UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
February 23, 1981 .
ADMINISTRATOR
MEMORANDUM FOR: COURTNEY RIORDAN, Ph.D.
FROM: DOUGLAS B, SEBA, Ph.D.
SUBJECT: ' Recommendations of the Sampling
Protocols Study Group
Enclosed for your use are the recommendations of the
Sampling Protocols Study Group that were developed as a
result of the December llth meeting in Denver, Colorado,
cc; Dr. Dowd
Enclosure
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RECOMMENDATIONS OF THE SAMPLING PROTOCOLS STUDY GROUP
The Study Group has follower! the efforts o£ EPA during the
summer and fall sampling and analyses conducted in the Love Canal
area. We commend the efforts of the personnel involved in this
assay. Considering the constraints of time and money with which
they were presented, they used the best available technology and
worked with a good deal of willingness. The Study Group does,
however, strongly make the following recommendations:
1. This project has been allowed to proceed from
several points of origin and with imposed buget
and time limits, and the problems occurring sub-
sequent to the beginning of the study are based
upon this and the lack of clear objectives.
Therefore, it is recommended that there be set
up, immediately, an authority for the planning of
objectives, statistical, analytical and sampling
protocols, quality assurance, and a significant
useabie end product. To do so would require the
following:
a. Inventorving qroups involved in
emergencies in other federal agencies.
b. Interfacing with these agencies,
c. Setting up a central authority either
within EPA or a special office between
agencies for the sole purpose of dealing
with emergency problems.
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d. Charging this authority with
construction of an overall statistical
plan or plans dealing with these
problems. Actual problems will -or can
be subsets of the overall plans;"'
e.
Equipping this authority so that ready
response to emergencies is available.
Acting immediately to organize this
authority, since the occuranee of these
emergency situations is neither
parochial nor political. There is a
present requirement for basic
information on imminent situations.
Involving overseeing groups (e.g.,
Science Advisory Board) at the
beginning of each operation not after
it is underway and committed to action,
as in the case of the Love Canal Study.
h. Generally making a critique of the
actions of all participating and
overseeing parties at the end of the
Love Canal study, i.e., the phase
involving collection and disbursing of
data. This type of critique or
debriefing should be instituted at the
end of all emergencies dealt with by
the Agency.
2. Under no circumstances should the Agency either
accept or impose an investigative problem—such as
the one under discussion—without adequate
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knowledge of the probability of conclusion. The
latter phrase shoulfl include an intelligent
estimate of the time required and the funds
necessary to reach each systematically outlined
objective.
All existing regulations point out the
restrictions which are enforceable and capable of
being mointored where waste dumps cannot be
tolerated. There are no areas designated or
composite situations where such facilities should
be. Available data should be screened to indicate
such locations and conditions of use. This should
be done immediately as an anticipatory measure*
The Study Group notes that the monitoring function
of EPA has always involved measurement and
exposure study without direct approach to the most
important aspect indicated of the Agency.
Obvious effects such as cancer inducement or LC50
toxicity have been approached, but the realities
of the contact of organisms with their environment, the
activity of substances at low levels, and the latter1s
effects on the spectrum o£ organisms is the end
product of real impact. Without this as the prime
and major objective, monitoring studies have
little value. In addition, we can expect there to
be substances of low level concentration and of
high toxicity to some part of the living organism
spectrum which are detectable to the organism but
not to existing chemical, instrumentation.
Therefore, the Study Group recommends the priority
initiation of bioassay matrices. We recommend that
the exicitino met-hfjflnl n«v wil-h-i^ zn-i.3 ,->,,*---1 .a ~ -•--
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Agency be collated and brought to bear immediately
on the problem of toxic wastes. The-Study Groups
recommends that all necessary data and protocols
for obtaining data be collated for use tn risk
assessment in all anticipated toxic waste events.
The Study Group understands that the Love Canal Study is
ordered to proceed toward exposure assessment. We urge that this
be done and regret most strongly that the determination of risk
assessment is, thus far, in doubt. The Study Group wishes to be
informed of the final disposition of the treatment of the data and
recommends its use in some form of final critique of the Love
Canal situation.
