Documente Academic
Documente Profesional
Documente Cultură
September 4, 2019
Dear Tom:
As a follow up to your August 21, 2019 email, below please find our comments related to Peter
Spissak (Traffic Planning & Design, Inc.) August 19, 2019 email with Brian Boyer (PennDOT 5-
0 Permit Unit) and revised plans C-03, C-15, and C-17 prepared by EarthRes Engineering last
revised 8/13/19 which you provided with your email.
1. Plan sheet C-03 depicts a 74 foot wide driveway with what appears to be a pavement
marking at the center of the driveway. The driveway has a fifty foot deep throat length.
Brian Boyer confirms Peter Spissak’s August 19, 2019 email in which Brian indicates
that the proposed driveway would ultimately be approved given the following PennDOT
requirements:
A. Confirmation that adequate sight distance can be provided at the
intersection
B. The driveway would have a maximum width of 24 feet
C. The driveway radii would be 15 to 20 feet.
D. The applicant would provide as much shoulder widening as possible
without impacting the exiting utility poles for up to 200 feet in either
direction from the driveway along Pen Argyl Road.
The driveway depicted on C-03 may satisfy item A above, however it does not satisfy
items B, C, or D.
Mr. Thomas R. Petrucci, Township Manager
Plainfield Township
Scoping App #S0520190014
Benchmark Project No. 671004 September 4, 2019
2. The email referenced above indicates that approval of the driveway would also need to
address truck restrictions. The plan C-03 indicates truck restriction signs on Pen Argyl
which face the eastbound and westbound Pen Argyl Road through traffic and are located
approximately fifty feet to the east and west of the proposed driveway. It is doubtful that
this is what Brian Boyer intended when he indicated the need for truck restrictions. The
signs would not provide proper notification to trucks on Pen Argyl Road approaching the
new intersection. It is more likely that Brian Boyer intended to limit the trucks using the
proposed driveway in which case a different sign arrangement would be necessary and
signs would be required both within the site and along Pen Argyl Road.
3. A plan should be provided indicating the largest vehicle anticipated to use the proposed
driveway and that vehicles turning path. The plan should also depict whether that vehicle
can be accommodated on the existing pavement at the intersection and what pavement is
proposed to be constructed as part of the proposed driveway. This would also assist in
determining whether item 1.D above is addressed.
Further, we received the August 30, 2019 Earthres Transmittal on September 3, 2019 which
included Truck Turning Exhibits. Sheet C-05 (last revised 8/13/19) which is included in the
Truck Turning Exhibits, indicates the turning movements at a proposed driveway onto Pen
Argyl Road. This plan does not indicate a 24 foot wide driveway as was referenced in the Peter
Spissak August 19, 2019 email to Brian Boyer at PennDOT. The submitted plans depict a
significantly wider driveway which is contrary to the driveway specifications which Brian Boyer
indicated could ultimately be approved by PennDOT. The plan also does not indicate the Pen
Argyl Road shoulder widening which Brian Boyer indicated would be required.
Sincerely,
-2-
Benchmark Civil Engineering Services, Inc. • 1727 Jonathan Street • Allentown, PA 18104 • Phone: (610) 776-6700 • www.bencivil.com
September 5, 2019
Mr. Petrucci:
The following is a summary of comments related to the most recent revision of the Nuisance
Mitigation Control Plan (NMCP) dated August 29, 2019, submitted to the Township by Earthres
on behalf of Synagro. Comments summarized herein are based on the remaining nine comments
outlined in the August 22, 2019 letter from Material Matters to the Township.
Comments acknowledged as resolved in the August 22, 2019 letter from Material Matters are not
included herein and have been removed from the summary. However, the numbering system
used to identify the outstanding comments from the July 10, 2019 comment letter remain. (NOTE:
The pdf page numbers noted in the following narrative are from the August 29 NMCP
submission.)
c. Dust Preventative Monitoring Procedure (pdf page 18) – It is expected that around
a facility generating granular biosolids, there is potential to see dust on the
vegetation and other nearby surfaces. Add an Action Item to conduct visual
inspection of dust on nearby surfaces, both inside and outside the property
boundary, and if visible proceed with Actions / Resolution.
MM RESPONSE: Revisions were made to the Dust Preventative Monitoring
Procedure to include visual observation of fugitive dust accumulation of the
downwind property boundary. However, we suggest that in D-1, a third bullet be
added stating: “or excessive accumulation of dust on surfaces if observed” to
assure that action will be taken if fugitive dust is observed at the site.
