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1-13320_Phase IV RIP_2-8-2022.pdfMansfield, MA Amherst, MA Chester, VT PHASE IV REMEDY IMPLEMENTATION PLAN FORMER CUTLERY RACEWAY 360 RIVERSIDE DRIVE NORTHAMPTON, MA 01060 MassDEP RTN #1-13320 Prepared for: CUTLERY BUILDING ASSOCIATES 90 CONZ STREET NORTHAMPTON, MA 01060 Prepared by: OHI ENGINEERING, INC. 110 PULPIT HILL ROAD AMHERST, MA 01002 OHI PROJECT #13-1515 Report Date: FEBRUARY 8, 2022 Mansfield, MA Amherst, MA Chester, VT February 8, 2022 Mr. Ben Fish Massachusetts DEP-BWSC 436 Dwight Street Springfield, MA 01103 Re: Phase IV Remedy Implementation Plan (RIP) Former Cutlery Raceway – Headrace Levee Retaining Wall Restoration Project 320-360 Riverside Drive Northampton, Massachusetts DEP RTN: #1-13320 OHI Project #13-1515 Dear Mr. Fish: OHI Engineering, Inc. (OHI) is pleased to submit this Phase IV Remedy Implementation Plan (RIP) for repair and restoration of the headrace levee and retaining wall along the Mill River at the Former Cutlery in Northampton, MA. This project also involves expansion of the existing metals-impacted soil stockpile and construction of a proposed parking lot on the southerly portion of the stockpile. The goal of the proposed work is to prepare the Site for a Permanent Solution with Conditions. The Phase IV RIP for this metals release has been prepared in accordance with requirements of the MCP. If you have any questions or comments, please contact our office. Sincerely, OHI Engineering, Inc. Wm. Lyons Witten, PG, LSP James R. Borrebach, P.E., L.S.P. Regional Manager Principal 110 Pulpit Hill Road Amherst, MA 01002 Tel (413) 835-0780 www.ohiengineering.com Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page i of i Northampton, MA Table of Contents 1.0 INTRODUCTION ........................................................................................................ 1 1.1 Previous Investigations and Activities ....................................................................... 2 1.2 Phase IV RIP Setting ................................................................................................. 2 1.3 Contact Information ................................................................................................... 3 1.4 Priority Resources ...................................................................................................... 3 1.5 Notice of Intent .......................................................................................................... 4 1.6 Regulatory Status ....................................................................................................... 4 2.0 ASSESSMENT ACTIVITIES TO-DATE .................................................................. 5 2.1 Metals in Headrace Fill within AOC-2 ...................................................................... 5 2.2 Metals in Stockpile Soil ............................................................................................. 5 2.3 Metals in Levee Soil .................................................................................................. 6 2.4 Metals in Groundwater .............................................................................................. 6 2.5 Ecological Risk Characterization ............................................................................... 7 3.0 PHASE IV RIP SCOPE OF WORK .......................................................................... 8 3.1 Repoint Vertical Mortared Wall ................................................................................ 8 3.2 Remove Trees & Relax the Slope of the Bank .......................................................... 8 3.3 Re-build Collapsed Dry-laid Stone Wall ................................................................... 8 3.4 Gabion Wall ............................................................................................................... 9 3.5 Extend Retaining Wall ............................................................................................... 9 3.6 Stone Rip-Rap ............................................................................................................ 9 3.7 Geocell Turf Reinforcement Mat Treatment ............................................................. 9 3.8 Soil Stabilization ...................................................................................................... 10 3.9 Stockpile Excavated Soil ......................................................................................... 10 3.10 New Parking Area .................................................................................................... 11 3.11 Removal of Organic Matter ..................................................................................... 11 3.12 Activity and Use Limitations (AULs) ...................................................................... 12 3.13 Post-Construction Monitoring & Maintenance Plan................................................ 12 4.0 ENVIRONMENTAL MONITORING PLAN ......................................................... 14 4.1 Construction Entrance .............................................................................................. 14 4.2 Dust Control & Monitoring ..................................................................................... 14 4.3 Confirmatory Soil Samples ...................................................................................... 15 4.4 Remediation Waste Management ............................................................................ 15 4.5 Construction Period Stormwater Management ........................................................ 15 5.0 REGULATORY STATUS ......................................................................................... 17 5.1 Schedule and Timelines ........................................................................................... 17 5.2 MassDEP Transmittal Form .................................................................................... 17 5.3 Public Involvement .................................................................................................. 17 Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page ii of i Northampton, MA FIGURES Figure 1 Site Locus Figure 2 Aerial Photo Figure 3 Priority Resource Map Riverbank Restoration plan set (OHI, 2022) (Paper copies in separate roll of plans; Electronic copy of plan set located at the very end of the Phase IV RIP.pdf) TABLES Table 1 Tree Species by Size Table 2 Summary of Laboratory Results – Wood Chips APPENDICES Appendix A Summary of Prior Environmental Reports Appendix B Photographs Appendix C Wetland Delineation Report Appendix D Select Prior Summary Soil Results Tables Appendix E BlastoxR Info, MSDS, Treatability Results Appendix F Sediment Trap Calculations Appendix G Laboratory Results Appendix H Health & Safety Plan Appendix I Public Involvement Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 1 of 17 Northampton, MA 1.0 INTRODUCTION On behalf of Cutlery Building Associates, OHI Engineering Inc. (OHI) is pleased to present this Phase IV Remedy Implementation Plan (RIP) for RTN #1-13320 (Figures 1, 2, and 3). The Phase IV RIP involves restoration of the retaining wall along the base of the former Cutlery headrace levee from its upstream origin downstream to the vicinity of MW-4 where a wider flood plain area dissipates the energy of the Mill River. The goal of the proposed work is to prepare the Site for a Permanent Solution with Conditions. This report has been prepared in accordance with requirements of the Massachusetts Contingency Plan (MCP; 310 CMR 40.0000). The Site comprises the former headrace that carried water from the Mill River to the former Northampton Cutlery mill building (see Figure 2). A steep bank separates the former headrace from the east bank of the Mill River, approximately 15 feet below. The course of the former headrace follows a long, relatively flat strip of land approximately 40 to 60 feet wide. The strip extends in the north-south direction and is bordered on the east by Riverside Drive. A slight rise of 5 to 10 feet and a guardrail separates the flat strip of land from Riverside Drive. The former raceway is not directly visible as most of the ground surface has been filled and is now covered in different portions by trees, shrubs, organic debris, and portions of the Cutlery Building and Valley Home Improvement (VHI) parking lots. The course of the headrace has been determined by using historic maps and inspections of ground topography. Water from the Mill River entered the raceway at a former dam at the northern portion of Lot 77. It then continued south in a narrow strip of undeveloped land between Riverside Drive and the Mill River to the area of the now-paved parking lots of VHI (Lot 76) and the Cutlery Building (Lot 32). The downstream end of the headrace abuts the northwestern-most portion of the Cutlery Building where the water entered the Cutlery Building, turned a water wheel to generate power, and was returned to the Mill River via the relatively short tailrace. The raceway was built in the mid-1860’s and carried water until the mid-1900’s. Sometime in the 1940’s or 1950’s the water from the raceway was no longer needed and it was drained. For the next 20 to 30 years, the southerly portion of the raceway, extending approximately 600 feet north from the Cutlery Building (400 feet into Lot 77) was apparently used as a dumping site for household garbage, demolition debris, and industrial wastes. The levee that separates the headrace from the river has also been found to contain hazardous materials (heavy metals). The levee becomes topographically prominent from approximately 600 ft to 880 ft north of the Cutlery Building, where the former headrace has not been filled. The Former Cutlery RTN #13320 has been divided into three Areas of Concern (AOC): AOC-1: This portion of the Site includes the northwestern portion of the Cutlery Lot 32 and the western portion of the VHI Lot 76 as shown on Figure 2. AOC-1 includes the paved parking lots behind the Cutlery Building and the VHI building and the sloped bank down to the Mill River west of these parking lots. This portion of the Site was closed Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 2 of 17 Northampton, MA with a Permanent Solution (Class-A3 RAO-P) in February 2011. AOC-2 and AOC-3: These areas of the Site occupy the narrow strip of undeveloped land between Riverside Drive and the Mill River, from the northern VHI property line to the northern portion of Lot 77, where water entered the raceway at a former dam (Figure 2). AOC-2 includes the filled portion of the raceway, but does not include the bank of the Mill River west of this section. AOC-3 includes the entire exposed levee from the northerly end of AOC-2 north to the chain link fence at the north end of the Site. This portion of the Site, Lot 77, was closed with a Temporary Solution (Class-C1 RAO-P) in February 2011. This Phase IV RIP involves AOC-2 and AOC-3. The goal of the proposed work is to prepare the Lot 77/AOC-2/AOC-3 portion of the Site for a Permanent Solution with Conditions. This Phase IV RIP pertains to AOC-2 and AOC-3. 1.1 Previous Investigations and Activities Previous investigations documented the character of the fill material (contains solid and industrial waste, and demolition debris), and the excavation and stabilization of these materials on Site. A brief summary of these activities is presented in Appendix A. The levee and raceway fill contain elevated levels of the heavy metals antimony, arsenic, chromium, beryllium, lead, nickel, and thallium. 1.2 Phase IV RIP Setting Annual AUL inspections have been conducted by an LSP and reports have been submitted to MassDEP since 2011 when the original RAO-Ps were submitted. Limited repair work to the bank of the Mill River has been an outcome of several of these inspections. All Temporary Solutions must be evaluated every five years for the feasibility of achieving a Permanent Solution. Two such evaluations have been conducted on the Former Cutlery Site, in 2016 and 2021. The evaluations have explored multiple potential remedial actions intended to allow a Permanent Solution closure of the Site under the MCP. Following the February 2021 evaluation, an LSP inspection of the Site after spring snow melt revealed that additional portions of the retaining wall along the base of the headrace levee were in poor condition and had at least partially collapsed in multiple locations and that above each area of wall collapse was an area of increased bank erosion. This condition is evident in the series of Photographs included in Appendix B. Where the retaining wall at the base of the levee had collapsed, or started to, are areas where bank erosion control maintenance had been previously required. The bank restoration areas requiring maintenance in October 2020 are particularly evident in these photographs above areas of collapsed retaining wall. The levee retaining wall in these photographs was built in the 1860s and has never undergone significant repairs; it is in remarkably good condition, but it is starting to fail in critical areas and is in need of significant repairs in order to maintain the stability of the area and prevent erosion to the river. Cutlery Building Associates has maintained the levee bank via more-or-less annual bank stabilization measures. These measures slow the soil erosion into the Mill River, but the overall Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 3 of 17 Northampton, MA impact of a slowly degrading retaining wall is that there is more and more erosion of the bank into the Mill River. The approximate 100-year flood elevation is shown on the photographs in Appendix B. It is evident that the 100-year flood elevation is well above the top of the retaining wall along almost all of the length of this project, and that flood waters have a long-term role in the degradation of the retaining wall. The 100-year flood elevation is depicted accurately on the Riverbank Restoration plan set (OHI, 2022) as described below in Section 1.5. The continued evaluation of potential closure options under the MCP and the degradation of the levee retaining wall have resulted in the preparation of this Phase IV RIP to implement retaining wall and bank restorations that are designed to help the levee withstand the forces of the Mill River for the next 100-plus years. This retaining wall and bank restoration project coincide with the possible sale of one of the Cutlery mill buildings. This pending property transfer will provide the funding necessary to implement the necessary repairs. This is a one-time opportunity to privately fund significant and necessary repairs to the levee retaining wall and the bank it supports as part of achieving a Permanent Solution. 1.3 Contact Information The owner of the Site is the Cutlery Building Associates. The contact person for this facility is: Alan Verson, Partner 413-586-1348 office Cutlery Building Associates 90 Conz Street Northampton, MA 01060 The LSP of Record is: Lyons Witten, PG, LSP 413-835-0780 OHI Engineering, Inc. lwitten@ohiengineering.com 110 Pulpit Hill Road Amherst, MA 01002-4013 1.4 Priority Resources Based on the Massachusetts Department of Environmental Protection (MassDEP) Priority Resource Maps (PRM) for the vicinity, the Property is not located within a Zone II area, Zone A area, Interim Wellhead Protection Areas (IWPA), or medium yield aquifer. The area around the Property is serviced by public water. No private wells are known to exist within a mile of the Property. Mapped wetland areas, 100-year floodplain, estimated rare wetland wildlife habitat, and a certified vernal pool are located within a ½ mile of the Property. The Retaining Wall Restoration Project is located partially within the 100-year floodplain of the Mill River. The MassDEP Phase I Assessment Priority Resource Map is attached as Figure 3. Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 4 of 17 Northampton, MA 1.5 Notice of Intent In order to conduct the Phase IV RIP for metals-impacted-soil excavation work and restoration of the levee retaining wall, a Notice of Intent (NOI) was filed with the Northampton Conservation Commission and MassDEP. On March 15, 2021, wetland boundaries near the work area were flagged by Ward Smith, PWS, of Wendell Wetland Services (WWS) in Wendell, MA. A copy of the WWS Wetland Delineation report dated March 16, 2021 is included in Appendix C. The wetland delineation is shown on the Riverbank Restoration plan set (OHI, 2022). In April, 2021, Randall Izer, PLS of Harold Eaton & Associates, Inc. in Hadley, MA performed an existing conditions topographic survey of Lot 77 which included locating the wetland flags and inclusion of the 100-year flood elevations along the Site. Their Topographic Plan of Land is the base map for the Riverbank Restoration plan set prepared by OHI for this retaining wall restoration project. A copy of the Riverbank Restoration plan set (OHI, 2022) showing the location of the levee retaining wall, the proposed repair areas, and the wetland boundaries as flagged in the field is attached. The public hearing on the NOI is scheduled with the Northampton Conservation Commission for Thursday March 10th at 5:30 (?) pm. 1.6 Regulatory Status MassDEP was notified of this release on February 16, 2000. As noted above, multiple Phases of investigation, assessment, remediation, and annual bank maintenance have occurred at the Site. The AOC-1 portion of the Site comprised of Lots 32 & 76, was closed with a Permanent Solution (Class-A3 RAO-P) in February 2011. AOC-2 and AOC-3 portions of the Site located on Lot 77, were closed with a Temporary Solution (Class-C1 RAO-P) in February 2011. All Temporary Solutions must be evaluated every five years for the feasibility of achieving a Permanent Solution. Two such evaluations have been conducted on the Former Cutlery Site, in 2016 and 2021. The evaluations have explored multiple potential remedial actions intended to allow a Permanent Solution closure of the Site under the MCP. The continued evaluation of potential closure options under the MCP and the degradation of the levee retaining wall have resulted in the development of this Phase IV RIP to implement retaining wall and bank restorations that are designed to help the levee withstand the forces of the Mill River for the next 100-plus years and achieve a Permanent Solution. Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 5 of 17 Northampton, MA 2.0 Assessment Activities To-Date Assessment activities have been conducted at the Site from 1996 through to the present. Below are three representative sample data sets that demonstrate the range of metals-impacted soil within AOC-2 and AOC-3. Many other data have been collected, discussed and submitted to MassDEP, as summarized in Appendix A. 2.1 Metals in Headrace Fill within AOC-2 Results of soil samples collected between 1987 and 2005 from test pits across the filled portions of the headrace (AOC-2), indicated that lead and chromium were present in concentrations in excess of their Upper Concentration Limits (UCL). In addition, the metals antimony and arsenic were present above their Imminent Hazard (IH) concentrations, and nickel was present in excess of the listed Method 1 standard. These results are represented by samples SP-15/DUP-3, TP-12- S1, TP-12-S3, GZA-TP-1, TP-13-S3, and NEE-1 summarized in Tables 2/3/4/6 and shown on Figure 3 from the MCP Phase II & Phase III Submittal (NEE; October 2003), copies in Appendix D. There is not currently an IH condition at the Site. In the Fall 2004 and again in the Fall 2006, New England Environmental (NEE) oversaw the in- situ chemical stabilization and excavation of soil with the highest concentrations of detected metals within AOC-1. These soils were then stockpiled within AOC-2 on top of similarly impacted soil which is fill material within the former headrace. 2.2 Metals in Stockpile Soil Results of soil samples collected between 1987 and 2005 from test pits across AOC-1 indicated that the heavy metals lead, nickel and chromium were present in concentrations in excess of their Upper Concentration Limits (UCL). In addition, the metals antimony, arsenic, and zinc were present in excess of their listed Method 1 standards. In the Fall 2004 and again in the Fall 2006, NEE oversaw the in-situ chemical stabilization and excavation of soil with the highest concentrations of detected metals within AOC-1. These soils were then stockpiled within AOC-2 on top of similarly impacted fill material within the former headrace. These soils had one or more metals with concentrations in excess of the UCL. Confirmatory soil analyses from these excavations indicated that all soil in excess of UCL concentrations within AOC-1 had been removed. The laboratory results for excavated and final confirmatory soil samples were summarized in Tables 4-1 through 4-5 from the IRA Plan prepared by NEE dated June 2006, copies in Appendix D. In 2005, an area of elevated chromium and nickel-impacted soil with concentrations in excess of the UCLs was discovered on the bank within AOC-1. Table 1 from the MCP IH Evaluation & IRA Closure Report (NEE; September 2005) indicated that 10 of the 12 soil samples collected exceeded Method 1 standards for at least one metal (arsenic, beryllium, lead, antimony and/or thallium), nine of these samples exceeded the IH concentration for Chromium. There were no additional exceedances of UCL concentrations beyond the initial sample (CB-1) in this area. A copy of Table 1 is included in Appendix D. There is not currently an IH condition at the Site. Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 6 of 17 Northampton, MA UCL soils excavated from test pits and the CB excavation in AOC-1 were stabilized and shipped off-site to the Turnkey Landfill in Rochester, NH for disposal. The remaining metals-impacted soil was consolidated to the soil stockpile in AOC-2, on top of raceway fill material with similar concentrations of metals. Under the IRA Amendment (NEE, August 2006), the stockpile was covered with orange fencing as a marker, then covered with loam and seeded. Percolation of precipitation was not considered a concern as the concentrations of metals in the soil were demonstrated not to leach in excess of the EPA land treatment concentrations. The stockpile is completely vegetated. 2.3 Metals in Levee Soil Results of 2005 levee soil assessment activities within AOC-3 indicate that the heavy metals arsenic and chromium are present in concentrations in excess of the Imminent Hazard (IH) concentrations, and that nickel is present above its Upper Concentration Limit (UCL). In addition, the metals copper, lead and thallium are present in excess of their listed Method 1 standards. The sampling locations were illustrated on Figure 5 and the results were summarized in Table 5 from the IRA Plan prepared by NEE (June 2006), copies in Appendix D. The samples represented in that assessment were all near-surface (0-3”) soil samples, have not been excavated, are still present along the levee, and as such are subject to potential erosion. Under this Phase IV RIP, much of the levee metals-impacted soil will be stabilized in place, excavated, and added to the stockpile in AOC-2. 2.4 Metals in Groundwater In 2006, a Brownfield Investigation (Table 2-1; OTO, 2006) of the Site was conducted and groundwater samples were collected from eight monitoring wells for laboratory analysis. Laboratory results indicated the presence of lead in monitoring well CR-6 above Method 1 GW- 3 standards, and detectable concentrations of Arsenic, Chromium, Copper, Nickel and Zinc in at least one monitoring well. An unfiltered sample from MW-4 (MW-4U) was also analyzed and indicated elevated concentrations of multiple metals, interpreted to illustrate that the suspended sediment in the water contained metals. However, MCP standards are set on dissolved not total metals in groundwater samples, so the results from this sample have not been included in the present context. A copy of Table 2-1 from the Brownfields Investigation is included in Appendix D. The RAO A3-P C1-P Statement (NEE, 2011) included groundwater sample results from the upgradient wells MW-2S and MW-2D from 2001 and 2006, and the downgradient well MW-4 from 2001, 2002, 2006 and 2008. The results are summarized in the RAO Statement Table 1 and indicate no detections above Method 1 GW-3 standards for MW-2S/D and decreasing concentrations of Nickel in MW-4, with the 2006 and 2008 results below GW-3 standards. A copy of Table 1 from the RAO Statement is included in Appendix D. Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 7 of 17 Northampton, MA 2.5 Ecological Risk Characterization Ecological Risk Characterization of the Site included a  Stage I Ecological Screen included in the revised Method 3 Risk Characterization prepared by OTO dated March 8, 2012 (2012 RC).  Stage I Environmental Screening, Former Cutlery Raceway, 320-360 Riverside Drive, Northampton, MA, dated October 18, 2016 by AMEC Foster Wheeler (2016 Stage 1 ES).  Stage I Environmental Screening, Floodplain Soil, Former Cutlery Raceway, 320-360 Riverside Drive, Northampton, MA, dated January 4, 2017 by AMEC Foster Wheeler (2017 Stage 1 ES). The 2012 RC found that a condition of No Significant Risk existed for Site uplands, terrestrial habitat, and for Mill River surface water. Laboratory results from grab sediment samples collected in 2005-2006 indicate that none of the 14 samples exceeded the MassDEP’s freshwater benchmarks (SSVs) for metals. In 2016, Mill River sediment was again sampled to evaluate whether remedial activities and efforts to control riverbank erosion conducted since 2012 had been effective in reducing concentrations of Site-related compounds in sediment. The 2016 Stage I ES evaluated aquatic habitat, and screened chemicals detected in Mill River sediment against the SSVs. None of the eight composite sediment samples exceeded the SSVs for metals. The 2016 Stage I ES concluded that a condition of No Significant Risk continued to exist for sediment. The 2017 sediment samples were co-located with earlier sampling locations where elevated levels of Nickel had been previously detected. All of the laboratory results for the collocated August 2016 and May 2017 sediment samples were below the SSVs. These results support the conclusion that the 2000 and 2011 DEP-SED-1, DEP-SED-2, and DEP-SED-3 results are no longer representative of these areas of the Site. Considering the findings of the 2012 RC, 2016 Stage 1 ES, 2017 Stage 1 ES, 2017 RAM Completion Report, and most-recent 2017 collocation sediment sampling, a condition of No Significant Risk to the environment exists for Mill River surface water, sediment, terrestrial habitat/uplands, and floodplain soils at the Site, thus completing the Environmental Risk Characterization for the Site. Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 8 of 17 Northampton, MA 3.0 Phase IV RIP Scope of Work The continued evaluation of potential closure options under the MCP and the degradation of the levee retaining wall by the water action of the Mill River have resulted in the development of this Phase IV RIP to implement retaining wall and bank restorations that are designed to help the levee withstand the forces of the Mill River for the next 100-plus years. The goal of the proposed work is to prepare the Site for a Permanent Solution with Conditions. The following Phase IV RIP activities are planned for this Site. 3.1 Repoint Vertical Mortared Wall The upstream-most portions of the retaining wall, approximately 185 feet long, are vertical and were constructed with stone and mortar. This section is in relatively good condition and is mostly between 12 to 15 feet high. Wall height decreases towards the downstream end where it meets the dry-laid portions of the wall, and is roughly six feet high at the dry/mortar junction. Re-pointing of the mortar is required to maintain the long-term structural integrity of the vertical wall. 3.2 Remove Trees & Relax the Slope of the Bank Where the levee bank is quite steep to near-vertical above the retaining wall, the slope of the bank will be relaxed/lowered to a maximum slope of 2H:1V. All excavated soil from bank relaxation and wall repair/rebuilding activities will first be treated in-place to stabilize the metals (see Section 3.8), and then transported to AOC-2 where it will be added to the stockpile of similar soils (see Section 3.9). In order to relax the slope, access the retaining wall, and complete the proposed project, all trees along the levee and its bank will have to be removed. If trees were left in place, when they eventually fall over due to storm forces or old age, their root systems could open the newly rebuilt retaining wall or levee bank treatments exposing the underlying soil to erosion. Rotten stumps can cause soil collapse also resulting in erosion. A survey of existing tree species and their approximate breast-height diameter was conducted by OHI and Mathew Verson. The trees and their relative size are shown on the Riverbank Restoration plan set (OHI, 2022). A count of trees by species and size is summarized in Table 1. In total, 96 trees between 3” and 36” will be removed for this retaining wall restoration project. Roughly 1/3 of the trees are 4” in diameter or less. 3.3 Re-build Collapsed Dry-laid Stone Wall The remaining portions of the retaining wall start at six feet high and gradually become lower to a final height of approximately two feet at the downstream end of the retaining wall. Most of the dry-laid retaining wall is approximately four feet high. Sections of the dry-laid stone wall have collapsed, or started to collapse, and the levee bank above these sections can be observed to have eroded due to the lack of support from the retaining wall below. See Photographs in Appendix B. Where the dry-laid wall is mostly intact, the wall will be re-built to its apparent original height using a combination of stones on the shoreline directly below the collapsed wall, stone Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 9 of 17 Northampton, MA from the walls lining the former headrace, or sourced from off-site. The sections of wall to be rebuilt are illustrated in the Riverbank Restoration plan set (OHI, 2022) and details of this repair are shown in the Typical Wall Repair Type B, Sheet C7-2. 3.4 Gabion Wall In the sections where the dry-laid wall is in worst condition, the remaining stones will be removed and these sections of wall will be replaced with gabion baskets filled with stone. The gabion wall will be dug into the shoreline underlying soil for structural support, will be flush with the front face of the existing wall, and will be built to a height matching the apparent original height of dry-laid stone wall on either end of the gabion section. The sections of wall to be replaced with gabion basket are illustrated in the Riverbank Restoration plan set (OHI, 2022) and details of this installation are shown in the Typical Wall Repair Type C, Sheet C7-2). 3.5 Extend Retaining Wall The stone retaining wall will be extended approximately 105 feet south of its current end point at a height of approximately two feet in order to combat erosion of the bank. Further south, the river bed widens and a flood plain is present which absorbs the energy of flood water, thus reducing its potential for erosion and negating the need for additional retaining wall(s). 3.6 Stone Rip-Rap From the top of the retaining wall up to the 100-year flood elevation, stone rip-rap will be placed on the face of the relaxed slope on top of orange filter fabric (Mirafi 140NL/O, or equivalent); and a bed of crushed stone. The major stones will be flat and angular with a minimum thickness of twelve inches and the interstitial spaces will be filled with smaller stone. This rip-rap is designed to withstand the water forces of a 100-year flood event much better than the current conditions, and prevent erosion of the underlying metals-impacted levee bank soils. The orange fabric, crushed stone and rip-rap are designed to be a risk reduction barrier to prevent dermal contact with remaining underlying impacted soil. Details of the rip-rap construction are shown in the Typical Wall Repair Type A/B/C cross-sections on the Riverbank Restoration plan set (OHI, 2022) Sheet C8-2. 3.7 Geocell Turf Reinforcement Mat Treatment From the top of the rip-rap at the 100-year flood elevation to the top of the levee, the newly relaxed slope will be covered with turf reinforcement mat (VMAX 3000, or equivalent) and four inches of loam on top of orange filter fabric (Mirafi 140NL/O, or equivalent); and a 12-inch layer of clean fill. The geocell mat/blanket is designed to be filled with soil and seeded, allow water to pass through, and to hold a bank in place to impede erosion. The filter fabric, clean fill, loam and turf reinforcement mat are designed to be a risk reduction barrier to prevent dermal contact with remaining underlying impacted soil. Details of the turf reinforcement mat installation are shown in the Typical Wall Repair Type A/B/C cross-sections and the Turf Reinforcement Mat details on the Riverbank Restoration plan set (OHI, 2022) Sheets C8-1 and C8-2. Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 10 of 17 Northampton, MA A four-foot-high chain link fence will be installed along the top of the newly relaxed slope and the vertical pointed wall to restrict access to the Mill River via this slope. 3.8 Soil Stabilization Soil that is located along the entire length of the levee and the levee bank down to the top of the stone retaining wall is assumed to contain elevated concentrations of the metals previously detected at the Site (see Section 2.0). Prior to moving soil in these areas, the soil will be stabilized in place using Blastox®, a patented, fine granular, complex calcium silicate-based additive for stabilizing heavy metals. Blastox® will be applied onto the soil surface, and mixed into the soil using an excavator prior to removal of the soil from the levee and/or bank and transport to the AOC-2 stockpile. The Blastox® process produces insoluble heavy metal compounds through chemical conversion, pH adjustment and physical encapsulation, thereby making the metals unavailable to leach. The total amount of metals in the soil will not change, but their availability to the environment will be dramatically reduced. OHI and Blastox have completed a bench-scale pilot test on the stabilization process using Site soil. OHI collected several composite surface soil samples from a location near the center of the levee, and submitted them to Blastox for the test. Bench test results indicate that the stabilization process will reduce the TCLP concentrations of metals in Site soil to below EPA land application standards (5 mg/L). A similar product and process were utilized in 2005 when metals-impacted soil from AOC-1 was stabilized prior to creating the stockpile in AOC-2. Information on the Blastox® soil stabilization process, the Material Safety Data Sheet, and results of the bench-scale test are included in Appendix E. 3.9 Stockpile Excavated Soil Excavated and stabilized soil from along the levee will be transported to AOC-2 and placed on top of the filled portion of the headrace. The southern portion of the filled headrace already contains a metals-impacted soil stockpile. The existing stockpile will be increased in length toward the north and in overall height. The concentration and speciation of metals detected along the levee are consistent with the metals already contained within the stockpile and the headrace fill. Thus, the stockpile will grow in volume, but not in character. This is consistent with prior soil excavations at the Site as previously agreed between MassDEP and the Cutlery, and thus with the provisions and intent of 310 CMR 40.0030. When final grade, side slopes and compaction of the stockpile are reached, the stockpile will be covered with an engineered risk reduction barrier to prevent dermal contact with remaining underlying impacted soil. The proposed risk reduction barrier will be constructed as follows from bottom to top:  Layer of orange non-woven filter fabric (Mirafi 140NL/O);  18 inches of clean fill;  6 inches of topsoil; and  Vegetation (grass). Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 11 of 17 Northampton, MA The engineered risk reduction barrier installation is shown in the Impacted Soils Stockpile Area cross-section in the Riverbank Restoration plan set (OHI, 2022) Sheet C8-1. 3.10 New Parking Area The southern-most portion of the stockpile is proposed to be covered by a new paved parking area, to allow expansion of parking for the abutter, Valley Home Improvement. A modification of the proposed risk reduction barrier for the paved parking area will be constructed as follows from bottom to top as shown on the Riverbank Restoration plan set (OHI, 2022) Sheet C8-3:  Layer of orange non-woven filter fabric (Mirafi 140NL/O);  12 inches of clean compacted sub-base;  Layer of woven geotextile Mirafi RS380i;  2.5” binder coat asphalt; and  1.5” top coat asphalt. The new parking area will be graded and sloped to drain into and through the existing VHI paved parking lot which drains via gravity through the Cutlery paved parking lot. This water will then discharge into the sediment trap constructed in 2005 within the tailrace when the VHI and Cutlery parking lots were first paved. Calculations attached in Appendix F show that the existing sediment trap will have sufficient capacity to accept the additional stormwater from the new parking lot if one course of 8” concrete block is added along its top. Infiltration of this water into the soil at AOC-2 on Lot 77 is not proposed since such a structure would be within or immediately adjacent to the metals in the filled headrace and could promote leaching of those metals. 3.11 Removal of Organic Matter Tree removal from the Site will be accomplished primarily by crane to protect the Mill River, the levee/bank, and to facilitate removal of the trunks and limbs from the Site. A log-mat road will be installed along the inside face of the headrace parallel with the levee to enable the tree crane to access the Site. Additional log-mats will be utilized on either side of the log-mat road as needed for the crane stabilization pads. Log trucks will utilize the lab-mat road for removal of the trunks and branches. On September 14, 2021, OHI collected a composite sample of various live tree (oak, maple, and birch) branches with leaves and submitted this “wood chip” sample to Pace Analytical of East Longmeadow, MA for analysis of MCP13 total metals. The analysis detected levels of barium, lead, nickel, and zinc that are consistent with published values of metals in wood chips from other locations. The results indicate that wood chips and solid tree logs can be removed from the Site without restrictions. The laboratory results are summarized in Table 2, and a copy of the laboratory report is included in Appendix G. Part of the bank relaxation and retaining wall reconstruction process will involve removal of stumps of the cut trees. Stumps will be relocated to a dedicated area on the stockpile and power Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 12 of 17 Northampton, MA washed to remove soil prior to loading and transport off-site for disposal/grinding. 3.12 Activity and Use Limitations (AULs) This proposed soil excavation/disturbance is permitted by the existing AUL at the Site. The soils are located within AUL-3 on Cutlery Building Associates property, Lot 77. In Section (1)(i) of the AUL, short-term construction, subsurface activities, and relocation of soil are activities which are allowed. Once the wall repairs, levee modifications, and parking lot construction are completed, the existing AUL will require modification to conform with the future uses of the Site and the engineered barrier. AUL modification will be accomplished as part of the Permanent Solution Statement submittal for the Site. 3.13 Post-Construction Monitoring & Maintenance Plan Consistent with the provisions of 310 CMR 30.633 and 310 30.592B(3), post-construction monitoring must occur for a minimum of 30 years following the construction of the risk reduction barrier, or until an engineered risk reduction barrier is no longer required at the site to maintain a condition of No Significant Risk. In accordance with the provisions of 40.0996(4)(c)(7), post-construction activities will be memorialized in a written Post-Construction Monitoring & Maintenance Plan submitted to MassDEP following construction of the engineered risk reduction barrier, at or prior to the submittal of the Permanent Solution Statement. At a minimum, this plan will detail the following:  The name, address, and telephone number(s) of the person(s) responsible for implementation of the post-construction activities plan, together with the name, address, and telephone number of the LSP who will oversee implementation of the post- construction monitoring and maintenance plan.  Plans and provisions for the periodic inspection of the engineered barrier, to observe the integrity of cover and barrier systems, maintain appropriate signage, and document changes in site activities or uses that may negatively impact the integrity or function of the engineered barrier. Inspections of engineered barriers containing a vegetative cover (stockpile and turf mat bank) will occur at least every 3 months for the first year following construction, and at least yearly thereafter; additional inspections of soil covers will occur following severe storms (i.e., storms with an average 10 year or greater return period). All other engineered barriers (rip-rap section of levee bank) will be inspected on at least a yearly basis. Inspections conducted on a yearly basis will be undertaken during the months of April or May. Within 30 days following such an inspection, but no later than June 1st, a written report will be submitted to the regional office of MassDEP memorializing the results of this inspection, and detailing any deficiencies or needed corrective actions.  Plans and provisions for the periodic sampling of groundwater and/or soil gas monitoring wells, if contaminants immobilized by the engineered barrier are considered Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 13 of 17 Northampton, MA soluble and/or volatile. Such plans will specify, to the extent necessary and appropriate, continuing requirements for sampling of groundwater for metals. Soil gas sampling is not anticipated due to the non-volatile nature of metals.  Plans and provisions for the periodic maintenance of the engineered barrier. Such plans will specify, to the extent necessary and appropriate, continuing requirements for erosion and/or subsidence control measures, pavement maintenance, and/or landscaping measures.  Contingency plans and provisions to be implemented in the event of an unanticipated failure of the engineered barrier. Such plans will specify, to the extent necessary and appropriate, procedures and specifications for the replacement of the Separation Layer, marker layer and/or geomembranes. In accordance with the provisions of 40.0875(1)(b), As-Built Construction plans will be prepared and submitted to MassDEP as part of the Post-Construction Monitoring & Maintenance Plan submittal. Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 14 of 17 Northampton, MA 4.0 Environmental Monitoring Plan 4.1 Construction Entrance A construction entrance will be located off of Riverside Drive as shown on the Riverbank Restoration plan set (OHI, 2022) Sheets C4-1, C5-1 and C6-1. The purpose of the entrance is to provide access directly off of Riverside Drive, and prevent the migration of dust, soil and debris from the Site onto the public way. The construction entrance will be 24 feet wide in order for two trucks to enter and exit at the same time. The construction entrance crosses a low ditch between the existing stockpile and Riverside Drive. 