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2008 LETTER TO MEPA FROM BETA GROUP Norwood Park r Group, Inc. 315Norwood,MA 2 62 t (781)255.1982,fax(781)255-1974 Engineers • Scientists a Planners www.BETA-Inacom July 24, 2008 Mr.Richard Bourre,Acting Director Massachusetts Executive Office of Environmental Affairs MEPA Office 100 Cambridge Street, Suite 900 Boston, Massachusetts 02114 Attn.: Mr. Richard Bourre Acting Director Re: Supplemental Information to Environmental Notification Form Salem Transfer Station& Landfill Closure Project Swampscott Road, Salem, MA Dear Mr. Bourre: The following questions and comments were posed by members of the MassDEP Northeast Regional Office, Salem Planning Board, and City Council in response to the Environmental Notification Form for the referenced project, submitted to MEPA on June 2, 2008. On behalf of Northside Carting, Inc. and the City of Salem, we have provided the following responses in bold. text. Questions are answered in the order received by MEPA. I—July 9th Letter received from the Salem Board of Health I-1: Will the project require an EIR pursuant to Section 11 03 (9)(a)of the MEPA regulations because the capacity will increase to greater than 150 TPD forroD cessing and disposal of solid waste? Since the project is a transfer station, it is exempt from a categorical EIR under the regulations at Section 11.03 (9) (a). I-2: Are industrial revenue bonds being used so the Board of Health and DEP will not be able to retract the permit? At this time,no industrial bonds and/or state assisted funding have been arranged. If such public funding is arranged and MEPA regulations require the filing of a Notice of Project Change,the Project Proponents are committed to filing such public notice. I Mr.Richard Bourre,Acting Director July 23, 2008 Page 2 of 8 I-3: The stated tipping floor area of the proposed building is 5,328 square feet Based on the proposed capacity, the Best Practice equation calculates that an area of 12,000 square feet would be needed. How will the proposed area be able to handle the increase in capacity Based upon recent discussions with MA DEP representatives,we plan to expand the building size by approximately 2,200 square feet to obtain additional space within the building for operations. The actual square footage of the building is expected to be approximately 9,700 square feet. The square footage of the tipping room floor is estimated to be approximately 7,500 SF. Based upon years of operating experience by Northside personnel, that space is more than adequate to handle the volume of waste projected for the facility. I-4: Why do the Progress Set of Drawings (Attachment J) show building dimensions of 7,350 SF (97'8" x 74'6") when the proposed area is stated as 7,500 SF? The Progress Set of Drawings was provided for review of the building layout and operational concepts. As indicated above, the final square footage of the building is expected to be on the order of 9,700 SF. I-5: Is Northside Carting intending to do a land excbange with the adjacent property owner that wM extend the sensitive receptors margin to include eight more residential dwellings? The City has arranged for a temporary construction agreement with the.adjacent property owner to allow capping of the landfill to be performed. Land swaps will not be required under that access temporary site access arrangement. I-6: The two garage doors will be open during operational hours Will this affect the surrounding area by allowing odor, litter, dust noise and vectors to escape? The building will have misting capabilities and ventilation equipment that will significantly control nuisance conditions. A fore water spray will be used, as required, to knock down any fugitive dust emissions. The ventilation equipment, including exhaust fans and filtration equipment will be operated to help prevent any dust and odors to be emitted from the building by maintaining a negative pressure. Minimal noise impact to surrounding properties is anticipated, based upon results of the Noise Study conducted by Epsilon. 1-7: How do you plan to locate the transfer station so that it minimizes the effects on the surrounding community The transfer station will be located in the least conspicuous area within the boundaries established in 310 CMR 16. The closest residential area is located approximately 650 feet away, and a day care center is located approximately 675 feet away on Greenledge Street, both outside the required 500-foot buffer zone. Furthermore, the transfer station has been oriented to minimize visual and noise impacts to the surrounding area. Reference is made to the Site Plan included in the ENF that shows the location of the transfer station with relationship to the neighboring properties. i Mr.Richard Bourre,Acting Director July 23, 2008 Page 3 of 8 I-8: The noise impact report states that a"pure tone" condition will be created by the truck's back-up alarms Will the frequent backing W cause a noise nuisance for the closest residence? A noise impact study was conducted to determine what effects the expansion would have on the surrounding area. Results of the study showed a 3dB increase at the closest residence,which is well below the DEP maximum allowable increase of 10dB; . however, during station operating hours,nearby residents may detect the pure tone sound from the trucks. We are committed to address this'issue during final design, where we will consider reasonable alternatives for sound attenuation. I-9: Will the composting area include windrows so that excessive odor will be avoided? No composting will be performed at the site. As yard wastes accumulate in the collection area, they will be loaded onto dump trailers and transported off-site to a composting or other processing facility. During periods of high usage,the yard wastes will be shipped daily. During low usage, the yard wastes will not be allowed to accumulate more than one month. I-10: Will trucks pull into the building_and directly dump into waiting transfer trucks or will there be sorting and recycling? In most cases the waste will be dumped on the floor. Any land-banned materials will be segregated for separate off-site management. The waste will then be pushed by a front end loader into the trailers waiting below. I-11: Is segregating and sorting required as part of the waste ban? If sorting recycling or segregating is required is a larger tipping floor and building necessary Segregation of land banned materials will be a requirement in our operating permit. "Sorting" is a processing term, and no sorting will be performed at this location. Only segregation of land banned materials will be performed for separate off-site management. As indicated in the response to I-3, the tipping room floor will be expanded by approximately 2,200 SF beyond the dimensions shown on the concept plans to facilitate tipping floor operations, consistent with recent discussions with DEP representatives. 