Additionally, we suggest that D-2 be revised to say “If D-1 conditions are
exceeded then:”. Also, “Actions if permit limits are exceeded” be replaced with
“Actions if D-1 limits are exceeded”. Accordingly, this item remains unresolved.
e. SOP for n-Butanol Odor Intensity Field Kit Requirements (pdf page 14 and 86)
iv. Require donning of 1/2 face carbon filter respirator prior to exiting the
odor free room and before making odor assessment.
MM RESPONSE: Information provided on pdf page 14 of the pdf
addresses use of the half face respirator from the controlled environment.
A correction on pdf page 86 noted the stock solution will be prepared “in
water”, not air. These items are considered resolved with the August 29
submission.
The process for removing sources that are the cause of truck complaints or odor
problems at the Dewatered Biosolids Receiving & Storage area or odors from
trucks during transit should be revised to address the above comments.
Accordingly, this item remains unresolved.
6. (pdf page 3) An intensity of 3.0 on the n-butanol scale has been accepted as a trigger for
certain response activities in the OCRP. Based on the history of odors complaints in the
community, we suggest the use of 3.0 to represent a “distinct odor” on the n-butanol scale be
reviewed annually. This review shall be coupled with an annual assessment of the entire
NMCP with Plainfield Township (Township) and Pen Argyl Borough (Borough) to review
records, complaints, operations, and emerging biosolids recycling science; to consider
modifications to improve the effectiveness of the overall SBHRC program.
MM RESPONSE: Information provided by Synagro in the August 29 revised NMCP is being
addressed with the commitment to participate in an annual meeting with the Township and
Boroughs. These items are considered resolved with the August 29 submission.
Additional Item: Storm Water Retention Pond Odors (pdf pages 28 and 29)
It has been brought to our attention that the on-site storm water retention pond at the SBHRC
could become a source of nuisance odors if eutrophic conditions develop in the basin. This is a
possibility, which could lead to off-site nuisance odor conditions. Accordingly, the applicant
shall revise the NMCP to include the retention pond as a potential source for nuisance odor
emissions and address appropriate related factors. This topic was discussed in the 7/23/19
conference call between MM and Synagro representatives, so it is not a new item, but is a new
element for the NMCP document, and needs to be addressed. As such, we currently consider this
item as unresolved at his time.
MM RESPONSE: “Odors from algae growth within sediment basin No.2” has been added as a
Risk and Hazard in the Housekeeping SOP. Additionally the Housekeeping SOP notes that
sediment basin No. 2 should be visually inspected at least once per week during the summer and
fall months and monthly in other months. We suggest that “should” be replaced with “shall”.
To insure that the sediment basin will be monitored for odors, it is also suggested that “and
sediment basin No. 2” be added to O-3 of the Odor Preventive Monitoring Procedure (pdf page
15). Accordingly, this item remains unresolved.
Annual Updates to the NMCP and Comprehensive Monitoring Program (pdf page 3)
It is understood that annual updates to the NMCP and Comprehensive Monitoring Program will
be implemented in the future, based on experience gained through time at the SBHRC and
advancing biosolids science. If certain aspects of the NMCP and/or the Comprehensive
Monitoring Program are found to be lacking, annual updates will fill this void, making the
NMCP a true “Living Document”. Incorporating plans to hold an annual meeting with Plainfield
Township and Pen Argyl Borough into the NMCP is the best way to share accomplishments and
ideas for the upcoming year.
MM RESPONSE: This item is considered resolved with the August 29 submission.
Should you have any questions about comments provided herein, please contact me at (717) 367-
9697 or trudy@materialmatters.com.
Trudy Johnston
CEO
September 4, 2019
1. Full compliance with all NMCP (as approved, adopted and amended) provisions and
protocols at all times.
3. If NMCP provisions and protocols, which include the use of Professional Odor Support
(POS), identify Slate Belt Heat Recovery Facility (SBHRC) Facility or Site as the source
of malodors/nuisance odors and there continues to be ongoing malodor/nuisance odor
conditions caused by the Facility, SBHRC will voluntarily incur penalties and shut down
operations under the following conditions:
3.1. That the POS confirms the source of the nuisance odor conditions is emanating
from the SBHRC Facility and/or Site.
3.2. That the pre-Corrective Action Plan (CAP) efforts made in accordance with the
provisions and procedures set forth in the NMCP by SBHRC personnel to address the
ongoing odors has not resolved the malodor/nuisance odor conditions.
