The purpose of this blog is to document biosolids and water extraction projects that do not meet zoning requirements, in an effort to protect the rights of neighboring landowners and residents. The initial project was Nestlé Waters in Kunkletown, Eldred Township, and the current ones are Jay Land's Ringgold Acquisition Group II LLC and MC Resource Development in West Penn Township and Synagro biosolids in Plainfield Township - the "Slate Belt Heat Recovery Center". We all live downstream.
It is common knowledge that the air quality in Northampton County is impaired. The air quality does not meet the standards for Ozone or PM2.5 particulates.
PM2.5 means particles suspended in air that are less than 2.5 micrometers - about 3% the diameter of human hair. PM10 refers to particles that are 10 micrometers or less, so PM10 includes particles that are PM2.5.
There are pages on an EPA website for the Grand Central landfill and Energy Center that reflect the fact that Northampton County's air does not meet these two standards. This does not mean each facility does not meet standard - but that the air where it is located does not.
Northampton County's air quality sucks - newsflash
Synagro plant will apparently exceed threshold for a minor air quality permit
Synagro's application states that they expect to emit 15.47 tons per year PM10. The EPA has established a standard for new sources in PM2.5 non-attainment areas that seek a minor permit of 15 tons per year (tpy) of PM10. An EPA memorandum that documents this standard is located here. At the bottom of page 3 is this statement:
"On July 1, 1987, we established a significant emissions rate for PM-10 of 15 tpy"
Since PM10 embodies PM2.5, regulating PM10 emissions regulates PM2.5. Thus Synagro's facility should require a Title V major air quality permit. Synagro's Air Quality Permit application does not reflect that Northampton County's air quality is impaired, nor does it mention that the applicable standard to be exempted from a Title V permit has been exceeded.
Single Source determination claim in Air Quality Permit application
Apparently, when Synagro and Waste Management met with their chums at the DEP a year ago, a gentleman's agreement was made that Synagro's plant would be a "single source" of air emissions. Accordingly, Synagro applied for an Individual Air Quality Permit. However, common sense tells anyone with a brain that this is unadulterated bull shit. The operations of Grand Central, Green Knight and Synagro are all connected by both contracts and energy source, and all on land owned by Waste Management. These must be permitted as a group. Let's look at an aerial:
DEP apparently can't discern it's ass from a hole in the ground
Syangro's proposed plant would not be a single source
Here is where in Synagro's application it is revealed that it coordinated with DEP on this matter:
Synagro's engineer claims it is entitled to an Individual Air Quality Permit
Note that Synagro makes no mention of the fact that the first two criteria are met - the facilities do belong to the same industrial grouping, and the facilities are adjacent. Waste Management controls this whole proposed operation, and owns the land all are located on. Obviously none of these three are a single source in the context of emissions - they are all emitting into the air based on the operation of the landfill, and should come under a single Air Quality permit.
DEP is an acronym for the Pennsylvania Department of Environmental Protection, but what it really means is:
DON'TEXPECTPROTECTION
This sounds a bit harsh, so let's look at recent local evidence that support this statement.
In the early 2000's, DEP approved the Buzzi Unicem Quarry in Stockertown being lowered by 50'. Within a short period of time, sinkholes developed that swallowed a few houses and a bridge that can not be replaced. The Bushkill Creek now runs dry for over 2 miles unless massive pumps at Buzzi are operational. Four times in the last year, power outages have resulted in countless fish dying. PennDOT's new multi-million dollar bridges over the Bushkill Creek are sinking and will need to be replaced due to unstable geology.
In about 2010, DEP approved the Slate Hills Quarry in West Bangor be filled to reclaim the land for commercial use. Within a short period of time of commencement, Nestle Waters' Deer Park wells were contaminated. Nestle was forced to drill an interceptor well, which continues to be required to be run to pump 290,000 thousands of gallons of contaminated water daily from the aquifer into a creek so it does not reach the production wells. The adjacent Green Walk Fish Hatchery experienced degraded water quality and dead fish as a result. DEP revoked the permit they had issued. See a news article on this here.