1-12: What are the average Weekday Daily total trips? Currently, the Average Weekday Daily amount of vehicle trips is 140. The proposed expansion will result in an additional 54 vehicle trips,for an Average Weekday Daily total of 194 vehicle trips. Mr.Richard Bourre,Acting Director July 23, 2008 Page 4 of 8 I-13: What are the differences between the vehicles currently using the transfer station compared with the vehicles that will use the transfer station after the expansion? Currently, the vehicles that use the transfer station include cars, pickup trucks and various size dump trucks. For the proposed facility, vehicles are expected to include cars, pickup trucks, rear-loading garbage compactor collection trucks (-16 tons/truck), and 18-wheel hauling trucks (-20 tons/truck). I-14: Based on calculations for a 400 TPD facility the number of 12-21 ton vehicles was determined to be 104 round trips between collection and hauling trucks This translates to one truck entering/exiting every 4.6 minutes. What effect will this have on surrounding roads? As indicated in the Traffic Study, the impact to traffic over the course of the day is not expected to be significant. The additional rear-loading collection and hauling trucks anticipated due to the expansion would enter/exit the site every 9 minutes. I-15: How will internal traffic be directed so that individuals disposing of yard waste and using the tipping floor are safely out of the way? Is there any way to keep the public unloading ureas and traffic separate from commercial vehicles? The roads on the site will be paved,of sufficient width, and clearly marked to safely accommodate the projected truck and residential traffic. Signage and pavement markings will clearly demarcate lanes for public and commercial vehicles. Further consideration will be given to establishing safe on-site traffic conditions during final design. I-16: Is the salt barn shown in the Fact Sheet in Attachment D currently in the transfer station design? Based upon discussions between City Officials and Northside Carting,no Salt Barn will be constructed on the rear portion of the site, as originally proposed. 1-17: Have the materials for the building that is to be demolished been sampled for hazardous residuals, including asbestos? Yes, a comprehensive pre-demolition inspection has been performed by Smith& Wessel and BETA staff. All hazardous and regulated building material(asbestos, mercury switches, PCB ballasts, lead paint, and other hazardous materials)will be segregated and properly managed off-site prior to demolition of building. Most of the remaining building components will be segregated, sorted, and either configured under the landfill cap, or managed off-site at appropriate reuse/recycle/disposal facilities. i Mr.Richard Bourre,Acting Director July 23, 2008 Page 5 of 8 I-18: What are the sources and projected amounts for waste water other than from storm water run off? All wastewater will be discharged to the City's sanitary sewer,which runs along Swampscott Road. Runoff is anticipated to be on the order of approximately 500 gallons per day. Sources of waste water include wastewater from restroom facilities for use by on-site workers, general housekeeping(washing of the tipping floor and trucks) and a small amount from the misting system used to reduce the amount of fugitive dusts. Questions I-19 through 1-21 reference Epsilon's Air Quality Monitoring Report I-19: Was the modeling performed in this report based on the use of cars and small trucks that are currently using the facility or majnly 10-21 ton trucks proposed to use the facility? The baseline modeling used in the Epsilon report modeled fine and course particulate emissions for existing traffic, including the types of vehicles that currently use the station. For projected use of the new transfer station, the modeling includes the types of vehicles projected to use the station, including the existing and projected vehicles,packer trucks and larger waste hauling trailers. I-20: Figure 1 in the Air Ouality Monitoring Report shows an out of date aerial view, and does not show the 12 pump gas station located on the comer of Highland Avenue and Swampscott Road. How does the gas station affect the air quality in the area immediatUI s=ounding the gas station? Emission controls for volatile organic compounds are present at the existing gas station at the intersection of Route 107 and Swampscott Road. Vapor controls are required at all gasoline dispensers, so that there is limited impact associated with fueling vehicles. I-21: The report states that the most recent data was obtained from EPA AIRS database for the years 2004—2006. Does this data include information collected after the neighboringgas station opened in 2007? The most currently available data was used,which does not include the neighboring gas station. I-22: How will the combination of VOC emissions from the gas station. heavy routine traffic methane emissions from the landfill cam the commuter rail train, nearby junklauto salvage yard Aggregate Industries and Salem Hospital effect the air quality? The assessment is outside the scope of our current assessment. We reviewed the current level of fine and course particulates and volatile organic compounds(VOCs) associated with the current and projected operating scenarios and determined that the impact on human health corresponding to the increased traffic related to the expanded transfer station is negligible. Phase in of new emission controls and W.Richard Bourre,Acting Director July 23, 2008 Page 6 of 8 changes in the formulation of diesel fuel will actually result in reduced air quality impacts. H.