Rural homeowners in Lehigh, Northampton, Monroe and Schuylkill counties dodge the biosolids fertilizer bullet, for now. Synagro scrubs website of references to proposed Plainfield Township crap factory

In the past week, all mention of the ill conceived "Slate Belt Heat Recovery Center" that Synagro proposed to be placed on land leased from Waste Management in Plainfield Township, has been removed from Synagro's website.  Previously, the project showed up on the "Locations" map, which shows all the Synagro locations.  Here is what the map looks like today:

Slate Belt Heat Recovery Center no longer shown

on Synagro's map of shitpiles across America

The SBHRC was announced in a press release in late November 2016, which was also on Synagro's website.  Here is the pertinent section of archived press releases in chronological order today:

The "Big News" that Synagro was opening a plant in Plainfield Township used to

be between the top two entries in this list

Prior to last week, there was a page devoted to all the shitty details about this project.  This page is now absent.  Prior to its removal, it looked like this:

Synagro hype referred to Green Knights

as an "economic development" organization

Synagro makes it appear like this is wonderful for the community, and that an economic development organization is partnering with them.  In reality, Green Knights is just a part of Waste Management.  It was first revealed by Green Knights president Carlton Snyder that "contractual obligations" were factored into Green Knight agreeing to sell its waste energy to Synagro.  In other words, they did no have a choice.  It was later revealed that Green Knight would not even be selling "its" waste heat to Synagro, but rather Waste Management would, in what Synagro project manager Jim Hecht called a "complicated" arrangement.  Green Knights buys its landfill gas from Waste Management to burn to create electricity, but Waste Management "owns" the waste heat that is a byproduct of burning the gas.  Sweet!  Waste Management would have tossed "up to a maximum of $100,000" to Green Knights annually, and raked in potentially a few million a year from the waste heat going up Green Knights' stacks.  Synagro would also have raked in millions, and supported 12 to 16 low quality jobs shoving shit around a building.  "Economic development" this was not.

Another revelation during review of this proposal was that although Synagro advertised that its product may be used as a fertilizer or a fuel, it would likely never be used as a fuel.  Biosolids expert Trudy Johnston, a member of the Mid Atlantic Biosolids Association, hired by both Pen Argyl and Plainfield Township, stated that in her opinion biosolids will never be used as a fuel in the state of Pennsylvania.  There is only one plant in the entire US that burns biosolids as a fuel.

What this means is that Synagro's product, these unwanted crap pellets, would have ended up on a farm near you.  100 tons a day, distributed all over the Lehigh Valley and across the mountain in Monroe and Schuylkill counties.  Synagro makes its money on the front end, to haul the crap (no pun intended) away from sewage treatment plants.  If they could dump it somewhere, they would be rolling in it.  They have to pay to dry it first, to convert it from Class B to Class A, which does little to nothing to reduce or eliminate the toxins in it.  It was learned in November 2018 that 352 known pollutants are in biosolids, 60 that are hazardous, with no known metrics for how much of any of these pollutants is too much.  This stuff contains PFAS and PFOS, and the state of Pennsylvania and others are struggling currently with how to regulate these.

Is Synagro really not planning to pursue this project?  Why would they give up?  We'll take a look at that in the next post, and we will compare the arc of Synagro's proposal in Plainfield Township to that of Nestle Waters' failed attempt to take hundreds of thousands of gallons a water a day out of Eldred Township - the project that launched this blog.  There are multiple similarities.  For now, people across the Slate Belt as well as neighbors to the west and north can breathe a tentative sign of relief.  Nestle moved on to Centre County, where they were quickly ejected by the community.  What will Synagro do next?

Synagro and Waste Management withdraw Slate Belt Heat Recovery Center land development plan after board motion is made to deny it

At last night's Board of Supervisors meeting, Synagro's program manager Jim Hecht, Counsel Mike Brennan and Counsel Elizabeth Witmer spent a half hour mealy mouthing the supervisors, as they attempted to explain why they should be granted an 18-month extension and the board should take no further action on this evening.

Let's rewind - on September 9, Synagro refused to allow an extension of the deadline that was September 30, 2019, so the planning commission had to vote on a recommendation to the board.  They voted 4-0 to recommend rejection of the plan.  Synagro was asked by the planners to grant a 90-day extension, but Synagri claimed they could not do this without consulting Synagro management.

On Tuesday, September 17, Synagro reportedly contacted Plainfield Township, and offered an 18-month extension of the plan.

Solicitor Backenstoe explained that the board had only two options at Thursday's meeting, to accept Synagro's extension/negotiate a shorter version (eg 6 months, etc), or deny the plan.  Accepting the plan with conditions was not possible because the planning commission and Synagro had not reached mutually acceptable conditions.

Then Synagro started its song and dance, claiming that it was blindsided by the planning commission on September 9 when it required at least a 90 day extension in order to work on major deficiencies.  Jim Hecht claimed he did not have authorization to make longer than a 60-day extension.  Mr. Hecht suggested that board Chairman Heard poll the township's experts to see how many line items had been resolved over the course of the reviews, suggesting that if it was a high number that Synagro should be granted additional time to address remaining items.  Mr. Heard did not fall for this trick, and we'll see where this ends up below.

In typical Jim Hecht self-contradictory form, he stated that he felt Synagro could resolve remaining issues in 1 month (there is no way in hell this could be done), but was requesting 18 months.  Yeah - this makes sense.  All that could happen in one month is a slim chance that DEP will issue a permit that Synagro and Waste Management could weaponize against the township.  DEP hasn't issued a response to the public comments made at the November 2018 hearing, but it does feel like they may be on the brink of something.

Chairman Heard asked Mr. Hecht point blank "will you agree to do an environmental impact statement?" which he never got an answer to, again in typical Jim Hecht form.  The best he received was a mealy-mouthed "Well, that is something we are willing to look at."  Not "Yes, that is why we need 18 months," but rather "we're willing to take a look and we think we can be ready in a month..."  An EIS would take several months.

Synagro made its bed by ignoring the most significant deficiencies in its application

It caught up to them on September 19

After speaking in circles with Mr. Hecht, Counsel Brennan took over, mealy mouthing his way through an argument that Synagro has worked with the planning commission, blah blah blah, and we thought we had addressed the major outstanding issues (two variances, a SALDO issue, and lack of an EIS).  "We submitted an Environmental Package and a Hydrogeological Package."  It is true that Synagro submitted collections of pages with those titles, but they did not contain an EIS or a hydrogeological study.  This was just more scraped from the walls of a crock of shit.

At this point, Robert Lynn, engineer for the township requested the microphone, and addressed Mr. Hecht's line item survey challenge.  Mr. Lynn pointed out that while several individual line items have been addressed, many remain in addition to the ones that Synagro has not addressed (the EIS, variances, and SALDO).  Mr. Lynn pointed out that of the sticking points, there has been little progress for months.

