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                                                                                                           Appendix A

Summary                                                    ernment institutions to remember, fund, and carry out
                                                           commitments for long-term continued monitoring and
   There are four areas of uncertainty that can affect     maintenance of the site. The full range of institutional
projections of the long-term integrity of the remedial     issues surrounding very long-term commitments for
technology. Before any decision on habitability can        managing uncontrolled hazardous waste sites under
be made, these uncertainties must be addressed and         the Superfund program have not been addressed. Cur-
solutions identified.                                      rent cost estimates for routine operation, maintenance,
   1. Remedial Action in the Emergency Declaration         and replacement of the leachate collection system are
Area (EDA).—The areas in the EDA contaminated              about $0.4 million now, $4.2 million in the year 2005,
with high levels of dioxin have not yet been cleaned       and $8.5 million in 2030. There is no guarantee that
up. Moreover, until just a few months ago storm            State officials 20 or 100 years from now will either
sewers leading from the canal region to the EDA and        remember or honor this commitment. Furthermore,
known to contain dioxin remained open. It is possi-        there are few institutional mechanisms in place to
ble that during the past few years—after completion        assure continuity in transferring vital information on
of the EPA monitoring study—dioxin may have been           Love Canal from one generation to the next. Nor does
transported within or beyond the EDA. A study to           it appear that New York State has taken unequivocal,
determine the full extent of contamination in and near     binding, and permanent title of the canal area in a
the sewers is not completed.                               manner that prevents future use of the site.
   2. Leak Detection Systems.—The long-term integri-
ty of the remedial technology is not certain. Reliable
methods are needed to allow detection of damage            Categories of Remedial Technology
(leading to permeability) to the two basic elements of        Technical options for remedial action implemented
the containment system. These elements, intended to        under the authority of the Comprehensive Environ-
minimize water entering the canal, are the cap over        mental Response, Compensation, and Liability Act of
the canal area and the concrete barrier wall to be built   1980 (CERCLA) can be categorized as either waste con-
around it. There is no dispute about the need for repair   trol or environment control. l Table A-1 lists the types
and replacement of the cap and leachate collection         of technologies in these two categories and illustrates
system over time. Yet how it will be done is not clear.    some of the advantages and disadvantages of each.
How structural damage or clogging of the drain system      The implementation of any of them will depend on
will be detected, and how repair and replacement can       site-specific conditions. In some situations, a combina-
be carried out safely remain unanswered.                   tion of waste and environment control strategies would
   3. Monitoring Programs.—Assurance of sufficient
                                                           be required.
warning about any potential migration and accumula-           Waste control refers to the removal of the hazard-
tion of chemicals from the canal is essential. Plans are   ous material from a site, followed by some treatment
underway for developing a long-term monitoring plan        that reduces the potential harm of hazardous com-
for ground water in the area immediately adjacent to       pounds and subsequent disposal of the waste or treat-
the canal but not in the EDA. It is also necessary to      ment residue in an appropriate facility. The treatment
design more extensive ambient monitoring of envir-         can involve destruction of toxic components of the ex-
onmental media other than ground water (e.g., air,         cavated material through chemical, physical or bio-
soil, and biota). Media other than ground water are        logical processes, or immobilization of the hazardous
possible routes of exposure to toxic chemicals. For ex-    components.
ample, depending on the properties of chemicals dis-          At present, the application of destruction techniques
posed in the canal and properties of the soil through      has been limited to excavated materials or small area
which the ground water moves, some chemicals could         spills treated by biodegradation and chemical proc-
be filtered out and could accumulate in soil or possibly   esses. Some thermal destruction technologies are avail-
in biota. Humans might become exposed to either. In
                                                           able. Thermal destruction of large volumes of contam-
addition, damage to the cap could allow release of         inated material, such as excavated soil, is a new ap-
volatile compounds into the air.                             1
   4. Institutional Mechanisms for Long-Term Protec-             Technologies and Management Strategies for Hazardous Waste Control,
                                                           “Chapter: Technologies for Hazardous Waste Management: Uncontrolled
tion of the EDA Residents. —The fourth major area          Sites” (Washington, D. C.: U.S. Congress, Office of Technology Assessment,
of uncertainty concerns the long-term ability of gov-      OTA-M-l96, March 1983).


