HanoverEngineering

20 CSnyder Lane Ephrata, PA 175229101

Phone: 717.721.7444 Fax: 717.721.7447 HanoverEng.com

ovember 1, 2017

Via E-mail

Mr. Thomas R. Pecrucci, Town hip RE: Plainfield Township

Manager Synagro Facilities - Alternate Site
Plainfield Township Slate Belt Heat Recovery Center
6292 ullivan Trail Sketch Plan
azareth, l'A 18064 Hanover Project pLF17-15

Dear Mr. Pecrucci:

We have completed our review of the Sketch Plan Application for the Synagro Facilities, as prepared
by EarrhRes Engineering and cience. Our review was of submittals received on October 11, 2017.

Our review included the follO\ving illfolmation:

1. Olle (1) copy of the Karasek Law Offices, LLC, Sketch Plan Application cover letter dated
October 3, 2017, we have not received a copy of the application
2. One (1) copy of the Sketcll Plan Review Application - Description of Project Tntent dated
October 3, 2017
3. Overall ynagro late Belt Heat Recovery Cemer Sketch Plan - seven (1) Plan sheets (Sheets
C-Ol through CoO?), dated March 23, 2017, last revised September 5, 2017
4. Truck Turning Movement Exhibits - four (4) Plan sheets (Sheets C-09 dlfough -12), last
revised September 5, 2017
5. One (1) copy of the EarrhRes Group, Inc., Steep lope Analysis dated May 2017, including
Plan Sheer C-08, last revised eptember 2017
6. Letter dared Ocrober 6, 2017, withdra\ving all previous submittals

The ketch Plan Application has been reviewed pursuant to the requirements of the Plainfield
Township Subdivision and Land Development Ordinance (SALDO), the Plainfield Township
Zoning Ordinance, and the Plainfield Township Stormwater Ordinance. Contrnents relating ro the
applicable ordinances and other Township regulations follow:

A. SKETCH PLA REVIEW (SALPO)

1. Section 4.3.A.2 Names and addres es of the Landowner, Developer and Corporate
Officers shall be provided.

2. Section 4.3.AA.e - Names of all adjoining landowners shall be shown on me Plan.

Envisioning and Engineering sustainable, cost-effective, and environmentally responsible projects since 1971
Mr. Thomas R. Petrucci, 2 November 1,2017
Plainfield Township

3. Sectton 4.3.A.5 Verification is required from the Zoning Officer thar the Pilln
compUes with rhe use and zoning district performance standards, as included in the
Zoning Ordinance.

4. Section 4.3.A.6.b - A proposed Wastewater Management Area is showo 011 the

Sketch Plan. Whar is rhe ptupose of this area?

5. Seetio" 4.3.B.1.d - Locatioo and extent of soil types shall be provided on the Plan.

6. Section4.3.B.2.d - In the DescriptiOI1 of Project Intent, the AppUcant indicates rhat

sanita.ry wastewarer will be discharged to the Pen Argyl Municipal Authority's
system. No existing sanitary sewer facilities are apparent on the Sketch Plan.

7. Secrion 10A.F.3. - The minimum grade across the paving in a cul-de-sac shall be
1.5%. The maximum grade across the paving il1 a cul-de-sac shall be 6.0%.

8. Section 1OA.G.2.a - Unless approved by the Planning Commission upon

reconunel1dation from the TO\l.rnship Engineer, centerline street grades on local
streers shall not exceed 10%.

9. Section 10A.H.2.a - The cenrerline curve of rhe proposed cul-de-sac does not
include the design radius. Tbe minimlUl1 centerline radius for a local streer/road is
150 feet.

10. SectioI110.4.H.3 -A minimum rangent section ofl00 feer shall be between curves
on major collector and arterial streets, and berween a cmve and a streer inrersection
where one of rhe intersecting streets is a major collector or an arterial street. The
Applicant nares in d,e Descriprion of Project Intel1t dlat the existing haul road has
previously bee" classified as a "privare collector" road.

11. Section 10.4.L - Adequate sight dista"ce shall be provided at the cul-de-sac
intersection widl the existing haul road in accordal1ce with the Township Zoning
Ordinance Section 404.C.l. and the requirements of the Plainfield Township
Driveway rdinance (Ordinance 229).

12. Section 10A.M.1 - Cul-de-sac streets must be provided with a tlUn-around bulb with
a minimum radius of 48 feet to d,e oUlside edge of paving or curb (Ordinance
#313).

13. Section IOA.O.2.B - Street structures shall be crowned in conforma"ce with the
Township Street al1d Improvement Specifications.

