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25-31 Letters 1995-2001 William F.Weld Grivernor Argeo Paul Cellucci 1.Gwemor Commonweaffh of Massachusetts Executive Office of Environmental Affairs Department of Environmental Protection Western Regional Office Mr. George M. Childs 14 Kingsley Avenue Haydenville, MA 01039 Dear Mr. Childs : Trudy Core Secretary David B.Struhs Commissioner November 20, 1995 Re: Northampton - Childs Property 25-31 State Street RTN: 1-11134 INTERIM DEADLINES FAILURE TO NOTIFY NOTICE OF RESPONSIBILITY M.G.L. c. 21E 310 CMR 40 . 0000 On November 10, 1995 the Department of Environmental Protection (the "Department" ) received an assessment report, entitled Phase II Environmental Site Assessment (the "report" ) , dated March 14, 1994 from the Federal Deposit Insurance Corporation (FDIC) with regard to the environmental conditions which exist at the site. This assessment, which was performed by ATC/Con-Test, Inc . , also included a groundwater sampling update report, dated March 8, 1995 . The analytical results of groundwater samples taken during the February 21, 1995 sampling round, indicated that a reportable release condition, which required notification to the Department within 120 days of obtaining knowledge of such condition, continues to exist at the site. As a result, the Department wishes to ensure that you (as used in this notice, "you" refers to Mr. George M. Childs) are aware of your rights and responsibilities under the Massachusetts Oil and Hazardous Material Release Prevention and Response Act, M.G.L. c. 21E, and the Massachusetts Contingency Plan (MCP) , 310 CMR 40 . 0000 . The information contained in the FDIC submittal indicates that the above-referenced property has been subject to a release of total petroleum hydrocarbons (TPH) , 1, 2 dichloroethane, benzene, and Zinc in excess of the applicable reportable concentrations (RCs) . Based on this information, the Department has reason to believe that the property, or portions thereof, is a disposal site which requires a response action. The cleanup of disposal sites is governed by M.G.L. c. 21E and the MCP. 136 Dwight Street • Springfield, Massachusetts 01103 • FAx(413)784-1149 • Telephone(413)784-1100 NOTICE OF RESPONSIBILITY RTN: #1-11134 Childs Property Northampton, MA 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 governed by laws which establish the time allowed for bringing litigation. The Department encourages you to take any action necessary to protect any such claims you may have against third parties . ACTIONS UNDERTAKEN TO DATE AT THE S.TE An initial subsurface investigation has been performed at the site as well as subsequent groundwater sampling rounds, the results of which indicate that a historical release of oil and/or hazardous material has occurred. NECESSARY RESPONSE ACTIONS AND APPLICABLE DEADLINES Information available to the Department indicates that you obtained knowledge of the contamination on the property on April 18, 1995 . This information includes a copy of certified letter from FDIC to you, dated April 11, 1995, which was signed for by Bernice A. Childs on April 18, 1995, acknowledging receipt of the letter. The FDIC informed you of the results of the subsurface assessment performed by ETC/Con-Test, which indicated that a gotifiable release condition had been identified at the site, and that notification of the Department was required. However, the Department and was not informed of the FDIC report was submitted to almost 3 months after actual Department was required. never received notification from you, contamination at the site until the the Department on November 10, 1995, notification, August 16, 1995 , to the Unless otherwise provided by the Department, responsible parties have one year from the initial date notice of a release or :hreat of release is provided to the Department pursuant to 310 CMR 10 . 0300 or from the date the Department issues a Notice of 2esponsibility (NOR) , whichever occurs earlier, to file with the Department one of the following submittals : (1) a completed Tier nlassification Submittal; or (2) a Response Action Outcome (RAO) tatement . With this NOR, the Department hereby establishes the 3eadline for the submission of the remaining documentation for this iisposal site as August 16, 1996, based upon the date that the Department should have been notified. )TICE OF RESPONSIBILITY CN: #1-11134 iilds Property )rthampton, MA Page 3 Furthermore, in accordance with 310 CMR 40. 0333 (2) and 310 CMR ) . 0336 (1) , the Department now requires you to submit a completed =lease Notification Form (attached) within 60 calendar days of the ate of receipt of this Notice of Responsibility (NOR) . The apartment may also issue to you a Notice of Noncompliance for ailure to notify the Department within the proper time-frame. In addition, the MCP requires responsible parties and any [her person undertaking response actions at a disposal site to erform Immediate Response Actions in response to sudden releases, Eminent Hazards and Conditions of Substantial Release Migration. .ich persons must continue to evaluate the need for Immediate =_sponse Actions and notify the Department immediately if such a eed exists . No disposal site will be deemed to have had all the necessary nd required response actions taken for it unless and until all ubstantial hazards presented by the release and/or threat of elease have been eliminated and a level of no significant risk xists or has been achieved in compliance with M.G.L. c. 21E and he MCP. The MCP requires persons undertaking response actions at a isposal site to submit to the Department a Response Action Outcome tatement prepared by a Licensed Site Professional upon determining hat a level cf no significant risk already exists or has been chieved at the disposal site . PROCEDURES TO FOLLOW TO UNDERTAKE RESPONSE ACTIONS The Department encourages parties having liability under .G.L. c . 