Public Hearing Comments

Draft NPDES Permit No. PA0276120

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

Good evening. My name is Michael Brunamonti. I work for BCM Engineers/ATC Group
Services.

BCM Engineers/ATC Group Services (BCM) has reviewed Draft NPDES Permit No.
PA0276120, as transmitted to Slate Belt Heat Recovery Center LLC (SBHRC) by the
Pennsylvania Department of Environmental Protection (PA DEP), with a cover letter dated July
10,2019. Plainfield Township will submit a complete copy of written comments regarding the
draft NPDES permit to the Department. For purpose of the public hearing, I will briefly
summarize some of the comments.

The PA DEP's cover letter and NPDES Permit Fact Sheet (Fact Sheet) contain language
acknowledging that SBHRC has submitted monitoring plans to Plainfield Township intended to
address the Township's concerns regarding the proposed discharge of stormwater to Basin No.2.
The Fact Sheet also acknowledges that the proposed monitoring plans include an Enhanced
NPDES Monitoring Plan, a Basin No.2 Monitoring Plan, and a Groundwater Monitoring Plan.
The Enhanced NPDES Monitoring Plan was included with the revisions to the NPDES permit
application submitted to PA DEP on July I, 2019; but the Basin No.2 Monitoring Plan, and the
Groundwater Monitoring Plan were not included. The Fact Sheet states that SBHRC indicates
that Basin No.2 water quality monitoring and groundwater monitoring will be addressed in the
PA DEP Waste Management Program permitting.

The applicant proposes to discharge stormwater associated with industrial activities to Basin No.
2, which originated from an abandoned quarry and is directly connected to groundwater. The PA
DEP Clean Water Program must consider groundwater protection when reviewing NPDES
Permit Application No PA0276 120; and Basin No.2 water quality monitoring, and groundwater
monitoring should be included in the draft NPDES permit. Furthermore, ifPA DEP were to
defer the matter of groundwater protection to the Waste Management Program permit, then PA
DEP should publish a draft Waste Management Program permit for review and comment, before
taking any further action on NPDES Permit Application No. PA0276120.

The Draft Permit incorporates additional monitoring requirements based upon the Enhanced
NPDES Monitoring Plan. Specific comments regarding the listed parameters and monitoring
frequencies in the draft permit are as follows:

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SBHRC DEP Public Hearing Comments August 12, 2019

a) Outfall 001 (SBHRC Discharge to Basin No.2, Waltz Creek watershed): BCM
recommends that from the second year after start-up through permit expiration the
minimum measurement frequency should be semiannually for all of the listed parameters,
including the Volatile Organic Compounds (VOCs).

b) Outfall 002 (Basin No.2 Emergency Spillway Discharge to Waltz Creek): BCM
recommends that from the second year after start-up through permit expiration the
minimum measurement frequency should be semiammally for all of the listed parameters,
including the VOCs.

c) Outfall 003 (GKEDC inlet to SBHRC Outfall 001): BCM recommends that VOC
monitoring be required at Outfall 003, with a minimum measurement frequency of
quarterly though year one after start-up and semiannually thereafter.

d) Outfall 004 (GCSL Sediment Trap Discharge to Basin No.2): BCM recommends that
from the second year after start-up through permit expiration, the minimum measurement
frequency should be semiannually for all of the listed parameters, including the VOCs,
copper and nitrate.

e) Outfall 005 (SBHRC Maneuvering & Parking Areas flowing into Outfall 001): BCM
recommends that VOC monitoring be required for this outfall. In addition, the minimum
measurement frequency for all parameters should be quarterly from start-up through year
one and semiannually thereafter.

f) Outfall 006 (SBRC northern drainage area to UNT of L. Bushkill Creek): BCM
recommends that the minimum measurement frequency should be quarterly from start-up
through year one and semiannually thereafter.

g) Outfall 007 (SBHRC eastern drainage area to Basin NO.2): BCM recommends that from
the second year after start-up through permit expiration the minimum measurement
frequency should be semiannually for all of the listed parameters, including the VOCs.

It must be noted that the above stated comments regarding specific outfall monitoring
requirements are predicated upon PA DEP also requiring Basin No 2 water quality monitoring
and groundwater monitoring.

Additional comments regarding the Draft Permit include the following:

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SBHRC DEP Public Hearing Comments August 12,2019

On Page 47, under Routine Inspections, Part C.III.A.I: BCM recommends that routine
inspections should be required on a weekly basis (as opposed to semiannual per the Draft
Permit). In addition, at least once per calendar quarter the routine inspection must be conducted
during a period when a stormwater discharge is occurring (as opposed to once per calendar year).

BCM recommends that the NPDES permit should include a requirement for submission of a
report to the PA DEP and the Township after the first year of the facility operation. The report
should include a summary of all monitoring data collected during the first year of operation,
details regarding any permit limit exceedances or non-compliance, and details regarding any
required corrective actions.

Lastly, Plainfield Township and its consultants believe a Chapter 105 permit is required for the
proposed modifications to Basin No.2.

Thank you.