December 2009

The Onondaga Lake Superfund Site

Prepared by Atlantic States Legal Foundation, Inc.

A Citizen’s Guide

Prepared for

The United States Environmental Protection Agency

Preface ................................................................................................................................ 1

Part One Introduction to Superfund ...................................................................... 3

1.1 What’s a Superfund site? ............................................................................................................................... 4 1.2 Who manages Superfund sites? ................................................................................................................. 4 1.3 Who pays for remediation? .......................................................................................................................... 4 1.4 What exactly is “remediation,” anyway? ................................................................................................... 4 1.5 What clean up technologies are available? ............................................................................................. 5 1.6 How is a clean up plan developed? .......................................................................................................... 5 1.7 How long will clean up take? ...................................................................................................................... 5 1.8 How can the public participate? ................................................................................................................ 7

Part Two Onondaga Lake Superfund Site ........................................................... 8

2.1 Background ....................................................................................................................................................... 9 2.2 Sources of Pollution ....................................................................................................................................... 10 2.3 Major Contaminants ..................................................................................................................................... 11 2.4 Environmental Degradation ...................................................................................................................... 11 2.5 Human Health Risks ...................................................................................................................................... 11 2.5.1 Mercury in Onondaga Lake Fish ....................................................................................................... 12 2.6 Onondaga Lake Superfund Subsites ...................................................................................................... 14 2.7 NY State-Regulated Sites around Onondaga Lake ............................................................................ 18 2.8 The Remediation of the Onondaga Lake Sediments ........................................................................ 20

Part Three Sources of Information ....................................................................... 22 3.1 Document Repositories for the Onondaga Lake Superfund Site ................................................. 23 3.2 Useful Links for the Onondaga Lake Remediation ............................................................................. 23

Contents

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Preface On December 14, 1994, the United States Environmental Protection Agency (USEPA) listed Onondaga Lake and its industrially related contaminated areas on the Superfund NationalPriorities List (NPL). The Superfund listing means that the lake system is among the nation’s mostpolluted natural resources and must undergo a hazardous substance clean-up program consistentwith the federal Superfund Law. The federal program is very similar to New York State’s inactivehazardous waste site remediation program; this similarity led USEPA to grant the New York StateDepartment of Environmental Conservation (NYSDEC) the primary management role, together with a series of Federal grants totaling over $15 million (as of 2009). USEPA continues to oversee theOnondaga Lake clean-up.

Onondaga Lake’s pollution arises from multiple sources. The Metropolitan sewage treatmentplant (“Metro”), located south of the Carousel Center, has long been a source of excess nutrients(nitrogen, phosphorus) to the lake. In addition, there are sewer-related issues that have historicallyreleased large quantities of bacteria into tributaries (such as Onondaga Creek) which flow into thelake. All of these sewage issues are being addressed under a court order known as the AmendedConsent Judgment (ACJ) which was put into effect in January 1998. This is entirely separate from theSuperfund listing.

The ACJ required Onondaga County to construct about $150 million dollars’ worth of new treatment processes at Metro to remove both ammonia and phosphorus. These advanced treatment systems have led to major improvements in the lake’s water quality. Ammonia levels in Onondaga Lake have dropped by a factor of six since 1998 and phosphorus levels are at the lowest levels ever recorded in the lake. As a result, water clarity is better and levels of dissolved oxygen, which fish and other creatures depend on, have greatly improved. It has also been found that bacteria levels in the lake are less problematic than originally thought.

Superfund is the name given to a Federal program established by the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA). This law was enacted following the discovery of toxic waste dumps such as Love Canal in the 1970s. It allows the USEPA to clean up such sites and to compel responsible parties (usually industries) to perform cleanups, and to reimburse the government for its costs. State environmental agencies - in this case, the NYS Department of Environmental Conservation - are part of this effort.

Superfund is set up to address primarily pollution which originated from old industrial sources.These sources include old manufacturing sites and hazardous waste disposal sites which arereleasing or threatening to release contamination to the lake. These sources have contaminated thesediments of the lake and several of its tributaries, including Ninemile Creek, Ley creek, and HarborBrook. As of December 2009, the Onondaga Lake Superfund site includes the lake bottom and nine “subsites” in the lake’s watershed. It is a large, complex site; new subsites will likely be added as

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investigations of pollution are completed.

Each individual subsite has its own schedule. The investigations, remedy selections, and clean-upsof the subsites proceed as separate projects. The intention is to obtain voluntary participation ofparties responsible for subsite contamination through the use of administrative consent orders thatobligate a polluter (responsible party) to conduct all or part of the appropriate remediation program.If a polluter fails to voluntarily participate, NYSDEC and USEPA will consider other clean-up optionssuch as completing the program under the auspices of the federal Superfund. The goal of the strategyis that by addressing each subsite, the entire site will be cleaned up. To date, Honeywell Inc., whichinherited the lake bottom and five subsites when it merged with Allied-Signal in 1999, has cooperatedin the cleanup process. General Motors, which is responsible for several subsites along Ley Creek, hasalso been cooperative. The Federal government has assumed a more active role for the GM subsitessince General Motors went through bankruptcy in 2009.

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Part OneIntroduction to Superfund

Superfund refers to a multi-billion dollar pot of money which Congress established in 1980in response to hazardous waste disasters like those at Love Canal in Niagara Falls and, closer tohome, the Pollution Abatement Services sites near Oswego. The fund was originally financedthrough special fees on chemicals and petroleum. This is no longer true. In general, thegovernment relies on money from private industry found to be responsible for some or all of thepollution.

