BCM Jan 2018 Review Synagro Land Development Plan Slate Belt Heat Recovery Center

1001 Lackawanna Trail
SCM
ENGINEERS
Clarks Summit, PA 18411
Phone: (570) 587-3339
Fax: (570) 586-7989
www.atcgroupservices.com
ATC GROUP SERVICES LL.C
January 17, 2019
Via email: manager@plainfieldtownship.org
Plainfield Township
6292 Sullivan Road
Nazareth, PA 18054
Attention: Mr. Thomas R. Petrucci

Township Manager
Re: Proposed Slate Belt Heat Recovery Center

Plainfield Township, Northampton County
Dear Mr. Petrucci:
I am enclosing with this letter updated review comments regarding the below listed applications, as
submitted to the Pennsylvania Department of Environmental Protection by Earthres Group, Inc. on
behalf of Slate Belt Heat Recovery Center, LlC; Grand Central Sanitary Landfill, Inc.; and Green Knight
Economic Development Corporation, Inc. regarding the proposed Slate Belt Heat Recovery Center. The
updated comments were prepared after considering the information provided by Earthres with its letter
addressed to Plainfield Township, dated December 28, 2018.
1. Application for Municipal or Residual Waste General Permit, submitted by Slate Belt
Heat Recovery Center, LLC
2. National Pollutant Discharge Elimination System (NPDES) Application for Individual

