REDUCTION OF
TOXICS LOADINGS TO
THE NIAGARA RIVER FROM
HAZARDOUS WASTE SITES
IN THE UNITED STATES:
NOVEMBER 1998
A Report by the United States Environmental Protection Agency
and the New York State Department of Environmental Conservation
November 1998

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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	  16
Glossary	  17
References	 22
Appendix: Priority Niagara River Hazardous Waste Sites

       Occidental Chemical — Buffalo Avenue	   A-l
       Niagara County Refuse Disposal	   A-6
       DuPont Necco Park	   A-9
       CECOS International	  A-13
       Occidental Chemical — Hyde Park	  A-17
       102nd Street	  A-23
       Bell Aerospace Textron	  A-26
       Occidental Chemical — Durez Division, Niagara Falls (formerly BTL Specialty)	  A-29
       Occidental Chemical, S-Area	  A-32
       Stauffer Chemical	  A-36
       Solvent Chemical	  A-38
       Vanadium Corporation of America (formerly SKW Alloys)	  A-40
       Olin Corporation	  A-42
       DuPont — Buffalo Avenue	  A-46
       Buffalo Color Corporation	  A-48
       Buffalo Color--Area D	  A-51
       Bethlehem Steel Corporation	  A-53
       River Road (INS Equipment)	  A-56
       Niagara Mohawk — Cherry Farm	  A-57
       Frontier Chemical, Pendleton	  A-60
       Frontier Chemical, Royal Avenue	  A-62
       Occidental Chemical — Durez Division, North Tonawanda	  A-65
       Gratwick Riverside Park	  A-67
       Mobil Oil	  A-69
       Iroquois Gas-Westwood Pharmaceutical	  A-72
       Booth Oil	  A-75

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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
9 of the sites. The remedial technology will be
operated and monitored for effectiveness for
years to come at those sites.  Remedial actions
are underway at 13  sites.  Five of these are
interim remedies, including 4 sites under interim
remediation while final remedies are being
designed or investigated, and one site where an
interim remedial action  was  completed and an
effort to identify potentially responsible parties
is underway. At 9 of the  13 sites where remedial
actions 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 at least
25%.  This estimate  is based primarily on the
sites  where the  final  remedial   action  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 exceed 25%. EPA also estimates that
remedial activities to be completed through the first quarter of 1999 at several of the most significant
sites will reduce the potential inputs into the River by approximately 80%.  Revised remediation
schedules call for all of the sites to be completed by 2003. Work by EPA and DEC is underway to
improve reduction estimates.
REMEDIATION OF U.S. HAZARDOUS WASTE SITES
9 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)
13 SITES WHERE REMEDIATION IS UNDERWAY:
   Occidental Chem. Buffalo Ave (Niagara Falls)
   DuPont Necco Park (Niagara Falls)
   Occidental Chem. Hyde Park (Niagara Falls)
   Mobil Oil (Buffalo)
   102nd Street (Niagara Falls)
   Occidental Chem. S-Area (Niagara Falls)
   River Road (Tonawanda)
   Niagara Mohawk Cherry Farm (Tonawanda)
   Frontier Chemical Royal Ave (Niagara Falls)
   Iroquois Gas-Westwood Pharmac. (Buffalo)
   Niagara County Refuse Disposal (Wheatfield)
   Vanadium Corporation (Niagara)
   Solvent Chemical (Niagara Falls)

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Recent  accomplishments in remediation of the priority waste  sites include the following:
Construction and optimization of the remedial systems has been completed at the Olin Corporation
site and Buffalo Color - Area D. The groundwater stabilization programs at the Occidental Chemical
Corporation's Buffalo Avenue site are nearly complete. Occidental is enhancing its new treatment
plant for contaminated groundwater to allow increased groundwater extraction  rates, and has
converted an abandoned sewer line to an overburden groundwater collection system.  This system
is being augmented by installation of a tile drain collection system.   Construction of remedial
systems is also nearly  complete at the 102nd Street site.  The final  landfill cap was recently
completed.  The leachate pump-and-treat system is under construction and due to be completed in
December 1998.  Site landscaping will be completed in March 1999. At Occidental's S-Area site,
the new Niagara  Falls Drinking Water Treatment  Plant (DWTP) was completed and is now
supplying the community with its drinking water. This allowed construction to begin on the remedy
for the old DWTP area. The old DWTP was demolished, the final portion of the perimeter barrier
wall was completed, and the cap and groundwater collection system are being installed. All remedial
work is complete at the River Road and Niagara Mohawk - Cherry Farm sites, except for sediment
removal. The  remedial action includes fish  and wildlife habitat enhancements.  At Occidental's
Hyde Park site, additional extraction wells were completed, and more are being installed, to ensure
effective hydraulic containment. Remedial construction recently began at several sites, including
Niagara County Refuse Disposal.  The remedy at this site includes a perimeter clay barrier wall,
leachate collection with off-site treatment, a final landfill cap, and other actions. At the Vanadium
Site, an interim remedial  action was initiated by one of the potentially responsible parties.  The
action involves capping portions of the site and control of storm water runoff.

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 $ 316,900,000.  Additional costs
expected in the future are estimated at $ 312,700,000.
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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 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 February 1998
                                            (Niagara River Secretariat, 1998).
    NRTMP PRIORITY Toxic CHEMICALS
Benz(a)anthracene       Mirex
Benzo(a)pyrene  Octachlorostyrene
Benzo(b)fluoranthene    PCBs
Benzo(k)fluoranthene
Chlordane
Chrysene
Dieldrin
Hexachlorobenzene
Mercury
DDTs
Dioxins
Tetrachloroethylene
Arsenic
Lead
Toxaphene
                                            Non-point sources of toxic chemicals to the 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 River.

In 1988, an EPA study estimated potential toxic pollutant loadings to the 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 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 Ibs (315  kg)/day of toxic chemicals have the potential of
migrating from the sites to the Niagara River.  Because collection of site-specific transport data is
ongoing, estimates were made based on certain assumptions - for instance, that groundwater flow
is horizontal, and that pollutants behave in a conservative manner.  These assumptions yielded
conservative estimates (i.e., estimates of toxic loadings that are expected to be higher than the actual
loadings).

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                                                                  Booth Oil Site
                                   41 b / 78  242
                             V  /••/    /•
                             -X-/. '•-.•? •..
Frontier Chemical-
   Royal Ave.
          APPROXIMATE SCALE

    024           8 MILES
     NOTE: First number only is given for site areas
          with multiple site numbers.
                                                               Niagara Mohawk
                                                               Cherry Farm Site
                                                                   118
Figure 1     LOCATION OF SIGNIFICANT NIAGARA RIVER HAZARDOUS WASTE SITES

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                            Figure 1:  LEGEND
  USGS SITE NUMBERS
                 SITE NAME
                     41b-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 (OCC) - Buffalo Avenue
Niagara County Refuse Disposal
DuPont Necco Park
CECOS International/Niagara Recycling
Occidental Chemical (OCC) - Hyde Park
102nd Street
Bell Aerospace Textron
OCC - Durez, Niagara Falls (formerly BTL)
Occidental Chemical (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, including Area D
Bethlehem Steel
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
Huntley Power Station
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 Bel den site (#94)

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

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

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 River, the EPA/DEC report presented ambitious remediation
schedules for the Category I and II sites.  The report's best estimates indicated that the potential
inputs of all toxic chemicals from these sites to the  River would be reduced by 99% by 1996, if
remediation schedules were met.  However, the  1989 schedules were estimates based  on limited
knowledge of site conditions and average negotiation periods with Potentially Responsible Parties
(PRPs). Delays in the schedules have occurred, because of lengthy legal proceedings with PRPs or
complex site  conditions that were unanticipated. Thus, many of the sites have  exceeded their
original 1996 targeted  completion date.  In each progress update,  EPA and DEC explain the
circumstances surrounding the slippages in the site-specific reports 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 Niagara River. Two sites have been
removed as insignificant sources of toxics, and four sites have been added as significant sources.
This November 1998 update reports on remediation progress at the resulting 26 significant hazardous
waste sites.

