Hamilton County General Health District December 12, 2011: Fill & Download for Free

The Gist:The overall criticisms of theprogram are its inefficiency, inaccuracy, and monetary cost.The inaccuracy claim comeslargely from the fact that risk assessments are subjective, and therefore biased.Scientists use bioassays, which often give conservative estimates ofenvironmental risk. They also use epidemiology, an assay that makes it hard tolink observed risk with cause.[1]One of the biggest controversiesof the program is the liability issue. The EPA states that if negligent andfault is found on the part of the defendant, that they are strictly held to thefunds of cleaning up the site; however, many worry that it actually tax dollarspaying for the doings of these highly profitable companies. One of the uniqueproperties of the Superfund is that companies that dumped waste even before theSuperfund program can be counted for liability. Each of the polluters can beliable for the cost to clean up the entire site.The next controversy of theprogram is that it is inefficient. Critics claim that there are often delays incleaning up the sites, that there are administrative deficiencies, and thatthere are high transaction costs that are ultimately paid for by the EPA andnot the responsible parties. In 2010 alone, the program conducted 261 five-yearreviews, amended 24 cleanup plans, and issued 59 explanations of significantdifferences at 53 sites.[2]All of these actions, while important to the documentation of the program, takeaway from funds allocated to the actual remediation process.Refutations of the inefficiencyclaim state that the program did not really get off the ground until 1987. Ingeneral, critics tend to focus on the number of sites cleaned up (or not),however, it is really the decrease in health risk that should be emphasized.This focus on number of sites gives the EPA incentive to fix the easiest sitesrather than to take action where the money would have the biggest impact.[3]Still others claim that theSuperfund process is inherently unfair. The superfund cannot equitably fix the fact that some populations aremore exposed to the toxic substances more than others. Although most wouldassume that it is poorer parts of the nation that are impacted more, Superfundsites are actually found more often in wealthier towns. This may have to dowith the fact that industry was settled and made great financial profit for thetown and its workers while simultaneously polluting the area. In areas ofhigher median income, on average it takes more time between the proposal andfinal NPL status. Also, sites are less likely to have removal actions and areassociated with larger planned cleanup obligations.[4]Impacts of the Toxic ReleaseInventory were also felt. It took time and resources for companies to make thereports, and cost them money to change their chemicals. It took governmentresources to make the data public (which was difficult because of technologyavailable at the time). Furthermore, the accuracy of the data was still inquestion since companies were self-reporting. In addition, housing prices inneighborhoods near the plants dropped, effecting homeowners and the housingmarkets of the microcosm economies.[5]There are many shortcomings ofthe program that have to do with the bureaucracy of government. The term “dump-stumping”has been coined to describe when politicians visit a site just to criticize theSuperfund program and get PR. Initially, when the Superfund program wassupported by Republicans, Democrats criticized. The opposite is now true asdemocrats are more likely to support the EPA and its funding than republicans.[6]Nonetheless, there were stillclear benefits of the TRI program. It ultimately led to a change in chemicaluse to those that were less toxic and that stakeholders approved of more. It helpedreporters, journalists, activists, and environmental lobbyists delve deeper andmake more accurate claims. It also lead to the phasing out of ozone depletingchemicals also known as CFCs (Chlorofluorocarbons), which had a significantimpact on the “ozone hole”. Thirty-three out of fifty participants in theprogram voluntarily reduced their levels of pollution.[7]Many see the Superfund as a wayto make companies “internalize externalities”.[8]As pollution data goes public, companies reduce their more dangerouspollutants, especially in areas of greater voter turnout. However, pound ofpollution is a bad way to quantify success because different chemicals havedifferent effects. This is something that the general public is usuallyuninformed about and goes unnoticed.