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Nyanza: A small American town and its superfund hazardous waste site
175
ENVIRON IMPACT ASSESS REV 1988;8:175-180
NYANZA: A SMALL AMERICAN TOWN AND ITS SUPERFUND HAZARDOUS WASTE SITE
JOHN DUNCAN POWELL
The Nyanza hazardous waste site in Ashland, Massachusetts, became known in 1981 as one of the top ten sites on the Environmental Protection Agency (EPA) Superfund priority list. As a "risk event" to be studied for lessons in risk communication, it is representative of a class of historic industrial sites found on the outskirts of metropolitan areas such as Boston that emerged in the 1970s and 1980s as a focus of concern over toxic wastes and public health. From 1917 until 1978, when Nyanza, Inc. ceased operations, the 35-acre site on Megunco Road in Ashland was host to a series of companies manufacturing textile dyes and intermediaries. It was the discovery of mercury deposits in the Sudbury River in 1970 by EPA contract researchers and the State Division of Water Pollution Control's efforts to analyze and control the sources of contamination that led to the eventual involvement of the EPA and its Superfund program at the Nyanza site. Currently, the site has funding and an approved Stage I plan to stabilize the site and prevent further groundwater pollution, and a Stage II plan to evaluate further and clean up the groundwater which moves from the site, under the Pleasant Street neighborhood (and often into the basements of the homes there), and discharges into the Sudbury River system. There are a number of aspects to the Nyanza case which make it particularly promising for learning lessons in improving risk communication. First, as an historic industrial site in a small town, it lies in close proximity to an exposed population of neighbors, making the assessment and communication of health risks particularly important. But its historic presence also means that redefining local perception of the dye plant on Megunco Road from a place to work (even if a source of nuisance odors) into a potentially life-threatening menace was a major wrench. For neighbors of the plant and for other townspeople and some local officials, Nyanza has been a rude awakening to the risks of modern American life. The local media have played a prominent role in this situational re© 1988 Elsevier Science Publishing Co., Inc. 52 Vanderbilt Avenue, New York, NY 1001"7
0195-9255/88/$3.50
176
JOHNDUNCANPOWELL
definition and the related assessment of health risks, an endeavor which has evoked both praise and censure. The second aspect of the Nyanza situation which makes it a rich case for study and analysis has to do with the complexities of the historic waste disposal practices on the site and the resulting wide variety of environmental and potential health impacts. Raw liquid wastes and dye waste sludges were for 60 years routinely discharged, accidentally or deliberately, into wetlands and brooks adjacent to the various buildings and sheds in which the dyes and intermediaries were manufactured. In addition, organic liquid and inorganic wastes and mixed sludges were either pumped or barreled and hauled up Megunco Hill above the plant, and then dumped on the ground, into wetlands, or into waste pits as standard disposal practice. Thus, the still-active light industrial site is contaminated in a variety of specific locations by a wide range of toxic materials, and the waste disposal hill area suffers from surface, subsurface, and wetlands contamination. Both surface water and groundwater contamination have moved offsite, polluting downgradient water courses, wetlands, and neighborhood basements during seasonal high water table periods. The physical complexities of the site and its contamination impacts have provided ample material for risk communication conflicts during the process of site assessment, selection of remedial alternatives, and the assessment of health risks. Third, the Nyanza case involves an intricate pattern of intergovernmental relations concerning a single site. Historically, the local Board of Health responses to neighborhood complaints of nuisance odors and waste discharge impacts on Chemical Brook. By the early 1960s, the State Division of Water Pollution Control (DWPC) took a series of steps to force the dye company to upgrade the partial waste treatment system that had been operating since 1919. The DWPC and, later, the state Department of Public Health were gradually drawn into dealing with the disposal practices on Megunco Hill. When the JBF Scientific Research Corporation, under contract to the EPA, traced mercury contamination of the Sudbury River up to its source at the Nyanza site in 1970, the Metropolitan District Commission (MDC) became involved because Reservoirs # 1 and # 2 were standby supplies for the MDC water distribution system (including Boston and some 40 surrounding communities). Soon the Division of Fish and Wildlife was drawn in because mercury contamination of river and reservoir fish was encountered. In 1975, a number of environmental protection agencies were combined into the State Department of Environmental Quality Engineering (DEQE), which, under the 1979 Hazardous Waste Management Act (Massachusetts General Laws, Chapter 21C), took an aggressive role in dealing with the Nyanza site. The EPA, in setting up its Superfund program as mandated in 1980, placed the Nyanza site on its National Priority List in October 1981, and, after an abortive attempt to deal with the responsible parties (begun by DEQE), took over the cleanup of the site in August 1982. This pattern of complex
