A) On the Q+A page, responding to the question “The hydrological situation is changing …” Evergreen’s response includes the words “climate changes predicted to occur within the anticipated timeframe to completion will be considered.” B) On the Q+A page, responding to the question “Climate change-generated sea-level rise (Schuylkill, Delaware) is a given” Evergreen’s response includes the words “… i.e., how many years are predicted for Evergreen to meet Cleanup goals under Act 2 compared to the magnitude of climate change predictions within that general time period.” Both of these responses imply that only the amount of sea-level rise that occurs during the clean-up operation will be considered. However, sea level rise will continue to affect the site for decades, or perhaps centuries. 1. Can Evergreen confirm (in plain English) that it is only considering sea-level rise for the duration of the remediation project? 2. If so, why is Evergreen not considering long-term sea level rise and its impact on aquifers into account, when considering the remediation plans for the site?

It is Evergreen’s intent to consider climate changes predicted to occur within the timeframe of cleanup of the former Sunoco refinery. In general, this timeframe would be considered “long term” as petroleum contaminants in groundwater may take decades to remediate and/or degrade to concentrations below regulated standards.

Follow-up question to the question above: Can you expand on your use of quotes for “long term” in this reply. Do you consider this a reference to Act 2, Sec. 304 – Site Specific Standards?

Because long is a relevant descriptor of time that is subject to interpretation, Evergreen’s use of quotes in this response was meant to add context to the comparison of the anticipated remediation timeframe versus a changing climate as both being long term considerations. Evergreen has selected a combination of Act 2 standards for cleanup of the former Philadelphia refinery and this response wasn’t in reference to any particular standard.

Follow-up question to the question above: In the zoom meeting of December 2020, it was pointed out that climate change will continue after the remediation. The Evergreen position was clarified to state that Evergreen will follow climate change data and predictions up until 2100, which is the current limit for reliable modeling that is accepted in the wider scientific community.  Can you confirm that this is Evergreen’s policy? [Evergreen note: Evergreen held virtual meetings in August 2020 and January 2021].

Evergreen does not have a policy on this matter.  It is Evergreen’s intent to consider peer reviewed and published climate change predictions based on modeling studies for or inclusive of the Philadelphia region. To date, the year 2100 generally appears to be the most widely cited future limit for reliable climate predictions in the area. Evergreen’s assessment of potential climate change impacts on the groundwater model used for fate and transport will work within this timeframe.