pennsylvania

DEPARTMENT OF ENVIRONMENTAL
PROTECTION

March 22, 2019

Grand Central Sanitary Landfill, Inc.

c/o Mr. Joe Statile, District Manager
910 West Pennsylvania Avenue
Pen Argyl, PA 18072

RE: Technical Deficiencies

Minor Permit Modification Application
Slate Belt Heat Recovery Center
Grand Central Sanitary Landfill, Inc.
Permit Number 100265
Plainfield Township, Northampton County, PA

Dear Mr. Statile:

The Pennsylvania Department of Environmental Protection (DEP) has reviewed the

above referenced application and has identified the following technical deficiencies. The
deficiencies are based on applicable laws, regulations, and policies and this guidance sets
forth DEP's preferred means of satisfying the applicable regulatory requirements.

Technical Deficiencies
Northampton County Conservation District - Form I review comments

I. §102.4(b)(5)(i) The existing topographic features of the project site and the
immediate surrounding area.
a. All existing improvements should be shown and identified on the plan
drawings. The location of Sediment Basin and Trap associated features,
i.e. outlet structure/principal spillway, outlet channel, emergency spillway,
etc. should be provided (pages 357 & 398 of the E&SPC Manual).
§102.11 (a)(l)

2. §I02.4(b)(5)(ii) The types, depth, slope, locations and limitations ofthe soils.
a. Please provide a soils drawing that meets the standards of page 397 of the
E&SPC Manual. §102.ll(a)(l)
b. Please indicate the use limitations of the soils pertinent to the proposed
project as described in Item 2 on page 2 of the E&SPC Manual.
§102.ll(a)(I)
c. Describe how the identified soil use limitations have been resolved by the
site design and/or E&S Plan (page 2 of the E&SPC Manual).
§102.11(a)(I)

Northeast Regional Office

2 Public Square I Wilkes-Barre, PA 18701-1915 I 570.826.2511 I Fax 570.826.5448 I www.dep.pa.gov
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3. §102.4(b)(5)(iii) The characteristics of the earth disturbance activity, including

the past, present, and proposed land uses and the proposed alteration to the
project site.
a. Please provide proposed final contours for all proposed earthmoving
(including conversion or removal of all basins, traps, channels and PCSM
BMPs) that meet the standards in Item 3 on page 2 and on page 398 in the
E&SPC Manual. §102.11(a)(l)

4. §102.4(b)(5)(iv) The volume and rate of runoff from the project site and its
upstream watershed area.
a. It does not appear that the drainage area tributary to Sediment Trap 2 is the
maximum tributary to the facility as described on page 123 of the E&SPC
Manual. Per Figure 1 and E-288, it appears drainage areas, 4, 5, 6, 7 and
17A are all tributary to the sediment trap; making a tributary area of over
24 acres. The maximum permissible drainage for adequate sediment trap
design is 5 acres. This proposed sediment control facility should be
designed as a sediment basin per Chapter 7 of the E&SPC Manual. Please
revise plan accordingly. §102.1l(a)(1)
b. Maximum during construction drainage areas to the proposed inlet
protection should be provided on the E&S plan drawing to SUppOlt BMP
design, (e.g. a inlet drainage area table, etc.) (re: page 123 of the E&SPC
Manual.) §102.11(a)(l)

5. §102.4(b)(5)(vii) A sequence of BMP installation and removal in relation to the

scheduling of earth disturbance activities, prior to, during, and after earth
disturbance activities that ensure the proper functioning ofall BMPs.
a. Provide a site-specific sequence of all BMPs and proposed features
installation and removal in accordance with Chapter 2 of the E&SPC
Manual. The last paragraph on page 1 of Form I Narrative indicates the
sequence is provided below, however the only proposed features
referenced in the later sections of the narrative are Sediment Basin No 2
and SBHRC Swale. Please provide a complete construction sequence on
the plan drawing which consistently addresses all proposed BMPs and
features of the site. (i.e. rock construction entrance and wash rack,
concrete washout, staging area, stockpile area, compost filter socks, rock
filter, inlet protection, channels S 1, S 2.1, 2.2, 2.3 and 2.4, culvert
relocation, building construction, parking lot grading and stabilization,
utility installation, retaining wall, conversion of temporary controls for
stormwater management, etc.) §102.1l(a)(1)

6. §102.4(b)(5)(viii) Supporting calculations and measurements.