[9]The Final Paper:In2011, Forbes rated the Philadelphia area as the most toxic in the United Statesbecause of its concentrations of highly contaminated Superfund sites.[1]However, as Philadelphia Inquirer reporter Anthony Wood said, “MostPhiladelphians wouldn’t know the Superfund from the Super Bowl.”[2]Most Superfund sites look as plain as a gated lot with a small sign indicatingcontamination and risk. Although scarcely known, the Superfund is extremelyrelevant to the Philadelphia area and residents should become informed in orderto ensure the safety of their communities.Inthe summer of 1978, toxic chemicals turned up in basements and yards near LoveCanal, New York. It was soon discovered that the Hooker Chemical Company hadfilled an abandoned site with over 21,000 tons of chemical waste. Hookercovered the site with earth and clay and sold it to the Niagara Falls Board ofEducation for one dollar. Schools and a playground were then built on the siteand a residential community developed in the neighborhood.[3]In1986, two sites per each congressional district were put on the NationalPriorities List to start off the program. CERCLIS, the ComprehensiveEnvironmental Response, Compensation, and Liability Information System, asuperfund tracking database, was created to follow their progress. However, insome districts there were over 50 sites that did not qualify for the program,despite their toxicity.[4]OnDecember 2, 1984, there was a leak at the Union Carbide Plant in Bhopal, Indiathat killed over 20,000 workers and residents. Union Carbide was an Americancompany under the Dow Corporation that had slipped in equipment maintenance anddrastically reduced training time for workers to cut costs. Senior managersnever checked to see if the plant was following safety protocol. In addition,residents were not educated on an emergency situation plan. They accidentally ran in the directionof the wind, increasing their exposure and were also unaware that simplycovering their faces with a wet cloth could have helped immensely. Outragebroke out immediately from both Americans and Indians. Americans were not onlyupset about the needless loss of life but also feared something similarhappening closer to home.[5]This sparked subcommittees and action within the United States’ government. Theoutcome was a bill known as EPCRA, the Emergency Planning and Right to KnowAct. EPCRA is Title III of the Superfund Amendments and Reauthorization Act(SARA), which was created in 1986.[6]EPCRA showed that citizens had the right to know the chemicals being used bycompanies near them. This led to the Toxic Release Inventory (TRI), in whichall companies are required to divulge all information about the chemicals theyuse.[7]The State Emergency Response Commission (SERC) was created on a state level tokeep citizens safe and respond to the information provided in the TRI.[8]Republicanand Democratic support for the EPA and the Superfund has gone in waves.Initially, it was Republicans that championed the program and more funding forthe EPA, but by the late 1980s, the political polarity had reversed. From1989-1992, during the first Bush administration, environmentalists tried toexpand EPCRA through legislation, without much success. During the proceedingClinton administration, however, the EPA increased the number of chemicals andindustries that had to report to the TRI. Industry officials took everypossible measure to get out of this, and the subsequent Bush administrationtook input from stakeholders, who believed that companies were losing profitsdue to the regulations, and limited the companies’ burden of reporting.[9]Data was first released in 1989, and was reported on by journalists andreporters. On average, the release led to negative returns on the day’s stockprice by an average of $4.1 million.[10]Throughout the second Bush administration, the project faced gradual budgetcuts, which reduced enforcement and effectiveness.[11]The subsequent Edgar Amendment required facilities to report releases andtransfers of chemicals with acute and chromic effects. This caused a decreasein pollution because the costs of reporting and the public scrutiny thatfollowed were high.