EPA estimates that a reduction of 25% or more in potential toxic chemical inputs from all sites to
the River has been achieved by the site remediations to date. The estimate is based on the percentage
of remedial actions in place at some of the 22 sites with completed or on-going remedial actions
(Table  2). A  100% reduction was assumed for the 9 sites with all remedial actions in place, and a
percentage  reduction was estimated for two other sites with partial implementation of remedial
actions. Since estimates could not be made for many of the sites with on-going remediation, actual
reductions to date are greater than the estimated 25%. Remedial systems are functioning at 9 of the
13 sites where remediation is underway, and these systems are expected to have already substantially
reduced the off-site loadings. For example, groundwater pump-and-treat systems are operational at
several sites, thus  substantially reducing potential loadings to the river. 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 river.

Completion of final remedial actions are expected within the next several months at two of the most
significant sites (OCC Buffalo Avenue, 102nd Street). Based on the expected implementation of the

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final remedial actions at these sites in 1998 and the first quarter of 1999, EPA's best estimates are
that, by the end of this period, the estimated toxic chemical inputs from all sites will be reduced by
approximately 80% from the 1989 inputs. Revised schedules call for all sites to be remediated by
2003.

Efforts are underway by EPA and DEC to improve estimates of the chemical loadings to the Niagara
River from the 26 waste sites.  The focus of the efforts is to develop loading estimates for the 18
NRTMP priority toxic chemicals. The estimates will incorporate information that was not available
at the time the Gradient/Geotrans estimates were developed, for example, improved information on
chemical concentrations in groundwater and groundwater flow. At EPA's request, several site PRPs
agreed to use existing information collected under EPA and DEC approved programs to develop
loading estimates for several of the sites.  EPA and DEC  are reviewing a report submitted by the
PRPs.  DEC has completed data collection addressing the remaining sites. The efforts are expected
to be completed in 1999. EPA and DEC expect that the results will confirm the significant progress
in reduction of toxic chemical loadings.

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 in reducing toxic inputs from a number of
waste sites to the River. Based on information available in 1987, the U.S. identified the Falls Street
Tunnel as the largest source of toxic pollutants from any of its point sources. The Tunnel was once
a major unlined industrial sewer cut into the bedrock under the City of Niagara Falls. By the mid-
1980s, it only received overflows of wastewater from the sewers of a Niagara Falls industrial area
and contaminated groundwater from major waste sites infiltrating through cracks in the bedrock.
Unlike flows from other point sources, flows from the Falls Street Tunnel entered the Niagara River
untreated.  In 1993, EPA and DEC required the City of Niagara Falls to treat the contaminated water
flowing in the Falls Street Tunnel during dry weather at the Niagara Falls treatment plant. The data
gathered by the U. S. show that this action has reduced, through wastewater treatment, the input from
the Falls Street Tunnel into the River of mercury by 70%, tetrachloroethylene by 85% and four  other
priority toxic chemicals by almost 100%, relative to the 1980s inputs.

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 the
inputs from the following sites to the River:

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

For this report, reductions in toxic chemical inputs to the River due to the treatment of Falls Street
Tunnel flow are not included in the estimate of the reduction in toxic inputs.

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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/day

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

Category II: between 1-50 Ib/day

Occidental Chemical - 102nd Street
Bell Aerospace Textron
Occidental Chemical - Durez, Niagara Falls (formerly known as BTL Specialty Resins)
Occidental Chemical - 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, including Area D
Bethlehem Steel
River Road (INS Equipment)
Frontier Chemical - Pendleton
Occidental Chemical - 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
Huntley Power Station
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 9 of the sites. The remedial technology installed at those sites
       will be operated and monitored for effectiveness for years to come.
•      Remedial actions are underway at 13 sites.
             5 of these are interim remedies, including 4 sites under interim remediation while
             final remedies are being investigated or designed,  and one site where an interim
             remedial action was completed and PRP search efforts are underway.
             Construction of the final remedy is underway at 8 sites.
       Remedial actions are under design or investigation at 8 sites (including 4 of the sites under
       interim remediation).

HIGHLIGHTS OF RECENT ACTIONS

For each site, a detailed description of progress is  presented in the Appendix. The highlights of
progress made, with emphasis on accomplishments since the last progress report in May 1997, are
summarized below.

Occidental Chemical — Buffalo Ave

 !      Final  completion of the groundwater  stabilization  programs in December 1998 will
       effectively eliminate future off-site contaminant loadings.
 !      A recently constructed plant to  treat contaminated  groundwater is being enhanced by
       increasing plant capacity and adding additional treatment measures. Once this is complete,
       the extraction rates of the bedrock groundwater recovery system will be increased.
 !      Conversion of abandoned sewer line to an overburden groundwater collection system, and
       a groundwater collection trench  to expand the capture zone, was completed and began
       operation December 1997. The system is now being augmented by installation of atile drain
       system to further enhance groundwater capture.
 !      Occidental Chemical will submit a comprehensive, site-wide, Final Corrective Measures
       Study in November 1998.

Niagara County Refuse Disposal

       EPA approved the Final Design Report in September 1997.
       The municipalities responsible for site remediation completed the requirements for state
       assistance in the remediation in May 1998.
       Remedial construction began in fall 1998. The remedy includes a perimeter clay barrier wall,
       leachate collection with off-site treatment and disposal, removal of field tile drains to the

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west of the landfill, a final landfill cap, and other actions.
Completion of the Remedial Action is expected by September 2000.

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                                      TABLE 2
                         STATUS OF SITE REMEDIATIONS
INVESTIGATION AND DESIGN:

PRP Search

Frontier Chemical, Royal Avenue1

Site Investigation Underway

Mobil Oil
Buffalo Color
Bethlehem Steel
Vanadium Corporation2

Remedial Design Underway

DUPONT NECCO PARK
OCC - BUFFALO AVENUE
Gratwick Riverside Park
Booth Oil
REMEDIATION:

Remediation Underway:

   Interim Remedy In Place or Under Construction:

   OCC, BUFFALO AVENUE
   MOBIL OIL
   Frontier Chemical, Royal Avenue1
   DUPONT NECCO PARK
   Vanadium Corporation2

   Construction of Final Remedy Underway

   OCC, S-AREA
   OCC, HYDE PARK
   IROQUOIS GAS-WESTWOOD PHARMAC.
   RIVER ROAD
   NIAGARA MOHAWK - CHERRY FARM
   102 STREET (OLIN/OCC)
   Niagara County Refuse Disposal
   Solvent Chemical

Remediation Completed
(Operation & Maintenance 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
The sites in interim remediation are also under investigation or design, and therefore are listed twice.

