296 Letters & Emails 2000-2015 ARGEO PAUL CELLUCCI
Governor
JANE SWIFT
Lieutenant Governor
Pro Corporation—PMC
296 Nonotuck Street
Florence, MA 01060
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
WESTERN REGIONAL OFFICE
Attention: Richard O'Connor
Dear Mr. O'Connor:
BOB DURAND -
Secretary
LAUREN A LISS
Commissioner
November 16, 2000
Re: 296 Nonotuck Street,Florence, MA
Release Tracking# 1-13582
Immediate Response Action Plan Modification Approval
The Department of Environmental Protection,Bureau of Waste Site Cleanup(the Department)received
an Immediate Response Action(IRA)Plan Modification on November 7,2000,for the property located
at 296 Nonotuck Street in Florence,Massachusetts(the"site"). The Plan was prepared by ATC
Associates, Inc.and signed by their Licensed Site Professional, Mr. Timothy J. O'Brien.
On August 9,2000,ATC Associates,Inc. provided oral notification to the Department of a non-aqueous
phase liquid(NAPL),which was observed during excavation activities under a Release Abatement
Measure. Three to four inches of NAPL similar to machine oil was observed at a depth of three feet
below grade. The Department approved the following IRA activities to address the NAPL: removal of
the NAPL encountered during the excavation; excavation and proper disposal of up to 50 cubic yards of
contaminated soil; and completion of assessment activities to determine the source of the NAPL.
The IRA Plan Modification proposes the installation of a physical barrier and an active recovery system
in the excavation area to recover the NAPL. The proposed IRA Plan Modification includes: construction
of a recovery trench and installation of a sump; connection to a holding tank;weekly inspections of the
system; and confirmatory soil sampling of the excavation area.
436 Dwight Street•Springfield,Massachusetts 01103•FAX(413)784-1149•TDD(413)746-6620•Telephone(413)704-1100
0 Printed on Recycled Paper
Pro Corporation
IRA Approval
RTNN 1-13582
The Department approves of the response actions documented in the IRA Plan Modification.The
response actions proposed in the plan are subject to the condition listed below:
1. The Department should be notified two(2)days prior to the commencement of IRA activities at the
site.
If you have any questions regarding this matter, please contact Eileen Barnes at(413)755-2]25.
DS/EMB/kml
rely
Day
Section Ch
Emergency
ponce
Certified Mail#7000 0600 0026 4624 9273,Return Receipt Requested
cc: Northampton:
Board of Health
Fire Department
Board of Selectmen
ATC Associates,Inc.
Timothy J.O'Brien,LSP
Leni-Sarah Machinton,Environmental Scientist
This information is available in alternate format by calling our ADA Coordinator 4(617)5744 72.This information is available in alternate format by
1RGEO PAUL CELLUCCI
3ovemor
JANE SWIFT
Lieutenant Governor
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
WESTERN REGIONAL OFFICE
November 29, 2000
URGENT LEGAL MATTER: PROMPT ACTION NECESSARY
CERTIFIED MAIL:RETURN RECEIPT REQUESTED
Pro Corporation—PMC
296 Nonotuck Street
Florence,MA 01062
Attention: Fred Gariepy,Plant Engineer
Re:
Florence
296 Nonotuck Street
Release Tracking# 1-13695
RELEASE NOTIFICATION and
NOTICE OF RESPONSIBILITY;
M.G.L.c.21E and
310 CMR 40.0000
BOB DURAND
Secretary
LAURENA LISS
Commissioner
Dear Mr.Gariepy:
On November 21,2000,at 2:30 P.M.,Mr.Timothy O'Brien,LSP of the consulting firm ATC Associates,Inc.
provided notification on your behalf to the Department of Environmental Protection(the Department)of an oil
release to the Mill River from a water discharge pipe located at the subject location(the site). The quantity of oil
released was approximated to be 20 gallons. In addition to oral notification,310 CMR 40.0333 further requires
that a completed Release Notification Form(RNF)be submitted to the Department within 60 calendar days
of the date of the oral notification.
The Department has reason to believe that the release that was reported is or may be a disposal site as defined in the
MCP. The Department also has reason to believe that you(as used in this letter"you"refers to Pro Corporation-
PMC)are a potentially responsible party(PRP)with liability under Section 5A of M.G.L.c.21E. This liability is
"strict",meaning that it is not based on fault,but solely on your status as owner,operator,generator,transporter,
disposer or other person specified in said Section 5A. This liability is also"joint and several",meaning that you are
liable for all response costs incurred at a disposal site even if there are other liable parties.
The Department encourages PRPs to take prompt and appropriate actions in response to releases and threats of
release of oil and/or hazardous materials. By taking the necessary response actions,you may significantly lower
your assessment and cleanup costs and/or avoid liability for costs incurred by the Department in taking such actions.
You may also avoid or reduce certain permit or annual compliance fees payable under 310 CMR 4.00. Please refer
to M.G.L.c.21E for a complete description of potential liability. For your convenience,a summary of liability
under M.G.L.c.21E is attached.
This intonation is available in alternate format by Sling our ADA Coordinator at(617)5116872.
438 Dwight Street•Springfield,Massachusetts 01103•FAX(413)784-1149•TDD(413)746-6620•Telephone(413)784-1100
0 Printed on Recycled Paper
Mr.Fred Gariepy
Notice of Responsibility
RTN 1-13695
Page 2
You should be aware that you may have claims against third parties for damages,including claims for contribution
or reimbursement for the costs of cleanup. Such claims do not exist indefinitely but are govemed by laws which
establish the time allowed for bringing litigation. The Department encourages you to take any actions necessary to
protect any such claims you may have against third parties.
At the time of oral notification and subsequent field inspection the Department approved the following response
actions as Immediate Response Actions(IRA):excavation and proper disposal of up to 10 cubic yards of
contaminated soil.
The Department records indicate that there have been previous releases at this facility. However,the oil release to the
Mill River described above is considered a separate release and will be tracked under Release Tracking No. 1-13695.
