Soil Transportation & Disposal Services in Philadelphia’s Growing Real Estate Market

Recently the Greater Philadelphia real estate and construction markets have been increasing in five main areas: University City, Market East, the Navy Yard, Camden, and King of Prussia. Three out of these five markets are located within the city limits meaning that there is bound to be a whole lot of change coming to the City of Brotherly Love. Some of these changes will be apparent physically such as the Comcast Innovation and Technology Center which started construction just over a year ago. This building will surpass the current tallest skyscraper in the city, the Comcast Center. When completed the Comcast Innovation and Technology Center will be the tallest building in the United States outside of Chicago and New York City at 1,121 feet.

Although not a skyscraper, arguably the most prominent development will be in University City with the Schuylkill Yards project announced by Drexel University and Brandywine Realty Trust. This 14-acre, $3.5 billion investment will be the largest-scale project in Philadelphia’s history. The development will encompass an area next to Amtrak’s 30th Street Station and Brandywine’s Cira Centre towers on the west bank of the Schuylkill River. At the end of the predicted 15-20 year construction phase the area will be home to residential, retail, hotel, corporate, and research spaces.

However, no matter what is going into these projects one thing is sure to come out… soil. REPSG’s soil disposal services have seen strong demand over the last few years and we are prepared to keep the momentum going throughout the growth of our city. Located in Southwest Philadelphia our soil disposal services department provides comprehensive services for your disposal needs.

REPSG’s soil experts will help in every step of your transportation and disposal project. Our skilled technicians will start by sampling materials requiring export or disposal. These sample results will provide the information necessary to coordinate the applicable approvals needed to safely and legally dispose of the materials. REPSG will complete and submit all necessary paperwork to the proposed facilities in order to ensure acceptance and approval. Additionally, REPSG will coordinate and provide transportation for the proper disposal of the soil to the facility. Once the work is completed, REPSG will provide all disposal documentation.

REPSG provides the staff and support to sample and dispose of your soil in the most efficient and affordable means. We will work with your construction, demolition, or financing schedule to ensure your project stays on, or ahead of schedule. Your project may not be as large as those highlighted here but regardless of size, REPSG is here to help. We have provided transportation and disposal services to several redevelopment projects in the Greater Philadelphia Area including Pennsylvania, New Jersey, and Delaware. Our transportation and disposal department staff have expertise in all standards and regulations of your disposal needs. Contact us for more information by commenting below or contacting our office at (215) 729-3220 or info@repsg.com.

For more information on the Comcast Innovation and Technology Center please visit: http://corporate.comcast.com/media-center/citc-updates

For more information on the Schuylkill Yards project please visit: http://www.schuylkillyards.com/

Ted Mosher & James Romanchek, Council-certified Microbial Consultants

REPSG is happy to announce that Project Managers Ted Mosher and James Romanchek have received the certification of Council-certified Microbial Consultant (CMC) by the American Council for Accredited Certification.

This industry certification is one of the most prominent for mold consultants and inspectors. Ted and James will use their expertise to strengthen our mold abatement services. The presence of mold is a serious occupational health and safety issue as mold can have numerous effects on one’s health. Mold can be found anywhere that moisture is present. Spores are produced due to mold reproduction and are then released into the atmosphere. The inhalation of spores over time or of specific types can cause adverse health effects such as asthma, allergies, and respiratory issues. Our mold abatement service helps to decrease the risk of incurring mold related symptoms and concerns. Ted, James, and the rest of our Due Diligence staff have the proper experience and tools necessary to assess potentially hazardous samples.

In order to obtain this worldwide recognized accreditation one must have extensive training. Applicants must complete one of the following requirements: a Bachelor’s degree (or equivalent) in a related field of science with a minimum of four years of field experience that includes documented microbial sampling; a two-year degree (or equivalent) in a related field of science with at least six years of documented experience in microbial sampling; or no post-secondary degree (high school diploma or GED required) and at least eight years of microbial sampling consulting experience. In addition to one’s academic and field achievements one must also pass a rigorous exam that includes many areas of microbiology. The certification must also be renewed every two years with evidence that one has been continuing their education and performing relevant field work adding to at least forty hours within the two year span.

