAPL  recovery will  be  monitored for
                   the following:

                        NAPL   and  APL   production  rates
                        (measured);

                        NAPL/APL ratio (calculated);

                        NAPL       production       decline
                        (calculated);

                        Volume  of  water  pumped  to  recover
                        NAPL (measured);  and

                        radius     of    well     influence
                        calculated and/or measured.

              0    Wells   not   being   pumped   will   be
                   monitored for depth of NAPL.

         52.  The  cumulative  volume  of  NAPL recovered  by the

Overburden RRT purge/recovery well system  will be monitored and

calculated monthly.

         B3.  Piezometers outside  the Overburden  Barrier Walls

will be monitored for NAPL presence as follows:

              0    Monitoring  will  begin   one year  after
                   completion  of  the  Overburden  Barrier
                   Walls.

              6    Annual frequency.

              0    Each of the  nine  Overburden piezometers
                   outside  the  Overburden  Barrier  Walls
                   will  be  visually  inspected  for  NAPL
                   using hand  bailing  to  the  bottom of the
                   piezometer  (or  a  performance  equiva-
                   lent) .

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                              1-17
         C.   Response Actions;
         Cl.       During  the ONP, an Overburden  NAFL recovery
test/  as per  Subsection 2.1.2.C2.,  will be  conducted  on any
Overburden purge/recovery well where:
              0    ONP  monitoring  indicates  NAPL in  any
                   previously      non-NAPL       bearing,
                   non-pumping well.
              0    The  level  of  NAPL  in   a  NAPL-bearing
                   well   which    is   not   being   pumped
                   increases  to   pumpable   levels  between
                   ONP monitoring  observations.
              If  any  well  is  shown  by the  pump  test  to  be
capable of recovering reasonable  amounts  of  NAPL (as  defined in
Section 2.1.2.C3.)/  it  will be operated as described in Section
2.1.2.C3.
         C2.  Any Overburden  purge/recovery  well which is being
operated solely  for  the purpose  of  NAPL recovery will  be shut
off  if it  is  no  longer  recovering reasonable  amounts  of NAPL
based  upon  the  considerations  stated  in Subsection  2.1.2.C3.
However, that  well will continue to be  subject to  monthly ONP
monitoring,  and, if the NAPL  level increases to pumpable levels
between monitoring  observations,  the  NAPL  will be pumped out.
If  the  well  is  determined  to  be  capable  of  producing  a
reasonable  amount  of  NAPL,  operation  of  the well  will  be
reinitiated as described in Subsection 2.1.2.C3.
         C3.  One year  after initiation  of  ONP monitoring, the
selection of Overburden Wells which  are being  pumped  for NAPL

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                              1-18
 recovery will  be  assessed.   OCC shall submit this assessment to
 the  Governmental  Parties within 30 days.
         C4.   As   a   result   of  the   assessment,   additional
 Overburden  wells  for  NAPL  recovery  will be  installed if data
 indicate that such  wells would collect reasonable  amounts  of
 NAPL (as described in  Subsection 2.1.2.C3).
         C5.   If  ONP monitoring indicates NAPL  presence in any
 piezometer  immediately  outside the  Overburden  Barrier Walls,
 OCC  will proceed  pursuant  to  Section  5.1.1 to  determine what
 Operational  Modifications  (as  defined  in Section 5.1.1) to the
 Overburden  RRT System and/or  the  Site Containment  System are
 required to contain  NAPL.
         C6.   If   further  ONP   monitoring  indicates  that  the
 action  taken pursuant  to Subsection  C5.  above is not effective
 in containing  NAPL  within  the  existing Overburden  NAPL plume,
OCC will proceed pursuant to Section  5.1.2.

         2.3.2  OVERBURDEN HYDRAULIC MONITORING
         A.   Monitoring Objective;                ......
         The  objective of  the   Overburden Hydraulic Monitoring
Program  (OHP)  is  to  evaluate   the  effectiveness  of  the Site
Containment System and the  Overburden RRT System in maintaining
inward gradients across the Overburden  Barrier Walls and upward
gradients  into the  Site  Containment  System and  Overburden RRT
System from the Bedrock.

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                              1-19
          B.    Program  Implementation;

          Bl.   OHP monitoring frequency will be as follows:

               0    Water  level  monitoring will  begin  no
                   more  than  90 days  after  the  start  of
                   operations  of the Site  Containment and
                   Overburden  RRT Systems;

               0    Monthly   frequency/   except   that  one
                   Overburden  well,  one Bedrock  well, and
                   water  level  in  the  Niagara  River will
                   be  monitored  continuously.   The  wells
                   to  be  continuously  monitored  may  be
                   changed from  time to time.

          B2.   Water  levels  to calculate  inward  gradients will

be monitored using the following wells and piezometers:

               0    four   piezometers   inside    and   six
                   piezometers    outside    the    eastern,
                   northern  and  western  portion  of  the
                   Overburden  Barrier Walls,  as  shown  on
                   Figure 4.

               0    a piezometer  placed on  each  side of the
                   three  grout  plugs  near  the middle  of
                   each of the plugs.

               0    Niagara River (stilling well)

               0    Any   of    the    purge/recovery   wells
                   installed   immediately   north   of  the
                   Niagara  River which  are  not  operated
                   for   NAPL   recovery   or  water  level
                   reduction.

         B3.  Water levels to  calculate upward  gradient  will be

monitored  using  the  following  wells,  shown  conceptually  on

Figure 4:

               0    12 maintenance piezometers;

               0    23    purge/recovery    wells    in   the
                   Overburden,  and

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                              1-20
               0    21  Shallow Bedrock wells  selected from
                   those wells that presently exist.
Where   existing   wells  become  unusable,  new  wells  will  be
installed.
         B4.   An  assessment  of  OHP  monitoring  procedures  and
well  locations will be  initiated  one year  after the  start of
operation  of  the  Site Containment  and Overburden  RRT Systems
and submitted  to  the Governmental Parties within  60 days after
initiation of  the assessment.

         C.    Response Actions;
         Cl.   If  OHP   monitoring  indicates   that   an  inward
hydraulic  gradient  is not  being  achieved across the Overburden
Barrier Walls  in  an  area not influenced by  any other installed
overburden  remedial  system(s),  OCC  will  proceed  pursuant  to
Section 5.1.1  to  determine  what  Operational Modifications  (as
defined in Section  5.1.1)  are required  either  to  achieve  the
specified  gradients  or otherwise  contain NAPL  and  APL  in  the
affected  area.   Such measures  may  include increased  pumping
and,  if  necessary,   installation  of  additional  wells  and/or
drain tiles to draw  down the overburden water table as required
to maintain  specified  inward gradients  across  the Overburden
Barrier Walls.
         C2.   If  further  OHP  monitoring  indicates  that  the
action(s)   taken  pursuant to  Cl., above,  are  not  effective in

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                              1-21
maintaining  inward  gradients  across  the  Overburden  Barrier
Walls,- OCC will proceed pursuant to Section 5.1.2.
         C3.  If OHP monitoring  indicates  that upward gradients
specified   in   Subsection  2.2.2.C   between   the  Bedrock  and
Overburden are not being  achieved/ OCC  will  proceed pursuant to
Section  5.1.1  to  determine what Operational  Modifications (as
defined  in  Section   5.1.1),   are   required   to   achieve  the
specified  gradients.    For the  Site  Containment  System,  such
Operational  Modifications  may  include  increasing the  pumping
rates or other  operational changes  to existing wells, but shall
not include  installation  of new wells.   For the  Overburden RRT
System/  such  Operational Modifications  may  include,  among
others,   increased   pumping   rates   or   other   Operational
Modifications  (as  defined in  Section  5.1.1)  to  drawdown the
overburden water table within the RRT Barrier Walls.

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                              1-22
                          3.0  CAPPING

          3.1  The  areas at and around the Landfill Site will be
 capped  as follows:
              (a)  The  area within  the Site  Barrier Wall west
 of  the  existing 003 Outfall alignment will be capped with clay
 or  asphalt  and may  be  used  in  the  future   as  a  storage  or
 parking area.
              (b)  The  area within the  Site  Barrier Walls east
 of  53rd Street  shall be asphalted and may  be used in the future
 as  a storage or parking area.
              (c)  The  area south  of the  northern  (westbound)
 lanes of the RMP may be capped to reduce infiltration.
              (d)  The  area within  the Site Barrier  Wall north
 of  Adams  Avenue  shall  be  capped  with asphalt  or  concrete and
 mi/ be  used in the future  as an  area for  storage  of  APL and
 NAPL generated  by remedial  activities  required by the Judgment
 or  the  Stipulation.
              (e)  All   other    areas   within   the  Overburden
 Barrier  Walls will be capped as described in Section  3.2.
          3.2  Except  as  provided  in  Section  3.1,  all  other
 areas  within the  Overburden  Barrier Wall  will  be capped  as
 follows:
              (a)  The  cap shall  consist of  clay  and  have  a
                                 _7
maximum  permeability  of 1  x  10  cm/sec.  The clay cap shall
consist  of a minimum of three feet of clay,  an 18-inch  layer of

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                              1-23
silty soil or loam, and a six-inch layer of  topsoil  seeded with

native vegetative  growth.   All areas capped with  clay shall be

crowned  by the  construction  of  one or  more  apexes,  each  of

which slopes at  a  minimum  of  5% grade toward a surface drainage

system having a minimum of 0.5% grade.

              (b)  The   following   actions    shall   be   taken

concerning   the   cap   to   verify   compliance   with   design

specifications:

              (i)    before  installation,  the  clay  to  be
         used for  the cap shall  be  tested;  permeabilities
         at  various  soil  compaction densities  shall  be
         determined;  and the  density required  to  attain a
         maximum  permeability  of   1 x  10~7cm/sec.   shall
         be identified;

              (ii)   during installation, the clay  used for
         the cap shall be evaluated before it  is placed to
         insure the material meets specifications;  and the
         compacted density in each six-inch  layer  shall be
         tested to  insure  it  meets  requirements to  attain
         the specified permeability;  and

              (iii)  after  installation,  six  undisturbed
         samples  (Shelby  Tubes)   shall  be  collected  at
         representative locations  and density  tested;  the
         thickness  of  the  clay cap  and  topsoil also shall
         be verified at these six  locations; and the holes
         created  in   accordance   with   this  subparagraph
         shall   be   appropriately  plugged  and   the   cap
         restored.

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                              1-24

                    4.0  BEDROCK RRT SYSTfcJf
         NAPL  and  APL in the Bedrock at and around the Landfill
Site will  be  addressed by  the  RRT System  (Bedrock  RRT System)
described below.

         4.1  OBJECTIVES
         The design and  remedial  objectives of  the  Bedrock RRT
System  are:    (1)  to  contain APL  and NAPL within  the existing
S-Area  Bedrock  NAPL plume;   (2)  to  prevent  further  NAPL
migration  in  the  Bedrock under  the  Niagara  River; and  (3)  to
collect   NAPL   within   this  plume   to   the   maximum  extent
practicable.  The  Bedrock  RRT System will be operated to attain
these objectives.   The Bedrock RRT  System will be  operated  to
attain  its objectives even if doing so prevents maintaining the
specified upward hydraulic  gradient? into  the  Site Containment
and Overburden RRT Systems.

         4.2  PHASED APPROACH
         The design,  installation, operation and  monitoring  of
the Bedrock RRT System will proceed in a three-phased approach:
         Phase I   -    Initial Testing of  Shallow Bedrock
                        Zone.
         Phase II  -    Design,    Installation,    Operation
                        and   Monitoring    of    Prototype
                        Bedrock  System   in  the  Shallow,
                        Intermediate   and   Deep   Bedrock
                        Zones.

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                              1-25


         Phase III -    Design,   Installation,   Operation
                        and   Monitoring   of   Bedrock   RRT
                        System     in      the     Shallow,
                        Intermediate   and   Deep   Bedrock
                        Zones.

Three zones within the Bedrock are defined for the RRT System:

         Shallow Zone:       Top 30 feet of Bedrock

         Intermediate Zone   From   the   bottom   of   the
                             Shallow Zone to  30  feet above
                             the   top   of   the   Gasport
                             Formation

         Deep Zone:          From   30   feet   above   the
                             Gasport Formation down to the
                             top of the Rochester Formation

4.3      PHASE I - INITIAL  TESTING  OF SHALLOW BEDROCK  (Top  30
                   Feet)

         4.3.1 NAPL RECOVERY TESTING

         A.   A  network  of  eleven  recovery  wells  which  are

designed to  maximize NAPL collection will  be installed  into the

top 30  feet  of  the Bedrock (Shallow Bedrock)  as  shown on Figure

2 and subsequently tested.   Testing  will be designed to evaluate

the  capability   of  wells   to   recover  NAPL   and   to  define

operational  requirements.   Initially,  each well will be pumped

for APL and NAPL at the maximum rate achievable  (to a  maximum of

5  gal/min)  for   a duration  of  five  days.   The  test  will  be

designed to  quantify the  ratio  of  NAPL to  APL  collected  as  a

function of time.

         B.   Test  results  will be  evaluated during  each  well

test and  the pump rates  and duration may be varied  to enhance

the  effectiveness  of  the  test  and   to   determine   the  most

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                              1-26
 effective   operation  to   maximize  the   collection  of  NAPL.
 Modifications to the initial  test  procedure may be made, subject
 to  approval by  the Governmental  Parties.   After  completion of
 the  recovery  testing,  all data generated by the  testing will be
 evaluated  and used to design  the  NAPL  recovery component of the
 Prototype Bedrock System.

         4.3.2  HYDRAULIC TESTING - APL/NAPL CONTAINMENT
         A.   A  second  network  of  eight  Shallow  Bedrock  purge
 wells,  which  are   intended   to  effectively  characterize  the
 hydraulic  properties of  the  Bedrock,  will be installed  at the
 locations  shown  on  Figure 3.   Each well  will be  sized  for  a
 pumping  rate  up   to   150  gallons  per  minute.   Water  level
 measurements will be taken: i) from each pumped well; ii)  from a
 maximum  of ten  observation wells  for  each  test,  two  of  which
will  be  instrumented  with continuous  recorders;  and  iii)  from
 the Niagara River  via  a continuous recorder.  Existing wells may
be used  if their  location  and construction are  appropriate for
 the  test;  no  new wells will be  installed solely  for the purpose
of this  test.   However,  new  wells  required for  other programs
under  this  RRT  Remedial  Plan  shall  be  installed  ahead  of
schedule if needed for this test.  Water levels will be measured
every  four  hours  for  a  period  of  one day prior  to  each test
start.  Due to  the  effects of  the  Niagara River  fluctuations,

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                              1-27
 the  maximum  time  permitted between water  level  measurements in
 any well  during  the  test  period will be two hours.
          B.    Initially,  each  of the  first  two wells  will be
 pumped  for  APL at the maximum  rate  achievable (to  a maximum of
 75  gal/min) for a  duration of 24 hours.   After  these two wells
 are tested, the  results will be evaluated  and the test protocols
 reviewed.   If higher pump  rates  are required  for  the. remaining
 tests.,  the  pump  rates will  be adjusted up  to 150  gal/min.  After
 the completion of the  hydraulic  testing,  all  data  generated by
 the testing will be evaluated  and  used to  design  the hydraulic
 containment component of  the Prototype Bedrock System.

 4.4       PHASE II -  PROTOTYPE BEDROCK SYSTEM
          Based on  the  data obtained during the Phase I testing,
 a  Prototype  Bedrock  System,  which  consists  of NAPL  recovery
wells and APL/NAPL containment purge wells,  will  be designed and
 installed as described below.

          4.4.1  PROTOTYPE BEDROCK SYSTEM (Shallow Bedrock)
          A.   Remedial System:
         Al.  System Design  and  Installation:   The  Prototype
Bedrock  System will be designed  and  installed  in  the  Shallow
Bedrock  based on  the  data  obtained  from  the Phase  I  testing.
The Prototype Bedrock System shall be designed and installed, as
the second  phase of a three-phase program,  to attain the design

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                              1-28
 and  remedial objectives  of  the Bedrock RRT  System described in
 Section  4.1  and  to  collect data  for the  final design  of the
 Bedrock  RRT  System.   The  prototype design will  include  the
 number   of   wells,  well  locations  and  the  well,  pump,  and
 operation specifications.
         A2.  System  Evaluation:   The Prototype  Bedrock System
 will  be operated  and monitoring  data will  be  collected until
 implementation  of  the  Bedrock RRT  System   pursuant  to  Section
 4.5.1.   The  monitoring data  will  be  used  to  evaluate  the
 effectiveness of  the Prototype Bedrock System in recovering NAPL
 and containing APL and NAPL.   Based upon evaluation of generated
 data  and  subject  to  the  Governmental  Parties   approval,  the
 system will  be  adjusted during the first 12  months  of operation
 of the  Prototype Bedrock System by varying pumping rates  and, if
 necessary, by the  addition  or deletion  of   NAPL  recovery wells
 and APL/NAPL containment purge  wells.   Evaluation for the above
 adjustment will  be made by OCC 6 months  and  12  months following
 startup  of  the Prototype Bedrock  System.  OCC will  conduct one
 additional evaluation doing this 12-month period  if so requested
by the Governmental Parties.
              After  the  initial 12-month period,  pumping rates
in the Prototype  Bedrock System's  wells may  be adjusted at three
month  intervals  to  evaluate  the  effect  on  inward  hydraulic
gradients  and   NAPL  recovery  rate.    Data  collected  during
operation of the  Prototype  Bedrock System will  be used  to:  (i)

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                              1-29
 evaluate  Bedrock  conditions;  and  (ii)  design  the  Bedrock RRT
 System and monitoring programs per Section 4.5.
         A3.  Hydraulic  Stabilization:   Hydraulic  Stabilization
 in  the  Bedrock  is  defined to  have  occurred  when  the  head
 measurement  of  the inside  Bedrock  piezometer  of  a piezometer
 pair  no  longer  declines more than  0.2 feet  per  quarter, taking
 appropriate   account   of    barometric   pressure,   water   level
 fluctuations in  the Niagara  River,  and seasonal  effects.   When a
 modification  of  the Prototype  Bedrock  System is   implemented,
 only  the area affected by  that modification  will  be evaluated to
 determine   if   Hydraulic   Stabilization    is   re-established.
 Hydraulic monitoring  will  continue  for those  areas  not  affected
 by  the  modification.   If  the  head  measurement  of  the inside
 piezometer does  not achieve a decline  rate  of 0.2 feet  or less
 per  quarter,  then Hydraulic  Stabilization  is  assumed  to have
 occurred  one  year  after   implementation  or  modification  of the
 Prototype Bedrock System.

         B.   Monitoring Program:
         Bl.  Shallow Bedrock NAPL Monitoring:
              (a)   Monitoring Objective;   The objective of the
Shallow  Bedrock  NAPL Monitoring  Program  (SBNP)  is  to evaluate
the effectiveness  of the  Prototype Bedrock  System  in attaining
the objective set forth in Subsection 4.4.1.A1.

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                              1-30
               (b)   Program Implementation;

               1.    The  following  SBNP monitoring to assess NAPL

 recovery  by the  Prototype Bedrock  System will  be conducted in

 purge/recovery wells  within  the  existing  Bedrock  NAPL  plume

 along the River:

               0    A  monitoring  program for NAPL  recovery
                   by  the  Prototype  Bedrock  System will be
                   developed   after    completion    of   the
                   Initial  Testing  Program (described  in
                   Section  4.3)  and  from data  resulting
                   from  the  NAPL Tracer monitoring program
                   (see Section 4.4.1.B3 below).

               0    Elements  of  SBNP  monitoring   for  the
                   Prototype  Bedrock  System will  include
                   quarterly   evaluation   of   cumulative
                   total  NAPL/APL  recovery data  for  the
                   Prototype  Bedrock   System   and  annual
                   assessment of the following:

                        NAPL/APL   ratios   on   individual
                        purge/recovery wells;

                        NAPL/APL ratios  on five monitoring
                        wells  located  south of  the Robert
                        Moses Parkway;

                        evaluation   of   NAPL   collection
                        decline  curves  and  the  radius  of
                        well  influence, on  an  individual
                        well basis.

               2.   The following SBNP  for  the  Prototype Bedrock

System will be  conducted in  purge/recovery  wells within  the

existing Bedrock NAPL  plume  not  along the River to monitor NAPL

recovery:

               0    Monitoring will begin upon  installation
                   of  the  Prototype  Bedrock  System  and
                   will continue until implementation of a
                   SBNP for the Bedrock RRT System.

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                              1-31
               0    Quarterly  monitoring  of  NAPL/APL ratios
                   in NAPL wells currently being pumped.

               0    Annual  monitoring of  NAPL/APL ratios in
                   NAPL  recovery  wells  which  have  been
                   shut off.

               0    Quarterly   evaluation   of   cumulative
                   NAPL/APL   recovery  data  for  Prototype
                   Bedrock System.

               0    Annual  evaluation  of  NAPL  collection
                   decline  curves   and   radius   of  well
                   influence/ on an  individual well basis.

               0    Quarterly  measurement of  NAPL levels in
                   all inner  piezometers of  the piezometer
                   pairs.

               3.   The following monitoring  for the presence of

NAPL beyond the existing Bedrock NAPL plume will be conducted:

               0    Monitoring  will  begin when piezometer
                   pairs and  Prototype Bedrock  System are
                   installed.

               0    Quarterly  frequency.

               0    Method:    hand    bailing   bottom   of
                   well/piezometer      or      performance
                   equivalent.

               0    Monitor  each  outside  piezometer  of the
                   piezometer pairs.

               0    Monitor   each   Shallow   Bedrock   well
                   within 200 feet  of  the outside boundary
                   of the Bedrock NAPL plume.

               (c)  Response Actions;

               If/  at  any  time  during   the operation  of  the

Prototype  Bedrock  System,   SBNP   monitoring   in  any  Shallow

Bedrock  well  or  piezometer  indicates   the presence of  NAPL

outside the previously-defined Bedrock NAPL plume/ OCC will:

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                              1-32
               0    Within  30  days thereafter,  modify the
                   operation   of  the   Prototype  Bedrock
                   System  and/or install additional wells,
                   if    necessary,    subject    to    the
                   Governmental    Parties    approval,    to
                   contain  NAPL, unless the  source of the
                   NAPL  is  demonstrated  not to be  from the
                   S-Area  NAPL  plume.   However,  following
                   OCC's  submission  of  the  final design
                   for  the  Bedrock RRT  System per Section
                   4.5.1.,  and until  implementation of the
                   Bedrock   RRT  System,   the    response
                   actions  triggered  by  the  SBNP  under
                   this   Subsection  4.4.1.B1   shall   be
                   limited   to  Operational  Modifications
                   (as defined in Subsection 5.1.1).

               0    Following  implementation  of   the  above
                   action(s),    adjust    the   monitoring
                   program,  as appropriate, to  assess  the
                   effectiveness  of  the  modified  remedial
                   system.

               0    Utilize   data   collected   from   the
                   adjusted    monitoring     program    in
                   designing  of  Phase  III  - Bedrock  RRT
                   System per Section 4.5.1.

         B2.   Shallow Bedrock Hydraulic Monitoring  Program:

               (a)  Monitoring  Obiactive;  The  objective of  the

Shallow  Bedrock  Hydraulic  Monitoring  Program  (SBHP)  is  to

evaluate the  effectiveness of the  Prototype Bedrock  System in

maintaining an inward  gradient across the areal boundary of the

S-Area Shallow Bedrock NAPL plume.

               (b)  Program Implementation;

               1.   SBHP  monitoring will  utilize the  following

wells:

               0    12  Shallow  Bedrock piezometer  pairs  to
                   be  installed  around  the  areal  boundary
                   of the Shallow Bedrock NAPL Plume:

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                              1-33
                        each pair  spaced no more  than  400
                        feet apart;

                        inner well of each  pair  within  and
                        no  more • than   100  feet  from  the
                        areal   boundary  of  the   Shallow
                        Bedrock NAPL plume.

              0    Selected   S-Area   and   Niagara   Plant
                   Shallow  Bedrock  wells   available  for
                   SBHP  monitoring will be  utilized  for
                   SBHP monitoring/ as appropriate.

              2.   Following   the  Prototype   Bedrock   System

installation  and  until Hydraulic  Stabilization  (as  defined  in

Section  4.4.1.A3.),  the  following monitoring of  the Prototype

Bedrock System will be conducted:

              0    Water  levels will be measured weekly in
                   all   Bedrock   Piezometer   pairs   and
                   selected existing Shallow Bedrock wells.

              0    Continuous   water    level   measurements
                   will   be  taken  on  two  well   pairs
                   (locations  to  be changed  from  time  to
                   time).

              0    Hydraulic  data  and  pumping   rates  from
                   Bedrock  purge  wells  will be evaluated
                   quarterly,  and pumping  rates  will  be
                   modified, as appropriate, at that time.

              3.   After   Hydraulic   Stabilization   following

installation  of   the  Prototype  Bedrock   System,  or   after

Hydraulic  Stabilization  following  any modification   to  the

System or  its operation,  the following SBHP monitoring will  be

conducted, and  will continue  until  implementation of  the SBHP

for the Bedrock RRT System:

              0    Water  levels in all  paired  piezometers
                   will be measured at  least weekly for 12
                   months   after   the   initial   Hydraulic
                   Stabilization  and  then  the  monitoring
                   frequency will be assessed.

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                              1-34

               0    Only    piezometer    pairs    will    be
                   monitored,    unless   response   action
                   criteria  from  any monitoring  program
                   (tracer,  chemical,  or  hydraulic)  are
                   triggered,  in which case other wells in
                   the   affected   area    also   will   be
                   monitored.
               (c)  Response Actions:
               1.   If,   after   Hydraulic  Stabilization,   the
monthly average of the water  level elevation difference between
any  piezometer pair  is  less  than 0.1  foot  (inward gradient),
OCC  will  within 30 days modify the operation of  the Prototype
Bedrock  System and/or  install  additional  wells,  if necessary,
subject  to the  Governmental  Parties  approval,  to  achieve  the
specified  inward  gradient.  Nothing  in this Subsection 4.4.1.B2
shall  require the  installation of  additional  wells  after  the
first 12 months of operation of  the Prototype Bedrock System.
               2.   After implementation  of  the  above action(s),
only the  area affected  by the modification will be evaluated to
determine   when   Hydraulic    Stabilization  occurs,   although
monitoring will continue in all  areas.

         B3.  Tracer Monitoring:
               (a)  APL Tracer Dispersion Testing Program;
              1.   Objective:
              The objective of the Tracer Dispersion Test  is to
ccllecc  information  (including  groundwater  velocity,  tracer
concentration profiles at receiving wells and  Bedrock porosity)

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                              1-35
for  use   in  assessing  the  feasibility  of   an   APL  Tracer

Monitoring  Program and,  if feasible/  for designing   a  Tracer

Monitoring Program for the Bedrock RRT System.

              2.   Program Implementation:

              (i)     The Tracer  Dispersion  Test  will  be
              conducted as follows:

              0    Perform    promptly     following     the
                   installation of  the Bedrock  purge  well
                   selected for the test.

              0    Inject a  water  soluble tracer  (Tracer
                   I)  into  a  Shallow Bedrock  well to be
                   installed in   the  northern  portion  of
                   the  existing   Bedrock  NAPL  plume,  100
                   feet  southeast  of  the  Bedrock  purge
                   well to be used for the test.

              0    Select  Tracer  I  which  satisfies  the
                   following criteria:   a  chemical  which
                   is highly soluble  in water,  unlikely to
                   have  significant chemical  or  physical
                   interaction with  the  Bedrock,  and  is
                   readily  capable   of   interference-free
                   detection   using   generally   accepted
                   analytical methods.

              0    Take and analyze APL samples  for  Tracer
                   I   from   six   Shallow  Bedrock   wells
                   (OW-225,    OW-23O,    OW-231,    OW-232,
                   OW-233, and Bedrock RRT  purge well  used
                   for test).

              0    Base the initial sampling  frequency for
                   each well on estimated  travel time  from
                   the injection  point to  the  well.

              0    Continue  sampling  until  the  first  of
                   the following  three conditions occurs:

                        the  concentration  of  Tracer  I  in
                        each  of  the   target  wells   has
                        fallen    to   50%    of   the   peak
                        concentration   measured   in   that
                        well; or

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                1-36
          the   start   of   the  pumping  test
          described in (ii) below; or

          one   year   after   injection,   if
          Tracer I  is  detected  in any target
          well   within   three   months   of
          injection  or before  the  start  of
          the pumping test (see (ii) below).

(ii)   The pumping  test will  be conducted as
follows:

0    Perform if  Tracer I  is  not detected in
     any target  well  within  three  months  of
     injection.

0    Perform after  injection  of the addition
     of  Tracer  I or  injection  of   a  second
     tracer  (Tracer IA)  if use  of  Tracer IA
     is   demonstrated   by   OCC   or   the
     Governmental Parties to be practicable.

0    The duration   of  well pumping will  be
     five  times the   estimated   travel  time
     from the injection point to the Bedrock
     purge well under pumping conditions.

0    APL samples from  the  Bedrock purge well
     used  for   the  test  will  be  taken  and
     analyzed for Tracer I or Tracer IA at a
     frequency to be determined  prior to the
     start of well pumping.

(iii)   The  following  performance  criteria
for  the  Tracer  Dispersion  Test   will  be
utilized:

0    Performance "Successful" if  Tracer  I  is
     detected  in a  target well before  the
     start  of the Pumping test.

0    Performance "Unsuccessful"  if  Tracer  I
     or  IA  is  not  detected in any  target
     well before or  during the pumping test.

0    If Tracer  I  or IA  is detected during,
     but not before  the  pumping  test/  OCC
     will    submit    a    report    to    the
     Governmental Parties  assessing  whether

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                              1-37


                   APL  tracer  monitoring  is  appropriate
                   for the Bedrock RRT System.

         (b)  NAPL Tracer Monitoring Program?

              1.   Monitoring Objective:  The objectives  of  the

NAPL Tracer Monitoring Program (NTP) are as follows:

              0    During the  first stage of the  program,
                   to  collect  information   on  the  volume
                   and  velocity of southward  NAPL  plume
                   migration   across   the   line   of   NAPL
                   recovery wells immediately north of the
                   Niagara  River,   as  shown  on Figure  2,
                   prior to the  installation and  operation
                   of the Prototype Bedrock System, and;

              0    During the  second stage of the  program,
                   to  collect  information  to   assist  in
                   evaluating  the  effectiveness   of  the
                   Prototype Bedrock  System  in containing
                   southward*  NAPL  plume migration  across
                   the   line   of   NAPL   recovery   wells
                   immediately north of  the  Niagara River,
                   as shown on Figure 2.
                                                  •
              2.   Program Implementation:

              (i)     During   the  first   stage  of   the
              program, NTP monitoring will be conducted as
              follows:

              0    Monitoring will  be initiated as soon as
                   possible

              0    OCC  will  select a  hydrophobic  tracer
                   (Tracer  II),  mix it  with S-Area  NAPL,
                   and  inject   this  mixture  into  wells
                   OW-244 and OW-245.

              0    APL  and  NAPL  from four  NAPL  recovery
                   wells  and  from  five  Shallow  Bedrock
                   monitoring  wells   along  the   Niagara
                   River  will  be  sampled   and   analyzed
                   serai-annually  for   two   years   after
                   injection,    and   annually   thereafter,
                   until Hydraulic  Stabilization  following
                   installation  of  the  Prototype  Bedrock
                   System.

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                              1-38
              (ii)     During   the  second  stage   of  the
              program, NTP monitoring will  be conducted as
              follows:

              0    Program  will   be   initiated   promptly
                   after Hydraulic  Stabilization  following
                   the     Prototype     Bedrock     System
                   installation.

              0    An  appropriate  second  tracer  (Tracer
                   HA) will be injected  into wells OW-244
                   and OW-245.

              0    NAPL will  be  sampled  and  analyzed  for
                   Tracer  HA  from   appropriate   Bedrock
                   purge/recovery   wells    and    Bedrock
                   monitoring wells  semi-annually  for  two
                   years   after   injection   and   annually
                   thereafter.

              0    Tracer  HA  will   be   replenished   by
                   additional  injections   over  time,   as
                   appropriate.

              0    Monitoring  for  Tracer  II  in  APL  and
                   NAPL  from wells  along  the River  will
                   continue after  Hydraulic Stabilization,
                   in  parallel  with  the  monitoring  for
                   Tracer HA in NAPL  from  these  and other
                   appropriate wells.

              0    The . results  of  the  monitoring  will be
                   submitted  annually  to the Governmental
                   Parties.

              (c)  Response  Actions:    If   NAPL   sampling  and

analysis  indicate  the presence of  Tracer II  and/or  Tracer IIA

in non-pumping  wells adjacent to the River,  OCC will within 30

days submit to.the Governmental Parties  a report  assessing what

modifications to  the operation of  the  Prototype  Bedrock System

and/or  installation  of   additional  wells   are   necessary  to

contain southward  NAPL plume migration across  the  line of NAPL

recovery  wells   immediately  north  of  the  Niagara  River,  as

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                              1-39
 shown  on  Figure  2.   Nothing in  this  Subsection 4.4.1.B3(b)

 shall  require installation of additional wells  after  the first

 24 months of  operation of  the  Prototype Bedrock System.

              Following  implementation of the  above action(s),

 OCC  will  adjust  the  monitoring  program/  as  appropriate,  to

 assess the effectiveness of the modified  remedial system.



         B4.  Baseline Chemical Monitoring;

              (a)  Monitoring  Objective!   The objective  of  the

 Baseline Chemical  Monitoring  is  to collect  information  for  use

 in  designing the  Shallow  Bedrock Chemical Monitoring  Program

 (SBCP) for the Bedrock RRT System.

              (b)  Program Implementation:

              1.   Baseline   Chemical   Monitoring   and   SBCP

monitoring will  be conducted on wells within  the  upper  30 feet

of  the   Bedrock  selected   from   three  concentric   "rings,"

including:

              0    an outer  ring  considerably beyond  the
                   S-Area  Bedrock  NAPL   Plume  and  inside
                   the EMP wells (outside the  influence  of
                   Bedrock RRT System and,  if  technically
                   practicable,   outside   any    chemical
                   plumes);

              0     a  middle  ring beyond  the Bedrock  NAPL
                   plume areal boundary   (i.e.. within  the
                   S-Area  APL  plume but  outside  the  NAPL
                   plume),    with    approximately    equal
                   numbers   of  wells   immediately  adjacent
                   to and  somewhat  removed from the areal
                   boundary of the  NAPL plume;

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                              1-40
               0    an  inner  ring  within the S-Area Bedrock
                   NAPL Plume;
               Existing  wells  and  wells  installed  for  other
monitoring  programs  will  be used  wherever  feasible;  however,
installation  of  up  to  eight  new  Shallow  Bedrock  monitoring
wells may be necessary.
               2.   SBCP  baseline monitoring  will  be conducted
as follows:
               0  .  Monitoring  will   begin  in  accordance
                   with the RRT Schedule.
               0    APL samples from  four inner ring,  eight
                   middle  ring,  and four  outer  ring  wells
                   will  be  collected  quarterly  for  two
                   years,   and   semi-annually  thereafter
                   until   the  start   of  SBCP  monitoring
                   following  Hydraulic   Stabilization  of
                   the Bedrock RRT System.
               0    Samples  will   be  analyzed  for TOX  and
                   baseline parameters.
4.4.2    PROTOTYPE   BEDROCK  SYSTEM   (Intermediate   and   Deep
         Bedrock Zones)
         A.   Remedial System:
         Al.  Refinement  of  NAPL Plume Boundary:  In  order to
design  the  Prototype  Bedrock  System  for  the  Bedrock  zones
beneath  the Shallow  Bedrock,  the extent  of  the NAPL  plume on
the eastern portion of the Site will be  defined  by installing a
supplemental  boring  about  250  feet  west  of   the  CWTP  pump
station.  The  supplemental boring will be installed  to  the top
of the Gasport Formation  using  the  same protocols specified for

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                              1-41


conducting  prior   survey  activities   (Judgment,   Addendum  I,

Paragraph B).

