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8/18/2019 Nestle Eldred Township Environmental Impact Statement Township Engineer's Review
1/6
nover
ngineering
s s o ates
nc
April 15, 2016
Mary
nne
Clausen, Chair
Board
of
Supervisors
Eldred Township
P.O. Box 600
490 Kunkletown Road
Kunkletown, PA 18058
Dear Mary Anne:
RE: Special Exception Review
Environmental Impact Statement
Deer Park - Chestnut Springs Project
Hanover Project ELD15-21
The following materials were reviewed with regard to environmental impact concerns and
regulations,
as
related to the above-referenced project:
• A Site Plan consisting
of
fifteen
15
sheets, prepared by Miller Bros. Construction,
Inc., dated December 10,2015, with most but not all sheets having a latest revision
date of February 22, 2016.
•
On e 1
copy
of
the Deer Park - Chestnut Springs Project Volume 1
of
3
Application, Environmental Impact Statement,
and Erosion
and Sediment
Contro /Stormwater Management Plans.
• One l) copy
of
the Deer Park - Chestnut Springs Project Volume 2
of
3
Hydrogeological Report, prepared by EarthRes
Group
Inc., dated December 2015.
• A Wellhead Protection Area
Zone
1 and Zone 2 Map dated February 2, 2016.
• A Wellhead Protection Regulation Analysis Table.
This sire
is
located in Eldred Township, Monroe County, south east
of
the intersection
of
Chestnut Ridge Drive
SR
3001) and Kunkletown Road (SR 3004).
The
Applicant proposes to
access the site
via
an unlabeled Stone Arch Bridge Road
to
Chestnut Ridge Drive.
We have reviewed this Special Exception Use Application with respect to the applicable
Township ordinances
and
State and Federal regulations, and we have the following comments
to
offer:
ENVIRONMENT L IMP CT
ST TEMENT
REVIEW:
1.
The Environmental Impact Statement (EIS) does not indicate that the Buckwha
Creek
is
a nearest surface water
to
the project site, noting thar wetlands and the
unnamed tributary are listed.
252 Brodhead Road Suite 100 Bethlehem 18017 8944 • 610.691.5644 • Fax 610.691.6968 www.hanoveren9.com
8/18/2019 Nestle Eldred Township Environmental Impact Statement Township Engineer's Review
2/6
Mary Anne Clausen
Eldred Township
2 April 15, 2016
2. The wedand evaluation report provided in olume 2 of 3 is unclear on the extent of
the evaluation area. The report references a study area
is
outlined
on
Figure
4,
yet
only a Property Boundary
is
shown on Figure
4.
Figure 4 does not indicate the
location of field data collection points. Only eight
8)
field data forms are provided
as
an attachment to the wedand evaluation report, and based
on
descriptions all are
concentrated in the location
of
the delineated wedands and ponds in the western
portion of the site. There does
not
appear to be any supporting data for the
remainder of the 71-acre property. If a smaller study area \us used for the
wedand eHluation, this study area should be clearly depicted on plans and in reports.
The study area should include the entire project area, accounting for buffers on any
edands and waters located outside of the project area.
3. Based on all mapping and reporting provided, the Ordinary High Water Mark
boundaries ofBuckwha Creek and the unnamed tributary flowing through the site
are not located and depicted. The regulated boundaries
of
these features are
necessary for planning and permitting requirements, and should be included on the
plans and in reports.
4. The stream channel connecting upslope identified wedands which conveys surface
flow to the 48-inch CMP
is
not shO\m
on
the plans, and is no t identified
as
a
regulated stream channel which may be within the project area. Further, the stream
enclosure in the existing 48-inch CMP
is
not
identified on the plans or in the EIS as
a regulated waters of the Commonwealth/United States. This feature conveys
surface waters from upslope wedands and unnamed stream channel direcdy to
Buckwha Creek, and therefore
is
a regulated watercourse hich should be delineated
at its Ordinary High \1( ater Mark boundaries. Per Township ordinances, buffers on
this stream channel should also be shown on the plans. Per State regulations,
permits may be required for activities within the watercourse s floodway.
5.
The condition of the 48-inch CMP used for the stream enclosure should be
evaluated to ensure that it is sufficient to maintain functionality as part of the
proposed project activities.
6.
Documentation
dut
the stream enclosure was completed
compliance with State
and Federal regulations should be provided to the Township by the Applicant.
7. Crossing of the stream enclosure with water lines, utility lines, roadway
(improvements), etc. requires State approvals,
and may require Federal approvals if
there will be any repairs to or replacement of the existing 48-inch CMP.
a.
Statewide General PermitNo.5 is required for the water line and any other
utilities.
b. Statewide General Permit o. 7 would be required
for
any upgrade (e.g., fill,
gravel, paving, etc.) to the road for this new use at the site.
