Thursday, August 15, 2019

Expert testimony at August 12, 2019 hearing shows that neither DEP or Synagro are on the same page as Plainfield Township regarding proposed crap factory

On August 12, there was a hearing hosted by DEP to hear testimony on two of four permit applications for a proposed Synagro biosolids (shit) processing factory - Air Quality and NPDES (stormwater).  Representatives of DEP associated with the two Solid Waste permit applications were nowhere to be seen - including Roger Bellas who is a critical player as he is the one ironically charged with the responsibility of the sedimentation basin within a few feet of the proposed plant, which has become a major issue.  Bellas does solid waste, not water.

This post is to memorialize the testimony of experts and consultants, read into the record at the hearing.

It should be noted that while it was advertised that representatives of Green Knight (providing waste energy to partially fuel the plant), Waste Management (lessee of land), Synagro and EarthRes (Synagro's engineer) would be present at the hearing, what they did was not make a presentation or take questions, but rather testify along with the public.  Their "testimony" consisted of public relations bull shit, not comments on the permit applications.

The consultants for Plainfield Township were:
  • Jack Embick Environmental Attorney
  • Gail Braden (GB Universe) Air Quality
  • Jason Smith (Hanover Engineering) Wetlands Consultant
  • Mike Brunamonti (BCM Engineers) Environmental Consultant
  • Trudy Johnston (Material Matters) Biosolids Consultant
Also testifying:
  • Tracy Carluccio, Deputy Director of the Delaware Riverkeeper Network on NPDES permit
  • Russell Zerbo of the Clean Air Council on Air Quality Permit
The testimony below shows that while Synagro may believe everything is fine with its application, Plainfield Township does not.  Furthermore, Plainfield Township is not at all satisfied with the piecemeal approach that DEP has taken in evaluating multiple permit applications but not cross-pollinating monitoring requirements, and allowing the sedimentation basin to be filled without a Ch 105 permit.  The Riverkeeper and Clean Air Council have significant issues with each of the two permit applications.

Plainfield Township legal environmental counsel testifies that DEP encouragement
of township to approve
Synagro's Land Development Plan is "inappropriate"

Very troubling is that Plainfield's expert Jack Embick stated that "representatives of the DEP have encouraged the township" to approve the Land Development Plan currently before the planning commission, which he correctly terms in his testimony as "inappropriate".  This statement suggests that DEP may be biased, since DEP has been aware of the township's objection to DEP's handling of the basin for many months (the township sued DEP over it), and DEP has done nothing to change its stance or recognize the township's concern for the protection of the water quality in the basin or adjacent creeks.  If DEP representatives have in fact encouraged the township to approve Synagro's plan, it would be highly inappropriate.   Note that Mr. Embick encourages the DEP to put its position in writing, so that the township and public can see the hijinx DEP is up to - knowing full well that DEP would never do this on the record.  This indicates that DEP's officials did it verbally, in a non-public forum.  Possibly the May 23, 2019 on-site meeting, at which DEP met with Synagro for an hour and 20 minutes, before letting Plainfield Township officials and consultants join the meeting.  There will be more posted on this meeting and the meeting before the meeting in the near future.  Mr. Embick tossed this warning out in a very public way (he could have just called their legal counsel) and on the record for the DEP to MYOFBAs - and DEP deserved it and the public deserves to know that it happened.

Does DEP "want" to proliferate plants like the one proposed across Pennsylvania so badly that it will come right out and attempt to influence a local review process?  It looks like it.   Green Knight Treasurer Peter Albanese has stated "DEP wants more facilities like this one."  At any cost, regardless of "environmental protection"?  It's in their name for God's sake.  Pathetic.

PA DEP and Synagro appear to be on the same team,
obsessed with the pursuit of the Holy Grail of poop

DEP picked a piss poor choice of this project to be the flagship for Project Spread Shit Across Pennsylvania, but it seems they do not want to acknowledge it and will go down fighting to see it happen as opposed to lifting a finger to protect the environment.  Synagro has been ignoring requests by township planners to submit an environmental impact statement for over a year, and has refused to acknowledge it's proposal needs zoning and SALDO relief.  DEP seriously expects the township to just bend over and wince whilst they get a telephone pole shoved up their behinds, smile and say "thank you"?  Both the DEP and Synagro should fully expect plan approval by the township to be DENIED.

What business do DEP representatives have to weigh in on local compliance and review?  PA DEP should not even be spending time or taxpayer funds on Synagro's permit applications, since DEP is  to require local approval to proceed with a permit application.  In at least one Synagro permit application (Air Quality) is it falsely stated that the proposal has received local zoning approvals - patently false - not a single township approval has been granted. This stinks to high heaven.

A full review of testimony will be published at a later time.  Here without further comment is the testimony of each of these experts:







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Friday, August 9, 2019

Synagro's biosolids to be processed in Plainfield Township and used as fertilizer are not categorized as hazardous waste but they contain hazardous substances - PFAS and more

At multiple planning commission review meetings, Synagro representatives have stated that the Class B biosolids that it will process into Class A biosolids are not hazardous waste.  Here are just a few samples of many:

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 (!)

