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22 Notice of Non Compliances DANIEL S.GREENBAUM Commissioner JOHN J. HIGGINS Regional Dtedor J4 'fo r nwm eala Stackeda OO e t5/7 giuteonsteet.4d sarA rt .z .z w '36 .� . . ±—#.h<< . tom.. own (,/s) 7a -//co Shell Oil Company P.O. Box 1703 Atlanta, GA 30371 Attn: Mr. L.S. Dealer Dear Mr. Bealer: July 14, 1992 Re: Northampton #1-0861 Shell Service Station 22 Main Street, Florence M.G.L. Ch.21E The Department of Environmental Protection has placed the above- referenced property on the list of locations to be investigated (LTBI) , which is updated periodically and published by the Department. If you are a potentially responsible party as described in Section 5 (a) of the Massachusetts Superfund Law (M.G.L. Chapter 21E) , you are responsible for ensuring that appropriate assessment and remedial action, if necessary, is undertaken at this property. These and other responsibilities and liabilities are described in M.G.L. Chapter 21E, and in 310 CMR 40. 000 (the Massachusetts Contingency Plan or MCP) , copies of which can be obtained at the Secretary of State Bookstore Offices in Springfield or Boston. The Department' s Waste Site Cleanup Program has been revised to reflect the July 1992 amendments to M.G.L. Chapter 21E. The MCP has also been substantially revised. Most of the new rules will take effect on October 1, 1993; requirements for sites that have already been reported to the Department will take effect on August 2, 1993 . There will be various options available for sites listed as LTBIs on the August 1993 Transition List. You will be receiving information under separate cover regarding the various options available to you for addressing the referenced property under the revised MCP. All correspondence and reports should reference the Site No. identified in the heading of this letter. Sincerely, Catherine G. Wanat Section Chief, Site Support Bureau of Waste Site Cleanup CGW:JF cc: Northampton Board of Health Northampton Chief Municipal officer DANIEL S.GREENBAUM commissioner JOHN J. HIGGINS Regbrel D eclor gAe, WanuntinLecta, ViSuezeizezaaat el © o/e s Yea. Rxdraw 496 9 Yt eet .9" 6.#:/a. , . GYM, (iii) ,F#-U09 November 3, 1993 Shell Oil Company Corporate Ridge 175 Capital BLVD. ,Suite 300 Rocky Hill, CT 06067 Attention: L.S. Sealer RE: Northampton Shell/Florence 22 Main Street SA #1-0861 RAM Plan Approval APPROVAL OF PROPOSAL Dear Mr. Bealer, The Department of Environmental Protection received a proposal on October 22, 1993 for the approval of a Release Abatement Measures (RAM) Plan for the Shell gasoline service station located at 22 Main street in Northampton, Massachusetts. The Release Abatement Measure (RAM) proposal was prepared and submitted in your behalf by Sue Shepley of Groundwater Technology. The RAM consists of the removal of the LISTS and associated piping. During tank removals, soils will be field screened and post excavation samples will be collected and analyzed for EPA Method 8020/MTBE. Based on field screening, contaminated soils will be stockpiled on-site until disposal can be arranged at an approved waste facility. The Department gave verbal approval to Sue Shepley of Groundwater Technology for this RAM proposal on October 29, 1993. Ms. Shepley stated that they would implement the RAM on November 1, 1993. If you have any questions, please contact John Bourcier of Emergency Response at the above address of telephone number. JSB/j sb A:10861.RAM cc: erely, yid A Section C Emergency Response pity of Northampton Fire Department VCity of Northampton Board of Health Susan Shepley - Groundwater Technology Florence, 1-0861 (5) initiate enforcement actions listed at 310 CMR 40.1140(2) if violations of M.G.L. c. 21E or the MCP have been identified. If you have any questions regarding this notice or any of the requirements contained in it, or believe that you cannot comply with its requirements, please call Justine Fallon at 413-784-1100 extension 299. Sincerely, 6 -L. Catherine G. Wanat Section Chief Audits/Site Management Bureau of Waste Site Cleanup Enclosures cc: Northampton, Chief Municipal Officer Northampton, Board of Health Northampton, Conservation Commission Northampton, Fire Department Timothy Kemper, Groundwater Technology, Inc. Susan Shepley, Groundwater Technology, Inc., Windsor, CT WERO Audit File Stephen Winslow, DEP Audit Coordinator JF/CGW/mr William F. Weld Governor Trudy Coxe Secretary, EOEA Thomas B. Powers Acing