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Home My WebLink AboutSludge Compost Facility -NUTT ROMNEY Governor TERRY HEALEY Lieutenant Governor COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE 20 RIVERSIDE DRIVE, LAKEVILLE, MA 02347 508-946-2700 si t. Mr. Kenneth F. Hackett Town of Mansfield 6 Park Row Mansfield, Massachusetts 02048 Dear Mr. Hackett: ...................... i MAY 1 April 30, 2003 ii mo ELLEN ROY HERZFELDER Secretary, EDWARD P. KUNCE Acting Commissioner RE: MANSFIELD--Residuals Approval of Suitability, BRPWP29, 1998, 2001, 2002 and Future Compost Production, Mansfield Sludge Composting Facility, Off Fruit Street, Transmittal No. W035188 In a letter dated March 6, 2003, your consultant, Camp, Dresser & McKee, Inc., acting on behalf of the Town of Mansfield, applied for a Type I classification for compost produced at the Town of Mansfield Sludge Composting Facility in Mansfield, Massachusetts. This composting facility produces compost from wastewater treatment plant sludge generated at the Town of Mansfield Water Pollution Control Facility located in Norton, Massachusetts. An application for an Approval of Suitability (AOS) was filed under Transmittal No. W035188. The product subject to this application was generated in 1998, 2001 and 2002 and is currently stockpiled on -site. In support of this request, chemical analytical results, compost temperature, TCLP results, and organic results were submitted to the Department. The application contained the following supporting documentation: 1. Temperature monitoring data for the active compost piles. 2. Eight sets of laboratory test data representing three years of ongoing compost processing. This data represents the appropriate sampling frequency in accordance with 310 CMR 32.13(6) and the approved sampling and analysis plan. This test data includes parameters listed in 310 CMR 32.13(5)(a) as well as organic parameters and TCLP (Toxicity Characteristic Leaching Procedure) results. The Department has reviewed the information submitted and has concluded that composting has been conducted in accordance with the operation plan previously approved by the Department and that sampling, analysis and reporting has successfully been completed pursuant to the requirements of 310 CMR 32.00. Also, as a result of its review, the Department has made the following determinations: This information is available in alternate format Call Aprel McCabe, ADA Coordinator at 1-617-556-1171. TDD Service- 1.800-298-2207. DEP on the World Wide Web: hUp://v .mass.gov/dep 0 Printed on Recycled Paper 2 1. All analyses have been conducted in accordance with the sampling and analysis plan approved by the Department on December 11, 1997. 2. Sufficient data records have been submitted to allow the Department to classify the compost sludge. 3. TCLP test data has demonstrated that the compost is non -hazardous pursuant to 310 CMR 30.00. Temperature data obtained from the compost piles for which the Type I approval is being sought have demonstrated that PFRP (Processes to Further Reduce Pathogens) requirements have been met utilizing a static aerated pile, high temperature composting process. 5. Results of all bulk analysis of compost for the land application parameters have been reported appropriately and the final product meets the criteria for Type I as set forth in 310 CMR 32.12. The Department has completed its review of the application and hereby grants Type I approval for the sludge based product produced at the Mansfield, Massachusetts Sludge Composting Facility during 1998, 2001 and 2002 and stockpiled at this facility; and for continuing production of sludge based product from the date of this approval for a period of not more than two (2) years. No other materials are subject to this approval. Pursuant to 310 CMR 32.11 (4), this approval shall be valid for no more than two (2) years from the date of this letter subject to the following terms and conditions: In discussions with the Town relative to utilization of the classified compost, the Town indicated that a vendor will be the primary user of the Type I compost. The Town also indicated that there could be other potential users of the Type I compost. For all distribution, the Town shall comply with the labeling and other requirements of 310 CMR 32.51, "Requirements for sale or distribution of Type I sludge/compost", which states: a) No person shall sell or distribute, or offer for use, sale, or distribution any Type I sludge/compost unless, pursuant to 310 CMR 32.00, the Department has approved such sludge/compost as Type I sludge/compost and that approval is valid at the time the Type I sludge/compost is sold or distributed, or offered for use, sale, or distribution. b) No person shall obtain Type -I sludge/compost unless such sludge/compost has a valid approval of suitability. c) Labeling of I-ype, 141n ge/C omnogt. Each container in which Type I sludge/compost is sold, distributed, or transported or offered for use, sale, or distribution shall itself prominently display or, if such display is not practicable, shall be accompanied by a shipping paper which shall prominently display the following: i) identification of the material as Type I sludge (compost). ii) the date of issuance of the Department Approval of Suitability for the Type I sludge/compost and the expiration date thereof. iii) instructions for land applying the material in accordance with proper agricultural practice, including, but not limited to, identification of proper agronomic application rates which shall not cause exceedance of the nitrogen requirements of the crop to be grown or intended to be grown. iv) Type I sludge/compost containing more than 10 parts per million of molybdenum shall be accompanied by a written warning that the sludge should not be used on pasture lands subject to grazing or on lands where crops are grown or intended to be grown for forage. Use of the sludge/compost under these circumstances may result in forage crops containing levels of molybdenum which are toxic to ruminants. v) all other instructions and information required by law. 2. RecodKeepin , The Town shall comply with all the record keeping requirements of 310 CMR 32.60, including the submission to the Department of an annual report pursuant to section 32.60(2)(c) which shall be due on February 1 of the calendar year following the date the Department issued the approval of suitability. 3. Should the consistency of, or type of, amendment used in the composting process change, then the Department shall be notified and additional steps may be required to ensure that the handling and distribution of the final compost product does not create a nuisance. 4. Continue to perform sampling, analysis and monitoring of the compost on an on -going basis as required in 310 CMR 32.13(6) and in accordance with the Department approved sampling and analysis plan. Please note, the approved sampling and analysis plan specifies that the first sample of each production year be split in the field to provide a duplicate sample for analysis. 5. Please be advised, your facility must perform a TCLP within the next two years, and at intervals not to exceed two years thereafter, in order to retain compliance with the requirement that at least one TCLP be performed for every two year AOS renewal period. 6. This approval does not include approval to blend 1998 Type I compost with previously approved Type 3 compost, which is also stockpiled at the composting facility. As per your request, the review and classification of existing and future compost has been expedited as the review of the blending proposal is held pending further direction from the Town. The Mansfield Board of Health, in a letter dated April 4, 2003, approved of the proposal for Type I classification of Mansfield compost. This approval fulfills the obligation of 310 CMR 32.14(2) which requires the written concurrence of the board of health prior to Type I approval by the Department. The Department reserves the right to rescind, suspend or modify this approval by the imposition of additional conditions or amendments to the stated conditions based on determining any actual or potential adverse impacts resulting from the conduct of this project. This Permit is an action of the Department. If you are aggrieved by this action, you may request an adjudicatory hearing. A Notice of Claim for an Adjudicatory Heating must be made in writing and postmarked within thirty (30) days of the date this permit was issued. Pursuant tc 310 CMR 1.01(6), the Notice of Claim shall state clearly and concisely the facts which are grounds for the proceeding and the relief sought. The Notice of Claim, along with a valid check payable to the Commonwealth of Massachusetts in the amount of one hundred dollars ($100.0Q), must be mailed to: Commonwealth of Massachusetts Department of Environmental Protection P.O. Box 4062 Boston, MA 02211 The Notice will be dismissed if the filing fee is not paid, unless the appellant is exempt or granted a waiver as described in 310 CMR 4.00. If you have any questions, please contact Mr. Richard Rondeau at (508) 946-2816. Very truly yours, W .L'f cc: Mr. Lee Azinheira, Town Engineer Town of Mansfield 6 Park Row Mansfield, MA 02048 Protection cc: Mr. Scott Leite, Agent Board of Health 6 Park Row Mansfield, NIA 02048 Mr. Edward C. Sanderson Camp Dresser & McKee, Inc. One Cambridge Place, 50 Hampshire St. Cambridge, MA 02139 DEP-Millbury ATTN: Larry Polese TOWN OF MANSFIELD, MASSACHUSETTS Six Park Row, Mansfield, MA 02048 April 4, 2003 Mr. Richard Rondeau Department of Environmental Protection Southeast Regional Office 20 Riverside Drive Lakeville, MA 02347 RE: MANSFIELD—Board of Health Concurrence, BRPWP29, Residuals Approval of Suitability, 1998, 2001, 2002 and Future Compost Production,Sludge Composting facility, Off Fruit Street, Transmittal No. W035188 Dear Mr. Rondeau, The Board of Health has reviewed the proposal for sale of composted sludge and approves of the proposed project. If I can be of further assistance, please do not hesitate to contact me. C: Lee Azinheira, Director of Department of Public Works Kenneth Hackett, Wastewater Operations Manager Tim Gould, Agresource, Inc. CDM One Cambridge Place, 50 Hampshire Street Cambridge, Massachusetts 02139 tel: 617 452-6000 fax: 617 452-8000 February 27, 2003 Mr. Scott Leite, Health Agent Board of Health 6 Park Row Mansfield, Massachusetts 02048 Subject: Town of Mansfield, Massachusetts BRPWP29 Approval of Suitability Compost Production at the Wastewater Biosolids Composting Facility Dear Mr. Leite: In the near future, the Town of Mansfield will be applying to the Department of Environmental Protection (DEP), Division of Water Pollution Control, for an Approval of Suitability for Type I residual sludge compost produced at the Mansfield Wastewater Biosolids Composting Facility located on Fruit Street in Mansfield. In compliance with 310 CMR 32.14(1)(c), a copy of the subject application will be forthcoming to the Board of Health. 310 CMR 32.14(2) states that the DEP shall not approve the use, sale, or distribution or offering for use, sale, or distribution of Type I sludge without the written concurrence of the board of health of the city or town in which the owner's or operator's facility is located, provided that such concurrence is not unreasonably withheld. Said board of health shall be deemed to have given such concurrence unless it gives written notice to the contrary to the Department not later than 35 days after the date of notice given the board of health pursuant to the first sentence of 310 CMR 32.14(2)." The Town of Mansfield, or its consultant, Camp Dresser & McKee, will be forwarding a copy of the application of the Approval of Suitability. If you have any questions in the meantime, please contact me at 617-452-6664. CASanderson\0201-34021 Mansfield\Contract 42\Approval of Suitability\ApplicatlonWH notilicationdoc consulting • engineering - construction • operations Mr. Scott Leite February 27, 2003 Page 2 We look forward to working with the Board of Health and expediting the application process. Very truly yours, Edward C. Sanderson Project Engineer Camp Dresser & McKee Inc. cc: Rick Rondeau - DEP Lakeville Lee Azinlieira - Town of Mansfield Ken Hackett - Town of Mansfield Jolu1 Donovan - CDM CASanderson\0201-34021 Mansfield\Contract #2\Approval of Suilabllity\AppllcalioN80H-notificalion.doc COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE 20 RIVDRSIDR DRIVE, LAI EVILLR, MA 02347 JANR SWIFT Governor 1 Mr, Lee Azinheira, Director Department of Public Works Town of Mansfield 6 Park Row Mansfield, Massachusetts 02048 Dear Mr. Azinheira: BOB DURAND i Secretary �. �• -� 7002 i LAURUN A. LISS /! Commissioner January 31, RE: 1VMANSFIELD--Water Pollution Control, Town of Mansfield Composting Facility Operation and Maintenance Manual The Department is in receipt of the Composting Facility Operation and Maintenance Manual, dated September 2001 prepared by your consultant, Camp Dresser & McKee, Inc., on behalf of the Town of Mansfield regarding the sludge composting facility located off Fruit Street in the Town of Mansfield. The Town of Mansfield was issued a plan and specifications approval for the year round composting facility in a letter dated February 8, 1999, from the Department. In submitting this Operation and Maintenance Manual, the Town is seeking to comply with condition #2 of that approval. The Department has completed its review of the Composting Facility Operation and Maintenance Manual and has determined that it properly and adequately complies with the requirements of condition 92 of the Department's composting facility approval dated February 8, 1999. The Department recommends the following additions to the Operation and Maintenance Manual: o The maintenance schedules reconunended by the equipment manufacturers of the composting equipment should be included as part of this Manual. o All routine maintenance at the composting facility should be included in the wastewater treatment plant's preventative maintenance (PM) program. o The Sampling and Testing section of the Operation and Maintenance Manual should include provisions for TCLP testing as required for Approval of Suitability submittal to the Department. This infornmtion is available in alleinale fo rnal by calling our ADA Coordinator al (617) 574-6872, DEP on the World Wide Web: http://w ,mass.gov/dep 10 Printed on Recycled Paper Please be advised, the Department recognizes the Operation and Maintenance Manual as a "living document" and thereby encourages the Town to update this document on a regular basis, as needed, to ensure that any operational changes are reflected and documented for future reference. The Department should be provided any such updates but inclusion in the Manual, in and of itself, will not require submittal for approval. Please refer to the facility approval, 310 CMR 32:00 and 314 CMR 12.00 for requirements for approval by the Department for operational changes or other facility modifications. Please be aware, in accordance with 310 CMR 32.00, no beneficial use of this material shall be allowed without a currently valid Approval of Suitability from the Department. The Mansfield Board of Health shall be copied on all correspondence regarding operation of the composting facility and must be copied on the future approval of suitability application to the Department. The Department will be seeking their concurrence before any Type I classification of this material is granted. If you have any questions, please contact Mr. Richard Rondeau at (508) 946-2816. Very truly yours, Protection G/RR/bh cc: Mr. John D. Sullivan, Jr., Town Engineer Town of Mansfield 6 Park Row Mansfield, MA 02048 Mr. Ken Hackett, Plant Manager Department of Public Works 6 Park Row Mansfield, MA 02048 Mr. David F. Young Camp Dresser & McKee Inc. One Cambridge Place 50 Hampshire St. Cambridge, MA 02139 Mr. Scott Leite, Agent Board of Health 6 Park Row Mansfield, MA 02048 DEP-SERO . ATTN: David DeLorenzo Joseph Shepherd COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE ARGEO PAUL CELLUCCI BOB DURAND Secretary Governor JANE SWIFT Lieutenant Governor - f /`` , DAVID B. STRUHS Conunissioner i i � ✓ tg February 8, 1999 Mr. Lee Azinheira, Town Engineer RE: MANSFIELD--Water Pollution Control, Town of Mansfield BRPWP45, Modifications to Residuals 6 Park Row Management Facilities, Plans and Mansfield, Massachusetts 02048 Specifications, Sludge Composting Facility, Off Fruit Street, Transmittal No. 124182 Dear Mr. Azinheira: In a letter dated March 5, 1998, the Department of Environmental Protection issued conditional approval ofyour request to perform year round composting at the existing Town of Mansfield composting facility off Fruit Street. Currently, the Town operates the composting facility on a seasonal basis from May to October. This letter is written to address condition.l, of that approval which required submittal of plans for all structural, equipment and.process control changes once available. In a meeting on November 24, 1998, your consultant, Camp Dresser and McKee, submitted plans and specifications in order, to gain Department approval and fulfill the above -mentioned condition. The submitted plans, consisting of Contract No. 1, 10 sheets which encompass demolition and structural modifications, and Contract No. 2, 4 sheets which encompass mechanical and electrical instrumentation modifications, are titled as follows: TOWN OF MANSFIELD, MASSACHUSETTS .COMPOSTING FACILITY MODIFICATIONS CONTRACT No. 1 NOVEMBER, 1998 TOWN OF MANSFIELD, MASSACHUSETTS COMPOSTING FACILITY MODIFICATIONS CONTRACT No. 2 NOVEMBER, 1998 CAMP DRESSER & McKEE INC. ENVIRONMENTAL SERVICES CAMBRIDGE, MASSACHUSETTS 20 Riverside Drive 0 Lakeville, Massachusetts 02347 0 FAX(508) 947-6557 0 Telephone (508) 946-2700 -2- The Town wishes to expand upon it's successful seasonal composting operation in order to eliminate landfilling of sludge during the winter months and produce a compost material which has a beneficial use. This would also extend the life of their current sludge landfill while maintaining redundancy via landfilling. The plans include the addition of two pre-engineered structures to cover and enclose the main active composting area and the screening area. The active composting area enclosure is proposed as a 125 foot by 150 foot structure which will house all active compost piles. The screening enclosure is proposed as a 140 foot by 30 foot structure and will act as a storage area for bulking material and will house a new trommel screen the town proposes to purchase. Also proposed are larger blowers and the addition of instrumentation and electrical improvements. The ten existing one horsepower blowers are to be replaced with five horsepower blowers which will be activated by an instrument package that includes a temperature probe to pace the blowers accordingly. Although not currently required, the blower exhaust _piping is configured so as to provide for odor control measures and equipment in the future if needed. No modifications are proposed for the final compost curing area and/or final product storage area. After reviewing all pertinent information, the Department .hereby approves the physical modifications as proposed in the submitted plans for the year round composting facility at the existing seasonal residuals composting facility off Fruit Street in Mansfield,, Massachusetts, subject to the following terms and conditions: 1. Only condition 1. of the March 5, 1998 Department approval has been satisfied with the issuance of this letter. All other conditions of the.March 5, 1998, Department approval letter remain in effect as approval of a year round, versus seasonal, composting operation. 