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

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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

Material Matters, Inc. September 5, 2019
July 26, 2019 Revised NMCP Comments

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”.

Plainfield Twp_Rev NMCP August 29 2019_Comment LTR(09-05-2019).doc Page 3 of 5

Material Matters, Inc. September 5, 2019
July 26, 2019 Revised NMCP Comments

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

Plainfield Twp_Rev NMCP August 29 2019_Comment LTR(09-05-2019).doc Page 4 of 5

Material Matters, Inc. September 5, 2019
July 26, 2019 Revised NMCP Comments

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.

Plainfield Twp_Rev NMCP August 29 2019_Comment LTR(09-05-2019).doc Page 5 of 5

 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.

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

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