21E to take prompt action in response to releases and hreats of release of oil and hazardous materials . By taking rompt action, liable parties may significantly lower cleanup costs nd avoid the imposition of, or reduce the amount of, certain ermit and/or annual compliance assurance fees payable under 310 MR 4 . 0000 (e.g. , no annual compliance assurance fee is due for RAO tatements submitted to the Department within 120 days of the nitial date of release notification) . You must employ or engage a Licensed Site Professional (LSP) o manage, supervise or actually perform all response actions which -ou intend to undertake at this disposal site . You may obtain a .ist of the names and addresses of Licensed Site Professionals by )ontacting the Board of Registration of Hazardous Waste Site 'leanup Professionals by telephone at (617) 556-1145 or in person )r by mail at One Winter Street, 6th Floor, Boston, Massachusetts )2108 . CE OF RESPONSIBILITY #1-11134 ds Property hampton, MA Page 4 In the event that an imminent hazard is identified and/or tate response actions (IRAs) are necessary, the Department require an IRA plan be submitted to the Department within 60 of this determination. Be advised that additional submittals necessary with respect to all approved IRAs . If you have any questions relative to this matter, you should :act Steve Cooperman of the Regional Emergency Response/ ification Section at the above letterhead address or call (413) -1100 ext . 314 . All future communications regarding this dition must reference the Release Tracking Number (RTN) in the ject block of this document . ISLC/s1c /kml cooperm\letters\11134.NOR Sincerely Yours, Alan Weinberg Regional Engineer Bureau of Waste Site Cleanup . Northampton Fire Department Board of Health Mayor' s Office ATC/Con-Test, Inc. attn: Tim O'Brien FDIC, 101 East River Drive, East Hartford, CT 06128 attn: Alan R. Koppel, Environmental Coordinator Certified #Z 082 548 319 tachmentso F Summary of Liability underB Instructions M.G.L.M.G.L c . 21E LUCCI COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVERONMEENTAL AAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION WESTERN REGIONAL OFFICE gorge M. Childs ngsley Avenue nville, MA 01039 February 21, 1996 TRUDY COXE Secretary DAVID B.STRUMS Commissioner Re: Northampton - Childs Property 25-31 State Street RTN: 1-11134 NON #: NON-NE-96-3008 NOTICE OF NONCOMPLIANCE M.G.L. c. 21E 310 CMR 40 .0000 IS AN IMPORTANT NO ITRIS NOTICE ADEQUATE ACTION IN COULD RESULT IN SERIOUS LEGAL CONSEQUENCES Mr. Childs: Department records indicate that response actions at the ve-referenced site are not in compliance with one or more laws, ulations, orders, licenses, permits, or approvals Department . Attached hereto is therrequirements violated,1) each the action erred to above, (2) and (4) the deadline for Department now wants you to take, :ing such action. the prescribed If you fail to come into compliance by adline (s) , or if you otherwise fail to comply in the future with quirements app licable to you, you could be subject to legal rosecution, court- pose. Such action could civil it administrative penalties assessed court- posed eivil penalties, may be assessed the Department . A civil that you remain pout lof compliance with ie every day from now on that y le requirements described in this Notice of Noncompliance . t Street • Springfield, Massachusetts 01103 • FAX(413)784-1149 • TDD(413)746-6620 • Telephone(413)164-1100 `= pnnted on Recycled Paper(20%Post Consume) -- OF NONCOMPLIANCE NON-WE-96-3008 'lease be advised that, in ceewithe310 CMR 40 . 0333 (2) LO CMR the Dep artment a ted Release ease Notification Form (attached) within 60 calendar of the date Ne er 20, 9 its Notice you signed for and received u, dated November 20 , 1995, vember 21, 1995 . Also, be advised that the 120-day deadline has passed to t a Response Action Outcome (RAO) Statement without the RAO Therefore, a fee of $750 .00 must accompany any RAO submitted .e Department on or before August 16, 1996 . You must submit a Classification for your site should you be unable to reach deadline. If you fail to perform an >r rer to the August by August 16, 1996 deadline, you may be required actions l the Augu to $2600 . 00 in accordance M.G.L. annual compliance fee of up M. .L c.21E and the Massachusetts Contingency Plan (the " ) , 310 CMR 40 .0000 . Please contact Steve Cooperman have any West ronRegional Office 413) 784-1100 ext.314 if you Sincerely, Page 2 Alan Weinberg Regional Engine-r Bureau of Waste Site Cleanup /SLC/Slc /kml ooperm\letters\11134.non Northampton Fire Dep artment Board of Health Mayor' s Office ATC/Con-Test, Inc. attn: Tim O' Brien CT 06128 FDIC, 101 East River. Drive, East Hartford, attn: Alan R. Koppel, Environmental Coordinator James Colman, Assistant Commissioner/BWSC/Boston Larissa Drennan, BWSC/Boston Bob Donovan, BWSC/ER/Boston BWSC\WERO Enforceme1t5File Steve Ellis (2) p Certified #Z 082 549 345 NOTICE OF NONCOMPLIANCE SUMMARY (IES IN NONCOMPLIANCE :hilds Property :ON OF NONCOMPLIANCE 25-31 State Street, Northampton, MA OF NONCE August 16, 1995 for failure to notify the Department of a which se or threat of release of obtaining knowledge of such grelease/t reat on tof release.120 January 20, 1996 for the submission of a Release Notification (RNF) . 2IPTION OF RE.UIREMENT S 310 CMR 40 . 00315 requires that any person who obtains ledge of a release specified in 310 CMR 40 . 0315 (1) - (3) notify Department not more oree than the -hund eed and twenty (120) days r obtaining 310 CMR 40 .0336 requires that a completed ReleasenNoG0ification I (attached) be submitted to the Department you signed for and of the date of rece1 1995,t O according to Department files . rived on November 21, MIPTION OF ACT OR OMISSION CONSTITUTING NONCOMPLIANCE Failure to notify the Department of a re 6 e specified in 310 40 . 0315 and 310 CMR 40 . 