Permit to Discharge Industrial Stormwater, submitted by Slate Belt Heat Recovery
Center, lLC
3. Application for Air Quality Plan Approval, submitted by Slate Belt Heat Recovery Center,
llC
4. Application for Minor Modification Municipal Waste landfill Permit, submitted by Grand
Central Sanitary Landfill, Inc.
5. Request for Determination of Changes of Minor Significance and Exemption from Plan
Approval/Operation Permit, submitted by Green Knight Economic Development
Corporation, Inc.
We appreciate the opportunity to provide Plainfield Township with assistance regarding these matters.
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BCM
ENGINEERS
,UC GROUP SERVlCES lle
Mr. Thomas R. Petrucci, Township Manager January 17,2019
If there are any questions, please contact me by telephone at 570-877-2241, or via email at
michael.brunamonti@atcgs.com.
Sincerely,
)M}
Michael 1. Brunamonti, P.E.
Project Manager
BCM Engineer/ATC Group Services LLC
Enclosures
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BCM
ENGINEERS
ATC GROUP SERVICES LLC
Review Comments
General Waste Processing Permit Application
Slate Belt Heat Recovery Center, LLC
November 6, 2018
(Updated January 17, 2019)
1. 1.0- Introduction (Page 5/198): A description of the sources of process wastewater are
identified. Please provide a summary of the anticipated characteristics of this process wastewater (pH
range, T55, 800, O&G, etc.). Please also provide a wastewater characterization of each of the
component streams to the combined wastewater flow.
The EARTHRES response dated October 26, 2019 proVides general wastewater characteristics for BOD5,
COD, TSS, pH, NH3-N, Total P and TDS and states that actual characteristics will be confirmed once the
facility is in operation.
What is the basis for the basis for the provided wastewater characteristics? Ideally this information
would be based upon data from a similar facility, if available. If these characteristics are not from a
similar facility, further details should be provide showing how these estimates were developed. What
are the anticipated concentration levels for metals, such as copper, lead and zinc? Also, a wastewater
characterization of each of the component waste streams was not provided as requested.
The EARTHRES response dated December 28, 2018 states the estimated process wastewater
characteristics have basis from a comparable belt type biosolids thermal dryer that operates in a similar
general arrangement to the proposed SBHRC; analysis of the dryer condensate discharge provided by
Haarslev indicates metals discharge concentration at or below the detection limit; and wastewater
characteristics will be confirmed during facility startup as required to meet permit and disposal facility
requirements.
No further comments at this time.
2. 1.0- Introduction (Page 5/198): Process wastewater will be hauled to an offsite liqUid disposal
facility. Will wastewater be hauled back only to facilities that generate the incoming biosolids, or will
other facilities, such as other POTWs or the Grand Central leachate treatment plant, accept this
wastewater?
The EARTHRES response dated October 26, 2018 states SBHRC process wastewater will be backhauled to
the biosolids generator plants or transported to permitted offsite wastewater treatment plants, and that
none of the SBHRC wastewater will hauled to the GCSL leachate treatment plant. The response also
states that SBHRC has received conditional approval from the Passaic Valley Sewerage Commission on
August 27, 2018 and includes a copy of the approval letter.
Prior to accepting hauled-in waste, NPDES permitted wastewater treatment facilities must perform an
evaluation to confirm that the facility has available capacity, and to confirm that the waste is
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ENGINEERS
General Waste Processing Appl. Comments, cont'd Nov. 6, 2018 (Updated Jan. 17,2019)
compatible with the treatment process and will not interfere with or pass through the treatment
facility. This evaluation will need to be completed for any of the facilities to which backhauling of
wastewater is intended or any other offsite wastewater treatment facilities.
The EARTHRES response dated December 28, 2018 states as detailed in the prior letter dated October 26,
2018, the SBHRC received conditional approval from the Passaic Valley Sewerage Commission (PVSC) on
August 27, 2018 to accept wastewater condensate from the SBHRC facility and the letter from pvsc
states they have capacity to accept 100% of the volume of condensate wastewater from the proposed
SBHRC.
3. 1.0- Introduction (Page 5/198): Process wastewater from multiple facilities will be combined in
the onsite storage tank, so comingling of fluids from different facilities is inevitable. Before any site will
accept this process wastewater for disposal, will monitoring of analysis of the wastewater be provided
to the recipients? Provisions for routine monitoring and wastewater characterization prior to truck
loading should be considered.
The EARTHRES response dated October 26, 2018 states it is anticipated that confirmatory wastewater
samples will be collected and analyzed for the required parameters prior to acceptance at offsite
treatment facilities, a sampling port will be installed on the storage tank, ond monitoring requirements
will be based upon disposal agreement with the facilities.
No further comments.
The EARTHRES response dated December 28, 2018 states none required.
4. 1.0- Introduction (Page 5/198): What mixing or agitation, if any, is provided in the process
wastewater storage tank? Please clarify the impact of mixing on the tank odor control system.
The EARTHRES response dated October 26, 2018 states that no mixing or agitation is currently propose
for the wastewater storage tank.
5. Form 20- Narrative (Page 24/198): Secondary containment for the process wastewater tank,
loading area, and delivery trucks are described in the narrative. It is noted that secondary containment
piping is required on certain liquid streams at the landfill depending upon the fluid characteristics,
including untreated and partially treated process wastewater from leachate treatment operations.
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Please clarify what provisions, if any, are required for secondary containment piping for the process
wastewater conveyances in this unit.
The EARTHRES response dated October 26, 2018 states double wall piping is not required or proposed for
the wastewater lines at the SBHRC facility.
6. Form 20- Narrative (Page 25/198): Three days of process wastewater storage is provided.
Please describe the impact to system operations if storage capacity is exhausted because wastewater
flows exceed estimates or wastewater hauling operations cannot keep up with incoming flows.
The EARTHRES response dated October 26, 2018 states that in the event that SBHRC's wastewater
storage tank is at design high level, the plant would not accept additional biosolids until wastewater
storage levels are reduced.
Additional details need be provided to document how this will be implemented. What type of
mechanism will be used to monitor the tank level, what is the design high level, how frequently will
the level be checked, is a high level alarm necessary? How much advance notice will be built in to this
procedure for notifying biosolids generators to stop shipment so that loaded vehicles are not caught
mid route. It is recommended that a Standard Operating Procedure be required for this.
The EARTH RES response dated December 28, 2018 states the wastewater storage tank will be equipped
with a level transducer (or equivalent) to measure the wastewater level in the storage tank. When the
tank level reaches a predetermined capacity, the level instrument will activate a high-level alarm
warning the facility. At this point the wastewater storage tank will have adequate capacity for
approximately one day of wastewater generated from the drying process, including a 25 year storm
event (6" over 24 hours), tailgate wash water, and the odor control system discharge. Storage tank
freeboard requirements will be in accordance with adopted Federal and State regulations and design
practices. An SOP for wastewater management will be developed prior to facility construction.
It would be preferable for the proposed SOP to be submitted to the PA DEP during the permit
application review process. Otherwise, if PA DEP issues a permit for this facility it should include a
permit condition requiring submission of the SOP prior to facility construction.
7. Form 20- Narrative (Page 25/198): 100,000 gpd of wastewater flow has been estimated. Please
provide supplemental calculations backing up this estimate. Please include a breakdown of each
component stream to the overall combined wastewater flow.
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BCM
ENGINEERS
General Waste Processing Appl. Comments, cont'd Nov. 6, 2018 (Updated Jan. 17,2019}
The EARTHRES response dated October 26, 2018 provides calculations showing how the 100,000 gpd
wastewater flow has been estimated. The calculations include a breakdown of process waste water
sources consisting of dryer condensate (76,739 gal/day); stormwater (19,616 gal/day); process and
tailgate wash water (1,000 gal/day); and odor control system discharge (720 gal/day). The estimated
storm water flow is based upon a 25-year stem event (6/1 over 24 hours). The proposed areas where
storm water would be captured as process wastewater are shown as follows: Receiving Units -1,452 sq.
ft. Truck Unloading - 2,363 sq. ft. and Product Loadout -1430 sq. ft. The total estimated flow including
a 25-year storm event is 98,075 gallons per day.
8. Form 20- Narrative (Page 25/198): A portion of the wastewater flow is generated from receiving
pad stormwater. Please clarify what storm event was used for the basis of calculating this
stormwater/wastewater volume.
The EARTHRES response dated October 26, 2018 states that a 25-year storm event (6/1 over 24 hours)
was used to calculate the stormwater volume capture in the containment areas.
9. Form 20- Narrative (Page 28/198): The process wastewater storage headspace is vented to the
combined odor control system. Is this venting active or passive? If active, please specify what provisions
are provided for odor control in the event the active venting is non-operational.
The EARTHRES response dated October 26, 2018 states that the need for an active ventilation system has
yet to be determined, design requirements established at the final design will reflect any changes made
to the ventilation system, and air flow from the wastewater storage tank has been accounted for in the
odor control unit design capacity.
This comment and response should be flagged for further review when the final design is complete.
Also, how will the storage tank be vented when the odor control system is shut down for
maintenance? Unless the tank is pumped empty and cleaned, it will always need to vent.
The EARTHRES response dated December 28, 2018 states the process wastewater storage tank vent will
be connected to the facility odor control system and the airflow has been accounted for in the design.
Further design is required to determine if an active ventilation system is required. The dryer will not be
operating during planned maintenance on the odor control system and flow to the process wastewater
tank from the dryer, odor control system, process or containment area will be suspended. The process
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ENGINEERS
ATe GROUP SERVIC·ES LLC
wastewater storage tank roof is sealed with a pressure relief valve that will not be activated during this
period of time.
Unplanned downtime may occur when a controlled dryer plant disruption will stop feed and may require
clearing the dryer of material and cooling the dryer down. The design includes redundancy in equipment
such as recirculation pumps and chemical dosing pumps, and will be powered by a back-up generator to
minimize the potential downtime.
The wastewater storage SOP, developed prior to facility construction, will include facility wide
procedures to minimize potential nuisance during planned and unplanned downtime of the odor control
system.
permit condition requiring submission of the SOP prior to facility construction
10. Form L- Contingency Plan for Emergency Measures (Page 67/198): 5000 gallons of sulfuric acid
will be stored inside the dryer building. Sulfuric acid is a water reactive class 2 material as defined by the
International Fire Code. If greater than 50 Ibs of water reactive class 2 materials are to be stored inside a
bUilding, then the building must be classified as Group H (High Hazard Occupancy). Please confirm that
the building permit and design will reflect this high hazard occupancy classification and the associated
design requirements from the Building Code and Fire Code.
The EARTHRES response dated October 26, 2018 states that the final design will meet all applicable
building and fire codes and the storage tanks will meet applicable PA DEP standards.
This comment and response should be flagged for follow-up to insure these requirements are met.
The EARTHRES response dated December 28, 2018 states no response required at this time.
11. Form L- Contingency Plan for Emergency Measures (Page 67/198); 3000 gallons of sodium
hydroxide will be stored inside the dryer building. Sodium hydroxide is a corrosive material as defined by
the International Fire Code. If greater than 500 gallons of corrosive materials are to be stored inside a
building, then the building must be classified as Group H (High Hazard Occupancy). Please confirm that
the building permit and design will reflect this high hazard occupancy classification and the associated
design requirements from the Building Code and Fire Code.
bUilding and fire codes and the storage tanks will meet applicable PA DEP standards.
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SCM
ENGINEERS
A TC GROUP SERVICES LLC
General Waste Processing Appl. Comments, cont'd Nov. 6, 2018 (Updated Jan. 17, 2019)
The EARTHRES response dated December 28, 2018 states no response required at this time.
12. Form L- Contingency Plan for Emergency Measures (Page 67/198): Portable fire extinguishers
are listed as available emergency response equipment, but not fire alarms or sprinkler systems. Because
the building must be classified as Group H (High Hazard Occupancy), it is probable that both automatic
sprinklers and fire alarms will be required. Please update the contingency plan to reflect the fire
equipment required by the Building Code and Fire Code.
building and fire codes and the storage tanks will meet applicable PA DEP standards.
This comment and response should be flagged for follow-up to insure the contingency plan is
updated.
The EARTHRES response dated December 28, 2018 states no response reqUired at this time.
This comment and response should be flagged for follow-up to insure the contingency plan is
updated.
13. Form Rl- Waste Analysis and Classification Plan (Pages 123/198 & 126/198): Section 1.0 states
that SBHRC will accept dewatered municipal biosolids, but section 2.2 describes provisions for accepting
material not sourced from a POTW. Please clarify if SBHRC will accept biosolids from any industrial
wastewater treatment facilities.
The EARTHRES response dated October 26, 2018 states that SBHRC propose to accept biosolid materials
that meet the acceptance criteria and are compatible with the end product uses.
For the record, it must be noted that Plainfield Township submitted comments regarding General
Permit Application No. WMGR160 to the PA DEP in a letter October 17,2018. The letter includes
comments stating why the application must be based on and changed to a Municipal only Processing
Permit.
The EARTHRES response dated December 28, 2018 states no response is required at this time and SBHRC
will review the comments on the general permit application when received from PA DEP.
14. Form Rl- Waste Analysis and Classification Plan (Pages 123/198 & 126/198): Section 1.0 states
that SBHRC will accept dewatered municipal biosolids, but "dewatered" is not defined in the application.
Is there a minimum total solids criteria before acceptance, or will incoming material be required to pass
the paint filter test prior to acceptance?
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ENGINEERS
ATC GROUP SERVICES lLC
General Waste Processing App!. Comments, cont'd Nov.~2018(UpdatedJan.1~2019)
The EARTHRES response dated October 26, 2018 states that incoming biosolids will be dewatered
utilizing wastewater industry standard dewater technologies and practices and a paint filter test may be
used to determine iffree liquid is present.
The PA DEP should consider whether it is necessary to set a baseline total solids acceptance criteria.
This is important since biosolids with higher water content are more likely to result in nuisance
conditions, espt;cially undigested biosolids.
The EARTHRES response dated December 28, 2018 states no response is required at this time.
15. Form Rl- Waste Analysis and Classification Plan (Page 127/198): SBHRC will provide a notice to
PADEP if a new inbound solids source has been identified. Please clarify if Plainfield Township will also
have the opportunity to review and approve new biosolids source prior to shipment to SBHRC.
The EARTHRES response dated October 26, 2018 states that the final acceptance process will be
determined during the PA DEP permit review process; the proposed plan calls for SBHRC to submit
documentation from new sources to PA DEP for approval; and if desired the SBHRC can notify Plainfield
Township of the submission and the Township can provide camments to PA DEP as part of the review
process.
Plainfield Township desires to be notified of such submissions and to be given the opportunity to
comment to PA DEP as part of the review process.
The EARTHRES response date~ December 28, 2018 states Plainfield Township will be copied on
correspondence submitted to PA DEP regarding a proposed new source of biosolids to be accepted at the
SBHRC facility.
If PA DEP issues a permit for this facility, it should consider including a permit condition requiring
SBHRC to copy Plainfield Township on correspondence submitted to PA DEP regarding a proposed
new source of biosolids to be accepted at the SBHRC facility.
16. Form Rl- Waste Analysis and Classification Plan (Page 127/198): Will any quantity restrictions
be placed on incoming biosolids sources?
The EARTHRES response dated October 26, 2018 states that SBHRC proposes to accept up to 400 wet
tons per day of biosolids on an average annual basis.
The EARTHRES response letter speaks to total tons on average annual basis, whereas this question
asks about limits on sources. Does PA DEP plan to consider setting limits on sources?
The EARTHRES response dated December 28, 2018 states no source limits are anticipated or needed. If
biosolids are acceptable, the primary limit will be processing capacity.
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ENGINEERS
General Waste Processing App!. Comments, cont'd Nov. 6, 2018 (Updated Jan. 17, 2019)
The PA DEP should consider the possible need to limit sources as part of its review of the permit
application.
17. Form Rl- Waste Analysis and Classification Plan (Page 127/198): Will SBHRC accept digested
and undigested biosolids alike? Undigested solids, particularly with higher water content, have the
potential to generate additional odor concerns.
The EARTHRES response dated October 26, 2018 states that SBHRC proposes to accept digested and
undigested biosolids.
The acceptance of undigested biosolids increases the importance for PA DEP to carefully review this
permit application to insure proper design, construction, operation, and maintenance of the proposed
facility to prevent nuisance odors. As already explained in the Township's comment letter to the
Department dated October 17, 2018, a fully developed Nuisance Control Plan must be provided with
this Permit Application.
The EARTHRES response dated December 28, 2018 states SBHRC has been developing a complete
Nuisance Management and Control Plan (NMCP) in conjunction with Plainfield Township and Material
Matters, Inc. This NMCP will address all potential nuisances related to the proposed facility. A copy of
the completed plan will be provided when available.
18. Form Rl- Waste Analysis and Classification Plan (Page 127/198): It is unclear from the permit
application if periodic recertification of inbound biosolids is reqUired in addition to the acceptance
testing prior to shipment. Please clarify.
The EARTHRES response dated October 26, 2018 states that recertification procedures will be determined
upon issuance of the General Permit and in accordance with Federal and State regulations, and SBHRC
currently anticipates annual recertification.
The EARTHRES response dated December 28, 2018 states no response required.
19. Form Rl- Waste Analysis and Classification Plan (Page 127/198): Is the intention that biosolids
processed at SBHRC rather than at the landfill will also require Form 26R prior to acceptance? If so,
please clarify.
The EARTHRES response dated October 26, 2018 states that GCSL and SBHRC are separate operations
with separate waste acceptance procedures. Biosolids acceptance for drying and beneficial use will be
separate from biosolids acceptance for landfill disposal. It is anticipated that SBHRC will need to
complete a Form 43 - Request for Approval to Process or Dispose of Sewage Sludge for each source
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ENGINEERS
ATe GROUP SERVICES LLe
General Waste Processing Appl. Comments, cont'd Nov.~2018{UpdatedJan.1~2019}
proposed for drying at the facility. Final requirements will be provided upon issuance of the General
Permit.
The EARTHRES response doted December 28, 2018 states no response required.
20. Form Rl- Waste Analysis and Classification Plan, Table 1- Pollutant Concentration Limits {Page
127/198}: Please clarify if there are additional analytes besides the list in Table 1 that comprise the
acceptance criteria for incoming biosolids {beryllium, chromium, etc.}.
The EARTHRES response doted October 26, 2018 states that the parameters listed in Table 1 of the
Waste Analysis and Classification Plan (Form R1) are the proposed acceptance criteria for SBHRC.
127/198}: Will incoming biosolids be required to undergo a TCLP test?
The EARTHRES response dated October 26, 2018 states that biosolids do not typically undergo a TCLP
test and SBHRC will comply with all testing requirements issued in the General Permit.
127/198}: If SBHRC will accept only digested sludge, will fecal testing be performed on incoming solids
sources to verify pathogen reduction?
The EARTHRES response doted October 26, 2018 states this comment is not applicable since SBHRC plans
to accept both digested and undigested biosolids. Fecal testing will be performed on the finished
(pelletized) product in accordance with the corresponding SOP (Attachment A) in order to demonstrate
compliance with 40 CFR Part 503, Part 136.
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ENGINEERS
ATC GROUP SERVICES liC
General Waste Processing Appl. Comments, cont'd Nov. 6, 2018 (Updated Jan. 17, 2019)
23. Form R1- Waste Analysis and Classification Plan, Table 1- Pollutant Concentration Limits (Page
127/198): If SBHRC will accept only digested sludge, will verification of specific vector attraction
reduction options (VS reduction, SOUR, etc.) be required prior to acceptance?
The EARTHRES response dated October 26, 2018 states this comment is not applicable since SBHRC plans
to accept both digested and undigested biosolids.
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ENGINEERS
ATe GROUP SERVICES LLC
Review Comments
NPDES Application for Individual Permit to Discharge Industrial Stormwater
November 6, 2018
(Updated January 17, 2019)
1. The NPDES Application for Individual Permit to Discharge Industrial Stormwater (IW Stormwater
Permit Application) states that stormwater from the facility will discharge into an existing non-
discharging, engineered, permitted, designed stormwater control pond known as Sediment Basin #2
located on Grand Central Sanitary Landfill (GCSL) property, and that Sediment Basin #2 is associated
with Outfall #012 in GSL's NPDES Permit No. PA0074083. GCSL's current NPDES Permit No PA0074083
effective July 1, 2016 through June 30, 2021 does not list Outfall #012. This needs to be clarified. Also,
has an evaluation been performed to determine whether or not discharge of stormwater to this pond
would affect any nearby ground water sources?
The EARTHRES response dated October 26, 2018 states that Sediment Basin No. 2's original design
included a discharge barrel identified as Outfall 012 in the GCSL NPDES Permit No. PA0074083.
However, the basin discharged to surface water and the discharge barrel was never constructed. For this
reason GCSL requested that Outfall 012 not be included in the 2016 NPDWES permit renewal. The
response letter states that GCSL has several nearby groundwater wells that are monitored and sampled
quarterly, and that these wells provide background data for the areas surrounding the proposed SBHRC
facility.
The response letter does not indicate that an evaluation has been performed to determine whether or
not discharge of storm water to Basin #2 would negatively groundwater. Sedimentation Basin No.2
originated from an abandoned quarry pit and is directly connected to ground water. PA Code Title 25,
Chapter 91.51{a) states in part, "The Department will, except as otherwise provided in this section,
consider the disposal of wastes, including stormwater runoff, into the underground as potential
pollution, unless the disposal is close enough to the surface so that the wastes will be absorbed in the
soil mantle and be acted upon by the bacteria naturally present in the mantle before reaching the
underground or surface waters." Sedimentation Basin No.2 does not meet the Department's
requirements for stormwater infiltration basins contained in Pennsylvania's Stormwater Best
Management Practices Manual (DEP Document ID #363-0300-002). The permit application does not
include a hydrogeology evaluation and fails to demonstrate that the proposed stormwater discharge
to Sedimentation Basin No.2 would meet water quality standards necessary to protect groundwater
uses.
The EARTHRES response dated December 28, 2018 states this issue has been addressed by other
submissions to the Township and PA DEP and refers to the December 28, 2018 letter to Jason Smith of
Hanover Engineering and anticipated January 2019 response letter to the Plainfield Township Zoning
Officerfor a complete response.
BCM/ATC has reviewed the additional information as referenced in the EARTH RES response dated
December 28, 2018. The additional information fails to demonstrate that the proposed stormwater
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ENGINEERS
NPDES IW Stormwater App!. Comments, cont'd. Nov.~2018(UpdatedJan. 17,2019)
discharge to Sedimentation Basin No.2 would meet water quality standards necessary to protect
groundwater uses. Phil Gray, PG, reviewed the Consolidated Hydrogeological Package included with
the December 28, 2018 submission and provided comments in a memorandum dated January 16,
2019 (copy attached). The memorandum includes the following conclusions and recommendations:
1. Any uncontained releases from the biosolids operation which come in contact with
stormwater will flow into Basin No.2 and migrate into shallow and bedrock aquifers and
eventually discharge into the Little Bushkill and Waltz Creek's. Any contaminants associated
with the biosolids operation in the stormwater may impact groundwater and surface water
quality.
2. A well search should be completed to identify all water wells in the area including, but not
limited to, potable supply, irrigation, monitoring, industrial supply, injection, etc. Any water
quality data from those wells should be provided and a discussion of how pumping or
recharge from those wells affect groundwater flow.
3. Stormwater from the chemical and petroleum containment area, identified as a portion of the
discharge from Outfall 005, should be pumped into the wastewater containment tank.
4. Further evaluation is needed regarding how stormwater may be impacted from the
equipment storage areas.
2. The permit application should contain calculations used to determine the amount of stormwater
that will be captured and diverted to the wastewater holding tank. What is the square footage of the
involved areas? What is the design storm frequency? Has sufficient capacity for diverted stormwater
been factored into the proposed 100.000 gallons per day design wastewater flow and the proposed
300,000 gallon holding tank capacity? Will the system be operated and maintained so that there will
always be enough reserve capacity available in the holding tank to capture runoff from the design
storm? How will stormwater from these areas be managed during weather events that exceed the
design storm frequency? Would it be feasible to install a roof over the receiving end of the facility in
order to reduce the amount of stormwater that would need to be diverted to the wastewater holding
tank?
The EARTHRES response dated October 26, 2018 includes calculations showing how the 100,000 gallons
per day wastewater flow has been estimated. The calculations include a breakdown of process waste
water sources consisting of dryer condensate (76J39 gal/day); storm water (19,616 gal/day); process
and tailgate wash water (1,000 gal/day); and odor control system discharge (720 gal/day). The
estimated stormwater flow is based upon a 25-year stem event (6" over 24 hours). The proposed areas
where storm water would be captured as process wastewater are shown as follows: Receiving Units-
lA52 sq. ft. Truck Unloading - 2,363 sq. ft. and Product Loadout -1430 sq. ft. The total estimated flow
including a 25-year storm event is 98,075 gallons per day. The response states that even if a 25-year
storm event occurs each day over a three day period the SBHRC will be generating less than 100,000
gallons per day of wastewater, and if larger amounts of precipitation are expected the facility will
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ENGINEERS
NPDES IW Stormwater Appl. Comments, cont'd. Nov. 6, 2018 {Updated Jan. 17,2019)
monitor the wastewater tank level to ensure levels not exceeded. The response states there are no plans
for a roof over the receiving area.
Additional details should be provided describing how the tank level will be monitored. What type of
mechanism will be used to monitor the tank level, what it the design high level, how frequently will
the level be checked, is a high water alarm necessary, etc.? Also, it is recommend that a Standard
Operating Procedure be required for this.
The EARTHRES response dated December 28, 2018 states the wastewater ~torage tank will be equipped
with a level transducer (or equivalent) to measure the wastewater level in the storage tank. When the
tank level reaches a predetermined capacity, the level instrument will activate a high-level alarm
warning the facility. At this point the wastewater storage tank will have adequate capacity for
approximately one day of wastewater generated from the drying process, including a 25 year storm
event (6" over 24 hours), tailgate wash water, and the odor control system discharge. Storage tank
freeboard requirements will be in accordance with adopted Federal and State regulations and design
practices. An SOP for wastewater management will be developed prior to facility construction.
permit condition requiring submission of the SOP prior to facility construction.
3. The IW Stormwater Permit Application indicates that the NPDES Application to Discharge
Stormwater Associated with Construction Activities (Construction SW Permit Application) was not yet
submitted to DEP. It would be preferable for Construction Stormwater Permit Applications to be
submitted sooner rather than later in order to determine if there are any Best Management Practices
(BMPs) that could be installed during construction and possibly retained as IW Stormwater BMPs, in
addition to the prosed grass lined swale.
The EARTHRES response dated October 26, 2018 states that the Construction Storm water permit
Application has been submitted to PA DEP and is currently under review. The response letter includes a
list of the BMP's that will be employed. The response states that Sediment Basin No.2 will provide
erosion and sedimentation control for SBHRC during construction and serve as a post-construction
storm water management BMP; and that storm water from the SBHRC bUilding, driveway and parking
area will be conveyed to Basin No 2 via a grass line swole.
As stated under comment 1 above, Sedimentation Basin No.2 originated from an abandoned quarry
pit and is directly connected to ground water. PA Code Title 25, Chapter 91.51(a) states in part, "The
Department will, except as otherwise provided in this section, consider the disposal of wastes,
including stormwater runoff, into the underground as potential pollution, unless the disposal is close
enough to the surface so that the wastes will be absorbed in the soil mantle and be acted upon by the
bacteria naturally present in the mantle before reaching the underground or surface waters./I
Sedimentation Basin No.2 does not meet the Department's requirements for stormwater infiltration
basins contained in Pennsylvania's Stormwater Best Management Practices Manual (DEP Document
ID #363-0300-002). The permit application does not include a hydrogeology evaluation and fails to
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SCM
ENGINEERS
NPDES IW Stormwater Appl. Comments, cont'd. Nov. 6, 2018 (Updated Jan. 17,2019)
demonstrate that the proposed stormwater discharge to Sedimentation Basin No.2 would meet
water quality standards necessary to protect groundwater uses.
submissions to the Township and PA DEP and refers to the December 28, 2018 letter to Jason Smith of
Hanover Engineering and anticipated January 2019 response letter to the Plainfield Township Zoning
Officer for a complete response.
See comments under item 1, above.
4. The site plans should identify a staging area for times when more than one delivery vehicle
arrives at the facility. Also, the permit application should evaluate and identify stormwater
management features and best management practices for the staging area.
The EARTHRES response dated October 26, 2018 states that the site will provide adequate space for
trucks to maneuver, deliver their cargo, load with product or wastewater, and exit the site; that the
receiving area can accommodate two trucks at the same time; that the product load-out area can
accommodate one truck; and that trucks will not be parked overnight at the SBHRC facility.
If issued, the PA DEP should include conditions on the General Permit reflecting the above (prohibit
overnight parking of vehicles and limit the number of be of trucks that can be on site at any given
time).
The EARTHRES response dated December 28,2018 states no response required.
The above comment should be flagged for follow-up in regards to PA DEPs consideration of this
matter during review of the permit application.
5. NPDES Application Form: On Page 5, Item 10 - List of Outfalls. The language on line one should
be revised to list all the areas from which stormwater will be collected and transported to offsite
disposal (not just stormwater from the truck loading pad).
The EARTHRES response dated October 26,2018 states that storm water that falls within the
containment areas of the receiving units, truck unloading area, and product loadout area will be
conveyed to the process wastewater storage tank and handled as process wastewater.
Conflicting/unclear information in the permit application should be revised accordingly.
The EARTHRES response dated December 28, 2018 states that precipitation falling on the
loading/unloading tipping area and the product load out area will be contained and conveyed to the
wastewater storage tank for offsite disposal as process wastewater. Precipitation falling in the storage
tank and the thermal oil containment areas will be tested and released if not contaminated. Details on
the sampling and testing requirements are contained in the draft NPDES permit and the EARTHRES
response.
Conflicting/unclear information in the permit application documents should be revised accordingly.
-4-
BCM
ENGINEERS
NPDES IW Stormwater App!. Comments, cont'd. Nov.~2018(UpdatedJan. 17,2019)
6. Module 1- Anti-Degradation Supplemental Narrative: The third paragraph on Page 1 contains

