Revisiting a Hazardous Waste Site 25 Years Later
Harris, Glenn, Nelson, Leah, Journal of Environmental Health
Twenty-five years ago, the Journal of Environmental Health published one of the earliest articles to report illegal disposal of hazardous waste (Harris, Garlock, LeSeur, Mesinger, & Wexler, 1982). Two years earlier (1980), Congress had enacted the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), which established the Superfund program to directly address such problems. Most of the early regulations governing hazardous waste management were promulgated under the authority of the 1976 Resource Conservation and Recovery Act (RCRA) at the same time (1980-1982). This period was one of widespread interest in hazardous waste, according to more recent commentators (Hamilton & Viscusi, 2000). Although a few widely reported cases captured most of the nation's attention (e.g., Love Canal in New York, Times Beach in Missouri, Woburn in Massachusetts), numerous communities throughout North America and Europe were dealing with their own circumstances (DiPerna, 1985; Edelstein, 1988; Epstein, Brown, & Pope, 1982).
The case study highlighted in the 1982 May/June issue of the Journal of Environmental Health (JEH) was a classic instance of "midnight dumping" and corporate abandonment leaving an orphaned hazardous waste site for others to deal with. Using general parameters of water quality, the article documented the presence of a downgradient plume of pollution following periods of high precipitation. The article also proposed a methodology for more effective siting of industrial waste sites in the future. The proposed methodology based siting on the "intrinsic suitability" of natural features and suggested specific criteria by which areas for safer disposal of hazardous waste could be identified.
What has happened at this site over the last 25 years? This article follows up the earlier one and addresses the following questions: What remedial actions were taken, and how were these funded? What roles have been played by agencies of the local, state, and federal governments? How has the community responded? How useful is the methodology that was proposed for siting hazardous waste facilities? Was it widely employed and why or why not? What lessons can we learn from a historical review of this case study?
The site is located in an extremely rural area of the St. Lawrence River Valley in northern New York, adjacent to the Canadian border. In 1979, the New York State Department of Environmental Conservation (NYSDEC) issued a permit to Sealand Restoration, Inc. (SRI) to construct and operate the facility. The permit application was based on a consultant's report that concluded, "With the removal of the upper permeable sands and unsuitable materials, and the installation of surface water controls, the site could accept oil spill clean-up debris without significantly impacting the surrounding environment" (Malcolm Pirnie, Inc., 1978). According to the report, the site would consist of a 20,000-gallon tank for temporary storage of oily wastes, agricultural fields where waste would be spread before planting of corn, and a disposal pit excavated to receive drummed waste. Landspreading was to be with biodegradable wastes--that is, "vegetable oil." It was later learned, however, that petroleum-based oils containing low levels of PCBs and heavy metals were landspread instead. Moreover, the oils were applied in such high quantities that runoff entered downgradient wetlands and streams. In addition, a proposed interception ditch was not installed deeply enough to lower the groundwater moving through the disposal pit, and deposited oil spill debris was contaminated with organic solvents. Within a year after operations commenced, local farmers observed oil on the undersides of dairy cattle drinking from streams receiving runoff. Only in this way did residents and town officials learn about the site, since wastes were transported under cover of night and NYSDEC was not required to notify local governments about permit applications at the time. …