Specific approval is required from the Department for the implementation of an IRA with the exception of
assessment activities,the construction of a fence and/or posting of signs. Additional submittals are necessary with
regard to this notification including,but not limited to,the filing of an IRA Completion Statement and/or Response
Action Outcome(RAO)statement. The MCP requires that a fee of$750.00 be submitted to the Department when a
RAO Statement is filed greater than 120 days from the date of initial notification.
It is important to note that you must dispose of any Remediation Waste generated at the subject location in
accordance with 310 CMR 40.0030 including,without limitation,contaminated soil and/or debris. Any Bill of
Lading accompanying such waste must bear the seal and signature of a Licensed Site Professional(LSP). You may
contact the LSP Board of Registration at 617/556-1145 to obtain the current LSP list. The Department has listed
Mr.Timothy O'Brien of ATC Associates,Inc. as the LSP of record for this release.
If you have any questions relative to this notice,you should contact Eileen Barnes at the above letterhead address
or by telephone at 413-755-2125. All future communications regarding this release must reference the Release
Tracking Number(RTN)contained in the subject block of this letter.
Very truly yours,
00A ri A. _u -. rrPr
David A.Slowick
Section Chief
Emergency Response
DAS:EMB:kml
P:13695 nor.doc
Certified Mail No.7000 0600 0026 4624 9242
copy: Northampton
Fire Department
Board of Health
Board of Selectmen
ATC Associates,Inc.
Timothy O'Brien,LSP
Attachments to addressee only:
Release Notification Form;BWSC-003 and Instructions
Summary of Liability under M.G.L.c.21E
NE SWIFT
avernor
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
WESTERN REGIONAL OFFICE
Pro Corporation-PMC
296 Nonotuck Street
Florence,Massachusetts 01062
BOB DURAND
Secretary
LAUREN A.LISS
Commissioner
Attn: Richard O'Connor,General Manager
June 20, 2001
Re:
Florence
296 Nonotuck Street
Pro Corporation
Release of Hydraulic Oil
RTN 1-13695
NON#:NON-WE-01-3079
NOTICE OF NONCOMPLIANCE
M.G.L.c.21E,310 CMR 40.0000
THIS IS AN IMPORTANT NOTICE FAILURE TO TAKE ADEQUATE ACTION IN
RESPONSE TO THIS NOTICE COULD RESULT IN
SERIOUS LEGAL CONSEQUENCES
Dear Mr.O'Connor:
Department records indicate that response actions at the above-referenced site are not in compliance with
one or more laws,regulations,orders,licenses,permits,or approvals enforced by the Department.
Attached hereto is a written description of(1)each activity referred to above, (2)the requirements
violated, (3)the action the Department now wants you to take and(4)the deadline for taking such
action.
If you fail to come into compliance by the prescribed deadline(s),or if you otherwise fail to comply in
the future with requirements applicable to you,you could be subject to legal action. Such action could
include criminal prosecution,court-imposed civil penalties,or civil administrative penalties assessed by
the Department. A civil administrative penalty may be assessed for every day from now on that you
remain out of compliance with the requirements described in this Notice of Noncompliance.
This information is available in alternate format by calling our ADA Coordinator at(617)574-6872.
438 Dwight Street•Springfield,Massachusetts 01103•FAX(413)784-1149•TOD(413)746-8820•Telephone(413)784-1100
0 Printed on Recycled Paper
2
Please contact David Slowick of the Western Regional Office at 413-784-1100 ext.2246 if you have
any questions.
Sincerely,
Alan Weinberg /
Deputy Regional Director
Bureau of Waste Site Cleanup
DAS/ds/kml
P:.13695NON
Certified Mail#7001 0320 0003 0115 8836,Return Receipt Requested
cc: Northampton:
Board of Health
Mayor's Office
Maria Pinaud, BWSC/Boston
BWSC\WERO Enforcement File
Steve Ellis,WERO(2)
Eileen Bames-WERO
3
NOTICE OF NONCOMPLIANCE SUMMARY
ENTITY IN NONCOMPLIANCE:
Pro Corporation-PMC
296 Nonotuck Street
Florence,Massachusetts 01062
LOCATION OF NONCOMPLIANCE:
296 Nonotuck Street,Florence,Massachusetts 01062
DATE(S)OF NONCOMPLIANCE-
January 20,2001 for the submission of an Immediate Response Action Plan
March 17,2001 for the submission of an Immediate Response Action Status Report.
DESCRIPTION OF REOUIREMENT(S)NOT COMPLIED WITH:
On November 21, 2000,Pro Corporation-PMC notified the Department of a release of an unknown
quantity of hydraulic oil to the environment. The oil was discharged to the Mill River from piping
maintained by Pro Corporation-PMC,resulting in a visible sheen on the river. The Department inspected
the site on November 22,2000, and confirmed that a release of oil to the environment had occurred. The
Department assigned release tracking number 1-13695 to this release,and issued a Notice of
Responsibility,dated November 29,2000,to Pro Corporation-PMC. The NOR advised Pro Corporation-
PMC of its responsibility to conduct response actions to address the release.On December 8,2000,the
Department received a Release Notification Form prepared by Pro Corporation-PMC for the release. No
additional information was found in the Department's files regarding status of the release.
310 CMR 40.0420 requires the submission to the Department of an Immediate Response Action Plan
within sixty (60) days of notification to the Department of the need to conduct an Immediate Response
Action, unless an Immediate Response Action Completion Report or a Response Action Outcome
Statement is submitted to the Department within this sixty (60) day time period, or a remedial action
consisting solely of the construction of a fence or posting of warning signs was taken.
310 CMR 40.0425(1)requires any person conducting Immediate Response Actions to submit a written
Status Report to the Department within one-hundred and twenty(120)days from the date of initial
notification to the Department of the intent to conduct an immediate Response Action.
DESCRIPTION OF ACT OR OMISSION CONSTITUTING NONCOMPLIANCE:
Failure to submit an Immediate Response Action Plan and an Immediate Response Action Status Report
to the Department.
4
DESCRIPTION AND DEADLINE(S)OF ACTION(S)TO BE TAKEN
On or before July 6,2001, submit to the Department an Immediate Response Action Plan and Status
Report prepared by a Licensed Site Professional in accordance with 310 CMR 40.0424 and 310 CMR
40.0425 respectively.
