Notice of Audit Request for Info 2002 ANE SWIFT
overnor
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
936 Dwight Street•Springfield,Massachusetts 01103• (413)784-1100
United States Postal Service
1883 Main Street
Springfield,MA 01101-9750
Attn: Brian Granger
February 25, 2002
Re: Northampton, 1-00901
U.S.Post Office
37 Bridge Street
Phase H, Phase III,Phase IV, Phase V
BOB DURAND
Secretary
LAUREN A.LISS
Commissioner
NOTICE OF AUDIT
REQUEST FOR SITE INSPECTION
REQUEST FOR INFORMATION
Dear Mr. Granger:
The Department of Environmental Protection's Bureau of Waste Site Cleanup(the Department)
has selected the above-referenced site for an audit. The Department audits response actions
conducted without Department oversight at oil and/or hazardous material disposal sites, in order
to ensure that these actions are meeting the requirements of Massachusetts laws and regulations,
including Massachusetts General Law Chapter 21E and the Massachusetts Contingency Plan(the
MCP), 310 CMR 40.0000.
An Audit Fact Sheet is attached(Attachment A)that outlines the audit process and provides the
citations in the MCP that relate to the audit process. Audit staff from the Western Regional
Office will primarily focus on the Phase V Remedy Operation Status Submittal and Tier II
Extension Request,dated January 15, 1998,prepared by David Johnson of EMCON and
received by the Department on January 30, 1998, for this audit evaluation. In addition,the
following documents, prepared by EMCON(or by its antecedent,Wehran Engineering Corp.),
are available in Department records for the site and may be evaluated during this audit:
• Phase I Limited Site Investigation, dated September 1991
• Short Term Measure Quarterly Evaluation Reports for 1992 through 1995
• Annual Waiver Status Reports for 1993 through 1996
This Information is available in alternate format by calling our ADA Coordinator et 1617)574-6812.
DEP on the World Wide Web.tetp.r/www.masegovelep
0 Printed on Recycled Paper
Northampton,1-00901 2 Notice of Audit
• Phase II Report, dated February 1995
• Quarterly Inspection Monitoring Reports for the 4th quarter 1995 through 2000
• Phase III Remedial Action Plan, dated November 8, 1995
• Phase IV Remedy Implementation Plan dated November 8, 1995
• Phase V Remedy Operation Status Report, dated January 30, 1998
• Semi-Annual Phase V Operation, Maintenance, and Monitoring Reports for 1998 through
2000
The Department's evaluation of the site's compliance status will be based on the information
provided in these documents. If you are aware of additional, existing documentation relevant to
the response actions being audited at the site,please submit the existing documentation to the
Department within 21 days of your receipt of this notice. Any submittal made in response to this
notice must contain the attached Certification of Submittal per 310 CMR 40.0009(Attachment
B).
Request For Information
The Department needs additional information to clarify the actions taken at the site and/or to
verify the site's compliance with the MCP. A Request for Information is attached as Attachment
C. You must prepare written responses to all questions and/or requests listed and submit them to
the Department within 21 calendar days of your receipt of this notice. Your response must
contain the attached Certification of Submittal (Attachment B), and follow the requirements
outlined in the attached Request for Information. Send your response to this request, along with
the required certification,to the undersigned.
The deadline given for a response to this Request for Information is an Interim Deadline
enforceable under 310 CMR 40.0167. You may request an extension of this deadline in writing,
but the Department is not required to grant extension requests.
Request For Site Inspection
The Department requests an appointment to inspect the site on March 22, 2002, at 10:00 a.m.
The inspection will be conducted by Thomas Keefe. You or your representatives familiar with
the site are requested to attend. The Licensed Site Professional (LSP)-of-Record may also
attend. Please call Thomas Keefe within five(5) days of receipt of this notice at 413-755-2117 if
you need to arrange an alternative date or time. The purpose of the inspection will be to evaluate
the site conditions in relation to the information received by the Department,to inspect the
operation of the Comprehensive Response Action, and to discuss the following issues identified
during the Department's record review:
1. Submission of the Phase IV Final Inspection Report, and Phase V Operation,
Maintenance, and Monitoring Reports;
2. Remedial air emissions; and
3. Evaluating the effectiveness of the Comprehensive Response Action.
Preliminary audit findings based on the Department's file review may also be discussed during
the site inspection.
Northampton,1-00901
Notice of Audit
Audit Results
After the site inspection and review of your responses to the Request for Information, the
Department will evaluate whether the actions taken at the site are in compliance with the
regulations and meet the performance standards needed to protect public health, safety, and the
environment. The Department's determination of compliance will be based on the work
performed as of the date the Department received the submittal. You will receive a Notice of
Audit Findings summarizing the results of the audit.
If the Department finds that response actions were not conducted in compliance with the MCP,
you will be notified of the actions needed to return to compliance. The Department may set
deadlines by which you will be expected to correct any violations,or the Department may pursue
higher level enforcement.
