A History of The TCE, Superfund Site

From 1947 - 1991 National Wood Preservers (NWP) operated a wood preservation facility at a site east of the gum factory site that Haverford acquired by condemnation through Eminent Domain. About nine (9) different chemical compounds were mixed with diesel oil and impregnated into wood in a pressurized charge vessel.

The preservatives themselves, as well as diesel oil, spread onto the soil and settled into the ground water beneath the site then flowing generally east with groundwater toward West Chester Pike in the valley of Naylor’s Run beneath about 77 houses in the vicinity of Rittenhouse Circle.

Haverford applied for status, which resulted in listing on the National Priority List (NPL) in the early 1980's and the site was accepted by the Environment Protection Agency (EPA) in 1983; after that and to this day it is a federalized Superfund Site known as the Havertown PCP Site (NPL 542). This site extends to all areas where wood preserver contamination is found.

The site receives the benefits of clean-up with federal funds, provided it has chemical compounds associated with wood preservation. One of the hazardous chemicals (there are others) associated with this site is naphthalene which can off-gas into the air particularly in buildings to cause diseases such as hemolytic anemia and cancer. Today, the site is not completely remedied of wood preserver contaminany compounds.

Now — nearly three decades — after the EPA began remedying the Havertown PCP Site, another site has slowly come into existence conterminously with the PCP Site at the very nearly the exact same location, only this site has not yet been approved, nor even nominated, as a Superfund Site but is known as the TCE Havertown Site for another principal chemical component, trichloroethylene, another volatile industrial solvent that EPA has known was present for decades, but didn’t mention and kept very quiet about until recently as the agency prepares to hand-off the entire Superfund Site to the Pennsylvania Department of Environmental Protection for management. TCE produces its own health effects; breathing it in building air can cause lung, kidney and liver damage and it could cause cancer.

Naphthalene from diesel oil has a low time-weighted average (TWA) level in air of 10 p.m. and a Action Level of half-that or 5 ppm. while trichloroethylene has a TWA level in air of 50 ppm or an Action Level of 25ppm.

At the federalized Haverstown PCP site, EPA recently disclaimed responsibility for the presence of trichloroethylene which it states is not a wood preserver compound or for removing it from the water which carries it, although the agency will test for it beneath and in some houses above the Superfund Site. In the event it is found in air samples the Agency will supply a TCE vapor venting system, which operates similarly to a radon removal system, venting basement sub-slab gases before these enter the air within the house. Permanent maintenance and electrical operation of the system would be the homeowner’s responsibility.

So far, the EPA has not stated whether the Agency will test household air for naphthalene, wood preserver compounds or its constituents, or derivatives of the wood preserver compounds, which may become airborne vapors.

An Action Level for any chemical in household air is its very presence becaus Action Levels are designed for the workplace where an occupational exposure is the 8-hour workday not a period of up to 24-hours or a full day.

By disclaiming responsibility for TCE, or any other toxic chemical not associated with the wood preservation process at a site listed as a Superfund Site on the National Priority List, a homeowner who is emphatic about wanting to be relocated to a home which is free of unremedied contaminants at or below an Action Level without needing a remedy could not prevail in a claim for EPA to buy the property at fair market value and have EPA prepare listings of comparable priced properties for sale and also pay closing costs, title fees as well as cover moving expenses to another property. In other words, if it is not a Superfund Site, on the NPL, EPA will not even consider moving the owner.

Finally, for the leasee of a property who will build its enclosed facility upon a Superfund Site like the gum factory site, they too will come to occupy the site just like an existing home over contamination; this could find its way into the enclosed space, thereby creating — under worst case conditions — an unhealthful environment for those who use it as a community center or by ventilating untreated sub-surface vapors into the surrounding community, a condition not protective of public health.

Michael H. Levin, Ph.D.
www.EnvironResearchAssoc.com