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National Advisory Council for

Environmental Policy and Technology

February 15, 2012

The Honorable Lisa P. Jackson

Administrator

United States Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

RE: Technologies for Environmental Justice Communities and Other Vulnerable Populations

Dear Administrator Jackson: 

In May 2010 you asked us to identify the needs for technologies that can help address 

environmental problems experienced by environmental justice communities and other vulnerable 

populations (which we refer to as EJ/VP communities). Your charge was straightforward: to 

provide ―advice ... on the identification and use of existing, or needed, technologies ... to better 

protect vulnerable populations‖, including ―game-changing technologies‖ that have ―potential to 

deliver relevant, actionable information‖ to all parties. 

We studied the topic in detail, discussed needs for technologies in a dozen diverse communities, 

and prepared six community case studies that illustrate the needs for deployment of effective 

technologies in EJ/VP communities across the country. 

Clearly most environmental justice communities and other vulnerable populations face unusually 

high risks to human health and the environment. We offer two broad recommendations and a 

number of specific suggestions to address this situation:

1. EJ/VP communities need three kinds of technologies:

Detection, monitoring, and assessment technologies—from portable sensors 

that can be used by community members to complex monitoring systems operated 

by specially trained personnel—are the most important technology needs at this 

time in most EJ/VP communities and can be true game-changers. 

Communication technologies are needed to assure that residents, local agencies, 

and industry are fully informed about risks to the community, such as:
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real-time information about ambient pollution that may peak at dangerous 

levels and about steps that residents can take to reduce risks when peaks 

occur;

real-time information needed by first responders and local hospitals when 

accidents or other factors cause spikes in pollution; and

information that residents can use to protect themselves from localized 

environmental exposures in their homes, backyards, parks, and 

neighborhoods. This information could come from sensors of contaminated air 

and contaminated soils—as well as easily- understandable written, electronic, 

and face-to-face verbal information about what residents can do to understand 

and protect themselves from localized environmental threats. 

Solution technologies, that is, technological solutions to correct environmental 

problems, are also vitally important and need attention because they can be costly 

and difficult to identify and deploy at a particular clean-up site. There is a need to 

develop rapid, less expensive solution technologies that can be used to clean sites 

more effectively. 

2. EPA’s Office of Research and Development should enter into partnerships with 

EJ/VP communities to develop and deploy these technologies.

 

ORD and EPA‘s regional offices should work with one or two communities in 

each region to develop needed technologies and become a national model for 

deployment of technologies in other communities;

ORD should establish a public-private task force to engage EJ/VP leaders from 

around the country, technology companies, investors, and other experts to inform 

and guide this national partnership.

This letter includes:

A. A review of the distinctive nature of the problems facing EJ/VP communities and other 

vulnerable populations;

B. A discussion of needs for technologies to detect and monitor, communicate, and solve 

environmental problems in EJ/VP communities, including six case studies and lists of 

specific needed technologies. Full case studies of all six communities are available at

http://www.epa.gov/ofacmo/nacept/reports/index.html.

C. Additional, detailed recommendations for a ―game-changing‖ effort by ORD and other 

parts of EPA to work with EJ/VP communities, the private sector, and others to identify, 

develop, and deploy needed technologies. 
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A. PROBLEMS FACED BY ENVIRONMENTAL JUSTICE COMMUNITIES

AND OTHER VULNERABLE POPULATIONS

Vulnerable populations—including children, the elderly, people in poor health, and people living 

in environmental justice communities—experience health effects from environmental pollutants 

directly and profoundly. Vulnerable populations are often exposed to more pollutants, through 

more environmental pathways and at higher concentrations, than populations generally. 

Vulnerable populations are more susceptible to being harmed, are less prepared to withstand 

exposure, and are less able to recover.

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Environmental justice communities also suffer from the 

additional stress of living in poverty, experiencing racism, or both; and they often lack influence 

and institutional strengths to organize effectively for change. They often feel, and, in fact are, 

disempowered. 

The three distinctive threats to vulnerable populations generally and environmental justice 

communities in particular—multiple and cumulative exposures, additional stressors, and 

disempowerment—often make it hard for residents, governments, and businesses to understand 

and address the full scope and nature of environmental problems, even when human-health risks 

are significant. In many cases, problems persist until residents organize to become effective 

advocates for change. 

This letter focuses on the technology needs of environmental justice communities and other 

vulnerable populations (EJ/VP communities). We have identified these needs through case 

studies of environmental justice communities, and we highlight these case studies throughout the 

letter. Some of the case study communities are facing problems that have only recently been 

identified and are still not fully understood. Others face environmental conditions that have been 

causing severe damage to the health of local residents and to the economic and social vitality of 

the local community for far too long. In all parts of the country, there are too many communities 

where EJ/VP communities have been experiencing severe environmental problems for far too 

long. 

Whether their problems are new or long-standing, EJ/VP communities need technologies to 

effectively detect, monitor, and assess pollutants. They also need technologies to communicate 

risks. And they need technologies that can solve environmental problems. The first need is 

particularly pressing. Data gathered by residents can start a powerful, constructive process of 

community-driven environmental change. (See Table 1) The most persuasive detection, 

monitoring, and assessment data would track pollutants to their sources, link pollution to health 

outcomes, and provide timely, understandable information to local communities—residents, 

public-health and environmental regulatory agencies, first responders, businesses, and others—

about what they can do to reduce human-health and environmental risks. 

Although adequate detection, monitoring, and assessment; communications; and solutions 

technologies may be costly, that cost is small in comparison to healthcare and other costs paid by 

residents and by taxpayers.2
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B. NEEDS FOR TECHNOLOGIES

1. The most important technology need in EJ/VP communities at this time is for better 

technologies to detect, monitor, and help residents and others understand ongoing 

environmental contamination—and for these technologies to be deployed effectively

so that they can inform and drive near-term decisions about how to reduce risks on 

an individual as well as a community-wide basis.

Residents of EJ/VP communities want to know: 

How much hazardous and toxic stuff is in the air my children breathe, the water 

they drink, the soils in the backyards and school playgrounds, the food grown in 

our garden, and the fish we catch in local streams? Is my family safe? 

EJ/VP communities confront multiple stressors, including sources of pollution and multiple 

pollutants, resulting in human-health and economic impacts. ―Bucket samplers‖ have been 

useful to residents of EJ communities to detect and demonstrate the presence of plumes passing 

through fenceline neighborhoods.3,4 But in most cases, existing monitoring technologies 

typically specified and deployed do not provide robust real-time and historic data on pollution 

levels. They provide insufficient bases for risk analysis and response, preventing assessment of 

cumulative and synergistic effects of multiple pollutants in combination with other stressors. 

New, effectively deployed technologies to adequately detect environmental contamination could 

be ―game-changers‖ for environmental justice communities and other vulnerable populations, 

even if the technologies don‘t contain all of these desired capabilities. Some such technologies 

are available and being deployed in a few locations.5,6,7,8,9,10

Two case studies illustrate the needs for credible and effectively deployed detection, monitoring,

and assessment technologies.
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Rubbertown, KY: The Need for Detection and Communication Technologies

Rubbertown is a large industrial section of west Louisville, Kentucky, that is home 

to 19 large plastics and petrochemical facilities, with low-income African American 

neighbors on the east and low-income whites to the south. Forty-five percent of the 

3,000 people living within a half-mile of these facilities have a household income 

less than $25,000. This is a typical ―chemical corridor‖ community. 

Some technologies are already in place, although arguably not being used enough: 

warning sirens, reverse 911 calling systems, and a 24-hour complaint hotline. 

Communities and residents are already using Tedlar®bag grab sample ―bucket 

brigade‖ technology, but it is not sensitive or quick enough and is still somewhat 

expensive to the community residents. 

Residents of Rubbertown want improved technologies to solve the environmental 

problems they encounter on a daily basis, plus:

1. Handheld monitors, operated by community members, to measure VOCs at 

health-threatening levels during short periods of time.

2. Real-time monitoring of air toxics at the stack or fenceline, accessible on the 

Internet and sent to regulators.

3. Phone and text-message alerts to local residents when emissions exceed 

limits and may cause health problems.

Hartford, CT: The Need for Continuous Monitoring

Hartford, Connecticut, is home to 125,000 people, 80% of whom are African 

American, Latino, or mixed race. Average income is very low. A large trash-toenergy incinerator handles waste from 70 towns around the state and, previously, 

from other states as well. Some of the trash contains large quantities of metals or 

toxics, and there are more than 10 fires or explosions each year. But local emissions 

of air toxics are measured only once a year. Local residents have asked for both 

detection and communication technologies:

1. Continuous emissions monitoring of air toxics on the stack of the 

incinerator.

2. Communications technologies connected to the emissions monitors so that at 

appropriately high levels of toxic emissions it will automatically alert the 

public, managers of the incinerator, and local emergency response and 

regulatory agencies by voice or text messages on cellular telephones of 

monitoring readings with or without suggestions on how they should 

respond.

3. Hand-held sensors that local residents could use to measure and send data 

about ambient air quality to the local agency, managers of the incinerator, 

and to local residents.
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The greatest need in EJ/VP communities is for technologies that residents and community groups 

can use to detect and monitor environmental threats, because they can spark community-driven 

environmental change. 

The technologies that are needed extend along a continuum from relatively simple citizenoperated sensors that are geo-located and sometimes hand-held to more powerful monitoring 

systems that are deployed and maintained by specialists. The continuum of technology needs 

has multiple dimensions including:

Low-cost to expensive

Single-observation to continuous

Single-parameter to multi-parameter

Point to area

Fixed location to mobile

Medium-sensitivity to high-sensitivity

Volunteer-contributed to professionally collected data

New monitoring technologies that are embedded within sensor networks—using fixed as well as 

portable sensors—are especially important

More complex monitoring technologies are necessary as well. Complex technologies, operated 

and maintained by specially trained personnel, generate technically credible data that are 

particularly meaningful to regulators, emitters, and elected officials at all levels. These 

technologies can credibly document not only the background concentrations in plumes crossing 

fence-lines and passing through neighborhoods but also the frequency, magnitude (or 

concentration), and duration of excursions, accidents, and unscheduled releases. Some such 

cutting-edge technologies exist11,12,13,14 and are available for deployment, and others need to be 

developed. Community organizations and local residents can and should participate in the use of 

the full continuum of technologies. They will learn and be empowered by doing so.

Many of these needed technologies for detection and monitoring are already in use in 

commercial settings. For example, the construction industry is developing ―smart buildings‖ 

with sensor systems that measure heat, light, and energy use and use these data to fine-tune 

operating systems to reduce costs. Automobile manufacturers have developed ―smart cars‖ that 

sense traffic lights, other cars, and other obstacles and can steer around them. The first ―smart 

cities‖ in Spain, the Middle East, and China have ―smart pipes‖ that sense water pressure as well 

as the contents of the pipes, so that pipes can be repaired before they spring big leaks. Some 

manufacturers of aircraft engines have stopped selling them; instead they lease engines equipped 

with sensors that send data to the manufacturers about the need for repairs.15

Sensor systems are also being constructed for environmental monitoring. For example, in 

October 2011, the National Science Foundation (NSF) awarded $3 million to Clemson 

University to design, develop and deploy a basin-wide network of computerized sensors to 

monitor water quality along the length of the 312-mile Savannah River. The sensors will be 

attached to a system of buoys anchored to the river floor and will collect data on water 

temperature, flow rate, turbidity, oxygen levels and the presence of pollutants.16
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Dense network observing systems are also developing rapidly for air emissions, including air 

toxics. Air emission inventories built from emissions factors have consistently underestimated 

emissions, because they often leave out small sources and leaks. New technologies might help 

fill some of these gaps. Also, high quality emissions data might be obtained from third party, 

private sector sources to supplement government observing practices.17

 

EPA should assure that all EJ/VP communities have access to and use similar smart, costeffective state-of-practice sensor technologies to measure indoor air quality, water quality, and 

emissions from industrial facilities in their communities in real time.

