Dear Friend,

Evergreen Resources Group, LLC is a subsidiary of Sunoco LLC, the company liable for historic soil and groundwater contamination at the former Philadelphia refinery. Evergreen is leading the environmental cleanup of the site as required by Pennsylvania’s Act 2 of 1995 and is now required to submit a report to the Pennsylvania Department of Environmental Protection (DEP) regarding the “fate and transport” of pollutants at the site like benzene (a known carcinogen) and lead, which can damage brain function and harm other vital organs like kidneys. Act 2 defines “fate and transport” as “the degradation of a chemical over time and where chemicals are likely to move given their physical and other properties and the environmental medium they are moving through.”

Clean Air Council believes that Evergreen has not adequately documented the potential for dangerous pollutants to travel at the site, which could potentially increase human exposure and damage wildlife and ecology. The Council urges you to submit an official comment asking DEP to disapprove this report. Comments are due at the end of the day Saturday.

The Council has many concerns about soil and groundwater pollution at the site and is concerned with Evergreen’s description of how groundwater will move at the site over the next 30 years, particularly given the potential for the Schuylkill River to flood because of the increased effects of climate change. In the discussion of climate resiliency in Evergreen’s report, it included projected sea level rise and the effects that would have on the tidal Schuylkill River, but it did not mention the effects of increased precipitation resulting from climate change, which will be compounded by increased impervious area. This is even more concerning given that the site’s new owner, Hilco Redevelopment Partners, is proposing to raise and pave the majority of the 1,400 acre site. This would add massive amounts of impervious area and greatly increase the risk that the Schuylkill River would flood during a storm and increase the risk of exposure to dangerous contaminants currently in the site’s soil and groundwater. 

Please tell DEP to disapprove this inadequate report for the many reasons the Council has outlined in this suggested comment. Click here to submit an official comment by Saturday, July 30th.

Sincerely,

Joseph Otis Minott, Esq.
Executive Director and Chief Counsel

Sources:

https://billypenn.com/2015/03/31/cancer-in-philly-eight-maps-and-charts-show-the-citys-high-cancer-rate/

 

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