Department of Environmental Protection
L �
DATE: June 20, 2001 By:
Alan Weinberg
Deputy Regional Director
Bureau of Waste Site Cleanup
Pro Corporation-PMC
Machine Oi(Release
RTN I-16060
Page 2 of 2
You should be aware that you may have claims against third claims fo
contribution or reimbursement for the costs of cleanup. Such claims do not exist indefinitely but an
governed by laws which establish the time allowed for bringing�igation damages,Th Department encourage:
you to take any actions necessary to protect any such claims you may have against third parties.
At the time of oral notification to the Department, the Department was advised that Immediate Response
Actions(IRA)consisting of assessment-only activities would be performed at this time.
Specific approval is required from the Department for the implementation of an IRA with the exception of
assessment activities, the construction of a fence and/or posting of signs. Additional submittals are
necessary with regard to this notification including, but not limited to, the film of
Statement and/or Response Action Outcome(RAO) statement. The MCP requires that a fee of$1200.00
be submitted to the De g an IRA Completion
initial notification. Department when an RAO Statement is filed greater than 120 days from the date of
Unless otherwise provided by the Department, responsible
of a release or threat of release is provided to the Department have one year from the initial date notice
the Department issues a Notice of Responsibility, whichever occurs earlier,to 310 file witth the Department one of
the following submittals: (1) a completed Tier Classification Submittal; or (2) a RAO Statement; or (3) a
Downgradient Property Status Submittal. The one-year anniversary date for this release is Januaa220 2
It is important to note that you must dispose of any Remeon Waste generated at the sect ons
in accordance with 310 CMR 40.0030 including, w thoutalimitati n, contaminated soil and/orodebr s.
Any Bill of Lading accompanying such waste must bear the seal and signature of a Licensed Site
Professional (LSP). You may contact the LSP Board of Registration at 617/556-1091 to obtain the
current LSP list. Presently, the Department has recorded that Kevin Sheehan of Environmental
Compliance Services will provide LSP services for this release.
If you have any questions relative to this notice, you should contact the undersigned at the above
letterhead address or by telephone at 413-755-2246. All future communications regarding this release
must reference the Release Tracking Number(RTN)contained in the subject block of this letter.
DAS/ds/kml
P:16060mf
ely
A. Slo
Section Chief
Emergency Response
Certified Mail No 7000 0600 0026 8858 8491
cc: Northampton:
Health Department
Mayor's Office
Kevin Sheehan-ECS
Attachments to addressee only:Release Notification Form;B WSC-003,and Instructions
Summary of Liability under M.G.I.c.21E
4NEY
EALEY
it Governor
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
WESTERN REGIONAL OFFICE
436 Dwight Street•Springfield,Massachusetts 01103• (413)784-1100•FAX(413)784-1149
STEPHEN R.PRIT CHAAR'D
Sretary
Pro Corporation-PMC
296 Nonomck Street
Northampton,Massachusetts 01060
Attn:David Tally
ROBERT W.GOLLEDGE,Jr,
Commissioner
January 24, 2006
Re: Northampton(Florence)
296 Nonomck Street
RTN 1-16060
Machine Oil Release
RELEASE NOTIFICATION and
NOTICE OF RESPONSIBILITY;
M.G.L.c.21E and 310 CMR 40.0000
Dear Mr.Tolly:
On January 20, 2006 at 4:35 PM, notification was provided to the Department of Environmental
Massachusetts(the Department)Yt) of a release Environmental Compliance Services, installed a l boring
below e n its site). e Your consultant,d detected eater than '/ inch of light, non-aqueous phase below the on-site machine underlying and machine shop. In addition to oral notification,as listed in
the Mass on setts Continency flan,1310 CMR 40.0000 This he constitutes
MCP"). a reportable e to oral tted to the
the Massachusetts Contingency Plan,
Department within 60rts of the date of the eoral notification.Notification Form (RN
The Department has reason to believe that the release that was reported is or may be a disposal
used in this letter site"you"
sal sit as
are a potentially responsible party (PRP)with liability under Section 5(a)
defined in the MCP. The Department also has reason to believe that you your status
refers to . c Corporation-PMC)Thi i r meaning that it is not based on fault,but solely on y
of M.G.L. c. e at ,This liability a sports ,
This
liability owner, also "joint i t andrseve al",meaning sin that you are other ble for all response costs incurred at a disposal
liability is also "joint and several",meaning that y
site even if there are other liable parties.
The Department encourages PRPs to take prompt and appropriate actions in response to releases you may
taking the necessary response actions, y
threats of release w r oil r assessment mentdand materials. By g effort or is incurred
red bi he
significantly lower your assessment and cleanup costs and/or avoid liability for costs incurred by the e
fees Department payable under 310 CMR 4.00. Please refer to M.G.L.ro 21E for a complete description of potential
fs payable
This information is available in alternate format.Call Donald M.Comes,ADA.Coordinator at 617-S56-1051.TED Service-l-800.29 8-2207.
DEP on the World Wide Web http9lwvwt.mas5 govldep
0 Printed on Recycled Paper
Pro Corporation-PMC
RTN 1-16060
NON-WE-06-3026
Paget of 4
The Department reserves its rights to exercise the full extent of its legal authority in order to obtain full
compliance with all applicable requirements, including, but not limited to, criminal prosecution, civil
action including court-imposed civil penalties, or administrative action, including administrative penalties
imposed by the Department.
If you have any questions about this Notice, please contact David Slowick of the Department's Western
Regional Office at 413-755-2246. In responding to this Notice of Noncompliance, please reference the
Release Tracking Number 1-16060 and the NON number (NON-WE-06-3026)to ensure proper tracking
of your response.
