Chapter Ten
Industrial Pollution Along the Wicomico River
Maureen Skidmore
Salisbury Marketing, an automotive service location and a gasoline station, is located at the southwestern corner of North Salisbury Boulevard (rt. 13) and Bridgeview Street in Salisbury, MD. On November 22, 1988 Salisbury Marketing officially purchased the land, but the site had been run as a gasoline service station ever since 1975. When Salisbury Marketing purchased the land, it operated the site as the Original Deli Store and also dispensed gasoline there. Salisbury Marketing has since closed and the site is now operated as the Eagle Express Mart, a convenience store that also dispenses gasoline. [1]
Site
of the Former Salisbury Marketing
Photo by Maureen Skidmore, April 13, 2002
In April of 1989, Salisbury marketing began excavating the property in order to install underground gasoline pipes and fittings on the property. While doing this, five hidden underground storage tanks leaking free flowing petroleum and petroleum saturated soils were discovered. The conditions of the site were reported to the Maryland Department of the Environment (MDE.) With the reporting of the site, Salisbury Marketing entered the Superfund process. [2]
The Superfund process is expensive, but necessary. Superfund sites have a very large impact on the citizens of a town, in many different ways, but the majority of people are unaware to the workings of Superfund. It is also very difficult to find information about the histories of these pollution sites.
Around the 1960’s, citizens really began to take a stance on pollution, once they realized the ill effects that their own pollution had on them. This new found environmentalism even reached the United States congress. In 1963, congress passed the Clean Air Act, which actually, in writing, set national standards for many air and water pollutants. This was followed by the Clean Air Act Amendments of 1970, 1977 and 1990. [3] Born out of this environmentalist movement, on December 11, 1980, was the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) also known as Superfund. Six years later, the Environmental Protection Agency, which was formed in 1970 in order to oversee and enforce these pollution regulations, added amendments to CERCLA. They were collectively termed the Superfund Amendments and Reauthorization Act (SARA.) [4]
The entire idea behind the formation and the need for Superfund is to help fund the clean up efforts of sites that are so polluted the owners can no longer afford to foot the bill. However, much of the pollution at these sites, though intentional, was not done out of malice. Many times certain pollution disposal methods that we see as being harmful now were common practice several decades ago. Or, sometimes we simply did not understand the effects that certain chemicals would eventually have on the environment and ourselves. We as humans seem to have a history of doing things first and then understanding their consequences later. Superfund also helps to pay for clean up efforts at sites where the owners have left and cannot be found. [5]
But what exactly is Superfund? Superfund is a very large pool of money that is collected from the taxes levied on chemical and petroleum companies. [6] In “An Analysis of the Costs at Five Specific Superfund Sites”, the EPA estimates that they have spent 17.7 billion dollars on Superfund clean ups. The price tag for individual sites may vary, of course, according to pollution levels found there. One particular and very severe case, a creosoting site in Conroe, Texas cost 38.7 million dollars to clean up. [7] As of September 30, 1997, 1,353 Superfund sites had been classified, and 52 sites had been proposed for classification. There were also about 3,000 sites that had been reported, but had not yet been inspected or classified. The average time for a cleaning up a Superfund site is 3.9 years. [8]
Returning to Salisbury Marketing, the pollution on the site was officially discovered, according to records, on September 28, 1989. The EPA/ Brownfields division administered the first steps towards a clean up. With Salisbury Marketing, two monitoring wells and one recovery well were installed on the property. These wells were then monitored and sampled by HTS Risk management Services, an independent organization- paid for by the property owner, who oversaw the clean up of the site. The well samples showed concentrations above the EPA’s legal limit of 1,2-dichloroethane, which is used in making plastics, and is also used as a solvent. Acetone, which is also a solvent, was detected, but not in a significant amount that was anywhere near a health risk. In August of 1989, Salisbury Marketing took the initiative of beginning clean up before an official assessment of the area had been completed. The company installed a hydrocarbon recovery and treatment system. [9] A hydrocarbon recovery system is what companies commonly use to clean up oil and gasoline that has seeped into the ground and into groundwater. A pump is dug into the ground until it reaches the oil that has seeped into the aquifer. The oil, because it will not mix with groundwater, it will float on top of the water-hence the pump need not penetrate all the way to the bottom of the groundwater. Then it is pumped through to the surface. Here it is filtered through several tanks that contain activated charcoal. Activated charcoal is very effective at removing impurities from a substance. Once this is done many times, the cleaned up water is then either disposed of into a municipal sewer system, or it can be returned back down into the groundwater. [10]