4.2 Dust Control & Monitoring During excavation and construction, the Contractor will monitor the air quality where construction activities involve soil handling such as excavation, relocation, staging, loading or grading of soil/waste materials. Visual monitoring will be conducted if there is no reason to believe that the material is contaminated. Dust suppression will be conducted if visible dust is observed. In addition to visual monitoring, air monitoring will be conducted around the Site. Air monitoring will involve appropriate techniques capable of providing real-time indications of air contaminants to protect on-site personnel and the local population. Air monitoring will be performed using particulate meters such as TSI DustTrak II Aerosol monitor, or equal. Each designated operator will be properly trained in the use of the monitoring equipment. Air monitoring will be conducted at three locations (north end of work zone, south end of work zone, and near the center) around the Site at 60-minute intervals or if visible dust is observed for a continuous period of five (5) minutes or more. The results of the air monitoring will be recorded and used as the basis for specifying personal protective equipment (PPE) and determining the need to upgrade/downgrade protective measures. All personnel will be made aware of potential hazards and be informed of air monitoring information. The Contractor’s Site Health and Safety Officer and Superintendent will be responsible for assuring that monitoring is conducted in an appropriate manner and that work practices, engineering controls and/or personal protective equipment are proper for the conditions. Work activities at the Site will be shut down if monitoring values exceed 1 milligram per cubic meter (1 mg/M3) as specified in the project-specific Health and Safety Plan (HASP; Appendix H). Dust will be controlled during excavation of soil/fill material to limit potential spread of contaminants and potential exposure of contaminants to workers and the public. Nuisance dust levels will be reduced by pre-wetting the surface soils and by establishing and maintaining clean access roads. Prior to excavation, areas of exposed earth will be lightly sprayed with water before excavation if there is potential for nuisance dust generation. At a minimum the Contractor will provide clean water, free from salt, oil and other deleterious materials. Additional water spay may be utilized only when an indication of excessive dust is observed. To the extent feasible, the Contractor will Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 15 of 17 Northampton, MA minimize the use of water within the limits of excavation. When feasible, access roads will be sprayed with water on a regular basis to minimize the generation of dust. 4.3 Confirmatory Soil Samples Confirmatory soil samples will be collected after the final grade of the relaxed levee bank has been established and prior to placement of new/replacement materials. The purpose of these samples is to document the metals content of the remaining soil along the levee. Approximately 20 confirmatory soil samples will be collected in a uniform grid along the levee bank surface. The samples will be analyzed for MCP 14 total metals. The goal of this Phase IV RIP soil excavation is to remove metals-impacted soil from exposed locations along the levee to the extent necessary to repair/replace the stone retaining wall. Excavated soil will be placed in the stockpile in AOC-2 and covered with an engineered risk reduction barrier. Remaining metals-impacted soil along the levee will be covered with a similar risk reduction barrier such that erosion by flood and/or stormwater is far less likely, so that a condition of No Significant Risk can be achieved for levee soils; thus, enabling the possibility for a Permanent Solution with Conditions at the Site. 4.4 Remediation Waste Management Metals-impacted soil will be chemically stabilized in place and then moved to the stockpile in AOC-2 on-Site and placed on top of similar soils, expanding the existing stockpile as detailed above in Sections 3.8 & 3.9. This is consistent with past agreements between MassDEP and the Cutlery, and past practices at this Site. There is no known remediation waste that will leave the Site. 4.5 Construction Period Stormwater Management A silt sock will be installed along the length of the Mill River shoreline to prevent sedimentation while wall repair and soil excavation work is being conducted along the levee. A turbidity curtain will be installed along the east side of the Mill River, outside the silt sock, prior to any wall repair or soil excavation activities along the levee to prevent sedimentation of the Mill River. In most locations work will be conducted from the Bank Full Bench/shoreline which borders the retaining wall, with two exceptions as shown on the Riverbank Restoration plan set (OHI, 2022) Sheets C7-1 through C7-4.:  At the far northern extent of the dry-laid stone wall the shoreline is quite narrow and some machinery may need to be located partially over the river for short periods of time. To facilitate the work and protect the Mill River from erosion, log mats will be installed in/along the edge of the river from the Bank Full Bench to the upstream end of the vertical stone/masonry wall. This will provide access to the vertical wall from below for pointing of the masonry and a stable platform for ladders to reach the higher sections of the wall.  At the far southern extent of the dry-laid stone wall the shoreline is also quite narrow, and Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 16 of 17 Northampton, MA any machinery needed to move stone along the shoreline will access the shoreline from the flood plain further to the south. This area will require log mats and turbidity curtain from the flood plain access point to a location where the shoreline is wide enough for the full width of machinery when such work is in progress. Elsewhere, silt fence will be installed around the perimeter of the interior wetland to protect it from siltation and to define the work area. It is understood that log-mat will cover the western edge of this interior wetland for the duration of the project to allow access for the tree crane during tree removal and the excavator and trucks for the balance of the project soil and wall restoration work. Silt fence will also be installed from construction access road south along the road to the VHI parking lot, west along the parking lot to the top of the levee, then north from the VHI parking lot to approximately MW-4 where the bank restoration and tree removal work begins. At this point the silt fence will continue west down the bank to the top of the levee retaining wall and continue upstream/north along the top of the retaining wall to the northerly project terminus at the existing chain link fence, where it will follow the fence easterly to the base of the slope under the road. Silt fence will not be installed along the road as it is elevated above the entire work site, except in the vicinity of the construction access road where silt fence will be installed along its north and south edges. Silt fence will also be installed around the perimeter of the isolated vegetated wetland as shown in the Riverbank Restoration plan set (OHI, 2022) Sheets C7-2 and C7-3. Phase IV RIP - Retaining Wall Restoration Project RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive February 8, 2022 Page 17 of 17 Northampton, MA 5.0 Regulatory Status 5.1 Schedule and Timelines A Phase IV RIP Status Report will be due within 120-days of the submittal of this Phase IV RIP, and every six months thereafter until a Phase IV RIP Completion Statement or Permanent Solution Statement (PSS) is appropriate. We anticipate the tree removal will occur in April/May 2022, and that Phase IV RIP soil excavation will occur in the 2022 construction season. 5.2 MassDEP Transmittal Form This report was submitted electronically as an attachment to the DEP’s Comprehensive Response Action Transmittal Form (BWSC-108) and can be viewed at the MassDEP’s web site: http://db.state.ma.us/dep/cleanup/sites/search.asp and searching for the Site using the RTN. 5.3 Public Involvement Public involvement activities have been conducted in accordance with 310 CMR 40.1403(a) and (e). These activities included notification of the Chief Municipal Officer and the Board of Health in the City of Northampton, as well as the Conservation Commission. Copies of letters sent to these offices are included in Appendix I. FIGURES SITE LOCUSSite Locus www.ohiengineering.com  44 Wood AveMansfield, MA Phone (508) 339-3929Fax (508) 339-3140 110 Pulpit Hill RdAmherst, MA Phone (413) 835-0780Fax (413) 549-7918 LatitudeLongitude Data Source: OHI Project #13-1515 Former Cutlery320-360 Riverside DriveNorthampton, MA Rev. Date: March 24, 2020 N 42° 19' 13.4 N72° 39' 54.7" W Figure 1Locus Map National Geographic www.ohiengineering.com  44 Wood AveMansfield, MA Phone (508) 339-3929Fax (508) 339-3140 110 Pulpit Hill RdAmherst, MA Phone (413) 835-0780Fax (413) 549-7918 LatitudeLongitude Data Source: OHI Project #13-1515 Former Cutlery320-360 Riverside DriveNorthampton, MA Rev. Date: March 24, 2020 N 42° 19' 13.4 N72° 39' 54.7" W Figure 2Orthographic 0 330330 0 165 1" = 330' Google Maps www.ohiengineering.com  44 Wood AveMansfield, MA Phone (508) 339-3929Fax (508) 339-3140 110 Pulpit Hill RdAmherst, MA Phone (413) 835-0780Fax (413) 549-7918 LatitudeLongitude Data Source: OHI Project #13-1515 Former Cutlery320-360 Riverside DriveNorthampton, MA Rev. Date: March 24, 2020 N 42° 19' 13.4 N72° 39' 54.7" W MassGIS, Commonwealth of Massachusetts Executive Office of Environmental Affairs IUSGS Figure 3Priority Resource Map TABLES 3" 4" 5" 6" 7" 8" 9" 10" 11" 12" 13" 14" 16" 18" 20" 22" 24" 30" 36"W Willow 0BB Black Birch 20 33214 1131 1WB White Birch 11Sy Sycamore 1 1BCh Black Cherry 0BL Black Locust 721 1 2 1RM Red Maple 7 11 1 1 1 11NM Norway Maple 0RO Red Oak 911 13111WO White Oak 11E Elm5 3 1 1A Ash0P Polpar0T Tilia11S Sumac0HH Hop Hornbeam 22C Caltapia0B Beech22Total:56SpeciesTotal #Size: Breast Height Diameter (est.)Table 1 ‐ Tree Removal by Size & SpeciesFormer Cutlery Headrace360 Riverside DriveNorthampton, MA 01060RTN #1‐13320OHI Engineering, Inc. Reportable Concentrations (RCs)SAMPLING LOCATIONParameterRCS‐1S‐1/GW‐1S‐1/GW‐2S‐1/GW‐3WOOD CHIPSSampling Date9/14/2021 9:00:00 AMSample Depth‐ FeetSW‐846 6010D (mg/Kg) Metals DigestionANTIMONY20202020ND (1.6)ARSENIC20202020ND (3.3)BARIUM100010001000100044BERYLLIUM90909090ND (0.16)CADMIUM70707070ND (0.33)CHROMIUM100100100100ND (0.66)LEAD2002002002000.85NICKEL6006006006009.3SELENIUM400400400400ND (3.3)SILVER100100100100ND (0.33)THALLIUM8888ND (1.6)VANADIUM400400400400ND (0.66)ZINC100010001000100025NOTES:1. An asterisk (*) following a detection limit indicates that the minimum laboratory reporting limit exceeds one or more of the regulatory criteria.2. ND = Not detected above the lab reporting limits shown in parenthesis.3. NT = Not tested.4. ~  = No Method 1 Standard or UCL available5. Shaded values exceed the MCP Reportable Concentrations (RCs).6. Bolded values exceed the Method 1 Cleanup Standards.7. Bold Red values exceed the TCLP limits.MCP ‐ Method 1 Cleanup StandardsTable 2 ‐ Summary of Laboratory Results ‐ WOOD CHIPSFormer Cutlery Headrace360 Riverside DriveNorthampton, MA 01060RTN #1‐13320OHI Engineering, Inc.21I0777   APPENDIX A Summary of Prior Environmental Reports Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 1 Northampton, Massachusetts 1.0 INTRODUCTION The Site is the former raceway that carried water from the Mill River to the former Northampton Cutlery mill building (Figure 3). A steep bank separates the former raceway from the east bank of the Mill River, approximately 15 feet below. The course of the former raceway follows a long, relatively flat strip of land approximately 40 to 60 feet wide. The strip extends in the north-south direction and is bordered on the east by Riverside Drive. A slight rise of 5 to 10 feet and a guardrail separate the flat strip of land from the road. The former raceway is not directly visible at most of the ground surface because it has been filled and is now covered in different portions by trees, shrubs, organic debris, and the Cutlery Building and Valley Home Improvement parking lots. The course of the raceway has been determined by using historic maps and inspections of ground topography. The downstream end of the raceway abuts the back (western-most) portion of the Cutlery Building. Following its course upstream it then winds north through (under) the now paved parking lots of the Cutlery Building (Lot 32) and Valley Home Improvement (VHI, Lot 76) behind the former firehouse building, and then continues in the narrow strip of undeveloped land between Riverside Drive and the Mill River to the northern portion of Lot 77, where water entered the raceway at a former dam. The raceway was built in the mid 1860’s and carried water until the mid-1900’s. Sometime in the 1940’s, or 1950’s the water from the raceway was no longer needed and it was drained. For the next 20 to 30 years, the southerly portion of the raceway, extending approximately 600 feet north from the Cutlery Building (400 feet into Lot 77) was used as a dumping site for household garbage, demolition debris, and industrial wastes. The levee that separates the raceway from the river has also been found to contain hazardous materials (metals). The levee becomes topographically prominent from approximately 600 ft to 880 ft north of the Cutlery Building, where the former raceway has not been filled. The Site has been divided into three Areas of Concern (AOC): AOC-1: This portion of the Site includes the northwestern portion of the southerly Cutlery Lot 32 and the western portion of the Valley Home Improvement (VHI) Lot 76 as shown on Figures 3 and 5. This includes the paved parking lots behind the Cutlery building and the VHI building and the sloped bank down to the Mill River west of these parking lots. AOC-2 and AOC-3: These areas of the Site occupy the narrow strip of undeveloped land between Riverside Drive and the Mill River, from the northern VHI property line to the northern portion of Lot 77, where water entered the raceway at a former dam (Figure 3). AOC-2 includes the filled portion of the raceway, but does not include the bank of the Mill River west of this section. AOC-3 includes the entire exposed levee from the northerly end of AOC-2 north to the chain link fence at the north end of the Site. 1.1 Previous Investigations and Activities Previous investigations documented the character of the fill material (contains solid and industrial waste, and demolition debris), and the excavation and stabilization of these materials on Site. A brief summary of these activities is presented below. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 2 Northampton, Massachusetts In all areas of AOC-1 where heavy metals were identified in excess of their respective UCLs in 2005, this material was moved to the existing soil stockpile within AOC-2. This includes several areas under the Cutlery and Valley Home Improvement parking lots, and an area on the bank of the Mill River on the Cutlery property. Confirmatory soil samples indicated that the UCL contaminated soil had been removed from AOC-1. Changes to several UCL concentrations were incorporated in the 2006 MCP “Wave 2 Changes”. As a result, the soil sample CB-12 was identified as containing lead (4,480 mg/kg) and antimony (471 mg/kg) at concentrations in excess of their respective UCL concentrations (3,000 mg/kg and 400 mg/kg). These concentrations are part of the calculated Exposure Point Concentrations (EPCs) calculated in the Method 3 risk characterization. The resulting EPCs indicated this material did not need to be removed in order to close this portion of the Site. Residual contamination in this and other areas of AOC-1 is still present in soil. The parking lot area where residual contamination remains was paved. This pavement has been and will be maintained in good condition. The remaining metals-impacted soil along the bank leading down to the Mill River (including CB-12) was physically stabilized in place to prevent any further erosion and these erosion controls have been and will be maintained in good condition. The unpaved areas within AOC-1 have been fenced off with a chain link fence and this fence has been and will be maintained in good condition. In AOC-3, the bank of the Mill River was stabilized using erosion control fabric and grass seed. One section of the stone rip-rap at the base of the bank was re-built in an effort to control erosion. These activities stabilized this portion of the Site and dramatically reduced erosion. Bank stabilization was not required in AOC-2 as this portion of the Site is relatively flat, the bank is further from the Mill River, and is thickly wooded with mature trees. The filled portions of the raceway in AOC-2 were used as the location of a soil stockpile accepting primarily UCL soil from AOC-1. The fill in this area was similar in nature to the stockpile soil, in that it had been found to exceed UCL concentrations of several metals in multiple places, so placement of the stockpile in AOC-2 did not make this location worse. The stockpile was then graded in such a way as to reduce its height and was covered in geo-textile fabric and loam. The pile was then seeded with grass to prevent erosion. A five-foot high chain link fence was then installed at both ends of AOC-2 and AOC-3 and along the entire length of Riverside Drive in such a fashion as to isolate these areas from trespassers. 1.2 Conceptual Site Model The Site is a former water-powered industrial mill which manufactured cutlery table ware. This process involved metal plating, and wastes from the plating were deposited both along the levee and in the former raceway once it was no longer in use. Other waste materials were also deposited in the raceway, but the heavy metals arsenic, antimony, lead, chromium, and nickel are the primary contaminants of concern at the Site, and these have origins with the metal plating process involved in the manufacture of cutlery. Some of these metals were buried deep in the raceway and others were dumped on or near the ground surface of the raceway, the levee, and likely also the bank down to the Mill River. Since the Northampton Cutlery was in operation from about 1865 through the early 1980s, it is likely that some metals eroded into or were simply dumped in the Mill River at one time or another. Erosion of surface soil was evident on the banks of the Mill River and the levee during the early parts of this investigation and this investigation has shown that levee and bank soils Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 3 Northampton, Massachusetts contain elevated concentrations of these same metals. Sampling of the Mill River surface water and sediments indicates that concentrations of the metals present at the Site are not present at significant concentrations within the river at this time. Upstream and downstream sediment samples yield similar concentrations of metals, indicating that the Northampton Cutlery was not the only source of heavy metals to the Mill River sediments. It would not be possible at this late juncture in time to effectively quantify what portions of the metals detected in the river are attributable to this Site. It was possible to change the surface characteristics of the Site in such a way as to eliminate most of the erosion to the Mill River. A systematic and thorough evaluation of the river bank was completed and the following activities were completed toward this goal of limiting erosion: The parking lots were paved, UCL concentrations of metals were excavated from the river bank in AOC-1 and both stabilized and relocated at the Site to the soil stockpile in AOC-2, a portion of the stone retaining wall in AOC-3 was rebuilt at the foot of the levee, the steep and eroding portions of the levee and river bank in AOC-1 and AOC-3 were physically stabilized with a combination of orange plastic fencing, compost, and erosion control blankets, and the soil stockpile was re-graded to have a lower profile, covered in landscape fabric, loam and seed. With these improvements to the ground surface at the Site, virtually all of the erosion has been stopped, thus protecting the Mill River and the public. The metals are still present at the Site, both in and on top of the former raceway, and that is why portions of the Site will have an Activity and Use Limitation (AUL) and others will have a Class C RAO. With these improvements and the addition of an AUL for AOC-1, the level of concern for the Site has been reduced from Significant Risk to No Substantial Hazard (NSH) for AOC-2 and AOC-3, and from Significant Risk to No Significant Risk (NSR) for AOC-1. The current Conceptual Site Model includes a former water-power raceway which was filled with industrial wastes, including several heavy metals. The highest concentrations of these metals within AOC-1 have been moved to the soil stockpile in AOC-2. The banks of the river and the levee have been physically covered and planted to stabilize former erosion. The soil stockpile has been physically stabilized and planted to prevent any possible erosion. The parking lots have been paved and a fence installed around unpaved portions of AOC-1 and all of AOC-2 and ACO-3 to restrict access to these portions of the Site. Limited amounts of metals are leaching to groundwater under the raceway, but these concentrations do not appear to be impacting the Mill River surface water or sediments in a significant way. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 4 Northampton, Massachusetts (Appendix C from ClassA3 RAO-P & ClassC1 RAI-P Statements, NEE Feb 8, 2011) Previously Published Investigations Environmental Site Evaluation, by GZA, 1989 The report documented lead and chromium contamination on the northerly portion of the Site (Lot 77, 360 Riverside Drive). GZA’s evaluation indicated that various debris and metal scraps were buried within the former mill raceway that ran north/south through the lot. Test pits performed to define the extent of the debris, indicated that the material was up to 7 feet thick with a width near the surface approximating the width of the flat portion of the land. The debris was determined to extend roughly 400 feet north into Lot 77. Laboratory analysis of the material sampled from test pit TP-1 indicated elevated levels of total lead and chromium and that the Toxicity Characteristic Leaching Procedure (TCLP) level of lead was 62 mg/L, which exceeded the 1989 (and current) federal standard of 5 mg/L used to identify a characteristically hazardous waste. GZA’s TP-1 is located within 20 feet of the former firehouse’s northern property boundary. Initial Site Investigation, by Almer Huntley, Jr. & Associates, 1996 In their investigations of the building, Huntley did not turn up any evidence of OHM release. No Volatile Organic Compounds or Petroleum Hydrocarbons were detected in the four samples collected. RCRA 8 metals were detected at concentrations below the reportable concentrations (RCs) and were determined by Huntley to not present a significant risk. The borings from which these samples were taken did not intercept the former raceway, and provide evidence that the waste debris does not extend to these locations. Level 1 ESA & Limited Subsurface Investigation Report, by C&C, October 1999 This report included the excavation of three test-pits to evaluate the potential presence of buried debris and lead and chromium contamination. Both debris and metals contamination in the soil were confirmed. The EPH laboratory results revealed concentrations that exceeded the RCS-1 standard of 200 mg/Kg. The concentrations of chromium and lead in TP-1 and TP-2 were also above the RCS-1 standards for these metals. Limited Subsurface Investigation, by C&C, February 2000 This report documents eight additional test pits that were conducted to determine the extent of the debris. It was determined that the debris appeared to be located within the confines of the former raceway, and was contaminated with both Extractable Petroleum Hydrocarbons (EPH) and the heavy metals lead (Pb) and chromium (Cr). Lead and chromium were detected in all twelve samples that were collected. It was also determined from this laboratory testing that the in-situ sediments beyond the extent of the debris fill did not contain reportable concentrations (RCs) of lead, chromium, or petroleum compounds. The release of petroleum compounds, lead and chromium to soil was reported to DEP on February 16, 2000. As part of their response, DEP issued a Notice of Responsibility (NOR) to both Mr. Elbaum and Cutlery Building Associates (RTN 1-13320), and requested that an Imminent Hazard Evaluation be conducted to determine if concentrations of lead and chromium in surface soil constituted an Imminent Hazard as defined by the MCP. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 5 Northampton, Massachusetts Imminent Hazard Evaluation, by C&C, October 2000 Eight surficial soil samples were collected from areas identified as being within the former raceway. The waste fill material was found below a four-inch organic layer. No fill material was observed directly on the surface at any of the sampling locations. Laboratory results from all eight samples confirmed the presence of lead and chromium in surficial soil. The DEP collected three sediment samples from the Mill River. On this date, the DEP also collected a surface soil sample from on top of the former raceway levee, approximately 300 feet south of the former dam that once diverted water into the raceway. The surface soil sampled was a mixture of black ash and cinder and a pink-tan fine sand. This material was found to contain arsenic in excess of the Imminent Hazard standards, and was the basis of DEP’s request to conduct a second Imminent Hazard Evaluation. Imminent Hazard Evaluation for Arsenic–IRA Plan & Status Report, by C&C, December 2000 Twelve shallow test pits were dug to 1 foot below ground in the vicinity of DEP-1. It was determined that a layer of pink-tan sand existed that was approximately 4 feet wide and 12 feet long and varied in thickness from 4 inches to less than 1/16th of an inch. Laboratory analysis of four samples taken from these test pits indicated that the pink-tan sand was the source of the Imminent Hazard concentrations of arsenic. All observed pink-tan sand was removed from the levee by shoveling the material into 55-gallon drums. Three drums of material were removed from the area surrounding DEP-1 on November 21, 2000, and on November 22, 2000, three additional drums of soil were removed from a location approximately 40 feet south of DEP-1 that was discovered during the initial removal process. This soil was removed from the Site under a Uniform hazardous Waste Manifest. With this IRA activity complete, the highest known concentrations of arsenic have been removed from the Site. Three shallow test pits located in the driveway of the Cutlery Building, just off the west edge of the northern section of the building, were also excavated. Waste fill was found in all three test pits, therefore indicating that the edge of the former raceway exists parallel to the west edge of the northern section of the building. The top of a stone wall that is visible approximately 20 feet west of the edge of the building is presumed to be the western edge of the raceway at this location. These observations are consistent with the depiction of the raceway on the Sanborn maps. A sample from each of the test pits was submitted for laboratory analysis of RCRA 8 metals, reactivity, cyanide, and polychlorinated biphenyls (PCBs). Concentrations of arsenic above the Imminent Hazard criteria and concentration of total chromium and lead exceeded the Method 1 cleanup standard. Additional driveway gravel was added to the parking as an Institutional Control to bring the depth of the waste fill to a depth greater than 12 inches, thereby relieving the arsenic Imminent Hazard condition in the parking lot. The owner has agreed to maintain the parking lot with adequate cover, until a more permanent solution is reached. Seventeen evenly spaced test holes were dug to a depth of 1 foot with a spade along the top the levee. Samples were collected and found concentrations of arsenic that exceeded Imminent Hazard criteria and elevated concentrations of total chromium. Location IH-L-18 was re-sampled to confirm the elevated chromium concentration and to test for the presence of hexavalent chromium. This result confirmed that hexavalent chromium has not been detected at the Site, and is therefore inferred to not exist. Because additional portions of the levee contain elevated, Imminent Hazard, concentrations of arsenic, a fence has been erected, along with warning signs, to discourage access to the site. The effort to achieve a final resolution to the Imminent Hazard condition is ongoing at this time. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 6 Northampton, Massachusetts Phase I Initial Site Investigation Report, by C&C, February 2001 C&C supervised the excavation of four backhoe test pits that indicate the buried debris is concentrated in a strip, approximately 40 feet wide, which runs in a north/south direction parallel to the bank. The vertical extent of buried debris generally decreases moving towards the east/west limits of the strip, and is greatest near the center of the strip extending to approximately 6 to 8 feet below ground surface. Concentrations of EPH, Chromium, lead, antimony, arsenic and nickel were all detected above the Method 1 cleanup standards. Three additional samples were collected from the levee and were analyzed for Total PP13 Metals, and samples were also analyzed for hexavalent chromium. Arsenic, chromium thallium and nickel were reported above the cleanup standards and hexavalent chromium was not detected. Groundwater sampling of the five monitoring wells was conducted and indicated concentrations for both EPH and Soluble PP13 Metals were below the detection limit in all samples except MW-4 where nickel and zinc were detected. The groundwater laboratory results suggest that contamination from the raceway fill does leach to the groundwater in detectable concentrations at selected locations, but not at others. C&C collected four sediment samples from the Mill River and two sediment samples. DEP collected three sediment samples from the Mill River. The DEP samples were analyzed for the Soluble PP13 Metals, and C&C’s six samples were analyzed for the 8RCRA Metals. Various metals were detected in varying concentrations in the eight sediment samples, but all were below the Method 1 standards. The northern portion of the Site has been temporarily fenced off to prevent unauthorized access. A permanent fence installation is planned for the Spring of 2001. Upon completion of this fence installation, it is anticipated that the Site will no longer pose an Imminent Hazard, and re-classification of the Site will be considered. As part of the Tier Classification process, the Numerical Ranking System Scoresheet was completed in accordance with 310 CMR 40.1500(9) and the Site received a score of 362. As this value is between 350 and 450, the Site is classified as Tier IC. Phase II – Comprehensive Site Assessment (Phase II) & Phase III – Identification, Evaluation and Selection of Comprehensive Remedial Action Alternatives Report (Phase III), by NEE, October 2003 The content and location of the fill material, and materials deposited along the levee between the raceway and the Mill River are now known. This report documents the concentration of metals in Site groundwater, and the lack of significant concentrations of metals in river sediments. These materials comprise the known OHM at the Site, and therefore the nature and extent of contamination are known and described in this report. Fill material in the raceway was found to be approximately six feet deep for the length of the filled portion of the raceway and to extend to a width of around 30-40 feet. This filled area is roughly 300 feet long. In the southern portion closer to the former mill building, the filled area cross-section has a rounded bottom shape, and in the northern portions a more rectangular cross-sectional shape. The fill itself consists of building demolition debris (wood, electrical conduit, asphalt roofing, plaster), solid waste (shoes, glass, cans, and plastic), and industrial wastes (4” leather belts; colored sand; metal knife blanks; metals-, petroleum-, and to a far lesser degree PCB-impacted soil). Soil in the filled areas was found to contain contaminants and the sand below the fill was found to not contain contaminants at concentrations requiring additional action. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 7 Northampton, Massachusetts On the levee, the upper one to three feet of soil along identified areas of the raised portion of the levee was found to contain elevated concentrations of metals, primarily in colored sands (red, pink, and green). The sand and gravel of natural appearance underlying these colored sands did not contain elevated concentrations of contaminants. Approximately half of the exposed levee length has experienced adverse impact from metals. In the area of the fill under the driveway behind the former Firehouse building, TCLP Pb levels above the land application standard were identified in one sample. Two samples analyzed for TCLP Pb collected in the levee reported concentrations below the land application standard therefore; the TCLP Pb is a small isolated problem in the fill material only. No areas of surface water runoff from the Site to the Mill River were observed, except at the extreme northern end of the property near the former raceway dam, and no contaminants were identified in soil in this location. Contaminants were detected in Mill River and wetland sediment samples but not at elevated concentrations, and similar low concentrations were detected in an upstream sample as in the samples adjacent to the Site and downstream of the raceway. Nickel was consistently detected at elevated concentrations in one on-site groundwater monitoring well, MW-4. Other contaminants found at the Site were not detected at elevated concentrations in this or the other three monitoring wells at the Site. Based upon the a comparison of the Site exposure point concentrations with the applicable Method 1 standards, the exposure point concentration for groundwater at MW-4 exceeds the GW-3 and Upper Concentration Limit (UCL) standards. MCP Phase IV Remedy Implementation Plan (RIP), by NEE, August 2004 The following remedial options were considered the best alternatives for the areas of concern (AOC) at the Site noted below. Each will require approval from appropriate state and local authorities, and each is considered reliable in the long-term for the Site. AOC-1: Excavate hot spots from under the parking lots and consolidate this material within AOC-2 (completed). Pave the parking lots and place an AUL on the new pavement areas for the residual metals-impacted soil. AOC-2: Consolidate the excavated soil from AOC-1 and AOC-3 in this area and either a) phytoremediate the metals, or b) stabilize the metals in place. AOC-3: Excavate hot spots and other impacted soil off the top of the levee and consolidate this material within AOC-2 (started). The goal in this area was to achieve Method 1 soil standards. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 8 Northampton, Massachusetts Phase IV – Interim Construction Report, by NEE, August 2, 2005 MCP Phase IV REVISED Remedy Implementation Plan, by NEE, September 2005 Problem with RIP: AOC-1: The recent discovery of metals-impacted soil on the bank of the Mill River behind the Cutlery and Firehouse buildings indicates that AOC-1 extends further to the west than previously thought. This means that simply paving the parking lot surface will not provide a sufficient barrier to isolate this soil. AOC-2: Phytoremediation does not appear to be a promising solution for this area of the Site. AOC-3: Removal of much of the material trapped by the dry-laid stone retaining wall will require partial dismantling of the wall, at least on a temporary basis, in order to remove the material. Alternate Remediation Plan: AOC-3: The metals-impacted soil will be excavated from atop the levee and from the river side of the levee, and stabilized and stockpiled at the base of the hill under Riverside Drive. The stone retaining wall will be lowered in areas where contaminants have gotten down behind the stones. In the central portion of the levee, the interior drainage wetland will be eliminated, and the drainage pipe that feeds it will be extended to discharge directly to the Mill River. In the southern portion of the levee, the stone retaining wall no longer exists in this portion of the Site, and neither does the interior drainage wetland. AOC-2: In the filled portion of the raceway north of the Firehouse property, the metals-impacted soil in the stockpile and in the raceway fill will be stabilized in place. Impacted soil that exists atop the levee and on the river side of the levee will be excavated, stabilized and stockpiled at the base of the hill under Riverside Drive. This new material and the current stockpile material will be reformed into a terrace at the base of the hill below Riverside Drive. AOC-1: West of the Cutlery Building and Firehouse metals-impacted soil along the bank leading down to the Mill River will be stabilized in place and an AUL will be extended from the parking lots down to the river’s edge. In all areas where exceedance of a UCL of any metal are identified, this material will be removed, and consolidated in the stockpile in AOC-2. It will then be stabilized with the stockpile and treated as noted above. West of the Cutlery Building where the bank is near vertical, metals-impacted soil along the steep bank leading down to the Mill River will be stabilized and formed into a soft constructed wall. Six to eight horizontal feet of the bank will be removed, the large boulders and debris removed, and the remaining soil stabilized. This newly stabilized material will then be returned to the bank inside a roll of tensar net and filter fabric. The wall will be built of a number of “lifts”, each containing a roll of net and filter fabric filled with stabilized soil. The exact height of each lift will be determined by a structural engineer who will sign off on final design drawings. The effect will be to create a wall of stacked soil burritos that are porous such that hydrostatic pressure does not build up behind the wall, and so that plant can grow in, on, and through the netting and fabric. Groundwater that passes through this stabilized soft wall will be filtered by the stabilized soil and combination of fabrics. Building a soft wall in this area will necessitate the removal of all vegetation prior to building the wall. The wall itself will be re-planted with appropriate vegetation as the last step of construction. In areas that are less steep, the surface of the bank will be covered in a marker layer of landscape fabric that is laid down around the existing trees. The bank will then be sprayed with the stabilization treatment such that it can soak into the bank and stabilize the metals in place. The landscape fabric/marker layer will then be covered in a minimum of one foot of cover material and loam, and then planted with materials designed to physically stabilize the bank against future erosion. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 9 Northampton, Massachusetts This alternative solution leaves the contaminants in place at the Site, but in a stabilized form that will not be available to the environment. It will also place most of this material in a location farther from the Mill River (AOC-2 and AOC-3), or use it to protect the river from likely future degradation (AOC-1). To accomplish this goal, most of the large trees along the Mill River will need to be removed so that the metals-impacted soil can be effectively excavated. An interior drainage wetland, under local bylaw jurisdiction only, will cease to exist. The newly created set of terraces down from Riverside Drive to the newly widened Bank terrace will, in the end, be an improved area suitable for use as a public park. MCP IH Evaluation & IRA Closure Report, by NEE, September 2005 NEE identified one area in AOC-1 with silver grey soil similar to impacted soil found along the levee (AOC-3) in earlier sampling. A sample of this light grey silt was collected and found to contain, among several metals exceeding Method 1 standards, 25,000 mg/kg of chromium. This concentration is above the Imminent Hazard concentration of 200 mg/kg, and the Upper Concentration Limit (UCL) of 10,000 mg/kg for chromium (III). Since this surface soil sample was collected in an accessible area of AOC-1, an Imminent Hazard condition existed. This single result prompted additional sampling of the river bank behind the parking lots of the Cutlery and Firehouse buildings. Sample results indicated that 10 of the 12 soil samples collected exceed Method 1 standards for at least one metal, 9 of these exceed the IH concentration for chromium. There were no additional exceedances of UCL concentrations beyond the initial sample in this area. It is the expanded lateral extent of these soils that is of concern, and the presence of soil exceeding IH concentrations in a non-fenced area (AOC-1) that is the subject of this report. The DEP was notified of the IH condition on July 28, 2005 and an Immediate Response Action (IRA) was initiated. The bank down to the Mill River behind the Cutlery parking lot has been posted with “No Trespassing” signs, and several areas of orange construction fencing have been installed to deter entrance to this area. These IRA mitigating measures were completed on July 29, 2005. At a site visit on August 12, 2005, Mr. Ben Fish of the DEP agreed that the sign posting and fences were adequate mitigation measures for the steep bank. This river bank has been added to the areas of concern at the Site, expanding the total area of the Site. With the area “closed”, the Imminent Hazard has been alleviated, and the IRA can be closed. REVISED Remedy Implementation Plan, by NEE, May 2006 AOC-1: In all areas where exceedance of a UCL of any metal are identified, this material will be removed, and consolidated in the stockpile in AOC-2. It will then be treated with the stockpiled soil when that occurs in the future. West of the Cutlery Building and Firehouse, the remaining metals-impacted soil along the bank leading down to the Mill River will be physically stabilized in place and an AUL will be extended from the parking lots down to the river’s edge. A chain-link fence will be erected along the west side of the parking lots in AOC-1 to restrict access to the bank. The surface of the bank will be stripped of small brush and vegetation, and then covered in a marker layer of bright orange, plastic, construction-type fencing that is laid down around the existing trees. The marker layer will then be covered with four to six inches of cover material and loam, then covered with erosion control landscape fabric, and planted with materials designed to physically stabilize the bank against future erosion. A coconut bio-log will be installed at the toe of the slope within AOC-1 to anchor the fabric layers and reduce possible erosion by the Mill River of the lower portions of the new installations. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 10 Northampton, Massachusetts West of the Cutlery Building where the bank is near-vertical, it is unrealistic to assume that even four to six inches of soil will stay on the bank. Some areas of this bank are boulders, and these do not need to be covered with soil and planted. In the remaining areas, soil will be placed between the large rocks and covered with an erosion-control fabric to help hold it in place prior to being planted with materials designed to physically stabilize the bank against future erosion. At the base of established trees, the soil layer will be reduced to nothing so that the trees’ root systems and trunks are not suffocated. This alternative solution leaves most of the contaminants in place at the Site, but in a stabilized form that will not be available to the environment. It will also place the worst of this material in a location farther from the Mill River (stockpile within AOC-2), or use it to protect the river from likely future degradation (AOC-1). Under this alternative solution, the entire site will be subject to an Activity and Use Limitation (AUL; 310 CMR 40.1074). This will include the land area under the former raceway west to the edge of the Mill River, and from the mouth of the raceway south to the tail race. IRA Plan, by NEE, June 2006 Prior to initiating Phase IV remedial actions at the Site on the bank behind the Cutlery Building, it was necessary to amend the existing Notice of Intent (NOI) to include this portion of the river bank within the project work area. Initial discussions with the Northampton Conservation Commission indicated their agreement that cleaning up the bank of the Mill River was an appropriate course of action. Follow-up discussions indicated a resistance to approve the NOI since the scope of work involved adding additional contaminated soil to a soil stockpile that had been at the Site longer than 120 days. In addition, the City desired confirmation of the remediation plan from an MCP perspective. In an effort to work with the City, the Cutlery has found an off-site disposal facility that can accept this excavated soil from CB-1, and has opted to conduct the work under the IRA provisions of the MCP. In the Fall of 2004, the worst of the identified impacted soil within AOC-1 was excavated and either stabilized and consolidated, or simply consolidated in a stockpile, within AOC-2. Approximately 400 yds3 of soil from AOC-1 were stockpiled within AOC-2. Confirmatory soil sampling results from the excavation areas identified in the Phase IV RIP indicate that the objectives of this excavation were met; the areas are substantially cleaner than before the excavations. The soil in SA-3 that contained leachable lead was stabilized in place so that the lead would no longer leach. Confirmatory soil sampling indicates that the metals stabilization was successful. Now that excavation activities within the parking lots for the Cutlery Building and the Firehouse have achieved the remedial goals in these areas, the parking lots have been paved. The addition of a sediment trap within the tail race to improve stormwater quality is also complete. In the Summer of 2005, metals-impacted soil was discovered on the bank of the Mill River behind the Cutlery and Firehouse buildings, west of the parking lots, indicating that AOC-1 extends further to the west than previously thought. This means that simply paving the parking lot surface will not provide a sufficient barrier to isolate this soil. The concentrations of chromium exceed Imminent Hazard (1,000 mg/kg) levels in 9 of the 15 samples collected in this area, and one of these (CB-1 at 25,000 mg/kg) exceeds the UCL for chromium (10,000mg/kg). The bank of the Mill River in this location is entirely composed of fill material including a large number of boulders and concrete slabs, and is currently held in place, in part, by the roots of many mature trees. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 11 Northampton, Massachusetts The DEP was notified of the CB-1 Imminent Hazard (IH) condition on July 28, 2005 and an Immediate Response Action (IRA) was initiated. NEE proposed the installation of “No Trespassing” signs as an appropriate mitigating measure under the IRA triggered by the IH condition. Mr. John Bourcier of the DEP agreed that sign posting was an appropriate measure, and the signs were installed the following day, July 29, 2005. In addition to the signs, NEE also installed several short lengths of orange construction fencing in the more accessible areas of the top portion of the bank as an additional deterrent. At a follow-up site visit on August 12, 2005, Mr. Ben Fish of the DEP agreed that the sign posting and fences were adequate mitigation measures for the steep bank. The IRA was closed on September 9, 2005. No other IRA activities have occurred for this condition. Alternative to RIP AOC-1: In all areas where exceedance of a UCL of any metal are identified, this material will be removed, and transported to the Turnkey Landfill in Rochester, NH. West of the Cutlery Building and Firehouse, the remaining metals-impacted soil along the bank leading down to the Mill River will be physically stabilized in place and an AUL will be extended from the parking lots down to the river’s edge. A chain-link fence will be erected along the west side of the parking lots in AOC-1 to restrict access to the bank. The surface of the bank will be stripped of small brush and vegetation, and then covered in a marker layer of bright orange, plastic, construction-type fencing that is laid down around the existing trees. The marker layer will then be covered with four to six inches of cover material and loam, then covered with erosion control landscape fabric, and planted with materials designed to physically stabilize the bank against future erosion. A coconut bio-log will be installed at the toe of the slope within AOC-1 to anchor the fabric layers and reduce possible erosion by the Mill River of the lower portions of the new installations. West of the Cutlery Building where the bank is near-vertical, it is unrealistic to assume that even four to six inches of soil will stay on the bank. Some areas of this bank are boulders, and these do not need to be covered with soil and planted. In the remaining areas, soil will be placed between the large rocks and covered with an erosion-control fabric to help hold it in place prior to being planted with materials designed to physically stabilize the bank against future erosion. At the base of established trees, the soil layer will be reduced to nothing so that the trees’ root systems and trunks are not suffocated. Excavated UCL soil from AOC-1 will be transported to the Turnkey Landfill in Rochester, NH. Based upon the distribution of sampling locations and laboratory results (CB-1 to CB-15; Table 4), NEE estimates that less than 30 yd3 of soil exceeding UCL concentrations for chromium will require excavation, more likely 5-10 yd3. This alternative solution leaves most of the contaminants in place at the Site, but in a physically stabilized form that will not erode into the river. It will also remove the worst of the contaminants from the bank of the Mill River. Under this alternative solution, the entire site will be subject to an Activity and Use Limitation (AUL; 310 CMR 40.1074). This will include the land area under the former raceway west to the edge of the Mill River, and from the mouth of the raceway south to the tail race. Brownfields Investigation Report, by O’Reilly, Talbot & Okun (OTO), July 2006 Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 12 Northampton, Massachusetts OTO completed this report for the City of Northampton with the stated goals of filling existing gaps in the environmental data set and informing the City of current site conditions. This was conducted as part of the City’s evaluation of portions of the Site for possible future acquisition for recreational purposes, not for any specific MCP requirements. Tasks completed included: 1) Installation of five (5) groundwater monitoring wells spaced along the length of the Site; 2) Analysis of soils from borings to provide information on the vertical extent of impact; 3) Installation of two (2) hand-driven groundwater monitoring points along the river; 4) Riverbank soil and groundwater testing along the length of the parcel, including re-testing of the existing well MW-4; 5) Surface water and sediment testing in the abutting Mill River. Six soil samples were collected from below the limits of visible fill materials. EPH carbon fractions and target PAHs were not detected in these samples. Metals concentrations were below the S-1/GW-3 standards with the exception of nickel, which exceeded the standard in three of the six samples (CR-2, CR-5B) and CR-6). These samples were collected from depths of 10-14 feet b.g., suggesting that nickel may be leaching from raceway fill materials into underlying soil. Groundwater results indicate that no VOCs or EPH constituents were detected in Site groundwater. Metals were detected above GW-3 groundwater standards in samples from two wells (CR-6 and MW-4). Well CR-6 is located approximately 40 feet southeast of well MW-4 and is adjacent to or within raceway fill materials. The concentration of lead in CR-6 (158 ug/L) slightly exceeds the GW-3 standard (100 ug/L). OTO states this result may indicate the possibility of lead migrating from the Site into surface water at a concentration of concern for aquatic life. However, OTO did not detect lead in the surface water samples they collected from the Mill River. At MW-4, OTO noted that there was only a small amount of groundwater in the screened section of the well, and that the water collected had a high visual entrained sediment content. Two samples were submitted to the lab for analysis from this well, a filtered sample and an unfiltered sample. Metals analytical results for the filtered sample from MW-4 indicate no metals above GW-3 standards, while the unfiltered sample contained elevated concentrations of nickel, lead, chromium, silver and zinc. It was noted that the nickel concentration in the unfiltered sample (3,670 ug/L) was similar to earlier NEE March 2003 data from this well (4,180 ug/L). OTO concludes that well MW-4 is not optimally constructed, with very little screen intercepting the water table, and may not produce groundwater samples representative of conditions in this portion of the Site. EPH and target PAHs were not detected in river bank soil samples at concentrations above S-1/GW-3 standards. Nickel was found in each of the ten samples above the S-1/GW-3 standard of 20 mg/kg. Eight of the 10 samples contained chromium above the S-1/GW-1 standard (200 mg/kg). Standards were also exceeded in some samples for antimony, arsenic, cadmium, and/or lead. Seven of the ten samples (RB-1 through RB-7) contained one or more metals above UCLs. OTO concludes that materials with high concentrations of metals are present adjacent to the river and have likely been sloughing into the rover for years. Three surface water samples (OSW-1 through OSW-3) were collected from the Mill River at locations upstream, sidestream, and downstream of the head race fill area. The samples were analyzed for EPH and PP13 metals and results do not indicate a significant impact to surface water from the discharging Site groundwater. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 13 Northampton, Massachusetts EPH hydrocarbon fractions and PCBs were not detected in the 14 sediment samples collected. PAHs were detected in one sample above MADEP Sediment Screening Values (DEP. 2006) opposite the filled section of the raceway. Metals were not detected above the screening levels in any of the 14 sediment samples. The OTO report noted river bank soils were both potentially accessible and subject to erosion and transport into the Mill River. These situations were remedied by streambank stabilization activities, re-building portions of the retaining wall at the base of the levee, and the installation of a fence along the entire length of the Site between public areas (Riverside Drive and the Site parking lots) and the impacted soils (see the following three IRA Status Report summaries: October 2006, April 2007, and October 2007). OTO also noted the presence of the soil stockpile within AOC-2 which did not meet the requirements for remediation waste (MCP 310 CMR 40.0031). The stockpile was re-graded, covered with landscape fabric and loam, and was seeded in order to eliminate erosion (IRA Status Report, NEE October 2006). IRA Plan Amendment & Other Related Activities, by NEE August, 2006 The objective of the original IRA was to excavate soil that exceeds UCL concentrations for chromium within AOC-1 and to dispose of this soil off-site at an approved landfill. This amendment seeks to notify the DEP that under an agreement between the PRP, the City of Northampton Conservation Commission, and the DEP-BWSC-WERO, the soil excavated from AOC-1 under this IRA will now be added to the existing soil stockpile within AOC-2. The stockpile will in turn be lowered slightly, and spread out slightly to remove the high peaks and some of the steep side slopes. The stockpile will then be covered with a geotextile fabric, loam and seed. The plastic will not be replaced on top of this stockpile. Under the agreement, fabric, loam and seed was considered a better long-term cover material than plastic as it would not degrade in the sun and it would prevent contaminated soil from being blown by the wind. Percolation of precipitation was not considered a concern as the concentrations of metals in the soil have been demonstrated not to leach in excess of the EPA land treatment concentrations. With the exception of changing the cover material on the stockpile, these actions are similar to those included in the Revised Phase IV RIP submitted to the Department on September 15, 2005. Additional chain link fence will be added to the road-side of the Site from the southerly chain link fence all the way to the northerly chain link fence; the entire length of AOC-2 and AOC-3. The orange plastic fencing will be moved to the river-side of the soil stockpile, after it has been loamed and seeded. This action will completely encircle the stockpile with fencing. The goal of this IRA Plan remains to remove the most highly contaminated soil from AOC-1 and then to stabilize, control and isolate the remaining concentrations of metals-impacted soil. Once this is complete, an Activity & Use Limitation will be placed on AOC-1, and NEE will file a Class A3 Partial Response Action Outcome (RAO-P) on this portion of the Site (the Cutlery Building and Firehouse lots). The remaining Remediation Waste from AOC-1 that is included in the soil stockpile located in AOC-2 will be managed as noted below and included in the Class C RAO for those portions of the Site. These actions are sufficient to allow partial closure of AOC-1 under 310 CMR 40.0030. Related Activities in AOC-2 & AOC-3 While not specifically included in the IRA, the following actions are also planned for AOC-3: The steep slopes along the levee that are not vegetated and are eroding will be covered with erosion control fabric Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 14 Northampton, Massachusetts and seeded with grass. The relatively flat top surface of the levee will be seeded and covered with straw. A short (40-50 foot) section of the toe of the slope will receive stone rip-rap to hold down the lower end of the erosion control fabric. This area is directly downstream from the downstream end of the stone retaining wall that exists along most of the toe of the slope along the levee, effectively making the stone retaining wall 40-50 feet longer. This new section of stone wall will be up to two feet high. The goal of lowering the soil stockpile, adding fencing along the entire length of Riverside Drive in AOC-2 & AOC-3, and stabilizing the levee bank from erosion is to get this portion of the Site in a condition where it is as stable, controlled and protected as is feasibly possible at this time in order to qualify for a Class C RAO. This Temporary Solution will allow additional time and research to determine the best long-term approach to remediation of the groundwater and soils, both in place and in the stockpile, in AOC-3. IRA Status Report, by NEE, October 2006 Soil Excavation On September 13, 2006, vegetation along the bank behind the Cutlery and Valley Home Improvement buildings and parking lots was cut and chipped in preparation for the remaining IRA tasks. On September 21, 2006, NEE supervised the excavation of soil exceeding UCL concentrations of chromium. Excavation was conducted by Duffy-Willard of Northampton, MA. Excavated soil was moved and added to the soil stockpile within AOC-2. In total, approximately 28 yds3 of soil were excavated from AOC-1 and added to the stockpile. Soil Sampling and Results Prior to initiating excavation activities on the bank of the Mill River in AOC-1, NEE collected the following soil samples for laboratory analysis: a) A duplicate sample of CB-1 (CB-1-2) was collected by NEE on June 6, 2006 and submitted to Spectrum Analytical of Agawam, MA for laboratory analysis of Full Toxicity Characteristic Leaching Procedure Scan (TCLP-VOCs, TCLP-SVOCs, TCLP-PCBs, TCLP-RCRA 8 metals) to ensure that the material proposed for excavation under this IRA Plan is considered “non- hazardous” under RCRA. Additional characterization analyses included Total and Hexavalent Chromium, flashpoint, pH, and reactivity. Laboratory results indicate that sample CB-1-2 contained 69,900 mg/Kg total chromium, no hexavalent chromium and 0.0523 mg/L chromium under the TCLP extraction. No other analytes were detected in the TCLP extraction. Flashpoint was >200, the pH 6.63, and reactivity was negative. Sample CB-1 contained 25,000 mg/Kg total chromium (Table 1). These analyses indicate that the material is not “hazardous” under RCRA, is the identified material in exceedance of UCL chromium concentrations, and is therefore suitable for addition to the existing soil stockpile within AOC-2 under the terms of this IRA. Copies of the laboratory report are included in Appendix C. b) Four additional surface soil samples were collected by NEE on June 6, 2006 from the bank of the Mill River north of CB-2 on the Firehouse lot for analysis of total metals. One sediment sample was collected from the Bank Full Bench (CB-16-sed), and three soil samples were collected from the embankment below the Valley Home Improvement parking lot (Figure 3). The samples were submitted to Spectrum Analytical of Agawam, MA for laboratory analysis of PP13 total metals to indicate if the work area needed to extend all the way to the north Firehouse property line Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 15 Northampton, Massachusetts (current location of the chain link fence). Currently the northern-most sample (CB-2) did not indicate a “clean margin” on the sampling area. Laboratory results indicate that sample CB-16-sed exceeds the TEC Benchmark values for copper, mercury, nickel, and lead, but does not exceed Method 1 standards for any of the PP13 metals (Table 1). Samples CB-17 and CB-18 each contain chromium above the imminent hazard concentration and below the UCL, and lead above the Method 1 standard. Sample CB-19 collected from the edge of the parking lot did not exceed a listed standard for any of the PP13 metals. These results are similar in nature to the other samples collected on this portion of the bank (except CB-1/CB-1-2), and indicate that the work area should extend all the way to the north Firehouse property line (current location of the chain link fence). Copies of the laboratory report are included in Appendix C. c) After soil excavation on September 21, 2006, NEE collected eight confirmatory soil samples from the excavation area, and one duplicate sample (of CB-CS-5). The samples were submitted to Spectrum Analytical for laboratory analysis of PP13 total metals. Laboratory results indicate that all samples contain concentrations of chromium below the UCL value (10,000 mg/Kg), confirming that the IRA excavation was successful. Laboratory results are summarized in Table 1 and indicate that 7 of the 9 confirmatory samples collected still contain chromium above the Method 1 (1,000 mg/kg) and Imminent Hazard (1,000 mg/kg) concentrations, but significantly below the UCL value of 10,000 mg/kg. These results represent an order of magnitude or greater decrease in the total chromium concentrations along the bank of the Mill River from the initial CB-1 (25,000 mg/kg) and CB-1-2 (69,900 mg/kg) concentrations. Copies of the laboratory report are included in Appendix C. Soil Stockpile The excavated soil from AOC-1 was added to the soil stockpile within AOC-2 and this pile was re-graded to achieve a lower profile on the pile and change its cover material. The plastic cover on the stockpile was removed, and the pile re-graded to cover most of the east-west cross-section of the filled portion of the raceway near the original stockpile. The IRA Plan called for adding length to the stockpile as a means of reducing its height and then covering it with loam and seed. This proved to be highly impractical in the field as moving this volume of soil laterally along the pile was not possible without increasing the pile width. However, increasing the pile width eliminated the truck access along the western side of the stockpile. In the end, the pile was made almost twice as wide, compacted, and covered in geotextile fabric, loam, and seeded. Truck access to the northern portions of the Site is now over the seeded stockpile. The stockpile total height is between 3-4 feet and ramped to 0 at the north and south ends, its width 45-50 feet, and the total length increased slightly from 180 feet to approximately 230 feet. Two depressions in the stockpile provide access to City of Northampton sewer manholes. This stockpile has been covered in loam and seeded (see photographs). Added Fill Material & Imminent Hazard Evaluation “No Trespassing” signs were posted to mitigate the CB-1 UCL chromium IH situation in July 2005 as noted above. The signs are still present at the Site and NEE also installed several short lengths of orange construction fencing in the more accessible areas of the top portion of the bank as an additional deterrent at that time. The laboratory results from confirmatory soil sample CB-CS-8 indicate the presence of arsenic (76.6 mg/Kg) above the Imminent Hazard concentration of 40 mg/Kg. To alleviate this situation, a foot of Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 16 Northampton, Massachusetts clean fill material was imported to this portion of the Site and placed on the top of the bank near the edge of the parking lot on top of this sampling location. The area was then covered with wood chips from the clearing operations. An Imminent Hazard situation no longer exists at this location for arsenic. Confirmatory soil sample results do indicate the presence of chromium in excess of the Imminent Hazard concentration of 1,000 mg/Kg. Since it has been demonstrated that Chromium IV does not exist at the Site, and a similar situation has existed along this bank since the initial CB soil sampling, and since the posting of signs has been deemed sufficient protection of the public at this location in the past, additional signs were added to this area (see Section 2.5 below) for the short term, and this was considered adequate until the chain link fence is installed. No other Site conditions have changed and no other new information has surfaced since the initial IH Evaluation & IRA Plan for the CB-1 UCL soil situation. There is currently no known Imminent Hazard situation at the Site. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 17 Northampton, Massachusetts Retaining Wall Valley Home Improvement built a three-foot high concrete block retaining wall approximately six feet west of the edge of pavement at the northern-most portion of their parking lot. This wall was added to the plans in order to increase the paved area along this side of the parking lot to ease winter snow plowing and allow a place to pile plowed snow. With the addition of a chain link fence, snow can no longer be plowed over the bank and must remain on the pavement for the winter, or removed altogether. This design modification was approved by the Conservation Commission along with the NOI for the project. Soil that was excavated for the footing of this retaining wall was left on the bank below the wall. No soil was removed from the bank for this portion of the project. Design drawings for this wall are included in Appendix D. Sign Posting Additional “No Trespassing” signs were added to both the street and river sides of the Site. There are now six “Posted, No Trespassing” signs along the edge of pavement of the Cutlery and Valley Home Improvement parking lots, a total of 11 similar signs on the edge of Riverside Drive along AOC-2 and AOC-3, and three “Posted, No Trespassing” signs along the bottom edge of the levee facing the Mill River in AOC-3, with a final sign at the base of the CB-1 excavation facing the River in AOC-1. In all, 12 new signs were added to the Site in September 2006. IRA Status Report, by NEE, April 2007 Soil Excavation No soil excavation activities have occurred in the period from October 20, 2006 through April 20, 2007. Sign Posting Additional “No Trespassing” signs were added to both the street and river sides of the Site. There are now six “Posted, No Trespassing” signs along the edge of pavement of the Cutlery and Valley Home Improvement parking lots, a total of 11 similar signs on the edge of Riverside Drive along AOC-2 and AOC-3, and three “Posted, No Trespassing” signs along the bottom edge of the levee facing the Mill River in AOC-3, with a final sign at the base of the CB-1 excavation facing the River in AOC-1. In all, 12 new signs were added to the Site in September 2006. Update on the Status of Bank Stabilization, NEE, June 2007 Orange plastic fencing has now been installed as a marker layer on the bank surface to identify the former ground surface west of the parking lots in ACO-1. Spring flooding of the Mill River this Spring caused considerable erosion of the toe of the slope in AOC-1 and over-topped the silt fence, flattening it in many places. A flexible filter soc filled with seeded mulch was installed along the toe of the slope in this area of the Site as a replacement for the silt fence. Seeded mulch (EcoBlanketTM, see attached product specification sheets) was then sprayed in a layer 2-4 inches thick on the slope on top of the orange plastic fencing in AOC-1. Straw mat was stapled to the top surface of the bank, on top of the EcoBlanketTM, in some of the steeper portions of the slope to further protect the slope from erosion. The attached photographs show various stages of this installation and the finished installation with sprouted seed. It is anticipated that some areas will require touch up before the summer is over, and this work is scheduled for August. The bank stabilization plan also called for planting of dormant willow stakes which is scheduled for November 2007. Small areas at the edge of the existing parking lots and the land within the Valley Home Improvement storage fence still require paving. The necessary prep work for the paving was just completed with the bank stabilization and the paving is scheduled for this summer. Once the paving is complete, the chain Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 18 Northampton, Massachusetts link fence will be installed at the edge of the pavement and AOC-1 of the Site will be ready for an AUL and Class A-3 RAO-P. We anticipate that the bank stabilization NOI Certificate of Completion can be achieved once the willow stakes are installed, and that the IRA Completion Report can be prepared shortly thereafter. The AUL/RAO-P can then be finalized and submitted. We anticipate this will occur early in 2008. On the issue of the chain link fence, Cutlery Building Associates would greatly prefer to install a four-foot-high fence along the edge of the parking lot immediately behind the buildings, including behind the old firehouse, with “No Trespassing/ Restricted Area” signs. This would be in place of the five-foot fence outlined in the IRA Plan. They believe a higher fence will be unattractive and very adversely impact their property value, and is unnecessary as a means of restricting access by the public. They believe a four-foot fence behind the buildings will be effective to deter people from climbing over the fence due to the proximity and active use of the buildings. A five-foot high chain link fence will still be installed along Riverside Drive as originally planned as this area is more accessible to the public. Primarily this is an issue of aesthetic impact of a five-foot fence, and the ability to rent space within the Cutlery Building. The fence will be very close to the buildings and the five-foot height will have a much more negative impact on the buildings than a four-foot height without any real additional protection of the public. They want to make this minor change to the IRA plans, along the parking lot only, but need assurance from the Department that such a fence will be accepted when this RTN/RAO-P is audited in the future. We would appreciate the Department’s written response to this request. Erosion had occurred in the sand under the new concrete wall of the sediment trap within the tailrace. The hole under the wall and the floor of the sediment trap were filled with a layer of pea-stone in early June to combat this erosion, and this solution appears to be holding up. The soil stockpile in AOC-2 has an ample crop of grass and no erosion is apparent on the sides of the stockpile. This stockpile is solid as evidenced by the lack of evident compaction or erosion when the levee area was accessed for bank stabilization work (see below). The inevitable tire tracks across the top of the stockpile were seeded with the same EcoBlanketTM mulch material once the levee work was complete, and we anticipate this will look as good as the rest of the stockpile within several weeks. The proposed stone retaining wall at the toe of the slope of the levee in AOC-3 is installed. An eroded, undercut area just above/behind this wall was filled with pea-stone to physically stabilize the bank and return the bank profile to its former slope. The entire levee bank was coated in a 2-4” layer of EcoBlanketTM, as was the top surface of the levee. The steepest sections of the levee bank were then covered with straw mat that was stapled to the ground surface in an effort to further combat erosion on the levee bank. The silt fence along the toe of the levee bank was left in place. Photographs of this area of the Site are also attached. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 19 Northampton, Massachusetts IRA Status Report, by NEE, October 2007 Soil Excavation No soil excavation activities have occurred in the period from April 20, 2007 through October 3, 2006. Sign Posting Additional “No Trespassing” signs were added to both the street and river sides of the Site in September 2006. There are now 18 “Posted, No Trespassing” signs around the Site: six along the edge of pavement of the Cutlery and Valley Home Improvement parking lots, a total of 11 similar signs on the edge of Riverside Drive along AOC-2 and AOC-3, and three “Posted, No Trespassing” signs along the bottom edge of the levee facing the Mill River in AOC-3, with a final sign at the base of the CB-1 excavation facing the River in AOC-1. Mill River Bank Stabilization in AOC-1 The remaining metals-impacted soil along the bank leading down to the Mill River in AOC-1 were physically stabilized in place. Orange plastic fencing has now been installed as a marker layer on the bank surface to identify the former ground surface west of the parking lots in ACO-1. Spring flooding of the Mill River this Spring caused considerable erosion of the toe of the slope in AOC-1 and over-topped the silt fence, flattening it in many places. A flexible filter soc filled with seeded mulch was installed along the toe of the slope in this area of the Site as a replacement for the silt fence. Seeded mulch (EcoBlanketTM) was then sprayed in a layer 2-4 inches thick on the slope on top of the orange plastic fencing in AOC-1. Straw mat was stapled to the top surface of the bank, on top of the EcoBlanketTM, in some of the steeper portions of the slope to further protect the slope from erosion. The attached photographs show various stages of this installation and the finished installation with sprouted seed. It is anticipated that some areas will require touch up this Fall, and this work is scheduled for October. The bank stabilization plan also called for planting of dormant willow stakes which is scheduled for November 2007. Mill River Bank Stabilization in AOC-2 and AOC-3 The proposed stone retaining wall at the toe of the slope of the levee in AOC-3 was installed. An eroded, undercut area just above/behind this wall was filled with pea-stone to physically stabilize the bank and return the bank profile to its former slope. The entire levee bank was coated in a 2-4” layer of EcoBlanketTM, as was the top surface of the levee. The steepest sections of the levee bank were then covered with straw mat that was stapled to the ground surface in an effort to further combat erosion on the levee bank. The silt fence along the toe of the levee bank was left in place. Photographs of this area of the Site are also attached. The soil stockpile in AOC-2 has an ample crop of grass and no erosion is apparent on the sides of the stockpile. This stockpile is solid as evidenced by the lack of evident compaction or erosion when the levee area was accessed for bank stabilization work (see below). The inevitable tire tracks across the top of the stockpile were seeded with the same EcoBlanketTM mulch material once the levee work was complete, and this area recovered and looked as good as the rest of the stockpile within several weeks. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 20 Northampton, Massachusetts IRA Closure Report, by NEE, November 2007 Soil Excavation in AOC-1 In all areas where exceedance of a UCL of any metal was identified, this material was moved to the existing soil stockpile within AOC-2. The soil was excavated and moved by Duffy & Willard of Northampton, MA under the supervision of an NEE LSP on September 21, 2006. NEE estimates that 25 yd3 of soil exceeding UCL concentrations for chromium was excavated and moved to the soil stockpile. Confirmatory soil samples were collected at the end of excavation activities and the results indicated that the UCL contaminated soil had been removed from this location. These laboratory results were submitted with the October 20, 2006 IRA Status Report (see Table 1). Mill River Bank Stabilization in AOC-1 West of the Cutlery Building and Firehouse, the remaining metals-impacted soil along the bank leading down to the Mill River was physically stabilized in place. The surface of the bank was stripped of small brush and vegetation, and then covered in a marker layer of bright orange, plastic, construction-type fencing that was laid down around the existing trees and large boulders. The marker layer was then covered with four to six inches of blown-in compost mulch and seed. In steep areas, this was then covered with erosion control landscape fabric. West of the Cutlery Building where the bank is near-vertical, it was unrealistic to assume that even four to six inches of soil would stay on the bank. Some areas of this bank are boulders, and these did not need to be covered with soil and planted. In the remaining areas, soil was placed between the large rocks and covered with an erosion-control fabric to help hold it in place prior to being planted. At the base of established trees, the soil layer was reduced to nothing so that the trees’ root systems and trunks were not suffocated. The bank was then planted with willow stakes to physically stabilize the bank against future erosion. A blown-compost bio-log was installed at the toe of the slope within AOC-1 to anchor the fabric layers and reduce possible erosion of the lower portions of the new installations by the Mill River. Photos of the installation sequence and completed bank treatment are attached. Fence Installation A chain-link fence was erected along the west side of the parking lots in AOC-1 to restrict access to the river bank. Cutlery Building Associates requested permission from the DEP to install a four-foot high fence along the edge of the parking lot immediately behind the buildings, including behind the old firehouse, with “No Trespassing/ Restricted Area” signs. This was in place of the five-foot fence outlined in the IRA Plan. Cutlery Building Associates believed a higher fence would be unattractive and very adversely impact their property value, and was unnecessary as a means of restricting access by the public. They believed a four-foot fence behind the buildings would be effective to deter people from climbing over the fence due to the proximity and active use of the buildings. A five-foot high chain link fence was installed along Riverside Drive (AOC-2 and AOC-3) as originally planned as this area is more remote. The DEP responded favorably to this request, issuing an approval letter dated July 19, 2007 (Appendix A). Photos of the four-foot high and five-foot high fences are attached. Soil Stockpile in AOC-2 On September 21, 2006, the plastic that formerly covered the stockpile was removed, and the stockpile was re-graded to be wider and shorter. The length of the stockpile increased only slightly from 180 to 230 feet and the entire newly graded stockpile remained on top of the filled raceway within AOC-2. The stockpile was then covered in geo-textile fabric, several inches of loam, and was seeded and hayed. The fabric, loam and seed was considered a better long-term cover material than plastic as it would not degrade in the sun and it would prevent contaminated soil from being blown by the wind. Percolation of precipitation was not considered a concern as the concentrations of metals in the soil have been Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 21 Northampton, Massachusetts demonstrated not to leach in excess of the EPA land treatment concentrations. Due to the width of the stockpile, access to the northern portions of the Site (AOC-3) is now accomplished by traversing the length of the top of the stockpile. This includes authorized pedestrian and vehicular traffic. Photos of the completed stockpile installation are attached. A depression in the stockpile near the center and another near the north end provide access to City of Northampton sewer manholes. Sign Posting Additional five-foot high chain link fence was added to the road-side of the Site from the southerly chain link fence all the way to the northerly chain-link fence; the entire length of AOC-2 and AOC-3. Additional “No Trespassing” signs were attached to trees along both Riverside Drive and the shore line of the Mill River. These actions completely encircled the stockpile with signs and on three sides with chain-link fence. This IRA was initiated to abate an Imminent Hazard associated with chromium in soil in excess of UCL concentrations in AOC-1. This UCL soil has been moved to the soil stockpile in AOC-2, the stockpile has been covered with geo-textile fabric, loam and seed, and the stockpile has been fenced on three sides. The riverbank where the soil was excavated has been shown to no longer contain UCL concentrations of chromium (Table 1). The remaining soil on the riverbank is known to contain residual concentrations of chromium and other metals in excess of Method 1 clean-up criteria. These impacted soils have been isolated under an orange plastic fencing marker layer and behind a chain link fence. The riverbank was then physically stabilized using compost mulch, seed, erosion control fabric, and willow stakes. The non-paved areas of AOC-1 (the riverbank) have been further isolated with the installation of a four-foot-high chain link fence. This fence connects the existing chain link fence around the tailrace with the existing chain link fence on the north side of the paved parking area at the firehouse lot. This fence runs along the edge of the paved surface, separating the unpaved riverbank from the paved areas accessible to the general public. Since the UCL soil no longer exists in this area and the residual concentrations of metals are isolated, the Imminent Hazard situation no longer exists, and the IRA can be closed. The goal of this IRA was to remove the most highly contaminated soil from AOC-1 and then to stabilize, control and isolate the remaining concentrations of metals-impacted soil. Now that this is complete, an Activity & Use Limitation will be placed on AOC-1, and NEE anticipates filing a Class A3 Partial Response Action Outcome (RAO-P) on this portion of the Site (the Cutlery Building and Firehouse lots). The remaining Remediation Waste from AOC-1 that is included in the soil stockpile located in AOC-2 will be included in and managed under the Class C RAO for those portions of the Site. These actions are sufficient to allow partial closure of AOC-1 under 310 CMR 40.0030. Cutlery Raceway Slope Stabilization, Wetland Restoration Monitoring Report, by NEE to Northampton Conservation Commission, November 16 2010. New England Environmental, Inc. (NEE) was hired by Alan Verson (the applicant) to assess the bank stabilization work at 320-360 Riverside Drive in Northampton and assess vegetational cover as required by the Order of Conditions. This work was originally completed in 2007 by Northeast Environmental Solutions (NES) under a “revised remediation plan” submitted to the Commission in a letter dated May 29, 2007. A site visit to complete this assessment was done on November 11, 2010. An NEE wetland Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 22 Northampton, Massachusetts scientist had previously visited the site on July 28, 2010. Both of these site visits were conducted by Karro Frost, PWS. To describe the vegetation on the site, the work areas will be described individually below. These sections include (1) the northern section of the levee with the retaining walls between the raceway and the Mill River; (2) the soil stockpile area on the levee which has been loamed and seeded; (3) original slope stabilization work completed adjacent to the former firehouse and cutlery building and their associated parking area; and (4) 2010 repair work completed in two sections within (3). The primary wetland resource area impacted by the work is the 200-foot Riverfront Area associated with the Mill River. Most of the work also occurred within the 100-foot buffer zone to bank. Northern Section of the Levee and Stabilized Bank Material was removed from this area under the 2004 Order of Conditions, and portions of the stone walls were rebuilt. Photos 1 through 4 (Attachment A) illustrate this area during the July and November site visits. The work went around pre-existing trees without damaging them. This area is well vegetated with an unidentified grass and scattered clover and tree seedlings. Only a few of the willow stakes survived and have grown. The percent cover is 85% in November, 2010. This area meets the criteria in the Order of Conditions for 85% vegetative cover. There is a silt fence at the toe of the slope which should be removed. Soil Stockpile Area The soil stockpile was created under the 2004 Order of Conditions, and then regraded, and stabilized in place under an IRA Amendment dated August 2006. The IRA Amendment was the result of a joint agreement between the Applicant, the City of Northampton Conservation Commission, and the DEP-BWSC-WERO. Under the IRA Amendment, the stockpile was covered with orange fencing as a marker, then covered with loam and seeded. This area now is completely vegetated, with no open areas and a percent cover of 100%. The dominant vegetation includes New England Aster (Symphyotrichum novae-angliae), wild rye (Elymus spp.) and deertongue (Dichanthelium clandestinum). Photos 5 and 6 in Attachment A illustrate this area on July 28 and November 11, respectively. A variety of other plants were also observed in this area including Queen Anne’s lace (Daucus carota), raspberry and blackberry (Rubus spp.), fall panic grass (Panicum dichotomiflorum), wavy-leaved aster (Symphyotrichum undulatum), tall goldenrod (Solidago altissima), burdock (Arctium sp.), red oak seedlings (Quercus rubra), bird cherry seedlings (Prunus pensylvanica), and sugar maple seedlings (Acer saccharum). A few exotic species pre-existing on the site have also started to colonize this area, including autumn olive (Elaeagnus umbellatus), Japanese knotweed (Polygonum cuspidatum) and multiflora rose (Rosa multiflora). Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 23 Northampton, Massachusetts This area meets the criteria in the Order of Conditions for 85% vegetative cover. Stabilized Slope Adjacent to Cutlery and Old Firehouse This area was stabilized under the 2004 Order of Conditions and the 2007 “revised remediation plan.” Work was done around pre-existing trees. This area includes very steep slopes. The canopy cover in this area is very dense and there is little light reaching the forest floor, preventing much growth in the herbaceous layer. This area has approximately 15% herbaceous cover, but 95% canopy cover. Portions of this area have slopes over 3:1, and the orange fencing is visible in sections on the slope. In addition, this area was minimally disturbed, with the primary activity covering the soil with orange fencing, which was then loamed and seeded. This area does not have any signs of erosion. Although the area does not meet the 85% herbaceous vegetation cover, it has 95% canopy cover. The area was minimally disturbed and shows no signs of erosion after three years. Smaller 2010 Repair Area - Upstream Immediately downstream of the above area is a small area of repair that was completed in spring, 2010. Unlike the above areas, this area was becoming undercut and was eroding. The total length of this repair is 30 linear feet. Repairs consisted of creating geo-lifts at the toe of the slope with brush layered between them, and soil covering the slope, seeded and covered with an erosion control blanket staked into place. Photos 8 through 10 in Attachment A illustrate this area. The vegetative cover of this area is approximately 20%. The vegetation is growing well and there is no further sign of erosion. Larger 2010 Repair Area – Downstream A second and larger area of bank repair was completed downstream and near the Cutlery Building. This area also was becoming undercut and the repairs were similar to the above. This area is 130 feet in length, and consists of biologs and geo-lifts at the toe of the slope with brush layering, and loam and seed were placed on the upper slope, which was then covered with an erosion control blanket. The grass has started Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 24 Northampton, Massachusetts to grow on the slope. Photos 11 and 12 illustrate this area. The herbaceous cover is approximately 50% and there has been no additional erosion. Canopy percent cover is 80%, with a total percent cover of approximately 90%. Summary Most of the site is well-vegetated, and the overall percent cover is 85% including the both canopy and herbaceous layers. The herbaceous layers in the 2010 repaired areas have not yet grown in to the density desired, however, they are expected to continue to expand and grow. The site was stable during both the July and November site visits conducted to assess the vegetation. An Activity & Use Limitation (AUL) will be placed on all of the areas described above as part of Site closure with DEP-BWSC. In part, the AUL will require the orange marker layers to be covered with loam and vegetation, the parking lot asphalt to remain in good condition, that any areas experiencing erosion be repaired in a manner to prevent future erosion, and that the fences and signs remain in good condition. The AUL will also require an Annual AUL Inspection Report be provided to DEP-BWSC. NEE suggests that the Conservation Commission also receives copies of these reports on an annual basis. If any areas have signs of erosion, these areas must be stabilized, which will include a new filing with the Conservation Commission. This is the end of the Appendix C review of prior investigations. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 25 Northampton, Massachusetts ClassA3 RAO-P & ClassC1 RAO-P Statements, by NEE, February 2011 The extent of the disposal of industrial waste materials, demolition debris, and common refuse in an unregulated landfill within and along the former raceway leading to the Cutlery Building was identified. Soil that exceeded the UCL in AOC-1 was excavated and moved to the stockpile in AOC-2. For the Area AOC-1, a Permanent Solution was achieved, the level of OHM in the environment was not reduced to background and an Activity and Use Limitation was implemented. The EPCs for identified OHM material at the disposal Site did not exceed any UCL in soil and groundwater, therefore this portion of the Site was eligible for a Class A3 RAO. For the portion of the Site labeled AOC-2 & AOC-3, a condition of No Substantial Hazard existed, response actions to achieve a permanent solution were not currently feasible, and an Activity and Use Limitation was implemented. This portion of the Site was eligible for a Class C1 RAO. Response to NOAF-NON-WE-11-3A073, by NEE 3/14/2012 New England Environmental, Inc. (NEE) is pleased to provide the following response to the NOAF-NON issued by the Department on November 9, 2011 (Attachment 1). We have addressed each of the eight MCP “Requirements not Complied With”, and provided new and/or revised information for each of the three “Actions to be Taken”, as listed in the NON. These items are as follows: MCP “Requirements not Complied With” (Partial relevant text in bold, responses follow): 1. 310 CMR 40.0995(3)(a).1.c Exposures of site biota and habitats must be characterized by a Stage I Environmental Screening. A Stage I Environmental Screening has been included in the revised Method 3 Risk Characterization (OTO, 3/2012). Exposure of site biota and habitats to the contaminants of concern (COC) are considered in this screening evaluation. 2. 310 CMR 40.0995(3)(c).1.b The Department has determined that a potentially significant exposure posed by sediment does exist at the site, which … must be evaluated by a Stage I Environmental Screening.. A Stage I Environmental Screening has been included in the revised Method 3 Risk Characterization (OTO, 3/2012). Exposure to the COCs remaining in site sediment are considered in this screening evaluation. 3. 310 CMR 40.0902(3) The Department has determined that all three EPH fractions detected in soil at the site are considered to be contaminants of concern which must be included in the quantitative evaluation of site risk. A revised Method 3 Risk Characterization (OTO, 3/2012) has been provided which evaluates EPH carbon fractions as contaminants of concern (COC) at the Site. 4. 310 CMR 40.1056(2)(k) - All documentation necessary to support the RAO must be submitted to the Department, including, for all Class A, B, or C RAOs, a Data Usability Assessment documenting that the data relied upon is scientifically valid and defensible, and of a sufficient level of precision, accuracy, and completeness to support the RAO. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 26 Northampton, Massachusetts The Department is in general concurrence that the data are usable in support of the RAO Report conclusions. However, because the highest non-cancer risk Hazard Index value obtained for the construction worker exposure pathway (0.8, segregated by critical effect) approached the Method 3 Risk Characterization criteria of I, the low bias and variability seen in a number of quality control samples associated with metals data obtained at AOC-I (the "SA" excavations data in particular), further evaluation is needed to determine how they affect the risk characterization determination of No Significant Risk. The requested further evaluation is included in the revised Method 3 Risk Characterization (OTO, 3/2012). 5. 310 CMR 40.0926(1) - For oil and/or hazardous material in each medium at each exposure point, an exposure point concentration (EPC) must be identified and documented. There was some confusion as to the definition of “sediment” in the early stages of this project, and several “soil” samples were collected from within the floodplain, or the bank full bench, and characterized as “sediment” from the Mill River. These sample results have now been extracted from data Table 5, and segregated into new/revised data tables such that Table 5-1R contains only “soil”, and Table 5-2R contains only “sediment”. They are therefore now easily compared to their respective standards, and have been introduced to evaluation in the revised Method 3 Risk Characterization (OTO, 3/2012) in this segregated manner. This does two things: a) it clears up the prior confusion of soil vs. sediment, and b) it allows evaluation of the floodplain exposures separately in the risk assessment. 6. 310 CMR 40.1012(2)(a)2 - Activity and Use Limitations (AULs) are required at all disposal sites or portions of disposal sites for which an RAO, and the risk characterization used to support the RAO, are based upon the restriction or limitation of site activities and uses to achieve a level of No Significant Risk ... The delineated AUL boundaries at AOC-I do not include the area extending further westward (down slope) to the river's edge; namely, the lower riverbank and floodplain soil area. With the segregation of “soil” and “sediment” samples from Table 5 into Table 5-1R and Table 5-2R, the risk assessment is now able to evaluate exposure within the floodplain as requested. Such an evaluation is included in the revised Method 3 Risk Characterization (OTO, 3/2012), along with all the other exposure points. 7. 310 CMR 40.0897(1)(b) - The provisions of 31 0 CMR 40.0897 shall apply to any disposal site where the operation, maintenance or monitoring of the selected remedial alternative is necessary to ensure that the conditions upon which the Class C RAO is based are maintained, and/or that further progress towards a Class A Response Action Outcome is made. Although AULs were implemented at Areas of Concern AOC-2 and AOC-3, subject to the partial Class C-I RAO Statement submitted to the Department, which include obligations and conditions necessary to maintain the integrity of the site's erosion controls, no plan was provided in the RAO Report which specifies how these obligations and conditions will be conducted. An Operation & Maintenance Plan has been prepared for the Site and is included in Attachment 2. While a formal O&M Plan was not previously written, the activities listed in the O&M Plan have been conducted by NEE since Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 27 Northampton, Massachusetts the RAO Statement was submitted in February 2011 (revised RAO Statement, Section 2.4). NEE is under contract with the PRP to provide these services on an on-going basis. 8. 310 CMR 40.1074(2)(c) – If the person signing the Notice of AUL is not an individual signing on his/her own behalf, but rather on behalf of an entity (LLC, LLP, limited partnership, etc.) or as trustee, executor, or attorney in fact, documentation of the person's signatory authority must be attached as an exhibit to the Notice of AUL. The appropriate documentation establishing the authority of the person signing the AUL was not attached as an exhibit to the Notice of AUL for AUL Area I, owned by Firehouse Realty Corporation. A Certificate of Vote noting “That the Notice of Activity And Use Limitation dated February II , 2011, recorded in the Hampshire Registry of Deeds at Book 10475 Page 118 and executed by Nelson Shifflett is hereby ratified and confirmed and adopted for all purposes as an official act of the Company” was adopted by written vote of the directors of Firehouse Realty Corp. on 2/20/2012. A notarized copy of this Certificate of Vote was recorded at the Hampshire County Registry of Deeds on 3/6/2012 (Book 10833 Page 81; copy included in Attachment 3). ACTION(S) TO BE TAKEN AND DEADLINE(S) FOR TAKING SUCH ACTION(S): (Relevant text in bold, responses follow): 1. Submit a revised risk characterization, including a Stage I Environmental Screening, and revised Class C-I and A-3 RAO Statements that meet the requirements of the MCP specified above, or an RAO retraction(s) and a Tier II Extension Submittal in accordance with 310 CMR 40.0560(7). A revised Method 3 Risk Characterization, including a Stage I Environmental Screening, and revised Class C-I and A-3 RAO Statement has been submitted via eDEP. 2. File separate Amendment to Notice of Activity and Use Limitation (Form 1082B) instruments for AUL Areas I and 2, in accordance 310 CMR 40.1081(4), including the appropriate documentation of signatory authority attached as exhibits to each AUL. A Certificate of Vote noting “That the Notice of Activity And Use Limitation dated February II , 2011, recorded in the Hampshire Registry of Deeds at Book 10475 Page 118 and executed by Nelson Shifflett is hereby ratified and confirmed and adopted for all purposes as an official act of the Company” was adopted by written vote of the directors of Firehouse Realty Corp. on 2/20/2012. A notarized copy of this Certificate of Vote was recorded at the Hampshire County Registry of Deeds on 3/6/2012 (Book 10833 Page 81; copy included in Attachment 3). 3. Complete the actions specified above and submit a Post-Audit Completion Statement in accordance with 310 CMR 40.1170, on the form established by the Department (BWSC-lll), within 120 days of the date of this Notice. With the addition of one additional week requested in our letter of March 8, 2012 (Attachment 4), this has been accomplished. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 28 Northampton, Massachusetts MassDEP accepted most of the above information. They maintained the need for a full Stage II Environmental Risk Characterization, which the PRP insisted they could not afford. MassDEP also requested additional AULs to cover the “land under water” that was adjacent to the AULs placed on the “land” portions of AOC-1, AOC-2, and AOC-3. These additional AULs were implemented in April 2013. Stage I Environmental Screening Floodplain Soil, by AMEC Foster Wheeler 1/2/2017 This Method 3 Stage I Environmental Screening (ES) has been prepared for the Former Cutlery Site (RTN 1-13320) located at 320-360 Riverside Drive, Northampton, MA (Figure 1) following the Massachusetts Contingency Plan (MCP, 30 CMR 40.0000). Soil samples collected from the Mill River floodplain in 2005 and 2006 indicated the presence of metals including arsenic, beryllium, cadmium, chromium, copper, mercury, nickel, lead, and zinc. Since 2006, extensive activities have been performed at the site to remediate source areas and to stabilize the riverbank (consisting of the filled raceway and raceway levee, Figure 2), limiting the presence, bioavailability, and transport of oil and hazardous materials (OHM). In November 2016, floodplain soil was again sampled to characterize current site conditions. This Stage I ES screens chemicals detected in floodplain soil against ecological soil screening benchmarks to evaluate 1) whether remedial response activities and efforts to control riverbank erosion conducted since 2006 have been effective in reducing concentrations of site-related compounds in flood plain soil, and 2) whether these reductions have achieved a condition of No Significant Risk. This Stage I ES concludes that a condition of No Significant Risk does not currently exist for floodplain soil. A possible hot spot associated with two rusting, decaying drums partially buried at the southern end of the floodplain (locations FPS-9, Drum-E, and Drum-W) suggests the presence of a source (i.e., the partially buried drums and their contents). This Stage I ES finds that if this source/hot spot were removed, a condition of No Significant Risk would be achieved for floodplain soil. Post-RAO RAM Plan, by OHI Engineering, Inc. June 2017 In May and June 2017, OHI Engineering, Inc. (OHI) conducted additional soil sampling at the Drum Hot Spot at the Former Cutlery in Northampton, MA to better define the planned shallow excavation. Results of soil sampling identified a larger area of metals-impacted soil than was previously anticipated. The release was initially thought to be small enough to qualify as a Limited Soil Excavation, but with the additional laboratory results it is clear that the 20 cubic yard limit for metals-impacted soil will likely be exceeded before this Hot Spot removal is finished. Therefore, it is appropriate to conduct this work under a Release Abatement Measure. The revised estimate is approximately 39 cubic yards of soil to excavate. This work was completed in July 2017 with the excavated metals-impacted soil being added to the stockpile in AOC-2 which was then covered in construction fence, loam and seed, similar to prior additions to the stockpile. Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 29 Northampton, Massachusetts Interim Deadline Completion Report, by OHI Engineering, Inc. October 2017 OHI completed both items requested in MassDEP’s Interim Deadline Letter dated April 14, 2017. MassDEP issued a Notice of Audit Findings and Notice of Noncompliance (NOAF/NON; 11/9/2011) in response to the submittal of Class A-3 and Class C-1 Response Action Outcome (RAO) Statements (2/16/2011) and Activity & Use Limitations (AULs; 2/11/2011) for the Site submitted by New England Environmental, Inc. (NEE) of Amherst, MA. The NOAF/NON required submittal of a revised RAO that included a Stage I Environmental Screening (ES) in the Method 3 Risk Characterization. A Stage I ES was included in the revised Method 3 Risk Characterization prepared by O’Reilly, Talbot & Okun dated March 8, 2012 (2012 RC). Exposure of Site biota and habitats to the Compounds of Concern (COCs) and exposure to the COCs remaining in Site sediment were considered in the 2012 RC. The 2012 RC cleared up prior confusion of the definition of soil versus sediment in several samples, and it allowed separate evaluation of the floodplain exposures. The NON required an Ecological Risk Characterization on the Mill River adjacent to the Site. After numerous submittals and correspondence with MassDEP, on January 6, 2017 OHI submitted two Stage I Environmental Screening reports for the Site, one for sediment and one for floodplain soil:  Stage I Environmental Screening dated October 18, 2016 and prepared by AMEC Foster Wheeler (AFW) of Chelmsford, MA (2016 Stage 1 ES) details August 2016 sediment sampling results within the Mill River at the Site; and,  Stage I Environmental Screening Floodplain Soil dated January 4, 2017 and prepared by AFW (2017 Stage 1 ES) details November 2016 floodplain soil sampling results adjacent to the Mill River at the Site. One outcome of these two reports was a determination that the Drum Hot Spot needed to be excavated. On April 14, 2017, in an Interim Deadline Letter, MassDEP concurred with the revised evaluation approach of potential floodplain soil exposure risk, incorporating post-excavation data from Hot Spot removal, and set an Interim Deadline of July 31, 2017 to receive documentation of successful removal of the drum-area Hot Spot. A Release Abatement Measure Completion Report (OHI, 7/31/17) was submitted documenting successful removal of the drums and the Hot Spot soil. MassDEP also set an Interim Deadline of October 31, 2017 to receive “a revised evaluation of potential environmental risks posed by sediment, which may include additional/replacement data focused on the areas of prior SSV exceedances, and/or documentation of a focused removal of these sediments.” Laboratory results of the May 2017 sediment sampling are summarized in Table 2c along with the 2016 Stage I ES results, and also in Table 2a with the earlier DEP-SED-1 and DEP-SED-2 results from 2000 and 2011. Table 2c indicates consistent similarity between the 2016 composite transect sediment results and the 2017 grab sample results, where none of the recent Review of Prior Investigations RTN #1-13320 Former Cutlery Raceway July 21, 2020 320-360 Riverside Drive OHI Project No. 13-1515 Page 30 Northampton, Massachusetts results exceed the SSVs (MassDEP, 2006). Table 2a shows a marked decrease in metals concentrations from the earlier 2000 and 2011 results to the current 2017 results, particularly for the Nickel values. All of the laboratory results for the collocated May 2017 sediment samples are below the SSVs (MassDEP, 2006). A full copy of the laboratory report is attached. Summary The 2012 RC found that a condition of No Significant Risk exists for Site uplands, terrestrial habitat, and for Mill River surface water. Laboratory results from grab sediment samples collected in 2005-2006 indicate that none of the 14 samples exceeded the SSVs for metals. In 2016, Mill River sediment was again sampled to evaluate whether remedial response activities and efforts to control riverbank erosion conducted since 2012 have been effective in reducing concentrations of Site-related compounds in sediment. The 2016 Stage I ES evaluated aquatic habitat, and screened chemicals detected in Mill River sediment against MassDEP’s freshwater benchmarks (SSVs). None of the eight composite sediment samples exceeded the SSVs for metals. The 2016 Stage I ES concluded that a condition of No Significant Risk continues to exist for sediment. The 2017 sediment samples were collocated with earlier sampling locations where elevated levels of Nickel had been previously detected. All of the laboratory results for the collocated August 2016 and May 2017 sediment samples are below the SSVs. These results support the conclusion that the 2000 and 2011 DEP-SED-1, DEP-SED-2, and DEP-SED-3 results are no longer representative of these areas of the Site. Considering the findings of the 2012 RC, 2016 Stage 1 ES, 2017 Stage 1 ES, 2017 RAM Completion Report, and most-recent 2017 collocation sediment sampling, a condition of No Significant Risk to the environment exists for Mill River surface water, sediment, terrestrial habitat/uplands, and floodplain soils at the Site, thus completing the Environmental Risk Characterization for the Site. This was the last risk characterization submittal for the Site and MassDEP seemed satisfied that their questions had been answered on this subject. LSP Annual AUL Inspection Reports (2011-Present) Annual AUL inspection by an LSP and reports submitted to MassDEP have been conducted and submitted since 2011 when the original RAO-Ps were submitted. Limited repair work to the bank of the Mill River has been an outcome of several of these inspections. APPENDIX B Photographs www.ohiengineering.com Photo Page L1 Photo L1: This is the north end of the stone retaining wall, showing erosion control repair areas R1 & R2-2020. Approximate 100-yr Flood Elevation in cyan. (North to L, South to R; next photo connects/overlaps to R). Photo L2: South of erosion control repair areas R1 & R2-2020 is repair area R3-2020. Approximate 100-yr Flood Elevation in cyan. (North to L, South to R; next photo connects/overlaps to R). www.ohiengineering.com Photo Page L2 Photo L3: South of erosion control repair areas R1 & R2-2020 is repair area R3-2020. Approximate 100-yr Flood Elevation in cyan. (North to L, South to R; next photo connects/overlaps to R). . Photo L4: South of erosion control repair area R3-2020 are repair areas R4 & R5-2020. Approximate 100-yr Flood Elevation in cyan. (North to L, South to R; next photo connects/overlaps to R). www.ohiengineering.com Photo Page L3 Photo L5: South of erosion control repair area R3-2020 are repair areas R4 & R5-2020. Approximate 100-yr Flood Elevation in cyan. (North to L, South to R; next photo connects/overlaps to R). Photo L6: Erosion control repair areas R4 & R5-2020. Approximate 100-yr Flood Elevation in cyan. (North to L, South to R; next photo connects/overlaps to R). www.ohiengineering.com Photo Page L4 Photo L7: This is the southern end of the stone retaining wall. Approximate 100-yr Flood Elevation in cyan. (North to L, South to R; next photo connects/overlaps to R). Photo L8: Area immediately south of the stone retaining wall. Approximate 100-yr Flood Elevation in cyan. (North to L, South to R; next photo connects/overlaps to R). www.ohiengineering.com Photo Page L5 Photo L9: Area immediately below monitoring well MW-4. Approximate 100-yr Flood Elevation in cyan. (North to L, South to R; next photo connects/overlaps to R). Photo L10: South of MW-4 there is a flood plain between the [elevated] filled raceway and the Mill River with the roof lines of the VHI and Cutlery buildings in the background. Approximate 100-yr Flood Elevation in cyan. APPENDIX C Wetland Delineation Report APPENDIX D Select Prior Summary Soil Results Tables Table 2Summary of Laboratory Results - Soil June 2002 (NEE, Phase II & III, October 2003)Former Cutlery Raceway - Phase II EvaluationRTN #1-13320SedimentSapmle ID:Depth (in.)Date CollectedSP14-5'6/26/02SP30-1'6/26/02SP35-6'6/26/02SP42-3'6/26/02DUP-12-3'6/26/02SP45-6'6/26/02SP410-11'6/26/02SP50-1'6/26/02SP52-3'6/26/02SP55-6'6/26/02SP62-3'6/26/02SP67-8'6/26/02SP72'6/26/02SP74'6/26/02SP76'6/26/02SP9A0-1' G6/26/02SP9A0-1' R6/26/02SP9B2' 6/26/02SP9B5' 6/26/02SP105'6/26/02SP142-3'6/26/02SP152-3'6/26/02DUP-2(SP-15)2-3'6/26/01DUP-3(SP-15)2-3'6/26/02SP160-1'6/26/02SPMW414'6/26/02DUP-414'6/26/02Green Brick0'6/26/02Imminent Hazard (mg/kg)Method 1S-1 Soil & GW-2(mg/kg)Method 1S-1 Soil & GW-3(mg/kg)Method 1S-2 Soil & GW-2(mg/kg)Method 1S-2 Soil & GW-3(mg/kg)UCLPolychlorinated Biphenyls (mg/Kg)SP15 SP15PCBs (total)na na na BDL na na na na na na na na na na na na na na na na na250.2na na na0.041na na 10 2 2 2 2Total Metals (mg/kg)AntimonyBDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL na BDL BDL BDL BDL BDL NSL 10 10 40 40300ArsenicBDL12.8BDL30.7 31.9BDL BDL BDL BDL BDL BDL BDL205BDL BDL BDL149BDL BDL BDL BDL BDL na BDL BDL BDL BDL BDL 40 30 30 30 30500BerylliumBDL BDL BDL BDL BDL BDL BDL BDL BDL0.49BDL BDL1.96BDL BDL BDL2.640.54BDL BDL0.492BDL na BDL BDL0.551BDL BDL NSL 0.7 0.7 0.8 0.82000Cadmium0.5 2.47 0.7 4.60 4.99 0.567 0.5BDL BDL0.808BDL BDL1.51BDL BDL0.766 1.89BDL BDL BDL BDL BDL na BDL BDL BDL0.708BDL 60 30 30 80 801000Chromium15.6 17.7 23 39 17.5 20.3 24.6 977 20.9 22.1 36.3 21.3 13 9.43 21.5 22 24 5.18 24.7 22.5 20.616,500na29,8006.84 32.3 59.9 7591000* 1,000 1,000 2500 250010000Copper6.57 43 7.94 1,250 89.5 8.66 5.3 130 242 6.2 6,760 4.79 166 6.83 9.89 41,900 340 40.4 6.66 79 8.75 218na239 34.7 14.3 13.3 34.9NSL NSL NSL NSL NSLNSLLead 7.6938.1415160 8.18 8.22 131 283 9.29 190 7.677866.89 8.57 49421225 8.60 89 7.16 61.4na3,80014.9 9.91 25.2 44.9NSL 300 300 600 6006000Nickel276 235 152,790416 13.8 13.3 125 107 117.016,50013.1 235 127 61.1111,000 694106 14.4 20.2 104500na80214 59.5 83.4 44NSL 300 300 700 70010000SeleniumBDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL na BDL BDL BDL BDL BDL NSL 400 400 2,500 2,5007000SilverBDL BDLBDL BDL BDL BDL BDL BDL BDL BDL3.04BDL8.49BDL BDL4.9BDL BDL BDL BDL BDL BDL na BDL BDL BDL BDL BDL NSL 100 100 200 2002000ThalliumBDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL na BDL BDL BDL BDL BDL NSL 8 8 30 30800Zinc19.8 53 25 80.6 78.3 21.3 19.2 14.5 94.6 22.2 211 18.2 132 27 138 128 279 60 52 104 26.1 325na137 63.1 42.3 33.8 75.6NSL 2,500 2,500 2,500 2,50010000MercuryBDL BDL BDL BDL BDL BDL BDL BDL0.254BDL0.4BDL BDL BDL BDL BDL BDL BDL BDL1.8BDL0.582na0.501BDL BDL BDL BDL 300 20 2060 60300 EPH Aliphatics & Aromatics (mg/Kg) C9-C18 AliphaticsBDL na na na na na na na BDL na BDL na na na na na na na na na na BDL BDL na na na na na NSL 1,000 1,000 2,500 2,500C19-C36 AliphaticsBDL na na na na na na na BDL na BDL na na na na na na na na na na620 880na na na na na NSL 2,500 2,500 5,000 5,000C11-C22 AromaticsBDL na na na na na na na BDL na BDL na na na na na na na na na na92BDLna na nananaNSL2008002002,000EPH Target Analytes (mg/Kg)NapthaleneBDLnananananananaBDLnaBDLnanananana nananananaBDLBDLna na nananaNSL410041,0002-MethylnapthaleneBDL na na na na na na na BDL na BDL na na na na na na na na na na BDL BDL na na na na na NSL 4 7 4 1,000AcenaphthyleneBDL na na na na na na na BDL na BDL na na na na na na na na na na BDL BDL na na na na na NSL 100 100 100 1,000AcenaphtheneBDL na na na na na na na BDL na BDL na na na na na na na na na na BDL BDL na na na na na NSL 20 1000 20 2,500FluoreneBDLnananananananaBDLnaBDLnanananana nananananaBDLBDLna na nananaNSL40010004002,000PhenanthreneBDL na na na na na na na BDL na BDL na na na na na na na na na na BDL BDL na na na na na NSL 700 100 700 100AnthraceneBDLnananananananaBDLnaBDLnanananana nananananaBDLBDLna na nananaNSL1,0001,0002,5002,500FluoranthreneBDLnananananananaBDLnaBDLnanananana nananananaBDL0.94na na na na na NSL 1,000 1,000 2,000 1,000PyreneBDLnananananananaBDLnaBDLnanananana nananananaBDL0.92na na na na na NSL 700 500 1,000 2,000Benzo (a) anthraceneBDLnananananananaBDLnaBDLnanananana nananananaBDL0.44na na na na na NSL 0.7 0.7 1.0 1.0ChryseneBDLnananananananaBDLnaBDLnanananana nananananaBDL0.43na na na na na NSL 7 7.0 10.0 10.0Benzo (b) fluorantheneBDL na na na na na na na BDL na BDL na na na na na na na na na na BDL0.46na na na na na NSL 0.7 0.7 1.0 1.0Benzo (k) fluorantheneBDL na na na na na na na BDL na BDL na na na na na na na na na na BDL BDL na na na na na NSL 7 7.0 10.0 10.0Benzo (a) pyreneBDLnananananananaBDLnaBDLnanananana nananananaBDLBDLna na nananaNSL0.70.70.70.7Indeno (1,2,3,-cd) pyreneBDL na na na na na na na BDL na BDL na na na na na na na na na na BDL BDL na na na na na NSL 0.7 0.7 1.0 1.0Dibenzo (a,h) anthraceneBDL na na na na na na na BDL na BDL na na na na na na na na na na BDL BDL na na na na na NSL 0.7 1 0.7 0.7Benzo (g,h,I,) peryleneBDL na na na na na na na BDL na BDL na na na na na na na na na na BDL BDL na na na na na NSL 1,000 100 2,500 2,500Notes:Laboratory Analytical results compared to: 310 CMR 40.0321(b) & 310 CMR 40.0975(6)(a).Red (bold & shaded orange) = Exceeds Upper Concentration Limit (UCL)Red (bold & shaded yellow) = Exceeds Imminent Hazard StandardRed (& bold) = Exceeds Method 1 Cleanup StandardBlue = Parameter detected above laboratory Method Detection LimitNSL=No Standard Listedna = Not Analyzed for this parameter.ND = Not Detected above detection limit.BDL = Below Detection Limit* = Total Chromium and Chromium III = 1,000 mg/kg if Hexavalent Chromium not analyzed; Chromium VI = 200 mg/kg.RacewayNot Filled Levee Sampling LocationsRacewayFillNew England Environmental, Inc.Table2-Met-PCB-EPH02-2053-Table 2-3-5-6-SOIL_Ph II Raceway FillSapmle ID:Depth (in.)Date CollectedNEE-12.5-3'7/23/03NEE_22-2.5'7/23/03NEE-32-3'7/23/03NEE-42.5'7/23/03NEE-54'7/23/03NEE-73'7/23/03NEE-82-2.5'7/23/03NEE-92-2.5'7/23/03NEE-102-2.5'7/23/04Imminent Hazard (mg/kg)Method 1S-1 Soil & GW-2(mg/kg)Method 1S-1 Soil & GW-3(mg/kg)UCLTotal Metals (mg/kg)AntimonyBDL BDL BDL BDL BDL BDL BDL BDL BDL NSL 10 10300Arsenic25.3 24.1BDL17.5 16.7 7.09 20.537.4BDL403030500BerylliumBDL BDL BDL0.5BDL0.7BDL BDL0.52NSL 0.7 0.72000CadmiumBDL BDL BDL BDL BDL0.8BDL BDL BDL 60 30 301000Chromium18,800 11,800 57,00056610,0406897,17068.4 16.71000* 1,000 1,00010000Chromium, HexavalentnanaBDLnananananana200 200 2002000Copper553 212 1,540 79 163 369 253 111 30NSL NSL NSLNSLLead 3,550 1,990142 297356 451 2,213166 52NSL 300 3006000Nickel3072855,206118 216 105 238 33.9 15NSL 300 30010000Selenium BDL BDL BDL BDL BDL BDL BDL BDL BDL NSL 400 4007000Silver BDL BDL BDL9.05BDL BDL BDL3.41BDL NSL 100 1002000Thallium BDL BDL BDL BDL BDL BDL BDL BDL BDL NSL 8 8800Zinc285 288BDL78.4 303 2,150 214 54.2 42.2NSL 2,500 2,50010000Mercury0.586 1.07BDL0.257BDL1.02BDL BDL BDL 300 20 20300Barium557nanana77.9na139nanaNSL 1,000 1,00010000Notes:Laboratory Analytical results compared to: 310 CMR 40.0321(b) & 310 CMR 40.0975(6)(a).Red (bold & shaded orange) = Exceeds Upper Concentration Limit (UCL)Red (bold & shaded yellow) = Exceeds Imminent Hazard StandardRed (& bold) = Exceeds Method 1 Cleanup StandardBlue = Parameter detected above laboratory Method Detection LimitNSL=No Standard Listedna = Not Analyzed for this parameter.ND = Not Detected above detection limit.BDL = Below Detection LimitTable 3Summary of Laboratory Results - Soil July 2003 (NEE, Phase II & III, October 2003)Former Cutlery Raceway - Phase II SamplingRTN #1-13320Under Cutlery Parking LotUnder VHI Parking Lot, stabilized & now in stockpileNew England Environmental, Inc.Table3-met02-2053-Table 2-3-5-6-SOIL_Ph II Table 4Summary of Laboratory Results - TCLP in Soil (NEE, Phase II & III, October 2003)Former Cutlery Raceway - Phase II EvaluationRTN #1-13320Raceway FillSapmle ID:Depth (in.)Date CollectedSP72'6/26/02DUP-3(SP-15)2-3'6/26/02NEE-12.5-3'7/23/03NEE_22-2.5'7/23/03NEE-32-3'7/23/03NEE-54'7/23/03NEE-73'7/23/03NEE-82-2.5'7/23/03NEE-92-2.5'7/23/03Imminent Hazard (mg/kg)Method 1S-1 Soil & GW-2(mg/kg)Method 1S-1 Soil & GW-3(mg/kg)TCLP Land Disposal CriteriaUCLTotal Metals (mg/kg)Arsenic205BDL25.3 24.1BDL16.7 7.09 20.537.440 30 30300Chromium1329,800 18,800 11,800 57,000 10,0406897,17068.41000* 1,000 1,00010,000Lead 786 3,800 3,550 1,990142356 451 2,213166NSL 300 3006,000TCLP Metals (mg/L)TCLP As0.0552na na na na na na na na5TCLP Crna0.061BDL BDL BDL0.07BDL BDL na5TCLP Pb0.214 3.248.672.92 0.21 2.67 0.06 3.2 0.025Notes:Laboratory Analytical results compared to: 310 CMR 40.0321(b) & 310 CMR 40.0975(6)(a).Red (bold & shaded orange) = Exceeds Upper Concentration Limit (UCL)Red (bold & shaded yellow) = Exceeds Imminent Hazard StandardRed (& bold) = Exceeds Method 1 Cleanup StandardBlue = Parameter detected above laboratory Method Detection LimitNSL=No Standard Listedna = Not Analyzed for this parameter.ND = Not Detected above detection limit.BDL = Below Detection LimitUnder VHI Parking Lot, stabilized & now in stockpile Under Cutlery Parking LotNew England Environmental, Inc.\\OHI_DELL2\OHI Engineering\PROJECTS-OHI Amherst\13-1515_Northampton_Cutlery\2021-03 Proposed PS Remedy\RAM Plan\02-2053-Table 2-3-5-6-SOIL_Ph IItable4-TCLP Sapmle ID:Depth (in.)Date CollectedIHS-910-12"10/24/00NEE-82-2.5'7/23/03NEE-73'7/23/03NEE-32-3'7/23/03TP-25-6'9/29/99SP152-3'6/26/02TP-12, S35'9/11/00DUP-3SP-152-3'6/26/02GZATP-1, S1 0-5'8/8/87TP-12, S17'9/11/00TP-13, S34'9/11/01SP42-3'6/26/02IH-L-10G0-1"12/07/00SP72'6/26/02SP9A0-1' R6/26/02IH-L-180-12"11/21/00SP9A0-1' G6/26/02SP14-5'6/26/02Imminent Hazard (mg/kg)Method 1S-1 Soil & GW-2(mg/kg)Method 1S-1 Soil & GW-3(mg/kg)Method 1S-2 Soil & GW-2(mg/kg)Method 1S-2 Soil & GW-3(mg/kg)UCLPolychlorinated Biphenyls (mg/Kg)SP15PCBs (total)ND nana na na250.2na na na na naBDLna na nana/nana na102222Total Metals (mg/kg)Antimonyna BDL BDL BDL na BDL903BDL na na na BDL3,100BDL BDL na/630BDLBDLNSL10104040300Arsenic51.520.5 7.09BDL na BDL327BDL0.2na na30.7 98.1 205 149 159/108BDL BDL 40 30 30 30 30500BerylliumnaBDL0.7BDL na BDL BDL BDL na na na BDL BDL1.96 2.64na/BDL BDL BDL NSL 0.7 0.7 0.8 0.82000CadmiumBDL BDL0.8BDL na BDL13.90BDL0.9na na4.60BDL1.51 1.89BDL/BDL0.766 0.5603030 80 801000Chromium5,570 7,17068957,0002,41016,500 15,541 29,800 7,510 14,020 7,3473913,30013 2428,600/21,70022 15.61000* 1,000 1,000 2500 250010000Chromium, HexavalentBDLnanaBDLna242BDLna nanaBDLnaBDLna nana/BDLna na 200 200 200 NSL NSL2000Copperna253 369 1,540na218 751 239 nana na1,250 163.0 166 340na/15141,900 6.57NSL NSL NSL NSL NSLNSLLead 721 2213 451142na61.4 1063,800 64,49855.781,203 415 528.0 786 421216/190 49 7.6NSL 300 300 600 6006000Nickelna238 1055,206 941 500 1,430 802na na na2,790174.0 235694na/225111,000276NSL 300 300 700 70010000Seleniumna BDL BDL BDL na BDL BDL BDL11.7na na BDL BDL BDL BDL na/BDL BDL BDL NSL 400 400 2,500 2,5007000Silverna BDL BDL BDL na BDL BDL BDL5.0na na BDL3.48 8.49BDLna/2.584.9BDL NSL 100 100 200 2002000Thalliumna BDL BDL BDL na BDL BDL BDL na na na BDL8.44BDL BDL na/19.3BDL BDL NSL 8 8 30 30800Zincna214 2,150BDL na325 185 137 nana na80.6 114.0 132 279na/168128 19.8NSL 2,500 2,500 2,500 2,50010000Mercury0.258BDL1.02BDL na0.582BDL0.501 0.1na na BDL BDL BDL BDL0.353/BDLBDL BDL 300 20 2060 60300 EPH Aliphatics & Aromatics (mg/Kg) C9-C18 Aliphaticsna na na na BDL BDL250na na500 370na na na nanana BDL NSL1,000 1,000 2,500 2,500C19-C36 Aliphaticsna na na na1160 6207,400na na8300 5,600na na na nanana BDL NSL2,500 2,500 5,000 5,000C11-C22 Aromaticsna na na na312 92830na na1092 1,200na na na nanana BDL NSL200 800 200 2,000VPH Aliphatics & AromaticsC5-C8 Aliphaticsna na na na BDL naBDLna na BDL ND na na na nanana na NSL100 100 500 500C9-C12 Aliphaticsna na na na BDL na3.7na na2.2 0.7na na na nanana na NSL1,000 1,000 2,500 2,500C9 -C10 Aromaticsna na na na BDL na5.9na na8.0 1.8na na na nanana na NSL100 100 500 500Notes:1. Results in red (bold) exceed listed standard.Red (bold & shaded orange) = Exceeds Upper Concentration Limit (UCL)2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard3. Results in blue exceed method detection limit.4. BDL = Below Detction Limit5. na = Not Analyzed for this parameter.6. Shaded Blue = Exposure Point Concentration by AreaRegulatory StandardsTable 6Exposure Point Concnetrations by Area- Soil (NEE, Phase II & III, October 2003)Former Cutlery Raceway, Northampton, MARTN #1-13320Driveway Areas, stabilized, now in StockpileFenced Filled Raceway AreaLevee Area WWWWWWWWWWW W W W W WDDDDDDDDDDD G G G GGGGGGGGGGGGG s s s s s s s s s s sss sssSSSSSSS SSSSS SSS S S S Sss s ssssSs GGGGSMHSMHSMHssssssGGGG205.14 (PVC)MW-4194.04 (Water Level)206.05 (PVC)183.11 (River Elevation)181.61 (River Elevation)207.68 (PVC)203.19 (PVC)191.61 (Water Level)194.91 (Water Level)MW-3MW-1MW-2S204.16 (PVC)199.53 (Water Level)MW-2D189.47 (Water Level)DSMH(Huntley 1996)SB-4(Huntley 1996)SB-3GZA TP-9DEP Sediment Sample Sed-2(Approximate Location)DEP Sediment Sample Sed-1(Approximate Location)C&C Sed-6C&C Sed-5C&C Sed-3C&CSed-2C&C Sed-1150' UpstreamAreas ofSurficialExcavationIH-L-8IH-L-18IH-L-15IH-L-12IH-L-10IH-L-9IH-L-2SMH210205Stone withMasonry CapDEP-1SMH200195190CulvertStone and Masonry DamSMH200Stone Ret ai nin g Wal l 200195190185StoneRetainingWall/Rip RapGZA TP-8GZA TP-7ApproximateLimits ofFormer RacewayIHS-8IHS-7SP-310 feetSP-610 feetSP-76 feetSP-412 feetSP-15 feetSP-161 footSP-154 feetSP-146 feetSP-135 feetSP-105.5 feetSP-9A5 feetSPMW-414 feetWetland AreaWetland AreaNORTHSP-58.5 feetSP-1SP-9B6 feetSP-2Sed-7ExtentofContaminationGGGExtentofContaminationH:\PROJECTS\02-2053-H_Cutlery Raceway\neer14\logo.jpg Former Cutlery Raceway PHASE II SAMPLING SITE PLAN FIGURE 3 320-360 Riverside DriveDrawn by: REVISIONSNEE File # Checked by: DEP RTN #DATEScale: Date:BYNew England Environmental, Inc. Environmental Consulting Services (413) 256-0202 Amherst, MA 01002 9 Research Drive F (413) 256-1092 Northampton, Massachusetts Prepared for: Cutlery Building Associates 56 Main StreetNorthampton, MassachusettsFIGURE 30' - 1'2' - 3' 5' - 6' 10'-11' 14'SP- 1AshPP13, EPH/VPHSP-3PP13PP13SP- 4PP13, PCBs, Pesticides, SVOC, Cyanide, VOCsPP13 PP13SP-5PP13 PP13, EPH/VPH PP13SP-6PP13, EPH PP13SP-7PP13, PP13 PP13SP-9PP13, PP13 PP13, Ash PP13SPMW- 4PP13, PCBs, Pesticides, SVOC, Cyanide, VOCsSP-10PP13SP-14PP13Sed-7AshSP-16PP13, AshSP- 15PP13PP13, EPH, PCBs, Pesticides, SVOC, Cyanide, VOCsNote: SP-7 sample locations in the leveeSP-16 sample locations in the racewaySed-7 sediment sample locations in the wetlandsSP-15 sample locations in the fill materialLocationTable 1 - Soil Sampling Sample Depths and Analyses ``2006 MCP StandardsRegulatory StandardsSapmle ID:Depth (ft.)Date CollectedNEE-82-2.5'7/23/03SA-1-N2-3'11/10/04SA-1-E2-3'11/10/04SA-1-S2-3'11/10/04SA-1-W2-3'11/10/04SA-1-Base3.5'11/10/04Imminent Hazard (mg/kg)Method 1S-3 Soil & GW-2(mg/kg)Method 1S-3 Soil & GW-3(mg/kg)UCLs(mg/kg)TCLP Land Disposal CriteriaExcavated11/10/04Total Metals (mg/kg)SilverBDLBRL BRL50.0 47.4 5.99NSL 200 200 2,000Arsenic20.55.1 19.7 12.4 6.17 8.7240 20 20 200BerylliumBDLBRL BRL BRL BRL BRL NSL 200 200 2,000CadmiumBDL1.22 2.09 9.16 25.0 2.1360 30 30 800Chromium7,1701,1205,4001,830 2,550 2,2001000* 5000 5,000 10,000Chromium, Hexavalentnana na na na na200 200 200 2,000Copper25353.0 116 142 258 131NSL NSL NSL NSLMercuryBDL0.329BRL0.338 3.38 0.26530030 30300Nickel23845.1 113 116 88.9 79.6NSL 700 700 7,000Lead 2,213190 127910 359 321NSL 300 300 3,000AntimonyBDLBRL BRL BRL BRL BRL NSL 30 30 300SeleniumBDLBRL BRL BRL BRL BRL NSL 800 800 8,000ThalliumBDLBRL BRL BRL BRL BRL NSL 80 80 800Zinc21485.7 63.15,020203 95.6NSL 5,000 5,000 10,000Barium139nananananaNSL 5,000 5,000 10,000TCLP Metals (mg/L)TCLP Asnana na na na na 5TCLP CrBDLna na na na na 5TCLP Pb3.20na na na na na 5Notes:1. Results in red (bold) exceed listed standard.2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard3. Results in blue exceed method detection limit.4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH)4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter.6. Shaded Orange = Exceeds Upper Concentration Limit (UCL)7. Shaded Blue = Exceeds TCLP Land Application Standard8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location.Table 4-1IRA Plan (NEE 6/2006) - Table 1-SA-1Confirmatory Soil Summary: SA-1 ExcavationFormer Cutlery Raceway, Northampton, MARTN #1-13320AOC-1New England Environmental, Inc.02-2053_Lab Table-SOIL-SAsSA-1 Excav ``2006 MCP StandardsRegulatory StandardsSapmle ID:Depth (ft.)Date CollectedTP-10b4'11/15/99NEE-54'7/23/03SA-2-N3-4.5'11/10/04SA-2-N23-4.5'12/8/04SA-2-E3-4.5'11/10/04SA-2-E23-4.5'12/9/04SA-2-S3-4.5'11/10/04SA-2-W3-4.5'11/10/04SA-2-W23-4.5'12/9/04SA-2-Base5'11/10/04Stabilized"Stockpile"11/10/04Imminent Hazard (mg/kg)Method 1S-3 Soil & GW-2(mg/kg)Method 1S-3 Soil & GW-3(mg/kg)UCLs(mg/kg)TCLP Land Disposal CriteriaExcavated11/10/04Excavated11/10/04Excavated 12/8/04Excavated 12/9/04Excavated 12/9/04Total Metals (mg/kg)Silverna BDL BRLBRLBRLBRL BRLBRLBRL BRL na NSL 200 200 2,000Arsenicna 16.7 16.312.534.9BRL8.026.6BRL BRL na 40 20 20 200Berylliumna BDL 1.11BRLBRL0.63 BRLBRL0.658BRL na NSL 200 200 2,000Cadmiumna BDL 2.532.424.440.99 1.593.861.46 1.06na 60 30 30 800Chromium202010,0402,5104,05018,70073.0 4,56015,500127 958na 1000* 5000 5,000 10,000Chromium, HexavalentnananaBRLnana nanaBRLnana 200 200 200 2,000Copperna 163 27151518024.4 60.517372.9 39.2na NSL NSL NSL NSLMercuryna BDL BRL0.356BRLBRL BRLBRLBRL BRL na 30030 30300Nickelna 216 59.2280.044831.3 62.3207123 33.2na NSL 700 700 7,000Lead 79935615,40039040198.9585877938132na NSL 300 300 3,000Antimonyna BDL BRL89.2BRL6.09 BRLBRL10.0BRL na NSL 30 30 300Seleniumna BDL BRLBRLBRLBRL BRLBRLBRL BRL na NSL 800 800 8,000Thalliumna BDL BRLBRLBRLBRL BRLBRLBRL BRL na NSL 80 80 800Zincna 303 45023623754.5 62.890.1155 50.9na NSL 5,000 5,000 10,000Bariumna 77.9nananana nanana nana NSL 5,000 5,000 10,000TCLP Metals (mg/L)TCLP Asna na nananana nanana na na 5TCLP Crna 0.07 nana0.0373na na0.0495na na na 5TCLP Pbna 2.67167BRLnana nanana na0.03895Notes:1. Results in red (bold) exceed listed standard.2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard3. Results in blue exceed method detection limit.4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH)4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter.6. Shaded Orange = Exceeds Upper Concentration Limit (UCL)7. Shaded Blue = Exceeds TCLP Land Application Standard8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location.Table 4-2IRA Plan (NEE 6/2006) - Table 1-SA-2Confirmatory Soil Summary: SA-2 ExcavationFormer Cutlery Raceway, Northampton, MARTN #1-13320Side-By-Side AOC-1New England Environmental, Inc.02-2053_Lab Table-SOIL-SAsSA-2 Excav Table 4-3Table 1-SA-32006 MCP StandardsRegulatory StandardsSapmle ID:Depth (ft.)Date CollectedTP-9b1.5'-2'11/15/99 TP-9b4'11/15/99SA-3-N3-5'11/10/04SA-3-N23-5'11/16/04SA-3-N33-5'11/23/04SA-3-E3-5'11/10/04SA-3-S3-5'11/10/04SA-3-W3-5'11/10/04SA-3-W23-5'11/16/04SA-3-W33-5'11/23/04SA-3-Base5.5'11/10/04TP-9b6'-7'11/15/99 Stabilized"Stockpile"11/10/04Imminent Hazard (mg/kg)Method 1S-3 Soil & GW-2(mg/kg)Method 1S-3 Soil & GW-3(mg/kg)UCLs(mg/kg)TCLP Land Disposal CriteriaExcavated11/10/03Excavated11/10/04Excavated11/16/04Excavated11/23/04Excavated11/16/04Excavated11/23/04see note #9 belowTotal Metals (mg/kg)Silverna na BRL BRLBRL BRL BRLBRL BRLBRL BRL na na NSL 200 200 2,000Arsenicna na 34.2 BRLBRL6.37 16.434.0 BRLBRL5.78na na 40 20 20 200Berylliumna na BRL BRLBRL BRL1.86BRL BRL0.697BRL na na NSL 200 200 2,000Cadmiumna na 7.12 2.92BRL0.93 2.923.4 2.60.675 1.69na na 60 30 30 800Chromium33503810 24,900 9,6501,130 3,090 4,51012,100 8,720430 2,320 38.4na 1000* 5000 5,000 10,000Chromium, Hexavalentna nananananananananananana 200 200 200 2,000Coppernana290 294211 52.7 135185 18895.1 110nana NSL NSL NSL NSLMercurynana BRL 0.400.31BRL0.285BRL BRL0.225 0.987nana 30030 30300Nickelnana292 14641.1 54.5 125198.0 167.028.4 78.9nana NSL 700 700 7,000Lead 346719256914119355 3591,350 6751,10027735na NSL 300 300 3,000Antimonynana BRL BRLBRL BRL BRLBRL BRLBRL BRL nana NSL 30 30 300Seleniumnana BRL BRLBRL BRL BRLBRL BRLBRL BRL nana NSL 800 800 8,000Thalliumnana BRL BRLBRL BRL BRLBRL BRLBRL BRL nana NSL 80 80 800Zincnana103 BRL113 77.4 583193 BRL82.4 197.0nana NSL 5,000 5,000 10,000Bariumnanananananananananananana NSL 5,000 5,000 10,000TCLP Metals (mg/L)TCLP Asnanananananananananananana5TCLP Crna 0.120 0.106 nananana0.0382 nanananana5TCLP Pbna11.70.0146 nana2.02 0.05300.0862 nana0.0490na0.03895Notes:1. Results in red (bold) exceed listed standard.Note #9. Shows the decrease in concentration with depth at this location.2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard3. Results in blue exceed method detection limit.4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH)4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter.6. Shaded Orange = Exceeds Upper Concentration Limit (UCL)7. Shaded Blue = Exceeds TCLP Land Application Standard8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location.Table 4-3IRA Plan (NEE6/2006) - Table 1-SA-3Confirmatory Soil