HanoverEngineering 252 Brodhead Road Suite 100 * Bethlehem, PA 18017-8944 Phone: 610.691.5644 * Fax: 610.691.6968 * HanoverEng.com Apail 15, 2019 Mr. Thomas Petrucci RE: Phhinfield Township ‘Township Manager Grand Central Sanitary Landfill, Inc. Plainfield Township Slate Belt Heat Recovery Center Project 6292 Sullivan Teail ‘Comments on Information Provided by EarthRes, Nazareth, PA 18064 and the PA DEP Technical Deficiency Letter Plainfield Township, Northampton County, PA Hanover Project PLF18-12 Dear Me. Petrucci: We have completed out review of the information provided by Mr. Thomas Pullar via e-mail on March 29, 2019 related to the Major Subdivision and Preliminary Land Development Plan for the Slate Belt Heat Recovery Center (SBHRC) project, as prepared by EarthRes Engineering and Science, Our review was of the following items received on March 29, 2019: 1, Esmail Correspondence (body) from Mr. Thomas Pullar 2. PDF File ~ Figure PAGWIS-01 and PA DCNR PaGWIS Well Search Data.pdf 3. PDF File ~ Figure GCSL-01 — GCSL Monitoring Points.pdf 4. PDF File ~ Drawing No. PCSM-01 — Post Construction Stormwater Management Plan. pdf We have also reviewed the recently received Technical Deficiency Letter from PA DEP for the ‘Minot Permit Modification Application. In response to our review of the above listed materials, we offer the following comments, as related to wetlands, waters, and riparian buffer impact concerns for the Township’s consideration. 1. PaGWIS Search — Ate there other wells that are not in the database? Are there any wells, between the pond (Basin No. 2 on plans) and the Little Bushkill and Waltz Creeks. 2. GCSL Monitoring Points ~ There are no existing wells identified or shown that are between the pond (Basin No, 2 on plans) and the Little Bushkil and Waltz Creeks. Without wells in such locations, how can we know and understand the potential or future impacts associated with stormwater discharges into the pond, including both quantity and quality concerns for such discharges? The information provided by the Applicant would further support the need for either installation of monitoring wells between the pond and the two «aforementioned streams, intensive monitoring of water quality of the pond (befote/baseline and after construction), and/or improved stormwater management controls for all runoff from the SBHRC project area to protect the water quality of the pond, groundwater, and connected surface waters, as would normally be required for stormwater discharges. Envisioning ond Engineering sustainable, cost-effective, and environmentally responsible projects since 1971Mr. Thomas Petrucci 2 April 15, 2019 ‘Township Manager 3. Best Management Practices Inserts/inlets should include special provisions for targeted removal of Total Petroleum Hydrocarbons, not just passive incidental removal along with particular matter. Plans should reflect this level of treatment with product specifications, Proper management and maintenance should be included on the plans and in the ‘Operation & Maintenance Plan for the site, in a manner that will ensure consistency under all conditions and best prevent pollutant discharges into the pond, downstream waterways, and groundwater. A vegetated swale with containment capability would be preferable to an earthen berm for discharge to Tnlet IN-2, assuming there may be sufficient area and grade to allow it, Containment capability should be maximized, and preferably sufficient to retain one full truck load of biosolids like the other proposed swale. Basin No. 2 Monitoring Itis recommended that monitoring of the pond be conducted monthly to best document water quality and to provide the necessary data for proper management of water quality in the pond and prevention of concerns such as nuisance odors from nuisance algae. If the pond is proposed to provide any level of treatment for water quality (eg, sediments, nutrients, etc), the plans and the Operation & Maintenance Plan should indicate that regular monitoring and management will be undertaken to best prevent water quality impacts and associated nuisance conditions. Management alternatives identified for use should include all applicable physical, chemical, and biological controls that may be necessary to improve water quality and prevent nuisance conditions. For purposes of nuisance algae management, chlocophyll a should be monitored monthly with a minimum detection limit of 1 ug/L, with treatment whenever chlorophyll a exceeds a concerning level (e.g.,20 ug/L) and at any lower concentration with nuisance odors being produced. For the purpose of water quality management in the pond, itis recommended that the detection limits for Total Phosphorus and Total Nitrogen be set at or below 0.01 and 0.1 mg/L, respectively. The proposed higher limits may help to determine potential discharges to the pond but would not provide any substantive data to assist with proper management of water quality, specifically with respect to nuisance algae and associated nuisance odors. Costs for laboratory testing should be similar for the lower detection limits recommended. General Comments Related to Provided Information ‘The pond should be monitored for background water quality conditions, especially in consideration of past and surrounding land uses. Without a good baseline of the water quality conditions, there will be nothing to which furure potential impacts may be compared. At a minimum, the trophic conditions of the pond should be part of the baseline, along with all potential pollutants of concern identified for monitoring under the DRAFT NPDES permit issued for SBHRC by PA DEP. While this old quarry pond may have been approved in past permit applications to PA DEP and to the Township for use as a stormwater management facility, the proposed use for the SBHRC is a new application and a new use. ‘The application should be reviewed in accordance with current standards for both construction and post-construction stormwater management, independent of past use and approvals, for other activities.Mr. Thomas Petrucci 3 April 15, 2019 ‘Township Manager c. Macroinvertebrate monitoring results for the Grand Central Woods station(s) have indicated less than optimal conditions/water quality, which would otherwise be expected for such headwater streams in the region. What is the impact to water quality that may be causing this? Has that been studied? 6. The plans should properly address all concems noted by PA DEP in their Technical Deficiency Letter. 7. PA DEP Comment 6 indicates several plan deficiencies and regulatory conflicts related to the existing pond being used as a sediment basin. Collectively, these comments suggest that this existing pond is not a sedimentation basin. 8. PA DEP Comment 6.c. states that “the bottom elevation of a sediment basin should not be located below the seasonal high water table, adjacent wetlands, or perennial streams.” The bottom of the pond (Basin No. 2 on plans), based on plan information, is approximately 70- 80 feet below the adjacent Waltz and Little Bushkill Creeks. The Consolidated Hydrogeological Package provided by EarthRes also supports the hydrologic connection of the pond to these adjacent streams, as well as to groundwater. 9. PA DEP Comment 6.4. indicates that Sediment Trap No. 2 “may not be located within the drainage area of another sediment trap/basin.” Additional requirements fot revisions to Sediment Trap No. 2 are also noted and should be made to be consistent with Chapter 102 requirements. 10. PA DEP Comment ~ Hydrogeology — As noted above in our Comment No. 8, the pond @asin No. 2 on plans) has been reported to be connected to groundwater and to the Waltz and Little Bushkill Creeks. Has the Applicant conveyed this information to the PA DEP? ‘The Consolidated Hydrogeotogical Package provided by EarthRes should be provided to PA DEP, along with any other supporting information for fll disclosure and consideration. As an additional concern that has recently come to our attention through a news release by PA DEP segarding testing and concem for per- and polyfluoroalkyl substances (PFAS), landfills are targeted for testing as a potential source beginning May 2019. PA DEP stated, “Addressing PFAS in drinking water is one of the top priotities of the DEP.” Given the location of the proposed SBHRC adjacent to the Grand Central Sanitary Land&ill (GCSL), the Township should inquire about potentially proposed testing wells around the landfill site and request that related data be provided to the Township, if nothing else as baseline data.