Generated by All in One SEO v4.9.5, this is an llms.txt file, used by LLMs to index the site.

# PRLR

## Sitemaps

- [XML Sitemap](https://phillyrefinerycleanup.info/sitemap.xml): Contains all public & indexable URLs for this website.

## Posts

- [Elementor #1922](https://phillyrefinerycleanup.info/uncategorized/elementor-1922/)

## Pages

- [Home](https://phillyrefinerycleanup.info/) - Sign Up for Updates
- [Semi-Annual Remediation Status Reports](https://phillyrefinerycleanup.info/act-2-documents/semi-annual-remediation-status-reports/)
- [Act 2 Documents](https://phillyrefinerycleanup.info/act-2-documents/)
- [Yards Community Spotlight - Evergreen's Quarterly Newsletter](https://phillyrefinerycleanup.info/newsletters/)
- [Public Involvement](https://phillyrefinerycleanup.info/public-involvement/) - Register for 2026 Q1 Virtual Public Meeting See past public meetings Read the quarterly newsletters Submit public comments Stay connected and sign up for updates Public Engagement Timeline 2006 | Notice of Intent to Remediate & Public Involvement Plan (PIP) After submittal of the Notice of Intent to Remediate in 2006, the City of Philadelphia
- [Comment Submission Form](https://phillyrefinerycleanup.info/comment-submission-form/)
- [Public Meetings](https://phillyrefinerycleanup.info/public-meetings/)
- [Meeting Video 12-09-25](https://phillyrefinerycleanup.info/meeting-video-12-09-25/)
- [HB Edit - Act 2 Documents](https://phillyrefinerycleanup.info/hb-edit-act-2-documents/) - Notices of Intent to Remediate (NIR) Belmont Terminal Area of Interest (AOI) Site-Wide Reports Public Involvement Plans Permits Site-Wide Initial NIR (October 2006) NIR Update (November 2014) NIR Update (November 2016) Belmont Terminal Belmont Terminal NIR (October 2014) Remedial Investigation Report (RIR) RIR Part 1 - text/tables/figures (June 2024) RIR Part 2 - appendices (June
- [HB Edit - Home Page](https://phillyrefinerycleanup.info/home-4/) - Sign Up for Updates Evergreen and the former Philadelphia Energy Solutions Refining Complex Providing Opportunity for Public Comment Previous Next The Former Philadelphia Refinery The former Philadelphia Refinery is a 1300-acre site located in South Philadelphia. Formerly known as the Sunoco Philadelphia Refinery (sold in 2012) and then the Philadelphia Energy Solutions Refining and Marketing
- [Site History](https://phillyrefinerycleanup.info/site-history/)
- [Site History](https://phillyrefinerycleanup.info/site-history-2/)
- [Meeting Video 03-25-25](https://phillyrefinerycleanup.info/meeting-video-03-25-25/)
- [HB Edits - Act 2 Documents](https://phillyrefinerycleanup.info/act-2-documents-2/) - Belmont Terminal Remedial Investigation Report Part 1 Belmont Terminal Remedial Investigation Report Part 2
- [ARCHIVED - Q & A (OLD BACKUP)](https://phillyrefinerycleanup.info/archived-q-a-old-backup/)
- [HB edits - Site History](https://phillyrefinerycleanup.info/site-history/site-history-draft/) - History of Remedial Investigationat the Philadelphia Refining Complex The former Sunoco Philadelphia Refinery, now known as The Bellwether District, covers over 1,300 acres along the Schuylkill River in Philadelphia. Its petroleum activities date back to the 1860s when Atlantic Petroleum Company established an oil distribution center. Crude oil processing began in the 1900s, and gasoline
- [ARCHIVED: Resources](https://phillyrefinerycleanup.info/archived-resources/) - Videos Legacy Remediation Basics Air Quality & Vapor Intrusion Groundwater Model (external video) Fact Sheets Air Quality Contaminant Fate & Transport DEP Act 2 (external fact sheet) Regulations Remediation Risk Assessment
- [Referenced Historic Reports](https://phillyrefinerycleanup.info/act-2-documents/referenced-historical-reports/)
- [PFAS](https://phillyrefinerycleanup.info/pfas/)
- [Meeting Video 03-07-24](https://phillyrefinerycleanup.info/meeting-video-03-07-24/)
- [Public Comment](https://phillyrefinerycleanup.info/comment-submission-form/thank-you/)
- [Meeting Video 12-6-23](https://phillyrefinerycleanup.info/meeting-video-12-6-23/)
- [Q & A](https://phillyrefinerycleanup.info/q-a/)
- [Meeting Video 06-07-23](https://phillyrefinerycleanup.info/meeting-video-06-07-23/)
- [Meeting Video 03-14-23](https://phillyrefinerycleanup.info/meeting-video-03-14-23/)
- [09-13-22 Poster Presentation Videos](https://phillyrefinerycleanup.info/meeting-video-09-13-22/)
- [Video: Air Quality & Vapor Intrusion](https://phillyrefinerycleanup.info/video-air-quality-vapor-intrusion/)
- [Sign Up](https://phillyrefinerycleanup.info/sign-up/)
- [Q&A Follow-Up 05-24-22](https://phillyrefinerycleanup.info/qa_follow_up_5-24-22/)
- [Contact Us](https://phillyrefinerycleanup.info/contact-us/) - We encourage you to stay connected with us. Choose from the options below to stay informed, ask questions, and to send us your comments. Sign Up for Email Updates Sign up to receive email updates from Evergreen about public meetings, reports, and other news. Submit a Comment Submit general comments on comments on reports here.
- [Meeting Video 05-24-22](https://phillyrefinerycleanup.info/meeting-video-05-24-22/)
- [Meeting Video 02-17-22](https://phillyrefinerycleanup.info/meeting-video-02-17-22/)
- [Philadelphia AMS Evergreen Joint Public Information Session Video 12-15-21](https://phillyrefinerycleanup.info/ams-evergreen-public-info-session-rec-121521/)
- [Meeting Video 09-28-21](https://phillyrefinerycleanup.info/meeting-video-09-28-21/)
- [Meeting Video 08-27-20](https://phillyrefinerycleanup.info/meeting-video/)
- [Video: Legacy Remediation - the Basics](https://phillyrefinerycleanup.info/video-legacy-remediation-basics/)
- [Meeting Video 02-18-21](https://phillyrefinerycleanup.info/meeting-video-02-18-21/)
- [Meeting Video 01-14-21](https://phillyrefinerycleanup.info/meeting-video-01-14-21/)

## My Templates

- [Elementor Loop Item #1928](https://phillyrefinerycleanup.info/?elementor_library=elementor-loop-item-6)
- [Elementor Loop Item #1858](https://phillyrefinerycleanup.info/?elementor_library=elementor-loop-item-5)
- [Elementor Loop Item #1857](https://phillyrefinerycleanup.info/?elementor_library=elementor-loop-item-4)
- [Elementor Loop Item #1714](https://phillyrefinerycleanup.info/?elementor_library=elementor-loop-item-3)
- [Elementor Loop Item #1713](https://phillyrefinerycleanup.info/?elementor_library=elementor-loop-item-2)
- [Elementor Loop Item #1708](https://phillyrefinerycleanup.info/?elementor_library=elementor-loop-item)
- [Default Kit](https://phillyrefinerycleanup.info/?elementor_library=default-kit)

