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