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

Type                                               Advantages                                      Disadvantages
Waste control technologies
Excavation and removal followed                                              • High initial costs
                                               • Good for containerized or bulk disposal
  by treatment or disposal                                                     Potential higher risk during cleanup

                                                                             • Relocation of risk unless waste is
                                                                             . Not cost effective for low-level
                                                                                hazardous waste or uncontainerized
                                                                                buried waste in large area
Excavation with onsite treatment q Expose waste to complete treatment        q  High initial cost
                                                                             q  Difficult to assure monitoring
                                                                             q Some risk of exposure

                                                                             q  Not cost effective for large amount
                                                                                of low-hazard waste
Neutral ization/stabilization       Useful in areas where waste excavated q Limited application
                                    prior to mixing                          q  Requires long-term land use
                                    Low risk of exposure if injection method    regulations
                                    is used                                  q  Eventual off site migration if reaction
                                                                                is incomplete
Biodegradation                   q Low costs                                 q Difficult to maintain optimum

                                                                                conditions to keep reaction going
Solution mining                  . Useful in homogeneous uncontainerized     q Can result in uncontrolled release

                                    solvent-soluble, buried solid hazardous
Environmental control:
Isolation, containment, and                    q Useful for large volumes of mixed            . Effectiveness depends on physical
  encapsulation                                   hazardous and domestic waste and low-          conditions
                                                  hazard waste                                q Long-term O&M needed

Ground water diversion and                     q Useful if soils are permeable or if there    q Requires  wastewater treatment
  recovery                                        are high perched water tables                  option
                                                                                              q Process is slow

                                                                                              q O&M monitoring

                                                                                              q Not effective for insoluble or

                                                                                                 containerized material
Surface water diversion                        q   Easy to implement                          q   Can create flooding off site

                                               q   No transport of waste offsite

Ground and surface water                       q   Can be used onsite or offsite              q May generate hazardous sludges,
  treatment                                                                                      spent carbon
                                                                                              q Long-term  monitoring
Gas collection or venting                      q   Low costs                                  q Site safety and fire hazards
                                                                                              q Off site air pollution
                                                                                              q 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,                     thus, the risk to public health and the environment is
these technologies currently have not received wide-                        reduced.
spread consideration as a remedial technology.                                 These control technologies can be used effectively
   An alternative to destruction is the immobilization                      when the waste has been deposited in containers and
of hazardous components. This is achieved by encap-                         removal from the site can be accomplished readily. It
sulating the excavated material in some impermeable                         also can be implemented at those sites where hazard-
matrix. When placed in soil or marine environments,                         ous components have not become distributed through-
migration of hazardous constituents is then prevented                       out environmental media. For example, it is used at
(or at a minimum, the rate of migration is decreased);                      those sites where bulk disposal has occurred and before

widespread migration of the material within the soil                          tial transfer of risk from one area to another; for some
has taken place. However, if the contaminated area                            waste control options this transfer of risk is a major
is large, e.g., measured in several acres, waste con-                         consideration. Moreover the use of environment con-
trol techniques are difficult and costly to implement.                        trol technologies does not create risks for transporta-
   In the case of an accidental spill, removal and subse-                     tion accidents. Environment control, however, re-
quent treatment can be effective, if remedial action is                       quires long-term (i.e., forever) operation and
not delayed and boundaries of the spill can be iden-                          maintenance. In contrast, waste control includes
tified easily. Under appropriate site conditions, treat-                      treatments that completely destroy the hazardous ma-
ment techniques can be used without removal of the                            terial, eliminating long-term hazards. Both environ-
contaminated material, e.g., in situ biological or                            ment control and those waste control options that only
chemical degradation of soil contaminated through an                          immobilize hazardous components must include long-
accidental spill of hazardous chemicals.                                      term monitoring programs.
   Environment control options include those techni-                             A major concern associated with either type of
ques that contain or isolate hazardous material, divert                       remedial action is the limited experience with these
water movement away from a site, or treat contam-                             techniques. Sites using either waste or environment
inated water sources. A review of 23 landfill sites sug-                      control have not been in existence long enough to pro-
gests that environment control is the more common                             vide sufficient data about the long-term integrity of
remedial strategy currently in use.2 The technologies                         the methods. For example, a review of sites where en-
for containment are not new; rather they are adapted                          vironment control has been in place indicates that the
from structural or civil engineering procedures and                           “oldest site” has had a clay barrier wall (5-to 8-ft thick)
consist of the installation of caps, barrier walls, and                       only since 1976. Monitoring at this site has not yet

drainage systems. 3 4 At many sites, containment tech-                        indicated leakage through the wall. Remediation at the
nology is used in combination with water diversion                            oldest sites incorporating barrier systems using syn-
techniques. These latter include changing the flow of                         thetic materials (e.g., asphalt-bentonite, cement-
surface water to prevent flow into a contaminated site                        bentonite) were completed only in 1979. Thus, our