Detection and monitoring technologies can be used very effectively in tandem with sophisticated

assessment technologies, which can document the multiple, synergistic risks that EJ/VP 

communities face. Assessment technologies can also help identify solutions that advance health 

and environmental quality, economic opportunity, and social benefits. The assessment 

technologies that are needed in EJ/VP communities include risk assessment, life cycle 

assessment, environmental footprint assessment, resilience analysis, integrated assessment 

models, and sustainability impact assessment.18

Examples of Needs for Detection, Monitoring, and 

Assessment Technologies in EJ/VP Communities

Simple sensors, analogous to carbon monoxide or smoke detectors, that are connected to 

cellular data networks that may be loaned to or permanently installed in community 

homes, schools, or other locations of interest. 

Fixed sensors installed at multiple locations along the property fenceline around 

industrial facilities. 

Geo-located, personal sensors that may be carried by persons for continuous monitoring 

of both ambient conditions and individual exposure.

Monitoring and warning systems of air pollution in ―fenceline‖ communities. 

Advanced assessment technologies that can be used in tandem with geo-coded detection 

and monitoring data to monitor multiple sources of pollution and multiple pathways of 

exposure. 
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Toledo, OH: The Need for Effective Communication Technologies

The Dorr-Smead Brownfields in Toledo, Ohio is an old, inner-city industrialized 

area with large acreages of contaminated soils located close to housing in this 

low-income, predominantly minority community. Local residents and 

environmental agencies are concerned about exposure to contaminated soils from 

gardening and children playing in backyards and about the possibility that gases 

from contaminated soils may leak into basements.

Dorr-Smead is also a leader in urban revitalization, with many abandoned lands 

being used for urban agriculture. Often the crops grow in ―clean‖ soils that are 

trucked in, but there is always the risk that contaminants may leak from the local 

soils into the pots and bins where vegetables and fruits are growing. One need in 

Dorr-Smead is for easy-to-use soil test sensors, with clear instructions on soil test 

sampling, and information about crops that can be grown safely.

In addition, there is a need for communication technologies in Dorr-Smead to 

educate residents who are raising crops about how to construct their gardens so 

that pollutants in contaminated soils do not pass into the ―clean‖ soil where the 

crops are growing. EPA and state and local environmental agencies should 

develop and deploy communication technologies in partnership with nongovernmental organizations, who may be met with greater trust than government, 

and tailor communication to specific audiences. Even though EPA‘s mission is 

quite different from the US Census Bureau‘s, EPA might look to the Census 

Bureau‘s experience communicating with diverse communities. The Census

Bureau has established partnerships with cell phone companies for effective 

messaging, used social media extensively, partnered with community-based 

organizations, and undertaken market segmentation research to tailor messaging 

to specific communities. In partnership with local professionals and lay experts 

and organizations, and working collaboratively with state and local environmental 

agencies, EPA should customize toolkits for use by residents in specific EJ/VP 

communities. 

2. EJ/VP communities need effective communication technologies for both data access 

and information sharing. 

In addition to technologies to detect, monitor and assess pollution, EJ/VP communities need 

technologies to communicate information about pollution. In Hartford and Rubbertown, 

residents have asked for relatively simple communication technologies – email and cell phone 

systems to alert residents to high levels of pollution. Two additional case studies suggest other 

communication technologies that are needed in EJ/VP communities.
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If there had been appropriate sensors in place in Graniteville,19,20,21 some of the deaths and illness 

might have been prevented. But local sensors would not have been enough. What was needed 

was an information system on the railcars themselves to communicate information about the 

location, types, and condition of the chemicals, the rail cars, the train, and the accident to 

officials, rescue teams, hospitals, and community residents. The technologies needed were not 

just electronic. Also needed were management systems to assure that information available to 

the railroad and the shippers would be made available to the community immediately after the 

accident.

Communications technologies must be accessible and provide information that local residents 

and agencies – as well as businesses and other entities that are sources of pollution – can obtain 

at very low cost and can use effectively. This means that communications technologies may 

need to provide information in other languages besides English in some communities and must 

be easily understandable by ordinary citizens in all communities. Communications technologies 

must also provide opportunities for local residents to get more information about the nature of 

specific problems, about how these problems relate to other potential exposure, and about how to 

deal with these problems in specific locations. In some cases, communications technologies 

should also enable local residents to ask questions and get information from agency staff or other 

trained personnel. 

Graniteville, SC: The Need for Effective Communication Technologies

Graniteville, South Carolina, is a low-to-middle-income community adjacent to 

several old abandoned textile mills—brownfields. A major rail line runs through 

Graniteville which facilitated picking up products from the textile mills before 

they closed. In January 2005, two trains collided, five cars carrying chlorine and 

other toxic chemicals went off the rails, and the tanks ruptured. The result was a 

full-scale emergency response situation, and it did not go well because of 

inadequate technologies and inadequate arrangements for analyzing and 

communicating information about the chemicals released. 

Railroads and shippers generally keep close track of rail shipments of chemicals 

and can check to see where rail cars with chemicals are at any given time. But 

this information was not available to local government agencies in Graniteville on 

a real-time basis. Emergency teams rushed to the scene but had no information 

about the gases and fluids leaking from the railcars. Local residents were 

overcome by the gases, but when the rescuers took them to local hospitals, the 

doctors did not have information about the gases. 

When federal responders arrived to assess damages, most victims had already 

been taken to hospitals, so the responders focused most of their attention on fish 

in a stream that had been contaminated by liquids spilled from the rail cars. Nine 

people died – eight immediately – and many homes were ruined by the cloud of 

chlorine gas. 
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Local residents, agency staff and others may also need training and education in how to use 

communication technologies. 

Communications technologies will often be more effective when they provide geo-coded 

information that can be mapped. Social media may be very useful in providing opportunities for 

residents and small businesses that are sources of pollution to understand and learn how to 

manage risks. Cellular telephones are often a useful platform for such communication, as many 

residents of EJ/VP use them as a comparatively inexpensive way to gain access to the web and to 

receive text and voice messages. 

The development of communications technologies must go hand-in-hand with the development 

of monitoring and assessment technologies. Measurements of local conditions are meaningful 

only when they can be compared with thresholds that are built on scientific evaluation and that 

take multiple causes of risk into account. Experts at EPA and elsewhere are continuing to 

develop a sophisticated suite of analytic tools that should be accessible to EJ/VP communities 

through communications technologies, such as risk assessment, cumulative exposure assessment, 

life-cycle analysis, environmental footprint, ecosystem evaluation, decision support tools like 

cost-benefit and resilience analysis, and sustainability analytics. 

Examples of Needs for Communications Technologies in EJ/VP Communities

Residents need real-time information about concentrations of localized pollution that can 

peak at dangerous levels and about the steps they can take to reduce risks. 

Residents need technologies that can help them to avoid exposures and to protect 

themselves in their homes, backyards, parks, and neighborhoods—such as information 

from hand-held sensors of contaminated air and contaminated soils—as well as easilyunderstandable written, electronic, and face-to-face verbal information about how to 

protect themselves from environmental threats. With geo-coded sensors, residents could 

download information about the steps that they could take to reduce risks from indoor 

and outdoor air pollution.

Community groups and agencies need reliable, actionable data to provide real-time 

human-health warnings to residents about local environmental conditions and possibly 

notices to industry about any need for adjustments in emissions.

First responders and local hospitals need complete, real-time information in the event of a 

train derailment, major highway accident, or similar emergency release or spill event –

both to protect local residents and to ensure that first responders do not rush in without 

proper information and become contaminated themselves.
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3. EJ/VP communities need solution technologies.

What all communities want is technologies that solve problems resulting from releases of 

hazardous and toxic pollutants that impact human health and the environment at low costs and in 

short periods of time. 

In some cases, adequate monitoring and communication technologies can lead directly to the 

implementation of not-so-difficult solutions. Monitoring and communication may provide 

sufficient understanding of local problems and bring enough public as well as official attention to 

these problems to convince industry to take voluntary action to clean up or to persuade regulators 

to require cleanup to reduce human-health and environmental impacts in EJ/VP communities. 

Simply asking engineers to invest more energy in adjusting and managing manufacturing 

systems to reduce leaks and operate more efficiently can lead to big reductions in pollution

emissions and operating costs. And the process of mobilizing the community to gather data and 

attract attention can empower residents, teaching them skills that may open doors to economic 

and social opportunities. 

But in many communities, there are no easy answers. Many EJ/VP communities are located in 

brownfields where the soils, groundwater, and streams are seriously contaminated by decades of 

pollution. The contamination causes problems of indoor air quality in basements, backyards, 

parks where it is unsafe for children to play, and rivers where residents cannot safely fish or 

swim. Other EJ/VP communities have serious indoor air quality problems arising from 

substandard construction of homes and community buildings. In some communities, rising 

levels of groundwater cause mold and indoor air quality problems, or mobilize toxic pollution in 

contaminated soils. The direct dollar cost of clean-up of these properties and groundwater to 

safe levels is often very high. Clean-up approaching pristine levels is often unattainable. The 

economic and other costs to residents of EJ/VP communities and other vulnerable populations—

and to state and federal taxpayers—from human-health impacts is great and should be considered 

by decision makers. 

Some EJ communities across America are so contaminated, or so close to multiple sources of 

pollution, that they are not livable.22 For example, the best permanent solution for the Norco 

community in the chemical corridor of Louisiana along the lower Mississippi River was 

determined to be for industry to finance the relocation of residents to different, safer locations. 

EPA can play an essential role in sites like these, both in effectively deploying monitoring and 

communication technologies so that local problems are fully documented and understood, and by 

using its regulatory authority to ensure that appropriate action is taken to protect human health in 

these communities. 

But in other communities the challenge is to find solution technologies that are low cost and 

permanent. Too often, agencies and communities adopt policies that are not solutions at all -

such as moving wastes from one contaminated site to another, often to another EJ/VP 

community. 
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Two of our case studies suggest ways that EPA can help develop and deploy effective solution 

technologies. 

Indoor air quality in Pablo, MT

Salish Kootenai College (SKC) is a Tribal College located in the unincorporated 

community of Pablo, on the Flathead Indian Reservation in northwest Montana. 

SKC has about 1,100 students. About 76% of the students are Native American. 

The students come from 66 tribes and 20 states. SKC has a mix of traditional and 

non-traditional students so many of the students are older students and low income. 

Also, many of the Tribal students often have a family who has moved with them as 

they attend SKC so family members include children and sometimes elder members 

of the family.

The major environmental problem of focus is the mold in school buildings and 

student housing units on the SKC campus. One contributing factor to the mold 

problem is groundwater. In the summer of 2011 the staff at SKC began to notice 

mold conditions in a few buildings. They begin an evaluation of the severity of the 

mold condition. Samples of mold were sent to a lab for testing. The staff decided 

to have the student housing units tested at the same time. It was then that they 

discovered that there was a significant mold problem in the student housing units. 