 Sites in bold have achieved progress since the May 1997 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, including tank and drum removal, was completed in 1995. A
PRP search is underway to be followed by negotiation of an RI/FS order.

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2 Preliminary investigations were completed. Interim Remedial Action under construction. RI/FS Order
under negotiation.
DuPont Necco Park

       The Proposed Plan was released to the public in July 1996.
       Extensive public comments on the Proposed Plan, leading EPA to revise the plan and
       provide an additional public comment period, contributed to delays. A Record of Decision
       was issued in September 1998.
       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.
       Remedial Design began in October 1998.
       Remedial construction is expected to begin December 1999.  RA completion is expected
       September 2001.

Occidental Chemical — 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. In the three
       bedrock groundwater zones, at least 80% of contaminated groundwater is being  contained.
       Remedial work to achieve full containment is continuing.
 !      Phase III of the bedrock groundwater treatment system was installed  (pumping and
       monitoring wells, and force mains connecting the wells to the treatment plant), in  mid-1997.
 !      However, complex site conditions and difficulties in pumping NAPL continue to result in
       the need to install additional wells. Three additional pumping wells were installed in Spring
       1998, and the connecting force main will be completed in December 1998.  Completion of
       all remedial systems, including optimization, is expected by September 2000.
 !      Sampling of fenced groundwater seeps in the Niagara River Gorge Face was conducted in
       1997. Results indicated no need for additional control or remediation of the seep areas.

102nd Street

       The final landfill cap was completed in 1998.
       The potential for contaminants to enter the River from this site will be eliminated with the
       completion  of the leachate pump-and-treat system in December 1998.
       The remedial design was modified to take advantage of excess capacity at the Love Canal
       Treatment Plant.  Instead of on-site leachate treatment, a force main is being constructed to
       pump leachate from the 102nd Street Site to  the Love Canal Treatment Plant.

                                           11

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 !      Landscaping and optimization of the pump-and-treat system will continue until March 1999.

Bell Aerospace Textron

 !      CMI start-up was in 1995. An additional extraction well was installed in July 1998 to ensure
       that contaminated groundwater is not migrating from the site.

Occidental Chemical S-Area

 !      The new Niagara Falls Drinking Water Treatment Plant (DWTP) was completed and fully
       operational in March 1997.
 !      This allowed  construction  of the remedy  for  the  old DWTP  property  to  begin.
       Decommission and demolition of the old plant were completed in early 1998. The barrier
       wall on the eastern perimeter of the property was completed in May 1998, thus completing
       barrier wall  construction around the S-area site.
 !      The cap and overburden drain collection system for the old DWTP property are now being
       installed.  Completion is expected December 1998.
 !      Operation of the drain collection system for the landfill portion of the site began in 1996.
       Additional wells were installed in  1997 to improve the performance of the  system in
       collecting NAPL.  However, a portion of the system is not functioning as designed due to
       collapse of the drain pipe in several areas.  EPA and DEC are assessing what actions are
       necessary to repair or replace the damaged system.  EPA anticipates that this problem will
       delay completion of the Remedial Action by approximately one year, until 2000.
 !      The final landfill cap is scheduled for construction in 1999, but is likely to be delayed
       depending on the actions necessary to correct the damaged landfill drain collection system.

Stauffer Chemical

 !      Construction at this site is  completed.  Operational  difficulties  with  the groundwater
       treatment system were corrected in 1997.

Solvent Chemical

 !      DEC completed the RI/FS andROD in 1996, and subsequently negotiated a settlement with
       the PRP requiring ROD implementation.  The U.S.  District Court approved the settlement
       in October 1997. Construction began in early 1998. Completion is expected in December
       1999.

Vanadium Corporation

 !      DEC completed a  study to further define the nature and  extent of contamination on the
       properties of two of the PRPs (Niagara Mohawk and NYPA).
                                          12

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 !      One of the site PRPs (SKW Alloys) is undertaking an Interim Remedial Measure to cap
       portions of  their parcel and control site storm water  runoff.  Completion is  expected
       December 1998.
 !      DEC is negotiating an RI/FS Order with another of the PRPs (Airco). The outcome of these
       negotiations will determine whether additional RI/FS work is necessary by the other PRPs.
 !      The need to negotiate with the PRPs individually has contributed to delays in the completion
       of remediation, now expected in 2003.

Olin Corporation Plant Site

 !      In 1997, DEC issued a Consent Order to implement the remedy. The remedial system was
       constructed and began operation in October 1997. The remedy includes five groundwater
       recovery wells and on-site treatment of the recovered groundwater, and paving of all unpaved
       surfaces on the site.
 !      The remedial system is close to meeting its performance objectives. Olin is  currently
       addressing problems due to incrustation  associated with high pH (>10) groundwater.

Buffalo Color

 !      The site investigation is on-going.  Hazardous contaminants were detected at the perimeter
       monitoring wells during the Phase I and  II investigations.
 !      A supplemental investigation, involving the  collection of 6 additional soil samples was
       conducted, and a revised RFI report submitted in November 1997.
 !      A second supplemental investigation was conducted during summer 1998, in response to
       DEC comments on the revised RFI report.  The investigation included 8 new wells, ten
       additional soil samples, and other work.  A revised RFI report is due December 1998.
 !      The additional work will delay completion of the RFI until March 1999.

Buffalo Color — Area D

 !      Remedial construction was 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; non-aqueous phase liquids found at the site are
       being removed; groundwater is being pumped and treated at an on-site treatment  facility.

Bethlehem Steel Corporation

 !      BSC has completed the field work for the site investigation, and is preparing RFI and human
       health risk assessment reports. These have been delayed due to negotiations over the scope.
       Approval is anticipated by April 2000.
                                          13

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 !      BSC completed limited remedial technology studies for two areas that are the primary
       sources of groundwater contamination at the facility (the Acid Tar Pits and Coke Oven
       Areas). However, EPA and DEC found the studies to have major technical flaws.
 !      A comprehensive Corrective Measures Study will commence after RFI approval. All CMS
       and Corrective Measure Implementation will be performed pursuant to a subsequent order
       or permit.
 !      A two-year delay is anticipated for CMI start-up (December 2002).

River Road (INS Equipment) and Niagara Mohawk - Cherry Farm

       These two  sites were combined for joint remediation.
       A Consent Order for remediation of the site includes: 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.
 !      The remedial action also  includes fish and wildlife habitat enhancements through the
       construction of shoreline wetland embayments along the Niagara River.
 !      All remedial work is complete except for sediment removal and final capping of the sediment
       disposal  area. Completion is expected in June 1999.  Completion of these actions was
       delayed due to an increase in the volume of sediments to be removed.

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
       including the removal of thousands of drums, removal of wastes from 45 tanks on the site,
       and other actions. The  action was completed in 1995.
       EPA recently ruled not to include the site on the National Priorities List.
       DEC has initiated PRP search efforts to be followed by negotiations of an RI/FS Order to
       address soil and groundwater contamination.