Commissioner Commonwealth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection Western Regional Office Shell Oil Company 400 Blue Hill Drive Westwood, MA 02070 ATTN: R.H. Hummel October 14, 1994 Re: Northampton; Site #1-0861; RAM Shell/Florence 22 Main Street NOTICE OF AUDIT Dear Mr Hummel: Massachusetts General Law Chapter 21E requires the Massachusetts Department of Environmental Protection (the Department) to audit response actions at sites of releases of oil or hazardous material to ensure that these actions are being conducted according to M.G.L. c. 21E, the Massachusetts Contingency Plan (MCP), and other relevant laws and regulations. The MCP at 310 CMR 40.1100 establishes procedures for conducting such audits. The site referenced above has been selected by the Department for an audit. The audit will be conducted by Department staff in the Western Regional office in Springfield. The audit will initially focus on Release Abatement Measures (RAMS) conducted at the site. Additional response actions may also be examined as appropriate. This notice describes the scope of the audit and the type of audit activities the Department initially intends to perform along with your responsibilities and relevant deadlines. A fact sheet and flow chart that describe the audit process are also included as part of this notice. Note that, during an audit, response actions can proceed as planned unless you are otherwise notified by the Department. At the completion of this phase of the audit the Department may: (1) issue a Notice of Audit Findings which may include a statement of deficiencies and steps to correct those deficiencies. (2) request that you and if you choose, a representative, appear at the Department's office for an interview to provide an oral explanation and other supporting evidence to demonstrate compliance and then issue a Notice of Audit Findings. (3) conduct further site investigations and then issue a Notice of Audit Findings. (4) issue a Notice of Audit Findings and request that you participate in Compliance Assistance pursuant to 310 CMR 40.1150. 436 Dwight Street • Springfield, Massachusetts 01103 • FAX(413)784-1149 • Telephone(413)784-1100 a GROUNDWATER TECHNOLOGY November 14, 1994 Groundwater Technology,Inc. Kennedy Business Park II,431(F)Hayden Station Road.Windsor,CT 06095 USA Tel:(203)688-1151 Fax:(203)688-8239 Refer: 01121-5307 Mr. Peter Mcerlain Health Agent Board of Health City Hall 210 Main Street Northampton, MA 01060 Subject: Response Action Outcome Statement Former Shell Service Station 22 Main Street Florence, Massachusetts MADEP N° 1-0861 Dear Mr. Mcerlain: The Massachusetts Department of Environmental Protection (MADEP), in correspondence dated December 10, 1993, informed you that the above referenced property is a "disposal site subject to the requirements of the revised Massachusetts Contingency Plan, 310 CMR 40.000. In accordance with the requirements of 310 CMR 40.1400, please accept this correspondence as notification that a Response Action Outcome Statement for the Florence site has been filed with the MADEP. The correspondence includes a statement that the present site conditions do not pose a significant risk to human health or the environment, and based on the available site and risk assessment data no further assessment or remedial action is proposed for the location. Copies of all applicable project submittals are available for review at the DEP's Western Regional Office in Springfield, Massachusetts. If you have any comments or questions regarding the site, please call me. Sincerely, Groundwater Technology, Inc. Susan I. Shepley Lead Geologist Project Manager SIS/tmp Sh ell 10.59 Copy: Ms. Christine Skorupski, City Clerk, Northampton, MA Ms. Catherine Wanat, Massachusetts DEP, Western Region Mr. Richard Hummel, II, Shell Oil Company Offices throughout the U.S.,Canada and Overseas William F. Weld Governor Trudy Coxe Secretary. EOEA Thomas B. Powers Acting Commissioner Commonweatth of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection Western Regional Office Shell Oil Company 400 Blue Hill Drive Westwood, MA 02070 ATTN: R.H. Hummel March 3, 1995 Re: Northampton; Site #1-0861; RAM Shell/Florence 22 Main Street NOTICE OF AUDIT FINDINGS Dear Mr. Hummel: On October 14, 1994, the Massachusetts Department of Environmental Protection issued a Notice of Audit informing you that the Department was conducting an audit of certain activities related to the disposal