After the treatment systems were installed, a Preliminary Assessment (PA) was conducted, again, under the supervision of HTS. [11] A PA is a short investigation, conducted by trained EPA officials, which evaluates the extent of the pollution of a site. A PA verifies whether or not the pollution of a site is hazardous to human health or to the environment. Normally, after the PA, a Site Investigation (SI) would be conducted. An SI is a more detailed report, which enables the EPA to gather the site information needed to rank each location within the Hazardous Ranking System (the HRS). Rankings in the HRS are scored upon three criteria, groundwater migration pathways, surface water migration pathways and airway migration pathways. The most contaminated sites, which pose immediate and serious threats to human health and the environment, can use Superfund monies. These sites are classified “National Priorities List (NPL).” These are the most dangerous sites that cost millions of dollars to clean up. However, simply because a site is designated No Further Remedial Action Planned (NFRAP), and not NPL. NFRAP does not mean that there is no pollution at the site, or that the pollution is not dangerous and will not harm humans or the environment. If there is still enough pollution at a site to pose a threat to humans or to the environment, but is not enough to warrant an NPL standing, the site will be referred to a state level organization for clean up. [12]
The name of the state level program is the Environmental Restoration and Redevelopment Program (ERRP). The ERRP functions under the Waste Management Administration of the Maryland Department of the Environment. The purpose of the ERRP, according to their Activity Report for July 2001, is to be “responsible for managing the investigation and clean up of uncontrolled hazardous substances released throughout the state of Maryland. The program seeks to eliminate threats to public health from exposure to soils, groundwater and surface waters contaminated by controlled hazardous substances.” [13] Under the ERRP, there are three divisions. The first is The State Superfund Division, which oversees the cleanups of contaminated sites that are not listed on the EPA’s NPL. Currently, in Maryland, the State Superfund Division manages the cleanups of 19 sites, including one in Wicomico County- the Chevron Chemical Corporation. The next division is the Federal Facilities/NPL Superfund Division. This section helps oversee the cleanup efforts of sites in Maryland that are listed on the EPA’s NPL list, or where the Department of Defense is a responsible party with regards to pollution. Currently, there are no such sites listed in Wicomico or Somerset Counties. The last division of the ERRP is the Voluntary Cleanup/Brownfields division. This department, formed in emergency legislation passed by governor Paris Glendening in 1997, encourages companies to clean up and redevelop their own contaminated properties. Of course the ERRP will help the cleanup efforts, in the form of loans, grants and tax credits. The incentive is, if a company “turns themselves in” and admits to having pollution on their property, then if they make the efforts to clean it up themselves, penalties and fines will be less severe. [14]
As stated before, because the pollution on the Salisbury Marketing site was not dire enough to warrant national EPA help, the management of the Salisbury Marketing cleanup efforts was done by the state level ERRP Brownfields Division. Salisbury Marketing, after installing their hydrocarbon recovery systems, was officially listed, by the U.S. EPA, a NFRAP site. [15] At this point, the ERRP thought that the contamination on the site was contained and safe.
Pollution’s Affect on Groundwater and Water Resources
Contamination released from industrial sources can have very adverse effects on the environment and human health. As mentioned before, the three criteria that the Hazardous Ranking System uses to rank Superfund sites on are groundwater mitigation, surface water mitigation, and airway mitigation pathways. Water and Air are the two basic ways in which pollution can enter the environment. When we speak of Superfund pollution, more often than not, we are speaking about water pollution, and not air pollution. Therefore, it is important to understand the mechanisms of how pollution can enter our water systems and contaminate them. The pollutants that raise the most concern are petroleum hydrocarbons, chlorinated organics, heavy metals like zinc and lead, and inorganic salts. [16] This is because of their adverse effects on human health and on the environment. All water on the planet moves in a cycle, the hydrologic cycle. When pollution enters this cycle, it can stay there, for long periods of time. This of course is the same water that we draw for our wells, for our kitchens and for our bathrooms.