Gratwick Riverside Park

 !      Remedial Design (RD) started in early 1996.  The design includes shoreline protection,
       hydraulic barrier between site and 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 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 are being submitted for approval in a proposed ROD
       amendment, released in September 1998.  Remedial construction is expected to begin in
       early 1999. The changes are expected to delay completion of the remedial  action by  six
       months.

Mobil Oil
                                          13

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       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 are to be submitted December 1998.
       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 September  1997, including sheet
       piling barrier wall, groundwater extraction wells, groundwater and NAPL treatment, and a
       clay cap.
       Remediation of Scajaquada Creek is underway. Completion is expected in October 1999.
       Delays in the schedule for the creek remediation resulted from disagreement between DEC
       and the PRP on design concepts, and technical difficulties relative to ensuring the structural
       integrity of the elevated roadway above the creek

Booth Oil

 !      The RI/FS was performed under State Superfund, and a ROD was issued for the site in 1992
       and for the adjacent Little Niagara River in 1993.
 !      There were many PRPs, so lengthy negotiations followed. A PRP proposal for an alternate
       remedy was accepted in June 1998.
 !      The remedy consists of the excavation of contaminated on-site soils, sewer sediments and
       a limited area of sediment in the Little River,  with off-site disposal.  Contaminated ground
       water will also be extracted and treated.
 !      Remedial design is expected to be complete by June 1999.
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 Potentially Responsible Party (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
                                           15

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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):

              Federal       $  32.8 million
              State                $   5.1 million
              PRPs	$ 279.0 million
              Total                $316.9 million

Based on available estimates for 16 sites, the total  additional costs expected in the future are as
follows (costs for the remaining 10 sites are unavailable):

              Federal       $   4.8 million
              State                $   0.4 million
              PRPs	$ 307.5 million
              Total                $312.7 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.
                                            15

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                                    ACRONYMS

APL         Aqueous phase liquids

CERCLA    Comprehensive Environmental Response, Compensation and Liability Act of
             1979
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

EC          Environment Canada
EPA         U.S. Environmental Protection Agency

HSWA      Hazardous and Solid Waste Amendments
ICM
Interim corrective measure
MOE
OCC

PCBs
PRP
PSA
PVC
Ontario Ministry of the Environment
NAPL       Non-aqueous phase liquids
NRTMP     Niagara River Toxics Management Plan
Occidental Chemical Corporation

Polychlorinated biphenyls
Potentially Responsible Party
Preliminary Site Assessment
Polyvinyl chloride
RCRA Resource Conservation and Recovery Act
RFA         RCRA Facility Assessment
RFI         RCRA Facility Investigation
RI/FS        Remedial Investigation/Feasibility Study
ROD        Record of Decision
RRT         Requisite Remedial Technology

TCDD Tetrachlorodibenzo-p-dioxin
TCP         Trichlorophenol
voc
Volatile organic compounds
                                         16

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                                     GLOSSARY
                                              drinks contaminated water or eats
                                              contaminated food.
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.

Bioaccumulation
The process by which chemical substances
accumulate in the tissues of an organism that
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 sewage and
storm water runoff. Normally, all of the
sewer system's flow goes to a treatment
plant, but during a heavy storm, there may
be so much storm water as to cause
overflows.  When this happens, mixtures of
storm water and sewage may flow into a
waterbody untreated.
                                          17

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

Contaminant
A substance that is not naturally present in
the environment or is present in amounts
that can adversely affect the environment.
                   D
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.
Furan:  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.
                   G
Groundwater
The fresh or saline waters found beneath the
Earth's surface that often supply wells and
springs. Contrast to "Surface water".
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                   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.

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.
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.
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
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
                                           19

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identified for long-term remedial action
under Superfund.

Non-point source
Pollution entering the environment over a
widespread area, where the sources cannot
be traced to a single, identifiable point.
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
Polychlorinated 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
Source of pollution that is distinct and
identifiable, such as a pipe from a sewage
treatment plant.

Pollution prevention
Any action that reduces or eliminates
pollutants before they are created.

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

Remedial Investigation/Feasibility Study
(RI/FS)
The RI defines the areal 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.
                    s
Slurry wall
Barrier made of a thin, watery mixture of
fine, insoluble material (clay, cement, soil,
etc...).

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
whenever this can be arranged.

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.
OR
A substance that can cause death, disease,
birth defects, behavioral abnormalities,
cancer, genetic mutations,
physiological/reproductive malfunctions, or
physical deformities in any organism.
                                                                   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
                                           21

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that are adapted to a wet environment.
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                                   REFERENCES
Gradient Corp./Geotrans Inc. 1988. Potential Contaminant Loadings to the Niagara River from
U.S. Hazardous Waste Sites.

Niagara River Secretariat.  1998.  Niagara River Toxics Management Plan: Progress Report  and
Work Plan, February 1998.

U.S. Environmental Protection Agency/New York 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 #4Ib-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.

Interim Corrective Measures

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                                       A-2

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 (RFI). 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. As
described below, OCC is currently preparing a comprehensive, site-wide CMS, addressing
all site components, and considering the adequacy of the stabilization measures.

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.
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

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                                       A-3

contaminated groundwater.

Based on performance monitoring data, OCC determined that additional measures were
necessary to achieve the remedial design objectives. The treatment plant is being 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. Once this is
completed,  OCC will increase the extraction rates of the bedrock groundwater recovery
system.

Overburden Groundwater. Construction of a collection system to capture overburden
groundwater along the southern boundary of the site is in progress.  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 is being augmented by installation of a tile drain.  The
new collection system  extends along the alignment of the converted sewer to the vicinity of
the OCC S-Area site.

The overburden groundwater collection system is expected to be fully operational by
December 1998.  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.

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

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                                       A-4

instead to submit a comprehensive, site-wide, final CMS that addresses remedial measures
for all site components (bedrock, overburden and off-site), by November 1998.

Schedule for Completion

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

Future off-site loadings from the Buffalo Avenue site will be effectively eliminated by the
start-up of the bedrock groundwater stabilization program (completed), and the start-up of
the overburden groundwater stabilization program (by December 1998).

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-5
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)1
Start-up of CMI
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
submitted
N/A
Nov 1998
COMPLETED
COMPLETED
N/A
N/A
COMPLETED
COMPLETED
N/A
N/A
COMPLETED
COMPLETED
N/A
N/A
Dec 1998
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 will
be eliminated in Dec. 1998, with full operation of the overburden groundwater remedial system.
OCC will submit a comprehensive, site-wide, final CMS in November 1998, addressing all on-site
and off-site components.

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                                            A-6

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

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                                      A-7

                   NIAGARA COUNTY REFUSE DISPOSAL
                                     Site #81

Site Program: Federal Superfund
Summary Prepared by: EPA

Site Description

The Niagara County Refuse site occupies approximately 50 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 aquifers and one bedrock aquifer are present under this  site.  The
groundwater in all four aquifers generally flows in a south/southwesterly 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 (RI/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 RI report indicated that the three 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.  A more accurate loadings estimate will be calculated
based on new sampling data.

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                                      A-8

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.

