Memo to ConComm re Cutlery NOI (11-30-22) (1).pdfMansfield, MA Amherst, MA Chester, VT
To: Northampton Conservation Commission Date: November 30, 2022
RE: Response to Requests for Additional Information
Former Cutlery 360 Riverside Drive Northampton, MA 01060 NOI No.: WE 246-0761 RTN: #1-13220 OHI Project #13-1515
During the continued public hearing held on November 10, 2022, for the referenced NOI, the Commission requested that the applicant provide some additional information as follows:
1. Options for replication of the area of Isolated Wetland (“IW”) being impacted by the work;
2. Options for removing the existing chain link fence along Riverside Drive or at least creating some areas for wildlife passage;
3. Information regarding the standard for achieving a Permanent Solution under the MCP and
how long the stabilization is required to last; and
4. Information about groundwater monitoring in the context of this 21E site and the decommissioning of monitoring wells once the Permanent Solution filing is completed. The following information is provided to address these requests.
1. IW Replication
A total area of approximately 678 square feet (SF) is proposed for replication immediately north of the IW, to replace 549 SF being occupied by the stockpile extension and 129 SF from relaxation
of the slope. A plan depicting these areas is provided as Attachment A.
The replication area will be created by excavating the top 12” of soil (which will be incorporated into the stockpile) at the 199-foot contour. This will bring the replication area to the same elevation as the existing IW, and it is anticipated that the subsoil in the area will be suitable for replication. The 678 SF area will then be seeded with a New England Wetland Seed Mix (see Attachment B
for a species list). The replication area will be monitored annually through two consecutive growing seasons, and reports will be submitted to the Commission. If this replication plan is approved, a revised sheet will be submitted for the final plan set showing the adjustments to the limit of work and erosion controls in this area.
110 Pulpit Hill Road Amherst, MA 01002 Tel (413) 835-0780 www.ohiengineering.com
Response to Requests for Additional Information – DEP File No. WE 246-0761 Former Cutlery OHI Project #13-1515 RTN #1-13320 360 Riverside Drive November 30, 2022 Page 2 of 3 Northampton, MA
2. Options for Changes to the Chain Link fence along Riverside Drive
Under the current Temporary Solution the full fence is required, and the fence cannot be removed
under Chapter 21E until a Permanent Solution is achieved. As previously stated, the applicant
cannot remove the fence entirely in order to restrict public access on private property, but holes can be cut in the bottom of the fence (e.g., 12 inches high and 18 inches wide) to allow for small animal passage.
3. Standards for achieving a Permanent Solution under the MCP and how long the stabilization is required to last. The standards in the MCP for a Permanent Solution are the following:
o 310 CMR 40.0006 - “Permanent Solution” means “a measure or combination of
measures which will, when implemented, ensure attainment of a level of control of each identified substance of concern at a disposal site or in the surrounding environment such that no substance of concern will present a significant risk of damage to health, safety, public welfare, or the environment during any foreseeable period of time.”
o 310 CMR 40.1005(2) - “Any foreseeable period of time” shall mean the period of time during which the conditions for achieving and maintaining a level of No Significant Risk
upon which a Permanent Solution is based will remain in effect.
(a) For Permanent Solutions with No Conditions, “any foreseeable period of time”
shall be an unlimited period of time;
(b) For Permanent Solutions with Conditions, “any foreseeable period of time”
shall be the shortest period of time, as applicable, that:
1. Activity and Use Limitations, where required to maintain a Permanent Solution, remain in effect;
2. Exposure Pathway Mitigation Measures, where required to maintain a
Permanent Solution, remain in effect; or
3. other conditions on which the Permanent Solution with Conditions is based for which an Activity and Use Limitation is not required, as specified at 310 CMR 40.1013, remain in effect.
The stabilization with Blastox is permanent. The Blastox® Technical Bulletin (TB-006 Issued 1-
98), which is included in the Phase IV Remedy Implementation Plan filed with the NOI, states:
Blastox® utilizes an initial pH adjustment followed by additional stabilization reactions that
produce a long-term stable waste. The stabilization 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.