site referenced above pursuant to 310 CMR 40 1100 That audit is now complete. The purpose of this Notice is to explain the results of the audit. This audit included a review of the following: • Preliminary Response Actions and Risk Reduction Measures (Subpart D). The audit consisted of the following activities: • A review of documents in Department files. • Review of a Phase i - Limited Site Investigation received by the Department on December 5, 1990. • Review of a Project Status Update received by the Department on September 16, 1993. • Review of the Release Abatement Measure Plan received by the Department on October 29, 1993. • Review of written approval of the Release Abatement Measure Plan dated November 3, 1993. • Review of the Release Abatement Measure Completion Statement received by the Department on February 16, 1994. • A Notice of Audit dated October 14, 1994 436 Dwight Street • Springfield, Massachusetts 01103 • FAX(413)784-1149 • Telephone(413)784-1100 1-0861 Northampton 22 Main Street SUMMARY/STATUS OF RESPONSE ACTIONS A Response Action Outcome (RAO) Statement was received by the Department on November 18, 1994. The site is located on 22 Main Street in Florence, Massachusetts, at the intersection of Main Street and Chestnut Street. The property serves as a retail gasoline service station. The site is currently owned by Shell Oil Company. During the Phase I investigation six underground storage tanks were located on the property, two 5,000-gallon gasoline tanks, two 6,000-gallon gasoline tanks, a 500-gallon waste oil tank, and a 500-gallon fuel oil tank. The property consists of a two bay brick and cinder block service station and two retail gasoline pump islands. The property surrounding the site is commercial. Five schools and institutions are located within a one mile radius. The Mill River is located one half mile from the site. The Florence Pond is located within a half mile west of the site. There are two municipal wells located approximately three quarter miles to the southwest. The site is underlain by a coarse sand which goes to a varied clay/silt matrix at approximately 35 feet. Groundwater was encountered at approximately 30 feet below surface. The groundwater flow is to the south. In October 1990, four soil borings were advanced as monitoring wells (GT-1 through GT-4). Soil samples were collected and analyzed for VOCs by Modified EPA Method 8240. Methylene Chloride and Acetone were detected in all of the soil samples as well as the laboratory blank. The groundwater monitoring wells were sampled and analyzed by EPA Method 624 for Purgeable Organics in water and Methyl Tert Butyl Ether (MTBE). The groundwater samples contained 14 parts per billion (ppb) of benzene, 29 ppb of toluene, 53 ppb of ethylbenzene and 2,000 ppb of total xylenes. All other monitoring wells came up non-detect for contaminants. A Project Status Update was submitted to the Department on September 16, 1993 by GTE Groundwater samples were collected from monitoring wells GT-1 through GT-4 on July 28, 1993. The samples were analyzed for VOCs by EPA Method 8020. Benzene, toluene, ethylbenzene, and xylene (BTEX) was not detected in any.of the monitoring wells. GT-4 had an MTBE concentration of 2.1 ppm. - - - - A Release Abatement Measure (RAM) Plan was submitted by Groundwater Technology, Inc. (GTI) and received by the Department on October 29, 1993. The objective of the RAM was to remove the six on-site underground storage tanks (USTs) and associated piping. GTI proposed to field screen the soils from the excavation and analyze for Volatile Organic Compounds (VOCs) and MTBE according to US EPA Method 8020. Any impacted soils would be stockpiled on-site and sampled for waste characterization prior to disposal at an approved waste facility. The Department approved this RAM plan in writing on November 3, 1993. The RAM Completion Report was received by the Department on February 16, 1994. Two 5,000- gallon and two 6,000-gallon gasoline, one 500-gallon fuel oil and one 500-gallon waste oil storage tanks were removed on November 2, 1993. The six USTs were disposed of at Mass Tank Disposal in Chicopee, Massachusetts. Approximately 65.4 cubic yards of soil, recording detectable VOC concentrations on a portable photo-ionization detector (ND), were excavated and stockpiled on-site for disposal. Soil samples were collected from the excavations and analyzed for volatile organics by 1-0861 Northampton 22 Main Street