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2008 BOH LETTER TO MEPA )a t.�TTG-t —Ia.• � � - Q Zoog') July 9, 2008 Massachusetts Executive Office of Environmental Affairs MEPA Office 100 Cambridge Street, Suite 900 Boston, MA 02114 Attn.: Mr. Richard Bourre Acting Director Re: City of Salem-Transfer Station Expansion Environmental Notification Form-Public Comment Dear Mr. Bourre, As you know, the Salem Board of Health will be asked to act on an application to increase the amount of solid waste permitted at the Salem Transfer Station from 100 to 400 tons per day. The original approval of this site as an incinerator was given by the Board of Health in 1960. At that time, Swampscott Road had very few businesses or nearby residents and there was a minimal review process. Now there are several residents within 500 feet, more businesses including a multi-pump gas station, and the proposition of changing from a mainly C&D/Commercial Solid Waste facility to a mixed C&D/MSW/Commercial Solid Waste facility. After reviewing the ENF submitted by the City of Salem/Northside Carting, the Salem Board of Health has several questions regarding: the proposed size of the expanded transfer station; the building design; 1 waste water generation; and traffic data which effects the traffic impact study, the draft air-quality study, and the noise study. Is this project subject to an EIR pursuant to Section 11.03 (9) (a) of the MEPA regulations because it will create new capacity of 150 or more tpd for processing and disposal of solid waste? Is this project using industrial revenue bonds so that the Board of Health and DEP would not be able to rescind the permit for any reason? As a reference to best practice, the Board used EPA's "Waste Transfer Stations: A Manual for Decision-Making", June 2002. ENF Size of Project, pg. 2 The stated gross square footage of the proposed building is 7500sf. Best practice, according to EPA, uses this useful exercise in calculating how much tipping floor space a facility would require to store a full day's waste in case of extreme emergency. 4,000sq.ft + (400 TPD x 20sq. ft/ton) = N 4,000sq.ft+8,000= 12,000sq. ft needed tipping floor vs. Proposed tipping floor 5,328 SF According to the EPA, a 400 TPD facility would require 12,000 sq. ft tipping floor. The total size of this proposed building is half the size of the EPA's recommended size of a tipping floor for a 400 TPD facility. As stated in ENF Attachment H Letter from City Solicitor dated 9/13/07, the TPD can be as high as 500 TPD. A 500 TPD tipping floor calculation would need to be 14,000 sq. ft. Best Practice calls for a building with a minimum of 35,000 to 40,000 sq. ft to accommodate 400-500 TPD. Additionally, a building less than 10,000 SF allows this project to bypass the usual review by the City's Planning Board and the resultant protections for the immediate sensitive receptors and the community along the truck route. 2 Although, mentioned in the ENF pg.6 is the City's Design and Review Board (DRB), DRB's concentration is the design of a building, not parking, traffic flow etc. while the Planning Board looks at all aspects of a project. The BOH is not aware of any project outside of downtown that necessitated the review by the DRB and not the Planning Board. ENF Construction of New Transfer Station pg. 3 When looking at the Attachment J Progress Set of Drawings A4.1 the dimensions of the proposed building are 97'8"x 7416" 98x75=7350SF. This is 150 SF less than the stated 7500 SF building. Every SF for this type of project is essential. It states "thero osed new transfer station will include an enclosed p p metal building". An enclosed building with this SF can only occur 9 9 Y when the facility is not operational. During operation the two garage doors will be open which will generate odors, litter, dust, noise, and vectors which will have an impact on the surrounding neighborhood and streets. Design of an urban transfer station needs to employ a combination of planning, design, and operating practices to help minimize impacts upon the surrounding community. A residential area is within 235 ft of this proposed transfer station and a Day Care play yard is within 518.75 ft. It was stated at the Conservation Commission public hearing that NSC is intending to do a land exchange with the adjacent property owner which will then extend the sensitive receptors margin to include 8 more residential dwellings. To protect sensitive receptors, design may require roll-up doorways that would only be opened to allow trucks to enter and exit. 3 