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.

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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

What sea level rise, if any, was the tide gate built to accommodate?

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Tide gates are a common flood prevention structure for areas in a tidal zone. Tide gates close during incoming tides to prevent inundation from downstream water propagating inland, and they open during outgoing tides to drain upland areas. The tide gates at the Site were not specifically designed to address sea level rise; however, the Site will continue to be regulated under the stormwater management requirements... read more

Will Evergreen be incorporating climate resilience into its groundwater modeling?

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A literature review of available, published resources on climate change for the Philadelphia region and discussion of the potential implications to Evergreen’s groundwater model will be included in the upcoming Fate and Transport RIR.  Evergreen’s groundwater flow model for the former Philadelphia Refinery has been calibrated and validated to recent environmental conditions and measured observations. As a part... read more