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122 Letters 1999-2014 ARGEO PAUL CELLUCCI Governor JANE SWIFT Lieutenant Governor Tech Alloy Co., Inc. 122 Federal St. Northampton, MA 01061 Attention: Scott Soutra Dear Mr. Soutra: COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION WESTERN REGIONAL OFFICE August 12, 1999 Re: Northampton Tech Alloy Co., Inc. 122 Federal St. Tetrachloroethylene Release RTN: 1-13053 RELEASE NOTIFICATION and NOTICE OF RESPONSIBILITY; M.G.L. c.21E and 310 CMR 40.0000 BOB DURAND Secretary LAUREN A LISS Commissioner On August 5, 1999 at 8:15 PM. a representative of the Northampton Fire Department (NFD) provided notification to the Department of a release and/or threat of release of approximately 2.1 To 5.6 gallons of tetrachloroethylene from a malfunctioning distiller located at the above property. In addition to oral notification, 310 CMR 40.0333 further requires that a completed Release Notification Form (RNF)be submitted to the Department within 60 calendar days of the date of the oral notification. The Department has reason to believe that the release/threat of release reported is or may be a disposal site as defined in the MCP. The Department also has reason to believe that you(as used in this letter "you" refers to Tech Alloy Co., Inc.) are a potentially responsible party (PRP) with liability under Section 5A of M.G.F. c. 21E. This Information Is mailable Lr alternate format M.calling our 104 Coordinator at(617)5744872 436 Dwight Street•Springfield.Massachusetts 01103•FAX(413)784-1149•TDD(413)748E620•Telephone(413)784-1100 Cat Printed on Recycled Paper Tech Alloy Co. , Inc. Notice of Responsibility RTN 1-13053 This liability is "strict", meaning that it is not based on fault, but solely on your status as owner, operator,generator, transporter,disposer or other person specified in said Section 5A. This liability is also "joint and several", meaning that you are liable for all response costs incurred at a disposal site even if there are other liable parties. The Department encourages PRPs to take prompt and appropriate actions in response to releases and threats of release of oil and/or hazardous materials. By taking the necessary response actions, you may significantly lower your assessment and cleanup costs and/or avoid liability for costs incurred by the Department in taking such actions. You may also avoid or reduce certain permit or annual compliance fees payable under 310 CMR 4.00. Please refer to M.G.L. c. 21E for a complete description of potential liability. For your convenience, a summary of liability under M.G.L. c. 21E is attached. You should be aware that you might have claims against third parties for damages, including claims for contribution or reimbursement for the costs of cleanup. Such claims do not exist indefinitely but are governed by laws,which establish the time allowed for bringing litigation. The Department encourages you to take any actions necessary to protect any such claims you may have against third parties. At the time of oral notification to the Department, the Department approved the following response actions as Immediate Response Actions (IRA): The Department did not approve any IRAs. The NFD passively ventilated the building to mitigate any potential fire, explosion, and employee health hazards. Specific approval is required from the Department for the implementation of an IRA with the exception of assessment activities, the construction of a fence and/or posting of signs. Additional submittals are necessary with regard to this notification including, but not limited to,the filing of an IRA Completion Statement and/or Response Action Outcome (RAO) statement. The MCP requires that a fee of $750.00 be submitted to the Department when an RAO Statement is filed greater than 120 days from the date of initial notification. It is important to note that you must dispose of any Remediation Waste generated at the subject location in accordance with 310 CMR 40.0030 including, without limitation, contaminated soil and/or debris. Any Bill of Lading accompanying such waste must bear the seal and signature of a Licensed Site Professional (LSP). You may contact the LSP Board of Registration at 617/556- 1145 to obtain the current LSP list. If you have any questions relative to this notice, you should contact Ben Fish at the above letterhead address or by telephone at 413-784-1100 ext. 2285. All future communications regarding this release must reference the Release Tracking Number(RTN) contained in the subject block of this letter. 2 Tech Alloy Co. , Inc. Notice of Responsibility RTN 1-13053 BF/bf P:nhamp053.mf copy: Northampton Health Department Fire Department Mayor's Office Very truly yours, David A. Slowick Section Chief Emergency Response Certified Mail Z 456 365 160,Return Receipt Requested Attachments: Release Notification Form; BWSC-003 and Instructions Summary of Liability under M.G.L. c. 2I E 3 NORTHAMPTON,RTN 1-16452 NOTICE OF AUDIT 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 14 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 14 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, hut the Department is not required to grant extension requests. Request For Site Inspection The Department requests an appointment to inspect the site on April 22,2013,at 10:00 am. The inspection will be conducted by David Bachand. You or your representatives familiar with the site are requested to attend. The LSP-of-Record may also attend. Please call David Bachand within five(5) days of your receipt of this Notice at 413-755-2221 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 and to discuss the following issues identified during the Department's record review: 1. Evaluation of potential sources of contamination 2. The scope of the sediment and surface water assessment 3. Calculation of soil exposure point concentrations 4. Soil category selection 5. Hot Spot identification 6. Remedy Implementation Plan details and schedule Preliminary audit findings based on the Department's file review may also be discussed during the site inspection. 