Compliance Inspection 1995 William F.Weld
GOVelflOr
Argeo Paul Cellucci
Lt.Governor
Commonwealth of Massachusetts
Executive Office of Environmental Affairs
Department of
Environmental Protection
Western Regional Office
November 8, 1995
Packaging Corporation of America
525 Mount Tom Road
Northampton, MA 01060
Attn: Mr. Thomas Dougherty
RE: Northampton, 1-10586, PAM
Packaging Corp.
525 Mount Tom Road
COMPLIANCE INSPECTION
Dear Mr. Dougherty:
Trudy Coxe
Secretary
David B.Struhs
Commissioner
On September 29, 1995, the Department of Environmental Protection (the Department)
conducted a compliance inspection at the above referenced location. The compliance inspection
consisted of a review of the file and the Release Abatement Measure Completion Report, and a
site walkover. The purpose of the compliance inspection was to view current site conditions and
to review the Release Abatement Measure (RAM) removal actions and outcome.
RAM STATUS
On September 1, 1994, a Limited Removal Action was initiated to remove impacted soils from
the drum disposal area. During excavation of the soil it became apparent that more than 20
cubic yards would need to be removed and therefore the Department was notified of the release
and permission was granted on October 31, 1994, to continue the soil removal action as a RAM.
Upon completion of the RAM, approximately 90 cubic yards of impacted soils were excavated by
Clean Harbors, Inc. and removed from the site. The impacted soils were transported by Clean
Harbors Inc., on December 28 and 29, 1994 and taken to their facility in Bristol, Connecticut.
Following stabilization, the soils will be taken to the Laidlaw, Inc. landfill in Plainville,
Massachusetts. Following excavation of the soil a composite soil sample of the bottom of the
excavation indicated the detection of 8 parts per million (ppm) of lead. Groundwater was not
encountered during the soil excavation. Results of the groundwater analyses indicated that
metals were not detected above their respective reportable concentrations. A Release Abatement
Measure Completion Report documenting these activities was received by the Department on
January 10, 1995.
INSPECTION FINDINGS
The site visit was conducted by Michael Scherer of the Department and Thomas Dougherty of
Packaging Corporation of America, and consisted of an inspection of the drum disposal area
where soil, drums and pails impacted by ink containing the hazardous metals lead, chromium,
and arsenic had been removed. The removal area was cleared of vegetation and had recently
436 Dwight Street • Springfield, Massachusetts 01103 • FAX(413)784-1109 • Telephone(413)764-1100
1-10586, Northampton
been filled with a clean sandy soil fill. The locations of monitoring wells installed to assess the
groundwater under the drum disposal area were verified. No soil piles were present on site.
Based upon the results of the soil removal actions undertaken as part of the RAM it appears
that the metal-impacted soils have been removed from the former drum disposal area and that
the objective of the RAM, to remove and properly dispose of contaminated soil, has been met.
No deficiencies or violations identified during the compliance inspection. .On the basis
of the information reviewed during the inspection and in reliance upon the accuracy of that
information, the Department did not identify any deficiencies or violations of the requirements
reviewed in the course of the inspection that warrant further action by the Department at this
time.
LIMITATIONS
These findings do not apply to response actions or other aspects of the site that were not
reviewed in the inspection. These findings do not in any way constitute a release from liability
under M.G.L. c. 21E, the Massachusetts Contingency Plan (MCP), or any other law, regulation,
or requirement. This inspection does not preclude future audits of past current, or future
response actions or activities at the site.
No portion of this Notice shall be construed to relieve any person from obligation for Response
Action Costs or damages related to a site or disposal site for which that person is liable under
M.G.L. c. 21E or from any obligation for any administrative, civil or criminal penalty, fine,
settlement, or other damages. No portion of this Notice shall be construed to limit the
Department's authority to take or arrange, or to require any Responsible Party or Potentially
Responsible Party to perform, any response action authorized by M.G.L. c. 2IE which the
Department deems necessary to protect health, safety, public welfare or the environment.
If you have any questions regarding this letter please contact Michael Scherer at (413) 784-1100
x-278.
Sincerely,
Michael L. Scherer
Environmental Analyst
Catherine G. Wanat
Section Chief
Audits/Site Management
Bureau of Waste Site Cleanup
cc Northampton Board of Health
Northampton Board of Selectmen
Steve Winslow,,DEP Audit Coordinator, Boston
• WERO Audit File
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