AGS/das/kml
P:16060 Northampton NON-WE-06-3026
Certified Mail#7004 0550 0000 4693 8461
enclosure: RNF&Instructions
cc: Northampton:
Health Department
Mayor's Office
e-cc Denise Andler
Sincerely,
1$VL ntic_
Ann ingt
Deputy Regional Director
Bureau of Waste Site Cleanup
:EY
LEY
}overnor
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
WESTERN REGIONAL OFFICE
436 Dwight Street•Springfield,Massachusetts 01103• (413)784-1100•FAX(413)784'1149
STEPHEN R.PRISe HARD
Corporation-PMC
6 Nonotuck Street
othampton,Massachusetts 01060.
ttn:David Tally
April 4, 2006
Re: Northampton(Florence)
296 Nonotuck Street
RTN 1-16060
NON#:NON-WE-06-3026
M.G.L.cO 21E 310 CMR 40.0000
THIS IS AN IMPTANT
NOTICE.
THIS NOTICE COULD RESULT T IN
SERIOUS LEGAL CONSEQUENCES
ROBERT W.GOLLEDGE,Jr.
Commissioner
Gentlemen:
r The Department's records
The Department of Environmental requirements (the "Department') has determined that meet's i not n
PRP for one or more release(s) you are not
compliance with one or more requirements enforced by the Department.
indicate that m you aze a Potentially Responsible site) Party ( )
hazardous materials at the disposal site(the site) named above. As of the date of this Notice,y
in compliance with regulatory deadlines for investigating and cleaning up the disposal site. Specifically,
Pro Plan to e Department for the ile of release of Notification
achine oil that was reported to the Department
at the above-referenced site.
assessed the required every actions after ttcompleted te of this the
Notideadlines that specified
noencompliance administrative
occurs ortconttiiinue. Such a
assessed far everyday 000 violation per day.
penalty may be assessed in an amount of up to$1, per the date and place that
Attached is a Notice of Noncompliance that describes(1)the requirement violated,(2)
the Department asserts the requirement was violated, (3) either the specific actions which must be taken in
(4) the deadline for taking such actions or submitting such a proposal. These
order to return to compliance or direction to submit a written proposal describing how and when you plan o
return q i to compliance and d ) Please consult the
Plan or "MCP").
requirements are governed by Massachusetts General Laws Chapter 21E, and dv neon the Departments
thereunder MCP (310 CMR 40.0000 — the Massachusetts requirements.ts. The MCP viewed
through the State
web for the complete explanation of these requirements. TCe MCP may
web page at h •:Ilwwwstate.ma.uslde•/bwsclre s.htm. Copies may be purchased
Store in the State House(617-727-2834).
This information is available in alternate for on Call Donald M.
Wide Web:ams.ADA Coordinator
ratl6 p5564057 TDD Service-1-80049&2207.
0 Paled on Recycled Paper
Pro Corporation-PVC
RTN 1-16060
NON-WE-06-3026
Page4 of 4
DESCRIPTION AND DEADLINES OF ACTION S TO BE TAKEN
On or before Aori114 2006, submit to the Department a signed Release Notification Form(attached).
On or before Anri127 2006, submit to the Department an Immediate Response Plan or Response Action
Outcome Statement prepared by a Licensed Site Professional in accordance with the Massachusetts
Contingency Plan, 310 CMR 40.0000.
If the required actions are not completed by the deadlines specified above, an administrative penalty may
be assessed for every day after the date of this Notice that the noncompliance occurs or continues. The
Department reserves its rights to exercise the full extent of its legal authority in order to obtain full
compliance with all applicable requirements, including, but not limited to, criminal prosecution, civil
action including court-imposed penalties, or administrative action, including administrative penalties
imposed by the Department.
Department of Environmental Protection
By:
( L
4rymin
t ' �u egional Prector
Bureau of Waste Site Cleanup
orporafion-PMC
1-16060
.WE-06-3026
3 of 4
NOTICE OF NONCOMPLIANCE SUMMARY
NON-WE-06-3026
TITY IN NONCOMPLIANCE:
Corporation-PMC,296 Nonotuck Street,Northampton,Massachusetts 01060
)CATION OF NONCOMPLIANCE:
IN 1-16060
Corporation-PMC,296 Nonotuck Street,Northampton,Massachusetts 01060
ATE S OF NONCOMPLIANCE:
larch 21,2006, for the submission of a Release Notification Form and an Immediate Response Action
Ian.
)ESCRIPTION OF RE S U IREMENT S NOT COMPLIED WITH:
4n January 20,2006,the Department was notified of the detection of greater than 1 inch of non-aqueous
phase liquid (machine oil) on groundwater underlying the machine shop at the Pro Corporation-
well.
PMC
facility. The release was discovered after the installation of a soil boring/groundwater monitoring The release may be due to historical oil leakage from machinery.
The Department assigned release tracking number (RTN) 1-16060 to this release, and issued a Notice of
Responsibility (NOR), dated January 24, 2006, to roCorporation-t and assessment Th NOR
release. The NOR noted PMC of its responsibility to insure appropriate
NOR noted within a sixty Release 0) days of the date of oral anotifica on to Response
the Department of the release, by be
Marh submitted within sixty ( ) Y
March 21,2006. The Department has not received either of the required submittals as of the date of this
Notice of Noncompliance.
310 CMR 40.0333 requires that a completed Release Notification Form be submitted to the Department
within 60 calendar days of the date of the oral notification of an Immediate Response Action Plan
310 CMR 40.0420 requires the 'submission to the Department
within sixty (60) days of notification to the Department of the need to conduct an Itrunediate Response
Action, unless an Immediate Response Action Completion day or a Response Action Outcome
Statement is submitted to the Department within this sixty(60) y
DESCRIPTION OF ACT OR OMISSION CONSTITUTING NONCOMPLIANCE:
Failure to submit a Release Notification Form and Immediate Response Action Plan to the Department.
rage i u
Ina, Ellen
Bokina, Ellen
,. Monday, May 11, 2009 12:18 PM
'Richard A. Starodoj
'Xanthi Scrimgeouf
eject: RE: UIC approval Northampton_296 Nonotuck St
Rick:
<you for deuce as the
pr val of your approval for the geothermal wells at 296 Non tluck St.the Please accept
i of Health o office.as Upon col p etio well permit. I, pleasesendtto thee Northampton BOH office a copy of the out
i of Heh office. Upon completion of the project, p
jilt to complete the BOH file.
