The new permit is “to establish start up and shutdown limits based on continuous compliance tests conducted at the facility.” This change in emission limits would increase nitrogen oxide and particulate start up emissions and decrease volatile organic compounds and carbon monoxide start up emissions. Overall, the changes will decrease the total air emissions of the facility. For that reason, the assessment of existing community conditions and analysis of the cumulative impacts of new or modified sources of air pollution that may affect Environmental Justice (EJ) populations will NOT be required.”

The Peabody Board of Health and Breathe Clean North Shore have previously requested that MMWEC be required by MassDEP to develop an Environmental Impact Report and a comprehensive health impact assessment given the facility’s proximity to EJ populations within four communities residing within one mile of the plant.

“Although the net result will be an overall decrease in emissions, there is still the potential for elevated health impacts, particularly respiratory events.

During the siting process to add MMWEC’s new generator to the two existing PMLP generators at Waters River Station. BCNS and the Peabody Board of Health requested that MMWEC be required by MassDEP to develop an Environmental Impact Report and conduct a Comprehensive Health Assessment (CHIA). Neither of these two assessments were conducted.

Although MMWEC’s application shows that the permitted changes will result in an overall reduction in potential emissions over the course of a single start-up/shut down event as well as over the course of the operating years when operating on its primary fuel source (natural gas), it also shows that there would be a net increase in total potential emissions both on a per cycle and on annual basis when the plant is operating on its backup fuel: diesel oil.

When SP2015A operates on natural gas, start-up emissions of nitric oxide and levels of particulates could increase. When burning diesel oil, start-up emissions of NOx, methane, particulates, S02m and Hs 204 could increase. These pollutants cause health risks, including cancer, birth defects, harm to the nervous system and brain, heart disease, COPD and asthma.

We agree with the Peabody Board of Health that the potential for elevated health impacts, particularly respiratory events, exist during facility start-up events. There is currently no mechanism to be aware of increased risks that may be associated with these start up events.

BCNS and the Peabody Board of Health have repeatedly requested information about whether and when the plant runs and what it is burning – to no avail.

BCNS also recommends the Peabody Board of Health’s safeguards be implemented prior to approving any application that allows, even for a limited period, an increase in emission of pollutants.

1. MMWEC should be required to conduct the Cumulative Impact Analysis described at 310 CMZR 7.02 (14).

2. MMWEC should be required to submit information about its compliance with air quality and other environmental parameters associated with its permit to the Board of Health.

3. MMWEC should be required to regularly share information with the Board of Health about any complaints received regarding emissions, odor, noise, or other environmental concerns, as well as corrective action taken.

4. MMWEC should be required to regularly share information with the Board of Health about any malfunction affecting emissions at the facility,as well as corrective action taken.

5. MMWEC should be required to install and maintain one or more air monitors in the adjacent EJ area that measures particulate levels and whose data is publicly accessible in real time, such as through the Purple Air Monitoring network or some similar public platform, so that the public can monitor local air quality and take individual precautions when relevant.

BCNS requests that MMWEC also provide details on the monitor to be installed at the plant that DEP requested after reviewing comments from the last public hearing (12/14/2?). BCNS has followed up with MMWEC as to the status of the monitor and how the monitor’s results will be published and available but we have not received a final update with details.

A health analysis of the neighborhoods within 2km of the Waters River Power Station was conducted by the BU School of Public Health in 2022 in cooperation with Mass Climate Action Network (MCAN). @ Pollution, People, and Power

plants: Health Burdens in Peabody, MA November 1, 2022

https://assets.nationbuilder.com/…/Pollution_People…

Commissioner Ray Melvin also sought to eliminate the soon-to-be vacated Assistant Manager position due to attrition.  Joined by Commissioner Tom Paras, they questioned a rationalization for hiring attorneys as employees instead of as contractors and the number of engineers employed at PMLP were raised.

“I’m looking out for the ratepayers,” Melvin said “I don’t  think they (MMWEC) have served us well over the years. I think they really cheated us a lot and made a lot of errors.  I think they run their organization very sloppy.”

 “I asked if money’s been added to the budget because we apparently are going to be hiring  a consulting firm to insure that the strategic plan is done properly. We voted for an Organizational review, a 3-2 vote. We also asked management to freeze all positions pursuant to this request. I don’t think that was adhered to.”

“If you look at the numbers  other municipal light plants with an  MMWEC service charge are  no where near us. The number is $125,237 for Peabody for one year,” said Melvin.

“We (Peabody) are 17 percent of MMWEC,” added Paras.

MLP General Manager Joe Anastasi said, “We are the third largest municipal light plant (after Taunton and Reading)  not a smaller plant – have to look at it in context.”

Melvin asked why the issue was “never brought to our attention”?

Anastasi replied, “It goes up every year. We’re bound by a contract. There’s been a steady increase since the dawn of time. The energy market is a crazy market, extremely volatile. Every light plant is in the same situation.”

‘’We need to understand this and what that means before we start approving money and throwing money around,” said Melvin.

In January, the commission did not act on the proposed Fy226 budget.

