The Department acknowledges that, at times, BRADS has been the source of odors. The Department cited BRADS for violations related to malodors causing nuisances in the community as a result of complaint investigations. Specifically, Notices of Violation were issued to BRADS on January 2, 2024, May 8, 2024, September 30, 2024 and October 29, 2024. In response, BRADS installed a flare as well as a system of vertical landfill gas (LFG) extraction wells and horizontal collectors in addition to its hydrogen sulfide (H2S) treatment system to address landfill gas/hydrogen sulfide odors. The H2S treatment system removes/reduces the concentration of sulfur compounds entering the flare. The flare destroys any remaining odorous constituents in the LFG. BRADS has also submitted drawings for future gas collection in Cell 3 through Cell 6 which includes plans for future gas extraction wells and gas collection pipeline. Additional horizontal collection systems will be installed as needed when construction and active use of each new cell progresses. The Department has executed a Consent Order & Agreement with BRADS to resolve past violations regarding odor, litter, intermediate cover and leachate management issues. The Agreement included a $96,525.00 penalty and corrective actions to minimize the possibility of these issues from reoccurring. Included in the corrective actions are requirements to perform daily site perimeter checks for odors, conduct quarterly surface emissions monitoring for H2S and a modified Nuisance Minimization and Control Plan (NMCP). The Department also conditioned the renewed permit with additional requirements to further minimize the possibility of these issues from recurring. DEP’s regular inspections, offsite odor patrols and complaint investigations have confirmed that these corrective actions have been effective to minimize offsite odors.

The Department acknowledges that, at times, BRADS has been the source of odors. The Department cited BRADS for violations related to malodors causing nuisances in the community as a result of complaint investigations. Specifically, Notices of Violation were issued to BRADS on January 2, 2024, May 8, 2024, September 30, 2024 and October 29, 2024. In response, BRADS installed a flare as well as a system of vertical landfill gas (LFG) extraction wells and horizontal collectors in addition to its hydrogen sulfide (H2S) treatment system to address landfill gas/hydrogen sulfide odors. The H2S treatment system removes/reduces the concentration of sulfur compounds entering the flare. The flare destroys any remaining odorous constituents in the LFG. BRADS has also submitted drawings for future gas collection in Cell 3 through Cell 6 which includes plans for future gas extraction wells and gas collection pipeline. Additional horizontal collection systems will be installed as needed when construction and active use of each new cell progresses. The Department has executed a Consent Order & Agreement with BRADS to resolve past violations regarding odor, litter, intermediate cover and leachate management issues. The Agreement included a $96,525.00 penalty and corrective actions to minimize the possibility of these issues from reoccurring. Included in the corrective actions are requirements to perform daily site perimeter checks for odors, conduct quarterly surface emissions monitoring for H2S and a modified Nuisance Minimization and Control Plan (NMCP). The Department also conditioned the renewed permit with additional requirements to further minimize the possibility of these issues from recurring. DEP’s regular inspections, offsite odor patrols and complaint investigations have confirmed that these corrective actions have been effective to minimize offsite odors.

The Department acknowledges that, at times, BRADS has been the source of odors. The Department cited BRADS for violations related to malodors causing nuisances in the community as a result of complaint investigations. Specifically, Notices of Violation were issued to BRADS on January 2, 2024, May 8, 2024, September 30, 2024 and October 29, 2024. In response, BRADS installed a flare as well as a system of vertical landfill gas (LFG) extraction wells and horizontal collectors in addition to its hydrogen sulfide (H2S) treatment system to address landfill gas/hydrogen sulfide odors. The H2S treatment system removes/reduces the concentration of sulfur compounds entering the flare. The flare destroys any remaining odorous constituents in the LFG. BRADS has also submitted drawings for future gas collection in Cell 3 through Cell 6 which includes plans for future gas extraction wells and gas collection pipeline. Additional horizontal collection systems will be installed as needed when construction and active use of each new cell progresses. The Department has executed a Consent Order & Agreement with BRADS to resolve past violations regarding odor, litter, intermediate cover and leachate management issues. The Agreement included a $96,525.00 penalty and corrective actions to minimize the possibility of these issues from reoccurring. Included in the corrective actions are requirements to perform daily site perimeter checks for odors, conduct quarterly surface emissions monitoring for H2S and a modified Nuisance Minimization and Control Plan (NMCP). The Department also conditioned the renewed permit with additional requirements to further minimize the possibility of these issues from recurring. DEP’s regular inspections, offsite odor patrols and complaint investigations have confirmed that these corrective actions have been effective to minimize offsite odors.

There have been 317 complaints since January 2024. Of those complaints, 223 complaints occurred in 2024. In 2025 there were 74 complaints received. Approximately 20 complaints were received in 2026. All complaints are responded to. The number of complaints has decreased since 2024. Past odor issues were responded to through odor complaint investigations, H2S gas monitoring using a Jerome meter, and monthly inspections of the landfill. BRADS addressed these past odor issues through the implementation of weekly inspections, daily flare inspections, daily odor patrols, and regular media changeouts of the H2S capture system. These mitigation measures are now permit requirements.

The Department acknowledges that, at times, BRADS has been the source of odors. The Department cited BRADS for violations related to malodors causing nuisances in the community as a result of complaint investigations. Specifically, Notices of Violation were issued to BRADS on January 2, 2024, May 8, 2024, September 30, 2024 and October 29, 2024. In response, BRADS installed a flare as well as a system of vertical landfill gas (LFG) extraction wells and horizontal collectors in addition to its hydrogen sulfide (H2S) treatment system to address landfill gas/hydrogen sulfide odors. The H2S treatment system removes/reduces the concentration of sulfur compounds entering the flare. The flare destroys any remaining odorous constituents in the LFG. BRADS has also submitted drawings for future gas collection in Cell 3 through Cell 6 which includes plans for future gas extraction wells and gas collection pipeline. Additional horizontal collection systems will be installed as needed when construction and active use of each new cell progresses. The Department has executed a Consent Order & Agreement with BRADS to resolve past violations regarding odor, litter, intermediate cover and leachate management issues. The Agreement included a $96,525.00 penalty and corrective actions to minimize the possibility of these issues from reoccurring. Included in the corrective actions are requirements to perform daily site perimeter checks for odors, conduct quarterly surface emissions monitoring for H2S and a modified Nuisance Minimization and Control Plan (NMCP). The Department also conditioned the renewed permit with additional requirements to further minimize the possibility of these issues from recurring. DEP’s regular inspections, offsite odor patrols and complaint investigations have confirmed that these corrective actions have been effective to minimize offsite odors.

Regulations and permits are developed to be protective of public health. Implementation of proposed operational controls, mitigation plans and the NMCP are designed to protect public health. That said, some people can have a strong reaction to unpleasant environmental odors, while others may have no reaction. At times, the H2S levels observed may have been high enough to potentially cause symptoms or conditions related to the smell of H2S, such as headache, nausea, fatigue, or stress in some people. This may occur more in those people who have strong reactions to odors. The level at which people can smell H2S in air, also referred to as an odor threshold, varies widely and ranges from 0.0005-0.3 parts per million (ppm), or 0.5-300 parts per billion (ppb). People are primarily exposed to H2S by inhalation, and since it naturally occurs in the environment, the general population will have some exposures. H2S sampling conducted by DEP staff, using a Jerome Meter, occurs frequently at the landfill to measure the concentrations of H2S being emitted from the surface of the landfill. The majority of these readings are significantly less than 1 part per million (ppm). Given the majority of readings obtained on site, taken inches from the surface of the landfill, are below 1 ppm, it is unlikely that residents over 1.5 miles from BRADS are/were exposed to harmful levels of H2S. Established exposure limits are 70 ppb for acute exposure, 20 ppb for intermediate exposure and 1.8 ppb for long term daily exposure.