## Questions

- [What projects has Hummingbird have worked on in South Philly?  Hummingbird.. Darby is not in South Philly can you be more specific?](https://phillyrefinerycleanup.info/questions/what-projects-has-hummingbird-have-worked-on-in-south-philly-hummingbird-darby-is-not-in-south-philly-can-you-be-more-specific/) - It is more accurate to say that the projects that we have worked on and communities that we have worked with are in Southwest Philadelphia. For the past 7 years, Marion Cox on our team has worked with several Philadelphia communities at the Lower Darby Creek Area Superfund Site. More specifically, the Lower Darby Creek
- [Did Evergreen involve any neighborhood organizations in the process of deciding which community engagement consulting firm to hire? Thank you.](https://phillyrefinerycleanup.info/questions/did-evergreen-involve-any-neighborhood-organizations-in-the-process-of-deciding-which-community-engagement-consulting-firm-to-hire-thank-you/) - Evergreen did not directly involve neighborhood organizations in the process of deciding which community engagement consulting firm to hire. Evergreen drafted a Community Outreach Plan based on feedback from members of the public and from regulatory agencies in spring of 2020. Evergreen also researched firms that had a successful engagement history on complex environmental sites
- [Who is responsible to collect, sample, and treat stormwater? Does the ACT 2 closure include PFAS concerns to reduce future liabilities? We are treating impacted PFAS stormwater at a site in the NE. The owner in this case is risk adverse and we are treating to non-detect levels.](https://phillyrefinerycleanup.info/questions/who-is-responsible-to-collect-sample-and-treat-stormwater-does-the-act-2-closure-include-pfas-concerns-to-reduce-future-liabilities-we-are-treating-impacted-pfas-stormwater-at-a-site-in-the-ne-th/) - Storm water will continue to be managed by the current owners/operators of the property, not Evergreen. PFAS compounds are not currently part of Evergreen’s Act 2 program at the facility; however, Evergreen is developing a PFAS sampling program for subsurface conditions, not storm water.
- [You still have those pollution Underground I still smell odors outside of my house](https://phillyrefinerycleanup.info/questions/you-still-have-those-pollution-underground-i-still-smell-odors-outside-of-my-house/) - Evergreen is responsible for investigation and cleanup of subsurface conditions present at the property before the sale to PES in 2012. Part of Evergreen's investigation involves defining the extent of contamination in soil and groundwater and determining if the impacts present a risk to people onsite and those located near to the site. Evergreen operates
- [How long will this take and when will the cleanup start?](https://phillyrefinerycleanup.info/questions/how-long-will-this-take-and-when-will-the-cleanup-start/) - Evergreen’s cleanup, when talking about subsurface remediation (extraction of petroleum and impacted groundwater from the subsurface), has been ongoing for quite some time and is expected to continue for several years until removal of petroleum and impacted groundwater is no longer necessary). The need for any additional remediation systems to address pre-2012 impacts will be
- [What plans does HILCO have to verify that the cleanup of AOI 11 (the PRM Aquifer) does not impact the water supply in NJ?  Many municipal and public water companies and farmers draw their water from this source?](https://phillyrefinerycleanup.info/questions/what-plans-does-hilco-have-to-verify-that-the-cleanup-of-aoi-11-the-prm-aquifer-does-not-impact-the-water-supply-in-nj-many-municipal-and-public-water-companies-and-farmers-draw-their-water-from-t/) - Evergreen is responsible for subsurface petroleum impacts that existed prior to the sale of the facility to PES in 2012. The investigation of that historic contamination includes AOI-11, which is the lower aquifer beneath the facility. Evergreen will continue to address those pre-2012 impacts in the lower aquifer throughout the Act 2 process and AOI
- [At the outset of remediation activities back in the 1990s, a large number of contaminants were sampled for. Evergreen, with approval from DEP, later revised the list of “contaminants of concern” down to only 30 chemical compounds and one heavy metal, lead. We need to have a full analysis explaining why this was done. Otherwise, additional samples should be collected for all of the compounds that were not included. Similar question: There are over 100 chemical compounds and metals used in oil refining, yet only around 30 contaminants have been investigated on site. Every contaminant must be accounted for!](https://phillyrefinerycleanup.info/questions/at-the-outset-of-remediation-activities-back-in-the-1990s-a-large-number-of-contaminants-were-sampled-for-evergreen-with-approval-from-dep-later-revised-the-list-of-contaminants-of-concer/) - The site was tested for a complete list of metals as part of the 1992 EPA Resource Conservation and Recovery Act (RCRA) Facility Investigation, and none of these metals – with the exception of lead –were identified as contaminants of concern. The 1992 report is posted on the Evergreen website for reference. The current analyte
- [Evergreen has stated that it has the fate and transport model, but that it has not been finalized. Can Evergreen share this information with us? It doesn’t have to be final in order for the public to see it. In fact, Act 2 specifically calls for public involvement during the development of all reports, so we would appreciate the opportunity to see and make comments on the fate and transport studies and model in its draft form or formative stage.](https://phillyrefinerycleanup.info/questions/evergreen-has-stated-that-it-has-the-fate-and-transport-model-but-that-it-has-not-been-finalized-can-evergreen-share-this-information-with-us-it-doesnt-have-to-be-final-in-order-for-the-pu/) - We are currently still developing the underlying flow model (this is the foundation of the model prior to inputting concentrations of contaminants of concern (COCs)). Later this summer we expect to be able to start making the model runs that will project the distance, direction and concentrations of compounds over time. Those projections must be
- [While Evergreen has stated that benzene contamination moving off-site has not impacted the air quality in surrounding buildings, they have also said that no sampling of air quality in off-site buildings has been done. Evergreen needs to collect data to ensure that benzene and other contamination has not moved offsite and made its way from contaminated soils into the basements of surrounding buildings, affecting the health of residents.](https://phillyrefinerycleanup.info/questions/while-evergreen-has-stated-that-benzene-contamination-moving-off-site-has-not-impacted-the-air-quality-in-surrounding-buildings-they-have-also-said-that-no-sampling-of-air-quality-in-off-site-buildin/) - Evergreen has conducted initial assessments using existing data and conservative assumptions, which did not find any potential impacts to off-site residences’ indoor air quality from the conditions in shallow groundwater moving offsite from the facility; therefore, we have no plans to test off-site buildings. However, future fate and transport evaluation will model the projected extent
- [Have there been any studies on the effect of the pollution of the PRM in the water supply in NJ, as public and private water companies draw water from it and Phila stopped using it in the 1990’s because it was too polluted?](https://phillyrefinerycleanup.info/questions/have-there-been-any-studies-on-the-effect-of-the-pollution-of-the-prm-in-the-water-supply-in-nj-as-public-and-private-water-companies-draw-water-from-it-and-phila-stopped-using-it-in-the-1990/) - Evergreen is not aware of any available studies that evaluate the fate and transport of petroleum hydrocarbon chemicals in groundwater from the site into New Jersey groundwater. Evergreen plans to complete fate and transport modeling with a numerical groundwater model, which will evaluate the potential migration of petroleum-related chemicals from both the water-table aquifer (AOIs
- [I currently reside in Siena Place near the borderline of the refinery. I just want to know is it safe to live there in terms of Air quality and in regards to the plume status. Recently, I have smelled Gas outside approximately on A few occasions near the end of July and don’t know if that is from the refinery or cleanup process as the refinery is not currently operating.](https://phillyrefinerycleanup.info/questions/i-currently-reside-in-siena-place-near-the-borderline-of-the-refinery-i-just-want-to-know-is-it-safe-to-live-there-in-terms-of-air-quality-and-in-regards-to-the-plume-status-recently-i-have-smelled/) - The refining operations were shut down in 2019; however, Evergreen is unaware of other site activities that have taken place at the facility since that time, so we are unsure of the source of any odors. PES operated the site and would have the information pertaining to air emission data. In addition, the City of
- [If there are risks to people I would like to be provided with information which will allow me to identify if something in your process has gone poorly and if I need to take further precaution to keep myself and my family safe.](https://phillyrefinerycleanup.info/questions/if-there-are-risks-to-people-i-would-like-to-be-provided-with-information-which-will-allow-me-to-identify-if-something-in-your-process-has-gone-poorly-and-if-i-need-to-take-further-precaution-to-keep/) - Evergreen interprets this question as potentially being in reference to the ongoing demolition and construction processes, which would be the responsibility of the new property owner. However, with respect to Evergreen’s responsibility to investigate and remediate soil and groundwater contamination, the route of exposure to nearby communities would be potential indoor or outdoor air impacts
- [It may have been more effective if this presentation was made available a week ago and we could have spent these two hours asking pertinent questions, such as: 1. what are the critical paths for considering the risks of lead and benzene to the adjacent communities; 2. how  are increased climate-change risks being  assessed; 3. how is ground and surface water run off being considered in the plans; 4. how is Hilco assessing the additional risks of (what looks like will be) hard scape pavement of 85-90% of the site?](https://phillyrefinerycleanup.info/questions/it-may-have-been-more-effective-if-this-presentation-was-made-available-a-week-ago-and-we-could-have-spent-these-two-hours-asking-pertinent-questions-such-as-1-what-are-the-critical-paths-for-consi/) - 1- The route of exposure (or risk pathway) identified for adjacent communities would be potential indoor or outdoor air impacts from dissolved groundwater plumes that migrate offsite. However, initial assessment did not find any potential impacts to off-site residences from the conditions in shallow groundwater. This will be further evaluated after the contaminant fate and
- [Have you submitted draft cleanup plans to DEP? Can we receive a copy of the Cleanup Plan?](https://phillyrefinerycleanup.info/questions/have-you-submitted-draft-cleanup-plans-to-dep-can-we-receive-a-copy-of-the-cleanup-plan/) - A draft Cleanup Plan has not been submitted to the PADEP. Remedial Investigations must be completed prior to submitting Cleanup Plans and other Act 2 reports that follow Remedial Investigations in the Act 2 process. Upon completion of Remedial Investigation Reports (RIRs) for each of the Areas of Interest, the subsequent Act 2 reports can
- [Please listen to the people who have no interests other than the health of their loved ones. Please understand that people are not exaggerating that generations have been suffering from the toxicity of the previous oil refinery’s existence, and do not belittle their concerns. Everything is fixable, the question is who will you choose to represent, the people and their health or corporate levers of power? I hope it’s not the latter. Clean this area up THOROUGHLY.](https://phillyrefinerycleanup.info/questions/please-listen-to-the-people-who-have-no-interests-other-than-the-health-of-their-loved-ones-please-understand-that-people-are-not-exaggerating-that-generations-have-been-suffering-from-the-toxicity-o/) - Evergreen’s role here is very specific as it relates to environmental remediation of subsurface contamination at the former refinery site through 2012, when Sunoco sold the refinery, as required by Act 2. We are following all appropriate regulations to carry out this remediation work, including attempting to engage the public throughout the process. However, Evergreen
- [I was wondering what your plans are now that Hilco has purchased the land PES and Sunoco both left in shambles.](https://phillyrefinerycleanup.info/questions/i-was-wondering-what-your-plans-are-now-that-hilco-has-purchased-the-land-pes-and-sunoco-both-left-in-shambles/) - Evergreen is in the process of finishing the investigation activities at the former Philadelphia Refinery to identify the extent of the chemicals in soil and groundwater, in order to develop a remediation (cleanup) plan for the site. At various steps in the process, Evergreen will prepare reports and hold public meetings on Act 2 reports,
- [Do you have any idea what is going to be done with the site, and is there any way to encourage using it as a site for renewable energy for the city?](https://phillyrefinerycleanup.info/questions/do-you-have-any-idea-what-is-going-to-be-done-with-the-site-and-is-there-any-way-to-encourage-using-it-as-a-site-for-renewable-energy-for-the-city/) - Evergreen is responsible only for the historic contamination that exists below the surface in soil and groundwater at the Site. We are in the process of finishing the investigation activities at the site to identify the extent of the chemicals in soil and groundwater, so we can develop a remediation (cleanup) plan for the site.
- [Air monitoring has been done on site to see if vapors were present in refinery buildings or the surrounding air. When will this investigation of air quality be extended to surrounding areas, slash neighborhoods?”](https://phillyrefinerycleanup.info/questions/air-monitoring-has-been-done-on-site-to-see-if-vapors-were-present-in-refinery-buildings-or-the-surrounding-air-when-will-this-investigation-of-air-quality-be-extended-to-surrounding-areas-slash-nei/) - As part of the Act 2 program, Evergreen evaluates potential air quality effects from subsurface conditions (as opposed to any air quality issues from above-ground operations). The evaluation of any vapors to indoor and outdoor air from a dissolved plume beneath the subsurface is part of the evaluation required by Act 2 and will be
- [Gulf operated a refinery where the Schuylkill Tank Farm is currently located before building the refinery at Gerard Point. What contamination is left at the former refinery site? What are the implications for people living or working in Eastwick?](https://phillyrefinerycleanup.info/questions/gulf-operated-a-refinery-where-the-schuylkill-tank-farm-is-currently-located-before-building-the-refinery-at-gerard-point-what-contamination-is-left-at-the-former-refinery-site-what-are-the-implicat/) - The site characterization and history for the Schuylkill River Tank Farm (SRTF), which is also known as AOI 9, can be found in the RIR for AOI 9. Some contaminants are present in soil and groundwater related to the former operations. Light non-aqueous phase liquid (LNAPL), or oil, is also present in limited areas and
- [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.](https://phillyrefinerycleanup.info/questions/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-1/) - 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
- [1)We are concerned about lead in surface soil. The standard Evergreen has proposed does not address the risk. 2) Evergreen has not obtained approval from DEP for remedial investigation reports for several of the more contaminated areas of interest. Including the aquifer. 3) The work done so far does not consider the impacts of climate change, rising sea level and worsening storms.  Note: for the purpose of response, this comment was split into three topics by Evergreen.](https://phillyrefinerycleanup.info/questions/1we-are-concerned-about-lead-in-surface-soil-the-standard-evergreen-has-proposed-does-not-address-the-risk-2-evergreen-has-not-obtained-approval-from-dep-for-remedial-investigation-reports-for-sev/) - 1)The site-specific standard for lead was approved by both PADEP and EPA and utilized the updated Adult Lead Model and exposure assumptions recommended by the USEPA and the PADEP. As part of the remedial investigations, the lead data was compared to the Act 2 SHS MSC, which is 450 ppm, based on the soil to
- [Lead    is a heavy metal, but it will not remain stationary. Contaminated soil will be kicked up as dust by cars on the road, construction projects, and even by children at play.](https://phillyrefinerycleanup.info/questions/lead-is-a-heavy-metal-but-it-will-not-remain-stationary-contaminated-soil-will-be-kicked-up-as-dust-by-cars-on-the-road-construction-projects-and-even-by-children-at-play/) - Potential dust from Site soils will be addressed through the remedies selected for the Site, which will be proposed in the Cleanup Plan. Measures to prevent dust generation during redevelopment should be included in Hilco Redevelopment Partner’s site development permits.
- [Over its lifespan, this refinery used over a hundred chemical compounds. Why are only 30 of these sampled for on site? What is the rationale for not sampling the others?](https://phillyrefinerycleanup.info/questions/over-its-lifespan-this-refinery-used-over-a-hundred-chemical-compounds-why-are-only-30-of-these-sampled-for-on-site-what-is-the-rationale-for-not-sampling-the-others/) - The current analyte list utilized for the Act 2 program at the facility was developed after analyzing historic reports and data from previous sampling efforts and in consideration of historic use of the site and the DEP analyte ‘short lists’ for various petroleum products. Evergreen’s current analyte list includes compounds indicative of the various petroleum
- [Evergreen should not characterize this remediation project as a voluntary cleanup.](https://phillyrefinerycleanup.info/questions/evergreen-should-not-characterize-this-remediation-project-as-a-voluntary-cleanup/) - Act 2 is a voluntary cleanup program. However, Sunoco is obligated to cleanup the legacy contamination under the Act 2 cleanup program through enforceable legal agreements signed with PADEP, and Evergreen completes the cleanup on Sunoco’s behalf. Therefore, Evergreen’s participation is not voluntary nor does Evergreen characterize the remediation project as voluntary.
- [The 2015 Human Health Risk assessment Report [HHRA] assesses the exposure for non-residential populations. Fenceline measurements of chemicals such as benzene are above regulatory limits. What health risk assessments have been done for nearby residential populations and are these publicly available?](https://phillyrefinerycleanup.info/questions/the-2015-human-health-risk-assessment-report-hhra-assesses-the-exposure-for-non-residential-populations-fenceline-measurements-of-chemicals-such-as-benzene-are-above-regulatory-limits-what-health/) - 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
- [When will the areas be sampled that have not been sampled before because the refineries had been operating and when will that data be made public?](https://phillyrefinerycleanup.info/questions/when-will-the-areas-be-sampled-that-have-not-been-sampled-before-because-the-refineries-had-been-operating-and-when-will-that-data-be-made-public/) - There are some areas under the old process units that weren’t accessible or where it wasn’t safe for us to drill or dig because of ongoing operations. Once those units have been dismantled and the areas are accessible, Evergreen will go out and do additional sampling. Evergreen has not been provided with the planned schedule
- [Will you commit to cleaning up all areas near residential off site areas to residential health based standards? For the part of the property that will be a public park, do residential standards apply to these areas?](https://phillyrefinerycleanup.info/questions/will-you-commit-to-cleaning-up-all-areas-near-residential-off-site-areas-to-residential-health-based-standards-for-the-part-of-the-property-that-will-be-a-public-park-do-residential-standards-apply/) - Per the 2020 First Amendment to the Consent Order & Agreement dated June 26, 2020 (and the deeds transferring the parcels), Philadelphia Energy Solutions/Hilco committed to continuing to use the former refinery property for non-residential use. As such, Sunoco agreed to remediate the site to non-residential use standards under Pennsylvania Act 2 and Evergreen’s future
- [Of particular concern are impacts to living species in the Schuylkill and Delaware Rivers: - Persisting water quality problems stemming from site pollution (including sedimentation) that enters surface water through stormwater runoff and other pathways. These problems include low Dissolved Oxygen that impinges on fish and other aquatic life, hydrocarbons such as benzene and polychlorinated biphenyls (PCBs), along with other legacy pollutants that harm species and their habitats - Endangered species (i.e., Atlantic Sturgeon and Shortnose Sturgeon, both of which are federally endangered); both of these sturgeon species are greatly imperiled and use this part of the tidal Schuylkill and the tidal Delaware - Fish and fishlife and other vulnerable species such as mussels and migratory fish, known to live and utilize the river.](https://phillyrefinerycleanup.info/questions/of-particular-concern-are-impacts-to-living-species-in-the-schuylkill-and-delaware-rivers-persisting-water-quality-problems-stemming-from-site-pollution-including-sedimentation-that-enters-surfac/) - If contamination affects certain sensitive ecological receptors, such as threatened and endangered species, it must be addressed in the cleanup. This can be accomplished through a risk assessment or remedial measures. An ecological risk assessment that evaluates the ecological receptors that would be in the Schuylkill and on site has been completed already and will
- [What are some of the possible risk pathways that you’ve encountered at the refinery. And how are you dealing with them?](https://phillyrefinerycleanup.info/questions/what-are-some-of-the-possible-risk-pathways-that-youve-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
- [Question from TASC Public Meeting: What was the impact of the recent hurricane on the ongoing remediation processes? [Evergreen note: the TASC Meeting took place in October 2020] Were any of the water treatment processes overwhelmed and were there any discharges into the River?](https://phillyrefinerycleanup.info/questions/question-from-tasc-public-meeting-what-was-the-impact-of-the-recent-hurricane-on-the-ongoing-remediation-processes-evergreen-note-the-tasc-meeting-took-place-in-october-2020-were-any-of-the-water/) - Evergreen has not observed any impact by heavy storm on our remediation processes at the site. Evergreen is unaware of conditions with facility wastewater treatment plants or discharges, as those are facility operations.
- [Remove all of the lead, we deserve a space that is safe to work and play in.](https://phillyrefinerycleanup.info/questions/remove-all-of-the-lead-we-deserve-a-space-that-is-safe-to-work-and-play-in/) - Act 2 includes procedures to allow for the reuse and development of a site while maintaining safety of the community, environment, and workers on site. This is inherently the purpose of Act 2. Evergreen will evaluate how best to do this through remediation, pathway elimination, modeling, risk assessment, and engineering and institutional controls to make
