Pennsylvania’s Dept. of Environmental Protection (DEP) has cited Tully Environmental Inc., which operates Natural Soil Products in Frailey Township, for significant permit violations at its biosolids processing facility earlier this year.
Residents of western Schuylkill County have been locked in a years-long struggle with Natural Soil Products (NSP) over noxious odors emanating from its biosolids processing facility.
In a Notice of Violation letter, DEP alleges the company stored nearly double the allowed amount of biosolids in its processing bunkers and utilized unapproved groundwater testing methods.
The notice, issued on Dec. 2 by Joshua Matulevich, an Environmental Protection Compliance Specialist with the DEP’s Waste Management Program, outlined three distinct compliance failures by the company.
Storage Limits Exceeded
The most substantial violation concerns the volume of material currently on site. Citing data reported to the Department for Oct. 27, 2025, regulators determined the facility was storing 33,600 cubic yards of biosolids processing in its bunkers.
This exceeds the 18,000-cubic-yard cap established in the bond calculations for the facility’s Gore Composting System Permit Modification.
DEP also identified 10,860 cubic yards of unscreened biosolids stored on “Pads 3, 4, and 5”. Those are areas where the permit bond calculations did not identify any storage allowance.
Inside Building 2, the facility held 4,807 cubic yards of unscreened material, surpassing the 2,000-cubic-yard limit.
The DEP cited these overages as a violation of 25 Pa. Code § 281.201(b)(2) regarding failure to comply with permit plans and specifications.
Sampling Protocols Violated
Regulators also flagged procedural errors regarding groundwater monitoring.
During a third-quarter sampling event on Sept. 17, a consultant for the company collected samples from two groundwater sites without a DEP representative present. This failure to “split annual sampling” violates multiple sections of the facility’s Solid Waste Management Permit and state code, DEP says.
Further, DEP says the consultant used an incorrect filtration method during that event. A 0.45 micron filter was used on all samples rather than solely on dissolved metals samples.
This practice was deemed a violation of 40 CFR Part 13 and 25 Pa. Code Chapter 16 regarding approved test methods for specific pollutants.
DEP has directed Tully Environmental to submit a response within 15 days addressing the “correction and prevention” of these violations.
Matulevich notes in the letter that the notice does not constitute a final order, but warned that under the Solid Waste Management Act, each day a violation continues constitutes a separate offense potentially subject to enforcement action.
Brief History of NSP’s Troubles in Schuylkill County
Following a Department of Environmental Protection (DEP) investigation into resident complaints, the agency fined NSP $50,000 for failing to mitigate odors. Residents in Joliett, Good Spring, Donaldson, Newtown, and Tremont reported that these odors caused “sleeplessness and illness,” severely impacting their quality of life.
The investigation led to a “Consent Order and Agreement,” which mandated that the company reduce its sewage sludge intake and monitor weather conditions that could carry smells to neighboring communities.
Under the Consent Order, NSP was required to install a “Gore Biosolids Composting System” by Oct. 15, 2023. The company missed this deadline, citing rain delays for concrete work and late equipment deliveries.
In response, DEP imposed a $500 daily fine on the company until the system was operational.
Despite the Gore system eventually coming online, residents reported that it was “not working.”
In September 2024, the DEP issued a new Notice of Violation (NOV) after agency representatives detected odors offsite on 12 separate days in August (Aug. 5, 6, 9, 12, 13, 20, 22, 23, 25, 26, 27, and 28).
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