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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.