Niagara River Toxics Management Plan (NRTMP) Reports

Appendix 
Priority Niagara River Hazardous Waste Sites

OCCIDENTAL CHEMICAL -- BUFFALO AVENUE 
Site #41b - 49

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

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

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

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

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

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

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

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

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

Site Investigation
Pursuant to the permits, OCC completed the on-site and off-site components of a RCRA Facility Investigation (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. OCC has prepared a comprehensive, site-wide CMS, addressing all site components including the adequacy of the stabilization measures described below. This was submitted in November 1998.

Stabilization Measures (Additional Interim Corrective Measures)
Bedrock Groundwater. All of the bedrock groundwater extraction wells and monitoring wells have been installed. A new treatment plant designed to treat the contaminated bedrock groundwater has been constructed. The pump-and-treat system has been started up. From April 1996 through September 1996, as part of the testing and optimization of the remedial system, over 700 gallons per minute of contaminated groundwater were pumped from the upper three bedrock aquifers and treated at the new treatment plant. Three bedrock wells have collected, through May 1997, approximately 5,840 gallons of DNAPL from the site. The DNAPL is incinerated in OCC's hazardous waste incinerator. The pump-and-treat system was tested and optimized through March 1997. The pumping rates of each of the 19 bedrock groundwater extraction wells were optimized to achieve a hydraulic barrier along the northern and western plant boundaries to contain the contaminated groundwater.

Based on performance monitoring data, OCC determined that additional measures were necessary to achieve the remedial design objectives. The treatment plant has been enhanced by adding additional treatment measures (air stripping to address break-through of vinyl chloride), and expanding the plant’s capacity from 800 gpm to 1200 gpm. OCC subsequently increased the extraction rate of the bedrock groundwater recovery system to 1000 gpm. On average more than 30 pounds per day of organic chemicals are captured by the bedrock groundwater collection system.

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

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

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

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

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

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

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

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

The Final Corrective Measures in the final permit include:

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

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

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)

NIAGARA COUNTY REFUSE DISPOSAL 
Site # 81

Site Program: Federal Superfund
Summary Prepared by: EPA

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

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

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

Site Investigation
Niagara County Refuse is an EPA-lead site on the National Priorities List of Superfund sites. Pursuant to a March 1989 consent order, a group of fourteen Potentially Responsible Parties (PRPs) performed a Remedial Investigation/Feasibility Study (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 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.

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

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

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

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

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

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

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

Federal $ 1,250,000
PRP $ 11,200,000

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

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

The Site was capped in 1978. Since 1982, two recovery wells near the center of the property, when operational, have recovered contaminated groundwater and established a partial hydraulic barrier in the upper bedrock and overburden along the southern edge of the landfill. However, some upper bedrock groundwater continued to flow south toward the Niagara River. In order to improve containment and collection of contaminated groundwater, an up-gradient grout curtain was installed in the bedrock in August 1989. A third recovery well, which penetrates the middle bedrock zones at the southern boundary of Necco Park, went into limited operation in 1992. These on-site remedial actions have resulted in an estimated load reduction from the site of approximately 27% to 55%, based on information collected pursuant to the AOC. DuPont estimates that approximately 150 million gallons of groundwater have been pumped since 1983. Since 1989, 6,780 gallons of DNAPL have been recovered, containing approximately 90,400 pounds of organic compounds.

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

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

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

1. Containment of the Source Area by:

• Upgrading the existing cap to meet New York State Part 360, 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.  
   
5. Comprehensive monitoring to verify hydraulic control, identify DNAPL occurrence, demonstrate the effectiveness of the remedial measures, and assess the impact of such measures on far-field groundwater quality.  
   
6. Additional characterization of the Site to assess whether natural attenuation will be effective in addressing far-field contamination.  
   
7. Development and implementation of institutional controls to restrict Site access, the use of groundwater at the Site, and control land use such that it is consistent with Site conditions. 

Schedule for Completion
The Proposed Plan was released to the public in July 1996, upon approval of the FS. A public meeting to discuss the Proposed Plan was held in August 1996, shortly after its release. Because of extensive public comments received on the Proposed Plan, EPA revised the Proposed Plan in response to the comments and provided a second public comment period. A Record of Decision (ROD) was issued in September 1998. Design studies started in October 1998. The remedial design is underway. In September 2000, DuPont commenced installation of additional groundwater wells that will serve as component parts of the hydraulic containment portion of the final remedy. RA completion is expected by October 2003. Because of the fractured bedrock beneath the site, complications may arise in achieving effective hydraulic containment. The target date is intended to allow sufficient time to ensure that any additional remedial work to achieve effective containment can be completed, and that the system is tested and optimized.

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

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

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.