Once the officials at SKC learned of the mold severity they moved the students out 

of the housing units and placed them in alternative housing.

 

In all technology categories it is recommended that community based resources be 

made available. Technical resources at the Tribal, County or City level would be 

ideal. In the absence of community based resources personal use technology is 

recommended. Technology needs include: Monitoring and Analysis (humidity 

sensors, test kits), Data Management and Communication (sending and receiving 

information once a problem is detected is critical. Who do you contact? How 

reliable is the information? Do I have to pay for it? What can I do to fix it? These 

are some questions a household may have. One suggestion made was a hotline. 

Such a hotline could be useful for a variety of indoor air quality issues.) Mitigation 

and Remediation (Simple inexpensive methods for fixing problems are needed as 

well as good reliable resources for contractors when a simple fix is not the answer.)
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EPA can contribute to finding solution technologies in five ways. 

One is to develop standards for the identification and cleanup of contamination by mold. Tribal, 

public, institutional, and rental housing is often not cleaned of mold that is causing health 

problems because there is no standard for when this should be done. 

A second is to conduct research and work with industry to develop new solution technologies for 

different kinds of pollution—e.g. mold-resistant paints and coatings, ventilation systems and air 

purifiers that can capture and bind mold spores so that they are no longer airborne, and 

remediation technologies for older buildings as well as different construction technologies for 

inexpensive new homes and community facilities. EPA‘s Office of Research and Development 

(ORD) could work with EPA program offices in systematic, on-going efforts to monitor efforts 

to address the typical problems that EJ/VP communities face and to support the most promising 

ideas. For example, it might be worth focusing ORD research on technologies to manage rising 

levels of groundwater in contaminated soils or in places where groundwater could damage 

buildings or cause mold to grow and create problems of indoor air quality. (Indeed, ORD and 

media offices may already do things like this.) 

Third, in addition to working with EPA media offices to develop new solution technologies, 

ORD should also work with other countries that are facing similar problems. ORD could play an 

active role in ensuring that technologies developed overseas are readily available to American 

communities by testing, publishing information about, and perhaps certifying technologies as 

cost-effective. 

Lower Passaic River, NJ: The Need for Solution Technologies

The lower Passaic River flows through dozens of municipalities into Newark Bay. 

The residents of these communities are generally working class or low income, 

80% are of various minority groups, and many are recent immigrants. The 

sediments of the lower Passaic include dioxins, mercury, lead, PAHs, and many 

other toxic industrial pollutants. Most of the fish in the river are too contaminated 

to be eaten. 

EPA, the state of New Jersey, and the New York Academy of Sciences have been 

studying the river for more than 20 years; but technologies to remediate the 

pollution are quite expensive, and no action has been taken to clean up the river 

and the bay. Several years ago, a study suggested that the river should be dredged

and that the sediments could be converted into a substance that would be a safe 

building material. The toxics in the blended ―cement‖ would be immobilized, 

using a technology ready for commercialization. This technology is being 

reviewed by experts in the US, with the hope that it will finally open the door to 

cleaning up the river. 
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A fourth way that EPA can contribute to finding solutions is to work directly with state, local,

and tribal agencies that have responsibilities for building and construction or for making 

decisions about the proper use of contaminated land or on wetlands. This could be done in 

partnership with other federal agencies that have the responsibility and legal authority for 

housing, construction standards, and related matters. EPA is already working with the 

Department of Housing and Urban Development and with the Department of Transportation, as 

well as with state and local governments, to encourage the development of ―smart,‖ compact, 

energy-efficient communities. EPA could take the same approach to finding solution 

technologies for EJ/VP communities. The Federal Emergency Management Agency, HUD and 

DOT would be important partners in such an effort. 

Fifth, EJ/VP communities will benefit not only from technologies that are targeted to meet their 

special needs but also from technologies that are needed by all communities, for example, cars 

with low (perhaps zero) emissions, healthier houses, inexpensive green infrastructure, and less 

polluting sources of electricity. EPA is already working on many of these technologies. 

In all cases EPA should seek permanent solutions through a transparent process with a defined 

timeline for installation of industrial solution technologies, so that confidence can be established 

between the agency and the EJ community. It is not acceptable to say that the environmental 

problems facing EJ/VP communities cannot be solved. The search for permanent solutions 

technologies should continue until solutions have been developed and deployed. 

Examples of Solution Technologies Needed by EJ/VP Communities

Closed-loop sustainable solution technologies.

Community/Soils: Technologies that can detect and confine hazardous chemicals so that 

edible crops can be grown on properly-designed urban farms in brownfields.

Chemistry/Indoor Air: Technologies to ensure high standards of indoor air quality in 

public and institutional housing in Native American communities and generally in lowincome communities across the country. 

Mold resistant and mold binding paints and coatings.
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C. RECOMMENDATIONS FOR GAME-CHANGING NEXT STEPS

NACEPT was asked to develop a list of needs for technologies to address problems in 

environmental justice communities and other vulnerable populations. Our report can provide 

initial answers, but to fully understand the needs and how EPA can meet them, ORD would have 

to work closely with EJ/VP communities themselves. 

ORD should also reach out to the business community, researchers in the private and public 

sector, and to other federal agencies. EPA-ORD recognizes that such an effort would be a 

departure from past practice. In September, 2011, ORD published an implementation plan for 

developing and deploying ―science tools‖ as part of EPA‘s Plan EJ 14. This report says that:

―presently, ORD lacks any mechanism for public input into its research agenda.‖ 

(p. 16) 

The September plan proposes greater efforts by ORD to work with EPA regional offices, the 

National Environmental Justice Advisory Committee, and others to reach out to EJ communities, 

both to inform ORD about conditions and needs in communities and to build capacity at the 

community level. Specifically, it says that ORD will:

work with OSWER‘s Community Engagement Initiative and similar efforts that other 

media offices develop to engage community stakeholders in ways that will help them 

participate in EPA decisions on topics of special concern to EJ communities; 

establish a workgroup within the National Environmental Justice Advisory Committee to 

advise the administrator and ORD about scientific research and health impacts related to 

environmental justice; 

support community-based participatory research;

engage EJ stakeholders in efforts like its Regionally Applied Research Effort program. 

(pp. 16-17)

Our recommendations are consistent with this approach and are designed to reinforce these 

efforts.

1. ORD should enter into partnerships with EJ/VP communities to develop and deploy 

these new technologies. 

Working with EPA regional offices and media offices, ORD should identify one or two ―pilot 

communities‖ in each region to be test beds for effective detection, monitoring, and assessment 

technologies that are the highest priority for ―game-changing‖ action. (EPA‘s EJ Showcase 

Communities and Community Action for a Renewed Environment – ―CARE‖ – communities

might be possible sites.) These communities should become models for deployment of 

technologies in other communities. The regional offices and state agencies should assist 

communities in identifying needed technologies. 

2. ORD should also establish a public-private task force to provide strategic advice and 

supplement ORD’s technical expertise. 
16

This task force should:

Compile an inventory of specific existing, cutting-edge, available-for-deployment

technologies that could effectively address the needs of EJ/VP communities and humanhealth and environmental regulatory agencies.

Identify specific technologies that are ready to enter the market as well as any legal, 

financial, or other barriers to the deployment of these technologies. 

Provide advice on incentives to encourage private development of needed technologies. 

Members of the task force might be drawn from:

Leading technology companies with experience in R&D, commercialization, production, 

and deployment.

Companies in the regulated community, as well as research institutes, academia, and state 

and federal human-health and environmental regulators with successful experience in 

effectively and transparently monitoring releases.

NGOs with experience in effective monitoring and communication technologies.

Staff in key EPA offices.

Experienced leaders from EJ/VP communities. 

EPA might wish to work with the National Academies to participate in or lead this effort.

3. EPA should reach out to other federal agencies to mobilize a multi-agency federal 

initiative to develop and deploy needed solution technologies, similar to EPA’s work 

with the Department of Transportation and Department of Housing and Urban 

Development in support of state and local efforts to build “smart communities”.

Several agencies in DHHS could be essential partners. 

4. ORD should publish a biennial update to EJ/VP communities about the progress of 

these activities.

This would include providing information about the needs for technologies and the pros 

and cons of newly emerging technologies to EJ/VP communities, EPA regional offices, 

state environmental agencies, interested partners in the private sector, and others.

5. EPA must also strengthen its own IT capabilities in order to support monitoring, 

reporting, and mitigation activities in EJ/VP communities. 

A separate paper explaining these requirements in some detail is available at 

http://www.epa.gov/ofacmo/nacept/reports/index.html. These requirements relate to the use 

of open interoperability standards to streamline both collection of measurements being 

generated by monitoring systems, and dissemination of data products derived from those 

systems. These standards range from general-purpose web services based upon the REST 

web service model (which in turn is based upon the HTTP standard protocol), to the suite of 
17

more specific open standards from the Open Geospatial Consortium (OGC) relating to data 

visualization (Web Map Service - WMS), data access (Web Feature and Web Coverage 

Services - WFS and WCS respectively), and sensor control and communication (Sensor Web 

Enablement - SWE). 

These services are the key components in the development of a services oriented architecture 

(SOA) that 

Lowers the barriers to data acquisition - decreasing the time required for collected data to 

be entered into the core management systems;

Provides a logical separation between internal data management systems and the clients 

that consume products that are based upon the contents of that system;

Enables publication of standards-based services that may be both used by EPA 

developers to provide specialized data access and visualization tools, but also may be 

used by external developers to provide custom mashups in support of specific user 

communities - particularly vulnerable populations.

EPA has initiated a number of programs that are developing these capabilities: EPA‘s ―Apps for 

the Environment Challenge‖, ―Environmental Dataset Gateway‖, ―Geospatial Data Download 

Service‖, and the ―National Geospatial Program‖ are all examples of programs that are making 

use of this SOA approach. What is needed within EPA‘s IT planning is a routine consideration 

and assessment of where interoperable services may be integrated into the development of new 

capabilities or updates to existing ones. 

CONCLUSION

EJ/VP communities are directly impacted by multiple environmental assaults, are more likely to 

suffer adverse health impacts from these exposures, and lack the power to change their 

situations. The technologies that we have identified as needed could help these communities 

begin a process of community-driven environmental change. With EPA‘s support, that process 

could result in solutions that could ―change the game‖ of environmental degradation and adverse 

health impacts that EJ/VP communities continue to face every day. We thank you for the 

opportunity to work with ORD and other EPA offices toward that end. We also wish to thank 

ORD, the Office of Environmental Justice, and the Office of Children‘s Health Protection for 

their assistance with this advice letter.

Sincerely,

/Signed/

James H. Johnson, Jr., Ph.D.

Chair

/Signed/ /Signed/

DeWitt John, Ph.D.

Workgroup Co-Chair

Mark A. Mitchell, MD, MPH, FACPM

Workgroup Co-Chair
18

Attachments: Table 1: Steps in the Community-Driven Environmental Change Process

NACEPT Vulnerable Populations Workgroup Member List

Endnotes

NACEPT EJ and Vulnerable Populations Case Studies

cc: Lek Kadeli, Acting Assistant Administrator, Office of Research and Development

Fred S. Hauchman, Director, Office of Science Policy, Office of Research and Development

Cynthia D. Jones-Jackson, Acting Director, Office of Federal Advisory Committee 

Management and Outreach

NACEPT Members 

NOTICE

This letter is the product of the National Advisory Council for Environmental Policy and Technology 

(NACEPT), an advisory committee created under the Federal Advisory Committee Act. NACEPT 

provides independent advice and recommendations on environmental policy, technology, and 

management issues to the Administrator and other officials of the U.S. Environmental Protection 

Agency (EPA). The recommendations in this letter reflect the opinions and views of NACEPT, and not 

necessarily the views or opinions of the U.S. EPA.