[12] In thecurrent political atmosphere, Republicans argue that the budget for the EPA istoo large and that the EPA stifles companies from free production and,therefore, harms the economy. Democrats see the EPA as necessary to protect ourcountry for pollution.TheSuperfund process has many multistage steps. The first part of the process isidentifying a contaminated site. From there, the identifiers determine if itwould be a good candidate for Superfund funding. The next step is the extensiveapplication process. Ifpreliminary assessment reveals that the site is significantly contaminated, it willbe listed on National Priorities List (NPL) and ranked according to the HazardRanking System (HRS), a key part of the EPA’s system. Next are remedial investigation and a feasibility study,remedial design, construction, NPL deletion, and finally site reuse. Manyexperts are part of each of these steps. The Remedial Project Manager overseesthe entire project and works with specialists and attorneys to find potentiallyresponsible parties. Hydrogeologists, work on the soil and water contaminationissues to make sure that they are contained as much as possible. Civilengineers locate potentially responsible parties for liability litigation. The Centerfor Disease Control (CDC) works to make sure that public health issues are keptunder control. Toxicologists and biologists assess and minimize the harm doneto nature. The Community Involvement Coordinator has one of the biggest roles –bridging the communication barrier between the public and the experts. Throughout,detailed records of decisions are kept and can be viewed by the public on theEPA’s website.Thereare debates on how the Superfund should be funded; however, most agree that itshould be funded with taxes on industry and directly by the companies thatcaused the damage. Originally in 1980, funding for the Superfund program was$1.6 billion, however, the amendments made in 1985 cut its funds.[13]The Downey Amendment created a $10 billion taxes on polluters, $3.1 billion onpetroleum, $2.1 billion on chemicals, $2 billion on hazardous waste disposal,and $1.6 billion in general revenues.TheSuperfund’s budget currently comes from a variety of sources including theRecovery Act, responsible parties, and state cost-share contributions. In thefiscal year 2010 report, the Superfund “obligated $443 million in appropriatedfunds, state cost-share contributions, and potentially responsible parties…”for construction on Superfund sites. Three of the 18 sites that completed theconstruction phase in 2010 received money from the American Recovery andReinvestment Act of 2009[14],the act signed by President Obama in an attempt to fix the economic crisis,create jobs, and spur the economy. It is a fund that has a total of $787 billion.[15]Allocation of Superfund resources is determined by a high HRS score and lengthof time on the NPL. In addition, state prioritization, non-federal sites, andfederal fund-lead sites have automatic priority.[16]Costs / Benefits of Superfund: Theoverall criticisms of the program are its inefficiency, inaccuracy, and inequity.Criticsclaim that the process is inefficient because delays in cleaning up the sites,administrative deficiencies, and high transaction costs that are ultimatelypaid for by the EPA and not the responsible parties. In 2010 alone, the programconducted 261 five-year reviews, amended 24 cleanup plans, and issued 59explanations of significant differences at 53 sites.[17]All of these actions, while important to the documentation of the program, takeaway from funds allocated to the actual remediation process. One of the root causes of theinefficiency stems from the intensely bureaucratic government. The term “dump-stumping”has been coined to describe when politicians visit a site solely to criticizethe Superfund program and get PR. Initially, when the Superfund program wassupported by Republicans, Democrats criticized it. The opposite is now true asdemocrats are more likely to support the EPA and its funding than republicans.[18]Refutationsof the inefficiency claim state that the program did not really get off theground until 1987, which can explain deficiencies in the number of totalSuperfund sites remediated. In general, critics tend to focus on the number ofsites cleaned up (or not), however, it is really the decrease in health riskthat should be emphasized. This focus on number of sites gives the EPAincentive to fix the easiest sites rather than to take action where the moneywould have the biggest impact.[19]Theinaccuracy claim comes largely from the fact that the inventories areself-reported by the companies, which have a negative incentive in the directand indirect financial burdens.. In addition, risk assessments are subjective,and therefore biased. Scientists use bioassays, which often give conservativeestimates of environmental risk. They also use epidemiology, an assay thatmakes it hard to link observed risk with cause.