a. A spot check of sediment basins found one or more where the required
discharge capacity is not provided. (see Item 12 on page 160 of the
E&SPC Manual) §102.1l(a)(1) Revise as necessary.
i. At minimum the principal spillway should be designed to convey
the calculated peak flow from the 10 year storm. Per Section E,
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Sediment Basin 2 proposes no discharge and principal spillway

information is not provided. (see Item 12 on page 160 of the
E&SPC Manual. §102.11(a)(l) Revise as necessary.
b. A spot check of sediment basins found one or more where the 4 to 7 day
dewatering time specified in Item 9 on page 160 of the E&SPC Manual is
not provided. §I02.11 (a)(I) Please make the necessary changes.
L Per Section E, no dewatering device is proposed for Sediment
Basin No.2; please revise and provide proper dewatering.
c. Section E does not provide the length or width of the bottom of Sediment
Basin 2 nor does the Supporting calculations; narrative indicates the
bottom is unknown, however existing contours on Figure 1 indicated
bottom elevation of 61 0'. Please provide complete supporting information
in the resubmission. NOTE: the bottom elevation of a sediment basin
should not be located below the seasonal high water table, adjacent
wetlands, or perennial streams. Please provide the requested information
to support the design criteria is met. (re: items I and 5 on page 160 of the
E&SPC Manual. §102.11(a)(1) Revise as necessary.
d. Section E references Sediment Trap No.2 when presenting the maximum
sediment storage volume of the principal spillway for Sediment Basin No.
2. The SuppOliing calculations also indicated that Sediment trap 2 is
designed for pre-treatment of mnoff. Sediment trapslbasins may not be
located within the drainage area of another sediment trap/basin per item 1
on page 160 of the E&SPC Manual. §102.11(a)(l) Please clarify and
revise as necessary. It appears Sediment Trap No.2 should be designed as
a sediment basin with a proper outlet stmcture and dewatering device due
to large drainage area, etc.
e. The minimum surface area for a sediment basin should be calculated
according to Item 7 (top of page 160 of the E&SPC Manual) unless an
acceptable alternative (e.g. soil stabilizer, silt curtain, forebay, etc.) is
employed. §102.11(a)(I) Revise as necessary for all proposed sediment
basins.
f. A spot check of sediment basins found one or more where the required 4: 1
flow length to width ratio is not supported. See page 199 of the E&SPC
Manual for guidance regarding calculation of required flow length.
§102. l1(a)(I)
L Length and Width at crest of principal spillway are not provided in
Section E for Sediment Basin No.2.
ll. Since an outlet structure is not proposed, required flow length
could not be evaluated.
g. Complete supporting calculations should be provided for all proposed
Channels (Le. S 1, S 2.1, S 2.2, S 2.3, S 2.4, etc.); peak flow, capacity and
protective lining calculations should all be provided in the narrative. (pg.
127 of the E&SPC Manual) §102.11(a)(1)
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7. §102.4(b)(5)(ix) Plan drawings.

a. All referenced plan drawings should be provided with the submission, i.e.
EarthRes Drawing Nos. C-06 and C-12 as referenced on page I ofFOllli I
Narrative, DWG E-277 as referenced on E-288, etc.
b. Per Drawing C-17, the proposed SBHRC Swale appears to be discharging
to a proposed disturbed area, the tributary area of this swale also appears
to be within the proposed disturbed area, thus this swale should be
designed as a conveyance channel to convey its sediment laden discharge
to an adequate sediment control facility. Please revise accordingly and
provide adequate E&S control for disturbance related to land development
activity, swale constl'Uction and discharge. (re: E&SPC Manual page 127)
§102.1I(a)(1).
c. Complete construction details should be provided for the proposed
vegetated channels (Le. SBHRC swale, S 2.1, S 2.4, etc.); Standard
Construction Detail #6-1 is recommended for this purpose. Proposed
staple pattern for charmel linings should also be provided. (Item 9, page 5
of the E&SPC Manual) §102.II(a)(I).
d. Proposed emergency spillway channel S I should be depicted on Figure I
and C-17. It appears construction vehicles will require a crossing over S I
to access the construction site, a compost filter sock may be proposed
across the charmel, utilities may be proposed through the channel and later
a section of the channel appears to be paved. Adequate E&S control and
conveyance should be provided. Construction detail and supporting
calculations should be revised to indicate proposed stabilization method
for channel S I, as the current detail shows reinforced vegetative
stabilization with TRM. (Items 8 and 9, page 5 of the E&SPC Manual)
§102.11(a)(1).
e. A complete construction detail should be provided for the proposed rock
filters; Standard Construction Detail #4-14 is recommended for this
purpose. (Item 9, page 5 of the E&SPC Manual) §102.1I(a)(1).
f. A complete constmction detail should be provided for the proposed inlet
protection; Standard Construction Details #4-1 and supporting tables are
recommended for this purpose. (Item 9, page 5 of the E&SPC Manual)
§102.1I(a)(1).
g. E&S BMPs should be provided for the construction of charmel S I and
SBHRC swale, Le. rock filter, erosion control matting, etc. (page I of the
E&SPC Manual). §102.1I(a)(I)
h. Suitable outlet protection should be designed for the proposed discharge
from charmel S 2.1 into the Sediment Trap No.2, SBHRC swale and
culverts fi'om inlets Nos. 3 and 4 to channel S 2.4. (top of page 229 in the
E&SPC Manual). Please provide the associated plan view location,
constmction detail and supporting design calculations. §102.1I(a)(1)
L A review of incomplete calculations provided found anticipated
velocity for culvert from inlet No. 3 discharge exceeding the
maximum allowable for R-5 from Table 6.6 in the E&SPC
Manual. § I02.11 (a)(1) Make all necessary corrections.
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I. Rock construction entrance wash racks should discharge to an adequate