The Solid Waste Department of DEP in August 2018 approved the partial filling of a quarry that is located within five feet of the proposed Synagro biosolids facility in Plainfield Township (water within 20 feet), and approved a waiver for the quarry so that it will not require a Clean Water permit. Although this quarry is known to connect with an aquifer, and two high quality creeks are within a few hundred feet, the Clean Water Department of DEP apparently had no say in this matter. All of Synagro's outdoor activities (loading, unloading, truck wash, trucking) are within 50 to 75 feet of the new proposed boundary of the pond, and some are within its current boundary. Plainfield Township has appealed this decision to the PA Environmental Hearing Board.
Wednesday November 7 hearing
On Wednesday, November 7, there will be a DEP hearing on the Synagro application to locate a biosolids plant in Plainfield Township. There will be a public question and answer session followed by a public comments session held at Wind Gap Middle School. Representatives of Synagro, Green Knights and Waste Management will answer questions. It is vitally important for all concerned citizens to attend and send DEP a message that we aren't going to take this shit - whether you plan to speak or not. And this is the chance to ask questions of Synagro, Green Knight, and Waste Management and expect answers.
If you plan to speak, call or email Colleen Connolly ahead of time (Tuesday November 6) at coconnolly@pa.gov or 570-826-2035 to reserve a speaking slot. Otherwise, there may not be time to handle all walk-ins. You may also submit written comments the night of the meeting or up until November 21.
6:00 to 6:05 Synagro presentation
6:05 to 6:15 DEP describes permitting process
6:15 to 7:45 Q & A - two questions per citizen, and one follow-up
8:00 to 9:30 Public comment of 5 minutes or less each, depending on number of speakers
What is this about FOUR permits/applications being reviewed on November 7?
When this hearing was first announced September 29 in the PA Bulletin, it was to consider only one permit - an NPDES (stormwater) Draft Permit. This covers surface water runoff. A Draft Permit number is needed to submit specific written comments, and for the NPDES permit it is #PA0276120. DEP had also announced that a General Waste Management Permit Application for the facility had completed an administrative review, and written comments on "technical deficiencies" were due by October 17 for Permit Application #WMGR160. The expectation was that DEP would review claimed deficiencies with Synagro, and a response be generated.
However, DEP abruptly changed course in the last week and added the General Waste Management Permit for the Synagro facility for public comment on November 7 as if it is a Draft Permit. But as of today, there is no Draft Permit and thus no Draft Permit number corresponding to this permit application. In the last week, DEP also announced that a Grand Central Waste Management Permit Modification would be reviewed as a Draft Permit on November 7. But as of today, there is also no Draft Permit or Draft Permit number corresponding to this permit application. A DEP spokesperson stated "we plan to publish these two draft permits as late as the day prior to the hearing." There is no way to submit written comments on these two permit applications as if they are Draft Permits, since they are not yet Draft Permits. They will publish the Draft Permits on Tuesday and take oral comments on Wednesday? This is horse shit!
The fourth permit application is for an Air Quality Permit Approval. This was announced in the PA Bulletin on October 20, and is Approval Application #48-00111A.
To summarize :
NPDES Draft Permit - covers stormwater runoff into a freshwater pond, and two HQ creeks
General Waster Management Permit - anything related to the Synagro plant
Grand Central Waste Management Permit Modification - covers truck traffic, use of scales and roads, and use of Sedimentation Basin #2 to collect stormwater runoff.
Air Quality Permit Approval - covers particulates at silos and conveyors, odors associated with handling/processing
Speak your mind - about this plant or biosolids application to farmland
Don't let this alphabet soup confuse or intimidate you. It is clear the PADEP does not want this hearing, and does not want to return to Wind Gap for another hearing on the Synagro plant. Heck, DEP has recently refused to even come to the Slate Belt to discuss the application of biosolids to farmland - which is not the subject of this hearing but you should take advantage to voice your concerns and let DEP know what is important to you. You may not get another chance anytime soon, because DEP is hiding behind "pending litigation" to avoid discussing the topic.
