SOUTH ESSEX SEWERAGE DISTRICT DEQESOUTH ESSEX SEWERAGE DISTRICT
D. E. Q. E.
ANTHONY D. CORTESC, S,.D.
C..m;%,i ....
727.3194
-R E P 0 R T
SUBJECT: Salem
South Essex Sewerage-bistrict
BY: Bruce K. Mail -let
DATE: November 8, 1979
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The South Essex Sewerage Treatment Plant was opened in September 1979..
Approvals for the sewage sludge incinerator associated with the plant,we.re
issued in 1973 and 1975. (The latter approval was for a change in the scrubber
to meet federal New Source Performance Standards).
The plant was put on line in September 1977, but only operated Eor about
one week. Very high Hydrogen Sulfide levels in the plant made work conditions
intolerable and forced shut down of the plant.
Modifications were designed and approved in mid 1978. The installation
of new equipment was accomplished in.late 1978, and the plant was put back on
line.
The incinerator was stack tested in April 1979. It had operated since•
late February 1979. (Subsequent result's showed the units met the particulate
emission limitations.) "
Complaints from neighborhood residents began to occur as warm weather
arrived. The situation culminated with the South Essex Sewerage Board ordering
incineration stopped in June of 1979.
Modifications to the.sludge incinerator were proposed by Metcalf and Eddy,.
the consulting engineer for the plant, which included use of the number one
hearth as an afterburner. This modification of*unit number. one was tried on
July 13, 1979. The unit operated until July 18, 1979 when the Board again
discontinued use of the incinerator. The Department of Environmental Quality
Engineering obtained a court order to force operation of the incinerators, and
the operation, was restarted on September 17, 1979. Mechanical problems forced
a discontinuance of sludge buiii.ing until September 25, 1979.
Continuous Operation
During the continuous operation which began on September 25, 1979, the
Dcpartmpnt of Environmental Quality Engineering, provided observers both
inside the plant, and in the neighborhood. The observers were to note conditions'
in the control room, and odor nuisance conditions in the neighborhoods. Department .
of Environmental Quality Engineering personnel were at the plant daily., for 18 to
24 hours 7during sludge burning.
Control room observations and neighborhood observations were recorded
at specific intervals (copies'of the observations are attached as appendices).
Prior to start up, an operating procedure was developed jointly by the
Department of Environmental Quality Engineering personnel, South Essex operators
Mr. Richardson and Mr. Barone, and Mr. Frank Reardon and Mr. Tom Hintz of Metcalf!
and Eddy (a copy is attached 3n the appendix).
During the observation period, sludge was burned in Unit #1 from September .
25 through September 29, 1979. No major odor problems were encountered from
sludge burning during the use of incinerator number 1. Some downwash did occur,
but the odors were slight to.moderate. Most complaints received were attributed
to the process odors, and were described as "sewage".
Mechanical problems with the I.D. fan and then the by-pass damper forced
a switch to unit number 2. Unit number 2 was not modified to provide the .
afterburner mode. Temperatures from hearth number 1 in unit number 2 were 400-500OF
lower than those from hearth 1 in unit number 1. Sludge was burned at the same
rate of 10 tons per hour in unit number 2 as was burned in unit number 1. More
odor complaints were received, and more odor was detected in the neighborhood.
A severe rainstorm on October 1, 1979 flushed the sewer lines and created a very
poor sludge. Sulfides in the 'sludge could not be controlled. [leather conditions
on October 5, 1979 were heavy fog and very light on -shore winds. Downwash was
severe, and the neighborhood was fumigated. Lack of the afterburn mode and high
sulfides created a very odorous plume. Sludge burning was stopped, and the
sludge has dumped (pumped to the main effluent'.line). Sludge was again collected
on the 6th, and burning began on the 7th. On October 8th, 1979. the Department
of Environmental Quality Engineering personnel•'Stopped the con tirnuous.coverage
at the plant. ;
s
Tests
During the operation of the two units, the South Essex Sewerage Board
engaged the'Arthur D. Little Co. to test and study the emissions from the
incinerator and the process vents. The.Arthur ;D. Little Co. will. repgrt'to
the Sewerage Board on their work.
In conjunction with the Arthur D. Little work, DEQE performed nodeling
analysis on the stacks from the incinerator and from the process vent. This
modeling analysis confirmed A.3'D. Little's findings and.showed downwash to be a
problem. (downwash is a term applied to a plume that becomes entrained'in air
that is trapped in -the wake of a building)
Stack heights were projected to deterninn what stack height would be
necessary to get out of the downwash condition attributed to the South Essex
Sewerage Plant. A sixty five (65) foot stack (above roof level) was shown by
calculations to be acceptable. Another downwash problem was also analyzed. The
New England Power Company's (NEPCO) Salem Station is .located adjacent to the
South Essex Sewerage Treatment Plant and'is much larger. Stack heights of Units.
al, p2 and #3 are 250 feet, and Unit U4 has a 500 foot stack.,- Wind from the
'•south east (see map) will cause turbulance and downwash of the incinerator plume.'.
Stack heights necessary to overcome this specific downwash problem were not
calculated, but are probably on the order of 300-400 feet.
Downwash caused by NEPCO is not considered a major problem becuase of the
wind direction involved. The majority of the odor complaints were from Fort
Avenue, (below #70) Memorial Drive and Larkin Lane. Wind direction to this
impacted area would nest cause downwash from NEPCO at SESD (see map).
Preliminary data from the ADL work indicates that:
1. odors observed in.the neighbrrhood when unit #1
was operated were slight and very occasional
(confirmed by DEQE).
2. analysis of stack gases by GC -Mass Spec show very
low'o[r,anic content prior to the scrubber, but hig
organic levels after the scrubber (scrubber medium
is effluentflushing water).
3. odor is impact strongest from the pthcess vent.
4. odor from incinerator numher2 prior to the scrubber
is worse than the odor from incinerator number one prior
to the scrubber.
S. odor from incinerator number.2 after the scrubber.is
better than incinerator number 2 prior to the scrubber,
but worse than unit number 1 with the scrubber. '
6. best incineration, from an odor standpoint, was unit '
number 1 (afterburner mode) prior to:.the scrubber.
Odor levels for these situations are graphed and are attached in the
Appendix.
Observations of Incinerator'Operations
DEQE personnel were observers in the control roori for the entire
observation period. Periodic records were kept of readings taken from the .
control panel. These recordings were reviewed, and'some conclusions were drawn..
1. Instruments were not always accurate.
a. percent open was really percent closed.
b. draft across one scrubber plate was really
draft across three scrubber plates. (then
calibrated and defined as being across one ..
plate).
C. draft gauges and air flow could not be correlated.
2. Operators treat similar situations differently
(see attached summary).
Observations of the equipment revealed the following:
1. refractory flaking off in Unit ,'.'1. By•Pass stack.
2. sludge_ combustion vanes may be_funetipning .
improperly. -- - - ---- - --
3. veuturi shaft bent on both units.
4. Unit h2 differs from Unit #1 in feed, location.
These observations have been reviewed by staff engineers of -the metropolitan _.-
Boston/Northeast Region of the DEQE, and have resulted _in, the following _
recommendations: --
1. operations:
a. operators be trained to properly evaluatesltr
incinerator operations.
b. a Standard Operating Procedure be established so that
each operator will react in the same way to rectify
similar situations.
2. capital improvements area:
a. stack height should be increased to prevent.
downwash (preliminary calculations indicate
65 feet above roof level).
b. establish wind direction and velocity ,indicator .at
plant, out of.._the_plant turbulance_
c. modify incinerator number,.2 to mirror incinerator number 1.
d. modify hearth number 1 of both units to get better
retention time and temperature to reduce cas consumption.
e. evaluate better control methods; -perhaps intermittant,
for process vents.
S UMI IA RY
The incinerator of the SESD can burn sludge without causing nuisance
conditions to exist. Modifications can and should be made to reduce odor
impact even further than they have been. Use of an intermittant control strategy
to control odors can be -a cost' -effective measure. The wind direction, wind
speed, and stack height are important considerations in this area.
s
The use of "cit_" water instead of effluent flushing water will eliminate
the odorous organic material added to the stack gases by the scrubber. The
use of this scrubbing medium when downwash, even though stack height increased,
would occur (when wind comes over NEPCO) should•reduce the odor iinpacE.
n
The operation of the sewage sludge incinerators located at Fort Avenue,
Salem was observed by Department Personnel during the period from September
17 to October 8, 1979.
An analysis of actions taken by the various plant personnel as a result.
of fluctuations in the operating conditions has revealed the following results:
1. Variations in 'Temperatures in burning zones:
1. Condition: Temperatures in burning hearths (116 and 117) increase
sharply.