sediment control facility, a 24" compost filter sock trap area is the
acceptable minimum. (re: page 35 of the E&SPC Manual) §I02.ll(a)(l).
Please revise plan to provide adequate ABACT E&S control.

8. §I02.4(b)(5)(x) A maintenance program which provides for the operation and

maintenance ofBMPs and the inspection of BMPs on a weekly basis and after
each stormwater event, including the repair or replacement of the BMPs to
ensure effective and efficient operation.
a. Provide maintenance instmctions for all proposed temporary and
permanent BMPs (including disposal of materials removed from the
BMPs or the project area) on the plan drawings (page 5 of the E&SPC
Manual). §102.11(a)(l)

9. §I02.4(b)(5)(xi) Procedures which ensure that the proper measures for the
recycling or disposal ofmaterials associated with or from the project site will be
undertaken in accordance with this title.
a. Identify the constmction wastes that are to be recycled or disposed in the
E&S Narrative (page 6 of the E&SPC Manual). §I02.11(a)(l)
b. Provide instructions for proper recycling and/or disposal of the
construction wastes associated with the E&S BMPs on the plan drawing(s)
(page 6 of the E&SPC Manual). §102.l1(a)(l)

10. §I02.4(b)(5)(xii) Identification of the naturally occurring geologic formations

or soil conditions that may have the potential to cause pollution during earth
disturbance activities and include BMPs to avoid 01' minimize potential
pollution and its impactfrom the formations.
a. The E&S plan should identify naturally occurring geologic formations or
soil conditions that may have the potential to cause pollution during ealih
disturbance activities and include BMPs to avoid or minimize potential
pollution and its impact from the formations., (re: Item 12 on page 6 of the
E&SPC Manual).

11. §I02.4(b)(5)(xiii) Identification of potential thermal impacts to surface waters

of this Commonwealth from the earth disturbance activity including BMPs to
avoid, minimize and mitigate potential pollution from thermal impacts.
a. Describe how potential thermal impacts upon receiving waters have been
avoided and/or minimized by the plan design (page 6 of the E&SPC
Manual). §I02.ll(a)(I)

12. §I02.8(c) Consistency with E&S Plan. The PCSM Plan shall be planned,
designed and implemented to be consistent with the E&S Plan under § I02.4(b)
(relating to erosion and sediment control requirements).
a. The PCSM plan should be planned, designed and implemented to be
consistent with the E&S Plan. If any design changes made as a result of
the above-referenced E&S deficiencies should impact the PCSM Plan,
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please make the necessary revisions and list them clearly in the response
letter.

13. §102.8(d) Separate plan. Unless otherwise approved by the Department, the
PCSM Plan must be separate from the E&S Plan and labeled "PCSM" or
"Post COllstructioll Stormwater Management Plan" and be the jillal plan for
construction.
a. A PCSM Plan was not found with the submitted materials. It appears that
final grades plans, drainage area plans and a stormwater management
nalTative were included, therefore only a partial review could be
completed. A PCSM Plan is a site-specific plan consisting of both
drawings and a nalTative that identifies Best Management Practices
(BMPs) to manage changes in stonnwater runoff volume, rate and water
quality. Plan drawings should identifY, at a minimum, permanent site
features, alterations, PCSM BMPs, etc. Please revise as necessary.

