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REVISED-NHESP_Phase IV RIP-Wall Repair Alternatives Analysis 2022-04-18Mansfield, MA Amherst, MA Chester, VT Phase IV RIP MEMO – Wall Repair & Alternatives Analysis Date: April 18, 2022 RE: Former Cutlery 360 Riverside Drive Northampton, MA 01060 NHESP Tracking No.: 12-31337 RTN: #1-13220 OHI Project #13-1515 A Phase IV Remedy Implementation Plan (RIP) for the Former Cutlery (OHI, February 8, 2022) was submitted to MassDEP BWSC and a corresponding Notice of Intent (NOI) was submitted to the Northampton Conservation Commission. Copies of these documents were submitted to the Massachusetts Natural Heritage & Endangered Species Program (NHESP) who provided a letter dated March 25, 2022 requesting additional information. This memo provides responses (in plain text) to the requested additional information (in italics) below. Cutlery Building Associates is mandated by MassDEP BWSC and the MCP to implement a Permanent Solution for this Site, and the Phase IV RIP details how this can occur. OHI has chosen repair options that will last, using our experiences at this Site and Professional Engineering standards.   1) Alternatives Analysis: Assessment must explore options for the feasibility of bioengineering or  hybrid bioengineering/hardened solutions for the existing wall repair and the proposed  stabilization; in particular, alternatives to the proposed gabion baskets and dry laid boulders.   The Site is the former raceway that carried water from the Mill River to the former Northampton Cutlery mill building. 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 separates 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 110 Pulpit Hill Road Amherst, MA 01002 Tel (413) 835-0780 www.ohiengineering.com Wall Repair Alternatives Analysis RTN #1-13320 Former Cutlery OHI Project #13-1515 360 Riverside Drive April 18, 2022 Page 2 Northampton, MA 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. Alternative remediation strategies and bank repairs at this MCP Site have been evaluated and submitted to MassDEP several times in the past: 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. Multiple remedial options were evaluated and different solutions chosen for each of the three AOCs at the Site. 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. 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. Wall Repair Alternatives Analysis RTN #1-13320 Former Cutlery OHI Project #13-1515 360 Riverside Drive April 18, 2022 Page 3 Northampton, MA Phase IV – Interim Construction Report, by NEE, August 2, 2005 MCP Phase IV REVISED Remedy Implementation Plan, by NEE, September 2005 Problems were encountered with some of the RIP tasks. The tasks were revised and submitted to MassDEP and Northampton Conservation Commission who then requested a Comprehensive NOI for the Site. REVISED Remedy Implementation Plan, by NEE, May 2006 Comprehensive NOI AOC-1: In all areas where exceedance of an Upper Concentration Limit (UCL) of any metal was identified, this material was removed, and consolidated in the stockpile in AOC-2. West of the Cutlery Building and Firehouse, the remaining metals-impacted soil along the bank leading down to the Mill River were physically stabilized in place and an AUL was extended from the parking lots down to the river’s edge. A chain-link fence was erected along the west side of the parking lots in AOC-1 to restrict access to the bank. 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. The marker layer was then 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 was 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 was 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 were boulders, and these were not 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 with materials designed to physically stabilize the bank against future erosion. At the base of established trees, the soil layer was reduced to zero so that the trees’ root systems and trunks are not suffocated. This alternative solution, completed in 2007, left most of the contaminants in place at the Site, but in a stabilized form that would not be available to the environment. It also placed the worst of this material in a location farther from the Mill River (stockpile within AOC-2) or used it to protect the river from likely future degradation (AOC-1). Cutlery Raceway Slope Stabilization, by NEE, Summer 2010. In AOC-1 behind the Cutlery Building, 130 linear feet of eroding bank was restored immediately upstream of the tailrace. Much of this area had been covered in erosion control fabric and bio-logs in 2006/2007, but those materials did not withstand the flood water forces of the Mill River and needed a stronger solution. Coir bio-logs were anchored in at the toe of slope with CF 700 fabric secured underneath. The first geo- lift consisted of one foot of loam blown into place on a fold of the CF 700 fabric creating a 4’ shelf, which was then seeded and the fabric was pulled up and over to stabilize the lift. This process was repeated two additional times creating three pillows of seeded loam. Saplings were planted between each geo-lift. The remaining slope above the three geo-lifts was covered in CF 700, and sprayed with loam and seeded. Wall Repair Alternatives Analysis RTN #1-13320 Former Cutlery OHI Project #13-1515 360 Riverside Drive April 18, 2022 Page 4 Northampton, MA Cutlery Raceway Slope Stabilization, Wetland Restoration Monitoring Report, by NEE to Northampton Conservation Commission, November 16, 2010. In 2010, the bank stabilization work at the Site was assessed, including vegetational cover as required by the Order of Conditions. Stabilized Slope Adjacent to Cutlery and Firehouse (AOC-1) This area was stabilized under the 2004 Order of Conditions and the 2007 “revised remediation plan.” Work was done around pre-existing trees. Portions of this area had slopes over 3:1, and the orange fencing was 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 did not have any signs of erosion. The area was minimally disturbed and shows no signs of erosion after three years. 