THE SUPERFUND REMEDY IN LATE SUMMER PERSPECTIVE

A “critical” time period exists from January 2006 to the present, during which EPA currently is deliberating the final remedy at the Havertown PCP site.  Months have passed with a number of cancelled Environmental Advisory Committee (EAC) meetings between the August 2005, 5-year review and a coming final Record of Decision (ROD) by the Environmental Protection Agency.  Haverford is right down to the wire; if you don’t speak up, the outcome will be determined for you.  That is just what the Environmental Protection Agency is hoping for.

Criticism of  EPA’s November 2005 oral presentation was not deemed worth responding to by the Agency.  Recently, instead of answering oral telephone questions forthrightly, EPA determined that it is necessary to put a “minder” on the phone line when a project manager is asked technical questions about the Havertown PCP site.  “Minders,” or listening observers are necessary when questions cannot be answered freely and honestly; when a “minder” is on the line an employee responds to questions by reciting the Agency’s litany of  procedures.  This is a disgrace for a federally funded Superfund project in Havertown that has been ongoing for 23 years by an Agency that has been around for 36 years and is a good reason to believe that the remedy at the Havertown site, indeed, is obsolete. 

Wood preserver site remedies seem to have been established more than a decade ago with handling procedures that haven’t changed much since.  Additionally, the present remedial project manager, Jill Lowe, recently volunteered in a non-sequitur response that the next 5-year review won’t take place until 2010. EPA’s own guidelines for reviews of a site remedy in progress state that a 5-year review could take place at any time and is not locked into every 5-years.  Thus, Haverford would receive only one (1 ) more 5-year review in August 2010 before the site is handed to the State for further action. Furthermore, the August 5-year review wasn’t done by EPA; it seems to have been subcontracted to the outside firm that does the water treatment.  Haverford should insist that a 5-year review to determine progress be done every year – including 2006 – by the project manager who was once asked what unique contribution she was going to bring to the then near 20-year old project because no progress is demonstrable in the August 2005 5-year review.

In an endeavor to determine the leadership, structure and function of the EPA’s established “working group” on wood preserver sites, a number of phone calls to EPA offices in Washington, DC, were made.  The response  from the office of innovation indicated that the project managers at over 100 wood preservers sites don’t meet to share information on remedial technologies, but merely know of each other’s existence without comparing notes.  They get guidelines, a one-size-fits-all approach.  After being shunted from telephone to telephone in office after office I couldn’t secure further information about how innovative proposed remedies take place; I concluded they don’t.  With millions of dollars going into remedies at those wood preservers sites it is studied negligence not to share information that would enable the Agency to spend less money to get better remedies at wood preserver sites.  With an emphasis on guidelines, rather than on measurements, progress and tinnovative technologies based upon sharing of information, the remedy at the Havertown PCP site is firmly rooted in the last century. 

EPA halted doing detailed analysis of soils at the Superfund site in the mid-1990's.  As a result, the Agency grinding to a halt the remedy or for removing contaminated soils found down gradient from the site.  Soils at the Superfund site including those newly found downgradient are likely to be left in place and covered with another cap of minimal thickness and corresponding useful lifespan thereby leaving the problem of contamination for the future; this is unacceptable in Haverford where the Eagle Road business district is estopped from major planning or improvements. 
On the other hand, another nearby wood preserver’s site is receiving a $45 Million dollar soils removal with contaminated soils being trucked  685 miles for treatment north of Quesbec by thermal oxidation at over $400/ton (a ton of soil is about a cubic yard).  EPA doesn’t have a formula for determining which site will get the $50 - $200Million dollar solution and which, like Haverford, will get the $20Million dollar one.  Haverford’s remedy is unsatisfactory.  Both projects cited, however, are receiving federal and state funding and neither has a Principal Responsible Party locked in. 
 
You have to deal with this by multi-tasking with other things like budgets, warrants and resolutions.  Haverford State Hospital site too.  No one said your job would be easy.  Listen as your ad hoc committee on the Superfund remedy, which I fully support, asks questions and sets the course to improvement.  Find out what happened to that letter requesting input on the 2005, 5-year review that EPA stated it sent personally to each of you.  Then, send forward your requests  to EPA, the State Department of Environmental Protection and your elected State and Federal representatives.  Tell them you’re not happy with the current planned outcome, force the reevaluation of this contaminated and polluting waste site.  Tell them you want this site cleaned up, not just a wave of the hat and a soft-shoe as EPA pulls out in 2013 leaving the site as much of a subterrranean mess as when they arrived.

Haverford is not signatory to the Superfund remedy.  Haverford has a right to a receive better remedy.   Haverford has an obligation to stand up and be counted.  Get that better remedy for our residents.