Neely,
1 Bokina
'tartan
ierst Public Health Department
3oltwood Walk
ierst, MA 01002
;ct: 413-259-3241
413-259-2404
---Original Message---
From: Richard A. Starodoj Emailto:RSTAROD03@ecsmnsult.com
Sent: Friday, May 08, 2009 4:48 PM
To: Bokina, Ellen 296 Nonotuck St
Subject: FW: UIC approval Northampton_
We have our state approval for the water loop and DX wells as noted below! Great news! Please let
me know when the local permit is ready.
Have a great weekend!
Rick
From Cerutti, Joseph ( ) I a'PMJOSeph.Cerutti @state.ma.us]
Sent: Friday, May 08, 2009
To: Richard A. Starodoj
Cc: Sam Johnston;Subject:UIC approval Daniel Felten; Poland,
Northampton 296Nonotuck St DCR)
Hi Rick,
The of two purpose of
closed-lloop you
ource heat1pump wells 5 DX wells tand the start-uP of the Ration the
-oval for the start-up of the DX system. The ground-loop portion of the
standard closed-loop system at 296 Nonotuck Street, Northampton. I will need some additiona
closed-loop prior to issuing only cop
closed-loop system shall only contain an ethanol and water solution the system shall include automatic
shut off controls/devices in the event of a significant pressure drop in either the water or refrigerant
loops. The DX system shall also include automatic shut off controls in the event of a significant pressure
Prior to charging the DX system, MakcDDEP requires that
as o cross ate theal
type in the refrigerant loop.
diagram am of typical you well cone to u use. Missing imil the app
diagram of the typical DX well construction details (similar to the sketch that showed both the Keliz and
5/11/2009
rage L.
conventional closed-loop side by side cross sections. Normally MassDEP does not issue the UIC
registration number sectional diagram it detailed ton.
P rrtothe start ofdell ng the DX wells please confirm my assumption that the of the
borehole to within a few feet or less of the header trench will be grouted with the Geo supergrout send and s end, the spropo
designer sea sectional nal diagram within a
the following.week. Once the Installation of the 7 wells is
sed If the system , 1 was Winter St Street 5
th FI.,Boston,MA 02108 indicating send a letter to that the system wasp stalled as as
UIC
es Program,
designed and shall submit a copy of the well completion reports that were sent to Department of
Conservation and R creaolcati (DCR's)Well Driller Program and local Board of Health (including latitude
and longitude
If the system was not installed as designed, the system designer shall submit a BRP
WS06e modification registration form with the above
referenced any revisions UIC r registration
attachments number,
such m l design
e refe UIC ri number, completing
only those pans of the form that were changed,
plans or specifications. A copy of the well completion reports that were sent to DCR's well drilling
program and local Board of Health shall also be submitted.
Following MassDEP's receipt of the above, the UIC Program will issue a final approval letter for the UIC
registration.
Please be aware that the issuance of the above UIC registration number only indicates that MassDE s
including but not limited to Board of Health permits for well
UIC Program has received the information that we have requested. There may be other local permits.
installations or and Building that apply, 9
registration umberllby M2SSDEP does not superrsede the requirements remen s of anyhothe state or a UI trenching work.
local regulatory entity.
Please also be aware that the above UIC registration number is only for the installation of the 2 standard
closed-loop and 5DX wells. It does not include the proposed Kelix well installation. I anticipate issuing
the registration number for the Kelix well by the end of next week. Regarding the Kelix well 1 mt hobo if
Laurene Poland of the OCR Well Driller Registration Program also wants to be on-site to witness the well
installation process. I don't yet know her availability for the week starting May
your proposed Kelix drilling schedule changes so that I can coordinate with Laurene and DEP staff.
Joe Cerutti
Hydrogeologist
MassDEP
1 Winter Street, 5th Floor
Boston, MA 02108
617 292-5859
fax 617 292-5696
From: Richard A. Starodoj [mailto:RSTAR0D03@ecsconsult.com]
Sent: Monday, May 04, 2009 1:29 PM
To: 'Cerutti, Joseph (DEP)'
Cc: Sam Johnston; Daniel W. Felten
Subject: 205422 -the requested additional information for Geothermal Permitissuance - ECS, 296
Nonotuck Street, Florence MA
Good afternoon Joe, 2008 email to Dan
I am sending the additional information that your requested in your December 9,
5/11/2009
regcJVI-
=elten regarding our UIC application for the installation of wells to operate our proposed geothermal
seating units at our office at 296 Nonotuck Street, Florence (Northampton) MA.
are
and the approximate three
DX footprints geothermal units at a indicated on the this draft Site Planation of the water
Unit 1 will be a 5 to direct exchange unit utilizing five, 3 inch diameter, 100 foot long bores installed at an
approximate 30 degree angle from the vertical in a fan pattern. These wells will be installed inside of the
existing f the building with the pattern being under fee the existing building.
wells at horizontally degreey away vertical
from the for
each of the five wells is approximately 87 feet. Installation of the wells at a 30 degree angle from the
copPer approximately ' inch diameter. Geo super grout will be
vertical will result in the bottom of the well being located approximately
surface for grog point. Tubing ed will be copy
utilized for grouting. Attached is a link to Super gr and nets all technical documents.
requirements. cop witl
htto�llsuoeraroutoroducts� Super grout meets all permeability requirements. The copper tubes
from each bore will be brought up in the central drill pit and manifolded together by brazing They
then proceed to the geothermal unit which will be located
angled DX well is located in the lower left corner of the attached
immediately adjacent to the well head area.
site plan.an. Cn hodic prof of
ct the ill
one avn. Cathodic protection will be
ha provided as needed of C st rfield on in the Mass a regulations.
