Habitability of the Love Canal Area: An

Analysis of the Technical Basis for the

Decision on the Habitability of the

Emergency Declaration Area

June 1983

NTIS order #PB84-114917
Recommended Citation:

Habitability of the Love Canal Area: An Analysis of the Technical Basis for the Division

on the Habitability of the Energency Declaration Area-A Technical Memorandum

(Washington, D. C.: U.S. Congress, Office of Technology Assessment, OTA-TM-M-I3,

June 1983).

Library of Congress Catalog Card Number 83-600552

For sale by the Superintendent of Documents,

U.S. Government Printing Office, Washington, D.C. 20402
Foreword

In December 1982, OTA was requested by Senators Daniel Patrick Moynihan and

Alfonse D’Amato of New York to perform a case study of Love Canal. The request

came at a time when OTA was completing its 3-year study of hazardous wastes. OTA’s

report Technologies and Management Strategies for Hazardous Waste Control was released in March 1983. OTA’s larger study on hazardous wastes formed the basis for

the case study on Love Canal.

The principal goal of the case study was to examine the technical basis for, and

validity of, the habitability decision for the emergency declaration area near Love Canal.

This decision was made by the Department of Health and Human Services, and was

based principally on the results of a monitoring study conducted by the Environmental

Protection Agency. OTA was also asked to examine the current monitoring and cleanup

activities at Love Canal, and the plans for future remedial action.

This technical memorandum consists of three principal sections:

1.

2.

3.

OTA’s findings on the habitability decision, and the four arguments on which

they are based.

An outline of the steps that could be taken to safely achieve incremental rehabitation of the emergency declaration area.

Implications of the results of this case study for the national Superfund program

for uncontrolled hazardous waste sites, under which cleanup at Love Canal is

proceeding.

The timely completion of this study was made possible by the extensive assistance

provided by many people at several New York State agencies, the Environmental Protection Agency, the Department of Health and Human Services, and the National Bureau

of Standards.

,..

Ill
OTA Love Canal Case Study Project Staff

OTA

Lionel S. Johns, Assistant Director, OTA

Energy, Materials, and international Security Division

Audrey Buyrn, Industry, Technology, and Employment Program Manager

Project Staff

Joel S. Hirschhorn, Project Director

Suellen Pirages, Senior Analyst

Michael Gough, Senior Associate

Administrative Staff

Carol A. Drohan Patricia A. Canavan

Contractors

Robert Michaels Katherine Gillman L. Adrienne Cupples

Publishing Staff

John C. Holmes, Publishing Officer

John Bergling Kathie S. Boss Debra M. Datcher Joe Henson

Glenda Lawing Linda Leahy Donna Young
Contents

Page

Acronyms, Abbreviations, and Terms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii

CHAPTER l: Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

The OTA Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Scope of the OTA Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

The Four Arguments for OTA’s Principal Findings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

Possible Steps Toward Rehabitation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

Implications for the Superfund Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

l. The ’’How Clean Is Clean?’’ Issue . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

2. Health Effects Data and Decisions inhabitability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

3. Technical Guidelines for Monitoring Studies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

4. Selection and Implementation of Remediation Programs . . . . . . . . . . . . . . . . . . . . . . . . 16

S. Long-Term Institutional Capabilities and Issues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

APPENDIX A: Remediation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Categories of Remedial Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Evaluation of Alternative Technologies at Love Canal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Control Action at the Love Canal Site . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Uncertainties Associated With the Remedial Action. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

APPENDIX B: Design of the EPA Monitoring Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

Scope of the EPA Monitoring Study . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

Evaluation of the Sampling Effort . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31

Conclusions About the Sampling Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

APPENDIX C: Results of the EPA Study Related to the Habitability Decisions . . . . . . . . . . . . 40

Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40

Basis of the Habitability Decision . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40

Problems With Statistical Comparisons of EPA Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40

Range of Variability for Reported Values . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

What If EPA’s Numbers Are Wrong? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44

Uncertainties in Potential Health Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

The Special Case of Dioxin . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

APPENDIX D: Analysis of the EPA Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

Statistical Analysis of Indicator Substances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54
Contents—Continued

List

Table

A-1.

A-2.

A-3.

A-4.

B-1.

B-2.

B-3.

B-4.

B-5.

c-1.

c-2.

c-3.

c-4.

c-5.

C-6.

D-1,

D-2,

D-3,

D-4.

D-5.

of Tables

No. Page

Advantages and Disadvantages of Control Technologies . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

Summary of Lifecycle Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Performance Criteria Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Priority Pollutants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Criteria Used To Evaluate EPA Sampling Effort . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Number of Sites and Samples for Target Substances 33

Approximate Size of EDA Study Regions 34

Sampling Effort for Dioxin . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

Comparison of Dioxin Sampling Effort Between Eastern Missouri and the EDA . . . . . . . 39

Number of Samples Required To Detect Actual Differences Between

the EDA and Control Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

Maximum Values Reported for Organic Compounds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

Maximum Values Reported for Dioxin, pub. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

Summary of Test Results Available on Health Effects of Chemicals

Disposed in Love Canal and Monitored by EPA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

Comparison of Regulated Exposure Limits to Detected Maximum

Concentrations in the EDA: Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

Comparison of Regulated Exposure Limits to Detected Maximum

Concentrations in the EDA: Air . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

Odds Ratio and Detection Rates for l,2-Dichlorobenzene . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

Detection of Indicator Substance and Numbers of Samples Analyzed

for Environmental Media in the Control Areas.... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55

Detection of Indicator Substance and Numbers of Samples Analyzed

for Environmental Media in the EDA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

Detection of Substances Not Found in Control Areas and Numbers of

Samples Analyzed for Environmental Media in the EDA . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

Summary of Mantel-Haenszel Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58

List

Figure No. Page

B-1.

B-2.

B-3.

B-4.

B-5.

B-6.

B-7.

B-8.

B-9.

B-10.

of Figures

The 10 Subregions of the EDA Included in the EDA Monitoring Study . . . . . . . . . . . . . . 31

Distribution of Shallow Well Sampling Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

Distribution of Deep Well Sampling Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34

Distribution of Soil Sampling Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

Distribution of Sump Water Sampling Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35

Disribution of Storm Sewer Sampling Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36

Surface Water Sampling Sites Along the Black Creek and the Bergholtz Creek . . . . . . . 36

Distribution of Air Sampling Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Distribution of Drinking Water Sampling Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37

Distribution of Dioxin Sampling Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

vi
Acronyms, Abbreviations, and Terms

ACGIH

ACS

C

CDC

CERCLA

DHHS

EDA

EDF

EPA

FEMA

GAO

gpm

IARC

LCARA

—

—

—

—

—

—

—

—

—

—

—

—

—

—

Acronyms and Abbreviations

American Conference of Government

Industrial Hygienists

American Chemical Society

control areas sampled by EPA monitoring study

Centers for Disease Control, Public

Health Service, U.S. Department of

Commerce

Comprehensive Environmental Response, Compensation, and Liability

Act of 1980, 42 U.S.C. 9601 et seq.,

known colloquially as “Superfund”

U.S. Department of Health and

Human Services

emergency declaration area

Environmental Defense Fund

U.S. Environmental Protection Agency

Federal Emergency Management Act

of 1978, CFR Title 44, Part 2, and

associated Agency

General Accounting Office, U.S.

Congress

gallons per minute

International Agency for Research on

Cancer, U.N. World Health

Organization

Love Canal Area Revitalization

Agency

LOD –

LOQ –

MDL –

NAS –

NBS –

NCI –

NTP

NYS/DEC -

NYS/DOH –

NYS/DOL –

OTA –

ppb —

ppm —

ppt —

RCRA –

TLV –

TSCA –

μg/kg —

μg/1 —

limit(s) of detection

limit(s) of quantitation

method detection limit(s)

National Academy of Sciences

National Bureau of Standards, U.S.

Department of Commerce

National Cancer Institute

National Toxicology Program

New York State Department of Environmental Conservation

New York State Department of Health

New York State Department of Law

Office of Technology Assessment, U.S.

Congress

parts per billion, equal to micrograms

per liter in water, micrograms per

kilogram in solids or gases

parts per million

parts per trillion

Resource Conservation and Recovery

Act of 1976, 42 U.S.C. 6901 et seq.

threshold limit value

Toxic Substances Control Act of 1976,

15 U.S.C. 2601 et seq.

micrograms per kilogram, equal to ppb

in solids or gases

micrograms per liter, equal to ppb in

water

Terms

emergency declaration area (EDA): area sampled by environmental submedium: 1 of 22 components of the

EPA monitoring study, outside 49-acre area sur- five environmental media

rounding the canal landfill, divided by EPA into 10 indicator substances: substance which was known to

subregions for sampling purposes. have been disposed into canal landfill

Love Canal: 49-acre area including canal landfill

environmental medium: one of five environmental sampled by EPA monitoring study

components sampled by EPA, including water, soil, target substance: 1 of 50 substances monitored in EPA

sediment, air, biota. monitoring study

vii
Chapter 1

Executive Summary
Chapter 1

Executive Summary

SUMMARY

In 1980, the Federal Government decided that

a potential health threat existed in an area near

Love Canal, beyond the canal itself and two inner rings. This outer area was termed the emergency declaration area (EDA). In cooperation with

New York State, the Federal Government provided assistance for residents who wished to move

out of the area. There was no clear evidence at

the time of substantial and widespread contamination of the EDA by toxic chemicals from Love

Canal.

From August to October 1980, the Environmental Protection Agency (EPA) conducted a monitoring study to provide evidence for determining whether the EDA was contaminated or could

become so. Later, the Department of Health and

Human Services (DHHS) became responsible for

deciding, on the basis of the EPA study and other

data, whether the EDA was habitable. In July

1982, after considering comments by the National

Bureau of Standards (NBS) on the procedures

EPA had used, and after further consultation with

EPA, DHHS affirmed its earlier provisional decision that the EDA was habitable. The decision was

contingent on effective safeguards against leakage

from the canal, and cleaning up contamination

in the EDA.

OTA has reviewed and analyzed the EPA monitoring study, documents prepared by other Federal agencies, plans for remedial action developed

by EPA and New York State, and various independent critiques. OTA’s primary goal was to examine the technical basis for the decision reached

by DHHS, in conjunction with EPA, that the EDA

is habitable.

OTA’s principal finding is that: With available

information it is not possible to conclude either

that unsafe levels of toxic contamination exist or

that they do not exist in the EDA. The OTA analysis does not support an interpretation of the

DHHS decision that would lead to the immediate

and complete rehabitation of the EDA. There remains a need to demonstrate more unequivocally that the EDA is safe immediately and over the

long term for human habitation. If that cannot

be done, it may be necessary to accept the original

presumption that the area is not habitable.

Four arguments that support the principal finding are:

1.

2.

3.

4.

The current activities and long-term plans

for EDA cleanup and operation and maintenance of the Love Canal remedial action

program pose difficulties and uncertainties.

The design of the EPA monitoring study,

particularly its sampling strategy, was inadequate to detect the true level and pattern of

toxic chemical contamination that might exist in the EDA.

The EPA monitoring study contains important uncertainties over the levels of the toxic chemicals detected, and the possible levels

of those not detected. There are also uncertainties over possible synergistic human

health effects of multiple toxic chemicals

present at low concentrations. These two

areas of uncertainty, as well as the lack of

detailed documentation by DHHS of its analyses, place the decision on habitability by

DHHS in doubt.

OTA’s analysis of some data obtained in the

EPA monitoring study provides limited, but

not conclusive, indication that there may be

contamination in the EDA by toxic chemicals

from Love Canal. OTA examined those data

for chemicals known to have been disposed

in Love Canal, as compared to the much

larger universe of data analyzed by EPA.

Incremental rehabitation of the EDA is a possible alternative to complete rehabitation, or to a

presumption that the area is not habitable. OTA

has outlined several steps that could be taken to

move in this direction. By incremental rehabitation we mean a paced, cautious approach. Improvements in scientific certainty to assure safe3
4

ty of the EDA are necessary for the success of this

approach. Another benefit of improved certainty is to increase public confidence in policy decisions that are based on technically complex data

and analyses. Four key steps for moving toward

incremental rehabitation are:

1. To address the technical problems and uncertainties in the current cleanup activities

in the EDA and in the long-term plans for

operation and maintenance of the waste

containment system at Love Canal.

2. To address the uncertainties related to institutional stability and effectiveness over

the very long terms (i.e., hundreds of years)

that reflect the long lifetimes of the chemicals in Love Canal.

3. To consider performing additional monitoring for carefully defined areas of the EDA,

perhaps for individual homesites. This

would make use of what has been learned

from the EPA monitoring study.

4. To develop a program for finding a permanent solution to deal with the large amounts

of toxic wastes still in Love Canal (i.e.,

waste destruction or detoxification instead

of the waste isolation approach now in effect).

OTA's case study of the Love Canal EDA

touches on a number of issues of general importance to the Federal Superfund program for cleanup of uncontrolled hazardous waste sites. EPA is

now aware of about 16,000 uncontrolled hazardBACKGROUND

In 1980, the Federal Government decided that

a potential health threat existed beyond the canal

(shaded area on figure) itself. The outer area was

termed the emergency declaration area (EDA). See

the accompanying figure for a description of the

EDA and Love Canal areas. In cooperation with

New York State, the Federal Government provided assistance for residents who wished to move

out of the area. Not all residents in the EDA decided to relocate. The canal itself and Rings 1 and

2 had been the subject of an earlier Federal state

of emergency which included total evacuation and

intensive cleanup efforts. As for the EDA, there

was no clear evidence at the time of the emergency

ous waste sites nationwide. The use of monitoring studies to answer questions on relocation and

habitability will likely continue to be necessary.

Therefore, it is important to learn as much as possible from the Love Canal experience to make future efforts more effective and efficient. There are

needs to:

Examine the “How clean is clean?” question,

and to develop standards for unacceptable

levels of contamination by toxic chemicals.

Obtain much more information on the health

effects of toxic chemicals, and better define

the Federal decisionmaking process concerning habitability of, and relocation of residents

from, uncontrolled hazardous waste sites.

Develop technical guidelines for monitoring

studies, particularly for sampling and analytical protocols, and for the way results are

presented and documented.

Compel consideration of more permanent solutions for cleaning up uncontrolled waste

sites, and to develop ongoing programs to

evaluate technological opportunities for

eventual permanent solutions to replace

waste containment “interim solutions. ” It is

also necessary to improve oversight by EPA

of State implementation of chosen remedial

action programs.

Explore answers to problems of long-term institutional effectiveness, such as mechanisms

to assure indefinite funding for operating and

maintaining waste containment systems.

declaration that substantial and widespread contamination by toxic chemicals existed in the area.

The voluntary evacuation was considered a precautionary measure.

Nevertheless, Government actions have raised

the issue of habitability of the EDA. These actions

included: providing assistance for relocation, implementing monitoring studies to determine if contamination was present (and at what levels and

patterns), carrying out studies on possible health

effects among residents of the EDA, and implementing the cleanup program to correct the

known problems in the canal itself and the adjacent rings. In light of these activities, the hab-
5

Love Canal Revitalization Area —

scale 1 =200

—

\

I

I

J

\ ‘-. - . ‘, ●

“% I

c , .

\ . ”

., ~% ~ ‘

. . .> ..4 I ,’ ‘]

-. . .

■ - UNOCCUPIED: HOUSES PURCHASED BY LCARA ‘.

● -

(423 AS OF 4/1/83) ‘. ,,

49- GRIFFON MANOR UNITS OCCUPIED

. J.

17- SENIOR CITIZENS UNITS OCCUPIED ., \ \

NOTE: UNSHADED OUTLINES ARE PROPERTIES

THAT ARE OCCUPIED . .

21-893 0 - 83 - 2
6

itability of the EDA became, and still remains,

an important issue.

Government agencies anticipated that scientific

evidence of no contamination, or of acceptably

low levels of contamination, would be necessary

before people could be allowed to move back into

the evacuated portions of the EDA. From August

to October 1980, EPA conducted a monitoring

study to provide evidence for determining whether the EDA was contaminated by toxic chemicals

from Love Canal, or could become so. The related, difficult task of deciding whether or not the

EDA was habitable was undertaken by DHHS.

DHHS was to make its decision primarily on the

basis of the EPA monitoring study, but was also

to consider other data on contamination levels

and on health-related problems observed in residents, as well as professional judgments about

possible health effects that could result from exposure to chemicals present in the EDA.

EPA asked NBS to examine the analytical

chemistry procedures EPA used in its monitoring

study. After completion of the initial NBS report

in May 1982, DHHS requested NBS to explain the

significance of the negative data in the EPA study.

Ninety percent of the samples taken by EPA had

revealed either no detectable levels or trace

amounts of contamination. DHHS wanted to be

satisfied that the data were reliable enough to

allow the conclusion that, in fact, only very low

levels of chemicals were detected. The possibility that EPA’s analytic techniques may have missed

contamination in the low parts-per-billion range

had to be considered. DHHS was satisfied with

EPA’s responses to the NBS comments on this

matter. In July 1982, DHHS affirmed its earlier

provisional decision that the EDA “is as habitable

as the control areas with which it was compared.”

However, DHHS made its decision on habitability

contingent on the understanding that the canal site

itself and Rings 1 and 2 would be “constantly

safeguarded against future leakage from the canal

and that cleanup is required for existing contamination of local storm sewers and their drainage tracts [in the EDA].”l

1

“DHHS Evaluation of Results of Environmental Chemical Testing

By EPA in the Vicinity of Love Canal-Implications for Human

Health–Further Considerations Concerning Habitability” (Washington, D. C.: Department of Health and Human Services, July 13,

1982).

It must be stressed that EPA’s monitoring task

for a large area possibly contaminated by hundreds of different chemicals was historically

unique, technically complex, and very large in

scope. EPA had no precedent for a similarly broad

and complex monitoring study, targeted toward

a decision on whether a site possibly contaminated

by toxic wastes was habitable or rehabitable.

Time for the study was severely constrained because of the Government’s strong desire to make

a policy decision on habitability. The effort was

further complicated by other factors:

1.

2.

3.

Information on the existing or potential migration of chemicals from the canal was lacking.

Boundaries for the EDA were arbitrary, unrelated to technical considerations of possible routes of transport of chemicals from the

canal.

The time constraints ruled out a pilot study

to define the requirements for ‘the larger

monitoring program (e.g., to identify qualitatively the levels of contamination to be expected, thus influencing sampling design and

the choice of analytical procedures).

The findings of the study, moreover, made a

habitability decision difficult. The discovery of

high levels of contamination of even a few chemicals can provide a reasonably certain basis for

a decision of “nonhabitability,” but it is far more

difficult to contend with a situation involving low

levels of contamination. The latter was the unexpected result of the EPA monitoring study. Did

the low levels of contamination in the EDA found

by EPA accurately reflect reality? For the general

public as well as technical experts, there were concerns about the sampling, analysis, and interpretation of EPA’s data. Thus, the goal of reaching a

policy decision on habitability quickly was not

met. Interpretation of the data collected by EPA

was difficult in itself. In addition, a number of

parties raised questions about the study which required further analysis.

The problems confronting New York State in

the Love Canal cleanup were also unique, difficult, and complex. Love Canal was one of the first
7

major uncontrolled hazardous waste sites in the

Nation where remediation was attempted. There

was a paucity of previous experience to offer

guidance on the technological problems of shortterm cleanup and long-term maintenance. These

THE OTA ANALYSIS

Scope of the OTA Analysis

At the request of the two U.S. Senators from

New York, and based on OTA’s previous work

on hazardous waste,2 OTA reviewed and analyzed the EPA monitoring study, documents prepared by DHHS and NBS, the plans for remedial

action developed by EPA and New York State,

and various independent critiques. OTA focused

on the technical aspects of sampling design and

analytical procedures used to obtain monitoring

data, on the statistical methods used to evaluate

the data, and on the immediate and long-term

remediation plans for the entire Love Canal area.

It was not OTA’s task to reach a finding concerning habitability of the EDA or to obtain new monitoring data. OTA’s primary goal was to examine

the technical basis for the decision already reached

by DHHS in conjunction with EPA. OTA was

also asked to consider possible implications of this

case study for the national Superfund program

for cleaning up uncontrolled hazardous waste

sites.

2 Technologies and Management Strategies for Hazardous Waste

Control (Washington, D. C.: U.S. Congress, Office of Technology

Assessment, OTA-M-196, March, 1983).

problems must be solved. Moreover, EPA’s Superfund program has not yet reached the stage

of providing complete, effective

policy guidance on remediation.

technical and

The principal findings:

1.

2.

With available information it is not possible to conclude either that unsafe levels of

toxic contamination exist or that they do not

exist in the EDA.

There are also serious concerns and uncertainties about progress in the remedial program to date and plans for the future.

The OTA analysis does not support an interpretation of the DHHS decision that would lead to the

immediate and complete rehabitation of the EDA.

There remains a need to demonstrate more unequivocally that the EDA is safe for human habitation immediately and over the long term. If that

cannot be done, it maybe necessary to accept the

original presumption that the area is not habitable.

The three following sections discuss:

1.

2.

3.

Four arguments that support the above findings, with the more detailed supporting analyses provided in an appendix to this report.

A number of Federal and State actions that

might be undertaken for incremental rehabitation of the EDA over time.

Implications and issues for the national

Superfund program of the Love Canal case.

THE FOUR ARGUMENTS FOR OTA’S PRINCIPAL FINDINGS

1. The current activities and long-term plans for The current activities and long-term plans for

EDA cleanup and operation and maintenance cleanup of the entire canal area and for isolation

of the Love Canal remedial action program of the wastes remaining in the canal must be efpose difficulties and uncertainties. fective (see the appendix for a description of these

activities and plans). Effective cleanup was a critical contingency in the DHHS decision on habRegardless of whether contamination of the itability, for two main reasons:

EDA by toxic chemicals exists now, rehabitation 1. in several areas of the EDA there are conof the EDA requires assurance about the future. firmed high concentrations of dioxin which
8

2.

pose a threat either if the dioxin stays where

it was found originally or if it migrates elsewhere; and

there remain in the canal itself very large

amounts of toxic wastes and contaminated

soil, both of which pose threats unless they

are safely isolated from the environment,

totally removed, or permanently destroyed

or detoxified onsite.

The remediation approach at Love Canal is

containment of the toxic wastes so that there is

no migration of toxic chemicals into the surrounding environment. This approach raises the question of what is meant by “long-term” in containing these wastes. Both technically and institutionally, “long-term’’ for toxic wastes must be interpreted to mean hundreds or thousands of yearn.

Why is it necessary to go beyond several decades

in assuring the effectiveness of the containment

system? Because many of the toxic chemicals present in the canal area are expected to remain stable

and hazardous indefinitely. It is difficult to conceive of sanctioning rehabitation in the areas most

exposed to leakage of toxic chemicals from the

canal area without a high level of confidence that

the remediation plan will remain effective beyond

the next few decades.

OTA sees three major reasons for concluding,

at present, that further attention must be given

to site cleanup and remediation before rehabitation of the EDA can proceed.

First, the areas in the EDA contaminated with

high levels of dioxin have not yet been cleaned

up. Moreover, until just a few months ago storm

sewers leading from the canal area to the EDA

and known to contain dioxin remained open. It

is possible that during the past few years—after

completion of the EPA monitoring study—dioxin

may have been transported within or beyond the

EDA. A study to determine the full extent of contamination in and near the sewers is not yet completed. When it is completed, it will greatly assist

the cleanup effort.

Second, there are technical problems with the

current activities and plans for the canal itself and

the immediate rings. These include:

• Leak Detection Systems. —The long-term integrity of the remedial technology is not certain. Reliable methods are needed to allow

early detection of damage (leading to permeability) to the two basic elements of the

containment system. These elements, intended to minimize water entering the canal,

are the cap over the canal area and the concrete barrier wall to be built around it. There

is no dispute about the need for repair and

replacement of the cap and leachate collection system over time, Yet, how it will be

done is not clear. How structural damage or

clogging of the drain system will be detected,

and how repair and replacement can be carried out safely remain unanswered.

Monitoring Programs. —Assurance of sufficient warning about any potential migration

and accumulation of chemicals from the

canal is essential. Plans are underway for developing a long-term monitoring plan for

ground water in the area immediately adjacent to Love Canal, but not in the EDA. In

this same area (adjacent to Love Canal) it is

also necessary to design more extensive ambient monitoring of environmental media

other than ground water (e.g., air, soil, and

biota). Media other than ground water are

possible routes of exposure to toxic chemicals. For example, depending on the properties of chemicals disposed in the canal and

the soil through which the ground water

moves, some chemicals could be filtered out

and could accumulate in soil or possibly in

biota. Humans might become exposed to

either. In addition, damage to the cap could

allow release of volatile compounds into the

air.

third major area of uncertainty concerns the

long-term ability of government institutions to

remember, fired, and carry out commitments for

long-term continued monitoring and maintenance

of the site. The full range of institutional issues

surrounding very long-term commitments for

managing uncontrolled hazardous waste sites

under the Superfund program have nowhere yet

been fully addressed. New York State is not alone

in facing these questions. But Love Canal is something of a historical first, and may be viewed as

a model. Annual cost estimates for routine operation and maintainance, as well as for replacement,

of the leachate collection system at Love Canal
9

are about $0.4 million now, $4.2 million in the

year 2005, and $8.5 million in 2030. These costs

could rise if the other leak detection and monitoring needs noted above are found to require attention. Even though the present State administration is committed to providing these funds, there

is no guarantee that State officials 20 or 100 years

from now will either remember or honor this commitment.