Noise The Noise report states that back-up alarms will not operate continuously during the day. However, given the small size of the building, the trucks will need to maneuver forward and backward continuously during their operation, resulting in frequent backing up. The report states that a "pure tone" condition will be created. Will this condition cause a noise nuisance for the closest residents? Odor The plan calls for a composting area. Will this include windrows so that odor nuisances will be avoided? Direct Dump Design Will trucks pull into the building and directly dump into waiting transfer trucks below or will there be sorting and recycling? In the Noise Impact Assessment Study, the transfer station is referred to as a "recycling facility" with "front-end loaders used to move materials, occurring inside the tipping floor." However, elsewhere there is a direct dumping description. Sorting, recycling, or segregating may call for a larger tipping floor and building. Is segregating and sorting required as part of the waste ban? The EPA delineates some concerns regarding the disadvantages of direct dump into transfer vehicle as follows: -Transfer station cannot accept waste unless a trailer is positioned to receive waste. (shortage of empty trailers shuts down facility). -No short term storage (surge capacity) to accommodate peak inflow periods causing long customer queuing can be expected during peak inflow periods. -Relatively low payloads in trailers. -Fall hazard -Limited ability to screen and remove unacceptable waste. 4 -No opportunity for waste diversion or materials recovery -Trailer can be damaged by direct dumping of heavy materials, therefore causing long customer queuing. It is important that these concerns be addressed prior to construction with solutions outlined in the application. ENF Traffic pg. 2 External The Traffic Impact and Access Study (Vanasse & Associates, Inc. 12/2007) - pg, 15 states: " Based on information provided by Northside Carting, the proposed expansion is expected to result in an additional 54 vehicle trips on a average weekday over existing conditions, with 6 additional vehicle trips during both the weekday am & pm peak hours. The majority of these trips will be trucks and of the same composition (type & size) as those currently servicing the facility." The stated average Weekday Daily total trips are 140 This number is not consistent with what NSC has reported to the DEP. In addition there is no comparison to the type of vehicles that are currently using this site to the type of vehicles which will be using this site after this proposed expansion. ENF Attachment H Letter from City Solicitor under traffic Ms. Rennard states "...due to the size of the current vehicles that utilize the transfer station (cars, pickups and small dump)". Currently there are no 10-12 ton diesel trash trucks entering/exiting the site, nor are there 48 21 ton load diesel trucks entering/exiting this site. Currently the transfer station only accepts C&D and yard waste, averaging 65 TPD (see scale records below). With the expansion, this transfer station will be accepting C&D, MSW and yard waste, averaging 400-500 TPD. 5 In order to safely facilitate the transfer of 400-50OTPD the number of 12-21 ton vehicles is obtained by using the following calculation: Rear Loadinq Garbage Compacter Collection Truck - averages 10-12 tons of trash/per truck - based on 12 ton load 450 TPD _ 12 ton load = 38 trips or 76 round trips 500 TPD = 12 ton load = 42 trips or 84 round trips 18 wheel Hauling truck averages 21 tons/ truck - based on a 21 ton load 500 TPD = 21 ton load = 24 trips or 48 round trips (60-70 foot diesel trucks) 400 TPD = 76 collection trips + 48 hauling trips = 124 total combined Diesel truck trips. This number seems low compared to the 340 trips anticipated at a North Andover Transfer Station with a 650 tpd capacity. 124 =8 = 16 truckseve er hour 3.75 minutes truck P every entering/exiting site 500 TPD = 84 collection trips + 48 hauling trips = 132 total combined Diesel truck trips 132 = 8 = 17 trucks per hour every 3.5 minutes truck is entering/exiting site This is not including the small vehicles (1 ton) that could equal 50 trips per day It is best to project maximum volumes. 