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Due January 9th.
Please send the following message to the email addresses 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.
Subject: PAD510222
Please reject BP Point Breeze, LLC’s Chapter 102 construction stormwater discharge permit application (PAD510222) for its proposed warehouse at 6310 Passyunk Avenue. The precipitation estimates used by BP Point Breeze do not accurately reflect the last decade of rainfall statistics in Philadelphia. BP Point Breeze assumes that the average annual maximum 24-hour precipitation event will be 2.83 inches of rain, but over the last decade, the average maximum 24-hour precipitation event in Philadelphia was 3.84 inches of rain. This misestimation is particularly important because this significantly contaminated site is currently enrolled in the state’s Act 2 remediation program and it is critically important that stormwater not disturb contaminated soils at the site, potentially causing known carcinogens like benzene to enter the Schuylkill River and nearby groundwater. BP Point Breeze’s own stormwater discharge application clearly states that because of the site’s contamination, underground basins and rain gardens must be designed to capture all stormwater that accumulates at the site and these systems must drain within 72 hours. The Pennsylvania Department of Environmental Protection (DEP) should require BP Point Breeze to use accurate precipitation figures in designing its stormwater infrastructure because the current precipitation estimates could result in the flooding of the site. BP Point Breeze assumes that every 5 years there will be a 4.2 inch 24-hour precipitation event, but in the last 10 years this has happened 4 times, not including a 4.16 inch 24-hour precipitation event occurring in August 2020. DEP’s own 2021 Climate Impacts Assessment concluded that Southeast Pennsylvania will experience the most extreme increases in precipitation and sea level rise in the state. DEP must require BP Point Breeze to accurately reflect current precipitation data in this permit application in addition to future increases in precipitation and sea level because of climate change.
It is similarly concerning that BP Point Breeze claims to have used Philadelphia Stormwater Management Guidance Manual, Version 3.1 to meet stormwater management design standards when version 3.2 became effective on October 1, 2020. DEP should ensure the application addresses any new requirements.
As mentioned, the site’s existing land contamination and its cleanup is a significant risk to local water quality and there is simply not enough information in this permit application regarding the presence of known contaminants like benzene at the site. At minimum, DEP should require BP Point Breeze to fully dismantle the existing fuel storage facilities, including 6 large storage tanks, before the site’s design, particularly stormwater infrastructure, is approved. It is a real possibility that during the demolition of the existing fuel storage tanks, soil and groundwater pollution could be discovered. This could significantly impact the placement of proposed rain gardens and underground basins at the site, particularly for rain garden #1, which is proposed in the exact location as storage tank #6. Rain garden #1 is also the location of the proposed sediment basin to aid stormwater management during the proposed warehouse construction and storage tank demolition. DEP should require BP Point Breeze to create a sediment basin on currently unoccupied land south of storage tank #6 to ensure that demolition activities do not create water pollution discharges.
An August 2022 environmental covenant between DEP and BP Point Breeze restricts direct contact to groundwater under tank #5 because of significant benzene contamination. Similar contamination could be discovered under tank #6, which would prevent BP Point Breeze from pursuing its plan to construct a sediment basin or rain garden at that location. It is alarming that soil sampling around tank #6 was not included in BP Point Breeze’s provided image of soil sampling related to Act 32, the Storage Tank and Spill Prevention Act. DEP must require BP Point Breeze to dismantle tank #6 and test soil and groundwater in that area before approving any proposed infrastructure at the site.
Similarly, just as the site’s Act 2 and Act 32 cleanups should be concluded before the design of the site is approved, DEP should not issue this Chapter 102 water discharge permit until a firm decision has been made regarding the potential discharge of water to the Philadelphia Water Department’s (PWD) sewer system. The issuance or rejection of a PWD groundwater discharge permit will significantly impact stormwater management at the site and it would be premature for DEP to issue this Chapter 102 stormwater discharge permit before that permit decision has been made.
Finally, soil contamination at Wetland B, which is largely the area between the site and the Schuylkill River, presents significant water quality issues related to this proposal. In BP Point Breeze’s own Chapter 102 permit application it states that, “Existing Wetlands B is perched atop several feet of fill that was placed in the historic wetlands of the river floodplain decades before the Clean Water Act was enacted.” Significant soil and groundwater contamination is likely present in Wetland B because of the historic fill and its proximity to the contaminated fuel storage facility since the early 1960s. BP Point Breeze claims it is attempting to replicate the site’s current hydrology by directing almost all of the stormwater gathered at the site into Wetland B. A significant discharge of stormwater from the site into Wetland B could cause contaminated water to be displaced and discharged into the Schuylkill River from Wetland B, which is even more concerning given BP Point Breeze’s underestimation of Philadelphia’s precipitation and the likelihood that the proposed stormwater infrastructure will overflow. Further analysis of how contaminants in Wetland B will respond to the proposed stormwater discharge is necessary. DEP should also require BP Point Breeze to analyze how sea level rise will impact the tidal Schuylkill River and Wetland B, specifically how an increased water line on the Schuylkill River and increased groundwater levels in Wetland B could inhibit the area from absorbing stormwater discharged from the proposed infrastructure. DEP must also require BP Point Breeze to extensively sample soil and groundwater in Wetland B.
Overall, more information about soil and groundwater contamination at 6310 Passyunk Avenue and the adjacent wetland is needed, in addition to updated precipitation data, in order to protect water quality in the Schuylkill River and Southwest Philadelphia. The permit application also claims that surrounding residents were notified of this proposal and their concerns were addressed, but provides no evidence of either.
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