2000 EPA
In 1999 EPA Region III’s removal administrative record for the Logan Section Contamination Site in Philadelphia. They trace the site from community complaint (September 1999) to an approved soil cleanup (December 1999).
THE SITE
The site covers 17 blocks in the lower Northeast, bounded by Roosevelt Boulevard and Marshall Street, Wingohocking Street, 11th Street, and Loudon Street. The area was a former stream valley filled with ash cinder and construction rubble. Homes built on that fill cracked as the ground settled, so the City condemned them and demolished about 75%. The basements were backfilled with more fill. What remained were vacant lots: about 30% paved, 40% grass, and 30% bare soil. Kids played on the lots, people cut across them, and some neighbors grew vegetables there.
EARLIER TESTING (1999). In February, an Army Corps of Engineers test found elevated lead and mercury. In March and May, the City took 17 samples, one per lot:
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4 samples exceeded Pennsylvania Act 2 direct-contact standards for lead, ranging from 645.5 to 1,892.8 ppm.
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10 samples exceeded the standards for arsenic, ranging from 13.3 to 84.5 ppm.
The City told residents the levels were a long-term, chronic concern rather than an immediate risk, and advised handwashing. Follow-up arsenic tests in August came back much lower. On August 27, the Logan/Olney Coalition wrote to Senator Santorum asking for an EPA investigation and an “emergency cleanup.”
EPA RESPONSE
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Sept 8: EPA logged an incident notification report naming lead and arsenic. The coalition was listed as the reporter and On-Scene Coordinator (OSC) Bob Kelly as the preparer.
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Nov 8–11: OSC Robert Kelly and Weston contractors gridded the lots and collected about 230 GPS-referenced soil samples, plus background samples, and sent them to a lab in Huntsville, AL. Kelly met with Rev. Newkirk of Harold D. Davis Baptist Church, the Logan Assistance Corporation, and a City risk manager. On Nov 12, the team handed out 500 newsletters in the neighborhood.
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Nov 16: Kelly authorized $50,000 in Superfund (CERCLA) money for fencing and guards to keep people off the soil until results came in. He cited children’s exposure, contamination near the surface, and soil that could blow or be tracked into homes. Senator Santorum toured the site with residents that same day.
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Nov 18–19: Contractors put up high-visibility fencing around all 21 sample grids.
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Dec 8: An EPA toxicologist ran a lead exposure model for children (the IEUBK model) on the results. It found six distinct hotspots that pose unacceptable risk to young children. The cleanup target was set at an average of 750 mg/kg lead. That is higher than EPA’s usual 400 ppm screening level because of high background lead in the city.
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Dec 14: The federal toxic-substances health agency (ATSDR) agreed that remediation was appropriate at the six hotspots. Weston produced a soil excavation map.
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Dec 15: The Division Director verbally raised the funding ceiling to $200,000. Next steps were to keep the guards in place, share results with the City, and meet residents to explain the cleanup.
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The record was made publicly available February 9, 2000.
Table of Contents
1. September 9, 1999. Incident Notification Report – Logan Olney Coalition (186644)
2. November 12, 1999 Pollution Report #1 (186645)
3. November 18, 1999. Pollution Report #2, Special Bulletin A
Notification of $50,000 Comprehensive Environmental Response (186648)
4. November 19, 1999. Pollution Report #3 (186646)
5. December 14, 1999. Soil Excavation Map [Roy F. Weston Inc] (186647)
6. December 15, 1999. Pollution Report #4, Special Bulletin B – Verbal Increase of Ceiling to $200,000 (186649)
7. February 9, 2000. Removal Administrative Record File Index of Documents (186650)
The EPA documents
1. September 9, 1999
Incident Notification Report – Logan Olney Coalition (186644)
Summary: September 9, 1999 Incident Notification Report. Logan/Olney Coalition contacts EPA. EPA issues site assessment report. EPA OSC meets with Senator Santorum and residents on Logan Triangle site November 16, 1999 re: concerns about contamination on site.
2. November 12, 1999
Pollution Report #1 (186645)
Summary: November 12, 1999 Pollution Report #1 written by EPA OSC Robert F. Kelly dated November 12, 1999 describes how the EPA became involved.
February 1999: City requests USACE to sample and analyze surface soil on site.
March, May 1999: City conducted further sampling and these tests showed elevated levels of arsenic and lead in surface materials - 'no immediate health risk'. but - 'posing a potential, chronic, or long term health hazard.'
August 1999: sampling (assuming City) for arsenic (only) showing arsenic 'significantly lower' than in earlier round of testing.
May - Aug (date uncertain): Logan/Olney Coalition writes Senator Santorum and EPA is contacted and becomes involved.