modified EPA Method 8020, or Total Petroleum Hydrocarbons (TPH) by EPA Method 418.1. In the area of the gasoline tanks the EPA Method 8020 results came back non-detect. In the area of the fuel oil and waste oil tanks the results ranged from non-detectable to 350 parts per million for TPH by EPA Method 418.1. The stockpiled soil was sampled and analyzed for TPH by EPA Method 418.1. The results indicated that concentrations were below the detection limits. The soil was disposed at Clean Earth, Inc. in Delaware on December 23, 1993. The disposal of the soil was documented using a Clean Earth, Inc. non-hazardous waste manifest. ADDITIONAL AUDIT ACTIVITIES On October 11, 1994, there was a telephone conversation between Mr. Richard Hummel of Shell Oil Co. and Ms. Justine Fallon of the Department. An inquiry was made regarding the future of the site. Mr. Hummel indicated that the site will be closed with a Response Action Outcome Statement and the wells on-site will be abandoned When asked about specific RAM activities, Mr. Hummel directed the Department to his consultant, Ms. Susan Shepley of Groundwater Technology Inc. There was a telephone conversation between Ms. Shepley and Ms. Fallon on October 11, 1994. Ms. Shepley was asked why the tanks were removed. She indicated the tanks were removed so the new owners of the property could install their own tanks. Ms. Shepley was asked to further clarify the area of soil excavation. She indicated that the soil was excavated from the area around the gasoline USTs, fuel oil UST, and the waste oil UST. An inquiry was also made regarding the groundwater contamination in monitoring well GT-3. In 1990 there was 2,096 parts per billion (ppb) of BTEX, however, the 1993 status report indicated BTEX was not detected in GT-3. She had no immediate explanation and said this would be addressed in the Response Action Outcome Statement. A Response Action Outcome Statement was received by the Department on November 14, 1994. The Response Action Outcome Statement was not included in the audit for this site. AUDIT FINDINGS No deficien©es or'violations identified during the-audit. On the basis of the information reviewed • during the audit 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 audit that warrant further action by the Department at this time. This finding does not apply to response actions or other aspects of the site that were not reviewed in the audit. ADDITIONAL COMMENTS The following observation does NOT constitute a deficiency or violation and requires no response to the Department from you. Instead, it is included to help you and your LSP better understand the Department's interpretation of M.G.L. c. 21E, 310 CMR 40.0000, and other requirements applicable to the site. Pursuant to the Department of Environmental Protection's Interim Remediation Waste Policy for Petroleum Contaminated Soils (#WSC-94-400) dated April 21, 1994 and the requirements of the 1-0861 Northampton 22 Main Street Massachusetts Contingency Plan (40.0030), either a Bill of Lading, Hazardous Waste Manifest, or a Material Shipment Record Form should be used to transport contaminated soils, below the 21E notification thresholds, to an out-of-state facility. LIMITATIONS The audit focused primarily on compliance with certain requirements of M.G.L. c.21E and the MCP and, to a limited extent, other applicable requirements. This audit does not preclude future audits of past, current, or future response actions or activities at the site or inspections to confirm compliance with applicable requirements of other laws or regulations enforced by the Department. These findings do not in any way constitute a release from liability under M.G.L. c. 21E, the MCP, or any other law, regulation, or requirement. No portion of this Notice shall be construed to relieve any person from an 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. 