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Hazardous Waste Cleanup: Dunkirk Acquisition Corporation in Dunkirk, New York

On this page:

  • Cleanup Status
  • Site Description
  • Contaminants at this Facility
  • Site Responsibility

Cleanup Status 

The Phase II Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) report was submitted in October 2003. After the Phase II RFI report is approved, remediation of all solid waste management units and areas of concern is planned to be referred to the New York State Inactive Hazardous Waste Site program. This is due to a projected lack of funds in the Al Tech Trust Fund.

An interim corrective measure (ICM) is being implemented at the Lucas Avenue Plant West since the spring of 2002 to control off-site migration of contaminated groundwater. Universal has agreed to allow former RealCo to use its wastewater treatment plant to treat wastewater resulting from RealCo's corrective action activities. The condition of the Lucas Avenue Plant building, which has not been used for several years, is deteriorating and may require the implementation of an ICM to decontaminate and demolish the building. However, lack of funding at this time precludes any action. 

Site Description

The entire site occupies approximately 90 acres on Willowbrook Avenue in the City of Dunkirk. It has been in operation since 1908, and has changed owners and names several times during the years. Currently, production facilities owned by Universal Stainless Steel are located on 79 acres and the remaining 11 acres, which do not support manufacturing activities, are owned by RealCo Inc. All areas surrounding the facility are zoned residential, plus some light industrial usage to the west. RealCo is responsible for remediating its property under the Resource Conservation and Recovery Act (RCRA) Corrective Action Program, funded by responsible parties, including several former owners.

Historical operations at the facility included pickling, annealing, lime coating, lead and copper coating, cutting, drawing, degreasing, grinding, rolling, straightening, crucible and electric arc melting, coal gasification, and forging. Production processes resulted in a variety of wastes, including waste acids, spent pickle liquor, pickle rinse water, contact and non-contact cooling water, and oily wastes. 

Contaminants at this Facility

As required by state and federal hazardous waste regulations, CWM has investigated over 80 solid waste management units (SWMUs) and areas of concern at the Model City facility. Based upon the investigations, it has been determined that hazardous waste constituents have been released to the fill/soil and groundwater beneath the facility. Contaminants include volatile and semi-volatile organic compounds and polychlorinated biphenols (PCBs).

The most significant area of contamination is located in the Lagoons, West Drum and Process Areas. Evaluation of possible sources indicated that Lagoons 1, 2 and 5 and/or former tank and container storage areas in and adjacent to the process area were the principle source of the contamination. Other areas of contamination are related to past container and leachate handling practices and activities during the federal government's ownership of the property. None of the observed contamination has been attributed to releases from the operation of any of CWM's eleven hazardous waste landfills at the site.

Because of the long-term potential for off-site migration, the contaminated groundwater is the principle threat to human health and the environment at the CWM facility. However, groundwater contamination has not migrated off-site. Additionally, areas of significant groundwater contamination have had remedial measures installed. Monitoring of the remedial systems indicate that most of the contamination has been contained. Groundwater migration rates average four inches per year, limiting the further migration.

As part of the corrective measures study for this facility, a risk assessment was completed. The only significant potential exposure points would be direct contact with surface soils by on-site workers and construction workers; contact with subsurface soils by construction workers and contaminated site groundwater by construction workers. If personal protective equipment is used by current and future workers, these exposure pathways would be eliminated.

Additional information on the risk assessment can be found in the "Site-wide Corrective Measures Study, Model City TSD Facility, Rust Environment & Infrastructure, January 1995" at the New York State Department of Conservation office. 

Site Responsibility at this Facility

The corrective action program is regulated by the New York Department of Environmental Conservation (NYSDEC) under its 6 NYCRR Part 373 Permit No. 9-2911-00110/00015-0.

The facility currently has a 6 NYCRR part 373 (Final Status) operating and post-closure permit, which was originally issued in September 1989. The permit underwent a major modification on January 31, 2001, to incorporate the selection of final corrective measures to address the presence of contamination at the facility.