Revised Zoning Permit Application

Proposed Slate Belt Heat Recovery Facility

May 30, 2017
Page 2 of 24

followed by our responses are below each item as indicated by response. Below is the first
comment from Page 2 of the April 11, 2017 letter:

The Application for Plan Examination and Building dated March 31, 2017
references the proposed use as Industrial, Tanks and Towers, and Agricultural Industry
S31l.5 (B)/ S3ll.5 (C). It is the determination of the Zoning Officer that the proposed use is
not Agricultural Industry but is an Industrial use (Biosolid Processing Facility) as specifically
defined in the Plainfield Township Zoning Ordinance as a Material Separation Facility (as
defined in Sec. 201 B), which is permitted by right and only in the Solid Waste Processing
and Disposal District (SW). The Material Separation Facility has additional requirements for
the Permitted by Right Use as set forth in Section 315 (B) (35) as follows:

a. The site shall contain at least three (3) acres for any facility with a capacity to treat
or dispose of up to three hundred (300) tons of solid waste per day.
b. Entrances and exits to the facility shall be separated and clearly designated;
entrances and exits shall each be at least thirty (30') feet in width and shall be
located along either an arterial or collector road.
c. All access roads shall be paved.
d. Measures and procedures to prevent and minimize fire hazard shall be established
and practiced at the site or facility. A report describing these procedures shall be
provided to the Township.
e. Each facility shall be operated and maintained in such a manner as to minimize
health hazards, odors, dust, noise, environmental degradation, unsightliness, the
attraction, harborage or breeding of insects, rodents or vectors and to eliminate
conditions which create safety hazards or impose an undue burden upon the
Township or its municipal services infrastructure.
f. The operation of the facility shall comply with all applicable State and Federal
regulations.
g. The facility shall comply with the performance standards in this Ordinance (Article
5).

Response: The applicant concurs with the above comment. The Project complies with all of
the referenced design requirements as discussed in detail below and operation of the Facility
will comply with all of the referenced operational requirements

In reviewing the additional requirements for the permitted by right use as set forth
in Section 315 (B) (35) as listed above, the Zoning Officer offers the following comments in bold
italics:

a. The site shall contain at least three (3) acres for any facility with a capacity to treat
or dispose of up to three hundred (300) tons of solid waste per day. The size of the
site shall be increased by two (2) additional acres of land for each additional
capacity of one hundred (100) tons per day, or fraction thereof.
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Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 3 of 24

The applicant shall clearly delineate the acreage of the proposed Synagro lot
(7.01 acres) that is not impacted by steep slopes, slate spoils, and the Sediment
Basin No. 2 as shown on the Site Plan. Based on the information and Site
Plan submitted, the Zoning Officer has determined that this requirement has
not been met.

Considering the provisions of Section 315 (B) (35) that require an additional
two (2) acres of land for each one hundred (100) tons per day, the Zoning
Officer recommends that the applicant shall provide daily tonnage receipt
reports to the Township during the operational life of this facility as a condition
of any future approval in order to ensure continued and ongoing compliance
with this provision in perpetuity.

Response: The Zoning Ordinance defines lot area as the area within the lot lines, excluding
space within all existing and future road rights of way. In that regard, the lot area is not
limited to the developable/buildable area, and previous applications and Township
approvals within the Solid Waste District have similarly employed the Zoning Ordinance
definition and have not excluded steep slopes, slate spoils or sedimentation basin areas from
the acreage of the site. The resulting lot area provided for the Facility as documented in the
Site Plan is five acres, sufficient for a facility that will accept up to four hundred (400) tons
of solid waste per day.

Regarding the request that the Applicant provide tonnage reports to the Township, the
Applicant agrees to this request and will provide the requested tonnage reports. Five (5)
acres was the minimum applied as 400 tons per day of solid waste is the anticipated
throughput of the biosolids. The term solid waste is specifically addressed in Section
315(b)35.a of the Plainfield Township Zoning Ordinance and was utilized for the site area.

b. Entrances and exits to the facility shall be separated and clearly designated;
entrances and exits shall each be at least thirty (30') feet in width and shall be
located along either an arterial or collector road.

Entrances and exits to the facility are not separated and clearly designated on
the Site Plan. Pursuant to the requirements set forth in Section 315 (B) (35),
the entrances and exits shall each be at least thirty (30') feet in width and shall
be located along either an arterial or collector road. There is not a separate
entrance and exit to the facility shown on the Site Plan. Further, the entrance
and exit to the facility is not located along either an arterial or collector road.
Therefore, the conditions and provisions associated with this additional
requirement are not being met.

In addition, the applicant shall provide the Zoning Officer with a drawing that
shows the proposed traffic pattern for the entire site. It is not clear to the
Zoning Officer based on what was submitted how the vehicular truck traffic
is moving through the interior parallel roads of the Grand Central Sanitary
Landfill.
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Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 4 of 24

Response: The plan has been revised to show the traffic pattern for the entire site.

c. All access roads shall be paved.

The proposed driveway and the loading/outgoing access roads are not clearly
shown as paved on the Site Plan. Therefore, this provision is not being met as
currently proposed.

Response: The plan has been revised to show the proposed driveways, access roads, and
loading areas to be paved.

d. Measures and procedures to prevent and minimize fire hazard shall be established and
practiced at the site or facility. A report describing these procedures shall be provided to
the Township.

A written report shall be provided to the Township. The report shall he to the
satisfaction of the Township Engineer, Fire Chief, Slate Belt Regional Police
Department Chief, Zoning Officer, Building Code Official and the Emergency
Management Coordinator.

Response: The Applicant will comply with the Ordinance.

A written report demonstrating facility compliance with the applicable codes and standards
will be submitted by the applicant as part of the building permit submission. An overview
meeting with the Plainfield Fire Department has already occurred and Applicant is
awaiting feedback from the Department. The applicant will coordinate with the first
responders to determine if the input received to date will be impacted by either site
location.

e. Each facility shall be operated and maintained in such a manner as to minimize health
hazards, odors, dust, noise, environmental degradation, unsightliness, the attraction,
harborage or breeding of insects, rodents or vectors and to eliminate conditions which
create safety hazards or impose an undue burden upon the Township or its municipal
services infrastructure.

