OCR Version Slate Belt Heat Recovery Center Review Memorandum - September 6 2019

Plainfield Township Board of Supervisors
6292 Sullivan Trail

Nazareth, Penna. 18064
Phone 610-759-6944 Fax 610-759-1999
To: Plainfield Township Planning Commission; David M. Backenstoe, Esq., Plainfield

Township Solicitor; John R. Embick, Esq., Plainfield Township Special
Environmental Solicitor
From: Thomas R. Petrucci, Township Manager
RE: Current Status of Grand Central Sanitary Landfill, Inc. Slate Belt Heat Recovery
Center Preliminary Land Development/Major Subdivision Plan
Date: September 6, 2019
As requested, I have prepared this letter detailing the current status of the Grand Central
Sanitary Landfill, Inc. Slate Belt Heat Recovery Center Preliminary Land
Development/Major Subdivision Plan.
The Plan is entitled "Major Subdivision and Preliminary Land Development Plan for
Slate Belt Heat Recovery Facility" for lands owned by Grand Central Sanitary Landfill, Inc. and
prepared for Slate Belt Heat Recovery Center, LLC, Green Knight Economic Development
Corporation (GKEDC), and Grand Central Sanitary Landfill, Inc. (GCSL), Sheets 1 through 23
of23, dated February 6,2018 last revised August 13,2019 (and actually received by the
Township Municipal Office on August 30, 2019), prepared by EarthRes Group, Inc. The
proposed facility shall be referred to as the "Site," "Facility," or "SBHRC".
This letter identifies the defects found in the plan submission as identified in the most
recent Plainfield Township expert review letters, which are listed as follows:
1. Benchmark Civil Engineering Letter Dated September 4,2019.
2. Material Matters, Inc. letter dated September 5, 2019;
3. Hanover Engineering, Inc. Jason Smith Letter Dated September 6, 2019;
4. Hanover Engineering, Inc. Robert Lynn Letter Dated July 11, 2019;
5. Hanover Engineering, Inc. Robert Lynn Letter Dated September 6, 2019;
6. BCM Engineers Michael Brunamonti Letter Dated September 4,2019;
7. Letter from Tom Petrucci, Plainfield Township Manager/Alternate Zoning

Officer Dated August 29, 2019.
SBHRC Status Review Memorandum - FINAL - 9/6/2019 Page 1
The above-identified letters describe the requirements which have not been met and cite
the particular section of the Plainfield Township Zoning Ordinance and the Subdivision and
Land Development Ordinance (SALDO) containing the requirements.
The identified items that are currently deficient are provided as follows:
A. A formal review for compliance with the Code of Ordinances of Plainfield Township has
been performed. The following sections of the Township Zoning Ordinance (Chapter 27),
Subdivision and Land Development Ordinance (SALDO) (Chapter 22), and Stormwater
Management Ordinance (Chapter 23), have not been complied with by the Applicant.
1. Chapter 27 - Zoning
a.Section §27-316 (2) (II) - Upon a review of the revised plan sheets C-03,
C-17, C-18 and Truck Turn Exhibits C-04 and C-05, it is the opinion of
the Zoning Officer and the Township Manager that a Variance is still
required from Section §27-316 (2) (II) (2) of the Code of Ordinances of
Plainfield Township due to the fact that the proposed entrance and exit to
the facility are not located along an Arterial or Collector Road. Pursuant to
the requirements set forth in §27-316 (2) (II) (2), the proposed entrance
and exit to the facility are not located along either an Arterial or Collector
road. The proposed entrance and exit to the facility are located along an
interior Private Access Drive of the Grand Central Sanitary Landfill.
The entrance and exit to the facility of the proposed "Pen Argyl Road
(S.R. 1011) Low-Volume Driveway" are now separated and clearly
designated. Further, the proposed entrance and exit to the facility are each
at least thirty feet (30') in width.
However, the proposed "Pen Argyl Road (S.R. 1011) Low-Volume

Driveway" is proposed to restrict truck traffic. The Zoning Officer is of
the opinion that a Low-Volume Driveway restricted to truck traffic is not
sufficient to serve the facility in accordance with the requirements of
Section §27-316 (2) (II) (2) of the Code of Ordinances of Plainfield
Township. Section §27-316 (2) (II) (2) requires that the entrance and exit
to the facility be located along an Arterial or Collector Road; it is the
opinion of the Zoning Officer and the Township Manager that said
entrance and exit must allow for the activities associated with the use to
take place. A Low-Volume Driveway would not accommodate the truck
traffic that is associated with the proposed Material Separation Facility
use. The Applicant failed to obtain the required Variance; therefore,
the Applicant failed to comply with this provision.

Plainfield Township's Traffic Planning Consultant, who is Mr. Peter
Terry, P.E. of Benchmark Civil Engineering, Inc., performed a review of
the revised plan sheets C-03, C-17, C-18 and Truck Tum Exhibits C-04
and C-05. Mr. Terry's review letter dated September 4, 2019, which
identified technical deficiencies with your submission, is enclosed and
incorporated herein as though more fully set forth at length.
b.Section §27-505 - A Variance is required from Section §27-505 of the

Code of Ordinances of Plainfield Township to allow for an area of open
space between the proposed structures/improvements and the pond that is
less than fifty feet (50'). Currently, there is no buffer of fifty feet (50')
provided, as proposed development associated with the facility encroaches
into the existing pond itself. The Applicant failed to obtain the required
Variance; therefore, the Applicant failed to comply with this
provision.
c.Section §27-410 (Performance and Traffic Impact Requirements);

§27-410 (4) Standards to be Enforced - In order to provide the
necessary information to the Board of Supervisors to assist the governing
body with making the determination as to whether the proposed use
compromises the public health, safety, and welfare, the adverse
environmental impacts as listed within §27-410 (I) (A) and (B) shall be
reviewed locally in accordance with the following standards:
• Conduct a study, in advance, and identify the current,

cumulative, andfuture effects ofadverse environmental impacts
ofall activities associated with the proposed use. The study
must identify and assess direct and indirect environmental
effects that can be negative or positive; identify and assess
impacts that are immediate, short- term or long-term; and
which impacts can be incremental, compounding over time, or
develop over the passage ofyears;
• Determine whether and to what degree the effects or impacts

will infringe unreasonably upon or violate the protected rights
and values (air, water, scenic, historical, natural, and esthetic)
or unreasonably cause actual or likely deterioration ofthe listed
values, as per Article L Section 27 ofthe Commonwealth of
Pennsylvania Constitution; and
• Unless the unreasonable effects or impacts ofall activities

associated with the proposed use can be eliminated, or reduced
to a level where the impacts are not unreasonable, then the use
SBHRC Status Review Memorandum - FINAL - 91612019 Page 3

cannot be permitted, pursuant to the requirements of§27-410
(1) (A) and (B).
The Applicant failed to conduct the above-described Environmental

Impact Study that was formally requested by Plainfield Township
officials in letters dated March 20, 2018, September 6, 2018,
December 21, 2018 and May 9, 2019. Additionally, the request for this
study was recited during numerous special meetings that were held
regarding the pending SHURC Preliminary Land DevelopmentlMajor
Subdivision review process. The Applicant failed to comply with this
provision.
d.Section §27-410 (Performance and Traffic Impact Requirements);

§27-410 (4) Standards to be Enforced; §27-502 - Nuisance Mitigation
Control Plan (NMCP)
In order to facilitate the Applicant demonstrating compliance with all
provisions of §27-41 0 of the Code of Ordinances of Plainfield Township,
§27-502 of the Code of Ordinances of Plainfield Township, and in
accordance with the authority granted to the Township under §27-410 as
cited above, Plainfield Township has engaged the services of Trudy
Johnston, who is the Chief Executive Officer of Material Matters, Inc. in
order to develop a Slate Belt Heat Recovery Center Nuisance Mitigation
Control Plan (NMCP). Material Matters, Inc. has identified deficiencies
within the Nuisance Mitigation Control Plan as set forth in a letter dated
September 5,2019, which is incorporated herein as though more fully set
forth at length.
Under the authority of §27-410 and §27-502 of the Code of Ordinances
of Plainfield Township and Article I, Section 27 of the Commonwealth of
Pennsylvania Constitution, the Township Manager and Zoning Officer
are recommending that the Applicant address all outstanding elements of
the Nuisance Mitigation Control Plan (including any subsequent
revisions) in order to prevent nuisance conditions occurring within
Plainfield Township and surrounding communities. Accordingly, the
Township Manager and Zoning Officer are recommending that land
development approval be withheld because the NMCP is not
satisfactory to the Township in its current form and is not sufficient
to prevent or abate nuisance conditions.
Nuisance Mitigation and Control Plan (NMCP) Facility
Enforcement/Shutdown Provisions Protocol
As previously identified by the Township and Applicant, a necessary
component of the NMCP is an enforceable legal instrument that will
allow Plainfield Township and its officials to ensure complete
compliance with the provisions of the NMCP and to impose sanctions
and penalties when compliance is not achieved by the Applicant. In
consideration of this identified requirement, a proposed SBHRC NMCP
Facility Enforcement/Shutdown Provisions Protocol (DRAFT) dated
September 4, 2019 is enclosed herein for the review of the Planning
Commission, Board of Supervisors, and the Applicant; said document is
incorporated herein as though more fully set forth at length. The method
of legally incorporating the final approved version of the proposed
SBHRC NMCP Facility Enforcement/Shutdown Provisions Protocol into
the final approved NMCP shall be in a manner and form that is
acceptable to the Plainfield Township Solicitor and Plainfield Township
Environmental Legal Counsel. Accordingly, the Township Manager
and Zoning Officer are recommending that land development
approval be withheld because the proposed SBHRC NMCP Facility
Enforcement/Shutdown Provisions Protocol has not been finalized.
g. Access Study Review (Compliance with §22-504 (8)- SALDO;

Compliance with §27-410.5- Zoning) - The Applicant has failed to
address the technical deficiency comments that are set forth within the
most recent Access Study review letter prepared and issued by traffic
planning professional Mr. Peter Terry, P.E., PTOE, PMP, who is
employed with Benchmark Civil Engineering Services, Incorporated.
Said letter dated September 4, 2019 is incorporated herein as though
more fully set forth at length. The Applicant failed to comply with this
provision.
2. Chapter 22 - Subdivision and Land Development Ordinance (SALDO)
a.Section §22-108 (2) (3) - Actual legal, engineering, and other costs and
expenses incurred by the Township, in connection with the review and
processing of a subdivision or any proposed land development, shall be
reimbursed to the Township by the subdivider or developer. No final plan
shall be approved unless all fees and charges have been paid in full. As of
September 6, 2019, a combined total of $21,887.02 in actual legal,
engineering, and other costs and expenses incurred by the Township in
connection with the review and processing of the above-referenced
SBHRC Land Development/Major Subdivision plan remain unpaid.
Therefore, the Applicant has failed to comply with this provision.
b.Section §22-503 (1) (A) (6) - Sanitary sewer profiles shall be provided.
Evidence of Pen Argyl Municipal Authority review and approval of
the sanitary system design and details have not been provided, as
requested by the Township Engineer. Therefore, the Applicant has
failed to comply with this provision.
c. Section §22-503 (1) (A) (7) - Evidence of PA American Water Company
review and approval of water system design and details shall be provided.
The review and approval of water system design and details have not
been provided, as requested by the Township Engineer. Therefore, the
Applicant has failed to comply with this provision.
d.Section §22-503 (8) (A) - Evidence of Erosion and Sedimentation Control
Plan approval by Northampton County Conservation District shall be
provided. The requested evidence of review and approved has not been
provided with the latest plan review application; the Applicant has
failed to comply with this provision.