It is reasonable to raise the prospect that even

larger funds might be needed at some time to take

further corrective action at the Love Canal site

if the original containment system were to fail.

Furthermore, there are few institutional mechanisms in place to assure continuity in transferring

vital information on Love Canal from one generation to the next. Nor does it appear that New York

State has taken binding and permanent title to the

canal area in a manner that unequivocally rules

out future use of the site. * Finally, the idea that

the present containment system is no more than

an acceptable “interim solution” requires more attention. No specific program has been undertaken

to find a more permanent remedy for removing,

destroying, or detoxifying the wastes in the canal.

2. The design of the EPA monitoring study, particularly its sampling strategy, was inadequate

to detect the true level and pattern of toxic

chemical contamination that might exist in the

EDA.

The principal finding of the EPA monitoring

study was that, except for a few locations with

high levels of dioxin and some other chemicals,

there were insignificant levels and patterns of contamination in the EDA attributable to wastes in

Love Canal. The finding was based on analysis

of the samples taken in the EDA. Our concern

is that the design of the monitoring study was not

adequate to detect all significant contamination

that might be present.

The uncertainties which OTA sees as critical

involve such aspects of design as how many sam-

● This is not to imply that there is any serious consideration being given to reuse of the canal. But some people may raise this prospect for the future. Reuse already took place once, when governmental bodies deemed the canal area safe for community development after it was no longer used for waste disposal.

pies were taken for specific chemicals, in how

many locations within the EDA, and in what environmental media. Whether a monitoring study

detects contamination depends on how the search

is conducted. If the design of a monitoring study

is inadequate, then an erroneous false-negative interpretation may result.

The absence of a strong positive finding of contamination does not at all imply that a negative

finding (absence of contamination or absence of

health effects) follows logically or persuasively.

In the case of a monitoring study, particularly one

carried out under serious time constraints and

without the benefit of a pilot study, sampling inadequacies can lead to a low level of confidence

in the results. While there may never be absolute

confidence that a study can find what it is looking for, the issue in the case of the EPA monitoring study is that the confidence level is low.

This lack of confidence in negative results (the

finding of an absence) presents substantial problems to policymakers who desire a firm, scientific

basis for decisionmaking, but it is sometimes an

inevitable outcome of scientific studies. Scientists

themselves often find it difficult to give an answer

of “I can’t determine, or I’m not sure” rather than

a “yes or no” answer. Low confidence in the design of a study to produce the desired information, it should be noted, is not the same as scientific uncertainty over the results of a study; uncertainty is discussed in a later section.

The following specific problems with the sampling procedures used by EPA led OTA to judge

the outcome of the study indeterminate with regard to the extent (or distribution) and level of

chemical contamination, and its site and regional

variability y:

● The monitoring study sampled unevenly

across environmental media and the 12 regions (10 in the EDA, the canal, and the control). The numbers of sampling sites were not

in proportion to sizes of the regions, which

vary by a factor of 10. One reason for this

situation was that EPA assumed that higher

levels of contamination existed closer to the

canal. Consequently, some regions farther

away from the canal had very little sampling;
10

●

●

●

●

the distribution of sampling among regions

in the EDA was particularly inadequate. Initial beliefs about possible routes of transport

of toxic chemicals from the canal to and

through the EDA may also have influenced

numbers of sampling sites in environmental

media. To the extent that these assumptions

about patterns remain unproven or unsupported by the results of the study, it can be

concluded that the sampling may not have

detected contamination present in the EDA

which does not correspond to the patterns

assumed initially by EPA.

The numbers of sampling sites used were insufficient to determine accurately the level

of contamination within some regions.

As for environmental media, the extent of

sampling was very broad and included air,

surface and ground water, soil, sediment, and

biota. However, the effort across media was

uneven, and there was no examination of

yearly seasonal variations. Within the EDA,

those media sampled most extensively were

soil, air, and sump water. Ground water was

sampled less extensively and biota were

sampled least often of any of the environmental media. Sampling in some media may

have been inadequate to detect contamination.

Too few replicate samples were collected per

site to evaluate site variability; thus, the data

on absolute concentrations of chemicals detected within any one region may not be

meaningful.

The study lacked adequate control area data;

thus, comparisons among regions are difficult. However, as discussed more fully later,

DHHS did not rely entirely on the control

area data in its habitability decision.

The considerations outlined above apply to all

the chemicals sought in the EPA monitoring

study. However, OTA has examined the sampling

situation for dioxin in greater detail because:

●

●

●

dioxin is generally viewed as a very toxic

material at very low concentrations,

very high levels of dioxin were found in some

locations within the EDA,

public sensitivity to dioxin contamination is

high, and

• it is possible to make some comparisons between the Love Canal dioxin sampling and

that done by EPA recently in Missouri.

Monitoring for dioxin was insufficient with respect to extent (distribution), level, and replication. No conclusions can be drawn from the absence of positive findings for dioxin in most of

the EDA. There can be little assurance that the

findings accurately describe any contamination

that could or could not exist there. Only 6 out

of 21 environmental submedia in the EDA were

sampled for dioxin; of the 10 regions in the EDA,

only two were sampled for sump water contamination and three each for air and soil. In the 10

EDA regions no more than five sites were sampled per region, except for storm sewer sediment.

No attempt was made to take replicate samples

at all sites; this is particularly important because

dioxin binds strongly to organic particles. Some

further indication that sampling for dioxin in the

EDA was inadequate is that in three Missouri sites

the number of samples ranged from about 4 to

37 times more per acre than those used in the

EDA.

3. The EPA monitoring study contains important

uncertainties over the levels of the toxic chemicals detected, and the possible levels of those

not detected. There are also uncertainties over

possible synergistic human health effects of

multiple toxic chemicals present at low concentrations. These two areas of uncertainty, as

well as the lack of documentation by DHHS

of its analysis, place the decision on habitability

by DHHS in doubt.

The results of the EPA monitoring study were

the major basis for the DHHS habitability decision. Two lines of evidence have been offered to

support the view that the EDA is not too contaminated for habitation. DHHS has asserted that:

1. the EDA is no more contaminated than “control areas” near the EDA, and

2. the absolute levels of contamination are so

low as to present no health threat.

OTA has not emphasized in this discussion a

comparison of findings in the EDA with those in
11

the control areas used in the monitoring study.

As discussed in the appendix, OTA’s own analysis, analysis in other studies, and, to a degree,

even EPA’s own analysis disclose critical flaws in

the study’s use of control areas. As a result, most

of the comparisons made between the EDA and

control areas lack statistical confidence. In any

case, DHHS maintains that its decision on habitability did not solely depend on making comparisons with the control areas.

Therefore, the following discussion focuses on

the data which did form the critical basis of the

DHHS decision—-the levels of contamination detected in the EDA. EPA has presented data to

demonstrate that the low levels and the lack of

patterns of contamination it found are consistent

with levels found in industrialized areas nationwide. However, it is not clear how DHHS used

this information.

Like others who have examined the results of

the EPA monitoring study, OTA questioned the

reliability of the study measurements, which

found low values for most chemicals detected in

the EDA; moreover 90 percent of all measurements found only trace amounts, or no detectable

amounts, of contamination.

For the low values reported, the main issue is

the validity of the values and the uncertainty that

might exist in such values. EPA reported results

as parts per billion (ppb) and did not report results

as ppb plus or minus some value. The fact that

“plus or minus” values are lacking means that the

study provides no information on a possible

spread in the detected levels. Such a spread could

result from single or compounded errors in the

entire chain of sampling, and analysis of the samples.

Closely related to this issue is the level of contamination which is judged to be significant to

human health. Human health effects are different

for different chemicals, and they are also different

for the same chemical in different environmental

media because of differences in exposure opportunities. For example, suppose that 100 ppb is the

value, for a specific combination of chemical and

environmental medium, below which health effects are not considered important or likely. In

this case, a finding in a sample of 50 ppb plus or

minus 10 ppb would be a firm basis for a decision that health is not likely to be affected. But

if the result is 50 ppb plus or minus 40 or 50 ppb,

then such a decision becomes much less certain.

And in fact, it is often difficult to achieve high

levels of certainty in associating a health effect

with a given contamination level.

Considering the uncertainties in data and estimates of health effects, as well as in detection

levels, the combination of the two introduces substantial uncertainty into a decision dependent on

both. All technical data have some uncertainties;

nevertheless policy decisions can make use of such

data. The issue is: How much uncertainty exists?

The uncertainties for the EDA monitoring data

and with the health effects information used by

DHHS are high, and they make policy decisions

based on these technical inputs open to continuing debate.

EPA reported that its positive findings reliably

indicated contamination in the EDA no higher

than the low ppb range. NBS, which examined

the EPA monitoring study to assess the adequacy

of the analytical methodology, quality control and

quality assurance programs, did not support the

EPA contention. Based on a review of their analysis, OTA believes the NBS assessment is valid

and has not duplicated it. NBS said:

The methodology selected and used by EPA is

appropriate for measuring concentrations in the

low parts-per-billion range for air and water

samples. However, using appropriate methodology does not guarantee reliable results. Thus,

the question that remains is the level of performance of the laboratories conducting the analyses.

At the low parts-per-billion level, the contract

laboratories displayed wide variability in performance. Well-documented statements of precision and accuracy are critical since these provide

the only valid basis for assessing the meaning of

the numerical data to those who wish to draw

their own conclusions from the report. Without

such documented statements of precision and accuracy, the results of measurements are of limited

usefulness for making comparisons within and

among sites. 3 [Emphasis added. ]

3

From a letter by Raymond G. Kammer, Deputy Director, National Bureau of Standards, Aug. 30, 1982, sent to Senators Daniel

P. Moynihan and Alfonse M. D’Amato and Congressman John J.

LaFalce. This letter is the most recent statement from NBS and was

written after EPA responded to the earlier comments of NBS, and

also followed congressional hearings on the subject.
12

NBS also noted that the "limitations in the stateof-the-art for measuring biota and soils and sediments resulted in EPA appropriately focusing its

study principally on air and water. ” What all this

means is that there remains troubling uncertainty regarding the results of the monitoring study

indicating low levels of contamination in the

EDA. Some of the positive results said to be in

the low ppb range maybe as high as several hundred ppb because of variability and uncertainty.

Of even greater uncertainty are the 90 percent of

the results termed “not detected” or “trace. ” For

these results, NBS continued, in the letter quoted

from above:

Unless measured values, including “none detected, ” are accompanied by estimates of uncertainty, they are incomplete and of limited usefulness for further interpretation and for drawing

conclusions. For these reasons, performance "

. . . in the low parts-per-billion range” has not

been demonstrated to our satisfaction in the documentation.

Based on knowledge of the analytical methodology used by EPA and the documentation provided by EPA, NBS has no reason to believe that

measurements labeled “none detected” or “trace”

represent concentrations above one part-per-million. [Emphasis added. ]

DHHS has taken the results of the EPA monitoring study, including EPA’s reply to NBS concerns, to mean that the chemicals present in the

EDA are present in amounts ranging from low

ppb to perhaps several hundreds of ppb. Furthermore, except for the locations in which high levels

of contamination, primarily dioxin, were found,

DHHS has made the judgment that less than 1-

part-per-million levels support a positive finding

of habitability; i.e., that contamination is for the

most part so low and so unexceptional as to rule

out possible health effects for those choosing to

reside in the EDA.

OTA believes that the persistent concerns of

NBS remain valid. EPA has not yet provided all

the considerable details of its monitoring study

that would permit outside experts to reach EPA’s

own level of confidence in its data. Thus, levels

of contamination may or may not be consistently as low as DHHS concludes, and as EPA assures

them to be. Moreover, OTA has had difficulty

in assessing the foundation for the DHHS decision, as few details have been released (e.g., what

health effects data for specific chemicals and environmental media were considered, and how

these were linked to specific results of the EPA

monitoring study). DHHS faced problems with

EPA’s monitoring study because details were absent from the publicly available documentation.

Ironically, this is now the case with materials

made available by DHHS.

DHHS has not explained how it considered the

potential for synergistic health effects from the

many toxic chemicals at Love Canal. Synergism

means that low levels of contamination for several

chemicals may combine to pose health threats,

even though the same chemicals present individually at the same low levels of contamination might not be considered threatening. This

comment should not be interpreted to mean that

much information on possible synergistic effects

exists. Unfortunately, there are few data on

synergistic effects for the many toxic chemicals

which may contaminate the EDA. However, this

lack of information contributes to uncertainty for

possible health effects. The importance of this

uncertainty to DHHS is not clear.

It is also possible that for a few chemicals (e.g.,

hexachlorobenzene), contamination at levels of

only hundreds of parts per billion may pose health

threats. Such levels, because of uncertainties, may

have been present in samples recorded as having

no detectable or trace amounts. Of particular concern is uncertainty about the “no detect” results

for some two-thirds of samples tested for dioxin.

First, the number of samples tested for dioxin was

very small, only four soil samples in the entire

EDA of over 200 acres were taken. Moreover, the

problems of analyzing for dioxin are well known.

They may have been less known and, perhaps,

even worse in 1980 than they are today.

Finally, the semantics and logic of the formulation of the habitability issue raise questions. So

do the statements by DHHS on its habitability decision. DHHS defined the task for itself and its

consultants in this way:
13

Based on available data, can it be concluded

that the area is not habitable?4

This formulation of the habitability decision

task seems to demand one of two answers: either

the EDA is to be demonstrated as unsafe or it is

habitable. * In light of this formulation, DHHS

summarized its interpretation of the findings of

the panel of 11 outside experts who advised

DHHS staff, as follows:

. . . a majority of the consultants concluded that

based on the data available they could not conclude that the area was not habitable. 5

However, as indicated earlier, the inability to

conclude that the EDA is not habitable does not

necessarily imply that the EDA is habitable. It

may be questioned whether the findings of the

DHHS panel of consultants, as quoted above,

support the statements DHHS ultimately made on

habitability.

The most recent statement on habitability, by

a senior member of the DHHS team that made

the original habitability decision, includes no

reference to control areas and is put in unusually

positive terms:

Review of these [monitoring] data by the Department of Health and Human Services, with

evaluation of technical methodologies by the National Bureau of Standards, led to federal recommendations in July 1982 that the general area surrounding the Love Canal was safe for human residence outside the canal itself and the two rings

of homes surrounding it. It was also recommended that the storm sewers and their drainage

tracts be cleaned and that special plans be made

for perpetual maintenance of the clay cap covering the site.6

4 Statement of Edward N. Brandt, Assistant Secretary for Health,

Department of Health and Human Services, hearing of Subcommittee on Commerce, Transportation, and Tourism, House Committee on Energy and Commerce, Aug. 9, 1982.

* This formulation of the problem might be interpreted differently; i.e., that it demands a lesser burden of proof than a formulation

which begins with the premise that the area is unsafe. Detecting contamination is, at least theoretically, easier than proving that an area

is free of contamination. However, this is only the case if there is

precise design of the study and use of procedures which yield low

levels of uncertainties for experimental results.

5Brandt, op. cit.

6Clark W. Heath, “Assessment of Health Risks at Love Canal, ”

Fourth Annual Symposium on Environmental Epidemiology, May

2-4, 1983, Pittsburgh, Pa. (Dr. Heath was the senior author of the

DHHS habitability statement in July 1982. )

Relative to our earlier expressed concerns regarding cleanup and maintenance of the site, this

statement lacks the strong contingency element

of the original DHHS statement on habitability.

Instead, it poses cleanup and maintenance needs

as separate from the habitability conclusion. It

provides less assurance that the site will in fact

be cleaned up and the cleanup maintained; a concern which is emphasized in the OTA analysis.

Heath of DHHS notes that “one would hope

that this could be done while restoring the surrounding neighborhood to normal activity.” This

rather general statement not only retreats from

the implication that cleanup is a prerequisite to

habitability, it fails to address the potential problems of cleaning up the locations contaminated

with high dioxin levels without threatening the

health of nearby residents.

The results of studies on health effects and

chromosomal damage in Love Canal area residents may appear relevant to the DHHS habitability decision. For the most part, these studies

have found little positive evidence of health

damage. However, the following conclusion and

caveat by Heath should be noted:

. . . it can be said from current epidemiologic

data available at Love Canal that no striking increases in illness occurrence have thus far appeared in association with living near the canal.

This does not mean that such occurrences might

not yet appear or that some canal-related illness

may not have occurred but at frequency levels not

detectable by the studies performed.

The present state of uncertainty about health

effects for Love Canal area residents is not unique.

It is common. That is why so much public policy

in the environmental protection area is precautionary in nature. To wait for conclusive evidence

for adverse health effects in people would mean

that people could be unnecessarily exposed to toxic

4.

chemicals.

OTA’S analysis of some of the data obtained

in the EPA monitoring study provides limited,

but not conclusive, indication that there may

be contamination in the EDA by toxic chemicals from Love Canal.
14

Despite the limits and uncertainties of EPA’s

monitoring study previously discussed, OTA considered the possibility that the positive detections

found might be analyzed so as to better discern

whether significant contamination existed in the

EDA. Although some interesting, suggestive results were obtained regarding contamination of

the EDA, by no means are these results strong

enough to support a conclusion of nonhabitability. The results also suggest how future monitoring studies may be designed to produce more certain results.

OTA disaggregated the EPA monitoring data

to allow an examination of a small universe of

data, what we term “indicator compounds.” These

are toxic chemicals which are known to have been

disposed of in Love Canal and which the monitoring study looked for in the control areas and the

EDA. A statistical analysis was performed for

OTA to determine whether any observed differences in detections of contaminants in the EDA

as compared to the control areas were statistically significant. Four chemicals (1,2- and 1,3-dichlorobenzene and 2- and 4-chlorotoluene) were

found to be present in the EDA at significantly

greater frequencies than in the control areas.

However, the levels found for these chemicals

were quite low.

Why was it possible for OTA to find these statistically significant differences between detection

of contaminants in the EDA versus the control

areas when EPA came to a general conclusion that

the EDA was not significantly more contaminated

than the control areas? The chief answer is that

OTA combined monitoring data for all environmental media tested, thereby enlarging the data

base per chemical. EPA analyzed data per chemical for each submedia tested, which meant that

there were very few data for the control areas.

In this situation there were too few data from the

control areas to reveal statistically significant differences with the EDA. However, for several

chemicals EPA did find several significantly higher

frequencies of detection in the EDA samples as

compared to the control areas. Essentially, EPA

discounted the few positive findings of significantly more frequent contamination in the EDA because the number of negative findings was far

larger. This preponderance of negative findings

was based on the large number of chemicals which

EPA monitored in the study—about 150 chemicals, including 129 which are considered to be

“priority” pollutants for general regulatory purposes but, by and large, have no history of disposal in Love Canal. In other word, with regard

to its analysis and interpretation of data, EPA

directed a substantial portion of its efforts toward

chemicals that are not necessarily unique and important in the Love Canal situation.

POSSIBLE STEPS TOWARD REHABITATION

In making decisions on the habitability of the

EDA, there are choices other than immediate,

complete rehabitation and a continued presumption against people moving back into the area.

A number of actions could be taken to move

toward incremental rehabitation of the EDA. By

incremental rehabitation we mean a paced, cautious approach resting on improvements in the

scientific certainty for conclusions about the safety

of the EDA, and on increased public confidence

in policy decisions based on technically complex

data and analyses. Habitability need not be seen

“as an all or nothing” issue.

ing study unfortunately did not resolve, is that

some portions may not be contaminated, while

others may be. Over time, portions of the EDA

may be found, with a higher degree of confidence,

to be free of contamination. Depending on their

location, they may then be judged habitable. One

complexity is that if some areas are found to be

contaminated, then it will be necessary to clean

them up and to assess the effect of the cleanup

actions on uncontaminated and, perhaps, rehabitated areas.

Four critical actions merit further consideration:

In fact, one of the difficulties in assessing the 1. The technical problems and uncertainties in

habitability of the EDA, which the EPA monitor- the current cleanup activities and long-term
15

2.

3.

plans for operation and maintenance of the

containment system should be removed.

There must be effective cleanup of areas

known to be contaminated with dioxin.

The uncertainties of institutional stability

and effectiveness over very long terms (i.e.,

hundreds of years) should be addressed.

There may be ways to assure that the funds

necessary for indefinite monitoring, operation and maintenance of the containment

system, and for possible corrective actions,

will be available over the long term. It may

be possible to remove uncertainties related

to the ownership, title, and future use of

Love Canal. There are probably ways to assure that critical information is retained and

made accessible over long periods.

It should be possible to design well-focused

monitoring studies to be conducted for carefully defined areas of the EDA, perhaps for

individual homesites. To some extent, the

EPA’s 1980 monitoring study can serve a

function similar to that of a pilot study. The

new studies could monitor for fewer chemicals, sampling can be improved, and analytical results can be presented in ways that

remove uncertainties over their reliability

4.

and accuracy. Costs are a concern, but may

prove to be a reasonable investment. It appears that additional monitoring for individual homesites (including several samples

for dioxin and multiple samples for chemicals

known to have been deposited in Love Canal) might have a one-time cost of about

$5,000 per site.

Finding a permanent solution for the large

amounts of long-lasting toxic wastes still in

Love Canal is highly desirable. The present

containment approach may best be viewed

as an interim solution. Plans could be made

to:

●

●

track technological developments for permanently destroying or detoxifying the

wastes, and

assess the technical feasibility and economic cost effectiveness of applying such

developments at Love Canal.

Finally, EPA should provide considerably greater detail on the results of its monitoring study,

which might resolve the uncertainties raised by

NBS in its examination of currently available

documentation.

IMPLICATIONS FOR THE SUPERFUND PROGRAM

This case study provides insights into several

issues involved in the Federal Superfund program

for cleaning up uncontrolled hazardous waste

sites.

1. The “ HOW Clean Is Clean?” Issue

Technical standards to determine unacceptable

levels of contamination by toxic chemicals are,

on the whole, lacking. Some standards do exist

in various environmental programs, but there is

no overall set of standards for the broad range

of toxic chemicals associated with hazardous

wastes. Having such standards, however, does not

rule out the use of site-specific information (e.g.,

concerning migration routes and potential exposure levels) to arrive at habitability decisions.

Without standards, Government agencies must

make ad hoc decisions. Uniform protection nationwide is unlikely, and decisions may not

always be technically valid. This Love Canal case

study illustrates three uses for standards for acceptable (and unacceptable) levels of contaminants:

●

●

With such standards, technical information

on contamination, even if only from pilot or

preliminary monitoring, could provide the

basis for decisions on relocation of residents

and the nonhabitability of areas.

Standards could be very useful in designing

detailed monitoring studies to assess the full

extent and level of contamination. The problem could be defined as assuring that stand-
16

ards are not exceeded, rather than detecting

anything that might be present. Interpretation of the results of monitoring studies

would also be improved. Standards would

probably make the use of control areas unnecessary.

● The choice of cleanup technologies could be

more effective, if based on standards that set

targets and goals for the cleanup action.

2. Health Effects Data and Decisions

on Habitability

Better understanding of the health effects of toxic chemicals is a critical need, particularly on the

various exposure routes for toxic chemicals in hazardous waste sites. Using available data, it is possible to establish some standards for acceptable

levels of contamination, but more data are needed

to establish more reliable and complete standards.

Health effects data can be collected from conventional research, but more effective implementation of the congressional mandate in the Superfund legislation is also needed to expand the epidemiological data base for health effects in people already exposed to toxic chemicals. Moreover,

policy decisions on evacuation and relocation of

residents, and on (re)habitability, need a firmer

underpinning of administrative and analytic procedures. The responsibility given to DHHS for the

Love Canal EDA was not very clearly defined in

this respect. For example, no detailed analysis supporting the DHHS decision was provided. The

role of EPA relative to DHHS in substantiating

and reaching habitability decisions, and perhaps

the use of consultants and advisory panels by

DHHS, needs further examination. In the case of

Love Canal, interactions between EPA and DHHS

that could have influenced the design and implementation of the monitoring study were not

possible because DHHS did not play a role until

after the study was completed. If DHHS is to continue to be responsible for decisions on relocation

and habitability, then it may be appropriate for

it to participate more actively in the design and

implementation of monitoring studies, and the

analysis of their results.

