~MATERlAL

~MATTERS,Inc.
December 28,2018
p.o. Box 224
Elizabethtown, PA 17022
717/367-9697
717/367-0367 FAX
Thomas Petrucci, Township Manager www.mateti.alma..ters.com
Plainfield Township
6292 Sullivan Trail
Nazareth, PA 18064

RE: Summary of Comments Slate Belt Heat Recovery Center

Updated Comments Project Performance Review and Compliance Report

Mr. Petrucci:

At the request of Plainfield Township, Material Matters, Inc. (MM) is providing an update to the
comments prepared on behalf of Pen Argyl Borough dated June 12, 2017 and April 3, 2018
regarding the Project Performance Review and Compliance Report submitted for the Slate Belt
Heat Recovery Center (SBHRC) by the applicant (Synagro) in March 2017. The Report was
updated by the applicant and provided to MM in August 2018.

The original comments included in the June 2017 and April 2018 letters are provided, with an
update to the comment shown in italic. The Pen Argyl letters are attached for reference.

Comments from the June 12,2017 letter to Pen Argyl Borough where sufficient detail was not
provided by the application are included below.
1. Nuisance Odors (l.a) - Comment on applicant willingness to conduct a detailed odor
emission study for the proposed SBHRC relative to conducting an air dispersion model.
Additionally, comment on the applicant's willingness to prepare a Nuisance Odor
Prevention Plan (now called Nuisance Mitigation and Control Plan or NMCP)
The applicant is currently working with the Township to develop an approach for air
dispersion modeling employing good engineering practices and a revision to a draft
NMCP. Suggested guidance was provided in the comment letter.

2. NMCP (l.c) - Comments included a number of questions about the drying system and
axillary equipment to manage odor emissions. Responses provided by the applicant to
the following comments were either not provided, or the level of detail was not sufficient.

a. Estimated percentage of material received at this facility that will be unclassified

and/or unstabilized wastewater solids?

b. How will odors from trucks transporting incoming materials be avoided prior to
offloading?
Material Matters, Inc. December 28, 2018
Updated Comments

c. How will odors from the cake tipping area be contained and treated?

d. How will negative pressure in the off-loading area be maintained?

e. What sanitation practices will be employed to insure that the Cake Receiving
Station area is maintained in a manner free of accumulated wastewater solids or
sludge that could become a source of odors?

f. What practices will be adopted to monitor appropriate air handling flow rates and
pressures for both the Cake Receiving Station and Dryer Building?

g. What is the backup plan for times when the dryer and/or essential auxiliary
equipment is out of service for emergency repairs or maintenance?

h. What conditions would dictate diversion of wastewater solids away from this
drying facility to an alternative processing or disposal site?

We are not aware that the above noted questions have been addressed in
sufficient detail.
3. Dust (2)

a. Provide a sample of thermally dried bioso1ids from a facility that processes

unstabi1ized wastewater solids using a belt dryer similar to the one proposed for
the SBHRC (Hars1ev) to determine percentage of dust in the product and assess
handling characteristics?

b. Provide Standard Operating Procedures for operation of the truck 10adout.

c. Submit basis of design, design drawings, equipment specifications, and operating

requirements for all dust control equipment to be employed in the Dryer Building
and 10adout area.

We are not aware that the above noted questions have not been addressed in
sufficient detail.
4. Vectors (3)

a. Develop and provide a plan to eliminate conditions conductive to the harborage,

breeding, and/or attraction of vectors.

b. Describe how the plan will be implemented, monitored, and/or revised if

necessary?

We are not aware that the above noted questions have not been addressed in
sufficient detail.
5. oise Control (4)

a. How will dB levels be measured at the SBHRC?

Plainfield Twp_SBHRC_Updated Pen Argyl Commem_LTR(11-28.18).doc

Material Matters, Inc. December 28,2018
Updated Comments

b. How frequently will dB levels be measured SBHRC?

