In 2019, the Landfill applied to discharge up to 200,000 gallons of treated leachate directly into Little Roaring Brook.
Last month, the DEP issued a pre-denial letter because the landfill hasn't still hasn't provided enough data for the DEP to do a technical review.
“It’s not surprising that the landfill isn’t able to provide complete information on anything related to leachate since they’ve had ongoing leachate problems from storage to treatment for years, including documented violations,” - Pat Clark of FOL.
We look forward to seeing what DEP does next and if KSL submits the required information. Because this pattern fits the exact history of KSL + DEP interactions with the expansion -- unlimited chances to update applications followed by approval.
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DEP sends Keystone Sanitary Landfill pre-denial letter over proposal to discharge into Little Roaring Brook
BY FRANK WILKES LESNEFSKY STAFF WRITER
The state Department of Environmental Protection could deny the Keystone Sanitary Landfill’s proposal to discharge treated leachate directly into a Lackawanna River tributary.
The department sent the landfill in Dunmore and Throop a pre-denial letter last month for its pending applications for a National Pollutant Discharge Elimination System permit, or stormwater permit, and a water quality management permit to discharge up to 200,000 gallons of effluent per day into Little Roaring Brook just off East Drinker Street near Derrig Street — enough to fill two Olympic-sized pools in just under a week.
Leachate is the liquid that percolates through piles of garbage.
The landfill currently treats its leachate on site before piping it to Pennsylvania American Water’s Scranton wastewater treatment plant.
The pre-denial letter pertains to permitting for a leachate treatment plant, related pump stations/pipelines and the proposed outfall off East Drinker Street.
“(The DEP) has determined that the applications remain incomplete and not adequate for technical review,” according to the Feb. 15 letter, which the DEP released on Monday.
According to an application history in the letter, correspondence about the project began May 12, 2016. The Louis and Dominick DeNaples-owned landfill formally applied for the project on Dec. 18, 2019.
The landfill initially sought to discharge effluent into both Eddy Creek and Little Roaring Brook, but it later removed Eddy Creek from its plans.
The pending applications do not yet address application requirements and/or provide information pertaining to about a dozen items, including wastewater quality and characteristics, the proposed industrial wastewater treatment plant design and new aboveground storage tanks for leachate, according to the letter.
The landfill now has until June 14 to provide “complete and technically adequate” permit applications, or it can withdraw its applications. Otherwise, the DEP said it may deny both applications.
If Keystone withdraws its applications and reapplies, including new fees and public notification, the DEP will conduct a new completeness review.
The landfill will submit all required information by the June deadline, landfill consultant Al Magnotta said in a text. Keystone performed pilot tests to ensure its effluent, which undergoes a treatment process called reverse osmosis, could achieve the DEP’s strict quality limits for effluent. The landfill recently completed its testing, he said.
Magnotta previously described reverse osmosis as a process that pushes the leachate under high pressure through a membrane that extracts contaminants.
Bernie McGurl, the recently retired longtime executive director of the Lackawanna River Conservation Association, called the pre-denial letter “wonderful news.” McGurl, who is now an LRCA senior project manager, said the leachate should undergo secondary treatment in a sewer plant rather than direct discharge into the waterway.
“While they might be cleaning it up to a good degree from what it was as a raw leachate, it still has the potential to carry higher levels of toxic elements and hazardous elements that shouldn’t be going into waterways,” McGurl said. “While it’s a proven technology for doing certain types of treatment, it hasn’t been used here before to this degree.”
McGurl contends the reverse osmosis-treated leachate should be diverted to the sewer treatment plant for the next 10 to 20 years until they are confident over the long-term that it is an effective treatment.
Should the process prove to be time tested, McGurl would rather see the water directed into Eddy Creek instead of Little Roaring Brook. McGurl has advocated for the restoration of the mine-ravaged Eddy Creek, which flows through Throop and Olyphant and disappears into mines in numerous spots before eventually feeding into the Old Forge borehole. Someday, diverting the treated leachate into Eddy Creek could offset the loss of flow due to infiltration into the mines, he said.
Pat Clark, a leader of grassroots landfill opposition group Friends of Lackawanna, questioned if the leachate would be self-monitored by the landfill and advocated for the DEP to make its data publicly available. Discharging into a river or public waterway only heightens the risk, he said.
“It’s not surprising that the landfill isn’t able to provide complete information on anything related to leachate since they’ve had ongoing leachate problems from storage to treatment for years, including documented violations,” Clark said. “As usual, the DEP continues to provide the landfill with endless chances to update and adjust any application KSL submits.”
In a September 2022 letter, Dunmore and Scranton councils, along with Dunmore Mayor Max Conway and Scranton Mayor Paige Gebhardt Cognetti, sent a joint letter to then-Gov. Tom Wolf urging him to carefully review the landfill’s application.
After learning of the pre-denial letter, both Conway and Cognetti praised the decision.
“I am pleased that DEP is asking for more detail and seems to be taking the matter seriously,” Cognetti said in a text.
Conway commended the DEP for its thoroughness.
“This project, had it been approved, seemed to carry an unnecessary risk, potentially jeopardizing our local waterways in the event of accidents or mishaps,” he said.