PFAS had not been sampled during the Remedial Investigations as it was not included as a Contaminant of Concern. However, as noted during public meetings, PADEP and Evergreen have had discussions regarding future sampling of these compounds. A formal request was subsequently received from PADEP to sample remediation system effluents for PFAS compounds. Upon receipt of data, results will be discussed with PADEP.
Note: other questions and comments have been posted on PFAS:
- 1) The PA Dept of Environmental Protection has added Per- and polyfluoroalkyl substances (PFAS) to the recent regulations for contaminants—likely present in refineries, since they are used in firefighting foams. Indeed, other states such as Alaska, Michigan, Colorado and Wisconsin found PFAS contamination in refineries, and are requiring or undergoing remediation of those sites. The site should be tested for these contaminants and required to address the contamination.
- 2) The Site is a Significant Potential Source of PFAS to the Environment
- 3) It is important that public agencies at the state and city level ask more of Evergreen. Basic reporting, as required by state law, is not sufficient for this site. PFAS, for example, are likely highly concentrated here due to firefighting on site. I support the specific reporting measures recommended by the Clean Air Council in Mr. Minott’s op ed in The Inquirer this morning (January 13). This would be a big step forward.
- 4) Regarding the F&T model, are PFAS compounds going to be included in the model? A model in 2001 showed that groundwater does flow from beneath the refinery to parts of New Jersey, so we wanted to know if PFAS compounds, especially PFOA, PFOS and PFNA, are going to be sampled and included in the modeling?
- 5) Applicable Guidelines Require PFAS Investigation
- 6) The PES Site should be required to sample for PFAS using appropriate EPA Method 537 methodologies in shallow and deep groundwater and surface water and soil consistent with EPA and PADEP requirements. The Site has experienced multiple releases of AFFF, a product known to contain PFAS, and the lower aquifer beneath the Site, the Potomac-Raritan-Magothy (“PRM”) aquifer system, is a major source of drinking water in New Jersey. **The report prepared by EPA’s contractor, Skeo Solutions, Inc., acknowledges that contamination in the lower aquifer could migrate offsite and affect the water supply for parts of New Jersey. EPA’s policy, Interim Recommendations to Address Groundwater Contaminated with PFOA and PFOS, sets a preliminary remediation goal of 70 ppt for PFOA and PFOS in groundwater that is a current or potential source of drinking water. The Pennsylvania Act 2 program uses the EPA PFOA and PFOS Lifetime Drinking Water Health Advisory Level of 70 ppt as the groundwater medium specific concentration (“MSC”). New Jersey, where drinking water supplies may be impacted, has established an MCL of 14 ppt for PFOA, 13 ppt for PFOS, and 13 ppt for PFNA.
- **The question above notes The report prepared by EPA’s contractor, Skeo Solutions, Inc., acknowledges that contamination in the lower aquifer could migrate offsite and affect the water supply for parts of New Jersey. Skeo’s report noted “The refinery’s pollution may affect an area of underground water (i.e. an aquifer) used by the state of New Jersey for drinking water”. That statement is accurate in that an aquifer exists beneath both the former refinery and parts of New Jersey, and Evergreen has acknowledged impact in the lower aquifer beneath the former refinery. However, it is highly unlikely that contamination sourced at the refinery could migrate into New Jersey. We have also noted that until a chemical fate and transport model can be completed, this cannot be confirmed.