REPSG is here to help! If you feel it is necessary to perform mold abatement on your site please contact us by commenting below or submitting an information request via our Contact section.

For more information on CMC requirements please visit: http://www.acac.org/forms/applications/cmcdescription.pdf

For more information on molds, potential risks, and removal please visit: http://www.epa.gov/mold

Do New Vapor Rules in NJ Affect Your Project?

NJDEP LogoToday, January 17, 2013: NJDEP published major changes to guidance and standards pertaining to Vapor Intrusion. Vapor Intrusion is defined as the migration of volatile chemicals from the subsurface into overlying buildings through subsurface soils or preferential pathways (such as underground utilities). This pathway has been the driver for many off-site investigations, public notifications and costly indoor air testing since the NJDEP’s initial guidance came out in 2007.

Just released on the NJDEP’s Vapor Intrusion web page is the revised Vapor Intrusion Technical Guidance document and updates to the 2007 Vapor Intrusion Screening Levels (VISL). Finally, the web page also features Johnson & Ettinger (J&E) Model spreadsheets that were updated to reflect toxicity changes in the new VISL.

Here are just some of the changes:
Naphthalene and 2-methylnaphthalene have been added to the VISL tables. At this time, the laboratory capacity to analyze naphthalene and 2-methylnaphthalene using the preferred USEPA Method TO-17 is limited (only one certified laboratory). Therefore, the Department will not require the collection and analysis of naphthalene and 2-methylnaphthalene until July 16, 2013.

A factor of 10 has been incorporated into the calculation of the health-based ground water screening values for additional petroleum related contaminants (not reflected in the March 2007 tables) to account for degradation of the contaminants in the unsaturated zone. The additional petroleum related contaminants include: 1, 3-butadiene; cyclohexane; n-hexane; 2-methylnaphthalene; naphthalene; and styrene.

Five contaminants have been eliminated from the VISL tables due to the absence of inhalation toxicity information. These chemicals include: 1, 3-dichlorobenzene; 1, 2- dichloroethene (cis); 1, 2- dichloroethene (total); 2-chlorotoluene; and tertiary butyl alcohol (TBA).

Changes to many previously regulated compounds, including increases in groundwater screening levels for tetrachloroethylene (aka PCE) (up to 31 ug/l from a prior standard of 1 ug/l) and trichloroethylene (TCE) (up to 2 ug/l from a prior standard of 1 ug/l) for example, were also made.

Consult your LSRP regarding how these changes affect your project, or feel free to contact REPSG directly at info@repsg.com.

PCBs in Caulk

CaulkingIn 2012, several school renovation projects were hindered by caulk. The reason: PCBs.

In Connecticut, the towns of Southington and Fairfield discovered PCBs in the window caulking of their middle school and high school, respectively. In both cases, the discovery led to an unexpected increase in cost. The clean-up can also be confusing, since PCBs leach from caulk into surrounding porous building materials, including masonry, wood, and concrete. In October, the USEPA issued a reinterpretation of PCB Bulk Product Waste, specifically to address this issue.

PCBs, short for Polychlorinated Biphenyls, were commonly used in electrical equipment and building materials, until Congress banned manufacture of the toxic chemical in 1979. PCBs were used in caulk to impart flexibility, and can still be present in buildings constructed or renovated in the 1950s through the 1970s. The USEPA states that caulk containing PCBs at levels ≥ 50 parts per million (ppm) must be removed. When disposed, the caulk is to be managed as PCB Bulk Product Waste.

Now, here’s the tricky part. Because PCBs in caulk are known to contaminate adjacent building material, any surrounding building material that is coated by ≥ 50 ppm PCB-containing caulk is also considered PCB Bulk Product Waste if the caulk is still attached to the building material at the time of designation for disposal. To quote the EPA: “if your abatement plan states that you intend to dispose of the PCB caulk and any contaminated building materials together and the PCB caulk becomes separated from the adjacent contaminated building materials during remediation, you may still dispose of all the materials as a PCB Bulk Product Waste.” The plan is what’s important, not what happens between the building and the dumpster. If the caulk and building material are disposed of separately, then the building material is managed as a PCB Remediation Waste. The respective disposal options are outlined here.