In order for the Zoning Officer to make a determination regarding this provision,
additional information is required and requested from the applicant as to how
each item listed above will be specifically addressed. Some of these items are also
listed within Article 5 as set forth below. It is the recommendation of the Zoning
Officer to the Plainfield Township Board of Supervisors that as a condition of
any future approval of this proposed use and the occupancy of any proposed
structure associated with this use, that evidence that all performance standards
are complied with be provided via certification of tests by appropriate government
agencies, or be recognized testing laboratories (with the costs to be borne by the
applicant), pursuant to Section 410 of the Zoning Ordinance.
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Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 5 of 24

Response: The Applicant will comply with this ordinance. Following approval and
construction, the Facility will operate pursuant to environmental regulatory and
permitting requirements and will have a continual duty to comply with all applicable and
required regulations and permit requirements as they are controlled and regulated by the
Agencies of the Commonwealth of Pennsylvania and the United States of America. Copies
of all approvals / permits will be provided to the Township as they are obtained. Specific
compliance with operational requirements cannot be demonstrated in advance of the
approval, construction and actual operation of the Facility, but will be provided to the
Township once the Facility is operational to show continued compliance following
approval.

f. The operation of the facility shall comply with all applicable State and Federal
regulations.

The Zoning Officer cannot make a determination at this time as to whether the
operation of the facility is in compliance with all applicable State and Federal
regulations. The following information shall be provided before any zoning or
building permits can be issued to the satisfaction of the Zoning Officer, Planning
Commission, and the Township Engineer:

1. Evidence of PennDOT Highway Occupancy Permit compliance, as

applicable.

2. Evidence of Act 537 (Pennsylvania Sewage Facilities Act) compliance from

the Pennsylvania Department of Environmental Protection.

3. Evidence of Water Obstruction Act of 1913 compliance.

4. Evidence of Solid Waste Management Act, Act 97 of 1980 (including

amendments) compliance from the Pennsylvania Department of
Environmental Protection.

5. Evidence of Municipal Waste Planning, Recycling and Waste Reduction Act

compliance from the Pennsylvania Department of Environmental Protection.
Clarification is required from the Commonwealth of Pennsylvania Department
of Environmental Protection as to whether the proposed facility is defined as a
"Resource Recovery Facility" as set forth in the Municipal Waste Planning,
Recycling and Waste Reduction Act.

6. Evidence of Act 167 Stormwater Management Act/Plainfield Township

Stormwater Ordinance (Bushkill Creek, Martins/Jacoby Creek and Delaware
River Sub-Basin I Watersheds Act 167 Stormwater Management Ordinance).
A review from the Lehigh Valley Planning Commission (LVPC) is required.
 Revised Zoning Permit Application
Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 6 of 24

7. Evidence of Federal Water Pollution Control Act Amendments of 1972 (Section

404, 33, U.S.C. 1334) compliance.

8. Evidence of Clean Streams Law compliance from the Pennsylvania

Department of Environmental Protection and the Northampton County
Conservation District (including but not limited to Chapter 93, Chapter 102
and Chapter 105).

9. Evidence of Clean Air Act compliance from the Pennsylvania Department of

Environmental Protection Bureau of Air Quality and the Environmental
Protection Agency (EPA), as required.

10. Jurisdictional determinations from the Army Corps of Engineers and the
Pennsylvania Department of Environmental Protection (PA DEP) as to whether
the Sedimentation Basin No. 2/Sediment Pond as shown on the Site Plan are
considered to be "Waters of the United States" or "Waters of the
Commonwealth".

11. Evidence of Pennsylvania Natural Diversity Inventory (PNDI) compliance.

12. Evidence of compliance with all applicable Pennsylvania Historical and

Museum Commission notification requirements.

13. Evidence from the Pennsylvania Department of Environmental

Protection that the proposed site is in compliance with the current
approved Operating Permit of the Grand Central Sanitary Landfill
(Facility ID No. 100265).

14. Evidence that the proposed Wastewater Treatment Plant Area is compliant
with all applicable Pennsylvania Department of Environmental Protection
and Delaware River Basin Commission requirements, provisions and
regulations. The receiving stream needs to be identified. Both the Waltz
Creek and the Little Bushkill Creek are designated as High Quality Cold
Water Fisheries and as Migratory Fisheries.

15. Evidence that the proposed fill-in and reduction in size of the Sediment
Basin No. 2 is approved by the Pennsylvania Department of Environmental
Protection. An enlargement or reduction in size of a Sediment Basin/Pond
can only be approved by the Pennsylvania Department of Environmental
Protection. A revision to NPDES Permit No. PA 0070483 is likely required.
In addition, evidence is required from the Pennsylvania Department of
Environmental Protection that confirms that the use of the Sediment Basin
No. 2for this proposed facility is in compliance with the current approved
Operating Permit of the Grand Central Sanitary Landfill (Facility ID No.
100265).
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Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 7 of 24

16. Evidence from all of the applicable State and Federal agencies that all
required State and Federal permits that are required to legally operate a
facility as proposed for this site have been obtained by the applicant.

Response: Applicant will comply with this ordinance requirement. The provision
states that the operation of the facility shall comply with all applicable State and
Federal regulations. Specific compliance with such operational requirements cannot
be demonstrated in advance of the approval, construction and actual operation of the
Facility, but the Applicant acknowledges that all pertinent Federal, State and/or
County permits will need to be secured in order to proceed with the Project. The
zoning application provided general descriptions of the proposed environmental
controls for air, water, and land pollution prevention and the permit applications to
be submitted to PADEP will provide further details on the control measures and
demonstrate compliance with applicable environmental regulations. The Applicant
will provide the Township with copies of all
approvals/permit/authorizations/clarifications issued by the pertinent agencies upon
receipt. The Applicant understands and agrees that compliance with all applicable
State and Federal laws and regulations during the lifetime of Facility operations is a
condition of approval by the Township, and compliance testing will be performed at
the Facility as required by the applicable regulations and/or permit conditions and
will be provided to the Township upon request. Applicant disagrees that evidence of
compliance from all the referenced State and Federal agencies is required at this point
in the zoning approval process since the Zoning Ordinance requires operational
compliance by the Facility, not prior approvals from all relevant agencies, but
Applicant will nonetheless provide the Township with all the requested compliance
information in the course of the development, construction and operation of the
Facility consistent with the standard protocol for local zoning approval by the
Township.

g. The facility shall comply with the performance standards in this Ordinance (Article 5).

