By Joseph Minott
South Philadelphia residents and the general public have long been denied a voice in the investigation and remediation process for contamination at the Philadelphia Energy Solutions refinery. In the wake of the massive explosion and fire at the site this summer, there is a new opportunity for the public to offer input on making the site safer for the surrounding communities and future use. We must use that opportunity to demand appropriate and protective cleanup standards for soil and groundwater. Currently, the approved site-specific standard for lead in soil is not appropriate and must be revised.
In 2015, the Department of Environmental Protection approved a site-specific standard of 2240 parts per million (ppm), which was twice the default health-based standard of 1000 ppm. This approval occurred without an invitation for public comment. Fortunately, this year DEP and the City of Philadelphia ensured that Evergreen, the consultant performing the remediation work, invited public comment on this cleanup standard and the remedial investigation reports that provide details about the level of contamination of soil and groundwater.
Now it is clear that the assumptions Evergreen used in calculating the site-specific standard are inaccurate and outdated. The standard must be revised to protect public health. Proper calculations result in a standard around 1000 ppm.
Since Evergreen used an inappropriate site-specific standard, its remedial investigation reports have underestimated the scope of the required corrective action for soil. With a standard of 1000 ppm, the number of exceedances that must be addressed at the Schuylkill River Tank Farm increases from 11 to 54. For the Girard Point South Tank Field, the number of exceedances increases from 11 to 55. A cleanup of just the areas with exceedances as currently defined by Evergreen would address only a fraction of the soil contamination subject to corrective action.
Groundwater is also a major area of concern. Evergreen’s reports highlight the presence of benzene (a carcinogenic chemical compound), methyl tert-butyl ether (a gasoline additive) and other hazardous substances. In 2017, Evergreen’s consultant agreed to develop a contaminant transport model for groundwater. It is not clear whether this has been done. A review of such modeling is an important part of the public comment process. The potential for contaminants to migrate in aquifers is one of a number of other groundwater concerns.
The Schuylkill River, which borders the property for several miles, is an ongoing contamination concern. There is an extensive public record of notifications to the National Response Center regarding reports of oil sheens on the river near the outfall of the Pollock Street sewer, which has been the subject of remediation work. A sheet pile wall is the last line of defense against contaminated groundwater in Girard Point entering the river. On the west bank, the Point Breeze West Yard is the site of four past disposal areas, and the evidence indicates the continuing presence of lead-contaminated soil.
Climate change and sea-level rise magnify concerns about soil and groundwater pollution. They have serious implications for future uses of the site. According to the National Oceanic and Atmospheric Administration, a local sea level rise of 2 to 3 feet will inundate large portions of land in the most heavily contaminated areas of the refinery site. It is not unreasonable to predict this rise will occur by 2050. Evergreen’s environmental investigations do not consider the impacts of climate change.
Decision makers evaluating future uses of the property should take all of these considerations into account. While these factors directly affect the extent of cleanup of the site in the short-term, they will also play a large role in the property’s long-term use. Philadelphia deserves appropriate cleanup standards and a strong cleanup. We deserve a voice in making sure those standards are met. We deserve a future use of the refinery site that fully protects public health and the environment. ••
Joseph Minott is executive director and chief counsel of the Clean Air Council.