14. §102.8(e) PCSM Plan preparer requirements. The PCSM Plan shall be
prepared by a person trained and experienced in PCSM desigll methods and
techlliques applicable to the size and scope ofthe project being designed.
a. Please provide infolTllation to show that the PCSM Plan was prepared by a
person trained and experienced in PCSM design methods and techniques
applicable to the size and scope of the project being designed. Standard
E&S Worksheet # 22 (page 393 of the E&SPC Manual) may be modified
for this purpose and added to the PCSM narrative.
b. The plan drawings (i. e. "Stormwater Management Plan Proposed Drainage
Areas", etc.) and stOimwater nalTative (ref: Attachment I-I) found in the
application do not appear to identify the location of all surface waters
which may receive mnoff from the project. A review of the nearby area
revealed an Uunamed Tributary to the Little Bushkill Creek (west of
project site) and the Waltz Creek (east of the project site) in close
proximity to the site. Please review the application materials and
clarifyIrevise as necessary.

15. §102.8(f)(8) Supportillg calculations.

a. It appears that the application does not address the volume increases and
water quality impacts that may be encountered as a result of the proposed
Slate Belt Heat Recovery Center (SBHRC) construction. A volume control
requirement is essential to mitigate the consequences of increased
stOlTllwater runoff. To accomplish this, the volume reduction BMPs must
be designed and implemented to protect stream charmel morphology;
maintain groundwater recharge; prevent downstream increases in flooding
and replicate the natural hydrology onsite before development to the
greatest extent possible.

The volume control and water quality requirements included in the

proposed mlemaking and retained in the final-folTll 1Uiemaking are
 7

necessary to maintain and protect natural hydrology including velocity,

current, cross-section, runoff volume, infiltration volume and aquifer
recharge volume. These requirements will sustain damaging bank full
flows. The requirements will also help prevent increases in peak runoff
rates for larger events (2-year-IOO year) on both a site-by-site and
watershed basis. A volume control requirement is protective of water
quality and also provides the benefits listed. Please provide the required
post construction stormwater management BMPs to mitigate the 2-year
volume increase of stormwater due to construction activities. §102.8(g)(2)
b. Based on the narrative provided, it appears that Basin 2 has been designed
as a detention basin with no primary outlet (ref: Attachment I-I, page 3).
Retention and detention facilities should be designed to completely drain
water quality volumes including both the permanently removed volume
and the extended detention volume over a period of no less than 24 hours
but no more than 72 hours (ref: PADEP PCSM BMP Manual Chapter 3
Page 7). Please review and revise as necessary (Le. calculations, details,
plan infOlmation, etc.). ref: PADEP PCSM BMP Manual Chapter 6 Page
177, §102.8(f)(6), §102.8(f)(9)
c. It appears that the stormwater peak rate design provided (ref: Attachment
I-I, page 3) has only analyzed drainage areas tributary to Basin 2. The
disturbed areas bypassing Basin 2 should also be analyzed in order to
analyze the peak rate runoff from the entire project site. Please review and
revise as necessary. §102.8(g)(3)
d. Clarification is requested regarding to the "I DO-year Storm Flow" utilized
for the Basin 2 emergency spillway design. The 268.67 cubic feet per
second (cfs) identified does not appear consistent with the hydrographs
provided. Please note, the emergency spillway should be designed for the
maximum flow tributary to the basin.
e. Sizing calculations (Le. anticipated flow depth, etc.) for the emergency
spillway could not be located in the nan·ative provided. Please review and
revise as necessary.
f. The permanent stabilization calculations for the emergency spillway and
Basin No.2 swale could not be located in the materials provided (Le. grass
and North American Green P330, respectively). Please review and
revise/clarify as necessary.
g. A review of the Basin No.2 resizing calculations revealed that only 0.22
feet of fi·eeboard has been provided fi·om the 100-year storm event
elevation to the invert of the emergency spillway. A minimum freeboard
of I (one) foot should be provided above the I DO-year storm event
elevation. Please review and revise as necessary. ref: PADEP PCSM BMP
Manual Chapter 6 Page 176
h. Clarification is requested regarding the source of the curve number
(CN=72) utilized for the peak rate design (ref: Appendix B, page 6).
Calculations/references should be provided as necessary. §I02.8(g)(3)
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i. A review of the hydrograph calculations revealed that sediment trap 2 was

included in the routing. The following comments regarding the
calculations should be addressed:
I. While the provided hydrographs appear to address stormwater
discharge from the site during construction, the post construction
stormwater management of the site has not been addressed (i.e.
after landfill closure, sediment trap conversion/removal, etc.).
Please review and clarify/revise as necessary. §102.8(g)(3)
n. The spillways and basin bottom elevation identified in the pond
report do not appear consistent with the existing plan elevations.
Please review and clarify/revise as necessary. §102.8(g)(3)