Schedule for Completion

An updated schedule for remediation of the site is shown in the following table.  Delays
in the RD/RA schedule were due primarily to lengthy negotiations with over 20 PRPs at
every phase of remediation.

Remediation Costs

Following are estimated amounts that have been spent to date in response to this site:

       Federal       $  1,300,000
       State         $ (State costs included in EPA costs.)
       PRP          $ 2,000,000

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

       Federal       $    200,000
       State         $ (State costs included in EPA costs.)
       PRP          $ 17,800,000

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                             A-9
NIAGARA COUNTY REFUSE DISPOSAL
Output
RI/FS
Record of Decision
Remedial Design Start
Remedial Action Start
Remedial Action Completion
Responsible
Party
14PRPs
EPA
13PRPs
13PRPs
13PRPs
Previous
Target Date
Mar 1993
Sept 1993
Jul 1994
Jan 1997
Dec 1999
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
Sept 2000

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                                      A-10

                            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.

DuPont 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 aquifers 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 when it operates.  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 has conducted
groundwater investigations pursuant to a RCRA 3013 consent  decree. DuPont entered
into an Administrative Order on Consent (AOC) with EPA to conduct further
groundwater investigations and to study on-Site remediation of ground water and non-
aqueous phase liquids.

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

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                                      A-ll

resulted in an estimated load reduction from the site of approximately 27% to 55%, based
on information collected pursuant to the AOC.  DuPont estimates that approximately 138
million gallons of groundwater have been pumped since 1983.  Since 1989, 6,600 gallons
of DNAPL have been recovered, containing approximately 88,000 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 3 60, or equivalent 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.

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                                      A-12

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.  The schedule was delayed because of extensive public comments received on the
Proposed Plan. EPA revised the Proposed Plan in response to these comments and provided
a second public comment period. However, significant  milestones have recently been
accomplished. A Record of Decision (ROD) was issued  in September 1998.  Remedial
Design started in October 1998. The Final Remedial Action is expected to start by December
1999. These delays are not expected to further impact the schedule for completion of the
Final Remedial Action, because the action is more easily implementable than the original
proposal.

Remediation Costs

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

      Federal       $  1,500,000  (Does not include EPA's indirect costs)
      State         $   141,000  (Does not include travel costs)
      PRP         $40,200,000  (Unverified DuPont estimate)

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

      Federal       $    500,000
      State         $    100,000
      PRP         $ 65,102,000 (includes O&M)

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                            A-13
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
Sept 1999
	
	
Jun 1997
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
Dec 1999
COMPLETED
COMPLETED
Sept 2001

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                                      A-14

                          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 50 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 transmissive zones monitored  by
CECOS. The volatile organic compounds (VOC) detected include acetone, 2-butanone,
benzene, chloroform, toluene, chlorobenzene, methylene chloride, and tetrachlorethane.

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                                     A-15

Interim Corrective Measures (ICM)

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

CECOS submitted a Corrective Measure Implementation (CMI) design in August 1995 and

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                                     A-16

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-17
CECOS INTERNATIONAL
Output
RFI Work Plan Approval
RFI 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-18

                  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 1A 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 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 achieved. The bedrock is separated
into three groundwater zones (upper, middle and lower). Full containment has been achieved
in the upper zone, the most contaminated zone.  The middle and lower zones have not been
completely contained.  Full control has not been achieved in the northwest corner of the site
in these two zones.  Approximately 90% of the contaminated groundwater in the middle
zone, and 80-90% of the contaminated groundwater in the lower zone, has been contained.
Remedial work to achieve full containment is continuing, as described below.

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                                     A-19
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 includes:

 !      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
Phase I Source Control Extraction Wells Installed
Phase II Source Control Extraction Wells Installed
Overburden Barrier Collection System
APL/NAPL Plume Redefinition
Start
10/88
—
	
01/98
07/90
04/90
04/94
—
04/90
Complete
12/89
05/89
04/91
03/98
01/92
06/90
07/94
11/90
07/90
(Table continued on next page)

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                                      A-20
Phase I Prototype Purge Wells Installed
Phase II Prototype Purge Wells
Phase III Purge Wells
3 Additional Bedrock Purge Wells and Force Main
Recirculation Wells
Cluster Monitoring Wells
Landfill Cap
04/90
03/93


01/91
06/90
08/94
07/90
12/93
05/97
12/98
03/91
09/90
12/94
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. Annual inspections are  conducted to maintain the integrity of this
program.

Fences 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.  Sampling of the fenced seeps was conducted
in 1997. Results indicated no need for additional control or remediation of the seep areas.
Annual inspections are performed at all recorded seep locations.

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 activated carbon treatment.  Biological treatment, which was not
required in the settlement  agreement, was added  by OCC in an attempt to reduce treatment
costs.  It was subsequently discontinued.  All vapors in the closed system are treated, and
NAPL is trucked to Laidlaw Environmental Services in Deer Park, Texas, for incineration.
To date, 286,600 gallons of NAPL have been destroyed.

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                                      A-21

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, 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.   These  additional  wells are
equipped with two-phase flow submersible pumps which should enhance the flow of NAPL
into these Source Control wells. The NAPL collected by these wells is pumped by force
mains into the Leachate Treatment Facility's NAPL storage tank.

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.

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
       wells (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 III 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 III monitoring indicated that the bedrock NAPL collection system in this area
       still did not meet performance criteria. Three additional bedrock wells were installed
       in spring 1998. A force main connecting these wells to the treatment plant will be
       completed by December 1998.

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                                      A-22

 !      Additional wells may be necessary to assure an inward hydraulic gradient on all
       vectors within the bedrock.  The dates shown below for completion of remedial
       system construction (September 1999) and final remedy completion (September
       2000) would allow time for installation and testing of additional extraction wells, if
       necessary

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. An impermeable 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. By  September 1999, all remedial
systems for the overburden and bedrock will be completed. It is expected that these remedial
systems will be operational* by September 2000. Remedial efforts now focus on operating,
monitoring and adjusting the systems to ensure remedial effectiveness.

During January - March 1998, the APL treatment system was upgraded to handle a higher
flow of 100-150 gallons per minute.

Remediation Costs

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

       Federal       $11,000,000
       PRP          $ 47,000,000

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.
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-23

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                                       A-24
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
Sept 1999
Sept 2000
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-25

                                 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 flyash.

Two overburden aquifers and one bedrock aquifer are 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

-------
                                      A-26

time the Remedial Design started.

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
requires these sediments to be excavated and placed behind the wall within the
encapsulated landfill. The redesign will enable 2 to  3 acres of embayment water
resources to be saved.

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.  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 will take advantage of excess capacity at the
Love Canal Treatment  Plant.  Instead of on-site leachate treatment, a force main is being
constructed to pump leachate from the 102nd Street Site to the Love Canal Treatment
Plant. This change is not expected to delay the completion and optimization of the final
remedial action.

The leachate pumping system will be completed in December 1998, at which time the
potential for contaminants to run to the River from this site will be eliminated.
Landscaping and optimization of the pump-and-treat system will continue until March
1999.

Remediation Costs

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

       Federal       $  7,900,000 (Indirect costs not included.)