Chairman Heard questioned Synagro about why it had not gone to the Zoning Hearing Board for variances.  The mealy mouthed reply he received was that Synagro wanted to resolve its violations (which it has steadfastly denied exist) through design changes.  This is just nonsense.  If Synagro has picked up the phone and asked the Zoning Officer, he would have told them at each step that they have resolved either variance.  Mr. Heard stated that in 12 years he has never seen an applicant not go and get variances.  This resulted in Mr. Hecht mumbling that he was just now realizing that Synagro might have to go the Zoning Hearing Board.  He didn't state that they would (they could/should have submitted an application in the intervening time since September 9, if they were acting in good faith - which they are not).  Mr. Heard added that while this is a permitted use, he sees this proposal as very negative for development the Slate Belt - people want Starbucks, not sludge plants and trucks hauling odorus waste through town.

Counsel Witmer said something at some point that was of no consequence.  It was not as daft as usual for her, but there is a saying about fool me once, fool me twice.  It is doubtful many listened to what she said.  Basically she held to the "we don't believe these variances or EIS are required, but hey we tried to work things out (our way, not yours)" storyline.

At this point, board member Jane Mellert spoke.  She stated that she had been to all the review meetings.  She itemized that there had been nine 30-day extensions and two 60-day extensions since the reviews began.  Now Synagro is here suddenly asking for an 18-month extension, and you never went for your variances. (Mr. Heard also made these points).  You came into the September 9 planning meeting unprepared to agree to a reasonable extension to address major issues - why is that?  It was obvious where the vote was headed after Mr. Heard and Ms. Mellert had spoken.

Mr. Heard again spoke, and made clear that an EIS would help the township assess the impacts the project will have on the community, including neighbors.  The landfill has been an issue, and now you are going to add another potentially problematic business on the same site - this merits a study.

Mr. Heard made a motion to reject the application.  Before there was a second, Mr. Brennan's hand shot up and he yelled out "can we have a 5-minute break?"  The audience groaned, there was some confusion, and eventually Solicitor Backenstoe explained that the either the board should follow through with a second and then discussion and possibly take a break, or Mr. Heard retract his motion and a break be taken per Synagro's request.  Mr. Heard retracted his motion as a courtesy, and Synagro and Waste Management huddled in conversation.  At the end of the break, it was announced that Synagro and Waste Management were withdrawing their application.  Note that the Applicant technically is Grand Central (Waste Management) and the Operator is Synagro.  Also note that if Mr. Heard had not retracted his motion, after it was seconded - which it likely would have been by Ms. Mellert - the application could have been withdrawn then, prior to a vote.

Pardon the interruption

This caught many by surprise, but the lawyers in the room suspected it.  For the township, it will save the expense of defending an appeal in court - pocket change for the Applicant but several tens of thousands of dollars potentially for the township. While a rejection could be appealed, withdrawing avoids the bad press of a rejection.  Let's face it, Synagro doesn't need any more bad press.  As Mr. Backenstoe pointed out, Synagro and Waste Management could turn around and file a new application tomorrow, starting the entire process over again.  Mr. Hecht was seen looking annoyed as he shoved some items into his carrying bag - but he had no one to be upset with except himself.

It is unknown what will happen to the four DEP permit applications.  It is hard to understand how they can work on permits for a project that does not exist, but this is the DEP and they appear to "want" this kind of project.

Courtesy of the floor

Tracy Carluccio pointed out that Synagro is gaming the system, by pulling its application and being able to file another one.  It is causing the township a great expense.  She said the Riverkeeper Network will remain committed to protecting groundwater and the high quality creeks that the basin feeds with the groundwater.  If this proposal comes back, the RiverKeeper Network will be too.

Howard Klein pointed out that Synagro was not able to get a simple additional 30-day time extension on September 9 supposedly because they could not contact management, but on this evening within 5 minutes they received approval to withdrawal their application.  Mr. Klein stated that the board must be sure that the township is in attendance at all DEP meetings, and he had heard that they were excluded from an important one on May 23, 2019.  The Municipalities Planning Code must be changed so companies with very deep pockets like Synagro and Waste Management can't bleed towns dry of cash by dragging out applications; if Synagro/Waste Management want to file a new application, they should reimburse the township for the $200,000 it spent defending itself against this plan.

Don Moore pointed out the details of what happened on May 23, and displayed two agendas for back to back meetings that Tom Pullar of Synagro's engineer EarthRes had crafted with Roger Bellas of the DEP, that excluded the township from a discussion of deficiencies of sedimentation basin #2.  Mr. Pullar had previously told the township that they would be participating in this meeting.  Mr. Pullar stared at the floor as Mr. Moore pointed out the deception that had taken place.  Mr. Moore also stated that this project is not economic development - real economic development would be for Waste Management to return the township's trail when the landfill closes, which would allow the township trail to travel through Grand Central Woods and connect with Wind Gap and Pen Argyl.  Trails - especially through trails - are known to increase adjacent property values.

Elisa Robles presented the board with a petition signed by over 1000 citizens, objecting to the project.

Tom Carlo pointed out that this project was said to be all Green Knights and Synagro when it began, and no questions could be asked of Waste Management.  It has become clear that Waste Management is the Applicant and more questions should be asked of Waste Management if this project returns.  Sludge is not safe for application to land - it contains 350+ known pollutants, 60+ hazardous.

Sheri Acevedo of Northampton County Parks encouraged the township to be vigilant and uphold its ordinances, including requiring an EIS for a project with such potential impacts.  The township also must not let applicants file new materials a few days before meetings - if there is a 21-day rule it must be enforced uniformly.

Rachel Rosenfeld of the Sierra Club congratulated the township on the recent passage of its Appalachian Trail Ordinance, which implements various protections of the Appalachian Trail corridor and throughout the township.  Ms. Rosenfeld stated that the Sierra Club seeks to assist communities in protecting its citizens from degraded natural resources, especially high quality waters - as are present at the proposed Synagro site.

David Flyte reminded everyone that Synagro/Waste Management owes at least $21,000 in land development review fees.

Several speakers thanked the planning commission members for the outstanding effort they put into reviewing Synagro's application, over the course of 2 years and 10 months in total.

Synagro and Waste Management will be back with another try at this - they are way too greedy to let this opportunity go, no matter how insane their proposal is.

Resident calls out DEP for irregularities in Synagro biosolids bakery permit review process for Slate Belt Heat Recovery Center in Plainfield Township

The meaning of the phrase "the fix is in" is pretty widely known.  It implies that the process has been corrupted such that the outcome will not biased away from the criteria that should be evaluated.  The outcome may be consistent with an unbiased evaluation, or more commonly it will be the opposite, and shock the conscience.

In the case of this biosolids plant, which will process 400 tons of crap a day, to be distributed to a farm next to you as fertilizer, some may say "This biosolids plant will be approved.  These are big companies, they will get what they want."  It is true that big companies have big money, and have lobbyists working overtime attempting to curry favor with politicians.  But lacking a change in law, weakening even further Pennsylvanians' ability to enjoy a healthy environment, at the end of the day the courts must uphold the law.  The passionate observer must stand up for him or herself, and get involved in the fight.  That is what this blog is all about - justice for citizens.  Active participants and voices in the fight against this proposed plant are the Delaware Riverkeeper Network, Clean Air Council and the Sierra Club.

