Read the documents planners will rely on for their vote Monday September 9, 2019 on Synagro's proposed biosolids crap processing plant in Plainfield Township

Synagro proposes to nestle a "biosolids" processing plant on the edge of Pen Argyl, on land in Plainfield Township on Waste Management's Grans Central Sanitary Landfill.   This plant will process 400 tons of wet biosolids (aka shit) a day, into roughly 100 tons of dried shit.  The 300 tons of water removed is proposed to be hauled away to parts unknown at this time.  The remaining shit will end up on farms throughout the Lehigh Valley and Monroe County, or it is proposed it may be burned as a fuel if one or more customers finds the product to be worthy of burning.

Synagro submitted new materials on August 30, 2019 at the end of the day and the beginning of the Labor Day holiday.  It is pointed out in a letter (below) by township manager Tom Petrucci that the materials the submission contains are dated August 13.  This is a really shitty move - and designed solely to pressure the township since the meeting date of September 9 was chosen weeks earlier, and Synagro controls the deadline for a decision by the Board of Supervisors - currently September 30.    Consultants did not receive the packet until September 3, giving them a whopping 3 business days to submit a review to the township so that planners would get it prior to this weekend.  At a recent meeting, Planning Commission Chairman Levitz commented that this practice had to end, but Synagro did it again - and apparently is unwilling to approve an extension of the September 30 deadline.  Applicants that pull these stunts are shitty (no pun intended) businesses you do not want in your town.

To the township and its consultants' credit, reviews were completed by the end of business on September 6.  These reviews and a memorandum by Manager and Alternate Zoning Officer Petrucci are contained in the document below, which you may download as a PDF.  This file is text searchable, so you can look for text such as "quarry", "pond", "basin", "environmental impact statement", etc.  A non text-searchable, higher resolution version is here.

Of particular note is an item presented without explanation - the "Facility Enforcement/Shutdown Provisions Protocol" on pages 6-7 of the Material Matters submission (PDF pages 27 and 28).  This appears to be a new document, which assesses monetary penalties for failure to comply - including up to $4000 a day maximum for a problem left unresolved.  Nice work Material Matters!

Note that Mr. Pertucci's memorandum contains Sections A, B and C across 16 pages, and is a guide to two possible actions by planners (in sections A and C):

• A. Recommend denial of the application for reasons set forth herein (p, 2)
• B. Environmental authority (p. 10)
• C. Recommend approval of the application with conditions set forth herein (p. 10)

OCR version Slate Belt Heat... on Scribd

Another new item for planners to discuss is that PennDOT has apparently reversed course and approved a driveway from Pen Argyl Road, for use by cars and light trucks.  The review letter by Benchmark addresses this update.

Note that in one evening, planners will have to talk about the changes and updates in the August 30 submission, consider whether to conditionally approve or deny the application, and discuss ramifications of each of these approaches.  Recall that Environmental Counsel Embick previously stated that in his opinion, planners must vote to deny the plan - due to Synagro's repeated refusal to do an Environmental Impact Study.  If this is still his opinion, it will carry weight,  In reading over Mr. Petrucci's letter, see if you could vote to approve this project regardless of conditions - taking into consideration that Synagro has refused to to an Environmental Impact Study, and has refused to apply for variances it needs.  Try to ignore the fact that the DEP has attempted to influence Plainfield Township to approve the plan - since DEP has no right to do interfere with the local approval process.  DEP should be protecting the air and water, and lacking this the township has to step in and do that job.

Minutes of the August 12, 2019 DEP hearing to take public comments on the proposed Synagro biosolids factory whimsically known as Slate Belt Heat Recovery Center

Synagro is proposing to locate a 400-ton per day crap bakery in Plainfield Township, Northampton County, PA, on land owned by Waste Management.  The project is misadvertised as "green", with waste heat from the adjacent Green Knight Energy Center used for 84% of the energy needed (reducing to zero once the landfill closes in 2030, at which time a switch to 100% natural gas will occur).  This will be within 10 feet of the boundary of a quarry that was once at least 300 feet  deep, whish was partially filled 10-15 years ago.  DEP's department of mining approved this with likely no concern for water quality.  This quarry, which is technically a pond and by DEP permit a sedimentation basin, is a key point of contention for this project.  All of the loading and unloading of sludge will be within crapping distance of the pond, in addition to trucks loaded with wastewater that must be removed since the lot is too small to process it onsite.