With all the nitty gritty of disposal regs, it is easy to lose sight of the big picture: how to minimize exposure to PCBs, especially in schools. Air monitoring in affected schools can determine the inhalation exposure. Diligent housekeeping can minimize ingestion exposure. Encapsulation is effective at very low levels. Ultimately, all PCB-containing caulk should be removed.

Have you discovered PCBs in caulk during renovations, or gotten tangled up in disposal questions? Leave a comment below, or feel free to contact me at Sszymanski@repsg.com. Happy 2013!

Long-Term Impacts of Lead

Children Raising Hands

The use of lead-based paint was phased out by the EPA as of 1978. Yet, 34 years later, lead remains on surfaces in many aging homes.

Last month, James wrote about the soon-to-be-implemented Philadelphia ordinance requiring rental units to be certified as “lead free” or “lead safe” (read his post here for more details).

Now, here’s another reason to care about lead exposure in homes. Children exposed to lead tend to do worse in school than kids who are not exposed. A Massachusetts case study shows that the concentration of lead in a child’s bloodstream is linked to their academic performance later in life. The research found that the state’s investment in lead abatement led to improved standardized test scores among elementary school students a decade later.

Add this to the research from 2007 linking childhood lead exposure to crime rates. As a poison that targets the nervous system, lead is shown to negatively impact control impulses in children. People that are exposed as youth are more likely to have juvenile and adult criminal records. Earlier studies focused on the impact of car exhaust during the era of leaded gasoline. Now that we’ve cleaned up the air a bit, the focus has shifted to lead paint, which persists especially in low-income communities.

So, starting in December, does this mean that Philadelphia is on its way to a smarter and less violent city? Let’s hope so. It may not be much of a consolation to landlords facing tighter regulations now. But, hey, maybe it’ll pay off next decade when there are fewer broken windows to repair, and property values are soaring in those safe neighborhoods with high-performing city schools. Feel free to share your thoughts on the topic in the comments below, or contact REPSG with any questions about lead exposure and abatement.

EPA RRP (Renovation, Repair, and Painting) News

EPA LogoFor those of you who are not already aware, the EPA’s 2008 lead Renovation, Repair and Painting (RRP) Rule is a set of required standards for all building and home contractors who work in buildings that have lead-based paint. The rule requires the use of lead-safe work practices to minimize the possible conditions that can generate a lead hazard during normal RRP activities. Part of the requirement is for contractors and workers to take appropriate classes in lead-safe work practices.

Originally, the law was anticipated to include a requirement for final clearance dust wipe sampling to ensure there is not a lead dust hazard in the area of renovations. However, the EPA backed off of the requirement in 2011, instead favoring a “qualitative” method of having the contractor compare a damp cloth wipe of the renovation area to an “EPA Standard” to determine if they needed to do additional cleaning (the so called “dirty-diaper test”). You can read the EPA’s reasoning for this change in a document titled “Improving Our Regulations: Final Plan for Periodic Retrospective Reviews of Existing Regulations.” The entire EPA document is worth reading, as it addressed other regulatory topics, including drinking water standards, vehicle emissions, TSCA, NPDES, and others. However, the RRP Paragraph is below:

“After carefully weighing the issues and considering the comments from over 300 stakeholders, EPA has determined that there are currently no data or information that call into question the reliability, safety, and efficacy of the lead safe work practices established in the 2008 RRP rule.

Therefore, EPA did not finalize additional “clearance” requirements that contractors obtain lead-dust testing and laboratory analysis of the results for renovation jobs.  EPA believes that if certified and trained renovation contractors follow EPA’s 2008 RRP rule by using lead-safe work practices and following the cleaning protocol after the job is finished, lead-dust hazards will be effectively reduced.”