NYANZA:A SMALLTOWNANDITS SUPERFUNDSITE
177
intergovernmental relations dealing with Nyanza affected risk communication significantly. While it brought to bear a wide range of expertise and experience in dealing with a common problem, it complicated and slowed down the process of bringing the site under control and remediating its impacts, In turn, delay eroded local confidence in the process, and eventually produced a skeptical or even adversarial posture on the part of concerned local citizens, officials, and the media. This erosion of confidence and trust combined with the already existing uncertainties and technical complexities presented by the site itself and worked to exacerbate disagreement over the assessment and remediation of risks. Fourth, under such circumstances, it should come as no surprise that dealing with the local public at Nyanza, as it is at most Superfund sites, can be a communications minefield. The initial media reporting of the Nyanza site as among the "Top Ten" on the National Priority List entrenched the perception of the site as a dreaded menace. This perception, reinforced by a talented editorial cartoonist, became--and remains--imbedded in the public mind. An organized citizens group quickly emerged with the Nyanza site and its health impact on the community as its focus. It conducted a door-to-door sampling of health problems among the site's immediate neighbors and found eight cases of cancer and assorted ills among the 47 households it covered. This fact was communicated by several means: a public meeting called by the group, letters from responsive local legislators, and guest appearances on local radio shows. Local reporters quickly learned of and reported an additional 12 cases of cancer in the town. Reaction by local and state health authorities was technically sound from an epidemiological point of view: that is, skeptical because of the small numbers and the lack of precise end points and direct exposure measures. But the reaction was disastrous from the perspective of effective risk communicationl The cancer scare in the early summer of 1982 generated a continuing legacy of distrust in governmental agencies and officials, and an explicit dissatisfaction with a process which elevates the principles of a science above the direct health concerns of citizens. This legacy remains perhaps the greatest obstacle to the communication of health risk information during the ongoing assessment and remediation process at Nyanza.
Lessons Learned and Recommendations for Improving Risk Communications Superfund risk managers enter a scene dominated by people with perspectives different from theirs. These people and their perspectives are responsible parties (RPs) concerned with conducting their businesses; neighbors, with intimate and long-standing knowledge of the site and its off-site impacts, who are concerned with their health; local media that focus on worst-case risk potential and the human interest reaction of the neighbors; local officials with conflicting inter-
178
JOHNDUNCANPOWELL
ests--concern about the local tax base, the business climate, the property values, the impact of negative publicity concerning the hazardous waste problem, the health impacts of the site, the slowness of the Superfund process, and the lack of bureaucratic responsiveness to health concerns; and citizen groups interested in participating effectively in the decision-making process. While Superfund risk managers concentrate on an orderly attack on site containment and remediation, these other groups have their own ideas regarding priorities and resource allocation. They begin the process with the assumption and expectation that Superfund will come into their community and quickly and quietly clean up the toxic material on the site and rid the community of it. This is assumed. What is expected is that their concerns will be addressed in a prompt and effective fashion. Businesses expect the investigative and remedial disruptions caused by the site to be minimal. Neighbors expect to be told whether their fears of health impacts are warranted, and what to do if they are. Local reporters want definitive answers to questions beyond the limits of scientific certainty. Local