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?

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 which they requested closure via a combination of... read more

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.

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 those that have... read more

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).

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 the subsurface as well as significant... read more

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.

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 efforts are also part... read more

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.

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, since the groundwater conditions are not bound by AOI... read more

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 Partners as part of their environmental sampling to... read more

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?

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 debris, including sand, clay, silt, gravel, cinders,... read more

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.

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 reports have always been accessible to the... read more

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 products processed at the facility.  In... read more

Why is lead the only metals COC? Aren’t 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 reference. However, both soil and groundwater samples from various areas of the facility with history of... read more