16 Letters 1989-1998 lq\
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L S. GREENBAUM
CommFsooner
iN J. HIGGINS
tegmoai Director
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4/S-794-1100
SEP 1 4 1989
Central Chambers Realty Trust
16 Center St.
Northiampton, MA
Attn. Carol Heon, Building Manager
Re: Northampton - W88-672
16 Center St. SA I 0685
M.G.L. ch. 21E
NU1'10E OF RESPONSIBILITY
Dear Ms. Heon:
This letter concerns the release of #2 fuel oil from a leaking underground
storage system located at 16 Center St. , Northampton, MA.
This condition constitutes a release and/or threat of release of oil or
hazardous materials from the site. The prevention and/or mitigation of such a
release or threat of release is governed by M.G.L. ch. 21E, the "Nassach»cetts
Oil and Hazardous Material Release, Prevention and Response Act,"
Chapter 21E identifies as responsible parties the current owner or operator of
a site from or at which there is or has been a release or threat of release of
oil or hazardous material; the past owner or operator of such a site; any
person who directly or indirectly arranged for the transport, disposal, storage
or treatment of hazardous materials to or at such a site; any parson who
transported hazardous materials to such a site; and any person who otherwise
caused or is legally responsible for a releas< or a threat of reicase at such a
site. Such parties are jointly and severally liable without regard to fault
(M.G.L. ch. 21E, section 5(a)) .
This letter is to inform you in writing that:
(1) Information available to the Department of Environmental Quality
Engineering (pursuant to Stat. 1989, c. 240, 101. , ". . . the Department
of Environmental Quality Engineering shall be known as the Department of
Environmental Protection, ." hereinafter in this document referred to as
the "Department") indicates that you may be a liable party pursuant to
section 5(a) as described above;
(2) The Department is authorized pursuant to M.G.L. ch. 21E
sections 3A(j) and 4 to take such response actions at the site
as it deems necessary should you fail to respond to the releacn
or threat of release in an appropriate and timely manner; and
(3) You may take the prescribed response actions in lieu of the
Department.
Original Printed on 100% Recycled Paper
Your liability noted in (1) above may include up to three (3) times the cost
of any and all response actions conducted by the Department due to the
relnasa/threat of release, including all contract, administrative, and
personnel costs In addition, you may be liable for all damages for any
injury to, destruction, or loss of natural resources due to the
release/threat of release. Additional liability may be imposed under M G L
ch. 21E section 11 in the form of fines or penalties for each violation of
chapter 21E.
Regardless of who perfons the necessary work at the site, you may be liable
for all the Department's response action costs. Response action costs
include the cost of direct hours for work performed by Department employees
in overseeing or arranging for response actions, any expenses incurred by the
Department in support of those direct hours, as well as payments to the
Department's contractors (for more detail see the cost recovery regulations
at 310 CMR 40.600 et seg.).
Your liability constitutes a debt to the Commonwealth. The debt,
together with interest, constitutes a lien on all of your property in the
Commonwealth. In addition to the foreclosure remedy provided by the lien,
the Attorney General of the Commonwealth may recover that debt or any part of
it in an action against you. You may be liable for additional penalties or
damages pursuant to other statutes or common law.
The Department has determined that a Preliminary Assessment and Phase I -
Limited Site Investigation must be completed at this site in accordance with
310 CMR 40.541 and 310 CMR 40.543, respectively. The need for Short Term
Measures (310 CMR 40.542) should be evaluated throughout this process and the
final report should include a completed Interim Disposal Site Classification
System form (310 CMR 40.544) and a scope of work for a Phase II -
Comprehensive Site Assessment (310 QTR 40.545) , if needed
If you intend to undertake the required actions, you must notify the
Department in writing of your intent no later than seven (7) days from the
date you receive this letter and contract with an environmental consultant
capable of performing this work and acceptable to the Department. Your
consultant must be able to submit to the Department a Preliminary Assn sment,
a Phase I - Limited Site Investigation report, the completed Interim Disposal
Site Classification System form, and a scope of work for Phase II, if needed,
by no later than ninety (90) days from the date of this letter.