officials expect to have control over the local impacts of the remedial measures taken at the site. And citizen groups expect a responsive and forthcoming sharing of information and decision making. Superfund managers find that these groups are not easily persuaded to alter their points of view and adopt those of the risk managers including the attendant legal, procedural, and budgetary constraints. This basic factor can generate considerable tension and conflict, but it will not go away; it must be managed. These are concrete steps that will help manage this problem: 1) The timely provision of information from the EPA to the public must be institutionalized by means of a representative citizens advisory committee and community archive. Regular meetings with this committee, to share information and plans, help minimize unnecessary conflict. 2) Basic decision-making power cannot be shared by Superfund risk managers, but opening up key stages of the decision-making process to structured community participation can help. For example, collaboration in defining the scope of the Remedial Investigation and Feasibility Study would help reduce conflict over the results of such studies. 3) Superfund on-site coordinaters must be selected and supervised carefully to ensure that they are not only technically competent and well informed, but are aware of, willing, and able to deal effectively with the human dimensions of the problem that emerge when a diverse community faces the heightened anxiety of a Superfund cleanup. Nowhere do the conflicting points of view, perceptions, and expectations of professional risk managers and diverse community interests cause more problems than with regard to the issue of health effects. State and federal public health officials most often do not address the health effects issue in a manner that meets
NYANZA: A SMALL TOWN AND ITS SUPERFUND SITE
179
the needs of concerned neighbors of a Superfund site. Professionally trained epidemiologists focus on difficult-to-satisfy scientific standards for establishing causality (specification of sources, transport fate, effective dosages delivered to receptors, and measurable health endpoints); potential victims focus on health effects, real and imagined (neurological symptoms, rashes, tumors, emotional problems). While the professionals are reluctant to respond to such ambiguous complaints, neighbors resent the lack of reassurance from health professionals obviously more concerned with scientific abstractions than with people as patients. Professionals want adherence to rigorous research standards; neighbors want clinical attention to their perceived afflictions. The health studies mandated in Title III of the Superfund Amendments and Reauthorization Act of 1986 will not alter this basic mismatch of professional and community perspectives on the issue of health effects. Judging from evaluations of health effect studies at Superfund sites, even investigations conducted by the Agency for Toxic Substances and Disease Registry are unlikely to satisfy scientific requirements for causality, let alone potential victim demands for clinical attention (Grisham, 1986; Andelman and Underhill, eds., 1987). There are a number of options for dealing directly with this problem rather than aggravating it with additional, inconclusive studies: 1) provide professional training for local health providers in the recognition and treatment of the effects potentially caused by the specific chemicals at the site. 2) provide citizens access to evaluative clinical services provided by occupational health specialists knowledgeable in the diagnosis and treatment of the health effects of toxic substances. 3) Following the visiting nurse model, provide periodic community visiting clinical services by medical specialists. While such steps may involve difficult administrative, budgetary, and liability issues, they will surely be more cost effective than epidemiological studies which fail to meet community needs.
Conclusion The Nyanza case is a rich one in that it readily generates a number of lessons for participants in similar risk communications situations. This is not to say that the Nyanza case can teach participants how to avoid difficulties in risk communication. At best, risk communication around hazardous waste sites is a difficult, delicate process. But understanding the dynamics of the Nyanza case can help risk managers at hazardous waste sites anticipate, tolerate, and patiently deal with each situation's most problematic aspects.
180
JOHN DUNCAN POWELL
An earlier version of this paper was presented at the Conference on Environmental Gridlock, Princeton, New Jersey, November 1987.
References Andelman, J. and Underhill, C. (eds). 1987. Health Effects from Hazardous Waste Sites. Chelsea, Michigan: Lewis Publishers, Inc. Grisham, J. 1986. Health Aspects of the Disposal of Waste Chemicals. New York: Pergamon Press.