e. Section §22-503 (11) - Construction details of sanitary sewer and water
facilities shall be in accordance with the respective service providers. Pen
Argyl Municipal Authority Sewer Details have been provided with the
February 4,2019 plan review application. The applicant has indicated
the PA American Water Details will be provided when received. The
Applicant has failed to comply with this provision.
f. Section §22-504 (2) - Certification of public water supply, including
water company's ability to serve the project, conditions of service and
authority to serve the facility shall be provided. This provision has not
been addressed. The Applicant has failed to comply with this
provision.
g.Section §22-504 (3) (A) - Certification of public sanitary sewer service
including provider's ability to serve the project, conditions of service and
authority to serve the facility shall be provided. This provision has not
been addressed. The Applicant has failed to comply with this
provision.
h.Section §22-504 (S) -The Applicant has failed to address the comments
and concerns of the Zoning Officer and to adequately address the technical
deficiency comments of the latest review letter prepared by Benchmark
Civil Engineering Services, Inc. dated September 4, 2019. The Applicant
has failed to comply with this provision.
i. Section §22-1003 (4) - All aspects of the proposed land developments
shall conform to the Township Zoning Ordinance (Chapter 27) and all
other Township Ordinances and Specifications. The Applicant has failed
to demonstrate conformity and compliance with all Township
Ordinances and Specifications, including the Township Zoning
Ordinance (Chapter 27). Therefore, the Applicant has failed to
comply with this provision.
J. Section §22-1003 (6) - No subdivision or land development shall occur
in such a way that would significantly threaten the public health and
safety, including hazard of toxic substances, groundwater pollutions,
traffic hazard and explosive and fire hazards. The Applicant has failed
to address all of the Township's environmental, public health and
safety concerns as noted herein. The Applicant has failed to comply
with this provision.
k.Section §22-100S (5) (A) - Requirements for recreation land area or fee-
in-lieu ofland area shall be determined by the Board of Supervisors. The
Applicant has not reviewed the recreation land area or fee-in-lieu of
land area provisions with the Board of Supervisors. The Applicant
has not yet complied with this provision.
1. Section §22-1009 (6) (A) (S) - Groundwater recharge through Basin No.
2 is proposed. Groundwater recharge is encouraged when suitable
subsurface conditions are present; the Applicant shall define the
precautions to be taken to prevent pollution ofthe groundwater. The
Applicant has provided calculations based on certain assumptions;
however, the Applicant has not satisfactorily addressed the comments as
set forth within the latest review letter of Jason Smith, PWS (Hanover
Engineering, Inc.) dated September 6, 2019.
The latest Michael Brunamonti, P.E./Phil Gray, PG (BCM Engineers)
review letter dated September 4,2019, which is incorporated herein as
though more fully set forth at length, indicated that the proposed
Stormwater Monitoring Plan, Sediment Basin No.2 Monitoring Plan,
Groundwater Monitoring Plan and Backfill Sampling and Analysis Plan,
as submitted with the letter of transmittal dated August 30, 2019 provides
for an effective means to monitor stormwater discharges or other possible
discharges of pollution or pollutants from the proposed facility.
As set forth in the above-referenced BCM Engineers letter dated
September 4,2019, the Township has identified a concern with how to
legally incorporate the proposed Stormwater Monitoring Plan, Sediment
Basin No.2 Monitoring Plan, Groundwater Monitoring Plan and Backfill
Sampling and Analysis Plan into the Pennsylvania Department of
Environmental Protection (PA DEP) NPDES Permit Application to
Discharge Industrial Stormwater and the Application for Minor Permit
Modification for Facility No. 100265, which is the Grand Central
Sanitary Landfill, Inc. The applicant shall answer the questions set forth
within the BCM Engineers letter dated September 4, 2019 to the
satisfaction of Plainfield Township.
Additionally, the Applicant must adequately address the water quality
impacts to the Sedimentation Basin No.2, surrounding groundwater, and
nearby streams, as well as eutrophication and associated potential odors
as delineated in the September 6, 2019 letter of Jason Smith, PWS, which
is incorporated herein as though more fully set forth at length, to the
satisfaction of Plainfield Township.
The Applicant has failed to demonstrate compliance with this
provision.
m.Section §22-1009 (7) (G) (5) - The Board of Supervisors shall determine
ifpublic safety will be endangered if Basin No.2 is not fenced. As part of
this determination, the Board shall also determine if the proposed
concrete wheel stops in the parking area are adequate protection to
prevent errant vehicles from entering thru Basin No.2. The Applicant
has not yet demonstrated compliance with this provision.
n. Section §22-1009 (7) (J) - An outflow control structure shall be provided
at the outlet of all detention/retention basins. The stormwater
management calculations indicated that Basin No.2 will be a "no
discharge" basin. The calculations appear to only address storage volume.
It is unclear how available storage volume will be restored after any
storm event without discharge via basin outlet or infiltration. Clarification
is needed regarding how the stormwater volume will be dewatered. The
Applicant has stated that the information will be addressed with the
NPDES Permit Application and provided with the revised plan
submission. We have reviewed the information submitted as part of the
NPDES Permit Application and there does not appear to be any analysis
of the dewatering time and capabilities of Sediment Basin No.2 to
dewater the increased runoff volume within the application information.
The Applicant has failed to comply with this provision. Further, the
item is subject to additional review of the provided geologic analysis.
The Applicant has not satisfactorily addressed the comments as set

forth within the latest review letter of Jason Smith, PWS (Hanover
Engineering, Inc.) dated September 6, 2019.
o.Section §22-1021 (A) - Evidence ofNPDES Pennit approval shall be
provided to the Township. Copies of the complete NPDES application
package shall also be provided. The Township has received copies of
the NPDES permit application package. The Township is not in
receipt of application completeness or technical review comments
from PA DEP. Evidence of approval of the NPDES permit shall be
provided to the Township. The Applicant has failed to comply with
this provision.
p.Section §22-1023 (4) (E) - All areas within fifty (50) feet of the top of
the bank of any pond or lake shall be open space. Stonnwater control
ponds, not intended to pennanently retain water, are not subject to this
requirement. The Applicant has not provided an area of open space
that is fifty (50) feet from the top of the bank of the pond that is
situated on the proposed Land Development and labeled by the
Applicant as Sedimentation Basin No.2. The pond permanently
retains water, so §22-1023 (4) (C) applies. Further, the Applicant has
not adequately addressed the comments of the Township's appointed
Wetlands/Environmental Consultant, who is Jason Smith, PWS, as
directed in correspondence dated September 6, 2019. The Applicant
has failed to comply with this provision.
q. Section §22-1023 (4) (F) and §22-1023 (8) - For those projects involving
subdivision or land development submission, the plans shall show the
limits of riparian buffers along a watercourse and limits of open space
along ponds or lakes defined by bearings and distances tied to property
comers at two points. The Applicant has not shown the bearings and
distances, with ties to property comers, for the existing pond and
associated buffer of fifty (50) feet. The Applicant has not adequately
addressed the comments of the Township's appointed
Wetlands/Environmental Consultant, who is Jason Smith, PWS, as
directed.
Further, the September 6,2019 letter of Jason Smith indicates that the
Applicant has labeled Sedimentation Basin No.2 as "waters of the
Commonwealth" on Plan Sheets C-04A and CO-OS; however, there
remains a discrepancy on the regulatory boundary of this water feature, as
noted above.
The Applicant has failed to comply with these provisions.
r. Section §22-1023 - Compliance with Summary of Outstanding

Comments Letter dated September 6, 2019 as prepared by Jason
Smith, PWS of Hanover Engineering, Inc., which is incorporated
herein as though more fully set forth length, is required. The

Applicant has failed to address all of the items listed within the letter
dated September 6, 2019.
PA DEP Chapter 105 Permit Required
As noted within the September 6, 2019 letter of Jason Smith, Plainfield

Township contends that a PA DEP Chapter 105 Permit is required for any
modification to the Sedimentation Basin No.2 pond.
3. Chapter 23 - Stormwater Management
a. Section §23-405 (D) (5) - Any fencing or landscaping required by the

Township shall be shown on the plan. This requirement has not been
addressed by the Applicant with the Planning Commission or the
Board of Supervisors. The Applicant has not demonstrated
compliance with this provision.
b. Section §23-704 - An Operations and Maintenance Agreement shall be
provided. The Applicant has not demonstrated compliance with this
provision.
c. Section §23-405 - As previously noted in the Township Engineer
(Hanover Engineering Associates, Inc.) review letter dated July 11,2019,
report narrative page 4 of 4 notes that additional storage capacity is
available above the 100-year event storage elevation of 699.1 to the
emergency spillway elevation of703.00; however, the proposed
subsurface conveyance system for the eastern most driveway has a top of
grate elevation of 70 1. Based on the conveyance system design, the
system will be inundated for basin water surface elevations in excess of
696.89. The Township Engineer noted that this item appears to have
been addressed, but cannot be considered to be resolved, pending PA
DEP approval/modification of the NPDES Permit.
d. Section §23-405 - As previously noted in the Township Engineer
it appear that bypass stormwater runoff discharges into the Waltz Creek
and Little Bushkill Creek from new impervious areas without any
effective water quality of volume control BMPs. Specific concern is
directed to the proposed access to Pen Argyl Road, which includes new
inlet connections to an existing conveyance that discharges to Waltz
Creek. The Township Engineer noted that this item appears to have
been addressed, but cannot be considered to be resolved, pending PA
DEP approval/modification of the NPDES Permit.
e.Section §23-405 - As previously noted in the Township Engineer
with the proposed increased basin bottom elevation and the potential 20
vertical feet increase in basin bottom, the Applicant should verify that the
assumptions related to the function/dewatering abilities of the basin, as
included on page 1 of3 of the Sediment Basin No.2 analysis, will remain
valid. This item is subject to further review of the Geologist's Basin
Dewatering Calculations included in the December 28, 2018 plan
review submission. The Township Engineer has deferred further
comments on this item to the latest review letters/discussion of Jason
Smith, PWS (Hanover Engineering, Inc.) and Michael Brunamonti,
P.E.lPhil Gray, PG (BCM Engineers). The Township Engineer noted
that this item appears to have been addressed, but cannot be
considered to be resolved, pending PA DEP approval/modification of
the NPDES Permit and review/approval of the proposed Stormwater
Monitoring Plan, Sediment Basin No.2 Monitoring Plan,
Groundwater Monitoring Plan and Backfill Sampling and Analysis
Plan.
B. Environmental Concerns/General Comments
1. The below identified Environmental Concerns/General Comments are provided in

accordance with the authority bestowed upon the Township as set forth within the
following provisions of the Code of Ordinances of Plainfield Township:
a. Section §27-41O (1) (A) and (B) of the Code of Ordinances of Plainfield
Township.
b. Section §22-1003 (6) of the Code of Ordinances of Plainfield Township.
c. §27-502 of the Code of Ordinances of Plainfield Township
2. Environmental Concerns/General Comments as compiled by the Township

Engineer within are provided as follows.
a. Comments of the Township Engineer as set forth within the Summary of

Outstanding Comments letter as prepared by Hanover Engineering, Inc.
(prepared by Robert Lynn, P.E.) dated July 11, 2019, which is
incorporated herein as though more fully set forth at length.
Environmental Concerns/General Comments are listed in Section A
(Environmental Concerns), Item Numbers 1 through 27.
C. Slate Belt Heat Recovery Center (SBHRC) Land DevelopmentlMajor Subdivision

Proposed Conditions*
*These conditions have not been reviewed or approved by either the Plainfield Township
Planning Commission or the Plainfield Township Board ofSupervisors.
Should the Planning Commission/Board of Supervisors recommend to conditionally approve

the above-referenced plans, provided below is a comprehensive list of potential conditions
pertaining to Overall Facility Operations and Use to consider.
Slate Belt Heat Recovery Center (SBHRC) Land Development
Revised Proposed Conditions
Defmitions:
Applicant - Grand Central Sanitary Landfill, Inc., Synagro Technologies, Inc., and Slate Belt
Heat Recovery Center, LLC.
Operator - the organization that operates the Slate Belt Heat Recovery Center biosolids
processing facility and all of its accompanying accessory uses. Slate Belt Heat Recovery Center,
LLC is the current Operator known to the Township; the term Operator shall apply to any
successor organization that operates the Slate Belt Heat Recovery Center biosolids processing
facility and its accompanying accessory uses.
NMCP - The Nuisance Mitigation Control Plan as approved by the Township and the Applicant.
PA DEP - The Commonwealth of Pennsylvania Department of Environmental Protection (PA

DEP).
Record - Shall include any transcripts, testimony, exhibits, review letters, expert reports, and
submissions made by the Township and the Applicant, as well as any information provided
during the course of the public meetings, each being given their appropriate weight.
Site - Leasehold interest of Slate Belt Heat Recovery, LLC for the SBHRC, as shown on the
approved Final Development Plan.
Lot - The parcel of land delineated, as shown on the approved Final Development, Sheet C-04 of
the Lot Line Adjustment Plan.
Facility - The building, infrastructure, plant, equipment and services that include the industrial
biosolids processing facility use known as the Slate Belt Heat Recovery Center. The land use is
defined locally within §27-202 of the Code of Ordinances of Plainfield Township as a "Material
Separation Facility".
Township - Plainfield Township, which is a Township of the Second Class (political

subdivision) located in Northampton County, Commonwealth of Pennsylvania.
Conditions Agreed Upon by the Applicant:
a. As a condition of Final Land Development approval, the Applicant shall prepare a

complete legal description, and accompanying plot plan, of the parcel of land associated
with the proposed Site to be included in the Final Plan.
b. As a condition of Final Land Development approval, the Final Plan shall depict/state on
the sheet to be recorded that the specific use classification for the use approved for the
Site is a Material Separation Facility, with approved accessory uses and no other uses,

and that the Site is located in the Plainfield Township Zoning District denominated Solid
Waste Processing and Disposal District (SW). "Material Separation Facility" is a land use
specifically defined within §27-202 of the Code of Ordinances of Plainfield Township.
c. As a condition of Final Land Development approval, the Applicant shall obtain a

Township Road Occupancy Permit or any other required utility easements for the State
Route 512 Access Drive, prior to approval and recording of the final plan.
d. As a condition of Final Land Development approval, a Development and Financial

Security Agreement which is mutually acceptable to the Applicant and the Township
shall be prepared and executed prior to approval and recording of the Final Plan, to insure
installation of public improvements required to be built pursuant to the Final Plan. The
Applicant may, at its discretion, choose to complete fully the agreed improvements prior
to recording the Final Plan. Improvements and security (partial improvements with a fee
in lieu of) shall be in accordance with the approved Final Plan.
e. As a condition of Final Land Development approval, the Applicant shall obtain letters
from GCSL and GKEDC agreeing to the Final Plan and conditions.
f. As a condition of Final Land Development Approval, the Material Separation Facility

Use and all accessory uses and activities shall be limited to the area of the Site described
on the Plan, except for earth disturbance, which shall be restricted to the area of the Lot
shown on the approved Plan as well as any areas authorized in applicable permits or
approvals.
g. As a condition of Final Land Development approval, all permitted and approved

activities at the Site and Facility shall be conducted in a manner consistent with the
record provided by the Applicant and the Township to the Planning Commission and the
Board of Supervisors during the land development/subdivision process.
h. As a condition of Final Land Development approval, no direct retail sales to the public
shall be conducted at the Site, including the sale of fuel pellets or fertilizer pellets.
1. As a condition of Final Land Development approval, all uses accessory to the Material
Separation Facility Use, shall cease to be operated within six (6) months of the date that
the Material Separation Facility Use permanently ceases operations at the Site.
J. As a condition of Final Land Development approval, there shall be no equipment stored

on the Lot that is not used for the Material Separation Facility Use and the Refuse
Derived Fuel Facility Use being conducted on the Site.
k. As a condition of Final Land Development approval, the Applicant/Operator shall not

allow parking of transport vehicles containing biosolids, sewage sludge or wastewater to
be parked overnight at the Site. The Applicant/Operator has represented to the Township
that the Applicant/Operator has a need to park clean, unloaded transport vehicles
overnight from time to time on the Site. The amount of such transport vehicles parked on
the Site overnight shall not exceed four (4) clean, empty or unloaded vehicles.
1. As a condition of Final Land Development approval, all required permits shall be

obtained from the Pennsylvania Department of Environmental Protection (PA DEP), and
proof of issuance shall be provided to the Township.
m. As a condition of Final Land Development approval, all required Federal and local
permits shall be obtained and proof of issuance shall be provided to the Township.
n. As a condition of Final Land Development approval, the Applicant and/or Operator of the
proposed Facility will comply with all applicable local, state and federal regulations
related to the Facility or the Site.
o. As a condition of Final Land Development approval, all required road or access driveway
improvements shall be completed prior to the commencement of Material Separation
and/or biosolids processing operations at the Facility or the operation of any accessory
use on the Site.
p. As a condition of Final Land Development approval, a Groundwater, Stormwater and