The RRP Rule has been in effect since April of 2010. However, it was not until April of this year that the EPA announced the first set of enforcement actions against contractors who violated the RRP rule. For those of you counting, that took the agency two years.

The three announced enforcement actions all included fines of at most $10,000, but it has been long suspected that these actions were in the pipeline. The violations cited by the EPA included both the failure of companies to obtain the RRP certification and then subsequent work practices that could have caused a lead hazard. No incidents of elevated lead blood levels were indicated.

The press release regarding the violations is available here.

Have a comment of question regarding the EPA lead RRP? Feel free to leave a comment below or contact me at jromanchek@repsg.com.

Philadelphia Lead Paint Disclosure Ordinance and Musing of Politics in Philadelphia

Philadelphia City Planning Commission SealPhiladelphia City Council, at the end of 2011, passed an ordinance that will dramatically effect some of our major clients, and hopefully will have an impact some of the work we do. Philadelphia City Ordinance 100011-A, colloquially called the “lead based paint disclosure ordinance,” amends the city code to require that a rental property be certified as either “lead free” or “lead safe” before it may be rented.

The law takes the approach of being a disclosure ordinance; landlords are required to disclose this certificate that says that the rental unit is lead free or lead safe to their prospective tenants, and such a certification must have been acquired no more than two years prior to the start of the lease. However, what the law is actually accomplishing is something different. Essentially, as I read the text of the bill, it is requiring that the owner/landlord must have the unit inspected by a certified lead paint risk assessor and declared “lead safe” or “lead free” by the assessor. Lead free means that the house has no lead-based paint at all and is a permanent designation. Lead Safe simply means that the unit is free of lead based paint hazards and is only valid for 2 years. It should be noted that part of the requirement for “lead safe” certification includes the collection of lead wipe samples to assess any potential lead dust hazard. Lead wipe samples are a quantitative way of determining lead paint hazard, rather than the mostly qualitative methods of a risk assessment.

Of course, as we know, most properties in the city with lead-based paint are not free of any lead-based paint hazards. Therefore before a “lead safe” certification can be granted the owners will have to institute lead remediation or intermediate control measures, as determined by the risk assessor, after which the property will need to be reassessed before it can be certified lead safe.

And this brings us to the interesting part of the story.

Coffee MugWhile sitting in a café off of Logan Circle recently (doing work, of course), I was having a conversation about this ordinance with a friend, in particular regarding how it is suppose to take affect this December and yet we have not seen any indication that there has been widespread movement to come into compliance. I was allegorically discussing the nature of Philadelphia politics and regulations, and was overheard by a man sitting at the table next to me.

He informed me that he was one of the (former) council staffers who helped write the ordinance, and being a policy geek myself, we began discussing the nature of the political process. According to him, the primary purpose for this ordinance was to basically coerce L&I to enforce existing lead paint safety standards in the rental properties in the city. While L&I will do a nominal “inspection” of some rental properties as a requirement to their license, they mainly react to tenant complaints. As such, the ordinance was written so that when landlords apply for their rental license through L&I, the agency will look to see if the property is “lead safe” before issuing the license, thus completing a kind of proactive inspection. This is quite similar to how asbestos inspections work in the city; the asbestos inspection report form is due to L&I along with their permit applications.

However, due to the nature of Philadelphia politics, the Ordinance was instead held up in court, changes were made, parties were appeased, and the wheels continued to turn.