ENVIRON IMPACT ASSESS REV 1988;8:175-180
NYANZA: A SMALL AMERICAN TOWN AND ITS SUPERFUND HAZARDOUS WASTE SITE
JOHN DUNCAN POWELL
The Nyanza hazardous waste site in Ashland, Massachusetts, became known in 1981 as one of the top ten sites on the Environmental Protection Agency (EPA) Superfund priority list. As a "risk event" to be studied for lessons in risk communication, it is representative of a class of historic industrial sites found on the outskirts of metropolitan areas such as Boston that emerged in the 1970s and 1980s as a focus of concern over toxic wastes and public health. From 1917 until 1978, when Nyanza, Inc. ceased operations, the 35-acre site on Megunco Road in Ashland was host to a series of companies manufacturing textile dyes and intermediaries. It was the discovery of mercury deposits in the Sudbury River in 1970 by EPA contract researchers and the State Division of Water Pollution Control's efforts to analyze and control the sources of contamination that led to the eventual involvement of the EPA and its Superfund program at the Nyanza site. Currently, the site has funding and an approved Stage I plan to stabilize the site and prevent further groundwater pollution, and a Stage II plan to evaluate further and clean up the groundwater which moves from the site, under the Pleasant Street neighborhood (and often into the basements of the homes there), and discharges into the Sudbury River system. There are a number of aspects to the Nyanza case which make it particularly promising for learning lessons in improving risk communication. First, as an historic industrial site in a small town, it lies in close proximity to an exposed population of neighbors, making the assessment and communication of health risks particularly important. But its historic presence also means that redefining local perception of the dye plant on Megunco Road from a place to work (even if a source of nuisance odors) into a potentially life-threatening menace was a major wrench. For neighbors of the plant and for other townspeople and some local officials, Nyanza has been a rude awakening to the risks of modern American life. The local media have played a prominent role in this situational re© 1988 Elsevier Science Publishing Co., Inc. 52 Vanderbilt Avenue, New York, NY 1001"7
0195-9255/88/$3.50
176
JOHNDUNCANPOWELL
definition and the related assessment of health risks, an endeavor which has evoked both praise and censure. The second aspect of the Nyanza situation which makes it a rich case for study and analysis has to do with the complexities of the historic waste disposal practices on the site and the resulting wide variety of environmental and potential health impacts. Raw liquid wastes and dye waste sludges were for 60 years routinely discharged, accidentally or deliberately, into wetlands and brooks adjacent to the various buildings and sheds in which the dyes and intermediaries were manufactured. In addition, organic liquid and inorganic wastes and mixed sludges were either pumped or barreled and hauled up Megunco Hill above the plant, and then dumped on the ground, into wetlands, or into waste pits as standard disposal practice. Thus, the still-active light industrial site is contaminated in a variety of specific locations by a wide range of toxic materials, and the waste disposal hill area suffers from surface, subsurface, and wetlands contamination. Both surface water and groundwater contamination have moved offsite, polluting downgradient water courses, wetlands, and neighborhood basements during seasonal high water table periods. The physical complexities of the site and its contamination impacts have provided ample material for risk communication conflicts during the process of site assessment, selection of remedial alternatives, and the assessment of health risks. Third, the Nyanza case involves an intricate pattern of intergovernmental relations concerning a single site. Historically, the local Board of Health responses to neighborhood complaints of nuisance odors and waste discharge impacts on Chemical Brook. By the early 1960s, the State Division of Water Pollution Control (DWPC) took a series of steps to force the dye company to upgrade the partial waste treatment system that had been operating since 1919. The DWPC and, later, the state Department of Public Health were gradually drawn into dealing with the disposal practices on Megunco Hill. When the JBF Scientific Research Corporation, under contract to the EPA, traced mercury contamination of the Sudbury River up to its source at the Nyanza site in 1970, the Metropolitan District Commission (MDC) became involved because Reservoirs # 1 and # 2 were standby supplies for the MDC water distribution system (including Boston and some 40 surrounding communities). Soon the Division of Fish and Wildlife was drawn in because mercury contamination of river and reservoir fish was encountered. In 1975, a number of environmental protection agencies were combined into the State Department of Environmental Quality Engineering (DEQE), which, under the 1979 Hazardous Waste Management Act (Massachusetts General Laws, Chapter 21C), took an aggressive role in dealing with the Nyanza site. The EPA, in setting up its Superfund program as mandated in 1980, placed the Nyanza site on its National Priority List in October 1981, and, after an abortive attempt to deal with the responsible parties (begun by DEQE), took over the cleanup of the site in August 1982. This pattern of complex
