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2009 REVIEW OF AIR QUALITY IMPACTS & TRAFFIC STUDY PEER REVIEW MEMORANDUM Tighe&Bond Salem Transfer Station - Review of Air Quality Impacts To: Salem Board of Health THROUGH: Dave A. Murphy, P.E., Peer Reviewer Tighe & Bond FROM: Jeff Bibeau, REM, Tighe & Bond DATE: November 24, 2009 SUBJECT: 2nd Round of Air Quality Review The following is a summary of the comments that were addressed by Epsilon in the original Air Quality review conducted by Tighe & Bond, Inc. in a memo prepared November 5, 2009: 1. Comment #1 - Epsilon used the EPA recommended AERMOD air model in their recent air modeling work. Therefore, this comment was addressed. 2. Comment #2 - Epsilon did address the comment related to whether or not the applicant verified that the particulate monitoring stations were the closest and most representative. However, Epsilon did re-run the air quality model for the increased truck trips of 230 trips per day. 3. Comment #3 - Epsilon did complete the air modeling and air permitting evaluation for the proposed building at the transfer station (stationary source). In addition, the recent air modeling assessment was completed for the residence located at One Dipietro Avenue. We also note the applicant purchased the property at One Dipietro Avenue. 4. Comment #4 - Epsilon did not address any of the miscellaneous issues associated with the applicability of storm water and wastewater discharges permits. This memo includes a peer review of the following reports that were prepared in anticipation of the expansion of the Salem Transfer Station and any potential air quality impacts associated with the expansion: • "Updates to Air Quality Modeling Report for Proposed Salem Transfer Station" prepared by Epsilon Associates, Inc. dated November 18, 2009 • "Updates to Air Quality Modeling Report for Proposed Salem Transfer Station- Revision" prepared by Epsilon Associates, Inc. dated November 20, 2009 • Email from Alan Hanscom (BETA) to David Murphy (Tighe & Bond) Re: Air Quality dated November 20, 2009 Air Quality Review--(Epsilon Air Quality Modeling Reports dated November 18 & 20 2009) Tighe and Bond, Inc. has reviewed the reports entitled "Updates to Air Quality Modeling Report for Proposed Salem Transfer Station" prepared by Epsilon Associates, Inc. dated November 18 & 20, 2009 for Northside Carting, Inc. located in Salem, MA. According to the reports, an air quality dispersion modeling analysis was conducted to assess the potential MEMO Tighe&Bond trips including existing traffic volumes and were compared to ambient air quality standards and DEP air permitting thresholds. The reports included the following revised data: • Increased truck trips to the facility from 194 to 230 with a daily peak of waste material received to 500 tons per day • Increased the transfer station operating days per week from 5 to 5.5 • Included a modeling analysis of the particulate emissions from the transfer station building • Included a Best Available Control Technology (BACT) for a fabric filter particulate control system This review included a review of the references and assumptions that are the basis for the - air quality modeling that was prepared. Emission calculations were also checked. In addition, MADEP's "Guidance for Conducting Facility Impact Assessment for Solid Waste Facility Site Assignment" dated March 22, 2006 was also used as a reference document during this review. Report Review 1. According to MADEP's "Guidance for Conducting Facility Impact Assessment for Solid Waste Facility Site Assignment dated March 22, 2006, total potential emissions of Volatile Organic Compounds (VOCs) sources registered in the Mass DEP SSEIS database must be provided within one-mile of the perimeter of the subject facility. BETA provided VOC emission data from Thermal Circuits, Inc for reporting year 2007 at 6.39 tons per year. Is the 6.39 tons per year actual or potential emission data? The DEP Guidance document requires the VOC data be provided in potential not actual emissions. If the potential VOC emission sources, within one-mile of the transfer station, are below 50 tons of VOCs per year, then no further study is required at this time. 2. In Epsilon's cover letter (paragraph #1) dated November 18, 2009, they reference a Table 5. There is no Table 5. 3. In Epsilon's cover letter (paragraph #2) dated November 18, 2009, they state that in Attachment A, building emissions were 0.58 tons per year for PM-10 and 0.24 tons per year for PM-2.5 after controls. However, page 3 of 4 in Attachment A indicates that emissions from just the dumping/loading/pushing of the waste were 0.64 tons per year for PM-10 and 0.26 for PM-2.5 after controls. It should be noted, that this does not even include the emissions from the idling trucks inside the building. Also, please provide the basis for using 3 hrs/9 hr shift for pushing operations inside the building. 