Depending on the information generated by the above work, the Department may
require additional investigations, studies, and actions. If you fail to take
theme actions or if you fail to perform these tasks in accordance with the
Department's requirements, the Department may perform response actions in
your stead and recover up to three (3) times its costs from you in accordance
with the provisions desr-ribed above
If the Department does not hear from you within the time sd .ified above, the
Department will assume that you have refused to accept responsibility for the
site. The Department will soon thereafter commence response actions, and
will expect to recover to the full extent of the liability set forth above
If you have any questions regarding this notice, pleat contact Cyndi Ca ter of
Emergency Response. future correspondence and/or reports should be submitted to
Alan Weinberg of Waste Site Clean-up.
Very truly yours,
F. Joyce
Regional Engi
Bureau of Waste Site Cleanup
CC:bmz
WSC003S:central
Certified Mail #P128448254, Return Receipt Requested
cc: Northampton Board of Health
Northampton Fire Department
_ S. GREENBAUM
commissioner
IN J. HIGGINS
egional Director
096art etzt/ `.wcu,9 6'111tee/` C/
Westerns cow J
486 Oa At cfteeee, ffreadylea, S 01108
478-76'4-1100
OCT 2 0 1989
Evert N. Fowle, Trustee
Central Chambers Realty Trust
16 Center Street
Northampton, Mass. 01060
RE: Northampton - 1-0685
Center Chambers Realty
Trust
Dear Sir:
This will acknowledge receipt of your letter dated October 13 , 1989
requesting an extension for submittal of a Preliminary Assessment
Form and a Phase I - Limited Site Investigation, as required by the
Notice of Responsibility issued by the Department on September 14 ,
1989 . You are requesting that the submittal deadline be extended.
until the end of July, 1990 due to your planned absence of several
months, financial considerations, and in view of the fact that the
release source has been removed and contamination at the site is
limited, confined and unlikely to spread.
The Department hereby approves the requested extension and amends
the Notice of Responsibility, dated September 14, 1989 , to require
submittal of a Preliminary Assessment, Phase I, and Interim Sits
Classification Form by no later than July 31, 1990.
If there are any questions, please contact Alan Weinberg of this
office.
SFJ/AW/aw
fowle. ltr
cc: Northampton Board of Health
9922
_nth
Regional Engi eer
Waste Site Cleanup
Original Printed on 100% Recycled Paper
'.LIAM F.WELD
ernor
3E0 PAUL CELLUCCI
Governor
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
WESTERN REGIONAL OFFICE
Central Chambers Realty Trust
16 Center Street
Northampton, MA 01060
ATTN: Ms. Carol A. Heon, Manager
December 4, 1996
RE: NORTHAMPTON-A-0685
NO FURTHER ACTION
RECOMMENDATION
16 Center Street
TRUDY COXE
Secretary
DAVID S. STRUHS
Commissioner
NOTICE OF AUDIT
This is an important notice.
Promptly respond to any requests contained he rein.
Dear Ms. Heon:
Maaaarhusetts General Law Chapter 21E requires the Massachusetts Department of
Environmental Protection (the Department) to audit response actions not overseen by the
Department at sites of releases of oil and/or hazardous material (OHM) 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. The audit will initially focus on
the undated Phase I - Limited Site Investigation Report (the "Phase I Report") completed for this
site and it's "no further action" recommendation. This report was received by the Department
on July 13, 1990. 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.
REQUEST for INFORMATION. Pursuant to M.G.L. c. 21E §§ 2, 4, and 8, 310 CMR 40.0165,
and 310 CMR 40.1120(1), the Department requires you (as used in this notice, "you" refers to
Dwight Street • Springfield, Massachusetts 01103 • FAX(413)704-1149 • TOD(413)7466620 • Telephone(413)784-1100
Printed on Recycled Paper(20%Post Consumer)
1 - 0685
Central Chambers Realty Trust) to provide the information in Attachment 1. You must prepare
written responses to each item and submit to the Department within fourteen (14) calendar
days of your receipt of this notice. Furthermore,your response must contain the
certification of submittal as specified in 310 CMR 40.0009 (Attachment 2).