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. Commonwealth of Massachusetts Executive Office of Energy&Environmental Affairs LEVAL L PATRICK Governor TIMOTHY P.MURRAY Lieutenant earernor Department of Environmental Protection Western Regional Office•43G Dwight Street, Springfield MA 01103.413-784-1100 April 8,2013 Northampton Wireworks Office, Business,&Technology Center,LLC 667 Main Street Holyoke,MA 01040 Attn: Herbert Berezin Manager RICHARD K SULLIVAN JR Secretary KENNETH L.KDAMELL Commcaionu Re: Northampton,RTN 1-16452 Former Wire Manufacturing Facility 122 Federal Street Phase II CRA,Phase III RAP Phase W RIP NOTICE OF AUDIT REQUEST FOR SITE INSPECTION REQUEST FOR INFORMATION Dear Mr.Berezin: 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)which 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 Combined Phase II Comprehensive Site Assessment Report, Phase III Remedial Action Plan,and Phase IV Remedy Implementation Plan prepared by Paul Beaulieu of Tighe and.Bond, Inc., the Licensed Site Professional(LSP)-of-Record,and received by the Department on January 17,2012,for this audit evaluation. In addition,a Tier Classification Submittal received on June 30,2008,also prepared by Paul Beaulieu, is available in Department records for the site and may be evaluated during this audit. The Department's evaluation of the site's compliance status will be based on the information provided in all of the documents identified. TNM Information Is available In alternate formal Call Michelle WMOREKanem,Diversity Director,at 617-262.5761.TDD#1466538-7822 or 1411-674-6568 MassDEP Webllte 1,asw.mass.6ovldeP Printed on Rel.r6.IM Paper Massachusetts D e p e I m e n t ENVIRONMENTAL P R O T E C T I O N A u d i t F a c t S h e e t Authority, Mandate, and Funding for Audits The Massachusetts Department of Environmental Protection(MassDEP)is required to audit response actions at disposal sites by M.G.L. Chapter 21E§3A(o). This law mandates that MassDEP audit a minimum of 20 percent of all the sites that are required to pay annual compliance assurance fees. Regulations that govern the audit process are contained in the Massachusetts Contingency Plan (MCP) (310 CMR 40.1100). M.G.L.c.21E and the MCP also give MassDEP the authority to inspect sites, collect environmental samples, and require that pertinent site information be submitted. What is the Goal of an Audit? Audits ensure compliance with M.G.L. c.21E and the MCP by verifying that response actions have been conducted according to applicable MCP requirements. The audit focuses on determining whether human health, safety, public welfare, and the environment have been adequately protected by response actions conducted at the site. Overall, the MassDEP audit program has been designed to ensure: • Compliance with M.G.L.c. 21 E,the MCP,and other applicable requirements. Consistency of audits within and across MassDEP regions. • Credibility to maintain public confidence that response actions that have little or n direct MassDEP oversight are being performed in a proper and timely manner. • Commitment to achieving the 20 percent audit target in M.G.L.c.21E. How Is The Audit Conducted? The audit includes a comprehensive evaluation of site response actions to ensure compliance with the MCP. This type of Audit is known as a Level 3(L3)Audit and also includes: • An examination of documents in MassDEP site files. • A written Notice of Audit(NOA)that may also include:(1)a request for information, (2)a request to meet with MassDEP,(3)a site inspection, (4) collection of samples,or(5)other actions as required. A Notice of Audit Finding(NOAF)at the conclusion of the L3 Audit MassDEP is not required to issue a NOAF if doing so might jeopardize other enforcement actions at a site. Other types of audit include Level 1 Audits and Level 2 Audits. Additional information on these types of audits can be found on the MassDEP web site at http://www.mass qov/deD/cleanup/compliance/audits.htm When May a Site be Audited? MassDEP selects a site for audit both randomly(Random Audit)and by criteria-specific methods(Targeted Audit)within the following timeframes: • From the point of the initial release notification to 2 years after a Class A or B Response Action Outcome(RAO)Statement has been filed, MassDEP may select a site for a Random Audit. From the point of the initial release notification to 5 years after a Class A or Class B RAO has been filed, MassDEP may select a site for a Targeted Audit. MassDEP may, at any time, initiate/conduct a Random or Targeted Audit of any site subject to an Activity and Use Limitation (AUL). After 5 years MassDEP shall not initiate a Targeted Audit unless it has reason to believe that a significant risk may be present at the site and/or that it is noncompliant. What are My Responsibilities in an Audit? Whether you are a Responsible Party(RP), Potentially Responsible Party(PRP), or Other Person(OP), you have two principal obligations during an audit: • You must respond to any"Requests For Information"(RFI)from MassDEP pursuant to M.G.L. Chapter 21E§§2,4,and 8 and the MCP[(310 CMR 40.0165(1-5)and 40.1120(1)(b 8 c)]. You must allow entry to the site by MassDEP staff, agents,and contractors so they can sample or inspect any records,conditions,equipment practices, or property NOTICE OF AUDIT NORTHAMPTON,RTN 1-16452 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 David Bachand at 413-755-2221. The Department appreciates your anticipated cooperation in this matter. Sincerely, David Bachand Environmental Analyst Certified Mail#7011 3500 0000 8445 3977 Return Receipt Requested ohn Zie Section Ch -f,Audits/Site Management Bureau of Waste Site Cleanup Attachments: A. Audit Fact Sheet B. Certification of Submittal C. Request for Information cc: Paul Beaulieu,Tighe&Bond,LSP-of-Record Northampton,Chief Municipal Officer Northampton,Health Department John Ziegler,WERO,ASM Derrick Bruce,WERO,C&E Data Entry: AUDCOM/NOA, RFI/INTLET NORTHAMPTON,RTN 1-16452 NOTICE OF AUDIT 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 personally examined and am familiar with the information contained in this submittal,that 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. lithe 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: For: Signature Title Name of person or entity RTN#: 1-16452 Date lassachusetts Department of Environmental Protection One Wmer Street Boston,MA 021004746 Commonwealth of Massachusetts Deval L.Patrick,Governor =thy P.Murray,Lt.Governor pursuant to M.G.L. Chapter 21E§8 and the MCP(310 CMR 40.0166). MassDEP, however,must arrange such entry at reasonable times and give you reasonable notice(at least 24 hour prior notice). Am I Required to Engage the Expertise of Others? You are responsible for responding to the audit and complying with any requests made by MassDEP. However,you may engage or may be