3. Technical Guidelines for

Monitoring Studies

The entire experience in the EDA monitoring

program underlines the need to develop appropriate sampling and analytical protocols for a

number of toxic chemicals and environmental

media. It is also highly desirable to establish requirements for the presentation and documentation of results of monitoring studies, including

estimates of error and uncertainty.

4. Selection and Implementation of

Remediation Programs

A very important implication of this case study

for the Superfund program concerns the statutorily required analysis of alternative cleanup approaches. At Love Canal, and apparently at many

other Superfund sites, there has been no detailed

consideration of permanent solutions. The costeffectiveness study of which cleanup methods to

use at Love Canal considered alternatives for

isolating or containing the hazardous wastes in

the canal, but none that would destroy or detoxify the wastes. Methods to accurately evaluate the

relative cost effectiveness of containment versus

permanent solutions require more study.

The containment method adopted imposes operating and maintenance costs for all time

(presumably for which New York State is responsible). It is also subject to technical uncertainties

about possible future failures and release of toxic substances into the environment.

This leads to an exceptionally important consequence of the Love Canal experience for the

Superfund program: the need to compel consideration of more permanent solutions, albeit with

higher capital costs (to be paid mostly by the

Superfund program), in analyses of alternative

cleanup approaches. Some technical approaches

for onsite destruction and detoxification of toxic

wastes and contaminated materials are available

today, and considerable effort is going into the

development of more such techniques. Even if a

permanent solution does not appear technically

or economically feasible for a specific site at the
17

outset, there is a need for a formal, continuing

program to evaluate relevant scientific research

and developing technological opportunities for

such permanent solutions, site by site. The growing trend to relocate residents away from critical

uncontrolled waste sites, followed by containment

of wastes and contaminated materials, means continuing difficulties in establishing long-term safety

for rehabitation.

Another apparent need is for improved oversight by EPA of State implementation of selected

remediation programs. In the case of the EDA,

the delay in cleaning up areas known to be highly

contaminated with dioxin—still not carried out

several years after its discovery-is disturbing.

However, New York State has faced a number

of critical tasks at Love Canal as well as at other

uncontrolled hazardous waste sites that have undoubtedly strained its resources.

5. Long-Term

and Issues

Institutional Capabilities

Love Canal may have yet another unique and

useful historical role. Some Government regulations recognize the long-term hazards of nuclear

wastes and, reflecting concern for future generations, impose requirements for assured isolation

over thousands of years. Yet there has been very

little attention to the long-term hazards of toxic

wastes, and the extreme uncertainties of containment approaches for controlling them. This neglect is paradoxical and inconsistent. Many of the

most toxic wastes will retain their hazardous characteristics indefinitely. Unlike nuclear wastes,

most such toxic wastes (molecules) have no inherent half-lives; i.e., they will remain stable

unless they degrade through environmental interactions. Yet Government regulations for new

land disposal facilities have well-defined requirements extending only 30 years. In addition,

the Superfund program has given no consideration to the capability of institutions to carry out

essential tasks of controlling toxic waste sites for

hundreds or thousands of years.

In considering the long-term effectiveness of the

current remediation plan for the EDA, it became

apparent that there are currently no mechanisms

to assure indefinite funding for monitoring, for

operation and maintenance, and possibly for corrective actions for the waste containment system

at Love Canal. Considering the recent failures of

many public and private institutions to control

toxic wastes adequately, it is unreasonable to expect the public to have confidence in a Superfund

program that makes extensive use of long-term

waste containment but provides no assurances for

the long-term effectiveness of those “solutions.”

It is likely that waste containment at Superfund

sites will continue to be used until there are more

widely available and low-cost technological alternatives to destroy or detoxify wastes and contaminated materials onsite. The issues of long-term

institutional effectiveness cannot be escaped.

21-893 () - 83 - ~
Appendixes
Appendix A

Remediation

Summary

There are four areas of uncertainty that can affect

projections of the long-term integrity of the remedial

technology. Before any decision on habitability can

be made, these uncertainties must be addressed and

solutions identified.

1. Remedial Action in the Emergency Declaration

Area (EDA).—The areas in the EDA contaminated

with high levels of dioxin have not yet been cleaned

up. Moreover, until just a few months ago storm

sewers leading from the canal region to the EDA and

known to contain dioxin remained open. It is possible that during the past few years—after completion

of the EPA monitoring study—dioxin may have been

transported within or beyond the EDA. A study to

determine the full extent of contamination in and near

the sewers is not completed.

2. Leak Detection Systems.—The long-term integrity of the remedial technology is not certain. Reliable

methods are needed to allow detection of damage

(leading to permeability) to the two basic elements of

the containment system. These elements, intended to

minimize water entering the canal, are the cap over

the canal area and the concrete barrier wall to be built

around it. There is no dispute about the need for repair

and replacement of the cap and leachate collection

system over time. Yet how it will be done is not clear.

How structural damage or clogging of the drain system

will be detected, and how repair and replacement can

be carried out safely remain unanswered.

3. Monitoring Programs.—Assurance of sufficient

warning about any potential migration and accumulation of chemicals from the canal is essential. Plans are

underway for developing a long-term monitoring plan

for ground water in the area immediately adjacent to

the canal but not in the EDA. It is also necessary to

design more extensive ambient monitoring of environmental media other than ground water (e.g., air,

soil, and biota). Media other than ground water are

possible routes of exposure to toxic chemicals. For example, depending on the properties of chemicals disposed in the canal and properties of the soil through

which the ground water moves, some chemicals could

be filtered out and could accumulate in soil or possibly

in biota. Humans might become exposed to either. In

addition, damage to the cap could allow release of

volatile compounds into the air.

4. Institutional Mechanisms for Long-Term Protection of the EDA Residents. —The fourth major area

of uncertainty concerns the long-term ability of government institutions to remember, fund, and carry out

commitments for long-term continued monitoring and

maintenance of the site. The full range of institutional

issues surrounding very long-term commitments for

managing uncontrolled hazardous waste sites under

the Superfund program have not been addressed. Current cost estimates for routine operation, maintenance,

and replacement of the leachate collection system are

about $0.4 million now, $4.2 million in the year 2005,

and $8.5 million in 2030. There is no guarantee that

State officials 20 or 100 years from now will either

remember or honor this commitment. Furthermore,

there are few institutional mechanisms in place to

assure continuity in transferring vital information on

Love Canal from one generation to the next. Nor does

it appear that New York State has taken unequivocal,

binding, and permanent title of the canal area in a

manner that prevents future use of the site.

Categories of Remedial Technology

Technical options for remedial action implemented

under the authority of the Comprehensive Environmental Response, Compensation, and Liability Act of

1980 (CERCLA) can be categorized as either waste control or environment control.l Table A-1 lists the types

of technologies in these two categories and illustrates

some of the advantages and disadvantages of each.

The implementation of any of them will depend on

site-specific conditions. In some situations, a combination of waste and environment control strategies would

be required.

Waste control refers to the removal of the hazardous material from a site, followed by some treatment

that reduces the potential harm of hazardous compounds and subsequent disposal of the waste or treatment residue in an appropriate facility. The treatment

can involve destruction of toxic components of the excavated material through chemical, physical or biological processes, or immobilization of the hazardous

components.

At present, the application of destruction techniques

has been limited to excavated materials or small area

spills treated by biodegradation and chemical processes. Some thermal destruction technologies are available. Thermal destruction of large volumes of contaminated material, such as excavated soil, is a new ap1 Technologies and Management Strategies for Hazardous Waste Control,

“Chapter: Technologies for Hazardous Waste Management: Uncontrolled

Sites” (Washington, D. C.: U.S. Congress, Office of Technology Assessment,

OTA-M-l96, March 1983).

21
22

—

Table A-l.—Advantages and Disadvantages of Control Technologies

Type Advantages Disadvantages

Waste control technologies

Excavation and removal followed • Good for containerized or bulk disposal • High initial costs

by treatment or disposal ● Potential higher risk during cleanup

• Relocation of risk unless waste is

treated

. Not cost effective for low-level

hazardous waste or uncontainerized

buried waste in large area

Excavation with onsite treatment ●

Neutral ization/stabilization

Expose waste to complete treatment ●

●

●

●

Useful in areas where waste excavated ●

prior to mixing ●

Low risk of exposure if injection method

is used ●

High initial cost

Difficult to assure monitoring

effectiveness

Some risk of exposure

Not cost effective for large amount

of low-hazard waste

Limited application

Requires long-term land use

regulations

Eventual off site migration if reaction

is incomplete

Biodegradation ● Low costs ● Difficult to maintain optimum

conditions to keep reaction going

Solution mining . Useful in homogeneous uncontainerized ● Can result in uncontrolled release

solvent-soluble, buried solid hazardous

waste

Environmental control:

Isolation, containment, and ● Useful for large volumes of mixed . Effectiveness depends on physical

encapsulation hazardous and domestic waste and low- conditions

hazard waste ● Long-term O&M needed

Ground water diversion and ● Useful if soils are permeable or if there ● Requires wastewater treatment

recovery are high perched water tables option

● Process is slow

● O&M monitoring

● Not effective for insoluble or

containerized material

Surface water diversion ● Easy to implement ● Can create flooding off site

● No transport of waste offsite

Ground and surface water ● Can be used onsite or offsite ● May generate hazardous sludges,

treatment spent carbon

● Long-term monitoring

Gas collection or venting ● Low costs ● Site safety and fire hazards

● Off site air pollution

● Long-term monitoring and O&M

O&M—operating and maintenance.

SOURCE: Office of Technology Assessment, op. cit., p. 210.

plication and data on its efficiency are limited. Thus,

these technologies currently have not received widespread consideration as a remedial technology.

An alternative to destruction is the immobilization

of hazardous components. This is achieved by encapsulating the excavated material in some impermeable

matrix. When placed in soil or marine environments,

migration of hazardous constituents is then prevented

(or at a minimum, the rate of migration is decreased);

thus, the risk to public health and the environment is

reduced.

These control technologies can be used effectively

when the waste has been deposited in containers and

removal from the site can be accomplished readily. It

also can be implemented at those sites where hazardous components have not become distributed throughout environmental media. For example, it is used at

those sites where bulk disposal has occurred and before
23

widespread migration of the material within the soil

has taken place. However, if the contaminated area

is large, e.g., measured in several acres, waste control techniques are difficult and costly to implement.

In the case of an accidental spill, removal and subsequent treatment can be effective, if remedial action is

not delayed and boundaries of the spill can be identified easily. Under appropriate site conditions, treatment techniques can be used without removal of the

contaminated material, e.g., in situ biological or

chemical degradation of soil contaminated through an

accidental spill of hazardous chemicals.

Environment control options include those techniques that contain or isolate hazardous material, divert

water movement away from a site, or treat contaminated water sources. A review of 23 landfill sites suggests that environment control is the more common

remedial strategy currently in use.2 The technologies

for containment are not new; rather they are adapted

from structural or civil engineering procedures and

consist of the installation of caps, barrier walls, and

drainage systems. 3 4 At many sites, containment technology is used in combination with water diversion

techniques. These latter include changing the flow of

surface water to prevent flow into a contaminated site

or removal and treatment of ground water that has

been contaminated.

Because the strategy of environment control does

not remove sources of contamination, it is necessary

to include safeguards that increase the likelihood of

long-term integrity of containment and reduce effects

of failure should it occur. Well-developed environmental monitoring programs are essential safeguards.

Monitoring should include all environmental media:

water, air, soil, and biota. Moreover, some sort of leak

detection system is necessary to warn of possible

release of contaminants through the natural or synthetic barriers of the containment structure.

When comparing these two categories of remedial

technology, advantages and limitations can be identified. For example, environment control offers certain

advantages over waste control in that large areas of

contamination (e.g., many acres) can be controlled.

In addition, installation costs are generally less for environment control technologies than for waste control.

Environment control technologies eliminate the poten2E. Nagle, Environmental Law Institute, personal communication, April

1983.

3C. Kufs, et al., “Alternatives to Ground Water Pumping for Controlling

Hazardous Waste Leachates,” Management of Uncontrolled Hazardous Waste

Sites, Hazardous Materials Control Research Institute, 1982, pp. 146-149.

4P. A. Spooner, R. S. Wetzel, and W. E. Grube, “Pollution Migration Cutoff Using Slurry Trench Construction, ” Management of Uncontrolled Hazardous Waste Sites, Hazardous Materials Control Research institute, 1982,

pp. 191-197.

tial transfer of risk from one area to another; for some

waste control options this transfer of risk is a major

consideration. Moreover the use of environment control technologies does not create risks for transportation accidents. Environment control, however, requires long-term (i.e., forever) operation and

maintenance. In contrast, waste control includes

treatments that completely destroy the hazardous material, eliminating long-term hazards. Both environment control and those waste control options that only

immobilize hazardous components must include longterm monitoring programs.

A major concern associated with either type of

remedial action is the limited experience with these

techniques. Sites using either waste or environment

control have not been in existence long enough to provide sufficient data about the long-term integrity of

the methods. For example, a review of sites where environment control has been in place indicates that the

“oldest site” has had a clay barrier wall (5-to 8-ft thick)

only since 1976.5 Monitoring at this site has not yet

indicated leakage through the wall. Remediation at the

oldest sites incorporating barrier systems using synthetic materials (e.g., asphalt-bentonite, cementbentonite) were completed only in 1979. 6 Thus, our

experience regarding long-term integrity of containment technology is limited.

Uncertainties exist for waste control options, also.

Unless the extent of contamination can be characterized in detail, i.e., the types and concentrations of all

constituents are known, complete destruction of hazardous elements cannot be validated. New constituents

could be formed as products of the biological, chemical, or thermal processes taking place. These new constituents could be as, or more hazardous than, the

original compounds.

Much theoretical work has been done to predict the

performance of remedial technology. While the information gained through the use of theory and models

is important, it must be emphasized that at present no

field experience exists. The persistence of many waste

constituents is much longer than the effective lifetime

of the environment control technologies; the degree

of hazard for components in wastes may be increased

by waste control treatments. Thus, environment control may simply postpone risks to public health and

the environment to future generations, and waste control may create new hazards.

5Nagle, op. cit.

6 Ibid.
24

Evaluation of Alternative Technologies

at Love Canal

In accordance with CERCLA requirements, EPA did

a cost-effectiveness analysis of alternative technologies

for remedial action at Love Canal. Their analysis considered only environment control technologies. OTA

identified factors that are relevant to consideration of

waste control options:

1.

2.

3.

4.

Given the large area of the landfill and adjacent

land, waste control technologies likely would be

costly, possibly greater than environment control by orders of magnitude. For example, excavating and treating 49 acres of contaminated

soil to a depth of possibly 15 ft (equal to nearly

2 million tons of contaminated soil) would be a

major and expensive task with current technologies, particularly in water saturated zones.

Workers as well as residents in the EDA would

be exposed to hazardous substances through the

excavation process and formation of potentially

hazardous products by operation of a waste treatment system.

Given the broad range of chemicals that were

originally dumped in the canal and the variety

of products that could result from natural and

enhanced degradation as well as thermal combustion processes, the outcome of destruction efforts

is uncertain with present technology. Demonstration studies would be required to evaluate the efficacy of the waste control treatments. These

studies would delay completion of remedial action and possibly increase the risk to residents remaining in the EDA.

The problem of finding an ultimate disposal site

for treatment residue would be difficult to resolve

without knowing its hazardous quality. Disposal

of such residues in a new site could result in merely relocating health and environmental risks.

The environment control alternatives considered by

EPA included four altematives:7

1. No additional action beyond operation and

maintenance of a leachate collection system.

2. Cut-off and plugging utility lines, in addition to

alternative 1. All utility conduits that are possible routes for lateral movement from the site

would be plugged and all utility lines beyond the

containment areas would be cleaned.

3. Alternatives 1 and 2, plus installation of a partial wall. A subsurface wall would be installed

‘CHJWfi”14 Immediate Remedial Action-Uncontrolled Hazardous Waste

=lSites, zone L pdiminarydraftnwort tbr U.S. EPA Region IZ April

at points of natural migration routes from the

site—e.g., sand lens or drainage swales.

4. Alternatives 1 and 2, plus complete containment

of the contaminated area. Construction of a barrier wall that would completely enclose the site.

A summary of the lifecycle costs for these alternatives

is presented in table A-2. Although initially the costs

are greatest for option 4, over a period of 50 to 200

years this alternative is expected to result in the lowest

total cost to the State. As indicated in table A-3, each

alternative was also evaluated based on expected

performance. Alternative 4 provides the greatest

relative protection for public health and the

environment.

Table A-2.—Summary of Lifecycle Costs

(present worth In 1981 dollars-1 x 10a)

1 year 50 years 100 years 200 years

Alternative 1:

Capital . . . . . . . . .

O&M . . . . . . . . . . .

Replacement. . . .

Total. . . . . . . . .

Alternative 2:

Capital . . . . . . . . .

O&M . . . . . . . . . . .

Replacement. . . .

Total. . . . . . . . .

Alternative 3:

Capital . . . . . . . . .

O&M . . . . . . . . . . .

Replacement. . . .

Total. . . . . . . . .

Alternative 4:

Capital . . . . . . . . .

O&M . . . . . . . . . . .

Replacement. . . .

Total. . . . . . . . .

0.25

—

0.25

0.61

0.25

—

0.86

1.99

0.20

—

2.19

2.55

0.14

—

2.69

—

12.73

1.04

13.77

0.61

12.73

1.04

14.38

1.99

10.09

0.79

12.87

2.55

7.02

1.49

11.06

—

25.46

7.29

—

50.92

20.19

32.75

0.61

25.46

7.29

33.36

1.99

20.17

8.17

30.33

2.55

14.04

1.49

71.11

0.61

50.92

20.19

71.72

1.99

40.34

22.02

64.35

2.55

28.08

21.35

18.08 51.98

NOTE: Alternative 1—No additional action beyond installation of Ieachate collection system.

Alternative 2—Utility cut-off containment.

Alternative 3—Partial slurry well containment.

Alternative 4—Complete slurry wall containment.

SOURCE: CH2M-Hill, op. cit.

When Congress included the requirement of

conducting cost-effective analyses in the Superfund

legislation, the intent was that both waste and environment control alternatives would be considered. While

it is apparent that alternative 4 is preferred over alternatives 1 through 3, OTA questions the omission of

some consideration for of any waste control technology in the cost-effectiveness analysis. As indicated

above, present waste control technology cannot handle efficiently the large volumes of contaminated

material that exist at the Love Canal site. Therefore,

choosing environmental control options makes sense
25

Table A-3.—Performance Criteria Evaluation

Rank

a b c

Criterion Alt. 1 Alt. 2 Alt. 3 Alt. 4

Initial cost . . . . . . . . . . . . . . . . . .

O&M cost . . . . . . . . . . . . . . . . . .

Lifecycle cost . . . . . . . . . . . . . . .

Long-term environmental impact

Short-term environmental impact

Construction site health and

safety . . . . . . . . . . . . . . . . . . . .

Community health and safety .

Technical reliability . . . . . . . . . .

System reliability . . . . . . . . . . . .

Community acceptance . . . . . .

Construction duration . . . . . . . .

Achieve objectives . . . . . . . . . . .

Meet project bid date . . . . . . . .

1

3

3

4

1

1

4

1

4

4

1

4

1

2 3

3 2

4 2

3 2

2 3

2 3

3 2

2 2

3 2

3 2

2 3

3 2

2 2

4

1

1

1

4

aRanking ranges from “1” = best to "4" = worst. Equal rankings denoted by

equal low numbers.

bAlternative 1 . No additional action beyond Ieachate collection system.

Alternative 2 - Utility cut-off containment.

Alternative 3 - Partial slurry wall containment.

Alternative 4 . Complete slurry wall containment.

cNo weighting factors have been applied to performance criteria

SOURCE: CH2M-Hill, op. cit.

as a short to medium term action, pending development of technology to deal permanently with the

material. However, environment control cannot and

should not be considered a long-term or permanent

solution.

Many people have cited the great uncertainty of assuring long-term protection using environment control technologies. No effective alternative has been advanced. New York State officials are convinced that

greater efforts should be expended on research and

development of detoxification and destruction techniques thus, eliminating the need for long-term commitments to protection of a large land area. Once these

technologies have been developed, they must be given

serious consideration in any cost-effectiveness analyses

for remedial technology. Although waste control options might be extremely costly to implement, it is

possible that these would compare favorably with total

costs over a 200-year time period for environment control options. In addition, the complete elimination of

the hazard due to waste control treatments may

outweigh objections to the high cost for implementing

this type of remedial action and the short-term risks

to workers and residents due to excavation of the

material.

Control Action at the Love Canal Site

Because of the large area involved and environmental distribution of wastes disposed in the canal, the

remedial action chosen by EPA and the New York

State Department of Environmental Conservation

(NYS/DEC) follows a strategy of environment control. Two types of technologies are used: a leachate

collection system, for which construction began in

1978; and a containment system, for which construction work was planned for June 1983. These technologies are commonly used for remedial action.8 910

The drainage system became operational in 1979 and

is to continue indefinitely with planned repair and

replacement. The system consists of a clay cap covering the immediate area of the original landfill; a French

drain system rings the cap enclosing an area of approximately 23 acres.

Ground water migrates through the site into the

drainage system, is pumped into an onsite treatment

facility, and put into clarification tanks where water

and sludge phases are separated. The average flow

through the system is 8 gallons per minute (gpm); the

maximum capacity is 200 gpm and peak flows of 48

gpm have been recorded during the wet Season,ll The

water phase is drawn through an activated carbon

system and effluent discharged into the municipal

sewage system.

Effluent standards have been established by the City

of Niagara Falls specifically for discharge of effluent

from this facility. For every day that the treatment

facility is operational, analyses are performed to determine whether these standards are being met. Analyses

include tests for the presence of priority pollutants (see

table A-4) determination of effluent pH levels (the effluent is neutral), and analyses of levels of total organic

carbons (tests the efficiency of the activated carbon

system), and total chlorinated hydrocarbons. A review

of available data on constituent levels within treated

leachate indicates that the highest value recorded for

any of the priority pollutants was 46 parts per billion

(ppb).12 Even this low concentration has been detected

only occasionally; most results of the analyses indicate

no detection. State and city officials consider values

in the ppb range to be sufficiently low because the effluent receives further treatment in the public wastewater treatment system. 13 Residues from the treatment

8

Spooner, Wetzel and Grube, op. cit.

*J. C. Evans and H. Fang “GeotechnicalAspects of tk De@ and Construction of Waste Containment Systems, ” Management of Uncontrolled

Hazardous Waste Sites, Hazardous Materials Control Research Institute, 1982.

IOHand~ok ~r Reme~”a] Action at Waste Disposal Sites (Washington,

D. C.: U.S. EPA Municipal Environmental Research Laboratory, EPA-625/6-

82-006, June 1982). llCHzM-Hi]l, op. Cit., P. 3-1.

IZW. J. McDoug~], R. A. FUSCO, and R. P. O’Brien, “containment and

Treatment of the Love Canal Landfill Leachate,’’Joumaf WPC’5 vol. 52, No.

12, 1980, pp. 2,914-2,924.