Several warning signs have appeared in the case of this crap factory that indicate the Pennsylvania Department of Environmental Protection may be biased in favor of approving it.  The letter below, written by a citizen, identifies these warning signs to Joe Buczynski, the Assistant Director of the Northeast Regional Office in Wilkes-Barre.  This office is reviewing three of Synagro's permint applications, the fourth is being reviewed in Harrisburg since it is a general permit that will allow plants like this to be spread across the state, and to sell their product as a fuel.

Here are the warning signs the letter writer cites:

• DEP is intentionally not putting in writing decisions it has made
• DEP is intentionally not putting in writing a record of negotiating a lengthy list of deficiencies
• DEP participated in excluding Plainfield Township and Pen Argyl from attending a critical meeting they were told they could participate in to discuss significant deficiencies of Sedimentation Basin #2, a pond located next to the proposed plant
• DEP is acting consistent with a bias towards spreading similar plants across the state, leaving the protection of the water and air in this community and on this site is a lower priority
• DEP is acting like Synagro in placing a priority on the goal, without regard for how it reaches that goal
• DEP and Synagro have made statements that seem to indicate DEP has already decided to issue permits once local approval is granted, and Synagro has stated an intent to use a DEP permit to pre-empt local ordinances

The letter writer also expresses a fear that DEP may be participating in or accommodating "state pressure" to approve this project - outside pressure - which may have resulted in one or more of the behaviors in this list.  You have the power to fight back against such biases, but it takes your participation - which you are guaranteed as a right as a citizen.  Asses in the seats send a message as much as those who speak.

The Plainfield Township Board of Supervisors will meet to vote on this proposal on Thursday, September 19, at the Fire Hall Banquet facility on Sullivan Trail, beginning at 7pm.  The planning commission voted unanimously to recommend rejection by the Board.  If you care about your property and health, or that of your neighbors, northeastern PA citizens and future generations, you are encouraged to attend and participate either as an observer, or speaker at courtesy of the floor.  Speakers will have 5 minutes to make their voice heard.

Letter to DEP regarding irr... on Scribd

The first six people on the sign-in sheet at 11:00AM are officials and consultants for Plainfield Township and Pen Argyl, who were let in the room at 11:20AM.  Most all of people who attended beginning at 10:00AM then signed again - an odd exercise.

DEP Sign in Sheet for Slate Belt Heat Recovery Center Meetings on May 23, 2019 on Scribd

Signs that Waste Management controls the waste energy of non-profit Green Knights Economic Development Corporation

Who owns the waste heat going up Green Knights' stacks?

On April 5, 2017, a dog and pony show was held at the Plainfield Township Fire Company Banquet Hall, and representatives of Synagro took questions from the audience.  However, neither Waste Management nor Green Knight were on the panel that answered questions.

After the meeting, Green Knights President Carlton Snyder informally addressed some questions by audience members.  He stated:

• This was not our idea - we were approached by either Synagro or Waste Management
• We looked at three criteria in choosing this project, one of which was contractual obligations

Synagro was asked how they got involved, and they stated that they were approached by Waste Management.  Together with Mr. Snyder's statement, the project was envisioned by Waste Management, who likely discussed it with DEP, and then approached Synagro.  Green Knights was brought in at the end.  It is logical that if it was Waste Management's idea, the potential of making insignificant income was present.

In 2018, it was learned from Green Knights' treasurer Peter Albanese that Green Knights will receive up to $100,000 a year by selling the waste heat used by Synagro.  The assumption that Green Knight is selling its waste energy to Synagro appears to be false; Synagro's project manager Jim Hecht has stated that Green Knights has "an arrangement with Waste Management" for remuneration for its waste heat (July 2019).

On August 9, Mr. Hecht was asked whom Synagro is paying for its waste heat, and he stuttered "It's c... complicated," implying that Waste Management is involved.

Why would this be?  Green Knights is a non-profit and should be an independent organization.  It converts the landfill gas it receives to electricity and in the process waste heat is generated and sent up the stacks of its generators.

We found earlier that Waste Management and Synagro could both earn millions of dollars a year off of this project, while Green Knights sucks out $100,000 maximum of exhaust fumes.  This analysis assumed that Waste Management would makes its income from a lease fee for its property - it could charge virtually any price it chooses.  The assumption this is Waste Managements' only source of income from Synagro appears to be incorrect.

It is a very simple matter to estimate what the worth of Green Knights' waste heat is to Synagro, to replace the heat from burning natural gas.  Krüger is a manufacturer of a belt dryer for biosolids, which performs the same function as the one Synagro proposes.  Krüger has published a chart that shows the energy needed to reduce biosolids of various water content to 90% dry - the same as proposed.  This analysis is at the link above, and repeated here:

Synagro has stated that the water content of its biosolids is 21% - the highlighted row.  Looking at that row, 9523.6 pounds of wet biosolids requires 11003492 BTU of energy.  There are 1000 BTU per cu ft of natural gas, so it will take 11003.5 cu ft to dry 9523.8 pounds of "cake"- Synagro's class B raw product.  This is 4.76 tons of product.

In August 2018, natural gas in PA was an average of $9.38 per thousand cu ft, so the cost to dry this amount of product is $9.38 * 11003.5/1000 = $103.21.  To obtain the cost per ton to dry wet cake, we calculate $103.21/4.76 = $21.67.

Synagro will process 400 tons a day maximum, and using 100% natural gas we obtain 400 * 21.67 = $8670 per day as the cost of fuel.  Per year, this is $3,164,422.

Synagro has stated that Green Knights can not provide more than 84% of its energy needs (showing the project isn't as green as suggested), and that they plan to run on 84% waste energy and 16% natural gas.  The 84% of heat energy that is supplied by Green Knight is equivalent to 0.84 * 3,164,422, or $2,658,114 worth of natural gas per per year.

This must be where Waste Management sticks its greedy hand in the pot and makes a heck of a lot of money.  Green Knight is receiving $100,000 per year, saving Synagro $2,558.114.  Mr. Hecht has implied that Green Knight will receive its $100,000 from Waste Management, not Synagro.  This begs the question, how much per year will Waste Management receive from Synagro, for Green Knights' waste heat?  It would obviously be far better for the community, and more like the "economic development" touted, if Green Knight were receiving say, 50 cents on the dollar, or roughly $1.6 million per year.

Another question is, is there some "contractual obligation" of Green Knights in Mr. Snyder's words, in which they don't control or have ownership of their own waste heat?  It certainly seems like they have little or no independence from Waste Management.

Plainfield Township planners vote to recommend rejection of Synagro land development plan application - Synagro refuses to grant time extension to resolve remaining issues

At 10:05pm last evening, September 9, the planning commission voted unanimously 4-0 to recommend rejection of Synagro's land development plan for a biosolids (aka crap) bakery on lands of Waste Management.