0332 (3) by August the Failure to submit a Release Notification Form to ,artment within sixty (60) days of the interim accordance t by adline Department, as described in 310 CMR 40 .0371, 1 CMR 40 . 0336 , 310 CMR 40 . 0332 (3) , and 310 CMR 40 . 0167 . iCRIPTION AND DEADLINE S OF ACTION S TO BE TAKEN 28, 1996 , submit to the Department a On t before regarding your failure to notify the Department atement of facts deg adding y and submit to the thin the 120 day notification time-frame, re area in accordance uwibo 0 CMR a Release The i D pa tment prepared requires Y :0 CMR 40 . 0371. period that you :knowledge in writing within the same 14 day p stead to comply with the notification regulations in the future . NOT COMPLIED WITH -3- ' bx ax 21, 1996 Department of Environmental Protection By: Al Weinberg Regional Engine Bureau of Waste Site Cleanup COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVDRONMENTAL PROTECTION WESTERN REGIONAL OFFICE LUCCI neorpnrated Street apton, MA 01060 Mr. Edward Cavallari March 31, 1997 nn. Northamcto, - RTN 1-0817, Phase I & NRS Serio's Market 65 State Street NOTICE OF AUDIT FINDINGS TRUDY CORE Secretary DAVID R.STRUES Commissioner r. Cavallari: On March 4, 1997 you were notified that the Massachusetts of oil Environmental Ion had begun to audit cleanup actions conducted in response release Department's l tit. a described above. This Notice informs you of the results of the Depart :OLATIONS OR DEFICIENCIES WERE FOUND The Department finds that the audited actions comply with applicable requirements and that lotion submitted to the Department adequately documents those Scons Tbe� necessary. anal actions regarding the Phase I report and Numerical Ranking reshee are ne eel during site Memorandum (Attachment A) describes activities Department personnel and summarizes relevant site information. LTIONAL COMMENTS Finally, in Section VI of the Site Memorandum, the Department has provided additional your Nations and recommendations related to the implementation of requirements Site prefto Professional ins. The Department provides those comments to assist you and your Plan.Licensed Sit comments o al tter understand our interpretation of the Massachusetts Contingency an to them at e time. constitute violations or deficiencies. Therefore, you do not need to respond se note, however, that additional investigations within the tank grave area will be needed prior abmitting a Response Action Outcome Statement for this site. ENSED SITE PROFESSIONAL A copy of this Notice has been sent to Mr. Evan Johnson, the Licensed Site Professional {P) of record for your disposal site. Street • Springfield, Massachusetts 0110 Post FAX(413)784-1149 • TDD(413)746-6620 • Telephone(413)784-1100 puruted dit Findings IONS Ire Department relies upon the accuracy of the information reviewed during the audit, information submitted during the course of the audit, to make these findings. These do not: (1) apply to actions or other aspects of the site that were not reviewed inn h lute audit, ads future audits of past, current, or future actions at the site, (3) in any way tom any liability, obligation, action or penalty ender M.G.L. c. 21 E, 310 CMR 40 0000. or :• law, regulation, or requirement, or (4) limit the Department's authority to���or age, mire any Responsible Party or Potentially Responsible Party to perform, l to protect health, safety, public ed by M.G.L. c. 21E which the Department deems necessary P or the environment. If you have any questions regarding this Notice or any requirements contained in it please Edward Weagle at the letterhead address or by calling(413) 784-1100 x221. Please e the Release Tracking Number in any correspondence regarding the site. Sincerely, Edward J. ale Environmental Analyst 4-o Catherine G.Wanat Section Chief Audits/Site Management Bureau of Waste Site Cleanup ±ments: A. Site Memorandum (5 pages) City of Northampton Mayor's office Northampton Board of Health i Westfield, MA 01085, Tighe &Bond, Westfield Executive Park, 53SSouthampton mod' Attn: Mr. Evan Johnson, MA 01060 Attorney John C. Serio, 56 Main Street, Northampton, WERO Audit File Stephen Winslow, DEP Audit Coordinator Attachment A AUDIT MEMORANDUM !7S AUDITED included a review of the following actions taken under Release Tracking Number (RTN) the Serio's Market dispose) site located at 65 State Street in Northampton: Phase I Report Transition Provisions A Tier U Classification Submittal re-referenced LSP Opinions were prepared by Evan T. Johnson, the ISPof-record for RTN ET ACTIVITIES it consisted of the following activities: • A Notice of Audit dated March 4, 1997, which included a written Request for Information. • A Site Inspection on March 20, 1997. .`E SUMMARY operty located at 66 State Street consists of approximately 1 acre of land located in a mixed :mini/residential area of Northampton. The property is currently owned by Serio's orated and is occupied by a grocery stoic and pharmacy. Abutters to the site include: tc the and east, multi-family residential buildings; to the south across Center Street, offices; and to et across State Street, commercial properties. The property has bee occupied by the current ig since 1950. Site history prior to 1950 was not reported. me 5, 1990, a 1,000 gallon fuel oil underground storage tank (UST) was excavated and red from the site. At the time of the removal, the tank was believed to be approximately 40 old, and reportedly had not been used since 1980. Upon removal, numerous holes through the and bottom of the tank were observed, ranging in size from one-quarter to three-quarters of an in diameter. A total of five cubic yards of soil was removed and disposed off-property. vation was limited to the north and west due to the presence of the of building. Materials d at 10 feet reportedly due to concern for the structural integrity of the building. baler and entered in the excavation consisted of approximatelyt7e base of the e1111 nn on (9 to 10 feet ;re, overlying 2 feet of