Section 501 Environmental Preservation Required. The applicant shall furnish

proof to the Township to the satisfaction of the Township Engineer and the
Zoning Officer that the use provides for the preservation and the minimum
destruction of natural drainage areas, minimum grading and destruction of the
ground surface, the preservation of substantial stands of trees and forested
areas, and the preservation of attractive views and any other natural amenities

Response: The Applicant will comply with Ordinance Section 501. The site
has been an active industrial site for nearly a century as documented on
historical aerial photographs which have been provided in the enclosed Steep
Slopes Narrative. The proposed facility will not alter the existing drainage,
requires minimal grading, and the area has no forested area. The proposed
facility will be situated within an existing, developed, reclaimed mining area
and will not negatively impact any attractive views or natural amenities
considering the surrounding topography and land uses.
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Proposed Slate Belt Heat Recovery Facility
May 30, 2017
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Section 502 Nuisances Prohibited. The applicant shall furnish proof to the
Township that the proposed structure shall not be used or occupied in a manner
that creates a dangerous, injurious, noxious, or otherwise objectionable
condition, fire, explosion, or other hazards, heat, electromagnetic or other
radiation, noise or vibration in violation of Plainfield Township noise regulations
under Section 410, smoke, dust, odor or other form of air pollution, or any other
condition in such manner or on such amount as to adversely affect the
reasonable use or value of the surrounding area or adjoining premises or be
dangerous to public health or safety.

Response: The Applicant will comply with Ordinance Section 502. As noted
above, the Facility will operate pursuant to PADEP permitting and regulatory
requirements, which are specifically designed to prohibit the creation of any
dangerous, noxious, or otherwise objectionable condition. Consistent with the
applicable requirements, Facility operations will be contained within the
confines of the proposed building with the exception of the unloading and
loading, which will include dust and odor management controls to minimize
nuisances despite being outside the confines of the plant building. As any
business in the Township, the Applicant will be required to provide a safe
working environment for its employees. Potential external nuisances are
further addressed in the response to comments below.

Section 503 Steep Slopes. As noted elsewhere in this letter, the applicant shall
furnish proof of compliance with Ordinance No. 356 (duly adopted December 12,
2012 and which amended Section 503 of the Plainfield Township Zoning
Ordinance entitled Steep Slopes in its entirety).

Response: The Project complies with the Ordinance Section 503 as amended
by Ordinance No. 356. A Steep Slope Narrative has been enclosed for the
Townships review and approval. The narrative concludes that all steep slopes
in the project vicinity are man-made (e.g. quarry highwalls and reclaimed
quarry slopes, quarry waste rock piles, landfill side slopes) which was verified
with aerial photos, historical photos, and historical topographic
documentation. As a result, to the extent that any Project-related slope area
falls within the Steep Slope Overlay District, it would expected to be classified
under Ordinance No. 356 as a Class C Steep Slope since it consists of man-
made slopes that naturally contained less than a 15% grade. Because
permitted uses and development of such Class C Steep Slopes include all uses
in compliance with the provisions of the underlying district, which are not
prohibited by any other Ordinance, Ordinance No. 356 does not pose any
independent restrictions on the Project.

Section 504 Areas with High Water Table. Proof shall be furnished to the
Township that the proposed land use will not directly or indirectly result in the
pollution of the groundwater. Such a use would be prohibited from developing
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Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 9 of 24

in any area which has a year-round or seasonal high water table which comes to
within any distance of the ground surface, which violates Pennsylvania
Department of Environmental Protection regulations. The determination of such
hazards shall be made by the appropriate State agency and/or by a qualified
sanitary engineer, geologist or soil scientist approved by the Board of Supervisors.

Response: The applicant will comply with Section 504 of the

Ordinance.PADEP administrates the Regulations set forth by that Agency.
The Applicant will comply with all applicable PADEP requirements, and
determination of substantive compliance with those requirements rests with
PADEP as reflected in Ordinance Section 504. Sedimentation Basin No. 2
(former Doney #2 quarry) does connect to groundwater, but is a permitted and
regulated erosion and sediment control facility which is covered under the
landfills NPDES permit. Per previous comment, modification of the basin will
be required and will be processed through PADEP, the regulating Agency with
subsequent evidence of approval to be provided to the Township.

Section 505 Development Along Waterbodies. The proposed Site Plan does not
appear to be in compliance with Section 505 (Development Along Waterbodies)
of the Plainfield Township Zoning Ordinance.
Pursuant to Section 505 of the Zoning Ordinance, all areas within fifty feet (50')
of the banks of any streams, lake or pond shall be in open space. There is not
fifty feet (50') of open space between the proposed structures/improvements and
the sediment pond; the Zoning Officer has determined that this requirement has
not been met. The proposed Site Plan identifies the sediment pond/basin as
"Existing Streams/Ponds" on Sheet 2 of 4. The fifty feet (50') of open space
requirement between the pond and all proposed structures/improvements is not
being met in the determination of the Zoning Officer.

Response: Enclosed is a copy of the PADEP approval to install the sediment

basin as a developed water resource and not a naturalized water
impoundment. Sedimentation Basin No. 2, formerly the man-made Doney #2
quarry, is a regulated erosion and sedimentation control facility, not a stream,
lake or pond. The drawing will be revised to characterize the basin
accordingly. As such, this requirement is not applicable to the instant
Application and is controlled/regulated by PADEP.

Section 506 Alluvial Soils Areas. The applicant shall furnish proof to the
Zoning Officer that the areas proposed for the development are not within an
''Alluvial Soils" area.

Response: The Applicant is in compliance with Ordinance Section 506. Soils

from the County soil survey are currently depicted on the site plans. Existing
soils are mapped as PQ Pits, Quarries, which is not an alluvial soil.
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Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 10 of 24

Section 507 Flood Plain Regulations. All Special Flood Hazard Areas shall be
shown on the Site Plan. Specifically, the limits of Zone A on FEMA FIRM Map
Panel 42095C0132E are very close to the proposed driveway for the project.
Confirmation is needed that the proposed driveway or any other proposed
improvement/structure is not within Zone A. Compliance with Ordinance No. 368,
which was duly adopted June 11, 2014 and amended Section 507 (entitled Flood
Plain Regulations) of the Plainfield Township Zoning Ordinance, is required.