Something to consider - DEP normally would issue an Individual Permit, not a General Permit for the Synagro facility. A General Permit will allow other facilities like this one to be approved across the state of Pennsylvania to be quickly approved in the future. Reportedly, DEP instructed Synagro to file its application for a General and not an Individual permit. Could DEP actually envision this poorly designed pile of crap next to a freshwater pond as a prototype for future facilities? Don't laugh - this may in fact be DEPs plan. The problem is, this site is not suitable for a Synagro facility. DEP picked an extremely poor model if this is intended to be the first of many "green" waste/energy/biosolids processing projects in the state.
What questions should I ask?
There are talking points on the Delaware Riverkeeper's website for both water and air issues. These will be reviewed on this blog Tuesday night. In the interim, here are a few quick suggestions:
How can the Clean Water Department of DEP stand idly by, and let the Waste Management Department issue waivers that remove protections of a fresh water pond?
Does DEP know how deep Sedimentation Basin #2 is, and if so how do they know it?
What is the hydrogeology of Sedimentation Basin #2, and if it is not known, how could a waiver be issued to allow partially filling it? Was the lesson of West Bangor not learned?
Did DEP instruct Synagro to file a General Permit application for its facility, and if so why?
Why is Green Knight giving away its waste heat for less than 1/20th the cost of heating using natural gas?
Was Green Knight pressured into partnering with Synagro in exchange for renewal of its lease which was set to expire in 2019?
Green Knight is expecting to get a maximum of $100,000 a year. What is the maximum that Waste Management expects to get from Synagro?
Is there a profit sharing agreement between WM and Synagro?
Why isn't DEP suspending the Synagro applications until the appeal of the waiver of a Clean Water permit for Sedimentation Basin #2 has been resolved before the PA Environmental Hearing Board?
Synagro stated in its application that it satisfies the Zoning Ordinance, and that it has obtained Zoning Approval. These statements are not true - when will Synagro file applications for two zoning variances that are required?
And here is another question - has DEP implemented any of the safeguards recommended by Nestle hypdrogeologist Eric Andreus, regarding decisions and procedures to be followed when filling a quarry? Specifically, Andreus recommended first understanding the geology of the quarry - which Synagro has steadfastly refused to do. No one knows what is going on with water flow in Sedimentation Basin #2, and how it interacts with the Little Bushkill and Waltz Creeks. Read Andreus' letter here.
DEP really does NOT want to discuss biosolids in public
This proposed hearing is absurd and grossly inadequate. Citizens are concerned about this plant, and they are also concerned about their properties near farms where biosolids may be spread. DEP pulled a fast one by cramming 4 permits in where only one was advertised so they can get in and get out. And DEP doesn't want to even talk about a topic of wider concern to Pennsylvanians - biosolids spread on farmland.
Here is an email that Senator Scavello's representative Taylor Munoz sent a constituent. DEP was sued by East Penn Township over a permit issued to a single farm, and is using this as an excuse to not participate in public Senate hearing that Scavallo tried to call. Not this hearing on Synagro's plant, but a hearing on the use of bioslids. Mr. Munoz states the obvious - having DEP involved it critical - but DEP refuses to participate. If what is written in the email is true, DEP will never be involved in a conversation that must be had. Maybe you will want to voice your concerns on November 7 and tell DEP this position is unacceptable.
DEP's lame cop out to not discuss biosolids allplication to farms
At the October Plainfield Township BOS meeting, Peter Albanese of Green Knight Economic Development Corporation reportedly stated that Green Knight will take in "up to $100,000 per year" selling its waste heat to Synagro. Thus, the communities of Wind Gap, Pen Argyl and Plainfield Township may receive up to $33.3K each, per year - a pittance. In short, they will take it up the rear.