required to engage the expertise of a Licensed Site Professional (LSP)when responding.to the audit If the audit requests additional follow-up information and/or directs you to submit a Post-Audit Completion Statement(P-ACS)to accompany the information requested, an LSP must be hired. Additional information on the LSP profession and hiring LSPS can be found at the Board of Registration of Hazardous Waste Site Cleanup Professional's web site at http Ilwww mass oov/Isollsphome.htm. How Long Will the Audit Take? or more to Depending The etngth of time will depend on audit findings and any necessary actions. • An audit could end quickly if a file review raises no questions and/or reveals no For example: deficiencies or violations. • An audit could take several weeks to months to complete if information is unavailable, and/or deficiencies or violations are discovered. What May Happen if Violations or Deficiencies are Found? If the audit discovers violations or deficiencies,at the conclusion of the audit MassDEP will issue a NOAF,which may include a Notice of Noncompliance(NON)that may: • Require you to correct those violations within a specified Deadline. • Require you to correct those deficiencies within a specified Interim Deadline. • Require you to submit an Audit Follow-up Plan, which will require MassDEP approval prior to implementation. • Invalidate the submittal and require additional response actions to be conducted to return the site to compliance. Executive Office of Energy&Environmental Affairs Richard K.Sullivan Jr Secretary Department of Environmental Protection • Kenneth'L.Kimmel, Commissioner Produced by the Bureau of Waste Site Cleanup, 11 April 2007. Printed on recycled paper This Information is available In alternate format by calling our ADA Coordinator at (617)2925565 Once these activities are completed,a P-ACS must be submitted to MassDEP together wit must also be submitted foor both the Audit Follow-up Plan an and h Form the Post-Audit Completion Statement,and can be found on the MassDEP web site at htt•://www.mass.••vide• clean era••rovals/bwsc-111. f The audit is considered closed after the P-ACS,with the signatures of the RP, PRP,or OP and the LSP-of- Record, is submitted. These response actions may also be selected for a random or targeted audit. Will MassDEP Take Any Other Actions if Violations are Discovered? MassDEP may also initiate enforcement actions for violations found at any time during or of Intent to Assess any audit. Enforcement N ice of Enforcement Conference, Notice of spoonns Responsibility,Notice of Response a seilcena,lA of Rsponse Action,Administrative Consent Order,Administrative Consent Order with Penalty,MassDEP Order, and/or referrals to the Attorney General's Office or the Licensed Site Professional Board Additional information on MassDEP's enforcement procedures, policies,and cases can be found at htt //www mass cod/dedcleanuo/enforcem.htm Who Should I Talk to if I Have Questions About an Audit Finding? You may call or write the auditor or the contact p submit the the matte NOAF.Are BW3C Deputy u disagree with the findings of the NOAF,you may Regional Director for investigation/resolution. NORTHAMPTON,RTN 1-16452 2 REQUEST FOR INFORMATION 2. Please provide the results of additional soil sampling proposed in the Phase Ill Remedial Action Plan dated January 17,2012, if available. NOTICE OF AUDIT NORTHAMPTON,RTN 1-16452 ATTACHMENT C REQUEST FOR INFORMATION This Request for Information is addressed to Northampton Wireworks Office,Business,& Technology Center,LLC,a Potentially Responsible Party for RTN1-16452,located at122 Federal Street,Northampton. Pursuant to M.G.L. Chapter 21E §§ 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 14 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 anytime after submission of your response to this request that any the portion of the y information you have provided is false or misrepresents the troth,you 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 loeet o 310 CMR 40.0165(3)if you cla im any nrmat on submitted is a trade secre otherwi e 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 request. Note,however, that you,not theLSP,are obligated to respond to this request. this consult with a QUESTIONS 1. Please provide site plans/maps depicting the location of the following potential areas of environmental concern identified in the ASTM Phase I Environmental Site Assessment 07. Techalloy—Northampton Plant,May 2002srecei e d by tthenDt un t rt ent on Janua yng the tube oil above-ground storage tank, 2 equipment,wire manufacturing areas,and related virgin and waste oil and/or hazardous material(OHM) storage areas. In addition,please also identify the locations of loading docks,and several sub-grade structures and piping associated with process(alkaline baths) and wastewater treatment at the facility. ssDEP ALL PATRICK truer 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 RICHARD K.SULLNAN JP. Secretary October 24,2013 Northampton Wireworks Office Business&Technology Center,LLC 677 Main Street Holyoke,Massachusetts 01040 Attn: Herbert Berezin,Manager Re: Northampton,RTN 1-16452 122 Federal Street NON-WE-l3-3A029 Interim Deadlines KENNETH L KIMMEL. Commissioner APPROVAL OF AUDIT FOLLOW-UP PLAN Dear Mr Berezin: Thank you for your response to the Notice of Noncompliance(NON) issued to Northampton Wireworks Office,Business&Technology Center, LLC by the Department of Environmental Protection(the Department)on May 15,2013. The Department has reviewed the Audit Follow- up Plan for the above-referenced site,received on August 29,2013,and prepared on your behalf by Tighe &Bond of Westfield,Massachusetts. Determination The Audit Follow-up Plan provides a supplemental Phase II scope of work (SOW)for the site, which proposes additional assessment activities required to delineate the vertical and lateral extent of metals impacted soils located behind the existing manufacturing building,and to investigate potential source areas of site contamination, including metals and tetrachloroethene, within the footprint of the building. The Audit Follow-up Plan also provides a schedule for submittal of the revised Phase II Comprehensive Site Assessment Report and Phase IV Remedy Implementation Plan(RIP)required by the NON, and a date for implementation of the Comprehensive Response Actions detailed in the RIP. The Department approves the Audit Follow-Up Plan pursuant to 310 CMR 40.1160(3),with the following