&EPA
                         MAY  1986
         NIAGARA RIVER
           ACTION  PLAN
         LAKE ONTARIO
                        NIAGARA FALLS (NY)
                        SUB-AREA
                           NEW YORK
              MAQARA FALLS (ONT)
                                    TONAWANO
                                    NORTH
                                    TONAWANOA
                                    SUB-AREA
 CMIPPAWA SUB-AREA


ONTARIO
                                 BUFFALO-LACKAWAN HA
                                  SUB-AREA
               FOซT ERIE SUB-AREA
United States
Environmental Protection
Agency
                            REGION 2
                        26 Federal Plaza
                     New York, N.Y. 10278

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UNITED STATES  ENVIRONMENTAL PROTECTION AGENCY
          NIAGARA  RIVER ACTION PLAN
                  Prepared By
     U.S.  Environmental Protection Agency
      Region  2  Office,  26 Federal Plaza
            New York,  N.Y.  10278
                   May,  1986

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             U.S. ENVIRONMENTAL  PROTECTION  AGENCY
                  NIAGARA RIVER ACTION  PLAN
                          MAY,  1986
INTRODUCTION

The 37-mile Niagara River,  flowing  northward from Lake Erie
to Lake Ontario and forming  the  international boundary between
the U.S. and Canada,  is  a  major  source of water for industry,
for municipalities and for  power generation.  The quality of
its waters has a  significant impact on the quality of Lake
Ontario.  The Niagara  Frontier is a significant center of
population, industry  and tourism.  The Niagara area has
therefore long been a  focus  of major concern and commitment
for U.S. environmental agencies  at  both the state and federal
leveIs.

This commitment is reflected first  in the massive investment
made by all levels of  government in municipal wastewater
collection and treatment.   Under the Federal Clean Water Act,
passed in 1972, EPA has  provided over $550 million to build
these systems, and New York State and local governments have
contributed a like amount.   As a result,  all the U.S.
municipalities that discharge into  the Niagara River have
operating secondary treatment plants.  These include advanced
designs at Amherst, North Tonawanda and Niagara Falls to
account for heavy industrial flows.  The Niagara Falls plant
has recently  come back into full operation, thanks to special
EPA funding of $14 million,  and  is  removing an additional 350
Ib./day of priority pollutants  from the river.

Also under the Clean  Water Act,  EPA and the New York State
Department of Environmental Conservation (NYSDEC) have issued
discharge permits that limit the flow of pollutants from all
significant industrial and municipal point  sources.  The first
round of these permits concentrated on "conventional" pollutants
(oil and grease,  solids, BOD, etc.).  Over  recent years the
permits have  all  been revised in a second round to concentrate
more on the elimination  of chemical discharge, and are under
review once more  to see  what additional limits might still be
needed.  The  permit program is  backed up by an annual inspection
and enforcement schedule.  All  six municipalities (Buffalo,
Tonawanda, Amherst, North Tonawanda, Niagara County, City of
Niagara Falls) along  the Niagara have prepared and begun to
enforce industrial pretreatment  programs designed to reduce  the
discharge of  chemicals by industries directly into municipal  systems

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                             -2-
EPA has approved all  six  programs  over the past year.

As a result of these  point source  programs, most indicators
show a marked decline  in  environmental contamination in the
Niagara Frontier over  the past decade.  Where environmental
or public health standards exist or are proposed  they are
being met.

However, increased  sophistication  in analytical techniques,
coupled with problems  like those at Love Canal, has produced
awareness and concern  over low levels of toxic chemical
contamination.  To  respond to  these concerns  EPA and NYSDEC have
developed a multifaceted  program directed at toxics.  Point
sources are addressed  through  the  Clean Water Act programs
described above.  Nonpoint sources are addressed through the
Resource Conservation  and Recovery Act (RCRA), which regulates
existing hazardous  waste  operations, the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA,
or Superfund), which  covers the investigation and control of
abandoned sites, and  the  Clean Water Act, which regulates
nonpoint sources of wasterwater pollution.

Under RCRA, twenty  existing active hazardous waste operations
on the Niagara Frontier have been  brought under interim
regulation.  They are  now all  in various stages of the final
permit or closure process.

Under CERCLA, EPA and  NYSDEC are using a combination of federal,
state and industry  resources to investigate abandoned sites
and carry out cleanup  or  control measures.  All 61 sites of
concern listed in the  NRTC Report, have been or are being
investigated, and remedial work is underway at several.
EPA allocated $1.2  million to  NYSDEC for site investigations
in Fiscal 1985, which  was matched  by more than $1.5 million
in state funds.  In addition,  EPA  allocated about $600,000
per year in direct  contract funds  for site investigations in
Fiscal 83, 84 and 85.

At four major sites in Niagara Falls (Love Canal, Hyde Park,
S-Area and 102nd St.), EPA obligated over $20 million from
Superfund in Fiscal 1985; the  agency anticipates obligating
over $10 million in Fiscal 86  and  over $8 million in Fiscal 87
to these four sites alone, assuming reauthorization of CERCLA.
Groundwater hydrogeological work being carried out by EPA
contractors at Niagara sites is estimated at $16 million.
Private party cleanups underway under Federal Court Consent
Agreements are expected to cost over $50 million each at Hyde
Park and S-Area.

In summary, EPA, NYSDEC and local  governments have invested over
$1 billion to date  in  ongoing  environmental programs along the
Niagara Frontier.   These  programs  constitute a comprehensive,
integrated, ongoing commitment that still totals in the tens

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                             -3-
of millions of dollars  per  year.   Both EPA and NYSDEC are
committed to carry  on  these programs until the environment,
public health and international waterways are protected to
the full extent  required  by law and international agreement.

The Niagara River Toxics  Committee report, issued in November,
1984, identified gaps  in  our knowledge of the contamination in
the river, and the  effectiveness  of control programs.  EPA
identified several  new initiatives to fill in these gaps, in
cooperation with NYSDEC.   These initiatives were announced in
May of 1985.  The initiatives,  coupled with the ongoing
programs discussed  above,  constitute EPA's Action Plan for
the Niagara River.   In May of 1985, EPA also published specific
responses to the NRTC  Report's  24 recommendations.
(see Table I).
It is worthwhile  to  compare the Niagara Action Plan with  the
Five-Year strategy outlined in 1985 by the Great Lakes National
Program Office.   GLNPO presented a five-stage strategy for
dealing with  environmental  problems in the Great Lakes.   The
work done so  far  by  the NRTC in its report and recommendations,
coupled with  the  workplans  prepared by EPA Region 2 and NYSDEC
in response,  correspond to  the first three stages of  the
GLNPO strategy  -- that is,  the identification of problems,
the assessment/characterization of these problems, and the
proposal of solutions.

The next several  years will be devoted to the remaining two
stages — implementation of solutions and installing  a
monitoring/feedback  loop for measuring progress.
THE ACTION  PLAN

The Niagara River  Action Plan consists of the several major
programs  EPA has already ongoing under the Clean Water  Act,
the Resource Conservation and Recovery Act, and the Comprehensive
Environmental Response,  Compensation and Liability Act,
combined  with a  number of specific new initiatives to respond
to gaps identified in  the report of the Niagara River Toxics
Committee (NRTC).

EPA's plan  is complementary to and supportive of the Niagara
plan being  carried out by the New York State Department of
Environmental Conservation (NYSDEC).  NYSDEC is the lead
agency for  carrying out most environmental programs, both
state,and also federal (under delegations from EPA), on the
Niagara Frontier.   Similarly, some work initiatives involving
monitoring,  research,  and development require close cooperation
with our  counterpart Canadian agencies.

Table II  summarizes the Plan.

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                               — 4 —

ACTION PLAN GOALS

The EPA Action Plan  is  designed to:

       - ensure  continued  progress  in the identification, control,
         and reduction  of  point source discharges of toxics
         into the Niagara  River;

       - ensure  continued  identification, investigation and
         control of  nonpoint  discharges of toxics into the
         Niagara River,-

       - improve current and  future  understanding of the
         ambient levels of  toxics in the Niagara River and
         its environs,  and  to assess accurately the risks
         posed by those levels;

       - enhance communication and  cooperation among U.S.
         and Canadian agencies charged with protecting the
         environment along  the Niagara.

       - combine the four  preceding  objectives into a
         coordinated plan  for achieving specific reductions
         in toxic chemical  loadings  to the Niagara River
         within  specified  timetables in accordance with U.S.
         laws and standards for protecting public health and
         the environment and  with U.S. obligations under the
         Great Lakes Water  Quality  Agreement.
ACTION PLAN COMPONENTS

Point Source Control

The NRTC identified nine  major U.S.  point source dischargers,
both industrial and municipal. Their combined discharge of
EPA priority pollutants,  based on 1982 data, was estimated as
2488 Ib/day.  Based on  upgradings,  control programs and
shutdowns, that total has  already been reduced.  Table III
provides a narrative status  report on these nine major
facilities.

EPA's program for dealing with point sources of pollutants
consists of the following  components (many of which are joint
EPA/DEC responsibilities):

       0 SPDES Permits  -- NYSDEC and EPA have reviewed State
         Pollutant Discharge  Elimination System permits for
         all major industrial dischargers, and DEC has reissued
         them with stricter  controls on the discharge of
         toxics.  During  FY  86,  EPA  is working with DEC to
         carry out enhanced  compliance inspections at selected
         dischargers.

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                              -5-

       0  Industrial Pretreatment Program -- EPA  and  NYSDEC have
         reviewed  and EPA has approved local  industrial
         pretreatment programs for the 6 U.S.  municipal
         treatment plants on the Niagara-  Developed under
         the Clean Water Act, these plans  require  industries
         to reduce toxic discharges to municipal sewerage
         systems.  They are being enforced by  the  municipalities.
         Table IV is a schedule of implementation  and anticipated
         loading reductions.  EPA, working with  DEC, has
         developed a contractor-supported  technical  assistance
         program for the municipalities to improve enforcement.

       0  Stormwatar Runoff -- During  FY 86, SPA  is carrying out
         a project to investigate the contribution of toxics
         in stormwater runoff from industrial  facilities-  A
         contractor will identify potential sites, and EPA's
         Great Lakes National Program Office  (GLNPO) will con-
         duct a site-specific demonstration program.  The
         results of this project will define  the need for
         future control measures.
                 : ontroi
Toxic contamination  of  ground  and  surface  water from nonpoint
sources, such as former  and  existing  hazardous  waste landfills,
is recognized as a significant problem  in  the Niagara Frontier.
Both EPA and DEC have given  high priority  to the identifi-
cation and cleanup of inactive sites  through the federal and
state superfund programs,  and  to the  regulation of operating
hazardous waste facilities  through the  Resource Conservation
and Recovery Act and state  hazardous  waste disposal regula-
tions .

