Sewage sludge biosolids proposed on Hower Preserved Farm
Overview
In Plainfield Township, Northampton County, PA, the 80 acre Hower Farm is being proposed for disposal of processed sewage sludge i.e. “biosolids”. The property is located at 6249 Hower Rd., Nazareth, PA. Biosolids are the product from wastewater treatment processes where the liquids are separated from the solids and the solids are treated to produce a semisolid, nutrient-rich product, as defined by the US Environmental Protection Agency.1
The Nazareth Borough Municipal Authority bought the property in the fall of 2021. The Municipal Authority’s sewage treatment plant (Nazareth Borough Municipal Authority Wastewater Treatment Plant, Lower Nazareth Township, Northampton County, PA) would supply the sewage sludge; it is uncertain if other sources of sewage sludge would be used as well.
While the Hower farm property is preserved farmland, the Pennsylvania Right to Farm Act does allow for the permitted disposal of biosolids on the land. Community members and neighbors to the Hower Farm property remain concerned about the possibility of pollution to groundwater and the Little Bushkill Creek, possible damage to wetlands on and adjacent to the property, stormwater runoff and flooding, the historic nature of the property being ruined, and air emissions and odor that could result from the spread of the biosolids.
Biosolids are known to contain many pollutants that are contained in sewage sludge and, depending on the waste stream to the sewage treatment plant, can contain toxic and/or hazardous materials, radioactive substances and unregulated toxic compounds such as per and poly-fluoroalkyl substances (PFAS).
The Hower Farm Property
The Hower Farm property flows down to the Little Bushkill Creek and an intermittent stream flows through the property to a pond and the stream. The Little Bushkill Creek has a designated use as a High Quality-Cold Water Fishery. It has also been determined to be impaired in meeting its designated uses. Little Bushkill Creek is a tributary to Bushkill Creek with an approximately 17.5 square mile (mi.2) watershed.2 The Bushkill Creek flows to the Delaware River.
The Hower Farm property’s headwater stream begins in the property and runs into the Little Bushkill Creek which raises more concerns that the Little Bushkill Creek will become polluted and impaired by the runoff created from the spread of biosolids on the property and the farming practices that are being used on the land, which are different than how the farm was cultivated for decades. According to concerned community members, there is a plan to place two detention basins on the property to address stormwater. However, the land is comprised of two large slopes that are vulnerable to erosion.
The Hower Farm is located in an agricultural area of the township, surrounded by open land and next to a community park. The Farmer’s Fairgrounds host the local Farmers Fair there annually. The historic house on the property was most likely built in the early 1800’s but is slated for demolition by the Municipal Authority.
Municipal Authority Refused to Grant Permission
The Municipal Authority has refused to grant permission for the Northampton County Conservation District to disclose the farm conservation plan for the property to Delaware Riverkeeper Network, which we have sought through Right to Know and letters to various agencies. DRN’s requests to Nazareth Borough for assistance in gaining access to the farm conservation plan have yielded no success. The farm conservation plan has important information that is supposed to ensure that the farming practices used on the preserved land, which would include the land application of biosolids, does not negatively effect the environment and is beneficial to regional conservation of natural resources.
DRN submitted comment to the Delaware River Basin Commission on an application for the Nazareth Borough Municipal Authority Wastewater Treatment Plant to renew its current docket (1.6 mgd WWTP and its discharge) and change from chlorine disinfection to ultraviolet (UV) disinfection.3 A copy of the comment is below under Supporting Documents.
The Nazareth Borough Municipal Authority (NBMA) has a General Permit from the PA Department of Environmental Protection to apply sewage sludge (Class B biosolids) to land from their sewage treatment plant. This general permit can be used on property other than what the permit was originally planned for because DEP evaluates the sludge that is being produced by the sewage facility (rather than the location where the biosolids would be applied) in its determination of compliance with DEP biosolids regulations. On October 27, 2023, NBMA issued notice that they planned to start applying biosolids to the Hower Farm. This is required to be done 30 days in advance of the applying of the sludge.
The Community
The community members working to protect the region from the harmful impacts of sewage sludge and biosolids land application have formed a nonprofit corporation Save Plainfield Township (see https://www.saveplainfieldtownship.com/). Plainfield Township, where the Hower Farm is located, filed a Notice of Appeal with the Environmental Hearing Board objecting to the 30-day notice. Violations of Pennsylvania environmental laws and objections to the General Permit were cited. Save Plainfield Township has intervened in the appeal in support of the Township. Delaware Riverkeeper Network is in support of this legal action.
On November 4, 2023, PADEP published a notice for an individual “Draft NPDES Permit for Discharges of Stormwater Associated with Construction Activities (PAD480199)” based on the application NBMA filed with PADEP to discharge stormwater runoff from stormwater infrastructure they plan to construct on the Hower Farm. The permit would allow the demolition of the farm house, barn and other structures and the installation of stormwater basins, land cover changes such as driveways, associated piping and a storage area for the biosolids produced by the NBMA sewage treatment plant. The discharge would flow to the Little Bushkill Creek, crossing neighboring property.
DRN requested that the 30-day comment period be extended beyond the original deadline of Dec. 4 (see extension request below). PADEP granted the extension to December 19, 2023. DRN, Save Plainfield Twp., Plainfield Twp., and several members of the public submitted comments to PADEP criticizing the proposed permit and the deficiency of the application. Among the objections to the proposed permit was that the Erosion and Sediment Control (E&S) Plan and a Post-Construction Stormwater Management (PCSM) Plan were inadequate and did not comply with effluent standards required in federal regulations at 40 CFR Part 450. For technical details see below for a copy of DRN’s comments prepared by stormwater experts Meliora Design.
Update
As of mid-January 2024, PADEP has not issued a NPDES permit. There has been no application of biosolids to date.
“Plainfield Township, Little Bushkill Creek, Restoration Plan”, prepared for Plainfield Twp., November 2013 Project No.: 19999838.
See DRBC draft docket here.