2. An amendment to, or a modification of the existing operations and maintenance manual specifically addressing year round compost operations shall be submitted to this office for review and should include, at a minimum, the information listed below, items a. through i., as required by 314 CMR 12.04:(1). A draft must be submitted; for Department comments thirty (30) days prior to modified compost facility operation. Once comments are received, a final must be submitted to this office within ninety (90) days. a. Introduction b. Permits and Standards C. Description, Operation and Control of Wastewater Treatment Facilities d. Sampling and Laboratory Analysis e. Records and Reporting -3- f. Maintenance g. Emergency Operating and Response Program (shall include an Emergency Action and Contingency Plan) h. Safety i. Utilities 3. If compost operations create nuisance and/or odor problems/ complaints, then no new composting piles shall be constructed and odor/nuisance sources shall be identified and mitigated. Permanent corrective measures, as applicable, shall be submitted to the Department for evaluation and concurrence before compost operations can resume. Odor/nuisance mitigation measures shall be part of the Contingency Plan which is to be addressed through item 2.g. above. 4. The Department approved Sampling and Analysis Plan for ongoing compost classification, issued December 11, 1997, shall remain in effect and be adhered to for year round composting operations. Please be advised, this will result in an increase in the number of samples per year based on quarterly sampling of year round, versus seasonal, composting. 5.. Written certification from the engineer, along with as -built plans which are stamped and signed by a Massachusetts Registered Professional Engineer, that all construction is in accordance with the plans must be submitted to this office prior to operation of the compost facility. Also, the Town shall provide notice to the Southeast Regional Office so that a DEP representative may conduct a site visit prior to start-up of compost operations. 6. As the instrumentation package includes only one temperature probe per two active compost piles, it will be necessary to continue to perform manual temperature probing at various points, at various times daily, within each compost pile in order to demonstrate compliance with 310 CMR 32.81, Acceptable Processes for Additional Pathogen Reduction. 7. As final compost curing will not occur within one of the proposed enclosures, measures shall be taken to ensure that adverse weather conditions do not affect the quality, consistency and reduced pathogen content of the compost prior to sale and/or distribution. The Department reserves the right to rescind, suspend or modify this approval by the imposition of additional conditions or amendments to the stated conditions based on determining any actual or potential adverse impacts resulting from the conduct of this project. This Permit is an action of the Department. If you are aggrieved by this action, you may request an adjudicatory hearing. A Notice of Claim for an Adjudicatory Hearing must be made in writing and postmarked within thirty (30) days of the date this permit was issued. Pursuant to 310 CMR 1.01(6), the Notice of Claim shall state clearly and concisely the facts which are grounds for the proceeding and the relief sought. The Notice of Claim, along with a valid check payable to the Commonwealth of Massachusetts in the amount of one hundred dollars ($100.00), must be mailed to: Commonwealth of Massachusetts Department of Environmental Protection P.O. Box 4062 Boston, MA 02211 The Notice will be dismissed if the filing fee is not paid, unless the appellant is exempt or granted a waiver as described in 310 CMR 4.00. If you have any questions, please contact Mr. Richard Rondeau at (508) 946-2816 or Mr. Joseph Shepherd at (508) 946-2756. Very truly yours, J ck Hamm, Chief unton River Watershed H/RR/bh cc: Mr. Kenneth Hackett Town of Mansfield WPCF 50 West Street Mansfield, MA 02048 Ms. Jane E. Madden Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Mr. Ken Bohlin Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Mr. Scott Leite, Agent Board of Health 50 West Street Mansfield, MA 02048 DEP-SERO ATTN: Jeffrey Gould DEP-Millbury ATTN: Larry Polese DEP-SERO ATTN: John Winkler COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE ARGEO PAUL CELLUCCI TRUDY COXE Governor _ t Secretary lJ tti '1 DAVID B. STRUHS Commissioner March 5, 1998 Mr. Lee Azinheira, Town Engineer RE: MANSFIELD--Water Pollution Control, Town of Mansfield BRPWP45, Modifications to Residuals 6 Park Row Management Facilities, Sludge Mansfield, Massachusetts 02048 Composting Facility, Off Fruit Street, Transmittal No. 124182 Dear Mr. Azinheira: In a letter dated November 11, 1997, your consultant, Camp Dresser & McKee Inc., acting on behalf of the Town of Mansfield, filed a request for approval of modifications to the existing sludge composting facility operated by the Town of Mansfield off Fruit Street under Transmittal Number 124182. In general, the Town is seeking permission to operate a year round composting facility. To date, the Town has operated the existing composting facility on a seasonal basis from May to October. The Town wishes to expand upon it's successful seasonal composting operation in order to eliminate landfilling of sludge during the winter months and produce a compost material which has a beneficial use. This would also extend the life of their current sludge landfill while maintaining redundancy via landfilling. Currently, primary and secondary sludges generated at the plant are co -thickened, conditioned with ferric chloride and lime, and then dewatered at the treatment plant site to a solids content of 32 to 39 percent. The sludge is then transported to the Fruit Street composting site. Approximately 1,370 dry tons of sludge are generated annually. Composting at the Fruit Street site is performed utilizing the aerated static pile method. Sludge is mixed with wood chips volumetrically on a 1 part sludge to 2 part new/recycled wood chip mix. The pile is aerated in both the positive and negative mode to maintain an aerobic environment, control pile temperature, to assure proper pathogen reduction, and reduce moisture content. After approximately 30 days in the aerated pile, compost is transported to the screen for wood chip reclamation. The compost is then taken to the non -aerated curing area where it resides for approximately 90 days before being moved to the finished compost area. 20 Riverside Drive • Lakeville, Massachusetts 02347 0 FAX (508) 947-6557 0 Telephone (508) 946.2700 -2- In order to facilitate year round composting of wastewater treatment plant residuals, select areas of the composting facility will be partially enclosed with new structures. These structures, either wood or metal, will cover up to 17,000 square feet and will encompass the active composting and screening areas. Also, the existing blower system will be upgraded, along with associated electrical improvements, and the exhaust from the blower system will be manifolded to collect and transport condensate from the system when operating in the negative mode. In reviewing this proposal, the Department has also considered the following: 1. In a letter dated December 29, 1997, the Department of Environmental Protection, Southeast Regional Office, Division of Air Quality determined that increased emissions from year round composting will be relatively insignificant and therefore not require Department approval. 2. The Town has successfully operated a seasonal composting operation since 1987 with almost no odor complaints or reported operational problems. 3. The Town has demonstrated that it can produce compost which meets Department requirements for classification as Type 1 material under 310 CMR 32.00. After review of all pertinent information, the Department finds no reason to prohibit year round composting at the existing Fruit Street residuals facility at this time and hereby determines that year round composting is permissible subject to the following terms and conditions: 1. It is the Department's understanding that year round composting will not take place until roof structures and upgraded blower systems are designed and in place. As such, the Town shall submit plans to the Department, which are stamped and signed by a Massachusetts Registered Professional Engineer, for all structural, equipment and process control changes. The Town must receive approval from the Department for these modifications prior to implementation of year round composting. 2. An amendment to, or a modification of the existing operations and maintenance manual specifically addressing year round compost operations shall be submitted to this office for review and should include, at a minimum, the information listed below, items a. through i., as required by 314 CMR 12.04:(1). A draft must be submitted for Department comments thirty (30) days prior to modified compost facility operation. Once comments are received, a final must be submitted to this office within ninety (90) days. a. Introduction b. Permits and Standards C. Description, Operation and Control of Wastewater Treatment Facilities -3- d. Sampling and Laboratory Analysis e. Records and Reporting f. Maintenance g. Emergency Operating and Response Program (shall include an Emergency Action and Contingency Plan) h. Safety i. Utilities 3. If composting during the winter months creates nuisance and/or odor problems/complaints, then composting shall cease immediately and corrective measures shall be evaluated and approved by the Department before compost operations can resume. 4. The Department approved Sampling and Analysis Plan for ongoing compost classification, issued December 11, 1997, shall remain in effect and be adhered to for year round composting operations. Please be advised, this will result in an increase in the number of samples per year based on quarterly sampling of year round, versus seasonal, composting. The Department reserves the right to rescind, suspend or modify this approval by the imposition of additional conditions or amendments to the stated conditions based on determining any actual or potential adverse impacts resulting from the conduct of this project. This Permit is an action of the Department. If you are aggrieved by this action, you may request an adjudicatory hearing. A Notice of Claim for an Adjudicatory Hearing must be made in writing and postmarked within thirty (30) days of the date this permit was issued. Pursuant to 310 CMR 1.01(6), the Notice of Claim shall state clearly and concisely the facts which are grounds for the proceeding and the relief sought. The Notice of Claim, along with a valid check payable to the Commonwealth of Massachusetts in the amount of one hundred dollars ($100.00), must be mailed to: Commonwealth of Massachusetts Department of Environmental Protection P.O. Box 4062 Boston, MA 02211 The Notice will be dismissed if the filing fee is not paid, unless the appellant is exempt or granted a waiver as described in 310 CMR 4.00. s� If you have any questions, please contact Mr. Richard Rondeau at (508) 946-2816. Very tru yours, a k Ham , Chief nton Watershed H/RR/rr CC: Mr. Kenneth Hackett Town of Mansfield WPCF 50 West Street Mansfield, MA 02048 Ms. Jane E. Madden Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Mr. Scott Leite, Agent Board of Health 50 West Street Mansfield, MA 02048 DEP-SERO ATTN: Jeffrey Gould DEP-Millbury ATTN: Larry Polese DEP-SERO ATTN: John Winkler ARGEO PAUL CELLUCCI Governor COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE April 6, 1998 TRUDY COXE Secrelary DAVID B. STRUHS Commissioner Mr. Scott Leite, Agent RE: MANSFIELD--Administrative Review, Board of Health BRPWP29, Residuals Approval of 50 West St. Suitability, 1996 and 1997 Compost Mansfield, Massachusetts 02048 Production, Sludge Composting Facility, Off Fruit Street, Transmittal No. 137135 Dear Mr. Leite: The Town of Mansfield has applied to the Department of Environmental Protection, Division of Water Pollution Control, for an Approval of Suitability for Type 1 residual sludge compost produced in 1996 and 1997 at the composting facility. It is the understanding of the Department that the Mansfield Board of Health has received a copy of the subject application, in compliance with 310 CMR 32.14(1)(e). 310 CMR 32.14(2) states that "...The Department shall not approve the use, sale, or distribution or offering for use, sale, or distribution C)f Type I sludge without the written concurrence of the board of health of the city or town in which the owner's or operator's facility is located, provided that such concurrence is not unreasonably withheld. Said board of health shall be deemed to have given such concurrence unless it gives written notice to the contrary to the Department not later than 35 days after the date of notice given the board of health pursuant to the first sentence of 310 CMR 32.14(2)." Accordingly, the Department requests that the Board review the subject proposal and indicate in writing its approval or disapproval of the proposed project. Such response should be sent to Richard Rondeau of my staff at the below address. If you have any questions, please contact Richard Rondeau at (508) 946-2816. H/RR/bh Very truly yours, J ck Ham iiefnton Wathed 20 Riverside Drive 9 Lakeville, Massachusetts 02347 • rAX(508) 947-6557 0 Telephone (508) 946-2700 -2- cc: Mr. Lee Azinheira, Town Engineer Town of Mansfield 6 Park Row Mansfield, MA 02048 Mr. Kenneth Hackett Town of Mansfield WPCF 50 West St. Mansfield, MA 02048 Ms. Yuehlin Lee Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 DEP-MILLBURY ATTN: Larry Polese COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE ARGEO PAUL CELLUCCI Governor TRUDY COXE Secretary DAVID B. STRUHS Commissioner 6 .1T �ay 14, 1998 Mr. Kenneth F. Hackett RE: MANSFIELD--Water Pollution Control, Town of Mansfield BRPWP29, Residuals Approval of 6 Park Row Suitability, 1996 and 1997 Compost Mansfield, Massachusetts 02048 Production, Sludge Composting Facility, Off Fruit Street, Transmittal No. 137135 Dear Mr. Hackett: In a letter dated March 11, 1998, the Town of Mansfield, filed an application with documentation prepared by your consultant, Camp Dresser & McKee Inc., for Type I classification of compost produced from Mansfield Water Pollution Control Facility sludge and currently stockpiled at the Town of Mansfield Composting Facility off Fruit Street in the Town of Mansfield, Massachusetts. An application for an Approval of Suitability was filed under Transmittal No. 137135 and contained the following supplementary documentation: Temperature monitoring data for the 1996 and 1997 compost piles. Ten sets of laboratory test data representing compost produced in 1996 and 1997. This data includes eight samples, including three composite and one field duplicate for each year, for parameters listed in 310 CMR 32.13(5)(a) as well as organic parameters. Results from two TCLP (Toxicity Characteristic Leaching Procedure) tests, one for each production year to be classified, were also provided. The compost is stockpiled by year and represents compost produced seasonally in 1996 and 1997. There is approximately 1,900 cubic yards of sludge compost which was produced in 1996 and approximately 2,000 cubic yards produced in 1997. The Department has reviewed the information submitted and has concluded that sampling, analysis and reporting has successfully been completed pursuant to the requirements of 310 CMR 32.00. Also, as a result of its review, the Department has made the following determinations: All analyses have been conducted in accordance with the sampling and analysis plan approved by the Department on December 11, 1997. 20 Riverside Drive 0 Lakeville, Massachusetts 02347 0 FAX (508) 947-6557 • Telephone (508) 946-2700 WAS 2. Sufficient data records have been submitted to allow the Department to classify the 1996 and 1997 compost. 3. TCLP test data has demonstrated that the compost is non -hazardous pursuant to 310 CMR 30.00. 4. Temperature data obtained from the compost piles for which the Type I approval is being sought have demonstrated that PFRP (Processes to Further Reduce Pathogens) requirements have been met utilizing static aerated pile, high temperature composting, in accordance with 310 CMR 32.81(1). 5. Results of all bulk analysis of the material for the land application parameters have been reported appropriately. In all samples, the final product meets the criteria for Type I as set forth in 310 CMR 32.12. As a result of the Department's review, the Town of Mansfield is granted Type I approval for finished compost produced in 1996 and 1997 and currently stockpiled at the composting facility. This approval is subject to the following terms and conditions: 1. This is a one time approval for compost produced in 1996 and 1997 and currently stockpiled at the Town of Mansfield Compost Facility. 2. In its application for approval of suitability, the Town indicated a variety of potential users of the Type I compost. In all cases, the Town shall comply with the labelling and other requirements of 310 CMR 32.51, "Requirements for sale or distribution of Type I sludge/compost", which states: a) No person shall sell or distribute, or offer for use, sale, or distribution any Type I sludge/compost unless, pursuant to 310 CMR 32.00, the Department has approved such sludge/ compost as Type I sludge and that approval is valid at the time the Type I sludge/compost is sold or distributed, or offered for use, sale, or distribution. b) No person shall obtain Type I sludge/compost unless such sludge/compost has a valid approval of suitability. c) Labelling of Type I Sludge/Compost. Each container in which Type I sludge/compost is sold, distributed, or transported or offered for use, sale, or distribution shall itself prominently display or, if such display is not practicable, shall be accompanied by a shipping paper which shall prominently display the following: i) identification of the material as Type I sludge (compost). ii) the date of issuance of the Department Approval of Suitability for the Type I sludge/compost and the expiration date thereof. -3- iii) instructions for land applying the material in accordance with proper agricultural practice, including, but not limited to, identification of proper agronomic application rates which shall not cause exceedence of the nitrogen requirements of the crop to be grown or intended to be grown. iv) Type I sludge/compost containing more than 10 parts per million of molybdenum shall be accompanied by a written warning that the sludge should not be used on pasture lands subject to grazing or on lands where crops are grown or intended to be grown for forage. Use of the sludge/compost under these circumstances may result in forage crops containing levels of molybdenum which are toxic to ruminants. v) all other instructions and information required by law 3. In accordance with the provisions of 310 CMR 32.11(6), the use, sale and distribution or offering of use, sale and distribution of the compost as a commercial fertilizer or as a soil conditioner is prohibited, except in compliance with the licensing requirements of the Massachusetts Department of Food and Agriculture (MGL c. 128, s.64). 