NGWA submits comments on Superfund site deletion leaving groundwater unusable

February 1, 2021


NGWA submitted comments on a U.S. Environmental Protection Agency proposal to delete a Superfund site, North Penn-Area 6 in Pennsylvania, from the National Priorities List of hazardous waste sites.

NGWA’s Government Affairs Committee Review Group on EPA Superfund Site Deletion Practices sent the comments on January 28. It expressed concern about what it viewed as inadequate information and decision documentation of completed remedial actions that would leave groundwater contaminated by volatile organic compounds — including trichloroethylene (TCE) and perchloroethylene (PCE) — to be treated indefinitely and unusable.

The review group felt the documentation incorporated in the description of the deletion was superficial and did not appear to justify removing the site from the NPL. A significant concern of the review group is the deletion of sites with contaminated groundwater left in place and lost to future use to overlying or adjacent communities.

The review group comments to the EPA included the following items.

  • Deletion proposals should:
    • Transparently, comprehensively, and clearly communicate the data and analytic methodologies that served as the basis for decisions to delete sites
    • Incorporate summary data and statistics to inform the public regarding actions affecting deleted sites in the present and future
    • Include the schedule adopted to accomplish groundwater treatment and monitoring at the sites
  • The EPA should review its internal protocols and quality assurance processes for reporting on proposed site deletion.

The review group has reviewed 20 Superfund sites already, or proposed to be, deleted to prepare for a discussion with the EPA on its site deletion practices. The group’s goal is to promote that remedial actions should have groundwater sufficiently safe at sites for future community and business use.

Review the proposed deletion of the North Penn-Area 6 Site.

Read the full comments provided by NGWA to the EPA.