14. Section 10.8.D-A - The Township shall determine whether the payment of
recreational fees is required.

15. Section 10.9.0 - The proposal regarding Stormwater management appears to urifue
existing feamres onsite with regrading of the site designed to control drainage
'tvIr. Thoma R. Petrucci, 3 November 1, 2017
Plainfield Township

patterns. The stormwater managemel1t aspects of the site will l1eed to be reviewed
and processed in full compliance with the Township's Act 167 tormwatet
Management Ordinance No. 289, as part of any land developmem Plan application
for the proposed facility. We note that the proposed grading of the existing basi.n to
the south of ti,e proposed facility and parking area indicates the basin volume is
being reduced.

16. Section 10 13.0 -TIle Applicant shall provide adequate desiS" information to show
compliance with the driveway desiS" standards.

17. Section 10.23 - Riparian and Wedand Buffers. The Applicant has stated that
provisions of d,e section are not applicable, as there are no wedands or applicable
waterbodies located On the proposed Slate Belt Heat Recovery Cenrer lot.

18. The Sketch Plan indicates that a portiou of the paved/parking area On the Green
Knight lot (on the northeast side of the existing building) will requite reguding. The
impact of the grading on existing parking should be defined.

19. The Applicanr shall be requited to comply with all applicable requitements of the
Township Zoning, Subdivision al1d Lal1d Development al1d Stormwater
Management Ordinances, as well as any applicable perfom'ance-based ordinances, as
part of any future land development plan application for d,e proposed site al1d
facilities.

20. TI,e proposed lots are located along a private, il1temal developmenr road, which
according to d,e Applicant, has been classified by d,e Township as a Mil10r
Collecror. Documetltation should be provided to confirm dus classification.

B. ZONING

1. The proposed sire is located in d,e Solid Waste Processing and Disposal District
(SW).

2. TI,e proposed use is a Material Separation Facility, as defined in Section 201 B:

Material Separation FaciliJy. An area ofland and/or facility where solid,

liqnid or gaseous materials are extracted from solid waste by meal1S of a
mechanical, thermal or chemical process for reuse at anod'er site, provided
no hazardou waste is produced.

Hazardous Waste is defined as follows:

Hazardous Waste. Those wastes where significant potential exists for existing
adverse public heald, or elwiroumenta] impacts. For the purpose of tlus
ordinance, hazardous wastes include those defined as "hazardous wastes" in
the Pennsylvania Department of Environmental Protection Rules and
Regubtions, Section 275.260 - 276.261.
M..I:. Thomas R. Petrucci, 4 ovembeJ; 1, 2017
Plainfield Township

The Township Zoning Officer sbould confirm that the proposed use meets the
definition of Material Separation Facility.

3. Section 318 B - Material eparation Facilities are permined by right and only in the
Solid Waste Proces ing and Di posal District (SW). The Material Separation Facility
has additional requirements for the Permined by Right Use as set forth in Section
315 B.35 of the Zoning Ordinance. In addition, a Sire Plan Review is required, in
accordance with Section 409 of d,e Ordinance.

4. Section 315.B.35.a - The facility is proposed to treat up to 400 tons of solid waste
per day, which would require a mininlum lot size of seven (J) acres. A lot size of 7.01
acres is proposed. In the Description of Project Intent, the Applicant agrees to
provide annual waste tonnage reports to the Township during the operational life of
the facility. uch rcpotts should sbow daily tonnage data to confirm compliance wim
this section.

5. Sectiog 315.B,35.b - The widm and locations of proposed entrances and exits
appear to comply witb d,e requirements of this section.

6. Sectiou 315.B.35.c - AJl access roads are proposed to be paved, in accordallce witb
d,e requirements of dus section.

7. Section 315.B.35.d -In the Description of Project Intent, the Applicant indicates
that, upon building permit submission, mc Applicant will provide a wrinen report
demonstrating facility compliance widl all applicable building and fire codes.

8. Section 315.B.35.e In the Description of Project Intent, d,e Applicant indicates

mat d,e facility will be operated and maintained in accordance with the requirements
of this section.

9. Section 315.B.35.f -In the Description of Project Intent, the Applicant indicates
mat d,e operation of the facility will comply with all applicable state and federal
regulations, and at the time of building permit ubmission, the Applicant shall
provide evidence of all required state and federal permits for operation.

10. Section 315.B.35.g - In the Description ofProjecr Intent, d,e Applicant indicates
iliat d,e requirements of Article 5 of the Ordinance will be complied with.