Responses: Time Action Noted
a. Reduce Dialatrols 9/28 3:00 P.M. 10/4 4:00 P.M.
b. Cut 1 or 2 burners .`; 9/17 11:00 Art. 9/18 Noon
at a time
c. Cut 3 or 4 burners 9/26 5:30 P.M. 8:00: P.N.
d. No response 9/29 all day 10/5 7:00 - 10:00 A.M.
2. Condition: Temperature in Burning Hearths drop sharply.
Responses:
a. Fire one burner and wait 9/28 6:00 P.M.
for its response
b. Fire 4 burners 9/29 Midnight to 8:00 A.M.
c. Increase dialatrols 9/17 2:00 P.M. 9/28 5:_00 P.M.
d. No response 10/4 5:00 - 8:00 P.M.
3. Condition: Burning zone drops dorm one hearth.
Responses:
a. Fire burners above it 10/5 Noon
b. No response 9/29 Noon
c. Cut burners below it 10/8 .10:00 A.M.
II. Reduction in amount of oxygen supplied to hearths:
1. Condition: Insufficient oxygen for combustion.
Responses:
a. Add oxygen by opening combustion
air dampers below burning zone
b. Clothing
III. Reactions to Alarms:
1. Conditon: Low scrubber water alarm set off.
Responses:
j Operator turned valve the wrong way, further reducing water
level in the scrubber.
PAY
Indicators and Controls:
The indicator panels, lights, and metersare not consistent. The
scrublrgr water meter indicates the pressure drop across one plate, however
it actually measures the total pressure drop. across all three .plates.. The
indicators for the combustion air dampers and sludge combustion vanes are
also inconsistent. A reading of zero percent.open on the meter'actually
represents percent open. 'file meter for the sludge combustion vancs'is
labeled " '/, Open", however, it actually indicates % closed. It must be
mentioned that the purpose of this report ip not to put blame on the plant
personnel for inconsisties in incinerator operation; but rather to point
out the need for proper, adequate operator training and accurate indicators
and controls. A Standard Operating Procedure must be developed, and followed,-
for optimum efficiency. This SOP must reflect difficulties faced by plant
personnel when burning variable amoutns of industrial/municiple sludges.
Input from chief operators and other_ plant personnel would be valuable in
the development of this SOP.'
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ANTHONY D. CORTESE, Sc D.
Comminioner
727-5194 January 9, 1984
935-2160
Daniel J. Lynch, P.E. i 04 RE: SALEM -Subsurface Sewage
210 Washington Street Disposal System
Marblehead, MA 01945 UjOF SALEM Salem Sound Development Corp.
HFAurH DEpt.
Winter Island Marina
Support Building
Gentlemen:
<The Metropolitan Boston/Northeast Regional 'Office of`the Department of
Environmental..Quality.Engineering-acknowledges:receipt'of;..Your -"letter dated
December 16,,;j19U9'!,reque'sting-a "review by the Department of a` proposed ;subsurfac`e
sewage disposal system planto;.service.the subject_facility
k.
The plan consists of one rsheet which is titled.
-Salem Sound Developmeut�Corp.
Proposed" SanitaryLeaching; Facilities .
Winter Island Marina
Date: Decmeber 15, 1983
Scale: As noted
Engineer: D.J.'Lynch, P.E.'
An engineer of the Department has reviewed the plan°and it is the -opinion. of the
Department" that the;plan is:in',conformance with the provisions of 310CMR15.00'
(Title<5)'of the State Environmental Code.
ex
"jUadditional:information is required, contact.Thomas F. Clougherty atthe above
noted address.or at 935-2160.
Very truly yours,
William A: Krol, P;'.r,
Deputy Regional Environmental Engineer
WAK/TFC/mes
.. A..'�.! r ... N.1 r v .-:': ..a... '. r • . .:': r ... n... � 1r .
01
ANTHONY D. CORTESE, S,,p.
Cemmi,.ien.,
727.5,94
R5CE:IVED
,ON 2 21983
OF SDEPM
Salem Suede HEALTH
72 Flint Street
Salem, Massachusetts 01970
Attention: Mr. Jim Shildneck
Gentlemen:
r
June 17, 1983
Re: Salem -Met. Boston
Northeast Region
310 CMR 7.02 - Plans Approval
Appl. No. MBR -83 -IND -031
This letter is to acknowledge your communication received on
June 7, 1983 relative to an application concerning the new scrubbing
system for your chrome liquid process at the Salem facility.
Your application has been assigned the number MBR -83 -IND -031.
Please refer to this application number on 'all. future correspondence
with the Region concerning this matter.
Please be further advised that Section 142B of Chapter 111 of the
General Laws allows the Department, at the discretion of the
Commissioner, the authority to keep certain information confidential
when requested. This confidentiality will apply to any secret
processes, methods of manufacturing, or production information which
could divulge a trade secret.. Emission data may not be kept
confidential under any circumstances, and as such will be considered
part of the public record. Any request to apply confidentiality to
information submitted to this office must be made in writing, should
accompany the submitted information to which it applies, and must
adequately specify those items to which the applicant requests
confidential treatment.
Should you have any questions concerning this application, please
do not' hesitate to contact Ms. Nancy Seidman, the review engineer
assigned to this project, at the above address or telephone number.
Very truly yours,
Thomas R. Parks
Principal Engineer
Air Quality Control
TRP/Edk/rm
cc: Board of Health
DAQC Engr. Branch
Section
ANTHONY D. CORTESE, S[.D,
Commissioner
7274194
935-2160
New England Power Company
20 Turnpike Road
Westboro, Ma 01581
Attention: John W. Leborveau
Gentlemen:
(Oo"rrir1o�uc/� ���:1.zac2ii.1e��1
i�EC EIVED
9q4;
January 31 1984
L ; SALEM
h-,LiH DEPT.
RE: SALEM - MB/NE REGION '
310 CMR 7.13 -Stack Testing
The Metropolitan Boston/Northeast Region of the Department of Environmental
Quality Engineering is aware of concerns over increased levels of particulate
fallout in the communities adjacent to your Salem Harbor Facility. As a result
of recent analyses it has been shown that a significant portion of this problem
is connected to the operation of your oil -fired Unit No. 4. On review of our
files, it has been found that particulate emission compliance testing of Salem
Harbor Unit Number Four has not been conducted since December of 1979.
Therefore, the Department hereby requests that particulate emissions and NO
testing, according to E.P.A. Methods One thru Seven as published in the Federal
Register of August 18, 1977, be conducted on Unit Number Four of your facility.
It is requested that a pre-test report be submitted no later than thirty days
from receipt of this letter, and that testing be conducted no later than sixty
days from same.
If you have any questions regarding this matter, please feel free to contact
Mr. Michael J. Maher or Mr. Brad Stewart at the above address of telephone num-
ber.
Very truly yours,
Richard JI /hatpin
Deputy Regional Environmental Engineer
RJC/Emjm/Ebs/erc
cc: Mr. J. Kwaznik, N.E:P. Co., 24 Fort Ave., Salem, Ma 01970
Salem BoH, Town Hall, Salem, Ma 01970
��rrr�/orrvr/r/ Criv: ri�r�ruiun/n�YJiirr�// <vi �irir u•rn�
ANTHONY D. CORTESE, S,.D.
Commissioner
7275194
935-2160
George A. Be Lisle
36 Cabot St.
Salem, MA 01970
Attention: Mr. George A. Belisle
Gentlemen:
7Yj2'i�ri +C�._ ��,E®
*CU
ULV Cj SV83
CITY OF SALEM
December 1, 1983 HEALTH DEPT.
RE: SALEM/BEVERLY - Met. Boston/Northeast Region
310 CMR 7.09(1) - Dust and Odor
Notice of Violation
Personnel of the Metropolitan Boston/Northeast Region of the Department of
Environmental Quality Engineering, on November 22, 1983 at 9:40AM, observed a
condition of air pollution which was created by the emission of fugitive dust at
the Essex Bridge. Such emissions constitute a violation of Section 7.09 1 of the
"Regulations for the Control of Air Pollution in the Metropolitan Boston/Northeast
Region Air Pollution Control District", which were adopted under the provisions of
Sections 142B and 142D of Chapter 111 of the General Laws.
You are hereby directed to take all appropriate actions required to bring the
subject facility into compliance with the "Regulations" which were adopted to
prevent air pollution and to enhance the quality of the ambient air. You are also
hereby directed to inform this Office in writing on or before December 12, 1983
as to the action you have taken,or intend to take in order to comply with the
stated Section 7.09(1).
Should you have any questions concerning this matter, please contact the
writer at the above address or telephone number.
