The Niagara Falls Storage Site (NFSS) is located at 1397 Pletcher Road in Lewiston, NY. The 191-acre, Federally owned site is a remnant of a larger Lake Ontario Ordnance Works (LOOW) Site used by the wartime Manhattan Engineer District (MED). The NFSS and adjacent LOOW properties were developed for the production of trinitrotoluene (TNT) during World War II. However, TNT production never reached full capacity and the site became an interim storage facility, first receiving radioactive wastes and residues in 1944.
The NFSS was used by the Manhattan Engineer District (MED) to store radioactive residues and wastes from uranium ore processing conducted off-site. Radioactive wastes and residues continued to be brought to the site for storage until 1952.
In the 1950’s, drums of high- activity radioactive residues and waste from around the LOOW Developed Area were emptied into a vented Silo that subsequently emitted substantial radon into the community for some 30 years. It wasn’t until the early 1980’s, the Dept. of Energy transferred this waste to under-ground storage on the NFSS.
During remedial actions conducted by the U.S. Department of Energy from 1982 to 1986, approximately 240,000 cubic yards of residues and wastes were consolidated in a diked containment area known as the interim waste containment structure (IWCS). The 10-acre engineered IWCS is located in the southwest corner of the site. The IWCS consists of a WWII-era basement originally constructed to hold water for “containment” of radioactive residues from the former Silo. Drains, cracks and pipeline connections in this under-ground structure were plugged. An engineered clay cap was then added to the top and sides of this WWI-era structure, to retard radon emissions. There is no engineered clay beneath the IWCS.
Additionally, the Corps is responsible for environmental investigation and response at three open vicinity properties, designated as Vicinity Property E, E’ and G on an adjacent private parcel owned by CWM Chemical Services, LLC. These open vicinity properties were impacted by the MED and the Atomic Energy Commission; however, not all portions of the properties were accessible for investigation by the U.S. Department of Energy during the 1980s.
Interim remedial actions also attempted to address on-site and off-site drainage areas such as 4-Mile and 6-Mile Creeks, which had been contaminated from migration of radioactive materials.
Adequacy of NFSS Reports and data from the Army Corps, Project Status Investigations (Used as the basis to evaluate risk)
On December 14, 2007, the Corps of Engineers issued a comprehensive Remedial Investigation Report for the Niagara Falls Storage Site, to communicate the nature and extent of FUSRAP-related radioactive and chemical contamination on the site. This Remedial Investigation report issued by the Army Corps concluded there were no imminent hazards to safety or health from radiological or chemical exposure within the site or to a member of the public outside the site. However, agencies and members of the public disagreed with the adequacy of the investigation. As a result, the Corps conducted another investigation and issued the Remedial Investigation Report “Addendum” in April of 2011. Again, agencies and members of the public identified gaps and concerns about the adequacy of this report. As a result, the Corps created a third investigation, called the “Balance of Plant” investigation which will be concluded in 2012 as part of another step in the decision-making process; the issuance of a Feasibility Study.
The Corps did not make any of the Sampling and Analysis Plans available for public or RAB input in advance of conducting the three investigations noted above. The Corps supplied a substantial portion of the laboratory data for evaluation and comparison to its published data for the Remedial Investigation Report. However, to date, the Corps has declined public requests for the raw laboratory data from the Remedial Investigation Report Addendum.
Analysis of Potential Remedies (for problems identified in investigations, above)
The Corps of Engineers is working on a Feasibility Study for the IWCS which will identify, define the scope, and evaluate selected long-term remedies to address the FUSRAP contamination in the IWCS. The Feasibility Study for the IWCS is currently scheduled for completion in 2013. Two more Feasibility Studies, one for site soils and infrastructure, and another for groundwater, will follow the current Feasibility Study for the IWCS.
The NFSS is partially evaluated with chemical and radiation sampling, with results reported in an annual environmental surveillance report which is posted at www.lrb.usace.army.mil/fusrap/nfss/index.htm#EnvSurv. These evaluations are used to assess the protectiveness of the containment structure. This environmental surveillance program begun in the early 1980’s was substantially cut back for about 25 years. Many groundwater wells were taken out of service, making the identification of potential migration from the IWCS more difficult to detect.
The Corps’ environmental surveillance program for the site was improved in 2008 and 2010 by adding additional sampling points and parameters. However, compared to the surveillance program cut back in the early 1980’s, less data is available to construct a trend analysis for the presence of NFSS contaminants in area groundwater.
The NFSS continues to be maintained (mowing, plowing, etc.) to help prevent cracks in the IWCS that is intended to retard radon emission and to resist infiltration of rainwater and snowmelt. Historical data identified by RAB members indicates that infiltration, and therefore, leakage has likely occurred. The Corps disagrees. Gaps in historical surveillance impedes the identification of contamination from leakage, as opposed to residual groundwater contamination missed in prior clean-up attempts.