2010 Repair Area - Upstream Immediately downstream of the above area was an 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 was 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. The vegetative cover of this area was approximately 20%. The vegetation was growing well and there was no further sign of erosion. 2010 Repair Area – Downstream A second area of bank repair was completed downstream and near the Cutlery Building in 2010. This area also was becoming undercut and the repairs were similar to the above. This area was 130 feet in length, and consisted 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. Cutlery Raceway Slope Stabilization, by NEE, Summer 2012. In AOC-1 behind the Cutlery Building, flood water damage required a CF 700 patch at the downstream end of the 130 linear feet of eroding bank that was restored in 2010. In AOC-3, erosion repair was necessary along 93 feet of the bank above the dry-laid stone wall. A portion of the stone wall required rebuilding in order to create a stable base for this repair. Coir bio-logs were anchored in at the toe of slope above the wall, with CF 700 fabric secured underneath. A single geo- lift consisting of one foot of loam blown into place on a fold of the CF 700 fabric creating a shelf, which was then seeded, and the fabric was pulled up the remaining slope and secured with landscape staples. The geo-lift and CF 700 were sprayed with loam and seeded. Two sections of the 93 feet had less severe erosion and were treated with a lighter straw blanket. 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. Wall Repair Alternatives Analysis RTN #1-13320 Former Cutlery OHI Project #13-1515 360 Riverside Drive April 18, 2022 Page 5 Northampton, MA 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. Periodic Review of Temporary Solution, by OHI, February 17, 2016 AOC-2 and AOC-3 were each closed in February 2011 with a Class C-1 RAO-P. In accordance with 310 CMR 40.1055(3), the Site was considered to have achieved a Temporary Solution With Conditions, which was the subject of this Periodic Review. The following remedial alternatives were considered during this five-year review: No Further Action, Monitored Natural Attenuation (MNA), Stabilization and Disposal of TCLP Metals, Stabilization of All Metals and Leave On-Site, Excavate & Off-Site Disposal, Engineered Barrier, and Phytoremediation. It was not feasible to achieve a Permanent Solution at the Site at that time. The contaminants did not appear to have dissipated over time and were not likely to decompose via a process of unassisted microbial action. Therefore, monitoring the status quo did not appear to meet the remedial objectives of a Permanent Solution for the Site, but was an appropriate action under the Temporary Solution. 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 was an outcome of several of these inspections. 2020 Erosion Repair Work During the August 6, 2020 site inspection, Mr. Lyons Witten, LSP noted six areas along the upper levee in AOC-3 where the bank was found to be eroding, and erosion noted at the tailrace stone wall (upriver side) at the downstream end of AOC-1. The identified erosion areas were repaired in October 2020 using straw blanket fixed to the slope using six-inch landscape staples and woody material already on the slope. Orange marker layer was replaced where missing. Straw wattle held in place with wooden stakes was used at the toe of each section to affix the straw blanket (and orange marker layer in AOC-1). The AUL Annual Inspection Report submitted on February 17, 2021 outlined erosion control repairs completed as a result of issues identified during the 2020 annual AUL inspection. Periodic Review of Temporary Solution, by OHI, February 17, 2021 AOC-2 and AOC-3 were each closed in February 2011 with a Class C-1 RAO-P. In accordance with 310 CMR 40.1055(3), the Site was considered to have achieved a Temporary Solution With Conditions, which was the subject of this Periodic Review. The following remedial alternatives were considered during this five-year review: No Further Action, Monitored Natural Attenuation (MNA), Stabilization and Disposal of TCLP Metals, Stabilization of All Metals and Leave On-Site, Excavate & Off-Site Disposal, Engineered Barrier, and Phytoremediation. It was not feasible to achieve a Permanent Solution at the Site at that time. The contaminants did not appear to have dissipated over time and were not likely to decompose via a process of unassisted microbial action. Therefore, monitoring the status quo did not appear to meet the remedial objectives of a Permanent Solution for the Site, but was still an appropriate action under the Temporary Solution. Phase IV Remedy Implementation Plan (RIP), by OHI, February 8, 2022 Following the February 2021 evaluation, an LSP inspection of the Site after spring snow melt Wall Repair Alternatives Analysis RTN #1-13320 Former Cutlery OHI Project #13-1515 360 Riverside Drive April 18, 2022 Page 6 Northampton, MA 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. 