£ United States
^M^2 Environmental Protection Agency

LOVE CANAL
EMERGENCY
DECLARATION AREA
HABITABILITY STUDY
FINAL REPORT
    VOLUME I
    Introduction and
    Decision-Making
    Documentation
TECHNICAL REVIEW COMMITTEE
U.S. Environmental Protection Agency Region II
U.S. Department of Health and Human Services/
Centers for Disease Control
New York State Department of Health
New York State Department of Environmental Conservation

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VOLUME I

Introduction and
Decision-Making
Documentation
Prepared for
U.S. EPA REGION II
26 Federal Plaza
New York, New York 10278
Prepared by
ICAIR, LIFE SYSTEMS, Inc.
24755 Highpoint Road
Cleveland, Ohio 44122
Under Contract No. 68-01-7331
and

CH2M HILL SOUTHEAST,  Inc.
P.O. Box 4400
Reston, Virginia  22090
Under Contract No. 68-01-7251
May 1988

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                      CONTENTS



Section                                              Page

          ACKNOWLEDGEMENTS                        vi

          LIST OF ACRONYMS AND ABBREVIATIONS     vii

  1.0      INTRODUCTION                              1-1
          1.1  Early History of the Love Canal Site            1-1
          1.2  Environmental Contamination and Human
              Health Concerns                            1-3
          1.3  Remedial Activities at the Site                 1-5
          1.4  The 1982 Department of Health and Human
              Services Habitability Recommendation          1-8
          1.5  The 1983 Office of Technology Assessment
              Response                                1-10
          1.6  Formation of the TRC                      1-11

  2.0      THE HABITABILITY ASSESSMENT PROCESS     2-1
          2.1  The Role of the TRC                         2-1
          2.2  Development of the Habitability Criteria         2-2
          2.3  Implementation of the Habitability Criteria        2-6
          2.4  Public Participation                        2-10
          2.5  Summary                                2-11

  3.0      FUNDAMENTAL CONCEPTS AND OBJECTIVES   3-1
          3.1  Definition of Habitability                     3-1
          3.2  Consideration of "Background" Chemicals        3-2
          3.3  Evaluation by Residences and Neighborhoods     3-3
          3.4  Summary                                 3-4

  4.0      SELECTION OF THE BASIC APPROACH TO
          EVALUATE HABITABILITY                    4-1
          4.1  Application of Relevant Standards, Criteria,
              or Guidelines                              4-1
          4.2  Derivation of New Guidelines                 4-1
          4.3  Risk Assessment                            4-2
          4.4  Health Studies                             4-3
          4.5  Time Trends in Pollution Levels               4-4
                            HI

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                    CONTENTS
                       (continued)
        4.6 Comparison of the Love Canal Facility to
           State-of-the-Art Facilities                    4-5
        4.7 Comparison of the EDA to Inhabited Urban
           Areas                                  4-5
        4.8 Summary of Approach Selected               4-6

5.0      APPLICATION OF RELEVANT STANDARDS,
        CRITERIA, OR GUIDELINES                   5-1
        5.1 Air                                    5-1
        5.2 Water                                  5-2
        5.3 Soil                                    5-2
        5.4 Summary                               5-3

6.0      IMPLEMENTATION OF THE COMPARATIVE
        APPROACH                                 6-1
        6.1 Selection of Environmental Media for
           Comparison                              6-1
        6.2 Selection of Comparison Chemicals            6-3
        6.3 Selection of Comparison Areas              6-13
        6.4 Selection of Neighborhood Boundaries        6-20

7.0      SAMPLING AND ANALYSIS PLAN             7-1

        REFERENCES                               R-l
                          IV

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                        CONTENTS
                            (continued)
Tables

  1-1      Representatives of TRC Agencies                   1-12

  6-1      Chemicals Likely to Have Been Deposited at
           Love Canal                                       6-9

  6-2      Love Canal Chemicals Excluded as Indicator
           Chemicals                                       6-10

  6-3      Evaluation of Chemicals Based on Detection and
           Gradient Criteria                                 6-11

  6-4      Alternative Modifications to Soil LCIC Compar-
           ison Procedure                                   6-19

Figures

  1 -1      Location of Love Canal and the EDA                 1-2

  1 -2      Map of the EDA and Rings I and II                   1 -4

  1-3      Timeline of Love Canal Remediation Activities        1-6

  2-1      Timeline of Love Canal Habitability Study
           Activities                                       2-13

  6-1      LCIC Selection Process                            6-8

  6-2      Map of Waste Sites and Comparison Areas in
           Niagara and Erie Counties                         6-21

  6-3      Map of Neighborhood Boundaries in the EDA        6-22

  6-4      Map of EDA Sampling Areas                       6-24

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               ACKNOWLEDGEMENTS
The authors would like to acknowledge the efforts of all organizations and
individuals who assisted in the conceptualization, design, and implementa-
tion of this study.  Special acknowledgement goes to the U.S. Environmen-
tal Protection Agency Region II and the other members of the Technical
Review Committee and their staffs for their continuing guidance.
                              VI

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     LIST OF ACRONYMS AND ABBREVIATIONS

AALs       Acceptable Ambient Levels
ACGIH      American Conference of Governmental Industrial Hygienists
CDC        Centers for Disease Control
DHHS       U.S. Department of Health and Human Services
EDA        Emergency Declaration Area
EPA        U.S. Environmental Protection Agency
GC/MS      Gas Chromatograph/Mass Spectrometer
LCIC       Love Canal Indicator Chemical
NBS        National Bureau of Standards
NYSDEC    New York State Department of Environmental Conservation
NYSDOH    New York State Department of Health
OTA        U.S. Congressional Office of Technology Assessment
ppb         Parts Per Billion
TAGA       Trace Atmospheric Gas Analyzer
TCDD       2,3,7,8-Tetrachlorodibenzo-p-dioxin
TLVs       Threshold Limit Values
TRC        Technical Review Committee
                            Vll

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                  1.0 INTRODUCTION
This report is Volume I of a five-volume series. The objective of this report
is to describe the main elements and key decision points in the Habitability
Study of the Emergency Declaration Area (EDA) near the Love Canal Su-
perfund site  and to summarize the logic and  rationale supporting the
decisions made in the study.  Most of this information has been documented
in written reports from the Love Canal Technical Review Committee (TRC)
and its contractors and has been presented and discussed at many public meet-
ings. However, because this information is scattered among so many sour-
ces, trying to gain familiarity with the study and its logical basis from these
sources would be a complex and time-consuming process. Thus, this report
organizes and consolidates the key information needed to answer the ques-
tions "What was done, and why?"

This report is organized by subject matter and key decision point. The docu-
ment does not trace the evolution of a concept or the strict chronology of
each decision, unless this background is important to understanding the final
decision. Rather, emphasis is placed on the final decision that was made and
the rationale and logic supporting that decision. The presentation of infor-
mation proceeds from  general concepts and decisions to detailed issues re-
quired to implement the Habitability Study. Following the discussion of each
major subject, a list of pertinent references is provided. References are coded
by index numbers or acronyms, and these are defined in the back of the docu-
ment in the References section.

Volumes II and HI of this series present the results of the assessment for in-
dicator chemicals for air and soil, respectively. Volume IV reports on the
soil  assessment  for  2,3,7,8-tetrachlorodibenzo-p-dioxin  (TCDD),  and
Volume V summarizes the subsequent peer review of Volumes II, HI, and
IV and the responses to the peer review.
1.1 EARLY HISTORY OF THE LOVE CANAL SITE

Love Canal is a landfill site located in the southeastern corner of Niagara
Falls, New York (Figure 1-1). Excavation of the Canal was begun in the late
1800s, with the aim of providing cheap, direct-current hydroelectric power
                               1-1

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                                                         CHEEKTOWAGA
Scale: 1" = 3 Miles
(Approx.)
                                                Figure 1-1
                                                LOCATION OF
                                                LOVE CANAL AND THE EDA
                                1-2

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 for proposed industrial facilities along its banks. However, the development
of alternating current eliminated the need for industrial sites to be located
close to power sources, so the partially dug Canal was abandoned, leaving a
channel approximately 3,200 feet long and 80 feet wide. The exact depth of
the original  Canal is uncertain, but anecdotal information and current
geophysical studies indicate the excavation was approximately 7 to 16 feet
below grade.

From 1942 to 1953, the excavation became a chemical disposal site for the
Hooker Electrochemical Company (now a subsidiary of Occidental Chemi-
cal Corporation). Hooker obtained title to the Canal in 1947 and sold the
dump site to the Niagara Falls School Board in 1953 with a deed disclaim-
ing responsibility for any injuries that might result from the buried waste.
The City of Niagara Falls disposed of municipal wastes at the site from 1953
to 1954, after which time dumping ceased and the site was covered. Home
building in the vicinity of the Canal accelerated, and the school board built
a school on 99th Street near the middle portion of the site.

Referencesfor Section 1.1: 25 (Section 1.3), 27,44,45 (pp. 4-8), 64,86 (Ap-
pendix 1)
1.2 ENVIRONMENTAL CONTAMINATION AND
    HUMAN HEALTH CONCERNS

During the years that followed, residents near the old Canal site began to
complain of chemical odors, surface contamination, and injury to children
and pets. By the mid-1970s there was increasing evidence that chemicals
were leaking from the landfill, and analysis of sump samples in 1978 revealed
significant levels of chemicals in eight homes abutting the Canal. Because
of concern that these chemicals might pose a human health risk to some resi-
dents, most of the homes closest to the Canal (termed Rings I and II, as shown
in Figure 1-2) were purchased from the residents on a voluntary basis in 1978.
Subsequently, most of these homes were demolished, and a fence was erected
around the perimeter of Ring II to enclose and restrict access to the site.

Concern remained, however, over health risks to residents beyond Ring II,
and in 1980 President Carter determined that".. .the adverse impact of chemi-
cal  wastes in the Love Canal  waste landfill...is of sufficient severity and
magnitude to warrant  an emergency declaration...."   This declaration
                               1-3

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               VICINITY MAP

SOURCE:
EDA BOUNDARIES TAKEN FROM NEW YORK STATE
REAL PROPERTY TAX LAW ARTICLE 17,  SECTION 1702
Figure  1-2
MAP OF  THE  EDA AND RINGS  I &  II
Niagara Falls,  New  York
SCALE: 1"=750'
LEGEND
•——• EMERGENCY DECLARATION AREA (EDA) BOUNDARY
                                                 1-4

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followed release of a preliminary study that indicated some Love Canal resi-
dents may have suffered chromosomal damage because of exposure to toxic
chemicals (a study that was later discredited). The area affected by the dec-
laration was termed the "Emergency Declaration Area," and the boundaries
were established as shown in Figure 1-2. Contained within these boundaries
were about 650 private residential properties and about 300 public housing
units. The Love Canal Area Revitalization Agency was established by the
New York State Legislature and authorized to purchase the property of EDA
residents who chose to relocate from the EDA.

References for Section 1.2: 16,  36, 40,41, 42,44 (pp. 6-11), 45 (pp. 8-16),
49, 51, 52, 56, 57, 58, 64, 65, 66, 67,110, lll.PR-4 (Sect. 2.13.3)
1.3  REMEDIAL ACTIVITIES AT THE SITE

In October 1978, a program for the remediation of the Love Canal was in-
itiated to reduce the environmental impact and potential health hazards as-
sociated with the chemicals in the dump site. Figure 1-3 summarizes the
chronological relationship between the main elements of the remedial ac-
tivities and other important events at Love Canal.

Remediation has progressed in three phases. Phase I activities took place
from October 1978 to November 1979. The 99th Street School was closed,
and more than 230 homes on 97th and 99th Streets adjacent to the Canal
(Rings I and II) were purchased by the Government.  The area encompass-
ing the Love Canal, Ring  I and Ring n  south of Colvin Boulevard was
enclosed by an 8-foot-high cyclone fence and posted to limit access.  The
99th Street School as  well as  the homes  within the fence  were later
demolished.

Phase I engineering work focused on containing the contaminants present at
the site and limiting further discharges to the ground water, the surface water,
or the atmosphere. To accomplish this, a barrier drain system was installed
around the site to collect contaminated leachate. The leachate is pumped to
a permanent, onsite treatment plant, which began operation in 1979. Treat-
ment consists first of removal of the settleable solids and immiscible liquids,
followed by filtration of suspended solids, and then by removal of organic
contaminants from the aqueous phase in granular activated c arbon filters.
                                1-5

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Remediation Activities
EPA/NYSDOH/NYSOEC Meet on Remedial
Action Plan
First State ol Emergency Declared

Phase 1 Remediation Activities
Rings 1 and II Evacuated and Enclosed
Barrier Drain Installed
Clay Cap Installed

Second State ol Emergency Declared
•X*XvX*X*X*X*I'X*X*X*X*XvX*X"X*X
PhssG II Remediation Activities
Sewers Within Ring II Cleaned and Plugged
Extended Cap Installed


Perimeter Survey and Long-term Monitoring
Program
Sewers Outside ot Ring II Cleaned
Remediation of Black & Bergholtz Creeks
Thermal Destruction ol Sediments
1978
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                                                                                  Figure 1-3
                                                                                  TIMELINE OF LOVE CANAL
                                                                                  REMEDIATION ACTIVITIES

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The effluent, which is monitored each operating day, is discharged to the
sanitary sewer system in accordance with the sewer use ordinance of the City
of Niagara Falls.

In addition, the landfill was covered with a 3-foot-thick compacted clay cap
to reduce infiltration of water from rain and snowmelt and to retard the for-
mation of leachate and contaminated surface runoff.  The cap also limits
direct contact with the underlying contaminated soil as well as release of
volatiles and contaminated fugitive dust from the surface.

Phase II remediation work was designed to enhance the effectiveness of the
Phase I measures and was carried out from  December 1982 to December
1984.  To further reduce infiltration  into the disposal area, a high-density
polyethylene membrane was installed to cover nearly all the area inside the
fence (a total of 40 acres). This membrane was covered with 18 inches of
soil and planted with grass. The barrier drain system was cleaned and in-
spected and, where necessary, repaired. These Phase n activities collective-
ly reduced the long-term costs of operation and maintenance of the leachate
collection and treatment system.

Storm and sanitary sewers at the site were known to contain  contaminated
sediments and to serve as routes of contaminant migration to nearby creeks.
As part of Phase II, sewers within Rings I and II were cleaned, plugged, and
removed from further service. This action prevented the spread of addition-
al contamination from  man-made pathways into nearby  creeks and the
Niagara River.

The final phase of remediation (Phase HI) is addressing areas affected by
chemicals that had moved offsite into the EDA  sewers and creeks.  Sewer
remediation has been completed, including the hydraulic cleaning of more
than 65,000 linear feet of storm and sanitary sewers.  The sewer sediments
are currently stored onsite.  Sediments contaminated with TCDD will be
removed from nearby Black and Bergholtz creeks in 1989. A containment
facility for the sewer and creek sediments and other onsite wastes will be
constructed in the summer of 1988 at the Love Canal site. After appropriate
testing of a transportable thermal destruction unit, these sediments and wastes
will be destroyed onsite.  This process is scheduled for completion by 1993.
Also during this period, a decontamination/drum storage building will be
constructed to provide year-round decontamination ability and a future drum
management area.
                                 1-7

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Phase in also includes a perimeter ground water and soil survey and will in-
clude the implementation of permanent long-term monitoring programs to
evaluate the continuing effectiveness of the Love  Canal  remediation
program.