NYANZA:A SMALLTOWNANDITS SUPERFUNDSITE
177
intergovernmental relations dealing with Nyanza affected risk communication significantly. While it brought to bear a wide range of expertise and experience in dealing with a common problem, it complicated and slowed down the process of bringing the site under control and remediating its impacts, In turn, delay eroded local confidence in the process, and eventually produced a skeptical or even adversarial posture on the part of concerned local citizens, officials, and the media. This erosion of confidence and trust combined with the already existing uncertainties and technical complexities presented by the site itself and worked to exacerbate disagreement over the assessment and remediation of risks. Fourth, under such circumstances, it should come as no surprise that dealing with the local public at Nyanza, as it is at most Superfund sites, can be a communications minefield. The initial media reporting of the Nyanza site as among the "Top Ten" on the National Priority List entrenched the perception of the site as a dreaded menace. This perception, reinforced by a talented editorial cartoonist, became--and remains--imbedded in the public mind. An organized citizens group quickly emerged with the Nyanza site and its health impact on the community as its focus. It conducted a door-to-door sampling of health problems among the site's immediate neighbors and found eight cases of cancer and assorted ills among the 47 households it covered. This fact was communicated by several means: a public meeting called by the group, letters from responsive local legislators, and guest appearances on local radio shows. Local reporters quickly learned of and reported an additional 12 cases of cancer in the town. Reaction by local and state health authorities was technically sound from an epidemiological point of view: that is, skeptical because of the small numbers and the lack of precise end points and direct exposure measures. But the reaction was disastrous from the perspective of effective risk communicationl The cancer scare in the early summer of 1982 generated a continuing legacy of distrust in governmental agencies and officials, and an explicit dissatisfaction with a process which elevates the principles of a science above the direct health concerns of citizens. This legacy remains perhaps the greatest obstacle to the communication of health risk information during the ongoing assessment and remediation process at Nyanza.
Lessons Learned and Recommendations for Improving Risk Communications Superfund risk managers enter a scene dominated by people with perspectives different from theirs. These people and their perspectives are responsible parties (RPs) concerned with conducting their businesses; neighbors, with intimate and long-standing knowledge of the site and its off-site impacts, who are concerned with their health; local media that focus on worst-case risk potential and the human interest reaction of the neighbors; local officials with conflicting inter-
178
JOHNDUNCANPOWELL
ests--concern about the local tax base, the business climate, the property values, the impact of negative publicity concerning the hazardous waste problem, the health impacts of the site, the slowness of the Superfund process, and the lack of bureaucratic responsiveness to health concerns; and citizen groups interested in participating effectively in the decision-making process. While Superfund risk managers concentrate on an orderly attack on site containment and remediation, these other groups have their own ideas regarding priorities and resource allocation. They begin the process with the assumption and expectation that Superfund will come into their community and quickly and quietly clean up the toxic material on the site and rid the community of it. This is assumed. What is expected is that their concerns will be addressed in a prompt and effective fashion. Businesses expect the investigative and remedial disruptions caused by the site to be minimal. Neighbors expect to be told whether their fears of health impacts are warranted, and what to do if they are. Local reporters want definitive answers to questions beyond the limits of scientific certainty. Local officials expect to have control over