2
Community Concerns About Natural Attenuation

The community surrounding a contaminated site includes the people who live close to the site, local business owners, elected officials, local government agency representatives, workers at the site, and others who live farther from the site. However, those who live close to the site bear the brunt of the health and environmental risk and the most significant potential economic losses. While recognizing the importance of other community members, this chapter focuses on the concerns of residents who live closest to the site and are thus the most directly affected by the contamination. Although members of affected communities have concerns about all remedies for contaminated sites, they may have special questions about natural attenuation because of the lack of visible, active steps to remove the contamination.

At the majority of contaminated sites where natural attenuation has been used to date—gasoline stations with leaks in their underground fuel tanks—community members generally have not been involved in evaluating this remedy. At most gas station sites, the community is not even aware that contamination is present and cleanup is occurring. Consequently, the majority of decisions to use natural attenuation to date have been made without the benefit of public input. As proposals to use natural attenuation expand beyond the small gas station sites, public visibility will increase. Public participation programs for these more complex sites have to be reconsidered to determine whether they are adequate to address the special concerns that citizens often have about natural attenuation. Equally important, scientists and engineers involved in evaluating



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Natural Attenuation for Groundwater Remediation 2 Community Concerns About Natural Attenuation The community surrounding a contaminated site includes the people who live close to the site, local business owners, elected officials, local government agency representatives, workers at the site, and others who live farther from the site. However, those who live close to the site bear the brunt of the health and environmental risk and the most significant potential economic losses. While recognizing the importance of other community members, this chapter focuses on the concerns of residents who live closest to the site and are thus the most directly affected by the contamination. Although members of affected communities have concerns about all remedies for contaminated sites, they may have special questions about natural attenuation because of the lack of visible, active steps to remove the contamination. At the majority of contaminated sites where natural attenuation has been used to date—gasoline stations with leaks in their underground fuel tanks—community members generally have not been involved in evaluating this remedy. At most gas station sites, the community is not even aware that contamination is present and cleanup is occurring. Consequently, the majority of decisions to use natural attenuation to date have been made without the benefit of public input. As proposals to use natural attenuation expand beyond the small gas station sites, public visibility will increase. Public participation programs for these more complex sites have to be reconsidered to determine whether they are adequate to address the special concerns that citizens often have about natural attenuation. Equally important, scientists and engineers involved in evaluating

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Natural Attenuation for Groundwater Remediation natural attenuation potential must be aware of possible community concerns that their assessments may have to address. This chapter summarizes concerns about natural attenuation raised by a panel of representatives from communities located near contaminated sites. The chapter then describes the basis for these concerns. The final section recommends strategies for involving the affected community and improving communication and cooperation among community members, responsible parties, and environmental regulators in assessing natural attenuation potential. SPECIFIC COMMUNITY CONCERNS To learn first-hand about potential community concerns with natural attenuation, the Committee on Intrinsic Remediation invited a panel of six community leaders to present comments at a committee meeting. The panelists represented communities in California, Florida, Louisiana, and New York that are affected by large industrial waste sites. Appendix A lists the panelists and their affiliations. In general, panelists expressed the following concerns about natural attenuation as a method for managing the contaminated sites in their neighborhoods: It represents a “do-nothing” approach: First and foremost among the panelists’ concerns was that natural attenuation is essentially a do-nothing approach that leaves contamination in place and allows dilution, dispersion, and volatilization to transfer chemicals from one environmental medium to another. Natural attenuation is being used at more sites primarily because it is inexpensive, not because it provides adequate protection of public health. No standard documentation methods exist: There are no standard methods for showing that degradation and/or transformation of contaminants (rather than dilution, dispersion, and volatilization) are the mechanisms responsible for reductions in contaminant concentrations. The plume may expand: Contamination may spread if natural attenuation is approved as the remediation method for the site, but fails. It legitimizes dilution: Natural attenuation legitimizes the dilution and dispersion of toxic chemicals into the environment. Evidence is often insufficient: Evidence presented to community members is insufficient to indicate that contaminant degradation and/or transformation is occurring at sites where natural attenuation has been chosen as a remedy. The evidence provided does not distinguish whether contaminant concentrations are decreasing due to degradation and/or