If you do not have any portion of the information requested in your possession, custody, or
control, you must state this in your response and identify the person(s), if known to you, from
whom the information can be obtained. You must follow the procedure described in 310 CMR
40.0165(3) if you claim any information submitted is a trade secret or otherwise exempt from
public dicrlosure.
DO NOT IGNORE THIS REQUEST. Failure to respond to this request or the submission of
false or misleading information may subject you to enforcement action by the Department.
A copy of this request has also been sent to Mr. Paul Hatch, the consultant who prepared the
Phase I Report on your behalf for this site. You may consult with a consultant or Licensed Site
Professional (LSP) when preparing a response to this request. Note, however, that you, not your
consultant/LSP, are obligated to respond to this request. Send your complete response to this
request and the required certifications to the undersigned.
The deadline given for a response to this request is an "Interim Deadline" enforceable under 310
CMR 40 0167 You may request an extension of this deadline in writing to the Department
auditor listed below. The Department, however, is not required to grant a request for an
extension.
Note that you are obligated under 310 CMR 40.0165(2) to promptly provide the Department any
information relevant to this "Request for Information' and correct any errors in your response to
this "Request for Information' at any time in the future when you discover such information or
errors.
REQUEST for SITE INSPECTION. Pursuant to M.G.L. c. 21E §§ 2, 4, and 8, 310 CMR
40.0166, and 310 CMR 40.1120(1) employees, agents, and contractors of the Department may
enter any site to investigate, sample, or inspect any documents, conditions, equipment, practice,
or property as part of the audit. The Department has scheduled an appointment with you to
inspect the site on December 4, 1996 at 11:00 a.m. to discuss issues relevant to this audit. The
inspection will be conducted by Ms. Debra Kelley-Dominick. The inspection will be conducted by
Ms. Debra Kelley-Dominick.
At the completion of this phase of the audit the Department may:
1. Issue a Notice of Audit Findings (NOAF) which may include a statement of
violations or deficiencies and steps to correct those violations or deficiencies.
2. Request a meeting with you, and if you choose, a representative, to discuss
response actions and other supporting evidence to demonstrate compliance and
then issue an NOAF.
1 - 0685
3. Conduct further site investigations and then issue an NOAF.
4. Issue an NOAF that sets an Interim Deadline to correct violations or deficiencies
or to prepare an Audit Follow-up Plan.
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 can not comply with its requirements, please call Ms. Kelley-Dominick at (413)
784-1100 extension 222.
Sincerely,
Deyrfl. Kelley-Do 'nick
Environmental Analyst
SAL,_ V V
Catherine G. Wanat
Section Chief
Audits/Site Management
Bureau of Waste Site Cleanup
hand delivered December 4, 1996
CGW/DKD/dkd/
Enclosures
cc: Audit File, BWSC, WERO
Site File BWSC, WERO
Stephen Winslow, Audit Coordinator
Honorable Mary L. Ford, Mayor, City of Northampton
City of Northampton Health Department
Paul B. Hatch
ATTACHMENT 1
REQUEST FOR INFORMATION
This Request for Information (RFI) is addressed to Central Chambers Realty Trust, who has
been identified as a Potentially Responsible Party (PRP) for the 16 Center Street site (1-0685)
located in Northampton, Massachusetts.
This RFI is a continuing request. That is, if information requested here which is not known or
available to you as of the date of your response later becomes known or available to you, you
must forward such information to the Department. In addition, if you discover at any time after
submission of your response to this request that any portion of the information you have
provided is false or misrepresents the truth, you must notify the Department immediately.
Note that you must provide in writing any specific information that is responsive to the
questions even if that information has not been written previously in any document.
If you do not have any portion of the information requested in your possession, custody, or
control,you should state this in your written response and identify the person(s) from whom the
information may be obtained.
SUBMITTALS and QUESTIONS
The Department hereby requires the submittal of the following information and that you answer
the questions to the best of your knowledge and ability. Based upon the Department's
evaluation of these submittals, further audit actions may be indicated.
