The Community LOOW Project
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The Community LOOW Project: A Review of Environmental Investigations and Remediation at the Former Lake Ontario Ordnance Works Report prepared for: The Community LOOW Project Niagara County Department of Health 5467 Upper Mountain View Road, Lockport, NY by King Groundwater Science, Inc. Buffalo, NY September 2008 Community LOOW Project EXECUTIVE SUMMARY The Project This report presents the results of the Community LOOW Project (CLP). The CLP was a community sponsored effort to critically evaluate the environmental condition of the former Lake Ontario Ordnance Works (LOOW) property in Niagara County. The former LOOW is a 7,500 acre area within the Towns of Porter and Lewiston, approximately 3 miles from Lake Ontario and 2 miles from the Niagara River. Initially developed to manufacture TNT for the World War II war effort, the central portion of the area was subsequently used for a number of Department of Defense and Atomic Energy Commission projects. This varied history has led to the current situation where environmental contamination remains. Investigations and remedial planning are underway in some areas, led by the U.S. Army Corps of Engineers (USACE). Currently, the area consists of property owned by federal and local governments, active waste disposal operations, commercial businesses, private homeowners, and recreational or cultural activities. A hazardous waste disposal operation (CWM Chemical Services, LLC), a municipal solid waste landfill (Modern Corporation) and a radioactive waste containment facility (Niagara Falls Storage Site) occupy neighboring properties in the central portion of the LOOW. The project was initiated during 2005 by the Niagara County Department of Health (NCDOH). A unique collaboration of local, state and federal officials funded this project with the purposes of evaluating the environmental status of the LOOW and to create a Geographic Information System (GIS) database of the environmental data. The goal was to examine the available information and to identify data gaps in past investigation and remediation activity. No new data was collected for this project. Documents were reviewed to gain an understanding of past work and to determine which information might be useful to include in the GIS mapping system. There were three main components of the project: • To identify and compile relevant data from past LOOW historic activity, investigations and clean-ups into a Geographic Information System (GIS) database • To perform a “Gap Analysis” of the LOOW data, and involve independent expert review of the work. • To identify and recommend solutions to the lead agencies, which are the U.S. Army Corps of Engineers, NYS Department of Environmental Conservation and NYS Department of Health. Over the course of the project four public meetings were held to transfer information and provide opportunities for people to comment or discuss the issues. An internet-based GIS was developed to enable public access to LOOW data. The site can be accessed at the internet site www.communityloowproject.com. The ii Community LOOW Project LOOW GIS Mapping website enables users to view geographic information about the LOOW and surrounding area, visualize the data locations of recent environmental studies and perform queries of the database. Findings The relationship between those responsible for investigations and remediation, and the surrounding community is important in conveying information and ensuring a successful resolution of LOOW-related concerns. A general lack of trust has existed between some members of the community and those in government charged with overseeing monitoring, investigation and clean up. Sharing of information and input to decision making appear to be stumbling blocks. There has been a multi-year delay in publishing the NFSS Remedial Investigation report since the time the data was collected. Resources need to be available to complete the Formerly Used Site Remedial Action Program (FUSRAP) and Defense Environmental Restoration Program for Formerly Used Sites (DERP- FUDS) investigations, so that fundamental information is available to the community for decision-making in a timely manner. As a result of the separate and distinct purposes and regulatory requirements, it appears that there is also fragmented jurisdictional oversight. The issues in play include delegation to USACE from DOE for radiologic and chemical investigations under the FUSRAP; USACE investigation of past DOD sites under the DERP-FUDS program; involvement of multiple branches and offices of NYS DEC (headquarters in Albany and Region 9 in Buffalo) concerning regulation of air, solid waste, hazardous waste, surface water, and wildlife; separate regulation of radiologic and drinking water quality issues by different parts of NYSDOH; and occasional limited involvement by USEPA. The responsibility for the approval process for USACE activity on the LOOW and identification of “who is the regulator?” needs to be better explained to the public. Long term safety of the waste sites (including the NFSS, Modern Landfill, CWM and legacy materials) and offsite migration is of concern. Therefore, the adequacy of monitoring programs to detect contaminant transport in potential offsite pathways is important. Potential offsite migration of contamination could likely occur via four pathways: surface water drainage, groundwater migration, air, and sediment transport. Offsite migration of contaminated sediment and surface water occurred during past operations on LOOW. Each landfill has monitoring requirements which reflect their waste activities, but there does not appear to have been a unified attempt to include radiologic or common contaminants related to the shared historical use of portions of all three landfill properties. Three other properties totaling nearly 1,000 acres are not within the USACE authority to investigate at the present time and they have been addressed under another program: the DERP Installation Restoration iii Community LOOW Project Program (IRP). These properties contain the former TNT storage igloos north of Balmer Road , the former Air Force Plant 38, which is now occupied by the NYS Army National Guard Weekend Training Site (WETS), a small parcel transferred to the Town of Porter, and the launch area of the former NIKE missile base at the corner of Balmer and Center-Porter Road. Although these properties have been subject to some previous environmental investigation by their respective Department of Defense site owners, there does not appear to have been coordination in approach, methodology, or data quality objectives comparable to the USACE FUSRAP or DERP-FUDS investigations elsewhere on the LOOW. At the WETS, there have been no groundwater investigations on the property, the thoroughness of the historical review for AFP 38 was insufficient to fully describe site activities, and the number of samples collected is not sufficient to be confident that all potential sources of contamination have been identified. We found no information concerning the environmental status of the Town of Porter property. The former NIKE base has been characterized and found to have few environmental problems. There was, however, no testing for hydrazine or missile fuel in the fueling area and the composition of the waste dumps represents an unknown risk. This property was recently sold to a private party. South of Balmer Road at CWM, concern exists that previous remediation of radiologic contaminants was insufficient and that site development has disturbed soil on the property. DOD related contamination is present, has and is being investigated; however some areas have been awaiting remediation for more than 10 years. Despite several surveys and decontamination efforts, the location of buried radioactive waste associated with the Rochester Burial area (located on CWM) may be in a different location than previously investigated (Appendix G). The Occidental property, west of CWM, has had only limited investigation and a former storage/disposal area remains unexplained. The NFSS, south of CWM and west of Modern Landfill, has undergone an extensive remedial investigation which indicates that the site contains widespread contamination of surface soil and groundwater. Data gaps have been noted concerning characterization (e.g. geophysical surveys, West Ditch sampling, delineation of groundwater plumes), monitoring ( e.g. insufficient annual groundwater sampling, lack of air particulate monitoring), contaminant fate and transport, and coordination of groundwater level monitoring with neighboring properties. The Baseline Risk Assessment Report for the NFSS was not reviewed as part of the CLP. Modern Landfill is well monitored in accordance to its permit, but there has been a lack of radiological legacy contaminant monitoring. Construction activities involving pumping of groundwater should be coordinated iv Community LOOW Project with the NFSS to contemporaneously measure water levels. Soil screening for radiologic parameters during construction should also be implemented. The LewPort school campus has been evaluated for a number of environmental issues over the years. Remaining areas of concern are the 30 inch outfall pipeline from the former LOOW waste water treatment plant that crosses the campus and has never been evaluated for contaminated residue on the school property west of the Southwest Ditch. The Southwest Drainage Ditch has had insufficient sediment characterization for potential constituents from NFSS. Mounds in the wooded area