NACEPT‘s reports and advice letters are posted on the EPA website at 

http://www.epa.gov/ofacmo/nacept.
19

Table 1: Steps in the Community-Driven Environmental Change Process

Phase I: Problem Identification

First Step Second Step Third Step

Triggers

Fire, explosion, etc

Smoke

Odor

Proposed new or expanding 

facility 

Regulatory processes with 

public input

Unexpected releases of 

pollution

Public notice of potential 

hazard

Demonstrate Need for 

Change

Community test results

Government or academic 

testing

Emergency response

Release of report

Expert advice

Consciousness Raising

News media coverage

Leaflet/flyers

Word of mouth

Social structures 

schools/churches

Social media/computer 

networks

Public meetings

Phase II: Actions Phase III: Results

Fourth Step Fifth Step Sixth Step

Developing strategy

Information gathering

Convening 

Planning

Resource development

Consensus building

Communications

Coalition building

Logistics

Publicity

Actions/Tactics to build 

power

Petition 

Rally/protest/demonstration

Meeting with public 

officials

Letters to Editor

Press Releases

Give demands to polluter‘s 

reps

Community forums

Community learning 

sessions

Lawsuits/legal 

interventions

Responsive outcome

Negotiated change

Regulatory change

Legislative change

Other responsive process or policy 

change

Note: The items that are highlighted are places where better detection, monitoring, and 

assessment technologies are needed and can be effective. 
20

NACEPT Vulnerable Populations Workgroup

Dr. Karl Benedict

Director

Earth Data Analysis Center

University of New Mexico

Albuquerque, New Mexico

Dr. Ben Dysart

Principal

Dysart and Associates, Inc.

Nashville, Tennessee

Mr. Kurt Erichsen

Vice President

Environmental Planning

Toledo Metropolitan Area 

Council of Governments

633 Woodbine Road

Toledo, Ohio

Ms. Ella Filippone

Executive Director

Passaic River Coalition

Morristown, New Jersey

Dr. DeWitt John

Workgroup Co-Chair

Thomas F Shannon 

Distinguished Lecturer in 

Environmental Studies

Bowdoin College

Brunswick, Maine

Dr. James H. Johnson, Jr.

NACEPT Chair

Professor and Dean Emeritus

College of Engineering, 

Architecture and Computer 

Sciences

Howard University

Washington, DC

Dr. Daniel Kammen

Professor of Energy

Energy Resources Group

University of California

Berkeley, California

Ms. Vivian Loftness

Professor of Architecture

Carnegie Mellon University

Pittsburgh, Pennsylvania

Mr. Clayton Matt

Director of Tribal Services

Confederated Salish and 

Kootenai Tribes

Pablo, Montana

Dr. Mark A. Mitchell

Workgroup Co-Chair

President 

Mitchell Environmental Health 

Associates

Hartford, Connecticut

Ms. Jennifer Nash

Executive Director

Regulatory Policy Program

Harvard Kennedy School

Harvard University

Cambridge, MA

Ms. Arleen O'Donnell

Vice President

Eastern Research Group, Inc.

Lexington, Massachusetts

Ms. Kristie Orosco

Director of Environmental

Protection and Compliance

San Pasqual Band of Mission 

Indians

Valley Center, California

Dr. Edith A. Parker

Professor and Head

Department of Community and 

Behavioral Health

College of Public Health

University of Iowa

Iowa City, IA 

Mr. John T. Preston

Managing Partner

C Change Investments, LLC

Cambridge, Massachusetts

Acting Designated Federal 

Officer

Mr. Mark Joyce

U.S. Environmental Protection 

Agency

Office of Federal Advisory 

Committee Management and 

Outreach 

Washington, DC
21

ENDNOTES

 

1 US EPA 2003 Framework for Cumulative Risk Assessment, p. 39; NEJAC 2004 Ensuring Risk 

Reduction in Communities with Multiple Stressors: Environmental Justice and Cumulative 

Risk/Impacts; WHO 2006 Principles for Evaluating Health Risks in Children Associated with 

Exposure to Chemicals.

2

For example, respiratory disease is a common human-health problem affecting EJ community 

residents and other vulnerable populations. One of these is asthma which can be caused or 

exacerbated by hazardous/toxic chemical releases to the air and small particulates (PM10). 

According to a 2011 CDC report, the overall US asthma prevalence rate in 2009 was 8.2% (24.6 

million persons) and was disproportionately greater among children (9.6%), poor adults (10.6%), 

blacks (10.8%), non-Hispanic blacks (11.1%), the poor (11.6%), poor children (13.5%), and nonHispanic black children (17.0%). The CDC estimated total cost of asthma to society in the US, 

including medical expenses ($50.1 billion per year), loss of productivity resulting from missed 

school or work days ($3.8 billion per year), and premature death ($2.1 billion per year) was $56 

billion (2009 dollars) in 2007. See: Hatice S. Zahran, Cathy Bailey, and Paul Garbe, ―Vital 

Signs: Asthma Prevalence, Disease Characteristics, and Self-Management 

Education—United States, 2001-2009,‖ Morbidity and Mortality Weekly Report, Centers 

for Disease Control and Prevention, May 6, 2011, vol. 60, no. 17, pp. 547-552, 

http://www.cdc.gov/mmwr/preview/mmwrhtml/mm6017a4.htm?s_cid=mm6017a4_w.

3

―Bucket Brigade: Community Monitoring Tool Kit,‖ Global Community Monitoring website,

http://gcmonitor.org/section.php?id=138.

4

―The Bucket,‖ Louisiana Bucket Brigade website, 

http://www.labucketbrigade.org/article.php?list=type&type=4.

5

―Environmental Surveys—methane and H2S‖ (Picarro's CRDS Technology Methane analysis 

Southeast Louisiana January 2010), Chris Rella, January, 2010, 

http://www.scribd.com/doc/25927927/Picarro-s-CRDS-Technology-Methane-analysisSoutheast-Louisiana-January-2010.

6

―Community Based Odor Sampling Programs in the Bay Area,‖ Aug. 2, 2010, Don Gamiles, 

Argos Scientific.

http://www.baaqmd.gov/~/media/Files/Compliance%20and%20Enforcement/Compliance%20As

sistance/Odor%20Conf/Community%20Based%20Odor%20Sampling%20Programs%20in%20t

he%20Bay%20Area.ashx. 

7 Documentation of fenceline air-quality monitoring study involving ConocoPhillips San 

Francisco Refinery, Bay Area Air Quality Management District, and Community Working 

Group, April and May 2010, pdf file, (see Exhibit 2: ―Field services contract,‖ April 29, 2010—

pp. 8 through 18 of 37 and Exhibit 3: ―Memorandum of understanding: Enhancements to 

fenceline monitoring at Rodeo Refinery,‖ April 28, 2010–pp. 20 through 33 of 37), 

http://crgna.org/blog/wpcontent/uploads/2009/11/NOTICE+TO+COMPLY+CONOCO+PHILLIPS.pdf. 
22

 

8

―Chevron Renewal Project Neighborhood Air Quality Monitoring: Work Plan for 

Monitoring,‖ October 14, 2008, 8-pp. pdf file, 

http://www.chevron.com/products/sitelets/richmond/docs/work_plan_monitoring.pdf.

9

―Chevron Renewal Project Neighborhood Air Quality Monitoring: Work Plan for Monitoring,‖ 

October 14, 2008, 8-pp. pdf file, 

http://www.chevron.com/products/sitelets/richmond/docs/work_plan_monitoring.pdf.

10 ―Motor City Madness—How the  ̳Compliance‘ mentality is killing Southwest Detroit,‖ Denny 

Larson, Air Hugger, blog sponsored by Global Community Monitor, April 22, 2010, 

http://airhugger.wordpress.com/2010/04/22/motor-city-madness-%E2%80%93-how-the-

%E2%80%9Ccompliance%E2%80%9D-mentality-is-killing-southwest-detroit/

11 ―Quantifying Greenhouse Gases and Air Toxic Emissions: Technologies, Applications, and 

Verification and Validation Issues‖ and ―Forecasting National Management Expectations for 

GHG and Air Toxics Measurements: New Challenges and Needs,‖ John Bosch, June 2011, 104th

Annual Conference of the Air & Waste Management Association, Orlando, Fla. Promising new 

technologies include cavity ring-down spectroscopy,(CRDS) and others.

12 ―EPA ORD NRMRL: Research on Detection and Quantification of Air pollutant and GHG 

Emissions from Fugitive and Area Sources,‖ Eben Thoma, June 2011, 104th Annual Conference 

of the Air & Waste Management Association, Orlando, Fla.

13 ―Extending the Reach of Picarro‘s GHG Products,‖ Eric Crosson, June 2011, 104th Annual 

Conference of the Air & Waste Management Association, Orlando, Fla.

14 ―Recent Applications of Open-Path Monitoring to Measure Air Toxics & GHGs,‖ Steve 

Ramsey, ENVIRON, June 2011, 104th Annual Conference of the Air & Waste Management 

Association, Orlando, Fla.

15 See ―It's a Smart World‖, Special Report, Economist, November 6th 2010, pp. 1-2.

16 http://www.clemson.edu/media-relations/3903.

17 John C. Bosch, ―Quantifying Greenhouse Gas and Air Toxic Emissions: Technologies, 

Applications, and Verification and Validation Issues‖, prepared by J. Bosch Ltd, Raleigh NC for 

ENVIRON, June 2011, 104th Annual Conference of the Air & Waste Management Association, 

Orlando, Fla.

18―Science & Technology Foundations of Sustainability,‖ Paul Anastas, NACEPT Meeting 

November 14, 2011.

19 ―Graniteville, South Carolina train disaster,‖ 

http://en.wikipedia.org/wiki/Graniteville,_South_Carolina_train_disaster.
23

 

20 ―Train Wreck and Chlorine Spill in Graniteville, South Carolina: Transportation Effects and 

Lessons in Small-Town Capacity for No-Notice Evacuation,‖ A. E. Dunning and Jennifer L. 

Oswalt, Transportation Research Record: Journal of the Transportation Research Board, No. 

2009, Transportation Research Board of the National Academies, Washington, D.C., pp. 130–

135.

21 ―Railroad Accident Report: Collision of Norfolk Southern Freight Train 192 With Standing 

Norfolk Southern Local Train P22 With Subsequent Hazardous Materials Release at 

Graniteville, South Carolina January 6, 2005,‖ NTSB/RAR-05/04, PB2005-916304, Notation 

7710A, Adopted November 29, 2005, National Transportation Safety Board, Washington, D.C. 

20594, 59 pp.

22 See, for example, (1) Steve Lerner, Sacrifice Zones: The Front Lines of Toxic Chemical 

Exposure in the United States, The MIT Press, Cambridge, 2010; (2) Ronnie Greene, Night Fire: 

Big Oil, Poison Air, and Margie Richard’s Fight to Save Her Town, Amistad/HarperCollins, 

New York, 2008; (3) Steve Lerner, Diamond: The Struggle for Environmental Justice in 

Louisiana's Chemical Corridor, Urban and Industrial Environments series, The MIT Press, 

Cambridge, 2005; and (4) Barbara L. Allen, Uneasy Alchemy: Citizens and Experts in 

Louisiana’s Chemical Corridor Disputes, Urban and Industrial Environments series, The MIT 

Press, Cambridge, 2003. 
`

1.Graniteville Train Wreck

Ben Dysart 

Dysart & Associates, Inc.