4. Record Keeping. The Town shall comply with all the record keeping requirements of 310 CMR 32.60, including the submission to the Department of an annual report pursuant to section 32.60(2)(c) which shall be due on February 1 of the calendar year following the date the Department issued the approval of suitability until such time as all material hereby classified is utilized. Upon utilization of all material, the report shall be submitted within 30 days or by February 1, whichever is sooner. S. In seeking future approval of compost classification, perform sampling, analysis and monitoring of the compost on an on -going basis as required in 310 CMR 32.13(6) and in accordance with the Department approved sampling and analysis plan dated December 11, 1997, The Department reserves the right to rescind, suspend or modify this approval by the imposition of additional conditions or amendments to the stated conditions based on determining any actual or potential adverse impacts resulting from the conduct of this project. The Mansfield Board of Health, in a letter dated May 13, 1998, approved of the proposal for classification of Mansfield compost as proposed and acted upon by this approval letter. This approval fulfills the obligation of 310 CMR 32.14(2) which requires the written concurrence of the board of health prior to Type I approval by the Department. This Permit is an action of the Department. If you are aggrieved by this action, you may request an adjudicatory hearing. A Notice of Claim for an Adjudicatory Hearing must be made in writing and postmarked within thirty (30) days of the date this permit was issued. Pursuant to 310 CMR 1.01(6), the Notice of Claim shall state clearly and concisely the facts which are grounds for the proceeding and the relief sought. The Notice of Claim, along with a valid check payable to the Commonwealth of Massachusetts in the amount of one hundred dollars ($100.00), must be mailed to: Commonwealth of Massachusetts Department of Environmental Protection P.O. Box 4062 Boston, MA 02211 The Notice will be dismissed if the filing fee is not paid, unless the appellant is exempt or granted a waiver as described in 310 CMR 4.00. If you have any questions, please contact Mr. Richard Rondeau at (508) 946-2816. Jaun ryck ton Watershed H/RR/bh CC: Mr. Lee Azinheira, Town Engineer Town of Mansfield 6 Park Row Mansfield, MA 02048 Mr. Dan Clifford, Director Department of Public Works 6 Park Row Mansfield, MA 02048 Mr. William Williams, Town Manager Town Hall 6 Park Row Mansfield, MA 02048 Ms. Yuelin Lee Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Mr. Scott Leite, Agent Board of Health 6 Park Row Mansfield, MA 02048 -5- cc: DEP-SERO ATTN: Jeffrey Gould DEP-MILLBURY ATTN: Larry Polese TOWN OF MANSFIELD, MASSACHUSETTS 50 West Street, Mansfield, MA 02048 May 13, 1998 Mr. Jack Hamm, Chief Taunton Watershed 20 Riverside Drive Lakeville, MA 02347 RE: MANSFIELD--Administrative Review, BRPWP29, Residuals Approval of Suitability, 1996 and 1997 Compost Production, Sludge Composting Facility, Off Fruit Street Dear Mr. Hamm, The Board of Health has reviewed the above referenced proposal and approves of the proposed project. If I can be of assistance, please do not hesitate to contact me. 9Le uly, ite, Health Agent C: Lee Azinheira, Town Engineer ARGEO PAUL CELLUCCI Governor COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE April 6, 1998 TRUDY COXE Secretary DAVID B. STRUHS Commissioner Mr. Kenneth F. Hackett RE: MANSFIELD--Administrative Review, Town of Mansfield BRPWP29, Residuals Approval of 6 Park Row Suitability, 1996 and 1997 Compost Mansfield, Massachusetts 02048 Production, Sludge Composting Facility, Off Fruit Street, Transmittal No. 137135 Dear Mr. Hackett: The Department has completed its Administrative Review of the permit application listed above and determined that the application is administratively complete. Accordingly, the Department will begin its Technical Review. According to 310 CMR 4.04, the Department now has sixty (60) days to complete its Technical Review and issue a final decision to grant or deny the permit. Provided your application is technically adequate, and none of the contingencies outlined in 310 CMR 4.04 occur, the Department will issue a final decision within the timeframes listed above. If you have any questions, please contact Richard Rondeau at (508) 946-2816. H/RR/bh CC: Mr. Lee Azinheira, Town of Mansfield 6 Park Row Mansfield, MA 02048 Very trul a k Hamm, Chief a nton Watershed Town Engineer Mr. Dan Clifford, Director Department of Public Works 6 Park Row Mansfield, MA 02048 20 Riverside Drive • Lakeville, Massachusetts 02347 0 FAX(508) 947.6557 • Telephone (508) 946.2700 sX CC: Mr. William Williams, Town Manager Town Hall 6 Park Row Mansfield, MA 02048 Ms. Yuelin Lee Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Mr. Scott Leite, Agent Board of Health 6 Park Row Mansfield, MA 02048 DEP-MILLBURY ATTN: Larry Polese COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE ARCED PAUL CELLUCCI TRUDY COXE Governor ��"" �,} f Secretary DAVID B. STRUHS Commissioner November 23, 1998 Mr. Lee Azinheira, Town Engineer RE: MANSFIELD--Water Pollution Control, Town of Mansfield Compost Blending Proposal, 6 Park Row Classification and Utilization Mansfield, Massachusetts 02048 Dear Mr. Azinheira: In a letter dated September 22, 1998, your consultant, Camp Dresser & McKee Inc., acting on behalf of the Town of Mansfield, submitted a proposal to the Department to produce a manufactured topsoil using Mansfield compost for future use on a municipal recreational site in the Town of Mansfield. The compost was produced at the Mansfield Composting Facility in 1991 and 1992. It was classified as Type 3 by the Department in an approval letter dated October 16, 1998 and is currently stockpiled at the composting facility. The town is seeking to produce a Type I material by blending with topsoil in accordance with the Department's Blending Policy, No. 87-1. This letter is written in response to the town's request for approval to blend Type 3 compost with topsoil on a one to one volumetric basis. Following blending at the compost facility site, the town will sample the material in accordance with the Department approved sampling and analysis plan dated February 14, 1996, and submit test results to the Department for classification. If classified as Type I by the Department, the town will utilize the blended compost for the construction of recreational fields at the town's Memorial Park on Chauncy Street. At the fields the compost blend is to be incorporated in the first six inches of topsoil. An identifiable and designated market or end use of the final blended product is a prerequisite for approval under the Blending Policy. Currently there is approximately 6,000 cubic yards of compost classified as Type 3 which is stockpiled at the compost facility site off Fruit Street. Although this represents compost produced during the years 1987 through 1992, it is only years 1991 and 1992, a total of 1,000 cubic yards of Type 3 material, which are the subject of this proposal and result in 2,000 cubic yards of final blended product. The Department has reviewed the information submitted and hereby concurs with the feasibility of this proposal subject to the following conditions: 20 Riverside Drive 0 Lakeville, Massachusetts 02347 0 rAX(508) 947-6557 • Telephone (508) 946-2700 -2- 1. In order for the town to reach its goal of achieving Type I classification and recreational field utilization, the town must submit to the Department for approval, an application for Approval of Suitability (BRPWP29) for the new compost blend. 2. Blending will be performed at the compost facility site only. 3. No beneficial use of this material, as proposed, shall be allowed until a new Approval of Suitability (Type 1) is granted by the Department. 4. As proposed, testing of the final blended product shall be performed in accordance with the December 11, 1997, Department approved sampling and analysis plan and must include all parameters, not just cadmium and copper. In accordance with this sampling and analysis plan, three representative composite samples will be collected. One of these composite samples will be split in the field for quality assurance/quality control purposes thereby producing a total of four samples. Each sample will be composited from eight sub -samples collected from different locations in the final blended compost at a depth of three to six feet. Parameters to be sampled for shall include those listed in 310 CMR 32.13(5). As it has already been determined the compost is non -hazardous in accordance with 310 CMR 30.00, no additional TCLP need be performed. 5. All testing must be performed by a Massachusetts certified laboratory which is certified to perform all requisite analysis. 6. The Mansfield Board of Health shall be copied on all correspondence and must be copied on the future approval of suitability application to the Department. The Department will be seeking their concurrence before any Type I classification of this material. 7. Temperature data for all compost piles which are to be classified must accompany the chemical quality data at the time an Application for Approval of Suitability is submitted. This information serves to verify the degree of stabilization provided by the active compost process. 8. If the compost appears highly variable during blending or sampling, the Department shall be notified and additional samples may be required in order to determine the classification of the final compost blend material. 9. Public access to the application site shall be restricted for a period of one year from the time manufactured topsoil is applied to the entire field. Please be advised, the Department recommends that the town test any topsoil to be used as part of the blending process in order to avoid negative impacts to the final blended product. . -3- Please be aware, any future proposal to blend currently classified Type 3 material to meet Type 1 standards should not include material produced in 1987 as temperature records have not been made available for this year and, therefore, 310 CMR 32.12(1)(b) cannot be met. The Department reserves the right to rescind, suspend or modify these findings by the imposition of additional conditions or amendments to the stated conditions based on determining any actual or potential adverse impacts resulting from the conduct of this project. This Permit is an action of the Department. If you are aggrieved by this action, you may request an adjudicatory hearing. A Notice of Claim for an Adjudicatory Hearing must be made in writing and postmarked within thirty (30) days of the date this permit was issued. Pursuant to 310 CMR 1.bl(6), the Notice of Claim shall state clearly and concisely the facts which are grounds for the proceeding and the relief sought. The Notice of Claim, along with a valid check payable to the Commonwealth of Massachusetts in the amount of one hundred dollars ($100.00), must be mailed to: Commonwealth of Massachusetts Department of Environmental Protection P.O. Box 4062 - Boston, MA 02211 The Notice will be dismissed if the filing fee is not paid, unless the appellant is exempt or granted a waiver as described in 310 CMR 4.00. If you have any questions, please contact Mr. Richard Rondeau at (508) 946-2816. Very truyours, r'; mm, Chief Watershed H/RR/bh CC: Mr. Kenneth Hackett Town of Mansfield WPCF 50 West Street Mansfield, MA 02048 Mr. John F. Donovan, V.P. Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Ms. Jane Madden Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 a CC: Mr. Scott Leite, Agent Board of Health 50 West Street Mansfield, MA 02048 DEP-SERO ATTN: Jeffrey Gould Joseph Shepherd DEP-Millbury ATTN: Larry Polese consulting engineering constructlon operations Camp Dresser & McKee Inc. fen Cambridge Center ,ambridge, Massachusetts 02142 iel:617252-8000 Fax:617621.2565 [November 20,1997 Mr. Rick Rondeau Department of Environmental Protection Division of Water Pollution Control 20 Riverside Drive Lakeville, Massachusetts 02347 X �t2)'if Subject: Town of Mansfield, Massachusetts Application for Approval of Sampling and Analysis Plan (BRP WP 28) DEP Transmittal No.137134 Dear Mr. Rondeau: On behalf of the Town of Mansfield, Camp Dresser & McKee Inc. (CDM) is writing to notify you of an amendment to the Application for Approval of Sampling and Analysis Plan referenced above. Due to the Town's bidding requirements, a new laboratory has been selected to provide analytical services for the proposed sampling and analysis plan. The proposed analytical laboratory for this compost sampling and analysis plan is: R.I. Analytical Laboratories, Inc. 41 Illinois Avenue Warwick, RI 02888 (401)737-8500 Certification # M-RIO15 R.I. Analytical is certified in Massachusetts for all proposed analyses listed in Exhibit B of the sampling and analysis plan. As you know, the Town is proceeding with preliminary design to allow for year-round composting at the existing compost facility. The design will be presented at a Town meeting in April 1998. In order to build support for this beneficial project, we would like to show that composting will provide the Town a marketable product that can bring in revenue to offset some of the operational costs. To demonstrate the latter point, we believe it is critical to show that the compost being produced at the Mansfield facility is of the highest quality, with a DEP Type I classification, Therefore, we would like to complete the current compost classification process by April 1998. To meet this deadline, we would need to sample in early December and submit the Approval of Suitability application in January 1998. We would greatly appreciate your efforts in expediting DEP's review of the sampling and analysis plan, and the general review process for the Approval of Suitability, so that we could meet this proposed schedule. 201-22245-RT.TSKI CW Camp Dresser & McKee Inc. Mr. R. Rondeau November 20,1997 Page 2 Please call me at (617) 252-8247 if you have any questions on the above or if you need any further information to facilitate your review of the sampling and analysis plan. Very truly yours, CAMP DRESSER & McKEE INC. r Yuehlin Lee Project Engineer YL/mom cc: K. Hackett, Mansfield L. Azinheira, Mansfield Mansfield Board of Health L. Hersho Moss, CDM J. Donovan, CDM 201-22246.RT.TSK1 COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE ARGEO PAUL CELLUCCI Governor Mr. Kenneth F. Hackett Town .of Mansfield 6 Park Row Mansfield, Massachusetts 02048 Dear Mr. Hackett: TRUDY COXE Secretary DAVID B. STRUHS Corrunissioner December 11, 1997 RE: MANSFIELD--Water Pollution Control, BRPWP28, Residuals Sampling and Analysis Plan, 1996 and Future Production, Sludge Composting Facility, Off Fruit Street, Permit No. 137134 The Department is in receipt of a Sampling and Analysis Plan prepared by your consultant, Camp Dresser & McKee, Inc., on behalf of the Town of Mansfield regarding compost produced at the Mansfield Composting Facility, off Fruit Street, in Mansfield, Massachusetts, under Transmittal No. 137134. The Town of Mansfield is seeking a Type I Approval of Suitability (classification) for the compost which is intended to be distributed for beneficial use in Massachusetts. This sampling and analysis plan is proposed to encompass both existing production year 1996 and 1997 compost and future compost production. The Town currently has existing compost piles onsite for compost which was generated in 1996 and 1997. .In order to characterize the existing compost, three representative samples will be collected from each of the 1996 and 1997 composts for analysis. The first of the three composite samples will be split in the field to provide a duplicate sample to serve as a quality assurance/quality control mechanism for laboratory results. Each composite sample will be created from eight grab samples. Each grab sample will be collected from a different location in the compost pile at a depth between three and six feet. These eight locations shall be selected so as to best represent the entire range of compost in each pile. Analysis will include one TCLP sample each for 1996 compost and 1997 compost. For future compost production, a minimum of three composite samples from the active composting area will be collected for analysis at a minimum interval of one sample every three months. The first sample of each production year will be split in the field to provide a duplicate sample for analysis. Each sample will be composited from eight grab samples from 20 Riverside Drive 0 Lakeville, Massachusetts 02347 0 TAX(508) 947-6557 • Telephone (508) 946-2700 -2- compost that has completed the compost process by demonstrating adherence to the requirements of 310 CMR 32.81. Each grab sample will be collected from a different, representative location in the compost pile at a depth between three and six feet. Analysis will include at least one TCLP to demonstrate that the compost in non -hazardous pursuant to 310 CMR 30.00. Analytical services for compost testing are to be provided by R.I. Analytical Laboratories, Inc., of Warwick, Rhode Island, which is certified by the Commonwealth of Massachusetts to perform all requisite analysis. The Department finds that this laboratory is acceptable to perform the analysis required under 310 CMR 32.00 and the TCLP. Please be advised, it is the responsibility of the consultant to ensure that adequate sample volumes are collected commensurate with laboratory distribution and testing as outlined above. Also, in reporting data from the proposed analysis, the Department wishes to reinforce the selection of detection limits which are at least as low as the classification criteria set forth in 310 CMR 32.12. Detection limits which are too high will invalidate the associated analytical results. The Department has completed its review of the sampling and analysis plan and has determined that it complies with the requirements of Massachusetts Land Application Regulations. Based on this review, the Department hereby approves the Plan with the following conditions and understandings of approval: 1. All sampling and analysis shall be performed in accordance with the application submitted by the applicant. Any proposed changes must be approved by the Department prior to implementation. 2. Temperature data for all compost piles which are to be classified must accompany the chemical quality data at the time an Application for Approval of Suitability is submitted. This information serves to verify the degree of stabilization provided by the active compost process. 3. Parameters to be sampled for shall include those listed in 310 CMR 32.13(5) and Table 1 and Table 2 in the application for Approval of Suitability (BRPWP29). 4. All analyses shall be performed using approved test procedures in accordance with the List of Approved Test Procedures for Sludge Parameters contained in the Sampling and Analysis Plan Approval application (BRPWP28). Any deviations must be explained in the application for Approval of Suitability (BRPWP29). 5. If the compost appears highly variable during sampling, additional samples may be required in order to determine the classification of the final compost material. The Department reserves the right to rescind, suspend or modify this approval by the imposition of additional conditions or amendments to the stated conditions based on determining any actual or potential adverse impacts resulting from the conduct of this project. -3- If you have any questions, please contact Mr. Richard Rondeau at (508) 946-2816. Very Itruly,Y ruly,y urs, Ja k Hamm, Chief T unton Watershed H/RR/cb CC: Mr. Dan Clifford, Director Department of Public Works 6 Park Row Mansfield, MA 02048 Mr. William Williams, Town Manager Town Hall 6 Park Row Mansfield, MA 02048 Ms. Yuelin Lee Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, .MA 02142 Mr. Scott Leite, Agent Board of Health 6 Park Row Mansfield, MA 02048 DEP-MILLBURY ATTN: Larry Polese ARGEO PAUL CELLUCCI Governor COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE October 16, 1997 Mr. Lee Azinheira, Town Engineer RE: Town of Mansfield 6 Park Row Mansfield, Massachusetts 02048 Dear Mr. Azinheira: TRUDY COXE Secretary DAVID B, STRUHS Commissioner MANSFIELD--Water Pollution Control, BRPWP29, Residuals Approval of Suitability, Type 3 Classification, Sludge Composting Facility, Off Fruit Street, Transmittal No. 115018 In a letter dated July 1, 1997, your consultant, Camp Dresser & McKee Inc., acting on behalf of the Town of Mansfield, filed a revised application to allow the Department to classify the material, by stockpile designation, by segregation into Type 1 and Type 3 approval requests based on stabilization and testing data. On August 18, 1997, the Department conditionally approved the classification of stockpiles 7, 8 and 9, representing production years 1993, 1994 and 1995, as Type 1 compost. This letter is thereby sent to address the request for Type 3 classification of compost produced from Mansfield Water Pollution Control Facility sludge and currently stockpiled at the Town of Mansfield Compostinq Facility off Fruit Street in the Town of Mansfield, Massachusetts. This revision is part of an application for an Approvai oz Suitability originally filed on February 7, 1997, under Transmittal No. 115018. The compost is stockpiled by year and represents compost produced from 1987 through 1995. There is approximately 9,000 cubic yards of material which have been labeled as piles 1 through 9, consecutively by year. The July 1, 1997 letter requests a Type 3 approval for stockpiles 1 through 6 which represent production years 1987 through 1992. The Department has reviewed the information submitted and has concluded that sampling, analysis and reporting has successfully been completed pursuant to the requirements of 310 CMR 32.00. Also, as a result of its review, the Department has made the following determinations: 1. All analyses have been conducted in accordance with the sampling and analysis plan approved by the Department on February 14, 1996. 