WSK/tm
cc: Board of Health, Salem
Board of Health, Beverly
Very truly yours, l
Wei scopff S. Kel/ y
Senior Engineer
Air Quality Control Section
0
ANTHONY D. CORTESE, Sc.D.
Commiffioner
7475194
935-2160
Salem Water Department
1 Salem Green
Salem, MA 01970
Gentlemen:
E
is?9. 4/1" .�4,r/ao..�Aimrl,-/�iY O/P(�/ DEC -1 ��W�
CITY OF SALEM
HEALTH DEPT.
December 1, 1983
RE: Salem Public Water System -
Maximum Microbiological
Contaminant Level.
You were sent a violation notice from this office on Nov.22,1983, concerning the
presence of coliform bacteria in your system in August and October, 1983.
Although there were small coliform counts in the system for those months, the
letter sent requiring your system to notify the public was an error.
Please accept apologies for any inconvenience this miscalculation may have caused
If you have any questions, please feel free to call Margaret Carson at 935-2160.
Very Truly Yours,
William A. Kroll, P.E.
Deputy Regional Environmental
Engineer
WAK/MC
cc:Mayors Office, City Hall, Salem MA 0.1970
Board of Health, Robt. E. Blenkhorn, Agent, 1 Broad St., Salem MA 01970
Beverly -Salem Water Supply Board, WTP,Arlington St., Beverly MA 01915
DEQE Boston
-2 -
"The second major step requires the person wishing to land apply Type II or III
sludge or septage to obtain from DEQE a Land Application Certificate. The regulations
require that information demonstrating that the site and application plans meet
established standards must be submitted to the Department. Major issues of
concern are soil type, drainage characteristics, and topography; depth to ground
water; distance to water supply; crops grown; and application rates. DEQE approval
requires local board of health concurrence. A Land Application Certificate is valid
for one year.
Applications for Approval of Suitability and Land Application Certificate
should be submitted to DEQE regional offices. It is redbtmended that those consider-
ing land application consult with the local Cooperative Extension Service and/or
Soil Conservation Service whose expertise can be of great assistance in preparing
a land application proposal.
For further information, contact Fifi Nessen, One Winter Street, Boston, MA
02108, (617) 292-5590. _
A v , / // J
Yl•J_•
ANTHONY
• CORTESE,• ,
C%ne ivi�ctea Greet, :lJi oatooa, • /liaaa. 0$108
December 15, 1983
t- ALTH DEPT...
The Department of Environmental Quality Engineering is pleased to announce
the promulgation of Regulations for the Land Application of Sludge and Septage,
310 CMR 32.00 (Please note that the CMR number has been changed from 310 C -M, 29.0000,
the number used in the Public Hearing Draft). The regulations went into effect
on November 15, 1983. Existing land application projects must comply with the new
regulations by November 15, 1984.
Copies of the regulations, which appeared on November 10 in Massachusetts
Register, No. 389 may be obtained from:
The State House Book Store
Room 116
State House
Boston, Mass. 02133
The cost per issue is $1.25 plus $.65 for mailing.
The regulations establish a two-step process for obtaining approval plans for
land application of sludge or septage. The first step, the approval of sludge or
septage suitability, requires that the owner or operator of a sludge or septage
facility submit an analysis of the sludge or septage for heavy metals and PCBs
to DEQE for approval. Approval of Suitability may be obtained independently of
a Land Application Certificate. Frequency of sampling, specific parameters, and
requirements for analysis are spelled out in the regulations. Depending upon the
quality of the sludge or septage and the degree of stabilization, DEQE may grant
approval for one of the three following categories of uses:
Type I - Sludge and sludge products for unrestricted public use.
Type II - Sludge (including sludge products) and septage suitable
for agricultural use, subject to DEQE approval of the site.
Type III - Sludge (including sludge products) and septage suitable for
crops, exclusive of those for direct human consumption.
Approval of Suitability is valid for two years; during this period sludge or septage
monitoring must continue.
ANTHONY D. CORTESE, Sc.D.
Commissioner
747-5194
39MWArif
eJ��nn ��rzirzoizla�a /� �/ /%/.J.Ja(1-�ffJ 4/4
.LC/erzrtiir enl �.�F� errannzurlrt��icu�� C �riiiirrir r�
</ ,rlr�arilirii �a.11aii. --/Ivrl�aas/ lLcycba
�EEV
Harmony Grove Cemetery CITY OF SAI_E-M
30 Grove Street HEALTH DEPT.
Salem, Ma 0197,0
Attention: Mrs. Alice Havenook
Dear Mrs. Havenook:
January 10, 1984
RE: SALEM - MB/NE REGION
310 CMR 7.06(2) - Visible emissions
Notice of Violation
Personnel of the Metropolitan Boston/Northeast Region of the Department of
Environmental Quality Engineering, on December 28, 1983 at 12:00 p.m., observed
visible emissions having a shade, density or appearance equal to or greater than
a No. 4 of the Chart from the crematory stack at your facility located at Harmony
Grove Cemetery, 30 Grove Street, Salem. Such emissions constitute a violation of
Section 7.06(2) of the "Regulations for the Control of Air Pollution in the Metro -
Boston Air Pollution Control District", which were adopted under the provisions of
Sections 142B and 142D of Chapter 111 of the General Laws.
You are hereby directed to take all appropriate actions required to bring the
subject facility into compliance with the "Regulations" which were adopted to pre-
vent air.pollution and to enhance the quality of the ambient air. You are also
hereby directed to inform this office in writing on or before January 23, 1984 as
to the action ,you have taken, or intend to take in order to comply with the stated
Section 7.06(2).
Should you have any questions concerning ,this matter, please contact the writer
at the above address or telephone number.
Very truly yours,
Weisco, S. Kelly
Senior Engineer
Air Quality Control Section
WSK/erc
cc: BoH, City Hall, Salem, Ma
ANTHONY D. CORTESE, S<.D.
Commissioner
777.5190
935-2160
Mr. Leo Zisis
1 Colonial Road
Lynnfield, Ma 01940
Dear Mr. Zisis:
.1/e/errrlirr rnf ��Uiereion/rem/el�c��Gieel.// U�/�ciiierrir�
��/�dd"•_7 i'Js{, _1
CITY OF SALEM
January 13, 1984 : HEALTH DEPT.
RE: SALEM - Barrel removal from
old Tannery Building
This letter is in regard to your sampling of the liquid and barrels at the
former tannery on the corner of Tremont Street and Irving Street, in Salem, Mass-
achusetts. Samples of solid and liquid material were taken from the barrels and
a vat on the property. Percent volatiles, moisture, ash content, and unsaponi-
fiability of samples were analyzed by Salem Oil and Grease and flash point analysis
was conducted at Stevens Water Analysis.
The liquid sample was found to have a strong hydrocarbon solvent odor and con-
tained 47% volatiles. Solvent Recovery Services of New England was contracted and
removed 1078 gallons of this flammable liquid on December 8, 1983.
The barrels containing the solid, however, have not been removed. Salem Oil
and Grease determined after analysis that the solid is an animal -type grease prob-
ably generated after distillation of liquid waste of the type found in the on-site
vat.
Reportedly, the solids in the drums contained mineral spirits.which have evap-
orated over time. It is therefore the opinion of the Department that these
barrels contain animal grease with low concentrations of mineral spirits; the
barrel contents are therefore not classified as hazardous waste but are classified
as a "special waste" pursuant to 310 CMR 19.00, the Department's Solid Waste Regu-
lations. These barrels can be disposed of at a landfill with the approval of the
Board of Health of the.community where the landfill is located.pursuant to.section
19.16 of these regulations.
Thank you for your cooperation in this matter. Please continue to keep us
informed of your disposal plans for these barrels. If you have any further ques-
tions, please feel free to contact Margo Thornton or John Fitzgerald of my staff
at 935-2160.
Very truly yours,
1x
s�
L �,.t -� u•.. (; , 1. � �, 2�
Richard J. alpin
Deputy Regi al Environmental Engineer
RJC/Emt/EJf/erc
cc: William Cass, Director, Div. of Hazardous Waste, DEQE, 1 Winter St., Boston, Ma 0210
Richard McIntosh, Building Inspector, One Salem Greene, Salem, Ma 01971
Robert Blenkhorn, BoH, One Broad St., Salem, Ma 01971
ANTHONY D. CORTESE, Sc.D.