EPA's nonpoint  source control  program has  the following
components:

        3 Site Investigation — The NH.TC report identified 61
         sites  as potential  sources of  ground or surface
         water  contamination.  These sites  have been or are
         being  investigated  through a joint EPA - NYSDEC site
         assessment  program and, where  needed,  they are
         scheduled for  remedial work. Table V summarizes the
         status of these investigations and the timetables
         for completing them.

        0 Remedial Programs  --  Four major sites in Niagara --
         Love Canal, Hyde Park, 5-Area  and 102nd Street --
         are in some stage  of  the  investigative/remedial
         process.  Table VI summarizes  work on these sites.

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                               -6-
       0 Groundwater Hydrogeology  --  One  problem hampering the
         characterization and control of  nonpoint sources is
         the complex geology of  the Niagara  region.  To help
         address this problem, EPA is developing site-specific
         and areawide groundwater  models  through its CERCLA
         contractors and the U.S.  Geological Survey.

       0 Active Site Control --  There are twenty hazardous
         waste management facilities  in  the  Niagara  Frontier.
         EPA has requested  Part  B  permit  applications from
         all of them under  RCRA.   All are now in various
         stages of  the  permit or closure  process.  Table VII
         summarizes the status of  each of these facilities.
Monitoring Programs

The NRTC identified  the  need  for  specific long-term ambient
and point-source monitoring related  to  toxics in sediments,
biota and water. EPA agrees that  a  comprehensive monitoring
program is needed  for  the  purpose of establishing long-term
trends in toxic contamination,  assessing the effectiveness of
control programs,  and  identifying the need for modifications or
additions to  those programs.

EPA believes  that  ambient  monitoring is an important area for
international cooperation.  With  respect to point source
monitoring, however,  EPA and  NYDEC  have specific regulatory
responsibilities under the Clean  Water Act and will continue
to carry out  those responsibilities.  For all monitoring
programs, EPA believes it  is  essential for all four involved
environmental agencies in  the U.S.  and Canada (EPA, NYSDEC,
Environment Canada,  and  the Ontario Ministry of the Environment)
to agree on mutually acceptable sampling protocols, analytical
techniques and data  interpretation  methods.

EPA's monitoring program is part  of a binational effort being
explored with Canada which would  consist of the following:

       0 Long-Term Ambient Monitoring -- EPA is working with
         NYSDEC and  the  Canadian  agencies to try to develop
         mutually  acceptable  sampling and analytical protocols
         and  methods for interpreting data.  Some discussions
         have already taken place.   (Already scheduled is an
         evaluation  by the U.S. agencies of Canadian high-volume
         water  sampling  techniques.)  It is hoped that these
         efforts will form the basis for a joint ambient
         monitoring  project that  will determine, where possible,
         how  the estimated net contribution of chemicals  to
         the  Niagara River varies with time.  Trends would be
         defined by  comparing values at the source and mouth
         of the  river.

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                               -7-
         Point Source  Monitoring -- New York DEC, under Clean
         Water Act delegation,  carries on a continuing
         compliance  monitoring  program for point sources on
         the Niagara River.  EPA is  negotiating with the Canadians
         to establish  a  binational  effort that would review both
         NYSDEC's program  and Ontario Ministry of the Environment's
         program.
Integrated Enforcement

One of EPA's primary  missions  is  the enforcement of national
laws to control pollution  in  its  many forms,  and thereby
protect public health and  the  environment.  The Niagara Area,
because of its industrial  diversity and the high flow rate of
the Niagara River,  presents  a  unique set of pollution regulatory
problems, particularly with  respect to extremely low levels
of toxic chemical  contamination.   EPA and NYDEC. have recognized
the need to develop enhanced  data management  tools and
integrated enforcement strategies to help deal with these
problems.

       0 Regulatory Coordination  -- EPA has put into place an
         internal  management  structure to coordinate Niagara
         enforcement  programs  across all media lines.  Under
         this system, Region  2's  new Niagara  Frontier Program
         Manager,  (see page  9),  together with designated
         representatives from  each regional program and the
         Office of Regional  Counsel, are continually reviewing
         source-specific and  areawide pollution control
         programs  in  the Niagara  area to ensure maximum
         effectiveness and to  address potential delays or
         conflicts in strategies.  The region is also
         coordinating these  activities with NYSDEC and with
         EPA Headquarters.

       0 Automated Data Systems -- Through EPA's Integrated
         Environmental Management System, computer software
         packages  are being  examined which may permit a
         variety of point  source  and ambient  environmental
         data to be collected  and analyzed together.  These
         programs  would allow  better identification of potential
         hotspots  and targeting of enforcement activity
         where necessary.

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                              -8-
Toxic Loading Reductions

The main purpose of EPA's Niagara  Action Plan is to reduce the
discharge of persistent organic  chemicals to the river.  Such
reductions are not only required by  U.S. environmental laws,
but also by the Great Lakes  Water  Quality Agreement.  Many of
the components of the Action Plan  are  resulting in such reductions,
or have the potential to do  so,  as indicated in Table II.

Where specific reductions can already  be documented or
predicted, they are contained in the Tables at the end of
this document.  It is EPA's  intention  to continue to improve
documentation of reductions  and  to include this as part of
its regular public reporting on  the  Action Plan.
Resource Commitment
As described  in  the  Introduction,  EPA has maintained a strong
commitment of dollars  and  staff  time in the Niagara area for
a number of years, with  Federal  investment in pollution
control programs  now totalling  over $500 million.  This
ongoing support  for  routine  environmental programs will
continue, primarily  through  program support grants for NYDEC
and the NY Department of Health  which,  on a statewide basis,
total $20 million for Fiscal Year  1986.

In addition,  EPA's regional  staff  will continue to devote
the internal  resources required  to support this work.  It is
estimated that direct staff  support for Niagara activities
totals 41 workyears  per  year,  of which 27 work years are in
Region 2 and  the  balance split among headquarters and other
field programs.  This is  equivalent to approximately $1.5
million per year,  not including  indirect costs, laboratory
or contract support.

Several of the new initiatives  identified in Table II involve
additional staff  or  contract support.
Communications  and  Management
EPA recognizes  the  need  for integrated management of its
various  programs  on the  Niagara Frontier.  The agency also
recognizes  the  need for  timely and complete exchange of
information with  the other agencies and the need to communicate
fully with  the  public on both sides of the border.

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                               -9-
The following mechanisms have been established:

       0 Management — EPA's Region  2  office  has  the lead
         responsibility for the agency's  Niagara  programs.
         The Regional Administrator  has appointed a Niagara Frontier
         Project Coordinator reporting directly  to him and,
         through him, to the EPA Administrator.   The Coordinator
         is responsible for coordinating  Niagara  programs
         within Region 2, with other EPA  offices, including
         the Great Lakes National Program Office  and the
         Office of Research and Development,  with New York
         DEC and with the Canadian agencies.
       o
         Communication -- In  1985 EPA  Region  2  established an
         information office in Niagara  Falls, New York,  to
         facilitate information exchange  with the public and
         Canadian agencies.   Public meetings  and  press
         briefings also will  be held from time  to time in order
         to convey information about the  program,  and  to elicit
         comments on our activities.

       0 Progress Reports --  EPA Region  2 will  issue  periodic
         status reports on the Niagara  Action Plan.

EPA's Niagara River Action Plan should  be regarded as  a
dynamic document.  The Agency intends  to  review and  update it
at least annually.

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                         LIST OF TABLES
Table I         EPA's  Response to the Niagara  River  Toxics
                Committee Recommendations
Table II        Niagara River Action Plan --  Major  Components
Table III       Status  of Nine Major U.S. Point  Source
                Dischargers
Table IV        Implementation Schedule for  Six  Municipal
                Pretreatment Programs


Table V         Status of 61 Potential Nonpoint  Sources of
                Ground or Surface Water Contamination
Table VI        Status of Four Major Superfund  Sites
Table VII       Status  of Permit Activities  for
                RCRA Hazardous Waste Facilities

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                                         TABLE      I
EPA's   RESPONSE   TO   THE   NIAGARA   RIVER   TOXICS
                   COMMITTEE   RECOMMENDATIONS

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                                                        1-1

               TABLE I -- EPA RESPONSE TO NIAGARA RIVER TOXICS COMMITTEE RECOMMENDATIONS — MAY, 1985
      NRTC RECOMMENDATIONS
  EPA POLICY OR PROGRAM
    EPA NIAGARA PROGRAM
   New York should revise permit
   limits so that the cumulative
   impact of all discharges will
   not exceed criteria at the
   edge of defined mixing zones.
   Ontario should further assess
   the potential for impact of
   hazardous contaminants in
   trace amounts on receiving
   water and then determine
   specific needs for further
   action.
State delegated program. EPA
oversees NYSDEC permit program
and reviews major permits from
the Niagara Frontier area.
Not applicable - Canadian issue.
LONG TERM WATER MONITORING PROGRAM
  Point Source 3-7 day surveys.
  Review Canadian technique for
  large volume water sampling,
(reference program description)

Also addressed through EPA/DEC
on-going programs.

Not applicable - Canadian issue*
3. Good housekeeping and routine
   maintenance/ where not in
   effect in a formalized sense
   at present should be adopted
   by all industrial and commercial
   facilities along the river,
   including dischargers to a
   municipal system, to reduce
   or eliminate inadvertent
   discharges of toxic substances.

4. Point source self-monitoring
   programs should include a
   quality control program and
   a laboratory certification
   process.
State delegated permit program.
EPA oversees NYSDEC program,
including EPA review of major
permits from Niagara Frontier
for inclusion of Best
Management Practices (BMP).
EPA has Discharge Monitoring
Report Quality Assurance program
which evaluates selected labora-
tories each year.
PRETREATMENT COMPLIANCE
Compliance follow-up on "indirect"
dischargers with additional
inspection, sampling, enforcement.

Also addressed through EPA/DEC
ongoing programs.
Also addressed through laboratory certi-
fication program being developed by
DEC/DOH with EPA assistance.