the local impacts of the remedial measures taken at the site. And citizen groups expect a responsive and forthcoming sharing of information and decision making. Superfund managers find that these groups are not easily persuaded to alter their points of view and adopt those of the risk managers including the attendant legal, procedural, and budgetary constraints. This basic factor can generate considerable tension and conflict, but it will not go away; it must be managed. These are concrete steps that will help manage this problem: 1) The timely provision of information from the EPA to the public must be institutionalized by means of a representative citizens advisory committee and community archive. Regular meetings with this committee, to share information and plans, help minimize unnecessary conflict. 2) Basic decision-making power cannot be shared by Superfund risk managers, but opening up key stages of the decision-making process to structured community participation can help. For example, collaboration in defining the scope of the Remedial Investigation and Feasibility Study would help reduce conflict over the results of such studies. 3) Superfund on-site coordinaters must be selected and supervised carefully to ensure that they are not only technically competent and well informed, but are aware of, willing, and able to deal effectively with the human dimensions of the problem that emerge when a diverse community faces the heightened anxiety of a Superfund cleanup. Nowhere do the conflicting points of view, perceptions, and expectations of professional risk managers and diverse community interests cause more problems than with regard to the issue of health effects. State and federal public health officials most often do not address the health effects issue in a manner that meets
NYANZA: A SMALL TOWN AND ITS SUPERFUND SITE
179
the needs of concerned neighbors of a Superfund site. Professionally trained epidemiologists focus on difficult-to-satisfy scientific standards for establishing causality (specification of sources, transport fate, effective dosages delivered to receptors, and measurable health endpoints); potential victims focus on health effects, real and imagined (neurological symptoms, rashes, tumors, emotional problems). While the professionals are reluctant to respond to such ambiguous complaints, neighbors resent the lack of reassurance from health professionals obviously more concerned with scientific abstractions than with people as patients. Professionals want adherence to rigorous research standards; neighbors want clinical attention to their perceived afflictions. The health studies mandated in Title III of the Superfund Amendments and Reauthorization Act of 1986 will not alter this basic mismatch of professional and community perspectives on the issue of health effects. Judging from evaluations of health effect studies at Superfund sites, even investigations conducted by the Agency for Toxic Substances and Disease Registry are unlikely to satisfy scientific requirements for causality, let alone potential victim demands for clinical attention (Grisham, 1986; Andelman and Underhill, eds., 1987). There are a number of options for dealing directly with this problem rather than aggravating it with additional, inconclusive studies: 1) provide professional training for local health providers in the recognition and treatment of the effects potentially caused by the specific chemicals at the site. 2) provide citizens access to evaluative clinical services provided by occupational health specialists knowledgeable in the diagnosis and treatment of the health effects of toxic substances. 3) Following the visiting nurse model, provide periodic community visiting clinical services by medical specialists. While such steps may involve difficult administrative, budgetary, and liability issues, they will surely be more cost effective than epidemiological studies which fail to meet community needs.
Conclusion The Nyanza case is a rich one in that it readily generates a number of lessons for participants in similar risk communications situations. This is not to say that the Nyanza case can teach participants how to avoid difficulties in risk communication. At best, risk communication around hazardous waste sites is a difficult, delicate process. But understanding the dynamics of the Nyanza case can help risk managers at hazardous waste sites anticipate, tolerate, and patiently deal with each situation's most problematic aspects.
180
JOHN DUNCAN POWELL
An earlier version of this paper was presented at the Conference on Environmental Gridlock, Princeton, New Jersey, November 1987.
References Andelman, J. and Underhill, C. (eds). 1987. Health Effects from Hazardous Waste Sites. Chelsea, Michigan: Lewis Publishers, Inc. Grisham, J. 1986. Health Aspects of the Disposal of Waste Chemicals. New York: Pergamon Press.