We are not aware that the above noted questions have been addressed in
sufficient detail.
6. Wastewater Treatment (original comments related to wastewater treatment facility onsite;
now planned for storage onsite)
a. How will nuisance odors from the storage tanks be monitored and controlled?

We are not aware that the above noted questions have been addressed in
sufficient detail.
Comments from the April 2018 letter to Pen Argyl Borough where sufficient detail was not
provided by the application are included below.
1. It is noted in the Project arrative that the facility shall be operated and maintained in
such a manner as to minimize any potential impacts or impose no undue burden on the
Township. However, a detailed description of how impacts from odors, noise, and dust
will be minimized is not provided.

Detailed information regarding standard operating procedures (SOP), operational

practices, emergency responses (PPC Plan), and performance standards are currently
under development by the applicant, and plans to review with the Township is scheduled
to take place in early January 2019.

2. Sources of odors and odorants are described in the Project arrative. It is noted that the
system will be designed to reduce specific compounds (hydrogen sulfide, ammonia, and
other odorous compounds). OSHA standards for hydrogen sulfide and ammonia were
noted as the target discharge concentration. However, OSHA standards for these
odorants are designed for exposure, and not for odor nuisances from these and other
odorants. Additionally, unless air dispersion modeling has been conducted, explain how
the air will be subject to immediate atmospheric dispersion and the design will eliminate
any nuisance odors.

a. Specific design information about the odor control system removal of odors and
level of effectiveness was not provided.

Satisfactory information provided by the applicant.

b. Odor control system operation and maintenance standard operating procedures

(SOP) were not provided.

Sufficient detailed information was not provided by the applicant; however, SOPs
included in the NMCP are currently being developed and reviewed with the
Township.

Plainfield Twp_SBHRC_Updated Pen Argyl Comment_LTR(12-28-18).doc

Material Matters, Inc. December 28, 2018
Updated Comments

3. The Project Nan-ative notes that operation of the facility will take place in a fully
enclosed building, and inbound trucks will offload in an enclosed receiving pit. The
nan-ative does not include information relative to how long trucks are expected to wait
outside before offloading, and whether the doors will be open at any time during
operation of the facility.

Detailed planning information regarding ojjloading inbound solids and the length of time
trucks will be waiting in line was not provided. Additionally, it is our experience that
odors will escape from tarped trucks due to the buildup of gases during transit. The
NMCP does not currently include sLifjicient detail to address odors from trucks waiting to
ojjload.

4. It is assumed that biosolids in the Biosolids Storage Tanks will be pumped to the Dryer
Building. It is not clear if any or all piping is inside or outside of the enclosed building.
If all piping is not fully enclosed and inside buildings, how frequently will inspections for
leaks take place and how will leaks be detected?

Leaks from biosolids processing facilities are known to take place, in effect bypassing the
odor control system. Specific details regarding routine inspection of the facility for leaks
(potential sources ofodors) is not included in the most recent applicant's Report.

5. It was noted in the Project Nan-ative that the applicant has 20 years of successful
biosolids thermal drying facilities relative to odor control and that the goal of nuisance
odor elimination is achieved at other facilities. Were objective odor studies/assessments
completed at any of the 20 facilities to document low or no nuisance odors? If so, please
provide.

We are not aware of specific information regarding odor studies/assessments (odor

modeling, assessments, or other objective evidence) that were conducted or collected at
other applicant facilities.

Please let us know if you have questions about our response or if you would like to discuss. You
can contact me at (717) 367-9697 or trudy@materialmatters.com.

