Elcon Recycling Services, LLC

This page was last updated on August 27, 2020

On July 23, 2020, Elcon Recycling Services, LLC informed DEP that it no longer planned to pursue its proposed facility in Falls Township, Bucks County. On August 17, 2020, Elcon formally requested that all applications currently under DEP’s review for the project be withdrawn. DEP is no longer reviewing Elcon’s applications. The project webpage will remain online for future reference and accessibility.

Project Termination Notice

Application Withdrawal Request

Application Withdrawal Confirmation

Press releases

• DEP Terminates Review of Elcon Recycling Services, LLC Applications; Applicant to Withdrawal Project
• DEP Issues Draft Denial to Elcon Recycling Services, LLC for Waste Permit
• DEP to Host Public Meeting Regarding Proposed Elcon Recycling Services Facility in Bucks County
• DEP Determines Elcon Recycling Services Application to be Administratively Complete, Begins 10-Month Technical Review (July 2018)
  
• DEP Finds Elcon Application to be Administratively Incomplete (January 2018)
• DEP Receives Phase II Application from Elcon Recycling Services, LLC
• DEP Determines Elcon Application to be Administratively Incomplete
  
• DEP Receives Updated Phase II Application from Elcon Recycling Services, LLC
  

Waste: RCRA Phase II Application

The Resource Conservation and Recovery Act of 1976 was enacted by Congress to mandate that hazardous wastes be treated, stored and disposed of in order to minimize any present or future threats to human health or the environment.

Information Sheets

• Understanding the Permitting Process (PDF)

Correspondence

• March 9, 2017 DEP letter Re: receipt of application (PDF)
• March 16, 2017 DEP letter to Elcon Re: Assertion of Confidential Business Information (PDF)
• March 24, 2017 DEP letter to Elcon Re: Permit coordination (PDF)
• March 30, 2017 Elcon response to DEP Re: CBI (PDF)
• April 11, 2017 DEP letter to EPA Re: CBI (PDF)
• April 24, 2017 DEP letter to Elcon Re: CBI (PDF)
• May 8, 2017 Elcon letter to DEP Re: CBI (PDF)
• May 30, 2017 DEP letter to Elcon – Deficiency Letter (PDF)
• May 30, 2017 Deficiency Letter Attachments (PDF)
• October 20, 2017 DEP letter to Elcon – Admin Response Acknowledgment (PDF)
• October 20, 2017 DEP letter to Elcon Re: CBI (PDF)
• November 27, 2017 DEP letter to Elcon Re: CBI (PDF)
• December 22, 2017 Elcon letter to DEP Re: CBI (PDF)
  
• January 9, 2018 DEP letter to Elcon – Administrative Deficiency Letter (PDF)
  
• May 15, 2018 DEP letter to Elcon – Admin Response Acknowledgment (PDF)
• July 26, 2018 DEP letter to Elcon – Administrative Completeness Letter (PDF)
• July 26, 2018 DEP letter to Elcon – Assertation of CBI (PDF)
• November 13, 2018 DEP letter to Elcon – Permit Coordination (PDF)
  
• November 28, 2018 DEP letter to Elcon – Permit Coordination (PDF)
• December 19, 2018 DEP Letter to Elcon – Response to Deficiencies, Extension (PDF)
• May 15, 2019 DEP Letter to Elcon, Notice of Intent to Deny (PDF)
  
• July 15, 2019 Elcon Letter to DEP Re: Notice of Intent to Deny (PDF)
  
• December 18, 2019 DEP letter to Elcon – request for clarifications (PDF)
• January 17, 2020 DEP letters to Elcon – extension on clarification response (PDF)
  

Application Materials

On May 15, after completing its 10-month technical review of the application, DEP announced its issuance of a Notice of Intent to Deny (NOID). The NOID is a draft action, subject to a 45-day public comment period and is not a final decision. Elcon can still submit additional information to DEP to cure the deficiencies.

