Besides the omission of my legal name and the inclusion of the 2007 FEMA report as a link ( here) rather than an attachment, this is a copy of the information that associates and I compiled today in relation to proposed reopening of Norrell Elementary School. After consulting with protest organizers Lillie Estes, Art Burton, and Mo Karn, we sent the report to some media outlets (with copies for organizers and other parties interested in helping out).

I’m including it here for the use and proliferation of anyone who wants it. The language is sort of dry and not particularly accessible, but I was working on a short time frame. I may be able to fix it up to sound less like a research report later, but for now, here it is.



The report:



Megan Walker, Jonathan Cunningham, and myself compiled the following information on Norrell Elementary. I’ve included a brief summary of results, as well as links to where we found each piece of information. All of the information was publicly available when we found it (9/4/2012). This is by no means a complete picture of the situation with Norrell Elementary, as it neglects statements made by school board members, direct testimony from area parents, a complete history of the site, and many other facets. For more complete information, speak to Art Burton and Lillie Estes.

Our findings establish that there were explosive levels of methane still being exuded from the dump site as late as 2006 (FEMA’s 2007 Report), that the Environmental Protection Agency lists A.V. Norrell Elementary School as an ‘active’ candidate for the National Priorities List of contaminated sites (Superfund Site Information Database), and that the conditions at Norrell stand to violate the Head Start Program’s Environmental Requirements. Additionally, despite some claims from School Board members, Parks and Recreation has never listed the school as the site of a community center or community program.

The most recent environmental survey of the site available to the public was the FEMA report in 2007, reflecting conditions in 2006. There exist no more recent investigations available to the public online.



These sources, and the absence of more recent data, suggest that the dangers of Norrell have not been addressed in any way since its closing in 2006. Beyond the obvious physical dangers of the site, which were very much present in 2006 with no evidence that they have been resolved since, Richmond Public Schools could stand to lose Head Start funding should conditions violating the requirements be rediscovered



The following report includes a description of, and select quotes from, the source materials.



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FEMA’s 2007 Report



The most extensive description of the area that Norrell is built on can be found in the attached PDF file, Federal Emergency Management Association’s 2007 report of the condition of Battery Park and surrounding areas. This report was compiled after the 2006 sewage pipeline burst, in order to propose methods of correction. Page 15 of the report, discussing groundwater, describes the Fells Street Dump:



“Because the Fells Street Landfill is not lined and capped according to current regulations, rainwater and contaminated leachate permeates through the soil and MSW materials in the proposed project area. Assumed leachate was observed repeatedly in the fall of 2006 excreting from the toe of the southern slope of the Fells Street Landfill near Bacon’s Quarter.”



The report goes on to detail the content of the leachates likely exuding from the landfill, and to describe how long the landfill would have been leaching contaminates into the soil and groundwater:



“The typical quality of leachate from solid waste includes heavy metals such as arsenic, barium, boron, cadmium, chromium, copper, iron, lead, manganese, mercury, selenium, silver, and zinc. This information on leachate quality was published after studying leachate collected both from landfills in operation prior to and after promulgation of regulations for solid waste landfills (FEMA, 2006a). It is assumed that such contaminants would be found in the Fells Street Landfill as well. The soils in and around the Fells Street Landfill have presumably been leaching contaminants into the groundwater since the landfill was established.” (page 16)



The most damning results of the report, however, relate to landfill gasses. The description of the history of the landfill in relations to problems with gasses begin at page 18, section 3.5, titled Air Quality. The report describes the findings as of 2006:



“Based on the results of the borings performed in the area of the proposed work, it appears the presence of landfill gas is at levels approaching the lower explosive limit (LEL), which is 5 percent methane by volume, and was as high as 24 percent methane by volume—nearing the upper explosive limit (UEL). Although there has been a gas extraction and collection system in place since 1977, it is unclear if that system is still operational today (FEMA, 2006a).”



The report concludes “It is, therefore, expected that landfill gas is still an issue of concern for the Fells Street Landfill, and specifically for the proposed activities.”



FEMA Battery Park Repair News Release



The FEMA report on the Battery Park sewage pipeline repair ( http://coop.fema.gov/news/newsrelease.fema?id=37881 ) describes the landfill as “posing considerable obstacles” to the repair of the system. This corroborates the above report, which describes the concentration of methane gas at explosive levels.



Superfind Site Information Database



The EPA’s database of Superfund sites lists Norrell Elementary ( http://cfpub2.epa.gov/supercpad/cursites/csitinfo.cfm?id=0305869 ) as a candidate for the National Priorities List for cleanup- it was added as requiring investigation in 2002, and as of 2012, the database lists a screening investigation as 'ongoing’. The EPA ID number of the site is VAN000305869 . Because no end date for the investigation was ever published, it appears that the investigation of Norrell never occurred, although this database confirms that the EPA was interested in evaluating the site for Superfund eligibility. The site remains listed for investigation because it was never exonerated.



This search result ( http://cumulis.epa.gov/supercpad/cursites/srchrslt.cfm?start=1&CFID=10893526&CFTOKEN=33348554&jsessionid=e0309018a631e5293e7f3f4e2b5b745b5f57 ) within the EPA website reveals that Norrell is, in fact, an 'active’ site, as opposed to 'archived’- meaning, investigation or remediation is ongoing or yet to happen. In other words, the EPA does not consider the site a closed case.



Because the site was slated for investigation, but not listed as an NPL site as of 2002, it appears that the EPA has not updated its stance on Norrell in ten years- it can’t be dismissed from consideration until an investigation clears it. That investigation apparently never occurred.



We have requested a more detailed report from the EPA- this should resolve what actions, if any, the EPA took upon identifying Norrell as a potentially toxic site. It should arrive in two to three weeks.



The Head Start Program’s Environmental Requirements



The Head Start Program, through which the preschool program being moved to Norrell receives federal funds, lists stringent environmental requirements in their building guide, specifically on page 40 of the document ( http://eclkc.ohs.acf.hhs.gov/hslc/hs/resources/eclkc_bookstore/pdfs/head%20start%20%20design%20guide%20–%20second%20edition.pdf ). Some of those requirements include “The center should be located away from hazardous conditions or sites … The site, including the playground, should be certified as free of these contaminants before design begins.”



The requirements speak specifically to air quality: “The center should not be exposed to fumes or dust from industrial operations and vehicles, furnace and incinerator exhaust, mists from cooling towers, or similar pollutants. Avoid placing centers near exhausts from food processing and waste handling operations, loading docks, or similar sources of unpleasant odors.”



It is worth noting that methane has a strong odor.

10:25 pm • 4 September 2012 • 4 notes