Jennifer Nash 

Executive Director, Regulatory Policy Program

Harvard Kennedy School

2.Hartford Trash-to-Energy Incinerator

Mark Mitchell, M.D.

President, Mitchell Environmental Health Associates

3.Louisville Rubbertown Air Toxics

Mark Mitchell, M.D.

President, Mitchell Environmental Health Associates

4.Lower Passaic River & Newark Bay Restoration Projects

Ella Filippone

Executive Director, Passaic River Coalition

5.Toledo’s Dorr-Smead Brownfields

Kurt Erichsen, P.E.

Vice President of Environmental Planning, Toledo Metropolitan 

Area Council of Governments 

6.Tribal Environmental Health: Indoor Air Quality with an emphasis on 

Mold

Clayton Matt

Director of Tribal Services

Confederated Salish and Kootenai Tribes

NACEPT

National Advisory Council for Environmental Policy and Technology

CASE STUDIES

Environmental Justice and Vulnerable Populations

JANUARY 2012
Graniteville Train Wreck

NACEPT Environmental Justice / Vulnerable Populations 2/22

Case Studies

GRANITEVILLE TRAIN WRECK, AIKEN COUNTY, SC

A HUMAN HEALTH TRAGEDY IN GRANITEVILLE

Early on the morning of January 6, 2005, two trains collided in unincorporated Graniteville, SC. 

Five tank cars containing hazardous material were derailed: three car loads of chlorine—each 

containing 180,000 pounds of chlorine, one car load of sodium hydroxide, and one car load of 

rosin residue. One tank car exploded, releasing some 60 tons of chlorine gas. No warnings were 

given to sleeping residents living as close as 100 feet from the collision point except to shelter in 

place, which left the entire neighborhood subject to dangerous exposures. The accident would 

result in nine deaths and 554 residents sent to the hospital for chlorine inhalation treatment.

1

 

Residents would be evacuated, but their homes would be ruined from the gas cloud that hovered 

over the community. The immediate illness would later be determined to be a permanent 

debilitating condition for workers. Since the textile industry had already left for lower-wage 

countries, there was little reason to repair or reopen the mill once the explosion occurred.

The case illustrates the inadequacies of currently deployed sensing and communication 

technologies for community protection and regulatory response. It also points to several 

immediate and actionable recommendations for the US EPA. Adequate information, 

communications, and low-cost, on-site, ambient monitoring would have greatly improved the 

Graniteville response, reduced exposure, decreased long-term health effects, and saved lives. 

GRANITEVILLE AS AN EXAMPLE

Graniteville is one of three (Graniteville, Vauclause, and Warrenville) textile mill villages, 

collectively known as ―Graniteville,‖ abandoned by industry due to various political and 

economic circumstances which typify many small, rural communities throughout the Southeast 

and other areas of the US. These communities are typical of early industrial sites built along fallline waterways. Six Graniteville mills in these three communities are now being assessed or 

cleaned up via the EPA Brownfields Program and have additional local Special Option Local 

Sales Tax (SPLOST) funding to supplement these federal resources. However, the consequential 

impacts of the train wreck left behind in Graniteville—which include devastating health, social, 

and economic impacts—are only partially solved by these resources. 

The Graniteville, Vauclause, and Warrenville communities are examples of historic EJ and 

textile communities: located outside traditional community boundaries, they are left with 

minimal services compared with traditional communities such as police and fire protection, 

garbage pickup, schools, hospitals, and water and sewer service. They are isolated from 

shopping, schools, and the larger community. In operating mill communities, now a thing of the 

past, the mill itself provided most services; but as mills closed, these services disappeared. The 

history of disenfranchisement led to continuing isolation, as nearby communities, North Augusta 

and Aiken, never connected with these now-disconnected and disadvantaged neighbors. Now 

Graniteville is an area which can absorb suburban sprawl—which requires new infrastructure for 

 

1

 Railroad Accident Report: Collision of Norfolk Southern Freight Train 192 With Standing Norfolk Southern Local 

Train P22 With Subsequent Hazardous Materials Release at Graniteville, South Carolina, January 6, 2005, 

NTSB/RAR-05/04, PB2005-916304, Notation 7710A, Adopted November 29, 2005, National Transportation Safety 

Board (http://www.ntsb.gov/publictn/2005/rar0504.pdf)
Graniteville Train Wreck

NACEPT Environmental Justice / Vulnerable Populations 3/22

Case Studies

new populations—while continuing to ignore the needs of the original community. With the risk 

of substantial transportation-corridor exposure and substantial active or brownfield 

manufacturing hazardous or toxic releases, Graniteville is illustrative of thousands of other 

struggling, underserved, disproportionately impacted American communities and neighborhoods 

attempting to recover from their manufacturing history in the face of ongoing political and 

economic constraints. 

PROBLEM OF NO, INADEQUATE, AND NON-ACTIONABLE INFORMATION

Relevant, high-quality, and accessible data are the holy grail of environmental and human-health 

assessment. In Graniteville, no such data were available to indicate the timing, duration, areal 

extent, and magnitude of the toxic release. As a result, there was no reliable basis for estimating 

exposure of the nearby sleeping and sheltering-in-place humans. Eight immediate deaths that 

resulted from the chlorine gas cloud that early morning in January 2005 were just the beginning 

of the continuing human-health disaster that was to come. Formal inquiries determined that the 

well-meaning first responders from the local volunteer fire department had protective gear but 

failed to use it, which delayed evacuation of residents and victims and caused additional 

exposure. 

When federal responders arrived to assess damages to public health and environment, victims 

had been transported to hospitals in most cases. So regulators focused on next-available 

organisms: fish in the creek. The EPA utilized broad Comprehensive Environmental Response 

and Compensation Liability Act of 1980 (CERCLA) Emergency Response Authorities to address 

the environmental aspects of the spill only, concentrating on a spill to Horse Creek which caused 

a fish kill, rather than focusing on worker and community human exposure. Latent pollution 

from decades of mill operation was ignored in the EPA response, which could have created 

additional requirements for the past operators to clean up the facilities rather than leave it for the 

EJ community to figure out. The responsible party, Norfolk Southern railroad, was required to 

complete the necessary responses under federal law for the spill: at that point, Norfolk Southern 

had addressed the fish kill by providing 3,000 replacement fish in the Horse Creek and providing 

$100,000 worth of landscaping to address erosion problems along the stream bank as well as 

agreeing to some $4-million in Clean Water Act (CWA) fines and $32,500 in federal CERCLA 

response costs. 

TECHNOLOGY THAT COULD IMPROVE OUTCOMES FOR HUMAN HEALTH

Technology should immediately warn and advise the adjacent or downwind community, first 

responders, and local hospital emergency rooms, and document environmental releases for

residents and local governments, state environmental and health regulatory agencies, the source’s 

local and corporate senior management. Such technology provides the basis for (a) effective 

first-responder emergency response or—in the case of chronic, cumulative releases—informed 

responses by community leaders, (b) immediate evacuation or sheltering and effective treatment 

of exposed humans, (c) proper long-term medical treatment, (d) immediate threat and human 

exposure estimates as well as post-immediate-response modeling and characterization of the 

release, and (e) regulatory response as appropriate.
Graniteville Train Wreck

NACEPT Environmental Justice / Vulnerable Populations 4/22

Case Studies

Like flood damage due to elevated flows in a stream, risk to human health from permitted and 

un-permitted hazardous or toxic releases from mobile sources, regulated facilities, and other 

stationary sources is a function of magnitude, duration, and frequency. Inexpensive, credible, 

easy-to-operate, easily deployed technologies are required: technologies capable of providing 

solid, transparent data on the timing, frequency, severity, and duration of all unsafe and 

unpermitted air releases—even for only a few of EPA’s top-priority hazardous or toxic air 

pollutants—to which communities are regularly exposed. 

SENSORS AND SYSTEMS

Required are appropriate (a) sensors and (b) systems to interpret data gathered by sensors that 

take into account chronic long-term exposures and pre-existing health conditions common to 

vulnerable populations. Sensors should be reliable, cost-effective, easy to deploy, and suitable 

for local community residents to use and maintain. 

Three levels of technology are necessary:

1. Sensors, including devices able to detect releases of local sources—e.g., VOCs or 

benzene—as well as sensor arrays that can sufficiently characterize releases real-time to 

protect human health. Sensors should be located on mobile sources and in communities of 

vulnerable populations.

2.Continuous monitors utilizing sensors to detect any hazardous or toxic air release above 

permitted and safe levels. Continuous monitors should be located with the bulk hazardous 

or toxic material in transit as well as between EJ communities and transportation corridors 

and loading, unloading (including inter-modal), and storage facilities.

3.Communication systems to share real-time air hazardous or toxic release detection, 

quantification, and timing information with EJ community leaders and first responders, 

local hospitals, and environmental and health regulatory agencies as well as, if above an 

acceptable level, trigger timely deployment of more sophisticated sensor arrays and 

monitors to thoroughly document unsafe and unpermitted hazardous or toxic air releases 

reaching EJ communities.

SOLUTION TECHNOLOGY

While we are emphasizing sensing and systems, we aren’t ignoring the importance of solution 

technologies in achieving EPA’s mission of ―protect[ing] human health‖ and ―ensur[ing] that ... all 

Americans are protected from significant risks to human health ... where they live, learn and work.‖ 

Technically effective control technologies—in the sense of producing any specified output 

including air releases—have existed, now exist, and are being improved. But they must be 

deployed and then operated as intended. And someone—a regulator or someone else—must and 

does specify the expected and required level of performance which, in turn, determines the 

hazardous and toxic air releases and resulting human exposure.
Graniteville Train Wreck

NACEPT Environmental Justice / Vulnerable Populations 5/22

Case Studies

REGULATORY ISSUES RELATED TO EJ EXPOSURES ILLUSTRATED BY GRANITEVILLE

Lack of available, reliable, timely data—at the time of an incident—creates inherent weaknesses 

in regulatory response on the ground. These inherent weaknesses then manifest themselves 

throughout the aftermath of the incident—particularly as it relates to both the environmental and 

human-health impacts and remedy requirements—even until more detailed environmental and 

human-health studies are completed. 

As remedy requirements must be translated into an enforcement process, the initial inherent 

weaknesses due to lack of appropriate environmental and/or human-health data collection 

methods continue to plague the ability of the regulatory system to complete its own statutory 

requirements to impose duties on the responsible parties. This situation details why some agency 

officials are surprised when EJ communities (or other communities) attack EPA for leaving their 

community with continuing exposure and human-health problems. 

Through its Brownfield Program, EPA has had a role in addressing contamination issues that 

were not addressed appropriately during the regulatory phase. It was likely not intentional that 

they were not addressed: EPA just did not understand what should be addressed. On the dark 

side of the moon where EJ communities tend to be co-located with sources of hazardous or toxic 

air releases, if there are no data, there is no problem.

There are three areas that need closer examination to illustrate both the long-standing problem 

and the solution: (a) how the lack of data weakens the technical human-health and 

environmental impact assessment, (b) how a weakened technical assessment then further 

weakens the regulatory response, and (c) how data improvements and procedural improvements 

eliminate weaknesses and create a more scientific, rational, and fair approach for all 

communities—especially citizens who live in EJ and other disenfranchised communities.

