555 (Police Barracks) Environmental Audit Records 2013 NORTHAMPTON,RTN 1-00973
2 NOTICE OF AUDIT FINDINGS
LIMITATIONS
The audit inspection did not include a compliance review of all response actions undertaken at
this site to date. This audit was focused primarily on evaluating compliance with the MCP's
requirements for operation,monitoring, and maintenance of the response action being conducted,
as detailed in the most recent 1&M report and as observed on October 26,2012.
The Department's findings were based upon the certainty of the information reviewed during the
audit, These findings do not: (1)apply to actions or other aspects of the site that were not reviewed
M the audit; (2)preclude future audits of past,current,or future actions at the site;(3)in any way
constitute a release from any liability,obligation,action or penalty under M.G.L. c. 21E,310 CMR
40.0000,or any other law,regulation,or requirement;or(4)limit the Department's authority to
take or arrange,or to require any Responsible Party or Potentially Responsible Party to perform,
any response action authorized by M.G.L. c.21E which the Department deems necessary to protect
health,safety, public welfare,or the environment.
If you have any questions regarding this Notice,please contact Rebecca Woolley at 413-755-
2263. Please reference Release Tracking Number 1-00973 in any future correspondence to the
Department regarding the site.
Sincerely,
Rebecca Wooll
Environmental
dut
ohm Lie
Section RSA Audits/Site Management
Bureau of Waste Site Cleanup
Attachments:
A. Audit Pre-Inspection Screening Checklist
13. MNA Information Sheet
ec: Charles Klingler, LSP-of-Record,ECS
Northampton Chief Municipal Officer
Northampton Health Department
Derrick Bruce,DEP WERO
Data Entry: PHV/SNAUDI; AUDCOM/NAFNVD; FLDRUN 10/26/2012
DEVAL L PATRICK
Governor
1MGTHY P.MURRAY
Lieutenant Governor
Commonwealth of Massachusetts
Executive Office of Energy &Environmental Affairs
Department of Environmental Protection
Western Regional Office•436 Dwight Street, Springfield MA 01103.413-784-1100
November 1,2012
Massachusetts Department of State Police
Mr. Gerald Densmore
470 Worcester Road
Framingham,MA 01702
RICHARD K SULLIVAN JR
Secretary
KENNETH L.KIMMELL
Commissioner
Re: Northampton,RTN 1-00973
Mass. State Police Barracks
555 North King Street
Remedial Action Inspection
NOTICE OF AUDIT FINDINGS
AUDIT INSPECTION
Dear Mr. Densmore:
On October 26,2012,the Massachusetts Department of Environmental Protection(the
Deportment)conducted an audit inspection at the location identified above. In particular,the audit
inspection focused on the Comprehensive Response Action being implemented at this site. The
remedial action currently consists of enhanced fluid recovery,in-site chemical oxidation,and
monitored natural attenuation. The audit also included a review of the inspection and monitoring
(I&M)reports on file at the Department,the most recent of which was received on May 12,2012.
This Notice informs you of the results of the Departments audit inspection.
DETERMINATION
The Department did not identify any violations of the requirements applicable to the remedial
action at the site. Copies of the Audit Pre-Inspection Screening Checklist and Monitored Natural
Attenuation(MNA) Information Sheet are enclosed.
LICENSED SITE PROFESSIONAL (LSP)
A copy of this Notice has been sent to Charles Klingler, the LSP-of-Record for the disposal site.
This Information Is available In alternate format.Call Michelle Waters-Ekanem,Diversity Director,at 517-292-5751.TCDM 1.866.539-7622 or 1-617-574 6868
MassLEP Website:Gym mass govldep
Printed on Recycled Paper
RSI AUDIT—PRE-INSPECTION SCREENING CHECKLIST
Lead RTN: 1-00973
II Town: NORTHAMPTON
Action Inspected:
• Phase V ❑Class C f•4 ROS
PRP/OP: Massachusetts State Police
Site Name: Mass. State Police, Northampton Barracks
Owner Commonwealth of Massachusetts
LSP/Consultant: Charles Klingler, ECS, 508-756-0151
Occupant: Massachusetts State Police
Site Contact/Phone k: Gerald Densmore 508-820-2300
Condition
Yes/No
Comments
Puhlic Health Concerns
>0.5°NAPL within 15 feet of ground surface
No
>5 mg/I total VOCs<15 ft bgs&wTin 30 fl of schooWresidence
No
OHM in surfidal soil in S-1 area(schoovresidence/park)
No
Private wells located<500 feel,or site in Zone II or IWPA
No
Other potential impacts to nearby receptors
Yes
An unnamed stream is located—50 feel south/
downgradient of the site.