As of March 1988, over 90 percent of the private properties and the public
housing units in the EDA were vacant, with about 60 residences and 15 rent-
al units still occupied. Of the unoccupied residences, about 90 have been
demolished because of deterioration, but the U.S. Environmental Protection
Agency (EPA) and the New York State Department of Environmental Con-
servation (NYSDEC) have undertaken a stabilization program to maintain
the remaining homes within the EDA until a habitability decision is made
and implemented.

References for Section 1.3: 4,14,16,18,19, 26, 30, 35, 37, 39,43,44 (pp.
18-32), 45 (pp. 33-69), 62, 86 (Appendix 6), 97,98,99,100,102,103,104,
105,106,107,108,109, PR-1 (pp.415-474), PR-2 (Sect. 2.10), PR-3(pp.77-
85), PR-4 (Sect. 2.10.1), TRC (10/10/84 - Present), PR-5 (532-538), SRP
(723-740, 801, 826, 1122-1146, 1331-1386, 1688-1783, 1809-1830, 1932,
1942,1974-2072, 2128-2145)
1.4 THE 1982 DEPARTMENT OF HEALTH AND
    HUMAN SERVICES HABITABILITY
    RECOMMENDATION

One of the main reasons that the EDA was declared a potential human health
risk in 1980 was the preliminary finding that residents of the EDA had an
above-average frequency of chromosome damage. Serious questions were
subsequently raised, however, about the validity and proper interpretation of
these preliminary data. Based on the recommendations of a peer review
panel, a second study of chromosome damage was designed and imple-
mented by the Centers for Disease Control (CDC). This study was careful-
ly planned to incorporate optimal case-control matching procedures, sample
collection methods, and data analysis techniques. The study did not detect
any significant difference in the frequency of chromosome damage between
residents of the EDA and people living in other locations.

This result called into serious doubt one of the main reasons for declaration
of an emergency and evacuation of the EDA and raised the issue of whether
                              1-8

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the EDA was suitable for rehabitation. The EPA requested that the Depart-
ment of Health and Human Services (DHHS) address this question and
provided the DHHS with the results of an extensive environmental chemical
testing program that the EPA had begun in 1980.  This program involved
analyzing samples of air, water, sediment, soil, and biota for a wide range of
chemical pollutants.  Altogether, more than 6,000 samples were analyzed.

After an initial review of the data, the DHHS asked the National Bureau of
Standards (NBS) to evaluate the analytical procedures employed by the EPA.
Based on the NBS finding that the methods were appropriate, the DHHS then
sought to answer the following questions:

1. Are the concentrations of chemicals measured in the EDA significantly
  different from levels found in other areas of Niagara Falls?

2. Do the levels measured represent concentrations that could cause acute
  or chronic adverse health effects in people living in the Love Canal
  area, beyond what might be expected under usual residential conditions
  in the Niagara Falls area?

3. Were sufficient samples taken and analyzed to determine the extent of
  contamination by particularly hazardous materials and to be able to as-
  sess their potential threat to human health?

4. Based on the available data, can it be concluded that the area is not
  habitable?

Based on their review of the EPA data, DHHS reached the following con-
clusions, with which the New York State Department of Health (NYSDOH)
concurred:

1. Concentrations of chemicals in the EDA (excluding storm sewers) were
  comparable to levels detected in control areas elsewhere in Niagara
  Falls. Increased concentrations were present at the Canal itself and in
  some homes abutting it, as well as in material from storm sewers at
  many points in the area.

2. Concentrations of chemicals in air, water, and soil in the EDA (exclud-
  ing storm sewers)  were well below established regulatory or advisory
  exposure limits for those identified chemicals where guidelines exist
  and, by inference, for closely related compounds. In this context, the
                                1-9

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  levels detected were judged not to present risks to human health dif-
  ferent from those in the control areas in Niagara Falls. However, com-
  plete judgments of the potential adverse health effects could not be
  made since official safety limits did not exist for all possible chemicals,
  and those that did exist were developed for exposure to single chemi-
  cals alone, not for combinations of chemicals.

3. Environmental samples obtained and analyzed by EPA were sufficient
  for numerical comparisons between declaration and control areas, al-
  though the materials supplied to DHHS did not allow an assessment of
  the adequacy of the sampling plan or the statistical power of the study.

4. The Love Canal EDA was as habitable as the control areas to which it
  was compared. This decision was contingent on the provision that the
  sewers and their drainage tracts be cleaned and that continuous
  safeguards be observed to prevent further leakage from the site.

References for Section 1.4: 10,17,23,27,28,29,31,39,53,54,55,59,60,
70, PR-3 (pp.158-189), SRP (13-16)
1.5 THE 1983 OFFICE OF TECHNOLOGY ASSESS-
    MENT RESPONSE

In December 1982, the Congressional Office of Technology Assessment
(OTA) was requested to review the technical basis for and the validity of the
conclusions by DHHS regarding the habitability of the EDA. In June 1983,
the OTA reported that, based on available information, it was not possible
to conclude whether or not unsafe levels of toxic contamination existed in
the EDA. The OTA further concluded that the analysis of available data did
not support the decision by DHHS that the EDA was as habitable as the con-
trol areas to which it was compared. The OTA had three major criticisms of
the study:

   •  The EPA monitoring study was not designed for a comparison ap-
     proach; therefore, the choice of comparison areas was not necessari-
     ly appropriate nor were sufficient samples obtained from the
     comparison areas to permit a valid comparison.
                               1-10

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   • The number of samples with nondetectable concentrations made a
     statistical comparison of the EDA with the comparison areas dif-
     ficult.

   • The EPA study contained important uncertainties over the levels of
     the toxic chemicals detected and the possible levels of those not
     detected.

The OTA pointed out that one of the major shortcomings of the approach
followed by EPA and  DHHS was  that  specific criteria for determining
habitability were not developed prior to the collection and evaluation of data.
Consequently, OTA indicated the need to demonstrate more unequivocally
that the EDA was safe both immediately and over the long term. Otherwise,
OTA concluded it might be necessary to accept the original presumption that
the EDA is not habitable.

References for Section 1.5: 29, 63, PR-3 (pp. 190-191), SRP (13-16)
1.6 FORMATION OF THE TRC

In August 1983, the EPA established the Love Canal TRC to act as a manage-
ment group to provide interagency coordination and oversight for the many
matters related to the Love Canal site. The TRC comprises senior-level rep-
resentatives from EPA, the CDC/DHHS, NYSDOH, and the NYSDEC.
Table 1-1 lists the lead representatives from each agency and their times of
service on the TRC.

The principal task that the TRC undertook was to consider the issue of
habitability of the EDA. The TRC asked the CDC and the NYSDOH to
develop habitability criteria that could be applied to the EDA and that, if met,
could be used by the Commissioner of Health for the State of New York to
determine the habitability of the EDA.

To assure that the criteria would be reasonable, practical, and scientifically
sound, the CDC and NYSDOH sought the advice of scientists from a variety
of disciplines, along with the suggestions and recommendations of repre-
sentatives of industry, other government agencies, and the public. A sum-
mary of the process by which the Habitability Study was planned, reviewed,
and performed is provided in Section 2.0.
                              1-11

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                              Table 1-1
                REPRESENTATIVES OF TRC AGENCIES
Agency
             Representative
Years of Service
EPA
DHHS/CDC
NYSDOH
NYSDEC
Mr. William Librizzi, Director, Emergency and      1983--1986
Remedial Response Division, EPA Region II,
New York, NY (Chairman)

Mr. Kenneth Stoller, Deputy Director,             1986--1988
Emergency and Remedial Response Division,
EPA Region II, New York, NY (Chairman)

Mr. Steven Luftig, Director, Emergency          1988-Present
and Remedial Response Division, EPA
Region II, New York, NY (Chairman)

Mr. Daniel Van der Meer, Associate Director,      1983--1986
Center for Environmental Health, Centers for
Disease Control, U.S. Department of Health
and Human Services, Atlanta, GA

Dr. John Liddle, Center for Environmental        1986-Present
Health, Centers for Disease Control,
U.S. Department of Health and Human
Services, Atlanta, GA

Dr. Robert Huffaker, Associate  Director, Office     1983--1986
of  Public Health, New York State Department
of  Health, Albany, NY

Dr. William Stasiuk, Director, Center for          1986--Present
Environmental Health, New York State
Department of Health, Albany, NY

Mr. Norman Nosenchuck, Director, Division of     1983--1988
Solid and Hazardous Waste, New York State
Department of Environmental Conservation,
Albany, NY

Mr. Michael OToole, Acting Director, Division     1988-Present
of  Hazardous Waste Remediation, New York
State Department of Environmental Conserva-
tion, Albany, NY
                              1-12

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References for Section 1.6:  71, 73, 86 (pp. 1-4, Appendix 2), 115, PR-3
(pp. 191-196), SRP (1-12,1009-1011), TRC (12/14/83,04/23/84)
                               1-13

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      2.0  THE HABIT ABILITY ASSESSMENT
                          PROCESS
2.1 THE ROLE OF THE TRC

The Love Canal TRC was organized in August of 1983 to provide coordina-
tion and technical oversight of both remedial actions at the Love Canal site
and efforts to assess the habitability of the Love Canal EDA. This document
and its four companion volumes focus on the habitability study and TRC ef-
forts to provide review and guidance for scientific and technical excellence,
public participation, and an integrated multiple-agency approach.

Throughout the habitability assessment process, specialized groups and in-
dividuals were used,  including chemists, statisticians, soil  scientists,  air
monitoring experts, computer scientists, field samplers, and community rela-
tions experts. In addition, the TRC convened two panels of scientists to
review the work conducted to date. A third panel was established to review
Volumes n through IV. A summary of their review and responses to peer
review comments can be found in Volume V.

Public involvement in the habitability assessment evolved into an active
program with public TRC meetings held every 4 to 6 weeks. All major TRC
decisions were preceded by opportunities for public comment and discussion
of their concerns.  Additional aspects of this unique public participation
program are discussed in a later section.

As a result of active TRC oversight and public participation, the habitability
assessment process has been an integrated, multiple-agency undertaking.
The process has resulted in a project that has the  general support of the four
TRC agencies and the public.

References for Section 2.1: 86,73
                               2-1

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2.2 DEVELOPMENT OF THE HABIT ABILITY
    CRITERIA

One of the first and most important tasks undertaken by the TRC was to
develop criteria to be presented to the Commissioner of Health for the State
of New York for use in a determination of the habitability of the EDA. The
development of habitability criteria as the initial step in the habitability
assessment of the EDA was the primary responsibility of NYSDOH and
CDC. The TRC obtained the services of 10 distinguished scientific advisors
to assist in the development of the habitability criteria. From March 1984 to
March 1985, the scientists met seven times at Niagara Falls  in  public ses-
sions to develop the initial concepts for the habitability criteria.

The  scientific  advisors reviewed  the existing environmental data, the
remedial measures, and the published and unpublished health  studies.  Con-
currently, they also considered several possible approaches to use as the basis
for the habitability criteria. The approaches considered and the rationale for
their acceptance or rejection are discussed in Section 3.0.

After several meetings, the scientific advisors recommended an approach for
the habitability criteria that uses a combination of relevant Federal and
New York State standards,  criteria, or guidelines for residential purposes
(where they exist) and a comparison of levels of select Love, Canal Indicator
Chemicals (LCICs) in the EDA with levels of the same chemicals from areas
similar to the EDA, but not  near a chemical landfill.  The basic concept of
the comparison approach assumes that "data collected from the comparison
areas will correspond to 'normal' or habitable conditions." When these data
are compared to similar measurements in the EDA, they will provide an in-
dication of whether or not the concentrations of air LCICs in the EDA homes
and soil LCICs in the  EDA  neighborhoods are significantly different from
those in the comparison areas. If the concentrations of the LCICs  in the EDA
are significantly greater than those of the comparison areas, the source of the
chemicals will be assumed to be the Love Canal.

The intent of the recommended approach is to determine if the chemicals
from Love Canal have reached the EDA in sufficient quantity to create a sig-
nificant difference between the concentration of the LCICs in the EDA and
the concentration in the comparison areas. This approach purposely does not
assess the health impacts of the Love Canal on the EDA.
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This basic approach to determining habitability was further developed by
NYSDOH and CDC staff through nine drafts of the habitability criteria. The
first draft was issued in 1984, and the final document, Love Canal Emergen-
cy Declaration Area:  Proposed Habitability Criteria, was  released in
December 1986.  Issues that received particular attention and that are ad-
dressed in subsequent chapters include the determination of the applicable
Federal or New York State standards, criteria, or guidelines that apply to the
EDA, the selection of the comparison areas, the choice of media to sample,
the selection of LCICs, the determination of what constituted a "significant
difference,"  and the identification of the ways in  which air sampling in
individual homes would be used in conjunction with soil sampling for EDA
neighborhoods.  Each  draft was reviewed by the  scientific advisors, the
public, the TRC agencies, and the contractors retained by the TRC.

References for Section 2.2:  86, SRP

2.2.1  Summary of the Draft Proposed Habitability Criteria

The habitability criteria called for three environmental sampling studies. The
air assessment for LCICs, Volume n, was to be designed to compare the
results of indoor air samples from occupied residences in the EDA with in-
door air samples from occupied residences in the  comparison area.  Air
samples from unoccupied EDA residences were to  be compared with am-
bient  air samples taken from the EDA.  The soil  assessment for LCICs,
Volume HI, was to be designed to compare concentrations of LCICs in EDA
neighborhoods (13 neighborhoods were defined in the habitability criteria)
with concentrations of LCICs in a comparison area (the criteria specified how
these areas were to be selected) to determine if the EDA neighborhoods were
significantly different from the comparison neighborhoods. The soil assess-
ment for dioxin, Volume IV, was designed to determine if the EDA soils had
concentrations of TCDD greater than the 1 part per billion (ppb) Federal level
of concern.

The draft criteria stated:

A neighborhood in the EDA is considered habitable if all three of the follow-
ing conditions are met:

1. If soil sample measurements of TCDD are less than 1 ppb; and,
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1. If soil sample measurements of TCDD are less than 1 ppb; and,

2. If the chosen aggregate values (e.g., mean, median, percentiles, etc.) of
  each non-TCDD LCIC evaluated both individually (univariate) and col-
  lectively (multivariate) are not significantly different than the values
  from the comparison areas; and,

3. If the integrity of the neighborhood with reference to the habitability of
  individual homes within it and to its location relative to other neighbor-
  hoods (habitable or uninhabitable) is maintained.