Response actions at the site can proceed as planned during the audit unless the Department
otherwise notifies you. If you have any questions about this notice,or if you cannot comply with
its requirements,please call Thomas Keefe at 413-755-2117. The Department appreciates your
anticipated cooperation in this matter.
Sincerely,
Thomas Keefe
Environmental Analyst
Catherine Wanat
Section Chief, Audits/Site Management
Bureau of Waste Site Cleanup
Certified Mail 7001 0320 0003 0115 7488
Return Receipt Requested
Attachments: A. Audit Fact Sheet
B. Certification of Submittal
C. Request for Information
cc: Northampton Chief Municipal Officer
Northampton Health Department
Northampton Planning Department,Wayne Feiden
George Campbell, LSP-of-Record, IT Corporation
3 Riverside Drive,Andover,MA 01810-1141
Saint John of Cantius Church, 10 Hawley Street,Northampton, MA 01060
Robert Quinn, Esq., Egan,Flanagan, and Cohen, P.C.,
P.O. Box 9035, Springfield,MA 01102
Northampton,1-00901
4 Notice of Audit
Kevin O'Reilly, O'Reilly,Talbot, & Okun Associates,
293 Bridge Street, Suite 500, Springfield, MA 01103-1490
Thomas Potter, Audit Coordinator,DEP-Boston
WERO Audit File
Data Entry: NOA/Phase II,Phase III,Phase IV, Phase V
ATTACHMENT B
CERTIFICATION OF SUBMITTAL (310 CMR 40.0009)
This certification must be included with your response to the Request for Information.
I attest under the pains and penalties of perjury(i)that I have
personally examined and am familiar with the information contained in this submittal,including
any and all documents accompanying this submittal, (ii) that,based on my inquiry of those
individuals immediately responsible for obtaining the information,the material information
contained in this submittal is,to the best of my knowledge and belief,true, accurate and
complete,and(iii)that I am fully authorized to make this attestation on behalf of the person or
entity legally responsible for this submittal. l/the person or entity on whose behalf this submittal
is made am/is aware that there are significant penalties, including,but not limited to,possible
fines and imprisonment, for willfully submitting false, inaccurate or incomplete information.
By:
Signature
Date
Title
For United States Postal Service
Name of person or entity
RTN#: 1-00901
Northampton,1-00901
ATTACHMENT C
Request for Information
REQUEST FOR INFORMATION
This Request for Information is addressed to the United States Postal Service, a Potentially
Responsible Party for the U.S.Post Office,RTN 1-00901, located at 37 Bridge Street in
Northampton.
Pursuant to M.G.L. Chapter 21E §§ 2, 4,and 8,310 CMR 40.0165, and 310 CMR 40.1120(1),
the Department requires you to provide the information requested below. You must prepare
written responses to each item and deliver the responses to the Department within 21 calendar
days of your receipt of this notice.
A separate response must be made to each of the questions in this Request for Information.
Please label each answer with the number of the question to which it responds. Note that you
must provide in writing any specific information that is responsive to the questions even if that
information has not been written previously in any document.
This Request for Information is a continuing request. That is, if information requested here
which is not known or available to you as of the date of your response later becomes known or
available to you, you must forward the information to the Department at that time. In addition,if
you discover at any time after submission of your response to this request that any portion of the
information you have provided is false or misrepresents the truth, you must notify the
Department immediately. You are obligated under 310 CMR 40.0165(2)to promptly provide
the Department any information relevant to this Request for Information and correct any errors in
your response to the Request for Information at any time in the future when you discover such
information or errors. If you do not have any portion of the information requested in your
possession,custody,or control, you should state this in your response and identify the persons
from whom the information may be obtained. You must follow the procedure described in 310
CMR 40.0165(3) if you claim any information submitted is a trade secret or otherwise exempt
from public disclosure.
DO NOT IGNORE THIS REQUEST. Failure to respond to this request or the submission of
false or misleading information may subject you and your officers and employees to enforcement
action by the Department.
You may consult with a Licensed Site Professional (LSP)when preparing a response to this
request. Note,however,that you,not the LSP, are obligated to respond to this request.
QUESTIONS
1. Regarding the leaking underground storage tank that was removed from the site on
November 9, 1989,please describe the following, as may be applicable:
• The dimensions of the excavation;
• Any observations of contaminated soil or groundwater made during excavation;
Northampton,1-00901 2 Request for Information
• The results of any field screening;
• The amount and disposition of any contaminated soil or groundwater removed from the
excavation;
• The results of any post-excavation soil sampling and analysis; and
• The results of any assessment activities relative to soil located beneath or adjacent to the
former tank's concrete anchor pad.
2. The last Phase V Operation,Maintenance, and Monitoring Report for the site was received
by the Department on August 4, 2000. Please provide a summary of the most recent
monitoring data available relative to the total volume of groundwater treated, and the total
volume of weathered gasoline recovered(i.e., including non-aqueous phase liquid,dissolved
phase gasoline, and vapor phase gasoline).
3. Please state the dates of any vapor phase carbon changes or on-site carbon regeneration that
has occurred between July 1999 and the present.