&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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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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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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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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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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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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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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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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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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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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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)
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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.
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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.
-------
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.
-------
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.
-------
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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