conditions: on Is available in alternate format Call Michelle Waters-Ekanem,Diversity Director,at 617-292-5751.TDO#4655539-7622 or 1417-5746668 Mosel/EP Websie:www mass.govldep This info Printed on Recycled Paper Northampton,RTN 1-16452 2 Approval of Audit Follow-up Plan • A Tier II Classification Extension Submittal shall be submitted to the Department in accordance with 310 CMR 40.0560 within 30 days of the date of this letter. The site's Tier II Classification expired on June 30,2013. • A revised Phase II Comprehensive Site Assessment which includes a revised risk assessment that meets the requirements of the Massachusetts Contingency Plan(MCP) shall be submitted to the Department on or before September I,2014,as specified in the work plan. • A revised Phase IV RIP that meets the requirements of the MCP shall be submitted to the Department on or before December 1,2014. • requirements of the Completion CP shall be submitted to the Department on Statement June that 0 2015. The dates specified above constitute teim Deadlines established by the Department in accordance with 310 CMR 40.1160(3)(b). You are advised to complete the measures that the Department has required within the deadlines specified above to avoid additional enforcement action by the Department.In accordance with 310 CMR 40.0167(2), any requests to extend this Interim Deadline must be received by the Department in writing,prior to the running of any such deadline, and shall state clearly and concisely the facts which are grounds for the extension and relief sought. If you have any questions regarding this correspondence,or any requirement contained in-it, please contact David Bachand at 413-755-2221 Please reference Release Tracking Number 1- 16452 and Notice of Noncompliance Number NON-WE-13-3A029 in any future correspondence to the Department regarding this matter. Sincerely, David Bachand Enyironmental John Ziegler Section Chief,Audits& Site Management Bureau of Waste Site Cleanup 'Vv Certified Mail If 7011 3500 0000 8445 1584 Return Receipt Requested ec: Northampton,Chief Municipal Officer;Health Department Paul Beaulieu,LSP-of-Record,Tighe&Bond Denise Ant,DEP-WERO 1NTLET Data Entry: AUDCOM/APWRIT; Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup COMPREHENSIVE RESPONSE ACTION TRANSMITTAL Release Tracking Number FORM & PHASE I COMPLETION STATEMENT 1 _ Pursuant to 310 CMR 40.0484(Subpart D)and 40.0800(Subpart H) B.THIS FORM IS BEING USED TO(cont.):(check all that apply) _ 14. Submit a Revised Phase IV Completion Statement, pursuant to 310 CMR 40.0878 and 40.0879. n 15. Submit a Phase V Status Report, pursuant to 310 CMR 40.0892. C 16. Submit a Remedial Monitoring Report.(This report can only be submitted through eDEP.) a.Type of Report:(check one) i. Initial Report C po Interim Report I Final Report b.Frequency of Submittal:(check all that apply) I. A Remedial Monitoring Report(s)submitted monthly to address an Imminent Hazard. I ii. A Remedial Monitoring Report(s)submitted monthly to address a Condition d Substantial Release Migration. n iii. A Remedial Monitoring Reports)submitted concurrent with a Status Report. c.Status of Site: (check one) I I i. Phase IV ii. Phase V ID H. Remedy Operation Status Ei iv.Class C RAC d. Number of Remedial Systems and/or Monitoring Programs: A separate BWSC108A,CRA Remedial Monitoring Report,must be filled out for each Remedial System and/or Monitoring Program addressed by this transmittal form. n 17. Submit a Remedy Operation Status,pursuant to 310 CMR 40.0893. BWSC108 16452 18. Submit a Status Report to maintain a Remedy Operation Status,pursuant to 310 CMR 40.0893(2). 19. Submit a Transfer and/or a Modification of Persons Maintaining a Remedy Operation Status(ROS),pursuant to 310 n CMR 40.0893(5)(check one,or both,if applicable). — a. Submit a Transfer of Persons Maintaining an ROS(the transferee should be the person listed in Section ID,"Person Undertaking Response Actions"). b. Submit a Modification of Persons Maintaining an ROS(the primary representative should be the person listed in Section D, "Person Undertaking Response Actions"). c. Number of Persons Maintaining an ROS not including the primary representative: 20. Submit a Termination of a Remedy Operation Status, pursuant to 310 CMR 40.0893(6).(check one) ` a. Submit a notice indicating ROS performance standards have not been met. A plan and timetable pursuant to 310 CMR 40.0893(6)(b)for resuming the ROS are attached. it b. Submit a notice of Termination of ROS. in 21. Submit a Phase V Completion Statement,pursuant to 310 CMR 40.0894. Specify the outcome of Phase V activities: (check one) a. The requirements of a Class A Response Action Outcome have been met. No additional Operation,Maintenance or _, Monitoring is necessary to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement(BWSC104)will be submitted to DEP. nb. The requirements of a Class C Response Action Outcome have been met. No additional Operation, Maintenance or Monitoring is necessary to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement and Report(BWSC104)will be submitted to DEP. c. The requirements of a Class C Response Action Outcome have been met. Further Operation, Maintenance or — Monitoring of the remedial action is necessary to ensure that conditions are maintained and/or that further progress is made toward a Permanent Solution. A completed Response Action Outcome Statement and Report(BWSC104)will be submitted to DEP. E 22. Submit a Revised Phase V Completion Statement, pursuant to 310 CMR 40.0894. 123. Submit a Post-Class C Response Action Outcome Status Report,pursuant to 310 CMR 40.0898. Revised: 4/1/2009 Page 2 of 5 Massachusetts Department of Environmental Protection Bureau of Waste Site Cleanup COMPREHENSIVE RESPONSE ACTION TRANSMITTAL FORM & PHASE I COMPLETION STATEMENT Pursuant to 310 CMR 40.0484(Subpart D)and 40.0800(Subpart H) TE LOCATION: NO LOCATION AID ite Name treet Address: Iity/Town: 5. Check here if a Tier Classification Submittal has been provided to DEP for this disposal site. a. Tier IA EJ b. Tier IB U c. Tier IC n d. Tier II 'applicable,provide the Permit Number: HIS FORM IS BEING USED (check all that apply) I 1. Submit a Phase I Completion Statement,pursuant to 310 CMR 40.0484. 1 2. Submit a Revised Phase I Completion Statement,pursuant to 310 CMR 40.0484. 3. Submit a Phase II Scope of Work,pursuant to 310 CMR 40.0834. tti 4. Submit an interim Phase II Report. This report does not satisfy the response action deadline requirements in 310 CMR 40.0500. 