Biosolids Monitoring Plan that is determined to be satisfactory by the Township and its
consultants shall be submitted to the Township and approved by the Township. Once
approved by the Township, the Applicant and Operator shall comply with the
Groundwater, Stormwater and Biosolids Plan, and the said plan shall be incorporated into
these conditions as if fully set forth. The Groundwater, Stormwater and Biosolids
Monitoring Plan may be amended in writing from time to time upon mutual agreement of
the Township, and the Operator and Applicant. Said Groundwater, Stormwater and
Biosolids Monitoring Plan, or any components thereof, shall be incorporated into any
applicable PA DEP permit, including but not limited to the SBHRC NPDES permit for
Industrial Discharge and the Minor Permit Modification for the Grand Central Sanitary
Landfill, Inc. (Facility ID No. 100265).
q. As a condition of Final Land Development approval, the Applicant/Operator shall

provide the Township with a copy of all plans, reports, monitoring results, performance
data, and notices of violation issued to the Applicant (including its agents, employees, or
consultants) by any state or federal agency, including but not limited to the Pennsylvania
Department of Environmental Protection, the Pennsylvania Bureau of Mining, the United
States Environmental Protection Agency, the U.S. Army Corps of Engineers and the U.S.
Fish and Wildlife Service, regarding any aspect of the Facility or the Site.
r. As a condition of Final Land Development approval, the Applicant/Operator shall hold

regularly scheduled monthly meetings with the Township, and the content of such
meetings shall address details on the ongoing operations and maintenance plan for the
SBHRC Status Review Memorandum - FINAL - 91612019 Page 13
Facility, including but not limited to days of operation in the previous month (including
the dates and times of operation per day), information on incoming and outgoing
biosolids materials processed (including, but not limited to, compliance standards, reports
of amounts received per day/month, reports of amounts processed per day/month, and
reports of material transported from the facility per day/month), operational issues or
planned substantive capital upgrades, the status of both the NMCP and the Groundwater,
Stormwater and Biosolids Monitoring Plan, reports of any non-compliance related to the
Facility or violations of any applicable local, state and federal permits issued for the
Facility, and any issues that could impact compliance with both the NMCP and the
Groundwater, Stormwater and Biosolids Monitoring Plan. The monthly meeting shall
also include reports of any spills, releases, or permit standard exceedances which
occurred in the previous month related to the operation of the Facility or the Site, as well
as a report on the steps taken to address any problems or issues. The content of the
monthly meeting shall also include a report that provides the Township with a date, time,
amount, reason and source of any incoming biosolids or sewage sludge which were
rejected by the Facility for any reason, or was out of compliance with standards for
incoming biosolids. The Applicant and/or Operator shall also report, on a monthly basis,
the final destination or disposal site for any such rejected or non-complying biosolids.
s. As a condition of Final Land Development Approval, the Applicant and/or Operator of

the Facility shall provide sixty (60) days advance notice in writing of the proposed
commencement of any activities which will modify Sedimentation Basin #2 in any
fashion, except for any emergency modifications approved by the PA DEP, in which case
immediate notice of the commencement of any activities which will modify
Sedimentation Basin #2 in any fashion shall be provided to the Township.
t. As a condition of Final Land Development approval, the Applicant and/or Operator shall
take no action related to the Facility or the Site which prevents or impedes compliance
with the terms of the area more fully described within the recorded Easement Agreement
between Grand Central Sanitary Landfill, Inc. and Plainfield Township dated March 12,
1997, and shall provide with sixty (60) days advance written notice of any proposed
changes to the Facility or the Site, which shall include but not be limited to construction
activities related to the Facility or the Site, realignment of the Access Drive, and the
placement of any structures related to the Facility or the Site, which might affect the
Easement Agreement Area in any manner.
u. As a condition of Final Land Development approval, all comments of the Fire Chief of
the Plainfield Township Fire Company and the Emergency Management Coordinator
related to the Facility or the Site shall be addressed by the Applicant and the Operator.
v. As a condition of Final Land Development approval, all access roads associated with the
proposed Facility or Site shall be paved.

w. As a condition of Final Land Development approval, the Applicant /Operator shall
comply with the Nuisance Mitigation Control Plan (NMCP) dated _
and incorporated herein these conditions as if fully set forth. The NMCP shall address the
provisions covering odors and malodorous material related to the Facility or the Site as
set forth in §27-410 (4) (B) of the Township Code of Ordinances at the Site and Facility.
The NMCP shall also cover any and all transportation nuisances associated with the
vehicle transportation ofbiosolids, sewage sludge, and wastewater through Plainfield
Township and Pen Argyl Borough to the Facility or the Site, as well as vehicle
transportation oftreated biosolids and other products or materials, related to the Facility
or the Site, including, but not limited to, fertilizer pellets and fuel pellets, and waste water
generated or produced by the Facility at the Site, through Plainfield Township and Pen
Argyl Borough. The NMCP shall also cover the travel routes taken by each and every
vehicle transporting biosolids or sewage sludge to the Facility or the Site. The NMCP
may be amended in writing by mutual agreement of the Township, and the
Applicant/Operator, and any amendments shall become conditions herein as if fully set
forth.
x. As a condition of Final Land Development approval, the proposed wastewater backhaul

option related to the Facility or the Site will be conducted in compliance with all
applicable PA DEP and Pennsylvania Department of Transportation provisions and
regulations.
y. As a condition of Final Land Development approval, the Applicant/Operator shall obtain

an Act 537 Official Plan amendment, ifrequired, and a will serve letter from the Pen
Argyl Borough Municipal Authority prior to issuance of a building permit.
z. As a condition of Final Land Development approval, the Applicant/Operator shall

complete sewage planning under Act 537, if required, before recording of the Final Plan.
aa. As a condition of Final Land Development approval, the Applicant/Operator shall submit
a will serve letter from Pennsylvania American Water Co.
bb. As a condition of Final Land Development approval, the Applicant/Operator shall

comply with the acceptance criteria set forth in the PA DEP solid waste permit for all
biosolids to be accepted and treated at the Facility. A copy of all materials or infonnation
sent to PA DEP associated with the acceptance criteria shall be provided to the Township
at the same time that said materials or infonnation are transmitted to PADEP.
cc. As a condition of Final Land Development approval, Applicant/Operator shall supply, on

a monthly basis, records of the disposition of all biosolids received for processing or
treatment at the Site and to be disposed of within the municipal limits of Plainfield
Township, including, but not limited to, date, amount, transporter, and location of final
disposition, and the identification and contact information for the entity which receives
the biosolids. If any biosolids processed at the Facility are disposed of at a landfill,
Applicant and/or Operator must provide the date of disposal, amount, transporter
identification, route identification, and location of final disposition of any such biosolids.
dd. As a condition of Final Land Development approval, the Applicant shall provide on the
Final Plan, all relevant details or specifications of the proposed water quality swale or
conveyance for stormwater management at the Site, including, but not limited to, design,
size, cross-sections, outlet design, capacity and volume calculations, and proposed
plantings.
ee. As a condition of Final Land Development approval, the Applicant and/or Operator shall
place a description on the Final Plan regarding how each and every permanent or
temporary BMP on or associated with the Site shall be operated and maintained, and the
identity of any entities responsible for the operation and maintenance of such BMPs. The
Applicant and/or Operator shall notify the Township in writing 30 days in advance of
making any changes reflected in the Final Plan.
ff. As a condition of final Land Development approval, the Applicant and/or Operator shall
allow entry and inspection of the Facility or the Site by any authorized representative of
the Township who has the appropriate personal protection equipment and who has
received appropriate safety instruction during regular business hours, or at any time the
Facility is operating if advance notice of at least 4 hours is provided.
gg. As a condition of Final Land Development approval, the Applicant/Operator shall include
all details related to Facility or Site traffic management including, but not limited to,
signs, barriers, and pavement markers, on the Final Plan. The Applicant and/or the
Operator shall not permit left hand turns into the eastern access drive of the Site from the
Route 512 Access Road.
hh. As a condition of Final Land Development approval a fence around Sedimentation Basin
#2 shall be provided for safety purposes, and to prevent unauthorized access to
Sedimentation Basin #2, if determined necessary by the Plainfield Township Board of
Supervisors, in their sole discretion.
11. As a condition of Final Land Development approval, the Applicant and/or Operator shall
provide certified or verified as-built drawings, in a form acceptable to the Township
Engineer, for every significant alteration or modification to Sedimentation Basin #2
related to the Facility or the Site.
JJ. As a condition of Final Land Development approval, the Applicant and/or Operator shall
provide a schedule of Site inspections during construction on the Final Plan. The Final
Plan shall indicate that no earth-moving activities related to the Facility or the Site may
commence prior to a mandatory pre-construction meeting, which meeting shall include a
representative from the Township, and representatives of the appropriate regulatory
agencies.
kk. A Final Land Development condition shall be that the Applicant and/or Operator shall
provide notice in writing and 30 days in advance of any fill to be placed into
Sedimentation Basin #2.
11. As a condition of Final Land Development approval, no direct discharges of any

pollutants or contaminants associated with the Facility or Site shall be allowed to any
tributary of Waltz Creek or Little Bushkill Creek, or any Waters of the Commonwealth or
the United States, except as permitted by and State or Federal regulatory agencies.
Compliance with this condition shall be confirmed by way of compliance with the
Groundwater, Stormwater and Biosolids Monitoring Plan, as approved.
Conditions Specifically Not Agreed Upon by Applicant:
a. As a condition of Final Land Development Approval, the Applicant shall comply with
Section §27-316 (2) (II) (2) of the Code of Ordinances of Plainfield Township;
alternatively, the Applicant shall obtain a Variance and/or obtain favorable zoning relief
from Section §27-316 (2) (II) (2) of the Code of Ordinances of Plainfield Township,
which reads as follows: "Entrances and exits to the facility shall be separated and clearly
designated; entrances and exits shall each be at least 30 feet in width and shall be located
along either an arterial or collector road."
b. As a condition of Final Land Development Approval, the Applicant shall comply with
Section §27-505 of the Code of Ordinances of Plainfield Township; alternatively, the
Applicant shall obtain a Variance and/or obtain favorable zoning relief from Section §27-
505 of the Code of Ordinances of Plainfield Township, which reads as follows: "All areas
within 50 feet of the banks of any stream, lake, or pond shall be in open space."
c. As a condition of Final Land Development approval, the Applicant shall submit a

verification ofthe current Jurisdictional Delineation by the Army Corps of Engineers for
any areas on or adjacent to the proposed Site.
d. As a condition of Final Land Development approval, the Applicant and Operator shall
limit the capacity of the Facility to treat or dispose of solid wastelbiosolids to a daily
maximum amount of 400 wet tons per day.
e. As a condition of Final Land Development approval, the Applicant and/or Operator shall
retain or submit promptly to the Township and PA DEP, as required by the Groundwater,
Stormwater and Biosolids Monitoring Plan, or any components thereof, and applicable
permits related to the Facility or the Site, copies of any surface water or ground water
sample analyses obtained by Applicant and/or the Operator, and any of their
representatives or consultants related to the Facility or the Site. The current list of
sampling requirements in the NMCP and in the PA DEP regulations will be determined
subsequently as part of the PA DEP General Permit review process, as per the Applicant.
f. As a condition of Final Land Development approval, and prior to issuance of a zoning
permit or building, Applicant or the Operator shall perform or provide the following,
which is necessary to determine whether the proposed use compromises the public health,
safety, and welfare or causes the adverse environmental impacts as listed in §27-41O (1)
(A) and (B) of the Township Code of Ordinances.
In order to provide the necessary information to the Board of Supervisors to assist the
governing body with making the determination as to whether the proposed use
compromises the public health, safety, and welfare, the adverse environmental impacts as
listed within §27-410 (1) (A) and (B) shall be reviewed locally in accordance with the
following standards:
1. Conduct a study, in advance, and identify the current, cumulative, andfuture

effects ofadverse environmental impacts ofall activities associated with the
proposed use. The study must identify and assess direct and indirect
environmental effects that can be negative or positive; identify and assess impacts
that are immediate, short-term or long-term; and which impacts can be
incremental, compounding over time, or develop over the passage ofyears;
2. Determine whether and to what degree the effects or impacts will infringe
unreasonably upon or violate the protected rights and values (air. water, scenic,
historical, natural, and esthetic) or unreasonably cause actual or likely
deterioration ofthe listed values; and
3. Unless the unreasonable effects or impacts ofall activities associated with the
proposed use can be eliminated, or reduced to a level where the impacts are not
unreasonable, then the use cannot be permitted, pursuant to the requirements of
§27-410 (1) (A) and (B).
Please call me or email me if you have any questions or require additional information regarding
this matter.
Thomas R. Petrucci
Township Manager/Secretary
Alternate Zoning Officer
Phone: 610-759-6944 ext 102
Email- manager@plainfieldtownship.org

Enclosures (Benchmark Civil Engineering Peter Terry Letter Dated September 4,2019; Material
Matters, Inc. Trudy Johnston Letter Dated September 5,2019; SBHRC NMCP Facility
Enforcement/Shutdown Provisions Protocol (DRAFT); BCM Engineers Michael Brunamonti
Letter Dated September 4,2019; Hanover Engineering, Inc. Jason Smith Letter Dated September
6,2019; Hanover Engineering, Inc. Robert Lynn Letter Dated July 11, 2019; Hanover
Engineering, Inc. Robert Lynn Letter Dated September 6,2019; Tom Petrucci, Plainfield
Township Manager/Alternate Zoning Officer Letter Dated August 29,2019)
TRP:trp
cc: Plainfield Township Board of Supervisors, Individually

