DEP holds meeting to discuss deficiencies related to freshwater pond adjacent to proposed Synagro biosolids plant - but creates no minutes, and withholds notes taken during meeting. Your tax dollars abused.

At the April 17, 2019 Planning Commission review of Synagro's land development plan, Plainfield Township manager Tom Petrucci inquired about a May 23rd meeting that Syangro had scheduled with DEP to discuss deficiencies DEP has fund with Sedimentation Basin #2, and requested that the township be included in this meeting.  Here is a transcript of the exchange:

Meeting with DEP on site to discuss issues surrounding Sedimentation Basin #2

Everyone will be in the same room... or will they?

Plainfield Township and Pen Argyl were invited to attend, at 11:00AM on May 23rd.They showed up on time, but were kept waiting in a conference room until 11:20, at which time they were allowed to join a meeting in progress since 10:00AM.  Here are two agendas for the same meeting, or more accurately an agenda for the DEP portion of the meeting, without the municipalities present, and an agenda for after the municipalities were allowed to join the meeting.

Two agendas... for one meeting

Note that Plainfield Township is scheduled to show up, after the conversation with DEP of deficiencies with Sedimentation Basin #2 have been discussed

Let's see who was able to attend each portion of this meeting(s):

Two sign in sheets... for one meeting

Representatives of DEP, NorCo Conservation District, Synagro, EarthRes, Waste Management

are at both meetings.  Plainfield Township and Pen Argyl only at the second "meeting"

Note that Phil Gray is the geologist consultant for the township.  He would have had important input to the discussion about the basin - if only he had been invited to the discussion about the basin at 10:00AM.  It is reported that the only thing that happened after 11:20AM were several announcements.  Jason Smith, wetlands consultant for the township summarized the following announcements at the June planning commission review meeting:

• DEP will not be requiring a Chapter 105 permit to paritally fill the pond (Sedimentation Basin #2)
• DEP will be issuing a permit to use the pond for runoff of the Synagro facility (apparently ignoring all the deficiencies in the DEP's letter)
• DEP will not be putting anything in print until a permit is issued, and it can be challenged at that time.

What Mr. Smith did not report, but township environmental attorney Jack Embick did (during the August 12, 2019 DEP hearing), is that Plainfield Township officials were "encouraged" by DEP to approve Synagro's application.  The timing indicates this would have happened during the May 23rd meeting, and done verbally while township officials were present.  Mr. Embick challenged DEP to put this highly inappropriate "encouragement" in writing, which is a lawyer's way of saying "you fucked up big time and we're calling you out."  You can be certain that DEP will not do this, because it is evident that they will put nothing in writing, in addition to it in fact being very inappropriate.  Peter Albanese, Green Knight Treasurer, has stated that "DEP wants more facilities like this one," and it is becoming apparent that DEP wants so badly to issue permits to Synagro for this facility, it will do virtually anything to make it happen - environmental protection be damned.

Roger Bellas in his office, consumed by euphoric crapulence and a dream

of crap bakeries throughout Pennsylvania

Editor's note - See the bottom of the page before leaving to see what you can do to help fight back against this kind of douchebaggery

A Right to Know Request submitted to DEP for notes, minutes, etc that memorialize what took place at the May 23rd "meeting", yielded exactly 1/2 page (generous estimate) of notes of Roger Bellas, Solid Waste Program Manager and the person who issued an opinion that a waiver would be granted so that a Chapter 105 permit would not be required to fill the pond.  Bellas never provided proof that a waiver was properly granted years ago for a similar purpose, but stopped a lawsuit against DEP filed by the township by withdrawing his opinion early this year.  Here are his sketchy notes, apparently of only the scheduled 11:00AM meeting:

The only notes that DEP will release on the May 23rd meeting to discuss

serious deficiencies with Sedimentation Basin #2

(these notes do not discuss the geology of substantive issues at all)

There was this page and an additional blank lined page provided (2 sheets total)

These hen-scratchings do not contain anything pertinent to the deficiencies of Sedimentation Basin #2, other than it has never discharged.  Nothing about its geology, nothing about whether a waiver will be needed.