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Natural Attenuation for Groundwater Remediation transformation processes or due to dilution, dispersion, evaporation, and similar processes. A scientific basis is lacking: Natural attenuation may be approved to treat contaminants whose fate scientific understanding is too limited to predict. Monitoring requirements are insufficient: Extensive monitoring for the unique end products of the specific physical, chemical, and biological processes occurring at a natural attenuation site is needed, but community members have little confidence that responsible parties and government agencies will provide this type of testing unless required to do so by law. Effects on mixtures are uncertain: The effects of natural attenuation on mixtures of contaminants are highly uncertain, but such mixtures are typical at contaminated sites. Hazardous by-products may form: Breakdown products of natural attenuation, such as vinyl chloride produced during biodegradation of trichloroethene, may be more toxic than the original substance. Such breakdown products are not always addressed as part of the decision to use natural attenuation. Time line may be long: The time line for cleanup at sites where natural attenuation is being used may be excessively long. During this period, choices about reusing the site for other purposes (such as parks) are limited, creating a “dead zone” in the community. Institutional controls are inadequate: Institutional controls for restricting site access while natural attenuation is occurring have limited effectiveness. For example, children may climb over fences, ignoring warning signs about contamination. Further, natural attenuation unfairly places the burden of enforcing institutional controls on the local community, rather than on those who created the contamination problem. Funds for contingency plans are inadequate: Funds to construct an engineered remediation system may not be available later if regulators approve natural attenuation as a remediation method, but it fails to control the contamination. The community panel identified a number of specific questions that must be answered at sites where natural attenuation is proposed as a remedy; these are listed in Box 2-1. Panelists agreed unanimously that before accepting natural attenuation as a remedy, they would need documentation (such as the types of analyses described in Chapter 4 of this report) that reductions in contaminant concentrations are due to degradation or transformation to less harmful forms, rather than to dilution or transfer to another environmental medium. The panel was concerned about the lack of a standard definition of natural attenuation. Some definitions, such as that used by the Environmental Protection Agency (EPA),

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Natural Attenuation for Groundwater Remediation BOX 2-1 What Communities Want to Know The community panel raised a number of important questions and identified several critical areas in which information is needed for the general public to better understand the role and effectiveness of natural attenuation in treating contaminated sites. The list below shows questions from the community panel. Chapters 3 and 4 provide the technical information needed to answer these questions. How are chemical substances naturally degraded in the environment? What chemical, physical, and biological processes are in effect? What site conditions are needed for these chemical, physical, and biological processes to work? Which types of site conditions are optimal? Which conditions inhibit natural attenuation? What information is needed to fully characterize a site where natural attenuation is being considered? What breakdown products that may be more toxic, persistent, or mobile are created when chemicals degrade? How does one prove that contamination is degrading into harmless substances? What monitoring and testing are needed to determine that a site and its contaminants are suitable for natural attenuation? Is extensive monitoring guidance necessary? How long is it reasonable to monitor to ensure that natural attenuation is working? How viable are institutional controls? Can they be enforced? Is stabilization by natural attenuation irreversible for metals or other substances? include dilution, dispersion, evaporation, and similar processes that transfer chemicals from one medium to another (see Chapter 1). Panelists strongly urged the National Research Council (NRC) to define natural attenuation as a process of degradation and/or transformation that excludes dilution and dispersion processes. The group emphasized that the inability to distinguish the extent to which a reduction in contaminant levels is due to these processes, rather than to degradation and/or transformation, will be a major point of contention for local community-based organizations. Further, panelists agreed on the need for clear evidence demonstrating to the affected community that degradation and/or transformation of contaminants is occurring and will continue until cleanup goals are achieved. Panelists were concerned that developing such documentation will not be possible at many sites. They indicated the need for help in defining what constitutes an appropriate

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Natural Attenuation for Groundwater Remediation monitoring program for natural attenuation. Panelists also expressed concern about the need to remove the original source of contamination. The panel was concerned that some site owners will choose natural attenuation almost every time over technologies that might be more expensive but that in some instances offer faster, more complete cleanup. Panelists raised concern that widespread reliance on natural attenuation will slow the development and use of innovative technologies for cleaning up contaminated sites. Communities want permanent, effective cleanups and want to see new technologies developed and used, according to the panelists. Nonetheless, the panel also made clear that if natural attenuation by degradation and/or transformation processes can be proven to work, activists in many communities would welcome it as a cleanup option. Although other community activists and community members may not share all of these views, the issues raised by the panel were consistent with those identified by community leaders at the 1998 National Stakeholders’ Forum on Monitored Natural Attenuation, which involved nearly 250 community activists, scientists, and government officials (CPEO, 1998). Owners of contaminated sites proposing to use natural attenuation are likely to encounter one or more of these concerns in locations with active community groups. Considering such concerns in advance likely will result in a less time-consuming and contentious process for selecting the most appropriate remedy—whether natural attenuation or an engineered approach—for the site. BASIS FOR COMMUNITY CONCERNS The basis for community concerns about natural attenuation—or any other potential remedy—is reports of possible adverse health effects caused by contaminants in the environment. Because of concern about such reports, many communities want the contamination controlled as quickly as possible. Community members are unlikely to believe that natural attenuation offers the quickest, best solution to a contamination problem. They also want answers to their questions about the effects of contamination. Unfortunately, determining the degree to which toxicants at waste sites affect surrounding populations is a complex and uncertain exercise that can lead to high levels of frustration among community members. In addition, when health risks are suspected, property values may decline, and community members may experience significant psychological stress. These factors can lead to mistrust of remedies, such as natural attenuation that appear to leave contaminants in place.