Comminioner
727-51%
��e
1�eva"Ae el �' �acroie acal¢/ �¢¢l� ��tarerci
�• •` �. , � _ V�vZ'Gelr�o�l¢n, r/rlaslon. - ,�orl�ii•¢.fl ��con
P2P _/Yrri• �ae/aia • �f rrJAN
t /�!'oc�arr, •///%��< 01PG�/
N•EAt TH SALEM January 13, 1984
DEPT,
Michael's Trim Company RE
58 Grove St.
Salem, MA
Attention: Paul Kostopoulos
Gentlemen:
SALEM - Met. Boston/Northeast Region
310 CMR 7.06(1)(A) - Visible Emissions
Notice of Violation
Personnel of the Metropolitan Boston/Northeast Region of the Department of
Environmental Quality Engineering, on January 5, 1984 at 2:3OPM, observed visible
emissions having a shade, density or appearance equal to or greater than a 100%
opacity for a period in excess of six minutes from the wood stove, space heating
stack at your facility located at 58 Grove Street in Salem, Massachusetts. Such
emissions constitute a violation of Section 7.06(1)(A) of the "Regulations for the
Control of Air Pollution in the Metropolitan Boston Air Pollution Control District"
which were adopted under the provisions of Sections 142B and 142D of Chapter 111
of the General Laws.
You are hereby directed to take all appropriate actions required to bring
the subject facility into compliance with the "Regulations" which were adopted
to prevent air pollution and to enhance the quality of the ambient air. You are
also hereby directed to inform this Office in writing on or before January 27, 1984
as to the action you have taken, or intend to take in order to comply with the
stated Section 7.06(1)(A).
Should you have any questions concerning this matter, please contact the
writer at the above address or telephone number.
Very truly yours,/
Weiscop Ke ly
Senior Engineer
Air Quality Control Section
WSK/tm
cc: Board of Health „ Salem, MA
TABLE I
DEPARTMENT OF ENVIRONMENTAL DUALITY ENGINEERING
Metropolitan Boston/Northeast Region
Pertinent Information for
Fossil Fuel Utilization Facilities
Name of Facility: New England Power Company
Location: Salem Harbor Station
Salem, Massachusetts
Submitted by: New England Power Company
20 Turnpike Road
Westborough, MA
The following listed plans and information are classified as
pertinent to the described fossil fuel utilization facility for the
above address.
Plans
* "General Plot Plan, Plant Site -Southend"
dated:
4/23/83
* Schematic Diagram of Pressure
Type Flyash
Handling System", SKM-22
dated:
4/23/83
* "Schematic Diagram of Botton Ash System", SKM-n
dated:
4/23/82
* "General Arrangement of Flyash
Silo and
Dewatering Bins", SKC-16
dated:
9/03/82
* General Arrangement of Flyash
Silo and
Dewatering Bins", SKC-17
dated:
9/03/82
* General Arrangement of Flyash
Silo and
Dewatering Bins", SKC-18
dated:
9/03/82
* "Layout of New Flyash System",
SKM-32-1
dated:
3/03/83
ecifications
• Approval of Boiler Modifications" dated: 7/8/82
* Coal Handling and Sampling System dated: 3/2.1/83
* Ash Handling Systems dated: 5/7/82 & 3/21/83
* Electrostatic Precipitator System dated: 4/7/82 & 9/27/82
* Stack Modification dated: 3/22/82
esiqn Data Sheets
* Fossil Fuel DDS
* Standard Operating Procedure
Attested to by: Mr. Floyd T. John Mass
No. 1982-32
Mr. Mathew West Brown,
dated: 7/8/82
dated: 7/27/82
P.E. Temporary Registration
Mass. P.E. No. 308-78
February 3, 1984
New England Power Company
Page 6
In addition, the nitrogen dioxide emission rate for the Units 1,
2, and 3 must not result in an annual increase of NOx of 250 tons or
more compared to the estimated NOx emissions using oil. Exceedance of
this annual tonnage increase would subject the continued operation of
the converted units to the provisions of the Department's NOx Policy,
dated November 3, 1980. To date, this policy has been assumed not to
apply to this conversion because of the calculations contained in the
Environmental Impact Report submitted for this project (Appendix C,
Page C-3).
This letter constitutes a proposal to approve the Air Ouality
portions of your application only. Disposal of liquids is regulated
by the Division of Water Pollution Control under Sections 26-53, Chap-
ter 21 of the General Laws. Specifically, you should refer to Part Al
of your NPDES Discharge Permit which pertains to changes in discharge.
An Environmental Notification Form was required and submitted for
this project, and a Draft and Final Environmental Impact Report was
prepared. The certificate of the Secretary of Environmental Affairs
dated April 28, 1982 stated that the "Final Environmental Impact Re-
port on this project does adequately and properly comply with Massa-
chusetts General Laws, Chapter 30, Section 62-62H inclusive, and the
regulations implementing MEPA."
Please be advised that this proposed approval would not 'negate
the responsibility of the New England Power Company to comply with
this or any other Federal, State or Local regulations in the future.
Please refer all correspondence on this matter to Mr. Michael J.
Maher, Air Quality Section Chief, Metropolitan Boston/Northeast
Region, 323 New Boston Street, Woburn, Massachusetts.
RJC/yd/rm
cc: Salem Board of Health
Salem Fire Department
DAQC
Very truly yours,
Richard J.1/Chalpin
Deputy Regional Environmental
Engineer
February 3, 1984
New•England Power Company
Page 5
4. That the continuous opacity monitoring equipment with smoke
density indicators, alarms and recorders be maintained and
continuously operated.
5. That each unit shall be equipped with continuous 02 and CO
monitoring equipment including recorders which are properly
installed, maintained and continuously operated.
6. That stack testing for particulate matter and nitrogen oxide
emissions shall be conducted for each unit within sixty days
after each unit goes on line, and that the testing he conduc-
ted in accordance with EPA Reference Method 1-5, and 7 as
specified in the Code of Federal Regulations, Title 40, Part
60, Appendix A - Standards of Performance for New Stationary
Sources.
7. That NEP will switch from coal burning to oil firing when and
if plant operational and/or meterological conditions produce
a threat to any NAAQS. NEP will inform this office by tele-
phone immediately of said fuel switch. NEP will also adhere
to fuel switching plans as well as any other conditions spec-
ified by the "Statement of Agreement" contained in the De-
partment's letter to the attention of Mr. John Kaslow of NEP,
dated Janaury 25, 1982.
8. That NEP comply with each of the requirements, provisions,
and conditions as set forth in the existing DCO (Federal Reg-
ister/Volume 47, No.27/Tuesday February 9,1982/Rules and Reg-
ulations, page 5897).
9. That the maximum ash content of the coal of use not exceed
12.0% by weight.
10. That NEP will continue to submit monthly reports on dry coal
analysis including, but not limited to, the 30 -day "rolling
average" sulfur content values for the coal burned, calcu-
lated for each day of the month. Monthly data shall be re-
ported within 30 days of the end of each month.
11. That NEP locate and secure
sal capacity, or equivalent
resource use of ash, for at
the units burning coal.
enough ash and solid waste dispo-
commercial arrangements for the
least one year of operation of
The particulate emission rate for each of the Units No. 1, 2, and
3 must not exceed 0.12 pounds per million 8.t.u. at any firing rate.
Once this Department has been informed in writing by NEP that the
units are ready for continuous operation, the ability of the described
systems to maintain an emission rate at or below the stated level must
be demonstrated to the Department in accordance with provision Nc. 6
of this letter.
February 3, 1984
New England Power Company
Page 4
Both the bottom and fly ash handling systems are enclosed wi�h no
discharge to the ambient air. Boilers No. 1 and 2 will each generate
3.888 tons of ash per hour, and Boiler No. 3 will generate 6.72 tons
of ash per hour when the Units are operating at 1007 of their rated
capacity while burning coal having the maximum approved ash content.
D. Chimney (Stack) Specifications
The products of combustion from Units No. 1 and 2 will be exhaus-
ted through identical steel stacks, the tops of which are 43n.5 feet
above ground level. These stacks have inside exit diameters of 9 feet
which will provide a flue gas exit velocity of 9n feet per second at a
temperature of 265°F while the units are operating at 100%, rated ca-
pacity.
The products of combustion from Unit No. 3 will be exhausted
through a steel stack, the top of which is also 430.5 feet above
ground level. This stack has an inside exit diameter of 12.5 feet
which will provide a flue gas exit velocity of 90 feet per second at a
temperature of 250°F while the unit is operating at 1007 rated capac-
ity. The stacks from all three units will be clustered within a com-
mon concrete shell complete with an interior elevator to facilitate
stack testing and monitoring.
The Department is of the opinion that the submitted plans, spec-
ifications, and the Standard Operating and Maintenance Procedures per-
tinent to the submittal are in conformance with current air pollution
control engineering practices, and hereby proposes to approve the
boiler/burner systems, the electrostactic precipitator system, tKe ash
handling system, the coal handling system, and the stack specifica-
tions for the described facility, as submitted, including the use of
coal having an ash content of 12.07 by weight or less, with the fol-
lowing provisos:
1. That the Metropolitan Boston/Northeast Regional Office will
be notified in writing when the construction of each of the
described phases is completed, and the individual units are
ready for continuous operation.