6 The following are NSC's scale records on file at the DEP (public information) 2006---51 .6 TPD 2005---74 TPD 2004---72 TPD 2003---73 TPD Even though the transfer station is permitted for 100 TPD it has not reach this figure in the past 5 or greater years. Currently, this facility may be better defined as a community convenience center. No portion of its waste is directly from collection vehicles. Consequently, an increase from an average of 65 TPD to 400-500 TPD is a 700% increase in activity at this site and a 700% increase in the type of heavy truck traffic in the immediate area where there are >40 sensitive receptors. Swampscott Road is a 2 lane road with no room to be expanded. A slight back up in queuing on site could cause trucks to block this 2 lane road and negatively impact an already congested intersection. Re-timing of the lights will not produce an increase in the flow of traffic in this situation. The above calculations for a 400-500 TPD describes the entering/exiting of one of these 12-21 ton trucks (with lengths of 30- 70 it every 3.75-3.5 minutes. As a result, if there is even a slight delay in the flow (at the tipping floor or scale area or a rejected load) this will force the queuing of these trucks to back up onto Swampscott Road causing severe traffic back up of traffic onto Rt. 107 and surrounding neighborhoods. Consequently, the Board questions the information in this traffic report regarding the type and number of heavy diesel trucks using the facility before and after the expansion. It is vitally important that the conclusions in the traffic study are sound since the air quality and noise studies are based upon the numbers in the traffic study. The accuracy of models to predict effects on traffic and air quality are dependent upon an accurate traffic study. 7 Internal Traffic The Boards concerns relevant to internal traffic is the safety of the individuals using this site to dispose of their yard waste and using the same tipping floor as the commercial vehicles. Yard waste disposal will be located in back of the property, the portion of the site west of the Forest River. The road leading to this portion of the property will also be the same road traveled by the 70 ft. 18 wheeled 21 ton diesel trucks. This road according to the scale provided is approximately 15" wide. Any snow or debris on the ground would lessen this width. The EPA recommends that public unloading areas (tipping floor) and traffic be kept separate from commercial vehicles for safety and efficiency. ENF FIGURE-Proposed Site Plan There is only one entrance and exit for both small cars and trucks and the 12-21 ton trucks to use. The commingling of these entities raises safety questions. The north exit should have little use due to the trucks having to be re-weighed on exiting. The EPA recommends that it is best to project maximum volumes. This plan also shows little queuing space on site during peak hours for 400-500 TPD and does not mention an off site waiting area. This plan indicates that within 100 ft. of the north (exit only) driveway is an enter/exit driveway for an adjacent very busy 12 pump gas station and drive through bank. Could these be easily obstructed by trucks if there is a slight delay in the transfer process? ENF Attachment D Fact Sheet Pa.4 States Option 4 includes a construction of a new salt barn. The Board believes this to be outdated information. Its present proposed use is for yard waste. s ENF Solid and Hazardous Waste Section-Pa. 14 D. If the project involves demolition, do any of the buildings to be demolished contain asbestos? NO ENF Attachment I Additional Information Conservation Commission pq.2 Question: Have the building materials, ash and other "suspect" materials inside the incinerator building and stack been sampled for hazardous residuals? Answer: The primary contaminants of concern include: asbestos containing building materials (roofing materials, wall panels, gaskets, duct insulation, mastics and floor tiles). Inappropriate handling and disposal of this asbestos concerns the Board given all the research and data on mesothelioma. ENF Water/Wastewater pg.2 GPD wastewater generation/treatment: Left blank There will be or should be other sources of waste water other than from storm water run off from the following locations: -Waste water from the handling of dust from vehicles and waste handling operations appeared to be omitted. -C&D generates more dust than MSW and therefore all trucks should be washed before they leave the transfer station to remove dust-generating dirt and debris. -Waste water from a misting system over the tipping floor area to knock down dust particles. -Waste water generated from daily washing down of the tipping floor to decrease odors. 