Column: Encina project update via online survey results & more than 40 questions answered by company

This photo, provided by Encina, shows its Public Demonstration Unit (PDU) located in a contracted development institute in San Antonio. Per info from Encia, it is not a commercial-scale operational system.

​Riverkeeper note: This column is written by Riverkeeper John Zaktansky in reference to the Encina project proposed along the Susquehanna River's North Branch between Northumberland and Danville.

Many years ago, my wife and I lived in a neat remote cottage-like rental home in the woods. For an outdoors lover, you couldn't ask for a better location. The home was attached to a second home, which was rented by a very nice older lady for the first six months or so.

Unfortunately, her health deteriorated, and she moved into a nursing home. Our landlord rented the home to someone new -- a heavy smoker. The constant aroma of cigarette smoke wafting through the walls triggered a variety of health issues for my wife. We spoke with the landlord (who allegedly had a strict no-smoking policy), but she wound up siding with the new tenant and we ultimately had to move.  

This scenario, for some reason, has popped into my mind quite often while researching the proposed Encina plastics plant.

The concept of recycling plastic on the surface offers some allure. The science nerd part of me has been intrigued by the chemistry of what is suggested and if it is doable on such a large scale.

The environmental steward side of my Riverkeeper role, however, causes me to be more cautious. Like a tenant about to get a new neighbor, I find myself more anxious than ever to vet the company, its plan and its process. To question things like what 450,000 tons of plastic (what they plan to process at the plant per year) truly looks like on a volume and per-day basis. To look at all aspects of various chemicals and compounds they are using and creating and eventually transporting along the river basin.

​Skepticism isn't some naive attempt to derail the project before it begins, but more a defense mechanism. Asking questions is a necessary process for gathering info and filling in the gaps. Our association has a track record of trying to work with companies and other groups to figure out their pollution problems. Proactively addressing concerns hopefully leaves us with less regrets later.

So, we developed a survey and asked the public for feedback, posting it on our blog on Feb. 16 and sharing it out via various social media channels. The column and survey were developed around potential environmental threats -- a theme lacking in other limited media coverage the project has received over the past year. 

The post has attracted quite a bit of attention. To date, 186 people have taken the time to complete the survey, and there has been an overwhelming theme in these responses about a lack of public knowledge about the project. 

Of the 186 responses, 136 (73.1%) rate concern over the potential environmental impact of the project a 10 out of 10. Those that rate it an eight or higher out of 10 jumps to 167 (89.9%). 

A total of 63.2% stated that they are against the project continuing. Another 31.9% are still gathering info before making a decision. Out of the 186 surveys, 133 of them had at least one question they'd like to ask Encina -- most of those had multiple questions.

I spoke last week on Monday (Feb. 27) with Sheida Sahandy, chief sustainability officer and counsel for Encina. We talked about some of the questions I had as well as a few from the surveys. We ran out of time to address them all, so I sent her a list that covered most of the questions from the surveys received in one way or another. 

Sheida recently responded with answers to these questions, encouraging us to share them out with our members and followers. We appreciate the open dialogue and the opportunity to share these responses -- questions and transparency via answers is a valuable tool in assessing potential threats and proactively working toward a common goal of what is best for our river and the communities it flows through. 

Please note that each question (as asked by me or our surveys) and Encina's responses (via Sheida) are complete and un-altered.

These responses do lead to a few additional questions for me personally, which I will relay to Sheida and will include in a future update. If you have additional questions concerning this project, please use the form below.

Site specifics
Q: How many acres is the site?
A: Just over one hundred acres.

Q: What buildings, treatment systems, and other infrastructure will be developed at the site?
A: Site planning accounts for one large, enclosed building for feedstock sorting and processing, an administrative building, a maintenance building, a warehouse, and a parking lot. The remainder of the site will be used for equipment that is not in a single building but distributed throughout the site. We also will have water treatment onsite. Draft renderings of the site plan can be found on our project website at www.EncinaPointTownship.com.

Q: How do you address the 100-year floodplain concerns?
A: Any development activities that occur in floodplains must be in compliance with the safety regulations in place at the municipal level (through the township) as well as at the federal level through FEMA. We intend to get all required permits and approvals, the purpose of which is to protect public and environmental safety.
Additionally, we are designing our facility and supporting infrastructure in a way that minimizes disturbance to the strip of wetland along the river. We anticipate that water intake and outflow pipes will be the only infrastructure that will cross these wetlands.