              Following  installation,  the  supplemental  boring

will  be  grouted if OCC  concludes and the  Governmental Parties

agree  that   it  is   inappropriate   to   use  this   boring  in

conjunction with the  Monitoring  Programs described  in Section

4.5.2.

         A2.  System  Design  and  Installation:  Based on  data

generated  by the  refinement  of  the  NAPL plume  boundary  and

other  available  data,  the  Prototype  Bedrock  System for  the

Intermediate and Deep Zones will be installed as follows

              0    Four   purge/recovery  wells   will   be
                   installed,   two   in   each    of    the
                   Intermediate  and  Deep  Zones  (maximum
                   depth to top of Gasport Formation).

              0    If   NAPL   has  been   found   in   the
                   supplemental  boring  installed  in  the
                   Intermediate/Deep   Zones,    a    third
                   purge/recovery  well  will  be  installed
                   in each zone where NAPL was so detected.

         A3.  System Evaluation:  The following  actions will be

taken  to  evaluate  the  capability  of  the  Prototype  Bedrock

System in attaining the objectives set forth in Subsection 4.1.

              0    Six  monitoring  wells/piezometers   will
                   be    installed   in   each   of    the
                   Intermediate and  Deep Zones  (12 wells)
                   outside  any existing  NAPL plume.   The
                   wells  in   the  Deep  Zones  shall  be
                   installed  tc  the top  of  the  Rochester
                   Formation.

              0    Each   purge  well   in  the   Prototype
                   Bedrock  System will  be pumped at  the
                   maximum  rate  achievable  (to a  maximum

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                              1-42
                   of  20 gal/min.)  for  a  duration of  48
                   hours.    Pumping   rates   and   water
                   elevations  in the  pump  test wells  and
                   monitoring  wells/piezometers   will   be
                   recorded and evaluated.
              0    Based  on  the  data  generated  by  the
                   individual  pump   testing/   the  entire
                   system,  including the individual  purge
                   wells, will be  assessed  to  determine if
                   it  is  capable of creating  an  inward
                   gradient  across  the  areal boundary of
                   the Bedrock NAPL Plume.
         B.   Intermediate/Deep Hydraulic Evaluation Program:
         Bl.  Objective:   The  objective of  the  Intermediate/
Deep  Zones Hydraulic  Evaluation Program (IDHP)  is to collect
hydraulic  data  for  use  in  designing  the  Intermediate/Deep
components  of   the   Bedrock  RRT  System   and  designing  the
hydraulic monitoring program for that System.
         B2.  Program Implementation:
              (a)  Based  on pump  test  results/   pumping  rates
will  be   set  to  maximize  NAPL/APL  containment  and   NAPL
recovery.  Pumping  rates will be  measured  and water elevations
will  be   taken   in  purge/recovery  wells.    Inward   gradient
monitoring will oe performed.
              (b)  OCC  will also  measure  water   elevations  in
six  observation  wells  in  the  Intermediate  Zone  and in  six
observation   wells   in   the  Deep   Zone   and    in   selected/
then-existing wells  located in these Zones  within 1000 feet of
the Landfill  Site.  These wells  will be installed during  Phase

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                              1-43

II  and  monitored  immediately  following  installation.   This
monitoring shall include:
              0    monthly frequency;
              0    two    continuous   digital    recorders
                   installed, one  in the Intermediate Zone
                   and one in the Deep Zone;
              0    reassessment after two years.
         B3.  Program  Evaluation:    Five  years  after  program
initiation,  OCC  will  submit  to   the   Governmental  Parties  a
report  assessing  the pump  test  results  and  all the  hydraulic
data  collected to  date  pursuant   to  the  Hydraulic  Evaluation
Program.   This  assessment  will   be used  to  design  a  final
hydraulic monitoring  program for  the  Intermediate/Deep Bedrock
Zones pursuant to Section 4.5.2.B,  infra.

4.5      PHASE  III  -  BEDROCK  RRT  SYSTEM  (Shallow  Bedrock,
         Intermediate/Deep Zones)
         4.5.1  REMEDIAL SYSTEM
         A.   The  Bedrock  RRT  System  will  be  designed  and
installed  in the  Shallow  Bedrock and  Intermediate/Deep  Zones
based on  the data generated from  the Phase  I  initial Testing
Program and  Phase II  Prototype Bedrock  System.  Evaluation of
that data  base to determine whether there are  sufficient data
to  complete final  Bedrock  System design  will  occur  one year
after  start-up  of   the  Prototype Bedrock  System.   OCC  will
submit  a  report to  the  Governmental Parties  assessing whether

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                              1-44
 the  data  are sufficient  for  this  purpose.   If OCC  and  the
 Governmental  Parties  agree that the data are sufficient for the
 final design/ OCC will submit a  final  Bedrock RRT System design
 within  90  days  thereafter.  If OCC and the Governmental Parties
 agree that the  data are not sufficient, the  additional  data to
 be  collected will  be  identified by  OCC  and  the Governmental
 Parties  and will  be collected  by OCC.  A re-evaluation  of the
 data  base will be  made  every six months.   Twenty-four months
 following  startup  of the  Prototype  Bedrock  System,  sufficient
 data  will  be deemed  to  have been collected  and  a final design
 will  be submitted by OCC to the Governmental Parties within 90
 days  thereafter.    Following approval  of  final  design  by the
 Governmental  Parties,  OCC  will install,  operate, monitor  and
 maintain  the Bedrock RRT  System to  attain  system design and
 remedial objectives.
         B.   The design of the Bedrock RRT System may modify
 among other things, the number of wells, pumping  rates  and well
 locations  used in the Prototype Bedrock System.  The design may
 also consider installation of a  Bedrock  grout curtain  along the
 edge of  the River.   The design for the Bedrock RRT System shall
 include  a  monitoring  program  as per  Section  4.5.2.   However,
 under the  Bedrock RRT System  design,  OCC will not  be required
 to install  purge/recovery wells in the Deep Zone  below  the top
of the  Gasport  Formation unless data  is collected showing NAPL
below the Gasport Formation.

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                              1-45
          4.5.2   MONITORING  PROGRAMS
          A.   NAPL Monitoring;
          Al.  Shallow Bedrock NAPL Monitoring:
              (a)  Monitoring   Objective;   The   Objective  of
 Shallow  Bedrock NAPL  Monitoring  Program (SBNP) is  to evaluate
 the  effectiveness of the  Bedrock  RRT  System  in  attaining its
 objectives as set forth  in  Section 1.0.
              (b)  Program  Implementation;
              1.   The SBNP  to monitor  NAPL  recovery by the
 Bedrock  RRT System  will be  designed after  two years  of SBNP
 monitoring of the Prototype Bedrock System.
              2.   The following  monitoring  for the presence of
 NAPL beyond the  existing Bedrock NAPL plume will be conducted:
              0    Monitoring  will  begin when  the Bedrock
                   RRT System is installed.
              0    Quarterly frequency.
              0    Method:    hand    bailing    bottom   of
                   well/piezometer      or      performance
                   equivalent.
              0    Monitor  each outside piezometer.
              0    Monitor   each  Shallow   Bedrock   well
                   within 200  feet  of the outside boundary
                   of  the Bedrock NAPL plume.
              (c)  Response Actions;
              1.   Response actions  will be determined for the
SBNF  monitoring of  NAPL  recovery  by  the  Bedrock RRT  System
based upon  the  data generated  from the  Phase  I Initial Testing
Program,   the  Phase   II  Prototype  Bedrock   System   and  the

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                              1-46
 associated  SBNP monitoring.  Response  actions relating to NAPL
 recovery   will   consist   of   monitoring    of   then-existing
 non-pumping  wells  to determine if they are capable of producing
 reasonable   amounts  of  NAPL  (and  thus  become  NAPL  recovery
 wells)   and/  if   necessary,  implementation  of  Operational
 Modifications  (as   defined   in  Section  5.1.1),  such  as  the
 installation of new  NAPL recovery wells.
              2.   If  SBNP monitoring  in  any  Shallow  Bedrock
 well  or piezometer  indicates  the  presence of  NAPL  outside the
 previously-defined Bedrock NAPL plume, OCC will:
              0    Proceed  pursuant  to  Section  5.1.1  to
                   determine        what        Operational
                   Modifications   (as  defined  in  Section
                   5.1.1)  to  the  Bedrock  RRT  System  are
                   required  to  contain  NAPL,  unless  the
                   source of  the NAPL  is demonstrated  not
                   to be from the S-Area NAPL plume.
              0    Following    implementation    of    the
                   Operational   Modifications   described
                   above,  adjust  monitoring  program,   as
                   appropriate,      to      assess      the
                   effectiveness of  the  modified remedial
                   system.
              0    If  further  SBNP  monitoring  indicates
                   that  action  described   above  is  not
                   effective  in containing  NAPL within  the
                   newly-defined  Bedrock  NAPL plume,  OCC
                   shall proceed pursuant to Section 5.1.2.
         A2.  Intermediate/Deep NAPL Monitoring:
              (a)  Monitoring  Objective;   The  objective  of the
Intermediate/Deep NAPL Monitoring  Program (IDNP)  is  to  monitor
the effectiveness  of the Bedrock  RRT System  at containing NAPL

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                              1-47
 in   the  Intermediate  and  Deep  Zones   within  the  vertical
 projection  of  the  existing Bedrock NAPL plume.
               (b)  Program   Implementation;    IDNP  monitoring
 will be conducted  as  follows:
               0    Begin  monitoring  immediately following
                   the       installation       of       the
                   Intermediate/Deep     Zones    Hydraulic
                   Evaluation Program observation wells;
               0    Hand       bail       from       selected
                   wells/piezometers  within  400   feet  of
                   the  Bedrock  NAPL  plume  in  Deep  and
                   Intermediate Zones;
               0    Annual monitoring frequency.
               (c)  Response   Actions;     If    IDNP   monitoring
 indicates  the  presence  of  NAPL  in any well  outside of  the
 previously-defined  NAPL  plume  in  the   Intermediate  or  Deep
 Bedrock Zones/  OCC will  take  response  actions  as  described in
 Section 4.5.2 Al.(c)(2).

         B.   Hydraulic Monitoring;
         Bl.  Shallow   Bedrock   Hydraulic   Monitoring:    The
 objective of  the Shallow  Bedrock  Hydraulic  Monitoring Program
 (SBHP)  is  to  evaluate  the  effectiveness of  the  Bedrock  RRT
 System  in  maintaining  an  inward  gradient  across  the  areal
boundary of the S-Area Shallow Bedrock NAPL plume.
              A  hydraulic monitoring  program  for  the Bedrock
RRT System  will be  developed  following  the completion  of  the
Prototype  Bedrock  program.    Final  monitoring  criteria  and

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                              1-48
response  actions  for the Bedrock  RRT System will  be developed
as part of the finalization of the Bedrock RRT System design.
         B2.  Intermediate/Deep  Zones Hydraulic Monitoring:   A
hydraulic  monitoring  program  for the  Intermediate  and  Deep
Bedrock  Zones will  be  assessed after completion  of  the  IDHP
pursuant  to  Section 4.4.2.B,  infra.   Based on  the  results  of
this   assessment/   OCC  will  design  a   hydraulic  monitoring
program,  including  final   monitoring  criteria  and  response
actions, as part of the Bedrock RRT System design.

         C.   Chemical Monitoring;
         Cl.  Shallow Bedrock Chemical Monitoring:
              (a)  Monitoring  Objective:   The objective  of the
Shallow  Bedrock  Chemical  Monitoring  Program  (SBCP)   is  to
evaluate,  in  conjunction   with  other   applicable  monitoring
programs, the effectiveness of the Bedrock RRT System.
              (b)  Program Implementation:   SBCP monitoring for
indicator chemicals will be conducted as follows:
              0    Upon  Hydraulic  Stabilization  following
                   installation of the Bedrock RRT  System,
                   indicator  chemicals  characteristic  of
                   the  S-Area Landfill  will  be  selected
                   based   on    detection    frequency   of
                   baseline   parameters   analyzed   during
                   Baseline Chemical Monitoring.
              0    The   need    to   include    additional
                   indicator     chemicals     which     are
                   characteristic of  N-Area  or other Plant
                   Site chemicals will be assessed  at this
                   time.

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                              1-49
               0    Monitoring  will  begin  within  60  days
                   after  Hydraulic  Stabilization  of  the
                   Bedrock  RRT  System  (Shallow  Zone)  and
                   selection    of   indicator   chemicals.
                   Baseline    Chemical   Monitoring   will
                   continue until indicator chemicals have
                   been  selected  by OCC  and  approved  by
                   the Governmental Parties.

               0    APL  samples  from  six  inner  ring,  16
                   middle  ring/  and  six outer  ring wells
                   will    be   collected    and    analyzed
                   send-annually  for indicator chemicals.

               0    Monitoring  of  some  or  all of  the  six
                   inner  ring  wells  may  be  discontinued
                   based    on    the    Baseline    Chemical
                   Monitoring  results.

               (c)  Response Actions;

               1.   OCC  will proceed  pursuant  to  Section  5.1.1

to determine the need  for  Operational Modifications (as defined

in Section 5.1.1) to the System if:

               0    A statistically significant increase in
                   SBCP  indicator  chemical concentrations
                   in  any  one or more  middle  ring well(s)
                   occurs.   "Significance"  is defined  as
                   an  increase,  over an appropriate number
                   of     sampling    rounds,     in    the
                   concentrations  of at least  one-half  of
                   the  SBCP indicator parameters which are
                   detected in each sampling round, with a
                   confidence  level greater that 95%.

               2.   If   further  SBCP   monitoring   indicates  a

statistically  significant  increase  in  SBCP  indicator  chemical

concentrations    following    implementation    of   Operational

Modifications, OCC shall proceed pursuant to Section 5.1.2.

              3.   The   SBCP,   including   sampling  frequency,

number of wells sampled, and  indicator chemicals analyzed, will

be reviewed and the need for SBCP modifications assessed if:

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                              1-50
               9     over  an appropriate number  of  sampling
                    rounds,  the  concentrations  of between
                    one-quarter  and  one-half  of  the SBCP
                    parameters  which  are  detected in each
                    sampling    round    increase    with   a
                    confidence level greater  than 95%;  or
               0     the  level  of TOX  in any well  increases
                    with  a  confidence  level  greater than
                    95% on  two  consecutive or three of five
                    consecutive sampling events.
         C2.   Intermediate/Deep    Zones   Chemical    Monitoring
               Program:
               (a)   Monitoring  Obiactive:   The  objective  of the
 Intermediate/Deep  Zones  Chemical  Monitoring Program (IDCP)  is
 to  collect  chemical data in the Intermediate and  Deep Zones and
 to  utilize  the data  in  developing a  final  chemical  monitoring
 program for those zones.
               (b)   Program   Implementation;     IDCP   monitoring
 will be conducted as  follows:
               0     Following   installation,   sample   and
                    analyze   each   well   once   for   SBCP
                    baseline parameters.
               0     Begin  monitoring   upon   the  start  of
                    Phase   III    (Start  of   Operation  of
                    Bedrock RRT System).
               0     Sample  six  wells  (new or  existing)  in
                    each of the Intermediate and Deep Zones.
               0     Sample and analyze  semi-annually.
               0    Analyze  samples    for  SBCP   indicator
                   chemicals selected  as discussed above.
               (c)  Response Actions;
              Five  years  after  initiation  of  IDCP, OCC  will
submit a report to  the Governmental Parties  assessing whether a

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                              1-51
 Chemical  Monitoring Program  (CMP)  in the Intermediate and Deep
 Zones  is  useful  in  evaluating system performance.   Based on the
 results  of that  assessment,  OCC  will,  if appropriate, design a
 CMP,  including  final monitoring  criteria,  and develop response
 actions,  subject  to  the Governmental Parties approval.

          D.   Tracer Monitoring:
          Dl.  APL Tracer Monitoring Program:
              (a)  Monitoring  Objective:   The  objective  of the
 APL  Tracer Monitoring  Program is  to evaluate, in conjunction
 with  other applicable  monitoring programs, the performance of
 the Bedrock RRT System.
              (b)  Program     Implementation:      APL    Tracer
Monitoring  will  be  conducted  as  follows:  if   the  Tracer
Dispersion  Test  is  deemed  successful  or  if   APL  Tracer
monitoring   is   deemed   appropriate   pursuant   to   Section
4.4.1.B3.(a):
              0    APL Tracer  Monitoring  will  be  initiated
                   after   all   piezometer   pairs   have
                   satisfied   the   hydraulic   monitoring
                   criteria (i.e..  at  least 0.1 ft. inward
                   head differential between the outer and
                   inner piezometer of each pair).
              0    Tracer I or Tracer IA will be  injected
                   in  the  inner   piezometer   of  the  pair
                   which  displays  the   smallest   inward
                   gradient.
              0    APL  samples  will  be  taken  from  the
                   outer  piezometer of  that  pair  and  at

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                              1-52
                   other   appropriate   Bedrock  RRT  purge
                   wells   at   a  frequency  based  on  the
                   results of  the dispersion test.
               0    Tracer   I   or   Tracer   IA  will   be
                   replenished  by   injecting  additional
                   tracer/ as  appropriate.
               0    Two  years  after  initial   injection  of
                   tracer  for APL  Monitoring/  OCC  will
                   initiate   an  assessment   whether  ATP
                   monitoring   is  useful   in  evaluating
                   system  performance  and submit  a report
                   containing   the   assessment   to   the
                   Governmental  Parties   within  60  days
                   after  initiation.   Such assessment will
                   consider    continuation/   modification/
                   and termination of ATP monitoring.
               (c)  Response    Actions;     If   ATP   monitoring
indicates  the presence of Tracer I  or Tracer  IA in an  outer
piezometer,  OCC  will  proceed pursuant  to  Section 5.1.1.  to
                                               i
determine what Operational Modifications  (as  defined in Section
5.1.1.) are  required  to contain APL within the existing Bedrock
NAPL   plume.     Following    implementation    of    Operational
Modifications  described above/ OCC will  adjust  the monitoring
program/  as  appropriate/  to  assess  the  effectiveness  of  the
modified remedial system.
              0    Following    Operational   Modifications
                   described   above/   if  ATP  monitoring
                   again indicates  the presence of Tracer
                   I  or Tracer IA  and at least  two years
                   have elapsed  since initial Tracer  I  or
                   Tracer  IA   injection/ OCC  shall proceed
                   as per Section 5.1.2

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                              1-53
          D2.   NAPL Tracer Monitoring Program:

               (a)   Monitoring  Objective;  The  objective of the

 NAPL  Tracer Monitoring  Program (NTP) is:

               0     To  collect  information  to evaluate  the
                    effectiveness  of  the Bedrock RRT System
                    in   containing  southward   NAPL  plume
                    migration   across   the   line   of  NAPL
                    recovery  wells immediately north of  the
                    Niagara River, as shown on Figure 2.

               (b)   Program     Implementation;    NTP  monitoring

 will  be  conducted  as follows:

               0     The   program   described    in   Section
                    4.4.1.B3.b(2)    will    be    continued
                    following   installation  of   the  Bedrock
                    RRT  System.

               0     The  results of  the monitoring  will  be
                    submitted  annually to  the  Governmental
                    Parties.   Five years after the Tracer
                    HA  injection, OCC  will submit a report
                    to   the  Governmental  Parties  assessing
                    whether  NTP  monitoring  is  useful  in
                    evaluating    system   performance    and
                    whether    the   program    should    be
                    continued,  modified or terminated.

               (c)   Response  Actions;    If  NAPL  sampling  and

 analysis  indicate  the  presence  of  Tracer II  or Tracer  HA in

 non-pumping  wells  adjacent  to  the  River,  OCC  will  proceed

 pursuant  to Section 5.1.1.

              Following   implementation   of   the   Operational

Modifications  described above, OCC will adjust  the monitoring

program,  as  appropriate,  to  assess   the  effectiveness  of  the

modified  remedial  system.   If further NTP  monitoring indicates

that  the  Operational  Modifications   described above   are  not

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                              1-54

 effective  in containing southward  NAPL plume  migration across
 the  line of  wells immediately  north  of the Niagara  River,  as
 shown on Figure 2, OCC will proceed pursuant to Section 5.1.2.

         E.   Environmental Monitoring Program
         El.  Monitoring   Objective;    The  objective   of   the
 Environmental  Monitoring  Program  (EMP)  is  to  evaluate  the
 effectiveness  of  the  Bedrock  RRT System  in  protecting  human
 health  and   the   environment   from  endangerment  by  chemical
 migration from the Landfill Site.
         E2.  Program Implementation:
              (a)  Plans  and specifications  for  the  installa-
 tion  of the  EMP wells  will  be  submitted  to  the Governmental
 Parties in conjunction with the Bedrock RRT System design.
              (b)  Eight  EMP wells  will  Ls installed  in  the
 Shallow  Bedrock   Zone   in  an   area  extending  from  west  to
 northeast  of  the  Landfill   Site   and  located   beyond   the
 groundwater  capture  zone  of  the Bedrock  RRT  System.   (See
 Figure 5.)
              (c)  Following  Hydraulic   Stabilization  of   the
Bedrock RRT  System, samples  will  be  collected  quarterly  from
the EMP wells and analyzed.
              (d)  Groundwater flow will  be  calculated based on
quarterly  elevation  data  gathered  from the  EMP  wells.   As

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                              1-55
necessary/   piezometers  or   other  wells  will   be  used  to

supplement   the  EMP  wells   for  the  purpose  of   calculating

groundwater  flow hydraulic data.

               (e)  The collected data will  be used to calculate

the  average  groundwater concentration  in  the monitored aquifer

for each EMP Parameter on a guarterly basis/ as follows:

               0    The  samples  collected   from the  eight
                   EMP wells  will  be analyzed  for  the EMP
                   Parameters  listed in subparagraph (f).
                   EMP  Parameters  not  detected  will  be
                   assigned   a  value   of   one-half  the
                   detection   level  for   that   sampling
                   period  if  during  such  sampling  the
                   parameter  is  detected in  a  sample from
                   any  of  the  eight wells;  otherwise,  it
                   will be assigned a value of zero.

               0    The  groundwater  flow weighted  average
                   aguifer concentration (AAC)  of  each EMP
                   Parameter  identified in  the  monitored
                   aguifer will then be calculated.

               (f)  For  the  purposes of the EMP/  the following

action levels will be applicable:

              EMP Parameter            EMP  Action Level (PPB)

              1/1 Oichloroethylene                5

              Endosulfan                         10

              Hezachlorocyclohezane
              (each isoraer)                        7

              2/3/7/8  TGDD equivalents            0.0005

              Hezachlorobenzene                   7

              Mirex (CIQ Cli2>                    7

              Tetrachloroethylene                 5

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                              1-56

         E3.  Response Actions:
              (a)   If the  AAC level calculated per subparagraph
E2(e)  exceeds the EMP Action  Level for the  same EMP Parameter
for   two  consecutive  quarters,   OCC  will,  within  30  days
thereafter,  submit  a   report  to   the  Governmental  Parties-
assessing what  Operational Modifications (as defined in Section.
5.1.1),  if any, are required to  reduce the  AAC levels for those
parameters.
              (b)   If further  EMP  monitoring indicates that the
Operational  Modifications  undertaken  pursuant   to  (a)  were
ineffective  in  reducing  the  AAC  level(s)  below  the indicated
EMP Action Level(s), OCC will proceed  pursuant to Section 5.1.2.
              (c)   With  respect  to   Hezachlorocyclohezane  and
Tetrachloroethylene,  response  actions under  this subparagraph
E3 need not be undertaken unless the  total  chemical  flux of all
EMP  Parameters   exceeds   a  calculated  response  action  flux
level.   This  response action  flux  level will be calculated as
the  sum of  the  EMP Action  Levels  times  the total monitored*
aquifer  flow.   The total  chemical  flux will .be  calculated, as
the  product  of  the  AAC,   calculated  pursuant to subparagraph
E2(e), and the total monitored aquifer flow.
              (d)The  EMP  will  continue unless or un  1  it  is
superseded by applicable Niagara Plant monitoring progr  s.

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                              1-57
  5.0  REMEDIAL SYSTEfl - RESPONSE ACTIONS. REASSESSMENTS.
 5.1      Procedures Regarding Response Actions
          Sections  2.0,   3.0,  and  4.0   above   set   forth  the
 remedial  systems   selected   to   address   the   environmental
 conditions  identified  at  the Landfill  Site.   The  monitoring..
 programs selected  for these remedial systems,  as  described  in
 Sections  2.0  and  4.0,  are  intended  to  determine whether  the
 objectives of these remedial systems  are  being  met and whether
 response actions  are required.
          The following is  the process  which the  parties have
 agreed   to  follow  if a  response  action is  triggered  by  the
 monitoring programs.

          5.1.1  Operational  Modifications
          A.   "Operational    Modifications"    are   defined    to
 consist  of upgrading existing  equipment,  changes  in operating
 pumping  rates of existing wells,  and  installation of new*wells
 or  other  equipment in order to  attain  the  objectives  of  the
 remedial   system  being  monitored.   Operational  Modifications
 shall    be   consistent    with   good   engineering   practice.
Operational  Modifications do not  include:    (i)  actions which
exceed the "maximum"  modifications  pursuant  to Section 5.1.1.B,
or  (ii)   if  such maximums have not  been established,  actions
which significantly alter the  basic  features of  the initially

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                              1-58
 installed  remedial  system  or associated  treatment or  storage
 facilities with respect to scope  or cost.
          B.   OCC shall propose,  as part of  the c  ign of  the
 Site Containment  System,  the  Overburden  RRT Sys¥ ,a,  and  the
 Bedrock  RRT  System,  specified  maximum modifications  to  that
 system (e.g..  maximum number  of  additional  wells  or  maximum
 increase    in   pumping  rates)   which   constitute  Operational
 Modifications.   OCC and EPA/State shall,  prior  to approval  of
 the  design for  a  final remedial  system, use their  best  efforts
 to  agree  to specified maximum modifications to  the system.   If
 OCC  and EPA/State cannot  agree to such maximums at the  time  of
 design approval, OCC will  implement the approved design  without
 such  maximums   and  either  OCC  or  EPA/State  may pursue  the
 resolution of maximums through dispute  resolution.
          C.    If,  during  operation of  any  of   the  remedial
 systems   described   in  Paragraph  B,  the  monitoring   program
 applicable  to   the   specific   remedial   system(s)   triggers
 Operational Modifications,   OCC  will   implement  Operational
 Modifications to those systems as  provided below:
         Cl.  OCC   shall   submit   an   assessment  report   to
 EPA/State  proposing what   Operational   Modifications  OCC  will
 implement.   However,  such report  shall not  be  : quired for
Operational Modification(s)  involving  only increase   rates  of
operation.

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                              1-59
          C2.   For those Operational Modifications not  requiring
 an assessment report, OCC shall  implement  the response  action,
 as soon  as  practicable/  and shall  notify  the EPA/State within
 fourteen  (14)  days  of  the  initial   response   action  trigger
 date.   Such notification shall be in writing  and shall describe
 the Operational  Hodification(s)  taken  or to   be  takene* the*
 reason for  taking  such raodification(s)/  and  the justification
 for the selected  level of  response.
          C3.   For  Operational   Modifications   requiring   an
 assessment  report/  OCC   will  submit   such   report  within
 twenty-one (21)  days of  the  initial   response  action  trigger
 date.   The report shall  include:   a  description of the problem/
 including data and  analyses; Operational  Modification(s)  that
 OCC has considered;  an  evaluation  of  the  proposed  Operational
 Modification(s)/  including  assumptions and  analyses  used  and
 justifications  for the proposal;  and the total time estimate to
 implement  each alternative.   As  soon  as  practicable but* not
 later  than thirty  (30)  days  after  EPA/State  approval  of- the
 Operational Modif ieation(s),  OCC  shall  submit  an implementation
 schedule   and  plans  and  specifications  (to  the  extent  not
 already  approved  for such  use)  for  the  approved  Operational
Modification(s).   OCC  shall  implement  Operational  Modifica-
tions/   following  ZPA/State   approval/  in  accordance   with;  the
approved schedule.

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                               1-60

          5.1.2  System Modifications and Supplements
          Al.  As   used  herein,   "System  Modifies   HIS"   are
 defined to  consist of physical  alterations  to an  J    remedial
 system that:
               0    are   above   and   beyond   Ope.ational
                    Modifications;
               0    are compatible  with  the installed  RRT
                    remedial systems;
               0    are designed to meet the same  goals  and
                    objectives   as   the    installed    RRT
                    remedial        systems.          (System
                    Modifications  may  be  accompanied,   as
                    necessary/  by  revisions   to   specific
                    monitoring program requirements.)
          A  System  Modification/   in  general,  is a  physical
 alteration  that   will  augment   or  otherwise   enhance   the
 performance  of  the   installed  RRT   remedial  system  without
 significantly   altering    the   installed   system   in   either
'technology,   scope,  or  function.   System  Modifications   are
 intended   to include  only  alterations  using   engineering  and
 construction practices  used  or accepted  for   use in  landfill
 containment  projects  or other industrial  projects  which  are
 applicable to the  materials  and hydrogeologic  conditions  found
 at   the  S-Area/Treatment   Plant  area   and  will   not   include
 unproven  new  technologies  or  source  control   efforts  such  as
 full  or partial  excavation,  vitrification,  etc.   Examples  of
 System  Modifications   include,  among   others,  additional   or
 relocated  hydraulic  collection  or  containment   installations
 (e.g..  well  installations,  slurry  or  grout   walls).   System

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                              1-61
 Modifications  shall be designed and installed  to be consistent
 with good engineering practice and cost-effective in compliance
 with Paragraph C.
          A2.   As used herein,  "System Supplements" are defined
 as  remedies using Remedial Technology  (as  defined in Paragraph
 4(a)  of  the  Judgment) which  are different than  those  used? in
 the installed RRT  remedial  systems and  which are  designed to
 supplement   an  RRT   system   by  specifically  addressing   the
 conditions  triggering the response  action.   System Supplements
 shall  be  designed  to  be  consistent  with  good  engineering
 practice  and cost-effective in compliance with Paragraph C.

          B.    If,   after   OCC  has  implemented   all  required
 Operational Modifications  pursuant  to  Section 5.1.1, and one or
 more  response  action triggers  described in Sections  2.0  or 4.0
 require OCC to  take  further  action pursuant  to  Section 5.1.2,
 OCC will  proceed as follows:
          Bl.  NAPL   and   Certain   Hydraulic   Monitoring;    The
 procedures  of  this  subparagraph B.I  will  be  applicable  if a
 response  action for  System  Modifications  is  triggered  by the
monitoring  described in  Section   2.3.1.C6   (Overburden  NAPL
Monitoring),   Section' 2.3.2.C2  (Inward   Gradient  Overburden
Hydraulic  Monitoring),  Sections  4.5.2.A1.C.2  and  4.5.2.A2.C
 (Bedrock  NAPL  Presence  Monitoring),   or   Section  4.5.2.B1

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                              1-62
 (Shallow Bedrock  Hydraulic Monitoring).   OCC  will  submit to
 EPA/State,  within 90 days  of  the response action trigger date/
 a  focused feasibility study which  evaluates alternative System
 Modifications  to  the remedial  system  which would enable the
 system to prevent  further  response  action triggers and meet the--
 system  objectives  of Section  1.0.  OCC's  focused feasibility-
                                                         • -"/w
 study will  address at least the following factors:
               0    The nature  and  extent  of the condition
                   triggering the response action;
               0    The  degree  to  which  each modification
                   alternative  will  enable  the  remedial
                   system   to   prevent   further  response
                   action  triggers  and  meet system design
                   objectives of Section 1.0; and
               0    The cost and schedule  for implementing
                   such modification alternative.
 After submission of  the  focused feasibility  study to EPA/State,
 the  parties will  proceed  as  described in  Paragraph C  of   this
 Section.
          B2.   Other  Monitoring:   For those  monitoring programs
 not  identified  in  subparagraph  Bl,   the  procedures  of   this
 subparagraph  B2 will  be  applicable  if  a  response  action is •
 triggered by  any  monitoring program described  in  Sections 2.0
 or 4.0  which  requires response  under  Section 5.1.2.   OCC  will
 prepare  the same  type  of  focused  feasibility  study  of System
Modifications  set  forth  in subparagraph  Bl.   The  feasibility
 study shall also  identify  and evaluate  System Supplements.  In
 addition,  if  OCC  chooses/  the  feasibility  study  may   also
evaluate whether System Modifications  or System Supplements are

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                              1-63

 "Requisite*  (as  defined in Paragraph 4(a) of  the Judgment) and
 whether   the  Environmental,  Chemical   or   Tracer  Monitoring
 Programs  accurately evaluate the  Remedial  System's performance
 in meeting the remedial objectives in Section  1.0.
         OCC  will  submit  this   focused feasibility  study  to
 EPA/State  within  90  days  after the  response  action  trigger
 date.   After submission  of  the  focused  feasibility study  to
 EPA/State, the parties will proceed as described in Paragraph C
 of this Section.

         C.   Within   120  days  following  receipt  of  an  OCC
 submission described  in Paragraph B,  EPA/State will respond in
 writing to  the  submission.   EPA/State  will  either  approve the
 recommendations  in OCC's  feasibility study or propose  (either
 from OCC's feasibility study  or any  similarly  prepared study of
 its   own)   cost-effective   System   Modifications  or   System
 Supplements,  as  appropriate, which  enable  the system  to  meet
 the  objectives   of  Section 1.0  and  effectively prevent  further
 response  action  triggers.   OCC  will  be required  to  implement
 the  System  Modifications  or System Supplements  proposed  by
 EPA/State in  accordance with the  terms  and conditions  of  this
 Section 5.0 unless, upon the evidence, the Court determines:
         Cl.  That  the EPA/State proposal does not  satisfy the
definition of  System Modifications  or  System  Supplements,  as
 appropriate,  set forth in subsection 5.1.2.A; or

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                              1-64
          C2.   That   considering  the   factors  set   forth  in
 Bl(a)-(c)   and  all  relevant  monitoring  date   it   would  be
 arbitrary  and  capricious  to  require  OCC   to   implement  the
 proposed  System  Modifications or System Supplements; or
          C3.   That,   in  the   case  of   System  Modifications.
 triggered by the monitoring  programs referenced  in  subsection
 B.2 or System  Supplements:
               (i)    the proposed  System  Modifications  or
               System  Supplements are not  "Requisite"  (as
               defined in Paragraph 4(b) of the Judgment; or
               (ii)   those  monitoring   triggers  are  not
               accurate   measurements   of   meeting   the
               applicable objectives.

