Off-Site Contamination – Benzene pools extend beyond the property fence line but have not been mapped. Evergreen fails to acknowledge potential responsibility for cleaning up off-site contamination of benzene or other contaminants.

The RIRs and figures presented during the Aug. 27, 2020, Public Information Session show the known extent of dissolved benzene on- and off-site. Evergreen will be including additional off-site groundwater information in the AOI 9 and AOI 4 RIR Addendums.  As addressed in other related comments, no off-site air impacts have been identified from off-site groundwater related to historic environmental impacts that Evergreen is evaluating under Act 2.  Evergreen has acknowledged the benzene due to on-site sources and identified that there are other neighboring, contaminated sites that are also contributing to the observed off-site site groundwater impacts.