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' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D-C.204iO
or
Attfil
February U,
TO THE CITIZENS OF LOVE CANAL
Laet fall, I indicated that tin- KYfvm'emmfrntal Protection Agency (SPA)
wouid release thfc result* of U?> monitoring studies of k°ve Canal
eix to eight waeks after <-.oinji!et ion of al) swupling activities* Tht
sampJitxg was cunt-luded on October 31, 1980, and we still he«e considerable
work to complete I»ftj0r«.- tlic rt'SiiJt** of Uifc project v»ill be re^dy for
It l\ae taken longer thon we had oviftinMly planned to analyac the d*tm
prwp.'ire the mirrafcive ^sfviptiort <,>J rlifc extent and relative degree of
contamination of the Declaration Area. We now plan to ctuftplate tht report
un the results c»i the reonitoriri}; stuitit-s in tht latter part °
This report will contain the total »et of validated data at well at
summaries and narrative etati'mtni:;. The suioDarie.* and narratives will
describe how the data v)crc obtained «nO indicate th* extent and 7«letive
degrees of chemical contamlnotitw of the Declaration Area* It is owe plan
to provide at much char actt-ti station c»i Uie data ot can Ue
juKtified. In odditi&n tt» this rt'|»wt, « site-specif ic report will
provided tu «»ch Tetidtnt whom- property
EPA gcicntists will bfc at Uivc Canal vhc^n tlie reports ar* relea««d in order
to provide you with personal explanations ol the findings*
Courtney Riordan
Deputy Assistant Acinjinistrator
lor Monitoring Systems and Qualify
/*//
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WRTE ON
Re: "Love Canal—what fealty
happened" (December 1980, p. 740)
Your guest editorial by D, L, Baeder
of Hooker's parent company,
Ogcidenial Petroleum, white
undoubtedly reflecting t.'ue facts
regarding selected pas! events, is
incomplete in recent and current facts
and actions. We feel that publishing
editorials verbatim g$ received without
verification by your editors of the facts
in context is a disservice to your
readers snd would like to convey to
;hern in this letter the current events
and actions taken by the U.S.
Environmental Protection Agency to
put future conclusions and decisions on
a scientifically acceptable basis,
thereby doing exactly what various
criticisms quoted in the editorial said
r,hould be done.
First of ail. it i$ clear from Baeder's
remarks that we are not dealing with a
glaring case in which the outcome is
obvious; All shotgun, short-term.
iDelated studies to date have been
criticized for a variety ol inadequacies
concerning scientific measurement or
conclusions based thereon. Therefore,
ii would be naive to think that yet •
another "quickie study" involving
c'ollars only, without careful scientific
design, will fare any better.
Secondly, it must be realized that
the combination of measurements and
conclusions involves a huge matrix of
sciences and disciplines. One must
assess;
1. presence of toxic chemicals (for
many chemicals, accurate
measurement methods and
standards must still be developed)
2. actual exposure to the toxins
(involving, in addition to biological
models of human physiological
functions, knowledge of behavioral
aspects)
3. health effects resulting from this
exposure (epidemiologies! studies).
Thus, we are dealing with physics,
chemistry, biology, behavioral sciences,
physiology, and medicine, as well as
meteorology ^variations ol toxic levels
with humidity, temperature, barometric
pressure) and, importantly, different
aspects of statistical design and data
treatment,
Baeder's editorial makes no mention
01 the fact that, realizing these givers,
EPA has launched a coordinated
monitoring effort with guidance from its*
Science Advisory Board (SAB), In fact,
several public meetings of the board,
advertised in the Federal Register, nave
Deen held in the last eight month?;.
including one meeting that was also
moved to Las Vegas to coincide wth
the last annual meeting of the ACS
because many society members are
serving on the board. This is an
important developmtnt because it
represents a first effort toward a
systematic, coordinated measurement
approach to sampling impurity levels in
air, water, soil, and biota. This effort
has already resulted in a documented
data set that will be available for public
use, that is based on consistent and
controlled measurement protocol?., and
that has been scrutinized for quality
control.
Not only is such a data source
available on a major dump site for the
first time, but, bas>?d on the gained
experiences, and with input from t^e
EPA's SAB and the NAS/NRC
Numerical Data Advisory Board, this
system will be modified and expanded,
to be in place as other Crisis areas
require attention.
Anticipatory and baseline monitoring
is one more level removed from the
inadequate mode of fire fighting,
popularly used in the past. This subject
is next in line for inet eased attention.
These are the recent developments
on the measurements front, where
Baeder left oft. Science is being
brought into the decision making. Trie
vast complexity ol the problem does
not allow for instant success; in the
short time since Seeder's last
observations, a significant amount of
progress has already been made.
