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

It is common knowledge that the air quality in Northampton County is impaired.  The air quality does not meet the standards for Ozone or PM2.5 particulates.

PM2.5 means particles suspended in air that are less than 2.5 micrometers - about 3% the diameter of human hair.  PM10 refers to particles that are 10 micrometers or less, so PM10 includes particles that are PM2.5.

There are pages on an EPA website for the Grand Central landfill and Energy Center that reflect the fact that Northampton County's air does not meet these two standards.  This does not mean each facility does not meet standard - but that the air where it is located does not.

Northampton County's air quality sucks - newsflash

Synagro plant will apparently exceed threshold for a minor air quality permit

 Synagro's application states that they expect to emit 15.47 tons per year PM10.   The EPA has established a standard for new sources in PM2.5 non-attainment areas that seek a minor permit of 15 tons per year (tpy) of PM10.  An EPA memorandum that documents this standard is located here.  At the bottom of page 3 is this statement:

"On July 1, 1987, we established a significant emissions rate for PM-10 of 15 tpy"

Since PM10 embodies PM2.5, regulating PM10 emissions regulates PM2.5.  Thus Synagro's facility should require a Title V major air quality permit.  Synagro's Air Quality Permit application does not reflect that Northampton County's air quality is impaired, nor does it mention that the applicable standard to be exempted from a Title V permit has been exceeded.

Single Source determination claim in Air Quality Permit application

Apparently, when Synagro and Waste Management met with their chums at the DEP a year ago, a gentleman's agreement was made that Synagro's plant would be a "single source" of air emissions.  Accordingly, Synagro applied for an Individual Air Quality Permit.  However, common sense tells anyone with a brain that this is unadulterated bull shit.  The operations of Grand Central, Green Knight and Synagro are all connected by both contracts and energy source, and all on land owned by Waste Management.  These must be permitted as a group.  Let's look at an aerial:

DEP apparently can't discern it's ass from a hole in the ground

Syangro's proposed plant would not be a single source

Here is where in Synagro's application it is revealed that it coordinated with DEP on this matter:

Synagro's engineer claims it is entitled to an Individual Air Quality Permit

Note that Synagro makes no mention of the fact that the first two criteria are met - the facilities do belong to the same industrial grouping, and the facilities are adjacent.  Waste Management controls this whole proposed operation, and owns the land all are located on.  Obviously none of these three are a single source in the context of emissions - they are all emitting into the air based on the operation of the landfill, and should come under a single Air Quality permit.