Residences in the EDA will be sampled for air LCICs.  A residence in the
EDA is considered habitable if all three of the following conditions are met:

1. If it is located in a neighborhood judged to be habitable; and,

2. If the results of the air comparisons show that retesting and/or remedia-
  tion are not necessary; and,

3. If remediation is performed and is shown to be successful. Remediation
  will be considered successful if LCICs are reduced to the same levels as
  found in habitable areas.

Remediation would be called for if an EDA residence  had a significantly
higher LCIC concentration than found in the comparison area residences.

In addition, the habitability criteria required  that the previously taken
remedial actions effectively  contain the wastes stored in the  Canal, that
remediation of the sewers be conducted, and that an acceptable remedial plan
for the creeks be established.

References for Section 2.2.1: 86

2.2.2 Peer Review of the Habitability Criteria

Prior to finalizing the habitability criteria, the TRC convened a panel of 10
scientists for a peer review of the November 1985 draft of the habitability
criteria. The peer review panel was charged with determining whether the
approach and criteria described in the proposed habitability criteria were
reasonable, practical, and based on sound scientific principles. The major
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areas of scientific expertise that were required to perform a comprehensive
peer review of the habitability document were identified, and reviewers were
selected to provide expertise in the required subject areas. The peer review
panel assembled in Niagara Falls and met in public sessions from March 12
through 14 to debate the issues of concern.  A report summarizing the main
discussions and recommendations was submitted to the TRC and the public
on April 25, 1986.  On May 12 and 13,1986, the peer review panel recon-
vened to hear comments and questions from the public. Following the meet-
ing, written responses to each comment were drafted, approved by the panel,
and documented in a report.

The peer review panel concluded that the overall approach proposed by the
Habitability Criteria document was reasonable, practical, and based on sound
scientific principles.  There was a general  agreement among reviewers in
their analysis of and opinions on most aspects of the proposed approach. The
reviewers offered a number of recommendations and suggestions regarding
the sampling and analysis plan and the statistical analysis procedure.  Sig-
nificant discussion among the reviewers focused on two aspects of the ap-
proach, both related to the number and types of chemicals to be considered
in the comparisons.

Changes incorporated into the  criteria document resulting from the  peer
review process involved adding the following:

   • A preface that defined the sequence of future actions in the
     habitability assessment process

   • More justification for both the type of media and the chemicals
     selected for environmental sampling

   • The option to redefine neighborhood boundaries at the completion
     of the study

   • The criteria for successful remediation of measured levels of con-
     tamination in sampling media

References for Section 2.2.2: PR-1 through PR-4
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2.3 IMPLEMENTATION OF THE HABIT ABILITY
    CRITERIA

The habitability criteria required two initial implementation steps to be taken.
The first was selecting the comparison areas as specified in the habitability
criteria. This selection was completed by NYSDOH in October 1986 after
a thorough review of candidate sites and a tour of proposed sites by the public.
Section 6.3, Selection of Comparison Area, describes this process in more
detail.  The areas selected were neighborhoods in the towns of Tonawanda
and Cheektowaga. The second step was to conduct pilot studies for the air
and soil comparison studies. After these initial steps were completed, the
habitability study was conducted.

References for Section 2.3:  86

2.3.1 Pilot Studies

Prior to the start of habitability  sampling, pilot studies for the soil and air
comparisons were required. The purpose of the pilot studies was to test the
feasibility of implementing the habitability criteria and to develop data that
could be used to:

   • Test the sampling and analytical methods proposed for the com-
     parison studies

   • Provide preliminary data on the levels and statistical distributions of
     the LCICs

   • Provide a basis for determining the number of samples that needed
     to be taken to produce statistically valid results for the comparison
     studies

The results of the air and soil pilot studies are reported in Pilot Study for Love
Canal EDA Habitability Study, Volumes I and n. Based on the findings of
the soil pilot study, NYSDOH conducted a small follow-up study that col-
lected soil samples from areas within the EDA, Cheektowaga, Niagara Falls,
and the town of Wheatfield. This study was conducted to evaluate potential
non-Love Canal sources for some of the LCICs. The reasons for and the
results of this study are reported in Volume n of the pilot study report.
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The pilot study reports underwent peer review from March through May
1987 with a 3-day public meeting held from March 24 through 26. The peer
reviewers included some members  from the previous panel, which had
reviewed the habitability  criteria, as well as some new members.

The major changes in the soil LCIC assessment that resulted from the pilot
study and the peer review were:

   • The analysis for semivolatile compounds only

   • The consideration of two additional comparison areas, both from
     Niagara Falls

   • The combination of the 13 EDA neighborhoods into a smaller num-
     ber of sampling areas for purposes of the statistical design and
     analysis of the soil LCIC data

The major changes in the air LCIC assessment that resulted from the pilot
studies and  the peer review were:

   • The combination of the two isomers of the same compound
     (chlorotoluene)  into a measurement of total chlorotoluene concentra-
     tion (a shift from three to two air LCICs)

   • The consideration of any detectable air LCIC concentration as sig-
     nificant, which resulted in the air in the comparison areas not being
     sampled

References for Section 2.3.1: 79, 81, 84, 85,95, PR-5, PR-6

2.3.2 Habitability Study

The habitability study consisted of the air LCIC comparison study, the soil
LCIC comparison study, and the soil dioxin study. Many of the steps of the
three studies were similar and included:

   • Developing and testing sampling and analytical protocols
   • Obtaining permission to sample
   • Preparing a sampling plan
   • Preparing the Quality Assurance Project Plan
   • Collecting and analyzing the samples
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   • Validating the sample results
   • Evaluating the data
   • Preparing reports

The air  LCIC comparison  study collected  indoor  air  samples  from
562 residences during four sampling periods in 1987.  During the air com-
parison study, special attention was paid to developing protocols to track the
source of an LCIC should a detectable concentration be found in a residence.
The sampling plan was also designed to evaluate potential seasonal and diur-
nal variation in concentrations of LCICs.

The soil LCIC study was conducted in October and November of 1987. The
sampling design was carefully planned using a randomization concept so that
the comparison statistics could be properly performed at the end of the study.
A total of 879 soil samples were collected and sent for analysis. The  study
required the development of an analytical method capable of detecting the
LCICs at levels as low as 0.2 ppb. After the method was developed, analyti-
cal laboratories were selected and trained  in the use of the method.  The
quality of the laboratories' work was closely monitored by an extensive
quality control  program overseen by  the EPA Office of Research and
Development.

A total of 2,274 soil dioxin samples were collected during three sampling
periods, one in late 1986 and two in 1987.  Samples were collected using a
combination of a statistically based "hot spot" sampling design and a TRC
directive  to collect two samples per residential, lot.   The samples  were
analyzed  by laboratories in  EPA's Contract Laboratory Program and
validated by EPA Region II staff.

A peer review of Volumes II, III, and IV of this report is an integral part of
the implementation of the habitability study. The results of the peer review
are reported in Volume V.

References for Section!. 3.2:  89,90,91,92,93,94,95,96
                                2-8

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2.3.3 Habitability Decision

In accordance with the Habitability Criteria document, Volumes I through
V will be presented to the Commissioner of Health for the State of New York
for use in a determination of habitability.

Section 312(e) of the Federal Superfund Amendment and Reauthorization
Act requires the Administrator of EPA to conduct or cause to be conducted
a habitability and land use study. The study:

1. Assesses the risks associated with inhabiting the Love Canal EDA

2. Compares the level of hazardous waste contamination in that area to that
  present in other comparable communities

3. Assesses the potential uses of land within the EDA, including but not
  limited to residential, industrial, commercial, and recreational uses as
  well as the risks associated with such potential uses

The  Act also requires  the Administrator to publish the findings  of such a
study (this five-volume report) and to work with the State of New York to
develop recommendations based on the results of the study.

Since both the habitability criteria and the Superfund Amendments recog-
nize that decisions  on land use are ultimately related to decisions on
habitability, the Commissioner will convene a panel representative of com-
munity interests to advise him on future land uses for the EDA.  The Com-
missioner will consider the advice of the panel and include in his decision
on habitability recommendations for implementing that decision.

This local advisory panel will  be  convened shortly after transmittal of
Volumes I through V of this report. It is anticipated that the Commissioner's
determination on habitability of the EDA and recommendations for the im-
plementation of his  findings will take approximately 3 months following
receipt of the report. The process will  conclude with the Commissioner's
transmittal of his determination and recommendations to the Administrator
of EPA.

References for Section2.3.3: 116, TRC
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2.4  PUBLIC PARTICIPATION

There has been a long history of public involvement at the Love Canal site,
and the public has been actively involved in deliberations associated with the
Love Canal Habitability Study. In March of 1983 the NYSDEC established
a Public Information Office at the Love Canal. This office is staffed by two
full-time NYSDEC personnel and serves as a document repository for all
Love Canal-related materials.  When the TRC was established in August of
1983, the Public  Information Office also became the repository for all sig-
nificant records associated with the activities of the TRC. This local presence
has provided immediate public access to all significant documentation as-
sociated with Government decision-making related to the Love Canal site.
In addition, EPA also has a Niagara Falls Public Information Office which
informs the public of activities related to Love Canal as well as activities re-
lated to the Agency's other environmental programs.

The formation of the TRC resulted in requests from the public to participate
in the process in  an active and purposeful manner.  In response to these re-
quests, the TRC asked the community to recommend two independent scien-
tific advisors to assist NYSDOH and CDC in the development of the
habitability criteria. Although the community had divergent opinions on the
activities associated with the Love Canal site, a Love Canal Coalition, which
was representative of all community organizations at the Love Canal site,
was formed to respond to this request. After numerous meetings and discus-
sions, the coalition selected a list of scientists, which was submitted to the
TRC for consideration. Two of these scientists were asked to participate as
scientific advisors in the development of the habitability criteria.

In the interim, the TRC presented four options for public participation and
requested the community to select an  approach. In addition,  the coalition
developed its own 12-Point Plan for Public Participation. One significant
recommendation by the coalition was that the TRC hold all of its meetings
in a public location easily accessible to the Love Canal community. As a
result of discussions with the Love Canal Coalition on the 12-Point Plan, the
TRC made the decision to hold meetings in public at Niagara Falls, but
retained the right to hold executive sessions as necessary. Although the first
meeting of the scientific advisors was held in Buffalo, all subsequent meet-
ings of the advisors and the TRC have been held in Niagara Falls.
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During these open TRC meetings, opportunities for dialogue between the
TRC representatives and the community were provided for each major agen-
da item. While the agenda focused on the habitability assessment, NYSDEC
also provided periodic updates on the remedial program. (In addition, the
NYSDEC continued its more extensive public participation efforts for the
individual projects in which it was involved through the Public Information
Office.) This forum gave the public an opportunity for immediate input into
the decision-making process and for further discussion on items of concern.
Public comment periods on all significant documents were provided prior to
the finalization of these documents.

The TRC also provided a forum for the community to discuss issues not
directly related to the habitability study or the remedial program. Represen-
tatives of the TRC often interceded with Government agencies on behalf of
the local community. Attempts were frequently made by the TRC to resolve
problems that occurred within the Love Canal EDA, even if the problems
were outside the direct jurisdiction of the TRC agencies.

The NYSDOH also worked closely with the community in the selection of
the comparison areas. Residents and Government representatives traveled
together by minibus to each of the potential comparison areas and reviewed
them for comparability to the EDA.  The  comparison areas were selected
after the results of the joint community/Government review were considered.

An extensive community outreach program was implemented by the NYS-
DOH  to encourage Love Canal EDA and comparison area property owners
to participate in  the environmental sampling necessary to  complete the
habitability study. The schedule of sampling events was modified to meet
the needs of residents, ample notice of entry onto each property was provided,
and other conditions required by the property owners were accommodated
to the degree possible.

References for Section 2.4: 71,73, TRC
2.5  SUMMARY

In accordance with the habitability criteria document, the results of this study
will be presented to the Commissioner of Health for the State of New York
                               2-11

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for use in a determination of habitability.  The habitability study followed
the guidelines set forth in the habitability criteria.  The development of the
criteria and their implementation took more than 4 years. Figure 2-1 shows
a timeline of the major activities of this process.  Throughout the develop-
ment and implementation of the habitability criteria, the TRC and the public
have worked closely to assure that the highest technical standards have been
met.
                                 2-12

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Mabitability Study Activities
Technical Review Committee
" Convened
TRC Meelings


Habitability Criteria
Scientific Review Panel Meetings
Pppr Rpwipw

Criteria Document (Revised)

Pilot Studies
Air 1 PIP
Cnil 1 PIP
oOH LUt
Peer Review

Full-Scale Sampling Programs
Air 1 PIP
All Lblb
Cnii nirwin / o T 7 Q Tpnn\
ooii uioxin \
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       3.0  FUNDAMENTAL CONCEPTS AND
                       OBJECTIVES
The fundamental approach to the Habitability Study was to derive a set of
criteria for judging the suitability of the EDA for human habitation and to
obtain a data set adequate to satisfy the requirements of the criteria. To guard
against reaching an ambiguous result, it was stipulated that the criteria must
meet three requirements:

   •  The criteria must apply to the EDA and may or may not be
     applicable elsewhere.

   •  The criteria must be as objective, quantifiable, and reproducible as
     possible.

   •  The criteria must lead to a "yes" or "no" answer.

Before work began on development of the habitability criteria, it was neces-
sary to define the concept of habitability and to identify the principal deter-
minants of habitability in the EDA.  These issues are described below.
3.1 DEFINITION OF HABITABILITY

For purposes of the task at hand, "habitable" means suitable for human
habitation, including all ages and both sexes (including pregnant women)
engaged in normal activities.  In most situations, including that of the Love
Canal EDA, judgments about suitability for human habitation rarely involve
a simple yes/no response. Important considerations include the degree of
certainty about the presence or absence of risks and whether these risks are
immediate or delayed, serious or negligible, voluntary or involuntary, and
whether restricted habitability or alternative land use  is intended.  With
regard to the Love Canal EDA, the judgment is also complicated by the fact
that some residents of the EDA were offered temporary relocation pending
an official judgment on the risks posed by the presence of the Love Canal
disposal site.  This, compounded with the publicly voiced critiques (whether
justified or not) of the existing exposure and health assessment data of Love
                               3-1

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Canal, has created questions in the community concerning the risks posed
by rehabitation of the Love Canal EDA.

If the EDA is found to be suitable for human habitation, then other land uses
(e.g., public park, business area, churches) will also be acceptable. If the
EDA is judged to be unsuitable for full-time and unrestricted human habita-
tion, then other possible uses will be evaluated as specified under the Super-
fund Amendments and Reauthorization Act.  It is  expected that the data
collected for the Habitability Study will be adequate for use in any alterna-
tive land-use assessment.