I+J. Kolak, New York State Department of Environmental Con*rvation,

personal communication, March 1983.
26

Table A-4.—Priority Poiiutants

Volatile organic compounds

Acrolein

Acrylonitrile

Benzene

Carbontetrachloride

Chlorobenzene

1,1-Dichloroethane

1,2-Dichloroethane

1,1,1-Trichloroethane

1,1,2-Trichioroethane

1,1,2-2-Tetrachloroethane

Chloroethane

2-Chloroethylvinyl ether

Chloroform

1,1-Dichloroethylene

1,2-Trans-dichioroethyiene

1,2-Dichioropropane

1,3-Dichioropropene

Ethylbenzene

Methylene chloride

Methyl chloride

Methyl bromide

Bromoform

Dichlorobromomethane

Trichlorofluoromethane

Chlorodibromomethane

Tetrachloroethylene

Toluene

Trichloroethylene

Vinyl chloride

Bis (chloromethyl) ether

1,2-Diphenylhydrazine

Fluoranthene

4-Chlorophenyl phenyl ether

4-Bromophenyl phenyl ether

Bis (2-chloroisopropyl) ether

Bis (2-chioroethoxy) methane

Hexachlorobutadiene

Hexachlorocyclopentadiene

Isophorone

Naphthalene

Nitrobenzene

N-nitrosodimethylamine

N-nitrosodiphenylamine

N-nitrosodi-n-propylamine

Butyl benzyl phthalate

Di-n-butyl phthalate

Di-n-octyl phthalate

Diethyl phthalate

Dimethyl phthalate

Benzo(a)anthracene

Benzo(a)pyrene

3,4-Benzofluoranthene

Benzo(k)fluorathene

Chrysene

Acenaphthylene

Anthracene

Benzo(ghi)perylene

Fluorene

Phenanthrene

Dibenzo(a,h)anthracene

Ideno(l,2,3-cd)pyrene

Base-neutral extractable organic compounds Pyrene

Acenacphthene Bis (2-ethylhexyl) phthalate

Pesticides and PCBs

Aldrin

Dieldrin

Chlordane

4,4’-DDT

4,4’-DDE

4,4’-DDD

a-Endosulfan

b-Endosulfan

Endosulfan sulfate

Endrin

Endrin aldehyde

Heptachlor

Heptachlor epoxide

a-BHC

b-BHC

q-BHC

w-BHC

PCB-1242

PCB-1254

PCB-1221

PCB-1232

PCB-1248

PCB-1260

PCB-1016

Toxaphene

2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD)

Metals

Antimony

Arsenic

Beryllium

Cadmium

Chromium

Benzidine

1,2,4-Trichlorobenzene 2,4,6-Trichlorophenoi

Hexachlorobenzene Parachlorometa cresol Mercury

Hexachloroethane 2-Chlorophenol Nickel

Bis (2-chloroethyl) ether 2-Nitrophenol Selenium

2-Chloronaphthalene Pentachlorophenol Silver

1,2-Dichlorobenzene 2,4-Dimethyphenol Thallium

1,3-Dichlorobenzene 4-Nitrophenol Zinc

1,4-Dichiorobenzene 2,4-Dinitrophenol Miscellaneous

3,3’-Dichlorobenzidine 4,6-Dinitro-o-cresol Asbestos

2,4-Dinitrotoluene 2,4-Dichlorophenol

2,6-Dinitrotoluene

Total cyanides

Phenol

SOURCE: K. A. Brantner, R. B. Pojasek, and E. L. Stover, “Priority Pollutants Sample Collection and Handling,” Pollution Engineering, March 1981, p. 35.

process are presently being stored onsite for future cent data on water table elevations indicate that

treatment. The NYS/DEC plans to develop a pilot ground water in the region between the drain and the

project to investigate the potential for plasma arc in- landfill is being drawn into the collection system;

cineration as a treatment process for the sludge.14 likewise, data for the area immediately beyond the

Hydrogeological assessments suggest that the leach- drain and adjacent to the EDA also indicate flow

ate collection system is operating successfully.15 Re- toward the collection system.16

————-

Action Program Love Canal Project 1, Leachate Collection System, Niagara

Falls, New York Aug. 10,1982, prepared for Wald, Harkrader & Ross, Wash-

————.——— ington, D.C. According to Woodward-Clyde, their conclusions on ground

I* For a d~riptic)n of this technology see Technologies ad Man%ement

Strategies hr Hazardous Waste Control, op. cit., pp. 172-173.

water flow and the efficacy of the leachate collection system were essentially

the same as CHzM-Hill.

15~= were ~~om~ by CHIM-Hill, contractors for U.S. EPA; their l~Data provided by J. L. Slack, NYS/DEC, May 19, 19S.3, duri% a meeti%

report was not available to OTA. A separate evaluation of the system was with OTA, NYS/DEC, U.S. EPA, New York State Department of Health

made by Woodward-Clyde Consultants, Evaluation of Proposed Remedial (NYS/DOH), and New York State Department of Law (NYS/DOL).
27

The containment component of the remedial action

will involve the installation of a barrier wall around

the canal, encompassing an area of approximately 49

acres. 17 The wall will be constructed of concrete (a

width of 24 inches) and will extend to a depth of about

15 ft to be anchored into clay found at that depth. This

clay is very impermeable with hydraulic conductivity

(i.e., the rate at which water will move through the

strata) estimated to be in the range of 0.1 to 0.01 inches

per year.18 A synthetic membrane cap will be installed

to cover the entire 49 acres, including the existing clay

cap. This membrane will extend beyond the barrier

wall. Thus, it is expected that surface runoff will not

penetrate the enclosed area. Twelve inches of sterile

earthfill will be placed on top of the membrane cover;

6 inches of top soil will be the final cover. This top

soil will be grass seeded. All existing trees, shrubs, and

other plants will have been removed from the area

prior to installation of the synthetic membrane cap.

Only plants with a shallow root system can be allowed

to be grown within the 49-acre area. Long rooted

plants would eventually penetrate the cap.

The exact placement of the barrier wall will be determined using two sets of data: results obtained from

the 1980 Environmental Protection Agency’s (EPA)

monitoring study and 1983 data on the extent of dioxin

contamination in soils immediately surrounding the

canal. * EPA has concluded that major contamination

from Love Canal compounds does not extend beyond

the land immediately adjacent to the canal.**

According to Federal and State officials the wall will

serve three purposes:19

1. The wall reduces the volume of water dawn into

the leachate collection system. Based on results

from the 1980 EPA monitoring study, officials

assume that the water outside the 49-acre perimeter is relatively clean—i.e., contaminants are

present at concentrations of only parts per billion

or less. By including this clean water in the collection system, the ongoing operation and

maintenance costs will be quite large (see table

A-2, alternative 1). These costs must be covered

by State funds into the indefinite future. Reducing the volume of water that flows through the

17 Specifications for the barrier wall at Love Canal are provided in

NYS/DEC, Love Canal fioject 1 Site Containment System, Niagara Falls,

New York, vol. 1, August 1982.

1~L. R. Silka and J. W. Mercer, “Evaluation of Remedial Actions for

Groundwater Contamination at Love Cam], New York,” Management of

LJncontrolkd Muar&us Waste Sites, Hazardous Waste Control Research Institute, 1982, pp. 159-164.

● The new data on dioxin contamination were not available to OTA. They

are being collected by a contractor for NYS/DEC.

● *See app. C for OTA’s analysis of the EPA conclusions.

I*R< ~wliW, U.S. EpA Region II, personal communication, March 1983;

and N. Nosenchuck, NYS/DEC, personal communication, May 1983.

2.

3.

drainage system should result in a decrease in

operation and maintenance costs for the State.

Also once the 49 acres are contained by the barrier wall and surface covers, it is expected that

very little precipitation will infiltrate into the contaminated area. The rate of flow through the

drainage and leachate collection system is expected to decrease below the current average rate

of 8 gpm.

The wall provides further control against migration of contaminants from the canal into the residential areas. Should problems develop with the

leachate collection system at some time in the future, the barrier wall will serve as backup protection for EDA residents. Such protection, however, is dependent on there being no undetected

damage to the wall or cap over time. While leachate-collection system problems are being resolved, the wall would postpone migration of

compounds.

The wall prevents migration of chemicals into the

deep aquifer below the landfill. Results of a recent modeling effort indicate a third advantage

to having a barrier wall.20 After the wall is installed, a reversal of waterflow is expected between the shallow and deep aquifers, i.e., instead

of movement from shallow aquifer to deep aquifer, the flow will be from deep aquifer to shallow

aquifer. While some reversal may be occurring

due to operation of the collection system, the extent of the reversal should be greater with the

wall. If the model conclusions are correct, the

wall will provide the only real means for reducing deep aquifer contamination.

NYS/DEC recognizes the need for continued monitoring once the remedial action has been completed.

Although not yet completed, a ground water monitoring strategy is being planned. Because NYS/DEC considers that all mobile compounds will be present in the

ground water, no soil or air monitoring is planned.

State officials consider that any chemicals bound to

the soil will not be mobile. The synthetic cap is expected to prevent volatilization, therefore air monitoring would not be necessary .21

The EPA monitoring study identified chemicals in

sediment from both storm sewers and storm sewer

discharge points in surface waters. Cleanup of the

storm sewers within the canal area has been completed

and utility pipes were plugged in early 1983. Chainlink fences have been installed to discourage access to

‘OGeotrans, Inc., fioss+%wtional Simulations To Examine Proposed Wall

at Love Canal, New York oral presentation given to OTA, May 12, 1983,

~ls~tments made by NYS/DEC during a meeting on May 19, 1981.
28

contaminated areas in Bergholtz and Blackfoot Creeks.

Disposal of the contaminated sewage sediment awaits

permits from U.S. EPA. There are 375 drums of this

material being stored at the treatment facility. No action has yet been taken for contaminated storm sewers

within the EDA.

NYS/DEC initiated a monitoring study to determine

the extent of contamination within the storm sewer

systems located in the EDA. Chemicals of concern in

this study include priority pollutants and dioxin. A

total of 1,000 samples have been analyzed. The study

results are not yet available.

Discussions with the Love Canal Area Revitalization Agency (LCARA) indicate that decisions on the

future use of the properties within the EDA have not

been made.22 The Agency plans to delay any such decisions until the OTA review is released. An environmental impact assessment is required by State law

before any reuse of the EDA is allowed. LCARA has

begun the assessment process .23 Some sense of urgency is felt by the Agency to resolve the issue of

habitability so that revitalization plans can be

developed. It should be noted that 100 residences

within the EDA are currently occupied. A majority of

these (66 units in Griffon-Manor and Senior Citizen

housing) are situated adjacent to the canal area.

Uncertainties Associated With

the Remedial Action

There are four areas of uncertainty that can affect

projections of the long-term integrity of the remedial

technology:

1. Remedial action in the EDA.

2. Leak detection systems for the barrier wall and

leachate collection system.

3. Long-term monitoring programs.

4. Institutional mechanisms for long-term protection

of EDA residents.

While this brief OTA review cannot provide any suggestions for reducing the impact that these uncertainties may have, it is imperative that any decision of

habitability consider them and their consequences for

continued protection of the residences in the EDA.

Remedial Action in the EDA

Both EPA and NYS/DEC officials have based their

analysis of the need (or lack thereof) for remedial action in the EDA, beyond that required for the storm

sewer system, solely on the results of the 1980 monitoring study. The major concern was whether contamination observed in this area resulted from migration of

chemicals from the Love Canal landfill. Because the

EPA monitoring study indicated that the only portions

contaminated by Love Canal wastes (within the EDA)

were storm sewers and surface water sediments, no

large scale remedial action is planned.

According to NY officials, the actual extent of contamination in the storm sewers has not been fully

deterrnined.24 A monitoring study is in progress and

once the data are available, a decision will be made

about an appropriate method of cleanup. With the installation of the barrier wall and cover, future contamination of the EDA from Love Canal chemicals is

not anticipated.

Unfortunately, the 1980 monitoring data were not

sufficient to determine if hot spots of contamination

exist. Although data are recorded by subsection of the

EDA, all values were averaged for the area as a whole.

If hot spots do exist and remain untreated, the area

will continue to pose a threat to the health of the

residents.

Leak Detection Systems

Any analysis of the effectiveness of the remedial action must include some consideration of the capability to detect failure at some time after the system is

complete. A major limitation of environmental control systems, however, is that there are few methods

to test their continued integrity. Any cracks that

develop in the wall could serve as possible routes for

migration of chemicals. If the leachate collection

system is working properly, such cracks should not

pose a threat for outward migration of contaminants.

If the system does not operate properly, however,

pooling of ground water could occur near subsurface

structures. These could consist of rock formations

within the area as well as the basement structures containing rubble from destroyed houses on land immediately adjacent to the canal. Subsurface barriers

could impede downward movement of ground water

and facilitate lateral movement through breaks in the

wall.

Officials at NYS/DEC estimate that a well-made

concrete wall should last for at least 50 years. Even

if it lasts twice the expected lifetime, cracks can be expected. The only means to detect these cracks would

be a decrease in the water table elevations. The synthetic membrane cap has an estimated lifetime of 20

ZZR. Morris, Umtjve Director, LCARA, Niagara Falls, N. Y., personal

communication, March 1983.

~JStatments made by LCARA officials at a meeting on May 19, 1983.

24J. Slack, NYS/DEC, personal communication, March 1983, restated at

a meeting on May 19, 1983.
29

years. Evaluation of water-table elevation data and

changes in volume of leachate collected in the drainage

system are the currently available methods of determining the existence of damage.

Monitoring Programs

A final area of uncertainty concerns long-term monitoring strategies. The monitoring effort that is planned

may not provide sufficient warning about migration

and accumulation of chemicals outside the barrier

wall. The State plan requires only a ground water

monitoring program. 25 It is presumed that all mobilized chemicals would eventually migrate into the

shallow aquifer system within the barrier wall.

While ground water monitoring is a necessary

safeguard for containment technology, it is possible

to have contamination of soil and air before substantial levels of contaminants are detected in ground water

samples. For example, if cracks develop in the cap,

volatile compounds would be released to the air rather

than be transported through water. This situation existed when damage to the original cap occurred, and

noxious odors were apparent around the canal area.26

Also, those chemicals that have a strong affinity for

organic material can be filtered out of contaminated

water as it passes through soils high in organic components; this property is typical of clays found in the

vicinity of the canal. Thus, any migration of contaminated water outside of the barrier wall could lead to

a build-up of such chemicals in the soil and perhaps

be taken up by vegetation. However, at present no

plans exist to do any surveillance monitoring of air,

soil, or biota.

Such accumulation and uptake of these types of

chemicals, often compounds that are very persistent

in the environment, would not be detected through

ground water monitoring. It is likely that the absence

of chemicals in the ground water samples would be

interpreted as no contamination of the area surrounding the canal when, in fact, contamination in soil and

biota could be present. It may be prudent for

NYS/DEC to develop a monitoring strategy that observes biotic changes in areas adjacent to and outside

the barrier wall as well as analyzing soil and ground

water samples.

Institutional Mechanisms for Long-Term

Protection of EDA Residents

The first area of uncertainty surrounding the

planned remedial action concerns the need for long-

------ — ----- .— 25J. Slack, NYS/DEC, personal communication, March 1983.

26Statements made by State officials during a meeting with NYS/DEC,

NYS/DOH, NYS/DOL, and LCARA on May 19, 1983.

term appropriations by the State of New York and future restrictions on the use of the canal property. Costs

for operation, maintenance, and replacement of the

wall, covers, and leachate collection system are high.

For example, current expenditures for operation and

maintenance of the treatment facility is approximately $0.4 million.27 Included within the lifecycle costs

presented in table A-2 are requirements for replacement of the following:

• synthetic cover every 20 years,

. major equipment at the treatment facility every

20 years,

● treatment plant building every 50 years,

● leachate collection system every 50 years.

Institutional and legal mechanisms are needed to

provide some assurance of a long-term commitment

to meet these costs. Although the current State administration may be completely committed to providing sufficient funds for maintenance of the remedial

action, there are no guarantees that 10, 20, or 50 years

from now the same commitment will hold. Because

the remedial action chosen was environment control

rather than waste control, the source of contamination will not be eliminated.

It should be emphasized that the current problem

in Love Canal arose because the original use of the

canal was ignored or forgotten and improper use of

the land initiated. The original deed given by Hooker

Chemical Co. to the Niagara Falls Board of Education

included statements about the hazardous nature of the

contents of the canal .28 The Board chose to ignore these

warnings and proceeded with construction of sewer

systems that cut through the canal wall and a school

that damaged the cap.

Without strong institutional mechanisms that will

guarantee continued protection for the EDA, these

original problems could reoccur 50 years from now,

when the current actors in this unfortunate drama have

left the scene. At present the State has a temporary

easement for an undetermined time, which provides

some protection against improper use of the land.

However, the canal property currently has three different owners: the southern region is owned by a

private citizen; the central section belongs to the Board

of Education; the northern portion is owned by the

City of Niagara Falls. If at any time in the future the

State of New York relinquishes its temporary easement, these owners will be free to utilize their property as they see fit. There are presently no strong legal

or institutional mechanisms that will prevent resale and

reuse of the land by the current owners.

— 

-— z7N, ‘Koiack, NYs/DEc, personal communication, April 1983.

“E. Zuesse, “Love Canal, the Truth Seeps Out,” Reason, February 1981,

pp. 16-33.
Appendix B

Design of the EPA Monitoring Study

Summary

One aspect of the OTA review of the 1980 Environmental Protection Agency’s (EPA) monitoring study

focused on the sampling design. The following specific

problems with the sampling procedures used by EPA

led OTA to judge the outcome of the study indeterminant with regard to the extent (or distribution) and

level of chemical contamination, and its site and

regional variability:

●

●

●

●

●

30

The monitoring study used uneven numbers of

sampling sites across media and 12 regions (10

in the emergency declaration area (EDA), the

canal, and the control area). The numbers of sampling sites were not in proportion to sizes of the

regions, which vary by a factor of 10. One reason

for this situation was that EPA assumed that

higher levels of contamination existed closer to

the canal. Consequently, some regions farther

away from the canal had very little sampling; the

distribution of sampling among regions in the

EDA was particularly inadequate. Initial beliefs

about the possible routes of transport of toxic

chemicals from the canal to and through the EDA

may also have influenced numbers of sampling

sites in environmental media. To the extent that

these assumptions about patterns remain unproven or unsupported by the results of the

study, it can be concluded that the sampling may

not have detected contamination present in the

EDA which does not correspond to the patterns

assumed initially by EPA.

The numbers of sampling sites used were insufficient to determine accurately the levels of contamination within some regions.

As for environmental media, the extent of sampling was very broad and included air, surface

and ground water, soil, sediment, and biota.

However, the effort across media was uneven,

and there was no examination of yearly seasonal

variations. Within the EDA, those media sampled

most extensively were soil, air, and sump water.

Ground water was sampled less extensively and

biota were sampled least often of any of the environmental media.

Too few replicate samples were collected per site

to evaluate site variability; thus, the data on absolute concentrations of chemicals detected within any one region may not be meaningful.

The study lacked adequate control data; thus

comparisons among regions are difficult. However, as discussed more fully later, DHHS did not

rely entirely on the control area data in its

habitability decision.

Scope of the EPA Monitoring Study

In 1980, the EPA designed and implemented an extensive monitoring study of the EDA.1 The goals of

the study were:

1. to determine the extent and level of contamination in the area defined by President Carter in

his emergency declaration order (fig. B-1),

2. to assess the short- and long-term implications

of ground water contamination in the general

vicinity of Love Canal, and

3. to assess the relative environmental quality of

the EDA.

The design of the study was developed based on two

assumptions. First EPA expected that the levels of contamination would be very high. Also, EPA assumed

that the greatest contamination would exist nearest the

canal. EPA sampled five environmental media (air,

soil, sediment, water, and biota). Sampling sites were

selected in 12 regions: 10 subregions of the EDA, a

region directly adjacent to the Love Canal, and a control region that included selected sites throughout the

Niagara Falls area. Distribution of sites within a region

was generally random. The number of sampling sites

per region decreased with increased distance from the

canal. Additional sites were sampled at the request of

EDA residents and at places of possible migration

routes from the canal landfill. A total of 150 chemicals

were chosen for analysis, including chemicals that were

known to have been deposited within the landfill.

The EPA evaluated the data in two ways: one compared absolute concentrations of chemicals detected

within the EDA with available environmental standards and with concentrations detected at controI sites.2

Of secondary importance to EPA was a comparison

of the frequency of detection of chemicals in the EDA

to the frequency detected at control sites. EPA concluded that the only places within the EDA with significant contamination from Love Canal chemicals were

the sediments of storm sewer systems and their surface water outfalls.

‘Environmental Monitoring at Love Canal (Washington, D. C.: U.S. Environmental Protection Agency, EPA-600/4-82-030, May 1982), vol. I, II, III.

‘R. Dewling, U.S. EPA Region II, personal communication during a meeting

with OTA on May 12, 1983.
31

Figure B-1.—The 10 Subregions of the EDA Included

in the EDA Monitoring Study

10

/

‘ -- Indicates approximate location of the canal landfill within the Love Canal

region.

SOURCE: Woodward-Clyde Consultants, Evaluation of Proposed Remedial Action program Love Canal, Project 1, Leachate Containment System,

Niagara Falls, New York prepared for Wald, Harkrader & Ross, Washington, D. C., August 1982.

Evaluation of the Sampling Effort

There are certain principles for environmental

sampling that must guide any monitoring program.3

OTA used these principles as criteria for an evaluation of the EPA monitoring effort. As indicated in table

B-1, the OTA analysis suggests that the number of sites

and replicate samples taken at each site were insufficient to determine extent and level of contamination

for all of the EDA.

1. Are spatial and temporal factors considered?

The EPA study attempted to investigate spatial patterns that could be evidence of chemical migration

from the landfill. Sites were chosen to represent three

regions: an area adjacent to the canal, the EDA, and

control area. No samples were taken directly from the

3R. H. Green, Sampling Design and Statistical Methods for Environmental Biologists (New York: John Wiley & Sons, 1979).

landfill site for fear of interfering with the integrity of

the cap and sidewalls of the canal. Because of the time

constraints imposed on EPA, there was no attempt to

determine annual variability in the extent of contamination.

2. Were the choice and number of control sites

appropriate to distinguish among levels of contamination for the control area, EDA, and

Canal regions?

There is a general consensus within the scientific

community that all environmental studies require baseline data to which the test area can be compared. Such

baseline data can be control sites that are similar to

the test sites except for the variable of concern (in this

study the presence and concentrations of Love Canal

chemicals); baseline data can also be established standards for the chemicals of concern. If statistical analyses

are to be conducted comparing control and test site,

uncertainties in interpretation can be reduced if numbers of control sites are equal to, or closely approximate, numbers of test sites.

Because of the way EPA designed the sampling effort and because of the fact that the controls were

located farthest from the canal, the number of control sites was very small. For example, 11 control sites

were chosen for ground water samples. The number

of control sites for other environmental media also was

small; a maximum number of nine sites was sampled

as controls for soil analyses. For surface water and

sediment, as well as drinking water, only five control

sites were identified. Sump water and storm sewers

(both water and sediment) were sampled only at one

site in the control area.

Because the control sites for ground water were adjacent to and formed a ring around the EDA, there is

concern that some of these sites were not suitable as

controls. For example, it is not clear that these control sites were free of contamination from chemicals

similar to those disposed in the canal landfill. Because

the landfill had been in operation since the late 1940’s,

there is the possibility that chemicals could have migrated within the ground water to sites designated as

controls. For example, analysis of water table elevations prior to installation of the leachate collection

system indicate that flow of the overburden ground

water system was away from the canal, toward the

location of control sites.4 There is the added problem

that at least two of the control sites were located ad4Woodward-Clyde Consultants, Evaluation of Proposed Remedial Action

Program LQve Canal Rvject 1, Leachate Containrnent System, Niagara Falk,

I+&w York prqared for Wald, Harkrader & Rosa, Washington, D. C., August

1982.
32

Table B-l.–Criteria Used To Evaluate EPA Sampling Effort

Criteria Design of the study

Spatial/temporal factors: ●

●

Choice/number of controls: ●

●

●

Equal number of sites: ●

●

Replicates: ●

●

●

Verification of methods: •

Only spacial factors included in the study

No seasonal variations considered

Controls for ground water adjacent to EDA; possibility of

chemical migration to control sites from Canal

Two control sites adjacent to another Landfill

Number of control samples too few for adequate analysis

Unequal sample sites among regions

Not allocated in proportion to size of the regions

inconsistency in number of replicates taken per site

Not used to estimate variability within and among sites

Replicates treated as separate site samples

No verification of sampling, handling, and analytical

methods done prior to initiation of the study

EDA - emergency declaration area.

SOURCE: Office of Technology Assessment.

jacent to another known landfill, southwest of the

Love Canal area.

3. Were equal numbers of sites allocated among

regions and environmental media?

Equal (or nearly equal) numbers of sampling sites

among regions facilitate interpretation and reduce

uncertainties in results of statistical comparisons

among regions. If very different numbers of sites are

used, indeterminance can exist for those sites sampled least often. If equal numbers of sampling sites per

region are not possible, a standard practice is that the

numbers of samples be allocated in proportion to the

size of each region.

Because of the assumptions guiding the design of the

EPA study, the number of sites sampled across regions

were not equal nor were they in proportion to the differences in sizes among regions, as indicated in table

B-2. For example, the entire EDA is approximately 3 1/3

times the size of the Love Canal region (see table B-3),

yet the number of sampling sites do not reflect this difference. It should be noted that the sampling effort did

include sites chosen at the request of EDA residents

and because of possible migration routes from the

landfill.

Even for subregions within the EDA, the number

of sites were not allocated on a proportional basis (see

figs. B-2 through B-9.) For some media, site locations

are naturally limited. For example, sump samples were

obtained only in houses located in wet areas (fig. B-5);

surface water and sediment samples were possible only

from creeks (fig. B-7). However, for environmental

media such as air, soil, and ground water (both shallow and deep) allocation could have been proportional

to the area of each subregion. If this had been done,

the data would reflect a more accurate picture of environmental contamination over all of the EDA.

It should be emphasized that by designing a sampling effort with preconceived assumptions about the

outcome of the study, the use of the data can be limited. In this instance, the EPA data were used to make

judgments about the overall habitability of the EDA.