Response to Requests for Additional Information – DEP File No. WE 246-0761 Former Cutlery OHI Project #13-1515 RTN #1-13320 360 Riverside Drive November 30, 2022 Page 3 of 3 Northampton, MA
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 byproduct 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. Since the metals become insoluble, there is no longer a concern that the treated soil will leach lead
to groundwater at the Site. This is one important factor in the Risk Characterization determination
of No Significant Risk (NSR) and achieving a Permanent Solution at the Site. Since the reactions
are not reversible, this response action meets the definition of “any foreseeable period of time.” Under Section 3.12 of the Phase IV RIP, once work is completed, the existing Activity and Use Limitation (AUL) will require modification to reflect the presence of the engineered barrier. AUL
modification will be accomplished as part of the Permanent Solution submittal for the Site. Under Section 3.13 of the Phase IV RIP, the Post-Construction Monitoring & Maintenance Plan (PCMMP) requires post-construction monitoring for a minimum of 30 years following the
construction of the risk reduction barrier. The PCMMP will mirror the AUL requirements for this
Site. One of these is annual inspections by a Licensed Site Professional. There is no time limit in
the AUL for annual inspections, they will be required in perpetuity, meeting the minimum standard of 30 years of monitoring required under the PCMMP. 4. Information about groundwater monitoring in the context of this 21E site.
This site does not have conditions of groundwater impact that require any remediation and no further monitoring is required. The existing monitoring wells will be decommissioned once the Permanent Solution statement is filed.
ATTACHMENT A
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ATTACHMENT B
Botanical Name Common Name Indicator
NEW ENGLAND WETLAND PLANTS, INC
New England Wetmix (Wetland Seed Mix)
820 WEST STREET, AMHERST, MA 01002
PHONE: 413-548-8000 FAX 413-549-4000
EMAIL: INFO@NEWP.COM WEB ADDRESS: WWW.NEWP.COM
Carex vulpinoidea Fox Sedge OBL
Carex scoparia Blunt Broom Sedge FACW
Carex lurida Lurid Sedge OBL
Carex lupulina Hop Sedge OBL
Poa palustris Fowl Bluegrass FACW
Bidens frondosa Beggar Ticks FACW
Scirpus atrovirens Green Bulrush OBL
Asclepias incarnata Swamp Milkweed OBL
Carex crinita Fringed Sedge OBL
Vernonia noveboracensis New York Ironweed FACW+
Juncus effusus Soft Rush FACW+
Aster lateriflorus (Symphyotrichum lateriflorum)Starved/Calico Aster FACW
Iris versicolor Blue Flag OBL
Glyceria grandis American Mannagrass OBL
Mimulus ringens Square Stemmed Monkey Flower OBL
Eupatorium maculatum (Eutrochium maculatum)Spotted Joe Pye Weed OBL
The New England Wetmix (Wetland Seed Mix) contains a wide variety of native seeds that are suitable for most wetland restoration sites
that are not permanently flooded. All species are best suited to moist ground as found in most wet meadows, scrub shrub, or forested
wetland restoration areas. The mix is well suited for detention basin borders and the bottom of detention basins not generally under
standing water. The seeds will not germinate under inundated conditions. If planted during the fall months the seed mix will germinate the
following spring. During the first season of growth several species will produce seeds while other species will produce seeds after the
second growing season. Not all species will grow in all wetland situations. This mix is comprised of the wetland species most likely to grow
in created/restored wetlands and should produce more than 75% ground cover in two full growing seasons.
The wetland seeds in this mix can be sown by hand, with a hand-held spreader, or hydro-seeded on large or hard to reach sites. Lightly
rake to insure good seed-to-soil contact. Seeding can take place on frozen soil, as the freezing and thawing weather of late fall and late
winter will work the seed into the soil. If spring conditions are drier than usual watering may be required. If sowing during the summer
months supplemental watering will likely be required until germination. A light mulch of clean, weed free straw is recommended.
PRICE PER LB.$135.00 MIN. QUANITY 1 $135.00TOTAL:APPLY: 18 LBS/ACRE :2500 sq ft/lbLBS.
New England Wetland Plants, Inc. may modify seed mixes at any time depending upon seed availability. The design criteria and ecological function of the
mix will remain unchanged. Price is $/bulk pound, FOB warehouse, Plus SH and applicable taxes.