On August 12, a second DEP hearing was held to take public comments on the draft NPDES and draft Air Quality permits.  (note:  written comments may be submitted via email until tomorrow Monday at 4:00PM - see the right margin for details of where to send - let DEP know how you feel about this ill-conceived proposal)

Audience members were spared the dog and pony show presentation that occurred at the November hearing, but Waste Management, Green Knight and Synagro each felt compelled to make appearances at the podium, to deliver advertising speeches.  Each time, a small handful (perhaps 4 or 5) people clapped - these people were other representatives of the same group, not concerned citizens.  Perhaps the intent was to get the attention of the press.  Here are unofficial minutes, as recorded by one observer:

Minutes of August 12, 2019 DEP hearing

Gail Weber – citizen

 DEP has to update its regulations so that all contaminants from Synagro are filtered out of discharges to groundwater.  This plant will generate many toxins, some known but many not.  Not only to protect humans, but all living things including insects and aquatic life.

(name not known) EarthRes Air Quality engineer– We considered worst case emissions in our application to DEP, and in typical operation the alternate fuel sources of landfill gas and natural gas will not be used.  (This is untrue – Synagro has stated the amount of waste heat from Green Knight is insufficient to run their drying equipment.  Waste heat will supply 84% of the energy used prior to teh landfill closing.  This woman did not get the memo.)

(Editor's note: the complete testimony of Plainfield Township's five consultants, who are listed immediately below, is available here)

Gail Braden – Environmental Consultant for Plainfield Township – Air, water and waste. Synagro’s plan must meet exceptional conditions to earn the township’s support.  Synagro and DEP must consider exceptional quality of life standards, beyond regulatory minimums.  All contingencies must be considered – what happens if the power fails, heavy precipitation.  Routine audits should be performed and Synagro should be a good corporate neighbor.  Any issues should be resolved as soon as possible.  Conduct business like you live outside the fence.

Mike Brunamonti - Environmental Consultant for Plainfield Township

The revised NPDES permit application submitted to PA DEP on July 1, 2019 contains an Enhanced NPDES Monitoring Plan, but not the Basin #2 Monitoring Plan or Groundwater Monitoring Plan that are mentioned in the DEP’s NPDES Fact Sheet.  The Fact Sheet mentions these two Plans will be included in the Waste Management Permit.  Stormwater associated with industrial activities will be discharged to an abandoned quarry connected with groundwater, and therefore the Clean Water Program must consider groundwater protection when reviewing the NPDES permit application.  Basin #2 water quality monitoring and groundwater quality monitoring should be included in the NPDES permit.  If DEP were to defer Basin #2 water quality and groundwater quality to the Waste Management Permit, then DEP should issue a draft Waste Management Permit before talking any further action on the NPDES permit application.

Mr. Brunamonti recommended several testing intervals for monitoring VOC’s and other contaminants in outfalls to Basin #2, the Waltz Creek, and a tributary to the Little Bushkill Creek.  See here and scroll down the page.  Recommendations of these intervals assumes that DEP incorporates Basin #2 and ground water monitoring into the NPDES permit, as recommended above.

Routine inspections should be weekly, not semi-annually as stated in the permit.  At least once a quarter, the routine inspection should occur during a storm runoff event – not once per year.  A summary report should be submitted to DEP and Plainfield Township after the first year of operation, containing a summary of monitoring data and any exceedances of permit limits and corrective actions taken.

Plainfield Township and its consultants believes a Chapter 105 permit is required in order to modify Basin #2.

Jack Embick – Environmental Solicitor for Plainfield Township

The Zoning and Planning process is not complete, so final action on DEP permits should not take place.  DEP has encouraged Plainfield Township to approve Synagro’s land development plan; this is inappropriate.  IF DEP wishes to comment on (read: interfere) with the township’s process, it should put its comments in writing so the planning commission, officials and public can consider them – just as we are doing at this hearing.

The township has requested that the applicant submit an environmental impact study, which the applicant has refused to do.  Both the township and DEP would benefit from such a study, and we encourage DEP to support this request.  The township believes that an individual permit should be required for facilities such as this; the township has identified several areas in this proposal that need improvement. A general permit is not appropriate.  (note that because an individual permit was not required, a harms and benefits analysis is not required by DEP).

It is not apparent that DEP has considered the impacts of this proposal as a whole, given the segregated approach to permitting (ie Waste Management, NPDES, Air Quality).  The DEP must not consider the proposed permits in this piecemeal fashion.

The DEP has not responded to public comments submitted at the DEP hearing on November 7, 2018, 9 months ago.  The DEP must communicate in a more timely manner about the project and its proposed advantages and disadvantages.  (eg A general permit will allow DEP to more easily permit similar plants elsewhere in PA – DEP has not commented on this)

The township is unaware that the required engineering was done prior to issuing a Chapter 105 waiver to previously partially fill the pond.  A Chapter 105 permit should be required, because the water in this pond is directly connected with groundwater and Waters of the Commonwealth.

