Plainfield Township Board of Supervisors 6292 Sullivan Trail Nazareth, Penna, 18964 Phone 610-759-6944 Fax 610-759-1999 Roger Bellas VIA EMAIL AND UPS GROUND DELIVERY Program Manager Waste Management Program Pennsylvania Department of Environmental Protection (PA DEP) Northeast Regional Office 2 Public Square Wilkes Barre, PA 18701-1915 August 14, 2018 RE: Sedimentation Basin No, 2 Modifications Minor Permit Modification — Slate Belt Heat Recovery Center Grand Central Sanitary Landfill Application No. 1200265-A181 PS ID# 964052, AUTO ID# 1221430 Plainfield Township, Northampton County Dear Mr. Bellas: Plainfield Township has reviewed the most recent materials and documents for the above= referenced proposed project, including: the land development plan set, dated February 6, 2018; the NPDES permit application submission, dated March 2018; and correspondence between the project Applicant and the Pennsylvania Department of Environmental Protection (PA DEP). ‘Additionally, we have discussed the proposed project activities with Mr. Kevin White at the PA DEP Northeast Regional Office, specifically to understand the regulatory status of the old quarry pond Itis the Township’s understanding that the pond is regulated as a “waters of the Commonwealth,” and that the PA DEP has determined, based on the Applicant's input, that the Applicant’s proposal to substantially fill a portion of the pond to accommodate a new land development project for a sludge processing facility on the site would qualify as a waived activity under Chapter 105.12(a)(6). The sludge processing facility is proposed to have containment for storage and processing, with stormwater from such areas being collected and properly treated off-site. Stormwater from other areas of the site, however, including vehicle accessways, parking areas, and other impervious surfaces, will be directed to the pond without pretreatment water quality controls Available information about the quarry pond indicates that it was a relatively deep open-pit quarry which was then allowed to fill with water after completion of quarrying and permit termination. The pond was then augmented by owner (it is the Township's understanding that the owner of the pond is the Grand Central Sanitary Landfill, Inc., or a related entity) to provide fortreatment of stormwater for both quality and quantity control for runoff from the adjacent landfill, Green Knights Landfill Gas to Energy Facility, and connecting roadways. According to the Applicant's pending land development plan, the pond is approximately 90 feet deep and does not have a surface discharge. Stormwater inputs to the pond appear to become groundwater, with limited evaporation from the pond surface. The pond is located adjacent to the Waltz Creek and a headwater stream to the Little Bushkill Creek, both of which have elevations slightly below the water elevation of the pond, as provided by the Applicant’s land development plan and other sources. While the pond does not have a normal overland flow connection to the Waltz or Little Bushkill Creeks, an emergency spillway was proposed and shown on past plans to direct overflow to the Little Bushkill Creek. Portions of the Little Bushkill Creek have been designated High Quality (“HQ”) waters by the Commonwealth of Pennsylvania. Accordingly, water quality in HQ waters may not be degraded, and must be protected and maintained. Due to the concem for potential contamination of groundwater and surface water from the proposed pond filling, as well as from future operations of the proposed sludge processing facility, including potential spills of automotive fluids and incoming untreated sludge, the Township is formally requesting that the PA DEP require a permit for the proposed activities. ‘The pond is not lined and appears to have connections to both groundwater and surface water, which may have an influence on water quality and quantity in nearby wetlands, streams, wells, and water supplies, now and in the future, Therefore, itis the Township's position that a detailed review of all proposed activities at the site, including a hydrogeological evaluation, must be conducted to ensure that there will not be “a significant effect upon safety or the protection of life, health, property or the environment,” as provided in Chapter 105.12(a). ‘Thank you for your consideration of this request. We look forward to hearing back from you on this matter. Sincerely, Ege ‘Thomas R. Petrucei ‘Township Manager TRP:jas cc: David Backenstoe, Esquire, Plainfield Township Solicitor John Embick, Esquire, Plainfield Township Environmental Legal Counsel Mr. Jason E. Smith, PWS, Hanover Engineering Associates, Inc. Mr. Robert J. Lynn, PE, CSI, Hanover Engineering Associates, Inc. Mr. Farley F. Frey, PE, Hanover Engineering Associates, Inc. Ms. Erika Bloxham, Facilities Specialist, PA DEP