Superfund also refers to the clean-up program established under CERCLA.

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1.1 What’s a Superfund site?

The U.S. Environmental Protection Agency (EPA) has compiled a listing of thousands of sitesacross the U.S where toxic chemicals have been dumped, spilled, or otherwise “released” into theenvironment. Those that are considered the worst are put onto a special list known as the NationalPriorities List (NPL). In so doing, it makes these sites eligible for cleanup funding from the “Superfund.”As of December 2009, 1270 sites were listed on the NPL, with another 63 proposed for listing. Over300 sites have been de-listed. (See http://www.epa.gov/superfund/sites/)

1.2 Who manages Superfund sites?

Usually, the EPA oversees the investigation and cleanup of Superfund sites. However, stateenvironmental agencies have the option of “taking the lead” if they so choose. In the case ofOnondaga Lake, New York State has elected to be the “lead agency.” Therefore, the state Departmentof Environmental Conservation (DEC) manages the site, although USEPA still has oversightresponsibilities. The New York Attorney General’s office is also involved, since Superfund sitesinevitably involve legal disputes between the government and the industries that will be asked tofoot the bill.

1.3 Who pays for remediation?

Usually, private industries pay for cleanup. When a site is put on the NPL, the USEPA and the stategather evidence to identify the polluters or “potentially responsible parties” (PRPs). In the case ofOnondaga Lake, Honeywell International Inc. has been a major source of pollution since the turn ofthe century. Other PRPs have been identified as sources of contamination at the different subsites.

If a company is uncooperative, the government can sue to compel it to perform the cleanup. Asa last resort, the government may undertake the cleanup itself, and then seek punitive damages incourt (up to triple the cost of the cleanup). Federal Superfund money is also used when the PRP(s)cannot be located, or have gone out of business.

1.4 What exactly is “remediation,” anyway?

You will notice, if you read any official literature regarding Superfund or other hazardous wastesites, that the term “clean up” is frequently avoided. In its place, one finds the term “remediation” or“remedial action”. Officials do this because the term “clean up” implies that hazardous materials areremoved from the site to be put somewhere else, or destroyed. Frequently, however, this is not thecase. Leaving contaminants in place and restricting access to the site is the cheapest option, and isoften favored by PRPs faced with paying remediation costs. Many hazardous waste sites have been“remediated” simply by enclosing them with a fence, covering over with several layers of soil andthen planting with grass. Citizen involvement in the selection process is crucial to ensuring that theremedy selected entails a genuine clean-up.

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While confining and isolating hazardous materials on-site may reduce human health risks to levelsacceptable to government agencies, problems may emerge years later. For this reason, Congressincorporated a non-binding preference for “permanent” remedies when it re-authorized Superfund in1986. Furthermore, more and better cleanup technologies have evolved over the last decade. Theseoffer a much greater variety of methods for decontaminating soils, sediments and groundwater.

1.5 What clean up technologies are available?

Clean up technologies generally fall into two categories: those for treating groundwater and thosefor treating soils and sediments. Groundwater may be pumped out of the ground and treated in anabove-ground system (e.g., filtration and air stripping). An alternative approach involves building aninterceptor trench which treats the contaminants as they flow through it. For soils and sediments,generally the most contaminated areas are excavated and may be treated in some fashion to eliminate contaminants. Treatment may take many forms, ranging from a low energy process likelandfarming, which uses microorganisms to break down organic compounds, to incineration. Soils atthe LCP Bridge St. site were treated using a soil washing process to separate out liquid mercury.

1.6 How is a clean up plan developed?

While the Superfund remediation process (see text box on page 4) appears logical andstraightforward, it rarely works out that way. Investigation of the site, especially a large onelike Onondaga Lake, can be very complex and time consuming. Multiple sources of a variety ofcontaminants such as mercury, PCBs, dioxins, and chlorinated benzenes adds to the complexity.Data is often collected, reviewed and analyzed in stages. Final decisions may be re-worked as newinformation becomes available. Fifteen years have elapsed since the lake was put on the NPL.

In the Feasibility Study (FS), remedial alternatives (i.e. “clean up” options) are evaluated side by side.The alternatives typically range from “No Action” (used as a point of reference) to “dig everything upand bury it somewhere else” (no official acronym available). As you can imagine, costs range widely,from zero to hundreds of millions of dollars. Generally, the regulatory agencies that make the finaldecision regarding clean up (see “ROD”) select something in the middle. It is inevitably a trade offbetween protecting the economic interests of the polluters and protecting the health, economicinterests and environment of the community. Costs for remediating just the sediments of OnondagaLake are projected to be $450 million.

The various steps of the Superfund site clean-up process are described below. Note that the PRAPis the only step where the NYSDEC is required to hold a public comment period. You can, however,comment on any aspect of the process along the way. This helps to determine how well (or poorly) the remediation process is carried out.

1.7 How long will clean up take?

Superfund clean ups move at a pace best described as “glacial.” It is not unusual for the whole process

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SUPERFUND SITE

REMEDIATION PROCESS

(1)Preliminary Site Assessment (PSA)

(2) Negotiate Administrative Orders on Consent with Potentially Responsible Parties (PRPs)

--------------------------------------------------(3a) Remedial Investigation (RI)

(3b) Feasibility Study (FS)

(3c) Human Health Risk Assessment (HHRA)

(3d) Ecological Risk Assessment (ERA)--------------------------------------------------

(4) Implement “Interim Remedial Measures” (IRMs) if needed

--------------------------------------------------(5) Divide site into “Operable Units” if needed

(6) Preferred Remedial Action Plan(PRAP)

(7) Record of Decision (ROD)--------------------------------------------------

(8) Remedial Design (RD)

(9) Remedial Action (RA)--------------------------------------------------

(10) Site Review every 5 years

(11) Site De-listing

*Steps in the Superfund Process are not necessarily con-ducted sequentially but may be implemented concurrently. Step (4) may be implemented at any point in the process.