• Applicant's Transmittal Letter
• Check
  
• Checklist
• GIF Form
• Notifications
• Part A
• Public Meeting
• Section A
• Section B
• Section C
• Section D
• Section E
• Section F
• Section G
• Section H
• Section I
• Section J
• Section L
• Section M
• Section N
• Section O
• Section P
• Section Q
• October 13, 2017 Elcon Response to Administrative Completeness Letter
• May 9, 2018 Elcon Response to Second Administrative Completeness Letter
• November 8, 2018 DEP letter to Elcon – Technical Deficiencies
• February 8, 2019 Elcon Response to Technical Deficiencies
• February 4, 2020 Elcon Response to Request for Clarification

In addition, hard copies of both the March 1, 2017, Phase II application and subsequent submissions are available for review at DEP's Norristown Office, the Levittown Branch of the Bucks County Library (7311 New Falls Road, Levittown, Pennsylvania) and the Westampton Branch of the Burlington County Library (5 Pioneer Boulevard, Westampton, New Jersey).

Air: Air Quality Plan Approval Application and Dispersion Model/Risk Assessment

On July 23, 2019, DEP issued a technical deficiency letter to Elcon, outlining issues with the plan approval application, dispersion model, and risk assessment report.

These reviews ensure that a facility will meet all applicable rules and regulations, as well as meeting the best available technology, for the air pollution sources and any associated air pollution control equipment.

If Elcon addresses the deficiencies in the letter below, DEP will generate a draft Plan Approval that would allow for the construction and temporary operation of the proposed sources and associated control equipment. A draft plan approval contains specific conditions, including monitoring and recordkeeping, that will ensure the construction and operation of the air pollution sources and control equipment are operated in compliance with the applicable rules and regulations.

Correspondence

• October 16, 2018 Plan Approval Application Transmittal Letter
  
• November 1, 2018 Plan Approval Administrative Completeness Letter
  
• July 23, 2019 DEP letter to Elcon – Air Quality Deficiency Letter
  
• June 11, 2020 DEP Letter to Elcon – AQ Information Request
  
• July 9, 2020 Elcon request for extension
  
• July 9, 2020 DEP approval of extension request
  

Application Materials

• AQ Application 
• February 6, 2020 Elcon Response to AQ Technical Deficiencies
• Air Dispersion Model and Risk Assessment Report – Submitted February 28, 2019

Clean Water: NPDES Stormwater General Permit Application

An NPDES (National Pollutants Discharge Elimination System) PAG-03 permit and best management practices are used to control stormwater runoff and pollution prevention. Following a completeness review, a technical review of the application will be conducted. This includes a site inspection and Pollution Prevention and Control Plan and proposed Best Management Practices review (if applicable). 

Correspondence

• NPDES Transmittal Letter

Application Materials

• Amended Portions of NPDES Application – submitted July 30, 2019
• Amended Site Map – submitted July 30, 2019
• NPDES Application 
• Amended Portions of NPDES Application – submitted March 1, 2019

Clean Water: Act 537 – Sewage Planning

Elcon submitted a sewage planning waiver application in July 2019, which would allow the applicant to forego the full sewage planning process. DEP has determined that Elcon does not qualify for the planning exemption and must submit a full planning module to DEP for review.

• March 2, 2016 Checklist Letter – Planning Module
• July 31, 2019 DEP Response to Elcon re: Planning Module

Waterways and Wetlands: NPDES Permit for Stormwater Discharges Associated with Construction Activities Application

A person proposing an earth disturbance activity that involves equal to or greater than one (1) acre of earth disturbance shall obtain an NPDES (National Pollutants Discharge Elimination System) Permit for Stormwater Discharges Associated with Construction Activities. These applications are first submitted to the respective County Conservation District (CCD) for a Completeness Review. After the applications are determined to be complete by the CCD, DEP performs a coordinated Technical Review with the CCD.

