How do DEP and Evergreen determine what is safe?

This question was sent to PADEP who provided the following response: DEP establishes Act 2 Statewide health standard cleanup values for soil and groundwater, known as Medium-Specific Concentrations (MSCs), using a variety of risk- and health-based methods. For instance, many groundwater MSCs are adopted from U.S. EPA’s drinking water standards. Other MSCs are calculated by DEP to protect human health at... read more

But the state of PA actually uses a blood lead level double what the federal CDC updated in 2012.https://www.cdc.gov/nceh/lead/data/blood-lead-reference-value.htm

This question was sent to PADEP who provided the following response: DEP’s published Statewide health standard nonresidential direct contact numeric value for lead in soil, 1000 mg/kg (milligrams lead per kilogram soil), was based on a target blood lead level in adults of 20 mg/dL (micrograms lead per deciliter of blood). Evergreen derived a site-specific direct contact numeric value in their 2015 risk... read more

It may have been more effective if this presentation was made available a week ago and we could have spent these two hours asking pertinent questions, such as: 1. what are the critical paths for considering the risks of lead and benzene to the adjacent communities; 2. how are increased climate-change risks being assessed; 3. how is ground and surface water run off being considered in the plans; 4. how is Hilco assessing the additional risks of (what looks like will be) hard scape pavement of 85-90% of the site?

1- The route of exposure (or risk pathway) identified for adjacent communities would be potential indoor or outdoor air impacts from dissolved groundwater plumes that migrate offsite.  However, initial assessment did not find any potential impacts to off-site residences from the conditions in shallow groundwater.  This will be further evaluated after the contaminant fate and transport model is completed.  Any... read more

Is soil tested to a depth greater than 2 feet deep?

Yes, soil is tested at many depths.  We showed the soil data results in two different slides: 0-2 feet below the surface and anything else collected from greater than 2 feet below the surface.  That’s because the standard concentrations that we compare our data to are different for surface soil (0-2 feet) and subsurface soil (2-15 feet, or... read more

If residents are going to invest time & energy in providing our comments, we need to know that there will be responsiveness to the comments- and they won’t just sit on a website (thank u for the website btw!). Specifically: can “approved” reports that didn’t have public input until now be reopened and revised based on public comments that find any inadequacies in the reports? Otherwise what is the point of us commenting?

Evergreen is in the process of receiving questions from the public concerning the approved Remedial Investigation Reports. These reports will be revised if new information is found concerning the conclusions of the Remedial Investigation Reports. The comments received during this phase will also inform the future Act 2 phases, which have yet to occur at the site. These include the Fate and Transport, Risk... read more

How much more information do you need to complete the fate and transport model?

We believe we have sufficient information to complete the model.  However, we need to have agreeance on that from DEP prior to submittal. In other words, all of the Remedial Investigation Reports must be approved first (meaning, that DEP feels we have sufficiently defined the contamination so that a model can be accurate and complete).  Once the RIR Addendums for AOI’s 4 and 9 are submitted and approved, the... read more

Climate change-generated sea-level rise (Schuylkill, Delaware) is a given. There are already models out there. What range of values in feet are Evergreen assuming for 2050, and 2100?

Evergreen has yet to complete the contaminant fate and transport assessment for the facility and currently has a working groundwater flow model that is calibrated to recent, average sea level in the Schuylkill River estimated from a local tide gauge. The magnitude of sea-level rise has not yet been selected for evaluation in the modeling and is pending a literature review of available resources and initial modeling... read more