2. That should any nuisance condition(s) be generated by the
operation of this facility, or by the storage or handling of
the coal and/or coal ash, then appropriate steps will immedi-
ately be taken by the New Fngland Power Company to abate the
said nuisance condition(s).
3. That the average sulfur content of the coal not exceed 1.21
pounds per million B.t.u. heat release potential for any rol-
ling 30 -day period, nor exceed 2.31 pounds per million
B.t.u. heat release potential in any calendar day.
February 3, 1984
New England Power Company
Page 3
C. Electrostatic Preciritator System
The flue gas particulates from Units No. 1, 2 and 3 will be con-
trolled by three Environmental Elements Corporation rigid electrode
design, cold -side electrostatic precipitators. The Unit No. 1 and 2
precipitators will each be designed to handle 360,300 actual cubic
feet per minute (acfm) at a temperature of 300°F. The anticipated
particulate collection efficiency for Units Nos. 1 and 2 will each be
equal to a guaranteed minimum of 99.23%.which will reduce the particu-
late emission rate for each unit from 2.833 grains per actual cubic
foot (acf) to 0.0161 grains per acf. The particulates collected on
the electrodes will be removed by flail rappers and deposited inhop-
pers. Each electrostatic precipitator unit has 8 hoppers, and each
hopper has a capacity of 4,508 cubic feet.
The Unit No. 3 electrostatic precipitator will be designed to
handle 659,400 acfm at a temperature of 300°F. The anticipated par-
ticulate collection efficiency will he equal to a guaranteed minimum
of 99.23% which will reduce the particulate emission rate from 2.622
grains per acf to 0.0149 grains per acf. The particulates collected
on the electrodes will again be removed by flail rappers and deposited
in 16 hoppers, each of which has a capacity of 4,508 cubic feet.
D. Ash Handling.
The flyash and bottom ash systems are separate sytems. The fly -
ash system will collect flyash from the 32 precipitator hoppers, the
boiler house air heater hoppers of Units 1 and 2, and the economizer
hoppers of Unit No. 3. The ash will be pneumatically conveyed to a
storage silo by means of a positive pressure air stream. The convey-
ing air will be exhausted from the silos and returned to one of the
precipitator inlet ducts. The ash can be loaded into trucks in either
a dry or wet state from the storage silos.
Dry ash will be discharged to a closed tank type truck with
one dry unloader. The outer chute will be locked over the truck inlet
and an exhaust fan will draw flyash spillage from the chute into the
silo. Water conditioned ash would be discharged into open trucks by
two spray type rotary unloaders. The entrance to the truck encicsUre
will have a remotely controlled door which will he closed as necessary
to control fugitive emissions during the loading. All trucks will
normally be spray washed before leaving the facility.
The bottom ash handling system will use water eductors to propel
the ash and water from the bottom ash hopper to the dewatering bins.
The dewatered ash will be loaded into trucks, and the water will he
removed from the dewater bins and routed to the settling basins for
recycling.
February 3, 1984
New England Power Company
Page 2
The coal pile will be sprayed with water, or treated with a
crusting agent to minimize fugitive dust emissions. The main coal
pile will be reworked by tractors to coal hoppers located over the
conveying belt which runs underneath the coal pile. The coal is then
taken by the enclosed conveyor belt through the continuous coal samp-
ler and pulverizer, and ultimately into the boiler/burner chamber.No
particulate emissions are expected to he emitted from the enclosed
conveyor system.
B. Boiler/Burner Specifications
The entire fossil fuel utilization facility consists of four
boilers, three of which (Units No. 1, 2, and 3) will be converted from
oil -firing to coal -firing. Units No. 1 and 2 are identical Babcock &
Wilcox boilers which each have a maximum rated energy input capacity
of 810,000,000 B.t.u. per hour. Unit No. 3 is a Babcock & Wilcox
boiler which has a maximum rated energy input capacity of
1,400,000,000 B.t.u. per hour. The proposed modification consists of
a fuel conversion to allow the firing of pulverized eastern bituminous
coal as the primary fuel of use in Units No. 1, 2 and 3, with No. 6
fuel oil being burned as a secondary fuel of use. Hnit No. 4 is de-
signed as an oil burning unit, and will continue to burn No. 6 fuel
oil having a sulfur content not in excess of 2.27, by weight as the
primary fuel of use.
As modified, Boilers No. 1 and 2 will each be equipped with
twelve Babcock & Wilcox circular register type burners. Each boiler
unit will burn eastern bituminous coal as the primary fuel at a rate
of 64,800 pounds per hour while operating at 100" rated capacity.
Unit No. 3 will be equipped with sixteen circular register type burn-
ers which will also burn eastern bituminous coal as the primary fuel
of use at a rate of 112,000 pounds per hour while operating at 100%
rated capacity. The 30 -day average sulfur content of the proposed
bituminous coal will not exceed 1.21 pounds per million B.t.u. heat
release potential (approximately 1.51% by weight based upon an average
heating value of 12,500 B.t.u. per pound). This fuel will result in
the equivalent sulfur dioxide emissions as the currently used 2.2%
sulfur by weight fuel oil. The ash content of the coal will not ex-
ceed 12% by weight as received. The turndown ratio of the fuel burn-
ing equipment will be 4 to 1. As a standby fuel for Units 1,2 and 3,
No. 6 fuel oil having a sulfur content not in excess of 2.2_% by weight
will be burned, and the combined maximum fuel use rate wi11 be 2n,2.68
gallons per hour while the units are operating at 100%, rated capacity.
— o
ANTHONY D. CORTESE, SI.D.
Commissions,
7]7.5194
New England
20 Turnpike
Westborough,
Attention
Gentlemen:
Power Company
Road
Massachusetts 01581
Mr. John F. Kaslow
/rlr a lnn %lo.tlo2 ./1'nif�i n9/ c7�rin 7CE' IVSD
0 iq
CITY OF SALEM
February 3, 1964 �i HEALTH DEPT.
Re: SALEM -Met. Boston/Northeast
Region
310 CMR 7.02 - Plans Approval
Appl. No. MBR -82 -COM -017
Proposed Approval
The Metropolitan Boston/Northeast Region of the Department of En-
vironmental Quality Engineering has completed its review of the New
England Power Company (NEP) application for the long-term coal conver-
sion at their Salem Harbor facility in Salem, Massachusetts. This
application was made in a series of submittals dating from March 22,
1982 to March 25, 1983. The submitted information bears the seals and
signatures of Mr. Matthew West Brown, Mass. P.E. No. 308-78, and Mr.
Floyd T. John, Temporary Mass. P.E. Permit No. 1982-32.
A review of the submitted information by Department engineers in-
dicates that the items listed on the attached Table 1 are pertinent to
the plans review. A review of the pertinent information discloses
that the application can be divided into the following major sections:
A. Coal Handling Systems
B. Boiler/Burner Specifications
C. Electrostatic Precipitator System
D. Ash Handling System
E; Chimney (Stack) Specifications
Each of these sections is described below.
A. Coal Handling Systems
The coal will normally be delivered to the site by a 36,000 ton
self -unloading collier, although barges will be used during those per-
iods when the collier is unavailable for use. The transfer of the
coal from the collier to the coal pile will occur with the coal being
placed onto the main coal pile by a boom, keeping the fall distance to
that minimum height which is practical while allowing for the safe
operation of the boom. Fugitive emissions from this operation will be
controlled by a baffle system at the discharge end of the boom. The
end of the boom will be equipped with a system of water spray nozzles
to minimize emissions during either windy weather and/or dry coal con-
ditions. Existing cranes will be used to unload all coal from barges,
with similar precautions being employed to routinely minimize the fall
distance of the coal
r
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' (J � i
c
wN 5ev
ANTHONY D. CORTESE, Sc.D.
Co
727-SI94 ' RECEIVED
ijULy1,81983
CITY OF SALEM
HEALTH DEPT,
Salem Suede Co. Inc.
72 Flint Street'
Salem, Massachusetts 01971
I
Attention: Mr. Shildneck
Gentlemen:
July 12, 1983
Re: Salem- Met.Boston/Northeast
Region
310 CMR 7.06(1)(a) -Visible
Emissions
Notice of Violation
Personnel of the Metropolitan Boston/Northeast Region of the
Department of Environmental Quality Engineering, on June 22, 1983
at 10:50 a.m. observed visible emissions having a shade, density or
appearance equal to or greater than a No. 3 of the Chart for a period
in excess of fifteen minutes from the power plant stack at your
facility located at 72 Flint Street, Salem, Massachusetts. Such
emissions constitute a violation of Section 7.06(1)(a) of the
"Regulations for the Control of Air Pollution in the Metropolitan
Boston Air Pollution Control District", which were adopted under the
provisions of Sections 142B and 142D of Chapter 111 of the General
Laws.
