Habitability of the Love Canal Area: An Analysis of the Technical Basis for the Decision of the Habitability of the Emergency Declaration Area: A Technical Memorandum Page: 40
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Appendix C
Results of the EPA Study Related
to the Habitability DecisionsSummary
Until there is agreement about the possible level of
chemicals in samples that contained no detectable con
centrations, it is pointless to dwell on the quantitative
aspects of health risk posed by chemicals from Love
Canal. If the concentrations are in the parts per billion
(ppb) range, the risk has to be judged to be very low
and probably acceptable. If the concentrations for
some chemicals are 1,000 times higher, in the parts
per million (ppm) range, the risks are probably not ac
ceptable. According to the Environmental Protection
Agency (EPA), the concentrations are in the ppb range;
according to the National Bureau of Standards (NBS),
they could near 1 ppm.
OTA does not agree that the ppm estimate is realistic
for all chemicals, and it tends to accept EPA's esti
mates, but OTA does agree with NBS that further
documentation from EPA is necessary to settle the
matter. A resolution between EPA and NBS might be
reached by an examination of a subset of EPA's rec
ords. Also, if additional monitoring is carried out
before or during rehabitation of the emergency decla
ration area (EDA), EPA should consult with NBS to
ensure that quality control measures are adequate.
Basis of the Habitability Decision
The major input to the habitability decision was
data generated by the EPA monitoring study. The
Department of Health and Human Services (DHHS)
used absolute concentrations of chemicals found in
EDA and assessed the relationship of these concentra
tions to potential health problems. DHHS also re
viewed data about health problems observed in EDA
and Love Canal residents and used professional judg
ments about possible human health effects resulting
from exposure to chemicals deposited in the canal land
fill.
The OTA review concentrated on the EPA monitor
ing data and possible health effects associated with
*D. Rail, National Institute of Environmental Health Science, Research
Triangle Park, N. C., and B. Paigen, Children's Hospital, Oakland, Calif.,
personal communications, May 1983. See Environmental Monitoring at Love
Canal: Interagency Review, comments by DHHS, NBS, and EPA (Wash
ington, D. C.: U.S. Environmental Protection Agency, Office of Research and
Development, May 1982).Love Canal chemicals. OTA inspected but did not
evaluate the validity of reported health problems of
residents nor question the professional judgments of
the DHHS officials. The results of the OTA analysis
indicate three areas where uncertainties in the data
could have a major impact on the DHHS decision.
These areas include:
1. the range of variability associated with values re
ported for chemicals detected, nondetected, and
trace;
2. uncertainties in potential health effects associated
with Love Canal chemicals; and
3. problems associated with comparing data for the
EDA with data in control areas.
Problems With Statistical Comparisons
of EPA Results
A major statistical problem is related to the small
numbers of controls used in the EPA analysis.2The
power to detect differences in contamination between
the EDA and control areas and between Love Canal
and control areas has been questioned.'These criti
cisms that the canal cannot be distinguished from the
control are accepted as valid by EPA. This creates
uncertainty for a conclusion that the EDA is as hab
itable as the control areas to which it was compared.
Silbergeld has attacked the EPA monitoring study on
insufficiency of statistical power:
The small number of control area sampling sites se
riously reduced the ability to detect differences in
chemical contamination between the Declaration Area
and the control area.
The absence of power to distinguish between the
canal and the control areas seriously compromises any
conclusions to be drawn from comparing Love Canal
to the EDA and EDA to the control areas because, in
most cases, statistically there are no differences be
tween Love Canal and the control areas. The absence
'E. Silbergeld, Environmental Defense Fund (EDF), testimony before the
Subcommittee on Commerce, Transportation, and Tourism, Committee on
Energy and Commerce, U.S. House of Representatives, 97th Cong., serial
No. 97 197, August 1982, pp. 68 103.
'R. J. Cook, testimony before the Joint Public Hearing on Future Uses of
the Love Canal Hazardous Waste Site and Adjacent Property, State of New
York, Assembly Standing Committee on Environmental Conservation, As
sembly Subcommittee on Toxic and Hazardous Substances, Feb. 17, 1983.
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United States. Congress. Office of Technology Assessment. Habitability of the Love Canal Area: An Analysis of the Technical Basis for the Decision of the Habitability of the Emergency Declaration Area: A Technical Memorandum, report, June 1983; [Washington D.C.]. (https://digital.library.unt.edu/ark:/67531/metadc39508/m1/44/: accessed May 5, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.