draft community outreach plan former philadelphia refinery ......2020/08/11 · draft community...

Draft Community Outreach Plan Former Philadelphia Refinery Act 2 Remediation Program

1 Version dated August 11, 2020

This draft of the Community Outreach Plan was prepared in the spring of 2020 and shared with members of the public and regulatory agencies for initial comment. Evergreen is interested in receiving additional comments on this approach from the public as part of the overall process to engage with the public on Evergreen’s proposed activities at the Former Philadelphia Refinery.

Overview This community outreach plan (COP) has been prepared as an attachment to Evergreen’s public involvement plan (PIP) for the Act 2 remediation process at the former Sunoco Philadelphia Refinery (Site). Both the PIP and the COP can be found on the Public Involvement tab on Evergreen’s website at https://phillyrefinerycleanup.info. The Site, currently, and since 2012, known as the Philadelphia Energy Solutions Refining and Marketing LLC (PES) Complex, consists of approximately 1,400 acres. The Site has been divided into 11 Areas of Interest (AOIs) for environmental investigation. Evergreen is addressing environmental impacts to soil and groundwater from before the sale of the property to PES in 2012. These impacts are being addressed through the Pennsylvania Department of Environmental Protection’s (PADEP) Act 2 cleanup program and the joint PADEP and US Environmental Protection Agency (USEPA) One Cleanup Program.

This COP presents:

How Evergreen plans to communicate with the public about Act 2 activities at the Site,

The timeline for community engagement, and How the public can engage in the public involvement process.

Background The Act 2 Program includes requirements for notification and public participation. A Notice of Intent to Remediate (NIR) was submitted to the PADEP in 2006, formally entering the Site into the Act 2 Program. A PIP was developed at the request of the City of Philadelphia in 2006 and was updated in 2019. Numerous communications have occurred between Evergreen, the City of Philadelphia, PADEP, USEPA and the public in 2019 and 2020 about the Site. Based on these communications, Evergreen has committed in the COP to additional activities beyond those outlined in the PIP and those required by the Act 2 Program. These activities are presented in Figure 2 and described in more detail in later sections of the COP.

Figure 1: Former Sunoco Philadelphia Refinery


Community Outreach Activities Community outreach will be completed through a matrix of individuals, neighborhood contacts, community groups, environmental groups, public officials, state/federal agencies and the business community in an effort to reach interested people, as shown in Figure 3. The importance of a flexible program is highlighted by the recent COVID-19 outbreak; it may not always be possible to communicate as planned, so Evergreen has incorporated flexibility into the COP approach.

Evergreen has worked with the City of Philadelphia, community leaders, environmental groups, PADEP and USEPA to identify individuals, civic groups and local businesses who may be interested in the Act 2 process at the Site. Evergreen is communicating through many different types of media, including the Evergreen website, email, newspaper, hard copy mailer, public meetings and social media. Evergreen has also translated certain documents into Chinese, Vietnamese and Spanish, for non-English speaking members of the community and provided a google translation button on the website to assist in translation of information. If an individual or a group is not included on one method of communication, it does not mean that they cannot review documents or provide comment. People are encouraged to share information with others who may also be interested in the process. All public comments will be considered equally, regardless of the method of response utilized.

Evergreen website - Evergreen created a website, which includes all of the completed Act 2 reports, the PADEP comments to these reports and supporting information. The following link is to the documents page of the site (https://phillyrefinerycleanup.info/act-2-documents/). Also included in the website is an area where the public can directly upload comments (https://phillyrefinerycleanup.info/report-comments/) or ask questions. The website also includes a question and answer (Q&A) page (https://phillyrefinerycleanup.info/q-a/) and responses to questions. The dates of upcoming events including public meetings, report submittals and other key events are posted to the website (https://phillyrefinerycleanup.info/public-involvement/). People can submit comments and questions through the Evergreen website, email address ([email protected]) or P.O. Box 7275, Wilmington, DE, 19803.


Email notifications - Evergreen has worked with the City of Philadelphia, community leaders, environmental groups, PADEP and USEPA to create an email distribution list for individuals, civic groups and local businesses who may be interested in the Act 2 process at the Site. Email notifications will be sent to this distribution list in advance of public meetings and report submittals and will be used for other general communications. If an individual or a group is not included on the email distribution list, it does not mean that they cannot review documents or provide comment. People receiving these notifications are encouraged to share them with others who may also be interested in the process. Anyone can be added or removed from the distribution list upon request.

Social Media - Evergreen encourages community partners to utilize social media to notify their members of upcoming public meetings and report submittals. Evergreen will prepare public notifications in formats that can easily be used by the community partners within their social medial platforms to streamline the public’s efforts to provide comments on the Act 2 process at the Site.

Public Meeting - Evergreen is planning to have a public meeting on August 27, 2020 to provide the public with information on who Evergreen is, what we have done to date at the site, and what are we doing next. During the meeting, we will review the Act 2 reports and interim remedial activities which have been completed to date and the next steps in the Act 2 process. This public meeting will start a 120 day public comment period for the Act 2 reports that have already been submitted and approved by the PADEP. Evergreen will hold a second public meeting at the end of the 120 day comment period to close out the comment period. This 120-day period is to collect comments on past reports, but the public can send questions and comments on any topic at any time even after this period is over.