21E which the Department deems necessary to protect health, safety, public welfare or the environment. If you have any questions regarding this notice or any requirements contained in it please call Justine Fallon at the letterhead address or at (413) 784-1100 extension 299 Please reference number 1-0861 in any correspondence regarding this site Sincerely, I, I Catherine G. Wanat Section Chief Audits/Site Management Bureau of Waste Site Cleanup CERTIFIED MAIL Z 082 548 058 RETURN RECEIPT REQUESTED CGW/JF/mr noaf.861 cc: Northampton Chief Municipal Officer Northampton, Board of Health Northampton, Conservation Commission Northampton, Fire Department Robert Brackett, Groundwater Technology, Inc. 1-0861 Northampton 22 Main Street Susan Shepley, Groundwater Technology, Inc. Stephen Winslow, DEP Audit Coordinator WERO Audit File 1AM F WELD -nor 's0 PAUL CELLUCCI overnor COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION WESTERN REGIONAL OFFICE CERTIFIED MAIL NO. Z 276 535 391 RETURN RECEIPT REQUESTED Florence Towing 22 Main Street, Florence Northampton, MA 01060 Attn: Robert Gougeon JUN 111996 Re: BWP - Northampton Florence Towing 22 Main Street, Florence TRUDY CORE Secretary DAVID B. STRUHS Commissioner Noncompliance with MGL Chapter 111, Sections 142 A-M and 310 CMR 7.24 (Air Quality Regulations) Noncompliance with MGL Chapter 21C, Sections 1 - 14, and 310 CMR 30.000 (Hazardous Waste Regulations) • FMF# 135990 • AQ Stage II ID #MF0004821 • HW ID # MAD 053 390 258 Enforcement Document No. NON-WE-96-9041-2,7 NOTICE OF NONCOMPLIANCE THIS IS AN IMPORTANT NOTICE. FAILURE TO TAKE ADEQUATE ACTION IN RESPONSE TO THIS NOTICE COULD RESULT IN SERIOUS LEGAL CONSEQUENCES. Dear Mr. Gougeon: Department personnel observed on May 16, 1996 that your facility located at 22 Main Street in Florence, Massachusetts, was in noncompliance with one or more laws, regulations, orders, licenses, permits, or approvals enforced by the Department. Specifically, Department personnel observed that your facility was in noncompliance with applicable Air Quality and Hazardous Waste regulations. Attached is a written description of(1) the activities in noncompliance, (2) the requirement(s) violated, (3) the action(s) the Department now requires you to take, and (4) the deadline(s) for 6 Dwight Street • Springfield, Massachusetts 01103 • FAX(413)784-1149 • TDD(413)746-6620 • Telephone(413)784-1100 0 Peered on Recycled raper(20%Post onsumer) Florence Towing NON-WE-96-9041-2,7 Page 2 taking such action(s). An administrative penalty may be assessed for every day from now on that you are in noncompliance with the requirements described in this Notice of Noncompliance. Notwithstanding this Notice of Noncompliance, the Department reserves the right to exercise the full extent of its legal authority, including, but not limited to, criminal prosecution, civil action including court-imposed civil penalties, or administrative penalties assessed by the Department, in order to obtain full compliance will all applicable requirements. SOURCE REDUCTION OPPORTUNITIES You may be able to reduce environmentally driven costs and possibly reduce the regulatory requirements and fees applied to your firm if you eliminate or reduce the use of toxic materials or other inputs, or the generation of wastes through decreased chemical use or increased process efficiency. As a result, you may save money and improve quality and productivity. For further information on source reduction of toxic and other waste you may contact: • the Office of Technical Assistance (617-727-3260) for FREE, CONFIDENTIAL technical assistance including on-site assessments, financial evaluations, the handbook The Practical Guide to Toxics Use Reduction", and other resources. • the Toxics Use Reduction Institute (508-934-3262) for courses for certified "Toxics Use Reduction Planners". • DEP's Toxics Use Reduction Implementation Team (617-292-5870) for guidance material on the Toxics Use Reduction Act requirements. If you have any questions regarding this Notice of Noncompliance, please contact Juliana Vanderwielen or Craig Goff of this office at (413) 784-1100, extensions 256 and 277, respectively. JUN 11 1996 DATE: Very truly yours, Craig C Goff Sectio Chief Compliance & Enforcement Bureau of Waste Prevention CG/JV/jv enclosure: Summary of Requirements for Small Quantity Generators of Hazardous Waste cc: Dorothy Blickens, AQ-Stage II, One Winter Street, Boston, MA 02108 Roberta Baker, Steven Ellis (2 copies), Harry Vandergrift Alan Buckley, OTA, 100 Cambridge Street, Boston, MA 02202 Northampton Board of Health Florence Towing NON-WE-96-9041-2,7 Page 3 NOTICE OF NONCOMPLIANCE NONCOMPLIANCE SUMMARY NAME OF ENTITY IN NONCOMPLIANCE. Florence Towing LOCATION WHERE NONCOMPLIANCE OCCURRED OR WAS OBSERVED: 22 Main Street Florence, MA 01060 DATE WHEN NONCOMPLIANCE OCCURRED OR WAS OBSERVED: May 16, 1996 DESCRIPTION OF NONCOMPLIANCE AND THE REQUIREMENT(S) NOT COMPLIED WITH: A. Noncompliance with the Massachusetts Statute Regulating Air Pollution, MGL Chapter 111, Sections 142 A-M, and the Regulations Which Implement Such Statute, 310 CMR 7.00 1) Failure to maintain continuous records on the premises. Violation of 310 CMR 7.24(6)(). The testing results, maintenance/failure records, employee training log/certificate, and Installation and Compliance (I & C) form for the vapor recovery system were not available for review at the time of the inspection. 