1001 Lackawanna Trail

BCM
ENGINEERS
Clarks Summit, PA 18411
Phone: (570) 587-3339
Fax: (570) 586-7989
www.atcgroupservices.com
ATC GROUP SERVICES LLC

March 8, 2018

Plainfield Township
6292 Sullivan Road
Nazareth, PA 18054

Attention: Mr. Thomas R. Petrucci

Township Manager

RE: Proposed Slate Belt Heat Recovery Center

Preliminary Land Development Application, February 23,2018

Dear Mr. Petrucci:

I have reviewed the information submitted with the Proposed Slate Belt Heat Recovery Center
Preliminary Land Development Application, dated February 23, 2018. My focus in reviewing these
documents was to provide the Township an overview of environmental permits or approvals that may
be required for the proposed facility. A preliminary list of environmental permits and approvals which
may be reqUired for the proposed project follows below.

1. PA DEP - Municipal Waste Processing Permit. The project involves processing of dewatered
biosolids at the proposed facility where it will be dried to produce a Class A biosolid that can be used as
fertilizer, soil conditioner, or renewable energy. A Municipal Waste Processing Permit will need to be
obtained for the processing facility. Permit application and operating requirements for municipal waste
processing facilities are contained in 25 Pa Code, Chapter 283, Resource Recovery and Other Processing
Facilities (http://www.pacode.com!secure!data!025!chapter283!chap283toc.html). The waste
processing permit application requires submission of design details, operating plans and related
information shOWing how waste will be received, processed and stored at the facility. The permit
application will be reviewed to assure adequacy, suitability and operating reliability of the proposed
facility to process the waste, produce exceptional quality biosolids and prevent nuisance conditions or
pollution from occurring at the facility. Chapter 283 contains detailed permit application requirements
which include submission of: an operating plan, maps and related information, design and related
information, a plan for access roads, a soil erosion and sedimentation control plan, a soil and ground
monitoring plan (if required by the Department), a nuisance control plan, a litter control plan, and a
contingency plan. Chapter 283 also contains detailed operating requirements, including: general
provisions, daily operations, soil and water protection, emergency procedures, record keeping and
reporting, cessation and closure, and recycling and waste removal. The project narrative states that
Synagro Technologies, Inc. (Synagro) will own and operate the Slate Belt Heat Recovery Facility as a
lessee of Grand Central Sanitary Landfill, Inc. (Grand Central) on the new lot. The list of permits required
on page 6 of the project narrative includes a "PA DEP GCSL Minor Modification," but it does not
explicitly list a municipal waste processing permit. As owner and operator of the Slate Belt Heat
Recovery Facility would PA DEP not require Synagro to apply for a municipal waste processing permit? It
is recommend that the applicant be requested to provide clarification regrading this matter. Municipal

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ENGINEERS
ATCGROOf'RJIl:YlCES LLC

Mr. Thomas R. Petrucci, Township Manager March 8, 2018

Waste Permit Application Forms are found at:

http://www.dep.pa.gov/Business/Land/Waste/SolidWaste/MunicipaIWaste/MunicipaIWastePermitting/
Pages/MW-Permit-Forms.aspx.

2. PA DEP - General Permit (PAG-07) for Beneficial Use of Exceptional Quality Biosolids. Persons
who generate or otherwise prepare biosolids that will be beneficially used by application to the land
must apply for PAG 07. This includes persons who generate or otherwise prepare biosolids that will be
sold, given away, or otherwise distributed in bags or other containers for application to the land. (Note:
In some cases an Individual Permit may be required instead of a General Permit). The applicable
regulations are contained in 25 Pa. Code, Chapter 271, Subchapter J, Beneficial Use of Sewage Sludge by
Land Application (http://www.pacode.com/secure/data/025/chapter271/subchapJtoc.html) . The
regulations and permit contain standards and requirements that must be met with regards to pollutant
limitations, pathogen and vector attraction reduction, record keeping, and monitoring and reporting for
beneficial uses of exceptional quality biosolids. The application appears to acknowledge this permit
application requirement, listing it as "PADEP Solid Waste General Permit for SYNAGRO" on page 6 in the
project narrative. Permit Application Forms for Beneficial Use of Exceptional Quality Biosolids are found
at:
http://www.dep.pa.gov/Business/Water/CleanWater/WastewaterMgmt/Biosolids/Pages/Permits.aspx.