Evergreen is planning to have additional in-person public meetings, unless social distancing restrictions or other constraints prevent it. Virtual, web-based meetings, which will be recorded, may be held as an alternative, if necessary. Notification of the public meetings will be made through the Evergreen website, email, newspaper and notification to the City of Philadelphia, PADEP and USEPA. Evergreen will compile the comments received during the 120 day public comment period and prepare a report with all of the comments and responses. After this report is completed, Additional public meetings will be held at key Act 2 milestones.

Plain Language Summaries - Due to the technical nature of the Act 2 process, the reports include a lot of technical terms, concepts and acronyms. Evergreen has created plain language summaries for all of the submitted Act 2 reports included on the Evergreen website and another document titled Overview of Former Sunoco Philadelphia Refinery Environmental Investigations to assist in the public’s review of these documents (https://phillyrefinerycleanup.info/act-2-documents/). These documents are also available at two local library branches (noted below) along with all other Act 2 documents. Evergreen will include plain language summaries for all future Act 2 submittals as well.


These methods of communication are summarized in Figure 4. The timeframes for these activities are described in the following section.

Hard Copy Mailer - Evergreen sent a hard copy mailer in June 2020 to all known addresses of residents and businesses around the Site to notify them about Evergreen’s Act 2 activities at the Site. The mailer was also sent to a list of community groups/associations, community leaders, and other individuals provided by the City of Philadelphia and the USEPA. If an individual or a group is not included in the mailer distribution list, it does not mean that they cannot review documents or provide comment. People receiving the hard copy mailers will be encouraged to share them with others who may also be interested in the process, in addition to all of the other methods of communicating to the public about the meeting. The mailer was also sent to those on the email distributions list.

Newspaper Notifications Evergreen will include newspaper notices in the Philadelphia Daily News and the South Philly Review prior to any public meetings and report submittals.

Library Electronic copies of all of the Act 2 reports stored on the Evergreen website are also available at two branches of the Free Library of Philadelphia: Thomas F. Donatucci, Sr. Library at 1935 Shunk St. and Eastwick Library at 2851 Island Avenue. In addition, hard copies of the plain language summaries will also be made available at these two locations.

Notification to Municipalities and Agencies Letters will be sent to the City of Philadelphia, PADEP and USEPA prior to any public meetings or Act 2 report submittals before the meeting or report submittal.


Timeline of Activities The communication timeline for the COP will be based on the Act 2 milestone submittals for the Site, which are depicted in Figure 5, and include:

Notice of Intent to Remediate Remedial Investigation Report Risk Assessment Report Cleanup Plan Final Report

The Site is currently at the stage of the Act 2 process where Remedial Investigation Reports (RIRs) have been prepared for each area of the site, with a few AOIs requiring RIR addendums. An RIR is a report that describes all of the data collected to demonstrate that the environmental conditions at the property are known; this is called “characterization”. All of the RIRs already submitted and reviewed by the PADEP can be found at (https://phillyrefinerycleanup.info/act-2-documents/).

The public is encouraged to provide comments to these documents during the first public meeting, through the 120 day comment period following the first public meeting and/or during the second public meeting closing the 120 day comment period. Once the 120 day comment period closes, Evergreen will prepare a report summarizing the received comments and responses. Once the report summarizing the public comments and responses is approved by the PADEP, Evergreen can begin to submit the RIR addendums for the few remaining areas of the Site. These addendums will be reviewed by the PADEP and USEPA and the public can provide comments on these addendums. Once the addendums are approved, Evergreen will submit a fate and transport RIR, an ecological risk assessment report, a human health risk assessment report, cleanup plans followed by final reports in accordance with the Act 2 requirements.

All future reports submitted under the Act 2 program will be reviewed by the PADEP and USEPA. The public is welcome to submit comments on reports during the 30 day comment period after the reports are submitted. Within 30 days of the close of the agency’s review period, Evergreen will submit to the PADEP and EPA, and make available on the website, a summary of the comments received during the comment period (along with Evergreen’s responses) so that the PADEP and EPA will have these items available to them during their review of the reports. In addition, comments received to the reports may be included on the Q&A section of the website. Figure 6 provides an overview of the Act 2 process along with relative timeframes. The timeframes in Figure 6 are approximate and may be revised based on comments from the public or the agencies during the remainder of the Act 2 process.


Public Notification Public Meeting Act 2 Submittal

Notification(s) of Public Meeting August 2020 Public Meeting

Second Public Meeting

Public Comment RIR

Notification AOI 9 RIR Addendum

Notification AOI 4 RIR Addendum AOI 9 RIR Addendum

AOI 4 RIR Addendum

Notification Fate & Transport RIR and Public Meeting

Fate & Transport RIR Public Mtg

Fate & Transport RIR

Notification Ecological Risk Assessment

Ecological Risk Assessment Public Meeting

Ecological Risk Assessment Report

Notification AOI 10 Cleanup Plan/Final Report

AOI 10 Cleanup Plan and Final Report Public Meeting

AOI 10 Cleanup Plan and Final Report

Notification Sitewide Groundwater Final Report

Sitewide Groundwater Final Report Public Meeting

Notification Sitewide Groundwater Final Report

Notification of Human Health Risk Assessment and Cleanup Plan for

AOI 8

Human Health Risk Assessment and Cleanup Plan for AOI 8 Public

Meeting

Human Health Risk Assessment and Cleanup Plan for AOI 8

Figure 6 - Act 2 Submittals and Public Participation Timeline R

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draft community outreach plan former philadelphia refinery ......2020/08/11 · draft community...

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