Summary: SA-3 ExcavationFormer Cutlery Raceway, Northampton, MARTN #1-13320Side-By-SideAOC-1New England Environmental, Inc.02-2053_Lab Table-SOIL-SAsSA-3 Excav ``2006 MCP StandardsRegulatory StandardsSapmle ID:Depth (ft.)Date CollectedTP-14'-5'9/29/99NEE-32-3'7/23/03SA-4-N2-3'11/10/04SA-4-E2-3'11/10/04SA-4-S2-3'11/10/04SA-4-W2-3'11/10/04SA-4-Base4.5'11/10/04Imminent Hazard (mg/kg)Method 1S-3 Soil & GW-2(mg/kg)Method 1S-3 Soil & GW-3(mg/kg)UCLs(mg/kg)TCLP Land Disposal CriteriaExcavated11/10/04Excavated11/10/04Total Metals (mg/kg)Silverna BDLBRL BRL BRL BRL BRL NSL 200 200 2,000Arsenicna BDL7.4425.416.5BRL19.940 20 20 200Berylliumna BDLBRL BRL0.449 0.45 0.60NSL 200 200 2,000Cadmiumna BDL1.45 1.22BRL1.11 1.3260 30 30 800Chromium2,82057,0003,250 3,070 171 848 1,5901000* 5000 5,000 10,000Chromium, HexavalentnaBDLnanananana200 200 200 2,000Copperna 1,54070.6 106 31.8 35.6 57.7NSL NSL NSL NSLMercuryna BDL0.228BRL BRL BRL BRL 30030 30300Nickelna5,20658.6 52.7 11 43.8 45.4NSL 700 700 7,000Lead 93614288.7 192 45.6 45.6 216NSL 300 300 3,000Antimonyna BDLBRL BRL BRL BRL BRL NSL 30 30 300Seleniumna BDLBRL BRL BRL BRL BRL NSL 800 800 8,000Thalliumna BDLBRL BRL BRL BRL BRL NSL 80 80 800Zincna BDL57.9 52.7BRL64.3 71.3NSL 5,000 5,000 10,000Bariumna nanananananaNSL 5,000 5,000 10,000TCLP Metals (mg/L)TCLP Asna nana na na na na 5TCLP Crna BDLna na na na na 5TCLP Pbna 0.21na na na na na 5Notes:1. Results in red (bold) exceed listed standard.2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard3. Results in blue exceed method detection limit.4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH)4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter.6. Shaded Orange = Exceeds Upper Concentration Limit (UCL)7. Shaded Blue = Exceeds TCLP Land Application Standard8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location.Table 4-4IRA Plan (NEE 6/2006) - Table 1-SA-4Confirmatory Soil Summary: SA-4 ExcavationFormer Cutlery Raceway, Northampton, MARTN #1-13320Side-By-Side AOC-1New England Environmental, Inc.02-2053_Lab Table-SOIL-SAsSA-4 Excav Table 4-5Table 1-SA-52006 MCP StandardsRegulatory StandardsSapmle ID:Depth (ft.)Date CollectedTP-73'11/15/99 NEE-22-2.5'7/23/03SA-5-N2-3'11/10/04SA-5-N22-3'11/16/04SA-5-NE32-3'11/23/04SA-5-E2-3'11/10/04SA-5-E22-3'11/16/04SA-5-E32-3'11/23/04SA-5-S2-3'11/10/04SA-5-S22-3'11/16/04SA-5-W2-3'11/10/04SA-5-W22-3'11/16/04SA-5-Base3.5'11/10/04SA-5-Base24'11/16/04Imminent Hazard (mg/kg)Method 1S-3 Soil & GW-2(mg/kg)Method 1S-3 Soil & GW-3(mg/kg)UCLs(mg/kg)TCLP Land Disposal CriteriaExcavated11/10/03Excavated11/10/04Excavated11/16/04Excavated11/23/04Excavated11/16/04Excavated11/23/04Excavated11/16/04Excavated11/16/04Excavated11/16/04Total Metals (mg/kg)SilvernaBDL BRL 16.2BRLBRL BRLBRLBRLBRLBRLBRLBRLBRL NSL 200 200 2,000Arsenicna24.1 21.4 BRLBRL66.6BRL6.926.4BRL5.85BRL37.2BRL 40 20 20 200BerylliumnaBDL BRL BRLBRL0.58 BRL0.6BRLBRL0.44BRLBRLBRL NSL 200 200 2,000CadmiumnaBDL 3.19 3.27BRL1.66 3.38BRL1.941.661.230.733.280.7360 30 30 800Chromium274011,800 10,300 9,4203,5003,9808,90024.66,3904,8608564479,7404471000* 5000 5,000 10,000Chromium, Hexavalentnananananananananananananana200 200 200 2,000Copperna212 322 40067.778 17922.8128BRL43.8BRL191BRL NSL NSL NSL NSLMercuryna1.07 0.601 1.25BRLBRL 4.67BRLBRLBRLBRLBRL7.0BRL 30030 30300Nickelna285 248 31797.761.7 171.013.211682.534.518.519918.5NSL 700 700 7,000Lead 1,350 1,990433 3011511031,4901491,25025438032.769232.7NSL 300 300 3,000AntimonynaBDL BRL BRLBRLBRL BRLBRLBRLBRLBRLBRLBRLBRL NSL 30 30 300SeleniumnaBDL BRL BRLBRLBRL BRLBRLBRLBRLBRLBRLBRLBRL NSL 800 800 8,000ThalliumnaBDL BRL BRLBRLBRL BRLBRLBRLBRLBRLBRLBRLBRL NSL 80 80 800Zincna288 190 BRL102131 BRL14469.6BRL50.5BRL159BRL NSL 5,000 5,000 10,000BariumnanananananananananananananaNSL 5,000 5,000 10,000TCLP Metals (mg/L)TCLP Asnananananananananananananana5TCLP CrnaBDLnananananananananananana5TCLP Pbna2.92nananananananananananana5Notes:1. Results in red (bold) exceed listed standard.2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard3. Results in blue exceed method detection limit.4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH)4. BRL = Below Reporting Limit 5. na = Not Analyzed for this parameter.6. Shaded Orange = Exceeds Upper Concentration Limit (UCL)7. Shaded Blue = Exceeds TCLP Land Application Standard8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location.Table 4-5IRA Plan (6/2006) - Table 1-SA-5Confirmatory Soil Summary: SA-5 ExcavationFormer Cutlery Raceway, Northampton, MARTN #1-13320Side-By-Side AOC-2AOC-1New England Environmental, Inc.02-2053_Lab Table-SOIL-SAsSA-5 Excav Table 1Table 1Laboratory Results - PP13 Metals in Soil Former Cutlery Building BankNorthampton, MARegulatory StandardsSample I.D.:Sample Depth:CB-10-3"CB-20-3"CB-30-3"CB-40-3"CB-5-SED0-3"CB-60-3"CB-70-3"CB-80-3"CB-90-3"CB-100-3"CB-11-SED0-3"CB-120-3"CB-130-3"CB-14-SED0-3"CB-150-3"Method 1 StandardUCLs(mg/kg)Sampling Date: 5/23/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05 6/21/05S-1/GW-1 S-1/GW-2 S-1/GW-3 Metals (mg/Kg)lt. g br dk g, bl dk g t,br dk g, br dk br, g r, br o, br br t,br dk g, mr dk br br lt g, br, dk gSilverBDLBRL BRL3.01BRL BRL BRL BRL BRL BRL12.56.04BRL BRL BRL NBL100 100 100 100 NSL2,000Arsenic<31.710.5BRL BRL BRL BRL BRL32.5BRL32.7BRL10.9BRL BRL BRL 9.79 30 30 30 30 40300Beryllium<4.221.23BRL BRL BRL BRL BRL0.7610.550.757BRL BRL BRL0.48BRL NBL 0.7 0.7 0.7 0.7 NSL30CadmiumBDL1.34BRL0.884BRL1.06BRL BRL BRL1.11BRL1.2BRL BRL BRL 0.99 30 30 30 30 60800Chromium (III)25000 1910 1830 411089.54090940 345 75.711101130469078.176.8576043.4 1000 1000 1000 1000 100010,000Copper269 298 112 241142176 58.7 452 43.1 213315333 59.483.910631.6 1000 NSL NSL NSL NSL10,000MercuryBDL1.6 0.483 0.4390.3680.66 0.408 0.241.686.220.889BRL21.90.1820 20 20 20 300NSLNickel669188 111 16596.3188 53.556519.8 225545163 17.145.614222.7 300 300 300 300 NSL600Lead220 216505 7531281040238506 664 1260329448025281.324635.8 300 300 300 300 NSL7,000Antimony<31.7BRL BRL BRL BRL BRL BRL BRL BRL143BRL471BRL BRL BRL NBL 10 10 10 10 NSL6,000SeleniumBDLBRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NBL 400 400 400 400 NSL400Thallium<31.7BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL NBL8888 NSL10,000Zinc79.4 773 333 418129597 58 103 65 447281657 109101411121 2500 2500 2500 2500 NSL1,000Notes:Color Codes:1. Results in red (bold) exceed listed standard. br = brown p = pink t = tan2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standard bl = black r = red lt. = light3. Results in blue exceed method detection limit. g = gray mr = maroon dk. = dark4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) c = cinders y = yellow w = white4. BRL = Below Reporting Limit o = orange grn = green5. na = Not Analyzed for this parameter.6. Shaded Orange = Exceeds Upper Concentration Limit (UCL)7. Shaded Blue = Exceeds TCLP Land Application Standard8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location.9 - Shaded Rose - Exceeds TEC Benchmark TEC9 BenchmarksRCS-1 Imminent HazardNew England Environmental, Inc.PP13-CB02-2053_Lab Table_Phase IV_soil.xls Table 5Table 2Laboratory Results - PP13 Metals in Soil Former Cutlery RacewayNorthampton, MARegulatory StandardsSample I.D.:Sample Depth:LE-10-3"LE-20-3"LE-30-3"LE-40-3"LE-50-3"LE-60-3"LE-70-3"LE-80-3"LE-90-3"LE-100-3"LE-110-3"LE-120-3"LE-130-3"LE-140-3"LE-150-3"LE-160-3"LE-170-3"LE-180-3"LE-190-3"LE-200-3"LE-210-3"LE-220-3"LE-230-3"Method 1 StandardSampling Date: 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05 4/28/05S-1/GW-1 S-1/GW-2 S-1/GW-3 Metals (mg/Kg)br,g,c dk.br,o,c lt.g,r/brlt.br,t "clean" y,g,br br,o dk.gt,br, grn hue p/r br br, grn huec, ash, not ex lt.g r/br,y g dk.g, br t br, not ex br,c,ash br dk.br,c g g, sparklesSilverBRL3.45BRL BRL BRL14.7 14.9BRL BRL2.47 6.75BRL BRL BRL4.21BRL BRL6.09 3.43BRL BRL BRL BRL100 100 100 100NSL2,000ArsenicBRL17.7BRL7.5323 39.1 33.2 25.6 10714.529.615.3 17.8 7.4223.8BRL BRL21.417.8 13.9 13.1 6.44BRL2020202040200Beryllium0.522BRL0.471 0.499 0.645BRL0.682 0.674 2.05 0.577 0.668 1.06 0.453 0.484 0.603BRL0.598BRL0.912 0.541 0.795 0.528 0.463100 100 100 100NSL2000CadmiumBRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL222260300Chromium (III)1080101 148 785 280 18.1 520 376 22.7 528 519 547207030.3 723947043 591270 1050 3690 1300 80501000/30 1000/30 1000/30 1000/30100010,000/2,000Copper1171110028.6 310461043121400 115014119100 6410 1820767 60.611800359 43.612100 4970 3100 167085928001,000 NSL NSL NSLNSLNSLMercuryBRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL0.315BRL BRL BRL BRL BRL0.51BRL BRL20202020300300Nickel148 22800 97.5 566 9080 437 46300 1830 1040 35700 13000 3740 1600 812 23700 677 346 26500 7910 4950 2910 1650 525020202020NSL7,000Lead118 156 63.1 93.5 219 252 271 219 140436 394136 201 75.6 27884269.3 227324241 133 161 195300 300 300 300NSL3,000AntimonyBRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL20202020NSL300SeleniumBRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL400 400 400 400NSL8,000ThalliumBRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL8888NSL800Zinc36.9 125 27.9 53.4 97.8 117 144 80.7 29.4 186 119 20 66.7 43.4 71.8 44.6 46.5 75.7 41.2 126 50.7 57.1 3002500 2500 2500 2500NSL10,000Notes:Color Codes:1. Results in red (bold) exceed listed standard.br = brown p = pink t = tan2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standardbl = black r = red lt. = light3. Results in blue exceed method detection limit.g = gray mr = maroon dk. = dark4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) c = cinders y = yellow w = white4. BRL = Below Reporting Limit o = orange grn = green5. na = Not Analyzed for this parameter.6. Shaded Orange = Exceeds Upper Concentration Limit (UCL)7. Shaded Blue = Exceeds TCLP Land Application Standard8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location.9 - Shaded Rose - Exceeds TEC Benchmark Sediment Samples: sand collected on the BeachRegulatory StandardsSample I.D.:Sample Depth:LE-250-3"LE-260-3"LE-270-3"LE-280-3"LE-290-3"LE-300-3"LE-310-3"LE-320-3"LE-330-3"LE-340-3"LE-350-3"LE-360-3"LE-370-3"LE-380-3"LE-390-3"LE-400-3"LE-240-3"B-10-3"B-20-3"B-30-3"B-40-3"Method 1 StandardSampling Date: 5/2/05 5/2/05 5/2/05 5/2/05 5/2/05 5/2/05 5/2/05 5/2/05 5/6/05 5/6/05 5/6/05 5/6/05 5/6/05 5/6/05 5/6/05 5/6/05 4/28/05 5/6/05 5/6/05 5/6/05 5/6/05S-1/GW-1 S-1/GW-2 S-1/GW-3 Metals (mg/Kg)dk.br,c r/o p/r dk.br, bl, g dk.g, bl t, brlt.g, sparkles bl, grn lt.br, t mr dk.br,g dk.br,bl grn,t bl br dk.br t,br lt.g, wlt.br,g,grn huelt.br,g,grn hue t,grnSilverBRL BRL BRL4.16BRL BRL BRL BRL3.77 5.14 7.98 11.4BRL11.1BRL8.32BRL BRL BRL BRL BRLNBL100 100 100 100NSL2,000Arsenic14.228.2 213 39.2 20.25.85BRL18.221.8 40.3 56.3 104BRL667BRL19.6BRL BRL BRL BRL BRL9.792020202040200Beryllium0.637 0.551 3.56 0.861 0.53 0.571BRL BRL0.557BRL BRL BRL0.434 1.17 0.487BRLBRL BRL BRL0.511BRLNBL100 100 100 100NSL2000CadmiumBRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRLBRL BRL BRL BRL BRL0.99222260300Chromium (III)759 36.1 99.8 166188065.9 19.6934045 54.12310 145032.2124018.4 34952.5 16.6 21.2 39.5 38.543.41000/30 1000/30 1000/30 1000/30100010,000/2,000Copper911 2871490 2360 34000160 32.41730 3500 5260 18800 3110027.1 300 8.93429087.7 65 98.7 90.8 15931.61,000 NSL NSL NSLNSLNSLMercury0.22 0.23BRL BRL BRL BRL BRL BRL BRL0.243 0.665 0.227BRL1.23BRL BRLBRL BRL BRL BRL BRL0.1820202020300300Nickel1460 1320 2580 4280 86100 452 74.4 4140 6500 9920 46100 75900 107 149 142 910056.6 89 162 21.6 31722.720202020NSL7,000Lead164 264452 537130 80.6 25.9 155 128 157 147 184 24.5108012.237424.7 16.4 15 30.7 38.635.8300 300 300 300NSL3,000AntimonyBRL BRL BRL13.3BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRLBRL BRL BRL BRL BRLNBL20202020NSL300SeleniumBRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL BRL771BRL BRLBRL BRL BRL BRL BRLNBL400 400 400 400NSL8,000ThalliumBRL BRL BRL BRL16.6BRL BRL21.4BRL BRL BRL BRL BRL BRL BRL BRLBRL BRL BRL BRL BRLNBL8888NSL800Zinc79 90.4 127 89.5 80.8 30.8 31.8 274 100 143 288 121 21.2 164 25.3 97.786.1 43.2 98.6 124 30.91212500 2500 2500 2500NSL10,000Notes:Color Codes:1. Results in red (bold) exceed listed standard.br = brown p = pink t = tan2. Red (bold & shaded yellow) = Exceeds Imminent Hazard Standardbl = black r = red lt. = light3. Results in blue exceed method detection limit.g = gray mr = maroon dk. = dark4. BDL = Below Detction Limit (BDL-* = EPA Method 8100M, not EPH) c = cinders y = yellow w = white4. BRL = Below Reporting Limit o = orange grn = green5. na = Not Analyzed for this parameter.6. Shaded Orange = Exceeds Upper Concentration Limit (UCL)7. Shaded Blue = Exceeds TCLP Land Application Standard8. Results in grey type indicate this soil was subsequently excavated and is no longer present at this location.9 - Shaded Rose - Exceeds TEC Benchmark IRA PLAN (NEE 06/2006) - Table 2UCLs(mg/kg)UCLs(mg/kg)Imminent HazardRCS-1 Imminent HazardTEC9 BenchmarksRCS-1 New England Environmental, Inc.PP13-Levee02-2053_Lab Table_Phase IV_soil-updated09 OTO Brownfields Investigation (June 2006) - Table 2Groundwater Analytical ResultsInorganic AnalytesFormer Cutlery RacewayNorthampton, MAConcentrations in mg/lWell No.: CR-1 CR-2 CR-3 CR-6 CR-8 MW-4F* MW-4U* WP-1 WP-2 GW-3Sample Date: 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 6/5/06 StandardsUCLsVOCs by Method 8260BND ND ND ND ND -- -- ND ND vary varyEPH FractionsC9-C18 Aliphatics < 0.2 < 0.2 < 0.2 < 0.2 < 0.2 -- -- < 0.2 -- 20 100C19-C36 Aliphatics < 0.2 < 0.2 < 0.2 < 0.2 < 0.2 -- -- < 0.2 -- 20 100C11-C22 Aromatics < 0.2 < 0.2 < 0.2 < 0.2 < 0.2 -- -- < 0.2 -- 30 100EPH Target PAHsND ND ND ND ND -- -- ND -- varyvaryMetalsAntimony< 0.030 < 0.030 < 0.030 < 0.030 < 0.030 < 0.024 < 0.15 < 0.030 < 0.030880Arsenic < 0.004 < 0.004 < 0.004 < 0.004 < 0.004 < 0.0080.125< 0.004 < 0.0040.9 9Beryllium < 0.002 < 0.002 < 0.002 < 0.002 < 0.002 < 0.004 0.0165 < 0.002 < 0.002 0.05 0.5Cadmium < 0.0025 < 0.0025 < 0.0025 < 0.0025 < 0.0025 < 0.005 < 0.0125 < 0.0025 < 0.00250.004 0.05Chromium (III) < 0.005 < 0.005 < 0.0050.0431< 0.005 < 0.0101.81< 0.0050.0056 0.6 6Copper < 0.005 < 0.005 < 0.0050.0117< 0.005 < 0.0101.4< 0.0050.0103NS NSLead < 0.0075 < 0.0075 < 0.00750.0158< 0.0075 < 0.0150.286< 0.0075 < 0.00750.01 0.15Mercury< 0.0002 < 0.0002 < 0.0002 < 0.0002 < 0.0002 < 0.00020.00029< 0.0002 < 0.00020.02 0.2Nickel0.0058 0.0636 0.0656 0.0432< 0.0050.1743.67< 0.0050.0137 0.2 2Selenium < 0.015 < 0.015 < 0.015 < 0.015 < 0.015 < 0.030 < 0.075 < 0.015 < 0.0150.1 1Silver < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.0100.0272< 0.005 < 0.005 0.0071Thallium< 0.010 < 0.010 < 0.010 < 0.010 < 0.010 < 0.020 < 0.050 < 0.010 < 0.010330Zinc< 0.035 < 0.025 < 0.025 < 0.057 < 0.0250.1232.13< 0.0960.4930.950NOTES:1. Concentrations in milligrams per liter (mg/l, or parts per million). "<" indicates not detected; value is quantitation limit. "--" = Not analyzed for this pa2. MCP Method 1 groundwater standards from 310 CMR 40.0974(2). "UCLs" = Upper Concentration Limits, from 310 CMR 40.0996(7). 3. Values shown in bold exceed standards, underlined exceed UCLs.4. "ND" = None of the target analytes were detected. "NA"=Not applicable. "NS"=No standard available.5. "VOCs" = Volatile organic compounds. "EPH" = Extractable Petroleum Hydrocarbons. "PAHs"=Polycyclic aromatic hydrocarbons.* Groundwater from well MW-4 was analyzed on both a filtered (F) and unfiltered (U) basis.Table 2-1AOC-3AOC-2New England Environmental, Inc.GW data.xls / gw (2) Table 1 - Groundwater Sample Laboratory ResultsRAO A3-P & C1-P Statement (NEE, 2011)Former Cutlery Raceway, Northampton MARTN #1-13320Sample ID:Date CollectedMW-11/24/01MW-16/8/01MW-110/24/08MW-31/24/01MW-36/8/01MW-310/24/08MW-2S1/24/01MW-2S6/8/01MW-2S10/24/08MW-2D1/24/01MW-2D6/8/01MW-2D10/24/08MW-41/31/01MW-46/8/01MW-43/27/02MW-46/5/06MW-410/24/08Method 1GW-2StandardMethod 1GW-3Standard UCLOTOEPH Aliphatics/Aromatics (ug/L)C9-C18 AliphaticsBDL BDLnaBDL BDLnaBDL BDLnaBDL BDLna naBDLna na na1,000 20,000100,000C19-C36 AliphaticsBDL BDLnaBDL BDLnaBDL BDLnaBDL BDLna naBDLna na naNA 20,000100,000C11-C22 AromaticsBDL BDLnaBDL BDLnaBDL BDLnaBDL BDLna naBDLna na na50,000 30,000100,000EPH Target PAH Analytes (ug/L)All Analytes BDLBDL BDLnaBDL BDLnaBDL BDLnaBDL BDLna naBDLna na na -- -- --Soluble PP13 Metals (ug/L)7/11/01 7/11/01 7/11/01 7/11/01 7/11/01Antimony BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 8,000 80,000Arsenic BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 900 9,000Beryllium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 200 2,000Cadmium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 4 50Chromium BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL2.6BDL BDL BDL BDL BDL BDL NA 600/300 3,000CopperBDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NSL NSL NSLLead BDL BDLBDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 10 150NickelBDL20.9 9.5BDL BDL BDL BDL3.03BDL BDL BDL BDL333 735 468174 84.2NA 200 2,000SeleniumBDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 100 1000SilverBDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 7 1000ThalliumBDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 3000 30,000ZincBDL3.78BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL26.7 18.5 22.2 123BDL NA 900 50,000MercuryBDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL NA 20 200Notes:1 Laboratory Analytical results compared to: 310 CMR 40.1600 & 310 CMR 40.0974(2).2Red (& bold) = Exceeds Method 1 GW-3 Standard3Blue = Parameter detected above laboratory Method Detection Limit4 NSL=No Standard Listed5 na = Not Analyzed for this parameter.6 BDL = Below Detection Limit7Red (& bold) with yellow = Exceeds UCL StandardClass A3 RAO: AOC-1Class C1 RAO: AOC-2 & AOC-3DowngradientUpgradientUpgradient DowngradientNew England Environmental, Inc.O:\PROJECTS-OHI Amherst\13-1515_Northampton_Cutlery\2021-03 Proposed PS Remedy\RAM Plan\02-2053-Table 1-GW_2011Sheet1 (2) APPENDIX E BlastoxR Info BLASTOX® HOW DOES BLASTOX® WORK? There are multiple stabilization mechanisms for Blastox® . These are summarized by the following: 1) encapsulating hydration reactions; 2) addition and substitution reactions between heavy metal cations and calcium silicates; and 3) a pH adjustment. The pH adjustment is a result of hydration reactions, immobilizing the lead ions and allowing the remaining chemical reactions to occur. The lead is chemically converted from a soluble form (like lead oxide or lead hydroxide) to a stable lead salt (i.e., lead silicate). Blastox® uses an EPA BDAT stabilization process. Please contact TDJ Technical Services for more information. Long Term Stability data indicate that spent Blastox® blended abrasives repeatedly pass the EPA long-term stability test, i.e., Multiple Extraction Procedure (MEP). That test subjects a sample to 1 TCLP test, then nine (9) back to back tests in an acidic solution of pH 3.0. The MEP is designed to simulate long-term acid exposure in a landfill. In addition, spent Blastox® blended abrasives have passed multiple TCLP tests on the same waste sample. Similarly, spent Blastox® blended abrasives pass the Synthetic Precipitation Leach Procedure (SPLP) as well as neutral leach testing. The TDJ Group, Inc. 1-800-BLASTOX The TDJ Group, Inc. 760-A Industrial Drive 847-639-1113 Phone 009 Cary IL 60013 847-639-0499 Fax web www.blastox.com e mail tdj@blastox.com BLASTOX® TECHNICAL BULLETIN TB-006 Issued 1-98 BLASTOX® STABILIZATION REACTIONS The EPA has published a list of what it deems the Best Demonstrated Available Technologies (BDAT) for the stabilization of D008 and P+U Lead Wastes. Lead-based paint debris are included in this classification. BDAT stabilization technologies include "lime/fly ash mixtures, cement, concrete mixtures, or other proprietary or non-proprietary formulations". Blastox® uses these chemistries. The leachability of lead is affected by two factors: the chemical form of the lead, and the pH of the leachate. (Temperature can also slightly affect lead leachability, but the affect is minimal). The leachability of lead can be 'masked' or temporarily minimized by plating or pH buffering reactions. A plating reaction is one which the lead plates (adheres) to the surface of pure iron. Lead will not plate to iron oxide (rust). Once iron is exposed to environmental conditions that initiate the formation of iron oxide, the lead plating reactions reverse themselves and the lead becomes available for leaching. Lead solubility can also be minimized by controlling the pH of the leaching solution. Once the buffering effect is overcome, however, lead may become available for leaching. Blastox® utilizes an initial pH adjustment followed by additional stabilization reactions that produce a long term stable waste. The stabilization of lead by Blastox® occurs in three steps: 1. The addition of Blastox® creates an alkaline matrix in which lead is stable. This elevated pH instantaneously stabilizes the lead. 2. Silicate reactions change the chemical form of the lead from a lead oxide, carbonate, or hydroxide to a lead silicate which is insoluble. 3. Hydration reactions encapsulate the waste into a cementitious mass which limits the gravitational flow of water. The above reactions occur simultaneously and all are equally important in the stabilization of lead waste. The silicate and hydration reactions promote the long term stability of the waste. The end result of the three reactions is an encapsulated, insoluble lead silicate. The change in alkalinity (pH) is a by- product of the silicate and hydration reactions and is not the primary stabilizing reaction. The resulting lead silicate will not leach into acidic, neutral, or basic solutions. The reactions are not reversible. If Blastox® is present, the lead will be converted to a lead silicate and become insoluble. TECHNICAL DATA BLASTOX® 215 PRODUCT NAME Blastox® 215 PRODUCT DESCRIPTION: Blastox® 215 is a patented, fine granular, complex calcium silicate-based additive for stabilizing heavy metals including lead and cadmium. Other heavy metals can be stabilized with other TDJ product lines. OrDUCT DESCRIPTION USE: Dose rates vary based on untreated leachability rates. Exact dose rates can be verified by performing a treatability study. When resultant waste tests non-hazardous via the EPA TCLP test, it qualifies for disposal in a local subtitle D landfill. CHEMICAL REACTIONS: Blastox® 215 produces insoluble heavy metal compounds through chemical conversion, pH adjustment and physical encapsulation. RESTRICTIONS: Material must be kept dry until preparations are made for field application. TYPICAL PROPERTIES* SPECIFIC GRAVITY: 3.15 – 3.22 BULK DENSITY: 95 – 100 #/FT3 pH: 11.0-12.0 SOLUBILITY: (Slight) .1% - 1.0% SCREEN ANALYSIS :(~85%) (-) 52 – (+) 400 mesh per ASTM E-11 specification * *These data are results of historical production performance. AVAILABILITY Blastox 215 is manufactured at TDJ’s facilities in the Chicagoland area and sold through distributors. Product is available in bulk, super sacks and 70 lb multi-walled paper bags. Contact TDJ’s corporate office for pricing and your local distributor. TECHNICAL SERVICE Complete technical bulletins and information are available from TDJ’s corporate office or on the TDJ website at www.blastox.com. Technical assistance for specific applications is available by contacting the corporate office. BLASTOX® 215 WARRANTY All recommendations, statements and technical data contained herein are believed to be reliable and accurate, but are not to be construed as a warranty, expressed or implied. We accept no responsibility for results obtained by the application of this information. Unless otherwise specifically stated in a written supply contract, user assumes all responsibility and liability for loss or damage arising from the handling and use of this product. 12/05 Rev: 5/16 Blastox215TechData The TDJ Group, Inc. www.blastox.com 1-800-252-7869 Blastox 215 Safety Data Sheet (SDS) ® The TDJ Group, Inc. Date Prepared or Revised: October, 2015 SECTION 1: PRODUCT AND COMPANY INFORMATION Manufacturer TDJ Group, Inc., 760-A Industrial Dr., Cary, IL 60013 Telephone 847-639-1113 FAX (847) 639-0499 WEBSITE: www.blastox.com EMAIL: tdj@blastox.com Product Name(s) Blastox® 215 Recommended Uses / Restrictions Heavy metal stabilizer / Industrial or commercial use only Emergency Contact / Number Chemtrec: 800-424-9300; TDJ Group: 847-639-1113 SECTION 2: HAZARD IDENTIFICATION Hazards Eye damage/irritation Category 2B – Causes eye irritation Skin corrosion/irritation Category 2 – Causes skin irritation Specific Target Organ Toxicity (single occurrence) Category 3 – May cause respiratory irritation Signal Word WARNING Precautionary Statements: Wash hands and exposed areas thoroughly after handling. Wear protective gloves. Wear eye and face protection. Avoid breathing dust. Use only outdoors or in a well-ventilated area. If in eyes: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. If eye irritation persists: Get medical advice or attention. If on skin: Wash with plenty of water. If skin irritation occurs: Get medical advice or attention. Take off contaminated clothing and wash before reuse. If inhaled: Remove person to fresh air and keep comfortable for breathing. Call a poison center/doctor if you feel unwell. Store in a well-ventilated place. Keep container tightly closed. Dispose of contents or container in accordance with applicable regulations. SECTION 3: COMPOSITION/INFORMATION ON INGREDIENTS Component Name CAS# Component% Calcium silicates and aluminates See note >80 Magnesium oxide 1309-48-4 <5 Non-hazardous ingredients Proprietary Mixture Balance to 100% Note: Contains CAS 12168-85-3, 10034-77-2, 12042-78-3, and 12068-35-8 SECTION 4: FIRST AID MEASURES Most Important Symptoms / Effects: Eye contact with powder or solution can cause irritation or mechanical abrasion. Skin irritation can occur from contact with the product. Inhalation may cause coughing or mild irritation. Skin Contact: Wash exposed areas promptly with water and mild soap. Remove contaminated clothing immediately and launder before reuse. Seek medical advice or attention if irritation occurs. Eye Contact: Immediately flush eyes with water for at least 15 minutes. Remove contact lenses if easy to do. Seek medical attention if any symptoms persist. Inhalation: Move to fresh air. Keep at rest and in a position comfortable for breathing. If you feel unwell, seek medical advice. Ingestion: Do not induce vomiting. Wash out mouth with water. If vomiting occurs naturally, have victim lean forward to reduce the risk of aspiration. Seek immediate medical advice or attention. Indication of Immediate Medical Attention and Special Treatment, If Necessary: Persistent eye or skin irritation, difficulty in breathing. SECTION 5: FIREFIGHTING MEASURES Suitable and Unsuitable Extinguishing Media: Product does not burn. Use fire-fighting techniques appropriate to the surrounding fire. Specific Hazards Arising from the Chemical: None known. Special Protective Equipment and Precautions for Fire-Fighters: Use equipment and procedures appropriate to the surrounding fire. Page 1 of 3 Blastox 215 Safety Data Sheet (SDS) ® The TDJ Group, Inc. Date Prepared or Revised: October, 2015 SECTION 6: ACCIDENTAL RELEASE MEASURES Personal Precautions: Isolate release area and keep unnecessary or untrained people away. See Section 8 for personal protection gear. Environmental Precautions: Contain spill if it can be done with minimal risk. Prevent from entering drains, sewers or waterways. Material is not regulated by DOT or EPA. Methods for Cleaning Up: Avoid actions such as use of compressed air or vigorous dry sweeping that may cause dusting. Place material into container for later use, recycle or disposal. SECTION 7: HANDLING AND STORAGE Handling: Plant processes should be designed to minimize or control airborne dusts. All bags and containers should be properly labeled. Keep bags unopened until use. Keep containers tightly sealed when not in use. Use only with adequate ventilation. Wash hands at end of shift or before eating or using restroom. Wear gloves, goggles and appropriate clothing to avoid repeated or prolonged contact. Use good hygiene practices when handling product, including changing and laundering work clothes after use. Storage: Keep containers in a dry, cool, well-ventilated area. Keep containers tightly closed. SECTION 8: EXPOSURE CONTROL AND PERSONAL PROTECTION Exposure Limits Component Name ACGIH TLV-TWA OSHA PEL-TWA Particulate material 10 mg/m3 15 mg/m3 Calcium silicate 10 mg/m3 15 mg/m3 (total) 5 mg/m3 (respirable ) Magnesium oxide 10 mg/m3 15 mg/m3 Engineering Controls: Use appropriate ventilation to maintain airborne concentration limits below exposure limits. Have eye wash stations and safety showers readily available. Eye and Face Protection: Wear safety glasses or goggles to prevent dust from getting in eyes. Skin Protection: Wear water-proof gloves to prevent contact. Additional body garments should be used based upon the task being performed. Respiratory Protection: Use a properly fitted NIOSH respirator in areas where the exposure is unknown or above the OSHA PEL or ACGIH TLV. General Hygiene: Follow accepted work practices for handling an alkaline material. Do not eat, drink or smoke in areas where this chemical is used or stored. Wash thoroughly with soap and water after task or shift, when using the restroom or before eating. SECTION 9: PHYSICAL AND CHEMICAL PROPERTIES Appearance/Physical State Gray solid (powder) Flash Point Not Applicable Specific Gravity (Water=1) 3.15 Upper Flammability Limits Not Applicable Evaporation Point Not Applicable Lower Flammability Limits Not Applicable pH (in water) ~12 Auto-ignition Temperature Not Applicable Solubility in Water Slight (0.1 – 1%) Decomposition Temperature Not Determined Odor No distinct odor Vapor Pressure Not Applicable Odor Threshold Not Determined Vapor Density (Air-=1) Not Applicable Melting/Freezing Point >1000 °C Partition Coefficient (n-octanol/water) Not Applicable Boiling Range Not Applicable Viscosity (cSt , 40 °C) Not Applicable Initial Boiling Point Not Applicable Critical Temperature Not Determined Note: Physical and chemical properties are provided for safety, health and environmental considerations and do not fully represent product specifications. Those should be requested separately. Page 2 of 3 Blastox 215 Safety Data Sheet (SDS) ® The TDJ Group, Inc. Date Prepared or Revised: October, 2015 SECTION 10: STABILITY AND REACTIVITY Reactivity: None Chemical Stability: Stable when properly stored dry. Contact with water can produce calcium hydroxide. Possibility of Hazardous Reactions: Will not occur under recommended conditions Conditions to Avoid: Keep dry. Incompatible Materials: Acids, ammonia salts or aluminum Hazardous Decomposition Products: None SECTION 11: TOXICOLOGICAL INFORMATION Acute Effects: Aqueous solution can cause serious eye damage due to high alkalinity. Aqueous solution can cause severe skin irritation or burns due to high pH in water. Ingestion may cause burns or irritation to the linings of the mouth, throat, and gastrointestinal tract. Inhalation may be irritating or corrosive to the respiratory tract due to product’s alkaline nature. Target Organ Effects: Lungs and respiratory system: short-term or immediate effects of dust inhalation are expected to be coughing and mild respiratory irritation. Pre-existing Conditions Aggravated by Exposure: Respiratory or skin disorders Chronic Effects: Acute symptoms may be aggravated Carcinogenicity: Contains no components known by IARC, NTP or OSHA to be carcinogenic. Blastox® 215 has been analyzed and does not contain detectible amounts (<0.2%) of crystalline quartz which is known to be carcinogenic. SECTION 12: ECOLOGICAL INFORMATION Ecotoxicity: Not Determined Degradability: Not Determined Mobility: Not Determined Bioaccumulation: Not Determined SECTION 13: DISPOSAL CONSIDERATION Product is not regulated by EPA or DOT. Dispose in compliance with all applicable federal, state and local regulations. SECTION 14: TRANSPORT INFORMATION Proper Shipping Name: Not Regulated SECTION 15: REGULATORY INFORMATION TSCA Status: All components are listed in the TSCA inventory SARA 311/312 Reporting Categories: Acute hazard SARA 313 Reportable Ingredients: No ingredients listed SECTION 16: OTHER INFORMATION Department Issuing SDS Health and Safety Disclaimer While the information provided in this safety data sheet is believed to provide a useful summary of the hazards of Blastox 215 as it is commonly used, the sheet cannot, and does not, anticipate and provide all of the information that might be needed in every situation. In particular, the data furnished in this sheet does not address hazards that may be posed by other materials mixed with Blastox 215 products. Users therefore, should review other applicable safety data sheets before working with Blastox 215. The TDJ Group, Inc. makes no warranty, expressed or implied, concerning the product or the merchantability or fitness thereof for any purpose or concerning the accuracy of any information provided by TDJ Group, Inc., except that the product shall conform to contracted specifications. The information provided herein was believed by TDJ Group, Inc. to be accurate at the time of preparation or prepared from sources believed to be reliable. But it is the responsibility of the user to investigate and understand other pertinent sources of information. To comply with all laws and procedures applicable to the safe handling and use for the product, and to determine the suitability of the product for its intended use. Page 3 of 3 SDS BLASTOX 215 10.15 ANALYTICAL REPORT Eurofins TestAmerica, Chicago 2417 Bond Street University Park, IL 60484 Tel: (708)534-5200 Laboratory Job ID: 500-208623-1 Client Project/Site: Waste Testing Revision: 1 For: TDJ Group, The 18 East Dundee Road Bldg 6 Siote 100 Barrington, Illinois 60010 Attn: James Lively Authorized for release by: 12/9/2021 12:21:27 PM Jodie Bracken, Project Management Assistant II Jodie.Bracken@Eurofinset.com Designee for Jim Knapp, Project Manager II (630)758-0262 Jim.Knapp@Eurofinset.com This report has been electronically signed and authorized by the signatory. Electronic signature is intended to be the legally binding equivalent of a traditionally handwritten signature. Results relate only to the items tested and the sample(s) as received by the laboratory. 1 2 3 4 5 6 7 Case Narrative Client: TDJ Group, The Job ID: 500-208623-1 Project/Site: Waste Testing Job ID: 500-208623-1 Laboratory: Eurofins TestAmerica, Chicago Narrative Job Narrative 500-208623-1 Comments No additional comments. Revision The report being provided is a revision of the original report sent on 12/9/2021. The revision was added to report the requested analytes listed on the chain of custody; TCLP Pb, Cr, and Ni.. Receipt The samples were received on 11/18/2021 11:55 AM. Unless otherwise noted below, the samples arrived in good condition, and where required, properly preserved and on ice. Receipt Exceptions The Chain-of-Custody (COC) was incomplete as received and/or improperly completed. The sample date or time is not listed on the COC or sample container labels. I used the date the samples were relinquished as the sample date. Metals Method 1311: Insufficient samples were provided to perform the leaching procedure with the required 100g for the following samples: G1U4.2.215 (500-208623-1) and C12SS.2.215 (500-208623-2). The volume of leaching fluid was adjusted proportionally to maintain a 20:1 ratio of leaching fluid to weight of sample. Reporting limits (RLs) are not affected. Method 1311: For sample G1U4.2.215 (500-208623-1), the initial pH of the solution was 9. 62 The pH after adding H-Cl was 1. 79 and the final pH after rotation was 5. 31. Method 1311: For sample C12SS.2.215 (500-208623-2), the initial pH of the solution was 11. 58 The pH after adding H-Cl was 1.81 and the final pH after rotation was 5.06. Method 3050B: Elevated reporting limits are provided for the following samples due to insufficient sample provided for preparation/analysis: G1U4.2.215 (500-208623-1) and C12SS.2.215 (500-208623-2). Method 6010C: The following sample was diluted due to the nature of the sample matrix: G1U4.2.215 (500-208623-1). Elevated reporting limits (RLs) are provided. No additional analytical or quality issues were noted, other than those described above or in the Definitions/Glossary page. Eurofins TestAmerica, ChicagoPage 2 of 8 12/9/2021 (Rev. 1) 1 2 3 4 5 6 7 Sample Summary Client: TDJ Group, The Job ID: 500-208623-1 Project/Site: Waste Testing Lab Sample ID Client Sample ID Matrix Collected Received 500-208623-1 G1U4.2.215 Solid 11/17/21 00:00 11/18/21 11:55 500-208623-2 C12SS.2.215 Solid 11/17/21 00:00 11/18/21 11:55 Eurofins TestAmerica, ChicagoPage 3 of 8 12/9/2021 (Rev. 1) 1 2 3 4 5 6 7 Client Sample Results Job ID: 500-208623-1Client: TDJ Group, The Project/Site: Waste Testing Lab Sample ID: 500-208623-1Client Sample ID: G1U4.2.215 Matrix: SolidDate Collected: 11/17/21 00:00 Date Received: 11/18/21 11:55 Method: 6010C - Metals (ICP) RL MDL Chromium 24000 390 mg/Kg 12/08/21 12:31 100 Analyte Dil FacAnalyzedUnit DResult Qualifier Analyst JJB 19 mg/Kg 12/08/21 04:19 10Lead580 JJB 39 mg/Kg 12/08/21 04:19 10Nickel610 JJB Method: 6010C - Metals (ICP) - TCLP RL MDL Chromium 0.19 0.025 mg/L 12/07/21 02:35 1 Analyte Dil FacAnalyzedUnit DResult Qualifier Analyst JJB 0.050 mg/L 12/07/21 02:35 1Lead0.99 JJB 0.025 mg/L 12/07/21 02:35 1Nickel0.37 JJB Eurofins TestAmerica, Chicago Page 4 of 8 12/9/2021 (Rev. 1) 1 2 3 4 5 6 7 Client Sample Results Job ID: 500-208623-1Client: TDJ Group, The Project/Site: Waste Testing Lab Sample ID: 500-208623-2Client Sample ID: C12SS.2.215 Matrix: SolidDate Collected: 11/17/21 00:00 Date Received: 11/18/21 11:55 Method: 6010C - Metals (ICP) RL MDL Chromium 8200 220 mg/Kg 12/08/21 12:35 50 Analyte Dil FacAnalyzedUnit DResult Qualifier Analyst JJB 2.2 mg/Kg 12/08/21 04:22 1Lead310 JJB 4.3 mg/Kg 12/08/21 04:22 1Nickel6700 JJB Method: 6010C - Metals (ICP) - TCLP RL MDL Chromium 0.067 0.025 mg/L 12/07/21 02:38 1 Analyte Dil FacAnalyzedUnit DResult Qualifier Analyst JJB 0.050 mg/L 12/07/21 02:38 1Lead0.20 JJB 0.025 mg/L 12/07/21 02:38 1Nickel6.4 JJB Eurofins TestAmerica, Chicago Page 5 of 8 12/9/2021 (Rev. 1) 1 2 3 4 5 6 7 Accreditation/Certification and Definitions Summary Client: TDJ Group, The Job ID: 500-208623-1 Project/Site: Waste Testing Laboratory: Eurofins TestAmerica, Chicago Unless otherwise noted, all analytes for this laboratory were covered under each accreditation/certification below. Authority Program Identification Number Expiration Date Illinois NELAP IL00035 04-29-22 The following analytes are included in this report, but the laboratory is not certified by the governing authority. This list may include analytes for which the agency does not offer certification. Analysis Method Prep Method Matrix Analyte Moisture Solid Percent Moisture Moisture Solid Percent Solids Glossary These commonly used abbreviations may or may not be present in this report. ¤Listed under the "D" column to designate that the result is reported on a dry weight basis Abbreviation %R Percent Recovery 1C Result is from the primary column on a dual-column method. 2C Result is from the confirmation column on a dual-column method. CFL Contains Free Liquid CFU Colony Forming Unit CNF Contains No Free Liquid DER Duplicate Error Ratio (normalized absolute difference) Dil Fac Dilution Factor DL Detection Limit (DoD/DOE) DL, RA, RE, IN Indicates a Dilution, Re-analysis, Re-extraction, or additional Initial metals/anion analysis of the sample DLC Decision Level Concentration (Radiochemistry) EDL Estimated Detection Limit (Dioxin) LOD Limit of Detection (DoD/DOE) LOQ Limit of Quantitation (DoD/DOE) MCL EPA recommended "Maximum Contaminant Level" MDA Minimum Detectable Activity (Radiochemistry) MDC Minimum Detectable Concentration (Radiochemistry) MDL Method Detection Limit ML Minimum Level (Dioxin) MPN Most Probable Number MQL Method Quantitation Limit NC Not Calculated ND Not Detected at the reporting limit (or MDL or EDL if shown) NEG Negative / Absent POS Positive / Present PQL Practical Quantitation Limit PRES Presumptive QC Quality Control RER Relative Error Ratio (Radiochemistry) RL Reporting Limit or Requested Limit (Radiochemistry) RPD Relative Percent Difference, a measure of the relative difference between two points TEF Toxicity Equivalent Factor (Dioxin) TEQ Toxicity Equivalent Quotient (Dioxin) TNTC Too Numerous To Count Eurofins TestAmerica, Chicago Page 6 of 8 12/9/2021 (Rev. 1) 1 2 3 4 5 6 7 Method Summary Job ID: 500-208623-1Client: TDJ Group, The Project/Site: Waste Testing Method Method Description LaboratoryProtocol SW8466010CMetals (ICP)TAL CHI EPAMoisturePercent Moisture TAL CHI SW8461311Toxicity Characteristic Leaching Procedure TAL CHI SW8463010APreparation, Total Metals TAL CHI SW8463050BPreparation, Metals TAL CHI Protocol References: EPA = US Environmental Protection Agency SW846 = "Test Methods For Evaluating Solid Waste, Physical/Chemical Methods", Third Edition, November 1986 And Its Updates. Laboratory References: TAL CHI = Eurofins TestAmerica, Chicago, 2417 Bond Street, University Park, IL 60484, TEL (708)534-5200 Eurofins TestAmerica, Chicago Page 7 of 8 12/9/2021 (Rev. 1) 1 2 3 4 5 6 7 Page 8 of 8 12/9/2021 (Rev. 1) 1 2 3 4 5 6 7 APPENDIX F Sediment Trap Calculations Mansfield, MA Amherst, MA February 8, 2022 RE: Stormwater Management Plan Cutlery River Bank Remediation OHI Project #13-1515 As part of the Mill River Riverbank Remediation plan, it is proposed that an 11-stall parking facility be installed north of and adjacent to the existing parking lot associated with the former Cutlery Firehouse building. The Site is classified as a redevelopment of a former historic mill complex and the area where the parking facility is proposed is currently a stockpile area for impacted soils which is over a section of the former raceway of the mill complex. The proposed work area encompasses an area of 42,266 sf therefore, a Stormwater Management Permit Waiver Application will be filed with the City of Northampton Department of Public Works. Stormwater runoff from the Site currently flows offsite to the south onto the adjacent former Firehouse property or north and west eventually entering the Mill River. Flows to the south will continue to sheet flow southward across the former Firehouse property onto the property of the former mill complex and into the former tailrace where a sediment trap was installed in 2005 to protect the Mill River. After the installation of the parking facility the existing surface flow patterns will be maintained. The sediment trap will be modified by installing a single row of eight-inch (8”) cmu block to the sediment trap spillway to achieve in excess of the required volume for the increase in impervious area. The sediment trap will be maintained annually under the O&M for the former mill complex. Drainage analysis was performed using the Soil Conservation Service (SCS) TR-55 and TR- 20 methodologies as facilitated by the computer program HydroCAD 10.1 by HydroCAD Software Solutions, LLC. The stormwater model was analysed for performance during 2-, 10- and 100-year frequency rainfall events. The events were based on the 24 -hour, Type-III duration storm. The resulting change in peak runoff rates were 0.30 cfs, 0.40 cfs and 0.50 cfs for the 2-, 10- and 100-year storms, respectively and the resulting change in peak runoff volumes were 942 cf, 1,385 cf and 1,928 cf for the 2-, 10- and 100-year storms, respectively. Although there will be an increase in runoff volume due to the additional impervious area no increase to off-site flooding is anticipated as the remediation of the Mill River embankment will provide an additional 2,051 cf of flood storage volume. 44 Wood Avenue Mansfield, MA 02048 Tel (508) 339-3929 Fax (508) 339-3140 www.ohiengineering.com swcheck • 04/01/08 Stormwater Report Checklist • Page 1 of 8 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands Program Checklist for Stormwater Report A. Introduction Important: When filling out forms on the computer, use only the tab key to move your cursor - do not use the return key. A Stormwater Report must be submitted with the Notice of Intent permit application to document compliance with the Stormwater Management Standards. The following checklist is NOT a substitute for the Stormwater Report (which should provide more substantive and detailed information) but is offered here as a tool to help the applicant organize their Stormwater Management documentation for their Report and for the reviewer to assess this information in a consistent format. As noted in the Checklist, the Stormwater Report must contain the engineering computations and supporting information set forth in Volume 3 of the Massachusetts Stormwater Handbook. The Stormwater Report must be prepared and certified by a Registered Professional Engineer (RPE) licensed in the Commonwealth. The Stormwater Report must include:  The Stormwater Checklist completed and stamped by a Registered Professional Engineer (see page 2) that certifies that the Stormwater Report contains all required submittals.1 This Checklist is to be used as the cover for the completed Stormwater Report.  