As a former groundwater quality specialist, even small breaks in confining layers can result in significant transfer of contaminants. And, the direction and rates of water movement can change over time, often from groundwater drilling.

The direction and rates of groundwater flow are evaluated frequently at the site and groundwater samples collected routinely from various hydrogeologic units beneath the facility.  The Remedial Investigation activities also evaluated the areas where the confining layers in the subsurface were not continuous through the completion of soil borings, installation of monitoring wells, collection of groundwater samples,... read more

Can these report summaries (Evergreen note: refers to the Plain Language Summaries provided for each Remedial Investigation Report) identify the metrics and the benchmarks that you think Evergreen is attaining and succeeding and those that have not been reached – the question remains – what the critical path benchmarks for Lead, Benzene, Air Quality etc.

The goal of a Remedial Investigation Report (RIR) is to identify and define the source of contamination and particular constituents of concern, define the nature and extent of the contaminants (including fate and transport), characterize the affected media, and determine the appropriate Act 2 standards to be used.  DEP and EPA determine whether these goals and benchmarks have been met, through their review of the... read more

How long does it take to collect soil and groundwater data for an AOI?

That largely depends on a number of factors.  Data has been collected at the site for years for various reasons, whether it was in response to a particular release or general characterization of an area.  Most AOI investigations begin with compiling all known past data and historical information such as the particular use of an area, then coming up with a work plan for collection of new information.  After the... read more

What are some of the possible risk pathways that you’ve encountered at the refinery. And how are you dealing with them?

Risk pathways include routes of exposure for contaminants to reach receptors. One potential pathway would be vapor migration into sewers or buildings. Vapor intrusion into buildings can be addressed through various engineering controls, such as positive pressure in a building or vapor barriers/mitigation systems. Potential sewer vapors are currently being controlled in multiple locations using remediation systems... read more

Locations and concentrations of 30 contaminants of concern – including chrysene, naphthalene, mercury, and arsenic – were identified individually but their cumulative significance was not addressed.

As part of the Act 2 process, a risk assessment can be completed for a Site to develop risk based cleanup standards. The cumulative impacts from detected compounds would be included in the Risk Assessment activities. Evergreen cannot complete a Risk Assessment until the Remedial Investigation Reports are submitted and approved, and the RIR process cannot be completed until the public comment process on the Remedial... read more

Lead – High levels of lead are present at multiple locations. PADEP is allowing Evergreen to use a “site-specific lead standard” of 2240 PPM even though the statewide health limit is 1000 PPM.

As part of the remedial investigations, Evergreen compared the lead data to the Act 2 soil-to-groundwater Statewide Health Standard, which is 450 parts per million (ppm). This comparison is shown on the figures/tables in the Remedial Investigation Reports and in the 8/27/20 presentation. The Remedial Investigation Reports only report the data, not remedial decisions relating to the use of lead Site Specific... read more

Deep Aquifer – Evergreen states a layer of clay and mud partly separates the upper, “water table” aquifer from a lower, “deep” aquifer. This barrier is not continuous, though, and fails to protect the deep aquifer from contamination. Since the deep aquifer supplies drinking water to communities in New Jersey, Evergreen needs to specify the actions it will take to investigate and clean up any contamination affecting the deep aquifer and public water supplies.

As presented in the Remedial Investigation Reports, the lower aquifer (AOI 11) has been investigated during all the other AOI investigations completed since 2013 and the results were reported in the individual Remedial Investigation Reports. The concentrations found in the deep aquifer do not indicate a potential risk to communities in New Jersey, so no cleanup is anticipated as being necessary. The projected fate... read more

Benzene – High levels of benzene are present extensively at the site, and benzene is currently being emitted into the atmosphere.

As shown in the Remedial Investigation Reports, benzene is present in groundwater but is less extensive in soil.  While concentrations of benzene in soil and groundwater  exceed the statewide health standards in sampling locations, the concentrations in soil and groundwater have not been shown to emit high levels of benzene into the atmosphere.  Many samples have already been collected to evaluate benzene in air,... read more

MTBE – Methyl Tert-butyl Ether (MTBE) is present in concentrations that are over 100 times higher than the state-wide health standard. (Evergreen note: the comment addresses concentrations of MTBE in groundwater).

That is correct.  There are multiple compounds that have been detected in groundwater above statewide health standards (SHSs) at the facility as reported in Remedial Investigation Reports (RIRs).  Methyl Tert-butyl Ether (MTBE), as well as other compounds, that are present above the SHS in groundwater will be evaluated in relation to remedial action in future Act 2 submittals, including Risk Assessment and Cleanup... read more

Is there a transparent plan to look for and report on any radioactivity (radon, radon daughters, etc…), whether it is naturally occurring from underground or otherwise?

Radon is a naturally-occurring substance and is not known to be affiliated with refinery operations.  Radon or other radioactive substances have not been identified as compounds of concern (COCs) at the Site based on past operations or investigations; therefore, they have not been included in the Remedial... read more