Very truly yours,

Material Matters, Inc

Trudy Johnston
President

Cc: Robin Zmoda, Pen Argyl Borough Manager

Peter Layman, Esq
 ~MATERIAL
June 12,2017 ~MATTERS,Inc.
p.D. Box 224
Elizabethtown, PA 17022
717/367-9697
717/367-0367 FAX
Mrs. Robin Zmoda, Borough Manager IVlvw.materiaImatters. com
11-13 orth Robinson Avenue
P.O. Box 128
Pen Argyl, PA 18013

RE: Slate Belt Heat Recovery Center

Plainfield Township Planning Meeting

Dear Mrs. Zmoda:

Material Matters has been authorized by the Borough of Pen Argyl (Borough) to review
available documents, and provide comments and request additional information regarding the
Slate Belt Heat Recovery Center (SBHRC). The proposed location of the SBHRC is in
Plainfield Township, adjacent to the Borough. Plans submitted to Plainfield Township indicate
that the SBHRC will receive and process up to 400 wet tons of wastewater solids (also referred
to as cake) per day (approximately 20 trucks at 20%TS) via thermal drying.

The proposed location (Site #2) for the SBHRC is located on the South side of Pen Argyl Road,
immediately north and adjacent to the Grand Central Landfill area. It is approximately 2,000
feet south of residential areas in the Borough, 500 feet southwest of the Borough line and
approximately 1500 feet east of West Pen Argyle residential areas.

The following summarizes comments regarding the documents made available, and outlines the
additional information being sought on behalf of the Borough.

Background

Based on the prOXImIty of receptors (neighbors and public) noted herein, serious
consideration of measures to avoid unintentional off-site nuisance odors and dust emissions,
and attraction of vectors must be undertaken. It is notable that prevailing winds in this area
are generally out of the west, which places Pen Argyl Road (a hardtop public roadway) and
Pen Argyl Borough downwind from the proposed drying facility site. In the absence of wind,
during atmospheric inversion conditions, it is expected that a fugitive odor plume would tend
to flow south shortly after leaving the site, in topographically downgradient directions.

The chance that offsite odors might occur is directly related to:

a. Location, topography, and design of the facility to contain! control emissions (e.g.
Are the Cake Receiving Station and cake bunker contained in structures with
negative air pressure control?)
Material Matters, Inc. June 12,2017

b. The nature of the materials brought into the dryer facility (e.g. Are the solids
received at the facility incompletely stabilized and odorous to begin with?)

c. Proper selection / design of air handling and odor treatment equipment (e.g. Has the
air handling / odor control system been properly sized for adequate air exchange
rates and treatment of odorants contained in off-gases from the incoming materials
and dryer exhaust?)

d. Strict adherence to operating procedures specifically intended to minimize, contain,

and treat odorous air (e.g. Is air handling and treatment equipment being operated as
intended and routinely maintained? Are doors to the Cake Receiving Station building
kept closed?)

otably, a 400 wet ton per day wastewater solids Processing Facility (dryer facility)
would handle a wastewater treatment plant (WWTP) solids production level
approximately equivalent to a 80 million gallon per day (MGD) WWTP (assumes
incoming material averages 20% solids and typical WWTP biosolids production rate of
approximately one dry ton of biosolids per MGD). Interestingly, this is equivalent to a
WWTP handling approximately 4 to 5 times that of the WWTP serving the City of
Bethlehem.

Nuisance odors originating from WWTP facilities are not uncommon. While there are a
number of potential nuisance odor sources at a typical plant, the most common are
associated with the solids handling side of the plant. It is therefore not surprising that
sites where wastewater solids are stored and processed have the potential to become a
serious odor emission source.

When thermally dried, wastewater solids are capable of creating nuisance situations from
dust. Biosolids are generally considered "dusty" if the particle size is below 0.6 mm.
Thermally dried biosolids typically have a wide range of particle sizes depending on the
characteristics of the wastewater solids being dried (undigested versus digested) and the
type of dryer. When fine biosolids particles become airborne from the processing of
solids or from handling / loading dried granules, the dust may be carried offsite and
create a nuisance.

Requirements

The following summarizes requirements related to odor, dust, and vector requirements
referenced in the Plainfield Township Zoning Ordinance and applicable Pennsylvania
Department of Environmental Protection (PADEP) regulatory requirements for air
emissions and processing facilities.