          5.1.3   RRT Study
          If,   after   OCC   implements    all   required   System
Modifications  or  System Supplements to  the remedial  system,
pursuant  to  Section  5.1.2,  a response  action  described  in
Section  2.0  or  Section 4.0   is  still  being  triggered  by- a
monitoring  program  requiring  response and if  OCC  and EPA/State
agree  or  the  Court determines  that  no  further  modification(s)
will enable the  system to meet  the  system objectives  of Section
1.0, OCC  shall  undertake  an RRT  Study.  The RRT Study shall
include  an evaluation  of  whether   the   implementation  of  any
other  Remedial Technology  (including source  control)  would be
more effective in achieving the goals of the  Judgment  than the
installed  remedial  systems.  That  evaluation will be  based on

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                              1-65

 will  be based on the Requisite  Remedial  Technology criteria  of
 Paragraph 4  of  the Judgment.   OCC  will  implement  any  remedy
 selected  pursuant to Paragraph 4 of  the  Judgment in  accordance
 with  a  schedule approved  by EPA/State.

 5.2       Monitoring  Program Reassessment  and Modification
          5.2.1   Reassessment
          Every  five years  after  the  beginning of the operation
 of  the  Bedrock  RRT System,   OCC will  submit  to EPA/State  a
 reassessment  of such monitoring  programs (including  associated
 response   action triggers)  then  in  effect.   EPA/State  may
 require OCC  to  conduct a monitoring  program reassessment  sooner
 or at more frequent  intervals, if at  any  time, it is determined
 either  by agreement of  EPA/State  and OCC  or by  order of the
 Court,  that  there   is  an  endangerment  to human health,  the
 environment,  or the users of  the City of Niagara Falls drinking
 water resulting from chemical migration from  the Landfill Site-
 which is  not triggering  response actions then  in effect under
 Sections  2.0  and 4.0.  In  addition,  EPA/State,  the  City (when*
 conditions at the CWTP are specifically affected) or OCC  at its
 option,  may  conduct and, for good  cause,  submit to  the other
parties  a reassessment  of such monitoring programs,  provided
that it is conducted after the  first five year  assessment has.
been conducted and reviewed.

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                              1-66
          5.2.2  Modification
          As  a result  of  any reassessment conducted p»- -suant  to
 Section  5.2.1, EPA/State,  the  City (when conditions s   the  CWTP
 are   specifically  affected)  or  OCC  may   propose   .onitoring
 program   (including   associated   response   actior    triggers)
 modifications,  if  any, consistent  with  applicable  objectives
 described in  Section  1.0.   Such modifications  may  include,
 without  limitations,  the  following:   the number and location  of
 monitoring   sampling  points,   the   response  action   triggers
 associated  with  that  program,  the frequency of  such sampling,
 the  parameters  to be  analyzed,  the  levels  related  to   such
 parameters,  and  the frequency  of future reassessments  required
 in Section  5.2.1.  In the event  EPA/State  and OCC do  not agree
 regarding the proposed modification  of a  monitoring  program,
 the  party seeking such modification  may petition  the Court  to
 resolve  the  dispute.  The  petitioner  shall  bear  the  burden  to
 demonstrate  to the Court  that  the continued  utilization of the
 existing  monitoring   program   is  inappropriate  in  assessing
whether   a   remedial  system is  attaining   its  objectives-  as
described in Section 1.0  and  that the proposed modification  is
consistent with  those objectives.  If  the petitioner  seeks  to
change any response  action triggers  which are agreec.  uo as part
of the RRT Stipulation, there  will be  a  rebuttable i    sumption
that  the  response   actions  triggers  then  in  efft.t  under

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                              1-67
 Sections 2.0 and  4.0 are  appropriate measures  of  meeting  the
 objectives of Section 1.0.

 5.3       System Operation Reduction
          A.   Operation  of  any component  of  a  final  remedial
 system  installed  under  the S-Area  RRT Remedial  Plan  may*1 be?
 reduced  if it is determined by agreement of  OCC and  EPA/State,
 or by order  of the  Court, that  the  following  conditions  are
 met:    (1)  the  remedial  system  as   installed  and  without
 reductions is not  triggering  any applicable monitoring program
 response actions then in effect under  Sections  2.0  and 4.0  and
 (2)  the  operation of  the  proposed   reduced  system  would  not
 trigger   any  of  the applicable  monitoring  program  response
 actions   then  in   effect  under  Sections  2.0  and  4.0.   Such
 reduction may include a  reduction of  pumping rates  and/or in
 the  number  of   purge wells  and/or   recovery  wells.    If  such
 reduction triggers a response action  as  stated  above/ or if
 NAPL collection is reduced  as a result of  the system  reduction,
 OCC  shall  reinstitute  the  program  as it  existed before  the
 reduction.
         B.   Prior   to   any  system   reduction   described  in
 Section  5.3.A.  OCC shall  make a submission to EPA/State setting
 forth  its proposed  action  and  5.ts  assessment  of  the impact
thereof,   along  with all  underlying data.  Such submission shall
include,   without  limitation,   an evaluation  of  whether  more

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                              1-68

 frequent  monitoring of the reduced system for  a defined period
 of time is required/  the  need for continued maintenance of the
 subject system,  and the circumstances under which pre-reduction
 system operations would be resumed.
         C.   Within  60 days of  receipt of  such  submission,
 EPA/State  will  respond to  OCC in  writing  stating  either its
 agreement  or  disagreement with  OCC's position.   The operation
 and/or  maintenance  of  the  affected  remedial  system  may  be
 reduced  by  agreement  of  EPA/State and  OCC.   In  the  event
 EPA/State  disagrees with  OCC's  proposal/  the  reasons  for such
 disagreement will be set forth in its written response.
         D.   In  the  event that OCC  and EPA/State do not agree
 regarding  reduction of a  remedial system/  OCC  may petition the
 Court to  resolve the  dispute.  The operation and/or maintenance
 of  the   affected   remedial   system  may  be   reduced   if  OCC
 demonstrates to  the Court that  after such  reduction the system
 would not  trigger any  of  the response actions then  in effect
 under Sections 2.0  and 4.0.   During the pendency of the Court's
 review of the matter,  OCC  shall  continue  operation/  monitoring/.
 and  maintenance  of   the  affected  remedial   system  without
 implementing the proposed reductions.

5.4      Termination
         A.   Operation/ monitoring/  and  maintenance activities
undertaken in order to comply with the terms and  conditions  of

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                              1-69

 the Judgment and  the  RRT Stipulation  shall not  be terminated
 for 35 years following  submission of the  final  design for the
 Bedrock RRT System  as  per Section 4.5.1.   After such  35 year
 period,  all or  a  portion of such activities may be terminated
 if  it is determined,  by agreement of EPA/State  and OCC  or by
 order  of  the   Court,  that  such  activities  are  no   longer
 necessary to satisfy the  goals of  the Judgment.
          B.   Prior  to any termination  under this Section, OCC
 shall  submit   an  assessment  report  to  all  other  signatory
 parties  setting forth  the basis  for  its  proposed  termination
 along with  all data  relied upon by  OCC  in support  of  its
 position.   The  submission shall  include,  without  limitation,
 the following:   the impact  of  such termination with  regard to
 the objectives  of Section  1.0;  the basis  for  OCC's conclusion
 that  the  activities  are  no longer  necessary  to  satisfy the
 goals of  the  Judgment;   proposals  for  a  minimum three year
 post-termination  monitoring  program(s);  maintenance  programs
 for the  terminated  systems;  and  the response  actions  triggers
which would require  resumption of  terminated activities.
         C.   Within 60  days of  receipt  of such  submission,
EPA/State will  respond  to OCC  in writing  stating  either  its
agreement or  disagreement with  OCC's position.   In the  event
EPA/State disagrees  with OCC's  proposal,  the reasons  for such
disagreement will  be  set forth  in  its written  response.  The
operation,  monitoring  and/or  maintenance  of  the   subject

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                              1-70

 remedial   system(s)  may .be  terminated  by  agreement  of  the
 parties and  notice to  the Court or by order of the Court.
         D.    In  the event  that OCC and EPA/State do not agree
 regarding  termination under this  Section/  OCC may petition the
 Court  to  resolve the dispute.   OCC  shall  not  terminate  any
 activities  pursuant  to this  Section  until  a  deterstoafcioir
 described  in Paragraph A has been made, either by agreement of
 EPA/State  and  OCC or by  order of the Court.

 5.5      City  Review and Approval Responsibility
         A.    Submittals
         Any  time   a  submittal  or notice  is  required  under
 Section 5.0, copies  shall be provided to the City.
         B.    Approval
         Any   time    review,    approval,    determination   or
 concurrence  is required of  EPA/State under  Section  5.0,  the
 City  (when  conditions  at  the  CWTP are  specifically affected)
 may  also  conduct  a  concurrent review,  approval,  determination
 or concurrence process except that failure of the  City to issue
 its approval,  determination or  concurrence decision timely in a
 particular instance  shall be  deemed a waiver of that  right in
 that particular instance.
         C.   Comments
         Nothing  herein  shall  prevent the  City from submitting
timely comments on any  other submittals;  however, the  parties
shall  consider,  as  appropriate,   but  are  not  obligated  to
respond to or adopt any such comments.

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FIGDRES

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                                                                                        BARMEM WALLS

                                                                                        ALTERNATIVE BARRJCR WALL
                                                                                       OVERBURDEN
                                                                                       PUROE/REDIMEXr 1GLJL
                                                                                        OVERBURDEN
                                                                                        PURGE/RECOVERY
                                                                                        USED AS PCZOMETER
                                                                                         NOT PUMPED
                                                                               	PROPOSED 005 OUTFALL
                                                                                       REMJONMENT
                                                                                NOTE 1
                                                                                PO*O mm* nonto a LOCATED
                                                                                M 1HC OVERBURDEN. FCU>
                                                                                9PAOMO MAY RCOUMC 1HAT
                                                                                WALL K RELOCA1ED NOR1HWARO
                                                                                AS SHOWN.
IAGOONS
\  \\  \
                                                                                                 figure 1
                                                                               SITE CONTAINMENT AND
                                                                             OVERBURDEN  RRT SYSTEM
                                                                          S-AREA  REMEDIAL PROGRAM
                                                                      Occidental Chemical Corporation

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                                                                                                                                  too   zson
     LEGEND


     @   MAPI RECOVCTr TEST KU.

    —	OWKBURDEN NAPL PLUME

    ——— BEDROCK NAPL PLUME
      (Si)  COMMON TO BOTH BEDROCK PUMP TEST
       =X  AND NAPL RECOVERY TESTMO
                         figure 2
   NAPL RECOVERY TEST WELLS
   S-AREA REMEDIAL PROGRAM
Occidental Chemical Corporation
1789-21/06/W- 68-0

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                                                                                                                                 0  100   290ft
 CRA
     LEGEND


      (§)   BEDROCK PUMP TEST «EU

     	~  OVERBURDEN NAPL PLUME

    	BEDROCK MAPL PLUME

     /Sh   COMMON TO BOTH BEDROCK PUMP TEST
           AND NAPL RECOVERY TESTMC
                          figure 3
    BEDROCK  PUMP  TEST  WELLS
    S-AREA REMEDIAL PROGRAM
Occidental Chemical Corporation
1789-21/06/89-66-0

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                                                                                                                          I
                                                                                                                                     so
                                                                                                                                   LEGEND

                                                                                                                                   BARRIER WALLS

                                                                                                                                   ALTERNATIVE BARKER WALL

                                                                                                                                   PRESCWPTTVE GROUT PLUG

                                                                                                                                   Tl£ DRAM
                                                                                                                                  PURGE^ECOVERY
                                                                                                                         	PROPOSED 005 OUTFALL
                                                                                                                                  REALIGNMENT
                   MAINTENANCE KZDMCRX

                   ORAOENT IMMrrORMO
                                                                                                   WATER TREATMENT
                                                                                                       ..PLANT
                                                                                                                                           i son
                                                                                                                                               WEU
                                                                                                                                  POROE/TCCOVERY WELL
                                                                                                                                  USED AS PIEZOMETER
                                                                                                                                    NOT PUMPED
                                                                                                                          NOTE 1
                                                                                                                          PUWIR TOWER FOOTING S LOCATED
                                                                                                                          M THE OVERBURDEN. FKLD VERTED
                                                                                                                          SPACMG MAY REQURE THAT BARRCR
                                                                                                                          WALL BE RELOCATED NORTHWARD
                                                                                                                          AS SHOWN.
                                                                                      NIAGARA  RIVER
                            figure 4
        OVERBURDEN  MONITORING
    S-AREA  REMEDIAL PROGRAM
Occidental Chemical Corporation
5/89- 66-1

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                                                                         WATER TREATMENT PLANT
       EMP WELL IN SHALLOW AQUIFER

       ESTIMATED BEDROCK APL PLUME
       BEYOND THE NAPL PLUME
       PRIOR TO REMEDIATION
                                                                                DEFINED NAPL PLUME
V.,—ESTIMATED EXTENT OF
 \   NAPL PLUME MIGRATION IN
 V   BEDROCK BENEATH RIVER
figure 5
ENVIRONMENTAL MONITORING  PROGRAM
MONITORING  WELLS AND
ZONES IN SHALLOW AQUIFER
Occidental Chemical Corporation
                  CRA

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             APPENDIX II




ENVIRONMENTAL HEAT.T^ AND SAFETY PLAN

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                                 APPENDIX II

                      ENVIRONMENTAL HEALTH AND SAFETY PLAN


1.0   The Environmental  Health  and Safety  Plan  set forth  In Addendum V  of the
      Judgment is modified as follows:


2.0   Section D - PERSONNEL EQUIPMENT. CLOTHING AND HYGIENE

      2.1   Subparagraph (2)(c) shall be replaced by the following:

      (c)   Samples collected pursuant to subparagraph (a) at the Survey Site and the
            Working Site  shall be assessed for the major components of the organic
            vapors  (Subparagraph K(1)(c)).   In the  event  that the time weighted
            average  (TWA) exposure for  any  major component exceeds the
            appropriate American Conference of Government and Industrial Hygienists
            (ACGIH) Guideline, then the Safety Officer shall proceed as described in
            subparagraph (f).

      2.2   Subparagraph (2)(d) shall be replaced by the following:

      (d)   Samples collected pursuant to subparagraph (a)  at the Working Site shall
            be assessed for tetrachlorobenzene and hexachlorobenzene.  In the event
            the levels exceed 1 ppm (8 mg/nr) or 0.1 ppm (1 mg/nr) respectively,
            the Safety Officer shall proceed as described in subparagrapn (f).

      2.3   Subparagraph (2)(e) shall be replaced by the following:

      (e)   Within seven days of the  receipt of the analytical results, Hooker shall
            submit  to the Governmental  Parties all data relating to such  detected
            organic vapors and/or particulate levels.


3.0   Section J - SURVEY MONITORING

      3.1   Subparagraph (1)(a) shall be replaced with the following:

      (1) (a) Organic vapor levels shall be monitored periodically at the perimeter of the
            Survey  Site downwind of each Survey Site by use of a photoionization
            detector (PID), or its performance  equivalent   In  addition, the  major
            components of the organic vapors shall be periodically monitored  at the
            Survey Site.

      3.2   Subparagraph (1)(b) shall be replaced by the following:

      (b)   If the Time Weighted Average (TWA) exposure for any major component
            exceeds one-half of the appropriate ACGIH Guideline, then the Safety
            Officer  and  EPA/State  on-srte  representative  shall  determine what
            corrective action, it any, shall be taken.  (The turnaround time for analytical

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Page 2
Appendix II


            results will be specified in the plans.specifications and protocols.) Within
            seven days following receipt of analytical results, Hooker shall submit to
            the Governmental Parties all data relating to such detected organic vapor
            levels and the results of corrective action, if any, taken pursuant to this
            subparagraph.


4.0   SECTION K - SPECIAL CONSTRUCTION MONITORING

      4.1   Subparagraph (1)(a) shall be replaced by the following:

      (1) (a) Organic vapor levels shall be monitored continuously at each Working Site
            by use of a photoionization detector (PID), or its performance equivalent.
            In addition,  the  major components  of the organic  vapors  shall be
            periodically monitored at each Working Site.

      4.2   Subparagraph (1)(b) shall be replaced by the following:

      (b)   If the Time Weighted Average (TWA) exposure for any major component
            exceeds the  appropriate ACGIH Guideline then the Safety Officer arid
            EPA/State on-site representative shall determine what corrective action, if
            any, shall be taken.  Within  seven days following receipt of analytical
            results, Hooker shall submit to the Governmental Parties all data relating to
            such detected organic vapor levels and the results of corrective action, if
            any, taken pursuant to this subparagraph.

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                    APPENDIX III




CITY DRINKING WATER TREATMENT PLANT REMEDIAL PROGRAM

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                             APPENDIX III


         CITY DRINKING WATER TREATMENT PLANT REMEDIAL PROGRAM


                          TABLE OF CONTENTS


                                                            Page


 1. 0  INTRODUCTION	     III-l

 2.0  PLAN B	     III-l

     2.1   Collection System Configuration	     III-2

     2.2   Collection System Design	     III-3

     2.3   Collection System Operation	     III-4

     2.4   CWTP Service Line Monitoring
          and Response Actions	     III-5

          2.4.1     Purpose	     III-5
          2.4.2     Monitoring Program	     III-5
          2.4.3     Response Actions	     III-5

     2.5   O/TTP Vertical Gradient  Monitoring	     III-6

          2.5.1     Objective	     III-6
          2.5.2     Program Implementation	     III-6

     2.6   Emerald Channel Intake  Tunnel
          Monitoring	     III-7

     2.7   Distribution Water Monitoring	     111-12

     2.8   Monitoring Program Assessment	     111-23

     2.9   Inoperative Paragraph	     111-24

     2.10  48-Inch Raw Water Line  Monitoring	     111-24

     2.11  48-Inch Raw Water Line  Protection	     111-24
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                                                             Page


 3.0  INTERIM CWTP MONITORING
     AND RESPONSE ACTION PLAN	      111-26

     3.1  Interim Drinking Water Monitoring
          and Response Actions Program	      111-26

          3.1.1     Purpose	      111-26
          3.1.2     Water Monitoring	      111-26
          3.1.3     Response Actions	      111-28

     3.2  Interim NAPL Presence Monitoring
          and Response Action Program	      111-32

          3.2.1     Purpose	      111-32
          3.2.2     Investigations	      111-32
          3.2.3     Monitoring Program	      111-33
          3.2.4     Response Actions	      111-33

 4 . 0  EASTERN PORTION STUDY	      111-35

 5.0  EXISTING CWTP REMEDIAL/CLOSURE PLAN	      111-39

 FIGURES

 ATTACHMENT A  Plan A Milestone Schedule

 ATTACHMENT B  Plan B Bar Sequencing Schedule

 ATTACHMENT C  DWTP Closure/Remedial Plan

 ATTACHMENT D  New CWTP Project Cost Estimate
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13493-6:0.C.

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                                                       DRAFT
                                                   July 20.  1990
                          APPENDIX III
      CITY DRINKING WATER TREATMENT PLANT REMEDIAL PROGRAM

 1.0       INTRODUCTION
          The   City   Drinking  Water   Treatment  Plant   (CWTP)
 Remedial  Program described  in Section E of the  RRT Stipulation
 shall  include the  Interim CWTP Monitoring  and Response Action
 Plan  described below in Section  3.0  and either Plan A,  Plan B,
 or  any  alternative  plan  (Plan  "C")  agreed  to   pursuant  to
 Paragraphs  15 and  16,  Section E,  of the RRT  Stipulation.   Plan
 A consists  of  the  activities described in Paragraph 10,  Section
 E,  of the  RRT  Stipulation;  the Plan A Milestone  Schedule  is
 attached  as Attachment A.   Plan B  consists  of the  activities
 described   iu  Section  2.0  below;   the Pl-n  B  Bar  Sequencing
 Schedule  is attached  as Attachment B.
 2.0      PLAN  B
         Plan  B  consists  of  the implementation  by  OCC  and  the
 City  of  the  remedial  systems  and  associated  activities  as
 described in  Paragraph E of Addendum  I; Paragraphs  C through  I
 of Addendum II;  and  Paragraphs C, D(l)  and E of Addendum III,
 of  the Judgment,   except  as  modified  as  set  forth  in   this
 Section 2.0.
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                              III-2
          2.1  Collection System Configuration
          (a)  OCC will install  Collection Systems  ("hereinafter
 CWTP Collection  Systems")  for  the  pump  station,   Filtration
 Plant  "A"  and the  reservoir  at  the current  CWTP,  which  will
 include  the conceptual elements shown on  Figures  E-2, E-3,  and
 E-4  of the Judgment.
          (b)  OCC  will   repeat the  performance   of  soil   and
 groundwater surveys at  the five existing survey well  locations
 adjacent to Filtration Plant "B,"  as shown on Figure  III-2,  and
 shall  assess, as described in subparagraph E(3)(d), Addendum  I
 of  the  Judgment,  whether there  are  chemicals in the  Overburden
 in  the  vicinity of  Filtration Plant "B"  which  have migrated
 from the Landfill Site.  OCC  shall not be  required to  install
 the  component of the collection  system  adjacent to  Filtration
 Plant "B" unless  it  is  determined,  either  by agreement of  the
 signatory  parties  or  by  order  of  the  Court,  following  the
 aforementioned survey  and  assessment,   that  chemicals   have
 migrated  to  the  vicinity of  Filtration   Plant   "B"   in   the
 Overburden from  the  Landfill   Site  in  excess  of  the   survey
 levels  described  in  subparagraph E(3)(c),  Addendum  I  of  the
 Judgment.   OCC shall  submit a report  describing  the results of
 the  assessment described  in this  Paragraph  at  least 120  days
 prior  to   the scheduled   date  for   submission  of   plans   and
 specifications  for  design  of  the   Filtration Plant/Reservoir
Collection  System.
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                              III-3
          (c)   In addition, the  conceptual elements of  the CWTP
 Collection Systems for Filtration Plant  "A"  and the  reservoir/
 as  shown  on  Figures  E-3  and  E-4  of  the  Judgment,  will  be
 augmented  to  include  french  drain  laterals  to   the  30-inch
 ductile  iron waste water drain to provide groundwater control.
 The  conceptual  location  of  these  laterals  is  shown  on  Figure
 III-l.    OCC   shall,   as  a   component  of   the  plans   and
 specifications   to be   submitted   for   the  monitoring  systems
 described  in Paragraphs  C and  D of Addendum II, include  alarms
 which  are triggered  if  a collection system  is not functioning
 properly.
         2.2  Collection System  Design
         In  addition to  the  design considerations set  forth in
 Paragraph   E(2),   Addendum    I   of    the    Judgment,    design
 considerations   applicable  to  the   CWTP  Collection   Systems
 described  in Section  2.1 will include the following:
               (a)   Drain  tile  systems  will  be capable  of
         achieving  an   Overburden  groundwater  elevation
         lower  than  that of finished floors in the Plant  A
         clearwell,  the  filtered water  reservoir,  control
         chambers,  raw  water  forebays  and   high  service
         pump forebay.
              (b)   The   design  of  the  CWTP Collection
         Systems  will   allow  for  partially   flooded   and
         non-flooded  operation,  and  provide   operational
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                              III-4
          flexibility  sufficient   to   adjust   Overburden
          groundwater  elevations   adjacent   to   critical
          pipelines   and   structures.    This   operational
          flexibility may  require/  but  is not  limited  to,
          additional   sump   installations,  added   pumping
          capacity,    or    modifications   of    alignments
          conceptually  indicated in  the Judgment.
          2.3   Collection  System Operation
          (a)   The CWTP Collection Systems will  be  operated over
 a  range  of  groundwater elevations so  as to allow the systems to:
          (i)    minimize    the   submergence    of    active
                pipelines  and  structures   in   Overburden
                groundwater.
          (ii)   minimize   partial  dewatering  of   timber
                support pilings beneath these structures.
          (iii)  maintain,  in  conjunction with  appropriate
                CWTP operations, an  outward  gradient  from
                CWTP  structures  and  water  lines  to  the
                surrounding Overburden,  and
          (iv)   seek to  minimize upward vertical  gradients
                from the Bedrock to  the  Overburden  at  the
                CWTP outside of  the  RRT  and Site  Barrier
                Walls.
          (b)   The   operations  described   in  subparagraph  (a)
 shall be defined  and limited  by operating procedures  described
 in  a  collection system operations  manual to be  included  in the
design  plans   and  specifications for  this system submitted  to
the Governmental Parties.
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                              III-5

          (c)  Subparagraphs  (a)   and   (b)  shall  be  deemed  to
 supersede  the  requirements  of  Paragraphs  C(4)-(6)  and  D(4),
 Addendum II of the Judgment.
          2.4  CWTP Service Line Monitoring
               and Response Actions
               2.4.1  Purpose
          The  position  and  potential  movement   of   the  CWTP
 42-inch  diameter  low  service  lines  will   be   monitored  to
 evaluate the effects on the  timber  piles  supporting these lines
 of  lowering the Overburden water  table as a result of  remedial
 system operations at the CWTP.
               2.4.2  Monitoring Program
          The  CWTP  Service   Line  Monitoring  Program  shall  be
 implemented as follows:
               0    Proceed with  the   installation  of  the
                    tile  collection  system  and  dewatering
                    as provided  in Plan B;
               0    Monitor the  position   of  the  42-inch
                    diameter  low service discharge  line  for
                    any movement;  and
               0    Monitor   the   volume   of   groundwater
                    collected  from  the  drain  tile  system
                    pursuant  to Paragraph  C(l)(b),  Addendum
                    II  of  the  Judgment,   to   determine
                    possible   leakage   from   the   41-inch
                    diameter   low  service   lines   due   to
                    dewatering by  remedial  systems.
               2.4.3  Response Actions
          If  movement of the  low service  lines is detected,  or
if  there  is  leakage from those lines/  due  to  dewatering  by
remedial  systems,  OCC shall promptly so notify  the  Governmental
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                              III-6
 Parties and take  action (including, as appropriate,  raising of
 the groundwater table)  in consultation with  the City which is
 necessary and  appropriate to provide  adequate support  for  the
 service lines  in all affected areas and adequate  water  pressure
 in the City's  water distribution system.
          2.5  CWTP Vertical Gradient Monitoring
          OCC shall  implement the  CWTP Plant Vertical  Gradient
 Monitoring  Program described in  this section.
               2.5.1  Objective
          The objective of  this monitoring program is  to  monitor
 and record  the  vertical hydraulic gradient between the  Bedrock
 and Overburden at  the CWTP.
               2.5.2  Program Implementation
               (a)   Three shallow Bedrock piezometers  shall
          be  installed by  OCC outside   of  the  Site and  RRT
          Barrier Walls  at  the  CWTP,   as  shown  on Figure
          III-2.
               (b)   Water levels  will   be  measured monthly
          by  OCC in the three shallow Bedrock  piezometers
          described above at the  same  time as water  levels
          are measured in  the CWTP maintenance  piezometers
          and  in  the   CWTP  Collection  System  wetwells
          pursuant   to  Paragraph  D,  Addendum  II of  the
          Judgment.    Measurements  will  be  evaluated   to
          determine  the  direction  and magnitude of  the
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                              III-7

          vertical  hydraulic  gradient  between  the  Bedrock
          and  Overburden  at  the  CWTP  outside  of the  Site
          and  RRT Barrier Walls.   Results will be  reported
          monthly to  the Governmental Parties.
               (c)  This   monitoring    system    shall    be
          installed   concurrent   with   installation  of   the
          CWTP Collection Systems  described in Section  2.1
          above.    This  monitoring   program   shall    be
          initiated  upon  operation of the CWTP  Collection
          System.
          2.6   Emerald  Channel Intake Tunnel Monitoring
          (a)   Paragraph E(ll)(l),  Addendum I of  the Judgment is
replaced  by the  following:
               "(1) In  lieu of  the activities described  in
          subparagraphs (a)-(j),  Hooker may, at its  option,
          undertake  the  sleeving described in  subparagraph
          (k).   If  Hooker undertakes  such  sleeving,  Hooker
          and   the  City  shall  not thereafter  conduct  any
          activities  described in  subparagraphs   (a)-(j)  or
          subparagraph  (14)."
          (b)   After   the  last   sentence  of  Paragraph   E(2),
Addendum  II of the Judgment, the following sentence  is  added:
               "Hooker    shall    submit    the   statistical
          protocol  to  the Governmental  Parties  for their
          review   and   approval.    The   submission  shall
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                              III-8
          include  all  data   and  methodologies  used   in
          developing the statistical protocol."
          (c)   The  introductory  sentence  of   Paragraph  E(5),
Addendum II of the Judgment is replaced by the  following:
               "If statistical analysis of data  pursuant  to
          subparagraphs (2)-(4) indicates  that  both of  the
          conditions described  in  subparagraph (4)  exist,
          and   if  the  Emerald  Channel  Intake   Tunnel  and
          Shaft have  not  been sleeved  by Hooker,  the City
          and  Hooker shall  take the  following  actions:"
          (d)   Paragraph E(7),  Addendum  II  of  the  Judgment  is
replaced by the following  new paragraphs £(7),  E(8)  and E(9):
               "(7) If   Hooker undertakes  the  sleeving  of
          the  Emerald Channel Intake  Tunnel  and Shaft,  the
          City  shall  thereafter  conduct Emerald  Channel
          Intake Tunnel  Monitoring  to  determine  the  long
          term effectiveness  of  the newly  relined  intake
          tunnel  and  shafts.  Hooker and  the   City  shall
          proceed  as  described  below  if  both   of  the
          conditions  described in  subparagraph (4)  exist.
                    "(a) The  City   shall  immediately   so
               notify  Hooker  and  the   other  Governmental
               Parties.
                    "(b) The City shall  promptly  make  any
               appropriate  modifications to its  operational
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                              III-9

               or maintenance  activities at  the  Treatment
               Plant  which  are  required  to  address  CWTP
               Monitoring   Parameters   (as   defined    in
               Paragraph 3.1.2.1.(c),  Appendix  III of  the
               RRT  Stipulation)   entering   the   Treatment
               Plant water supply.
                    "(c) Upon   receiving  said  notification,
               Hooker     shall    promptly    undertake    an
               assessment,   using   all  available  data,   to
               evaluate  the  extent,  if any,  to which  the
               condition is a  result  of the  migration  of
               chemicals from   the  Landfill   Site  or   the
               Hooker   Buffalo   Avenue  Plant  through   the
               lining   of the  New  Intake  System.   To  the
               extent  required  to   achieve  this  objective,
               the assessment  shall include the  analysis of
               water samples from  the  Niagara  River in  the
               vicinity of  the  Emerald Channel  and/or  East
               Branch  Intake Shafts,   as  appropriate;  from
               the shoreshaft  of the New Intake  System;  and
               from appropriate locations  within  Treatment
               Plant  structures.   Hooker shall  submit  the
               assessment,   together  with  all   underlying
               data,  to the   Governmental  Parties within
               sixty  (60) days  following notification.   If
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                             111-10

               it  is  determined,  either  by  agreement  of
               Hooker  and  the  Governmental  Parties  or  by
               the order of the Court, that  chemicals which
               have  migrated from the  Landfill Site  or  the
               Hooker  Buffalo Avenue Plant are  entering  the
               Treatment Plant  water  supply   through  the
               lining  of the New Intake System,  the parties
               shall proceed  as described  in  subparagraph
               (8) below.
                    "(d) Hooker  shall  reimburse  the  City
               for    reasonable   costs    incurred    under
               Subparagraph (b)  to  address  chemicals  which
               have  migrated from   the   Landfill   Site  or
               Hooker  Buffalo Avenue Plant.
               "(8)  If so required pursuant  to  subparagraph
          (7)(c),  the  following  response actions  will  be
          undertaken:
                    "(a) If  such   chemicals  entering   the
               Treatment Plant water supply  as  described in
               subparagraph   (7)(c)   are   not  adequately
               addressed pursuant  to  subparagraph  (7)(b),
               Hooker  shall,  upon  written   request  by  the
               Governmental   Parties,   conduct   a  study  to
               determine     what     Requisite     Remedial
               Technology,  if any,  is required to  address
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                             III-ll

               the   condition.     This   study   shall   be
               submitted no  more  than  120  days  following
               the aforementioned request.
                    "(b) Following     such      submission,
               pursuant  to  Paragraph  6(9),  Addendum I  of
               the Judgment,  a  determination shall  be made
               regarding     what     Requisite     Remedial
               Technology,  if any,  shall be implemented  to
               address   chemicals  entering  the   Treatment
               Plant   water   supply    as   described   in
               subparagraph  (7)(c).
               "(9)  Hooker   shall  implement   all   remedial
          action    required   by   the   RRT    determination
          described in  subparagraph  (8)(b).   The  City will
          be  responsible  for those  costs  whicn  represent
          maintenance,   repairs   or  replacements  which  the
          City  would otherwise  be  required  to  perform  at
          the  same  level and  in  the  same  manner  in  the
          absence  of chemicals  in the Treatment Plant water
          supply   which  have migrated  from  the   Landfill
          Site."
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                             111-12

          2.7  Distribution Water Monitoring
          Paragraph F, Addendum II, of  the Judgment is  replaced
 by the following:
          "F.   Within  30  days   following  completion  of   all
 activities  described in  Paragraph E of Addendum I, as  modified
 pursuant  to Appendix  III,  Section 2.0  of the RRT  Stipulation,
 the City  and  Hooker shall  initiate the  following actions  to
 monitor the  quality  of  water  supplied  to  the   distribution
 system by the  Treatment Plant:
               "(1)   The City shall take a daily  (work day)
          grab   sample   of   distribution  water   from   a
         distribution water  tap located  at  the Treatment
         Plant.   Such  samples  shall  be analyzed  by  the
         City   for   chemical   parameters   described   in
         subparagraph  E(l)(b)   of   Addendum  II   at   the
         detection  levels specified  therein.
               "(2)    (a)   In  addition  to the  above,   the
         City  may  develop  and  implement  a  distribution
         water   monitoring   program  for  any   additional
         chemical.   If any such  chemical is  detected in
         four  consecutive samples, any signatory party  may
         propose  that such  chemical  be  added  to chemical
         parameters  described  in subparagraph (1).  Such
         chemicals  shall  be added  if  it  is  determined,
         either   by   agreement   of   Hooker   and    the
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                             111-13