As could be predicted by everyone in the room except representatives Pam Racey and Jim Hecht of Synagro, there were multiple unresolved issues as the 10pm hour approached.  Recall that Synagro submitted a thick package (roughly 5" thick by the looks of the clumps in front of each planner and consultant) on August 30, four business days before the meeting date. Pam Racey stated that she thought any unresolved items at this end of this meeting could have been handled as "conditions", and the planners should be able to vote for conditional approval.  The problem is, there were multiple significant issues unresolved, which anyone except an idiot would know going into the meeting would be the case.  Either Ms. Racey and Hecht are idiots, or they just does not care.  This observer believes it is the latter.  Why wouldn't they care?  The suggested answer is, Synagro knows it is heading to court, one way or the other.  So they really don't care - they are stringing the township along and trying to game the system by coordinating with DEP as it reviews Synagro's permit applications.  Many on the township's side have been hoping for almost a year that this process could be started, and after tonight's meeting and vote, everyone is finally on the way.  While Synagro legal counsel Elizabeth Witmer was present, she was not involved in the decision making as the clock wound down to the witching hour.

Oddly this is the first meeting where Waste Management did not pay a stenographer to record the meeting.  Could it be they did not want the best record of what transpired at the most important meeting of all?  Plainfield Township's secretary appeared to take detailed notes, so there will be a good record.

Let's review your issues

The first hour of the meeting was spent with Tom Petrucci reading his memorandum to planners, dated September 6.  Synagro had a chance to respond, and of course tried to explain away most all of the deficiencies that Petrucci enumerated.  Again, Racey stated that she felt these could be handled as "conditions" of approval.  Don't resolve them, but say that you will fix them later... so you can tell DEP you got approval.  Note that Synagro submitted its own list of suggested conditions, which planners essentially ignored.  Racey was wrong - the deficiencies are too serious to leave for after a vote.  Why she didn't realize this is a mystery but consistent with the "just give us approval" attitude Synagro has displayed throughout.  Racey stated that the DEP needs to see at least conditional approval to issue permits, including the issuance of one permit Synagro would need to go to the zoning hearing board and argue they do not need a variance.  Like a chicken and egg situation.  Chairman Levitz had admonished Synagro for once again submitting their package with too little time for planners to be prepared to review it, and once again Pan Racey appeared clueless as to what Levitz was referring to.  "Do planners not receive the package when we send it?  I don't understand."  What Racey failed totally to consider is that the township's consultants have to have time to do a review, get the reviews to the township, and the township sends the reviews to planners days ahead of a meeting.  When Racey was informed that 21 days ahead is typically the requirement, this seemed to blow her mind.  Ironically, Racey herself lamented that there was not time to respond to the township's comments of August 30.  Hello - if you granted an extension and postponed this meeting, or submitted your materials a few weeks earlier, you would have that time.  Where is this woman from - Planet Clueless?  This is the person 4 months ago who exclaimed "I just can't wrap my arms around the concern over the water in this pond."  People this stupid shouldn't be allowed to... well, they shouldn't.

The next hour and a half was spent discussing the more significant issues such as variances and the lack of an environmental impact statement.  Racey announced that Synagro will choose the course that is most likely to result in "approval," and may choose to "go to court" to achieve approval - the assumption being for some reason that they will prevail .  At this point Plainfield counsel Backenstoe pointed out that the only venue he knows of to hear variances is the local zoning hearing board - not a court.

Let's hear from that kindly looking gentleman that speaks the citizens rights gospel

Plainfield Environmental counsel Jack Embick was asked if he still felt that an Environmental Impact Statement was needed, and lacking it he would continue to recommend that planners recommend denying the application.  This led to Mr. Embick delivering a prepared 15+ minute soliloquy on the scope of an EIS, and how it could assist planners in assessing the short and long term impacts of this project on various aspects of the lives of people in the community as well as on the environment.  Article 1 Section 27 of the PA Constitution is the authority that protects these values.  Mr. Embick felt that many items contained in an EIS have not been addressed by Synagro, despite repeated requests for Synagro to submit one.  Mr. Petrucci had enumerated five or six occasions beginning in March 2018 that an EIS was requested by planners.  (Note: Waste Management/Synagro's legal counsel Elizabeth Witmer doesn't think much of the Constitution, but she kept her mouth shut on this evening.  This is best, as when she speaks she is very dismissive, daft, and condescending)

Chairman Levitz crafts a segway to conclusion

Several audience members were allowed to speak for 2 minutes each at courtesy of the floor and then a break was taken at 9:40pm.

Public speaker points out troubling reality

At courtesy of the floor, Howard Klein pointed out a concern he has mentioned several times - how are any of the conditions placed on Synagro for monitoring odors, water quality, etc going to be enforced?  He stated that they will not be.  His point was, all these concessions Synagro is making (such as shutting down the plant if problems go unresolved) are to get their foot in the door, and once they do you will not be able to control problems.  Think about it - there is no way Synagro would shut down its plant.  For one, they lose money.  Two, their contracts require them to haul away shit with no excuses.  So that shit has to go somewhere.  Can't pile it up on this postage stamp-sized lot.

Follow the money

Don Moore asked a seemingly simple question that Mr. Hecht could not answer - whom will Synagro pay for its waste heat?  Mr. Hecht previously stated that Green Knight has an "arrangement" with Waste Management to be remunerated, suggesting that possibly Synagro will purchase Green Knights' waste heat not from Green Knight but from Waste Management.  Mr. Hecht seemed confused (like usual), and stuttered out that "it's c... complicated".   Could it be that the reason Green Knights is receiving a few pennies on the dollar for its waste heat be that Waste Management is acting as a middle man?  An additiuonal question Mr. Moore could have asked is, how much is Synagro paying for the waste heat that Green Knights generates and is receiving only up to $100,000 for?   How much more than $100,000 is it?

After reconvening at 9:55pm, with 5 minutes remaining, Chairman Levitz pointed out that there were remaining items, and asked if Synagro was interested in an extension.  Synagro first tried the "any remaining details can be made conditions," but apparently Trudy Johnson quietly said something to Hecht and had made clear to him that Material Matters' issues were non-trivial.  Hecht reported this to planners "I just learned it is more than dotting i's and crossing t's," sounding almost surprised.  Are these people on medication?  Acting stupid on purpose - for almost three years?

What is left is a lot more than dotting i's and crossing t's

The 5" thick packet delivered on August 30 that Waste Management and Synagro surely paid many thousands of dollars for was apparently intended to tie up loose ends to the point that in Racey's mind would leave anything else as a "condition" as part of a conditional approval.  But it slowly dawned on Racey and Hecht that planners were not going to grant conditional approval this evening, and to gain approval a lot more was needed.  Racey suddenly proposed to do an EIS, with the guidance of Embick for what it would contain.  Whatever it takes to get to DEP's safe shelter.  Hecht proposed a 30-day extension, and when challenged suggested that he could provide a later deadline on Tuesday by phone.  Planners were having no part this, stating correctly an extension was required this evening and that it made no sense to make it 30 days (been there, done that way too many times).  Once planners revealed 90 days would be their preference, Racey and Hecht went for 60 days, and once again the seemingly clueless Racey suggested that after 60 days, an EIS would not be completed but the framework for one would be and a completed EIS could be conditional approval.  Planner Dingle pointed out an EIS with no content to base decisions on would be of no use, echoed by Embick.  Basically, audience members could see that planners were willing to have no part of the short extensions that Synagro has become known for, including meetings in which submissions are received too late for to be reviewed.  Racey and Hecht seemed flustered that their usual routine of one month extensions rope-a-dope was playing out in daylight, and that this move was not going to be acceptable.  The writing was on the wall - someone was coming for their carpet squares, taking away their safe space.

