From the banks of the Susquehanna: Plastics, promises and potential pitfalls of an unprecedented project

*Riverkeeper note: This post should not be printed in other media sources without prior permission from the Middle Susquehanna Riverkeeper Association. You can contact us at [email protected] with questions.

A stroll along the banks of the Susquehanna illustrates an unfortunate truth we've all likely accepted but struggle to address.

We have a major plastics problem. 

Litter lines our river, most of it in the form of plastic that will likely never fully break down in the environment. Plastic bait containers, plastic Dunkin iced coffee cups, plastic bags and a wide spectrum of other types of plastic materials cast aside, caught up in our river system and swept ashore.

A year ago, a company out of Texas named Encina announced plans to build and operate a massive plastic "advanced recycling" plant along the banks of the Susquehanna River with promises to process upwards of 450,000 tons of plastic a year. Their goal is to sort 1,200 tons of plastic a day brought in from major metropolitan areas such as New York City, Philadelphia, Baltimore, etc., wash them with river water and use a form of pyrolysis via a catalyst to melt down these plastic products into benzene, toluene and xylene which will be shipped via rail car to places that allegedly will turn them back into new plastic products.

The process is being touted by the company as an answer to a growing plastics crisis on full display along our riverbanks and everywhere else plastic products wind up (such as our landfills). Yet, if this plant is the magical elixir for such a massive issue, why has no respected environmental group embraced the project with open arms? Why the hesitation to just blindly accept and applaud the narrative provided by Encina and its partners?

Some who question Encina's motives have suggested their claims of environmental stewardship are a form of greenwashing, at term defined by Investopedia as "the process of conveying a false impression or misleading information about how a company’s products are environmentally sound. Greenwashing involves making an unsubstantiated claim to deceive consumers into believing that a company’s products are environmentally friendly or have a greater positive environmental impact than they actually do."

The Encina plant doesn't address single-use plastics that are the heart of the plastics crisis, said Tamela Russell, founder of the Pennsylvania-based group Move Past Plastic, in an April 13 article by the Chesapeake Bay Journal. She suggested the $1.1 billion would be better spent creating biodegradable packaging and establishing a reuse model in which plastic products are designed to be collected by manufacturers, refurbished, cleansed and used again.

“It’s just going to perpetuate using more plastics,” she said. “And it’s still just taking those environmental contaminants and just recycling them. It’s the same false recycling narrative. It’s not going to stop more production, which we must do.”

More than what meets the eye
For a moment, let's return to that litter-laced riverbank on the Susquehanna. Beyond the trash peppering the shoreline is a cocktail of contaminants that are much harder to see in the depths of the Susquehanna.

Depending on where you are on the river, and the time of year and other parameters, there are varying levels of elements from abandoned mine drainage (high acidity and different metals such as iron or aluminum), nutrient runoff, sedimentation, mercury, endocrine disruptors, increasing salinity, pharmaceuticals, microplastics, a history of industrial pollution, unknowns involving chemicals from fracking and the emerging contaminant known as PFAS or forever chemicals. Click on the link with each contaminant listed above for Susquehanna River-based stories from the Middle Susquehanna Riverkeeper Association on each topic.

“In the past few years, I have done research focused on estrogenic compounds, then I did work on Mercury in fish and now it is PFAS. The bottom line is that a fish – or anything in the environment – is exposed to such a complex mixture of various stressors. It can really make it hard to know what individual chemical effects may be,” said USGS biologist Vicki Blazer. “I think it is important that people recognize that because one of the things we are questioning now with PFAS is their interactions with some of the things we know are already in those fish. How are those contaminants interacting with each other?”

In other words, our river system is already taxed with a wide variety of concerns. While much has improved over the past few decades in terms of water quality, there are still issues lurking in our river and its tributaries that we are still trying to fully understand – especially in terms of how those compounds impact each other as they impact the aquatic food chain and the humans that depend on it.

“Benzene, toluene, ethylbenzene, and xylene (components Encina plans to turn plastic waste into) are a group of chemicals collectively termed ‘BTEX,’ and they are present in many liquid fuels like gasoline. There are health concerns associated with significant exposure to them, so they are all individually regulated under the national drinking water standards,” said Dr. Kevin Gilmore, associate professor of Civil and Environmental Engineering at Bucknell University, in an April 3 article in the Milton Standard-Journal. “Because they are somewhat soluble in water, they could be present in the wastewater that is generated. They are also volatile, so they could be emitted to air when that wastewater is aerated for treatment.”

Encina plans to pull upwards of 2.5 million gallons of water per day from the Susquehanna River. That water will be used to wash plastic products and for other aspects of the pyrolysis process before a portion of it (an estimated 60-70 percent per Encina's responses to the MSRKA questions) will be treated and returned to the river.