or removal and treatment of ground water that has                             experience regarding long-term integrity of contain-
been contaminated.                                                            ment technology is limited.
    Because the strategy of environment control does                             Uncertainties exist for waste control options, also.
not remove sources of contamination, it is necessary                          Unless the extent of contamination can be character-
to include safeguards that increase the likelihood of                         ized in detail, i.e., the types and concentrations of all
long-term integrity of containment and reduce effects                         constituents are known, complete destruction of haz-
of failure should it occur. Well-developed environmen-                        ardous elements cannot be validated. New constituents
tal monitoring programs are essential safeguards.                             could be formed as products of the biological, chemi-
Monitoring should include all environmental media:                            cal, or thermal processes taking place. These new con-
water, air, soil, and biota. Moreover, some sort of leak                      stituents could be as, or more hazardous than, the
detection system is necessary to warn of possible                             original compounds.
release of contaminants through the natural or syn-                              Much theoretical work has been done to predict the
thetic barriers of the containment structure.                                 performance of remedial technology. While the infor-
    When comparing these two categories of remedial                           mation gained through the use of theory and models
technology, advantages and limitations can be iden-                           is important, it must be emphasized that at present no
tified. For example, environment control offers certain                       field experience exists. The persistence of many waste
advantages over waste control in that large areas of                          constituents is much longer than the effective lifetime
contamination (e.g., many acres) can be controlled.                           of the environment control technologies; the degree
In addition, installation costs are generally less for en-                    of hazard for components in wastes may be increased
vironment control technologies than for waste control.                        by waste control treatments. Thus, environment con-
Environment control technologies eliminate the poten-                         trol may simply postpone risks to public health and
                                                                              the environment to future generations, and waste con-
                                                                              trol may create new hazards.
    E. Nagle, Environmental Law Institute, personal communication, April
    C. 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.
    P. A. Spooner, R. S. Wetzel, and W. E. Grube, “Pollution Migration Cut-
off Using Slurry Trench Construction, ” Management of Uncontrolled Haz-
ardous Waste Sites, Hazardous Materials Control Research institute, 1982,          Nagle, op. cit.
pp. 191-197.                                                                       Ibid.

Evaluation of Alternative Technologies                                     at points of natural migration routes from the
at Love Canal                                                              site—e.g., sand lens or drainage swales.
                                                                        4. Alternatives 1 and 2, plus complete containment
   In accordance with CERCLA requirements, EPA did                         of the contaminated area. Construction of a bar-
a cost-effectiveness analysis of alternative technologies                  rier wall that would completely enclose the site.
for remedial action at Love Canal. Their analysis con-               A summary of the lifecycle costs for these alternatives
sidered only environment control technologies. OTA                   is presented in table A-2. Although initially the costs
identified factors that are relevant to consideration of             are greatest for option 4, over a period of 50 to 200
waste control options:                                               years this alternative is expected to result in the lowest
   1. Given the large area of the landfill and adjacent              total cost to the State. As indicated in table A-3, each
      land, waste control technologies likely would be               alternative was also evaluated based on expected
      costly, possibly greater than environment con-                 performance. Alternative 4 provides the greatest
      trol by orders of magnitude. For example, ex-                  relative protection for public health and the
      cavating and treating 49 acres of contaminated                 environment.
     soil to a depth of possibly 15 ft (equal to nearly
     2 million tons of contaminated soil) would be a                         Table A-2.—Summary of Lifecycle Costs
     major and expensive task with current technolo-                           (present worth In 1981 dollars-1 x 10a)
     gies, particularly in water saturated zones.
  2. Workers as well as residents in the EDA would                                                  1 year 50 years 100 years 200 years
     be exposed to hazardous substances through the                  Alternative 1:
                                                                       Capital . . . . . . . . .                 —          —             —
     excavation process and formation of potentially
                                                                       O&M . . . . . . . . . . .     0.25     12.73      25.46        50.92
     hazardous products by operation of a waste treat-                  Replacement. . . .             —       1.04       7.29        20.19
     ment system.                                                         Total. . . . . . . . .     0.25     13.77      32.75        71.11
  3. Given the broad range of chemicals that were                    Alternative 2:
     originally dumped in the canal and the variety                    Capital . . . . . . . . .     0.61      0.61       0.61         0.61
     of products that could result from natural and                    O&M . . . . . . . . . . .     0.25     12.73      25.46        50.92
                                                                       Replacement. . . .              —       1.04       7.29        20.19
     enhanced degradation as well as thermal combus-
     tion processes, the outcome of destruction efforts                   Total. . . . . . . . .     0.86     14.38      33.36        71.72
                                                                     Alternative 3:
     is uncertain with present technology. Demonstra-                  Capital . . . . . . . . .     1.99      1.99       1.99          1.99
     tion studies would be required to evaluate the effi-              O&M . . . . . . . . . . .     0.20     10.09      20.17        40.34
     cacy of the waste control treatments. These                       Replacement. . . .              —       0.79       8.17        22.02
     studies would delay completion of remedial ac-                       Total. . . . . . . . .     2.19     12.87      30.33        64.35
     tion and possibly increase the risk to residents re-            Alternative 4:
     maining in the EDA.                                               Capital . . . . . . . . .     2.55      2.55       2.55         2.55
                                                                       O&M . . . . . . . . . . .     0.14      7.02      14.04        28.08
  4. The problem of finding an ultimate disposal site                  Replacement. . . .              —       1.49       1.49        21.35
     for treatment residue would be difficult to resolve                   Total. . . . . . . . .    2.69     11.06      18.08        51.98
     without knowing its hazardous quality. Disposal                 NOTE: Alternative     1—No        additional   action beyond   installa-
     of such residues in a new site could result in mere-                     tion of Ieachate collection system.
                                                                           Alternative 2—Utility cut-off containment.
     ly relocating health and environmental risks.                         Alternative 3—Partial slurry well containment.
  The environment control alternatives considered by                       Alternative 4—Complete slurry wall containment.