References forSection 3.1: 53 (pp. 3-4), 86 (pp. 4-5,  Appendix 4), 112,116,
PR-1 (pp. 27-34), PR-2 (Sect. 2.2), PR-4 (Sect. 2.12.1), SRP (4-10, 92-94,
320-323,532-545, 664-668,1149-1170), TRC (01/14/88)
3.2  CONSIDERATION OF "BACKGROUND" CHEMI-
     CALS

Any chemical contaminants present in the EDA may have migrated or been
transported there from Love Canal, or they may have reached the EDA from
sources other than the Canal.  Other sources could include emissions from
nearby industries, emissions from vehicle traffic, pesticide products applied
to lawns or shrubs, and so on. In considering the scope of the Habitability
Study, it was therefore necessary to choose between two basic alternatives:

1. Evaluate the habitability of the EDA in terms of the total amount of all
  chemicals present, regardless of their origin.

2. Evaluate the habitability of the EDA on a relative basis, seeking to deter-
  mine if migration or transport of chemicals from Love Canal has
  resulted in any significant increase in chemical levels in the EDA.

In considering these two approaches, it was presumed that the EDA would
be considered habitable if it were certain that there was no chemical con-
tamination present from Love Canal.  Consequently, the critical issue was
judged to be whether or not chemicals from Love Canal had reached the
EDA, and not whether any other chemicals were present as a result of emis-
sions from other sources. Moreover, any assessment based on the total of all
chemicals present  would  require generation of standards or guidelines by
                               3-2

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which to judge acceptable environmental levels.  However, this is an ex-
tremely slow and costly process, which was neither feasible nor appropriate,
since the setting of standards and guidelines requires proper legislative man-
date and review.  For these reasons it was concluded that the Habitability
Study should be based on a consideration of chemicals from the Love Canal
waste site only. To the extent that any concern might exist regarding back-
ground or ambient pollutants, that concern remains the proper responsibility
of the appropriate local, State, or Federal agencies.

References for Section 32:  75, PR-1  (pp. 38-63, 323-325, 361-366), PR-2
(Sect. 2.1, 2.3), PR-3 (pp. 25-56,  94-116), PR-4 (Sect. 2.1.1, 2.4.7, 2.5.7,
2.6.6, 2.6.7,2.8.2,2.9.1,2.12.3), SRP (1149-1170,1659-1660,1678-1687)
3.3  EVALUATION BY RESIDENCES AND NEIGHBOR-
     HOODS

The EDA is a large area, and a priori it was considered plausible that varia-
tions across the EDA might lead to the finding that some portions of the EDA
were habitable while others were not. Consequently, it was judged ap-
propriate to deal with these potential variations in an open and flexible way,
rather than on an all-or-nothing basis.  For this reason, the smallest unit of
the habitability  assessment  was taken to be  an individual residence.
However, the suitability of an individual residence also depends on social
factors such as the distribution of habitable and nonhabitable residences near-
by. That is, a habitable residence surrounded by nonhabitable residences
might lack the necessary contiguous habitable space required for a suitable
residence. Consequently, it was concluded that the Habitability Study should
contain an evaluation of the EDA by neighborhoods as well as by individual
residences.

References for Section 3.3: 86 (pp. 18-22, Appendix 8), PR-1 (pp. 37-38),
PR-2 (Sect. 2.9), PR-4 (Sect. 2.9.1), SRP (557-559,695-696,927-929,1267-
1274,1431-1432,1784-1796,1833-1855,1925-1929)
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3.4 SUMMARY

Based on the considerations described above, the objectives and scope of the
Habitability Study were articulated as follows:

    The proposed habitability criteria are designed to yield informa-
    tion necessary to answer this question:  Does the Love Canal haz-
    ardous waste disposal site (in its present state of remediation and
    with the guarantees of EPA and NYSDEC for continuous monitor-
    ing and containment) have a measurable impact on the environ-
    ment  of the Emergency Declaration Area (EDA) which, in the
    judgment of the New York State Commissioner of Health, renders
    the entire Emergency Declaration Area or neighborhoods in the
    EDA  not habitable from a public health  standpoint?  (Source:
    Love  Canal Emergency Declaration Area  Proposed Habitability
    Criteria: December, 1986)
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  4.0 SELECTION OF THE BASIC APPROACH
          TO EVALUATE HABIT ABILITY
A number of approaches were considered for assessing the habitability of the
EDA. Presented below is a summary of each approach that was considered,
along with an evaluation of the approach in terms of the general objectives
and requirements described in Section 3.0.
4.1 APPLICATION OF RELEVANT STANDARDS,
    CRITERIA, OR GUIDELINES

The EDA cannot be recommended for habitation if the concentrations of any
chemical in the environment of the EDA exceeds a relevant Federal or New
York State standard, criterion, or guideline. Consequently, comparison of
chemical levels in the EDA to relevant standards, criteria, or guidelines was
selected as the most appropriate first step in the Habitability Study. Because
the goal is to safeguard residents of the area, "relevant" in this case is taken
to mean that the standard, criterion, or guideline is intended to apply to the
conditions of residential exposure typical in the EDA.

References for Section 4.1:  51 (pp. 8-11), 86 (pp.7-8, Appendix 7, pp. 7-8
to 7-11), 87, 101 PR-1 (pp. 227-268), PR-2 (Sect. 2.1, 2.3), PR-3 (pp. 202-
203), TRC (08/05/85, 11/21/85), SRP  (633-635, 1420-1423, 1763-1773,
2082-2119).
4.2 DERIVATION OF NEW GUIDELINES

Few guidelines or standards directly relevant to the types of residential ex-
posure (inhalation of air, contact with soil) that are of primary concern in the
EDA have been established by State or Federal health or environmental agen-
cies. However, there are a number of guidelines or standards which, although
not directly relevant, might be used as a starting point for calculation of values
that could be applied in the EDA. For example, Threshold Limit Values
(TLVs), derived by the American Conference of Governmental Industrial
Hygienists (ACGIH), identify  limits for airborne concentrations of toxic
                             4-1

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chemicals in the workplace. In principle, these TLVs might be "adjusted"
to derive a new value that would apply under residential conditions.

This approach was judged to be inappropriate for two reasons.  First, there
is no generally accepted procedure for making this adjustment, and any
resulting value would be subject to debate and controversy.  Second, any
such extrapolation performed by the TRC would bypass the necessary and
proper scientific, administrative, and public reviews that are involved in es-
tablishing guidelines and standards.  For these reasons, any extrapolation
from a guideline or standard not expressly derived to apply to residential ex-
posures was judged to be inappropriate.

References for Section 4.2: 87,101.PR-1 (pp. 38-45,227-268), PR-2 (Sect.
2.1,2.3), PR-4 (Sect. 2.3.2), TRC (08/05/85), SRP (1420-1423,1434-1438,
1509-1539,1891-1919).
4.3  RISK ASSESSMENT

Risk assessment is often used to estimate the magnitude of the human health
risk at a chemical waste site. The risk assessment process includes three basic
steps: first, the concentration of chemicals in the environment is determined;
second, the amount of exposure (dose) for individuals who live or work in
the area is estimated; and third, the health consequences of this exposure are
predicted, based on available toxicological dose-response data.

However, this process is limited by a number of factors.  First, it is usually
difficult to  identify and quantify all toxic chemicals in all media (air, soil,
water), especially at a complex site such as Love Canal where many different
types of waste (at least 200 different chemicals have been identified) have
been deposited. Second, even if the identity and concentration of all toxic
chemicals were known, there is insufficient toxicity data on many chemicals
to predict the likely human health consequences of exposure. Further uncer-
tainty is added by possible interactions  among multiple chemicals, about
which there is currently only limited information and understanding. Final-
ly, the risk assessment process depends on data that are subject to change as
new toxicological or epidemiological studies are performed. Consequently,
a habitability decision based on even the best-performed risk assessment
might subsequently have to be revised as a result of new toxicological data.
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For all of these reasons, standard risk-assessment methodology was judged
to be inadequate for evaluating the habitability of the EDA.

References for Section 4.3: 3, 24, 51, 82 (Appendix 7, pp. 7-4 to 7-8), PR-
1 (pp. 38-45), PR-4 (Sect. 2.1.2,2.3.2), TRC (07/23/85,08/05/85), SRP (108-
114,568-577,709-712,1389-1410,  1473-1476,1552-1566,1683-1684).
4.4  HEALTH STUDIES

Another approach considered was to study the health status of current resi-
dents in the EDA to determine if they have an increased incidence of any
chemical-related diseases or symptoms. However, experience has shown
that it is very difficult to detect the effects of exposure to low-level environ-
mental pollution in small population groups.  This is because there are nor-
mally large variations in the prevalence of symptoms and diseases in different
groups of people, and usually only large differences can be detected as statis-
tically significant effects.  In addition, when a difference is detected, it may
be difficult to determine whether the cause is related to chemicals in the en-
vironment, the workplace, or the home, or to some other reason.  Health
studies of this sort performed in 1978, when the population in the EDA was
large, provided no definitive  evidence of chemical-related health effects, and
any such studies done now, when the residential population is much smaller,
would  almost certainly not  be sufficiently sensitive to detect any  health
effects that might exist.

It should be noted that health studies based on past residents of the EDA
(people who were residents  prior to remediation but who no longer live in
the EDA)  would not provide useful information about any possible  health
risks that might currently exist in the EDA. Likewise, any study of the fu-
ture health status of current  residents or of future residents (if rehabitation
occurs) cannot be part of the current decision-making criteria.

A variation to studying the health of current residents would be to measure
the levels  of chemical pollutants in the fluids or tissues of EDA residents.
However,  this approach is limited by the same problem of variations among
individuals and among groups of people as noted previously. In addition,
while any  above-average concentrations would indicate above-average ex-
posure, this finding would  not necessarily imply that any adverse  health
                                4-3

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effects would result or that emissions from Love Canal had caused the above-
average exposures.

For these reasons, neither of these approaches was judged to be adequate to
serve as  the primary basis for evaluating the  habitability of the  EDA.
However, based on recommendations in the Habitability Criteria document,
the NYSDOH will  determine whether Love Canal residents have ex-
perienced an increased incidence of adverse  health outcomes relative to
populations from comparable areas in the United States.  To this end, the
NYSDOH is updating the registry of people who live or have lived in the
Love Canal area.

References for Section 4.4: 1,2,3,15,20,31,40,41,42,44 (pp. 11-17), 45
(pp. 16-32), 46,49,50,52,56,57,58,64,65,66,67,69, 86 (pp. 32-33, Ap-
pendix 7, pp. 7-11 to 7-12), PR-1 (pp. 461-471), PR-2 (Sect. 2.11), PR-3 (p.
204), TRC (11/21/85,12/03/87), PR-5 (551-562), SRP (47-65,114-119,138,
176-300,313-315,380-381,625-633,741-765,862-925,1015-1102,1215-
1254,2131-2132,2161-2162).
4.5  TIME TRENDS IN POLLUTION LEVELS

Another approach considered was to determine if chemical contamination of
the environment had been reduced by the remedial activities (as described in
Section 1.3) at the site. This approach has two serious limitations. First, ade-
quate historical quantitative data on chemical levels in the EDA are limited,
so identifying and quantifying any time-dependent changes that were present
would be difficult.  Second, even if the data did show a reduction in con-
taminant levels over time, this finding would not establish whether present
levels are higher than levels in other comparable areas of the Niagara Fron-
tier or whether present levels are acceptable. Therefore, this approach was
judged to be inadequate.

References for Section 4.5: 86 (Appendix 7, pp. 7-3 to 7-4), SRP (107-108,
1970)
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4.6 COMPARISON OF THE LOVE CANAL FACILITY
    TO STATE-OF-THE-ART FACILITIES

Another approach considered was to review the design features and perfor-
mance data for the Love Canal leachate treatment facility and to compare
them to a state-of-the-art facility meeting all existing regulations. This ap-
proach was deemed to be inadequate, since the design and operation of each
waste treatment plant depends on site-specific variables such as type, num-
ber, and quantity of contaminants present, hydrogeological characteristics of
the site, and so on. In addition, this approach would not address whether any
residual contamination exists in the EDA that was deposited prior  to site
remediation or whether such contamination would constitute an unacceptable
risk.

References for Section 4.6:  86 (Appendix 7, pp. 7-12 to 7-13), SRP (132-
137)
4.7 COMPARISON OF THE EDA TO INHABITED
    URBAN AREAS

As discussed in Section 3.2 (Consideration of "Background" Chemicals), the
basic objective of the habitability study was to determine whether any chemi-
cals from Love Canal have migrated or have been transported to the EDA,
and not to evaluate the possible significance of background chemicals from
other sources. An approach well-suited to this objective is comparison of
chemical levels in the EDA with those in one or more areas that are similar
to the EDA, but are not affected by a chemical waste site. The comparison
approach is based on the assumption that inhabited residential neighborhoods
that meet public health and housing codes and are not affected by a chemi-
cal landfill are habitable. Thus, data on environmental levels of chemicals
collected from the comparison areas will correspond to "normal" or habitable
conditions that, when compared to similar measurements in the EDA, will
provide an indication of whether EDA neighborhoods and homes are or are
not "significantly different," with respect to contamination, from those in
comparable western New York communities.   While  this  approach is
designed to determine whether the EDA is uninhabitable due to contamina-
tion by chemicals that migrated or were displaced from the Love Canal, it
cannot provide absolute assurances that the EDA is risk free.
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Although the implementation of a comparative approach is not without some
difficulties (see Section 6.0), this approach specifically addresses the impact
of the Love Canal site on the EDA.  In addition, interpretation of the results
does not depend on judging what level of additional environmental con-
tamination or risk is or is not acceptable. Consequently, the comparison ap-
proach was selected as the core of the habitability decision-making process.

References for Section 4.7:  3, 86 (pp. 8-13, Appendix 7, pp. 7-13 to 7-14),
PR-2 (Sect. 2.1), PR-4  (Sect. 2.5.2), TRC (04/11/85, 07/23/85, 08/05/85,
10/07/85,  11/21/85), PR-5  (354-368), SRP  (109-112, 150-153, 470-474,
876-883, 1256-1259,1411-1421).
4.8  SUMMARY OF APPROACH SELECTED

The approach selected for evaluating the habitability of the EDA consists of
two phases. First, relevant Federal or New York State standards, criteria, or
guidelines for chemicals in environmental media to which residents and
potential residents may have significant exposure will be used to assess the
possible hazard of habitation of the EDA.  Second, because applicable and
relevant standards, criteria, or guidelines are not available for residential air
and soil for most of the chemicals identified thus far in the Love Canal and
the EDA, a comparison methodology will  also be used  to assess  the
habitability of the EDA. This approach involves comparison of environmen-
tal sampling data from the neighborhoods and residences in the EDA with
results from similar inhabited communities in western New York not affected
by a chemical landfill.
                                4-6

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         5.0  APPLICATION OF RELEVANT
    STANDARDS, CRITERIA, OR GUIDELINES
The first phase in the Habitability Study was comparison of chemical con-
centrations in the EDA with relevant Federal or New York State standards,
criteria, or guidelines. A standard, criterion, or guideline was considered
relevant if based on residential exposure conditions similar to those in the
EDA.  A search was undertaken to identify all standards,  criteria, or
guidelines that meet this definition. The results are summarized below.
5.1 AIR

National ambient air quality standards exist for six pollutants:  ozone,
nitrogen oxides, sulfur dioxide, carbon monoxide, lead, and suspended par-
ticulates. However, none of these pollutants are suspected of being an emis-
sion of concern from the Love Canal site, so none of these standards are
useful in evaluating the effect of the waste site on ambient air quality in the
EDA.