16. §102.8(f)(9) Plan drawings.

a. Temporary E&S BMPs should not be shown on the final grades/PCSM
plan drawings. Please revise the final grades/PCSM plan as necessary to
identify permanent site features only. §102.8(f)(6)
b. The grading of the proposed basin 2 (i.e. bottom elevation 650, etc.) does
not appear consistent with the "Basin 2 Reduced" pond report provided
(ref: Appendix B of Attachment I-I). Please review and clarify/revise as
necessary for consistency. (ref: "Stormwater Management Plan Proposed
Drainage Areas") §102.8(f)(3), §102.8(f)(6)
c. A spot check of the "Stormwater Management Plan Proposed Drainage
Areas" plan compared to the E&S plans revealed inconsistencies/missing
plan items (i.e. site grading, stormwater conveyance facilities, etc.). Please
review and clarify/revise as necessary for consistency. §102.8(f)(3),
§102.8(f)(6)
d. The plan location and tributary drainage area of "Basin No. 2 Swale"
could not be identified on the plans provided. Please review and
clarify/revise as necessary. §102.8(f)(6)
e. A discharge culvert identified in the stormwater narrative (ref: Appendix
B, page 3) could not be located on the plan drawings provided. Please
review and revise/clarify as necessary. §102.8(f)(3), §102.8(f)(6)
f. Supporting plan/narrative infOlmation for the proposed PCSM BMPs
could not be located in the application materials provided. Supporting
information may include, but is not limited to, construction sequence,
construction details, long term operation and maintenance notes, etc.
Please include this information to support the BMPs proposed.
§102.8(f)(6), §102.8(f)(7), §102.8(f)(l0)

17. §102.8(k) Licensed professional oversight of critical stages. A licensed

professional or a designee shall be present onsite and be responsible during
critical stages of implementation of the approved PCSM Plan. The critical
stages may include the installation of underground treatment or storage BMPs,
structurally engineered BMPs, or other BMPs as deemed appropriate by the
Department or the conservation district.
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PaDEP comments - hydrogeology

Municipal and public comment indicate a concern that modification of Sedimentation

Basin #2 could impact ground water and possibly the two sub-watersheds in this area.
The Department is not aware of any data that would show/allow evaluation of a
connection between the sedimentation basin and the groundwater. Please respond to this
concern.

You must submit a response fully addressing each of the technical deficiencies set forth
above within 60 business days or DEP may deny the application.

If you believe that any of the stated deficiencies is not significant, instead of submitting a
response to that deficiency, you have the option of asking DEP to make a decision based
on the information with regard to the subject matter ofthat deficiency that you have
already made available. If you choose this option with regard to any deficiency, you
should explain and justify how your current submission satisfies that deficiency. Please
keep in mind that if you fail to respond, your application may be denied.

Should you have any questions regarding the identified deficiencies, please contact me at
(570) 830-3111 to discuss your concerns or to schedule a meeting. You may also follow
your application through the review process via eFACTS on the Web at:
http://www.ahs2.dep.state.pa.us/eFactsWeb/default.aspx.

Sincerely,

David F. Matcho, P. E.
Environmental Engineer Manager
Waste Management Program

cc: Earthres Group, Inc.

NOlihampton County Conservation District
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bee: WM File thru D. Mateho

R. Bellas: email PDF
D. Mateho: email PDF
D. Ritter: email PDF
T. McGurk: email PDF
A. Fauleh: email PDF
E. Bloxham: email PDF
L. Hannigan: email PDF
S. Warmate: email PDF

FW:ms
WP: W2-609
H/T: 3/22/19

EARTHRES GROUP INC.

C/O THOMAS G. PULLAR, P. E., SENIOR PROJECT MANAGER
PO BOX 468
PIPERSVILLE, PA 18947

NORTHAMPTON COUNTY CONSERVATION DISTRICT

C/O SHARON PLETCHAN, DISTRICT MANAGER
14 GRACEDALE AVE.
GREYSTONE BUILDING
NAZARETH, PA 18064