York. Due to
on having Kirke Henshaw of Henshaw Well Drilling of Chesterfield on Site to conduct oversight of the DX
well drilling be conducted by Rob Feuer with Smart Energy, Inc. out of New Rochelle,
weekend interior location May 16 of the es ndrillingwcreate a have tentatively v tse eduled this drilling to take place on the
Unit 2 will be a 5 ton closed loop water unit. It will utilize two approximately 500 foot deep vertical bores
of 5 and 1 12 inch diameter. Temporary casing will be utilized from the surface to and into the bedrock
interface. Two lengths of geothermal 1 and 1/.inch diameter polyethylene tubing will be inserted into each
borehole to create a"U-tube". The U tube in each of the wells will be manifolded together with heat fused
connections and run back to the building in a trench as shown on the plan. The piping wirl placed at a
depth of between 3 and 4 feet below the surface. Piping will run to the geothermal unit which will be
located in the third floor mechanical room of the building and will enter from the floor after passing
through
r o gmix. We foundabon wall
would like to start depth.
install of thegU for the well-loop wells on will
May 11th the if possible. entonite Portland
Unit 3 will be a 5 ton closed loop water unit. It will utilize a Kelix brand heat exchange tube located in a 6
inch diameter bore hole. Details of the Kelix install procedure supergrout
and depth
from the in he Unitt 1 the building ri n
htt•dlkelix.coml•ubliGima•es/Formsllnstall5.•df Geo supergrout as referenced in the Unit 1 description
will be the for the back sorbed of the hole. Piping Piping yp
will be same trench as that
the wells e for un t Unit The Kelix sall is a tali Kelix
scheduled for the will be in
of May the
18th.
The water w A.lsThe Units
have a numberlof Mass installed
Registered Well Drillers eon staff Artesian
The erlegstration
Longmeadow, MA. Y
number of the particular driller overseeing the install will not be available until the install takes place and
we provided with
in the e comp eti n future ports. The
h commencement meof the re giste red well ll driller installing the DX loops will
The attached plans shows the proposed well locations floor) of the wells
wells
that
and piping trench from the water loop wells gel s
to the building to be serviced by the 3 units. The units will serve the 3rd floor(top )
contains the mechanical room. Piping and well locations may need to be shifted slightly due to
conditions encountered during install line setback requirement.
There are no well loations proposed that are close to the 10 foot property
The Northampton Health Department stated that there is only
ly o street to the east the former part of the
ly one know well in the vicinity which is
located ro-Br at h238 co aleck Street a the next property r t
Pro-Brush mill complex). This well is located greater than 400 feet to the east of the proposed DX area
lied for the local well construction and trenching permit from Northampton along
and greater than 500 feet from the water loop area. I have attached the Health Department's faxed
response. We have app
with a Dig-Safe number.
5/11/2009
rage4 us -r
Attached is a copy of a plan on file with the Hampshire County Registry of Deeds (Plan book 218, Page
15) indicating the AUL area in question. The eastern most foot print of the DX system at a depth of 87
feet below to et de is of the greater than 65 feet from the AUL area. The DX pit area is located greater
than
We request permission to use ethanol in the water loop wells and the Kelix system.
We have applied for and expect local permit approval from the Board of Health (well permit)and DPW
(trench permit) by Thursday 5/7/09. We have received clearance from the Conservation Commission to
proceed.
Please call with any questions.
Rick
Rick Starodoj
ECS, Inc.
588 Silver St.
Agawam, MA 01001
Voice 413-789-3530 ext325
Fax 413-789-2776
Cell 413-374-3521
Richard A. Starodoj
Senior Field Technician
cs
588 Silver St.
Agawam MA 01001
tel 413.789.3530 fax 413389.2776
rtarodoj @ecSCOn su ILCOm
www ecs
cot contains
confidential, privileged or subject to the work product doctrine
This electronic message and any attachment contains information from Environmental Compliance
Services. Inc.. which may be proprietary.
and thus protected from disclosure. It is intended for the addressees only If you are not an addressee.
taken
any and copying
may be unlawfucontents lf you are not or any nplease inforrm the senderimmediately.
5/11/2009
Heon
Ellen Bokina
Tuesday, June 02, 2009 3:11 PM
Madeline Neon
Xanthi Scrimgeour
FW: 205442-Local well permit
.Ilne.
please send out a copy of the well permit to Mr. Starodoj for this address? 1 believe the permit was completed
o him. If you can't find it let me know. It would be in the pending septic file next to the printer.
.1,
ina
Public Health Department
pod Walk
MA 01002
13-259-3241
5-259-2404
,final Message-----
2ichard A. Starodoj [mailto:RSTARODO3 @ecsconsult.com
"uesday, June 02, 2009 1:54 PM
Gina, Ellen
3: 205442 - Local well permit
dternoon Ellen,
II not been able to locate the copy of the well permit for 296 Nonotuck Street in Northampton that your office had
i me last week. My guess is that it was misdirected at our office while I was on vacation. If you could send along
Sr copy I would appreciate it very much.
:s,
Starodoj
1, Inc.
silver St.
vam, MA 01001
e 413-789-3530 ext325
413-789-2776
413-374-3521
hard A. Starodoj
nor Field Technician
ICS
OLE BUSINESS E ENVIRONMENT CONVERGE
8 Silver St.
lawam MA 01001
1 413.789.3530 fax 413.789.2776
tarodo ecsconsult.com
sultcom
te i pmt Ins email unless you really need to
product doctrine and thus protected frontsdis the E meIlt
flc message and any attachment contains information from Environmental Compliance Services. Inc , which
foir t e ddressees o only. If you or subject to the work p
for the (o addressees only- e you are not an addressee. and disclosure Ia copying
�n taken (or not taken)in reliance on It is unauthorized and may be unlawful. If you are not an addressee.
-m the sender immediately.
2
NON-WE-13-3021, R7W;1-17208
prosecution,civil action including court-imposed civil penalties,or administrative action,
including administrative penalties imposed by the Department.
Please note that as of January I,2009,all submittals for this release that require a Licensed Site
Professional SP 0 inion must be submitted through eDEP,MassDEP's electronic document and
form submittal repository. For more information on electronic submittal of forms and reports,
please visit MassDEP's website,http://www.mass eov/den/se
rvice/comnlianceJede onlfhtm.
You must employ or engage an LSP to manage, supervise or actually perform all response
actions which you intend to undertake at this disposal site. You may obtain a list of the names
and addresses of LSPs by contacting the Board of Registration of Hazardous Waste Site Cleanup
Professionals by telephone at(617)556-1091 or via the following internet link:
htt o:///mubli--- is deo state na us/LSP/Ispseamh.htm.