interbedded silt and clay. At ✓ grade), a sand unit was encountered. Groundwater was not encountered in the excavation, the excavation was back-filled with clean soil after approval from the Department. ing excavation activities, several soil samples were collected, screened for volatile organic pounds (VOCs) using a photoionization detector (PID) and Jar-headspace methods, and analyzed total petroleum hydrocarbons (TPf) via EPA Method 418.1. Results are as follows: andum y RTN 1-0817 maple I.D. S-3 West wall at bottom, 7-8 fbg S-4 Base of excavation 9-10 fbg 151.1 195.6 North, East, &West wall composite Not Analyzed 5-Sample Composite 21,000 mg/kg 19,000 mg/kg 30,000 mg/kg in the results of this investigation, the site was listed by the Department as a Location to be gated. cember 20, 1990, three soil borings, completed as monitoring wells, were advanced at the site. was placed 56 feet to the west southwest of the UST excavation, in an apparent upgradient n. MW-2 and MW-3 were placed 20 feet to the southeast and 35 feet to the east, respectively UST excavation, in the apparent downgradient direction. Subsurface materials encountered the advancement of MW-2 and MW-3 consisted of approximately. 7 feet of sandy fill overlying r of clay overlying fine sands from 10 feet below grade to a depth of approximately ens encountered at grade, overlying interbedded sands and silts. Refusal (glacial :t below grade. MW-1 was terminated at 24 feet below grade in very fine sand and silt, and :ncountered a clay layer at the 5 to 7 foot interval. During screened for VOCs via jar-headspace edboace spoon samples were collected at 5 foot intervals, ce ened for VOCs. The sample collected ods. One soil sample contained elevated VOC headspace at 15 to 17 feet below grade exhibited a headspace concentration of 1.1 ppmv, however, terentiated drill cuttings (depth unknown) from this boring exhibited a headspace of 8.0 ppmv, ating the presence of contamination. Quantitative soil analyses from the drilling program were )erformed. December 27, 1990, the three monitoring wells were gauged to determine depth to groundwater. andwater was encountered at 13.2 feet below grade and 29.4 andn32.3ofeet flovbelow east LW-2 and MW-3, respectively. Using these data, groundwater n average gradient of 0.23 ft/ft. Groundwater samples were collected from et�mnlll eftr VOC o a of lyses via EPA Methods 8010 and 8020. Toluene was the only VOC detected, samples Lions o 2 9 and 1.3µgil for wells MW-1, MW-2 and MW-3, respectively. e not � µyd o not analyzed for TPH. The results investigations were 12, 1991.p�n�to the Department to hese I report prepared by random n, RTN 1-0817 30, 1996, Serio's Incorporated provided the Department with an ISP Evaluation Opinion 11 classification report. The report contained a copy of the February 12, 1991 Phase I 3pended to the transition opinion and NRS scoresheet. The LSP Evaluation Opinion and lassificatioa report did not provide�new information above and beyond what had ly been submitted to the Department of Phase I and NRS scoresheet ase I report for this site was prepared and submitted to the Department in March 1991. Soil /monitoring wells were not installed in the tank grave, where the most elevated levels of soil approxi r coy 25 eetifn would grave.expected.As such,The nearest soil boring/monitoring well was approximately 25 feet from the grave. Ae s these is a lack of information characterizing th of the soil contamination in the tank grave, whether the soil contamination extends all the the groundwater, and whether any localized groundwater contamination is present directly the tank grave. In addition, the groundwater analyses conducted in 1991 did not include TPH rget analyte, even though 97,000 mg/kg of TPH was found is a soil sample taken from the of the tank excavation. At this disposal site, the #2 fuel oil contamination would be better terized by analyzing for TPH in groundwater, due to the very low amounts of VOCs in fuel high levels of TPH in soil, and the suspected age of the release. Number 2 fuel oil is also to contain certain polyaromatic hydrocarbons (PAIIs), including naphthalene, 2-methyl- balene, and phenanthrene. However, the Phase I report does not present any information ling the presence/absence of PAHs at the disposal site, or any justification as to why Peen the not be present at concentrations of concern in soil and g un wa�Rce inosummma y, given groundwater if groundwater quality information from the tank grave f he water sea for TPH and PAHs, the Phase I report does not adequately characterize potential order its to groundwater. These data gaps indicate that future investigations are necessary the perfodrmance standards set forth in the 1993 MCP (as amended). achieved in accordance equately NRS scoresheet filed for the site correctly classifies this location as a Tier II disposal site. ever, there is one portion of the scoresheet which is incorrectly scored. This incorrect score led ,e assignment of a total NRS score higher than what is appropriate. Specifically, in Section V., ogical Population, a score of 0 was assigned to Subsection VA, Environmental Resource Areas, a score of 20 points was assigned to Subsection V.B., Environmental Toxicity Score. However, CMR 40.1508 (b) states in Part "Environmental Toxicity Score, Subsection V.B shall be scored if unamended score assigned to [Environmental Resource Areas) Subsection V.A is greater than or il to 30." As indicated above, the score assigned by the ISP in Subsection VA was not greater 1 or equal to 30. Therefore, it is not necessary or appropriate to assign a score in Subsection . The inclusion of this correction to the NBS scoresheet for this site results in a lower total score .23, verses the score of 143 assigned by the ally, in Subsection IV.B., Aquifers, a score of 15 was assigned indicating that the site is located a Potentially Productive Aquifer. This subsection was correctly scored