language which could be read to imply that it is optional as to whether stormwater from the biosolids
receiving area and the product loading pad will be conveyed to the process wastewater storage tank or
discharged. This paragraph should be revised to make it clear that any spills and stormwater from the
biosolids receiving area and the product loading pad will at all times be conveyed to the process
wastewater storage tank.
The EARTHRES response dated October 26,2018 states that storm water that falls within the
containment areas listed in the previous comment will be conveyed to the process wastewater storage
tank for offsite disposal.
Conflicting/unclear information in the permit application should be revised accordingly.
The EARTHRES response dated December 28, 2018 states that precipitation falling on the
loading/unloading tipping area and the product load out area will be contained and conveyed to the
wastewater storage tank for offsite disposal as process wastewater. Precipitation falling in the storage
tank and the thermal oil containment areas will be tested and released if not contaminated. Details on
the sampling and testing requirements are contained in the draft NPDES permit and the EARTHRES
response.
Conflicting/unclear information in the permit application documents should be revised accordingly
7. Appendix G, Standard Operating Procedures contains a note stating "To be added upon
completion of Facility Construction. It is recommended that draft SOPs or SOPs outline be should be
included with the permit application.
The EARTHRES response dated October 26, 2018 includes a list of sOPs included in the General permit
application and a copy of a new draft SOP for unloading, tailgate washing, and loading of incoming and
outgoing trucks. The response also notes that transportation of biosolids and wastewater to and from
SBHRC must comply with the Waste Transportation and Safety Act (Act 90) and states that SBHRC will
prepare and adhere to a Transporter Contingency Plan.
A Draft Transporter Contingency Plan should be required with the General Permit Application. Also, it
is recommended that a Standard Operating Procedure be required for the wastewater storage tank.
The EARTHRES response dated December 28, 2018 states agreed and required SOP's will be provided
prior to start-up.
It would be preferable for the proposed Transporter Contingency Plan and Wastewater Storage Tank
SOP to be submitted to the PA DEP during the permit application review process. Otherwise, if PA
DEP issues a permit for this facility it should include a permit condition requiring submission of the
SOP prior to facility construction.
8. For completeness sake, Questions 1.0 and 2.0 on the General Information Form should be
answered. Also, evidence of newspaper publication should be provided.
-5-
BCM
ENGINEERS
NPDES IW Stormwater Appl. Comments, cont'd. Nov. 6, 2018 (Updated Jan. 17,2019)
The EARTHRES response dated October 26,2018 states that Boxes 1.0 and 2.0 will be checked "No" and
the revised GIF will be submitted if requested by PA DEP. Documentation of newspaper publication was
also provided.
Agree.
9. Below are additional comments based upon review of the Draft NPDES Permit as provided to
Slate Belt Heat Recovery Center LLC by the PA DEP, under cover letter dated September 18,2018:
a. The permit application and the draft NPDES permit fail to support the assertion that
only uncontaminated stormwater runoff will be discharged to Sedimentation Basin No 2. The
proposed discharge includes storm water runoff from vehicle access and parking areas
susceptible to contamination from leaks or spills. The permit application and the draft NPDES
permit fail to demonstrate that the proposed grass-lined swale will result in a discharge
suitable to protect groundwater.
b. The permit application should contain detailed information regarding the type of
vehicle that is proposed to be used for hauling materials into and out of the site. In response
to previous comments on this matter the applicant has indicated it plans to utilize a possum
bottom trailer capable of handling solids and liquids and the trailer will be tarped during
transport. A cut sheet for the trailer is included with the response letter. The Trailer Cut
Sheet provided lacks sufficient details to demonstrate how the tailgate will seal in order
prevent leaks from the biosolids compartment. Has the Pennsylvania Department of
Environmental Protection (DEP) seen these trailers used for this purpose elsewhere? If so,
have there been problems with leaks or odors?
c. The effluent limitations monitoring frequency in the draft NPDES permit should be
increased from once per six months to once per month.
d. In the draft NPDES permit, under Part C.III. Routine Inspections, the inspection
frequency should be increased from semi-annual to weekly, at a minimum.
e. In the permit application, under Appendix G, Standard Operating Procedures there is a