Setting aside for a moment that no amount of money would ever compensate local residents or the communities within 50 or 100 miles for having Class A (90% dried) sludge spread on farmland, let's take a deep dive into the economics of this operation - and in the process see how Waste Management may profit handsomely from the proposed operation while the host communities and those within delivery distance become literal shitholes.
In Synagro's NPDES permit application to DEP it states that the product Synagro will process is 21% solids. There is industry data available that details the amount of energy required to dry-roast shit on belt conveyors, which is the same process that Synagro proposes. A chart published by Veolia Water Systems/Kruger on the "BioCon" dryer is presented, which has been marked up accordingly:
What the chart shows is that to dry 9523.8 pounds of "wet cake" to Class A biosolids (90% dry solids), just over 11 million BTU of energy is needed. Since there is 1000 btu in one cu ft of natural gas, and the industrial cost of natural gas in August 2018 was $9.38 per 1000 cu ft, we divide by 1000 twice to find that 11 cu ft of natural gas is needed. This is a fuel cost of $103.21 for 9523.8 pounds, or $21.67 per wet ton.
Recall that Synagro proposes to bake 400 tons of crap a day, so the cost of using 100% natural gas per day would be 400 * 21.67 = $8669.88.
Now let's compare to the cost of Green Knight's waste energy. At a planning commission meeting a few months ago, Synagro project manager Jim Hecht stated that Synagro plans to use 84% waste heat and 16% natural gas. So much for being the "green" project this is hyped to be - Synagro can't run on 100% waste heat. At $100,00 per year, Synagro will pay $273.97 per day for 16% of its baking costs. That is $273.97/(0.16 * 400) or $0.81 per wet ton.
Something stinks here:
To heat with natural gas, Synagro pays $21.67 per ton
To heat with Green Knight's waste heat, Synagro pays $0.87 per wet ton.
Synagro's fuel cost per day will be reduced to 0.84 * 400 * 21.67 + 0.16* 400 * 0.87 = $1387.18 + 273.97 = $1661.15, or $4.15 per wet ton. Jim Hecht also agreed in the past few months "this plant could run profitably running on 100% natural gas." In other words, Synagro could afford to pay $8669.88, but will only be paying $1661.15.
Let's look at how the plant could run profitably on 100% natural gas, and consider the consequence that Green Knight appears to be screwing citizens twice over - once for partnering in this operation, and twice for not receiving even 1/10 of fair market value for its waste heat. And in the process we will discover why Waste Management wants this so badly... It's green - money, that is.
There are several assumptions here, and they are shown. Since Synagro is not building a waste water treatment facility, the cost of the plant has been reduced $2m from an original estimate of $10m. The lowest paid employees (most of them) are estimated to earn $35,000 a year, and one or two lucky people $80,000. The waste water of this operation is loaded with ammonia and nasty. Assuming it doesn't leak into high quality water bodies and Synagro finds someone to take it, the cost of disposing it was estimated.
In the S&P 500, an 11% profit margin is typical. We have allowed for 18.6% here. Look at who the big winner of this shitty operation could be - Waste Management. They can pretty much charge what they want. Using the estimates above,
Using 100% natural gas, Waste Management may receive $8000 per day or $2.9m per year
Using 84% waste energy, Waste Management may receive $15000 per day or $5.5m per year
The assumption is that Synagro delivers the product for the cost of delivery - there is no need to charge for the product because it is so lucrative to haul the raw product away from sludge generators.
Once the landfill shuts down and the waste heat goes away because the landfill gas to energy plant is shuttered, Waste Management will remain on easy street for decades. And Synagro's trucks will be using a "street" that is actually Plainfield Township's recreational trail.
