At the outset of remediation activities back in the 1990s, a large number of contaminants were sampled for. Evergreen, with approval from DEP, later revised the list of “contaminants of concern” down to only 30 chemical compounds and one heavy metal, lead. We need to have a full analysis explaining why this was done. Otherwise, additional samples should be collected for all of the compounds that were not included. Similar question: There are over 100 chemical compounds and metals used in oil refining, yet only around 30 contaminants have been investigated on site. Every contaminant must be accounted for!

The site was tested for a complete list of metals as part of the 1992 EPA Resource Conservation and Recovery Act (RCRA) Facility Investigation, and none of these metals – with the exception of lead –were identified as contaminants of concern. The 1992 report is posted on the Evergreen website for reference. The current analyte list (21 compounds) utilized for the Act 2 program at the facility was developed after reviewing historic reports and data from the previous sampling efforts and in consideration of historic use of the site and the DEP analyte ‘short lists’ for various petroleum products. Evergreen’s current analyte list includes compounds indicative of the various petroleum products processed at the facility. In addition, both soil and groundwater samples from areas of the facility which historically stored and processed crude were sampled for a more comprehensive analyte list (48 compounds), which included other metals, VOCs, and SVOCs, as part of the Act 2 remedial investigation activities. These data have all been included in the RIRs. Other compounds have been analyzed in targeted areas based on past use, more complex forensic characterization, or other purposes. Ultimately, an Act 2 Final Report (where demonstration must be made that the selected remediation standards have been met) includes only those compounds that have been fully characterized.