Response: The Applicant complies with Ordinance Section 507. The Site plans
have been revised to incorporate the Floodplain associated with Waltz Creek.
As demonstrated in the revised Site Plan, the project is not located within Zone
A of the floodplain.

Section 508 Filling, Excavation and Grading. All NPDES, Northampton County
Conservation District and Department of Environmental Protection regulations
shall apply to this proposed use. The applicant shall furnish proof that Section
508 of the Township shall be complied with. A zoning permit is required before
any activities that require the moving of earth or the filling or excavation of an
area can commence.

Response: The Applicant will comply with the Ordinance. Section 508.
Applicant acknowledges that authorization from PADEP and/or NCCD is
required prior to commencement of earth moving activities and Applicant will
provide such authorization to the Township upon receipt.

Section 509 Outdoor Storage Control. The Applicant shall identify whether any
outdoor storage facilities are proposed.

Response: No outdoor storage facilities are proposed for this permitted use.
The Applicant is in compliance with the Ordinance Section 509.

Section 510 Sewage Waste Treatment and Disposal Control Evidence of Act 537
(Pennsylvania Sewage Facilities Act) compliance from the Pennsylvania
Department of Environmental Protection shall be required.

Response: The Applicant will comply with Ordinance Section 510.

Specifically, PADEP Sewage Facilities approval will be provided to the
Township following completion of the Act 537 plan revisions relative to the
proposed sanitary facilities for the center.

Section 511 Noise Control. The applicant shall furnish proof that the proposed
use is in compliance with the Sound Level Limits by Receiving Land Use and time
as set forth in Section 511A of the Zoning Ordinance. Sections 511B, C, D and E
shall apply for an Industrial use.
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Proposed Slate Belt Heat Recovery Facility
May 30, 2017
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Response: The Applicant will comply with Section 511 of the Ordinance. The
proposed process equipment will be located within an enclosed structure
which will reduce sound levels and the Facility will comply with the Township
requirements as noted in the application.

Section 512 Vibration Control. The applicant shall furnish proof of

compliance with Section 512 to the Township.

Response: The Applicant will comply with Ordinance Section 512 as noted in
the application and will ensure that proposed equipment to be used at the
Facility will comply with the referenced Township requirements.

Section 513 Dust, Dirt, Smoke, Vapors, Gases and Odors Control. The applicant
shall furnish proof of compliance with Section 513 to the Township.

Response: The Applicant will comply with all Ordinance requirements

contained within Section 513. Currently compliance is noted in the
application. The Applicant maintains the proposed equipment will comply
with the referenced Township requirements. The facility operation
incorporates a comprehensive engineered odor control system for the
mitigation of dust, dirt, vapors and odors. No smoke or gases will be generated
by the process. Further, the Applicant will submit an air quality permit
application to the PADEP and will be responsible for complying with the
applicable regulations and permit requirements upon issuance.

Section 514 Light, Glare and Heat Control. The applicant shall furnish proof of
compliance with Section 514 to the Township.

Response: The Applicant will comply with Ordinance Section 514 as noted in
the application and will submit a lighting plan to the Township to details steps
that will be taken to address light and glare.

Section 515 Electric, Diesel, Gas or other Power. The applicant shall furnish proof
of compliance with Section 514 to the Township.

Response: The Applicant will comply with Ordinance Section 515 as noted in
the application. That section states:

ELECTRIC. DIESEL, GAS OR OTHER POWER. Every use requiring

power shall be so operated that any service lines, substation, or other
facility shall:
A. Conform to the highest applicable safety requirements,
B. Be constructed and installed as an integral part of the
architectural features of the plant, and
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May 30, 2017
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C Substations or other structures must be concealed by evergreen

planting from residential properties.

Applicant will ensure that each of these referenced requirements applicable

to uses requiring power will be met at the Facility.

Section 516 Control of Radioactivity, Electrical Emissions and Electrical

Disturbances. The applicant shall furnish proof of compliance with Section 516 to
the Township.

Response: The two (2) parts of Section 516 are as follows:

A. No person shall operate or permit the operation of any device

or conduct or permit any use to be conducted which does not
comply with the regulations of the Pennsylvania Department
of Environmental Protection's Division of Radiology, the
Federal Nuclear Regulatory Commission, and the Federal
Nuclear Regulatory Commission.
B. No person shall conduct or permit any use to be conducted
which causes electrical disturbances (except from domestic
household appliances) to adversely affect any equipment at
any time other than the equipment creating the disturbance.

The Applicant will comply with the Ordinance Section 516 and all required
Agency permitting requirements as noted in the application.

Section 410 Performance Requirements. It is recommendation of the Zoning Officer to the

Plainfield Township Board of Supervisors that as a condition of any future approval of this
proposed use and the occupancy of any proposed structure associated with this use, that
evidence that all performance standards are complied with be provided via certification of
tests by appropriate government agencies, or be recognized testing laboratories (with the
costs to be borne by the applicant). It is the recommendation of the Zoning Officer that
specific types of equipment, machinery and devices are installed or used as required in order
to determine whether or not the proposed operation is in compliance with all applicable
performance standards. Permits and certificates required by other government agencies shall
be submitted to the Zoning Officer as proof of compliance with applicable codes. Regulation
of Nuisance Characteristics and the Standards to be enforced shall be in accordance with
Section 410 C and D of the Plainfield Township Zoning Ordinance and all applicable State
and Federal regulations.