You are hereby directed to take all appropriate actions required
to bring the subject facility into compliance with the "Regulations"
which were adopted to prevent air pollution and to enhance the quality
of the ambient air. You are further directed to inform this office in
writing on or before July 26, 1983 as to the action you have taken,
or intend to take in order to comply with the stated Section
7.06(1)(a).
Should you have any questions concerning this matter, please
contact the writer at the above address or telephone number.
Very truly yours,
Weiscopf S. Kelly
Senior Engineer
Air Quality Control Section
WSK/rm
cc: Board of Health
ANTHONY D. CORTESE, Sc.D.
Commissioner
727.5194
��B �(Opirl/17,0/1✓C�<'Cr��� a� c/C/GCGJ.�CGGlLiG1���
9/4rrrGaenl �G�reuei�oiineuzla�_Girrr��j ( �riirrrri
��lr�a�,lirn- clJo.11orz - .11��f�r.ns/ </J,crlron
i'?9-/"I�i'-lJriilo/%-JlrPrl �Jnlrra. -/��`% OGP//l
RE'COVED
JULA-Z 9983
CITY OF SALEM
HEALTH DEPT.
Salem State College
352 Lafayette Street
Salem, Massachusetts 01971
Attention: Arthur Brown
Chief Engineer
Gentlemen:
July 12, 1983
Re: Salem- Met
Region
310 CMR 7.
Emissions
Boston/Northeast
06(1)(a) -Visible
310 CMR 7.04(2)(a) -Fossil Fuel
Utilization Facility
Notice of Violation
Personnel of the Metropolitan Boston/Northeast Region of the
Department of Environmental Quality Engineering, on June 22, 1983 at
11:20 a.m. observed visible emissions having a shade, density or
appearance equal to or greater than a No. 3 of the Chart for a period
in excess of ten minutes from the brick combustion stack at your
facility located at 352 Lafayette Street, Salem, Massachusetts. Such
emissions constitute a violation of Section 7,06(1)(a) of the
"Regulations for the Control of Air Pollution in the Metropolitan
Boston Air Pollution Control District", which were adopted under the
provisions of Sections 1428 and 142D of Chapter 111 of the General
Laws.
During the investigation, personnel of the Metropolitan
Boston/Northeast Region of the Department of Environmental Quality
Engineering observed the operation of a fossil fuel fired boiler rated
by the Department as having an energy input capacity of equal to or
greater than 10,000,000 B.t.u. per hour which was equipped with an
approved smoke density sensing device and recorder that did not
function continuously, and was not maintained in a state of good
repair. Operation of such a facility without said functional
equipment constitutes a violation of Section 7.04(2)(a) of the
"Regulations for the Control of Air Pollution in the Metropolitan
Boston Air Pollution Control District", which were adopted under the
provisions of Sections 142B and 142D of Chapter Ill of the General
Laws.
You are hereby directed to take all appropriate actions required
to bring the subjectl,facility into compliance with the "Regulations"
which were adopted to prevent air pollution and to enhance the quality
of the ambient air. You are further directed to inform this office in
writing on or before July 26, 1983 s to the action you have taken,
or intend to take in order to comp) with the sated Section
7.06(1)(a) and 7.04(2)(a).
Should you have any questions concerning this matter, please
contact the writer at the above address or telephone number.
WSK/rm
cc: Board of Health
Very truly yours,
WeiscopfGS. Kelly '
Senior Engineer
Air Quality Control Section
M
ANTHONY D. CORTESE, S,.D.
Commissioner
747-5194
935-2Lf0
Jean A. Levesque
Mayor, City of Sa'leni
93 W,ishi.ngt-on Street
SaLem, NIA 01970
Dear Sir:
61irir6oi?uizzxfx <j c��z1.1Cz<iiJi�
C�nrfri cii/ fr�i�:rraninialn��ii.r�/� (�//�ih rrrri�f
/10//;/ r111 -f,Jo1�02 - lir/r%�.n.f/ JGP/LeO��
RECEIVED
July 11, 1983
RECEI V E® RE: Salem - Leather Scrap
Wastes at McGrath Park
(JUL' 191983 Marlborough Road
CITY OF SALEM
HEALTH DEPT.
In response to a request from Representative Michael Ruane, five Salem
playgrounds have been investigated due to allegations that the parks were
previously used as waste disposal areas. Engineers from the Department of
Environmental. Quality Engineering on March 29, 1983 conducted field investiga-
tions at the following parks:
I. McGrath Park on Marlborough Road
2. McGlew Park on North Street
3. Furlong Park on Franklin Street
4. Memorial Park on Fort Avenue
5. Palmer Cove Park on Leavitt Street
Portable field instruments used to survey the above referenced sites included
an H -Nu Photoionization Detector (P.I.D.) and a Ludlum Model 2 Geiger Counter. The
Photoionization Detector is capable of detecting low concentrations (parts per
million) of many common organic and some inorganic compounds in the ambient air,
including such volatile organic compounds as benzene, toluene and methylene chloride.
The Ludlum Geiger Counter is capable of detecting radiation levels below 0.1
millirems per hour.
No indication of organic chemicals or radioactive contamination was noted at
any of the sites surveyed using these instruments. However, areas of ash and
cinders at the McGrath Park on Marlborough Road suggest this site was probably
used as a private and/or municipal dumping area in previous years. Additionally,
piles of wastes appearing to be tannery leather scraps were observed along the
northwest perimeter of the park.
On April 29, 1983, engineers sampled water and leather scrap wastes from
the perimeter of McGrath Park for analysis at the Department's Lawrence Experi-
ment Station. According to the laboratory results, a copy of which is enclosed,
the leather waste sample contained 1.03% (total) chromium and trace amounts of
arsenic and lead. Water samples obtained near the leather piles and easterly
perimeter of the park were found to be relatively uncontaminated for those con-
taminants that were analyzed.
ANTHONY D. CORTESE, Sc.D.
Commissioner
747.5194
6T1_1
-J<
Jefferson Foundry
Franklin Street
Salem, Massachusetts 01971
.J�rirlin rii/,�'c�r:.i'a.,oerrrra/ `r rrii/� C72�riirvrri�Q
Attention: Mr. Ron Quellette
Gentlemen:
/Plr�o��p/an .'�a��.1//llhie ..Tor/�i rr.l/'/JLP¢i/Jn
i;!i ..'��, .�<t/au-J(rr./, ����ir2 ., �Y<S'�✓O/rP/�/
May 31, 1983
RECEIVE®
F�4�N I,3 1983
CiTy bF 5ALEM
HEALTH DEFT'
Re: Salem -Met. Boston/Northeast
Region
310 CMR 7.09(1) -Dust and Odor
Notice of Violation
Personnel of the Metropolitan Boston/Northeast Region of the
Department of Environmental Quality Engineering, on May 25, 1983 at
10:00 a.m., detected a condition of air pollution which was created by
the emission of odors from your facility located at Franklin Street,
Salem, Massachusetts. Such emissions constitute a violation of
Section 7.09(1) of the "Regulations for the Control ofiAir Pollution
in the Metropolitan Boston Air Pollution, Control District", which were
adopted under the provisions of Sections 142E and 142Diof Chapter 111
of the General Laws.
You are hereby directed to take all appropriate actions required
to bring the subject facility into compliance with the "Regulations"
which were adopted to prevent air pollution and to enhance the quality
of the ambient air. You are further directed to inform this office in
writing on or before June 13, 1983 as to the action you have taken, or
intend to take in order to comply with the stated Section 7.09(1).
Should you have any questions concerning this matter, please
contact the writer at the above address or telephone number.
Very truly yours, I
Weiscopf S. Kelly
Senior Engineer
Air Quality Control Section
WSK/rm
cc: Board of Health
THE COMMONWEALTH OF MASSACHUSETTS
DEPARTMENT OF ENVIRONMENTAL QUALITY ENGINEERING
DIVISION OF AIR QUALITY CONTROL
N O T I C E
Notice is hereby given that the Department of Environmental
Quality Engineering, acting in accordance with the provisions of
M.G.L. Chapter 111, Section 142A through 142D, and in conformance with
the federal Clean Air Act as amended August 7, 1977 will hold a public
hearing on the matter of the proposed revision of its regulations, 310
CMR 7.12, which will require those facilities,except,public
facilities, that are currently required under this section to register
their facility to pay a fee for an inspection and to 310 CMR 7.00 and
7.02 which will control organic material or gasoline emissions from
external floating roof tanks. Also, pursuant to M.G.L. c.21, section
43 the Department of Water Pollution Control proposes to adopt a fee
regulation that will effect all holders of or applicants for waste
water discharge permits including: surface and subsurface discharge
permits, sewer extension permits and sewer connection permits.
