The Site is located in Marshall County, West Virginia, approximately three miles south of Moundsville. The 382-acre Site contains a former chlor-alkali manufacturing facility that released various contaminants, most notably mercury, into on-site floodplain soils, wetlands, and the adjacent Ohio River. Beginning in 1987, the Site was under investigation under the Resource Conservation and Recovery Act (“RCRA”). On June 22, 1999, the Site was listed in the National Priority List (“NPL”) under the CERCLA. Releases of hazardous substances have impacted surface soils, subsurface soils, surface water, groundwater and floodplains on the Site. Numerous natural resources under our jurisdiction in the Ohio River and on its floodplain have likely been affected by the releases of hazardous substances from the Site. Natural resources include the groundwater, surface water, sediment, biological resources of the Ohio River that provide habitat for fish and wildlife species, and two islands within the Ohio River Islands NWR. Honeywell is drafting the remedial design for OU1 - the upland portion of the site. The TC considered but rejected proposing an early restoration project for the upland area. Honeywell does not agree that any site-specific biological data are warranted for the river ERA or NRDAR. EPA found the SLERA for the river (OU2) to be inadequate and an EPA contractor is completing the necessary sampling to evaluate ecological risk in the river. Soil data from Captina Island, a FWS refuge island, located downstream from the Site was collected during the summer of 2022 and data indicates ecological risk to small mammals and bird associated with mercury. Field studies were conducted during the spring/summer of 2023 to determine mercury contamination of biota within the river. Analysis began in FY2024 on the mercury concentrations measured in periphyton and freshwater mussels from the 2023 studies. Additional dragonfly larvae and snail samples have been collected and sent in for mercury analyses during the FY2024. Combined results will be used to track mercury exposure and methylation critical to injury determination within the Ohio River. Given Honeywell's position on the river and Captina soil data, the TC decided that a collective case for both OUs was the more likely to yield a settlement that included injury to all biota. The Assessment Plan is being drafted and will encompass terrestrial and aquatic resources.