REDUCTION OF
TOXICS LOADINGS TO
THE NIAGARA RIVER FROM
HAZARDOUS WASTE SITES
IN THE UNITED STATES:
JUNE 2002
A Report by the United States Environmental Protection Agency
and the New York State Department of Environmental Conservation
JUNE 2002

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                              TABLE OF CONTENTS

Executive Summary
Introduction	1
Summary of Remediation Progress	7
      Overview of Remediation Status	7
      Highlights of Recent Actions	7
      Estimated Remediation Costs	14
Acronyms	15
Glossary	16
References	21
Appendix: Priority Niagara River Hazardous Waste Sites

      Occidental Chemical Corporation, Buffalo Avenue	A-l
      Niagara County Refuse Disposal	A-8
      DuPont Necco Park	A-l 1
      CECOS International	A-l5
      Occidental Chemical Corporation, Hyde Park	A-l9
      102nd Street	A-26
      Bell Aerospace Textron	A-29
      Occidental Chemical Corp., Durez Division, Niagara Falls (formerly BTL Specialty).A-32
      Occidental Chemical Corporation, S-Area	A-35
      Stauffer Chemical	A-40
      Solvent Chemical	A-42
      Vanadium Corporation of America (formerly SKW Alloys)	A-44
      Olin Corporation	A-47
      DuPont, Buffalo Avenue	A-51
      Buffalo Color Corporation	A-53
      Buffalo Color Corporation, Area D	A-56
      Bethlehem Steel Corporation	A-58
      River Road (INS Equipment)	A-61
      Niagara Mohawk - Cherry Farm	A-63
      Frontier Chemical, Pendleton	A-65
      Frontier Chemical, Royal Avenue	A-67
      Occidental Chemical Corporation, Durez Division, North Tonawanda	A-70
      Gratwick Riverside Park	A-73
      Mobil Oil	A-76
      Iroquois Gas-Westwood Pharmaceutical	A-79
      Booth Oil	A-82

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                               EXECUTIVE SUMMARY

Since 1987, the Niagara River has been the focus of attention for four environmental agencies in the
United States and Canada ("The Four Parties").  In a Declaration of Intent, the  Four Parties
committed to reducing toxic chemical  inputs to the Niagara River.  Hazardous waste sites were
considered the most significant  non-point source of toxics to the river.   Therefore, the U.S.
Environmental Protection Agency (EPA) and  New York State Department  of Environmental
Conservation (DEC) identified 26 U.S. sites responsible for over 99% of the estimated input from
all such sites on the U.S. side of the basin, and put them on ambitious remediation schedules.
Remediation of the sites is intended to virtually eliminate the migration of toxic pollutants from the
sites.
All remedial construction has been completed at
16 of the sites. The remedial technology will be
operated and monitored for effectiveness for
years to come at those sites. Remedial Actions
(RAs) are underway at 7 sites.  Four of these are
interim remedies, including 3 sites under interim
remediation while final  remedies are  being
designed or investigated, and one site  where an
interim  RA was  completed  and an  effort to
identify  potentially   responsible  parties  is
underway.  At 5 of the 7 sites where RAs are
underway,  significant  remedial  controls  are
already operating. For many of these  sites, the
load reductions are substantial. The remaining
sites are under design or study.

Based on various simplifying assumptions, EPA
estimates that remediations to date have reduced
the  potential  inputs  into   the  river  by
approximately  90%   This estimate  is  based
primarily on the  sites  where  the final  RA is
completed.   It does  not include  the  load
reductions  at all  the  sites  where  remedial
controls are operating, though the reductions
may be  substantial.   Therefore,  the  actual
reductions to date may exceed 90%. Through 2003, completion of RAs is expected at four more
sites, summarized below.

Recent accomplishments in remediation of the priority waste sites include the following:
REMEDIATION OF U.S. HAZARDOUS WASTE SITES
16 SITES ARE  COMPLETED:
  CECOS (Niagara Falls)
  Bell Aerospace Textron (Niagara Falls)
  Occidental Chem. Durez (Niagara Falls)
  Stauffer Chemical (Lewiston)
  DuPont Buffalo Ave (Niagara Falls)
  Frontier Chemical (Pendleton)
  Occidental Chem. Durez (North Tonawanda)
  Olin Corporation (Niagara Falls)
  Buffalo Color Area D (Buffalo)
  Occidental Chem. Buffalo Ave (Niagara Falls)
   102nd Street (Niagara Falls)
  River Road (Tonawanda)
  Niagara Mohawk Cherry Farm (Tonawanda)
  Niagara County Refuse Disposal (Wheatfield)
  Iroquois Gas-Westwood Pharmac. (Buffalo)
  Gratwick Riverside Park (North Tonawanda)
7 SITES WHERE REMEDIATION IS UNDERWAY:
  DuPont Necco Park (Niagara Falls)
  Occidental Chem. Hyde Park (Niagara Falls)
  Mobil Oil (Buffalo)
  Occidental Chem. S-Area (Niagara Falls)
  Frontier Chemical Royal Ave (Niagara Falls)
  Vanadium Corporation (Niagara)
  Solvent Chemical (Niagara Falls)
Gratwick Riverside Park - Remedial construction started in June  1999, and was substantially
completed in November 2001.

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Iroquois Gas-Westwood  Pharmaceutical - All remedial construction at  the plant site was
completed September 1997, including sheet piling barrier wall,  groundwater extraction wells,
groundwater and non-aqueous phase liquid (NAPL) treatment, and a clay cap. Remediation of
Scajaquada Creek sediments commenced in July 1998 and was completed in March 1999.  The
second extraction system was completed in August 2000 and commenced operation for NAPL
extraction in December 2000.

Through 2003, completion of final RAs are expected at the following sites:

Solvent Chemical - Construction of the groundwater extraction and treatment systems were
completed in 2001. The groundwater extraction/treatment system will be operational in 2002. A
performance monitoring program will begin in 2002.

Occidental Chemical Corporation (OCC), S-Area - The construction of the final OCC S-area
Landfill cap commenced in August 2000 and should  be completed by the end of the spring or
summer of 2002.  Construction activities for the year 2003 include  the  remaining bedrock
monitoring programs as well as the design, installation and evaluation of the Phase III (final)
Bedrock System at both the OCC S-Area and formerNiagara Falls Drinking Water Treatment Plant
(DWTP) property.

Occidental Chemical Corporation, Hyde Park- A report examining the need for further remedial
measures was submitted in draft form by OCC to EPA and DEC in February 2002.  Data indicated
groundwater capture of 88% in the upper bedrock, and  100% in the middle and lower layers. Two
of the wells OCC installed in 2001 were drilled deeper in order to better intercept groundwater flow
zones.  This spring, OCC will retrofit monitoring wells  with 3 one-inch PVC pipes in the four-inch
wells to better delineate the groundwater capture. Completion of all remedial systems is expected
by September 2002, with RAs expected to be complete by September 2003.

Booth  Oil - After lengthy  negotiations between the DEC and the Booth Oil Site Administrative
Group (BOSAG), a group of potentially responsible parties, a final agreement for site remediation
is near. The agreement will include remedial design, which is expected to be completed by August
2002, followed by remedy implementation. Should the proposed amendment be deemed acceptable,
construction is expected to commence in the Fall of 2002 and be completed by June 2003.

Other significant updates since the October 2000 report include:

Vanadium - DEC and Airco negotiated an Interim Remedial Measure (1RM) to cap the landfill on
their portion of the site.  Closure of the Airco portion of the site (Operable Unit No. 2) was
completed by December 2000.

Buffalo Color Corporation (BCC) - The Corrective Measures Study (CMS) was approved in July
2000. The remedy selection was expected to be public noticed in  February 2002 and finalized in

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May 2002, with Corrective Measures Implementation (CMI) start-up expected in March 2003.
However, the implementation of the final remedy will be delayed indefinitely due to the Financial
status of the company. If BCC declares bankruptcy, the responsibility for implementing the remedy
may be transferred to another State or Federal program.

DuPont, Necco Park - RA completion is expected by November 2005. Because of the fractured
bedrock  beneath the site, future  complications may arise in  achieving  effective hydraulic
containment. The target date is intended to allow sufficient time to ensure the completion of any
additional remedial work required to achieve effective containment, as well as system testing and
optimization. It is also important to note that remedial actions already implemented on-Site have
resulted in an estimated load reduction from the Site of approximately 27-55%.

Estimates of the cost of remediation are available for most of the 26 priority hazardous waste sites.
Based on these estimates, the costs incurred to date are at least $ 382,000,000. Additional costs
expected in the future are estimated at $ 249,200,000.
                                           in

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INTRODUCTION
                  THE FOUR PARTIES
     U.S. ENVIRONMENTAL PROTECTION AGENCY (EPA)
              ENVIRONMENT CANADA (EC)
NY STATE DEPT OF ENVIRONMENTAL CONSERVATION (DEC)
       ONTARIO MINISTRY OF ENVIRONMENT (MOE)
Since 1987, the Niagara River has
been the focus of attention for four
environmental agencies in the U.S.
and  Canada,  called  "The  Four
Parties".  The Four Parties signed a
Niagara River Declaration of Intent,
pledging  cooperation to achieve
significant reductions of toxic chemical pollutants in the Niagara River. The Declaration of Intent
and a work plan form the Niagara River Toxics Management Plan (NRTMP).

Under the NRTMP, the Four Parties identified 18 persistent toxic chemicals as "priority toxics".
Actions to reduce the inputs of these priority toxics to the Niagara River have been aimed at point
                                            sources and non-point sources. Significant point
                                            sources on both sides of the Niagara River have
                                            been  identified and are being addressed in U.S.
                                            and Canadian  point  source  plans.   The Four
                                            Parties summarize progress in controlling point
                                            sources in an annual  report, last  issued in June
                                            2000 (Niagara River Secretariat, 2000).

                                            Non-point sources of toxic chemicals  to  the
                                            Niagara River (e.g.,   leachate  from  hazardous
                                            waste sites, storm water runoff,  atmospheric
                                            deposition) are more  difficult  to quantify and
                                            control. Given the limited information available
about non-point sources, the U.S. has proceeded with its actions based on the assumption that
hazardous waste sites are the most significant non-point sources of toxic chemicals to the Niagara
River.

In 1988, an EPA study estimated potential toxic pollutant loadings to the Niagara River from U.S.
hazardous waste sites (Gradient Corp/Geotrans Inc 1988). All known U.S. waste sites in the Niagara
River area  were  considered.  To help EPA/DEC focus actions on the sites that  have the most
significant potential for polluting the Niagara River, the report produced a list of 70 most-significant
U.S. sites. The agencies treated the 70 sites as 33 site clusters, largely based on the manner in which
data have historically been collected. Figure 1 shows the locations of these 33 clusters, and several
additional hazardous waste sites.

The study showed that an estimated 694 lbs/day(315 kg/day) of toxic chemicals have the potential
of migrating from hazardous waste sites to the Niagara River. Because collection  of site-specific
transport data is ongoing, estimates were made based on certain assumptions, e.g., that groundwater
flow is horizontal, and that pollutants behave in a conservative manner.  These assumptions yielded
NRTMP PRIORITY
Benz(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Chlordane
Chrysene
Dieldrin
Hexachlorobenzene
Mercury
Toxic CHEMICALS
Mirex
Octachlorostyrene
PCBs
DDTs
Dioxins
Tetrachloroethylene
Arsenic
Lead
Toxaphene

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conservative estimates (i.e., estimates of toxic loadings that are expected to be higher than the actual
loadings).

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         Late Ontario
                                        66
                                   41b/78   242
    Frontier Chemical-
       Royal Ave.
Booth Oil Site
                           Niagara flive,-
      APPROXIMATE SCALE

024            8 MILES
 NOTE:  First number only is given tor site areas
       with multiple site numbers.

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Figure 1: LOCATION OF SIGNIFICANT NIAGARA RIVER HAZARDOUS WASTE SITES
                              Figure 1: LEGEND
      USGS SITE NUMBERS
               SITE NAME
                        4lb-49
                            81
                            14
                         78a,b
                            39
                   40,56,85,94*
                             5
                            66
                           41a
                           255
                           251
                             1
                     58,59,248
                     15-19,250
                           254
                       120-122
                           118
                           136
                            67
                         24-37
                           253
                            68
                           141
                           162
                           242
                            22
                           182
                           241
                           108
                           107
                           207
                       125-127
                           123
                            38
                      9-15-141
Occidental Chemical Corp. (OCC), Buffalo Ave.
Niagara County Refuse Disposal
DuPont Necco Park
CECOS International/Niagara Recycling
OCC, Hyde Park
102nd Street
Bell Aerospace Textron
OCC, Durez, Niagara Falls (formerly BTL)
OCC, S-Area
Stauffer Plant (PASNY)
Solvent Chemical
Vanadium Corp. (formerly SKW Alloys)
Olin, Buffalo Avenue
DuPont, Buffalo Avenue Plant
Buffalo Harbor Containment
Buffalo Color Corporation, including Area D
Bethlehem Steel Corporation
River Road (INS Equipment)
Frontier Chemical, Pendleton
OCC, Durez, North Tonawanda
Small Boat Harbor Containment
Gratwick Riverside Park
Mobil Oil
Alltift Realty
Charles Gibson
Great Lakes Carbon
Niagara Mohawk Cherry Farm
Times Beach Containment
Tonawanda Coke
Allied Chemical
Tonawanda Landfill
Dunlop Tire and Rubber
Columbus-McKinnon
Love Canal
Iroquois Gas/Westwood Pharmaceutical
     Occidental 102nd Street site (#40), Olin 102nd Street site (#56), Griffon Park (#85),
     and Niagara River Belden site (#94)

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In November 1989, EPA and DEC issued a report prioritizing the 33 hazardous waste clusters in
order of their potential for polluting the Niagara River (EPA/DEC 1989). Table 1 presents the 33
clusters divided into three categories, based on Gradient/Geotrans estimates of their potential toxic
loads to the Niagara River.  These categories are as follows:

       Category I:    Sites with loading greater than 50 Ib/day
       Category II:   Sites with loadings from  1 to 50 Ib/day
       Category III:  Sites with loadings less than 1  Ib/day

Sites from Category I  and II collectively represented 99.9% of the total estimated loadings.

In keeping with the strategy to reduce inputs from the sites with the potential for contributing the
largest amounts of pollutants to  the Niagara River, the  EPA/DEC report presented ambitious
remediation schedules for Category I  and  II sites.  The report's best estimates indicated that if
remediation schedules were met, potential  inputs of all toxic chemicals from these sites to the
Niagara River would be reduced by 99% by 1996. However, the 1989 schedules were estimates
based on limited knowledge of site conditions and average negotiation periods with Potentially
Responsible Parties (PRPs). Lengthy legal proceedings with PRPs or unanticipated complex site
conditions have since resulted in delays.  Consequently,  many of the sites have exceeded their
original 1996 targeted completion date. The circumstances surrounding these delays are summarized
below and described in more detail in the site-specific reports contained in the Appendix.

Since 1989, EPA and DEC have also reevaluated the hazardous waste sites to identify those that new
information shows are significant sources of toxic chemicals to the Niagara River. Two sites have
been removed as insignificant sources of toxics, and four sites have been added  as significant
sources. This update reports on remediation progress at the resulting 26 significant hazardous waste
sites.

The EPA estimates that site remediations have to date achieved a reduction of approximately 90%
in potential toxic chemical inputs from all sites to the Niagara River. The estimate is based on the
percentage of RAs in place at some of the 23 sites with completed or on-going remediation (Table
2).  A 100% reduction was assumed for 13 of the 16 sites with all RAs in place. For one site, it was
estimated that up to 1.5% of the site's toxic chemical load may be continuing after remediation; this
limitation is included in the overall load reduction estimate. A percentage reduction  was estimated
for two other sites with partial implementation of RAs. Since estimates could not be  made for most
of the sites with on-going remediation, actual reductions to date may be greater than the estimated
90%. Remedial systems, e.g., groundwater pump-and-treat systems, are functioning at 6 of the 7
sites where remediation is underway and are expected to have already reduced  off-site loadings.
Table 2 identifies the sites where remediation  is not yet completed, but which have operational
remedial systems that are expected to have reduced contaminant loads to the Niagara River.

Completion of final RAs are expected at  several additional sites through 2003.  Based on the
expected implementation of these RAs, EPA's best estimates are that, by the end of 2003, the

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estimated toxic chemical inputs from all sites will be reduced by almost 95% from the 1989 inputs.
Current schedules call for all sites to be remediated by 2005.

Estimates have recently been made of the potential loadings of the NRTMP priority chemicalsto the
Niagara River from priority waste  sites.  The estimates are based on information that was not
available when the Gradient/Geotrans estimates were developed, such as information on chemical
concentrations in groundwater and groundwater flow. For example, a report by several site PRPs
addressing groundwater loadings for ten of the NRTMP priority waste sites estimated priority
chemical loadings from ten sites at 5.6 Ibs/day (2.5 kg/day)  pior to RA, and 0.0048 Ibs/day (0.002
kg/day) after RA completion, a reduction of over 99%  (CRA  1998). Since these estimates only
consider the NRTM P priority chemicals, they are not comparable to the Gradient/Geotrans estimates
of total toxic chemical loading.  In addition,  the report also  used some assumptions (i.e. non-
conservative assumptions) that would tend  to reduce load estimates.  Therefore,  although actual
loadings are probably greater than the estimates, the estimates do corroborate the reduction in toxic
chemical loadings to the Niagara River achieved through remedial programs.

In addition to remediation efforts at the waste sites themselves,  it is also important to recognize the
role of the Niagara Falls Waste Water Treatment Plant (WWTP)  in reducing toxic inputs  from a
number of waste sites to the Niagara River.  Based on information available  in 1987, the U.S.
identified the Falls Street Tunnel, a  major unlined industrial sewer cut into the bedrock under the
City of Niagara Falls, as the largest source of toxic pollutants from any of its point sources.  By the
mid-1980s, the Tunnel was only receiving overflows of wastewater from the sewers of a Niagara
Falls industrial area, in addition to contaminated groundwater infiltrating from major waste sites via
cracks in the Tunnel's bedrock walls.  In contrast to flows from other point sources, effluent from
the Falls  Street Tunnel entered the Niagara  River untreated. In 1993, EPA and DEC  required the
City of Niagara Falls to treat the Falls Street Tunnel discharges during dry weather at the Niagara
Falls WWTP. Data gathered by the U.S. indicate that WWTP treatment of the Tunnel's dry weather
discharge has reduced mercury loadings by 70% relative to 1980  loads, tetrachloroethylene loadings
by 85%, and the loadings of four other priority toxic chemicals by almost 100% .

Since the Falls Street Tunnel captures portions of the upper Lockport bedrock groundwater flow
from seven hazardous waste sites, the actions taken to control discharge from the Tunnel reduce
loadings  from the following sites:

       DuPont, Buffalo Avenue                                Solvent Chemical
       OCC, Buffalo Avenue                                  CECOS International
       Frontier Chemical, Royal Avenue                        DuPont Necco Park
       OCC, Durez, Niagara Falls

For this report, estimates of site loading reductions do not include those obtained through treatment
of the Falls Street Tunnel dry weather flow.

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                                     TABLE 1
              Gradient/Geotrans Prioritization of Waste Sites According to
                   Potential Toxic Loadings to Niagara River in 1988

Category I;  greater than 50 Ib/dav

Occidental Chemical Corporation, Buffalo Ave.
Niagara County Refuse Disposal
DuPont Necco Park
CECOS International
Occidental Chemical Corporation, Hyde Park

Category II;  between 1-50 Ib/dav

Occidental Chemical Corporation, 102nd Street
Bell Aerospace Textron
Occidental Chemical Corporation, Durez, Niagara Falls (formerly known as BTL Specialty Resins)
Occidental Chemical Corporation, S-Area
Stauffer Plant (PASNY)
Solvent Chemical
Vanadium Corp. (formerly SKW Alloys)
Olin, Buffalo Avenue Plant
DuPont, Buffalo Avenue Plant
Buffalo Harbor Containment
Buffalo Color Corporation, including Area D
Bethlehem Steel Corporation
River Road (INS Equipment)
Frontier Chemical, Pendleton
Occidental Chemical Corporation, Durez, North Tonawanda
Small Boat Harbor Containment
Gratwick Riverside Park
Mobil Oil

Category III; less than 1 Ib/day

Alltift Realty                     Dunlop Tire and Rubber
Charles Gibson                   Columbus-McKinnon
Great Lakes Carbon               Love Canal
Niagara Mohawk, Cherry Farm
Times Beach Containment
Tonawanda Coke
Allied Chemical
Tonawanda Landfill

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                     SUMMARY OF REMEDIATION PROGRESS


OVERVIEW OF REMEDIATION STATUS

Table 2 and Figure 2 give overviews of remediation status at the 26 waste sites. In summary:

•     All remediation is in place at 16 of the sites.  The remedial technology installed at the 16
      sites will be operated and monitored for effectiveness for years to come.

•     RAs are underway at 7 sites.
             4 of these are interim remedies, including 3 sites under interim remediation while
             final remedies are being investigated or designed, and one site where an interim RA
             was completed and PRP search efforts are underway.
             Construction of the final remedy is underway at 3 sites.

•     RAs are under design or  investigation at 6 sites (including 3 of the sites under interim RA).

Remedial systems are functioning at 5 of the 7 sites where remediation is underway, and these
systems are expected to have already reduced the off-site loadings.


HIGHLIGHTS OF RECENT ACTIONS

For each site, a detailed description of progress is provided in the Appendix. Highlights of progress
made, in particular since  the October 2000 progress report, are summarized below.

Niagara County Refuse Disposal

      Remedial construction began in November 1998.  The remedy includes a perimeter clay
      barrier wall, leachate collection with off-site treatment and disposal, removal of field tile
      drains to the west of the  landfill, a final landfill cap, and other actions.
•     Installation of the leachate collection system and its tie-in to the City of North Tonawanda
      sanitary sewer has been completed. The leachate collection has been operational since the
      summer of 1999,  thus eliminating any potential pathway for leachate to migrate off-site.
      The final Remedial Action Report was approved  in December 2000 and operation and
      maintenance activities commenced.  Groundwater monitoring supports that the remedy is
      effective and operating as designed.

