Department of Environmental Protection: The KSL Files

For your convenience, here is a link to the DEP’s own KSL Files. Warning - it is long and will send you down a worm whole of anger.

Happy Reading.

Keystone Landfill (pa.gov)

dep HEALTH CONSULTATION 2019

April 2, 2019: The PA Department of Health has released is final Health Consultation Document. The evidence is clear. The harms that this landfill bring to our municipalities is greater than the benefit.

As part of the DEP process, Keystone Sanitary Landfill must prove that the benefits to this expansion clearly outweigh the harms, both known and potential. We believe that the Harms clearly outweigh any Benefit that could conceivably be recognized from this expansion. 

 

KSL's Harms and Benefits Analysis

FOL's Harms and Benefits Analysis

KSL's Resubmitted Permit Application (May 2016)

fol'S RESPONSE TO KSL'S RESUBMITTED PERMIT APPLICATION (AUGUST 2016)

Friends of Lackawanna has challenged Keystone Sanitary Landfill's current operating permit. It is our believe that if we believe the harms outweigh the benefits for expansion, then the harms must clearly outweigh the benefits of KSL's current operating permit as well. To read more on our position, check out our Notice of Appeal of KSL's current operating permit.

FOL's Notice of Appeal

The DEP has issued KSL its first Environmental Assessment Review Letter. The letter outlines which of KSL's stated benefits the DEP will consider when reviewing the landfill's permit application. Among things that will not be considered:

  • Charitable donations, like volunteering to pay an estimated $250,000 to obtain 2,000 feet of rights-of-way and for utility relocations for Eddy Creek’s flood control project — a project DEP is spearheading.

  • Other donations that similarly won’t be part of the decision include $100,000 of annual contributions to Dunmore Senior Center, $60,000 per year to Throop’s environmental fund and a proposed $10,000 per year to several colleges for scholarships.

  • A plan to relocate 8.8 million tons of waste from the landfill’s unlined portions to the active disposal area. The regulator determined it is not relevant to the expansion because Keystone proposed it in a separate application and will place the garbage in the active disposal area, not the expansion site.

  • Keystone’s plans to expand its recycling of captured methane gas and convert it into a clean source of electricity.“Beneficial reuse of landfill gas is mitigation of gas that is created by the landfill and an expected business practice, and is not considered to be a benefit of the Phase 3 expansion,” wrote Jeffrey Spaide, environmental engineer manager for the region’s DEP waste management division.

  • Plans to start an annual $10,000 contribution to a trust fund dedicated to rehabilitating Dunham Drive and Tigue Street. Mr. Spaide similarly described it as “likely a mitigation of damage to the roads caused by trucks accessing the landfill.”

  • Processing drill cuttings and fluids from hydraulic fracturing operations, which the agency saw as unrelated to the expansion plan.

 

To read more from the DEP's Assessment letter, click on the link below.

DEP FIRST ENVIRONMENTAL ASSESSMENT REVIEW LETTER 

As discussed at the recent DEP meeting, we have obtained some air quality reports that we are compelled to share with the public.

Background: since no off-site air testing was being conducted as part of the evaluation of the Landfill expansion, or the ongoing operation of the Landfill, Friends of Lackawanna requested that air testing begin. In addition to KSL, one of the testing sites was nearby Sherwood Park. We received the data from DEP and had two independent professionals** examine it. You can read both of their reports as linked to below.

Steven Lester summarized it as follows: "While there were many methodological problems with this analysis, what was clear from the sampling is that many toxic chemicals were found in the air samples taken on the landfill property. There were also a good number of toxic chemicals found in the air samples taken off-site including the April sample at Sherwood Park..."

** The two professionals that reviewed the information for us are Steven Lester and Kevin Stewart. Steven is the Science Director for the Center for Health, Environment & Justice. He has degrees from American University (B.S. in Biology), New York University (M.S. Environmental Health) and from Harvard University (M.S. in Toxicology). Kevin is the Director of Environmental Health for the American Lung Association of the Mid-Atlantic region. He received his Chemical Engineering degree from Princeton University.

Stephen Lester Letter March 9, 2016

Stephen Lester DEP Testimony, July 18, 2016

American Lung Association's Kevin M. Stewart DEP Testimony, July 18th, 2016

For KSL, the year 2016 brought with it two Notice of Violations from the Department of Environmental Protection. The first was issued in April 2016. KSL's west's leachate lagoon was found to be leaking. And then in October of 2016, it was determined that KSL's leachate had been leaking (over 7000 gallons) from a drywell at the facility. Below are the Notices from the DEP.

DEP's NOTICE OF VIOLATION TO KSL FOR LEACHATE LINER OVERFLOW (APRIL 2016)

DEP'S NOTICE OF VIOLATION TO KSL FOR OCTOBER LEACHATE SPILL (JANUARY 2017)

KSL RESPONSE TO LEACHATE SPILL (OCTOBER 2016)

 

 

The Pennsylvania Department of Health (PA DOH) is responsible for conducting research to determine the direct health risks of the Keystone Sanitary Landfill. Below is a link to a status update and a Q and A regarding their research. 