PFAS a major concern
In a list of questions that Encina answered and gave permission to post on the Middle Susquehanna Riverkeeper blog feed, they were asked about potential emerging contaminants (including PFAS) that will be tested for and removed from the water before it goes to the river. Their response: "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."

A line worth repeating: "Our facility does not produce PFAS."

Perhaps their pyrolysis process specifically doesn't produce PFAS, but how can a company that plans to process 1,200 tons of plastic products and packaging a day ignore the potential threat of washing and processing plastic materials that, according to some recent studies, will likely be treated with some form of the wide spectrum of PFAS compounds?

“PFAS is all over plastic packaging, and it is water-soluble,” said Jan Dell, a chemical engineer who has worked as a consultant to the oil and gas industry and now runs The Last Beach Cleanup, a nonprofit focused on plastic pollution and waste, in a recent article by Inside Climate News. “We are seeing it in leachate from landfills. Has it been found in wastewater from recycling operations? I am not sure if anyone has tested for it, but they should.”

In March, the EPA affirmed it would set the maximum contaminant level of 4 parts per trillion for the most common forms of PFAS, saying in a fact sheet that “there is no level of these contaminants that is without a risk of adverse health effects.” 

​"There is no way that Encina’s wastewater discharge would have less than 4 parts per trillion (ppt) of PFAS," said Dell. "The plastic is laden with PFAS. There isn’t an available commercial technology to plug onto wastewater treatment to reduce PFAS to 4 ppt. Encina’s wastewater discharge into the river would be a huge point source of PFAS pollution."

While Northumberland and Sunbury – ​the first two bigger towns downstream of the proposed Encina plant don't immediately pull their drinking water from the river at this time (they pull from Milton and Little Shamokin Creek, respectively), other nearby communities (such as Shamokin Dam) do.

Plus, the proposed Encina plant will be located within a designated Watershed Priority Area for drinking water, agricultural use, wildlife and fish, as illustrated on this map:

Beyond the PFAS, microplastic discharge continues to be a concern for this site. While Encina has shared confidence in its wastewater treatment to filter out microplastics, there are numerous similarities in PFAS and microplastics – ​in fact, one form of PFAS is known to break down into microplastics.

Again, a company that is processing 1,200 tons per day of plastic waste can't ignore PFAS or assume that microplastics will all be addressed in their proposed membrane bioreactor system, especially at the scale that is anticipated at this site.

“In municipal wastewater treatment, where the contaminants are readily biodegradable, membrane bioreactors are seeing increasing use because they can achieve effective treatment with a relatively small physical footprint,” said Gilmore in an April 3 article by the Milton Standard-Journal. “Their effectiveness, though, is limited by how biodegradable the contaminants are in the wastewater. Contaminants in industrial wastewater can be more difficult to biodegrade. Every industrial wastewater is a unique situation.”

Changing tunes?
In the questions Encina answered publicly via the post on the Middle Susquehanna Riverkeeper Association blog, the company was asked how it would ensure that water returned to the river would be acceptable in contaminant level and temperature.

Their response: "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."

When asked what world-class partner they would be utilizing, Encina specifically named the company Veolia. 

"Veolia has extensive experience in water treatment, especially when involving plastics, and the design and operation of effective systems on the Susquehanna River," they said via one response.

Interestingly in an article that ran in the Milton Standard-Journal on April 3, 2023, reporter Matt Jones questioned Encina CEO David Roesser about environmental violations that Veolia and their subsidiaries had been cited for – including a 2018 incident that led to the company paying $1.6 million to settle a lawsuit with the state of Massachusetts for failing to properly maintain a wastewater piping system.

Roesser, who admitted that Encina was aware of Veolia's past violations, responded in the article: "We’re really in charge. They will follow our direction on being good stewards. They are hired by us. The responsibility is with us to make sure they work to our standards."

That is quite a change in tone from touting Veolia as a "world class partner" with "extensive experience in water treatment" to one that will require Encina's supervision and "direction on being good stewards."

A local resident asked during one of the public meetings with Encina an interesting question related to water quality: If the water they plan to discharge back into the river (about two-thirds of what they will be removing) will be as clean as they state, why not recycle it back through the plant to reduce the amount of water that has to be pulled from the river in the first place and cut down on expense for the water treatment done to the water when it is first pulled from the river?

​A numbers game?
Another major concern with the Encina project has been the changing numbers of various things. For example, the estimated number of trucks needed to haul in 1,200 tons of plastic a day has fluctuated quite a bit between different discussions and public meetings. 

The first question of a public meeting held via telephone in early March, a representative from Encina stated that there will be an average of 100 trucks traveling down Route 11 per day (plus truck traffic leaving the facility). Less than a week later in responses to MSRKA questions, Encina stated that there would be an average of 80 trucks per day. Others have reported to the MSRKA that they've seen estimates fluctuate between 70 and 150 truckloads per day.