D.W.P.C. intends to adopt the proposed regulation as part of a more
comprehensive permit regulatory proposal which will be the subject of
future hearings.
The public hearings will be conducted under the provisions of
M.G.L. Chapter 30A on:
June 20, 1983 - 10:30 A.M., Auditorium, Lakeville Hospital, Route
105, Lakeville, Massachusetts.
June 21, 1983 - 1:00 P.M., in Building 20, Room 106, Springfield
Technical Community College, Armory Square, Springfield,
Massachusetts.
June 22, 1983 - 10:00 A.M., Faculty Conference Room, University
of Massachusetts Medical Center, 55 Lake Avenue North, Worcester,
Massachusetts.
June 23, 1983 - 10:00 A.M., 10th Floor Conference Room,
Department of Environmental Quality Engineering, One Winter Street,
Boston, Massachusetts.
Testimony may be presented orally and/or in writing no later than
the conclusion of the public hearing. Parties are requested to submit
four written copies of their testimony at the hearing.
Copies of the proposed Regulations and background information
will be available for inspection at the Division of Air Quality
Control, 8th Floor, One Winter Street, Boston, Massachusetts, at the
Merrimack Valley and Metropolitan Boston Air Pollution Control
Districts, 323 New Boston Street, Woburn, Massachusetts, at
the Berkshire and Pioneer Valley Air Pollution Control District, 1414
State Street, Springfield, Massachusetts, at the Central Massachusetts
Air Pollution Control District, 75 Grove Street, Worcester,
Massachusetts and at the Southeastern Massachusetts Air Pollution
Control District, Lakeville Hospital, Lakeville, Massachusetts.
By Order of the Department.
Anthony D.((' ,�ortese, Sc.DD---.��
Commssloner%
BACKGROUND INFORMATION
AND
TECHNICAL SUPPORT
FOR
PUBLIC HEARINGS
ON
PROPOSED AMENDMENTS
TO
310 CMR 7.00 and 7.12
OF THE REGULATIONS
FOR THE
CONTROL OF AIR POLLUTION
IN THE
Berkshire Air Pollution Control District
Central Massachusetts Air Pollution Control District
Merrimack Valley Air Pollution Control District
Metropolitan Boston Air Pollution Control District
Pioneer Valley Air Pollution Control District
Southeastern Massachusetts Air Pollution Control District
I. INTRODUCTION
The Department of Environmental Quality Engineering, Division of
Air Quality Control has undertaken a review of potential fee systems
through the mechanism of a Task Force composed of environmental and
business representatives. The charge to the Task Force from the
Commissioner was to work together to determine a system for
calculating and charging Massachusetts.' facilities a fee that would be
equitable, and to review the level of income such fees could bring to
the Commonwealth.
The policy to recommend a fee structure that would compensate the
Commonweath for certain portions of its costs in carrying out its
regulatory authority authorized by Chapter 111, Section 142B of the
Massachusetts General Laws, was made by the Commissioner prior to the
formation of the Task Force. That issue was not debated by the Task
Force, other than in the limited question of whether to exempt public
or municipal facilities.
The Task Force after several attempts to apportion costs
throughout the permitting process finally reached an agreement on a
basic division between public and private interests in the
permit/registration granting procedures.
The concept on which the proposed rates are based involve three
principles:
1. The original review and granting of a permit under 310 CMF.
7.02 (plan approval) is considered to be in the public
interest and recommended to be funded by public dollars.
The inspection and monitoring of source registration under
310 CMR 7.12 is considered to be in the private interest and
is recommended to be funded by fees collected from the
owners or operators of the facility.
After reviewing costs and potential income, it was agreed
not to charge for the initial permit, but charging for the
inspection of a facility produced an equitable division of
cost sharing between the private and public sectors. The
Department would obtain a predictable income on an ongoing
bases because fees will be paid and collected regardless of
whether an inspected facility is approved or disapproved.
Any facility that has to be re -inspected will not have to
pay a second fee.
2. The costs of operating and maintaining the registration
certificate program incurred by D.E.Q.E. involves not only
the direct cost of the field inspectors, but also the many
support elements of the Department.
The fee is determined by taking the cost of a field person
and multiplying by the days projected to accomplish the
inspections on an annual basis. The cost of a field person
is determined by adding the salaries of the field persons
and related administrative personnel and support costs, then
dividing by the number of field personnel. These
calculations, using existing budget figures, have produced
total costs for field personnel roughly two and one half
times basic salary. This is a rate for overhead and support
that, while conservative, is roughly what could be expected
for a non-profit operation. The Division produced a rate of
$305 per day under this formula which is relatively low for
engineering services.
3. The income derived should result in resources being
allocated to the Department sufficient to carry out its
source registration procedure in a more predictable and
efficient manner.
This third principle was of major concern and unanimously
accepted by all the participants. That is, if a fee is to
be charged for these services, the industries paying the
fees deserve some type of commitment that the income will
assure an adequately staffed D.E.Q.E. to carry out the
inspection and certification functions as proposed. While
it was not in the scope of the Task Force to produce a
specific recommendation, the group felt that some sort of
"dedicated fund" approach should be pursued.
PROPOSAL
After discussions with both industry and environmental
constituencies, D.E.Q.E. has proposed a process whereby the
Commonwealth of Massachusetts will be reimbursed, through fees, for
the Division's inspection and monitoring of permitted facilities.The
Division will charge a fee to most facilities currently being reviewed
by its source registration regulation, 310 CMR 7.12. Those facilities
to be included are fossil fuel facilities that have a rated fuel input
capacity in excess of three million B.t.u. per hour. A typical three
million B.t.u. size boiler includes one necessary to heat and operate
about a twelve unit apartment house. Also, included are most large
industrial facilities such as asphalt batching plants, foundries,
chemical products, aggregate manufacturing plants, food and food
products plants, dry cleaning establishments, paint and varnish
manufacturing plants, paper manufacturing plants, leather
manufacturing plants, concrete manufacturing plants, and metal coating
and treating plants; and most incinerators operated for commercial
purposes. It is proposed by the Department to exclude publicly owned
facilities from paying a fee under this regulation.
The Division estimates that there are approximately 400 major
sources that will be inspected annually and approximately 3,000 minor
sources that will be inspected once every three years. The total
projected income to the Commonwealth for the first year would be
$1,075,000. For a more detailed analysis of cost basis see Appendix
A.
DEQE decided to pursue a fee based on inspection when both
business representatives and environmentalists on the Task Force
expressed reservation with fees geared to permit issuance. On the one
hand environmentalists feared a bias would be created to approve
permits, on the other, businessmen did not want companies who were
denied permits to be charged large review fees since they would have
no capacity to amortize the fee. Nearly all parties could agree on
the inspection process as the most logical basis for charging a fee.
This regulation will give both the Division and the industry a
procedure to work with, providing a level of predictability and
formality not currently extant. Also the regulation will begin to
formalize the relationship between the Division and facilities in
terms of establishing a fixed time limit on registrations and the
renewal process.
Although the Department recognizes the necessity,of charging a
fee for inspections, it wants to discourage getting itself involved in
a collection process against facilities that do not pay their fee.
Therefore, after a facility has been inspected by the Division and
foundto comply with the requirements of 310 CMR 7.12(1) it has an
obligation, after notification by the Department, to pay the
inspection fee. To encourage timely payment of fees, the Department
is proposing to require a late payment charge to delingquent
facilities of $200.00 for major sources and $50.00 for non -major
sources. The Department hopes that all registration fees are paid
when due.
While the Division feels there are several ways it could charge
inspection fees, the proposed system seems most equitable because:
1) It only charges for a registration fee under 310 CMR 7.12,
eliminating the situation of a firm facing fees before
obtaining a permit under 310 CMR 7.02.
2) Although the system raises significant revenue for the
Commonwealth, there is very little pressure on the Division
to grant or deny an inspection certificate based on
increased income.
3) The difference between a source plan approval and a source
registration certificate provides a reasonable division.
between the public benefit of a source plan review and the
ongoing private interest of inspection and compliance
monitoring.
Airregs disk #2
(inspfeetec)
APPENDIX A
DRAFT INSPECTION CERTIFICATE FEES
A. Major Sources (inspected annually)
1. Cost Basis
1.5 days inspection
1.0 day testing
5 day clerical, issuance, complaints
3.0 man days @ $305 = $915
2. Total Recovery for D.E.Q.E.
a) 400 @ 915 = $366,000
Total .................................$366,000.