- [Conventional land remediation consists of capping the contaminated soil with tarp and/or concrete; or hauling the soil someplace else. Capping ignores the problem for a few decades at most, until chemicals leach out. In this case, into the Delaware River. Hauling the soil elsewhere just pushes the problem of leaching onto another bioregion. Neither of these methods is true remediation since we’re either burning, burying, or relocating the contamination. Eco-remediation is the most cost effective method of remediating soil and water, per figure 98 in "Mycelium Running, Paul Stamets.](https://phillyrefinerycleanup.info/questions/conventional-land-remediation-consists-of-capping-the-contaminated-soil-with-tarp-and-or-concrete-or-hauling-the-soil-someplace-else-capping-ignores-the-problem-for-a-few-decades-at-most-until-chem/) - Evaluation of current and potential remedial options is ongoing. Cleanup Plans will be submitted upon completion of all Remedial Investigation activities, which will consist of identification and evaluation of remedial alternatives, selection of proposed remedies, and plans for the development, construction, and initial operation of the proposed remedy and/or documentation of interim remedial actions already
- [What is the timeline for the [remaining] cleanup? Is it measured in months, or years?](https://phillyrefinerycleanup.info/questions/what-is-the-timeline-for-the-remaining-cleanup-is-it-measured-in-months-or-years/) - Evergreen’s active remediation has been ongoing for decades and may extend for many years more. Part of the future Act 2 Cleanup Plan will include defining parameters that are measured and tracked to determine the appropriate time to cease active remediation in each area.
- [I am wondering if you are able to send out updates about what plans are being carried out when. For instance, if you are cleaning a particular thing, I'd like to know ahead of time when that cleaning will take place and what the risks to the surrounding environment/people are.](https://phillyrefinerycleanup.info/questions/i-am-wondering-if-you-are-able-to-send-out-updates-about-what-plans-are-being-carried-out-when-for-instance-if-you-are-cleaning-a-particular-thing-id-like-to-know-ahead-of-time-when-that-cleaning/) - Evergreen is in the process of finishing the investigation activities at the former Philadelphia Refinery to identify the extent of the chemicals in soil and groundwater, in order to ultimately develop remediation (cleanup) plans for the site. During this process, Evergreen will develop reports and hold public meetings, both of which will have public notices.
- [When clean-up will the community be notified in south and southwest Philly?](https://phillyrefinerycleanup.info/questions/when-clean-up-will-the-community-be-notified-in-south-and-southwest-philly/) - Evergreen is in the process of finishing the investigation activities at the former Philadelphia Refinery to identify the extent of the chemicals in soil and groundwater, in order to ultimately develop remediation (cleanup) plans for the site. During this process, Evergreen will develop reports and hold public meetings, both of which will have public notices.
- [Are you aware which Philadelphia City officials are charged with reviewing the documents?](https://phillyrefinerycleanup.info/questions/are-you-aware-which-philadelphia-city-officials-are-charged-with-reviewing-the-documents/) - Evergreen is not aware of who at the City may review the Act 2 reports. Our Act 2 reports must be reviewed by both DEP and EPA for approval, not the City. Nonetheless, the City is engaged in the public involvement process.
- [How do DEP and Evergreen determine what is safe?](https://phillyrefinerycleanup.info/questions/how-do-dep-and-evergreen-determine-what-is-safe/) - This question was sent to PADEP who provided the following response: DEP establishes Act 2 Statewide health standard cleanup values for soil and groundwater, known as Medium-Specific Concentrations (MSCs), using a variety of risk- and health-based methods. For instance, many groundwater MSCs are adopted from U.S. EPA’s drinking water standards. Other MSCs are calculated by
- [I understand that the cleanup is happening under a voluntary act 2 opt in? What were the benefits to opting into this program?](https://phillyrefinerycleanup.info/questions/i-understand-that-the-cleanup-is-happening-under-a-voluntary-act-2-opt-in-what-were-the-benefits-to-opting-into-this-program/) - The information provided below was largely obtained from the PA Department of Environmental Protection (DEP) Overview of the Land Recycling Program Fact Sheet, which can be accessed through this link: DEP Fact Sheet. The Land Recycling Program (which actually includes Acts 2, 3, 4, 6 and 68, but is commonly referred to as “Act 2”)
- [Evergreen has not provided sufficient time following explanations for the community to digest the information provided. 120 days is insufficient.](https://phillyrefinerycleanup.info/questions/evergreen-has-not-provided-sufficient-time-following-explanations-for-the-community-to-digest-the-information-provided-120-days-is-insufficient/) - The Remedial Investigation Reports have been available at PADEP for the public for review since the time of their submittal. The reports have been posted to Evergreen’s website created for the refinery project since July 2019. The 120-day comment period consists of the time between the first Public Information Session, on Aug. 27, 2020, and
- [We are listening to your description of evergreen communications, but after exploring the materials at length, and attending meetings, many engaged citizens don’t agree that you are offering access to materials that facilitate public conversations, delivering 1000 page documents for comment is not democratic. Your reports can easily be designed to make key data and decisions accessible to the public. And the question is are you willing to create living documents that are updated about the state of knowledge about contamination and incorporate public comment? This will make for authentic public conversation about the future of this incredibly important place in our city. The recent NYT article about PES and Philly Thrive shows that the world is watching how we do this. Evergreen can be an important leader.](https://phillyrefinerycleanup.info/questions/we-are-listening-to-your-description-of-evergreen-communications-but-after-exploring-the-materials-at-length-and-attending-meetings-many-engaged-citizens-dont-agree-that-you-are-offering-a/) - The reports Evergreen is required to submit to regulators are inherently long and technical due to their specific requirements as related to the site’s history, size and complexity. Reports must include the incorporation of not just current data, but all historic data with back-up documentation for all referenced activities and interpretation in the reports. While
- [The following are similar comments/questions/and sentiments and were combined for one cohesive response.  However, each individual question has been listed below so that each person's question is carried through and addressed.  The Public Involvement Program should allow for proactive, two-way consultation between Evergreen and the community about the clean-up, throughout the development of the reports and the clean-up itself. ● The people affected by what Evergreen and Hilco are doing need to be involved. Equal partnership with the public needs to be achieved by: (1) creating a series of public meetings in a small-group format to allow for meaningful public engagement throughout the Act 2 process and (2) creating a community-based advisory group to solicit questions and comments, and evaluate the effectiveness of the PIP on an ongoing basis. ● As a Grays Ferry resident, I’m very concerned about the clean-up and the lack of community involvement in the process as well as minimal communication with the community as to the health hazards and potential risks. There needs to be meaningful inclusion of community members throughout the Act 2 process, which means open access to information, feedback, and frequent consultation. This can be accomplished by creating a community-based advisory group to solicit questions and comments and evaluate the effectiveness of the PIP on an ongoing basis. None of the work that’s been done so far has involved active outreach to ALL community members. ● For years have been told what was happening only to find out it was not true we need to create a community base Advisory to review everything that’s going on are you willing to do that. ● I support the demands of Philly Thrive and all fence line community members. Beyond presenting your goals to the community, it is the right of the community to demand and expect free, prior, and informed consent over the entire process given the health impacts of the air, water, soil, and aesthetics of their community. ● This process is one-sided and not meaningfully engaging the public. To follow through on your stated commitment to hear residents about how to make meetings better, listen to our feedback that we’ve repeatedly shared tonight to create public meetings in a small group format that allow the public to meaningfully share OUR insights with Evergreen and create a community-based advisory group to solicit questions and comments, and continually evaluate the effectiveness of the PIP. ● This is a once in a hundred-year opportunity to do right by the people who live by the site. People are eager to be involved and engaged. Will Evergreen consider a process that is less hierarchical? There are limitations due to COVID but past efforts at engagement indicate that communication is one-way rather than a dialogue. Will you make room for smaller, topic-targeted conversation in real-time rather than this type of Q+A.](https://phillyrefinerycleanup.info/questions/click-for-multiple-questions-on-public-involvement-and-communication/) - Evergreen understands the community’s interest in the site and is committed to providing meaningful public involvement. Evergreen has reached out in many ways, beyond Act 2 requirements, to work with the public and identify the best and most productive ways to engage. Evergreen has already taken several actions to involve the public in meaningful ways
- [Meeting Format: 1) As a community resident I think this media forum is not consumer friendly in allowing community members to have an opportunity to participate fully in this report out process. (Evergreen Note: comment refers to the use of Microsoft Teams Live event during the August 27, 2020 Public Information Session).  2) Many communities and cities are finding that COVID 19 doesn’t have to stifle public debate. The South Philadelphia and Grays Ferry communities are comfortable with virtual tools that allow us to see and hear each other, as well as Evergreen. It is important that you adopt tools (which you likely use in your daily meetings with colleagues) that promote a true virtual public meeting. Would Evergreen be willing to discuss with community organizations the selection of technology that is more appropriate for virtual public meetings?](https://phillyrefinerycleanup.info/questions/meeting-format-1-as-a-community-resident-i-think-this-media-forum-is-not-consumer-friendly-in-allowing-community-members-to-have-an-opportunity-to-participate-fully-in-this-report-out-process-ever/) - The Microsoft Teams Live format was selected to ensure that as many people as possible could see the presentation and participate. Other meeting platforms, like Zoom, have caps on attendance, and we knew that there was potentially a significant interest in the first meeting. We chose a platform that had a higher capacity to allow
- [A presentation where more than 3/4 of the time is spent in a one-way flow of information and where residents’ concerns are relegated to a still-diminishing-and-to-be-seen Q & A period at the end of the meeting does not bode well for a process that is inclusive of the public, as the City has requested and as the law requires.  (Evergreen note: this comment refers to the Aug. 27, 2020 event).](https://phillyrefinerycleanup.info/questions/a-presentation-where-more-than-3-4-of-the-time-is-spent-in-a-one-way-flow-of-information-and-where-residents-concerns-are-relegated-to-a-still-diminishing-and-to-be-seen-q-a-period-at-the-e/) - The first public information session held on Aug. 27, 2020, was designed to provide an overview of the technical information in the RIRs. It included discussion of questions and comments already received from the public, both on the reports and the Act 2 process in general. Evergreen is aware that the presentation went long and apologizes
- [Tonight’s Information Session (Evergreen note: refers to the August 27, 2020 Public Information  Session) offers a strong basic primer on geology, groundwater and characterization of the contamination readings, and the presenters are very good at explaining things. Many engaged community members have already studied this material together, and with a variety of other subject matter experts, and are ready to move on to learning more about the key decisions being made now (or soon) about contamination management and clean up. Similarly, at the recent meeting held by SKEO and EPA, representatives were resistant to answering public questions beyond the scope of the TASC report. Limiting what information will be given to the public to arbitrarily defined packages does not support meaningful engagement or transparency as defined by the law. I agree with other suggestions that Evergreen and others focus future discussion on critical paths for decision making about management of risks to adjacent communities and the ecological future of the site. As this meeting approaches its end, will you commit to a part 2 of this meeting, soon, to discuss decision making?](https://phillyrefinerycleanup.info/questions/tonights-information-session-evergreen-note-refers-to-the-august-27-2020-public-information-session-offers-a-strong-basic-primer-on-geology-groundwater-and-characterization-of-the-conta/) - DEP requested Evergreen to re-open the comment period for previously submitted Act 2 reports and provide a venue where the information contained in those reports would be presented to the public. This was also echoed by the request from the City to begin and end the comment period with meetings about those previously submitted Act
- [Many of the finalized online reports reflect reviews done between 2011 to 2016 with no updates. How can I learn what happened next? Is there a person to contact with specific, referenced questions, which would be onerous for a Zoom conference?](https://phillyrefinerycleanup.info/questions/many-of-the-finalized-online-reports-reflect-reviews-done-between-2011-to-2016-with-no-updates-how-can-i-learn-what-happened-next-is-there-a-person-to-contact-with-specific-referenced-questions-wh/) - Remedial Investigation Reports do not get updated once approved. Once RIRs are completed and approved, other reports are submitted with additional information, activities, and updates in the Act 2 process. Evergreen has multiple reports planned for 2021 and will provide a draft schedule on the website of upcoming reports. We have also provided copies of
- [Why did it take 10+ years, and an almost-catastrophic explosion, for Evergreen to come back and engage the public?  Why was Evergreen so delinquent in doing the outreach associated with the legal/contracted obligations to this site? Until the massive explosion, the community at large had not heard from them in years and their outreach/engagement was pitiful.](https://phillyrefinerycleanup.info/questions/why-did-it-take-10-years-and-an-almost-catastrophic-explosion-for-evergreen-to-come-back-and-engage-the-public/) - The June 2019 fire at the PES facility does not relate to Evergreen’s Act 2 submittals or public involvement plan. Since Atlantic/Sunoco purchased the refinery, there have been 21 Act 2 reports submitted and, at the time of each submission (as well as at the time of each of three Notices of Intent to Remediate
- [Does Evergreen consider the 11/7 "event" a formal meeting, and if so, does this start the timeline for them? If it does not, when will the next meeting be held?](https://phillyrefinerycleanup.info/questions/does-evergreen-consider-the-11-7-event-a-formal-meeting-and-if-so-does-this-start-the-timeline-for-them-if-it-does-not-when-will-the-next-meeting-be-held/) - Evergreen was disappointed that entrances were blocked at the planned meeting on Nov. 7, 2019, preventing members of the community and agency officials from engaging in a discussion about the environmental condition of the refinery property. Evergreen views the public engagement process for the site as ongoing, as comments and questions from the public have
- [Thank you for doing your best to use plain language and take the measures you have to try to include the public, as is required by Act 2. Will you hold more regular small group sessions, as a necessary precursor to the public being able to submit educated comments? Information only presented in a one-way format does not enable true public engagement.](https://phillyrefinerycleanup.info/questions/thank-you-for-doing-your-best-to-use-plain-language-and-take-the-measures-you-have-to-try-to-include-the-public-as-is-required-by-act-2-will-you-hold-more-regular-small-group-sessions-as-a-necessar/) - Evergreen has offered to community groups, such as Philly Thrive, to meet in smaller group settings to answer questions concerning the Site. Evergreen will work with the community to develop the best format to engage in smaller group settings as part of the Act 2 process.
- [Public Participation that begins after the all the information is gathered, everything decided and recommendations are ready to be presented to the public is not adequate public participation. Public participation must begin at the beginning, not the end or near the end.](https://phillyrefinerycleanup.info/questions/public-participation-that-begins-after-the-all-the-information-is-gathered-everything-decided-and-recommendations-are-ready-to-be-presented-to-the-public-is-not-adequate-public-participation-public/) - Sunoco submitted a public notice at the time of the Notice of Intent to Remediate (NIR) that started the Act 2 process, and similarly when the NIR was updated two times afterwards. In addition, Sunoco/Evergreen completed public notice when each of the 21 Act 2 reports were submitted to the PADEP. Evergreen also held a
- [How is it determined what ground pollution is from 2012 and before...and what is from 2012 to the present?](https://phillyrefinerycleanup.info/questions/how-is-it-determined-what-ground-pollution-is-from-2012-and-before-and-what-is-from-2012-to-the-present/) - When the facility was sold to PES in 2012, Sunoco had a good understanding of the nature and extent of contamination at the facility. After the sale of the property, if changes in the contaminant profile on-site occurred, or known spills happened, the resulting cleanup became PES’ responsibility. In some instances, new contamination co-exists with
- [The site contains two refineries (at Point Breeze and Girard Point). What is the story for each refinery?](https://phillyrefinerycleanup.info/questions/the-site-contains-two-refineries-at-point-breeze-and-girard-point-what-is-the-story-for-each-refinery/) - While the question is a bit open-ended and capable of multiple interpretations, we interpret this question to be generally inquiring about the ownership history of the two refineries. As specified on the website, Point Breeze (which includes AOIs 1, 2, 3 4, and 8) was formerly owned by Atlantic Richfield Company (ARCO) and purchased by
- [I thought the refinery was to be permanently shut down following the explosion in June of 2019? Will the refinery be permanently shut down?](https://phillyrefinerycleanup.info/questions/i-thought-the-refinery-was-to-be-permanently-shut-down-following-the-explosion-in-june-of-2019-will-the-refinery-be-permanently-shut-down/) - Evergreen is responsible only for the historic (pre-2012) contamination that exists below the surface in soil and groundwater at the Site. Because of that, our work includes investigating and cleanup of the extent of contamination in the subsurface that existed before the sale of the facility from Sunoco to Philadelphia Energy Solutions (PES) in 2012.
- [Please explain the formal, legal, and/or organization ties that Evergreen has to Sunoco and/or Energy Transfer.](https://phillyrefinerycleanup.info/questions/please-explain-the-formal-legal-and-or-organization-ties-that-evergreen-has-to-sunoco-and-or-energy-transfer/) - Evergreen is an affiliate of Sunoco (R&M), LLC (formally known as Sunoco, Inc. (R&M), a former operator of the refinery), and both companies are indirect subsidiaries of Energy Transfer L.P. In November 2013, Evergreen was formed to manage Sunoco’s legacy environmental cleanup at the Philadelphia Refinery. Response also answers a similar question: What is [Evergreen’s]
- [Could you explain Evergreen’s exact relationship with the refinery?](https://phillyrefinerycleanup.info/questions/could-you-explain-evergreens-exact-relationship-with-the-refinery/) - Evergreen is an affiliate of Sunoco (R&M), LLC (formally known as Sunoco, Inc. (R&M), a former operator of the refinery), and both companies are indirect subsidiaries of Energy Transfer L.P. In November 2013, Evergreen was formed to manage Sunoco’s legacy environmental cleanup at the Philadelphia Refinery. By legacy, we mean that Sunoco retained responsibility for
- [PFAS - Fire fighting and training exercises have released PFAS (“forever carcinogens”) at the site. Evergreen ignores this legacy and recent contamination. PFAS should be sampled for and included in remediation planning and activities.](https://phillyrefinerycleanup.info/questions/pfas-fire-fighting-and-training-exercises-have-released-pfas-forever-carcinogens-at-the-site-evergreen-ignores-this-legacy-and-recent-contamination-pfas-should-be-sampled-for-a/) - PFAS had not been sampled during the Remedial Investigations as it was not included as a Contaminant of Concern. However, as noted during public meetings, PADEP and Evergreen have had discussions regarding future sampling of these compounds. A formal request was subsequently received from PADEP to sample remediation system effluents for PFAS compounds. Upon receipt
- [2 Questions: 1) Have you reached out to Hilco about their clean-up efforts? Will you be monitoring them for accountability over severe toxic chemical spills in the water and soil?  2)I believe that Hilco must provide up-to-date, factually correct, and timely information about the status of the site’s pollution and the harm pollutants at the site (past, present, and future) and inflicting upon neighboring communities. Currently the burden of asthma and cancer around the site suggest that there are significant health risks that need to be remediated and addressed by Hilco. This solution must include more time for public comment and collaborative and meaningful engagement with residents of neighboring communities impacted by legacy contamination and who will be affected by development.](https://phillyrefinerycleanup.info/questions/have-you-reached-out-to-hilco-about-their-clean-up-efforts-will-you-be-monitoring-them-for-accountability-over-severe-toxic-chemical-spills-in-the-water-and-soil/) - Evergreen will continue to communicate and work with Hilco Redevelopment Partners during their redevelopment so that our investigation and remediation (cleanup of the historic contamination) can continue during their redevelopment activities. Evergreen’s cleanup plan, which will address contamination in soil and groundwater existing up to the date of the sale of the facility to PES
- [If Hilco is going to help Evergreen throughout the cleanup, then why aren't they on this call and subsequent PIP meetings? (Evergreen note: question referring to the 8/27/20 public information session)](https://phillyrefinerycleanup.info/questions/if-hilco-is-going-to-help-evergreen-throughout-the-cleanup-then-why-arent-they-on-this-call-and-subsequent-pip-meetings-evergreen-note-question-referring-to-the-8-27-20-public-information-sessio/) - Evergreen is responsible for the remedial investigation and cleanup work that is the subject of this meeting and the August 27, 2020 meeting. Specifically, Evergreen is responsible for former Sunoco releases/liabilities that occurred prior to September 2012. Hilco Redevelopment Partners and Evergreen are working together during the site development to ensure that Evergreen’s remediation activities