when the scoresheet was sndum i, RTN 1-0817 i in July/August 1996. However, for future reference, revisions to the regulations which ffective on September 9, 1996, indicate that the site is no longer located in a Potentially re Aquifer. section sday, March 20, 1997 at 6:30 am, Thomas Potter and the writer Evan Johnson,Edward a- i and Attorney John Serio representing Serio's Incorporated, and referred o as n, site". It frith Tighe &Eond, at the above-referenced property, Ad and cloudy morning with temperatures in the upper 20s to low 30s. The Site Inspection .ducted for the purpose of documenting site conditions in conjunction with the Department's 'certain response actions performed at the site. pection began with a general overview of the site and surrounding properties The entire the property is covered by pavement or the building. The surrounding area is very densely ed. An apparent residential building is located in close proximity to the downgradient line. The locations the three e s road v ere secure, and the wells all appeared to be��l , however, of the wells significant VOC groundwater contamination ., as previous analytical data had not indicated a signs n. To date, groundwater has not yet been tested for TPH. oup next discussed the possible options available in order to address the remaining nination and bring the site to closure.determiner i dieate of cat it would have pn�mbeneficial duct soil borings in the tank grave tting the Tier II classification, as significant biodegradation of the oil may have occurred in the ars since soil quality was last determined. Attorney Serio expressed reservations that sting additional environmental investigations would be costly, unproductive and unnecessary. •potential options that were discussed included waiting for the currently proposed revisions to igulations, and the potential applicability of the proposed Class A-4 RAO, if adopted. group also discussed the potential timing of the Department's audit m the letter. The Inse to the Department's Request for Information was also provide action concluded at approximately 9:05 am. iUMMARY OF VIOLATIONS ing this audit the Department did not identify any violations in the actions audited. ;UNWARY OF DEFICIENCIES ing this audit, the Department did not identify any deficiencies in the actions audited. )randum rn, RTN 1-0817 NTIONAL COMMENTS ts. The list below contains observations and recommendations from the renton the Comments. do NOT sent on the ac4ons that were audited- The abservations and rernmm',ndstmns at this ite deficiencies or violations and require no response to the Department nstead, they are included to help you and your LSP better understand the Department's station of M.G.L. c. 21E, 310 CMR 40.0000, and other requirements applicable to the site. 1. During the review of the activities conducted that the site, the Department has taken note that the depth to which the contamination extends in the underground storage tank grave has not been determined. As such, it is possible that the oil released in the area of the former underground storage tank, may have migrated further into the ground then 10 feet below grade, potentially to the groundwater table. Please note the MCP requires that the full extent of the contamination at the disposal site be determined. The Department has also noted that the presence or absence of need to be a hydrocarbons ee addressed by performing at mi g site additional investigations within the tank grave need to or order to aede adequately Plyfsuppog Stet, in nt f r toe s . Th Department subsequent Response Action that the use of thOutcome TPH Statement pr achh site. The le Pert be considered by your MP analysis approach, Extractable Petroleum Hydrocarbons, when developing an appropriate sampling plan. 2. An inappropriate score was assigned to Subsection V.B. of the NRS scoresheet, as detailed on page 3 of this Site Memorandum. .LUCCI COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION WESTERN REGIONAL OFFICE TRUDY COXE Secretary DAVID B. STRUHS Commissioner October 16, 1998 URGENT LEGAL MATTER: PROMPT ACTION NECESSARY [FIED MAIL RN RECEIPT REQUESTED treet Twenty-Five, Inc. rley Sacks mbull Road impton,Massachusetts 01060 RE: Northampton, 1-11134 25-31 State Street M.G.L. Ch 21E NOTICE OF RESPONSIBILITY M.G.L. c. 21E,310 CMR 40 0000 Sir or Madam: ng a routine site review process,the Department identified you as a Potentially Responsible for the above Site. In light of this action,the Department wishes to ensure that you(as used is notice, "you" refers to State Street Twenty-Five,Inc.)are aware of your rights and ion and onsibilities under the Massachusetts Oil and Hazardous Material Release 3 entCMR d0.0000. Donse Act,M.G.L. c.21E, and the Massachusetts Contingency Plan(MCP), irmation contained in the Department files indicates that the above-referenced property has been ject to a release of oil and/or hazardous materials in unknown quantities or in excess of the licable reportable quantity or reportable concentration. Based on this information,the )artment has reason to believe that the property, or portions thereof,is a disposal site which uires a response action. The cleanup of disposal sites is governed by M.G.L. c. 21 E and the :P. This information is available in alternate format by calling our ADA Coordinator at(617)511680:. 436 Dwight Street•Springfield Massachusetts 01103•Printed(413)3)7841149•TDD(413)746-6640•Telephone(413)784-1100 on nation obtained from the City of Northampton and Hampshire County Registry of Deeds that you are a party with potential liability for response action costs and damages under ;. 