EPA included four altematives: 7                                     SOURCE: CH2M-Hill, op. cit.

  1. No additional action beyond operation and
     maintenance of a leachate collection system.                       When Congress included the requirement of
  2. Cut-off and plugging utility lines, in addition to              conducting cost-effective analyses in the Superfund
     alternative 1. All utility conduits that are possi-             legislation, the intent was that both waste and environ-
     ble routes for lateral movement from the site                   ment control alternatives would be considered. While
     would be plugged and all utility lines beyond the               it is apparent that alternative 4 is preferred over alter-
     containment areas would be cleaned.                             natives 1 through 3, OTA questions the omission of
  3. Alternatives 1 and 2, plus installation of a par-               some consideration for of any waste control technol-
     tial wall. A subsurface wall would be installed                 ogy in the cost-effectiveness analysis. As indicated
                                                                     above, present waste control technology cannot han-
                                                                     dle efficiently the large volumes of contaminated
 ‘CHJWfi”14 Immediate Remedial Action-Uncontrolled Hazardous Waste
=lSites, zone L pdiminarydraftnwort tbr U.S. EPA Region IZ April
                                                                     material that exist at the Love Canal site. Therefore,
                                                                     choosing environmental control options makes sense

     Table A-3.—Performance Criteria Evaluation                                 State Department of Environmental Conservation
                                                                                (NYS/DEC) follows a strategy of environment con-
                                                      R a n ka b c              trol. Two types of technologies are used: a leachate
Criterion                                         Alt. 1 Alt. 2 Alt. 3 Alt. 4   collection system, for which construction began in
Initial cost . . . . . . . . . . . . . . . . . .    1      2      3       4     1978; and a containment system, for which construc-
O&M cost . . . . . . . . . . . . . . . . . .        3      3      2       1     tion work was planned for June 1983. These technol-
Lifecycle cost . . . . . . . . . . . . . . .        3      4      2       1
Long-term environmental impact 4                           3      2       1     ogies are commonly used for remedial action.8 910
Short-term environmental impact                     1      2      3       4        The drainage system became operational in 1979 and
Construction site health and                                                    is to continue indefinitely with planned repair and
   safety . . . . . . . . . . . . . . . . . . . .   1      2      3             replacement. The system consists of a clay cap cover-
Community health and safety .                       4      3      2             ing the immediate area of the original landfill; a French
Technical reliability . . . . . . . . . .           1      2      2
System reliability . . . . . . . . . . . .          4      3       2            drain system rings the cap enclosing an area of approx-
Community acceptance . . . . . .                    4      3       2            imately 23 acres.
Construction duration . . . . . . . .               1      2       3               Ground water migrates through the site into the
Achieve objectives . . . . . . . . . . .            4      3      2             drainage system, is pumped into an onsite treatment
Meet project bid date . . . . . . . .               1      2      2
                                                                                facility, and put into clarification tanks where water
  Ranking ranges from “1” = best to "4" = worst. Equal rankings denoted by
equal low numbers.
                                                                                and sludge phases are separated. The average flow
    Alternative 1 . No additional action beyond Ieachate collection system.     through the system is 8 gallons per minute (gpm); the
   Alternative 2 - Utility cut-off containment.
   Alternative 3 - Partial slurry wall containment.                             maximum capacity is 200 gpm and peak flows of 48
   Alternative 4 . Complete slurry wall containment.
  No weighting factors have been applied to performance criteria
                                                                                gpm have been recorded during the wet Season, ll The
SOURCE: CH2M-Hill, op. cit.
                                                                                water phase is drawn through an activated carbon
                                                                                system and effluent discharged into the municipal
                                                                                sewage system.
as a short to medium term action, pending develop-
                                                                                   Effluent standards have been established by the City
ment of technology to deal permanently with the
                                                                                of Niagara Falls specifically for discharge of effluent
material. However, environment control cannot and
                                                                                from this facility. For every day that the treatment
should not be considered a long-term or permanent
                                                                                facility is operational, analyses are performed to deter-
                                                                                mine whether these standards are being met. Analyses
   Many people have cited the great uncertainty of as-
                                                                                include tests for the presence of priority pollutants (see
suring long-term protection using environment con-
                                                                                table A-4) determination of effluent pH levels (the ef-
trol technologies. No effective alternative has been ad-
                                                                                fluent is neutral), and analyses of levels of total organic
vanced. New York State officials are convinced that
                                                                                carbons (tests the efficiency of the activated carbon
greater efforts should be expended on research and
                                                                                system), and total chlorinated hydrocarbons. A review
development of detoxification and destruction techni-
                                                                                of available data on constituent levels within treated
ques thus, eliminating the need for long-term com-
                                                                                leachate indicates that the highest value recorded for
mitments to protection of a large land area. Once these
                                                                                any of the priority pollutants was 46 parts per billion
technologies have been developed, they must be given
serious consideration in any cost-effectiveness analyses                        (ppb). 12 Even this low concentration has been detected
                                                                                only occasionally; most results of the analyses indicate
for remedial technology. Although waste control op-
                                                                                no detection. State and city officials consider values
tions might be extremely costly to implement, it is
                                                                                in the ppb range to be sufficiently low because the ef-
possible that these would compare favorably with total
                                                                                fluent receives further treatment in the public waste-
costs over a 200-year time period for environment con-
                                                                                water treatment system. 13 Residues from the treatment
trol 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                              8
                                                                                     Spooner, Wetzel and Grube, op. cit.
to workers and residents due to excavation of the                                  *J. C. Evans and H. Fang “GeotechnicalAspects of tk De@ and Con-
                                                                                struction of Waste Containment Systems, ” Management of Uncontrolled
material.                                                                       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).
Control Action at the Love Canal Site                                             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.
   Because of the large area involved and environmen-                           12, 1980, pp. 2,914-2,924.
tal distribution of wastes disposed in the canal, the                             I+J. Kolak, New York State Department   of Environmental Con*rvation,
remedial action chosen by EPA and the New York                                  personal communication, March 1983.