(1-2) Initial Steps:initial site investigation•legal process•not open to public•

(3) Detailed Site Assessment:PRP(s) hire consultants•technical evaluation of contamination•voluminous reports•open to public via reports & Fact Sheets•

(4) Agencies & PRP(s) decide whether immediate action required

(5-7) Agencies propose/select course of action

public input is solicited, for review and •comment on PRAP, with public meeting.public, local government, other PRPs •may comment agencies respond to comments and •make “final” decision in ROD

(8-9) Agencies & PRP design the clean-up “remedy”

public input may be solicited for •Remedial Design

(10-11) Final StepsSites with contamination remaining •after clean-up must be re-visited every five yearsSites that are de-contaminated may be •removed from Superfund list (NPL).

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to take in excess of ten years, especially for large sites. Regulatory agencies - not known forrapid, decisive action - must continuously negotiate with the PRP(s) on any number of technical,administrative and legal issues regarding investigation and possible remediation strategies for eachpart of the site; since the Onondaga Lake Superfund Site consists of many subsites, negotiating hasbeen particularly time consuming.

Initially, the pace of work toward remediation in and around Onondaga Lake was quite encouraging.New York State sued Allied-Signal and LCP in 1989 for pollution in Onondaga Lake. By the end of1992, a $7 million investigation of the lake had been completed. In 1994, the lake officially becamea Superfund site. Since then, the pace has slowed. Further investigations of the lake were performedin 2000. A conceptual remediation plan was issued in late 2004. Actual dredging and capping ofsediments is not anticipated to begin until 2012.

This is not to say that nothing has been accomplished. In 1996, ten wells were installed to intercepta plume of chlorobenzene which was migrating into the lake along Interstate 690 (this is known asan Interim Remedial Measure, or “IRM”). Another IRM is the temporary cap placed on top of the TarBeds in 1995. The LCP site has been largely contained. The West Flume, a major source of mercury, hasbeen cleaned up. Honeywell is currently installing a barrier wall along the southwestern edgeof the lake.

1.8 How can the public participate?

You can comment on any aspect of the process and at any point in the process. However, in order tobe most effective, you should direct your comments to elected officials at the local, state, or federallevel. For more information on how to get involved, see the New York State DEC’s website: http://www.dec.ny.gov/chemical/37558.html. Honeywell International has also established an informativewebsite at http://www.onondaga-lake-initiatives.com. Atlantic States Legal Foundation postsOnondaga Lake Superfund site information at www.onondagalake.org.

A Community Participation Working Group (CPWG) has been established by the NYSDEC to helpthe public get information and provide feedback to decision-makers at the state and federal levels.Contact NYSDEC Region 7 (315-426-7403) or via e-mail to reg7info@gw.dec.state.ny.us to learn aboutparticipating in the CPWG.

The official opportunity for public comment is the “Proposed Remedial Action Plan” (PRAP) in whichthe regulatory agency presents its recommendation for the action to be taken at an individualsubsite. The public can submit written comments and/or present oral testimony at a public hearing.Regulatory agencies (USEPA and NYSDEC) must take public comments into account when makinga final decision. Minor adjustments may be made, but regulators rarely make major changes inresponse to comments on the PRAP.

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Part Two Onondaga Lake Superfund Site

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2.1 Background

Onondaga Lake, located in metropolitan Syracuse, NY, is a relatively small lake, approximately 4.5 miles long and 1 mile wide, with a mean depth of approximately 38 feet and a maximum depth of approximately 68 feet. Several tributaries flow into the lake, including Onondaga, Ninemile, and Ley Creeks. The Lake drains northerly to the Seneca River which combines with the Oneida River to form the Oswego River, and which in turn empties into Lake Ontario. For many centuries, the lake was home to the Onondaga Nation, one of the six members of the Haudenosaunee (Iroquois) Confederacy. The Lake has great spiritual significance to the Onondagas and other Haudenosaunee.

Today, Onondaga Lake is bordered on its southeastern shore by the city of Syracuse, on its easternshore by the suburban village of Liverpool and town of Salina, and on its western shore by thetown of Geddes. In the 19th century, salt springs of the lake created a booming salt mining industrythat was responsible for the rapid population and economic growth of Syracuse. In the late 1800s andearly 1900s Onondaga Lake supported both thriving recreational resort and commercial fishing industries. From the late 1800s to the present, however, Onondaga Lake has been a receptacle for large quantities of industrial and municipal wastes.

Figure 1. Aerial photograph, circa 1960s, shows most of the “Syracuse Works” in Solvay, NY. The reservoir in the foreground held brine mined from the Tully Valley, south of Syracuse. The village of Solvay lies to

the left, and Solvay wastebeds 7-8 in the upper right. The Main Plant is in the center of the photo. The NYS Fairgrounds

and Solvay wastebeds 9-11 lie behind it. Photo courtesy of Solvay Public Library

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The Solvay Process Company began operations on the shores of Onondaga Lake in 1884. It usedthe ammonia soda “Solvay” process to produce soda ash, a product used in a variety of applications,including the manufacture of industrial chemicals and glass. This and three other chemical firmsmerged to become the Allied Chemical & Dye Co. on December 17, 1920. This company shortened itsname to Allied Chemical Corp. in 1958 and to Allied Corp. in 1981. In 1985 Allied merged with SignalInc., forming Allied-Signal, which in 1999 merged with Honeywell; the resulting company is known asHoneywell International Inc. Honeywell and its predecessor companies will be referred to as Allied/Honeywell in this publication.Allied/Honeywell operated at four main locations throughout the 102-year existence of the “SyracuseWorks .”