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       State
       PRP
                 A-27

$ (State costs are included with EPA costs)
$ 18,000,000
It is estimated that the following amounts will be spent from now to the completion of
remediation:

       Federal       $ 2,000,000
       State         $ (State costs will be included with EPA costs)
       PRP          $ 8,000,000
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
Previous
Target Date
Mar 1990
Sep 1990
Jun 1995
Dec 1993
Dec 1993
Dec 1995
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
Mar 1999*
       The potential for contaminants to flow to Niagara River from this site will be
       eliminated in December 1998, when the leachate pumping system is completed.
       Landscaping and optimization of the pump-and-treat system will continue until
       March 1999.

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                                      A-28

                        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 a 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, a 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. The permit required
final Corrective Measures Implementation (CMI), consisting of groundwater pump-and-
treat programs for on- and off-site contamination.

The 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.

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                                      A-29

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 areal extent of the contamination is diminishing. Five extraction
wells have been installed to contain the off-site groundwater.  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 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.

With the above modifications, it is expected that all contaminated groundwater is being
intercepted and treated on-site, so that no loading is currently migrating from the site. Six
extraction wells are currently operating in the on-site system.  The on-site system is
designed to recover four pounds of volatile compounds daily.

Remediation Costs

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

       Federal        $  (Oversight costs not available)
       State         $  (Oversight costs not available)
       PRP          $  1,500,000 (Capital/Operation/Maintenance)

It is estimated that the following amounts will be spent from May 1997 to the completion
of remediation:

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

-------
                            A-30
PRP
$ 500,000

-------
                                    A-31
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
* Start-up completed.  On-site system is still being tested and optimized.

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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 organics (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 CMI
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.

-------
A-35

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                                     A-36

                     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. Approximately 200 yards to the south is the
Niagara River and immediately to the east is the 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 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.

Remedial Actions

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                                      A-37

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) is not functioning
as designed.  An investigation in late 1997 revealed that the drain pipe is collapsed at
several locations.  EPA/DEC are currently assessing what actions need to be taken in
order to repair or replace the damaged system.  EPA anticipates that these problems will
delay completion of the Remedial Action until 2000.

The new DWTP was completed and fully operational by March 1997.  The remedial
activities planned for the old DWTP and property, including the decommission and
demolition of the plant, began thereafter and are now nearly complete. It is noted that the
performance of such activities 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 was completed in May 1998. The installation of the cap for the DWTP
property and the overburden drain collection system are ongoing.

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 in the overburden to: 1) collect
       contaminated ground water and 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 bedrock purge wells to contain the NAPL plume in the bedrock;
•       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 APLs 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, APL/NAPL collection wells (i.e., pumping wells),
       and the force mains for the drain and collection wells were completed in 1995 for

-------
                                      A-38

       the landfill. Additional wells were installed in 1997 to improve the performance
       of the system in collecting NAPL. The drain collection system planned for the old
       DWTP property is currently being installed.
•      Operation of the landfill drain collection system and collection wells began in
       1996 and is ongoing.  As noted above, the drain collection system is not
       functioning as designed due to damage of the collection pipe.  Additional actions
       will be required to correct this condition.
       An APL/NAPL storage facility and carbon adsorption treatment facility have been
       constructed on site and currently receive APL/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 final landfill cap is scheduled for construction in 1999, but is likely to be
       delayed pending resolution of the problems with the landfill drain collection
       system.
•      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 cap and drain collection system are being installed. Completion is
       expected in December 1998.

An updated schedule for remediation of the site follows.  The schedule shows that
remedial action at the site actually began before completion of all components of the
remedial design.  Completion of the remedy at the S-Area site was delayed, because,
after the site was surveyed between 1986 and 1988, the remedy was substantially
expanded to include adjacent off-site areas that were found to be contaminated.
Subsequently,  the target dates were revised for the 1991  RRT stipulation.  In 1993,
construction activities were also  postponed until the Environmental Health & Safety Plan
Air Monitoring program was modified. Construction resumed in June 1994. As noted
above, the remedial actions for the DWTP property could not begin until the new DWTP
was completed and operational.  EPA anticipates that completion of the landfill remedy
(including the final landfill cap) will be delayed until 2000 due to the problems with the
landfill drain collection system.

Remediation Costs

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

       Federal      $ 10,000,000
       State         $ (State costs were covered under EPA costs through grants)
       PRP         $42,174,000

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                                            A-39

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

             Federal       $2,100,000
             State         $ (Not available)
             PRP          $8,000,000 (Capital costs)
                           $ 2 to 3,000,000 per year for 30 years (Operation & Maintenance)
       OCC S-AREA
Output
RRT Survey work (RI)
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
Perimeter landfill
cap & drain
collection sytem
Final landfill cap
Construct Eastern
barrier wall
RA Completion
Responsible
Party
PRP
PRP
EPA/DEC
PRP
PRP
PRP
PRP
PRP
PRP
PRP
PRP
PRP
Previous Target
Date
—
	
Mar 1990
	
Jun 1991
Apr 1997
Sep 1997
1998
N/A
1999
Jul 1998
1999
Current Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
Dec 1998
COMPLETED*
2000
COMPLETED
2000
  Drain collection system not functioning as designed. EPA and DEC are assessing necessary
corrective actions.

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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 include bedrock groundwater pumping and  treatment (including DNAPL
extraction), and soil vapor extraction, both on and off site. The site will also be re-
graded.

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.  Operational
difficulties had been encountered with the groundwater treatment system. The
groundwater treatment system has been modified.  Groundwater now flows through
granular activated carbon prior to discharge to the NYPA  Forebay.

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                                     A-41
Remedial actions completed include the following:

•      Installation of a bedrock pump-and-treat system that will operate for the next 30
       years.
•      Installation of a soil vapor extraction system that draws contaminants out of the
       soil.  This system is expected to operate for about 3-5 years.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:
       State
       PRP
$  170,000
$ 5,100,000
It is estimated that the following amounts will be spent from now to the completion of
remediation:
       State
       PRP
$    10,000
$ 1,200,000
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 litigates 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.
             Site to be capped.
       •      Contaminated groundwater to be hydraulically controlled through pump-
             and-treat systems.

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                                         A-43
    DEC and site PRPs have 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 and as of September 1998, asbestos removal is complete and
    site demolition is nearing completion. Design of on-site extraction and pretreatment
    systems is ongoing.

    Remediation Costs

    Following are estimated amounts that have been spent to date on remediating this site:
           State
           PRP
$ 1,170,000
$  950,000
    It is estimated that the following amounts will be spent from now to the completion of
    remediation:
           State
           PRP
$         0*
$ 13,250,000
    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
Sep 1994
Dec 1994
Dec 1995
Dec 1996
N/A
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED
Dec 1999
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 1A 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 to further define the nature and extent of
contamination at the Niagara Mohawk and NYPA properties.

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                                     A-45

Under Consent Order, SKW is undertaking an Interim Remedial Measure to cap portions
of their parcel and control site stormwater runoff.  This remedial measure should be
completed by December 1998. DEC and Airco are negotiating an RI/FS for all or
portions of the site. The outcome of these negotiations will determine whether additional
RI/FS work is necessary by the other PRPs.

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.

