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.

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

Waste Management stands to earn $$$ millions per year from proposed Synagro crap bakery in Plainfield Township, while citizens' quality of life and property values are reduced

At the October Plainfield Township BOS meeting, Peter Albanese of Green Knight Economic Development Corporation reportedly stated that Green Knight will take in "up to $100,000 per year" selling its waste heat to Synagro.  Thus, the communities of Wind Gap, Pen Argyl and Plainfield Township may receive up to $33.3K each, per year - a pittance.  In short, they will take it up the rear.

edit - At the November 7, 2018 DEP public hearing on Synagro's permit applications, Green Knight representative Robert Cornman, Jr responded to a citizen's question of "what is in this for the community?" by stating that Green Knight will receive "some funds" that will benefit the community.  He didn't mention anything about the amount of funds - knowing the answer would displease anyone hearing the figure.  Yet he promotes this horrible proposal.

Setting aside for a moment that no amount of money would ever compensate local residents or the communities within 50 or 100 miles for having Class A (90% dried) sludge spread on farmland, let's take a deep dive into the economics of this operation - and in the process see how Waste Management may profit handsomely from the proposed operation while the host communities and those within delivery distance become literal shitholes.

In Synagro's NPDES permit application to DEP it states that the product Synagro will process is 21% solids.  There is industry data available that details the amount of energy required to dry-roast shit on belt conveyors, which is the same process that Synagro proposes.  A chart published by Veolia Water Systems/Kruger on the "BioCon" dryer is presented, which has been marked up accordingly:

What the chart shows is that to dry 9523.8 pounds of "wet cake" to Class A biosolids (90% dry solids), just over 11 million BTU of energy is needed.  Since there is 1000 btu in one cu ft of natural gas, and the industrial cost of natural gas in August 2018 was $9.38 per 1000 cu ft, we divide by 1000 twice to find that 11 cu ft of natural gas is needed.  This is a fuel cost of $103.21 for 9523.8 pounds, or $21.67 per wet ton.

Recall that Synagro proposes to bake 400 tons of crap a day, so the cost of using 100% natural gas per day would be 400 * 21.67 = $8669.88.

Now let's compare to the cost of Green Knight's waste energy.  At a planning commission meeting a few months ago, Synagro project manager Jim Hecht stated that Synagro plans to use 84% waste heat and 16% natural gas.  So much for being the "green" project this is hyped to be - Synagro can't run on 100% waste heat.  At $100,00 per year, Synagro will pay $273.97 per day for 16% of its baking costs.  That is $273.97/(0.16 * 400) or $0.81 per wet ton.

Something stinks here:

• To heat with natural gas, Synagro pays $21.67 per ton
• To heat with Green Knight's waste heat, Synagro pays $0.87 per wet ton.

Synagro's fuel cost per day will be reduced to 0.84 * 400 * 21.67 + 0.16* 400 * 0.87 = $1387.18 + 273.97 = $1661.15, or $4.15 per wet ton.  Jim Hecht also agreed in the past few months "this plant could run profitably running on 100% natural gas."   In other words, Synagro could afford to pay $8669.88, but will only be paying $1661.15.

Let's look at how the plant could run profitably on 100% natural gas, and consider the consequence that Green Knight appears to be screwing citizens twice over - once for partnering in this operation, and twice for not receiving even 1/10 of fair market value for its waste heat.  And in the process we will discover why Waste Management wants this so badly...  It's green - money, that is.

There are several assumptions here, and they are shown.  Since Synagro is not building a waste water treatment facility, the cost of the plant has been reduced $2m from an original estimate of $10m.  The lowest paid employees (most of them) are estimated to earn $35,000 a year, and one or two lucky people $80,000.  The waste water of this operation is loaded with ammonia and nasty.  Assuming it doesn't leak into high quality water bodies and Synagro finds someone to take it, the cost of disposing it was estimated.

In the S&P 500, an 11% profit margin is typical.  We have allowed for 18.6% here.  Look at who the big winner of this shitty operation could be - Waste Management.  They can pretty much charge what they want.  Using the estimates above,

• Using 100% natural gas, Waste Management may receive $8000 per day or $2.9m per year
• Using 84% waste energy, Waste Management may receive $15000 per day or $5.5m per year

The assumption is that Synagro delivers the product for the cost of delivery - there is no need to charge for the product because it is so lucrative to haul the raw product away from sludge generators.

Once the landfill shuts down and the waste heat goes away because the landfill gas to energy plant is shuttered, Waste Management will remain on easy street for decades.  And Synagro's trucks will be using a "street" that is actually Plainfield Township's recreational trail.

Did Waste Management dictate that Green Knight will only receive $0.87 for energy that would otherwise cost Synagro $21.67?  There is evidence that Green Knight's lease with Waste Management that was just renewed for 20 years may have been used to leverage GK's participation with this project.  At each of the planning commission review meetings this year, several Waste Management personnel have been in attendance.  Now it is very clear that Waste Management is the driver of this operation, not Green Knight.  Waste Management will very likely reap millions of dollars of income per year from this operation, while Green Knight gets table scraps of "up to" $100,000.  You just could not make this shit up.  "Slate Belt Heat Recovery Center" my ass.

This project is in fact green - but not to the environment.  It is green to Synagro and Waste Management, and shit-brown to everyone else.

Green Knight is serving up shit on a stick to Slate Belt residents,

while Synagro and Waste Management feast on a bottomless buffet of cash