20 Riverside Drive 0 Lakeville, Massachusetts 02347 • FAX(508) 947-6557 • Telephone (508) 946-2700 -2- 2. Sufficient data records have been submitted to allow the Department to classify compost stockpiles 1 through 6. 3. TCLP test data has demonstrated that the compost is non -hazardous pursuant to 310 CMR 30.00. 4. Temperature data obtained from the compost piles 2 through 6 for which the Type 3 approval is being sought have demonstrated that PFRP (Processes to Further Reducing Pathogens) requirements have been met utilizing static aerated pile, high temperature composting, in accordance with 310 CMR 32.81(1). Temperature records for compost stockpile 1 are not available but, since the process used to stabilize the material is acceptable and fecal coliform data meets class B requirements under EPA 40 CFR 503 Regulations, the Department has determined that adequate stabilization has occured in order to classify stockpile 1 as Type 3 compost. Additionally, the Department agrees that stabilization under 310 CMR 32.81(8) has been met for all . stockpiles, 1 through 6, utilizing EPA 40 CFR 503. 5. Results of all bulk analysis of the material for the land application parameters have been reported appropriately. In all relevant samples, the final product meets the criteria for Type 3 as set forth in 310 CMR 32.12 for stockpiles 1 through 6. As a result of the Department's review, the Town of Mansfield is granted Type 3 approval for finished compost produced in 1987, 1988, 1989, 1990, 1991 and 1992 and stored as stockpiles 1, 2, 3, 4, 5, and 6. This approval is subject to the following terms and conditions: 1. This is a one time approval for compost currently stockpiled at the Town of Mansfield Compost Facility storage area and designated as stockpiles 1 through 6, produced from 1987 through 1992. 2. No beneficial use of this material shall be allowed unless it is in accuidaii,c wiLh u valid Land F.pplication Certificate the Department in accordance with 310 CMR 32.20 3. Record Keeping. The Town shall comply with all the record keeping requirements of 310 CMR 32.60, as applicable. The Department reserves the right to rescind, suspend or modify this approval by the imposition of additional conditions or amendments to the stated conditions based on determining any actual or potential adverse impacts resulting from the conduct of this project. This Permit is an action of the Department. If you are aggrieved by this action, you may request an adjudicatory hearing. A Notice of Claim for an Adjudicatory Hearing must be made in writing and postmarked within thirty (30) days of the date this permit was issued. Pursuant to 310 CMR 1.01(6), the Notice of Claim shall state clearly and concisely the facts which are grounds for the proceeding and the relief sought. 99M The Notice Commonwealth of ($100.00), must of Claim, along Massachusetts in be mailed to: with a valid check payable to the the amount of one hundred dollars Commonwealth of Massachusetts Department of Environmental Protection P.O. Box 4062 Boston, MA 02211 The Notice will be dismissed if the filing fee is not paid, unless the appellant is exempt or granted a waiver as described in 310 CMR 4.00. If you have any questions, please contact Mr. Richard Rondeau at (508) 946-2816. Very trul ours, 4aack Hamm, Chief unton Watershed H/RR/cb CC: Mr. Kenneth Hackett Town of Mansfield WPCF 50 West Street Mansfield, MA 02048 Mr. James Small Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Ms. Lynne M. Mosd Camp Dresser & McKee Inc. 10 Cambridge center Cambridge, MA 02142 Mr. Scott Leite, Agent Board of Health 50 West Street Mansfield, MA 02048 DEP-SERO ATTN: Jeffrey Gould DEP-Millbury ATTN: Larry Polese COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE ARGEO PAUL CELLUCCI fj Governor C J* 1B � i$ 9 August 18, 1997 TRUDY COXE Secretary DAVID B. STRUHS Commissioner Mr. Lee Azinheira, Town Engineer RE: MANSFIELD--Water Pollution Control, Town of Mansfield BRPWP29, Residuals Approval of 6 Park Row Suitability, Sludge Composting Mansfield, Massachusetts 02048 Facility, Off Fruit Street, Transmittal No. 115018 Dear Mr. Azinheira: In a letter dated July 1, 1997, your consultant, Camp Dresser & McKee Inc., acting on behalf of the Town of Mansfield, filed a revised application for Type I classification of compost produced from Mansfield Water Pollution Control Facility sludge and currently stockpiled at the Town of Mansfield Composting Facility off Fruit Street in the Town of Mansfield, Massachusetts. This revision is part of an application for an Approval of Suitability originally filed on February 7, 1997, under Transmittal No. 115018. The compost is stockpiled by year and represents compost produced from 1987 through 1995. There is approximately 9,000 cubic yards of material which have been labeled as piles 1 through 9, consecutively by year. The July 1, 1997, letter specifically requests a Type 1 approval for stockpiles 7, 8 and 9 which represent production years 1993, 1994 and 1995. The town is pursuing a Type 3 classification for stockpiles 1 through 6, production years 1987 through 1992, separately as time and space constraints at the site dictate expedited approval and removal/distribution of the Type 1 material as soon as possible. Therefore, this approval letter specifically addresses the request for Type 1 approval for stockpiles 7, 8 and 9. Classification of stockpiles 1 through 6 is currently under review by the Department and a determination will be issued separately. The Department has reviewed the information submitted and has concluded that sampling, analysis and reporting has successfully been completed pursuant to the requirements of 310 CMR 32.00. Also, as a result of its review, the Department has made the following determinations: All analyses have been conducted in accordance with the sampling and analysis plan approved by the Department on February 14, 1996. 20 Riverside Drive 0 Lakeville, Massachusetts 02347 • FAX(508) 947.6557 • Telephone (508) 946-2700 -2- 2. Sufficient data records have been submitted to allow the Department to classify compost stockpiles 7, 8 and 9. 3. TCLP test data has demonstrated that the compost is non -hazardous pursuant to 310 CMR 30.00. 4. Temperature data obtained from the compost piles for which the Type I approval is being sought have demonstrated that PFRP (Processes to Further Reducing Pathogens) requirements have been met utilizing static aerated pile, high temperature composting, in accordance with 310 CMR 32.81(1), 5. Results of all bulk analysis of the material for the land application parameters have been reported appropriately. In all relevant samples, the final product meets the criteria for Type I as set forth in 310 CMR 32.12 for stockpiles 7, 8 and 9. As a result of the Department's review, the Town of Mansfield is granted Type I approval for finished compost produced in 1993, 1994 and 1995 and stored as stockpiles 7, 8 and 9. This approval is subject to the following terms and conditions: 1. This is a one time approval for compost currently stockpiled at the Town of Mansfield Compost Facility storage area and designated as stockpiles 7, 8 and 9. Beneficial use of materials at the Mansfield compost facility other than stockpiles 7, 8 and 9 or any materials not meeting the Type 1 standards is prohibited under this approval. 2. The Town shall comply with the labelling and other requirements of 310 CMR 32.51, "Requirements for sale or distribution of Type I sludge/compost", which states: a) No person shall sell or distribute, or offer for use, sale, or distribution any Type I sludge/compost unless, pursuant to 310 CMR 32.00, the Department has approved such sludge/ compost as Type I sludge and that approval is valid at the time the Type I sludge/compost is sold or distributed, or offered for use, sale, or distribution. b) No person shall obtain Type I sludge/compost unless such sludge/compost has a valid approval of suitability. c) Labelling of Type I Sludge/Compost. Each container in which Type I sludge/compost is sold, distributed, or transported or offered for use, sale, or distribution shall itself prominently display or, if such display is not practicable, shall be accompanied by a shipping paper which shall prominently display the following: i) identification of the material as Type I sludge (compost)• MCC ii) the date of issuance of the Department Approval of Suitability for the Type I sludge/compost and the expiration date thereof. iii) instructions for land applying the material in accordance with proper agricultural practice, including, but not limited to, identification of proper agronomic application rates which shall not cause exceedence of the nitrogen requirements of the crop to be grown or intended to be grown. iv) Type I sludge/compost containing more than 10 parts per million of molybdenum shall be accompanied by a written warning that the sludge should not be used on pasture lands subject to grazing or on lands where crops are grown or intended to be grown for forage. Use of the sludge/compost under these circumstances may result in forage crops containing levels of molybdenum which are toxic to ruminants. v) all other instructions and information required by law. 3. Record Keeping. The Town shall comply with all the record keeping requirements of 310 CMR 32.60, including the submission to the Department of an annual report pursuant to section 32.60(2)(c) which shall be due on February 1 of the calendar year following the date the Department issued the approval of suitability until such time as all material hereby classified is utilized. Upon utilization of all material, the report shall be submitted within 30 days or by February 1, whichever is sooner. The Department reserves the right to rescind, suspend or modify this approval by the imposition of additional conditions or amendments to the stated conditions based on determining any actual or potential adverse impacts resulting from the conduct of this project. The Mansfield Board of Health, in a letter dated July 17, 1997, approved of the proposal for classification of Mansfield compost as proposed and acted upon by this approval letter. This approval fulfills the obligation of 310 CMR 32.14(2) which requires the written concurrence of the board of health prior to Type I approval by the Department. This Permit is an action of the Department. If you are aggrieved by this action, you may request an adjudicatory hearing. A Notice of Claim for an Adjudicatory Hearing must be made in writing and postmarked within thirty (30) days of the date this permit was issued. Pursuant to 310 CMR 1.01(6), the Notice of Claim shall state clearly and concisely the facts which are grounds for the proceeding and the relief sought. -4- The Notice of Claim, along with a valid check payable to the Commonwealth of Massachusetts in the amount of one hundred dollars ($100.00), must be mailed to: Commonwealth of Massachusetts Department of Environmental Protection P.O. Box 4062 Boston, MA 02211 The Notice will be dismissed if the filing fee is not paid, unless the appellant is exempt or granted a waiver as described in 310 CMR 4.00. If you have any questions, please contact Mr. Richard Rondeau at (508) 946-2816. Very tru e yours, z-�_ ck Hamm, Chief j'aunton River Watershed G/RR/bh CC: Mr. Kenneth Hackett Town of Mansfield WPCF 50 West St. Mansfield, MA 02048 Mr. James Small Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Ms. Lynne M. Moss Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Mr. Scott Leite, Agent Board of Health 50 West St. Mansfield, MA 02048 DEP-SERO ATTN: Jeffrey Gould DEP-MILLBURY ATTN: Larry Polese TOWN OF MANSFIELD, MASSACHUSETTS 50 West Street, Mansfield, MA 02048 July 17, 1997 Mr. Richard Rondeau Division of Water Pollution Control Department of Environmental Protection 20 Riverside Drive Lakeville, MA 02347 RE: MANSFIELD--Administrative Review, BRPW29, Residuals Approval of Suitability, Water Pollution Control, Sludge Composting Facility, Off Fruit Street Dear Mr. Rondeau, Please be advised that the Mansfield Board of Health concurs with the owner of the above referenced facility in its wish to distribute and/or market compost from the above referenced disposal. If I can be of further assistance, please do not hesitate to contact me. Yolottte/ y, Sc, Health Agent WILLIAM F. WELD Governor ARGEO PAUL CELLUCCI Lt. Governor COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE March 7, 1997 TRUDY COXE Secretary DAVID It. STRUHS Commissioner Mr. Scott Leite, Agent RE: MANSFIELD--Administrative Review, Board of Health BRPWP29, Residuals Approval of 50 West St. Suitability, Water Pollution Mansfield, Massachusetts 02048 Control, Sludge Composting Facility, Off Fruit Street, Transmittal No. 115018 Dear Mr. Leite: The Town of Mansfield has applied to the Department of Environmental Protection, Division of Water Pollution Control, for an Approval of Suitability for Type 1 and Type 3 residual sludge compost currently stockpiled at the composting facility. It is the understanding of the Department that the Mansfield Board of Health has received a copy of the subject application, in compliance with 310 CMR 32.14(1)(c). 310 CMR 32.14(2) states that "...The Department shall not approve the use, sale, or distribution or offering for use, sale, or distribution of Type I sludge without the written concurrence of the board of health of the city or town in which the owner's or operator's facility is located, provided that such concurrence is not unreasonably withheld. Said board of health shall be deemed to have given such concurrence unless it gives written notice to the contrary to the Department not later than 35 days after the date of notice given the board of health pursuant to the first sentence of 310 CMR 32.14(2).n Accordingly, the Department requests that the Board review the subject proposal and indicate in writing its approval or disapproval of the proposed project. Such response should be sent to Richard Rondeau of my staff at the below address. 20 Riverside Drive • Lakeville, Massachusetts 02347 9 FAX(508) 947-6557 • Telephone (508) 946-2700 -2- If you have any questions, please contact Richard Rondeau at (508) 946-2816. Very truly you Jef;rb%E ld, Chief Wat ��\\ ti n Control Section G/RR/cb CC: Mr. Lee Azinheira, Town Engineer Town of Mansfield 6 Park Row Mansfield, MA 02048 Mr. Kenneth Hackett Town of Mansfield WPCF 50 West St. Mansfield, MA 02048 Mr. James Small Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Ms. Lynne M. Moss Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 DEP-MILLBURY ATTN: Larry Polese TOWN OF MANSFIELD, MASSACHUSETTS Six Park Row, Mansfield, MA 02048 January 20,1997 Mr. Rick Rondeau Department of Environmental Protection Southeast Region Office 20 Riverside Drive Lakeville, MA 02347 Subject: Town of Mansfield, Massachusetts Application for Approval of Suitability (AOS) Transmittal No.115018 Dear Mr. Rondeau: Enclosed you will find an AOS application for stockpiled compost at the Mansfield Composting Facility, The application was prepared on behalf of the Town by Camp Dresser & McKee Inc. (CDM). The town of Mansfield has successfully composted biosolids since 1987 using the static pile method. Approximately 50 percent of the annual quantity of sludge is composted during the warm -weather months with the remainder landfill in an on -site sludge -only landfill. Since that time the town has stockpiled approximately 9,000 cubic yards of finished biosolids compost product. Marketing or other utilization of the compost has not been a priority of the town because the composting site had sufficient storage area and during the first few years of operation some metals concentration were high (due in part to lack of corrosion control in the town's water system). The compost product stockpile area is nearing capacity and the town has recently decided to initiate design for facility improvements that will allow year-round composting. Simultaneously, sludge metal concentrations have decreased due to establishment and enforcement of an industrial pretreatment program and the initiation of corrosion control for some of the town's drinking water supply wells. Also the town has received proposals to distribute and/or market the compost product. Therefore, this AOS is intended to result in a sludge "typing" that will allow the town to distribute the compost product, Based on analytical data presented in the AOS, the Town requests that a portion of the compost be classified as Type I material (specifically, stockpiles generated from 1992 through 1995), with the remainder (generated from 1987 to 1991) classified as Type III material. The basis for this request is detailed below. Deviations from analytical protocols are also noted. Basis for Classification Request It is our understanding that composts must meet 310 CMR 32 requirements for stabilization, metals content, and PCB content. Compliance with each of these requirements is highlighted below. ■ Stabilization (time and temperature). Time and temperature records for 1988 through 1995 are attached for your reference in Attachment B. Mr. Rick Rondeau January 20,1997 Page 2 Proposed Type I compost: Stockpiles 6, 7, 8, and 9 meet the requirements of 310 CMR 81 (1), compliance with which is mandatory for Type I materials. Records for stockpiles 7, 8, and 9 (generated in 1993,1994, and 1995, respectively) demonstrate that each individual pile contributing to the stockpiles achieved 55°C for three consecutive days. For stockpile 6 (1992), 32 out of 35 individual piles also met the criteria. In the remaining three individual piles (#12,14, and 17), the average temperature of three measurements exceeded the 55°C criterion. (Operators typically take three measurement per day in a cross-section of the pile.) To assure that stockpiles 6, 7, 8, and 9 all achieved adequate pathogen reduction each stockpile was checked based on the EPA Part 503 limit of less than 1000 fecal coliforms per gram of dry solids. All four stockpiles has less than 10 fecal coliforms per gram and thus meet Type I requirements. Proposed Type III materials: Composts generated in 1988, 1989, 1990, and 1991 generally met time and temperature requirements for Type I materials. Several individual piles constructed in those years did not hit 55°C in all sections of the pile; for these piles, however, the average of cross -sectional temperatures exceeded 55°C. In some other cases, temperature measurements were not taken on consecutive calender days because the facility is operated 5 days per week. Consecutive readings indicate compliance with the high temperature composting criteria though the readings were not necessarily performed on consecutive calender days. The following chart shows which individual piles are impacted by either of these two issues are listed below: Production Year Compost Stockpile Number Cross-section Temperatures Averaged - Pile Numbers Measurements on Non-consecutive Calender Days - Pile Numbers 1988 2 33,43 33, 34, 50 1989 3 18, 19,23 21,24 1990 4 35, 36 29, 30, 34 1991 5 9 8, 14, 15, 17, 20, 21 We assert that the these compost in stockpiles 2, 3, 4, and 5 meets the intent of the stabilization requirements - namely the reduction of pathogens. This assertion is supported by fecal coliform testing performed on each stockpile. The testing revealed concentrations ranging from <10 to 150 fecal coliforms/g for these stockpiles. The fecal coliform concentrations in the stockpiles are well within the EPA Class A criteria of 1,000 fecal coliforms/g. For stockpile 1, generated in the first year of the plant's operation, no time and temperature data was collected but is not available. Pathogen testing shows a fecal Mr. Rick Rondeau January 20,1997 Page 3 coliform concentration of 30/g, and we believe this well -aged material to be stabilized. Also note that the plant adds roughly 0.27 lb lime/lb dry sludge for dewatering purposes - a dosage that is also capable of substantial pathogen reduction. Although the compost in stockpiles 1,2,3,4 and 5 is well stabilized, we propose that this material be classified as Type III material based on metal concentrations as discussed below. Metal and PCBs. Table 1 summarizes the metal and PCB data contained in the AOS application. Each sample collected represents a discrete pile generated in a single compost production year. (Sample C-2, for example, was collected from stockpile 2, which was generated in 1988). As shown in the Table, compost in stockpiles 1 through 7 each exceed Type I cadmium and/or copper concentrations. All other metals (and PCBs) meet Type I criteria. The remaining piles (1, 2, 3, 4, and 5) each exceed Type II criteria for cadmium and/or copper and must be classified as Type III materials. Deviations from Approved Protocol Analytical methods used varied from the protocol for mercury, nitrate and pH. For mercury, the protocol specified EPA 200.7/6010. Method 7471, which the CDM laboratory indicates is the preferred test for this constituent, was used instead. EPA Method 353.1 was used to measure nitrate concentrations. Lab staff indicate that the method specified in the protocol (Method 352.1) was at one time the preferred method for nitrate analysis, but that it has now been superseded by Method 353.1. Finally, pH was measured using methods specififed in Methods of Soil Analysis, Part 2: Chemical & Biological Properties. This is standard procedure for soil (and soil -like) samples. Please contact Lynne Hersho Moss of CDM at (617) 252-8379 if you have any questions regarding this transmittal. Very truly yours, r Lee Azinheira, .E Town Engineer att. cc: K. Hackett, Mansfield Mansfield Board of Health J. Small, CDM L. Moss, CDM no rJ c 0 U 0 a 0 0 U Y O U 0 •a U 2f Y O V 0 .a a g O O V ^ 0 p N O O ti ti V ^ u V U� 0 erf O a O V Ot � V N� Oe P O Ot Q Y b C N 0 a _p U P U V V N^ O b O b M V Y Q C Q � U� O _ V b Md' VP V v vjr�j ^ N y vNi e Q V 0 .ap e J P 3 v � e o U o �-1 rt $3 E E U } 'a '� a a u o u co u C 0 4 cv"60J D E. P Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection Southeast Regional Office Wllllam F. Weld Gowma Argeo Paul cel cl U.