BRADS has an approved Traffic Control Plan that it is required to adhere to. This plan has designated truck routes based on size and type of truck as well as the origin of the waste being hauled. All trucks hauling waste generated outside of the Borough of St. Clair must use approach route number 1. This route requires all trucks to enter the landfill from the East via Burma Road. Approach route number 2, which allows for trucks to utilize roads and streets within the Borough of St. Clair can only be used by trucks hauling waste generated within the borough and these trucks must be under 10 ton. Any complaints or observations that trucks are not following the routes and/or the landfill is not using procedures for trucks to adhere to landfill travel routes are investigated for any potential violations. As part of this renewal application, BRADS updated its Traffic Compliance Plan to specifically restrict any vehicles over 10-ton from utilizing approach route #2. Only trucks carrying waste generated within the Borough of St. Clair can utilize approach route #2. BRADS will conduct random observations of incoming vehicles approach routes to ensure compliance. BRADS also sent the Borough of St. Clair’s Chief of Police a letter informing them of this change and encouraging them to contact the landfill if they suspect any vehicles of violating BRADS Traffic Compliance Plan.

BRADS has an approved Traffic Control Plan that it is required to adhere to. This plan has designated truck routes based on size and type of truck as well as the origin of the waste being hauled. All trucks hauling waste generated outside of the Borough of St. Clair must use approach route number 1. This route requires all trucks to enter the landfill from the East via Burma Road. Approach route number 2, which allows for trucks to utilize roads and streets within the Borough of St. Clair can only be used by trucks hauling waste generated within the borough and these trucks must be under 10 ton. Any complaints or observations that trucks are not following the routes and/or the landfill is not using procedures for trucks to adhere to landfill travel routes are investigated for any potential violations. As part of this renewal application, BRADS updated its Traffic Compliance Plan to specifically restrict any vehicles over 10-ton from utilizing approach route #2. Only trucks carrying waste generated within the Borough of St. Clair can utilize approach route #2. BRADS will conduct random observations of incoming vehicles approach routes to ensure compliance. BRADS also sent the Borough of St. Clair’s Chief of Police a letter informing them of this change and encouraging them to contact the landfill if they suspect any vehicles of violating BRADS Traffic Compliance Plan.

BRADS has an approved Traffic Control Plan that it is required to adhere to. This plan has designated truck routes based on size and type of truck as well as the origin of the waste being hauled. All trucks hauling waste generated outside of the Borough of St. Clair must use approach route number 1. This route requires all trucks to enter the landfill from the East via Burma Road. Approach route number 2, which allows for trucks to utilize roads and streets within the Borough of St. Clair can only be used by trucks hauling waste generated within the borough and these trucks must be under 10 ton. Any complaints or observations that trucks are not following the routes and/or the landfill is not using procedures for trucks to adhere to landfill travel routes are investigated for any potential violations. As part of this renewal application, BRADS updated its Traffic Compliance Plan to specifically restrict any vehicles over 10-ton from utilizing approach route #2. Only trucks carrying waste generated within the Borough of St. Clair can utilize approach route #2. BRADS will conduct random observations of incoming vehicles approach routes to ensure compliance. BRADS also sent the Borough of St. Clair’s Chief of Police a letter informing them of this change and encouraging them to contact the landfill if they suspect any vehicles of violating BRADS Traffic Compliance Plan.

All leachate hauling trucks are required to follow a prescribed route in accordance with the facility Traffic Compliance Plan and also pursuant to the Department permit minor modification issued October 9, 2024, condition #2, which provides: All leachate hauling vehicles shall enter and exit the site via “Approach Route 1” as identified in the BRADS Traffic Control Plan. No leachate hauling vehicle may travel through Saint Clair Borough, with the exception of Route 61.

The State Police have jurisdiction over enforcing vehicle safety laws. In an effort to minimize the number of unsafe vehicles utilizing the landfill, BRADS sent letters to the Pennsylvania State Police Troop L and the Blythe Township Police encouraging them to utilize their facility to conduct safety inspections on the vehicles entering the landfill. Overweight truck concerns were brought up to BRADS during the application review process. In response, BRADS revised its Transportation Compliance Plan to include placing overweight drivers in a holding area for first and second offenses and prohibiting drivers from coming to BRADS upon the third offense. BRADS also requested that Blythe Township update its Surcharge Fee Tier Resolution. The new resolution, signed in November 2024, now includes a minimum $200 surcharge for any truck over 80,000 pounds. Since this $200 surcharge for overweight trucks within 3% of the 80,000-pound maximum gross vehicle weight came into effect in November 2024, the number of overweight trucks reported by BRADS has markedly decreased.

BRADS has an approved Traffic Control Plan that it is required to adhere to. This plan has designated truck routes based on size and type of truck as well as the origin of the waste being hauled. All trucks hauling waste generated outside of the Borough of St. Clair must use approach route number 1. This route requires all trucks to enter the landfill from the East via Burma Road. Approach route number 2, which allows for trucks to utilize roads and streets within the Borough of St. Clair can only be used by trucks hauling waste generated within the borough and these trucks must be under 10 ton. Any complaints or observations that trucks are not following the routes and/or the landfill is not using procedures for trucks to adhere to landfill travel routes are investigated for any potential violations. As part of this renewal application, BRADS updated its Traffic Compliance Plan to specifically restrict any vehicles over 10-ton from utilizing approach route #2. Only trucks carrying waste generated within the Borough of St. Clair can utilize approach route #2. BRADS will conduct random observations of incoming vehicles approach routes to ensure compliance. BRADS also sent the Borough of St. Clair’s Chief of Police a letter informing them of this change and encouraging them to contact the landfill if they suspect any vehicles of violating BRADS Traffic Compliance Plan.

All leachate hauling trucks are required to follow a prescribed route in accordance with the facility Traffic Compliance Plan and also pursuant to the Department permit minor modification issued October 9, 2024, condition #2, which provides: All leachate hauling vehicles shall enter and exit the site via “Approach Route 1” as identified in the BRADS Traffic Control Plan. No leachate hauling vehicle may travel through Saint Clair Borough, with the exception of Route 61.

The State Police have jurisdiction over enforcing vehicle safety laws. In an effort to minimize the number of unsafe vehicles utilizing the landfill, BRADS sent letters to the Pennsylvania State Police Troop L and the Blythe Township Police encouraging them to utilize their facility to conduct safety inspections on the vehicles entering the landfill. Overweight truck concerns were brought up to BRADS during the application review process. In response, BRADS revised its Transportation Compliance Plan to include placing overweight drivers in a holding area for first and second offenses and prohibiting drivers from coming to BRADS upon the third offense. BRADS also requested that Blythe Township update its Surcharge Fee Tier Resolution. The new resolution, signed in November 2024, now includes a minimum $200 surcharge for any truck over 80,000 pounds. Since this $200 surcharge for overweight trucks within 3% of the 80,000-pound maximum gross vehicle weight came into effect in November 2024, the number of overweight trucks reported by BRADS has markedly decreased.