[20]Nonetheless,there were still clear benefits of the TRI program. It ultimately led to achange in chemical use to those that were less toxic, largely because ofstakeholder pressure. It helped reporters, journalists, activists, andenvironmental lobbyists delve deeper and make more accurate claims. It alsolead to the phasing out of CFCs (Chlorofluorocarbons), an ozone depletingchemical that was the main cause of the “ozone hole.” The remediation of thishole was one of the greatest environmental successes of the 20thcentury. Thirty-three out of fifty participants in the program voluntarilyreduced their levels of pollution.[21]Manysee the Superfund as a way to make companies “internalize externalities”.[22]As pollution data goes public, companies reduce their more dangerouspollutants, especially in areas of greater voter turnout. However, pound ofpollution is an inaccurate way to quantify success because chemicals have awide range and intensity effects. This is something that the general public isusually uninformed about.[23]Impactsof the Toxic Release Inventory were also felt. It took time and resources forcompanies to make the reports, and cost them money to change their chemicals.It took government resources to make the data public (which was difficultbecause of technology available at the time). Furthermore, the accuracy of thedata was still in question since companies were self-reporting. In addition,housing prices in neighborhoods near the plants dropped, effecting homeownersand the housing markets of the microcosm economies.[24] Effects of the project are felt allaround, and the question ultimately becomes – is the Superfund worth it?Stillothers claim that the Superfund process is inherently unfair. The superfund cannot equitably fix thefact that some populations are more exposed to the toxic substances thanothers. Although most would assume that this refers to poorer parts of the nation,Superfund sites are actually found more often in wealthier towns. This may haveto do with the fact that industry was settled and made great financial profitfor the town and its workers while simultaneously polluting the area. It couldpotentially also be contributed to the fact that wealthier areas tend to spendmore money looking for contaminated sites and are more proactive in pushing forSuperfund status. In areas ofhigher median income, on average it takes more time between the proposal and finalNPL status. Also, sites are less likely to have removal actions and areassociated with larger planned cleanup obligations.[25] This may also be attributed togreater citizen involvement.Oneof the biggest controversies of the program is the liability issue. The EPAstates that if negligent and fault is found on the part of the defendant, theyare strictly held to the funds of cleaning up the site; however, many worrythat it actually tax dollars paying for the doings of these highly profitablecompanies. One of the unique properties of the Superfund is that companies canbe found liable even for actions that took place before the Superfund wascreated. Each of the polluters can be liable for the cost to clean up theentire site.The Superfund’s performance measures including the following:· Government Performance and Results Act (GPRA)· Sitewide Ready for Anticipated Use (SWRAU)· Human Exposure Under Control (HEUC)· Groundwater Migration Under Control (GMUC)· Final Assessment Decision (FAD)· Construction Completed (CC)· EPA Strategic Plan[26]The latestSuperfund accomplishments report was issued after the fiscal year 2010 andshows a long list of the programs successes. In 2010, the Superfund reducedhuman exposure to harmful chemicals at 18 sites, exceeding the annual goal,which was set at ten, and mitigated contaminated ground water by 18 as well,surpassing the annual goal of 15. They claim that this brings the total numberof significantly remediated Superfund sites to 1,338! It is estimate that 1.3million acres of land have been remediated to the point of safety to people andthat over 455,800 acres are ready for use. The construction phase was finished at18 sites, bringing the total for that to 1,098, or 67.5% of all NPL sites. Bythe end of 2010, there were 1,627 final and deleted sites.[27]On the other side of the spectrum, the Superfund is a continuing andever-growing process. In 2010, 20 new sites were added to the NPL. There are also many contaminated sitesthat are not listed and more that have yet to be discovered.There are forty Superfund sites listed in the city of Philadelphia, andmany more in the greater Philadelphia area. Philadelphia was rated the mosttoxic urban area by Forbes magazine in 2011[28]and was on the bottom of Sperling’s water rating list with a score of just 13%.