`"�� . Gowmot /�^% .. February 14, 1996 F E B 1 6 1996 Trudy Coxe Be retnry David B. SUuhs Commleeloner Mr. Kenneth F. Hackett RE: MANSFIELD--Residuals Sampling and Town of Mansfield Analysis Plan, BRPWP28, Water 50 West Street Pollution Control, Sludge Mansfield, Massachusetts 02048 Composting Facility, Off Fruit Street, Permit No. 111986 Dear Mr. Hackett: The Department is in receipt of a Sampling and Analysis Plan prepared by your consultant, Camp Dresser & McKee, Inc. on behalf of the Town of Mansfield regarding compost product stored at the Mansfield Composting Facility, off Fruit Street, in Mansfield, Massachusetts under Transmittal No. 111986. The Town of Mansfield is seeking a Type I Approval of Suitability (classification) for the compost which is intended to be distributed for beneficial use in Massachusetts. Please note, the Town understands that, based on anticipated sampling results, a Type 2 Approval of Suitability may ultimately be granted by the Department. The Town currently has nine existing individual compost piles onsite which consist of compost which was generated between 1987 and 1995 with each pile representing one years worth of production. In order to characterize the compost, representative sampling will be performed on each pile of compost. Nine composite samples, one from each pile, will be collected for analyses. Each composite sample will be created from eight grab samples. Each grab sample will be collected from a different location in the compost pile at a depth of approximately four feet. These eight locations shall be selected so as to best represent the entire range of compost in each pile. A duplicate sample will be created from one of the nine compost piles to serve as a quality assurance/quality control mechanism for laboratory results. Analysis will include one TCLP sample which will include a portion of each of the nine pile composite samples. Analytical services for compost testing are to be provided by four separate laboratories, only three of which will be performing the required testing under 310 CMR 32.00. These three labs are Camp Dresser & McKee Laboratory of Cambridge, Massachusetts, Lapuk Laboratories of Watertown, Massachusetts and A&L Eastern Agricultural Laboratories of Richmond, Virginia. The Camp Dresser & McKee Laboratory will be performing PCB, metals and TCLP analyses and A&L Eastern Agricultural Laboratories will be performing the other required chemical analyses. Lapuk Laboratories will 20 Riverside Drive a Lakeville, Massachusetts 02347 a FAX (508) 947.6557 • Telephone (508) 946.27DO w gy Primed on Recycled Paper -2- be performing stabilization testing in accordance with EPA part 503 regulations. The Department finds that these laboratories are acceptable to perform the requisite analysis required under 310 CMR 32.00. A fourth lab, Woods End Research Laboratory, Inc., will be used to assess other marketability criteria not required under 310 CMR 32.00. Please be advised, it is the responsibility of the consultant to ensure that adequate sample volumes are collected commensurate with laboratory distribution and testing as outlined above. Also, in reporting data from the proposed analysis, the Department wishes to reinforce the selection of detection limits which are at least as low as the classification criteria set forth in 310 CMR 32.12. Detection limits which are too high will invalidate the associated analytical results. The Department has completed its review of the sampling and analysis plan and has determined that it complies with the requirements of Massachusetts Land Application Regulations. Based on this review, the Department hereby approves the Plan with the following conditions and understandings of approval: 1. All sampling and analysis shall be performed in accordance with the application submitted by the applicant. Any proposed changes must be approved by the Department. 2. If available, temperature data for all existing compost piles which are to be classified should accompany the chemical quality and stabilization data at the time the Application for Approval of Suitability (BRPWP29) is submitted. 3. Parameters to be sampled for shall include those listed in 310 CMR 32.13(5) and Table 1 and Table 2 in the application for Approval of Suitability (BRPWP29). 4. All analyses shall be performed using approved test procedures in accordance with the List of Approved Test Procedures for Sludge Parameter contained in the Sampling and Analysis Plan Approval application (BRPWP28) Any deviations must be explained in the application for Approval of Suitability (BRPWP29). 5. If the compost appears highly variable during sampling, additional samples may be required in order to determine the classification of the final compost material. The Department reserves the right to rescind, suspend or modify this approval by the imposition of additional conditions or amendments to the stated conditions based on determining any actual or potential adverse impacts resulting from the conduct of this project. -3- If-you have any questions, please contact Mr (508) 94672816. Very Jef Wat G/RR/ir cc: Mr. Dan Clifford, Director Department of Public Works 50 West Street Mansfield, MA 02048 Mr. William Williams, Town Manager Town Hall 50 West Street Mansfield, MA 02048 Mr. James Small Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Ms. Lynne M. Hersho Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 DEP - MILLBURY ATTN: Larry Polese Richard Rondeau at Section TOWN OF MANSFIELD, MASSACHUSETTS 50 West Street, Mansfield, MA 02048 November 29, 1984 Mr. Joseph Zeneski DPW Director Town Hall Mansfield, MA 02048 Dear Mr. Zeneski: The Board of Health would like to invite you to our meeting on Wednesday, December 5, 1984, at 8:00 P.M. At such time we would like to discuss the Board's approval of the sludge landfill pro- ject off Fruit Street as required in the MGLA, Chapter 111, Section 150A. If there are any questions, please call the health office. Sincerely, Edward. J. Tartufo Chairman sc TOWN OF MANSFIELD, MASSACHUSETTS DPW January 31, 1984 D.E.Q.E. Lakeville Hospital Lakeville, MA 02346 Attention: Mr. Phil Ripa Reference: Telephone Conversation 1-11-84 Septage Handling Mansfield W.W.T.P. Gentlemen: 50 West Street, Mansfield, MA 02048 FF6 1 1984 The Town of Mansfield has taken steps to handle septage generated within the town at the treatment facility on Fruit Street. The action is being taken on an experimental basis with strict conformance with effluent dis- charge limitations. The existing sewage treatment plant on Fruit Street is a secondary treat- ment system utilizing extended aeration with settling and chlorination for most of the flow and trickling filters preceded and followed by sett- ling with final chlorination. The entire flow enters lagoons for addi- tional settling. The sludges (primary, secondary, and trickling filter) are treated in aerobic digestors, chemically conditioned, and dewatered. The aerobic digestion system has been modified to allow the introduction of septage into one of the two 100,000 gallon tanks. The tank can be operated to mechanically mix and aerate the septage, then shut off to allow settling (thickening). The settled septage sludge can then be fil- tered in the same manner as other sludges and the clear supernatant can be bled back to either the extended aeration stream or to the trickling filter stream. The system has the lize the usually handling and in addition of any ment, handling, adding chlorine odorants. flexibility to allow the addition of lime to neutra- very acidic septage. This will help in septage sludge odor control. The system also allows for the controlled or all of the other sludges to enhance septage treat - or dewatering. Odor control will be achieved by either by way of a portable chlorination unit or by use of de- To: Mr. Phil Ripa Page 2 January 31, 1984 We have established a separate account to keep track of the cost of oper- ating the septage treatment stream. We are presently charging pumpers $10.00/thousand gallons and expect that this will cover all costs at our estimated safe operating rate of 11,000 gpd. We are only receiving sep- tage from haulers who can document that the load was from systems loca- ted in Mansfield. If you have any questions or comments regarding our system, please call me. Very truly yours, OF PUBLIC WORKS .. M.\Zeneski „P.E. cc: Board of Health Town Manager JMZ/eac 1'0NVJ'N OF N,1.AN'SF[F,I,1), N4X;SACHUSETTS MEMORANDUM To: Town ManagevN From: DPW Directo Subject: Septage Han in SUMMARY 50 West Street, Mansfield, MA 02048 January 18, 1984 JAN 2 6 1984 On Tuesday, January 10, 1984, I was informed by you, from Boston, that you had met with the MDC and learned that septage haulers serving Mansfield would no longer be allowed to dump in the receiving station in Walpole. By Friday, January 13, 1984, we were receiving septage on an experimental basis from haulers working in Mansfield. We have responded to a problem in a most efficient and technically correct manner. The speed of our response is due to the cooperation and dedication of our wastewater treatment plant personnel, our office staff, Town Accoun- tant Barbara Hagg and Health Agent Karl Drown. The following is a documen- tation of the sequence of events and the technical problems that were encountered and solved. CHRONOLOGY Tuesday, January 10, 1984 The Town was officially informed;;that haulers working in Mansfield will no'longer-be allowed to dump at the MDC station in Walpole. The Town Manager immediately'informed the DPW Director and Health Agent that actions would have to be taken to find an alternative. The Health,Agent immediately began. calling other communities and sewer system operators to explore use of those systems. Simultaneously, the DPW Director began exploring the possibility of accepting septage on a limited basis at the Fruit Street treatment plant. During meetings with C.D.M. representatives previously scheduled for inspection of the new treatment plant in Norton, the Director and Sewer Division Supervisor reviewed possible septage treatment actions to be taken at the Fruit Street plant. It was decided to accept a limited amount of septage in one of the sludge digestion tanks whereby the septage could be isolated from the main treatment stream. To: Town Manager Page 4 January 18, 1984 ADMINISTRATION There is a real need to maintain proper records on septage receipts for billing and control purposes. We, therefore, are using a three-part work order form to document from whom the septage was received and the total quantity. This is signed by the driver to acknowledge his obligation to pay for the service and endorse his statement of septage source. The driver receives a copy for his records; the office receives a copy for billing and Bill Handy keeps a copy to spot check on septage pumping. Pumpers understand that if they are caught cheating or do not pay prompt- ly, they will be denied use of the facility. COST RECOVERY Based on fixed costs of about $350. per week for electricity, $85, per week for labor and $2.00 per thousand gallons for chemicals, the charge of $10.00 per thousand gallons will result in "break-even" at about 55,000 gallons per week or 11,000 gpd during working hours. If actual costs vary, however, we will adjust the rate to properly recover the costs of septage treatment. The actural mechanism for cost recover will be through weekly bills sent out from the DPW office. SIDE BENEFI There are a couple of extra benefits in the operation we're undertaking: 1. The Board of Health will have a record of septage pumping in town. 2. We will acquire experience in septage treatment that will be useful at the new facility. 3. We are maximizing the use of the existing faciltiy. JMZ/cb To: Town Manager Page 3 January 18, 1984 Friday, January 13, 1984 - Three (3) days after formal notifi- cation from the MDC, the Mansfield treatment plant on Fruit Street was ready to accept and treat septage from non-sewered buildings in Mansfield. The modifications included structural changes, paper work for recording/verification and a billing system for proper cost recovery. TREATMENT SYSTEM The existing sewage treatment plant on Fruit Street is a secondary treatment system utilizing extended aeration with settling and chlorination for most of the flow and trickling filters preceded and followed by settling with chlorination. The entire flow enters lagoons for additional settling during the summer months. The sludges (primary, secondary and the trickling filter) are separately treated in aerobic digestors chemically conditioned and filtered. The filtered sludge is mixed with sand/gravel and used as cover material at the landfill. The aerobic digestion system has been modified to allow the introduction of septage into one of the two 100,000 gallon tanks. The tank can be operated to mix and add air to the septage, then shut off to allow settling (thick- ening). The settled septage sludge can then be filtered in the same manner as other sludges and the clear supernatant can be bled back either to the extended aeration stream or to the trickling filter stream (followed by chlorination and disposal). The system has the flexibility to allow the addition of lime to neutralize the usually very acidic septage. This will help in septage sludge handling and in odor control. The system also allows for the controlled addition of any or all of the other sludges to enhance septage treatment, handling or dewatering. Odor control can be achieved by either adding chlorine by use of a portable chlorination unit or by the purchase of deoderants (purchanse is expensive and will obly be considered if warranted). COSTS The Town.Accountant has established jobbing account numbers for labor and material costs associated with the septage handling. Thus far, we spent about $750.00 in overtime wages in cleaning out the existing aerobic digestor. We've presently accrued no costs for materials. We expect, hbwever, to be spending for lime (2 to 5 pounds per thousand gallons) and electricity (we'll be running a 40hp motor to aerate the septage). In order to keep the cost of septage handling separate, we will be charging the septage jobbing account when labor is involved in receiving, proces- sing or dewatering sludge. To: Town Manager Page 2 January 18, 1984 On Tuesday evening, DPW Wastewater Treatment Section personnel worked overtime to dewater and process the sludge that was being stored in one of the aerobic digestors. This was necessary to make room for the septage that we expected to receive. 'Wednesday, January 11, 1984 - Steps were taken to refine the envisioned septage treatment process by locating a suitable re- ceiving point and making structural modifications to control the inflow and "bleed off" to the main treatment stream. A meeting with septage haulers was scheduled for Thursday morning. This meeting was desired to determine how much septage would have to be handled and whether it could be accomodated at the Fruit Street plant: Mr. Phil Ripa of Massachusetts D.E.Q.E. Southeast Region was contacted regarding the situation. He informed us that the State would have no problem with the proposal as long as it did not adversely affect the quality of effluent. He agreed that the concept of a separate treatment stream with control of "bleed off" to the main stream was a reasonable approach. The Town Accountant and DPW Director discussed the matter of bil- ling for septage handling/treatment. It was agreed that in order to retain flexibility and to be consistent with the concept of the enterprise account for wastewater treatment, a jobbing account would be established to separate the actual cost of septage hand- ling/treatment and allow recovery of those costs from the haulers (and ultimately from the homeowner) and not from the regular sewer customer. 'Thursday, January 12, 1984 - A meeting was held with five (5)'of the 20 septage pumpers holding permits from the Board of Health. It was determined that they would produce about 10,000 to 15,000 gpd. It was further established that some changes in our orig- inal concept for management and charging should be made to better control and recover the costs of handling septage. Each of the haulers was invited to visit the site and offer comments on receiving facilities. An administration and cost recovery plan was developed and pre- sented to the Town Manager. WILLIAM F. WELD Governor ARGEO PAUL CELLUCCI Lt. Governor COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE March 7, 1997 TRUDY COXE Secretary DAVID B. STRUHS Commissioner Mr. Scott Leite, Agent RE: MANSFIELD--Administrative Review, Board of Health BRPWP29, Residuals Approval of 50 West St. Suitability, Water Pollution Mansfield, Massachusetts 02048 Control, Sludge Composting Facility, Off Fruit Street, Transmittal No. 115018 Dear Mr. Leite: The Town of Mansfield has applied to the Department of Environmental Protection, Division of Water Pollution Control, for an Approval of Suitability for Type 1 and Type 3 residual sludge compost currently stockpiled at the composting facility. It is the understanding of the Department that the Mansfield Board of Health has received a copy of the subject application, in compliance with 310 CMR 32.14(1)(c). 