Response: The Applicant will comply with Ordinance Section 410. Applicant will
comply with this ordinance requirement. Specific compliance with operational
performance standards cannot be demonstrated in advance of the approval,
construction and actual operation of the Facility, but the Applicant acknowledges
that all pertinent Federal, State and/or County permits will need to be secured in
order to proceed with the Project. Those permits are designed to require the
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May 30, 2017
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performance demonstrations as reflected in the Ordinance and the zoning

application provided general descriptions of the proposed environmental controls
for air, water, and land pollution prevention. The permit applications to be
submitted to PADEP will provide further details on the control measures and will
demonstrate compliance with applicable environmental regulations. The Applicant
will provide the Township with copies of all
approvals/permit/authorizations/clarifications issued by the pertinent agencies upon
receipt. The Applicant understands and agrees that compliance with all applicable
State and Federal laws and regulations during the lifetime of Facility operations is a
condition of approval by the Township, and compliance testing will be performed at
the Facility as required by the applicable regulations and/or permit conditions and
will be provided to the Township upon request. Applicant disagrees with any
suggestion that evidence of compliance from the referenced State and Federal
agencies is required at this point in the zoning approval process since the Zoning
Ordinance requires performance compliance by the Facility, not prior approvals
from all relevant agencies, but Applicant will nonetheless provide the Township
with all the requested compliance information in the course of the development,
construction and operation of the Facility consistent with the standard protocol for
local zoning approval by the Township.

Section 410 Traffic Impact Requirements. A review of the level of traffic impact by the Township
Engineer is required for an Industrial Material Separation Facility pursuant to Section 410 E
(Traffic Impact Requirements) of the Plainfield Township Zoning Ordinance. The Zoning
Officer will defer to the comments and recommendations of the Township Engineer on this
matter. However, the Zoning Officer reserves the right to make the final determination or
interpretation as to the specific uses in the latest edition of the publication entitled "Trip
Generation, An Information Report" as published by the Institute of Transportation Engineers.
If a Major Traffic Impact is determined, all applicable provisions of Section 410 E (1, 2, 3, and
4) shall apply to this proposed use.

Response: The Applicant is in compliance with the Ordinance. The necessary

information on vehicular traffic associated with the proposed facility is included
with the project narrative. Upon receipt of the Township Engineers review letter,
the applicant will address any remaining comments/concerns and will meet all
Traffic impact requirements contained in Section 410 of the Ordinance.

The following dimensional requirements will apply to the proposed facility located within
the Solid Waste Processing and Disposal District as per Section 318 H, I, and J of the
Zoning Ordinance:

a. Minimum Lot Size: 5 acres is required for proposed 400 tons of solid waste per day.

Response: The Applicant meets the requirement of the Ordinance

Sections 318 h-j et seq.

b. Minimum Lot Width: 200 feet.

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May 30, 2017
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Response: The Applicant meets the requirement of the Ordinance.

c. Maximum Building Coverage: 25%

Response: The site plan has been revised to comply.

d. Maximum Building Height: 50 feet.

Response: The Applicant meets the requirement of the Ordinance.

e. Maximum Structure Height: 75 feet (403 B. Accessory Structures 150% of 50 feet)

Response: The Applicant meets the requirement of the Ordinance.

f. Maximum Impervious Coverage: 45% (318 J Maximum Impervious Coverage in

in the Solid Waste Processing and Disposal District)

Response: The site plan has been revised to comply.

g. Front Yard: 50 feet.

Response: The Applicant meets the requirement under the Zoning Ordinance.

h. Side Yard: 25 feet each/50 feet both.

Response: The Applicant meets the requirement under the Zoning Ordinance.

i. Rear Yard: 50 feet.

Response: The Applicant meets the requirement under the Zoning Ordinance.

Comments on the dimensional requirements are as follows:

a) Clarification is needed as to the final proposed silo height. The site plan narrative
references the silo as 65 feet, and Sheet 1 of 4 of the Overall Synagro Alternate
Facility Siting Plan shows the proposed maximum structure height as 51.65 feet.

Response: The plan has been revised to note 65-feet, consistent with the
project narrative and meets the Ordinance.

b) Both the Site Plan narrative and the Overall Synagro Alternate Facility Siting Plan
shall be revised to reference the correct dimensional requirements as set forth above.
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May 30, 2017
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Response: The dimensional requirements as noted above have been revised

in the project narrative and plans as requested and noted.

c) The proposed loading and offloading road encroaches upon the proposed Green Knight
lot (5.18 acres). The setback requirements for the rear yard for both proposed lots and
the front/side setbacks of the Green Knight lot are therefore not being met as currently
proposed on the Site Plan, as determined by the Zoning Officer.

Response: A cross access agreement between the two (2) tenants will be
submitted and this is not uncommon in a unified development. There are no
landscaping/buffer yards requirements that would require the two (2) lots to
be physically separated. The application complies with the Ordinance.
There is a longstanding relationship of this type already in existence between
the Green Knights LFGTE and the existing Landfill occupant/owner.

d) The lot or yard requirements for any new building or use shall not include any part of a
lot that is required by any other building or use to comply with the requirements of this
Ordinance. Therefore, that requirement of the Zoning Ordinance is not currently being
met by the proposed Site Plan, as per Section 404 A (1) of the Zoning Ordinance.

Response: This requirement is not applicable under the Ordinance as no

part of either of the proposed lots are using overlapping lot or yard
requirements. The Applicant will comply with the Ordinance and requests
clarification as to its alleged applicability.

Accessory Uses Determination (WWTP and Switch Gear). It is the determination of the
Zoning Officer that the proposed Wastewater Treatment Plant (WWTP) area is an Accessory
Use that is "clearly customary and incidental to the principal use." The Minimum Yard
requirements as listed in Section 318 H shall be applicable for the Accessory Use. The
Wastewater Treatment Plant area shall only be used for the Principal Use of the Material
Separations Facility. The existing Switch Gear of the Green Knights Energy Center is proposed
to be located on a separate parcel/lot located within the Commercial Industry (CI) Zoning
District. The Switch Gear, which is clearly an Accessory Use to the Green Knights Energy
Center, would not be a Permitted Accessory Use on another lot located within the CI Zoning
District in the determination of the Zoning Officer.

Response: The switch gear will remain on the Green Knights lot. Wastewater
Treatment Plant will not be used for the Green Knights facility and/or Landfill and
shall only be used for the Material Separation Facility.

Geotechnical Site Investigation Report. A Geotechnical Site Investigation Report for the
proposed site to the satisfaction of the Township Engineer shall be provided.
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Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 16 of 24

Response: A courtesy copy of the Geotechnical Report was previously supplied to

the Township Engineer for Site #1. Although it is not a specific requirement under
the Ordinance, as a further courtesy the Applicant will provide a copy of further
and forthcoming Geotechnical reports in the same fashion and upon completion.