The State of New York has established a number of guidelines termed
Acceptable Ambient Levels (AALs). However, these values do not specify
acceptable concentrations of chemicals in ambient air, rather, they specify
the maximum increment in airborne chemical levels permitted as a conse-
quence of emissions from any specific industrial source. Therefore, these
values are not relevant indices of ambient air quality in the EDA.

As noted previously, there are many guidelines for airborne levels of toxic
chemicals in the workplace, derived by organizations such as the ACGIH or
the Occupational Safety and Health Administration. However, these values
are intended to apply to the workplace and are designed to protect healthy
adult workers exposed for 8 hours per day, 5 days per week. They are not
intended to apply to other populations (children, the aged, pregnant women)
or to conditions of continuous exposure. Consequently, they are not direct-
ly relevant to the EDA.

In summary,  no existing relevant guidelines or standards were located that
could be used to evaluate ambient air quality in the EDA.
                               5-1

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References for Section 5.1: 87, PR-1 (pp. 227-268), PR-3 (pp. 57-59), SRP
(2082-2119)
5.2  WATER

The EPA Office of Drinking Water and the State of New York have promul-
gated a number of guidelines or standards that apply to human ingestion of
drinking water. However, the drinking water that supplies the EDA and other
regions of Niagara Falls is drawn from the Niagara River, not from a loca-
tion near the Love Canal site.  Consequently, although it is appropriate that
drinking  water supplied to the EDA meet existing standards, there is no
reason to believe that the quality of this drinking water is affected  by the
Love Canal site.

The EPA has also published a  number of values termed Ambient  Water
Quality Criteria. These values are intended to protect humans who ingest
surface water, ingest fish taken from the surface water, or both.  The only
water in the EDA to which these criteria could apply are Bergholtz and Black
Creeks. However, because these creeks are to be fully remediated as part of
the remedial plan at the site, evaluation of the creeks by use of these criteria
was not considered to be necessary.

References for Section 5.2:  87, SRP (2082-2119)
5.3  SOIL

No Federal or New York State standards define acceptable concentrations of
toxic chemicals in residential soil.  However, a value of 1 (ppb) (1 Jig/kg)
for TCDD in accessible residential surface soils has been identified as a level
of concern by the CDC. This concentration value is estimated to pose an ex-
cess lifetime risk of cancer of approximately 10" to 10  for a resident who
inhales, ingests, and has dermal contact with typical amounts of soil.  Be-
cause this value is based on estimates of exposure typical of a residential
area, it is directly applicable to the EDA.

References for Section 5.3: 87,113, PR-1 (pp. 227-268), TRC (10/07/85),
SRP (16-17,938-939,2112-2113)
                                5-2

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5.4  SUMMARY

Only one guideline or standard (that for TCDD in soil) was identified that
was relevant and useful for evaluating the acceptability of chemical levels in
the EDA.  Other guidelines and standards were not relevant, either because
they do not apply to the residential exposure conditions in the  EDA or
because they relate to chemicals that are not associated with the Love Canal
site.
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          6.0  IMPLEMENTATION OF THE
            COMPARATIVE APPROACH
The objective of the comparative approach was to determine if chemical pol-
lutants from Love Canal occur in the EDA at concentrations significantly
greater than the concentrations of these chemicals in comparable residential
areas not affected by a chemical waste site. Implementation of this approach
required answers to three basic questions:

   • What environmental media will be compared?
   • What chemicals will be compared?
   • What areas will be compared?

The approaches selected for answering these questions are detailed below.
6.1 SELECTION OF ENVIRONMENTAL MEDIA FOR
    COMPARISON

The principal consideration in choosing appropriate comparison media was
the likelihood that the medium is a significant exposure route in the EDA.
This depends on the extent of human contact with the medium and the
likelihood that the medium is contaminated with chemicals from Love Canal.
Application of these criteria to each of the possible media is described below.

6.1.1 Air

If ambient (outdoor) air is contaminated with chemicals from Love Canal,
many or all residents of the EDA will be exposed.  Outdoor air might be
affected by emissions from the site or the treatment plant, or possibly, by
volatilization from contaminated soils. Indoor air could, in some cases, also
be affected by chemicals volatilizing from subsurface soils into basements
or crawl spaces. While this process might affect only a limited number of
residences, it could result in indoor air exposure levels considerably higher
than in ambient air. On this basis, both indoor and outdoor air were selected
as comparison media.
                              6-1

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6.1.2  Soil

Previous studies have revealed that soil in the immediate vicinity of Love
Canal was contaminated by a variety of chemicals. In addition, contaminated
soil from close to the Canal was used in at least one case as fill material at
another location in the EDA (the 93rd Street School) and may have been used
at other locations as well. Most humans are exposed to soil through inciden-
tal ingestion of soil from the hands or on food, from inhalation of soil par-
ticles  suspended in air, or by dermal contact with soil, especially during
activities such as gardening, excavation work, or children playing outdoors.
On this basis, soil was selected as an appropriate comparison medium.

6.1.3  Surface Water

Surface water was excluded as a sampling medium for the Habitability Study
because soil sampling  was judged to be preferable and more meaningful.
When present, standing surface water is chiefly the result of precipitation
that has not evaporated or been absorbed into the soil.  Chemical levels
measured in standing surface water would be a reflection of those in the soil
on which the surface water lies.  Also, soils will contain all contaminants
present, while surface water will contain primarily the water-soluble com-
pounds.  Finally, human contact with standing surface  water is usually
limited and intermittent.

The only permanent bodies of surface water in the EDA are Bergholtz and
Black Creeks. Sediments in some parts of the creeks were previously con-
taminated by discharges from storm and sanitary sewers. However, because
the remedial plan for the EDA specifies that these creeks will be excavated
and remediated, the creeks were not selected as comparison media.

6.1.4  Shallow Ground Water and Basement Seepage

Shallow (subsurface) ground water and seepage found in basement sumps
were not selected as environmental sampling media, though it was recog-
nized that, should contaminated water leak into basements, it would settle in
sumps, and volatile chemicals could escape into the air. However, sumps
also serve as a collection point for spilled domestic products, and  these
chemicals could obscure measurements of Love Canal chemicals. For pur-
poses of the Habitability Study, indoor air sampling in basements was judged
                                6-2

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to be the most direct and relevant index of exposure to Love Canal con-
taminants that may be transported through shallow ground water into base-
ments.

6.1.5 Deep Ground Water

Ground water is not currently used as a source of domestic water supply in
the EDA, and it is unlikely to be used for this purpose in the future. There-
fore, ground water does not represent an exposure source for EDA residents,
and it was excluded as a comparison medium for this reason.

Periodic ground water monitoring in and around the Canal is included as one
of the special provisions required  by the Habitability Criteria and is an in-
tegral part of the remedial program. Monitoring wells of varying depths are
currently located around the Love Canal site at  varying distances from the
Canal. Monitoring of ground water from these wells will be continued into
the future.

References for Section 6.1: 21,22,32,48,61, 86 (pp. 26-28, Appendix 11),
114, PR-1 (pp. 280-297, 368-377), PR-2 (Sect. 2.5), PR-3 (pp. 16-19), PR-
4 (Sect. 2.6.1 to 2.6.5), TRC (02/21/85, 03/14/85, 04/11/85), SRP (79-80,
302-304, 333-377, 408-410, 455-458, 615-616, 826-838, 876-883, 1582-
1589, 2053-2072,2236-2275)
6.2  SELECTION OF COMPARISON CHEMICALS

Given that the comparison of the EDA to other areas would be made on the
basis of concentrations of chemicals in soil and air, it was necessary to select
the specific chemicals that would be measured.  One possibility was to
analyze for each chemical suspected of having been deposited in Love Canal.
However, this list is rather large (a minimum of 200 different chemicals and
perhaps a great many more), and analyzing a large number of samples for
each of these chemicals would have been very difficult.  Indeed, adequate
analytical techniques with the necessary sensitivity  and specificity do not
exist for many of the chemicals, especially in soil. Thus, it was a practical
necessity that analyses be performed for only a subset of all the chemicals
that are known or suspected to have been deposited in Love Canal.  Three
basic subsets of chemicals were considered, as described below.
                                6-3

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6.2.1  AH Love Canal Chemicals for Which Adequate Analytical
Techniques Exist

The first possibility was to select chemicals solely on the basis of whether or
not it is possible to perform reliable chemical analyses in soil and air. This
"broad-brush" approach had the advantage that it would provide the maxi-
mum amount of information concerning the levels and location in the EDA
of environmental pollutants from the Love Canal. However, there were three
significant disadvantages to this approach.  First, it would still have been
very time-consuming and costly to perform analyses of sufficient specificity
and reliability, that also had a sufficiently low detection limit for a large num-
ber of different chemicals in the samples. Second, when many different vari-
ables are  measured and compared among multiple  groups, it  is a near
statistical certainty that some differences among the groups will appear to be
real when, in fact, they are a consequence of random variation. Third, many
of the chemicals in the Love Canal are also widely distributed in the environ-
ment, and detection of these chemicals in the EDA would not distinguish
whether they arose from Love Canal or other sources. Based on these con-
siderations, it was concluded that this approach should not be employed and
that a more limited subset of chemicals should be selected for analysis.

6.2.2 Most Toxic Chemicals

The second possibility was to select a subset of chemicals on the basis of
their toxicity. This approach assumes that if human health risk from the most
toxic chemicals is minimal, then health risk from other less toxic chemicals
is also minimal. However, this may not necessarily be so, especially if large
numbers and/or high concentrations of the less  toxic chemicals are present.
In addition, while it may be possible to select a list of the most highly toxic
Love Canal chemicals based on current knowledge, that list might later prove
to be inadequate, due to discovery of previously unrecognized adverse health
effects of other chemicals at the site or to the discovery of previously un-
recognized toxic chemicals in Love Canal. For these reasons, this approach
was considered inadequate.

6.2.3 Indicator Chemicals

A third option was to select a group of chemicals based on  their ability to
migrate from Love Canal into the EDA and to persist there.  This approach
                                6-4

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is based on the concept that the location of the most highly mobile chemical
present in a landfill will mark the outer boundary of any chemical migrations
from the site.  This approach had the advantage that attention could be
focused on only a few specific chemicals, allowing optimization of analyti-
cal detection limits, accuracy, and reliability, and this in turn would reduce
statistical difficulties in data interpretation. In addition, the approach is in-
herently conservative, since elevated levels of an indicator chemical at a loca-
tion do not prove that any chemicals of health concern are also present at that
location.  For these reasons, this approach was  selected as the most ap-
propriate.

6.2.4 Indicator Chemical Selection Criteria

Based on the general concept of indicator chemicals as described above, the
following characteristics were judged to be important properties of any LCIC
selected.

6.2.4.1  Presence in Love Canal.  If a chemical is to serve as a marker of
chemical migration from a landfill, it is evident that the chemical must have
been deposited in the landfill. For this reason, only chemicals that are known
to or likely to have been disposed of in Love Canal were considered. Detec-
tion of a chemical in the present-day leachate from the site (that is, in the in-
fluent  to the treatment  plant) was a useful  but not  essential means of
confirming the prior disposal of a chemical in the Love Canal landfill.

6.2.4.2 Migration Potential. As discussed above, a key characteristic of a
suitable indicator chemical is a high migration potential in the medium of
concern. For soil, migration potential correlates with good water solubility
and relatively low adherence to  soil particles.  For air,  it correlates with
adequate volatility to ensure significant escape into air.

6.2.4.3 Analytical Suitability. It is important that for each indicator chemi-
cal, analytical techniques exist that have detection limits low enough that
levels in the EDA and comparison areas can be measured. One way to en-
sure this was to focus on chemicals that were previously detected at least
once in the EDA, since this is direct evidence that available methods are ade-
quate to detect the levels likely to be encountered in the EDA.  In addition,
the analytical method for the chemical must  be specific (i.e., able to
                                 6-5

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distinguish the indicator from other chemicals) and reliable (i.e., able to give
reproducible results within acceptable limits of variation).

6.2.4.4 Environmental Persistence. One concern in the EDA is that chemi-
cals that reached the area in the past (before remediation) may still persist.
For this reason, indicator chemicals must be relatively stable in the environ-
ment, resisting degradation by both chemical and biological pathways. This
characteristic ensures that they will adequately indicate past as well as cur-
rent sources of exposure.

6.2.4.5 Specificity (Ubiquity). As discussed in Section 3.2 (Consideration
of "Background" Chemicals), one of the factors that complicates the com-
parative approach is that chemicals in the EDA may have arisen either from
the Love Canal or from outside sources, or both.   The problem posed by
"ubiquitous" chemicals (those that are common in the environment) is two-
fold: first, the presence of a substantial background level of a chemical in
the EDA greatly diminishes the ability to detect a small increase due to an
emission from Love Canal; and second, variations in the level of background
chemicals between the EDA and the comparison areas can lead to faulty con-
clusions. For example, the level of a ubiquitous chemical might be higher
in the EDA than the comparison area because the local background emission
rate is high, and not because of emissions from Love Canal.  This situation
would lead to the conclusion that the EDA  was affected by the Canal when
it was not (a false positive).  Conversely, if the background level of a ubiq-
uitous chemical were higher in the comparison area than in the EDA, this
could mask the presence of emissions in the EDA that did derive from the
Canal (a false negative).

Because of these problems, a desirable property of indicator chemicals is that
they  are not likely to be present in the environment (either the EDA or the
comparison areas) as a result of emissions from sources other than Love
Canal.  It is important to reemphasize that this does not mean that ubiquitous
chemicals originating from the waste site are of any less concern than non-
ubiquitous chemicals, only that ubiquitous chemicals are not the best choice
to determine the extent of any migration.

6.2.4.6  Evidence of a Gradient.   One way  to ensure that the chemicals
selected as indicators are appropriate markers of migration from the landfill
is to show that the chemical has a decreasing gradient of environmental con-
centration as  a function of  distance from the site. This characteristic is
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expected of chemicals moving away from the waste site but is not expected
of chemicals which reach the EDA by migration from other locations.

6.2.4.7  Correlation Between Chemicals. An additional means of ensur-
ing that chemicals selected as indicators do, in fact, reflect emissions from
the Love Canal is to show that their levels tend to vary in concert (i.e., they
are correlated). This property is expected of two or more chemicals arising
from the same site and migrating by the same pathway but would not be ex-
pected of chemicals arising from different background sources.

6.2.4.8  Optimal Number of LCICs. There are two opposing considera-
tions that influence the optimum number of indicator chemicals to select. On
one hand, choosing  several LCICs provides  desirable redundancy and
reduces  the chances that random fluctuations in LCIC levels could lead to a
faulty conclusion. On the other hand, choosing a  large number of LCICs
greatly increases the statistical chance of obtaining a false positive result.
Based on these two considerations, it was concluded that at least 2 but less
than 10 LCICs should be selected for each comparison medium.