Applicant/Project Name  Project Address  Name of Firm and Registered Professional Engineer that prepared the Report  Long-Term Pollution Prevention Plan required by Standards 4-6  Construction Period Pollution Prevention and Erosion and Sedimentation Control Plan required by Standard 82  Operation and Maintenance Plan required by Standard 9 In addition to all plans and supporting information, the Stormwater Report must include a brief narrative describing stormwater management practices, including environmentally sensitive site design and LID techniques, along with a diagram depicting runoff through the proposed BMP treatment train. Plans are required to show existing and proposed conditions, identify all wetland resource areas, NRCS soil types, critical areas, Land Uses with Higher Potential Pollutant Loads (LUHPPL), and any areas on the site where infiltration rate is greater than 2.4 inches per hour. The Plans shall identify the drainage areas for both existing and proposed conditions at a scale that enables verification of supporting calculations. As noted in the Checklist, the Stormwater Management Report shall document compliance with each of the Stormwater Management Standards as provided in the Massachusetts Stormwater Handbook. The soils evaluation and calculations shall be done using the methodologies set forth in Volume 3 of the Massachusetts Stormwater Handbook. To ensure that the Stormwater Report is complete, applicants are required to fill in the Stormwater Report Checklist by checking the box to indicate that the specified information has been included in the Stormwater Report. If any of the information specified in the checklist has not been submitted, the applicant must provide an explanation. The completed Stormwater Report Checklist and Certification must be submitted with the Stormwater Report. 1 The Stormwater Report may also include the Illicit Discharge Compliance Statement required by Standard 10. If not included in the Stormwater Report, the Illicit Discharge Compliance Statement must be submitted prior to the discharge of stormwater runoff to the post-construction best management practices. 2 For some complex projects, it may not be possible to include the Construction Period Erosion and Sedimentation Control Plan in the Stormwater Report. In that event, the issuing authority has the discretion to issue an Order of Conditions that approves the project and includes a condition requiring the proponent to submit the Construction Period Erosion and Sedimentation Control Plan before commencing any land disturbance activity on the site. swcheck • 04/01/08 Stormwater Report Checklist • Page 3 of 8 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands Program Checklist for Stormwater Report Checklist (continued) LID Measures: Stormwater Standards require LID measures to be considered. Document what environmentally sensitive design and LID Techniques were considered during the planning and design of the project: No disturbance to any Wetland Resource Areas Site Design Practices (e.g. clustered development, reduced frontage setbacks) Reduced Impervious Area (Redevelopment Only) Minimizing disturbance to existing trees and shrubs LID Site Design Credit Requested: Credit 1 Credit 2 Credit 3 Use of “country drainage” versus curb and gutter conveyance and pipe Bioretention Cells (includes Rain Gardens) Constructed Stormwater Wetlands (includes Gravel Wetlands designs) Treebox Filter Water Quality Swale Grass Channel Green Roof Other (describe): Standard 1: No New Untreated Discharges No new untreated discharges Outlets have been designed so there is no erosion or scour to wetlands and waters of the Commonwealth Supporting calculations specified in Volume 3 of the Massachusetts Stormwater Handbook included. swcheck • 04/01/08 Stormwater Report Checklist • Page 4 of 8 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands Program Checklist for Stormwater Report Checklist (continued) Standard 2: Peak Rate Attenuation Standard 2 waiver requested because the project is located in land subject to coastal storm flowage and stormwater discharge is to a wetland subject to coastal flooding. Evaluation provided to determine whether off-site flooding increases during the 100-year 24-hour storm. Calculations provided to show that post-development peak discharge rates do not exceed pre- development rates for the 2-year and 10-year 24-hour storms. If evaluation shows that off-site flooding increases during the 100-year 24-hour storm, calculations are also provided to show that post-development peak discharge rates do not exceed pre-development rates for the 100-year 24- hour storm. Standard 3: Recharge Soil Analysis provided. Required Recharge Volume calculation provided. Required Recharge volume reduced through use of the LID site Design Credits. Sizing the infiltration, BMPs is based on the following method: Check the method used. Static Simple Dynamic Dynamic Field1 Runoff from all impervious areas at the site discharging to the infiltration BMP. Runoff from all impervious areas at the site is not discharging to the infiltration BMP and calculations are provided showing that the drainage area contributing runoff to the infiltration BMPs is sufficient to generate the required recharge volume. Recharge BMPs have been sized to infiltrate the Required Recharge Volume. Recharge BMPs have been sized to infiltrate the Required Recharge Volume only to the maximum extent practicable for the following reason: Site is comprised solely of C and D soils and/or bedrock at the land surface M.G.L. c. 21E sites pursuant to 310 CMR 40.0000 Solid Waste Landfill pursuant to 310 CMR 19.000 Project is otherwise subject to Stormwater Management Standards only to the maximum extent practicable. Calculations showing that the infiltration BMPs will drain in 72 hours are provided. Property includes a M.G.L. c. 21E site or a solid waste landfill and a mounding analysis is included. 1 80% TSS removal is required prior to discharge to infiltration BMP if Dynamic Field method is used. swcheck • 04/01/08 Stormwater Report Checklist • Page 5 of 8 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands Program Checklist for Stormwater Report Checklist (continued) Standard 3: Recharge (continued) The infiltration BMP is used to attenuate peak flows during storms greater than or equal to the 10- year 24-hour storm and separation to seasonal high groundwater is less than 4 feet and a mounding analysis is provided. Documentation is provided showing that infiltration BMPs do not adversely impact nearby wetland resource areas. Standard 4: Water Quality The Long-Term Pollution Prevention Plan typically includes the following:  Good housekeeping practices;  Provisions for storing materials and waste products inside or under cover;  Vehicle washing controls;  Requirements for routine inspections and maintenance of stormwater BMPs;  Spill prevention and response plans;  Provisions for maintenance of lawns, gardens, and other landscaped areas;  Requirements for storage and use of fertilizers, herbicides, and pesticides;  Pet waste management provisions;  Provisions for operation and management of septic systems;  Provisions for solid waste management;  Snow disposal and plowing plans relative to Wetland Resource Areas;  Winter Road Salt and/or Sand Use and Storage restrictions;  Street sweeping schedules;  Provisions for prevention of illicit discharges to the stormwater management system;  Documentation that Stormwater BMPs are designed to provide for shutdown and containment in the event of a spill or discharges to or near critical areas or from LUHPPL;  Training for staff or personnel involved with implementing Long-Term Pollution Prevention Plan;  List of Emergency contacts for implementing Long-Term Pollution Prevention Plan. A Long-Term Pollution Prevention Plan is attached to Stormwater Report and is included as an attachment to the Wetlands Notice of Intent. Treatment BMPs subject to the 44% TSS removal pretreatment requirement and the one inch rule for calculating the water quality volume are included, and discharge: is within the Zone II or Interim Wellhead Protection Area is near or to other critical areas is within soils with a rapid infiltration rate (greater than 2.4 inches per hour) involves runoff from land uses with higher potential pollutant loads. The Required Water Quality Volume is reduced through use of the LID site Design Credits. Calculations documenting that the treatment train meets the 80% TSS removal requirement and, if applicable, the 44% TSS removal pretreatment requirement, are provided. swcheck • 04/01/08 Stormwater Report Checklist • Page 6 of 8 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands Program Checklist for Stormwater Report Checklist (continued) Standard 4: Water Quality (continued) The BMP is sized (and calculations provided) based on: The ½” or 1” Water Quality Volume or The equivalent flow rate associated with the Water Quality Volume and documentation is provided showing that the BMP treats the required water quality volume. The applicant proposes to use proprietary BMPs, and documentation supporting use of proprietary BMP and proposed TSS removal rate is provided. This documentation may be in the form of the propriety BMP checklist found in Volume 2, Chapter 4 of the Massachusetts Stormwater Handbook and submitting copies of the TARP Report, STEP Report, and/or other third party studies verifying performance of the proprietary BMPs. A TMDL exists that indicates a need to reduce pollutants other than TSS and documentation showing that the BMPs selected are consistent with the TMDL is provided. Standard 5: Land Uses With Higher Potential Pollutant Loads (LUHPPLs) The NPDES Multi-Sector General Permit covers the land use and the Stormwater Pollution Prevention Plan (SWPPP) has been included with the Stormwater Report. The NPDES Multi-Sector General Permit covers the land use and the SWPPP will be submitted prior to the discharge of stormwater to the post-construction stormwater BMPs. The NPDES Multi-Sector General Permit does not cover the land use. LUHPPLs are located at the site and industry specific source control and pollution prevention measures have been proposed to reduce or eliminate the exposure of LUHPPLs to rain, snow, snow melt and runoff, and been included in the long term Pollution Prevention Plan. All exposure has been eliminated. All exposure has not been eliminated and all BMPs selected are on MassDEP LUHPPL list. The LUHPPL has the potential to generate runoff with moderate to higher concentrations of oil and grease (e.g. all parking lots with >1000 vehicle trips per day) and the treatment train includes an oil grit separator, a filtering bioretention area, a sand filter or equivalent. Standard 6: Critical Areas The discharge is near or to a critical area and the treatment train includes only BMPs that MassDEP has approved for stormwater discharges to or near that particular class of critical area. Critical areas and BMPs are identified in the Stormwater Report. swcheck • 04/01/08 Stormwater Report Checklist • Page 7 of 8 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands Program Checklist for Stormwater Report Checklist (continued) Standard 7: Redevelopments and Other Projects Subject to the Standards only to the maximum extent practicable The project is subject to the Stormwater Management Standards only to the maximum Extent Practicable as a: Limited Project Small Residential Projects: 5-9 single family houses or 5-9 units in a multi-family development provided there is no discharge that may potentially affect a critical area. Small Residential Projects: 2-4 single family houses or 2-4 units in a multi-family development with a discharge to a critical area Marina and/or boatyard provided the hull painting, service and maintenance areas are protected from exposure to rain, snow, snow melt and runoff Bike Path and/or Foot Path Redevelopment Project Redevelopment portion of mix of new and redevelopment. Certain standards are not fully met (Standard No. 1, 8, 9, and 10 must always be fully met) and an explanation of why these standards are not met is contained in the Stormwater Report. The project involves redevelopment and a description of all measures that have been taken to improve existing conditions is provided in the Stormwater Report. The redevelopment checklist found in Volume 2 Chapter 3 of the Massachusetts Stormwater Handbook may be used to document that the proposed stormwater management system (a) complies with Standards 2, 3 and the pretreatment and structural BMP requirements of Standards 4-6 to the maximum extent practicable and (b) improves existing conditions. Standard 8: Construction Period Pollution Prevention and Erosion and Sedimentation Control A Construction Period Pollution Prevention and Erosion and Sedimentation Control Plan must include the following information:  Narrative;  Construction Period Operation and Maintenance Plan;  Names of Persons or Entity Responsible for Plan Compliance;  Construction Period Pollution Prevention Measures;  Erosion and Sedimentation Control Plan Drawings;  Detail drawings and specifications for erosion control BMPs, including sizing calculations;  Vegetation Planning;  Site Development Plan;  Construction Sequencing Plan;  Sequencing of Erosion and Sedimentation Controls;  Operation and Maintenance of Erosion and Sedimentation Controls;  Inspection Schedule;  Maintenance Schedule;  Inspection and Maintenance Log Form. A Construction Period Pollution Prevention and Erosion and Sedimentation Control Plan containing the information set forth above has been included in the Stormwater Report. swcheck • 04/01/08 Stormwater Report Checklist • Page 8 of 8 Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands Program Checklist for Stormwater Report Checklist (continued) Standard 8: Construction Period Pollution Prevention and Erosion and Sedimentation Control (continued) The project is highly complex and information is included in the Stormwater Report that explains why it is not possible to submit the Construction Period Pollution Prevention and Erosion and Sedimentation Control Plan with the application. A Construction Period Pollution Prevention and Erosion and Sedimentation Control has not been included in the Stormwater Report but will be submitted before land disturbance begins. The project is not covered by a NPDES Construction General Permit. The project is covered by a NPDES Construction General Permit and a copy of the SWPPP is in the Stormwater Report. The project is covered by a NPDES Construction General Permit but no SWPPP been submitted. The SWPPP will be submitted BEFORE land disturbance begins. Standard 9: Operation and Maintenance Plan The Post Construction Operation and Maintenance Plan is included in the Stormwater Report and includes the following information: Name of the stormwater management system owners; Party responsible for operation and maintenance; Schedule for implementation of routine and non-routine maintenance tasks; Plan showing the location of all stormwater BMPs maintenance access areas; Description and delineation of public safety features; Estimated operation and maintenance budget; and Operation and Maintenance Log Form. The responsible party is not the owner of the parcel where the BMP is located and the Stormwater Report includes the following submissions: A copy of the legal instrument (deed, homeowner’s association, utility trust or other legal entity) that establishes the terms of and legal responsibility for the operation and maintenance of the project site stormwater BMPs; A plan and easement deed that allows site access for the legal entity to operate and maintain BMP functions. Standard 10: Prohibition of Illicit Discharges The Long-Term Pollution Prevention Plan includes measures to prevent illicit discharges; An Illicit Discharge Compliance Statement is attached; NO Illicit Discharge Compliance Statement is attached but will be submitted prior to the discharge of any stormwater to post-construction BMPs. EXISTING AP1 Routing Diagram for Cutlery Prepared by OHI Engineering, Inc., Printed 2/8/2022 HydroCAD® 10.10-4b s/n 11276 © 2020 HydroCAD Software Solutions LLC Subcat Reach Pond Link Cutlery Printed 2/8/2022Prepared by OHI Engineering, Inc. Page 2HydroCAD® 10.10-4b s/n 11276 © 2020 HydroCAD Software Solutions LLC Area Listing (all nodes) Area (sq-ft) CN Description (subcatchment-numbers) 6,702 61 >75% Grass cover, Good, HSG B (EXISTING) 35,296 98 Pavement & Roof (EXISTING) Type III 24-hr 2-Year Rainfall=3.00"Cutlery Printed 2/8/2022Prepared by OHI Engineering, Inc. Page 3HydroCAD® 10.10-4b s/n 11276 © 2020 HydroCAD Software Solutions LLC Summary for Subcatchment EXISTING: Runoff = 2.34 cfs @ 12.09 hrs, Volume= 7,564 cf, Depth= 2.16" Runoff by SCS TR-20 method, UH=SCS, Weighted-CN, Time Span= 1.00-72.00 hrs, dt= 0.05 hrs Type III 24-hr 2-Year Rainfall=3.00" Area (sf) CN Description 6,702 61 >75% Grass cover, Good, HSG B * 35,296 98 Pavement & Roof 41,998 92 Weighted Average 6,702 15.96% Pervious Area 35,296 84.04% Impervious Area Tc Length Slope Velocity Capacity Description (min) (feet) (ft/ft) (ft/sec) (cfs) 6.0 Direct Entry, Segment A Summary for Link AP1: Inflow Area = 41,998 sf, 84.04% Impervious, Inflow Depth = 2.16" for 2-Year event Inflow =2.34 cfs @ 12.09 hrs, Volume= 7,564 cf Primary = 2.34 cfs @ 12.09 hrs, Volume= 7,564 cf, Atten= 0%, Lag= 0.0 min Primary outflow = Inflow, Time Span= 1.00-72.00 hrs, dt= 0.05 hrs Type III 24-hr 10-Year Rainfall=4.50"Cutlery Printed 2/8/2022Prepared by OHI Engineering, Inc. Page 4HydroCAD® 10.10-4b s/n 11276 © 2020 HydroCAD Software Solutions LLC Summary for Subcatchment EXISTING: Runoff = 3.80 cfs @ 12.09 hrs, Volume= 12,607 cf, Depth= 3.60" Runoff by SCS TR-20 method, UH=SCS, Weighted-CN, Time Span= 1.00-72.00 hrs, dt= 0.05 hrs Type III 24-hr 10-Year Rainfall=4.50" Area (sf) CN Description 6,702 61 >75% Grass cover, Good, HSG B * 35,296 98 Pavement & Roof 41,998 92 Weighted Average 6,702 15.96% Pervious Area 35,296 84.04% Impervious Area Tc Length Slope Velocity Capacity Description (min) (feet) (ft/ft) (ft/sec) (cfs) 6.0 Direct Entry, Segment A Summary for Link AP1: Inflow Area = 41,998 sf, 84.04% Impervious, Inflow Depth = 3.60" for 10-Year event Inflow =3.80 cfs @ 12.09 hrs, Volume= 12,607 cf Primary = 3.80 cfs @ 12.09 hrs, Volume= 12,607 cf, Atten= 0%, Lag= 0.0 min Primary outflow = Inflow, Time Span= 1.00-72.00 hrs, dt= 0.05 hrs Type III 24-hr 100-Year Rainfall=6.40"Cutlery Printed 2/8/2022Prepared by OHI Engineering, Inc. Page 5HydroCAD® 10.10-4b s/n 11276 © 2020 HydroCAD Software Solutions LLC Summary for Subcatchment EXISTING: Runoff = 5.63 cfs @ 12.09 hrs, Volume= 19,120 cf, Depth= 5.46" Runoff by SCS TR-20 method, UH=SCS, Weighted-CN, Time Span= 1.00-72.00 hrs, dt= 0.05 hrs Type III 24-hr 100-Year Rainfall=6.40" Area (sf) CN Description 6,702 61 >75% Grass cover, Good, HSG B * 35,296 98 Pavement & Roof 41,998 92 Weighted Average 6,702 15.96% Pervious Area 35,296 84.04% Impervious Area Tc Length Slope Velocity Capacity Description (min) (feet) (ft/ft) (ft/sec) (cfs) 6.0 Direct Entry, Segment A Summary for Link AP1: Inflow Area = 41,998 sf, 84.04% Impervious, Inflow Depth = 5.46" for 100-Year event Inflow =5.63 cfs @ 12.09 hrs, Volume= 19,120 cf Primary = 5.63 cfs @ 12.09 hrs, Volume= 19,120 cf, Atten= 0%, Lag= 0.0 min Primary outflow = Inflow, Time Span= 1.00-72.00 hrs, dt= 0.05 hrs PROPOSED AP1 Routing Diagram for Cutlery-Post Prepared by OHI Engineering, Inc., Printed 2/8/2022 HydroCAD® 10.10-4b s/n 11276 © 2020 HydroCAD Software Solutions LLC Subcat Reach Pond Link Cutlery-Post Printed 2/8/2022Prepared by OHI Engineering, Inc. Page 2HydroCAD® 10.10-4b s/n 11276 © 2020 HydroCAD Software Solutions LLC Area Listing (all nodes) Area (sq-ft) CN Description (subcatchment-numbers) 6,132 61 >75% Grass cover, Good, HSG B (PROPOSED) 39,151 98 Pavement & Roof (PROPOSED) Type III 24-hr 2-Year Rainfall=3.00"Cutlery-Post Printed 2/8/2022Prepared by OHI Engineering, Inc. Page 3HydroCAD® 10.10-4b s/n 11276 © 2020 HydroCAD Software Solutions LLC Summary for Subcatchment PROPOSED: Runoff = 2.61 cfs @ 12.09 hrs, Volume= 8,506 cf, Depth= 2.25" Runoff by SCS TR-20 method, UH=SCS, Weighted-CN, Time Span= 1.00-72.00 hrs, dt= 0.05 hrs Type III 24-hr 2-Year Rainfall=3.00" Area (sf) CN Description 6,132 61 >75% Grass cover, Good, HSG B * 39,151 98 Pavement & Roof 45,283 93 Weighted Average 6,132 13.54% Pervious Area 39,151 86.46% Impervious Area Tc Length Slope Velocity Capacity Description (min) (feet) (ft/ft) (ft/sec) (cfs) 6.0 Direct Entry, Segment A Summary for Link AP1: Inflow Area = 45,283 sf, 86.46% Impervious, Inflow Depth = 2.25" for 2-Year event Inflow =2.61 cfs @ 12.09 hrs, Volume= 8,506 cf Primary = 2.61 cfs @ 12.09 hrs, Volume= 8,506 cf, Atten= 0%, Lag= 0.0 min Primary outflow = Inflow, Time Span= 1.00-72.00 hrs, dt= 0.05 hrs Type III 24-hr 10-Year Rainfall=4.50"Cutlery-Post Printed 2/8/2022Prepared by OHI Engineering, Inc. Page 4HydroCAD® 10.10-4b s/n 11276 © 2020 HydroCAD Software Solutions LLC Summary for Subcatchment PROPOSED: Runoff = 4.18 cfs @ 12.09 hrs, Volume= 13,992 cf, Depth= 3.71" Runoff by SCS TR-20 method, UH=SCS, Weighted-CN, Time Span= 1.00-72.00 hrs, dt= 0.05 hrs Type III 24-hr 10-Year Rainfall=4.50" Area (sf) CN Description 6,132 61 >75% Grass cover, Good, HSG B * 39,151 98 Pavement & Roof 45,283 93 Weighted Average 6,132 13.54% Pervious Area 39,151 86.46% Impervious Area Tc Length Slope Velocity Capacity Description (min) (feet) (ft/ft) (ft/sec) (cfs) 6.0 Direct Entry, Segment A Summary for Link AP1: Inflow Area = 45,283 sf, 86.46% Impervious, Inflow Depth = 3.71" for 10-Year event Inflow =4.18 cfs @ 12.09 hrs, Volume= 13,992 cf Primary = 4.18 cfs @ 12.09 hrs, Volume= 13,992 cf, Atten= 0%, Lag= 0.0 min Primary outflow = Inflow, Time Span= 1.00-72.00 hrs, dt= 0.05 hrs Type III 24-hr 100-Year Rainfall=6.40"Cutlery-Post Printed 2/8/2022Prepared by OHI Engineering, Inc. Page 5HydroCAD® 10.10-4b s/n 11276 © 2020 HydroCAD Software Solutions LLC Summary for Subcatchment PROPOSED: Runoff = 6.14 cfs @ 12.09 hrs, Volume= 21,048 cf, Depth= 5.58" Runoff by SCS TR-20 method, UH=SCS, Weighted-CN, Time Span= 1.00-72.00 hrs, dt= 0.05 hrs Type III 24-hr 100-Year Rainfall=6.40" Area (sf) CN Description 6,132 61 >75% Grass cover, Good, HSG B * 39,151 98 Pavement & Roof 45,283 93 Weighted Average 6,132 13.54% Pervious Area 39,151 86.46% Impervious Area Tc Length Slope Velocity Capacity Description (min) (feet) (ft/ft) (ft/sec) (cfs) 6.0 Direct Entry, Segment A Summary for Link AP1: Inflow Area = 45,283 sf, 86.46% Impervious, Inflow Depth = 5.58" for 100-Year event Inflow =6.14 cfs @ 12.09 hrs, Volume= 21,048 cf Primary = 6.14 cfs @ 12.09 hrs, Volume= 21,048 cf, Atten= 0%, Lag= 0.0 min Primary outflow = Inflow, Time Span= 1.00-72.00 hrs, dt= 0.05 hrs APPENDIX G Laboratory Results 39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 September 24, 2021 Lyons Witten OHI Engineering, Inc. - Amherst 110 Pulpit Hill Road Amherst, MA 01002 Project Location: Noho, MA Client Job Number: Project Number: 13-1515 Laboratory Work Order Number: 21I0777 Enclosed are results of analyses for samples received by the laboratory on September 15, 2021. If you have any questions concerning this report, please feel free to contact me. Sincerely, Scott C. Basal Project Manager Page 1 of 11 Table of Contents Table of Contents Sample Summary 3 Case Narrative 4 Sample Results 5 21I0777-01 5 Sample Preparation Information 6 QC Data 7 Metals Analyses (Total) 7 B290636 7 Flag/Qualifier Summary 9 Certifications 10 Chain of Custody/Sample Receipt 11 Page 2 of 11 Table of Contents 39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 ANALYTICAL SUMMARY 9/24/2021 OHI Engineering, Inc. - Amherst 110 Pulpit Hill Road Amherst, MA 01002 ATTN: Lyons Witten 13-1515 21I0777 The results of analyses performed on the following samples submitted to CON-TEST, a Pace Analytical Laboratory, are found in this report. PROJECT LOCATION: PURCHASE ORDER NUMBER: PROJECT NUMBER: REPORT DATE: WORK ORDER NUMBER: FIELD SAMPLE #LAB ID:MATRIX TESTSAMPLE DESCRIPTION SUB LAB Noho, MA WOOD CHIPS 21I0777-01 Product/Solid SW-846 6010D [TOC_1]Sample Summary[TOC] Page 3 of 11 Table of Contents 39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 CASE NARRATIVE SUMMARY All reported results are within defined laboratory quality control objectives unless listed below or otherwise qualified in this report. [TOC_1]Case Narrative[TOC] The results of analyses reported only relate to samples submitted to Con-Test, a Pace Analytical Laboratory, for testing. I certify that the analyses listed above, unless specifically listed as subcontracted, if any, were performed under my direction according to the approved methodologies listed in this document, and that based upon my inquiry of those individuals immediately responsible for obtaining the information, the material contained in this report is, to the best of my knowledge and belief, accurate and complete. Lisa A. Worthington Technical Representative Page 4 of 11 Table of Contents 39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Date Received: 9/15/2021 Work Order: 21I0777Sample Description:Project Location: Noho, MA Sample ID: 21I0777-01 Field Sample #: WOOD CHIPS Sample Matrix: Product/Solid Sampled: 9/14/2021 09:00 [TOC_2]21I0777-01[TOC] AnalystAnalyzedDilutionFlag/QualRLResultsAnalyte Date/Time Units Date PreparedMethod Metals Analyses (Total) ND 1.6 9/23/21 15:20 QNWmg/Kg 9/20/21SW-846 6010D1Antimony ND 3.3 9/23/21 15:20 QNWmg/Kg 9/20/21SW-846 6010D1Arsenic 44 1.6 9/23/21 15:20 QNWmg/Kg 9/20/21SW-846 6010D1Barium ND 0.16 9/23/21 22:58 QNWmg/Kg 9/20/21SW-846 6010D1Beryllium ND 0.33 9/23/21 15:20 QNWmg/Kg 9/20/21SW-846 6010D1Cadmium ND 0.66 9/23/21 15:20 QNWmg/Kg 9/20/21SW-846 6010D1Chromium 0.85 0.49 9/23/21 15:20 QNWmg/Kg 9/20/21SW-846 6010D1Lead 9.3 0.66 9/23/21 15:20 QNWmg/Kg 9/20/21SW-846 6010D1Nickel ND 3.3 9/23/21 15:20 QNWmg/Kg 9/20/21SW-846 6010D1Selenium ND 0.33 9/24/21 13:26 QNWmg/Kg 9/20/21SW-846 6010D1Silver ND 1.6 9/23/21 15:20 QNWmg/Kg 9/20/21SW-846 6010D1Thallium ND 0.66 9/23/21 15:20 QNWmg/Kg 9/20/21SW-846 6010D1Vanadium 25 0.66 9/23/21 15:20 QNWmg/Kg 9/20/21SW-846 6010D1Zinc [TOC_1]Sample Results[TOC] Page 5 of 11 Table of Contents 39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Sample Extraction Data Prep Method: SW-846 3050B Analytical Method: SW-846 6010D Lab Number [Field ID]Batch DateInitial [g]Final [mL] B290636 09/20/211.52 50.021I0777-01 [WOOD CHIPS] [TOC_1]Sample Preparation Information[TOC] Page 6 of 11 Table of Contents 39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Result Limit Reporting Units Level Spike Result Source %REC %REC Limits RPD RPD Limit Notes Analyte Metals Analyses (Total) - Quality Control QUALITY CONTROL [TOC_2]Metals Analyses (Total)[TOC] Batch B290636 - SW-846 3050B [TOC_3]B290636[TOC] Blank (B290636-BLK1) Prepared: 09/20/21 Analyzed: 09/23/21 Antimony mg/Kg1.7ND Arsenic mg/Kg3.3ND Barium mg/Kg1.7ND Beryllium mg/Kg0.17ND Cadmium mg/Kg0.33ND Chromium mg/Kg0.67ND Lead mg/Kg0.50ND Nickel mg/Kg0.67ND Selenium mg/Kg3.3ND Silver mg/Kg0.33ND Thallium mg/Kg1.7ND Vanadium mg/Kg0.67ND Zinc mg/Kg0.67ND LCS (B290636-BS1) Prepared: 09/20/21 Analyzed: 09/23/21 Antimony mg/Kg4.8 134 1.9-200.784.0113 Arsenic mg/Kg9.6 170 82.9-117.693.4159 Barium mg/Kg4.8 183 82.5-117.598.2180 Beryllium mg/Kg0.48 116 83.4-116.495.9111 Cadmium mg/Kg0.96 89.5 82.8-117.399.388.9 Chromium mg/Kg1.9 101 82.1-117.896.397.3 Lead mg/Kg1.4 140 82.9-117.196.3135 Nickel mg/Kg1.9 68.3 82.1-117.798.967.5 Selenium mg/Kg9.6 182 79.7-120.396.9176 Silver mg/Kg0.96 50.1 80.2-12097.548.8 Thallium mg/Kg4.8 87.7 81.1-118.610390.1 Vanadium mg/Kg1.9 153 79.1-120.997.2149 Zinc mg/Kg1.9 228 80.7-118.996.3220 LCS Dup (B290636-BSD1) Prepared: 09/20/21 Analyzed: 09/23/21 Antimony mg/Kg4.8 134 301.9-200.781.4 3.17109 Arsenic mg/Kg9.6 170 3082.9-117.692.1 1.38157 Barium mg/Kg4.8 183 2082.5-117.595.8 2.51175 Beryllium mg/Kg0.48 116 3083.4-116.496.7 0.810112 Cadmium mg/Kg0.96 89.5 2082.8-117.399.5 0.22389.1 Chromium mg/Kg1.9 101 3082.1-117.894.4 2.0295.3 Lead mg/Kg1.4 140 3082.9-117.195.4 0.916134 Nickel mg/Kg1.9 68.3 3082.1-117.797.6 1.3466.6 Selenium mg/Kg9.6 182 3079.7-120.395.8 1.14174 Silver mg/Kg0.96 50.1 3080.2-12097.6 0.12348.9 Thallium mg/Kg4.8 87.7 3081.1-118.6102 0.99589.2 Vanadium mg/Kg1.9 153 3079.1-120.996.1 1.15147 Zinc mg/Kg1.9 228 3080.7-118.995.8 0.467218 [TOC_1]QC Data[TOC] Page 7 of 11 Table of Contents 39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 Result Limit Reporting Units Level Spike Result Source %REC %REC Limits RPD RPD Limit Notes Analyte Metals Analyses (Total) - Quality Control QUALITY CONTROL Batch B290636 - SW-846 3050B Reference (B290636-SRM1) MRL Check Prepared: 09/20/21 Analyzed: 09/23/21 Lead mg/Kg0.50 0.496 80-12087.60.434 Page 8 of 11 Table of Contents 39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 FLAG/QUALIFIER SUMMARY *QC result is outside of established limits. Wide recovery limits established for difficult compound. Wide RPD limits established for difficult compound. #Data exceeded client recommended or regulatory level Percent recoveries and relative percent differences (RPDs) are determined by the software using values in the calculation which have not been rounded. No results have been blank subtracted unless specified in the case narrative section. RL Reporting Limit is at the level of quantitation (LOQ) DL Detection Limit is the lower limit of detection determined by the MDL study MCL Maximum Contaminant Level ND Not Detected [TOC_1]Flag/Qualifier Summary[TOC] Page 9 of 11 Table of Contents 39 Spruce Street * East Longmeadow, MA 01028 * FAX 413/525-6405 * TEL. 413/525-2332 CertificationsAnalyte CERTIFICATIONS Certified Analyses included in this Report SW-846 6010D in Product/Solid CT,NH,NY,ME,VA,NCAntimony CT,NH,NY,ME,VA,NCArsenic CT,NH,NY,ME,VA,NCBarium CT,NH,NY,ME,VA,NCBeryllium CT,NH,NY,ME,VA,NCCadmium CT,NH,NY,ME,VA,NCChromium CT,NH,NY,ME,VA,NCLead CT,NH,NY,ME,VA,NCNickel CT,NH,NY,ME,VA,NCSelenium CT,NH,NY,ME,VA,NCSilver CT,NH,NY,ME,VA,NCThallium CT,NH,NY,ME,VA,NCVanadium CT,NH,NY,ME,VA,NCZinc [TOC_1]Certifications[TOC] Con-Test, a Pace Environmental Laboratory, operates under the following certifications and accreditations: Code Description Number Expires 100033AIHA-LAP, LLC - ISO17025:2017AIHA 03/1/2022 M-MA100Massachusetts DEPMA 06/30/2022 PH-0165Connecticut Department of Publilc HealthCT 12/31/2022 10899 NELAPNew York State Department of HealthNY 04/1/2022 2516 NELAPNew Hampshire Environmental LabNH-S 02/5/2022 LAO00112Rhode Island Department of HealthRI 12/30/2021 652North Carolina Div. of Water QualityNC 12/31/2021 MA007 NELAPNew Jersey DEPNJ 06/30/2022 E871027 NELAPFlorida Department of HealthFL 06/30/2022 LL720741Vermont Department of Health Lead LaboratoryVT 07/30/2022 MA00100State of MaineME 06/9/2023 460217Commonwealth of VirginiaVA 12/14/2021 2557 NELAPNew Hampshire Environmental LabNH-P 09/6/2022 VT-255716Vermont Department of Health Drinking WaterVT-DW 06/12/2022 25703North Carolina Department of HealthNC-DW 07/31/2022 68-05812Commonwealth of Pennsylvania DEPPA 06/30/2022 9100Dept. of Env, Great Lakes, and EnergyMI 09/6/2021 Page 10 of 11 Table of Contents Page 11 of 11 Table of Contents APPENDIX H Health & Safety Plan Health & Safety Plan RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive January 18, 2022 Page 1 of 16 Northampton, MA Health & Safety Plan – Cover Page OHI Project Number & Name: #13-1515 Former Cutlery Raceway Location: 320-360 Riverside Drive, Northampton, MA OHI Engineering, Inc. Contacts: Lyons Witten, Project Manager (413) 835-0780 (w) (413) 262-4009 (mobile) Alex Gamble, Project Scientist (413) 835-0780 (w) (978) 806-5950 (mobile) Client Contacts: Alan Verson Phone # (413) 586-1348 90 Conz Street, Northampton, MA Chemical Hazards Identification: Metals arsenic and chromium exceed imminent hazard concentrations. Additional Recognized Hazards On-site: Other contaminants include: lead, nickel, antimony, beryllium, thallium, PCBs, and EPH. Utilities OHI Engineering DIG SAFE Contractor ID Number: 73643 DIG SAFE Telephone Number: 1-888-344-7233 or 811 Utilities Notified by DIG SAFE: Mass Electric, Bay State Gas, Verizon Day and Time of Approval to Start July 22, 2022 after 12:15 PM # 2022-xxxxxxxxx Water and Sewer Department: Trench Permit #2935 Notified 7/17/22, and applied for Trench Permit. Emergency Information and Phone Numbers Town (state name of agency): Northampton DPW (413) 587-1570 (413) 587-1576 (fax) Nearest Telephone to Job Site: in Site building or with SSO 413-262-4009 Fire Dept / Police / Ambulance: 911 Massachusetts Poison Control Center (24 hours): 1-800-682-9211 National Response Center: 1-800-424-8802 MassDEP Emergency Response (Western Region) 1-413-784-1100 x 246 1-413-755-2246 In the event of a fire or explosion, the Fire Department must be notified as soon as possible. In the event that a medical emergency occurs, call an ambulance. Cooley Dickinson Hospital Emergency Number: 911 Directions to Hospital: exit Site to the right and follow Riverside Drive until it ends at the intersection with Elm Street. Turn right on Elm Street and follow it to the top of the hill. At the Intersection of Route 9 (about one block), turn left, and proceed approximately three blocks to the traffic light at the hospital. Turn left into the hospital driveway and the emergency entrance is straight ahead. (See Figure 1, next page). Google Maps Figure 1Route to Hospitalwww.ohiengineering.com  44 Wood AveMansfield, MA Phone (508) 339-3929Fax (508) 339-3140 110 Pulpit Hill RdAmherst, MA Phone (413) 835-0780Fax (413) 549-7918 LatitudeLongitude Data Source: OHI Project #13-1515 Former Cutlery320-360 Riverside DriveNorthampton, MA Rev. Date: January 19, 2022 N 42° 19' 13.4 N72° 39' 54.7" W SITE HOSPITAL Health & Safety Plan RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive January 18, 2022 Page 3 of 16 Northampton, MA TABLE OF CONTENTS 1.0 Introduction 2.0 Organization and Safety Responsibilities 3.0 Site Characterization and Analysis 4.0 Site Control Measures 5.0 Personal Protective Equipment 6.0 Decontamination 7.0 Emergency/Contingency Planning 8.0 Record keeping, Logs and Reports Appendices: S.O.P. #1 - Personal Protective Equipment Program S.O.P. #2 - Respiratory Protective Program S.O.P. #3 - First Aid for Heat Stress and Cold Stress S.O.P. #4 - Confined Space Entry S.O.P. #5 - Materials Handling S.O.P. #6 - Heavy Equipment Operation S.O.P. #7 - Underground Utilities/Electrical Hazards Health & Safety Plan RTN #1-13320 Former Cutlery Raceway OHI Project #13-1515 360 Riverside Drive January 18, 2022 Page 1 of 16 Northampton, MA SECTION 1 - INTRODUCTION 1.1 Introduction The purpose of this site-specific Worker Health and Safety Program (HASP) is to establish in detail the procedures and protocols necessary for protecting all site workers and the general public from hazards associated with the proposed work activities, specifically: placement of log mats, tree removal, soil excavation, stone wall repair & reconstruction, sewer manhole riser installations, installation of rip-rap, soil stabilization, placement of stone and sheet materials, installation of pavement and fencing. This HASP is limited to the above mentioned site activities. The provisions of this HASP shall apply to all employees, their subcontractors, state and federal regulatory personnel and site visitors who will potentially be exposed to safety and/or health hazards related to site activities. Personnel who are unable or unwilling to comply with the requirements of this HASP will not be permitted to work on the job site. Subcontractors may develop their own HASP provided it is consistent with this HASP and provides at least the same level of employee protection. This HASP has been written to comply with specific state and federal regulations regarding health and safety. 1.2 Statement of Safety and Health Policy This HASP is intended to provide site specific procedures to address known hazardous conditions and potentially hazardous conditions that may be encountered at the site. Site activities in conjunction with this project may pose unique safety, chemical, and/or physical hazards which require specialized expertise to address. The Emergency Response Plan addresses hazards that have not been identified or anticipated. The HASP is intended to establish in detail the protocols necessary for protecting workers, on- site personnel, visitors and potential off-site receptors from potential hazards encountered during work activities. This HASP addresses all topics required by OSHA 29 CFR 1910.120(b)(4) and 1926.65(b)(4). The objectives of this document include but are not limited to: • Statement of Safety and Health Policy • Site Description and Contamination Characterization • Safety and Health Risk Analysis and Activity Hazard Analysis • Regulations • Staff Organization/Administration • Hazard Communication Training • Medical Surveillance • Exposure Monitoring • Health and Safety Equipment • Standard Operating Procedures • Identification and evaluation of potential and unanticipated hazards • Definition of levels of protection required for certain work activities • Establishment of work zones • Formation of emergency action plans • Development of personnel training • Development of decontamination procedures (personal and equipment) • Heat and Cold Stress • Emergency Equipment and First Aid Requirements • Spills Containment Program Logs, Reports and Record keeping • Inspections and Audits • Permit Required Confined Space Entry Program OHI Engineering, Inc. views the HASP as an important document which is necessary to the success of the work activities. Every effort has been made to ensure that the HASP will be in compliance with applicable federal, state and local regulations and is consistent with the requirements of the specifications. The purpose and intent of the HASP is to ensure that the site work is conducted in a safe manner. The on-going program will be directed at recognizing and dealing with the specific hazards at the site as needed to protect employees. Along with site personnel safety, a second major objective is to perform site operations in such a manner as to minimize the possibility of fire, explosion, or any unplanned or sudden release of hazardous waste contaminants into the environment which could adversely affect local receptors. The HASP has been developed to meet these essential objectives and ensure the safe execution of this project. The HASP is a dynamic document and will be reviewed and modified throughout the duration of the project at the site work, to ensure flexibility and adaptability as changes occur and new situations develop. Any changes to the plan will be brought to the attention of those covered under the plan through additional training. Several Standard Operating Procedures (SOPs) are attached to this HASP for preventing accidents and protecting personnel from injury and occupational illness for all operations having significant accident potential. These procedures are required to be read and observed by all workers, on-site personnel and visitors to the site. These SOP’s are generic in nature and may be modified to fit the specific needs of this project. 1.2 Applicable Regulatory Requirements The site-specific HASP shall be consistent with the requirements of: 1. Occupational Safety and Health Administration (OSHA) Standards and Regulations contained in Title 29, Code of Federal Regulations, Parts 1910 and 1926 (29 CFR 1910 and 1926) including amendments as stated in Federal Register March 6, 1989: 9294-9336 (Final Rule, 29.CFR 1910.120 "Hazardous Waste Operations and Emergency Response"). 2. United States Environmental Protection Agency (EPA) Standard Operating Safety Guidelines, Office of Emergency and Remedial Response, Hazardous Response Support Division. Revised November 1984. 3. National Institute of Occupational Safety and Health NIOSH/OSHA/USCG/EPA Occupational Safety and Health Guidance (OSHG) Manual for Hazardous Site Activities, October 1985, Department of Health and Human Services (DHHS), NIOSH Publ. No. 85-115. 4. Massachusetts Department of Environmental Protection Policy: a. 310 CMR 7.00 “Air Pollution Control” b. 310 CMR 30.00 “Hazardous Waste Regulations” c. 310 CMR 40.00 “Massachusetts Contingency Plan” d. 310 CMR 19.00 - “Solid Waste Management Regulations” e. 314 CMR 1.00 - 30.00 “Water Pollution Control Regulations” 5. 454 CMR 11.00 Commonwealth of Massachusetts Construction Industry Rules and Regulations for Structural Painting Safety Code. Other federal regulations, codified in the Code of Federal Regulations, and consensus standards developed by ANSI and ACGIH are referenced in the HASP. These include: ACGIH: (2004) Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices. ANSI Z358.1 (1990) Emergency Eyewash and Shower Equipment 29 CFR 1904: Recording and Reporting Occupational Safety and Health Injuries and Illnesses. 29 CFR 1910: General Industry Standards 29 CFR 1926: Construction Industry Standards 29 CFR 1926.65 Hazardous Waste Operations and Emergency Response 40 CFR 260-270 EPA Hazardous Waste Regulations 40 CFR 50 National Primary and Secondary Ambient Air Quality Standards 49 CFR 172 Department of Transportation Hazardous Materials Tables, Special Provisions, Hazardous Materials Communications, Emergency Response Information, and Training Requirements.(For transporters of hazardous waste) 1.3 Minimum Requirements This HASP shall include the following subject areas: a. Site Description and Evaluation b. Names of key personnel for site safety and health c. Health and Safety Assessment and Risk Analysis for each site task d. Training & Education e. Personal Protective Equipment f. Medical Surveillance g. Air Monitoring h. SOP's, Engineering Controls I. Site Control Measures j. Personnel Hygiene and Decontamination k. Logs, Reports, and Housekeeping l. Emergency Equipment and First Aid m. Emergency Response Plan n. Heat/Cold Stress Monitoring o. Vapor Control p. Fire/Explosion q. Temporary Facilities r. Site Control s. Action Levels and Responses SECTION 2 - ORGANIZATION AND SAFETY RESPONSIBILITY 2.1 Introduction Implementation of the comprehensive safety and health program is a key management responsibility. The HASP will include a listing of health/safety personnel, and a description of their specific responsibilities for implementation of the program. Clear lines of authority, consistent with good operating policies and procedures, have been established for enforcing safety compliance. The qualifications of the site safety and health personnel are included in the appendices. 2.2 Line Management/Chain-of-Command The Project Superintendent will have overall responsibility for contractual matters, scheduling and field management of the project. 2.3 Site Safety and Health Officer (SSHO) The Site Safety and Health Officer (SSHO) will be on-site when this plan is implemented or when the potential exists for employees to be exposed to hazardous materials in excess of the regulatory limits. The SSHO has considerable experience at sites where potentially hazardous materials are present. The SSHO will monitor work locations for employee health and safety purposes, as well as document any employee exposures and/or substance releases that may occur through the course of this project. The SSHO is trained and experienced to be proficient in the proper use and limitations of all equipment that they may be utilizing. The SSHO is responsible for operating the equipment, assisting in implementing the HASP and performing any other duties assigned to them. The SSHO is also to be empowered to deny access to the site or restrict the presence of any persons (under their control), and also has the authority to cease activities on-site if and when conditions present uncontrollable risks to site personnel and off-site receptors. The SSHO shall also be responsible for coordinating, conducting and documenting any required training activities, performing and maintaining record keeping duties, and carrying out any other duties specified by site management. The SSHO will be the main contact for any on-site emergency situation. Except in an emergency, the SSHO may modify the approved HASP. The SSHO will be familiar with all matters pertinent to this project and shall assist and represent the implementation of the HASP as required. This includes field supervision; maintaining contamination control zones; enforcing safe work practices and decontamination procedures; ensuring proper use of personal protective equipment; and communicating modified safety requirements to site personnel. 