421 Advanced ES Solution Letter •
Advanced Environmental
Solutions, Inc.
A Service-Connected, Disabled Veteran Owned and HUBZone Certified Firn
September 29, 2003
Mr. Daniel Hall
Section Chief—Division of Solid Waste Management
Massachusetts Department of Environmental Protection
436 Dwight Street
Springfield,MA 01103
RE: Filing of Request for Extension
Draft Comprehensive Site Assessment Report Submittal Deadline
VA Medical Center Landfill
Northampton,MA
DSWM File # 03-214-018
Dear Mr. Hall:
Advanced Environmental Solutions, Inc. (AES) has been retained by the Veterans
Administration (VA) to perform an assessment of the landfill located at the VA Medical Center
in Northampton, Massachusetts. AES is currently performing a Comprehensive Site Assessment
(CSA) in accordance with the MADEP Division of Solid Waste Management (DSWM)
Regulations and Guidance. After review of the Initial Site Assessment (ISA) Report and CSA
Scope of Work prepared by AES, MADEP DSWM prepared a response letter dated February 12,
2003. In this letter, MADEP DSWM outlined additional tasks required under the CSA Scope of
Work, and also specified a November I,2003 deadline for submittal of the Draft CSA Report.
The purpose of this letter is to request an extension of the Draft CSA Report submittal deadline,
and to present the rationale for requesting the extension. This letter has been prepared based on
feedback obtained through conversations between AES personnel and Mr. Charlie Clines of
MADEP DSWM, primarily a telephone conversation on August 28, 2003 during which Mr.
Clines outlined the process for requesting an extension on the submittal deadline. Mr. Clines
indicated that AES should submit a letter to MADEP DSWM which outlines the project status
and progress to date, and presents the rationale for requesting the extension to the CSA Report
submittal deadline of November 1, 2003.
Project History and Timeline
Upon receipt of the February 12, 2003 letter from MADEP DSWM, AES began the process of
re-costing the additional CSA tasks required by MADEP DSWM. Once complete, the revised
90 Madison Street-Suite 303 Phone: (508) 363-488:
Worcester, MA 01608 Fax: (508)363-4883
VA Medical Center Landfill
Northampton,MA
DSWM File#03-214-018
Page 2 of 3
cost estimate was presented to the VA in March 2003, with a justification for performance of the
additional tasks. Subsequently, AES submitted a change order to the VA for the additional CSA
tasks, and the VA initiated the process of allocating additional funding to conduct the CSA field
activities. Once the additional funding was approved by the VA, AES initiated the CSA field
activities.
One item required was the completion of a wetland delineation and filing of either a Notice of
Intent (NOI) or Request for Determination of Applicability (RDA) to the Northampton
Conservation Commission. This was required due to the proximity of the Site to nearby
wetlands, and the nature of proposed investigation activities and their potential impact on the
wetlands. Due to the harsh winter of 2002/2003 and the extensive snow cover at the Site, the
wetland delineation and land survey was not able to be conducted until early April 2003. Once
the wetland delineation and survey were completed, the RDA was submitted to the Northampton
Conservation Commission on April 28, 2003 for review. The City of Northampton Conservation
Commission held a public hearing on May 22, 2003 to review the RDA filing, and the RDA
filing and proposed CSA investigation activities were approved.
Following approval of the RDA at the hearing on May 22, 2003, AES scheduled the CSA field
activities to begin in early June 2003. The test pit excavation activities were conducted during
the week of June 2, 2003, prior to drilling and well installation activities so that the lateral extent
of waste could be defined to ensure proposed monitoring well locations were beyond the limits
of waste. Drilling and well installation/development activities were subsequently conducted
during the period of June 23 through 30, 2003, with the schedule dictated primarily by
subcontractor availability. The first round of CSA groundwater sampling activities was
performed on July 8 and 9, 2003, one week after the completion of well installation and
development activities. The results of Round I Groundwater Sampling were submitted to
MADEP DSWM in a letter report dated August 29, 2003.
The Round II CSA Groundwater Sampling activities were conducted on September 23 and 24,
2003, nearly three months after Round I sampling. The results of Round II Groundwater
sampling are due on or about October 10, 2003, with the complete data package including
laboratory Quality Assurance/Quality Control (QC/QC) results, due from the analytical
laboratory on or about October 24, 2003, approximately one week prior to the current Draft CSA
Report submittal deadline of November 1, 2003. Once the Round II groundwater sampling data
package is received, the data will be reviewed and incorporated into the Draft CSA Report which
will include a Qualitative Risk Assessment.
The Qualitative Risk Assessment is a key component of the Draft CSA Report, and cannot be
completed until all analytical data, including QA/QC results, is received and carefully reviewed
and evaluated. To ensure preparation of a technically sound Qualitative Risk Assessment, AES
feels that additional time beyond the current submittal deadline of November 1, 2003 is
necessary, and is therefore requesting an extension to this deadline.
VA Medical Center Landfill
Northampton,MA
DSWM File#03-214-018
Page 3 of 3
In the August 28, 2003 telephone conversation between Mr. Clines and AES, Mr. Clines
recommended AES request the submittal deadline be extended to January 15, 2004, after the
2003 holiday season. Therefore, based on Mr. Clines' recommendation, AES is requesting that
the submittal deadline be extended to January 15, 2004.
In the interest of moving this project forward, AES will make every effort to complete the Draft
CSA Report as expeditiously as possible, and plans to submit the Report to MADEP DSWM
well before the requested submittal deadline of January 15, 2004. If you have any questions
regarding the information provided in this letter, or would like to discuss the project status,
please feel free to contact me at(508) 363-4882.
Sincerely,
ADVANCED ENVIRONMENTAL SOLUTIONS, INC.
Philip M. Smith
Technical Director
cc: Mr. Peter J. McErlain, City of Northampton Board of Health
Mr. Frank Lalamas, Smith Vocational Agricultural High School
Mr. David Lawson, VA Medical Center,Northampton,MA
Mr. Charles Clines,MADEP DSWM
C:\VA Landfill\Task 2\VA extension DEP.doc