Environmental Research Associates

Research & Consulting Ecologists

July 2008

Havertown PA Superfund29 Jul 2008 02:38 pm

1. What evidence does the EPA have demonstrating that wood-preserving compounds like phenols, dioxins, pentachlorophenols, benzene, and dibenzofurans reaching “non-detectable” levels reflect the actual removal of contaminants from the groundwater instead of just a misrepresentative sample of uncontaminated groundwater being tested?

2. How many valences of heavy metals like arsenic compounds, tin, and chromium are being monitored at the Superfund Site? How have concentrations of organic compounds designated in (1.) and heavy metals, separated by valence, adjusted over time?

3. Which “biodegradation daughter products” would be present were biodegradation to occur naturally? What plan does the EPA have in effect to monitor the concentration of the “biodegradation daughter products?”

4. Would the EPA be willing to investigate the usefulness of on-site or in-situ bioremediation technologies to accelerate the removal of hazardous substances at the Havertown Superfund site?

5. How have the concentrations of chemical compounds not related to the wood-preserving process changed over time? Do any of these naturally occurring chemical compounds pose health/safety risks for life in and around Naylor’s Run?

6. Which new methods and technologies (e.g. slant drilling, use of subsurface slurry walls and others used at over 100 Superfund Sites) can be used to improve capture of groundwater, contaminants and removal of contaminants beneath the Superfund site as well as from nearby collection trenches and recovery wells?

7. For which other Superfund sites have a geosynthetic cap and compacted clean soil fill been used as part of the remedial action? Which specific types of development have been proposed-and-accepted or proposed-and-rejected at other sites with a geosynthetic cap? What evidence exists demonstrating that the physical integrity of the “cap” can be maintained indefinitely, that deterioration of the “cap” will not occur, and soil volatile compounds (VOC’s) will not collect in above ground structures prior to the completion of site remediation?

8. Will EPA make available methods, analysis and conclusions of soil and ground tests performed in the vicinity of the “recreational open space”(ROS) and private residences including a tracking (graphing) of historical concentrations of all contaminants and a written assurance that tracking (graphing) of these compounds will continue in the future? To which rules and procedures should affected property owners refer in order to ascertain whether they would qualify for government real property buyouts?

9. Which specific records were examined to determine that no Principal Responsible Party (PRP) exists for the Havertown Superfund site; is that tabulation available for review? In order to counter the perception that a less aggressive remedial action was selected for the Havertown Superfund site solely because no PRP was identified, can the EPA identify instances when less aggressive remedial action such as “capping” was pursued when a Principal Responsible Party was identified?

Havertown PA Superfund15 Jul 2008 04:59 pm

Two environmental studies were produced by a Massachussets environmental firm as Phase I and then  Phase II Environmental Audit.  A Phase I Environmental Audit is review of existing documentation about the site, a site visit, and an attempt to draw conclusions regarding whether the site is contaminated.  In the case of the Philadelphia Chewing Gum factory site, the results indicated that the entire site is contamination from contaminated groundwater flow from the former National Wood Preserver site on Eagle Road.  The conclusion is that a Phase II Environmental Audit is warranted; this was undertaken with test borings and emplacement of monitoring wells on the property. Apparently, a condition imposed by EPA required the monitoring wells to be closed at the end of the study.  The Phase II Environmental Audit concluded that the entire site was measurably contaminated with the admonition that unspecified remedial measures be taken before the site is reused.  I know of no permanent measures to prevent contaminated groundwater from producing volatiles that would collect in enclosed spaces such as buildings that may be constructed on the site in the future.

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Airspace Redesign14 Jul 2008 08:42 pm

On June 11, 2008 a letter was forwarded to Mayor Michael Nutter by our congressman indicating that Philadelphia International Airport (PHL) has a Noise Compatibility Program (NCP) dated 2003 currently in effect approved by the Federal Aviation Administration (FAA) pursuant to FAA Regulation 150; a new one was to be finished his year, but seems to be on hold. PHL is owned and operated by the City of Philadelphia. 

The program is not in compliance primarily as a result of FAA’s airspace redesign mitigated headings that were rushed into effect on December 19, 2007 rather than the summer of 2008.  When fully implemented, thousands of people in Delaware County communities and southeastern Chester County would experience noise levels of 65 DNL dB.  Swarthmore and Media, for example, would be subject to these noise levels by 2011.  In Haverford, North-South Runway 17-35 extension, nears completion, with traffic flows in airspace over our heads that will be authorized for that runway; hopefully PHL will continue to comply with the NCP, however, this is by no means certain. Delaware County overflights occur on a regular basis during nighttime hours, up to 4am. Runway 17-35 with approach or departure over Haverford is perpendicular to East-West Runways 9-27.  While simultaneous use of  perpendicular runways can increase the number of planes an airport can handle in an hour, air traffic controllers (ATC) have said the procedure is not safe. There were two close calls, planes coming within about half-mile and 300 - 600 feet in altitude of each other, during the last week at JFK due to one plane aborting a landing and going around and the simultaneous use of perpendicular runways on a departure.

Currently, there is no relevant noise monitoring, just modeled data about noise impacts. 
Twelve lawsuits have been filed against FAA and have been consolidated in the U.S. Court of Appeals — Washington, D.C. Circuit, asking review of FAA’s Record of  Decision (ROD) for Runway 17-35 extension and airspace redesign at PHL; issues are now being teased out of each..

While noise is one of the issues in PHL’s failure to comply with its NCP there are other issues that need to be carefully considered; these include, adverse health impact, safety risks, air quality.  A noise workshop was not held in the area to be primarily affected by runway 17-35 airspace redesign.  Delaware County seeks only to influence legislators and will not undertake to measure either noise or air quality in either a baseline or continuing study.   

Recruiting and training air traffic controllers by FAA is a problem encountered now with  the present crop of ATC’s retiring primarily as a result of the firing of ATC’s under the Reagan administration.  The New York Post today reported that a 20-year old was recently recruited. 

At present, FAA’s attitude toward it’s three “masters,” - commercial air transport, the flying public and the impacted public on the ground is questionable primarily due to what has been expressed by others as incomplete or just plain bad planning, politics, influences of the airline industry and selected incompetences within FAA,  http://ejectsturgell.blogspot.com.JL1408BC.AIR