Reckoning day is here

Chairman Levitz put his foot down, and stated that he felt if Synagro was not willing to grant a 90-day extension this evening, then planners should vote on the application in its current state.  The time was now 10:05pm.  After hemming and hawing around, Hecht stated that if these were the two choices, then planners should go ahead and vote.  It took little time for planner Terry Kleintop to read a prepared motion to recommend rejection of the application.  Planner Simpson seconded the motion and the rest is history - until September 19 when the BOS is scheduled to vote on the proposal.

It is hard to believe that Synagro pulled out at this time - they must have known the vote would go against them - as they had made significant progress on multiple points of contention.  They agreed to add several monitoring locations and wells, and even agreed to a Protocol that would shut down the facility if they fall out of compliance.  As Howard Klein has observed above, they likely would never do most of the things they committed to do, would be the same nuisance they are in other communities and were only agreeing to get in the door.  At the same time, their utter lack of courtesy for the planners is inexplicable - both the last minute submissions and refusing to submit materials that were requested.  It's like dealing with a schizophrenic.

The fix is in for Synagro, but how to get past the township?

Synagro's problem is, without the permits from DEP that are needed to make moot one of the variances, they need the local approval or conditional approval that they can not obtain.  As Racey described this conundrum to the planners, an audience member mumbled "your problems are not our problems."  The fact is, Synagro brought this on itself by choosing a site that requires variances.  While Racey was fixated on conditional approval for the DEP, she was blinded to the fact that there were very real serious deficiencies that would prevent said conditional approval.  Wishful thinking?  Denial?  Certainly not a rational approach.  Synagro and Waste Management have very deep pockets, so don't be surprised when this shitshow resurfaces.  This project is worth 10's of millions to Waste Management over the life of the plant - they will be back.  It is clear that Waste Management and Synagro feel that DEP will waive the green flag - the fix is in.  But they never figured out how to use anything but apparent ignorance and legal threats with the planning commission, not even that they needed to submit materials in a timely manner.  The plan from day one was to sweep aside the township as a mere nuisance, and get big daddy DEP to take them across the finish line.  Recall that at meeting one in November 2016, Robert Cornman, Jr was a planning commission member as well as the Green Knight spokesperson for this project, and he did his best to obtain conditional approval that very night.  Just give us what we want, and we'll be a good neighbor.  Just look at Synagro's reputa- oh, yeah, about that.

Assuming the BOS votes the same way as the planners recommend, it could take 6 months or more for an appeal to be heard in the Court of Common Pleas - after a 30 day appeal period.  Will DEP continue to work on the permit applications?  Who the hell knows.

Footnote: Following the meeting, Northampton County Council member Tara Zrinski observed "Plainfield Township is very lucky. Their Planning Commission is extremely strong." The Planning Commission is very strong, and should be commended for remaining focused and professional throughout this ordeal - which began in November 2016.

Plainfield Township planners consider Enforcement, Shutdown and Fines protocol for proposed Synagro crap factory submitted at eleventh hour

On August 30, 2019, five business days prior to what is planned to be the final planning commission review of Synagro's land development plan, Synagro submitted a thick package of updated materials.  This consists of a full set of plans (including modification of a driveway) and truck movement diagrams, as well as over 300 pages of narrative.  Normally, there is a three week requirement for new materials to be submitted, which has been violated multiple times by Synagro.  Chairman Levitz admonished Synagro about this only 3 months ago.  The three week requirement is to allow for consultant review, and review by planners prior to a meeting.  An ethical applicant would extend the deadline (currently September 30, 2019) for a decision, when submitting materials they would like considered with 5 business days notice.  Mr. Levitz' point addressing this issue was, if you want the commission to consider something it is common as well as professional courtesy to submit it in a timely manner.  In this case the township is not dealing with an ethical applicant, so neither of these courtesies are relevant.

Included in the submission is the latest draft of the Nuisance Mitigation Control Plan.  This document is prepared by Synagro by request of the township, and township biosolids consultant Trudy Johnson is the expert who is evaluating its contents as suitable on unsuitable.

While some items in Synagro's late submission may have been new to the township, the township had something up its sleeve for Synagro that it delivered a few days later.  On September 4, Ms. Johnson submitted a document titled "Enforcement/Shutdown Provisions Protocol," which was delivered to Synagro on September 6, 2019.  The lack of finalizing agreement on this Protocol and its inclusion in the NMCP is included in the memorandum of Mr. Petrucci (also delivered on September 6), as a justification for recommending denial of the plan.

Planning commission and audience members as well as Pen Argyl solicitor Peter Layman have expressed concern for months that enforcement may not be effective.  Synagro's proposal in the NMCP would result in a situation where months could go by before any action might be taken to resolve a complaint of odors.  To address this, Ms. Johnson has crafted this Protocol, which includes a table of fines due to lack of compliance.  Synagro isn't going to be enamored of either fines or "shutdown".  This blogger did not find this Protocol in the August 30 version of the NMCP submitted by Synagro (attached below), so it appears to be brand new.  It is only two pages, and presented for your inspection:

Synagro Slate Belt Heat Recovery Center Enforcement/Shutdown Provision Protocol on Scribd

  Enforcement/Shutdown Provision Protocol

Here is Synagro's submission of the NMCP on August 30:

Nuisance Mitigation Control Plan - 8.30.2019 Submission on Scribd

Timeline of key events associated with Synagro's proposed Slate Belt Heat Recovery Center or more colloquially crap bakery in Plainfield Township

A lot has happened since Synagro showed up in Plainfield Township in 2016, and a lot happened prior to 2016 that made it possible for Synagro to even darken the township's door.  The following is a timeline of several key events.  Many of the entries from November 2016 through today happened at planning commission meetings or DEP hearings.  If at another venue this is noted.

This timeline will allow the reader to see a progression in the evolution of the project, and put it in context within the proposed site as well as the community.  What will become clear is that the project has zero support from the community, and is neither wanted nor needed.  While a few members of Green Knight stubbornly continue to promote it as a benefit to the community - the truth has become crystal clear - it will not be.

Some names mentioned below:

• Jim Hecht - Synagro project manager
• Pam Racey - Synagro project representative
• EarthRes - Synagro's engineering consultant
• Thomas Pullar - EarthRes environmental engineer
• Paul Levitz - Planning Commission member and chairman
• Bob Simpson - Planning Commission member
• Robin Dingle - Planning Commission member
• Terry Kleintop - Planning Commission member
• John Reinhart - Former Superintendent of Bangor and Easton Area School Districts
• Slate Belt Rising - Group whose mission it is to promote economic development in the Slate Belt
• Green Knight Economic Development Corporation - non-profit created solely to sell electricity to the grid, by burning landfill gas from Waste Management's  Grand Central Sanitary Landfill.  Green Knight's mission is to benefit the needy in Pen Argyl, Wind Gap and Plainfield Township through economic development
• Green Knight Energy Center - burns landfill gas and generates electricity to sell to the grid
• Peter Albanese - Green Knight member and treasurer
• Robert Cornman, Jr - Green Knight member and Vice President, former Planning Commission member

Timeline

1996 USA Waste Services purchases GCSL from Perin family

1999 Northampton County Industrial Development Authority begins effort to develop the multi-site (2 or 3-lot) Slate Belt Industrial Park (SBIC) on a 19.3 acre parcel now owned by one company - Techo-Bloc.