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Natural Attenuation for Groundwater Remediation Health Effects A number of studies at specific sites have found adverse health effects among residents living nearby. Other studies have found no association. A 1991 NRC review of all contaminated site health studies published in the scientific literature at the time found sufficient evidence to conclude that hazardous wastes have produced serious health effects in some populations (NRC, 1991). The NRC found that some investigations have documented a variety of symptoms of ill health—including low birth weight, cardiac anomalies, headache, fatigue, and a variety of neurological problems—in people exposed to contaminants from waste sites. Less clear was whether diseases, such as cancer, with a long delay between exposure and onset of illness have also occurred due to exposure to contaminants from waste sites. Nonetheless, the report notes, “Some studies have detected excesses of cancer in residents exposed to compounds such as those found at hazardous waste sites.” In another study, the Agency for Toxic Substances and Disease Registry (ATSDR), found that 46 percent of the Superfund sites evaluated from 1992 to 1996 “posed a threat to the health of persons residing near the sites at the time ATSDR conducted the assessment” (emphasis in the original). ATSDR classified these sites as posing an “urgent or public health hazard” (Johnson and De Rosa, 1997). The general public has learned about the potential hazards of exposure to toxic chemicals found at contaminated sites mostly through the media. Several of the health studies reviewed by the NRC (1991) have been widely reported in the media. The more prominent studies include those conducted at Love Canal in Niagara Falls, New York, which made national headlines and was the basis for enacting legislation requiring the cleanup of contaminated sites (Gibbs, 1998), and those conducted at Woburn, Massachusetts, the subject of at least two books and a major motion picture (Harr, 1995; Brown and Mikkelsen, 1997). At Love Canal, health studies found increases in miscarriages (NYDOH, 1978) and low birth weight (Vienna and Polan, 1984); increased prevalence in children of seizures, learning problems, hyperactivity, eye irritation, skin rashes, abdominal pain, and incontinence (Paigen et al., 1985); and decreases in growth and maturation in children whose parents were born at Love Canal (Paigen et al., 1987). In Woburn, a childhood leukemia cluster was linked to trichloroethene (TCE) that had leaked into the water supply from two contaminated sites. The Massachusetts Department of Public Health found that children of women who drank the TCE-contaminated water had a significantly higher risk of developing childhood leukemia (MDPH, 1997). Less widely reported but also raising concern was another recent study that found congenital anomalies in babies born to mothers who lived near hazardous waste landfills in Europe (Dolk et al., 1998). A

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Natural Attenuation for Groundwater Remediation study of residents living near the Lipari landfill in Pitman, New Jersey, the Superfund site ranked as having the highest risk, found a decrease in birth weight among babies born to residents near the landfill (Berry and Bove, 1997). Other incidents of environmental contamination also have been widely reported in the media. Although not strictly related to groundwater contamination, these incidents nonetheless have heightened public concern about contaminants in the environment. Examples include the evacuation of Times Beach, Missouri (Russakoff, 1983; Commoner, 1992); the contamination of thousands of Michigan cows that were accidentally fed flame-retardant polybrominated biphenyls (Brown, 1979; Reich, 1991); widespread contamination of the environment and wildlife with persistent pesticides, notably DDT (Carson, 1962); contamination of the Great Lakes with polychlorinated biphenyls (Highland, 1980); exposure of soldiers to Agent Orange in Vietnam (Wilcox, 1983); and the Bhopal, India, accident in which a Union Carbide plant released methyl isocyanate into the surrounding community (Reich, 1991; Shrivastava, 1992). More recently reported was a 1998–1999 follow-up on serious health effects among the residents of Seveso, Italy, who were exposed in 1976 to a gas cloud containing dioxin that was accidentally released from a pesticide manufacturing facility. This study found an increase in cancer of the stomach, lymph, and blood tissue among exposed individuals (Bertazzi, 1997) and excess mortality from cardiovascular and respiratory disease (Pesatori, 1998). Reports of the potential adverse health effects (including reproductive and neurological problems) caused by exposure to endocrine-disrupting chemicals also have been followed widely in the media (Colborn et al., 1995). Given this history, it is not surprising that people living near contaminated sites often believe these sites pose a high level of risk to their health. In a survey comparing beliefs of residents near Michigan Superfund sites and those of environmental and public health officials, Mitchell (1992) found that the resident group, on average, ranked contaminated sites as having a risk of 4.7 on a scale of 1 through 5, with 5 representing the highest risk level. In comparison, the health officials, on average, ranked the sites as having a much lower risk (see Figure 2-1). As shown in Figure 2-1, the resident group ranked contaminated sites as having a risk higher than all other types of risks mentioned in the survey, including smoking and motor vehicle use. Mitchell found that the risk-communication efforts of the Superfund program had failed to decrease the residents’ level of concern. Thus, many residents near contaminated sites will have a deep-seated belief that these sites pose a greater risk to their own health and the health of their families than any other risk they might face.