9 I Air Quality Modeling Report Prepared by Epsilon Associates, Inc. May, 2008 Pg. 2-1 states an air quality dispersion modeling was conducted for the existing and proposed truck volumes with NSC. Presently only cars and small trucks enter this site. With this proposed expansion predominantly 10- 21 ton vehicles will be using Y the facility. Figure 1 illustrates an out dated aerial view of the proposed site. In the spring of 2007 adjacent to the transfer station a busy 12 pump gas station opened. Even with vapor recovery systems, VOC's may be emitted from this multi-pump gas station. This would negatively affect the ambient air quality in the immediate vicinity of the transfer station and surrounding area. Pg. 2-2 states it used the most recent data obtained from EPA AIRS database for the years 2004-2006, however this data was collected prior to the opening in 2007 of the adjacent gas station. The Board's concern is the combination of the gas station's emissions of VOC's; emissions from heavy routine traffic; methane emissions from the land cap; the commuter rail train; a nearby junk/auto salvage yard; Aggragate Industries; and Salem Hospital. These are in addition to the transfer station's external traffic emissions of particulates, carbon monoxide, other gases, airborne microbes, dust, etc on the air quality in the surrounding area which are not reflected in the air quality report. Health Impacts in Salem According to the Massachusetts Department of Public Health, the number of emergency room visits for asthma in 2005 by Salem residents exceeded that by Massachusetts residents as a whole by almost 12%. 10 In addition, the prevalence of Lung and Bronchus Cancer in Salem men between 2000 and 2004 was 25% greater than that experienced by men as a whole in the state. Approximately one mile from the proposed transfer station these 124-132 (non-retrofitted) heavy diesel trucks pass by high school, elementary school, and junior high school yards where the most vulnerable of all the sensitive receptors (children) recreate, breathing deeply and rapidly as they partake in sports and play. Thank you for the opportunity to comment on this important project that is currently before the Massachusetts Executive Office of Environmental Affairs and will be before the City of Salem's Board of Health soon. Regards, For the City of Salem Board of Health as voted on July 8, 2008, Paulette Puleo Chairperson Cc: Mayor Kimberley Driscoll Aisling Eglington 11 July 9, 2008 Massachusetts Executive Office of Environmental Affairs MEPA Office . 100 Cambridge Street, Suite 900 Boston, MA 02114 Attn.: Mr. Richard Bourre Acting Director Re: City of Salem-Transfer Station Expansion Environmental Notification Form-Public Comment i Dear Mr. Bourre, As you know, the Salem Board of Health will be asked to act on an application to increase the amount of solid waste permitted at the Salem Transfer Station from 100 to 400 tons per day. The original approval of this site as an incinerator was given by the-Board of Health in 1960. At that time, Swampscott Road had very few businesses or nearby residents and there was a minimal review process. Now there are several residents within 500 feet, more businesses including a multi-pump gas station, and the proposition of changing from a mainly C&D/Commercial Solid Waste facility to a mixed C&D/MSW/Commercial Solid Waste facility. After reviewing the ENF submitted by the City of Salem/Northside Carting, the Salem Board of Health has several questions regarding: the proposed size of the expanded transfer station; the building design; I waste water generation; and traffic data which effects the traffic impact study, the draft air-quality study, and the noise study. Is this project subject to an EIR pursuant to Section 11 .03.(9) (a) of the MEPA regulations because it will create new capacity of 150 or more tpd for processing and disposal of solid waste? Is this project using industrial revenue bonds so that the Board of Health and DEP would not be able to rescind the permit for any reason? As a reference to best practice, the Board used EPA's "Waste Transfer Stations: A Manual for Decision-Making", June 2002. ENF Size of Project, pg. 2 The stated gross square footage of the proposed building is 7500sf. Best practice, according to EPA, uses this useful exercise in calculating how much tipping floor space a facility would require to store a full day's waste in case of extreme emergency. 