Plainfield Township Zoning Ordinance (Adopted 9 Feb 2000 - amended 10 April

2012) Article 4, relating to GENERAL REGULATIONS, requires:

Pen Ar)gl_Township Planning Meeting_Conunem Letter(6--12·17).doc Page 2 of9

Material Matters, Inc. June 12,2017

a. ' 0 use shall be permitted in any district if it is to be operated in such a manner

so as to create .....significant adverse environmental impact which will
adversely affect the premises or the surrounding areas. [410.A.]
b. The adverse environmental impacts could result by reason of the emission
of.....odor.... noise ... A use could become a prohibited use if the applicant
cannot or will not mitigate its adverse environmental so that those impacts are
reduced to an insignificant level of impact." [41 0.A.2]
c. "As a condition of approval ....the applicant shall supply evidence, satisfactory to
the zoning officer, that the proposed use, structure, process or equipment will
conform fully with all of the applicable performance standards." [41 O.B]
d. "The determination of the existence of (odor) nuisance characteristic shall be
made at the property line." [§ 4l0.C.2]
e. "Continued compliance with the performance standards shall be a
requirement for continued occupancy." [§ 410.C.3]
f. "No odorous material may be emitted into the atmosphere in sufficient quantities
sufficient to be detected without instruments." [§ 410.D.2]
g. Solid waste must not be allowed to accumulate such that odors are generated and
become a nuisance. [§ 410.DA.c]

Plainfield Township Zoning Ordinance (Adopted 9 Feb 2000 - amended 10 April

2012) Article 5, relating to ENVIRO ME TAL PROTECTIO ,requires:
a. " no land shall be used or occupied in any manner that creates any dust,
odor or form of air pollution" [§ 502.E]
b. ''No person shall operate ..... or permit use that does not conform with PADEP
Title 25 Rules and Regulations pertaining to air resources." [§ 513] See PA Title
25 excerpts below .....

PA Title 25, Ch. 123 (Pertaining to Standards for Contaminants - Fugitive Emissions)
states that:
a. "A fugitive emission is an emission of an air contaminant in a specific manner
and it includes particulate matter, sulfur compounds, odor and visible emissions
if emitted other than through a flue." [Fugitive Emission Definition}
b. "A person may not permit the emission into the outdoor atmosphere of any
malodorous air contaminants from any source, in such a manner that the
malodors are detectable outside the property of the person on whose land the
source is being operated." [§ l23.31.(b)]

PA Title 25, Ch. 283 (Pertaining to Resource Recovery and other Processing Facilities)
reqUires:
a. "A plan ..... to prevent and controL ..... nuisances from vectors, odors, dust,
noise and other nuisances not otherwise provided for in the permit application.

Pen Arygl_Township Planning Meeting_Comment Letter(6-1 2·1 7).doc Page 3 of9

Material Matters, Inc. June 12,2017

The plan shall provide for the routine assessment. and provide for
countermeasures." [§ 283.219]
b. Title 25, Ch. 283 regulations are the primary standards applicable to the
permitting of Biosolids Processing Facilities. However, these regulations provide
no specific details relative to odor management.

PA Title 25, Ch. 273 (Pertaining to Municipal Waste Landfills) requires:

a. Odors. [§ 273.218]
1. "An operator shall implement the plan approved under § 273.136 (relating
to nuisance minimization and control plan) to minimize and control
public nuisances from odors. If the Department determines during
operation of the facility that the plan is inadequate to minimize or control
public nuisances, the Department may modify the plan or require the
operator to modify the plan and obtain Department approval."
11. "An operator shall perform regular, frequent and comprehensive site
inspections to evaluate the effectiveness of cover, capping, gas collection
and destruction, waste acceptance and all other waste management
practices in reducing the potential for offsite odor creation."
Ill. "An operator shall promptly address and correct problems and deficiencies
discovered in the course of inspections "
IV. Other. An operator shall implement the plan approved under § 273.136 to
minimize and control other conditions that are harmful to the environment
or public health, or which create safety hazards, odors, dust, noise,
unsightliness and other public nuisances.
b. It is understood that the proposed biosolids dryer facility would not normally be
required to observe Ch. 273 landfill regulations, but the facility will occupy a
parcel situate on the Grand Central Landfill property. It is not clear whether
nuisance odor planning developed for the dryer facility should, or should not, be
coordinated with the existing Grand Central Landfill nuisance control plan. It is
possible that odors from the landfill could sweep across the dryer facility site and
be mistaken for dryer site emissions.