• NCIDA will develop each site and reap the financial rewards as well as bring jobs to the area.

3/12/1997 Recreation Trail agreement between Plainfield Township and Grand Central Sanitary Landfill

• Purpose is to allow landfill support operations to be located outside the Solid Waste district on land it also owned.
• Intent is trail will be returned to the township when the landfill closes,according to Chairman Leonard Dell'alba statement in BOS minutes.
• Decision is made by the township to not sell the trail property
• Could be used for future connections to other trails Currently, a study is underway to connect Plainfield Township's trail with Wind Gap and Pen Argyl

1998 Waste Management merges with USA Waste Services

3/3/1999 Waste Management attempts to obtain a zoning variance to locate the Energy Center on a portion of Grand Central's land today used as a recycling storage area, outside the Solid Waste zoning district.  The Energy Center is permitted only in the Solid Waste zoning district.

• Bob Cornman, Planning Commission member and Green Knight task force member, testifies before the Zoning Hearing Board in support of the variance "because it will benefit the community," even though the planning commission's responsibility it to maintain the zoning ordinance and zoning map.
• Plan is to supply waste heat from the energy center to support new industries that would locate on Nolin Perin's lot on the north side of Rt 512, or on 3 lots proposed for the current Techo-Bloc site.

10/19/1999 Green Knight Energy Center plan approved and then and recorded at Vol 2000-5 Page 69, with vehicle access from Pen Argyl Road Never constructed - instead unapproved access is from Plainfield Township's trail to this day

4/1/2001 click here Waste Management representative states that selling the Energy Center's waste heat "will be gravy" in addition to the income from selling its electricity

•  GKEDC member Peter Albanese states the objective is to bring a "high-heat consumer to the SBIC site, and that Green Knight had just started soliciting businesses to locate

5/1/2001 Northampton County Industrial Development Authority, owner of SBIC, states that for 2-1/2 to 3 years they have been unable to find any kind of business that wishes to locate on the SBIC site.

• Yet NCIDA asks County Council to issue a bond, so that a shell building can be built on one site. The profit on that building would pay to build a second, and the same to build the third building.
• NCIDA never identifies a single interested buyer.
• Council refuses to issue the bond.

10/3/2002 NCIDA gives up trying to develop SBIC, and JG Petrucci under the name Plainfield Development Co signs a lease for the purpose of developing it.

11/17/2003 The SBIC site is sold to Techo-Bloc.  Petrucci had earlier declined to take on the development, as it didn't meet their desired financial profile.  Northampton County Council minutes reflect at least one member is grateful for the county to "break even".  Green Knight touts this as a great success, though in fact it is mostly a failure as no consumer of Green Knight's waste heat ever appeared, and a private developer ended up making a meager profit on one site instead of the county developing and selling three.

2014 Waste Management procures a use variance to locate a retail natural gas pump on its property despite not meeting several variance requirements, and thus meet the state requirements to obtain $1.6m in grants to convert its trucks to natural gas.  This funds an extension of a natural gas pipeline to the Waste Management property.

• Without this improperly granted variance, there would be no natural gas on site and this project could not happen

2015 Synagro begins discussion with Waste Management and DEP about a possible biosolids facility on Waste Management property

• DEP instructs Synagro to submit a General Waste Management Permit application for the facility
• An Individual Permit requires a Harms and Benefits analysis, a General Permit does not
• The General Permit application ultimately submitted includes the ability for Synagro to sell its product for use as a fuel (eg cement company)

2016 Two Green Knights members resign, and express concerns to confidants that the Synagro project will not be good for their businesses.  Stephen Ruggiero is a funeral director in Pen Argyl, and John T Dally is a real estate agent. Green Knight seeks business leaders for its membership, and if members resign because of what effects a purported economic development may have on their business... you can finish the thought

11/21/2016 Synagro first presents its proposal at a planning commission meeting for site plan review, proposing to locate on the exact same site as the failed proposal to locate the Energy Center.
Synagro's application materials contain a "DO NOT COPY" watermark (Dec 22) - though in the packet is a statement that the public will be involved in all public reviews and the public is not invited
by Synagro to this meeting.

• Robert Cornman, Jr announces that he will recuse himself as a planning commission member since he is representing Green Knight, but participates in the discussion and suggests multiple times from his position on the dais that conditional approval might be possible that evening.  Mr. Cornman, Jr is replaced in January on the Planning Commission by a new member
• Mr. Cornman, Jr does not alert planners that Synagro's proposed use is Solid Waste, and that a use variance was denied on March 3, 1999 for a Solid Waste use on this same land because it is not in the Solid Waste zoning district - a zoning hearing at which he was present and testified for Waste Management.
• Synagro's packet contains a statement that sludge will be received from the "Tristate" area.

12/19/2016 Jim Hecht is quoted in a Morning Call article stating that biosolids will be received from NJ, NY and PA.  He does not mention Connecticut, which is in the Tristate area and 100 miles from Pen Argyl.

2/2/2017 Express Times - John Reinhart cautions citizens to remain vigilant and monitor the actions of the group Slate Belt Rising, considering the ties this economic development group may have to those promoting the Synagro project

• Date unknown - Slate Belt Rising asks Waste Management to increase its funding for a project, and Waste Management says it will if SBR endorses the Synagro proposal.  Slate Belt Rising declines this "offer"

2/14/2017 Express Times - John Reinhardt's guest column published criticizing Green Knights' participation in the Synagro proposal.

• No one wants more waste brought into the Slate Belt
• Maybe a community somewhere wants human waste trucked into it and processed there, but this is not one
• Green Knights is off base with this project - it will destroy its partnerships and reputation
• This is not what anyone thought Green Knight would think economic development in the Slate Belt would be
• Many of us have lived here for generations.  We do not want this project here.

3/1/2017 Pen Argyl Council votes to oppose Synagro's proposed plant

4/2/2017 Lower Mt Bethel Township Board of Supervisors votes to oppose Synagro's proposed plant

4/4/2017  At a Q&A session held by Synagro, Jim Hecht states that trucks would enter and exit the site the same hours as happens at the landfill - 7am to 4pm M-F and 7-9am Sat.

• Synagro was approached by Waste Management
• Jim Hecht can not name one organization that supports the project
• Carlton Snyder states that Green Knight considered "contractual obligations" when choosing to participate in the proposal Did Waste Management leverage Green Knight with a threat to not renew the contract for the energy center - which expired in 2018?  See Peter Albanese's comments on 10/25/2018

4/2/2017 Upper Mt Bethel Township Board of Supervisors votes to oppose Synagro's proposed plant

4/18/2017 Wind Gap Borough Council votes to oppose Synagro's proposed plant

6/12/2017 Plainfield Township issues a determination that Synagro's proposed development requires eight zoning variances.  This includes two that remain to this day.  Synagro has defiantly denied it needs variances and has not filed an application to the Zoning Hearing Board.

