This is what a real expert says about the proposed industrial waste dump on Route 145 in Clinton CT: Trinkaus Engineering, LLC 114 Hunters Ridge Road Southbury, Connecticut 06488 203-264-4558 (ph & fax) E-mail: strinkaus@earthlink.net http://www.trinkausengineering.com March 5, 2018 Mr. David Radka, Chairman Inland Wetlands Commission Town of Clinton 54 East Main Street Clinton, Connecticut 06413 Re: Shoreline Rail & Recycling, LLC 30 Old Post Road Clinton, Connecticut Dear Mr. Radka and Members of the Inland Wetlands Commission, I have been retained by Herbert T. Clark, III to perform a third party engineering review of the above referenced application to evaluate direct and indirect adverse impacts on the inland wetlands and watercourses which exist on the subject property as well as for compliance, I have reviewed all of the documents which have been filed with the Town of Clinton Land Use office as of 2/22/18. I have the following comments for your consideration. Evaluation of proposed development on delineated inland wetlands and watercourses: 1. The plan as proposed will result in significant increases in the amount of non-point source pollutants which will be discharged to existing wetlands and watercourse on or adjacent to this site. 2. The cause of the increased pollutant loads is the result of the increased movement of large trailer dump trucks bringing and removing materials from the proposed recycling center. 3. The stormwater management system as proposed by the applicant is inadequate to reduce the non-point source pollutant loads. 4. The proposed stormwater management system does not adequately reduce non-point source pollutants, such as total suspended solids, total phosphorous, total nitrogen, metals, and total petroleum hydrocarbons to the receiving wetlands and watercourses. These included pollutant loads will cause adverse changes to the chemistry of the receiving water. It has been well documented in literature that many aquatic organisms are adversely affected by increased pollutant loads, particularly metals and hydrocarbons. Review of submitted documentation in support of the application: 1. The description of the proposed activities in the application does not mention the proposed outdoor storage area. This is a serious omission in the application and the application should be considered incomplete. 2. The project narrative only talks in generic terms the type and amount of material to be brought to this site (ferrous, non-ferrous metals, volume reduction facility (construction and demolition debris). No detailed description of these types of materials was included. This is extremely important to know as it greatly affects the quality of the stormwater runoff which will be created on the site. 3. The exact composition of and amounts of material to be brought to this site for processing must be provided as this greatly affects the water quality of the runoff. Without knowing this information, this proposed use poses a high and unacceptable risk of polluting the wetlands and watercourses to which runoff will drain from the site. 4. The project narrative does not say if the railroad spur will be used or not for either the delivery or removal of material. The site plan shows truck weigh scales for vehicles arriving and departing the site, it appears that trucks will be the primary source of the materials brought to the site and not the rail spur. 5. With increased deliveries by truck to the site, it will significantly increase the pollutants loads on the site, particularly metals and total petroleum hydrocarbons which will wind up the stormwater. 6. The narrative further states that the facility will remove over 100 trucks per day from the Route 95 corridor. Where is the evidence about the existing truck traffic? Where is it coming from? Where is it going? What types of materials are in the trucks? 7. The application does not list the proposed stormwater management improvements shown on the plans. 8. David Lord delineated the wetlands in the eastern portion of the site according to the mapping, but it appears that he did NOT delineate the wetland area between the parking and rail spur. So who delineated this wetland area and where is the soil report for this wetland system? The map states that it is not known who delineated the wetlands along the railroad. Without this information, the application is not complete. 9. The narrative states that the existing sewage disposal system is adequate for this proposed project. This falls under Section B100a of the Public Health Code Technical Standards. Soil test pits and percolation tests witnessed by the local health authority need to be done to evaluate the system under the requirements of B100a. No current soil data was found on the plans. Also, there based upon the information provided by the applicant, there appears to be a discrepancy as the type and length of the existing sewage disposal system. As the existing system is located within the defined upland review area from the delineated inland wetland boundary, it must be properly evaluated and at this time, cannot be. 10. There are no calculations for evaluating the required Minimum Leaching System Spread (MLSS) based upon current soil testing and the proposed number of employees to be on the site. Only old calculations from the 1980s are provided for the sizing and capacity of the leaching system. 11. Drainage report states that the onsite outdoor storage is 15,000 yards of aggregate material (clean fill), contained by mulch sock. What type of aggregate material? If this is a recycling material why does aggregate material need to be processed? What is the purpose of this material? 