Since Evergreen used an inappropriate standard as a basis for its remedial investigation reports, how does it justify that it has correctly defined the extent of lead contamination?

Remedial Investigation Reports must include delineation of contamination of soil to be approved.  This includes all analyzed compounds.  All compounds of concern were compared to their respective soil-to-groundwater medium specific concentrations, as illustrated in RIR data tables, and delineated to the direct contact medium specific concentrations in both surface and subsurface soil based on existing exposure pathways, as illustrated in RIR figures.  This delineation is conducted up to the fenceline or other boundaries of the property, as required by Act 2.

The exception to this is lead in surface soil only, that was delineated to the site-specific standard based on a direct contact pathway and updated model calculations.  As noted in response to other questions concerning the lead, the calculation of the site-specific standard was appropriate in accordance with the Act 2 regulations and recommendations from the USEPA and the PADEP.

Response also addresses similar questions: 

  • Lead looks to be close to the edge of the site which is close to residential areas. Are you willing to commit to cleaning up the lead to residential standards in areas of the property that are closer to residential areas?
  • Evergreen fails to sufficiently delineate exceedances of the soil-to-groundwater numeric value and the direct contact numeric value for all constituents of concern.