CONCLUSION

An important challenge for EPA is the lack of low-cost, reliable, easily deployable technologies 

capable of providing real-time data about accidental and other non-permitted hazardous or toxic 

air releases to residents, first responders, and local governments in EJ communities. In 

Graniteville, the direct consequences of the lack of timely, actionable data included deaths of 

nine people, long-term health effects on many citizens, and severe economic dislocation resulting 

from the last operating mill’s closure. Those consequences underscore the vulnerability of 

disenfranchised EJ communities that have experienced decades of environmental exposures. 

Adequate real-time monitoring resulting from low-cost, simple, easily deployed sensors and 

systems will reduce the severity of the impacts of accidents and other non-permitted hazardous 

or toxic air releases when they occur and make possible more appropriate legal and regulatory 

remedies. 

While the technologies described here are indeed critical, the will to effectively deploy these 

technologies and act on the information they generate is even more important. 
Hartford Trash-to-Energy Incinerator

NACEPT Environmental Justice / Vulnerable Populations 6/22

Case Studies

HARTFORD TRASH-TO-ENERGY INCINERATOR

ENVIRONMENTAL PROBLEMS

There are variable emissions of toxins, including metals from burning of household trash, 

depending on what is being burned at a given moment, as well as how well the facility is 

operating. In addition, there are 10 or more fires and explosions each year. Even though peak 

emissions are the greatest health threats, emissions testing is only conducted once annually at the 

stack, presumably at times of ideal steady state conditions, and averaged over a period of several 

hours. These measurements are projected to be the same year-round to get annual emissions 

rates. Emissions variability with possible permit violations are not identified and communicated 

to the public or to regulators. There is no community monitoring of the emissions. The 

monitoring process and emissions results are suspect. 

EJ/VPS AFFECTED

Hartford, Connecticut is a city of 125,000 people, about 80% of whom are Black or Latino. It is 

one of the lowest income cities over 100,000 in the U.S. It is only 18.4 square miles in size and 

is the capital of Connecticut, the wealthiest state in the Union. The trash-to-energy facility, the 

Connecticut Resources Recovery Authority’s Mid-Connecticut facility, ranks in the top five 

largest facilities in the country, burning 2,850 tons per day of municipal solid waste. This waste 

is brought to Hartford from 70 municipalities to burn. 

NEEDED TECHNOLOGIES

Technologies for problem identification; technologies for problem assessment, analysis and 

communication; and/or solution technologies)

The community would like to have continuous emissions monitoring installed on the stacks 

of the incinerator that would have continuous readings of toxins including metals and 

dioxins over the internet and would indicate when permit standards are exceeded and 

provide text alerts to those who request it when there are major violations that may be an 

immediate threat to health. 

They are looking for low cost soil testing of dioxins surrounding the incinerator, 

They want portable ambient air monitoring devices for emissions tests that can be carried 

out by community residents and give immediate results. 

There could be a way to email or text information and photos of complaints and potential 

violations to regulators and other community members where they can be stored on public 

databases. 

They are looking for human biomonitoring testing of neighborhood residents of these 

metals and dioxins that is cost effective.
Hartford Trash-to-Energy Incinerator

NACEPT Environmental Justice / Vulnerable Populations 7/22

Case Studies

There is a need for the ability to test for the potential health effects of the multiple and 

cumulative mixture of chemicals to which people are exposed who live near this facility, 

the sewage sludge incinerator, oil fired power plants, highways, and other sources of air 

toxins.

RELEVANT CROSS-CUTTING ISSUES

Communications technologies that could send alerts to email subscribers may be new 

applications of technology that would be useful in the other cases. Low cost monitoring of 

dioxins in soil could be used in other Brownfields situations.
Louisville Rubbertown Air Toxics

NACEPT Environmental Justice / Vulnerable Populations 8/22

Case Studies

LOUISVILLE RUBBERTOWN AIR TOXICS

EJ/VPS AFFECTED

Rubbertown is an industrial zone in west Louisville, KY along the Ohio River composed of 19 

large plastics and petrochemical facilities in close proximity to low-income African American 

neighbors on the east and low-income whites to the south. 45% of the 3000 people living within 

a half-mile of these facilities have a household income less than $25,000. These facilities have a 

large number of accidental releases and mishaps with various colored smoke plumes, fires, 

odors, and explosions. The releases are of 35 or so mostly VOC’s, but also inorganic chemicals, 

metals, acids and bases. 

NEEDED TECHNOLOGIES

The companies and the City/County have a system of responses to releases. These include 

warning sirens, reverse 911 calling systems, and a 24 hour complaint hotline. Residents 

complain that these systems are often times not used or are used too late to be of use to the 

public.

Residents want handheld monitors to measure their neighborhood’s VOCs at low levels for short 

periods, i.e. over a few seconds in order to identify the chemical being released, identify the level 

of chemical exposure, interpret the health threat from each chemical release, be able to know 

what kind of health protective actions to take, and have information to hold government and 

industry accountable for any health threats.

The technologies needed are:

Real time air monitoring of air toxics - either at the fenceline or stack monitoring, that can 

be accessible on the internet and sent to regulators

Communications - allow alerts to be sent by phone and by text message to people at various 

levels and durations of releases to allow people to know when there are potential air toxics 

violations and when there are potential health threats.

Pollution control technology - need improved technologies for process management and 

end-of-stack controls to reduce toxics.

Biomonitoring to identify pollutants from local source exposure 

Handheld low-cost monitors for VOC’s that can be operated by community members

POSSIBLE TECHNOLOGY SOLUTIONS 

Develop new technologies; adapt technologies to address situations in EJ/VP communities; 

address barriers to the deployment of needed technologies.
Louisville Rubbertown Air Toxics

NACEPT Environmental Justice / Vulnerable Populations 9/22

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There is a need to develop low-cost portable immediate sensing devices that can be used by the 

community. Current tedlar bag grab sample ―bucket Brigade‖ technology is not sensitive 

enough, is not immediate with its results, and is still a bit expensive, although the price has 

declined recently.

RELEVANT CROSS-CUTTING ISSUES 

Cross cutting issues include needs for portable air toxics monitors, communications 

technologies, and biomonitoring 
Lower Passaic River & Newark Bay Restoration Projects

NACEPT Environmental Justice / Vulnerable Populations 10/22

Case Studies

LOWER PASSAIC RIVER & NEWARK BAY RESTORATION PROJECTS

LOCATION

Densely populated urban area in northeastern New Jersey

SPECIFIC ISSUE AND POLLUTANTS OF CONCERN 

Northeastern New Jersey has been at the epicenter of economic activity since the start of the 

Industrial Revolution over two centuries ago because its waters provide shipping access to the 

world. However, these activities have left a legacy of contaminants in the sediments of the 

Lower Passaic River and Newark Bay, which persist today. The most hazardous are dioxin, 

PCBs, and mercury. Dioxin has gotten into the shellfish and fish, and eating these fish can be 

very hazardous. Furthermore, most of the Lower Passaic River has not been dredged since the 

1950s, and dredging Newark Bay has become very expensive because of problems with 

disposing of the contaminated sediments. This means that many recreational, ecological, and 

economic benefits of the river and bay have been lost. Also, the river and bay have been filling 

up with more sediment, and flooding is worsening, and will get even more hazardous in coming 

years as sea level rises due to global warming. 

KEY PLAYERS INVOLVED

The following agencies are directly involved in carrying out these projects: US Environmental 

Protection Agency, US Army Corps of Engineers, US National Oceanic and Atmospheric 

Administration (NOAA), US Fish and Wildlife Service, NJ Department of Transportation, NJ 

Department of Environmental Protection, and Tierra Solutions, Inc. The residents and workers 

in sixteen or more municipalities in Bergen, Essex, Hudson, Passaic and Union Counties are 

being impacted by this pollution. Large percentages of this vulnerable population have low 

incomes, are African Americans or Hispanic, and are uninformed about how to protect them 

from the pollution. Some even eat crabs and fish from the river and bay.

TECHNOLOGY APPLIED

In 1984, a quarter century ago, the ―Diamond Alkali‖ site, which includes the properties at 80-

120 Lister Avenue in Newark as well as the contaminated Lower Passaic River and Newark Bay, 

was declared a Superfund Site. Although contaminants on the land side of the site have been 

partially contained, the sediments in the river and bay are still badly contaminated. Part of the 

Lower Passaic River Restoration Project (LPRRP), planning for an Early Action program for 

cleaning up the contaminated sediments in the lower eight miles of the Passaic River, has been 

ongoing since 2003.2 (See <www.OurPassaic.org> and <www.OurNewarkBay.org>.) Many 

 

2 Malcolm Pirnie, Inc. 2007. Lower Passaic River Restoration Project, Draft Source Control Early Action Focused 

Feasibility Study. Prepared for US Environmental Protection Agency, US Army Corps of Engineers, New Jersey 

Department of Transportation. June 2007. Executive Summary, page x. 
Lower Passaic River & Newark Bay Restoration Projects

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studies have been conducted and more are ongoing. Currently, the data collected in recent years 

is being modeled to estimate the distribution of dioxins and PCBs in sediments and biota in the 

river, bay and harbor under alternative clean up scenarios. In June 2009 a revised list of 

alternative scenarios for the Early Action program was suggested. 

The highest levels of dioxin are found in the sediments immediately adjacent to the shore of the 

old Diamond Alkali site. Occidental Chemical Corporation and Tierra Solutions, Inc., which 

have taken responsibility for the Diamond Alkali site, reached an agreement with EPA in June 

2008 to remove about 200,000 cubic yards of dioxin-laden sediment from the river in the vicinity 

of the site.3

For ten years the New York Academy of Sciences Harbor Consortium had studied contaminants 

in the New York/New Jersey Harbor. Four years ago the Consortium’s recommendations 

include the following statement:4

Cleanup of PCB-contaminated sites – particularly along the Passaic River – as well as the 

dioxin-contaminated Diamond Alkali Superfund site and its effects on the nearby Harbor, 

remains a (if not the) major priority. The Consortium has urged all litigating parties to 

focus their efforts on achieving early and effective action.

TRANSFERABLE TOOLS/STRATEGIES

Actions to clean up the contaminated sediments in the Lower Passaic River and Newark Bay 

have long been delayed for lack of a publically acceptable technology for dredged material 

management. However, today there is the Cement-Lock tool. Cement-Lock is a virtually 

odorless thermal-chemical technology that converts contaminated sediment and hazardous waste 

to Ecomelt®, a non-leachable, harmless beneficial-use product. When combined with cement it 

exceeds the ASTM requirements for Portland cement and concrete. Air pollution equipment for 

Cement-Lock facilities can meet or exceed the EPA’s 2014 compulsory air quality regulations. 

Demonstration of the effectiveness of this technology for these sediments could lead to cleaning 

up other sites in the US. An added high benefit is that the facility will also supply energy to the 

grid, establishing a significant beneficial use.

CHALLENGE

The Lower Passaic River and Newark Bay are critical parts of the New York/New Jersey Harbor 

Estuary, a hub of economic activity on the east coast of the United States. By dredging 

contaminated sediment from the river and harbor, and treating it on land so it can be used 

beneficially, both the ecologic and economic vitality of the region can be reinvigorated. A 

Regional Sediment Management (RSM) Plan, prepared under the auspices of the New York/New 

 

3 Kluesner, David, U.S. EPA, Region 2, Public Affairs Division. June 2008. EPA Signs Agreement with 

Companies to Remove Major Source of Passaic River Contamination.