8/15/2017 EPA announces that Synagro has signed a consent decree for failure to implement controls of mercury emissions in accordance with tighter EPA standards that went into effect in 2016.  Synagro and partner Waterbury CT pay a fine of $104,000 for failure to comply with the updated standards.  Synagro stated at multiple planning commission meetings that if new standards are enacted, the public can have confidence that Synagro will implement them.  Ha.

11/2017 Synagro announces it will haul its wastewater off site instead of dumping it in the Walz Creek, purportedly to address concerns of citizens The Delaware River Basin Commission would have had to approve a permit for the 80,000 gallons a day that Synagro would produce - this is unlikely to have been approved due to the low volume of flow in the Walz Creek tributary

12/12/2017 Jim Hecht submits a letter confirming that trucks will operate from 7am to 4pm M-F and 7-9am Sat.

2/21/2018 Mr. Hecht states that trucks will enter and exit the site from 6am to 6pm M-Sat.

2/21/2018 Synagro admits that the tarps used to cover the trucks will do not control odors

3/22/2018 Synagro submits an application for an Air Quality permit to DEP, with a false statement at the bottom of page 3 - that Synagro's proposal meets local zoning requirements or has obtained local zoning approvals.  Neither of these is true, but John Goodwin in Engineering at Synagro answered this question in the affirmative.

4/4/2018 Pam Racey states truck traffic 6am to 6pm will be "just weekdays... on weekdays", contradicting Jim Hecht.  Mr. Hecht reiterates truck traffic will be 6am to 6pm, M-Sat

• Jim Hecht We plan to process biosolids at 84 percent waste heat and liquid gas at 16 percent natural gas.
• Terry Kleintop After the landfill closes in 10 to 12 years, there will be no more revenue for Green Knights.  Response from Jim Hecht I have no idea what the contract is between Waste Management and Green Knights is. Green Knight has a contract not with Synagro, but with Waste Management for the pitiful 3.4 cents on the dollar it will receive for its waste heat?  Why is Waste Management involved in Green Knights' agreement to sell its waste heat?
• Thomas Puller The water body is not a pond.. It is a non-discharging engineered sedimentation basin.
• Robert Simpson It is just a pond.  It infiltrates 100 percent.
• Thomas Pullar It is not.  It's a... it's a sedimentation basin.
• Robin Dingle The sedimentation basin infiltrates to groundwater and a lot of wells in the area.

5/31/2018 Lisa Perin - real estate agent - Does this fulfill a need in our community?  The answer is "no",  We can handle our own sludge.  The negatives of this plant outweigh the positives.  Once this is here, you will never see it leave.  This will be forever.  They are putting this here because the regulations are looser than the states where this sludge is coming from.  This is not our problem.  The community absolutely does not want this. Ms. Perin's full statement is here.

• Jim Hecht We can run this plant profitably on 100% natural gas
• Steve Hurni  I just realized something.  Synagro doesn't need our waste heat at all.

7/6/2018 Eric Andreus Nestle Hydrologist submits a letter to a state policy committee studying the use of fill in quarries regarding pollution of an aquifer as a result of a DEP-approved clean fill reclamation at the Slate Hills Quarry in West Bangor

• As a result of the pollution, Nestle had to drill an interceptor well that diverts over 100,000 gallons a day before it can reach Nestle's production wells.  This has continued for years since the pollution was first detected
• DEP must require material to be used for such operations to be thoroughly tested
• Surface and groundwater flows from former quarry pits must be analyzed (hydrogeological analysis) to determine what effects may be experienced down gradient This is what township planners have been requesting for 11 months or more - see 10/8/2018

8/10/2018 Roger Bellas issues a letter stating that a waiver of a Chapter 105 permit will be granted to Synagro for partially filling Sedimentation Basin #2

• Plainfield Township writes a letter 4 days later asking Mr. Bellas to reconsider, which is ignored.

9/11/2018 Plainfield Township appeals Mr. Bellas' 8/10/2018 letter to the Environmental Hearing Board, arguing that the record does not show the proper engineering was done prior to issuing a similar waiver 11 years earlier.

10/8/2018 Robin Dingle and Bob Simpson state that a professional hydrogeologist is needed to determine ground water exchange with the basin.

•  Thomas Pullar responds "I will... can present that information."  In July 2019, Mr. Pullar stated that EarthRes can not determine how much goes to the Walz and how much to the Little Bushkill Creek.  Synagro has still not agreed to do a hydrogeological study of the basin.  Mr. Pullar's "information" on flow, depth of the basin, etc consists solely of estimates and projections - not measurement.

10/25/2018 Peter Albanese at Plainfield Township BOS meeting Green Knights will receive up to $100,000 annually.

• Green Knight just received a 20 year extension of its contract with Waste Management for the Energy Center
• DEP wants more plants like this one. It has become apparent that DEP really "wants" the Synagro plant approved - Plainfield Township Counsel Jack Embick admonished DEP during the August 12, 2019 hearing that it was inappropriate for DEP to have encouraged township officials to approve Synagro's land development plan.
• The sludge is safe - people don't understand this.  There is nothing to be afraid of.  They test it.

11/7/2018 DEP hearing

• Waste Management program director Roger Bellas states that he knows of no hydrogeological study ever being done on Sedimentation Basin #2
• Mr. Bellas states that he reviewed the engineering that was done to previously grant a Chapter 105 waiver, prior to determining that a waiver would again be granted for Synagro to partially fill the basin

11/15/2018 EPA Inspector General releases a report that 352 known pollutants are in sludge, including 61 that are hazardous, for which EPA has no risk assessment. This directly contradicts Mr. Albanese's comment less than 3 weeks earlier.  There are no standards for these 352 pollutants known to be in biosolids.

1/28/2019 Environmental Hearing Board dismisses DEP and Waste Management's attempt to have the lawsuit filed 9/11/2018 finding:

• Grand Central's motion provides almost no contextual or background information on its site or the sedimentation basin addressed in the letter.
• Only the township has taken the time to address in even remote detail what it contends is the function and history of Sedimentation Basin No. 2

2/14/2019 Roger Bellas issues a letter retracting his August 8, 2018 letter, making the township's appeal moot.  Neither Bellas nor DEP ever produced the engineering in question to prove that DEP properly issued the 2007 waiver, which the township argues should prevent a rubber-stamping of issuing a new waiver as the August 8 letter indicated would happen

2/21/2019 Township Environmental Counsel Jack Embick finds that the township has a legal right to require an Environmental Impact Statement, and without one he recommends that the township deny the application

• Mike Brunamonti of BCM engineers, states on behalf of the township that the pond is directly connected with groundwater and therefore it requires additional level of study

3/22/2019 DEP issues a scathing deficiency letter to Synagro, for the permit application to modify the landfill's waste management permit.  This is essentially an NPDES (stormwater) portion of the permit - Sedimentation Basin #2 falls under the DEP's Waste Management permit.