Did Waste Management dictate that Green Knight will only receive $0.87 for energy that would otherwise cost Synagro $21.67? There is evidence that Green Knight's lease with Waste Management that was just renewed for 20 years may have been used to leverage GK's participation with this project. At each of the planning commission review meetings this year, several Waste Management personnel have been in attendance. Now it is very clear that Waste Management is the driver of this operation, not Green Knight. Waste Management will very likely reap millions of dollars of income per year from this operation, while Green Knight gets table scraps of "up to" $100,000. You just could not make this shit up. "Slate Belt Heat Recovery Center" my ass.
This project is in fact green - but not to the environment. It is green to Synagro and Waste Management, and shit-brown to everyone else.
Green Knight is serving up shit on a stick to Slate Belt residents,
while Synagro and Waste Management feast on a bottemless buffet of cash
Imagine that you live next to or near farms, and there is a plan to spread dried shit on those farms. An "economic development" organization which came up with this plan explains that it will bring in revenue that otherwise would be lost, and in the process it will produce good quality jobs. This is the claim.
Off the top, this sounds like a harebrained plan. What price do you put on your quality of life, and what about your property values? If your neighbor spreads shit on his property, will your property value:
A. Go up
B. Go down
C. Stay the same
D. Who the fuck cares, because this is economic development in someone's mind
The PA "Department of Environmental Protection" requires testing for only 9 trace elements and one synthetic compound (PCB's) in biosolids. The fact that pathogens, endotoxins, and toxic chemicals remain in Class A biosolids after some bacteria are reduced by baking shit cake at 175 degrees:
A. Sounds like something that requires much more research and regulation by the agencies that are supposed to protect my family's health, because this is like Russian Roulette
B. Is unacceptable to remain in a product used to "fertilize" the land near my property
C. Sounds scientific, but convince me I should be concerned
D. Who the fuck cares, because this is economic development in someone's mind
A good quality, well paying job - what exactly is that? If my family's health is degraded and our property's value goes down in order to provide someone a job elsewhere in town, is this a desirable job in the eyes of the community where it is located? Now let's say the job is moving shit around in a factory that bakes shit cake 24 hours a day. Trucks loaded with wet shit roll in and dump their load, the shit is conveyed around and baked, dried shit is lifted to lofty heights in buckets, and stored in shit silos for bulk delivery. Is this a job I want my child to do? Will this provide an opportunity for my child to go further than I did?
A. $35,000 a year is a great salary and will attract other new development and families to the area
B. $35,000 a year is above the poverty level, so this is awesome - aim low
C. This is "going further" than I ever did - I crapped for a day once when I had food poisoning, but these jobs will allow my son to be immersed in crap all day, every day. A man shits, and it just goes down the drain. But give a man a shovel, and he can move shit for life
D. Who the fuck cares, because this is economic development in someone's mind
Green Knight announces that it expects about $100k a year revenue from partnering with shit processor
A Green Knight representative reported at a recent municipal meeting that in selling its waste energy to Synagro to bake shit, it expects on average to receive $100k in revenue per year or $274 per day. Since Green Knight is supposed to support distressed citizens in three communities, that is a whopping $33,333 to benefit each town annually or $91 per day. Per resident in Wind Gap, this is 3.4 cents per day, for Pen Argyl, 2.6 cents per day, and for Plainfield Township, 1.5 cents per day. That is what you get in return for putting your water, air and health at risk, and coping with smelly trucks full of shit trundling around the Slate Belt. And your property value going down the shitter. Now that is economic development, Green Knight and Waste Management style.
Are you frigging kidding? That is a shade less than a single Synagro employee will earn for facilitating 133 tons of shit around in a shift at the plant at a job claimed to be good quality by the fools promoting this folly. Meanwhile, all the neighbors and citizens have the distinction of living in Shitsville, USA, and enjoying all this entails - putrid smelling trucks hauling shit up and down their streets, farms laden with shit, shit absorbed into the ground and running off into streams. Shit dust and odors wafting over hill and dale.