          Governmental  Parties  or by  order  of  the  Court,
          that  such  action is  appropriate to collect  data
          necessary to  assess  the  impact, if  any,  on  the
          quality of the Treatment Plant distribution water
          resulting from chemicals  which  may have migrated
          from  the Landfill Site.
                    "(b)   As used in  this  Paragraph F,  the
          term   "Treatment   Plant  Monitoring  Parameter(s)"
          refers  to each chemical described in  subparagraph
          F(l)  and each  chemical  added thereto pursuant  to
          subparagraph  F(2)(a).
               "(3)   The  City  shall  make  available  to
          Hooker  and EPA/State  all data   generated  by  the
          monitoring  program, including QA/QC data.
               "(4)   (a)   Using  all  City monitoring  data
          for    Treatment   Plant   Monitoring    Parameters
          collected   during  the   initial  12   months   of
          observation,  Hooker  shall  establish  a baseline
          level  of  finished  water  quality  against  which
          subsequently-collected    chemical   concentration
          data  will  be  evaluated.    In   addition,   Hooker
          shall   develop   a   statistical   protocol,   using
          non-parametric  methods,  comparable to the  methods
          described  in  subparagraph  E(2),  Addendum  II,  to
          assess   whether  subsequently-collected  chemical
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          concentration  data   indicates  a   statistically
          significant  increase  over  the  baseline  level;
          provided,  however,  that the statistical  analysis
          shall be carried out  using the 0.01  significance
          level (99% confidence level).   The  protocol shall
          take  appropriate  account  of  seasonal  trends  in
          water temperature and  other factors  in  selecting
          time  periods   and   intervals   for   comparison.
          Hooker shall  submit  the  statistical protocol  to
          the  Governmental  Parties  for  their  review  and
          approval.   The submission  shall include  all  data
          and   methodologies    used   in   developing   the
          statistical protocol.
                    "(b)    Every  five   years  during   the
          course  of  such distribution   water  monitoring,
          Hooker shall  assess  the   appropriateness  of  the
          baseline  level  taking  into   account  the  then
          existing  quality  of  the  water  in  the   Emerald
          Channel  and/or East   Branch  Intake  Shaft,   the
          shoreshaft,  and the  distribution water.   Based  on
          such data, the baseline level   shall  be modified,
          as   appropriate,  to  reflect  such  water   quality
          conditions.
               "(5)   Prior to  and  after the  establishment
          of  the  baseline level  and  statistical  protocol
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          described  in  subparagraph  (4),   the   City  and
          Hooker shall proceed as described  in subparagraph
          (7)  if  monitoring described  in subparagraph  (1)
          or  (2)  indicates  either  of  the following:   (a)
          four consecutive samples having  a  Treatment Plant
          Monitoring   Parameter   concentration   level   in
          excess  of one-half  of  the  maximum  contaminant
          level  established under federal  or  state statutes
          applicable  to   any  such  parameter;  or   (b)   a
          verified   sample   having    a    Treatment   Plant
          Monitoring  Parameter  concentration  level  which
          requires  the   City  to   make  a   notification,
          pursuant  to  State  Sanitary  Code,  Public  Water
          Supplies,   Subpart  5-1,  that  a  violation  of  a
          maximum contaminant  level has occurred.
               "(6)   After  the  establishment and  approval
          of the  baseline  level and  statistical  protocol
          described   in  subparagraph  (4),   the   City  and
          Hooker shall proceed as described  in subparagraph
          (7)  in  the  event concentrations  of a  Treatment
          Plant    Monitoring     Parameter     indicate    a
          statistically  significant   increase   over   the
          established baseline  level.
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               "(7)     If    so    required   pursuant    to
          subparagraph (5)  or  (6),  the  City  and  Hooker
          shall take  the  following  actions:
                   "(a)   All  signatory  parties  shall  be
          immediately so  notified;
                   "(b)   The City  shall  promptly make  any
          appropriate modifications  to its  operational  or
          maintenance  activities   at   the Treatment  Plant
          which are   required  to  address Treatment  Plant
          Monitoring   Parameters   entering  the   Treatment
          Plant water supply.  Likewise/  Hooker shall  make
          any    modifications   to   its    operational   and
          maintenance activities relating to the  Treatment
          Plant remedial  systems (excluding  the New Intake
          System) which are  so  appropriate.
                   "(c)   Hooker  shall promptly  undertake
          an  assessment  of  the data  collected pursuant  to
          this  Paragraph  F, data  from  the   CWTP  Vertical
          Gradient Monitoring Program  (see RRT  Stipulation,
          Appendix   III,    Section   2.5)   and   all   other
          available data, to  evaluate the extent,  if  any,
          to  which   the   condition  is  a  result   of   the
          migration    of    Treatment    Plant   Monitoring
          Parameters   from  the  Landfill Site.    If   the
          condition  is to  any  extent  the  result of  such
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          migration,   Hooker  shall  identify  the  location
          where such  chemicals are  entering the  Treatment
          Plant water  supply.   To  the extent  required  to
          achieve   this  objective,  the   assessment   shall
          include  the  analysis of  water   samples  from  the
          Niagara  River in the  vicinity  of  the Emerald
          Channel  and/or   East Branch Intake  Shafts,   as
          appropriate;   from  the  shoreshaft  of   the   New
          Intake   System;   and   from appropriate  locations
          within  Treatment  Plant  structures.   In  addition
          if    such    condition   occurred    during   and/or
          immediately   subsequent   to   the   use   of   the
          Treatment  Plant  48-inch  raw  water line,  Hooker's
          assessment  shall  also  include  the  analysis   of
          water samples  from   the  Niagara  River in   the
          vicinity of  the  Treatment Plant  48-inch  raw water
          line   intake  structure   and  the  pump  station
          forehcy.   Hooker  shall  submit   the   assessment
          report,  together  with all underlying data,  to  the
          Governmental   Parties   within   sixty  (60)  days
          following  the  aforementioned  notification.    In
          the event  it is  determined either  by agreement of
          Hooker  and  the  Governmental Parties  or by  the
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          order  of  the  Court,  that  chemicals  which  have
          migrated from the Landfill  Site are entering  the
          Treatment  Plant  water supply,  the parties  shall
          proceed as described  in subparagraph (8)  below.
                    "(d)   The  City shall  be reimbursed by
          Hooker   for   reasonable  costs   incurred   under
          subparagraph (7)(b) to address  chemicals entering
          the Treatment  Plant  water  supply which  migrated
          from the Landfill Site.
               "(8)    If    so    required    pursuant    to
          subparagraph   (7)(c),    the   following   response
          actions shall be  undertaken:
                    "(a)     If    Landfill    Site    chemicals
          determined  to  be  entering  the  Treatment  Plant
          water   supply   per subparagraph  (7)(c)   are  not
          adequately  and  promptly  addressed pursuant   to
          subparagraph (7)(b),  Hooker  shall,  upon  written
          request    by     the    Governmental     Parties,
          ezpeditiously   conduct   a   focused   feasibility
          study.   The purpose  of  the  study  is  to  evaluate
          alternative  Treatment   Plant   Remedial   System
          Modifications,  if any, which could  be  implemented
          to   address  the   conditions.   As  used  herein,
          Treatment  Plant   Remedial   System  Modifications
          ("TPRS   Modifications")   are   defined   to  consist
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                             111-19


          solely of  either  the  installation of  additional

          components   to  the  Treatment  Plant   Collection
                              \

          Systems/  or the installation of purge wells  which

          would  achieve  the same  performance objective  as

          such  additional Collection System  components.   In

          addition,   in  the  event  that  chemicals   which

          migrated  from the  Landfill Site are determined  to

          be  entering  the Treatment Plant  water supply  in

          the  vicinity of the  Treatment  Plant  48-inch  raw

          water  line,  the  TPRS  Modification  alternatives

          shall  also  include  lining  or  sealing  interior

          portions  of such line.  OCC's focused feasibility

          study  will  address at  least the  following  factors:
          (1)  The   nature  and  extent  of  the   condition
              triggering  the  response  action;

          (2)  The  degree to  which the  TPRS Modifications
              will  enable  the  Treatment   Plant   remedial
              program  to  prevent   further  response  action
              triggers   and  to   meet  the  system  design
              objectives   of   Paragraph  G,  Section  1.0,
              Appendix I; and

          (3)  The  cost  and schedule  for implementing  such
              TPRS Modifications.
         This study  shall  be submitted to the Governmental

         Parties  within 60  days after  the  aforementioned

         request by  the Governmental Parties.

                   "(b)   Within 60  days following  receipt

         of   Hooker's  focused   feasibility   study,   the
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                             111-20

          Governmental Parties  will respond  in writing  to
          the submission.   The  Governmental  Parties  will
          either  approve  the  recommendations  in  Hooker's
          feasibility  study   or   propose   (either   from
          Hooker's  feasibility   study  or   any   similarly
          prepared study  of  its  own)  cost  effective  TPRS
          Modifications which  enable  the  Treatment  Plant
          remedial  systems  to   meet   the   system  design
          objectives  of Paragraph  G,  Section 1.0,  Appendix
          I,   and  effectively   prevent   further   response
          action  triggers.   Hooker will   be  required  to
          implement  the TPRS Modifications  proposed  by the
          Governmental Parties  unless,  upon the  evidence,
          the Court determines:
          (1)   that  the Governmental  Parties  proposal  does
               not   satisfy  the  definition  of   the   TPRS
               Modifications   set   forth  in   subparagraph
               (8)(a),  or
          (2)   that  considering  the  factors  set  forth  in
               subparagraph (8)(a)(l)-(3)  and  all  relevant
               monitoring  data,  it  would  be  arbitrary  and
               capricious  to  require  Hooker  to  implement
               the proposed TPRS  Modifications.
               "(9)   TPRS  Modifications  implemented  as  a
         result  of  a  focused feasibility study  will  be
         deemed   effective   when   the   Treatment   Plant
         Monitoring  Parameter  concentration   levels   have
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                             111-21

          been  reduced  to  previously  existing   baseline
          levels and  trend analyses  for each parameter  do
          not   indicate    a    statistically    significant
          increasing trend.
               "(10)   If,  after   Hooker   implements   all
          required     TPRS    Modifications    pursuant    to
          subparagraph (8)(b),  a  response  action  described
          in  subparagraph  (5)   or  (6)  is  still   being
          triggered,  and   if  Hooker  and  the Governmental
          Parties   agree  or  the  Court   determines  that  no
          further   TPRS  Modification(s)  will  enable   the
          Treatment  Plant   remedial  systems   to   meet  the
          system design objectives  of Paragraph G,  Section
          1.0 of Appendix  I  and to prevent response  action
          triggers,  Hooker shall undertake  an RRT  study  to
          assess what  response  actions,  if  any,   using
          Requisite   Remedial    Technology,    should    be
          implemented  to   satisfy   the   goals   of   the
          Judgment.   The RRT Study  shall include  analysis,
          review and  consideration of   all  available  data
          regarding  Treatment  Plant  Monitoring  Parameters
          and other relevant data that is available at that
          time  or that is provided  to Hooker  by EPA/State.
          The RRT Study shall also  include an evaluation  of
          whether the implementation  of  any other  remedial
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          technology,  including  without limitation,  lining
          the  interior   of  water-bearing   structures,   the
          relocating  of  underground  water  lines  to   the
          ground surface, or the placing of water  lines  in
          dewatered vaults,  would  be more effective  than
          modifications  to  the  installed  remedial  systems
          in achieving the goals of  the  Judgment;  provided,
          however,   that   such   technology  satisfies   the
          definition of  Requisite  Remedial Technology  set
          forth in  Paragraph 4  of the Judgment.  This study
          shall be  submitted  to the  Governmental  Parties
          within  60  days   following  the   aforementioned
          notification.
               "(11)  Hooker shall   implement  all  remedial
          actions  required  by  the  determination  described
          in subparagraph  (10)  above in accordance with  a
          schedule   approved  by  the  Governmental  Parties.
          The  City  will  be  responsible  for  those costs
          which    represent    maintenance,    repairs    or
          replacements  which  the City would  otherwise  be
          required  to perform  at the same  level and in  the
          same  manner in the  absence of  chemicals in  the
          Treatment  Plant water  supply which have  migrated
          from  the Landfill Site.*
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          2.8  Monitoring Program Assessment
          Paragraph  G,   Addendum  II  of  the  Judgment  is
 replaced by the following:
               "G.   Based  on   all   available   data,   an
          assessment of  monitoring  programs referenced  in
          Paragraphs E and F of Addendum  II shall  be made
          five  years  after  the New  Intake  System is  put
          into  operation  by  the  City,   and  a  reassessment
          shall be made  once every ten  years thereafter  by
          Hooker to evaluate the  following,  at a  minimum:
          the  number  and   location  of  sampling   points
          referenced in  Paragraphs E and F of Addendum  II;
          the frequency  of such sampling;  the parameters  to
          be analyzed;   the  detection   and  action  levels
          related to such parameters;  the adequacy of  the
          statistical  procedures  used  to  assess the  data;
          and frequency  of  future  reassessments  per  this
          section.    An   unscheduled  reassessment   may   be
          undertaken if  the  party seeking  the .reassessment
          demonstrates     that     such    reassessment     is
          necessary.     Following    such   assessment    or
          reassessment,   appropriate  modifications   to  the
          monitoring  programs   described  in  Addendum   II
          shall  be  made  either  by agreement  of  Hooker  and
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                             111-24

          the  Governmental  Parties,  or  by  order  of  the
          Court."
          2.9  Inoperative Paragraph
          Paragraph  E(13),   Addendum  I,  of  the   Judgment   is
 inoperative.
          2.10  48-Inch Raw Water Line  Monitoring
          The City shall develop sampling and  analysis protocols
 to  assess the  quality of water in the 48-inch  raw water  line
 for each  of  the following events:
          (i)   Use of the 48-inch raw water  line during  a
                non-emergency maintenance  and/or cleaning
                activity;  and
          (ii)   Use of the 48-inch  raw water line during  an
                emergency   which  requires  a  supplemental
                source of  raw water.
 The  protocols  shall  include   sampling  and  analysis   of   an
 appropriate  number of water samples  representative  of the water
 in such  line,  and/or being  supplied  by  such  line.   The  samples
 shall be  analyzed for the Treatment  Plant Monitoring  Parameters
 set forth in subsection 2.7, paragraph  F(2)(b).   The  protocols
will be  submitted  to EPA/State for  approval  at  least 120 days
prior to  the scheduled date for City use of  the newly  relined
bedrock intake  tunnel.
          2.11 48-Inch Raw Water Line  Protection
          Based  on the Additional  Investigations  (as  defined  in
subsection  3.2.2  below),  and   monitoring  programs  undertaken
pursuant  to  Section  3.2  and all  other  relevant and  available
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                              111-25

 data/  OCC shall prepare  and submit to the  Governmental Parties
 an RRT  study assessing  what  actions,  if  any,  using Requisite
 Remedial  Technology,   are  required  to  protect  water  in  the
 48-inch  intake  line from impact by  the NAPL  plume  (including
 the associated APL  within the  NAPL  plume).   In no  event will
 the eastern portion of the Barrier Wall be located east of the
 48-inch  line.   If  NAPL  is  found east  of the   Barrier  Wall
 location,  then  it  will  be  addressed pursuant  to  Appendix I,
 Subsection 2.3.1 C5 and  C6.  OCC  shall  prepare and submit the
 RRT study  no later  than  120  days following  the  determination
 that Plan  B  will  be  implemented.
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                             111-26
 3.0      INTERIM CWTP MONITORING
          AND RESPONSE ACTION PLAN
          3.1  Interim Drinking Water Monitoring
               and Response Actions Program
               3.1.1  Purpose
          The purpose  of  this  Program  is  to monitor  for  the
 possible presence of chemicals which migrated  from  the  Landfill
 Site   in the  water  supplied   by  the CWTP during  the  interim
 period before  the new  CWTP  described  in  Plan  A  or  remedial
 systems  described  in  Plan B  are  fully  operational and  to  take
 response actions  in  the  event  that  any  such  chemicals  are
 detected.
               3.1.2  Water Monitoring
               3.1.2.1  (a)  The  City shall continue  to  monitor
 the current  raw  and  finished  drinking  water   from  sampling
 locations  currently  being utilized  for  the  following  list  of
 CWTP   Monitoring   Parameters   at   the   levels   specified   in
 subparagraph E(l)(b),  Addendum II  of the  Judgment:

                    trichlorobenzenes
                    hezachlorobutadiene (C-46)
                    hezachlorocyclopentadiene (C-56)
                    tetrachlorobenzenes
                    hezachlorobenzene (HCB)
                    2,4,5  trichlorophenol  (2,4,5 TCP)

               (b)    In addition  to  the  above,   the  City  may
develop  and  implement   a water  monitoring   program  for   any
additional chemicals.   If any such  chemical is detected  in  four
consecutive samples,  any signatory party may  propose that  such
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                             111-27

 chemical   be  added  to  the   list   described  in  subparagraph
 3.1.2.1(a).   Such chemicals  shall  be added if it  is  determined,
 either  by agreement  of  OCC and the Governmental Parties  or  by
 order of  the Court, that such  action is appropriate to  collect
 data  necessary to assess the  impact,  if any, on  the quality  of
 the  CWTP water  supply  resulting from  chemicals which may have
 migrated  from the Landfill Site.
               (c)   As used in this  Section  3.0, the term  "CWTP
 Monitoring   Parameter(s)"  refers  to  each  chemical  listed  in
 subparagraph (a)  and each  chemical added to the list  pursuant
 to subparagraph  (b).
               3.1.2.2    The  City  shall  make available  to OCC
 and  EPA/State  all data generated  by  the  monitoring  program,
 including QA/QC  data.
               3.1.2.3    Using  City  monitoring data provided  to
 OCC  for  CWTP Monitoring Parameters  for  at  least  12  consecutive
 months prior to  September 1. 1990,  OCC  shall establish  baseline
 levels of raw water  and finished  water quality  against  which
 subsequently-collected   chemical  concentration  data  will   be
 evaluated.    In   addition,   OCC  shall  develop   a   statistical
 protocol,  using  non-parametric  methods,   to  assess   whether
 subsequently-collected  chemical concentration data  indicates  a
 statistically  significant  increase  over the  baseline  level;
 provided,  however,  that  the   statistical   analysis  shall   be
 carried out  using  the  0.05 significance  level  (95% confidence
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                             111-28

 level)  for raw water  results  and  the  0.01  significance  level
 (99%  confidence level)  for  finished water.  The protocol  shall
 take   appropriate   account   of   seasonal   trends   in   water
 temperature  and  other  factors  in  selecting  time periods  and
 intervals  for comparison.  Within  90 days following the lodging
 of  the  RRT  Stipulation,  OCC  shall   submit   the statistical
 protocol   to  the  Governmental  Parties  for  their review  and
 approval.    The   submission   shall   include   all   data   and
 methodologies used in  developing the statistical protocol.
              3.1.3  Response Actions
              3.1.3.1   Prior  to and  after  the  establishment  of
 the   baseline   level  and  statistical  protocol   described   in
 subparagraph  3.1.3.2,   the   City   and  OCC  shall  proceed   as
 described  in  subparagraph  3.1.3.3  if  monitoring  pursuant  to
 subparagraph 3.1.2 indicates  either of the following:   (a)  four
 consecutive   samples   having  a   CWTP   Monitoring   Parameter
 concentration   level   in excess  of one-half   of   the  maximum
 contaminant  level established  under federal or state  statutes
 applicable to  any such chemical;  or  (b)  a   verified  sample
 having  a  CWTP  Monitoring  Parameter concentration level  which
 requires  the  City  to  make  a notification/  pursuant  to  State
 Sanitary   Code,  Public  Water  Supplies,  Subpart  5-1,  that  a
violation  of a maximum contaminant  level has occurred.
              3.1.3.2   After  the establishment  and approval  of
the  baseline   level   and   statistical  protocol   described   in
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                             111-29

 subparagraph  3.1.2.3,  the  City   and   OCC  shall  proceed  as
 described in subparagraph  3.1.3.3   in  the  event  concentrations
 of  a  CWTP  Monitoring  Parameter  indicate   a   statistically
 significant  increase over  the  established baseline level.
              3.1.3.3  If  so required pursuant  to subparagraphs
 3.1.3.1  or 3.1.3.2,  the City  and OCC  shall take  the  following
 actions:
               (a)   All   signatory   parties   shall    be
          immediately so  notified; and
               (b)   The  City   shall  promptly   make   any
          appropriate modifications  to  its  operational  and
          maintenance  activities  which  are  required   to
          address  CWTP Monitoring  Parameters entering  that
          CWTP water supply.
               (c)   OCC   shall   promptly    undertake    an
          assessment to  evaluate whether  the condition  is
          the  result of the migration of  chemicals from the
          Landfill  Site into the CWTP water supply  system
          and/  if   so,  shall  identify  the  location where
          such   chemicals  are   entering   the  CWTP  water
          supply.   To  the  extent required  to achieve  this
          objective,   the  assessment  shall  include   the
          analysis   of water   samples  collected  from   the
          Niagara  River  in  the  vicinity  of the 48-inch
          intake,  from the shoreshaft  and from  appropriate
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                             111-30

          locations  within  CWTP  structures.   OCC   shall
          submit  an  assessment  report,   together  with  all
          underlying   data,  to  the  Governmental   Parties
          within   60   days  following  the   aforementioned
          notification.    In  the  event  it  is  determined,
          either by  agreement  of  OCC and the  Governmental
          Parties or  by order of  the Court,  that  chemicals
          which  have  migrated  from  the  Landfill  Site  are
          entering the  CWTP water supply, the parties  shall
          proceed as  described  in subparagraph  3.1.3.4.
               (d)  The City  shall be reimbursed by OCC  for
          reasonable  costs incurred  under subparagraph  (b)
          to   address  chemicals   entering the   CWTP   water
          supply which  migrated  from  the Landfill Site.
               3.1.3.4   If so  required  pursuant to subparagraph
3.1.3.3(c),  the following actions  shall be undertaken:
               (a)  If  Landfill  Site  chemicals determined
          to   be   entering  the   CWTP   water   supply   per
          subparagraph  3.1.3.3(c)  are  not  adequately  and
          promptly   addressed   pursuant   to   subparagraph
          3.1.3.3.(b)    above,    OCC   shall   ezpeditiously
          conduct  a  "focused  RRT  study"  to  assess what
          response   actions,    if   any,    using   Requisite
          Remedial  Technology,   should  be   implemented   to
          satisfy the  goals  of  the  Judgment.   The   study
6344o:KSW:03/20/90
Revised:  07/19/90
13493-6:D.C.

-------
                             111-31

          shall include  analysis,  review and  consideration
          of  all  available data  regarding  CWTP  Monitoring
          Parameters  and  other   relevant   data   that   is
          available at that time or that is provided  to  OCC
          by  EPA/State.   This  study  shall  be  submitted to
          the Governmental Parties within 60 days following
          the  aforementioned   determination.    As  used   in
          this   subsection  and   subsection  3.2.3   below,
          •focused RRT  Study"   means  a  study  described  in
          Paragraph B(8), Addendum I  of the Judgment  which
          evaluates  only   the   following   actions   using
          Requisite Remedial Technology:
                    The   lining  of  operative  CWTP   water
                    service  lines,
                    Installation     of     CWTP    collection
                    system(s);  and/or
                    Installation  of purge  wells  at the CWTP.
               (b)  Following  the  submission  described  in
         subparagraph  (a),  a determination shall be  made,
         pursuant  to  Paragraph  B(9),  Addendum I  of  the
         Judgment,   regarding   what   Requisite  Remedial
         Technology,  if any, should be implemented by OCC
         to  address  chemicals  entering   the  CWTP  water
         supply which have migrated  from the Landfill  Site.
6344o:KSH:03/20/90
Revised:  07/19/90
13493-6:D.C.

-------
                             111-32

               (c)   OCC   shall   implement   all   remedial
          actions  required  by  the determination  described
          in   subparagraph    (b).     The   City   will   be
          responsible  for   those   costs  which  represent
          maintenance,  repairs  or  replacements  which  the
          City would  otherwise  be required  to perform  at
          the same  level and   in  the  same manner  in  the
          absence  of  chemicals  in the CWTP  water  supply
          which have migrated from  the Landfill  Site.
          3.2  Interim  NAPL  Presence Monitoring
               and Response  Action  Program
              3.2.1 Purpose
          The purpose of  this  program is to assess whether  NAPL
 is   present  on  CWTP   property  in   the  Overburden   outside
 identified  areas of  the defined  S-Area  Overburden  NAPL  plume
 and  to  take appropriate  response  actions  in the  event NAPL  is
 identified.
              3.2.2 Investigations
          OCC shall  undertake  the investigations  regarding  the
 presence  of  NAPL   in  the  vicinity   of  the  48-inch  raw  water
 intake  described in the document  "Additional Investigations,
 City of Niagara  Falls  Drinking Water  Treatment Plant, July  31,
 1989"  ("Additional  Investigations").   OCC will  use  its  best
 efforts   to   complete   field   work   for    the    Additional
 Investigations  by  November  1,  1990.  If  NAPL  is  identified
during installation of  any  borings or wells installed  pursuant
6344o:KSW:03/20/90
Revised:  07/19/90
13493-6:D.C.

-------
                             111-33

 to  the  Additional  Investigations,  OCC   shall   conduct  NAPL
 mobility testing as described in  Paragraph E(4)(b), Addendum  I
 of the  Judgment  on appropriate soil  samples.
               3.2.3 Monitoring  Program
          Each  of  the  four NAPL monitoring wells,  the  existing
 well  OW-265,  and  the monitoring  wells  east  and  west  of  the
 D-Building  at  the  CWTP,  as  shown  in  Figure  III-2,  shall  be
 initially monitored quarterly for the presence of NAPL.   This
 will  be accomplished by lowering  a  bottom  loading bailer to the
 bottom  of  the well and  examining  the  contents  of the  bailer
 upon  removal from  the  well.   The field  observation data  shall
 be  submitted   to  the  Governmental  Parties  following   each
 quarterly monitoring event.   After  completion of  construction
 of the  eastern-most barrier wall  between the Landfill Site  and
 the  existing CWTP,  such  monitoring  will be  conducted  annually.
 Such  monitoring shall  be continued until  the earlier  of  the
 following:   (i)  OCC demonstrates that remedial  or monitoring
 systems   have  been  installed   which  render  such monitoring
 unnecessary;   or   (ii)  drinking  water  supply  operations  have
 ceased at the  existing CWTP.
               3.2.4  Response Actions
          If NAPL  is identified  in any boring or well  described
 in  subparagraphs  3.2.2  or  3.2.3,  OCC  shall, within  60  days,
 submit  to  the Governmental  Parties  a  focused  RRT  Study  (as
defined  in  subsection  3.1.3.4)  assessing what  response  actions,
6344o:KSW:03/20/90
Revised:  07/19/90
13493-6:0.C.

-------
                               111-34


 if any,  are  required  to  assure  that the  NAPL  (including  the

 associated  APL within  the NAPL  plume) will  not impact Jtllfi CWTP

 water supply.
6344o:KSW:03/20/90
Revised: 07/19/90
13493-6:D.C.

-------
                             111-35

 4.0      EASTERN PORTION STUDY
          Paragraph  E(23),  Addendum   I  of  the   Judgment  is
 replaced by the following:
               "(23)(a)    The   eastern   portion   of   the
          existing CWTP,  as  shown conceptually  in  Figure
          E-9   of   the   Judgment   ("Eastern   Portion"),
          including   all   studies,   investigations    and
          remedial measures,  if any, relating  thereto,  will
          be  initially   addressed  by  the  City  under  the
          State's  Inactive  Hazardous  Waste  Disposal  Site
          Program,  Environmental Conservation  Law,  Article
          27,  Title 13.   The  City shall perform  the "Phase
          II"  investigation which,  under the Judgment,  was
          to be performed by EPA.  Within  60 days after DEC
          approval  of  the City's "Phase II" study,  the  City
          shall   make  a  determination  whether  to  proceed
          with  an  RRT   Study   under   subparagraph   (b)  or
          whether to  continue  to  proceed under the State's
          Inactive  Hazardous Waste Disposal  Site  Program.
          If a consent order between the State and  the City
          is  achieved,   the   City   will    perform   the
          investigation   and  any  necessary  remediation  of
          the  Eastern  Portion pursuant  to the terms  of  that
          consent order,  and  may  apply,   as  appropriate,
          subject  to   all  eligibility  requirements,   for
6344o:KSW:03/20/90
Revised:  07/19/90
13493-6:D.C.

-------
                             111-36

          reimbursement  under  the  Environmental   Quality
          Bond Act  of  1986  ("EQBA")   and  any  subsequent
          Environmental Bond Acts.   The  City shall not  be
          eligible  for reimbursement  under  EQBA  for  any
          "Phase  II" investigation or for  any investigation
          of,  or  remediation  costs  for,  any  OCC wastes
          identified on said Eastern Portion.   Such consent
          order  under  the  State's  Inactive Hazardous  Waste
          Disposal  Site  Program  may  require  disposal  of
          Eastern  Portion  wastes  in facilities other  than
          the  S-Area Landfill.
               (b)  If the City determines to proceed  with
          an RRT  Study in  accordance with  subparagraph (a),
          the  City  shall   conduct  a study to  assess   what
          Requisite   Remedial   Technology,   if   any,   is
          necessary  to address  such situation.   Thereafter,
          the   parties  shall   proceed   as   described   in
          subparagraphs B(8)  and  (9);   provided,   however,
          that  for  the  purposes  of  such.  study  and  any
          subsequent action  relating  thereto  pursuant  to
          subparagraphs B(8)  and (9) and Paragraph  4 of the
          Judgment,  whichever obligations are applicable  to
          Hooker  in  those subparagraphs  shall  instead  be
          solely applicable to the  City,  and Hooker  shall
          have no  obligations in such instance.
6344o:KSW:03/20/90
Revised:  07/19/90
13493-6:D.C.

-------
                             111-37

               (c)   Regardless of which  of the two  options
          described in subparagraph (a)  the City  chooses to
          pursue/  OCC  shall  have no  obligations  for  any
          studies,   investigations  or  remedial   measures
          regarding  the  Eastern  Portion   performed  under
          either  option,  except  that,  consistent with  good
          engineering practice and prior to final  Landfill
          Site  capping,  OCC will provide in accordance with
          the  Remedial  Waste  Management Plan  (Appendix  IV
          to  the RRT  Stipulation)  (i)  disposal capacity at
          the Landfill Site prior to final capping  for  any
          solid waste generated  by such investigative  and
          remedial   measures,   if  any,   undertaken   on  the
          Eastern   Portion,   and  (ii)   treatment   and/or
          incineration  capacity   at  OCC's Buffalo   Avenue
          Plant Site for liquid waste  generated during  such
          investigative   activities.    The   City  shall   be
          responsible   for  transporting  such  wastes   for
          disposal  at  the Landfill Site  or treatment  and/or
          incineration,  as appropriate.  Issues relating  to
          City  compensation  to  OCC, if  any, for disposal  of
          Eastern Portion solid  waste  at the Landfill  Site
          and   treatment  and/or   incineration  of   Eastern
          Portion  liquid waste  shall   be the  subject of  a
          separate agreement between OCC  and the City.
6344o:KSW:03/20/90
Revised:  07/19/90
13493-6:D.C.

-------
                              II1-38

               (d)  If  the City proceeds  under the State's
          Inactive Hazardous  Waste  Disposal  Site  Program,
          after completion  of the "Phase  11" investigation
          pursuant to subparagraph  (a)  above,  the  City and
          State shall  furnish to EPA copies of all reports
          concerning the  above  investigation  and  remedial
          activities  at   the  Eastern   Portion.    Nothing
          herein
          shall  prevent  the  EPA  from  submitting  timely
          comments  on   reports   related  to  the  Eastern
          Portion; however,  the  parties shall  consider, as
          appropriate,  but are not  obligated  to  respond to
          or adopt any such comments."
6344o:KSW:03/20/90
Revised: 07/19/90
13493-6:0.C.

-------
                               111-39


 5.0      EXISTING CWTP REMEDIAL/CLOSURE PLAN

          The plan  for the existing  CWTP remediation and closure

 is set forth in Attachment  C hereto.
6344o:KSW:03/20/90
Revised: 07/19/90
13493-6:0.C.

-------
FIGURES

-------
OMH6A
I 9610
                                                        MANHOLE INVERT ELEVATION
                                                        PREVIOUSLY PROPOSED WTP GROUNOWA1ER
                                                        COLLECTION SYSTEM
                   ADDITIONALLY PROPOSED GROUNDWA1ER
                   COLLECTION SYSTEM
                 FILTERED  WATER

                   RESERVOIR
                                                        NEWLY PROPOSED MANHOLE
                                                        INVERT ELEVATION
                                                        TOP OF CLAY ELEVATION
                                                                           SLUDGE
                                                                           THICKENER
                                                         PUMP
                                                         STATION
                       III-
COLLECTION  SYSTEM FOR
30*0  WASTEWATER DRAIN
                  DPHHPAU
             MH20A
             (555.8]
GROUNDWATER
   CHEMICAL BLDa
     6 OFFICES

-------
                                                    CONCEPTUAL
                                                    FUTURE
                                                    PROPERTY BOUNDARY FOR
                                                    WESTERN PORTION OF DWTP
                    W28I®
               W280®
                                               DRINKING
                                        WATER TREATMENT PLANT
                                                             figure III-2
                                                     MONITORING WELLS
                                  DRINKING WATER  TREATMENT PLANT
                                        Occidental Chemical Corporation
NAPL MONITORING WELL

BEDROCK PIEZOMETER
OVERBURDEN SURVEY
WELLS (EXISTING)
1769-23/05/90-L-0

-------
      ATTACHMENT A



Plan A Milestone Schedule

-------
                               ATTACHMENT A
                         Plan A Milestone Schedule
                     (New City Water Treatment Plant)
 CONSTRUCTION
 1.  All  Parties  Sign and Lodge the RRT
    Stipulation  with the Court
 2.  City Council Pass Bond Resolution
 3.  City Submit  Process/Treatability Studies/
    Pilot Plant  Program to NYSDOH for Approval
 4.  Receive  NYSDOH Approval of Studies/Pilot
    Work
 5.  Start NYSDOH Approved Studies/Pilot Work
 6.  Start Facilities Planning
 7.  City Submits Facilities Plan to NYSDOH
 8.  Receive  NYSDOH/EPA Endorsement of Facility Plan
 9.  Supplemental Bond Resolution or Other
    Financial Authorization Passed by City
    Council  (if  needed)
 10. Start Detailed Design
 11. City Submit  Final Application for 601  and
    608  Permits  to NYSDEC
 12. Receive  Approved 601 and 608 Permits from
    NYSDEC and associated Corps  of Engineers
    Permits
 13. City Submits  Detailed Design to NYSDOH
 14. Receive  NYSDOH/EPA Approval  on Design
 15. Supplemental  Bond Resolution or Other
    Financial Authorization Passed by
    City  Council  (if  needed)
Months afte:
Stipulation
Lodging wit!
  the Court
    5
    6
   12
   21
   23

   24
   26

   29

   32
   36
   38

   39
6816o:KSW:07/05/90
Revised:  07/19/90
13493-6:D.C.

-------
                                   - 2 -
                                                            Months Afte
                                                            Stipulation
                                                            Lodging Wit
                                                               the Court
 16.  Notice to Proceed to Contractor(s)
 17.  Receive First Payment Check from OCC
 18.  Construction Substantially Complete
 19.  NYSDOH Completed Works Approval Received
     and New Water Plant On-Line
 20.  Demolition of Existing Plant Complete
 21.  Title to Existing Plant Transferred to OCC
45
46
69

71
76
77
 SITE  ACQUISITION
 1.  Remedial  Investigation and Delisting Petition
    for  Portion of NYPA Buffalo Avenue Site
    Submitted to NYSDEC
 2.  Delisting Action Approved by NYSDEC or Other
    Acceptable Authorization(s) by NYSDEC
 3.  Site Acquisition Completed
17

20
21
6816o:KSH:07/05/90
Revised:  07/19/90
13493-6:D.C.