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                                        TABLE 2
                            STATUS OF SITE REMEDIATIONS
INVESTIGATION AND DESIGN:

Potentially Responsible Party fPRP)
Search

none

Site Investigation Underway

Bethlehem Steel Corporation
Frontier Chemical, Royal Avenue1
VANADIUM CORPORATION2

Remedial Design (RD) Underway

Booth Oil3
Buffalo Color Corporation
DUPONT NECCO PARK
REMEDIATION:

Remediation Underway:

   Interim Remedy In Place or Under Construction:

   MOBIL OIL
   Frontier Chemical, Royal Avenue1
   VANADIUM CORPORATION2
   DUPONT NECCO PARK

   Construction of Final Remedy Underway

   OCC, S-AREA
   OCC, HYDE PARK
   SOLVENT CHEMICAL

Remediation Completed (O&M Underway)

Stauffer Chemical
Frontier Chemical, Pendleton
Bell Aerospace Textron
CECOS International
OCC, Durez, Niagara Falls
OCC, Durez, North Tonawanda
DuPont Buffalo Avenue
Olin Plant Site
Buffalo Color, Area D
OCC, Buffalo Avenue
102 Street (Olin/OCC)
River Road
Niagara Mohawk, Cherry Farm
Niagara County Refuse Disposal
Iroquois Gas-Westwood Pharmac.
Gratwick Riverside Park
The sites in interim remediation are also under investigation or design, and therefore are listed twice

        Sites in bold have achieved progress since the October 2000 report.

       These sites, though not completed, have operational remedial systems that are expected
              to have reduced contaminant loadings to the Niagara River.

1  A major Superfund Response Action was completed in 1995.  A PRP search is underway, to be
followed by negotiation of an Remedial Investigation/Feasibility Study (RI/FS) order. Notice letters
were issued to PRPs in December 1999.
2  Preliminary investigations were completed. An Interim Remedial Measure (IRM) was completed by
one PRP; an IRM by another PRP is under construction.
3  RI/FS completed. Negotiations on a legal agreement for performance of the RD/RA are continuing.

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Figure 2: STATUS OF SITE REMEDIATIONS
                   Construction of Final Remedy (3)
                  Interim Remedy (4)
               Remedial Design (3)
                                                                                     Final Remedy In Place (16)
                        Site Investigation (3)
    (Number of sites in parentheses)
    No sites are currently under PRP Search. The four sites under Interim Remedy are also under investigation or design, and thus are counted twice.
                                                         10

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DuPont. Necco Park

       Remedial Design (RD) is underway, including the installation of additional groundwater
       wells, which began in September 2000. The wells will serve as component parts of the
       hydraulic containment portion of the Final Remedy.
       Construction of the Final Remedy began November 2001. The following are among the
       measures included in the Final Remedy:
              Upgrading the existing cap;
              Containment of the overburden source area using hydraulic measures or a physical
              barrier;
              Containment of the bedrock  source area using hydraulic measures;
              Treatment of the extracted groundwater on-site or off-site;
              Collection and off-site disposal of DNAPL;
              Comprehensive monitoring and additional site characterization.
       RA completion is expected by November 2005. This date has been extended from October
       2003 due to the time  needed to resolve issues which arose with DuPont regarding the
       interpretation of New  York State's  landfill regulations on how to design the landfill cap
       upgrade. Because of the fractured bedrock beneath the site, future complications may arise
       in achieving effective hydraulic containment.  The target date is intended to allow sufficient
       time to ensure that any additional remedial work to achieve effective containment can be
       completed, and that the system is tested and optimized.

Occidental Chemical Corporation. Hyde Park

       Though the RA  is not completed, the remedial systems are already containing most of the
       contaminated groundwater on site, thus greatly reducing the potential contaminant loading
       to the Niagara River. All of the overburden groundwater is being contained and in the three
       bedrock groundwater zones, approximately 96% of the contaminated groundwater is being
       contained. Remedial work to achieve full containment is continuing.
       In  1997, Phase III of the bedrock groundwater extraction system was installed (pumping and
       monitoring wells, and force mains  connecting the wells to the on-site treatment plant).
       However, complex site conditions and difficulties in pumping NAPL resulted in the need to
       install additional wells.  Three pumping wells and associated monitoring wells and force
       mains were installed in 1998. Three additional pumping wells and associated monitoring
       wells and force mains were installed in 1999;   one additional pumping well and five
       monitoring wells were installed in 2000.
•      OCC still did not achieve all required inward hydraulic gradients when the additional wells
       were installed in 2000. Therefore, OCC created a groundwater model to better understand
       groundwater flow in the site vicinity.  Model output was utilized to place four additional
       wells in 2001. Also, a NAPL recovery well was converted to an extraction well. OCC will
       use the model to determine if the operation of these five additional wells, in conjunction with
       existing remedial system, will capture 100% of the contaminated groundwater, or if further
       remedial measures will be necessary. In February 2002, OCC submitted a draft data report
                                           II

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       to EPA and DEC. The report indicated groundwater capture of 88% in the upper bedrock
       and 100% of the middle and lower bedrock layers. OCC drilled 2 of the wells they installed
       in 2001 deeper, to better intercept groundwater flow zones.
       Hydrogeologic studies conducted in 2000 and 2001 have shown that the three-bedrock- layer
       system  is oversimplified and that there are eleven discrete flow zones in the bedrock. To
       improve the monitoring system, OCC is currently retrofitting existing 4-inch monitoring
       wells by installing three one-inch PVC pipes in each well.  The one-inch wells will be
       screened to monitor the individual flow zones to better delineate the groundwater capture.
       Completion of all remedial systems is expected by September 2002, and RA completion is
       expected by September 2003
       Sampling of fenced groundwater seeps in the Niagara River Gorge Face was conducted  in
       1997,  1998 and 1999.  Results continue to  indicate no need  for additional control or
       remediation of the seep areas.

Bell Aerospace Textron

       Corrective Measurement Implementation (CMI) started in 1995.  The on-site system has
       since been enhanced by the installation and operation of an additional groundwater extraction
       well in  1998, including the use of a higher capacity pump in August 1999, and the change
       of pump heads in two extraction wells in April 2000.  These enhancements have produced
       a consistent capture zone, and the system has been achieving its design goals. No significant
       operational change was reported during the first quarter of 2002.

Occidental Chemical Corporation. S-Area

•      The drain collection system and cap for the old Niagara DWTP property were completed  in
       1999.
•      Operation of the drain collection system for the landfill portion of the site began in 1996;
       however, a portion of the system was improperly installed and did not function as designed.
       The system was subsequently replaced in  1999-2000, delaying completion of the RA.
       Construction of the final landfill cap began in August 2000.
•      Securement of the raw water intake structure from the old DWTP began in August 2000.
•      Construction of the final S-area Landfill  cap commenced in August 2000 and should be
       completed by the end of the spring or summer of 2002. ,
       Construction activities for the  year  2003  include the remaining bedrock  monitoring
       programs as well as the design, installation and evaluation of the Phase III (final) Bedrock
       System at both the OCC S-Area and former Niagara Falls DWTP.

Solvent Chemical

       Construction of the groundwater extraction and treatment systems were completed in 2001.
       The groundwater extraction/treatment system will be operational in 2002.
       A performance monitoring nropram will heain in 7007
A performance monitoring program will begin in 2002.
                                          12

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Vanadium Corporation

       In November 1998, one of the site PRPs (SKW Alloys) completed an IRM to cover portions
       of their parcel and control site stormwater runoff.
•      DEC and Airco negotiated an IRM to cap the landfill on their portion of the site. Closure of
       the Airco portion of the site (OU No. 2) was completed by December 2000.
       Negotiations with the PRPs have not resulted in an Order of Consent requiring that a site-
       wide Remedial  Action/Feasibility  Study  (RA/FS)  be undertaken.   DEC  will open
       negotiations with Niagara Mohawk Power Corporation and the New York Power Authority
       to address their portion of the site.

Buffalo Color Corporation

       The Corrective Measures Study (CMS) was approved'in July 2000. The remedy selection
       was expected to be public noticed in February 2002 and finalized in May 2002, with CMI
       start-up expected in March 2003. However, the implementation of the final remedy will be
       delayed  indefinitely due to the financial status of the company. Should BCC declare
       bankruptcy, the responsibility for implementing the remedy may be transferred to another
       State or Federal program.

Bethlehem Steel Corporation fBSO

•      BSC has completed the field work for the site investigation, and is preparing Resource
       Conservation and  Recovery Act Facility Investigation  (RFI) and  human  health  risk
       assessment reports. These have been delayed due to negotiations over the scope and the need
       to collect additional data. Submittal of these reports is anticipated by July 2002.
       BSC completed limited remedial technology studies  for two areas that appear to be the
       primary sources of groundwater contamination at the facility (the Acid Tar Pits and Coke
       Oven Areas). The EPA and DEC found the studies to be technically flawed and of limited
       value. BSC continues to study various potential remedial technologies.
•      BSC has submitted a Pre-design Investigation Report for the remediation of the Benzol Plant
       Area (i.e., Coke Oven Area). However, a dispute over waste characterization has delayed
       implementation.
       BSC submitted an application for the construction of a Corrective Action Management Unit
       (CAMU) at its facility in November of 2000. The application was approved as substantially
       complete and BSC submitted a 30% design document.
       A portion of the BSC site was selected as a RCRA brownfield pilot project in March of 2000.
       The focus of the project is to make  approximately 102 acres of the facility available for
       potential redevelopment. The 102 acres has been released from the RCRA RFI Order to
       allow the property to be addressed under alternative programs.
       BSC declared Chapter  11 bankruptcy in October 2001.
•      BSC closed the coking plant and ceased coke production at the Lackawanna facility in the
                                           13

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       Fall of 2001
       Any future CMS or CMI activities will require a new order, permit or other agreement.

Frontier Chemical. Royal Avenue

       The company that owned the facility went bankrupt in 1992, and failed to implement a DEC
       Order for waste removal. The site was referred to Federal Superfund for a Response Action
       that including the removal of thousands of drums, removal of wastes from 45 tanks on the
       site, and other actions.  The action was completed in 199S.
       EPA  ruled not to include the site on the National Priorities List.
       DEC initiated PRP search efforts in 1998. The efforts are to be followed by negotiations of
       an RI/FS Order to address soil and groundwater contamination.
       DEC finalized the list of PRPs and issued notice letters to  the PRPs in December 1999.
       In January 2001 the site  was referred for RI/FS action  under the NY State Superfund
       program. The Focused Remedial Investigation was begun in 2001. The RI/FS is expected
       to be completed in 2002, with a  final Record of Decision (ROD) expected in early 2003.

Gratwick Riverside Park

•      Remedial Design started in early 1996. The design includes shoreline protection, a hydraulic
       (slurry wall) barrier between the site and Niagara River,  a  cap over the site to allow it to be
       used  as a park, and collection of contaminated groundwater.
•      During design, some site-related contamination was found in Niagara River sediments.  It
       was also determined that steps should be taken to improve  the habitat value of the shoreline
       area.
       Design changes to address these issues were addressed as a ROD amendment issued  in
       January 1999.
       Remedial construction  started in June 1999, and was substantially completed in November
       2001.

Mobil Oil

       Following site investigations in the 1980s, DEC re-classified a 3-acre area of concern on the
       site as Class 3 (does not present significant threat to public  health or the environment; action
       may  be deferred).
        In 1994, the entire Mobil facility was selected for DEC's Multi-Media Pollution Prevention
       (M2P2) program.
       A multi-media inspection was conducted, leading to the signing of a Consent Order in May
        1997 to undertake further site investigation and  remediation.   The results of the site
       investigation were submitted in  November 1998.
•      Three areas of the site were identified as requiring additional investigation to determine the
       extent of contamination. The results of this  site facility  investigation were submitted  in
       December 1999.
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•      The results of completion of the investigation of the remaining areas of the site were
       submitted in March 2002.
•      Remedial systems are operating at the Mobil Oil facility. A well point system was installed
       in the early 1970s to prevent petroleum seepage to the Buffalo River. In 1993, six dual-pump
       recovery wells were activated to recover petroleum product and groundwater. Five of the six
       recovery wells are presently being operated in conjunction with the well point system.

Iroquois Gas-Westwood Pharmaceutical

•      All remedial construction at the plant site was completed in September 1997, including sheet
       piling barrier wall, groundwater extraction wells, groundwater and NAPL treatment, and a
       clay cap.
•      Remediation of Scajaquada Creek sediments commenced in July 1998 and was completed
       in March 1999.
       Megotiations to purchase property to locate the second well at the upstream portion of the site
       caused some delay in its installation. The second extraction system was completed in August
       2000 and commenced operation for NAPL extraction in December 2000.

Booth Oil

       A PRP proposal for an alternate remedy was accepted in June 1998.  In 2001, the DEC
       proposed amending the earlier RODs.  Negotiations on a  legal agreement for performance
       of the RD/RA are continuing.
•      The RD is expected to be complete by August 2002. Should the proposed amendment be
       deemed acceptable, construction is expected  to commence in the  Fall  of 2002 and be
       completed by June 2003.

ESTIMATED REMEDIATION COSTS

Where available, estimated remediation costs incurred to date and expected in the future are provided
in each site description (Appendix). Federal, State, and PRP contributions were estimated, where
possible. Remediation costs were unavailable for Federal/State RCRA sites, because reporting cost
information  is not  a requirement of the RCRA corrective action  program, and facilities have
generally been reluctant to provide it. The remediation costs that are provided are estimates that may
change as remediation progress is made at each  site.  The estimates will be  updated as new
information becomes available.

Based on available estimates for 19 sites, following is the total amount incurred to date (costs for the
remaining 7 sites are unavailable):
                                           15

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              Federal              $  38.75 million
              State                $   6.80 million
              PRPs	$ 336.45 million
              Total                $ 382.00 million

Based on available estimates for 17 sites, the total additional costs expected in the future are as
follows (costs for the remaining 9 sites are unavailable):

              Federal              $   0.85 million
              State                $   0.8 million
              PRPs	$ 247.55 million
              Total                $ 249.20 million

The estimated costs to date cannot be compared to the estimated costs expected in the future, because
different sites are included in the estimates. It is also difficult to compare the relative contributions
of federal, state, and PRP expenditures, because cost information for some sites was incomplete
(e.g., some sites may have been able to provide federal or state costs but not PRP costs, and so on).
However, the cost information  does provide a sense of the magnitude of U.S. expenditures for
hazardous waste site  remediation in the Niagara River basin.
                                            16

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                                      ACRONYMS

APL          Aqueous phase liquids
BCC          Buffalo Chemical Corporation
BSC          Bethlehem Steel Corporation

CERCLA     Comprehensive Environmental Response, Compensation, and Liability Act of 1980
CMI          Corrective Measure Implementation
CMS          Corrective Measure Study

DDT          primarily l,l'-(2,2,2-trichloroethylidene)-bis/4 chlorobenzene
DEC          New York State Department of Environmental Conservation
DNAPL       Dense non-aqueous phase liquids
DWTP        Drinking Water Treatment Plant

EC           Environment Canada
EPA          U.S. Environmental Protection Agency

HSWA        Hazardous and Solid Waste Amendments

ICM          Interim Corrective Measure
IIWA         Immediately Implementable Work Assignment
I RIM          Interim Remedial  Measure

MOE         Ontario Ministry of the Environment

NAPL        Non-aqueous phase liquids
NRTMP      Niagara River Toxics Management Plan

OCC          Occidental Chemical Corporation

PCBs         Polychlorinated biphenyls
PRP          Potentially Responsible Party
PSA          Preliminary Site Assessment
PVC          Polyvinyl chloride

RA           Remedial Action
RCRA        Resource Conservation and Recovery Act
RFA          RCRA Facility Assessment
RF1          RCRA Facility Investigation
RI/FS         Remedial Investigation/Feasibility Study
ROD          Record of Decision
RRT          Requisite Remedial Technology

SPDES        New York State Pollutant Discharge  Elimination System

TCDD        Tetrachlorodibenzo-p-dioxin
TCP          Trichlorophenol
VOC          Volatile organic compounds
                                            17

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                                     GLOSSARY
Ambient
A surrounding medium, such as water or air.
Used in contrast to a specific source.

Aquatic
Growing in, living in, or dependent upon
water.

Atmospheric deposition
Pollution from the atmosphere associated
with dry deposition in the form of dust, wet
deposition in the form of rain and snow, or
as a result of vapor exchanges.
                   B
Barrier wall
A wall constructed underground in a
hazardous waste site or landfill to stop the
flow of contaminated groundwater.

Basin
The land that drains into a waterbody.

Bedrock groundwater
Water flowing through a rock layer
underground, under a top layer of mixed soil
and loose rock called the overburden.

Benzo(a)pyrene [B(a)P]
A PAH that is formed by the incomplete
combustion of fossil fuels, wood,  and
tobacco; the incineration of garbage; and in
steel production.

Bioaccum ulation
The process by which chemical substances
accumulate in the tissues of an organism that
drinks contaminated water or eats
contaminated food.
Cap
A cover over hazardous waste sites, usually
made of clean soils or clay, that prevents
rainwater from seeping through soil and
causing the contaminants in the soil to flow
into the groundwater.

Capture Zone
Area in which groundwater is flowing
towards a pumping well; used as
remediation technique for hazardous waste
sites, to "capture" contaminated
groundwater and treat it.

Chlordane
A persistent toxic chemical that was used to
control ants, grasshoppers, and other insects
on certain crops.

Collection drain
System of pipes around a hazardous waste
site or  landfill that collects surface or
groundwater and directs it toward a
treatment plant.

Combined sewer overflow (CSO)
Water  discharged into a waterbody from a
sewer system that carries both sanitary
sewage and stormwater runoff.  During dry
weather the combined sewer system's flow
is normally treated at a wastewater treatment
plant, but during rain events, the plant's
capacity may be exceeded and the flow may
be bypassed to discharge, untreated, directly
into a waterbody.

Consent decree
A legal document, approved by a judge,
which  puts into effect a remedy (i.e., actions
to correct an environmental problem).
                                          18

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Contaminant
A substance that is not naturally present in
the environment or is present in amounts
that can adversely affect the environment.
DDT
Dichloro-diphynyl-trichloroethane. A
persistent toxic chemical that was used as a
pesticide, particularly for mosquito control.
DDT is banned in U.S. and Canada. DDE
and ODD are metabolites of DDT.

Dieldrin
A persistent toxic chemical that was used
mainly as a soil insecticide.

Dioxins/furans
Dioxin: A family of persistent toxic
chemicals known as dibenzo-p-dioxins.
Dioxins can enter the environment as the by-
products  of industrial processes or as a result
of combustion  processes in incinerators and
motor vehicles using leaded fuel.  The
compound called "2,3,7,8-TCDD" is the
most toxic member of the dioxin family.
Furans are a class of chemicals similar to
dioxins, which are created at high
temperatures, such as incineration of PCBs
and other organic wastes containing
chlorine.

DNAPL  (Dense Non-Aqueous Phase
Liquid)
An oily, sludge-like mixture of chemicals
that is denser than water. DNAPL flows
with gravity or along geological formations,
not always in the same direction as
groundwater.

Downstream
In the direction with the flow of a stream or
river; down river. For Niagara River,
downstream is towards Niagara-on-the-Lake
and Lake Ontario.

Dredging
Removal of sediment from the bottom of a
waterbody.
                                                                 E
Embayment
A bay. A part of a waterbody (such as a
river or lake) that makes an indentation into
the adjacent land.
Force main
A pipe that carries contaminated
groundwater drawn out of hazardous waste
sites by pumping wells to a treatment plant.

Four Parties
The four agencies who implement the
Niagara River Toxics Management Plan:
U.S. Environmental Protection Agency,
Environment Canada, New York State
Department of Environmental Protection,
and Ontario Ministry of Environment and
Energy.
Groundwater
The fresh or saline waters found beneath the
Earth's surface that often supply wells and
springs. Contrast to "Surface water".
                   H
Habitat
Place where a particular type of plant or
animal lives. An organism's habitat must
provide all of the basic requirements for its
life.
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Hazardous waste
Any substance that is a by-product of society
and is classified under U.S. or Canadian law
as potentially harmful to human health or the
environment. Hazardous wastes are subject
to special handling, shipping, storage, and
disposal requirements under the law.

Hazardous waste site
Land disposal site for hazardous wastes.

Heavy metals
Metallic elements with high atomic weights
that tend to be toxic and  bioaccumulate.
Examples are mercury, arsenic, lead, etc.

Hexachlorobenzene (HCB)
A persistent toxic chemical that was
originally manufactured  as a fungicide for
cereal crops.  It is also generated as a by-
product in the manufacture of pesticides and
can be formed during the combustion of
substances containing chlorine.
Infiltration
Passing through or filtering through, as in
rain water that filters through soil to join
groundwater.

Inorganic substance
A chemical compound that does not contain
carbon. Inorganic substances are often
derived from minerals.

Insecticide
A chemical used to kill or control the growth
of insects.
Landfill
Land disposal site for hazardous (or non-
hazardous) wastes.

Leachate
Liquid derived from rain or snow melt that
percolates through a hazardous waste site.

Load or Loading
The amount of a material entering a system
over a given time  interval.
                   M
Medium (plural: Media)
A surrounding substance in the environment:
water, air, or sediment.

Metabolite
A substance that is the product of biological
changes to a chemical.

Mirex
A persistent toxic substance that was used as
an insecticide and a fire retardant.

Multi-media
Involving multiple media, such as water and
air, or air and sediment, or all three.
                    N
National Priorities List (NPL)
An EPA list of the most serious uncontrolled
or abandoned U.S. hazardous waste sites
identified for long-term remedial action
under Superfund.

Non-point source
Diffuse pollution sources (i.e., without a
single point of origin or not introduced into
a waterbody from a  specific outlet).
Generally carried off the land by stormwater.
                                           20

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Common sources can be associated with a
variety of land-uses (e.g., agriculture,
forestry, and urban) and activities (e.g.,
construction, mining, and land
disposal).Contrast to "Point source".
                    O
Octachlorostyrene (OCS)
A.persistent toxic chemical that was released
as a by-product when chlorine was
manufactured using certain processes that
are no longer used.

Organic substance
A chemical compound that contains carbon.

Overburden groundwater
Water flowing through a layer of mixed soil
and loose rock that lies over the rock layer
called bedrock.
PAHs
Polycyclic or polynuclear aromatic
hydrocarbons. A class of persistent toxic
compounds that are formed from the
combustion of organic material, such as
forest fires or gasoline in cars.

PCBs
Poly chlorinated biphenyls.  A group of
persistent toxic chemicals used in electrical
and hydraulic equipment for insulating or
lubricating purposes.

Persistent toxic chemical
Any toxic chemical that is difficult to
destroy or that breaks down slowly in the
environment (i.e., with a half-life in water
greater than eight weeks).

Pesticide
A chemical used for preventing, destroying,
or repelling any pest.

Point source
Any discernible confined and discrete
conveyance, including, but not
limited to, any pipe, ditch, channel, tunnel,
conduit, well, container, landfill, leachate
collection system, vessel or other floating
craft from which pollutants are or may be
discharged from.

Pollution prevention
Any action that reduces or eliminates
pollutants before they enter the environment.

Potentially Responsible Party (PRP)
Any individual or company potentially
responsible for, or contributing to, the
contamination problems at U.S. hazardous
waste sites.

Pretreatment
Processes used to reduce, eliminate, or alter
pollutants from industrial sources before
they are discharged into publicly-owned
sewage treatment systems.

