COMMONWEALTH OF PEN SYLVANIA

BEFORE THE
ENVIRONMENTAL HEARING BOARD

SLUDGE FREE UMBT, et aI., Appellants, and
DELA WARE RlVERKEEPER NETWORK
AND MAYA VAN ROSSUM, Intervenors

v. EHB Docket No. 2014-015-L

COMMONWEALTH OF PENNSYLVANli\,
DEPARTMENT OF ENVIRONMENTAL
PROTECTION and SYNAGRO, a.k.a.
SYNAGRO MID-ATLA TIC, INC., Pennittee

STIPULATION OF SETTLEMENT

AND NOW, this ~ day of January • 20---.!..§., Appellants and Intervenors

(hereinafter collectively "Appellants"), and Appellee Commonwealth of Pennsylvania,

Department of Environmental Protection (hereinafter "Department"), hereby STIPULATE and

AGREE to the following:

WHEREAS, on or about November 7, 2013, Synagro Mid-Allantic (hereinaOer, "Synagro'')

provided a Notice of First Land Application of exceptional quality ("Class A") and non-

exceptional quality ("Class B") biosolids pursuant to PAGOS ("Notice ofril'Sl Land Application")

on the following two (2) properties in Upper Mount Bethel Township. Pcnnsylvanja: a) property

located west of the intersection of Potomac Street and Sunrise Boulevard, Mt. Bethel,

Pennsylvania, TMP No.D I 15 IA-401 31 (the "Potomac Fann" or "Angle I"); and b) property

located south/southwest of the intersection of Sunrise Boulevard and Sagen Drive, Mt. Bethel,

Pennsylvania TMP Nos. D127110131.1 DI2720131, D12710131. DI271 00131. DI2730131 (the

"Sumise Farm" or "Angle II").

IS9SS77.1I41328

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10. Entire Agreement. No changes, additions, modifications, or amendments to this

Agreement shall be effective unless they are set forth in writing and signed by both

parties.

11. Execution. This Settlement may be signed in counterparts, each of which shall be

deemed to be an original and all of which together shall constitute one and the same

instrument. Facsimile or electronic scanned (pdf) signatures shall be valid and effective.

IN WITNESS WHEREOF, the Appellants and the Department hereto have caused this

Agreement to be executed by their duly authorized representatives. The undersigned

representatives of the Parties certify under penalty oflaw, as provided by 18 Pa. C.S. § 4904,

that they are authorized to execute this Settlement on behalf of the Parties, and that the

Parties hereby knowingly waive their right to appeal this Agreement and to challenge its

content or validity, which rights may be available under Section 4 of the Environmental

Hearing Board Act, Act of July 13, 1988, P.L. 530,35 P.S. § 7514; the Administrative

Agency Law, 2 Pa. C.S. § 103(a) and Chapters 5A and 7A; or any other provisions oflaw.

Date: S/INTERVENORS:
....--7--...

Jord er, sq.
Curtin & Heefner LLP
2005 S. Easton Rd., Ste. 100
Doylestown, PA 18901
(267) 898-0570
j by@curtinheefner.com

FOR THE COMMONWEALTH OF PENNSYLVANIA,
DEPARTMENT OF ENVIRONMENTAL PROTECTION:

Michael T. Ferrence, Assistant Counsel
Office of Chief Counsel
2 Public Square
Wilkes-Barre, PA 18701-1915
1595577.1148328

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