-------
       APPENDIX VI




INSURANCE CERTIFICATE FORM

-------
                                              Duration
                                              (months)
L.
CAPPING PROCTAMS

       L1A.  Plans & Specifications
       LIB.  EPA/State Review If
             Approval
       L1C  Award Contract
       LID.  Installation
       LIE.   Install East Cap
                                                  3
                                                  2
                                                  6
                                                  4
M.
N.
SPECIAL CONSTRUCTION . HEALTH k SAFETY

       MIA.  EPA/State Review fc
             Approval                      1
       M1B.  Install Monitoring Stations       2
       MIC.  Perform 30 day Background
             Study                         1
       MID.  EPA/State Review &
             Approval                      3

WASTE CELL CONSTRUCTION

       N1A.  Plans and Specifications          2wks
       NIB.  EPA/State Review &
             Approval                      3
       NIC.  Award Contract                 2
       N1D.  Contraction of Cell 1             1
                                                        Float
                                                      (months)
17

17
17
26
 0
 2
 2

 2

 2



 21/2

 21/2
 21/2
 1
             Critical
No

No
No
No
Yes
                                                                               No
                                                                               No

                                                                               No

                                                                               No
                                                                               No

                                                                               No
                                                                               No
                                                                               No
      Activity is not critical. However, no float time is shown on the bar chart since the activity is
      tied to an on-going monitoring, operational or data collection activity. Some float time may
      actually be available as a delay in the start-up of the monitoring, operational or data
      collection activity would not affect the critical path.
                                         11

-------
                                            Duration
                                            (months)
                                               Float
                                              (months)
Critical
K.    BEDROCK MONITORING SYSTEM
      Kl.   Performanrp PipmmPt^
      K2.
      K3.
      K4.
K1A. Plans and Specifications
K1B. EPA/State Review fc
Approval
K1C Award Contract
KID. Installation
K1E. Perform Hydraulic,
Monitoring
APL Dispersion Testing
K2A. Award Contract
K2B. Installation
K2C. Inject Tracer
K2D. Collect Data
K2E. Submit Results
K2F. Plans and Specifications
Monitoring Program (if required)
NAPL Tracer Testine
K3A. Award Contract
K3B. Installation
K3C. Inject Tracer Stage I
K3D. Collect Data Stage I
K3E. Submit Results
K3F. Inject Tracer Stage U
K3G. Monitor Stage n
Chemical Monitorine Program
K4A. Award Contract
K4B. Installation
K4C. Perform Monitoring
2
3
2
6
ongoing
1
1
Iwk.
58
2
ongoing
1
1
Iwk.
35
2
Iwk.
ongoing
2
1
ongoing
      K5.
Environmental Monitoring Program

K5A.  Plans and Specifications         2
K5B.  EPA/State Review &
      Approval                     3
K5C.  Award Contract                2
K5D.  Installation                   2
K5E.  Monitoring                  ongoing
                                                           maximum
                                                              •
                                                              »
                                                              •
                                                              »
                                                           maximum
                                                                            No

                                                                            No
                                                                            No
                                                                            No

                                                                            No
                                                               No
                                                               No
                                                               No
                                                               No
                                                               No

                                                               No
                                                                No
                                                                No
                                                                No
                                                                No
                                                                No
                                                                No
                                                                No
                                                                            No
                                                                            No
                                                                            No
                                                                            No

                                                                            No
                                                                            No
                                                                            No
                                                                            No
                                       10

-------
J2.


J1E

J1F.

JIG.
J1H.
JH.
JU.

J1K.

J1L.
JIM.
JIN.
API
J2A.

J2B.

J2C.
J2D.
J2E.

J2F.


J2G.

J2H.
J2I.
J2J.
J2K.

J2L

J2M.
J2N.
J2O.


Duration
(months)
NAPL Recovery Tests and Plans
and Specifications Phase I
EPA/State Review &
Approval
Award Contract Phase n
Install Phase II
Operate Phase II
Plans and Specifications
Phase III
EPA/State Review &
Approval
Award Contract Phase HI
Install Phase III
Operate Phase III
Recovery Wells
Plans, Specificaitons and
Protocols
EPA/State Review &
Approval
Award Contract
Installation
Pump Tests and Evaluate
Data
Complete Remaining Pump
Tests and Plans and
Specifications Phase II
EPA/State Review &
Approval
Award Contract Phase n
Install Phase II
Operate Phase II
Plans and Specificaitons
Phase in
EPA/State Review *
Approval
Award Contract Phase HI
InstallPhase HI
Operate Phase HI
5

3
2
5
23

2

3
2
2
ongoing


(

3
2
2

2


4

3
2
5
24

2

3
2
2
ongoing
                                                        Float
                                                      (months)
                                                          14

                                                          14
                                                          14
                                                          14
                                                           0
                                                           0
                                                           0
                                                           0
                                               completed
                                                          12
                                                          12
                                                          12
                                                           0
                                                           0
                                                           0
     Critical
        No

        No
        No
        No
        No

        Yes

        Yes
        Yes
        Yes
        Yes
        No

        No
        No
        No

        Yes
(first 2 months)
        Yes

        No
        No
        No
        Yes
(first 15 months)

        Yes

        Yes
        Yes
        Yes
        Yes

-------


H2.









Overburden Collection Wells
H2A. Plans and Specifications
H2B. EPA/State Review fc
Approval
H2C. Award Contract
H2D. installation
H2E. Pei f 01 in Pump Tests on
NAPL Wells
H2F. Select NAPL Recovery
Wells
H2G. EPA/State Review &
Approval
H2H. Operate NAPL Recovery
Wells and O/B Collection
Wells
OVERBURDEN MONITORING SYSTEM
11.


12.



Gradient Monitoring Wells
11 A. Plans and Specifications
I1B. EPA/State Review &
Approval
I1C. Award Contract
I1D. Installation
Maintenance Piezometers
I2A. Plans and Specifications
I2B. EPA/State Review fc
Approval
I2C. Award Contract
I2D. Installation
Duration
(months)

2
3
' 3 '^"'•••~ •
2
1

1
ongoing
2
3
2
2

2
3
2
2
Float
(months)

12
12
12
. -*• » — - • ••
» .
*
.


12
12
12
*

12
12
12
•

Critic

No
No
No
No
No
No

No
No
No
No
No
No

No
No
No
No
       13.    Conduct Monitoring Program
ongoing
                                     No
J.      BEDROCK RRT SYSTEM

       Jl.     NAPL Recovery Wells

             J1A.    Plans, Specifications and
                    Protocols
             JIB.    EPA/State Review &
                    Approval
             J1C    Award Contract
             J1D.    Installation
  3
  2
  4
      completed
12
12
16
                                     No

                                     No
                                     No
                                     No
8

-------
                                              Duration         Float
                                              (months)        (months)         Critical
F.     ITTTLTTY REMEDIATION

             F1A.   Plans and Specifications          2              91/2           No
             FIB.   EPA/State Review and Approval  3              91/2           No
             F1C.   Award contract                 2              »               No
             FID.   Construction                    1              *               No
       BARRIER WALL CONSTRUCTION

       Gl.    Slurry Wall             •

             G1A.   DWTP Option A or Option B      74              0              No
             GIB.   Plans and Specifications          4              *              No
             G1C   EPA/State Review &
                    Approval                      3              *              No
             G1D.   Award Contract                 2              *              No
             G1E.   Installation of Utility
                    Severance Plugs                 1              *              No
             GIF.   Installation of N., S. and W.
                    Walls                         5              •              No
             GIG   Install East Wall                2              0             Yes

       G2.    Prescriptive Grout Plugs

             G2A.   Plans and Specifications          4              4              No
             G2B.   EPA/State Review fc
                    Approval                      3              4              No
             G2C   Award Contract                 2              4              No
             G2D.   Installation                     4              •              No
H.     OVERBURDEN REMEDIAL SYSTEM

       HI.   Tile Collection System                                   ••.....

             H1A.  Plans and Specifications          4              8              No
             H1B.  EPA/State Review it
                    Approval                      3              8              No
             H1C.  Award Contract                 2              *              No
             HID.  Installation                    6              *              No
             HIE.  Operate Tile Collection
                    System                      ongoing                          No

-------
                                       Duration         Float
                                       (month*)       (months)        Critical

       DID.  Award Contract                2               0            Yes
       DIE.  Construction                    9               0            Yes
       DIP.  Startup                       1               0            Yes
       DIG.  Additional Storage
             Assessment/Approval           2               0            Yes
       D1H.  Award Contract                3               0            Yes
       D1I.  Construction • Additional
             Required Storage                10               0            Yes

D2.    APL Treatment

       D2A.  Plans and Specifications
             Process Design/                 8              11             No
       D2B.  Plans and Specifications
             Detailed Design                10              12             No
       D2C.  EPA/State Review &
             Approval                      13              11             No
       D2D.  Process & Approve Discharge
             toPOTW                      4              12             No
       D2E.  Award Contract                2              11             No
       D2F.  Construction                    12              11             No
       D2G.  Startup                       4              11             No
       D2H.  EPA/State Approval -
             Additional Treatment
             Capacity                      3              17             No
       D2I.  Award Contract -
             Additional Treatment
             Capacity                      3              17             No
       D2J   Construction - Additional
             Treatment Capacity             12              17             No

D3.    NAPL Treatment

       D3A.  Design, Install 4 Test
             Incinerator APCE                32              13             No
       D3B.  Assess  Incineration              3              16             No
       D3C  EPA/State Review &
             Approve APCE                 5              13             No
LAGOON DECOMMISSIONING

El.    Provide Alternate Treatment
       System                              12               6             No
E2.    dean Out Lagoons                     2               6             No

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4.0   DURATION OF ACTIVITIES



                         The following list of Activities identifies the scheduled

      duration, the available float time for each Activity before the critical path is

      affected and identifies those Activities which are currently on the critical path

      which controls the timely completion of the S-Area program.
B.
ACCELERATED MATERIALS TESTING

Bl.   Slurry Materials

      B1A.  Conduct Testing
      BIB.  Submit Results
      B1C.  EPA/State Review &
            Approval

B2.   Grout Materials

      B2A.  Conduct Testing
      B2B.  Submit Results
      B2C.  EPA/State Review &
            Approval
                                            Duration
                                            (months)
                                               6
                                               2
                                               9
                                               2
                                                     Float
                                                    (months)
4
4
           Critical
             No
             No

             No
No
No

No
      ADDITIONAL SURVEY WORK

            CIA.  Award Contract
            C1B.  Installation (IIPT Wells,
                  Water Plant Borings/Wells)
            C1C  Submit Results
                                             completed
                                         31/2
                                         2
71/2
5
No

No
No
      SITE FACILITIES

      Dl.   APL/NAPL Storage

            D1A.  Plans and Specifications
                  Process Design
            DIB.  Plans and Specifications
                  Detailed Design
            D1C  EPA/State Review k
                  Approval
                                             completed

                                         4              0

                                         7              0
             Yes

             Yes

             Yes

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3.0    GOVERNMENTAL APPROVAL PROCEDURES

                       Most RRT Components listed in Section 4.0 include a
      90-day procedure for review and approval of OCC submissions of plans,
      specifications and protocols by EPA/State. This time interval is shortened
      from that provided in Paragraph 7 of the Judgment.

                       The elements of this procedure are as follows:

      1)    OCC prepares plans, specifications and protocols and submits them to
           the EPA/State.
           Scheduling Duration - as individually noted in Section 4.0.

      2)    EPA/State reviews the submitted plans, specifications and protocols.
           Scheduling Duration - 45 days

      3)    OCC reviews the EPA/State comments and subsequently revises and
           resubmits the plans, specifications and protocols.
           Scheduling Duration -15 days

      4)    EPA/State reviews re-submission and approves plans, specifications
           and protocols.
           Scheduling Duration • 30 days

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2.0    ASSUMPTIONS

                       The Bar Chart and Network Diagram are based on the
      following assumptions:

      (1)   OCC will utilize the amount of time indicated in Section 4.0 to
           complete each of the listed Activities.

      (2)   EPA/State will utilize the amount of the time indicated in Sections 3.0
           and 4.0 for review and approval of all OCC submissions.

      (3)   Seasonal variations and weather conditions will have no adverse
           impact on the scheduled duration of Activities.

      (4)   Both governmental and private approvals and other authorizations
           necessary to perform an Activity will be obtained in a timely manner
           prior to  initiation of such work.

      (5)   All prior dependent Activities and RRT Components listed in
           Section 4.0 are completed as scheduled.

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addition, the initiation and completion of certain RRT Components is
directly dependent upon the satisfactory completion of other RRT
Components.  Therefore, if any of these RRT Components or Activities are
not completed as scheduled, it will have a consequential direct effect on the
initiation and completion of the dependent RRT Component or Activity.
RRT Components and Activities which could be effected in this manner are
presented on both the Network Diagram and the Bar Chart.

                 The performance of certain RRT Components and
Activities listed in Section 4.0 also is directly dependent upon the accuracy of
each of the assumptions described in Section 2.0.

                 All revisions to the S-Area Project Schedule will be made
in accordance with Section F of the RRT Stipulation.

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1.0    INTRODUCTION

                       This project schedule ("S-Area Project Schedule") is
      applicable to activities related to implementation of the S-Area RRT
      Remedial Plan.

                       The S-Area Project Schedule consists of the following:

      a)    the assumptions  set forth in Section 2.0;
      b)    the procedure relating to submission, review and approval of plans,
           specifications and protocols set forth in Section 3.0;
      c)    the major RRT components listed in Section 4.0 and the duration of
           each of the activities included under each component;
      d)    the Network Diagram included as an attachment hereto; and
      e)    the Bar Chart included as an attachment hereto.

                       Section 4.0 identifies the major components of the  S-Area
      RRT Remedial Plan ("RRT Components"). It also includes various activities
      which will be carried out in implementing each RRT Component
      ("Activities"). However, the list cannot take into account additional
      unscheduled tasks and  extensions in performance time of currently
      undefined Activities resulting from required response actions, such as
      Operational Modifications, System Modifications, focused feasibility studies,
      and RRT Studies.

                       The performance of certain activities listed in Section 4.0
      is directly dependent upon the satisfactory completion of prior Activities.  In

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                      TABLE OF CONTENTS



                                                       Page




1.0   INTRODUCTION	1





2.0   ASSUMPTIONS	3





3.0   GOVERNMENTAL APPROVAL PROCEDURES	4





4.0   DURATION OF ACTIVITIES	5

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        APPENDIX V




OCC S-AREA PROJECT SCHEDULE

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                                     ATTACHMENT A                              Page 3 of 3
                                     TO APPENDIX IV

C5.       Complete Trial Burns and, if Authorized, Initiate                November, 1993
          Restrictive Burning of Remedial Wastes, Including
          S-AreaNAPL(OCC)

C6.       All Required Complete Submissions for final                   February, 1994
          Authorization (OCC)

C7.       Authorization to Incinerate S-Area NAPL in Solids               July 1994~ (five months
          Incinerator Under Final Permit Conditions (EPA/DEO           after Item C6)
Schedule D: Other EPA/State Permitted Incineration/Treatment and Storage Alternatives
            specified in § 2
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                                   ATTACHMENT A
                                   TO APPENDIX IV

Schedule B: Upgrade for Liquid Incinerator Air Pollution Control Equipment (APCE)
                  Page 2 of 3
 Bl.       Approval Determination of APCE Technology
          (EPA/DEC)

 B2.       Submit Complete Final APCE Design (OCO
B3.       Authorization Determination of APCE Construction
          (EPA/DEC) Start of APCE Construction (OCO

64.       Submit Complete APCE Trial Bum Plan (OCC)


B5.       APCE Trial Burn Plan Approval (EPA/DEC)
B6.      Completion of APCE Construction and APCE Start-up
         (OCC)

B7.      Submit complete APCE Trial Burn Report (OCC)
B8.      Submit Remedial Waste Treatment Assessment Report
         Per Stipulation § 20(b) Assessing Status of APCE
         Upgrade (OCC)

B9.      Approval Determination for NAPL Incineration with
         APCE (EPA/DEC)
   •JCptCfllOd f 1990
   March 1991 (six months
   after Item Bl)

   July 1991 (four months after
   ItemB2)

   January 1992 (six months
   after Item B3)

   June 1992 (five months after
   ItemB4)

   July 1992 (twelve months
   after Item B3)

   March 1993 (eight months
   after Item B6)

   January 1993 (three months
   after Phase I pump tests)
   August 1993 (five months
   after Item B7)
Schedule C: OCC s Solid Hazardous Waste Incinerator

Cl.        Incorporate Liquid Remedial Waste Streams into Permit
          Applications and DEIS for OCCs Solids Incinerator
          (OCO

C2.        AU Required Complete Submissions Made (OCO

C3.        Permit Determination for OCCs Solids Incinerator
          (EPA/DEO

C4.        Submit Remedial Waste Treatment Assessment Report
          per Stipulation § 20(b) Assessing Status of OCCs Solids
          Incinerator (OCO
   Ongoing, concurrent with
   Schedules A & B
   February, 1991

*  December 1991* (ten months
   after Item C2)

   January 1993 (three months
   after Phase I pump tests)

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                                   ATTACHMENT A                             Page 1 of 3
                                   TO APPENDIX IV


          The dates set forth below for OCC to make complete submissions require OCC to make its best
efforts to provide complete submissions in compliance with § 5(g) of the RRT Stipulation. It is
contemplated that these submissions will be followed by written and oral communications between
EPA/DEC and OCC during governmental reviews prior to final governmental determinations that the
OCC submissions are complete.

          Final governmental determinations or approvals on the permit applications are dependent
on receipt of OCC submissions which are complete.


            REMEDIAL WASTE TREATMENT MILESTONE SCHEDULE (RWTMS)


Schedule A: Approval to Incinerate S-Area NAPL at OCCs Liquid Incinerator


Al.       Submit Preliminary S-Area NAPL Characterization
          Data Report (OCO                                        October, 1990

A2.       Submit Representative S-Area NAPL Sample Collection          December 1990 (two months
          Plan (OCC)                                              after Item Al)

A3.       Approval Determination of Item A2 Submission                March 1991 (three months
                                                                 after Item A2)

A4.       Complete Implementation of Item A2, Submit Complete          July 1991 (four months after
          Application for Approval to Incinerate S-Area NAPL            Item A3)
          per permit (OCO

A5.       Approval Determination for S-Area NAPL Incineration          September 1991 (two
          (consistent with confirmatory analyses required pursuant        months after Item A4)
          to the permit) (EPA/DEO

A6.       If APCE is required for capacity to treat all of S-Area NAPL, continue authorization process to
          incinerate S-Area NAPL under (RWTMS) Schedule B. If APCE is not required to treat all
          S-Area NAPL, men schedule B is inoperative.

A7.       Submit Remedial Waste Treatment Assessment Report           January 1993 (three months
          per Stipulation § 20(b) Assessing Status of Liquid               after Phase I pump test)
          Incinerator (OCO

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            ATTACHMENT A TO APPENDIX IV
REMEDIAL WASTE TREATMENT MILESTONE SCHEDULE (RWTMS)

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                                   APPENDIX F

                      GROUTING PROCEDURE FOR WELL CLOSURE
In the event that any well is to be grouted and removed from service, the
following procedures are to be implemented:

1)  Place polyethylene on ground surface around well.

2)  Install a water tight connection with tremie tube access over well.

3)  Set up water collection tank on polyethylene.

4)  Insert tremie tube to bottom of hole.

5)  Pump groud into the well lifting the tremie tube as the grouting proceeds.

6}  Place tremie tube into a steel barrel (placed on top of polyethylene) as it
    is removed from the well.

7}  Pump fresh water used to purge the tremie tube at the completion of grouting
    into the grout mixing drum.

8)  Cover the tremie tube with polyethylene and return to the cleaning area
    where the tubing exterior will be cleaned along with all other equipment
    used in the grouting procedure.

9)  Contain all well water and transport to a permitted treatment facility.
    Depending on the volume, wastewater may be pumped into a wastewater haul
    vehicle or into 55-gallon drums as appropriate.  Excess grout will be placed
    into 55-gallon drums for transport to the spoils cell.

10) Retop the grout with additional grout.

11) Cut casing off at or below grade.

12) Dispose of appropriate safety equipment and material in 55-gallon steel
    drums and transport to the drum storage facility.

13) Restore site to original condition or better.

The above procedure will be used for all wells screened in the bedrock or above
the top of the confining layer (clay/till).  For overburden wells screened in
the clay or till unit, the well will be overdrilled, the well pipe removed to
the extent practicable and then the grouting procedure will be implemented.

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             APPENDIX F
GROUTING PROCEDURE FOR WELL CLOSURE

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             MINIKUN REQUIRED  STEEL  SLIP-IN BLANK THICKNESS
PIPE SIZE
 INCHES       1      5       10    25    50    75   100   150   200
    1        1/16   1/16   1/16  1/16  1/8   1/8   1/8   1/8   3/16
    2        1/16   1/16   1/8   1/8   3/16  3/16  3/16  3/16  1/4
    3        1/16   1/8    1/8   3/16  3/16  3/16  1/4   1/4   5/16
    4        1/16   1/8    1/8   3/16  1/4   1/4   5/16  5/16  3/8
    6        1/8    3/16   3/16  1/4   5/16  3/8   3/8   7/16  1/2
    8        1/8    3/16   1/4   5/16  3/8   7/16  1/2   9/16  11/16
   10        1/8    3/16   1/4   5/16  7/16  1/2   9/16  11/16 13/16
   12        3/16   1/4    5/16  3/8   1/2   5/8   11/16 13/16 15/16
                           E-6

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 YES        MO
 LJ          Q   Process  fluids  removed from equipment or lines broken.
                  Necessary blanks Installed?
                  Drain  valve to be Installed?
             p.
             |— j  On-Slte Personnel  assigned to job Instructed In proper
                 method?
                 Has  safety shower been located and tested?
p         a
r—|         i-i  Line or equipment has been properly prepared  and  Is
p
                 safe to break Into.
                 All pumps and starters locked out?
SPECIAL PRECAUTIONS
I certify that the precautions  checked and/or written out above have
been taken, and will be followed  for the duration of the job.
OCC SAFETY OFFICER
Signed     •	
                            E-5

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                      CHECK LIST MUST  BE  COMPLETED
                BEFORE ANY PROCESS  LINE  IS  OPENED  WHICH
              CONTAINS OR HAS CONTAINED HAZARDOUS  MATERIAL
       Date      .               Fran                    TO*
Department                      Location
Work TO Be Done
MATERIAL 7055IBLY IN LINE
             Name of Material
Complete this section before checklist  Is  signed.   Check  the  precaution
to be taken before line opening starts.  Cross  out  those  not  applicable
to the particular job being done at the  tine.
YES        NO
LJ         LJ  All necessary protective  equipment.  Including  rubber
                 suits, face shield (or  hood) rubber  foot wear, liquid
                 proof gloves to be worn?
            nr-i  Respiratory protection needed  and/or  available?   If  so
            U  state type	.
            Dp-i  Area barricaded for  maximum protection  of  other  On-S1te
            U  Personnel?
i—i            i  Scaffolding Installed or other safe access to  equipment
                 provided?
                 •Hot Work Permit' provided  as needed?
D         P
            p.  Line or equipment drained  Into a  suitable  container?
            p.  All valves properly Identified, tagged  and locked out?
i—i         p.  All pumps and starters locked out?
                                E-4

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A.  Pipelines Containing Hazardous Materials

   (1) When these pipelines are worked on,  valves  that  stop
       material flow oust be closed,  locked,  tagged and tried.

   (2) Where possible, at least two valves  on the  upstream side of
       the point of work should be closed,  locked, tagged and
       tried.  No dependence should ever be placed upon check
       valves to prevent flow of materials.

       a.  If lines are tied to a common header,  It may also  be
           necessary to lock out and  tag additional valves to
           prevent backflow.

       b.  All material should be bled from the  lines  and, where
           possible, a positive means of keeping the line vented,
           such as a double block and bleed,  should be  used.

       c.  When a bleed point 1s not  available, the source of
           pressure on the material 1n a pipe line should be
           removed (shutting down and locking out  a pump feeding
           the line).

   (3) When lockout of the valve or valves, due  to its  construction
       1s Impractical, a "Danger" tag, properly  filled  out, dated
       and signed, must be securely affixed to the valve stem.

   (4) The contaminated lines will be flushed with clean water  than
       cutup and placed in 55 gal. barrels  and disposed at the
       secure landfill.  (All water used for  flushing will be
       collected and treated according to the Hyde Park Consent
       Agreement).
                            E-3

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 4.  The On-Slte Personnel  will  fill out the checklist before starting
     the job and the Safety Officer will periodically audit to Insure
     that this Is being done.  This checklist will be given to the Safety
     Officer upon completion of the line breaking job. Mho will review
     and Initial the work permit sheet and retain 1t for or* calendar
     quarter.

 5.  Barricading Area

     Before the moment  of breaking occurs, the surrounding area shall be
     barricaded for maxima protection of other On-S1te Personnel.

 6.  Downtime After Line Breaking

     A.   When line break-ing Includes a period of downtime greater than
         the shift during which  the breaking occurred, the open system
         shall  be secured or closed by one of the following means:

         (1)   double block  and bleed

         (2)   blind flanges - refer to blank flange sizes
              (attached)

         (3)   a properly designed closure

         Exceptions to  6a would  be where a crew can maintain continuity
         thru a shift change.

         Where  there 1s  a possibility of a line refilling and no other
         drain  exists,  a drain valve shall be attached to the blank
         flange or closure.

     B.   Safeguards such as  locked switches and locked valves shall be
         continued until the system Is again closed.

7.   Safety Showers

     Before breaking Into equipment,  a safety shower will be situated
     within IS1  of the  equipment before making the break.

8.   Plastic  Piping and  Fittings 1n Hazardous Service

     Some forms  of plastic  piping can  become brittle with age and
     chemical exposure,  others are affected by extreme temperatures.
     Cart oust  be  exercised  when working with these plast.ics.

9.  Safety locks  and "Danger -  Do Not Operate" tags must be installed on
    closed valves  when:

    The flow of  air, steam,  water,  flammable liquids or  chemicals
    through  unblanked pipe  lines would present a hazardous condition.
                                E-2

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S-AREA REMEDIAL PROGRAM
Safety Operating Procedure S110
SUBJECT

Line Or Equipment Breaking Checklist

PURPOSE

To establish a standard procedure for minimum safe preparation and opening of
equipment or pipeline which have or could contain hazardous materials.
Individual circumstances may require more stringent procedures.

AFFECTS

All Construction Activities during the S-Area Remedial Program.

PROCEDURE

1.  Checklist

    A.  Line breaking checklist (Appendix E, Page E-4) shall be filled out
        before Personnel break into equipment or pipelines which have or could
        contain hazardous materials.

2.  Required Protective Apparel

    A.  Face Shield and Goggles
    B.  Safety Hard Hat
    C.  Liquid Proof Gauntlet Gloves
    D.  Protective Footwear Covered by Rain Suit
    E.  Respiratory Equipment ad Defined in SI3

3.  Duration of Mode of Operation

    A.  The protective equipment must be worn when On-Site Personnel open as
        isolated line or equipment for the first time and work on open lines
        and/or equipment as long as the hazard of exposure exists.  The hazard
        of exposure may be considered eliminated and the Safety Officer may
        approve removal of protective equipment to the minimum requirement of
        goggles, gloves, respirator, and hard hats when all of the following
        exist:

        (1)  The line or equipment is drained and vented to a proper means of
             containment.

        (2)  The line is physically disconnected (opened) at all low points.

        (3)  Interconnecting lines are blanked or locked out and tested not to
             leak through.

        (4}  Lines or equipment which have contained hazardous materials have
             been flushed.
                                      E-1

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             APPENDIX E








  SAFETY OPERATING PROCEDURE S#10



LINE OR EQUIPMENT BREAKING CHECKLIST

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 i.   Washable  coveralls  -  cotton  jump  suit type.

 j.   Cold weather gear - when  and if needed,  jackets, hats,  insulated  underwear.

 k.   Disposable  shoe covers.


 Protection  level S-4 -  Project Site Workers.    There  is  no need  for  the
 following classification  of workers to  enter  a Survey  Site  or  to  handle any
 potentially contaminated  material or  equipment:  equipment  operators  outside  the
 Survey Site,  technicians,*/ supervisors, engineers, office  workers  who must go
 to  a Survey Site, service personnel,  janitorial service personnel,  and general
 site visitors.  These Project Site Personnel  will be provided  with  and wear:

 a.   Respirator  - Scott  64-OAF or approved equivalent.   (Available for immediate
     use)

 b.   Hard  hat.   (to be worn}

 c.   Safety  glasses with side  shields,   (to be worn)

 d.   Protective  rubbers  -  neoprene reusable.   (Available if  required by Site
     conditions.)

 e.   Outer gloves - janitorial personnel only.


 Protection  Level S-5.     Office  workers, clerical workers,  visitors,  and  others
 who remain  within the fenced  area near  the offices will not need  nor  be issued
 any special personal protective  equipment.  Scott 64-OAF  or approved  equivalent
 respirators will be available in the  office for emergency purposes.
_V  the air monitoring technician will adjust his personal  respiratory
    protection depending on the readings from his instruments.

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 c.  Hard hats.

 d.  Safety glasses with side shields.

 e.  Full face shields or approved equivalent will be used when drilling through
     waste or through the lower section of the Lockport Dolomite.

 t.  Cotton gloves (inner glove).

 g.  Outer gloves (two sets).

 h.  Work boots.

 i.  Outer boots  (neoprene reusable).

 j.  Washable coveralls - cotton jump  suit type.

 k.  Cold weather gear - when and if needed - jackets, hats, insulated
     underwear.

 1.  Sock and underwear.

 m.  Disposable Hood (unlaminated Tyvek type 2196).


 Protection Level 8-3 - Survey Site Morkers with  Minisnsi Potential of Bxpoaure to
 Surrey Liquids.     The following classification  of  worker will be working at
 Survey Sites located in areas other than on the  S Area Landfill or in areas with
 minimum  potential for contact with Survey Liquids.   These workers include:  soil
 and  water samplers,  sample handlers,  and personal protective equipment cleaners.
 They will be provided with :

 a.  Respirator - Scott 64-OAF or approved equivalent.  (Available for immediate
     use).

•b.  Disposable coveralls - For expected wet conditions use item b in Level S-2
     above;  for expected dry conditions, uncoated TYVEK may be used.

 c.  Hard hat.  (to be worn)

 d.  Safety glasses with side shields,  (to be worn)

 e.  Cotton gloves (inner glove),  (to be worn)

 f.  Outer gloves,   (to be worn)

 g.  Work boots,   (to be worn)

 h.  Protective rubbers (neoprene reusable),  (to be worn)

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                                   APPENDIX D
Subject

Levels of Worker Protection

Protection Level S-1 - Confined Space Survey Site Workers.    Because of the
higher potential for exposure to chemicals while in a confined space or while
drilling within the interior of the S-Area Landfill, worker classification for
Survey-Site Personnel who work in these areas will be provided with and wear:

a.  Pressure Demand Supplied air (1980 ANSI Standard Z88.2).

b.  Five minute positive pressure escape air pack independent of primary air
    source.  (Available for emergency use)

c.  Fully encapsulating chemical resistant suit (Coated Chemical Resistant
    TYVEK, Kapplar Model 77 or approved equal).

d.  Washable coveralls.

e.  Socks and underwear.

f.  Gloves outer (chemical resistant neoprene) - the most effective glove
    will be provided.

g.  Gloves inner (cotton).

h.  Work boots - the most effective work boot will be provided.

i.  Outer boots (neoprene reusable) will be provided.

j.  Hard hat - an ANSI approved hard hat equivalent to Wilson Alpha Safety Cap
    I82AC and compatible with item c. will be provided.


Protection Level S-2 - Survey Site Workers.    The following classification of
workers might on occasion handle potentially contaminated material or equipment.
They will be working around mobile equipment, wells and the spoils cell and will
include drillers and driller helpers drilling on the immediate perimeter of the
S Area Landfill, equipment operator cleaners and those involved in the operation
of the spoils cell.

a.  Respirator - Scott 65-OAF or approved equivalent (Cartridges to be replaced
    daily).

b.  Disposable coveralls - splash resistant polylaminated coated TYVEK type
    P2126-1 with closure capacity at wrists and neck.  Equipment cleaner to have
    laminated hood.

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         APPENDIX D
LEVELS OF WORKER PROTECTION

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                                  APPENDIX C
                       Soil Testing Procedures - OA/OC Plan

All imported clay to be used for the construction of the Disposal Area berms and
capping of the Site (interim and final) shall be tested for the following parameters at the
frequency noted:

•  Grain Size Distribution       (ASTM D-422-63)       - once/1,000 c.y.
•  Moisture Content            (ASTM D-2216-80)      - once/1,000 c.y.
•  Atterburg Limits             (ASTM D-4318-84)      - once/1,000 c.y.
•  Triaxial Permeability         Engineering Manual    - once/5,000 c.y.
                               Number EM 1110-2-1906:
                               Appendix VII
                               "Permeability Test with
                               Back Pressure"
•  Moisture Density Test        (ASTM D698 OR D1557) -once/5,000 c.y. and at
                                                        least once during base
                                                        placement, once
                                                        during each interim lift
                                                        cover  placement
                                                        (3-inch layer) and
                                                        once during final
                                                        cover  placement

Physical testing data from proposed clay sources will be provided prior to bringing the
materials to the Site (grain size, moisture content, Atterburg limits, triaxial
permeability and moisture density relationship).  Results of three historic test sets will
be forwarded to the EPA/State Field Representative for review and approval.

In the case where day is being used for capping purposes, the following testing shall be
performed at the frequency indicated:

•  In-place Compaction Test     (ASTM D-2922-81
                               orD-1556-82)            - nine tests/acre/lift
•  In-place Moisture Content    (ASTM D-3017-78)       - nine tests/acre/lift
•  Triaxial Permeability
   (Final Cap Only)             Engineering Manual     - one/acre
                               Number EM 1110-2-1906:
                               Appendix VII
                               "Permeability Test with
                               Back Pressure"

In the case where clay is being used for berm construction, the following testing shall be
performed at the frequency indicated:

•  In-place Compaction Test                            - one test/150 LF of berm
•  In-place Moisture Content                           - one test/150 LF of berm
                  \

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             APPENDIX C
SOIL TESTING PROCEDURES - QA/QC PLAN

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                     It is to be noted that:

i)    The Safety Officer is responsible for inspecting all
      vehicles/equipment prior to final release from the Site.

ii)   All wash water will be contained and treated at the Niagara
      Plant Calgon Unit.

iii)   All sediment from wash water will be drummed and disposed at
      the Landfill Site.

iv)   All dirty haul roads will be removed and disposed on Site at
      the conclusion of each phase of the remedial program unless
      programs are running concurrently or consecutively.

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                            APPENDIX B

          On-Site Traffic Standard Operating Procedures
All vehicles and equipment entering the Landfill Site are required
to adhere to the following SOP for cleaning prior to leaving the
Site:

Condition A - Vehicles/equipment that do not handle waste and do
              not use dirty haul roads or enter open sections of
              waste disposal areas are not required to undergo
              cleaning.


Condition B - Vehicles/equipment used to haul/handle waste
              material are exempt from cleaning between loads if
              all of the following conditions are met:

              * provisions are made to protect the exterior of the
                haulage vehicle during the loading and unloading
                operations.

              * The vehicle/equipment does not use dirty haul
                roads or enter open sections of the waste disposal
                area (unless clean haul roads are extended into
                the area).  Otherwise, the undercarriages must be
                cleaned at a wash station prior to leaving the
                defined work zone.  All waste material adhering to
                the exterior of the vehicle (excluding the inside
                face of the box container) will also be removed at
                the wash station.
Condition C - Vehicles/equipment permanently leaving the Site
              which have been used to haul/handle waste material
              must have:

              * their undercarriages cleaned as noted in
                Condition B before leaving the defined dirty work
                zone.

