Public Hearing Comments

Slate Belt Heat Recovery Center LLC - Biosolids Processing Center

Plainfield Township, Northampton County
August 12, 2019
PA DEP Plan Approval No. 48-00111A

Good evening. My name is Gail Braden. I'd like to tell you a little about myself.

Gail Braden Biography

Chemical Engineering - University of Delaware
I worked for Dow Chemical for 20 years building and operating chemical plants
I have been and Environmental Consultant for the past 25 years providing multimedia services
(air water and waste).
For the past 25 years I have prepared air permit applications, written permit terms and
conditions and prepare air permit compliance programs for industrial clients. That is the basis
upon which I offer my comments on the Draft Plan Approval No. 48-00111A.
Relationship to Slate Belt Heat Recovery Project - Environmental consultant to Plainfield
Township so the Township has credible information on which to make decisions.

Purpose and Goals: Why are we all here?

The "interested parties" that have assembled here tonight have common goals.
Common Goals:
• Protect the health of the residents of the community
• Protect the environment of the community (air and water)
• Ensure the long-term prosperity of the Plainfield Township Community

Plainfield Township Board and Plainfield Township Residents - Goal

Achieve exceptional standards of performance, rather than regulatory minimums. The Board and
the residents desire to live in a community with an exceptional quality of life. The proposed
Biosolids Processing Facility needs to be exceptional to win the support of Plainfield Township.

How can we establish exceptional enforceable permit conditions?

Regulatory minimum requirements are the basis for the Plan Approval that has been prepared by
the PA DEP, but the Plainfield Township residents want the permit to reflect their desire to live
in a community with an exceptional quality oflife.

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Slate Belt Heat Recovery Center LLC (SBHRC) - Proposed General Actions:
• Design, build and operate a facility that meets exceptional environmental standards;
• Work with the DEP to put exceptional conditions in the permit that go beyond regulatory
mInImUmS;
• Prepare a plan for "What If Scenarios" (power failure - loss of control equipment, heavy
rain/flooding, truck accident - on public road or inside facility, other) ;
• Be proactive and strictly adhere to all terms and conditions in all of the permits;
• Conduct daily operations inspections, routine management inspections, and routine third
party compliance audits to ensure compliance with permit requirements and the
responsibility to be a good corporate citizen;
• Promptly identify and implement permanent solutions to all non-compliance issues;
• Do whatever it takes and work with unrelenting effort to solve all issues ASAP during the
permitting period and after project approval (if granted);
• Create goals and plans (with metrics) to achieve continuous improvement;
• Maintain lines of communications with community, ideas include:
a. Open House Events,
b. Public Meetings and Information Sessions,
c. Community-Right-to-Know communications with local police, fire, emergency
responders, and
d. Routine publications(s) with information of interest to the community;
• Be a good corporate citizen and operate the facility as if your employees and their
families lived in houses just outside the property line; and
• Conduct all business with full transparency.

PA DEP - General Actions

• The purpose of a "typical" Plan Approval is to establish enforceable emission limits,
applicable requirements, monitoring requirements, recordkeeping requirements, reporting
requirements and work practice standards per the PA regulations.
• The Plainfield Township Board and the residents in the community are asking for
conditions in the permit that will achieve exceptional performance, not just minimum
performance.
• Work with SBHRC to incorporate exceptional standards into the air permit.
• Incorporate Nuisance Mitigation Control Plan (NMCP) into the air permit. This is an
Operations and Preventive Monitoring Program and a Community Complaint Response
Plan related to nuisance odors (fugitive emissions) and dust (fugitive particulate matter).

Slate Belt Heat Recovery Center LLC (SBHRC) - Specific Actions:

Odors, Dusts and Visible Emissions

1. During operations - Strict compliance with exceptional permit conditions

2. Start-up, Shutdown and Equipment Malfunction - Use the "What-If' process" to identify
potential sources of odors, dust and visible emissions. Devise plans to mitigate the
problems
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 3. Biosolids Truck Transport to Facility - Use the "What-If' process to identify potential
sources of odors, dust and visible emissions. Devise plans to mitigate the potential
problems
4. Water Truck Transport from Facility - Use the "What-If' process to identify potential
sources of odors, dust and visible emissions. Devise plans to mitigate the potential
problems
5. Investigate innovative technical solutions to control odor in addition to the current plans

Monitoring and Recordkeeping

Odors, Dusts and Visible Emissions (ODV)

1. Pennit - Once daily at facility boundary for 6 months and weekly thereafter
2. Proposal- Daily monitoring of all processes with potential ODV emissions
3. Identify the best procedure to monitor each process with ODV emissions
4. Keep monitoring records of ODV emissions data
5. Keep records of community complaints
6. Keep records of equipment inspections, maintenance and repair
7. Establish metrics - track perfonnance
8. Identify and implement corrective actions
9. Reduce source emissions to zero ASAP
10. Control of source emissions will ensure facility boundary incidents
Sludge Receipts

1. Keep records of key parameters for each truckload

2. Relate the sludge data to OOV emissions data from process sources and facility boundary
3. Solve the problem(s) causing OOV emissions
4. Establish specifications for sludge
5. Identify sludge suppliers that cause ODV emissions
6. Tenninate contracts with suppliers that cause OOV emissions
Summary

1. Partner with the Plainfield Township Board and Citizens to ensure the long-tenn
prosperity of the Township and SBHRC (ifpennitted) by committing to exceptional
standards of perfonnance.
2. Design, build and operate an "exceptional" facility that is worthy of Plainfield Township
3. Tackle odors, dusts, and visible emissions at their source and reduce to zero ASAP
4. Monitor process operations and collect key infonnation to be used to achieve zero
environmental incidents.
Conclusion
The tenns and conditions put forth in the draft Plan Approval do not ensure the exceptional air
quality in Plainfield Township that the Board and the community residents require. The draft
Plan Approval needs to be significantly improved to meet the goals of the community. Anything
less is unacceptable. Thank You!

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