In general, the Plainfield Township Zoning Ordinance prohibits any use that will have a
significant adverse environmental impact resulting from emissions (e.g. odor, dust, noise, vectors,
etc.), requiring the applicant to supply evidence that the proposed use will conform fully with the
applicable performance standards.

Comments / Questions

In consideration of the background information provided in the preceding section, we pose the
following questions and requests for information in an effort to better understand and evaluate
the applicant's intentions relative to off-site nuisance odor, dust, and vector prevention. These
questions are intended to address the full spectrum of potential odor and dust emission points on

Pen Arygl_Township Planning Meeting_Corronent Letter(6-1 2-1 7).doc Page 4 of9

Material Matters, Inc. June 12,2017

the SBHRC facility site including: point source emISSIOns (e.g. drier stack and/or enclosure
exhaust fans); area source emissions (e.g. Sludge Reception Bunker), and; dispersed source
emissions (e.g. fugitive emissions from open doors, trucks, spills, etc.).

1. Nuisance Odors

a. Is the applicant willing to conduct a detailed odor emission study for the proposed
SBHRC, including:

1. Collection of background field olfactometry odor observations at the

proposed site to establish preexisting nuisance odor conditions.

11. An air dispersion model analysis to demonstrate that no odors will be

detectable at the property line (per Plainfield Twp. zoning requirements.)

111. Air dispersion model inputs should include:

1. Reasonable odor emission rates from various points/areas observed

at similar facilities handling similar incoming materials (both type
and volume of materials)

2. Weather data for multiple years from the nearest weather station
having appropriate applicable hourly records

3. Local topography data (DEM - digital elevation model data)

b. In lieu of performing a detailed odor emission study, the applicant shall provide:

1. Documentation of successful performance of similar facilities (i.e., dryer,

unloading structure, operating plan, downtime, etc.) operated by the
applicant that accepts similar wastewater solids (unstabilized or
unclassified)
11. Provide contacts for similar facilities that may be interviewed to assess
facility compliance with Nuisance Odor Prevention operations

111. If the facility creates off-site nuisance odors, there may be a requirement
for the owner/operator to perform the above noted Odor Emission Study
to demonstrate that the facility can be operated without creating off-site
nuisance odors

c. Is the applicant willing to prepare a Nuisance Odor Prevention Plan (NOPP)

addressing the following:
i. Will this facility receive unclassified and/or unstabilized wastewater solids?

Pen Arygl_Township Planning Meeling_Comment Letter(6-12-17).doc Page 5 of9

Material Matters, Inc. June 12,2017

Il. Estimated percentage of material received at this facility that will be

unclassified and/or unstabilized wastewater solids?
Ill. How will odors from trucks transporting incoming materials be avoided
prior to off-loading?

IV. How will odors from the cake tipping area be contained and treated?
v. How will odors from the sludge receiving bunker be contained and treated?
VI. Assuming the Cake Receiving Station is enclosed and maintained in a
negative pressure structure, how will negative pressure be maintained in
consideration of traffic?
Vll. What is the longest period of time that incoming material may be held in
the sludge reception bunker?

Vlli. What sanitation practices will be employed to insure that the Cake
Receiving Station area is maintained in a manner free of accumulated
wastewater solids or sludge that could become a source of odors?

