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Appendixes Appendix A Remediation 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). 21 22 — 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 q • 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 q Expose waste to complete treatment q High initial cost q Difficult to assure monitoring effectiveness 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 waste 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 23 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 5 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 6 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- 2 trol may create new hazards. E. Nagle, Environmental Law Institute, personal communication, April 1983. 3 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. 4 P. A. Spooner, R. S. Wetzel, and W. E. Grube, “Pollution Migration Cut- off Using Slurry Trench Construction, ” Management of Uncontrolled Haz- 5 ardous Waste Sites, Hazardous Materials Control Research institute, 1982, Nagle, op. cit. 6 pp. 191-197. Ibid. 24 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 25 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 a 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 b 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 c 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- solution. 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. 26 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 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 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). 27 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 17 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. 28 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. 29 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, 26 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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