Q: How will waste plastics and chemicals be stored at the facility (outside/inside the building)?
A: The baled mixed plastics that are delivered to the site will be stored indoors. The outbound liquids will be stored in closed-system vessels and tanks. We are designing the system to be in full compliance with local, state, and federal best practices.

Q: What other sites were considered and why select this site vs the others or Texas?
A: Many sites were considered around the country, but this location presented a number of
favorable qualities that made us excited about investing and operating in Point Township. For one, this region has a long history of manufacturing and provides a skilled workforce, and there are numerous educational institutions in the region with relevant degrees and programs. It is also close to markets where there is an acute need for better plastics management options.
Additionally, access to interstate highways and rail lines is another advantage of the location. Last but not least, nearly 20 other states in the US, as well as elected leaders in Pennsylvania, have expressed a specific desire to attract businesses in our industry.

Transparency with San Antonio facility
Q: Where is the facility located, who owns it, what does it produce, and have there been
problems?
A: Our process demonstration unit (“PDU”) is located in a contracted development institute in San Antonio. Our technology has been in development there at various scales since 2014. The PDU unit (pictured on our project website) is owned by Encina and its purpose is to serve to demonstrate parts of the Encina technology and outputs. This facility houses numerous customers.
There have been no issues related to Encina’s technology and operations. Also, it is not a
commercial-scale operational system so there are no relevant rates for us to provide in response to the question about the amount of plastic per day being run through that system.

Comprehending 450,000 tons of plastic processed per year.
Q: Will the plant be operational 24/7/365 or other?
A: The Point Township facility is being designed for continuous manufacturing throughout the year (365 days), but there will be planned shutdowns for maintenance activities.

Q: If operating 365 days a year, that is an average of 1,232 tons per day. If five days per week, 1,730 tons per day, correct?
A: On average our facility will be processing approximately 1,200 tons of end-of-life plastics and other non-plastics that will need to be sorted out per day.

Q: What form will the plastic have when it comes to the plant? Cleaning will occur on-site, so won’t it be fully processed?
A: The end–of–life mixed plastics will arrive in bale form and be processed to remove anything not appropriate for our processing.

Q: How much volume will that be per day and how many truckloads per day on average?
A: On average, our facility will have 80 truckloads per weekday. We are conducting a traffic study to determine the best approach to minimize traffic impacts.

Q: Plans are to recycle approximately 90 percent of the plastics that come in. What happens to the remaining 123/173 tons of leftover plastic? Where does it go and is there a plan in place of who will accept that? Will it go back to NY/NJ landfills or will our local landfills be expected to handle the increased leftover plastic load?
A: We expect that approximately 90 percent of the materials that come into our facility that are currently going to landfills, incinerators, or other undesired endpoints, will get recycled. The majority will go through our process; however, through additional sorting, certain plastics will go to the mechanical recycling markets, and non-plastic materials like metals and other products will go to their appropriate recycling markets. The remaining non-plastic materials for which we cannot find a higher use will go to their original destinations-landfills located out-of-state.

Q: What sort of chemicals or other waste is anticipated to be washed off the plastics and how will that be collected/handled?
A: Water treated after it is withdrawn from the Susquehanna River (pending approvals) will primarily be washing off organic matter, grit, and non-plastic materials (paper labels, etc.). Wash water effluent will be first treated onsite within the treatment facility and the remaining sludge will then be transported away to a facility equipped to manage it.

Q: What cleaner/detergent will be used during the plastic washing/prep process?
A: We will be using water for washing. No detergents will be used.

Process Questions
Q: What form of the proposed catalyst will you be using and how much will be needed to process 1,232/1,730 tons per day?
A: The catalyst we will deploy will be in solid particle form and is found in commonly used products, including personal care. In the interest of commercial competitiveness, we can’t reveal the exact amount to be used; however, it is significantly less than the amount of plastics being processed.

Q: In layman’s terms, how does the overall process work?
A: We take in end-of-life plastics that have been sorted at least once at a regional material
recovery facility (MRF) and execute an additional level of sorting and washing to prepare the materials for our process. The end-of-life plastics go through a series of conversion steps in which they interact with our catalyst without any combustion occurring, becoming liquified, separated, and purified. The final separated liquid materials, BTX (benzene, toluene, and mixed xylenes) are stored in vessels that are regulated and specially designed for safe storage and handling. The materials are then trans-loaded onto regulated, specially designed rail tankers (approximately one rail tanker per day) where they will be transported to customers.