[29] Many of the superfund sites in the Philadelphia area areformer landfills that did not have proper containment and liner systems. Somesignificant sites include the Bridgeport Rental and Oil Services, which was listedin 1984 and is currently in the final fazes; the Ryeland Road Arsenic, a sitelisted in 2004 at which ferns were used for bioremediation; and the VinelandChemical Company, Inc., which was funded by the Recovery Act. The PalmertonZinc Superfund Site[30] is one ofthe relative success stories of the Philadelphia area. The area in CarbonCounty, PA along the Appalachian Trail at the top of Blue Mountain wasre-vegetated and is on track to return to its natural habitat.TheEast Tenth Street superfund site is a 36-acre plot in an industrialized area ofMarcus Hook, PA, which was proposed to the NPL in January of 1994. The site wentthrough multiple stages of ownership starting in 1910 when the American ViscoseCompany produced Rayon and then switched to cellophane in 1958. From 1963-1977,the FMC Corporation produced cellophane as well and then handed a parcel of theland over to Envirosafe Services. The parcel was then purchased by the Marcus Hook Processing Inc., a subsidiaryof Envirosafe. This 4.25 acres of contaminated land has now gone throughmultiple environmental assessments. One of them, conducted by the PennsylvaniaDepartment of Environmental Resources (PADER), found employees excavating anunderground solvent storage tank farm that consisted of thirty tanks anddisposing of the contents on the bare soil of the site.A 1990 investigation showed tanks, leaking transformers, and asbestos withinand outside of the site’s buildings. In 1990, an EPA evaluation revealedasbestos, PCBs, and other hazardous materials that had been mishandled duringthe demolition. They also discovered a sludge filled tunnel on one of the lots.The soil contains PCBs, asbestos, heavy metals, and other organic contaminants,the sludge filled tunnel contains chloroform, cadmium, and mercury, andsediments in the creek contain PCBs. The EPA website concludes that “Touchingor ingesting contaminated groundwater, soils, surface water, or sediments posesa health risk.”[31] Despite thefact that the site is located next to the Marcus Hook Creek, a state-designatedarea for the protection of aquatic life, the site is still not listed on theNPL and hardly any remediation has been done. This site represents a failure ofthe Superfund program. Attempts to talk to the EPA site’s listed CommunityInvolvement Coordinator failed and other sources told me that it was notpossible to receive any further information on the site.Onthe other end of the spectrum, the most recent NPL listings is the former MetroContainer Corporation in Trainer, Delaware County, which was added on March 13,2012. The site has a lagoon that was used for industrial purposes for severaldecades by multiple companies. The property is now owned by an industrialpainting company, Trainer Industries, which uses it for storage[32].It has been an industrial site since the19th century. From 1920 to1959, the site was used as a chemical manufacturing plant by Stauffer ChemicalCompany. In 1991, owners of theMetro Container Corporation, a steel drum reconditioning plant, pled guilty tocharges that they had dumped hazardous waste and discharged contaminated waterinto Stoney Creek.[33] However,Metro had filed for bankruptcy in 1987, so liability funding for the site iscomplicated. The unlined lagoonwas filled with soil and artificial fill materials, which did nothing toprotect the surrounding area from contamination. The soils are now contaminatedwith PCBs, inorganics, PAHs (Polyaromatic hydrocarbons), and VOCs (volatileorganic compounds). Assessment reveals that there is potential to contaminatethe tidal flats of the Delaware and the river itself.AlexMendell, the Community Involvement Coordinator for the Metro ContainerCorporation Superfund site in Trainer described himself as the liaison betweenthe scientists and community members, a translator of sorts between thetechnical and laymen terms. He finds his job “rewarding, although oftendifficult because I does my best to remain transparent to the communitymembers.” When asked whether there was a community push to put the site on theNPL, he responded, “The public is always a part of the process – we visited thesite a number of times and communicated with members of the community duringthe proposal.” He emphasized the value of one-on-one communication and wentdoor to door to talk with as many residents as possible. In Trainer, the mayorlives right in the community, which, Mendell says, made communication easier.He made fact sheets and hosted open houses. They also use a CIP – CommunityInvolvement Plan, a comprehensive plan that highlights questions about bettercommunicating information to the community. His thoughts on efficiency includedthe importance of social media and learning how to better engage with it in thefuture. Overall, Mendell has seenthat the public is relatively aware of the project’s details, the site, and theremediation plan – thanks in most part his own outreach efforts.