- [Does your careful evaluation of pollutant concentrations, water levels, plumes etc. take account of future rises in sea level due to global warming, the fact that some portion of the site (perhaps most of it) will be underwater by the end of the century), also the value of restoring some of the site to the wetland it used to be for relation between land and water?](https://phillyrefinerycleanup.info/questions/does-your-careful-evaluation-of-pollutant-concentrations-water-levels-plumes-etc-take-account-of-future-rises-in-sea-level-due-to-global-warming-the-fact-that-some-portion-of-the-site-perhaps-mos/) - The remedial investigations performed to date sought to characterize the facility’s current and past conditions, delineate petroleum contamination, and form a basis for making predictions of future conditions. Evergreen recognizes that changes to climate are predicted to occur and may impact the facility in the future, and that these changes should be evaluated within the
- [It seems like many of the RIRs are still pending despite Hilco's plans to start construction in 2021. 1) What AOIs are planned to be clear to build in 2021 and 2) what are the states of their RIR and Remedial Action Reports such that building can occur so soon. 3)If they are starting in the North, AOI 8 has an identified benzene plume that exceeds the site boundary to the north. There is a sample point in the lower aquifer on the boundary that is outside of the active and inactive remediation boundaries. What are the remediation activities that need to be done prior to construction to address these needs?](https://phillyrefinerycleanup.info/questions/it-seems-like-many-of-the-rirs-are-still-pending-despite-hilcos-plans-to-start-construction-in-2021-1-what-aois-are-planned-to-be-clear-to-build-in-2021-and-2-what-are-the-states-of-their-rir-and/) - Hilco Redevelopment Partners’ construction schedule is not dependent on completion of Evergreen’s remediation activities. Operation of Evergreen’s remediation systems in the North Yard (AOI 8) and in other areas of the site will continue during and after Hilco Redevelopment Partners’ decommissioning, demolition, and redevelopment activities. Hilco Redevelopment Partners and Evergreen have been and will continue
- [Evergreen has described petrochemical recovery results. But information has not been provided about how contamination conditions have changed over time or what the current situation is. Hilco plans to replace the existing systems, but no information has been provided as to what or why such replacement is appropriate.](https://phillyrefinerycleanup.info/questions/water-treatment-evergreen-has-described-petrochemical-recovery-results-but-information-has-not-been-provided-about-how-contamination-conditions-have-changed-over-time-or-what-the-current-situation/) - Remediation systems are reviewed in the Remedial Investigation Reports. The RIRs also all include a qualitative fate and transport discussion, which addresses how conditions have changed over time. It is not expected that Hilco will need to replace any of Evergreen’s remediation systems because Hilco and Evergreen are working together to limit disruption to Evergreen’s
- [Off-Site Contamination - Benzene pools extend beyond the property fence line but have not been mapped. Evergreen fails to acknowledge potential responsibility for cleaning up off-site contamination of benzene or other contaminants.](https://phillyrefinerycleanup.info/questions/off-site-contamination-benzene-pools-extend-beyond-the-property-fence-line-but-have-not-been-mapped-evergreen-fails-to-acknowledge-potential-responsibility-for-cleaning-up-off-site-contamination-of/) - The RIRs and figures presented during the Aug. 27, 2020, Public Information Session show the known extent of dissolved benzene on- and off-site. Evergreen will be including additional off-site groundwater information in the AOI 9 and AOI 4 RIR Addendums. As addressed in other related comments, no off-site air impacts have been identified from off-site
- [Is the water table or the lower aquifer the source of drinking water for anyone?](https://phillyrefinerycleanup.info/questions/is-the-water-table-or-the-lower-aquifer-the-source-of-drinking-water-for-anyone/) - The water table and lower aquifers are not utilized as sources of potable water in proximity to the Site. As a part of the investigations, Evergreen conducted a well search within a one-mile radius of the Site using Pennsylvania’s Groundwater Information System (PaGWIS) and PADEP’s eMapPA GIS mapping tool. Results of the search, which included
- [Who pays evergreen to do this work?](https://phillyrefinerycleanup.info/questions/who-pays-evergreen-to-do-this-work/) - Evergreen is an indirect subsidiary of Energy Transfer. Evergreen is fully capitalized to fund the remediation of the site.
- [What sampling has been done of the water and sediment in the Schuylkill River?](https://phillyrefinerycleanup.info/questions/what-sampling-has-been-done-of-the-water-and-sediment-in-the-schuylkill-river/) - There has been no direct sampling conducted by Evergreen in the Schuylkill River. An ecological risk assessment has been completed, which evaluated site conditions in relation to the surface water and sediment in the Schuylkill River. This will be submitted after the RIRs are approved in accordance with the Act 2 requirements. Going forward, the
- [We are also requesting that OSHA inspects the site and provides the community with a detail report ensuring that all OSHA precautions are adhered to.](https://phillyrefinerycleanup.info/questions/we-are-also-requesting-that-osha-inspects-the-site-and-provides-the-community-with-a-detail-report-ensuring-that-all-osha-precautions-are-adhered-to/) - Since Sunoco no longer owns or operates the Site, any OSHA inspections should be coordinated with the new site owner, Hilco.
- [Unfortunately, there are a few things that I am concerned with as well, including recycling the debris and where are they going to take it?](https://phillyrefinerycleanup.info/questions/unfortunately-there-are-a-few-things-that-i-am-concerned-with-as-well-including-recycling-the-debris-and-where-are-they-going-to-take-it/) - Evergreen provided this question to Hilco Redevelopment Partners, who provided the following response: Approximately 30,000 tons of Asbestos Containing Material (ACM) will be safely abated and disposed of in close coordination with the City of Philadelphia and other regulatory agencies such as PaDEP, USEPA, OSHA etc. and per all applicable standards and regulations.
- [The dates for final completion was originally set for December 31, 2020 but was extended for 10 years to December 31, 2030. Why?  In reference to the deadline, why ten years instead of 3 to 4 years for example?](https://phillyrefinerycleanup.info/questions/the-dates-for-final-completion-was-originally-set-for-december-31-2020-but-was-extended-for-10-years-to-december-31-2030-why/) - The extension to the cleanup deadline was agreed by Sunoco and the PADEP in the CO&A amendment in 2020 because of bankruptcy of PES and impending acquisition of the property by Hilco, which included a substantial and material change in the use of the site. Evergreen must coordinate its Act 2 timeline with Hilco’s redevelopment
- [What questions has Skeo asked to Evergreen? Were the answers received satisfactory? What unanswered questions does Skeo have for Evergreen?  [Question refers to a question asked of EPAs contractor that reviewed past Act 2 reports per their TASC program]](https://phillyrefinerycleanup.info/questions/what-questions-has-skeo-asked-to-evergreen-were-the-answers-received-satisfactory-what-unanswered-questions-does-skeo-have-for-evergreen-question-refers-to-a-question-asked-of-epas-contractor-tha/) - Skeo has not asked Evergreen any specific questions about the RIRs. Evergreen has reviewed the Q&A that was part of Skeo’s report and has included any questions that were included in Skeo’s report that were not subsequently asked to Evergreen, as described in Section 1.0.
- [Evergreen and Hilco may have a reasonable and actionable agreement about how the cleanup is divided between you, but the public has no idea whether there is one. It’s illogical for Evergreen to be working on a remediation project, and do an incomplete job on an area because some of the contaminants arrived after PES bought it. Or vice-versa.](https://phillyrefinerycleanup.info/questions/evergreen-and-hilco-may-have-a-reasonable-and-actionable-agreement-about-how-the-cleanup-is-divided-between-you-but-the-public-has-no-idea-whether-there-is-one-its-illogical-for-evergreen-t/) - In 2006, Sunoco voluntarily entered the site into Act 2 and Evergreen, since 2013, has been managing the legacy (pre-sale in 2012) site investigation and remediation. PES/Hilco are separately managing post-sale in 2012 releases. Both Evergreen and Hilco separately report to the PADEP on their respective efforts. Sunoco, PES and PADEP entered into a Consent
- [How can you tell whose benzene is whose?](https://phillyrefinerycleanup.info/questions/how-can-you-tell-whose-benzene-is-whose/) - In general, where there are potentially off-site and/or on-site sources that may explain the presence of benzene, factors such as the respective products used at a site, release history and/or environmental conditions – such as geology and hydrogeology, which govern how those products behave in the subsurface - may assist in identifying a source. Where
- [What was your process for hiring the local consultants. Was there any review of consultants by residents/public?](https://phillyrefinerycleanup.info/questions/what-was-your-process-for-hiring-the-local-consultants-was-there-any-review-of-consultants-by-residents-public/) - Evergreen considered several factors in selecting consultants at this site including but not limited to a thorough evaluation of the consultants’ past experience at similar sites; for example, have they worked at refineries before and/or have they worked on petroleum sites before.
- [Trucks with no identifying logos or signage are going into and out of the property and more smoke is coming off of the property lately. Does Evergreen know what is going on with these situations? Is this Evergreen-related or Hilco-related?](https://phillyrefinerycleanup.info/questions/trucks-with-no-identifying-logos-or-signage-are-going-into-and-out-of-the-property-and-more-smoke-is-coming-off-of-the-property-lately-does-evergreen-know-what-is-going-on-with-these-situations-is-t/) - Evergreen provided this question to Hilco Redevelopment Partners, who provided the following response: Some trucks should be on site assisting HRP in transforming the site. We have a security check point that everyone must register and produce identification.
- [Hilco was responsible for an appalling failure during remediation that put local residents, an immigrant-heavy, environmental justice community, at risk. As part of the remediation process, they had to demolish the former smoke stack from the Plant. Although they had all of the permits necessary, they still completed it in such a way that sent a cloud of potentially toxic chemicals into the air. Chicago Mayor, Lori Lightfoot, commented that “The city was given repeated assurances that Hilco had a solid plan to contain the dust. Clearly that didn’t happen,” Lightfoot said. “This is absolutely and utterly unacceptable. It’s unsafe, it’s unsanitary. I would not tolerate this in my neighborhood and we’re not going to tolerate it here either.” Ultimately, because of the danger that Hilco created to the community, Hilco agreed to pay $370,000 to settle a lawsuit filed by the State.](https://phillyrefinerycleanup.info/questions/hilco-was-responsible-for-an-appalling-failure-during-remediation-that-put-local-residents-an-immigrant-heavy-environmental-justice-community-at-risk-as-part-of-the-remediation-process-they-had-t/) - Evergreen provided this question to Hilco Redevelopment Partners, who provided the following response: We have partnered with a best in class demolition contractor who has a great deal of experience demolishing refineries and a strong presence in Philadelphia. They will be implementing an extensive dust mitigation plan and will be working with all appropriate agencies
- [Evergreen’s priority during the cleanup should be beautifying the riverbank in a way that will adapt with rising water levels.](https://phillyrefinerycleanup.info/questions/evergreens-priority-during-the-cleanup-should-be-beautifying-the-riverbank-in-a-way-that-will-adapt-with-rising-water-levels/) - Any site improvements are being conducted by the property owner, Hilco Redevelopment Partners, as part of its redevelopment activities.
- [I’m especially interested in the Schuylkill River Bike Path improvements, and would like to get on your email list with redevelopment progress and updates.](https://phillyrefinerycleanup.info/questions/im-especially-interested-in-the-schuylkill-river-bike-path-improvements-and-would-like-to-get-on-your-email-list-with-redevelopment-progress-and-updates/) - Site improvements such as this are being conducted by the property owner, Hilco Redevelopment Partners, as part of their redevelopment activities. However, we have added you to Evergreen’s email list for future notices regarding legacy remediation (any person submitting a comment or question has been added to the distribution list for future communications).
- [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?](https://phillyrefinerycleanup.info/questions/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 Investigations.
- [I would also like to know your plan for holding Sunoco responsible for the decades of destructive pollution they caused in our city. This pollution has had direct impacts on community health in the surrounding neighborhood and has fueled the devastating climate crisis now impacting us all.](https://phillyrefinerycleanup.info/questions/i-would-also-like-to-know-your-plan-for-holding-sunoco-responsible-for-the-decades-of-destructive-pollution-they-caused-in-our-city-this-pollution-has-had-direct-impacts-on-community-health-in-the-su/) - Sunoco is responsible for cleaning up soil and water contamination generated prior to the sale of the facility in September 2012. Evergreen is managing this cleanup.
- [The benzene graphic is different from one previously presented, which showed different levels of concentration for benzene on and off the site. (Evergreen note: comment refers to slide 38 “Groundwater Investigation Results: Benzene” from the August 27, 2020 Public Information Session).  The arrow that is pointing to "offsite benzene source areas" is pointing to a residential area and the PGW facility (just west of I76). Who is responsible for cleaning up the off-site contamination under the residential area?](https://phillyrefinerycleanup.info/questions/the-benzene-graphic-is-different-from-one-previously-presented-which-showed-different-levels-of-concentration-for-benzene-on-and-off-the-site-evergreen-note-comment-refers-to-slide-38-gro/) - The benzene graphic was modified to simplify the presentation and to depict where benzene is predicted to be present above the Statewide Health Standard in the water table. The purple arrows were drawn to denote other offsite properties that are active in Pennsylvania’s Act 2 program that have benzene sources in groundwater. These include the
- [Has NJ DEP been involved with any issues on the NJ side of the Delaware River? Have public and municipal water companies in NJ been notified about pollution in the PRM Aquifer water supply? Have they been notified about AOI 11 efforts by PA DEP and EPA?](https://phillyrefinerycleanup.info/questions/has-nj-dep-been-involved-with-any-issues-on-the-nj-side-of-the-delaware-river-have-public-and-municipal-water-companies-in-nj-been-notified-about-pollution-in-the-prm-aquifer-water-supply-have-they/) - The NJDEP is routinely involved with groundwater investigations of the Potomac-Raritan-Magothy aquifer (PRM) due to source areas located in New Jersey that are not related to impacts in AOI 11. There has been no demonstrated connection between groundwater impacts in AOI 11 due to past refinery operations and the PRM groundwater quality in New Jersey.
- [What effect has pollution been in the last 7 years since the last reports on AOI 11 were issued on 6/21/2013?  We understand that contamination has reached the deep aquifer (area of interest 11), which means we need to clean the water too. We’ve learned from the Clean Air Council that “while Evergreen has made available semiannual groundwater reports through the first half of 2020, that information is not part of the reports open for public comment”.](https://phillyrefinerycleanup.info/questions/what-effect-has-pollution-been-in-the-last-7-years-since-the-last-reports-on-aoi-11-were-issued-on-6-21-2013/) - New groundwater data for AOI 11 has been collected since 2013 and it is presented in the Remedial Investigation Reports for each of the other Areas of Interest. Overall, most groundwater conditions in the lower groundwater (AOI 11) have been demonstrated to be stable to improving for petroleum-related compounds since the 2013 RIR was submitted.
- [There has been some concern that because of the aquifer under the water, pollutants from the refinery may impact drinking water in downstream New Jersey. Do you think this was ever a concern? If yes, will it continue to be one even as the refinery shuts down?](https://phillyrefinerycleanup.info/questions/there-has-been-some-concern-that-because-of-the-aquifer-under-the-water-pollutants-from-the-refinery-may-impact-drinking-water-in-downstream-new-jersey-do-you-think-this-was-ever-a-concern-if-yes/) - Evergreen’s role is to evaluate and remediate groundwater conditions created based on use of the facility up through 2012. Based on extensive data collected over the last 20+ years, and groundwater modeling performed to date, it is highly unlikely that groundwater impacts at the former refinery site affect drinking water quality in New Jersey. As
- [There is a benzene pool that extends toward residential neighborhoods of South Philadelphia. In June 2019, PES reported fence line measurements of benzene above regulatory limits. What’s the situation? What corrective actions have been taken?](https://phillyrefinerycleanup.info/questions/there-is-a-benzene-pool-that-extends-toward-residential-neighborhoods-of-south-philadelphia-in-june-2019-pes-reported-fence-line-measurements-of-benzene-above-regulatory-limits-whats-the-s/) - Dissolved benzene in groundwater (otherwise known as a benzene groundwater plume) is present at the former Philadelphia Refinery. The Remedial Investigation Reports summarize the benzene in groundwater that Evergreen has characterized as part of the Act 2 investigations. For example, the AOI 1 RIR presents details concerning benzene in groundwater along the eastern boundary of
- [The hydrological situation is changing. Are you considering remediation strategies with respect to sea-level rise, which could affect groundwater on the site?](https://phillyrefinerycleanup.info/questions/the-hydrological-situation-is-changing-are-you-considering-remediation-strategies-with-respect-to-sea-level-rise-which-could-affect-groundwater-on-the-site/) - Evergreen will detail its approach to remediation of the facility in future Cleanup Plans and will consider climate changes predicted to occur within the anticipated timeframe to completion. Evergreen will also incorporate climate change into future modeling. Response addresses the similar questions: "Are you considering your remediation strategies with respect to sea level rise, which
- [What sea level rise, if any, was the tide gate built to accommodate?](https://phillyrefinerycleanup.info/questions/what-sea-level-rise-if-any-was-the-tide-gate-built-to-accommodate/) - Tide gates are a common flood prevention structure for areas in a tidal zone. Tide gates close during incoming tides to prevent inundation from downstream water propagating inland, and they open during outgoing tides to drain upland areas. The tide gates at the Site were not specifically designed to address sea level rise; however, the
- [Air quality measurements were made within existing buildings, but no air quality data was collected in surrounding neighborhoods or onsite at contaminated locations.](https://phillyrefinerycleanup.info/questions/air-quality-measurements-were-made-within-existing-buildings-but-no-air-quality-data-was-collected-in-surrounding-neighborhoods-or-onsite-at-contaminated-locations/) - Evergreen must investigate air quality arising from subsurface contamination only, not from refinery operations above ground. As documented in the remedial investigation reports (RIRs), air samples were collected from inside site buildings, and from outdoor air locations, both as background and above areas of known LNAPL plumes. Based on the data collected in the RIRs
- [Now I’m smelling and feeling the toxic pollution from the refinery again.](https://phillyrefinerycleanup.info/questions/now-im-smelling-and-feeling-the-toxic-pollution-from-the-refinery-again/) - There is no indication of off-site air impacts from the historic subsurface environmental impacts to soil and groundwater that Evergreen is investigating and remediating. Additional information concerning air quality from either the EPA or the City of Philadelphia may be helpful to identify the source of any smells.
- [This comment regards the benzene groundwater contamination on the Verizon SDWC property and   subsequent properties. There does not seem to be sufficient sampling points located on the properties to the north of N-3 or west of V-MW-9 to accurately estimate the true extent of the plume. Similarly there appears to be insufficient data points to the north east of V-MW-16 on the north part of the Verizon SDWC property to properly determine a contaminant boundary . Was subsequent sampling and monitoring performed alongside I-76 or on the other side of the highway near the Philadelphia Housing Authority building to further delineate offsite impacts? Water level gradients seem to indicate slight a NE flow off of the Verizon SDWC that this report did not consider or investigate.  In addition, the pump-and-treat system along Maiden Ln does not look like it changes the gradient of the plume that extends to the Verizon SDWC property and beyond. What is being done to properly delineate and mitigate this off-site benzene issue?](https://phillyrefinerycleanup.info/questions/this-comment-regards-the-benzene-groundwater-contamination-on-the-verizon-sdwc-property-and-subsequent-properties-there-does-not-seem-to-be-sufficient-sampling-points-located-on-the-properties-to-t/) - The Verizon SDWC property is a separate remediation site. A Site Characterization Report indicating closure via a combination of Statewide Health and Site Specific Standards was submitted by the property owners and approved in 2012. A subsequent SSS Remedial Action Plan was approved in 2012. A Remedial Action Completion Report was submitted in 2015, in
- [Benzene - High levels of benzene are present extensively at the site, and benzene is currently being emitted into the atmosphere.](https://phillyrefinerycleanup.info/questions/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
- [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.](https://phillyrefinerycleanup.info/questions/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-didnt-seem-like-the-soil-to-groundwa/) - 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
- [1) Investigation information is out of date; some data was collected over a decade   ago. Accurate, current conditions must be understood, using recent data, to develop appropriate remediation plans. 2) I am writing to state that the RIRs presented are so flawed that even those that were previously approved by DEP (without adequate public review) need to be rejected, improved significantly at least as described below and in other’s detailed comments, and then resubmitted for public review and comment before they are used to develop long-term remediation plans. It is not necessary to stop ongoing remediation, but future remediation should not be limited by using incomplete and potentially inaccurate data.  (three additional similar questions with answer below)](https://phillyrefinerycleanup.info/questions/current-conditions-investigation-information-is-out-of-date-some-data-was-collected-over-a-decade-ago-accurate-current-conditions-must-be-understood-using-recent-data-to-develop-appropriate-rem/) - It is important to remember that Evergreen is responsible for investigating and remediating contamination that was present up until the time of the sale of the facility to Philadelphia Energy Solutions (PES) in 2012. Any releases or emissions from refinery operations or other site activities after 2012 are the responsibility of the new property owners.