IX. What measures will be employed to insure that trucks leaving the site are
not contaminated with solids that may become a source of off-site
nuisance odor.
X. What practices will be adopted to monitor appropriate air handling flow
rates and pressures for both the Cake Receiving Station and Dryer
Building?

Xl. Describe the air handling, treatment systems and discharge points for the
Cake Receiving Station and Dryer Building. Are these completely
separate systems? How do these discharges relate to the drier exhaust
system described by the applicant in previous submissions?
XII. How are wastewater solids conveyed from the sludge reception bunker to
the Dryer Building? Is the equipment enclosed so that there is no
opportunity for untreated air emissions?

Xill. Submit basis of design, design drawings, equipment specifications, and

operating requirements for all air handling and odor treatment facilities to
be employed at this site.
XIV. What practices will be adopted to monitor odor treatment unit
effectiveness for all odor emission points on the site? (stack, exhaust fans,
etc.).

Pen Arygl_Township Planning Meeting_Comment Letter(6·12-17).doc Page 6 of9

Material Matters, Inc. June 12, 2017

xv. What is the backup plan for times when the dryer and/or essential
auxiliary equipment is out of service for emergency repairs or
maintenance?

XVI. What is the backup plan for times when the air handling system and/or
odor treatment equipment is out of service for emergency repairs or
maintenance?
XVII. What conditions would dictate diversion of wastewater solids away from
this drying facility to an alternative processing or disposal site? What is
the alternative destination (backup plan)?

2. Dust
a. Thermally dried biosolids has the potential to create dusty conditions in and
around the processing facility. We request that the applicant provide the
following information to assess the potential that dust will not create a nuisance
condition at the SBHRC.
1. Provide a sample of thermally dried biosolids from a facility that
processes unstabilized wastewater solids using a belt dryer similar to the
one proposed for the SBHRC to determine percentage of dust in the
product and assess handling characteristics?
11. Describe the method and frequency ofloading thermally dried biosolids
into trucks from the truck loadout.

111. Provide Standard Operating Procedures for operation of the truck loadout.

IV. Describe Best Management Procedures (BMPs) for minimizing dust

emissions from the truck loadout.

v. Describe the air discharge point source from the Dryer Building and how
dust will be removed from the dryer exhaust system.
VI. Submit basis of design, design drawings, equipment specifications, and
operating requirements for all dust control equipment to be employed in
the Dryer Building and loadout area.

3. Vectors
a. Vectors (such as flies) are attracted to putrescible materials, such as wastewater
solids. We request the following information to assess the potential that vectors
will not create a nuisance condition at the SBHRC.
1. Develop and provide a plan to eliminate conditions conductive to the
harborage, breeding, and/or attraction of vectors.

Pen Arygl_Township Planning Meeting_Comment Letter(6-12-17).doc Page 7 of9

Material Matters, Inc. June 12,2017

11. Describe how the plan will be implemented, monitored, and/or revised if
necessary?

4. Noise Control

a. Sound levels at the property line are dictated by the Plainfield Ordinance in
Article 5, Section 511. Specific Sound Level Limits are outline therein. We
request the following information to assess the potential that noise levels are not
expected to exceed the Township Ordinance limits.
i. Documentation of successful performance of similar thermal drying
facilities operated by the applicant.
11. How will dB levels be measured at the SBHRC?
111. How frequently will dB levels be measured SBHRC?

5. Wastewater Treatment

a. We understand that a WWTP is planned to treat approximately 90,000 gallons per

day of "process" wastewater generated at the SBHRC. Sanitary wastes will be
treated off-site by the Pen Argyl WWTP. Wastewater treatment facilities have
the potential to be a major source of nuisance odors, particularly when receiving
wastewater from solids handling and processing operations. We request the
following information to assess the potential for nuisance odor emissions from the
planned WWTP.

