There are some areas under the old process units that weren’t accessible or where it wasn’t safe for us to drill or dig because of ongoing operations. Once those units have been dismantled and the areas are accessible, Evergreen will go out and do additional sampling. Evergreen has not been provided with the planned schedule of demolition of the unit areas. However, the sampling will be performed immediately... read more
Evergreen’s proposed site-specific standard for lead in surface soil at the former refinery site will not be protective of public health. I strongly urge you to withdraw the proposal to set a site-specific standard of 2,240 mg/kg. Evergreen’s proposed site-specific standard is more than twice the direct contact numeric value in state regulations (1,000 mg/kg). Evergreen made a flawed assumption about the target blood lead level to adequately protect a fetus of a worker at the site – an important factor in determining the site-specific standard for lead. It used a level that is twice the reference value that the Centers for Disease Control and Prevention uses to address lead exposure in children. Evergreen should be using the current science to set a site-specific standard for this site.
As part of the remedial investigations, Evergreen compared the lead data to the Act 2 soil-to-groundwater Statewide Health Standard, which is 450 parts per million (ppm) and the direct contact Statewide Standard, which is 1000 ppm, as well as the Site Specific Standard. This comparison is shown on the figures/tables in the Remedial Investigation Reports and in the 8/27/20 presentation. The Remedial Investigation... read more
Lead – High levels of lead are present at multiple locations. PADEP is allowing Evergreen to use a “site-specific lead standard” of 2240 PPM even though the statewide health limit is 1000 PPM.
As part of the remedial investigations, Evergreen compared the lead data to the Act 2 soil-to-groundwater Statewide Health Standard, which is 450 parts per million (ppm). This comparison is shown on the figures/tables in the Remedial Investigation Reports and in the 8/27/20 presentation. The Remedial Investigation Reports only report the data, not remedial decisions relating to the use of lead Site Specific... read more
Why is the site specific standard for lead contamination at the site, more than double the default state, non-residential lead standard?
The approach used to calculate the SSS for lead was to use the updated Adult Lead Model recommended by the USEPA. The previous calculations used by the PADEP were outdated; therefore, the PADEP recently used the same 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 standard for lead is... read more
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
In addition to the toxins already mentioned, what is the plan to deal with the benzene that is in the soil?
In general, benzene and other volatile compounds are not identified for further evaluation in soils (meaning they were not detected above the statewide health standards in many locations). However, all remedial options, which can include engineering and intuitional controls will be detailed in future Cleanup... 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
Why isn’t the site-specific standard for lead being reevaluated based on the anticipated site use (commercial warehouse)?
The site-specific standard for lead was calculated based on non-residential (not industrial) site use, which is consistent with the planned future... 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