Looking back at Love Canal EPA's former study director discusses the episode's history and the agency 's study m e t M
John Deegan, Jr.
University of Northern Iowa Cedar Falls, Iowa 50614 Since August 1978, when New York State health authorities and President' J i y Carter declared that a major chemical emergency existed at Love Canal (Niagara Falls, N.Y.),there have been numerous commentaries, conferences, documents, recriminations, and lawsuits. One of the principal documents is a three-volume report issued in 1982, which describes the results of a comprehensiveenvironmental monitoring program conducted by EPA at Love canal (I). The EPA report came under fire as soon as it was published. In 1982, Ellen
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K. Sibergeld, chief toxics scientist for the Environmental Defense Fund, raised concerns about the study's design and execution and about the samplmg site plan (2). In 1986, Michael R. Stol i and Richard J. Cook took issue with the statistical handling of the data (3,following the lead of earlier statistical criticism by Richard L. Andeman (4). Now that nearly a decade has passed since the Love Canal issue was f m t raised, it seems useful to consider dispassionately EPA's study and the data it developed.
The emergency's history Officials of the Hooker Chemicals and Plastics Corporation have acknowledged that from 1942 to 1953 the com-
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pany disposed of some 21,800 t of chemical wastes in a trench on a parcel of land the company f m t leased, and then purchased in 1947. The property (Figure 1) is in what was then a sparsely popnlated portion of the southeast corner of the city of Niagara Falls. It contains the remnants of a canal that was to supply power to a utopian indusaial community, called Model City, which was to have been built in the early 1890s by entrepreneur William T Love in what is now the town of Lewiston, N.Y. Love’s unfinished dreamthe legacy of which is the partially completed canal that bears his namewas to lure industry to Model City with economifal hydroelectric power generated by water diverted through the canal around Niagara Falls to the site of the planned community, where it would cascade down the Niagara escarpment. In part because of the harsh economic conditions of that period, only a small portion of Love’s canal was excavated. Shortly after Hooker closed its landfill in 1953, the Niagara Falls Board of Education acquired the property. To accommodate the increasing papulation of the area, the board built an elemen-
tary school, which opened in 1955, on State Commissioner of Health declared a centrally located portion of the land. a health emergency at Love Canal; on The building faced 99th Street, and was Aug. 7, Gov. Hugh Carey announced a adjacent to the waste burial site (pig- program to relocate residents of all 238 houses in Rings 1 and 2. The state was ures 1 and 2). The board sold the residual portion to buy theii homes at full replacement of the land not occupied by school value. Also on Aug. 7, President Carter isbuildings to private interests. By 1966, residential development had e l i t e d sued an executive order declaring that a all surface evidence of the earlier exca- man-made state of emergency existed vation; by 1972, virtually all of the 99 at Love Canal. The order, which was walled Ring 1 houses on 97th and the first executive order addressing a 99th Streets (their back yards faced the hazardous-waste problem, enabled the closed landfill) were completed (pig- federal government to provide technical and f m c i a l asqistance for the City ures 1 and 2). From the fall of 1975 through the of Niagara Falls to begin cleanup and spring of 1976, heavy precipitation re- containment of the site. By the end of sulted in an unusually high local 1979, nearly $20 million in local, state, groundwater condition. This, in turn, and federal funds had been spent on caused portions of the landfill to sub remediation, all nearby residents had side, created ponds of surface water been relocated, and public access to the heavily contaminated with chemicals, site (idenMied as the Canal Area in and transported chemical wastes to Figures 1 and 2) had been restricted. To nearby residences. During 1977 and date, approximately $100 million in 1978, New York State officials moni- public funds has been spent on site retored environmental contamination and mediation, resident relocation, and enassessed potential human health effects; vironmental and human health investitechnical assistance was provided by gations at Love Canal. On Dec. 20, 1979, after a year-long federal Officials. On Aue. 2, 1978. the New York investigation, the Department of Justice filed a civil lawsuit against Hooker, alleging that the company (and other corporate defendants) had caused or contributed to the creation of an “imminent and substantialendangerment [to public health and the environment]” and a nuisance at Love Canal. To gather additional evidence for the Department of Justice, EPA contracted for limited cytogenetic assemments of 36 current or former residents of the Love Canal area. The results of this pilot investigation, which documented an excess of chromosomal abnormalities and damage in the study group, were made public May 19, 1980. These results became the subject of considerable attention in the news media, caused great distress among the local citizens, and generated much controversy with regard to their validity and meaning. In response to these events, on May 21, 1980, the president declared, for the second time, a federal state of emergency at Love Canal. This declaration enabled the temporary relocation of some 800 additional families who lived close to the landfill. The directive given to EPA was to complete, within six months, a comprehensive environmental study at Love Canal for the purpose of determining the habitability of the area identified by the state-of-emergency order (the Declaration Area in Figure 2). This order directed EF’A to constitute a study team, design a monitoring study, reprogram and reallocate the financial resources needed to conduct the study, and identify and employ contracEnvimn. sci. Technol.. Vol. 21. No. 4,1987 329
tors who would collect and analyze environmental samples. Furthermore, before even beginning the study, EPA also had to overcome a testing boycott initiated by the Love Canal Homeowners Association. The agency was directed to ensure. the quality of the data acquired from various environmental media and analyzed by numerous laboratcries; to integrate, interpret, and report the data, and to assess, from an environmental perspective, the habitability of the area encompassed by the emergency declaration order. The remarkable aspect of this presidential mandate was that even though a study of the magnitude and complexity devised by EPA had never before been conducted (an environmental assessment of habitabiiity had, in fact, never been attempted by any federal agency), the entire task was to be accomplished withii six months.
Design considemtions The Love Canal studies were designed by EPA to comply with the presidential mandate as efficiently as p s i ble. In formulating them, EPA took several factors into account. First, the six-month deadliie, concern for public health and the environment, and political imperatives dictated that a comprehensive, integrated study be conducted. EPA detehned that the study would have to include a major hydrogeologic program that incorporated a multidimensional approach to allow for identification of potential mechanism of contaminant movement from the closed landfill into the surrounding environment. An extensive, cross-sectional, multimedia environmental monitoring study also was to be conducted to allow identification of the actual movement of Love Canal wastes into the Declaration Area. The results aao
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were to be integrated and compared with conditions in the ambient environment to determine the incremental contribution of contaminants from Love Canal to the Declaration Area. Second, the sampling design of the monitoring study was biased to concentrate sampling intensity within the Declaration Area and, within this area, to regions located closest to the canal and to known or suspected pathways of chemical migration. Through use of this design, the study would maximize the probability of detecting Love Canal-related contaminants in the Declaration Area and increase the likelihood of identifying preferential transport pathways through which contaminants may have migrated from the landfdl into the surrounding environment. Third, the results of the monitoring studies were to be integrated across m e dia so that the likelihood of detedng and identifying the presence of contaminants would be increased. This would also help to validate the existence of suspected transport pathways. The integration of monitoring studies compensates for the variability in analytical methods and for the variability in sampling locations and sampling intensity across media. Integration helps to assure the validity and completeness of findings, and to identify false negative and false positive results. Fourth, the monitoring studies were oriented toward specific substances found in Love Canal wastes, and a large number of those substances were monitored to present a full picture of the environmental contamination caused by Love Canal. Finally, the latest monitoring methods had to be used, the monitoring data had to be validated, and the quality of the data was to be fully documented. The presence or absence of a substance in a particular
sample was to be assessed in a manner that erred on the side of caution to provide the best assurance of protecting public health and the environment.