Q: Beyond benzene, toluene, xylene and propylene, what other byproducts will come from this process?
A: This facility is designed to produce high value benzene, toluene, and mixed xylenes (BTX) for resale. Byproducts of our process are used comingled catalysts and filtered solids from water treatment (sludge). The process also produces some liquid oil products (which will be sold to create other materials, and not for use as any type of fuel). To ensure safety, all byproducts will be removed from the site and disposed in compliance with applicable regulations.

Q: What specific compounds/elements are in the leftover catalyst ash? How much of this
byproduct will there be on a regular basis (day/month/year) and what will become of this?
A: The leftover catalyst is simply the same catalyst but it will no longer be in active form. Other solids in the ash primarily come from within the plastics that are processed. For example, some bags/packaging in everyday use actually contain ceramics-like solids that are embedded in them.
To ensure safety, all byproducts will be removed from the site and disposed in compliance with applicable regulations.

Q: Which products of this process will be sent away to another party to develop new plastics?
A: The high value products that will be produced at this facility and sold to customers are benzene, toluene, and mixed xylenes (BTX).

Q: How do you anticipate shipping of that material to ensure safety?
A: All liquid products will be shipped out via rail via Department of Transportation compliant railcars for each product class. For context, we anticipate filling approximately one railcar of material per day for shipping to customers.
All chemical operators and other relevant personnel will receive regular, prescribed training to uphold safety and environmental protocols. Additionally, the site will staff and maintain its own, on-site fire brigade, whose members will receive specific and regular training suited for the products manufactured and handled onsite.
We have already engaged with North Shore Railroad leaders and local emergency responders and will continue to expand our collaboration moving forward, making it clear to them that safety is our highest concern. We will also engage with employees, and neighbors of our facility and emergency responders to raise awareness of potential hazards and coordinate emergency response planning with our facility and local authorities.

Water usage/return
Q: Plans to remove 2.5 million gallons of water per day? Is that average? What is the upper limit and how will that amount be modified in drier/drought-like situations?
A: We are planning to withdraw an average of 2.5 million gallons per day (pending approvals) and we do not expect to go beyond that on a daily basis. During drought-like conditions, Encina has some flexibility to reduce plastic wash water and we will employ those tactical measures as needed. For reference, daily withdrawals from the Susquehanna River for civic uses are stated to be around 400 million gallons per day according to the PA Department of Conservation and Natural Resources.

Q: What processes, specifically, will the river water be used in?
A: Water withdrawn from the Susquehanna River (pending approval) will be pre-treated and used as wash water for washing the end-of-life plastics feedstock. The pre-treated water will also be used for cooling water in our manufacturing process.

Q: What percentage of water will be returned to the river?
A: We anticipate that 60-70% of the water withdrawn from the Susquehanna River will be returned after being treated and returned to the permitted temperature. The balance will be evaporated.

Q: How do you ensure water returned is acceptable both in contaminant and temperature?
A: Encina is contracting with world-class partners to build on-site water treatment capabilities for cleaning and deploying monitoring systems to meet stringent health and safety, and water management requirements. The treatment systems have continuous monitoring as well as regular sampling. The water will be monitored for temperature as well as components like TOC, dissolved oxygen, chlorine, pH, and conductivity.

Q: Encina “is contracting” or “has contracted” with what world-class partners for the cleaning and monitoring systems? How do the logistics work in the system planned? For example, what will be used to filter out microplastics and how feasible is that on the scale proposed?
A: Encina is working with Veolia for the integrated raw and wastewater treatment design. Veolia has extensive experience in water treatment, especially when involving plastics, and the design and operation of effective systems on the Susquehanna River.
Our process will utilize a Membrane Bioreactor System and our design and water management plans will include continuous monitoring and testing for all parameters to stay below permissible levels. This will include testing for temperature, dissolved oxygen, chlorine, pH, conductivity, total dissolved solids, total hardness, sodium, silica, nitrogen, phosphates, and metals. The product is expected to have the capability to filter out materials as small as bacteria.

Q: Beyond microplastics, what other potential emerging contaminants are you testing for and removing from the water before it is returned to the river? How about things like PFAS?
A: The design of our on-site water treatment capabilities will include testing for many parameters to ensure they stay below permissible levels. This will include testing for pH, conductivity, total dissolved solids, total hardness, sodium, silica, nitrogen, phosphates, and metals. Our facility does not produce PFAS.