8/18/2019 Nestle Eldred Township Environmental Impact Statement Township Engineer's Review
3/6
Mary Anne Clausen
Eldred Township
3 April 15, 2016
8. The
surface water recharge area delineation provided in the Special Exception
Application, which was generated in the Stream Stats program appears to exclude a
sizeable area draining from the east from the old quarry sites on the property.
Further clarification regarding this matter should be provided.
9.
The EIS states
no
fill
or
structures
i I I
be placed in the 1
DO-year
floodplain.
Grading ,,-ith cut-and-fill
is
proposed in the 100-year floodplain
on
the plans
•
t the
project location along the Buckwha Creek, the current FEMA floodplain mapping
indicates a Zone AE floodplain ithout floodway.
\s
such, the Ordinance allows
certain activities within the mapped floodplain area, including fill/development
which when combined i th all other existing and anticipated development,
will
not
increase the Base Flood Elevation more than one foot at any point within the
communiry. The majority of proposed development activities within the Zone AE
floodplain represent minor lowering
of
existing grades for new travel lanes with
curbing. \ temporary sediment trap for erosion and sediment control during
construction activities
is
also partially within the floodplain, but is also lo,,-er than
existing grades.
At
a minimum, activities representing
fill or
structures \vithin the
floodplain include guiderail and landscape plantings. Underground storrnwater
management facilities are also proposed. The applicant must provide proof that
proposed activities within the 1DO-year floodplain
will
not increase the Base Flood
Elevation by greater than one foot ) at any point within the community, with an
appropriate engineering study
and/or
concurrence from FEMA.
10. An existing berm
is
cited in the EIS and it is stated that
water
elentions... clearly
indicate the flood ,,-ater will not flow into the project area. To properly address this
purported discrepancy in the FEMA mapping, the Applicant should apply for and
coordinate
ith
FEl\1A for a fonnal approval and map revision to correcdy depict
on-site conditions.
The
corrected information should then be used for site planning.
11. The endwall, labeled
as
Headwall S-10, should extend to the edge ofBuckwha Creek
and discharge in a stable manner, rather than onto a steep slope. State and Federal
permits may be required, such as Statewide General Permit
No.4
- Intakes and
Outfalls and Federal Section 404 Permit. See Section 707.10.A
of
the Zoning
Ordinance_
12. Under EIS Section C, the two
2
storage tanks are
not
mentioned as new
impervious coverage, nor is there any mention of road re-establishment at Sandy Hill
Path at wellhead buildings.
13. Under EIS Section C, none
of
the species dependent
on
wedands and waters, such
as turtles, snakes, frogs, macroinvertebrates, etc. are mentioned. Potential impacts to
these -ater-dependent species are
not
discussed. Impacts associated with
both
direct and indirect impacts on wetlands and waters should be discussed in the EIS_
14. Crossing
of
the wedands, as shown
on
the plans requites a Joint Permit apprO\-al, as
wedands are designated as Exceptional Value due to reproduction
of
wild trout in
do,,-nstream ,,-aters, as listed by the Pennsylvania Fish and Boat Commission. See
Section 707.1 O.A.
of
the Zoning Ordinance.
8/18/2019 Nestle Eldred Township Environmental Impact Statement Township Engineer's Review
4/6
l\lary
Anne
Clausen
Eldred TO\\ fiship 4 April 15, 2016
15. The validity
of
clearance issued through the Pennsylvania Natural Diversity
Inventory for the potential impacts to a listed plant species with the Pennsylvania
Department
of
Conservation and Natural Resources should be investigated. The
Applicant s agent indicated,
as
part
of
the online search process, that the project
would not have any impacts to surface waters. The project plans and narrative,
however, indicate that there will
be
impacts to surface waters, including impacts
requiring State and Federal authorizations for encroachments. The Applicant should
pro,-ide an updated search with the corrected input and pertinent correspondence
from the jurisdictional agencies, including any additional srudy and associated
clearances that may be required. See Section 707.10.A.
of
the Zoning Ordinance.
16. Based on United States Fish and Wildlife Service (USFWS) guidance in the
Bog
Turrle
Clemmys muhlenbergi,
Northern Population Recovery Plan, all werlands
~ t i n
300 feet
of
the proposed Limits
of
Earth Disrurbance for the project site
must
be
evaluated for potential bog turtle ClemmYJ
l111/lJIenberg i
habitat, travel corridors, and
occurrence, including off-site areas/wetlands. Additionally, all ,,·erlands that are
within the cone
of
depression and within one-half mile of the extraction wells
must also be enluated for potential bog rurrle habitat/occurrence. The srudies that
were conducted do not indicate the srudy area boundaries, respective to the above
noted information. Based on available mapping and information, it is possible that
there are additional werlands within the 300 feet and one half mile radii of the
proposed project Limits
of
Disturbance and extraction wells, respectively. The
Applicant should prm-ide revised mapping and any additional studies and regulatory
correspondence/clearances that may be necessary to meet the USFWS guidance.