310 CMR 32.14(2) states that "...The Department shall not approve the use, sale, or distribution or offering for use, sale, or distribution of Type I sludge without the written concurrence of the board of health of the city or town in which the owner's or operator's facility is located, provided that such concurrence is not unreasonably withheld. Said board of health shall be deemed to have given such c.oncurren.cc unless it gives written notice to the contrary to the Department not later than 35 days after the date of notice given the board of health pursuant to the first sentence of 310 CMR 32.14(2)." Accordingly, the Department requests that the Board review the subject proposal and indicate in writing its approval or disapproval of the proposed project. Such response should be sent to Richard Rondeau of my staff at thebelow address. 20 Riverside Drive 0 Lakeville, Massachusetts 02347 0 FAX(508) 947-6557 0 Telephone (508) 946-2700 -2- If you have any questions, please contact Richard Rondeau at (508) 946-2816. action G/RR/cb CC: Mr. Lee Azinheira, Town Engineer Town of Mansfield 6 Park Row Mansfield, MA 02048 Mr. Kenneth Hackett Town of Mansfield WPCF 50 West St. Mansfield, MA 02048 Mr. James Small Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Ms. Lynne M. Moss Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 DEP-MILLBURY ATTN: Larry Polese COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION SOUTHEAST REGIONAL OFFICE WILLIAM F. WELD Govemor ARGEO PAUL,CELLUCCI Lt. Govemor Mr. Lee Azinheira, Town Engineer Town of Mansfield 6 Park Row Mansfield, Massachusetts 02048 Dear Mr. Azinheira: TRUDY COXE Secretary DAVID B. STRUHS Commissioner March 6, 1997 RE: MANSFIELD--Administrative Review, BRPWP29, Residuals Approval of Suitability, Water Pollution Control, Sludge Composting Facility, Off Fruit Street, Transmittal No. 115018 The Department has completed its Administrative Review of the permit application listed above and determined that the application is administratively complete. Accordingly, the Department will begin its Technical Review. According to 310 CMR 4.04, the Department now has sixty (60) days to complete its Technical Review and issue a final decision to grant or deny the permit. Provided your application is technically adequate, and none of the contingencies outlined in 310 CMR 4.04 occur, the Department will issue a final decision within the timeframes listed above. If you have any questions, please contact Richard Rondeau at (508) 946-2816. Very tryily Je G/RR/.cb CC: Mr. Kenneth Hackett Town of Mansfield WPCF 50 West St. Mansfield, MA 02048 Control Section 20 Riverside Drive 0 Lakeville, Massachusetts 02347 0 FAX(508) 947-6557 0 Telephone (508) 946-2700 -2- cc: Mr. James Small Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Ms. Lynne M. Moss Camp Dresser & McKee Inc. 10 Cambridge Center Cambridge, MA 02142 Mr. Scott Leite, Agent Board of Health 50 West St. Mansfield, MA 02048 DEP-MILLBURY ATTN: Larry Polese a 0 Town of Mansfield, Massachusetts Sludge Management Study August 1996 0 e V Contents List of Figures List of Tables Section 1 Background and Approach ......................................... 1-1 1.1 Background ................................................. 1.2 Approach .................................................. 1-1 1-1 Section 2 Existing Sludge Management Practices ............................... 2-1 2.1 Description ................................................. 2-1 Section 3 Evaluation of Sludge Management Alternatives ......................... 3-1 3.1 Alternatives Evaluated 3-1 ........................................ 3.2 Evaluation Considerations ..................................... 3-1 3.2.1 Sludge Production ...................................... 3-1 3.2.2 Sludge Quality .......................... 3-2 3.2.3 Landfill Reclamation Potential ............................. 3-2 4 w L Section 4 3.2.4 Equipment Replacement Needs ........................... 3-4 3.3 Evaluation Criteria ................ 3-4 3.3.1 Life -cycle Costs ....................................... 3.4 3.3.2 Non -cost Factors ....................................... 3-6 3.4 Alternative Descriptions and Evaluations .......................... 3-6 3.4.1 Scenario 1: Continuation of Existing Practice ................. 3-8 3.4.2 Scenario 2: Full -year Composting with Woodchips ........... 3-11 3.4.3 Scenario 3: Full -year Composting with Sawdust ............. 3-15 3.4.4 Scenario 4: Full -year Landfilling .......................... 3-18 3.4.5 Scenario 5: Hauling Liquid Sludge ........................ 3-18 3.4.6 Scenario 6: Hauling Dewatered Sludge .................... 3-24 3.5 Evaluation Summary ........................................ 3-27 Recommendation................................................ 4-1 CDM Camp Dresser & McKee 2DI-IG AT-4TSK t Contents (continued) 0 Appendices A 8 C Stockpiled Compost Quality Assessment Stockpiled Compost Procurement Package Request for Modification to the Landfill Operating Permit CDM Camp Dresser 6t McKee 201-160-RT-4TSK ii List of Figures Figure 3-1 Proposed Compost Roof Structure ................................ 3-12 3-2 Non -Cost Evaluation Summary .................................. 3-29 CDM Camp Dresser & McKee 201-160-RTATSK 111 List of Tables Table 3-1 Current Sludge Production ........................................ 3-3 3-2 WPC Design Criteria ............................................ 3-3 3-3 Equipment Replacement Schedule ................................. 3-5 3-4 Cost Estimate Assumptions ...................................... 3-7 3-5 Estimated Costs: Scenario - Continuation of Existing Operations Current Sludge Production ........................................ 3-9 3-6 Estimated Costs: Scenario - Continuation of Existing Operations Design Sludge Production ....................................... 3-10 3-7 Estimated Costs: Scenario 2 - Year Round Composting with Woodchips Current Sludge Production ....................................... 3-13 3-8 Estimated Costs: Scenario 2 - Year Round Composting with Woodchips Design Sludge Production ........................................ 3-14 3-9 Estimated Costs: Scenario 3 - Year Round Composting with Sawdust Current Sludge Production ....................................... 3-16 3-10 Estimated Costs: Scenario 3 - Year Round Composting with Sawdust Design Sludge Production ....................................... 3-17 3-11 Estimated Costs: Scenario 4 - Year Round Landfilling Current Sludge Production ....................................... 3-19 3-12 Estimated Costs: Scenario 4 - Year Round Landfilling Design Sludge Production ............. I......................... 3-20 3-13 Estimated Costs: Scenario 5 - Liquid Haul and Disposal Current Sludge Production ....................................... 3-22 3-14 Estimated Costs: Scenario 5 - Liquid Haul and Disposal Design Sludge Production ....................................... 3-23 3-15 Estimated Costs: Scenario 6 - Cake Haul and Disposal Current Sludge Production ....................................... 3-25 3-16 Estimated Costs: Scenario 6 - Cake Haul and Disposal Design Sludge Production ....................................... 3-26 3-17 Cost Summary for Sludge Management Study ...................... 3-28 CDM Camp Dresser & McKee 201460flT-0TSK iv One Section 1 Background and Approach 1.1 Background Since the Town of Mansfield constructed its sludge composting and landfill facilities in 1985, the number and nature of sludge management options available to municipalities has in- creased dramatically, especially in the area of commercial enterprises. Looking to the future, the Town wishes to ensure that their current operation remains cost-effective. This study has been commissioned to assess the cost-effectiveness of current operations as compared to a variety of sludge management alternatives. The study is actually one of four studies that Camp Dresser & McKee Inc. (CDM) is currently performing for the Town with regard to sludge management issues. Concurrent studies and their corresponding status are as follows: ■ Assessment of stockpiled compost quality. This study has been completed and is included in this report as Appendix A. ■ Assistance to the Town in their efforts to market existing compost. To meet this objective CDM prepared a preocurement package for the Town. The package is included here as Appendix B. ■ Assessment of the feasibility of landfill reclamation. DEP staff have indicated that onsite reclamation may be a viable alternative for the Town. A letter to the DEP requesting a permit modification to allow reclamation activities is presented in Appendix C. 1.2 Approach To meet the objectives of this study, six sludge management alternatives were evaluated, including a continuation of existing practices. Alternatives were compared on both a cost and a non -cost basis. Cost comparisons considered life -cycle costs, developed for a 20-year planning period. Non -cost evaluations considered the relative merits of the alternatives with respect to factors such as implementability, reliability, environmental impacts, beneficial use potential, and revenue potential. Based on these assessments, preferred alternatives were identified. El 14 CDM Camp Dresser & McKee 201A TATS 1.1 0 i !I D 4 I I, I U n tion Two Section 2 Existing Sludge Management Practices 2.1 Description The Town of Mansfield Water Pollution Control Facility (WPCF), located in Norton, Massa- chusetts, provides secondary treatment for wastewaters generated in both Mansfield and Norton. The WPCF was constructed in 1985 (replacing an older facility in Mansfield) and has a design capacity of 3.14 million gallons per day (MGD). The plant currently treats about 2.0 MGD. Sludge produced at the plant is a mixture of primary and secondary solids. Mixed primary and secondary solids are co -thickened in clariflocculators and then transferred to a sludge holding tank at a solids concentration ranging from 3.5 to 5.5 percent. Thickened sludge is conditioned using ferric chloride and lime and -then dewatered onsite using plate and frame presses. The solids content of the dewatered sludge ranges from 32 percent to 39 percent, Dewatered sludge is transported by dump truck to the old wastewater treatment site in Mansfield (the "Fruit Street" site) for composting in the warmest six months (generally May to October) and landfilling in the coldest six months (November to April). A total of about 1,372 dry tons of sludge per year are composted or landfilled at the site. The Town is currently operating the second of three landfill cells at the site. One of the three cells is full, and the active cell will soon reach capacity, leaving one cell remaining for future use. The Town currently spreads the sludge in the active cell, and covers the newly deposited material with gravel on a daily basis. A crawler loader is used for the spreading and covering operations. Approximately three cubic yards of gravel are used to cover each cubic yard of landfilled sludge. Composting at the site is performed using the aerated static pile method. Sludge is mixed with wood chips at a volumetric ratio of 1 part sludge to 1.5 to 2 parts woodchips (as determined by the operator). Both new and recycled chips are used in the mix. The mixed sludge and woodchips are transported by a front end loader to the active composting area to be placed in a composting pile. Before pile construction, a four to six inch bed of woodchips is placed on the ground. Perforated piping is placed in the woodchip bed to convey air from a blower through the bed and constructed pile. Composting material remains in the pile for 30 days, after which the pile is broken down, the woodchips are screened from the material and the screened compost is taken to the curing area. After 90 days of curing, the finished material is moved to the finished compost storage area. 14 CDM Camp Dresser & McKee 201.1GO-RT-4TSK 2-t I on Three Section 3 Evaluation of Sludge Management Alternatives 3.1 Alternatives Evaluated A total of six sludge management scenarios were evaluated. They are described in Section 3.4 and highlighted below. ■ Scenario 1: Continuation of Existing Practice. This alternative assumes that sludge management practices at Mansfield will remain essentially unchanged. Sludge will be dewatered, then composted in the warmer months and landfilled in the winter months. ■ Scenario 2: Full -year Composting with Woodchips. Under this alternative, landfilling of sludge would be eliminated and replaced with composting as currently practiced only in summer. A roof over the fictive composting pad and material storage areas would be required to implement this scenario. Blower improvements are recommended as well. ■ Scenario 3: Full -year Composting with Sawdust. This scenario differs from Scenario 2 only in that sawdust is used in place of woodchips as a composting amendment. ■ Scenario 4: Full -year Landitlling. This alternative assumes that all composting activity in Mansfield will cease and be replaced with onsite landfilling of dewatered sludge. ■ Scenario 5: Hauling Liquid Sludge for Offsite Processing/disposal. Under this scenario, dewatering operations at the WPCF would be eliminated, as would landfilling and composting operations. Liquid sludge would be hauled to privately -operated incinerator operations for subsequent processing. ■ Scenario 6: Hauling Dewatered Sludge for Offsite Processing/disposal. This alternative is similar to Scenario 5 in that sludge would be hauled to a commercial facility for process- ing or disposal. Unlike Scenario 5, however, the sludge would be dewatered (as currently practiced) at the WPCF prior to hauling. 3.2 Evaluation Considerations To develop sludge management alternatives and corresponding costs, a variety of factors must be considered and assumptions made. This section presents the considerations and assump- tions that provide the framework for alternative development. 3.2.1 Sludge Production To size sludge management facilities and estimate operating costs, it is important to know how much sludge must be handled both now and in the future. CDM Camp Dresser & McKee 3 1 201-i6o-aT4Tsx Section 3 Evaluation of Sludge Management Alternatives To estimate current production, CDM reviewed the WPCF sludge generation rates for 1993, 1994, and 1995 (see Table 3-1). As shown in the table, no growth trend in sludge production was observed during that period and so an average of 1,372 dry tons per year (dtpy) was used to estimate current sludge management costs. Estimating future sludge generation rates for the Town is more problematic. Factors that could affect future sludge generation at the plant include population growth in Mansfield, removal of infiltration and inflow from the system, and an increase in wastewater flow from other towns contributing to the WPCF. The Town is planning (but has not yet started) a facility plan to estimate future wastewater flows. In the absence of specific projections, we have assumed for this study a maximum future sludge generation rate equal to the design capacity of the WPCF. Design criteria from the plant, established in 1985 (see Table 3-2), indicates that "design year" sludge production is expected to be 3,161 dtpy. Because there is such a significant difference between current and design sludge production, compounded by uncertainty regarding future flows to the plant, costs for each sludge manage- ment alternative have been developed for two approaches. The first assumes that sludge generation will not increase over the next twenty years, while the second assumes that sludge generation will increase to the design capacity of the plant. These approaches dramatically affect operating costs for each alternative. Capital cost estimates are not affected, however, as all facilities and equipment required have been generally sized to accommodate design year sludge quantities. 3.2.2 Sludge Quality Sludge quality primarily impacts the viability of beneficial use options, such as composting, and is usually defined in terms of compliance with state and federal regulations. On the state level, the 310 CMR 32 regulations govern beneficial use; the 40 CFR 503 regulations fulfill this role on a federal level. Recent analyses of compost from Mansfield indicates that composts generated in the last three years are in compliance with the most stringent Massachusetts and federal regulations for inorganic constituents (see Appendix A). Further, all existing compost materi- als meet federal criteria for pathogen reduction (the Commonwealth does not have numeric criteria for pathogens). Sludge quality issues will be explored in greater depth in an upcoming CDM report. For this study, it is sufficient to know that the quality of compost generated at Mansfield will not limit its potential for beneficial use. 3.2.3 Landfill Reclamation Potential As noted previously, the Town has essentially filled two of the three available landfill cells on site. At current sludge production rates and cover material usage, the remaining cell capacity will be exhausted in about 5 years. dn CDM Camp Dresser & McKee 3-2 In I 201.160AT-4TSK TOWN OF MANSFIELD, MASSACHUSE77S SLUDGE MANAGEMENT STUDY TABLE 3-1 Current Sludge Production Year Sludge Quantities (Dry Tons per year) Lime Ferric Chloride Total 1993 1,030 279 74 1,383 1994 1,033 285 76 1,393 1995 m 279 ZQ 1.338 Average 1,017 281 73 1,372 TABLE 3-2 WPCF Design Criteria" Annual Sludge Production Dry Tons CY Initial Year (1985) 1,820 4,784 Design year' (2005) 3,161 8,372 `For original facility design Section 3 Evaluation of Sludge Management Alternatives To extend landfill capacity, the Town may wish to consider "reclaiming"existing landfill capacity. This process would involve excavating landfilled materials (initially from the oldest cell) and using the excavate as cover material for new sludge. The excavate is about 75% (or more) gravel, and its use could both reduce gravel costs and add landfill capacity without constructing new facilities. Excavated cells could potentially be refilled with gravel and sludge at a ratio of 2:1 (compared to the current 3:1 ratio), further extending landfill capacity. The validity of this assumption is contingent upon the purchase of new grading equipment for the landfill operation and a favorable outcome of slope stability studies. For this study, we have assumed that the assump- tion is valid. We also assumed that the landfill cells would be reclaimed only once as perpetual reclamation may have adverse effects on slope stability and cell integrity. The goals of the reclamation effort are: 1) to reduce the cover to sludge ratio in each cell to 2:1, thereby effectively adding landfill capacity. In order to begin reclaiming landfill capacity, the Town will need to obtain a modification to the existing operating permit for the landfill. Toward this end, CDM has prepared a letter to the DEP requesting a permit modification for the landfill (see Appendix C). The implementation issues outlined above must be resolved before the Town pursues landfill reclamation. As will be shown in Section 3.4, the economic benefits of this approach are significant, however, warranting further exploration of this procedure. 3.2.4 Equipment Replacement Needs Now eleven years old, some of the sludge management equipment at the WPCF, composting facility, and landfill will need to be replaced now or in the near future. Based upon discussions with WPCF staff, CDM developed an equipment replacement schedule, which is presented in Table 3-3. Table 3-3 also reflects the current cost of this equipment and the expected cost at time of replace- ment. Future replacement costs are based on an assumed inflation rate of 3%. 