- [Similar questions: 1) Can you comment on why AOI 11 deep groundwater report has not yet been approved?”  2) AOI 11 has deep aquifer contamination that was not accepted by the DEP. Please discuss the extent of pollution, its evaluation and anticipated cleanup timeline.](https://phillyrefinerycleanup.info/questions/can-you-comment-on-why-aoi11-deep-groundwater-report-has-not-yet-been-approved/) - There were both an AOI 11 Remedial Investigation Report and a Final Report that were submitted. Both were disapproved solely for the fate and transport analysis that was included in the reports. The remedial investigation portion of those reports were acceptable. Note that before we started a site wide model concept, each of the AOI
- [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.](https://phillyrefinerycleanup.info/questions/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/) - 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
- [When will the revised RIRs for AOIs 4, 9 and 11 be submitted?](https://phillyrefinerycleanup.info/questions/when-will-the-revised-rirs-for-aois-4-9-and-11-be-submitted/) - The Remedial Investigation Addendums for AOI 4 and 9 will be submitted once the public comment period for the approved Remedial Investigation Reports is completed and a summary document is submitted and approved by the PADEP. The investigation of the deep groundwater unit (AOI 11) has been incorporated into the other Remedial Investigation Reports since
- [Are drinking water intake portals downstream from the site. All the way to the Delaware Bay?](https://phillyrefinerycleanup.info/questions/are-drinking-water-intake-portals-downstream-from-the-site-all-the-way-to-the-delaware-bay/) - As a part of the investigations, Evergreen conducted a well search including field reconnaissance within a one-mile radius of the Site using Pennsylvania’s Groundwater Information System (PaGWIS) and PADEP’s eMapPA GIS mapping tool. Search results did not identify potable water supply wells in the area. We also conducted a search of surface water intakes from
- [When will Evergreen conduct the fate and transport analysis for the lower aquifer? There is no aquitard between upper and lower aquifer across most of the site. Won't the heavily contaminated shallow aquifer gradually leach contaminants into the lower aquifer? (a critical drinking water source for New Jersey)](https://phillyrefinerycleanup.info/questions/when-will-evergreen-conduct-the-fate-and-transport-analysis-for-the-lower-aquifer-there-is-no-aquitard-between-upper-and-lower-aquifer-across-most-of-the-site-wont-the-heavily-contaminated-shallow/) - The fate and transport analysis for the lower aquifer will be performed once the Remedial Investigation Reports for AOI 4 and AOI 9 have been approved. Areas beneath the Site where connections exist between the lower aquifer and water table aquifer are less extensive than the areas where we have that important clay layer present.
- [Is there a permit for the discharge of water from the wastewater treatment system to the PWD, who is the permit holder, and have the permit requirements been met?](https://phillyrefinerycleanup.info/questions/is-there-a-permit-for-the-discharge-of-water-from-the-wastewater-treatment-system-to-the-pdw-who-is-the-permit-holder-and-have-the-permit-requirements-being-met/) - Evergreen has a permit for discharge from a remediation system directly to the PWD and is not the permittee for the onsite wastewater treatment plant.
- [A) On the Q+A page, responding to the question “The hydrological situation is changing …” Evergreen’s response includes the words “climate changes predicted to occur within the anticipated timeframe to completion will be considered.” B) On the Q+A page, responding to the question “Climate change-generated sea-level rise (Schuylkill, Delaware) is a given” Evergreen’s response includes the words “… i.e., how many years are predicted for Evergreen to meet Cleanup goals under Act 2 compared to the magnitude of climate change predictions within that general time period.” Both of these responses imply that only the amount of sea-level rise that occurs during the clean-up operation will be considered. However, sea level rise will continue to affect the site for decades, or perhaps centuries. 1. Can Evergreen confirm (in plain English) that it is only considering sea-level rise for the duration of the remediation project? 2. If so, why is Evergreen not considering long-term sea level rise and its impact on aquifers into account, when considering the remediation plans for the site?](https://phillyrefinerycleanup.info/questions/a-on-the-qa-page-responding-to-the-question-the-hydrological-situation-is-changing-evergreens-response-includes-the-words-climate-changes-predicted-to/) - It is Evergreen’s intent to consider climate changes predicted to occur within the timeframe of cleanup of the former Sunoco refinery. In general, this timeframe would be considered “long term” as petroleum contaminants in groundwater may take decades to remediate and/or degrade to concentrations below regulated standards. Follow-up question to the question above: Can you
- [Two questions on fill: 1) Could you talk more about the topmost ‘fill’ layer in the Environmental Setting slides … how deep is this fill, what is it composed of? When was it added there? Thank you!  2)What is the composition of the layer labeled ‘Fill’? Does Evergreen know from where the fill was obtained? Is river dredging/channel widening one possible source for this fill?](https://phillyrefinerycleanup.info/questions/two-questions-on-fill-1-could-you-talk-more-about-the-topmost-fill-layer-in-the-environmental-setting-slides-how-deep-is-this-fill-what-is-it-composed-of-when-was-it-ad/) - Much of the former refinery and surrounding area is underlain by historic fill material, which was primarily placed for the purpose of reclaiming lowlands along the banks of the tidal Delaware and Schuylkill Rivers during industrialization. The fill materials are heterogeneous in nature and have been characterized as a mixture of compacted soil and anthropogenic
- [Evergreen’s proposed site-specific standard for lead in surface soil at the former refinery site will not be protective of public health. I strongly urge you to withdraw the proposal to set a site-specific standard of 2,240 mg/kg. Evergreen’s proposed site-specific standard is more than twice the direct contact numeric value in state regulations (1,000 mg/kg). Evergreen made a flawed assumption about the target blood lead level to adequately protect a fetus of a worker at the site – an important factor in determining the site-specific standard for lead. It used a level that is twice the reference value that the Centers for Disease Control and Prevention uses to address lead exposure in children. Evergreen should be using the current science to set a site-specific standard for this site.](https://phillyrefinerycleanup.info/questions/evergreens-proposed-site-specific-standard-for-lead-in-surface-soil-at-the-former-refinery-site-will-not-be-protective-of-public-health-i-strongly-urge-you-to-withdraw-the-proposal-to-set-a/) - 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) and the direct contact Statewide Standard, which is 1000 ppm, as well as the Site Specific Standard. This comparison is shown on the figures/tables in the Remedial Investigation Reports
- [Will the site-specific standard be at least as stringent as the statewide standards?](https://phillyrefinerycleanup.info/questions/will-the-site-specific-standard-be-at-least-as-stringent-as-the-statewide-standards/) - There will be a combination of statewide health and site-specific standards at this site. The lead site specific standard calculated for the Site utilized the Adult Lead Model and the standard PADEP default assumptions. Use of the ALM resulted in a lead site specific standard that was higher than the statewide health standard, but protective
- [Evergreen should make available on its website all historical reports referenced in Appendix A of the 2004 Current Conditions Report.](https://phillyrefinerycleanup.info/questions/evergreen-should-make-available-on-its-website-all-historical-reports-referenced-in-appendix-a-of-the-2004-current-conditions-report/) - The 2004 Current Conditions Report is not an Act 2 document, nor are the documents referenced in that report. However, many available documents referenced in Appendix A of the Current Conditions Report are posted on the for reference.
- [Will Evergreen be incorporating climate resilience into its groundwater modeling?](https://phillyrefinerycleanup.info/questions/will-evergreen-be-incorporating-climate-resilience-into-its-groundwater-modeling/) - A literature review of available, published resources on climate change for the Philadelphia region and discussion of the potential implications to Evergreen’s groundwater model will be included in the upcoming Fate and Transport RIR. Evergreen’s groundwater flow model for the former Philadelphia Refinery has been calibrated and validated to recent environmental conditions and measured observations.
- [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?](https://phillyrefinerycleanup.info/questions/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
- [And for waste that is removed, please spell out which communities that waste will be dumped on, at which facilities, the type of facility, the demographics around that facility, and whether this violates Title VI of the Civil Rights Act.](https://phillyrefinerycleanup.info/questions/and-for-waste-that-is-removed-please-spell-out-which-communities-that-waste-will-be-dumped-on-at-which-facilities-the-type-of-facility-the-demographics-around-that-facility-and-whether-this-viola/) - Transportation, storage, and disposal (TSD) facilities are regulated by the EPA under the Resource Conservation and Recovery Act (RCRA) through which guidance on hazardous and non-hazardous waste has been developed. Wastes that may be removed from the former refinery facility could go to various different regulated TSD facilities, which will be determined at the time
- [1) I’m worried about Hydrofluoric acid or HF because if it gets into the neighborhood and someone throws a cigarette and it hits it, the whole neighborhood will blow up causing massive casualties.  2) Another concern I have is about Butane because this is the second large chemical in there this is lighter fluid and if it’s the right pressure and temperature then this will blow up also, this was the gas that blow up in the first place and if this was in a neighborhood it would be like a nuclear bomb exploded. 3) Another concern I have is about nickel carbonyl because nickel carbonyl is very toxic and can cause chronic bronchitis, reduced lung function, and lung and nasal cancer if breathed in.](https://phillyrefinerycleanup.info/questions/1-im-worried-about-hydrofluoric-acid-or-hf-because-if-it-gets-into-the-neighborhood-and-someone-throws-a-cigarette-and-it-hits-it-the-whole-neighborhood-will-blow-up-causing-massive-casualt/) - These comments refer to chemicals used in petroleum refining processes and concerns with potential gas phase/ambient air conditions. Evergreen cannot address concerns regarding use of these chemicals as Evergreen is responsible solely for contamination in the subsurface and from releases prior to 2012.
- [To what extent will you be using bioremediation technology?](https://phillyrefinerycleanup.info/questions/to-what-extent-will-you-be-using-bioremediation-technology/) - Evergreen is currently using a form of biotechnology at the site for interim remedial activities. We have two biofilters on site, which take the vapors pulled out of the sewers and treat them through those filters. Bioremediation technology is not currently used to treat any groundwater. Most systems onsite currently are in place to prevent
- [Evergreen has not sufficiently answered questions from the public on its Q&A Webpage.](https://phillyrefinerycleanup.info/questions/evergreen-has-not-sufficiently-answered-questions-from-the-public-on-its-qa-webpage/) - Evergreen is continually reviewing the Q&A to determine what updates are needed to be included in the Public Comment RIR. The Q&A webpage will be updated as any answers are updated as part of this process. Also note that some questions/comments cannot be addressed fully as the subject matter may be part of future site
- [Can anything be built there after the cleanup?](https://phillyrefinerycleanup.info/questions/can-anything-be-built-there-after-the-cleanup/) - What is built at the property is not determined by Evergreen; however, the future use of the site must remain non-residential.
- [What direct communication have you had with hilco? They seem unaware of the data you shared that shows how dangerous the site remains and yet Hilco is marketing and promoting the redevelopment of PES site as safe for businesses.](https://phillyrefinerycleanup.info/questions/what-direct-communication-have-you-had-with-hilco-they-seem-unaware-of-the-data-you-shared-that-shows-how-dangerous-the-site-remains-and-yet-hilco-is-marketing-and-promoting-the-redevelopment-of-pes/) - Evergreen is in direct communication with Hilco regarding our activities and how that may impact their planned site activities. Evergreen has shared, and plans to continue to share, all data with Hilco.
- [Did you say that Evergreen will cleanup as Hilco redevelops/builds?](https://phillyrefinerycleanup.info/questions/did-you-say-that-evergreen-will-cleanup-as-hilco-redevelops-builds/) - Partially. Evergreen has been remediating the site for years and remediation is ongoing. Therefore, Evergreen will have some remedial measures in place before Hilco redevelops an area of the Site, and some remedial measures are part of the development (for example capping and vapor mitigation measures in a building, if warranted). The timing of the
- [These graphics (Evergreen note: assumption is reference to graphics from the August 27th Public Information Session relating to remediation) all show problems relating to gasses and water...not contaminated soil. Will soil be removed and replaced with clean soil?](https://phillyrefinerycleanup.info/questions/these-graphics-evergreen-note-assumption-is-reference-to-graphics-from-the-august-27th-public-information-session-relating-to-remediation-all-show-problems-relating-to-gasses-and-water-not-contam/) - The remediation systems operated at the site historically and currently were installed to address groundwater or vapors since those represented potential risk pathways, which is why they were shown during the August 27th Public Information Session. The purpose of the information session was to review historic reports which include mostly Remedial Investigation Reports. Remedial plans
- [These are very informative graphics (referring to the August 27th Public Information Session). What about removal of contaminants that are in the soil? Lead cannot be pumped out. All the soil must be removed.](https://phillyrefinerycleanup.info/questions/these-are-very-informative-graphics-referring-to-the-august-27th-public-information-session-what-about-removal-of-contaminants-that-are-in-the-soil-lead-cannot-be-pumped-out-all-the-soil-must-be/) - Contamination in soil can be dealt with in many ways. Some areas of soil impact have been excavated previously. Soil remediation can also include institutional and engineering controls which eliminate a risk by blocking a pathway of exposure. Remedial plans for all media will be detailed in the Cleanup Plan(s).
- [We are still waiting on a city response to our request for a public hearing on Evergreen’s existing remediation infrastructure, including vents that emit fumes coming from underground pollutants.](https://phillyrefinerycleanup.info/questions/we-are-still-waiting-on-a-city-response-to-our-request-for-a-public-hearing-on-evergreens-existing-remediation-infrastructure-including-vents-that-emit-fumes-coming-from-underground-pollutan/) - It is our understanding that Philadelphia Air Management Services (AMS) will hold a public hearing on the draft Natural Minor Operations Permit; however, Evergreen is not aware of the timing. Questions regarding the permit application and timing of future public hearings should be directed to Philadelphia AMS.
- [Can we get some documentation saying that your company has started cleaning any part of this site?](https://phillyrefinerycleanup.info/questions/can-we-get-some-documentation-saying-that-your-company-has-started-cleaning-any-part-of-this-site/) - Documentation of Evergreen’s ongoing and historic remediation activities are included in each of the Remedial Investigation Reports.
- [Is there any involvement of Hilco, the new owner?](https://phillyrefinerycleanup.info/questions/is-there-any-involvement-of-hilco-the-new-owner/) - Hilco Redevelopment Partners is not involved in Evergreen’s Act 2 program at the site. Hilco Redevelopment Partners will have their own remediation program to manage focused areas where contamination occurred after September 2012; however, the two programs are separate. Evergreen and Hilco Redevelopment Partners will work together to limit disruptions of Evergreen’s remediation program during
- [Hilco has indicated in the Soil Management Report it filed with the City that the site-specific standard for lead required for the HRP intended uses for the site is 1,000 PPM.  Will Evergreen remediate to this 1,000 PPM standard rather than the 2,240 PPM previously approved by PADEP?](https://phillyrefinerycleanup.info/questions/hilco-has-indicated-in-the-soil-management-report-it-filed-with-the-city-that-the-site-specific-standard-for-lead-required-for-the-hrp-intended-uses-for-the-site-is-1000-ppm-will-evergreen-remediat/) - Evergreen’s future cleanup plans will still compare all new soil data to both the statewide health and site-specific values to determine appropriate remedy selection. In addition, Evergreen will reevaluate the current site-specific standard based on DEP’s proposed new soil standards and associated input values.
- [Groundwater needs more attention and testing as well as soil. For one thing, an update is needed to reflect the conditions of both shallow and deep groundwater because of the length of time since the reported sampling, and after years of partial remediation. Contamination in groundwater aquifers does not stay in one place for years! I’m also concerned that the shallow and deep aquifers were presented as being separated by an aquitard, implying that the deeper drinking water aquifer was somehow protected from the high pollution in the more shallow areas. However, the shallow and deep aquifers are not continuously separated, leaving contamination to migrate between them. This is even more concerning since some shallow areas of the aquifer are very close to highly contaminated soil and thus very vulnerable to becoming more contaminated over time. Also, while pumping contamination out of the water has removed a lot of pollution, pumping also alters how quickly and in what direction groundwater (and contamination) moves, and may have increased the movement of contamination between these unconfined aquifers or how far from the refinery the contamination extends. Because of this, it would be prudent to conduct new tests as well as sampling a larger portion of both aquifers.  The current work cannot be evaluated until all analysis about the aquifers is completed. Without that information, the public does not have all of the information to evaluate decisions on soil and groundwater sampling.   Evergreen has not sufficiently delineated the nature and extent of contamination in the deep aquifer and the unconfined aquifer (water table).](https://phillyrefinerycleanup.info/questions/groundwater-needs-more-attention-and-testing-as-well-as-soil-for-one-thing-an-update-is-needed-to-reflect-the-conditions-of-both-shallow-and-deep-groundwater-because-of-the-length-of-time-since-the/) - Evergreen conducts continual groundwater sampling at the facility, not just as part of the RIRs. Sampling is necessary before, during and after remediation is complete; therefore, sampling will continue at this facility for quite some time. The current work under evaluation (what’s included in the RIRs) includes defining the nature and extent of contamination in
- [Could you clarify the period in which you are considering climate change projections? Is it the period of remediation or the post-remediation use of the site? If it’s post-remediation, what assumption are you using for future climate change?](https://phillyrefinerycleanup.info/questions/could-you-clarify-the-period-in-which-you-are-considering-climate-change-projections-is-it-the-period-of-remediation-or-the-post-remediation-use-of-the-site-if-its-post-remediation-what-as/) - At a minimum, we’d be looking at several decades to be considered for climate change projections. This process is ongoing, however, and will continue to be evaluated to see if longer time frames are necessary as the F&T RIR is completed this year.
- [In its remedial investigation, Evergreen should adequately account for the impacts of climate change on existing soil and water contamination. These impacts could occur before, during, and after remediation. Sea-level rise, storm surges, and the increased frequency and volume of events like superstorms could have major implications on the migration of contaminants in the soil and groundwater to the river, and into adjacent residential neighborhoods.](https://phillyrefinerycleanup.info/questions/in-its-remedial-investigation-evergreen-should-adequately-account-for-the-impacts-of-climate-change-on-existing-soil-and-water-contamination-these-impacts-could-occur-before-during-and-after-remed/) - Remedial investigations are evaluations of current conditions. Those current condition measurements would inherently include climate effects as they have occurred and are occurring. The future effects of climate change will be evaluated in future modeling efforts. Note that the future fate and transport modeling is also a remedial investigation activity. The fate and transport modeling
- [When were the outdoor air samples taken?](https://phillyrefinerycleanup.info/questions/when-were-the-outdoor-air-samples-taken/) - The outdoor (ambient) air samples that Evergreen has collected across the site have been collected over many years. Some samples were collected during individual AOI investigations and some were collected as part of a site-wide vapor investigation, generally conducted between 2009 and 2018. Individual sample dates are included in the air data tables within the
- [Why is lead the only metals COC? Aren’t there other contaminants such as copper, cadmium, arsenic that come from refining processes?](https://phillyrefinerycleanup.info/questions/why-is-lead-the-only-metals-coc-arent-there-other-contaminants-such-as-copper-cadmium-arsenic-that-come-from-refining-processes/) - The site was tested for a complete list of metals as part of the 1992 RCRA Facility Investigation and none of these metals, except lead, were found to be a contaminant of concern and therefore were not identified as a contaminant of concern going forward. The 1992 Report is posted on the Evergreen website for
- [Grouped questions: 1) Evergreen may not fragment the Remedial Investigation Reports by diverting its deficiencies into a future Fate and Transport Remedial Investigation Report. 2)Once again, you are dealing with a corporate entity not dedicated to much beyond its profits and quite willing to put the health of its workers and the public at risk. The way this corporation has divided its reports, delayed releasing updates, promises to report later regarding crucial elements of the project that are needed to make a final decision is NOT the kind of behavior we want to see in our region. I find this appalling and needs to be separately addressed.](https://phillyrefinerycleanup.info/questions/grouped-questions-1-evergreen-may-not-fragment-the-remedial-investigation-reports-by-diverting-its-deficiencies-into-a-future-fate-and-transport-remedial-investigation-report-2once-again-you-are/) - All Remedial Investigation Reports do contain Fate and Transport. Earlier AOI reports used the Domenico model to analyze the individual AOI areas. The decision to complete a site-wide Fate and Transport model to be included in a separate Remedial Investigation report allows Evergreen to evaluate groundwater flow and contaminate transport on a site wide basis,