1. Submit any information/sampling results that may have been generated regarding
response actions conducted at the site subsequent to the submittal of the Phase I
Report on July 13, 1990. If no response actions were taken since this date,
provide a statement to that effect.
2. What were the ages of the 1,000 gallon #2 fuel oil underground storage tank
(UST) and the 5,000 gallon #2 fuel oil UST? Is there any information on the
condition of the 5,000 gallon UST i.e. inventory records, tank testing results?
3. Was any soil removed during the excavation and removal of the 1,000 gallon
UST in August 1989 or from the area of the 5,000 gallon UST? If so, provide
documentation of the volume of soil removed and transported off-site, the date(s)
of off-site transport and the final destination of these soils
4. Were any soils screened for Volatile Organic Compounds (VOCs) from the areas
of the 1,000 gallon and the 5,000 gallon USTs?
5. Were any catchbasins along the sewer lines running from the areas of the 1,000
gallon and the 5,000 gallon USTs inspected during the Phase I investigation? If
so, what observations were made?
1 - 0685
6. At what depths were the storm drain pipes, sanitary sewer lines and electrical
conduits encountered in the areas of the 1,000 gallon and 5,000 gallon USTs?
7. The Site Plan included in the Phase I Report identifies a sump in the boiler room
area of the basement. What is this sump used for? Was any oil observed in this
sump during the Phase I investigation? Identify any associated piping or
conduits and their point(s) of discharge.
8. Has the basement area where oil was discovered seeping through the foundation
wall in December 1988 been inspected subsequent to the submittal of the Phase I
Report in July 1990? If so, what observations were made and when? Has oil
been observed seeping through the basement wall subsequent to the removal of
this UST?
9. Are there any floor drains in the basement?
ATTACHMENT 2
CERTIFICATION OF SUBMITTAL (310 CMR 40.0009)
This certification must be included with your response to any request for further
information or documentation
I attest under the pains and penalties of perjury, (i) that I have personally examined and am
familiar with the information contained in this submittal, including any and all documents
accompanying this certification, and that based on my inquiry of those individuals immediately
responsible for obtaining the information, the material information contained herein is, to the
best of my knowledge and belief, true, accurate and complete. I am aware that there are
significant penalties, including, but not limited to, possible fines and imprisonment, for wilfully
submitting false, inaccurate or incomplete information.
Name (Print):
Position or title
Signature:
Date:
1 F WELD
PAUL CELLUCCI
Mar
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
WESTERN REGIONAL OFFICE
Central Chambers Realty Trust
16 Center Street
Northampton, MA 01060
ATTN: Ms. Carol A. Heon, Manager
December 27, 1996
TRUDY CORE
>
DAVID B.97RUUS
Conomomer
RE: NORTHAMPTON--1-0685
DISAPPROVAL of NO FURTHER
ACTION RECOMMENDATION
16 Center Street
NOTICE OF AUDIT FINDINGS
INTERIM DEADLINE LETTER
This is an important notice.
Promptly respond to any request'contained heron.
Failure to respond to any such requests could mutt in
serious legal consequences.
Dear Ms. Heon:
On December 4, 1996, Central Chambers Realty Trust (CCRT) was notified that the
Massachusetts Department of Environmental Protection, Bureau of Waste Site Cleanup (the
"Department") had begun to audit response actions conducted in response to releases of oil and
hazardous material (OHM) at the above-referenced site. This notice informs you (as used in this
letter, "you" refers to CCRT) of the results of the Department's audit.
The Department has found deficiencies in the actions audited. The Site Memorandum
(Attachment A) describes activities Department personnel performed during the audit,
summarizes relevant site information and lists deficiencies that currently exist.