Allied/Honeywell plant site Major Products/Operations Years

1. Main Plantsoda ash, related products 1884 – 1986

benzene, toluene, xylenes, and naphthalene 1917 – 1970coal-fired power plant 1884 – 1986

2. the Willis Avenue plantchlor-alkali products 1918 – 1977

chlorinated benzenes 1918 – 19773. Semet-Solvay-Barrett Div. coal-derived paving material 1919 – 1983 1

4. Bridge Street plantchlor-alkali products 1953 – 1979 2

hydrogen peroxide 1956 – 1969

2.2 Sources of Pollution

There were two major sources of industrial pollution from the Allied/Honeywell Syracuse Works:the East Flume, which led to an 84-acre deposit of contaminated waste known as the “In-Lake WasteDeposit”, and Geddes Brook / Ninemile Creek, which combined overflow from the Solvay waste bedsand effluent from the LCP Bridge Street Plant to form another large deposit of material at the mouth ofNinemile Creek. Both deposits are contaminated with mercury and chlorinated benzenes. The In-LakeWaste Deposit - consisting of over 4,000,000 cubic yards of Solvay Waste - is also contaminated withBTEX, PCBs, dioxins/furans, other heavy metals, and polyaromatic hydrocarbons (esp. naphthalene).

Other sources of industrial pollution include Ley Creek, which has transported PCBs and otherpollutants from General Motors IFG facility, Carrier Corp., and other industries, as well as leakage fromthe Town of Salina Landfill.

Bloody Brook, in Liverpool, has apparently contributed cadmium, PCBs and other pollutants fromlocal industries, including the former General Electric facility at Electronics Park. The area immediatelysouth and east of Onondaga Lake, current home of the Carousel Center and a sewage treatment plant,was formerly occupied by dozens of petroleum and chemical storage tanks (“Oil City”) as well as scrapmetal yards, coal gasification facilities, and other sources of pollution to Onondaga Creek, which flows into Onondaga Lake.

Table 1. Allied/Honeywell Plant and Major Products

1 This operation was sold to Penn-Can Corporation in 1983, which continues to operate at this site. 2 The Bridge Street plant was sold to LCP in 1979, which operated it until it was shut down in 1988.

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Industrial contamination of the lake has been compounded by municipal pollution from the Metro sewage treatment plant, which overwhelmed the lake with excess ammonia (toxic to fish) and phosphorus. The phosphous led to rampant algae growth, causing an unpleasant odor and appearance as well as depriving the lake waters of oxygen. Water quality in the lake has greatly improved as a direct result of major upgrades to the treatment processes at the Metro facility.Ammonia and phosphorus levels are now incompliance with court-mandated target concentrations.

2.3 Major Contaminants The major contaminants found in Onondaga Lake are listed in Tables 2 and 3. Known and suspected sources are listed as well. The major problems caused by these chemicals are (1) bio-accumulation in fish, making them unsafe to eat, and (2) being toxic to bottom-dwelling organisms (benthos).

2.4 Environmental Degradation

The New York State DEC has determined that contamination in the lake presents risks to many species in the Onondaga Lake ecosystem, including plants, invertebrates, amphibians, fish, birds, andmammals. Chemical contamination of the sediments is severe enough to be highly toxic to benthic(bottom-dwelling) organisms; it is suspected that this contamination has reduced the localfrog population. In addition to chemical toxicity, both plant and animal life has been greatly affected by a loss of habitat through the filling in of wetlands with Solvay waste and other materials, the deposition of huge quantities of calcium carbonate on the bottom of Onondaga Lake, and general urban, suburban, and industrial development. These issues are discussed in detail in the Baseline Ecological Risk Assessment (TAMS and NYSDEC, 2002).

2.5 Human Health Risks

The major health risks associated with Onondaga Lake itself (not including upland sub-sites) are due to fish consumption and direct contact with some of the sediments and soils near the lake; contact with the waters of Onondaga Lake poses little to no risk.

Table 2. Inorganic Contaminants (metals) in the sediments of Onondaga Lake

* Major known and suspected sources are listed. ** Benthos = small creatures, like crayfish, which live in the sediments of lakes.Abbreviations: GM = General Motors Inland Fisher Guide plant; GE = General Electric (Electronics Park, other locations)

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A Human Health Risk Assessment published by NYSDEC in 2002 revealed that exposure to wetland soils and lake sediments can lead to unacceptably high cancer risks: sediments are contaminated with polychlorinated biphenyls (PCBs); pesticides; creosotes; heavy metals, including lead, cobalt, cadmium, and mercury; polycyclic aromatic hydrocarbons; and volatile organic compounds such as chlorobenzene, benzene, and toluene. In addition, consumption of fish posed unacceptable cancer and non-cancer risks. Non-cancer risks arise from mercury, which is a neurotoxin, and PCBs.

