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 11 will be included in Evergreen’s future Cleanup Plans, which... read more
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.
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 groundwater related to historic environmental impacts that... read more
As a former groundwater quality specialist, even small breaks in confining layers can result in significant transfer of contaminants. And, the direction and rates of water movement can change over time, often from groundwater drilling.
The direction and rates of groundwater flow are evaluated frequently at the site and groundwater samples collected routinely from various hydrogeologic units beneath the facility. The Remedial Investigation activities also evaluated the areas where the confining layers in the subsurface were not continuous through the completion of soil borings, installation of monitoring wells, collection of groundwater samples,... read more
Deep Aquifer – Evergreen states a layer of clay and mud partly separates the upper, “water table” aquifer from a lower, “deep” aquifer. This barrier is not continuous, though, and fails to protect the deep aquifer from contamination. Since the deep aquifer supplies drinking water to communities in New Jersey, Evergreen needs to specify the actions it will take to investigate and clean up any contamination affecting the deep aquifer and public water supplies.
As presented in the Remedial Investigation Reports, the lower aquifer (AOI 11) has been investigated during all the other AOI investigations completed since 2013 and the results were reported in the individual Remedial Investigation Reports. The concentrations found in the deep aquifer do not indicate a potential risk to communities in New Jersey, so no cleanup is anticipated as being necessary. The projected fate... read more
MTBE – Methyl Tert-butyl Ether (MTBE) is present in concentrations that are over 100 times higher than the state-wide health standard. (Evergreen note: the comment addresses concentrations of MTBE in groundwater).
That is correct. There are multiple compounds that have been detected in groundwater above statewide health standards (SHSs) at the facility as reported in Remedial Investigation Reports (RIRs). Methyl Tert-butyl Ether (MTBE), as well as other compounds, that are present above the SHS in groundwater will be evaluated in relation to remedial action in future Act 2 submittals, including Risk Assessment and Cleanup... read more
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 the Schuylkill River within one mile of the Site, and... read more
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?
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 Philadelphia Gas Works (PGW) Passyunk Facility, Belmont Terminal, and... read more
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... read more
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 groundwater impacts. Offsite wells have been installed beyond the... read more
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.
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 reports had separate individual models completed, and we have since updated that... read more