The July 11 meeting
On July 11, the Plainfield Township planning commission held what was proposed to be the second to last meeting, prior to making a recommendation to the BOS on whether to conditionally approve or deny Synagro's land development plan for a sludge processing plant. This plant would be located on land leased from Waste Management - land that currently is within the permitted area of the Grand Central Sanitary Landfill. Fuel for the plant would be a combination of waste heat from the landfill gas to energy Green Knights plant adjacent to the proposed site, and either landfill gas or natural gas. Synagro has estimated it will use approximately 85% waste heat, in addition to 15% natural gas, prior to the landfill closing in approximately 2030 and waste energy and then landfill gas no longer being available. The plant will then transition to 100% natural gas.
When planners arrived for the July 11 meeting, they were greeted with a 2" thick packet submitted by Synagro that is dated July 2, 2019 - which obviously they had no time to review. In addition, they had review letters from township consultants dated July 9 through July 11, which the consultants had rushed to turn around based on the July 2 Synagro submission. Township manager Tom Petrucci announced at the beginning of the meeting a tentative schedule, which is driven by negotiations with the Applicant to grant extensions of the deadline for a decision. Apparently Synagro's position is it wants a decision by August 31, which was announced to be the new deadline. To meet this deadline, Mr. Petrucci announced tentative dates of August 1 for the last planning commission meeting, and August 22 for the board meeting at which the planners' recommendation would be considered and a vote made.
Planning Commission Chairman Paul Levitz made an announcement midway through the meeting on the difficulty Synagro's continued lengthy and late submissions are causing. Mr. Levitz was very professional, as he made the point that Synagro is not submitting materials in a timely manner so they can be reviewed prior to the next meeting. This has been a continuous cycle over the majority of meetings. Yet Synagro wants a recommendation from the planners. The bottom line is, there are several open issues, and Synagro appears to be demanding a vote by August 31. It is a lot to expect these issues to be resolved, and a list of conditions for approval or reasons for denial, in the only meeting that is left according to the schedule laid out at the beginning of the meeting.
What happened at the meeting
The first hour and a quarter was wasted by Synagro, giving a presentation on why once again they don't believe they need to do an Environmental Impact Study, how they believe their plan provides for prevention and remedy in case of pollution of ground water. Of course those two are contradictory. They also stated they had no idea of how much flow occurs between the pond and the Waltz Creek, versus the Little Bushkill Creek - both High Quality waters of Pennsylvania. A hydrogeological study as part of an EIS would let everyone know. Syngaro also stated that over time they would seek permission from DEP to reduce sampling - which concerned the planners.
After the presentation, only review letters from BCM dated July 9 were discussed. While Mike Brunamonti from BCM recommended that additional Water Quality testing be done from what has been proposed, and at a greater frequency, Synagro felt that the testing required by DEP was sufficient. The planners took BCM's recommendation one step further, as more than one recommended testing four times a year for as long as the plant operates - whereas Synago stated it would seek to eliminate some water testing completely after a certain amount of time. Planners were concerned that it could take several months for an issue to be detected and corrective action begun, as well as once contamination occurs the damage is done. The risk of contamination does not change over time, so why should the testing frequency be reduced?
A second letter from BCM, authored by geologist Phil Gray was also discussed. This letter is significant, in that Mr. Gray (not present at the meeting) recommends detailed hydrogeological testing be done near and in the pond. Planner Bob Simpson pointed out that this is the kind of testing that he and others recommended many months ago, and that it could have been done by now but Synagro refused to do it.
Planner Kleintop brought up a concern over the results of ongoing macro-invertebrate testing that has been required by DEP that Waste Management do on the Little Bushkill Creek tributary near the landfill. Scores near 50% have been recorded, which is the bare minimum for attainment. Also, no mayflies have been found, which is an indication of health of a watershed. Planner Dingle made a recommendation that a location of macro testing be added for Waltz Creek, which Synagro stated it does not feel is necessary.
Letters received from Material Matters on the Nuisance Mitigation Control Plan (NMCP) were not discussed, nor a letter from legal counsel Jack Embick on the legality of requiring an Environmental Impact Statement. At courtesy of the floor, Solicitor Peter Layman stated that the reviews reflect that many items in the NMCP have been resolved, but some significant ones remain. Near the beginning of the meeting, Mr. Petrucci had announced that the township believes two variances, SALDO relief for violation of Riparian Buffer requirements, and the lack of the EIS are outstanding issues.
Courtesy of the floor statements
Peter Layman stated that Pen Argyl would like to have Synagro's contracts with haulers reviewed, which naturally was objected to by Synagro. Mr. Layman, as a lawyer, believes this is possible. Pen Argyl's principle concern is the trucks that will be delivering shit to the crap bakery. Synagro stated that issues related to truck trafficare taken care of in the NMCP. Earlier in the meeting, there was some discussion that Synagro could mix lime into shipments that are found to be particularly odorous. It was also stated that Synagro's contracts call for hauling waste, regardless of the status of the receiving plant. Thus, if the crap bakery is shut down for any issue, Synagro is obligated to haul the waste that would normally be headed to the bakery and dispose of it elsewhere.
Alan Stangle - how do you know what is in it? how much is it heated, and is does this burn off compounds? (No it does not - it is primarily to reduce the 75% to 80% water content)
Howard Klein - you have to know where to look on Synagro's trucks for a number that identifies that load - the numbers are on the back of the cab or front of the trailer, not the back. Even with a number, you have no idea what the source was. (Pam Racey of Synagro stated that Synagro knows what the source is - but would they reveal it in the event of a stinky semi rolling through town?)
Don Moore - letters written by Waste Management lawyers have been submitted objecting to various initiatives the township is currently pursuing - an official map, a zoning ordinance amendment. Also, a trail connection that is being pursued Waste Management assumes will not involve the section of trail covered by an easement agreement that allows the dump to use until it closes. This is our town, and Waste Management is shoving us around in multiple ways. These people don't live here. Green Knight struck a terrible deal in agreeing to receiving a maximum of $100,000 a year, considering that Synagro's facility Charlotte County Bio-Recycling pays the community of Punta Borda FL nine times as much on a per ton processed basis according to Synagro's own website ($300,000 for 136 tons daily vs $100,000 for 400 tons daily). Synagro has stated to planners that if a new substance is regulated - only 9 or 10 currently are, while the November 2018 EPA inspector General report states that 352 known pollutants in biosolids have not even been assessed for risk - that Synagro will test for it. But in 2016, the EPA updated its Mercury emissions regulations, and Synagro's Waterbury CT plant failed to comply and Synagro had to be sued before it complied with the new requirements. Synagro entered into a consent decree in 2017 and paid a fine. Moore stated he therefore has no faith in Synagro's pledge that it will comply with new regulations. Board of Supervisors minutes from 1996 and 1997 show that residents wanted the township to retain the section of trail covered by the easement, and one resident foresaw the use of that trail section to make connections to other trails possible, as is now being pursued in 2019.
Millie Beahn - this is our community, my community. I grew up here. Something like this can change the community, we must consider the impacts. (Granddaughter Lisa Perin of the Grand Central Sanitary Landfill founder spoke at length last year how negatively this facility would impact the community - see a transcript of her comments here)
Justin Huratiak - what ever happened with the road access issue? The last information was that PennDOT will not allow access from Pen Argyl Rd. (It appears that access will be solely from Route 512, since PennDOT will not issue a permit for access from Pen Argyl Rd for daily use)
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