The ability to calculate a site-specific standard (for any media) is a provision in the Act 2 regulations and is not the only one allowed, but is common practice and one of the three options for standards that can be applied to a site: Statewide Health, Background, or Site-Specific. Other non-residential sites can also calculate a Site Specific Standard if they choose to do so for their Act 2 projects. This... read more
Why did you choose such a high site-specific standard, and do you plan to keep it that high?
Posted by Tiffani Doerr & filed under .
The approach used to calculate the SSS for direct contact was to use the Adult Lead Model recommended by the EPA. The PADEP used the same model to develop an updated non-residential lead direct contact MSC that reflects the current state of the science for lead. If the PADEP changes PADEP’s assumptions related to lead, such as permissible blood lead levels, Evergreen will update the SSS accordingly. The SSS for... read more
1)We are concerned about lead in surface soil. The standard Evergreen has proposed does not address the risk. 2) Evergreen has not obtained approval from DEP for remedial investigation reports for several of the more contaminated areas of interest. Including the aquifer. 3) The work done so far does not consider the impacts of climate change, rising sea level and worsening storms. Note: for the purpose of response, this comment was split into three topics by Evergreen.
Posted by Tiffani Doerr & filed under .
1)The site-specific standard for lead was approved by both PADEP and EPA and utilized the updated Adult Lead Model and exposure assumptions recommended by the USEPA and the PADEP. As part of the remedial investigations, the lead data was compared to the Act 2 SHS MSC, which is 450 ppm, based on the soil to groundwater pathway. This comparison is shown on the figures/tables in the RI Reports and in the 8/27/20... read more
The speaker (during the August 27th Public Information Session) said that the remedial investigation reports have to be approved before Evergreen does risk assessments. Since this hasn’t happened yet, why did Evergreen already complete the risk assessment for lead in soil?
Posted by Tiffani Doerr & filed under .
In order to determine risk to human or ecological receptors associated with contamination in soil or groundwater, the extent of the contamination must be known/defined for accurate calculation of risk. The calculation of the lead Site Specific Standard for shallow soil used risk-based calculations utilizing the updated Adult Lead Model and exposure assumptions recommended by the USEPA and the PADEP. This... read more
Similar questions: 1) Can you comment on why AOI 11 deep groundwater report has not yet been approved?” 2) AOI 11 has deep aquifer contamination that was not accepted by the DEP. Please discuss the extent of pollution, its evaluation and anticipated cleanup timeline.
Posted by Tiffani Doerr & filed under .
There were both an AOI 11 Remedial Investigation Report and a Final Report that were submitted. Both were disapproved solely for the fate and transport analysis that was included in the reports. The remedial investigation portion of those reports were acceptable. Note that before we started a site wide model concept, each of the AOI reports had separate individual models completed, and we have since updated that... read more
When will Evergreen conduct the fate and transport analysis for the lower aquifer? There is no aquitard between upper and lower aquifer across most of the site. Won’t the heavily contaminated shallow aquifer gradually leach contaminants into the lower aquifer? (a critical drinking water source for New Jersey)
Posted by Tiffani Doerr & filed under .
The fate and transport analysis for the lower aquifer will be performed once the Remedial Investigation Reports for AOI 4 and AOI 9 have been approved. Areas beneath the Site where connections exist between the lower aquifer and water table aquifer are less extensive than the areas where we have that important clay layer present. The cross section shown during the August 2020 Public Information Session was just... read more
Is the water table or the lower aquifer the source of drinking water for anyone?
Posted by Tiffani Doerr & filed under .
The water table and lower aquifers are not utilized as sources of potable water in proximity to the Site. As a part of the investigations, Evergreen conducted a well search within a one-mile radius of the Site using Pennsylvania’s Groundwater Information System (PaGWIS) and PADEP’s eMapPA GIS mapping tool. Results of the search, which included field reconnaissance, indicated a low probability for potable water... read more
Air monitoring has been done on site to see if vapors were present in refinery buildings or the surrounding air. When will this investigation of air quality be extended to surrounding areas, slash neighborhoods?”
Posted by Tiffani Doerr & filed under .
As part of the Act 2 program, Evergreen evaluates potential air quality effects from subsurface conditions (as opposed to any air quality issues from above-ground operations). The evaluation of any vapors to indoor and outdoor air from a dissolved plume beneath the subsurface is part of the evaluation required by Act 2 and will be included in future Act 2 reports, submitted upon completion of all Remedial... read more
I would also like to know your plan for holding Sunoco responsible for the decades of destructive pollution they caused in our city. This pollution has had direct impacts on community health in the surrounding neighborhood and has fueled the devastating climate crisis now impacting us all.
Posted by Tiffani Doerr & filed under .
Sunoco is responsible for cleaning up soil and water contamination generated prior to the sale of the facility in September 2012. Evergreen is managing this... read more
In today’s presentation (August 27th Public Information Session), a summary of the content within RI reports was provided. If source, extent and pathway of contaminants is discovered to have conveyed contaminants beyond the beyond the property boundary which legal entity is currently responsible for impact study costs and remediation costs?”
Posted by Tiffani Doerr & filed under .
Act 2 requires that the Remedial Investigation Report defines the extent of contamination, including beyond the property boundaries. Two of the RIRs were not approved for that reason, which is why they required additional offsite work to further define the full extent of contamination in those areas. Any entity causing a release is responsible for the investigation and remediation of that... read more