pS pennsylvania Bw DEPARTMENT OF ENVIRONMENTAL PROTECTION NORTHEAST REGIONAL OFFICE ECEry: August 10,2018 AUG 17 208 BY: fa Mr. Glenn Kempa, District Manager Grand Central Sanitary Landfill, Inc. 910 W. Pennsylvania Avenue Pen Argyl, PA 18072 Re: Sedimentation Basin No. 2 Modifications Minor Permit Modification ~ Slate Belt Heat Recovery Center Grand Central Sanitary Landfill Application No. 100265-A181 APS ID# 964052, AUTH ID# 1221430 Plainfield Township, Northampton County Dear Mr. Kempa: ‘The Department of Environmental Protection (DEP) has reviewed information provided by EarthRes Group, Inc (ERG) regarding proposed modifications to sedimentation basin number 2. ERG provided DEP with background information regarding the history of this basin in an email correspondence dated June 26, 2018. (copy enclosed) The purpose of this correspondence was to seek clarification regarding the regulatory classification of this body of water. ‘Upon review of the information provided and DEP’s historic knowledge regarding basin number 2, DEP has determined that the basin was engineered and presently being maintained as a sediment basin and stormwater control facility. It is a regulated body of water under Pa Code Chapter 105. However, modifications, including filling a portion of the facility is waived from state water obstruction and encroachment permitting requirements under 105.12(a)6. This ‘waiver is for water obstructions and encroachments located in, along, across or projecting into a stormwater management facility or an erosion and sedimentation pollution control facility which meets the requirements in Chapter 102, [ trust that you find this information helpful. If you have additional questions about your application, please contact me, 2 Public Square | Wilkes-Barre, PA 18701-1915 570,826.2511 | Fax $70.826-5448 www. depweb.state.pa.usGrand Central Sanitary Landfill, Inc. 2. Cb Roger Bellas Program Manager ‘Waste Management Program Sincerely, Enclosure cc: EarthRes Group, Inc. Plainfield Township ‘August 10, 2018peri 6 Bellas, roger” From: Thomas Pullar Sent: Tuesday, June 26, 2018 7:18 AM To: Bellas, Roger ce: James Hecht; Brian Cataldo; Ball, Christopher GCSL Basin #2 Roger, ‘As you know, Slate Belt Heat Recovery Center, LLC (SBHRC) proposes to develop a biosolids processing facility located in Plainfield Township, Northampton County, Pennsylvania on a site located adjacent to the Green Knight Economic Development Corporation at the Grand Central Sanitary Landfill (GCSL). On March 21, 2018, GCSL applied for @ minor permit modification for the changes related to SBHRC. Concurrently, SBHRC applied for an individual NPDES permit to cover the discharge of stormwater runoff from the site into Basin #2 at GCSL. As we discussed at our last meeting on the project, Plainfield Township has asked for clarification regarding the regulatory categorization of Basin #2 and we would appreciate the Department's assistance in providing the township with the clarity they seek. For context, the design of the SBHRC provides for containment of stormwater falling on the primary operational areas of ‘the facility. Specifically all stormwater from the truck unloading and product loading areas of the SBHRC will be contained and conveyed to a process wastewater storage tank where it will be tested and hauled offsite for disposal. Most of the remaining stormwater runoff from SBHRC will be conveyed to Basin #2 through a vegetated swale ‘and monitored separately following the terms and conditions of the NPDES permit when issued. Basin #2 is a non-discharging, engineered, permitted stormwater contro! structure located on the GCSt property. The basin was originally excavated as a quarry and was permitted throughout its active mining years as a large noncoal quarry pursuant to PADEP Permit No. 48820501. After completion of mining activities, and under a proposed reclamation plan submitted to PADEP, significant engineering and construction efforts were performed on the quarry to remove all pre-act highwalls, and backfilled through the use of soil, ock and overburden so that the quarry could be reclaimed and used as a stormwater runoff/detention basin. PADEP reviewed the reclamation plan, determined that a “stormwater runoff control feature is compatible with the adjacent land use as part ofa landfill permit area,” approved of the post-mining land-use as a stormwater runoff/detention basin (categorized as a “Developed Water Resource” under the Department's regulations), and the basin was permitted by the Waste Management Program in 2008 in the context of the landfil's Southern Expansion. The originally proposed design for Basin #2 included a discharge barrel from the basin identified as Outfall 012 in GCSL's NPDES Permit No. PA 0074083. The basin’s significant capacity, however, precluded any stormwater from discharging from the basin, and the discharge barrel was never constructed as a result. The basin emergency spillway was built and remains in place. Because Basin #2 operates as a non-discharging basin, Qutfall 012 was ultimately deemed unnecessary and deleted from GCSU’s NPDES permit in the 2016 renewal. GCSL monitors surface water in the channel between the Green Knights facility and Basin 007 quarterly under the landfill permit. Basin #2 will be modified for the SBHRC facility, and the basin modifications were included in the minor permit modification because the basin is a permitted stormwater management feature and within the GCSL landfill permitboundary. The design continues to provide for containment of a 100-year storm event so itis anticipated that Basin #2 will continue to be non-discharging under all typical conditions. During the local review process, questions were raised by Plainfield Township about the regulatory status of Basin #2, and specifically whether it should be considered a pond, or watercourse potentially subject to setback and/or open space requirements under local ordinances. Categorization of the basin as a watercourse would seem to be inappropriate because the basin lacks the flow typically required for a waterbody to be considered 8 watercourse. More importantly, because local ordinances recognize that setback and open space requirements were not meant to apply to stormwater control features, we are requesting your confirmation that the basin operates as a non-discharging, engineered, permitted, stormwater control structure that will be modified as part of the minor modification when issued. The administrative record for the basin clearly reflects this, but we believe that the Department's reiteration of the regulatory categorization of the basin will help to move the project review forward. We appreciate your assistance with this matter and please feel free to call me with any questions. Tom A EarthRes httos/Awww.earthees.com ‘Thomas G. Pullar, P.E. Senior Project Manager 215-852-1135 Cell tpullar@earthres.com 800,254,4553 Toll-Free Pipersville, PA * Morgantown, WV 215.766.1211 PA Office www.Earthes.com 304.212.6866 WV Office Follow us on: 805