Existing Utilities. The main structure on the site is proposed to be built where there are existing
overhead electric utilities, as well as existing utilities poles. A relocation plan shall be submitted
to the Township. Proof of coordination with the local utility provider and the utility provider's
approval of the relocation of the utility facilities shall be furnished to the Township.

Response: Upon receipt, a copy of the utility provider's approval of the relocation
of the utility facilities shall be furnished to the Township. All requests related to
the relocation plan and operation of utilities shall be provided.

Traffic Visibility Across Corners. The applicant shall furnish proof to the Township that the
proposed use is in compliance with Section 404 C (Traffic Visibility Across Corners) for all
sightlines at intersections of driveways or access ways with streets.

Response: The Applicant will comply with the Ordinance. Section 404c

Operating Hours. The applicant shall identify the proposed operating hours for this proposed
facility and all proposed Accessory Uses. Additional information is required from the
Commonwealth of Pennsylvania Department of Environmental Protection in terms of whether
the proposed operating hours are not in conflict with the current Grand Central Sanitary
Landfill Operating Permit and all other applicable Plainfield Township ordinances.

Response: Clarification will be requested from DEP on any potential conflicts on

proposed operating hours and will comply with all State and Federal Regulations
regarding the same. The Landfill has restrictions on open hours of operation for
accepting incoming waste and the Facility will operate under the same hour
constraints as the Landfill. Incoming/outgoing traffic may be restricted by DEP,
which is the delegated authority for such regulations. Any restrictions will be noted
as conditions of the authorization from DEP. All parts of the Ordinance will be met
along with all Regulatory Agency requirements as to Operations.

Plainfield Township Driveway Ordinance. Compliance with the Plainfield Township

Driveway Ordinance shall be confirmed to the satisfaction of the Driveway
Administrator and the Township Engineer.

Response: No driveways are proposed onto Township roads. The two (2) driveways
to be utilized for the proposed facility will be connected to the Landfill access road
which is a private access road and also serves the Green Knights facility. The
driveway ordinance is not applicable with respect to driveways.
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Proposed Slate Belt Heat Recovery Facility
May 30, 2017
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Land Development/Major Subdivision approval by the Plainfield Township Planning

Commission and Plainfield Township Board of Supervisors is required for this proposed use
and the two lots (Synagro 7.01 acres and Green Knight 5.18 acres) before any zoning and
building permits can be issued. All applicable provisions of the Subdivision and Land
Development Ordinance shall apply.

Response: An application for land development and subdivision approval will be

filed by the applicant. The Applicant will comply with the Ordinance and
applicable State and Federal Regulations of the same.

Principal Buildings Section 402 A. Every principal building shall be built upon a lot with
frontage upon a public or private street improved to meet Township standards or for which
such improvements have been insured by the posting of a performance guarantee pursuant to
the Subdivision and Land Development Ordinance, excepting however, those principal
buildings specifically approved by the Board of Supervisors. Future compliance with this
section is unclear, as the proposed access road is owned in part by Plainfield Township (Tax
Map Parcel ID# E8 14 IA 0626E) and temporary use of the access road was granted to Grand
Central Real Estate Company, Inc. and Grand Central Sanitation, Inc. via an Easement
Agreement dated March 12, 1997. This section of what is currently an improved road may
once again in the future be used as part of the Recreation Trail pursuant to the Easement
Agreement provisions once the landfill has entered the closure phase of its life cycle, and the
amount of the frontage may be impacted. A determination on this provision must be made as
part of the required Site Plan review and the formal Subdivision and Land Development
(SALDO) review.

Response: The enclosed easement agreement referenced does not specify the landfill
and/or associated operations. The agreement states that (t)he parties recognize
that, at some time in the future, Grand Central Real Estate and/or GCSs need for
the easement granted under paragraph 7 may cease. There is no specific timeframe
or event noted that would trigger the easement to cease. Such a cessation can only
be initiated by Grand Central Real Estate and/or GCS. The agreement speaks for
itself. The agreement does not operate to the detriment of the proposed use. A copy
of said easement is attached to the instant application. The applicant will adhere to
the easement agreement as drafted.

The metes and bounds of Tax Map Parcel ID# E8 141A 0626E should be used to delineate
the exact location of the section of the access road that is owned by Plainfield Township in
order to determine whether or not any of the proposed yard and lot measurements are impacted
by said parcel. It would appear that a portion of the proposed side yard setback is encroaching
onto the E8 141A 0626E parcel.

Response: The recorded subdivision plan was included in the original submission to
The metes and bounds of Tax Map Parcel ID# E8 141A 0626Eare incorporated in
the submitted plans. The Applicant will provide the metes and bounds description
as is applicable. The applicant will comply with the Ordinance.
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Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 18 of 24

Impact to Future Recreation Trail. As described above, part of the proposed access road is
owned by Plainfield Township. It is the recommendation of the Zoning Officer that the current
and future impact of this facility on the Recreation Trail should be studied and provided to the
Township, to the satisfaction of the Planning Commission, the Township Engineer and the
Zoning Officer.

Response: The trail has been relocated to avoid conflicts with the Grand Central
facilities. The proposed facility will not have any adverse impact on the recreational
trail. Attached is the easement agreement for the Townships reference. The
Applicant will comply with the Easement Agreement as drafted.

Signage. Article 6. All signage proposed for this facility and use shall be identified to
the Township in order for the Zoning Officer to determine compliance with Article 6
of the Zoning Ordinance entitled "Signs".

Response: The design of the facility signage required by PA DEP will be provided
to the Township prior to installation. The Applicant will comply with all applicable
state, federal and local regulations and law.

Compliance with Ordinance No. 356 (duly adopted December 12, 2012 and which amended
Section 503 of the Plainfield Township Zoning Ordinance entitled Steep Slopes in its entirety)
cannot be determined by the Zoning Officer based on the Site Plan submission. As defined and
in accordance with Ordinance No. 356 (Section 503 B), Class A, B and C Steep Slopes shall
be clearly delineated on the Site Plan where applicable. Section 503 I and Section 503 J of
Ordinance No. 356 list both the Permitted Uses and Development on Class A Slopes and the
Prohibited Uses on Class A Slopes. Pursuant to Section 503 B (5) and (6) of the Zoning
Ordinance as amended by Ordinance No. 356, the burden of proving the correct boundary shall
be on the applicant, supported by engineering and/or surveying data or mapping, testimony of
a soil scientist, or other evidence acceptable to Plainfield Township. Compliance with
Ordinance No. 356 shall be confirmed by the Township Engineer.