[34]Oneof the best measures of success is the public perception of the program,especially since the Superfund was born from public discontent with governmentresponse to hazardous materials. The Joel Best sociological model of framing separates a topicinto four main components: experts, activists, media, and politicians, and thenanalyzes the issue from each of these angles. All four of these then influence the general publicperception of the issue. Experts believe that the Superfund is a thoroughprocess. Activists generally believe that it is too slow, however, this isinherent in the role of activists, because people only stand up when they feelsomething is wrong. The media hardly gives the Superfund any attention becauseit is such a slow moving issue. When there is a dramatic change or if theactivists make a big enough splash to garner some attention it is generallycovered with a negative tilt. Asfar as politicians, currently democrats are in favor of the EPA, andextrapolating would be in favor the Superfund, while republicans are againstit, saying that it hurts business and that the EPA is overfunded. These fourperspectives reveal the two common sentiments of the general public – ignoranceand negativity.Inan interview with “Chris,” a responder for the Superfund General InformationHotline, they receive a “decent number of calls from citizens, who are motoften looking for information on sites in their community.” When asked aboutthe average level of knowledge possessed by callers, her responded that“Education varies, some have done a significant amount of research and want toget involved, and others have just found out that there is a site in theircommunity and are curious to learn more.” However, he also mentioned that thehotline does not have any additional information from what is on the extensivepublic EPA Superfund branch of their website. He did also indicate that,despite this fact, the hotline is efficient because many citizens do not knowhow to navigate the website and it is a useful venting location for people whoare frustrated and want to complain.[35]There is no formal tracking devise for complaints, so the public may see thehotline as a waste of taxpayer dollars.Thenext interview was conducted with “Dawn,” a librarian for the Superfundprogram. She was willing to share her personal opinion on the Superfund. Hermain points were that funding is not always available and that many sitesinvolve significant controversy stemming from residents skepticism ofremediation’s interference and the slow speed of the program. She stresses thateach site is different: often funding is not available and communities vary intheir involvement. There is also significant difference between federal sitesand those that are privately owned.Overall,the documentation of the Superfund Program, and the incredible about of detailavailable to the public, is remarkable. The website and hotlines keep theprocess as transparent as possible – a major feat for a government-run program.However, there are several components that could be made more efficient.Streamlining of the litigation and liability process, while difficult, wouldsave a significant amount of money and time. In addition, the national generalhotline is likely repetitive and a waste of resources. Overall the program issuccessful at doing what it was set up to do – remediate sites – however, thisdoes not solve the ever-growing problem of industrial contamination. Stricterregulations must be put on companies to prevent further damage to the UnitedStates. A major coup of industrial lobbyists in Washington is absolutelycrucial to making sure that the Superfund is a success. The Superfund is worthit, but it should not be paid for by American tax dollars. Public sentiment isgenerally negative because news stories generally only focus on this angle, butmost community involvement is more positive.Bibliography / Works CitedAssociated Press. "EPA Approves Philly-area Plant forSuperfund List." York Dispatch. Media News Group, 13 Mar. 2012.Web. 17 Apr. 2012.<http://www.yorkdispatch.com/penn/ci_20163802/epa-approves-philly-area-plant-superfund-list>.Barnett, Harold C. Toxic Debts and the Superfund Dilemma.Chapel Hill: University of North Carolina, 1994. Print."East Tenth Street." EPA. EnvironmentalProtection Agency, Jan. 2008. Web. 2 Mar. 2012.