Because numbers of sites sampled decreased with increasing distance from the canal, uncertainties exist

about contamination in some areas. For example,

EDA-I had samples collected from only one or two

sites (depending on the medium of concern) for the entire region. This sampling effort is hardly sufficient to

determine the overall level of contamination for this

subregion.

4. Were replicate samples taken for each site?

It is very important that any monitoring effort include replicate samples (i.e., identical samples from

one site). The appropriate number of replicates will

vary depending on the anticipated impact that variability within individual sites may have on the conclusions drawn from the data. If an assessment relies

on absolute concentrations, replicate samples can be

used to estimate the variance in concentration at a particular site. Without replicates, confidence in the absolute concentrations cannot be indeterminate.

Replicate samples from one site are used to estimate

the amount of variance inherent at that site. Samples

collected at several different sites enable art estimation

of the variability inherent in a region. These estimates

of variability may not be equal. Differences between

them will depend on the evenness of distribution of

a chemical within the environment, the properties of

the medium being examined, and the presence of those

factors that enhance or inhibit degradation of the

chemical.
33

Table B-2.—Number of Sites and Samples for Target Substances

Regionsa

Environmental media 1 2 3 4 5 6 7 8 9 10 EDA LC C

Ground water

Shallow well:

Sites . . . . . . . . . . . . . . . . . 1

Samples b . . . . . . . . . . . . . 1

Deep well:

Sites . . . . . . . . . . . . . . . . . 1

Samples . . . . . . . . . . . . . . 0

Sump water:

Sites . . . . . . . . . . . . . . . . . 2

Samples . .............1-2

Drinking water:

Sites . . . . . . . . . . . . . . . . . 1

Samples. . . . . . . . . . . . . . 1

Surface water:

Sites. . . . . . . . . . . . . . . . . 0

Samples . . . . . . . . . . . . . . 0

Storm sewer water:

Sites . . . . . . . . . . . . . . . . . 1

Samples. . . . . . . . . . . . . . 1

Soil:

Sites . . . . . . . . . . . . . . . . . 7

Samples . .............2-5

Volatiles. . . . . . . . . . . . . . 9

Sediment:

Storm sewer:

Sites . . . . . . . . . . . . . . . . . 1

Samples. . . . . . . . . . . . . . 1

Surface water:

Sites. . . . . . . . . . . . . . . . . 0

Samples . . . . . . . . . . . . . . 0

Air:

Living:

Sites . . . . . . . . . . . . . . . . . 1

Samples Tc . . . . . . . . . . . 9

Samples P . . . . . . . . . . . . 3

Basement:

Sites . . . . . . . . . . . . . . . . . 0

Samples T..... . . . . . . . 0

Samples P..... . . . . . . . 0

Outdoor

Sites . . . . . . . . . . . . . . . . . 0

Samples T . . . . . . . . . . . . 0

Samples P..... . . . . . . . 0

13

11-13

9 5

8-9 5

3

2-3

3

2-3

3 2 4

2-3 1-2 1-4

49

36-47

18

9-21

11

9-11

11

7-1o

9 5

4-5 2-4

5

2-4

2

1

3 2 6

1 1 2-4

17

6-13

15

11-16

2

8-18

0 8

0 9-22

1

3-8

3

2-8

2 4 4

1-6 3-14 7-9

33

92-104

13

6-16

1

1-5

3

1-3

1 7

1 3-7

3

1-3

4

2-4

3 3 2

2-3 2-3 2

34

10-31

3

lt,3

5

lt,4-5

o

0

0 5

0 lt,2-4

o

0

0

0

0 0 0

0 0 0

5

2-4

0

0

5

lt,3-5

3

3t

3 6

l,3t 1-4

1

1

1

lt

1 1 4

1 1t 1,4t

1

1

9 10 10

6-9 3-10 8-10

18 19 18

23

13-23

45

15

14-15

28

12

9-12

24

9

1-9

18

113

71-109

213

9

5-9

17

3

1-3

3 6

1-2,3t 1-3

0

0

1 1 4

1 1 1-2

22

5-15

1

1

4

1-4

1

1

0

0

0 5

0 1t,4

o

0

0

0

0 0 0

0 0 0

5

3-4

0

0

5

1-5

6

60

26

5 8

52 76-79

20 48

5

60-61

25-26

6

66

27

6 6 5

49-50 62 46-47

35 43 22

54

538-542

292

30431

28

6

10-11

12

0 7

0 12

0 11

5

12

11

6

10

9

6

11

8

0

0

0

6

11

9

0 7

0 10

0 9

5

12

12

6

9

7-8

6

10

10

0

0

0

tSampled only for K-stable potassium, cesium, radium, Americium.

aColumns 1 through 10 represent subregions in the emergen Cy declaration ares (EDA); LC represents the region adjacent to the Canal, and C represents the control region.

bRepresents range of total analytical samples verified and entered into the EPA data base for each target substance; e.g., in EDA-2 some target substances

were analyzed using 11 shallow well samples and other substances using 13 samples.

C

T represents the total number of samples analyzed with the Tenax method; P represents the total number analyzed with the PFOAM method.

SOURCE: U.S. Environmental Protection Agency, Environmental Monitoring at Love Canal, Volume III.

As illustrated in table B-2, multiple samples per site that for some compounds as few as 8 samples were

were collected only for sump water samples, for vola- analyzed and recorded in the data base; for other

tile compound analyses in soil, and for air analyses.5

chemicals, analyses were performed with 18 samples

For example in EDA-2, two sump water sites were collected at the two sites. For all soil sites, two samples

identified from which 8 to 18 samples were collected per site were collected for analysis of volatile comfor chemical analyses. The range (8 to 18) indicates pounds. Two methods were used to analyze air samples. For the Tenax method nearly 10 replicates per

site were collected; four replicates per site were col-

‘Environmental Monitoring at Love Canal, op. cit., vol. 11. lected for analysis using the PFOAM method. It is dif-
34

Figure B-2.-Distribution of Shallow Well Figure B-3.–Distribution of Deep Well

Sampling Sites Sampling Sites

c

c

c

c c

—

c

.

1.

c

c c

KEY: Numbers denote subregions; X indicates approximate location of each

KEY: Numbers denote subregions; X indicates approximate location of each

well; C represents location of control wells; ( ) indicates maximum

Well; C represents location of control wells; ( ) indicates maximum

number of samples collected per region.

number of samples collected per region.

SOURCE: Environmental Monitoring at Love Canal (Washington, D. C.: U.S. Envi- SOURCE: Environmental Monitoring at Love Canal (Washington, D. C.: U.S. Environmental Protection Agency, EPA-600/4-82-030, May 1982), vol. Ill, p. 14. ronmental Protection Agency, EPA-600/4-82-030, May 1982, vol. Ill, p. 19.

Table B-3.—Approximate Size of EDA Study Regions replicates, EPA did not follow the normal practice of

using them to estimate variability within the site. Such

estimates are particularly important when low levels

of contamination are encountered and when an assessment of habitability is based on absolute concentrations of chemicals, as was the case in this study. The

decision to treat replicates as actual samples was unfortunate as it increases uncertainties about the significance of differences in observed concentrations

among control, EDA, and Love Canal regions.

Square yards Football fielda

Region (in thousands) equivalence

3 . . . . . . . . . . . . . . . . . . . . .

4 . . . . . . . . . . . . . . . . . . . . .

5 . . . . . . . . . . . . . . . . . . . . .

5. Were the sampling and analytical techniques

verified? Love Canal region . . . . . . 60

All sampling and analytical methods have certain

biases associated with them—e.g., differences in results

can occur if slightly different procedures are followed,

if different personnel perform the analyses, and if different collection and analytical equipment are used.

If results of environmental studies are to be properly

interpreted, it is necessary to identify these biases.

aCalculated by assuming a football field is approximataly equal to 5,000 yd2

.

SOURCE: Calculated from maps provided by the Love Canal Area Revitalization

Agency.

ficult to determine whether these multiple samples

were actual replicates.

If, in fact, these multiple samples were collected as
35

Figure B-4.—Distribution of Soil Sampling Sites

KEY: Numbers denote subregions, X Indicates approximate location of each

site; ( ) Indicates maximum number of samples (nonvolatile) collected

per region

SOURCE: Environmental Monitoring at Love Canal (Washington, D. C.: U.S. Environmental Protection Agency, EPA-600/4-82-030, May 1982), vol. Ill, p. 23.

Because of time constraints, EPA could not conduct

any preliminary analyses that would have identified

biases inherent in the techniques chosen for this

monitoring study.

In addition, EPA did not verify that the methods

used for sample collection and analysis were suitable

for the conditions at Love Canal. For example, the

methods of obtaining samples could have been a major contributor of the large number of below detection results that were obtained. Soil samples were obtained by using a soil corer, which obtained a core 1 3

/8

inches in diameter and 6 feet in depth. Seven cores

were taken at a site; two cores, representing two

samples per site, were analyzed for volatile chemicals.

The remaining five cores were homogenized and

treated as one sample per site. Such a method could

have serious consequences for detecting soil contamination. If the compounds are present at low concentrations and/or within only a small region of the core,

the practice of compositing five cores to produce one

sample will dilute any concentration level and make

detection extremely difficult. Because of this dilution

Figure B-5.—Distribution of Sump Water

Sampling Sites

KEY: Numbers denote subregions; X indicates approximate location of sites;

( ) indicates maximum number of samples collected per region.

SOURCE: Environmental Monitoring at Love Canal (Washington, D. C.: U.S. Environmental Protection Agency, EPA-600/4-82-030, May 1982), vol. Ill, p. 33.

factor associated with this particular sampling technique, even if hot spots exist at a site the measured

values would be lower than actual environmental concentrations. The use of such sampling techniques calls

into question the validity of using absolute contamination values as the basis for a habitability decision.

Similar problems existed for ground water samples.

For example certain ground water samples were invalidated by EPA, because it was suspected that inadequate purging had occurred.’ Hydrant water was used

as a drilling fluid during construction of the wells.

Prior to collecting samples the wells had to be purged,

removing all hydrant water. EPA officials thought that

hydrant water had been collected rather than aquifer

water. Appropriate location of sampling wells is critical to obtaining representative samples with which to

judge the extent of ground water contamination.

Plumes of chemicals, which may have densities greater

than water, can travel in directions different from the

6

Environmental Monitoring at Love Canal, op. cit., vol. I, p. 238.
Figure B-6.— Distribution of Storm Sewer

Sampling Sites

m

1

m

10

(2)

(

KEY: Numbers denote subregions; X indicates approximate Iocation of each

storm sewer; ( ) indicates maximum number of samples (water or sediment) collected per region.

SOURCE: Environmental Monitoring at Love Canal (Washington, D. C.: U.S. Environmental Protection Agency, EPA-600/4-82-030, May 1982), vol. Ill, p. 41.

ground water flow and can migrate into undetected

fissures.’ Thus, when this occurs analysis of samples

taken from those wells placed to match ground water

flow patterns would not likely lead to detection of the

contaminated plume.8

Analytical methods likewise were not verified for

Love Canal environmental conditions and study mechanisms prior to initiation of the monitoring effort. If

EPA had attempted such verifications, problems associated with sample extraction (e.g., for dioxin),

analyses of air samples using the PFOAM method, and

uneven analytical capabilities among laboratories

could have been resolved before enormous effort and

7The geology beneath the canal landfill has not been studied extensively.

Fractures have been noted in parts of the Niagara Falls region. E. Koszalka,

U.S. Geological Survey, Long Island, N.Y., personal communication, March

1983.

‘Ground water monitoring problems are discussed further in Tiwhnologies

and kagement Strategies fix Hhzar&us Waste Controf, “Chapter T: The

current Federal-State Hazardous Waste Program” (Washington, D. C.: U.S.

Congress, Office of Technology Assessment, OTA-M-l%, March 1983).

Figure B-7.—Surface Water Sampling Sites Along the

Black Creek and the Bergholtz Creek

.

I

m

-

10

/

KEY: Numbers denote subregions; ( ) indicates maximum number of samples

collected for region 4.

SOURCE: Environmental Monitoring at Love Canal (Washington, D. C.: U.S. Environmental Protection Agency, EPA0600/4-82-030, May 1982, vol. III, p. 51.

resources had been expended. Absence of the verification was probably a direct result of the fact that EPA

was under great pressure to do the study quickly. In

retrospect, providing time prior to initiation of the

monitoring study to verify methods likely would have

resulted in more definitive answers.

Proper sample handling is a critical element in environmental monitoring programs. All samples taken

in the field tend to lose a variable portion of the

substances to be monitored during sampling, handling,

and storage. A standard technique for determining the

percent of loss is to add a specified amount of known

substance (to “spike”) to certain field samples. The concentration of the spiked substance is measured in the

laboratory; any differences between the amount added

in the field and the amount measured in the laboratory

represents the percent lost during sample handling.

Analytical results of unspiked samples thus can be adjusted to reflect these losses. Loss of concentrations

during sample handling can result from chemicals

bonding to the sample medium or containers, to vola-
37

Figure B-8.-Distribution of Air Sampling Sites

—

—

—

b .

KEY: Numbers denote subregions; X indicates approximate location of each

site; ( ) indicates maximum number of samples collected per region.

SOURCE: Environmental Monitoring at Love Canal Washington, D. C.: U.S. Environmental Protection Agency, EPA-600/4-82-030, May 1962), vol. Ill, p. 61.

tilization, or to other chemical-physical processes that

may occur during handling and storage.

This technique was not employed in the EPA study

for water, soil, or sediment samples. Blind spiked

samples were included in the field sample analyses for

air. Consequently, reliable estimates of loss for most

substances cannot be made. (However, EPA did estimate percent recovery for extraction of dioxin from

field samples.) Particularly for volatile chemicals and

for those samples collected during the warmest periods of the monitoring program (which spanned August

to October), loss of substances could have occurred.

Analysis of air samples, however, did not reveal pronounced seasonal variations. It is uncertain whether

other media would reveal a similar lack of variation.

Field spiking was omitted from the EPA protocols

to eliminate the possibility of accidental contamination of all field samples with target substances.9 In addition EPA was presented with certain difficulties regarding implementation of spiking for their field

samples. Spiking with all 150 target substances would

Figure B-9.—Distribution of Drinking Water

Sampling Sites

x

x

KEY: Numbers denote subregions; X Indicates approximate location of each

site; ( ) indicates maximum number of samples collected per region.

SOURCE: Environmental Monitoring at Love Canal (Washington, D. C.: U.S. Environmental Protection Agency, EPA-600/4-82-030, May 1962), vol. Ill, p. 74.

be extremely difficult; choosing a few compounds to

serve as representatives of the total set has several

uncertainties associated with it. For example, it would

be difficult to verify that the representative compounds

behaved similarly to the 150 chemicals within the variety of environmental media investigated in this study.

Identification of these representative compounds

would have required additional time, and EPA was

under pressure to complete its large study within 6

months.

Conclusions About the

Sampling Strategy

Perhaps the most serious failings of this study were:

9

J. Deegan, statement and supplementary testimony before the subcommittee on Commerce, Transportation, and Tourism of the Committee on

Energy and Commerce, U.S. House of Representatives, 97th Cong., serial

No. 97-197, Aug. 9, 1982.
38

the inadequate numbers of sites sampled in different regions,

varying intensity of sampling of different environmental media, and

the lack of replicate samples with which to estity, confidence in reported concentration values must

be limited. For example, “trace” is considered to represent levels less than 100 parts per billion (ppb) in the

EPA study; the possibility exists that site variability

could range by an order of magnitude. Analysis of rep1 .

2.

3.

mate site variability in concentrations of chem- licate sample; from a site would verify whether trace

icals.

The numbers of collected samples per region and the

number of measurements available per target substance are insufficient to serve as a representative picture of the potential contamination either in the EDA

or within subregions of the EDA. For example, EDA-1

covers an area of approximately 80,000 square yards

(approximately equal to 16 football fields, as shown

in table B-3). Only one or two sites, depending on the

environmental media, were sampled to represent potential contamination. Similarly, nine or fewer sites

were sampled for all media to represent EDA-6, an

area approximately equal to 50,000 square yards and

directly adjacent to the Love Canal region.

The lack of sufficient sites and inability to estimate

sample variations within sites presents serious consequences for an assessment of habitability based on absolute concentrations. Without estimates of variabilirepresents 100 ± 10 ppb or 100 ±200 ppb. Because

human health effects can result from chronic exposure

to concentrations in the ppb and parts per million

(ppm) ranges, it is necessary to know with some level

of confidence that the values reported for an area represent actual environmental concentrations.

Dioxin is probably the most toxic of the contaminants (in low concentrations) known to be present in

Love Canal, and an analysis of the data for this chemical illustrates the OTA concern about the sampling

effort. Monitoring for dioxin was insufficient with respect to extent, level and replication, as shown in table

B-4 and figure B-10. Only 6 out of 21 submedia were

sampled in the EDA; 3 were sampled in control areas;

and 7 submedia were analyzed in the Love Canal. Of

the 10 regions in the EDA, only 2 were sampled for

sump water contamination and 3 each for air and soil.

No samples were collected in deep well, shallow well,

Table B-4.—Sampling Effort for Dioxin

EDA (10 subregions) Controls Love Canal region

Total Total Total Total Total Total Total

regions sites samples sites samples sites samples

Water:

Deep well . . . . . . . . . . . . . . . . .

Shallow well . . . . . . . . . . . . . . .

Sump . . . . . . . . . . . . . . . . . . . . .

Surface . . . . . . . . . . . . . . . . . . .

Drinking . . . . . . . . . . . . . . . . . . .

Storm sewer . . . . . . . . . . . . . . .

Sanitary sewer . . . . . . . . . . . . .

Soil . . . . . . . . . . . . . . . . . . . . . . . . .

Sediment:

Sump . . . . . . . . . . . . . . . . . . . . .

Storm sewer . . . . . . . . . . . . . . .

Sanitary sewer . . . . . . . . . . . . .

Surface water . . . . . . . . . . . . . .

Air:

Living area. . . . . . . . . . . . . . . . .

Basement . . . . . . . . . . . . . . . . .

Outdoor . . . . . . . . . . . . . . . . . . .

Biota:

Oatmeal . . . . . . . . . . . . . . . . . . .

Potatoes . . . . . . . . . . . . . . . . . .

Crayfish . . . . . . . . . . . . . . . . . . .

Dog . . . . . . . . . . . . . . . . . . . . . . .

Maple . . . . . . . . . . . . . . . . . . . . .

Mice . . . . . . . . . . . . . . . . . . . . . .

Worms . . . . . . . . . . . . . . . . . . . .

0

0

4

3

0

0

0

3

0

0

0

3

0

0

0

4

3

3

5

0

0

4

0

3

2

2

2

0

0

1

0

4

0

4

0

0

0

4

0

0

0

9

0

1

0

18

0

3

0

18

0

3

0

0

0

0

0

0

0

0

2

0

0

3

0

0

1

0

0

1

0

0

1

0

0

3

0

0

1

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

— — 0. — —

Totals . . . . . . . . . . . . . . . . . . . 33 36 3 3 23 16

SOURCE: U.S. Environmental Protection Agency, op. cit., Vol. Il.
39

Figure B-10.– Distribution of Dioxin Sampiing Sites

0

●

o

0

A ir

.

Key:

● Stream sediment

Ground water

Storm sewer sediment

SOURCE: Environmental Monitoring at Love Canal (Washington, D. C.: U.S. Environmental Protection Agency, EPA-600/4-82-030, May 1982), vol. Ill, p. 77.

drinking water, storm sewer water, or sanitary sewer

water. Surface water and sediment were sampled in

one subregion. It should be noted, however, that the

volubility of dioxin in water is extremely low (0.2 ppb).

Storm sewer sediment was collected in nine of the EDA

regions. Also, this substance has not been detected

previously in air samples, except when present on dust,

near incinerators, or in smoke from forest fires. Thus,

EPA may have reduced the extent of sampling because

of assumed distribution primarily in soil and sediment.

For a determination of the possible level of dioxin

contamination in the EDA, the amount of sampling

was very limited for dioxin. For most of the regions,

including the 10 subregions of the EDA, no more than

five sites were sampled per region. Storm sewer sediment sampled in the EDA is the one exception. Given

the large area covered by both the Love Canal and

EDA (see table B-3), this level of sampling effort seems

insufficient to estimate the potential contamination in

the Love Canal area.

Within each of the major sampling regions (EDA,

control area, and Love Canal), few replicate samples

were taken. Variability in concentrations within a

single site could be possible, but without replicates this

variability cannot be estimated. Lack of replicates reduces the certainty associated with comparison of

dioxin concentrations among the EDA, Love Canal,

and control area. Distinctions between regions require

estimates of variation within each individual region

as a basis for comparison. Consequently, in the extreme case of no replication, it is impossible to determine whether the regions, regardless of absolute concentrations, differ because of normal site variability

or because of actual regional variations.

OTA compared this extent and level of sampling for

dioxin at Love Canal with recent EPA protocols for

dioxin sampling in Missouri.10 The Eastern Missouri

Dioxin program has collected samples from some 30

areas, including Denny Farm (1979), Times Beach

(1982), and Quail Run (1983). Two important differences emerged.

1. In Eastern Missouri, preliminary surveys were

conducted to identify areas of highest

contamination,

2. Within the boundaries of these highly contaminated areas, the level of sampling was between

4 and 37 times as great as in the Love Canal EDA

(table B-s).

Table B-5.—Comparison of Dioxin Sampling Effort

Between Eastern Missouri and the EDA

Area Total Samples

(acres) samples per acre

Denny Farm (1979). . . . . . . . . . 4.5 30 6.7

Love Canal EDA (1980) . . . . . . 200 0.18

Times Beach (1982) . . . . . . . . . 640 5(X%OO 0.78-0.93

Quail Run (1983) . . . . . . . . . . . 24 113 4.7

SOURCE: Environmental Promotion Agency, Region Vll, Kansas City, Mo., May

Some important differences exist between the Eastern Missouri program and the Love Canal effort. First,

the analytical capability to analyze for dioxin has advanced tremendously since 1980. Second, the detection limits are different for the two programs: 20 parts

per trillion for Love Canal and 1 ppb for Eastern

Missouri. This leads to significant gains in turnover

time and laboratory capacities. Third, at Love Canal,

EPA was faced with analyzing for a broad diversity

of substances known to have been disposed in the landfill, while in the Eastern Missouri program, dioxin was

the only target substance. Fourth, in Eastern Missouri,

EPA is not operating under a presidentially declared

Federal Emergy Management Agency state of emergency as was the situation at Love Canal. Therefore, time

was not a limiting factor.

IOGale Wnsht, William Keffer, Will Bun, William Fairleaa, and John

Whitland, U.S. EPA Region VII, Kansas City, Me., personal communication, May 27, 1982.
Appendix C

Results of the EPA Study Related

to the Habitability Decisions

Summary

Until there is agreement about the possible level of

chemicals in samples that contained no detectable concentrations, it is pointless to dwell on the quantitative

aspects of health risk posed by chemicals from Love

Canal. If the concentrations are in the parts-per-billion

(ppb) range, the risk has to be judged to be very low

and probably acceptable. If the concentrations for

some chemicals are 1,000 times higher, in the partsper-million (ppm) range, the risks are probably not acceptable. According to the Environmental Protection

Agency (EPA), the concentrations are in the ppb range;

according to the National Bureau of Standards (NBS),

they could near 1 ppm.

OTA does not agree that the ppm estimate is realistic

for all chemicals, and it tends to accept EPA’s estimates, but OTA does agree with NBS that further

documentation from EPA is necessary to settle the

matter. A resolution between EPA and NBS might be

reached by an examination of a subset of EPA’s records. Also, if additional monitoring is carried out

before or during rehabitation of the emergency declaration area (EDA), EPA should consult with NBS to

ensure that quality control measures are adequate.

Basis of the Habitability Decision

The major input to the habitability decision was

data generated by the EPA monitoring study.1 The

Department of Health and Human Services (DHHS)

used absolute concentrations of chemicals found in

EDA and assessed the relationship of these concentrations to potential health problems. DHHS also reviewed data about health problems observed in EDA

and Love Canal residents and used professional judgments about possible human health effects resulting

from exposure to chemicals deposited in the canal landfill.

The OTA review concentrated on the EPA monitoring data and possible health effects associated with

Love Canal chemicals. OTA inspected but did not

evaluate the validity of reported health problems of

residents nor question the professional judgments of

the DHHS officials. The results of the OTA analysis

indicate three areas where uncertainties in the data

could have a major impact on the DHHS decision.

These areas include:

1. the range of variability associated with values reported for chemicals detected, nondetected, and

trace;

2. uncertainties in potential health effects associated

with Love Canal chemicals; and

3. problems associated with comparing data for the

EDA with data in control areas.