Paige Stefanelli, Plainfield Township Planning Commission Secretary
John Lezoche, Plainfield Township Zoning Officer (via email)
Farley Fry, P.E., Township Engineer for Synagro Applications (via email)
Robert Lynn, P.E. Township Engineer for Synagro Applications (via email)
Jason Smith, PWS, Wetlands Consultant, Plainfield Township (via email)
Michael Brunamonti, P.E., Special Environmental Consultant (via email)
Trudy Johnston, CEO, Material Matters, Inc. (via email)
Peter Terry, P.E., PTOE, PMP, RSP, Benchmark Civil Engineering (via email)
Robin Zmoda, Pen Argyl Borough Manager (via email)
Peter Layman, Pen Argyl Borough Solicitor (via email)
James Hecht, Applicant's Project Manager (via email)
Joe Statile, Applicant's Representative (via email)
Mike Brennan, Esq., Applicant's Attorney/Representative (via email)
Elizabeth Witmer, Esq., Applicant's Attorney/Representative (via email)

1727 Jonathan Street • Allentown, PA 18104
Phone: (610) 776-6700 • Fax: (610) 776-1190 • www.bencivil.com
September 4, 2019
Mr. Thomas R. Petrucci

Township Manager
Plainfield Township
6292 Sullivan Trial
Nazareth, PA 18064
manager@plainfieldtownship.org
RE: Scoping App #S0520190014

Slate Belt Recovery Center (SBHRC), LLC
Plainfield Twp., Northampton County
Benchmark Project No. 671004
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.
If you have any questions please do not hesitate to contact me.
Sincerely,
Peter A. Terry, P.E., PTOE, PMP, RSP

PAT/slc
-2-
Benchmark Civil Engineering Services, Inc. • 1727 Jonathan Street • Allentown, PA 18104 • Phone: (610) 776-6700 • www.bencivil.com
September 5, 2019
Thomas Petrucci, Township Manager

Plainfield Township
6292 Sullivan Trail
Nazareth, PA 18064
RE: Comments on Revised NMCP Dated August 29, 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.)
3. Attachment A; Design & Pre-construction Activities

a. Air Dispersion Modeling (pdf page 12) – Air dispersion isopleth maps will be
generated as part of air dispersion modeling prior to final design and after facility
commissioning. It should be noted that maps associated with final model runs
should be provided to the Township and Borough.
MM RESPONSE: On pdf page 12 of the revised NMCP, Synagro agrees to
provide output plots for each phase of the project within 30 days after generation,
for informational purposes. This item is considered resolved with the August 29
submission.
4. Attachment B; Operational and Preventive Monitoring
a. Odor Preventive Monitoring Procedure (pdf page 15 to 16)
vi. Additional Action – if an odor intensity equal to 3 or greater than 3 is
recorded, then O-9 should be triggered.
MM RESPONSE: The August 29 NMCP did not include this change as
suggested. However, in a conference call held on August 22, 2019 with
Synagro, discussion centered on the difference between preventative odor
monitoring verses addressing odor complaints. During the call, it was
suggested that the annual meeting will serve as the venue to address
changes needed in the preventative odor monitoring procedure if odor
Material Matters, Inc. September 5, 2019
July 26, 2019 Revised NMCP Comments
complaints are being received despite preventative activities. Therefore, it

is suggested that the Township and Boroughs attending the annual meeting
be prepared to request changes to the NMCP, including the Preventative
Odor Monitoring Procedure if appropriate. This item is considered to be
resolved with the August 29 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.
d. Dewatered Biosolids Receiving & Storage; Nuisance Mitigation and Control

Performance Standard (pdf page 22 and 61)
iv. Actions to take - Add bullet “to identify truck and source of solids
unloading at the time. If truck solids are determined to be a malodor
source and all other mitigation practices are determined to be in good
working order (and operating as intended), discontinue taking the source
until effective source odor mitigation measures are implemented”.
MM RESPONSE: We assume that “verify deliveries received following
Dewatered Biosolids Receiving Procedures” means that when loads are
being delivered, preventative odor procedures will be followed.
Additionally, discontinuing loads from sources that trigger “Additional
Action” in the Odor Preventive Monitoring Procedure or are the cause of
an odor compliant is addressed in the Inbound Material Sources and
Odors description on pdf page 61. Specific comments are included in
item 5 below. 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
Plainfield Twp_Rev NMCP August 29 2019_Comment LTR(09-05-2019).doc Page 2 of 5

water”, not air. These items are considered resolved with the August 29
submission.
5. Attachment C – Complaint Response (pdf page 61)

a. The Community Complaint and Response Form asks the caller if the complaint is
related to a truck and asks for the vehicle number and where the truck was located
at the time of the complaint. Documenting complaints about truck odors is an
important part of complaint response, as evident in questions at previous
Plainfield Township Planning commission meetings. However, there is no
detailed plan regarding how truck odor complaints will be resolved, once
received. It is suggested that a specific complaint response section be included
related to truck odors and how they will be addressed and resolved.
MM RESPONSE: Information provided by Synagro in the August 29 NMCP
response includes a one-page description (Inbound Material Sources and Odors)
on the process proposed to address sources with potential for odor nuisances. The
process includes activities related to receiving sources, and when complaints are
received and linked to the source. Comments on the description is provided
below.
• How will high odor loads/sources be identified prior to offloading?
• What time period or how many loads of the high odor sources will be
accepted before mitigation support is offered?
• How long after support services are offered or completed will the sources
continue to be accepted at the SBHRC?
• What impact will the “season” have on the potential for odor?
• Removing sources from the Approved Generators Log that have two
actual odor complaints in four consecutive seasons (total of eight per
year) that are associated with their loads is insufficient.
• There is no specific language that clearly identifies grounds for permanent
removal of a source; either after complaints are received or as part of
preventive monitoring, that is clear and has clear standards.
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.
d. Dust Complaint Response Procedure (pdf page 116)

i. Dust can be generated from a source other than the stack. Under D-4,
include “inspect site for dust in driveways and on vegetation, and outside
property line”.

MM RESPONSE: Additional language was added to the Dust Complaint

Response Procedure. These items are considered resolved with the
August 29 submission.
ii. Add “property site observations” to D-8.

MM RESPONSE: Additional language was added to the Dust Complaint
Response Procedure. These items are considered resolved with the
August 29 submission.
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.
Very truly yours,

Material Matters, Inc
Trudy Johnston
CEO
Cc: Robin Zmoda, Pen Argyl Borough Manager

Peter Layman, Esq.

Slate Belt Heat Recovery Center (SBHRC)
Nuisance Mitigation and Control Plan (NMCP) Facility Enforcement/Shutdown Provisions

Protocol (DRAFT)
September 4, 2019
1. Full compliance with all NMCP (as approved, adopted and amended) provisions and
protocols at all times.
2. Follow all prescribed provisions of the NMCP to:
a. Prevent nuisance odor conditions.
b. Record and communicate nuisance odor complaints.
c. Investigate and resolve all validated nuisance odor complaints.
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.
ii. Change(s) in customer mix of material being received by the Facility or

Site.
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:
Time Period Penalty ($)

First day through Fifteenth Day $250.00 per day/violation
Fifteenth Day through Thirtieth Day $1,000.00 per day/violation
Thirty-First Day to Sixtieth Day $1,500.00 per day/violation
Sixty-First Day to Ninetieth Day $2,000.00 per day/violation
Over Ninety Calendar Days $4,000.00 per day/violation and Facility
Shut Down in accordance with Section 3.5
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.
4. All penalties imposed under the SBHRC NMCP Facility Enforcement/Shutdown

Protocol Provisions are due and payable on the fifth (5 th) day after the penalty accrues.
The penalties accrue without notice from the Township, and are in addition to any
enforcement action the Township may take against the Applicant or the Operator under
law or equity.
2
1001 Lackawanna Trail
BCM
ENGINEERS
Clarks Summit, PA 18411
Phone: (570) 587-3339
Fax: (570) 586-7989
www.atcgroupservices.com
ATC GROUP SERVICES LLC
September 4,2019
Plainfield Township
6292 Sullivan Road
Nazareth, PA 18054
Attention: Mr. Thomas R. Petrucci

Township Manager
Re: Slate Belt Heat Recovery Center LLC (SBHRC)

Plainfield Township, NOlthampton County
Dear Mr. Petrucci:
BCM Engineers/ATC Group Services (BCM) has reviewed the proposed Stormwater Monitoring
Plan, Sediment Basin No.2 Monitoring Plan, Groundwater Monitoring Plan, and Backfill
Sampling and Analysis Plan, as submitted with the letter of transmittal dated August 30, 2019,
from Mr. Thomas G. Pullar, P.E., EARTHRES.
The revised plans reflect changes agreed upon during the conference call held on August 29,
2019. Based upon our review, BCM believes monitoring of the Stormwater Outfalls, Sediment
Basin No.2, and Groundwater, as proposed in the revised plans, provides for an effective means
to monitor stOimwater discharges from the proposed facility.
BCM has also reviewed the email message from Mr. Pullar dated September 3,2019, stating that
PA DEP has "confirmed that a condition can be added to Section C of the NPDES Pelmit
referencing the Township Monitoring Plan." Plainfield Township should request clarification
regarding the following:
I. Is the proposal still that the NPDES permit condition will include the Stormwater
Monitoring Plan only, and that the Sediment Basin No.2 Monitoring Plan and the
Groundwater Monitoring Plan will be included under the GCSL landfill permit
modification?
2. If the answer to the above question is yes, Plainfield Township should be provided
fiuther details showing exactly how the Sediment Basin No.2 Monitoring Plan and the
Groundwater Monitoring Plan will be incorporated into the GCSL landfill permit.
3. Plainfield Township should be provided an opportunity to review and comment upon the
contemplated NPDES Pennit Section C language and any modifications to the GSCL
landfill pelmit.
1
BCM
ENGINEERS
ATC GROUP SERVICES LLC
Plainfield Township September 4, 2019
Please contact me if there are any questions regarding these matters.
Michael J. Brunamonti, P.E.

Project Manager
BCM Engineers/ATC Group Services LLC
Enclosures
cc: Phil F. Gray, Jr., P.G., BCM Engineers/ATC Group Services LLC
2
HanoverEngineering
252 Brodhead Road • Suite 100 • Bethlehem, PA 18017-8944
Phone: 610.691.5644 • Fax: 610.691.6968 • HanoverEng.com
September 6, 2019
Mr. Thomas Petrucci RE: Plainfield Township

Township Manager Grand Central Sanitary Landfill, Inc.
Plainfield Township Slate Belt Heat Recovery Center Project
6292 Sullivan Trail Review Comments
Nazareth, PA 18064 Plainfield Township, Northampton County, PA
Hanover Project PLF18-12
Dear Mr. Petrucci:
We have completed our review of the revised submission materials from EarthRes Group, Inc.
received in our office on September 3, 2019, which included the following materials:
1. EarthRes Transmittal Form addressed to Mr. Thomas Petrucci, Township Manager,

Plainfield Township, dated August 30, 2019
2. EarthRes Letter addressed to Mr. Thomas Petrucci, Township Manager, Plainfield
Township, dated August 30,2019, with attachments including Biosolids Monitoring Plan,
Stormwater Monitoring Plan, Sediment Basin No.2 Monitoring Plan, Groundwater
Monitoring Plan, and Backfill Sampling and Analysis Plan
3. SYNAGRO Letter addressed to Mr. Thomas Petrucci, Township Manager, Plainfield
Township, dated August 30,2019, indicating attached plan sheets that have been revised,
describing edits
4. Revised Plan Sheets for the Preliminary Land Development Plan C-01, C-03, C-04, C-04A,
C-OS, C-06, C-1S, C-17, C-18, C-20, C-23 and for the Truck Turn Exhibits C-04 and C-OS.
Based on our review, we offer the following comments, as related to wetlands, waters, and riparian
buffer impact concerns for the Township's consideration:
1. Per Section 22-1023.4.E. of the Township's Code of Ordinances, the on-site pond is
subject to the 50-foot open space buffer from the existing top of bank. Per Section 22-
1023.1. Purpose - It is the purpose of this Section to establish requirementsfor the establishment,
maintenance andpreseroation ofriparian buffers and open space, as defined herein, to protect the
watercourses, ponds, lakes and wetlands in Plainfield Townsh{b, and to limit the surface areas of buildings
and structures within these areas. Per Section 22-1023.3 ApplicabiJiry, Item A. - This Section shall applY
to all lands within Plainfield Township that are a4jacent to a watercourse. pond, lake or wetland. Per
Section 22-1023.3 AppJicabiliry, Item B. - This Section shall applY to alfJ subdivision or land develo,pment
vlan, submitted after the effective date ofthis Section. Per Section 22-1023.4. General Design Standards,
J. ... ~ :::
Item E. - All areas within 50 ftet ofthe top ofthe bank ofa'!Y pond or lake shall be open space.
Stormwater controlponds, not intended to permanentlY retain water, are not suo/ect to this requirement.
Envisioning and Engineering sustainable, cost-effective, and environmentally responsible projects since 1971
Mr. Thomas Petrucci 2 September 6, 2019
Township Manager
Based on the language presented in the Purpose and Applicability subsections, the intent of
Section 22-1023 is to protect existing wedands and "waters" within the Township. The
pond, identified as Sedimentation Basin No.2 on the Applicant's plans, is a modified old
quarry pond that has a demonstrated and accepted connection to groundwater and nearby
surface waters (through groundwater). The pond permanendy retains water based on
photographic evidence, testimony, and information provided by the Applicant. Additionally,
several fish were observed in the pond along the shoreline during a site visit conducted on
April 26, 2019, which would further support that this feature permanendy retains water.
This pond, while approved in the past for use to control stormwater from adjacent land uses,
does not function explicitly as a "sedimentation basin" and does not meet the design
standards as a sedimentation basin under Chapter 102, Title 25 of the Pennsylvania Code.
The pond also meets the common definition of a "pond" in both the Merriam-Webster and
Black's Law Dictionaries. This pond has been and will continue to be, as proposed, a
permanent surface water feature in the landscape that meets the definition(s) of a "pond"
and also provides certain stormwater control functions and permanently retains water. This
pond has been determined to be a "waters of the Commonwealth." Therefore, the
proposed project is not in compliance with the Township's ordinance, noting the proposed
significant encroachment into the 50-foot buffer area for filling and proposed structures and
facilities.
The recendy submitted Wedand and Riparian Buffer and Open Space Exhibit contains notes
indicating that "Sedimentation Basin #2 is not intended to permanendy retain water" and
that "No open space area is shown around Sedimentation Basin #2 on the existing
conditions plan, Sheet C-05 because the Township specifically decided to not apply such a
buffer during the proceedings for approval of the expansion which included the
reconfiguration of Sedimentation Basin #2 into its current form." As discussed above and
based on ample evidence and testimony, Sedimentation Basin #2 permanendy retains water
and therefore is subject to the Ordinance. Further, the Ordinance was approved by the
Township in 2013 and was not yet established when the prior approval was granted for the
landfill expansion in 2008. Per Section 22-1023.3. Applicabiliry, Item B. - This Section shall applY to
any subdivision or land development plan, submitted qfter the effective date (if/his Section. Therefore, the
Township'S 50-foot open space set-back/buffer is applicable to the existing pond, as
measured from its existing top of bank. This buffer must be shown on the plans. The
current plans are not in compliance with this section of the Ordinance. Regardless of the
Pennsylvania Department of Environmental Protection's (FA DEP's) grant of approvals or
permits for encroachments on the pond (e.g., proposed filling), the Applicant still must
obtain relief from the Township's Ordinance provisions.
2. Per Section 22-1023.4.E. of the Township's Code of Ordinances, the proposed

stormwater easement and associated activities may be in conflict with the 50-foot
open space buffer from the existing top of bank of the on-site pond. See explanation
provided above in Item 1.
3. A Chapter 105 permit(s) or a formal permit determination for "no permit" by PA

