Public Hearing Comments

Revised Draft NPDES Pennit No. PA0276120

Slate Belt Heat Recovery Center LLC
Plainfield Township, Northampton County
August 12, 2019

Good evening. My name is Jason Smith. I work for Hanover Engineering as a wetland biologist
and senior scientist, and was retained by Plainfield Township as a consultant to assist with the
review of the proposed Slate Belt Heat Recovery Center, including the Subdivision and Land
Development application and related approvals and pennits. I was specifically tasked with
review of proposed and potential impacts to natural features on and immediately adjacent to the
site, including wetlands, waters, riparian buffers, open space buffers, and listed species, as well
as ensuring compliance with associated local, state, and federal regulations.

Hanover Engineering has reviewed Revised Draft NPDES Pennit No. PA0276120 which was
transmitted to Slate Belt Heat Recovery Center LLC (SBHRC) by the Department on July 10,
2019. Plainfield Township will submit a complete copy of written comments regarding the
Revised Draft NPDES pennit to the Department. For purpose of tonight's public hearing, I will
briefly summarize some of the comments related to items I was tasked to address.

The Revised Draft NPDES Pennit addresses the Applicant's intent to conduct Pre-Startup
Sampling on a quarterly basis, as requested by the Township. Due to the pond's connection to
other nearby surface waters and surrounding groundwater, this pre-startup sampling should be
required as part of the NPDES Pennit, and should include stormwater sampling at listed outfalls
and water quality monitoring for the pond, itself. This is especially important for this site given
the existing adjacent land uses, the pond's characteristics as an old quarry, uncertain history with
regard to contamination, and the fact that the pond has been receiving runoff from the adjacent
landfill and Green Knights facilities for many years and will continue to do so. There is
currently no background data for the pond water quality or immediately surrounding
groundwater, which would be required to properly address potential future water quality impacts
as they may relate to the proposed Slate Belt Heat Recovery Center.

As part of the plan review process with the Township, the Applicant has proposed additional
surface water and groundwater monitoring to address Township concerns. This additional
monitoring, including list of parameters, frequency, thresholds, and Action Levels, should be
included in the Revised Draft NPDES Pennit.

The Township is concerned about potential eutrophication of the pond and associated odors
resulting from the proposed discharge of 100,000 cubic yards of fill material and/or the discharge

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of stormwater from the project area into the pond. This concern should be adequately addressed
in the Revised Draft NPDES Pennit, either though additional monitoring of the pond, including
pre-construction, pre-startup, and post-startup, or through adequate provisions for detection and
mitigation as part of the Nuisance Mitigation and Control Plan, and should last for the duration
of the permit.

During the plan review process, the Township has requested for the Preparedness, Prevention,
and Contingency (PPC) Plan to be provided for Township review. The Revised Draft NPDES
Permit states that the PPC Plan must be provided prior to facility start-up by pernlit condition. In
consideration of concerns for on- and off-site water quality impacts and for flooding of Pen
Argyl Road noted by the Township, it is requested that this PPC Plan be required for review and
approval by PA DEP and the Township prior to pennit issuance.

During an on-site meeting with the Township and its consultants, a previously unidentified
wetland was observed along Waltz Creek within 300 feet of the proposed project activities and
appeared to contain potential bog turtle habitat, including adequate hydrology, mucky soils
greater than three (3) inches deep, and qualifying vegetation. The potential impact to this species
for the project area was identified on the submitted Pennsylvania Natural Diversity Inventory
Search Receipt. This concern was subsequently expressed to the Applicant. Final resolution on
this matter should be properly attained prior to pennit issuance.

Plainfield Township and its consultants believe a Chapter 105 permit is required for the proposed
modifications to Basin No.2, specifically the discharge into the basin of approximately 100,000
cubic yards of fill material and stonnwater, including infrastructure, into this "waters of the
Commonwealth." The potential for use ofa waiver is understood; however, the regulations
stipulate that "the Department upon complaint or investigation finds that a structure or activity
which is eligible for a waiver, has a significant effect upon safety or the protection of life, health,
property, or the environment, the Department may require the owner of the structure to apply for
and obtain a permit under this chapter." This basin is also a pond that has been detennined to be
a "waters of the Commonwealth" and is connected to nearby streams and groundwater. This
pond was not explicitly designed, constructed, and maintained as a Chapter 102-compliant
stormwater or sedimentation basin. While the pond may serve certain approved functions for
stornlwater control, it is also a surface water with connections to other surface waters and
groundwater. Further, there is very little known about the existing pond, such as water depth,
water volume, water quality, potential for existing contamination, and other factors. Due to
concerns for impacts to water quality associated with the proposed substantial filling and the
stormwater discharges, the Township feels that a fonnal review of the proposed activities under
Chapter 105 by the Department is warranted.

Thank you for your time and consideration.