5/23/2019 On-site meeting to discuss Sedimentation Basin #2 deficiencies, and Plainfield Township is invited to attend a meeting starting at 11pm

• At 10am, DEP Wilkes-Barre, DEP Harrisburg, Northampton County Conservation District (drafted deficiency list), Synagro, EarthRes, Waste Management convene a meeting that shows Plainfield Township "joining" at 11am, at the conclusion of discussion of deficiencies
• Plainfield Township's consultants including a hydrologist are kept in a room from 11am to 11:20am, at which time they are permitted to join a meeting that unknown to them has been in progress since 10am.
• Several announcements are made after 11:20am, and Plainfield Township is excluded from the primary discussion of Sedimentation Basin #2's deficiencies.
• Roger Bellas states that a Chapter 105 permit will again be issued.
• DEP has no written record of what actually happened at this meeting(s).  Nothing will be put in writing until permits are issued.

DEP appears to be more concerned about an appeal being filed of something it puts into print, than protecting a natural resource in the township.  It also appears that Mr. Bellas is fully committed to issuing a waiver to fill the pond so that Synagro can operate a biosolids plant - a means to an end and water quality be damned.  Ironically, DEP is cracking the whip for municipalities to reduce sediment in runoff through MS4s, yet spreading biosolids on farmland (by far the greatest contributor to sediment) will create more sedimentation.

7/9/2019 Phil Gray - BCM Engineers hydrologist Found in the middle of the BCM review document embedded in this page

• A hydrogeological study of the pond is needed

8/12/2019 Nolin Perin -DEP hearing - We have to address our problem - this sludge. Mr. Perin's niece Lisa addressed this issue on 5/31/2018, observing to the contrary that the sludge Synagro will receive is not from the area - consistent with Synagro stating it will be from the "Tristate" area.

9/4/2019 Trudy Johnson of Material Matters - biosolids consultant - submits a draft document titled "Enforcement/Shutdown Provisions Protocol", which includes a schedule of fines for failure to comply.  Neither Synagro or the planners are believed to have previously seen this document.  It is on pp. 27-28 of the document found here.  It should inspire some discussion at Monday evening's meeting, as several planners, Peter Layman for Pen Argy, and citizens have expressed concern that Synagro will attend to issues as they arise - something that has not been found to be a strong suit for Synagro.

Green Knight Economic Development Corporation agrees to give away $2.66m worth of waste heat annually in return for $100,000 maximum from Synagro at proposed pond-side crap bakery in Plainfield Township

Green Knight has not been boasting much about how much it will get for its waste heat...

3.4 pennies per dollar - while it lasts...

At the October 25, 2018 township Board of Supervisors workshop, Green Knight treasurer Peter Albanese was asked by Chairman Randy Heard "what are you going to get for your waste heat?"  Mr. Albanese replied "up to $100,000 a year".

Now, Mr. Albanese is the treasurer, so he probably knows his facts when it comes to finances.  Green Knight Vice President Robert Cornman, Jr stated at an August 2019 DEP hearing "between $100,000 and $200,000 a year," but that is likely due to publication of Mr. Albanese's comment.  Note that $100,000 is included in the range Mr. Corman, Jr stated - just at the very bottom.  These are the only two instances that Green Knight has addressed this issue since November 2016 when the project first became known to the community.  It is doubtful that Green Knight renegotiated its contract since Mr. Albanese's statement.  If this project is of such great benefit, Green Knight would publish the contract for all to see, and/or have boasted a lot more than twice about its expected income.

An analysis of the potential income for Waste Management and Synagro was posted here.  It is millions of dollars per year for each.  In that analysis, the cost of natural gas to operate a belt dryer similar to the one proposed for the Synagro plant to dry biosolids with similar water content to Synagro's was found to be $21.67 per wet ton processed.

Synagro will process 400 tons of wet shit a day 24/7, or 146,000 tons a year.  At $21.67 per ton, that is a total cost of $3,163,820 annually using 100% natural gas.

Synagro project manager Jim Hecht has stated multiple times that Synagro plans to run on 84% waste heat and 16% natural gas until the landfill closes (projected 2028 in a Waste Management publication dated 2017).

So, at break even, Synagro would pay 0.84 * $3,163,820 = $2,657,609 for Green Knight's waste heat.  But Green Knight accepted a "maximum of $100,000" for this same quantity of energy - which is 3.4 cents on the dollar.

Green Knight will get 3.4 cents to replace $1 of natural gas - Deal, or No Deal?

In Punta Gorda FL, Synagro gives over $300,000 annually to the community for processing 50,000 wet tons of shit, compared to $100,000 maximum for the 146,000 tons proposed here.  Do the math.  Any way you slice it - including the absurd 100% slop in Mr. Cornman, Jr's range, Green Knights made an absolutely horrible deal.  If the wheels at Green Knight consider this good economic development, well here is a newsflash - it clearly is not.  It is excellent economic development for Waste Management as well as pure corporate greed - and sadly it appears that Green Knights is focused on the interests of Waste Management rather than those of the community.  Recall the only reason Green Knight exists is because Waste Management by utility regulations was unable to sell electricity from its landfill gas to electricity operation to the grid itself.  This project has revealed the true stripes of Green Knight.

Only "green" that remains is potential income for Waste Management and Synagro

It was clear from the first few months that this is not at all the "green" project it is cast to be.  300,000 gallons of toxic wastewater daily first proposed to be disposed of in a creek will be hauled away by tractor trailer.  Then the plant and its handling and traffic operations were moved to within a few feet of a freshwater pond.  The main selling point - Green Knights' waste heat - will no longer be available in only 8 years for a plant designed for a 25-year lifespan.  The product, biosolids pellets containing over 350 known pollutants according to the EPA Inspector General, will be distributed to farmland throughout the area for either free or a very low cost.  Synagro can't give this stuff away in some areas.   Green Knight doesn't even make enough waste heat to power the plant.  After 8 years, the plant will convert to 100% natural gas.

After a planning commission meeting in 2018, at which Jim Hecht admitted that the plant can be profitable running on 100% natural gas (obviously it can, since it will have to after 2030), Green Knight member and Board member Steve Hurni exclaimed "I just realized something.  Synagro doesn't need our waste heat at all!"  Yup - that's correct Steve.

Green Knight is virtually giving away its waste heat, and will get $0 per year after 2030

Green Knight states its mission is to help the economically distressed citizens of the community.  What they have done is sponsor an environmental disaster that will bring malodors, water and air pollution to the community, in exchange for pocket change that is far and away not worth the opportunity cost.  And after 2030, a mere 8 years after the shit factory opens, Green Knight will have nothing to sell to Synagro.  No one would boast about that.

In the late 1990's Pen Argyl Concerned Citizens and later Green Knights were seeking a company that Green Knights could sell its waste energy to in the neighboring industrial district.  A company that would provide many good manufacturing jobs and be a positive economic development for the community,  It became clear after 5 years that no such company would locate nearby,  Waste Management has resurrected the idea strictly out of self interest and reaping millions a year out of its property, not as a benefit to the community.  Green Knight went along, instead of doing the obviously correct thing and saying "no" since this is a glaring negative for the community.  In the process they also struck a deal for 3.4 pennies on the dollar for their waste heat - something they would never have accepted from an unrelated business back in the late 1990's through 2003.  It would be far better to let that heat go up the stack.  John Reinhart was correct in his assessment of Green Knights' choice to get involved in this project - this is bad for the community, and bad for Green Knights.

What's in your wallet?

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.