5.Submit a final Phase II Report and Completion Statement,pursuant to 310 CMR 40.0836. 6.Submit a Revised Phase II Report and Completion Statement,pursuant to 310 CMR 40.0836. 7. Submit a Phase III Remedial Action Plan and Completion Statement,pursuant to 310 CMR 40.0862. 8. Submit a Revised Phase III Remedial Action Plan and Completion Statement pursuant to 310 CMR 40 0862. 9. Submit a Phase IV Remedy Implementation Plan,pursuant to 310 CMR 40 0874. I 10. Submit a Modified Phase IV Remedy Implementation Plan,pursuant to 310 CMR 40.0874. • 11. Submit an As-Built Construction Report,pursuant to 310 CMR 40.0875. • 12. Submit a Phase IV Status Report,pursuant to 310 CMR 40.0877. • 13. Submit a Phase IV Completion Statement,pursuant to 310 CMR 40.0878 and 40.0879. Specify the outcome of Phase IV activities:(check one) co a. Phase V Operation,Maintenance or Monitoring of the Comprehensive Remedial Action is necessary to achieve a Response Action Outcome. Maintenance or b. The requirements of a Class A Response Action Outcome have been met. No additional Operation, n Statement is necessary ess Bo ensure (BWSC104)will integrity o submitted to sponse Action Outcome. A completed Response Action Outcome DEP. c. The requirements of a Class C Response Action Outcome have been met. No additional Operation,Maintenance or Monitoring is necessary to ensure the integrity of the Response Action Outcome. A completed Response Action Outcome Statement and Report(BWSC104)has been or will be submitted to DEP. d. The requirements of a Class C Response Action Outcome have been met. Further Operation,Maintenance or Monitoring of the remedial action is necessary to ensure that conditions are maintained and that further progress is made C toward a Permanent Solution. A completed Response Action Outcome Statement and Report (BWSC104)has been or will be submitted to DEP. BWSC108 Release Tracking Number E - 16452 122 FEDERAL ST NORTHAMPTON 4. ZIP Code 01060-0000 geld Revised:4/1/2009 LMassachusetts Department of Environmental Protection Bureau of Waste Site Cleanup COMPREHENSIVE RESPONSE ACTION TRANSMITTAL FORM & PHASE I COMPLETION STATEMENT Pursuant to 310 CMR 40.0484(Subpart D)and 40.0800(Subpart H) D. PERSON UNDERTAKING RESPONSE ACTIONS: 1. Check all that apply: ❑ a.change in contact name Name of Organization 3. Contact First Name: 5. Street: WIREWORKS LLC BWSC108 Release Tracking Number 1 `16452 !HERBERT b.change of address c. change in the person undertakin res•onse actions • 4.Last Name: !SEREZIN 344 MAIN ST 7. City/Town. IHOLYOKE 0. Telephone: 11.Ext.: 6.Title: 8. State: 12. FAX I E. RELATIONSHIP TO SITE OF PERSON UNDERTAKING RESPONSE ACTIONS: 1_ RP or PRP U a. Owner C b. Operator ✓ e. Other RP or PRP Specify. 1MA I✓I 9. ZIP Code: !01040.0000 I Check here to change relationship c. Generator fl d. Transporter NON-SPECIFIED PRP 2. Fiduciary,Secured Lender or Municipality with Exempt Status(as defined by M.G.L.c.21E,s.2) 3. Agency or Public Utility on a Right of Way(as defined by M.G.L.c.21E,5.5O) C 4. Any Other Person Undertaking Response Actions Specify Relationship: F. REQUIRED ATTACHMENT AND SUBMITTALS: 1. Check here if the Response Action(s)on which this opinion is based, if any,are(were)subject to any order(s),permit(s) and/or approval(s)issued by DEP or EPA. If the box is checked, you MUST attach a statement identifying the applicable provisions thereof. 2. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the submittal of any Phase Reports to DEP. C 3. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the availability of a Phase III Remedial Action Plan. 7 4. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of the availability of a Phase IV Remedy Implementation Plan. E 5. Check here to certify that the Chief Municipal Officer and the Local Board of Health have been notified of any field work involving the implementation of a Phase IV Remedial Action. In 6. If submitting a Transfer of a Remedy Operation Status (as per 310 CMR 40.0893(5)),check here to certify that a statement detailing the compliance history for the person making this submittal(transferee)is attached. T If submitting a Modification of a Remedy Operation Status(as per 310 CMR 40.0893(5)), check here to certify that a statement detailing the compliance history for each new person making this submittal is attached. 6. Check here if any non-updatable information provided on this form is incorrect,e.g.Site Name. Send corrections to: BWSC.eDEP @state.ma.us. ✓J 9. Check here to certify that the LSP Opinion containing the material facts,data,and other information is attached. Revised:4/1/2009 Page of 5 Massachusetts Department of Environmental Protection BWSC106 Bureau of Waste Site Cleanup Release Tracking Number COMPREHENSIVE RESPONSE ACTION TRANSMITTAL FORM & PHASE I COMPLETION STATEMENT Pursuant to 310 CMR 40.0484(Subpart D)and 40.0800(Subpart H) 1 116452 IP SIGNATURE AND STAMP: -it under the is and of perjury that I have pr f t including g ar al l documents accompanyin g this submittal. In m y professional opinion and judgment based upon application of(i)the lard of care in 30 9 CMR 4.02(1).( )the applicable provisions of 309 CMR 4.02(2)and (3),and 309 CMR 4.03(2),and(iii)the sions of 309 CMR 4.03(3),to the best of my knowledge,information and befef, edy Operation Status is being Phase actlon(s)that is(are)the subjecct of this submittl0)r has(hate)been loped loped and implemented in accordance with the applicable provisions of M.G.L c.21 E and 310 CMR 40.0000,(ii)is(are) opriate and reasonable to accomplish the purposes of such response action(s)as set forth in the and visi identified of M.G.L.this E and 310 CMR 40.0000,and(iii)comply(ies)with the identified provisions of all orders,permits, nittal; Section B indicates that a Phase II Scope of Work or a Phase IV Remedy Implementation Plan is being submitted,the once c.21E action(s)that 310 is(are) 40.0000,(ii is(are)appropriate a (have) d rreasonable to developed accomplish the with the of applicable response nO as 21E and in the CMR 40.0000,pr vii (are)M.G.L.P ro(e as set forth in the applicable provisions of M G c.21 E and 310 CMR 40 0000,and(iii)mmply(ies)with the identified risions of all orders,permits,and approvals identified in this submittal; Phase V or Post-Class I Section B indicates that an As-Built Construction Report,a Remedy Operation Status,a Phase IV, ?AO Status Report,a Status Report to Maintain a Remedy Operation Status,a