note stating "To be added upon completion of Facility Construction." Draft SOPs should be
required with the permit application.
f. On Page 10 of the NPDES Permit Fact Sheet it states, "The client (SBHRC) has no open
violations per 9/13/2018 WMS Query (Open Violations for Client). This is due to the fact that
SBHRC is a newly created entity with no existing DEP permits or authorizations. With regards
to this permit application DEP should consider SYNAGRO as the client for compliance history
review purposes.
-6-
BCM
ENGINEERS
NPDES IW Stormwater Appl. Comments, cont'd. Nov. 6, 2018 (Updated Jan. 17, 2019)
The EARTHRES response dated December 28, 2018 states that comments have been provided to the PA
DEP by EARTHRES on the draft NPDES permit. To assist in the trailer evaluation Synagro provided
references for the possum bottom trailer.
The above comments should be flagged for follow-up in regards to PA DEP's consideration of these
matters during review of the permit application.
Attachment: Gray Memorandum dated 01/16/2019
-7-
ATC Group Services LLC
920 Germantown Pike, Suite 200
Plymouth Meeting, PA 19462
Telephone 610-313-3100
Fax 610-313-3151
ENVIRONMENTAL· GEOTECHNICAL WMv.atCQroupservices.com
BUILDING SCIENCES· MATERIALS TESTING
INTEROFFICE MEMORANDUM
TO: MICHAEL J. BRUNAMONTI, PE
FROM: PHIL GRAY, PG
SUBJECT: SLATE BELT HEAT RECOVERY CENTER, CONSOLIDATED