6.2.5 Selection of Indicator Chemicals

The indicator chemical selection criteria described  above were applied in a
series of steps, as shown in Figure 6-1.  First, a list of all chemicals known
or likely to have been deposited in Love Canal was assembled from avail-
able historical records. This list of chemicals is shown in Table 6-1.  Next,
a number of these chemicals were excluded because of their low mobility or
their lack of stability in the environment, or because they are ubiquitous. The
chemicals that were excluded and the reasons for their exclusion are shown
in Table 6-2.  For the remaining chemicals, historical monitoring data that
met quality assurance reviews were reviewed to determine if the chemical
had been detected at least  once in either the air or the soil of the EDA, and
if so, whether there was evidence of a decreasing concentration gradient from
Rings I and II to the ED A. This analysis is summarized in Table 6-3.  Chemi-
cals that had been detected in the EDA but whose concentrations were either
lower or nondetectable in  Rings I and II (a reverse gradient) were not con-
sidered, since this suggests that some source other than the Canal is more im-
portant.
                                6-7

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   Identify chemicals known or likely
      to have been deposited in
       Love Canal waste site
Exclude chemicals that are non-mobile,
   chemically reactive, biologically
      degradable or ubiquitous
  Exclude chemicals that have never
      been detected in the EDA
    Exclude chemicals that do not
      show a gradient from the
        waste site to the EDA
     Suitable Indicator Chemicals
                                     Figure 6-1
                                     LCIC SELECTION PROCESS
                 6-8

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                               Table 6-1
    CHEMICALS LIKELY TO HAVE BEEN DEPOSITED AT LOVE CANAL
Halogenated Organics

     Carbon Tetrachloride
     Chloroform
     1,1-Dichloroethylene
     Trichloroethylene
     Tetrachloroethylene
     Hexachloroethane
     Hexachlorobutadiene
     Hexachlorocyclopentadiene

Benzene and Derivatives

     Benzene
     Monochlorobenzene
     1,2-Dichlorobenzene
     1,3-Dichlorobenzene
     1,4-Dichlorobenzene
     1,2,4-Trichlorobenzene
     1,2,3,4-Tetrachlorobenzene
     1,2,4,5-Tetrachlorobenzene
     Pentachlorobenzene
     Hexachlorobenzene
     Benzole acid
     Benzoyl chloride
     Benzyl chloride
     Benzal chloride
     Benzotrichloride

Phenols
Naphthalene and Derivatives

     Naphthalene
     Chloronaphthalenes
     Dichloronaphthalenes
     Trichloronaphthalenes

Acids and Derivatives

     Acetic acid
     Acetyl chloride
     Acetic anhydride

Pesticides and Related Products

     a-BHC
     p-BHC
     8-BHC

Metals

     Arsenic
     Antimony
     Chromium
     Copper
Other
     Carbon disulfide
     Dioxin (TCDD)
     2,4-Dichlorophenol
     2,4,5-Trichlorophenol
     2,4,6-Trichlorophenol
     Pentachlorophenol

Toluene and Derivatives

     Toluene
     2-Chlorotoluene
     4-Chlorotoluene

Source: Adapted from Love Canal Emergency Declaration Area: Proposed
        Habitability Criteria (1986)
                               6-9

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                            Table 6-2
 LOVE CANAL CHEMICALS EXCLUDED AS INDICATOR CHEMICALS
Reason for Exclusion
Chemicals Excluded
Chemical Reactivity
Biological Degradability
Ubiquity
Low Migration Potential
Acetyl chloride
Acetic anhydride
Benzoyl chloride
Benzyl chloride
Benzal chloride
Benzotrichloride

Acetic acid
Benzole acid
Dichlorophenol

Benzene
1,4-Dichlorobenzene
Chloroform
Trichloroethylene
Toluene
Naphthalene
Carbon disulfide
Tetrachloroethylene
1,1-Dichloroethylene
Hexachloroethane

Arsenic
Antimony
Copper
Chromium
TCDD
Hexachlorobenzene
Trichloronaphthalenes
Hexachlorobutadiene
Hexachlorocyclopentadiene
Source: Adapted from Love Canal Emergency Declaration Area:
       Proposed Habitability Criteria  ("1986)
                          6-10

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                                                                   Table 6-3
                                   EVALUATION OF CHEMICALS BASED ON DETECTION AND GRADIENT CRITERIA
                                                                               Air
Soil
o\
Class
Solvents
Benzenes






Phenols


Toluenes

Naphthalenes

Pesticides



Chemical
Carbon tetrachloride
Monochlorobenzene
1 ,2-Dichlorobenzene
1 ,3-Dichlorobenzene
1 ,2,4-Trichlorobenzene
1 ,2,3,4-Tetrachlorobenzene
1 ,2,4,5-Tetrachlorobenzene
Pentachlorobenzene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Pentachlorophenol
2-Chlorotoluene
4-Chlorotoluene
Chloronapthalenes
Dichloronapthalenes
a-BHC
P-BHC
•y-BHC
8-BHC
Detected
in EDA
Yes
Yes
Yes
No
No
Yes
No
Yes
No
No
No
Yes
Yes
No
No
No
No
Yes
No
Decreasing
Gradient
No
Yes
No
NA
NA
No
NA
No
NA
NA
NA
Yes
Yes
NA
NA
NA
NA
No
NA
Detected
in EDA
Yes
Yes
Yes
No
Yes
Yes
No
No
No
No
Yes
No
No
Yes
No
Yes
Yes
Yes
Yes
Decreasing
Gradient
No
Yes
Yes
NA
Yes
Yes
NA
NA
NA
NA
No
NA
NA
Yes
NA
Yes
Yes
Yes
Yes
             NA = Not applicable, since chemicals that were never detected in EDA were not considered further
             Source: Adapted from Love Canal Emergency Declaration Area: Proposed Habitability Criteria (1986)

-------
It was originally expected that a large number of candidate LCICs would
remain after this stage of the selection procedure and that application of the
correlation  criterion would be  needed  to  choose a suitable subgroup.
However, application of the criteria above served to reduce the list of can-
didate LCICs to a reasonable number, so a correlation between chemicals
was taken to be desirable, but not essential. The chemicals that met the selec-
tion criteria were:

   • Air LCICs

     Chlorobenzene
     2-Chlorotoluene
     4-Chlorotoluene

   • Soil LCICs

     Monochlorobenzene
     1,2-Dichlorobenzene
     1,2,4-Trichlorobenzene
     1,2,3,4-Tetrachlorobenzene
     2-Chloronaphthalene
     BHCs (p, Y, total)

In order to obtain preliminary information on the typical levels and degree
of variation in soil LCIC concentrations, a pilot soil sampling study was car-
ried out in the EDA and two comparison areas in the Buffalo area (see Sec-
tion 6.3, below). The results of this study revealed that monochlorobenzene
did not occur at measurable concentrations in any of the samples from the
EDA or the comparison areas.  Since analysis of soil for monochlorobenzene
required a separate sample preparation procedure from that used for the other
soil LCICs, it was decided to drop monochlorobenzene from the list of soil
LCICs. Subsequent improvements in the analytical methods for soil LCICs
(see Volume III) allowed two additional BHC isomers (a, 8) to be added,
and so each was employed as a soil LCIC.  Use of the four BHC isomers
replaced the need for total BHC.

A pilot study was also performed to obtain  preliminary data on air LCIC
levels and to assess the suitability of two alternative analytical instruments:
a laboratory-based gas chromatograph coupled to a mass spectrometer
(GC/MS) and a mobile  mass  spectrometer—mass spectrometer termed the
                               6-12

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Trace Atmospheric Gas Analyzer (TAGA). There was close agreement be-
tween the two instruments on blanks, check samples, and test samples. The
TAGA was selected for use in the full-scale Habitability Study because it
yields results in real time and can be used to seek out the source of any LCICs
detected in a residence.

Since the TAGA does not employ a chromatographic column, it does not dis-
tinguish between isomeric forms of chemicals. Therefore, 2-chlorotoluene
and 4-chlorotoluene were combined, and total chlorotoluene was taken as an
appropriate air LCIC.

The  pilot study indicated that very few of  the test samples contained
measurable levels of any air LCICs. For indoor air in occupied homes, only
1 in 30 samples from the EDA and 1 in 31 from the comparison areas had
measurable levels of chlorotoluenes. No detectable levels of chlorobenzene
or chlorotoluenes were observed in samples from 33 unoccupied houses in
the EDA or from outdoor air in either location.

Because the air LCICs were detected so infrequently, it was concluded that
any measurable concentration of LCICs in the EDA should be considered
significant and that analysis of air in the comparison areas was not required.

References for Section 6.2: 8, 9, 11, 45, 86 (pp. 28-31, Appendix 9), PR-1
(pp. 88-226, 378-386), PR-2 (Sect. 2.4, Appendix 2), PR-3 (pp. 10-13, 30-
33, 87-88, 117-122, 212-250), PR-4 (Sect. 2.4.1  to 2.4.6), TRC (02/21/85,
03/14/85, 11/21/85, 09/04/86), PR-5 (354-368),.SRP (594-615, 826-838,
1204-1214,1567-1589, 1654-1687,2236-2275)
6.3  SELECTION OF COMPARISON AREAS

The comparison approach to determining the relative habitability of the EDA
is based on a comparison of environmental sampling results from the neigh-
borhoods and homes of the EDA with those from similar inhabited com-
munities not affected by a chemical landfill.  This method relies on the
comparison area to provide data that corresponds to "normal" or habitable
conditions and that, when compared to similar measurements in  the EDA,
can provide an indication of whether EDA neighborhoods and homes are dif-
ferent from those in other western New York communities.  Critical to the
                               6-13

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success of this approach are the criteria and methodology for selection of the
comparison areas.

6.3.1  Selection Criteria

In principle, an ideal comparison area would be identical to the EDA in all
respects except for the presence of a chemical waste site. A number of selec-
tion criteria were established in order to guide the search for appropriate com-
parison areas and to ensure that the areas selected are as similar to the EDA
as possible.  These selection criteria are described below.

6.3.1.1 General Location. The Niagara Frontier of western New York is
characterized by a relatively  high  density of chemical manufacturing and
other  industrial sites, and halogenated organic compounds are commonly
found in the air in this area.  Consequently, it was important that the com-
parison areas be selected from within this industrialized area to ensure that
background  levels of environmental chemicals in the EDA are  similar  to
those  in the comparison areas. In addition, comparison areas located in the
Niagara  Falls/Buffalo area  are  likely  to  have  meteorological  and
hydrogeological characteristics similar to the EDA, and nearby areas provide
a familiar frame of reference for  residents of the EDA.

6.3.1.2 Distance  from a Waste Site.  While it was  apparent that a com-
parison area must  be sufficiently far from the closest waste site so that it is
not affected by the site, it was  not immediately obvious what distance is ade-
quate  to meet this demand. The distances that any leaking chemicals  will
migrate away from a waste site  depend on the nature and quantity of the
chemicals present, along with the geological, meteorological, and hydrologi-
cal characteristics of the site. Consequently, any single absolute distance
criterion that does not consider site-specific characteristics is essentially ar-
bitrary. Nevertheless, it was  desirable to establish some sort of  minimum
distance criterion in order to guide the process of selecting comparison areas.
Originally, a distance of at least one mile from a chemical waste site  was
proposed.   However,  initial  attempts to locate comparison areas  in the
Niagara Falls/Buffalo  area revealed that, because of the large number  of
known chemical waste sites in the area, there were no suitable residential
neighborhoods located more  than one mile from a waste site.  As a result,
the distance criterion was designated to require that comparison areas  should
                                6-14

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be as far as possible, but no less than one-half mile, from any known chemi-
cal landfill.

6.3.1.3 Soil and Hydrologic Characteristics. As discussed above, the fate
and transport of contaminants released from a chemical landfill are deter-
mined by the chemical characteristics of the leachate and, to a great extent,
by the topographical,  hydrogeologic, and meteorological conditions that
characterize the site. In addition, the ability to extract and detect chemicals
adsorbed to soil may depend upon soil type.  For these reasons, it was im-
portant to ensure that the comparison areas resemble the EDA with respect
to soil type and hydrogeologic and meteorological conditions.

6.3.1.4  Housing Characteristics.  Studies during the last decade have
shown that indoor air quality is strongly influenced  by chemical emissions
from building materials and various household products. For this reason, it
was important that the homes of the comparison areas and the EDA  be
similar.  The most useful parameters available for characterizing the nature
of a residential neighborhood were housing age, density, and value. Hous-
ing value, in particular, was used as  a proxy for the  type of house and type
of living style of the residents as well.  These statistics were available from
the 1980 Census for each census tract in the EDA and in  the surrounding
areas.

If the EDA were fully populated, it would also have been important to match
the EDA and comparison areas with respect to population-based characteris-
tics such as age, sex, race, and income levels. However, since the EDA is
now mostly unoccupied, such characteristics were not directly relevant to the
selection process.

6.3.2  Number of Comparison Areas

Implementation of the comparison approach required selection of at least one
suitable comparison area, but selecting two or more comparison areas was
deemed to have some merit.  The main advantage of sampling in multiple
comparison areas is that more data would be obtained on typical background
levels of environmental contaminants, thereby reducing statistical variations
and uncertainty in the comparative process.
                                6-15

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However, if two or more comparison areas were employed and if these com-
parison areas were significantly different from each other, then it was not
clear how the comparison to the EDA should be made. For example, if the
EDA were "as safe as" one area, but not as safe as the other, what habitability
decision would be appropriate? Assuming that all comparison areas have
acceptable levels of background chemicals, then it could be argued that the
comparison area with the highest background levels should be used for com-
parison to the EDA. It was concluded that at least two comparison areas
should be selected and that the sampling results from these areas would be
treated as one data set for the purposes of comparison with the EDA. The
data from each comparison area would  be maintained separately in case
separate analysis  was later judged to be necessary.

6.3.3  Comparison Areas Selected

Based on the selection criteria described above, areas in western New York
(Niagara and Erie Counties) were evaluated to determine their suitability as
comparison areas for the Habitability Study. The first step in the process was
to identify and characterize the soil types and hydrogeology found in the
EDA. The Sta'te Geographical Survey of the New York State Education
Department characterized EDA soils as lake silt, composed of fine to medium
sand and clay. The overburden was characterized as thin bedded to massive,
and in part, regularly bedded with cyclic alteration to clay and silt laminae
and moderately permeable along bedding surfaces. The circumstances lead-
ing to this geological formation were offshore deposits from lakes and basins
that did not require an impounding ice margin for closure and hence persist-
ed after deglaciation.

The second step in the process was to identify areas in Niagara and Erie Coun-
ties with similar soils and to display them on a map.  Chemical waste dis-
posal  sites listed in the most current New York State Registry of Sites (1984)
and on the Community Right-To-Know List were located on the same map,
as were census tract boundaries. Census tracts with borders one-half mile or
less from known waste sites were excluded from further consideration.

