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.

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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... read more

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!

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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 list (21 compounds) utilized for the Act 2 program at the facility was developed... read more

Will the site-specific standard be at least as stringent as the statewide standards?

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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 of the human health. As the PADEP revises their standard assumptions for... read more

Evergreen should not characterize this remediation project as a voluntary cleanup.

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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... read more

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]

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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... read more

What sampling has been done of the water and sediment in the Schuylkill River?

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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 groundwater model, which includes a surface water model that is... read more

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?

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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 timeline, which is expected to be approximately 10 years. The planned future use of... read more

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.

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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 Order & Agreement (CO&A) in 2012 and an amendment... read more