Mr. Buczynski's meeting memo shows Roger Bellas organized the May 23rd meeting(s)

and the purpose was to discuss technical deficiencies of Sedimentation Basin #2

Here is Mr. Buczynski's meeting reminder.  Take a close look at what is in the red boxes:

If only "the" one meeting actually took place the way this memo describes

The technical deficiencies were discussed from 10:00AM to 11:20AM,

before Plainfield Township and Pen Argyl were allowed to enter the room

Abnormalities in DEP's RTK response

When Mr. Bucynski was asked, "if everyone's personal notes were to be redacted, why were Roger Bellas' notes, or some of them, included in DEP's response?"  Mr. Buczynski agreed this was odd, and later stated "it was an error, these are the two pages that should not have been sent.  We will examine our internal procedures."  Mmm-kay.

Here is another abnormality - 10:00AM comes before 11:00AM.  Mr. Bellas' notes for 11:00AM are at the top of the page, then 10:00AM where the good technical stuff happened is halfway down the page, but blank.  Looks like Mr. Bellas created these "notes" after the meeting(s), and supplied only details that are innocuous and not of substance.  He doesn't jot down that DEP will be issuing a waiver, that a permit will be issued, that the township was encouraged by DEP to approve Synagro's land development plan, that DEP will put nothing in writing until a permit is issued.  He also did not provide jack shit about the 11:00AM meeting.

Is there really no record of what happened at this meeting, other than who attended it?

Think about this - apparently the only record of what transpired at this meeting to discuss technical deficiencies of Sedimentation Basin #2, the most controversial aspect of this proposal, is who was in attendance and what was scheduled to be discussed.  Can it be that no correspondence between DEP employees, or between DEP and the Conservation District (which determined what the deficiencies are) or between DEP and Synagro exists, that reflect Roger Bellas verbal comments and announcements made at this meeting?  It stretches credulity, or if true is a piss poor way to conduct business.  It sounds like DEP came in the door ready to make announcements, with no record.  Not to have a serious discussion of experts of the issues at hand.

This is a crock of shit.  This two meetings in one meeting underhanded skullduggery was orchestrated by Synagro and EarthRes, but DEP participated in the farce and Roger Bellas organized the meeting(s).  Mr. Petrucci requested that Plainfield Township be present and Solicitor Layman requested that Pen Argyl be present, to discuss technical deficiencies of the pond, and Synagro agreed.  All the municipalities were invited to was the outcome of that meeting.  And DEP is withholding anything and everything written that would inform not only Plainfield Township and Pen Argyl of the substantive discussion that occurred at the meeting(s), but the tax paying concerned citizens of the public as well.

Announcing 2019 Golden Turd Award

We now present the 2019 Golden Turd Award... to PA DEP.  Past winners are depicted as well.

One great big, stinking crock of shit

Congratulations, all winners!  You earned it, dookie style

What you can do today to fight back against DEP's refusal to be transparent

Synagro and EarthRes are expected to perform douchebaggery, but DEP should be held to a higher standard.  Comments are being received through Monday August 26th on the NPDES and Air Quality permit applications.  There are talking points published by the Delaware Riverkeeper and Clean Air Council, respectively, to give you an idea of issues the experts see in these two permit applications.  See the right margin of this page for where to email your comments, which must be received by 4pm on Monday.  Ideally, DEP prefers that comments be addressed separately to each permit, but you can send one combined.  Put the permit number in your subject line (shown on the margin).

Full transcripts of eleven Synagro 2018-2019 planning commission meetings and November 2018 DEP hearing available in your inbox - Synagro Slate Belt Heat Recovery Center Crap Factory

The full transcripts of the following land development plan review meetings, as well as the November 2018 DEP hearing, for the proposed Synagro bulk crap processing and redistribution plant in Plainfield Township are available on request.

If you send an email to Sharon Winslow at winslowsharon1983@gmail.com, you will privately receive four (4) zipped files that are less than 25MB each in return.  These files when unzipped contain the transcripts of the following meetings:

April 4, 2018
May 31, 2018
July 16, 2018
September 6, 2018
October 6, 2018
November 7, 2018 (DEP hearing)
December 10, 2018
February 21, 2019
March 11, 2019
April 17, 2019
May 13, 2019
June 10, 2019

You will be a BCC blind recipient, and your email address will not be visible to anyone else, shared, or retained.

Due to file size some of the files can not be hosted in the usual way.  They can't be reduced in size without making the text illegible.