HYDROGEOLOGICAL PACKAGE
DATE: 01/16/2019
Mike,
ATC Group Services LLC (ATC) has reviewed the Consolidated Hydrogeological Package
(Report) for Doney II Quarry prepared for Slate Belt Heat Recovery Center, LLC for the
proposed Biosolids processing facility located at Grand Central Sanitary Landfill's (GCSL)
property in Plainfield Township, Northampton County, PA, which was prepared by
Earthres Group, Inc. and dated December 2018.
The Doney" quarry was reclaimed with permission from the Pennsylvania Department of
Environmental Protection (Department). After reclamation, the former quarry was
repurposed as a sedimentation basin (referred to as "Basin No.2") for GCSL.
The dewatering calculations in the Report describe the amount of stormwater entering the
basin for multiple 1OO-year storm events, the rate of infiltration through the quarry backfill
material, the flow through shallow perched and bedrock aquifer systems, and the rate of
discharge to Little Bushkill Creek and Waltz Creek. Based upon the assumptions in the
Report, Earthres concludes there will be no measurable change to the baseflow of Little
Bushkill Creek and Waltz Creek.
Groundwater quality information for the Slate Hills Site was provided which indicates
groundwater was adversely impacted. Groundwater flow was diverted from a spring
source to protect water quality. The method of groundwater flow diversion was not
described and the location of the spring was not identified on Figures 1A through 14. This
information should be provided.
Water quality data from Little Bushkill Creek and Waltz Creek was also discussed in the
Report. The Report concludes existing operations at the GCSL and surrounding quarries
has not significantly impacted surface water quality "based on available data".
Process wastewater from the biosolids operation will be contained in a wastewater storage
tank for off-site disposal along with stormwater and washwater contained in the truck
unloadinglloading areas. The remaining stormwater from the site will be permitted through
- -----. -
920 Germantown Pike. Suite 200
Fax 610-313-3151
ENVIRONMENTAL' GEOTECHNICAL vNIW.alcqroupservices.com
BUllDltlG SCIENCES· MATERIALS TESTING
seven (7) outfalls identified in the draft NPDES permit as O'utfalls 001 through 007. There
are equipment storage areas within the boundaries of the stormwater outfalls, which may
adversely impact strormwater quality.
ATC offers the following conclusions and recommendations:
stormwater will flow into Basin NO.2 and migrate into shallow and bedrock aquifers
and eventually discharge into the Little Bushkill and Waltz Creek's. Any
contaminants associated with the biosolids operation in the stormwater may impact
groundwater and surface water quality.
2. A well search should be completed to identify all water wells in the area including,
but not limited to, potable supply, irrigation, monitoring, industrial supply, injection,
etc. Any water quality data from those wells should be provided and a discussion
of how pumping or recharge from those wells affect groundwater flow.
3. Stormwater from the chemical and petroleum containment area, identified as a

portion of the discharge from Outfall 005, should be pumped into the wastewater
containment tank.
Please let me know if you have any questions regarding this matter. Thank you.
2
BCM
ENGINEERS
GCSL Minor Mod. Appl. Comments, cont/d. Nov.~2018(UpdatedJan.17,2019)
The EARTHRES response dated October 26, 2018 states that the E&S plan for this projeCt was submitted
to PA DEP as part of the GCSL Application for Minor permit Modification.
The EARTHRES response dated December 28, 2018 states Agreed.
Stormwater Management Plan
1. It is unclear how the proposed basin will discharge stormwater flows while maintaining a
permanent pool elevation. Documentation should be provided as to the de-watering method and de-
watering time of the proposed basin.
The EARTHRES response dated October 26, 2018 states that Basin 2 can store over the 100-year storm
event within the proposed configuration, supporting calculations are included in the Storm water
Management Report submitted as part of the Land Development submission to Plainfield Township,
Basin levels return to the typical pool elevation following storm events, and no surface water discharges
from Basin 2 have occurred in the past 20 years.
Sedimentation Basin No.2 originated from an abandoned quarry pit and is directly connected to
ground water. PA Code Title 25, Chapter 91.51(a) states in part, ''The Department will, except as
otherwise provided in this section, consider the disposal of wastes, including stormwater runoff, into
the underground as potential pollution, unless the disposal is close enough to the surface so that the
wastes will be absorbed in the soil mantle and be acted upon by the bacteria naturally present in the
mantle before reaching the underground or surface waters." Sedimentation Basin No.2 does not
meet the Department's requirements for stormwater infiltration basins contained in Pennsylvania's
Stormwater Best Management Practices Manual (DEP Document ID #363-0300-002). The permit
application does not include a hydrogeology evaluation and fails to demonstrate that the proposed
stormwater discharge to Sedimentation Basin No.2 would meet water quality standards necessary to
protect groundwater uses.
submissions to the Township and PA DEP, and refers to the December 28, 2018 letters to the Plainfield
Township Zoning Officer and Jason Smith of Hanover Engineering for a complete response.
BCM/ATC has reviewed the additional information as referenced in the EARTH RES response dated
December 28, 2018. The additional information fails to demonstrate that the proposed stormwater
discharge to Sedimentation Basin No.2 would meet water quality standards necessary to protect
groundwater uses. Phil Gray, PG, reviewed the Consolidated Hydrogeological Package included with
2
BCM
ENGINEERS
ATC GROUP SERvrCES LLC
GCSL Minor Mod. Appl. Comments, cont'd. Nov. 6, 2018 (Updated Jan. 17,2019)
eventually discharge into the Little Bushkill and Waltz Creek's. Any contaminants associated
quality.
2. Per Section 23-307.1 of the Stormwater Management Ordinance "Stormwater runoff from all
development sites shall be calculated using either the Rational Method or the soil-cover-complex
methodology." The Stormwater Narrative states that the hydrographs from the original calculations
utilizing the VTPSUHM program were imported into the Hydroflow Program. For new development, the
SCS Methodology should be utilized along with new rainfall intensity data consistent with that shown in
Section 23-307.10 of the Stormwater Management Ordinance and should take into account the revised
curve numbers for the drainage areas containing proposed impervious surfaces.
The EARTHRES response dated October 26, 2018 states that the Stormwater Management Report has
been revised since its original submittal and is currently under review by the Township and the Lvpc.
The Township and LVPC should consider whether or not the above comments have been taken into
account during their review of the revised Stormwater Management Report.
3. The Stage Storage listed in the narrative under the heading "Southern Expansion Basin 2 Storage
Volume Table - 39% Reduction" does not match the Stage Storage table listed in the Hydrograph model.
The EARTHRES response dated October 26,2018 states that the Stormwater Management Report has
3
BCM
ENGINEERS
ATC GROUP SERVfCES LLC
GCSL Minor Mod. Appl. Comments, cont'd. Nov. 6, 2018 (Updated Jan. 17, 2019)
eventually discharge into the little Bushkill and Waltz Creek's. Any contaminants associated
quality.
2. Per Section 23-307.1 of the Stormwater Management Ordinance "Stormwater runoff from all
development sites shall be calculated using either the Rational Method or the soil-cover-complex
methodology." The Stormwater Narrative states that the hydrographs from the original calculations
utilizing the VTPSUHM program were imported into the Hydroflow Program. For new development, the
SCS Methodology should be utilized along with new rainfall intensity data consistent with that shown in
Section 23-307.10 of the Stormwater Management Ordinance and should take into account the revised
curve numbers for the drainage areas containing proposed impervious surfaces.
The EARTHRES response dated October 26, 2018 states that the Stormwater Management Report has
The Township and Lvpe should consider whether or not the above comments have been taken into
3. The Stage Storage listed in the narrative under the heading "Southern Expansion Basin 2 Storage
Volume Table - 39% Reduction" does not match the Stage Storage table listed in the Hydrograph model.
The EARTHRES response dated October 26,2018 states that the Stormwater Management Report has
3
BCM
ENGINEERS
GCSL Minor Mod. Appl. Comments, cant'd. Nov.6,2018(UpdatedJan.17,2019)
The Township and LVPC should consider whether or not the above comment has been taken into
The EARTHREs response dated December 28, 2018 states Agreed.
4. Per Section 23-307.8 of the Stormwater Management Ordinance "All stormwater detention
facilities shall provide a minimum 1.0 foot freeboard above the maximum pool elevation associated with
the two-year through twenty-fIve-year runoff events. A 0.5 foot freeboard shall be provided above the
maximum pool elevation of the one-hundred-year runoff event. The freeboard shall be measured from
the maximum pool elevation to the invert of the emergency spillway. The two-year through one-
GCSL Minor Comments, cont'd. November 6,2018
hundred-year storm events shall be controlled by the primary outlet structure. An emergency spillway
for each basin shall be designed to pass the one-hundred-year return frequency storm peak basin inflow
rate with a minimum 0.5 foot freeboard measured to the top of basin." The 100 year ponding elevation
listed in the stormwater management report is 703.86 which does not provide 0.5 feet of freeboard
between the 100 year maximum elevation and the emergency spillway invert of 704.00.
The EARTHREs response dated October 26, 2018 states that the Storm water Management Report has
General Comments
1. The drawings provided for review with the stormwater management narrative do not
adequately show the existing or proposed drainage features. Please provide drawings at a scale that
clearly conveys the required data.
The EARTHREs response dated October 26, 2018 states that the stormwater Management Report has
4
BCM
ENGINEERS
GCSL Minor Mod. Appl. Comments, cont'd. Nov. 6, 2018 (Updated Jan. 17,2019)
2. Detail Drawings were not provided for Channels or Basins. Therefore, review for consistency
with the design narrative could not be performed.
The EARTHREs response dated October 26, 2018 states that the Storm water Management Report has
been revised since its original submittal and is currently under review by the Township and the LVPC.
The EARTHREs response dated December 28, 2018 states Agreed.
Attachment: Gray Memorandum dated 01/16/2019
5
Fax 610-313-3151
ENVIRONMENTAL' GEOTECHNICAL W/NJ.atcgroupservices.com
BUllDlIlG SCIENCES· MATERIALS TESTING
INTEROFFICE MEMORANDUM
TO: MICHAEL J. BRUNAMONTI, PE
FROM: PHIL GRAY, PG
SUBJECT: SLATE BELT HEAT RECOVERY CENTER, CONSOLIDATED