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      NRTC RECOMMENDATIONS
   EPA POLICY OR PROGRAM
 EPA NIAGARA PROGRAM
5. Restoration of the Niagara
   Falls Waste Water Treatment
   Plant carbon filter beds
   should be completed and the
   plant brought up to its
   original design capability as
   quickly as possible,

6. Once a problem site has been
   identified, the fastest means
   of clean-up should be adopted.
   If the site owner's voluntary
   cooperation cannot be obtained,
   governmental funds should be
   used for investigations and
   remedial actions, and legal
   action commenced concurrently
   for cost recovery.

7. The United States should
   extend the investigation of
   sub-surface hydrogeology and
   contaminant migration to all
   hazardous waste sites within
   the drainage basin of the
   Niagara River in New York
   State,
   In setting priorities for the
   clean-up of waste disposal
   sites, the United States and
   Canada should take account of
   the long term effects of low
   level contamination of Lake
   Ontario as well as the
   effects on the area near the
   disposal site.
The Niagara Falls Waste Water
Treatment Plant is now fully
operational.
Addressed through EPA/DEC
on-going programs.
Once a site is identified and placed
on the NPL, the fastest means of
clean-up is adopted. The process
includes an RI/FS, option selection,
engineering design, and clean-up.
Some Niagara actions started prior
to CERCLA,  when no other choices
were available.
EPA and NYSDEC work together to
investigate hazardous waste sites
on an established priority basis.
EPA has developed a Hazard Ranking
System (HRS) to quantify dangerous
sites and to establish a priority
list for site clean-ups under
CERCLA.
CERCLA/RCRA PROGRAM

Addressed through EPA/DEC
on-going programs.
GROUNDWATER HYDROLOGIC STUDY
FOR NIAGARA FALLS
Review existing data, identify gaps,
develop plan. Implement monitoring
and develop models. Write report.
Three year phased work schedule.

Also, EPA/DEC have done, or are doing,
a full site investigation at all 61
sites listed in the NRTC report,

CERCLA/RCRA PROGRAM

Also EPA is examining how the HRS
could be modified to better address
the Niagara River/Lake Ontario
problems.

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      NRTC RECOMMENDATIONS
   EPA POLICY OR PROGRAM
  EPA NIAGARA PROGRAM
 9. The responsible agencies
    should carry out a detailed
    site and area investigation
    program for sites not presently
    under such investigation.
    These agencies should implement
    appropriate remedial action,
    as determined by such investi-
    gations, to preclude contami-
    nant migration to the Niagara
    River system.
Preliminary assessments have been
been conducted at all 61 sites in
NYS and listed in the NRTC report.
One third of the sites have also
had either a New York State Phase II
investigation.or a Remedial
Investigation/Feasibility Study
(under CERCLA) completed.  The
remainder have been scheduled for
completion this year.
CERCLA/RCRA PROGRAM

Addressed through EPA/DEC
on-going programs.
10. On-site confinement of
    hazardous toxic substances
    requiring continual maintenance,
    monitoring and appropriate
    corrective action should not
    be considered as the final
    answer for toxic waste disposal.
    Innovative, more effective
    techniques must be developed
    for toxic waste disposal.
The NCP states that remedies must
be cost-effective, technically
feasible and reliable, and must
provide adequate protection for
public health, welfare and the
environment. All options are
evaluated during the final
remedial selection process.
Innovative technology which
provides waste destruction or
ultimate treatment will be used
when warranted by site
conditions.
CERCLA/RCRA PROGRAM

Addressed through EPA/DEC
on-going programs.
11. A complete picture of the bottom
    sediment contaminant load in
    the river should be developed.
    Concurrent with this, bio-
    availability and transport
    studies should be carried out.
    The findings from these studies
    should be assessed to determine
    an appropriate remediation
    program.
Not applicable.
LONG TERM WATER MONITORING PROGRAM
(reference program description)

In addition EPA will try to locate
funding support for a Fate and
Transport Study for Buffalo River
and Black Rock Canal.
2-3 year program.

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                                                            1-4
       NRTC RECOMMENDATIONS
  EPA POLICY OR PROGRAM
  EPA NIAGARA PROGRAM
12. Responsible Agencies should
    conduct investigations to
    determine the extent of
    chlorinated organics in the
    bottom sediments in the Fort
    Erie and Chippawa segments and
    in water of the Chippawa
    Channel.

13. The Parties to the Great
    Lakes Water Quality Agreement
    of 1978 and jurisdictions in
    the upstream basins should
    control persistent toxic
    substances as called for by
    the Agreement.  The IJC should
    evaluate and compare control
    programs used by other juris-
    dictions in the Great Lakes
    Basin with those proposed for
    the Niagara River.

14. The responsible parties should
    continue the remedial and
    investigative work underway to
    eliminate the sources of conta-
    mination of the river established
    in Chapter IV and summarized on
    pages 11 and 12.  Where remedial
    work has been completed since
    the Project, monitoring should
    be conducted to assure that the
    remedial work has been effective.

15. To determine the origin of
    Group I chemicals, they should
    be included in source monitoring
    programs as appropriate.
Not applicable - Canadian issue.
Not applicable - Canadian Issue,
International Joint Commission
issue.
International Joint Commission
issue.
These problems are being addressed
through ongoing programs either by
NYSDEC or EPA. The programs are:
RCRA site closures, CERCLA site
investigations and clean-ups, and
the CWA storm water program.
CERCLA/RCRA PROGRAM

Addressed through EPA/DEC
on-going programs.
On-going EPA/DEC source monitoring
programs do address many chemicals
in Group I.
LONG TERM WATER MONITORING PROGRAM
CERCLA/RCRA PROGRAM
PRETREATMENT COMPLIANCE
(reference program descriptions)

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                                                            1-5
        NRTC RECOMMENDATIONS
   EPA POLICY OR PROGRAM
                                                                                     EPA NIAGARA PROGRAM
16. Chemicals in Group I and HA
    should be included, as
    appropriate, in ambient moni-
    toring programs to establish
    both temporal and spatial
    trends and to determine their
    existence in other media.

17. All chemicals determined only
    qualitatively should be included
    in ambient monitoring programs
    to confirm their existence or to
    determine their levels.

18. Characteristics data should be
    obtained or developed by the
    agencies for the chemicals as
    indicated in Chapter VI.  This
    information should be assembled
    in order of priority amongst the
    groups.
19. Environmental and human health
    criteria should be established
    by the appropriate agencies
    and the 1JC for the many
    chemicals for which none
    exist.  Criteria should be
    developed in order of priority
    among the groups in this
    report (i.e.. Group I before
    Group IIA before Group IIB,
    etc.).  Agencies and the IJC
    should establish uniform
    criteria for water bodies
    which are a shared resource.
On-going EPA/DEC ambient
monitoring programs include
many of the chemicals in Groups I
and IIA.
LONG TERM WATER MONITORING PROGRAM
(reference program descriptions)
Not addressed.
EPA develops a selected number of
environmental and health criteria
each year. EPA program offices
establish priorities.
EPA develops a selected number of
environmental and health criteria
each year. EPA program offices
establish national priorities for
selection of criteria and risk
assessment documents to be done
each year.
LONG TERM WATER MONITORING PROGRAM
(reference program description)
DEVELOP ENVIRONMENTAL AND HUMAN
  HEALTH CRITERIA
Review EPA work already done, and
now being done. Schedule new
assessment documents as required,
and as EPA ORD resources permit.
Some work to be done through CERCLA
Hyde Park case.

DEVELOP ENVIRONMENTAL AND HUMAN
   HEALTH CRITERIA
(reference previous description)

-------
                                                              1-6
         NRTC RECOMMENDATIONS
 EPA POLICY OR PROGRAM
   EPA NIAGARA PROGRAM
  20. The Long Term Monitoring
      Program should contain a
      Quality Assurance Program.
      The overall objectives of the
      program should be clearly
      stated and agreement should be
      reached on analytical labora-
      tory performance criteria,
      parameters and detection limits.
All EPA monitoring programs
include quality assurance.
LONG TERM WATER MONITORING PROGRAM
Quality Assurance Program is
included.
(reference program description)
  21. The Committee found that the
      lack of a common international
      data base has created mechanical
      barriers to the prompt
      completion of its charges.
A number of computer information
systems are available for access.
Detailed data on CERCLA sites is
available from NYSDEC and EPA.
CERCLA/RCRA PROGRAM

Also addressed through EPA/DEC
on-going programs.

Need better access to Canadian
data bases.
  22. A binational committee should
      be identified to coordinate
      the implementation of the
      recommendations in this report.
EPA works through organizations
such as the IJC and GLNPO.
EPA is working together with EC,
MOE, and NYSDEC on a newly formed
binational committee on the
Niagara.
* 23. That the Niagara River be the
      pilot site for implementing
      a toxic loading allocation
      plan based on a mass balance
      concept and incorporating a
      progressively reducing ceiling
      on loading levels,  simultaneously
      leading toward the  development
      of a conceptual allocation plan
      for toxic contaminants for the
      whole of Lake Ontario and
           (continued)
The Niagara River contributes
approx. 85 percent of the
tributary flow to Lake Ontario.
The direct discharges to the
Niagara River represent only 20
percent or less of the discharges
to the lake.  While it has been
alleged that the Niagara River
is the most significant contamin-
ation source to the lake, such
has not been documented.  In fact,
        (continued)
EPA is now working with
Canadian government agencies
and NYSDEC to develop a toxic
wasteload allocation plan for
the entire Lake Ontario basin,
starting with the Niagara River,
and later to include Lake Ontario.

-------
                                                            1-7
       NRTC RECOMMENDATIONS
EPA POLICY OR PROGRAM
                                                                                       EPA NIAGARA PROGRAM
  23. (Continued...)
      eventually the whole Great
      Lakes basin.  Consideration
      should be given in the renewal
      of the Canada/U.S.  Agreement
      on Great Lakes Water Quality
      to the development of target
      loads for toxic substances for
      each lake, similar to the
      target loadings for phosphorus
      in the Supplement to Annex 3.
* 24.  That Annex 1  of the Great Lakes
      Quality Agreement be updated
      and expanded by the parties to
      include at least those
      chemicals addressed in the
      allocation plan; that the
      Parties examine Article 2,
      Annex 1 of the Agreement, to
      revise and make progressively
      more stringent the objectives
      as currently established, in
      order to more closely follow
      the zero discharge philosophy
      of Annex 12.
   as of 1978,  Canadian discharges
   represent a  little over 50
   percent of the discharge flows
   to the lake.   The answer to the
   toxics problem in Lake Ontario is
   to undertake  an allocation plan
   for the Lake  Ontario basin,
   including the Niagara River.
   The Niagara  River represents  only
   a small portion of the direct
   discharges to Lake Ontario.