After an on site meeting with community members and Senator Santorum, EPA funded a site testing program, and borings/ 'grab samples' took place on site November 8 (~60 samples), 9 (~110 samples), 10 (~40 samples), that were sent to Sential, Inc in Huntsville, AL for analysis. Site was gridded out in lots 1 - 21 as shown on December 14, 1999 Soil Excavation Map (#5 below).
3. November 18, 1999
Pollution Report #2. Special Bulletin A – Notification of $50,000 Comprehensive Environmental Response (186648)
Summary: November 19, 1999 Pollution Report #2 and Special Bulletin A states:"The OSC has identified an immediate and significant threat to public health or welfare or the environment posed by conditions at the site as expressed above [Sections I and II of this document]. Hazardous substances (lead and arsenic) have been identified at the site in concentrations which may pose these threats if exposure continues. A Removal Action is warranted based upon the criteria of Section 300.415 of the NCP due to the uncontrolled release of hazardous substances into the environment. Actual or threatened release of harzardous substances from this site, if not addressed by implementing response action identified herein, may present an imminent and substantial endangerment to public health, or welfare, or the environment."
Threat Justification (NCP §300.415(b)(2))
The report cites four criteria justifying removal action:
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(i) Direct human/animal exposure risk — children playing in contaminated soil, hand-to-mouth contact, residents gardening in affected soil
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(iv) Shallow contamination (sampled ~3 inches deep) with high migration potential
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(v) Weather-driven migration risk (runoff onto lawns, airborne dust from unvegetated areas)
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(vii) Limited alternative response mechanisms currently available besides EPA action
Proposed Action & Cost
On November 16, 1999, the OSC activated $50,000 in CERCLA removal funds to:
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Mobilize/demobilize personnel, supplies, and equipment
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Install temporary fencing to restrict access to contaminated areas
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Provide guard service to prevent barrier breaches
4. November 19, 1999
Pollution Report #3 (186646)
Summary: November 1999 Pollution Report #3. Activity as of this report (event dates 11/18–11/19/99):
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ERRS crews (and a subcontractor) were on-site installing high-visibility fencing around the perimeters of sample grids 1–21.
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Personnel on-site: 1 EPA rep, 1 SATA rep.
Next steps: OSC Robert F. Kelly (EPA Region III) will continue coordinating with state/local officials while awaiting lab analysis results.
5. December 14, 1999
Soil Excavation Map [Roy F. Weston Inc] (186647)
Summary: December 14, 1999 Soil Excavation Map. This is the Soil Excavation Map that documents grids, where soils testing took place, and lead and arsenic levels at the locations. An enlarged section of the map is below the full map.
6. December 15, 1999
Pollution Report #4
Special Bulletin B – Verbal Increase of Ceiling to $200,000 (186649)
Summary: December 15, 1999 Pollution Report #4, Special Bulletin B.
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Funding increase: On 11/16/99, OSC Robert F. Kelly activated $50,000 in CERCLA funds to begin stabilizing hazardous substances at the site. On 12/15/99, the Division Director verbally authorized a $150,000 increase, raising the total ceiling to $200,000.
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Toxicology findings (12/08/99): EPA's toxicologist ran the Integrated Exposure Uptake Biokinetic (IEUBK) Model on soil sampling data. The results identified six distinct pockets of lead contamination posing unacceptable risk to young children in a residential setting. The recommended cleanup target is 750 mg/kg average lead concentration, adjusted for elevated urban background lead levels.
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ATSDR consultation (12/14/99): The Agency for Toxic Substances and Disease Registry's Division of Toxicology reviewed the findings and agreed with EPA that remediation is warranted at the six contaminated pockets.
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Planned next steps:
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EPA will maintain site security/guard service until a remedy is implemented.
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EPA will share sampling results and recommendations with the City of Philadelphia.
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EPA will meet with local residents to explain findings and outline planned remedies.
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7. February 9, 2000
Removal Administrative Record File Index of Documents (186650)
Summary: February 9, 2000 Removal Administrative Record File
This is an Index of Documents for the Logan Section Contamination Site Removal Administrative Record File (a lead contamination site in Philadelphia, Pennsylvania), made available on 2/9/00. It lists the records in two categories:
I. Factual Information (4 documents)
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ERNS Incident Notification Report — prepared by Bob Kelly, 9/8/99
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U.S. EPA Pollution Report #1 — 11/12/99
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U.S. EPA Pollution Report #3 — 11/19/99
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Soil Excavation Map, Logan Lead Site — prepared by Roy F. Weston, Inc., 12/14/99
II. Decision Documents (2 documents)
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Special Bulletin A — notifying a $50,000 CERCLA removal action, 11/18/99
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Special Bulletin B — verbal increase of the funding ceiling to $200,000, 12/15/99
In short, this is a table of contents for the case file rather than the underlying reports themselves: it shows that a lead contamination cleanup ("removal action") was initiated at the Logan Section site in late 1999, starting with a $50,000 budget that was quickly raised to $200,000 as the scope became clearer.