2.5.1 Mercury in Onondaga Lake Fish

A ban was placed on public fishing from the lake in 1970 due to high concentrations of mercury in several species of fish. The lake was re-opened to fishing in 1986 on a catch and release basis only. Currently the New York State Department of Health advises men to limit consumption of certain species of fish from the lake and its tributaries while women1 and children are advised not to consume any fish at all. These advisories are based on high concentrations of mercury, chlorinated dioxins/1 “of child-bearing age.”

Table 3. Organic Contaminants in the sediments of Onondaga Lake.

* & ** See notes in Table 2

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furans, and PCBs found in the fish.2

Figure 2 shows mercury concentrations in a sportfish (s.m. bass) over the period 1981 to 2005. For reference, the graph shows a guideline set by the U.S. Food & Drug Administration (FDA) for commercial fish. The 1-ppm guideline was set in 1979, and has remained unchanged ever since. The USEPA’s Office of Science and Technology established a guideline (also shown) of 0.3 ppm based on eating one meal per week. Health Canada’s guideline is 0.5 ppm. In any case, two things are clear: (1) A large fraction of smallmouth bass caught in Onondaga Lake are above all of the guidelines. In 15 of the 24 years shown at least 50% of the fish were above the FDA guideline. In nearly all years, all of the fish are above the USEPA guideline. During several years (1987, 1989, 1999 and 2005), the majority of fish exceeded 1.5 ppm, which is 5 times the USEPA target value. (2) the concentration of mercury is not decreasing. Recent years have even seen an increase, despite reductions in the amount of mercury entering the lake. The recent upward trend in mercury in fish remains unexplained.

A major goal of the remedial actions being undertaken in Onondaga Lake is to reduce the level of mercury contamination in the lake’s fish. It is uncertain that this goal can be achieved.

2 Other chemicals, such as hexachlorobenzene and pesticides, contribute to the overall risk, but to a much lesser degree.

Figure 2. 24 years’ worth of mercury data for smallmouth bass caught in Onondaga Lake (1981-2005). The red line shows the median mercury concentration in fish fillets: half of the fish had greater mercury values,

and half had smaller mercury values. (Typically, 40-50 fishes are caught and tested each year.)

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Figure 3: Contaminated sites in the vicinity of Onondaga Lake. - refer to the Onondaga Lake Superfund subsites. - refer to other contaminated sites regulated by New York State.A1 10

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Onondaga Lake Bottom--Sediments

Geddes Brook/Ninemile Creek

LCP Bridge Street Facility

Semet Residue Ponds (Tar Beds)

Willis Avenue Facility

Harbor Brook/Wastebed B

Salina Town Landfill

GM Inland Fisher Guide (IFG) Plant

Ley Creek PCB Dredgings

Lower Ley Creek

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Solvay Waste Beds 1-8 (State Fair Parking)

Solvay Waste Beds 9-11

Solvay Waste Beds 12-15

Crucible Steel Landfill

Maestri Property No. 2

Matthews Ave. Landfill sites

American Bag & Metal

Niagara Mohawk Manufactured Gas Plant (MGP)

-1 Former MGP at 300 Erie Blvd. W

-2 Former MGP at 600 Hiawatha Blvd

Syracuse China Landfill

West Branch Bloody Brook

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2.6 Onondaga Lake Superfund Subsites The Onondaga Lake Superfund site (EPA ID: NYD986913580) includes the Lake itself, seven major and other minor tributaries, and upland sources of contamination to the Lake (sub-sites). Many of the upland sources are also on New York State’s list of Inactive Hazardous Waste Sites.

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Onondaga Lake Bottom--Sediments

A large portion of the lake bottom is covered with •calcium deposits from Allied Chemical’s Solvay Process (1884-1986). A four-million-cubic-yard deposit (the “In-lake •Waste Deposit”) is located in the SW corner of the lake. This deposit has highest concentrations of mercury, chlorinated benzenes, chlorinateddioxins and furans, benzene and PAHs.•The sediments throughout the lake are •contaminated with mercury and other heavy metals, and PCBs, petroleums and other organic pollutants. Remedial efforts --- see • Section 2.8

Geddes Brook / Ninemile Creek

The single largest external source of mercury to the •lake, receiving contaminants from the LCP site via Geddes Brook and West Flume, and from Solvay wastebeds. Primary contaminants: Mercury and other heavy •metals, hexachlorobenzene, and chlorinated dioxins/furans.Remedial efforts: dredge and remove about •117,000 cubic yards of contaminated channel sediments and floodplain soils from over 30 acres along the streams, and restore habitats following sediment and soil removal.

LCP Bridge Street Facility

Site of former chemical plants which manufactured •chlorine, caustic soda, and hydrogen peroxide (1953-1988).Primary contaminants: pure liquid mercury and •PCBs in both soil and groundwaterOver eight tons of mercury were removed through •a soil washing process in 2005, and a 50-ft deep barrier wall and cap were installed to contain the tons of mercury that remain in soils on site. In addition, mercury-contaminated sediments were dredged from the West Flume and buried at the •LCP site.

Figure 4. Biologists Collect Samples from Onondaga Lake. Courtesy of Dennis Nett /

The Post-Standard

Figure 5. Ninemile Creek West to I-690(The foreground is the base of a Wastebed)

Figure 6. LCP Bridge Street Facility

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Semet Residue Ponds (Tar Beds)

A 22-acre site used for disposal of about 80 •million gallons of acidic tarry wastes from former Allied Chemical benzol production plant, in operation from 1917 to 1970.Primary contaminants include benzene, •toluene, xylene, diphenyl ethanes, and naphthalene, in the waste itself and in groundwater.An early plan would have converted the waste •into driveway sealer. Final plans are hampered by the stickiness and toxicity of the waste.