The remaining tracts, all at least one-half mile from any known chemical dis-
posal  site, were then rank-ordered according to distance from the nearest site
and compared to the EDA for similarity with respect to prevailing winds from
                               6-16

-------
major  industrial  air  emission  sources  and  with respect to selected
socioeconomic indicators such as age and value of housing.

Starting with census tracts that were located closest to chemical waste dis-
posal sites, census tracts that represented the poorest match with the census
tracts composing the EDA were rejected until the list was reduced to six
tracts. These were Erie County tracts 38,40, 80.02, 80.03,101.02, and 103.

NYSDOH staff reviewed all available data and information on any  chemi-
cal waste disposal sites located within 8,000 feet of these six tracts. The dis-
posal sites were inspected to assess any potential for offsite migration that
might affect the census  tracts under  consideration as comparison areas.
Based on this review, two census tracts, 38 and 103, were excluded from fur-
ther  consideration because it was determined that the Scajaquada Creek
flowed beneath them after receiving permitted industrial discharges.

A panel of eight individuals (two representatives from the NYSDOH, one
representative from the NYSDEC, and five residents of the EDA) inspected
the remaining four sites (40, 80.02, 80.03,  and 101.02)  for visual com-
parability with the EDA.  Neighborhoods within each census tract were
determined by panel consensus to be "acceptable" or "not acceptable," and
the most suitable neighborhoods were identified for comparison to the EDA.
Based on this review, neighborhoods within Tonawanda Census Tract 80.03
and Cheektowaga Census Tract 101.02 were selected as the most appropriate
comparison areas.

With two comparison areas identified in the Buffalo area, a pilot sampling
study was carried out to provide information on the typical levels and degree
of variation in soil LCIC concentrations in the EDA and the comparison
areas. This study revealed that two soil LCICs (1,2,4-trichlorobenzene and
1,2,3,4-tetrachlorobenzene) occurred  at measurable levels  in more  than
30 percent of the samples from the EDA, but were detectable in less than
2 percent of the samples from the comparison areas.  However, this  pattern
was not observed for any of the other soil LCICs, suggesting the possibility
that these two contaminants might have reached the EDA from some local
source other than the Love Canal waste site.

In order to determine whether soil contamination with 1,2,4-trichloroben-
zene and 1,2,3,4-tetrachlorobenzene was widespread or restricted to the
EDA, the NYSDOH collected a number of soil samples from four different
                                6-17

-------
regions in the Niagara Falls area, including the EDA and one area in Buf-
falo. The results of this study indicated that significant differences existed
between the levels of these chemicals in the sites in Niagara County (includ-
ing the EDA) and the comparison site in Buffalo. This finding presented a
significant complication to the implementation of the full-scale soil sampling
plan. A number of alternatives were considered for addressing this problem,
as summarized in Table 6-4.

Alternative 1 (no change from the original plan) was rejected because it
would not allow an assessment of the effect of the Love Canal waste site on
the EDA, independent of the influences of other sources of environmental
pollutants in the Niagara  Falls area.  Alternative 2 (deletion of  1,2,4-
trichlorobenzene and 1,2,3,4-tetrachlorobenzene as LCICs) was rejected be-
cause these chemicals had met all the  selection criteria  for LCICs, and
deletion of these chemicals would render the design of the full-scale study
uncertain and could become a source of public concern.  Alternative 4
(replacing the original comparison areas with new areas in Niagara Falls)
was rejected because the original comparison areas had been selected in
accordance with the specified criteria, while the NYSDOH areas had not
specifically been selected to meet the criteria.

Alternatives 3 and 5 are similar in that they retain all LCICs and the original
comparison areas,  while adding one  or more new comparison areas in
Niagara Falls.  The alternatives differ only in whether  all LCICs or only
1,2,4-trichlorobenzene and 1,2,3,4-tetrachlorobenzene would be measured
in the Niagara Falls areas. Of these, alternative 3 .(analysis for all LCICs in
all comparison areas) was selected as the most appropriate.

Consequently, a search was undertaken to identify suitable comparison areas
in the Niagara Falls area. Based on a review of areas in  Niagara Falls near
the EDA but at least one-half mile from any known chemical waste site, two
neighborhoods (portions of Census Tracts 221 and 225) were selected as
comparison areas. The LaSalle neighborhood (Census Tract 221) had been
employed as a control area during earlier studies based on similarities of
socioeconomic   characteristics  to the  EDA,  and   both  areas   have
hydrogeological characteristics similar to the EDA. If concentrations of any
LCIC are found to be significantly higher in the EDA than in the Buffalo
comparison areas, then the Niagara Falls comparison areas should be com-
pared to both the EDA and the  Buffalo comparison areas. The purpose of
this comparison would be to determine whether the concentrations are unique
                                6-18

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                               Table 6-4
ALTERNATIVE MODIFICATIONS TO SOIL LCIC COMPARISON PROCEDURE
Alternative
Comparison Areas
LCICs
    1        Retain original areas

    2        Retain original areas
             Retain original areas; add
             new areas from Niagara Falls

             Replace original areas with
             new areas from Niagara Falls

             Retain original areas; add
             new areas from Niagara Falls
                          Retain all LCICs

                          Delete 1,2,4-trichlorobenzene
                          and 1,2,3,4-tetrachlorobenzene

                          Retain all LCICs
                          Retain all LCICs
                          Retain all LCICs for original
                          areas; analyze for 1,2,4-tri-
                          chlorobenzene and 1,2,3,4-
                          tetrachlorobenzene only in
                          Niagara Falls area
Source: Adapted from Pilot Study for Love Canal EDA Habitability Study,
        Volume II (1987)
                               6-19

-------
to the EDA or indicative of regional sources other than known toxic waste
disposal areas.

Figure 6-2 depicts the  location  of the four comparison areas that were
selected in relation to known chemical waste sites and to the EDA.

References for Section 6.3: 34, 84, 85, 86 (pp. 23-26) PR-1 (pp. 269-279),
PR-2 (Sect. 2.6), PR-3 (pp. 13-21, 137-157, 172-175), PR-4 (Sect. 2.5.1 to
2.5.6, 2.8.1), TRC  (02/21/85, 03/14/85,  04/11/85, 08/05/85,  10/07/85,
11/21/85, 01/21/87,  03/31/87, 04/10/87), PR-5 (406-410, 545-546), PR-6
(Sect. 3.0), SRP (716,1804-1805,1871-1891,2164-2234)
6.4  SELECTION OF NEIGHBORHOOD BOUNDARIES

As discussed in Section 3.3 (Evaluation by Residences and Neighborhoods),
the basic unit of the Habitability Study was an individual residence, but
evaluating the habitability of the EDA on a neighborhood scale also seemed
appropriate.   In general,  neighborhood boundaries may be based  on
geographic barriers (creeks, roads, etc.), community interactions (schools,
churches, etc.), or social distinctions (income, ethnicity, etc.).

For statistical reasons, the size of the neighborhoods is also an important con-
sideration. If a large number of small neighborhoods were demarcated, there
would be a high statistical probability that one or more of the neighborhoods
would, by chance variations alone,  appear to be different from the com-
parison areas when, in fact, there was no real difference (a false positive).
This problem is diminished by increasing the size (and decreasing the num-
ber) of neighborhoods, but this approach decreases the ability to detect local
areas of elevated chemical levels and increases the potential of declaring a
large part of the EDA uninhabitable even if only localized contamination is
found.

Figure 6-3 displays a set of boundaries that divide the EDA into 13  neigh-
borhoods.  These boundaries were established by sociologists on the basis of
roadway and waterway patterns, the distribution and location of housing
units, and the patterns of social interactions among remaining and former
residents.  The 93rd Street school site in the northwest portion of the EDA
was  not included, since this is being evaluated separately. To reduce the
                               6-20

-------
                                                     TOWN OF
                                                     PENDLETON
                                                   NIAGARA CO.
                                                   ! ERIE  CO.
O   O  O
                          TOWN OF
                         WHEATFIELD
     NIAGARA  O
                              NORTH
                           TONAWANDA
                          TONAWANDA
                             O
                                                   TOWN OF
                                                   AMHERST
                                 TOWN OF
                                TONAWANDA
                             ; KENMORE ,'   ^ C %
  A - Census Tract 221
  B - Census Tract 225
  C - Census Tract 80.03
  D - Census Tract 101.02
                                                 CHEEKTOWAGA
                                                      00
                                                      D    D
  O - NYS Registry Sites
    - Rlght-to-Know Sites
Figure 6-2
                                          ONE INCH = ABOUT 2.2 MILES
MAP OF WASTE SITES AND COMPARISON  AREAS IN
NIAGARA AND  ERIE  COUNTIES
                                  6-21

-------
                       MflO
                           S/Tf
                  ; (UKtXn SEPAflATF STUDY)
Rgure 6-3
                                                       ^
MAP OF NEIGHBORHOOD BOUNDARIES
IN  THE EDA
Niagara  Falls.  New  York
SCALE: r*eev  *
LEGEND
'— NEIGHBORHOOD BOUNDARY
	FENCE LINE AROUND LOVE CANAL REMEDIATION SITE
SOURCE: ADAPTED FROM LOVE CANAL EMERGENCY DECLARATION AREA:
       PROPOSED HABITABILITY CRITERIA (1986)
:
i
fe
f
i




.
r~—
\
5 k
] 1
I
t
3 !
r>
r^Q A'y'ft
1 i
T
i
?
i
—

5





3
3SZ&3
^^
                                          6-22

-------
statistical chances of a comparison falsely indicating a significant difference
and to reduce the range of spatial sampling densities, some of these original
13 neighborhoods were combined to yield seven sampling areas, as shown
in Figure 6-4. These areas were considered to be the most appropriate a priori
divisions, but the option was kept to redefine some boundaries after sampling
was completed in order to minimize the impact of any areas that might be
found nonhabitable and to maximize the amount of contiguous habitable
area.

References for Section 6.4:  20, 86 (Appendix 8), PR-1 (pp. 386-402), PR-2
(Sect. 2.9), TRC (03/14/85,  04/11/85, 09/04/86),  PR-5 (538-542),  SRP
(1604-1606,1777-1783,1806-1808,2309-2311)
                               6-23

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Figure  6-4
MAP OF  EDA  SAMPLING  AREAS
SCALE: f-6501
LEGEND
 	13 EMERGENCY DECLARATION AREA (EDA) NEIGHBORHOOD BOUNDARY
 — • •- FENCE LINE AROUND LOVE CANAL REMEDIATION SITE
     ~~7 EDA SAMPLING AREA BOUNDARY


 SOURCE:  ADAPTED^FROM LOVE CANAL EMERGENCY DECLARATION AREA:
        PROPOSED HABITABILITY CRITERIA (1986)
•02/s'O S7
  • A.'.'OP
                                               6-24

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       7.0  SAMPLING AND ANALYSIS PLAN
One of the major criticisms  voiced by OTA regarding  the  original
EPA/DHHS habitability evaluation was that an insufficient number of
samples had been taken in the EDA and in the comparison area and that
analytical methods employed may not have had sufficiently low detection
limits, especially for the analysis of soil.  Consequently, considerable care
was taken in the data collection phase of the Habitability Study to ensure that
the number of samples and the analytical detection limits would be adequate
to yield an unambiguous result.

This involved development and validation of sample collection protocols,
analytical methods, and quality assurance procedures. In order to test the
adequacy of the sampling and analysis plans, pilot studies were performed
for the analyses of LCICs both in air and in soil. These pilot studies allowed
for refinements and improvements in sampling and analysis methods that
were incorporated into the full-scale protocols. The details of these sampling
and analysis procedures are presented in the appropriate sections of the fol-
lowing volumes, which describe the analysis of LCICs in air (Volume II) and
soil (Volume IE) and the analysis of TCDD in soil (Volume IV).

References for Section 7.0: 84, 85
                               7-1

-------
                           REFERENCES
Index
 No.
Title
Source
Date
   1    Use of Small Mammals (Voles) to
       Assess a Hazardous Waste Site at
       Love Canal, Niagara Falls, New
       York

   2    Pilot Cytogenetic Study of the
       Residents of Love Canal

   3    Love Canal Emergency Declaration
       Area (EDA) Strategy for Deter-
       mination of Habitability

   4    Public Review Draft: Data Col-
       lection and Evaluation Support,
       Love Canal Remedial Action Plan,
       Draft-Phase I Work Plan

   5    Summary of Love Canal Well Data
       Base Compiled by NYSDEC

   6    First Complete Love Canal Non-
       Confidential Document Citations
       Listing

   7    Second Complete Love Canal Non-
       Confidential Document Citations
       Listing

   8    List of Chemicals from Love Canal
       and Other Areas

   9    Love Canal Marker Chemical Data
       Summary

  10    Summary of Love Canal
       Environmental Data Collection
       Efforts by Medium

  11    Love Canal Target Chemicals

  12    Love Canal QA Review & Assessment
       Technical Memorandum No. 1
       Phase A Results

  13    Printouts of Data from EPA,
       NYSDEC, and Malcolm Pimie
       Data Bases

  14    Love Canal Sewer and Creek
       Remedial Alternatives Evaluation
       and Risk Assessment
                     Archives of Environmental   00/00/83
                     Contamination & Toxi-
                     cology: 12:383-397
                     M.H. Rowley, etal.