              * Drive to or be transported to the decontamination
                facility (if transported, the undercarriage
                cleaning can be deleted)..

              * Clean the entire exterior of the vehicle/equipment
                with a pressurized water wash.

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                  APPENDIX B
ON-SITE TRAFFIC STANDARD OPERATING PROCEDURES

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7.  Proper placing and maintenance of fifth wheel jack supports.
    A.   Fifth wheel jack supports must be properly adjusted so  it  is
        against the face of the fifth wheel.
    B.   The surface of which the jack is placed must be level.
    C.   Fifth wheel jacks must be maintained in good operating condition
        and if damaged must be replaced.
                              A-3

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         surface.   When a tanker or trailer is spotted for purpose of
         loading or unloading, the driver will place a nose jack support.
         If the tanker or trailer Is spotted for storage only, a nose
         jack  need not be used.

         After a loading or unloading operation has been completed, the
         tractor driver must never couple to a trailer or tanker without
         first getting consent from the loader or unloader.

3.   Stake  Trucks  and  Dump Trucks

     Wheel  chocks  need not be used with these vehicles, unless mobile
     equipment is  being driven onto them.

     When chocking 1s  needed, they must be placed at the front and rear
     of  an  outer rear  wheel  on both sides of the truck.

4.   Parked Trailers,  Tankers and Trucks

     If  there  1s no  loading  or unloading to be done and trailers, tankers
     or  trucks are to  be left parked on an even surface, it will  not be
     necessary to  chock the  wheels.

     However,  if there Is  work to be done on any unit whether it  be
     loading,  unloading, maintenance or painting, the wheels must be
     chocked to  prevent both backward and forward movement.

     In either case, the brakes must be applied after spotting the unit.

5.   Removal of  Wheel  Chocks

    A.  Wheel chocks  MUST NEVER be  removed from position until  approval
        has been  given by the loader or unloader.  After getting this
        approval, the tractor or truck driver may remove the wheel
        chocks.

     B.  The loader must closely examine all  drain valves and other
        outlets to  insure that all  outlets are secure and not leaking
        prior to  giving approval  for removal  of the wheel  chocks.

6.   Proper  Placing and Maintenance  of Wheel  Chocks

    A.  Chocks must be squarely placed against the tire-of the  vehicle
        with  the  toothed  edge gripping the surface on which it  rests..

    B.  The surface on which  the  wheel  chock  is placed must be free of
        ice and snow.   If it  *s a concrete surface, the area where the
        chocks are placed must  be free of gravel,  dirt and etc.

    C.  Wheel  chocks  must be  maintained in good condition and if
        damaged, must  be  replaced.
                               A-2

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   a-nrea
Safety Operating Procedure  si6
SUBJECT

Loading and Unloading of Trailers, Tankers,  and  Trucks

PURPOSE

To prevent accidental movement of trucks,  trailers  and tankers  during
loading and unloading operations.

AFFECTS

All construction activities during the  s-Area   Remedial  Program.

PROCEDURE

1.  Loading or unloading trucks  and trailers or  tankers with tractor
    attached.

    A.  Responsibilities of the  Tractor Driver or Truck Driver

        After spotting the unit  at Us loading or unloading position,
        the driver must test  the brake system on both the  tractor and
        trailer.  This is done by applying the air  brakes  to the trailer
        and the hand emergency brake  to the  tractor and with the motor
        running and transmission in gear  attempt to move the unit
        forward.  The test must  show  that  there  is  enough  restraining
        force of the applied  brakes to prevent forward movement.  After
        this test has been satisfactorily completed, the driver Mill
        shut off the tractor  motor and place the transmission in reverse
        gear.

        Trailers or tankers must have chocks placed at the front and
        rear of an outer wheel or set of  wheels  on  both sides of trailer
        to prevent movement in either direction. The tractor driver
        must then notify the  On-Site  Personnel responsible for  the
        loading or unloading  operations that the above precautions  have
        been taken.

        The tractor driver must  never pull the trailer or  tanker away
        from this secured position until  he  has  received permission from
        the On-Site Personnel responsible  for the loading  or unloading
        operations.

2.  Loading or unloading trailers or  tankers without the tractor
    attached.

    A.  Responsibilities of Tractor Driver

        Before uncoupling the tractor the  driver must  set  the trailer  or
        tanker air brakes.  He must then  test these brakes by attempting
        to move the trailer or tanker forward with  the tractor  as the
        moving force.  The driver must then  place the wheel  chocks  as
        previously outlined and  then  lower the trailer or  tanker dolly
        wheels making sure that  the dolly  wheels are setting on a firm


                                A-l

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                      APPENDIX A








            SAFETY OPERATING PROCEDURE S#6




LOADING AND UNLOADING OF TRAILERS, TANKERS AND TRUCKS

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h)    All areas outside the placement cell which are impacted by leakage will
      be cleaned up according to the procedures described in the appropriate
      Health and Safety Plan.

                  The pump and hoses will be transferred from cell to cell as
work progresses. Upon completion of the final cell, the pump and hoses shall
be buried with the final waste placement prior to final capping.
5.10   HEALTH AND SAFETY PLAN

                  The Health and Safety Plan to be followed during the
placement of the waste in the placement cell will be in accordance with the
Health and Safety Plan applicable to the remedial work which generates the
waste. The Health and Safety Plan will typically be one of the following:

•  Environmental Health and Safety Plan for Survey Activities, or
•  Environmental Health and Safety Plan for Special Construction Activities.

                  In cases where two waste generating activities are ongoing
concurrently, the more stringent Health and Safety Plan will be implemented
at the waste placement cell.
                               41

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a)    Immediately shut down any operating pumping equipment.

b)    Notify the appropriate personnel that repairs are required immediately.

c)    Drain and collect all liquid from the hoses and isolate the leaking
      portion.

d)    Perform all line breaking in accordance with Safety Operating
      Procedure S#10 "Line or Equipment Breaking Checklist" (See
      Appendix E).

e)    Repair or replace the leaking portion of hose as necessary.

f)    Should repairs be lengthy or further pumping be required before
      repairs can be completed, make provisions for temporary bypass of the
      damaged area.

g)    In addition to the normal safety clothing requirement, the following
      safety equipment must be worn for work on leaking hoses:
      -   rubber rain suit
      -   rubber gloves
      -   rubber boots
      -   face shield
      -   respirator (Scott 64 OAF or approved equivalent).
                               40

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                  Precipitation falling within a prepared area that has begun
to receive waste material will be contained within the excavation and shall be
removed to a trailer or storage on the AOC Where possible, precipitation
landing on placement areas that have been capped with day will be diverted
to the local surface drainage courses for discharge off the Landfill Site. The
daily inspections will insure that this precipitation remains as non-waste
contact surface water.

                  If water is sediment-laden, it will be allowed to settle until
the water is of reasonable clarity so as not to impair the operation of OCC's
Treatment facilities.  In order to reduce the potential for sediment discharge
with the waste contact surface water, OCC will install a filter (See Plan 1)
around the pump to reduce the sediment intake.

                  A submersible pump and dedicated flexible
chemical-resistant hose will be used to pump the water from the waste cell
area.  At OCCs option, either manually-controlled or level-activated pumps
may be used to pump water from the disposal area. Any joints in the hose
shall be wrapped with duct tape and shall be inspected  once per day during
pumping operations to monitor the integrity of the line.  If
manually-activated pumps are used, single hoses with hourly inspections
will be used.  If level-controlled pumps are used, encased hoses and daily
inspections will be used.

                  In the event that leakage is detected in any of the hoses,
the following procedures will be followed:
                                39

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above-grade haul roads will be scraped down and made level with the
existing grade. This material will be placed within the waste cell area.

                  Dust control measures on haul roads shall be
implemented on an as-needed basis. These measures will include the
application of water or calcium chloride. Maximum speed on haul roads will
be limited to ten miles per hour to further reduce dust generation.
5.9   SURFACE WATER HANDLING

                  The waste placement and cell preparation areas shall be
constructed in such a sequence as to maintain positive surface drainage of
rainwater away from the active cell placement area and toward existing
surface water drainage systems.  Surface water shall be diverted around the
prepared areas by means of swales as shown on enclosed Plan 1.  Wherever
possible, sheet flow conditions are preferred as opposed to concentrating
surface water flow in swales.

                  Precipitation falling within a prepared area that has not
yet begun to receive waste material will be pumped from the cell and
discharged to the surrounding drainage swale.  A dean pump and discharge
line \
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b)    During cell placement activities for personnel within prepared area but
      not within waste cell use Level S-3 protective equipment (See
      Appendix D).
c)    During times of entry with all waste covered or sealed use Level S-3
      protective equipment.

                  The above levels of worker protection will be upgraded by
the Safety Officer should the air monitoring being conducted indicate that
such an upgrade is warranted.  The Safety Officer will follow the guidelines
for the pertinent health and safety plan per Section 5.10 in determining
whether such actions are required.

                  Access into the prepared cell areas will be through an
opening in the temporary fence. The openings  will be dosed nightly with
fencing or similar material.

                  The location of haul roads and accesses into the cell areas
will depend upon the cell location.  The intent will  be to maximize the use of
haul roads once they are constructed.

                  Haul road requirements must be determined in  the field
to suit the conditions and needs encountered. Haul roads within cell areas
will simply consist of a layer of stone consistent with the intended purpose
and estimate of usage and will be upgraded as required.  If deemed
appropriate by the OCC Field Representative, a filter fabric may be used in the
haul road construction. Prior to final capping of the Landfill Site, all
                                37

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-  collection systems,
-  site benchmarks,
-  advisory signs, and
-  fences.

Based upon the inspections made, OCC shall promptly repair or modify any
problems identified.

                 All records shall be kept available at the OCC Field Office
for reference.

                 Upon completion of each cell placement area, OCC shall
submit a copy of the records of waste placement and a record drawing
stamped by a New York State registered Professional Engineer to the
EPA/State.
5.8    SECURITY FENCE AND ACCESS REQUIREMENTS

                 A temporary security fence (snow fence) will be placed
around the perimeter of the prepared area.  Access within the fenced areas
will be restricted to personnel equipped with the following equipment:

a)     During cell placement activities for personnel entering waste cell use
      Level S-2 protection equipment (See Appendix D).
                               36

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                   In addition to the above activities, a daily record of waste
 placement and inspection activities shall be maintained at the project site.
 The daily record shall include:

•  records of waste placement in cells:
    -   date,
    -   type,
    -   quantity,
    -   container type or bulk,
    -   location (accurate to 50'+), and
    -   disposal method;

 •  records of Landfill Site testing, (soil density, moisture for clay cap), and

 •  records of daily inspections:
    -   day cover,
    -   disposal area inspections (and sideslopes under interim cover),
    -   surface water control and discharge, and
    -   haul roads.

                  Regular maintenance inspections shall be made on a
 weekly basis as specified in Addendum HI of the Settlement Agreement for
 the following:

 -   slopes,
 -   vegetation,
 -   drainage structures,
                                 35

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aspects of the waste cell placement program to ensure compliance with
approved plans and specifications:

-  cell construction,
-  benn construction,
-  waste placement,
-  waste compaction,
-  material transfer,
-  haul road conditions,
-  requirement for dust control,
-  equipment  cleaning,
-  interim cover placement,
-  surface water control,
-  health, safety and personal hygiene, and
-  air  monitoring.

                 The air monitoring requirements during the period of
active cell operation will be identical to the air monitoring program
implemented at the point of waste generation.  In cases where two waste
generating activities are ongoing concurrently, the more stringent air
monitoring plan will be implemented at the waste disposal cell.

                 It is to be noted that air monitoring of the waste cell
operation will not be required in cases when the waste material being placed
into the cell is contained in sealed units (i.e. 55-gallon steel drums or fiber
drums).
                               34

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                  The preferred source of loam to be used for the final cap is
the residual from incineration of OCC remedial wastes at the proposed
Niagara Plant solid waste incinerator.  It is currently estimated that this
incinerator will generate approximately 35/000 cubic yards of ash residue per
year.

                  OCC will apply for governmental "de-listing" of the
residual ash from its status as a hazardous waste.  Concurrently with this
application to de-list the residual ash, OCC will petition NYSDEC for the
beneficial use of this residual ash for use as fill, including its use as
intermediate loam in the final caps at  the S-Area and the DWTP.

                  If the ash is delisted and its use satisfies all applicable state
and federal regulations, it will be used as intermediate loam for the final cap..
If, at the time of final capping, the residual ash has not been  de-listed and
accepted for beneficial use, does not meet applicable state and federal
regulations, or is not available, it will not be used, and an alternate source of
intermediate loam will be readily  available for immediate use.
5.7   SUPERVISION, DOCUMENTATION AND
      MONITORING REQUIREMENTS	
                  The OCC Safety Officer shall be present at the project site
whenever waste materials are being placed into the daily cells. The Safety
Officer or his appointed designee will provide oversight of the following
                                33

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                  The final top slope of each waste cell will be set at a
minimum of two percent grade. This will not only promote surface drainage,
but also provide a base for any required additional lifts. The exterior side
slopes of each cell will be kept to a minimum of 1:2 and in those cases where
the cell lies along the outside edge of the Landfill Site, the slope shall be
graded according to the final Landfill Site closure plan.

                  Typical waste cell construction progression is presented in
enclosed Plan 1.
5.6.2  Final Capping

                  As major portions of the Landfill Site reach final grade,
OCC will install the final cap, as specified in the S-Area Settlement
Agreement, over the completed areas. The final landfill cap shall  consist of:

•  6 inches of topsoil, overlying
•  18 inches of intermediate loam, overlying
•  36 inches of day (KS1 x 10~7 on/sec).

                  The 18-inch intermediate loam layer described above will
required the use of approximately 11,000 cubic yards of material as  a part of
the final cap at the Landfill Site. In addition, if the DWTP is removed, the
DWTP structures will be demolished  and  most of the DWTP will be capped as
described above. This will require approximately 6,500 cubic yards of loam
material as part of the final cap at the DWTP.

                                32

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-  30 mil polyethylene film or equivalent.

                  The polyethylene film will only be used in cases in which
disposal activities are planned to be resumed within 72 hours.

                  It should be noted that fiber drums may be kept within the
designated drum storage area  in the disposal areas for extended periods as
long as the drums are covered with polyethylene.

                  In all other cases, the waste will be capped with a
minimum compacted thickness of six inches of day.  The clay will be obtained
from sources as directed by OCC. The clay will have a permeability of
1 x 10~7 cm/sec or less with a  minimum of 40 percent fines passing the #200
sieve.  Prior to and during use at the Landfill Site, the imported clay shall be
tested in accordance with the  requirements specified  in Appendix C.  This
includes the clay used for the  initial six-inch base.

                  Results of  these tests will be forwarded to EPA/State prior
to use of the material on the Landfill Site.

                  The size of each daily spoils cell will be based on the
volume of waste available for  disposal on that particular day. Sections of the
disposal cell which will not be reused for periods in excess of 180 days will be
capped with an additional three inches of day. The additional three inches of
day will be compacted with a smooth drum roller to the density spedfied to
meet the 1 x 10"? cm/sec requirements.
                                31

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5.5   LAGOON DECOMMISSIONING

                  The S-Area lagoons will be decommissioned.  This will
involve the cleaning of the lagoons in accordance with standard plant
operating procedures and then dismantling the water handling functions of
the lagoons including:

-  removal of the slurry inlet pipe, and
-  plugging the outfall structure with cement.

                  The outfall pipe is connected to the portion of the
003 Outfall within the Site Barrier Wall that is to be severed and plugged.
Severing and plugging of the 003 Outfall will effectively isolate the outfall
pipe.
5.6    WASTE CAPPING

5.6.1  Interim Capping

                  At the conclusion of each working day, or as necessitated
to control vapor emissions, the waste cell shall be covered with one of the
following caps:

-  six inches of low-permeability clay (K£l x 10'? cm/sec); or

                                30

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    •  crane, or
    •  conveyor system
-   dump/unload directly into place from within the cell (requires dirty haul
    road designations)

                  Depending upon the waste volume and character, the
methodology for waste placement and transfer will vary and is not necessarily
limited to those described above.
5.4   OTHER CONSIDERATIONS

                  Placement of waste on the Landfill Site will not interfere
with the installation of the proposed wells and collection systems. The
condition of the Landfill Site at the time of construction of various
appurtenances will be taken into consideration.  Possible additional loading
due to increased heights of fill will also be considered.

                  Any wells in existence at the time the waste cells are
constructed will either be removed or extended as appropriate. Wells not
included in the ongoing monitoring programs will be removed subject to
EPA/State concurrence and the others will be extended as appropriate.  Any
well included in the ongoing monitoring programs which become damaged
will be replaced with a new installation unless an appropriate alternate well
already exists.  Wells installed after the waste cells are constructed will be
integrated into the cover design.  Removal of wells will be undertaken in
accordance with the protocols described in Appendix F.

                               29

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 "contaminant reduction zone" at the equipment wash facility or other agreed-
 upon location. Standard Operating Procedures for On-Site Vehicle Traffic are
 presented in Appendix B.

                  Construction and maintenance of haul roads will be an
 on-going operation with dean gravel being added on an as-needed basis.

                  Specific details of waste placement, haul road designations
 (i.e. clean, dirty), contaminant reduction zone locations and container loading
 and unloading will be determined in the field by the OCC Field
 Representative, when concurrences by the EPA/State Field Representative
 prior to implementation.  The following options are available for  waste
 placement:

 Waste Transport Containers
-  55-gallon steel drums - secured lid
 -  watertight dump truck with polyethylene cover
 -  watertight lugger box with polyethylene cover
 -  DOT approved fiber waste container
 -  fiber drums

 Waste Transfer
 -  dump/unload directly into cell from edge of cell
 -  dump /unload into a staging area and transfer into place using  a:
   •  backhoe
   •  bulldozer
 »
   •  dragline

                               28

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areas recompacted by large equipment when they return to the Landfill Site
for the larger waste volume programs. Typical equipment to be used for
compaction include:

•  Self-propelled vibratory Sheeps Foot Compactor typical model numbers:
   -  Raygo 320
   -  Dynapac CA25
   -  Bomag BW605

•  A small vibratory roller available at the Landfill Site for all of the small
   programs for compaction purposes.

                 Compaction procedures will be determined in the field by
the OCC Field Representative, taking all of the pertinent factors into account.
The test results will be reviewed with the EPA/State Field Representative.
Prior to proceeding to the second and third lifts of waste placement, all of the
waste disposal areas will be proof-rolled with a 20-ton (static)
smooth-drummed roller to reduce the potential for  future subsidence.  Care
will be taken in the area of drummed waste placement to maintain the
integrity of the underlying drums while proofrolling.  The OCC and
EPA/State Field Representatives shall determine the level of compaction
required in drum disposal areas.

                 Vehicles hauling waste material to the placement area
will not enter and leave the waste cell unless appropriate haul road
provisions have been made.  These provisions will include construction and
maintenance of "dean"  and "dirty" haul  routes and allowances  for a
                               27

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5.3   PLACEMENT IN WASTE WELLS

                  All waste placement into the landfill site will be
completed under the direction of the OCC Field Representative in accordance
with the overall grading plan and an individual plan describing the proposed
disposal activities for each individual disposal area.  The individual plan will
be subject to concurrence of the EPA/State Field Representative.

                  All bulk and drummed wastes will be placed into the
prepared placement area in the corner opposite the lowest base elevation.
The size of the area prepared to receive waste will be consistent with the
estimated volume of waste expected to be generated during that disposal
period.  A disposal period typically would last for one to six months
depending upon the type and amount of remedial activity scheduled for the
Site. Typical cells will range in size from 7,500 square feet to 85, 000 square
feet.

                  The material shall be shaped into a lift of approximately
five feet in height consistent with the final grading plan which has been
designed to improve the surface water runoff characteristics from the Landfill
Site. The material shall be  compacted to the extent practicable, given the
equipment available at the time of placement. For the large volume waste
placement programs, specific heavy equipment will be dedicated to the
compaction and interim operations.  The small volume waste placement
programs for which heavy compaction equipment will not be available at the
Landfill Site will utilize alternate compaction equipment.  Further
compaction of these small volume wastes will be addressed by having these
                               26

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to insure that precipitation landing on completed areas maintains its
non-waste contact status and can, therefore, be allowed to discharge off the
Landfill Site.

                  The berms will be constructed using clay which shall be
compacted in six-inch to nine-inch lifts to a density at least equal to 90 percent
of the Maximum Modified Proctor Density or to the density specified by the
day testing laboratory to attain an in-place permeability of 1 x IQ~? on/sec,
whichever is greater.  The berm will be keyed three inches into the six-inch
compacted clay base to prevent surface water from entering or leaving the
cell. In the case of cells constructed on top of previous cells, the berms shall
key into the interim cap of the underlying cells. The clay key will be
constructed by pressing pieces of lumber into the lower berm,  removing the
lumber, and then placing the upper day berm. All upper cells  are to be
constructed in such a manner  as to provide the same drainage configuration
as that constructed for the first layer of cells.

                  The berms will have an interior  slope of 1:1 and an
exterior slope of 1:2 or be constructed to match the final contours of the
Landfill Site, allowing for the five-foot cap,  if the cell lies along the edge of the
Landfill Site. The berms shall be three feet wide.

                  Plan 1 presents a typical cell construction detail for
disposal area 3A.
                                25

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                                                                                                          CITY OF NIAGARA FALLS
                                                                                                       DRINKING WATER TREATMENT PLANT
                NIAGARA  MOHAWK
                 POWER CORP.
                                                                                                                             COSTING GROUND CONTOUR
769-10/07/89-68
                                                                                                                                           figure  9
                                                                                                               EXISTING  TOPOGRAPHICAL FEATURES
                                                                                                                                     S-Area Landfill

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5.2   LANDFILL SITE PREPARATION

                  Prior to waste placement at the site, a layer of day
(minimum six-inch compacted thickness) will be placed on the Landfill Site
on which all waste will be placed. This day placement will take place as each
disposal cell is constructed.  No pregrading will be done as the first lift of
waste will vary somewhat in thickness to accommodate the topographical
irregularities.  Efforts will be made to overcome the irregularities in grade
over the first two waste lifts  to even out lift heights to the extent practicable.
A map depicting existing topographical features is presented in Figure 9.

                  To prepare cells for each five-foot lift of waste, clay berms
will be constructed around the entire perimeter of the proposed disposal cell
area.  The berms will be at least two feet in height at all locations around the
perimeter and shall be of sufficient height to contain a 25-year storm event
(approximately four inches of rain in a 24-hour period).

                  In order  to insure that the placement can continue to
accommodate a 25-year storm event while the available storage area within
the cell shrinks due to waste placement, surface water landing on top of the
completed placement area (daily day cover in place) will be directed away
from the unused portion of the disposal area. This will be accomplished by
leaving a windrow of clay along the edge of the covered cells  to direct dean
surface water to adjacent  completed areas and ultimately off the Landfill Site.
Inspection of the day capped waste areas will be induded in a daily inspection
                                24

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                                                                                                 JF NIAGARA FALLS
                                                                                        DRINKING WATER TREATMENT PLANT
NIAGARA  MOHAWK
 POWER CORP.
             ROBERT   MOSES   PARKWAY
                                                                                                      LEGEND


                                                                                                      	9SO	 PROPOSED FINAL CONTOUR
                                                                                                                                figure SB

                                                                                                                                PLAN A
                                                                                                                   FINAL GRADING  PLAN
                                                                                                                         S-Argo Landfill

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                                                                                     A       CITY OF NIAGARA FALLS
                                                                                     y\  DRINKING WATER TREATMENT PLANT
NIAGARA MOHAWK
 POWER CORP.
                                                                                                         LEGEND
                                                                                                                PROPOSED FINAL CONTOUR
                                                                                                                               figurt 8A
                                                                                                                                PLAN B
                                                                                                                  FINAL GRADING  PLAN
                                                                                                                        S-Araa Landfill

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                                                                               CITY OF NIAGARA FALLS
                                                                           DRINKING WATER TREATMENT PLANT
ROBERT   MOSES    PARKWAY
                                                                                            mm  PROPOSED uuir or s -ARE*
                                                                                            *»*»  WASTE PlACtUfNT

                                                                                             7   PLACEMENT AREA OCSOHAIKM
                                                                                                               figure 7A
                                                                                                                 PLAN  B
                                                                                        PLACEMENT AREA  22'-26' LIFT
                                                                                                         S-Area  Landfill

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                                                                                           CITY OF NIAGARA FALLS
                                                                                      DRINKING WATER  TREATMENT PLANT
PHOPOSU) uuir or s -AREA
WASTE PLACEMENT
NIAGARA  MOHAWK
 POWER CORP.
                                                                                                         5   PtACEUENI AREA
             ROBERT   MOSES    PARKWAY
                                                                                                                           figure 6A
                                                                                                                             PLAN  B
                                                                                                PLACEMENT AREA 16.5'-21.5' LIFT
                                                                                                                     S-Aroa Landfill

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                                                                                               ln\\      CITY OF NIAGARA FALLS
                                                                                               \3\\ DRINKING WATER TREATMENT PLANT
                                                                                                                        LEGEND
                            ROBERT   MOSES   PARKWAY
                                                                                                                         man PROPOSED UUIT or S-AREA
                                                                                                                         2^J WASTE PLACEMEN r

                                                                                                                          5   PLACEMENT AREA DESIGNATION
                                                                                                                                          figure SB
                                                                                                                                            PLAN A
                                                                                                                    PLACEMENT AREA  11f-13' LIFT
                                                                                                                                    S-Aroa Landfill
CRA

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                                                                                     \
                                                                                                   CITY OF NIAGARA FALLS
                                                                                              DRINKING WATER TREATMENT PLANT
                                                                                                                 LEGEND
                                                             NO FIUJNG ON VCST Of
                                                                  rtu \rt « OROOI TO
                                                                  »T ttmj» d£v»noN$  \
                                                             OH BOIH SDCJ «r -nc IAOOONS'.
NIAGARA  MOHAWK
  POWER CORP.
                                       \	
               ROBERT   MOSES    PARKWAY
                                                                                        INDUSTRIAL  WHARF
 mm  PROPOSED LIMIT or s -AREA
 *«a  WASTE PLACEMENT

  1    PLACEMENT AKEA DESICNATION

  U    f»l FKOM CtlTDNG UO«N
  ""    CREST OF LAGOON MOUNDS
                         figure  5A
                           PLAN B
PLACEMENT  AREA  11'-16' LIFT
                  S-Areo Landfill

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                                                                            CITY OF NIAGARA FALLS
                                                                        DRINKING WATER TREATMENT PLANT
ROBERT   MOSES    PARKWAY
                                                                                              LEGEND


                                                                                               IWfl PROPOSED UMT OF S-AKEA
                                                                                               "Eil WASTE PLACEMENT

                                                                                                 2  PIACCUCNT AKEA DKSCNAIIOh
                                                                                                                figure 48
                                                                                                                 PLAN A
                                                                                      PLACEMENT AREA  5.5'-10.5*  LIFT
                                                                                                         S-Area Landfill

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                                                                                            CITY OF NIAGARA FALLS
                                                                                        DRINKING WATER TREATMENT PLANT
                                                                                                           LEGEND
NIAGARA MOHAWK
 POWER CORP.
             ROBERT   MOSES   PARKWAY
•jri  PROPOSED UHir or s -AWA
*^l  WAS1E PLACEMENT

 1   PLACEMENr AREA DESIGNATION
                                                                                                                               figure 4A
                                                                                INDUSTRIAL  WHARF                                 PLAN  B
                                                                                                    PLACEMENT  AREA  5.5'-10.5'  LIFT
                                                                                                                        S-Area Landfill

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                                                                                                        *f    100'
                                                                                                \\
                                                                                                  ,P>\\       CITY OF NIAGARA FALLS
                                                                                                  w"  DRINKING WATER TREATMENT PLANT
                                                                                                                              LEGEND
                                                                                                                               RI«3FI PROPOSED UMT OF S-AREA
                                                                                                                               [&&J WASTE PLACEMENT

                                                                                                                                1   PLACEMENT AREA DESGNAIlnN
~*^^£>
CRA
                                                                                                                                             figure  3B
                                                                                                                                               PLAN A
                                                                                                                        PLACEMENT AREA 0'-5' LIFT
                                                                                                                                       S-Aroa Landfill

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                                                                                            CITY OF NIAGARA FALLS
                                                                                    y\   DRINKING WATER TREATMENT PLANT
                                                                                                       LEGEND
NIAGARA  MOHAWK
 POWER CORP.
             ROBERT   MOSES    PARKWAY
mm  PROPOSED uuir or S-AREA
&LJ  WASH: PLACEMENT

 1   PLACEMENT AREA DESIGNATION
                                                                                                                             figure  3A
                                                                                                                               PLAN B
                                                                                                        PLACEMENT AREA  0'-5* LIFT
                                                                                                                      S-Area Landfill

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 to minimize erosion and still provides a reasonable slope which facilitates
 maintenance of the final cap. The actual final Landfill slope and area will
 vary to accommodate the actual waste volume requiring placement.  A
 minimum three percent slope has been used for the top surface of the
 landfill.

                  Based upon the S-Area Remedial Program Schedule and
 the estimate of waste volume to be generated, a general plan has been
 prepared identifying where the wastes from each phase of the 5-Area
 Remedial Program will be placed. The preliminary disposal area locations for
 Plan B waste staging are presented in Figures 3A through 7A for the five
 successive lifts of waste planned for placement. Figures 3B through 5B
 illustrate the waste staging for Plan A indicating three successive lifts of
 waste. Based on the fact that the waste volumes expected are only estimates,
 it is understood that actual disposal volumes and conditions will change and,
 therefore, it will be necessary to periodically update the estimated  volumes
 shown in Tables 4A and 4B and to account for the differences encountered.

                  Based on a cap with 20 percent grade and the generation
 volumes of Table 4, preliminary final grading plan for the Landfill Site have
 been developed for both plans  and are presented in Figure 8A and  8B. These
grading plans will accommodate a 5-foot cap over the expected required
 capacity of 66,000 cubic yards (65,100 cubic yards bulk; 900 cubic yards drums)
for Plan B and 33,700 cubic yard, (32,000 cubic yard, bulk; 900 cubic yards
 drums) for Plan A.  The S-Area Remedial Program will be undertaken in a
manner which minimizes solid waste generating activities so that the height
of waste placement areas can be kept as low as possible.
                                                 *•
                                23

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                                            TABLE 4B
Disposal
  Area

Areal
Area2

AreaS



Area 4
AreaS
                                  SOLID WASTE VOLUMES AND
                                      WASTE STAGING PLAN
                                   (PLAN A - RELOCATED DWTP)
     'Remedial Construction
        Survey/Activity

Northern Containment System
   Boreholes (1)
Water Treatment Plant Wells (1)
Chemical Monitoring Wells (1)
Tracer Monitoring Wells (1)
S-Area Bedrock/Overburden Study
   Wells (1)
S-Area Barrier Well Investigation (1)
Bedding Study (1)
Monitoring Program-Bedrock Wells
48" Intake Line Survey
day Trench Investigation
DWTP Rehabilitation Wastes
Trench:
Underground Utilities relocation
Severance of Underground Utilities
at Barrier Wall
S-Area Barrier Wall Construction
S-Area Collection System

Lagoon Cleaning
Northern Area Capping (2)
DWTP Collection System
DWTP Capping
                      Waste Volume
                   Bulk (cy)      Drums
                                            Areal Totals
Area 2 Totals
                                 Area 3 Totals
                                            Area 4 Totals
                                                                  1,000
                                                                  2,500
12,900
15,400

10,500
10300

  450
 1,125
 1,575

2,500*
	0_
 2300
           * DWTP ColL System - assume 1000* length, 4' wide, 14' depth average
              and 1,2 bulking factor = 2500 cy.
S-Area Capping
                                            Area 5 Totals

                                    Combined Area Totals
                      1,800
                      1,800

                     32300 cy
                                                                                   1348
                                                                                    300
                                                                                     11
                                                                                     10
                                                                                     50
                                      1,898
                                                                   1,898
                                                                  (or900c.y.)
Survey Waste from DWTP - Eastern Area (EPA Investigation) - estimated volume = 10 drums
Total available capacity at S-Area is 90,000 cubic yards
Total remaining available capacity for additional S-Area wastes is 56,300 cubic yards.

Notes:
(1)      Completed Activities, combined number of drums from these
        activities is 1548.
(2)      Assuming day cap for the whole area north of Adams Ave. (i.e. worst case)

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                                                                                       Page 2 of 2
                                            TABLE 4A

                                  SOLID WASTE VOLUMES AND
                                     WASTE STAGING PLAN
                                    (PLAN B - DWTP IN PLACE)

Disposal         Remedial Construction                             Waste Volume
  Area             Survey/Activity                              Bulk(cy)     Drums

Area 6     Water Treatment Plant Capping                           12,300
           Water Treatment Plant Monitoring                       	 	60_
                                            Area 6 Totals          12,300              60

Area 7     Concrete Liner Removal/Intake
           Tunnel                                                 1,300  	-_
                                            Area7Totals           1,300
Area 8     S-Area Capping                                         2,200
                                            Area 8 Totals           2,200

                                   Combined Area Totals           65,100 cy   1,970 Drums
                                                                            (or900c.y.)
Survey Waste from DWTP - Eastern Area (EPA Investigation) - estimated volume * 10 drums
Total available capacity at S-Area is 90,000 cubic yards
Total remaining available capacity for additional S-Area wastes is 24,000 cubic yards.

Notes:

(1)      Completed Activities, combined number of drums from these
        activities is 1548.
(2)      Assuming day cap for the whole area north of Adams Ave. (i.e. worst case)

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                                                                                         Page .1 of 2
                                             TABLE 4A

                                   SOLID WASTE VOLUMES AND
                                      WASTE STAGING PLAN
                                     (PLAN B - DWTP IN PLACE)

Disposal         Remedial Construction                              Waste Volume
  Area              SinroeylActivity                               Bulk(cy)      Drums

Area 1     Northern Containment System
              Boreholes (1)
           Water Treatment Plant Wells (1)
           Chemical Monitoring Wells (1)
           Tracer Monitoring Wells (1)
           S-Area Bedrock/Overburden Study
              Wells (1)
           S-Area Barrier Well Investigation (1)
           Bedding Study (1)                                            -            1348
           Monitoring Program-
              Bedrock Wells                                             -             300
           48" Intake Line Survey                                                       11
           day Trench Investigation                                                     10
           DWTP Test Pits                                          8,100
           DWTP Rehabilitation Wastes                               1,000   	-
                                             Area 1 Totals           9,100            1369

Area 2     Trench:
           Underground Utilities relocation                            2,500
           Severance of Underground Utilities
           atBarrierWaU                                                              50
           S-Area Barrier Wall Construction                          12,900   	•_
                                             Area 2 Totals          15,400               50

Area 3     S-Area Collection System                                 10,500
                                             Area 3 Totals          10300

Area 4     Lagoon Cleaning                                          450
           Replace 42" High Service
              Discharge Lines                                         100
           Access Shaft                                              825
           Northern Area Capping (2)                                 1,125
           Collection System Pump Station                            3300
                                             Area 4 Totals           5,800

Area 5     Optional Collection Systems
           i) Filtration Plant "A"                                     1,600
           2) Filtration Plant "B"                                      1,400
           3) Filtered Water Reservoir                                 5300
                                             Area 5 Totals           8300

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                                                                                     10'   100'
                                                                              \\
                                                                                     CITY OF NIAGARA FALLS
                                                                                  ADRINKING WATER TREATMENT PLANT
NIAGARA  MOHAWK
 POWER CORP.
                                                                                                      LEGEND
                                                                                                            AVAHABtE LANW1U. AREA
                                                                                                            FOR WASTE PLACEMENT
                                                                                                                         figure 2B
                                                                                                                          PLAN A
                                                                                                      UMIT OF PLACEMENT AREA
                                                                                                                  S-Area Landfill

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                                                                                                         CITY OF NIAGARA FALLS
                                                                                                   i\ DRINKING WATER TREATMENT PLANT
               NIAGARA  MOHAWK
                POWER CORP.
                            "OBERT   MOSES    PARKWAY
                                                                                                                               AVAILABLE IANOF1U. AREA
                                                                                                                               FOK WASH: PLACEMEN r
CRA
                                                                                                                                           figure  2 A
                                                                                                                                             PLAN B
                                                                                                                        LIMIT OF PLACEMENT AREA
                                                                                                                                    S-Areo Landfill

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5.0    SITE PLACEMENT

      5.1    SOLID WASTE DISPOSAL AREA

                       Solid and Semi-Solid Waste materials will be placed
      within the area defined by the Site Barrier Wall at the Landfill Site.  For the
      purposes of this plan, OCC intends to use only those areas historically utilized
      for S-Area waste disposal.