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Natural Attenuation for Groundwater Remediation FIGURE 2-1 Relative risk ratings indicated in a survey of residents near Michigan Superfund sites and health and regulatory agency personnel working at these sites. NOTE: SW = solid waste. SOURCE: Mitchell, 1992. Reprinted, with permission from Plenum Press (1992). © 1992 by Plenum Press. The tools of modern epidemiology are usually insufficient to answer the community’s questions about health risks. This lack of definitive methods for confirming or disproving potential health effects can be extremely frustrating to community members. Epidemiological studies are the primary tool used to investigate whether an association exists between an observed health effect in a community and the presence of a contaminant to which community members are exposed. However, these studies have significant limitations in determining associations between chemical contamination of soil and groundwater and health effects. Key reasons for these limitations include

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Natural Attenuation for Groundwater Remediation uncertainties about who was exposed to the contamination, which complicate determination of which population should be studied and which population can be used as an unexposed comparison group; the long latency period between exposure to chemical contaminants and onset of some diseases, which causes some studies to overlook diseases that develop after the study is completed; the relatively small size of the exposed population, which limits the ability to conduct statistical evaluations of the significance of observed effects; uncertainties about health effects of the contaminants, due to limitations of available toxicological data on many contaminants; the presence of mixtures of contaminants that may cause synergistic effects; and confounding factors (such as exposure to chemical pollutants from sources other than the waste site) and sources of bias (such as increased recall of past health problems by site residents due to concern about the site or, conversely, unwillingness to disclose information about some types of medical problems) (NRC, 1994). These limitations and uncertainties can result in widely differing conclusions among epidemiological studies. For example, in the Woburn case, two different epidemiological reports from the Massachusetts Department of Public Health reached opposite conclusions about whether there was an association between the childhood leukemia cluster and the contamination of local water supply wells with TCE (Brown and Mikkelsen, 1997). The first study concluded that there was no link, while the second (later) study found a significant dose-response relationship between the leukemia cases and the exposure of mothers to contaminated well water during pregnancy. Such conflicting results, along with the frequent failure of health agencies to involve local citizens in the planning and design of epidemiological studies, can lead to public mistrust not only of the study results but also of the health agencies responsible for conducting the studies (Brown and Mikkelsen, 1997; Ozonoff and Boden, 1987). Economic Effects Also of concern to neighbors of contaminated sites is the potential for significant economic losses, primarily due to the decline in home values caused by proximity to a contaminated area. Many economic studies have documented such losses (NRC, 1997). For example, McClelland et al. (1990) determined that a southern California community of 4,100 homes lost an estimated $40.2 million total in property values due to the

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Natural Attenuation for Groundwater Remediation presence of a former hazardous waste landfill nearby, even though no documented contaminant leakage from the landfill had occurred. Further, most people are unable to sell their home and have mortgage commitments that make buying or renting another home financially impossible, leaving people “economically unable to escape and often feeling trapped and helpless” (Rich et al., 1995). Relocation is especially a problem for Native Americans, who usually have a deep and sacred relationship with their land (Native Land Institute, 1995). In some cases, site neighbors may lose all faith in the ability to protect the safety of their home. One resident of Woburn commented, “There’s no safe place anywhere, and every day it gets worse” (Brown and Mikkelsen, 1997). Psychological Effects The presence of a contaminated site also can have effects due to the high levels of stress imposed on individuals and the community. Many studies have documented that neighbors of contaminated sites often experience inordinately high levels of chronic stress due to the known presence of contamination (see, for example, Fleming et al., 1991; Gatchel and Newberry, 1991; Baum et al., 1992; Unger et al., 1992; Brown and Mikkelsen, 1997). For example, in a detailed study, Fleming et al. (1991) concluded that a community affected by a Superfund site in the Middle Atlantic region of the United States showed higher levels of stress than a control group according to multiple psychological indices, including sleep trouble, anxiety, and depression. Fleming et al. also measured higher levels of the stress-induced hormones epinephrine and norepinephrine in the urine of landfill neighbors than in members of the control group. Gatchel and Newberry (1991) found similar results in an Ohio community affected by pesticide contamination of groundwater and a local creek. Residents of this community exhibited higher levels of stress according to common psychological measures (including sleep disorders, anxiety, and depression) and also according to two physiological measures (resting heart rate and blood pressure) than residents of a control community. Symptoms of chronic stress such as those exhibited in these communities can also result from the neurotoxic effects of contaminants (Rosenberg, 1992). Neither of these studies determined whether the observed symptoms were solely due to stress factors or whether neurotoxic effects also might have played a role. Contaminated sites affect not only individuals, but also community function. Whereas natural disasters tend to unite communities because the necessary response is clear, the presence of contaminated sites can divide communities (Couch et al., 1997). In a study of effects on community function in a subdivision affected by drinking water contaminated by