Expert testimony at August 12, 2019 hearing shows that neither DEP or Synagro are on the same page as Plainfield Township regarding proposed crap factory

On August 12, there was a hearing hosted by DEP to hear testimony on two of four permit applications for a proposed Synagro biosolids (shit) processing factory - Air Quality and NPDES (stormwater).  Representatives of DEP associated with the two Solid Waste permit applications were nowhere to be seen - including Roger Bellas who is a critical player as he is the one ironically charged with the responsibility of the sedimentation basin within a few feet of the proposed plant, which has become a major issue.  Bellas does solid waste, not water.

This post is to memorialize the testimony of experts and consultants, read into the record at the hearing.

It should be noted that while it was advertised that representatives of Green Knight (providing waste energy to partially fuel the plant), Waste Management (lessee of land), Synagro and EarthRes (Synagro's engineer) would be present at the hearing, what they did was not make a presentation or take questions, but rather testify along with the public.  Their "testimony" consisted of public relations bull shit, not comments on the permit applications.

The consultants for Plainfield Township were:

• Jack Embick Environmental Attorney
• Gail Braden (GB Universe) Air Quality
• Jason Smith (Hanover Engineering) Wetlands Consultant
• Mike Brunamonti (BCM Engineers) Environmental Consultant
• Trudy Johnston (Material Matters) Biosolids Consultant

Also testifying:

• Tracy Carluccio, Deputy Director of the Delaware Riverkeeper Network on NPDES permit
• Russell Zerbo of the Clean Air Council on Air Quality Permit

The testimony below shows that while Synagro may believe everything is fine with its application, Plainfield Township does not.  Furthermore, Plainfield Township is not at all satisfied with the piecemeal approach that DEP has taken in evaluating multiple permit applications but not cross-pollinating monitoring requirements, and allowing the sedimentation basin to be filled without a Ch 105 permit.  The Riverkeeper and Clean Air Council have significant issues with each of the two permit applications.

Plainfield Township legal environmental counsel testifies that DEP encouragement
of township to approve

Synagro's Land Development Plan is "inappropriate"

Very troubling is that Plainfield's expert Jack Embick stated that "representatives of the DEP have encouraged the township" to approve the Land Development Plan currently before the planning commission, which he correctly terms in his testimony as "inappropriate".  This statement suggests that DEP may be biased, since DEP has been aware of the township's objection to DEP's handling of the basin for many months (the township sued DEP over it), and DEP has done nothing to change its stance or recognize the township's concern for the protection of the water quality in the basin or adjacent creeks.  If DEP representatives have in fact encouraged the township to approve Synagro's plan, it would be highly inappropriate.   Note that Mr. Embick encourages the DEP to put its position in writing, so that the township and public can see the hijinx DEP is up to - knowing full well that DEP would never do this on the record.  This indicates that DEP's officials did it verbally, in a non-public forum.  Possibly the May 23, 2019 on-site meeting, at which DEP met with Synagro for an hour and 20 minutes, before letting Plainfield Township officials and consultants join the meeting.  There will be more posted on this meeting and the meeting before the meeting in the near future.  Mr. Embick tossed this warning out in a very public way (he could have just called their legal counsel) and on the record for the DEP to MYOFBAs - and DEP deserved it and the public deserves to know that it happened.

Does DEP "want" to proliferate plants like the one proposed across Pennsylvania so badly that it will come right out and attempt to influence a local review process?  It looks like it.   Green Knight Treasurer Peter Albanese has stated "DEP wants more facilities like this one."  At any cost, regardless of "environmental protection"?  It's in their name for God's sake.  Pathetic.

PA DEP and Synagro appear to be on the same team,

obsessed with the pursuit of the Holy Grail of poop

DEP picked a piss poor choice of this project to be the flagship for Project Spread Shit Across Pennsylvania, but it seems they do not want to acknowledge it and will go down fighting to see it happen as opposed to lifting a finger to protect the environment.  Synagro has been ignoring requests by township planners to submit an environmental impact statement for over a year, and has refused to acknowledge it's proposal needs zoning and SALDO relief.  DEP seriously expects the township to just bend over and wince whilst they get a telephone pole shoved up their behinds, smile and say "thank you"?  Both the DEP and Synagro should fully expect plan approval by the township to be DENIED.

What business do DEP representatives have to weigh in on local compliance and review?  PA DEP should not even be spending time or taxpayer funds on Synagro's permit applications, since DEP is  to require local approval to proceed with a permit application.  In at least one Synagro permit application (Air Quality) is it falsely stated that the proposal has received local zoning approvals - patently false - not a single township approval has been granted. This stinks to high heaven.