Economics do not add up unless Synagro is using a lot of natural gas
One debunked purported selling point of this shit was that this is a "green"project, using waste energy to recycle shit and everyone wins. The "Slate Belt Heat Recovery Center" - bwa ha ha. Does it seem logical that $274 of worth of waste energy can bake 400 tons of shit in a day? As Home Depot advertising would say, "This is only $0.69 per ton!" As will be shown in a separate post, if the Synagro plant were running on 100% natural gas, Synagro would pay about $8000 per day for the fuel to bake wet cake with an 18% solids concentration , or $20 per ton (assuming a cost of $8 per 1000 cu ft - scale accordingly). Synagro project manager Jim Hecht stated that this plant can run profitably on 100% natural gas. Shit haulers are paid roughly $100 to $200+ per ton of wet crap hauled from a waste water treatment plant, depending on the distance hauled, so $20 in fuel costs to bake it is not prohibitive.
Conclusion - Green Knight is either supplying a tiny fraction of the total energy being used daily, or Green Knight (and the communities hosting this project through Green Knight's involvement) will be getting ripped off big time. More "good economic development" in the name of supposed "green energy" according to very fuzzy logic.
Green Knight extended lease contract 20 years coincident with agreeing to partner with Synagro
The Green Knight Energy Center opened in 1999, and had a 20 year lease agreement with land owner Waste Management. The landfill was expected to fill far sooner prior to latest landfill expansion and the 2008 recession. At the current rate, it is estimated to fill several years later, in about 2030+/-. The initial lease should expire next year.
In February 2017, Green Knight president Carlton Snyder stated that "We looked at contractual obligations when agreeing to partner with Synagro." Not what is best to do for the community by this non-profit, but "contractual obligations". Now it is reported that Green Knights have extended their lease 20 years. That statement likely means that Waste Management either encouraged or required Green Knight to agree to work with Synagro in order to get its lease extended. But would Waste Management really have not extended Green Knight's lease and shut down the energy center? That would be horrible public relations.
Green Knight and Waste Management's concept of economic development is warped
The Grand Central landfill is a nuisance business - landfills always are. So is a biosolids plant. Nobody wants one in their community, which is why Synagro has desperately tried for 2 years to get its plant approved in Plainfield Township - this location is ideal to provide a gateway for redistributing CT, NY and NJ's shit across eastern PA. Inviting a shit bakery to town is the polar opposite of economic development. A handful of crappy jobs that are worse than virtually any other job you can name, the contamination of high quality streams and an aquifer at the proposed site, the contamination of the earth and stormwater where the product is applied to fields, and a minuscule $33,333 per year for each town to use for expenses or a fraction of the costs including benefits to provide a single decent job.
Not all development is good development. Making the Slate Belt a less attractive place to live and do business is not economic development - it is tossing prospects for a better future away for the sake of Waste Management and Synagro making a shitload of money, and for Green Knight to continue so-called "economic development" in the self-serving manner the puppeteers at Waste Management envision it. This is economic suicide, and Class A bullshit.
Your appearance goes to shit over time, but your community shouldn't also Green Knights' vision is to literally develop the Slate Belt into Shitsville
In 2006, a French documentary film directed by Mario Desmarais was released titled Tabou(e)!
It was first re-released with English subtitles, and then again in English under the title Sludge Diet.
The clip begins with environment scientist Dr. Caroline Snyder relating her awakening to a deadly serious topic in the late 1990's. She has become a resource for activists and those fighting sludge in their communities. Here is a page that discusses her work:
Please click headshot to see the article on Dr. Caroline Snyder
Unfortunately, the entire film (which is excellent) does not appear to be available for free.
The next planning commission review of Synagro's proposed crap factory is tonight at 7pm at the Plainfield Township Volunteer Fire Company 6480 Sullivan Trail in Wind Gap.