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Natural Attenuation for Groundwater Remediation Neighbors of contaminated areas may lose trust in government institutions. SOURCE: Courtesy of Center for Health, Environment, and Justice. a neighboring industrial park, Couch et al. (1997) found that subdivision residents experienced feelings of alienation from neighbors who were unaffected by contamination and from local institutions. Couch et al. concluded, “Toxins in the biosphere are likely to disturb the predictable and assumed relationships between people and key social networks and organizations.” In another study, Edelstein (1982) found a similar sense of alienation among community members affected by contamination; one community member observed, Only my mother will come here. It’s like we have the plague…. Before the water, we entertained every weekend. Now only immediate family come. The others are afraid…. People even called to ask us whether they were exposed to pollution from our water during their visits. This sense of alienation can compound the stress experienced by affected individuals (Couch et al., 1997). Neighbors of contaminated sites also may lose trust in institutions they formerly believed were established to help protect their interests (Ozonoff and Boden, 1987; McCallum et al., 1991, Edelstein, 1993; Rich et al., 1995; Brown and Mikkelsen, 1997; Ashford and Rest, 1999). For example, Mitchell’s (1992) survey comparing perceptions of waste site neigh-

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Natural Attenuation for Groundwater Remediation even to be aware of the contamination. However, where such groups do exist, they provide an ideal base for community involvement in site decision making. The most important role of neighborhood organizations is to provide a voice for the community in decisions that affect the health and well-being of its members. These organizations provide information, a place to meet, emotional support, and a sense of empowerment (Unger et al., 1992). They usually have a small office, perhaps in a member’s home or in donated space; the staff usually consists of volunteers; and meetings are held sporadically (Adams, 1991). The growth in the number of these grassroots, community-based organizations has been described as a new wave of environmentalism that is strikingly different from the traditional environmental movement, which came about in the early 1970s (Adams, 1991; Dowie, 1995; Gottlieb, 1993; Shabacoff, 1993). While the traditional environmental movement is led primarily by lawyers, scientists, and lobbyists, such grassroots groups typically consist of homemakers, farmers, blue-collar workers, ranchers, urban dwellers, suburban residents, low-income earners, and people of color who do not see themselves as environmentalists in the traditional fashion (Gibbs, 1998). Many are led by women who believe their families are in some way affected or threatened by the contamination and who quickly develop into strong leaders able to assimilate complex scientific and technical information even though their formal education may be limited (CHEJ, 1989a; Levine, 1982). Some groups spend years working on the same contamination problem. It is not unusual for a group to have 10 years of history or more. For example, Concerned Neighbors in Action was established in 1979 and is still working today to clean up the Stringfellow Acid Pits, located 40 miles west of Los Angeles in Riverside, California (Gottlieb, 1993). Over such a long period, those active in the groups become skilled in the many issues that affect the cleanup process. Surveys have found a relatively high level of public trust in these organizations. For example, McCallum et al. (1991) found that survey respondents had five times as much trust in environmental groups (whether local or national) as in chemical industry officials and nearly four times as much trust in these groups as in local and federal officials. Further, grassroots organizations may provide valuable information that professionals not familiar with the local environment and community might overlook (Ashford and Rest, 1999; ATSDR, 1996; Brown and Mikkelsen, 1997). They may know who is sick and with what disease, have valuable first-hand historical knowledge of past practices that may have led to the contamination, and be familiar with local environmental conditions.