Regardless, the ordinance as it stands now was left largely intact, and is scheduled to go into effect in December. It will apply to all rental housing, with the following notable exceptions:

  • Housing built after March 1978
  • PHA housing (and Section 8 vouchers)
  • Housing exclusively rented to college students
  • Housing where no child 6 years or younger will be residing during the length of the lease

The last point brings up some significant points. First, the risk assessment only needs to have occurred a maximum two years prior to the START of the lease. Therefore, in large multi-unit housing, it would not be inconceivable for each unit to have a different inspection date, based on when it is leased out. I would hope landlords would realize the logistical challenges to this approach, and the benefits of economies of scale, but who knows? Second, the wording of the bill does not require the landlords to identify the age of the tenants in order  to determine if their rental unit meets the above criteria. If the city discovers that the landlords are in violation, then they will be subject to penalties, but there may not be a reporting requirement as written

Copies of the inspection and the “lead safe” or “lead free” certification must be provided to the Department of Public Health and the tenant with every new lease, along with a notification that the tenant will contact the owner or the owner’s agent if they see any deteriorated paint. The owner must promptly make any necessary repairs. Penalties for not complying with the lead free or lead safe certifications include an order to provide the required certification and to do the work to make the property lead safe; damages for any harm caused; fines up to $2,000; refund of rent for the period the property is occupied without the certification; and attorneys fees and costs.

Do you have any comments or questions about this new ordinance? Feel free to leave a comment below or contact me at jromanchek@repsg.com.

An Introduction to Vapor Intrusion Investigations in New Jersey

 For the New Jersey Department of Environmental Protection (NJDEP), 2012 has been a banner year. Here at REPSG, we have really had to stay on our toes to ensure that allNew Jerseysites are adhering to current regulatory guidance, form submittal requirements, and rules.

In January 2012, the new Vapor Intrusion Technical Guidance was finalized, providing lots of new details for the investigation of vapor intrusion into indoor air. Additionally, the Technical Requirements for Site Remediation (7:26E) was finalized in May 2012, providing the last word in receptor evaluation of populations being potentially impacted by harmful vapors. Now that all of the changes have been finalized, Suzanne Shourds and I plan to tackle the topic of vapor intrusion in an upcoming series of blog articles. We will be discussing the ins and outs of vapor intrusion as well as our own experiences with sites in New Jersey that have addressed potential vapor intrusion. These posts will cover vapor intrusion screening levels, receptor evaluations, the stages of a vapor intrusion investigation (groundwater, soil gas, and indoor air), mitigation, and the special requirements associated with Immediate Environmental Concerns and Vapor Concerns.ew Jersey Department of Environmental Protection (NJDEP), 2012 has been a banner year. Here at REPSG, we have really had to stay on our toes to ensure that all New Jersey sites are adhering to current regulatory guidance, form submittal requirements, and rules.

To get things started, let’s take a look at Vapor Intrusion Investigation Triggers, Screening Levels, and Receptor Evaluation (Stage 1).

When conducting a Site Investigation, the first step to take to address potential vapor intrusion is to identify a source, as well as a potential pathway (typically impacted groundwater) and possible receptors. Identification of all these components triggers the need for a Vapor Intrusion Investigation (Stage 2), addressed in the next blog post on this topic).

Once impacted groundwater with concentrations above the NJDEP’s Groundwater Vapor Intrusion Screening Levels is identified and delineated, all buildings (homes, apartments, commercial spaces, warehouses) and structures (garages, utility vaults, sheds) within 30 feet of petroleum-based impacts (including free product) and/or within 100 feet of non-petroleum-based groundwater impacts (including free product) must be considered potential receptors of vapor intrusion impacts and incorporated into the investigation.       A receptor must be present in order for there to be a potential vapor intrusion concern. This includes consideration of future receptors. Once the trigger is identified, the property owner has 150 days to conduct sampling of the identified receptors. Prior to conducting this sampling, all receptors must be characterized to identify building or structure use, size, and details (such as the presence of a basement).

Additional site triggers for a vapor investigation include: soil gas or indoor air data above Vapor Intrusion Screening Levels, a wet basement or sump containing free product or groundwater impacted with volatile compounds, methane-generating conditions, any other situation threatening health and safety that is related to vapor/indoor air.

Have a question about vapor intrusion investigation triggers? Leave a comment below or please feel free to contact me at jcutright@repsg.com. Please check back soon for our follow up article on Stage 2: Vapor Intrusion Investigation.

