Wednesday, November 7, 2018

Synagro Air Quality permit application for Plainfield Township plant shows facility will exceed proposed regulatory standards and incorrectly claims it is a Single Source

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.

Tuesday, November 6, 2018

DEP plans to cram through four permits for proposed Synagro crap bakery in a 3-1/2 hour hearing, yet only two permits currently exist

DEP is an acronym for the Pennsylvania Department of Environmental Protection, but what it really means is:

DON'T EXPECT PROTECTION

This sounds a bit harsh, so let's look at recent local evidence that support this statement.
  1. 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. 
  2. 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.
  3. 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

Sunday, November 4, 2018

Waste Management stands to earn $$$ millions per year from proposed Synagro crap bakery in Plainfield Township, while citizens' quality of life and property values are reduced

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

Sunday, October 14, 2018

Synagro use of "waste energy" in Plainfield Township will deliver only $100k per year of potential revenue to local communities, and 100 tons of shit per day to farmland in eastern PA

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

Monday, October 8, 2018

Sludge application to agricultural crops does have negative effects on people - if you consider dying negative. Preview of "Sludge Diet (Tabou(e)!)"

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.


Wednesday, October 3, 2018

DEP now receiving public comments for two different permit applications related to Synagro biosolids plant in Plainfield Township - public hearing in Wind Gap scheduled

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 Permit application 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 on PA0276120" 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 Permit application (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:
  1. The application be revised.
  2. The application be approved.
  3. 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.

Thursday, September 13, 2018

Plainfield Township files state court appeal of DEP decision in regards to proposed Synagro biosolids plant on Waste Management land

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 "shit flow".  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:


Appeal by Plainfield Township of DEP determination freshwater pond can be filled 
with sediment and other shit


Here is a link to the Appeal PDF at the Environmental Hearing Board, that you may download or print: APPEAL


Thursday, September 6, 2018

PA DEP takes cover in extending waiver granted in 2008 to Waste Management to Synagro at planned biosolids site - Plainfield Township pushes back

A few years after the Green Knight Energy Center was built, the PA Department of Environmental Protection (a misnomer) approved the partial filling of the former Doney Quarry #2 near the energy center.  This quarry was originally a few hundred feet deep, and is connected to a ground water aquifer.  Within a few hundred feet are the Waltz Creek and the headwaters of the Little Bushkill Creek.

In issuing this approval in 2008, DEP granted a waiver of permit requirements under Chapter 105.12(a)(6) - which addresses obstructing stormwater facilities and sedimentation basins that meet the requirements of Chapter 102.  Now, DEP is planning to extend the same waiver for Synagro to allow it to further fill the basin in order to create space for a parking lot and maneuvering area, under the guise of "we did it before."  Here is a letter sent from Roger Bellas of the DEP to Synagro/Waste Management on this subject:


Note that attached to the Bellas letter is an email in which Synagro engineer EarthRes mentions open space requirements as well as refers to the water body as a basin that was originally "engineered".  Synagro is attempting to argue the basin is just a stormwater feature and that (local) open space requirements do not apply.  In response, Bellas's letter parrots that "engineering" was done back in 2008, and as a result again the basin will be exempt a permit under Chapter 105.12(a)(6).  What if Bellas is taking the Applicant word for it here?  The DEP is overworked and understaffed - could Bellas have drafted this letter, signed off, and headed out for a two hour lunch?  But DEP does find that the basin a "regulated water body" (not just a detention basin, which would not be regulated) and states that Chapter 105 otherwise applies.  DEP is not in a position to preempt Plainfield Township's buffer requirements adjacent to ponds, which is what the former quarry now is.

Plainfield Township is requiring a zoning variance, since there is a 50' setback requirement from water bodies.  But Plainfield Township is further concerned about the fact that the pond is connected to the aquifer, and that there may be other considerations (wetlands, etc) that should be taken into consideration in determining if a DEP permit should in fact be required under Chapter 105.  The township's wetlands consultant issued a report found at the bottom of this blog post.  Here is a letter sent by the township to Mr. Bellas at DEP following his communication to Synagro/Waste Management, which does not mention the consultant's report but incorporates its findings:


The township is essentially challenging the DEP's voracity in its determination that the proposed activities are exempt from a permit, and that "engineering" was done in 2008.  Is this based on EarthRes' claim in its letter that engineering was done?  What if DEP just granted the waiver in 2008, without doing its homework?  This would not be unheard of, and DEP has made other errors in allowing quarries to be filled.

