Regarding the soil-to-groundwater value, did you compare the soil concentrations to the soil-to-groundwater number and the site-specific number? If so, it didn’t seem like the soil-to-groundwater number was given enough consideration or serious analysis.

In the Remedial Investigation Reports, the soil concentrations were compared to the statewide health standard soil-to-groundwater number, the statewide health standard direct contact number, and to the site-specific number (for lead only).  We have hundreds of wells onsite that provide actual groundwater concentrations, and we evaluate groundwater concentrations of all compounds of concern, not just those that have exceeded soil to groundwater Medium-Specific Concentrations (MSCs).  With respect to soil, the direct contact number was utilized for comparison based on the existing pathway of exposure.