Sunday, January 27, 2019

Deficiencies in Synagro Land Development Plan to be reviewed at Tuesday Planning Commission meeting in Plainfield Township

--- RESCHEDULED TO FEBRUARY 21, 2019 ----

Reports from the various consultants working to assist Plainfield Township planners in assessing compliance with the Zoning Ordinance and SALDO (subdivision and land development ordinance) are on the agenda to be reviewed on Tuesday, January 29, at 7pm at the Plainfield Township Fire Company on Sullivan Trail in Wind Gap.


These are attached below, and include:
  • Material Matters remaining deficiencies in Nuisance Mitigation Plan dated Dec 17
  • Benchmark Civil Engineering traffic review dated Dec 21
  • Plainfield Township Zoning Office review dated Dec 21
  • Material Matters general comments on application dated Dec 28
  • BCM Engineers comments dated Jan 17
  • Hanover Engineering general zoning comments (Robert Lynn) dated Jan 17
  • Hanover Engineering wetlands specialist comments (Jason Smith) dated Jan 18
The challenge for Plainfield's planners is to figure out what to do with this hefty pile of crap.  Synagro has refused to accept that the township Zoning Office has determined that variances are required*.   Any other Applicant would either walk away (Synagro can't possibly show the hardship needed for the variances), or file an Application for an Interpretation and in the alternative a Variance with the Zoning Hearing Board.  Synagro has done neither.  The Zoning Hearing Board is the venue to determine if the Zoning Officer erred in determining that a variance is required, so it is unclear what Synagro's strategy is.  Sooner or later, they will have to appear before the ZHB.  

*In its December 21, 2018 review, the Zoning Office identified a third variance that may be required - see the very bottom of this post for an explanation.

Why did Synagro and Waste Management spend hundreds of thousands of dollars on an application in which the Zoning Officer has determined that Synagro can't even access the proposed site?  The answer is this plant will be highly lucrative and it is impossible to find locations that permit such a shit factory.  This opportunity is too damned good to pass on, and a three or four hundred grand is nothing in comparison to the income this would generate for both Synagro and Waste Management.

On Tuesday evening, the charade will continue, as planners begin the process of plowing through the reports listed above.

Endgame

How does this end?  Currently, Synagro has allowed through February 28th for planners to finish their review and make a recommendation.  This will not be sufficient.  The reviews pending discussion have found significant deficiencies remain, and when the planners are ready to discuss a recommendation it will likely require more than one meeting to agree on its terms.  Planners have two choices when the make their recommendation on the Preliminary Land Development Plan:
  • Recommend approval of the Plan, with a lengthy list of conditions that all reamining deficiencies be addressed and additional conditions be met (for example)
  • Recommend the BOS deny the plan, with justifications
It will likely require at least three more meetings including the Tuesday meeting for this shitshow to reach a conclusion.
Update: The deadline for a decision from the planning commission has been extended by Synagro to March 31.

Reviews on tap to be discussed Tuesday











Third variance identified in Zoning Office review letter dated Dec 21

In the Synagro application for a General Permit for its facility (click to see document), Form L contains a Contingency Plan in case of emergencies.   There are several references in Form L, including Form L Figure 2 Facility Plan (pdf page 99 in the document linked to), to sulfuric acid and sodium hydroxide being stored in above ground storage tanks (ASTs) "adjacent to" the dryer building - outside.  Plainfield's ordinance permits above ground storage tanks of up to 600 gallons of regulated liquids.  Note that Synagro's site plan being reviewed by township planners does not show these tanks outside the building, and in other places the tanks are shown inside the drier building.

Graphic in Synagro's DEP General Permit application - Form L Figure 2

At a minimum, Synagro would need to inform DEP that its Contingency Plan isn't accurate if the AST's are inside.  A portion of the text of Form L is shown below:

Wednesday, January 23, 2019

Testimony of Lisa Perin, granddaughter of Grand Central Landfill founder, explains why Synagro plant would be never-ending negative value-added nuisance for Slate Belt

At a planning commission review of Synagro's shit bakery proposed in Plainfield Township, the granddaughter of Grand Central Sanitary Landfill's founder spoke at courtesy of the floor.  Lisa Perin, who lives adjacent to the landfill, spoke at length and from her unique perspective.  She itemized several ways in her opinion that the proposed project would be horrible for the community.