There are two permit applications the PA DEP is accepting comments/complaints on, associated with the Synagro crap bakery planned for Plainfield Township, Northampton County PA.
NPDES Draft Permit (stormwater specific) Public hearing November 7, 2018
General Permit application (general, including wastewater, air) Comments/complaints due by Oct 17, 2018
This is a bit confusing, but here are the details. The General Permit application is not yet what is called a "draft permit," but the NPDES permit is a draft permit. Once a permit is a draft permit, a local public hearing may be scheduled, if the DEP determines it is warranted based on municipality concerns.
The NPDES Permitapplication went straight to draft permit status (Draft Permit No. PA0276120), since it is much smaller than the General Permit. This allowed the local pubic hearing to be scheduled for November 7. The announcement of the hearing is at the end of the document located at this link
DEP will give speaking priority to those who register prior to the hearing date by submitting their name via email to Colleen Connolly at coconnolly@pa.gov
This author suggests you put "Registration for hearing onPA0276120" in the subject line.
"Walk-in" members of the public can sign up to speak at the hearing if time is available.
DEP will require that your comments to be made orally be submitted in writing, which may be done at the hearing. (Therefore you need not submit your comments via email, and it is unknown at this point if they would be accepted if you do).
Speakers are limited to 2 questions and a total of 5 minutes. This may mean two questions and/or unlimited comments for up to 5 minutes.
Additional written comments are typically accepted by DEP up to a few weeks following the hearing - the closing date has not yet been published.
Note that an NPDES permit is specific to stormwater, so complaints about air quality (for example) are not best made here - they may be ignored. Feel free to vent if it floats your boat though ;)
If you are concerned about runoff from the site into the Little Bushkill or Waltz Creek or Sedimentation Basin #2 (freshwater pond) from the various possible sources (accidents, trucks tracking shit across the parking lot, etc) then this hearing is for you. Synagro and its engineer EarthRes claim this shit factory will be magically insulated from these water bodies by "vegetative buffers" and anyone with half a brain knows that is bull shit. Of course when the General Permit public hearing occurs, general comments about all kinds of shit will be appropriate.
DEP Hearing for Synagro NPDES (stormwater) Permit
November 7, 2018
6pm to 9:30pm
Wind Gap Middle School
1620 Teels Road Wind Gap PA
The General Permitapplication (Permit Application No. WMGR160)will go through a more lengthy process initially, and then track like the process above for the NPDES draft permit. At the moment the permit application is considered "administratively complete." Next, DEP will accept written "technical deficiency" complaints from anyone until October 17, 2018. Then it will process the complaints, and request Synagro to update its application to address concerns that the DEP agrees need more detail, etc. Once Synagro submits satisfactory updates, DEP will change the General Permit status to a draft permit. At this point, a public hearing will be scheduled as in the case of the NPDES permit. The DEP announcement for the public "technical deficiency" comment period for this permit is on page 17 of the document at this link
Hard copy complaints may be mailed to Chris Solloway, Group Manager, Division of
Municipal and Residual Waste, Bureau of Waste Management,
P.O. Box 69170, Harrisburg, PA 17106-9170 by October 17.
Complaints may be submitted via email to ra-epbenuseall@pa.gov by October 17.
Put "Comments on WMGR160NE001" in the subject line of the email
This permit is for the entire facility, so any concerns (wastewater, air quality, odors, etc) may be brought up (though stormwater is most appropriate for the NPDES hearing).
Complaints may be truly "technical" - addressing specific deficiencies contained in the Application, or more general in nature or in between.
At this point there is no way of knowing when a public hearing on the General Permit will be held, but it is safe to assume there will be one.
This is your chance to speak up! The Delaware Riverkeeper has a form and sample comment letter for the General Permit application comments due October 17. This allows you to submit a complaint using a "fill in the blanks" approach, and not concern yourself with attaching an email and using an email program. The DEP instructions state that your complaint may make a recommendation that:
The application be revised.
