Murphy DEP Commissioner Suppressed Rutgers Study That Documented Extraordinarily High Levels Of Lead In Trenton Homes
EPA Urged To Broaden Remedial Investigation And Sample Human Blood Levels
Trenton Residents Are Being Poisoned In Their Homes
DEP Knows That The Extent Of Lead Contamination Is Far Larger Than EPA's Superfund Designation Of East Trenton
In a June 12, 2024 letter to US EPA (see above), NJ Department Of Environmental Protection Commissioner Shawn LaTourette nominated the East Trenton lead contamination site for listing on the Superfund National Priorities List (NPL).
LaTourette wrote:
Due to the public health and environmental risks associated with lead contamination and given the significant scope of investigation and remedial action anticipated, NJDEP believes that it is necessary and appropriate for USEPA to propose the Historic Potteries for inclusion on the NPL.
But Commissioner LaTourette withheld critically important DEP science and data that demonstrated that the lead contamination issues were far worse than EPA was aware of - including extraordinarily high levels of lead DEP found inside homes and in an area of Trenton far larger than the EPA studied East Trenton neighborhood. (see:
(caption: Source: USEPA)
To put those Rutgers indoor lead levels of 3,488 ppm (mg/kg) in context, consider the fact that EPA conducted an “emergency removal action” at outdoor soil contamination levels half those found inside Trenton homes: (see this EPA memo report)
EPA collected a total of 408 composite soil samples, including field duplicates, from 69 sampling locations throughout the sampling area. The analytical results indicated lead levels exceeded 400 milligram/kilogram (mg/kg), 1 the applicable EPA Removal Management Level (RML) at the time, in 291 of the 408 samples. Lead levels exceeded 1,200 mg/kg at 26 of the 33 properties sampled. Overall lead levels above the EPA RML were found at all properties sampled, except for one property located upwind that was sampled to establish background levels. Despite the discovery of elevated concentrations of lead in the East Trenton neighborhood, the RSE documented several reasons why the contamination was not attributable to the L.H. Mitchell facility (Attachment 1).
I just wrote to EPA Region 2 Regional Administrator Martucci to inform him of this NJ DEP suppression of the Rutgers study and to urge him to expand the pending EPA remedial investigation to consider:
1) lead levels and lead exposures and risks INSIDE homes;
2) statistically representative blood lead levels of Trenton residents. This is scientifically justified by the documented pervasive lead contamination throughout the Trenton community (indoor, outdoor, and in drinking water) and the fact that there is no threshold for adverse health effects; and
3) to conduct a broader sampling program than currently exists to determine broader lead levels that warrant a broader designation - beyond the geographic boundaries of the currently designated AOC - based, on a minimum, the Rutgers study data (but EPA should conduct additional sampling prior to scoping the RI).
4) to conduct public hearings in Trenton, a DEP designated environmental justice community, on the scoping of the remedial investigation.
---------- Original Message ----------
From: Bill WOLFE <>
To: "Martucci.Michael@epa.gov" <Martucci.Michael@epa.gov>, "Evangelista.Pat@epa.gov" <Evangelista.Pat@epa.gov>
Date: 07/10/2025 1:08 PM EDT
Subject: East Trenton Superfund designation
Dear EPA Region 2 Regional Administrator Martucci:
I am writing to bring a DEP scientific study and data to your attention that is relevant to the recent EPA Superfund designation of the East Trenton site.
The study was conducted by the Rutgers Environmental and Occupational Health Sciences Institute, circa 2006. It was designed to assess, among other things, Trenton lead levels ad human exposures. That study found outrageously high levels of lead inside homes (a 3,488 ppm, mean value) see Table 5 on page 33:
That DEP contracted Rutgers study also documented high levels of lead in soils and inside homes and schools in an area of Trenton that is far broader geographically than the East Trenton neighborhood "area of concern" (AOC).
See my letter below to NJ DEP Commissioner LaTourette.
I understand that the EPA HRS screening was limited to outdoor soil exposure potential. That alone was sufficient to exceed the 28.8 HRS threshold for NPL listing, so other routes of exposure were not considered, at this time.
I also understand that EPA is now developing a scope of work for the remedial investigation.
Accordingly, I request that EPA broaden the scope of the remedial investigation to include:
1) lead levels and lead exposures and risks INSIDE homes;
2) statistically representative blood lead levels of Trenton residents.This is scientifically justified by the documented pervasive lead contamination throughout the Trenton community (indoor, outdoor, and in drinking water) and the fact that there is no threshold for adverse health effects; and
3) to conduct a broader sampling program than currently exists to determine a broader lead levels that warrant a broader designation - beyond the geographic boundaries of the currently designed AOC - based, on a minimum, the Rutgers study data (but EPA should conduct additional sampling prior to scoping the RI).
Additional scientific bases for a broader area designation are found in the EPA HRS document, which analyzed: a) historic air emissions from manufacturing, the location of the kilns along the east and west banks of the D&R Canal, prevailing wind patterns, and atmospheric deposition; and b) leaching from lead contaminated ceramic pieces that were used as fill during development. The EPA HRS stated:
"The number of pottery kilns in Trenton increased from 1 to 258 between 1852 and 1903. Depictions of the Trenton kilns show smoke emanating from their stacks and moving with the wind; lead would have been released in these kiln emissions and then settle into the soil downwind from the kilns (the prevailing wind direction in Trenton is northwesterly, and a large majority of wind direction is distributed across the western half from northerly to southerly). Soil and debris containing ceramic pieces that was used as fill material during development of the residential neighborhoods is also adding to the lead contamination.
EPA found lead to be one of the most leachable metals from the ceramic chips, indicating that leaching of lead from the chips over time is one of the mechanisms of soil contamination. …
Results for the Grant Intermediate School, where there are 542 students and 45 full-time faculty members, show lead concentrations more than three times above background levels in several grass- and soil-covered areas on school grounds."