                       Because the existing lagoon at the landfill will be taken
      out of service, this area can be available for waste placement disposal for
     . Plan B, the area! extent of the proposed Site placement area is presented in
      Figure 2A. Figure 2B indicates that the area! extent of the proposed Site
      placement area for Flan A has been restricted to the east side of the lagoons as
      a smaller volume of waste is available for disposal. Table 4A and 4B present a
      sequential plan for waste placement in various areas and the anticipated
      volumes depending upon whether the DWTP is left in place (Table 4A) or
      relocated (Table 4B).

                       All waste will be placed in lifts of up to approximately five
      feet in height in accordance with the final grading plan. During the first lift,
      some areas may be in excess of five feet thick to account for present
      topographic irregularities.  Waste cells will be stacked on top of each other to
      accommodate waste placement and to match the final grading plan. The final
      grading plan is based on assumed final side slopes of approximately 20 percent
      although a final slope of up to 25 percent is acceptable.  A final slope of 20
      to 25 percent is stable, provides good surface water drainage, can be controlled

                                     22

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Judgment.  Discharge to a permitted outfall at the Buffalo Avenue Plant will
require OCC to obtain permit authorization for such discharge. OCC shall use
its best efforts to obtain all permits, approvals or authorizations for discharge
by the scheduled start of remedial systems operation that will require AFL
Treatment.
4.4.7  Containment Dike

                  The design of the S-Area APL/NAPL storage facility will
include a concrete containment dike to be constructed surrounding an area
sufficient to permit the construction of 6 tanks of 158,000 gallons each. This
containment dike will have a capacity of at least 110 percent of the capacity of
the largest tank plus allowances for rainwater.  The floor of the containment
area will be sloped to direct spills, leaks, and rainwater to a sump from which
it will be pumped back to a storage tank for subsequent treatment.
                                21

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     for installation of APCE equipment on OCC's Liquid Incinerator, for
     permitting CXCs Solids Incinerator to incinerate liquid waste and for
     other incineration, treatment and storage alternatives, if required.

c)    APL Treatment

                  Initially, all APL collected from the sources described in
Section 2.2 will be trailered or piped directly to OCCs existing Niagara Plant
Carbon Treatment facility following the separation of NAPL in the decanters
at the S-Area APL/NAPL Storage Facility. Once the rates of APL collection are
better defined  following Phase I remedial activities, OCC plans to construct a
Carbon Treatment facility adjacent to the existing Carbon Treatment facility.
It is presently anticipated that this new treatment facility will be capable of
handling approximately 300 gpm.  This facility will also be designed with an
allowance for expansion capacity in the event the actual APL treatment
requirements are higher than anticipated. The new treatment facility will use
two stages of carbon adsorption to remove organic compounds from the APL.

                  The carbon from the first stage (sacrificial bed) will be
containerized and stored in permitted facilities at the Niagara Plant pending
incineration in the OCC Solids Incinerator. The spent carbon from the second
stage adsorbers will be returned to the carbon vendor for regeneration.

                  Effluent from both carbon treatment facilities will be
discharged to the City of Niagara Falls POTW or to a permitted outfall at the
OCC Buffalo Avenue Plant. Discharge to the City's POTW shall be subject to
the requirements of subparagraph G(l) and (2) of  Addendum I of the

                                20

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                 OCC's activities to obtain governmental authorizations to
incinerate NAPL generated by activities under the Judgment at the OCC
Liquids Incinerator and the OCC Solids Incinerator will include the following:

(i)  OCC will collect samples of NAPL from the Landfill Site from two
    existing bedrock wells and two existing overburden wells selected in
    consultation with EPA/State. A total of 100-200 gallons will be collected.
    The  sample from each well location will be analyzed for heavy metals,
    ash,  and BTU value. OCC will submit a report describing the results of
    the sampling and analysis to EPA/State in accordance with Schedule A
    of the Remedial Waste Treatment Milestone Schedule (RWTMS).
    Within 60 days  following such submission, the Program Coordinators or
    their designees will meet to discuss the report.

(ii) Pursuant to the Supplementary Approval Procedures described in
    paragraph 4(b),  Section B, Attachment F-2, of OCC's Liquids Incinerator
    permit, OCC will submit to EPA/DEC a plan to collect a representative
    sample of NAPL from the Landfill Site ("NAPL Collection Plan") for
    characterization in accordance with permitting requirements.  The Plan
    will  include a description of collection procedures and a schedule for
    completing sample collection and analysis. OCC will submit the plan  in
    accordance with Schedule A of the RWTMS and will implement the
    Plan following approval by EPA/DEC permitting authorities in
    accordance with the schedule set forth in the approved plan.

(iii) In addition to these activities, OCC will pursue governmental approvals
    as described in  Paragraph 20 of the RRT Stipulation and in the RWTMS
                               19

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Treatment Facility. Following completion of the Phase I activities per
Section 4.3 of Appendix I, OCC will estimate whether the installed APL
storage tanks provide sufficient capacity for APL volumes expected to be
collected during one day's normal operations of remedial programs installed
under the Judgment and if one day storage is sufficient or necessary for
operational needs.  Within 30 days following completion of Phase I activities,
OCC will submit a report to EPA/State describing the results of the estimate.
If that estimate concludes that the installed APL tanks do not provide
sufficient storage capacity, OCC shall promptly install additional tanks to
provide such storage capacity.

                  The facility has been designed and will be authorized to
accommodate a maximum of six storage tanks.  In no event will OCC be
required to install more than  six tanks at the S-Area APL/NAPL Storage
Facility except as provided in Paragraph 20(d) or 20(e) of the Stipulation.

b)    NAPL Treatment

                  NAPL collected from sources described in Section 2.2 and
from the investigation activities described in Section 4.0, Appendix I will be
treated at a facility which satisfies all applicable regulatory and permitting
requirements.  As described in the RRT Stipulation, the OCC Liquids
Indrierator and the OCC Solids Incinerator, either singly or in combination,
are the preferred facilities for the treatment of NAPL generated during
activities under the Judgment.
                               18

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4.4.6  APL/NAPL Storage and Treatment

a)   AFL/NAPL Storage

                 APL and NAPL collected from the sources described in
Section 2.2 and from the investigation activities described in Section 4.0,
Appendix I will be temporarily stored in tanks pending APL treatment or
NAPL incineration. The S-Area APL/NAPL Storage Facility will be located
north of Adams Avenue, west of 53rd Street (see Plan 1).  Each tank at the
facility will be approximately 30 feet in diameter and 32 feet high, with  a
capacity of approximately  158,000 gallons.

                 Initially, one NAPL storage tank will be installed at the
facility to meet the anticipated operational needs of the thermal treatment
facility that is authorized or expected to be authorized for the S-Area NAPL.
Within 30 days following  the completion of the Phase I activities per
Section 4.3 of Appendix I,  OCC will estimate the monthly NAPL volumes
expected to be generated by normal remedial system operations under the
Judgment and will submit a report to EPA/State describing the results of its
estimate. If that estimate  indicates that three months of NAPL generation
will exceed the capacity of the installed NAPL storage tank, OCC will also
include in its submissions an assessment whether the installation of
additional NAPL capacity is required to meet the operational needs of the
NAPL thermal treatment  facility.

                 Initially, two APL storage tanks will be installed at the
facility to meet the anticipated operational needs of the Niagara Plant APL
                               17

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                  Dimensions and capacity of the decanters are as follows:

Decanter dimensions:   8 feet diameter
                       32 feet high
Decanter Capacity:       11,200 gal

                  A total of five decanters for the separation of NAPL from
the recovered APL/NAPL will be used.

                  Two decanters to process all of the APL/NAPL from the
overburden (purge wells and collection systems) will be used.  The flow from
the overburden purge wells (6 gpm) into a single decanter creates a detention
time of 1,900 minutes. The flow from the combined landfill site (6 gpm) and
Pump Station (22 gpm) Collection Systems into a single decanter creates a
detention time of 400 minutes.  If the DWTP is relocated the Pump Station
Collection System would not be constructed. However, a drain tile collection
system would be constructed at the DWTP. How rates will be determined
after realization of the reduced system location.

                  Flow from the bedrock purge wells, which is estimated to
be 270 gal/min., will be directed to three decanters. The use of three decanters
will result in an average detention time of 120 minutes.
                               16

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Handling Facility.  As such, the decanter size, decanting times, and storage
volumes are consistent with the Hyde Park system.

                  The NAPL (having a Specific Gravity of 1.6) will settle to
the bottom of the decanter while the APL (Specific Gravity « 1.0) will remain
above the NAPL. NAPL will then be drawn off from the bottom of the tank
and APL can be removed from the top of the tank.

                  A small proportion of the NAPL may be lighter than
water and will float on top of the APL. The conceptual design of the  decanters
provides for a number of pipe outlets situated at varying heights.
Lighter-than-water NAPL will be removed from the decanter periodically
using these outlets by reducing the fluid volume in the decanter to a level
below a selected pipe outlet. A small increase in the fluid volume will then
allow the light NAPL to flow out of the selected outlet and it can then be
piped to the NAPL storage tank.

                  The required settling time is dependent on the physical
characteristics of the liquids being separated. The rate of settling is more rapid
for larger droplet sizes, large density difference between phases, and low
viscosity of the continuous phase (APL).

                  The volume of the decanter vessel is selected to provide a
detention time sufficient to allow adequate separation of the  two phases.

                  Detention time is calculated from the relation:
Holding time = decanter voL/flow rate.          „.

                                15
                                                                  \

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4.4.3  Chemical Composition

                 Chemical analyses of samples from overburden and
bedrock survey wells are compiled in the reports entitled "Information
Summary Report, Volume II, Appendix 6 • Analytical Results, S-Area
Remedial Program" and "NAPL in Bedrock Beneath the Niagara River,
Assessment of Human Endangennent, S-Area Remedial Program".
4.4.4  Piping of APL/NAPL to Storage Facility

                 Efficient separation of NAPL from the collected
APL/NAPL and treatment of APL must take into consideration the
differences in the APL/NAPL characteristics from each area (volume fraction
and chemical composition). For this reason, APL/NAPL from the
overburden collection systems, overburden purge wells, and bedrock purge
wells will be piped separately to the S-Area APL/NAPL Storage Facility.
4.4.5  APL/NAPL Separation

Separation Method

                 NAPL will be separated from the recovered APL/NAPL
using gravity separation (decanting). It should be noted that the conceptual
design of separation methods for this plan are based on the separation
methods incorporated in the design of the Hyde Park Leachate Storage and

                               14

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                  The water from construction dewatering activities will be
pumped through a filtration unit such as a sand filter to remove suspended
material. Thereafter, the water will be trailered or piped to the S-Area Storage
Facility and carbon treated at an OCC Facility and discharged in accordance
with all applicable laws and regulations at the OCC Niagara Plant. Solid or
semi-solid sediment will be collected, solidified and placed in sealed units and
placed in the landfill site as described in Section 4.1.

                  Chart 2 presents the flow diagram for handling liquid
wastes.
4.4.2  Physical Characteristics of APL/NAPL

Specific Gravity of NAPL

                  Based on the results of physical testing completed on a
number of S -Area bedrock samples of NAPL, the specific gravity of NAPL was
determined to be approximately 1.6.

Viscosity of NAPL

                  Based on the results of physical testing completed on a
number of S-Area bedrock samples of NAPL, the viscosity of NAPL was
determined to be approximately 0.000118 Ib sec/ft2 (5.6 centipoise).
                                13

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                  The design of the separation decanters, storage tanks, and
ancillary equipment for S-Area AFL/NAFL will be based on the design of the
Hyde Park Leachate Storage and Handling Facility, including the
requirements of detention times for APL/NAPL separation. The design
capacity of the storage facility is discussed in Section 4.4.6 and 4.4.7.
4.4.1  Tunnel Water/Construction Water

                  In order to perform the visual inspection of the Emerald
Channel Intake Tunnel, it will be necessary to dewater the tunnel and
maintain it in a dewatered state for the duration of the inspection. It is
anticipated that approximately two days will be required to complete the
inspection. This activity will not be undertaken if a new DWTP is
constructed.

                  It is estimated that the initial volume of  water in the
tunnel is  860,000 gallons. This water will be discharged to the sanitary sewer
at the DWTP for treatment at the City of Niagara Falls POTW.  Once this
volume of water has been discharged, pumping will continue to keep the
tunnel dewatered. It is presently anticipated that a pumping rate of 70 gpm
will be required to accomplish this. The pumping of water beyond the initial
860,000 gallons will be handled in  the same manner as construction
dewatering activities as described in the next paragraph.
                               12

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treatment of the APL. This storage facility will be located north of Adams
Avenue, west of 53rd Street (see Plan 1).

                 This section discusses the conceptual design of the S-Area
APL/NAPL Storage Facility. This conceptual design addresses the
requirements of the APL/NAPL Storage Facility regarding:

1)    expected volumes of APL/NAPL to be pumped from the overburden
      collection systems, the overburden purge wells and the bedrock purge
      wells, as discussed in Section 3.2.1 and 3.2.2;

2)    estimated volume of NAPL to be recovered, as discussed in
      Section 3.2.2;

3)    physical properties of the APL/NAPL as they relate to separation of
      NAPL;

4)    temporary storage of the APL/NAPL; and

5)    treatment of the APL at the Niagara Plant APL Treatment Facility and
      incineration of the NAPL at the Niagara Plant Liquid Incinerator.

                 The  5-Area KRT Program provides for pumping and
collection of APL/NAPL from the overburden and bedrock. This APL/NAPL
will be transported from their source to the APL/NAPL Storage Facility,
NAPL and APL will be separated, and the NAPL and APL will be stored prior
to incineration or treatment, respectively.
                               11

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spread over semi-solid wastes to promote stabilization.  The use of absorbent
material will be at the direction of OCC's Representative in the field.
Materials which do not stabilize will be reworked until suitable stabilization
has been achieved. Where appropriate, the paint filter test methodology
(Method 9095 as described in EPA Publication SW846) will be used to
determine stability of semi-solid wastes. In cases where OCC and EPA/State's
Field Representatives do not agree as to when stabilization has occurred, a
paint filter test shall be conducted to confirm the degree of stabilization that
has been achieved.

                  Absorbent materials to be used for stabilization purposes
may include flyash, portland cement and "speedi-dry" type materials.  OCC's
Field Representative will select the absorbent to be used in each case and will
inform the EPA/State Field Representative of the selection. Should a
material other than one of the above be selected, concurrence with the
EPA/State Field Representative will be obtained prior to use.
4.4    LIQUID WASTE

                  Due to the anticipated volume of S-Area liquid wastes to
be handled, it will be necessary to construct a permanent storage facility
within the AOC. The proposed S-Area APL/NAPL Storage Facility will be
designed to be consistent with all applicable regulations and will include
decanters for the separation of NAPL from the APL and tanks for the
temporary storage of all the liquids prior to incineration of the NAPL and
                                10

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implemented. If the changes implemented do not resolve the handling
problems, the use of fiber drums will be discontinued.
4.2   BULK SOUP WASTES

                  All bulk solid waste will be transferred from its area of
generation or storage to the waste placement area on the Landfill Site.  The
wastes will be placed into the daily spoils cell and covered in accordance with
the specified operating procedures in Section 5.0. All loading and unloading
of waste from trucks will be done per Section 5.3 and Safety Operating
Procedure S#6 (see Appendix A).
4.3   SEMI-SOLID WASTES

                  Semi-solid wastes described in Section 2.1 will be placed
directly into a selected area of the active waste disposal cell and allowed to
decant.  The area chosen for semi-solid decanting will be field selected by the
OCC Field Representative in concurrence with the EPA/State Field
Representative.  Factors such as weather conditions, volume of semi-solid
waste, amount of observed decanting occurring and other relevant
information shall be taken into consideration in this matter.  Any collectable
liquid will be pumped out to a trailer or stored within the AOC on a daily
basis. Once suitably decanted, the material shall be capped in place (or
consolidated as appropriate) and the waste cell closed in accordance with the
specified operating procedures. If necessary, an absorbent material will be

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generated drummed waste to insure that drums contain no greater than
five percent void space. Any identified unfilled drums shall be topped up
with waste material. In the case of sludge wastes to be drummed/ the OCC
Field Representative shall perform a paint filter test for free liquids (Method
#9095 as described in EPA Publication SW846). The test shall be performed
once for every ten drums of each sludge-type waste or more often at the
discretion of the OCC and EPA/State Field Representatives. Material failing
the test shall have absorbent material added in sufficient amounts and mixed
to achieve stabilization.

                 Any drum placement at the Landfill Site will be upright,
side by side and covered so that material enters the voids between them.  The
drums may be double stacked.  As an alternative to steel drums, OCC may, at
its option  and with the EPA/State Field Representative's concurrence, use
fiber drums for non-saturated waste materials or DOT-approved fiber waste
containers. These substitute containers would be placed in the cell in the
same manner as the drums. The use of fiber drums will be restricted to
materials which are  compatible (based on moisture conditions, size, chemical
reactivity and corrosivity and shape) with the specific containers proposed for
use.

                 The use of fiber drums is further restricted to cases where
the drums will be placed either directly into a waste cell for placement at the
end of each working day or stored in the drum storage area for no longer than
one work day unless suitably covered with polyethylene. If fiber drums
exhibit handling problems, changes  in the handling procedures will be
                                8

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WASTE MANAGEMENT STEPS

WASTE GENERATI
*
UCUD
I
APL
APL/NAPL






— _, SOLD /
^ SEE
NAPL
SEPARATION
'
FILTRATION
(SEDIMENT REMOVAL) ApL
{
SEDMENT
i
STORAGE DECANT
*
pH ADJUSTMENT pREOPtTATE



t
TRANSFER TO fl) TRUCK
PUMT 00 PIPELINE





FILTRATION
NApL (SEDIMENT REMOVAL)
t
SEDIMENT


blUKAUt
\
PLACED IN TRANSFER TO
EALED UNTTS WONERATION
FACLTY
|

MSPECT
1

INCINERATE
*
TREATMENT AT
CARBON ABSORPTION
FAOUTY
t
DISPOSAL - DISCHARGE TO
SANITARY SEWER
SYSTEM
X
COVFP •

ASH
F
L
FULL | 	 1 	 1
NOT FULL INCWERATE

CHART 1

(0 TRUCK

ADD
WASTE

1

PAINT FILTER TEST
WHERE APPROPRIATE
FAIL
STABttJZED
^


1 PASS
-p SOLD
I

CLOSE UNITS



*
E IN CELL

• REMOVAL OF PREOPITATE, IF ANY. DUE TO pH ADJUSTMENT
chart 2
BASIC WASTE MANAGEMENT STEPS - UQUID
S-AREA WASTE MANAGEMENT PLAN
CRA S—Area Landfill
1769-30/10/89-68-0 (C-7)

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 CRA
                        WASTE MANAGEMENT STEPS
















'
LKXJ
SEE CHi









LIQUID



ID
vn 2






sa

nrrvA
CE









f
ll-SOUD
I
MT (M
ILS
UfACTr fiClfCDATCn

*
SCUD/SEMI-SOLID
1
PLACE M CELL
r
INSPECT WASTE
1
T
SCUD
















































P
SE


fUl



L





! '
LACED IN
ALED UNITS
{
INSPECT
tnot
ftjll
ADO WASTE


CLOSE UNITS
1

njMtft IN uu
                    SCUDS
               PAINT FILTER TEST
              WHERE APPROPRIATE
          STABOJZED
SOLD
               r   T
              COMPACT TO EXTENT
                PRACTICABLE
                  COVER
                                                        chart  1

                             BASIC WASTE MANAGEMENT STEPS
                                        SOUDS / SEMI-SOLIDS
                           S-AREA WASTE MANAGEMENT  PLAN
                                                S-Area Landfill
1769-24/11/87-68-0 (C-1)

-------
4.0    WASTE MATERIAL STORAGE & HANDLING

                       The basic steps describing waste material handling are
      presented in Charts 1 and 2.
      4.1    DRUMMED SOUP WASTES
                       Drummed solid waste materials described in Section 2.1
      will be placed in a staging area in the active waste disposal cell in the S-Area.
      This staging area will be field selected by the OCC Field Representative subject
      to concurrence with the EPA/State Field Representative. As drums are
      accumulated in the staging area, the inventory of drums will be regularly
      reviewed.  The decision to remove the drums from the staging area to the
      operating disposal face within the disposal area will be made by the OCC Held
      representative in concurrence with EPA/State field representative.  The
      drums will then be covered in accordance with the disposal protocols detailed
      later in this section.  In the event that other remedial activities are taking
      place at the same time that drummed solid wastes are being generated, the
      drums may, at OCC's option, be disposed directly into the operating
      placement face in concurrence with the EPA/State field representative. The
      drums will be filled to  the maximum extent practicable with waste.  Empty
      drums disposed at the Landfill Site will be crushed prior to disposal.

                       As drummed wastes are generated or prior to site
      placement, the drums will be filled to contain less than five percent void
      s.pace. The OCC Field Representative shall make daily inspections of

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                                               TABLES

                                     NAPL VOLUME FLOW RATES
APL/NAPL
Source
System
         Estimated
          Start     APUNAPL
          Date      Flow Rate
                       (gpm)
            NAPL
        NAPL Flow
          Rate
          (gpm)
             Total NAPL
            Volume/Time
               Period
               (gallons)
                   Note
Overburden
Collection
System and
Purge Wells
        May 1993
 12
1
0.1
 0.12
 0.01
  5,200
First 30 Days
After 30 Days
Pump Station*1* March 1993
Collection
System
                        22
Bedrock
Purge
Wells
        June, 1995
270
270
270
8
4
0.4
21.6
10.8
 1.1
 31,100
 15350
  1,584

(91,000)
First Day
Second Day
Third Day and
thereafter
First 30 Days
Note:
(1)
If the DWTP is relocated, the Pump Station Collection System would be eliminated and a smaller collection
system will be implemented in its place.

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                                        TABLE2

                                NAPL GENERATION RATES
                                         Estimated
                                          Duration

                                          1 month (1993)
                                         4 months (1993)
                                          Continuous
                                          in 1993
                                          2 Weeks
                                          (1992)

                                          One Month
                                          (1992)

                                          One Month
                                          (1993)

                                          Continuous
                                          (1993)
                                                               Incremental
                                                                  Rate
                                                                 032
Description

Overburden Collection System and
Purge Wells (0.12)^ > (During Initial
Startup Period) and Pump Tests on
11 Bedrock Purge Wells (02) G)

Overburden Collection System and
Purge Wells (0.01)(3) + Pump Test on 11 BR
Purge Wells (0.2) (4)

Overburden Collection System and
Purge Wells (Estimated Long Term
NAPL Collection Rate)

Pump Test on 2 Bedrock Wells
Pump Test on 6 Bedrock Wells
Prototype Bedrock Purge Well System
(During initial Startup Period)

Prototype Bedrock Purge Well System
(Estimated Long Term NAPL Collection
Rate)

Notes:
(1)   1% of OBCS How (see Table 3) for first 30 days
(2)   Test 11 wells for 5 days each at 5 gpm. Allow week for recovery between tests
                          5x11
     therefore, Q = 5 gpm x7 x 22             =1.79 gpm
               Assume 10% NAPL           = 02 gpm
(3)   0.1% of OBCS flow (see Table 3) after first 30 days
(4)   See (2) above
(5)   Test 2 wells for 24 hours each at 75 gpm. Allow one week to perform both tests
                          2
     therefore, Q = 75gpmx=                =21.4 gpm

               Assume 8% NAPL             =171 gpm
(6)   Test 6 wells for 24 hours each at 100 gpm. Allow three weeks to perform all tests.

     therefore, Q = lOOgpmx_-r              =28.6 gpm
               Assume 8% NAPL             = 2.4 gpm
(7)   9 wells at 30 gpm each. Q = 270
     NAPL = 270 x (1 x 0.08 + 1 x 0.04 + 28 x 0.004)/30 = 2.1 gpm (see Table 3)
(8)   See Table 3 - Bedrock Purge Wells
                                                                 0.21
                                                                 0.01
                                                                 1.71
                                                                 2.4 (6)
                                                                 2.1
                                                                 1.1
 NAPL
 Volume
(gallons)

    13,820
    40,820



Continuous



    17240


    72,580


    90,720


Continuous

-------
the operation of the bedrock purge wells.  A total of 9 wells are included in
the initial design of the bedrock remediation system. Each well is planned to
operate at 30 gpm.  This is based on the experience gained at the Hyde Park
Landfill where well yields of up to 20 gpm were measured.  Since S-Area is
expected to have more groundwater available for extraction than Hyde Park
therefore a factor of 1.5 was applied to the 20 gpm.  In addition, a pump test
performed at 53rd Street identified well yields in excess of 100 gpm with
considerable drawdown criteria. Pump tests will be conducted as a part of
RRT Remedial Plans (see Appendix I, Section 4.3.2). Data collected from  these
tests will be used to determine appropriate pumping rates for each well.
Based upon current information, an initial pumping rate of 270 gpm is
reasonable.
3.2.2  NAPL Volume

                  This section addresses the volume of NAPL generated for
future treatment from the S-Area Remedial Program.

                  The estimated NAPL volumes and rates generated for
future incineration are summarized on Tables 2 and 3, respectively.

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Source

A.  Construction Water

    1)  Testexcavationsd)
        Waste Cell runoff
        Equipment decontamination
    2)  Utility Relocations
        Waste Cell Runoff
        Equipment decontamination
    3)  Slurry Walls
        DWTP Tile Collection Systemd)
        S-Area Tile Collection System
        Waste Cell Runoff
        Equipment Cleaning
                                                TABLE 1

                                        APL VOLUME ESTIMATES
                  Estimated
Flow Rate Range  APL Volume
     (CPD)
(gallons)
    APL
 Flow Rate
    (gpm)
(with DWTP)
14704,410
1440
200
2^10-9,950
0.0-40,600
1440
200
1440-12,140
0.0
720-11410
2,960-13,100
200
51,700
14,700
2,200
68,600
590,900
104400
11400
717,200
0.0
231,100
471,200
332400
35,400
                                                 5,220-26,450
    4)  Continued Dewatering of DWTP
        Tunnel (for inspection only of
        Emerald Channel TunnelXl)             	

        Total Construction Waste Water Quantity

    Dewatering Activities

    5)  Initial Dewatering of DWTP Tunnel(l)

        Total Dewatering Waste Water Quantity

C  S-Area Remedial System Operation

    6)  i)  Overburden collection system(2)
        ii)  Overburden purge wells (12 wells © 0.5 gpm)
        iii) Bedrock purge wells (9 wells ffl 30 gpm)
        iv) DWTP overburden collection systems(3)
           • Pump Station
           • Optional Systems
        100,800
        Total Operations Waste Water Quantity
Notes:
                    1,070,000
   201,600

 2,057,400 Gallons
                     860,000
                     860,000 Gallons
                                           6
                                           6
                                          270

                                           22
                                      not estimated

                                         304  Gallons/Minute
T)  These activities would be deleted if the DWTP is relocated
2)  APL flow rate is for scenario of completed Barrier Wall bui no capping.
3)  These activities would be reduced if the DWTP is relocated.

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 "No Migration Variance Permit
 Centralized Storage Facility
 UFA 90-86-0707
 EPA ID No. NYD 000824482
 Niagara Plant"
3.2   LIQUID WASTE VOLUME

                  Estimates have been made of the anticipated volumes of
liquid waste to be generated by the S-Area Remedial Programs.

                  The APL and NAPL liquid volume estimates are
individually calculated in the following sections.
3.2.1  APL Volume

                  APL generated by the S-Area Remedial Programs will be
treated at the existing Niagara Plant Carbon Treatment Facility or an
additional carbon facility to be built at the Niagara Plant Effluent from the
existing treatment facility will be discharged to the Niagara Falls POTW. The
effluent from the new treatment facility will be evaluated to determine
whether it will be discharged to the City of Niagara Falls POTW or a Niagara
Plant permitted outfall as per Paragraph 4.4.6.

                  The estimated APL sources and volumes generated are
presented on Table 1. The major portion of the APL waste generated is from

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3.0    WASTE VOLUMES

      3.1   SOUP WASTE VOLUME

                       Estimates have been made of the anticipated volumes of
      solid waste to be generated by the S-Area Remedial Programs.  The estimated
      waste volume is as follows:

      Plan A  (new DWTP is constructed)

      •  33,700 cubic yards of S-Area and DWTP Remedial Activity Wastes
         (32,800 c.y. bulk and 900 cy. drums);

      Plan B  (DWTP remains in place)

      •  66,000 cubic yards of S-Area and DWTP Remedial Activity Wastes
         (65,100 c.y. bulk and 900 cy. drums);

                       The S-Area solid wastes generated during the
      investigation phases of the programs that have already been completed are
      currently  stored in Building V-60. These wastes will be incinerated at OCC's
      proposed solid waste incinerator. Details of the CSF, its operation, remote site
      locations, and waste volume estimates are found in the following document:

-------
                 In addition, as set forth in Section 5.6.2, ash residue from
OCC's proposed thermal destruction unit at its Niagara Plant (OCC's Solids
Incinerator), may be used as intermediate fill for the contouring and final
capping.  Any waste generated within the AOC mat is removed from the AOC
will not be returned to the Landfill Site unless such waste is treated pursuant
to applicable regulations.
2.2    LIQUID WASTE

                 All APL and NAPL wastes from the S-Area Remedial
Program activities will be separated and subsequently treated at OCC's facility
at the Niagara Plant. The sources of APL and NAPL wastes will include the
following:

1.    Ground water from dewatering activities during construction including
      APL and NAPL collected during S-Area Remedial Programs.

2.    Cleaning liquids generated from washing operations, including
      solvents.

3.    APL/NAPL recovered from S-Area Remedial Program operations,
      including overburden collection systems, overburden and bedrock
      purge wells and overburden and bedrock NAPL recovery wells.

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                                                                                                                          0  100   230ft
  CRA
           figure 1

AREA OF CONCERN
   S-Areo Landfill
I769-IO/O7/89 68-1

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2.0    WASTE SOURCES

      2.1    SOLID WASTE

                       The following solid and semi-solid waste from the
      following sources (resulting from investigative and remedial activities) will
      be disposed of at the landfill site:

      1.     Solid and semi-solid waste from the S-Area Remedial Programs,

      2.     S-Area Survey wastes to be generated in the future and stored within
            the Area of Concern (AOC) at the Niagara Plant as shown on Figure 1,

      3.     Any waste related to the remediation activities on the eastern portion
            of the Drinking Water Treatment Plant (DWTP), and

      4.     Any waste generated from rehabilitation work at the DWTP which
            cannot be disposed at a sanitary landfill.

                       All solid and semi-solid waste managed by this section
      will be generated within the AOC as shown in Figure 1 and will remain
      within the AOC, until placement in the landfill.  Because the AOC
      encompasses the area impacted by the migration of chemical residue from the
      S-Area Landfill, activities under this plan relating to solid waste placement
      may be considered "replacement" of material historically deposited at the
      landfill.  All solid and semi-solid waste will be placed within the boundaries
      of the historic S-Area disposal area.

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1.0    INTRODUCTION

                       This document describes the plan of Occidental Chemical
      Corporation (OCC) to manage waste materials generated during the S-Area
      Remedial Program (all investigation and remedial programs required under
      the S-Area Settlement Agreement, including court-approved modifications
      such as the RRT program) including remedial and rehabilitation work at the
      DWTP. These plans includes the handling, treatment and placement of solid,
      semi-solid, aqueous phase liquids (APL), and non-aqueous phase liquids
      (NAPL) waste materials.

                       At the present time, either of two alternative remedial
      plans will be implemented at the City of Niagara Falls Drinking Water
      Treatment Plant (DWTP). One remedial plan will be essentially as described
      in the S-Area Settlement Agreement (Plan B) and the alternative plan will
      involve the construction of a new DWTP at a different location and closure of
      the existing plant (Plan A).  In order to make this waste management plan as
      complete as possible, both plans are considered throughout the remainder of
      this  report. Whenever wastes generated by the S-Area Remedial Program
      (solid, semi-solid, APL or NAPL) are referenced to in this document,  these
      wastes are intended to include wastes from both the S-Area and the selected
      remedial plan for the DWTP.