Transfer or Modification of Persons intaining a Remedy Operation Status and/or a Remedial Monitoring Report is being submitted,the response action(s)that is I the subject of 5(are)submittal appropriate and reasonable to accomplish sh accordance e purposes of such Iresp response action(s)as set forth in the and 310 IRable provisions(are) P. P 'linable provisions of M.G.L.c.21E and 310 CMR 40 0000,and(iii)wmply(les)with the identified provisions of all orders,permits, approvals identified in this submittal. n aware that significant penalties may result,including,but not limited to,possible fines and imprisonment,if I submit information ich I know to be false,inaccurate or materially incomplete. LSP#: 9999 First Name: Telephone: Signature: Date: PAUL G (413)562-1600 PAUL G BEAULIEU /17(2012 (mmlddlyyyy) Revised:4/1/2009 5. Ext.: 3. Last Name: 6. FAX BEAULIEU (413)562-5317 9.LSP Stamp Page 3 of 5 Massachusetts Department of Environmental Protection 3. Bureau of Waste Site Cleanup COMPREHENSIVE RESPONSE ACTION TRANSMITTAL FORM & PHASE I COMPLETION STATEMENT Pursuant to 310 CMR 40.0484(Subpart D)and 40.0800(Subpart H) ERTIFICATION OF PERSON UNDERTAKING RESPONSE ACTIONS: attest under the pains and penalties of perjury(i)that 1 have HERBERT a and am familiar including any and all documents molly examined and am if form,M)with the information son my inquiry contained in this Mvidual,' 9 Y �mpanyinh this transmittal (c)that,based this mb ittal i of the Idoif ys wedie and responsible true,oaccurate and the motion,the M that information fully ut orize to in this this do to fhb best of my knowledge one belies, oln or and(iothat a fully this submittal makethis am/is that theroareesignificant f legally responsible includin ,hbut not limited toe aware on ornesty and whose went,this sufllytslb made antis naccuate,torriincomplete ormation.ies,including, :ible fines and imprisonment,for willfully submitting false, ection B indicates that this is a Modification of a Remedy Operation Status(ROS), I attest under the pains and penalties of CMR iry that o receive vauthorized oral a to persons Mass DEP with respect espect actions o performance ROS as actin s under the 3,and t ) 3,and to receive a statement of fee amount as per 4.03(3). derstand that any material received by the Primary Representative from MassDEP shall be deemed received by all the persons orm ing response actions under the ROS,and I am aware that there are significant penalties,including,but not limited to,possible s and imprisonment,for willfully submitting false,inaccurate or incomplete information. BWSC1OS Release Tracking Number 1 116452 3y: HERBERT G.BEREZIN 3. Title: Signature 1111712012 For: WIREWORKS LLC 5. Date: (mMddlyyyy) (Name of person or entity recorded in Section D) 2 6. Check here if the address of the person providing certification is different from address recorded in Section D. 667 MAIN STREET Street: City/Town: . Telephone HOLYOKE 413)534-0955 12. Ext 9. State: MA 13. FAX: 01040-0000 10 ZIP Code: YOU ARE SUBJECT TO AN ANNUAL COMPLIANCE ASSURANCE FEE OF UP TO 510,000 PER BILLABLE YEAR FOR THIS DISPOSAL SITE. YOU MUST LEGIBLY COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM,YOU MAY BE PENALIZED FOR MISSING A REQUIRED DEADLINE Date Stamp(DEP USE ONLY:) Received by DEP on 111712012 2:32:38 PM Page 5 of 5 Revised: 4/1/2009 • . '� CIRCLES INDICATE 500-FOOT AND 112-MILE RADII. BASED ON USGS TOPOGRAPHIC MAP FOR EASTHAMPTON MASSACHUSETTS QUADRANGLE REVISED 1979 10-FOOT CONTOUR INTERVAL JWAN6669\GIS-PDFSWSg$pd1 p d N S MONK Martfian -:Menlo d cq 1 FIGURE 1 SITE LOCUS 122 FEDERAL STREET NORTHAMPTON, MASSACHUSETTS Tighe&Bond SCALE 125,000 JANUARY 2008 V\MalscW\MN066g\usgsmxd ADOW STREET. PINE OTASt{RO Mas6GIS DATA VALID AS OF DECE .Y „„ESP ward....P .. .. ., SPA De- N . BER 2007 PoPeUPPAI PPM,.!We.Blurt..Pm.6101.P -o 1.101-Lane Hwahway NOT „,..A.P•_ FIGURE 2 PRIORITY RESOURCE AREAS 122 FEDERAL STREET NORTHAMPTON, MASSACHUSETTS ,w..,.... ..�� . .] ,P . .,,H. �, //// AN,sr..1.6 o Sub Dm nape Bow ....��,Uc&m u>GSauo,,.,.,,.b., Armt AMN0669\GIS PDFSgi Tighe&Bond SCALE 1:25,000 JANUARY 2008 V\P rolstMMN0669\914 mxd ORTHOPHOTO PRO ID ETBY M SSGIIS FROM APRIL 2005 Legend Approximate Parcel Location N S 0 150 300 eet FIGURE 3 ORTHOPHOTOGRAPH 122 FEDERAL STREET NORTHAMPTON, MASSACHUSETTS SCALE 1:300 Tighe&Bond JANUARY 2008 V Trolects\MN0669Wdliom J\MN66696.GIS-PDFSbNO.pet If you have any questions or comments about this correspondence, or to obtain a copy of the RAO submittal, please contact me at (413) 572-3254. Very truly yours, TIGHE & BOND, INC. Paul G. Beaulieu, PWS, LSP Project Manager/Associate Enclosures Comprehensive Response Action Transmittal Form & Phase I Completion Statement BWSC 108, Figures 1 - 3 Copy: Mr. Herbert Berezin - Northampton Wireworks Office, Business & Technology Center, LLC David Slowick - MA DEP Western Region City of Northampton Department of Health JAN\N0669\phase 11_III_IV\RAO Public Notification_doc Tighe&Bond N-0669 January 17, 2012 ay"M""or David Narkewicz City Hall --210 Main Street, Room 12 Northampton, MA 01060 Re: MCP Phase II, III & IV Report Northampton Wireworks Office, Business & Technology Center, LLC 122 Federal Street Northampton, MA RTN 1-16452 Tighe&Bond Dear Mayor Narkewicz: In accordance with the Public Notification 4Prroaceed Procedures then Massachusetts setse outingenl to the Plan(MCP, 310 CMR 40.1403(3)(f) and (h)), Massachusetts Department of Environmental Protection (MA DEP) of a Phase II, III and IV Report for the above-referenced release site. Historical contaminants identified at the site include metals and petroleum constituents in soil. MA DEP was notified of the historical contamination on December 14, 2006 and Release Tracking Number (RTN) 1-16452 was assigned to the site. Assessment and delineation activities performed at the site include the advancement of multiple soil borings and the installation of multiple groundwater monitoring wells throughout the site. Multiple soil and groundwater have been collected from the site and submitted for laboratory analysis. In addition, sediment and surface water samples have been collected from the adjacent Mill River and submitted for laboratory analysis. Assessment and delineation activities performed at the site indicate that a condition of No Significant Risk does not exist at the site and Remedial Activities are required at the site. A copy-of-the Phase II, III and IV submittal can be obtained from the Western Regional Office