Implementation of the studies Before any remedial action began, it was recognized that there were a number of natural mechanism that may have contributed to the transport of contaminants directly from the landfill into the surrounding environment. These included air transport of vaporphase contaminants and contaminated particulate matter, surface water transport, and groundwater transport. After remedial action, air transport of contaminants probably was stopped by the placement of an extensive clay cap over the landfd (Figure 3). Similarly, surface water transport probably also was eliminated as a source of contamination, although residual near-surface soil contamination outside the area subjeci to remediation might have continued to serve as a relatively isolated source. Runoff of contaminated surface water and soil probably did not extend beyond Ring l (except perhaps through local sewer systems) because of the streets, drains, and storm sewers completely encircling the landfill. The groundwater transport of contaminants conceivably could have continued because of an ineffective containment system or because of the presence of contaminated groundwater that had migrated beyond the the containment system. Before a site is cleaned up, groundwater movement is a primary transporter of environmental contaminants. It also is a potential carrier of contaminants after remediation. Thus, EPA concentrated considerable effort and resources on conducting a comprehensive hydrogeological investigation of the Love Canal area.
As part of its hydrogeologic program, EPA reviewed all existing hydrogeological studies and previously collected data. The next task was a test drilling program to defme the geology of the sNdy area, to determine the occurrence of groundwater in the unconsolidated material and underlying hedrock, and to identify the direction and rate of movement of groundwater in the study area. A geophysical investigation used a variety of remote-sensing techniques, such as ground-penetrating and electromagnetic conductivity, to determine the location of groundwater sources and to locate permeahle soils (potential transport pathways) intersecting the landfill. These methods also helped to identify plumes of contaminants emanating from the canal, and they helped to locate suitable sites for monitoring wells. A model of groundwater movement in the area estimated vertical and horizontal groundwater velocities. It also estimated the distances contaminants could have traveled from the canal into the environment, and it aided the assessment of the remedial containment system's effectiveness (Figures 3 and 4). As part of its environmental monitoring program, EPA analyzed samples of Love Canal leachate. to compile a comprehensive list of substances present in the Love Canal wastes. From this list, approximately 133substances were targeted in water, soil, sediment, and biota samples, and 50 substances were targeted in air samples. Next, 174 wells were installed to sample groundwater. EF'A officials collected 6853 samples between August and October 1980. EPA validated analytical data obtained from 5708 of the 6853 samples collected by means of an extensive
quality assurance-quality control program. The program included the analysis of an additional 5743 samples. Selecting sampling sites Because of prior information concerning environmental contamination in the Canal Area, because of extensive remdiation at the site, and because of state-imposed legal restrictions, only relatively l i i t e d sampling was performed there. Within the Canal Area (outside the containment system, but inside the fenced compound), samples were collected at previously identified contaminated sites, at additional sites suspected of k i n g contaminated, in former swales (shallow depressions through which surface water drains preferentially), in sand lenses (sandy soil sediment deposits shaped like lenses). and in areas subiect to local flooding. Most of EPA's attention and resources were devoted to monitoring the occupied Declaration Area. Samples were collected at purposely selected sites to maximize the possibility of identifying transport pathways, and randomly, to ensure representative coverage of the entire area. procedures followed at the preselected sites, from which the majority of samples were taken, included. decreasing sampling frequency with increasing distance from the landfil, deliberate location of sampling sites in former swales and flood areas, and sampling in areas residents believed were contaminated. The agency's remaining resources were used to carry out a limited program of monitoring at selected control sites. The control sampling program was intentionally l i i t e d because of a number of factors, including EPA's desire for more intense sampling of the Declaration Area to maximize the like-
lihood of detecting the presence of contaminants from Love Canal. The hydrogeologic and monitoring studies designed and conducted by EPA cost $5.4 million, which covered only direct contract expenses for hydrogeologic work, field sampling, and analytical laboratory work. If EPA's internal costs are added, the total exceeds $8.5 million. By a variety of measures, the EPA Love Canal investigation represents the most comprehensive and most thoroughly documented environmental assessment program that had, as of 1982, ever been conducted.
Referem
John Deegan, Jr., is dean of the College of Social and Behavioral Sciences at the University of Northern Jowa. He sewed as project cwrdinaror for the 1980 EPA Love Canal environmental monitoring studies and was the primary author of a fhreevolume report published in 1982. This is thejirstpart of a two-part series. Environ. Sci. Technol., Vol. 21, No. 4, 1987 331