Willis Avenue Facility

Site of former chemical plants 1918-1977; used to produce chlorinated benzenes, chlorine gas and •caustic soda. Primary contaminants include benzene, toluene, xylene, mercury, chlorinated benzenes, •naphthalene and chlorinated dioxins/furans in soils and groundwater. The groundwater is caustic (pH > 11).A barrier wall is being constructed along the southwest shore of Onondaga Lake to prevent •contaminants from continuing to migrate into the lake from the site and Semet Ponds.

Wastebed B / Harbor Brook

This site comprises the mouth of Harbor Brook •and a former Solvay waste bed located west of the brook Soils, sediments and groundwater are heavily •contaminated with benzene, toluene, xylene, mercury, chlorinated benzenes, naphthalene (and other PAHs) and chlorinated dioxins/furans.A barrier wall is being installed to intercept •a plume of contaminated groundwater and a dense layer of chlorinated benzenes. The groundwater will be treated, while the chlorinated benzenes will likely be shipped offsite. No final remediation plans have been proposed.

Town of Salina Landfill

The former municipal landfill is situated in a flood-prone wetland, on both sides of Ley Creek. •During its operation (1950s to late 1970s), domestic, commercial and industrial wastes were

Figure 7. Semet Residue Ponds and Willis Avenue Subsites

Figure 8. Mouth of Harbor Brook to Onondaga Lake

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landfilled there. A partial soil cover was placed over the site in late 1982.Contaminants: PCBs, heavy metals, chlorinated •solvents and PAHs.The remedial plans for this site call for installation •of a multi-layer cap, leachate collection and on-site treatment of the leachate.

General Motors IFG Facility / Ley Creek Sediments

Automobile manufacturing facility which utilized •polychlorinated biphenyl (PCB) oil, chlorinated solvents, and paints. Closed in November 1993.Contaminants: PCB-containing hydraulic oils; •waste solvents (e.g. trichloroethylene), and paint sludge (xylenes, copper)An RI / FS (Remedial Investigation / Feasibility •Study) is underway. Three major IRMs were completed in 2006, including a landfill cap, a soil removal IRM and a SPDES Treatment IRM. PCB-contaminated sediments in upper Ley Creek will also be remediated with this site.

Ley Creek PCB Dredgings

Site of over 4000 feet of dredged sediments piled along the banks of Ley Creek, downstream of •Townline Rd.Contaminants: PCB-contaminated sediments•Sediments containing >50 ppm PCBs were removed to a hazardous waste landfill. Remaining •contaminated sediments were graded and covered with clean soil (1999-2001). This site is currently in an operation and maintenance phase.

Lower Ley Creek Sediments

This site was named in 2009 by USEPA. It will be addressed using a fund created when General •Motors went into bankruptcy.The site includes the Ley Creek channel downstream of Route 11 (Wolf St.). Sediments are •contaminated with high levels of PCBs as well as polycyclic aromatic hydrocarbons (PAHs) and heavy metals.

Figure 10. Map showing GM’s subsite, including the IFG facility and upper Ley Creek sediments,

and Ley Creek PCB Dredgings subsite

Figure 9. Town of Salina Landfill and Lower Ley Creek Sediment Subsites

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2.7 NY State Regulated Superfund Sites around Onondaga Lake Please refer to Figure 3 for the location of these sites.

Solvay Waste Beds

-1• Waste Beds No. 1-8 (State Fair Parking) NYS Superfund site #734081 -2 Waste Beds No. 9-11 (West of Ninemile Creek) NYS Superfund site #734076 -3 Waste Beds No. 12-15 (East of Ninemile Creek) NYS Superfund site #734076

Together, the Solvay wastebeds (originally “settling basins”) cover over 1000 acres of land on the •southwestern side of the lake. They were used for the disposal of Solvay process wastes from the 1920s to 1986. Other wastes containing mercury, chlorobenzenes, and Semet residue have been added as well. Waste beds have contributed large quantities of salts (sodium and calcium chlorides) to the lake system. The calcium inputs have reacted with naturally occurring carbonate to form a precipitate (calcite) which has coated much of the lake bottom, as well as Ninemile Creek.Contamination: • mercury, asbestos, lead, chlorinated benzenes. Some other wastes that were disposed included fly ash and bottom ash from the power plant, sewage sludge, brewery sludge, and brine purification mud.Remediation: • Honeywell is investigating the planting of willow trees to reduce the infiltration of rain/snowmelt into Wastebeds 9-12, 14 and 15. Wastebed 13 will be used for storing contaminated sediments dredged from Onondaga Lake. Wastebeds 1-8, which are adjacent to the lake, are under investigation largely due to hazardous wastes (Semet residue) which were buried there.

Crucible Steel Landfill NYS Superfund site # 734021

This 28-acre landfill, situated on the west end of Wastebeds 1- 8, is a state-approved disposal area •for steel-making wastes from Crucible Steel; namely chromium wastes and air pollution baghouse dust.Contamination:• chromiumRemediation: • A closure plan has been approved and the site has since been capped. The site is now under an operations and maintenance plan, and is inspected annually.