   The United States through the Clean
   Water Act and its admendments is
   dedicated to  a policy of zero discharge.
   To this end the Agency,  through its
   effluent guidelines programs, has been
   promoting a policy of continued loading
   reductions towards the ultimate goal  of
   zero discharge.   The issue in
   Recommendation 24 is not one  concerning
   a zero discharge policy, but  involves
   an apparent conflict within  the Great
   Lakes Water Quality Agreement.
   Specifically, Annex 1 specifies
   numerical levels of selected  persistent
   contaminants, while Annex 12  specifies
   a philosophy  of  zero discharge.   This
   apparent conflict in meaning  must be
   clarified by  the parties to the agreement.
Addressed by
EPA policy statement
presented in column to
the left.
  *  These  recommendations  were  not  supported,  as  written,  by  the  U.S.  members  of  the  NRTC

-------
         TABLE   II
NIAGARA RIVER  ACTION  PLAN







      MAJOR COMPONENTS

-------
            TABLE II — NIAGARA RIVER ACTION PLAN — U.S. ENVIRONMENTAL PROTECTION AGENCY — MAY, 1986

 Point Sources

         Goal: Ensure continued progress in the identification, investigation and control
               of point source discharges of toxics from U.S. sources into the Niagara River
        Component
Ongoing   New   Agency(s)
   Status/Resources
          Toxic Reduction
Second round (toxic-specific)
   SPDES permits
Industrial Pretreatment
   Programs
Industrial Pretreatment —
   technical assistance
   to municipalities for
   enforcement.
                 NYSDEC         All majors have been
                 EPA - 2        reissued: review
                                underway.

                 EPA - 2        Plans approved for all
                 NYSDEC         six U.S. municipal
                                plants.

                 EPA - 2        Program  for all 6 in
                 EPA - NEIC     FY 86.
                 NYSDEC         (approx. 2 work-years)
                                      Yes
                                      Yes
                                    Potential
SPDES permit compliance —
   enhanced inspections for
   selected major dischargers,
                 EPA - 2        Program for FY 86
                 EPA - NEIC     (resources depend on
                 NYSDEC         type of inspection done)
                                    Potential
Investigation of stormwater
    runoff at selected
    industrial sites.
                 EPA - GLNPO
                 NYSDEC
Program for FY 86: GLNPO
Contractor — ง60,000.
              Potential
Program to quantify loading
    reductions expected
    through permit limits.
                 EPA - GLNPO
                 NYSDEC
FY 86 under IJC Areas
Concern program:
GLNPO Contractor --
$25,000.
of
NA
EPA - 2 = Region 2 Office
EPA - GLNPO = Great Lakes National Program Office
EPA - NEIC = National Enforcement Investigations .Center
                            NYSDEC = New York state Department of Environmental
                                       Conservation
                            IJC = International Joint Commission

-------
                                                         II-2

            TABLE II — NIAGARA RIVER ACTION PLAN — U.S. ENVIRONMENTAL PROTECTION AGENCY — MAY, 1986

Nonpoint Sources

         Goal: Ensure continued identification, investigation and control of nonpoint discharges of
               toxics into the Niagara River.
      Component
Ongoing   New
Agency(s)
Status/Resources
Toxic Reduction
Investigation, study and remediation
  of abandoned hazardous waste sites
  under Federal Superfund  (CERCLA).
Develop an areawide groundwater
  hydrology model — coordinate
  with site-specific
  models (CERCLA).

Bring all 20 active hazardous waste
  facilities into conformance with
  Resource Conservation and Recovery
  Act (RCRA).
Determine whether leakage is occuring
  from CECOS facility.
                   EPA - 2
                   EPA - OSWER
                   EPA - OECM
                   NYSDEC

                   EPA - 2
                   EPA - OECM
                   USGS
                   NYSDEC

                   EPA - 2
                   NYSDEC
                   EPA - 2
National Groundwater Task Force
  investigation of SCA facility;
  national program to enhance
  RCRA enforcement.
            X
                   EPA - OSWER
                Major ongoing program.           Yes
                See Table VI for
                status of 61 sites
                identified by NRTC.

                First phase (compile             NA
                existing data) is
                scheduled to be started
                in FY 86.

                EPA has requested Part B       Potential
                permit applications  from
                all 20; all are in permit
                or closure process.
                (Table VII)

                CECOS carrying out ground-     Potential
                groundwater survey.  EPA
                inspected 16 of 17 nearby
                sites and has begun
                two-phase sampling.

                Sampling completed;  analysis   Potential
                and data interpretation
                unde rway.
EPA - 2 = Region 2 Office
EPA - OECM = Office of Enforcement and Compliance Monitoring
EPA - OSWER = Office of Solid Waste and Emergency Response
                           USGS = U.S.  Geological Survey
                           NYSDEC = New York State Department of
                                    Environmental Conservation

-------
                                                         II-3

            TABLE II — NIAGARA RIVER ACTION PLAN — U.S. ENVIRONMENTAL PROTECTION AGENCY — MAY, 1986
Monitoring Programs
          Goal: Improve current and future understanding of the ambient levels of toxics in the Niagara River and
                its environs; assess the risks posed by those levels; ensure interagency/international agreement
                on data collection, analysis and interpretation methods.
         Component
Ongoing    New   Agency(s)
                 Status/Resources
Toxic Reduction
Establish binational coordination
  on long-term monitoring
  activities.
Ressolve binational differences in
  sampling protocols, analytical
  techniques, detection limits and
  data interpretation.
Evaluate Canadian high-volume water
  sampler for U.S. applications.
Develop bioaccumulation factors for
  Niagara River toxics in biota.
Assess Chemicals of Concern identified
  by Niagara River Toxics Committee
  Report.
                  EPA - 2
                  EPA - ORD/OW
                  NYSDEC
                  EC
                  MOE

                  EPA - 2
                  EPA - ORD/OW
                  NYSDEC
                  EC
                  MOE

                  EPA - GLNPO
                  EPA - 2
                  EC
              Discussions being held with
              DEC and Canadian agencies.
      NA
              Discussions begun in November
              1985.
      NA
              Workshop held 8/85; field tests
              begun 9/85. Work ongoing.
      NA
       X
EPA - OECM    Work to begin in FY 86.
EPA - 2        EPA - $750,000
NYSDEC         NYS - $250,000
OCC            OCC - $330,000

EPA - ORD     EPA risk assessment program
              has completed or is in
              process of reviewing
              all Chemicals of Concern.
                                                                     NA
EPA - 2 = Region 2
EPA - GLNPO = Great Lakes National Program Office
EPA - OECM = Office of Enforcement and Compliance Monitoring
EPA - ORD = Office of Research and Development
EPA - OW = Office of Water Programs
                           NYSDEC = NYS Dept.  of Environmental Conservation
                           EC = Environment Canada
                           MOE = Ontario Ministry of the Environment
                           OCC = Occidental Chemical Corporation

-------
                                                       II-4
          TABLE II — NIAGARA RIVER ACTION PLAN — U.S. ENVIRONMENTAL PROTECTION AGENCY ~ MAY, 1986
Integrated Enforcement
        Goal: Develop enhanced data management tools and integrated enforcement strategies
              to help deal with the unique pollution control regulatory problems of the
              Niagara area.
       Component
Ongoing    New   Agency(s)
                  Status/Resources
                               Toxic Reduction
Cross-media regulatory program
  coordination within EPA.
Formal enforcement coordination
  between EPA and NYDEC.
  X
Assemble point source and
  ambient data banks. Quality
  assure as required.

Generate computer software
  packages to assist in
  identifying potential
  hot spots and to establish
  enforcement targets.
            X
                  EPA-2
                  EPA-OECM
EPA-2
EPA-OECM
DOJ
NYSDEC
NYDOL

EPA-2
EPA-OPM
NYSDEC

EPA-2
EPA-OPM
Intermedia network estab-
lished and coordination
now underway.

Major ongoing activity.
Data to be compiled in
FY 86.
                                Begin using integrated
                                data system in late FY 86.
                                                Potential
Potential
   NA
                                  Potential
EPA-2 = Region 2
EPA-OECM = Office of Enforcement and Compliance
               Monitoring
EPA-OPM = Office of Planning and Management
                       DOJ = U.S.  Department of Justice
                       NYSDEC = NYS Department of Environmental Conservation
                       NYDOL = New York  State Department of Law

-------
                                                    TABLE      III
STATUS   OF   NINE   MAJOR      U.S.    POINT    SOURCE   DISCHARGERS

-------
                          TABLE III — STATUS OF NINE MAJOR U.S. POINT SOURCE DISCHARGERS
                                            SUMMARY OF CONTROL MEASURES SINCE 1982
                                                      In-House               New/Upgraded                permit with
                                  Reduced   Facility  Controls      Flow     Treatment    On Compliance     Toxic
FACILITY (Permit No.)
Buffalo Sewer Authority WWTP
(NY0028410)
Niagara Falls WWTP
(NY0026336)
Bethlehem Steel Corp.
(NY0001368)
Niagara Mohawk Power
(NY0001023)
Olin Corp.
(NY0001635)
Spaulding Fibre Corp.
(NY0002364)
Town of Tonawanda WWTP
(NY0026395)
Town of Araherst WWTP2
(NY0025950)
Donner-Hanna Coke
(NY0003310)
Operations Closure Instituted Reduction Facilities Schedule Limitations (date)
xx x 10/1/85
x 11/1/821
x xxx 7/1/84
x xx 7/1/82
x x 3/1/83
x x x 5/1/84
x 6/1/83
8/1/85
x
1  - Toxic limits are currently stayed
    by Court.
2 - New secondary treatment plant completed prior to NRTC Report.
    Facility has been in continual compliance with permit limits.

-------
                                                       III-2
FACILITY (Permit No.)