Priority toxic chemicals
Under the NRTMP, 18 toxic chemicals that
exceeded water quality or fish tissue
standards in the Niagara River or Lake
Ontario.
                   R
RCRA
Resource Conservation and Recovery Act.
A U.S. program to remediate active
hazardous waste sites. Sites are remediated
by potentially responsible parties whenever
this can be arranged.

Record of Decision (ROD)
A public document that explains what
actions will be taken to remediate a U.S.
                                           21

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hazardous waste site.
whenever this can be arranged.
Remedial Investigation/Feasibility Study
(RI/FS)
The RI defines the area! and vertical extent
of the hazardous waste problem at a
Superfund site through numerous sampling
wells, an extended environmental sampling
program and a full geophysical survey.
Based on the RI, the FS develops and
evaluates alternative solutions to the
problem.

Requisite Remedial Technology (RRT)
An RRT is the equivalent of an FS (see
RI/FS above) for a pre-CERCLA
agreement.

Runoff
Water that flows over the land surface into a
waterbody.
Slurry wall
Barrier made of a thin, watery mixture of
fine, insoluble material (e.g., clay, cement,
soil).

Solid Waste Management Units (SWMUs)
Areas within a hazardous waste site where
hazardous materials are stored or managed.
SWMUs are generally storage areas,
treatment systems, disposal areas, spill areas,
or containment cells.

Superfund
A U.S. program to remediate inactive or
abandoned hazardous waste sites in an
emergency or for the long-term. Sites are
remediated by potentially responsible parties
Surface water
All water open to the atmosphere (e.g.,
rivers, lakes, reservoirs, seas, etc.).Contrast
to "Groundwater".
Toxaphene
A persistent toxic chemical that was used as
an insecticide.

Toxic substance
Any substance that adversely affects the
health or well-being of a living organism,
e.g., causing death, disease, birth defects,
behavioral abnormalities, cancer, genetic
mutations, physiological/reproductive
malfunctions, or physical deformities.
                                                                   U
Upstream
In the direction against the flow of a stream
or river; upriver. For Niagara River,
upstream is towards Fort Erie and Lake Erie.
Volatile substance
A substance that evaporates readily.

                   W

Wetland
An area that is saturated with water or has a
water level at or near the surface. A wetland
has organic soils and plant/animal species
that are adapted to a wet environment.
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                                   REFERENCES
CRA. 1998.  Estimates of Pre-Remedial and Post-Remedial Action Chemical Loading via
Groundvvater to the Niagara River. Conestoga-Rovers & Associates, January 1998. Ref. No.
9855(1).

Gradient Corp./Geotrans Inc. 1988. Potential Contaminant Loadings to the Niagara River from
U.S. Hazardous Waste Sites.

Niagara River Secretariat.  2002.  Niagara River Toxics Management Plan: Progress Report and
Work Plan, May 2002.

U.S. Environmental Protection Agency/New York State Department of Environmental
Conservation (EPA/DEC). 1989. Reduction of Toxics Loadings to the Niagara River from
Hazardous Waste Sites in the United States.
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APPENDIX
PRIORITY NIAGARA RIVER HAZARDOUS WASTE SITES:




SITE DESCRIPTIONS & REMEDIATION SCHEDULES

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                                       A-l

               OCCIDENTAL CHEMICAL - BUFFALO AVENUE
                                   Site#41b-49

Site Program: RCRA (State and Federal)
Summary Prepared by: EPA and DEC

Site Description

Occidental Chemical Corporation's (OCC) Buffalo Avenue Plant is a major manufacturing
facility in central Niagara Falls adjacent to the Robert Moses Parkway, along the Niagara
River.

Starting with seven acres in 1911, the facility has grown to approximately 130 acres, with
hundreds of buildings. During its history, the facility has manufactured over 250 different
chemical products, including halogenated benzenes, toluenes, phenols, and aliphatics.
Chemical raw materials, products and wastes have been buried or spilled at numerous
locations on the plant site.  Estimates of the amount of waste disposed in the various
production areas include: 4,200 tons in D-Area, 1,500 tons in F-Area, 11,300 tons in N-
Area, and unknown amounts in U-Area.

Five aquifers exist at this site: one overburden and four bedrock. A clay/till layer serves as
an aquitard (a barrier) between the overburden and the bedrock, except where man-made
influences such as utilities and building foundations have penetrated the layer.  The four
bedrock flow zones occur within the Lockport Group (a rock formation) with the three
upper units accounting for nearly 100% of bedrock groundwater at the site.

In the overburden, groundwater flow was historically toward the Niagara River from the
southeast portion of the site.  However, an overburden barrier wall constructed in 1994
restricts the direct discharge of this groundwater to the Niagara River. The barrier wall re-
directs the groundwater to the southwest. In the southwest portion of the site, the
overburden groundwater discharges to the New York Power Authority (NYPA) conduit
drain system and then probably discharges from the NYPA drain system to the  Falls Street
Tunnel. At other plant areas, the direction of overburden groundwater flow is locally
influenced by man-made structures, particularly the sanitary and outfall sewers as well as
existing groundwater collection systems.

In the bedrock aquifers, groundwater moves northwest, north, and northeast, is recharged
by the river, and is influenced by the NYPA conduits and the Falls Street Tunnel. Most
bedrock groundwater flow  leaving the site will enter the NYPA conduit drainage system or
the Falls Street Tunnel. All of the dry weather flow through the Falls Street Tunnel now is
treated by the Niagara Falls Wastewater Treatment Plant before discharge to the River.

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                                      A-2

Interim Corrective Measures

OCC completed certain interim corrective measures required under the Resource
Conservation and Recovery Act (RCRA):

•      Removal and capping of contaminated soils
•      Installation of a barrier wall
•      Collection of DNAPL from bedrock wells
       Installation of fences
•      Removal of spills from secondary containment areas
•      Removal of fly ash accumulated on the ground.

DEC and EPA issued OCC a state Part 373 permit and an EPA Hazardous and Solid Waste
Amendments permit under RCRA in June 1988, permitting the storage/treatment and
incineration of hazardous wastes.

Site Investigation

Pursuant to the permits, OCC completed the on-site and off-site components of a RCRA
Facility Investigation (RF1). Due to the complexity of site conditions, the remedial
program activities for the facility were subdivided into several components:

•      bedrock groundwater
•      overburden groundwater
•      overburden soils
•      off-site groundwater contamination.

In accordance with an August 1993 DEC Part 373 permit modification, the remedial
measures are being implemented as stabilization measures, followed by the final remedy
selection after the adequacy of the stabilization measures are assessed. Stabilization
measures for the individual components are being addressed on a priority basis. OCC has
prepared a comprehensive, site-wide CMS, addressing all site components including the
adequacy of the stabilization measures described below. This was submitted in November
 1998.

Stabilization Measures (Additional Interim Corrective Measures)

Bedrock Groundwater. All of the bedrock groundwater extraction wells and monitoring
wells have been installed. A new treatment plant designed to treat the contaminated
bedrock groundwater has been constructed. The pump-and-treat system has been started
up. From April 1996 through September 1996, as part of the testing and  optimization of
the remedial system, over 700 gallons per minute of contaminated groundwater were
pumped from the upper three bedrock aquifers and treated at the new treatment plant.
Three bedrock wells have collected, through May 1997, approximately 5,840 gallons of
DNAPL from the site.  The DNAPL is incinerated in OCC's hazardous waste incinerator.

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                                       A-3

The pump-and-treat system was tested and optimized through March 1997. The pumping
rates of each of the 19 bedrock groundwater extraction wells were optimized to achieve a
hydraulic barrier along the northern and western plant boundaries to contain the
contaminated groundwater.

Based on performance monitoring data, OCC determined that additional measures were
necessary to achieve the remedial design objectives. The treatment plant has been enhanced
by adding additional treatment measures (air stripping to address break-through of vinyl
chloride), and expanding the plant's capacity from 800 gpm to 1200 gpm.  OCC
subsequently  increased the extraction rate of the bedrock groundwater recovery system to
1000 gpm.  On average more than 50 pounds per day of organic chemicals are captured by
the bedrock groundwater collection system.

Overburden  Groundwater. Construction of a collection system to capture overburden
groundwater along the southern boundary of the site  is complete.  In the southwestern
portion of the site, an  1,800 foot-long abandoned sewer line has been converted into a
groundwater collection system. Conversion of the line began in February 1996. A 1,400
foot-long section of the line began operation in June  1997. During the sewer line
conversion, a 400 foot-long section of the line was found to be unsuited for capturing the
groundwater.  As a result, OCC installed a new groundwater collection drain (trench)
adjacent to this 400 foot-long section of pipe, and extending an additional 400 feet to the
west beyond the original sewer line length. This increased the capture zone to a total of
2,200 feet.  This system began operation in December 1997.  However, performance
monitoring data indicated that these measures were insufficient to produce the necessary
groundwater capture, so the system was augmented by installation of a tile drain. This was
completed in  December 1998.  The new collection system extends along the alignment of
the converted sewer to the vicinity of the OCC S-Area site.  On average more than 50
pounds per day of organic chemicals are captured by the overburden groundwater.
collection system.

The overburden ground water col lection system is now fully operational. The collected
groundwater is being treated on-site at an existing wastewater treatment plant, which was
upgraded to handle the additional flow.

At one time, groundwater infiltration into the on-site industrial waste sewer system was a
significant source of contamination to the river.  However, OCC has had an ongoing
program  for replacing and repairing pipes since the early 1980s.  OCC completed the
investigation of groundwater infiltration into the Plant's Outfall Sewer System in June
1996 and implemented measures to eliminate infiltration points from Fall 1996 through
Spring 1997.

OCC installed a barrier wall in 1994 along the Niagara River to prevent migration of
overburden groundwater contamination into the Niagara River.

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                                       A-4

Overburden Soils and Off-site Groundwater.  As interim corrective measures, OCC
identified and removed 36 tons of liquid mercury from contaminated soils on-site in U-
Area, and capped dioxin-contaminated soils in X-Area.

OCC submitted a draft CMS for the overburden soils in 1996. In a Fall 1997 comment
letter on the draft CMS, DEC advised OCC not to prepare a separate off-site CMS, but
instead to submit a comprehensive, site-wide, final CMS that addresses remedial measures
for all site components (bedrock, overburden and off-site).  That CMS was submitted in
November 1998.

Final Corrective Measures

Future off-site loadings from the Buffalo Avenue site will be effectively eliminated by the
bedrock groundwater stabilization program (completed), and the overburden groundwater
stabilization  program (completed).

A draft permit that specifies the Final Corrective Measures for the facility was public
noticed in September 1999. The draft permit proposed to incorporate the Interim
Corrective Measures currently in place as part of the Final Corrective Measures for the site.
After a public comment period, the final permit became effective February 10, 2000.

The Final Corrective Measures in the final  permit include:

•      Extraction of bedrock groundwater on-site; and treatment in accordance with the
       applicable SPDES permit at an on-site plant.
•      Monitoring bedrock groundwater extraction wells for NAPL; and  collection of
       detected NAPL with on-site or off-site treatment.
       Extraction of overburden groundwater on-site; and treatment in accordance with the
       applicable SPDES permit at an on-site plant.
•      Compliance with the limits specified in the applicable Significant Industrial User
       Wastewater Discharge Permit for overburden groundwater infiltration into the City
       of Niagara Falls sanitary sewers.
•      Compliance with the provisions of the applicable SPDES permit to restrict
       discharge of overburden groundwater from the outfall sewer system.
•      Monitoring overburden groundwater extraction wells for NAPL; and collection of
       detected NAPL with on-site or off-site treatment.
•      Monitoring the performance of the remedial systems on-site and off-site.

The schedule for implementation of a corrective action program at the plant, including
Corrective Measure Study (CMS) and Corrective Measure Implementation (CMI), is
shown below.

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                                       A-5

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:

       Federal       $ (Not available)
       State         $ (Not available)
       PRP         $ (Not available)

The following estimated amounts will be spent from now to the completion of remediation:

       Federal       $ (Not available)
       State         $ (Not available)
       PRP         $ (Not available)

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                                        A-6
OCCIDENTAL CHEMICAL - BUFFALO AVENUE
Output
RFI Work Plan Approval
RFI Completion
CMS Work Plan Approval
CMS
Completion:
Stabilization
Selection:
Stabilization
Work Plan
Approval:
Start-up:
Stabilization2
Bedrock Groundwater
Overburden Groundwater
Overburden Soil1
Off-Site (Groundwater)1
Site-wide CMS1
Bedrock Groundwater
Overburden Groundwater
Overburden Soil1
Off-Site (Groundwater)1
Bedrock Groundwater
Overburden Groundwater
Overburden Soil1
Off-Site (Groundwater)1
Bedrock Groundwater
Overburden Groundwater
Overburden Soil1
Off-Site (Groundwater)'
Start-up of CM I
Responsible
Party
DEC/EPA
Permittee
DEC/EPA
Permittee
Permittee
Permittee
Permittee
Permittee
DEC/EPA
DEC/EPA
DEC/EPA
DEC/EPA
DEC/EPA
DEC/EPA
DEC/EPA
DEC/EPA
Permittee
Permittee
Permittee
Permittee
Permittee
Previous
Target Date
Jun 1991
Dec 1992
Jun 1993
Aug 1993
Dec 1994
Aug 1996
Feb 1997
N/A
Dec 1994
Feb 1995
Oct 1997
Apr 1998
Nov 1994
Jun 1995
Apr 1998
Jul 1998
Oct 1995
Dec 1997
Oct 1998
Dec 1998
Dec 1997
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
N/A
COMPLETED
COMPLETED
COMPLETED
N/A
N/A
COMPLETED
COMPLETED
N/A
N/A
COMPLETED
COMPLETED
N/A
N/A
COMPLETED
1  The overburden soil remedial measures were delayed so that contaminated soils generated
during both bedrock and overburden groundwater remediation could be addressed at once. Off-site
remedial measures were delayed, pending evaluation of the effectiveness of on-site remedial
measures.  None of these remedial measures impact the potential for off-site loadings, which was
eliminated in Dec.  1998, with full operation of the overburden groundwater remedial system.
OCC submitted a comprehensive, site-wide,  final CMS in November 1998, addressing all on-site
and off-site components. The NYSDEC issued a draft 373 permit that specifies final corrective

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                                           A-7

measures for the facility in September 1999. After a public comment period, the final permit
became effective February 10,2000.

2 Implementation of the Bedrock and Overburden Stabilization Programs will effectively eliminate
future off-site loadings from the Main Plant Site.

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                                      A-8

                   NIAGARA COUNTY REFUSE DISPOSAL
                                    Site #81

Site Program: Federal Superfund
Summary Prepared by: EPA

Site Description

The Niagara County Refuse site occupies approximately 65 acres, about 1000 feet north
of the Niagara River in the Town of Wheatfield, New York.

During its operation period (1968-1976), the Niagara County Refuse Disposal District
(NCRDD) accepted household, yard, agricultural, institutional, commercial, and
industrial waste; demolition and construction debris; sewage treatment plant sludge; street
sweepings; and used tires. More than 100 waste generators or transporters are thought to
have used the site.  Disposed materials included heat-treatment salts, plating-tank sludge,
tetrachloroethylene, PVC skins and emulsion, thiazole polymer blends,  polyvinyl alcohol,
phenolic resins, and brine sludge containing mercury.  The site was capped with 20 inches
of dirt and clay at the time that it was closed by the NCRDD in 1976. Illegal dumping of
rubbish and hard fill, as well as the erosion of the clay cap, have been concerns  at the site
since its closure.

Three overburden zones and one bedrock zone are present under this site. The  bedrock
zone and one of the overburden zones are the primary water-bearing formations
(aquifers).  The groundwater in these two aquifers generally flows in a south/southwest-
erly direction towards the Niagara River beneath the southern half of the site and in a
north/northwesterly direction towards Black Creek beneath the northern half of the site.

Site Investigation

Niagara County Refuse is an EPA-lead site on the National Priorities List of Superfund
sites. Pursuant to a March 1989 consent order, a group of fourteen Potentially
Responsible Parties (PRPs) performed a Remedial Investigation/Feasibility Study (Rl/FS)
for the site.  It was  completed in September 1993, when EPA signed a Record of Decision
(ROD) for the site.

Among other things, the Rl report indicated that the water-bearing zones beneath the site
showed either a negligible impact from volatile and semi-volatile organic compounds and
pesticides, or no impact at all.  Maximum contaminant levels were generally exceeded in
the site groundwater for chromium, iron, manganese, and sodium (although iron and
sodium levels in regional groundwater typically exceed maximum contaminant levels).
Based on these findings, EPA considers the original loadings estimate for this site to be
too high.

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                                       A-9

Upon completion of the RI/FS, EPA issued a Proposed Plan for remediation of the site.
After consideration of public comment on the Proposed Plan, EPA executed a ROD on
September 24, 1993, selecting the following remedy:

•      a full NYCRR part 360 cap with a complete perimeter clay barrier wall
       leachate collection and offsite treatment and disposal
       gas venting
       an ecological assessment of the adjacent wetlands
       removal of the field tile drains located to the west of the landfill
•      long-term operation and maintenance.

The Final Design Report for the remedial action was approved by EPA in September
1997. Due to the Site being a municipal landfill, the municipalities are eligible for State
funding assistance for their respective share of remedial action costs. As such, the
specific state requirements for funding eligibility were completed by May 1998.  A call
for bids was issued and the bid was awarded for remedial construction in June 1998.
Construction began in fall 1998.

Construction Progress

On-site construction at the site commenced in November 1998. The site was cleared and
grubbed and a security fence erected.  Installation of the leachate collection system and its
tie-in to the City of North Tonawanda sanitary sewer by force main was completed over
the winter months. Early spring was devoted to grading the site and filling the central
swales with clean fill. Placement of the first layer of the cap, gas-vent stone, began  in
May 1999. Construction progressed with the placement of a geotextile drainage  layer, a
geocomposite  barrier layer, a soil barrier protection layer, and a topsoil layer,
respectively. Placement of each layer proceeded  in a north-to-south direction over the
entire site. At the end of the 1999 construction season, construction was 95% complete.
Work resumed in the spring of 2000 and the construction was completed in June. A final
inspection was conducted in September 2000.  The final Remedial Action Report was
approved in December 2000 and operation and maintenance activities commenced.
Groundwater monitoring supports that the remedy is effective and operating as designed.

The leachate collection system has been operational since summer 1999, thus eliminating
any potential pathway for leachate to migrate off-site.

Schedule for Completion

An updated schedule for remediation of the site is shown in the following table.

-------
                                  A-10

Remediation Costs

Following are estimated amounts that have been spent to date in response to this site:
      Federal
      PRP
$ 1,300,000
$ 11,500,000
NIAGARA COUNTY REFUSE DISPOSAL
Output
RI/FS
Record of Decision
Remedial Design Start
Remedial Action Start
Remedial Action Completion
Responsible
Party
14PRPs
EPA
13PRPs
ISPRPs
ISPRPs
Previous
Target Date
Mar 1993
Sept 1993
Jul 1994
Jan 1997
Dec 1999
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED

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                                      A-ll

                            DUPONT NECCO PARK
                                    Site# 14

Site Program: Federal Superfund
Summary Prepared By: EPA

Site Description

The Necco Park Site, owned by DuPont, is an inactive industrial waste landfill on
approximately 24 acres in Niagara Falls. It is surrounded on three sides by the BFI
Sanitary Landfill and the CECOS site, approximately 1.5 miles from the Niagara River.

OuPont acquired the Site in the 1930s and used it as a landfill to dispose of
approximately 93,000 tons of industrial wastes until its closure in  1977. The following
chemicals are known, from disposal records, to have been disposed at the Site: carbon
tetrachloride, chloroform, hexachlorobenzene, hexachlorobutadiene, hexachloroethane,
methylene chloride, tetrachloroethylene and trichloroethylene.

Eight aquifer zones have been identified under the Site.  In the overburden, groundwater
flow is minimal, but is influenced by two water table depressions along the southern
property boundary, which are caused by two recovery wells in the upper bedrock.
Groundwater in the upper bedrock zones is partially captured by the recovery well
system. Otherwise, Site  groundwater in the upper bedrock water-bearing zones
discharges down-gradient to the south. A portion of it is presumed to eventually reach
the Falls Street Tunnel (FST).  Groundwater in the middle bedrock zones flows generally
to the west and is partially captured by a third recovery well.  Groundwater in the middle
and lower bedrock zones flows west toward the New York Power Authority (NYPA)
conduits.

Interim Remedial Measures

Necco  Park is not on the National Priorities List.  However, DuPont conducted
groundwater investigations pursuant to a RCRA 3013 consent decree and a CERCLA
Administrative Order on Consent (AOC) with EPA.

The Site was capped  in 1978.  Since 1982, two recovery wells near the center of the
property, when operational, have recovered contaminated groundwater and established a
partial  hydraulic barrier in the  upper bedrock and overburden along the southern edge of
the landfill.  However, some upper bedrock groundwater continued to flow south toward
the Niagara River.  In order to improve containment and collection of contaminated
groundwater, an up-gradient grout curtain was installed in the bedrock in August 1989. A
third recovery well, which  penetrates the middle bedrock zones at the southern boundary
of Necco Park, went into limited operation in 1992. These on-site remedial actions have
resulted in an estimated load reduction from the site of approximately 27-55%, based on

-------
                                     A-12

information collected pursuant to the AOC.  DuPont estimates that approximately 163
million gallons of groundwater have been pumped since 1983. Since 1989, 7100 gallons
of DNAPL have been recovered, containing approximately 94,600 pounds of organic
compounds.

A portion of the groundwater not recovered by the on-Site pumping wells is probably
captured (1) by the New York Power Authority conduit drain system (water in the drain
system may drain to the Falls Street Tunnel or flow north to the Forebay Canal) or (2) by
the Falls Street Tunnel directly. All the dry-weather flow through the Falls Street Tunnel
is treated by the Niagara Falls Wastewater Treatment Plant before discharge to the River.

Final Remedial Action

The remedial investigation began May 1991 and the Investigation Report was  approved in
May 1994. The feasibility study (FS) (entitled "Analysis of Alternatives Report") was
approved by EPA and DEC in  July 1996.

On September 18, 1998, EPA issued a Record of Decision (ROD) for the site, which set
forth the following remedy:

1.  Containment of the Source  Area by:

•      Upgrading the existing cap to meet New York State Part 360, orequivalent standards;
•      Using hydraulic measures in the overburden to maintain an inward gradient within
       the Source Area or installing a physical barrier (e.g., slurry wall, sheet pile) on the
       southern, and  portions of the eastern and western Necco Park property boundaries;
       Using hydraulic measures in the bedrock to maintain an inward gradient within the
       Source Area and prevent the movement of contaminated groundwater beyond the
       Source Area boundary.

