The lead standard should be revised to be protective of public health. The standard that was approved (2240 parts per million (ppm) in surface soil) is much weaker than the default standard of 1000 ppm. The assumptions Evergreen used in calculating the standard are inaccurate and outdated.

The SSS was calculated using the updated Adult Lead Model and exposure assumptions recommended by the USEPA and the PADEP. The previous calculations used by the PADEP were outdated; therefore, the PADEP recently used the same updated Adult Lead model to develop an updated non-residential lead direct contact MSC that reflects the current state of the science for lead.  The new calculated proposed direct contact statewide health standard for lead is in line with the site-specific standard that was calculated in 2015 for the site.  If the PADEP changes their assumptions related to lead, such as permissible blood lead levels, Evergreen will update the SSS accordingly.