Buffalo Sewer Authority WWTP
(NY0028410)
Niagara Falls WWTP
(NY0026336)

Bethlehem Steel Corp.
(NY0001368)
Niagara Mohawk Power
(NY0001023)
01in Corp.
(NY0001635)
 Spaulding  Fibre Corp.
 (NY0002364)
 Town  of  Tonawanda WWTP
 (NY0026395)

 Town  of  Amherst WWTP
 (NY0025950)

 Donner-Hanna  Coke
 (NY0003310)
     SUMMARY OF CONTROL MEASURES SINCE 1982

                 Comments

WWTP upgraded in 1982-83 per Consent Order.  Sewer repairs and infiltration
study to reduce flows are ongoing, as well as, combined sewer overflow
study.  Facility has been in compliance with permit limits, since end of
1985.

Carbon beds went on-line 8/1/85.  Facility is now in compliance with permit
limits.

Basic steel and coking operations closed in 1983.  In-house controls (Best
Management Plans, reduced acid dumps, increase use of polymers) instituted.
Water recirculation has reduced discharge to approximately 1-2 hours/week.
New lime slaker went on-line 1/86, with second unit to be on-line by 5/86.

New WWTP (coal pile runoff and demirieralizer wastes) is in start-up phase,
expect full operation by mid 1986.  In-house controls consisted of piping
and plumbing changes. Facility has, for the most part, been in compliance
with final permit limits since early in 1986.

Carbon beds were installed 7/84.  In-house controls include tighter
controls to prevent chemical spills/loses.  Toxics organic load reduced
> 90%.

Remedial controls initiated throughout 1983-84.  In-house controls included
piping changes and tighter process control.  Zinc concentration system was
upgraded in 1984 and has shown 50% increase in efficiency.  Compliance
schedule requires additional structural measures to be completed as part of
the Best Management Plan by early 1987.  Facility in compliance with permit
limits since 7/85.

A biomonitoring program was submitted on 9/19/85 to the NYSDEC. It is now
being reviewed by that agency.

Facility in Compliance with Permit Limits.
Facility shut down.  No current discharge.

-------
               TABLE   IV
     IMPLEMENTATION  SCHEDULE FOR







SIX  MUNICIPAL PRETREATMENT PROGRAMS

-------
Program Elements
                              IV-1

TABLE IV — PRETREATMENT PROGRAM IMPLEMENTATION SCHEDULE


                                        POTWS
Program Approval Date
SPDES Permit, Modified
Total SIUs and (Number
of Permits Issued)
Dates for Issuance
of all SIU Permits
SIUs in Compliance with
Fed. & Local Limits
Dates for Compliance
by all SIUs
Program Elements in
Place:
- Manpower
- Funding Mechanism
- Enforcement
Procedures
- Sampling & Monitoring
Procedures
- Computerized (Manual)
Data System
Buffalo Sewage
Authority
9/11/84
10/1/85
145(138)
12/31/85
131
9/30/86

X
X
X
X
X
Town of Town of Niagara Co.
Tonawanda Amherst S.D. No. 1
2/28/85 9/28/84 9/26/84
Draft 7/23/85 Pending
8(8) 4(1) 4(0)
9/1/86 8/31/86
844
11/20/85 mid-1987

XX X
XX X
XXX
XXX
XXX
City of North
Tonawanda
7/17/84
8/23/85
6(0)a
3/31/86
b
b
c
X
X
X
X
X
City of
Niagara Falls
5/08/85
Draft
34(34)
12/3/85
34
—

X
X
X
X
X
   SIU - Significant Industrial User
         (needs pretreatment permit).
                             a  - Two facilities presently shut down.
                             b  - SIUs currently being rechecked as  to status*
                             c  - Under Consent Order to develop implementation schedule<
                                 Submitted  to DEC  11/20/85  and currently under review.

-------
                                          TABLE     V
STATUS   OF   61    POTENTIAL   NONPOINT   SOURCES   OF







     GROUND   OR   SURFACE   WATER   CONTAMINATION

-------
                                                  V-1
TABLE V  —  STATUS OP 61 POTENTIAL NONPOINT SOURCES OP GROUND OR  SURFACE WATER CONTAMINATION
Site Description
BUFFALO-LACKAWANNA
SUB AREA
Bethlehem Steel
Altift Realty
Times Beach
Mobil Oil Corp.
MacNaugh ton- Brooks
Allied Chemical
Buffalo Color
(3 sites)
Squaw Island
TONAWANDA-NORTH
TONAWANDA SUB AREA
Allied Chemical
Tonawanda Coke
INS Equipment Corp.
Huntley Power Corp.
Phas
Start


3/83
5/83
5/83
11/84
11/84


11/85

5/83
3/83
5/83

e 1
End


11/83
9/83
9/83
6/85
6/85


3/86

9/83
11/83
9/83

Phase
Start


2/85

8/85
10/85
7/86


7/86


10/85
2/85

! 2
End


2/86

4/86
12/86
3/87


3/87


12/86
4/86
3/86
AGN

EPA
DEC
DEC
DEC
DEC
DEC
DEC

DEC

DEC
DEC
DEC
DEC
Enfc
Stat.
Code


NE

NE

NE
OS



NE
NE
NE
OS
ircenu
Act.
Code

CNT
CNT

CNT

CNT
CNT



CNT
CNT
CNT
CNT
jnt
Rem.
Prog .















Evaluation
for NPL


8/86

4/87
5/87
6/87


6/87


5/87
12/86
12/86
Remarks

EPA Consent Order signed 8/85
for RCRA closure of facility.


PRP doing Phase II ,






PRP drafting workplan
for remediation.

Field work completed. Draft
Phase II received/under review.
Field work completed. Draft Phase
II reviewed. Awaiting final report

-------
V-2
Site Description
Columbus-McKinnon
Occidental Chemical,
Durez Division
(14 sites)
Gratwick Riverside
Park
NIAGARA FALLS, NEW
YORK SUB AREA
Love Canal
Hyde Park (OCC)
S-Area (OCC)
102nd St. (OCC)
102nd St. (Olin)
Phas
Start


3/83





,e 1
End


11/83





Phase
Start


12/84





2
End


10/84





AGN
DEC
DOL
DEC
EPA
DEC
EPA
DEC
EPA
DEC
EPA
DEC
EPA
DEC
Enfc
Stat.
Code

NE
NE





>rcem€
Act.
Code


CNT

CRT
CRT


•nt
Rem.
Prog.








Evaluation
for NPL

Evaluated
9/84
Evaluated
9/84
On NPL
On NPL
On NPL
On NPL
On NPL
Remarks
PRP phase I, Phase II completed.
Cleanup scheduled to start 7/1/86.
RI/FS Design Invest.
End Start End
1. Sewers 11/85 11/85 2/86
2. Panhandle 12/85 3/86 10/86
3. Plant Site 10/85 10/85 9/86
Scored below cutoff value of 28.5
Scored below cutoff value of 28.5.
Negotiating with PRP for them to
remediate.
See Table VI for status report.
See Table VI for status report.
See Table VI for status report.
See Table VI for status report.
See Table VI for status report.

-------
V-3
Site Description
Niagara County
Refuse Disposal
Griffon Park
Bell Aerospace
Textron
Charles Gibson
Buffalo Avenue
Dupont, Me ceo Park
Reichold-varcum
Chemical Division
Dupont Plant
(6 Sites)
Occidental Chemical
Buffalo Ave. Plant
(9 sites)
Solvent Chemical
Olin, Buffalo Ave.
Plant site (3 sites)
Pha:
Start










3/83
3/83
36 1
End










11/83
11/83
Phas<
Start
2/85









2/84

s 2
End
7/86









10/84

AGN
EPA
DEC
DEC
DEC
DOL
DEC
EPA
DEC
DEC

DOL

DOL
DEC
Enf<
Stat.
Code

NE
OS
NE
OS



NE

NE
NE
>rcem<
Act.
Code

CNT
CRT
CNT
ADM



CRT

CRT
CRT
2nt
Rem.
Prog .












Evaluation
for NPL
10/81
Evaluated
9/84










Remarks
On NPL. Phase II in progress.
Scored below cutoff value of 28.5.
Olin and Hooker will do Phase II as
part of 102nd Street RI/FS.
Surface impoundment shut down.
Facility to be closed under RCRA.
Consent Agreement signed -
RI/FS start 5/85
RI/FS end 8/86
PRP doing Phase II. Workplan is
under negotiation.
Groundwater investigation by PRP
start 4/85; end 6/87.
PRP RI/FS completed. Materials
excavated and a drain system
installed.
Site investigations done. IRM's
(soil removals) done at 3 sites.
DEC supervised RI/FS in progress.




Proposed Consent Order sent
to Olin by DEC in 11/85.
Presently under negotiation.

-------
                                               V-4
                                              LEGEND
Phase I  - an initial site investigation to identify and
           generally characterize potential problems.

Phase II - a follow up site investigation to confirm or disprove
           the findings in Phase I and, if needed, to provide
           information required for a Hazardous Ranking System
           (HRS) score, which assigns priorities  for action.

(# sites)- Number of sites in the total count that are in one
           location, and therefore listed together.

   RI/FS - Remedial Investigation, Feasability Study

AGN - Agency

EPA - United States Environmental Protection Agency

DEC - New York State Department of Environmental  Conservation

DOL - New York State Department of Law
NPL - National Priorities List

PRP - Potential Responsible Party

CNT - Consent Order

ADM - Administrative Order

CRT - Court Order

NE  - Order Under Negotiations

OS  - Order Signed

IRM - Initial Remedial Measure

Stat Code - Status Code

Act Code  - Type of Action

-------
                                TABLE     VI
STATUS   OF   FOUR   MAJOR   SUPERFUND   SITES

-------
                              VI-1
         TABLE  VI — STATUS OF  POUR  MAJOR SUPERFUND SITES
                           LOVE  CANAL
Background

The Love Canal  site is in the  southeast corner of the city of
Niagara Falls approximately one-quarter mile north of the Niagara
River.  Hooker  Chemical and Plastics  Corporation (now Occidental
Chemical Corporation) disposed  of  over 21,000 tons of various
chemicals  (including dioxin contaminated trichlorophenols) into
Love Canal between 1942-1952.

The Love Canal  property was sold  by Hooker in April 1953 to the
City of Niagara Falls Board of  Education.   During the mid
1950's, home  construction accelerated in the area, and in 1954 a
public school was built on the  middle portion of the Canal.  Over
the next two  decades, contaminated leachate came into contact
with the surface of the Canal  and  nearby basement foundations.
Contaminants  also migrated through sewers  to two nearby creeks.