Correspondence

• December 18, 2019 WAW NPDES Technical Deficiency Letter
• January 29, 2020 WAW NPDES Technical Deficiency Response 
  

Application Materials

Original Application Submission

• Transmittal
• Transmittal - Stamped
• BCCD Response Letter
• BCCD Application
• BCCD Application - Updated
• NOI Application
• NOI Checklist
• Land Use Questions
• NPDES GIF Form
• PHMC Letter
• NPDES Notice to BCPC
• NPDES Notice to Twp.
• PNDI Receipt
• PCSM Report
• E&S Report
• Act 2 Report

Response to 12/18/19 Technical Deficiency Letter

• DEP Clouded Info Response Letter (PDF)
  
• DEP Response Letter (PDF)
• Overall PCSM Plan (PDF)
• Act 2 Approval Letter (PDF)
• PCSM Plan (PDF)
• Non-Use Aquifer Determination Letter (PDF) 
• PCSM Details (PDF)
  
• BCCD Application (PDF)
• PCSM Details 2 (PDF)
• NOI Application (PDF)
  
• Overall Erosion and Sediment Control Plan (PDF)
• Erosion and Sediment Control Plan (PDF)
  
• NOI Checklist (PDF)
  
• Erosion and Sediment Control Details 1 (PDF)
• NPDES GIF Form (PDF)
  
• Erosion and Sediment Control Details 2 (PDF)
  
• PCSM Report (PDF)
  
• Erosion and Sediment Control Report (PDF)
  

Response to 1/29/20 Technical Deficiency Letter

• Transmittal - BCCD (PDF)
• Transmittal - DEP (PDF)
• BCCD Response to PA DEP Additional Technical Comments Letter (PDF)
• Response to PA DEP Additional Technical Comments Letter (PDF)
• Overall PCSM Plan (PDF)
• NOI Application (PDF)
• PCSM Plan (PDF)
• PCSM Details 1 (PDF)
• PCSM Report (PDF)
• PCSM Details 2 (PDF)

Public Involvement

Announcements regarding DEP opportunities for public participation will be posted here.

June 1, 2019 – July 15, 2019 Public Comment Period
A 45-day comment period was open to the public to comment on DEP's Notice of Intent to Deny Elcon's RCRA application. All comments submitted during the comment period will be reviewed and responded to in a comment-response document at the conclusion of the application review.

March 5, 2019 Public Meeting
The Pennsylvania Department of Environmental Protection (DEP) hosted a public meeting regarding Elcon Recycling Services, LLC's (Elcon) proposed plans in Falls Township, Bucks County. To date, Elcon has applied to DEP for a Solid Waste Management Permit for a Commercial Hazardous Waste Treatment and Storage Facility, an Air Quality Plan Approval, and a General Stormwater Discharge permit. Representatives from DEP's Waste Management, Air Quality, and Clean Water programs provided background information on the applications currently under review and answered questions from the audience. The meeting was held at the Sheraton Bucks County Hotel. Formal presentations or transcripts were not presented or created for this event. Panelists included: Tom Magge (Clean Water); Jim Rebarchak, Jim Beach (Air Quality); Charlie Fees, Mohamad Mazid, Tom Mellott, Glenn Mitzel, Kuang-Chung Ou, Vu Tran, Jim Wentzel (Waste); Virginia Cain (Moderator)

December 28, 2019 – January 27, 2020 Public Comment Period
A 30-day comment period is open to the public to comment on the Waterways and Wetlands: NPDES Permit for Stormwater Discharges Associated with Construction Activities Application. The Bucks County Conservation District deemed the application administratively complete and DEP’s Southeast Regional Office is conducting a technical review.

Comments will be accepted throughout the duration of the application review. However, only comments received within a published comment period will be responded to in a final comment response document. Please send all comments to the project resource account: RA-EPHWELCON@PA.GOV