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Natural Attenuation for Groundwater Remediation Where no existing grassroots community organization exists, the involved regulatory agencies should take responsibility for reaching out to the affected community. The extent of outreach necessary, and ultimately the level of community involvement, will depend on the magnitude of the contamination problem, the number of people who are affected, and the interest of community members. According to ATSDR’s study of community involvement programs, community outreach is most effective when it begins with an effort to learn as much as possible about the community, including its culture, diversity, geography, and political relationships (ATSDR, 1996). EPA’s National Environmental Justice Advisory Council (NEJAC), formed to advise the agency on issues of environmental justice, suggests reviewing correspondence files and media coverage about the site. NEJAC also suggests identifying key individuals who represent different interests in the community and learning as much as possible about these people and their concerns (EPA, 1996a). This preliminary outreach step can be accomplished by personal contact, telephone, or letters. Educating the affected community is also a critical part of outreach. Studies of community outreach programs have suggested the following guidelines for community education (ATSDR, 1996; CDC, 1997; English et al., 1993; EPA, 1996a,b): Educational materials provided to the community should be culturally sensitive and relevant and should be translated when necessary. Materials should be readily accessible, written in a manner that is easy to understand, and timely. Unabridged materials should be placed in accessible repositories, such as public libraries. Meetings held to educate the community should be scheduled to make them accessible and inclusive. They should be held at times that do not conflict with work schedules, dinner hours, and other commitments. The meeting should be located at facilities that are local and convenient and that represent “neutral turf.” Translators should be provided in non-English-speaking communities. Meetings should be advertised in a timely manner in the print and electronic media, and advertisements should provide a phone number and/or address for people to contact about the meeting. Agency staff working on the outreach effort should be trained in cultural, linguistic, and community outreach techniques. Once steps have been taken to educate the affected community, ATSDR suggests using a “community-guided approach” to determining

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Natural Attenuation for Groundwater Remediation the appropriate level of community involvement. Under this approach, the agency works with community members to develop a community involvement plan that meets community needs as well as agency requirements. To make this plan work, the agency has to view community involvement as a central pillar of its work, not as an add-on. At many sites, community interest will be sufficiently high that formation of a citizen advisory group should be considered. There is a long history of formation of such advisory groups at contaminated sites. Some of these advisory groups include only citizens who are affected by the contamination, while others include the full range of stakeholders, such as representatives of the Chamber of Commerce, the responsible party, local business owners, and local politicians. Lynn and Busenberg (1995) reviewed 14 empirical studies of citizen advisory committees (CACs) spanning 1976 to 1993 and found “some cases where CACs seemed to have been formed solely for the purpose of fulfilling legal mandates or to serve as vehicles of persuasion” and other cases “where broadly based CACs, with well defined charges, adequate resources, and neutrally facilitated processes had significant policy impacts.” Some community-based organizations have raised concerns about the makeup of advisory groups, especially those proposed by responsible parties (CSPP, 1992; Renn et al., 1995). The primary concern is that members are often hand picked by the government or institutional body seeking advice, and membership often consists of all major stakeholders, rather than only those who are directly affected by the contamination. There are often few opportunities to address issues outside the charge of the CAC. In these cases, advisory groups are perceived as vehicles for accomplishing a predetermined agenda, rather than mechanisms for facilitating true community involvement in the decision-making process. In a review of different types of stakeholder participation programs, Hirschhorn (1997) concluded that citizen advisory groups should include only those who are directly affected by the contamination. Hirschhorn concluded, “Comprehensive stakeholder participation [involving parties other than citizens who are directly affected by the contamination] in risk management decisions can erode the rights of true victims of environmental risks and result in less than optimal solutions.” He found that if government agencies and responsible parties “continue to use a broad view of equal stakeholders, they may discover that a vocal minority consisting of those people directly at risk will either not participate or will pose considerable obstacles to achieving the smoothest possible implementation of environmental projects.” EPA has a very limited program for assisting community advisory groups at Superfund sites (EPA, 1995). This program was instituted in 1994 at the recommendation of the Office of Solid Waste and Emergency

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Natural Attenuation for Groundwater Remediation Response Environmental Justice Task Force. The task force recommended that EPA become involved with community advisory groups at a minimum of ten sites nationwide. Currently, 53 Superfund sites have such advisory groups. The degree to which these groups can influence decision making at sites is unclear, but it appears to be quite limited. EPA’s guidance document describing the program states that “EPA anticipates that the CAGs [community advisory groups] will serve primarily as a means to foster interaction among interested members of an affected community, to exchange facts and information, and to express individual views of CAG participants while attempting to provide, if possible, consensus recommendations from the CAG to EPA” (EPA, 1995). Other agencies involved at contaminated sites also have advisory group programs. ATSDR uses “citizen advisory panels” in conducting health assessments at contaminated sites (ATSDR, 1996). The Department of Defense (DOD) uses “restoration advisory boards” (RABs) in the cleanup of DOD installations and to date has established RABs for more than 300 installations (Council on Environmental Quality, 1995; L. Siegel, Pacific Studies Center, personal communication, 1999). DOD requires establishment of such advisory boards when (1) installation closure involves the transfer of property to the community; (2) at least 50 citizens petition for an advisory board; (3) the federal, state, or local government requests formation of an advisory board; or (4) the installation determines the need for an advisory board. To be effective, citizen advisory groups need to be provided with sufficient resources to review technical materials about the site and hire a consultant to assist with this review, if necessary. Financial resources are available to assist community advisory groups, but these resources are insufficient in most cases. EPA has a limited program for awarding technical assistance grants to community groups so they can hire their own technical adviser to help community members understand scientific and technical data and information. As of February 1999, more than 200 such grants totaling more than $14 million had been issued (L. Gartner, EPA, personal communication, 1999). However, these grants are not provided early enough in the process. Sometimes, they are awarded after the site remedy has been selected. Another limitation of technical assistance grants is that they are available only for communities with Superfund sites (Ashford et al., 1991). Grants also are not available for reviewing health studies conducted at contaminated sites (CHEJ, 1990). A coalition of community-based organizations has called for more and expanded technical assistance grants in the current efforts to reauthorize the Superfund legislation (CHEJ, 1998). The DOD also awards limited technical assistance funds to communities through a program, called Technical Assistance for Public Participa-