DEP needs to be provided to the Township. During the April 26, 2019 on-site meeting,
the PA DEP indicated that a Chapter 105 permit would not be required at this time, and that
the proposed activities would fall under a waiver. A formal permit determination indicating
Township Manager
such should be provided to the Township, which may be in the form of an approved minor
permit modification, as noted by the Applicant.
The proposed activities include the discharge of approximately 100,000 cubic yards of fill
material and stormwater (including associated structures) into the pond, identified as
Sediment Basin No.2 within the application materials. This pond has been determined to
be a "waters of the Commonwealth" and is connected to nearby streams and groundwater.
While the pond may serve certain functions for stormwater control, it is also a surface water
with connections to other surface waters and groundwater. Due to concerns for impacts to
water quality associated with the proposed substantial filling and the stormwater discharges,
the Township feels that a formal review of the proposed activities under Chapter 105 by the
PADEP is warranted.
4. Bog Turtle Clearance needs to be amended to include all wedands along Waltz Creek
that are within 300 feet of the proposed project disturbance area. On August 29, 2019,
Hanover Engineering corresponded with Mr. Robert Anderson of the United States Fish and
Wildlife Service (USFWS) regarding the previously noted concerns related to both wetlands
and bog turtle habitat evaluations provided for Township review. Mr. Anderson reviewed
data and information submitted by the Applicant's consultant for USFWS review and
classified USFWS database information related to bog turtle occurrence in the region, along
with information and photographs provided by Hanover Engineering. Mr. Anderson
concluded in an e-mail to Hanover Engineering that the wetland area along Waltz Creek was
"atypical bog turtle habitat" and that there is "no supporting evidence that bog turtles will be
impacted by the Slate Belt Heat Recovery Center project." This correspondence from
USFWS is sufficient to serve as clearance for the listed Potential Impact on the Pennsylvania
Natural Diversity Inventory (PNDI) Search Receipt for the proposed project.
5. Per Sections 22-1023.4.F. and 22-1023.8. of the Township's Code of Ordinances, all
wedands, waters, and riparian buffers (including open space buffers) must be shown
on the plans by bearings and distances with at least two ties to property comers. The
buffer on wedands can be shown as a dimensioned offset line.
The bearings and distances, with ties to property comers, have been added to the plans for
the on-site and adjacent wetlands and associated riparian buffers, as well as for the Waltz
Creek and its riparian buffer. The bearings and distances, with ties to property comers, have
been added to the plans for the proposed open space buffer around the proposed
reconfigured pond. The bearings and distances, with ties to property comers, for the
existing pond and associated 50-foot open space buffer have not been included on the plans.
As noted above in the response to Item 1, the Township's Ordinance applies to both ponds
and "stormwater control ponds, not intended to permanently retain water." The bearings
and distances, with ties to property corners, for the noted features and associated buffers
must be added to the plans to comply with the Township's Ordinances.
It was determined that the Little Bushkill Creek and its riparian buffer are further than 100
feet from the site, and therefore do not need to be shown on the plans.
6. A monitoring plan that ensures the best protection of on- and off-site surface water
and groundwater, as relating to the operation and maintenance of the proposed Slate
Belt Heat Recovery Center facilities, needs to be finalized to the satisfaction of the
Township Manager
Township. Sediment Basin No.2 is proposed to be filled with approximately 100,000 cubic
yards of fill material and is proposed to receive stormwater from the proposed Slate Belt
Heat Recovery Center facilities. These activities may result in impacts to water quality within
the basin, surrounding groundwater, and nearby streams. The Applicant has indicated that
only clean fill material will be used and will be properly tested in accordance with PA DEP's
Management of Fill guidance document (Document No. 258-2182-773). While the fill
material may meet the definition of "clean fill," the material may contain nutrients, organic
matter, and other constituents which contribute to eutrophication of the pond and
associated water quality impacts. Stormwater inputs may result in similar impacts. The
concerns are amplified with the basin having no regular surface outflow, a condition which
often· results in accumulation of nutrients, organic matter, and other constituents which may
lead to ongoing water quality and odor impacts and a need for management and mitigation.
Due to concerns for water quality impacts to the basin, surrounding groundwater, and
nearby streams, as well as eutrophication and associated potential odors, monitoring of the
basin should be conducted monthly during the growing season for nutrients and chlorophyll
a, in accordance with a monitoring plan that also includes management recommendations
and alternatives that will be implemented at identified, associated thresholds or Action
Levels. The Applicant should work with the Township to develop a satisfactory plan.
Monitoring at established frequencies should be conducted annually for the life of the
project, with reporting of monitoring results and implemented management activities
provided annually to the Township. See Comment 4 - Basin No.2 Monitoring from prior
comment letter dated April 15, 2019.
Also refer to the comments by BCM Engineers regarding surface water and groundwater
quality monitoring.
The proposed draft Sediment Basin No.2 Monitoring Plan included in the July 26, 2019 and
August 30, 2019 review materials contained only limited testing in comparison to what has
been discussed with BCM Engineers and Hanover Engineering in past meetings and
correspondence. The Target Quantitation Limits (TQLs) for parameters related to
eutrophication concerns (e.g., total phosphorus, nitrate-nitrogen, ammonia-nitrogen, and
total suspended solids) were generally sufficient. Additional parameters, including
chlorophyll a and total Kjeldahl nitrogen should be added at meaningful TQLs. Water
transparency, as measured with a Secchi Disk should also be included. Frequency for
monitoring should be monthly during the growing season, annually, for the life of the
project. Action Levels for chlorophyll a and total phosphorus should be established, with
management activities and alternatives specified. Monitoring should be conducted before,
during, and following construction (during regular operations) of the proposed facilities.
As an alternative to the above recommendations, standards for odor detection associated

with the pond and corresponding Action Levels, with identified Corrective Actions, may be
included in the Nuisance Mitigation and Control Plan, to the satisfaction of the Township.
If this option is implemented, the surface water of Sediment Basin No.2 should be sampled
at least two (2) times during the growing season at least one (1) month apart to provide
background water quality data for all of the parameters listed in Table 1 - Basin of the
Sediment Basin No.2 Monitoring Plan, along with chlorophyll a (per Analytical Method
S10200H-11 or equivalent).
Township Manager
7. Per Section 22-1023.8. of the Township's Code of Ordinances, "All wetlands, waters,
and riparian buffers (including open space buffers) must be shown on the plans ... "
The wetland (and waters) delineation report refers to the on-site and off-site ponds as
"non-jurisdictional stormwater management basins," with no mention as also being
''waters of the Commonwealth." It has been determined by PA DEP that the on-site
pond is a ''waters of the Commonwealth," which should be included in the wetland
evaluation report and labeled accordingly on the project plans. Unless the wetland
consultant officially confirmed with PA DEP that the on-site pond is a "non-
jurisdictional stormwater management basin," this reference should be removed
from their report. If there is official confirmation from PA DEP, then that
confirmation should be provided to the Township. A copy of the revised wetlands
(and waters) report should be provided to the Township. A copy of the revised
wetlands (and waters) report must be provided to the Township. The Sediment Basin No.2
has been labeled as a "waters of the Commonwealth" on Plan Sheets C-04A and C-05, as
required, noting that there is still a discrepancy on the regulatory boundary of this feature per
Township Ordinance, as noted above in comment responses to Items 1 and 5.
If you have any question or require additional information, please contact the undersigned.
Respectfully,
HANOVER ENGINEERING
'-
Jason E. Smith, PWS

Senior Scientist
jes:llb
5: \Projects\Mumcipal\PlamficldTwp\Plfl8-12-G rnndCentraiSanitaryLandfiliHeatRecovery\Wetlands\CoverLotter-PelrUcci-SlateBeltHeatRccoveryCentet-Review-2019-09-06.doc
cc: Mr. Robert J. Lynn, PE, CSI, Hanover Engineering Associates, Inc.
Mr. Farley F. Fry, PE, Hanover Engineering Associates, Inc.
HanoverEngineering
20 C Snyder Lane • Ephrata, PA 17522-9101
Phone: 717.721.7444· Fax: 717.721.7447· HanoverEng.com
July 11,2019
Via E-Mail
Mr. Thomas R. Petrucci, Township Manager RE: Grand Central Sanitary Landfill Heat Recovery
Plainfield Township Preliminary/Final Land Development
6292 Sullivan Trail Plan
Nazareth, PA 18064 Summary of Outstanding Comments
Dear Mr. Petrucci:
We have completed our review of the revised submission package received in our office on July 3,
2019, as prepared by Earthres Group, Inc. Based on our review, we offer the following comments:
A. ENVIRONMENTAL CONCERNS
Our comments are based on the information submitted by the Applicant.
1. The Applicant should coordinate with and address any concerns or requirements of
Citizens Water.
The Applicant has indicated that this item will be addressed as part of the final land
development submission.
The Applicant has added water system details to the drawing; but, it is not clear if the
water system information shown on the drawings is satisfactory to Citizens Water.
The Applicant should provide a letter from Citizens Water indicating that the
proposed water service shown on the plans is acceptable. The Meter Pit detail on
Sheet C-l1 shows a two-inch (2") and six-inch (8") connections to the meter pit
while Sheet C-07 shows a single six-inch (6") pipe. Please clarify.
The drawings have been revised to consistendy show an 8" pipe on all drawings.
This item is consideredresolved, pending water service approval from PA

American.
2. A fire hydrant detail is provided on the plan, but it is not clear where a fire hydrant
will be installed. Please clarify. The Applicant should solicit input from the Chief of
the Plainfield Fire Department regarding fire hydrant locations.
Mr. Thomas R. Petrucci, 2 July 11,2019
Plainfield Township
The Applicant has indicated that the fire hydrant and meter pit details will be
addressed as part of the final land development submission.
We reserve further comment pending water service approval from PA American.

Likewise, the applicant should submit documentation from the Plainfield Fire
Department regarding the desired location of any fire hydrants.
This item is consideredresolved, pending water service approval from PA

American.
3. The Applicant should submit documentation that the proposed sewer service and
grinder pump are satisfactory to the Pen Argyl Municipal Authority.
The Applicant has indicated that this item will be addressed as part of the final land
development submission.
We reserve further comment pending submittal by the applicant of actions by Pen

Argyl Municipal Authority regarding the application for sewerage extension and
actions on the Sewerage Mailer Request Form.
This item is considered resolved, pending sewer service extension approval

. from Pen Argyl Municipal Authority.
4. The application to PA DEP indicates that sanitary wastewater will be discharged to

the Pen Argyl Municipal Authority. Details should be provided as part of the final
land development submission.
We reserve further comment pending submittal by the applicant of actions by Pen

Argyl Municipal Authority regarding the application for sewerage extension and
actions on the Sewerage Mailer Request Form.
This item is considered resolved, pending sewer service extension approval

from Pen Argyl Municipal Authority.
5. The applicant has provided cut sheets for the proposed trailer/tanker and the
conditional approval from the Passaic Valley Sewerage Commission to accept
wastewater from the Slate Belt Heat Recovery Center.
We do not have any further comments.
6. The Applicant has noted that the trucks hauling biosolids will be licensed, fully-
contained and tarped. The Applicant should provide examples of similar trucks
transporting biosolids through residential areas with an emphasis on primary sludge,
secondary sludge, primary/secondary blend and undigested sludge.
The applicant has verbally indicated that they have provided two (2) examples and
references where similar trucks are used to transport sewage sludge through
Mr. Thomas R. Petrucci, 3 July 11, 2019
Plainfield Township
residential areas with an emphasis on primary sludge, secondary sludge,

primary/secondary blend and undigested sludge as previously requested. We believe
the odors from primary sludge, secondary sludge, primary/secondary blend and
undigested sludge will create odors greater than stabilized sludge currently disposed
of at the landfill and will have the potential to affect the surrounding area. (See
Section 27-41 O.1.B of the Plainfield Township Zoning Ordinance). The applicant
also notes that biosolids from dairies and comparable facilities may be accepted at
SBHRC. The applicant should provide more information on this matter. Will the
dairy biosolids be digested material, raw manure or manure from unaerated holding
tanks? The applicant has provided some verbal information but should provide more
detailed dairy solids information.
The applicant has provided two references where similar trucks are used to transport
sewage sludge through residential areas. It is not clear if these references cover
transport of primary sludge, secondary sludge, primary/secondary blend and
undigested sludge. The applicant did not provide more detailed information
regarding possible acceptance of dairy biosolids other than the proposed SBHRC
will accept any biosolids that meet the acceptance criteria. The applicant did not
respond to comments regarding if dairy biosolids would be digested material, raw
manure or manure from unaerated holding tanks.
Based on the SBHRCpresentation at theJune 10, 2019, Planning Commission

Meeting, the applicant wiD not be accepting dairy biosolids. The applicant
has provided examples ofwhere the proposed trucks are utilized to haul
biosolids through residential areaSj however, our discussion with the
Township Manager indicates that the examples provided do not appear to
represent conditions similar to those proposed for the SBHRG.
7. The General Information Form (GIF) Notification of Individual NPDES Permit

Application for Stormwater Runoff from Industrial Activities states that "dewatered
municipal biosolids, primary/secondary blend, digested and undigested, will be
transported ..."
Please describe any differences in pellet characteristics (dust, odors etc.)

based on the use primary/secondary blend and undigested biosolids versus
digested biosolids.
Please describe any odor variances between hauling primary or undigested
biosolids versus digested biosolids.
The applicant has not addressed the question regarding the dust and odor potential
from pellets derived from unstabilized sludge versus digested sludge.
Based on the SBHRCpresentation at theJune 10, 2019, Planning Commission

meeting, the applicant appears to have adequately explained that the pellets
are made from the blend ofbiosolidsj therefore, there should be litde or no
deviations in pellet characteristics related to biosolid sources. This item is
Plainfield Township
consideredresolved, subject to resolution ofrelated comments includedin the

Material Matters letter datedJuly 10, 2019.
8. Provide details on the proposed 5,000-gallon tank adjacent to the truck tipping area.
Additional information was provided as part of the application to PA DEP.