Lisa Perin

Ms. Perin appeared at only at this one meeting, but her comments reflect an understanding as someone who as she put it "heard trash talk at the dinner table."  On one point she was not familiar - that natural gas is available on the site currently, and will be used both as a supplementary energy source from inception as well as the sole source once the landfill closes and landfill gas ceases to be produced.  Once she learned this is the case, she immediately integrated the consequences of this for the community - it will be fucked.if this plant is built.  Ms. Perin also assumed the jobs would all be truck drivers, which ignores the fact there will be a couple of shit pushers in the building.

Ms. Perin's complete testimony,is below, with key phrases emphasized.

CHAIRPERSON: Lisa Perin.

INTERESTED CITIZEN: So I have two reasons for being here tonight. One is I live in extremely close proximity to the proposed facility.  I actually live on Grand Central Road. And if you walk out my front door from here to that wall back there. I'm looking at the current leachate tanks which don't bother me because I know how they’re controlled. But I do live close enough to this that it concerns me.

And the second reason is that I have a little bit of inside knowledge on the landfill industry given that my grandfather, Robert Perin, was the founder of GCS and my father. Ronald Perin, the late Ronald Perin, was the president until ‘95 when it was sold.

So just to give you a little insight on the litmus test that I’m using in my mind, I'm going to tell you how GCS started very briefly.

In the 1960’s the local town mayors came to visit my grandfather Bobby because they desperately needed a place to put their garbage. Having already asked several local farmers who turned them down and him being in the excavating business with holes in his ground, they felt that it was a good fit. He actually turned them down, he didn't want to do it. A little known fact.

They begged him to take the garbage because they had a great need for the local community. Eventually he decided to do it and here we are today how many years later.

So my litmus test here is that whether or not you like the landfill or not, it has provided hundreds of jobs over the years, a significant amount of additional tax revenue and has fulfilled a need for this community directly.

When I look at the proposed sludge plant, and I do -- now I'm a Perin, so there's a great deal of people who are very surprised that I'm against it. When I look at the sludge plant, it does not pass the litmus test in my mind. Does it provide enough jobs to outweigh the negative factors? No, not in my mind.

I believe that it was going to provide approximately 16 trucking jobs. So let's just discuss that real briefly. I think you used the phrase, family sustaining wages. 16 jobs that would provide family sustaining wages. I'd really like to know what your definition of family sustaining wages is, because I know what truck drivers make. And if you take out the taxes and you consider the
skyrocketing rents around here, you can't rent something for under a thousand that's decent here anymore. There's no standard on wages that these truck drivers are going to get paid.

How much revenue, if any, will be passed on to the community? The landfill via tipping fees provides a great deal of money to the community.  Yes, mostly to Plainfield Township.  I understand that's a bane of contention over the years.  But we do have things like the -- now the Slate Belt Regional Police Department, which was originally built with Plainfield funds, a lot of which came from the landfill. That's the reason that they have such a nice police department and the reason that is the one that you ended up using.

We don't know how much this is going to provide to the community. I don't believe there has been any answer. I do know that it's going to benefit Synagro. I do know that it's going to benefit Waste Management greatly. I do know that there's an awful lot of money being sent here today.

It was learned later the answer is "Up to $100,000 annually" total for Wind Gap, Plainfield Township, and Pen Argyl according to a Green Knight Treasurer Peter Albanese.  Millions of dollars for Synagro and Waste Management.  Ms. Perin is deftly explaining that this is a lose-lose for the community while the perpetrators profit handsomely.

There's attorneys racking up hundreds of dollars an hour, research and development, people flying in. I'm sure Synagro paid for all of them to drive up or fly in from wherever they came from.  They're spending an awful lot of money because it's going to be extremely profitable for them. Is it going to be profitable for this community? Not enough to outweigh the negative factors.

Does it fulfill a need in our community? The answer is no. Our sewer plants are currently able to handle what we process and provide in sewage in this area. We're taking in sewage from other communities. And let's face it, it's probably the very large cities that cannot process their sewage fast enough, which is also a great concern.

I realize that as far as this goes tonight, everything is very technical, dust control, odor control, there's a lot of things that you have to consider in approving this.

And I do understand that from a technical point, but I would like to point something out to you. The most important thing you should be considering here is whether or not your community wants this, not whether it passes X. Y, Z zoning and department of environmental protection issues. Does your community want this, should be the number one most important question in your mind.