In conclusion, what do you think?  Are biosolids "safe"?




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Thursday, August 8, 2019

Register by tomorrow Friday August 9 via email to speak at August 12, 2019 DEP hearing for proposed Synagro crap factory in Plainfield Township

The Pennsylvania DEP is accepting comments on two of the permits that Synagro has applied for, NPDES (stormwater) and Air Quality.  There is a hearing the evening of Monday August 12, and to pre-register to speak all you need to do is send an e-mail to one of three people at DEP, whose emails are on the right margin.  If you send your notice to one of the program managers, they will forward it to Ms. Connolly.  DEP requests that you include your name, address and phone number.

  • Colleen Connolly Public Relations
  • Amy Bellanca Clean Water Program Manager (NPDES draft permit #PA0276120 )
  • Mark Wejkszner Air Quality Program Manager (Air Quality draft permit #48-00111A )
You should submit this email with your intent to speak by the end of business Friday, August 9, though it is possible that if you send it on Monday prior to the meeting you will be pre-registered.  You may register at the meeting to speak, but you will have to wait until the pre-registered speakers are done.

Note: You can speak on anything related to the proposed plant, in addition to the stormwater and air quality permits.  DEP is not obligated to respond to topics outside of these two permits, but your comments will still be entered into the record.

DEP requests that you submit your comments in writing if you plan to speak, either before or in person at the meeting.  There will be a transcript taken, so technically you don't have to submit them in writing.  Some people may wish to only submit comments in writing, and either not appear at the hearing or appear but not speak.

DEP is keeping the comment period open through 4pm August 26, and written comments will be accepted up until that time at the same three email addresses.   If you submit written comments, it is a good idea to put the draft permit number (in bold above) in the top of your submission.  You may also submit your comments to DEP at 2 Public Square, Wilkes-Barre, PA 18701  Edit Aug 14 - DEP spokesperson Colleen Connolly incorrectly stated during the hearing that comments are due by Friday August 23rd.

Experts at two environmental groups have reviewed the permit applications, and have presented talking points on each.  You may wish to review the talking points in preparation for your address at the hearing and/or submitting comments in writing.

NPDES Permit - Comments supplied by Delaware Riverkeeper Network
Air Quality Permit - Comments supplied by Clean Air Council
Please plan to attend the DEP hearing on Monday August 12, 2019 - asses in the seats counts.  In association with the 2018 DEP hearing on this proposal, DEP reports that it received over 300 comments/letters!


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Monday, August 5, 2019

Transcripts of year 2018 reviews of Synagro land development plan and November 7, 2018 DEP hearing for crap bakery in Plainfield Township

Here are several transcripts of  planning commission meetings held in 2018, as well as the DEP hearing held November 7, 2018, regarding Synagro's plan for a biosolids (shit) processing facility dubiously named the "Slate Belt Heat Recovery Center" and misadvertised as a "green" project that is good for the environment.  Maybe if it were sited elsewhere, but not where planned.  The plant will be operating on 100% natural gas in only a handful of years, and the "heat recovery" aspect will be permanently in the past.  Heck, by the time they obtain approval, they may not even bother investing in the technology to recover heat from the Green Knights landfill gas to energy plant next door.

Remember that some things have changed in the plan since these transcripts were taken - for example stormwater management has changed a bit, to route some runoff from the pavement behind the plant that used to head for the pond to an inlet.  These are the only transcripts SYnagro has made available at this time.
  • May 31, 2018
  • July 16, 2018
  • Sept 6, 2018
  • Oct 8, 2018
  • Nov 7, 2018 (DEP hearing)




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Sunday, August 4, 2019

Synagro submits new materials in effort to resolve loose ends and obtain a vote on its Plainfield Township crap factory land development plan

On August 1, there was supposed to be what was anticipated would be the final land development review meeting before Plainfield Township's planning commission.  However, Synagro submitted new materials electronically on July 26th, and in hard copy on July 29th.  This is not a surprise, since after the last review meeting in July it was evident that several items were outstanding that required further negotiation between Synagro and the township's consultants.  In order for the consultants to review the July 26th materials and respond in writing, the August 1 meeting had to be postponed.  A new date has not yet been scheduled.

Once responses are received to these documents from township consultants, they will be posted.   I remains to be seen if issues will be resolved as much as possible to everyone's satisfaction by the next meeting. Here are the 4 documents submitted on July 26th:

Synagro Comprehensive Monit... on Scribd

Comprehensive Monitoring Plan


Nuisance Mitigation Control Plan


Hydrology of Sedimentation Basin #2

Wetlands, Riparian Buffer and Open Space Plan
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Friday, August 2, 2019

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.




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Thursday, August 1, 2019

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.







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