Leachate generated at BRADS landfill is conveyed to and stored in two open top storage tanks on site. All leachate is currently transported by tanker truck to approved wastewater treatment facilities for treatment. BRADS has installed a leachate conveyance piping system to transfer leachate directly from the landfill to the Schuylkill Valley Sewer Authority (SVSA) for treatment. BRADS is negotiating an agreement with SVSA to commence the use of this line. DEP has not identified the storage tanks as a source of odors. No additional odor mitigation measures are necessary.

BRADS landfill is designed with a protective liner according to current engineering design standards and 25 Pa Code Chapter 277 for construction / demolition (“C&D”) landfills. DEP regulations clearly provide liner and construction requirements that are designed to be protective of the environment. As such, the design is a lined system with leachate collection and detection. The landfill design met or exceeded all applicable design standards. BRADS is required to certify all of its construction work. These certifications are reviewed by DEP staff to ensure all construction standards are met. BRADS landfill has a system of groundwater wells to monitor for any potential environmental degradation. BRADS performs quarterly analysis of chemical composition of leachate to monitor and determine any impact of leachate on the liner system, ensure analytical limits of leachate constituents per the permit are being met, any potential need for modification of groundwater monitoring system, and any potential need for change to any effluent limitations of their NPDES permit. Based on this groundwater monitoring, there is no evidence that BRADS’s current C&D waste landfill operation is impacting soil or groundwater.

All leachate hauling trucks are required to follow a prescribed route in accordance with the facility Traffic Compliance Plan and also pursuant to the Department permit minor modification issued October 9, 2024, condition #2, which provides: All leachate hauling vehicles shall enter and exit the site via “Approach Route 1” as identified in the BRADS Traffic Control Plan. No leachate hauling vehicle may travel through Saint Clair Borough, with the exception of Route 61.

The leachate force main is a dual contained 4” x 8” DR 11 high density polyethylene (HDPE) pipeline. HDPE pipe is the design standard for landfill leachate conveyance. It has high abrasion and chemical resistance to an extensive number of reagents and solvents. The standard design life for this pipe material is 100 years. When designed, installed /constructed properly it has high resistance to buckling, crushing and deflection. Landfill leachate pipeline conveyance systems are designed, constructed and certified by a Professional Engineer and must satisfy all DEP regulations and requirements.

BRADS is a construction and demolition waste-only landfill. The referenced study was conducted at municipal waste landfills, which accepted pharmaceutical waste. Due to BRADS being a C&D-only landfill, it is not permitted to receive any pharmaceutical waste, such as lidocaine or carbamazepine, therefore pharmaceutical waste is not an issue at BRADS.

Bisphenol A, commonly known as BPA, was, and is still, found in many plastic and thermal paper products, but has been phased out of many consumer-grade plastics in the last few decades. Any BPA released by degrading plastics in the landfill would be captured by the landfill’s leachate collection system, thereby preventing it from entering the groundwater system. Additionally, the Department has contingencies in place, including groundwater assessment and abatement requirements, if landfill-related contaminants were to be found in groundwater downgradient of the site.

Compliance with discharge limitations is under the authority of the receiving wastewater treatment plant who also establishes monitoring requirements and frequencies. Under BRADS individual NPDES Permit 0065137, leachate has been tested quarterly for PCBs since at least the third quarter 2020 and PCB results have been below method detection limits for each of the quarterly events over the 5+ years of testing (22 monitoring events).

BRADS is required to continue to collect and treat leachate even after waste acceptance ceases and the landfill is closed. Additionally, the groundwater monitoring network continues to be sampled for decades after the landfill is closed, with contingencies remaining fully in place, regarding offsite migration of any site-related contaminants. This continued, post-closure monitoring is ensured by site bonding requirements, which the landfill is required to maintain.

The facility is permitted to accept only construction and demolition waste. It is not uncommon for C&D waste to contain packing materials such as paper, plastic, and cardboard. All trucks entering BRADS landfill are required to be labeled with the words “Municipal Waste.” C&D waste is municipal waste. DEP has investigated several complaints regarding the type of waste BRADS receives and disposes of. DEP has never identified any unacceptable waste being disposed of during its inspections. However, BRADS site personnel have discovered unacceptable waste streams entering the facility. These loads were rejected and sent back to the generator.

The leachate force main is a dual contained 4” x 8” DR 11 high density polyethylene (HDPE) pipeline. HDPE pipe is the design standard for landfill leachate conveyance. It has high abrasion and chemical resistance to an extensive number of reagents and solvents. The standard design life for this pipe material is 100 years. When designed, installed /constructed properly it has high resistance to buckling, crushing and deflection. Landfill leachate pipeline conveyance systems are designed, constructed and certified by a Professional Engineer and must satisfy all DEP regulations and requirements.

The Department acknowledges that, at times, BRADS has been the source of odors. The Department cited BRADS for violations related to malodors causing nuisances in the community as a result of complaint investigations. Specifically, Notices of Violation were issued to BRADS on January 2, 2024, May 8, 2024, September 30, 2024 and October 29, 2024. In response, BRADS installed a flare as well as a system of vertical landfill gas (LFG) extraction wells and horizontal collectors in addition to its hydrogen sulfide (H2S) treatment system to address landfill gas/hydrogen sulfide odors. The H2S treatment system removes/reduces the concentration of sulfur compounds entering the flare. The flare destroys any remaining odorous constituents in the LFG. BRADS has also submitted drawings for future gas collection in Cell 3 through Cell 6 which includes plans for future gas extraction wells and gas collection pipeline. Additional horizontal collection systems will be installed as needed when construction and active use of each new cell progresses. The Department has executed a Consent Order & Agreement with BRADS to resolve past violations regarding odor, litter, intermediate cover and leachate management issues. The Agreement included a $96,525.00 penalty and corrective actions to minimize the possibility of these issues from reoccurring. Included in the corrective actions are requirements to perform daily site perimeter checks for odors, conduct quarterly surface emissions monitoring for H2S and a modified Nuisance Minimization and Control Plan (NMCP). The Department also conditioned the renewed permit with additional requirements to further minimize the possibility of these issues from recurring. DEP’s regular inspections, offsite odor patrols and complaint investigations have confirmed that these corrective actions have been effective to minimize offsite odors.

Under the Pennsylvania Solid Waste Management Act, the Department may deny permit issuance if a principal of a corporation was a principal of another corporation which committed past violations of the Pennsylvania Solid Waste Management Act. Also, it provides that any applicant whose related party has engaged in unlawful conduct under the Act shall be denied any permit required by the Solid Waste Management Act unless the permit application demonstrates to the satisfaction of the Department that the unlawful conduct has been corrected.

Waste Connections owns two other landfills in Pennsylvania – Bethlehem Landfill and Blue Ridge Landfill. The Department acknowledges that Bethlehem Landfill Company (BLC) has past and outstanding violations of its operating permit. The Department entered into a Consent Order and Agreement which addresses the outstanding issues through corrective actions with deadlines. BLC also paid a penalty of $137,750. As this was a consensual agreement between the parties, BLC has not demonstrated a lack of ability or intent to comply with the environmental protection acts, the regulations or its permit. Blue Ridge Landfill has a rather limited compliance history since the time that Waste Connections has taken over ownership.

While the Waste Connections facilities in the Northeast Region do have past violations, the execution of the Consent Order and Agreement demonstrates the permittee’s commitment to correcting the violations and evinces its intention and ability to comply. While the Department does acknowledge that Waste Connections facilities in other states do have compliance history, that compliance history varies from facility to facility. The Department focused on the Pennsylvania facilities regulated under the Pennsylvania Solid Waste Management Act. The Department will continue to evaluate compliance with the BRADS permit and can require modification, suspension or revocation of the permit if necessary.