4

New York Academy of Sciences Harbor Consortium. January 2008. ―Safe Harbor: Bringing People and Sciences 

Together to Improve the New York/New Jersey Harbor. Page 47.
Lower Passaic River & Newark Bay Restoration Projects

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Jersey Harbor Estuary Program, was released in October 2008, and makes the following 

observations:5

The RSM Plan is a long-term Plan with anticipated near-term economic returns. The 

Dredged Material Management Plan for the Port of New York and New Jersey estimates 

that achieving the goal of clean sediments throughout the harbor can save at least 

$25,000,000 per year in costs of maintaining our water transportation infrastructure. 

Other economic drivers for implementing the RSM Plan also include increased and 

improved opportunities for recreation, tourism, and fisheries – industries valued at over 

$20 billion per year that depend on a clean Harbor Estuary. 

These expectations are justified by the observation that elsewhere in the United States and in 

Europe significant cost savings and other benefits have resulted from RSM efforts. The 

implementation of projects to restore the ecologic vitality of the Lower Passaic River and 

Newark Bay is critical for restoring economic prosperity to this region! 

STATUS

Studies after study after study confirm earlier findings, but no action has been taken to ―restore‖ 

the Lower Passaic River and Newark Bay. The technologies are available to dredge most of the 

most hazardous legacy pollutants from the river and bay, and to decontaminate these sediments 

so they can be used beneficially. A land based treatment facility within the region would 

significantly lower costs and establish beneficial uses from the contaminated sediments. While 

this recommendation has been made frequently, the opportunity to pursue such a facility as a 

priority disposal project requires EPA’s attention now. The demonstration of the efficacy of the 

Cement-Lock process in New Jersey would encourage clean-ups in several parts of the United 

States where toxic pollutants are challenging the nation. The Corps of Engineers, Engineer 

Research and Development Center, published a report on dredging and environmental research 

entitled Mass Balance, Beneficial Use Products, and Cost Comparisons of Four Sediment 

Treatment Technologies Near Commercialization by Trudy J. Estes, Victor S. Magar, Daniel E. 

Averett, Nestor D. Soler, Tommy E. Myers, Eric J. Glisch and Damarys A. Acevedo., March 

2011. I strongly suggest that EPA take over where the Corps left off and contact the CementLock people to examine the commercial viability of their process. (W.A. Hendricks, 407-492-

9731) This case study should be brought to the attention of Administrator Jackson.

 

5

New York/New Jersey Harbor Estuary Program. 2008. Regional Sediment Management Plan, October 2008, page 

iv.
Toledo’s Dorr-Smead Brownfields

NACEPT Environmental Justice / Vulnerable Populations 13/22

Case Studies

TOLEDO’S DORR-SMEAD BROWNFIELDS

DESCRIPTION

Toledo has had a strong industrial base for the past century. The city grew rapidly due to its Lake 

Erie port, industrial resources, and proximity to Detroit. Toledo’s economy was based on 

manufacturing, especially automotive.

Toledo’s population peaked at 383,818 in 1970. By then the city was losing industrial jobs, a 

process that has since continued. By 2010 the population had dropped to 287,208. With 

departing jobs, the factories were abandoned. The remaining inner city is lower income with a 

high proportion of minority residents.

Many of the abandoned factories are now brownfields. The City of Toledo identifies 410 

brownfield sites covering a total of 1,927 acres, the majority which are concentrated in the innercity area. 

The subject of this case study is a group of three brownfield sites located near Dorr Street and 

Detroit Avenue. The largest brownfield was the Doehler-Jarvis Plant #1, a producer of die-cast 

automotive parts. The others are Craft House and Fernwood, which we identify as the DorrSmead brownfields. The abandoned buildings at several of the sites have been razed; other 

nearby abandoned or underutilitized buildings remain.

EJ/VP STATUS

A third of Toledo’s population resides in brownfield-impacted area, representing half of the 

impoverished population, and an unemployment rate 50% higher than the rest of the city. From 

1970 to 2000, 94% of the city’s population decline was in this area.

Several vulnerable populations are affected by the Dorr-Smead brownfields.

Lower income and/or minority neighborhood residents are vulnerable to exposure by 

hazardous materials. House fire sites are often contaminated by metals and PAHs, posing 

neighborhood exposure risks.

Children may have been particularly vulnerable to physical hazard at the sites.

Homeless persons: before demolition, abandoned buildings were occupied as shelter. 

Homeless persons taking refuge were subject to exposure to hazardous materials, to 

physical hazards from unsafe structures, and fires set for warmth.

Building material thieves: abandoned buildings and properties are subject to stripping for 

hardware and other salvageable materials. Those undertaking this activity are subject to the 

site’s hazards.

Food Deserts, which lack access foods necessary for a healthy diet, form in areas of low 

income households; households without cars; and without access to grocery stores. Urban 

agriculture can create a ―Food Hub‖ in that desert.
Toledo’s Dorr-Smead Brownfields

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POLLUTANTS

Asbestos, arsenic, TCE, VOCs, lead, and PAHs on brownfield sites pose risks to vulnerable

populations. In Toledo, ambient arsenic levels often exceed soil standards for residential use. 

Asbestos containing building materials were utilized when the factories were constructed. PAHs 

are associated with heavy end petroleum products, such as diesel fuel and oils, and are even 

components of asphalt. On some sites there were abandoned drums, which once contained 

undetermined materials.

Potential human health exposure pathways include direct exposure to materials or soils; through 

ingestion of vegetables or fruit grown in contaminated soils (see discussion below), through site 

runoff into streams; or through groundwater. A building constructed on a contaminated site could 

have indoor air contamination.

Indirect pollutants include: nonpoint source pollution, increasing phosphorus in streams, leading 

to Lake Erie harmful algal blooms. The difficulties of redeveloping brownfield sites creates an 

economic incentive to develop greenfield sites instead. Failure to redevelop brownfields 

encourages urban sprawl and nonpoint source stormwater pollution.

KEY PLAYERS

City of Toledo, the Lucas County Improvement Corporation (LCIC), Toledo Community 

Development Corporation (CDC), US EPA Region V, HUD, Ohio EPA, the Ohio Department of 

Development Clean Ohio Fund, the Center for Innovative Food Technology, the University of 

Toledo (UT), Toledo Grows, and Kansas State University.

Of the Dorr-Smead brownfields, Toledo CDC owns Fernwood, LCIC owns Doehler-Jarvis, and 

the City of Toledo owns Craft House. Toledo and LCIC coordinate site remediation and 

beneficial redevelopment with EPA and HUD; the Center for Innovative Food Technology, the 

University of Toledo (UT), and Toledo Grows are partners in developing urban agriculture for 

the site.

MECHANISMS

Brownfield assessment and remediation: conduct property assessments and remedial 

activities, including excavation and off-site disposal of contaminated materials. 

Ohio VAP: Ohio’s Voluntary Action Program (VAP) sets risk-based cleanup standards. While 

the VAP has not been fully utilized for Dorr-Smead, the program facilitates many cleanup 

agreements between property owners and Ohio regulatory agencies. Cleanup standards based on 

the end use: commercial/industrial, residential, or construction. The residential standard, based 

on physical contact with the soil, is the most protective.

Beneficial Redevelopment – Urban Agriculture: The industrial jobs in the area are not likely 

to return. Doehler-Jarvis had good rail access, but today freeway access is more important. The 
Toledo’s Dorr-Smead Brownfields

NACEPT Environmental Justice / Vulnerable Populations 15/22

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land must be used to benefit a changing community. EPA provides resources for agriculture 

projects through brownfield. The agency website offers numerous resources.

The Toledo CDC is redeveloping a brownfield as an urban agriculture business called the 

Fernwood Growing Center:

Promotes community revitalization and eliminates the attractive nuisance of abandoned 

buildings.

Provides the community with access to, and foster understanding of, healthy food.

Promotes stewardship for the environment and neighborhood.

Provides 25 jobs for community residents, in addition to supporting local businesses.

Makes the neighborhood a more attractive setting for additional redevelopment and new job 

creation.

Foster communications with lower-income and minority communities. There are wide gaps 

in understanding environmental issues between the federal level, state and local governments and 

their consultants, and the impacted EJ communities. Bridging these gaps of understanding is a 

challenge for any agency, but EPA may benefit from the experience of the US Census Bureau. 

The common thread is similarity in communities EPA and the Census Bureau strive to reach. 

Low income, minority, homeless, non-English speaking, or disenfranchised communities that are 

a challenge for the Census Bureau to enumerate may often be the same communities impacted by 

EJ issues. The Census Bureau found that outside partners could communicate more effectively 

than the agency. Examples include partnerships with cell phone companies for effective 

messaging; extensive and easy-to-understand use of social media, partnership with communitybased organizations, and market segmentation research to tailor messaging to various 

communities. The Census Bureau has conducted extensive audience research6and developed 

toolkits with materials culturally and linguistically targeted to specific audiences.7

TECHNOLOGIES

Identification Technologies

Develop brownfield data tools as cell phone apps to streamline and standardize data 

management site assessments. This tool could take better advantage of local knowledge for 

brownfields whose assessments call for neighbor interviews. 

Develop risk-based cleanup standards of soils for urban agriculture

Develop and deploy community-based programs for soil and groundwater contaminant 

testing. Emphasize low-cost and broad-capability mobile monitors. Use the results to 

empower residents to protect themselves.

 

6

http://2010.census.gov/partners/research/

7

http://2010.census.gov/partners/toolkits/toolkits-take10.php
Toledo’s Dorr-Smead Brownfields

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Communication Technologies

Promote effective communication between the community and local / state / federal 

agencies on safe urban agricultural practices.

EPA offers toolboxes throughout its website to provide resources and information on a 

wide variety of environmental issues. While they are useful, they are passive, depending on 

the community find out that they exist and use them. They tend to be top-down: they 

promote EPA goals and recommendations, and provide information EPA thinks the affected 

community needs. Interactive approaches could improve the effectiveness of providing 

information the affected community wants, and encourage broader use.

Inventory groups that have equipment and experience with these issues on the local level 

and among similar grassroots organizations nationwide. Facilitate training opportunities 

through video conferencing with two-way communication, and developing and deploying 

visually-oriented phone apps.

Focus training on community capacity building to help residents use technologies and run 

the small business urban agriculture

Establish overarching urban area brownfield / agricultural plans, identifying potential sites 

and community leadership.

Solution Technologies

Promote redevelopment of the community

Develop urban agriculture to provide safe and nutritious food to the community and 

establish a beneficial use for contaminated properties

Develop phytoremediation for remediation. Vegetation may be grown to uptake 

contaminants from soil; when harvested, the plant material removes contaminants from the 

site.

Multipurpose environmental benefit of remediation: clean surface and ground water, clean 

air, recycling neighborhood compost, and proving safe and healthful food.

STATUS

Successful with challenges for continued implementation. 

The City of Toledo and LCIC have used a $2 million brownfield revolving loan fund and 

other grants to remediate sites in Toledo.

Abandoned structures have been razed at all three of the Dorr-Smead Brownfields; 

remediation at Fernwood is complete. Numerous urban agriculture programs are benefiting 

Toledo neighborhoods; construction of the Fernwood Growing Center is planned.
Toledo’s Dorr-Smead Brownfields

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Planned food production includes aquaponics farming, where tilapia and an assortment of 

greens and herbs year-around will be produced in raised beds and vertical growing systems. 

