King Groundwater Science, Inc.

THE COMMUNITY LOOW PROJECT

A unique collaboration of local, state and federal officials has funded a project that will evaluate the environmental status and create a GIS database of environmental data for the former Lake Ontario Ordnance Works site in Niagara County, NY. Data will include results of investigations, cleanups, and monitoring done by government and private industry at a former WWII era explosives plant and Manhattan Project storage site. The goal is to identify data gaps, ensure accountability, and increase trust in the community that this site is safe.

Scott King is serving as Coordinator of the project, which is being administered by the Niagara County Department of Health.

A summary is shown below and further information can be found at the Niagara County Health website, the LOOW Restoration Advisory Board website, or the Buffalo District of the U.S. Army Corps of Engineers website.

This project is now scheduled for completion in 2008.

BACKGROUND

The former Lake Ontario Ordnance Works (LOOW) is located in western New York, within the Towns of Lewiston and Porter, 3 miles from Lake Ontario, 2 miles from the Niagara River, and one mile from all Lewiston and Porter, NY public schools. Niagara County population is 220,000.

In 1942, the U.S. Dept. of War purchased 7,500 acres from Niagara County residents to construct and operate a TNT production facility. After only 9 months of operation, TNT production was discontinued. In 1944, the Manhattan Engineering Division (Manhattan Project) began using part of the LOOW site for the storage of highly radioactive uranium and radium residues.

For several years, a 165-ft. high open-topped former water tower known as “the silo,” housed this high level radioactive material, exposing workers and presumably residents to a plume of radon gas. The tower was capped and later, this dangerous material was transferred to an “interim” underground storage site operated by the federal government called the Niagara Falls Storage Site (NFSS) in the early 1980’s.

A large portion of the LOOW property was used as a “buffer zone” to protect the public from the hazards of TNT production. From 1946-1948 the 5,000 acres of this undeveloped land was divided up and sold by the Federal government to the general public. There is concern that the undeveloped land may have been contaminated by past activities, and the area is undergoing further investigation. All Lewiston-Porter public schools are located in the formerly undeveloped zone, as well as numerous residences, agricultural and other commercial activities.

Within the “developed” area of the LOOW current activities include storage of radioactive waste at the Niagara Falls Storage site, solid waste landfilling by Modern Corporation, and hazardous waste treatment and disposal by CWM Chemical Services. Additional property was transferred to government agencies or sold to the public in the 1960’s. Activities at the former LOOW include:

	· TNT Manufacturing Plant
	· Northeast Chemical Warfare Depot
	· 1944-Present Manhattan Project /Atomic Energy Commission / NFSS radioactive storage
	· U.S. Air Force Plant 38
	· U.S. Air Force Plant 68
	· Navy Interim Pilot Production Plant
	· Boron-10 Production Plant
	· NIKE Missile Base NF-03 and NF-05
	· Ransomville Test Annex - USAF
	· 1966-Present Youngstown Test Annex -USAF
	· 1979-Present Army National Guard weekend Training Site
	· 1972-Present Chemtrol / SCA / CWM Chemical Services, LLC - Toxic waste disposal
	· 1983-Present Modern Landfill – municipal solid waste disposal

This varied history has led to a current situation which has multiple regulatory influences. In addition to the formerly used Department of Defense properties which are being evaluated under the DERP-FUDS program, there are large areas still actively owned by the Department of Defense which are not being investigated in the same manner. There are those areas (some overlapping) which were affected by radioactive materials which are being investigated under the FUSRAP program. Some areas investigated separately under DERP-FUDS and FUSRAP are also currently owned by private entities such as CWM and Modern which have their own individual and different state regulatory conditions. Thus, there is an obvious perceived shortcoming in the design of the environmental investigations as not all issues associated with a particular portion of the LOOW are examined. In particular, DERP-FUDS is restricted in not being able to test for radiologic contaminants and FUSRAP is only focused on past radiologic activities.

The timeline for further investigation and remediation of formerly used Department of Defense property contamination by the U.S. Army Corps of Engineers is anticipated to extend to 2016. Although the site’s complexity is recognized, the long period of time to deal with the issues is of concern to the community.

Niagara County has above-average rates of some cancer incidences compared to other parts of the state. Niagara County rates for cancer Incidence and Mortality, combined, exceed NYS averages for 19 of 24 cancers tracked, according to the NYS Dept of Health web site. The relation of activities at the LOOW and NFSS to these health issues as potential causes is not known, but it remains a concern and perceived issue to many citizens. Other initiatives beyond this project are being taken to address these concerns.

PROJECT SUMMARY

This project was initiated in response to concerns in the community related to perceived health risks from legacy or current activities, apparent fragmented jurisdictional issues concerning investigation and remediation, a legacy of mistrust with federal agencies, and potential conflicts of interest by some agencies that supervise activity at the LOOW site. In addition, the NYS Dept. of Health Environmental Radiation Protection Bureau in 2004 indicated apparent gaps in the adequacy of previous radiological remediation.

The Niagara County Department of Health (NCDOH) is administering the project and is generally viewed as independent by community groups who have asked that they lead this effort. In contrast to other agencies and counties, the position of NCDOH Director is not a political appointment. Also, NCDOH has no significant benefit or liability with respect to historical or current activities on the LOOW. The NYS Dept. of Environmental Conservation, the NYS Dept. of Health, the U.S. Environmental Protection Agency, the U.S. Dept of Defense and the U.S. Dept. of Energy (and U.S. Army Corps of Engineers as its agent) have differing obligations to LOOW property owners and, in some cases, are considered conflicted by the community. The NCDOH is committed to ensuring public safety and increasing trust in the restoration process through a comprehensive approach to the entire LOOW area.

Approach to Project

There are three main components of the project. These are:

	· Identify and compile relevant past LOOW historic activity, investigations and clean-ups into one Geographic Information System (GIS) database
	· Perform a “Gap Analysis” of LOOW work using GIS and other evaluations, and involving independent expert review of the work.
	· Collaboratively 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.

This is different from past initiatives since it is intended to be “blind” to jurisdictional limitations of agency programs, takes a site-wide approach and looks at the “big-picture” using an independent science team. There will be an important community participation component to this project through public meetings and website postings. It is anticipated that the project will require two years to complete its goals. A key aspect is to provide the community with an assessment that will be viewed as independent by the community.

This project is very unique in that a broad source of support has been obtained from local, county, state and federal governments, and a community foundation. This wide community support indicates the need and desire for this project.

Products

This project will result in the following tangible products:

	· An internet website available to the public and members of the community which describes project progress, contains LOOW information with results of assessments, and maps prepared during the work
	· A Geographic Information System that contains compiled and relevant environmental data for use in a global site-wide “Data Gap” analysis, and for presentations to the public, agencies and other stakeholders.
	· A final written report describing the results and activities of the project.

Results or Benefits Expected

Completion of this project will have the following expected benefits to the community:

	· Increased confidence and trust in the restoration process and ensure that concerns of community members will be addressed
	· Construction of a database and GIS tool that will enable evaluation of the entire LOOW area rather than the individual properties of current owners.
	· Identification of the significant data gaps which should be addressed during the remediation of the entire LOOW
	· Increased accountability of state and federal regulators
	· Improve overall risk management at the LOOW site and effectiveness of hundreds of millions of dollars being spent on LOOW investigations and remediation
	· Improve protection of valuable farmland and scenic areas of Niagara County near the LOOW for future growth and prosperity