Environment and Release Characteristics
Within 500 feet of surface water,ACEC,and/or wetlands
Yes
See above
Confirmed contamination of surface water and/or wetlands
No
Historical contamination of stream. Currency,VPH
concentrations in surface wafer are below NSDS surface
water quality guidelines.
Multiple sources of contamination
Yes
Gasoline in soil and groundwater.
Media other than soil or groundwater are affected
Yes
See above. Unnamed stream impacted historically.
Remediation Waste(310 CMR 40.0030)
Remediation Waste removed within 120 days
N/A
Remediation Waste has been properly managed
N/A
Operation,Monitoring and Maintenance - -
Phase V/Class C OMM Requirements(310 CMR 40.0890)
OMM Plan is an-file,with Ph.IV RIP,per 40.0874(3)(d)
Yes
OMM Plan identifies the type and frequency of monitoring
Yes
OMM activities done in accordance with RIP goals&criteria
Yes
OMM Plan updated in response to changes In site conditions
No
Could be updated to reduce sampling frequency.
Current I&M report received on time(due every 6 mos.)
Yes
OMM results are adequately documented,per40.0892
Yes
Additional ROS Requirements(310 CMR 40.0893)
Complete ROS submittal was received,per 40.0893(3)
Yes
CRA is designed to achieve a Permanent Solution
Yes
However,MNA effectiveness has not been demonstrated
CRA is properly operated,monitored,and/or maintained
Yes
Each source of OHM has been eliminated or controlled
Yes
All Substantial Hazards have been eliminated
Yes
CRA modified or ROS terminated when required
Yes
Remedial Action Summary: Enhanced Fluid Recovery(EFR), in-situ
natural attenuation (MNA)were selected as the Comprehensive Response
soil, groundwater,and surface water. The remedial program consists
(as necessary), periodic ISCO injection events,and on-going MNA.
VPH and natural attenuation indicators(pH, DO, ORP, nitrate, and
quarterly monitoring of surface water for VPH.
chemical oxidation(ISCO)and monitored
Action to address a release of gasoline to
of EFR events to address LNAPL on groundwater
I &M activities include quarterly monitoring of
sulfate)in groundwater at select well Iocations, and
11. MNA monitoring points and monitoring frequency identified in OMM Plan: Quarterly sampling of groundwater al
select monitoring well locations for laboratory analysis of VPII,nitrate,sulfate,and dissolved iron,and for field
screening of DO,redox,specific conductivity, pH,and temperature.
12. Analytical tests performed to evaluate progress of MNA:
VPH ❑EPH ❑VOCs ❑ SVOCs ❑CVOCs ❑PAHs ❑PCBs ®Metals(Fe,Mn)
®pH ®DO ®Temp ®ORP ❑CO, ❑TOC ®NO3 ® SO4 ❑Plate count
13. Monitoring data shows that the plume is ❑expanding ® shrinking ❑static ❑unclear
Primary contaminant concentrations are: ❑ increasing ®decreasing ®static ❑unclear
Secondary contaminant concentrations are: ❑ increasing ❑decreasing ❑static ❑ unclear ® N/A
Comments: VPH concentrations are decreasing at the fringes of the plume, including in surface water adjacent and
immediately downstream from the site,where all analytes are now non-detect. However,VPH concentration trends in
groundwater are still static/variable at the source area,where they currently remain above OW-3 standards at five well
locations(MW-3, MW-9d,MW-13s,MW-12,and MW-14s). Sheens still occur intermittently at monitoring wells
MW-3,MW-14s,and MW-19.
Field Inspection(indicate all that apply)
1. Are the MNA monitoring points present and in useable condition? ®Yes ❑No
Comments: All monitoring points located in the paved and grassy areas were located during my inspection
2. Were the receptors observed at and in the vicinity of the site during the inspection consistent with those identified
during the file review?