Trudy Johnston – biosolids/Nuisance Mitigation Control Plan consultant for Plainfield Township

Incoming biosolids may or may not be stabilized – they could be digested or undigested.  There is a high probability incoming sludge will be odorous.  The particle size in emissions may become greater as the facility ages.  The Nuisance Mitigation Control Plan should be adopted into the Air Quality permit.

Regarding odors from trucks, what standard(s) does DEP use?  Definitions should be added so that complaints may be addressed.  Odors and particulates, regardless of the source (ie stack, roads, trucks, etc) must be regulated.

Jason Smith – wetlands consultant for Plainfield Township

Pre-startup sampling should be required as part of the NPDES permit for the outfalls and pond itself (note that due to the piecemeal permitting process – Brunamonti above – this is not currently the case).  There currently is no background data for the pond water quality or surrounding groundwater, which are required to assess future possible impacts.  The township has proposed additional surface and groundwater monitoring and these should be included in the NPDES permit.

A previously unidentified wetland has been observed along Waltz Creek within 300 feet of propose project activity.  This area could potentially support bog turtles, and the applicant should conduct a study (applicant has declined to do so).

The pond was not designed, constructed or maintained as a Chapter 102-compliant stormwater or detention basin.  Therefore the DEP should review the proposed activities under Chapter 105.  Granting a waiver of the 105 permit could result in harm to the health, safety and welfare of the public.

Tracy Carluccio – Deputy Director of Delaware Riverkeeper Network

This is a high risk project on an undersized lot.  3500 citizens will not be able to escape water and air pollutants.  The monitoring proposed in the draft NPDES permit is weak and ineffective, promoting a cover-up by commingling runoff from three different sources (ie landfill, gas to electricity plant, Synagro).  The groundwater is connected with creeks designated for special protection under the regulations.  Despite increased monitoring being proposed, there are many pollutants found in sludge and wastewater that are not included in the permit.

Why isn’t DEP also demanding a geologic analysis, as the township has, since the pond directly infiltrates to groundwater?  The groundwater and surface drains on the access road connect with the streams, carrying pollutants that will harm the creeks and life in them.  Synagro has not done the required anti-degradation analysis (Sec 93.4c).

The Rube Goldberg plan is to haul away wastewater using the same trucks that deliver the sludge, to an as-yet unidentified disposal facility.  This is caused by poor site selection, wherein it is impossible to meet the discharge standards for the creeks.  There is great potential for spills and accidents that will contaminate the creeks, given the maneuvering and tight quarters of the site.

The air quality plan will allow hazardous air pollutants to be emitted, and these will plaque the residents of Pen Argyl.  Pen Argyl is ground zero for the pollutants and odors that will be released from the plant and the trucks that support it.  This includes fires and explosions, which have occurred as recently as August 2, 2019 (Explosion at Stamford CT plant).  Permit violations, accidents and health and safety issues are to be expected with Synagro.

The proposed plant is the wrong project in the wrong place, and DEP has not provided the required protection of our water and air, and thus both permits must be denied.

Steve Demaris – citizen

Reported that EPA official/whistlebower William Sanjour stated that he was directed to create misleading public documents, and to not label sewage sludge as hazardous matter.  Sanjour was directed to not use the normal processes to identify hazardous material.  The public is not being protected from heavy metals found in sludge.  EPA fabricated the facts, and as a result the legality of DEP permits is in question.

Russell Zerbo – Clean Air Council, a PA and DE public health group

Synagro does not acknowledge in its application that 25% of the citizens who live in the area of the plant are below the poverty line, and this plant should be considered a major source of emissions.  Some of the most significant emissions will be from truck traffic.  Synagro is relying on dust control from Waste Management’s operations, yet it states that compliance of Waste Management to its permits is irrelevant.  Synagro’s compliance will in fact depend on the compliance of its neighbors.  Synagro’s Camden facility had a violation this year.Cumulative impacts of the operations near this site (ie: landfill, energy center, Synagro plant) must be considered.  Road emissions will be significant.

Bob Cornman – Green Knight Synagro spokesperson

Green Knight benefits three communities, Wind Gap, Pen Argyl, Plainfield Township (all three oppose the proposed project -  two have written opposition, the third can not legally oppose it).  Our biggest project is a land reclamation (but this project has the greatest potential for negatively affecting the community).  Synagro is expected to generate between $100,000 and $200,000 income (Green Knight Treasurer Peter Albanese has stated it is up to $100,00 maximum).

