LEVEL OF CONCERN
Berks consultant questions EPA safety standards surrounding former Exide site
On a 40-acre plot in Muhlenberg Township and Laureldale sits a monument to an era before modern environmental regulations.
The former Exide Technologies facility at 3000 Montrose Ave. has been closed since 2013, but traces of the toxic lead released by the battery plant decades prior remain buried in the soil of surrounding properties.
The question, according to Fred Osman, an environmental consultant hired by Berks County, is whether the level of lead in the soil still threatens the health of children living near the site.
Updates to the scientific consensus on safe lead standards have kept that question relevant, despite efforts by the EPA to mitigate lead pollution in the area, Osman said.
“The general concern for lead contamination is cognitive functioning in young children,” Osman noted. “It (lead) interferes with brain development and learning. It can cause a lot of problems.”
He said lead in the soil could be ingested by young children, which is the main concern with the Exide site.
County called for reevaluation
In a 2020 letter sent to the EPA on behalf of the county, Osman noted the standards the EPA set for safe lead levels in the soil around the Exide plant were based on old U.S. Centers for Disease Control and Prevention guidelines informed by outdated science.
Those guidelines were set decades prior and have since been updated by the CDC, Osman said.
In 2001 and 2002, the EPA took soil samples from 600 properties around the Exide facility and tested the bloodlead levels of 48 children in the area.
Only one child was found to have blood-lead levels that exceeded the CDC standard at the time of over 10 micrograms per deciliter — and that child was a visitor to the area.
Based on its assessment of the Exide site and CDC blood-lead standards at the time, the EPA concluded in 2007 that a soil-lead level of below 650 parts per million didn’t pose an unacceptable health risk to residences surrounding the plant.
But in 2012, the CDC lowered its standard for safe blood-lead levels to 5 micrograms per deciliter, in response to multiple studies showing that 5 micrograms per deciliter or less can cause lifelong health effects, including permanent neurological damage and behavioral disorders.
In 2021 the CDC lowered its standard again to 3.5 micrograms per deciliter, and has warned that despite the official standard, no safe blood-lead level has been identified for children.
Osman noted that 13 of the 48 children sampled in the CDC’s 2002 study had a blood-lead level of over 3.5 micrograms per deciliter.
Despite the CDC’s shifting standards, the EPA maintains that a soil level of 650 ppm is acceptable — a claim that Osman and county officials still contest today.
2017 study
In addition, Osman’s letter mentions a 2017 by the Metropolitan State University of Denver and the Reading Eagle that surveyed the soil of 82 properties around the Exide plant and found that 74% had soil-lead levels above 650 ppm.
Those levels were found despite previous cleanup efforts by the EPA for residences in the area, which were completed in 2009 and involved 220 properties.
In a response to the county’s 2020 letter, EPA officials said a study had been done in 2017 of 20 properties that asked to have their soil-lead levels tested in response to the Reading Eagle study.
That study calculated average soil-lead levels by taking four soil samples from each property.
It found that none of the 20 properties sampled had an average soil level above the EPA’s acceptable standard of 650 ppm.
EPA officials also said they were determining how to proceed in conducting additional site assessments to determine if more soil remediation is necessary, including in the nearby areas of Sacred Heart Convent and Rosedale Camp Grove.
Areas on those properties that the EPA found were at a high risk of residential exposure, such as playgrounds and cabins, were subject to a cleanup in 2018 and 2019, respectively, according to EPA officials.
Issues remain
Osman holds that the EPA’s response didn’t go far enough in addressing the core issue of whether a soil level of 650 ppm is safe for children — an issue the EPA has yet to properly address in 2023, Osman said.
He brought up a 2017 inquiry by U.S. Sen. Bob Casey Jr. to the EPA about the results of the Reading Eagle study, which EPA Acting Administrator Cecil Rodrigues responded to.
Rodrigues claimed the EPA was revising its model used to determine acceptable soil levels and would implement any updates as needed to cleanup sites nationwide, including Exide.
“They said they would go back and reevaluate, which they still haven’t done,” Osman said of the EPA.
Osman noted the EPA’s standards for soil-lead levels in the Exide area are lower than more recent similar EPA standards.
He highlighted an August 2020 fact sheet in which the EPA says lead levels for bare soil in residential areas and children’s play areas should be below 400 ppm, and that children should be kept out of gardens with lead levels higher than 200 ppm.
He also claimed the EPA’s follow-up to the Reading Eagle 2017 study was flawed because it only sampled properties that requested sampling, and it used composite samples that can dilute high lead levels.
“It’s just bureaucracy, they’re not really responding to their own policies, their own models, their own protocols,” Osman said, “And they’re not using CDC guidelines. I think it’s unacceptable levels of risk.”
Osman said he wasn’t aware of any follow-up studies on children’s blood levels in the Exide area since the initial EPA sampling in 2002.
He said the California EPA maintains a lead standard of 80 ppm for residential use areas, which amounts to a blood lead level of about 1 micrograms per deciliter.
“That’s a pretty good reference number,” Osman said.
County pursuing solutions
The county commissioners are also still pursuing solutions. In a November operations meeting, Osman gave an update on the state of the EPA cleanup.
County officials suggested preparing a letter to state and federal legislators addressing Osman’s concerns.
Osman said he’s putting together a proposal for a letter to Gov. Josh Shapiro, questioning the state of the EPA’s risk assessments and blood-lead modeling standards and asking for a rationale for the Exide site’s soil guidelines.
The EPA is not planning on revising its soil standards around the Exide facility, despite sampling another 10 properties within one mile of the Exide facility in November and December, said David Sternberg, EPA press officer.
“The samples were collected for the purpose of EPA’s on-going assessment of the Exide facility, which will help determine the agency’s next steps in addressing any threats to human health or the environment that may be present in the surrounding community,” Sternberg said.
He said the sampling also included a collection of groundwater from monitoring wells located on and off the Exide facility to assess the amount of lead and other heavy metals in the water.
When asked if the EPA is planning further remediation for the area, Sternberg said any updates on future plans for the site would be provided as they become available.
New EPA strategy
Osman said the renewed sampling might be related to a new EPA strategy aimed at reducing lead exposures nationwide.
The strategy, which the EPA announced in December, aims to identify communities with high lead exposures, reduce lead exposures, improve health outcomes and community engagement, and support critical research to inform those efforts.
The initiative includes a federal investment of $600 million to clean up over 50 superfund sites where lead is a concern.
Another EPA effort involving the Exide site is an ongoing removal operation that began in March 2021, intended to clear the plant of lead, acid and other harmful chemicals that could jeopardize nearby residents’ health.
Part of that effort includes monitoring air quality around the site to ensure airborne lead isn’t leaving the area.
The EPA has been monitoring groundwater lead levels as well.
At an October meeting, EPA officials noted that offsite evaluations found the Exide area’s soil is neutral, meaning it immobilizes lead from migrating into groundwater, and lead concentrations in groundwater around residential areas were within safe levels.