- [Immediate multiple station environmental sensing for air, water and soil is essential to establish a baseline of current and future conditions of the now Hilco owner of the refinery.](https://phillyrefinerycleanup.info/questions/immediate-multiple-station-environmental-sensing-for-air-water-and-soil-is-essential-to-establish-a-baseline-of-current-and-future-conditions-of-the-now-hilco-owner-of-the-refinery/) - All historic data collected to date has established a baseline of environmental conditions as per the requirements of Act 2 and have been documented in Remedial Investigation Reports. Ongoing groundwater sampling activities and soil samples collected since the RIRs were submitted, and the thousands of soil samples that are to be collected by Hilco Redevelopment
- [I think we’re asking the same questions about climate change/sea level rise etc., because we cannot parse/understand the answers that have been posted on the web site.](https://phillyrefinerycleanup.info/questions/i-think-were-asking-the-same-questions-about-climate-change-sea-level-rise-etc-because-we-cannot-parse-understand-the-answers-that-have-been-posted-on-the-web-site/) - As noted, climate change will be considered in future contaminant modeling efforts. Most questions posed to date cannot be answered specifically because we are not at that phase in the Act 2 process yet. We can say that Evergreen will consider all questions, comments and input relating to climate change received during the comment period
- [On the Q+A page, responding to the question “Why is there no mention of climate change in discussion of the Water-table aquifer? …”, the response includes the sentence “Evergreen recognizes that climate changes are predicted that could alter local hydrologic conditions near the facility, such as higher water levels in the water-table aquifer or higher tides in the Schuylkill River.” This misrepresents the nature of climate change and sea level rise. It’s not a question of higher tides. Everything will be higher - low tides, mean water levels, and high tides. Everything is going to go up. This will affect both the Schuykill (as far as it is tidal, to the art museum), and the Delaware. 1. What sources and estimates for climate change and sea level rise is Evergreen working with? 2. What is the maximum value for sea level rise that Evergreen is considering? 3. Sea-levels will continue to rise at least into the next century. What time-scale, in terms of years from now, does Evergreen consider adequate to ‘future proof’ the site from rising sea levels?](https://phillyrefinerycleanup.info/questions/on-the-qa-page-responding-to-the-question-why-is-there-no-mention-of-climate-change-in-discussion-of-the-water-table-aquifer-the-response-includes-the-sentence/) - Most of Evergreen’s groundwater modeling efforts to date have focused on the development of a baseline model that is calibrated to simulate current, average conditions. Evergreen is presently reviewing available documentation pertaining to climate changes predicted for the Philadelphia region. Data review is in its early stages as the Fate and Transport Model RIR is
- [On the Q+A page, responding to the question “Evergreen’s answer on the website to the question of whether climate change will be incorporated in the groundwater modeling …”, Evergreen’s response includes the sentence “Evergreen plans to evaluate climate change data … will include a review of available literature on climate change predictions for the Philadelphia region.” 1. It would be useful to see which sources Evergreen is consulting. Will Evergreen share a bibliography of the sources that you have consulted with the public?](https://phillyrefinerycleanup.info/questions/on-the-qa-page-responding-to-the-question-evergreens-answer-on-the-website-to-the-question-of-whether-climate-change-will-be-incorporated-in-the-groundwater-modeling/) - Yes, Evergreen’s fate and transport RIR will include a references section with all cited publications and resources used in the groundwater modeling. Evergreen is also planning future meetings to discuss the model and input values.
- [In today's presentation, the presenter described the topic of "source removal" as a remediation approach, summarizing it as "get rid of it."   It is understood that this is a plain-word explanation for a more involved process.  What percentage of this project is proposed to be source removal, and where is the material to be removed going?  What is the line of custody for such removal, at what stage are the applicable permits?  Are the byproducts of such processes contaminants themselves, and does the proposal comply with regulations and standards for such byproducts?](https://phillyrefinerycleanup.info/questions/in-todays-presentation-the-presenter-described-the-topic-of-source-removal-as-a-remediation-approach-summarizing-it-as-get-rid-of-it-it-is-understood-that-this-is-a-plain-word-explanati/) - These are all questions that are generally addressed in a Cleanup Plan. The Cleanup Plan(s) will be submitted subsequent to Remedial Investigation Reports.
- [Does the remediation process create an odor or smell? What kind? Will it be all the time, or at certain times?](https://phillyrefinerycleanup.info/questions/does-the-remediation-process-create-an-odor-or-smell-what-kind-will-it-be-all-the-time-or-at-certain-times/) - Emissions from Evergreen’s systems are all treated in some fashion. Groundwater and LNAPL pumping systems are closed loop systems from which vapors are extracted from the system components themselves (no vapors are extracted from the subsurface) and are treated with either granular activated carbon or catalytic oxidation. The sewer vapor extraction systems both use biofilter
- [In today's presentation (August 27th Public Information Session), a summary of the content within RI reports was provided. If source, extent and pathway of contaminants is discovered to have conveyed contaminants beyond the beyond the property boundary which legal entity is currently responsible for impact study costs and remediation costs?”](https://phillyrefinerycleanup.info/questions/in-todays-presentation-august-27th-public-information-session-a-summary-of-the-content-within-ri-reports-was-provided-if-source-extent-and-pathway-of-contaminants-is-discovered-to-have-conveyed/) - Act 2 requires that the Remedial Investigation Report defines the extent of contamination, including beyond the property boundaries. Two of the RIRs were not approved for that reason, which is why they required additional offsite work to further define the full extent of contamination in those areas. Any entity causing a release is responsible for
- [Thanks for being open to a community advisory group. This would be a big step forward. It would be very good to schedule a meeting of the advisory group + other stakeholder representatives in the near future to begin to discuss and compare all of the available remediation and capping methods in terms of cost and benefit, and to outline when and how choices will be made.](https://phillyrefinerycleanup.info/questions/thanks-for-being-open-to-a-community-advisory-group-this-would-be-a-big-step-forward-it-would-be-very-good-to-schedule-a-meeting-of-the-advisory-group-other-stakeholder-representatives-in-the-near/) - Evergreen is open to discussing these topics with the public and is currently evaluating the most effective method of communication and engagement with all community members. Evergreen cannot proceed through the Act 2 process (including cleanup plans) until the public comment process for the approved Remedial Investigation Reports and forthcoming addendums is completed; therefore, remedial
- [If residents are going to invest time & energy in providing our comments, we need to know that there will be responsiveness to the comments- and they won't just sit on a website (thank u for the website btw!). Specifically: can "approved" reports that didn't have public input until now be reopened and revised based on public comments that find any inadequacies in the reports? Otherwise what is the point of us commenting?](https://phillyrefinerycleanup.info/questions/if-residents-are-going-to-invest-time-energy-in-providing-our-comments-we-need-to-know-that-there-will-be-responsiveness-to-the-comments-and-they-wont-just-sit-on-a-website-thank-u-for-the-webs/) - Evergreen is in the process of receiving questions from the public concerning the approved Remedial Investigation Reports. These reports will be revised if new information is found concerning the conclusions of the Remedial Investigation Reports. The comments received during this phase will also inform the future Act 2 phases, which have yet to occur at
- [This process needs to change to involve the public in the development of all reports, as required by Act 2 law- not just commenting after reports are produced. Reports completed since 2006 with virtually no public involvement should be reopened and revised based on public comments that find any inadequacies in the reports. We should be able to call for revision of previously approved reports if new information is found. The Public Involvement Program should allow for proactive, two-way consultation between Evergreen and the community about the clean-up, throughout the development of the reports and the clean-up itself.](https://phillyrefinerycleanup.info/questions/this-process-needs-to-change-to-involve-the-public-in-the-development-of-all-reports-as-required-by-act-2-law-not-just-commenting-after-reports-are-produced-reports-completed-since-2006-with-virtua/) - Evergreen is in the process of receiving questions from the public concerning the approved Remedial Investigation Reports. These reports will be revised if new information is found concerning the conclusions of the Remedial Investigation Reports during this process. The comments received to the Remedial Investigation Reports will also inform the fate and transport evaluation, risk
- [Three related questions have been combined for response: 1) Evergreen has a specific charge, which you are pursuing in a professional and rigorous way. But you are still governed by that definition. How can we work together to make that real in this case in Philadelphia? Every violation of EJ involves different agencies acting narrowly and ignoring the big picture as not their job. Please work with us to change that here. 2) EPA does not define environmental justice – especially when it’s long been an agency accused of environmental racism itself. The movement defined it in the 17 Principles of Environmental Justice here: https://protect-us.mimecast.com/s/bruECkRKRRf1E6AC8LqL7 - principle #7 is particularly relevant. 3) Here is the EPA definition of Environmental Justice. To the best of my knowledge it has not been revoked. Environmental justice is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. EPA has this goal for all communities and persons across this nation. It will be achieved when everyone enjoys the same degree of protection from environmental and health hazards, and equal access to the decision-making process to have a healthy environment in which to live, learn, and work.](https://phillyrefinerycleanup.info/questions/three-related-questions-have-been-combined-for-response-1-evergreen-has-a-specific-charge-which-you-are-pursuing-in-a-professional-and-rigorous-way-but-you-are-still-governed-by-that-definition-h/) - Throughout the Remedial Investigation Phase of our Act 2 requirements, we have continued to involve the public in various ways and remain committed to finding ways to meaningfully engage the public in future meetings, both in our own public meetings and through participation in Hilco community meetings. We have not and will not intentionally discriminate
- [With the closing of PES an opportunity to restore wetland habitat to the river shouldn’t be overlooked. Wetlands purify water and remove contaminants. They also provide habitat for wildlife. And wildlife habitat with accessibility attracts people and helps expose kids to ecology. With that being said - Parcel AOI-10, the West Yard, is just downstream from Bartram’s Gardens and is cutoff from the PES facilities on the eastern banks of the river. While river access for barges or boats may be attractive for the future development, creating habitat along the banks of the river, will not only clean and beautify the area, but could also protect the redevelopment from flooding or water damage.](https://phillyrefinerycleanup.info/questions/with-the-closing-of-pes-an-opportunity-to-restore-wetland-habitat-to-the-river-shouldnt-be-overlooked-wetlands-purify-water-and-remove-contaminants-they-also-provide-habitat-for-wildlife-a/) - It is Evergreen’s understanding that there is no planned development for AOI-10 West Yard.
- [Isn’t there ongoing litigation about that plume by 26th street and whether Sunoco/Hilco/Evergreen is responsible for its source and remediation?](https://phillyrefinerycleanup.info/questions/isnt-there-ongoing-litigation-about-that-plume-by-26th-street-and-whether-sunoco-hilco-evergreen-is-responsible-for-its-source-and-remediation/) - Evergreen is not aware of any ongoing litigation involving 26th Street. Evergreen currently manages remediation at the property boundary along 26th street.
- [Is your remediation process (Act Two and beyond) guided in accordance with the Environmental Rights Amendment (ERA), (Article I, Section 27 of the Pennsylvania Constitution), which states: “The people have a right to clean air, pure water, and to the preservation of the natural, scenic, historic and esthetic values of the environment. Pennsylvania’s public natural resources are the common property of all the people, including generations yet to come. As trustee of these resources, the Commonwealth shall conserve and maintain them for the benefit of all the people.”](https://phillyrefinerycleanup.info/questions/is-your-remediation-process-act-two-and-beyond-guided-in-accordance-with-the-environmental-rights-amendment-era-article-i-section-27-of-the-pennsylvania-constitution-which-states-th/) - Section 101 of the Land Recycling and Environmental Remediation Standards Act, which established Act 2, specifically includes language how Act 2 helps to achieve the objectives of Article I, Section 27 of the Pennsylvania Constitution. The future cleanup activities of the Site will be completed in accordance with the Act 2 program requirements, also supporting
- [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.](https://phillyrefinerycleanup.info/questions/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-tim/) - 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
- [The information on your website seems to be outdated but i recently received a letter in the mail asking us to submit comments. I worry about our community over the river in South Philly who have dealt with countless decades of health problems due to this harmful refinery. Please keep me updated on this matter.](https://phillyrefinerycleanup.info/questions/the-information-on-your-website-seems-to-be-outdated-but-i-recently-received-a-letter-in-the-mail-asking-us-to-submit-comments-i-worry-about-our-community-over-the-river-in-south-philly-who-have-deal/) - We appreciate that you have taken the time to look at the Evergreen website. The intent of the website is to be a central location that contains environmental reports for the site, a summary of questions and comments, and news about upcoming events. We are continually updating the website with new information. The postcard was
- [When will the public hearings for AOI 11 under Act 2 take place?](https://phillyrefinerycleanup.info/questions/when-will-the-public-hearings-for-aoi-11-under-act-2-take-place/) - There is currently no separate meeting planned to discuss AOI-11. Evergreen held a Public Information Session on August 27, 2020 during which the environmental data collected from all AOI’s was reviewed with the public. Additional meetings are planned to be held for future Act 2 submittals and/or other key milestones in the Act 2 process,
- [How long does it take to collect soil and groundwater data for an AOI?](https://phillyrefinerycleanup.info/questions/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
- [Locations and concentrations of 30 contaminants of concern - including chrysene, naphthalene, mercury, and arsenic - were identified individually but their cumulative significance was not addressed.](https://phillyrefinerycleanup.info/questions/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
- [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.](https://phillyrefinerycleanup.info/questions/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/) - 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
- [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).](https://phillyrefinerycleanup.info/questions/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/) - 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
- [Will this presentation be uploaded with closed captioning and translated/available in other languages?  (Evergreen note: the question refers to the August 27, 2020 Public Information Session).](https://phillyrefinerycleanup.info/questions/will-this-presentation-be-uploaded-with-closed-captioning-and-translated-available-in-other-languages-evergreen-note-the-question-refers-to-the-august-27-2020-public-information-session/) - The presentation and other key documents have been posted to the website in three additional languages (Chinese, Vietnamese and Spanish), which are the three next most commonly spoken languages in the Philadelphia region. The website has also been modified to include a translation button on each page for translation of Q&A and other website information.
- [Can you please report how many people are on this meeting as we the public cannot see how many people are here?   (Evergreen note: question refers to the August 27, 2020 Public Information Session)](https://phillyrefinerycleanup.info/questions/can-you-please-report-how-many-people-are-on-this-meeting-as-we-the-public-cannot-see-how-many-people-are-here-evergreen-note-question-refers-to-the-august-27-2020-public-information-session/) - According to GHD, who administered the meeting on behalf of Evergreen, the raw data indicate an attendance of 493 people. However, after eliminating duplicate logins, attendance by presenters/regulators, and those that connected via both phone and computer, etc., the final count was approximately 213 people. This would not account for multiple people attending via single
- [Are your LNAPL bodies in Slide 32 a result of shallow, deep or both wells being gauged? (Evergreen note: question references Slide 32 in the August 27, 2020 presentation)](https://phillyrefinerycleanup.info/questions/are-your-lnapl-bodies-in-slide-32-a-result-of-shallow-deep-or-both-wells-being-gauged-evergreen-note-question-references-slide-32-in-the-august-27-2020-presentation/) - All site wells are gauged, but only those reporting LNAPL were used to create Slide 32. The LNAPL bodies shown during the presentation were drawn using observations from wells screened across the water table (i.e. shallow wells). No deep or lower aquifer wells were used.
- [Are chemicals you are presently using putting additional toxins in the air?](https://phillyrefinerycleanup.info/questions/are-chemicals-you-are-presently-using-putting-additional-toxins-in-the-air/) - Evergreen does not use chemicals in their current remediation systems.
- [But the state of PA actually uses a blood lead level double what the federal CDC updated in 2012.https://www.cdc.gov/nceh/lead/data/blood-lead-reference-value.htm](https://phillyrefinerycleanup.info/questions/but-the-state-of-pa-actually-uses-a-blood-lead-level-double-what-the-federal-cdc-updated-in-2012-https-www-cdc-gov-nceh-lead-data-blood-lead-reference-value-htm/) - This question was sent to PADEP who provided the following response: DEP’s published Statewide health standard nonresidential direct contact numeric value for lead in soil, 1000 mg/kg (milligrams lead per kilogram soil), was based on a target blood lead level in adults of 20 mg/dL (micrograms lead per deciliter of blood). Evergreen derived a site-specific
- [In today’s presentation (Evergreen note: question refers to the August 27, 2020 Public Information Session), related to lead, the presenter described that ‘it is a complex process’ for ‘choosing the standard’ associated with lead contamination levels and its subsequent categorization. Why does the entity responsible for contamination clean-up (and their supporting team) have the option to choose their standard for clean-up? Who is the authority having jurisdiction who reviews the selected standard? Are other standards more stringent? If so, why were those standards not used for these contaminants in this case?](https://phillyrefinerycleanup.info/questions/in-todays-presentation-evergreen-note-question-refers-to-the-august-27-2020-public-information-session-related-to-lead-the-presenter-described-that-it-is-a-complex-process/) - There are three choices for clean-up standards that can be applied to any Act 2 site: Statewide Health, Background, or Site-Specific. The choice between the three standards is up to the remediator, but each one has strict guidelines and processes that must be followed to demonstrate to the PADEP (who has jurisdiction and responsibility to
- [Why does the former refinery get special treatment compared to other nonresidential sites? In terms of the lead site specific standards in soils 0 to 2 feet](https://phillyrefinerycleanup.info/questions/why-does-the-former-refinery-get-special-treatment-compared-to-other-nonresidential-sites-in-terms-of-the-lead-site-specific-standards-in-soils-0-to-2-feet/) - The ability to calculate a site-specific standard (for any media) is a provision in the Act 2 regulations and is not the only one allowed, but is common practice and one of the three options for standards that can be applied to a site: Statewide Health, Background, or Site-Specific. Other non-residential sites can also calculate
- [Is soil tested to a depth greater than 2 feet deep?](https://phillyrefinerycleanup.info/questions/is-soil-tested-to-a-depth-greater-than-2-feet-deep/) - Yes, soil is tested at many depths. We showed the soil data results in two different slides: 0-2 feet below the surface and anything else collected from greater than 2 feet below the surface. That’s because the standard concentrations that we compare our data to are different for surface soil (0-2 feet) and subsurface soil
- [When will we get information comparing all the available remediation methods in terms of cost, effectiveness, and community impacts (such as air emissions from the remediation process itself)?](https://phillyrefinerycleanup.info/questions/when-will-we-get-information-comparing-all-the-available-remediation-methods-in-terms-of-cost-effectiveness-and-community-impacts-such-as-air-emissions-from-the-remediation-process-itself/) - Evaluation of current and potential remedial options is ongoing. Cleanup Plans will be submitted upon completion of all Remedial Investigation activities, which will consist of identification and evaluation of remedial alternatives, selection of proposed remedies, and plans for the development, construction, and initial operation of the proposed remedy and/or documentation of interim remedial actions already
- [As a community resident I think this media forum is not consumer friendly in allowing community members to have an opportunity to participate fully in this report out process.](https://phillyrefinerycleanup.info/questions/as-a-community-resident-i-think-this-media-forum-is-not-consumer-friendly-in-allowing-community-members-to-have-an-opportunity-to-participate-fully-in-this-report-out-process/) - Evergreen is evaluating how the future virtual public information session can be structured to allow for live Q&A that will allow for as many people as possible to have their questions answers.
- [How much more information do you need to complete the fate and transport model?](https://phillyrefinerycleanup.info/questions/how-much-more-information-do-you-need-to-complete-the-fate-and-transport-model/) - We believe we have sufficient information to complete the model. However, we need to have agreeance on that from DEP prior to submittal. In other words, all of the Remedial Investigation Reports must be approved first (meaning, that DEP feels we have sufficiently defined the contamination so that a model can be accurate and complete).