2) Vapor collection and control system has been altered, modified, or otherwise rendered inoperative (vapor recovery system is not operating properly). Violation of 310 CMR 7.24(6)(e). The configuration of dispenser #6 does not meet CARE Executive Order G-70-52-AM Exhibit 5. The lower loop of the hose is greater than the allowed maximum 10 inches. B. Noncompliance with the Massachusetts Hazardous Waste Management Act, MGL Chapter 21C, Sections 1 - 14, and the Hazardous Waste Regulations, 310 CMR 30.000 1) Failure to properly mark and label hazardous waste containers. Violation of 310 CMR 30.340(1)(6). The waste oil storage tank was not properly labeled. 2) Failure to post a "HAZARDOUS WASTE" sign in the hazardous waste accumulation area. Violation of 310 CMR 30.340(1)(j). A hazardous waste sign was not posted in the area of the waste oil storage tank. Florence Towing NON-WE-96-9041-2,7 Page 4 ACTIONS TO BE TAKEN, AND THE DEADLINE FOR TAKING SUCH ACTIONS: A. Noncompliance with the Massachusetts Statute Regulating Mr Pollution, MGL Chapter 111, Sections 142 A-M, and the Regulations Which Implement Such Statute, 310 CMR 7.00 1) Maintain and keep the following records at the facility: a) Vapor collection and control system failure records. b) Vapor collection and control system maintenance records. c) Daily and monthly throughput records. d) Testing results for the vapor collection and control system. e) Certification that facility operators and employees received training and instruction in the operation and maintenance of the vapor collection and control system. All permits, orders or licenses to operate issued for the facility by the Department. g) Inspection reports or other compliance documents issued for the facility by the Department. Further specifics regarding these records are listed in 310 CMR 7.246(6)(f) (g) and (i). This action must be taken within 7 days of the date of receipt of this Notice. 2) A copy of the testing results for the required testing of the vapor collection and control system must be submitted to the Department. If there are no testing results for the vapor collection and control system, the vapor collection and control system must be tested in order to demonstrate compliance with 310 CMR 724(6). The Department must be notified in writing at least two days prior to the anticipated test date. The required tests are specified in 310 CMR 7.24(6)(g) and (i). This action must be taken within 30 days of the date of receipt of this Notice. 3) Correct the configuration of the dispenser or submit documentation verifying that the configuration is Department certified (meets CARB Executive Order G-70-52-AM). This action must be taken within 21 days of the date of receipt of this Notice. B. Noncompliance with the Massachusetts Hazardous Waste Management Act, MGL Chapter 21C, Sections 1 - 14, and the Hazardous Waste Regulations, 310 CMR 30.000 1) Label the waste oil storage tank with the words "Hazardous Waste", the name of the waste, the type of hazard associated with the waste, and the date on which accumulation began. Florence Towing NON-WE-96-9043-2,7 Page 5 This action must be taken immediately on receipt of this Notice. 2) Place a "HAZARDOUS WASTE" sign in the waste oil accumulation area. The sign must met the guidelines of the National Fire Protection Associations code 704, with the words "HAZARDOUS WASTE" in capital letters at least 1 inch high. This action must be taken within 14 days of the date of receipt of this Notice. A description of all the steps that were taken to correct the above listed violations must be submitted to the Department within 30 days of the date of receipt of this Notice. JUN 111996 DATE: Craig C. ' .ff Section ' hief Bureau of Waste Prevention Western Region ,LIAM F WELD ernor :EO PAUL CELLUCCI :overnor Florence Towing 22 Main Street Florence, MA 01060 Attn: Robert Gougeon COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION WESTERN REGIONAL OFFICE AUG 1 1996 Re: BWP - Florence Florence Towing 22 Main Street FMF# 135990 TRUDY COXE Secretary DAVID B. STRUHS