The application be approved.
The application be rejected. DING! DING! DING! We have a winner!!!
The Riverkeeper reports that it is preparing a similar form for signing up for the NPDES Permit November 7 hearing. A link will be provided here when that is available.
Note:There are other permit applications for this project. If in the next week, an additional permit (eg Air) reaches draft status, it could be added to the November 7 hearing so as not to have to schedule an additional hearing.
As reported here, Roger Bellas within the Solid Waste division of the PA Department of Environmental Protection issued a determination on August 10, 2018 that former Doney Quarry #2 would continue to enjoy a waiver of a permit that would be otherwise be required under an exception located in PA Chapter 105.12(a)(6). The departments of Solid Waste and Mining back around 2008 approved this water body to be considered a "sedimentation basin", shortly after the quarry ceased all operations.
It may have not been a big deal at the time, because "all" that was proposed would be to continue to handle some stormwater from the Green Knight Energy Center, and some runoff from the landfill.
The problem is, there is no evidence that the former quarry was in fact engineered or designed as a sedimentation basin. Thomas Pullar of EarthRes, Synagro's engineer, claims that it was in a June 26, 2018 email to Mr. Bellas. Mr. Bellas dutifully parroted this back in his August 10 determination letter. But the documentation that Synagro has submitted does not support the claim.
A sedimentaion basin slowly filters water before it is released. The sediment is periodically removed. There is no such activity known to occur in Doney Quarry #2 - it is a pond connected to an aquifer. The exchange takes place immediately. No one is running out and removing sediment. A sedimentation basin has a spillway so that when it releases water to the surface it is controlled. Doney Quarry #2 had a spillway planned, but it was never built because the quarry connects with an aquifer and will likely never overflow unless a 500 year storm strikes. It simply isn't a sedimentation basin.
Synagro's runoff - we all live downstream
Furthermore, the proposed Synagro plant is located 5 to 10 feet from the edge of the former quarry, according to statements made by EarthRes engineer David Allen, P.E. at the September 6, 2018 Synagro Land Development Review before the township planning commission. Despite claims by Synagro that "no Industrial Activity poses a risk to the pond," and "the only drainage to the pond is sheet flow from a parking area," Synagro's plan shows the exact opposite - the parking area in question is downgrade of the driveway adjacent to the building, which is downgrade of the silos of finished shit, and the truck wash and delivery of shit areas. "Sheet flow" is when water flows across a surface in a thin layer as opposed to more concentrated flow in a pipe or creek, for example. What Synagro describes as "sheet flow" will actually be "shitflow". You just could not make this shit up.
The township's position will be, maybe you approved this activity in 2008, but you can't extend it to the proposed change. Now there will be heaping piles of shit and shit runoff located literally within the boundary of the existing quarry. Not stormwater, not water flowing over the top of a landscaped landfill. Actually, if you read the appeal (below), the township is arguing that DEP screwed the pooch big time back in 2008.
DEP does excel at something
What is needed is for the Wetlands and Water departments at DEP to make the current determination, not Solid Waste and Mining.
Plainfield Township appeals August 10, 2018 DEP determination
First strike launched by Plainfield Township in battle over baked crap factory
On September 11, 2018 Plainfield Township filed an appeal of Mr. Bellas' decision to the PA Environmental Hearing Board. This is huge. The EHB is a court that hears appeals of matters that involve the DEP, instead of the Commonweath Court. The EHB is very powerful - including the ability to effectively change law when necessary (not likely here). The outcome of this is significant, because if the township prevails the pond and surrounding areas would be protected, as well as the township being better able to enforce its riparian and open space requirements. As it stands, DEP has essentially given Synagro the green light to do whatever the hell it pleases right on top of clean water. The docket at the EHB is located at this link. Here is the notice of appeal - the grounds are on the last few pages and the appeal can be amended within 20 days:
DEP apparently can't discern it's ass from a hole in the ground
