What investigation has been done and will be planned to identify contamination to soil or groundwater beyond the property boundary? If so, when? If not, why not?

Remedial Investigation Reports must include delineation of contamination of soil and groundwater to be approved.  Soil impacts have been delineated across the Site and up to the fence lines, meaning soils impacts are not shown to extend offsite.  The RIRs for AOI-4 and AOI-9 were not approved due to need for additional offsite delineation of groundwater impacts.  Offsite wells have been installed beyond the... read more

Act 2 Standard, as presented in today’s presentation (August 27th Public Information Session), is being applied for statewide, and site specific. The presentation and presenter also reinforced the fact that the most stringent requirement must apply. If PA state’s lead standard in soil is 1000 ppm, why is Evergreen proposing a site-specific standard of 2,240 ppm, which is clearly twice the quantity?

The Site Specific Standard (SSS) was calculated using the updated Adult Lead Model and exposure assumptions recommended by the USEPA and the PADEP. The previous calculations used by the PADEP for lead were outdated; therefore, the PADEP recently used the same updated Adult Lead model to develop an updated non-residential lead direct contact MSC that reflects the current state of the science for lead.  The new... read more

These are very informative graphics (referring to the August 27th Public Information Session). What about removal of contaminants that are in the soil? Lead cannot be pumped out. All the soil must be removed.

Contamination in soil can be dealt with in many ways.  Some areas of soil impact have been excavated previously.  Soil remediation can also include institutional and engineering controls which eliminate a risk by blocking a pathway of exposure.  Remedial plans for all media will be detailed in the Cleanup... read more

Hilco has indicated in the Soil Management Report it filed with the City that the site-specific standard for lead required for the HRP intended uses for the site is 1,000 PPM. Will Evergreen remediate to this 1,000 PPM standard rather than the 2,240 PPM previously approved by PADEP?

Evergreen’s future cleanup plans will still compare all new soil data to both the statewide health and site-specific values to determine appropriate remedy selection.  In addition, Evergreen will reevaluate the current site-specific standard based on DEP’s proposed new soil standards and associated input... read more

These graphics (Evergreen note: assumption is reference to graphics from the August 27th Public Information Session relating to remediation) all show problems relating to gasses and water…not contaminated soil. Will soil be removed and replaced with clean soil?

The remediation systems operated at the site historically and currently were installed to address groundwater or vapors since those represented potential risk pathways, which is why they were shown during the August 27th Public Information Session. The purpose of the information session was to review historic reports which include mostly Remedial Investigation Reports.  Remedial plans for all media, including soil,... read more

Since Evergreen used an inappropriate standard as a basis for its remedial investigation reports, how does it justify that it has correctly defined the extent of lead contamination?

Remedial Investigation Reports must include delineation of contamination of soil to be approved.  This includes all analyzed compounds.  All compounds of concern were compared to their respective soil-to-groundwater medium specific concentrations, as illustrated in RIR data tables, and delineated to the direct contact medium specific concentrations in both surface and subsurface soil based on existing exposure... read more

The lead standard should be revised to be protective of public health. The standard that was approved (2240 parts per million (ppm) in surface soil) is much weaker than the default standard of 1000 ppm. The assumptions Evergreen used in calculating the standard are inaccurate and outdated.

The SSS was calculated using the updated Adult Lead Model and exposure assumptions recommended by the USEPA and the PADEP. The previous calculations used by the PADEP were outdated; therefore, the PADEP recently used the same updated Adult Lead model to develop an updated non-residential lead direct contact MSC that reflects the current state of the science for lead.  The new calculated proposed direct contact... read more