30A-032 Application_Cutlery Building Associates
Sarah LaValley
From:Lyons Witten [lwitten@neeinc.com]
Sent:Monday, November 15, 2010 2:01 PM
To:Sarah LaValley
Cc:Alan Verson
Subject:RE: Cutlery Certificate of Compliance
Attachments:P1030890.jpg; DSC02817.jpg; 2006-08-02_IRA Plan-Amendment.pdf; 2006-08-18_IRA Plan
Amend DEP Approval.pdf
Sarah-
Stamped Plan: Unlike Professional Engineers who liberally stamp documents of all types (reports, plans, specifications,
etc.), Licensed Site Professionals (LSPs) are prohibited by the Commonwealth from stamping anything that is not an LSP
Opinion submitted directly to DEP. Therefore it is not possible for me to “stamp” the As-Built Site Plan for any project.
However, this is the As-Built Plan which I will submit to the DEP with my stamped LSP Opinion as part of the final
Response Action Outcome Statement for this project. My ability to make the RAO filing with DEP is dependent upon
receiving the Certificate of Compliance from your office/commission with regard to the wetlands work.
A “Hazardous Waste Site” sign was placed on the gate leading from the Valley Home Improvement parking lot going up-
river long ago, around 2003 if my memory serves me correctly. Attached please find a photo of that early sign (circa 2004)
when excavation was going on in the VHI parking lot. That original sign is no longer present, and has been replaced with
a “No Trespassing” sign. I do not know when that change occurred. The two gates in the 4’ CLF have never had such
signs. I have had three “No Unauthorized Entry, DEP State Hazardous Waste Site” signs made and these will be
installed, one on each gate, prior to the ConCom meeting this Thursday. “No Trespassing” signs are installed a regular
intervals on trees just inside the 4’high and 5’ high CLF, facing out to the parking lots and street. These extend from the
tail race at the southern end all the way up to the northern end of the Site. These signs are replaced periodically as
needed. Similar signs exist at the base of the bank facing the Mill River. This signage was in agreement with DEP
requests and our various IRA Plans over the years.
A current Wetland Plant Report based upon a recent Site Visit by Karro Frost of our office is attached. NEE is not aware
of other such reports.
Reference to the soil stockpile being re-worked, lowered, covered with orange fence marker layer, loam and seed is
attached in our August 2, 2006 IRA Plan Amendment & Other Related Activities letter to DEP. As noted in that letter:
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.
These alterations to the Stockpile were approved by DEP in their IRA Approval letter dated August 18, 2006 (copy
attached).
I do not know if you noticed, but the As-Built Plan submitted has a 2007 date on it (at least my office copy does). I will
bring the same plan with a current date to the meeting. I would like to exchange that for the old date copy for your use in
the official filing.
If you have any further questions, please do not hesitate to contact me,
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Lyons
Lyons Witten, PG, LSP
New England Environmental, Inc.
15 Research Drive
Amherst, MA 01002-2774
(413) 256-0202 x117
(413) 262-4009 (cell)
(413) 658-2057 (Direct Phone Line)
(413) 658-2077 (Direct Fax)
lwitten@neeinc.com
www.neeinc.com
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From: Sarah LaValley [mailto:slavalley@northamptonma.gov]
Sent: Tuesday, November 09, 2010 3:51 PM
To: Lyons Witten
Cc: Alan Verson
Subject: RE: Cutlery Certificate of Compliance
Lyons:
Order 246-593 required that a stamped plan (condition 31) be submitted upon completion of work. This will be needed before a
certificate can be issued.
Condition #33 also required that hazardous materials signs be placed at the gates and along the road. These are indicated to be ‘no
trespassing signs’ only.
Do you have a reference to the wetlands plant reports that were required to be submitted by 2007? Annual reports were required to be
submitted to the Commission, but I am interested primarily in the final 3-year report demonstrating that 85% or more vegetation
establishment. I did not see these in our files.
The 246-546 Order condition #34 required that the stockpile of contaminated material be removed from or incorporated into the site. I
know cleanup plans were somewhat of a moving target, can you provide a reference to the IRA or other document where the plan to
keep the soil contained was provided?
Thanks very much-
Sarah
From: Sarah LaValley
Sent: Tuesday, November 09, 2010 10:45 AM
To: 'Lyons Witten'
Cc: Alan Verson
Subject: Cutlery Certificate of Compliance
Hi Lyons-
I’m reviewing the Cutlery filing this morning and will be getting back to you with any questions or concerns.
A request for CoC form was only provided for 246-593. Could you also fill out the form for 246-546, since they are separate Orders and
will require separate Commission actions? If you could email this to me I will add it to the filing.
Thanks very much-
Sarah
Sarah I. LaValley
Conservation, Preservation and Land Use Planner
City of Northampton
Office of Planning and Development
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