Does it provide a service for your community?  No.  Does your community want it? No.  Overwhelmingly I know that you're aware that this community absolutely does not want it. If you put it to a public vote, which I actually believe that you should, you already know in your hearts and your minds that the overwhelming vote would be against it.

You are here to represent the people of this township. And I really hope that you take some of what I'm saying into consideration tonight and take some weight from the fact that I am who I am and I know what I know from family experience.

I'd like to add one more thing, and I know that you had a comment on courtesy, so I'm going to try co say this as courteously as possible to you, ma'am. I'm sorry, I don't remember your name because I came in after you introduced yourself.

I respect how long you've done your job. I can hear the mumbling because I sat in the back row at the number of times that you answered I don't know or I will have to set back to you. And this is no disrespect. I'm just pointing out that it is disconcerting to the people sitting in the audience that if you have 30 years of experience, you should be able to answer the questions off the top of your head or most of them, instead of continually saying I don't know. I'll have to check, or I'll get back to you.

How can you not know off the top of your head how many odor complaints there have been at a facility that is not near something else creating a smell?

You don't really need -- I mean, you can answer that if you want. Hold on, I'1l be finished in a second.

In closing, I would like to add one more thing because I did learn tonight that it supposedly only has a 20-year life span which is something new to me. But I would like to point something out to you from the Perin point of view because I sat around the family table many nights growing up listening to the inside conversations that were going on when the landfill was always applying for expansions and here fighting for expansions.

It is well-known in the private circles inside the landfill industry that it is far easier to expand a landfill than it is to create a new one. I would like you to apply that to this here, because you can say that it's only going to have a 20-year life span because the energy produced by the landfill is going to decrease over time after the landfill closes.

But how do you know by the time that comes that they aren't going to find another energy source? Because you need to take into consideration that the reason that they're spending so much on attorneys and research and development and spending time here is because it's really hard to open a new sludge plant and they're going to find a way to extend this one via a new energy source because that will be easier in 20 years than it will be to open another new one. And by then all this will long have been forgotten.

Please take those things into consideration. This may not be the 20 years that you're expecting it to be. A landfill has a time limit. At a certain point it can no longer expand.  It has nowhere to go. This will not just be 20 years, and I'm guaranteeing you that tonight, based on what I know of expanding landfills.

And I apologize in advance to my cousin Scott who works for Waste Management, him and I are on opposite ends of the spectrum on this, but I still love you. I thank you very much for your time.

If you would like to answer the question that I asked you about the number of odor complaints, I believe you previously answered that you have to check.

MS. RACEY: Sure. I mean, particularly in a setting like this, you want to be accurate, right? Because you don't to come back and say. oh, you said this or you said that. And, you know, we operate 500 projects across the country.  I can’t know everything that happened ever everywhere. Off the top of my head the answer is, no, there haven’t been any, but I want to check that because I care about being accurate.

INTERESTED CITIZEN: I do, too, because I live within a very close distance and have well water and I would like to make sure that my children aren't showering and drinking that. And I thank you very much for your time tonight. Thank you.

MR. KLEINTOP: Ms. Perin, for your information, the landfill has been using natural gas for probably five, six years already. And if you been here earlier, you would hear Synagro tell you that they plan on already using 16 percent natural gas. So they're set up to go. When the landfill can't provide waste heat, it's already in place.

INTERESTED CITIZEN: You're saying that when the landfill can no longer provide the heat, they're going to cease operating?

MR. KLEINTOP: No, they're going to convert over 100 percent to natural gas.

INTERESTED CITIZEN: Then how can it be 20 years? They're saying it can only be 20 years. In all honesty, it's going to be much longer than that. It's probably never going to cease.

MR. KLEINTOP: I don't believe they're saying they're going to operate the plant for 20 years. They base their return on investment on a plant operating 20 years. Now, they can step in any time they like. I don't believe they were saying they were going to close up shop at the end of 20 years.

MS. RACEY: You're correct. The economic analysis for the plan was on a 20-year basis. After that point we would assess, you know, is there a business case to stay open going forward. 


INTERESTED CITIZEN: And the answer, as I said, will most likely be, yes, because it will be easier to continue the existing facility than it will be to open a new one. So, therefore, many years after the landfill has closed, this will be indefinite. You need to keep that in your mind.  This will likely be indefinite and forever. There will be no ending to it.