® Yes ❑No Comment:
3. Have impermeable surfaces been added over or moved from over the plume area? ❑ Yes ®No
Comments:
4. Other Comments: On October 26,2012,1 conducted an unaccompanied site inspection with
the permission of Gerald Densmore of the Massachusetts State Police(MSP)and Lt.Andrew Bzdel(MSP Station
Commander). Site conditions were consistent with those described in the site file. I observed that the concrete
surrounds of the roadboxes for monitoring wells MW-9s, MW-9i,and MW-9d were cracked and may require future
maintenance to maintain monitoring well integrity and security. On October 31, 2012, 1 conducted a follow-up
telephone conversation with the Matt Lyne(Sr.Project Manager)of ECS and explained that MNA effectiveness must
be demonstrated to support ROS,if MNA is to he solely relied upon to achieve a Permanent Solution. While MNA
data are being collected,the current level of MNA data evaluation is not enough to support ROS,if additional active
remcdiation is not conducted. 1 also recommended to Mr. Lyne that the OMM Plan be updated to reflect current
conditions and monitoring. Mr. Lyne indicated that the forecasted path to site closure will include a Method 3 Risk
Characterization to support a Response Action Outcome.
Completed by.- :%lcacecca G'/L<cv,
Date: 10/31/2012
Monitored Natural Attenuation (NINA) Information Sheet
Site Name&Location: Massachusetts State Police,Northampton Barracks RTN: 1-973
Inspector Name: Rebecca Woolley
Date: 10/26/2012
Fd letitew
1. Primary disposal site OHM:
0 Petroleum Hydrocarbons • Solvents • PCBs • Metals ❑Other:
2. Source of the release: OUST • AST • Septic • Surface Spill • Dry Well
• Source Unknown ❑Other:
3. Environmental media impacted at the disposal site:
unnamed stream located- 50 feet south/downgradient of site
® Soil a Groundwater ❑Soil Gas ®Other:
4. Environmental media targeted for MNA:
• Soil ®Groundwater ❑ Soil Gas ❑Other:
5. OHM targeted for MNA:
Petroleum Hydrocarbons ❑ Solvents • PCBs • Metals ❑Other:
6. Has the source of the primary contaminant(s)targeted
for MNA been removed,capped,or otherwise controlled?
Remedial activities have included UST removal,excavation of
• Yes • No ❑Not Determined Explain:
impacted soil,EFR,and ISCO.
7. Other ongoing Remedial Action Alternatives:
❑None • Excavation • P&T ❑AS • SVE 0 Remedial Additives ❑Other:
The last ISCO injection event was conducted in June 2010.
8. Indicate the lines of evidence used as the basis for selecting
® Analytical data demonstrates a clear and meaningful
over time at appropriate monitoring points.
MNA as a Remedial Action Alternative:
trend of decreasing contaminant mass and/or concentration
demonstrate that natural attenuation processes are active at the site,
MCP endpoints(within 5 years).
demonstrates the occurrence of natural attenuation.
information reviewed.
• Hydrogeologic and geochemical data indirectly
and the rate of the attenuation processes will achieve
❑ A site-specific study of microorganisms directly
• No line-of-evidence basis was presented in the
9. Identification of nearby receptors:
Receptor
(e.g., residence,water supply well,etc.)
residential properties
Location in relation to contaminants
(e.g., on-site, 500 ft. downgradient,etc.)
located>100 feet upgradient(west),across North King Street
un-named stream
located-50 south and downgradient of site
NHESP habitat
located- 750 feet to the southeast
10. Are sentinel monitoring points located between the
contamination and nearby receptors? 0 Yes • No
/28/99 07:56 /Y94135871264 NORTRAMPTON. MA 141001
sas*sSACTIVITYsssassas*sast
*sass ACTIVITY REPORT *****
saassSSasassiss3sissssasas3
TRANSMISSION OK
TX/RA NO. 6878
CONNECTION TEL 915087711886
CONNECTION ID ENGINEERED CONST
START TIME 06/28 07:54
USAGE TIME 01 ' 12
PAGES 2
RESULT OK
FAX
Date: June 28, 1999
Number of pages including cover sheet 2
To:
Robin Stevens
ECCI
Phone
Fax Phone
CC:
508-771-1886
From:
Northampton Board of Health
210 Main Street
Northampton,MA 01060
Peter J.McErlain,Health
Agent
Phone
Fax Phone
(413) 587-1213
(413) 587-1264
HEM AIt1:S:
Urgent
® For your review
Reply ASAP
Attached is an application for a permit to Abandon a sewage disposal system.