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 above areas of collapsed retaining wall. The levee retaining wall 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 impact of a slowly degrading retaining wall is that there is more and more erosion of the bank into the Mill River. The 100-year flood elevation is well above the top of the retaining wall along almost all of the length of this project, and 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). 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 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 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. Summary In considering the design options for this retaining wall restoration, OHI reviewed the prior bank stabilization designs and strategies.  The compost pillow geo-lifts employed in AOC-1 in 2006, 2010, and in AOC-3 in 2012 have little compost left in them and needed repair in 2020 and 2021. This construction detail/design works well in low water energy areas of this Site, but is not substantial enough to withstand annual spring flood water forces below the 100-year flood elevation;  The straw blankets and coir wattle repairs last several years after installation and then all that remains is the poly netting within them and they become less effective. Areas within AOC-3 treated with straw blanket have required additional erosion repairs within 5 to ten years;  Bioengineered solutions have not been successful over the long term at this Site, especially in areas of high flow velocities. They require regular repair and maintenance Wall Repair Alternatives Analysis RTN #1-13320 Former Cutlery OHI Project #13-1515 360 Riverside Drive April 18, 2022 Page 7 Northampton, MA and would not be a suitable option to achieve the required Permanent Solution;  Full excavation of metals-impacted soil is financially infeasible. Therefore, the metals- impacted soil must be covered in place in a manner that makes them inaccessible and keeps them in place for many generations;  The bank is too shaded for most of the plantings that have been attempted over the last decade to become established;  As more of the stone retaining wall fails due to the water forces of the Mill River, more of the bank above it will end up in the river, along with its entrained heavy metals. This is a vicious cycle, since the more the wall degrades, the easier it is for the Mill River to rip more of the wall from the bank;  OHI evaluated a number of “hard” solutions and chose the most natural materials available for various areas of the repair. The stone wall will be repaired using stone and gabion baskets filled with stone. The 100-year flood plain above the wall will have stone rip-rap installed to hold the bank in place during times of flooding. The slope above will have turf mat and native grasses. The entire slope angle will be relaxed in order for the installation package to withstand the forces of the Mill River for generations to come; and,  105 feet of new stone wall will be installed to help the most downgradient portions of the newly-relaxed steep slope stay in place. This is in addition to 56 lineal feet of repaired existing wall below Ordinary/Mean High Water and above Land Under Water Body. Cutlery Building Associates is mandated by MassDEP BWSC and the MCP to implement a Permanent Solution for this Site, and the Phase IV RIP details how this can occur. OHI has chosen repair options that will last, using our experiences at this Site and Professional Engineering standards.     2) Impact Calculations: Provide clear impact calculations (cumulative square footage) associated  with the temporary construction matting proposed riverward of the existing walls; and  excavation associated with wall replacement with gabion baskets.   The requested impact calculations are provided in the Revised NOI dated April 2022, along with the previously provided square foot calculations of impacts within wetland resource areas.   3) Site Plan Revisions: The site plans must be revised to detail:   a) Depict the ordinary high‐water line in relation to the elevations of the existing wall;   Ordinary High-water is coincident with Mean Annual High Water at this Site. Labels on the plans have been changed to make this clear. b) It appears that construction matting and equipment access is proposed below MAHW. The  plans must include the proposed construction matting layout, access, and anchoring  methods.   Construction matting layout below MAHW has been added to the plans. Wall Repair Alternatives Analysis RTN #1-13320 Former Cutlery OHI Project #13-1515 360 Riverside Drive April 18, 2022 Page 8 Northampton, MA c) The cross sections of bank stabilization methods (Types A‐D; Sheet C8.2) do not include  MAHW or a range thereof. Further clarification regarding excavation of soils below MAHW,  MALW, particularly in relation to the installation of gabion baskets. The plans must be  revised to include these clarifications.   A Profile Plan has been added to the plans as sheet C10.1