HYDROGEOLOGICAL PACKAGE
DATE: 01/16/2019
Mike,
ATC Group Services LLC (ATC) has reviewed the Consolidated Hydrogeological Package
(Report) for Doney" Quarry prepared for Slate Belt Heat Recovery Center, LLC for the
proposed Biosolids processing facility located at Grand Central Sanitary Landfill's (GCSL)
property in Plainfield Township, Northampton County, PA, which was prepared by
Earthres Group, Inc. and dated December 2018.
The Doney II quarry was reclaimed with permission from the Pennsylvania Department of
Environmental Protection (Department). After reclamation, the former quarry was
repurposed as a sedimentation basin (referred to as "Basin No.2") for GCSL.
The dewatering calculations in the Report describe the amount of stormwater entering the
basin for multiple 100-year storm events, the rate of infiltration through the quarry backfill
material, the flow through shallow perched and bedrock aquifer systems, and the rate of
discharge to Little Bushkill Creek and Waltz Creek. Based upon the assumptions in the
Report, Earthres concludes there will be no measurable change to the baseflow of Little
Bushkill Creek and Waltz Creek.
Groundwater quality information for the Slate Hills Site was provided which indicates
groundwater was adversely impacted. Groundwater flow was diverted from a spring
source to protect water quality. The method of groundwater flow diversion was not
described and the location of the spring was not identified on Figures 1A through 14. This
information should be provided.
Water quality data from Little Bushkill Creek and Waltz Creek was also discussed in the
Report. The Report concludes existing operations at the GCSL and surrounding quarries
has not significantly impacted surface water quality "based on available data".
Process wastewater from the biosolids operation will be contained in a wastewater storage
tank for off-site disposal along with stormwater and washwater contained in the truck
unloadinglloading areas. The remaining stormwater from the site will be permitted through
Fax 610-313-3151
ENVIRONMENTAL· GEOTECHNICAL www.atcgroupservices.com
BUILDING SCIENCES· MATERIALS TESTING
seven (7) outfalls identified in the draft NPDES permit as Outfalls 001 through 007. There
are equipment storage areas within the boundaries of the stormwater outfalls, which may
adversely impact strormwater quality.
ATC offers the following conclusions and recommendations:
stormwater will flow into Basin NO.2 and migrate into shallow and bedrock aquifers
and eventually discharge into the Little Bushkill and Waltz Creek's. Any
contaminants associated with the biosolids operation in the stormwater may impact
groundwater and surface water quality.
2. A well search should be completed to identify all water wells in the area including,
but not limited to, potable supply, irrigation, monitoring, industrial supply, injection,
etc. Any water quality data from those wells should be provided and a discussion
of how pumping or recharge from those wells affect groundwater flow.
3. Stormwater from the chemical and petroleum containment area, identified as a

portion of the discharge from Outfall 005, should be pumped into the wastewater
containment tank.
Please let me know if you have any questions regarding this matter. Thank you.
2
Plan Approval Review and Comments - EARTHRES Letter Dated October 26, 2018
ATC G.·oup Services

EARTHRES ATC GrouplBCM
Comments on
Permit Condition ID EARTlfimS Comments - Octoher Comments - Engineers (BCM)
Document Comment EARTHRES Response
or Section 26, 2018 Letter December 28, 2018 Comments on
Letter Dated October 26,
Letter 12/28/18 Letter
2018
Copies of all perntit
Review revised Plan
General Inforntation applications and
Since the answer to question 5.1 is Approval Application when
Form (GIF)- Question Nos. 5.0 and 5.1 have been EARTHRES No additional
Question 5.0 "yes", question 5.0 answer should be available to determine if
Coordination revised on the GIF per the comment. responses have been comments
"yes" revision is compliant with
Information provided to the
regulations.
Townshio
The sewage treatment facilities, Sanitary wastewater will be
sanitary sewcrs and/or sewage discharged to the local publically
pumping stations that makes this owned treatment works (Pen Argyl Review revised Plan
General Information This will be addressed
answer "yes" should be mentioned in Municipal Authority). The discharge Approval Application when Review PA DEP draft
FOrnt (GIF) - in accordance with
Question 8.0 "Project Inforntation - Project of sanitary wastewater is not a available to determine if permit and comment,
Coordination PA DEP regulations
Description" of the GIF and in processlsource of air emissions; revision is compliant with as necessary.
Information and the SBHRC PAA
Section B (Source Inforntation) of therefore, it has not been included in regulations.
the Application for Plan Approval Section B (Source Information) of the
Form 2700-PM-AOOO7 Annlication for Plan Aoorova] FOlm
SBHRC will be served by
General Information Review Letter of Approval
A Letter of Approval from the public Pennsylvania American Water.
Form (GIF)- when available to determine No additional
Question 16.0 water supplier should be obtained SBHRC is currently in the process of Agreed
Coordination if it is compliant with comments
and attached to the application obtaining a letter from Pennsylvania
Information regulations.
American Water stating that it will
The storage tanks emit PM
which is a regulated
The storage tanks required for this
The GIF will be revised to include pollutant. Therefore, the
project should be mentioned in
General Information language regarding the storage tanks. tanks should be included in This will be addressed
"Project Information - Project Review PA DEP draft
Form (GIF)- The storage tanks associated with the the air permit application. in accordance with
Question 22.0 Description" section of the GlF and permit and comment,
Coordination odor control system are not regulated Review GIF and Plan PA DE? regulations
in Section B (Source Information) of as necessary.
[nfomlation air sources since they do not contain Approval Application when and the SBHRC PAA
the Application for Plan Approval
VOCs or flAPs. available to determine if
Form 2700-PM-AQ007
they are compliant with
regulations.
Slate Relt Heat Recovery Center, LLC

