Meet the only person or entity which has spoken in favor of Synagro's proposed biosolids facility in Plainfield Township, after numerous meetings and a DEP hearing

Synagro has been shuffling its feet since October 2016, with a proposal to build a biosolids processing facility in Plainfield Township, on a small piece of property owned by Waste Management - property that is currently within the permitted bounds of Grand Central Sanitary Landfill.

That is almost 3 years, and in that time it feels like there have been perhaps 16 planning commission meetings and a DEP hearing (November 2018).  When time permits at a planning commission meeting, speakers are allowed at courtesy of the floor.  Let's say that at 10 of the 16 meetings citizens have spoken - and they always do when time permits.

Also, letters have been received from multiple towns regarding the facility - all in objection to it - Wind Gap, Pen Argyl, and Upper Mt Bethel Township and Lower Mt Bethel Township.  Washington Township sent its zoning officer to attend a few meetings, before they fired him because he was doing too good a job.

As the review of Synagro's land development plan finally near its end, it is reasonable to take a pulse to see how well the project fits into the community.  Not a single entity has endorsed this proposal, with the exception of course of Green Knight Economic Development Corporation.  At least as a whole... two members are believed to have resigned since the project was announced, fearing its impact on their standing in the community.  One member has been quoted as saying the proposal is "stupid".  It is said that Slate Belt Rising was asked by Waste Management to support the proposed facility, and since Slate Belt Rising mission is:

"to galvanize the boroughs of Wind Gap, Pen Argyl, Bangor, and Portland to capitalize on their shared heritage and traditions, the natural beauty of the Slate Belt, and the commercial potential provided by the proximity to major roadways in order to increase economic opportunity in the region, reduce poverty, eliminate blight, and improve the overall quality of life."

Slate Belt rising politely declined.  Slate Belt rising knows a pile of shit when they smell it.

Early in this process, former Bangor School Superintendent John Reinhardt submitted a succinct letter to the editor explaining just how bad the proposed facility would be for the Slate Belt region.

Meet the only public (but biased) supporter of Synagro's proposal

Nolin Perin - only person or unrelated organization

to have supported Synagro's proposal

Standing in front of RPM Recycling automobile waste (fluff)

A poll of attendees of planning commission meetings resulted in no one recalling a single speaker since October 2016 at courtesy of the floor speaking in favor of the proposal.  No organization has supported it.  Only one speaker - at the November 2018 DEP hearing - has said anything positive about it, Nolin Perin (son of landfill founder Robert Perin).  Here is the transcript of Mr. Perin's comments:

"MR. PERIN: Good evening. My name is Nolin Perin, and I reside at 253 Meadow Lane, Pen Argyl, Pennsylvania about a mile or so southeast from the proposed facility.  I have a lifelong involvement with the waste industry, landfill and waste hauling side of the business. We only have a few options now. We can recycle, have direct contact with the land as was done with mine reclamation. We can landfill it, or we can recycle it and turn it into useful products. While the last works fairly, well, it is limited to about half the days of the year due to weather consideration. And the sheer amount of materials excuse me a minute. And the sheer amount of land necessary for the landfill creates some other issues, exposing that water to the landfill and making it more contaminated. My  professional opinion is recycle material. These types of facilities reverse the process. My home is close to the proposed facility, and I have no personal objection to it being built, nor do I state an objection. In regard to health issues, I do not think the proposed facility is a threat. That facility has nothing to do with our communities.  Our friends and neighbors are working the sewage treatment plants, and we have several septic tanks in the area. Who's getting sick? What is being handled is raw sewage. I don't see anyone getting sick.

Thank you."

Mr. Perin is not concerned about processing 400 tons of sewage a day right next to a freshwater pond.  But he is hardly unbiased.  First of all, his son Scott Perin is in management at Waste Management, and is attending all the Synagro review meetings.  Mr. Perin has a self-described "lifelong involvement" with waste.   He knows waste like Santa Claus knows presents and reindeer.  He probably dreams about waste.  While this is not exactly a ringing endorsement ("I have no objection to it"), it is the closest thing to someone saying this proposal will be good for the community.   But he didn't say it would be good for the community.  That isn't close at all.  Contrast to niece Lisa Perin, who gave planners and the audience an earful of reasons the proposed plant will be bad for the community when she spoke at a meeting.  Ms. Perin isn't fulfilled by waste - she is a Realtor.