17. The plans designate the existing settling ponds
as
wetlands. TI,e EIS states that
only one 1 of these ponds has developed wetland conditions. This discrepancy
should be revised, accordingly.
is
recommended that the Applicant provide a
Jurisdictional Determination from the United States Army
Corps
of
Engineers to
ensure that all wetlands and waters boundaries are properly delineated and classified.
18. The EIS states, There
w
be no detrimental impact to wetlands or Buckwha Creek
as
a result of the project. Test results presented to the Township by the Applicant
indicate a decrease in baseflo,,·s to and in Buckwha Creek, as well
as
to nearby
existing wells. The EIS should contain discussion
of
how these decreases will not
result in detrimental impacts to the on- and off-site waters and wetlands. The EIS
should also contain a discussion on how the proposed stormwater discharge to the
Buckwha Creek will affect the Buckwha Creek.
19.
The EIS
states that the proposed silos (storage tanks) will resemble farm silos and
would be compatible with a typical rural setting. Are there similar stainless steel
farm silos in the area? The property
is
not a farm or an agricultural setting. The EIS
should contain additional discussion to show how the
proposed
facilities at the site
will
not
detract from the actual setting.
8/18/2019 Nestle Eldred Township Environmental Impact Statement Township Engineer's Review
5/6
Mary
.\nne
Clausen
Eldred Township
5
April
15 2016
20.
The EIS
indicates periodic existing use
of
Buckwha Cteek by small watercraft such
as kayaks and canoes. The application should contain discussion
on
how the
proposed project and decreased baseflows may affect this recreational use of
Buclru ha Creek.
21.
The EIS
states,
The
project
is
no t
anticipated to require services
of
the
fIre
company, police, or other municipal services. Based
on proposed
facilities and
uses, howe er, services by the fIre company and police may actually be needed.
22. The EIS states that no flammable materials of concern to a [lIe company will be
stored or used in conjunction with the project. Propane generators are proposed,
however, and tanker trucks will continually be entering and exiting the site during
hours of operation.
23. The Conclusion section of the EIS states, The proposed water extraction use,
which is regulated by both DRBC and PADEP is designed to be operated in a
sustainable manner that complies with applicable regulations, without adversely
impacting surface waters
or
groundwater. Studies prm-ided by the Applicant
indicate lower baseflows in streams (and nearby existing wells) which may indicate an
adverse impact on aquatic flora and fauna, as well as recreation potential noted in the
EIS.
ZONING ORDINANCE
(Section VII):
1. Section 701.1 Setbacks and Buffers - The Ordinance requires that a m x of ground
coyer and shrubbery vegetation and canopy trees, of such variety compatible weith
the local climate, may be required so that a dense screen not less than
six
feet (6 ) in
height will be formed within three
3
years of planting. In addition to proposed
landscape plantings, the report states that there are suffIcient existing natural buffers
between the project area and adjacent residential land. The plans should clearly
show
tillS
buffer area and indicate hov.. this buffer area
w be
protected from future
impacts.
2. Section 707.7 Regulated Uses - Storage tanks are prohibited in Wellhead Protection
Zones 1 and
2. The
EIS states that the tanks will get sanitized, periodically and
that
solution
is
collected and transported for off-site treatment. Therefore, the tanks do not
only contain clean groundwater.
3.
Section 707.7 Regulated Uses -
The
existing truck maintenance facility would require
a Special Exception approval
in
Wellhead Protection
Zone
2.
The
use should
be
formally classifIed and a determination should be made with regard
to
\X ellhead
Protection regulations.
4. Section 707.7 Regulated Uses - The proposed on-lot septic system is a Special
Exception n Wellhead Protection Zone 2.
8/18/2019 Nestle Eldred Township Environmental Impact Statement Township Engineer's Review
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Mary Anne Clausen
Eldred Township April
15 2 16
5. Section 707.9 - Subdivisions and Land Developmenr - It states land developments
proposed with subsurface sewage disposal within the \1Ii'ellhead Protection Zone shall
provide a tested and suitable primary absorption area and a tested and suitable
secondary absorption area.
Test
results for a secondary absorption area must be
provided.
Please note that the re iew
of
the application is ongoing and is therefore subject to further
comment
If you have any questions or comments regarding this information please contact tills office.
Respectfully
HANOVER
ENGINEERING
ASSOCIATES INC.
- -
Jason E. Snlith PWS
Project Scientist
jes:aat
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