- [Climate change-generated sea-level rise (Schuylkill, Delaware) is a given. There are already models out there. What range of values in feet are Evergreen assuming for 2050, and 2100?](https://phillyrefinerycleanup.info/questions/climate-change-generated-sea-level-rise-schuylkill-delaware-is-a-given-there-are-already-models-out-there-what-range-of-values-in-feet-are-evergreen-assuming-for-2050-and-2100/) - Evergreen has yet to complete the contaminant fate and transport assessment for the facility and currently has a working groundwater flow model that is calibrated to recent, average sea level in the Schuylkill River estimated from a local tide gauge. The magnitude of sea-level rise has not yet been selected for evaluation in the modeling
- [Evergreen's answer on the website to the question of whether climate change will be incorporated in the groundwater modeling states, "the boundary condition data variability must be quantifiable and based on accepted models or observations."  What in plain language does this response mean?  You have not directly answered the question. What efforts are being made to quantify the boundary condition data? Are accepted models available or not?  If not, why not?](https://phillyrefinerycleanup.info/questions/evergreens-answer-on-the-website-to-the-question-of-whether-climate-change-will-be-incorporated-in-the-groundwater-modeling-states-the-boundary-condition-data-variability-must-be-quantifiable-and/) - Evergreen plans to evaluate climate change data in support of groundwater modeling for contaminant fate and transport. The effort will include a review of available literature on climate change predictions for the Philadelphia region. Accepted climate models would be those that are published, peer-reviewed, and/or otherwise viewed as reliable and relevant to future conditions at
- [Why is there no mention of climate change in discussion of the Water-table aquifer? These levels could change by multiple feet in the next few decades.](https://phillyrefinerycleanup.info/questions/why-is-there-no-mention-of-climate-change-in-discussion-of-the-water-table-aquifer-these-levels-could-change-by-multiple-feet-in-the-next-few-decades/) - One of Evergreen’s primary objectives through the remedial investigations under Act 2 was to characterize the facility’s geologic framework and the water-bearing units it supports. Potential flow pathways for contaminant transport could be evaluated in this manner using recent groundwater observations from hundreds of wells at the facility. Evergreen’s groundwater model is calibrated and validated
- [Can you please go over your plan to clean up lead and other toxic contaminants at the site? And your plan to provide a sufficient analysis of and a plan for effectively and safely cleaning up contaminants in the deep aquifer below the site. I urge you to use the strictest possible health-based standard to clean up toxics in both of these and all other cases.](https://phillyrefinerycleanup.info/questions/can-you-please-go-over-your-plan-to-clean-up-lead-and-other-toxic-contaminants-at-the-site-and-your-plan-to-provide-a-sufficient-analysis-of-and-a-plan-for-effectively-and-safely-cleaning-up-contamin/) - All plans for cleaning up contamination in both soil and groundwater will be included in the Act 2 Cleanup Plan(s).
- [Can you please make the water permits mentioned public?](https://phillyrefinerycleanup.info/questions/can-you-please-make-the-water-permits-mentioned-public/) - Evergreen currently holds PWD discharge permits. These will be posted to the website.
- [In today's presentation, the presenter described that water flows within the upper groundwater can only mix with water in the lower groundwater if there is a "hole" in the 'shelf' layer between. Even from a layman's perspective, the airplane-view images provided for comparing the two zones and the ''shelf-like' separation, that pathway appeared quite large--and that it could be a pathway of contaminates.  Is this being studied?  What is the status of such a report and when would its findings be presented and addressed?](https://phillyrefinerycleanup.info/questions/in-todays-presentation-the-presenter-described-that-water-flows-within-the-upper-groundwater-can-only-mix-with-water-in-the-lower-groundwater-if-there-is-a-hole-in-the-shelf-layer-between/) - Characterization of the refinery geology, hydrogeology, and extent of contamination, including study of the pathways that could exist, has been ongoing and is included in the RIRs. A fate and transport analysis will be prepared once all the RIRs have been approved, and the analysis will include model simulations of contaminant transport. This report is
- [Will this affect our drinking water?](https://phillyrefinerycleanup.info/questions/will-this-affect-our-drinking-water/) - The refinery contamination sources discussed during the public information session are not expected to impact local drinking water supplies obtained by the City from the Delaware and Schuylkill Rivers.
- [Why is the site specific standard for lead contamination at the site, more than double the default state, non-residential lead standard?](https://phillyrefinerycleanup.info/questions/why-is-the-site-specific-standard-for-lead-contamination-at-the-site-more-than-double-the-default-state-non-residential-lead-standard/) - The approach used to calculate the SSS for lead was to use the updated Adult Lead Model recommended by the USEPA. The previous calculations used by the PADEP were outdated; therefore, the PADEP recently used the same Adult Lead model to develop an updated non-residential lead direct contact MSC that reflects the current state of
- [Who is GHD? And what is their relationship to Evergreen and Sunoco and ET?](https://phillyrefinerycleanup.info/questions/who-is-ghd-and-what-is-their-relationship-to-evergreen-and-sunoco-and-et/) - GHD is one of several environmental consulting firms contracted by Evergreen to work on Sunoco’s legacy remediation at the Philadelphia refinery.
- [What specific steps are being taken to clean the water from potential contaminants?](https://phillyrefinerycleanup.info/questions/what-specific-steps-are-being-taken-to-clean-the-water-from-potential-contaminants/) - Since the original Consent Order & Agreement between Sunoco and DEP in 1993, Sunoco and Evergreen have implemented several interim remedial actions at the refinery. Various remediation systems were installed in the facility in 1995 to prevent the migration of impacted groundwater offsite. Additional remediation systems have been installed since that time to either address
- [What investigation has been done and will be planned to identify contamination to soil or groundwater beyond the property boundary?  If so, when?  If not, why not?](https://phillyrefinerycleanup.info/questions/what-investigation-has-been-done-and-will-be-planned-to-identify-contamination-to-soil-or-groundwater-beyond-the-property-boundary-if-so-when-if-not-why-not/) - Remedial Investigation Reports must include delineation of contamination of soil and groundwater to be approved. Soil impacts have been delineated across the Site and up to the fence lines, meaning soils impacts are not shown to extend offsite. The RIRs for AOI-4 and AOI-9 were not approved due to need for additional offsite delineation of
- [In addition to the toxins already mentioned, what is the plan to deal with the benzene that is in the soil?](https://phillyrefinerycleanup.info/questions/in-addition-to-the-toxins-already-mentioned-what-is-the-plan-to-deal-with-the-benzene-that-is-in-the-soil/) - In general, benzene and other volatile compounds are not identified for further evaluation in soils (meaning they were not detected above the statewide health standards in many locations). However, all remedial options, which can include engineering and intuitional controls will be detailed in future Cleanup Plans.
- [Act 2 Standard, as presented in today's presentation (August 27th Public Information Session), is being applied for statewide, and site specific.   The presentation and presenter also reinforced the fact that the most stringent requirement must apply.  If PA state's lead standard in soil is 1000 ppm, why is Evergreen proposing a site-specific standard of 2,240 ppm, which is clearly twice the quantity?](https://phillyrefinerycleanup.info/questions/act-2-standard-as-presented-in-todays-presentation-august-27th-public-information-session-is-being-applied-for-statewide-and-site-specific-the-presentation-and-presenter-also-reinforced-the/) - The Site Specific Standard (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 for lead were outdated; therefore, the PADEP recently used the same updated Adult Lead model to develop an updated non-residential lead direct contact MSC that
- [Why isn't the site-specific standard for lead being reevaluated based on the anticipated site use (commercial warehouse)?](https://phillyrefinerycleanup.info/questions/why-isnt-the-site-specific-standard-for-lead-being-reevaluated-based-on-the-anticipated-site-use-commercial-warehouse/) - The site-specific standard for lead was calculated based on non-residential (not industrial) site use, which is consistent with the planned future use.
- [So, you are acknowledging that the DEP is attempting to increase the nonresidential surface soil lead standard to 2,500 from 1000 to accommodate the refinery site?](https://phillyrefinerycleanup.info/questions/so-you-are-acknowledging-that-the-dep-is-attempting-to-increase-the-nonresidential-surface-soil-lead-standard-to-2500-from-1000-to-accommodate-the-refinery-site/) - The PADEP calculated a new proposed direct contact standard based on the updated Adult Lead Model and updated exposure assumptions recommended by the USEPA, not to accommodate any specific site.
- [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.](https://phillyrefinerycleanup.info/questions/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-pp/) - 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
- [Why did you choose such a high site-specific standard, and do you plan to keep it that high?](https://phillyrefinerycleanup.info/questions/why-did-you-choose-such-a-high-site-specific-standard-and-do-you-plan-to-keep-it-that-high/) - The approach used to calculate the SSS for direct contact was to use the Adult Lead Model recommended by the EPA. The PADEP used the same model to develop an updated non-residential lead direct contact MSC that reflects the current state of the science for lead. If the PADEP changes PADEP’s assumptions related to lead,
- [The speaker (during the August 27th Public Information Session) said that the remedial investigation reports have to be approved before Evergreen does risk assessments. Since this hasn't happened yet, why did Evergreen already complete the risk assessment for lead in soil?](https://phillyrefinerycleanup.info/questions/the-speaker-during-the-august-27th-public-information-session-said-that-the-remedial-investigation-reports-have-to-be-approved-before-evergreen-does-risk-assessments-since-this-hasnt-happened-yet/) - In order to determine risk to human or ecological receptors associated with contamination in soil or groundwater, the extent of the contamination must be known/defined for accurate calculation of risk. The calculation of the lead Site Specific Standard for shallow soil used risk-based calculations utilizing the updated Adult Lead Model and exposure assumptions recommended by
- [What other companies are involved in the cleanup, besides Evergreen?](https://phillyrefinerycleanup.info/questions/what-other-companies-are-involved-in-the-cleanup-besides-evergreen/) - Evergreen is responsible to cleanup legacy contamination, generated prior to September 2012. Hilco Redevelopment Partners (HRP) is responsible to cleanup recent contamination, generated after September 2012.
- [Hi, I live in Siena place. I noticed that Benzene concentration is a light green and close to the dark green shaded areas in the same spot as my current house (very close to pha housing and refinery) (Evergreen note: this question refers to slide #38 “Groundwater Investigation Results – Benzene” in the August 27, 2020 presentation which is available for view or download on www.phillyrefinerycleanup.info). I think it was in the lower aquifer and water table aquifer. Because it is right below my house it seems from the map, can this present a danger to me or the house? Like can my water and be affected? And gas vapors be present? Or is it totally safe to live in this area even though it is below ground?](https://phillyrefinerycleanup.info/questions/hi-i-live-in-siena-place-i-noticed-that-benzene-concentration-is-a-light-green-and-close-to-the-dark-green-shaded-areas-in-the-same-spot-as-my-current-house-very-close-to-pha-housing-and-refinery/) - Information from the remedial investigation activities do not indicate that there is any risk to indoor or outside air in offsite properties from benzene in groundwater originating from the former Philadelphia Refinery. Evaluation of vapors to indoor and outdoor air from a dissolved plume beneath the subsurface is part of the evaluation required by Act
- [Philly Inquirer (8/3/2020) says Hilco is calling for an "exposure barrier," instead of removal. How extensive is contamination beyond the site? Concerned this does not address the health and environmental rights of the local community, nor account for sea-level rise and climate change flooding.](https://phillyrefinerycleanup.info/questions/philly-inquirer-8-3-2020-says-hilco-is-calling-for-an-exposure-barrier-instead-of-removal-how-extensive-is-contamination-beyond-the-site-concerned-this-does-not-address-the-health-and-environ/) - The off-site impacts are described in the Remedial Investigation Reports and two Areas of Investigation (AOIs), AOI 4 and AOI 9, have completed additional investigation activities to delineate off-site impacts. As part of developing future Cleanup Plans for the site, several remedial options will be evaluated, including exposure barriers which may be necessary on-site. Exposure
- [Right now there is a very strange smell outside. I am inclined to believe it may be emissions from your site. If so, what could it be?](https://phillyrefinerycleanup.info/questions/right-now-there-is-a-very-strange-smell-outside-i-am-inclined-to-believe-it-may-be-emissions-from-your-site-if-so-what-could-it-be/) - The operation of the site has been under the direction of Philadelphia Energy Solutions (PES) since the sale of the site in 2012 from Sunoco to PES, so Evergreen/Sunoco has not been involved in site operations since that time. In addition, operations at the former Philadelphia Refinery by PES were shut down in 2019, so
- [Why was there no meeting 11/7/20.  Why was Evergreen “blocked” from the meeting? Was there a meeting at all?](https://phillyrefinerycleanup.info/questions/why-was-there-no-meeting-11-7-20-why-was-evergreen-blocked-from-the-meeting-was-there-a-meeting-at-all/) - Evergreen is unaware of the exact reason the meeting was blocked by certain members of the public. The purpose of that meeting was to initiate public involvement by introducing who Evergreen is, provide a summary of the work that has been completed at the site to date, and discuss Evergreen’s future activities. Evergreen held a
- [I read that Benzene levels were 30 times higher than permitted, putting them on par with levels you would see in 3rd world countries like India. Also watchdog websites went black in the weeks leading up to the explosion. There was no data available to the public in the weeks leading up to the explosion.](https://phillyrefinerycleanup.info/questions/i-read-that-benzene-levels-were-30-times-higher-than-permitted-putting-them-on-par-with-levels-you-would-see-in-3rd-world-countries-like-india-also-watchdog-websites-went-black-in-the-weeks-leading/) - Evergreen is responsible for managing the environmental investigation and cleanup of soil and groundwater from impacts that occurred before PES purchased the site in 2012. PES operated the site and would have the information pertaining to air emission data. In addition, the City of Philadelphia Department of Public Health’s Air Management Services may also be
- [What are the biggest environmental concerns with the water moving forward as this space is transitioned to a mixed-use industrial site?](https://phillyrefinerycleanup.info/questions/what-are-the-biggest-environmental-concerns-with-the-water-moving-forward-as-this-space-is-transitioned-to-a-mixed-use-industrial-site/) - In general, water concerns remain the same between use of the site as a refinery and the proposed use. As part of the Act 2 process, groundwater quality must be investigated as well as migration of and risks associated with the contaminants identified. The groundwater beneath the site is not allowed to be used for
- [Has AOI 11 cleanup been started? What is the plan for the cleanup for AOI 11?](https://phillyrefinerycleanup.info/questions/has-aoi-11-cleanup-been-started-what-is-the-plan-for-the-cleanup-for-aoi-11/) - Additional investigation has been completed for AOI 11 since the time of the last report submitted solely for AOI 11 in 2013. In fact, the latest Remedial Investigation Reports (RIRs) for each of the AOIs include information about AOI 11, or the lower groundwater unit, within that AOI. We chose to incorporate AOI 11 into
- [The site contains multiple tank farms (Schuylkill, etc.). What is the story for each tank farm?](https://phillyrefinerycleanup.info/questions/the-site-contains-multiple-tank-farms-schuylkill-etc-what-is-the-story-for-each-tank-farm/) - While the question is a bit open-ended, we interpret this question to be generally inquiring about Sunoco’s regulatory compliance with respect to tanks at the property. The environmental impacts at the tank farms have been evaluated two different ways as part of Evergreen’s activities. If there was a release or tank closure from a tank
- [Various docks have handled ships since 1866. Multiple fires have occurred on ships over the years. What is the condition of the land along the waterfront?](https://phillyrefinerycleanup.info/questions/various-docks-have-handled-ships-since-1866-multiple-fires-have-occurred-on-ships-over-the-years-what-is-the-condition-of-the-land-along-the-waterfront/) - The environmental impacts that have been characterized during Evergreen’s Act 2 investigations along the waterfront are presented in the RIRs, specifically in the AOI 2, 3, 5, 6, 7, 8, 9 and 10.
- [The logistical infrastructure moves petrochemicals across the site. Where are the pipelines, pumps, storage tanks, and intakes/offtakes located (on a map)? What dangers do each pose?](https://phillyrefinerycleanup.info/questions/the-logistical-infrastructure-moves-petrochemicals-across-the-site-where-are-the-pipelines-pumps-storage-tanks-and-intakes-offtakes-located-on-a-map-what-dangers-do-each-pose/) - The features related to petroleum operations that were included in Evergreen’s Act 2 or Chapter 245 (Tank Act) investigations are included in the figures in the RIRs, and the associated environmental impacts are summarized in these reports. Also note that operations have been shut down and we expect that most infrastructure will likely be removed
- [The site contains several rail facilities (North Yard, West Yard, etc.). What are the conditions at rail terminals and along rail tracks?](https://phillyrefinerycleanup.info/questions/the-site-contains-several-rail-facilities-north-yard-west-yard-etc-what-are-the-conditions-at-rail-terminals-and-along-rail-tracks/) - The rail facilities are located in AOI 5 and AOI 8. Installation of these rail facilities occurred after the property transfer to PES. Therefore, conditions near these lines resulting from their operation would not be part of Evergreen’s investigations. However, the environmental conditions characterized as part of the Act 2 investigations, which included the areas
- [Have you considered remediating with bacteria? Or mycelium? We understand they’re both more affordable options.](https://phillyrefinerycleanup.info/questions/have-you-considered-remediating-with-bacteria-or-mycelium-we-understand-theyre-both-more-affordable-options/) - Evergreen has considered and will continue to consider various remedial options at each area of proposed remediation. Remedial options must consider a number of factors, including but not limited to logistics, utilities, subsurface flow conditions, chemistry, nature and extent of the contamination, nutrient availability, etc. Bioremediation technologies, not specifically mycoremediation, have been/are utilized in AOI-4
- [Why is Evergreen's site-specific Lead standard (2240 ppm) so much higher than the state standard (1000 ppm)?](https://phillyrefinerycleanup.info/questions/why-is-evergreens-site-specific-lead-standard-2240-ppm-so-much-higher-than-the-state-standard-1000-ppm/) - The PADEP’s Non-Residential Medium Specific Concentration (MSC) was derived using the Society for Environmental Geochemistry and Health (SEGH) model (Wixson, 1991). Since that time, the PADEP has endorsed the use of alternative uptake biokinetic models for the evaluation of lead toxicity including the Bower model (Bowers et al., 1994) for non-residential site uses. The USEPA
- [What is the quality of the water discharged from the Pollock St well system into the Schuylkill?](https://phillyrefinerycleanup.info/questions/what-is-the-quality-of-the-water-discharged-from-the-pollock-st-well-system-into-the-schuylkill/) - Groundwater collected from the Pollack St well system is not discharged directly to the Schuylkill River. Groundwater discharged from any remediation system is either processed through the facility’s wastewater treatment plant which operates under a National Pollutant Discharge Elimination System (NPDES) permit held by PES or discharged to the Philadelphia Water Department (PWD) sewer system
- [Should the groundwater remediation systems that were discontinued be restarted? If not, why not? If so, when will that happen?](https://phillyrefinerycleanup.info/questions/should-the-groundwater-remediation-systems-that-were-discontinued-be-restarted-if-not-why-not-if-so-when-will-that-happen/) - Various remediation systems historically have been discontinued generally when the remedial goals are complete or where the technology is no longer the most appropriate. Each remediation system is discussed in its associated Remedial Investigation Report. Any proposed additional systems, remedial goals and associated monitoring will be included in future Act 2 reports such as the
- [Two water filtration plants (at Girard Point and Point Breeze) treat groundwater before returning water to the Schuylkill River. How effective are these systems? What happens during heavy rains and floods?](https://phillyrefinerycleanup.info/questions/two-water-filtration-plants-at-girard-point-and-point-breeze-treat-groundwater-before-returning-water-to-the-schuylkill-river-how-effective-are-these-systems-what-happens-during-heavy-rains-and-fl/) - The water treatment plants are run and operated by PES under a NPDES permit issued by the PADEP. Operation of the water treatment plant will be conducted by the new property owner. PES or the PADEP would be better able to respond to the question of how effective these systems are and what happens during
- [What is being done to prevent contaminated groundwater from entering the Pollock and 26th St Sewers?](https://phillyrefinerycleanup.info/questions/what-is-being-done-to-prevent-contaminated-groundwater-from-entering-the-pollock-and-26th-st-sewers/) - Groundwater/light non-aqueous phase liquid (LNAPL) are being recovered via remediation system recovery wells along the property boundary in an area along 26th Street. Groundwater and LNAPL are also recovered via horizontal recovery wells along the Pollack Street sewer through the facility. Sewer conditions are to be evaluated as part of the future modeling efforts.
- [What is the status of your groundwater and aquifer modeling for all pollutants?](https://phillyrefinerycleanup.info/questions/what-is-the-status-of-your-groundwater-and-aquifer-modeling-for-all-pollutants/) - The groundwater flow model has been completed but cannot be finalized and submitted until all Remedial Investigation Reports are approved as data collected for these reports are used as the basis for the groundwater flow model. Groundwater contaminant fate and transport model efforts will be conducted subsequent to approval of the Remedial Investigation Reports since