2.  Treatment of the extracted groundwater from the Source Area, either on-site or off-site,
to achieve the appropriate discharge requirements.

3.  Collection, and off-site disposal, of DNAPL in the Source Area by:

•      Utilizing the existing monitoring wells network;
•      Utilizing any groundwater recovery wells placed in the Source Area;
•      The installation of additional dedicated DNAPL recovery well(s).

4.  Operation and maintenance (O&M) of the existing systems and the systems constructed
under this remedy.

-------
                                      A-13

5. Comprehensive monitoring to verify hydraulic control, identify DNAPL occurrence,
demonstrate the effectiveness of the remedial measures, and assess the impact of such
measures on far-field groundwater quality.

6. Additional characterization of the Site to assess whether natural attenuation will be
effective in addressing far-field contamination.

7. Development and implementation of institutional controls to restrict Site access, the use
of groundwater at the Site, and control land use such that it is consistent with Site conditions.

Schedule for Completion

The Proposed Plan was  released to  the public in July 1996, upon approval of the FS. A
public meeting to discuss the Proposed Plan was held  in August 1996, shortly after its
release. Because of extensive public comments received on the Proposed Plan, EPA revised
the Proposed Plan in response to the comments and provided a second public comment
period. A Record of Decision (ROD) was issued in September 1998. Design studies started
in October  1998.   The remedial  design  is underway.   In  September 2000, DuPont
commenced installation of additional groundwater wells  that will serve as component parts
of the hydraulic containment portion of the final remedy. RA completion is expected by
November 2005. Because of the fractured bedrock beneath the site, future complications may
arise in achieving effective hydraulic containment.  The target date is  intended to allow
sufficient time to ensure that any additional remedial work to achieve effective containment
can be completed, and that the system is tested and optimized. It is also important to  note
that,  as mentioned above under Interim  Remedial Actions, remedial actions  already
implemented on-Site  have resulted in an estimated load reduction  from the  Site of
approximately 27-55%.

Remediation Costs

Following are estimated  amounts that have been spent to date on remediating this Site:

       Federal       $  2,030,000 (Does not include EPA's indirect costs)
       State          $    141,000 (Does not include travel costs)
       PRP          $42,500,000 (Unverified DuPont estimate)

It is estimated that the following amounts will be spent from now to the completion of
remediation:

       Federal       $    320,000
       State          $     100,000
       PRP          $  65,102,000 (includes O&M)

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                          A-14
DUPONT NECCO PARK
Output
RI
FS
Record of Decision
Remedial Design Start
Final Remedial Action Start
Remedial
Action
Completion
Grout Curtain
3 Pumping Wells
Final Action
Responsible
Party
PRP
PRP
EPA
PRP
PRP
PRP
PRP
PRP
Previous Target
Date
May 1994
Sept 1994
Sept 1996
Feb 1997
Nov2001
—
...
Oct 2003
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
November 2005

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                                      A-15

                           CECOS INTERNATIONAL
                                    Site # 78

Site Program: RCRA (State and Federal)
Summary Prepared by: EPA and NYSDEC

Site Description

CECOS International, Inc. operates a 385-acre commercial solid/industrial waste
management facility in the Town of Niagara and the City of Niagara Falls. The facility is
situated in an industrial and commercial area, bordering residential and recreational areas,
and is about 1.5 miles north of the Niagara River.

The site has been used for waste disposal for over 80 years. The facility managed
hazardous wastes from all Resource Conservation and Recovery Act (RCRA) categories
identified in Part 261 — characteristic wastes, specific and non-specific industrial wastes
and commercial chemical product waste.  Current hazardous waste management activities
include a wastewater treatment system  and container storage.

The CECOS facility is underlain by an overburden and two bedrock aquifers. A less
permeable layer of native clays and glacial till serves as an aquitard (or barrier) between
the overburden and the bedrock aquifers.

All but a minor percentage of the CECOS site groundwater flows off site to the south and
southeast and is drawn into the Falls Street Tunnel and New York Power Authority
(NYPA) conduit sink on its way to the Niagara River.  The potential loading to the
Niagara River from the site overburden aquifer compared to that from  the bedrock
aquifers is minor.  By the time it reaches the tunnel/conduit system, the groundwater from
the overburden aquifer has found its way into the upper bedrock through discontinuities
and excavations in the native sediments. All of the dry weather flow through the Falls
Street Tunnel is treated by the Niagara Falls Waste Water Treatment Plant.

Site Investigation

The site encompasses approximately SO Solid Waste Management  Units, including
landfills, waste piles and surface impoundments. An EPA HSWA  permit and state Part
373 permit were issued in September 1988, requiring investigation/remediation of all
waste management units.

Pursuant to the requirements  of the RCRA permit, in September 1991, CECOS
completed the required  investigations at the facility. Groundwater  contaminants were
mainly detected in the central area of the site, in the three groundwater transtnissive zones
monitored by CECOS.  The volatile organic compounds (VOC) detected include acetone,
2-butanone, benzene, chloroform, toluene, chlorobenzene, methylene chloride, and

-------
                                     A-16

tetrachlorethane.

Interim Corrective Measures flCM")

An interim groundwater recovery system has been pumping contaminated groundwater
from all three zones since 1990. The recovery system was started with four recovery
wells and currently consists of 20 recovery wells.  The pumped groundwater is treated on-
site and discharged to the City of Niagara Falls wastewater treatment plant. From July
1991 through August 1998, over 60 million gallons of groundwater have been treated,
and over 2,500 pounds of organic compounds were removed.

In addition, several interim measures consisting of the removal of contaminated soils and
wastes have been completed at the following units: surface impoundments, phenolic
resin area, and sewage sludge area. Post-closure permit/HSWA modification for the
closed hazardous waste landfills was issued in September 1991.

A final remedy for the Scrap Yard Area was incorporated into the DEC/EPA permit
modification of September 1991. The remedy, implemented in  1992, consisted of:

•      Removal and off-site disposal of approximately 24,000 cubic yards of soil
       contaminated with PCBs, organic compounds, and metals
       Construction of a low permeability cover
•      Long-term inspection and maintenance of the cover, and monitoring of the
       groundwater.

All of the interim remedial actions that have come due at this site have been
accomplished.

Corrective Measures Study

A RCRA Facility Investigation (RFI) and a Corrective Measures Study have been
completed. The final, site-wide corrective measures for the CECOS site were selected
through the DEC Part 373 permit renewal process. The permit was renewed in February
1995. The final corrective measures consist of:

•      Groundwater extraction and on-site treatment (prior to discharge to the City of
       Niagara Falls Wastewater Treatment Plant);
       Maintenance of existing caps and pavement over areas of residual contamination;
       Restrictions on future land development; and
       Restrictions on public access to the facility.

The  interim groundwater pump-and-treat program has been successful in containing and
remediating the groundwater contamination at the facility. However, as part of the final

-------
                                      A-17

remedy, this interim remedial system will be enhanced to expand the groundvvater capture
zone and facilitate a more rapid clean-up of the site.

CECOS submitted a Corrective Measure Implementation (CMI) design in August 1995
and prepared an addendum to the design plan that included an aquifer pumping test
program. A short-term pumping test was conducted in October-November 1995 to
evaluate the potential use of existing wells as both pumping wells and monitoring wells
for the CMI. An extended trial CMI pumping test was conducted in February-May 1996
to test additional wells and to optimize pumping rates over a longer duration (to
determine the extent of long-term capture zones to control contaminant migration).
Several existing recovery wells, an existing collection drain,  and a new recovery well are
being operated for the CMI. CECOS submitted a new CMI design in November  1996.
The CMI was started up in December 1996. The remedial system continues to be
operated.

Remediation Costs

Following are estimated amounts that have been spent to date on  remediating this site:

      Federal       $ (Not available)
      State         $ (Not available)
      PRP         $ (Not available)

It is estimated that the following amounts will be spent from now to the completion of
remediation:

      Federal       $ (Not available)
      State         $ (Not available)
      PRP         $ (Not available)

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                           A-18
CECOS INTERNATIONAL
Output
RFI Work Plan Approval
RPI Completion
Stabilization Start-up
(Groundwater)
Start-up of CMI (Scrap Yard)
CMS Work Plan Approval
CMS Completion
Remedy Selection (site-wide)
CMI Work Plan Approval
(site-wide)
Start-up of CMI (site-wide)
Responsible Party
DEC/EPA
Permittee
Permittee
Permittee
DEC/EPA
Permittee
DEC/EPA
DEC/EPA
Permittee
Previous
Target Date
Sep 1989
Sep 1991


Apr 1992
Apr 1993
Dec 1994
Apr 1995
Apr 1996
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED

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                                      A-19

                  OCCIDENTAL CHEMICAL - HYDE PARK
                                    Site # 39

Site Program: Federal/State Co-lead: Superfund
Summary Prepared by: EPA

Site Description

Occidental Chemical Corporation's (OCC) Hyde Park site is a 15-acre landfill in
northwest Niagara Falls, less than one-half mile from the Niagara River.

From 1953 to 1975, the company (then Hooker Chemicals and Plastics) deposited
approximately 80,000 tons of chemical wastes at the site. The hazardous materials
disposed on site included 3,300 tons of 2,4,5-trichlorophenol (TCP) wastes, which are
known to contain significant amounts of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD);
approximately 0.7 - 1.6 tons of dioxin are believed to be associated with the TCP.
Chlorinated organic wastes, including hexachloropentadiene derivatives, chlorendic acid,
chlorinated toluenes,  benzenes and phenols, predominate at the site. The former drainage
stream of the landfill, Bloody Run, which flows into the Niagara River, was historically
contaminated with organic chemicals, including dioxin.  A clay cap and a shallow
leachate collection system were installed at the site in 1979.

There is an overburden and a bedrock aquifer present under this site. Groundwater flows
both downward and horizontally through the fractures and layers of the bedrock.  The
aquifers flow generally northwest, toward the Niagara River Gorge. Contaminants have
migrated from the site in both aqueous and non-aqueous phases in the overburden and
bedrock. Dioxin from the site has  previously been found in contaminated groundwater
seeping to the River from the Gorge face, located 1,600 feet west-northwest of the site.

Although, as summarized below, remedial action has not been completed at the site, the
remedial action taken at the site to date has substantially reduced off-site  migration.
Since installation of an overburden remediation system in 1991, groundwater in the
overburden is no longer migrating horizontally past the remediation system around the
site. Therefore, no loading of hazardous substances from the site to the Niagara River via
groundwater in the overburden is currently taking place.

Substantial containment of bedrock groundwater has also been achieved across the NAPL
plume boundary.  The bedrock is separated into three groundwater zones (upper, middle
and lower). OCC completed a groundwater model of the site in February 2001 and
concluded that full containment has not been achieved in the upper zone. Additional
control must be achieved in the northwest corner of the site.  OCC also concluded that the
major portion of the groundwater in the middle zone and almost the entire lower zone are
being captured with the existing extraction wells. Remedial work to achieve full
containment is continuing, as described below.

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                                     A-20
APL purge wells at the gorge face have substantially reduced the contaminants reaching
the Niagara River. Sampling at the gorge face seeps, conducted annually since 1997, has
not detected dioxin, which was found in previous gorge face surveys.

Requisite Remedial Technology Agreement

The site is a joint EPA/DEC-lead Superfund site on the National Priorities List and is
governed by a pre-CERCLA settlement agreement. EPA sued to require OCC to
remediate the site in 1979. In January 1981, EPA, DEC, and OCC filed a Stipulation and
Judgment Approving Settlement Agreement.  Since  1982, OCC has been implementing
the settlement agreement.  Agreement on a Requisite Remedial Technology (RRT) was
approved by the court in 1986. The RRT included:

•      Source Control (prototype landfill extraction wells);
•      Containment and collection of contaminants  in the overburden (overburden
       barrier collection system) and the Lockport bedrock (purge and recirculation
       wells);
       An Intermediate and  Deep Formations Study (monitoring wells);
•      A Community Monitoring Program (monitoring wells) for early detection of
       plumes;
       An Industrial Protection Program for neighboring industries;
       Treatment and monitoring of collected leachates:
             Aqueous-phase liquids to be treated on-site;
             Non-aqueous phase liquids to be destroyed by incineration;
•      Site Capping;
       Gorge Face Seep Remediation to isolate seeps from the public;
       A TCDD bioaccumulation study in Lake Ontario; and
•      Bloody Run Creek excavation and monitoring; and
•      Long-term monitoring.

Major Remedial Activities
Action
Intermediate Formation Wells
Leachate Storage Facility
Leachate Treatment Facility
Upgrade APL Treatment System
Lagoon Closure
Start
10/88
..
__
01/98
07/90
Complete
12/89
05/89
04/91
03/98
01/92
(Table continued on next page)

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                                      A-21
Phase I Source Control Extraction Wells Installed
Phase II Source Control Extraction Wells Installed
Overburden Barrier Col lection System
APL/NAPL Plume Redefinition
Recirculation Wells
Cluster Monitoring Wells
Landfill Cap
Phase I Prototype Purge Wells Installed
Phase II Prototype Purge Wells
Phase III Purge Wells
3 Bedrock Purge Wells and Force Mains Installed
3 Additional Bedrock Purge Wells and Force Mains
Groundwater model
Conceptual Evaluation of NAPL Plume Containment
Upgrade of Leachate Treatment Facility to 400 gpm
4 Additional wells installed in NW corner of site
Site Characterization (Geophysics, Hydraulic Evaluation)
Re-evaluation of NAPL Plume Containment
Additional wells or other remedial measures, if needed
04/90
04/94
_.
04/90
01/91
06/90
08/94
04/90
03/93
05/96
03/98
03/99
4/00
12/00
4/01
6/01
6/01
12/01
4/02
06/90
07/94
11/90
07/90
03/91
09/90
12/94
07/90
12/93
05/97
12/98
12/99
2/01
3/01
6/01
12/01
12/01
2/02
12/02
The status of activities included in the schedule follows.

Community Monitoring Wells provide early detection of chemical migration. They are
sampled and analyzed quarterly to ensure the safety of the community. The well data
confirm that the hydraulic gradient near the community is downward, thereby ensuring
that chemical migration toward the community is not an issue.

Under the Industrial Protection Program, sumps in neighboring industries have been
sealed, as have some manholes.

Fences were used to prevent access to the Gorge Face seeps; seep water has been diverted
into culverts and pipes to prevent humans from being exposed to the potentially
contaminated water; and contaminated sediments were scraped away. Monitoring of the

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                                     A-22

fenced seeps has been conducted annually since 1989. Results continue to indicate no
need for additional control or remediation of the seep areas.  Annual inspections are
performed at all recorded seep locations, and the fences around the seeps are not required
anymore.

The on-site Leachate Storage and Handling Facility was completed in April 1990.
155,000 gallons of NAPL which had been stored on-site in the lagoons and four railroad
tank cars were pumped into the  leachate storage facility and the lagoons were closed in
January 1992.

The Treatment Facility was brought on-line  in April 1991. The contaminants collected
through the remedial systems are treated on-site.  Aqueous-phase liquids pass through an
inclined plane settler, filters, and sacrificial carbon pre-treatment to remove dioxins and
PCBs. This is followed by activated carbon treatment.  All vapors in the closed system
are treated. In March 1998, the APL treatment system was upgraded to handle a higher
flow of 100-150 gallons per minute. In the spring of 2001, OCC completed upgrading the
capacity of the treatment system to 400 gallons per minute in June 2001 so it can
adequately handle excess water in wet weather.

NAPL is trucked to Laidlaw Environmental Services in Deer Park, Texas, for
incineration. To date, 299,166 gallons of NAPL have been destroyed.

Prior to the trucking, NAPL was destroyed at OCC's Niagara Plant Incinerator. The
plant's permit was modified by EPA and DEC in November  1990 to allow destruction of
NAPL from Hyde Park (and other Occidental sites). This was the first commercially-
owned incinerator in the U.S. specifically permitted to destroy dioxin wastes.

The Overburden Barrier Collection System (OBCS), a drain system around the entire
landfill, was installed in 1990.  Occidental continuously operates its pumps, preventing
the migration of contaminants through the overburden.

Installation of two 36-inch diameter Source Control extraction wells within the landfill
itself was completed in June 1990. Phased pump tests were conducted and evaluated
throughout 1991 and  1992.  Based on  the results of these  pump tests, four additional
source control wells of smaller  diameter were installed in the landfill in 1994. With the
completion of the new cap on the landfill and completion of the OBCS, the need for
source control wells has diminished.  Of the original six source control wells,  only three
remain in service. These are manually operated on a weekly basis due to very low
recovery rates.  Collected liquids are taken to the Leachate Storage Facility.

The Lake Ontario TCDD bioaccumulation study was completed in May 1990.  Fish and
sediment samples from Lake Ontario were analyzed for TCDD, and a laboratory study of
the uptake of TCDD by lake trout was conducted.

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                                      A-23

In 1990, the extent of the aqueous-phase liquid/non-aqueous phase liquid plumes in the
overburden and bedrock were redefined. This information was considered in the
implementation of the remedy for the site.

The objective of the bedrock NAPL plume containment system is to create a "zone of
capture" around purge wells down gradient of the landfill so that contaminated ground
water can be collected in these purge wells and pumped to the Leachate Treatment
Facility. The bedrock purge well system was installed in a phased approach:

•      Phase I of the system was installed  in the NAPL plume area and pump tests were
       performed on individual and multiple wells. Based on these tests, additional
       purge wejls (Phase II) were installed in late 1993.
•      Pump tests were performed on the Phase II wells in early 1994 to determine if
       there was an adequate zone of capture surrounding these wells.  Phase II wells did
       not meet the performance criteria and more wells were needed.
       OCC installed Phase ID wells in 1997, along with the associated monitoring wells.
       The force mains to connect these wells to the Hyde Park Leachate Treatment Plant
       were completed in May 1997.
•      Phase ITI monitoring indicated that the bedrock NAPL collection system in this
       area still did not meet performance criteria. Three pumping wells were installed
       and connected by force mains to the on-site treatment facility in 1998. Three
       additional wells were installed and connected to force mains in  1999; one
       additional well and five monitoring wells were installed in 2000.
       Subsequent to the completion of Phase II, additional wells were necessary to
       assure an inward hydraulic gradient on all vectors within the bedrock. OCC
       produced a groundwater model  which indicated that there was not complete
       capture in the upper bedrock in  the northwest corner of the site. Four additional
       wells were installed in 2002 and a NAPL recovery well was converted to an
       extraction well. The model predicts that the operation of these  five additional
       wells will achieve complete groundwater capture, however the reports containing
       the data that will document the effectiveness of these additional wells will not be
       ready in draft form until August 2002. Hydrogeologic studies conducted in 2000
       and 2001 have shown that the three-bedrock- layer system is oversimplified and
       that there are eleven discrete flow zones in the bedrock.  To  improve the
       monitoring system, OCC is currently retrofitting existing 4-inch monitoring wells
       by installing three one-inch PVC pipes in each well.  The one-inch wells will be
       screened to monitor the individual flow zones to better delineate the groundwater
       capture. If OCC demonstrates that full capture is being achieved, the EPA and
       DEC will issue a Construction Completion report September 2002 which
       documents the completion of all remedial systems. However, if it is determined
       that full containment has not been achieved, additional remedial measures will be
       installed by OCC.

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                                     A-24

Excavation of Bloody Run Creek began in October 1992 and was completed in March
1993. Occidental removed 29,200 cubic yards of contaminated sediment and lined the
creek bed with rocks. Samples taken at the bottom and sides of the excavation confirmed
the effectiveness of this remedy.

The sewer under University Drive adjacent to Niagara University was sealed and a new
sewer was installed in 1993. A sewer was relocated at Tarns Ceramics, a neighboring
industrial plant in 1989, and the College Heights sewer was remediated in 1990.

The perimeter cap of the landfill was completed in 1991. A low permeability cap was
placed over the entire landfill in 1994.

Complex site conditions and difficulties in pumping NAPL have resulted in the
installation of additional wells, thus delaying completion of remediation. However, the
landfill has been capped, a leachate collection system surrounds the landfill, NAPL is
being extracted and destroyed, and Bloody Run creek has been excavated.  Also,
additional wells have been installed to ensure sufficient bedrock NAPL containment.  It is
expected that the operation of the additional wells installed in 2002 will achieve full
capture of the contaminated groundwater associated with the site. However, the
documents which will evaluate the effectiveness of the additional pumping wells are not
yet available. These reports were submitted to EPA and DEC in draft form in February
2002. The report indicated that 88% of the groundwater in the upper bedrock was being
captured, and 100% of the middle and lower bedrock groundwater was being captured.
OCC drilled 2 of the wells they installed in 2001 deeper, to better intercept groundwater
flow zones.  This spring, OCC will retrofit monitoring wells with 3 one-inch PVC pipes
in the four-inch wells to better delineate the groundwater capture. This report will be
followed by  a re-evaluation of the containment of the NAPL plume.  If these documents
indicate that no additional remedial measures are needed to fully contain the site,
activities to install these remedial measures will be completed by September 2002.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:

       Federal       $11,550,000
       PRP          $ 62,000,000

It is estimated that $ 2,000,000/year will be spent on the Operation and Maintenance of
the site for approximately the next 30 years.

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                                       A-25
OCCIDENTAL CHEMICAL - HYDE PARK
Output
Remedial Action Completed for
Bloody Run Creek
Remedial Systems Construction
Completed (See above table for
detailed list of remedial actions)
Remedial Action Completion*
Responsible Party
PRP
PRP
PRP
Target Date
Jan 1993
March 1996
March 1997
Current Schedule
COMPLETED
September 2002
September 2003
Remedial systems are considered "operational" when they are operating as designed and are
meeting their performance criteria. Once the remedial systems are declared operational, the
Remedial Action is completed. Then, the Operation and Maintenance period follows.

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                                      A-26

                                102nd STREET
                             Sites # 40, 56, 85, and 94

Site Program: Federal Superfund
Summary Prepared By: EPA

Site Description

The 102nd Street site is located at the eastern edge of the City of Niagara Falls, on the
banks of the Niagara River.  The site  encompasses 22.1 acres, owned by two Potentially
Responsible Parties (PRPs): 15.6 acres owned by Occidental Chemical Corporation
(formerly Hooker Chemical and Plastics Corporation) and 6.5 acres are owned by Olin
Chemical Corporation.

This landfill was used from  1943 to 1971  for the disposal of an estimated 159,000 tons of
wastes, including organic and inorganic phosphates (1,300 tons), hexachlorocyclohexanes
(> 1,500 tons), chemical and demolition wastes, and fly ash.

There are overburden and bedrock aquifers present under this site. A clay and till layer
acts as an aquitard (or barrier) between the overburden  and the bedrock. Although water
flows in several directions in each aquifer, the average  flow direction and ultimate
discharge point is south to the Niagara River.  A small portion of the groundwater from
the upper two aquifers along the eastern site boundary flows east into an adjacent storm
sewer, which ultimately discharges into the Niagara River upstream of the site.