Approximately 850 families have been  evacuated from the Emergency
Declaration  Area (EDA), an area surrounding the Canal which
extends 1500  feet from the Canal.   Nearly  1050 families were
eligible for  evacuation.  All  homes on streets immediately bording
the Canal  have  been demolished, as has the school.  Other homes
within the EDA  have or are scheduled  to be demolished due to
deterioration.

In October of  1978, the first  phase of the Love Canal Remedial
Program was  initiated.  The objective of the first phase was to
contain chemical waste at the  site.  The program included a  tile
drain  (leachate collection) system, a clay cover over the Canal,
and an on-site  treatment  facility.

Leachate moving through the ground is intercepted and conveyed to
a drain pipe.   This lowers  the level  of the water inside  the
landfill and  causes water in  the  ground outside the Canal itself
to flow inward  toward the pipes.   The system is a barrier that
prevents leachate from moving  into the groundwater adjacent  to
the Canal.  The leachate  collection system and treatment  plant
began  operating in December  1979.

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                              VI-2
The clay cap acts  as  an  umbrella,  preventing rainwater and
melting snow from  mixing with the  toxic and hazardous chemicals
underneath.  The cap  decreases the amount of water entering
the landfill; prevents  the runoff  of contaminated rainfall;
prevents human  contact  with the waste in the dumpsite; and
stops atmospheric  emissions from the buried chemicals.

Status
On July 12,  1982,  a  cooperative agreement between NYSDEC and
EPA obligated  $6,995,000 from CERCLA.   Amendments have increased
the total available  CERCLA funding to  nearly $17,000,000.   The
Cooperative  Agreement identified several remedial tasks to  be
taken in addition  to those instituted  in October 1978.

In the fall  of  1982,  sewers leaving the Canal were severed  to
deter future contaminant flow via these pathways.  In  1984, an
expanded cap (from 16 to 40 acres) with a synthetic liner was
completed.

A long term  monitoring/perimeter study began this past fall and
is ongoing.  Aside from establishing a monitoring system, this
program will evaluate the effectiveness of the leachate collection
system, and  determine the extent of contaminant migration from
the Canal.

This study is  in  three phases.  Phase  I was conducted  this
past fall and  included the installation of wells and piezo-
meters; and  collection of water and soil samples for chemical
analyses.  Phase  II  (to be conducted this spring and summer)
calls for additional perimeter survey  explorations as  necessary;
collection of  water  and soil samples;  preparation of a report
on the findings  of the perimeter survey and installation of
piezometers  in  the Canal.  Phase III consists mainly of the
collection and  analysis of groundwater and surface water
samples at stations  during the first year of the monitoring
program.

On May 6, 1985  a  Record of Decision (ROD) was signed which
approved remediation of dioxin contaminated sewers and craeks
in the Emergency  Declaration Area (EDA) to prevent further
migration of contaminated sediments.  The collected sediments
will be placed  in  interim storage at the Canal.

A contractor has  been engaged to clean EDA storm and sanitary
sewers which drained from the Love Canal site or which might
have been contaminated by drainage from the site.  The work
has begun and  should be completed by summer of 1986.   Work
entails removal  of contaminated sediments by hydraulic cleaning,
followed by  remote television camera inspection to assure that
sediments have  been  removed.  The sewer sediments will be
dewatered and  eventually placed in an interim storage  facility.

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                              VI-3
A. contractor is currently  being selected to design the creek
remedy.  Remediation  of  the creeks is expected to begin
in the Spring of  1987  with the construction of the interim
storage facility.   The removal of contaminated creek sediments
is expected to take place  during the 1987 construction season.
Sediment in Bergholtz  Creek will be removed from approximately
150 feet above its  confluence with Black Creek downstream to
its confluence with Cayuga Creek.  Black Creek will be
remediated from 98th  Street to its confluence with Bergholtz
Creek.

A temporary berm  is scheduled to be constructed in the 102nd
Street outfall delta  area  to prevent the migration of contami-
nated sediments.   The  design and location of this berm will
be based upon sediment sampling previously performed by
Malcolm Pirnie  (1983  EID)  and sampling performed this spring  for
the 102nd Street  Landfill  remedial investigation.  Long  term
remediation of  the  delta area will be coordinated with remediation
of the 102nd Street Landfill.  To date,  neither the long term
remedial action for the  102nd Street Landfill nor the site's
contribution to contamination of the delta area has been
established.

Large quantities  of wastes will be generated as a result of
remedial activities at Love Canal.  Most of the wastes generated
are likely to be  contaminated with 2,3,7,8 TCDD.  Since  no
commercial facility is presently permitted to treat or dispose
of dioxin contaminated wastes, these wastes are subject  to
interim storage at  Love  Canal.  This is  consistent with  the
fact that interim storage  is necessary prior to final
destruction/disposal.

A final means of  destroying/disposing these wastes continues
to be investigated.   An  experimental burn of Love Canal  creek
sediments originally  scheduled to take place in January  at
EPA's Combustion  Research  Facility has been postponed until
this summer.  The experiment should provide an indication of
the incinerability  of  the  sediments as well as the degree of
contamination  (if any) in  the effluents  generated during
their incineration.

The NYSDEC's  Plasma  Arc was recently transported to Love
Canal.  Plans call  for the Plasma Arc to thermally treat the
leachate treatment  plant "sludge" currently stored at the
site.  NYSDEC hopes to conduct test burns with the unit  by
the end of this calendar year.  Unfortunately, this unit can
only treat liquid wastes at this point in time.

Selection of a  contractor  to perform a remedial investigation
and feasibility study for  the 93rd Street School is also
underway.  Remediation will be performed in conjunction  with
and highly dependent  upon  remediation in the rest of the EDA.

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                              VI-4
                      HYDE  PARK LANDFILL
The Hyde Park Landfill  is  in  the Town of Niagara, New York.  The
Landfill was utilized by Hooker Chemicals & Plastics Corporation
(now OCC) as a dump  site from 1953 to 1975.  During that time,
Hooker disposed of approximately 80,000 tons of hazardous materials
at the site, including  approximately 3,300 tons of 2,4,5-
trichlorophenol ("TCP") wastes.   TCP wastes are known to contain
significant amounts  of  2,3,7,8tetrachlorodibenzo-p-dioxin ("TCDD").

Chemicals migrating  from the  Landfill exist in two liquid phases
- non aqueous phase  liquids  ("NAPL") and aqueous phase liquids
("APL").  NAPL is a  mixture of a wide range of organic chemicals.
This mixture is predominately composed of chemicals with relatively
low solubility in water and a specific gravity heavier than water.
At the Hyde Park Landfill,  there is also evidence of a wide range
of organic constituents that  are either dissolved in or identified
in surface water, ground-water,  soil, sediment or NAPL.

The Landfill is in a complex  hydrogeologic environment.  Glacial
overburden composed  of  fine  clays, silts, and some sand overlies
a carbonate and shale bedrock.  Stratigraphically the bedrock is
composed of the Lockport Dolomite Formation (approximately 60
feet thick) which is in  turn  underlain by an approximately 240
foot thickness of rock  formations composed of limestone, dolomite,
sand.stone, siltstone and shale.   Below these formations is the
Queenstone Shale.

The bedrock is a fractured medium in which the localized ground-
water flow is often  controlled by the orientation and location  of
the fractures and joints.   The horizontally layered nature of the
Lockport, Rochester, and underlying formations imposes additional
constraints on ground-water  flow.  Ground-water movement is both
downward and horizontal, from the overburden to the bedrock and
through the bedrock  to  the Niagara River.  Some of this ground-water
exits the Niagara Gorge  Face  in the form of ground-water seeps.

EPA filed a lawsuit  in  1979  to require OCC to remediate the Hyde
Park landfill.  After several months of negotiations EPA, the
State, and OCC filed a  proposed Stipulation and Judgment Approving
Settlement Agreement on  January 19, 1981 ("Settlement Agreement").
Status
OCC has been  implementing the Settlement Agreement subject  to
governmental  oversight since 1982.  The Aquifer Survey was
completed during  1982 to 1983, and OCC's proposed Requisite
Remedial Technology ("RRT")was submitted to EPA and the  State
of New York in  April and May 1984.  This study proposed
remedies for  all  contaminated areas,  except there was no
proposed source control program and no proposed remedy for
certain portions  of the contaminated  bedrock ground-water.

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                              VI-5
As required by  the  Settlement Agreement, EPA and the  State
responded to OCC's  RRT study on September 5, 1984.  This
response generally  determined that OCC had submitted  insuffi-
cient information  to  conclude that either source control  or
remediation of  the  aforementioned portion of the contaminated
bedrock ground-water  was not "requisite" within the meaning
of the Settlement  Agreement.  The response also outlined  what
additional data and requirements would be necessary for each
aspect of the proposed RRT.

Since August 1984,  EPA, New York State and OCC negotiated
details of an acceptable RRT program.

EPA used its in-house expertise in conjunction with independent
expert consultants, who worked more than 15,000 hours  on  the
negotiations at an expense of approximately $1.5 million.

The parties have now  agreed on a comprehensive remedial
program described  in  the Stipulation on Requisite  Remedial
Technology Program.  When approved by the Court, the  agreement
will modify the Hyde  Park Settlement Agreement to  require OCC  to
perform a comprehensive remedial program at the site,  including
areas for which there are no specified  remedies in the original
Settlement Agreement, in order to make  them compatible with
the specified RRT remedies and with newly available information.

Specifically, the  RRT includes a number of activities  to  address

     "Gorge Face seeps;
     "Treatment and monitoring of collected liquids (NAPL &  APL),
     "Deep formations study  (Irondequoit/Reynales  formations);
     "Source Control;
     "Containment and collection of contamination  in  the
      overburden and Lockport bedrock;
     "Community montioring during investigative and remedial
      activitie s .

Within  60 days  after the RRT Stipulation becomes approved by
the Court, OCC  must submit a schedule for the  entire  project
for the governments'  approval.

OCC has submitted an application for an incineration  permit
that would allow them to burn Hyde Park wastes contaminated
with PCB  and TCDD.  This application is now being  reviewed by
EPA and New  York State.

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                              VI-6
                          S-AREA SITE
Background

The S-Area  Site  is  an 8-acre landfill owned by Occidential
Chemical Corporation  where approximately 53,000 tons  of
organic and inorganic chemicals were disposed of by  the  site
owner from  1947  to  1961.   Use of the site for debris  disposal
ended in 1975.   Located east of the site, just across  53rd
Street, is  the  City of Niagara Falls drinking water  treatment
facility.