DISAPPROVAL of NO FURTHER ACTION RECOMMENDATION
An undated Phase I - Limited Site Investigation Report prepared by Mr. Paul B. Hatch on behalf
of CCRT and received by the Department on July 13, 1990 concluded that no further remedial
response actions were necessary. On the basis of the information reviewed during the audit and
gM Street • Springfield, Massachusetts 01109 • FAX(413)784-1149 • TDD(413)746-6620 • Telephone(413)7N-1100
0 Printed on Recyckd Paw(20%Poet Consumer)
1 - 0685
in reliance upon the accuracy of that information, the Department, pursuant to 310 CMR
40.0610(4)0», hereby disapproves the no further action recommendation. This disapproval is
based on the levels of petroleum hydrocarbon contamination remaining in the soil at the site and
the lack of adequate assessment and documentation to support the conclusion that the site poses
no :n'firont risk.
DEP REQUESTS ADDITIONAL ACTIONS
The Department requests that you take the following actions to correct deficiencies that
currently exist and achieve or confirm compliance with the Massachusetts Contingency Plan
(MCP):
1. Employ a Licensed Site Professional (LSP) to conduct further response actions
including assessment of soil and groundwater and preparation of a risk
characterization, and within 180 days of the date of this notice submit either
of the following:
(a) a Response Action Outcome (RAO) Statement that complies with the
requirements of the MCP; or
(b) a Tier Classification Submittal pursuant to 310 CMR 40.0500, and, if
applicable, a Tier I permit application.
If you fail to take these actions within the specified Interim Deadline, the Department may
classify this site as a Tier Dl Disposal Site and require you to pay compliance fees until a RAO
in compliance with the MCP has been achieved.
You do not need further Department approval to take these actions. To respond to the
Department's request, complete the additional measures specified and then submit the
appropriate documentation of your actions.
DEADLINE FOR RETURNING TO COMPLIANCE
You are advised to complete the measures the Department has specified within 180 days of
the date of this notice to avoid additional enforcement action by the Department. The
deadline given for a response to this request is an "Interim Deadline"enforceable under 310
CMR 40 0167 You may request an extension of this deadline in writing to the Department
auditor listed below. The Department, however, is not squired to grant a request for an
extension.
LICENSED SITE PROFESSIONAL
A copy of this notice has been sent to Mr. Paul B. Hatch, the consultant who prepared the Phase
I Report for your disposal site. You may consult with a LSP when preparing a response to this
notice. Note, however, that you, not your LSP are obligated to respond to this notice and
remedy the deficiencies. Note that any submittals to the Department made in response to this
1 - 0685
notice must include the certification provided in Attachment B signed by an authorized
individual as specified in 310 CMR 40.0009.
ADDITIONAL COMMENTS
The Department has provided in Attachment A additional observations related to the
implementation of requirements applicable to your actions. The Department provides those
comments to help you and your consultant better understand our interpretation of M.G.L. c.
21E, 310 CMR 40.0000, and other requirements applicable to the site. Those comments do not
constitute violations or deficiencies. Therefore,you do not need to respond to them.
LIMITATIONS
The Department relies upon the accuracy of the information reviewed during the audit, including
information submitted during the course of the audit, to make these findings. These findings do
not: (1) apply to actions or other aspects of the site that were not reviewed in the auditt,(2) .
preclude future audits of past, current, or future actions at the site, (3) in any way constitute a
release from any liability, obligation, action or penalty under M.G.L. c. 21E, 310 CMR 40.0000,
or any other law, regulation, or requirement, or(4) 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 of the requirements contained in it, or
believe that you can not comply with its requirements, please call Ms. Kelley-Dominick at (413)
784-1100 extension 222.
Sincerely,
Debra d!Kelley-Dominick
Environmental Analyst
W
Catherine G. Wanat
Section Chief
Audits/Site Management
Bureau of Waste Site Cleanup
CERTIFIED MAIL #Z 082 549 871
RETURN RECEIPT REQUESTED
CGW/DKD/dkd/
1 - 0685
Attachments: A. Site Memorandum
B. Certification of Submittals
m: Audit File,BWSC,WERO
Site File,BWSC, WERO
Stephen Winslow, Audit Coordinator
Honorable Mary L. Ford, Mayor, City of Northampton
City of Northampton Health Department
Paul B. Hatch
ATTACHMENT A
SITE MEMORANDUM
NORTHAMPTON, 1-0685
CENTRAL CHAMBERS REALTY TRUST
16 CENTER STREET
I. RESPONSE ACTIONS AUDITED
• No Further Action (NFA) Recommendation under the Transition Provisions of the
Massachusetts Contingency Plan (MCP)
II. AUDIT ACTIVITIES
The audit consisted of the following activities:
• A review of the Department files.