Douglas B. Geba
Executive Secretary
Science Advisory Board
Office of the Administrator
U.S. EPA
Courtrwy Rlordan
Deputy Assistant Administrator
for Measurements and Monitoring
Oflice of Research and Development
u.s, EPA
Ueonard Qrftftnffeld
Environmental Consultant
Chairman, Environmental
Measurements Committee
Member, Science Advisory Board
U.S. EPA
£tf.:
with ste objectives outfit :\
three $>gn$ts or f.i/s *>rr»
if they .'Gaily refers ft- Mf.
e&itQfii'ii WP rejtf it ar> h.tv
not with she existence '
nor with wh$t"$ regmreC "i
rsth&r with Hookfi 's cw<'.
thus, tno this corfespQprf
exemplary o! the huttf a.'
that arises when 'wocr^i
talking past each other. .-i
and Mr. Boeder's so/nw.
side lo see whether you ?:r
in ars^iTi&'J with th>$ cop
.(." ;r'."
.' in. ''
«; ?'•«?
-.'s F-G? •
u'i-
"The last epidemic" by H. H HW.I
(January 1981, p. 17} w* 5 *e!S
:nlernio.ied and quite Ing uen^C V.
bothers me. ang 1 am sure r*!"*'?,
about nuclear disarmam*^: c! tn\> s
is the trust ir implies we mjjt n4^:-'
U.S.S.R. promises.
During the Cuban mis«,i'.e cnr-A. '•-
Gromyko came to the White HC.U.-. .
looked President Kennedy strarcw ••
the eyes, and denied the presence -.
Soviet missiles in Cuba, The
had photographic evidence ot
presence.
I am sure the Soviets ^^ve pub!iu.v
the lettw by the U.S. scie"'istF Iro^R •;••
N. V, Twnes, But have you eve^- seen
any tetters fiom Soviet serf1 njists
demanoing a halt to nucita" aniWi;; •'
in the Soviet Union?
Our adversaries do not i;ve Dy if-?
same codes as we do. !n ^d? ' tc !>••< -K
nuclear war, it Is necesss-y for the 'J if.
to be armed. Only a strong U.S. wt«
give the Soviets enough r-sason tD
A weak and unarmed i-ee worse,
prior to World War II. was an invita'«'-
to Hitler to start war, Suon is the bi*T=
fruit of a weak, unarmed f -ee wurld.
H»ny
Kcrwa'K, Com
I am sura that Donald Losman'sartici--
"Deflation of quality"
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MEETINGS OP THE SAB AND SAB/EXECUTIVE COMMITTEE REPRESENTATIVES
AT EMSL-LV ON AND DURING FEB. 9-13, 1981
Attendees: Leonard J. Greenfield, Ph.D.
John Krobock, Ph.D.
James Kittredge* Ph.D.
Clifton Brooks, Ph.D.
William Rea, Ph.D.
Amanullah Khan, Ph.D.
Cynthia Carter , Ph.D.
Jules Cohen, Ph.D.
Douglas Seba, Ph.D.
Memorandum/Letter of Record
During February 9-1 3 t 1981, the Sampling Protocol Study Group of
the Science Advisory Board and members of the Environmental
Measurements Committee of the Science Advisory Board met in Las
Vegas to attend sessions dealing with the approach to Love Canal
problems , review hazardous waste monitoring protocols, and also
discuss some of their intrinsic problems with S & A regional
officers. SAB Members were chosen to attend on the basis of
1. participation with all three groups of attendance at
only one or more meetings;
2. convenience and economy of travel; and
3. personal scheduling times.
Thus the full membership of each group was not present. Actual
attendance was approximately as follows t
Present for the full
1. Dr. Douglas Seba
2. Dr. Leonard Greenfield
3. Dr. John Krobock
Present for four days:
1. Dr. James Kittredge
2. Dr. Jules Cohen
Present for three dayss
1. Dr. Cynthia Carter
2. Dr. Clifton Brooks
Present for one day:
1* Dr. Amanullah Khan
2. Dr. William Rea
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For the first two days, there was discussion and critiaue of
some of the aspects of the past summer/fall sampling and
analysis of soilf sediments, biota, and water in the Love Canal
area. It was evident that there were a number of approaches
which needed rethinking at all planning levels. Among these
were;
1. Administrative 'input as to what the information was to
be used for;
2. Planned observation/experiment from the outset with
considerable statistical input?