The Department acknowledges that, at times, BRADS has been the source of odors. The Department cited BRADS for violations related to malodors causing nuisances in the community as a result of complaint investigations. Specifically, Notices of Violation were issued to BRADS on January 2, 2024, May 8, 2024, September 30, 2024 and October 29, 2024. In response, BRADS installed a flare as well as a system of vertical landfill gas (LFG) extraction wells and horizontal collectors in addition to its hydrogen sulfide (H2S) treatment system to address landfill gas/hydrogen sulfide odors. The H2S treatment system removes/reduces the concentration of sulfur compounds entering the flare. The flare destroys any remaining odorous constituents in the LFG. BRADS has also submitted drawings for future gas collection in Cell 3 through Cell 6 which includes plans for future gas extraction wells and gas collection pipeline. Additional horizontal collection systems will be installed as needed when construction and active use of each new cell progresses. The Department has executed a Consent Order & Agreement with BRADS to resolve past violations regarding odor, litter, intermediate cover and leachate management issues. The Agreement included a $96,525.00 penalty and corrective actions to minimize the possibility of these issues from reoccurring. Included in the corrective actions are requirements to perform daily site perimeter checks for odors, conduct quarterly surface emissions monitoring for H2S and a modified Nuisance Minimization and Control Plan (NMCP). The Department also conditioned the renewed permit with additional requirements to further minimize the possibility of these issues from recurring. DEP’s regular inspections, offsite odor patrols and complaint investigations have confirmed that these corrective actions have been effective to minimize offsite odors.

The facility is permitted to accept only construction and demolition waste. It is not uncommon for C&D waste to contain packing materials such as paper, plastic, and cardboard. All trucks entering BRADS landfill are required to be labeled with the words “Municipal Waste.” C&D waste is municipal waste. DEP has investigated several complaints regarding the type of waste BRADS receives and disposes of. DEP has never identified any unacceptable waste being disposed of during its inspections. However, BRADS site personnel have discovered unacceptable waste streams entering the facility. These loads were rejected and sent back to the generator.

Regulations and permits are developed to be protective of public health. Implementation of proposed operational controls, mitigation plans and the NMCP are designed to protect public health. That said, some people can have a strong reaction to unpleasant environmental odors, while others may have no reaction. At times, the H2S levels observed may have been high enough to potentially cause symptoms or conditions related to the smell of H2S, such as headache, nausea, fatigue, or stress in some people. This may occur more in those people who have strong reactions to odors. The level at which people can smell H2S in air, also referred to as an odor threshold, varies widely and ranges from 0.0005-0.3 parts per million (ppm), or 0.5-300 parts per billion (ppb). People are primarily exposed to H2S by inhalation, and since it naturally occurs in the environment, the general population will have some exposures. H2S sampling conducted by DEP staff, using a Jerome Meter, occurs frequently at the landfill to measure the concentrations of H2S being emitted from the surface of the landfill. The majority of these readings are significantly less than 1 part per million (ppm). Given the majority of readings obtained on site, taken inches from the surface of the landfill, are below 1 ppm, it is unlikely that residents over 1.5 miles from BRADS are/were exposed to harmful levels of H2S. Established exposure limits are 70 ppb for acute exposure, 20 ppb for intermediate exposure and 1.8 ppb for long term daily exposure.

BRADS landfill is designed with a protective liner according to current engineering design standards and 25 Pa Code Chapter 277 for construction / demolition (“C&D”) landfills. DEP regulations clearly provide liner and construction requirements that are designed to be protective of the environment. As such, the design is a lined system with leachate collection and detection. The landfill design met or exceeded all applicable design standards. BRADS is required to certify all of its construction work. These certifications are reviewed by DEP staff to ensure all construction standards are met. BRADS landfill has a system of groundwater wells to monitor for any potential environmental degradation. BRADS performs quarterly analysis of chemical composition of leachate to monitor and determine any impact of leachate on the liner system, ensure analytical limits of leachate constituents per the permit are being met, any potential need for modification of groundwater monitoring system, and any potential need for change to any effluent limitations of their NPDES permit. Based on this groundwater monitoring, there is no evidence that BRADS’s current C&D waste landfill operation is impacting soil or groundwater.

The Department of Environmental Protection does not have authority to regulate motor vehicle emissions, however, diesel vehicles operating in Pennsylvania must adhere to the Diesel Idling Act (Act 124).

BRADS was cited for violations related to an incident on December 27, 2023, in which leachate was discharged from a failed valve at the leachate sump area. As a result, leachate had run off the lined disposal area and onto the ground adjacent to the lined area. BRADS responded that day to stop the discharge and contain the flow. The contaminated soil from the affected area was removed the following day. Groundwater sampling data from downgradient wells, collected on a quarterly basis, indicates no impacts from the landfill.

BRADS is a construction and demolition waste-only landfill. The referenced study was conducted at municipal waste landfills, which accepted pharmaceutical waste. Due to BRADS being a C&D-only landfill, it is not permitted to receive any pharmaceutical waste, such as lidocaine or carbamazepine, therefore pharmaceutical waste is not an issue at BRADS.

Bisphenol A, commonly known as BPA, was, and is still, found in many plastic and thermal paper products, but has been phased out of many consumer-grade plastics in the last few decades. Any BPA released by degrading plastics in the landfill would be captured by the landfill’s leachate collection system, thereby preventing it from entering the groundwater system. Additionally, the Department has contingencies in place, including groundwater assessment and abatement requirements, if landfill-related contaminants were to be found in groundwater downgradient of the site.

The WQM permit review referenced in the comment above identifies aspects of the project that needed to be addressed prior to issuing the associated WQM approval. These concerns were addressed prior to the issuance of WQM Permit number 5423401.

BRADS is required to continue to collect and treat leachate even after waste acceptance ceases and the landfill is closed. Additionally, the groundwater monitoring network continues to be sampled for decades after the landfill is closed, with contingencies remaining fully in place, regarding offsite migration of any site-related contaminants. This continued, post-closure monitoring is ensured by site bonding requirements, which the landfill is required to maintain.

The landfill is required to follow the Groundwater Quality Monitoring requirements within 25 Pa. Code §§ 277.281 through 277.288, which specify the groundwater monitoring requirements BRADS must follow to be protective of groundwater. DEP reviews groundwater monitoring results from BRADS’ groundwater monitoring network, on both a quarterly and annual basis. To date, no landfill-related impacts have been observed in downgradient monitoring wells.

BRADS also has a leachate detection zone that is monitored quarterly. To date, iron and manganese are the only two monitored analytes that are over their respective secondary maximum contaminant levels (secondary MCL) within the leachate detection zone. Both iron and manganese have been detected over their secondary MCL in one or more upgradient wells, since the sampling program began at BRADS, and they are both commonly elevated in old coal mining regions of Schuylkill County, PA.

While soil is not typically sampled at municipal waste landfills, waste in BRADS landfill, and generally at all modern landfills, does not ever come into contact with site soils and is segregated from native soils by the landfill liner system. Leachate is managed through the leachate collection system, which is also segregated completely from site soils.