Commissioner Dear Mr. Gougeon: Department personnel inspected the above referenced facility on May 16, 1996. During this inspration Department personnel observed several floor drains in the garage area of this facility. No documentation was available regarding the point(s) of discharge of these floor drains. These floor drains may allow spilled chemicals and/or industrial wastewaters to discharge to groundwater, a sewer, or some other location. This may be a violation of 314 CMR 3.00, 5.00, or 7.00 and M.G.L. Chapter 21, Section 43. The Department requires that you submit documentation to the Department regarding the point(s) of discharge of these floor drains. This documentation must include piping plans and/or dye tests, certified by a registered professional engineer, identifying the point(s) of discharge of these floor drains. If the documentation shows that the floor drains discharge to the municipal sewer system, then the date that these floor drains were connected to the municipal sewer system must be included. This documentation must be submitted to the Department within 30 days of the date of receipt of this letter. After reviewing the submitted documentation, the Department may, depending on the documented point(s) of discharge of these floor drains, take further action. 16 Dwight Street • Springfield, Massachusetts 01103 • FAX(413)784-1149 • TDD(413)746-6620 • Telephone(413)784-1100 C,f Printed on Recycled Paper 120%Post onsumm If you have any questions regarding this matter, please contact Juliana Vanderwielen of this office at (413) 784-1100, extension 256. DATE: CG/JV/jv Very trul .yours, Craig C Sectio Chief Compliance & Enforcement Bureau of Waste Prevention cc: Dorothy Blickens/SERO Jeff Gifford, AQ-Stage II, One Winter Street, Boston, MA 02108 Roberta Baker, Steven Ellis (2 copies), Harry Vandergrift Alan Buckley, OTA, 100 Cambridge Street, Boston, MA 02202 Northampton Board of Health LIAM F.WELD snor EO PAUL CELLUCCI Iovernor Florence Towing 22 Main Street Florence, MA 01060 Attn: Robert Gougeon COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION WESTERN REGIONAL OFFICE LAUG 1 1996 Re: BWP - Florence Florence Towing 22 Main Street FMF# 135990 COMPLIANCE with TRUDY CORE Secretary DAVID B.STRUHS Commissioner • MGL Chapter 21C and 310 CMR 30.000 (Hazardous Waste Regulation) • MGL Chapter 111 Sections 142A-M and 310 CMR 6.00-8.00 (Air Pollution Control Regulations) • MGL Chapter 21 Sections 26-53 and 314 CMR 2.00-7.00 (Industrial Wastewaster Management Regulations) • MGL Chapter 21I and 310 CMR 50.00 (Taxies Use Reduction Regulations) RETURN TO COMPLIANCE Dear Mr. Gougeon Department personnel conducted a multimedia inspection of the above referenced facility on May 16, 1996. The purpose of this inspection was to determine compliance with the above referenced laws and regulations. As a result of this multimedia inspection, the Department issued a Notice of Noncompliance (NON), NON-WE-96-9041-27, to this facility on June 11, 1996. This NON was issued for violation of Air Pollution Control and Hazardous Waste Regulations. The specific regulations violated are listed in the NON. Department personnel re-inspected this facility on July 24, 1996 for the purpose of verifying compliance with the NON. As a result of this re-inspection, the Department has determined that 16 Dwight Street • Springfield, Massachusetts 01103 • FM(413)784-1149 • TOD(413)746-6620 • Telephone(413)784-1100 C. vnnied on Regaled Pape'(20%Post Consumer) the facility corrected the violations listed in the NON and that this facility was, at the time of the re-inspection, in compliance with the laws and regulations cited in the NON. The Department notes that this facility may be in non-compliance with Industrial Wastewater Management Regulations. To determine whether this is the race, the Department needs further information. A letter regarding this matter is enclosed. If you have any questions regarding this re-inspection or concerning any other environmental regulatory matter affecting this facility, please contact Juliana Vanderwielen at (413) 784-1100, extension 256. Ve$'truly yours, i G Bureau of Waste Prevention Western Region CCG/JV/jv enclosure: Installation and Compliance Form cc: Dorothy Blickens/SERO Jeff Gifford, AQ-Stage II, One Winter Street, Boston, MA 02108 Roberta Baker, Steven Ellis (2 copies), Harry Vandergrift/WERO Alan Buckley, OTA, 100 Cambridge Street, Boston, MA 02202 Northampton Board of Health