CHAIRPERSON: Thank you.
May 31, 2018

In the course of numerous planning commission reviews from November 2016 through December 2019,  as well as a DEP hearing in November 2018, over one hundred citizen witnesses including Ms. Perin have spoken at courtesy of the floor.  Every single witness has spoken in objection to the proposed plant.  To close this post, we have the testimony of Ms. Perin's uncle, Nolan Perin, who is the single witness in that time to have spoken "neutrally" - he stated he is not for or against it, but you can tell from his comments his true feelings - the Slate Belt should get its hands dirty "recycling" someone else's shit.

MR. PERIN: Good evening. My name is Nolan 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 the 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.
Nov 7, 2018 


Tuesday, December 18, 2018

EPA Office of Inspector General reports that 352 unregulated pollutants are in land-applied biosolids like Synagro's Slate Belt plant would produce

On November 15, the Office of the Inspector General of the EPA issued a report whose findings are contrary to what Synagro and Green Knight have been claiming about the Class A biosolids that Synagro proposes to produce in Plainfield Township - that the product poses no risk to humans.   Synagro will test for only what it is required to test for - they have stated this numerous times during the Planning Commission review of its site plan and land development plan.  When asked if they would test for more pollutants, the answer from project manager Jim Hecht and Synagro/Waste Management attorney Elizabeth Witmer is consistently "no" or "we will test only for what is required".

Testing is required for only 9 metals.  That's it.  The Office of the Attorney General found that 61 pollutants of the 352 in land-applied biosolids that are currently unregulated are considered "acutely hazardous, hazardous or priority pollutants in other [EPA] programs"

Synagro, Waste Management, Green Knight and even the PA DEP are acting as though this project is "green" and good for the environment.  There is nothing "green" about impacting people's health.

(The report is at this link and also linked below)


Tuesday, November 20, 2018

Wednesday Nov 21st is deadline to submit public comments to DEP on four permit applications for Synagro biosolids plant


Wednesday at 4:30pm is the deadline to submit public comments to DEP on four different permits or permit applications associated with the Synagro crap factory proposed on Waste Management's Grand Central landfill in Plainfield Township, Northampton County PA.

DEP requires that you send a letter/email on each of the four permits/permit applications individually, and put the number associated in the subject line of your email (or letter):

  1. WMGR160N001  General Waste Management permit application for the Synagro facility
  2. 100265-A181        Waste Management permit modification of Grand Central's existing permit
  3. PA#0276120         Individual NPDES Stormwater Discharge Draft Permit for the Synagro facility
  4. 48-00111A            Individual Air Quality permit application for the Synagro facility
#2 is a permit modification that addresses things such as Synagro's use of the haul road currently used for garbage trucks and the use of Sedimentation Basin #2, or the former quarry, which is located five feet (5') from the proposed facility.  It is currently used for runoff from the landfill and stormwater from the Green Knight Energy Center.  This water body (pond) is connected to a ground water aquifer that connects to at least one high quality creek (Little Bushkill), yet no one - not the DEP, not Synagro, not Grand Central has any clue what is happening below its surface.  There has been no hydrogeological study done on this water body, and DEP is on the verge of allowing it to be partially filled for Synagro, and allowing intense biosolids transportation, handling, storage and processing be conducted virtually IN the current boundary of the pond.  What could possibly go wrong?  A DEP waste management representative named Roger Bellas made a determination that would exempt Synagro from a Waterways Clean Water permit that would otherwise be required - which decreases to near zero the chance your water will be protected.  Strike 1

#1 is the general permit application for the Synagro plant, and it literally is a "general" permit where DEP would normally issue an individual permit for such a facility.  Because it is a general permit, if issued it will make it easier for DEP to grant permits (to its buddy Synagro for example) for similar facilities to this one in the future, elsewhere in Pennsylvania.  In other words, DEP sees this as a flagship model to pave the way to spread similar landfill-waste heat-crap bakery installations across the state.   A consequence of the fact DEP instructed Synagro to apply for a general permit is the harms/benefit analysis that is required on Form D of an individual permit application is not required!  Yes folks, the Department of Environmental Protection is orchestrating this application in yet one more way that prevent impacts to your environment from being assessed prior to issuance of permits and after they are issued.  The first notice of a problem will be after the air or water has been contaminated.  Strike 2   (DEP representatives confirmed what is stated here at the November 7 hearing in Wind Gap)

