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
Fifteenth Day through Thirtieth Day
Thirty-First Day to Sixtieth Day
Sixty-First Day to Ninetieth Day
Over Ninety Calendar Days
$250.00 per day/violation
$1,000.00 per day/violation
$1,500.00 per day/violation
$2,000.00 per day/violation
$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.