• A Notice of Audit (NOA) and Request for Information (RFI) letter dated December 4, 1996.
• A site inspection on December 4, 1996.
ID. SITE SUMMARY
The site is located at 16 Center Street and is located in a commercial area in the central business
district of the City of Northampton. It includes the Central Chambers building and 2 alleyways along
the southern and eastern sides of the building. The Central Chambers building includes #12 through
#22 Center Street and was built in 1912. Central Chambers Realty Trust (CORT) is the current
property owner.
On December 6, 1988, the Department was notified that oil was discovered seeping through the
building's southerly cellar wall. A 1,000 gallon steel#2 fuel oil underground storage tank(UST)located
in the southern alley in the vicinity of the observed oil seepage and a 5,000 gallon steel #2 fuel oil UST
located in the eastern alley were in use at the time of this notification.
Southampton Sanitary Engineering Corporation (SSE) pumped the oil from each of these USTs in
December 1988, filled the 5,000 gallon UST in-place with a concrete slurry in December 1988 and
excavated and removed the 1,000 gallon UST and oil transfer piping in August 1989. The 1,000 gallon
UST was determined to be in"very poor" condition and had 2 holes of approximately.25 inch diameter
and several pits. Leakage from the piping was also determined to have occurred. A combination storm
and sanitary sewer line was found immediately below the 1,000 gallon UST. Water flowing from this
open-jointed sewer line discharged into the tank excavation. Approximately .25 to 0.5 inches of oil
accumulated on top of the water which collected in the tank grave and it was removed by SSE with
absorbent pads. Three soil samples from the bottom of the tank grave were analyzed for Total
Petroleum Hydrocarbons (TP1Is) by an infrared method. TPH concentrations were 7,910 parts per
million (ppm), 23,400 ppm and 28,600 ppm. No other samples were taken.
The Department issued a Notice of Responsibility to CCRT on September 14, 1989 requiring the
1 -0685
submittal of a Preliminary Assessment and a Phase I-Limited Site Investigation(Phase I)by December
13, 1989. The Department received an undated PA and a Phase I Report prepared by Paul Hatch on
behalf of CCRT on July 13, 1990. This report summarized background information and the results of
the above-referenced response actions. This report concluded that no further remedial response actions
were necessary based upon a conclusion that the site did not pose and was not expected to pose a
significant risk of harm to health,safety,public welfare or the environment over any foreseeable period
of time.
This site was fast listed as a 'Location to be Investigated•(LTBI) on January 15, 1990 and was listed
as a LTBI on the Department's August 1993 Transition List of Confirmed Disposal Sites and Locations
to Be Investigated. The Department sent a letter dated May 31, 1996 to CCRT informing them of the
requirements for LTBIs listed between April 15, 1989 and January 15, 1991 including the deadline of
August 2, 1996 for the submittal of a licensed Site Professional(LSP)Evaluation Opinion or a certified
statement that affirms a previously stated NFA Recommendation. On July 25, 1996, the Department
received a letter from CCRT dated July 23, 1996, stating that they believed they had submitted
everything necessary and assumed that the site was closed, referring to the NFA recommendation by
Paul Hatch in the Phase I Report.
IV. SITE INSPECTION
On December 4, 1996, an inspection of the site was conducted by Ms. Debra Kelley-Dominick as pan
of the audit requirements. Ms. Carol Heon, representing CCRT, accompanied Ms. Kelley-Dominick
during the inspection.
Prior to the site inspection the NOA/RFI dated December 4, 1996 was given to and reviewed with Ms
Heon.