#3 is the stormwater discharge draft permit for the facility - kind of a subset of the facility permit that is focused on stormwater discharge.  Comments about stormwater are best filed under this number, though #1 is for the facility and you can make comments under that number as well.  Where to begin?  The sheer number of ways the water in Sedimentation Basin #2 can be contaminated is daunting.  At the November 7 hearing, Synagro's environmental engineer Pullar stated "at least that is the hope" after stating that a vegetated buffer between all the sources and the pond will "filter any contamination".   Um, what the fuck?  This isn't a strike against DEP, but against Synagro unless DEP makes them provide far better protection (eg: move the plant 100' or more from the pond).

This is the best permit number to make a comment that not requiring a Waterways Clean Water permit is not acceptable.  To learn more about what can happen when a quarry is filled with just clean fill, see the recent recommendations that Nestle Waters hydrogeologist Eric Andreus made to DEP for future precautions to take, in regards to contamination of Nestle's wells when the Slate Hills quarry began to be filled with DEP approval only a few miles away in Plainfield Township (West Bangor).  Has DEP taken a single one of Andreus' recommendations seriously?  Doesn't seem like it.

#4 is the air quality permit for the facility, and get this - it is an individual permit application for just the Synagro facility, because at a pow wow between DEP and Synagro, there was a gentleman's agreement that Synagro will be a "single source".  Single source is an EPA term used to denote a facility that is a stand-alone source of air contamination.  But in this case, there are three sources - Green Knight Energy Center, Synagro and Grand Central, all co-located and all on Waste Management property and under control of Waste Management, producing emissions into the air.  This is total bullshit and you should tell DEP this in a comment on this application number.  Strike 3, DEP, you're out!

To submit written comments via email
Tell DEP that what they are doing is unacceptable and they are not protecting you
  • The pond is way too close to the facility, and even Synagro acknowledges they don't know if they can prevent it from being contaminated (Robert Pullar, Synagro enviromental engineer Nov 7 hearing)
  • What if there is an accident in addition to all the known hazardous sources?
  • The air quality permit should not be for a single source, but for the entire facility
  • A more stringent air quality permit may be required since NorCo's air quality is impaired
  • Road drains that garbage trucks use and crap haulers will use drain directly into the pond, which will cause tracked fugitive crap up and down the road and increase contaminated runoff to the pond
  • The pond should not be exempt from a Waterways permit, because it is in fact a waterway and DEP recognizes that it is.  It isn't just a hole in the ground connected to nothing.
You have until tomorrow (Wednesday) at 4:30pm - anything received after 4:30pm will not count. You can use a form on the Delaware Riverkeeper Network's site (they have talking points too) to generate emails, or send your own emails as follows.  There is a single email address for comments on any of the four permits/permit applications: 
ra-epbenuseall@pa.gov

All you do is place "Comments on
  • WMGR160N001" for the Synagro Waste Management permit application or
  • 100265-A181" for the Grand Central Waste Management permt modification or
  • PA#0276120" for the Synagro NPDES stormwater draft permit or
  • 48-00111A" for the Synagro Air Quality permit application
In the subject line of your email.  That is all there is to it.  For example "Comments on WMGR160N001" would be for the email that addresses the Synagro facility permit.

Wednesday, November 7, 2018

Synagro Air Quality permit application for Plainfield Township plant shows facility will exceed proposed regulatory standards and incorrectly claims it is a Single Source

It is common knowledge that the air quality in Northampton County is impaired.  The air quality does not meet the standards for Ozone or PM2.5 particulates.

PM2.5 means particles suspended in air that are less than 2.5 micrometers - about 3% the diameter of human hair.  PM10 refers to particles that are 10 micrometers or less, so PM10 includes particles that are PM2.5.

There are pages on an EPA website for the Grand Central landfill and Energy Center that reflect the fact that Northampton County's air does not meet these two standards.  This does not mean each facility does not meet standard - but that the air where it is located does not.