A full review of testimony will be published at a later time.  Here without further comment is the testimony of each of these experts:

Jack Embick Comments at Aug... on Scribd

Gail Braden Comments at Aug... on Scribd

Jason Smith Comments at Aug... on Scribd

Mike Brunamonti Comments at... on Scribd

Trudy Johnston Comments at ... on Scribd

Tracy Carluccio Comments at... on Scribd

Russell Zerbo Comments Aug ... on Scribd

Synagro's biosolids to be processed in Plainfield Township and used as fertilizer are not categorized as hazardous waste but they contain hazardous substances - PFAS and more

At multiple planning commission review meetings, Synagro representatives have stated that the Class B biosolids that it will process into Class A biosolids are not hazardous waste.  Here are just a few samples of many:

From October 8, 2018, an interchange between citizen Jerry Lennon and Synagro rep Jim Hecht

MR. HECHT: ....So an independent tractor driver, you know, you would not see that on the trailer, but it would be our material, so you would call us.

INTERESTED CITIZEN: Also carry a sign on the back saying carrying hazardous waste?

MR. HECHT: No, it is not hazardous waste

INTERESTED CITIZEN: That's up for debate.

From May 31, 2018, an interchange between  citizen Gail Weber and Synagro rep Pam Racey

MS. RACEY: There's an annual scan for TCLP there is a list, don't know how long the list what's called TCLP which tests for a whole bunch of different parameters. That is required at a less frequent level because typically these things aren't found in biosolids. But in order to demonstrate that there's no contaminants of a hazardous nature, you have to do what's called a TCLP, usually on an annual basis. If it'S a small plant it might be biannual.

MS. RACEY: We're only going to be able to take in material that meets a certain criteria. If there's a plant that produce biosolids that have a higher level of pollutants, we're not going to be able to take them. 

          INTERESTED CITIZEN: By pollutants, do you mean pathogens?

MS. RACEY, Metals.

 INTERESTED CITIZEN: What about other contaminants? 

MS. RACEY: Or organics. Like I said,TCLP there is a list, don't know how long the list is, it's quite long. It's called TCLP. 

INTERESTED CITIZEN: I don't think this is the right place for it. I agree with the other gentleman that said about the pond. Who was the man that said about the pond? I have concern about that quarry that you've changed into to what is the runoff, the runoff sedimentation basin?

Few observers agree that Synagro's raw (Class B) or finished materials (Class A pellets) are benign or safe for the environment.  Citizen Steve Demaris is knowledgeable about the subject, and he expressed his assessment that Synagro's raw materials are hazardous on May 31, 2018:

INTERESTED CITIZEN: D-E-M-A-R-I-S I want to clear some points up. They say this thing is not hazardous. I'm going to quote you from 503 regulations. They say it's not hazardous or anything. I'm going to quote from the law, 503 regulations, right? Biosolids is described as a pollutant, right? And under 503 regulations it says. pollutant is an organic substance -- an inorganic substance. A combination of organic substance or inorganic substance or pathogen organic -- organism, excuse me, that after discharge. that means after treatment, upon exposure, ingested, inhaled, assimilated into the organism either directly or from the environment or indirectly by ingesting through the food chain. It means this bio stuff, the chemicals, the pathogens in biosolids. Can regrow and enter the food chain. This is stuff they're not telling you. On the basis of the information available to the administrator, that means the EPA, could cause death, disease, behavioral abnormalities, cancer, genetic mutations, psychological malfunctions, including malfunction of the reproduction organs, physical deformities in either organisms or offspring of that organism. That means your children. So this is the stuff that the law -- the law says. And it's even in the beneficial -- Title 25, 271, the beneficial use under the PA law states this. So don't tell me that it's not hazardous when the law tells me that it is.

.......... 

 Another thing, the location that this is being built on was a backfill quarry, which means water would drain from this. That means sinkholes there, from the shale and stuff falling back into where the water would drain. I suggest that the environmental study include to see if ducts have formed that it doesn't affect wells in the area, especially because they wash the trucks in the same area as this backfill quarry, and contamination could happen, right?And under the law, the problem is with this company, is almost every state they've been in, even when they've been told by EPA, right, that they would violate the law doing this, it seems like they'd rather pay the fine than follow the regulations.