If BRADS were to impact any soils through any landfill-related activities, they would be required to immediately remediate the impacted soils. Remediation of impacted soil includes completely removing all impacted soils, and disposing of them at an appropriate facility, depending on the soil’s waste characterization. A specific example of this enforcement by DEP, occurred when BRADS was cited for violations related to an incident on December 27, 2023 in which leachate was discharged from a failed valve at the leachate sump area. As a result, leachate had run off the lined disposal area and onto the ground adjacent to the lined area. BRADS responded that day to stop the discharge and contain the flow. All contaminated soil from the affected area was removed the following day.

Again, groundwater sampling data from downgradient wells, collected on an ongoing quarterly/annual basis, indicate no impacts from the landfill.

The landfill is required to manage stormwater through designed channels and collection system. The effluent discharge from their stormwater management system is regulated under the Clean Water Program Industrial Stormwater Discharge PAG-03 NPDES Permit number PAG032357. This permit requires periodic sampling during a storm event to ensure compliance with stormwater discharge limits. This NPDES permit ensures BRADS is not discharging any contaminated water to any surface water bodies located near the site, via their NPDES monitored discharge.

Additionally, the site’s Groundwater is monitored on a quarterly and annual basis and no impacts have been observed.

BRADS was required to submit an Environmental Assessment with its initial application and with the more recent major modification application. In the Environmental Assessment, which is included as part of Form D of the application, numerous criteria which could potentially affect quality of life are evaluated. These criteria include any potential geologic hazards, stream or river impacts, traffic, aesthetics, stormwater discharge rates, wetland impacts, parks and recreational areas, fish, game and plant impacts, groundwater, potential impacts to historical areas, airport impacts, air quality impacts, and a determination on whether the landfill meets zoning criteria. The applicant also must address any additional potential harms raised through public comment, DEP concerns, or concerns raised by other departments within state government. Where necessary the applicant develops mitigation measures for impacts the landfill will create. The applicant then conducts an evaluation of the environmental, social, and economic harms and benefits that would occur should the permit application be approved. The Department then reviews all of the above information and makes its own evaluation of the harms and benefits of the project. The Department found the benefits of the project to outweigh the harms when BRADS was originally issued the permit. For the renewal application, DEP evaluated how effective BRADS’ mitigation measures have been since they began operating and required BRADS to take additional measures as necessary to ensure harms continue to be mitigated to the fullest extent.

The primary concern at BRADS is removal of H2S to minimize potential for off-site odors. H2S inlet concentrations at the flare are limited in order to ensure that outlet sulfur dioxide concentrations remain below ambient air quality standards. Secondary concerns such as carbon dioxide production and fuel transport as a result of H2S control are necessary to reduce the immediate risk of elevated H2S emissions and are within acceptable standards.

Regulations and permits are developed to be protective of public health. Implementation of proposed operational controls, mitigation plans and the NMCP are designed to protect air, water and public health. BRADS has obtained permits from DEP’s Waste, Air and Clean Water Programs. All of these permits are evaluated to ensure compliance with regulatory standards which are protective of the environment and the community.

Regulations and permits are developed to be protective of public health. Implementation of proposed operational controls, mitigation plans and the NMCP are designed to protect air, water and public health. BRADS has obtained permits from DEP’s Waste, Air and Clean Water Programs. All of these permits are evaluated to ensure compliance with regulatory standards which are protective of the environment and the community.

BRADS landfill is designed with a protective liner according to current engineering design standards and 25 Pa Code Chapter 277 for construction / demolition (“C&D”) landfills. DEP regulations clearly provide liner and construction requirements that are designed to be protective of the environment. As such, the design is a lined system with leachate collection and detection. The landfill design met or exceeded all applicable design standards. BRADS is required to certify all of its construction work. These certifications are reviewed by DEP staff to ensure all construction standards are met. BRADS landfill has a system of groundwater wells to monitor for any potential environmental degradation. BRADS performs quarterly analysis of chemical composition of leachate to monitor and determine any impact of leachate on the liner system, ensure analytical limits of leachate constituents per the permit are being met, any potential need for modification of groundwater monitoring system, and any potential need for change to any effluent limitations of their NPDES permit. Based on this groundwater monitoring, there is no evidence that BRADS’s current C&D waste landfill operation is impacting soil or groundwater.

BRADS is required to continue to collect and treat leachate even after waste acceptance ceases and the landfill is closed. Additionally, the groundwater monitoring network continues to be sampled for decades after the landfill is closed, with contingencies remaining fully in place, regarding offsite migration of any site-related contaminants. This continued, post-closure monitoring is ensured by site bonding requirements, which the landfill is required to maintain.

The landfill is required to follow the Groundwater Quality Monitoring requirements within 25 Pa. Code §§ 277.281 through 277.288, which specify the groundwater monitoring requirements BRADS must follow to be protective of groundwater. DEP reviews groundwater monitoring results from BRADS’ groundwater monitoring network, on both a quarterly and annual basis. To date, no landfill-related impacts have been observed in downgradient monitoring wells.

BRADS also has a leachate detection zone that is monitored quarterly. To date, iron and manganese are the only two monitored analytes that are over their respective secondary maximum contaminant levels (secondary MCL) within the leachate detection zone. Both iron and manganese have been detected over their secondary MCL in one or more upgradient wells, since the sampling program began at BRADS, and they are both commonly elevated in old coal mining regions of Schuylkill County, PA.

While soil is not typically sampled at municipal waste landfills, waste in BRADS landfill, and generally at all modern landfills, does not ever come into contact with site soils and is segregated from native soils by the landfill liner system. Leachate is managed through the leachate collection system, which is also segregated completely from site soils.

If BRADS were to impact any soils through any landfill-related activities, they would be required to immediately remediate the impacted soils. Remediation of impacted soil includes completely removing all impacted soils, and disposing of them at an appropriate facility, depending on the soil’s waste characterization. A specific example of this enforcement by DEP, occurred when BRADS was cited for violations related to an incident on December 27, 2023 in which leachate was discharged from a failed valve at the leachate sump area. As a result, leachate had run off the lined disposal area and onto the ground adjacent to the lined area. BRADS responded that day to stop the discharge and contain the flow. All contaminated soil from the affected area was removed the following day.

Again, groundwater sampling data from downgradient wells, collected on an ongoing quarterly/annual basis, indicate no impacts from the landfill.

Under the Pennsylvania Solid Waste Management Act, the Department may deny, suspend, modify or revoke a permit if it finds that the applicant has failed or continues to fail to comply with the environmental protection acts, rules or regulations of the Department, or any permits or orders issued by the Department; or if the Department finds that the applicant has shown a lack of ability or intention to comply. Further, the Solid Waste Management Act provides that any applicant who has engaged in unlawful conduct as defined in the Act, or whose related party has engaged in such unlawful conduct, shall be denied any permit required by the Solid Waste Management Act unless the permit application demonstrates to the satisfaction of the Department that the unlawful conduct has been corrected.

While BRADS does have past violations, BRADS has not demonstrated a lack of ability or intention to comply with the environmental protections acts, the regulations promulgated thereunder, or its permits. BRADS has addressed the cause of the majority of the complaints through the extension of the gas collection system, maintaining the onsite H2S removal system, installation of the flare and the deployment of proper cover. DEP’s regular inspections, offsite odor patrols and complaint investigations have confirmed that these corrective actions have been effective to minimize offsite odors. Additionally, the Department has entered into a Consent Order and Agreement with BRADS that addresses violations cited by the Waste Management Program in Notices of Violation from 2024 to the present, and contains corrective actions related to intermediate and final cover, vegetation, leachate management, surface emissions monitoring, daily perimeter odor checks and revisions to BRADS Nuisance Minimization and Control Plan to address odors. As this was a consensual agreement, the execution of the Consent Order and Agreement demonstrates the permittee’s commitment to correcting the violations and evinces its intention and ability to comply. Moving forward these enhanced controls and measures should address these past compliance issues.