Response: As noted above, all steep slopes in the vicinity of the proposed facility
(e.g. quarry high walls, reclaimed high walls, material stockpiles and landfill slopes)
are man-made. The Steep Slopes Narrative has been enclosed to document in the
form of historical aerial photography and topographic maps the same that all steep
slopes onsite are manmade (Class C slopes). The Ordinance 356 does not apply as
cited by the Zoning Officer.

All Special Flood Hazard Areas shall be shown on the Site Plan. Specifically, the limits of
Zone A on FEMA FIRM Map Panel 42095C0132E are very close to the proposed driveway
for the project. Confirmation is needed that the proposed driveway or any other proposed
improvement/structure are not located within Zone A.

Response: Zone A from the flood map has been provided on the revised site plans.
The Applicant is in compliance.
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Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 19 of 24

NPDES Permit Required. As over one (1) acre of disturbance is proposed for this project,
Plainfield Township is not currently able to issue any permits (either zoning or building) for
this project as per Section 102.43 of the Commonwealth of Pennsylvania Department of
Environmental Protection (PA DEP) Erosion and Sediment Control Rules and Regulations,
25 Pa. Code I 02.43 and Section 611 of the Clean Streams Law, the Act of June 22, 1937,
L.L. 1987, as amended, 35 P.S. 691.611. 25 Pa. Code 102.43 states, "With the exception of
local stormwater approvals or authorizations, a municipality or county may not issue a building
or other permit approval to those proposing or conducting earth disturbance activities requiring
a Department permit until the Department or a conservation district has issued the E&S or
individual NPDES Permit, or approved coverage under the general NPDES Permit for
Stormwater Discharges Associated With Construction Activities under 102.5 (relating to
permit requirements)."

Response: The Applicant will comply with all applicable PADEP permitting
requirements, including any required NPDES Permit. The Applicant understands
and agrees that compliance with all applicable State and Federal laws and
regulations including NPDES requirements - during the lifetime of Facility
operations is a condition of approval by the Township, and compliance testing will
be performed at the Facility as required by the applicable regulations and/or permit
conditions and will be provided to the Township upon request. Applicant disagrees
that evidence of compliance from PADEP is required at this point in the zoning
approval process since the Zoning Ordinance does not require prior approvals from
all relevant agencies, but Applicant will nonetheless provide the Township with the
requested compliance information in the course of the development, construction
and operation of the Facility consistent with the standard protocol for local zoning
approval by the Township.

Stormwater Conveyance. The Site Plan narrative indicates that stormwater runoff is to be
directed and conveyed to the existing Sediment Basin No. 2 and that Sediment Basin No. 2
will be modified as required to accommodate the additional volume. Information shall be
provided on specifically how the stormwater runoff is to be conveyed to Sediment Basin No.
2. Act 167 (Stormwater Management Act)/Plainfield Township Stormwater Ordinance
(Bushkill Creek, Martins/Jacoby Creek and Delaware River Sub-Basin 1 Watersheds Act 167
Stormwater Management Ordinance) compliance is required. Proof of compliance with the
current Grand Central Sanitary Landfill Operating Permit to use this Sedimentation Basin No.
2 as a stormwater facility is required from the Pennsylvania Department of Environmental
Protection. In addition, all existing stormwater facilities shall be identified on the Site Plan.

Response: A stormwater management report will be submitted as part of the land

development submission to Plainfield Township. The sedimentation basin was analyzed as
part of the Act 167 compliance for the Landfills southern expansion as approved by the
Township, LVPC, and PADEP. Modifications to the basin will be verified as part of the
permitting process for the proposed facility. The Applicant will comply with the
appropriate agency requirements and required Ordinance policies. Applicant disagrees
with any suggestion that evidence of compliance with the current Grand Central Sanitary
 Revised Zoning Permit Application
Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 20 of 24

Landfill Operating Permit from PADEP is required at this point in the zoning approval
process since the Zoning Ordinance does not require prior approvals from all relevant
agencies, but Applicant will nonetheless provide the Township with the requested
compliance information in the course of the development, construction and operation of the
Facility consistent with the standard protocol for local zoning approval by the Township.

Riparian Buffer Ordinance. In the event that either the Army Corps of Engineers or the
Pennsylvania Department of Environmental Protection take jurisdiction of the Sediment Basin
No. 2 as "Waters of the United States" or "Waters of the Commonwealth", the Riparian Buffer
Ordinance of Plainfield Township shall apply, with all applicable requirements of that
ordinance for buffers to take effect.

Response: Sediment Basin 2 is a regulated sediment control facility serving GCSL

and permitted by PA DEP. Enclosed is the PA DEP letter approving the reclaimed
quarry to a developed water resources opposed to a naturalized water
impoundment. The applicant will be in compliance.

Lot Lines Yard Requirements. Confirmation is required from the Township Engineer that the
front, side and rear yard and all lot line design configurations as set forth on the Site Plan are
in conformance with the Plainfield Township Zoning Ordinance and the Plainfield Township
Subdivision and Land Development Ordinance (SALDO).

Response: No response required. The Applicant will comply with the Ordinance,
and SALDO. Upon receipt of the Township Engineers review, the applicant will
address his comments/concerns and will comply with appropriate requirements.

Front Lot Line. It is the interpretation of the Zoning Officer that the proposed Front Lot Line
(Street Line) does not meet the definition as set forth in the Plainfield Township Zoning
Ordinance as follows: "A lot line separating the lot from a street right-of-way. The front lot
line shall be the same as an existing or future right-of-way line (whichever establishes a
greater width)." The lot line is not shown as separating the lot from a street right-of-way, as
required by Section 201 B of the Plainfield Township Zoning Ordinance.

Response: The Applicant will comply with the Ordinance and will satisfy any
pertinent requirements for the creation of a private street right-of-way to the west
of the Green Knight lot and/or extension of the proposed facilitys lot to the right-of-
way of Pen Argyl Road. The Applicant will comply with the Ordinance.