Site Investigation

This National Priorities List site has been the subject of state and federal litigation, and is
a joint EPA/DEC-lead Superfund site. EPA and the State of New York sued Occidental
Chemical Corporation and the Olin Corporation in December 1979.

Interim remedial efforts taken at this  site include bulkheading along the shoreline to
minimize erosion into the river and the installation of a clay cap in the 1970s.

A Remedial Investigation (RI) was performed to determine the nature and extent of
contamination in the soils and ground water. The RI, Feasibility Study (FS) and the
Record of Decision (ROD) were completed in 1990.

The target dates for remedial action were delayed by approximately one year of
negotiations, during which the PRPs  disagreed with the terms of a proposed Consent
Decree. Instead of continuing negotiations, EPA issued an  Administrative Order in
September 1991, requiring the companies to perform the remedial design and remedial
action. An "Intent-to-Comply" letter was signed by the PRPs in October 1991, at which
time the Remedial Design started.

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                                      A-27
Remedial Design

The remedial design of this site was delayed when the natural resource trustees (federal
and state) expressed concerns about 5 acres of the embayment that was proposed in the
design to be enclosed within a slurry wall and covered by the final landfill cap.  Design
modifications were explored to reduce the embayment loss to approximately 2 to 3 acres
by constructing the slurry wall closer to the shoreline. The 1990 ROD, however, required
that hot spots of contaminated sediments that would be outside the slurry wall be
excavated and  incinerated.  The proposed design change would have left known hot spots
of contaminated sediment outside the slurry wall, substantially changing the scope and
cost of the remedy from that initially contemplated.  A Record of Decision Amendment,
signed by EPA in June 1995, eliminated the contingency requiring the incineration of any
hot spots of sediments that  would be left outside the slurry wall. The amended ROD
required these sediments to be excavated and placed behind the wall within the
encapsulated landfill.

Remedial Activities

Construction of remedial activities began in March 1996.  A cofferdam was built around
the embayment. After a fish survey was completed, game fish were removed from the
embayment. Contaminated sediments were removed from the embayment. Perimeter
soils were excavated and placed on site. The redesign discussed above enabled over 2
acres of embayment water resources to be saved. A slurry wall was built around the site to
prevent contaminants from leaking into the River. The final landfill cap was completed
in 1998, to  prevent rainwater from infiltrating the waste and carrying contamination off-
site.

An additional change in the remedial design is taking advantage of excess capacity at the
Love Canal Treatment Plant. Instead of on-site leachate treatment, a force main was
constructed to pump leachate from the 102nd Street Site to the Love Canal Treatment
Plant. This change did not delay the completion and optimization of the final remedial
action.

The leachate pumping system was completed in December 1998, at which time the
potential for contaminants to run to the River from this site was eliminated.  Landscaping
and optimization of the pump-and-treat system was completed in March 1999, and the
long-term operation and maintenance of the site was started.

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                                     A-28
Remediation Costs
Following are estimated amounts that have been spent to date on remediating this site:

       Federal       $ 9,900,000 (Indirect costs not included.)
       State         $ (State costs are included with EPA costs)
       PRP          $ 26,000,000

Costs for Operation and Maintenance expected to be incurred in the future are
approximately $100,000 per year, and will be paid by the PRPs.
   102ND STREET
Output
Final RI/FS Report
Record of Decision
Record of Decision Amendment
Remedial Design Start
Remedial Action Start
Remedial Action Completion
Responsible Party
PRPs (Olin and
Occidental)
EPA/DEC
EPA/DEC
PRPs
PRPs
PRPs
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED*
       The potential for contaminants to flow to Niagara River from this site was
       eliminated in December 1998, when the leachate pumping system was completed.
       Landscaping and optimization of the pump-and-treat system was completed in
       March 1999.

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                                      A-29

                        BELL AEROSPACE TEXTRON
                                     Site # 5

Site Program: RCRA (State and Federal)
Summary Prepared by: EPA and DEC

Site Description

The Bell Aerospace Textron plant is located approximately 2.5 miles north of the Niagara
River, adjacent to the Niagara Falls International Airport.

Between 1950 and 1980, the company used an unlined 60' X 100' surface impoundment
to collect wash water from rocket engine test firings, storm run-off, and solvent drippings
from cleaning, degreasing, and anodizing operations. Hazardous waste and constituents
of concern include trichloroethylene and dichloroethylene. The wastes were discharged
to a sanitary sewer after pH adjustment.

Beneath the site lies one overburden and two bedrock aquifers. Groundwater flow
through the overburden aquifer is primarily to the south-southeast.  There is a potential
vertical flow between the overburden and the upper bedrock aquifer, and at least some of
the  groundwater from the overburden discharges to Bergholtz Creek. The upper bedrock
aquifer flows primarily in a southeasterly direction and in the lower bedrock aquifer
groundwater flow is generally to the south. The down-gradient extent of groundwater
contamination in each of the three aquifers has been well defined, and, currently, no
contaminated groundwater appears to be discharging directly to the Niagara River.

Remedial Actions

Bell Aerospace Textron is an RCRA site with a closed surface impoundment.  The
company excavated 1225 tons of contaminated soil and capped the area in 1987.

All  of the remedial actions that were required here have been accomplished on schedule.

Since the initial 1989 hazardous waste site report, an RCRA Facility Investigation (RFI)
has determined the extent of contaminant migration and  a Corrective Measures Study
(CMS) has addressed on- and off-site groundwater contamination.  A State Part 373 post-
closure permit was issued to Bell Aerospace in September 1992, which will expire in
September 2003.  The permit required final Corrective Measures Implementation (CMI),
consisting of groundwater pump-and-treat programs for on- and  off-site contamination.
In addition, in October 2001 the facility has installed (on a voluntary basis) monitoring
wells through the cap of the Neutralization Pond as part of an ongoing investigation of
the  natural degradation of groundwater contamination at the facility.

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                                      A-30

The overall remedial program is designed to intercept the bedrock groundwater that is
migrating off-site toward the Niagara River. It consists of the installation of 11
groundwater extraction wells.

The off-site remedial system was started up in April 1993.  It is achieving its designed
objective. The capture zone associated with the system covers the area of groundwater
contamination, and the area! extent of the contamination is diminishing. Five extraction
wells have been installed to contain the off-site groundwater.  However, as the off-site
plume has become smaller, four extraction wells were determined to be optimal for
pumping. The extracted groundwater contamination is discharged into the publicly
owned treatment works (POTW) of the Town of Wheatfield. The off-site system is
designed to recover two pounds of volatile compounds daily.  The performance of the off-
site remedial system is considered  acceptable.

The on-site remedial system began the start-up operating period in April 1995. Several
technical problems prevented the on-site system from attaining all of its design
objectives. The remedial system was redesigned to address these problems, and the
following two modifications were  made:

•      The installation of a 900 foot-long pipeline to divert the cooling water discharge
       from a rocket testing facility operating at the site to the storm drainage system;
       and
•      The installation of a slurry  wall barrier along the main sewer line on Walmore
       Road to prevent the water migration from the sewer line to the on-site system.

However, even after these  modifications, the on-site system was still not attaining
satisfactory hydraulic containment. To address this, an additional extraction well was
installed along the southern boundary of the site. This well was installed in July 1998,
and is currently in operation. The  operation of this well has increased the groundwater
capture zone along the southern edge of the facility, but the capture zone was not
consistently continuous from two of the five extraction wells. A higher capacity pump
has been in operation on the new well since August 20, 1999, thus increasing the
groundwater pumping rate.

With the above modifications, the  on-site system is achieving its design goals. The on-
site system has been effective in creating a  groundwater capture zone, therefore, all
contaminated groundwater is being intercepted and treated on-site, so that no loading is
migrating from the site.  Six extraction wells are currently operating in the on-site system.
The operation of the higher capacity pump  has maintained a continuous capture zone.
Monitoring data of 2001 and the first quarter of 2002 indicates a complete capture zone
has been obtained along the southern boundary.  The on-site system is designed to recover
four pounds of volatile compounds daily.

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                                     A-31
Remediation Costs

Following are estimated amounts that have been spent through March 2002 on
remediating this site:

       Federal       $ (Oversight costs not available)
       State         $ (Oversight costs not available)
       PRP          $ 1,762,500 (Capital/Operation/Maintenance)

It is estimated that the following amounts will be spent from April 2002 over the next ten
years for operation and maintenance.

       Federal       $ (Not available)
       State         $ (Not available)
       PRP          $ 487,500

BELL AEROSPACE TEXTRON
Output
RFI Work Plan Approval
RFI Work Plan Approval for
Phase II
RFI Completion
CMS Work Plan Approval
CMS Completion
Remedy Selection
CMI Work Plan Approval
(off-site)
CMI Work Plan Approval
(on-site)
Start-up of CMI (off-site)
Start-up of CMI (on-site)
Responsible Party
DEC/EPA
DEC/EPA
Permittee
DEC/EPA
Permittee
DEC/EPA
DEC/EPA
DEC/EPA
Permittee
Permittee
Previous
Target Date
May 1990
None
Jul 1991
Dec 1991
May 1992
Oct 1992
Apr 1993
Sep 1993
Apr 1996
Nov 1994
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED

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                                     A-32

     OCCIDENTAL CHEMICAL - DUREZ DIVISION, NIAGARA FALLS
                        (Formerly BTL Specialty Resins)
                                    Site # 66

Site Program: RCRA (State and Federal)
Summary Prepared by: EPA and DEC

Site Description

Occidental Chemical Corporation (OCC) operates a phenol-formaldehyde resin
manufacturing plant at 5000 Packard Road, Niagara Falls, known until June 1986 as the
Varcum Chemical Division of Reichhold Chemicals, Inc. and until October 1989 as BTL
Specialty Resins. The 5-acre site is approximately 3 miles north of the Niagara River.

The hazardous wastes generated at this site are ignitable and/or toxic solvent washings
from reactor vessels, spilled raw materials and small amounts of laboratory samples.
These wastes are accumulated, stored, treated, and incinerated on site.

Under this site lie one overburden aquifer and four bedrock aquifers. Bedrock
groundwater flow is along both horizontal and vertical fractures.  In general, the
groundwater flow direction before remedial activities took place at the site was south to
southwest, with the upper most bedrock aquifer flowing southeast.

Interim Remedial Measures

Three recovery wells began pumping in February 1989 to capture and remediate the
groundwater under the site. These recovery wells affected groundwater flow in the
overburden and the upper bedrock aquifers. Most of the contaminated groundwater from
the uppermost bedrock aquifer and from the aquifer below it is captured by the recovery
wells.

In May 1990,  DEC issued OCC a state Part 373 Permit for the storage, treatment, and
incineration of hazardous waste on-site. An EPA Hazardous and Solid Waste
Amendments  (HSWA) permit was issued in March 1991.  Both permits required
corrective action. As required by the permits:

•      Four carbon-steel tanks were installed to replace a 30,000 gallon hazardous waste
       storage tank;
       The incinerator was modified with a larger burner, an expanded combustion
       chamber, a new double-layered refractory, a new control system, automatic alarm,
       and waste feed cut-off systems, and new instrumentation and piping. Prior to
       operation, a trial burn was conducted;
       Approximately 3,000 tons of phenolic-contaminated soil were removed from the
       tank farm area in 1990. Additional areas with contaminated soils were capped.

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                                      A-33
Site Investigation and Additional Interim Remedial Measures

The RCRA Facility Investigation (RFI) Work plan was approved in May 1990, and the
RFI was completed in November 1992.  The main area of chemical presence is beneath
the tank farm area on the east side of the facility.  The predominant overburden and
bedrock groundwater contaminants are total recoverable phenolics, ethylbenzene, total
xylenes, 1,2-dichlorobenzene, and 1,4-dichlorobenzene. The vertical extent of
groundwater contamination is limited to the overburden and the first three bedrock
aquifer zones. With the exception of the tank farm area, chemical concentrations in the
soils were less than action levels for soil ingestion. The soils are not a significant source
of groundwater contamination; nevertheless, all open spaces on the site have been paved
over.

As an interim corrective measure, beginning in February 1989, OCC has pumped bedrock
ground water contaminated with phenols and other organ ics (primarily non-chlorinated
solvents) to its biological treatment facility, prior to discharge to the Niagara Falls
Wastewater Treatment Plant.  EPA and DEC required OCC to submit interim reports to
assess whether groundwater was being remediated adequately, and to assess the need for
modifications, such as increasing pumping rates or installing additional wells. The
groundwater pumping rate was doubled  in 1990 with the addition of new treatment
capacity at OCC's treatment facility which was constructed that year.  Also, as an interim
corrective measure to address the overburden groundwater contamination at the tank farm
area, an overburden drain tile collection  system began operating in 1993. The purged
water is pretreated in the on-site wastewater treatment facility, prior to discharge to the
Niagara Falls Wastewater Treatment Plant.

From April 1994 through August 1998, 22,624,389 gallons of bedrock groundwater were
pumped and treated.  Since the start-up of the drain tile system in January 1993 through
August 1998, 189,620 gallons of overburden groundwater have been removed and
treated.  Approximately 25,442 pounds of contaminants have been removed.

Remedial Actions

The Corrective Measures study report has been approved.  EPA and DEC have
determined that the existing groundwater recovery systems which have been operating as
interim corrective measures are capable  of serving as the final groundwater remedy for
the facility. The DEC Part 373 permit was modified in September 1995 to specify the
final corrective measures.  In addition to operation of the groundwater recovery systems,
the final corrective measures include maintaining existing caps and pavement over areas
of contaminated soil, restricting site access, and restricting future site development.
Pursuant to the DEC  Part 373 permit, OCC prepares monthly reports on the operating
status of the groundwater recovery systems and is required to prepare comprehensive
annual reports on performance monitoring of the  recovery systems. The performance

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                                      A-34
monitoring includes hydraulic monitoring, to establish the extent of plume capture, and
chemical monitoring, to evaluate changes in groundwater quality.

The remedial actions that have come due at this site have been accomplished ahead of
schedule, and Corrective Measure Implementation is underway.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:

       Federal       $ (Not available)
       State         $ (Not available)
       PRP          $ (Not available)

It is estimated that the following amounts will be spent from now to the completion of
remediation:

       Federal       $ (Not available)
       State         $ (Not available)
       PRP          $ (Not available)

OCC -- DUREZ, NIAGARA FALLS
Output
RFI Work plan Approval
RFI Completion
Stabilization Start-up
CMS Work plan Approval
CMS Completion
Remedy Selection*
CMI Work plan Approval
Start-up of CM!
Responsible
Party
DEC/EPA
Permittee
Permittee
DEC/EPA
Permittee
EPA/DEC
EPA/DEC
Permittee
Previous
Target Date
Jul 1990
Sep 1992

Jun 1993
Dec 1993
Dec 1994
Feb 1995
Dec 1996
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
EPA and DEC have determined that the existing interim corrective measures groundwater pump-
and-treat program is capable of serving as the final groundwater remedy for the site. The DEC
Part 373 permit was modified in September 1995 to formally select the final remedy.

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                                     A-35

                      OCCIDENTAL CHEMICAL S-AREA
                                   Site #41A

Site Program: Federal/State Co-lead: Superfund
Summary Prepared by: EPA

Site Description

The S-Area site is an eight-acre landfill on Occidental Chemical Corporation's (OCC)
Buffalo Avenue Plant in Niagara Falls. The site is located approximately 200 yards north
of the Niagara River and immediately to the west of the former location of the old City of
Niagara Falls drinking water treatment plant.

The site was used primarily from 1947 to 1961 for the disposal of approximately 63,000
tons of organic and inorganic chemicals.  Chemicals deposited at the site included
chlorobenzenes, organic phosphates, acid chlorides, phenol tars, thionyl chloride,
chlorendic acid, trichlorophenol,  benzoyl chloride, liquid and chlorotoluene-based
disulfides, metal chlorides, thiodan, and miscellaneous chlorinated hydrocarbons.

One overburden and four bedrock aquifers exist under this site. While the bedrock
aquifers flow generally north-northwest onto the main OCC - Buffalo Avenue Site, only
the  overburden aquifer flows south to the Niagara River.

Requisite Remedial Technology Agreement

This National Priorities List site is a joint EPA/DEC-lead responsibility, governed by a
non-CERCLA settlement agreement, effective June 1985. The agreement provided for a
source control remedy, monitoring programs, and a remedial plan for the Niagara Falls
Drinking Water Treatment Plant  (DWTP). The DWTP main bedrock intake tunnel was
shut down due to the presence of non-aqueous phase liquid (NAPL) contamination. In
the  interim, the City's backup, emergency intake pipe was used to draw water from the
Niagara River. The S-Area site was surveyed by OCC from December 1986 to April
1988 to determine the extent of chemical migration from the landfill. This survey was the
basis for a Requisite Remedial Technology (RRT) report to EPA in November 1988.

As a result of the RRT Report and subsequent RRT negotiations among EPA/DEC, OCC
and the City of Niagara Falls, an  amendment (RRT stipulation) to the 1985 settlement
agreement was submitted to the court in September 1990 and approved in April 1991.
The RRT stipulation included construction of a new DWTP for the City of Niagara Falls
at a new location, to be funded by the City and OCC.

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                                     A-36

Remedial Actions

Most of the collection and containment remedial systems were installed at the landfill
from 1990 to 1995. Initial testing and operational start-up began on November 1, 1995.
The remedial systems are designed to eliminate the contaminant loadings from the site to
the Niagara River by containment and collection of contaminated ground water and
NAPL. Contaminated ground water and NAPL are currently being collected and treated
on-site. Assessment of the remedial systems performance began in early 1997,  and is
being done on a semi-annual basis.

One of the components of the landfill remedy (drain collection system) did not function
as designed during its initial operation.  An investigation in late 1997 revealed that the
system was improperly installed. OCC's efforts to enhance the performance of the drain
collection system in  1998 were unsuccessful and the EPA/DEC directed OCC to replace
the system in 1999. The new drain collection system was completed in early 2000 and  its
performance is presently being evaluated.

The work on the new drain collection system delayed the construction of the final landfill
cap.  The construction of the final landfill cap began in August 2000 and is on-going.

The new DWTP was completed and fully operational by March 1997. The remedial
activities for the old DWTP and property, including the decommission and demolition of
the plant, had to wait until the new DWTP was built and on-line. The demolition of the
old DWTP was performed in 1997 and early 1998. The eastern barrier wall, which
adjoins the other three sides of the S-Area barrier wall, was completed in May 1998. The
overburden drain collection system for the former DWTP was completed in 1999.
Construction of the DWTP cap was completed in 1999.

Securement of the raw water intake structures  from the old DWTP was scheduled for
completion in 2000. The grouting of the 5,000-foot long DWTP bedrock intake tunnel
commenced in August 2000.  However, due to problems encountered  in the field, the
remediation of this tunnel was not properly completed. A confirmatory boring  sampling
program was conducted in the summer of 2001, whereby a major void was discovered in
the tunnel grouting along a portion of the tunnel under Buckhorn Island and the Niagara
River.  It has been agreed by all regulatory parties and OCC that this ungrouted section of
tunnel poses no discernable environmental threat and will be used to monitor the
groundwater beneath the Niagara River at this location. A monitoring well will be
installed to sample the water in the tunnel during Summer 2002. This well will be
sampled as part of the overburden sampling program.

The  full remedial program  for this site consists of:

•      A slurry barrier wall in the overburden to contain the NAPL plume;
•      Installation of a drain system and collection wells (i.e., pumping wells)  in the
       overburden, within  the barrier wall, to:  1) collect contaminated ground water and

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                                      A-37

       NAPL, and 2) create an inward hydraulic gradient across the barrier walls and an
       upward hydraulic gradient from the underlying bedrock to the overburden within
       the barrier wall;
•      Installation of wells in the bedrock to contain NAPL by creating an inward
       hydraulic gradient across the bedrock NAPL plume boundary, and to collect
       NAPL from the bedrock, to the maximum extent practicable;
       Capping of the site to reduce infiltration;
•      Overburden and bedrock monitoring to determine the effectiveness of remedial
       systems;
•      Incineration of non-aqueous-phase liquids; and
       Treatment of contaminated groundwater by carbon adsorption and discharge to a
       permitted outfall.

The remedial systems will continue to operate for at least 30 years.

The following progress has been made:

•      The northern, western, and southern portions of the barrier wall were built in late
       1994/early 1995.
•      The drain collection system, collection wells, and the force mains for the drain
       and collection wells were completed in 1995 for the landfill. Additional wells
       were installed in 1997 to improve the performance of the system in collecting
       NAPL. The drain collection system for the former DWTP property was
       completed in 1999.
•      Operation of the landfill drain collection system and collection wells began in
       1996. As noted above, the drain collection system did not function as designed
       due to damage of the collection pipe and non-functioning stone backfill. The
       system was replaced in 1999-2000.
       A leachate storage facility and carbon adsorption treatment facility have been
       constructed on site and currently receive contaminated groundwater and NAPL
       from the overburden and bedrock collection wells.
•      A perimeter landfill cap was installed between March and August  1996 to reduce
       infiltration. It included a 2-foot clay layer and flexible membrane  liner near the
       Robert Moses Parkway, and asphalt paving west and north of the landfill.
•      The construction of the final landfill cap commenced in August 2000, and is
       nearly completed.  Reseeding of the cover material will be necessary in spring
       2002.
•      The new DWTP was completed in March 1997, and now supplies the City of
       Niagara Falls with its drinking water.
       The demolition of the old DWTP was completed in early 1998.
•      The eastern barrier wall at the DWTP property was completed in May 1998.
       The DWTP drain collection system was completed in 1999.
•      The construction of the DWTP cap was completed in 1999.
       The securement of the DWTP intake structure commenced in August 2000 and is
       on-going.

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                                      A-38
An updated schedule for completing the remaining remedial construction activities at the
site follows. EPA anticipates that all of the components of the remedy (including the
final S-Area and DWTP Bedrock RRT remedial system and related monitoring programs)
will be installed and should be fully operational by the end of 2003.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:

       Federal       $ 10,500,000
       State         $ (State costs were covered under EPA costs through grants)
       PRP         $ 45,000,000

It is estimated that the following amounts will be spent from now to the completion of
remediation:

       Federal       $ 1,000,000 (oversight)
       State         $ (Not available)
       PRP         $5,000,000  (Capital costs)
                    $ 2 to 3,000,000 per year for 30 years (Operation & Maintenance)

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                                             A-39
OCC S-AREA
Output
RRT Survey work (RJ) Completion
RRT Study (FS) approved
Record of Decision (RRT Stipulation)
Remedial Design (RD) Start
Remedial
Actions (RA)
Start
Construction of new
DWTP
Demolish old DWTP
DWTP cap & drain
collection system
Securement of raw
water intake
structures from the
old DWTP
Perimeter landfill
cap & drain
collection system
Final landfill cap
Construct Eastern
barrier wall
RA Completion
Responsible
Party
PRP
PRP
EPA/DEC
PRP
PRP
PRP
PRP
PRP
PRP
PRP
PRP
PRP
PRP
Previous Target
Date
___
—
Mar 1990
___
Jun 1991
Apr 1997
Sep 1997
1998
1999
N/A
1999
Jul 1998
2000
Current Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
2002'
COMPLETED
20022
COMPLETED
20033
  1 The securement of the DWTP intake structures, including the grouting of the 5,000-foot long
 bedrock intake tunnel, commenced in summer 2000.  Completion is tentatively scheduled in the
 summer of 2002.