ATC Group Services LLC Page # I Plainfield Township, Northampton County PA
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Comments on
Permit Condition TO EARTlffiES Comments - October Comments - Engineers (BCM)
Document Comment EARTl-IRES Response
or Section 26, 2018 Letter December 28, 2018 Comments on
2018
The sulfur content of natural gas
(NG), is anticipated to be 0.42
grains/! 00 SCF. The sulfur contenl of
Review revised Plan
the landfill gas (LFG) is estimated to This will be addressed
Application for Plan Approval Application when Review l'A DEI' draft
Provide the sulfur content of the be 402 ppm (25.14 grainsllOO SCPo in accordance with
Approval Fonn 2700- Section 8.2 - Fuel available to determine if permit and comment,
landfill gas Fuel to the heater will be a mix ofNG l' A DEI' regulations
PM-AQ007 revision is compliant with as necessary.
and LFG. The preferred fuel blcnd is and the SBHRC P AA
regulations.
70% LFG and 30% NG yielding a
sulfur cOntent of 17.75 grains/I 00
SCF based on Dresent data.
fs the heater rated heat input capacity
and maximum capacity 36.7 Review reviscd Plan
Section B.3 of the application has This will be addressed
Application for Plan MMBTUlhr. or 50.3 MMBTU/hr.'? Approval Application when Review PA DEI' draft
been revised to clarify that the in accordance with
Approval Fonn 2700- Section B.3 - Burner This needs to be clarified, so the availablc to dctermine if pemlit and comment,
maximum capacity of the burner is I' A DEI' regulations
PM-AQOO7 regulatory applicability and the PTE revision is compliant with as necessary.
50.0 MMBTUlhr. and the SBRRC PAA
calculations can be conducted regulations.
properly.
The type of relief is an "atmospheric
Review final design when
Application for Plan vent from relief valve" and the relief Adopted national code and design
Scction B.4 - Process available to determine if No additional
Approval Form 2700- valve/vent set prcssure (psig) is principles will be applied to the [mal Agreed
Storage Vessels revision is compliant with comments
PM-AQ007 "N/A". The relief valve set pressure design.
regulations.
.. should be soecified.
This is a sui furic acid storage tank
used to control ammonia emissions.
What will be the concentration of the
Application for Plan acid'? Materials of construction and Adopted national code and design
Section B.4.A.2 - available to determine if No additional
Approval Fonn 2700- design of the storage tank are principles will bc applied to the final Agreed
Process Storage Vessels revision is compliant with comments
PM-AQ007 dictated by the concentration stored. design.
regulations.
The vapor pressure needs to be
determined and presented in order to
design the tank vent.
Slate Belt Heal Recovery Ccnter. LLC

ATe Group Services LlC Page # 2 Plainfield Township, Northampton County PA
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Plan Approval Review and Comments - EARTHRES Letter Dated October 26,2018
ATC Group Selovices

Comments on
Permit Condition ID EARTHRES Comments - October Comments - Engineers (BCM)
or Section 26, 2018 Letter December 28,2018 Comments on
2018
The con~nrration of the sodium
Application for Plan hydroxide should be specificd since Adopted national code and design
Section BA.A.3 - available to determine if No additional
Approval Form 2700- it may impact the design of the tank principles will be applied to the final Agrccd
PM-AQ007 (freeze protection, etc.) and the design.
regulations.
safety and handling requirements.
The concentration of the sodium
Application for Plan hypochlorite should be specified Adopted national code and design
Section B.4.A.4 - available to determine if No additional
Approval Form 2700- since it may impact the design of the principles wiII be applied to the fmal Agrccd
PM-AQ007 tank and the safety and handling design.
regulations.
requirements.
The pressure relief valve is
a significant source when it
Identify and describe all fugitive Section B.6 has been revised to
is relieving. Pressure relief
points, all relicf and emergency include language regarding the
valves can vent huge
valves and any by-pass stacks: The exhaust points from the Supplemental
volumes of pollutants to the
text says "the only exhaust point to Thcrmal Oil Heater and the pressure
atmosphere when they lift
the atmosphere will be from the relief devices (there is only one relief
in an emergency or when PRY's will be
facility odor control stack (control device). Note that the pressure relief
Application tor Plan Section B.6 - they constantly leak addressed in Review PA DEI' draft
device). Other exhaust points to the valve is a trivial activity and is not
Approval Form 2700- MiscelIaneous through the seat. The accordance with PA permit and comment,
atmosphere include 1) Combustion considered an air pollution source;
PM-AQ007 [nformation pressure relief valve needs DEI' regulations and as necessary.
emissions from the Supplemental therefore, Section F.2 does not apply
to be included in the the SBHRC PAA
Themlal Oil Heater, 2) the 3 pressure and exhaust/stack information has not
application and it needs to
relief devices listed here. Where do bccn provided. Storage tank vents will
be monitored for leak-by.
the relief devices vent? The exhaust be designed and instaIJed according to
Review revised Plan
points to the atmosphere from the adopted national code by plans
Approval Application when
facility needs to be clarified. stamped by a PAPE.
available to determine if
revision is comoliant with
Section B.6 has been revised to
Describe how emissions will be
incorporate language regard ing Review revised Plan
minimized especially during start up. This will be addressed
Application for Plan Section 8.6 - emissions minimization during start Approval Application when Rcview PA DEP draft
shut down, nroccss upsets and/or in accordance with
Approval Form 2700- Miscellaneous up, shut down, process upsets and/or available to determine if pemlit and comment,
dismptions: The exhaust points to the PA DEP regulations
PM-AQOO7 Information disruption events fTom the revision is compliant with as necessary.
atmosphere from the facility need to and the SBHRC I' AA
Supplemental Thermal Oil Heater and regu lations.
be clarified.
tile nressure relief device exhaust
Slate Belt Heat Recovery Center. LLC
ATe Group Services LLC Page # 3 Plainfield Township, Northampton County PA
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Plan Approval Review and Comments - EARTI·IRES Letter' Dated October 26, 2018
ATC Group Services

Comments on
Permit Condition II) EARTHRES Comments - October Comments - Engineers (nCM)
or Section 26, 2018 Lette,' December 28, 2018 Comments on
Lette,' 12128/18 Letter
2018
Describe in Qctail the removal,
handling and disposal of dust,
effJJ)§nt etc. from the air cleaning Scction C.15 ha~ been revised to
device including proposed methods clarifY the exhaust points from the Review revised Plan
This will be addressed
Application for Plan of contrQ.l1ing fugitiv~.'§Jlltssions: Supplemental Thermal Oil Heater and Approval Application when Review PA DEP draft
Section C.15 - in accordance with
Approval Form 2700- ClarifY "the only exhaust point to the pressure relief device. Dust available to determine if permit and comment,
Miscellaneous PA DEP regulations
PM-AQ007 atmosphere" statement per previous collector solids handling and disposal revision is compliant with as necessary.
and the SBHRC PAA
comments. This section needs to will be by a facility pemlitted to regulations.
address how the dust collector solids accept the material.
will be handled and disposed
I (landfill. out into oroduct. other).
The PM-lO and PM-2.5 Ibs.lhr.

emissions data presented cannot be Facility-wide PM-lO and PM-2.S PTE
annualized to get the tpy values emissions include emissions from The Plan Approval
presented in the application (PM-I 0: paved and unpaved roadway activities Application should be This will be addressed
Application for Plan Review I' A DEP draft
Section F.I - Estimated 15.47 vs. 66.58 tpy) (PM-2.5: 9.92 in addition to the process sources. The revised to clarify the facility in accordance with
Approval Form 2700- permit and comment,
Atmospheric Emissions vs. 16.86 tpy) while the rest of the hourly emissions only includc process wide PM-IO and PM-2.5 I'A DEI' regulations
PM-AQOO7 as necessary.
lb.lhr. values presented can be sou.rces since roadway emissions are tpy potential-to-emit and the SBHRC I' AA
annualized to get the tpy values based on vehicle miles and not hours emissions.
present This needs to be reconciled of operation.
01' exolained.
Section F.2 has been revised to The pressure relief valve is
include specifications regarding the a significant air pollution
exhaust points from the Supplemental source when it is venting to
Thermal Oil Heater. Please note atmosphere (emergency
ClarifY "the only exhaust point to
Section F.2 does not apply to the situation or continuous leak- This will be addressed
Application for Plan atmosphere" statement per previous Review PA DEI' draft
Section F.2 • Stack and pressure relief device. The pressure by condition), therefore, it in accordance with
Approval Form 2700- comments. Information on all stacks permit and comment,
Exhauster relief valve for the HT thermal oil should be included in the FA DEI' regulations
PM-AQOO7 in the facility should be provided in as necessary.
heater inlet to the HT oil expansion air permit application. and the SBHRC PAA
the application
tank is a trivial activity and is not Review revised Plan
considered an air pollution source; Approval Application when
therefore, exhaust/stack infonnation available to determine if
has not been provided. revision is compliant with
Slate Belt Heat Recovery Cenler, LLC

ATC Group Services LLC Page II 4 Plainfield Township, Northampton County PA
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t............ • ..
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}'Iainfield Township, Northampton County
Plan Approval Review and Comments - EARTHRES Letter Dated October 26,2018
ATC Group Services