The Department acknowledges that, at times, BRADS has been the source of odors. The Department cited BRADS for violations related to malodors causing nuisances in the community as a result of complaint investigations. Specifically, Notices of Violation were issued to BRADS on January 2, 2024, May 8, 2024, September 30, 2024 and October 29, 2024. In response, BRADS installed a flare as well as a system of vertical landfill gas (LFG) extraction wells and horizontal collectors in addition to its hydrogen sulfide (H2S) treatment system to address landfill gas/hydrogen sulfide odors. The H2S treatment system removes/reduces the concentration of sulfur compounds entering the flare. The flare destroys any remaining odorous constituents in the LFG. BRADS has also submitted drawings for future gas collection in Cell 3 through Cell 6 which includes plans for future gas extraction wells and gas collection pipeline. Additional horizontal collection systems will be installed as needed when construction and active use of each new cell progresses. The Department has executed a Consent Order & Agreement with BRADS to resolve past violations regarding odor, litter, intermediate cover and leachate management issues. The Agreement included a $96,525.00 penalty and corrective actions to minimize the possibility of these issues from reoccurring. Included in the corrective actions are requirements to perform daily site perimeter checks for odors, conduct quarterly surface emissions monitoring for H2S and a modified Nuisance Minimization and Control Plan (NMCP). The Department also conditioned the renewed permit with additional requirements to further minimize the possibility of these issues from recurring. DEP’s regular inspections, offsite odor patrols and complaint investigations have confirmed that these corrective actions have been effective to minimize offsite odors.

BRADS landfill is designed with a protective liner according to current engineering design standards and 25 Pa Code Chapter 277 for construction / demolition (“C&D”) landfills. DEP regulations clearly provide liner and construction requirements that are designed to be protective of the environment. As such, the design is a lined system with leachate collection and detection. The landfill design met or exceeded all applicable design standards. BRADS is required to certify all of its construction work. These certifications are reviewed by DEP staff to ensure all construction standards are met. BRADS landfill has a system of groundwater wells to monitor for any potential environmental degradation. BRADS performs quarterly analysis of chemical composition of leachate to monitor and determine any impact of leachate on the liner system, ensure analytical limits of leachate constituents per the permit are being met, any potential need for modification of groundwater monitoring system, and any potential need for change to any effluent limitations of their NPDES permit. Based on this groundwater monitoring, there is no evidence that BRADS’s current C&D waste landfill operation is impacting soil or groundwater.

BRADS has an approved Traffic Control Plan that it is required to adhere to. This plan has designated truck routes based on size and type of truck as well as the origin of the waste being hauled. All trucks hauling waste generated outside of the Borough of St. Clair must use approach route number 1. This route requires all trucks to enter the landfill from the East via Burma Road. Approach route number 2, which allows for trucks to utilize roads and streets within the Borough of St. Clair can only be used by trucks hauling waste generated within the borough and these trucks must be under 10 ton. Any complaints or observations that trucks are not following the routes and/or the landfill is not using procedures for trucks to adhere to landfill travel routes are investigated for any potential violations. As part of this renewal application, BRADS updated its Traffic Compliance Plan to specifically restrict any vehicles over 10-ton from utilizing approach route #2. Only trucks carrying waste generated within the Borough of St. Clair can utilize approach route #2. BRADS will conduct random observations of incoming vehicles approach routes to ensure compliance. BRADS also sent the Borough of St. Clair’s Chief of Police a letter informing them of this change and encouraging them to contact the landfill if they suspect any vehicles of violating BRADS Traffic Compliance Plan.

All leachate hauling trucks are required to follow a prescribed route in accordance with the facility Traffic Compliance Plan and also pursuant to the Department permit minor modification issued October 9, 2024, condition #2, which provides: All leachate hauling vehicles shall enter and exit the site via “Approach Route 1” as identified in the BRADS Traffic Control Plan. No leachate hauling vehicle may travel through Saint Clair Borough, with the exception of Route 61.

The State Police have jurisdiction over enforcing vehicle safety laws. In an effort to minimize the number of unsafe vehicles utilizing the landfill, BRADS sent letters to the Pennsylvania State Police Troop L and the Blythe Township Police encouraging them to utilize their facility to conduct safety inspections on the vehicles entering the landfill. Overweight truck concerns were brought up to BRADS during the application review process. In response, BRADS revised its Transportation Compliance Plan to include placing overweight drivers in a holding area for first and second offenses and prohibiting drivers from coming to BRADS upon the third offense. BRADS also requested that Blythe Township update its Surcharge Fee Tier Resolution. The new resolution, signed in November 2024, now includes a minimum $200 surcharge for any truck over 80,000 pounds. Since this $200 surcharge for overweight trucks within 3% of the 80,000-pound maximum gross vehicle weight came into effect in November 2024, the number of overweight trucks reported by BRADS has markedly decreased.

Regulations and permits are developed to be protective of public health. Implementation of proposed operational controls, mitigation plans and the NMCP are designed to protect air, water and public health. BRADS has obtained permits from DEP’s Waste, Air and Clean Water Programs. All of these permits are evaluated to ensure compliance with regulatory standards which are protective of the environment and the community.

The landfill is required to follow the Groundwater Quality Monitoring requirements within 25 Pa. Code §§ 277.281 through 277.288, which specify the groundwater monitoring requirements BRADS must follow to be protective of groundwater. DEP reviews groundwater monitoring results from BRADS’ groundwater monitoring network, on both a quarterly and annual basis. To date, no landfill-related impacts have been observed in downgradient monitoring wells.

BRADS also has a leachate detection zone that is monitored quarterly. To date, iron and manganese are the only two monitored analytes that are over their respective secondary maximum contaminant levels (secondary MCL) within the leachate detection zone. Both iron and manganese have been detected over their secondary MCL in one or more upgradient wells, since the sampling program began at BRADS, and they are both commonly elevated in old coal mining regions of Schuylkill County, PA.

While soil is not typically sampled at municipal waste landfills, waste in BRADS landfill, and generally at all modern landfills, does not ever come into contact with site soils and is segregated from native soils by the landfill liner system. Leachate is managed through the leachate collection system, which is also segregated completely from site soils.

If BRADS were to impact any soils through any landfill-related activities, they would be required to immediately remediate the impacted soils. Remediation of impacted soil includes completely removing all impacted soils, and disposing of them at an appropriate facility, depending on the soil’s waste characterization. A specific example of this enforcement by DEP, occurred when BRADS was cited for violations related to an incident on December 27, 2023 in which leachate was discharged from a failed valve at the leachate sump area. As a result, leachate had run off the lined disposal area and onto the ground adjacent to the lined area. BRADS responded that day to stop the discharge and contain the flow. All contaminated soil from the affected area was removed the following day.

Again, groundwater sampling data from downgradient wells, collected on an ongoing quarterly/annual basis, indicate no impacts from the landfill.

A landfill permit renewal application is not a trigger permit under the Environmental Justice Policy. However, because the landfill is located in an environmental justice area and there was heightened public interest in this application, DEP opted to conduct enhanced public participation actions (i.e., posting information on website, conducting outreach and holding a public hearing and public meeting).