21E, § 5. The attached summary is intended to provide you with information about ander Chapter 21E to assist you in deciding what actions to take in response to this notice. uld be aware that you may have claims against third parties for damages,including claims ibution or reimbursement for the costs of cleanup. Such claims do not exist indefinitely bringing;ovemed by laws which establish the time Department ges you to take any action necessary to protect any such clai s you may have against third ACTIONS UNDERTAKEN TO DATE AT THE SITE ation on file with the Department indicates that the following actions have been performed to this disposal site: Jotification was made to the Department in November 1995 stating that oncentrations of oil or hazardous materials in the soil and groundwater exceeded the applicable reporting requirements. NECESSARY RESPONSE ACTIONS AND APPLICABLE DEADLINES sposal site will be deemed to have had all the necessary and required response actions taken unless liminated andla all level norsignifrcanstP risk presented boor the has been achieved neco compliance w have h L_ c. 21E and the MCP. vICP requires persons undertaking response actions at a disposal site to submit to the itment a Response Action Outcome Statement prepared by a Licensed Site Professional upon mining that a level of no significant risk already exists or has been achieved at the disposal Idition,the MCP requires responsible parties and any other person undertaking response ins at a disposal site to perform Immediate Response Actions in response to sudden releases, tinent Hazards and Conditions of Substantial Release Migration. Such persons must continue to nate the need for Immediate Response Actions and notify the Department immediately if such a d exists. PROCEDURES TO FOLLOW TO UNDERTAKE RESPONSE ACTIONS By taking prompt action, Department encourages patties having liability under M.G.L. c.21E to take prompt action in ponse to releases and threats of release of oil and hazardous materials. B takin p P ble parties may significantly lower cleanup costs and avoid the imposition of, or reduce the count of,certain permit and/or annual compliance assurance fees payable under 310 CMR 4.00. en must employ or engage a Licensed Site Professional to manage,supervise or actually perform 1 response actions which you intend to undertake at this disposal site. You may obtain a list of the Imes and addresses of Licensed Site Professionals by contacting the Board of Registration of is Waste Site Cleanup Professionals by telephone at(617) 556-1145 or in person or by ne Winter Street,6th Floor,Boston,Massachusetts 02108. wenty-one(21)days from the date of this letter,you must provide the Department ler a Tier Classification Form or a Response Action Outcome as required by 310 1.0000. If you fail to provide a response to this notice as requested,or fail to ke the necessary response actions in accordance with the MCP,the Department may the necessary response actions and take appropriate legal action against you. If any e actions have been taken since your association with this disposal site,please send the rent any information that is available. ave any further questions,please contact Stephen Ball at the letterhead address or by ne at ag this disposal site should reference Release Tracking correspondence or 1-11134. communications Alan Weinberg Deputy Regional Director Bureau of Waste Site Cleanup NOR died Mail# P 348 006 164,return receipt requested. osure Northampton,Board of Health Northampton,Chief Municipal Officer Site files,BWSC,WERO LUCCI COMMONWEALTH OF MASSACHUSE 1 IS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION WESTERN REGIONAL OFFICE ATTACHMENT TRUDY COXE Secretary DAVID B. STRUMS Commissioner SUMMARY OF LIABILITY UNDER CHAPTER 21E ed in the Notice of Responsibility accompanying this summary,the Department has reason ;ve that you are a Potentially Responsible Party("PRP")with potential liability under . c. 21E, section 5,for response action costs and damages to natural resources caused by the 11 and/or hin one or more The Department categories of perssons made poottentiallyshab liable ;tion 5(a): any current owner or operator of a site from or at which there is or has been a release or threat of release of oil and(or hazardous material: any person who owned or operated a site at the time hazardous material was stored or disposed of: any person who arranged for the transport,disposal,storage or treatment of hazardous material to or at a site: any person who transported hazardous material to a transport,disposal,storage or treatment site from which there is or has been a release or threat of release of such material: and any person who otherwise caused or is legally responsible for a release or threat of release of oil or hazardous material at a site. purposes of the MCP,you are considered a Responsible Party("RP")with actual liability under Ipter 21E if you fall within one of these categories unless you(1) are entitled to a defense under .ion 5 or other applicable law, and(2)have reasonably incurred cleanup costs in an amount al to or greater than any applicable cap on liability under subsection 5(d). is liability is "strict,' meaning it is not based on fault,but solely on your status as an owner, :rator, generator,transporter or disposer. It is also joint and several,meaning that each person This information iA 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)746-6620•Telephone(413)784-1100 0 Printed on Recycled Paper within one of these categories may be held liable for all response action costs incurred at regardless of the existence of any other liable parties. 