of MA DEP at 436 Dwight Street in Springfield, MA. Public file review sessions are held every Wednesday at the Western Regional Office of MA DEP. A copy of the Release Notification Form (BWSC-103) is attached. For more information about file review, please call the MA DEP Service Center at (413) 784-1100. Kr 53 Southampton Road • Westfield, MA 01085 • Tel 413.562.1600 • Fax 413.562.5317 191/3011 N-0669 November 26, 2014 Mayor David J. Narkewicz Northampton City Hall 210 Main Street Room 12 Northampton, MA 01060 Re: Revised Phase IV Report Submittal 122 Federal Street Northampton, Massachusetts RTN 1-16452 Tighe&Bond Dear Mayor Narkewicz: In accordance with the Public Notification Procedures of the Massachusetts Contingency Plan (MCP) 310 CMR 40.1403, we are hereby notifying you of the submittal of a Revised Phase IV Remedy Implementation Plan to the Massachusetts Department of Environmental Protection (MassDEP) for the property referenced above. MassDEP assigned Release Tracking Number (RTN) 1-16452 to the site on December 14, 2006 for historical concentrations of metals within site soils. A Comprehensive Phase II, III and IV report was submitted to the MassDEP on January 17, 2012. Additional assessment activities were performed at the site in 2014 and a Revised Phase II Comprehensive Site Assessment report was submitted to MassDEP on September 1, 2014. In accordance with 310 CMR 40.1403(3)(e), a copy of the description of the Comprehensive Remedial Action (CRA) provided in the Revised Phase IV Remedy Implementation Plan is included below. Description of the Selected CRA Limited soil excavation combined with the implementation of an activity and use limitation (AUL) was selected as the most feasible and effective means of achieving a Permanent Solution at the site. The goal of the selected Remedial Action Alternative (RAA) is to excavate contaminated soil where concentration of site contaminants have been identified above applicable Method 3 Upper Concentration Limits (UCLs) and ultimately reduce risk at the site. As detailed within the Revised Phase II grade between S he rearlof theesiteebuilding and the Mill RibverWeAns and 14 an feet d for your reference. e The approximate area where our RAA soil excavation is proposed is approximately 2,750 squaran feet in area with a maximum proposed excavation depth of 15 feet below surrounding grade estimated 1,526 cubic yards of material). As depicted on the attached Site Plan, in order to excavate/remove soils containing UCL exceedances located between the Mill River and the site building, installation of sheeting (or similar earth retention system) is necessary to support the 53 Southampton Road Westfield, MA 01085 • Tel 413.562.1600 • Fax 413.562.5317 adjacent building foundation and the steep bank of the Mill River. Groundwater within the proposed soil excavation area is between 10.75 and 11.74 feet below surface grade. Dewatering will be necessary during the RAA excavation. Permitting Prior to initiating work at the site, a Tighe & Bond Professional Wetland Scientist (PWS) will visit the site to identify and delineate areas subject for protection under the m a sachus ttseWetl od en Protection Act Regulations (310 CMR 10.00) and initiate app P e Northampton Conservation Commission. Vegetation, including trees, may need to be removed from, or near, the work area before sheeting installation or excavation activities will can prepared eed. A Notice of Intent (NOI), including necessary supporting plans and documents, behalf of the site owner and filed with the Conservation Commission and applicable abutters for the proposed work. Work at the site will not proceed until applicable permits or orders are provided by the Conservation Commission. Sheet Piling Installation As detailed above, sheet piling (or similar earth retention systems) will be necessary for safety of personnel, to mitigate potential impacts to the adjacent Mill River and protect the adjacent building during excavation activities. The excavation method will be designed to provide structural support to the foundation of the adjacent building and the adjacent slope toward the Mill River. The approximate boundary of the proposed sheet piling and the limits of the soil excavation are shown on the site plan. The area where sheeting will be installed is approximately 2,750 square feet. Each sheet may be driven/installed using a vibratory driver mounted on the arm of a medium-sized excavator. Heavy equipment, such as excavators and other earth moving machines, will access the work area via the gated fence near O'Rourke's Driving School and Federal Street. The sheeting system will be constructed using interlocking sheets. Sheeting will be driven ahead of and below the advancing excavation to avoid loss of soil or anthropogenic fill materials from below and in front of the sheeting. Each sheet will be driven to at least 2 feet below the bottom of the excavation (approximately 17 feet). The contractor selected for the project will be required to submit details, design drawings, and a description of the means, and methods of the earth retention system selected to complete this project for approval by the property owner. At the conclusion of the soil excavation and backfilling detailed below, sheeting will be removed in a manner that will not endanger the adjacent building or impact the Mill River. Select portions of sheeting may be left in place if it is determined that their removal could damage the building or impact the Mill River. Erosion Controls Erosion controls are a critical component of the selected RA the site. Controls will rk at the slue. to control erosion or correct conditions that develop prior Prior to initiating sheeting installation, excavation or any soil disturbance at the site, either straw wattle or wire tied hay bales combined with a filter fabric siltation fence will be installed to prevent erosion outside of the work area. The approximate location(s) of the erosion controls are shown on the site plan. Hay bales or straw wattle will be anchored to the ground using wooden Tighe?.Bond stakes to prevent movement. Filter fabric siltation fence will be installed adjacent to, and immediately down gradient of, the hay bales or wattle. The bottom of the siltation fence will be buried approximately six-inches below surrounding grade to prevent storm water from undermining the fence. Erosion controls will be periodically monitored and maintained during all phases of the