Please return to the Board of Health office.
Please contact me with any questions.
Please comment
"24/99 14:40 FAX 1 508 771 1886 ENGINEERED CONST
Engineered
Construction
Company Inc.
FAX COVER SHEET
TOTAL it OF PAGES ( 2 )
COMPANY:NORTHAMPTON
DEPARTMENT OF HEALTH
DATE: 6(24/99
ATTN: PETER MCERLAIN
FROM: ROBIN STEVENS
FAX#: (413)587-1264
FAX#: (508) 771-1886
Reply ASAP
X
Please Review
X
For Your Info.
X
Thank you for responding to our request for
permit information for the Northampton State
Police Project.
Please fax a permit application to abandon a
septic tank in Northampton since we will be
totally removing the tank.
Again, thank you for your assistance
270 Communication Way,Suite 1B,Hyannis,Massachusetts 02601
Established 1983 (508)771-1174 Fax(508)771-1886 Incorporated 1990
/44/99 14:40 FAX 1 508 771 1888
23/99 13:01 T194135471224
FAX
Pate: - 30, 1999
timber apneas iaehadioa cover sheer 2
ENGINEERED CONST
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Nortlampts Howe ofR•adth
21111 Male tmeer
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RECEIVED
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Robin Stereo Peter.1.Marble,Haan
ECCI AVM
Phone
Fax Plume
CC_
SO11-771.1886
❑ uegat
Plume (413)587-1 213
Fax Phew (413)587-1264
® Far year review ❑ Reply ASAP ❑ Please commas
In response to your inquiry,please be that the only permit required by dm Board of Health for a
sanitary sewer line would be for the abandonment of a septic system..
If the State Police Barracks is currently served by a septic system.the following actions will be
(r)• obtain a permit from the Bond of Health to abandon a septic tank(No charge for the shore)
• Pump the tank
• Punch a bole in the bottom of the tank to preen filling with surface water
• Fill the tank with sand sad bury it
• An inspection by the Board of Health confirms the lank has been properly abandoned
Please contact me with any gueations.
Thank you.
is\'hTl ( (+
?Cu et abF*,`r' 0. �.r.1! i�.M 0 .Sot/9- ,
wi&fox- sr reaw.ru:,..b sch� -
TRANSMITTAL
ENGINEERED CONSTRUCTION COMPANY, INC.
270 COMMUNICATION WAY
HYANNIS, MA 02601
(508) 771-1174 FAX(508)771-1886
TO: Northampton Board of Health
210 Main Street
Northampton, MA 01060
DATE: 6/30/99
ATTENTION: Peter McErlain
RE: ECCI Job#2228—Northampton Police Barracks
WE ARE SENDING YOU THE ATTACHED:
( )LETTER ( )PLANS ( )SUBMITTALS
( )CHANGE ORDER ( )SPECIFICATIONS ( )SHOP DRAWINGS
COPIES
DATE: DESCRIPTION
( )SAMPLES
(X)OTHER
1 6/30/99 Application for Disposal System Construction Permit
REMARKS:
Thank you.
COPY TO FILE
SIGNED:
Robin Stevens
Office Manager
This inspection report is signed and certified under the pains and penalties of perjury.
Sincerely,
Peter A. Wheeler
Environmental Health Ifispector,CSP, BEH
cc: Suzanne K.Condon,Associate Commissioner, Director, BEH
Steven Hughes, Director,CSP,BEH
—Northampton Board of Health
Department of Youth Services
Director of Community Services, Western Region Apprehension Gang Unit
Joette E. Robin, Sergeant,Massachusetts State Police
Colonel Marian J. McGovern, Superintendent, Massachusetts State Police
470-12-SP-Northampton-Report 10-17-12.doc Page 2 of 3
DEVAL L.PATRICK
GOVERNOR
TIMOTHY P.MURRAY
IEUTENANT GOVERNOR
'UDYANN BIGBY,M.D.