Northampton County's air quality sucks - newsflash

Synagro plant will apparently exceed threshold for a minor air quality permit
 Synagro's application states that they expect to emit 15.47 tons per year PM10.   The EPA has established a standard for new sources in PM2.5 non-attainment areas that seek a minor permit of 15 tons per year (tpy) of PM10.  An EPA memorandum that documents this standard is located here.  At the bottom of page 3 is this statement:
"On July 1, 1987, we established a significant emissions rate for PM-10 of 15 tpy"
Since PM10 embodies PM2.5, regulating PM10 emissions regulates PM2.5.  Thus Synagro's facility should require a Title V major air quality permit.  Synagro's Air Quality Permit application does not reflect that Northampton County's air quality is impaired, nor does it mention that the applicable standard to be exempted from a Title V permit has been exceeded.

Single Source determination claim in Air Quality Permit application
Apparently, when Synagro and Waste Management met with their chums at the DEP a year ago, a gentleman's agreement was made that Synagro's plant would be a "single source" of air emissions.  Accordingly, Synagro applied for an Individual Air Quality Permit.  However, common sense tells anyone with a brain that this is unadulterated bull shit.  The operations of Grand Central, Green Knight and Synagro are all connected by both contracts and energy source, and all on land owned by Waste Management.  These must be permitted as a group.  Let's look at an aerial:

DEP apparently can't discern it's ass from a hole in the ground
Syangro's proposed plant would not be a single source

Here is where in Synagro's application it is revealed that it coordinated with DEP on this matter:

Synagro's engineer claims it is entitled to an Individual Air Quality Permit

Note that Synagro makes no mention of the fact that the first two criteria are met - the facilities do belong to the same industrial grouping, and the facilities are adjacent.  Waste Management controls this whole proposed operation, and owns the land all are located on.  Obviously none of these three are a single source in the context of emissions - they are all emitting into the air based on the operation of the landfill, and should come under a single Air Quality permit.

Tuesday, November 6, 2018

DEP plans to cram through four permits for proposed Synagro crap bakery in a 3-1/2 hour hearing, yet only two permits currently exist

DEP is an acronym for the Pennsylvania Department of Environmental Protection, but what it really means is:

DON'T EXPECT PROTECTION

This sounds a bit harsh, so let's look at recent local evidence that support this statement.
  1. In the early 2000's, DEP approved the Buzzi Unicem Quarry in Stockertown being lowered by 50'.  Within a short period of time, sinkholes developed that swallowed a few houses and a bridge that can not be replaced.  The Bushkill Creek now runs dry for over 2 miles unless massive pumps at Buzzi are operational.  Four times in the last year, power outages have resulted in countless fish dying.  PennDOT's new multi-million dollar bridges over the Bushkill Creek are sinking and will need to be replaced due to unstable geology. 
  2. In about 2010, DEP approved the Slate Hills Quarry in West Bangor be filled to reclaim the land for commercial use.  Within a short period of time of commencement, Nestle Waters' Deer Park wells were contaminated.  Nestle was forced to drill an interceptor well, which continues to be required to be run to pump 290,000 thousands of gallons of contaminated water daily from the aquifer into a creek so it does not reach the production wells.  The adjacent Green Walk Fish Hatchery experienced degraded water quality and dead fish as a result.  DEP revoked the permit they had issued.  See a news article on this here.
  3. The Solid Waste Department of DEP in August 2018 approved the partial filling of a quarry that is located within five feet of the proposed Synagro biosolids facility in Plainfield Township (water within 20 feet), and approved a waiver for the quarry so that it will not require a Clean Water permit.  Although this quarry is known to connect with an aquifer, and two high quality creeks are within a few hundred feet, the Clean Water Department of DEP apparently had no say in this matter.  All of Synagro's outdoor activities (loading, unloading, truck wash, trucking) are within 50 to 75 feet of the new proposed boundary of the pond, and some are within its current boundary.  Plainfield Township has appealed this decision to the PA Environmental Hearing Board.
Wednesday November 7 hearing
On Wednesday, November 7, there will be a DEP hearing on the Synagro application to locate a biosolids plant in Plainfield Township.  There will be a public question and answer session followed by a public comments session held at Wind Gap Middle School.  Representatives of Synagro, Green Knights and Waste Management will answer questions.  It is vitally important for all concerned citizens to attend and send DEP a message that we aren't going to take this shit - whether you plan to speak or not.  And this is the chance to ask questions of Synagro, Green Knight, and Waste Management and expect answers.