11. Section 318 H - The ketch Plan proposes the subdivision of bom me existing
Green Knight and Grand Central anitaI)' Landfill lots. The existing 4.35-acre Green
Knight lot would be split in two (2), to creatc the lot proposed for the Synagro
facility. Land would also be subdivided from the existing Grand Central Sanitary
Landfill lot: (1) to reconfigure and expand the Green Knight Lot to 4.94 acres, and;
(2) to create a lot for the Synagro facility (the Slate Belt l-leat RecoveI)' Center Lot)
\vidl a lot area on.Ol acres in size. Both proposed/reconfigured lots would exceed
me rrUlumum lot area and nunllmill lot widm requirements of dle SW District.
Mr. 11lOmas R. Petrucci, 5 November 1, 2017
Plainfield Township

12. Section 318 I. - 11,e Facility Sketch Plan shows front, side and rear yard setbacks for
the two (2) proposed lots that comply with the minimum setback requirements of
the SW District. However, the Township should review and confirm that the
orientation of thc nont and side yards for the two (2) proposed lots meet the intent
of the Zoning Ordinance.

13. Section 318 [ - The Sketch Plan indicates that the proposed building and impervious
coverages for both thc Slate Belt Heat Recovery Center lot and the reconfigured
Green Knight lot will comply with the requirements of the SW District.

14. Section 402 A (Principal Buildings) - According to the Ordinance, evety

prmcipal building shall be huilt upon a lot with frontage upon a public or private
street improved to meet Township standards or for which such improvements
have been insurcd by the posting of a performance guarantee pursuaur to the
Subdivision and Land Deve.lopmeI1t Ordinance, excepting however, those principal
buildings specifically approved by the Board of Supervisors. 11,e access road along
which the existing Green Knight and proposed Slate Belt Heat Recovery Center lots
are located is on land owned by Plainfield Township (we are in receipt of a copy of
the Easement Agreement dated March 12, 1997). The legal ability of the proposed
Synagro lot to connect to the access road needs to be determined. TIlls will also
impact the configuration of front versus side/rear lot lines and yard setbacks.

15. Section 404 C. 2 The proposed driveways shall comply with the
requirements of this section.

16. Section 409 A Site Plan shall be prepared and approved prior to the issuance of a
zoning permit for the proposed use.

17. Section 410.E -111e traffic impact of the proposed facility development does not
appear to exceed the defined thresholds requiring a full traffic in1pact smdy, based
on floor arca and expected tlip generation. Based on further review of the truck
mrning facilities, we offer the following additional comments for consideration:

a. The Applicant shall clarify if the proposed accesses are one-way or bi-
directionaI, as it appears the "off-loading" tluck tra ffic (main daily trip
generator) can only access the facility via the westernmost access and exit via
the easternmost access, while the "loading" truck tl..ffic is proposed to
access the facility via the easternmost access and exit via d,e westernmost
access. 1n order to avoid passenger vehicle and truck conflicts, we
recommend a one-way tra ffic flow ilirough the site.

b. The Applicant shall clarify truck movement restrictions at the easternmost

driveway. We reconunend the tluck left-mrns out of the site at this access be
prohibited.
Mr. Thomas R. PeU1.1Cci, 6 November 1, 2017
Plain.f.ield Township

c. We recommend that d,e Applicant consider changing d'e vehicular parking

to angled parlcil1g in order to discourage exiting passenger vehicles from
conflictit1g with entering truck traffic.

d. Proper sig.nage sball be provided for traffic pattern clarity and acceSS use
restrictions, as necessary.

e. TI,e Applical1t shall indicate how trucks will be staged if multiple vehicles
arrive for 10adiJlg and/or offloading at the same or similar times.

f. The Plan is unclear wiili regard to how and where ilie processing condensate
and facility wash water will be loaded 011 to trucks for transport to me SOutce
treatment facilities supplying me sludge.

g. The Applicant shall clarify whether Or nOt trucks will require acceSS to d,e
proposed wastewater management area shown on the Plan.

18. Section 501 (EnvirolUl1ental Preservation Required) - In me Description of Project

lntent, ilie Applicant indicates d,at, at d,e time of building permit submission, d,e
Applicant will supply evidence from d,e relevant state and federal agencies that it has
me relevant cleaJ'ances for endangered species, if any.

19. Section 502 (Nuisances Prohibited) - In me Desc11ption of Project Intent, ilie

Applicant indicates iliat ilie facility is completely enclosed, and at me time of
building permit submission, d,e Applicant will supply evidence of all required state
and federal permits for opera tion.

20. Section 503 (Steep Slope~) - TI,e Applicant has provided a detailed Steep Slope
Narrative d,at addresses the requiremenrs of the OrdiJ"nce. The results of the
analysis indicate that the slope areas widlin the project area are Class C Steep Slopes
(man-made slopes dlat natnrally contained less d,an a 15% grade).

21. Section 504 GAreas with High Water Tabl<;) The Applicant has indicated d,at the
Slate Belt Heat Recovety Center lor is not located within a high water table area.