Section 703 Design Standards for Off-Street Parking Facilities; Section 704 Off- Street
Loading.

a. Section 703 A (7): The access drives/driveways as proposed are not at least ten feet
(10') from the rear lot line as required. The solid fence and planting screen of at least
four (4') feet is not shown on the Site Plan. Therefore, the requirements of this section
are not currently being met as shown on the proposed Site Plan.
 Revised Zoning Permit Application
Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 21 of 24

Response: The site plan has been revised to comply with Section 703 A (7)
which notes;
Parking facilities, including access drives and driveways shall be located at
least ten feet from the side and/or rear lot line or shall be screened from
neighboring properties by a solid fence or planting screen at least four (4)
feet.

The Zoning section does not specifically prohibit cross access between two (2)
lots. The Applicant will meet the standard for unified developments with
cross access and common parking facilities.

b. Section 703 D (1) (2) (3) (4): The required dimensions shall be shown for all access
drives, including the loading/offloading area. Provisions are not shown for parallel
drainage along the access drives. The proposed loading and offloading drive encroaches
upon the parking areas of both the proposed Green Knight lot and the proposed Synagro
lot. Therefore, the requirements of Section 703 D are not currently being met as shown
on the proposed Site Plan.

Response: Section 703 D (1) specifies the minimum width of driveways along
the street line. The plan complies.
Section 703 D (2) specifies parallel drainage along a public street will not be
interrupted (i.e. the existing gutter line will not be removed by a driveway).
Section 703 D (2) specifies 50 separation is required between any two (2)
access drives along 1 street for 1lot. The plan complies.
Section 703 D (4) specifies no access drive/driveway shall be closer than 30 feet
to any street intersection. The plan complies.

c. Section 703 E: The applicant will provide information to show that the required parking
facilities, including driveways, are to be graded, surfaced with asphalt or other suitable
material, and drained to the extent necessary to prevent dust, erosion, or excessive water
flow across streets or adjoining properties.

Response: The facility access roads, driveway and loading areas will be
paved. Preliminary grading has been provided in the site plans. Grading and
drainage will be addressed in more detail in the Land Development Plans.
The Applicant will comply with the Ordinance. Section 703 et seq.

d. Section 703 F: Any parking area designed for use by six (6) or more cars after dusk
shall be adequately illuminated. All fixtures used to illuminate parking areas shall be
arranged to prevent light from shining beyond the boundary of the property. Lighting
fixtures are not proposed for the sixteen (16) space Synagro parking lot. While the
applicant indicates in the Site Plan narrative that adequate lighting will be provided in
the parking lot and employee working areas by using wall mounted lighting fixtures,
the Site Plan does not show specifically how the lighting of the parking areas will be
achieved, the extent of the lumens and the reach of the proposed lighting to sufficiently
 Revised Zoning Permit Application
Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 22 of 24

illuminate the parking lot. Therefore, the requirements of Section 703 (F) are not
currently being met as shown on the proposed Site Plan.

Response: Additional site lighting has been provided to illuminate the

proposed parking spaces. The Applicant complies with the Ordinance.
Section 703 (F) et seq.

e. Section 703 G (1) (2): All parking spaces and access drives shall be at least ten feet
(10') from any side or rear lot lines. The access drives for the proposed Synagro lot are
not ten feet (1 0 ') from the rear lot line. All areas not serving as parking spaces, aisles,
access drives, or pedestrian walkways shall be permanently landscaped and maintained.
Landscaping is not shown on the proposed Site Plan. Therefore, the requirements of
Section 703 G (I) and (2) are not currently being met as shown on the proposed Site
Plan.

Response: Section 703.A.7 notes that landscaping or a 4-foot high solid

fence will be provided. 703 G (1) is under the heading of Landscaping
and would appear to applicable to landscaping is provided in lieu of
a solid fence. The Applicant is entitled to relief from this determination to
allow open cross access between the proposed facility and the Green Knight
LFGTE Plant.

f. Section 704 B (2): The maneuvering room is not sufficiently separated from other
parking to eliminate traffic conflicts within off-street loading and parking areas as
currently proposed.

Response: Truck turning exhibits have been prepared to show sufficient

maneuvering room. The Applicant will comply with the Ordinance.

g. Section 704 B (3): The maneuvering room is not entirely on the lot proposed to be
served. The maneuvering room is outside of the yard area.

Response: Truck turning exhibits have been prepared to show sufficient

maneuvering room on the proposed lot. The Applicant will comply with the
Ordinance.

h. Section 704 B (6): The traffic pattern as currently proposed on the Site Plan is a
hazard to the vehicles/pedestrians accessing or departing the parking area.

Response: Parking has been proposed away from the southern side of the
building in order to provide separation between the loading and unloading
areas. Designated cross-walk area is shown on the revised drawings and will
be marked along with posting speed limit signs (15 mph) adjacent to the
facilities to minimize potential hazards to vehicles or pedestrians.
 Revised Zoning Permit Application
Proposed Slate Belt Heat Recovery Facility
May 30, 2017
Page 23 of 24

i. Section 704 B (7): All of the requirements listed in Section 703 F and 703 G are not
currently being met.

Response: Section 704 B (7) incorporates the requirements for illumination

703 F and landscaping 703 G of parking areas for loading spaces. The
Applicant will comply with the Ordinance.

The Building Code Official of Plainfield Township has provided an initial response letter. Said
letter dated April 7, 2017 is enclosed and incorporated herein into this letter by reference.

Response: The associated building plans and documents will be submitted with the
application for building permit for the Building Code Officials review. The
Applicant will comply with the Ordinance.

Certification of ownership and acknowledgement of plan signed by owner and developer. It

is not clear to the Zoning Officer whether the owner of the property, Waste Management, is
represented by the Applicant's Designated Representative. Synagro Technologies, Inc. is the
Applicant but does not have ownership of the parcel. Proof of equitable ownership is
required.

Response: Attached please find a certification and acknowledgement of the Site Plan
by Grand Central Sanitary Landfill, Inc., the owner of the property.

In addition to the issues and determinations set forth within this letter, the Zoning Officer
review letter shall incorporate any and all issues and recommended conditions of approval as
identified by the Township Engineer and the Planning Commission as part of the required Site
Plan review.

Response: The Applicant will comply with all legal requirements.