1. How will process water from the SBHRC be handled and treated?

11. Will the treatment units be covered so as to control and/or treat odorous
emissions?

111. Where is the planned WWTP to be located?

IV. Is the applicant willing to include the planned WWTP in a detailed odor
emission study to collect background field olfactometry odor observations
to establish preexisting nuisance odor conditions?

v. Is the applicant willing to include the planned WWTP in an air dispersion

model analysis to demonstrate that no odors will be detectable at the
property line (per Plainfield Twp. zoning requirements)?

VI. How will nuisance odors from the planned WWTP be measured?

Pen Arygl_Township Planning Meeting_Commenl Letter(6·12·17).doc Page 8 of9

Material Matters, Inc. June 12,2017

Should you have any questions or comments regarding the information provide herein, please
contact me at (717) 367-9697 or trudy@materialmatters.com.

Very truly yours,

Material Matters, Inc

Trudy Johnston
President

Cc: Peter Layman, esquire

Pen Arygl_Township Planning Meeting_Comment lener(6-11-17).doc Page90f9

 ~MATERIAL
April 3,2018 ~MATTERS,Inc.
P.O Box 224
Elizabethtown, PA 17022
717/367-9697
717/367-0367 FAX
Mrs. Robin Zmoda, Borough Manager IVlY>V. materialmatters.com
Pen Argyl Borough
11-13 orth Robinson Avenue
P.O. Box 128
Pen Argyl, PA 18013

RE: Slate Belt Heat Recovery Center

Review Comments

Dear Mrs. Zmoda:

Material Matters has reviewed the Revised Facility Permit Proposal dated February 23, 2018
regarding the Slate Belt Heat Recovery Center (Center) to Plainfield Township; and responses
from Plainfield Township, Hanover Engineering, and BCM. Comments regarding the Center
were provided by Material Matters on behalf of Pen Argyl on June 12, 2017 and November 27,
2018. All of the comments were not addressed in the recent submittal by Snyagro (applicant), a
copy of which is attached. Our comments and questions relating to the recent submittal are listed
below.

1. It is noted in the Project Narrative that the facility shall be operated and maintained in
such a manner as to minimize any potential impacts or impose no undue burden on the
Township. However, a detailed description of how impacts from odors, noise, and dust
will be minimized is not provided.
2. Sources of odors and odorants are described in the Project Narrative. It is noted that the
system will be designed to reduce specific compounds (hydrogen sulfide, ammonia, and
other odorous compounds). OSHA standards for hydrogen sulfide and ammonia were
noted as the target discharge concentration. However, OSHA standards for these
odorants are designed for exposure, and not for odor nuisances from these and other
odorants. Additionally, unless air dispersion modeling has been conducted, explain how
the air will be subject to immediate atmospheric dispersion and the design will eliminate
any nuisance odors.
a. Specific design information about the odor control system removal of odors and
level of effectiveness was not provided.
b. Odor control system operation and maintenance standard operating procedures
(SOP) were not provided.
3. The Project Narrative notes that operation of the facility will take place in a fully
enclosed building, and inbound trucks will offload in an enclosed receiving pit. The
Material Matters, Inc. April 3, 2018

narrative does not include information relative to how long trucks are expected to wait
outside before offloading, and whether the doors will be open at any time during
operation of the facility.
4. It is assumed that biosolids in the Biosolids Storage Tanks will be pumped to the Dryer
Building. It is not clear if any or all piping is inside or outside of the enclosed building.
If all piping is not fully enclosed and inside buildings, how frequently will inspections for
leaks take place and how will leaks be detected?
5. It was noted in the Project Narrative that the applicant has 20 years of successful
biosolids thermal drying facilities relative to odor control and that the goal of nuisance
odor elimination is achieved at other facilities. Were objective odor studies/assessments
completed at any of the 20 facilities to document low or no nuisance odors? If so, please
provide.

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

Very truly yours,

Material Matters, Inc

Trudy Johnston
Chief Executive Officer

Cc: Peter Layman, esquire

Pen Arygl_Township Planmng Meetmg_Comment lener(O~-03-20 18) doc Page20f2