Vapor Encroachment Explained

In a Phase I Environmental Site Assessment (ESA) report, these days you are likely to see an evaluation of vapor encroachment conditions at the site. If you haven’t, you will. The upcoming update to ASTM’s Phase I Standard proposes to treat vapor encroachment like any other source of contamination, and thus a routine component of environmental due diligence.  So, what is it?

Think of vapor encroachment as a cousin of vapor intrusion.

According to the EPA, vapor intrusion occurs when there is a migration of volatile chemicals from contaminated groundwater or soil into an overlying building. Evaluation of vapor intrusion identifies contamination sources on- site. Vapor encroachment, on the other hand, also considers off-site sources. Think of vapor encroachment as a screening tool.

Vapor encroachment screening identifies releases in the vicinity of the subject property and, based on the contaminant plume, evaluates the likelihood of vapors migrating to the subsurface of the subject property. Vapors, in this case, consist of any chemical of concern (COC); and their presence or likely presence constitutes a vapor encroachment condition (VEC). The ASTM standard for this screening (E2600-10) uses a two-tiered approach (not to be confused with the EPA’s three-tiered vapor intrusion guidance!)

Tier 1 of vapor encroachment screening uses state and federal database records to identify those sites with the potential to affect subsurface vapor conditions. Much like the radius search for a Phase I report, Tier 1 employs a 1/3 mile radius for releases of non-petroleum products, and a 1/10 mile radius for releases of petroleum products. If a VEC cannot be ruled out, i.e. there are open sites within the search distance, then on to Tier 2.

Tier 2 starts out as a non-invasive records review. If you’re lucky, the state will have regulatory files for sites identified in Tier 1, and those files will contain the location of the source and contaminant plume. Based on the relation of the plume to the subject property, it is possible to rule out a VEC. If you don’t have access to plume info, or, if a VEC cannot be ruled out non-invasively, the next option is sampling – of soil, soil gas, and/or groundwater.

Ultimately, there are four possible outcomes of a vapor encroachment screen: 1) VEC exists; 2) VEC likely exists; 3) VEC cannot be ruled out; or 4) VEC can be ruled out. In the context of a Phase I ESA, the environmental professional determines if a VEC represents a recognized environmental condition (REC) for a specific site.

As vapor intrusion receives more attention from regulators, vapor encroachment screening can be a useful tool to delineate vapor concerns originating on-site and off. The intent is to provide an evaluation of vapor in the soil, thus refining the determination of vapor that may end up indoors. Some agree, some disagree, either way it is here to stay. Have you found vapor encroachment screening to provide insight or headaches? Leave a comment below, and please feel free to contact me at Sszymanski@repsg.com with your vapor encroachment questions.

The Hidden Dangers of Undeveloped Land

Developing farmland might appear, on the surface, to be free of environmental risks and liabilities.  If a field has only ever been a farm field or a forest, what environmental risks could a developer possibly face?  The answer lies in the field itself: pesticides.

In 1997 New Jersey created the Historic Pesticide Contamination Task Force (“Task Force”) to evaluate the potential environmental impacts and health effects of exposure to historic pesticide contamination.  The findings of the Task Force were published in 1999.  The Task Force recommended the sampling of former agricultural areas, particularly in areas where soils will be exposed to children (i.e. schools, daycare centers and playgrounds).  Indeed, under the Site Remediation Reform Act (“SRRA”) former agricultural land is considered an area of concern when the future use of a property includes sensitive populations.  Addendum 2 of the Task Force report lists the concentrations of pesticides included in the NJDEP Soil Cleanup Criteria (“SCC”).  While the Task Force report remains an informative document to be used in assessing a property, the pesticide concentrations included in the addenda are no longer the most up-to-date since the implementation of the New Jersey Soil Remediation Standards in June 2008.  For this reason, it is critical that environmental professionals communicate with the laboratories completing the soil analysis.  The pesticide chlordane is an excellent example of the potential pitfalls to not clearly communicating with the laboratory about project needs.