2.4 Work site Safety Conference Following site mobilization and prior to the start of work, the Contractor shall conduct a safety conference to discuss the hazards anticipated on the site, training on hazard recognition, response to emergencies, explanation of site activities, furnishing safety supplies, identifying safety personnel, decontamination procedures, levels of PPE required, air monitoring activities, and other topics deemed relevant to the safety of the site workers. 2.5 Training and Site Briefing/Education The Contractor will present a safety briefing to inform employees and visitors who will be performing work in or entering the Exclusion Zones (EZ) or Contaminant Reduction Zones (CRZ) during field operations. This briefing will cover the special hazards and procedures to control these hazards. All on-site personnel shall complete this briefing before working in identified portions of the site. A copy of training records for all workers completing this training shall be kept on-site. Copies of the training records for all workers associated with the project will be made available upon request. All workers and visitors shall sign a daily log before entering the active work zones. The locations of the CRZ and EZ areas are identified by the nature of the hazardous material, if any, encountered during the soil excavations. A copy of the records will become a part of the permanent project documentation. 2.5.1. Training Requirements All site personnel and visitors who will be entering any of the EZ or CRZ areas once the HASP is in effect will be required to provide proof of having received training for hazardous materials. In the event workers are exposed or potentially exposed to hazardous materials in excess of the OSHA PEL, then training which meets the initial 40-hour and current annual 8-hour refresher training for hazardous waste site workers as described in 29 CFR 1910.120 and 29 CFR 1926.65 will be required. All site personnel are required to have Hazard Communication Training which meets the OSHA Construction Industry requirements detailed in 29 CFR 1926.59. Proof of this training for each worker will be provided as necessary. Workers who will be incidental to the site work, such as truck drivers and heavy equipment operators who will be involved in work activities but who will remain in their vehicles do not require Hazard Communication training but will be required to attend a site safety briefing from the SSHO. 2.5.2. Site Safety and Health Briefing Personnel covered by this HASP will be required to read and understand this document. Prior to any on-site activity involving work, all on-site personnel will be required to attend a site safety and health briefing from the SSHO or other designated, qualified person. This is applicable to all on-site personnel located within the Exclusion, Contaminant Reduction, and Support Zones who are involved with site work and who will enter either the Exclusion or Contamination Reduction Zones. Periodic updates will be undertaken by the SSHO when operational or site conditions change or when designated refreshers are so warranted. The topics to be covered by the training may include the entire contents of the HASP with emphasis on emergency procedures, areas of restricted access, methods of decontamination and general safety. A brief daily safety "tailgate" meeting will be held for all on-site personnel and shall be conducted by SSHO or Site Foreman. Notes of the subjects covered and a list of those attendees at the daily meeting will be maintained for the documentation package. 2.6 Medical Surveillance All affected on-site personnel shall provide evidence of a medical examination when required which meets the requirements of 29 CFR 1910.120(f) and 29 CFR 1926.65(f). Medical examinations are required by OSHA for the following employees involved in operations where there is the potential for contaminate exposure: 1. All employees who are exposed to hazardous substances or health hazards at or above the permissible exposure limits or, if there is no permissible exposure limit, above the published exposure levels for these substances, without regard to the use of respirators for 30 days or more per year; 2. All employees who wear a respirator for 30 days or more per year; or 3. All employees who are injured or develop signs and symptoms related to overexposure from an emergency incident involving hazardous substances or health hazards. These employees shall have a medical examination within the last twelve months prior to the start of the project. 2.7 Emergency Medical Care Ambulance services are available twenty-four hours per day, by contacting local Emergency Medical Services (EMS). The emergency telephone number is 9-1-1. Any employees who are seriously injured on site should be transported to a hospital by EMS personnel. At least one person trained in Red Cross First Aid/CPR/Universal Precautions for Bloodborne Pathogens or the equivalent will be available on-site at all times when workers are present. First aid kits capable of treating minor injuries and first responder treatment will be maintained on site at all times. 2.8 Accident Reporting and Record keeping The Contractor will immediately notify appropriate parties of any accident/incident. Within two working days of any reportable accident, the Contractor will complete and submit an Illness/Injury Accident Report. If the illness or injury is recordable as defined by OSHA, such illness or injury will be recorded on the OSHA 300 log for the site. OSHA regulations require that all accidents involving a fatality or three or more persons sent to the hospital for treatment from a single event must be reported to the Area Office of OSHA within eight (8) hours following the accident, or notification of the accident. 2.9 Site Emergency Equipment The Contractor will provide ANSI approved portable eyewash/safety shower units in accordance with ANSI Z358.1, a portable first aid kit, compressed air horn, and a 10-pound dry chemical fire extinguisher with a minimum rating of 2A:10B:10C in the following locations: ● Contaminant Reduction Zone (which may move as the project proceeds) ● Each active work area of the Exclusion Zone. ● Project trailer (or other accessible location if trailer is not on site). The location of this safety equipment shall be marked with a sign, and workers informed in the "tailgate" meetings, when the location of the safety equipment is changed. Any safety equipment required for confined space entry will be brought to the project trailer if it is needed on a project site. This equipment includes safety harnesses, wristlets, retrieval lines, a tripod (required for entering manholes or other utilities with fixed openings), air horns, and two-way radios. 2.10 Daily Safety Inspections The SSHO will conduct daily safety inspections of the site to determine compliance with the HASP if contaminated materials are encountered on the site and the HASP is in effect. These inspections will be systematic and will follow good safety and health procedures. The SSHO will conduct a minimum of two visual inspections per day during work activities. The SSHO will advise the Project Superintendent of any unsafe acts or actions observed, and will record observations in a daily log book. These inspections will become a part of the permanent project record. 2.11 Safety Responsibility The ultimate responsibility for the health and safety of the individual employee rests with the employee themself, and his or her colleagues. Each employee is responsible for exercising the utmost care and good judgement in protecting their own health and safety as well as that of fellow employees and the general public which might be affected by site activities. Should any employee observe a potentially unsafe condition or situation, it is the responsibility of that employee to immediately bring the observed condition to the attention of the appropriate health and safety personnel as designated above. Should any employee find himself or herself in a potentially hazardous situation the employee shall immediately discontinue the hazardous procedure(s) and either personally effect appropriate preventative or corrective measures, or immediately notify the Project Manager or SSHO of the nature of the hazard. In the event of an immediately dangerous or life threatening situation, the employee always has "stop work" authority. Extenuating circumstances such as budget or time constraints, equipment breakdown, changing or unexpected conditions, etc., never justify unsafe work practices or procedures. In fact, under stressful circumstances, all project personnel must be mindful of the temptation to consciously or unconsciously compromise health and safety standards, and must be especially safety conscious. 2.12 Site Security The Project Superintendent is responsible for maintaining security on the job site. This includes limiting access to authorized individuals and equipment, and preventing automobile/truck and pedestrian traffic once the work begins. All employees should consider themselves responsible for on-site security or otherwise securing the area when entering or leaving the site. Care should be exercised to route any automotive/ truck and pedestrian traffic away from portions of the active site where the excavation work or any utility support is occurring. 2.13Subcontractor Support Each subcontractor has a contractual obligation to perform their work utilizing safe methods and to comply with the Health and Safety Plan for this project, OSHA regulations, and all other applicable federal, state and local requirements. SECTION 3 - HAZARD CHARACTERIZATION 3.1 Chemical Hazards Please see cover sheets for specific chemical hazards. 3.2 Physical Hazards Physical hazards may include but are not limited to: 1. Potential pedestrian and vehicle traffic (including struck by other vehicles) in the vicinity of the project site. 2. Operation of heavy machinery, including excavators, trenchers, and trucks. 3. Proper shoring and or sloping of excavations and trenches. 4. Excavation stability from inflow of groundwater, and soil stability. 5. Entry into permit-required confined spaces. 6. Lockout/Tagout especially in the event "hot taps" are required for utilities support. 7. Exposure to temperature extremes and noise. 8. Electrical shock from overhead or buried power lines. Contact with existing utility services. 9. Falls from elevated levels. 10. Slips, trips and falls Caution should be exercised when near heavy machinery on the site. The entire area is a hard hat and safety glasses area. Hard hats shall be non-conductive and shall meet the specifications of ANSI Z89.1, "Protective Headwear for Industrial Workers". Reflective safety vests will be used by all workers at all times. Workers will be advised of all known hazards at the site prior to startup and thereafter as needed. They will be encouraged to be observant of site safety and health hazards and to report them directly to the SSHO or to the SSHO through their supervisor. Other potential hazards include slips, trips, falls, bumps, cuts, pinch points, falling objects, and crushing injuries, typical of every construction-related job site. The location of all underground utilities, including electrical lines; natural gas lines; water and sewer lines; and telephone lines must be identified and clearly marked before starting and excavation work. 3.3 Chemical Health Hazard Site workers should always be alert for unrecognized or previously undiscovered or unanticipated hazards. Potential hazards include: • Inhalation of potentially toxic vapors or dust including: heavy metals; components of gasoline and total petroleum hydrocarbons; contact with underground storage tanks or buried drums. • Inadvertent ingestion of potentially toxic substances via hand to mouth contact or deliberate ingestion of food, or tobacco products inadvertently contaminated with potentially toxic materials; • Dermal exposure to substances which may affect the skin directly or which may exhibit other toxic effects via percutaneous (skin) absorption; Based upon historical experience, the potential routes of exposure to hazardous compounds are through dermal contact, inhalation or ingestion. Exposure via ingestion can be controlled effectively by the use of personal protective equipment such as gloves, boots, and disposable coveralls, good personal hygiene habits, and a ban on smoking, eating and drinking in the contaminated areas. Employees will be required to wash their hands before eating. Similarly, dermal exposure can be virtually eliminated by good personal hygiene, the use of gloves and appropriate personal protective clothing, and conscientious personal decontamination procedures. 3.4 Unanticipated Hazards Unanticipated hazards at this site may include but are not limited to the need to handle or open drums or containers which may contain hazardous substances; encountering underground storage tanks or buried drums; activities requiring personal protective equipment more extensive than Level D; field work in non-illuminated areas during periods of darkness, and work during periods of severe weather and/or high wind. Safety procedures appropriate to these potential unanticipated hazards are not included in this HASP. If any of these conditions are encountered, all work will be suspended and the SSHO will immediately contact the Project Manager in order to define a proper response. 3.5 Site Control During work activities in and around the adjacent area, special precautions shall be taken to prevent exposure to site workers, visitors and neighbors and to ensure the safety at all approaches to the work area. The Project Superintendent will be in charge of site security during the construction activities to prevent unauthorized access to the designated exclusion zone. The contractor shall also place caution signs at approaches to the work area. The wording of the signs shall be consistent with the requirements of 29 CFR 1910.145 and 1926.62. If necessary, dust control methods will be accomplished by the use of water, to keep possibly contaminated dust from becoming fugitive and affecting surrounding areas. 3.6 Confined Space Entry Entry into permit-required confined spaces is not anticipated during work activities, however the topic is addressed and procedures are described in SOP#4 in the event it becomes necessary. 3.7Shoring and Trenching Although the need for shoring during excavation activities is not anticipated, no employee shall enter an excavation greater than four feet in depth, unless there is a trench box, suitable shoring (i.e lateral bracing system of soldier piles and sheeting) or the walls are sloped back to an angle of repose in accordance with the OSHA standards for trenching, 29 CFR 1910.650. In the event that excavations will be greater than four feet in depth, requirements exist for shoring/sloping or benching for this project. In the event any walls and faces of trenches and excavations are more than four feet deep, they shall be properly supported using a lateral bracing system of soldier piles and sheeting as indicated by the dimensions of the opening, and the degree of soil stability. All trenching and excavation work shall be performed only by trained individuals. Associated duties are to be followed by a designated “Competent Person”. The dimensions and depth of the excavations do not require the approval of a Professional Engineer. A stairway, ladder or ramp or other means of egress shall be provided to limit lateral travel to 25 feet to reach a point of egress, in accordance with 29 CFR 1926.651(c)(2). 3.8 Site Inspections by the SSHO At least twice each shift during field operations in Exclusion and Contaminant Reduction Zones, the SSHO shall visually inspect all site activities for compliance with this Plan. Deficiencies in compliance will be corrected upon discovery and noted in the daily site log. This log will become a part of the documentation package at the completion of the project. 3.9 Hazard Analysis/Risk Assessment A limited hazard analysis and risk assessment is presented by task on the attached cover sheets. The objective is to identify and plan for hazards which might be encountered in this project, and do not include emergency planning for remote events. The assessment also defines the appropriate control measures to minimize the risk to on-site employees, as well as to the general public. SECTION 4 - SITE CONTROL Site control zones will be established in order to contain contamination within the smallest area possible. The SSHO will ensure that each employee has the proper personal protective equipment for the area or zone in which they are to perform work. Only authorized persons will be permitted access to Exclusion and Contamination Reduction Zones. All entrance to these areas will be restricted by means of regulated personnel flow. The purpose of this site-specific Health and Safety Plan (HASP) is to establish in detail the procedures and protocols necessary for protecting of workers and the general public from potential hazards associated with the work activities. This section shall define the work zone delineations, site communication, and site access control measures to be employed. 4.1 Exclusion Zone (EZ) The Exclusion Zone (EZ; contamination work zone) is the area(s) where potential exposure to contamination could exist. This is the area where exposure to potential contamination could cause risk to health of on-site workers in the absence of PPE defined for that area. The Project Superintendant and SSHO should refer to Contract Drawings of the site. OHI has established criteria for defining EZs in Section 5.1 of this HASP. The location of the EZ will be amended in the event other unanticipated hazards are encountered. Special precautions will be taken to insure that pedestrians and non-essential persons are not allowed near the EZ. Caution tape, snow fence, and traffic cones or other methods may be used to delineate the EZ around the work area. Warning signs will be posted at each entry point to the EZ. No eating or smoking is allowed anywhere within the area of the Site. The required protective equipment for use by personnel working in or entering any EZ or CRZ is specified in Section 5. Access to the EZ or CRZ is restricted to On-Site and Contractor personnel who are wearing the proper personal protective equipment and who have received the required site training and medical clearance. All workers and visitors will sign in the log book in the Support Zone prior to entering the Exclusion Zone. 4.2 Contamination Reduction Zones (CRZ) The CRZ is a buffer zone between the Exclusion Zone and the Support Zone, and is located at the interface of the two zones. Personnel, equipment and, if necessary, vehicle decontamination stations such as washing stations will be located in this area. The CRZ serves as an area to decontaminate personnel, equipment, and vehicles prior to entering the support zone. If necessary, clothing change facilities for reusable PPE shall be located in the contamination reduction zone. The CRZ will be a zone extending an appropriate distance beyond the EZ on one or more sides as required for site access. All access to the EZ shall be through the CRZ. 4.3 Support Zone (Non-Contaminated) This is the area outside of the Contaminant Reduction Zone, where there is no potential for contact with contaminants. The Support Zone contains the following: work rest area, support operations, radio communications, transportation, and storage facilities. The support zone is located outside the limits of the designated exclusion zones, and away from areas designated as contaminated. Eating and drinking of fluids are permitted only in this area and only after site workers have properly decontaminated themselves. Dust control is an important issue on this site. The following precautions will be taken to control the release of dust both on- and off-site: ● All trucks will be covered before leaving the site. ● Trucks will be carefully loaded with soil and debris to prevent spillage of soil and debris on the ground or on exterior truck bodies. ● All trucks will have wheels scraped and brushed or cleaned of dirt and debris before leaving the site. ● The entrance to the site will be kept swept to reduce any buildup of dust or dragout of dust onto surrounding streets. ● Water mists or other recognized dust suppression techniques will be applied as required. In the unlikely event “overt” contamination is identified, a response plan will be implemented. Indications of "overt" contamination as defined by Massachusetts DEP include but are not limited to the following: (1) staining or unusual color to the soil; (2) unusual or blackish color to trench or excavation water; (3) visible sheen or rainbow on top of the groundwater entering the trench or excavation; (4) smells of gasoline, oils, or solvents coming from the soils or water; (5) buried drums, tanks, or suspicious structures; (6) excavate contains levels of oils or hazardous materials. Personnel, vehicles and equipment used during the work activities, and hazardous chemicals and materials shall be decontaminated before leaving the EZ using work site procedures contained in the HASP and the Project Specifications. 4.4 Site Communication It is critical to maintain two-way communication on site at all times, to protect the safety of on-site employees, and to expedite the decision-making process, during events when contamination is encountered. Direct verbal communication is the most simple and effective emergency communication system. All requests for emergency services will take place through cellular telephones. The Project Superintendant will carry cellular telephones and will be in continuous contact with project personnel. Verbal communication and hand signals will be used to communicate among workers on the site. In addition, visual and voice or radio communications must be maintained at all times while working on-site. The following signals will be used to indicate an emergency situation: One long blast repeated three times at five second intervals. General warning used to signal relatively minor events. Personnel must stop all activity and equipment on site and await further instructions from the on-site project manager. Two blasts repeated three times at five second intervals. Medical emergency Immediate first aid or emergency medical care is needed. All first aid and/or CPR trained personnel should respond as appropriate, all other activity and equipment on site must atop and await further instructions from on-site project management. Evacuate site. Three horn blasts followed by one continuous blast. Immediate danger to life or health. All activity and equipment on site must stop and all workers and visitors must evacuate the site, heading to the pre-arranged muster point. Copies of the map and reference information for the rally point will be posted in an easily accessible and visible location where they may be used by site personnel as reference guides. 4.6 Signs The Contractor shall post warning signs designed to provide guidance and direction to on-site personnel and visitors. The signs shall be posted in locations approved by the SSHO, and should be large enough to visibly see from a reasonable distance. Visitor Signs: Signs shall be posted prohibiting access by all visitors. No Smoking: No smoking signs shall be posted in areas of high visibility immediately adjacent to the Exclusion Zones. 4.7 Engineering Controls At this time no special engineering controls are anticipated for this project. There are no plans to require or use forced continuous ventilation to provide safe working conditions. The need for ventilation will be established by the use of monitoring equipment. Dust suppression in the form of light water sprays will be implemented as required to control dusting during work activities. Alternatively, intrusive activities may be reduced or curtailed under high wind or heavy rain conditions, which in the opinion of the SSHO may pose a safety hazard to the workers, or nearby members of the community. Barricades will be erected to prevent unauthorized entry into the excavation. 4.8 Site Control Measures 4.8.1Access and Egress Patterns Specific movement patterns of both project personnel and equipment through designated site zones shall be maintained during routine operations at the project site. The following movement pattern will be utilized to assure compliance with this plan and the movement shall be monitored by the SSHO or other project management personnel. Access Procedure: 1. All site personnel are to log in prior to proceeding on-site. 2. Access to the exclusion zone and decontamination reduction zone shall be limited to on-site, contractor personnel. Visitors shall be restricted to the Support Zone, unless approved by the Project Manager and the SSHO. These personnel shall have proper protective equipment and have proof of training. 3. All personnel shall proceed to the exclusion zone through designated entrance locations that are clearly marked. 4. Access of routine personnel shall be monitored by the SSHO or other on-site project management personnel. 5. All equipment will have access to the exclusion zone through appropriate equipment routes. Exiting Procedure 1. All personnel shall exit the exclusion zone through the designated contaminated reduction zone. 2. Prior to proceeding from the CRZ to the support zone all personnel are required to undergo designated decontamination activity. 3. Once decontamination is complete, site personnel may proceed to the support zone prior to leaving the site. Do not reenter the EZ or CRZ. 4. All equipment on-site shall proceed from the exclusion zone to the CRZ and undergo appropriate decontamination prior to proceeding to the support zone. 5. Adherence to these specific exiting procedures shall be monitored by the SSHO or other appropriate project supervisory personnel. 4.8.2Operation Procedures The following procedures shall be maintained during routine activity associated with the site control procedures: 1. A copy of this HASP shall be maintained on-site. 2. All personnel shall be instructed in the contents of the plan. 3. Proper delineation of site control zones will be maintained and signs placed in visible locations. 4. Access and exiting routes are contained in this report for both equipment and personnel. 5. Any modifications to the plan including delineation of work zone boundaries shall be approved prior to implementation and all personnel shall be briefed in the modification prior to implementation. SITE OPERATING PROCEDURES/SAFETY GUIDELINES The following general work practice guidelines are intended to prevent injuries and adverse health effects. These guidelines represent the minimum standard procedures for reducing potential risks associated with the project and are to be followed by all site workers at all times. ** All safety equipment and protective equipment shall be worn at all times in designated areas, by all persons, in conformance with the HASP. ** Always observe the buddy system. Never enter or exit site alone, and never work alone in an isolated area. ** Always use the fall protection system when working on elevated areas. Use approved tie-offs and proper harnesses/lanyards etc. ** Always maintain a line-of-sight. ** Practice contamination avoidance. Never sit down or kneel, never lay equipment on the ground, avoid obvious sources of contamination such as puddles, and avoid unnecessary contact with on- site objects. ** No eating, drinking, or smoking outside the designated Support Zone. Washing of hands is mandatory before eating, drinking, etc. ** In the event Personal Protective Equipment is ripped or torn, work shall stop and it shall be removed and replaced as soon as possible. ** Be alert to any unusual changes in your own condition; never ignore warning signs. Notify SSHO as to suspected exposures or accidents. ** All personnel going on-site shall be familiar with the most direct route to the nearest hospital. ** In the event of direct skin contact, the affected area shall be washed immediately with soap and water. ** Note wind direction. Personnel shall remain upwind whenever possible during on-site activities. ** Never climb over or under refuse or obstacles. ** Hands and face must be thoroughly washed before eating, drinking, etc. ** Any modifications to this safety plan MUST be approved by the SSHO and the Project Engineer. SECTION 5 - PERSONAL PROTECTIVE EQUIPMENT 5.1 Introduction Personal protective equipment (PPE) is the major method used to minimize potential employee exposure to site contamination. The levels of protection for on-site personnel have been based on OSHA requirements. All personnel on-site shall have their own personal safety equipment which will be used according to the direction of the SSHO. All PPE shall be kept cleaned and maintained in a proper manner. Personnel will have been trained in the proper use and maintenance of PPE. It is the responsibility of the Contractor to supply and maintain all required PPE in a usable fashion. At a minimum, all workers and visitors will be required to have hardhats and steel toe safety shoes or boots whenever on-site. PPE as prescribed in this plan shall be worn on-site at all times. Loose sleeves, cuffs, loose clothing, ties, or other objects which may become entangled in machinery are not permitted. Reflective vests will be used at all times. OSHA has implemented a standard on personal protective equipment, 29 CFR 1910.132. This standard defines approved types of PPE for eye and face protection, head, and foot protection. The appropriate types of PPE shall be designated for the hazards of the particular task. All PPE shall comply with the appropriate ANSI designation as referenced in the standard. Controls will be implemented to reduce the potential for personnel to be exposed to contaminants at levels above the OSHA Permissible Exposure Limits (PELs), ACGIH Threshold Limit Values (TLVs), or encounter conditions which are Immediately Dangerous to Life and Health (IDLH). 5.2 Respiratory Protection Plan All workers assigned to this project shall be covered under the Respiratory Protection Plan, developed in accordance with the requirements of 29 CFR 1910.134. This standard, “Respiratory Protection” establishes the minimal requirements for the use of respirators. The following worksite-specific procedures have been incorporated into this Plan: ● The SSHO will implement and oversee the use of respirators on site. ● Respiratory protection will be utilized during work activities until such time as the “initial determination” has been completed. If the “initial determination” indicates that worker exposures are below the Action Level, the use of respirators will be discontinued unless the project changes or the potential for exposure increases. ● The “initial determination” will determine what, if any type of respiratory protection device is required. A half-face dust mask (e.g. N95) will be used by employees performing any task that produces visible dust emissions until the “initial determination” has been completed. ● All employees using respirators on this project shall demonstrate that they have received medical evaluations required to use respirators and have been approved for the use of these respirators. Employees or site visitors without medical approval will not be permitted in areas where respirators are required. ● All employees have been trained in the proper use and limitations of the respirator. This includes qualitative fit-testing, cleaning, servicing, repairing, maintaining and storing of the respirator. ● Dust masks (e.g. N95) do not currently have “end-of-service-life” indicators. As such, masks will be discarded at the end of the workday (see section on decontamination) and new filters placed in the respirator. ● It is expected that all employees and visitors using respirators will not have facial hair or beards which block the ability to have a good face-to-facepiece seal. ● As stated in other sections, employees have received training in the hazards associated with potential exposure to contaminates in accordance with the requirements of 29 CFR 1926.62 and Hazard Communication training in accordance with the requirements of 29 CFR 1926.59. ● Employees have been informed of the hazards on the project site and have been told of their right of access to exposure and medical records under the OSHA Access to Records standard, 29 CFR 1910.20. 5.3 Description of the Levels of Protection The following is a brief description of levels of protection to be used by site personnel: Level D: Work Clothes Safety Shoes with Outer Rubber Slush Boots (for water) Gloves Hard Hat Safety Glasses w/ side shields Reflective Vest (in high traffic areas and after dusk) Modified Level D: Reflective Vest (in high traffic areas and after dusk) Tyvek suit - Dry work and areas of low contamination PVC or Saranex-coated Tyvek - Wet work and areas of overt or moderate contamination Outer Rubber Slush Boots Outer Chemically Resistant Gloves - Butyl/Neoprene Inner gloves - latex, disposable nitrile or PVC Hard Hat Safety Shoes Safety Glasses w/ side shields or goggles Level C: Full Face Air Purifying Respirator with organic vapor/particulate cartridge PVC or Saranex-coated Chemically Resistant Tyvek Outer Rubber Boots Outer Chemically Resistant Gloves - Butyl/Neoprene Inner Gloves - latex, disposable nitrile or PVC Hard Hat Safety Shoes Reflective Vest (in high traffic areas and after dusk) 5.5 Air Monitoring for Worker Protection During excavation and construction, the Contractor will monitor the air quality where construction activities involve soil handling such as excavation, relocation, staging, loading or grading of soil/waste materials. Visual monitoring will be conducted if there is no reason to believe that the material is contaminated. Dust suppression will be conducted if visible dust is observed. In addition to visual monitoring, air monitoring will be conducted around the Site. Air monitoring will involve appropriate techniques capable of providing real-time indications of air contaminants to protect on-site personnel and the local population. Air monitoring will be performed using particulate meters such as TSI DustTrak II Aerosol monitor, or equal. Each designated operator will be properly trained in the use of the monitoring equipment. Air monitoring will be conducted at three locations (north end of work zone, south end of work zone, and near the center) around the Site at 60-minute intervals or if visible dust is observed for a continuous period of five (5) minutes or more. The results of the air monitoring will be recorded and used as the basis for specifying personal protective equipment (PPE) and determining the need to upgrade/downgrade protective measures. All personnel will be made aware of potential hazards and be informed of air monitoring information. The Contractor’s Site Health and Safety Officer and Superintendent will be responsible for assuring that monitoring is conducted in an appropriate manner and that work practices, engineering controls and/or personal protective equipment are proper for the conditions. Work activities at the Site will be shut down if monitoring values exceed 1 milligram per cubic meter (1 mg/M3). 5.6 Action Levels for Upgrade/Downgrade of Level of Protection The action levels for the upgrade/downgrade of worker personal protective equipment have been based upon information published by the American Conference of Governmental Industrial Hygienists (ACGIH), the Occupational Safety and Health Administration (OSHA), and the United States Environmental Protection Agency (US EPA). The action levels are based upon established Permissible Exposure Limits (OSHA), Threshold Limit Values (ACGIH), and Short-Term Exposure Limits (ACGIH). The action levels have been established for each work activity/contaminant present. 5.7 Respiratory Protection Initially, work activities are assigned a protection Level D. However, an upgrade could occur and in the event that respiratory protection will be required for on-site personnel exposed to suspected hazardous contaminants through inhalation, all employees who are required to wear particulate protection will be required to show proof of medical examination to the SSHO which indicates that the employee is capable of wearing such a device. Proof of initial and periodic training and qualitative or quantitative fit testing for use of air purifying respirators is also necessary. Negative and positive pressure fit checks will be performed daily by each individual respirator wearer upon donning a respirator. The following checks shall be performed on a daily basis in addition to the above: • Exhalation Valve - pull off plastic cover and check valve for debris or for tears in the neoprene valve (which could cause leakage). Also check valve cover for tightness. • Inhalation Valves (two) - screw off cartridges and visually inspect neoprene valves for tears. Make sure that the inhalation valves and cartridge receptacle gaskets are in place. • Make sure a protective lens cover is attached to the lens. Lenses are expensive to replace and should be protected at all times. • Make sure you have the right cartridge. Cartridges are not interchangeable among respirators. • Make sure that the face piece harness is not damaged. The serrated portion of the harness can fragment which will prevent proper face seal adjustment. • Make sure the speaking diaphragm retainer ring is hand tight (if applicable). SECTION 6 - DECONTAMINATION 6.1 Introduction Appropriate decontamination activities will be conducted whenever site workers have conducted activities in the area(s) where contamination is known to exist, and where exposure to this contamination could cause risk to health of on-site workers in the absence of PPE defined for that area. An area around the hot zone on the upwind side of the work activities where potential contamination has been confirmed will be used as the Contamination Reduction Zone (CRZ). This area will be used for the decontamination of personnel, vehicles, and equipment used on the site. Designated locations will be identified for decontamination of personnel and equipment using portable barriers or stanchions, and barrier tape. Decontamination of equipment and trucks used will be performed at a designated decontamination site. All decontaminated equipment must be verified by the SSHO prior to departing the site. The sign in/sign out record shall have a category to reflect that all equipment used in the Exclusion Zone (EZ) has been decontaminated. 6.2 Personnel Decontamination Decontamination procedures will be followed by all personnel leaving the Exclusion Zone. Under no circumstances (except emergency evacuation) will personnel be allowed to leave the site prior to decontamination. When worn, disposable items (i.e., Tyvek coveralls, inner gloves, and overboots) will be changed on a daily basis as required unless there is a reason to change sooner. Respirator cartridges/dust masks will be changed daily, unless more frequent changes are deemed appropriate, such as breakthrough. Portable wash down facilities such as water buckets, sprayers, hoses or other designated equipment will be available in the decontamination area for wash down and cleaning of personnel and equipment. All water shall be collected in a device to retain the water for subsequent testing and disposal if necessary. All personnel will wash their face and hands before leaving the site. A separate facility or cleaning station shall be developed for the cleaning of respirator facepieces each day. If non-disposable equipment (i.e., boots, gloves, respirators, etc.) are visibly contaminated, they should be washed before leaving the Contamination Reduction Zone for the next site. Workers are to segregate and store their personal protective equipment separate from their personal clothing. In no circumstances are workers allowed to take from the site or wear home any contaminated clothing or equipment. 6.3 Small Equipment Decontamination Small equipment will be protected from contamination as much as possible by covering with plastic (to the extent feasible) without hindering operation of the unit. Contaminated equipment will be cleaned as needed. The units will be checked, standardized, recharged as necessary for the next day's operation, and then prepared with new protective coverings. 6.4 Heavy Equipment Decontamination All equipment that shall enter the designated Exclusion Zone will be required to undergo decontamination prior to proceeding from the site. All decontamination activity will be undertaken at the location designated within the Site Control Plan. Care shall be exercised when loading trucks to prevent spillage of debris on the ground, or on the outside of the trucks. For all on-site excavation, debris movement, or other machine that comes in contact with suspected contaminants, decontamination procedures shall be employed. Trucks will be staged so as to prevent contamination of the wheels and truck body. SECTION 7 - EMERGENCY/CONTINGENCY PLANNING 7.1 Emergency/Contingency Plan This section identifies the emergency contingency planning undertaken for operations at the site, and includes further information to be used under emergency conditions such as emergency telephone numbers, routes to emergency medical facilities and emergency signals. The Emergency Response Plan is included as an Appendix to this HASP. 7.2 Evacuation Withdrawal Upwind - When conditions which endanger the safety or health of workers warrant moving away from the work site, the crew will relocate upwind at an appropriate distance as indicated by site monitoring instruments. In the event of withdrawal, the SSHO and a member of the crew (the buddy system must be used) may return to the work site to determine if the condition noted is transient or persistent. If persistent levels of air contaminants remain, an alarm should be sounded to notify personnel of the situation and the need to leave the site. The site management will be notified of conditions. This alarm will be given using a compressed air horn and portable radios, using a pre-arranged signal or tone, or message as described in the HASP: The following signals will be used to indicate an emergency situation: One long blast repeated three times at five second intervals. General warning used to signal relatively minor events. Personnel must stop all activity and equipment on site and await further instructions from the on-site project manager. Two blasts repeated three times at five second intervals. Medical emergency. Immediate first aid or emergency medical care is needed. All first aid and/or CPR trained personnel should respond as appropriate, all other activity and equipment on site must atop and await further instructions from on-site project management. Evacuate site Three horn blasts followed by one continuous blast. Immediate danger to life or health. All activity and equipment on site must stop and all workers and visitors must evacuate the site, heading to the pre-arranged muster point. Copies of the map and reference information for the rally point will be posted in an easily accessible and visible location where they may be used by site personnel as reference guides. When site access is restricted, thus hindering escape, the crew may be instructed to evacuate the site rather than move upwind, especially if withdrawal upwind moves the crew away from escape routes. The Contractor and/or subcontractors will have designated "counters" with the responsibility to account for all employees and visitors in the event of an evacuation. The exact meeting place should be announced at the Tailgate Meeting; the construction entrance. Site Evacuation - When conditions warrant site evacuation, the work party will proceed upwind of the work site and notify the SSHO, security force, and field office of site conditions. The Project Manager, Site Foreman or SSHO have authority to order an evacuation of the site. Fire/Explosion Upon notification of a fire or explosion on-site, all personnel will evacuate the site, immediately proceeding upwind to the agreed upon evacuation location. The local Fire Department shall be alerted along with the Project Superintendant. Personal Protective Equipment Failure If any site personnel experience a failure or alteration of protective equipment that affects the protection factor, that person and his/her buddy shall immediately leave the Exclusion Zone. Re- entry shall not be permitted until the equipment has been repaired or replaced. Other Equipment Failure If any other equipment on-site fails to operate properly, the SSHO shall be notified to determine the effect of this failure on continuing operations on-site. If the failure affects the safety of on- site personnel or prevents completion of the tasks, all personnel shall leave the exclusion zone until the situation is evaluated and appropriate actions taken. In all situations, when an on-site emergency results in evacuation of the Exclusion Zone, all personnel shall not re-enter until: 1. The conditions resulting in the emergency have been corrected. 