Anastasi said six projects “are not moving forward due to the budget” and outlined how not passing a budget jeopardizes actions:

• Infrastructure upgrades

• Overtime mitigation risks
• decreased reliability and safety
• Impede long term plans
• Affect the pilot payment with the City
• Decrease public transparency and board scrutiny
• Could face fines if don’t meet state mandated deadlines

The Grannies raised funds to support Haven from Hunger https://peabodyweeklynews.com/…/mad-grannies-raise…/

The Climate Change Group (CCG) and BCNS have been working on issues of air quality – promoting purple air monitors and volunteers to help us smash some pumpkins.

Here’s the link to the CCG current newsletter:

https://mail.google.com/mail/u/0?ui=2&ik=f4c04b59b6&attid=0.1&permmsgid=msg-f:1854438523556964200&th=19bc4a030e69a768&view=att&disp=inline&realattid=f_mkg8wm300&zw

The Peabody Municipal Light Plant has requested an opinion from the city solitictor regarding the status of a proposed BESS battery energy storage system at 201 Warren St. Ext. They are seeking exemption of rules regarding the property which is within Proctor Brook riverfront and FEMA Flood Plain. On July 20, the matter was continued awaiting the city’s legal team response and consideration by the Conservation Commission.

We applaud the creation of the Utility Battery Storage because it reduces bulk power costs by allowing PMLP to store power when it is cheaper for us to buy (during non-peak times), and then to use the battery to shave the peak which helps to reduce stress on the bulk power system and reduces PMLP’s transmission and capacity costs. A collaborative project with MMWEC, the groundbreaking was expected to begin in the summer of 2024. After the physical work begins, it is expected to be approximately 12 months before the battery goes online.

But, why exempt the project from meeting development requirements in the apparent riverfront and flood plain? This is the first or one of the earliest battery storage projects to be considered in the CIty; it should meet all enviromental requirements and set a future example. Does the City require lighting and fencing,m etc. for battery storage projects?

There are seven Purple Air quality monitors placed throughout the city and there have been some recent extreme spikes on the air quality readings in the downtown Environmental Justice area on the coldest days.

There is a concern for people’s health when levels in air are high. Outdoor PM 2.5 levels are most likely to be elevated on days with little or no wind or air mixing. What else might cause levels to rise? Could it be related to the Waters River Power Station in Ward 3? BCNS has been pursuing information for years as to when the generators off Pulaski St, are running and what they are burning – to no avail.

Could the rise in particulate matter (PM2.5) be related to the type of fuel burned at the plant on cold days?

Waters River Station is ranked #37 out of 44 natural gas power plants in Massachusetts in terms of total annual net electricity generation. Grid Info revealed that 20GWh of energy was produced during the 3-month period between September 2023 to December 2023.

Waters River Power Station is a 115,000-volt substation, three gas turbine generators, and a high-pressure natural gas metering station. Two of the gas and oil burning generators are owned by Peabody and one, the newest one, is owned by MMWEC.

Peabody’s oldest generator, #1, is 54 years old and has a power output of 20MW. It is delisted from ISO’s Forward Capacity Market with the earliest closure being 2026.

PMLP will use capacity from MMWEC’s newest peaker (Project 2015A) to replace the capacity lost from closing Unit 1. Peabody is 30% owner of MMWEC’s new peaker.

What Will PMLP Do Between Now and 2026 with Unit 1?

“Because of its age and technology, Unit 1 running on oil during the winter results in relatively high NOx emissions. In order to capture essentially the same benefits of delisting Unit 1 between now and 2026, not running Unit 1 during the winter months on oil will result in the same (approximately 70%) reduction in NOx emissions. Such a NOx reduction will benefit the communities in and around Peabody.

“Using other ISO-NE rules, commencing in November, 2022 and from then through 2026 PMLP will submit bids not to run Unit 1 on oil except as required for testing in adherence to Massachusetts Department of Environmental Protection and ISO-NE regulations. This approach will be used by PMLP until the time period by which ISO-NE allows Unit 1 to shut down.”

If this 54-year-old generator is needed by ISO on these cold days, it could be burning oil because it is the preferred alternative when there is an unavailability of gas or gas costs rise.

And/or, Peabody’s second peaker, a 33-year-old dual fuel (gas and oil) generator with a power output of 48 MW could be called on by ISO-NE anytime the grid needs it.

Submitted Jan. 22 to PMLP’s Energy Awareness Forum

Could PMLP make available information on the 2 generators owned by Peabody at the Waters River substation, including dates, times and duration when they run for either testing or as required for power generation? There are at least 7 air quality monitors placed throughout the city and there have been some recent extreme spikes on the air quality readings in the downtown area on the coldest days. It would be good to see if there is any correlation between the older peakers and the air quality. Ideally this information could be posted on the PMLP website. – RS

Resources:

Tips for Using PurpleAir’s Free Air Quality Map

https://www2.purpleair.com/…/tips-for-using-purpleair-s…

Go to US EPA PM2.5 by PurpleAir to manipulate the map.

https://map.purpleair.com/air-quality-standards-us-epa…

Grid Info

https://www.gridinfo.com/plant/waters-river/1678

PMLP Statement on Unit 1
https://pmlp.com/…/Statement-from-PMLP-Regarding-Waters…

Energy Awareness Forum | Peabody Municipal Light Plant, MA)

https://pmlp.com/229/Energy-Awareness-Forum

Here’s the entire October Peabody Municipal Light Commission meeting: https://peabodytv.org/videos-on-demand/?vid=1366

And, here’s the link by BCNS to the interactions after the meeting was gaveled closed: https://youtu.be/O3qca_ZEokk