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 The assumptions Evergreen used in calculating the standard are inaccurate and outdated.

Posted by & filed under .

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 The previous calculations used by the PADEP were outdated; therefore, the PADEP recently used the same updated Adult Lead model to develop an updated non-residential lead direct contact MSC that reflects the current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

Why does the former refinery get special treatment compared to other nonresidential sites? In terms of the lead site specific standards in soils 0 to 2 feet

Posted by & filed under .

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 & 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 & 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 & 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

The site contains several rail facilities (North Yard, West Yard, etc.). What are the conditions at rail terminals and along rail tracks?

Posted by & filed under .

The rail facilities are located in AOI 5 and AOI 8. Installation of these rail facilities occurred after the property transfer to PES. Therefore, conditions near these lines resulting from their operation would not be part of Evergreen’s investigations. However, the environmental conditions characterized as part of the Act 2 investigations, which included the areas below and around the current rail areas, are... read more

Why is Evergreen’s site-specific Lead standard (2240 ppm) so much higher than the state standard (1000 ppm)?

Posted by & filed under .

The PADEP’s Non-Residential Medium Specific Concentration (MSC) was derived using the Society for Environmental Geochemistry and Health (SEGH) model (Wixson, 1991). Since that time, the PADEP has endorsed the use of alternative uptake biokinetic models for the evaluation of lead toxicity including the Bower model (Bowers et al., 1994) for non-residential site uses. The USEPA adapted the Bowers et al. model to... read more