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32C_063 Hampton Ave Activity and Use LimitationWOODARD &CURRAN COMMITMENT & INTEGRITY DRIVE RESULTS August 23, 2012 City of Northampton 210 Main Street Northampton, Massachusetts 01060 Re: Notification to Record Interest Holder Pending Notice of Activity and Use Limitation 20 Hampton Avenue, Northampton, Massachusetts MassDEP Release Tracking Number 1 -14435 To Whom It May Concern: The terms of the AUL will consist of the following: 35 New England Business Ctr. T 866.702.6371 Suite 180 T 978.557.8150 Andover, Massachusetts 01810 F 978.557.7948 www.woodardcurran.com CERTIFIED MAIL. - -- RETURN - RECEIPT REQUESTED 3d-c-e On behalf of Hampton Housing Associates Limited Partnership (the current property owner), c/o Schochet Mass, Inc. (Its General Partner), Woodard & Curran, Inc. is sending you this letter to fulfill the notification requirements for a proposed Notice of Activity. and Use Limitation (Notice of AUL) established by the Massachusetts Contingency Plan (MCP; 310 CMR 40.0000). You have been identified as a current holder of record interest in the property located at 20 Hampton Avenue, Northampton, Massachusetts. As required by 310 CMR 40.1074(1)(e), current holders of any record interest in the area subject to the proposed Notice of AUL shall be notified of the existence and location of oil and /or hazardous material (OHM) within such area and the terms of such proposed Notice. The OHM present at the property consists primarily of petroleum hydrocarbons (including volatile and extractable petroleum hydrocarbons [VPH /EPH] and polycyclic aromatic hydrocarbons [PAHs]) in soil and groundwater related to one or more releases from above and underground storage tanks (ASTs /USTs) at the subject property. Although a condition of No Significant Risk (NSR) exists for all human receptors that currently occupy the property (including current multi - family residential occupants), a condition of NSR could not be achieved for future hypothetical single - family residential receptors. Accordingly, an AUL is required to restrict future single - family residential use and other such uses of the Portion of the Property where petroleum impacts are present in the future to ensure that the condition of NSR is maintained. 1. Activities and Uses Consistent with the AUL Opinion. The AUL Opinion provides that a condition of NSR to health, safety, public welfare or the environment exists for any foreseeable period of time (pursuant to 310 CMR 40.0000) so long as any of the following activities and uses occur on the Portion of the Property: (i) Activities and uses on the Portion of the Property involving multi - family residential development, industrial or commercial development and /or operations including, but not limited to, day care facilities, educational facilities, offices, retail businesses, restaurants, and other such uses provided that all buildings used or designed for human occupancy are constructed with a slab -on -grade foundation, or with sub -grade parking, and are constructed in accordance with Obligations and Conditions (i) and (ii) in Paragraph 3 below. Outdoor uses of the Portion of the Property including playgrounds, recreational fields, parks, bike paths, vehicular and pedestrian traffic, vehicular parking, landscaping, hardscaping, routine maintenance of hardscaped and /or landscaped areas and customary accessory uses are also allowed. WOODARD &CURRAN (ii) Emergency utility work including excavation, maintenance, and repairs to site utilities; (iii) Short -term (6 months or fewer) construction, development, excavation and /or other subsurface activities, including, without limitation — non - emergency utility work, provided that such work is (a) conducted in accordance with the management procedures given at 310 CMR 40.0030, and any applicable worker and public health and safety practices pursuant to 310 CMR 40.0018, and (b) managed in accordance with Obligations and Conditions (i) and (ii) in Paragraph 3 below; (iv) Such other activities and uses which, in the Opinion of an LSP, shall present no greater risk of harm to health, safety, public welfare, or the environment than the activities and uses set forth in this Paragraph; and (v) Such other activities and uses not identified in Paragraph 2 as being Activities and Uses Inconsistent with the AUL. 2. Activities and Uses Inconsistent with the AUL Opinion. Activities and uses which are inconsistent with the objectives of this Notice of Activity and Use Limitation, and which, if implemented at the Portion of the Property may result in a significant risk of harm to health, safety, public welfare or the environment or in a substantial hazard, are as follows: (i) Use of the Portion of the Property for single - family residential purposes; (ii) Use of sub -grade buildings or structures at the Portion of the Property for occupiable space, such as residential space, offices, retail businesses, restaurants, childcare or other regular occupancy; (iii) With the exception of emergency utility work as described in Paragraph 1 (ii), invasive activities and /or uses which are likely to involve the excavation, removal and /or subsurface disturbance of soil and /or groundwater at the Portion of the Property, without the prior development and implementation of a Soil Management Plan and a Health and Safety Plan in accordance with the MCP. (iv) Any long term (more than 6 months) invasive subsurface activities at the Portion of the Property unless such activity is evaluated by a Licensed Site Professional who renders an Opinion that states that such disturbance is consistent with maintaining a condition of No Significant Risk. 3. Obligations and Conditions Set Forth in the AUL Opinion. If applicable, obligations and /or conditions to be undertaken and /or maintained at the Portion of the Property to maintain a condition of No Significant Risk as set forth in the AUL Opinion shall include the following: (i) A Soil Management Plan must be developed and implemented prior to the initiation of any planned (non- emergency) invasive subsurface activity (e.g., construction) to be performed with respect to soil and /or groundwater at the Portion of the Property. The Soil Management Plan must be prepared by an LSP in accordance with the soil management procedures of the MCP at 310 CMR 40.0030 et seq.; and (ii) A Health and Safety Plan must be developed and implemented prior to the initiation of any planned (non- emergency) invasive subsurface activity to be performed with respect to soil and /or groundwater at the Portion of the Property. The Health and Safety Plan must be prepared by a Certified Industrial Hygienist or other qualified individual sufficiently trained in health and safety protocols. The Plan should clearly describe the nature of the oil and 20 Hampton Avenue, Northampton, MA (210765) 2 Woodard & Curran 30 -Day Notification Letter August 23, 2012 hazardous materials located in soils and /or groundwater throughout the area of the Portion of the Property where invasive subsurface activities are planned and specifically identify the types of personal protective equipment, monitoring devices, and engineering controls Ilk necessary to ensure that workers are not exposed (in a manner inconsistent with the MCP or this AUL) via dermal contact, ingestion, and /or the inhalation of particulate dusts /vapors. WOODARD _ - Workers _who _may _come . in contact with soil and/or groundwater at the Portion of_the Property &CURRAN must be informed that soil and /or groundwater impacted by oil and /or hazardous materials is located throughout the Portion of the Property and be made aware that all invasive subsurface activities in such areas must be performed in compliance with the requirements of the Health and Safety Plan. The Plan must be available on -site throughout the course of the work. Per 310 CMR 40.1074(1)(e), as a record interest holder in property, you are entitled to 30 days notice prior to recording of the AUL. The AUL will be recorded on or around September 24, 2012. If you have any questions regarding this matter, please feel free to contact me at 866- 702 -6371. Sincerely, WOODARD & CURRAN INC. David R. MacDonald, PG, LSP Senior Vice President DRM /ale cc: Massachusetts Department of Environmental Protection, Western Regional Office Richard Henken, Northampton Housing Associates Limited Partnership 20 Hampton Avenue, Northampton, MA (210765) 3 Woodard & Curran 30 -Day Notification Letter August 23, 2012