5 provides a few narrowly drawn defenses to liability,including odefense f or e�ployand ;caused with an whom of God,an has a contractual relationship(see subsection 5(c));a defense person with whom ttiaparry Lin owners of residential property at which the owner maintains a permanent residence(see on 5(h));and a defense for certain public utilities and agencies of the Commonwealth wn a right-of-way that is a site(see subsection 5(j)). ty voluntarily undertake response actions under the MCP without having your liability under r 21E formally adjudicated by the Department. If you do not take the necessary response ,or fail to perform them in an appropriate and timely manner, the Department is authorized pter 21E to perform the necessary ing the necessary response actions,you can avoid liability for response action costs incurred Department in performing these actions. If you are an RP and you fail to perform necessary se actions at the site,you may be held liable for up to three(3)times all response action costs ed by the Department and sanctions may be imposed on you for failure to perform response s required by the MCP. inse action costs include,without limitation. the cost of direct hours spent by Department ryees arranging for response actions or overseeing work performed by persons other than the rtment or its contractors.expenses incurred by the Department in support of those direct hours, ayr os to the Department's y sst CMR !00: Cost Recov ey). e Department ma also assess on costs incurred at the of re percent(12%),compounded annually. liability to the Commonwealth under Chapter 21E constitutes a debt to the Commonwealth. ecure payment of this debt,the Department may place liens on all of your property in the :lose onthe e under ens or the Attorney General mayobring this action against Commonwealth may ddition to your potential liability for response action costs and damages to natural resources ;ed by the release,civil and criminal liability may also be imposed by a court of competent sdiction under M.G.L.c. 21E, 1A, se t 11,ona16, for each violation openalties hapter be assessed MCP or Department under M.G.L. c. 21 A, order,permit or approval issued thereunder. rou are an RP and you have reason to believe that your performance of the necessary response ions is beyond your technical, financial or legal ability,you should promptly notify the apartment in writing of your inability in accordance with Chapter 21E, subsection 5(e),and 310 AR 40.0172. If you assert and demonstrate in compliance therewith ih that a p rfoh aail g or p ying r such response action is beyond your ability,subsection 5(e)pc Y an action by the Commonwealth for recovery of two to three times the Department's response Lion costs and 310 CMR 40.0172 provides you with a limited defense to the Department's isessment of civil administrative penalties. ,UCCi COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION WESTERN REGIONAL OFFICE March 23, 2000 I Mail receipt Requested Re:Northampton, RTN 1-11134 ree et T TTwenty-Five,Inc. Former Child Property; Twenty-Five, 25-31 State Street. ix l M.G.L. Ch.21E,310 CMR 40.0000 dale,,MA 01242 NON-WE-00-3045 BOB DURAND Secretary LAUREN A. LISS Commissioner NOTICE OF NONCOMPLIANCE ADEQUATE IS AN IORTANT NOTICE. FAILURE TO ONSE TO THISS NOTICE COULD RESULT IN SERIOUS TAKE IN Mr.Catalano: di Depart ment of Environmental fore the site above.or Thiiis Noticetof Noncompliance (NON) molly that you are not comp 310 CMR ms you that you are oT in compliance with the Massachusetts Contingency Plan (MCP), y0ou remain in noncompliance,oncompliance,beginni g on the day you receive this notice. (Note: As used in Votice. you and "yours" refer to State Street Twenty-Five,Inc.) You are in noncompliance because you suabove. a t ; me (RAO) Statemntor T er Classification Submittal for the site named ia Notice of ponsibility (NOR) issued to you on October 16, 1998,the Department informed you of your liability er M.G.L. Ch.21e and the requirements of the MCP. In addition, the NOR required you to submit a Tier 0 or ivedaa letter, r. 21 Environmental Corporation,/r questtiiing, on DEP e't e Department has noot received the RAO or the Tier Classification submittal from you.submit RAO. To To avoid imposition of a Civil Administrative Penalty for this violation of the MCP, you must take e of the following actions within 14 days of your receipt of this NON: This information is available in alternate format by calling our ADA Coordinator at(617)574-6373. 436 Dwight Street•Springfield Massachusetts 01103•FAX Recycled AX( 4-11 9 Paper (413)746-6620•Telephone(413)7134-1100 atalano sloncompliance -00-3045 ubmit RAO or Tier Classification report to DEP, in accordance with the MCP; or ubmit a serves the trightto accept ore reject any uchrpr proposal, at the lDepartment's sole and unrestricted achieving iscretion. ✓ithstanding this NON, DEP reserves the right to exercise the full extent of its legal authority to J1 compliance with all applicable requirements, including but not limited to,criminal prosecution, on including court-imposed civil penalties, and Civil Administrative Penalties issued by DEP. ched for your convenience is a fact sheet containing additional information about why this NON Led to you and the steps you need to take to return to compliance (Attachment 1). If you have any is, please contact Mr. Stephen Ball at 413/755-2226 or Mr. Saadi Motamedi at 413/755-2224 vely. Since J Robert Bell Acting Deputy Regional Director Bureau of Waste Site Cleanup ied Mail #: Z 456 365 097 sure M11134NON Northampton Chief Municipal Official Northampton Board of Health Attorney Harley Sacks,31 Trumbull Road,Northampton,Ma 01060 James Spencer, Omni Environmental Corp. Steve Ellis,WERO(2 Copies) Maria Pinaud,C&E,Boston Enforcement Files,BWSC,WERO Site Files,BWSC,WERO atalano goncompliance -00-3045 ATTACHMENT 1 FACT SHEET REGARDING THIS NOTICE OF NONCOMPLIANCE attachment explains why this Notice of Noncompliance (NON) has been issued to you, and luestions you may have about the NON. Please refer to Attachment 1 for selected excerpts of use ss cited in the NON. Consult 310 CMR 40 0000) for a complete explanation Chapter exxplanation of your usetts Contingency Plan (the "MCP", and responsibility for the noncompliance cited in the NON. is I issue d this NON? ' has reason to believe that a release of oil and/or hazardous material has occurred at, or come to ed the property , s he p It considered a disposal site, as in and the MCP, and i subject to state laws and regulations governing the