Scott Perin – employee of Waste Management
Public service announcement for Waste Management.  Mr. Perin apparently did not understand the purpose of the hearing.

Nolin Perin – citizen whose father founded the landfill, father of Scott Perin

We have to take care of our own problem and get rid of this sludge (this sludge is not “ours” and not "our problem" – it is from NJ, CT and NY, who have more strict regulations than PA)
As pertains to concerns about water, I would not mind living downstream of this plant. (to see thousands of cubic yards of hazardous waste that Mr. Perin stockpiled at the base of the Blue Mountain, where the headwaters of creeks are, click here)

Luther Bond – citizen

I work with waste – I know what is in this stuff, and it isn’t good for the environment.  Synagro has refused to do a study that would show its effects.  We need to consider fish, water life and mammals.  Synagro’s trucks are not closed – they are tarped, which will not control odors.  The risk of a spill is very high.  When sludge is delivered, there is no way to prevent material from becoming airborne.

Pat Sutter – citizen

I live along Route 512, and the garbage truck smell very bad one block away, travelling in either direction.  With this sludge, it will be worse.

Howard Klein – citizen

The question I am concerned about in addition to Synagro doing monitoring, is who will be monitoring Synagro?  What is in this sludge – every batch will be different.  You cook your turkey longer than Synagro will be heating this sludge.

Peter Layman – Solicitor for Pen Argyl

I want to focus on the Air Quality permit.  It is premature to issue a draft permit without a completed Nuisance Mitigation Control Plan.

Don Moore – citizen

For well over a year the planning commission has requested a hydrogeologic study of the pond to the creeks, and Synagro has refused.  In a lawsuit for DEP to produce proof that engineering was done to justify a Chapter 105 waiver years ago, instead of producing the documents DEP withdrew its intent to issue another waiver for Synagro.  Synagro has offered multiple estimates of the depth of the pond – it has no idea what is going on under the surface, and in a recent meeting stated it does not know what percentage of water from the pond goes to one creek versus the other.  A DEP employee told me that DEP also has no idea what is going on under the surface of the water.  No one knows.

On May 23^rd, Plainfield Township consultants arrived to attend a 11:00AM on-site meeting with Syangro, DEP, Waste Management and the county Conservation District to discuss deficiencies with Basin #2.  Plainfield reps were made to wait in a room until 11:20AM, at which time they were allowed to join the meeting – which had started at 10:00AM.  Deficiencies of Basin #2 were on the 10:00AM agenda, but not the 11:00AM agenda.  Several announcements were made once the township was in attendance, such as a Chapter 105 waiver would again be issued.  What science is this based on?  Mr. Bellas stated at the November 2018 hearing that he was unaware of geologic testing that ever been done on the pond.  There was no testing done prior to or following the partial filling years ago, so no one knows if there was an effect of that or not.

Synagro has announced that it will be petitioning reduced or eliminating monitoring after a year or two, but planners believe it should be forever, never reduced.  Monitoring will not be preventative.  Months to discover a problem, months to re-test, possibly months more of non-compliance with possibly fines that are or are never paid.  Synagro’s Waterbury CT plant was successfully sued in 2016 for failure to implement mercury emissions controls.  Synagro says it will pump the pond of it becomes contaminated.  This won’t cleanse groundwater.

The general permit Synagro applied for could be used across PA for the beneficial use of biosolids as a fuel.  Peter Albanese of Green Knight has stated “DEP wants more of these facilities”.  DEP should be more concerned about our water quality than implementing what it sees as a beneficial use across the state.

By Peter Albanese’s number, the income to Green Knight will be 1/9 on a per ton basis than another community with a Synagro plant.  By Mr. Cornman’s, it is still less than 1/4 maximum.

The community is totally against this proposal.  Wind Gap, Pen Argyl, Upper Mt Bethel and Lower Mt Bethel have all written letters of objection.  Nolan Perin is the single citizen at any meeting or hearing in almost three years who has spoken in favor of it. Lisa Perin, his niece, has said how negative it would be for the community.  It is common sense that this is the wrong place for such a facility.  DEP should reject the permits.

Millie Beahn – citizen

I know this community, I have lived here all my life.  This plant will change this community.  It should be placed somewhere else – not so close to residents.

Justin Huratiak – citizen

We must consider the cumulative impact of this plant.  Consider that the landfill has been able to control odors and its impact on the community, and now we are going to add this?  It will make things even worse.

David Flyte – citizen

I want to be able to sleep with my windows open.  Have picnics and enjoy my property.  My property value will sink if this plant is here.  The odors from it will add to the landfill.

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