After the landfill  was closed, Occidental capped the  site.
At the present  time,  two  lagoons exist on site. These  lagoons
are for non-hazardous wastewater from plant operations and are
operated under  State  permits.  In 1969, during a routine
inspection  of  the city water plant, small amounts of  chemicals
were found  in  the intake  structures.  In 1978, sampling  of the
intake structures and one of the bedrock intake tunnels
revealed chemical contamination.  Soil sampling of the plant
property also  revealed chemical contamination.  In 1983,  the
the City of Niagara Falls Water Authority closed the  contami-
nated bedrock  intake  tunnel and began utilizing the  overburden
intake tunnel.

In December 1979, the Department- of Justice filed a  civil
action against Occidental.  The legal action began a  series
of negotiations, which continued until 1984.  A Settlement
Agreement was  signed  in January 1984 that allows the  Federal
and State Governments to  establish criteria and oversee  clean
up activities at both the S-Area Site and the water  treatment
plant.  The Settlement Agreement was approved on April 15,
1985;  the effective date  of the Agreement was June 14, 1985.
Status
  The Settlement  Agreement contains provisions for:

    - Surveys and studies  program.   This requires the
      drilling  of survey  wells and  borings, to determine  the
      areal and vertical  extent of  chemical migration from
      the landfill site in the overburden towards the Niagara
      River and in the Lockport Formation.

    - Containment program.   This details the procedures that
      shall be  followed in order to contain and collect
      chemicals which have migrated from the landfill.  The
      program addresses conditions  at the landfill site,
      a small area to the  north of  the landfill and the
      water treatment plant (including intake tunnels).

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                        VI-7
 Monitoring program.  This entails  physical and chemical
 monitoring activities  at  the  landfill site,  northern
 landfill site and the  water treatment plant (including
 intake tunnels).

 Maintenance program.   This  is  designed to insure the proper
 performance of the remedial systems  installed
 pursuant to the containment and  monitoring programs.

 An environmental health/safety plan  will be implemented
 during the construction activities associated with
 the containment program.  The  plan is designed to
 provide appropriate precautions  to protect the health
 of all personnel, residents,  and nearby workers and
 to the environment outside  the immediate areas by
 controlling the airborne  dispersion  of particulates
 and volatile organic chemicals.

 Occidental submitted plans, specifications and pro-
 tocols for the subsurface investigative work that is
 scheduled to begin in  April 1986.  The documents have
 been reviewed by the governmental  parties and comments
 provided to Occidental.
 PLANNED SCHEDULE

     Activi ty                     Activity Period
                                From           To

- Surveys/Studies Phase        November 1985  June 1988

- Containment Systems
     o S-Area Landfill         May 1989       June 1991
     o Northern  Area           August 1989    March 1990

- Drinking Water Facility
     o Main Plant              May 1990       June 1994
     o Intake Tunnel           November 1988  April 1992
 Dioxin strategy  plan  entails  sampling of the entire
 Buffalo Avenue plant  site  (excluding S-Area).

 Construction  activities  associated with the water
 treatment plant  are to be  initiated no later than the
 beginning of  the 4th  construction season (1989) after
 the effective date of the  agreement.

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                              VI-8
                     102nd STREET LANDFILL
Background

This site is  a  20-acre landfill bordering on the Niagara River,
and is owned  by Occidental Chemical and Olin Chemicals.   An
estimated 89,000 tons of chemicals were dumped  at  this  site.
These chemicals include tetrachloroethene, trichloroethylene,
benzene, arsenic,  trichlorophenol, hexachlorocyclohexane(Lindane)
chlorobenzenes,  and  organic phosphates.

On June 26, 1984 Judge John T. Curtin U.S. District  Court
Western District,  State of New York approved the Remedial
Investigation (RI)  Workplan.

The RI is designed  to characterize the nature and  extent of the
presence of chemicals originating from the site  at both  onsite
and offsite locations.  This includes studies of:  the  surficial
soils adjacent  to  the landfill, the groundwater  both  on  and
offsite, the  sediment in the Niagara River, and  any  seeps
through the bulkhead boqdering the landfill.

The data and  conclusions of the Remedial Investigation will be
util'ized to perform  a Feasability Study (FS) to  develop,
evaluate and  select  final remedial action for the  site.
Current Status  and  Schedule

RI field work began in September 1985.

The groundwater  study has  begun and will be continued  for  12  months

The Niagara River  sediment survey, the bulkhead study  and  the
offsite soils investigation will begin in the spring.

The draft RI report is scheduled for compleation by January  1987
at which time the  loading  to the Niagara River will be  estimated.

The FS wll be performed after approval of the RI report.   At  that
time the reduction  in the  loading to the Niagara River  will  be
estimated.

Design and Implementation  of the chosen alternative will take
place after review  and comment by the public and approval  by
the agency.

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                           TABLE      VII
STATUS   OF   PERMIT   ACTIVITIES   FOR








RCRA   HAZARDOUS   WASTE   FACILITIES

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                                                   VII-1

                    TABLE VII --  STATUS  OF PERMIT ACTIVITIES FOR RCRA HAZARDOUS WASTE  FACILITIES

The following  permit,  closure, and post-closure  schedules  are based on current permit  timeframes.
NYSDEC is expected  to  receive final authorization for  permitting shortly.  The State permitting
priorities and schedules  may result in  delaying  some of  the  permit outputs.  In addition,
the Region is  planning to revise the corrective  action timeframes, increasing the amount of
time needed to perform a  site investigation and  remedial investigation.   This action will
delay the public noticing of some draft permits.
NAME

Olin Corp. - Niagara
Falls Plant (2)
NYD002123463

Occidental Chemical Corp.
Niagara Plant
NYD000824482   (3)
Reichhold
NYD002103216
(3)
Battery  Disposal
Technology
NYD000632372 (3)

Bell  Test Center
NY4572024624

Frontier Chemical Waste
Process,  Inc.
NYD043815703  (2)

Enyirotek Ltd.  (2)
              PART B
              REQUESTED

              2/24/82
9/9/82



10/29/82


9/9/82



5/1 3/83


9/9/82



9/9/82
            PART B
            SUBMITTAL

            8/31/82
3/1 7/83



4/29/83


3/17/83




(1 )


3/17/83



3/1 7/83
              DRAFT
              PERMIT

              4/84
                                         1/87
                                         1 2/6/85
                                         6/87
FINAL PERMIT
ACTION	

Final Permit
issued 4/84
    3/86
Buffalo  Color Corp,
NYD080335052   (4)
               11/14/83
             5/24/84
               2/87
COMMENTS

Partial closure  of
container storage
area planned.

Incinerator
facility
Closure  complete
    9/30/85

On-site  storage
and  treatments
                  Undergoing
                   closure

                  Commercial facility
                  Part B revisions
                  12/84, 9/85

                  Complaint for late
                  and incomplete
                  permit application
                  issued 11/85

                  Partial closure
                    planned

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                                             VII-2
NAME

Voelker Analysis,  Inc.
NYD991291782   (2)
PART B
REQUESTED

11/19/83
PART B
SUBMITTAL

5/23/83
 DRAFT
 PERMIT

1 2/86
                                                                   FINAL  PERMIT
                                                                   ACTION
COMMENTS

Commercial
storage/treatment
facility
Allied Corporation  (2)
Love Canal Leachate
Treatment plant
NYD000767657
9/9/82
1 1/22/82
SCA Chemical  Waste Services   2/14/83
(Model City)
NYD049836679   (2), (4)

CECOS  International          2/14/83
NYD080336241   (2), (4)

Bell Aerospace Textron       3/29/84
NYD002106276   (4)
Occidental  Chemical Corp,
Hyde  park
NYD980648281   (4)
Bethlehem  Steel              3/30/83
NYD002134880  (4)
3/17/83


(1 )
 2/24/84   Final  Permit
           Issued  7/84
             8/12/83



             8/16/83


             9/28/84
             3/4/83
             (1 )
               10/87
               4/87-facility
               8/86-SCRF landfill

               4/87
               N/A
           N/A
                             Superfund site - needs
                             no  permit - but must
                             meet RCRA technical
                             requirements.

                             Commercial disposal
                             facility
Commercial disposal
facility

Undergoing
closure -
Post Closure
Permit Required

Superfund site -  needs
no permit - but must
meet RCRA technical
requirements.

Undergoing closure.
Closure/post closure
plans submitted 11/85.
(requirements for
for Post Closure
Permit not finalized).

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                                              VII-3
U.S. Airforce - 914th TAG   12/20/83    6/22/84
NY0570024273  (2)

General  Motors Corp.         3/4/85      9/13/85
Harrison Radiator  Div.
NYD002126852  (2)
                                         9/86
                        1 1/86
                           Storage facility
                                                                     Undergoing
                                                                     Closure/Post
                                                                     Closure Plans
                                                                     submitted.
                                                                     (Requirements
                                                                      for Post Closure
                                                                      Permit not
                                                                      Finalized.)
 Van de Mark  Chemical Corp,
 NYD991290529  (4)
                                                                     Inactive  Landfill
                                                                     undergoing  closure.
                                                                     Closure plan
                                                                     submitted 11/85.
 FMC Corp.
 NYD002126845
               5/24/85
1 1/8/85
7/87
(4)
On-site storage
and surface
impoundment
       LEGEND
       (1)   Application  withdrawn
       (2)   Tank, container  and/or waste pile  facility
       (3)   Incinerator  facility
       (4)   Landfill and/or  surface impoundment

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                                           VII-4
                NARRATIVE SUMMARIES FOR RCRA FACILITIES LISTED IN TABLE VII
Tป  Olin Corporation,   Niagara Falls

    Final RCRA permit issued 4/84 for on-site treatment and storage.   Facility has
    requested permit modification for closure of permitted units and  permitting
    replacement units.

2.  Occidental Chemical Corp. -  Niagara Plant

    Issues;   This facility is applying for a RCRA permit to store and incinerate
             on-site generated wastes as well as to store and incinerate Superfund-
             wastes (including PCB's and dioxins) generated at OCC's  Hyde Park
             landfill.  The required trial burns are currently prohibited by the
             facility's State air and solid wastes permits.  The reported needed
             State permit modifications for the trial burns will take approximately
             one year to complete,  assuming that there is no significant public
             opposition.  The Superfund clean-up of Hyde Park will be slowed down
             by the trial burn delay.  This will cause problems for CERCLA in
             negotiating a final settlement.