Maestri Property No. 2 NYS Superfund site # 34040

The site, a former sub-site of Onondaga Lake Superfund Site, includes a 4.5 acre dump adjacent to •a wetland. Caustic coated mill scale from the Crucible Steel facility and wastes from a nearby auto shop and dealership were disposed of in the past.Contamination:• The primary contaminants include chromium, barium, other heavy metals, and PCBs. Investigations have determined that contamination is present in site soils and in surface water and sediments in the adjacent wetland.Remediation: • In 2004, PCB-contaminated soil was removed as part of an Interim Remedial Measure (IRM). A Remedial Investigation and Feasibility Study (evaluation of clean-up options) was completed in 2008. New York State issued a Record of Decision (ROD) in March 2008 calling for

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excavation of wetland sediment, consolidation of fill material and soil cover over the fill area.

Matthews Ave. Landfill sites NYS Brownfield Cleanup Program sites C734116

Consists of two parcels, A (37 acres) and B (70 acres). Parcel A contains a former construction and •demoliton landfill located in the Village of Solvay while Parcel B contains the former Mathews Ave. Landfill, utilized by the Solvay Process Co. and Allied Chemical for the disposal of various process wastes and construction and demolition debris from 1925 until the late 1980s. The remainder of the site includes a drainage swale and a portion of the former Erie Canal to the north, and state-recognized wetlands.Contamination: • mercury and other metals, solvents, and PCBs in the landfill material, soils, sediments, surface water, and groundwater. Diaphragm cells (and possibly mercury cells) associated with Allied Chemical (now Honeywell) were observed in the landfill in Parcel B.Remediation: • The sites are still under investigation. A remedial action work plan has been submitted to NYSDEC.

American Bag & Metal NYS Brownfield Cleanup Program C734088

Site of a scrap metal business which began operations in 1965. It consists of 2 small parcels (2.7 •acres, total) straddling Onondaga Creek at Spencer Street in SyracuseContamination:• PCBs, chlorinated solvents, paint waste Status: • Between 2005 and 2006, PCBs and paint wastes were excavated and disposed off-site. PCB contamination still exists on the west bank of Onondaga Creek, and potentially on adjacent properties and in the creek sediments. Groundwater contamination persists.

Niagara Mohawk Manufactured Gas Plants (MGPs) Both facilities used coal to produce gas and oil for lighting and heating.

-1. Former MGP at 600 Hiawatha Blvd. NYS Superfund site # 734059This 23-acre site operated from 1924 to 1958.•Contamination: • coal tar residues, benzene compounds (BTEX), naphthalene and related compounds, and cyanide.Remediation:• Over 120,000 tons of contaminated soil was removed from this site in 2001-02, when a new treatment system was installed at the Metropolitan Sewage Plant. Soils containing coal tar, sheens and high PAH concentrations (>500 ppm) were excavated.

-2. former MGP at 300 Erie Blvd. W NYS Superfund site # 734060

The first MGP was constructed in 1849. The plant continued operating in various capacities until •the 1930s. Prior uses of the site include a salt mill, a saw mill, a linseed oil mill, and a tannery.Contamination: • tar residues (coal tar), benzene compounds (BTEX), PAHsInvestigations indicate a deep groundwater plume moving ~2,000 feet off-site, under Onondaga •Creek.Remediation:.• This 10-acre site is largely paved. No remedial actions have been undertaken.

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Syracuse China Landfill NYS Superfund Program #734053

This site is on the north side of the Syracuse China Plant, now closed. It includes a 13-acre landfill •and wastewater treatment lagoons. The landfill was operated by Syracuse China since 1940 for industrial waste. It was also used by local municipalities (city of Syracuse and towns of Salina and Dewitt), as well as the general public, to dump other waste materials.Contamination: • Major contaminants include chlorinated solvents and lead. Toxic levels of lead were found in soils/sediments throughout the site and in the groundwater. The solvents 1,1-dichloroethane and 1,1,1-trichloroethane were found in surface waters.Remediation: • Following completion of the RI / FS in March 1995, a Record of Decision (ROD) was issued. As per the ROD, lead-contaminated soils, sediments, and sludge were excavated and placed into the on-site landfill. Contaminated water and sediments were removed from the adjoining wetlands. Landfill closure (consolidation of wastes, followed by capping) began in May of 2000 and was completed in 2003. Currently, groundwater is monitored along the entire perimeter of the landfill. In the long-term, the landfill cap, perimeter fence, and wetlands must be monitored and maintained. Deed restrictions were placed on the property to keep people (esp. utility workers) from encountering the remaining contamination.

Bloody Brook in NYS Voluntary Cleanup Program

This small tributary of Onondaga Lake drains a commercial/industrial area (North of NYS Thruway) •and a residential area (S of NYS Thruway) in the Town of Salina.Contamination: • Sediments in both the Middle and West Branches are contaminated with PCBs, mercury, copper, cadmium, and PAHs. Floodplain soils along the West Branch are heavily contaminated with cadmium.Renediation: • Contaminated sediments were removed from 750 feet of the West Branch in 1997 by Lockheed-Martin. Selected culverts were cleaned in 2008. Lockheed-Martin has proposed removing approximately 40,000 tons of cadmium-contaminated soil from properties along the West Branch. This proposal is under review by NYSDEC.

2.8 The Remediation of the Onondaga Lake Sediments

After extensive public comment and internal review, a Record of Decision for the Onondaga Lake Bottom sub-site was issued by the NYSDEC and the EPA on July 1, 2005. The selected remedy includes:

(1) Littoral zone - nearshore areas (water depths up to 30 feet): Up to 2.65 million cubic yards of contaminated sediments are to be hydraulically dredged and disposed of in an area of Wastebed 13 designated as the Sediment Consolidation Area (SCA) (see Figure 11). An estimated 425 acres would be covered with a 4-ft thick “isolation cap” consisting of sand and topped with gravel. Much of this area would also be restored with native aquatic plants.