Comments on
Permit Condition ID EARTI·IRES Comments - October Comments - Engineers (BCM)
or Section 26,2018 Letter December 28, 2018 Comments on
2018
The Supplemental Thennal Oil
The Supplemental Heater features an
Heater is affected by 40 CFR 60
indirect heating/physical barrier Review revised Plan
Subpart Dc since it is a fuel heater This will be addressed
Attachment A - (closed air loop and closed thermal oil Approval Application when Review PADEP draft
Page 5: New Source that will be constructed after June 9, in accordance with
Application Narrative loop) design, therefore, the available to determine if permit and comment,
Perfonnance Standards 1989 and will have a maximum PA DE? regulations
and Regulatory Review Supplemental Thermal Oil Heater is a revision is compliant with as necessary.
design capacity ~ 10 and::: 100 and the SBHRC PAA
steam generating unit; thus, subject to regulations.
MMBtuIhr. The Application
NSPS Subpart Dc.
Narrative should be updated
The Supplemental Thermal
Oil Heater is subject tu
Process Heaters are affected by Subpart JJJJJJ, but there is
Subpart JJJJJJ and the Supplemental an exemption for gas-fired
Thermal Oil Heater meets the units. The air permit
The Supplemental Thermal Oil Heater
definition of a process heater (not application should say
will fire gas only and therefore is not This will be addressed
Attachment A - exempt as stated in the narrative), but Subpart JJJJJJ is applicable. Review PA DEP draft
Page 6: NESHAP subject to Subpart JJJJJJ requirements. in accordance with
Application Narrative there is a gaseous fuel exemption that The EP t\ will have to be pemlit and comment,
Subpart JJJJJJ Attachment A of the Plan Approval PA DEP regulations
and Regulatory Review exempts the Supplemental Thermal notified of the applicability as necessary.
Application has been clarified ancl the SBHRC PAA
Oil Heater from compliance with status with an initial
accordingly.
Subpart JJJJJJ. Therefore, Subpart notification. Review revised
JJJJJJ is not applicable. This should Plan Approval Application
be clarified. when available to determine
if revision is compliant with
resrulations.
The header Supplemental Heater and Review revised Plan
Dryer Facility (Non-Combustion Air) Approval Application when
Attachment B • Thc header has been updated per the in accordance with No additional
Pages 2 - 6 Emissions does not represent the data available to dctemline if
Emission Calculations comment. PA DEP regulations commcnts
presented. The data presented revision is compliant with
and the SBHRC PAA
includes combustiun air. regulations.
Slate Dell Heal Recovery Center. LLC

ATC Group Services LLC Page # 5 Plainfield Township, Northampton County PA
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~'"·.v ·"tt.\.. '~"",<:".'
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Slate Bclt Hcat Recovery Center, LLC
Plan Approval Review and Comments - EARTHRES Lcttcr Dated October 26, 2018
ATC Group Services

EARTIIRES ATC Group/HCM
Comments on
Permit Condition 10 EARTHRES Comments - October Comments - Engineers (HCM)
or Section 26, 2018 Lettcr December 28,2018 Comments on
Letter Dated Octobcr 26,
Lettcr 12/28/18 Letter
2018
Note (1) states that the proposed
maximum burner design firing ratt: is
50.3 MMBTUlhr. but the
calculations arc based on 36.7
MMBTU/hr. and the vendor (Sigma
Thermal) Quotation # STQ 170194
Rev I presented in Attachment C Review revised Plan
Attachment B of the Plan Approval This will be addressed
shows a design heat input of37 Approval Application when Review PA DEP draft
Attachmcnt B - Application has been revised to clarify in accordance with
Page 5 MMBTU/hr. The maximum design available to determine if permit and comment,
Emission Calculations that the maximum capacity of the PA DEP regulations
heat input is referenced throughout revision is compliant with as necessary.
burner is 50.0 MlvJBTUlhr. and the SBHRC PAA
the application as 36.7, 37.0 and 50.3 regulations.
MMRTU/hr. This needs to be
clarified throughout the application
and the emission calculations need to
be conducted on the equipment
maximum heat input design basis.
This update will roll throu c h the
Review revised Plan
Attachment F - Best Attachment F has been revised to Approval Application when Review PA DEP draft
Page 4 - Combustion Include NSPS Subpart Dc in accordance with
Available Technology include language regarding NSrS available to determine if permit and comment,
Emissions requirements to the discussion PA DEP regulations
(BAT) Analysis Subpart Dc. revision is compliant with as necessary.
and the SBHRC PAA
ree;ulations.
Slatc Belt Hcat Recovery Center. LLC

ATC Group Services LLC Page # 6 Plainfield Township. Northampton County PA
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.'1.." . "•••• Ito off. .""'.,..'.W·_··.,....."".·~ •.-""",,.,\,.,'.••"""""'_, ,....... ",,.,.• "..,"." "., ., .,....,.~' ..'.--, "W ~ " \. . " " ••• , ". ~"." ' • • • •, . . ~.-~, ~ • ...,~.""",,,,,,,,,,,,,,,,,,,,,.,,, ,, _._ .
ATC Group Services

Comments on
I'ennit Condition ID EARTHRES Comments - October Comments - Engineers (BCM)
or Section 26,2018 Letter December 28,2018 Comments on
2018
Under Section 127.14(a)(9), the PA DEl' has approved the
modification of the three (3) existing Request for Determination.
turbine exhaust stacks qualifies for Th~r~ is no evidence that
exemption if the change a) would not dispersion modeling was
violate etc. b) would not result etc. ill. conducted to detemline the
would not result in an increased ground level impacts
ambient air qualitv impact for an air Not applicable. The Request for (impacts to the people who
fQ!ilil.minant. The application states Determination (RFD) regarding the live in the community) due
Provide comments to
that after heat removal for the modifications of the three (3) existing to the changes as the basis
PA DEl' regarding the
SBHRC Project the flue gas would turbine stacks (Source IDs: SO I, S02 for the approval of the
need for dispersion
Request for Letter submittal to continue out a newly located stack at and S03) operated by Green Knight RFD. The approval of the No response required
modeling data to
Determination PADEl' a reduced temperature. Relocating Economics Development Corporation, RFD by l'A DEl' withuut a at this time.
justify the approval of
the stack emission point and [nco (GKEDC) was submitted to l'A dispersion modeling study
the Request for
reducing the temperature of the stack DEP on March 20, 2018 and was is not based on science and
Determination.
emission may have an impact on the approved by PA DE? on April 5, potentially puts the
ambient air quality. Dispersion 2018. community residence at
modeling is a way to determine the risk. P A DEP should
impact ofthese changes. The provide scientific
application should address the basis justification for the
tor the statement that "modiJications approval of the RFD or
will not result in an increased reverse its decision and
ambient air Quality impact for an air reQ uire a dispersion
The unloading facility
must be operated to
The capture of odor- facilitate compliance
The odor control capture velocity containing air generated with applicable permit Review the NMCP
None - Odor Control
Meeting of September should be designed to ensure all odor- This item was discussed at the during dumping of requirements and when it is completed
capture velocity during
19,2018 at Plainfield containing air generated during meeting attended by EARTl-lRES, biosolids from tTucks needs regulations. SBHRC to deteml ine if odor
dumping ofbiosolids
Township Building dumping ofbiosolids from truck is ATCIBCM and }'lainfield Township. to be designed properly so is working on a control is likely to be
from trucks.
caprurcd and sent to odor control. no odor escapes the odor NMCP with Plainfield achicvcd.
control device. Township and
Material Matters, Inc.
for the facility.
Slare Bell Heal Recovery Center. LLC

ATC Group Services LLC Page # 7 Plainfield Township, Northampton County I'A
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BCM Jan 2018 Review Synagro Land Development Plan Slate Belt Heat Recovery Center

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Droits d'auteur :

BCM Jan 2018 Review Synagro Land Development Plan Slate Belt Heat Recovery Center

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Droits d'auteur :

1001 Lackawanna Trail

January 17, 2019

Via email: manager@plainfieldtownship.org

Attention: Mr. Thomas R. Petrucci

Re: Proposed Slate Belt Heat Recovery Center

Dear Mr. Petrucci:

2. National Pollutant Discharge Elimination System (NPDES) Application for Individual

Mr. Thomas R. Petrucci, Township Manager January 17,2019

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

No further comments at this time.

See comments under item 1, above.

The EARTHRES response dated December 28,2018 states no response required.

Conflicting/unclear information in the permit application should be revised accordingly.

Conflicting/unclear information in the permit application documents should be revised accordingly.

6. Module 1- Anti-Degradation Supplemental Narrative: The third paragraph on Page 1 contains

Conflicting/unclear information in the permit application should be revised accordingly.

Conflicting/unclear information in the permit application documents should be revised accordingly

e. In the permit application, under Appendix G, Standard Operating Procedures there is a

Attachment: Gray Memorandum dated 01/16/2019

TO: MICHAEL J. BRUNAMONTI, PE

FROM: PHIL GRAY, PG

SUBJECT: SLATE BELT HEAT RECOVERY CENTER, CONSOLIDATED

ATC offers the following conclusions and recommendations:

3. Stormwater from the chemical and petroleum containment area, identified as a

The EARTHRES response dated December 28, 2018 states Agreed.

No further comments at this time.

Stormwater Management Plan

The EARTHRES response dated December 28, 2018 states Agreed.

No further comments at this time.

The EARTHRES response dated December 28, 2018 states Agreed.

No further comments at this time.

The EARTHREs response dated December 28, 2018 states Agreed.

No further comments at this time.

The EARTHRES response dated December 28, 2018 states Agreed.

No further comments at this time.

The EARTHRES response dated December 28, 2018 states Agreed.

No further comments at this time.

The EARTHREs response dated December 28, 2018 states Agreed.

No further comments at this time.

Attachment: Gray Memorandum dated 01/16/2019

TO: MICHAEL J. BRUNAMONTI, PE

FROM: PHIL GRAY, PG

SUBJECT: SLATE BELT HEAT RECOVERY CENTER, CONSOLIDATED

ATC offers the following conclusions and recommendations:

3. Stormwater from the chemical and petroleum containment area, identified as a

ATC G.·oup Services

Slate Relt Heat Recovery Center, LLC

ATC Group Services

Slate Belt Heal Recovery Ccnter. LLC

ATC Group Selovices

ATC Group Services