3. PA DEP - National Pollutant Discharge Elimination System (NPDES) Permit for Stormwater
Discharges Associated with Construction Activities. Projects involving earth disturbance activities equal
to or greater than one (1) acre require an NPDES Permit Application for Stormwater Discharges
Associated with Construction Activities. Major components of this permit application include an Erosion
and Sedimentation Control Plan and a Post Construction Stormwater Management Plan. The application
appears to acknowledge this permit application requirement, but incorrectly lists it as a PA DEP Water
Quality Management Permit for Construction Activities instead of an NPDES Permit on page 6 of the
project narrative. NPDES Permit Application Forms for Stormwater Discharges Associated with
Construction Activities are found at:
http://www.dep.pa.gov/Business/Water/CleanWater/StormwaterMgmt/Stormwater%20Construction/P
ages/default.aspx.

4. PA DEP - Sewage Planning Approval. The project documents state that sanitary wastewater
from office, restroom, and empioyee facilities will be discharged to the local publically owned treatment
works (POTW) operated by Pen Argyl Municipal Authority (PAMA). This will require Act 537 sewage
planning approval. The project narrative acknowledges that Act 537 planning is necessary. Information
regarding the sewage planning process is found at:
http://www.dep.pa.gov/Business/Water/CleanWater/WastewaterMgmt/Act537/Pages/Sewage-
Facilities-Planning.aspx. The first step in this process is submission of the Sewage Facilities Application
Mailer.

5. Industrial Wastewater. The Sketch Plans do not show any treated wastewater discharge and the
project narrative states that wastewater will be backhauled to customers who are supplying the
dewatered biosolids that will be dried and pelletized. The project narrative states that receiving
treatment plant acceptance of process wastewater will be through an established single point identified
by the facility owner and will include the equipment necessary for the receiving facility to maintain

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ENGINEERS
...le;: ORQU"IiERYICI!S U.C

Mr. Thomas R. Petrucci, Township Manager March 8, 2018

monitoring and reporting compliance within their NPDES permit and local industrial pretreatment
program. The drawings show an above ground steel tank for storing process wastewater until it is
hauled away. A Water Quality Management Permit Application may be require for the storage tank
under DEP regulations (25 Pa Code, Chapter 91) if the tank capacity exceeds 250,000 gallons The
project narrative acknowledges the covered storage tank has the potential to be a source of odor and
states that the tank will be included in the odor control system as a negative pressure headspace.

6. PA DEP - NPDE5 Permit for Discharge of Stormwater Associated with Industrial Activities. A
NPDES Permit for Discharge of Stormwater Associated with Industrial Activities is required if the project
will result in a new, additional or increased stormwater discharges. NPDES Permits for Discharge of
Stormwater Associated with Industrial Activities require implementation of best management practices
to prevent water pollution. The application states that stormwater from the site will flow into existing
Sedimentation Basin No.2, and SYNAGRO has agreed with PADEP to apply for an Industrial NPDES
Permit for stormwater discharges from the facility, with a monitoring point to be located prior to
discharge into the existing basin. Information regarding NPDES Permit Application requirements for
Discharge of Stormwater Associated with Industrial Activities is found at:
http://www.dep.pa.gov/Business/Water/CleanWater/StormwaterMgmt/Pages/lndustrial
Stormwater.aspx

7. PA DEP - Air Quality Plan Approval & Operating Permit. PreViously submitted documents for the
proposed Slate Belt Heat Recovery facility stated that potential to emit (PTE) calculations were
estimated for the facility for the drying process and ancillary equipment; and that it is expected that a
plan approval and operating permit will be required. The project narrative acknowledges that Air Permit
Request for Determination is necessary. Air Quality Permit information is found at:
http://www.dep.pa.gov/Business/Air/BAQ/Permits/Pages/default.aspx.

8. PA DEP - Storage Tanks. Previously submitted documents for the proposed Slate Belt Heat
Recovery facility stated that there will be storage tanks for oil, sulfuric acid and sodium hydroxide.
These tanks may require Registration/Permitting under the Storage Tanks Program. Information
regarding the DEP Storage Tanks Program is found at:
http://www.dep.pa.gov/Business/La nd/Ta nks/Pages/defa uIt.as px.

Please contact me at 570-877-2241 if there are any question or if you wish to further discuss any of
these matters.

Sincerely,

Michael J. Brunamonti, P.E.

BCM Engineers