Notable errors PA DEP has made in permitting filling of other quarries local to Synagro site
In 2011, the DEP issued a permit that allowed a quarry near Nestle Deer Park's wells in Washington Township, Northampton County to be filled, and this process contaminated the water drawn from Nestle's wells.  DEP then withdrew said permit.  To this day, Nestle operates an "interceptor well" that diverts water from the aquifer flowing from this quarry towards Nestle's production wells.  Here is the DRBC approval for the interceptor well (see underlined text on page 3):


In about 2000, DEP approved the Buzzi Unicem quarry to be mined to an additional 50' of depth.  Within a few years, sinkholes began developing along the Bushkill Creek.  A few houses were swallowed/destroyed, as well as the bridge connecting Stockertown and Tatamy, which will not be replaced - partly because no one has a clue how to do it with Swiss Cheese for ground.  Sinkholes have spread as far as 2 miles downstream.  Two bridges on Route 33 over the creek were replaced at a cost of millions of dollars, and at least one of the "new" bridges is sinking and will need to be replaced.  Yeah - DEP is on top of it, and we're all underneath getting pounded.

The basis for what the township is requesting of DEP
The township references a section of Chapter 105.12(a) that provides for permits to be required in cases where threats to life, health, property or the environment are present, even though a project may be eligible for a waiver.  This request may result in DEP agreeing a jurisdictional determination is required, starting the ball rolling to real evaluations of the pond, its surrounding area, and interaction with the aquifer.

What could happen if DEP simply ignores Plainfield's request, and follows through in not requiring a permit under Chapter 105, and a permit is issued by DEP for the landfill modification that adds Synagro's use?   Plainfield and/or the Delaware Riverkeeper could appeal that issuance to the PA Environmental Hearing Board, if they believe the DEP's decisions are not based on sound analysis.

The swords are out.  DEP is taking the side of big money.  There will be a public hearing held locally by DEP, to allow citizens to give their input on this project.  This should occur within the next few months.  If DEP has not altered its position on this issue prior to the hearing, citizens need to add their voices to that of the township.  Protect our water.  You know, you are responsible for environmental protection.  Duh!

Monday, September 3, 2018

How Synagro's proposed biosolids crap bakery in Plainfield Township could more than double in size overnight

Synagro is having fits trying to wedge itself into a postage-stamp sized piece of property in Plainfield Township, Northampton County PA.  It proposes to process 400 tons of shit a day, within about 20 feet of a deep pond that is connected to a ground aquifer.  Also within a few hundred feet of the site are two high quality creeks, the Little Bushkill and Waltz.

As bad as this sounds, it is the flurry before the real shit storm strikes - the knockout blow.  When the landfill closes, within a few years the landfill gas coming from the landfill will no longer be sufficient to operate the Green Knight Energy Center.  At that time, the energy center can be torn down, creating more room to store and process shit.

In the "Lease Plan" (below), Synagro will use 7.8 acres, the energy center 3.2 acres and common areas between them 1.05 acres.  That is just over 12 acres.  12.05 to be exact.

Future expansion possibilities

As Synagro project manager James Hecht has admitted and Green Knight board member Steven Hurni has stated, Synagro does not need the energy center's waste energy - which will no longer be available in about 11 years.  The "green" aspect of this proposal has been soundly debunked.  The real green is decades of income off shit, perhaps a century of shit.  Plainfield Township, Wind Gap and Pen Argyl will become the tri-shitty capital of northeastern PA.

Plainfield Township's zoning ordinance requires 3 acres to run a shit factory up to 300 tons capacity a year, and 2 acres for each additional 100 tons.  A little math shows that a 12 acre site will allow up to 850 tons a day to be processed.  1.7 million pounds of shit a day.

 What could possibly be worse than this?


¡Ay, caramba!

If they can't get approval for the current application because the limited space and proximity to the pond suck ass, Synagro and Waste Management may become desperate and plow down the energy center now.  Public relations wise, not the best move, but Waste Management and Synagro each have a history of giving a flying frig about public relations.  What would the community lose?  One job at the most at the energy center, and Green Knights is doing virtually nothing for the "poor and distressed local citizens" as it is - they aren't fulfilling their mission.  A few contractors who are on Green Knights will lose potential business, but casualties are to be expected and Waste Management will likely not hesitate to toss the Green Knights under the bus.  Most people see the Green Knights as just a department under Waste Management anyway.

