~MATERIAL

August 7,2019
~MATTERS,Inc.
820 North Hanover Street
Elizabethtown, PA 17022
717/367-9697
Mark Wejkszner, P.E., Air Quality Program Manager 717/367-0367 FAX
Department of Environmental Protection results@materialmatters.com
Air Quality Program
Wilkes-Barre Regional Office
2 Public Square
Wilkes-Barre, PA 18701-1915

RE: Comments - PADEP Air Quality Program - Draft Plan Approval 48-00111A
Slate Belt Heat Recover Center

Mr. Wejkszner:
On behalf of Plainfield Township (Northampton County), Material Matters is providing a
summary of previously submitted comments relating to the Pennsylvania Department of
Environmental Protection (PADEP) Air Quality Program, Plan Approval 48-00111A (PA Plan)
for the Slate Belt Heat Recovery Center (SBHRC) published May 11, 2019 in the Pennsylvania
Bulletin. Note that written comments were previously provided by Plainfield Township and Pen
Argyl Borough dated May 23, 2019 on the Draft Plan Approval.
A summary of comments provided to PADEP in the letter from Plainfield Township dated
May 23, 2019, and additional comments are as follows.
1. Synagro is currently finalizing a Nuisance Mitigation Control Plan (NMCP) prepared to
outline the measures to be taken to avoid offsite nuisance conditions. The NMCP
includes an Operations and Preventive Monitoring Program and a Community Complaint
Response Plan related to nuisance odors (fugitive emissions) and dust (fugitive
particulate matter). As previously requested in a letter to the Department (dated May 23,
2019), we strongly believe that inclusion of the final NMCP into this PA Air Quality Plan
will strengthen community acceptance of SBHRC activities and allow both PADEP Air
Quality and Waste Management to partner with local authorities to resolve challenges, if
any arise. Note that the current NMCP addresses many of the requested PA Plan
conditions outlined herein.
2. Section C, VI, # 22 - PA Code §127.44 states that use of in-plant roads shall not produce
fugitive particulate matter (PM) in excess of limits specified in PA Code § 121.1 and
§ 123.2. Furthermore, fugitive PM is not permitted to be discharged into the outdoor
atmosphere if the emissions are visible beyond the generator's property boundary.
Therefore, we request that a condition be added to the PA Plan that includes a
requirement to make daily visible PM observations on all surfaces inside the facility and
at the property boundary, and document those observations.
Material Matters, Inc August 7, 2019

3. Section C, #001 - PA Code relating to odor emissions from trucks as they transport
wastewater solids through communities is not clear. A condition specifically related to
the emission of odors "from material in or on trucks" is important since the SBHRC will
be receiving up to 400 wet tons of wastewater treatment solids on a daily basis, which
will be transported through the community. A portion of these solids will be unstabilized
with a very high potential for malodorous emissions. Transportation through the
community and delivery at the SBHRC unloading area are prime locations for malodors
that could impact the community. Pa. Code §123.1(a)(3) excludes emissions from trucks
as a fugitive air contaminant. A condition should be added to the PA Plan that includes
odor emissions from trucks with respect to fugitive air contaminant requirements.
4. Section C, #001 -. Pa. Code 123.1(a) broadly states that "no person may pennit the
emission into the outdoor atmosphere of a fugitive air contaminant from a source....". A
Fugitive Emission is defined as "an emission of an air contaminant" .including
particulate matter, sulfur compounds, odor and visible emissions" if emitted other than
through a flue." Department of Environmental Resources v. Locust Point Quarries, Inc.,
396 A.2d 1205 (Pa. 1979). This decision clearly supports the inclusion of "material in or
on trucks" as a regulated activity.
5. Section C, #003 - The PA Plan states that "a person may not pennit the emission into the
outdoor atmosphere of any malodorous air contaminants from any source in such a
manner that the malodors are detectable outside the property of the person on whose land
the source is being operated". Notably the definition of malodor in PA Code §121.1 is
"An odor which causes annoyance or discomfort to the public and which the Department
detennines to be objectionable to the public". We are not aware of the standards by
which the Department detennines whether an emission (odor) is objectionable.
Therefore, a standard should be set and included in the PA Plan such that causing
annoyance or discomfort to the public is sufficient for the Department to take
enforcement action to mitigate the emission.
6. Section C, #0 12(b)( 1) - The conditions which would require an investigation and
reporting to the Department are not clear and should be included in the PA Plan.
7. Section C, #012(c) - We suggest that daily monitoring for odors and fugitive PM at the
property line be required for the life of the SBHRC facility and be incorporated into the
PA Plan.
8. Section C, #014 - In addition to the type and amount of wastewater treatment solids
received during the month, requiring records be kept relative to the source, "daily"
volume of each source, stabilization status, and date/time received should be included in
the PA Plan.
9. Section D, Source ID 102, I. Restrictions #002 (page 25) - Areas where fugitive
emissions may arise at the SBHRC include: the Sludge Receiving area, the Wastewater
Storage Tank, Product Loadout, and the stonn water retention pond. Odor and fugitive
PM from the facility, regardless of the source must be addressed with conditions in the
PA Plan.

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Material Matters, Inc August 7,2019

10. Section D, Source ID 102, I. Restrictions, #003 - Control of odors at the Sludge
Receiving area will require a set of control measures due to the unsheltered, open nature
of the facility design. Daily monitoring of this area for HzS and an odor assessment for
odor character and intensity is essential when trucks are being unloaded.
11. Section D, Source ID 102, II. Testing Requirements - The Sludge Receiving area facility
testing regimen should include daily monitoring for HzS and periodic monitoring for HzS
when trucks are actively unloaded.
12. Section D, III Source ID 102. Monitoring Requirements - The Sludge Receiving area
facility monitoring regimen should include daily monitoring for H2S and periodic
monitoring for HzS when tmcks are being actively unloaded.
13. Section D, Source ID 102, VI. Work Practice Requirements - Odors during transit are not
covered in the PA Plan conditions relative to restrictions, testing, monitoring,
recordkeeping, reporting, and work practice requirements. As such, we suggest that
requirements in PA. Code §285.213(a)(l)(ii), §285.213(2) (ii), and §285.215(a) be
included as conditions in the PA Plan. This request is justified, due to the nature of the
source material being transported and the heightened level of public sensitivity to
malodors arising from a history of malodor complaints associated with the adjacent
landfill.

Should you have any questions about comments provided herein, please contact me at (717) 367-
9697 or tmdy@materialmatters.com.

Very tmly yours,

Material Matters, Inc

Trudy Johnston
CEO

Cc: Robin Zmoda, Pen Argyl Borough Manager

Peter Layman, Esq.

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