Water contaminant pathways can include surface runoff and groundwater contamination. Surface runoff is the water, which, after a precipitation event of rain, snow or hail, does not evaporate back into the atmosphere. This surface runoff will flow into streams, rivers, lakes, wetlands and other major bodies of water. If this surface runoff is contaminated, the contaminants will make their way into the bodies of water, as well. Likewise, contaminated groundwater can make its way into water resources. [17]
But how does groundwater become contaminated? In the past, hydrocarbon contaminants like oil and gasoline were buried as a “removal” method (we know now of course that simply burying pollution does not make it go away.) The storage tanks for these hydrocarbons used to be made of metals- metals that, over time, would corrode and leak. Now, since we have a better understanding of pollution, storage tanks are made of plastics and synthetics, which are better able to resist leaking. [18] A prime example is Salisbury Marketing, who found the buried gasoline tanks on their property during a routine excavation. Leaking underground contaminants are particularly dangerous because they are not readily visible and often are abandoned and unnoticed for years before anything is discovered or even done. [19] Contaminants that puddle on the soil surface can also percolate into the ground and eventually contaminate groundwater.
Many factors can affect and essentially speed up the flow of contaminants underground. One factor is soil type. The more porous the soil, the more readily the contaminant can flow through it. However, clays, which have a very low porosity, can also be particularly dangerous. Clays can readily desiccate; leaving cracks in the soils that can be several feet wide. This easily facilitates the flow of contaminants. [20] In Wicomico County, and along the Wicomico River, the soil generally contains quartz, organic material and a little bit of clay. In general, “the sediments in…Wicomico…consist of thin deposits of very limited water bearing capacity.” [21] This simply means that rather than having contaminated water percolate through the soils, it is more likely to pool on the surface and travel to the Wicomico River as runoff. Another factor is the plants and animals of the local region. Flora and fauna can leave extensive networks of openings, holes and voids that allow contaminants to pass through more easily.
Once contaminated water has percolated into the surface soil, it will continue to migrate downward until it reaches the water table. The actual definition of a water table is a bit difficult, but absolutely necessary to understand. Above the line that designates the water table, the pressure of the pores in the soil is equal to the atmospheric pressure + the pressure of the water present in the pore. Below the water table line, the pore pressure is equal to the pressure of the water alone. Basically, above the water table line, the soil pores are unsaturated with water, but below the water table line, they are saturated. The aquifer that is located right underneath the water table line is called the water table aquifer. This would be, normally, where communities would draw their water from to use in everyday life. It so happens though, that in Wicomico County the water table aquifer is so polluted with fertilizers that it is necessary to draw water from a deeper aquifer below the water table aquifer- the confined aquifer. [22]
Confined aquifers, though guarded by rock that semi-restricts the permeability and movement of water through it- the rock is called an aquitard-, can still become contaminated. The contamination of a confined aquifer is not as commonplace as the contamination of a water table aquifer, but it can still happen. The main site of entry for contaminants into a confined aquifer is in the recharge zone. This is where a confined aquifer, which is not be completely horizontal- twists towards the soil surface. This is above the water table line, so rainwater, along with contaminants, will percolate directly through to the confined aquifer and move downward. [23]
confined
aquifer water
table aquifer aquitard Wicomico
River water table line recharge zone
Groundwater
Movement
Diagram by Maureen Skidmore with help provided by Dr. Elichia Venso [24]
Pollution Sites in the Wicomico River Watershed
In the Wicomico River watershed, there are seven sites that have been investigated by the EPA as possible Superfund sites, and one site, WaWa Food Markets, that voluntarily cleaned their site. The sites are: Adams Co. and Sons, Inc. in Salisbury, Atlantic Wood Industries in Fruitland, Chesapeake Shipbuilders in Salisbury, Chevron Chemical Corporation in Salisbury, Dresser Industries in Salisbury, Salisbury Town Gas in Salisbury, Salisbury Marketing in Salisbury, and WaWa Food Markets in Salisbury. Each of the eight above sites, as of February 2002 are listed by the Maryland Department of the Environment as No Further Remedial Action Planned, even though some site investigations have technically reopened and had Site Survey Initiatives conducted. As of May 22, 2002, there are no sites in Wicomico or Somerset Counties that are listed as NPL. [25] Therefore, technically no sites in Wicomico County draw monies from the federally funded Superfund program. There, however, still lurks the possibility that huge pollution sites could exist, and that simply no one has reported them. This is because pollution sites are reported to the EPA and other government agencies in very haphazard fashions. So, the possibility of overlooking a pollution site does exist.