If you plan to speak, call or email Colleen Connolly ahead of time (Tuesday November 6) at coconnolly@pa.gov or 570-826-2035 to reserve a speaking slot.  Otherwise, there may not be time to handle all walk-ins.  You may also submit written comments the night of the meeting or up until November 21.
  • 6:00 to 6:05 Synagro presentation
  • 6:05 to 6:15 DEP describes permitting process
  • 6:15 to 7:45 Q & A - two questions per citizen, and one follow-up
  • 8:00 to 9:30 Public comment of 5 minutes or less each, depending on number of speakers
What is this about FOUR permits/applications being reviewed on November 7?
When this hearing was first announced September 29 in the PA Bulletin, it was to consider only one permit - an NPDES (stormwater) Draft Permit.  This covers surface water runoff.  A Draft Permit number is needed to submit specific written comments, and for the NPDES permit it is #PA0276120.  DEP had also announced that a General Waste Management Permit Application for the facility had completed an administrative review, and written comments on "technical deficiencies" were due by October 17 for Permit Application #WMGR160.  The expectation was that DEP would review claimed deficiencies with Synagro, and a response be generated.  

However, DEP abruptly changed course in the last week and added the General Waste Management Permit for the Synagro facility for public comment on November 7 as if it is a Draft Permit.  But as of today, there is no Draft Permit and thus no Draft Permit number corresponding to this permit application.  In the last week, DEP also announced that a Grand Central Waste Management Permit Modification would be reviewed as a Draft Permit on November 7.  But as of today,  there is also no Draft Permit or Draft Permit number corresponding to this permit application.   A DEP spokesperson stated "we plan to publish these two draft permits as late as the day prior to the hearing."  There is no way to submit written comments on these two permit applications as if they are Draft Permits, since they are not yet Draft Permits.  They will publish the Draft Permits on Tuesday and take oral comments on Wednesday?  This is horse shit!

The fourth permit application is for an Air Quality Permit Approval.  This was announced in the PA Bulletin on October 20, and is Approval Application #48-00111A.

To summarize :
  • NPDES Draft Permit - covers stormwater runoff into a freshwater pond, and two HQ creeks
  • General Waster Management Permit - anything related to the Synagro plant
  • Grand Central Waste Management Permit Modification - covers truck traffic, use of scales and roads, and use of Sedimentation Basin #2 to collect stormwater runoff.
  • Air Quality Permit Approval - covers particulates at silos and conveyors, odors associated with handling/processing
Speak your mind - about this plant or biosolids application to farmland
Don't let this alphabet soup confuse or intimidate you.  It is clear the PADEP does not want this hearing, and does not want to return to Wind Gap for another hearing on the Synagro plant.  Heck, DEP has recently refused to even come to the Slate Belt to discuss the application of biosolids to farmland - which is not the subject of this hearing but you should take advantage to voice your concerns and let DEP know what is important to you.  You may not get another chance anytime soon, because DEP is hiding behind "pending litigation" to avoid discussing the topic.

Something to consider - DEP normally would issue an Individual Permit, not a General Permit for the Synagro facility.  A General Permit will allow other facilities like this one to be approved across the state of Pennsylvania to be quickly approved in the future.  Reportedly, DEP instructed Synagro to file its application for a General and not an Individual permit.  Could DEP actually envision this poorly designed pile of crap next to a freshwater pond as a prototype for future facilities?  Don't laugh - this may in fact be DEPs plan.  The problem is, this site is not suitable for a Synagro facility.  DEP picked an extremely poor model if this is intended to be the first of many "green" waste/energy/biosolids processing projects in the state.