Studies are planned for the Craft House site to test the soil for contaminants, and whether 

vegetables take up any legacy chemicals. The study will aid understanding of conditions 

under which these soils might be used for food production. Remediation standards exist for 

residential, commercial, and construction reuse, but not for urban agriculture. Urban 

agriculture standards are needed; such use may involve lower risk than residential. Safe 

levels of contamination for soils used for urban agriculture could be developed through a 

risk assessment.

Another outstanding question urban agriculture centers and brownfields sites is whether 

plants can absorb contaminants that may be in shallow perched groundwater. Groundwater 

may be deep enough that plants with shallow root systems — including most vegetables —

would not be affected. However, plants such as fruit trees and some fruit bushes, which 

have deeper root systems.

Under an EPA grant, Vita Nuova is developing an Urban Farming Planning Tool. Its 

purpose is to provide a business planning framework for distressed communities that 

surround brownfield sites, and provide TCDC with a business model.

CONCLUSIONS

Beneficial land redevelopment provides the driving force for brownfield remediation. EPA can 

set standards for cleanups, but economic factors make it happen. Redevelopment provides the 

economic incentive for remediation. Redevelopment creates jobs by putting property back into 

productive use. Job growth raises residents’ income, directly addressing the main cause of its 

being an Environmental Justice community. 

Partner with communications experts. EPA’s mission is to protect the environment, and should 

use strategic partnerships with state and federal agencies, local communities, and private 

companies who have closer ties to EJ populations or greater communications expertise. For 

example, EPA may benefit from the experience of the Census Bureau. The census faces 

obstacles communicating with disenfranchised communities; EPA faces similar obstacles 

communicating with EJ communities.

Communication is two-way. EPA should communicate with EJ communities to help these 

populations understand how the environment impacts them, and how citizens can protect 

themselves. But EPA should also use communication to understand EJ communities better, and 

fashion environmental programs and policies to meet those needs.

Programmatic cross cutting strategies with outside agencies can support EPA goals.

Residents may perceive that they belong to an EJ community, but not view environmental issues 

as key problems. Chronic environmental contamination that causes harm over a period of years 

is a lower priority than immediate, acute problems like crime, drugs, and unemployment. This 

case study illustrates the use of urban agriculture to address acute concerns by revitalizing the 

community while raising awareness of chronic environmental issues, and ultimately supporting
Toledo’s Dorr-Smead Brownfields

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Case Studies

brownfield remediation. Interagency agreements and coordination, and interagency staff 

assignments between EPA, CDC, and USDA can extend the effectiveness of EPA programs.
Tribal Environmental Health: Indoor Air Quality with an Emphasis on Mold

NACEPT Environmental Justice / Vulnerable Populations 19/22

Case Studies

TRIBAL ENVIRONMENTAL HEALTH

INDOOR AIR QUALITY WITH AN EMPHASIS ON MOLD

INTRODUCTION

This case study is an example of a problem that can be extrapolated to many Tribal settings and 

could easily be extended to many low income and minority housing environments. Additionally, 

while the emphasis is on mold, there are potentially several other issues that could follow from 

this example that are sometimes characterized as indoor air quality issues including lead, radon, 

CO2, pesticides and asbestos. Consequently, the National-EPA Tribal Science Council (TSC) 

has identified mold as a priority (http://www.epa.gov/osp/tribes/key.htm) and further links mold 

to health problems associates with asthma, also one of the TSC priorities.

LOCATION

Salish Kootenai College (SKC) is a Tribal College located in the un-incorporated community of 

Pablo, on the Flathead Indian Reservation in North West Montana. The census area for Pablo 

shows a population of about 2,000. The surrounding area has more people and is generally 

considered to be the ―Pablo‖ area of the reservation. Pablo is the location of the headquarters of 

Tribal Government of the Confederated Salish and Kootenai Tribes. There are also two other 

schools, one elementary school that is part of the Ronan School District, and one Tribal high 

school that also has a small middle school component. Also in Pablo, are two Early Childhood 

(head start and daycare) facilities, one located on or near the SKC campus, very near the location 

of the mold problems at SKC.

SKC has about 1,100 students. About 76% of the students are Native American. The students 

come from 66 tribes and 20 states. SKC has a mix of traditional and non-traditional students so 

many of the students are older students. Also, many of the Tribal students often have a family 

who has moved with them as they attend SKC so family members include children and 

sometimes elder members of the family.

ENVIRONMENTAL PROBLEM

The major environmental problem of focus in this example is the mold in school buildings and 

student housing units on the Salish Kootenai College campus. As will be discussed below, one 

contributing factor to the mold problem in this example is groundwater. 

For years officials at SKC have been aware of and have dealt with the problem of a groundwater 

table that is on the average 10 – 20 feet below ground level. They are also aware, and have 

monitored the seasonal fluctuation of the groundwater level. It comes up in August and 

September each year. However the winter of 2010 brought more snow and it snowed longer into 

the season than has been usual for the past decade or more and it also brought more spring 

moisture. This condition caused the water table to rise higher than recorded levels and it stayed 
Tribal Environmental Health: Indoor Air Quality with an Emphasis on Mold

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Case Studies

up for a longer period. The higher than normal groundwater table flooded basements and crawl 

spaces in buildings at SKC and in homes around the Pablo area. 

Prior to the flooding conditions SKC had also been noticing high moisture conditions in some of 

the building on campus. In the summer of 2011 the staff at SKC began to notice mold conditions 

in a few buildings. They begin an evaluation of the severity of the mold condition. Samples of 

mold were sent to a lab for testing. The staff decided to have the student housing units tested at 

the same time. It was then that they discovered that there was a significant mold problem in the 

student housing units. Once the officials at SKC learned of the mold severity they moved the 

students out of the housing units and placed them in alternative housing. At the same time that 

the mold condition was being discovered by the staff a few students were getting sick. 

The SKC student housing units were built in about 1994/1995. The units were built as energy 

efficient units. However during the mold investigations it was discovered that the wood walls of 

the units were built on the inside of the cement ―foundation‖ walls, which apparently are not 

foundation walls at all. This fact coupled with the high water table has, over the years, caused 

significant mold conditions and rotting of some of the wood walls that are in the ground, not on 

top of a cement foundation wall. During the assessment process SKC learned that for their 

situation the humidity levels in the housing units should be no more than 10 times the 

surrounding outside air. The actual humidity levels in some of the housing units were 30–50 

times the recommended levels.

Testing led to further analysis and a determination that the mold condition had to be cleaned up. 

SKC had to engage a contractor to help with remediation. The process is costing the school 

thousands of dollars and at the same time the school is being hit with an even larger expense 

associated with the remediation of the groundwater from campus buildings. At least one 

building has had groundwater in its basement most of the summer. In this building it was 

discovered that, when built, only part of the basement floor, the center part, was finished with 

cement. The ends were left exposed to the dirt. When the ground water levels came up this 

summer, continuing into the fall, the basement began to fill with water. The school has been 

pumping water at great expense since the start of the problem in August. This building also 

houses the school’s IT operations and many of the electrical units for this building are located in 

the basement. This has caused severe stress on the staff and the budget. 

EJ/VPS AFFECTED

Salish Kootenai College student housing has low income, Native American students, many with 

families. The families include children and in some cases elder members of the family. A 

facility like SKC, which is one of the best Tribal Colleges in the nation, attracts Indian and nonIndian students from all around the country. Because it is a Tribal College, it is relatively lowcost, attracting relatively low-income students. 
Tribal Environmental Health: Indoor Air Quality with an Emphasis on Mold

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NEEDED TECHNOLOGIES

An SKC official who is working to resolve the problems gave a good assessment of the 

processes that they have had to go through, that they are going through, and that they anticipate. 

Monitoring and Analysis

One suggestion that came out of this process was the need for humidity sensors. With the 

potential for mold in campus building and student housing, in an environment that may be 

conducive to mold, monitoring could be beneficial. If it is made simple and inexpensive it could 

be useful in households with similar potential problems. 

SKC has had to pay for expensive and time-consuming testing. The school is considering how 

they may use their on-campus environmental lab to assist with the testing in the future. They 

believe that they will need to do ongoing monitoring and testing as long as there is a potential 

problem. The problem is the expense of such testing. A normal household will not have the 

ability to afford it. One suggestion is a community-based approach to such testing such that a 

Tribe, county, city, state or federal program provides testing at the local level. Alternatively, it 

was suggested that a simple and inexpensive (or free) test kit might be useful at the school and in 

households to assist in identifying the problem. Maybe a test kit could be coupled with some 

kind if humidity sensor calibrated to a specific setting would provide the monitoring and analysis 

tools needed at the household scale. 

Data Management and Communication

Gathering data was critical to people living in student housing and students and staff in the class 

rooms. Data analysis gave SKC the ability to provide accurate information to students, staff and 

the public who might be concerned. Part of the process included learning about the various 

kinds of mold and how some are harmful and how some are not and how to communicate that 

information. At the household scale, a family may not have the ability to fully interpret such 

information and will need fast, reliable and accurate sources. This again should be localized. 

National-level data made available on the internet may be useful for some people but it will not 

be useful for most people who perceive a serious, possibly health-threatening situation. They 

will want to rely on local sources of information. In the absence of a community based solution, 

one suggestion that came out of this discussion was a hotline that someone can call to get fast, 

accurate and reliable information or suggestions for what to do, much like a poison hotline. Of 

course this could be applied to a variety of indoor air quality problems.

Mitigation and Remediation

Mitigation and remediation begins with proper analysis. If the problem is properly and 

accurately identified then the proper techniques and methods can be identified. If the analysis 

shows that the particular mold is not a threat then, quite possibly, little or no mitigation or 

remediation would be needed. On the other hand if the analysis shows a more dangerous mold 

then more specific methods can be used. 
Tribal Environmental Health: Indoor Air Quality with an Emphasis on Mold

NACEPT Environmental Justice / Vulnerable Populations 22/22

Case Studies

In this example SKC hired a contractor to clean the mold that had grown in the housing units and 

in the other campus buildings. They also have installed or they are planning on installing 

ventilation fans and air purifiers in the housing units. They are looking at replacing some of the 

material that the mold is growing on because some of the material is found to be a good source 

of food for mold. Humidity and food sources are key elements that must be considered.

In a household setting, most families in an EJ/VP community will not be able to afford expensive 

contractors. Education about how to avoid mold growth and how to deal with it once it is found 

will be critical. There is information, for example, on EPA web sites but a community based 

approach could be more affective in addressing local issues. Also in the absence of a community 

based approach, households will need to have access to inexpensive methods to mitigate or 

remediate for mold, and at the very least they need access to accurate and reliable information 

that can be easily applied to their particular circumstance.

LESSONS LEARNED

SKC has learned that proper construction techniques are critical in helping to avoid the 

conditions for mold growth. Prevention should be added to the list of categorical conditions. 

Building contractors should be concerned with such conditions and advise clients on proper 

construction techniques to avoid the problem. 

All activities associated with managing mold or other indoor air quality scenario begins with 

accurate data and the ability to understand it. Detection and analysis contribute to a final 

solution. Proper solution methods depend on knowing exactly what kind of problem is at hand. 

For most EJ/VP communities, much of the process is cost prohibitive. These communities need 

access to local sources for monitoring, analysis, mitigation, and remediation. In the absence of 

local assistance each household needs access to inexpensive tools and information that can assist

them in all phases.