3. Communication/feedback at all levels?
4. Preliminary "reading" of the area so that methods and
immediate objectives could be changed as necessary
and as dictated by initial results;
5. Etc.
The group also heard about the nature of the relationships
between the people of the Love Canal area and some of the
personnel at EPA and some of the contractors present in the
area* It is obviously important to hear all of their points of
view since they were obtained at different levels, And. before
dealing with the people of the area, as much understanding of
their attitude, as possible, should be learned.
It became apparent as conversations went on that the SAB
was being used by someone(s) to express reasons for some of the
difficulties of management within the project? e.g., the SAB was
blamed for the decision not to trap raccoons - after traps had
been purchased and a survey plan set up? the SAB was involved in
changing the "objectives11 of the project and therefore kept
throwing the project off balancej etc. Apparently no one ever
bothered to trace the origin of these statements or to check
their truth. Our suggestion is the one made several times at
executive meetings?
1* That the involvement of the SAB be at the beginning of
a project - rather than when it is well underway.
2. That there be full communication and feedback at all
levels.
On Thursday evening, the Study Group again recommended to the
SAB that the initial display of data to the public be devoid of
strata lines or other judgmental implications until correlative
situations (or lack of them) could be ascertained. Personal
appearance of EPA personnel during the week of data presentation
and narrative explanation of the reason for tests, their
quality, and their potential value for correlative testing were
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strongly recommended/ and a memo to Dr, Dowd stating this was
sent the next morning. In subsequent discussion with Director
Schweitzer of EMSL-LV and Dr. Courtney Riordan and John Deegan
{Thursday morning) the following was noted: •••
1. We now know much more about the Love Canal area than
we did at the start of the survey. It appears that
the situation may be quite different from what
is implicated by the setting up of strata. Since the
latter are based upon a statistical hypothesis, it is
better to set aside the strata lines rather than have
the residents draw conclusions not properly based.
(It is better to be conservative with the written
material than with that which is spoken.)
2. The data are rather strange and do not follow smooth
distributions. Therefore, at this time the data
should be presented as they are so that the Love Canal
people may get their experts to look at them. In
the meantime we will do the same. We can then meet
at some time, e.g*/ within 90 days, to discuss
correlations.
3* Stress the quality assurance and point out how much
data were obtained in the short time allowed.
For the remainder of our time at Las Vegas, we examined the
validated data with the idea of exploring methods of graphic
portrayal that would be significant and easily understood. We
presented some of these ideas to Director Schweitzer for his
perusal. While examining the data, there were certain aspects
that became apparent to us.
1, Earthworms in the control area showed evidence of
pesticide concentration.
2. Oatmeal and potatoes showed evidence of uptake of
methylene chloride and other substances.
3* There appear to be hot spots of substances, but they
are not immediately•correlative with'strata lines.
For instance/ some of the high readings in air, soil, and
drains were outside the declaration area. Control
drains showed higher values than those in the declaration
area* There may be some evidence to show that air
. values are more significant at night than during the
day.
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4. Air analyses and soil-water-biota analyses do not show
chemical relationship,
a» Possibly the taking of soil samples (and water) is
such that the technique allows for the escape of
volatiles to the extent that they do not show up
in soil or water.
b. Possibly, the volatiles noted in the air samples -
including the control area and outside controls
are from elsewhere upwind, Therefore, it would be
necessary to know the exact day o£ the sampling,
the weather for the day, and if any plants that
produce the gasdes found are operative upstream,
c. The major chemicals found in the air are
laboratory solvents or contaminants. Therefore,
it should be checked whether the laboratories
doing the gas/air analyses checked their own lab
atmospheres with a tenax cartridge every time they
ran a Love Canal sample. Leakage from vents and
air conditioning conduits could have been
responsible for positive errors. Hopefully*
contamination was minimal and measurable. If
not, the strata lines for air sampling should
definitely not be used,
5. Data at this point need extensive checking before any
release — in whatever format.
Members who attended the hazardous waste meetings stressed that
most of the concern dealt with just how superfund was to be
treated. S & A Members were also encouraged to become involved
in biorttonitoring, and there was considerable support for
Operation Wormwatch which discussed the use of the organisms as
bioconcentrators. Members of our Committee did not meet with S
S, A Members since we were not placed in their schedule. A
memorandum was sent to Dr. Dowd explaining this situation,
Finally, it should be noted that the report of Dr. Khan on
analyses of voles taken from the Love Canal area vs. those taken
from the control area is to be submitted as part of the report
concerning the area. Editorial changes were in progress while
the meetings were going on. Both Dr. Khan and Dr. Rea explained
the value of preventive long- range analyses of early measurable
reactions to adverse ecological conditions*
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