PA DOH keystone sanitary landfill update

 

 

Linked below is an article from Senator John Blake’s website detailing the final event of the 2017 Student Ambassador Program. 22 students from the 22nd Senatorial District were given an opportunity to make a presentation on a legislative or policy issue to a panel of judges that included Sen. Blake; Lackawanna County Court of Common Pleas Judge Julia Munley; Dr. Jean Harris, Professor of Political Science and Women’s Studies at the University of Scranton; and Kyle Mullins, legislative director for Sen. Blake. The team of Mid Valley senior Julia Betti and Carbondale senior Samantha Zenker were the winners of the legislative competition for their presentation on landfill regulations. Of the Student Ambassador Program, Sen. Blake said, “[It] is one of the favorite activities that we do each year and….is a great opportunity for me to work with bright young students and hear about the issues and policies that matter most to them, their families and their peers. The program informs my decisions in Harrisburg."

Blake Announces winners of student ambassador program

From black lung and mine fires, to lead poisoning and trash heaps, this Philly.com article by Michael E. Ruane posted in 1994 shows how Throop has become a town born and raised on the industries that harm it the most. The article focuses on KSL's successful 1994 expansion proposal that permitted the landfill to spread onto 458 acres of Throop land. Even after, "the borough government concluded several months of work on a new zoning code designed in part to block the expansion of Keystone's dumping to the other section of its land in Throop," the borough government ultimately failed in the face of a brutal legal defense, slanderous personal accusations, and the threat of bankruptcy. Read the full article linked below. 

 

Town with a coal past is leery of trash in its future

The DEP released its second Environmental Assessment Review Letter on May 25th, 2017. The letter addresses a number of issues discussed in their First Environmental Assessment Review Letter (see above) by either stating that KSL has failed to meet certain environmental health regulations or by requesting more information on certain issues. Click the link below to view the full 15 page letter. 

Dep second environmental assessment review letter

Linked below is a PDF of the Wikipedia page titled "Environment of Pennsylvania". While the page does describe PA's beautiful mountain ranges, waterways, and national parks, the page unfortunately also must dedicate most of its time discussing PA's excessive amount of landfills. With facts such as, "Pennsylvania has more trash per person at 34.5 tons of trash per person than every other state except Nevada in 2016," this page is a great way to gain perspective of PA's trash problem in a short amount of time. 

Wikipedia Article "Environment of Pennsylvania"

While it is widely known that seagulls are attracted to landfills, their effect on the ecosystems around the dumps they inhabit has long been unknown. However, a recent study conducted by R. Scott Winton and Mark River of Duke University (linked below) found that a spike in a local gull population caused by a nearby landfill can result in the spoiling of neighboring lakes and reservoirs. What's the connection between the two? The study found that since there's more gulls around, then, naturally, there's more gull poop, too. Eventually, this excess of gull poop finds its way into lakes and reservoirs. Although some bird poop is usually helpful to a water system–it contains beneficial nutrients–the amount of poop dropped by the increased gull population simply overwhelms the water. Specifically, this excess of gull poop increases the amount of nitrogen and phosphorus in the body of water. This starts a process called "eutrophication". In this process, a body of water receives an overabundance of nutrients that causes plant life to grow rapidly. While this may be good for plants like algae, it also results in a decrease of oxygen in the water. Eventually the oxygen levels get so low that the water is unable to support animal life. So, what does that mean in simple, practical terms? It means that fishing spots can be ruined, since the lack of oxygen killed the fish. That swimming spots can be ruined, because a forest of algae sprouted up beneath the rope swing. That our back up water supply will become useless, since the bird poop completely contaminated the reservoir, making it a "dead zone". For more in depth information about how gull poop dropped by birds eating landfill garbage can ruin our water, click the links below. Also included is an article about how the eutrophication of Lake Erie has earned it the nickname "Dead Lake". 

The Biogeochemical implications of massive gull flocks at landfills

Garbage-fed seagulls are spoiling our lakes and reservoirs with their poop

Trash-picking seagulls poop hundreds of tons of nutrients

Cause of lake erie's Harmful algal blooms gains more certainty

Linked below is the Environmental Hearing Board's response to Friends of Lackawanna's appeal to Keystone Sanitary Landfill's operating permit. In short, the EHB decided not to rescind KSL's operating permit and rejected the majority of FOL's objections to KSL's Harms and Benefits analysis, claiming that FOL has not satisfied the burden of proof. However, the EHB is now requiring Keystone to conduct a groundwater assessment plan due to the levels of contamination registered by a monitoring well during the past fifteen years. 

Environmental Health board ruling

Comments of Kevin M. Stewart
Director of Environmental Health
on Behalf of the American Lung Association in Pennsylvania
February 12, 2018
on Health Consultation Public Comment Version
Keystone Sanitary Landfill, Dunmore, Lackawanna County, Pennsylvania
Prepared by Pennsylvania Department of Health
under
a Cooperative Agreement with the U. S. Department of Health and Human Services
Agency for Toxic Substances and Disease Registry
December 14, 2017

AMERICAN LUNG ASSOCIATION IN PENNSYLVANIA COMMENTS

Pennsylvania Department of Health

Health Consultation

Keystone Sanitary Landfill

December 14, 2017

Prepared under a Cooperative Agreement with the
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Agency for Toxic Substances and Disease Registry
Division of Community Health Investigations
Atlanta, Georgia 30333

HEALTH CONSULTATION

The Center for Health, Environment & Justice (CHEJ)

Re: Comments on the Health Consultation Public Comment Version
Keystone Sanitary Landfill, Dunmore, Lackawanna County, Pennsylvania
Prepared by the Pennsylvania Department of Health
December 14, 2017

CHEJ Comments on the Health Consultation