Mr. Perin's apparent lack of concern for water quality is not new

The picture above of Mr. Perin was taken when he was a partner in RPM Recycling (now RPM Metals under different ownership) in Wind Gap with Joseph Raimo and George Miller, which ground up vehicles to reclaim metal.  The shredded "fluff" that results contains all kinds of toxic materials.  Mercury, is one example.  RPM cited the cost involved to completely strip vehicles before shredding as an excuse of why propane cylinders concealed in vehicles were frequently causing explosions that irritated residents, so it is not clear how completely vehicles were prepared to reduce toxins.  Fluff is hot after grinding, so piles of the stuff are a hazard and spontaneously combust and there have been fires at the facility.  RPM stated in its development plan that fluff would be removed in roll-off containers - no provision was made or approved to store it on site... or stockpile it next door.

In 2011, the following pictures were taken on a lot that Mr. Perin's company NAPER owns, as well as a lot that Grand Central Sanitation owns, which are adjacent to the RPM facility.  This is a former L&NE rail yard - nice and long and flat and a great place to stockpile fluff if it were not toxic and a huge fire hazard.  The first picture shows the direction and location of the four pictures that follow.  RPM's facility is on the left.  The red lines enclose rows of fluff 15-20' tall that are over a thousand feet long in total (scale is shown).  Note that in View 3, cattails are visible between rows of fluff; cattails are found in hydric soils and wetlands.

View 1 - RPM equipment seen at rear

View 2

View 3

View 4

The Plainfield Township Zoning Officer issued a violation notice, to which Mssrs. Perin and Raimo sent replies.  Mr. Raimo cites the reason for stockpiling fluff, is that to make more money RPM wishes to reprocess it.  Incredibly, he argues that it "would be very ungreen" to not get the last bit of metal from the waste.  But it certainly isn't "green" to leave it on the ground for months, leeching untold amounts of toxins into surface water and the ground.  The only green that is of concern here is obvious.

Notice of violation - stockpiling of flammable materials

Mr, Perin's response

Mr. Raimo's response

Plainfield Township issued a cease and desist order to RPM Recycling in 2012 over the unpermitted stockpiling of fluff.

The total lack of support over almost 3 years shows Synagro's project is in fact "stupid".  It has been proven that it isn't green, which was the calling card used to justify its existence.  Stupid on a good day, a real nuisance and threat to the quality of life of our residents otherwise.  A majority of voting members of Green Knight went along with this plan - possibly under duress since their contract for their facility with Waste Management was renewed after this project was announced.  The only person or entity who on paper is not connected with the project, and who supports it, is the son of the host landfill's founder and a self described lifelong manipulator of waste.

Slate Belt Rising is made up of people who travel in the same circle as Green Knights, but it isn't tied at the hip to Waste Management like Green Knights is.  Do the math.

Letters from Plainfield Township consultants in regards to Synagro crap bakery received for the July 11, 2019 land development review meeting

As posted earlier, the planning commission did not have sufficient time to review all the reviews from its consultants prior to the July 11 meeting - in fact one review came in after the 11th.  These review letters are shown below:

• Email from Mike Brunamonti BCM June 17
• Letter from Mike Brunamonti BCM June 21
• Letter from Mike Brunamonti/Phil Gray BCM July 9
• Letter from Bob Lynn Hanover Engineering July 11
• Letter from Jason Smith Hanover Engineering July 16
• Letter from Trudy Johnston Material Matters June 18
• Letter from Trudy Johnston Material Matters July 10
• Legal Memorandum from Jack Embick legal counsel July 10

The letters from Phil Gray and Jack Embick are among the most important, in that Phil Gray calls for a hydrogeological study of the pond, and Embick unequivocally believes that it is proper to require an Environmental Impact Study.

BCM Engineers Brunamonti to... on Scribd

BCM Engineers Brunamonti Re... on Scribd

BCM Engineers Review July 9... on Scribd

Bob Lynn Hanover July 11 Re... on Scribd

Jason Smith Hanover Review ... on Scribd

Material Matters June 18 on Scribd

Material Matters July 10 on Scribd

Embick July 10 Legal Memora... on Scribd

Synagro submits new materials for Plainfield Township crap bakery, causing planned "final" review meeting scheduled for today to be postponed

The expected final planning commission review meeting scheduled for this evening has been postponed, because of a new submission by Synagro that appears intended to address issues that remained open after the July 11 meeting.  The submission is dated July 29th.

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.

Edit - see the consultants' letters at this link

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)