12. A single 12” mulch sock is completely inadequate for an outside storage area which will hold 15,000 cubic yards of material. 13. Any type of standard erosion control barrier is inadequate for environmental protection around a stockpile of 15,000 cubic yards of unknown material which will be exposed to the elements. 14. The proposed outdoor storage area is a circle with a diameter of 200’ (scaled from plans). If you apply 15,000 cubic yards to this circle area, there are two options for storing this much material. One is a pile which is 12.9’ over the entire footprint of the circle, which is impossible as the outside limit of the pile would have to be completely vertical. The second is cone shaped pile, centered on the circle. The top of the cone at the center would be 38.7’ in height. 15. As this material will always be exposed to the weather, it is imperative that the type of material be determined prior to any action by Clinton Land Use Agencies. The duration of the stockpiled material must also be known as the discharge of potential pollutants will vary based upon the composition and duration of exposure of the stockpiled material. 16. The applicant proposes to install two hydrodynamic separators on the existing drainage pipes. As proposed the removal efficiency of the hydrodynamic separators will be significantly reduced and will not achieve the CT DEEP goal of 80% removal of TSS. 17. The analysis of the pollutant removal efficiency by the manufacturer for the two CDS units is not valid. Removal efficiencies are greatly affected by the how the system is sized and installed in the drainage system. As proposed, the CDS systems will only be able to remove roughly 30% of the total suspended solids (TSS) load directed to them, not the 80% which is necessary to meet the CT DEEP Goal. 18. Hydrodynamic separators are not suitable for the removal of nutrients as well as soluble pollutants. 19. There are no calculations of the Water Quality Volume per the CT DEP 2004 Storm Water Quality Manual. This is an important omission as the WQV is the volume of water that must be adequately and properly treated to reduce non-point source pollutant loads. 20. The stormwater management system will be discharging into existing wetland systems located between the concrete slab and the rail spur line and then the runoff into off-site wetland boundaries. As proposed, this design will cause adverse environmental impacts to the wetland system on and off of this property. 21. There is no evaluation which factually demonstrates that non-point source pollutants loads will be sufficiently reduce so as not to have adverse environmental impacts on the receiving inland wetland systems. 22. As currently proposed, there will be substantially higher pollutant loads generated from the site as a result of the following; increased number and trips of large dump trucks in and out of the site, and the stockpiling and processing of debris as stated in the application. 23. The entire building, large parking area, truck scales are within 100 year flood plain according the current FEMA mapping. The 100’ flood elevation is 12’. The building slab is at 9’and the parking area, including the truck scales are at a lower elevation (range between 5’ and 7’) and thus these areas are at a higher risk of flooding as they are lower to start with. It is important to keep in mind, that rainfall event less than the 100-year event can cause flooding on this site, just not to the same extent as the 100-year rainfall event. 24. It is stated that there will be a net increase in flood storage volume. 298 yards of fill being applied to site, approximately 461 cubic yards of flood storage will be provided. At the end of the day flood storage will be increased by 163 cubic yards. There are no calculations to support the statement regarding increased flow storage. 25. There is also no analysis showing what the effect of this minor increase in flood storage will be on the current FEMA flood elevation of 12’. It does not appear that addition of 163 cubic yards (4,400 cubic feet) will make reduce the flood elevation of 12’ in any measurable manner. 26. In the submitted stormwater report, it states that an existing swale will provide detention of stormwater. After reviewing the plan, I cannot determine where this swale is on the site. Without the swale being called out on the plan, it is impossible to verify the claims of detention as made in the stormwater report. 27. It is almost important to note that the swale will be overwhelmed during both the 50-year and 100-year rainfall events and will not provide the level of detention claimed in the report. 28. There is no evaluation which factually demonstrates that non-point source pollutants loads will be sufficiently reduce so as not to have adverse environmental impacts on the receiving inland wetland systems. 29. As currently proposed, there will be substantially higher pollutant loads generated from the site as a result of the following; increased number and trips of large dump trucks in and out of the site, and the stockpiling and processing of debris as stated in the application. Conclusion: It is my professional opinions that the submitted plans and civil engineering documentation are missing significant information or contain incorrect information and are not sufficient to allow the Inland Wetlands Commission to accurately evaluate the potential impacts of this development proposal on the environment. As currently proposed, the proposal to construct a recycling facility on this site poses a high risk of adverse water quality impacts to the wetlands and watercourses which are on or in close proximity to this site. Sincerely, Trinkaus Engineering, LLC Steven Trinkaus, PE