                                                           Table A-4.—Priority Poiiutants

Volatile organic compounds                 1,2-Diphenylhydrazine                                                 Pesticides and PCBs
Acrolein                                   Fluoranthene                                                          Aldrin
Acrylonitrile                              4-Chlorophenyl phenyl ether                                           Dieldrin
Benzene                                    4-Bromophenyl phenyl ether                                            Chlordane
Carbontetrachloride                        Bis (2-chloroisopropyl) ether                                         4,4’-DDT
Chlorobenzene                              Bis (2-chioroethoxy) methane                                          4,4’-DDE
1,1-Dichloroethane                         Hexachlorobutadiene                                                   4,4’-DDD
1,2-Dichloroethane                         Hexachlorocyclopentadiene                                             a-Endosulfan
1,1,1-Trichloroethane                      Isophorone                                                            b-Endosulfan
1,1,2-Trichioroethane                      Naphthalene                                                           Endosulfan sulfate
1,1,2-2-Tetrachloroethane                  Nitrobenzene                                                          Endrin
Chloroethane                               N-nitrosodimethylamine                                                Endrin aldehyde
2-Chloroethylvinyl ether                   N-nitrosodiphenylamine                                                Heptachlor
Chloroform                                 N-nitrosodi-n-propylamine                                             Heptachlor epoxide
1,1-Dichloroethylene                       Butyl benzyl phthalate                                                a-BHC
1,2-Trans-dichioroethyiene                 Di-n-butyl phthalate                                                  b-BHC
1,2-Dichioropropane                        Di-n-octyl phthalate                                                  q-BHC
1,3-Dichioropropene                        Diethyl phthalate                                                     w-BHC
Ethylbenzene                               Dimethyl phthalate                                                    PCB-1242
Methylene chloride                         Benzo(a)anthracene                                                    PCB-1254
Methyl chloride                            Benzo(a)pyrene                                                        PCB-1221
Methyl bromide                             3,4-Benzofluoranthene                                                 PCB-1232
Bromoform                                  Benzo(k)fluorathene                                                   PCB-1248
Dichlorobromomethane                       Chrysene                                                              PCB-1260
Trichlorofluoromethane                     Acenaphthylene                                                        PCB-1016
Chlorodibromomethane                       Anthracene                                                            Toxaphene
Tetrachloroethylene                        Benzo(ghi)perylene                                                    2,3,7,8-Tetrachlorodibenzo-p-dioxin (TCDD)
Toluene                                    Fluorene                                                              Metals
Trichloroethylene                          Phenanthrene                                                          Antimony
Vinyl chloride                             Dibenzo(a,h)anthracene                                                Arsenic
Bis (chloromethyl) ether                   Ideno(l,2,3-cd)pyrene                                                 Beryllium
Base-neutral extractable organic compounds Pyrene                                                                Cadmium
Acenacphthene                              Bis (2-ethylhexyl) phthalate                                          Chromium
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                                                    Total cyanides
2,6-Dinitrotoluene                         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              water flow and the efficacy of the leachate collection system were essentially
Strategies hr Hazardous Waste Control, op. cit., pp. 172-173.                        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).