4,000sq.ft + (400 TPD x 20sq. futon) = N 4,000sq.ft+8,000= 12,000sq. ft needed tipping floor vs. Proposed tipping floor 5,328 SF According to the EPA, a 400 TPD facility would require 12,000 sq. ft tipping floor. The total size of this proposed building is half the size of the EPA's recommended size of a tipping floor for a 400 TPD facility. As stated in ENF Attachment H Letter from City Solicitor dated 9/13/07, the TPD can be as high as 500 TPD. A 500 TPD tipping floor calculation would need to be 14,000 sq. ft. Best Practice calls for a building with a minimum of 35,000 to 40,000 sq. ft to accommodate 400-500 TPD. Additionally, a building less than 10,000 SF allows this project to bypass the usual review by the City's Planning Board and the resultant protections for the immediate sensitive receptors and the community along the truck route. 2 I .6 is the City's Desi Although, mentioned m the ENF pg n and y g Review Board (DRB), DRB's concentration is the design of a building, not parking, traffic flow etc. while the Planning Board looks at all aspects of a project. The BOH is not aware of any project outside of downtown that necessitated the review by the DRB and not the Planning Board. ENF Construction of New Transfer Station pg, 3 When looking at the Attachment J Progress Set of Drawings A4.1 the dimensions of the proposed building are 97'8"x 74'6" 98x75=7350SF. This is 150 SF less than the stated 7500 SF building. Every SF for this type of project is essential. It states "the proposed new transfer station will include an enclosed metal building". An enclosed building with this SF can only occur when the facility is not operational. During operation the two garage doors will be open which will generate odors, litter, dust, noise, and vectors which will have an impact on the surrounding neighborhood and streets. Design of an urban transfer station needs to employ a combination of planning, design, and operating practices to help minimize impacts upon the surrounding community. A residential area is within 235 ft of this proposed transfer station and a Day Care play yard is within 518.75 ft. It was stated at the Conservation Commission public hearing that NSC is intending to do a land exchange with the adjacent property owner which will then extend the sensitive receptors margin to include 8 more residential dwellings. To protect sensitive receptors, design may require roll-up doorways that would only be opened to allow trucks to enter and exit. 3 Noise The Noise report states that back-up alarms will not operate continuously during the day. However, given the small size of the building, the trucks will need to maneuver forward and backward continuously during their operation, resulting in frequent backing up. The report states that a "pure tone" condition will be created. Will this condition cause a noise nuisance for the closest residents? Odor The plan calls for a composting area. Will this include windrows so that odor nuisances will be avoided? I Direct Dump Design Will trucks pull into the building and directly dump into waiting transfer trucks below or will there be sorting and recycling? in the Noise Impact Assessment Study, the transfer station is referred to as a "recycling facility" with "front-end loaders used to move materials, occurring inside the tipping floor." However, elsewhere there is a direct dumping description. Sorting, recycling, or segregating may call for a larger tipping floor and building. Is segregating and sorting required as part of the waste ban? The EPA delineates some concerns regarding the disadvantages of direct dump into transfer vehicle as follows: -Transfer station cannot accept waste unless a trailer is positioned to receive waste. (shortage of empty trailers shuts down facility). -No short term storage (surge capacity) to accommodate peak inflow periods causing long customer queuing can be expected during peak inflow periods. -Relatively low payloads in trailers. -Fall hazard -Limited ability to screen and remove unacceptable waste. 4 -No opportunity for waste diversion or materials recovery -Trailer can be damaged by direct dumping of heavy materials, therefore causing long customer queuing. It is important that these concerns be addressed prior to construction with solutions outlined in the application. ENF Traffic pg. 2 External The Traffic Impact and Access Study (Vanasse & Associates, Inc. 12/2007) - pg, 15 states: " Based on information provided by Northside Carting, the proposed expansion is expected to result in an additional 54 vehicle trips on a average weekday over existing conditions, with 6 additional vehicle trips during both the weekday am & pm peak hours. The majority of these trips will be trucks and of the same composition (type & size) as those currently servicing the facility." The stated