4. In Attachment A page 3 of 4, indicates 51 days/year. It should be 51 weeks/year. -2- I I MEMO Tighe&Bond 5. In Attachment A page 2 of 4, indicates 0.023 lbs/hr uncontrolled PM-2.5 emissions from the dumping action. It should be corrected to 0.033 lbs/hr. 6. According to EPA's AP-42 Emission Factor document, continuously applying a chemical (i.e. surfactants) coupled with a watering operation can reduce particulate emissions up to 90%. It is reasonable to estimate the removal effienciency at 50%, recognizing that the handling operations are conducted indoors at low wind exposure. In addition, other modeling assumption such as the using all C&D waste instead of MSW, particle size multipliers (0.35 for PM-10 and 0.053 for PM-2.5), material moisture content (0.25%), and wind speed (1.3 mph) were all deemed acceptable and appropriate for the air modeling conducted. ]:\W\W3946 City of Salem Peer Review\MEMO\Air-Quality Peer Review 11-24-09.doc -3- f MEMORANDUM Tighe&Bond A Traffic Study Peer Review To: Salem Board of Health THROUGH: Mr. David A Murphy P.E., Peer Reviewer FROM: Mr. Joseph C. Balskus, Director of Traffic and Parking DATE: November 3, 2009 This memorandum will serve as Tighe & Bond's (T&B) assessment of the "Proposed Transfer Station Expansion, Salem Massachusetts", traffic study prepared by the proponent's engineer, Vanasse & Associates, Inc (VAI) dated, December 2007. The following constitutes T&B's independent review and analysis of the submitted materials in support of the application. Study Area The project study area consisting of a total three intersections, which are in the vicinity of the existing site, is an acceptable scope of work for the project. Traffic Analysis The proponent's traffic analysis of the proposed transfer station was prepared using a typical industry standard traffic study format that reviews the existing site conditions and assesses the future traffic impacts associated with the transfer station. The traffic operational analyses of the study area intersections includes level of service (LOS) methodologies using Synchro software, which is a MHD acceptable software for traffic analysis. Proponent Trip Generation and Distribution The existing 100 tons per day facility trip generation had a total of 20 vehicle trips (9 entering and 11 exiting vehicles) during the weekday morning hour and a total of 14 vehicle trips (7 entering and 7 exiting vehicles) during the weekday afternoon evening peak hour. The respective trip generation rates are 0.2 trips per ton and 0.14 trips per ton during the morning and afternoon peak hour periods. The proposed 400 ton per day facility will have a total trip generation of 26 (12 entering and 14 exiting vehicles) during the weekday morning hour and a total of 20 vehicle trips (10 entering and 10 exiting vehicles) during the weekday afternoon evening peak hour. The proposed 400 ton per day facility respective trip generation rate based are at 0.065 trips per ton and 0.05 trips per ton during the morning and afternoon peak hour periods. The proposed 400 ton per day facility has a lower trip generation rate than the existing 100 / ton per day trip generation. The proponent should clarify the trip generation rate discrepancy between the existing facility and the the proposed facility. It should be noted, for comparison purposes, a proposed 750 ton capacity per day solid waste transfer facility in another Massachusetts community, the peak hour site generated traffic impact was estimated to be 28 trips (14 entering and 14 exiting) for each of the MEMO Tighe&Bond <s morning and afternoon peak hours. This other facility's 750 ton per day respective trip generation rates based are at 0.03 trips per for each of the morning and afternoon peak hour periods. The proposed site traffic distribution is based on the existing routes. The distribution appears to be appropriate for the expected truck movements. Intersections Analysis: - The intersection analysis methodology was done in accordance with the typical traffic engineering industry practice and methodology. In the existing conditions, both of the study signalized intersections are operating near their respective capacity and are expected to operate similarly in future "No Build" and "Build" conditions. Assuming the future trip generation rates are correct, the facility related traffic is expected to produce a negligible increase in intersection vehicle delay. Off-Site Mitigation Off-site mitigation improvements include traffic signal retiming and lane use restriping. The proponent identified the retiming of the study area signalized intersections as an improvement measure to optimize traffic signal operations. Pavement marking modifications are proposed at the intersection of Swampscott Road and Highland Avenue. The Swampscott Road northbound roadway movement is proposed to be converted from one exclusive left turn-lane and one right-turn lane to one shared left-turn/right-turn lane and one exclusive right-turn lane. The proposed mitigation is expected to improve the level of service at the two signalized intersections. Conclusion Overall, the traffic study provided by the proponent documented the potential traffic impact by the proposed Facility on the study area roadways and intersections. However, a more detailed explanation of the proposed vehicle trip generation rates is suggested given that the proposed rates are considerably different compared to the existing rates. In addition, the proponent is considering a surge or peak delivery condition of 500 ton per day that should warrant a traffic impact study addressing these peak increases in trips. A detailed explanation and impact assessment of the trip generation should be identified given that cars, light trucks, and trash hauling vehicles are all expected to utilize the site. -2-