Clearly, worst case is when the landfill closes, Waste Management truck traffic will shift from hauling garbage to hauling more shit.  The writing is on the wall.

Enjoy your Labor Day ;)

Sunday, September 2, 2018

Green Knight Economic Development Corporation member observes "Synagro Slate Belt Heat Recovery Center doesn't need our waste heat"

The Green Knight Energy Center (GKEC) on Waste Management property in Plainfield Township burns landfill gas captured from the landfill, and sells electricity to the electric company.  To do this, the non-profit Green Knight Economic Development Corporation (GKEDC) had to be created, and ostensibly its mission is to:
"provide economic relief for poor and distressed local citizens"
The GKEDC has strayed from its mission, as we have seen.  Today, the emphasis appears to be on developing projects that some GKEDC board members can benefit from financially, and benefiting the poor and distressed local citizens is playing a distant secondary priority.

Enter the deceptively and poorly titled Slate Belt Heat Recovery Center.  As Synagro and Waste Management's yarn goes, the waste heat from GKEC "which was always planned to be used" will be used to dry shit in the Synagro baked goods plant, and this is great for the environment.  The truth is it was never planned to erect a crap bakery employing 12 people right next to the energy center - the original concept of nearby businesses using the waste heat on three lots supplying good jobs along Route 512 was destined for rapid failure and has been replaced by Waste Management's goal to make its landfill profitable for several decades after it closes, and GKEDC is playing along with the ruse.  Waste energy is not what will be used to fuel the ovens churning out dried shit 24 hours a day, and both Synagro and Waste Management know it.  So does at least one Green Knight member.
Synagro public relations depiction makes processing shit look playful,
like making sand castles at the shore

Synagro paid some firm to make cute graphics with trucks chock full of shit trundling over the countryside, delivering poop to the bakery, and trucks chock full of shit departing for fields lined with fluffy trees.  The truth is, the trucks of shit aren't coming in from local suppliers - rather they are coming off concrete and asphalt highways of hell from Connecticut, New York, and New Jersey, offloading crap here that those states don't want.  The same arteries delivering countless loads of toxic fill from the same states to fill quarries near your home and mine.  We'll take a look at DEP's role in the next installment.  Don't expect much from those useless assholes.  Deep pockets are the ticket to success with the DEP.

Trucks heading out will be delivering their precious cargo to local communities that don't want any part of biosolids application.  Yes, a shitstorm may be headed to your town in Schuylkill County, Carbon County, Monroe County, Lehigh County, Northampton, and points outward.  Ever seen Invasion of the Body Snatchers?

"I feel a powerful force in my ass, and it's the good stuff"

Following the July Plainfield Township Planning Commission review of Synagro's land development plan, Plainfield Township supervisor and GKEDC member Steven Hurni was chatting with another township supervisor and a resident, and this blogger has confirmed that he made the following observations:
  • Synagro doesn't need our waste heat at all
  • The waste heat is being used as an excuse
  • They are spending a heck of a lot of money sending lawyers and consultants to these meetings - they want this very badly
Mr. Hurni has seen the light - will it spread to the rest of the Green Knights?

Mr. Hurni is an intelligent man, and he has been seen regularly at the continuum of Synagro site plan and land development reviews.  He was in attendance at the previous meeting in May, when Synagro project manager Jim Hecht acknowledged that Synagro could operate its plant profitably on natural gas alone - which is available at the site.  This was the meeting at which Lisa Perin, a relative of the creator of the landfill, stated that once Synagro is "in" they will never leave.  That after the landfill closes, "they will find another source of energy."  What Ms. Perin did not realize is that source is there today - natural gas, and it is the only reason Synagro is obsessed with this site.  At this same meeting, Synagro saleswoman and airhead Pam Racey bragged about her 30 years of experience, and proceeded to make multiple misstatements of fact.  One of them was that this is a "green project that is good for the environment".  The only green stands to be in your company's coffers, Pam.  It's shit brown for the Slate Belt and beyond.  The "distressed" citizens Green Knight purports to assist will be even more distressed.  Perhaps Mr. Hurni was previously blinded by the state of euphoric crapulence that seems to have overcome the rest of the members of Green Knights - but his eyes have been opened.