selected RAA. Erosion controls will be repaired, replaced or upgraded as necessary to ensure proper function. Soil Excavation Soil and anthropogenic fill materials will be excavated from within the earth retention system/sheeting area for proper off-site disposal. Based upon our initial calculations, we anticipate that a maximum of 1,500 cubic yards of material could be removed from the site for disposal if the entire sheeted area were removed. However, field screening tools (x-ray fluorescence meter, photoionization detector and/or Dexsil PetroFLAG) will be used to focus excavation on those areas with UCL exceedances to limit potential for slope failure and minimize disposal costs. Materials will be excavated using equipment selected to minimize potential damage to the site. During excavation activities, the removed materials will be temporarily staged in the rear of the building. Using a smaller earth moving machine (Bobcat or similar), the stockpiled materials will be placed into roll-off containers. Filled roll-off containers will be covered and secured with tarps to prevent rain water from entering them and staged in the northern portion of the site. Excavated materials will be placed in roll-off containers at the end of each work day. Up to ten confirmatory soil samples will be collected from the base of the excavation at its maximum depth of approximately 15 feet below grade. Each soil sample will be submitted to a State-certified laboratory for analysis of metals and extractable petroleum hydrocarbons (EPH). The excavation will remain open until laboratory results are received. Based on field screening, confirmatory laboratory results and the vertical extent of the excavation, additional soils may be excavated or the excavation will be backfilled. Groundwater monitoring well MW-4 is located within the excavation area and will be removed during soil removal activities. Other groundwater monitoring wells located outside of the excavation area may be damaged by trucks or heavy equipment during implementation of the RAA. Wells that become damaged or are removed will be repaired or replaced, as needed, at the conclusion of soil excavation and site restoration. Dewatering Information collected during previous assessment and sampling activities at the site have identified groundwater within the proposed excavation area between 10.75 and 11.74 feet below surrounding grade. Dewatering will be required to complete the excavation to the proposed maximum depth. Laboratory analysis of the groundwater samples collected from MW-3R and MW-4 on July 18, 2014 did not identify concentrations of site contaminants above applicable Method 1 Standards. Groundwater will be pumped from the excavation to maintain an adequately dry excavation to allow for soil removal to approximately 14 feet below surface grade. In accordance with 310 CMR 40.0041, Remedial Wastewater generated from the excavation will be handled in a manner adequate to protect health, safety, public welfare, and the environment. Given the very limited Tighe/' Bond work area, limited access and the adjacent Mill River, remedial wastewater pumped from the excavation will be discharged to the City of Northampton publicly owned treatment works (POTW). The pump discharge will be connected to a sewer connection within uildi ding.. The remedial wastewater will be pumped through a silt filter bag or other approved devise prior to discharge. Silt filter bags or sedimentation devices will be maintained, cleaned or replaced as necessary to prevent solids from entering the sewer. Prior to performing excavation activities at the site, the City of Northampton Department of Public Works (DPW) will be contacted to request approval to discharge remedial wastewater into the POTW. One composite groundwater sample will be collected from wells MW-3R and MW-4 and submitted to a State-certified laboratory for analysis. Analytical a parameters will be s the selected DPW meet the requirements of the DPW and POTW. Written approval prior to discharging any remedial wastewater to the POTW. Soil Disposal Prior to performing excavation activities at the site, additional soil samples will be collected from the proposed excavation area for pre-characterization purposes. A licensed drilling firm will be contracted to advance up to three soil borings throughout the area. Each boring will be advanced to approximately 16 feet below surrounding grade and continuous soil samples will be collected from each location. Based on sample depth, spatial distribution, and field observations, select samples will be composited for laboratory analysis. Samples will be submitted to a State-certified laboratory for analysis. Analyses will be selected in accordance with the requirements of the appropriate disposal facility or landfill. Soil pre-characterization and pre-approval by the selected waste disposal facility will expedite soil disposal and minimize the staging of waste at the site. We expect that waste will be removed from the site and transported to the disposal facility or landfill concurrent with ongoing excavation activities. Backfilling and Site Restoration At the conclusion of the work detailed above, the excavation will be backfilled with clean fill materials and the sheeting or similar earth retention system will be removed. Fill materials will be placed in the excavation in 2 to 3 foot lifts and compacted using a vibratory compactor. The excavation will be topped with loam and seeded with an erosion control seed mixture. The erosion controls will remain in-place until the new vegetation is established. Activity and Use Limitation At the conclusion of the work detailed above, site exposure point concentrations (EPCs) will be re- calculated for all compounds of concern and a "hot spot" evaluation will be performed. Based on an evaluation of the site data, including the newly-determined EPCs and the results of a preliminary risk assessment, an AUL may be necessary to narrow the scope of exposure AUL assumptions used to implemented over the entire characterize e site o r to health aportionof the site tosupport the Permane teSolution.ay be Tighe?,Bond copy of the report,questions or contact comments relative ed at this earliest o uld like to obtain a If you have any convenience. Very truly yours, TIGHE & BOND, INC. Paul G. Beaulieu, PWS, LSP Project Manager/Associate Cc: ice;211 N06 14 Revised Phase IV!apt\Public Noti ., NOttheilnP00440ftletia" 3tIon Letter.DOc Tighe Bond