Environmental Research Associates

Research & Consulting Ecologists

August 2008

Havertown PA Superfund09 Aug 2008 05:14 pm

Associate Administrator for Congressional and Intergovernmental Relations
Environmental Protection Agency
1200 Pennsylvania Avenue, NW, Room 3426 ARN
Washington, DC 20460-0001

Dear Mr. Bliley,
To help address the concerns of my constituents, please review and provide written responses to the following questions regarding the Havertown Superfund site. If you have any additional questions, please contact Jason Marmon in my District Office at (610) 892-8623 or Jason.Marmon@mail.house.gov.

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 concentration 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 slurrry 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?

Joe Sestak
Member of Congress
Cc: Ms. Megan Mackey, Pennsylvania State and Congressional Liaison Officer US EPA

Deer09 Aug 2008 05:10 pm

by Michael H. Levin, Ph.D

Introduction. I attended a meeting in the fall of 2007, emailed on short notice of less than 8-hours - with an agenda - by State Representative Greg Vitali, of the ad hoc Haverford State Citizen’s Advisory Committee chaired by Jan Marie Rushforth.   Others present at the meeting included: Peter Hickman, Diane D’Amico, Jane Hall, Lucetta Alderfer, Mike Levitsky, Larry Abel, Bob Stump and myself.  I doubt whether more than two men at the meeting had ever hunted or been faced with the daunting prospect of field-dressing (i.e., slitting the abdomen from stem to stern and removing the digestive tract, liver, bladder and heart and lungs as intactly as possible) from a large bloody dead ungulate game animal like a deer and dragging all of it out of the woods. Then, work to butcher it only begins; deer meat is dry and strangely greasy; it is marginally edible, cooks fast like most wild game, with a generous dose of sweetened hunter’s fruit sauce laced with brandy. Some, on the other hand, would have a personal preference for a piece of aged beef that could be presented without the hunter’s sauce.     

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Deer08 Aug 2008 02:50 pm

by Michael H. Levin, Ph.D.

With the tabling of an agenda item after a voice vote and subsequent buck-passing to the elected state representative for help completing a deer management report that the state requires, mainly  a count or inventory of the deer within an area, local commissioners (6:3) sidestepped voting for a deer kill in the area where preservation has been dominant for over 40 years.  One wildly speculative estimate blurted out the deer population is “a hundred;” where another stated there should be “just six.”  The area is a combination of forest, meadow and riparian land; a deer population of 100, or a little better than 1 deer/acre couldn’t be sustained on 129 acres and have much quality vegetation left; an “infestation” like this couldn’t exist because any animal population requires at least there very basic ingredients to maintain itself; food, space and a place in which to live. If any of these is missing or in short supply, the population rises to a sustainable level and no more then stabilizes and gradually declines; a combination of these forces would lead to an inevitable deer population reduction or crash and may random walk to extinction if and when fawn birth rate declines.  

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