Q & A

The questions and comments below have been generated from website comment forms, emails, and public meeting comments.  These will be updated periodically and will be included in the Public Comment Remedial Investigation Report to be submitted to the agencies upon completion of the public comment period.

Please explain the formal, legal, and/or organization ties that Evergreen has to Sunoco and/or Energy Transfer.

Evergreen is a wholly-owned subsidiary of ETC Sunoco Holdings LLC f/k/a Sunoco, Inc. (there was a corporate name change in December 2018), and both companies are indirect subsidiaries of Energy Transfer L.P. In November 2013, Evergreen was registered in the State of Delaware to manage Sunoco’s legacy environmental cleanup at the Philadelphia Refinery.

Why did it take 10+ years, and an almost-catastrophic explosion, for Evergreen to come back and engage the public?

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 (NIR) submitted for the property), a letter was sent to the City of Philadelphia and notices appeared in a local newspaper informing the public of each submittal and their opportunity to comment on the submittals. In August 2018, DEP requested that Evergreen revisit the previous public involvement plan with the City of Philadelphia. After a meeting with DEP, EPA and City officials in November 2018, Evergreen began developing the www.phillyrefinerycleanup.info website in preparation for a public meeting. The fire at PES’ facility occurred after this effort was underway, in June of 2019. At that time, Evergreen suggested opening the website prior to announcing a date for a legacy remediation public meeting to allow the agencies to share the website in order to aid in answering questions that were being posed about Sunoco’s legacy remediation program. The June 2019 fire at the PES facility does not relate to Evergreen’s Act 2 submittals or public involvement plan.

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.

Evergreen agrees that public participation should not be done once everything is decided. As stated previously, public notice was completed when a Notice of Intent to Remediate (NIR) was submitted at the start of the Act 2 process and when the NIR was updated two times afterwards. In addition, public notice has been completed when each of the 21 Act 2 reports have been submitted to the PADEP. In addition, a public meeting was held in 2006 during the early stages of the Act 2 activities at the Site and Evergreen is committed to continuing public participation as part of the public participation plan, including additional public meetings.

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 remains disappointed that entrances were blocked at the planned meeting 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 as ongoing due to the acceptance of comments from the public, but a specific end date is still being discussed as the process continues. Evergreen is working with stakeholders to schedule another meeting in the future. Information on the scheduled meeting will be posted to the website and public notices will be submitted as was done with the original meeting.

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 investigation has been done to identify contamination to soil or groundwater beyond the property boundary (offsite)?

Evaluation of conditions at the property boundaries and offsite, where appropriate, are addressed in each Remedial Investigation Report with respect to the property boundary area nearest each defined Area of Interest. Investigation generally includes offsite monitoring wells installed by Evergreen (or previous entities) and data sharing efforts with multiple adjacent or nearby properties also in Act 2 or other environmental programs.

When will the revised RIRs for AOIs 4, 9 and 11 be submitted?

The remaining RIR addendums are awaiting completion of the current public comment period which has been re-opened as to the previously submitted Act 2 reports.

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 then be submitted. The Cleanup Plan will be prepared and submitted following the Sitewide Fate & Transport RIR, Sitewide Ecological Risk Assessment Report and Sitewide Human Health Risk Assessment Report. However, remediation (cleanup) activities which were conducted prior to entering the Act 2 program and interim remediation activities currently being conducted are summarized in the RIRs posted to the website.

Is there a permit for the discharge of water from the wastewater treatment system to the Phila Water Dept? Who is the permittee? Have the permit requirements been met?

Onsite wastewater treatment and discharge is managed and permitted by PES. Pursuant to their permit, PES is required to submit sampling data of the water discharged, which data is publicly available.

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 the fate and transport modeling is dependent upon the information in the Remedial Investigation Reports and the groundwater flow model.

Will Evergreen be incorporating climate resilience into its groundwater modeling?

Evergreen’s groundwater flow model for the former Philadelphia Refinery has been calibrated and validated to recent environmental conditions and measured observations. As a part of the remedial investigation’s contaminant fate and transport assessment, Evergreen will review available information related to climate change in the Philadelphia area and, if warranted, the groundwater model could be adjusted to adapt to predicted climate conditions and could provide a range of potential outcomes for consideration (e.g., a higher average Schuylkill River stage due to sea-level rise or an increased recharge rate due to an increase in annual precipitation). For a defensible model and reliable predictions, the boundary condition data variability must be quantifiable and based on accepted models or observations.

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 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 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 Site will continue to be regulated under the stormwater management requirements of the City of Philadelphia and the PADEP which includes provisions for sea level rise.

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 Risk Assessment and the Cleanup Plan.

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 via a Groundwater Discharge Permit held by Evergreen. Evergreen samples groundwater discharge to the PWD sewer per the permit requirements and the discharge from the facility’s wastewater treatment plant is sampled by PES in accordance with their NPDES permit.

Why is Evergreen's 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 adapted the Bowers et al. model to develop the Adult Lead Model (ALM). The ALM is a widely.accepted approach to risk characterization for non-residential exposure scenarios and recommended by the USEPA (EPA, 2001). Evergreen used the EPA’s default assumptions for assessing non-residential risks from lead exposure in the ALM model to develop the site specific standard for lead.

Have you considered remediating with bacteria? Or mycelium? We understand they’re 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 and AOI-1 and will continued to be considered for the Site.