In order to better understand what a Superfund site is, we need to examine several case studies. Since there are no NPL Superfund sites along the Wicomico River watershed, we will take a look at three sites designated NFRAP in addition to Salisbury Marketing. These sites, Chevron Chemical Corporation, WAWA food markets-located at the meetings of South Salisbury Blvd., Waverly St., Ohio Ave., and Maryland Ave., and Dresser Industries represent different divisions of the Maryland Department of the Environment. Salisbury Marketing, Dresser and Chevron were headed under the Brownfields division, while WAWA was headed under the Voluntary cleanup division. [26] Each site also shows different aspects of the state level industrial pollution clean-up process.
Chevron Chemical Corporation
Chevron Chemical Corp. was one of the many companies to answer surveys about pollution at their industry site. The Eckard committee, which was a senate subcommittee, sent out these questionnaires in an effort to better understand what kind of pollution was located in the state. Chevron responded, so in essence, they basically reported themselves. [27] The Department of Health and Mental Hygiene then investigated the pollution at Chevron Chemical Corporation. The clean up was then headed by NUS Corporation under the Maryland based Environmental Restoration and Redevelopment Plan, State Superfund division. [28] The national EPA funded NUS. [29] The Chevron Chemical Corporation is a .52 acre are of land located on Bateman St., in a light industrial area of downtown Salisbury. The Corporation right now consists of one building that serves as a furniture warehouse.
A brief history of events for the Chemical Corporation starts in March of 1917 when the city of Salisbury purchased the land. From 1951-1971 the Chevron Chem. Corporation leased the land from Second National Bank and operated a pesticide mixing and storage facility. The common method of floor sweepings, wood scraps and other pesticide-contaminated debris in those times was to place it all in a dust mill pit and cover it with cement. Chevron believed that some of this contamination has leaked out. In February of 1991, the MDE performed a partial Site Inspection. They collected samples from three close proximity wells and on site soils. Pesticides and Insecticides, such as Dieldrin, heptachlor, DDT and DDE were found in the samples. Then in April of 1990, an SI was completed for the site. The inspected area included soil and sub-soil samples around the former loading dock that the company used. The inspection revealed pesticide contamination and contamination from aromatic hydrocarbons. However, a toxicology evaluation revealed that the levels of contaminants were not sufficient enough to produce serious adverse health effects on humans from short-term exposures. [30] A short-term exposure is exposure to a lot of a hazardous chemical, at once, over a short period of time. Depending on the chemical, this time span may vary from minutes to hours or even days. This is in contrast to long-term exposures, which is exposure to a low dose of chemical repeatedly over a long time span. In the case of long-term exposures, exposures usually last for many years. [31] Finally, on January 23, 1996, the state designated the site as NFRAP.
Currently, Barbara Cantrell of Georgia owns the property and leases it as a furniture storage facility. [32] What is unique about Chevron Chemical Corporation is that for the ERRP Activity Report for the year 2001, the owners of Chevron Chemical Corporation have not responded to requests by the MDE to conduct further site inspections in areas of concern. As of now, a Site Survey Initiative has been proposed for the site. This means that the investigation of the site will open back up for further pollution testing. The investigation opened up again, because there is an administrative order from the state level EPA to complete and elaborate on the earlier investigation. Below all NPL sites in the state of Maryland, the MDE has ranked the Chevron Chemical Corporation as the sixth most polluted site, according to a Hazard Ranking Model, in the entire state of Maryland. [33]
Dresser Industries
Dresser Industries is located on West College Ave. in Salisbury and has been manufacturing and testing fuel dispensing pumps and automobile hoists since the company first started using the land in Salisbury in 1938. The company has used numerous hazardous chemicals over the years since its existence in Salisbury. Metal that is formed into component parts is pretreated with a zinc phosphate bath to prevent corrosion. Some manufactured machine parts are electrostatically powder painted. Gasoline dispensing pumps that are made there are tested with Norpar 12, which is a substitute for gasoline. Therefore, Norpar 12 had replaced the mineral spirits that were once used to calibrate and test the pumps and the 10,000 gallon mineral spirits storage tank and the 5,000 gallon Underground Storage Tank for the mineral spirit wastes were removed from the property. Before 1982 the company owned a permit that allowed for the disposal of caustic cleaning waste and metal pretreatment wastes into an asphalt surface impoundment (a surface lagoon). At first the lagoon was not even lined, but eventually they did line it and used it as a contaminant storage tank. As of now, the company pre-treats their metal wastes so that they can dispose of it in the municipal water treatment system of Salisbury. Every company that releases waste water into the Wicomico County sewage system needs to obtain a permit to do so. Stated in the permit is the acceptable level of contaminants that can be released with that water, to be treated by the county. Each industry must then treat their wastewater, before releasing it into the municipal water treatment system, in order to lower the level of contaminants sufficiently. Consequently, the lagoon is out of service.