Additional information should be included in the final land development submission.
The proposed tank is labeled as a Stormwater Capture Tank but includes wash water
from the unloading/loading area.
The tank includes a vent to provide air while water levels drop during pumping and
will exhaust air when the tank is filling. Odor control is not provided for the exhaust
air. The Applicant should evaluate the need for odor control due the presence of
washwater from the unloading/loading area.
The tank appears to be equipped with one (1) pump. The pumping rate is not
provided. The Applicant should consider a duplex pumping system since this tank
will include wash water from the unloading/loading area. What actions will be
taken if the single pump fails?
The tank is 11 feet in diameter and does not include a fillet. Sludge solids from the
unloading area could accumulate on the flat bottom tank due to the diameter
depending on the rate of pumping. The pumping rate is not defined at this time.
The type of pump is not provided. Will the pump be a solid handling pump or a
grinder pump?
The cartridge carbon filters should be considered as part of the Township review of
the NMCP. Details regarding the tank and pumps should be provided. The
applicant should consider connecting the 5,000-gallon tank to the odor control
system.
See Comment 12.
We understand that the details regarding the tank andpumps are design
details. Based on the infonnation provided, it does not appear that the tank
has been connected to the odor control system. This item has not been
addressed andis further subject to the Material Matters review ofthe NMCP.
9. Will the process wastewater storage tank be equipped with a standalone odor control
system or will one (1) central odor control system serve the entire complex? If the
latter, will overhead ductwork be required to serve the process wastewater storage
tank.
The application to PA DEP indicates that a negative pressure head space will be
maintained in the covered process wastewater storage tank. Additional details
should be provided as part of the final land development submittal.
Plainfield Township
The Applicant provided some additional information and notes that air from the
head space will be conveyed to the odor control system. The Applicant should
provide information on how the air will be conveyed to the air control system since
the Process Water Storage tank is distant from the rest of the facilities.
The applicant notes that the storage tank head space will be connected to the odor
control system without providing any details. Odor control for this tank will be
evaluated by the Township as part of the review of the NMCP.
The applicant has not submitted the requested detailed information. The odor
control system will require further review when more detailed drawings are
submitted as part of the land development process.
We understand that the details regarding the tank andpumps are design
details. Based on the infonnation provided, it does not appear that the tank
has been connected to the odor control system. This item is further subject to
the Material Matters review ofthe NMCP.
10. A proposed pumping station is proposed near the storage tank. Please provide
details.
The application to PA DEP provided additional information. Design details should

be provided as part of the final land development submittal.
A plan has been provided, but with few details. Pipe sizes and the pumping rate
have not been provided. The plan indicates that one (1) pump will be provided but
shows that space is provided for a second pump. The Applicant should consider a
duplex pumping system to improve system reliability. What actions will be taken if
the single pump fails?
As previously noted, odor control for this tank will be evaluated by the Township as
part of the review of the NMCP. The applicant has not responded to comments on
the pump or provisions for a second pump as a backup.
The applicant has not submitted the requested detailed information. The odor
control system and pumping station will require further review when more detailed
drawings are submitted.
This item is further subject to the Material Matters review ofthe NMCP.
11. Provide information on the proposed wastewater connection to the storage silos.
Additional information should be provided as part of the final land development

submission.
Plainfield Township
The Plan shows three (3) connections to the tank. The pipes are not labeled, pipe
materials are not identified, flow arrows are not provided, and pipe diameters are not
indicated. A Fill Pipe Elevation is provided; but, it is not clear if this is associated
with the force main from the 5,000-gallon stormwater collection tank or associated
with force main from the Dryer Building. The Fill Pipe Elevation shows a six-inch
(6") pipe. The pump discharge pipe in the 5,000 tank is three inches (3"). The pipe
size for the pipe conveying process water from the Drying Building to the Process
Water Storage Tank is not provided. Please clarify.
The Applicant is providing a double walled tank for process water storage and leak
detection system under the tank. These features provide valuable security from
leaks. We recommend that force mains discharging to the tank discharge over the
top of the tank wall to further enhance the integrity of the storage tank by reducing
the number of wall penetrations. It appears that two (2) pipe penetrations can be
eliminated by discharging over top of the tank wall.
Profiles should be provided for three (3) pipes associated with the storage tanks.
Profiles are provided for other water and sewage lines. The three process water
pipes crossing the paved area are not shown the relocated storm sewer profile on
Sheet C-09.
A Tank plan should be provided for a for better understanding of pipe layout.
Bollards should be considered for protecting exposed pipes from nearby traffic areas.
Will exposed pipes be provided with freeze protection?
Information should be provided regarding conveyance of process wastewater from

the Drying Building to the storage tank. Is a pumping station provided inside the
Drying Building to convey process water to the storage tank or will process water
from the Drying Building drain to the 5,000-gallon stormwater tank? The plan
shows a pipe leading directly from the Drying Building to the storage tank without
any details. Please clarify.
The applicant has provided a written description that addresses some but not all of
the questions and drawings with details have not been provided.
See comment 12. In addition, the applicant has noted that Standard Operating
Procedures will be employed to minimize wash water and the odor potential of wash
water. We have not received a copy of the referenced Standard Operating
Procedures and reserve comment pending submittal of the Standard Operating
Procedures. The applicant has provided a brief verbal description of pumping
station components.
We reserve further comments pending submittal ofdetailedpumping station

infonnation. This item is further subject to the Material Matters review of
theNMCP.
Plainfield Township
12. The Applicant provided process control information as part of the application to PA
DEP. Additional, more detailed information should be provided as part of the final
land development submission.
The applicant should provide more information regarding loading of process

wastewater on to the trucks. The applicant has verbally indicated that this will occur
at the tipping area and will include very little spillage. The applicant has indicated that
waste from this area will be minimal and will mosdy consist of rainfall runoff.
Written data should be submitted.
The applicant provided a response and cited General Permit Form 20 Equipment
and Process Description that had been submitted to PA DEP but did not provide a
date of the latest submittal and did not provide a copy of the document or provide
copies of any comments made by PA DEP. We reserve further comment pending
receipt of the Permit Form 20.
The finalpump station is not listed as an odor source on Fonn 20. This item
is finther subject to the Material Matters review ofthe NMCP.
New Environmental Comments Per May 30, 2018 Letter
13. The Emergency Contact list in the Contingency Plan submitted to PA DEP should
be modified. The list should be revised to list the Slate Belt Regional Police
Department instead of the Pen Argyl Police Department. Finally, the emergency
contact list should include emergency medical response services provided by the
Plainfield Township Volunteer Fire Company and Suburban Emergency Medical
Services.
We have no additional comments at this time.
This item is considered resolved.
14. The Applicant should provide assumed process wastewater characteristics and note
if the process wastewater storage tank will include solids withdrawal capability or
mixing capability.
The applicant has indicated that aeration and mixing will not be provided at this time
based the design concepts of a comparable belt type biosolids thermal dryer that
operates in a similar general arrangement. The applicant should provide the name
and contact information for the comparable installation.
This item is subject to further review ofdesign wastewater characteristics.
B. ZONING - Items included under this section, as related to traffic, are subject to
further review by the Township Zoning Officer and Benchmark Civil Engineering
Services, Inc.
Plainfield Township
1. Section 27-410.5 - The proposed development does not appear to require a full
traffic impact study based on gross floor area or expected trip generation; however,
we have the following comments based on the provided truck turning exhibit and
general access configuration:
a. Several movements at the main facility access at the western end of site
appear to significandy encroach into opposing lanes. The western access
does not appear to be able to accommodate trucks passing in opposite
directions as they enter and exit the facility.
The applicant has not provided information regarding how truck traffic
conflicts will be resolved, whether they proposed development site or the
access road. The applicant's information addresses only turning movement
patterns and does not provide remedy for conflicts. Further, the provided
information is solely related to the Synagro Facility and does not consider
conflicts with traffic related to the other existing uses within the site. We
refer the applicant to Section 27-703.1.A,B, D and H.
b. Proper signage shall be provided for traffic pattern clarity and access use
restrictive, as necessary. Truck entrance access at the eastern driveway should
be prohibited.
Full signing and pavement marking plan and details shall be provided.
The applicant indicated that a signing and pavement marking plan will be
provided with the Final Plan.
c. The Applicant shall indicate how trucks will be staged if multiple trucks
arrive for loading and/or off loading at the same or similar times.
The Applicant has indicated that staging of multiple vehicles is unlikely to

occur. Additional information to support this claim shall be provided.
While the applicant has indicated staging of multiple trucks is not likely to
occur, does not adequately address what measures will be implemented if it
does occur. The potential for conflict within the SBHRC site as well as the
potential of conflict on the access road, should staging be necessary, should
be addressed.
d. The Applicant shall address how conflicts between truck movements and
passenger vehicles will be mitigated.
We refer the applicant to Section 27-703.1.A, B, D and H.
ADDITIONAL COMMENTS PER AUGUST 15,2018 TRAFFIC INFORMATION

Plainfield Township
2. Section 27-41 0.5C(2) - The Applicant shall document, to the satisfaction of the
Zoning Officer, the existing access road is equivalent to a collector or major road
standards. Pavement markings may be required as recommended in the traffic
evaluation.
3. Section 27-410.5D(1) - The Applicant shall document all major roads and
intersections serving the project, including the access road and any primary
driveways or intersections.
4. Section 27-41 0.5D(2) - The Applicant shall document traffic circulation and update
the figures to include the site driveways. In addition, the evaluation shall document
traffic for employees, i.e. maintenance, operations, administrative, etc., other than
truck traffic.
5. Section 27-410.5D(3) - The Applicant shall conduct current (2018) turning

movement counts at all intersections or driveways included in the analyses. Due to
the nature of this comment, we did not review the capacity analyses.
6. Section 27-410.5D(4) - The Applicant shall update all analyses based upon the
turning movement counts and verify the opening year, as 2019 may be an overly
aggressive schedule.
7. Section 27-410.5D(5) - The Applicant shall document all site associated trips are
included and provide for any revised trip distribution for local trips not associated
with Route 33.
8. Section 27-410.5D(6) - The Applicant shall update all figures and analyses with data
obtained in the turning movement counts. Auxiliary lanes shall be evaluated for all
approaches and the signal warrant evaluations shall include all warrants applicable for
the intersections and driveways.
9. Section 27-410.5DO).(8) - The Applicant shall identify existing and projected

problems or deficiencies and propose mitigation as needed. Turning templates shall
be submitted documenting the largest anticipated vehicle can safely and efficiently
access and circulate the site without encroaching upon opposing lanes, loading or
parking spaces. Lastly, all mitigation measures shall be included in the Site
Plans/Land Development Plans.
With regard to the December 28,2018 revised Access Study and the February 4, 2019 plan
submission, we defer to Benchmark Civil Engineering Services, Inc., Traffic Study review.
As noted herein, the need for a traffic impact study based on gross floor area or expected
trip generation is not met; however, we refer the applicant to Section 27-410.5 which
includes provisions for traffic impact assessment for any "truck terminal, or any sanitary
landfill, recycling, facility, material separation facility, composting facility, refuse derived fuel
facility or any solid waste transfer facility".
Plainfield Township
C. SUBDIVISION AND LAND DEVELOPMENT
1. Section 22-503.1.A(6) - Sanitary sewer profiles shall be provided.
Evidence of Pen Argyl Municipal Authority review and approval of the sanitary
sewer design and details shall be provided prior to Final Plan approval by Plainfield
Township.
This item wiD be consideredresolved with the review and approval ofthe
design by Pen ArgylMunicipal Authority as part ofthe Final Plan review
process.
2. Section 22-503.1.AO) - Water system profiles shall be provided.
Evidence of PA American Water Company review, and approval of water system

design and details shall be provided prior to Final Plan approval by Plainfield
Township.
design by PA American as part ofthe Final Plan reviewprocess.
3. Section 22-503.8.A - Evidence of Erosion and Sedimentation Control Plan approval