Regulations and permits are developed to be protective of public health. Implementation of proposed operational controls, mitigation plans and the NMCP are designed to protect public health. That said, some people can have a strong reaction to unpleasant environmental odors, while others may have no reaction. At times, the H2S levels observed may have been high enough to potentially cause symptoms or conditions related to the smell of H2S, such as headache, nausea, fatigue, or stress in some people. This may occur more in those people who have strong reactions to odors. The level at which people can smell H2S in air, also referred to as an odor threshold, varies widely and ranges from 0.0005-0.3 parts per million (ppm), or 0.5-300 parts per billion (ppb). People are primarily exposed to H2S by inhalation, and since it naturally occurs in the environment, the general population will have some exposures. H2S sampling conducted by DEP staff, using a Jerome Meter, occurs frequently at the landfill to measure the concentrations of H2S being emitted from the surface of the landfill. The majority of these readings are significantly less than 1 part per million (ppm). Given the majority of readings obtained on site, taken inches from the surface of the landfill, are below 1 ppm, it is unlikely that residents over 1.5 miles from BRADS are/were exposed to harmful levels of H2S. Established exposure limits are 70 ppb for acute exposure, 20 ppb for intermediate exposure and 1.8 ppb for long term daily exposure.

BRADS landfill is designed with a protective liner according to current engineering design standards and 25 Pa Code Chapter 277 for construction / demolition (“C&D”) landfills. DEP regulations clearly provide liner and construction requirements that are designed to be protective of the environment. As such, the design is a lined system with leachate collection and detection. The landfill design met or exceeded all applicable design standards. BRADS is required to certify all of its construction work. These certifications are reviewed by DEP staff to ensure all construction standards are met. BRADS landfill has a system of groundwater wells to monitor for any potential environmental degradation. BRADS performs quarterly analysis of chemical composition of leachate to monitor and determine any impact of leachate on the liner system, ensure analytical limits of leachate constituents per the permit are being met, any potential need for modification of groundwater monitoring system, and any potential need for change to any effluent limitations of their NPDES permit. Based on this groundwater monitoring, there is no evidence that BRADS’s current C&D waste landfill operation is impacting soil or groundwater.

BRADS has an approved Traffic Control Plan that it is required to adhere to. This plan has designated truck routes based on size and type of truck as well as the origin of the waste being hauled. All trucks hauling waste generated outside of the Borough of St. Clair must use approach route number 1. This route requires all trucks to enter the landfill from the East via Burma Road. Approach route number 2, which allows for trucks to utilize roads and streets within the Borough of St. Clair can only be used by trucks hauling waste generated within the borough and these trucks must be under 10 ton. Any complaints or observations that trucks are not following the routes and/or the landfill is not using procedures for trucks to adhere to landfill travel routes are investigated for any potential violations. As part of this renewal application, BRADS updated its Traffic Compliance Plan to specifically restrict any vehicles over 10-ton from utilizing approach route #2. Only trucks carrying waste generated within the Borough of St. Clair can utilize approach route #2. BRADS will conduct random observations of incoming vehicles approach routes to ensure compliance. BRADS also sent the Borough of St. Clair’s Chief of Police a letter informing them of this change and encouraging them to contact the landfill if they suspect any vehicles of violating BRADS Traffic Compliance Plan.

All leachate hauling trucks are required to follow a prescribed route in accordance with the facility Traffic Compliance Plan and also pursuant to the Department permit minor modification issued October 9, 2024, condition #2, which provides: All leachate hauling vehicles shall enter and exit the site via “Approach Route 1” as identified in the BRADS Traffic Control Plan. No leachate hauling vehicle may travel through Saint Clair Borough, with the exception of Route 61.

The State Police have jurisdiction over enforcing vehicle safety laws. In an effort to minimize the number of unsafe vehicles utilizing the landfill, BRADS sent letters to the Pennsylvania State Police Troop L and the Blythe Township Police encouraging them to utilize their facility to conduct safety inspections on the vehicles entering the landfill. Overweight truck concerns were brought up to BRADS during the application review process. In response, BRADS revised its Transportation Compliance Plan to include placing overweight drivers in a holding area for first and second offenses and prohibiting drivers from coming to BRADS upon the third offense. BRADS also requested that Blythe Township update its Surcharge Fee Tier Resolution. The new resolution, signed in November 2024, now includes a minimum $200 surcharge for any truck over 80,000 pounds. Since this $200 surcharge for overweight trucks within 3% of the 80,000-pound maximum gross vehicle weight came into effect in November 2024, the number of overweight trucks reported by BRADS has markedly decreased.

Regulations and permits are developed to be protective of public health. Implementation of proposed operational controls, mitigation plans and the NMCP are designed to protect air, water and public health. BRADS has obtained permits from DEP’s Waste, Air and Clean Water Programs. All of these permits are evaluated to ensure compliance with regulatory standards which are protective of the environment and the community.

The landfill is required to follow the Groundwater Quality Monitoring requirements within 25 Pa. Code §§ 277.281 through 277.288, which specify the groundwater monitoring requirements BRADS must follow to be protective of groundwater. DEP reviews groundwater monitoring results from BRADS’ groundwater monitoring network, on both a quarterly and annual basis. To date, no landfill-related impacts have been observed in downgradient monitoring wells.

BRADS also has a leachate detection zone that is monitored quarterly. To date, iron and manganese are the only two monitored analytes that are over their respective secondary maximum contaminant levels (secondary MCL) within the leachate detection zone. Both iron and manganese have been detected over their secondary MCL in one or more upgradient wells, since the sampling program began at BRADS, and they are both commonly elevated in old coal mining regions of Schuylkill County, PA.

While soil is not typically sampled at municipal waste landfills, waste in BRADS landfill, and generally at all modern landfills, does not ever come into contact with site soils and is segregated from native soils by the landfill liner system. Leachate is managed through the leachate collection system, which is also segregated completely from site soils.

If BRADS were to impact any soils through any landfill-related activities, they would be required to immediately remediate the impacted soils. Remediation of impacted soil includes completely removing all impacted soils, and disposing of them at an appropriate facility, depending on the soil’s waste characterization. A specific example of this enforcement by DEP, occurred when BRADS was cited for violations related to an incident on December 27, 2023 in which leachate was discharged from a failed valve at the leachate sump area. As a result, leachate had run off the lined disposal area and onto the ground adjacent to the lined area. BRADS responded that day to stop the discharge and contain the flow. All contaminated soil from the affected area was removed the following day.

Again, groundwater sampling data from downgradient wells, collected on an ongoing quarterly/annual basis, indicate no impacts from the landfill.

A landfill permit renewal application is not a trigger permit under the Environmental Justice Policy. However, because the landfill is located in an environmental justice area and there was heightened public interest in this application, DEP opted to conduct enhanced public participation actions (i.e., posting information on website, conducting outreach and holding a public hearing and public meeting).