In 1987 the company ceased all electrostatic powder painting operations and replaced them with wet, solvent based paints. Right now the company has permits for all of the discharges that the company generates into the water treatment system.
In 1989, the MDE completed a PA on the site and in January of 1996 the EPA declared the site NFRAP. After the EPA’s decision, NUS’s sampling of monitoring wells in March of 1999 showed that petroleum hydrocarbons and chlorinated hydrocarbons existed on the site from the storage lagoon leaking contaminants into the groundwater, meaning that the NFRAP designation for the site was too hasty. Currently, under cooperation from the national EPA Superfund program, the MDE is conducting a Site Survey Initiative of Dresser Industries, just as was done with Chevron Chemical Corporation. [34]
All three of the sites examined, Dresser, Chevron and Salisbury Marketing were all designated NFRAP. Coincidentally, all three of the sites had their investigations reopened in order to conduct Site Survey Initiatives. Therefore, it is easy to come to the quick conclusion that NFRAP rulings are incorrect. However, this is merely three sites in Maryland, out of the thousands of sites located around the country. So, as it may appear that NFRAP designations are inaccurate and that pollution is probably still remaining, the government spends much time and effort in investigating these sites and they are given the best possible rulings as possible.
Dresser
Industries
Photo by Maureen Skidmore: April 26, 2002
WAWA
The WAWA site was never reported to the national EPA level. It was just reported to the state MDE level. The property is 1.9 acres and is surrounded on all sides by public access roads and by businesses and houses. The potable water for WAWA and the surrounding area is drawn up through Park Well field which is located just 1.8 miles from the store. There are also eleven private wells, meaning privately owned houses, each located within 0.5 miles of the store. The property was grassland until it was purchased and developed by Johnny and Sammy’s Inc. into Shore’s Pride Inc. The site was operated as a restaurant between the 1940’s and 1998. In 1998 the site was converted to a WAWA. Environmental investigations in 1998 and 1999 showed groundwater contamination. The chemicals found included, primarily, tetrachloroethene-which is a chlorinated dry cleaning solvent, petroleum fuel residues (naphthalene, isopropylbenzene) and traces of trichloroethene dichlorodifluoromethane, chloroform and methyl chloride, which are all chlorinated hydrocarbons commonly used as solvents, pesticides/insecticides and metal degreasers. [35] The source of this groundwater contamination is currently unknown. The confusion lies in the fact that most of the chemicals found would not have been used by either Shore’s Pride Inc. or by WAWA. It was never discovered where the pollution at WAWA had originated from, but is believed that the contamination originated from off-site commercial sources. The only action taken was to clean it up.
This example shows that no matter how safe a site may appear, because of the activities, or lack of activities that have taken place on the property, contamination can still leak in from off site sources, via groundwater movement. No matter where the contamination originated from, the owners of the land that it is found on are considered, by the EPA, to be potentially responsible parties (PRP.) By law, the owners of the land, at the time of the pollution discovery, then assume responsibility for the clean up processes. [36] The property owner of WAWA Inc. began a voluntary clean up of the site on March 24, 1999, placing WAWA on the Voluntary Cleanup Program Status. Upon the filing, WAWA assumed responsibility for the contamination. The final ruling of the property, No Further Requirements Determination (NFRD), is that it can only be used for commercial/ industrial purposes, and that groundwater beneath the facility cannot be used. On August 12, 1999. The status of NFRD was officially recorded onto the property deed in Wicomico County’s land records. [37]
WaWa
Food Markets
Photo by Maureen Skidmore: April 13, 2002
Pollution’s Effects on Human Health, the Environment and the Wicomico River
Industrial pollution leaking into groundwater have been proven to have adverse effects on human health and the environment, but these chemical’s effects on the Wicomico River are unclear and might never be determined.