by Northampton County Conservation District shall be provided.
Evidence of review and approval shall be provided prior to the commencement of

any earthmoving activities permitted within unconditional Preliminary Plan approval,
in accordance with the PA MPC provisions, or prior to final plan review and
approval by Plainfield Township.
Erosion and Sedimentation Control Plan by Northampton County
Conservation District andissuance ofNPDES Permit/Modification by PA
DEP.
4. Section 22-503.11 - Construction details of sanitary sewer and water facilities shall
be in accordance with the respective service providers (PA American Water).
The applicant has indicated the PA American Water Details will be provided when
received.
5. Section 22-504.2 - Certification ofPA American Water's public water supply shall be
provided prior to Final Plan review and approval by Plainfield Township.
Plainfield Township
6. Section 22-504.3.A - Certification Pen Argyl Municipal Authority's public sanitary

sewer service including provider's ability to serve the project, conditions of service
and authority to serve the facility shall be provided prior to Final Plan review and
approval by Plainfield Township.
This item wiD be considered resolved with the review and approval ofthe
design by Pen Argyl Municipal Authority as part ofthe Final Plan review
process.
7. Section 22-504.8 - A Traffic Study shall be provided for all sanitary landfill,
recycling, material separation, composting, refuse derived fuel or solid waste transfer
facilities in accordance with Section 27-410.5 of the Code.
As noted herein, the Zoning Ordinance Section 27-410.5 does not require traffic
study for the proposed use based solely on gross floor area or trip generation and is
subject to Township Engineer determination; however, the Subdivision and Land
Development Ordinance requires a study for the proposed Materials Separation use.
Based on our review of the provided information, the lack of information regarding
the full use of the access road and access from Rt. 512 and the information included
in the Form 20 - Narrative associated with the Municipal or Residual Waste General
Permit application, we believe that a study is appropriate. The Applicant initially
indicated that the trucks delivering the sludge cakes to the processing facility would
also be hauling the waste-water back to the points of origin for processing; however,
the referenced narrative indicates that the wastewater may be removed from the site
by contracted haulers with the resultant combined truck traffic generated of 84
combined trips (42 trucks). The Applicant notes that the additional trucks will be
less than 12% of the approved 716 truck trips for GCSL but does not note the
existing traffic demand of the existing and proposed facilities.
We defer review ofthese requirements to the Access Study reviewprepared by

Benchmark Civil Engineering Services, Inc.
8. Section 22-1003.4 - All aspects of the proposed land developments shall conform to
the Township Zoning Ordinance (Chapter 27) and all other Township Ordinances
and Specifications.
The Applicant has stated that the zoning permit application will be submitted after
land development approval is received, as included in the Plainfield Township
Zoning Officer's review.
zoningpermit application by the Township Zoning OfBeer.
Plainfield Township
9. Section 22-1003.6 - No subdivision or land development shall occur in such a way

that would significantly threaten the public health and safety, including hazard of
toxic substances, groundwater pollutions, traffic hazard and explosive and £ire
hazards.
The Applicant has acknowledged this requirement. The Applicant shall provide
evidence of compliance with all local, state and federal requirements prior to the
Township's consideration of the plan for approval.
This item wiD be consideredresolved upon receipt ofclean compliance

reviews bya11 Township professionals andreceipt evidence that the
applicable local, state and federal agencies have reviewed and approved the
various design andpermitting requirements ofthe proposed facilities.
10. Section 22-1 008.5.A - Requirements for recreation land area or fee-in-lieu of land
area shall be detennined by the Board of Supervisors.
The Applicant has indicated that this requirement will be addressed with the Board
of Supervisors.
This item is subject to review and determination by the Board ofSupervisors.
D. STORMWATER MANAGEMENT
1. Section 22-1009.6.A(8) - Groundwater recharge through Basin No.2 is proposed.

Groundwater recharge is encouraged when suitable subsurface conditions are
present, the Applicant shall define the precautions to be taken to prevent pollution
of the groundwater.
The Applicant has stated that the information will be provided with the revised plan
submission.
The applicant has provided calculations based on certain assumptions. Please refer
to Additional Comment 3, below.
This item is subject to review and acceptance ofthe proposedmonitoring and

samplingplan by Plainfield Township and PA DEP.
2. Section 22-1009.7.G(5) - The Board of Supervisors shall detennine if public safety

will be endangered if Basin No.2 is not fenced. As part of this detennination, the
Board shall also detennine if the proposed concrete wheel stops in the parking area
are adequate protection to prevent erra':lt vehicles from entering thru Basin No.2
area.
The Applicant has noted the concern and stated that the information will be
provided with the revised plan submission.
Plainfield Township
The applicant has included wheel stops and fencing on the latest plan and has
indicated no additional protective measures will be considered unless requested by
the Plainfield Township Board of Supervisors.
This item is subject to review and detennination by the Board ofSupervisors.
3. Section 22-1009.7.J - An outflow control structure shall be provided at the outlet of

all detention/retention basins. The stormwater management calculations indicate
that Basin No. 2 will be a "no discharge" basin. The calculations appear to only
address storage volume. It is unclear how available storage volume will be restored
after any storm event without discharge via basin outlet or infiltration. Clarification is
needed regarding how the stormwater volume will be dewatered.
The Applicant has stated that the information will be addressed with the NPDES
Permit Application and provided with the revised plan submission. We have
reviewed the information submitted as part of the NPDES Permit Application and
there does not appear to be any analysis of the dewatering time and capabilities of
Sediment Basin 2 to dewater the increased runoff volume within the application
information.
This item has not been addressed. We also refer you to the Hanover letters dated
August 22,2018 and February 21,2019, from Jason E. Smith, PWS, regarding
wetlands, waters and riparian buffer impacts of the proposed development.
As the applicant has noted, this item is subject to additional review ofthe
providedgeologic analysis andresponse to Hanover's (Jason Smith's) and
BCM's previous comments.
4. Section 22-1021.A - Evidence of NPDES Permit approval shall be provided to the

Township. Copies of the complete NPDES application package shall also be
provided.
The applicant has indicated that a copy of the final NPDES permit will be provided
to Plainfield Township upon issuance; however, the applicant should provide
evidence of application completion and any technical review comments received
form PA DEP. All revisions to the PCSM Plans, associated with NPDES review
comments (FA DEP (April 1, 2019, Technical Deficiencies letter) shall be provided
to Plainfield Township for review.
This item remains unresolved
5. Section 22-10234.E - The on-site Pond/Sediment Basin No.2 is subject to the 50-
feet open space buffer from the existing top of bank. We refer the applicant to the
latest review letter from Jason Smith of Hanover Engineering for additional
discussion and information.
Plainfield Township
This item is subject to additionalreview ofthe providedgeologic analysis and

response to Hanover's (Jason Smith's) previous comments.
ADDITIONAL COMMENTS BASED ON AUGUST 2018 PLAN AND REPORT AND

THE PLAINFIELD TOWNSHIP STORMWATER MANAGEMENT ORDINANCE
1. Section 40S.D.S - Any fencing or landscaping required by the Township shall be

shown on the plan.
The applicant has indicated that any Township requirements for landscaping and/or
fencing beyond what is included on the Preliminary Plan will be provided on the
Final Plan.
This item is subject to review and determination by the Board ofSupervisors.
2. Section 704 - An Operations and Maintenance Agreement shall be provided.
This item shaD be addressed as part ofthe Final Plan application.
3. It appears that bypass stormwater runoff discharges into the Waltz Creek and Little
Bushkill Creek from new impervious areas without any effective water quality or
volume control BMPs. Specific concern is directed to the proposed access to Pen
Argyl Road, which includes new inlet connections to an existing conveyance that
discharges directly to Waltz Creek.
This item appears to have been addressed with the December 28, 2018 and February
4, 2019 plan review submissions, subject to PA DEP approval of the NPDES
Permit.
This item is consideredresolved, subject to approval/modification ofthe

NPDES Permit.
4. With the proposed increased basin bottom elevation (refer to limitations identified in
item 4, above) and the potential 20 vertical feet increase in basin bottom, the
applicant should verify that the assumptions related to the function/dewatering
abilities of the basin, as included on page 1 of 3 of the Sediment Basin No.2 analysis,
will remain valid.
This item is subject to further review of the Geologist's Basin Dewatering

Calculations included in the December 28, 2018 plan review submission. We defer
to the latest letter and discussions between the applicant and BCM representatives.
This item is considered resolved, subject to approval/modification ofthe

NPDES Permit andreview and approval ofthe proposed water quality
monitoring and samplingplan.
Plainfield Township
E. GENERAL
1. The Township should consider the comments of the Township Zoning Officer.
2. The Township should consider the comments of the Township Solicitor.
3. The Township reserves the right to make additional comments based on the review
of revised submission materials.
4. Nothing included or excluded from this review relieves the Applicant from full
compliance with Township ordinances or any other Federal, State or Local
regulations.
If you have any questions, please contact the undersigned.
Respectfully,
HANOVER ENGINEERING
Robert J. Lynn, P
rjl:fff/saf
S:\Municipal\Plainfield Township\2018\PLFI8-12 Grand Central Sanitary Landftll Heat Recovery\Grand Central Sanitary Landfdl Heat Recovery Plan Review 2019-07-
It.docx
cc: David Allen, P.E., EarthRes Group, Inc. (via email)

Jim Hecht, Slate Belt Heat Recovery Center (via email)
Matthew Goodrich, Zito Martino & Karasek, LLP (via email)
Glenn Kempa, Waste Management (via email)
Scott Perin, Waste Management (via email)
Trudy Johnston, Material Matters, Inc. (via email)
HanoverEngineering
20 C Snyder Lane • Ephrata, PA 17522-9101
Phone: 717.721.7444· Fax: 717.721.7447· HanoverEng.com
September 6, 2019
Via E-Mail
Mr. Thomas R. Petrucci, Township Manager RE: Grand Central Sanitary Landfill Heat Recovery
Plainfield Township Preliminary/Final Land Development
6292 Sullivan Trail Plan
Nazareth, PA 18064 Summary of Outstanding Comments
Dear Mr. Petrucci:
We have completed our review of the revised submission package received in our office on
September 3, 2019, as prepared by Earthres Group, Inc. Based on our review, we offer the following
comments:
A. ENVIRONMENTAL CONCERNS
Our comments are based on the information submitted by the Applicant.
1. The Applicant should coordinate with and address any concerns or requirements of
Citizens Water.
The Applicant has indicated that this item will be addressed as part of the Final Plan
submission, pending water service approval from PA American.
2. A fire hydrant detail is provided on the plan, but it is not clear where a fire hydrant
will be installed. Please clarify. The Applicant should solicit input from the Chief of
the Plainfield Fire Department regarding fire hydrant locations.
The Applicant has indicated that the fire hydrant and meter pit details will be
addressed as part of the Final Plan submission, pending water service approval from
PA American.
3. The Applicant should submit documentation that the proposed sewer service and
grinder pump are satisfactory to the Pen Argyl Municipal Authority.
The Applicant has indicated that this item will be addressed as part of the Final Plan
submission, pending sewer service extension approval from Pen Argyl Municipal
Authority.
Mr. Thomas R. Petrucci, 2 September 6, 2019
Plainfield Township
4. The application to PA DEP indicates that sanitary wastewater will be discharged to

the Pen Argyl Municipal Authority. Details should be provided as part of the final
land development submission, pending sewer service extension approval from Pen
Argyl Municipal Authority.
5. A proposed pumping station is proposed near the storage tank. Design details
should be provided as part of the Final Plan submittal.
6. Provide information on the proposed wastewater connection to the storage silos as

part of the Final Plan review process.
B. SUBDIVISION AND LAND DEVELOPMENT
1. Section 22-503.1.A(6) - Sanitary sewer profiles shall be provided.
Evidence of Pen Argyl Municipal Authority review and approval of the sanitary
sewer design and details shall be provided prior to Final Plan approval by Plainfield
Township. This item will be considered resolved with the review and approval of
the design by Pen Argyl Municipal Authority as part of the Final Plan review process.
2. Section 22-503.1.A(7) - Water system profiles shall be provided.
Evidence of PA American Water Company review, and approval of water system

design and details shall be provided prior to Final Plan approval by Plainfield
Township. This item will be considered resolved with the review and approval of
the design by PA American as part of the Final Plan review process.
3. Section 22-503.8.A - Evidence of Erosion and Sedimentation Control Plan approval

by Northampton County Conservation District shall be provided.
Evidence of review and approval shall be provided prior to the commencement of

any earthmoving activities permitted within unconditional Preliminary Plan approval,
in accordance with the PA MPC provisions, or prior to final plan review and
approval by Plainfield Township. This item will be considered resolved with the
review and approval of the Erosion and Sedimentation Control Plan by
Northampton County Conservation District and issuance of NPDES
Permit/Modification by PA DEP.
4. Section 22-503.11 - Construction details of sanitary sewer and water facilities shall
be in accordance with the respective service providers (FA American Water).
The applicant has indicated the PA American Water Details will be provided when
received. This item will be considered resolved with the review and approval of the
design by PA American as part of the Final Plan review process.
Plainfield Township
5. Section 22-504.2 - Certification of PA American Water's public water supply shall be

provided prior to Final Plan review and approval by Plainfield Township. This item
will be considered resolved with the review and approval of the design by PA
American as part of the Final Plan review process.
6. Section 22-504.3.A - Certification Pen Argyl Municipal Authority's public sanitary

sewer service including provider's ability to serve the project, conditions of service
and authority to serve the facility shall be provided prior to Final Plan review and
approval by Plainfield Township. This item will be considered resolved with the
review and approval of the design by Pen Argyl Municipal Authority as part of the
Final Plan review process.
7. Section 22-1003.4 - All aspects of the proposed land developments shall conform to
the Township Zoning Ordinance (Chapter 27) and all other Township Ordinances
and Specifications. This item will be considered resolved with the review and
approval of the zoning permit application by the Township Zoning Officer.
8. Section 22-1003.6 - No subdivision or land development shall occur in such a way

that would significandy threaten the public health and safety, including hazard of
toxic substances, groundwater pollutions, traffic hazard and explosive and fire
hazards.
The Applicant has acknowledged this requirement. The Applicant shall provide
evidence of compliance with all local, state and federal requirements prior to the
Township's consideration of the plan for approval.
This item will be considered resolved upon receipt of clean compliance reviews by all
Township professionals and receipt evidence that the applicable local, state and
federal agencies have reviewed and approved the various design and permitting
requirements of the proposed facilities.
9. Section 22-1008.5.A - Requirements for recreation land area or fee-in-lieu of land

area shall be determined by the Board of Supervisors.
The Applicant has indicated that this requirement will be addressed with the Board
of Supervisors.
C. STORMWATERMANAGEMENT
1. Section 22-1009.6.A(8) - Groundwater recharge through Basin No.2 is proposed.