The old pesticide list required investigators to analyze soil samples for alpha-chlordane (CAS No. 5103-71-9) and gamma-chlordane (CAS No. 5103-74-2) individually.  The current NJ Soil Remediation Standards (“SRS,” last updated October 3, 2011) require the analysis of total chlordane (CAS No. 57-74-9) instead of the individual compounds.  According to N.J.A.C. 7:26D (Table 1A and 1B), total chlordane is calculated by adding together alpha- and gamma-chlordane.

When requesting chlordane from an analytical laboratory, it is critical that you specify the correct chlordane and CAS number.  Unless otherwise specified, the laboratory may report technical chlordane (CAS No. 12789-03-6) which is a mixture of 23 different compounds that include chlordane isomers.  In our experience we have seen analytical results in which technical chlordane is more than double the concentration of total chlordane.

The development of farmland remains an attractive option to avoid environmental risks; however mistaking technical chlordane for total chlordane could mean the difference between compliant soil samples and a delayed project due to repeated rounds of soil sampling.

If you have any questions about Site Remediation, Soil Contamination or the NJDEP, feel free to email me at jmanuel@repsg.com or leave a comment below!

Philadelphia’s Ghost Factories

USA Today’s recent investigation into ongoing lead contamination at sites of former lead smelters, which they term ‘Ghost Factories,’ has gotten a lot of coverage on environmental blogs lately. So, I decided to look and see what they say about Philadelphia. Not surprisingly, the majority of the smelter locations are in the east coast, with thirty-one located in Philly.

The newspaper’s method was to identify the location of former lead smelters (using Sanborn maps, of course), then went to 21 of those neighborhoods, and pointed an XRF analyzer at the ground, often in residents’ backyards. Most of these yards had elevated lead levels in the soil: 80% of of the neighborhoods had a median soil lead level above 80 ppm, several neighborhoods reached above 2,000 ppm. “Lead levels in the soil samples collected by USA TODAY were generally highest in places like Chicago, Cleveland and Philadelphia — where old inner-city neighborhoods mingled with industrial sites.”

The thrust of the story is the danger posed to children in these neighborhoods, and the lack of action by the EPA to address it.

Now, this bring up a few issue. First of all, it’s not like the EPA can conclusively hold the lead smelters accountable for contamination of an entire neighborhood. There are plenty of sources of lead in urban areas, it wouldn’t be hard to fight a charge. Yet, it shows a big gap in the superfund law. We do a lot of work to clean up brownfields. When a commercial transaction happens, due diligence functions as a useful screen to find out about contaminated sites and remediate them. Well, as long as there’s an interest in redevelopment. But no one conducts a Phase I when they buy an old rowhome in Kensington. What does USA Today think that the EPA is supposed to do here?

There are more than 400 of these ghost factories, only 230 are pinned down in this investigation. “Because most of the old smelters had operated for decades without any regulatory oversight and are now gone, little was known about the size of each factory, where they were located, how much lead they processed and how much pollution they left behind.” A start would be to find these factories. Then what, test everyone’s soil? Mount a massive education campaign? Pave every yard and park? It sounds a lot like the radon situation, a ubiquitous environmental hazard primarily affecting residences, and frustration about the EPA’s lack of action.

And speaking of Ghost Factories, REPSG’s own Jerry Naples received a shout-out on WHYY’s Radio Times recently. As part of the ongoing discussion of Ghost Factories in our city, Marty Moss-Coane featured the topic on her hour long PBS radio show Radio Times.  Her guests included USA Today reporter Allison Young, and Mary Seton Corboy, the founder of Greensgrow Farms in Kensington. Jerry Naples’ shout out came about halfway through the interview, when Mary was talking about the difficulty of developing neighborhood urban farms atop contaminated soils. Mary mentioned that Greensgrow was fortunate to have a member of their board who runs an environmental remediation company. That, my friends, would be REPSG.

You can download and listen to the whole interview on WHYY’s website here and hear how the USA Today’s report has started (or re-started) the conversation of residential pollution in urban environments.

Do you have any thoughts or questions about ghost factories, lead contamination, radon, or any environmental hazards in your community? Feel free to leave a comment below  or contact me at jromanchek@repsg.com.