SECRETARY
JOHN AUERBACH
COMMISSIONER
The Commonwealth of Massachusetts
Executive Office of Health and Human Services
Department of Public Health
Bureau of Environmental Health
Community Sanitation Program
23 Service Center
Northampton, MA 01060
Telephone: 413-586-7525, ext. 1196
Fax: 413-784-1037 TTY: (800)-769-9991
peter.wheeler(astate.ma.us
October 17,2012
ieutenant Andrew Bzdel,Station Commander
Iassachusetts State Police-Northampton Barracks
55 N. King Street
lorthampton, MA 01060
.e: Facility Inspection
/ear Lieutenant Bzdel:
Q v°41■2,
accordance with M.G.L.c. 111, §§ 3,20,21, and 22,and 105 CMR 470.000: Maintenance and Construction of
ockup Facilities; 105 CMR 480.000: Storage and Disposal of Infectious or Physically Dangerous Medical or
liological Waste(State Sanitary Code,Chapter VIII); 1 conducted an inspection of the Northampton State Police
larracks on October 16,2012 at 10:35 a.m. accompanied by you. Violations noted are listed below
indicates conditions documented on previous inspection reports).No violations were noted.
is part of the inspection I also looked for the presence of"potential" suicide hazards beyond the provisions outlined
t 105 CMR 470.000. Attached is a list of conditions 1 observed that could possibly contribute to the commission of a
uicide. While these conditions are not a violation of any law or regulation,you should be aware of their existence.
'o review the specific regulatory requirements please visit our website at www.mass.gov/dph/dcs and click on
Community Sanitation Regulations"(available in both PDF and RTF formats).
70-12-SP-Northampton-Report 10-17-12.doc Page 1 of 3
Conditions Which Could Be Used by a Detainee in the
Commission of a Suicide
Massachusetts State Police- Northampton Barracks
luring the course of the inspection on October 16,2012, the following conditions which may serve as an anchor point
the commission of a suicide were noted:
➢ Broken lexan in cell# 1
✓hile this is not a violation,you should be aware of its existence.
Sincerely,
Environmental Health Inspector, CSP,BEH
Peter A.W heeler
170-12-SP-Northampton-Report 10-17-12.doc Page 3 of 3
To review the specific regulatory requirements please visit our website at www.mass.gov/dph/dcs and click on
"Regulations"then "Lock Up Facilities"(available in both PDF and RTF formats).
This inspection report is signed and certified under the pains and penalties of perjury.
Sincerely,
Peter A. Wheeler
Environmental Health Inspector, CSP, BEH
cc: Suzanne K.Condon, Associate Commissioner, Director, BEH
Steven Hughes, Director,CSP, BEH
Merridith A.O'Leary, RS,Director, Northampton Board of Health
Tracy Longvall-Rivera,Director of ALPS, Department of Youth Services
Director of Community Services, Western Region Apprehension Gang Unit
Joette E. Robin, Sergeant, Massachusetts State Police
Lieutenant Colonel Timothy P. Alben, Superintendent. Massachusetts State Police
470-13-SP-Northampton-Report 124-13 Page 2 of 3
DEVAL L.PATRICK
GOVERNOR
)1-IN W.POLANOWICZ
SECRETARY
IERYL BARTLETT,RN
COMMISSIONER
The Commonwealth of Massachusetts
Executive Office of Health and Human Services
Department of Public Health
of
Bureau of Environmental l H Health �v
Community Sanitation Program
23 Service Center
Northampton, MA 01060
Telephone: 413-586-7525, ext. 5863196
Facsimile: 413-784-1037 / TTY: 800-769-9991
Peter.Wheeler@state.ma.us
December 4, 2013
Aeutenant James Dalton, Station Commander
vlassachusetts State Police—Northampton Barracks
■55 N. King Street
Vorthmnpton,MA 01060
2e: Facility Inspection- Massachusetts State Police—Northampton Barracks
>ear Lieutenant Dalton:
n accordance with M.G.L.c. 111, §§ 3,20,21, and 22,as well as Massachusetts Department of Public Health
Department)Regulations 105 CMR 470.000: Maintenance and Construction of Lockup Facilities; 105 CMR 480.000:
Storage and Disposal of Infectious or Physically Dangerous Medical or Biological Waste(State Sanitary Code,
:hapter VIII); I conducted an inspection of the Massachusetts State Police—Northampton Barracks on November 13,
1013 at 10:40 A.M. accompanied by Trooper Adam Hakkarainen. Violations noted during the inspection are listed
relow:
HEALTH AND SAFETY VIOLATIONS
'* indicates conditions documented on previous inspection reports)
105 CMR 470.409 Security Devices: Incorrect time on electronic security device
Dbservations and Recommendations
1. This facility does not have a separate detention area for juveniles as required by 470.401. Please provide a
copy of your facility's policy for holding juveniles.