Groundwater recharge is encouraged when suitable subsurface conditions are
present, the Applicant shall define the precautions to be taken to prevent pollution
of the groundwater.
This item is subject to review and acceptance of the proposed monitoring and
sampling plan by Plainfield Township and PA DEP.
Plainfield Township
2. Section 22-1009.7.G(5) - The Board of Supervisors shall determine if public safety

will be endangered if Basin No. 2 is not fenced. As part of this determination, the
Board shall also determine if the proposed concrete wheel stops in the parking area
are adequate protection to prevent errant vehicles from entering thru Basin No.2
area.
The applicant has included wheel stops and fencing on the latest plan and has
indicated no additional protective measures will be considered unless requested by
the Plainfield Township Board of Supervisors. This item is subject to review and
determination by the Board of Supervisors.
3. Section 22-1009.7.] - An outflow control structure shall be provided at the outlet of

all detention/retention basins. The stormwater management calculations indicate
that Basin No.2 will be a "no discharge" basin. The calculations appear to only
address storage volume. It is unclear how available storage volume will be restored
after any storm event without discharge via basin outlet or infiltration. Clarification is
needed regarding how the stormwater volume will be dewatered.
As the applicant has noted, this item is subject to additional review of the provided
geologic analysis and response to Hanover's Gason Smith's) and BCM's previous
comments.
4. Section 22-1021.A - Evidence of NPDES Permit approval shall be provided to the

Township. Copies of the complete NPDES application package shall also be
provided.
The applicant has indicated that a copy of the final NPDES permit will be provided
to Plainfield Township upon issuance; however, the applicant should provide
evidence of application completion and any technical review comments received
form PA DEP. All revisions to the PCSM Plans, associated with NPDES review
comments (pA DEP (April 1, 2019, Technical Deficiencies letter) shall be provided
to Plainfield Township for review, prior to Final Plan review and approval by
Plainfield Township.
5. Section 22-10234.E - The on-site Pond/Sediment Basin No.2 is subject to the 50-
feet open space buffer from the existing top of bank. We refer the applicant to the
latest review letter from Jason Smith of Hanover Engineering for additional
discussion and information.
This item is subject to additional review of the provided geologic analysis and
response to Hanover's Gason Smith's) previous comments.
ADDITIONAL COMMENTS BASED ON AUGUST 2018 PLAN AND REPORT AND

THE PLAINFIELD TOWNSHIP STORMWATER MANAGEMENT ORDINANCE
1. Section 405.D.5 - Any fencing or landscaping required by the Township shall be

shown on the plan.
Plainfield Township
The applicant has indicated that any Township requirements for landscaping and/or
fencing beyond what is included on the Preliminary Plan will be provided on the
Final Plan.
This item is subject to review and determination by the Board of Supervisors.
2. Section 704 - An Operations and Maintenance Agreement shall be provided. This

item shall be addressed as part of the Final Plan application.
E. GENERAL
1. The Township should consider the comments of the Township Zoning Officer.
2. The Township should consider the comments of the Township Solicitor.
3. The Township reserves the right to make additional comments based on the review
of revised submission materials.
4. Nothing included or excluded from this review relieves the Applicant from full
compliance with Township ordinances or any other Federal, State or Local
regulations.
If you have any questions, please contact the undersigned.
Respectfully,
HANOVER ENGINEERING
Robert J. Lynn, P ,
rjl:fff/saf
S:\Projecl>\MunicipaJ\Plainficld Township\2018\PLF18-12 Grand Central Sanitary Landfill I-kat R<'Covcry\Grand Central Sanitary Landed] Heat Recovery Plan Review
2019-Sep.{)6.docx
cc: David Allen, P.E., EarthRes Group, Inc. (via email)

Jim Hecht, Slate Belt Heat Recovery Center (via email)
Matthew Goodrich, Zito Martino & Karasek, LLP (via email)
Glenn Kempa, Waste Management (via email)
Scott Perin, Waste Management (via email)
Trudy Johnston, Material Matters, Inc. (via email)
Plainlield Township Board 01 Supervisors
6292 Sullivan Trail
Nazareth, Penna. 18064
Phone 610-759-6944 Fax 610-759-1999
To: Thomas G. Pullar, P.E., Senior Project Manager, EARTHRES
From: Thomas R. Petrucci, Township Manager, Plainfield Township
RE: Review of Draft Plan Sets C-03, C-15 and C-17 last revised 8/13/2019 for the Grand
Central Sanitary Landfill, Inc. Slate Belt Heat Recovery Center Preliminary Land
Development/Major Subdivision Plan
Date: 8/29/2019
As requested, I have reviewed the draft plan sheets C-03, C-15 and C-17 for the Grand Central
Sanitary Landfill, Inc. Slate Belt Heat Recovery Center Preliminary Land
Development/Major Subdivision Plan. This memorandum is a direct follow-up to the email
you had sent me on August 21, 2019, in which you submitted the above-referenced plans in draft
form for the preliminary review and comment of Plainfield Township officials prior to a formal
submission of a revised final plan set.
1. Variance Required from Section §27-316 (2) (II) (2) ofthe Code of Ordinances of
Plainfield Township
Upon a review of the draft plan sheets C-03, C-15, and C-17, it is the opinion ofthe Zoning
Officer and I that a Variance is still required from Section §27-316 (2) (II) (2) ofthe Code
of Ordinances of Plainfield Township due to the fact that the proposed entrance and exit to
the facility are not located along an Arterial or Collector Road. Pursuant to the requirements
set forth in §27-316 (2) (II) (2), the proposed entrance and exit to the facility are not located
along either an Arterial or Collector road. The proposed entrance and exit to the facility are
located along an interior Private Access Drive of the Grand Central Sanitary Landfill.
Further, the entrance and exit to the facility of the proposed "Pen Argyl Road (S.R. 1011) Low-
Volume Driveway" are not separated or clearly designated. Further, the proposed entrance and
exit to the facility are not each at least thirty feet (30') in width; the driveway has a maximum
width of twenty-four feet (24').
The proposed "Pen Argyl Road (S.R. 1011) Low-Volume Driveway" is proposed to restrict truck
traffic. The Zoning Officer is of the opinion that a Low-Volume Driveway restricted to truck
traffic is not sufficient to serve the facility in accordance with the requirements of Section §27-
316 (2) (II) (2) of the Code of Ordinances of Plainfield Township. Section §27-3l6 (2) (II) (2)
requires that the entrance and exit to the facility be located along an Arterial or Collector Road; it
is the opinion of the Zoning Officer and I that said entrance and exit must allow for the activities
associated with the use to take place. A Low-Volume Driveway would not accommodate the
truck traffic that is associated with the proposed Material Separation Facility use.
2. Benchmark Civil Engineering, Inc. Preliminary Review Comments
I also directed the Township's Traffic Planning Consultant, who is Mr. Peter Terry, P.E. of
Benchmark Civil Engineering, Inc., to perform a review of draft plan sheets C-03, C-15, and C-
17. Mr. Terry's review letter dated August 29,2019, which identified technical deficiencies with
your submission, is enclosed and incorporated herein as though more fully set forth at length.
Please call me or email me if you have any questions or require additional information regarding
this matter.
Sincerely,
~_.
Thomas R. Petrucci
Township Manager/Secretary
Alternate Zoning Officer
Phone: 610-759-6944 ext 102
Email- manager@plainfieldtownship.org
Enclosure (Benchmark Civil Engineering, Inc. Review Letter Dated August 29, 2019)
TRP:trp
cc: Plainfield Township Board of Supervisors, Individually (via email)

Plainfield Township Planning Commission, Individually (via email)
David Backenstoe, Esq., Plainfield Township Solicitor (via email)
John Embick, Esq., Plainfield Township Environmental Attorney (via email)
Paige Stefanelli, Plainfield Township Planning Commission Secretary
John Lezoche, Plainfield Township Zoning Officer (via email)
Farley Fry, P.E., Township Engineer for Synagro Applications (via email)
Robert Lynn, P.E. Township Engineer for Synagro Applications (via email)
Peter Terry, P.E., PTOE, PMP, RSP, Benchmark Civil Engineering (via email)
2
1727 Jonathan Street • Allentown, PA 18104
Phone: (610) 776-6700 • Fax: (610) 776-1190 • www.bencivil.com
August 29, 2019
Mr. Thomas R. Petrucci

Township Manager
Plainfield Township
6292 Sullivan Trial
Nazareth, PA 18064
manager@plainfieldtownship.org
RE: Scoping App #S0520190014

Slate Belt Recovery Center (SBHRC), LLC
Plainfield Twp., Northampton County
Benchmark Project No. 671004
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.
If you have any questions please do not hesitate to contact me.
Sincerely,
Peter A. Terry, P.E., PTOE, PMP, RSP

PAT/slc
enclosure
-2-
Benchmark Civil Engineering Services, Inc. • 1727 Jonathan Street • Allentown, PA 18104 • Phone: (610) 776-6700 • www.bencivil.com

OCR Version Slate Belt Heat Recovery Center Review Memorandum - September 6 2019

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OCR Version Slate Belt Heat Recovery Center Review Memorandum - September 6 2019

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Plainfield Township Board of Supervisors

6292 Sullivan Trail

To: Plainfield Township Planning Commission; David M. Backenstoe, Esq., Plainfield

From: Thomas R. Petrucci, Township Manager

Date: September 6, 2019

1. Benchmark Civil Engineering Letter Dated September 4,2019.

2. Material Matters, Inc. letter dated September 5, 2019;

3. Hanover Engineering, Inc. Jason Smith Letter Dated September 6, 2019;

5. Hanover Engineering, Inc. Robert Lynn Letter Dated September 6, 2019;

6. BCM Engineers Michael Brunamonti Letter Dated September 4,2019;

7. Letter from Tom Petrucci, Plainfield Township Manager/Alternate Zoning

However, the proposed "Pen Argyl Road (S.R. 1011) Low-Volume

SBHRC Status Review Memorandum - FINAL - 9/6/2019 Page 2

b.Section §27-505 - A Variance is required from Section §27-505 of the

c.Section §27-410 (Performance and Traffic Impact Requirements);

• Conduct a study, in advance, and identify the current,

• Determine whether and to what degree the effects or impacts

• Unless the unreasonable effects or impacts ofall activities

SBHRC Status Review Memorandum - FINAL - 91612019 Page 3

The Applicant failed to conduct the above-described Environmental

d.Section §27-410 (Performance and Traffic Impact Requirements);

g. Access Study Review (Compliance with §22-504 (8)- SALDO;

2. Chapter 22 - Subdivision and Land Development Ordinance (SALDO)

SBHRC Status Review Memorandum - FINAL - 9/6/2019 Page 5

SBHRC Status Review Memorandum - FINAL - 9/6/2019 Page 7

The Applicant has failed to comply with these provisions.

r. Section §22-1023 - Compliance with Summary of Outstanding

SBHRC Status Review Memorandum - FINAL - 9/6/2019 Page 8

PA DEP Chapter 105 Permit Required

As noted within the September 6, 2019 letter of Jason Smith, Plainfield

3. Chapter 23 - Stormwater Management

a. Section §23-405 (D) (5) - Any fencing or landscaping required by the

B. Environmental Concerns/General Comments

1. The below identified Environmental Concerns/General Comments are provided in

b. Section §22-1003 (6) of the Code of Ordinances of Plainfield Township.

c. §27-502 of the Code of Ordinances of Plainfield Township

2. Environmental Concerns/General Comments as compiled by the Township

a. Comments of the Township Engineer as set forth within the Summary of

C. Slate Belt Heat Recovery Center (SBHRC) Land DevelopmentlMajor Subdivision

Should the Planning Commission/Board of Supervisors recommend to conditionally approve

PA DEP - The Commonwealth of Pennsylvania Department of Environmental Protection (PA

Township - Plainfield Township, which is a Township of the Second Class (political

Conditions Agreed Upon by the Applicant:

a. As a condition of Final Land Development approval, the Applicant shall prepare a

SBHRC Status Review Memorandum - FINAL - 9/6/2019 Page 11

c. As a condition of Final Land Development approval, the Applicant shall obtain a

d. As a condition of Final Land Development approval, a Development and Financial

f. As a condition of Final Land Development Approval, the Material Separation Facility

g. As a condition of Final Land Development approval, all permitted and approved

J. As a condition of Final Land Development approval, there shall be no equipment stored

k. As a condition of Final Land Development approval, the Applicant/Operator shall not

1. As a condition of Final Land Development approval, all required permits shall be

p. As a condition of Final Land Development approval, a Groundwater, Stormwater and

q. As a condition of Final Land Development approval, the Applicant/Operator shall

r. As a condition of Final Land Development approval, the Applicant/Operator shall hold

s. As a condition of Final Land Development Approval, the Applicant and/or Operator of

SBHRC Status Review Memorandum - FINAL - 9/6/2019 Page 14

x. As a condition of Final Land Development approval, the proposed wastewater backhaul

y. As a condition of Final Land Development approval, the Applicant/Operator shall obtain

z. As a condition of Final Land Development approval, the Applicant/Operator shall

bb. As a condition of Final Land Development approval, the Applicant/Operator shall

cc. As a condition of Final Land Development approval, Applicant/Operator shall supply, on

11. As a condition of Final Land Development approval, no direct discharges of any