  2 The construction of the final S-area Landfill cap commenced in August 2000 and should be
 completed by the end of the spring or summer of 2002.

  3 Construction activities for the year 2003 include the remaining bedrock  monitoring
 programs as well as the design, installation and evaluation of the Phase III  Bedrock System
 (final system) at both the S-Area and former DWTP property.

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                                     A-40

                           STAUFFER CHEMICAL
                                   Site # 255

Site Program: N.Y. Division of Hazardous Waste Remediation
Summary Prepared by: DEC

Site Description

The Stauffer Chemical Plant site occupies about 23 acres, located about 1/4 mile east of
the Niagara River in the Town of Lewiston.

Used for manufacturing from 1900 to 1976,  the site was occupied by Stauffer Chemical
from 1930 to 1976. Carbon tetrachloride and various metallic chlorides were produced
on site, and methylene chloride and tetrachloroethylene were repackaged from bulk
shipments.  Plant operations terminated in 1976, and the site was razed in 1980.  Disposal
occurred on the plant site, as well as in two small landfills on the PASNY property to the
east.

There are four significant, and one less significant, bedrock aquifers under the site. The
flow direction for all water-bearing layers is southwest, towards the Power Authority of
New York Forebay and the Niagara River.

Site Investigation

The Stauffer Chemical Plant site is a DEC-lead site. Pursuant to a  Consent Order,
Stauffer Chemical completed a Remedial Investigation/Feasibility (RI/FS) study of the
site.  The Record of Decision (ROD) was signed July 1992, and consent order for the
remedial design/remedial action was executed in July 1993.  The main components of the
remedial plan included bedrock groundwater pumping and treatment, and soil vapor
extraction, both on and off site.  The plan also included re-grading  of the site.

Delays in the original schedule were due to the need for additional  remedial investigative
studies to adequately define the nature and extent of contamination.

Remedial Activities

The remedial design was completed in July  1995. Extensive design work was necessary
for proper de-watering, including pump tests, soil vacuum extraction pilot test, DNAPL
treatment, and so on. Construction of the remedy has been completed.

Remedial actions completed include the following:

•      Installation of a bedrock pump-and-treat system that will operate for the next 30
       years.

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                                     A-41
       Installation of a soil vapor extraction and dewatering system that draws
       contaminants out of the soil.

Operational difficulties were encountered with the groundwater treatment system. This
was corrected in 1997. The groundwater treatment system has been modified.
Groundwater now flows through granular activated carbon prior to discharge to the
NYPA Forebay.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:
       State
       PRP
$   180,000
$5,100,000
It is estimated that the following amounts will be spent from now on Operation and
Maintenance of the remedial system:
       State
       PRP
$    10,000
$ 1,300,000
STAUFFER CHEMICAL
Output
RI/FS
Record of Decision
Remedial Design
Remedial Action Completion
Responsible
Party
PRP
DEC
PRP
PRP
Previous Target
Date
Sept. 1990
Jan. 1991
April 1993
April 1994
Current Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED

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                                     A-42

                            SOLVENT CHEMICAL
                                   Site #251

Site Program: N.Y. Division of Hazardous Waste Remediation
Summary Prepared by: DEC

Site Description

The Solvent Chemical site occupies approximately 6 acres in the City of Niagara Falls.
The site is located about 1/4 mile north of the Niagara River.

The Solvent Chemical plant site has been used for manufacturing operations at various
times from 1941 to  1978 by DuPont, Hooker Chemical and Solvent Chemical. DuPont
and Hooker produced impregnite; Solvent Chemical manufactured  chlorinated
hydrocarbons, zinc chloride and zinc ammonium chloride. Chemicals disposed on site
include zinc, benzene and chlorinated benzenes.

Five water-bearing layers have been significantly impacted by site contaminants: the
saturated overburden layer and four bedrock zones. The groundwater in the overburden
flows to the north. The bedrock aquifers generally flow to the northeast. Groundwater in
the site area is influenced by the Falls Street Tunnel (due north of the site), and the New
York Power Authority (NYPA) conduits (about 1,500 feet east of the site), which drain
bedrock groundwater in the area. The majority of the site ground water flows into the
Falls Street Tunnel, either directly or via the NYPA conduits. All of the dry weather  flow
through the Falls Street Tunnel now is treated by the Niagara Falls  Wastewater Treatment
Plant before discharge to the River.

Site  Investigation

The  Solvent Chemical site  is a DEC/Department of Law-lead site.  An initial Remedial
Investigation [RI] (funded by the Potentially Responsible Party [PRP]) was completed in
June 1991. Despite  lengthy negotiations, the PRPs did not agree to undertake the
Feasibility Study [FS]. The site was referred to State Superfund  for completion of the
RI/FS, while the Attorney General's office litigated the matter. Field work for
supplemental investigations needed to support the FS was completed in November 1994.
The  RI/FS report was approved in August 1996. The proposed Remedial Action Plan
was  submitted for public comment in September 1996.  The resulting Record of Decision
(ROD) was signed in December 1996. The Remedial Action Plan  includes the following
components:

       •      Existing buildings on site to be demolished.
       •      Storm sewer from the site to Gill Creek is to  be removed.
       •      Site  is to be capped.
       •      Contaminated groundwater is to be hydraulically controlled through pump-
              and-treat systems (including an off-site hot spot to the west).

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                                           A-43
             •      Pre-treatment system for contaminated groundwater.

      DEC and site PRPs completed legal agreements that require ROD implementation. The
      settlement was approved by the U.S. District Court in October 1997.  Construction was
      started in early 1998, but was delayed by lack of access agreements with adjacent
      property owners. Building demolition was completed in 1998. Installation of the
      extraction system in the off-site hot spot has been completed.  Removal of the off-site
      storm sewer began in July 2000.

      Construction of the groundwater extraction and treatment systems were completed in
      2001. Treatment system modifications are required in early 2002. The remedial system
      is expected to be fully operational after the modifications.  A performance monitoring
      program will begin in 2002 when the remedial system comes on-line.

      Remediation Costs

      Following are estimated amounts that have been spent to date on remediating this site:
             State
             PRP
$ 1,170,000
$ 2,950,000
      It is estimated that the following amounts will be spent from now to the completion of
      remediation:
             State
             PRP
$         0'
$11,250,000
      SOLVENT CHEMICAL
Solvent Chemical
RI
RI/FS
Record of Decision
Remedial Design Start
Remedial Action Start
Remedial Action Completion
Responsible Party
PRPs
DEC
DEC
PRPs
PRPs
PRPs
Previous Target
Date
Dec 1990
Sepl994
Dec 1994
Dec 1995
Dec 1996
May 2001
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
Dec 2002
1  PRP will reimburse future state costs.

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                                     A-44

                 VANADIUM CORPORATION OF AMERICA
                            (Formerly SKW Alloys)
                                    Site # 1

Site Program: N.Y. Division of Hazardous Waste Remediation
Summary Prepared by: DEC

Site Description

The Vanadium site is located approximately 1 1/2 miles east of the Niagara River in the
Town of Niagara.

The Vanadium Corporation of America owned and operated a facility at the site from
1920 to 1964 when approximately 594,000 tons of slag and other refuse were disposed at
the site. In 1964, the site was purchased by the Pittsburgh Metallurgical Company, which
subsequently changed its name to Airco  Properties, Inc.  Airco disposed wastes similar to
the wastes disposed by Vanadium. In 1979, SKW Alloys, Inc. bought 37 acres of the 62
acre parcel owned by Airco, while Airco retained ownership of the eastern 25 acres. The
Vanadium site consists of both properties as well as property owned by the Niagara
Mohawk Power Corporation and the New York Power Authority (NYPA) to the east and
north which also contains waste piles deposited by Vanadium. Chromium is a major
contaminant of concern at the site, as well as a caustic waste which is affecting the pH of
the ground and surface water.

The site contains 11 to 24 feet of overburden, consisting of clay, stratified drift and till,
underlain by Lockport Dolomite.  Groundwater flow in the area is influenced by the
NYPA conduits causing a groundwater flow divide which bisects the site. Groundwater
under the SKW site and most of the Airco site flows to the southwest. Groundwater
under the Niagara Mohawk site, the NYPA site, and the remainder of the Airco site flows
east into the conduit drain system.

Site Investigation and Interim Remedial  Measures

The Vanadium site is a DEC-lead site. A Phase I investigation was completed in
December 1989.  A Preliminary Site Assessment (Phase II investigation) is complete.
Wells were sampled in November 1992  and a report with results and recommendations
for site reclassification was completed in September 1993.

As a result of the Preliminary Site Assessment, the site was reclassified to a class 2
(significant threat to the public health or the environment, action required) on April 3,
1995. In 1997, DEC completed a study (IIWA) to further define the nature and extent of
contamination at the Niagara Mohawk and NYPA properties. For remediation purposes,
the site has been divided into three operable units: OU#1 (SKW), OU#2 (Airco), and
OU#3 (Niagara Mohawk and NYPA).

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                                     A-45

Under Consent Order, SKW completed an Interim Remedial Measure to cover portions of
their parcel and control site storm water runoff. This remedial measure was completed in
November 1998. DEC and Airco negotiated an Interim Remedial Measure (IRM) to cap
the landfill on their portion of the site. Closure of the Airco portion of the site (OU No.
2) was completed by December 2000.

Schedule for Completion

A schedule for completion is presented below. The site PRPs have not agreed to act as a
group. This has contributed to delays in the schedule  due to the need to negotiate
individually with the PRPs. Niagara Mohawk and the NYPA have agreed to conduct a
Remedial Investigation of OU No. 3. A scope of work has been approved, and field work
is expected to commence in the summer of 2002.

Remediation Costs

Following are estimated amounts for the Interim Remedial Measures:

OU#1:

       State               $  30,000
       PRP               $ 750,000

OU#2:

       State:               $   75,000
       PRP               $ 4,500,000

It is estimated that the following amounts will be spent from now to the completion of
remediation:

       State               $ (Not available; site has yet
       PRP               $ to proceed to final remediation)

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                            A-46
VANADIUM CORPORATION OF AMERICA
Output
Phase I Investigation
Phase II Investigation
IIWA Investigation
Interim Remedial Measure
Interim Remedial Measure
RI/FS (Operable Unit #3)
Record of Decision (site wide)
Remedial Design
Remedial Action
Responsible Party
DEC
DEC
DEC
SKW Alloys, Inc.
Airco
Niagara Mohawk
And NYPA
DEC
PRP or DEC
PRP or DEC
Previous
Target Date
Dec 1989
Dec 1991
Augl997
Dec 98
Dec 2000
Mar 2001
July 2001
July 2002
July 2003
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
July 2003
Schedule
dependent on
results of OU
No. 3 Remedial
Investigation.

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                                      A-47
                             OLIN CORPORATION
                                   Site #58, 59

Site Program: RCRA (State and Federal)
Summary Prepared by: EPA and DEC

Site Description

The Olin Corporation site, 25 acres located on Buffalo Avenue in Niagara Falls, is
actually two plants on separate but contiguous sites, partially separated by the property of
the E.I. DuPont Company. Gill Creek flows through the eastern part of the facility. The
site is about 1/4 mile North of the Niagara River.

Olin Corporation has used this site for inorganic chemical production since 1897.  Several
organic chemicals, including benzene, chlorobenzene, trichlorobenzene, and
trichlorophenol were used or manufactured between 1950 and 1956. Wastes handled at
this facility include: ignitable, corrosive, reactive, and EPA toxic characteristic wastes
and Resource Conservation and Recovery Act (RCRA)-listed wastes (brine purification
muds and wastewater treatment sludge from mercury-cell chlorine production).  Brine
sludge, containing mercury and possibly polychlorinated bi-phenyl, was used as fill
material in various locations throughout the site.

The site consists of soil and gravel at 0-3.5 feet, sandy clay at 3.5-5 feet.  The bedrock
surface lies at 5.5-8 feet.  Proximity to the Niagara River and Gill Creek indicates a major
potential for contaminant migration. Ground  water on the site exists in shallow
unconsolidated deposits and in a bedrock aquifer composed of 3 monitored zones.
Shallow groundwater infiltrates to Gill Creek, which discharges to the Niagara River.

In 1984, EPA issued  Olin Corporation a RCRA permit to operate the hazardous waste
storage and treatment facilities on this site, but since it was issued before the Hazardous
and Solid Waste Amendments to RCRA were enacted, it did not incorporate corrective
actions. EPA issued  an order in September 1989, requiring investigation of releases
throughout the site, and particularly from the brine mud  storage area, where releases have
occurred. Permitted units were closed in  1990, according to a DEC-approved closure
plan.

Interim Remedial Measures

Under a joint venture with DuPont, Olin conducted the off-site remediation of Gill Creek
from Buffalo Avenue to the Niagara River, which was completed in December 1992.
Contaminated sediment was removed, and the creek has been restored.

An EPA/DEC-approved DNAPL interim corrective measure (ICM) was implemented by
Olin during May and June 1994. The program was intended to identify and characterize

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                                     A-48

any DNAPL presence in five Olin monitoring wells and to remove any DNAPL
encountered. DNAPL was only detected in one well and a total volume of less than two
gallons was removed.

Former Olin production wells are currently being used to pump and treat ground water
from the site through an agreement with the adjacent DuPont facility. The Olin wells
serve as part of DuPont's bedrock groundwater remediation program and exert a large
radius of influence over the Olin site, which effectively reduces the total toxic load
migrating from the Olin site. The radius of influence of the Olin wells extends
approximately halfway (east-west) across Olin's Plant 2 in the B zone, and approximately
to Gill Creek in the lower aquifer zones and CD zones). The remedy approved in the
CMS is designed to capture all groundwater contamination not captured by the Olin
production wells. The wells extract groundwater at a rate of approximately 600 gallons
per minute continuously.

Site Investigation and Remedy Selection

Olin has conducted soil and hydrological studies, and submitted several supplemental RFI
reports to the EPA/DEC.  Olin has completed the final phase of the RFI, and the final RFI
report was approved by EPA and DEC in February 1995. Mercury was detected in the
soils in concentrations up to 1,210 parts per million. Volatile and semi-volatile organic
constituents and pesticides were also identified in the soils. Sampling of twenty-four
overburden and bedrock wells identified volatile and semi-volatile constituents,
pesticides, and mercury at levels exceeding federal and state groundwater  standards.

Work plans for both Phase I of the CMS (soil & overburden groundwater) and for Phase
II of the CMS (bedrock groundwater) were previously approved by EPA/DEC.  In March
1995 Olin submitted a full CMS Report (incorporating both Phases I and II), which was
approved by EPA/DEC in September 1995. In July 1996, the proposed remedy for this
site was public noticed.  Following public review, a remedy was selected and the CMI
Work plan approved. The remedy includes the following components:

•      Drilling and installing 5 groundwater recovery wells at Olin's plant 2  site. The
       recovered groundwater will be pumped to a new on-site treatment  plant before
       being discharged into the City of Niagara Falls sewer system.
•      Paving all unpaved surfaces in order to minimize the volume of contaminated
       groundwater recharge.

DEC issued a Consent Order to implement the selected remedy. The remedial system
was constructed and began operation in October 1997.

Operation & Maintenance is now underway. The remedial system is close to meeting its
performance objectives. Olin is addressing problems due to incrustation associated with
high pH (>10) groundwater. For example, two pumps have been replaced and a system to

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                                      A-49

inhibit scaling of the pumps and pipes has been installed. Recent performance reports
indicate that system performance has improved, but more actions may be necessary.

An updated schedule for implementation of a corrective action program, including
Corrective Measure Implementation (CMI), follows. The scheduled project milestones
relate to complete on- and off-site investigation and remediation.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:

       Federal      $ (Not available)
       State         $ (Not available)
       PRP         $ (Not available)

It is estimated that the following amounts will be spent from now to the completion of
remediation:

       Federal      $ (Not available)
       State         $ (Not available)
       PRP         $ (Not available)

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                                     A-50
OLIN CORPORATION
Output
RFI Work Plan Approval
RFI
Completi
on
Phase I
Phase II
Stabilization Start-up
(Ground water)
CMS
Work
Plan
Approval
Phase I
Phase II
CMS Completion
(including approval)
Remedy Selection
CMI Work Plan Approval
Start-up of CMI
In itiation/Stabi 1 ization
Responsible
Party
DEC/EPA
Permittee
Permittee

Permittee
DEC/EPA
Permittee
DEC/EPA
DEC/EPA
Permittee
Previous Target
Date
Apr 1990

Dec 1994


Sep 1993
Mar 1995
Mar 1996
Mar 1996
Dec 1996
Current Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
Note:   Phase 1 - Overburden soil and groundwater
       Phase II - Bedrock groundwater

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                                      A-51

                        DUPONT -- BUFFALO AVENUE
                                   Site ff 15-19

Site Program: N.Y. Division of Hazardous Waste Remediation
Summary Prepared by: DEC

Site Description

The DuPont Buffalo Avenue Plant site occupies over 50 acres in the City of Niagara
Falls. The plant is separated from the Niagara River by the Robert Moses Parkway.

Manufacturing operations have been conducted at the site since 1898.  Chemicals
disposed on the site included: carbon tetrachloride, chloroform, dichloroethylene,
methylene chloride, trichloroethylene, tetrachloroethylene, vinyl chloride, PCBs, barium
and other organic and inorganic compounds.

One overburden and five bedrock aquifers exist under this site, each consisting of two or
three zones with different flow directions.  Groundwater flowing south discharges into
the Niagara River and Gill Creek. Groundwater flowing north discharges into the unlined
Falls Street Tunnel, and groundwater flowing east, into the New York Power Authority
(NYPA) conduit drain system.

Remedial Actions

As of January 1992, all remedial systems at this site were  completed and operating. More
than 60 studies of subsurface contamination were completed by DuPont on the plant site,
and a Consent Order was negotiated for the implementation of a groundwater remediation
program. In January 1992, an on-site groundwater pump-and-treat system went into
operation. A portion of the flow from the western half of the DuPont site  is under the
influence of the Olin  production wells.  This water is remediated by the Olin Treatment
Plant before discharge to the river.

Additionally, DuPont is a Potentially Responsible Party for the remediation of Gill Creek,
which was completed in December 1992. A total of 8,020 cubic yards of contaminated
sediment was removed, and the creek has been restored. Five-years of post-remediation
monitoring of Gill Creek sediments was completed in 1998. Monitoring reports do not
indicate PCB re-contamination in the sediment of the Gill Creek remediation area.

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                                     A-52


Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:
       State
       PRP
$    50,000
$ 43,600,000 (includes Gill Creek remediation)
It is estimated that $ 1,600,000 will be spent annually by the PRP on the Operation and
Maintenance of this site.
    DUPONT BUFFALO AVENUE
Output
Record of Decision
Remedial Design
Remedial Action
Responsible Party
DEC
PRP
PRP
Status
COMPLETED
COMPLETED
COMPLETED

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                                       A-53

                       BUFFALO COLOR CORPORATION
                                  Site# 120, 122

 Site Program: RCRA (State and Federal)
 Summary Prepared by: EPA and DEC

 Site Description

 Buffalo Color Corporation, located on 61 acres adjacent to the Buffalo River within the
 city of Buffalo, is a major manufacturer of indigo dye.

 This plant, which was originally built in 1879 by the Schoelkopf Aniline and Dye
 Company, merged with two other companies to form the National Aniline and Dye
 Company in 1916, one of five companies forming Allied Chemical Corporation in 1920.
 Buffalo Color Corporation purchased and began operating the dye plant in 1977.

 Dyestuffs and/or organic chemicals have been continuously produced at the facility for
 more than 110 years. The dye manufacturing operations generate approximately 450,000
 gallons per day of process waste water.  The waste water is a Resource Conservation and
 Recovery Act (RCRA) hazardous waste due to its corrosivity (pH > 12.5).  RCRA
 hazardous constituents in this waste stream include:  aniline, N-methylaniline, N,N-
 dimethylaniline, N,N-diethylaniline, cyanide, methanol, nickel, and chromium.  Prior to
 1971, these wastes were discharged directly to the Buffalo River. In 1971, Allied
 Chemical diverted the waste streams to three surface impoundments for neutralization
 prior to release to the Buffalo Sewer Authority, and beginning in March 1989, Buffalo
 Color installed a new neutralization tank to treat wastewater before discharge to sewers.

 The stratigraphy at the  site from the upper to lowermost units is: 2-11 feet of fill, 6-13
 feet of silt and fine sand (upper aquifer), 25-37 feet of silty clay, 5-7 feet of sand and
 gravel (lower aquifer),  and bedrock of Onondaga Limestone. Groundwater flow in the
 upper aquifer is towards the Buffalo River. Groundwater near the surface impoundments
 is contaminated with aniline, dimethylaniline, N-ethylaniline, and cyanide, all of which
 most likely derive from the surface impoundments.

 Site Investigation

 A RCRA Facility Assessment (RFA) Preliminary Review and Visual Site Inspection were
 completed during 1986 and 1988, respectively. Eight (8) Solid Waste Management units
 (SWMUs) have been identified at the site. Overburden ground water monitoring wells at
 the impoundments show concentrations of chlorobenzene, dichlorobenzenes, toluene,
 anilines and phenol above DEC-promulgated ground water standards. An RFA  soil
 sampling program for a container storage area was completed in January 1991.  EPA and
.DEC identified a need  to investigate potential releases from both the extensive sewer
 system and from two inactive buildings  at the site.

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                                     A-54

A DEC Part 373 post-closure permit was public noticed in 1992 to address releases.  The
facility objected to several conditions of the draft permit and requested an administrative
hearing. All outstanding issues were resolved and the Part 373 permit became effective
on February 10, 1995.  Remediation will be implemented under the Part 373 permit.

The RFI Work plan has been approved.  The RFI includes a subsurface (soil and
groundwater) investigation program for all areas of the plant except for Area D, which is
being remediated under the New York State Inactive Hazardous waste program (see  Area
D summary for details).

       Field work for Phase I of the RFI began in April 1996 and consisted of 18
       monitoring wells around the perimeter of the site to evaluate groundwater quantity
       and potential migration of hazardous constituents off site.
       Phase II of the RFI, completed in September 1996, involved the advancement of
       24 soil probes within the site to collect near and sub-surface soil samples.