Synagro has stated it will be capable of running on multiple sources of energy - waste energy, landfill gas, and natural gas.  Landfill gas is only about 50% methane - this is another ruse.  Why use crappy sources of energy when you can run more efficiently and profitably off of the good stuff - natural gas?  

Mr. Hurni is on the scent, and it appears he is realizing something smells odd and it isn't shit.  Synagro, Waste Management and Green Knights have all participated in trying to pull the wool over the Slate Belt's eyes.  Synagro has not acted in good faith - it is wasting tens of thousands of taxpayer dollars on an application that it has known for a year requires zoning variances.  Any other company would apply for the variances.  Not Synagro - it is applying for PA DEP permits, paying a stenographer to record all planning commission meetings, running a full court press visiting towns singing the praises of shit to anyone who will listen.  Meanwhile, its engineer is acting like everything is in order, when he knows it isn't.  He admitted on May 31, 2018 that Synagro is developing inside the boundary of the pond on site, yet in August 2018 he filed a report stating that Synagro is maintaining at least a 50' setback from the existing pond in a "compliance"report.  You just could not make this shit up.

Friday, August 31, 2018

Gross misrepresentation of fact and and deceit in latest Synagro land development update for crap bakery in Plainfield Township

On August 15, 2018, EarthRes engineer David Allen, P.E. submitted an update to Synagro/Waste Management’s application to site a biosolids processing plant in Plainfield Township.  This was the deadline for new materials to be reviewed at the September 6, 2018 Planning Commission review - they slipped this baby in the door at the last moment the way all Applicants do who don’t want a municipality to find the deficiencies in their application. And that is the case here, as we shall see.  "P.E." stands for professional engineer, but as we will also see, it could also stand for "professional evader".

Holy shit Batman, that must be awesome because it's so big - Powww!!!

Just look at the girth - an inexperienced 19 year old lass might blush, and any man would be happy to have a package the length of the thickness of this one.  No expense is being spared in an attempt to shove this pile of shit through approval.

The cover sheet shows what the package contents are, but we will focus on materials related to the two zoning variances that Synagro’s plant requires - which Synagro has been trying for over a year to avoid discussing or admitting.  The first is an open space buffer adjacent to water bodies, and the second is separate entrances and exits at least 30’ wide are required specifically for crap bakeries.  As we shall see, they expelled some foul odorous flak out their ass in the latest attempt to distract from the reality these variances are indeed needed.  There is a reason for this - they can not prove the hardships needed for the variances to be granted.  They are playing a very expensive game of charades, waiting until their plan is shit-canned by the Planning Commission and then the end game of this C-grade movie plays out.

A one inch thick packet in the package is the “Project Performance Review and Compliance Report,” which is laughable.  Their performance sucks, and they don’t comply with the ordinance.  But let’s continue because they are paying their dime for this round of hilarity.

Variance #1 - Sec 27-505 50’ Open Space Buffer adjacent to Water Bodies
The EarthRes Project and Performance Review and Compliance report contains no narrative, only references to sections of the Ordinance, and claims that each requirement is met.  That’s bullshit, but without further ado, here is what is stated in regards to the open space buffer:

Gross misstatement of fact that appears intentional - the exact opposite of this statement is true - less than 0' of open space from the existing sediment basin is proposed and 50' is required

A buffer is needed near “Waterbeds”?  Exposure to sex acts, being pasted with potentially dangerous bodily fluids in the heat of passion?  Come on, David Allen, P. the fucking E. - pull Ye head out of Ye ass.  EarthRes represents the scum of the Earth -engineering the most environmentally destructive projects known to mankind.  David we can barely see you - if you can rise above the surface of the cesspool, maybe one day you can work for a company that isn’t EarthRes.

Let’s give David Allen P.E. the benefit of the doubt and assume he isn’t trying to hide one intentional error by introducing a second one.  Section 505 pertains to water bodies - and he states that the existing sediment basin complies with the 50’ requirement.  Did time and gravity somehow reverse themselves?  Let’s go to the videotape, a site plan updated August 14, 2018 contained in the package received on August 15, 2018:

What the revised plans actually show is a bunch of parking and a driveway in sediment pond #2, and a shit factory less than 25' away.  We see what you did there.
Note that the black dashed line "Proposed Pond Boundary" is obscured.  Now it is a pond?  David!