Problems With Statistical Comparisons

of EPA Results

A major statistical problem is related to the small

numbers of controls used in the EPA analysis.2 The

power to detect differences in contamination between

the EDA and control areas and between Love Canal

and control areas has been questioned.3 These criticisms that the canal cannot be distinguished from the

control are accepted as valid by EPA. This creates

uncertainty for a conclusion that the EDA is as habitable as the control areas to which it was compared.

Silbergeld has attacked the EPA monitoring study on

insufficiency of statistical power:

The small number of control area sampling sites seriously reduced the ability to detect differences in

chemical contamination between the Declaration Area

and the control area.

The absence of power to distinguish between the

canal and the control areas seriously compromises any

conclusions to be drawn from comparing Love Canal

to the EDA and EDA to the control areas because, in

most cases, statistically there are no differences between Love Canal and the control areas. The absence

*D. Rail, National Institute of Environmental Health Science, Research

Triangle Park, N. C., and B. Paigen, Children’s Hospital, Oakland, Calif.,

personal communications, May 1983. See Fmvironmental A40nitoring at Love

Canal: Interagency Review, comments by DHHS, NBS, and EPA (Washington, D. C.: U.S. Environmental Protection Agency, Office of Research and

Development, May 1982).

‘E. Silbergeld, Environmental Defense Fund (EDF), testimony before the

Subcommittee on Commerce, Transportation, and Tourism, Committee on

Energy and Commerce, U.S. House of Representatives, 97th Cong., serial

No. 97-197, August 1982, pp. 68-103.

3R. J. Cook, testimony before the Joint Public Hearing on Future Uses of

the Love Canal Hazardous Waste Site and Adjacent Property, State of New

York, Assembly Standing Committee on Environmental Conservation, Assembly Subcommittee on Toxic and Hazardous Substances, Feb. 17, 1983.

40
41

of statistical power to distinguish between the Love

Canal and control areas results from the small number

of control area samples, and nothing can be done at

this time to make up for that deficiency. It is important to remember that differences almost certainly exist in chemicals actually present in the Love Canal and

control areas. But the differences cannot be shown because of too few control area samples.

Independent analysis of the EPA data shows that

the greatest number of samples analyzed from any one

medium in the control area was 33, compared to 539

in the EDA.4 For every chemical tested there were

fewer than 10 samples in a majority of the media.

Table C-1 describes the number of samples needed to

have a good chance of detecting differences between

two areas. Formally, this table gives required sample

size for a one-sided, alpha 0.10, Z-test on two proportions to achieve a power of 0.90. In less formal language, if the real frequency of positive detections of

chemicals in the control sample is equal to 5 percent

(0.05) and the positive detection rate in the EDA is

equal to 20 percent, a minimum of 61 samples from

each region must be analyzed to have a 90-percent

chance of detecting this (fourfold) difference. Because

the maximum number of samples analyzed in the control region was 33 from any one medium and most of

the time it was only 10 samples, even a fourfold difference in chemical detection rates would not be recognized. Because differences in detection rates between

the EPA and control area are much smaller than these

values, statistical significance between the EDA and

controls could not be expected.

OTA concludes that any decision based on differences in detection frequencies between the Love Canal,

EDA, and control area must be discounted because of

the weak statistical basis of the EPA study. EPA apparently agrees with this assessment and asserted that

making such comparisons is not the normal way to

judge whether an area is contaminated.5 Rather, EPA

would rely on measured absences of chemicals to show

the area is not contaminated. Some type of baseline

data, however, are needed to make such judgments.

These baseline measurements could be either control

area analyses or established environmental standards.

Unfortunately, few of the chemicals disposed in the

canal landfill have established environmental standards.

Range of Variability for Reported Values

Except for some compounds detected in sumps and

storm sewer systems, concentrations of chemicals

reported for the Love Canal region were generally

quite low, as illustrated in tables C-2 and C-3. The

maximum values reported for organic chemicals detected in the EDA, Love Canal, and control regions

range from 0.05 to 263 ppm. In the Love Canal, very

high concentrations were reported for sump sediment

(16,500 ppm); however, these samples were taken from

sumps of homes that had been built directly adjacent

to the canal landfill. Table C-3 provides reported maximum values for those media where dioxin was detected. These values were 672 ppb found in storm

sewer sediment within the EDA and 37 ppb detected

in surface water sediment, also in the EDA. For all

other environmental media, results of dioxin analyses

were below EPA’s reported detection limits (20 ppt).

In the Love Canal, very high values of dioxin were

reported for sump and storm sewer sediment. No values were reported for the control areas.

Table C-1 .—Number of Samples Required To Detect

Actual Differences Between the EDA

and Control Areas

Number of samples/per medium to

Detection rates produce a W-percent chance of

Control EDA detecting a statistical difference

0.03a

0.06 b625

0.03 0.09 203

0.03 0.12 110

0.05 0.10 362

0.05 0.15 115

0.05 0.20 61

a The frequencies of detection in control area samples was between 3 and 5 percent

bAssumed detection rate in the EDA.

SOURCE: Cupples, op. cit.

Although these measures appear low, their absolute

values for organic compounds can be questioned. The

EPA monitoring study used 19 different analytical

laboratories, each with varying capabilities.’ NBS was

asked by EPA to review the quality control protocols

used in the study.7 While NBS accepted the protocols

as adequate, the Bureau could not verify the certainty associated with performance of the different laboratories. As stated in a letter to Senator A.M.

D’Amato: 8

4L. A. Cupples, Boston University School of Public Health, report submitted to OTA, Industry, Technology, and Employment Program, May 1983.

‘Statements made by EPA officials during a meeting with OTA on May

12, 1983.

6Environmental Monitoring at Love Canal (Washington, D. C.: Environmental Protection Agency, vol. I, pp. 36-37.

7Environmental Monitoring at Love Canal: interagency Review, op. cit.

‘R. G. Kammer, letter to Senator A. M. D’Amato, August 1982.
42

Table C-2.-Maximum Vaiues (in ppm) Reported for Organic Compounds

Shallow well. . . . . . . . . . . . . . . . . . . . . . . . . . EDA

Control

Love Canal

Deep well . . . . . . . . . . . . . . . . . . . . . . . . . . . . EDA

Control

Love Canal

Soil . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . EDA

Control

Love Canal

Sump water . . . . . . . . . . . . . . . . . . . . . . . . . . EDA

Control

Love Canal

Sump sediment . . . . . . . . . . . . . . . . . . . . . . . EDA

Control

Love Canal

Storm sewer water . . . . . . . . . . . . . . . . . . . . EDA

Control

Love Canal

Storm sewer sediment . . . . . . . . . . . . . . . . . EDA

Control

Love Canal

Surface water sediment . . . . . . . . . . . . . . . . EDA

Control

Love Canal

0.048 di-n-octylphthalate

0.150 di-n-octylphthalate

3.300 3-chlorotoluene

0.230 phenol

0.105 xylene

0.050 acrolein

3.120 chrysene

0.420 benzene

10.485 1,2,3,4-tetrachlorobenzene

0.586 1,4dichlorobenzene

0.002 Aroclor 1254

8.500 2,4-dichlorophenol —

—

16,523 2,4dichlorotoluene

0.062 1,2,4,5-tetrachlorobenzene

0.0001 gammma-BHC

0.120 hexachlorobutadiene

123.000 di-(2-ethylhexyl)phthalate

0.012 1,2-dichloroethane

263.000 Aroclor 1254

20.000 delta-BHC

23.645 di-(2-ethylhexyl)phthalate —

SOURCE: U.S. Environmental Protection Agency, op. cit., vol. Ill

Tabie C-3.–Maximum Vaiues Reported for Dioxin, ppb

Love Control

Media EDA Canal area

Sump water. . . . . . . . . . . . . . . . . . . . — .6 –

Sump sediment . . . . . . . . . . . . . . . . — 9570 –

Storm sewer sediment . . . . . . . . . . 672 329 –

Surface water sediment . . . . . . . . . 37.4 — —

SOURCE: U.S. Environmental Protection Agency, op. cit., vol. Ill.

As we reported in our May 10, 1982 review, unless

measured values, including non-detected, are accompanied by estimates of uncertainty, they are incomplete

and of limited usefulness for further interpretation and

for drawing conclusions.

EPA’s response to NBS was to provide a “worst case”

range for selected chemicals based on performance of

the worst laboratory.9 While this provides some idea

about the variability for these particular chemicals, it

does not allow estimation of confidence limits for the

total set of 150 chemicals used in the study.

As mentioned in appendix B, a major failing of the

EPA effort was the improper use of replicates. For most

of the environmental media, no replicate samples were

taken at individual sites. In those few instances where

replication was obtained, EPA treated them as separate

samples. Thus, there is no way to determine if the absolute values reported for any one chemical varies by

twofold, tenfold, or 100-fold.

‘Environmental Monitoring at Love Canal: Interagency Review, op. cit.

This concern is not trivial. All samples collected

from environmental media will vary to some extent.

Because of the inherent variability of ecosystems and

the variations in interactions between chemicals and

elements of the environment, a minimal level of uncertainty can never be overcome. An additional level of

variability results during the analytical phase of a

monitoring study. Such analytical variations arise

when different people perform the same procedure in

the same laboratory. Even greater variability is introduced when different laboratories with different

capabilities, experience, and equipment* are used in

the same study.

In addition to uncertainties associated with the absolute values reported for chemicals detected within

the EDA, there is uncertainty associated with the detection limits of the various laboratories. Within the

EDA, 90 percent of the analytical measurements were

below the laboratory detection limits. The obvious

question is raised. Are the low values real or could they

result from limitations of the various laboratories? If

detection limits were insensitive (i.e., too high), concentrations significant for potential health problems

may be overlooked. If detection limits were too variable, then extent of contamination may not be accurately identified. The adequacy of EPA’s reported

detection limits for analytical methods is difficult to

● Although the same brand name of equipment can be used by different

laboratory=, performance differences between similar equipment can be

expected.
43

evaluate, in part because of the conceptual complexity of detection limits.

Method detection limits (MDL) were used by EPA.

The MDL is the lowest concentration of a substance

that can be detected with a 99 percent confidence that

the reported concentration is greater than zero.10 EPA

regarded detections reported as “trace” to be above the

MDL for a particular analytical laboratory .11 Therefore, the upper limit for the frequency of reporting false

positive (or false negative) readings should be 1 percent, i.e., one might not be able to determine with 99

percent confidence that an undetected substance is, indeed, absent in a sample at concentrations below the

MDL. OTA finds that this is subject to uncertainty.

EPA reported detection limits for only a sample of

its target substances, on the grounds that this select

group was representative of each structural class present among the target substances. However, it is difficult to determine whether MDLs accurately reflect

routine practices of particular analytical laboratories.

As EPA acknowledged, except in the case of air samples, analytical laboratories knew which samples were

performance evaluation samples.l2 Performance evaluation samples could, therefore, have been analyzed

more carefully than on the field samples.

Moreover, a different MDL was reported for particular substances representing more than one analytical method, and up to six analytical laboratories.

In some cases, MDLs were estimated for several laboratories based on the performance of only one. These

factors contribute to uncertainty about detection

limits.

Reported MDLs for metals were estimates only, and

were reported as aggregated value, which obscures

variability among laboratories. Also, analysis for

pesticides have only a single reported MDL, again

obscuring laboratory variability. In contrast, a MDL

for many organic substances was reported as a measured limit for specific laboratories.

Although most reported detection limits are quite

low relative to health standards (where available), the

issue of uncertainty of detection limits is relevant to

the issue of the validity of EPA results. For example,

beta-BHC is reported to have an overall (low) MDL

of 0.006 ppb for analytical Method 608 in reagent

water. The same substance is reported to have MDLs

that range from 4.2 to 9.5 ppb using analytical Method

625. The actual value depends on which laboratory

performed the analysis. Thus, if different methods or

different laboratories were used to analyze for betaBHC, then intended comparisons of frequencies of

beta-BHC detections among components of the environment might represent comparisons of methods and

of laboratory performance. Although, in conversation,

EPA has asserted that this should not happen, no

mechanism for reliably preventing it was presented.

It should be emphasized that neither of these values

may be relevant to detection limits of actual samples

as the Love Canal samples which would contain competing contaminants that possibly lower analytical

power.

Such variability in MDLs is not atypical. Detection

limits for other compounds also varied widely. For example, reported MDLs for 1,2,3,4-tetrachlorobenzene

ranged from 0.5 to 17 ppb, varying by a factor of 34

for different laboratories employing the same analytical method. Detection limits for several closely

related substances, the alpha, beta, delta, and gamma isomers of BHC, varied from 0.004 to 0.009 ppb,

a factor of 2.25. Likewise, detection limits for DDT,

DDD, and DDE varied by a factor of 3 (0.004 to 0.12

ppb). MDLs for endosulfan 1, endosulfan 2, and endosulfan sulfate varied from 0.004 to 0.066 ppb (a factor of 16.5), and for heptachlor and heptachlor epoxide MDLs varied by a factor of 27.7 (from 0.003 to

0.083 ppb).

MDLs were reported for only a subset (about onethird) of the total 150 chemicals; EPA considered that

the subset of compounds spanned the range of compound classes used in the study .13 Consequently, EPA

asserts that it should be possible to determine approximate detection limits for all substances:14

Similarly, it is reasonable to assume that the method

detection limits of most of the organic analytes . . . fall

into the same range of 0.5 to 79 micrograms per liter.

Nevertheless, none are provided for substances known

to have been disposed into Love Canal.

This variability in detection limits introduces uncertainties in interpreting the meaning of the many samples reported to be below the limits of detection. This

uncertainty in turn casts doubt on any conclusions

about the levels of contamination of the EDA or the

control area.

All reported MDLs are in or below the range of 0.5

to 79 ppb. The observed variability of MDLs across

methods as well as for similar compounds and the lack

of MDLs for most of the target chemicals calls into

question the ability to detect hazardous concentrations

IOJ. A. Glaser, et al., ‘Trace Analyses of Wastewaters,” Environmental Science and Technology, vol. 15, 1981, pp. 1426-1435.

ll~vuonmenta] Monitoring at Love Canal, op. cit.

l~statmmts made by EPA officials at a meeting with OTA, May 12, 198s.

‘

3 Deegan, op. cit., “it is true that MDL’s were determined for a subset of

the target compounds, and the subset included model compounds for the complete set of target compounds . . a valid methodology . . . accepted widely in scientific research,” p. 147.

ldfiv~onmental h40nitor@ at Love Canal, op. cit., VO1. I, P. 228.
44

of the target substances. Were the detection limits for

each compound sufficiently low and were actual laboratory performances sufficiently high to allow a conclusion that those chemicals not detected would be

present in such low levels as not to pose a threat to

human health? Is the range of variability for MDLs

sufficiently low to be certain that estimates of variance

for absolute concentrations are not within hazardous

concentrations for all target substances? Until MDL

values are reported with estimates of variances for

each, uncertainties about the meaning of none detected

and trace, remain.

What If EPA’s Numbers Are Wrong?

Most of the samples in which EPA detected measurable amounts of chemicals revealed concentrations

in the ppb range. If those numbers are accurate, the

assumption can be made that the samples in which

only traces of chemicals were detected or in which not

even traces were detected contain even lower concentrations of chemicals. Looking at the data reported

later in tables C-5 and C-6, it can be seen that if the

trace measurements are in the ppb range, the levels

of chemicals in the EDA are indeed so low as to pose

an acceptable health risk (except for hexachlorobenzene and dioxin).

NBS was asked to comment on the amount of chemicals that might have gone undetected in EPA’s monitoring program at Love Canal. NBS was not convinced that the absence of detectable levels of chemicals in the EPA analysis was consistent with concentrations as low as parts per billion.15 Instead, it is confident that the concentration of a chemical reported

to be below detection is no more than 1 part per million.

OTA asked officials of DHHS who participated in

making the habitability decision if they would persist

in their conclusion that the declaration area was habitable if many chemicals were present in the near 1 ppm

range. The response was that they would stick by their

earlier decision with a demur about certain chemicals.

OTA would not be so sanguine about the safety of

the EDA if the concentration of all or most of the 150

chemicals approached 1 ppm. If the NBS estimate that

the “no detectable limit” might be as high as 1 ppm

is applied to monitoring of drinking water, then every

limit shown on table C-5 would be exceeded in the

EDA. If the conservative NBS estimate is not applied

to drinking water because it is to be expected that

drinking water would be cleaner than other waters and

soils, finding concentrations in the 1-ppm range in

1 5Krammer, op. cit.

other media would still show that contamination of

the EDA was widespread. In that case, the chance of

human exposure would have to be reckoned as substantial.

Some toxic chemicals exhibit “synergism,” i.e., the

toxic effect of simultaneous or sequential exposure to

two (or more) chemicals greatly exceeds the toxic effects predicted from adding together the effects of the

individual chemicals. Without consideration of synergism and with consideration of only additive effects

of chemicals, OTA would not consider the EDA habitable if many of the 150 chemicals were present at concentrations near 1 ppm. For instance, if 10 carcinogens

are present in concentrations such that each one poses

a 1 in 100,000 chance of a person developing cancer,

then the 10 together may pose a 1 in 10,000 risk, which

may well be so high as to be unacceptable. For the very

reason that so little is known about carcinogenic potentials and other toxic potentials, OTA would come to

the conclusion that the uncertainties about health effects from many chemicals being present at near 1 ppm

each would preclude considering the declaration area

to be habitable.

However, it is impossible to interpret the NBS opinion as supporting the idea that all chemicals for which

MDLs were reported might be present in concentrations near 1 ppm. First, the ability of laboratories to

detect chemicals varies from substance to substance.

The basis of the NBS conclusion, that no concentrations higher than 1 ppm would have gone undetected

must be based on consideration of the properties of

the chemicals most difficult to detect and measure.

Therefore, the MDLs for chemicals that are more easily

detectable must be lower, perhaps in the low ppb range

claimed by EPA. The second reason is that there is little

reason to believe that all 150 chemicals monitored by

EPA were actually present in significant amounts in

the Love Canal dump. Therefore, to assume that all

the 150 chemicals could be present at concentrations

of up to 1 ppm poses an immediate question about the

origin of all these chemicals. OTA’s concentration on

a subset of chemicals known to be present in the landfill eliminates the problems associated with assigning

a possible concentration to chemicals that are not present.

It would be a tedious task for EPA to supply estimates of variance to support the contention that all

MDLs were in the low ppb range. However, it might

be a manageable job for EPA to examine the records

for the 16 or so chemicals known to be in the landfill

in significant amounts. Because the argument about

possible health effects hangs on knowing the absolute

concentrations of chemicals in the EDA, further analysis of the EPA data seems worthwhile.
45

Uncertainties in Potential Health Effects

Adverse health effects from exposures to toxic substances are conveniently divided into two broad

groups: acute and chronic. Acute effects are observed

soon after exposure, typically to relatively large concentrations of toxic materials. For example, when a

ruptured train car spilled nitric acid and the wind carried fumes into residential areas of Denver, Colo., people experienced choking and difficulty in breathing.

Less spectacular and more common effects include eye

irritations from air pollutants during periods of poor

air quality.

Acute toxic effects are marked by the body’s responding to an insult from ingestion, inhalation, or

dermal exposure to a substance. When the insult is removed, the affected cells and organ systems of the

body may recover, may die, or maybe replaced. Importantly, new body cells, those formed after the insult has passed, are not affected.

Chronic toxic effects encompass three dread events:

mutations, cancer, and birth defects. These may result

from exposure to extremely low concentrations and

may not be observed until years after the exposure occurred. (Neurological disorders, which may be caused

by low doses of some materials, e.g., lead, are also

chronic health effects, but they are not discussed in

this paper. ) Mutations and cancer differ from acute

toxic effects in that cells are altered genetically and the

damage caused is perpetuated in progeny cells formed

from the one originally harmed. In contrast, birth

defects that result from in utero exposure of the fetus

to chemicals do not necessarily involve genetic alterations. Some may result from biochemical changes in

critical developmental processes. Because most concerns about health risks to EDA residents has centered

on chronic effects, the OTA review focused on mutations, cancer, and birth defects.

Mutagenesis and Cancer

Mutagenesis —the causation of mutations—is the

best understood chronic effect, from the standpoint of

mechanism. An environmental contaminant interacts

with the DNA of a germ (reproductive) cell and alters

the genetic information within it. If that germ cell, an

egg or a sperm, is involved in the formation of an organism, every cell in the new organism will bear the

alteration, the mutation. If this organism has progeny,

half of those progeny, on average, will bear the mutation. Thus, mutations are chronic in the sense that once

introduced into a population they may be propagated

in every succeeding generation. Some mutations are

beneficial, but most of those that are detected in

humans are associated with deleterious effects.16

Cancer also involves an interaction between a contaminant and DNA, but the mutational event occurs

in a somatic, or body, cell rather than in a germ cell.

Thus, the mutation is not passed on to the next generation. Instead, a mutation that results in cancer causes

rapid proliferation of cells. The rapidly growing cells,

all of which may derive from a single mutated cell,

in turn, produce a tumor.17

Many mutational events, whether they occur in somatic or germ cells, may have no effect because they

cause changes in DNA without biological consequences. Others may produce small but undetected

changes, either beneficial or detrimental. Although it

is likely that only a few DNA changes produce a detectable mutation or tumor, our awareness of mutational events in humans has been heightened by increasing knowledge of their sometimes devastating

effects.

Methods for Identifying Health Effects

During recent years, much effort has been expended

in identifying carcinogens, agents that cause cancer. 18

The methods used for identifying cause-effect relationships between manmade or natural substances and toxic effects in humans can be illustrated by a discussion

of the methods used to identify carcinogens. Effects

from carcinogens (and toxic substances, in general) can

be identified through results of epidemiology—the

study of diseases and their causes in human populations—and various laboratory tests.

Epidemiology is the only method that establishes

associations between a substance and human toxicity. However, it is limited as a technique for identifying chronic effects that appear years or decades after

exposure, because people are difficult to study, move

from place to place, change their work environment,

and change their living habits. Also, it is hard to locate

those people who may have been exposed to a particular carcinogen several years previously. Estimating

past exposures to suspect agents is very difficult.

Testing suspected chemicals in laboratory animals,

generally rats and mice, is the backbone of current toxic substances identification. A chemical is administered

to animals either in their food, water, air, or (less frequently) by force feeding, skin painting, or injection.

‘

b

For examples see The Rok of Genetic Testing in the Prevention of@-

cupational Disease (Washington, D. C.: U.S. Congress, Office of Technology

Assessment, OTA-BA-195, April 1983).

IT-ment of TK~olog;m for Btermining Cancer fiks from t~ fivironment (Washington, D. C.: U.S. Congress, Office of Technology Assessment, OTA-H-138, June 1981.

18Ibid.
46

The animals are observed over a specified time period

to identify acute or chronic effects.

The reliability of animal tests, bioassays, depends

on their design and execution. Guidelines for cancer

bioassays were published by the National Cancer Institute in 1976. Bioassays now cost between $100,000

and $1 million and require up tos years to complete.

Clearly such expensive tools can be used only to test

highly suspect chemicals, and much effort is devoted

to selecting chemicals for testing.

Molecular structure analysis and examination of

basic chemical and physical properties are used to

make preliminary decisions about the likelihood of a

chemical being toxic and whether or not to test it. For

instance, greater suspicion is attached to chemicals that

share common features with identified toxic substances. “Paper chemistry” and “paper toxicology” are

used most extensively to estimate properties of new

chemicals. 19 Unfortunately, not all chemicals within

a single structural class behave similarly; thus, limits

are placed on the use of these approaches.

New developments in laboratory testing has resulted

in the greater use of short-term (a few days to months)

tests. Test costs range from a few hundred dollars to

a few thousand. Such tests depend on measuring biological interactions between chemical and DNA. The

best known test, the “Ames test,” measures mutations

in bacteria. Other short-term tests use nonmammalian

laboratory animals, as well as cultured human and

animal cells. Some tests measure mutagenicity; others

measure either the capacity of a chemical to alter DNA

metabolism or to transform a normal cell into one with

abnormal growth characteristics. Problems in interpreting mutagenicity tests arise from the ease of doing them; the possibility of false-positive tests increases

with the number of tests that are done, and since negative tests frequently are not reported, there is some

danger of overrelying on positive test results. Further

complicating interpretation, a substance may test out

as a mutagen in one assay system and not in another.

A critical problem in estimating human health effects is the need to extrapolate results from studies involving large concentrations of chemicals to expected

results from exposure to low levels actually seen in the

environment. The idea of dose response (that the percentage of people suffering adverse effects will decrease

at lower exposures) is well accepted. However, the exact relationship between dose (exposure levels) and responses (numbers of affected people) is disputed. In

particular, some knowledgeable observers argue that

there are doses of chemicals so low that they will cause

19OTA, The Information Content of Premanufacture Notice, OTA-BPH-17, Government Printing Office, Washington, D. C.: 1983.

no disease. In other words, a threshold has to be exceeded before any adverse effects will be seen. In general, thresholds are better accepted for acute effects

than for chronic effects. In particular, if the interaction between a single molecule of a chemical and DNA

is sufficient to produce a mutation, no threshold value

is likely for mutagenic and carcinogenic effects.