   The containment component of the remedial action                               drainage system should result in a decrease in
will involve the installation of a barrier wall around                            operation and maintenance costs for the State.
the canal, encompassing an area of approximately 49                               Also once the 49 acres are contained by the bar-
acres. 17 The wall will be constructed of concrete (a                             rier wall and surface covers, it is expected that
width of 24 inches) and will extend to a depth of about                           very little precipitation will infiltrate into the con-
15 ft to be anchored into clay found at that depth. This                          taminated area. The rate of flow through the
clay is very impermeable with hydraulic conductivity                              drainage and leachate collection system is ex-
(i.e., the rate at which water will move through the                              pected to decrease below the current average rate
strata) estimated to be in the range of 0.1 to 0.01 inches                        of 8 gpm.
per year.18 A synthetic membrane cap will be installed                         2. The wall provides further control against migra-
to cover the entire 49 acres, including the existing clay                         tion of contaminants from the canal into the res-
cap. This membrane will extend beyond the barrier                                 idential areas. Should problems develop with the
wall. Thus, it is expected that surface runoff will not                           leachate collection system at some time in the fu-
penetrate the enclosed area. Twelve inches of sterile                             ture, the barrier wall will serve as backup pro-
earthfill will be placed on top of the membrane cover;                            tection for EDA residents. Such protection, how-
6 inches of top soil will be the final cover. This top                            ever, is dependent on there being no undetected
soil will be grass seeded. All existing trees, shrubs, and                        damage to the wall or cap over time. While leach-
other plants will have been removed from the area                                 ate-collection system problems are being re-
prior to installation of the synthetic membrane cap.                              solved, the wall would postpone migration of
Only plants with a shallow root system can be allowed                             compounds.
to be grown within the 49-acre area. Long rooted                               3. The wall prevents migration of chemicals into the
plants would eventually penetrate the cap.                                        deep aquifer below the landfill. Results of a re-
   The exact placement of the barrier wall will be deter-                         cent modeling effort indicate a third advantage
mined using two sets of data: results obtained from                               to having a barrier wall.20 After the wall is in-
the 1980 Environmental Protection Agency’s (EPA)                                  stalled, a reversal of waterflow is expected be-
monitoring study and 1983 data on the extent of dioxin                            tween the shallow and deep aquifers, i.e., instead
contamination in soils immediately surrounding the                                of movement from shallow aquifer to deep aqui-
canal. * EPA has concluded that major contamination                               fer, the flow will be from deep aquifer to shallow
from Love Canal compounds does not extend beyond                                  aquifer. While some reversal may be occurring
the land immediately adjacent to the canal.**                                     due to operation of the collection system, the ex-
   According to Federal and State officials the wall will                         tent of the reversal should be greater with the
serve three purposes:19                                                           wall. If the model conclusions are correct, the
   1. The wall reduces the volume of water dawn into                              wall will provide the only real means for reduc-
       the leachate collection system. Based on results                           ing deep aquifer contamination.
       from the 1980 EPA monitoring study, officials                           NYS/DEC recognizes the need for continued moni-
       assume that the water outside the 49-acre perim-                     toring once the remedial action has been completed.
       eter is relatively clean—i.e., contaminants are                      Although not yet completed, a ground water monitor-
       present at concentrations of only parts per billion                  ing strategy is being planned. Because NYS/DEC con-
       or less. By including this clean water in the col-                   siders that all mobile compounds will be present in the
       lection system, the ongoing operation and                            ground water, no soil or air monitoring is planned.
       maintenance costs will be quite large (see table                     State officials consider that any chemicals bound to
       A-2, alternative 1). These costs must be covered                     the soil will not be mobile. The synthetic cap is ex-
       by State funds into the indefinite future. Reduc-                    pected to prevent volatilization, therefore air monitor-
       ing the volume of water that flows through the                       ing would not be necessary .21
                                                                               The EPA monitoring study identified chemicals in
      Specifications for the barrier wall at Love Canal are provided in
                                                                            sediment from both storm sewers and storm sewer
NYS/DEC, Love Canal fioject 1 Site Containment System, Niagara Falls,       discharge points in surface waters. Cleanup of the
New York, vol. 1, August 1982.                                              storm sewers within the canal area has been completed
   1~L. R. Silka and J. W. Mercer, “Evaluation of Remedial Actions for
Groundwater Contamination at Love Cam], New York,” Management of            and utility pipes were plugged in early 1983. Chain-
LJncontrolkd Muar&us Waste Sites, Hazardous Waste Control Research In-      link fences have been installed to discourage access to
stitute, 1982, pp. 159-164.
   q The new data on dioxin contamination were not available to OTA. They
are being collected by a contractor for NYS/DEC.
   q *See app. C for OTA’s analysis of the EPA conclusions.                   ‘OGeotrans, Inc., fioss+%wtional Simulations To Examine Proposed Wall
   I*R< ~wliW, U.S. EpA Region II, personal communication, March 1983;      at Love Canal, New York oral presentation given to OTA, May 12, 1983,
and N. Nosenchuck, NYS/DEC, personal communication, May 1983.                 ~ls~tments made by NYS/DEC during a meeting on May 19, 1981.