The parking places are forty-five feet into the existing sedimentation basin, and the proposed plant is a shade under 25’ from the existing basin.  Hello?  David?  We can see your leg and foot hanging out your ass, but where is the rest of you?  That looks REALLY uncomfortable!  How exactly does the existing sediment basin have a 50’ buffer around it, where there is no development?  Uh-oh.  David will have splain’n to do at the meeting on September 6, 2018.  Bring some Handi-Wipes, it will be ugly - in the seat of David’s pants.  It would be pleasantly surprising if just once a representative of EarthRes did something respectable.

The plan above is not stamped by David, so who knows if it is official or some draft he just tossed in.  No problem, because there is another sheet in the plans submitted on August 15 that does have his stamp, and it shows outright deceit on this subject:
Sheet C-03 of the Site Plan, which depicts the portion of Existing Sediment Basin #2 only where it isn't damaging to Synagro's plan.  The existing portion above the blue dashed "Proposed Sediment Basin" line is not shown.  What the hell is your definition of "existing," David Allen P.E.?

Variance #2 Sec 27-316 (2)(II).2  At least 30’ wide dedicated entrance and exits required, along an arterial or collector
At the Juy 16 lPlanning Commission, Synagro did a presentation that introduced the bold idea of adding an entrance and exit to Pen Argyl Road.  Aside from the fact it went over with the audience like the slip of a scalpel at a bris, David Allen P.E. seemed at a loss for words when asked how this new access would actually function.  All flash, no explosion.  More putrid flak - sure to impress the Express Times reporter Synagro invited to the meeting, but no one else.  “Synagro announces mesmerizing bull shit” was the headline the next day.  

In an examination of the August 15 super terrific Land Development Plan update, it is clear that the bold announcement and pretty slides at the July meeting portended a great big fat zero.  Bunkus.  Again, there is no narrative, but there is a Traffic Study and there are Truck Turn exhibits.  The Traffic Study indicates that the new access point to Pen Argyl Road that David Allen, P.E. unveiled in June should be gated and used only for emergencies.  You just could not make this shit up.  Where is the Express Times reporter now?  Writing a story about the next meeting about shit?  Come listen to more shit from David Allen P.E. on Thursday, September 6 - you won’t be disappointed!

I'll take Potpourri for $100, Alex

It's the Video Daily Double!

The truck turn exhibits show a bevy of activity at the western access point - in both directions.  Recall that separate entrances and exits are required, for safe and orderly flow.  This ain’t that.  The updated truck turn exhibits don’t represent any improvement in clarifying the intended operation, nor do they reflect separate entrances and exits to an arterial or collector.  FAIL.  The variance is still required.  Also, the Plainfield Township Recreational Trail would still be used by Synagro for decades - which is not the agreement that Waste Management made with Plainfield Township - the township is to get it back when the landfill closes.  Not 50 years from now.

Here is Synagro's real truck movement plan - whatever is necessary to get that truck full of crap on or off the property:

Why Synagro will not be able to obtain the variances needed

Briefly, in PA, there are 5 criteria to be proven to obtain a variance.  One is that your property can’t be used for a lawful use.  One is there are unique circumstances about your property - shape, slope, that make it so you can’t develop the lot.  But the uniqueness can’t be that you developed your lot without the future in mind, and now you’re screwed yourself.  The property is already being used profitably - to the tune of many millions of dollars a year.  There is nothing unique about the property except it is a garbage dump with little room left.  Tough shit - you built it.  This is fun - let's look at one more variance criteria - health, safety and welfare of the public can't be put at risk.  Yeah David, about that pond...

Thursday, August 9, 2018

Synagro refuses to do Environmental Study and has not studied water flow interchanges with aquifer below pond located 20 feet from proposed sludge plant

Synagro first proposed that it locate its crap processing plant near a large deep pond (Former Doney Quarry) in May of 2017.  As reviews progressed, it became apparent that Synagro would likely not be allowed to dump its 300 tons of wastewater per day into the nearby high quality Little Bushkill and Waltz Creeks.

Below: Plainfield Township Wetlands Consultant publishes review of proposed site, including the pond located near the plant and proposal to have a parking lot built in it.