B. Minor Sources (inspected once every three years)
1. Cost Basis
.3 days inspection
.5 days clerical, service & complaints
.8 San days @ $305 = $244
2. Total Recovery for D.E.Q.E.
a) 3,000 @ $240 = $720,000
Total..................................$720,000
Total From Minor and Major Sources ... $1,086,000
Reduced by an estimate of public facilities exempted ...... $11,000
NET TOTAL...........................$1,075,000
L
THE COMMONWEALTH OF MASSACHUSETTS
DEPARTMENT OF ENVIRONMENTAL QUALITY ENGINEERING
DIVISION OF AIR QUALITY CONTROL
ONE WINTER STREET
BOSTON, MASSACHUSETTS 02108
PROPOSED AMENDMENTS TO
REGULATION 310 CMR 7.00 & 7.12
FOR
THE CONTROL OF AIR POLLUTION
IN THE
BERKSHIRE AIR POLLUTION CONTROL DISTRICT
CENTRAL MASSACHUSETTS AIR POLLUTION CONTROL DISTRICT
MERRIMACK VALLEY AIR POLLUTION CONTROL DISTRICT
METROPOLITAN BOSTON AIR POLLUTION CONTROL DISTRICT
PIONEER VALLEY AIR POLLUTION CONTROL DISTRICT
SOUTHEASTERN MASSACHUSETTS AIR POLLUTION CONTROL DISTRICT
REGULATORY AUTHORITY:
M.G.L. c. 111, Section 142A — 142D
MAY 1983
310 CMR: DEPARTMENT OF ENVIRONMENTAL QUALITY ENGINEERING
7.12 (U) Inspection Certificate, Record Keeping and Reporting
(1) General Applications:
(a) Any person owning, operating, or controlling a facility
described in 310 CMR 7.12(3) through (7) which has been in
operation for at least one year, shall register with the
Department on a form supplied by the Department setting
forth accurately such information as the Department may
specify including:
1. the nature and amounts of emissions from the facility,
2. information which may be needed to determine the nature
and amounts of emissions from the facility, and
3. any other information pertaining to the facility which
the Department requires.
(b) The information required by 310 CMR 7.12(1)(a) shall be
submitted annually for any major stationary source and once
every three years for all other facilities. After
verification by the Department of the information submittd
by an applicant, and after compliance with 310 CMR 7.12(2),
the Department will issue to the facility an inspection
certificate. An affected facility shall apply for renewal
of its inspection certificate prior to the termination date
of its existing inspection certificate.
(c) Upon verification of the information required by 310
CMR 7.12(1)(a) the Department will review the supplied
information. All such emissions data shall be available to
the public during normal working hours at the office of the
Division of Air Quality Control and at such other offices as
the Department may specify. Copies of all information
supplied to the Department pursuant to 310 CMR 7.12 shall be
retained by the facility owner or operator for two (2) years
after the date on which the report is submitted.
(2) Inspection fee
(a) Any persons owning, operating or controlling any facility
described in 310 CMR 7.12(1)(a), other than a public facility,
shall make payment to the Commonwealth of Massachusetts of a fee
in an amount established by the Executive Office of
Administration and Finance, in accordance with Chapter 7, Section
3B of the Massachusetts General Laws.
(b) Any person owning, operating or controlling a facility
required to pay a registration fee under 310 CMR 7.12(2)(a) shall
do so within thirty days after written notification by the
Department to pay such fee, or shall be subject thereafter to a
late penalty established by the Executive Office of Administra-
tion and Finance.
310 CMR: DEPARTMENT OF ENVIRONMENTAL QUALITY ENGINEERING
(3) Fossil Fuel Combustion Facilities: Any person having
control of fuel burning facility such as but not limited to a
coal, oil, wood, or gas burner that has a rated input capacity in
excess of three (3) million Btu per hour shall comply with 310
CMR 7.12(1) and (2).
(4) Industrial Facilities: Any industrial facility having the
potential to emit:
1. two (2) tons/yr. of particulate matter,
2. two and one half (2.5) tons/yr. of oxides of sulfur
3. three point six (3.6) tons/yr. of organic material, or
4, four point four (4.4) tons/yr. of nitrogen dioxide shall
comply with 310 CRM 7.12(1) and (2)
(5) Incinerators: Any person having control of a hazardous waste
incinerator or an incineration facility that has a capability_ of
reducing in excess of fifty pounds per hour of waste shall comply
with 310 CMR 7.12(1) and (2).
(6) Any facility which emits an air contaminant subject to the
National Emission Standard for Hazardous Air Pollutants under the
federal Clean Air Act, Section 112, as amended shall comply with
310 CMR 7.12(1) and (2).
(7) The Department may, for the purpose of conducting a
continuing inventory of air pollution source emissions, require
any person owning, operating or controlling an air contamination
source not included in 310 CMR 7.12(3) through (6), to register
such source in accordance with 310 CMR 7..12 (1) and (2).
7.00 Definition:
Facility means any installation or establishment and equipment
associated therewith capable of emissions when all the component
or separate processes are integral or related to the overall
project and the process(es) is located on the same or contiguous
property.
Public Facility means a facility owned, operated or controlled by
the Commonwealth of Massachusetts or any of its cities, towns or
political subdivisions, including districts, counties or any such
entity formed for the purposes of conducting a traditional public
function, such as, but not limited to, fire, safety, water,
sewer, pollution abatement, refuse disposal, light or education.
Excluded from this definition however, is any state, municipal or
regional authority or any privately owned entity which performs a
public function whether or not said entity is regulated by the
Department of Public Utilities and such other facilities as the
Department may determine.
Disk Air Regs (2) - Inspfee
P !7cEI VED
JUN 71983
C''r
OF
HLTH DEPjM
r'd
ANTHONY D. CORTESE, Sc.D.
Commissioner
727-5194
935-2160
Mr. Stefanos J. Loisou
300 Raleigh Tavern Lane
North Andover, MA 01845
Dear Mr, Loisou:
ie ooi�ziiroiur�ecc��� �� ��Lrzl.�ac�irese��
e/G'��i.C�GOL/-/an ✓Uad/o2 - �I�i°/�r?.9/ �e�eO�r
,
July 20, 1983
RFCEj�p�r E:D
'JUL 28 1983 Re: SALEM -Old Tannery Building
Corner of Tremont Place and
CITY OF �" LEM1i' Irving Street -Improper Storage
HEALTH DF -PT. of Hazardous Waste
In response to a request by the Salem Building Inspector, engineers from
the Department of Environmental Quality Engineering have undertaken a
preliminary investigation to determine if a former tannery building located
at the corner of 3 Tremont Place and 36-40 Irving Street, Salem, Massachusetts
is in violation of the Massachusetts hazardous waste storage regulations.
Information available to the Department indicated that you are the owner
of this property and thus the responsible party. The building in question
contains a number of unmarked 55 gallon drums and a large, open vat approximately
half full of liquid. A preliminary investigation with portable field instrumentation
indicated these unidentified barrels contain volatile organic materials,
probably organic solvents. Additionally, open corrugated drums were also
observed containing old leather scraps and other solid waste debris.
Volatile organic vapors were also detected emanating from beneath a wooden
grate located outside the building near Irving Street. It is presumed that this
grate conceals an opening for an underground storage tank that could contain
organic solvents or fuels.
The Department has concluded that, based upon these preliminary findings,
these waste materials are being stored in violation of M.G.L. Chapter 21E,
the "Massachusetts Oil and Hazardous Materials Release Prevention and Response
Act", and M.G.L. Chapter 21C, the " Massachusetts Hazardous Waste Management
Act", specifically the Hazardous Waste Regulations (310 CMR 30.000). Therefore,
within two weeks of your receipt of this letter, please notify this office of your
plans to remedy this situation. You must include in your response information
pertaining to the quantity,and chemical composition of the waste and a',time table
for your actions which willtlead to the removal of any hazardous waste from the
property. Be advised that all hazardous waste must be removed by a licensed
hazardous waste disposal firm.
Stefanos J. Loisou
July 20, 1983
Page 2
If you have any further questions regarding this matter, please
contact John Fitzgerald or Margo Thornton of my staff at 935-2160.
Very truly yours
CA
Richard J. Cha in
Deputy Regiona Environmental Engineer
RJC/JF/MT/ac
cc: William F. Cass, Director, Division of Hazardous Waste, One Winter St.Boston,MA.02'
Richard Macintosh, Building Inspector, One Salem Green, Salem, Mass. 01971
Robert Blenkhorn, Board of Health, One Broad Street, Salem, Mass. 01971