If you have any questions about this Notice or any of the requirements contained in it,please
contact Catherine Wanat at 413-755-2216. In responding to this Notice of Noncompliance,
please reference the Release Tracking Number, RTh 1.17208, and the Enforcement Tracking
Number,NON- P anee,
WE-13-3021, to ensure proper tracking of your response.
Sincerely,
Eva V. Tor
Deputy Regional Director
Bureau of Waste Site Cleanup
IRA/ACTACertified Mail# 7011 3500 0000 8444 5903,Return Receipt Requested
L-D,AUDCOM/NAFNON
Enc. Notice of Noncompliance
ec: Northampton Mayor's Office
Northampton Health Department
Daniel Felton, LSP-of-Record
Denise Andler, DEP-WERO
Derrick Bruce, DEP-WERO
Commonwealth of Massachusetts Affairs
Executive Office of Energy ronmental
Department of Environmental Protection
- Western Regional Office•436 Dwight Street,Springfield MA 01103.413-784-1100
RICHARD K.SULLIVAN JR.
Secretary
PATRICK
P MURRAY
u Goesmor
CERTIFIED MAIL 7011 3500 0000 8444 5903
Nonotuck Mill,LLC
Attention: Mr.Matthew McDonough
270 Exchange Street
Chicopee,MA 01013-1677
KENNETH L KIMMELL
Commissioner
May 14, 2013
RE: NOTICE O NONCOMPLIANCE OMMPLLIANCE
Northampton,
RTN: 1-17208
NON-WE-13-3021
Failure to Meet Performance Standards for
Immediate Response Actions
Dear Mr.McDonough:
The Department of Environmental Protection("MassDEP" or the"Department")has determined
with one or
that you(in this letter"you"refers to Nonotuck Mill,LLC) are o s in
co dplianceate that you are
more requirements enforced by the Department. The Department'
a Potentially Responsible Party(PRP)for one or more releases of oil and/or u aaz o s materials
at the disposal site(the site)named above. As of the date of this Notice,you not in
did not are
compliance.with submitted ran Immediate e for Action Completion Rep the t disposal site.
Specifically,you
applicable performance standards. administrative penalty
If the required actions are not completed by the deadline specified below,an
may be assessed in an amount of up to$1,000.00 per violation per day.
may be assessed for every day after the date of this Notice that the noncompliance occurs or
date and
Attached Such a penalty Y the requirements violated,( )
requirements were violated,(3)the specific actions which
Attached is a Notice of Noncompliance that describes
q
must that taken the in rdmeot esertt the mq q the deadline for taking such actions: These
and the regulations
muu be ts in order to return to samusettse General Laws Chapter 21E,and(4) Please
adopted thereunder are governed(310 by 40.0000 u the Massachusetts Contingency Plan or"MCP").adopted the MCP for r r the CMR
the Department's the MCP web pa complete
e at htta//www.masi..f ov/de./clemanuflaws/ree at.him yCopies viewed
may be
the Depertment's web page
purchased thtough_the State Book Store in the State House(617-727-2834).
The Department reserves its rights to exercise the full extent of its legal authority in order to
obtain full compliance with all applicable requirements,including,but not limited to,criminal
MassDEP Webslte:wmumase govldeP
This information Is available In imamate format.call Michelle Wat rs E on RenDiler IW OIrecta,M 617-292-5751.TDDA 1866-599-7822 or 1.617.574-6868
NON-WE-13-3021,PTN: 1-17208
4
310 CMR 40.0426(1)-An Imminent Hazard Evaluation shall be performed as part of an
Immediate Response Action at sites where a release or threat of release could pose an Imminent
Hazard to human health, safety,public welfare, or the environment. -
On March 8,2013, an IRA Status- Completion Report was submitted. Despite the availability
of indoor air data from a sample collected on October 26,2012 which indicated the presence of
VOCs above the Commercial Threshold Values listed in the Department's Interim Final Vapor
Intrusion Guidance(WSC#11-435),no further sampling was performed to evaluate the
concentrations of VOCs in the basement and other areas of the building. The Report included a
statement concluding that site conditions do not present an Imminent Hazard. However, there
was no documentation that a site-specific Imminent Hazard Evaluation which included the
available VOC and PCB indoor air data had been performed for the site.
The IRA Status-Completion Report did not include consideration of the following relevant
policies or adequate justification for alternative approaches:
• The Interim Final Vapor Intrusion Guidance(WSC#11-435)addresses identifying, assessing
and mitigating vapor intrusion pathways at disposal sites. The IRA Status-Completion
Report includes several approaches not recommended in the VI Guidance, and adequate
justifications were not provided for the alternatives chosen. The approaches at variance with
the guidance are: (1)detections of VOCs in indoor air above the Commercial Threshold
Values were not followed up with more assessment; (2)first floor and outdoor air samples
were not collected simultaneously with the basement air samples; (3) EPA Method TO-15
was not used for analysis of the indoor air VOC samples; (4)multiple lines of evidence were
not used to evaluate the indoor air exposures; and (5)4-hour sample collection periods were
used instead of the 8-hour period recommended for commercial building uses.
• The.Compendium of Quality Control Requirements and Performance Standards for Selected
Analytical Protocols (WSC#10-320)or CAM includes EPA Method TO-15 for analysis of
VOCs in air. The IRA Status-Completion Report documented the use of a non-CAM
method,EPA Method TO-14a, but did not include an adequate support for the use of this
method, considering its use in concluding that an IRA is no longer needed at the site. The
Report stated only that"the use of these methods is considered to have provided an adequate
means of determining indoor air impacts at the site."