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Natural Attenuation for Groundwater Remediation tion, begun in 1998. This program provides $25,000 to RABs to obtain technical assistance (CPEO, 1998). In summary, no single mechanism will be appropriate for involving the community in every case. Community involvement programs should begin early by working with local grassroots groups formed to address the contamination problem, if such groups are available. Where no such groups exist, regulators and site owners should take active steps to educate the surrounding community and gauge the community’s level of interest in participating in site decision making. If community interest is sufficiently high, a citizen advisory group consisting of residents near the site should be formed. This group should be empowered to advise in decision making and should be provided with financial resources to obtain technical support. CONCLUSIONS The involved public’s greatest concern at sites where natural attenuation is proposed as a remedy for contamination is the need for documentation that contaminants are being degraded or transformed to less hazardous products, rather than being diluted or transferred to another environmental medium. Some members of the public have a deep philosophical objection to using dilution to solve pollution. The public also is likely to be concerned about monitoring plans for the site and whether the initial source of contamination will be removed. Providing understandable documentation to the public to address these concerns is a critical part of natural attenuation remedies at contaminated sites. Failure to provide this documentation can lead to significant delays late in the regulatory process at individual sites and is likely to increase public distrust of natural attenuation, limiting its use even when it is the most effective remedy. Although the general public may not be aware of contamination at the gas stations where natural attenuation has been used most frequently, a concerned public often is active at larger contaminated sites. These community members may be open minded and technically sophisticated, but also quite worried about potential health effects of the contamination and the potential for economic losses. These worries, combined with the stress caused by living near a contaminated site, can lead to a sense of alienation from unaffected community members and local institutions and to a loss of trust in the organizations responsible for managing the cleanup. Compounding these problems is the uncertainty about when the contamination will be cleaned up. Until cleanup occurs, community members will remain concerned about potential exposures and future health problems, especially among their children. These concerns will be

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Natural Attenuation for Groundwater Remediation especially significant at sites where natural attenuation is used because of the lack of visible steps to remove the contamination. Despite the presence of a concerned public at many larger sites, opportunities for public involvement in decision making have been limited. Most often, the public is not allowed to comment on candidate remedies until after the list of potential remedies is developed. As a consequence, those who are most affected by the contamination do not have a role in identifying candidate remedies, which can lead to mistrust of the ultimate choice of the regulatory agency and site owners. Public outcry can lead to delays late in the remediation process. Although involving the public early may slow the initial stages of remedy selection, studies have shown that early public involvement can reduce remediation costs in the long run by building public trust, decreasing legal disputes, and helping to identify lower-cost alternatives. Further, community members may have historical knowledge that can be a valuable asset in the early stages of site characterization and modeling. No one strategy for involving the public will be appropriate in every case. Some sites will have grassroots organizations that already have formed to address the contamination problem, and these groups can provide the basis for public involvement plans. At other sites, regulators and site owners have a responsibility to educate the affected public and determine the level of interest in forming a community advisory group to assist in decision making. In all cases where the public is concerned enough to become involved, public input should be sought from the beginning of the site investigation, and the public should be given real influence in decision making. Public involvement plans should focus on those who live nearest the contaminated site and are most at risk due to the contamination. Regulatory agencies and site owners should focus on building an effective working relationship with these affected people, rather than viewing their role as solely to provide technical documents. Community members can recognize the strengths and limitations in engineered and natural attenuation remedies. They want to be involved as early as possible in the site assessment and remedy selection process, treated with respect, recognized for their knowledge of their community, considered as equals (to the extent possible) in the process, and provided with the resources necessary for informed participation. They also generally want the responsible parties to be accountable for the pollution they created and for a permanent, effective cleanup. In summary, current programs for community involvement at contaminated sites are inadequate to address the special concerns that community members may have about natural attenuation. Public involvement programs have to be reexamined in light of the increasing formal

