Wednesday Nov 21st is deadline to submit public comments to DEP on four permit applications for Synagro biosolids plant

Wednesday at 4:30pm is the deadline to submit public comments to DEP on four different permits or permit applications associated with the Synagro crap factory proposed on Waste Management's Grand Central landfill in Plainfield Township, Northampton County PA.

DEP requires that you send a letter/email on each of the four permits/permit applications individually, and put the number associated in the subject line of your email (or letter):

1. WMGR160N001  General Waste Management permit application for the Synagro facility
2. 100265-A181        Waste Management permit modification of Grand Central's existing permit
3. PA#0276120         Individual NPDES Stormwater Discharge Draft Permit for the Synagro facility
4. 48-00111A            Individual Air Quality permit application for the Synagro facility

#2 is a permit modification that addresses things such as Synagro's use of the haul road currently used for garbage trucks and the use of Sedimentation Basin #2, or the former quarry, which is located five feet (5') from the proposed facility.  It is currently used for runoff from the landfill and stormwater from the Green Knight Energy Center.  This water body (pond) is connected to a ground water aquifer that connects to at least one high quality creek (Little Bushkill), yet no one - not the DEP, not Synagro, not Grand Central has any clue what is happening below its surface.  There has been no hydrogeological study done on this water body, and DEP is on the verge of allowing it to be partially filled for Synagro, and allowing intense biosolids transportation, handling, storage and processing be conducted virtually IN the current boundary of the pond.  What could possibly go wrong?  A DEP waste management representative named Roger Bellas made a determination that would exempt Synagro from a Waterways Clean Water permit that would otherwise be required - which decreases to near zero the chance your water will be protected.  Strike 1

#1 is the general permit application for the Synagro plant, and it literally is a "general" permit where DEP would normally issue an individual permit for such a facility.  Because it is a general permit, if issued it will make it easier for DEP to grant permits (to its buddy Synagro for example) for similar facilities to this one in the future, elsewhere in Pennsylvania.  In other words, DEP sees this as a flagship model to pave the way to spread similar landfill-waste heat-crap bakery installations across the state.   A consequence of the fact DEP instructed Synagro to apply for a general permit is the harms/benefit analysis that is required on Form D of an individual permit application is not required!  Yes folks, the Department of Environmental Protection is orchestrating this application in yet one more way that prevent impacts to your environment from being assessed prior to issuance of permits and after they are issued.  The first notice of a problem will be after the air or water has been contaminated.  Strike 2   (DEP representatives confirmed what is stated here at the November 7 hearing in Wind Gap)

#3 is the stormwater discharge draft permit for the facility - kind of a subset of the facility permit that is focused on stormwater discharge.  Comments about stormwater are best filed under this number, though #1 is for the facility and you can make comments under that number as well.  Where to begin?  The sheer number of ways the water in Sedimentation Basin #2 can be contaminated is daunting.  At the November 7 hearing, Synagro's environmental engineer Pullar stated "at least that is the hope" after stating that a vegetated buffer between all the sources and the pond will "filter any contamination".   Um, what the fuck?  This isn't a strike against DEP, but against Synagro unless DEP makes them provide far better protection (eg: move the plant 100' or more from the pond).

This is the best permit number to make a comment that not requiring a Waterways Clean Water permit is not acceptable.  To learn more about what can happen when a quarry is filled with just clean fill, see the recent recommendations that Nestle Waters hydrogeologist Eric Andreus made to DEP for future precautions to take, in regards to contamination of Nestle's wells when the Slate Hills quarry began to be filled with DEP approval only a few miles away in Plainfield Township (West Bangor).  Has DEP taken a single one of Andreus' recommendations seriously?  Doesn't seem like it.

#4 is the air quality permit for the facility, and get this - it is an individual permit application for just the Synagro facility, because at a pow wow between DEP and Synagro, there was a gentleman's agreement that Synagro will be a "single source".  Single source is an EPA term used to denote a facility that is a stand-alone source of air contamination.  But in this case, there are three sources - Green Knight Energy Center, Synagro and Grand Central, all co-located and all on Waste Management property and under control of Waste Management, producing emissions into the air.  This is total bullshit and you should tell DEP this in a comment on this application number.  Strike 3, DEP, you're out!

To submit written comments via email

Tell DEP that what they are doing is unacceptable and they are not protecting you

• The pond is way too close to the facility, and even Synagro acknowledges they don't know if they can prevent it from being contaminated (Robert Pullar, Synagro enviromental engineer Nov 7 hearing)
• What if there is an accident in addition to all the known hazardous sources?
• The air quality permit should not be for a single source, but for the entire facility
• A more stringent air quality permit may be required since NorCo's air quality is impaired
• Road drains that garbage trucks use and crap haulers will use drain directly into the pond, which will cause tracked fugitive crap up and down the road and increase contaminated runoff to the pond
• The pond should not be exempt from a Waterways permit, because it is in fact a waterway and DEP recognizes that it is.  It isn't just a hole in the ground connected to nothing.

You have until tomorrow (Wednesday) at 4:30pm - anything received after 4:30pm will not count. You can use a form on the Delaware Riverkeeper Network's site (they have talking points too) to generate emails, or send your own emails as follows.  There is a single email address for comments on any of the four permits/permit applications: 

ra-epbenuseall@pa.gov

All you do is place "Comments on

• WMGR160N001" for the Synagro Waste Management permit application or
• 100265-A181" for the Grand Central Waste Management permt modification or
• PA#0276120" for the Synagro NPDES stormwater draft permit or
• 48-00111A" for the Synagro Air Quality permit application

In the subject line of your email.  That is all there is to it.  For example "Comments on WMGR160N001" would be for the email that addresses the Synagro facility permit.