Staffing
Q: Once the facility is up and operational, what will the breakdown be of the advertised three hundred jobs? What will the majority of people working at this facility be tasked to do?
A: The majority of these jobs would be classified as skilled labor, but there will be a broad spectrum of positions and required education, training, and other qualifications. Positions will range from engineers, safety and environmental professionals, financial managers and analysts, maintenance professionals, equipment operators, analyzer technicians, and logistics managers and handlers.
Given the broad range of skills and qualifications within the facility, there will be no one specific activity a majority will focus on performing.
All site workers will be required to be trained on maintaining safety standards and protocols and environmental compliance. All chemical operators and other relevant personnel will receive regular, prescribed training to uphold safety and environmental protocols. Additionally, the site will staff and maintain its own, on-site fire brigade, whose members will receive specific and regular training suited for the products manufactured and handled onsite.

Q: What is a realistic salary baseline for most everyday non-engineer positions?
A: Given the broad range of skill sets and qualifications, it will be a range. As we get closer to the interview and hiring stages, we will have more specific information about salary ranges for each category of position.

Q: What percentage of the 300 positions will be hired from the local area vs. brought in from elsewhere?
A: The goal is to maximize local/regional hiring. There will be limited exceptions when a specialized skill may be required but we feel that it is to the benefit of the community, and our operations, to hire locally. The local skilled workforce and the educational systems that support it were major factors in our decision to invest and build our facility at this location.

Q: Is there a specific staffing report as far as pay, minimum criteria for eligibility, and job
titles/descriptions?
A: We are still developing our detailed staffing plan, so we are not able to share that level of
granular detail about each position. Looking more broadly at the full slate of positions, we can say there will be a broad range of skill sets running from a high school diploma with subsequent site-specific training, graduate certificate positions, two-year technical or business degrees as well as four-year engineering or business degrees, among others.
All site workers will be required to be trained on maintaining safety standards and protocols and environmental compliance. All chemical operators and other relevant personnel will receive regular, prescribed training to uphold safety and environmental protocols. Additionally, the site will staff and maintain its own, on-site fire brigade, whose members will receive specific and regular training suited for the products manufactured and handled onsite.

Other questions
Q: Can you explain the “two phases” of this process and what timelines are anticipated for
each?
A: Construction is sequenced to start with the front-end feedstock operations (intake, additional sort, and wash of end-of-life plastics). Followed by construction on the back-end operations where plastics are processed and transformed into their base materials that will be used by Encina's customers to make new plastics. An updated timeline is available on our project website.

Q: What agencies have you filed permits with so far?
A: To date, we have filed applications with

• Northumberland County Conservation District;
• PennDOT;
• PA DEP;
• US Fish and Wildlife Services for T&E species (PNDI);
• PA State Historic Preservation Office (PA Historical and Museum Commission);
• Point Township; and
• FAA

Q: How much money was donated to campaigns by Tom Wolf, John Fetterman and/or Josh Shapiro by Encina or other associated companies such as Steve Hillier (President of Worley Integrated Solutions) or Braven Environmental LLC?
A: Encina has made no political campaign donations to former Gov. Tom Wolf, U.S. Senator John Fetterman (former Lt. Governor), or Governor Josh Shapiro (former Attorney General). Encina as a company has not made any political donations period.
We cannot speak for any other entity or individuals outside of our company; however, that
information would be available as a part of campaign finance reporting public record.

Q: How does Encina plan to redefine a plastics industry that is currently only seeing/using a 5-6 percent recycling rate? What sort of realistic timeline do you anticipate until the industry is willing to use your recycled product vs. new product for future plastic creation?
A: The fact that the current recycling rate is so low is exactly the plastic waste problem we are trying to help solve and indicates that there is a large market for “hard-to-recycle” plastics. Our process will create a commercially viable pathway for significantly increased recycling rates while allowing for the continued use of plastics for critical uses. There is a market right now for recycled materials that will result from our process, and we have already announced one significant customer agreement and anticipate announcing more customer agreements in the near future.

Q: What companies have agreed to take Encina’s end product? What sort of things will be
created from this product ... what type of new plastic products? How much of this will be
developed into fuel stock?
A: The only publicly announced contract is with AmSty (American Styrenics). AmsSty’s product applications include Medical labware, Foodservice packaging, Extruded foam products (XPS), Commercial and residential insulation, Appliances, Automobile Parts, Bike Helmets, Paints and Coatings, Electronics, Manufacturing Heat Transfer Products, Flame Retardants, Consumer Electronics, and Appliances. Other conversations are taking place but are subject to Non-Disclosure Agreements during contract negotiations. When new customer agreements are finalized, they will be announced publicly. Encina will not be producing fuels.