In February 2018, suddenly Synagro announced now it would “backhaul” its wastewater to the source of the incoming sludge - to the amazement of listeners.  Purportedly this was in response to concerns by citizens - in fact they probably figured out they would never obtain DEP approval to discharge into the creek(s).  That line of shit about respecting concerns smells a mile away, and the trucks they propose be used to haul both crap and wastewater do not even exist.  And will these hypothetical trucks actually go back to where they came from in NY, NJ and CT to dump the wastewater?   It turns out that the answer may be “no”.  At the July planning commission review, Delaware Riverkeeper Deputy Director Tracy Carluccio informed the commission that she had informed Synagro VP of Project Development Pam Racey offline after the May 31 review meeting that the State of NY may not permit the backhauling of wastewater.

Ms. Racey was also corrected during the May 31 review by Ms. Carluccio - after Ms. Racey stated that if backhauled wastewater were refused by a facility, it would be taken to a facility in NJ.   “They take anything,” she said.  Ms. Carluccio pointed out that the facility Ms. Racey mentioned stopped accepting such materials over a year earlier.  Ms. Racey has 25 years experience and a BS degree in agriculture - she is a champion bull shitter.  Synagro’s “plan” appears to be “say whatever sounds good until someone challenges it.”  The operating hours are changing now that the public has questionedextended operating hours that were recently revealed that are beyond what was stated in a memo to the planning commission from Synagro project manager Jim Hecht in December of 2017.  Hecht’s comment on May 31, 2018 was “we’re trying to cut back the Saturday hours.”  Hecht appears to have gotten the same BS degree as Racey. The truth is, they have no idea how to make this operation work and are making everything up as they go.  For God's sake, they are building it in a pond.

The latest and more critical story that is changing has to do with the former Doney Quarry (aka Sediment Basin #2) - located only 20’ from the proposed plant, and proposed to have sludge-hauling trucks travelling through it.  A truck wash area, to rinse the shit off at the unloading station, is perhaps 50’ from the basin.


Sediment Basin #2 (a pond), proposed to be partially filled and to host 20 parking spaces

The "basin" to Synagro is a pond to everyone else
Over the past four months, more attention by the planning commission has been placed on the potential pollution of groundwater.  It took this long to get to the engineering and zoning reviews of Synagro’s plan.  Until the last review meeting, Synagro maintained steadfastly that the basin is a “stormwater facility, not a pond.”  It is important to note that the engineer for Synagro at a November 2017 review meeting agreed that the basin is connected to an aquifer.  The basin holds water permanently and has no outflow, and is connected to an aquifer, therefore by common definition it is a pond.

At the July 2018 Synagro review, Synagro finally agreed that in fact the basin is a “regulated water body” or waters of the Commonwealth according to DEP.  However, on questioning, Synagro’s engineer stated that Synagro has not studied groundwater flow in the pond   When asked if Synagro would do an Environmental Impact Study, Synagro representative Jim Hecht flatly and dully answered “No.”  This is the same Jim Hecht who has visited several municipal meetings in the past few months, spreading his PR line of bullshit to board and council members that this stuff is perfectly safe.  Prove to us it will be safe and not harm our environment, because we don’t believe you, Jim.

Plainfield Township Wetlands Consultant Publishes Review of Sediment Basin #2 (pond) and other water features on the site

Since Synagro has been poo-pooing, pun intended, the significance of the pond, Plainfield Township has contracted its engineer to issue a report on waters on the site.  It is below.  Key findings in the report are:

  • The pond is a state regulated water body, and contains Waters of the Commonwealth (this means that the Zoning Variance for 50’ of open space adjacent to a pond is in fact required)
  • The pond may qualify as Waters of the United States, and have to comply with federal regulations
  • Recommends that a hydrogeological study be performed to understand the flow of water into and out of the pond
  • The pond is regulated by the township’s ordinances since it is a pond
  • The pond is subject to the riparian buffer requirements of the ordinance
  • A delineation of all wetlands and water bodies on the site is required
  • The township may require a certification by the Army Corps of Engineers of the wetland and waters delineation
  • The plan is not in conformance with township riparian buffer requirements
  • Suggests that Plainfield Township request that the DEP require a full permit for partially filling the sediment pond, despite Synagro’s claims that it is exempt under PA Chapter 105.12(a)(6).
  • The proposed plans do not address required stormwater best management practices to protect the pond (not a detention basin) and downstream waterways.