3.3. In the event that the remedies prescribed within the pre-CAP do not abate the
ongoing occurrence of malodors/nuisance odors emanating from SBHRC Facility or Site
and the NMCP CAP is scheduled to take longer than fifteen (15) days to implement, the
following temporary management efforts shall be employed in an effort to resolve, or
mitigate the malodor/nuisance odor conditions during this CAP implementation period:
i. Reduction in biosolids volume production throughput and output.
3.4. If completion of the CAP is scheduled to take longer than fifteen (15) calendar days
to implement, the following penalties shall be imposed for malodors/nuisance odors
and/or failure to implement enforcement provisions, and the penalties set forth below
1
shall accrue from the first day the SBHRC Facility or Site is identified as the source of
malodors or nuisance odors:
3.5. If CAP has not resolved identified malodors/nuisance odors after ninety (90) days,
then SBHRC shall cease operations on or before expiration of the ninetieth (90 th) day and
shall remain ceased until such time that the permanent CAP is implemented and all
permanent CAP work is completed and inspected. From time of plant cessation, SBHRC
has forty-eight (48) hours to complete processing all material in the receiving hopper and
thirty (30) days to remove from the Site all finished product stored in Facility silos and/or
hoppers.
3.6. SBHRC shall be allowed to restart the Facility after Synagro Corporate Engineering
Department (or any successor Department) has determined based on their technical
analysis and industry standards that the cause of the malodor/nuisance odor conditions
have been addressed.
3.7. Once the CAP is successfully implemented and all permanent CAP work is
completed and inspected and SBHRC is back in operation for seven (7) continuous days,
the POC will conduct a review to confirm that the problem has been mitigated. If the
POS determines that the malodors/nuisance odors have not been abated, the facility shall
again shut down in accordance with Section 3.5, with all relevant penalties as set forth in
Section 3.4 restarting from the “Over Ninety Calendar Days” time period.
2
1727 Jonathan Street • Allentown, PA 18104
Phone: (610) 776-6700 • Fax: (610) 776-1190 • www.bencivil.com
Dear Tom:
As a follow up to your August 21, 2019 email, below please find our draft comments related to
Peter Spissak (Traffic Planning & Design, Inc.) August 19, 2019 email with Brian Boyer
(PennDOT 5-0 Permit Unit) and revised plans C-03, C-15, and C-17 prepared by EarthRes
Engineering last revised 8/13/19 which you provided with your email.
1. Plan sheet C-03 depicts a 74 foot wide driveway with what appears to be a pavement
marking at the center of the driveway. The driveway has a fifty foot deep throat length.
Brian Boyer confirms Peter Spissak’s August 19, 2019 email in which Brian indicates
that the proposed driveway would ultimately be approved given the following PennDOT
requirements:
A. Confirmation that adequate sight distance can be provided at the
intersection
B. The driveway would have a maximum width of 24 feet
C. The driveway radii would be 15 to 20 feet.
D. The applicant would provide as much shoulder widening as possible
without impacting the exiting utility poles for upt to 200 feet in either
direction from the driveway along Pen Argyl Road.
The driveway depicted on C-03 may satisfy item A above, however it does not satisfy
items B, C, or D.
Mr. Thomas R. Petrucci, Township Manager
Plainfield Township
Scoping App #S0520190014
Benchmark Project No. 671004 August 29, 2019
2. The email referenced above indicates that approval of the driveway would also need to
address truck restrictions. The plan C-03 indicates truck restriction signs on Pen Argyl
which face the eastbound and westbound Pen Argyl Road through traffic and are located
approximately fifty feet to the east and west of the proposed driveway. It is doubtful that
this is what Brian Boyer intended when he indicated the need for truck restrictions. The
signs would not provide proper notification to trucks on Pen Argyl Road approaching the
new intersection. It is more likely that Brian Boyer intended to limit the trucks using the
proposed driveway in which case a different sign arrangement would be necessary and
signs would be required both within the site and along Pen Argyl Road.
3. A plan should provided indicating the largest vehicle anticipated to use the proposed
driveway and that vehicles turning path. The plan should also depict whether that vehicle
can be accommodated on the existing pavement at the intersection and what pavement is
proposed to be constructed as part of the proposed driveway. This would also assist in
determining whether item 1.D above is addressed.
Sincerely,
-2-
Benchmark Civil Engineering Services, Inc. • 1727 Jonathan Street • Allentown, PA 18104 • Phone: (610) 776-6700 • www.bencivil.com