The problems of extrapolation are more complex

when data from laboratory studies are the only available information. In those cases, a method must be

chosen to translate the meaning of a toxic effect in the

animal to an expected toxic effect in humans. Almost

everyone accepts that animal results are important to

predicting human effects; toxicology is based on that

premise. However, there can be endless arguments

about the applicability of a particular animal test.

A 1979 IARC report summarized the agency’s analysis of 354 chemicals and chemical processes that it

had reviewed in its program, which began in 1971.20

IARC found sufficient epidemiologic information to

evaluate carcinogenicity in humans for fewer than 100

chemicals. For 18 of those, IARC considered that the

evidence was sufficient to support a conclusion that

the chemical causes cancer in humans. For an additional 18, the evidence was sufficient to support a conclusion that the agent was a probable human carcinogen. In the cases of the remaining 318 chemicals

and chemical processes, the data from human studies

were insufficient to support a conclusion that the

substance or process is a human carcinogen or a probable human carcinogen.

IARC also reviews the worldwide literature about

the testing of chemicals for carcinogenicity in animals.

About animal tests, it says:

. . . in the absence of adequate data in humans it is

reasonable, for practical purposes, to regard chemicals

for which there is sufficient evidence of carcinogenicity (i.e., a causal association) in animals as if they

presented a carcinogenic risk for humans.

IARC has reviewed the literature about the testing

of 354 chemicals in animals. For 142 of those, IARC

considered that the animal evidence was “sufficient,”

and that those substances should be considered to pose

a carcinogenic risk for humans. In 1980, scientists at

the National Cancer Institute (NCI) reviewed all of the

cancer tests carried out in animals there.21 In the cases

where both IARC and NCI evaluated data about the

same chemicals, the results of the two organizations’

analysis were generally consistent .22

20Chemicals and Industrial Processes Associated With Cancer in Humans,

Monographs, Supplement 1, (Lyon, France: IARC, 1979).

~lR. A. Griesemer and C. Cuets, Jr., ‘Toward a Classification Scheme for

Degrees of Experimental Evidence for Carcinogenicity of Chemicals for Anireals, ” in Mokctdarand Cellular Aspects of C%ucinogen f%wming Tests, I-I.

Bartsh and L. Tomatis (eds. ), Lyon France, 1980.

‘lOTA, 1981, Op. cit.
4 7

Comparing the relatively small number of chemicals

for which human evidence is available to the larger

number of chemicals which has been tested in animals

illustrates the importance of animal tests. The number

of tested chemicals is much smaller than the number

of all chemicals, and there are major efforts underway

to use “short-term tests, ” most of which measure

mutagenicity to provide information about carcinogenicity.

The IARC review provides an example of scientists

and policymakers wrestling with the problems of extrapolating results of epidemiology and animal tests

about toxicity to estimates of human effects. Although

findings of IARC are not binding on governments,

they are generally accepted as authoritative and provide an example of a successful ongoing effort to

evaluate scientific evidence. A number of approaches

to evaluating evidence about carcinogenicity and other

toxicities for regulatory purposes, all of which involve

a centralized panel of experts to consider the toxicity

of substances, have been advanced by Government

agencies,

23 Members of Congress, and by trade associations. 24 A recent National Academy of Sciences

committee document argued against a central committee for making decisions about carcinogenicity for all

Government agencies, but urged that a central committee be formed and charged with developing

guidelines for making those decisions.25

To a major extent, the interest in expert review stems

from a desire to grapple with uncertainty. Uncertainties in estimating the hazards posed by chemicals result

from difficulties with test design and execution, the

scantiness of data, and methods for extrapolation. The

activities of an expert panel (e.g., IARC) to review data

and conclusions reduce the uncertainties in a few cases

involving carcinogenicity. In the absence of such expert review, the reader or scientist interested in toxicity must develop a critical eye, inspect and evaluate

the evidence presented by others, and discuss opinions

with other interested parties.

Health Effects Associated With

Love Canal Chemicals

Toxic effects associated with 18 chemicals known

to have been deposited in the canal landfill are listed

in table C-4. The minimum lethal doses for these

chemicals are much greater than environmental concentrations reported or expected within the EDA (see

tables C-5 and C-6). For example, maximum environmental concentrations of chlorobenzene were on

the order of 3 to 5 micrograms per cubic meter of air

(table C-6), an amount less than 1/1,000,000 the level

needed to kill the most sensitive laboratory animal

(table C-4).

Data for birth defects or reproductive effects (called

here “teratogenic effects”) are not available for most

of these compounds. Only pentachlorobenzene and

hexachlorobenzene were reported to have been tested

for teratogenicity. 26 Both were found to be positive in

at least one test, but the quality of the data was not

evaluated.

Mutagenic test results are reported on 12 of the substances, and of these, 8 were positive in at least one

test. In addition, additional mutagenicity tests are

planned for lindane and hexachlorobenzene.27 The

chemical 1,4-dichlorobenzene provides an example of

a chemical that was mutagenic in one test and not in

another. It has been shown to cause mutations in bacteria, but not in a test involving the use of Chinese

hamster ovary (CHO) cells. Nevertheless, whatever

caveats are attached to finding a positive response in

testing for a mutational effect, the finding serves to

warn of a possible hazard.

The fact that IARC found adequate animal data to

evaluate the carcinogenicity of five of the chemicals

listed in table C-4 indicates that there had been concern about the carcinogenicity of those chemicals. In

addition, five chemicals, including three of the IARCreviewed chemicals, are currently under test at the National Toxicology Program (NTP). In other words, 7

of the 18 Love Canal chemicals have been tested or

are being tested for carcinogenicity, This level of effort does not mean that many or most of the chemicals

are carcinogens, but it does mean that scientists have

expressed sufficient concern about them that tests are

necessary to provide more information.

For three of the five chemicals that IARC reviewed,

data were sufficient to conclude that the chemicals are

carcinogenic in laboratory animals. In the other two

cases, IARC reached the conclusion that there was

“limited” evidence rather than “sufficient” evidence to

support a conclusion that the chemicals were carcinogens.

‘~STp, “Identification, Characterization, arid Control of Potential Human

Carcinogens: A Framework for Federal Decision-Making,” J. Natioml Gncer

hstitute, 64:169-176, 1980.

Mmc I+oP~I hr a scie~ce panel (Searsda]e, N. Y.: AIHS, ~9W).

~~Natio~ R=mch Counci], Risk Assessment in tk k&ra] &vemment:

Managing the Process (Washington, D. C.: National Academy Press, 1983).

lb~e Department of Health and Human Services, Report of the %bcommittee on the Potential Health Effkts of Toxic Chemicals Dumps of the

DHEW Committee to Coordinate EnvkonmentaI and Related Programs,

undated.

27National Toxicology Program, National Toxicology Program: Fiscal Year

1983 Annual Plan, Research Triangle Park, N. C., 1982.
Table C-4.–Summary of Test Results Available on Health Effects of Chemicals Disposed

in Love Canal and Monitored by EPA

Regulation or standardd

Substance Minimum lethal dosea Mutagenicity b Carcinogenicity C ACGIH OSHA EPA

Lindane (gamma-hexachlorohexane) . . Ingestion, animal,

Chlorobenzene . . . . . .

1,2-Dichlorobenzene . .

1,3-Dichlorobenzene . .

1,4-Dichlorobenzene . .

1,2,3-Trichlorobenzene

1,2,4-Trichlorobenzene

1,3,5-Trichlorobenzene

180 mg/kg

. . . . . . . . . . . . . . Inhalation, animal,

15 g/m3

. . . . . . . . . . . . . . Inhalation, animal,

821 ppm

. . . . . . . . . . . . . . —

. . . . . . . . . . . . . . Man, 221 mg/kg

. . . . . . . . . . . . . . —

. . . . . . . . . . . . . . Ingestion, animal,

758 mg/kg

. . . . . . . . . . . . . . Implant, animal

LD50 20 mg/kg

1,2,3,4-Tetrachlorobenzene . . . . . . . . . . —

1,2,4,5-Tetrachlorobenzene . . . . . . . . . . Ingestion, animal,

Pentachlorobenzene f

Hexachlorobenzenef.

2-Chloronaphthalene

Alpha-Chlorotoluene.

2-Chlorotoluene. . . . .

3-Chlorotoluene. . . . .

4-Chlorotoluene. . . . .

2.4-Dichlorotoluene. .

1,035 mg/kg

. . . . . . . . . . . . . . . Ingestion, animal,

2,000 mg/kg

. . . . . . . . . . . . . . . Man, 220 mg/kg

. . . . . . . . . . . . . . . Ingestion, animal

888 mg/kg

. . . . . . . . . . . . . . . Ingestion, animal,

LD50 1,200 mg/kg

. . . . . . . . . . . . . . . Inhalation, animal,

175,000 ppm

. . . . . . . . . . . . . . . —

. . . . . . . . . . . . . . . —

. . . . . . . . . . . . . . . —

Cytogenic changes

to be tested (NTP)

negative (CCERP) —

Positive (CCERP)

Positive (CCERP)

Point mutagen,

negative, CHO

test (NTP)

Negative (CCERP)

Negative (CCERP)

Negative (CCERP)

Positive (CCERP)

Positive, CHO

(NTP)

Positive (CCERP)

to be tested (NTP)

—

Point mutagen

DNA replication

positive (CCERP)

Negative (CCERP)

Animal + (IARC)

Animal - (NCI)

Under test (NTP)

Animal ? (IARC)

Animal - (NTP)

Animal ? (IARC)

Under test (NTP)

—

Under test (NTP)

Animal + (IARC)

Animal + (IARC)

Under test (NTP)

Yes

Yes

Yes

—

Yes

—

Yes

—

—

—

—

—

—

Yes

Yes

—

—

—

Yes

Yes

Yes

—

Yes

—

—

—

—

—

—

—

—

Yes

Yes

—

—

—

National Drinking Water Standard

W.Q.C.e

W.Q.C.

W.Q.C.

W.Q.C.

W.Q.C.

W.Q.C. insufficient data

W.Q.C. insufficient data

W.Q.C. insufficient data

W.Q.C.

W.Q.C.

W.Q.C.

W.Q.C.

W.Q.C. insufficient data

—

—

—

—

aAll data in this column are from 1980 Registry of Toxic Effects of Chemicals SUbStances (NlOSH, 1982).

bReferences for data in this column are from NIOSH (1982) unless otherwise indicated: NTP is National Toxicology Program: Fiscal Year 1983 Annual Plan (NTP, 1982); and CCERP is Report of the Subcommittee

on the Potentia/ Health Effects of Toxic Chemica/ Dumps of the DHEW Committee to Coordinate Environmental and Related Programs (Department of Health and Human Services, undated).

The appearance of a test name means that the chemical was found to cause the named effect: cytogenic changes: microscopically visible chromosomal changes; point mutagen: chemical altered a specific

gene in the test organism, a standard test; CHO test: a test of the capacity to alter growth patterns of Chinese hamster ovary cells, a standard test; DNA replication: a test of the capacity to alter DNA replication,

a standard test; positive: CCERP reported that at least one test has shown the chemical is a mutagen; the quality of the data was not reviewed; and negative: CCERP reported that the chemical had been tested

and none of the results showed the chemical to be a mutagen; the quality of the data was not reviewed. CReferences: IARC is IARC Monographs Supplement 1 (IARC, 1979); NCl is R. A. Griesemer, and C. Cueto, Jr. in Molecular and Cellular Aspects of Carcinogen Screening Tests (IARC, 1980); and NTP is same as 

under (b). + means the agency judged the substance to be an animal carcinogen; ? means the evidence about carclnogenicity was limited; and – means the evidence was negative.

dAcronyms: ACGIH—American Council of Government lndustrial Hygienist, Osha-Occupational Safety and Health Administration, EPA—Envimnmental Protection Agency, IARC—lnternational Agency for Research

on Cancer, NCI—National Cancer Institute, and NTP—National Toxicology Program.

eW.Q.C.: Water Quality Criteria Document (45 F. R., 11/28/80). W.Q.C. means EPA recommended a standard; W.Q.C. insufficient data means that there were insufficient data to base a standard.

fAt least one test result indicates that this substance has teratogenic properties.
4 9

Table C-5.—Comparison of Regulated Exposure Limits to Detected Maximum Concentrations

in the EDA: Water

Ratio:

Regulated limit Maximum concentration found in EDAa maximum detected level/

Substance (exposure through ingestion) [concentration (medium)] standard

One substance regulated under National Drinking Water Standard:

Lindane . . . . . . . . . . . . . . . . . . 4.0 ppbb

5.3 ppb (sanitary sewer) 1.3

3.4 ppb (storm sewer) 0.85

Substances for which water quality criteria have been published:

Lindane . . . . . . . . . . . . . . . . . .

Chlorobenzene. . . . . . . . . . . .

1,2-Dichlorobenzene . . . . . . .

1,3-Dichlorobenzene . . . . . . .

1,4-Dichlorobenzene . . . . . . .

1,2,4,5-Tetrachlorobenzene. .

Hexachlorobenzene . . . . . . .

No safe limit (carcinogen)

1 0

-5 risk,

water and fish, 0.186 ppb 5.3 ppb (sanitary sewer)

3.4 ppb (storm sewer)

fish only, 0.625 ppb 5.3 ppb (sanitary sewer)

3.4 ppb (storm sewer)

488 ppb Tracec (shallow well)

400 ppb 15 ppb (deep well)

400 ppb 80 ppb (sump)

400 ppb 586 ppb (sump)

Water and fish, 38 ppb 62 ppb (storm sewer)

fish only, 48 ppb 62 ppb (storm sewer)

No safe limit (carcinogen)

1 0

-5 risk,

water and fish, 7.2 pptb

Trace (sump water, sanitary sewer)

fish only, 7.4 ppt Trace (sump water, sanitary sewer)

28.5

18.3

8.5

5.4

0.04

0.2

1.46

0.61

0.77

aMuch higher concentrations, sometimes in excess of 10,000 ppb, were found in surface water sediment near sewer outfalls and in sewer sediments. Those two con -

taminated media are to be cleaned up in the remediation process.

b

ppb: parts per billion, 1 μg of chemical/liter water; ppt: parts per trillion, 0.001 μg of chemical/liter water.

c

Trace: detectable, but not measurable concentrations.

SOURCE: From several published sources.

Table C-6.—Comparison of Regulated Exposure Limits to Detected Maximum Concentrations

in the EDA: Air

Maximum concentration Ratio:

Regulated exposure limita

found in EDA maximum detected level/

Substance (exposure through inhalation) [concentration (medium)] standard

Lindane . . . . . . . . . . . . . . . . . . . . . . . . . 500,000 μg/m3

0.098 μg/m3 (living area) <0.001

(OSHA, ACGIH)b

Chlorobenzene. . . . . . . . . . . . . . . . . . . 350,000 μg/m3

3.5 μg/m3 (basement)

(OSHA, ACGIH)

<0.001

1,2-Dichlorobenzene . . . . . . . . . . . . . . 300,000 μg/m3

68 μg/m3 (living area) <0.001

(OSHA, ACGIH)

1,4-Dichlorobenzene . .............450,000 μ/m3

25 μg/m3 (living area)

(OSHA, ACGIH)

<0.001

1,2,4-Trichlorobenzene . . . . . . . . . . . . 40,000 μg/m3 (ACGIH) Tracec (living area) <0.001

2-Chlorotoluene . . . . . . . . . . . . . . . . . . 250,000 μg/m3 (ACGIH) 8 μg/m3 (living area) <0.001

a

Limits are generally expressed in units of milligrams/cubic meter. To facilitate comparison of limits and maximum concentrations, limits are converted to units of

micrograms/m3 here.

bOSHA—Occupational Safety and Health Administration; ACGIH—American Council of Government Industrial Hygienists.

c

Trace: detectable, but not measurable concentrations.

SOURCE: From several published sources.

The National Cancer Institute’s (NCI) evaluation of it is an animal carcinogen. IARC concluded that linthe carcinogenicity of lindane differed from that of dane was a carcinogen.

IARC.28 Data from NCI did not support the idea that For 1,2-dichlorobenzene, IARC found that there was

only limited information about carcinogenicity. A subsequent test by NTP reveals that the substance does

2 1G r iesemer, op. cit. not cause cancer in either rats or mice. Therefore, ad-
50

ditional evidence has reduced the level of concern

about possible carcinogenic effects for that chemical.

A related chemical, l,4-dichlorobenzene is now under

test at NTP as is alpha-chlorotoluene. Data about the

carcinogenicity of chlorobenzene and pentachlorobenzene under test at NTP, have not been reviewed by

IARC.

Table C-4 also shows that workplace and environmental exposures to many of these chemicals are regulated. The Occupational Safety and Health Administration (OSHA) regulates workplace exposure, and

restrictions on workplace exposures have been recommended by a group of industrial health experts, the

American Conference of Government Industrial Hygienists (ACGIH). EPA has published water quality

criteria for 13 of the 18 chemicals. In addition, a National Drinking Water Standard regulates exposure to

lindane.

The data summarized in table C-4 show that the

chemicals deposited in the canal landfill include some

recognized as presenting hazards to human health. An

immediate objection to drawing any conclusions about

health effects from these chemicals at Love Canal

derives from EPA’s observations that the concentrations within the EDA were very low.

Comparison of Regulated Exposure Levels and

Environmental Concentrations

EPA has published National Drinking Water Standards for 16 inorganic chemicals, 6 pesticides (including

lindane), 1 group of organic chemicals, and total dissolved solids. As is shown on table C-5, the maximum

concentration of lindane found in one sample each

from sanitary sewers and storm sewers slightly exceeded that limit. It should be emphasized that while

this concentration is higher than the drinking water

standards, the water in both systems is not likely to

be ingested by humans.

Water quality criteria documents have been published for 64 chemicals to serve as guidelines for acceptable concentrations in drinking and fishing waters.

There was some emphasis on protecting against carcinogenic risks in the criteria documents, and, in keeping with the idea that there is no dose of a carcinogen

below which there is no risk, the Agency declared that

there was no safe limit for carcinogens. Instead, it calculated the amount of the substance, that if ingested

over the course of a lifetime, would cause an incremental risk of cancer equal to 1 case of cancer in 100,000

people. The magnitude of that risk can be judged by

comparison to the figure that about 20 percent of

Americans (or 20,000 out of every 100,000) die from

cancer. As is shown in table C-6, the maximum detected concentrations of lindane in sewers exceeded the

standards for water to be used for drinking or fishing.

The measured levels of 1,2- and 1,3-dichlorobenzene

and 1,2,4,5-tetrachlorobenzenes were less than the limits established by the water criteria documents. Only

1,2-dichlorobenzene, found at 0.04 of the recommended guideline, was detected in deep wells and likely would be associated with human ingestion. No numerical measurements were reported for chlorobenzene and hexachlorobenzene, and EPA claims that concentrations of those chemicals would be in the low ppb

range. If the concentrations are that low or lower, the

level of chlorobenzene would be below that recommended by EPA.

Hexachlorobenzene presents an analytical problem.

The water quality criteria document associates a 10-5

cancer risk with a 7 ppt concentration of hexachlorobenzene. However, that chemical cannot be

measured at concentrations lower than a few ppb.

Thus, hexachlorobenzene could be present in water

samples in the Love Canal study in concentrations up

to 1 ppb, 130 times the level associated with a 10-5

cancer risk. But such concentrations are possible in all

water; methods are not available to measure this chemical at 7 ppt. The fact that hexachlorobenzene was detected only in waters that humans do not drink or fish

means that opportunities for exposure are limited.

To summarize, measured concentrations of some

chemicals found in sewer and sump waters in the EDA

approached or exceeded levels recommended for

drinking and fishing waters. However the contaminated waters in the EDA are not likely to be consumed, and exposure through ingestion is unlikely.

OSHA or ACGIH or both have established limits

on workplace exposure to six of the chemicals. In the

workplace, concern is about exposure by inhalation

or through the skin. In the case of lindane, the exposure limit shown on table C-6, based on inhalation,

is to be further lowered if there is any chance of the

chemical reaching the worker’s skin. The workplace

exposure limits are based on consideration of acute

toxic effects and are designed to protect against

workers’ becoming ill soon after exposure. They are

not designed to protect against any chronic health

effect-cancer, birth defects, or mutations. Therefore,

it is no surprise that the maximum levels of airborne

contamination found in the EDA is much less than the

workplace limits. Although there is little reason to

believe that the workplace limits protect against

chronic health risks, the airborne concentrations at

Love Canal are much lower, and are as low as levels

detected in many areas of the country.

EPA can consider chronic health effects in setting

limits for air pollutants under the Clean Air Act. To
51

date, it has not published nor made public any consideration of possible regulations of the chemicals listed

in table C-6. Therefore, there are no standards or

guidelines to compare to the detected levels. EPA did

compare airborne concentrations of chemicals in the

Love Canal area to concentrations in cities around the

country, and there were no striking differences reported.

The Special Case of Dioxin

Dioxin (more precisely, 2,3,7,8-tetrachlorodibenzop-dioxin, or 2,3,7,8-TCDD, or TCDD) is one of the

most toxic substances. It is known to cause cancer in

laboratory animals, and it has been associated with

tumors in humans. The “buyout” of Times Beach,

Me., was based on the premise that dioxin present at

concentrations greater than 1 ppb in the soil presented

a health threat.

There is no Federal standard that restricts environmental exposure to dioxin. EPA has carried out an

assessment of the health risk posed by the presence of

dioxin in incinerators. The Agency concluded that

0.0004 micrograms/m3 of stack air, which would be

diluted 100,000-fold by the time it reached ground

level, where it might be inspired, would not “present

a public health hazard. ”29 The government of the Providence of Ontario has set a permissible limit for dioxin in air equal to 0.00003 micrograms/m 3

, which is

about 1/10 the level found by EPA in the incinerator

stacks. (An average person breathes about 20 m

3 of

air daily. Over a 70-year lifetime, a person breathing

the maximum limit permitted by Ontario would inhale 219 micrograms of dioxin. )

One of the surprises from Times Beach is the observation that dioxin is very stable in soil. The stability

is probably related to the fact that dioxin binds very

firmly to particles in the soil, and being bound protects it from degradation. It is so difficult to extract

dioxin from soil, that it may be that the chemical is

not removed from soil particles that are inhaled or ingested. If that is the case, soil-bound dioxin would pose

little threat to human health. NTP is currently conducting studies about the bioavailability of soil-bound

dioxin and expects to have results by the end of the

summer of 1983. It has already been reported that root

crops, such as carrots, that were grown in dioxin-containing soil did not take up appreciable quantities of

dioxin .30 The low levels found with the carrots might

have resulted from contaminated soil sticking to the

outside of the root.

29D. Barnes,U.S. EPA, personal communication, May 1983.

JOR Kimbrou~t, Center for Disese Contro], Atlanta, Ga., personal communication, May 1983.

EPA has been working on a water quality criteria

document for dioxin for some time, Although it is not

known what level the final document will recommend,

a draft suggested that dioxin levels should not exceed

1 part in 1016 parts of water. This very low concentration presents analytical difficulties. Although both

EPA and the Canadian Government have perfected

methods to measure low levels of dioxin in water, the

minimum detection level are now 100-fold higher,

about 1 part of dioxin in 1014 parts of water. In other

words, water with no detectable levels of dioxin might

harbor 100 times the concentration that may be recommended as a guideline to protect health. (See discussion above, also of hexachlorobenzene. )

EPA claims that it was able to detect 1 to 20 ppt

(0.001 to 0.020 ppb) dioxin in the samples taken at

Love Canal. OTA has serious reservations about the

intensity of sampling for dioxin, but laying those aside

for the moment, EPA reported dioxin in sumps in the

Love Canal homes and in storm sewers. The Agency

reported finding no dioxin in air, which is not surprising because it has not been reported in air except in

stack gases. And no dioxin was reported in waters.

The Ring 1 homes are not being considered for rehabitation, and the storm sewers are to be cleaned up as

part of the remediation effort. Therefore, the known

sources of exposure to dioxin are going to be eliminated.

OTA is concerned that few samples were analyzed

for dioxin in the EPA study. If the decision is made

to rehabitate the EDA, and, if, as part of that effort,

monitoring is carried out, dioxin should be included

as a monitored substance more frequently than it was

in the EPA study reported in 1982. It may be that there

are good reasons for the sketchy sampling carried out

earlier, but it would not reassure the public to sample

this important contaminant any less frequently than

other chemicals.