—July 15, 2008 letter received from the MassDEP Northeast Regional Office JI-1: Final design plans have not yet been received Is data available to demonstrate the building will be able to handle the proposed capacitv9. As discussed recently with DEP representatives, the proposed transfer station building will be expanded, consistent with current siting regulations, to approximately 9,700 SF. That represents an increase of approximately 2,200 SF to the preliminary design. Based upon years of operating experience by Northside Carting staff, that will afford ample space for the proposed operations. DEP will be reviewing the final construction documents under their permitting regulations. II-2: Will there be enough room for vehicles to be within the building during tipping? See response to prior question. II-3: The Toe of Landfill Cap Detail attached as Figure 5 indicates waste materials exposed along the bank of the Forest River. How will erosion of this material be prevented? Will this design provide adequate stability to the bank? The slope stabilization detail was provided in the ENF and fully discussed with the Conservation Commission during the NOI public hearings. The slope will be stabilized with geotextile fabric to accommodate settlement; dumped rip-rap will be provided to achieve the required stability and protection from erosion. II-4: The storm water management system described in the Storm water Management Report would not be in compliance with the regulations that went into effect January 2008 Are data and calculations available that support the conclusion that the storm water management system would meet the applicable standards? Recently enacted storm water regulations were taken into account in providing our design for storm water treatment during the NOI public hearings. Reference is made to the filing with the Salem Conservation Commission, which details the drainage system layout and water quality control structure. Reference made to storm water report included in the ENE Detailed storm water calculations are available at the Salem Conservation Office located at 93 Washington Street, Salem, MA. II-5: What BMPs will be used to capture and treat the appropriate water quality volume for removal of 80% of Total Suspended Solids (TSS)? Are calculations available that demonstrate TSS,removal by these methods is appropriate? As indicated in the NOI and subsequent submissions to the Conservation Commission, proposed BMPs for the project include street sweeping, deep sump catch basins, and a water quality structure (Stormceptor). Calculations that demonstrate TSS removal are included in the NOI submittal to the Conservation i Mr.Richard Bourre,Acting Director July 23, 2008 Page 7 of 8 Commission and are available at the Salem Conservation Office located at 93 Washington Street, Salem, MA. M.—July 14, 2008 letter received from Charles M. Puleo III-1: Comment: Results from the traffic impact report, air quality report, and noise impact study show that the proposed transfer station expansion would have negligible to no effect on the surrounding areas. The reported findings from these impact studies are based on the most accurate and recent data available. We believe that all of the reports accurately assess the current situation and future traffic projections associated with the proposed expansion of the transfer station. III-2: Comment: Results from the Human Health Risk Characterization Study were not included in the ENF. The proposed transfer station expansion does not significantly increase the potential risk to human health. Even though an assessment of human health is not required under pertinent regulations,we did perform a focused human health risk characterization that evaluated the increased risk to human health associated with expansion of the transfer station. That characterization concluded that the risks to human health are projected to be minimal and that human health risks in the area are actually projected to decrease, due to phase-in of EPA regulations related to mandated changes in diesel fuel formulation and new vehicle emission controls. Furthermore, the-total travel associated with collection and off-site hauling of wastes is expected to decrease, now that a more centrally located transfer station will be available. The net effect to the region will be lower overall diesel fuel emissions. IV.—July 15, 2008 letter received from City of Salem Councilors IV-1: With 450 SF of vegetated wetlands. 3600 SF of land under water, 157,000 SF of riverfront area located on the site, and a 500 unit condominium complex located within 300 feet of the landfill why should an Environmental Impact Report notbbee, r uired? There is no significant impact to either human health or the environment that hasn't already been taken into account. Conversely, there is significant environmental benefit to the environment by closing the landfill, stabilizing the embankment along the river and addressing a long-standing aesthetic issue for area residents. Furthermore, it addresses a long-standing issue with DEP that requires the City to properly close the landfill. IV-II:Concerns regarding negative effects the expansion may have on the surrounding areas The impacts to traffic, air quality and noise have been adequately assessed and appropriate mitigation measures have either been taken into account or will be addressed during final design and facility operations. i i Mr.Richard Bourre,Acting Director July 23, 2008 Page 8 of 8 We trust that these responses adequately address the questions and comments received to date. Please call me with any further questions or concerns, or if we can provide any further information. Very truly yours, BETA Group,Inc. Alan D. Hanscom, LSP Senior Associate cc: Beth Renard,Esq.,City Solicitor David Knowlton,City Engineer Robert George,NSC Bill1homson,Jr.,NSC