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                        LIST OF TABLES
                                                    Following
                                                      Page
TABLE 1      APL VOLUME ESTIMATES                        5

TABLE 2      NAPL GENERATION RATES                       6

TABLE 3      NAPL VOLUME FLOW RATES                      6

TABLE 4A    SOLID WASTE VOLUMES AND WASTE
            STAGING PLAN (PLAN B - DWTP IN PLACE)          22

TABLE 4B    SOLID WASTE VOLUMES AND WASTE
            STAGING PLAN (PLAN OPTION B - RELOCATE DWTP)  22

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                        LIST OF PLANS
PLAN 1   CELL CONSTRUCTION
                       AREA NO. 1
                      LIST OF APPENDICES
APPENDIX A

APPENDIX B

APPENDIX C

APPENDIX D

APPENDIX E

APPENDIX F
SAFETY OPERATING PROCEDURE S#6

ON-SITE TRAFFIC STANDARD OPERATION PROCEDURES

SOIL TESTING PROCEDURES QA/QC PLAN

LEVELS OF WORKER PROTECTION

SAFETY OPERATING PROCEDURE S#10

GROUTING PROCEDURE FOR WELL CLOSURE
                    LIST OF ATTACHMENTS
ATTACHMENT A   REMEDIAL WASTE TREATMENT MILESTONE
                SCHEDULE

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                        T T!?r OF FIGURES
CHART 1     BASIC WASTE MANAGEMENT STEPS
            - SOLID/SEMI SOLIDS

CHART 2     BASIC WASTE MANAGEMENT STEPS
            -LIQUIDS
                                                     Following
                                                       Page
FIGURE 1     AREA OF CONCENTRATION

FIGURE 2A   UMTT OF PLACEMENT AREA - PLAN B

FIGURE 2B   LIMIT OF PLACEMENT AREA - PLAN A

FIGURE 3A   PLACEMENT AREA O1 - 5'LIFT - PLAN B

FIGURE 3B   PLACEMENT AREA 0' - 5' LIFT - PLAN A

FIGURE 4A   PLACEMENT AREA 5.5' -10.5' LIFT - PLAN B

FIGURE 4B   PLACEMENT AREA 5.5' - 10.5' LIFT - PLAN A

FIGURE 5A   PLACEMENT AREA 11' -16' LIFT - PLAN B

FIGURE 5B   PLACEMENT AREA 11'-13'LIFT-PLAN A

FIGURE 6A   PLACEMENT AREA 16.5' - 21.5' LEFT - PLAN B

FIGURE 7A   PLACEMENT AREA 22' - 26' LIFT - PLAN B

FIGURE 8A   FINAL GRADING PLAN - PLAN B

FIGURE 8B   FINAL GRADING PLAN - PLAN A
FIGURE 9
EXISTING TOPOGRAPHICAL FEATURES
 2

22

22

23

23

23

23

23

23

23

23

23

23

24

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                        TABLE OF
1.0   INTRODUCTION	1

2.0   WASTE SOURCES	2
     2.1   SOLID WASTE	2
     2.2   LIQUID WASTE	3

3.0   WASTE VOLUMES	4
     3.1   SOLID WASTE VOLUME	4
     3.2   LIQUID WASTE VOLUME	5
     3.2.1  APL Volume	5
     3.2.2  NAPL Volume	6

4.0   WASTE MATERIAL STORAGE & HANDLING	7
     4.1   DRUMMED SOLID WASTES	7
     4.2   BULK SOLID WASTES	9
     43   SEMI-SOLID WASTES	9
     4.4   LIQUID WASTE	10
     4.4.1  Tunnel Water/Construction Water	12
     4.4.2  Physical Characteristics of APL/NAPL	13
     4.4.3  Chemical Composition	~.	14
     4.4.4  Piping of APL/NAPL to Storage Facility	14
     4.4.5  APL/NAPL Separation	14
     4.4.6  APL/NAPL Storage and Treatment	17
     4.4.7  Containment Dike	21

50   SITE PLACEMENT	22
     5.1   SOLID WASTE DISPOSAL AREA	22
     5.2   LANDFILL SITE PREPARATION	:	24
     5.3   PLACEMENT IN WASTE WELLS	26
     5.4   OTHER CONSIDERATIONS	29
     5.5   LAGOON DECOMMISSIONING	30
     5.6   WASTE CAPPING	30
     5.6.1  Interim Capping	30
     5.6.2  Final Capping	32
     5.7   SUPERVISION; DOCUMENTATION AND
          MONITORING REQUIREMENTS	33
     5.8   SECURITY FENCE AND ACCESS REQUIREMENTS	36
     5.9   SURFACE WATER HANDLING	38
     5.10  HEALTH AND SAFETY PLAN	41

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         APPENDIX IV




REMEDIAL WASTE MANAGEMENT PLAN

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                           VOLUME II
              IN THE UNITED STATES DISTRICT COURT
              FOR THE WESTERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
THE STATE OF NEW YORK,
                   Plaintiffs,
              v.
OCCIDENTAL CHEMICAL CORPORATION and
THE CITY OF NIAGARA FALLS, NEW YORK,

                   Defendants.
                Civil Action No.
                79-988 (JTC)

                (S-Area Landfill)
                         STIPULATION ON
          REQUISITE REMEDIAL TECHNOLOGY (RRT) PROGRAM
         APPENDIX IV

         APPENDIX V

         APPENDIX VI
REMEDIAL WASTE MANAGEMENT PLAN

OCC S-AREA PROJECT SCHEDULE

INSURANCE CERTIFICATE FORM

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                            COST REDUCTION SUMMARY
                        New WTP Transmission Pipelines
                             (August  1988  Dollars)
1.  Porter Road Location;

        48-inch Raw Hater Pipeline    14,000 l.f.
        48-inch High Service Pipelines  5000 l.f.
        20-inch Hich Service Pipeline   2000 l.f.
      $4,300,000
       1,500,000
         400.000

Sub-Total:  $6,200,000
              Engineering, Legal, Admin. (25V)
              Contingency (10%)
       1,600,000
         600.000
                                                  Total:
            $8,400,000
2.  Adjacent Buffalo Avenue Location

        Raw Water Pipeline  500 l.f.
        High Service Pipelines  1500 l.f.
      $  150,000
         470.000

Sub-Total:  $  620,000
              Engineering, Legal, Admin. (25%)
              Contingency (10%)
         210.000
                                                  Total:
            $  830,000

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    JVVUODUVt
       PIRNIE
       April 19. 1990
                      MALCOLM PIRNIE. INC.
ENVIRONMENTAL ENGINEERS. SCIENTISTS A PLANNERS
       Mr. John R. Hestendorf
       Director of Hater Facilities
       City of Niagara Falls Hater Treatment Plant
       5317 Buffalo Avenue - P.O. Box 69
       Niagara Falls, New York 14302-0069


       Re:  Costs for New Hater Treatment Plant Transmission Pipelines

       Dear Mr. Hestendorf:

       As you know,  Malcolm Pirnie assisted the City's independent consultant in
       August  1988  by preparing a  preliminary cost estimate  for a  new  water
       treatment plant located on Porter Road.  This cost estimate was conceptual
       in nature, as no detailed facility planning had been authorized,  and the
       actual  site  had not been selected.   The August 1988 estimate included
       $8.400,000 in  new  transmission pipelines,  in addition  to approximately
       $310,000 for re-routing existing pipelines  along Buffalo Avenue.

       In  accordance with your  request, we  have attached  a worksheet  which
       documents the  reduction  in  transmission pipeline costs  associated with
       siting a new treatment plant adjacent to the  existing facilities instead
       of  at Porter  Road.   Essentially,  the amended  conceptual estimate  of
       $830,000 (which was provided to the City in December 1988) assumed that
       only about 2000 linear feet of 48-inch diameter pipeline would be required
       for the adjacent location,  instead  of the  four miles of  pipe needed to
       service the Porter  Road site.  As before, the transmission pipeline costs
       do not include re-routing the existing Buffalo Avenue pipelines.

       Please note that all  of the above costs remain in August 1988 dollars, as
       requested, and  include  a "nominal" 25  percent surcharge  for hazardous
       construction activities.   Please feel  free  to contact us if you have any
       questions about this estimate.

       Very truly yours,

       MALCOLM P4RNIE, INC.
       David B.  Schendel,  P.E.
       Senior Project Engineer

       enc.

     .  c:    E. Markus, Ernst Young
            P. Herthman, Malcolm Pirnie
          .  File:  0337-24-1, CE-1

       0337-24-1
S. 3515 ABBOTT ROAD        P.O. BOX 1938       BUFFALO, NY 14219       71&S28-1300        FAX71&828O431

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Demolition of the Existing Plant-
      Mid -1988 Bid Estimate:
      Mid -1994 Bid Estimate-
Water Storage Facilities:
      Mid -1988 Bid Estimate:
      Mid - 1994 Bid Estimate:
Relocation of Offices:
      Mid -1988 Bid Estimate:
      Mid -1994 Bid Estimate:
Transmission Mains (Buffalo Ave.):
      Mid • 1988 Bid Estimate:
      Mid -1994 Bid Estimate:
Total Construction Costs:
$1,800,000
$2.412.000

$3,800,000
$5.092.000

  $900,000
$1.206.000

  $310,000
  $415JQQQ
                                                      $6,000,000
                                                      52,009,000
                                                       2,412,000
                                                       5,092,000
                                                       1^06,000
                                                        415.000
                                                     $67,134,000

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                    CITY OF NIAGARA FALLS
                 WATER TREATMENT FACILITIES
              CONSTRUCTION COST UPDATE - 4/16/90
Raw Water Intake:
     Mid - 1988 Bid Estimate by Malcolm Pirnie, Inc.:   $16£00,000
Treatment/Pumping:
     Mid • 1988 Bid Estimate by MPL                  $30,500,000
New Transmission Lines - Buffalo Ave. Plant Site:
     Mid -1988 Bid Estimate by MPL                    $830,000
Total Costs for the Intake, Treatment/Pumping and Transmission Lines in
Mid -1988:                                         $48,230,000
Using a 5% annual inflation factor for construction costs:
     Mid -1988 Bid Estimate:                        $48,230,000
     Mid -1989 Bid Estimate:                        $50,642jOOO
     Mid -1990 Bid Estimate:                        $53,174000
     1990-1 Design & Related Expenses:                $6.000.000
     Remaining Mid -1990 Bid Estimate:              $47,174,000
     Mid -1991 Bid Estimate:                        $49,532,000
     Mid -1992 Bid Estimate:                        $52.009.000

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Ernst & Young
                                                              ":" Seventh Avenue
                                                              Kr.v York. New Yofk 10019
 ,  ., ,„  ..„««                                                 Tesonone: (212) 830-6000
 Apnl 17,1990
 Mr. John R. Westendorf
 Director of Water Facilities
 City of Niagara Falls Water Treatment Plant
 Buffalo Avenue & 53rd Street
 Niagara Falls, New York 14302

 Dear Mr. Westendorf:

 This letter is to confirm our recent telephone conversation relative to the updating
 of previous project cost estimates for the proposed new water treatment plant.
 The October 1988 report of Arthur Young & Company and Hazen & Sawyer, Inc.
 evaluated alternative water supply options for the City using preliminary
 construction cost estimates prepared by Malcolm Pirnie, Inc.  Given the most
 recent City schedule for implementing the new plant and the time which has
 elapsed since the date of our report, you requested that the October 1988 cost
 estimates be updated.

 The enclosed calculations have been prepared to update the previous construction
 costs to the expected project timetable of the City.  As we understand, the design
 phase will occur from 1990 - 91, with construction to begin in mid-1992.  The
 updated costs reflect the original estimates of Malcolm Pirnie, Inc. for each item
 of  the proposed  work,  adjusted for an  assumed  5% annual increase in
 construction costs due to inflation.  In addition, the site for the new water plant
 used  in our October 1988 report was on Porter Road, requiring substantial new
 transmission piping.  The current proposed location for the new water plant is
 adjacent to the current plant along  Buffalo Avenue, resulting in a significant
 savings in transmission main cost.

 We are pleased to have the opportunity to assist the City in its efforts to implement
 the new water treatment facilities.  Should you have any questions or comments,
 please do not hesitate to contact the undersigned at (212>773-6365.

 Very  truly yours,

 ERNST & YOUNG


        •^
 By
     Edward J jMarkus

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                              - 2 -
 costs associated with any real property acquired by  the City to
 proceed with  the  new CWTP  project  and ancillary  facilities.
 Investigation  and remedial costs for any City wastes identified
 on the  site  acquired by the  City shall  not  be  included  in
 project costs.    Any  design  modifications  to  the  new  CWTP
 required  by any state  or federal  agency  shall be  included  in
 the  project cost.  Any EQBA  reimbursement  received by  the  City
 for   investigation   or   remediation  of   wastes  other   than
 identified  City  wastes,  if   any,   on  this  property  shall  be
 subtracted  from  the project cost to offset  cost overruns.
6850o:KSW:07/19/90
13493-6:D.C.

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                          ATTACHK^HT D
                          Project Cost
                 New City Water Treatment Plant
                            June  1990
         The  project  cost  for  the  new City  Water  Treatment
 Plant   (CWTP)   has   been   estimated   based   on   preliminary
 engineering  and water supply  options studies performed for  the
 City by Malcolm Pirnie Engineers/  Inc./ and  by Ernst &  Young.
 The  attached letters  dated  April 17,  1990  (Ernst & Young)  and
 April  19,  1990  (Malcolm  Pirnie)  predict  that the  new  CWTP,
 assuming  a mid-1992 construction start/ will cost $67,134/000,
 which  includes  a  25%  allowance  for  engineering,   legal  and
 administrative  costs and a  10% contingency.  Included in these
 costs  are  provisions for relocating  the  Meter Shop and Outside
 Maintenance  Division  facilities  and offices.   In  addition  to
 the above  construction costs,  the cost  of  site acquisition  and
 associated  investigations  and  remedial actions  (if any) must be
 added to the project costs.  Current  estimates are as  follows:
         Site acquisition, investigations
         and remedial  costs                       $    700,000
         Construction  costs  from 04/17/90
         Ernst & Young letter                      67.100.000
         Project Cost                             $67/800,000

         Investigation  and   remedial  costs  included  in project
costs  shall be  limited  to those  investigation  and remedial
6850o:KSW:07/19/90
13493-6:0.C.

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         ATTACHMENT D



Hew CWTP Project Cost Estimate

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                  A swale for controlling surface water runoff will be
constructed to run parallel to the west side of the access road and will
discharge into the existing 60-inch flood relief sewer south of the tile
collection system located to the south of the pump station. On the east side of
the parking lot, a swale will be located over the existing 24-inch wash water
sewer and wifl discharge to the 24-inch wash water sewer south of tile tile
collection system.
                                16

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                                   DRINKING
                              WATER TREATMENT
                                  T. CATOM MM TO K UU««TCJ
                                         24k
                                       or PUJG.
                                    CA1W IA9N TO BE UMO.ITIU TO
                                    iTM«i«ir *ok nooo
   GROUND ELCVA1HN  1 UMTT OF CAP TO UM> W TO

ACEWAH* MMOrr

              4. ncroiMCA me HAU.
POOR
   ORIGINAL
                               figure  5

    PROPOSED  CAPPING AND GRADING PLAN
            DOT? CLOSURE REMEDIAL PLAN
           Occidental Chemical Corporation

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 3.6   FINAL GRADING AND CAPPING PLAN

                  Prior to final grading it is estimated that additional
 materials will be required to bring the demolition areas up to grade.  The
 storage capacity for demolition debris within the existing reservoirs and
 sedimentation basins is approximately 47,000 cubic yards.  This has been
 calculated from the elevation of the existing ground surface to the basement
 elevation of the respective structures.  The volume of debris created by
 demolition activities is approximately 37,000 cubic yards. A shortfall of
 10X300 cubic yards occurs, necessitating additional fill materials to bring the
 demolition areas up to final grade prior to capping.  Subject to EPA/State
 approval delisted OCC Solid Waste Incinerator ash  approved for use pursuant
 to the Waste Management Plan, Appendix IV will be used as fill or, if
 unavailable, another suitable dean fill will be imported.

                  It is proposed that the final grading plan for the DWTP
property will consist of an asphalt parking lot surrounded by grass covered
areas. Figure 5 presents the proposed capping and grading plan.

                  Access to the parking lot will be from Buffalo Avenue.
The access road and the parking lot will consist of a light traffic asphalt cap.

                  The remainder of the site will be sealed with a clay cap
and covered with grass.  The clay cap will extend from the edge of the Barrier
Wall to approximately 10 feet east of Filtration Plant A and from Buffalo
Avenue to the existing fenceline on the southern property boundary.
                                15

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collected. If the second collection of NAPL does not provide a substantial
amount of NAPL, OCC will secure the entire intake tunnel and the
shoreshaft as shown on Figure 4. If the second collection produces a
substantial amount of NAPL, the tunnel will be secured south of a location to
be determined by OCC and the governmental parties based on all the
available data. OCC will submit a plan for monitoring and/or NAPL removal
for the portion of the runnel left open.

                 Securement of the 48-inch intake Line will be performed
in accordance with Table 2. Both inlet crib structures will be removed.
                              14

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      600  —
      580  —
      560  —
      540 ~
      520 —
      500 —
 CRA
                  INSTALL CONCRETE PLUG
                                                      CEMENT-BENTONITE GROUT
                                                                                          .^INSTALL
                                                                                        if ce
                                                           HIGH WATER
                                           INSTALL CONCRETE PLUG
                                            CAPPED EAST CHANNEL
                                            INTAKE SHAFT
                    EMERALD
                    CHANNEL
                    SHAFT
                                                          1953 TUNNEL
                     1937 TUNNEL
                                 CONCRETE
                                 PLUG
                              I
                            52+00
                                figure  4

SECUREMENT OF INTAKE STRUCTURE
     DWTP CLOSURE REMEDIAL PLAN
     Occidental Chemical Corporation
1769-29/1f/89-76-0

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3.5   SECUREMENT OF RAW WATER INTAKE STRUCTURES

                  The existing raw water intake structures requiring
securement are:

•  Shoreshaft, East Branch Intake Tunnel and Shaft Intake, Emerald Channel
   Intake Tunnel and Shaft Intake;

•  East Channel Intake Line (48"0) and Intake Crib.

                  Securement of the Intake Tunnel network, including the
shaft intakes and shoreshaft will be performed by grouting the entire system
with cement/bentonite grout.  To the extent that the tunnel underdrain is
connected to the runnel it will also be grouted.  Figure 4 presents the tunnel
closure concept

                  Within 90 days after the start of construction of the new
DWTP pursuant to Plan A, 1,000 feet of the northern portion of the Intake
Tunnel commencing at the shoreshaft will be inspected with a video camera
equipped with a TV monitor on the surface.  Copies of the video tapes
produced will be provided to the governmental parties. If collectable
quantities of NAPL are present in the Tunnel, the NAPL will be removed. If
substantial quantities of NAPL are not collected, OCC will secure the entire
intake runnel and the shoreshaft as shown on Figure 4. If substantial
quantities of NAPL are collected, OCC shall schedule a followup inspection
for 90 days prior to the start of grouting operations of the runnel. If the
followup inspection finds collectable quantities of NAPL, that NAPL will be

                               13

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                                 TABLE 2

                    SUMMARY OF AFFECTED UTILITIES
 Utility
6" 0 Sanitary
42V36" high service
discharge

24" 0 Sanitary
gas
Abandoned Electrical
Service
12" Forcemain


30" Wastewater line
to sludge facility


48" Raw Water Line


60" Wastewater Line


24" Washwater Sewer
Preliminary Activity


    abandoned


    abandoned


    abandoned


    closed



 has been abandoned


    abandoned



    abandoned


    abandoned


    severed


    severed
      Plug Detail
plug per S-Area Settlement
Agreement

plug per S-Area Settlement
Agreement

plug per S-Area Settlement
Agreement

plug per S-Area Settlement
Agreement
plug per S-Area Settlement
Agreement

plug per S-Area Settlement
Agreement
plug per S-Area Settlement
Agreement

plug River Side per S-Area
Settlement Agreement

plug River Side per S-Area
Settlement Agreement

plug River Side per S-Area
Settlement Agreement

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3.4   UTILITY ABANDONMENT. REROUTING AND REPLACEMENT

                 Table 2 presents a listing of all known utilities affected by
the closure of the DWTP. Except for those utilities with the bedding tied into
the tile system (see Section 33), both ends and bedding of the severed utility
will be plugged.
                              12

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                 No groundwater flow, as monitored by the gradient
monitoring, from within the existing AFL Plume within the boundaries of
the western portion of the DWTP will be allowed to flow east onto property
owned by the Qty.

                 Hie DWTP overburden tile collection system (i.e. wet well
and manholes) will be inspected weekly to confirm system operation.
                              II

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                  It is to be noted that the operation of the proposed DWTP
overburden tile collection system may impact the achievement of an inward
gradient across the south-eastern leg of the S-Area Barrier Wall.  Preliminary
zone of influence estimates indicate an inward gradient to contain API and
NAPL within the S-Area Barrier Wall will be achieved. This is due to the fact
that the S-Area Collection System will be operated to maintain the lowest
achievable water level within the S-Area Barrier Wall. Conversely, the
DWTP overburden tiie collection system will lower the water table only low
enough to create the zone of influence necessary to intercept the API plume
within the boundaries of the western portion of the DWTP as shown on
Figured

MONITORING

                  To evaluate the long term effectiveness and-operation of
the DWTP overburden tile collection system, hydraulic monitoring will be
performed on a regular basis. The frequency of monitoring shall be consistent
with the programs established to address the S-Area RRT Systems.

                  To determine that an inward gradient toward the DWTP
overburden tile collection system across the existing APL plume within the
boundaries of the western portion of the DWTP is achieved, additional
monitoring wells shall be installed to evaluate groundwater gradients.  To the
extent possible, existing wells will be utilized.  Efforts will be made during
closure activities to prevent existing monitoring well destruction.
                               10

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                  Installation of the overburden tile collection system may
 encounter subsurface utilities and appurtenances. Severance of the respective
 utilities encountered shall be performed when necessary to permit placement
 of the perforated piping.  The utilities/bedding severed will have an
 appropriate section of piping removed and both ends of the pipe will be
 plugged and the respective River side bedding will be plugged. The bedding
 on the north side will be tied into the tile system.

                  Along the alignment of the overburden tile collection
 system, OCC will drill a line of borings at 50-foot centers down to the clay /till
 interface  Data from the borings will be used to determine if any NAPL is
 present along the alignment and to  assist in the design and final location of
 the drain tile.  If NAPL is encountered, then OCC will address the NAPL
 using appropriate technologies.

                  Details of typical utility severance and plugging are
 presented within Section 3.4.

                  System operation shall be adjustable to permit a greater or
 smaller zone of influence by variation of the liquid level within the wet well.
 Hydraulic monitoring, as discussed  below, will be utilized to evaluate
 whether the desired zone of influence is achieved within the DWTP areas.

                  Groundwater collected within the wet well structure shall
be pumped via HOPE forcemain and its companion containment/leak
detection piping  to the proposed S-Area  APL Storage Facility.

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     570-
     565-1
     560H
     555-1
     550-f
     545-1
    540-
    535
 CRA
                                 FILL
 AVERAGE 1989
"GROUNDWATER
 WATER LEVEL
                                                         EXISTING GROUND SURFACE

                                                                         /-PROPOSED MANHOL£
                               100
                                     N.T.S.
1789-29/11/89-76-0
                                                           figure 3

                                                     WEST - EAST
                             COLLECTION SYSTEM CROSS SECTION
                                  DWTP  CLOSURE REMEDIAL PLAN
                                  Occidental Chemical Corporation

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                                        DRINKING
                               WATER TREATMENT PLANT
                                    CONCEFTUAL FU1URE
                                    PROPERTY BOUNDARY
                                    FOR WESTERN PORTION
                                    OF OWTP
FORCEUAM
TO APL
TREATMENT
                   PROMUSLD
                   OWTP 0>£RBUROEN
                   SYSTEM TO CROSS
                   THE 48*«. 60V * 24V LMES
                               POOR QUALITY
                                  ORIGINAL
                        DWTP OVERBURDEN TILE COLLECTION SYSTEM
                                   OWTP CLOSURE REMEDIAL PLAN
                                  Occidental Chemical Corporation

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33   APL CONTAINMENT AND COLLECTION

                 Figure 2 presents the areas of identified APL presence in
the overburden groundwater at the DWTP as determined by the S-Area
Remedial Program survey described in the document entitled "City of
Niagara Falls Drinking Water Treatment Plant - • Assessment of Overburden
Chemical Migration to the Water Treatment Plant".

                 This APL will be contained and collected by a DWTP
overburden tfle collection system as shown on Figure 2 and as described
below:

i)     wet well located south of the existing pump station building;

ii)    perforated High Density Polyethylene Pipe (HOPE) collection tile
      installation/ extending 40Q± feet east of the wet well, terminating at a
      manhole;

iii)   HOPE forcexnain within a HOPE containment pipe complete with leak
      detection manholes; and

iv)   a submersible type effluent pump (size and type to be determined) with
      variable level controls installed within the wet well. The level
      controls shall be adjustable  to permit flexibility in the system operation.
      Figure 3 presents the cross-sectional view of the West/East collection
      system alignment.
                               8

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     •  water treatment chemicals, i.e. chlorine, fluoride, and associated
        handling equipment;
     -  solvents/oils, paints, ie. materials in bulk quantities within
        shops/service areas;
     •  laboratory components, Le. chemicals/ acids, solvents, and associated
        equipment, storage areas; and
     -  fuel and storage tank removal and associated distribution piping.

iii)  Identification, quantification, cleaning (if required) and removal of
     salvageable process equipment, appurtenances, furniture, office
     equipment, valuable metals, electrical generator and water tower;

iv)  Identification and closure/shutoff of incoming/outgoing utilities
     including:
     •  electrical, subsurface and overhead;
     •  natural gas;
     •  telephone; and
     •  watermain closure at plant boundary;
     .  sanitary and storm sewers; and
     •  wastewater drain and forcemain to sludge facility.

v)   Identification of subsurface utilities /services proposed for severance
     and/or plugging.  Details of these are presented in Sections 3.4 and 3.5.

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                                TABLE 1

                               PROPOSED
             BUILDING/STRUCTURE DEMOLITION SUMMARY
Structures/BuUdittgs Proposed for Demolition Program:
                    Guard House
                    Filtration Plant *B' and Sedimentation Basins
                    Sewer Department (Building D) and Underlying Reservoir
                    Filtered Water Reservoir and Adjacent Control Chamber
                    Former Carpenter Shop
                    Filtration Plant 'A' and Sedimentation Basins
                    Pump Station and Electrical Station
                    Shore Shaft Enclosure
                    Emergency Generator Station
                    Underground Fuel Storage Tanks
                    Water Tower
Structures/Buildings Remaining:

                 •  Former Fire Hall

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32   BUILDING DEMOLITION

                 Table 1 presents a summary of the buildings and
structures proposed for demolition.

DEMOLITION APPROACH

                 Demolition of the DWTP facilities will be implemented by
the City and includes demolishing existing structures in place and utilizing
existing reservoirs and sedimentation basins as receptacles for debris. Filter
media will be disposed at the historic S-Area Landfill.

DEMOLITION CONSIDERATIONS

                 The following is  a listing of the major components
requiring consideration when the decommissioning and demolition of a
facility of this size is performed:

i)   Accurate listing of buildings /facilities to be demolished and a listing of
    structures/utilities equipment to be saved.

ii)  Identification, quantification and prior removal (regardless of disposal
    option selected) of potentially hazardous components and associated
    handling/storage systems, including but not limited to the following:
    -  asbestos materials, i.e. insulation;
    •  PCBs, i.e. transformer fluids and transformers;

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3.1   NAPL CONTAINMENT AND COLLECTION

                 It is intended that prior to the implementation of this
Plan at the DWTP, the S-Area RRT Program and Systems will address all
NAPL present on the western portion of the DWTP. The S-Area RRT
Program will detail the plan to address this NAPL presence. This closure
remedial plan assumes that the overburden NAPL plume will be contained
and collected by the S-Area RRT Systems, as described below:

i)    Containment shall be performed by slurry wall construction through the
     overburden materials keying one foot into confining layer materials.
     Pending the final NAPL plume definition, the S-Area Overburden
     Barrier Wall alignment may be modified to address NAPL in the
     western portion of the DWTP.

ii)   Collection of NAPL shall be performed by the S-Area tile collection
     system which will be located within the Barrier Wall. Pending the final
     NAPL plume definition, the location of this system may also be
     modified to address NAPL in the western portion of the DWTP.

                 If NAPL is not addressed by the S-Area RRT Program, this
NAPL will be addressed using appropriate technologies.

                 Any underground utilities from the DWTP property that
cross the alignment of the Barrier Wall shall be addressed by the S-Area RRT
Program.

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3.0   PLAN ACTIVITIES

                     The major Flan activities identified are listed as follows
     and discussed individually in the following sections.

     •  NAPL CONTAINMENT AND COLLECTION

     •  BUILDING DEMOLITION

     •  APL CONTAINMENT AND COLLECTION

     •  UTUJTY ABANDONMENT, REROUTING AND REPLACEMENT

     •  SECUREMENT OF RAW WATER INTAKE STRUCTURES

     •  FINAL CAPPING AND GRADING

                     To achieve the proposed objectives identified in
     Section 2.0, the remedial closure plan concepts have been developed giving
     due consideration to:

   .  i)   hydrogeological and environmental conditions existing at the DWTP;
     ii)   structural conditions at the DWTP;
     iii)  proposed S-Area RRT Systems; and
     iv)  compatible construction techniques and methods.

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2.0    OBTECnVES

                       The objectives of this Plan are as follows:

      •  demolish existing structures in an environmentally acceptable manner;

      •  contain, collect and treat Aqueous Phase Liquids (APL) in areas not
         addressed by the S-Area RRT Program;

      •  contain, collect and treat Non-Aqueous Phase Liquid (NAPL) in areas not
         addressed by the S-Area RRT Program.

      •  abandon and plug existing utilities and bedding (underground watermain,
         sewers, etc.);

      •  secure raw water intakes;

      •  cap the demolished structures and surrounding areas with impervious
         surfaces that will minimize groundwater infiltration; and

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                                              CONCEPTUAL
                                              FUTURE
                                              PROPERTY BOUNDARY FOR
                                              WESTERN PORTION OF DWTP
                                            /-NSLUOCC
                                            (JlHOONCR
                                          DRINKING
                                    WATER  TREATMENT PLANT
                                                          figure I
                                                       PLAN VIEW
                            DRINKING WATER .TREATMENT PLANT
                                   DWTP CLOSURE REMEDIAL PLAN
                                 Occidental Chemical Corporation
1769-27/11/89-76-0

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ii)  CTTY OF NIAGARA FALLS DRINKING WATER TREATMENT PLANT
    •  Assessment of Groundwater Table Contours and Geologic Conditions
       S-Area Remedial Program    .                      June 1988

iii)  CITY OF NIAGARA FALLS DRINKING WATER TREATMENT PLANT
    PUMP STATION
    •  Hydrogeologic and Environmental Conditions
    •  Collection System Design Consideration               June 1988

iv)  CITY OF NIAGARA FALLS DRINKING WATER TREATMENT PLANT
    •  Assessment of Overburden Chemical Migration to the Water
       Treatment  Plant
       S-Area Remedial Program                          June 1988

v)  REQUISITE REMEDIAL TECHNOLOGY STUDY OF CHEMICALS IN
    THE OVERBURDEN AND BEDROCK S-AREA LANDFILL
    S-Area Remedial Program                          October 1989


                Figure 1 presents the DWTP existing facilities and adjacent
S-Area Landfill.  A  conceptual property boundary to define the boundary of
the DWTP property after closure is indicated on Figure 1.

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LO    INTRODUCTION

                      Occidental Chemical Corporation (OCC) has prepared the
      following Plan for the remediation and closure of the western portion of the
      City of Niagara Falls Drinking Water Treatment Plant (DWTP) property in
      the event that operations of the Plant at this site are discontinued. OCC will
      take title to the western portion of the DWTP and the City will retain title to
      the eastern portion of the DWTP property and a strip immediately south of
      Buffalo  Avenue.

                      This Plan incorporates engineering and construction
      practices accepted for use in containment projects and is applicable to the
      materials and hydrogeologic conditions at the S-Area/DWTP.

                      The geologic, hydrogeologic, environmental and
      structural conditions of the DWTP have been evaluated and are presented
      within the following S-Area/DWTP documents:

     i)    INFORMATION SUMMARY REPORT
          • S-Area Remedial Program         -                     June 1988
          Volume 1    Text
          Volume n   Drawings
          Appendix 1   Overburden Stratigraphic and Instrumentation Logs
          Appendix 2   Bedrock Stratigraphic  and Instrumentation Logs
          Appendix 3   Historical Stratigraphic and Instrumentation Logs and
                      Hydraulic Monitoring
          Appendix 4   Well Development and  Sampling Summary
          Appendix 5   Soils Physical Testing  Results
          Appendix 6   Analytical Results

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                         LIST OF TART PQ
                                                      Following
                                                       Page
TABLE 1      PROPOSED BUILDING/STRUCTURE
            DEMOLITION SUMMARY                         6

TABLE 2      SUMMARY OF AFFECTED UTILITIES                12

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                       LIST OF FIGURES
                                                   Following
                                                    Page
FIGURE 1    PLAN VIEW DRINKING WATER
           TREATMENT PLANT                           2

FIGURE 2    DWTP OVERBURDEN TILE COLLECTION SYSTEM      8

FIGURE 3    WEST-EAST COLLECTION SYSTEM
           CROSS-SECTION                              8

FIGURE 4    SECUREMENT OF INTAKE STRUCTURE             13

FIGURE 5    PROPOSED CAPPING AND GRADING PLAN          15

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                      TABLE OF CONTENTS

                                                          Page

1.0   INTRODUCTION	I		1

2*U   ^J&SJCi^ 11V fcj n-nTiKi»»T«-tt--i--T—tr-ii	T—I—	r	'	1?

3.0   FLAN Ai:iiViiiES.......~.~	^.^,.^...^	~~~..~.........—.4
     3.1  NAPL CONTAINMENT AND COLLECTION	5
     3.2  BUILDING DEMOLITION	6
     33  APL CONTAINMENT AND COLLECTION		A
     3.4  UnLTTY ABANDONMENT, REROUTING

     35  SECUREMENT OF RAW WATER INTAKE STRUCTURES	13
     3.6  FINAL GRADING AND CAPPING PLAN		15

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       ATTACHMENT C



DWTP Closure/Remedial Plan

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I
ATTACHMENT B
ACTIVITY
CWTP TUNNEL REMEDIATION
PHMTRATTfiP MlPlKlft 	
HFQIftKI 1 IKJFR TFQT PI AW* 	
rnwni IPT i IKIFR TF^T PI AM 	
PRFPAPF rnwTRAPT nnniurwT^ 	
prpriur DIHQ A K1H AM/APR 	

HYHPOTFCT Rfi1* IKITAKF 1 IMF 	

ACCESS SHAFT INSTALLATION
FyPAVATinM 	
IKIQTAI 1 klFUT QUAFT. - 	
rOCl\ IT 1Q"X7 TIIKJKJFl 	
orunv/r i IKIFP FPDU 10^7 TIIKIKIFI 	





CWTP SITE REMEDIATION
REPLACE 10" AND 42" HIGH SERVICE LINES-
rUMr* SIAIIUN CULLLUIIUN STaltM- • • •
FILTRATION/RESERVOIR COLLECTION SYSTEM-
Wlr rtnlMt ItK CArrlNw 	
C*WIP LLLANINU AC IIV1 IILb 	

START DISTRIBUTION WATER MONITORING* •
DURATION(MONTHS)
2
_























4
^••i






















6
••















••






8
















•••






10
















^






12























14

••




















16
M
^m



















IB
IV
m§


















20
•
••




*









22
••
mmm



•








24













26













28













30





—




32
^mm


— •




34
M


—




36
••
—




38
mmm




40




42




44




46




48




50




52




54




56




58



60



* USING S-AREA TILE TEST PROTOCOL. IF APPROPRIATE
** SCHEDULE ASSUMES THE 1953 TUNNEL WILL NOT REQUIRE SLEEVING
PLAN B BAR SEQUENCING SCHEDULE
^. Occidental Chemical Corporation
CRA r

1769-1B/07/90-L-1 (S-04)

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         ATTACHMENT B



Plan B Bar Sequencing Schedule

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                         INSURANCE CERTIFICATE FORM
X
2
2
1

1
       HMV

                                                            NMMV
                                                                 «1.000,
             I 5.000,
             f 5,000,
£ JMTMflO
SLl
             MB.)
  MMBMITH
  •MMiuwurr
                                                                 11,000,
                                                               t 1. OOOOKASt-fiOl BtflOrO)
                              POOR QUALITY
                                 ORIGINAL

-------