Hazardous contaminants were detected at the perimeter monitoring wells during the
Phase I and II investigations for the RFI.  In November 1996, BCC proposed
supplemental investigations (involving 10 additional wells) to determine the off-site
extent of contamination. DEC approved the proposal in December 1996. In January
1997, BCC proposed the collection of 6 additional surficial samples to provide further
support of a corrective measures study.  DEC approved the proposal in March 1997.
BCC submitted the RFI report in November 1997. In response to DEC comments on the
RFI, BCC submitted a second supplemental  investigation plan involving 8 new wells, 5
piezometers, and 10 soil samples. This proposal was approved in July 1998 and
implemented during the summer of 1998. A revised RFI report was submitted in
December 1998 and approved in  April 1999. A Corrective Measures Work Plan was
submitted in May 1999 and approved in July 1999.  In July 2000, the Corrective
Measures  Study Report was approved. However the approval does not constitute
approval of the Risk Assessment provided in the report. The Risk Assessment is based in
part, on USEPA Industrial/Commercial Risk-Based  Levels,  that are not completely
accepted by the NYS Department of Health. In addition, there were cases in which the
method detection limits for soils were not sufficiently low to evaluate comparison with
the risk levels.

During July 1999, a pump test was performed to aid in the design of Corrective Measures
for Plant Area A, to prevent the discharge of contaminated groundwater into the Buffalo
River. The pump test indicated that conventional pumping wells should be effective in
controlling the migration of contaminated groundwater in Plant Area A, and that
migration control should be achievable with a total system pumping rate on the order of
25-30 gpm. Such a system has been proposed as part of the final corrective measures,
within the CMS report.

The supplemental investigations  delayed completion of the RFI. All target dates in the
table below account for these delays. Remedy selection and CMI  implementation have

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                                      A-55
been delayed due to the financial viability of the company. Completion of the milestones
is dependent, in part, on field conditions encountered, which may delay the overall
schedule for corrective action.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:

       Federal       $ 0
       State         $ 0
       PRP         $ (Not available)

It is estimated that the following amounts will be spent from now to the completion of
remediation:

       Federal       $ (Not available)
       State         $ (Not available)
       PRP         $ (Not available)

BUFFALO COLOR CORPORATION
Output
RFA Work Plan Approval
RFA Completion
RFI Work Plan Approval
RFI Completion
Stabilization Start-up
CMS Work Plan Approval
CMS Completion
Remedy Selection
CMI Work Plan Approval
Start-up of CMI
Responsible Party
EPA/DEC
Permittee
EPA/DEC
Permittee
Permittee
EPA/DEC
Permittee
EPA/DEC
EPA/DEC
Permittee
Previous
Target Date
Mar 1990
May 1990
Mar 1995
July 1997
Jan 1998
Jan 1998
Jul 1998
Nov 1998
Apr 1999
Oct 1999
Current Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
N/A*
COMPLETED
COMPLETED
May 2002
September 2002
March 2003
* Results of a 1999 pump test indicated that conventional pumping wells should be
effective in controlling the migration of contaminated groundwater in Plant Area A, and
that migration control should be achievable with a total system pumping rate on the order
of 25-30 gpm.  Such a system has been proposed as part of the final corrective measures,
within the CMS report.

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                                     A-56
                         BUFFALO COLOR - AREA D
                                 Site# 120-122

Site Program: N.Y. Division of Hazardous Waste Remediation
Summary Prepared by: DEC

Site Description

Area D of the Buffalo Color Plant site occupies about 19 acres adjacent to the Buffalo
River in the City of Buffalo. The site is about 4 miles upstream of the confluence of the
Buffalo and Niagara Rivers.

Area "D" is an inactive hazardous waste site.  It was used from 1905 to  1974 as a
chemical manufacturing, handling and disposal site. From 1905 to 1920, acids, chemicals
and dye intermediates were produced by Contact Process Company and by National
Aniline Chemical Company, which merged into Allied Chemical and Dye Corporation in
1920. Allied Chemical and Dye Corporation manufactured petroleum-based detergents,
dye intermediates, picric acid, and other chemicals at Area "D" from 1920 to 1974.
During that time, a number of structures, railroad tracks and tank parks  were built at the
site. All chemical manufacturing operations ceased in 1974, and chemical waste handling
ceased in 1976 at Area "D".  In  1977, the property was sold to Buffalo Color Corporation
and remained idle.  All structures on the site were demolished to grade by Buffalo Color
Corporation in 1984.

The site overburden consists of fill, alluvium, glaciolacustrine deposits  and glacial till,
and is underlain by the Onondaga Limestone. The shallow overburden  water-bearing
zone on the site is in direct hydraulic connection with the Buffalo River. The major
pathways of contaminant migration from the site to the Buffalo River was shallow ground
water and erosion of the  shoreline.

Site Investigation and Remedy Selection

The Buffalo Color Area D site is a DEC-lead site. Pursuant to a Consent Order, the PRPs
(Buffalo Color and Allied Chemical) conducted a Remedial Investigation (RI), which was
first submitted in April 1989 and approved in September 1990. The RI indicated elevated
levels of Polynuclear Aromatic  Hydrocarbons (PAHs), chlorinated benzenes and heavy
metals in the site fill layer. The site groundwater was found to be contaminated  by
volatile organics, chlorinated benzenes, iron and other heavy metals and non-aqueous
phase liquid (NAPL).

A Feasibility Study (FS) was submitted in December 1990, with final revisions submitted
and approved in July 1991.  The FS evaluated 13 alternatives for the remediation of the
site and identified a preferred alternative; all were discussed at a public meeting in

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                                     A-57
October 1991.  A Record of Decision (ROD) was signed in November 1991, setting forth
a selected remedial plan.

An Order on Consent was signed by Allied Signal and NYSDEC in June 1993 for the
remediation of the site.  Construction of the selected remedy began in June 1996.  The
Remedial Action was completed in September 1998.

The following are the elements of the remedy completed in September 1998:

•      A slurry wall was constructed around the entire site;
•      River sediments adjacent to the site were dredged and deposited on-site. The
       shoreline was armored with rip rap;
•      A high-density polyethylene liner was placed over the entire site and properly
       capped;
       Groundwater is being pumped and treated at an on-site treatment facility.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:
       State
       PRP
$    200,000
$ 14,000,000
    BUFFALO COLOR -- AREA D
Output
RI/FS
Record of Decision
Remedial Design
Begin Remedial Construction
Remedial Action Completion
Responsible Party
PRPs
DEC
PRPs
PRPs
PRPs
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED

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                                     A-58

                    BETHLEHEM STEEL CORPORATION
                                   Site# 118

Site Program: RCRA (State and Federal)
Summary Prepared by: EPA

Site Description

The Bethlehem Steel Corporation (BSC) facility encompasses approximately 2.5 square
miles, located on Hamburg Turnpike, Lackawanna. Buffalo Harbor marks the northern
boundary of the site, and Lake Erie marks its western  boundary.

BSC is a former major manufacturing plant that produced structural steel, coke, coke
byproducts and specialty steel products.  Processing occurred primarily on the eastern
section of the site. The western section of the site was created by landfilling 440 acres of
Lake Erie with slag from processing. Since 1983 the facility has significantly reduced
manufacturing operations.  Most of the former production areas have been closed and
demolished.  Until the fall of 2001, the galvanizing and coke production processes were
the only areas in operation. The coke ovens were closed in the fall of 2001 and coke
production ceased.  Over 100 Solid Waste Management Units have been identified at the
site. Six surface water bodies on site have been identified as having received hazardous
waste or hazardous constituents from BSC.

Within the Buffalo-Lackawannaarea, all surface and  ground waters ultimately drain into
Lake Erie. Preliminary information concerning site-wide hydrogeology indicates that
contaminated groundwater flows east to west into  Lake Erie. Groundwater also appears
to enter both Smokes Creek and the Ship (or Lackawanna) Canal.  In the area
immediately surrounding the two regulated surface impoundments, groundwater flows
west towards Lake Erie.  Also, transecting the site are trenches, which drain from the
process area into Smoke and Blasdell Creeks. The Ship Canal drains northward into
Buffalo Harbor.

Site Investigation

EPA issued a consent order in August 1990 requiring an on-site RCRA Facility
Investigation (RFI). The RFI investigation is being conducted in a multi-phase approach.
Initial phases of the investigation (Phase I and Phase HA) were conducted between 1990
and 1993.

BSC submitted the Phase II-B RFI Report in November 1994. These investigations have
identified benzene, naphthalene, phenolic compounds, and metals in groundwater
samples collected from monitoring wells at the facility. Due to the complexity of site
conditions that have been encountered at the facility in previous investigations, EPA and
DEC required BSC to conduct a Phase III RFI investigation  to fill in data gaps. Field
work for this investigation was completed in September 1995. Negotiations over the

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                                      A-59

scope of the human health risk assessment, which is required as part of the RFI report,
have delayed the submittal of the RFI and human health risk assessment. In July 1996,
EPA approved the Ecological Risk Assessment Work Plan, and BSC completed a draft of
this assessment, which is also a component of the RFI. A review of the draft Ecological
Risk Assessment revealed that additional data collection was necessary to complete the
assessment. As such, BSC submitted an Ecological Sampling Work Plan and a
Supplemental Solid Waste Management Unit Work Plan in May 2000 to address
collection of the additional data. This data was collected in 2001 and will be incorporated
into the RFI Report.

EPA and DEC have identified two areas (Acid Tar Pits and Coke Oven Areas) where
BSC should consider implementing stabilization or interim corrective measures to control
and reduce the further spread and off-site migration of contaminated groundwater from
the facility. These two areas appear to be the primary sources of groundwater
contamination at this  facility. BSC has not implemented any interim corrective action or
stabilization activities to address the contamination in these areas to date. However, BSC
has submitted a Pre-design Investigation Report for the remediation of the Benzol Plant
Area (i.e., Coke Oven Area). The implementation of the remedial work in the Benzol
Plant Area has been delayed due to a dispute over the characterization of the wastes in
that area. BSC also previously proposed and performed two remedial technology studies
for the acid tar pit area.  These studies were found by the EPA and NYSDEC to be
technically flawed and of limited value. Any future CMS or CMI activities will require a
new order, permit or other agreement.

Following approval of the RFI report, a site-wide CMS Work Plan, with a schedule, will
be required of BSC.  The scope of this Work Plan will be partly determined by the results
of the Human Health  and Ecological Risk Assessments.

BSC also submitted an application for two Corrective Action Management Units
(CAMUs) to NYSDEC and EPA.  The Agencies have determined that BSC's application
is considered "substantially complete." BSC subsequently submitted a 30% design for the
CAMU and continues to meet with NYSDEC on the CAMU issue. This will allow the
potential for CAMUs to be utilized as part of a future remedy at the facility.

While RFI activities are being completed,  EPA has removed approximately 102 acres of
the facility from the RFI Order to facilitate brownfields type redevelopment. This acreage
is not believed to be significantly contaminated and may be suitable for redevelopment.
BSC and NYSDEC are negotiating a Work Plan and Order for investigation of the parcel.
The negotiations for the Work Plan and Order are currently stalled due to disagreement
between BSC and NYSDEC.

BSC filed for Chapter 11 bankruptcy in October of 2001. This has cause delays in the
implementation of various site activities.

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                                     A-60
A current schedule for implementation of a corrective action program at the facility,
including CMI, follows. Due to delays caused by several problems outlined above, the
proposed schedule was extended. All subsequent target dates were extended accordingly.
Completion of the outputs is dependent on 1) the nature and extent of contamination
found on- and off-site (and thus the complexity of remedial measures required); and 2)
the timeliness in which the planning and implementation of work plans and reports are
submitted by the facility and approved by EPA and DEC. The scheduled project
milestones relate to complete on- and off-site investigation and remediation.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:

       Federal       $ (Not available)
       State         $ (Not available)
       PRP          $ (Not available)

It is estimated that the following amounts will be spent from now to the completion of
remediation:

       Federal       $ (Not available)
       State         $ (Not available)
       PRP          $ (Not available)

BETHLEHEM STEEL CORPORATION
Output
RFI Work Plan Approval
RFI Completion
RFI Report Approved'
Responsible Party
EPA/DEC
Permittee
EPA/DEC
Previous Target
Date
Jan 1990
Mar 2000
Apr 2001
Current
Schedule
COMPLETED
Apr 2001
July 2002
CMS/CMI
Issue CMS/CMI Order
CMS Work Plan Approval2
CMS Completion2
Remedy Selection
CMI Work Plan Approval2
Start-up of CMI2
DEC/EPA
DEC/EPA
Permittee
DEC/EPA
DEC/EPA
Permittee
July 2000
Oct 2000
June 2001
Oct 2001
Aug 2002
Dec 2002
July 2002
Oct 2002
June 2003
Oct 2003
Aug 2004
Dec 2004

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                                      A-61

1   RFI to include human health and ecological risk assessments.

2   These outputs will require a new order, permit or other agreement. Target dates
dependent upon facility owner/operator agreement to complete these stages of site
corrective action program.

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                                     A-62

                       RIVER ROAD (INS EQUIPMENT)
                                   Site# 136

Site Program: N.Y. Division of Hazardous Waste Remediation
Summary Prepared by: DEC

Site Description

The River Road site occupies approximately 23 acres in the Town of Tonawanda. The
site is adjacent to the Niagara River.

The River Road site was utilized for waste disposal from the early 1920s through the late
1970s. Disposed on site were steel and coke industry wastes, consisting of foundry sand,
coke sludges, oils, solvents and slags.

The overburden at this site consists of 15 to 20 feet of fill over glaciolacustrine deposits
and till. The overburden is underlain by Onondaga Limestone.  The two overburden
aquifers on site flow west towards the Niagara River.

Site Investigation

The River Road site is a DEC-lead site.  Negotiations with the six Potentially Responsible
Parties (PRPs) for an RI/FS were not successful, causing a delay in targeted remedial
action dates. The PRPs did not agree to conduct an RI/FS; therefore, the State undertook
the task under State Superfund.  The RI/FS was completed in January 1994 and the record
of decision (ROD) was signed in March 1994. The River Road site was combined with
the adjacent Niagara Mohawk-Cherry Farm site for joint remediation (see following site
description).  Some PRPs agreed to remediate the site and signed an order of consent in
September 1994. The  remedial design was completed in February 1996, that consisted
of:

       •      Capping the site with clean soil;
       •      Pulling back, grading, and stabilizing the shore line;
       •      Removing some river sediments; and
       •      Installing groundwater collection trench and recovery wells.

Remedial Actions have been completed,  including sediment removal. Sediment removal
began in July 1998 and was completed November 1998. Final capping of the sediment
disposal area was completed July 1999. The Construction Certification Report and
Operation, Maintenance and Monitoring  Plan were approved in January 2000.

Diver inspection of the dredged areas shows good revegetation and recolonization by fish.

Groundwater is collected, treated at an on-site treatment facility, and discharged to the
local POTW.

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                                    A-63
Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:
      State
      PRP
$   546,000
$15,000,000*
    RIVER ROAD (INS EQUIPMENT)
Output
RI/FS
Record of Decision
Remedial Design
Remedial Action
Completion
Responsible Party
DEC
DEC
PRPs
PRPs
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
* Costs include Niagara Mohawk Cherry Farm site.

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                                      A-64

                   NIAGARA MOHAWK -- CHERRY FARM

Site Program: N.Y.S. Division of Hazardous Waste Remediation
Summary Prepared by: DEC

Site Description

The Cherry Farm Site is an inactive landfill located between River Road and the Niagara
River in the Town of Tonawanda, New York.  The site encompasses approximately 56
acres, 80% of which is covered by various fill  materials. The fill material consists
primarily of foundry sand, slag, and cinders. The surface of the fill is between 10 to 20
feet above the original surrounding land surface. The present topography of the filled
area is essentially flat.

The fill area is surrounded by intermittent surface water. A wetland designated as BW-6
by DEC is present on the eastern portion of the Site. This wetland drains into the
drainage ditches which flow along the southern and northern boundaries of the property
and ultimately discharge to the Niagara River, which forms the western side of the Site.

Site Investigation/Remedial Design

A Record of Decision (ROD) for the site was signed by DEC in February 1991.  The
selected remedy included covering the site with an impermeable cap, along with ground
water containment, collection, treatment, and disposal. After additional field
investigations and discussions with the PRPs,  the ROD was amended on October 7, 1993.
The differences between the remedies include I) the cover design will include a
permeable soil cover; 2) collected ground water will not be discharged into the Niagara
River, but will be pretreated and discharged to a local water treatment plant;  and 3)
fencing will not be installed around the site as part of the remedy.  The revised remedy
will allow for development of the site as a park after remedial construction is completed.
In addition, the remedial action includes fish and wildlife habitat
enhancements through the construction of shoreline wetland embayments along the
Niagara River.

A consent order between DEC and the PRPs to complete the design and construction of
the remedy was signed in September  1994. The Niagara Mohawk-Cherry Farm site was
combined with the adjacent River Road site for joint remediation.  Please see the previous
site description (River Road) for details on the remedial action. The remedial work is
complete.

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                                     A-65
Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:
      State
      PRP
$'
$'
     NIAGARA MOHAWK - CHERRY FARM
Output
RI/FS
Record of Decision
Remedial Design
Remedial Action
Responsible
Party
PRPs
DEC
PRPs
PRPs
Current Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
Remediation of the Cherry Farm site was completed as part of the River Road RI/FS.
Costs are reported in the River Road site description.

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                                     A-66
                    FRONTIER CHEMICAL, PENDLETON
                                    Site # 67

Site Program: N.Y. Division of Hazardous Waste Remediation
Summary Prepared by: DEC

Site Description

The Frontier Chemical site in the Town of Pendleton occupies about 21 acres adjacent to
Bull Creek, approximately 4 1/4 miles inland from the Niagara River.

Approximately 7.5 acres of the site were used for treatment and disposal of hazardous
wastes.  From about 1958  to 1974, Frontier Chemical used the site for processing, storage
and burial of industrial and hazardous wastes.  Unknown volumes of solvents, oils, acids,
dyes, paint wastes, heavy metal sludges, and other wastes were handled on the site. An
on-site lake was used for disposal of metal salt sludges from the neutralization of plating
wastes and pickling liquors.

The site consists of various amounts of fill underlain by glaciolacustrine silty clay to a
depth 20 to 30 feet.  The silty clay is underlain by glacial till and then  bedrock, which is
believed to be Lockport Dolomite. Shallow groundwater on the site flows radially from
the site, very slowly, with  some discharge to the on-site lake.

Site Investigation

DEC completed a remedial investigation/feasibility study (Rl/FS) of the site  using State
Hazardous Waste  Remediation  Program funds. The Record of Decision (ROD) was
finalized in March 1992.  The remedial design completed in May 1995 calls  for the
following: dredging and stabilization of contaminated lake sediments; consolidation of
lake sediments and contaminated  soils on the process/fill area; collection, treatment, and
disposal of contaminated groundwater; capping of the site; physical controls for run-on,
run-off and flow from the lake; long term monitoring. A Consent Order requiring a group
of Potentially Responsible Parties (PRPs) to implement the selected remedy  was
executed.

Remedial Actions

Remedial construction began in June 1995.  Quarry Lake was de-watered and
contaminated sediments were removed, stabilized, and consolidated into the onsite
landfill.  Construction of the landfill cap and leachate collection system is complete.  The
final completion report certification and Operation & Maintenance (O&M) manual were
finalized in March 1997.

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                                     A-67
Long-term O&M includes pump-and-treat of the leachate from the site. The O&M is
scheduled to continue for a period of 30 years from 1997. Thorough review of the project
will be done every five years during this period to verify that remediation goals are being
achieved.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:
       State
       PRP
$  1,430,000 (of which $1,326,000 has been repaid by PRPs)
$ 14,120,000
It is estimated that the following amounts will be spent for the O&M from now through
completion:
       State
       PRP
$   50,000
$ 1,680,000
    FRONTIER CHEMICAL, PENDLETON
Output
RI/FS
Record of Decision
Remedial Design
Remedial Action
Responsible Party
DEC
DEC
PRPs
PRPs
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED

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                                      A-68

                  FRONTIER CHEMICAL, ROYAL AVENUE

Site Program: Superfund
Summary Prepared by: EPA and DEC

Site Description

Frontier Chemical Waste Process, Inc. occupies approximately 9 acres, bordered by Royal
Avenue on the south and 47th Street on the east, in Niagara Falls, New York. The
Niagara River lies within 1 mile south of this site.

The facility treated chemical wastes from 1974 to December 1992 when the facility
closed.  The Solid Waste Management Units (SWMUs) at the facility include:

       •     A treatment and  pretreatment system for aqueous waste;
       •     Synthetic fuel-blending system for waste solvents/oils;
       •     A solvent recovery system;
       •     Bulk and drummed material handling, storage, and transfer facilities; and
       •     A hydrolysis process, tanks, old surface impoundments, an old waste pile,
             and site trucks.

When operating, the active waste management units treated or stored approximately
25,140 tons of chemical wastes each year. The waste, which came from businesses
located in the eastern United States and southeastern Canada, can be classified as RCRA-
listed wastes, as well as RCRA-characteristic wastes.

There are two fractured bedrock aquifers present under this site. Groundwater from both
aquifers flows generally in a southeasterly direction. Although the flow is toward the
Niagara River, it is intersected by the Falls Street Tunnel, south of the site, where the
groundwater infiltrates  into the  tunnel. All of the dry-weather flow from the Tunnel  is
diverted to the City of Niagara Falls wastewater treatment plant and treated before
discharge to the River.

The EPA and DEC added Frontier Chemical, Royal Avenue to the list of sites that
contribute a significant amount of contaminants to the Niagara River after extensive
groundwater investigation revealed the following chemicals at the site:
monochlorotoluene, methylene  chloride, chloroform, dichlorobenzene,
tetrachloroethylene and other organic contaminants. Dense Non-Aqueous Phase Liquid
(DNAPL) is present at the southern edge of the facility.

In 1999, most of the site buildings were demolished with the rubble remaining on site.

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                                      A-69

Interim Remedial Actions

This facility was formerly regulated under RCRA and 6 NYCRR Part 373. The company
that operated the facility went bankrupt in 1992. As a result, New York State issued an
Order in December 1992, requiring the owner to begin cleanup of the site by removing all
stored waste from the facility. When the company failed to meet the required deadline for
waste removal, the State requested that EPA secure the site and begin a Superfund
Response Action to remove the wastes.

Two phases were implemented at the site.  Initially, an EPA contractor provided
maintenance to the drums and tanks at the facility. Phase I dealt with enforcement actions
leading to the removal of over 4,000 drums and 6,700 pounds of laboratory chemicals
from the site. Phase II dealt with enforcement actions for the removal of all wastes from
the 45 tanks on site.