<http://www.epa.gov/reg3hscd/npl/PAD987323458.htm>."Bhopal: India Wants Compensation Doubled." BBCNews. BBC, 3 Dec. 2012. Web. 5 Mar. 2012.<http://www.bbc.co.uk/news/world-south-asia-11911828>.Hamilton, James. Regulation through Revelation: TheOrigin, Politics, and Impacts of the Toxics Release Inventory Program.Cambridge: Cambridge UP, 2005. Print.Hird, John A. Superfund: The Political Economy ofEnvironmental Risk. Baltimore: Johns Hopkins UP, 1994. Print.Revesz, Richard L., and Richard B. Stewart. AnalyzingSuperfund: Economics, Science, and Law. Washington, DC: Resources for theFuture, 1995. Print.Seneca, Roy. "Advanced Search." AerialRe-vegetation Resumes on Appalachian Trail Portion. United StatesEnvironmental Protection Agency, 12 Mar. 2012. Web. 1 Apr. 2012.<http://yosemite.epa.gov/opa/admpress.nsf/e51aa292bac25b0b85257359003d925f/76b8839afee7b85a852579c2005eaf8e!OpenDocument>.United States. Environmental Protection Agency. Office ofSolid Waste and Emergency Response (OSWER). Superfund NationalAccomplishments Summary Fiscal Year 2010. Environmental Protection Agency,2011. Web. 5 Apr. 2012. <http://www.epa.gov/superfund/accomp/numbers10.htm>.United States. Washington State Department of Ecology. WhatIs the Emergency Planning & Community Right-to-Know Act (EPCRA)? AccessWashington. Web. 1 Mar. 2012. <http://www.ecy.wa.gov/epcra/whatis.html>.Wood, Anthony R. "Trainer Site Makes EPA SuperfundList; Who Pays?" Philly.com. Philadelphia Inquirer, 13 Mar. 2012.Web. 13 Mar. 2012.<http://articles.philly.com/2012-03-13/news/31160150_1_epa-superfund-list-federal-cleanup-industrial-history>.[1] Brennan,Morgan. "America's 10 Most Toxic Cities." Forbes. ForbesMagazine, 2 Feb. 2011. Web. 20 Feb. 2012.<http://www.forbes.com/2011/02/28/most-toxic-cities-personal-finance.html>.[2] Wood, A.(2012, April 11). Email interview.[3] Hamilton,James. Regulation through Revelation: The Origin, Politics, and Impacts ofthe Toxics Release Inventory Program. (Cambridge: Cambridge UP, 2005), 16.[4] Hamilton,18.[5] "Bhopal: India WantsCompensation Doubled." BBC News. BBC (3 Dec. 2012) <http://www.bbc.co.uk/news/world-south-asia-11911828>.[6] UnitedStates. Washington State Department of Ecology. What Is the EmergencyPlanning & Community Right-to-Know Act (EPCRA)? Access Washington.<http://www.ecy.wa.gov/epcra/whatis.html>.[7] Hamilton, 10[8] UnitedStates. Washington State Department of Ecology. What Is the EmergencyPlanning & Community Right-to-Know Act (EPCRA)? Access Washington.<http://www.ecy.wa.gov/epcra/whatis.html>.[9] Hamilton, 176[10] Hamilton, 73[11] Hamilton, 176[12] Hamilton, 17[13] Hird, 14[14]http://www.recovery.gov/About/Pages/The_Act.aspx[15]http://www.epa.gov/superfund/accomp/numbers10.htm[16] Hird,John A. Superfund: The Political Economy of Environmental Risk.(Baltimore: Johns Hopkins UP, 1994), 138.[17]http://www.epa.gov/superfund/accomp/numbers10.htm[18] Hird, 31[19] Hird, 31[20] Hird, 56[21] Hamilton, 241[22] Hamilton, 114[23] Hamilton, 114[24] Hamilton, 241[25] Hird, 138[26] UnitedStates. Environmental Protection Agency. Office of Solid Waste and EmergencyResponse (OSWER). Superfund National Accomplishments Summary Fiscal Year2010. Environmental Protection Agency, 2011. Web.<http://www.epa.gov/superfund/accomp/numbers10.htm>.[27] UnitedStates. Environmental Protection Agency. Office of Solid Waste and EmergencyResponse (OSWER). Superfund National Accomplishments Summary Fiscal Year2010. Environmental Protection Agency, 2011. Web.<http://www.epa.gov/superfund/accomp/numbers10.htm>.[28] Brennan,Morgan. "America's 10 Most Toxic Cities." Forbes. ForbesMagazine, 2 Feb. 2011. Web. 20 Feb. 2012.<http://www.forbes.com/2011/02/28/most-toxic-cities-personal-finance.html>.[29] "Sperling'sBest Places to Live." Best Places to Live. Web. 5 Apr. 2012.<http://www.bestplaces.net/>.[30]Seneca,Roy. Aerial Re-vegetation Resumes on Appalachian Trail Portion,<http://yosemite.epa.gov/opa/admpress.nsf/e51aa292bac25b0b85257359003d925f/76b8839afee7b85a852579c2005eaf8e!OpenDocument>(12 Mar. 2012).[31] "EastTenth Street." EPA. Environmental Protection Agency, (Jan. 2008)<http://www.epa.gov/reg3hscd/npl/PAD987323458.htm>.[32] AssociatedPress. "EPA Approves Philly-area Plant for Superfund List." YorkDispatch. Media News Group, (13 Mar. 2012)<http://www.yorkdispatch.com/penn/ci_20163802/epa-approves-philly-area-plant-superfund-list>.[33] Wood,Anthony R. "Trainer Site Makes EPA Superfund List; Who Pays?" Philly.com.Philadelphia Inquirer, (13 Mar. 2012)<http://articles.philly.com/2012-03-13/news/31160150_1_epa-superfund-list-federal-cleanup-industrial-history>.[34] "Alex Mendell." Telephone interview. 13 Apr. 2012.[35] “Chris onthe Superfund Hotline”