2. This facility has one cell block,making compliance with 470.402. Location of Female Cells,difficult. Please
provide a copy of your facility's policy addressing the simultaneous detention of males and females.
This facility does not comply with the Department's Regulations cited above. In accordance with 105 CMR 470.000,
please indicate next to each entry on the inspection report a plan of correction. Said plan of correction must be
submitted within 21 days of receipt of this letter and should detail the specific steps that will be taken and the date of
expected compliance. The plan of correction should be submitted to my attention,at the address listed above.
As part of the inspection, I also looked for the presence of"potential"suicide hazards beyond the provisions outlined
at 105 CMR 470.000. Attached is a list of conditions I observed that could possibly contribute to the commission of a
suicide. While these conditions are not a violation of any law or regulation,you should be aware of their existence.
470-13-SP-Northampton-Report 12-4-13 Page 1 of 3
Conditions Which Could Be Used by a Detainee in the
Commission Ma Suicide
Massachusetts State Police—Northampton Barracks
,s part of the inspection 1 conducted on November 13,2013 1 also looked for the presence of"potential"suicide
azards beyond the provisions outlined at 105 CMR 470.000. Below is a list of conditions which may serve as an
nchor point in the commission of a suicide:
1. Grille cover missing on vent in cell# 1
Vhile this is not a violation,you should be aware of its existence.
Sincerely,
Peter A. Wheeler
Environmental Health Inspector,CSP, BEH
470-13-SP-Northampton-Report 12-4-13 Page 3 of 3
To review the specific regulatory requirements please visit our website at www.mass.gov/dph/dcs and click on
"Regulations"then"Lock Up Facilities"(available in both PDF and RTF formats).
This inspection report is signed and certified under the pains and penalties of perjury.
Sincerely,
Peter A. Wheeler
Environmental Health inspector,CSP, BEM
cc: Suzanne K. Condon,Associate Commissioner, Director, BEH
Steven Hughes, Director, CSP, BEH
Merridith A. O'Leary, RS, Director,Northampton Board of Health /
Tracy Longvall-Rivera,Director of ALPS, Department of Youth Services
Director of Community Services, Western Region Apprehension Gang Unit
470-13-Northampton-Report 12-0-13
Page 2 of 2
DEVAL L.PATRICK
GOVERNOR
]FIN W.POLANOWICZ
SECRETARY
BERYL BARTLETT,RN
COMMISSIONER
The Commonwealth of Massachusetts
Executive Office of Health and Human Services
Department of Public Health
Bureau of Environmental Health
Community Sanitation Program
23 Service Center
Northampton, MA 01060
Telephone: 413-586-7525, ext. 5863196
Facsimile: 413-784-1037 / TTY: 800-769-9991
Peter.Wheeler@state.ma.us
December 4,2013
tussell Sienkiewycz,Chief of Police
Northampton Police Department
?9 Center Street
Northampton,MA 01060
2e: Facility inspection -Northampton Police Department
Dear Chief Sienkiewycz:
In accordance with M.G.L. c. 111, §§ 3, 20,21, and 22, as well as Massachusetts Department of Public Health
"Department)Regulations 105 CMR 470.000: Maintenance and Construction of Lockup Facilities; 105 CMR 480.000:
Storage and Disposal of Infectious or Physically Dangerous Medical or Biological Waste(State Sanitary Code,
:hapter VIII); I conducted an inspection of the Northampton Police Department on November 12,2013 at 1:20 p.m.
accompanied by Staff Sargent Caputo,Northampton Police Department.No violations were noted.
As part of the inspection,I also looked for the presence of-potential" suicide hazards beyond the provisions outlined
at 105 CMR 470.000. Attached is a list of conditions 1 observed that could possibly contribute to the commission of a
suicide.While these conditions are not a violation of any law or regulation, you should be aware of their existence.
As part of the inspection,I also looked for the presence of"potential" suicide hazards beyond the provisions outlined
at 105 CMR 470.000.There were none noted during the inspection.
470-13-Northampton-Report 12-4-13 Page 1 oft