Remediation Costs

Following are estimated amounts for the Interim Remedial Measure:
       State
       PRP
$ (Not available)
$  750,000 (for SKW Interim Remedial Measure)
It is estimated that the following amounts will be spent from now to the completion of
remediation:
       State
       PRP
$ (Not available; site has yet
$ to proceed to remediation)
VANADIUM CORPORATION OF AMERICA
Output
Phase I Investigation
Phase II Investigation
Interim Remedial Measure
RI/FS
Record of Decision
Remedial Design
Remedial Action
Responsible Party
DEC
DEC
SKW Alloys, Inc.
PRP(s)
DEC
PRP or DEC
PRP or DEC
Previous
Target Date
Dec 1989
Dec 1991
N/A
Mar 1999
July 1999
July 2000
July 2001
Current
Schedule
COMPLETED
COMPLETED
Dec 1998
Mar 2000
July 2001
July 2002
July 2003

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                                      A-46
                             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.

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                                     A-47

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
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 groundwater
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 (C 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.

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                                      A-48

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

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-49
OLIN CORPORATION
Output
RFI Work Plan
Approval
RFI
Completion
Phase I
Phase II
Stabilization Start-up
(Groundwater)
CMS Work
Plan
Approval
Phase I
Phase II
CMS Completion
(including approval)
Remedy Selection
CMI Work Plan
Approval
Start-up of CMI
Initiation/Stabilization
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 I - Overburden soil and groundwater
             Phase II - Bedrock groundwater

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                                     A-50

                        DUPONT - BUFFALO AVENUE
                                   Site# 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. From start up in January 1992 through January 1, 1998, 48,600 pounds of
organic  contaminants have been removed from the overburden and shallow bedrock
groundwater.  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. The Olin production wells have removed
approximately  19,082 pounds of organic contaminants for the period of 1/1/92 through
1/1/98.

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.

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                                     A-51
Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:
       State
       PRP
$    50,000
$ 45,000,000 (includes Gill Creek remediation)
It is estimated that $ 2,000,000 will be spent 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
Previous
Target Date
Dec 1989
Mar 1990
Oct 1991
Status
COMPLETE
COMPLETE
COMPLETE

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                                      A-52

                      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-53

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. The revised RFI report is scheduled to be
submitted December 1998. The supplemental investigations are delaying completion of
the RFI by approximately two years. Depending on the progress and results of the
additional work, it is anticipated that stabilization/interim corrective measures could be
initiated in 1999, if necessary.

All target dates in the table below have been updated to account for these delays.
Completion of the RFI, CMS, and CMI are 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)

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                                    A-54

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
Mar 1999
May 1999
Aug 1999
May 2000
Aug 2000
Apr 2001
Jul 2001

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                                      A-55

                         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 has remained idle since.  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 are 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-56
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;
•      Non-aqueous phase  liquids found at the site are being removed;
       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
Previous
Target Date
Sept 1990
Dec 1990
Dec 1992
June 1996
Nov 1997
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED
COMPLETED

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                                      A-57

                    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. Currently, only specialty steel production and
coking are in operation. 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-Lackawanna area, 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 three 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 IIA) 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, chlorinated solvents 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 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

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                                      A-58

assessment.  In July 1996, EPA/DEC approved the Ecological Risk Assessment Work
Plan, and BSC has completed a draft of this assessment, which is also a component of the
RFI.

EPA and DEC have identified two areas (Acid Tar Pits and Coke Oven Areas) where they
believe BSC could implement 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 are the primary sources of groundwater contamination at this
facility.  At this time, BSC has not undertaken any of these stabilization activities.  At
EPA's request, BSC completed remedial technology studies for these areas. EPA
approved the studies with the understanding that they would be incorporated into a more
comprehensive technology assessment for the CMS. However, EPA and DEC found the
studies to have major technical flaws. A CMS will commence after RFI Report approval,
which is currently scheduled for April 2000. All CMS and Corrective Measure
Implementation (CMI) work will be performed pursuant to a subsequent order or permit.

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.

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 has been extended.  All subsequent target dates have been 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)

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                                     A-59
BETHLEHEM STEEL CORPORATION
Output
RFI Work Plan Approval
RFI Completion
RFI Report Approved1
Responsible Party
EPA/DEC
Permittee
EPA/DEC
Previous Target
Date
Jan 1990
Dec 1997
Jun 1998
Current
Schedule
COMPLETED
Mar 1999
Apr 2000
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
N/A
Nov 1998
Jul 1999
Oct 1999
Aug 2000
Dec 2000
July 2000
Oct 2000
June 2001
Oct 2001
Aug 2002
Dec 2002
1   RFI to include human health and ecological risk assessments.

2   These outputs will be implemented under a new Order or Permit. Target dates
dependent upon facility owner/operator agreement to complete these stages of site
corrective action program.

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                                      A-60

                       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, and calls for the
following remedial actions:

              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, except sediment removal, due to an increase in
the quantity of sediment to be removed. Sediment removal began in July 1998 and
should be complete by November 1998. Final capping of the sediment disposal area is
likely to be completed by June 1999.

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                                     A-61
Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:
       State
       PRP
$   546,000
$ 10,200,000
It is estimated that the following amounts will be spent from now to the completion of
remediation:
       State
       PRP
$*
$ *
RIVER ROAD (INS EQUIPMENT)
Output
RI/FS
Record of Decision
Remedial Design
Remedial Action
Completion
Responsible Party
DEC
DEC
PRPs
PRPs
Previous
Target Date
Jun 1991
Sep 1991
Sep 1992
Oct 1997
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
June 1999
* RA nearly complete, so costs are shown above. Costs include Niagara Mohawk Cherry
Farm site.

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                                      A-62

                   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.

There are widespread contraventions of ground water and surface water standards at the
site. Organic contaminants such as vinyl chloride, phenols, naphthalene,
trichloroethane, benzene, and xylene are present at levels which exceed ambient water
quality standards and guidance values for ground water.  Metals exceeded surface and
ground water standards in numerous cases. Aquatic sediment guidance values were
exceeded for PCBs found in one sediment sample and metals exceeded these levels in
several samples.

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  1) 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

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                                      A-63

combined with the adjacent River Road site for joint remediation. Please see the previous
site description for details on the remedial actions that will be carried out and the
schedule for completion. Except for removal of river sediments along the site, the
remedial work is complete.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:
       State
       PRP
$*
$ *
It is estimated that the following amounts will be spent from now to the completion of
remediation:
       State
       PRP
$*
$ *
NIAGARA MOHAWK - CHERRY FARM
Output
RI/FS
Record of Decision
Remedial Design
Remedial Action
Responsible
Party
PRPs
DEC
PRPs
PRPs
Previous Target
Date
NA
NA
NA
NA
Current Schedule
COMPLETED
COMPLETED
COMPLETED
June 1999
RI/FS for 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-64
                    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 (RI/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 has been
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-65
Long-term O&M has started and 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)
$ 14,000,000
It is estimated that the following amounts will be spent for the O&M  from now through
completion:
       State
       PRP
$   50,000
$ 1,800,000
FRONTIER CHEMICAL, PENDLETON
Output
RI/FS
Record of Decision
Remedial Design
Remedial Action
Responsible Party
DEC
DEC
PRPs
PRPs
Previous
Target Date
Dec 1991
Mar 1992
May 1994
May 1995
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
COMPLETED

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                                      A-66

                  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 and west of the site
boundaries, 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.

