From October 8, 2018, an interchange between citizen Jerry Lennon and Synagro rep Jim Hecht
MR. HECHT: ....So an independent tractor driver, you know, you would not see that on the trailer, but it would be our material, so you would call us.
INTERESTED CITIZEN: Also carry a sign on the back saying carrying hazardous waste?
MR. HECHT: No, it is not hazardous waste
INTERESTED CITIZEN: That's up for debate.From May 31, 2018, an interchange between citizen Gail Weber and Synagro rep Pam Racey
MS. RACEY: There's an annual scan for TCLP there is a list, don't know how long the list what's called TCLP which tests for a whole bunch of different parameters. That is required at a less frequent level because typically these things aren't found in biosolids. But in order to demonstrate that there's no contaminants of a hazardous nature, you have to do what's called a TCLP, usually on an annual basis. If it'S a small plant it might be biannual.
MS. RACEY: We're only going to be able to take in material that meets a certain criteria. If there's a plant that produce biosolids that have a higher level of pollutants, we're not going to be able to take them.INTERESTED CITIZEN: By pollutants, do you mean pathogens?
MS. RACEY, Metals.
INTERESTED CITIZEN: What about other contaminants?
MS. RACEY: Or organics. Like I said,TCLP there is a list, don't know how long the list is, it's quite long. It's called TCLP.
INTERESTED CITIZEN: I don't think this is the right place for it. I agree with the other gentleman that said about the pond. Who was the man that said about the pond? I have concern about that quarry that you've changed into to what is the runoff, the runoff sedimentation basin?Few observers agree that Synagro's raw (Class B) or finished materials (Class A pellets) are benign or safe for the environment. Citizen Steve Demaris is knowledgeable about the subject, and he expressed his assessment that Synagro's raw materials are hazardous on May 31, 2018:
INTERESTED CITIZEN: D-E-M-A-R-I-S I want to clear some points up. They say this thing is not hazardous. I'm going to quote you from 503 regulations. They say it's not hazardous or anything. I'm going to quote from the law, 503 regulations, right? Biosolids is described as a pollutant, right? And under 503 regulations it says. pollutant is an organic substance -- an inorganic substance. A combination of organic substance or inorganic substance or pathogen organic -- organism, excuse me, that after discharge. that means after treatment, upon exposure, ingested, inhaled, assimilated into the organism either directly or from the environment or indirectly by ingesting through the food chain. It means this bio stuff, the chemicals, the pathogens in biosolids. Can regrow and enter the food chain. This is stuff they're not telling you. On the basis of the information available to the administrator, that means the EPA, could cause death, disease, behavioral abnormalities, cancer, genetic mutations, psychological malfunctions, including malfunction of the reproduction organs, physical deformities in either organisms or offspring of that organism. That means your children. So this is the stuff that the law -- the law says. And it's even in the beneficial -- Title 25, 271, the beneficial use under the PA law states this. So don't tell me that it's not hazardous when the law tells me that it is.
..........
Another thing, the location that this is being built on was a backfill quarry, which means water would drain from this. That means sinkholes there, from the shale and stuff falling back into where the water would drain. I suggest that the environmental study include to see if ducts have formed that it doesn't affect wells in the area, especially because they wash the trucks in the same area as this backfill quarry, and contamination could happen, right?And under the law, the problem is with this company, is almost every state they've been in, even when they've been told by EPA, right, that they would violate the law doing this, it seems like they'd rather pay the fine than follow the regulations.On Mr. Demaris' last point, at the July 11, 2019 review citizen Don Moore pointed out his concern that as recently as 2017 Synagro paid a fine and entered into a consent decree with the EPA for failure to install equipment to control mercury emissions in accordance with updated EPA standards at its Waterbury CT biosolids plant. Wait to be caught violating the law, then pay a fine and move on.
Transcripts of several review meetings held in 2018 are located here. Also, minutes of planning commission meetings are located here.
Green Knights representative also maintains that biosolids are safe
At the October 10, 2018 Plainfield Township Board of Supervisors meeting, Green Knight Treasurer Peter Albanese stated multiple times that biosolids are safe, and suggested that people who do not believe they are "don't know". "The biosolids go through testing... there are standards" he maintained. Green Knight runs the landfill gas to energy center that will be giving its waste energy to Synagro - almost literally at the $100,000 maximum Mr. Albanese stated they will receive from Synagro annually.
First of all, the biosolids appear to be tested only once a year or every other year according to Ms. Racey's testimony above. What's in your wallet? And it gets worse...
November 15, 2018 EPA Inspector General Report
"EPA Unable to Assess the Impact of Hundreds of Unregulated Pollutants in Land-Applied Biosolids on Human Health and the Environment"
This report by the EPA Inspector General found that 352 pollutants known to be found in biosolids have no risk assessment. That sounds really bad, and it is. Here is an excerpt from the report:
EPA Inspector General found 61 hazardous pollutants in biosolids
- not one of which has been assessed for risk -
Of the 352 pollutants found in biosolids that EPA has no risk assessment for, 32 are "hazardous wastes," four of which are "acutely hazardous". "16 are NIOSH hazardous drugs", and 61 total are hazardous. If the EPA has no risk assessment for these they aren't being tested for. The claims of Synagro and Green Knight sound a bit hollow once the corner of the carpet is lifted.
Environmental PFOA and PFAS contaminant research and regulation is only in its infancy
As noted in the highlighted text above, PFOA and PFAS are found in biosolids. Several state governments are attempting to develop regulations for PFOA and PFAS, as found in various materials including biosolids; Maine and Pennsylvania are two examples.
In the past week an article was published that quotes none other than Tracy Carluccio, the Deputy Director of Delaware Riverkeeper Network, which is monitoring the Synagro application carefully and has objected to the project. This is the first article in the following list, which is is a sampling of recent articles that discuss PFOA and PFAS and biosolids. Note that the EPA released a "technical brief" only a few months ago in which it is stated that the EPA is "developing analytical methods for analyzing PFAS in biosolids" - which means they don't currently have them (!)
- "Waste containing PFAS chemicals poses conundrums" Aug 2, 2019 https://www.theintell.com/news/20190802/waste-containing-pfas-chemicals-poses-conundrums
- "EPA Technical Brief Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)" June 6, 2019 https://www.epa.gov/sites/production/files/2019-02/documents/pfas_methods_tech_brief_28feb19_update.pdf
- "Another reason biosolids should never be used as fertilizer" Aug 6, 2018 https://content.sierraclub.org/grassrootsnetwork/team-news/2018/08/another-reason-biosolids-should-never-be-used-fertilizer-pfas
- "Managing Organics in the "PFAS" Age" August 2018 https://www.biocycle.net/2018/08/07/managing-organics-pfas-age/
- "PFAS and Organic Residuals Management" July 2018 https://www.biocycle.net/2018/07/06/pfas-organic-residuals-management/
In conclusion, what do you think? Are biosolids "safe"?