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 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:

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

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 ½ mile from the Niagara River.

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

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

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

Substantial containment of bedrock groundwater has also been achieved. 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.

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

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

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 has been conducted annually since 1997. Results continue to indicate 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. All vapors in the closed system are treated. During January - March 1998, the APL treatment system was upgraded to handle a higher flow of 100-150 gallons per minute. OCC is currently upgrading the capacity of the treatment system to 400 gallons per minute so it can adequately handle excess water in wet weather.

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

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

The Overburden Barrier Collection System, 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 pumping wells were installed and connected by force mains to the on-site treatment facility in 1998. Three additional wells were installed and connected to force mains in 1999; one additional well and five monitoring wells were installed in 2000.
• Additional wells or other remedial measures will be necessary to assure an inward hydraulic gradient on all vectors within the bedrock. OCC is currently producing a groundwater model to better understand the groundwater flow in the immediate vicinity of the site. The output of the model will be utilized to place additional wells more effectively or to determine if other remedial measures should be taken at the site. Completion of all remedial systems is expected by September 2001.

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 Tams Ceramics, a neighboring industrial plant in 1989, and the College Heights sewer was remediated in 1990.

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

Complex site conditions and difficulties in pumping NAPL have resulted in the installation of additional wells, thus delaying completion of remediation. However, the landfill has been capped, a leachate collection system surrounds the landfill, NAPL is being extracted and destroyed, and Bloody Run creek has been excavated. Also, additional wells have been installed to ensure sufficient bedrock NAPL containment. By September 2001, all remedial systems for the overburden and bedrock will be completed. It is expected that these remedial systems will be operational* by December 2001. Remedial efforts now focus on operating, monitoring and adjusting the systems to ensure remedial effectiveness.

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

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.

** 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.

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

Site Program: Federal Superfund
Summary Prepared By: EPA

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

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

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

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

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

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

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

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

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

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

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

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

Costs for Operation and Maintenance expected to be incurred in the future are approximately $100,000 per year, and will be paid by the PRPs.

______________________________
* The potential for contaminants to flow to Niagara River from this site was eliminated in December 1998, when the leachate pumping system was completed. Landscaping and optimization of the pump-and-treat system was completed in March 1999.

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.

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. However, as the off-site plume has become smaller, four extraction wells were determined to be optimal for pumping. The extracted groundwater contamination is discharged into the publicly owned treatment works (POTW) of the Town of Wheatfield. The off-site system is designed to recover two pounds of volatile compounds daily. The performance of the off-site remedial system is considered acceptable.

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

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

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

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

Remediation Costs
Following are estimated amounts that have been spent through May 1998 on remediating this site:

It is estimated that the following amounts will be spent from May 1998 over the next ten years for operation and maintenance.

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.

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 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:

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

______________________________
*  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.

OCCIDENTAL CHEMICAL S-AREA 
Site # 41A

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

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

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

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

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

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

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

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

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

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

Securement of the raw water intake structures from the old DWTP is scheduled for completion in 2000. The grouting of the 5,000-foot long DWTP bedrock intake tunnel commenced in August 2000.

The full remedial program for this site consists of:

• A slurry barrier wall in the overburden to contain the NAPL plume;
• Installation of a drain system and collection wells (i.e., pumping wells) in the overburden, within the barrier wall, to: 1) collect contaminated ground water and NAPL, and 2) create an inward hydraulic gradient across the barrier walls and an upward hydraulic gradient from the underlying bedrock to the overburden within the barrier wall;
• Installation of wells in the bedrock to contain NAPL by creating an inward hydraulic gradient across the bedrock NAPL plume boundary, and to collect NAPL from the bedrock, to the maximum extent practicable;
• Capping of the site to reduce infiltration;
• Overburden and bedrock monitoring to determine the effectiveness of remedial systems;
• Incineration of non-aqueous-phase liquids; and
• Treatment of contaminated groundwater by carbon adsorption and discharge to a permitted outfall.

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

The following progress has been made:

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

An updated schedule for completing the remaining remedial construction activities at the site follows. EPA anticipates that all of the components of the remedy (including the final S-Area and DWTP monitoring programs) will be installed and fully operational by the end of 2001.

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

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

______________________________

¹ The securement of the DWTP intake structures, including the grouting of the 5,000-foot long bedrock intake tunnel, commenced in summer 2000. Completion is scheduled for fall 2000.
² The construction of the final S-area Landfill cap commenced in August 2000.
³ Construction activities for the year 2001 include the remaining bedrock monitoring programs at both the S-Area and former DWTP property.

STAUFFER CHEMICAL
Site # 255

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

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

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

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

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

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

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

Remedial actions completed include the following:

• Installation of a bedrock pump-and-treat system that will operate for the next 30 years.
• Installation of a soil vapor extraction and dewatering system that draws contaminants out of the soil.

