On April 16, the Environmental Protection Agency (EPA) approved a Record of Decision (ROD) for further treatment of contamination at the Havertown Superfund site. The ROD is a public document that explains what methods will be used to clean up a Superfund site. It was created from information generated during the Remedial Investigation/Feasibility Study (RI/FS), finalized in August 2007.

The ROD covers two distinct areas (or operable units). The first area (Operable Unit 3A) was found to have deep groundwater contamination under the site of the former National Wood Preserves plant near Eagle and Lawrence roads. The EPA plans to install an additional recovery well to prevent the migration of contaminants and restore the groundwater to beneficial use. The EPA also intends to increase the capacity of the current treatment facility and use a process known as “chemical flushing” whereby chemicals are injected into the water to treat the contaminated groundwater.

According to the EPA, the recovery wells are making enormous progress in reducing the area of contamination in the groundwater.  The area of groundwater contamination (also known as a “plume”) has been narrowing as the previously installed wells continue to extract impurities.

The second area (Operable Unit 3B) is recreational open space behind Rittenhouse Circle, near the end of Washington Avenue. The EPA will excavate 50 feet by 50 feet of contaminated land and replace it with clean soil. A sewer line there will also be removed. The EPA plans to install three wells to extract contaminated groundwater and transport it to the treatment facility. Routine groundwater monitoring will also be performed to ensure the effectiveness of the remedy.

After the designs for these proposals are completed, funding for construction will be sought from the U.S. Environmental Protection Agency. The estimated cost of the project is between $3.5 million and $4 million.

Construction could begin as early as May of 2009, and be completed by the end of September 2009. It should be noted that delays are possible as the EPA seeks access to residential property near Rittenhouse Circle and behind Naylor’s Run. After the construction, treatment will continue for several years.

Not everyone is in agreement with the EPA’s approach, most notably Dr. Michael Levin, a Havertown resident and environmental scientist who has researched the site for many years. Dr. Levin feels that the EPA has not sufficiently analyzed the data and that the entire remedy should be re-evaluated. He cites possible danger of the accumulation of harmful substances in gardens, contamination in basement water and elevated levels of contaminants in indoor air. Dr. Levin also categorically opposes “chemical flushing” of the groundwater. Dr. Levin has been raising his concerns with federal officials, and maintains a website at: www.EnvironResearchAssoc.com

For more details on the project, visit www.epa.gov/reg3hscd/super/sites/PAD002338010/index.htm. Comments and questions about the Superfund project should be referred to Jill Lowe, remedial project manager, at (215) 814-3123, or by email at lowe.jill@epa.gov. The source is: http://www.pahouse.com/Vitali

IN THE INTERESTS OF BALANCE, DR. LEVIN RESPONDS
It is true that not everyone is in agreement with EPA’s approach. Dr. Michael Levin, a Professional Ecologist and Environmental Scientist has researched the Havertown Superfund Site (NPL #542) for the past 18 years and written over 20 articles now posted to the ERA website www.EnvironResearchAssoc.com.

Dr. Levin believes that the entire remedy must be reevaluated now considering that 25 years have elapsed since the site was first listed on the National Priority List (NPL, AKA The Superfund List) and lessons have been learned from at least 107 wood preserver sites of over 1,200 sites on the NPL throughout the country. Accordingly, I have made over 20 oral presentations to meetings of elected officials, at Commissioner’s Meetings as well as publishing them in other local media over the years.

I find that EPA hasn’t analyzed, charted, graphed or drawn conclusions from all data that it collects at a cost to taxpayers of nearly $1 Million/year for the past 8-years. As a result EPA can make only unsupportable remarks about the beneficial effects of its now $20+ Million dollar remedy from which it has paid for capital equipment, operations and maintenance of the treatment plant, project management (EPA pays itself), and EPA’s subcontractors paid to run the treatment plant that extracts contamination from groundwater and writes reports that EPA presents.

For example, it is false to state that recovery wells are making “enormous” progress in reducing the area of contamination or that the plume of contamination is “narrowing;” these are unsupported by long-term studies because data has not been analyzed; plants in gardens may be accumulators of hazardous substances both as they grow and as water is rapidly pulled into developing fruits; basement water - a condition particularly of older homes - as well as very wet years -  may contain hazardous substances; and indoor air quality may have elevated levels of contaminants because volatile organic compounds, known as VOC’s,  are concentrated in enclosed spaces above contaminated soils or groundwater.

EPA has generally been unresponsive to requests for information regarding a government buyout of some 77 properties on the plume of contamination, including making available a list of comparable properties in the geographic area, providing closing costs, and moving expenses to landowners above the plume of contamination where vapors could concentrate in homes and other enclosed spaces; these are landowners for whom a deed restrictive ordinance and/or covenant will be established and enforced.;it may prove to be oppressive and unpalatable.

Additionally, Dr. Levin categorically opposes any use of chemical additives to ground water or for chemical flushing using such additives as emulsifiers or other chemical substances and further, he thinks it would not even be considered if all the recovery wells were in the “right” places to suck up subsurface pools of contaminants; chemical additives would probably confound or otherwise complicate a future remedy. EPA should know this, as well as not use the Havertown Superfund Site as an experiment.  For EPA to even propose this “kitchen chemistry” would involve this site being: (A) so unique and unable to be remedied that it would require it or (B) it is the commonly accepted method to be used at all wood preserver sites.  Which is it: A, B, or Neither?

EPA’s acceptance and use of an individual’s cancer risk of between 1 in 10,000 up to 1 in 1,000,000 does not mean that any individual is safe if he or she is exposed to a contaminant, no less to a soup of contaminants about which even less is understood.  Any person in that wide range could be the genetically predisposed individual, the exception who contracts a disease from that source.  Almost nothing is known about the health effects of multiple sources, no less a soup of them.

M. H. Levin, Ph.D., ENVIRONMENTAL RESEARCH ASSOCIATES, Inc., + since 1970 + 414 Mill Road, Havertown, PA 19083 Voice (610) 449-7400 Fax (610) 449-7404
Email ERAincMHL@aol.com
Website http://www.EnvironResearchAssoc.com