On Mr. Demaris' last point, at the July 11, 2019 review citizen Don Moore pointed out his concern that as recently as 2017 Synagro paid a fine and entered into a consent decree with the EPA for failure to install equipment to control mercury emissions in accordance with updated EPA standards at its Waterbury CT biosolids plant.  Wait to be caught violating the law, then pay a fine and move on.

Transcripts of several review meetings held in 2018 are located here.  Also, minutes of planning commission meetings are located here.

Green Knights representative also maintains that biosolids are safe

At the October 10, 2018 Plainfield Township Board of Supervisors meeting, Green Knight Treasurer Peter Albanese stated multiple times that biosolids are safe, and suggested that people who do not believe they are "don't know".  "The biosolids go through testing... there are standards" he maintained.  Green Knight runs the landfill gas to energy center that will be giving its waste energy to Synagro - almost literally at the $100,000 maximum Mr. Albanese stated they will receive from Synagro annually.

First of all, the biosolids appear to be tested only once a year or every other year according to Ms. Racey's testimony above.  What's in your wallet?  And it gets worse...

November 15, 2018 EPA Inspector General Report

"EPA Unable to Assess the Impact of Hundreds of Unregulated Pollutants in Land-Applied Biosolids on Human Health and the Environment"

This report by the EPA Inspector General found that 352 pollutants known to be found in biosolids have no risk assessment.  That sounds really bad, and it is.  Here is an excerpt from the report:

EPA Inspector General found 61 hazardous pollutants in biosolids 

- not one of which has been assessed for risk -

Of the 352 pollutants found in biosolids that EPA has no risk assessment for, 32 are "hazardous wastes," four of which are "acutely hazardous".  "16 are NIOSH hazardous drugs", and 61 total are hazardous.  If the EPA has no risk assessment for these they aren't being tested for.  The claims of Synagro and Green Knight sound a bit hollow once the corner of the carpet is lifted.

The full report of the Inspector General, including Appendix C (click)

Environmental PFOA and PFAS contaminant research and regulation is only in its infancy

As noted in the highlighted text above, PFOA and PFAS are found in biosolids.  Several state governments are attempting to develop regulations for PFOA and PFAS, as found in various materials including biosolids;  Maine and Pennsylvania are two examples.

In the past week an article was published that quotes none other than Tracy Carluccio, the Deputy Director of Delaware Riverkeeper Network, which is monitoring the Synagro application carefully and has objected to the project.  This is the first article in the following list, which is is a sampling of recent articles that discuss PFOA and PFAS and biosolids.  Note that the EPA released a "technical brief" only a few months ago in which it is stated that the EPA is "developing analytical methods for analyzing PFAS in biosolids" - which means they don't currently have them (!)

• "Waste containing PFAS chemicals poses conundrums" Aug 2, 2019 https://www.theintell.com/news/20190802/waste-containing-pfas-chemicals-poses-conundrums
• "EPA Technical Brief Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)" June 6, 2019 https://www.epa.gov/sites/production/files/2019-02/documents/pfas_methods_tech_brief_28feb19_update.pdf
• "Another reason biosolids should never be used as fertilizer" Aug 6, 2018 https://content.sierraclub.org/grassrootsnetwork/team-news/2018/08/another-reason-biosolids-should-never-be-used-fertilizer-pfas
• "Managing Organics in the "PFAS" Age" August 2018 https://www.biocycle.net/2018/08/07/managing-organics-pfas-age/
• "PFAS and Organic Residuals Management" July 2018 https://www.biocycle.net/2018/07/06/pfas-organic-residuals-management/

In conclusion, what do you think?  Are biosolids "safe"?

Register by tomorrow Friday August 9 via email to speak at August 12, 2019 DEP hearing for proposed Synagro crap factory in Plainfield Township

The Pennsylvania DEP is accepting comments on two of the permits that Synagro has applied for, NPDES (stormwater) and Air Quality.  There is a hearing the evening of Monday August 12, and to pre-register to speak all you need to do is send an e-mail to one of three people at DEP, whose emails are on the right margin.  If you send your notice to one of the program managers, they will forward it to Ms. Connolly.  DEP requests that you include your name, address and phone number.