ACTIONS TO BE TAKEN AND THE DEADLINES FOR TAKING SUCH ACTIONS:
On or before June 14,2013, submit to the Department:
(1) La icensed Site Professional i n acco dance with the Massachusetts Contingency Plan 310
CMR 40.0000. The revised report shall include an expanded investigation of indoor air
exposures at the site and a site-specific Imminent Hazard Evaluation. The Imminent
Hazard Evaluation shall address the Department's determinations above, specificall
incorporating data from a current round of indoor air sampling data for VOCs, CVOCs,
and PCBs, (b) y'(a)
O addressing areas of the building other than the basement, (c) using the
revised USEPA toxicity values for trichioroethylene(TCE)for comparison to a Hazard
3
NON-WE-13-3021,RTN: 1-17208
NOTICE OF NONCOMPLIANCE,
NON-WE-13-3021
RTN 1-17208
THIS IS AN IMPORTANT LEGAL NOTICE.
FAILURE TO RESPOND COULD RESULT IN SERIOUS LEGAL CONSEQUENCES.
NAME OF ENTITY IN NONCOMPLIANCE:
Nonotuck Mill,LLC
LOCATION WHERE NONCOMPLIANCE OCCURRED OR WAS OBSERVED:
RTN 1-17208,296 Nonotuck Street,Northampton
DATE WHEN NONCOMPLIANCE OCCURRED OR WAS OBSERVED:
March 8,2013-submittal of an Immediate Response Action(IRA) Status-Completion Report
DESCRIPTION OF REQUIREMENTS NOT COMPLIED WITH:
310 CMR 40.0049(5) - Air-emission control treatment devices shall be designed,constructed,
and operated in a manner that will ensure removal of at least 95%of the emitted oil and
hazardous materials,on a weight basis.
On January 17,2013, a ventilation system was installed at the site in an effort to reduce the
levels of polychlorinated biphenyls(PCBs)and volatile organic compounds(V Ore ),including
chlorinated VOCs(CV OCs)which had been detected in indoor air. The system draws air from
the treatment system recirculation tank and the building interior and passes it through v v.apor-
phase granular activated carbon prior to the discharge of the air to the building exterior. The
IRA Report and concurrent Remedial Monitoring Report did not contain documentation
demonstrating that this air emission control treatment device is meeting the required contaminant
removal requirements. - -
310 CMR 40.0191(2) -The Response Action Performance Standard must be employed during
the performance of all response actions conducted pursuant to the MCP, and must include,
without limitation,the following:
(a) consideration of relevant policies Department(b) use of accurate and upoo-danethods standards and practices,,equipment and technolo gies
which are appropriate,available and generally 2
communities conducting esponse ac ons ac ordan wi with M.O.D.. L c.21E and the MCP
under similar circumstances;and
(c) investigative � defensible, precision and
accuracy with the intended scientifically
se of the results of such investigations.
7N-WE-13-3021,RTN: 1-17208
Index of I,based on developmental effects from short-term exposure(see 310 CMR
40.0955(2)(c)); and(d)using EPA Method TO-15 for VOC air analysis or providing
adequate justification for using another method; and
(2) a Remedial Monitoring Report that specifically addresses the air emission control
treatment device,including monitoring results to demonstrate its efficiency in
contaminant removal. administrative penalty may be
If the required actions axe not completed by the deadline specified,an
assessed for every day after the date of this Notice that the noncompliance occurs or continues. The
but not limited to,criminal
Department reserves its rights to exercise the full extent of its legal authority in order to obtain
full compliance with all including court-imposed including,
c civil penalties,or administrative action,
including ad ini action ipenuding
including administrative penalties imposed by the Department.
For the Department of Environmental Protection:
zze-
Eva V.Tor
Deputy Regional Director
Bureau of Waste Site Cleanup
Commonwealth of Massachusetts
Executive Office of Energy &Environmental Affairs
.PATRICK
Department of Environmental Protection
Western Regional Office•436 Dwight Street, Springfield MA 01103.413-784A100
MAUVE VALLELY SWUM
Secretary
Nonotuck Mill LLC
270 Exchange Street
Chicopee,MA 01013
Attn: Matt McDonough
nAVin W.GASH
Commissioner
January S, 2015
Re: Northampton,296 Nonotuck Street
RTN: 1-17208
Immediate Response Actions
Imminent Hazard Notification
Dear Mr.McDonough:
The Department of Environmental Protection(the Department)received an oral Imminent
Hazard notification from Environmental Compliance Services,Inc. (ECS)on January 2,
The notification was based on indoor air concentrations of tetrahydrofuran of 4,000 µg/m3 in the
building at the referenced site. Acetone,ethanol and n-butanone were also detected in the indoor
air sample.
The following concentrations activities is indoor air at thcferenced site:investigate
ollection of another indoor
air for collection of a
sir -slabls for as able organic i e area of the elevvated indoor air sample;collection of an outdoor air
sap-pleb soil gas sample
sample; and evaluation of the potential for inventory(shoes) stored in the building to be a source additional
of indoor the indoor
sample air e contamination. The outsid of the suspected Department oor air source area for collecting
omparison and evaluating
indoor gr samp
building maintenance n source of�tkre if any an�and/or construction products use
in the building could be the
The proposed assessment activities are to be performed as part of the existing Immediate
Response Action(IRA)being conducted at the site to address the presence of light non-aqueous
phase liquid and vapor intrusion by chlorinated VOCs.s. B applicable,either:either 4(I a retraction of the
Nonotuck Mill LLC must submit to the Departmenumen plica le(ei a Release Notification
Imminent Hazard notification,with supporting
Ibis Information is available In alternate format Call Michelle Watere-Ekanem,Diversity Director.at 617-292-6761.TrY#Mad$RBlay Service 1-800439-4370
MassDEP Wabsite:a'^m'.mass.govIdep
Printed on Recycled Paper
1-17208 IRA
Form,an Imminent Hazard Evaluation pursuant to 310 CMR 40.0426, and an IRA Plan
Modification. If further reporting for this Imminent Hazard notification is required,it should be
done under the schedule of Status Reports established for the existing IRA.
Please provide the Department with the laboratory analytical results from the additional
assessment as soon as they are available.If you have any questions about this letter,please
contact Catherine Wanat at 413-755-2216.
Sincerely,
Eva V. Tor
Deputy Regional Director
Bureau of Waste Site Cleanup
ec: Northampton Mayor's Office
Northampton Health Department
MassDEP WERO: D. Slowick,1 Ziegler
ECS: N.Berube,D.Felton,LSP-of-Record
2