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Natural Attenuation for Groundwater Remediation use of natural attenuation for contaminant management. Community involvement programs for sites where natural attenuation is being considered as a formal remedy should not differ from those where other remedies are being considered. However, community concerns will be different at natural attenuation sites, as was indicated by the panel of community members that provided information for this report. Improved public involvement programs would benefit not only sites where natural attenuation is chosen, but also sites where engineered remedies are selected, because such programs would provide a more effective conduit for the community to convey essential information to remediation managers and would decrease the potential for disputes late in the process. RECOMMENDATIONS At sites where natural attenuation is proposed as a formal remedy for groundwater contamination and where the contamination affects a local community, environmental agencies and responsible parties should provide the community with clear evidence indicating which natural attenuation processes are responsible for the loss of contaminants. The evidence provided should emphasize biological degradation, chemical degradation, and/or physical immobilization processes that change contaminants to less hazardous forms. The evidence should be made available to the public in a transparent, easy-to-understand format. Federal and state environmental regulations and guidelines for cleaning up contaminated sites affecting communities should be changed to allow community involvement as soon as the presence of contamination above health-based standards is confirmed. Current regulations provide for community involvement only after a list of potential remedies has been proposed. The restoration advisory boards established as formal venues for community involvement in the cleanup of Defense Department installations could serve as useful models. Programs for community involvement may have to vary depending on the nature of the contaminated site (i.e., whether the site is a gas station with a small fuel leak and no affected neighbors or a complex Superfund site in a populated area). Environmental regulatory agencies and responsible parties should encourage affected community members to become involved in the decision making and oversight at contaminated sites. Community involvement should be sought as soon as contamination is discovered. Community input would be valuable in addressing issues such as definition of cleanup goals, identification of areas for testing, evaluation of remedial options, determination of a reasonable time frame for remediation, assessment of the potential effectiveness of institutional controls, and planning

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Natural Attenuation for Groundwater Remediation of how to conduct long-term monitoring of contaminant concentrations. Strategies for encouraging public involvement include providing information regularly, holding meetings at times and locations that are convenient to the community, establishing rules for community participation at all meetings, using culturally sensitive materials and, where appropriate, translating materials for non-English-speaking communities. EPA, state environmental agencies, and responsible parties should ensure that interested community groups can obtain independent technical advice about natural attenuation and other potential remedies. The availability of this assistance should be timely, and the advice should be provided by an objective source. Providing financial resources to obtain this advice may be appropriate in some circumstances. Environmental regulatory agencies and responsible parties should ensure that interested community members can obtain access to all data concerning the contamination, health effects, and potential remedies at sites where communities are affected by groundwater contamination. Information should be available at a central repository throughout the site assessment and cleanup process. Clear documentation should be provided to explain how, when, and where the data were collected. The data should be provided free of charge or at minimal cost. REFERENCES Adams, T. 1991. Grassroots Ordinary People Changing America. New York: Citadel Press. Ashford, N. A., and K. M. Rest. 1999. Public Participation in Contaminated Communities, Cambridge, Mass.: Center for Technology, Policy, and Industrial Development, Massachusetts Institute of Technology. Ashford, N. A., C. Bregman, D. E. Hattis, A. Karmali, C. Schabacker, L. Schierow, and C. Whitbeck. 1991. Monitoring the Community for Exposure and Disease: Scientific, Legal, and Ethical Considerations. Cambridge, Mass.: Center for Technology, Policy, and Industrial Development, Massachusetts Institute of Technology. ATSDR (Agency for Toxic Substances and Disease Registry). 1996. Learning from Success: Health Agency Effort to Improve Community Involvement in Communities Affected by Hazardous Waste Sites. Atlanta, Ga.: ATSDR. Baum, A., I. Fleming, A. Isreal, and M. K. O’Keeffe. 1992. Symptoms of chronic stress following a natural disaster and discovery of a human-made hazard. Environment and Behavior 24(3):347-365. Berry, M., and F. Bove. 1997. Birth weight reduction associated with residence near a hazardous waste landfill. Environmental Health Perspectives 105(8): 856-861. Bertazzi, P. A., C. Zocchetti, S. Guercilena, D. Consonni, A. Tironi, M. T. Landi, and C. Pestori. 1997. Dioxin exposure and cancer risk: A 15-year mortality study of the “Seveso accident.” Epidemiology 8(6): 646-652. Brown, M. 1979. Laying Waste: The Poisoning of America by Toxic Chemicals. New York: Pantheon Books. Brown, P., and E. J. Mikkelsen. 1997. No Safe Place: Toxic Waste, Leukemia, and Community Action. Berkeley, Calif.: University of California Press. Carson, R. 1962. Silent Spring. New York: Houghton Mifflin.

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