2. The hazards have been reassessed. 3. The Site Safety Plan has been reviewed. 4. All site personnel have been briefed on any changes in the HASP. 7.3 Emergency Medical Treatment/First Aid First aid will be rendered to any person injured on-site, as appropriate by any individual trained in First Aid/CPR/Universal Precautions. At least one trained person will be on site at all times during work activities First aid kits will be kept on-site and in each Supervisor’s vehicle. Following initial treatment, the injured person will then be transported for further examination and/or treatment. If the employee is seriously injured, the preferred transport method is a professional emergency transportation service; however, when this is not readily available or would result in excessive delay, other transport is authorized. Under no circumstances will injured persons transport themselves to a medical facility for emergency treatment. If an injury occurs in an Exclusion Zone area, provisions for decontamination of the victim will be made. However, life threatening conditions may preclude normal decontamination procedures. In such cases, arrangements will be make with the medical facility and transporter to provide for the situation. 7.4 Procedures for Handling Personnel With Excessive Exposure: Decontamination will be done at a location which is convenient to the area where the Emergency Response actions are occurring, in an upwind location. The decision to decontaminate a victim is based on the type and severity of the illness or injury and the nature of the contaminant. For some emergency victims, immediate decontamination may be an essential part of life-saving first aid. For others, decontamination may aggravate the injury or delay life-saving treatment. If decontamination does not interfere with essential treatment, it will be performed and will include a wash, rinse and/or cut off of protective clothing and equipment. If decontamination cannot be done, the victim will be wrapped in blankets, plastic or rubber to reduce contamination of other personnel. Emergency and off-site medical personnel will be alerted to potential contamination. A site person familiar with the incident and the chemicals will be sent if available. 7.5 Heat Stress SOP #3 deals with the signs, symptoms and first aid for heat stress victims. Monitoring for heat stress should begin whenever the work area temperature exceeds 70o F. All employees will be trained in recognition of the signs and symptoms of heat stress and will be required to do proper monitoring whenever they feel it is necessary. Any employee who feels that they are suffering the effect of heat stress shall inform the SSHO immediately. The Contractor shall follow the recommendations for monitoring requirements, and suggested work/rest schedules for heat stress found in the ACGIH-02, TLV Booklet (2004). For workers who wear semi-permeable or impermeable clothing (i.e. Saranex or PVC coated Tyvek), the technical guidelines in NIOSH Publication 85-115 shall be observed. An adequate source of cool water and or electrolyte replacement fluids (Gatorade, Squincher etc) should be provided for employees. The procedures for monitoring heat stress shall be to measure the radial heart rate (pulse) during a 30 second interval at the beginning of a rest period. If the heart rate exceeds 110 beats per minute, shorten the next work cycle by one-third, while keeping the rest period the same length. If the heart rate exceeds 110 beats per minute at the beginning of the next rest period, shorten the following work cycle by one-third. Continue monitoring and shortening work cycles until the heart rate is less than 110 beats per minute. Fluids will be available in the Support Zone for employees to maintain fluid intake during warm work periods. 7.6 Cold Stress SOP #3 deals with the signs, symptoms and first aid for cold stress victims. Monitoring for cold stress should begin whenever the work area temperature drops below 50o F. Employees should be aware of the symptoms of cold stress and frost bite. If any signs or symptoms appear, report it immediately to the SSHO. The work is projected to occur starting in the Spring of 2009 and continuing for about one month. Cold stress could become an issue for this project. In the event of extreme cold conditions, procedures to monitor and avoid cold stress shall be followed in accordance with the current TLV's for Cold Stress as recommended by ACGIH. This includes the use of layered clothing, periodic breaks in a heated area, and the use of warm non-alcoholic beverages. 7.7 Illumination Site operations will not be permitted without adequate lighting: a least 5 foot-candles is required for work on the site. Therefore, unless provisions are made for artificial light, downrange operations must halt in time to permit personnel and equipment to exit the Exclusion Zone and proceed through decontamination before dusk. Conversely, operations will not begin until lighting is adequate. 7.8 Emergency Information See the attached cover pages for emergency services contact information SECTION 8 - RECORD KEEPING, LOGS, AND REPORTS 8.1 General Requirements All required records, logs and forms will be maintained according to the appropriate regulations. This includes all safety inspection reports, site entry log, accident/incident reports, monitoring log, medical certifications, first aid/CPR, 40-hour training, current 8-hour refresher training, current 8-hour supervisor training, hazard communication training, air monitoring results, etc. All exposure and medical monitoring records will be maintained according to OSHA 29 CFR 1910.20 (Access to Records), 29 CFR 1910.120 (Hazardous Waste Operations and Emergency Response) and 29 CFR 1926. 8.2 Daily Safety Inspection Logs The daily safety inspection log will include as a minimum: 1. Date 2. Area (site specific) checked 3. Employees in a particular area 4. Equipment being utilized by employees 5. Protective clothing being worn by employees 6. Protective devices being used 7. Contractor's Personnel 8. Visitors 9. Designated State and Federal Representatives 10. Air Monitoring Data 11. Site Safety and Health Officer signature and date 8.3 Other Reports Other reports to be maintained may include but are not limited to reporting detailing monitoring results, decontamination of vehicles & equipment leaving the Site, actions taken, and the results of those actions; minutes of required safety meetings; and a phase-out report to be prepared at the conclusion of the project. All reports will be maintained in duplicate. STANDARD OPERATING PROCEDURE NUMBER 1 Personal Protective Equipment Program Standard Operating Procedure Personal Protective Equipment Program I. PURPOSE To provide minimum requirements for protection of employees, visitors and contractors from injury or ill health through the proper selection and use of Personal Protective Equipment (PPE). II. PROGRAM RESPONSIBILITIES A. The Site Safety and Health Officer is the personal protective equipment administrator and has the responsibility to: 1. Coordinate the program. 2. Insure that annual training is conducted. 3. Review the program annually. B. Supervisors are responsible for informing workers of the personal protective equipment requirements within their department/area. The supervisor will also ensure that workers have been instructed in the proper donning, wearing, removal and the cleaning or disposal procedures for such equipment, and that the worker has understood the instructions. The supervisor will provide additional instructions as needed, and will strictly enforce site rules related to PPE use. C. Workers are responsible for properly donning, wearing, removing, cleaning, and disposing of the required protective equipment. D. The Site Health and Safety Officer (SSHO) is responsible for ensuring that Contractors provide their own protective equipment as specified in this Program. E. The SSHO is responsible for maintaining the site PPE inventory control program. F. The Project Manager and SSHO are responsible for the purchase of PPE, including respiratory protection. III. GENERAL REQUIREMENTS A. Employees shall only use personal protective equipment supplied by the company. B. Visitors will be supplied with the appropriate personal protective equipment. C. Personal protective equipment requirements are posted in the site specific Health and Safety Plan. D. Disposal of PPE and cleaning of reusable PPE is governed by the procedures specified in the Respirator Program. E. Written procedures governing the safe use of PPE that might be required in an emergency are contained in this Standard Operating Procedure. These plans also contain the training requirements for emergency PPE. IV. CHEMICAL PROTECTIVE CLOTHING A. Selection of Chemical Protective Clothing (CPC) will be based on the following: • Manufacturers' instructions and degradation, penetration permeation data • Published literature such as the ACGIH Guidelines Selection of Chemical Protective Clothing Selected clothing will be contained in the HASP. V. PPE INSPECTION A. Respirators will be inspected in accordance with the Respiratory Protection Program. B. Other PPE should be inspected prior to use by the wearer. Inspection considerations should include: obvious signs of contamination; tears and holes; proper function of closures; seams, etc. Sample PPE inspection checklists are found in Standard Operating Procedure 2. C. PPE stored for emergency use should be inspected monthly. VI. STORAGE Storage of PPE at the site will follow the following general guidelines. A. Boots are decontaminated and stored on a boot rack at the hot line to dry. B. Disposable protective clothing may be stored before use at the hot line. However, a covering or other method should be provided to prevent contamination. Disposable clothing articles are placed in waste containers at the hot line after being removed. Disposable clothing is not to be reused. C. Respirators are stored in accordance with the Respiratory Protection Program. They should not be stored in the open air in contaminated areas. D. Reusable PPE should be stored in accordance with manufacturer's instructions to prevent equipment failure. E. Potentially contaminated coveralls worn under disposable coveralls, are stored in containers in a separate area from street clothing. VII. WORK MISSION DURATION Since the work mission durations vary from site to site and task to task, it will be the responsibility of the Project Manager and the SSHO to maintain adequate supplies of PPE and breathing air to accomplish the work mission and comply with this program. STANDARD OPERATING PROCEDURE NUMBER 2 Respiratory Protection Program AIR PURIFYING RESPIRATORY PROTECTION RESPIRATOR TRAINING OUTLINE A. Training of respirator wearers in the use, field maintenance, capabilities and limitations of respirators is given initially upon employment to all employees whose work will require the use of respirators, or where an employee changes into a job classification which requires respiratory protection. Retraining is given at least annually thereafter. No employee is allowed to wear a respirator in a work situation until he or she has been trained. B. Each employee is trained as follows: 1. Instruction in the nature of the respiratory hazards, and what may happen if the respirator is not used properly. 2. An explanation of the engineering and administrative control measures being used and why respirators are needed to provide protection. 3. Instruction in the selection, use, sanitary care, maintenance, proper storage, and limitations of each applicable respirator type. 4. Demonstrations and practice in proper fitting, wearing, adjusting, and checking the face-to-face piece seal of each applicable respiratory type. 5. An opportunity to handle the respirator and to wear it in a safe atmosphere for an adequate period of time to ensure familiarity with the characteristics of the respirator. 6. An opportunity to wear the respirator in a test atmosphere (such as atmospheres generated by smoke tubes or isoamyl acetate) to demonstrate that the respirator protects the worker. 7. Instructions in how to recognize and cope with emergency situations requiring respiratory protection. 8. An explanation of the requirement for a self-contained breathing device for work in unknown concentrations and immediately dangerous to life or health (IDLH) atmospheres, and for fire fighting. 9. An explanation of the medical surveillance program as it relates to the use of respiratory protective equipment. 10. An explanation of the requirements for maintaining the respirator gas-tight seal, including beard and facial hair policies; and the policy prohibiting the use of contact lenses while wearing respirators. C. Records of the training given each individual are placed in the employees training record file. Respirator Fit Test Form Employee Name Respirator Type (1) Face Piece (2) Make, Model Size Cartridge Used Test (3) Normal Breathing Deep Breathing Side to Side Up and Down Speaking Bending Jogging Normal Breathing Sensitive to Smoke Pass (P) or Fail (F) Comments: ______________________________________________________ Person Conducting Fit Test: _______________ Date: ____________ (1) Respirator Type: AP (air purifying); SA/SCBA (supplied air with SCBA escape bottle); SCBA (self-contained breathing apparatus (2) Face Piece: F (full face); H (half mask) (3) Test: IS (irritant smoke); QN (quantitative) Monthly Written Respiratory Protection Program Evaluation 11 Points of 29 CFR 1910.134 ___ 1. There are written standard operating procedures governing the selection and use of respirators. ___ 2. Respirators are selected on the basis of hazards to which the worker is exposed. ___ 3. Approved or accepted respirators are used when they are available. ___ 4. The user is instructed and trained in the proper use of respirators and their limitations. ___ 5. Where practical, the respirators are assigned to individual workers for their exclusive use. ___ 6. There are regular inspection and evaluations to determine the continued effectiveness of the program. ___ 7. Persons will not be assigned to tasks requiring the use of respirators unless it has been determined that they are physically able to perform the work and use the equipment; i.e., medically qualified. ___ 8. Respirators will be regularly cleaned and disinfected. ___ 9. Respirators will be stored in a convenient, clean and sanitary location. ___ 10. Respirators used routinely will be inspected during cleaning. ___ 11. Appropriate surveillance of work area conditions and degree of employee exposure or stress will be maintained. Reviewed by: ________________________ Date of Review: _________ STANDARD OPERATING PROCEDURE NUMBER 3 First Aid for the Identification of Heat Exhaustion or Heat Stroke, and Hypothermia IDENTIFICATION AND TREATMENT OF HEAT EXHAUSTION OR HEAT STROKE 1. Heat Exhaustion A. Symptoms: Usually begins with muscular weakness, dizziness, nausea, and a staggering gait. Vomiting is frequent. The bowels may move involuntarily. The victim is very pale, his skin is clammy, and he may perspire profusely. The pulse is weak and fast, breathing is shallow. The victim may faint unless he lies down. This may pass, but sometimes it persists and, while heat exhaustion is generally not considered life-threatening, death could occur. B. First Aid: Immediately remove the victim to the decontamination area in a shady or cool area with good air circulation. Remove all protective outer wear. Call a physician. Treat the victim for shock. (Make the victim lie down, raise feet 6-12 inches, maintain body temperature but loosen all clothing.) If the victim is conscious, it may be helpful to give sips of water. Transport victim to a medical facility. 2. Heat Stroke A. Symptoms: This is the most serious of heat casualties due to the fact that the body excessively overheats. Body temperatures often are between 107-110o F. The victim will have a red face and may not be breathing. First there is often pain in the head, dizziness, nausea, depression, and a dryness of the skin and mouth. Unconsciousness follows quickly and death is imminent if exposure continues. The attack will usually occur suddenly. Heat stroke is always serious. B. First Aid: Immediately evacuate the victim to a cool and shady area in the Decontamination Reduction Zone. Remove all protective outer wear and all personal clothing. Lay the victim on his back so that the head and shoulders are slightly elevated. It is imperative that the body temperature be lowered immediately. This can be accomplished by applying cold wet towels, ice bags, etc., to the head and groin. Sponge off the bare skin with cool water or rubbing alcohol, if available, or even place in a tub of cool water. The main objective is to cool without chilling. Give no stimulants. Transport the victim to a medical facility as soon as possible. IDENTIFICATION AND TREATMENT OF FROSTBITE Frostbite is a localized injury, resulting from a freezing of tissue. It is most common to the fingers and toes due to reduced circulation in the extremities and on the face and ears as they are most commonly exposed (uncovered) to the weather. For frostbite to occur, there must be subfreezing temperatures. It is most prevalent in very cold temperatures or when cold temperatures are extenuated by the wind (wind chill). A. Symptoms 1. Pre-Frostbite - Affected area feels painfully cold, but usually flushed (red-rosy) in color. 2. First Degree Frostbite (frost nip - Crystallization in superficial tissues. Affected area no longer feels cold, and is completely numb. Skin coloration is a small white or grayish-yellow waxy patch. Immediate treatment will completely reverse the condition with no ill effects. 3. Second Degree (Deep) Frostbite - A deep freezing of the fluids in the underlying soft tissues. Symptoms and treatment are the same as for above. Usually results in a death of tissue, blistering, black skin, loss of toes, etc., with possible complications from gangrene. B. First Aid 1. Cover and protect the affected part 2. Provide extra clothes 3. Bring indoors as soon as possible 4. Give warm drink 5. Rewarm frozen part quickly by immersing in warm water (if thawed and refrozen, warm at room temperature) 6. Do not rub - causes tissue death 7. Do not apply direct heat 8. Do not break blisters 9. Do not allow to walk after feet thaw 10. Discontinue warming as soon as part becomes flushed 11. Exercise thawed part 12. Separate fingers and toes with sterile gauze 13. Elevate frostbitten parts 14. Seek medical attention because of chance of infection, or gangrene. C. Treatment For all frostbite - rapid rewarming (thawing) as soon and as quickly as possible is the preferred treatment. Do not warm tissue that will only be refrozen, or warm feet if they are to be walked upon. Second degree frostbite requires medical attention and the victim should not be re-exposed to the cold. D. Prevention 1. Fatigue, cigarettes, alcohol, lack of food and drink, clothing which restricts circulation, and any other factors which reduce circulation will contribute to frostbite. 2. Properly insulate all body parts. Extreme cold may require a face mask. Use insulated gloves and boots. 3. Winds and wetness will accentuate frostbite. Keep dry and do not expose skin to the wind. 4. Be observant of each other. Look at ears, rosy cheeks, etc. Often the victim does not realize he has frostbite. IDENTIFICATION AND TREATMENT OF HYPOTHERMIA Hypothermia is a systematic lowering of the body temperature. Extreme cases (core temperature below 90o F) result in death of the victim. Hypothermia is the most common cause of death for persons involved in outdoor wilderness sport activities. It does not require freezing temperatures and, in fact, can occur in ambient temperatures as high as 70o F. Wind and wetness greatly accentuate hypothermia due to the enhanced cooling. Typical hypothermia conditions are a rainy, windy day with 50o F air temperatures. A. Symptoms 1. First Stage: goose bumps, shivering, feeling chilly 2. Second Stage: violent shivering, blue lips, pale complexion, feeling extremely cold 3. Third Stage: no longer feel cold, lack of coordination, mild unresponsiveness, drowsiness, stumbling 4. Fourth Stage: failing eyesight, victim barely responsive, cannot speak, barely able to or cannot walk. 5. Fifth Stage: coma and rapid death B. Treatment For all levels - remove wet, frozen or restrictive clothing. Dry the victim. Rewarming should be via an external heat source which completely envelopes the victim - a warm vehicle, a warm room, a sauna, a tub of warm water, by placing the victim in a sleeping bag with another person(s), etc. - and not a source of radiant heat which will warm only one side of the victim. Be prepared to administer CPR. Do not give the victim alcohol. 1. First Stage: Put on hat, shirt, additional clothing, wind breaker, etc. Eat and drink. Exercise on tense muscles. 2. Second Stage: Same as above, only more so. Warm drinks and rewarm if possible. NOTE: In hypothermia beyond second stage, the victim can no longer warm himself and must have an external heat source. 3. Third Stage: Rewarming, warm food and drink. 4. Fourth Stage: Remove wet or cold clothing and gradually rewarm victim so that blood trapped in extremities is rewarmed before it is circulated back into inner body to prevent afterdrop. Afterdrop is a further lowering of the body core temperature which results from recirculation of cold blood. Avoid hot, radiant heat sources which will warm surface blood before inner blood has been warmed. Do not give warm drinks which fool the body internally into feeling it is warm. Fourth stage hypothermia victims are best treated by supervised, experienced medical help, as complications can cause death. Place victim in warm vehicle and evacuate immediately to a medical facility. 5. Fifth Stage: Gradual rewarming, but requires sophisticated medical help to prevent death from after shock ( a recirculation of chilled blood causing heart fibrillation). C. Prevention 1. Wear proper clothing which will insulate the body, keep it dry and break the wind. 2. Cover the head, neck, wrists, and ankles in particular, as heat loss is most prevalent from these points. 3. Eat and drink warm fluids. Avoid eating snow. 4. Keep active to raise body temperature. 5. Avoid fatigue, alcohol, smoking and drugs. 6. Be aware of team members' condition and note symptoms. STANDARD OPERATING PROCEDURE NUMBER 4 Confined Space Entry Policy CONFINED SPACE ENTRY PROCEDURES A. Confined Space Classification OSHA has recently implemented the "Permit-Required Confined Space Entry" Standard. This regulation establishes a series of requirements for spaces which meet the definition of a permit-required confined space. In this project, trenches or excavations in excess of five feet in depth which will be entered by employees, meet the definition of a confined space. For each of these spaces, if there is a potential for exposure to an oxygen-deficient, toxic, or combustible environment, or if there is the potential for entrapment or engulfment due to soil stability, or rain, that space meets the definition of a permit-required confined space. Entry to this space requires the issuance of an entry permit, along with a series of requirements for training, supervision of the entry, and preparation for a rescue, should one be required. Prior to entry, the trench or excavation must also be properly trench, shored, or benched to prevent spillage of dirt into the hole where workers are present. B. Entry Procedures Team Size - A minimum of three workers is required for each confined space activity (two entry and one standby; or one entry, one rescue, and one standby). The one entry/one rescue/one standby arrangement should only be used when the confined space is relatively small and/or the entry person will be in the line of sight at all times. In this instance, the rescue person acts as the second person in the "buddy system." The two entry/one standby arrangement is used when the area of the confined space is larger, and the tasks may take the worker away from the entryway. Again, care must be taken with this arrangement because the standby person cannot enter the confined space and attempt rescue unless adequately protected (i.e., respiratory and dermal) and replaced by another qualified standby person. This number of workers is the minimum buddy for these activities and, in most cases, should only be used for relatively nonhazardous confined spaces. Additional crew may be needed if entering a permit-required confined space. Additional crew could include rescue, decontamination, and line-of-sight personnel. C. General Entry Procedures The following steps must be taken when entering a confined space: 1. Inspect all pieces of equipment to ensure they are in good working order. DO NOT ENTER CONFINED SPACE WITH DEFECTIVE EQUIPMENT. 2. Conduct a background check to identify all potential hazards that may be encountered in the confined space. Determine if there is a potential for fire/explosion hazards, as well as a potential for a toxic or oxygen-deficient atmosphere. 3. Before entry, the atmosphere inside the confined space must be tested. An attempt should be made to test the atmosphere without opening the entryway (i.e., through a vent line or a small opening). If the entryway must be opened to test and only low levels are expected in the confined space, crack open entryway, test breathing zone first, and then test the confined space. If potentially high levels are expected in the breathing zone, respiratory protection should be worn prior to opening the entryway cover. 4. If explosive, toxic, or oxygen-deficient atmosphere is detected, purge or ventilate the confined space prior to entry. Retest the atmosphere three times at 5-minute intervals. A person can enter the confined space without respiratory protection only if all three test results are below the Permissible Exposure Limit/Threshold Limit Value (PEL/TLV), 10 per cent of the LEL, and above 19.5 per cent oxygen (all three conditions must be met). (NOTE: Any downward deflection of the readings on the oxygen meter from background (i.e., 20.9 per cent) should be viewed as a potential for an IDLH atmosphere. Unless contaminants are known to be nontoxic, do not enter the confined space without respiratory protection if the oxygen level is below background.) 5. Blank, double block and bleed, or otherwise isolate, lockout, and tag all chemical, physical, and/or electrical hazards wherever possible. Reduce all forms of energy to a zero energy state. 6. If using an air-purifying respirator or if an IDLH and/or explosive atmosphere exists, air monitoring must be on a continuous basis. If respiratory protection is not used and there is potential for atmospheric conditions to change due to work practices or conditions, air monitoring should be done periodically. In all these cases, a 5-minute escape pack must be used. 7. Record all results of the tests for hazardous conditions including the location, time, date, weather (if applicable), and readings on the PID, combustible gas meter, oxygen deficiency meter, Drager tubes, and any other equipment. 8. Wear appropriate clothing for site conditions, as determined by the Site Safety and Health Officer (SSHO). 9. A safety belt or harness with lifeline must be worn if hazardous conditions exist, although good safety precautions dictate their use regardless of "existing" conditions. If the diameter of the entryway is less than 18 inches, the wrist-type harness must be used and special provisions made if a supplied air respirator is necessary. 10. One person (standby) must remain at the entryway at all times and must keep continuous contact with the person entering the confined space. Contact can be maintained by line- of-sight, listening for sounds, the safety line, and/or radio. The standby person must not enter the confined space unless another trained person is available to act as standby, and he/she is equipped with adequate respiratory and dermal protection. (In most cases, respiratory protection would be an airline respirator or SCBA.) 11. Do not smoke when working in or near confined spaces and do not take flash-lighted photographs when explosive gases are known or suspected to be present. 12. Do not rely on permanent ladders because they are often in poor condition. If they must be used, be sure of footing. Inspect permanent ladders for deterioration before entering and while descending. Try each step with one foot, while standing on the step above. When in doubt, use a portable ladder of adequate height to reach 3 feet above opening or a rope ladder, or lower the entry person using the tripod. If a portable ladder is used, it should be tied off, if possible; otherwise, it should be held in place by the standby person. 13. Do not work without adequate lighting. Use only "explosion-proof" lights or hand lamps. 14. The entry person must not remain in the confined space if he/she becomes even slightly drowsy, faint, dizzy, or otherwise uncomfortable. Many of the gases that cause the most problems are odorless, tasteless, and invisible. D. MANHOLE/SEWER ENTRY There are no reported plans to enter manholes or sewers as a part of this project. The following information is included in the event the scope changes to include such activities. The Plan should be reviewed at that point, prior to any entry to a manhole or sewer. When preparing to enter a manhole/sewer, the following safety measures must be taken: 1. Inspect all pieces of equipment to ensure they are all in good working order. DO NOT ENTER CONFINED SPACE WITH DEFECTIVE EQUIPMENT. 2. Park the vehicle near the manhole (do NOT leave the vehicle running). If the manhole is in the street, it is best to park so as to detour oncoming traffic around the manhole. The vehicle's emergency flashers and portable yellow warning beacon must be ON. The vehicle serves as protection from oncoming traffic, can be used to store emergency equipment (e.g., SCBA and first aid kit), and can be used in an extreme emergency to slowly pull an injured person from the confined space if a tripod with hoist attachment is unavailable or inoperative. 3. Erect portable barricades or cones around the manhole and in front of the vehicle to see that traffic is adequately diverted and to prevent pedestrians from falling in. Reflective vests should be worn so that workers are visible to approaching traffic. 4. If there are openings large enough to admit sampling tubes, test for the presence of explosive and toxic gases before removing each manhole cover. Otherwise, raise one side of the cover using the cover hook or pick, prop it slightly open, and conduct the tests. 5. If toxic or explosive gases are detected in the sewer, report this immediately to the local Fire Department and/or Department of Public Works. 6. Record the results of tests for hazardous conditions, including location, manhole number (if applicable), time and date, weather (if applicable), and the readings on the PID, combustible gas meter, oxygen deficiency meter, and Drager tube. 7. Remove manhole covers with a cover hook or pick; do not improvise. Be careful of fingers and toes; the cover is usually heavy and difficult to handle. Unless the cover is extremely heavy, it is safer for only one worker to handle it. 8. Test the atmosphere; if a toxic, flammable, or oxygen-deficient atmosphere exists, ventilate the sewer. Depending on the hazard, ventilation can be accomplished in a variety of ways: for example, (1) remove and vent the adjoining upstream and downstream manhole covers, as soon as possible, and well in advance of entering the manhole (high hazard); and (2) vent the manhole in which entry will occur (very low hazard). If a blower is used, it is desirable to establish a flow of air in the sewer, in one manhole and out another. Ensure that the air intake is well away from automobile exhaust, and combustible and/or toxic atmospheres. Appropriate traffic control measures must be taken by barricading or otherwise marking the open manholes. 9. After ventilating, test for explosive and toxic gases and oxygen deficiency in the manhole at ground level and at the bottom; record results. If entering the sewer itself, make the same tests at the manholes at either end. If ventilation is necessary, monitor the atmosphere in the manhole while work progresses, or continue operation of the blower. Continuous monitoring (i.e., equipment ON during entire entry) is imperative because conditions within the sewer may change rapidly. Do not enter a manhole while there is an oxygen deficiency without a pressure-demand, air-supplied breathing apparatus. If the oxygen level is lower than 20.9 per cent of background, caution must be taken because an IDLH atmosphere may exist. 10. When entering manholes or tanks, wear hardhats, protective clothing, and unless inappropriate, respiratory protection and safety belt or harness with lifeline. If the manhole is less than 18 inches in diameter, a wrist-type harness must be used and special provisions made if air-supplied respirators are necessary. When working in manholes greater than 12 feet deep, in the sewer itself, of where potential exists for gases to appear unexpectedly, a 5-minute emergency egress air supply is required (unless the time required to don the emergency respirator is greater than what would be needed to exit the manhole.) 11. At least one person (i.e., standby) must remain at the manhole at all times and must keep continuous contact with the person entering the sewer. Contact can be maintained by line-of-sight, listening for sounds, and the safety line and/or radio. The standby person must not enter the manhole unless another trained person is available to act as standby and has adequate respiratory and dermal protection available. (in most cases, respiratory protection will be an airline respirator or SCBA). The standby/rescue person should be suited up (but not yet on air) before the work crew enters the confined space. 12. Do not smoke when working in or near manholes. Do not take flash-lighted photographs when explosive gases are known or suspected to be present. 13. Do not rely on the manhole ladders because they are often in poor condition. If they must be used, be sure of footing. Inspect manhole ladders for deterioration before entering and while descending. Try each step with one foot, while standing on the step above. When in doubt, use a portable or rope ladder of adequate height to reach 3 feet above the manhole opening, or lower the entry person using the tripod. If a portable ladder is used, it should be tied off if possible; otherwise, it should be held in place by the standby person. 14. Do not work without adequate lighting. Use only "explosion-proof" lights or hand lamps in the manhole or sewer. 15. The entry person must not remain in the manhole or sewer if he/she becomes even slightly drowsy, faint, dizzy, or otherwise uncomfortable. Remember that carbon monoxide, carbon dioxide, methane, and hydrogen sulfide, which cause the most trouble, are odorless (hydrogen sulfide has a distinct odor only during initial exposure), tasteless, and invisible. STANDARD OPERATING PROCEDURE NUMBER 5 Materials Handling/Moving/Lifting MATERIAL HANDLING/MOVING/LIFTING Improper materials handling accounts for a large number of occupational injuries. Materials handling at hazardous waste sites can vary from heavy equipment handling to manually handling items. Hazards associated with materials handling include physical injury, detonation, fire, explosion, and vapor generation. When using equipment to move materials, proper work practices must be followed. Equipment used must be designed for the task to be performed. Equipment must be inspected regularly by the SSHO and the Project Manager, and damaged or defective equipment must be removed from service. Planning is critical when handling materials. The Project Manager must plan where the materials are to be moved, taking into consideration the current location of such materials and hazards associated with moving them. Routes for moving materials must be clearly outlined, with paths cleaned of all obstructions so materials may be transported. Injuries to the back and abdominal muscles from improper lifting of loads is one of the most common occupation injuries reported. Such injuries can range from relatively mild strains to major permanently disabling injuries. Before lifting any load, personnel should consider the overall weight, distribution of weight, unwieldiness or awkwardness of the load, distance to be carried, obstacles to be negotiated, site conditions, and visibility. Loads should be inspected for slivers, sharp edges, slippery surfaces, etc. prior to lifting. Loads should be lifted using the power of the leg muscles rather than the back, stomach or arm muscles. Approach the item to balance the load evenly. Never bend over when lifting. The back should be kept straight and the arms nearly parallel with the body. The knees should be bent to grasp the load. Lifting should be done by straightening the legs, holding the load as close to the body as possible and the back remaining as straight as possible. Bulky, heavy loads should be handled by at least two people, ensuring that the load is level and evenly distributed between all personnel helping to carry it. All carriers should know the destination and path for the load. STANDARD OPERATING PROCEDURE NUMBER 6 Heavy Equipment Hazards HEAVY EQUIPMENT HAZARDS The use of heavy equipment (e.g., backhoes, dump trucks, cranes, excavators, generators, compressors, etc.) may pose a variety of health and safety hazards to site workers. All heavy equipment work must be conducted only by trained, experienced personnel. Equipment backing up, swinging loads, buckets, booms, and counter-weights pose serious hazards to ground personnel. Dowling Corporation personnel must remain outside the turning radius of any large, moving equipment. At a minimum, all personnel must maintain visual contact with the equipment operator when the equipment is active. No personnel are permitted to work underneath ANY active load, the backhoe or other heavy equipment, because this practice poses serious crushing hazards. Belts, pulleys, sheaves, gears, chains, shafts, clutches, drums, flywheels, and other moving parts of equipment can pose injury hazards. No guard, safety appliance, or other device may be removed or made ineffective unless repairs or maintenance are required, and then only after power has been shut off and locked out. Safety devices must be replaced once repair/maintenance is complete. Exhaust from all equipment powered by steam or combustion engines must be properly located so that release of exhaust does not endanger workers or obstruct the view of the operator. Gasoline-operated equipment must be re-fueled properly to prevent fire hazards; power must be off, no smoking allowed, and proper dispensing equipment must be used. When not operational, equipment shall be set and locked so that it cannot be activated, released, dropped, etc. Backhoe buckets must be lowered to the ground. STANDARD OPERATING PROCEDURE NUMBER 7 Underground Utilities UNDERGROUND UTILITIES Underground utilities pose hazards to workers involved in drilling, excavation, soil vapor contaminant analysis, and other invasive operations. These hazards include electrical hazards, explosion, and asphyxiation, as well as costly and annoying hazards associated with damaging communication, sewer, water, and/or irrigation lines. The estimated location of underground installations, including sewer, telephone, fuel, electric, water lines, or other underground installations that reasonable may be expected to be encountered during invasive work shall be determined prior to the start of any invasive work. This may be determined by contacting appropriate utilities, contacting a utility clearance service, using site maps and prominent site features, using a pipe and cable locator, etc. Buried utilities encountered during invasive operations must be protected while digging to prevent risks to site personnel and damage to the utilities. The Contractor must request and received an assessment of the site from DIGSAFE. The telephone number for DIGSAFE in MA, ME, NH, RI and VT is (888) DIG-SAFE or 8-1-1. APPENDIX I Public Involvement Mansfield, MA Amherst, MA Chester, VT February 8, 2022 Gina-Louise Sciarra, Mayor City of Northampton 210 Main St., Rm. 12 City Hall Northampton, MA 01060 Board of Health 212 Main Street Northampton, MA 01060 VIA: CERTIFIED MAIL Re: Phase IV Remedy Implementation Plan (RIP) Former Cutlery, 360 Riverside Drive Northampton, Massachusetts DEP RTN: #1-13320 OHI Project #13-1515 Dear Municipal Officials, In accordance with the requirements of the Massachusetts Contingency Plan (MCP), OHI Engineering, Inc. is writing to notify you, as the Chief Municipal Officer and the Board of Health, that a Phase IV Remedy Implementation Plan (RIP) has been submitted to the Massachusetts Department of Environmental Protection (MassDEP). The Phase IV RIP involves restoration of the retaining wall along the base of the former Cutlery headrace levee from its upstream origin downstream to the vicinity of MW-4 where a wider flood plain area dissipates the energy of the Mill River. The goal of the proposed work is to prepare the Site for a Permanent Solution with Conditions. Approximately 800 cubic yards of metals-impacted soil will be removed from portions of the bank of the Mill River and relocated to the existing stockpile which will be expanded over areas of the former head race which already contain similar soils. The purpose of the work is to repair the retaining wall and relax the angle of the slope and then cover it to reduce erosion of metals-impacted soil into the Mill River. The stockpile is located north of Valley Home Improvement on Cutlery property. The new soil added to the stockpile will be covered with an orange marker layer and loam and seed to match the existing stockpile The Phase IV RIP is available at the MassDEP at 436 Dwight Street in Springfield, Massachusetts and at the DEP’s web site: http://public.dep.state.ma.us/SearchableSites2/Search.aspx using the address above. An electronic copy of this Phase IV RIP has also been provided to the Northampton Planning Department and can likely be found on their web site. This work was completed in accordance with the guidelines established in the MCP (310 CMR 40.0000). Very truly yours, OHI ENGINEERING, INC. Lyons Witten, P.G., L.S.P. Regional Manager cc: Northampton Planning Department Northampton Conservation Commission 110 Pulpit Hill Road Amherst, MA 01002 Tel (413) 835-0780 www.ohiengineering.com 44 Wood Avenue Mansfield, MA 02048 Tel (508) 339-3929 Fax (508) 339-3140 110 Pulpit Hill Road Amherst, MA 01002 Tel (413) 835-0780 Fax (413) 549-7918 P.O. Box 579 Chester, VT 05143 Tel (802) 885-1909 www.ohiengineering.com