Studies of Health Effects in the

Love Canal Population

Although the habitation decision was based on consideration of the extent of chemical contamination in

the EDA, there are other data that also bear on the

question of health effects. Those data derive from

observations made on the population of people who

lived near the Canal. Love Canal, A Special Report

to the Governor and Legislature, in 1981 summarizes

evidence collected by New York Department of Health

officials until that time.31

Jl~sj~H, ~Ve Canal, a Special Report to the Governor and J%-

islature, 1981. See also, Love C&naL Public Health Thne Bomb, NYS/DOH,

1979.
52

Briefly, pregnant women who lived near the canal

were found to be at greater risk of suffering a miscarriage or of delivering a ‘low birth-weight baby.” More

focused research into the location of residences associated with these adverse effects revealed that the

women at greatest risk lived either on 99th Street,

directly adjacent to the canal, or in formerly wet areas

just east of the canal. The New York State analysis

of these data led to the conclusion that the frequency

of spontaneous abortion (miscarriage) reached a peak

in the 1960’s and early 1970’s. In addition, the percentage of children born with birth defects was larger

among those delivered by women who lived on 99th

Street or in formerly wet areas as compared to women

who lived beyond what is now the declaration area.

The excess of birth defects was not, however, statistically significant. (Neither the study of reduced birth

weight nor birth defects has been published in a peerreview scientific journal. )

Cancer rates of residents of the census tract in which

Love Canal is located have been compared to cancer

rates in other census tracts in Niagara Falls. The female

population around Love Canal was found to have experienced twice the number of respiratory cancers as

a control female population; the excess among men

was less, respiratory cancer among male Love Canal

census tract residents was 1.7 times that observed in

the control population. 32 Scientists differ in what importance to attach to excesses of cancer that are less

than 2, but most agree that a twofold excess, as was

seen for respiratory cancer in women, merits attention.

Further analysis showed that the incidence of respiratory cancer within the Love Canal census tract does

not vary with distance from the canal, which weakens

the argument that substances in the canal were associated with the excess cancers. The incidence of some

cancers, lymphoma, leukemia, and liver cancer among

men living in the Love Canal census tract was only

half that observed in the control areas. The incidence

of genital organ and urinary cancers among women

was lower among Love Canal area residents than

among women in other areas of Niagara Falls.

Any conclusions to be drawn from the study of cancer incidence around Love Canal are weakened by the

small number of cancers that occurred during the

period (1966-77) over which the study was conducted.

Furthermore, since cancers may develop years or decades after exposure, the study done by New York State

may have been too early to detect an effect, if there

is one. A better answer to whether or not living near

the canal is associated with higher cancer rates may

J~Janerich, et a]., “cancer Incidence in the Love Canal Area, ” science 212,

1981, pp. 1404-1407.

become available as more people who lived in the

canal area are located and studied.33

In May of 1983, the DHHS released a study of

chromosomal abnormalities in a small population of

people who had lived near the canal.34 The results of

that study were negative; that is, the frequency of

unusual chromosomes among the canal area residents

was no greater than the frequency found in a control

population. There are some problems with this study.

(There may never have been a study without some

problems. ) In particular, in the opinion of many scientists, a chromosomal abnormality caused by exposure

to toxic chemicals may be short lived and may be repaired over time. Therefore, since the exposures occurred years ago, there might be no discernible effect

from them now. Despite that reservation (so far as

OTA can determine, that reservation is based on technical opinion and not upon prolonged observation of

human populations) and other technical reservations,

the consensus is that the study does not show any

chromosomal abnormalities as a result of living near

Love Canal. This negative study provides evidence

that an earlier study, which detected a high frequency of chromosomal abnormalities among Love Canal

area residents might have been in error.

Also in May 1983, Beverly Paigen and coworkers

presented a paper at a meeting of the Society for

Pediatric Research.35 They compared health effects

observed in the population of people who had lived

in the EDA to effects observed in groups of people who

lived in control areas. They reported that low birthweight babies were more common among the EDA

population and that the average weights of babies born

there were lighter at each week of gestation. Furthermore, children born and raised (for at least 75 percent

of their lives to date) in the EDA were shorter than

children in the control areas, and the parents reported

that these children had more episodes of six different

medical complaints than control area children.

Paigen confirmed that low birth weights were confined to families who had lived in the formerly wet

parts of the declaration area.36 The medical complaints

in children were not restricted to families living in the

wet areas, but decreased with distance from the canal.

She thinks that the play of children might bring them

into closer contact with contaminated areas, and dis33C. WI. Heath, Jr. Assessment of Health Risks at Love Canal, presented

at the Fourth Annual Symposium on Environmental Epidemiology, Pittsburgh, Pa., May 1983.

sac, W. Heath, Jr., et al., A Study of Cytogenetic piitte171S h pemflS h“ving Near the Love Card Center for Disease Control, Atlanta, Ga., May 1983.

JSB pa~en, et al., Growth ~d Health in Children Livins Near a fizar~

ous Waste Site, presented at Society for Pediatric Research, May 1983.

S*B. paigen, Children’s Hospital, Oakland, Calif., personal communication, May 1983.
53

tance from the canal would decrease the frequency of

the children reaching such areas.

To accumulate the data in the paper was difficult.

The 220 births reported in the declaration area and the

697 in the control areas occurred over a 15-year interval. Analyzing such data requires careful attention to

detail, and reviewing the data and analysis requires

an opportunity to review details. At the present time,

the results presented by Paigen, et al., are being prepared for publication, and final evaluation of their

work must wait until the paper, with more detailed

descriptions of the study and data, is complete.

A major study of health effects is expected sometime

this fall. The NYS/DOH has located as many as possible of all the people who lived in the canal area since

the 1940’s.37 Those people were interviewed about their

health status, and the results of that study will provide important information about the health of former

residents of the Love Canal region, and current and

former residents of the EDA.

37N, Vianna, NYs/mI-1, personal communication, May 1983.

The completed studies are sufficient to show that

the Love Canal population has not experienced any

adverse health effects at rates more than twice those

experienced by control area populations. Spontaneous

abortions and low birth-weight babies were statistically more frequent among the populations in the Love

Canal region, and birth defects, although not statistically more frequent, were observed more often in

that population. The incidence of some cancers in the

area has been higher than in control areas; the incidence of other cancers has been lower.

As more data become available in the near future,

it may become possible to draw firmer conclusions

about the health impacts of living near Love Canal.

Unsatisfying as it is, the consensus of opinion probably

is that the studies of the Love Canal area population

have produced more leads to follow up than strong

conclusions about the safety of the EDA. Evidence is

more convincing that serious health effects were associated with living in the Love Canal homes.
Appendix D

Analysis of the EPA Data

Summary

OTA examined a subset (20 chemicals) of the EPA

monitoring data. Differences were noted in frequencies of detection for this subset between the emergency declaration area (EDA) and control areas. Four

chemicals (1,2- and 1,3-dichlorobenzene and 2- and

4-chlorotoluene) were found to be present in the EDA

at greater frequencies than the control areas. The differences were significant, but the concentrations were

low.

Statistical Analysis of

Indicator Substances

OTA disaggregated the Environmental Protection

Agency (EPA) monitoring data to allow an examination of a subset of “indicator substances, ” toxic

chemicals known to have been disposed in the canal

landfill, Twenty chemicals were identified for the OTA

analysis; only 16 of them had sufficient data. Frequencies of detection for the 16 substances were compared

between the EDA and control areas.’ The method of

analysis was the Mantel-Haertszel procedure. This procedure assumes similar patterns across those media

that contain one positive sample; if a chemical is found

in one medium in a region, it is assumed that the chemical may be found in the other media in the same

region. The finding of no detectable levels in both

regions has no effect on the assumptions.

The results of Mantel-Haenszel analysis are shown

in table D-5. The EDA was found to have a significantly higher frequency of positive detections than the control area for four chemicals: 1,2- and l,3-dichlorobenzene, 2- and 4-chlorotoluene. Table D-1 illustrates the

results for one compound, 1,2-dichlorobenzene. A

higher rate of positive samples was found in the EDA

and the difference is statistically significant. * The odds

of finding a positive sample in the EDA is 7.5 times

greater than that for the control areas. It should be

noted that no comparison can be made with six of the

submedia, as no control samples were analyzed. The

EPA data used in this analysis are presented in tables

D-2, D-3, and D-4. EPA found significant differences

for 2-chlorotoluene and 1,2-dichlorobenzene in air between EDA and control areas. It should be noted that

IL. A. Cupples, Boston University School of Public Health, report submitted to OTA, Industry, Technology, and Employment Program, May 19S3.

“Significant refers to a 90-percent confidence level or greater.

5 4

Table D-l.—Odds Ratioa and Detection Rates

for l,2-Dicholorobenzene

EDA V. Love Canal

control area v. control area

7.5 (.001) 4.2 (.05)

Medium EDA Control area

Shallow well. . . . . . . . . . . . . .

Deep well . . . . . . . . . . . . . . . .

Sump water . . . . . . . . . . . . . .

Surface water. . . . . . . . . . . . .

Drinking water . . . . . . . . . . . .

Storm sewer water . . . . . . . .

Sanitary sewer water . . . . . .

Soil . . . . . . . . . . . . . . . . . . . . .

Storm sewer sediment . . . . .

Surface water sediment . . . .

Living area air . . . . . . . . . . . .

Basement air . . . . . . . . . . . . .

Outdoor air. . . . . . . . . . . . . . .

Oatmeal . . . . . . . . . . . . . . . . .

Potatoes . . . . . . . . . . . . . . . . .

Crayfish . . . . . . . . . . . . . . . . .

Mice . . . . . . . . . . . . . . . . . . . .

Worms. . . . . . . . . . . . . . . . . . .

0.0b

47=

0.04

28

0.0

104

0.0

4

0.0

30

0.11

9

1.00

1

0.01

105

0.07

15

0.30

4

0.42

539

0.34

88

0.10

83

—

0

—

0

0.0

31

0.0

35

0.0

19

0.0

11

0.0

14

0.0

4

0.0

4

0.0

1—

0

0.0

9

—

0

0.0

4

0.10

30

—

0

—

0

—

0

—

o

0.0

9

0.0

32

0.0

5

a

The odds ratio (P-value) indicates the odds of observing a sample with

l,2-dicholorobenzene in one region compared to another.

b

Frequency of samples containing 1,2-dichlorobenzene.

c

Total number of samples analyzed.

SOURCE: Cupples, op. cit.

1,4-dichlorobenzene was found to be more frequently detected in the control areas than in the EDA. The

absence of significant differences for the other compounds may be due to inadequate sampling for controls and cannot be interpreted as strong evidence that

the EDA and controls are similar in levels of contamination. It should be noted that these same four chemicals were detected in leachate sludge obtained at the
55

c
Table D-3.—Detection (+) of Indicator Substance and Numbers of Samples Analyzed (n) for Environmental Media in the EDA

Environmental media end submediaa

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 18 17 18 19 20 21 22- -

+ /n +/n + /n + /n +/n + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n +/In + /n + /n + /n + /n + /n + /n

Gamma-BHC (Lindane) . . . . . . . . . . 12/47 3/29 19/105 1/3 3/31 4/7 1/1 7/109 0/0 6/13 0/0 4/4 2/292 0/84 0/79 0/0 0/0 0/31 0/0 0/0 0136 0/8

Chlorobenzene . . . . . . . . . . . . . 1/43 2/30 2/104 0/4 7/31 0/9 0/1 3/212 0/0 3/15 0/1 3/4 8/540 1/88 2/83 0/13 0/12 0/0 0/0 0/0 0/0 0/0

1,2-Dichlorobenzene. . . . . . . . . . . . . 0/47 1/28 0/104 0/4 0/30 1/9 1/1 1/105 0/0 1/15 0/0 2/4 227/539 29/86 8/83 0/0 0/0 0/31 0/0 0/0 0/35 0/19

1,3-Dichlorobenzene. . . . . . . . . . . . . 0/47 1/28 2/104 0/4 0/30 1/9 1/1 0/105 0/0 1/15 0/0 2/4 0/0 0/0 0/0 0/0 0/0 0/31 0/0 0/0 1/35 0/19

1,4-Dichlorobenzene. . . . . . . . . . . . . 0/47 1/28 12/104 0/4 0/30 1/9 0/1 1/105 0/0 1/15 0/0 2/4 81/539 14/86 1/83 0/0 0/0 0/31 0/0 0/0 0/35 0/19

1,2,3-Trichlorobenzene. . . . . . . . . . . 0/47 0/28 0/104 0/4 0/15 2/9 1/1 0/105 0/0 0/7 0/0 1/4 0/292 0/84 1/79 0/0 0/0 0/31 0/0 0/0 0/35 0/19

1,2,4-Trichlorobenzene. . .........0/47 0/28 O/1O4 0/4 0/30 3/9 1/1 0/105 0/0 6/15 0/0 2/4 6/292 0/84 1/79 0/0 0/0 0/31 0/0 0/0 0/35 4/19

1,3,5-Trichlorobenzene. . . . . . . . . . . 0/47 0/28 0/104 0/4 0/15 0/9 1/1 0/105 0/0 0/8 0/0 0/4 0/292 0/84 1/79 0/0 0/0 0/31 0/0 0/0 0/35 0/19

l,2,3,4-Tetrachlorobenzene . . . . . . . 0/47 0/28 O/1O4 0/4 0/15 2/9 1/1 0/105 0/0 3/6 0/0 2/4 15/292 3/84 0179 0/0 0/0 0/31 0/0 0/0 8/34 0/19

1,2,3,5-Tetrachlorobenzene . . . . . . . 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0

1,2,4,5-Tetrachlorobenzene . . . . . . . 0/47 0/28 O/1O4 0/4 0/15 2/9 1/1 O/1O5 010 1/6 0/0 0/3 0/0 0/0 0/0 0/0 0/0 0/31 0/0 0/0 0/34 0/19

Pentachlorobenzene . . . . . . . . . . . . 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 2/291 0/84 0/77 0/0 0/0 0/0 0/0 0/0 0/0 0/0

Hexachlorobenzene . ............0/47 0/28 1/104 0/4 0/30 0/9 1/1 O/1O4 0/0 1/15 0/0 2/4 0/292 0/84 0/78 0/0 0/0 1/31 0/0 0/0 0/35 0/19

2-Chloronaphthalein . ............0/47 0/28 0/104 0/4 0/30 0/9 1/1 O/1O5 0/0 0/15 0/0 1/4 0/0 0/0 0/0 0/0 0/0 0/31 0/0 0/0 0/35 0/19

a-chlorotoluene . . . . . . . . . . . . . . . . 0/43 0/31 0/90 0/0 0/31 0/9 0/1 0/213 0/0 0/6 1/1 0/4 0/0 0/0 0/0 0/13 0/12 0/0 0/0 0/0 0/0 0/0

2-Chlorotoluene . ...............0/43 1/30 0/90 0/0 0/31 1/8 0/0 0/213 0/0 0/6 0/0 2/4 141/541 14/86 12/83 0/13 0/12 0/0 0/0 0/0 0/0 0/0

3-Chlorotoluene . . . . . . . . . . . . . . . . 0/43 4/30 0/90 0/0 0/31 1/8 0/0 0/213 0/0 0/6 0/0 2/4 0/0 0/0 0/0 0/13 0/12 0/0 0/0 0/0 0/0 0/0

4-Chlorotoluene . . . . . . . . . . . . . . . . 0/43 1/30 0/90 0/0 0/31 1/8 0/0 0/213 0/0 0/6 0/0 2/4 69/541 12/86 7/83 0/13 0/12 0/0 0/0 0/0 0/0 0/0

2,4-Dichlorotoluene . . . . . . . . . . . . . 0/47 1/28 0/104 0/4 0/15 1/9 1/1 O/1O4 0/0 0/9 0/0 1/4 0/0 0/0 0/0 0/0 0/0 5/31 0/0 0/0 0/35 3/19

a,a,2,6-Tetrachlorotoluene. . . . . . . . 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0 0/0

Totals . . . . . . . . . . . . . . . . . . . . . 13/779 15/448 38/1,673 1/51 10/441 20/148 11/14 12/2,328 0/0 23/167 1/2 28/67 451/4,737 73/1,018 33/965 0/65 0/80 6/372 0/0 0/0 9/419 7/217

Detection frequencies (O/.) . . . . . . . 1.7 3.1 2.2 2.0 2.3 13.5 78.6 0.5 0 13.8 50.0 41.8 0.1 7.2 3.4 0 0 1.6 0 0 2.1 3.2

aWater soil: Sediment:

1) shallow well, 8) SoiI, 9) sump,

2) deep well, 10) storm sewer,

3) sump, 11) sanitary sewer,

4) surface, 12) surface water;

5) drinking,

6) storm sewer,

7) sanitary sewer;

SOURCE: US/EPA, Op. cit., vol. Ill.

Air. Biota:

13) living area, 16) oatmeal,

14) basement, 17) potatoes,

15) outdoor; and 18) crayfish,

19) dog,

20) maple,

21) mice,

22) worms.
Table D-4.—Detection (+) of Substances Not Found in Control Areas and Numbers of

Samples Analyzed (n) for Environmental Media in the EDA

Environmental media and submediaa

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

Indicator substance + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n + /n

2-Chlorophenol . . . . . . . . . . . . . . . . . . . 0/47 1/27 0/104 0/4 0/30 0/9 0/1 0/104 0/0 0/15 0/1 1/4 0/0 0/0 0/0 0/0 0/0 0/31 0/0 0/0 0/35 0/19

4-Chlorophenol . . . . . . . . . . . . . . . . . . . 1/35 3/24 2/92 0/4 0/15 0/5 0/1 0/71 0/0 0/15 0/1 0/4 0/0 0/0 0/0 0/0 0/0 0/31 0/0 0/0 0/35 0/19

2-Nitrophenol . . . . . . . . . . . . . . . . . . . . . 0/47 0/28 0/104 0/4 0/30 0/9 0/1 0/104 0/0 0/15 0/1 0/4 0/0 0/0 0/0 0/0 0/0 0/31 0/0 0/0 0/35 0/19

2,3,6-Trichlorophenol . . . . . . . . . . . . . . 0/36 0/24 0/92 0/4 0/15 0/5 0/1 0/71 0/0 0/5 0/1 0/4 0/0 0/0 0/0 0/0 0/0 0/31 0/0 0/0 0/35 0/19

4-Chloro-3-methylphenol. . . . . . . . . . . . 0/47 0/28 0/104 0/4 0/30 0/9 0/1 0/104 0/0 0/15 0/1 0/4 0/0 0/0 0/0 0/0 0/0 0/31 0/0 0/0 1/35 1/19

1,3,5-Trichlorobenzene . . . . . . . . . . . . . 0/47 0/28 0/104 0/4 0/15 0/9 1/1 0/105 0/0 0/6 1/1 0/4 0/292 0/84 1/79 0/0 0/0 0/31 0/0 0/0 0/35 0/1 9

Acenaphthylene. . .................2/47 2/28 1/104 0/4 0/30 0/9 0/1 2/105 0/0 0/15 0/1 0/4 0/0 0/0 0/0 0/0 0/0 0/31 0/0 0/0 0/35 0/19

Dibenzo (a,h) anthracene . . . . . . . . . . . 0/47 0/28 0/104 0/4 0/15 0/9 0/1 0/105 0/0 0/15 0/1 0/4 0/0 0/0 0/0 0/0 0/0 0/31 0/0 0/0 0/35 0/19

2,4,6-Trichloroaniline. . . . . . . . . . . . . . . 0/47 0/28 0/104 0/4 0/15 0/9 0/1 0/105 0/0 0/6 0/1 0/4 0/0 0/0 0/0 0/0 0/0 0/31 0/0 0/0 0/34 0/19

1,2,4,5-Tetrachlorobenzene. . . . . . . . . . 0/47 0/28 0/104 0/4 0/15 2/9 1/1 0/105 0/0 1/6 1/1 0/3 0/0 0/0 0/0 0/0 0/0 0/31 0/0 0/0 0/34 0/19

Acrylonitrile . . . . . . . . . . . . . . . . . . . . . . 0/43 0/31 0/104 0/4 0/31 0/9 0/1 0/213 0/0 0/6 0/1 0/4 0/0 0/0 0/0 0/13 0/12 0/0 0/0 0/0 0/0 0/0

1,1,2-Trichloroethane. . . . . . . . . . . . . . . 0/43 1/31 0/103 0/4 2/31 0/9 0/1 0/213 0/0 0/15 0/1 0/4 0/0 0/0 0/0 0/13 0/12 0/0 0/0 0/0 0/0 0/0

1,2-Dichloroethane . . . . . . . . . . . . . . . . 1/43 0/31 1/104 014 0/31 0/9 0/1 0/213 0/0 0/15 0/1 0/4 0/0 0/0 0/0 7/13 0/12 0/0 0/0 0/0 0/0 0/0

Totals . . . . . . . . . . . . . . . . . . . . . . . . . 4/576 7/364 4/1,327 0/52 2/303 2/109 2/13 2/1,618 0/0 1/149 2/13 1/51 0/292 0/84 1/79 7/39 0/36 0/310 0/0 0/0 1/348 1/190

Detection frequencies (o/o)

(Control = 0°/0) . . . . . . . . . . . . . . . . . 0.7 1.9 0.3 0 0.7 1.8 15.4 0.1 0 0.7 15.4 2.0 0 0 1.3 18.0 0 0 — — 0.3 0.5

aWater Soil: Sediment: Air. Biota:

1) shallow well, 8) soil, 9) sump, 13) living area, 16) oatmeal,

2) deep well, 10) storm sewer, 14) basement, 17) potatoes,

3) sump, 11) sanitary sewer, 15) outdoor; and 18) crayfish,

4) surface, 12) surface water; 19) dog,

5) drinking, 20) maple,

8) storm sewer, 21) mice,

7) sanitary sewer; 22) worms.

SOURCE: US/EPA, op. cit., vol. Ill.
58

Love Canal treatment facility in volumes approaching

1 percent of the total sludge volume.2

A finding that 4 out of 16 chemicals known to have

been disposed in the canal landfill calls into question

the EPA conclusion that EDA is not contaminated by

Love Canal chemicals except for sediments of storm

sewers and surface water sediments at sewer discharge

points. The discrepancy between the OTA and EPA

finding can be explained. EPA aggregated data for 150

compounds including 129 priority pollutants, the majority of which were not known to have been disposed

in the canal landfill. OTA focused on only those chemicals with a history of disposal.

The detection of four substances at higher frequencies in the EDA does not necessarily mean that these

substances originated in the canal landfill. Frequencies

of detection for 12 indicator substances were not significantly different and one had a greater frequency

of detection in the control areas. It is to be expected

that, at the 90-percent confidence level applied in these

statistical analyses, 10 percent of the statistical tests

showing significance might be in error. In this case,

this means that 1.6 (or really 2) of the 16 analyses

might be a result of chance. However, two or possibly

four of the significant differences could be real indications of contamination in the EDA as compared to the -

control areas.

Table D-5.—Summary of Mantel-Haenszel Results

EDA V. Love Canal

Indicator substance control area v. control area

Lindane . . . . . . . . . . . . . . . . . .

Chlorobenzene. . . . . . . . . . . .

1,2-Dichlorobenzene . . . . . . .

1,3-Dichlorobenzene . . . . . . .

1,4-Dichlorobenzene . . . . . . .

1,2,3-Trichlorobenzene . . . . .

1,2,4 -Trichlorobenzene . . . . .

1,3,5-Trichlorobenzene . . . . .

1,2,3,4-Tetrachlorobenzene. .

1,2,3,5-Tetrachlorobenzene. .

1,2,4,5-Tetrachlorobenzene. .

Pentachlorobenzene . . . . . . .

Hexachlorobenzene . . . . . . .

2-Chloronaphthalene. . . . . . .

0-Chlorotoluene . . . . . . . . . . .

2-Chlorotoluene . . . . . . . . . . .

3-Chlorotoluene . . . . . . . . . . .

4-Chlorotoluene . . . . . . . . . . .

2,4-Dichlorotoluene . . . . . . . .

a,a2,6-Tetrachlorotoluene . .

No

No

Yes

Yes

(a)

No

No—

No—

No

No

No

No

—

Yes

No

Yes

No

—

No

Yes

Yes

Yes

(a)

No

Yes

No

No—

No—

Yes

—

—

Yes

No

Yes

No

. . —

Yes: Significantly greater contamination in EDA (Love Canal).

No: No significant difference between areas.

—: Insufficient data.

(a): Control area shows significantly greater contamination.

SOURCE: Cupples, op. cit.

2U. S. Environmental Protection Agency, Analysis of the Love Canal Treatment Plant Sludge Sample, memo from W. L. Budde, J. W. Eichelberger,

P. Olynk to T. Hauser, Aug. 22, 1980.

o