• Colleen Connolly Public Relations
• Amy Bellanca Clean Water Program Manager (NPDES draft permit #PA0276120 )
• Mark Wejkszner Air Quality Program Manager (Air Quality draft permit #48-00111A )

You should submit this email with your intent to speak by the end of business Friday, August 9, though it is possible that if you send it on Monday prior to the meeting you will be pre-registered.  You may register at the meeting to speak, but you will have to wait until the pre-registered speakers are done.

Note: You can speak on anything related to the proposed plant, in addition to the stormwater and air quality permits.  DEP is not obligated to respond to topics outside of these two permits, but your comments will still be entered into the record.

DEP requests that you submit your comments in writing if you plan to speak, either before or in person at the meeting.  There will be a transcript taken, so technically you don't have to submit them in writing.  Some people may wish to only submit comments in writing, and either not appear at the hearing or appear but not speak.

DEP is keeping the comment period open through 4pm August 26, and written comments will be accepted up until that time at the same three email addresses.   If you submit written comments, it is a good idea to put the draft permit number (in bold above) in the top of your submission.  You may also submit your comments to DEP at 2 Public Square, Wilkes-Barre, PA 18701  Edit Aug 14 - DEP spokesperson Colleen Connolly incorrectly stated during the hearing that comments are due by Friday August 23rd.

Experts at two environmental groups have reviewed the permit applications, and have presented talking points on each.  You may wish to review the talking points in preparation for your address at the hearing and/or submitting comments in writing.

NPDES Permit - Comments supplied by Delaware Riverkeeper Network

• Talking Points
• DEP announcement of hearing

Air Quality Permit - Comments supplied by Clean Air Council

• Talking Points
• DEP announcement of hearing

Please plan to attend the DEP hearing on Monday August 12, 2019 - asses in the seats counts.  In association with the 2018 DEP hearing on this proposal, DEP reports that it received over 300 comments/letters!

Synagro DEP hearing flyer on Scribd

Transcripts of year 2018 reviews of Synagro land development plan and November 7, 2018 DEP hearing for crap bakery in Plainfield Township

Here are several transcripts of  planning commission meetings held in 2018, as well as the DEP hearing held November 7, 2018, regarding Synagro's plan for a biosolids (shit) processing facility dubiously named the "Slate Belt Heat Recovery Center" and misadvertised as a "green" project that is good for the environment.  Maybe if it were sited elsewhere, but not where planned.  The plant will be operating on 100% natural gas in only a handful of years, and the "heat recovery" aspect will be permanently in the past.  Heck, by the time they obtain approval, they may not even bother investing in the technology to recover heat from the Green Knights landfill gas to energy plant next door.

Remember that some things have changed in the plan since these transcripts were taken - for example stormwater management has changed a bit, to route some runoff from the pavement behind the plant that used to head for the pond to an inlet.  These are the only transcripts SYnagro has made available at this time.

• May 31, 2018
• July 16, 2018
• Sept 6, 2018
• Oct 8, 2018
• Nov 7, 2018 (DEP hearing)

May 31 2018 Transcript on Scribd

July 16 2018 Transcript on Scribd

Sept 06 2018 Transcript on Scribd

Oct 8 2018 Transcript on Scribd

Nov 7 2018 DEP Hearing Transcript on Scribd

Synagro submits new materials in effort to resolve loose ends and obtain a vote on its Plainfield Township crap factory land development plan

On August 1, there was supposed to be what was anticipated would be the final land development review meeting before Plainfield Township's planning commission.  However, Synagro submitted new materials electronically on July 26th, and in hard copy on July 29th.  This is not a surprise, since after the last review meeting in July it was evident that several items were outstanding that required further negotiation between Synagro and the township's consultants.  In order for the consultants to review the July 26th materials and respond in writing, the August 1 meeting had to be postponed.  A new date has not yet been scheduled.

Once responses are received to these documents from township consultants, they will be posted.   I remains to be seen if issues will be resolved as much as possible to everyone's satisfaction by the next meeting. Here are the 4 documents submitted on July 26th:

Synagro Comprehensive Monit... on Scribd

Comprehensive Monitoring Plan

Synagro Nuisance Mitigation... on Scribd

Nuisance Mitigation Control Plan

Synagro Hydrogeology of Basin No. 2 submission for Plainfield Township biosolids plant land development pla... on Scribd

Hydrology of Sedimentation Basin #2

Wetlands, Riparian Buffer and Open Space Plan