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DELAWARE
RIVERKEEPER
NETWORK'
Verbal Testimony
Tracy Carluccio. Deputy Director
Delaware Riverkeeper Network
Synagro's Slate Belt Heat Recovery Center
Redraft Industrial Stormwater Permit
PADEP "NPDES" PA0276120 and
Proposed Air Quality Plan Approval Application No: 48-00111A.

The proposed Synagro Sludge Drying Plant - euphemistically called the Slate Belt Heat
Recovery Center - is a high-risk facility on an undersized site that is dominated by a fresh
water pond and located at the headwaters of two protected cold-water streams, right up
against the town of Pen Argyl. The site is hopelessly complicated by the multiple uses
already on the property, which is owned by the Grand Central Landfill. The sludge trucks
that would come in and out carrying dangerous and potentially toxic cargo will have to use
the same entrance and internal roadway as the landfill trucks, already an enormous
amount of traffic. The old quarry pond on the site is currently used by the landfill and
Green Knight as a sediment basin to collect stormwater runoff and, now would also have to
be used by the sludge plant for their runoff, setting up an unmanageable scenario where it
will be impossible to sort out the origin of contamination should polluted runoff make its
way into the pond. The weak and ineffective monitoring proposed in DEP's redrafted
stormwater permit is deficient to the point of actually abetting the potential for cover up of
pollution by setting up the comingling of runoff from three different sources, the infrequent
monitoring of runoff, the lack of monitoring of stormwater from some areas, and the lack of
certainty if monitoring will even continue since under certain conditions, DEP can cancel
the requirement. The site adjoins Pen Argyl and the homes, parks, and businesses of over
3,500 people who will not be able to escape the air and water pollution that can result from
the operation of the sludge plant.

DELAWARE RIVERKEEPER NETWORK

925 Canal Street, Surte 370 I
Bristol, PA 19007
Office: (215) 369-1 188
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The Little Bushkill Creek and Waltz Creek would both receive storrnwater and groundwater
flow from the sludge plant site. The quarry pond, now used as a sediment basin, is directly
connected to groundwater that flows to both creeks. These streams are High Quality/Cold
Water Fishery protected waterways under PADEP anti-degradation special protection
waters regulations. Although the revised draft permit requires that additional
contaminants must be monitored for, many of the pollutants that can be found in sewage
sludge and its process wastewater are not included in the permit. Bacteria, radioactive
substances, pharmaceuticals, and per-and polyfluoroalkyl substances (PFAS) are just
some of the dangerous contaminants that are found in sewage sludge but are not included.

Despite Synagro's claim, which DEP seems to accept, that the site is not within % mile of
an "infiltration gallery", the pond-basin does directly infiltrate to groundwater. This fact
would be proven by a geologic analysis but Synagro has stubbornly resisted doing this for
Plainfield Township. Why isn't DEP demanding this study from Synagro? The application
shouldn't have gotten this far without it and certainly no decision can be made about using
the quarry pond as a sediment basin without it.

Both the groundwater connection and the surface drains on the access road on which the
sludge trucks would travel connect the site to the streams, potentially carrying pollution
that will harm the creeks and the life in them. For instance, state regulations require the
protection of the existing use of the streams by reproducing brown and brook trout but
instead they will be exposed to roadway runoff and potential groundwater pollution
plumes. And Synagro has not even performed the required anti-degradation alternatives
analysis they must do if they want to locate the sludge plant there. (See
§ 93.4c. Implementation of antidegradation requirements.)

Making an already complicated site worse is the Rube Goldberg plan to have the trucks
deliver the sludge, then get filled up with untreated wastewater that's produced by the
sludge drying process, most likely containing toxic components, and haul this
concentrated waste to an as-yet unidentified disposal facility. This wastewater would be
produced day and night all year long with the excess stored on site in a 300,OOO-galion silo.
All of these maneuverings will mean lots of potential for spills, accidents, leaks and dirty
runoff because Synagro chose a location for their plant where the wastewater is too badly
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polluted to meet discharge standards for the streams. Yet, truth be told, the redrafted
stormwater plan WILL allow industrial stormwater to be discharged, through the
groundwater and the surface drains, risking pollution and watershed damage. This is a
stormwater plan poised to fail and the Little Bushkill and Waltz Creeks and the people of
Plainfield Township and Pen Argyl will bear the environmental burden.

The air quality plan will allow hazardous air pollutants to be emitted and these will plague
Pen Argyl in a similar way that the current landfill pollution and odors hit the Borough.
Nestled against beautiful Blue Mountain - with the Appalachian Trail - to the north, and the
proposed site and landfill on the other side, Pen Argyl is ground zero for every pollutant
and odor that will be released from the sludge plant and the stream of 50 truck trips per
day. That means being impacted by fires and explosions as well as air and water pollution.
Explosions and fires have occurred at Synagro sludge facilities for years and continue to
happen. As recently as August 2 of this year a Synagro " ... machine used to dry
wastewater sludge and turn it into pellets" in Stamford, Connecticut exploded, sending
three people to the hospital. (See https:/lm.stamfordadvocate.com/local/article/Explosion-
at-Stamford-Water-Pollution-Control-14275125.php) Permit violations, accidents, and
health and safety issues loom large with Synagro in charge.

The proposed Synagro Sludge Drying Plant is the wrong project in the wrong place and
DEP has not provided the protection from pollution to our water or air that it is required to
provide in the stormwater discharge permit or the proposed air quality plan and that is why
they both must be denied.

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