contaminated areas in Bergholtz and Blackfoot Creeks.                   sewer system, solely on the results of the 1980 monitor-
Disposal of the contaminated sewage sediment awaits                     ing study. The major concern was whether contamina-
permits from U.S. EPA. There are 375 drums of this                      tion observed in this area resulted from migration of
material being stored at the treatment facility. No ac-                 chemicals from the Love Canal landfill. Because the
tion has yet been taken for contaminated storm sewers                   EPA monitoring study indicated that the only portions
within the EDA.                                                         contaminated by Love Canal wastes (within the EDA)
   NYS/DEC initiated a monitoring study to determine                    were storm sewers and surface water sediments, no
the extent of contamination within the storm sewer                      large scale remedial action is planned.
systems located in the EDA. Chemicals of concern in                        According to NY officials, the actual extent of con-
this study include priority pollutants and dioxin. A                    tamination in the storm sewers has not been fully
total of 1,000 samples have been analyzed. The study                    deterrnined.24 A monitoring study is in progress and
results are not yet available.                                          once the data are available, a decision will be made
   Discussions with the Love Canal Area Revitaliza-                     about an appropriate method of cleanup. With the in-
tion Agency (LCARA) indicate that decisions on the                      stallation of the barrier wall and cover, future con-
future use of the properties within the EDA have not                    tamination of the EDA from Love Canal chemicals is
been made.22 The Agency plans to delay any such deci-                   not anticipated.
sions until the OTA review is released. An environ-                        Unfortunately, the 1980 monitoring data were not
mental impact assessment is required by State law                       sufficient to determine if hot spots of contamination
before any reuse of the EDA is allowed. LCARA has                       exist. Although data are recorded by subsection of the
begun the assessment process .23 Some sense of urgen-                   EDA, all values were averaged for the area as a whole.
cy is felt by the Agency to resolve the issue of                        If hot spots do exist and remain untreated, the area
habitability so that revitalization plans can be                        will continue to pose a threat to the health of the
developed. It should be noted that 100 residences                       residents.
within the EDA are currently occupied. A majority of
these (66 units in Griffon-Manor and Senior Citizen                     Leak Detection Systems
housing) are situated adjacent to the canal area.
                                                                           Any analysis of the effectiveness of the remedial ac-
                                                                        tion must include some consideration of the capabili-
Uncertainties Associated With                                           ty to detect failure at some time after the system is
the Remedial Action                                                     complete. A major limitation of environmental con-
                                                                        trol systems, however, is that there are few methods
   There are four areas of uncertainty that can affect                  to test their continued integrity. Any cracks that
projections of the long-term integrity of the remedial                  develop in the wall could serve as possible routes for
technology:                                                             migration of chemicals. If the leachate collection
   1. Remedial action in the EDA.                                       system is working properly, such cracks should not
   2. Leak detection systems for the barrier wall and                   pose a threat for outward migration of contaminants.
       leachate collection system.                                      If the system does not operate properly, however,
   3. Long-term monitoring programs.                                    pooling of ground water could occur near subsurface
   4. Institutional mechanisms for long-term protection                 structures. These could consist of rock formations
       of EDA residents.                                                within the area as well as the basement structures con-
While this brief OTA review cannot provide any sug-                     taining rubble from destroyed houses on land im-
gestions for reducing the impact that these uncertain-                  mediately adjacent to the canal. Subsurface barriers
ties may have, it is imperative that any decision of                    could impede downward movement of ground water
habitability consider them and their consequences for                   and facilitate lateral movement through breaks in the
continued protection of the residences in the EDA.                      wall.
                                                                           Officials at NYS/DEC estimate that a well-made
Remedial Action in the EDA                                              concrete wall should last for at least 50 years. Even
   Both EPA and NYS/DEC officials have based their                      if it lasts twice the expected lifetime, cracks can be ex-
analysis of the need (or lack thereof) for remedial ac-                 pected. The only means to detect these cracks would
tion in the EDA, beyond that required for the storm                     be a decrease in the water table elevations. The syn-
                                                                        thetic membrane cap has an estimated lifetime of 20