Q: What sort of disaster response planning does your company utilize and what scenarios are you preparing for in terms of potential disaster concerns at this site?
A: Prevention of any such event is the starting point, which occurs through extensive training, best practices, and high maintenance standards for the equipment. We are designing the system to be in full compliance with local, state, and federal best practices. The plant’s design maintains hazardous chemicals within specially designed pipes and vessels.
All chemical operators and other relevant personnel will receive regular, prescribed training to uphold safety and environmental protocols. Additionally, the site will staff and maintain its own, on-site fire brigade, whose members will receive specific and regular training suited for the products manufactured and handled onsite.
All liquid chemical products will be shipped out via rail via Department of Transportation-compliant railcars for each product class. For context, we anticipate filling approximately one railcar of material per day for shipping to customers.
We have already engaged with North Shore Railroad leaders and local emergency responders and will continue to expand our collaboration moving forward, making it clear to them that safety is our highest concern. We will also engage with employees, and neighbors of our facility and emergency responders to raise awareness of potential hazards and coordinate emergency response planning with our facility and local authorities.

Q: When do you anticipate breaking ground on this facility’s initial stage? When do you
anticipate the first phase to be up and operational? The second phase?
A: An updated timeline is available on our project website.

Q: What are the anticipated air emissions from the plant?
A: This is a work in progress as design and equipment choices are being made. We anticipate that air emissions will be comparable to a large college or university. We will make this information available once we get to the point of filing air emissions permits.

Q: What could the people in neighboring communities expect if a chemical line were to burst in the plant or a fuel source explode?
A: Prevention of any such event is the starting point, which occurs through extensive training, best practices, and high maintenance standards for the equipment. We are designing the system to be in full compliance with local, state, and federal best practices. The plant’s design maintains hazardous chemicals within specially designed pipes and vessels.
All chemical operators and other relevant personnel will receive regular, prescribed training to uphold safety and environmental protocols. Additionally, the site will staff and maintain its own, on-site fire brigade, whose members will receive specific and regular training suited for the products manufactured and handled onsite.
All liquid chemical products will be shipped out via rail via Department of Transportation-compliant railcars for each product class. For context, we anticipate filling approximately one railcar of material per day for shipping to customers.
We have already engaged with North Shore Railroad leaders and local emergency responders and will continue to expand our collaboration moving forward, making it clear to them that safety is our highest concern. We will also engage with employees, and neighbors of our facility and emergency responders to raise awareness of potential hazards and coordinate emergency response planning with our facility and local authorities.

Q: Has an Environmental Impact Study/Statement been completed and if not, could one be completed and released publicly?
A: No EIS has been required for this project; however, relevant planning and data calculations will be provided in our permit applications.

Q: What are the avoidance and mitigation strategies to prevent air, water, and noise pollution (including truck traffic)?
A: Our facility will be in compliance with rules and regulations in place for preventing air, water, and noise pollution. Additionally, we are in the process of completing a traffic study to determine the best mechanisms for limiting the impacts of traffic.
Encina is working with Veolia for the integrated raw and wastewater treatment design. Veolia has extensive experience in water treatment, especially when involving plastics, and the design and operation of effective systems on the Susquehanna River.
Our process will utilize a Membrane Bioreactor System and our design and water management plans will include continuous monitoring and testing fall all parameters to stay below permissible levels. This will include testing for temperature, dissolved oxygen, chlorine, pH, conductivity, total dissolved solids, total hardness, sodium, silica, nitrogen, phosphates, and metals.
Air pollution is regulated and overseen by the PADEP with strict designations for air emissions.
The municipality regulates noise to ensure that it does not rise to the level of being a nuisance.
Not only will this facility enable the recycling and reuse of tons of otherwise wasted plastic, it avoids the potential social and environmental impacts of landfills, as well as the impacts of having that amount of waste plastic trucked to other states.

Q: What are the decommissioning protocols and expectations if the plant shuts down?
A: Our plan is to operate the plant in a safe and environmentally compliant manner for decades to come and we strongly believe in the benefits that our facility will contribute to reducing plastic waste and reliance on fossil fuels, and the jobs and economic impact that it will bring to the community. As for decommissioning protocols, the plant would be brought into a safe state of non-operational status wherein environmental facilities would be preserved for potential future use, if needed, or if a new opportunity arose.

Q: What performance bond and liability insurance is required by the Commonwealth of PA?
A: We are not far enough along in the permitting process with the Commonwealth to be able to answer this specific question. We can say we will remain committed to fulfilling the permitting obligations as required by the state’s regulators and to disclosing those obligations, as required by Pennsylvania law.