average Weekday Daily total trips are 140 This number is not consistent with what NSC has reported to the DEP. In addition there is no comparison to the type of vehicles that are currently using this site to the type of vehicles which will be using this site after this proposed expansion. ENF Attachment N Letter from City Solicitor under traffic Ms. Rennard states "...due to the size of the current vehicles that utilize the transfer station (cars, pickups and small dump)". Currently there are no 10-12 ton diesel trash trucks entering/exiting the site, nor are there 48 21 ton load diesel trucks entering/exiting this site. Currently the transfer station only accepts C&D and yard waste, averaging 65 TPD (see scale records below). With the expansion, this transfer station will be accepting C&D, MSW and yard waste, averaging 400-500 TPD. s In order to safely facilitate the transfer of 400-50OTPD the number of 12-21 ton vehicles is obtained by using the following calculation: Rear Loading Garbage Compacter Collection Truck - averages 10-12 tons of trash/per truck - based on 12 ton load 450 TPD + 12 ton load = 38 trips or 76 round trips 500 TPD + 12 ton load = 42 trips or 84 round trips 18 wheel Hauling truck averages 21 tons/ truck based on a 21 ton load 500 TPD + 21 ton load = 24 trips or 48 round trips (60-70 foot diesel trucks) 400 TPD = 76 collection trips + 48 hauling trips = 124 total combined Diesel truck trips. This number seems low compared to the 340 trips anticipated at a North Andover Transfer Station with a 650 tpd capacity. 124 +8 = 16 trucks per hour every 3.75 minutes truck entering/exiting site 500 TPD = 84 collection trips + 48 hauling trips = 132 total combined Diesel truck trips 132 = 8 = 17 trucks per hour every 3.5 minutes truck is entering/exiting site This is not including the small vehicles (1 ton) that could equal 50 trips per day It is best to project maximum volumes. 6 The following are NSC's scale records on file at the DEP (public information) 2006---51 .6 TPD 2005--74 TPD 2004---72 TPD 2003---73 TPD Even though the transfer station is permitted for 100 TPD it has not reach this figure in the past 5 or greater years. Currently, this facility may be better defined as a community convenience center. No portion of its waste is directly from collection vehicles. Consequently, an increase from an average of 65 TPD to 400-500 TPD is a 700% increase in activity at this site and a 700% increase in the type of heavy truck traffic in the immediate area where there are >40 sensitive receptors. Swampscott Road is a 2 lane road with no room to be expanded. A slight back up in queuing on site could cause trucks to block this 2 lane road and negatively impact an already congested intersection. Re-timing of the lights will not produce an increase in the flow of traffic in this situation. The above calculations for a 400-500 TPD describes the entering/exiting of one of these 12-21 ton trucks (with lengths of 30- 70 " every 3.75-3.5 minutes. As a result, if there is even a slight delay in the flow (at the tipping floor or scale area or a rejected load) this will force the queuing of these trucks to back up onto Swampscott Road causing severe traffic back up of traffic onto Rt. 107 and surrounding neighborhoods. Consequently, the Board questions the information in this traffic report regarding the type and number of heavy diesel trucks using the facility before and after the expansion. It is vitally important that the conclusions in the traffic study are sound since the air quality and noise studies are based upon the numbers in the traffic study. The accuracy of models to predict effects on traffic and air quality are dependent upon an accurate traffic study. 7 Internal Traffic The Boards concerns relevant to internal traffic is the safety of the individuals using this site to dispose of their yard waste and using the same tipping floor as the commercial vehicles. Yard waste disposal will be located in back of the property, the portion of the site west of the Forest River. The road leading to this portion of the property will also be the same road traveled by the 70 ft. 18 wheeled 21 ton diesel trucks. This road according to the scale provided is approximately 15" wide. Any snow or debris on the ground would lessen this width. The EPA recommends that public unloading areas (tipping floor) and traffic be kept separate from commercial vehicles for safety and efficiency. ENF FIGURE-Proposed Site Plan There is only one entrance and exit for both small cars and trucks and the 12-21 ton trucks to use. The