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Please send the following message to the email address below and sign the petition below. Please be sure to include your full name, phone number, and address in your email to the Pennsylvania Department of Environmental Protection.
Comments are due Monday, May 22.
RA-EPNPDES_SERO@pa.gov
Subject: Comment on PAG030177
Please deny Clean Earth of Philadelphia’s (CEP) application to renew its stormwater discharge permit for its contaminated soil incinerator located at 3201 S 61st St. in Southwest Philadelphia. This facility poses a massive risk to the health of the Schuylkill and Delaware Rivers and its claim that it has not discharged any stormwater into the Schuylkill River since the summer of 2020 has not been justified. The fact that this facility handles soil contaminated with petroleum products, petrochemicals, oil and gas drill cuttings, and substances contaminated with polychlorinated biphenyls (PCB), listed as a probable carcinogen by the U.S. Environmental Protection Agency (EPA), adjacent to the Schuylkill River should warrant extensive stormwater management systems. Yet, unfortunately, current stormwater management systems are not functioning.
CEP is not adequately managing stormwater at its site. CEP claims that two of its stormwater outfalls stopped discharging stormwater to the Schuylkill River in the summer of 2020 and have not discharged since, but does not provide a justification or explanation. CEP even claims that the third stormwater outfall to the Schuylkill River has not discharged stormwater since 2016. CEP admits that the vast majority of stormwater that enters the site flows in the direction of the Schuylkill River and into the three stormwater outfalls and additionally claims that 79% of the site (347,302 square feet) is comprised of impervious area that does not absorb water. In March 2023, during an inspection, DEP discovered standing water at the facility that it deemed a public nuisance. Given the information in the application, it would seem to be physically impossible for this site to not discharge stormwater into the Delaware River during rain events. DEP must require CEP to fully explain where stormwater goes at this site during rain events. After it is determined where the site’s stormwater travels during rain events, DEP must require CEP to consistently sample the discharged stormwater for heavy metals like lead, the known carcinogen benzene, and PCBs. In addition, because the site mixes the incinerated soil contaminated with petroleum with water treatment plant sludge, Class A biosolids (dried sewage) and Class B biosolids (also dried sewage, but has more pathogens), DEP must require CEP to test discharged stormwater for contaminants commonly found in sewage, like fecal coliform and pathogens like E. Coli and Salmonella. Per- and Polyfluoroalkyl Substances (PFAS) are also commonly found in sewage and include probable human carcinogens listed by the EPA. PFAS are also highly toxic to aquatic life. Sewage-related water pollution also contributes to the proliferation of antibiotic resistant bacteria, because of widespread antibiotic contamination in sewage.
More broadly, DEP must require CEP to justify its use of water treatment plant sludge and biosolids as soil additives necessary to reach a certain consistency. Adding additional contaminants to an already-contaminated post-incinerated product is an unnecessary risk to the Schuylkill and Delaware Rivers. At the bare minimum, DEP should require CEP to store all contaminated soils and sewage-related soil additives inside the facility or inside properly sealed storage containers at all times. There is no reason to leave these substances in piles outside, exposed to the elements, where they can be dispersed to the public and the Schuylkill River by wind and rain.
This facility is less than three miles from the Delaware River and this facility’s water pollution must be reduced in order to protect the Schuylkill and Delaware Rivers. DEP must make a conclusion regarding where the site’s stormwater is discharged.
Before CEP claimed that outfalls 2, 3 and 4 stopped discharging stormwater, the company’s own testing of discharged stormwater confirmed high levels of lead, which is extremely toxic to aquatic life. CEP’s reported average discharge of stormwater containing 488.5 mg/l of Total Suspended Solids (TSS) with a maximum of 1640 mg/l is also extremely concerning, particularly considering that these solids could contain petroleum-related chemicals like the known carcinogen benzene. Simple filtration technologies can reduce TSS levels in discharged water and should be required at CEP’s soil incinerator. The silt socks CEP is currently using to filter pollutants are clearly not working given the last reported discharge of TSS. Reducing TSS discharges will be important in ensuring that discharges from the site do not undermine an upcoming U.S. Environmental Protection Agency’s rulemaking to improve dissolved oxygen in the stretch of the Delaware River from Trenton, NJ to Wilmington, DE, including Philadelphia, PA. This rule will better protect fish propagation in this stretch of the Delaware River, which is currently endangered by water pollution discharged by industrial facilities along the river, including the CEP soil incinerator in Philadelphia. Given the extremely high TSS concentrations in stormwater discharged from this facility into the Schuylkill River, it is clear stormwater controls are not functioning at this facility.
DEP must not grant this permit renewal before these issues are resolved.
Thank you for considering my comment.
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