    Status:   The Regional Administrator and State Commissioner have discussed
             possibilities of expediting State procedures so that the trial burn
             can occur in the near future.  An EPA Public Notice for  the trial
             burn was issued on 12/2/85 and a Public meeting held on  12/3/85.
             OCC is currently planning for the earliest trial burns to occur in
             the summer of 1986.

    Next Step;  A final State decision on the trial burn phase of the program has
                been made, and OCC has been advised to begin to prepare a draft
                State Environmental Quality Review (SEQR) to cover the trial burns.
                EPA Superfund personnel will negotiate with OCC on final scheduling
                of the Superfund Hyde Park remediation program agreement.

3.  Reichold, Niagara Falls

    Facility completed closure of~storage and treatment units 9/30/85.

4.  Battery Disposal Technology

    Final RCRA permit was issued in April, 1986 for on-site storage and treatment.

5ป  Bell Test Center

    Issues;   Inactive incinerator, storage pad and surface impoundment will be
             closed.  (A Department of Defense site.)  The impoundment is not
             regulated.

    Status;   Original (2/85) Closure Plan was revised and resubmitted in 4/86.

    Next Steps;  Closure Plan review to continue.

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                                           VII-5
6.  Frontier Chemical Waste Process, Inc.

    Issues;   Tliis is a large, complex, commercial facility which has been improperly
             managed and which has contaminated the groundwater.

    Status;   A revised Part B application was submitted on 9/30/85.  A State review
             of the application was received by EPA on 1/7/86 and is under review.
             A State order for an expanded groundwater monitoring system designed to
             assess releases from the plant's operations is being developed.  The
             State has also issued two orders for interim status violations.

    Next Steps;  Tracking of State enforcement follow-up will be carried out by EPA.


7.  Envirotek, Ltd.

    Issues;   This is a commercial storage/treatment facility which has has a number
             of interim status violations.

    Status:   A Complaint was issued by EPA in November 1985 for failure to submit a
             complete Part B application and other interim status violations.  A
             settlement conference was held in January to discuss the EPA complaint.
             A settlement could not be reached with the company and an amended
             complaint was issued in February.

    Next Steps;  An EPA administrative law hearing will be scheduled on the issue in
                 the summer of 1986.  (The facility's interim status violations have
                 also been cited in two State Consent Orders.)  A Site Investigation
                 is to be completed in August 1986.  A major component of the amended
                 complaint is that Envirotek shall immediately cease operating its
                 hazardous waste management units that treat, store or dispose of
                 hazardous waste.

8.  Buffalo Color Corp.

    Issues;— The facility's groundwater monitoring system has recently been expanded
             for the three surface impoundments on site.  The Part B application is
             not complete.

    Status;   Surface Impoundment No. 3 is inactive and will be closed.  The approved
             groundwater system was activated in November 1985.  (This recently
             expanded groundwater system serves to resolve the 3/84 EPA complaint
             issued against BCC.)

    Next Steps;  Enforcement action has been initiated for a late and incomplete
                 Part B.  A Preliminary Assessment will be completed by DEC by the
                 end of 2nd Quarter for prior releases, with a Site Investigation
                 completed by the middle of the fourth quarter.  (Past releases are
                 suspected.)

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                                           VI1-6
 9.  Voelker Analysis, Inc.

     Issues;  This is a commercial storage/treatment facility.  EPA has taken enforce-
              ment action against the company for submittal of an incomplete Part B
              application.

     Status;  A review of the facility's revised application is progressing.  Some
              deficiencies still continue.

     Next Steps;  Voelker is required to submit a revised Part B application in
                  July, 1986.

10.  Allied Corporation

     Final RCRA permit issued 7/84 for on-site treatment and storage.

11.  Love Canal Leachate Treatment Plant

     Issues:  The facility is operated by the DEC to clean-up the Love Canal Superfund
              site.  Contaminated leachate is treated in an activated  carbon system,
              with effluent being discharged to the Niagara Falls municipal wastewater
              treatment plant.  Hazardous waste sludge is a by-product of this treat-
              ment process.

     Status:  Plasma arc technology is planned to destroy the contaminated sludges
              that are generated at the facility.  Development of the  plasma arc
              reactor has been progressing in Canada under contract to the DEC.

     Next Steps;  Future testing schedules and plans for installing the Plasma Arc
                  unit at the Love Canal site are being developed.

12.  SCA, Inc.
     Issues:   This is a large,  complex,  commercial storage/treatment/land disposal
              facility.  The groundwater monitoring system at the site is still not
              adequate.  Past operating performance has been poor, with many penalties
              assessed, particularly for improper management and disposal of PCB's.
              Prior releases from solid waste management units have been reported.

     Status;   An extensive hydrogeologic study (11/84 - 9/85) of the SCA site has been
              reviewed and approved by DEC and EPA.  New well installations have begun.
              Some 15 of the planned 64 new wells around active units (LF No. 11A, B)
              have already been installed.  The remaining well installations were
              interrupted due to seasonal weather disruptions, but will be completed
              by 7/1/86.  Once installed, the 64 new wells will undergo an accelerated
              groundwater sampling program.  An EPA Groundwater Task Force inspection
              report was completed in April, 1986.

     Next Steps;  An EPA/DEC inspection was conducted in December 1985 to investigate
                  new well construction.  Preliminary Assessment work should be
                  completed by DEC within the second quarter of FY 86 while the State's
                  Site Investigation phase is to be done in 7/86.  Start up of a RCRA
                  Remedial Investigation for SCA is planned in February, 1987.  EPA and
                  DEC are presently reviewing the RCRA Part B application.  It is
                  anticipated that a RCRA permit may be issued by December, 1987.

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                                           VII-7
T3.  CECOS International, Inc.

     Issues;   This is a large, complex, commercial storage/treatment/land disposal
              facility.  Two EPA orders are requiring CECOS to implement an expanded
              groundwater monitoring program around landfills No. 1  thru 5.  NYSDEC
              is developing modifications to CECOS1 State Solid Waste permit to expand
              the groundwater monitoring system in other areas of the site.  CECOS is
              planning to construct a new interim status landfill in the center of the
              site, identified as the Secure Chemical Residue Facility (SCRP).  The new
              SCRF landfill will be double lined with leachate collection above and
              between the liners.

     Status;   A revised Part B application was submitted on 9/30/85 for the entire
              facility.  The design of the planned, new Secure Chemical Residue
              Facility (SCRF) landfill has also recently been revised.  This revised
              design is being reviewed for compliance with the Hazardous and Solid
              Waste Acts' Minimum Technology Standards.  New well installation is
              progressing per EPA's 3008 & 3013 Orders.

     Next Steps;  Initial review of the revised design for the new SCRF landfill was
                  completed on 2/14/86, and CECOS has been requested to submit
                  additional information.  EPA/DEC inspected well installations in
                  December 1985 and found the well system associated with the active
                  unit (#5) to be in compliance with the Loss of Interim Statu^
                  requirement.  A comprehensive sampling and analysis program for
                  groundwater monitoring has just begun.  A preliminary assessment will
                  be completed by EPA in June, 1986.  A site investigation will be
                  pursued by CECOS, with a workplan to be developed by June, 1986.  A
                  Groundwater Task Force inspection is targeted for the middle of 1986.

1 4.  Bell Aerospace Textron

     Issues;   Significant groundwater contamination has been detected on-site as a
              result of releases from, as yet, unknown numerous sources.  The only
              regulated unit, a surface impoundment, was shut down and will be closed.

     Status;   An expanded groundwater monitoring program is being worked out in final
              form to investigate the character and extent of the contamination.  DEC
              currently plans to public notice the approved closure plan this summer.

     Next Steps;  After final closure plan approval, post closure activities will be
                  monitored.  Finalization of the groundwater assessment plan should
                  occur shortly.  A preliminary Exposure Information Report was sub-
                  mitted by Bell in December 1985.  A Preliminary Assessment will be
                  done by DEC in the 2nd quarter of FY 87 and a Site Investigation
                  should be completed in the 3rd quarter.

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                                           VII-8


15.  Occidental Chemical Corp. - Hyde Park

     Issues;  This is a new facility to be constructed for remediation of OCC's Hyde
              Park Superfund site.  Contaminated leachate from the OCC Hyde Park
              landfill will be stored and treated at this facility with a portion,
              the non-aqueous phase liquid (NAPL) planned to be incinerated at OCC's
              Niagara Plant.

     Status;  Part B application review has progressed to the point where some
              information, concerning an additional storage tank at the site,
              remains to be submitted.

     Next Steps;  Remedial action for this site is dependent on the Superfund  Agreement
                  which has been negotiated between EPA and OCC.  The Agreement/clean-up
                  will probably not proceed without some preliminary approval  of OCC's
                  Niagara plant incinerator as a disposal alternative.

16.  Bethlehem Steel Corp.

     Issues;  BSC is regrading their entire shore front property for the purpose of
              constructing an industrial park.  Three RCRA inactive landfills  are
              located in this area.  An adequate groundwater monitoring program has
              been implemented at the site.  However, the closure/post closure plans
              have not been developed.  BSC is seeking ani official delisting determin-
              ation for wastes in two of the landfills.

     Status;  Under the EPA Consent Order, signed 8/85, BSC submitted a closure/post
              closure plan on November 23, 1985.  An October 1985 groundwater  report
              submitted by BSC, regarding new well installation and accelerated
              monitoring (from 2/85 thru 8/85), has been reviewed.  As a result of
              this review, EPA is requiring BSC to initiate additional groundwater
              monitoring.  A temporary cover for one landfill will be installed in
              the summer of 1986 until the delisting determination is made.

     Next Steps;  Delisting petition as well as the closure/post closure plan are
                  being reviewed by EPA.

17*  U.S. Air Force - 914 Tactical, Niagara Falls

     Draft RCRA permit due 9/86 for on-site storage and treatment.

18.  GMC, Harrison Radiator

     Undergoing closure of waste piles.  Post closure permit required.  Closure plan
     scheduled for public notice 9/86.

1 9.  Van De Mark Chemical

     Inactive landfill undergoing closure.  Unit is not subject to post closure permit.

20.  FMC Corp.

     RCRA permit being developed for on-site container storage and storage surface
     impoundment.  Draft RCRA permit due 7/87.

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