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

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

It is estimated that the following amounts will be spent from now on Operation and Maintenance of the remedial system:

SOLVENT CHEMICAL 
Site # 251

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

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

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

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

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

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

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

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

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

______________________________
¹  PRP will reimburse future state costs.

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 ½ miles east of the Niagara River in the Town of Niagara.

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

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

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

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

Under Consent Order, SKW completed an Interim Remedial Measure to cover portions of their parcel and control site storm water runoff. This remedial measure was completed in November 1998. DEC and Airco negotiated an Interim Remedial Measure (IRM) to cap the landfill on their portion of the site. Work on implementation of the Airco IRM began in May 2000 and is expected to be completed by November 2000.

Schedule for Completion
A schedule for completion is presented below. The site PRPs have not agreed to act as a group. This has contributed to delays in the schedule due to the need to negotiate individually with the PRPs. The NYSDEC plans to open negotiations with Niagara Mohawk and the New York Power Authority to address their portion of the site.

Remediation Costs
Following are estimated amounts for the Interim Remedial Measures:

OU #1:

OU #2:

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

OLIN CORPORATION 
Site #58, 59

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

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

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

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

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

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

An EPA/DEC-approved DNAPL interim corrective measure (ICM) was implemented by Olin during May and June 1994. The program was intended to identify and characterize 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 and CD zones). The remedy approved in the CMS is designed to capture all groundwater contamination not captured by the Olin production wells. The wells extract groundwater at a rate of approximately 600 gallons per minute continuously.

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

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

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

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

Operation & Maintenance is now underway. The remedial system is close to meeting its performance objectives. Olin is addressing problems due to incrustation associated with high pH (>10) groundwater. For example, two pumps have been replaced and a system to inhibit scaling of the pumps and pipes has been installed. Recent performance reports indicate that system performance has improved, but more actions may be necessary.

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

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

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

OLIN CORPORATION
Output		Responsible Party	Previous Target Date	Current Schedule
RFI Work Plan Approval		DEC/EPA	Apr 1990	COMPLETED
RFI Completion	Phase I	Permittee		COMPLETED
	Phase II	Permittee	Dec 1994	COMPLETED
Stabilization Start-up (Groundwater)				COMPLETED
CMS Work Plan Approval	Phase I	Permittee		COMPLETED
	Phase II	DEC/EPA	Sep 1993	COMPLETED
CMS Completion (including approval)		Permittee	Mar 1995	COMPLETED
Remedy Selection		DEC/EPA	Mar 1996	COMPLETED
CMI Work Plan Approval		DEC/EPA	Mar 1996	COMPLETED
Start-up of CMI Initiation/Stabilization		Permittee	Dec 1996	COMPLETED

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, 2000, 64,500 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 22,200 pounds of organic contaminants for the period of 1/1/92 through 1/1/00.

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

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

It is estimated that $ 1,600,000 will be spent annually by the PRP on the Operation and Maintenance of this site.

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.

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

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

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

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

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

The supplemental investigations delayed completion of the RFI. All target dates in the table below account for these delays. Completion of the milestones is dependent, in part, on field conditions encountered, which may delay the overall schedule for corrective action.

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

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

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*  Results of a 1999 pump test indicated that conventional pumping wells should be effective in controlling the migration of contaminated groundwater in Plant Area A, and that migration control should be achievable with a total system pumping rate on the order of 25-30 gpm. Such a system has been proposed as part of the final corrective measures, within the CMS report

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

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

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

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

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

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 the galvanizing process 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, 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 assessment. In July 1996, EPA approved the Ecological Risk Assessment Work Plan, and BSC completed a draft of this assessment, which is also a component of the RFI. A review of the draft Ecological Risk Assessment revealed that additional data collection was necessary to complete the assessment. As such, BSC submitted an Ecological Sampling Work Plan and a Supplemental Solid Waste Management Unit Work Plan in May 2000 to address collection of the additional data.

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 appear to be the primary sources of groundwater contamination at this facility. BSC has not implemented any interim corrective action or stabilization activities to address the contamination in these areas to date. However, BSC has submitted a Pre_design Investigation Report for the remediation of the Benzol Plant Area (i.e., Coke Oven Area). The implementation of the remedial work in the Benzol Plant Area has been delayed due to a dispute over the characterization of the wastes in that area. BSC also previously proposed and performed two remedial technology studies for the acid tar pit area. These studies were found by the EPA and NYSDEC to be technically flawed and of limited value. Any future CMS or CMI activities will require a new order, permit or other agreement.

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

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

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

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

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¹ RFI to include human health and ecological risk assessments.

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