BRADS was required to submit an Environmental Assessment with its initial application and with the more recent major modification application. In the Environmental Assessment, which is included as part of Form D of the application, numerous criteria which could potentially affect quality of life are evaluated. These criteria include any potential geologic hazards, stream or river impacts, traffic, aesthetics, stormwater discharge rates, wetland impacts, parks and recreational areas, fish, game and plant impacts, groundwater, potential impacts to historical areas, airport impacts, air quality impacts, and a determination on whether the landfill meets zoning criteria. The applicant also must address any additional potential harms raised through public comment, DEP concerns, or concerns raised by other departments within state government. Where necessary the applicant develops mitigation measures for impacts the landfill will create. The applicant then conducts an evaluation of the environmental, social, and economic harms and benefits that would occur should the permit application be approved. The Department then reviews all of the above information and makes its own evaluation of the harms and benefits of the project. The Department found the benefits of the project to outweigh the harms when BRADS was originally issued the permit. For the renewal application, DEP evaluated how effective BRADS’ mitigation measures have been since they began operating and required BRADS to take additional measures as necessary to ensure harms continue to be mitigated to the fullest extent.

There were multiple benefits approved, affecting more than just Blythe Township, during the initial permitting of the landfill. These include discounted disposal rates for multiple municipalities, re-establishing Little Wolf Creek, employment, recycling drop-off, removing historically disposed wastes, state taxes, and a fossil repository.

BRADS landfill is designed with a protective liner according to current engineering design standards and 25 Pa Code Chapter 277 for construction / demolition (“C&D”) landfills. DEP regulations clearly provide liner and construction requirements that are designed to be protective of the environment. As such, the design is a lined system with leachate collection and detection. The landfill design met or exceeded all applicable design standards. BRADS is required to certify all of its construction work. These certifications are reviewed by DEP staff to ensure all construction standards are met. BRADS landfill has a system of groundwater wells to monitor for any potential environmental degradation. BRADS performs quarterly analysis of chemical composition of leachate to monitor and determine any impact of leachate on the liner system, ensure analytical limits of leachate constituents per the permit are being met, any potential need for modification of groundwater monitoring system, and any potential need for change to any effluent limitations of their NPDES permit. Based on this groundwater monitoring, there is no evidence that BRADS’s current C&D waste landfill operation is impacting soil or groundwater.

BRADS was cited for violations related to an incident on December 27, 2023, in which leachate was discharged from a failed valve at the leachate sump area. As a result, leachate had run off the lined disposal area and onto the ground adjacent to the lined area. BRADS responded that day to stop the discharge and contain the flow. The contaminated soil from the affected area was removed the following day. Groundwater sampling data from downgradient wells, collected on a quarterly basis, indicates no impacts from the landfill.

The leachate force main is a dual contained 4” x 8” DR 11 high density polyethylene (HDPE) pipeline. HDPE pipe is the design standard for landfill leachate conveyance. It has high abrasion and chemical resistance to an extensive number of reagents and solvents. The standard design life for this pipe material is 100 years. When designed, installed /constructed properly it has high resistance to buckling, crushing and deflection. Landfill leachate pipeline conveyance systems are designed, constructed and certified by a Professional Engineer and must satisfy all DEP regulations and requirements.

BRADS is a construction and demolition waste-only landfill. The referenced study was conducted at municipal waste landfills, which accepted pharmaceutical waste. Due to BRADS being a C&D-only landfill, it is not permitted to receive any pharmaceutical waste, such as lidocaine or carbamazepine, therefore pharmaceutical waste is not an issue at BRADS.

Bisphenol A, commonly known as BPA, was, and is still, found in many plastic and thermal paper products, but has been phased out of many consumer-grade plastics in the last few decades. Any BPA released by degrading plastics in the landfill would be captured by the landfill’s leachate collection system, thereby preventing it from entering the groundwater system. Additionally, the Department has contingencies in place, including groundwater assessment and abatement requirements, if landfill-related contaminants were to be found in groundwater downgradient of the site.

BRADS is required to continue to collect and treat leachate even after waste acceptance ceases and the landfill is closed. Additionally, the groundwater monitoring network continues to be sampled for decades after the landfill is closed, with contingencies remaining fully in place, regarding offsite migration of any site-related contaminants. This continued, post-closure monitoring is ensured by site bonding requirements, which the landfill is required to maintain.

Regulations and permits are developed to be protective of public health. Implementation of proposed operational controls, mitigation plans and the NMCP are designed to protect air, water and public health. BRADS has obtained permits from DEP’s Waste, Air and Clean Water Programs. All of these permits are evaluated to ensure compliance with regulatory standards which are protective of the environment and the community.

The landfill is required to follow the Groundwater Quality Monitoring requirements within 25 Pa. Code §§ 277.281 through 277.288, which specify the groundwater monitoring requirements BRADS must follow to be protective of groundwater. DEP reviews groundwater monitoring results from BRADS’ groundwater monitoring network, on both a quarterly and annual basis. To date, no landfill-related impacts have been observed in downgradient monitoring wells.

BRADS also has a leachate detection zone that is monitored quarterly. To date, iron and manganese are the only two monitored analytes that are over their respective secondary maximum contaminant levels (secondary MCL) within the leachate detection zone. Both iron and manganese have been detected over their secondary MCL in one or more upgradient wells, since the sampling program began at BRADS, and they are both commonly elevated in old coal mining regions of Schuylkill County, PA.

While soil is not typically sampled at municipal waste landfills, waste in BRADS landfill, and generally at all modern landfills, does not ever come into contact with site soils and is segregated from native soils by the landfill liner system. Leachate is managed through the leachate collection system, which is also segregated completely from site soils.

If BRADS were to impact any soils through any landfill-related activities, they would be required to immediately remediate the impacted soils. Remediation of impacted soil includes completely removing all impacted soils, and disposing of them at an appropriate facility, depending on the soil’s waste characterization. A specific example of this enforcement by DEP, occurred when BRADS was cited for violations related to an incident on December 27, 2023 in which leachate was discharged from a failed valve at the leachate sump area. As a result, leachate had run off the lined disposal area and onto the ground adjacent to the lined area. BRADS responded that day to stop the discharge and contain the flow. All contaminated soil from the affected area was removed the following day.

Again, groundwater sampling data from downgradient wells, collected on an ongoing quarterly/annual basis, indicate no impacts from the landfill.

The landfill is required to manage stormwater through designed channels and collection system. The effluent discharge from their stormwater management system is regulated under the Clean Water Program Industrial Stormwater Discharge PAG-03 NPDES Permit number PAG032357. This permit requires periodic sampling during a storm event to ensure compliance with stormwater discharge limits. This NPDES permit ensures BRADS is not discharging any contaminated water to any surface water bodies located near the site, via their NPDES monitored discharge.

Additionally, the site’s Groundwater is monitored on a quarterly and annual basis and no impacts have been observed.

BRADS was required to submit an Environmental Assessment with its initial application and with the more recent major modification application. In the Environmental Assessment, which is included as part of Form D of the application, numerous criteria which could potentially affect quality of life are evaluated. These criteria include any potential geologic hazards, stream or river impacts, traffic, aesthetics, stormwater discharge rates, wetland impacts, parks and recreational areas, fish, game and plant impacts, groundwater, potential impacts to historical areas, airport impacts, air quality impacts, and a determination on whether the landfill meets zoning criteria. The applicant also must address any additional potential harms raised through public comment, DEP concerns, or concerns raised by other departments within state government. Where necessary the applicant develops mitigation measures for impacts the landfill will create. The applicant then conducts an evaluation of the environmental, social, and economic harms and benefits that would occur should the permit application be approved. The Department then reviews all of the above information and makes its own evaluation of the harms and benefits of the project. The Department found the benefits of the project to outweigh the harms when BRADS was originally issued the permit. For the renewal application, DEP evaluated how effective BRADS’ mitigation measures have been since they began operating and required BRADS to take additional measures as necessary to ensure harms continue to be mitigated to the fullest extent.