  ZZR. Morris, Umtjve Director, LCARA, Niagara Falls, N. Y., personal
communication, March 1983.                                                24J. Slack, NYS/DEC, personal communication, March 1983, restated at
  ~JStatments made by LCARA officials at a meeting on May 19, 1983.     a meeting on May 19, 1983.

years. Evaluation of water-table elevation data and                   term appropriations by the State of New York and fu-
changes in volume of leachate collected in the drainage               ture restrictions on the use of the canal property. Costs
system are the currently available methods of deter-                  for operation, maintenance, and replacement of the
mining the existence of damage.                                       wall, covers, and leachate collection system are high.
                                                                      For example, current expenditures for operation and
Monitoring Programs                                                   maintenance of the treatment facility is approximate-
                                                                      ly $0.4 million.27 Included within the lifecycle costs
   A final area of uncertainty concerns long-term mon-                presented in table A-2 are requirements for replace-
itoring strategies. The monitoring effort that is planned             ment of the following:
may not provide sufficient warning about migration                       • synthetic cover every 20 years,
and accumulation of chemicals outside the barrier                        . major equipment at the treatment facility every
wall. The State plan requires only a ground water                           20 years,
monitoring program. 25 It is presumed that all mobil-                    q treatment plant building every 50 years,
ized chemicals would eventually migrate into the                         q leachate collection system every 50 years.
shallow aquifer system within the barrier wall.                          Institutional and legal mechanisms are needed to
   While ground water monitoring is a necessary                       provide some assurance of a long-term commitment
safeguard for containment technology, it is possible                  to meet these costs. Although the current State ad-
to have contamination of soil and air before substan-                 ministration may be completely committed to provid-
tial levels of contaminants are detected in ground water              ing sufficient funds for maintenance of the remedial
samples. For example, if cracks develop in the cap,                   action, there are no guarantees that 10, 20, or 50 years
volatile compounds would be released to the air rather                from now the same commitment will hold. Because
than be transported through water. This situation ex-                 the remedial action chosen was environment control
isted when damage to the original cap occurred, and                   rather than waste control, the source of contamina-
noxious odors were apparent around the canal area.26                  tion will not be eliminated.
Also, those chemicals that have a strong affinity for                    It should be emphasized that the current problem
organic material can be filtered out of contaminated                  in Love Canal arose because the original use of the
water as it passes through soils high in organic com-                 canal was ignored or forgotten and improper use of
ponents; this property is typical of clays found in the                the land initiated. The original deed given by Hooker
vicinity of the canal. Thus, any migration of contam-                 Chemical Co. to the Niagara Falls Board of Education
inated water outside of the barrier wall could lead to                included statements about the hazardous nature of the
a build-up of such chemicals in the soil and perhaps                  contents of the canal .28 The Board chose to ignore these
be taken up by vegetation. However, at present no                     warnings and proceeded with construction of sewer
plans exist to do any surveillance monitoring of air,                 systems that cut through the canal wall and a school
soil, or biota.                                                       that damaged the cap.
   Such accumulation and uptake of these types of                        Without strong institutional mechanisms that will
chemicals, often compounds that are very persistent                   guarantee continued protection for the EDA, these
in the environment, would not be detected through                     original problems could reoccur 50 years from now,
ground water monitoring. It is likely that the absence                when the current actors in this unfortunate drama have
of chemicals in the ground water samples would be                     left the scene. At present the State has a temporary
interpreted as no contamination of the area surround-                 easement for an undetermined time, which provides
ing the canal when, in fact, contamination in soil and                some protection against improper use of the land.
biota could be present. It may be prudent for                         However, the canal property currently has three dif-
NYS/DEC to develop a monitoring strategy that ob-                     ferent owners: the southern region is owned by a
serves biotic changes in areas adjacent to and outside                 private citizen; the central section belongs to the Board
the barrier wall as well as analyzing soil and ground                  of Education; the northern portion is owned by the
water samples.                                                         City of Niagara Falls. If at any time in the future the
                                                                       State of New York relinquishes its temporary ease-
Institutional Mechanisms for Long-Term                                 ment, these owners will be free to utilize their proper-
Protection of EDA Residents                                            ty as they see fit. There are presently no strong legal
                                                                       or institutional mechanisms that will prevent resale and
    The first area of uncertainty surrounding the                      reuse of the land by the current owners.
planned remedial action concerns the need for long-
------ — ----- .—                                                                   -—
  J. Slack, NYS/DEC, personal communication, March 1983.
  25                                                                  —
                                                                                             personal communication, April 1983.
                                                                          z7N, ‘Koiack, NYs/DEc,
  Statements made by State officials during a meeting with NYS/DEC,     “E. Zuesse, “Love Canal, the Truth Seeps Out,” Reason, February 1981,
NYS/DOH, NYS/DOL, and LCARA on May 19, 1983.                          pp. 16-33.

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