22. Section 505 (Development Along Waterbodie~) - The Applicant has indicated that
me la te Belt Hea t Recovery Center lot docs not contait, any areas within 50 feet of
any stream, lake or pond.

23. Section 506 Wuyial Soils Areas) - The Applicant has indicated dm d,e property is
designated as PQ-Quarries, and not aJ) alluvial soil.

24. Section 507 (flood Plain Regulations) - The Sketch Plan shows mat the proposed
site is not located \vithin a flood prone area.
Mr. Thomas R. Pet:1ucci, 7 ovembe.t 1, 2017
Plainfield Township

25. Section 508 a'illing Excayation and Grading) - The Applicant bas indicated that a
zoning permit will be obtained before any activities that require eardl moving are
commenced.

26. Sections 509 through 516 -In the Description of Project Intent, the Applicant
indicates that the requirements of Sections 509 dltougb 516 will be complied wid,.

C. SEWAGE ENFORCEMENT OF ICER

1. A leview by a Sewage Enforcement Officer (SEO) is not tequired at this time since
the Applicant has indicated that domestic sanitary wastewatel will be discharge to
public sewe!' and uldnstrial wastewater will be backhauled to the wastewater
treat:lnent plants that send biosolids for processing. In additiol1, at this point in time,
it appears d,at a planning module for this project would be eligible for a plal1o.ing
excmption since the domestic wastewater will likely be less ilian 25 equivalent
dwelling units (EDUs).

D. ENVIRONI"ffiNTAL CONCERNS

Our comments arc based On ilie information submitted by d,e Applicant as part of the new
Application.

1. TI,e Applicant should provide information regarditlg d,e biosolids drying equipment
that will be employed at d,e plant. The information sbould include information n
sinJ..i.lar installations in the United States and elsewhe.te.

2. The Applicant should provide information on fire suppression systems associated

,vith proposed equipment, material storage areas and ilie overall site. Information
should include standard ope.tatillg and mai.ntenance procedures.

3. Information should be provided on dust suppression systems and oddress fugitive

dust emi sions and dust explosion suppression systems. Information sbould mdude
srondard operatit'g and maU1tenance pIOcedures.

4. The Applicant should address environmental concel'llS associated \vith tronspOltation

of sludge cake and associated liquids. In addition, ulformation addressmg
envir011tl1ental concems associated wid, the proposed backhaulitlg of industrial
wastewater to wastewoter trconnent plants should bc provided. TIle information
should address leakage concerns, odor potential etc. Informotion should mclude
standard operatitlg and maintenance procedures.

5. Information should be provided on me proposed odor control system, u'cluditlg me

potential for offsite odors. Information should illclude standard operatitlg and
maintenance pIOcedures.

6. The Applicant should provide itlfOlmation regarditlg thc sources and quality of
biosolids d,at would be processed by ilie proposed facility, mclUditlg stondard
Mr. Thomas R. Penucci, 8 November 1, 2017
Plainfield Township

operating procedures. The standard operating procedures should address proposed

testing protocols.

7. Information should be submitted regarding vector control and should include

standard operating procedures.

8. The Applicant should provide process control information.

9. The Applicant should address concems regarding the potential of biological

regrowth in the final pelletized product.

10. The Applicant should dalify and address the potential of sludge cake containing
phaullaceuticals and address any associated concerns.

11. The Applicant should provide written standard operating procedures to address
potential problems snch as power failure and oth.er unanticipated events and their
impact on odor, dust and fire suppression systems.

12. The Applicant should provide inC nuation on proposed chemical use storage
systems, including standard opeJ:atio'1 al1d maintenance procedures.

13. The Applicant should provide a detailed geotechnical report for the proposed
site/ facility. The report shall include an analysis of the interaction between the
surface runoff discharged to Sediment Basin 2, and the ediment Basin 2 itHeraction
with the prevalent groundwater aquifers.

14. The Applicant should provide information regard.ing the Proposed Wastewater
Management Area. Will the proposed facilities include storage and treatment?
Information should include standard operation and maintenance procedures.

E. GENERAL

1. The Township should consider the comments of the Township Zoning Officer.

2. The Township should consider the comments of the Township Solicitor.

3. The Township reselves the right to make additional comments based on the review
of revised submission material.
Mr. Thomas R. Petrucci, 9 November 1, 20'17
Plainfield Township

If you have OIly questions, please contact the undersigned.

Respectfully,

HANOVERENGmEEillNG

fi,r
Robert J. Lynn, PE, CSI

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cc: David Allen, P.E., Eardilles Group, Inc. (via email)

Jim Hecht, Synagro (via email)
Matiliew Goodrich, Zito Martino & Karasek, LLP (via email)
Glenn Kempa, Wa te Management (via email)
Scott Pe.rin, Waste Management (via email)