The 2015 HHRA report was completed specifically to assess lead exposure in soils to site workers. Fenceline measurements of benzene occurred as an operational task required by the EPA because it was an operating refinery at the time, and therefore, monitoring was done by PES. Evergreen is responsible for potential impacts from contamination at or below the ground surface, so that is our focus. We evaluate potential risk to off-site populations from dissolved plumes moving off-site. There was no indication from initial assessments that there is any risk to indoor/outdoor air from historic environmental data collected during the RI activities.