## Galleries

- [Public Involvement](https://phillyrefinerycleanup.info/bwg_gallery/public-involvement/)
- [org-chart-final](https://phillyrefinerycleanup.info/bwg_gallery/org-chart-test/)
- [site-history-org-chart](https://phillyrefinerycleanup.info/bwg_gallery/site-history-org-chart/)
- [epa logo](https://phillyrefinerycleanup.info/bwg_gallery/epa-logo/)

## Gallery Share

- [Image](https://phillyrefinerycleanup.info/bwg_share/image/)

## Categories

- [Uncategorized](https://phillyrefinerycleanup.info/category/uncategorized/)

## Question Categories

- [Ownership / History / Infrastructure](https://phillyrefinerycleanup.info/question-category/ownership-history-infrastructure/)
- [Public Participation](https://phillyrefinerycleanup.info/question-category/public-participation/)
- [Other / Misc.](https://phillyrefinerycleanup.info/question-category/other-misc/)
- [Groundwater](https://phillyrefinerycleanup.info/question-category/groundwater/)
- [Remedial Investigation Reports (RIR-specific Questions)](https://phillyrefinerycleanup.info/question-category/remedial-investigation-reports-rir-specific-questions/)
- [Air Quality](https://phillyrefinerycleanup.info/question-category/air-quality/)
- [Fate & Transport](https://phillyrefinerycleanup.info/question-category/fate-transport/)
- [Climate Change](https://phillyrefinerycleanup.info/question-category/climate-change/)
- [Remediation](https://phillyrefinerycleanup.info/question-category/remediation/)
- [Regulations](https://phillyrefinerycleanup.info/question-category/regulations/)
- [Soil](https://phillyrefinerycleanup.info/question-category/soil/)
- [Risk Assessment / Communication](https://phillyrefinerycleanup.info/question-category/risk-assessment-communication/)
- [Hilco / Redevelopment](https://phillyrefinerycleanup.info/question-category/hilco-redevelopment/)
- [LNAPL](https://phillyrefinerycleanup.info/question-category/lnapl/)