MID-SUMMER NIGHT’S SUPERFUND REALITY

Haverford’s commissioners have done nothing for ten (10) years to modify the course of EPA’s actions at the Havertown PCP Site – number 542 on the National Priority List (NPL) of over 1,200 worst contaminated sites in the nation – which they could have done at any time.

Presently, there are no geographic boundaries; contemporary representations of the contaminated plume and soils chemistry are unknown; no land planning in the vicinity of the site has taken place; health risks have not been thoroughly evaluated; remedy technologies have not been updated from old 20th century ones including a now 10 year old 30 mil cap about the thickness of 15  2 mil trashbags; and there is no environmental monitoring plan for the site or its vicinity.  All of this was stated in 1996 and remains unfulfilled.  EPA can not give positive answer to questions about the efficacy of over $13M invested in actions at the site.

In the past 10 years, Haverford has had several chairmen of the Environmental Advisory Committee (EAC) upon whom the Commissioners’ have stated, “They rely” for advice on the Superfund site.  If there has been advice sought from the EAC, it is unknown what it is and there are no minutes of the EAC documenting requests made and disposition.  Most recently, the Chairman stated in February there have been “No instructions;” this means no request has been made by the Commissioners’ Ecology Committee, one chaired and vice-chaired by 4th and 3rd ward commissioners.  And, there has been no request from Haverford’s liaison to EPA who serves solely as a conduit for information transmitted to EPA but adds no new information. There is no written record of requests and, thus, all such communications could be considered to be “back channel.”  In view of a projected expenditure of ~$20Million dollars by 2013, more detailed written transactions of requests and dispositions in full public view are required.

Opinions of  EAC chairmen are known, but not in writing; one from1996 is in the form of the attached  resolution with explanation; it rejects the interim action as unsatisfactory.  A subsequent chairman stated the health risk assessment is incomplete. A later chairman has opined EPA’s August 5-year review is “not good.”  A recent chairman has stated, “This may be a remedy for someplace other than Haverford;” frankly, I won’t even concede this.

Now, with seven (7) years, or less,  left before EPA relieves itself of funding the actions at the undefined Superfund site and transfers it in whole or part to the State, inaction on the part of Haverford commissioners is a stumbling block to improvement, contaminated soils at the site remain, the contaminated area is more extensive and has no boundaries and the State can not be relied upon in the future to continue to operate an old technically complicated expensive remedy. 

Several solutions to the problem of satisfactorily completing this remedy are apparent, but all depend upon Haverford’s commissioners taking the steps to ensure openness of the process, accuracy and mid-course corrections to the remedy, and involvement of an ad hoc scientific committee on improvement of the remedy.