In various newspaper stories, Encina relays that average salary for workers at the plant after it is constructed and running properly will be $75,000. However, that amount includes salaries of much higher-paid employees, such as engineers. When asked about a baseline pay for everyday non-engineer employees, Encina's response on their website: "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." Knowing that most people from our region will fall into that skilled labor category, why even throw the $75,000 number out there in the first place without proper context?

Encina uses various phrases to keep the numbers ambiguous, such as suggesting that they'll employ "up to" 300 people at its facility once it is fully operational. That is a very different statement than going on record suggesting they will hire 300. It could be any number under 300 and still technically fall into that phrasing as accurate.

One number, however, that has stayed the same from the initial announcement of the Encina plant is the intention of processing 450,000 tons of plastic a year. Other companies that have tried plastics pyrolysis using other methods have struggled to make the leap from concept to full-scale production on a much smaller scale than what Encina proposes, according to Dell and research she has done through her Last Beach Cleanup nonprofit.

"According to a 2022 report by Natural Resource Defense Council (NRDC), news reports and company websites, there are six small chemical recycling facilities that may be operating in the U.S. today," she said, citing links specifically to the NRDC study and this article in Bioplastics Magazine. "The total production rate for the six facilities is 106,950 tons per year."

Again, total production of those six plants is 106,950 tons per year – Encina plans to have a solution that will allow them to process much more than that at the proposed plant along our river.

Making the jump from their small public demonstration unit (details about how big it truly is and what all is going on there regularly are sparse as Encina considers that all proprietary information) to this massively unprecedented facility without a few environmentally devastating trial-and-error hitches seems extremely unlikely.

Taking a stand
Numerous groups have asked where the Middle Susquehanna Riverkeeper Association stands on the Encina project.

Considering all these concerns and the lack of any sort of track record for Encina (or really any company) to pull off this sort of facility at this scale, how could we fully support it while factoring in:

• The facility is proposed along the banks of our river in a flood plain just upstream from the recreational mecca known as the Shikellamy State Park and Lake Augusta, which is what locals call the swollen stretch of river just above the Adam T Bower Memorial fabridam after it is inflated each boating season.
• Our river already is enduring a long list of contaminants – both traditional and emerging – within a watershed priority area for drinking water, agricultural use as well as fishing and boating.
• There continues to be no one outside of Encina who is completely unbiased and knows the industry who actually advocates for Encina's plant and the process they plan to use. There are a growing number of people, such as plastics researcher and chemist Sherri A. Mason, director of sustainability at Penn State Behrend, who have gone on record to question the viability of this specific project. Those who have shared their support of this project are quick to regurgitate Encina's rhetoric and promises, but how many of those people have done their own research on this project and the threats it could pose vs. the economic figures (another number that may or may not be accurate) Encina provides? How could they when there is no precedent (which means no data) for this sort of facility at the scale they propose?
• Encina continues to withhold information, such as details of their PDU (process demonstration unit), details about their catalyst, details about how much of that catalyst will need to be disposed of and what specific chemicals it would include, etc., citing "proprietary" jargon that one would expect from a business venture prioritizing profit and shutting out competitors vs. openly sharing what they feel is a miracle solution to the worldwide plastics problem.
• As mentioned previously, there is no plan to address potential PFAS pollution. There are numerous stories online that highlight the connection between plastics and PFAS, including this one about fluorine gas practices and how they may be creating new PFAS on our plastic packaging. Again, the plant plans to wash (rinse) and process 1,200 tons of plastic waste per day.
• There have been some recent events, including this one, that illustrate the flammability of plastic waste in the recycling industry and the potential toxic fumes and health-related ripple effects when that plastic goes up in flames.
• The company has no intention of completing ​a full environmental impact study (EIS). Encina's response to an MSRKA question asking about the status of such a study: "No EIS has been required for this project." For a project with no track record at this scale on the opposite side of the country from company headquarters, an environmental impact study done without being "required" would go a long way to showing local people a sense of commitment and transparency and provide a little more reassurance that this project won't gravely hurt the region's most valuable resource (the Susquehanna).

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There is a certain stereotypical assumption about environmental groups automatically being against industry without looking at all the facts and potential benefits to the community. Hopefully our association's track record speaks for itself. This specific project raises special concern based on all the elements listed here, as well as others. Most of it, however, boils down to the long list of open-ended questions and lack of proven track record of this company (or really any company) doing this sort of project to the proposed scale. 

This association is not against working with Encina if they can legitimately address concerns a growing number of people in the community have and illustrate (through action, not just promises) that they prioritize the health of the river and our local communities.
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We encourage people to do their own research on the Encina project. Don't simply take our (or Encina's) word as the gold standard, but do some digging as an independent thinker, ask questions, talk with neighbors and friends and elected officials.

Groups tasked with permitting various aspects of the Encina project should do the same – don't just rubber stamp an approval or denial without independently (without bias one way or another) looking at the project and its potential long-term impacts.
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