The Holy Trinity Cemetery site (EPA ID No. NYN000206698), hereinafter referred to as “the HTC site” or “the site”, consists of an area of radionuclide contamination located at Holy Trinity Cemetery in Lewiston, New York. The overall property is approximately 31.5 acres in size and is owned by Divine Mercy Roman Catholic Parish of Niagara Falls NY. The main area (Area 1) of observed contamination is 2.91 acres. Area 1 is located in the northwestern portion of the property on a relatively flat and slightly elevated grassy field, as well as on existing roadbeds. Another area of identified contamination is on the southeastern part of the property. This area is approximately 0.5 acres in size. There is one building on site, which is utilized both as a residence and cemetery maintenance facility. The HTC site is bordered: to the north and east by Interstate 190; to the south by the Gates of Heaven Cemetery; and to the west by Robert Avenue and a residential area.
In a 1978 U.S. Department of Energy aerial radiological survey, more than 15 properties throughout the region were identified as having elevated levels of radiation above background. It is believed that, in the early 1960s, slag from the local Union Carbide facility was used as fill on the properties prior to paving. The slag contained sufficient quantities of uranium and thorium to be classified as a licensable radioactive source material. Union Carbide subsequently obtained a license from the Atomic Energy Commission (now the Nuclear Regulatory Commission) and the State of New York; however, the slag had been used as fill throughout the Niagara Falls region prior to licensing. Based on the original survey and subsequent investigations, it is believed that the radioactive Union Carbide slag was deposited at the Holy Trinity Cemetery property.
In February 1980, the New York State Department of Health Bureau of Radiological Health and the Niagara County Health Department conducted a radiological survey of the HTC site to identify areas of elevated radioactivity as a result of radioactive slag having been used on the property for fill. The survey was conducted based on information that the slag used at the cemetery was from the same source used at two other locations in nearby Niagara Falls, which had been identified by the NYSDOH as containing elevated levels of radioactivity. During the survey, cemetery personnel showed NYSDOH a slag pile located near the caretaker’s garage in the western portion of the property. Cemetery personnel stated that this slag was used as fill for the cemetery roads throughout the property.
Additionally, the slag was used as fill for the base of two proposed roadbeds that extended approximately 500 to 600 feet from the caretaker’s garage northwest toward Robert Avenue. At the time of the survey, the construction of these roads had been abandoned. The underlying slag base was covered with an unknown amount of soil and was left as an open field.
In October 2006, the New York State Department of Environmental Conservation and the Niagara County Health Department conducted a site visit at HTC. At that time, the slag pile that previously had been observed near the caretaker’s garage was no longer on site; the current caretaker had neither knowledge of the slag pile, nor what happened to it. The caretaker also indicated that children living nearby use this area for recreation. Since the 1980 NYSDOH site investigation, trees had grown through the abandoned slag roadbeds, pushing the slag to the surface.
In May 2007, NYSDEC visited the site to identify contamination in an on-site debris pile using gamma-ray spectroscopy. A 5-minute static reading was taken; radium-226 was the only nuclide identified. An additional similar analysis was conducted on one of the roadbeds, confirming the presence of thorium-232.
During a reconnaissance performed by the NYSDOH and NYSDEC in July 2013, screening activities showed radiation levels at the HTC site along the roadway and along the back roadway leading to offsite with radiation levels up to 51 μR/hr in the roadway with the pressurized ion chamber (PIC) and up to 50,000 cpm with the sodium iodide (NaI) 2x2 detector.
The Holy Trinity Cemetery Site (Site) was referred to the EPA by the NYSDEC and NYSDOH on July 21, 2013. No other removal actions have been taken by other government or private parties prior to this request.
From December 2013 through May 2014, EPA Pre-Remedial conducted preliminary assessment at the Site. The program concluded that the Site did not meet the minimum criteria to be eligible for the inclusion on the EPA National Priorities List (NPL) for remediation. However, it was decided that there was a need for EPA to perform further assessment at the Site to determine if an action under the Removal Program is warranted.
On March 08, 2016, OSC Daly was assigned as the lead On-Scene Coordinator (OSC) for Holy Trinity Cemetery Site to conduct the Removal Site Evaluation.