Ms. Kelley-Dominick informed Ms. Henn that due to the limited amount of sampling (only- 3 so]
samples, no groundwater samples) and the high concentrations of oil found in the 3 soil samples at the
bottom of the tank grave that further assessment work would be necessary including the collection of
soil and groundwater samples and an assessment of the catchbasins.
The cellar was inspected including the area where the oil was observed to be seeping through the
building's southerly cellar wall in December 1988 and the area near the filled 5,000 gallon UST. No
oil staining or standing oil was observed. No floor drains were observed with the exception of a capped
drain pipe which at one time was connected to a roof drain pipe. This pipe was removed from the area
of the boilers and where the oil seepage occurred.
The alleys along the eastern and southern building walls were inspected including the areas of the
former 1,000 gallon UST and the 5,000 gallon UST. There was no visual evidence of contamination.
There were parked vehicles and a few overhead utility wires in the eastern alley. There were nc
overhead utilities in the southern alley.
V. SUMMARY of VIOLATIONS "
No violations were 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
I - 0685
dolations of the requirements reviewed in the course of the audit that warrant further action by the
Department at this time.
VI. SUMMARY of DEFICIENCIES
The Department has identified the following deficiency.
1. Deficiency of 310 CMR 40.543(1)(c): The level of detail in Phase I - Limited Site
Investigation activities and Phase I Rep,n t did not reflect the nature and complexity of
the disposal site.
VII. ACTIONS to be TAKEN to CORRECT DEFICIENCY
Employ a LSP to conduct further response actions and within 180 days submit either of the following:
(a) a Response Action Outcome (RAO) Statement that complies with the
requirements of the MCP; or
(b) a Tier Classification Submittal pursuant to 310 CMR 40.0500,and,if applicable,
a Tier I permit application.
VIII. COMMENTS
The list below contains observations from the Department on the actions that were audited. These
rbeervations do not constitute deficiencies or violations and do not require a response to the Department
°rom you. Instead, they are included to help you and your LSP better understand the Department's
nterpretation of M.G.L. c. 21E, 310 CMR 40.0000, and other requirements applicable to the site.
1. The letter from CCRT dated July 23, 1996 did not include the certification required by
310 CMR 40.0009.
IX. CONCLUSIONS and RECOMMENDATIONS
The Phase I Report is not commensurate with the nature and complexity of the disposal site. The NFA
recommendation is not adequately supported. Additional actions should be taken to assess the
ontsmination and evaluate the risk of harm to health,safety,public welfare and the environment. The
Department, pursuant to 310 CMR 40.0610(4)(b),should disapprove the NFA recommendation.
ATTACHMENT B
CERTIFICATION OF SUBMITTAL(310 CUR 40.0009)
This certification must be included with your response to any request for further
information or documentation
I attest under the pains and penalties of perjury, (i) that I have personally examined and am
familiar with the information contained in this submittal, including any and all documents
accompanying this certification, and that, based on my inquiry of those individuals immediately
responsible for obtaining the information, the material information contained herein is, to the
best of my knowledge and belief, true, accurate and complete. I am aware that there are
significant penalties, including, but not limited to, possible fines and imprisonment, foryyilfully
submitting false, inaccurate or incomplete information.
Name (Print):
Position or title:
Signature:
Date:
B. Hatch
Consulting Engineer
Road,Monson,Massachusetts 01057 (413-267-3696)
August 4, 1997
Bureau of Waste Site Cleanup
Western Regional Office
Department of Environmental Protection
436 Dwight Street
Springfield, MA 01103
Re: Northampton 1-0685
Central Chambers Realty Trust
16 Center Street
Gentlemen:
In accordance with 310 CMR 40.0169(2),this is my notification to the Department
that my engagement in connection with the Department's site identified as Northampton 1-
0685 has been terminated effective August 4, 1997.