3.3 Evaluation Criteria 3.3.1 Life -cycle Costs An Equivalent Uniform Annualized Cost (EUAC) was developed for each sludge management alternative based upon estimated capital and operating costs. Essentially, the EUAC represents the annual cost outlay required if present and future operating costs and capital costs were to be evenly spread across the "life-cycle"(planning period) of 20 years used for this study. E CDM Camp Dresser & McKee 3.4 IN201.160AT,4TSK TOWN OF MANSFIELD, MASSACHUSETTS SLUDGE MANAGEMENT TABLE 3-3 Equipment Replacement Schedule Current Cost Year Replaced' Cost at Replacement' D wat ring Lime System',' $407,000 10 $547,000 L�doeg Bullzz$1001000 0 $100,000 Front End Loaders $195,000 5 $214,000 Trucks $110,000 5 $128,000 Composting Screen $150,000 0 $150,000 Mixer $105,000 5 $122,000 Front End Loaders $185,000 5 $214,000 Trucks' $110,000 5 $128,000 Blowers' $35,000 10 $47,000 Blower Electrical/Control System'' $75,000 10 $101,000 Botts: ' Denotes year replaced in 20-year planning period. Year 0 is assumed to be 1996. 'Inflated from current cost at a rate of 3%. 'Assumes replacement of mixers, slakers/feeders, and pumps. 'Includes engineering and contingency allowance of 35%. 'Maybe used for landfilling or composting operations. ' Reflects upgrade in site from 1hp to Shp. Section 3 Evaluation of Sludge Management Alternatives Capital costs developed for the study are generally based on design sludge quantities. Landfill construction costs were handled differently, however, since this approach was felt to be overly conservative for this application. For landfill sizing at currently sludge production, an average of current and design sludge quantities was used to size new facilities. For design production estimates, facilities were sized to accommodate 75% of the design production (as production will not reach design values 'overnight"). Assumptions used in the EUAC analyses are summarized in Table 3-4. 3.3.2 Non -cost Factors Although cost is of paramount concern in the selection of a sludge management strategy, other critical factors must be considered as well. For this study, each alternative was qualitatively evaluated with respect to the following factors: ■ implementability - this factor, considers regulatory acceptability of the alternative and public acceptance issues. ■ reliability - the selected alternative must provide a reliable outlet for sludge generated at the WPCF; this factor considers the accessibility of back-up measures should the primary outlet temporarily unavailable. ■ environmental impact - this factor considers the air quality, noise, aesthetic, and other environmental impacts of each sludge management alternative. ■ beneficial use potential - in this evaluation, alternatives that take advantage of the nutrients and organics in sludge through "recycling" methods such as composting are viewed more favorably than those that use sludge as a waste product. ■ revenue potential - although revenue from sludge product sales is not guaranteed, the potential for revenue generation must be considered in alternative evaluations. For this study, each alternative was given a favorable, neutral, or unfavorable rating for each of the above criteria. The non -cost evaluations were based be upon CDM experience with similar facilities and specific knowledge of Mansfield's operations. 3.4 Alternative Descriptions and Evaluations This section presents detailed descriptions of each alternative considered, costs associated with the alternatives and the non -cost evaluations. Equipment replacement needs, new facility needs, and alternative costs are presented in tabular form for each option. Non -cost evalua- tions are described in the text. All cost and non -cost evaluations are summarized in tabular form at the conclusion of the section. CDM Camp Dresser & McKee 3-6 2DI-160-aTdrs TOWN OF MANSFIELD, MASSACHUSETTS SLUDGE MANAGEMENT STUDY TABLE 3-4 Cost Estimate Assumptions Item Planning Period Discount Rate Inflation Rate Power Costs abor Costs' Supervising Operator Operator Skilled Laborer 2aterial Costs Fuel Sawdust Woodchips Disposable Piping Gravel Transportation Costs Engineering News Record Construction Cost Index & Contingency Allowance 1- includes salary cost plus 40% allowance for fringe benefits 20 Years 6.50% 3.00% $0.10/kw-hr $20.70/hr $20.60/hr $18.20/hr $0.64/gal $8.50/cubic yard $6.00/cubic yard $26.32/100 ft. $5.50/cubic yard $70/hr + $2.50/mile Travel Speed = 40 mi/hr 5,532 35% Jc., Evaluation of Sludge Management Alternatives N I J I I U 11 4 3.4.1 Scenario 1: Continuation of Existing Practice This alternative assumes that sludge management practices at Mansfield will remain essential- ly unchanged. Sludge will be dewatered at the WPCF, hauled to the Fruit Street site and composted in the warmer months and landfilled in the winter months. Proposed improve- ments are listed in Table 3-5 and 3-6 and are discussed below. D vr�terine. Only lime system equipment replacement is proposed. Lan fillingAssuming that filled landfill cells can be reclaimed as described in Section 3.2.3, and that the cover: sludge ratio is reduced to 2:1, CDM estimates that existing onsite landfill facilities can meet sludge disposal needs for about 10 years (about the same under current and design sizing assumptions), at which time new facilities would have to be constructed. The utilization of 2:1 covensludge ratios is contingent upon the purchase of a new low track pressure grader, which should facilitate improved landfiliing operations. com ostinn With the exception of a blower system upgrade, no major improvements other than equipment replacement are planned. The blower system upgrade includes replacement of the existing 1 horsepower (hp) blowers with 5 hp blowers and electrical system modifications required to support the larger blowers. The upgrade is timed to coincide with the expected need to replace the existing blowers (in 10 years). CDM recommends the upgrade to increase temperature control in the composting process. Since the Mansfield facility was constructed eleven years ago, practitioners have discovered that temperature control is critical to the generation of a stable compost product and, more importantly, that the air requirements for temperature control vastly exceed simple aeration needs (upon which the Mansfield blowers were sized). The upgrade is intended to bring the facility up-to-date with current compost science and minimize the curing time necessary to ensure product stability. The estimated costs for this alternative, assuming sludge production rates remain stable, are presented in Table 3-5. Corresponding costs assuming design sludge production values are presented in Table 3-6 and reflect the need to construct additional landfill capacity. From the perspective of reliability and environmental impact, this scenario is given a favorable rating. The flexibility of two onsite management methods (composting and landfilling) was the deciding factor with respect to reliability. Consistency with current practice, with a corre- sponding minimization of new facilities, additional traffic, odor emissions, etc, contributed to the favorable ranking with respect to environmental impact. With respect to all other criteria, the alternative has been assigned a neutral ranking - unce- rtainty regarding regulatory approval of landfill reclamation, and only partial beneficial use and revenue potential (as compared to full -year composting options) were deciding factors. lei CDM Camp Dresser & McKee 20W6Of)T-4TSK TUt',., Ui� tii�,i��ir'16ir.,,u,:��.-��n..a�:.•, SLUDGE MANAGEMENT STUDY TABLE 3-5 Estimated Costs: Scenario 1 - Continuation of Existing Operations Current Sludge Production Item Dewatering Composting Land611ing Total Costs pital Costs Year nReplacement ----- $150,000 ----- $150,000 Bulldozer Replacement - •-•- $100,000 Subtotal $ $250.000 250,000 Year Replace Trucks ----- $128,000 ----- $128,000 Replace Front End Loader ----- $214,000 ---- $214,000 Replace Mixer ----- $122,000 •---- Subtotal $122.005! $464,000 Year 14 Replace Blowers ---- $63,000 $136, ----- $63,000 Blower Electrical/ControlSystem ----- ... ,$136,000 $1,965000 $1,965,000 965000 Landfill Construction Replace Lime System $602,000 ----- •---- Subtotal $602 000 $2,766,000 Operation and Maintenance Costs Chemicals/Materials Labor Power Fuel Equipment Maintenance Miscellaneous Total Capital Expenditure (rounded): Equivalent Uniform Annualized Capital Costs (rounded): $46,700 $3,500 $32,100 $39,300 $14,800 $2,300 $0 $1,200 $5,000 $5,000 .0 $1.000 Subtotal $98,600 $52,300 Annual O & M Costs (rounded): $19,200 $23,200 $8,900 $1,000 $3,500 $56,800 Total Equivalent Uniform Annualized Costs (rounded): $3,480,000 $190,000 $69,400 $94,600 $26,000 $2,200 $13,500 $207,700 $210,000 $400,000 TOWN OF MANSFIELD, MASSACHUSETTS SLUDGE MANAGEMENT STUDY TABLE 3-6 Estimated Costs: Scenario I - Continuation of Existing Operations Design Sludge Production Item Dewatering Composting Landfilling Total Costs Capital Costs Year 0: Screen Replacement ----- $150,000 ----- $150,000 Bulldozer Replacement -•-•• -••-• $100,000 $100,000 Subtotal $250,000 Year is Replace Trucks ----- $128,000 ----- $128,000 Replace Front End Loader '----- $214,000 ----- $214,000 Replace Mixer ----- $122,000 ----- $122,000 Subtotal $464,000 Year10 Replace Blowers $63,000 ----- $63,000 Construct Landfill -•-•- ----- $1,965,000 $1,965,000 Blower Electrical/ContiolSystem $136,000 ----- $136,000 Replace Lime System $602,000 --• - $602.000 Subtotal $2,766,000 Total Capital Expenditure (rounded): $3,480,000 Equivalent Uniform Annualized Capital Costs (rounded): $190,000 Operation and Maintenance Costs Chemicals/Materials $107,300 $7,900 $44,200 $159,400 Labor $73,800 $90,400 $53,300 $217,500 Power $34,000 $5,200 $20,400 $59,600 Fuel $0 $2,700 $2,300 $5,000 Equipment Maintenance $11,500 $11,500 $8,100 $31,100 Miscellaneous $0 $2,300 $2,300 $4.600 Subtotal $226,600 $120,000 $130,600 $477,200 Annual O & M Costs (rounded): $480,000 Total Equivalent Uniform Annualized Costs (rounded): $670,000 Section 3 Evaluation of Sludge Management Alternatives 3.4.2 Scenario 2. Full -year Composting with Woodchips Under this alternative, landfilling of sludge would be eliminated and replaced with year-round composting. New and recycled woodchips would be used as amendments, as currently prac- ticed. A new roof structure over the active composting pad and material storage areas would be required to implement this scenario. Requirements for this alternative are detailed below. Dewatering No improvements other than lime system replacement are proposed. Land�filling Landfilling of sludge would be eliminated as the primary means of disposal in the winter months. Remaining landfill capacity could provide back-up capacity for the landfill operation and/or could be used to dispose of grit and screenings from the plant. Composting In addition to equipment replacements, two key improvements are recommend- ed to implement this option. First, the blower upgrade described for Scenario 1 should be implemented immediately. Secondly, a roof structure should be constructed over the composting pad and material storage areas to facilitate cold weather operations. Figure 3-1 illustrates the proposed to be covered by the roof structure. The structure, constructed of wood, would have open sides and would cover about 24,300 square feet. Costs associated with implementation of this option for current and design sludge production quantities are presented in Tables 3-7 and 3-8, respectively. A non -cost evaluation of this alternative provides a favorable rating with respect to reliability, beneficial use potential and revenue potential. A neutral rating was assigned for implementability and environmental impact. With respect to reliability, this scenario was favorably rated as it provides an onsite back-up should the composting facility be closed for a short -period. Beneficial use and revenue potential were both rated favorably, as this option maximizes the opportunity to "recycle' sludge and generate a small revenue stream. Potential revenues, which could be estimated at $3 to $5 per cubic yard, will not offset operating costs but could reduce net operating costs for this scenario. With respect to implementability, the major regulatory issue to be addressed is air quality permitting. The WPCF will have to demonstrate that the modified operation does not exceed emission rates established by the Department of Environmental Protection (DEP); if these rates are exceeded, then an air pollution control system will have to be installed. Given the size and nature of the Mansfield operation, we believe that the composting opera- tion will not trigger any DEP thresholds for air pollution control. This assumption must be verified if this scenario is to be pursued. CDM Camp Dresser & McKee 3-11 201-M-HTdTSK �O ® O on o -E t �> r I �YIDN. Y C Y N> �,y N xta ft�'re✓v_� o q'vxh`x V C Y�°bzY <r p 5ti.� S CL co U O O O O d of m � O / A E a� C N N O IL 0 U T011 N OF ,VANSFIELD, MASSACHUSETTS SLUDGE MANAGEMENT STUDY TABLE 3.7 Estimated Costs: Scenario 2 - Year Round Composting with Wood Chips Current Sludge Production Item Dewatering Composting Landfilling Total Costs pital Costs Year 0%• Compost Cover ----- $1,237,500 ----- $150,000 ----- $1,237,500 $150,000 Screen Replacement --•-- $,300 ..... $47,300 Replace Blowers Blower Electrical/ControlSystem $]01,300 total � $1,5300 536,100 Subtotal Year 5' Replace Trucks ... $128,000 $128,000 $214,000 ----- $128,000 ----- $214,000 Replace Front End Loader --._. $122,000 •••• $ Replace Mixer 464 Subtotal $464,000000 Year 10 Replace Lime System and Maintenance Costs Chemicals/Materials Labor Power Fuel Equipment Maintenance Miscellaneous $602,000 •••-• ----- Subtotal Total Capital Expenditure (rounded): Equivalent Uniform Annualized Capital Costs (rounded): W.1 111 O 111 $2,600,000 $200,000 $46,700 $6,900 $0 $53,600 $32,100 $78,600 $0 $110,700 $14,800 $4,600 $0 $19,400 $0 $2,300 $0 $2,300 $5,000 $10,000 $0 $15,000 N 1= N 1= Subtotal $98,600 $104,400 $0 $203,000 Annual O & M Costs (rounded): $200,000 Total Equivalent Uniform Annualized Costs (rounded): $400,000 TOWN OF MANSFIELD, MASSACHUSETTS SLUDGE MANAGEMENT STUDY TABLE 3.8 Estimated Costs., Scenario 2 • Year Round Composting with Wood Chips Design Sludge Production Item Dewatedng Composting Landfiiling Total Costs pital Costs Compost Cover - $1,237,500 - $1,237,500 Screen Replacement - $150,000 - $150,000 Replace Blowers - $47,300 - $47,300 Blower Electrical/Control System - $101,300 - $101,300 Subtotal $1,536,100 YeR p50 lace Trucks - $128,000 --- $128,000 Replace Front End Loader - $214,000 - $214,000 Replace Mixer - $122,000 - $121,000 Subtotal $464,000 Year 10 Replace Lime System ition and Maintenance Costs Chemicals/Materials Labor Power Fuel Equipment Maintenance Miscellaneous $602,000 Subtotal Total Capital Expenditure (rounded): Equivalent Uniform Annualized Capital Costs (rounded): $107,300 $15,900 $0 $73,800 $180,800 $0 $34,000 $10,500 $0 $0 $5,400 $0 $11,500 $23,000 $0 $0 $4,600 $4 subtotal $226,600 $240,200 $0 Annual O & M Costs (rounded): Ff-rowl1t $2,600,000 $200,000 $123,200 $254,600 $44,500 $5,400 $34,500 $466,800 $470,000 Total Equivalent Uniform Annualized Costs (rounded): $670,000 Section 3 Evaluation of Sludge Management Alternatives The option has been given a neutral rating with respect to environmental impacts because full -year composting will increase emissions from the site on an annual basis. We expect, however, that odor will not be an issue as the facility has successfully composted sludge during "peak odor season" (summer) for many years with few complaints; composting during the colder months, when odor complaints from most facilities abate, should not cause odor problems offsite. 3.4.3 Scenario 3: Full -year Composting with Sawdust This scenario differs from Scenario 2 only in that sawdust is used in place of woodchips as a composting amendment. This option was considered to potentially improve compost quality and streamline compost operations. Costs to implement the option at current and design sludge production are presented in Tables 3-9 and 3-10, respectively. Implementation require- ments for this alternative are described below. Dewaterine No improvements other than lime system replacement are proposed. Landfilline Landfilling of sludge would be eliminated as the primary means of disposal in the winter months. Remaining landfill capacity could provide back-up capacity for the landfill operation and/or could be used to dispose of grit and screenings from the plant. comma_ oostiTie As noted above, this scenario differs from Scenario 2 only in the amendment used - sawdust, rather than new and recycled woodchips. The use of sawdust would result in a more uniform compost product, potentially increasing marketability. Screening requirements would likely be less than those required to recover woodchips under Scenario 2. We recom- mend that screening not be eliminated, however, as it can eliminate oversized sludge particles that might diminish compost quality from an aesthetic perspective. WPCP staff conducted a demonstration project using sawdust to determine the viability of sawdust composting in the fall of 1995. The experiment was successful, but staff noted that if sawdust composting was implemented, they would prefer to use a sawdust that had fewer fines than the sawdust used in the demonstration. A discussion with the sawdust supplier indicted that a coarser blend could be supplied, albeit at a higher cost ($8.50/cubic yard versus $6/cubic yard). As noted on Tables 3-9 and 3-10, amendment costs are a significant portion of overall compost operating costs, and so the impact of the higher amendment cost is correspondingly large.. Aside from the amendment used, this scenario is essentially the same as Scenario 2, and it has been ranked accordingly from a non -cost perspective. It received a favorable rating from the reliability, beneficial use and revenue potential perspectives and a neutral rating with respect to implementability and environmental impact. CDM Camp Dresser & McKee 3-15 2o1.160AT4TSK TOWN OF MANSFIELD, MASSACHUSETTS SLUDGE MANAGEMENT STUDY TABLE 3-9 Estimated Costs: Scenario 3 - Year Round Contposting with Sawdust Current Sludge Production Item Dewatering Composting Landfilling Total Costs Capital Costs Compost Cover $1,237,500 •---- $1,237,500 Screen Replacement ---- $150,000 ----- $150,000 Replace Blowers $47,300 -•--- $47,300 Blower Electdcal/ControlSystem -•--- $101,300 •---- $191,300 Subtotal $1,536,100 Years' Replace Trucks $128,000 $128,000 Replace Front End Loader ----- $214,000 ----- $214,000 Replace Mixer ----- $122,000 ----- $122,000 Subtotal $464,000 Year 10 Replace Lime System ition and Maintenance Costs Chemicals/Materials Labor Power Fuel Equipment Maintenance Miscellaneous $602,000 ----- Subtotal Total Capital Expenditure (rounded): Equivalent Uniform Annualized Capital Costs (rounded): $46,700 $30,400 $0 $32,100 $78,600 $0 $14,800 $4,600 $0 $0 $2,300 $0 $5,000 $10,000 $0 $Q $2,000 $4 Subrotal $98,600 $127,900 $0 Annual O & M Costs (rounded): Total Equivalent Uniform Annualized Costs (rounded): B�i131101#11 .I off $2,600,000 $200,000 $77,100 $110,700 $19,400 $2,300 $15,000 $226,500 $230,000 $430,000 TOWN OF MANSFIELD, AIASSACHUSETTS SLUDGE MANAGEMENT STUDY TABLE 3.10 Estimated Costs: Scenario 3 - Year Round Composting with Sawdust Design Sludge Production tem Dewatering Composting Landfilling Total Costs Year Compost stCover - $1,237,500 _ - $150,000 237,500 $1$150,000 rCompos Replacement - $47,300 - $47,300 Blowers - - $101,300 $101.30subtotal Electrical/Control System $1,536,100 Trucks $128,000 - $128,000 $214,000 Front End Loader $214,000 - - - - $122,000 $122000 Replace Mixer Subtotal $464,000 Year ace Lime System $602,000 - - Subtotal $602,000 Total Capital Expenditure (rounded): $2,600,000 Equivalent Uniform Annualized Capital Costs (rounded): $200,000 Operation and Maintenance Costs Chemicals/Materials $107,300 $70,000 $0 $0 $177,300 $254,600 Labor $73,800 $180,800 $34,000 $10,500 $0 $44,500 Power $0 $5,400 $0 $5,400 Fuel Equipment Maintenance $11,500 $23,000 $0 io-00 $34�,550000 Miscellaneous Subtotal $0 $4,600 $226,600 $294,300 $0 $520,900 Annual O & M Costs (rounded): $520,000 Total Equivalent Uniform Annualized Costs (rounded): $720,000 Section 3 Evaluation of Sludge Management Alternatives 3.4.4 Scenario 4: Full -year Landfilfing This alternative assumes that all composting activity in Mansfield will cease and be replaced with onsite landfilling of dewatered sludge. Implementation requirements are discussed below. Dpwatering No improvements other than lime system replacement are proposed. Landfilling Under this scenario, new landfill cells will need to be constructed in year 5. At this time, it appears that adequate areas may be available to develop new landfill capacity. A more detailed assessment will be required to confirm this assumption, however. If sufficient area is not available, the landfill expansion could be sited in the area now used for composting. Equipment replacement and capital requirements for this option under current sludge and design production scenarios are presented on Tables 3-11 and 3-12, respectively, along with alternative costs. From a non -cost perspective, this option was given a favorable rating with respect to environ- mental impacts, a neutral rating for implementability and reliability, and an unfavorable rating with respect to beneficial use and revenue potential. The favorable rating for environmental impacts was assigned because overall (annual) facility emissions are likely to be reduced from current levels. The implementability rating was governed by the uncertainty regarding reclamation. With respect to reliability, this option has been given a neutral rating based upon a presumed lack of back-up capacity late in the planning period (which is not likely to be an issue in the near future). The unfavorable ratings for beneficial use and revenue potential are self-explanatory, as no products are generated. 