1) Investigation information is out of date; some data was collected over a decade ago.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)

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. The Remedial Investigation Reports that DEP requested be... read more

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.

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 and benchmarks have been met, through their review of the... read more

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 (2-15 feet, or... read more

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?

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... 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

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?

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 has been observed in monitoring wells. Evergreen completed additional off-site delineation of the... read more

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 2013 based on discussions with the PADEP, so we will not submit... read more