What questions should I ask?
There are talking points on the Delaware Riverkeeper's website for both water and air issues.  These will be reviewed on this blog Tuesday night.  In the interim, here are a few quick suggestions:
  • How can the Clean Water Department of DEP stand idly by, and let the Waste Management Department issue waivers that remove protections of a fresh water pond?
  • Does DEP know how deep Sedimentation Basin #2 is, and if so how do they know it?
  • What is the hydrogeology of Sedimentation Basin #2, and if it is not known, how could a waiver be issued to allow partially filling it?  Was the lesson of West Bangor not learned?
  • Did DEP instruct Synagro to file a General Permit application for its facility, and if so why?
  • Why is Green Knight giving away its waste heat for less than 1/20th the cost of heating using natural gas?
  • Was Green Knight pressured into partnering with Synagro in exchange for renewal of its lease which was set to expire in 2019?
  • Green Knight is expecting to get a maximum of $100,000 a year.  What is the maximum that Waste Management expects to get from Synagro?
  • Is there a profit sharing agreement between WM and Synagro?
  • Why isn't DEP suspending the Synagro applications until the appeal of the waiver of a Clean Water permit for Sedimentation Basin #2 has been resolved before the PA Environmental Hearing Board?
  • Synagro stated in its application that it satisfies the Zoning Ordinance, and that it has obtained Zoning Approval.  These statements are not true - when will Synagro file applications for two zoning variances that are required?
And here is another question - has DEP implemented any of the safeguards recommended by Nestle hypdrogeologist Eric Andreus, regarding decisions and procedures to be followed when filling a quarry?  Specifically, Andreus recommended first understanding the geology of the quarry - which Synagro has steadfastly refused to do.  No one knows what is going on with water flow in Sedimentation Basin #2, and how it interacts with the Little Bushkill and Waltz Creeks.  Read Andreus' letter here.

DEP really does NOT want to discuss biosolids in public
This proposed hearing is absurd and grossly inadequate.  Citizens are concerned about this plant, and they are also concerned about their properties near farms where biosolids may be spread.  DEP pulled a fast one by cramming 4 permits in where only one was advertised so they can get in and get out.  And DEP doesn't want to even talk about a topic of wider concern to Pennsylvanians - biosolids spread on farmland.

Here is an email that Senator Scavello's representative Taylor Munoz sent a constituent.  DEP was sued by East Penn Township over a permit issued to a single farm, and is using this as an excuse to not participate in public Senate hearing that Scavallo tried to call.  Not this hearing on Synagro's plant, but a hearing on the use of bioslids.  Mr. Munoz states the obvious - having DEP involved it critical - but DEP refuses to participate.  If what is written in the email is true, DEP will never be involved in a conversation that must be had.  Maybe you will want to voice your concerns on November 7 and tell DEP this position is unacceptable.


DEP's lame cop out to not discuss biosolids allplication to farms

Sunday, November 4, 2018

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

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

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

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

In Synagro's NPDES permit application to DEP it states that the product Synagro will process is 21% solids.  There is industry data available that details the amount of energy required to dry-roast shit on belt conveyors, which is the same process that Synagro proposes.  A chart published by Veolia Water Systems/Kruger on the "BioCon" dryer is presented, which has been marked up accordingly:
What the chart shows is that to dry 9523.8 pounds of "wet cake" to Class A biosolids (90% dry solids), just over 11 million BTU of energy is needed.  Since there is 1000 btu in one cu ft of natural gas, and the industrial cost of natural gas in August 2018 was $9.38 per 1000 cu ft, we divide by 1000 twice to find that 11 cu ft of natural gas is needed.  This is a fuel cost of $103.21 for 9523.8 pounds, or $21.67 per wet ton.

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

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

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

Let's look at how the plant could run profitably on 100% natural gas, and consider the consequence that Green Knight appears to be screwing citizens twice over - once for partnering in this operation, and twice for not receiving even 1/10 of fair market value for its waste heat.  And in the process we will discover why Waste Management wants this so badly...  It's green - money, that is.
There are several assumptions here, and they are shown.  Since Synagro is not building a waste water treatment facility, the cost of the plant has been reduced $2m from an original estimate of $10m.  The lowest paid employees (most of them) are estimated to earn $35,000 a year, and one or two lucky people $80,000.  The waste water of this operation is loaded with ammonia and nasty.  Assuming it doesn't leak into high quality water bodies and Synagro finds someone to take it, the cost of disposing it was estimated.

In the S&P 500, an 11% profit margin is typical.  We have allowed for 18.6% here.  Look at who the big winner of this shitty operation could be - Waste Management.  They can pretty much charge what they want.  Using the estimates above,
  • Using 100% natural gas, Waste Management may receive $8000 per day or $2.9m per year
  • Using 84% waste energy, Waste Management may receive $15000 per day or $5.5m per year
The assumption is that Synagro delivers the product for the cost of delivery - there is no need to charge for the product because it is so lucrative to haul the raw product away from sludge generators.

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

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

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

Green Knight is serving up shit on a stick to Slate Belt residents,
while Synagro and Waste Management feast on a bottomless buffet of cash