Evergreen has stated that it has the fate and transport model, but that it has not been finalized. Can Evergreen share this information with us? It doesn’t have to be final in order for the public to see it. In fact, Act 2 specifically calls for public involvement during the development of all reports, so we would appreciate the opportunity to see and make comments on the fate and transport studies and model in its draft form or formative stage.

We are currently still developing the underlying flow model (this is the foundation of the model prior to inputting concentrations of contaminants of concern (COCs)). Later this summer we expect to be able to start making the model runs that will project the distance, direction and concentrations of compounds over time. Those projections must be calibrated to real site data. Incomplete models (or documents) that have not yet undergone internal review, peer review, or quality assurance/quality control measures will not be formally shared. Once the fate and transport model and associated report have been completed, the documents will be available for review. However, due to the complexity of the model for this project, Evergreen plans to review the model with the public prior to submittal, once the internal reviews are completed.

PADEP provided the following explanation of the concept of ‘development’ with respect to Act 2 documents and public involvement: “Act 2 and our regulations and guidance describe several measures “to involve the public in the development and review” of reports, some of which are required. The intent of these measures is to collect comments, suggestions, concerns, and questions on the Act 2 work. The remediator’s responses to this input may result in revisions to the report, and in this manner the public influences the development of the report. The public is not just on the receiving end, but it’s correct that the primary public role is to comment on the work being done. Those comments can impact both the remediator’s actions and also PADEP’s technical review and decision to approve the report.”