Sincerely,
Paul B. Hatch,PE, LSP
cc: Office of the Mayor, City of Northampton
Board of Health, City of Northampton
Carol Heon
15322501
[F WELD
'AUL CELLUCCI
nor
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
WESTERN REGIONAL OFFICE
Marcl 7,
Central Chambers Realty Trust
16 Center Street
Northampton, MA 01060
ATTN: Ms. Carol A Heon, Manager
RE: NORTHAMPTON--1-0685
16 Center Street
MODIFICATION of INTERIM
DEADLINE, 16 Center Street
310 CMR 40 0000 and M.G.L. c. 21E
Dear Ms. Heon:
TRUDY CORE
Secretary
DAVID R.STEERS
Commissioner
The Department of Environmental Protection, Bureau of Waste Site Cleanup, (the Department), has
received your request to modify the Interim Deadline set forth in the Department's Notice of Audit
Findings letter dated December 27, 1996 to Central Chambers Realty Trust. This request was dated
February 18, 1997.
The Department is of the opinion that the requested modification to the Interim Deadline previously
established is reasonable. Therefore, pursuant to 310 CMR 40.0167 the Department modifies the
Interim Deadline of July 6, 1997 to October 30, 1997 for the submittal of either (I) a Response
Action Outcome (RAO) Statement that complies with the requirements of the Massachusetts
Contingency Plan; or (2) a Tier Classification Submittal pursuant to 310 CMR 40.0500, and, if
applicable, a Tier I permit application.
If you have any questions regarding this letter, please contact Ms. Debra Kelley-Dominick at (413)
784 - 1100 extension 222.
Sincerely,
Debra J. Kelley-Dominick
Environmental Analyst
ght Street • Springfield, Massachusetts 01103 • FAX(413)7841149 • TDD(413)7466620 • Telephone(413)784-1100
(20%Port Consumer)
1 - 0685
Catherine G. Went
Section Chief
Audits/Site Management
Bureau of Waste Site Cleanup
CGW/DED/dkd/
cc: Audit File, BWSC, WERO
Site File BWSC, WERO
Stephen Winslow, Audit Coordinator
Honorable Mary L. Ford, Mayor, City of Northampton
City of Northampton Health Department
'AUL CELLUCCI
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
WESTERN REGIONAL OFFICE
July 22, 1998
Central Chambers Realty Trust
16 Center Street
Northampton, MA 01060
ATTN: Ms.Carol Heon, Manager
Re: NORTHAMPTON, #1-0685
NO FURTHER ACTION
RECOMMENDATION
16 Center Street
Dear Ms. Heon:
TRUDY COXE
Secretary
DAVID B.STRUIIS
Commissioner
Dn December 27, 1996.the Department of Environmental Protection, Bureau of Waste Site Cleanup,
The Department), issued a Notice of Audit Findings(NOAF)that identified deficiencies in response
actions at the above-referenced site. The NOAF required that you take certain steps to correct the
dentified deficiencies. The Department,on May 20, 1998, received a copy of a Release Abatement
Measure Completion Report which included a Response Action Outcome. The report was prepared and
submitted on your behalf by Environmental Compliance Services, Inc.
The above-referenced report contains information indicating that steps required by the Department have
>een taken.
fhe Department has reviewed this information and now considers the audit of the Phase I Report and the
no further action" recommendation which was initiated with the Notice of Audit dated December 4.
1996,to be complete.
f you have any questions regarding this letter, please call Ms. Debra Kelley-Dominick at(413) 784-1100
extension 222.
Sincerely,
Debra J. Kelley-Dominick
Environmental Analyst
This information is available in alternate format by calling our ADA Coordinator at(617)574-6872.
436 Dwight Street • Springfield,Massachusetts 01103 • FAX(413)784-1149 • TOD(413)746-6630 • Telephone 1413)784-1100
0 Printed on Recycled Paper(20%Post Consumer)
1 -0685 2
Catherine G. Wanat
Section Chief
Audits/Site Management
Bureau of Waste Site Cleanup
CGW/DKD/dkd/
cc: Audit File, BWSC, WERO
Site file, BWSC, WERO
Maria Pinaud, BWSC, Boston
Honorable Mary L. Ford, Mayor,City of Northampton
City of Northampton Health Department
Environmental Compliance Services, Inc. Al IN: Mr. Kevin Sheehan, LSP-of-Record
Data Entry