(2) profundal zone - central part of the lake (water depths exceeding 30 feet): thin layer capping of an estimated 154 acres. Most of the profundal zone will be left untouched, allowing clean sediments

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to cover over the contamination. This is called “monitored natural recovery.” The most highly contaminated sediments, a small fraction of the total, would likely be disposed of off-site. Wastewater generated by dredging/sediment handling processes as a result of dewatering of the sediments at the SCA would be treated prior to being discharged back to the lake. The estimated cost to implement the remedy is approximately $451 million, which includes $414 million to construct the remedy, and the average operation and maintenance cost of about $3 million per year for 30 years.

Recent findings by Honeywell have led to changes in the amount of dredging to take place in the southwest portion of the lake (SMU#2). The change is necessary to ensure the stability of the adjacent causeway and the adjacent area which includes a portion of I-690 and is supported by recent, more extensive sampling of the area which indicates that the pure chemical contamination is significantly less extensive than previously estimated. A Consent Decree related to the design and construction of the remedy by Honeywell, under New York State oversight, was entered in federal district court in January 2007. Pre-design related activities are currently underway.

Figure 11. Map of Onondaga Lake Sediment Management Units Showing Dredging & Capping Areas

Figure 12. Map showing placement of barrier wall, sediment pipeline, and SCA on Wastebed 13.

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Part ThreeSources of Information

There are very many documents that have been created regarding the pollution in Onondaga Lake, its tributaries, and many surrounding industrial sites. While much of the literature is rather technical and dry, there is also a veritable treasure trove of interesting maps, historical information, legal documents, and scientific data concerning pollution of the local environment, its ecology, and human health effects.

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3.1 Document Repositories for the Onondaga Lake Superfund Site

Documents about the Onondaga Lake Superfund site, including the nine sub-sites, may be found at three local repositories and a repository in Albany. These are listed below. There are additional locations which have publicly available documents about the lake itself, and selected sub-sites. These are listed under “Other Document Collections.” Internet resources are provided in the next section. Documents for the Onondaga Lake Superfund sites are available for public inspection at:

Atlantic States Legal Foundation• 658 West Onondaga Street, Syracuse NY 13204-3711Phone: 315-475-1170 Please call for an appointment http://www.aslf.org/ and www.onondagalake.orgOnondaga County Public Library, Central Branch at the Galleries • 447 South Salina Street, Syracuse, NY 13202 Hours: M, Th, Fri, Sat, 9:00 a.m. - 5:00 p.m.; Tu, W, 9:00 a.m. - 8:30 p.m.Phone: (315) 435-1800http://www.onlib.org/New York State Department of Environmental Conservation • 625 Broadway, Albany, NY 12233-7016 Hours: M - Fri, 8:30 a.m. - 4:45 p.m. Please call for an appointment Phone: (518) 402-9676http://www.dec.ny.gov/chemical/8668.htmlNew York State Department of Environmental Conservation, Region 7• 615 Erie Blvd. West, Syracuse, NY 13204-2400 Hours: M - Fri, 8:30 a.m. - 4:45 p.m. Please call for an appointment Phone: (315) 426-7400http://www.dec.ny.gov/about/615.htmlAdditional repositories for Onondaga Lake Superfund documents:•

Liverpool Public Library• , 310 Tulip Street, Liverpool, NY 13088Camillus Town Hall• , 4600 West Genesee Street, Room 100, Syracuse, NY 13219Moon Library• , SUNY ESF, 1 Forestry Drive, Syracuse, NY 13210Solvay Public Library• , 615 Woods Road, Solvay, NY 13209 (315) 468-2441

3.2 Useful Links for the Onondaga Lake Remediation

The following WEBSITES offer additional information about Onondaga Lake environmental remediation and monitoring.

Health effects of contaminants in the environment •(Agency for Toxic Substances and Disease Registry): www.atsdr.cdc.gov/substances/index.aspFederal Superfund program (USEPA):• www.epa.gov/superfund/index.htmOnondaga Lake remediation efforts:•

New York State DEC• : www.dec.ny.gov/chemical/8668.html

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US Environmental Protection Agency• : Site description: www.epa.gov/Region2/superfund/npl/0203382c.htm Progress report: http://cfpub.epa.gov/supercpad/cursites/csitinfo.cfm?id=0203382

Honeywell International Inc.• : www.onondaga-lake-initiatives.comLockheed Martin Corp• : www.lockheedmartin.com/aboutus/energy_environment/community_solutions/liverpool.html

Onondaga Lake and its tributaries:•Onondaga County, Dept. of Water Environment Protection• : www.ongov.net/wep/index.htmlOnondaga Nation• : www.onondaganation.org//land/olake.htmlOnondaga Lake Partnership• : www.onlakepartners.org/Neighbors of the Onondaga Nation• : www.peacecouncil.net/NOON/lake/index.htmlPartnership for Onondaga Creek• : www.onondagacreek.orgUpstate Freshwater Institute• : www.ourlake.orgSolvay Public Library• , Solvay Process Collection: www.solvaylibrary.org/Solvay Process/splsproom.htm

Atlantic States Legal Foundation, Inc.658 W. Onondaga StreetSyracuse NY 13204-3711Phone: 315-475-1170Fax: 315-475-6719www.aslf.org

This brochure was funded under the US Environmental Protection Agency’s TAG (Technical Assistance Grants) program.

Prepared by

Donald J. Hughes, Ph.D. Hughes Consulting Services

for