Interim Remedial Actions

This facility was formerly regulated under RCRA and 6 NYCRR Part 373-2.  The
company that operated the facility went bankrupt in 1992.  As a result, New York State

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                                      A-67

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.

Three operable units were implemented at the site. Operable unit one (OU1) involved the
use of an EPA contractor to provide maintenance to the drums and tanks at the facility.
Operable unit two (OU2) dealt with enforcement actions leading to the removal of over
4,000 drums and 6,700 pounds of laboratory chemicals from the site. Operable unit three
(OU3) deals with enforcement actions for the removal of all wastes from the 45 tanks on
site.

OU2 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.

OU3 began in July 1994, after approximately 3 months of negotiations with well over 200
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

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 Superfund.
EPA has ruled not to include this site on the NPL. The DEC has initiated PRP search
efforts to be followed by negotiations of an RI/FS Order to address soil and groundwater
contamination.

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).

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site
(EPA Emergency Removal Action):

      Federal       $ 1,100,000

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                                    A-68
       State
       PRP
$   50,000
$ 3,600,000
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)
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
Target Date
COMPLETED
COMPLETED
Schedules dependent on establishment of PRP
group and subsequent RI/FS Order negotiations.

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                                     A-69

   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 and was shut down. Operation  of remedial systems at the plant 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

The Durez site is a DEC-lead site. Remedial activities have been conducted under
several consent orders. At this time, 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 sewer and
cove sediments are in controlled storage at OCC's Niagara Plant, awaiting destructive
treatment.

The remediations have proceeded  in 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 in 22,000 linear feet of sewers have been removed
       and are staged at the OCC  Niagara Falls Main Plant pending treatment.

       Pettit Creek Cove: Remediation  of the Pettit Creek Cove, a source of
       contaminated water and sediment to the Niagara River, has been completed under

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                                     A-70

       consent order. The RI/FS for the cove was completed in December 1991. A
       Record of Decision for the cove was issued in March 1992 to excavate and treat
       contaminated soil, sediment, and dense non-aqueous phase liquid (DNAPL), and
       restore the Cove as a wetland area. The major elements of the Remedial Action
       plan, including sediment removal at the cove, pumping of DNAPL, and dredging
       of the Little Niagara River have been completed. A total  of 23,500 cubic yards of
       soil and sediment were removed. The site is both stabilized and isolated.

Remediation Costs

Following are estimated amounts that have been spent through May 1997 on remediating
this site:
       State
       PRP
$   510,000
$ 32,000,000
It is estimated that the following amounts will be spent from May 1997 to the completion
of final treatment and disposal of remedial wastes:
       State
       PRP
$   100,000
$  8,000,000
OCC - DUREZ, NORTH TONAWANDA
Output
Responsible
Party
Previous
Target Date
Current
Schedule
Remedial Construction:
Plant Site
Sewer Clean-up
PRP
PRP
Jun 1991
NONE
COMPLETED
COMPLETED
Pettit Creek Cove:
RI/FS
Record of Decision
Remedial Design
Remedial Action
PRP
DEC
PRP
PRP
NONE
NONE
Sep 1993
Dec 1994
COMPLETED
COMPLETED
COMPLETED
COMPLETED

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                                      A-71

                        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 1960, 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 construction
costs.

Remedial Design (RD) started in early  1996. The design includes:
       •      Shoreline protection
             Hydraulic barrier 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
vegetation to be planted, and to include features to provide erosion resistance.  These

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                                     A-72

changes are being submitted for approval in a proposed amendment to the ROD released
in September 1998. Remedial construction is expected to begin in early 1999.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:
       State
       PRP
$ 1,000,000
$  500,000
It is estimated that the following amounts will be spent from now to the completion of
remediation:
       State
       PRP
$ 0
$ 10,700,000
Operation and Maintenance costs are estimated at $1,140,000 for ten years.
GRATWICK RIVERSIDE PARK
Output
RI/FS
Record of Decision
Remedial Design
Completion
Remedial Action
Completion
Responsible Party
DEC
DEC
PRPs
PRPs
Previous
Target Date
March 1990
June 1990
April 1998
Dec 1999
Current
Schedule
COMPLETED
COMPLETED
Nov 1998
April 2000

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                                      A-73

                                  MOBIL OIL
                                    Site #141

Site Program:  NY Division of Hazardous Waste Remediation/Multimedia Pollution
               Prevention Program
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-74

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 has 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 are to be submitted to
DEC by December 1998.

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-75
MOBIL OIL
Output
Phase I Investigation
Phase II Investigation
Re-classification to Class 3*
Responsible Party
DEC
PRP
DEC
Previous
Target Date
Sept 1983
Dec 1986
Dec 1988
Current
Schedule
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-76

             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-77

       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 RI 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 commenced in July 1998
and is scheduled for  completion in October 1999. Delays in the  schedule for the creek
remediation resulted from disagreement between DEC and the PRP on design concepts,
and technical  difficulties relative to ensuring the structural integrity of the elevated

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                                    A-78
roadway above the creek.

Remediation Costs

Following are estimated amounts that have been spent to date on remediating this site:
      State
      PRP
$  100,000
$ 2,000,000
It is estimated that the following amounts will be spent from now to the completion of
remediation:
      State
      PRP
$  150,000
$ 5,000,000
IROQUOIS GAS - WESTWOOD PHARMACEUTICAL
PLANT SITE:
Output
Record of Decision
Remedial Design
Remedial Action
Responsible Party
DEC
PRP
PRP
Previous Target
Date
Mar 1994
May 1997
Sept 1997
Current
Schedule
COMPLETED
COMPLETED
COMPLETED
CREEK SITE:
Output
Record of Decision
Remedial Design
Remedial Action
Responsible Party
DEC
PRP
PRP
Previous Target
Date
Mar 1994
Apr 1996
Dec 1997
Current
Schedule
COMPLETED
COMPLETED
Oct 1999

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                                      A-79

                                  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 Consolidated Rail Corporation. The  site is located about 500 feet from
the Little Niagara River.

Waste oils were refined at the site for more than 50 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 RI 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 Superfund. However, many Potentially
Responsible Parties (PRPs) exist, including the site owners and numerous generators who
shipped waste to the site. Negotiations with the PRPs for performance of the RD/RA
continues. A PRP proposal  for an alternate remedy was accepted in June 1998. The
alternate remedy includes all the components of the remedy in the RODs noted above,
except excavated material will be disposed off site.  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

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                                     A-80
      PRP
$0
It is estimated that the following amounts will be spent from now to the completion of
remediation:
       State
       Permittee
$ (Not available)
$ 15,000,000
BOOTH OIL
Output
Responsible Party
Previous
Target Date
Current Schedule
OU1
RI/FS
ROD
Remedial
Design
Remedial Action
DEC
DEC
PRP
PRP
Feb 1992
Mar 1992
Mar 1998
N/A
COMPLETED
COMPLETED
June 1999
June 2000
OU2
RI/FS
ROD
Remedial
Design
Remedial Action
DEC
DEC
PRP
PRP
Feb 1993
Mar 1993
Mar 1998
N/A
COMPLETED
COMPLETED
June 1999
June 2000

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