                     Biogenics                 05/14/80
                     Centers for Disease Control  03/00/84



                     CH2MHILL              03/17/84




                     NYSDEC/CH2M HILL     No Date


                     CH2M HILL              04/24/84



                     CH2M HILL              06/22/84



                     CH2MHILL              06/27/84


                     CH2MHELL              07/25/84


                     CH2MHILL              07/10/84



                     CH2MHILL              09/06/84

                     CH2MHILL              10/29/84



                     CH2MHILL              10/31/84



                     CH2MHILL              03/01/85
                                   R-l

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                            REFERENCES
                               (continued)
Index
 No.
Title
Source
Date
  15   Love Canal's Unhealthy Voles
  16   Aerial Assessment of Leachate
       Contamination Associated with the
       Landfill Site

  17   Love Canal Contaminant Movement
       Study

  18   Love Canal Remedial Project-
       Task V--A Borehole Investiga-
       tion, Vol. I, Text

  19   Love Canal Remedial Project-
       Task V--A Borehole Investiga-
       tion, Vol. II, Appendices

  20   Interim Status Report on Growth
       and Maturation Study

  21   Personal Exposure to Volatile
       Organics and Other Compounds
       Indoors and Outdoors-the TEAM
       Study

  22   Monitoring Individual Exposure
       Measurements of Volatile Organic
       Compounds in Breathing-Zone Air,
       Drinking Water and Exhaled Breath

  23   Environmental Monitoring at Love
       Canal Vol. I, Vol. II Parts I
       & II, and Vol. Ill

  24   Carcinogen Assessment Group's
       Cancer Risk Estimation Procedure
       for Selected Carcinogens in Love
       Canal Area Housing

  25   Surface Soil Sampling Protocol
       2,3,7,8-TCDD at Love Canal EDA

  26   Permitting Requirements for Land
       Disposal Facilities

  27   Analysis of a Groundwater Contam-
       ination Incident in Niagara
       Falls, NY
                     Natural History: 10:8-16      00/00/83
                     J.J. Christian

                     Cornell University          08/04/78
                     Earth Dimensions, Inc.       00/00/79
                     E.C. Jordan                10/00/83
                     E.C. Jordan                10/00/83
                     Environmental Defense      08/06/81
                     Fund

                     EPA                     06/19/83
                     Lance Wallace                to
                                               06/24/83
                     EPA                      00/00/82
                     Lance Wallace
                     EPA                      05/00/82
                     EPA                      11/14/79
                     EPA                      10/26/84
                     Federal Register            07/26/82
                     Fred C. Hart Associates      07/28/78
                                    R-2

-------
                           REFERENCES
                              (continued)
Index
 No.
Title
Source
Date
  28   HHS Evaluation of Results of
       Environmental Chemical Testing
       Performed by EPA in the Vicinity
       of Love Canal-Implications for
       Human Health

  29   HHS Response to Office of
       Technology Assessment Report

  30   Occidental Chemical Company
       (Hooker) (OCC) Critique of
       Malcolm Pirnie Report

  31   Cytogenetic Findings in Persons
       Living Near the Love Canal

  32   The Groundwater Monitoring
       Program at Love Canal, Vol. I:
       Final Report

  33   The Groundwater Monitoring
       Program at Love Canal, Vol. II:
       Well Logs and Diagrams

  34   DRAFT FINAL REPORT:
       Hydrogeology of the Love Canal
       Area

  35   Lewis Steel to Norman Nosenchuck
       RE: Malcolm Pirnie Report, Site
       Investigations and Remedial
       Action Alternatives-Love Canal

  36   Fact Sheet and Map
  37   Site Investigations and Remedial
       Action Alternatives-Love
       Canal

  38   Rebuttal to the OCC (Hooker)
       Critique of the Malcolm Pirnie
       Report, Site Investigations and
       Remedial Action Alternatives-
       Love Canal

  39   Evaluation of Site Investigations
       and Remedial Action Alternatives
       for Love Canal Task Areas II,
       III, IV, VI, and VII
                     Department of Health and     10/07/81
                     Human Services
                     Department of Health and    07/19/83
                     Human Services

                     Hooker Chemical & Plastics  No Date
                     Corp.
                     JAMA:251(11):1437-1440   03/16/84
                     C.W. Heath, etal.
                     JRB Associates
                     JRB Associates
                     JRB Associates
                     Malcolm Pirnie, Inc.
                     Malcolm Pirnie, Inc.
                     Malcolm Pimie, Inc.
                 09/00/81
                 09/00/81
                 11/07/80
                     Love Canal Renter's Assoc.  01/06/84
                     Love Canal Area Revitali-   No Date
                     zation Agency, R.J. Morris
                 10/00/83
                 03/29/84
                 08/12/83
                                   R-3

-------
                           REFERENCES
                             (continued)
Index
 No.
Title
Source
Date
  40   Analysis of Human Blood Samples
       for Selected Toxic Substances

  41   Health Study Faces Review Before
       Release

  42   Data in Health Study at Canal
       Called Fake

  43   6 NYCRR PART 360-Solid Waste
       Management Facilities (excerpts
       pertain to site characteristics
       and design)

  44   Love Canal: Public Health Time
       Bomb

  45   A Special Report to the
       Government and Legislature-Love
       Canal

  46   Epidemiologic Studies and Outcome
       ofPregnancies

  47   Determination of 2,3,7,8-
       Tetrachlorodibenzo-p-Dioxin in
       Sediment Samples from the Love
       Canal Storm Sewers, Black and
       Bergholtz Creeks

  48   OCC Chemicals in the EDA
  49   Liver Function Tests-Love Canal
       Families

  50   Medical Records Review-Love
       Canal Families

  51   Health Implications of Materials
       Found in or Associated with the
       Love Canal

  52   Preliminary Report-Epidemiology

  53   Analysis of Water Samples
       Collected at Love Canal

  54   Soils Report
                    Midwest Research Institute   08/15/80
                    Newspaper-Niagara Gazette  03/28/82
                    Newspaper-Buffalo News   03/27/82
                    New York State




                    NYSDOH


                    NYSDOH



                    NYSDOH


                    NYSDOH
                    NYSDOH
                    Dr. Robert H. Huffaker

                    NYSDOH
                    NYSDOH


                    NYSDOH



                    NYSDOH

                    NYSDOH


                    NYSDOH
                 03/09/82




                 09/00/78


                 04/00/81



                 No Date


                 No Date
                 03/13/84


                 00/00/78


                 No Date


                 11/20/78



                 07/27/78

                 06/03/78


                 10/02/78
                                  R-4

-------
                          REFERENCES
                            (continued)
Index
No.
55
56
57
58
59
60
61
62
63
64
65
Title
Air Samples of Basements at Love
Canal
Epidemiological Data (published
and unpublished)
Adverse Pregnancy Outcomes in the
Love Canal Area
Report on Chemicals Found in the
Blood of Love Canal Residents
Love Canal Soil Analyses
Love Canal Litigation Soil
Sampling
Analysis of Love Canal First Ring
Air and Sumps
Survey of Chemical Contamination
in Love Canal Storm Sewers
Habitability of the Love Canal
Area, An Analysis of the
Technical Basis for the Decision
on the Habitability of the
Emergency Declaration Area
Controversy at Love Canal
Low Birth Weight, Prematurity and
Source
NYSDOH
NYSDOH
NYSDOH
NYSDOH
NYSDOH
NYSDOH
NYSDOH
O.H. Materials
Office of Technology
Assessment
Hastings Center Report
Dr. Beverly Paigen
Dr. Beverly Paigen
Date
01/23/84
No Date
No Date
01/18/80
00/02/81
02/02/81
06/03/82
06/03/80
06/00/83
06/00/82
No Date
     Birth Defects in Children Living
     Near the Hazardous Waste Site,
     Love Canal, and

     Prevalence of Health Problems in
     Children Living Near the
     Hazardous Waste Site, Love Canal

66   Growth and Health of Children
     Living Near Love Canal

67   Cancer Incidence in the Love
     Canal Area

68   Volatile Organic Chemicals in the
     Atmosphere-An Assessment of
     Available Data
Dr. Beverly Paigen         No Date
Dr. Beverly Paigen         04/29/83
Science:212:1404-1407      06/19/81
D.T. Janerich, et al.

SRI International           04/00/83
                                  R-5

-------
                          REFERENCES
                             (continued)
Index
No.
Title
Source
Date
69   The Rationale and Methodology of
     Quantifying Sister Chromatid
     Exchange in Humans
70   Quantification of Toxic Materials
     in Ambient Air at "Old Love
     Canal," Niagara Falls, NY

71   Community Relations Plan for
     Remedial Actions at Love Canal
     Hazardous Waste Site, Niagara
     Falls, NY

72   New York State Hazardous Waste
     Treatment Facilities Task Force.
     Final Report. Appendix 2--
     Siting Criteria and Procedure/
     Suggested Revisions to State Law
     and Regulations

73   Draft TRC Public Participation
     Twelve Point Review

74   EPA Scientist Resigns in Leakage
     Controversy

75   Troubled Waters. A Dirty Niagara
     Feeds Lake Ontario

76   Love Canal Data Sources

77   Love Canal Sources

78   Environmental Monitoring at Love
     Canal. Vols. 1,2, and 3

79   Quality Assurance Project Plan
     for Air Sampling Pilot Plan,
     Love Canal Habitability Study

80   Data Report on Love Canal
     Habitability Study
Mutagenicity:  New         00/00/82
Horizons. In:  Genetic
Toxicology. New York,
Academic Press. A.H.
Carrano and D.H. Moore, II

EPA                     No Date
E.D. Pellizzari
EPA                     No Date
N.Y. State Hazardous Waste 03/00/85
Task Force
EPA                     08/15/84
Niagara Falls Gazette       04/26/85
Operation Clean Niagara    No Date
CH2MHTLL

CH2MHILL

EPA


CH2MHTLL
EPA
M.W. Holdren,
D.W. Joseph,
D.E. Smith, et al.
No Date

05/00/84

00/00/82


00/00/86



00/00/86
                                  R-6

-------
                           REFERENCES
                              (continued)
Index
 No.
Title
Source
Date
  81    Quality Assurance Project Plan
       for Analysis of Love Canal
       Indicator Chemicals in Soil Pilot
       Study. Appendix B of Love Canal
       Emergency Declaration Area
       Habitability Study

  82    Superfund Public Health
       Evaluation Manual

  83    Love Canal~The Truth  Seeps Out
  84   Pilot Study for Love Canal EDA
       Habitability Study, Vol. I

  85   Pilot Study for Love Canal EDA
       Habitability Study, Vol. II

  86   Love Canal Emergency Declaration
       Area: Proposed Habitability
       Criteria
  87   Love Canal Chemicals

  88   Love Canal Habitability Study--
       Soil LCIC Sample Data Use

  89   Love Canal Full-Scale Air
       Sampling Study Quality Assurance
       Project Plan

  90   Love Canal Full-Scale Air
       Sampling Study Quality Assurance
       Project Plan, Revision No. 2

  91   Love Canal Full-Scale Air
       Sampling Study Quality Assurance
       Project Plan, Revision No. 3

  92   Love Canal Dioxin Soil Sampling
       Study Quality Assurance Project
       Plan

  93   Revision to Love Canal Dioxin
       Soil Sampling Study Quality
       Assurance Project Plan
                     CH2MHELL
                 00/00/86
                     EPA
                     The Reason Foundation
                     E. Zuesse

                     CH2MHILL
                     CH2MHILL
                     NYSDOHandU.S.
                     Department of
                     Health and Human
                     Services

                     NYSDEC

                     CH2MHELL
                     Bruce Peterson

                     CH2MHILL
                     CH2MHILL
                     CH2MHILL
                     CH2MHILL
                     CH2MHILL
                 10/00/86


                 00/00/81


                 02/00/87


                 03/00/87


                 12/00/86




                 No Date

                 12/03/87


                 07/00/87



                 09/00/87



                 10/00/87



                 11/03/86



                 04/06/87
                                   R-7

-------
                           REFERENCES
                             (continued)
Index
 No.
Title
Source
Date
  94   Love Canal Habitability Study--
       Soil Sample Collection and
       Preparation Quality Assurance
       Project Plan

  95   Love Canal Habitability Study--
       Soil Sample Laboratory Analysis
       Quality Assurance Project Plan

  96   Summary of Responses to Peer
       Review of the Pilot Study for the
       Love Canal EDA Habitabili ty
       Study, Volumes I and II

  97   Cayuga Creek Dioxin Sampling of
       Fish and Sediment

  98   Site Investigations and Remedial
       Action Alternatives, Love Canal

  99   Love Canal Treatment Plant
       Influent Data Summaries 1979 to
       Present (Letter to J. Heaton from
       P. G. Waite, NYSDEC)

 100   Proposed Plan for Love Canal
       Creeks and Sewers

 101   Legal Constraints

 102   Air Study No. 181. Love Canal
       (Phase I). Final Report.
       December 1982-March 1983

 103   Air Study No. 181. Love Canal
       (Phase II). Final Report. June
       1983-November 1983

 104   Love Canal Monitoring Reports
       April 1,1984--May 31,1986

 105   Love Canal Perimeter S urvey and
       Long-Term Monitoring Program

 106   Status of Love Canal Remedial
       Projects

 107   Concerns Relative to Love Canal
       Treatment Plant Operations (Memo
       from N. Kolak to N. Nosenchuck)
                     CH2MHILL               10/00/87




                     CH2MHILL               11/00/87



                     CH2MHILL               10/15/87




                     Edward J.Kuzia            01/00/85


                     Malcolm Pirnie, Inc.         10/00/83


                     NYSDEC                  11/18/87




                     EPA                      08/25/87


                     NYSDEC                  No Date

                     NYSDEC                  10/06/83



                     NYSDEC                  No Date



                     NYSDEC                  No Date


                     NYSDEC                  03/12/86


                     NYSDEC                  03/12/86


                     NYSDEC                  03/13/86
                                   R-8

-------
                            REFERENCES
                               (continued)
 Index
 No.
Title
Source
Date
 108   Love Canal Remedial Action
       Project

 109   Additional Sampling of the Black,
       Bergholtz and Cayuga Creeks and
       Extended Sewer Inspection Project

 110   Emergency Declaration

 111   Emergency Declaration

 112   Letter from Stephen D. Luftig to
       Mr. Michael OToole

 113   Health Implications of 2,3,7,8-
       Tetrachlorodibenzodioxin (TCDD)
       Contamination of Residential
       Soil

 114   Board of Education Minutes
 115   Letter from J.E. Schafer to
       David Axelrod, M.D.

 116   Superfund Amendments and
       Reauthorization Act

 SRP   Scientific Review Panel (SRP)
       Meetings to Determine Criteria
       for Rehabitation of Love Canal
       Emergency Declaration Area

PR-1   Peer Review of Love Canal
       Emergency Declaration Area,
       Proposed Habitability Criteria
       (Meeting transcript)

PR-2   Peer Review of the Proposed
       Habitability Criteria for the
       Love Canal Emergency Declaration
       Area.  Peer Review Summary and
       Recommendations Report

PR-3   Public Comment Meeting on the
       Peer Review Summary and
       Recommendations Report (Meeting
       transcript)
                     NYSDEC


                     NYSDEC



                     President Carter

                     President Carter

                     EPA
                     Niagara Falls Board of
                     Education

                     EPA
                     U.S. Congress
                     Public Law 99499

                     NYSDOH and CDC
                     Life Systems, Inc.
                     Life Systems, Inc.
                     Life Systems, Inc.
                 03/13/86


                 02/07/86



                 08/07/78

                 05/21/80

                 01/22/88
                     J. Tox. Environ. Health:     00/00/84
                     14:47-93. R.D. Kimbrough
                     etal.
                 01/21/54


                 10/26/83


                 10/17/86
                 03/14/84
                 through
                 03/27/85
                 03/12/86
                 04/25/86
                 05/12/86
                                    R-9

-------
                           REFERENCES
                              (continued)
 Index
 No.
Title
Source
Date
 PR-4  Peer Review of the Proposed
       Habitability Criteria for Love
       Canal Emergency Declaration Area.
       Public Comments and Peer Review
       Panel Responses

PR-5   Peer Review Meeting on the Love
       Canal Emergency Declaration Area
       Full-Scale Sampling Plan (Meeting
       transcript)

PR-6   Peer Review of the Love Canal
       Full-Scale Sampling Plan.
       Meeting Summary Report

TRC   Technical Review Committee
       Minutes of Meetings from 08/01/83
       to the Present
                     Life Systems, Inc.
                 07/16/86
                     Life Systems, Inc.
                     Life Systems, Inc.
                     TRC
                 03/24/87
                 05/04/87
                 1983 to
                 present
                                   R-10

-------