Phase I began in October 1993, after approximately 5 months of negotiations with 430
potentially responsible parties (PRPs).  The PRPs hired a cleanup contractor to remove all
laboratory chemicals and drums from the site-and to send them to multiple disposal
facilities. This field work was completed in May 1994, and all wastes were subsequently
destroyed at off-site disposal facilities.

Phase II began in July 1994, after approximately 3 months of negotiations with over 400
PRPs. A consultant hired by the PRPs sampled the tanks and prepared a removal action
plan that was approved by EPA. Removal of the tank wastes was completed in March
1995.

Schedule for Completion

On April 6, 1994 the State of New York issued an Order which formally revoked the
operating Permit for the facility and revoked all authority to operate a hazardous waste
management facility at the Royal Avenue site. In March 1995, the site was listed on the
NYS Registry of Hazardous Waste sites as Class 2 (significant threat to the public health
or the environment, action required).

In March 1994, while the interim remedial actions were being implemented, the
Superfund Program assigned the site to be evaluated for possible inclusion in the National
Priorities List (NPL), which identifies sites requiring remedial action under Superfimd.
EPA has ruled not to include this site on the NPL. The DEC initiated PRP search efforts
in 1998.  The search effort will be followed by negotiations of an RI/FS Order to address
soil and groundwater contamination. In mid-1998, DEC contractors completed a review
of facility records to identify PRPs. DEC subsequently reviewed its internal records to
finalize the list of PRPs. Notice letters were issued to PRPs in December 1999.

In January 2001 the site was referred for RI/FS action under the NY State Superfund
program. The Focused Remedial Investigation was begun in 2001. The RI/FS is

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                                    A-70

expected to be completed in 2002, with a final Record of Decision expected in early
2003.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site
(EPA Emergency Removal Action):
       Federal
       State
       PRP
$ 3,690,000
$   50,000
$ 3,600,000
It is estimated that the following amounts will be spent from now to the completion of
remediation:

      Federal      $ 0
      State        $ (Not available)
      PRP         $ (Not available)
FRONTIER CHEMICAL, ROYAL AVENUE
Output
RFI Work plan Approval (groundwater
investigation)
RFI Completion
(groundwater investigation)
Remedial Investigation
Feasibility Study
Remedial Design
Remedial Action
Responsible Party
DEC
Permittee
DEC
DEC
Target Date
COMPLETED
COMPLETED
2002
2002
Dependent on ROD and subsequent RD/RA
Order negotiations with PRP group.

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                                     A-71

   OCCIDENTAL CHEMICAL -- DUREZ DIVISION, NORTH TONAWANDA
                                  Site #24-37

Site Program: N.Y. Division of Hazardous Waste Remediation
Summary Prepared by: DEC

Site Description

The Occidental Chemical Corporation (OCC) Durez site occupies about 40 acres in the
city of North Tonawanda. The site is located about 1 1/4 miles east of the Niagara River.

The Durez plant has been in operation since 1926, producing various plastic formulations.
Chemicals deposited on site include: chlorinated benzenes, phenol, chlorinated phenols,
chlorotoluene, and other organic compounds. During 1995, the plant ceased
manufacturing operations and the site facilities were demolished. Operation of remedial
systems at the site continue.

Two aquifers, one overburden and one bedrock, are present under this site.  The
overburden aquifer unit is the primary aquifer of concern.  The bedrock aquifer, for the
most part, is isolated from overlying chemical contamination by a confining clay layer.
Prior to remediation, groundwater in the overburden flowed in several directions and was
complicated by storm drains and sewers to the north, northwest, and southwest of the site.
The regional overburden and bedrock groundwater flow is to the southwest, toward the
Niagara River.

Remedial Actions

Remedial actions have been conducted under several consent orders and have addressed
the following three areas:

•      Plant site: An 8450-feet long groundwater interceptor trench  has been  constructed
       around the entire plant perimeter to collect contaminated groundwater for
       treatment at an on-site carbon treatment system.

•      Off site: Off-site contaminants from some 22,000 feet of City of North
       Tonawanda and OCC Durez plant sewers were removed.

•      Pettit Creek Cove: Remediation of the Pettit Creek Cove was completed in 1995
       under  consent order. This remediation included excavation and removal of
       contaminated soils and sediments from the cove and the Little Niagara River,
       removal and treatment of dense  non-aqueous phase liquid (DNAPL), and
       restoration of the cove as a wetland.  A total of 23,500 cubic yards of soil and
       sediment were removed and transferred to licensed disposal facilities.

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                                     A-72

All remedial construction activities have been completed. Operation of plant
groundwater systems will continue, probably for decades, until no longer needed.
Approximately 25,000 cubic yards of contaminated sediments from sewers and from
Pettit Cove were removed during the Remedial Action. Biomonitoring sampling by the
Ontario Ministry of the Environment in 1997, and recent water quality sampling by the
NYSDEC, detected the possible release of OCC Durez contaminants of concern into the
post-remedial Pettit Creek Cove. The extent of the sampling was limited to a very small
area at the mouth of the Pettit Creek Flume storm sewer. As a result, OCC agreed to
undertake a supplemental investigation of the Pettit Creek Cove to ascertain the cove's
current condition and to demonstrate the effectiveness of the completed remedial
programs. Sampling of cove sediment, completed October 1999, found that low levels of
Durez contaminants were present in recently deposited sediment emanating from the
Pettit Flume storm sewer. OCC believes the contamination to be residual from the sewer
cleaning project of 1994.  In response, OCC completed maintenance dredging of 400
cubic yards of the recently deposited sediment in May 2000.

Remediation Costs

Following are estimated amounts that have been spent for this remediation project:

       State               $    510,000
       PRP               $ 39,000,000

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                         A-73
OCC -- DUREZ, NORTH TONAWANDA
Output
Responsible
Party
Current
Schedule
Remedial Construction:
Plant Site
Sewer Clean-up
PRP
PRP
COMPLETED
COMPLETED
Pettit Creek Cove:
RI/FS
Record of Decision
Remedial Design
Remedial Action
PRP
DEC
PRP
PRP
COMPLETED
COMPLETED
COMPLETED
COMPLETED

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                                      A-74

                        GRATWICK RIVERSIDE PARK
                                    Site # 68

Site Program: N. Y. Division of Environmental Remediation
Summary Prepared by: DEC

Site Description

The Gratwick Riverside Park site occupies about 53 acres in the City of North
Tonawanda and borders the Niagara River.

Prior to I960, the site was used for the disposal of metallurgical slag.  During the period
1960 to 1968, the site was operated as a landfill accepting municipal and industrial
wastes. It is known that phenolic wastes from Occidental Chemical - Durez were
disposed at the Gratwick Park site.

The Gratwick Park site contains about 13 feet of fill underlain by a discontinuous
glaciolacustrine unit above glacial till. The till layer acts as an aquitard (or barrier) to
downward groundwater flow from  the overburden/fill aquifer to the next significant
aquifer, in the Camillus Shale bedrock.  Each aquifer flows generally to the southwest,
towards the Niagara River.

Site Investigation

Gratwick Riverside Park is a DEC-lead site.  DEC has completed a Remedial
Investigation/ Feasibility Study (RI/FS) of the site under State Superfund.  A Record of
Decision (ROD) selecting a remedy was completed February 1991. In May 1996, after
lengthy and difficult negotiations, the PRPs agreed to design and implement the selected
remedy. In February 1997, the City of North Tonawanda (one of the PRPs) entered into a
Title 3 contract for state funding of its share (approximately 34%) of project design and
construction costs.

Remedial Design (RD) started in early 1996. The design includes:
       •      Shoreline protection
       •      Hydraulic barrier (slurry wall) between site and river
       •      Cap over the site to allow it to be used as a park
       •      Collection of contaminated groundwater

During design, samples of river sediment along the shoreline indicated the presence of
relatively low levels of site-related contamination. It was also determined that steps
should be taken to improve the habitat value of the shoreline area. To address  these
issues and the shoreline protection component of the remedy, the design was modified to
include covering portions of the river bottom with soil that could support selected

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                                      A-75

vegetation to be planted, and to include features to provide erosion resistance. These
changes are incorporated in an amendment to the ROD issued in January 1999.

Construction of the remediation measures began in June 1999, and was substantially
completed in November 2001.

The components of the remediation of this site include the following:
•      a permeable soil cap, which includes a six inch fertile layer for planting of
       appropriate vegetation,
•      a subsurface hydraulic barrier wall along the entire shoreline of the site,
       approximately 5600 feet long, to separate the contaminated leachate on the site
       from the river waters,
•      rip rap stabilization and protection of the shoreline,
•      remediation of three existing storm sewer lines,
•      removal of an area of soils contaminated by viscous material approximately fifty
       feet square, and
•      a groundwater/leachate collection system.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:

       State               $ 2,550,000
       PRP                $ 5,000,000

It is estimated that the following amounts will be spent from now to the completion of
remediation:

       State               $ 450,000
       PRP                $ 430,000

Operation and Maintenance costs are estimated at $1,140,000 for ten years.

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                            A-76
GRATWICK RIVERSmE PARK
Output
RI/FS
Record of Decision
Remedial Design
Completion
Remedial Action
Completion
Responsible Party
DEC
DEC
PRPs
PRPs
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED

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                                      A-77

                                   MOBIL OIL
                                    Site#  141

Site Program: NY Division of Environmental Remediation
Summary Prepared by: EPA/DEC

Site Description

The Mobil Oil site associated with Niagara River Toxics Management Plan (NRTMP)
priority toxic chemicals is a 3-acre area in the southeast portion of an approximately 62-
acre Mobil facility in the City of Buffalo. The site is located adjacent to the Buffalo
River, about 5 miles upstream of the confluence of the Buffalo and Niagara Rivers.

The entire facility was used by Mobil for oil refining from 1951 to 1981. The 3-acre area
of concern was used by the City of Buffalo  for disposal of municipal wastes before being
sold to Mobil  in 1951.  Mobil used it until  1976 for the disposal of unknown quantities
of tetraethyl lead sludge, lubricating sludges, spent catalysts, and other wastes.

The site consists of varying amounts of fill  underlain by a sand and gravel unit. Below
the  sand and gravel unit is a clay layer, followed by glacial till and then the Onondaga
Limestone. Groundwater flow across the site is generally to the south toward the Buffalo
River.

Site Investigation

From 1982 to 1983, various investigations of the 3-acre site were conducted by the U.S.
Geological Survey and by DEC. In 1985, Mobil and DEC signed a Consent Order to
perform a Phase II investigation. The Phase II investigation, completed in 1987, included
soil sampling, groundwater monitoring, and surface water and sediment sampling  from
the  Buffalo River. The highest concentrations of lead and volatile organic compounds
were found in the soil and river sediment. The highest concentrations of semi-volatile
base/neutral compounds were found in the soil and groundwater.  Liquid petroleum was
found in a monitoring well.

In 1988, based on the site investigations, the 3-acre Mobil site was re-classified as Class 3
(does not  present a significant threat to the  public health or the environment, action may
be deferred). Tetraethyl lead has extremely low solubility in water and is not expected to
significantly migrate off site through groundwater. However, tetraethyl lead is highly
soluble in petroleum products,  so that any spill of fuel oils in the area could mobilize it
and carry  it to the Buffalo River.

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                                      A-78

Site Remediation

Around 1971 Mobil Oil began operation of a well point system (WPS) installed along the
Buffalo River.  The WPS consists of a series of interconnected wells designed to recover
groundwater and petroleum product and prevent petroleum seepage to the Buffalo River.
The WPS extends approximately 1600 feet along the south-facing side of the site, from
the 3-acre disposal area toward Babcock Street. In February 1989, Mobil notified DEC of
liquid phase petroleum encountered during the installation of geotechnical borings.  This
report prompted additional site investigation, and remedial measures were instituted to
recover petroleum product.  In  1993, six dual-pump recovery wells were activated. Each
of the recovery wells is equipped with both groundwater and product recovery pumps.
Five of the six  recovery wells are presently being operated in conjunction with the WPS.
The recovery wells are located  outside the 3-acre disposal area, within the south-central
portion of the Mobil facility.

In 1994, the entire 62-acre Mobil facility, including the 3-acre area of concern, was
selected for inclusion in the DEC Multimedia Pollution Prevention (M2P2) program based
in part on the facility's involvement with  multiple divisions within DEC (Division of Air
Resources, Division of Hazardous  Substance Regulation, Division of Environmental
Remediation, Division of Regulatory Affairs, Division of Solid Waste, Division of
Water). The goal of the M2P2 program is to provide an integrated approach to the
environmental management of the  facility. The M2P2 facility team conducted a multi-
media inspection to better coordinate the  various facility remediation activities. A
Consent Order was signed on May 20, 1997 to undertake further investigation and
remediation. The results of the additional site facility investigation were submitted to
the DEC and EPA on November 25, 1998. Three areas of the site (the Elk Street
Lot,  the Former Lube Building Area & the Buffalo Terminal Disposal Area)
were identified as requiring further investigation to determine the extent
of contamination. The results of the further site facility investigation were submitted to
the DEC and EPA on 12/15/99. The results of additional investigations  of the Babcock
Street Properties and the Eastern Tank Yard (Buffalo Terminal Disposal Area) were
submitted on 6/11/01 and 7/5/01, respectively. The results of completion of the
investigation of the remaining areas of the site were submitted in March 2002.

Remediation Costs

Following are  estimated amounts that have been spent to date on remediating this site:

       Federal      $  (Not available)
       State         $  (Not available)
       PRP         $  (Not available)

It is  estimated  that the following amounts will be spent from now to the  completion of
remediation:

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                                      A-79
       Federal        $ (Not available)
       State          $ (Not available)
       PRP          $ (Not available)
MOBIL OIL
Output
Phase I Investigation
Phase II Investigation
Re-classification to Class 3*
Site Investigation
Responsible Party
DEC
PRP
DEC
PRP
Previous
Target Date
Sept 1983
Dec 1986
Dec 1988
Nov 2000
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
Class 3 means that the site does not present a significant threat to the public health or the
environment and that action may be deferred. Further remediation will be coordinated
under the M2P2 program, with the schedule to be determined.

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                                      A-80

             IROQUOIS GAS - WESTWOOD PHARMACEUTICAL
                                Site Code 9-15-141

Site Program: N.Y. Division of Hazardous Waste Remediation
Summary Prepared by: DEC

Site Description

The Iroquois Gas - Westwood Pharmaceutical Hazardous Waste Site is 8.8 acres in size.
The site is bounded on the: east by Dart Street, north by Buffalo Structural Steel, west by
Scajaquada Creek, and south by residential properties. The site is predominately covered
by asphalt or buildings, and is fenced, which precludes direct exposure to the public. The
potential for site  contaminants to be transported via ground water to Scajaquada Creek
exists.

Iroquois Gas Company, predecessor to National Fuel Gas Distribution Corporation
(NFG) used the site from the turn of the century to about 1955 to manufacture gas. After
1955, NFG stored natural gas at the site, with oil storage believed to have continued into
the 1960's. In 1972 Westwood Pharmaceuticals, Inc.  purchased the site and, the next year,
constructed a 100,000 square foot warehouse on the southwest portion of the site.

In the fall of 1985, during building construction, buried tar separator pits and an oil
storage tank foundation were encountered, along with fill and soils containing tar-like and
oily residues. As a result, construction plans were modified to permit excavation,
evaluation and proper disposal of the potentially contaminated soils, materials and
liquids. In 1985,  Westwood also began an investigation of the site. The investigation
indicated the presence of both soil and ground water contamination.

Site Investigation

In 1989 DEC requested that Westwood undertake a Remedial Investigation and
Feasibility Study (RI/FS) to assess the nature and extent of contamination  at the site.
Ultimately, Westwood agreed to undertake the RI/FS, with DEC oversight, under a
Partial Consent Decree issued by the Federal Court. The purpose of the RI was to define
the nature and extent of any contamination resulting  from previous activities at the site.
Field work for the RI started in April 1992 and was completed in June 1993.

The results of the RI are as follows:

•     The soil at the site  is primarily contaminated  with PAHs (Polynuclear Aromatic
       Hydrocarbons), BTEX (Benzene, Toluene, Ethylbenzene, Xylene), lead and
       cyanide;
•     Ground water in the upper aquifer (fill, with maximum depth of up to 32 feet) is
       contaminated with PAHs and BTEX;

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                                      A-81

•      Substrate below the fill consists of a silty clay layer to a depth of 60 feet, followed
       by a layer of sand and gravel, and then bedrock. No significant contamination has
       been found in the sand and gravel layer; the direction of ground water flow is
       towards Scajaquada Creek.

Based on RJ data, the ground water discharge to the creek is estimated to be 7350 gallons
per day; the direction of flow of NAPL (liquid, non-water soluble chemicals) is also
towards the creek. The estimated amount of NAPL entering the creek is 440 Ib/year; the
chemicals of concern (BTEX and PAHs) in the NAPL and ground water are estimated to
be migrating to the creek at a rate of 261 Ib/year; the creek sediments are primarily
contaminated with the same contaminants which are present in soil, ground water and
NAPL.

In March 1994, the Department signed a Record of Decision which outlined a Remedial
Action Plan calling for:

•      Construction of a clay cap to isolate the source area contaminants;
•      In Situ (in place) bio-treatment of soil and groundwater, if feasible;
•      Installation of a vertical sheet piling barrier wall and extraction wells for ground
       water control and removal of contaminated ground water;
•      Treatment of extracted ground water and NAPL before proper disposal;
•      Long term Operation &  Maintenance.

The Remedial  Action Plan also addresses contamination in Scajaquada Creek and
includes: excavation of contaminated sediments originating from the site and restoration
of the creek channel to background conditions.

Note that DEC found bio-treatment to be infeasible.  DEC will review this decision at
five-year intervals to determine if any new technologies are feasible.

Remedial Actions

For remediation purposes, the site has been divided into two operable units: Operable
Unit 01  (Main Plant)  and Operable Unit 02 (Scajaquada Creek). Westwood is
undertaking the remediation of the Main Plant site which includes the pump-and-treat
system for groundwater and NAPL and plant site capping. National Fuel Gas is
responsible for remediation of Scajaquada Creek.

Remedial construction began in November 1996, with installation of the sheet pile barrier
wall. The wall was completed in  December 1996. All remedial work on the Main Plant
site was completed in 1997. Remediation of Scajaquada Creek sediments commenced  in
July 1998 and  was completed in March 1999.  The Remedial action includes two wells to
extract NAPL  from beneath the creek bed.  Extraction of NAPL from beneath the creek
bed  has begun at the  downstream portion of the site. Negotiations to purchase property

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                                    A-82
to locate the second well at the upstream portion of the site caused some delay in its
installation. The second extraction system was completed in August 2000 and
commenced operation for NAPL extraction in December 2000.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:
      State
      PRP
$  150,000
$ 6,500,000
It is estimated that the following amounts will be spent from now to the completion of
remediation, including operation and maintenance:
       State
       PRP
$  100,000
$  500,000
       IROQUOIS GAS - WESTWOOD PHARMACEUTICAL
       PLANT SITE:
Output
Record of Decision
Remedial Design
Remedial Action
Responsible Party
DEC
PRP
PRP
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
       CREEK SITE:
Output
Record of Decision
Remedial Design
Remedial Action
Responsible Party
DEC
PRP
PRP
Current
Schedule
COMPLETED
COMPLETED
COMPLETED

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                                      A-83

                                  BOOTH OIL

Site Program: N.Y. Division of Hazardous Waste Remediation
Summary Prepared by: DEC

Site Description

The Booth Oil site is located at 76 Robinson Street in the City of North Tonawanda. The
site occupies approximately 2.7 acres on three parcels of land each separated by railroad
tracks operated by CSX. The site is located about 500 feet from the Little Niagara River.

Waste oils were refined at the site for more than SO  years, until the phased plant closure
in the early 1980's. During processing, frequent spills occurred and oil was periodically
discharged to the Little Niagara River via surface water run-off through the Robinson
Street storm sewer.

Site Investigation

The Rl identifies oil saturated soils on site containing PCB, VOCs, Semi-VOCs, and
PAHs. An investigation of the River indicated that oil/PCB waste from the Booth Oil site
is limited to a small  area in the  vicinity of the outfall.

Two Records of Decision were issued: the first in March 1992 (Operable Unit OU1,
on-site) and the second in March 1993 (Operable Unit OU2, Little Niagara River). The
remedy consists of the excavation of contaminated on-site soils, sewer sediments and a
limited area of sediment in the Little River with on-site treatment by separation
technologies or incineration. Contaminated ground water will also be extracted and
treated.

The RI/FS was performed under State Superfimd. However, many Potentially
Responsible Parties  (PRPs) exist, including the site  owners and numerous generators who
shipped waste to the site.

A PRP proposal for  an alternate remedy was accepted in June 1998. In 2001, the
NYSDEC proposed  amending the earlier RODs.  The amended remedy is similar to the
previously selected remedies, however, contaminated soil and sediment would be
excavated and disposed of off-site, rather treating these materials on-site. The
components of the amended remedy include:

•      Contaminated soil would be excavated down to the clay layer underlying the site;
•      Storm sewer sediment would be removed from the  Robinson Street storm sewer
       and its catch basins;
       Contaminated sediments in the Little River would be excavated and disposed of
       with the contaminated site soils;

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                                     A-84

•      Water produced during de-watering of excavations would be treated on site prior
       to discharge;
•      All contaminated soils and sediments removed during remediation would be
       disposed of in a permitted disposal facility;
       Excavations would be backfilled and graded with clean fill;
•      Deed restrictions and a long-term monitoring program would be established to
       address any residual contamination.

After lengthy negotiations between the NYSDEC and the Booth Oil Site Administrative
Group (BOSAG), a group of potentially responsible parties, a final agreement for site
remediation is near.  The agreement will include remedial design, which is expected to be
completed by August 2002, followed by remedy implementation.  Should the proposed
amendment be deemed acceptable, construction is expected to commence in the Fall of
2002 and be completed by June 2003.

A schedule for remediation of the site follows.

Remediation Costs

Following are estimated amounts that have been spent through 1997 on remediating this
site:

       State                $ 1,100,000
       PRP                 $0

It is estimated that the following amounts will be spent from now to the completion of
remediation:

       State                $ (Not available)
       Permittee            $ 5,000,000

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                                 A-85
BOOTH OIL
Output
Responsible Party
Previous
Target Date
Current Schedule
OU1
Rl/FS
ROD
Remedial Design
Remedial Action
DEC
DEC
PRP
PRP
Feb 1992
Mar 1992
Apr 2001
Apr 2002
COMPLETED
COMPLETED
August 2002
June 2003
OU2
Rl/FS
ROD
Remedial Design
Remedial Action
DEC
DEC
PRP
PRP
Feb 1993
Mar 1993
Apr 2001
Anr 2002
COMPLETED
COMPLETED
August 2002
June 2001

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