commingling of these entities raises safety questions. The north exit should have little use due to the trucks having to be re-weighed on exiting. The EPA recommends that it is best to project maximum volumes. This plan also shows little queuing space on site during peak hours for 400-500 TPD and does not mention an off site waiting area. i This plan indicates that within 100 ft. of the north (exit only) driveway is an enter/exit driveway for an adjacent very busy 12 pump gas station and drive through bank. Could these be easily obstructed by trucks if there is a slight delay in the transfer process? ENF Attachment D Fact Sheet pg.4 States Option 4 includes a construction of a new salt barn. The Board believes this to be outdated information. Its present proposed use is for yard waste. 8 ENF Solid and Hazardous Waste Section pg. 14 D. If the project involves demolition, do any of the buildings to be demolished contain asbestos? NO ENF Attachment I Additional Information Conservation Commission pg.2 Question: Have the building materials, ash and other "suspect' materials inside the incinerator building and stack been sampled for hazardous residuals? Answer: The primary contaminants of concern include: asbestos containing building materials (roofing materials, wall panels, gaskets, duct insulation, mastics and floor tiles). Inappropriate handling and disposal of this asbestos concerns the Board given all the research and data on mesothelioma. ENF Water/Wastewater pg.2 GIRD wastewater generation/treatment: Left blank There will be or should be other sources of waste water other than from storm water run off from the following locations: -Waste water from the handling of dust from vehicles and waste handling operations appeared to be omitted. -C&D generates more dust than MSW and therefore all trucks should be washed before they leave the transfer station to remove dust-generating dirt and debris. -Waste water from a misting system over the tipping floor area to knock down dust particles. -Waste water generated from daily washing down of the tipping floor to decrease odors. 9 Air Quality Modeling Report Prepared by Epsilon Associates, Inc. May, 2008 Pg. 2-1 states an air quality dispersion modeling was conducted for the existing and proposed truck volumes with NSC. Presently only cars and small trucks enter this site. With this proposed expansion predominantly 10- 21 ton vehicles will be using the facility. Figure 1 illustrates an out dated aerial view of the proposed site. In the spring of 2007 adjacent to the transfer station a busy 12 pump gas station opened. Even with.vapor recovery systems, VOC's may be emitted from this multi-pump gas station. This would negatively affect the ambient air quality in the immediate vicinity of the transfer station and surrounding area. Pg. 2-2 states it used the most recent data obtained from EPA AIRS database for the years 2004-2006, however this data was collected prior to the opening in 2007 of the adjacent gas station. The Board's concern is the combination of the gas station's emissions of VOC's; emissions from heavy routine traffic; methane emissions from the land cap; the commuter rail train; a nearby junk/auto salvage yard; Aggragate Industries; and Salem Hospital. These are in addition to the transfer station's external traffic emissions of particulates, carbon monoxide, other gases, airborne microbes, dust, etc on the air quality in the surrounding area which are not reflected in the air quality report. Health Impacts in Salem According to the Massachusetts Department of Public Health, the number of emergency room visits for asthma in 2005 by Salem residents exceeded that by Massachusetts residents as a whole by almost 12%. 10 In addition, the prevalence of Lung and Bronchus Cancer in Salem men between 2000 and 2004 was 25% greater than that experienced by men as a whole in the state. Approximately one mile from the proposed transfer station these 124-132 (non-retrofitted) heavy diesel trucks pass by high school, elementary school, and junior high school yards where the most vulnerable of all the sensitive receptors (children) recreate, breathing deeply and rapidly as they partake in sports and play. Thank you for the opportunity to comment on this important project that is currently before the Massachusetts Executive Office of .. Environmental Affairs and will be before the City of Salem's Board of Health soon. Regards, For the City of Salem Board of Health as voted on July 8, 2008) Paulette Puleo Chairperson Cc: Mayor Kimberley Driscoll Aisling Eglington 1