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 Reports only report the data, no remedial decisions relating to the use of lead Site-Specific Standard are included in the Remedial Investigation Reports. The approved Site-Specific Standard for lead is based on updated information and models from the EPA and PADEP that reflect the current state of science for lead. Evergreen will modify the Site-Specific Standard if the PADEP or the EPA modifies these models or assumptions. If the PADEP changes their assumptions related to lead, such as permissible blood lead levels, Evergreen will update the Site-specific standard accordingly.