3.4.5 Scenario 5. Hauling Liquid Sludge Under this scenario, dewatering operations at the WPCF would be eliminated, as would landfilling and composting operations. Liquid sludge would be hauled to proximate incinera- tor or drying operations for subsequent processing. For this option, we have assumed that the WPCF can produce a liquid sludge with a 4% solids content. Because chemicals to aid dewatering are not required under this option, the dry tonnage requiring disposal is about 25 percent less than the corresponding tonnage for alternatives that manage dewatered sludge. Current and design productions used to assess liquid hauling options are therefore 1,017 dtpy and 2,340 dtpy, respectively. CDM Camp Dresser & McKee 3-18 20W6ORT-4TSK TOWN OF MANSFIELD, ,11ASSACHUSETTS SLUDGE MANAGEMENT STUDY TABLE 3-11 Estiulated Costs: Scenario 4. Year Round Landfiiling Current Sludge Production Item Dewatering Composting Landfilling Total Costs pital Costs Year ----- $100,000 $19i69.OSc Bulldozer Replacement ._... subtotal $100,000 Year 5. ___ ----- $128,000 $128,00 Replace Trucks ..... $214,000 $214,000 Replace Front End Loader ____ -__-- $5,124,000 $.411A.00 Landfill Construction ----- subtotal $5,466,000 Year 10 Replace Lime System $602,000 ----- subtotal • 6 02.00 $602,000 Total Capital Expenditure (rounded): $ ,170,000 0,000 Equivalent Uniform Annualized Capital Costs (rounded): ttion and Maintenance Costs $46,700 $0 $80,950 $127,700 Chemicals/Materials $32,100 $0 $23,200 $55,300 Labor $14,8 $0 $8,900 $23,700 Power $0 $0 $0 $1,000 $1,000 Fuel $5,000 $0 $3,500 $8,500 Equipment Maintenance K $4 $1,000 Lm Miscellaneous subtotal $98,600 $0 $118,600 $217,200 Annual O & M Costs (rounded): $220,000 Total Equivalent Uniform Annualized Costs (rounded): $ 620,000 TOWN OF MANSFIELD, MASSACHUSETTS SLUDGE MANAGEMENT STUDY TABLE 3.12 Estimated Costs. Scenario 4 • Year Round Landfilling Design Sludge Production Item Dewateting Composting Landfilling Total Costs pital Costs Year0; — $100,000 1000 5� 0.0 erReplacement — Subtotal $100,000 Year 5: _ $128,000 $128,000 Replace Trucks — $214,000 $214,000 Replace Front End Loader —_ — $5,124,000 0 Landfill Construction Subtotal $5,466,000 Year 10 Replace Lime System and Maintenance Costs Chemicals/Materials Labor Power Fuel Equipment Maintenance Miscellaneous $602,000 Subtotal Total Capital Expenditure (rounded): Equivalent Uniform Annualized Capital Costs(rounded): $107,300 $0 $186,200 $73,800 $0 $53,300 $34,000 $0 $20,400 $0 $0 $2,300 $11,500 $0 $8,100 S4 a4 $2,300 Subtotal $226,600 $0 $272,600 Annual O & M Costs (rounded): $6,170,000 $400,000 $293,500 $127,100 $54,400 $2,300 $19,600 $1,300 $499,200 $500,000 Total Equivalent Uniform Annualized Costs (rounded): $900,000 Je,:Ilon 5 Evaluation of Sludge Management Alternatives Capital expenditures required to implement this option are minimal, including only modifica- tions to ensure that sludge can be pumped into transport vehicles in a reasonable amount of time. Labor requirements are not expected to differ significantly from dewatering require- ments, as plant staff will be required to oversee pumping operations to haulers and, when time permits, can be assigned to other WWTF tasks, CDM contacted the following three sludge incinerators to assess potential costs for this option: ■ New England Treatment Company (NETCO), Woonsocket, RI. Discussions with NETCO indicate that they would be willing to accept liquid sludge from Mansfield at this incinera- tion facility. NETCO estimates a disposal cost of $260/dry ton (dt) and transportation costs of $175/9,000 gallon load. They note that a surcharge of $75/ half hour will be charged for sludge loading times that exceed 45 minutes. Long-term and short-term contracts are available. ■ Upper Blackstone Water Pollutibn Abatement District (UBWPAD), Worcester, MA. The District operates an incinerator and accepts liquid sludge with solids contents of 4.3% or more. They are willing to accept sludges with a lower solids content (such as Mansfield), but these sludges are considered to be septages under their fee schedule and a tip fee of $47/1,000 gallons is charged for their incineration. The tip fee for higher solids sludges is $260/dt, not including transportation. Long-term and short-term contracts are available. The District.does not provide transportation services. ■ City of Fitchburg, MA. Fitchburg's incinerator will be expanding at the end of this year from a capacity of 1.2 dt/hour to 2.25 dt/hour. In the meantime, they are not accepting new contracts. Current tip fees at the facility are $225/dt, excluding transportation; tip fees at the expanded facility will not be determined until March 1997. Fitchburg staff report that sludges incinerated at the facility must meet minimum criteria of 4% solids content and 70% volatile solids content. Since neither UBWPAD or Fitchburg provide transportation services, estimates for the use of commercial hauling services were generated based on the cost assumptions presented in Table 3-4. EUAC costs for this scenario, based on current sludge production, are presented in Table 3- 13. Table 3-14 presents corresponding costs based upon design sludge production. A non -cost evaluation of this scenario resulted in a favorable rating with respect to implementability and reliability, a neutral rating for environmental impact, and unfavorable ratings with respect to beneficial use and revenue potential. The scenario was rated favorably with respect to impiementability and reliability because regulatory constraints to implement this scenario are expected to be minimal and the existing landfill can be used to provide back-up capacity, providing reliability. 3.21 CDM Camp Dresser & McKee 20060-RT-4TSK TOR'A' OF MANSFIELD, MASSACHUSETTS SLUDGE MANAGEMENT STUDY TABLE 3.13 Estimated Costs: Scenario 5 - Liquid Haul and Disposal Current Sludge Production Item Dewatering Transportation Disposal Total Costs Capital Costs Year 0* Pumping Modifications — $200,000 subtotal $200,000 $200,000 Total Capital Expenditure (rounded): $200,000 Equivalent Unifom: Annualized Capital Costs (rounded): $20,000 Operation and Maintenance Costs NETCO (Woonsocke4RI) $32,100 $118,500 $264,400 $415,000 Fitchburg (Fitchburg, MA) $32,100 $264,000 $228,800 $524,900 UBWPAD (Worcester, MA) $32,100 $170,000 $286,000 $498,100 Annual O & M Costs (NETCO): $420,000 Annual O &M Costs (Fitchburg): $520,000 Annual O & M Costs (UBW PAD): $490,000 Total Equivalent Uniform Annualized Costs (NETCO): $440,000 Cost per Dry Ton: $433 /dt Total Equivalent Uniform Annualized Costs (Fitchburg): $540,000 Cost per Dry Ton: $531 /dt Total Equivalent Uniform Annualized Costs (UBWPAD): $510,000 Cost per Dry Ton: $501 /dt TO R'N OF MANSFIELD, MASSACHUSETTS SLUDGE MANAGEMENT STUDY TABLE 3-14 Estimated Costs: Scenario 5 • Liquid Haul and Disposal Design Sludge Production Item Capital Costs Year 0: Pumping Modifications ttion and Maintenance Costs NETCO (Woonsocket, RI) Fitchburg (Fitchburg, MA) UBWPAD (Worcester, MA) Dewatering Transportation Disposal Subiorat Total Capital Expenditure (rounded): Equivalent Uniform Annualized Capital Costs (rounded): Total Costs 11 11I1 11 111 $200,000 $20,000 $32,100 $272,600 $608,100 $912,800 $32,100 $607,200 $526,200 $1,165,500 $32,100 $391,000 $657,800 $1,080,900 Annual O & M Costs (NETCO): Annual O & M Costs (Fitchburg): Annual O & M Costs (UBWPAD): Total Equivalent Uniform Annualized Costs (NETCO): Cost per Dry Ton: Total Equivalent Uniform Annualized Costs (Fitchburg): Cost per Dry Ton: Total Equivalent Uniform Annualized Costs (UBWPAD): Cost per Dry Ton: I $910,000 $1,170,000 $1,080,000 $930,000 $397 /dt $1,190,000 $508 /dt $1,100,000 $469 /dt Evaluation of sludge Management Alternatives Environmental impacts were judged to be neutral, in that truck traffic would likely increase but overall impacts might be offset by reductions in emissions from composting operations. The unfavorable rating for beneficial use and revenue potential is self-explanatory, as no product would be generated. 3.4.6 Scenario 6: Hauling Dewatered Sludge This alternative is similar to Scenario 5 in that sludge would be hauled to a commercial facility for processing or disposal. Unlike Scenario 5, however, the sludge would be dewatered (as currently practiced) at the WPCF. Capital expenditures required to implement this option are limited to the replacement of the lime system in Year 10 of the planning period. The following commercial establishments were contacted to develop costs for this scenario. ■ New England Treatment Company (NETCO), Woonsocket, RI. This incinerator, described under Scenario 5, is also capable of accepting dewatered sludges with solids contents ranging from 25% to 35%. A surcharge is applied to sludges that do not fall into this range. Quoted disposal and transportation costs for this facility are about $260/dt and $175/load. ■ Wheelabrator, Rochester, NH. Wheelabrator will accept sludges for its operations in Rochester at the Turnkey landfill or the International Process Systems composting facility. Sludges accepted at the landfill must be stabilized (the lime used to dewater sludge at Mansfield should meet this requirement) and have a minimum solids content of 20%. Sludges destined for composting do not need to meet stabilization requirements. Tip fees (exclusive of transportation) at the landfill are $55 to $95 per wet ton, while composting tip fees are $50 to $75 per wet ton, depending on product quality. For this analysis, we have assumed a tip fee of $70/wet ton, equivalent to $200/dt for Mansfield's 35% solids sludge. Transportation services are provided by Wheelabrator, but detailed costs were not provided. ■ Partyka Resource Management, Chicopee, MA. Because Partyka has expressed an interest in taking sludge at its Chicopee landfill in the past, CDM attempted to contact the compa- ny to obtain current tip fee information. Partyka staff did not respond to CDM requests, however, and quotes solicited in 1994 (for another project) have been used to estimate disposal costs at this facility. At that time, Partyka quoted tip fees of $75/wet ton ($214/dt for a 35% solids sludge). Transportation services are not provided. Estimates for the use of commercial hauling services (for facilities other than NETCO, where transportation costs were provided) were generated based on the cost assumptions presented in Table 3-4. 3-24 CDM Camp Dresser & McKee 2oJ.J6ORT-4T$K TOIIW OF n9ANSP/ELD, n1ASSACHUSETTS SLUDGE MANAGEMENT STUDY TABLE 3.15 Estimated Costs: Scenario 6. Cake Haul and Disposal Current Sludge Production Item Capital Costs Year 10 Replace Lime System atlon and Maintenance Costs NETCO(Woonsocket, RI) Partyka (Chicopee, MA) Wheelabrator (Rochester, NH) Dewatering Transportation $602,000 Disposal Total Costs $602.000 Subtotal $602,000 Total Capital Expenditure (rounded): Equivalent Uniform Annualized Capital Costs (rounded): $89,400 S45,500 $356,000 $89,400 $106,100 $294,000 $89,400 $181,000 $274,400 Annual O & M Costs NETCO (Woonsocket, RI): Annual O & M Costs Partyka (Chicopee, MA): Annual O & M Costs Wheelabrator (Rochester, NM: Total Equivalent Uniform Annualized Costs NETCO(Woonsocket, RI): Cost per Dry Ton: Total Equivalent Uniform Annualized Costs Partyka (Chicopee, MA): Cost per Dry Ton: Total Equivalent Uniform Annualized Costs Wheelabrator (Rochester, NH): Cost per Dry Ton: $600,000 $30,000 $490,900 $489,500 $544,800 $490,000 $490,000 $540,000 $520,000 $379 /dt $520,000 $379 /dt $570,000 $415 /dt TOWN OF MANSFIELD, MASSACHUSETTS SLUDGE MANAGEMENT STUDY TABLE 3.16 Estimated Costs: Scenario 6 • Cake Haul and Disposal Design Sludge Production Item Dewatering Transportation Disposal Total Costs Capital Costs 10: Year Replace Lime System $602,000 $602,000 subtotal $602,000 Total Capital Expenditure: $600,000 Equivalent Uniform Annualized Capital Costs: $30,000 Operation and Maintenance Costs NETCO(Woonsocket,RI) $205,600 $104,700 $818,800 $1,129,100 Partyka (Chicopee, MA) $205,600 $244,000 $676.200 $1,125,800 Wheelabrator (Rochester, NH) $205,600 $416,300 $631,100 $1,253,000 Annual O &M Costs NETCO (Woonsocket, RI): $1,130,006 Annual O & M Costs Partyka (Chicopee, MA): $1,130,000 Annual O & M Costs Wheelabrator (Rochester, NH): $1,250,000 Total Equivalent Uniform Annualized Costs NETCO(Woonsocket, RI): $1,160,000 Cost per Dry Ton: $367 /dt Total Equivalent Uniform Annualized Costs Partyka (Chicopee, MA): $1,160,000 Cost per Dry Ton: $367 /dt Total Equivalent Uniform Annualized Costs Wheelabrator (Rochester, NH): $1,280,000 Cost per Dry Ton: $405 /dt Section 3 Evaluation of Sludge Management Alternatives t'. EUAC costs for this scenario, based on current sludge production, are presented in Table 3-15. Table 3-16 presents corresponding costs based upon design sludge production. This scenario is essentially the same as Scenario 5, and it has been ranked accordingly from a non -cost perspective with one exception. It received a favorable rating from implementability and reliability perspectives, a neutral rating with respect to environmental impacts, and unfavorable rating with respect to revenue potential. Unlike Scenario 5, however, it received a neutral ranking for beneficial use potential as the possibility of beneficial use exists through at least one of the commercial facilities contacted. 3.5 Evaluation Summary The results of cost analyses are summarized on Table 3-17. Figure 3-2 presents a matrix sum- marizing the results of non -cost analyses. As shown on Table 3-17, the costs for Scenarios 1, 2 and 5 (NETCO only) are essentially equal and represent the most cost-effective options for the Town at current sludge production quantities. As sludge production increases, Scenarios 1 and 2 remain the lowest cost options (and, in fact, are equal in cost at design sludge quantities), but all other scenarios become far less cost-effective. This phenomenon indicates that sludge production is a driving factor in cost- effectiveness. It should be noted that the costs presented for Scenario 2 have not accounted for potential revenues from product sale. Inclusion of these revenues could potentially result in this option being the most cost-effective sludge management option for the Town Composting with sawdust does not appear to be cost-effective at this time. Sawdust costs, and the loss of the cost benefit of woodchip recycling, are the likely causes of the relatively high cost of this option. Non -cost evaluations indicate that full -year composting with woodchips or sawdust ranks slightly higher than Scenario 1 (continuation of existing practice). All other alternatives were far less favorable from a non -cost perspective. Though not directly considered in the non -cost evaluations, the potential of each scenario for continued operation beyond the planning period cannot be ignored. From this perspective, the full -year composting options offer the greatest benefit to the Town, as only equipment replace- ment will be required to extend the facilities useful life beyond the planning period. Year- round landfilling, however, will completely eliminate the sludge management capacity of the Fruit Street site by the end of the planning period, such that the Town will be forced to "start from scratch" with respect to long-term sludge management. CDM Camp Dresser & McKee 3-27 201•16"T-4TSK T01VA' OF MANSFIELD, MASSACHUSETTS SLUDGE MANAGEMENT STUDY TABLE 3.17 Cost Summary for Sludge Management Study Scenario Estimated Capital Cost Equivalent Uniform Annualized Capital Cost Annual Operations and Maintenance Costs Total Equivalent Uniform Annualized Cost Cost per Dry Ton Scenario 1: Continuation of Existing Operations Current Sludge Production $3,480,000 $190,000 $210,000 $400,000 $292 Design Sludge Production S3,480,000 $190,000 $480,000 $670,000 $212 Scenario 2: Year Round Composting with Wood Chips Current Sludge, Production $2,600,000 $200,000 $200,000 $400,000 $292 Design Sludge Production $2,600,000 $200,000 $470,000 $670,000 $212 Scenario 3: Year Round Composting with Saw Dust Current Sludge Production $2,600,000 $200,000 $230,000 $430,000 $313 Design Sludge Production S2,600,000 $200,000 $520,000 $720,000 $228 Scenario 4: Year Round Landfrlling Current Sludge Production $6,170,000 $400,000 $220,000 $620,000 $452 Design Sludge Production $6,170,000 $400,000 $500,000 $900,000 $285 Scenario 5: Liquid Haul and Disposal Current Sludge Production NETCO $200,000 $20,000 $420,000 $440,000 $433 Fitchburg $200,000 $20,000 $524,900 $540,000 $531 UBWPAD $200,000 $20,000 $488,100 $510,000 $501 Design Sludge Production NETCO $200,000 $20,000 $910,000 $930,000 $397 Fitchburg $200,000 $20,000 $1,170,000 $1,190,000 $508 UBWPAD $200,000 $20,000 $1,080,000 $1,100,000 $469 Scenario 6: Cake Haul and Disposal Current Sludge Production NETCO (Rl) $600,000 $30,000 - $490,000 $520,000 $379 Partyka(MA) $600,000 $30,000 $490,000 $520,000 $379 Wheelabrator (NH) $600,000 $30,000 $540,000 $570,000 $415 Design Sludge Production NETCO(RI) $600,000 $30,000 $1,130,000 $1,160,000 $367 Partyka(MA) $600,000 $30,000 $1,130,000 $1,160,000 $367 Wheelabrator (NH) $600,000 $30,000 $1,250,000 $1,280,000 $405 Scenario 1. Continuation of Existing Practice CI O O 2. Full -year Composting with Woodchips (3 O � O O O 3. Full -year Composting with Sawdust Sawdust � O O O O 4. Full -year Landfilling O • • (01 5. Hauling Liquid Sludge O O (3 • 6. Hauling Dewatered Sludge O O • Rating: O= Favorable ® = Neutral = Unfavorable Town of Mansfield, MA Sludge Management Study Figure 3-2 CDM Camp Dresser & McKee Non -Cost Evaluation Summary ff ection Four Section 4 Recommendation Based on cost and non -cost evaluations, two management options - Scenarios 1 and 2 - appear to offer the greatest benefit to the Town. Scenario 1 (continuation of existing practice) and Scenario 2 (full -year composting with woodchips) ranked equally in cost evaluations. Scenario 2 ranked slightly higher than Scenario 1 in the non -cost evaluations. Considering both cost and non -cost factors, the two scenarios must be ranked as equals. Based upon the relative equality of the two options, the Town may wish to consider continued implementation of Scenario 1 in the near term. Efforts to secure compost markets (currently being investigated by CDM) should then be completed to allow Scenario 2 to be implemented as a long-term solution without concerns regarding compost distribution. Scenario 2 offers the long-term, benefits of higher potential revenues from compost sales and a maximum conserva- tion of existing landfill capacity. CDM Camp Dresser & McKee 4-1 201•iBTRT-4TSK