A lot of the chemicals found at each of the four sites-even though in moderate amounts-are still harmful to human health. For example, Zinc phosphate, which was found at Dresser Industries, is used as a metal primer. Its effects on humans can include respiratory irritations, headaches, dizziness, and a loss of coordination. In more severe cases, permanent brain damage can result and nervous system damage that could result in death. [38] Also, pesticides, such as Dieldrin, DDT, DDE and the insecticide Heptachlor that were found at the Chevron Chemical Corp. site, besides killing plants and insects can have harmful effects on humans as well. Dieldrin, and DDT both cause dizziness, convulsions, headaches, nausea and vomiting during short-term exposures. Long-term exposures of Heptachlor may be carcinogenic, or cancer causing, in humans. [39] Also, the environmental effects of these pesticides and insecticides are severe. Each of these chemicals, Dieldrin, DDT, DDE and heptachlor, and most other pesticides, have been shown to bioaccumulate in the environment. When these contaminants leak out into the environment, special attention must be given to monitoring aquatic organisms. [40] This is where bioaccumulation will start. Bioaccumulation describes when certain chemicals are released into the environment and are consumed by organisms that are low on the food chain. Many times, because the contaminants can readily make their way to waterways, the first organisms affected are aquatic ones. Then, another animal that is higher up on the food chain is going to eat many of the affected organisms. This second organism has now ingested multiple times the amount of poison that the first have ingested. This keeps on traveling up the food chain until the poison reaches the absolute top predator. For example, crops sprayed with DDT were eaten by insects. Then a fish would eat hundreds of insects before being caught by a bald eagle. The DDT concentrations would then be thousands of times more that in the original first insect that ate some sprayed plants. One of DDT’s negative effects on eagles is that it makes their eggshells too weak. Therefore, when a mother eagle would sit on them to keep them warm, the eggs would break. This greatly diminished the eagle population, because not enough babies were born to sustain the population. In addition to eagles, many times, unfortunately, this top predator is human beings. Perhaps this is why most people find the taste of the fish that they catch on the Wicomico River to be unpleasant and only catch and release them.
So, we know that sites along the Wicomico River have leaked pollution. We know that pollution can and will migrate through watersheds via surface water runoff and groundwater runoff. But we do not know the exact levels of pollutants that are actually found in the Wicomico River. This is because routine testing of the Wicomico’s waters for these toxic chemicals is not done. The Wicomico River is often times overshadowed by its more prestigious neighbor, the Nanticoke River, and even by the Chesapeake Bay. Also, there is a general sense of citizens of Wicomico County being left in the dark about the pollution of the river. For instance, some people believe that Salisbury University should purchase Dresser Industries and develop it into a parking lot for the overcrowded school. Well, they do not realize that Dresser Industries is a state superfund site and that if the University wanted to purchase it, they would then assume the responsibility of all clean up costs. Also, when I told my roommate that I would be writing a paper on Superfund sites along the Wicomico River. She remarked- surprised- saying “There’s a Superfund site in Wicomico County?” Though technically she is right in saying there are no (federal) Superfund sites, the emphasis that I make is that she was surprised that we had organized large-scale industrial pollution cleanups in Wicomico County. The lack of awareness of Superfund sites in Wicomico County is not due to a lack of intelligence on the part of the citizens, but rather a lack of information and a lack of publicity. Often, authorities and businesses try to keep major pollution incidents hush hush, when they should be publicizing information so that we can learn from our mistakes, because knowledge and understanding are powerful tools. We do have the power to control pollution, both along the Wicomico River and in the rest of our world.
Just as with Chevron Chemical Corporation and Dresser Industries, Salisbury Marketing found out that their pollution problems were not over, even with the 1990 ruling of NFRAP. In 1999, with cooperation from the national EPA, the MDE conducted a Site Survey Initiative. As stated before, “the Site Survey Initiative was proposed to reassess the status of those sites that were previously designated No Further Remedial Action Planned by the EPA. This initiative is intended to determine if site conditions have remained stable, provide a current description of the site, and identify and address any new pathways for contamination.” So, no matter how much a company thinks they are out of the water with regards to site pollution- no pun intended- the EPA and MDE will continue to work to remove toxic pollution from our environment. Now, with the help of these government organizations, citizens need to catch up, too. [41]