iminated sites. The property referenced in the NON is hereinafter referred to as "the site." P has reason to believe that you are a Potentially Responsible Party (PRP) for the site, as defined MCP. speaking, operators of disposal current owners and used or contributed to the contamination a property, persons who have been involved in some ith some circumstances.hazardous DEP has re son to believe that youtfalltw thin one ornmore of these ries. a PRP, you are required by the MCP to conduct certain actions to address the release of oil and/or haus materials at the site. One such action is the submission of a Tier Classification Submittal or nse Action Outcome Statement within deadlines specified in the MCP. ou did not make the required Tier Classification or RAO submittal for the site within the applicable ine. This NON was issued to inform you of this fact and offer you an opportunity to come back into liance by submitting the missing information to DEP by the deadlines specified in the NON. that ens if l fail to com i l with or res 1 and to the NON? iou have 14 days from the date you receive the NON to it com t ply.ce ply can or respond S , 0 per with beginning on the day you receive the NON, if you his deadline. nnington the date s you s receiveethe the Plleease refer to rthe Civil ilAdminis Administrative Penalty Statute, pier 21A, Section 16 and 310 CMR 5.00,the Civil Administrative Penalty Regulations, for complete till on the Administrative Penalty rules. w do I get started? First, do not ignore this notice. If you do not understand this notice, DEP staff are available to vide further explanation. If you need assistance, please call the Regional Engineer at the phone tuber listed at the bottom of the NON. atalano 1oncompliance 00-3045 id, you should contact a Licensed Site Professional (LSP) immediately if you have not already LSPs signature) on RAO and TerttCl Classification submittals. An and of aLSPs may be obtained(together e Massachusetts Board of Registration of Hazardous Waste Site Cleanup Professionals at (617) or view the list on the internet, at http://ww`n'state.ma.us/Isp/Isphome.htm. ie cleanu• contractor finished the work in the field, I thou ht m deali What more do I have to do? is a common question asked when a NON is received. PRPs often think their dealings with DEP when, for example, the field work is completed by a cleanup contractor. Examples of this type of .rk include cleaning up a spill from a saddle tank leak on a roadway, or removing contaminated n a tank grave during a tank replacement or oil-contaminated debris from a storage tank after a le field work may be complete, but you still must submit some paperwork to DEP to document cleanup was undertaken in compliance with the MCP. MCP includes deadlines by which you must compete response actions and submit information ,hose nformatioe about yourlc cleanup progress ho DEP on time. Fors ex y ample for work to if continue icationatoaDEP. If DEP does h not the MCP that Tier Classification 1eby the 1-year rsary we must assume ation intob[obtaining the cleanup hinformation, DEP does enot know whether serous environmental ins are being addressed. If work is not being performed, DEP must take action to ensure it ns. On the other hand, you may have finished the cleanup but neglected to forward the cleanup tentation required by the MCP. tON talks about either an RAO or Tier Classification re,ort. How do 1 choose which re ort to ith DEP were it° When i n Outcome-is completely t fDEP in wh ch you attest that you you have ompleted the cleanup in ponse with t e MCP. I more :dance with the MCP. If more environmental studies or cleanup are needed, you must make a Tier rofessi Submittal Forms the for these reports are MCP Helpline [dal (617)available the Boston area or outside of Professional (LSP), sachusetts, or 1-(800) 462-0444 from the other Massachusetts area codes, press "2" during the initial Line greeting]. To determine which submittal is appropriate for your site,you should contact your LSP. You should be aware that DEP does not become involved in or help mediate billing disputes with rrance companies, cleanup contractors, or LSPs. A common response to a NON is that an insurance hpany is slow on paying cleanup bills or will not cover various cleanup costs. We also hear that s. arum firms LSPs ust be resolved priv�ateelly by you. Youtultimately their ust comply with the attached )N or be subject to significant penalties from DEP. MLUCCI 5 MOT no enty-Five,Inc. A 01242 COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION WESTERN REGIONAL OFFICE May 12, 2000 Re:Northampton,RTN 1-11134 Former Child Property; 25-31 State Street. M.G.L.Ch.21E,310 CMR 40.0000 Establishment of Interim Deadline. BOB DURAND Secretary LAUREN A.LISS Commissioner ,lano: 00,The Department received a letter from your consultant,Omni d a Environmental Corporation, schedule. You a Department with a Release Abatement Measure(RAM) to the. You are r Department submit a RAM addendum,Status Report or a Response Action Outcome(RAO) P 31,2000. t that the deadlines for this site have long been expired,please be advised that the Department can ry of the"regulatory" deadlines set forth within the Massachusetts Contingency Plan(MCP). The however, can establish Interim Deadlines and utilize its enforcement discretion not to proceed with actions against you while the set Interim Deadline is in effect. tment's view,sites that are not able to meet their regulatory deadlines will be in noncompliance and so until such time when compliance is achieved. al problems at agree site with proposed 995 In specif c,you were notified of you have responsibility on October nd were given additional time to comply. For this case,the Department,pursuant to 310 CMR establishing August 31,2000,as the final Interim Deadline for ou to submit an RAO or the Tier ion. This deadline will not be extended. ;any questions,please contact Mr.Saadi Motamedi at 413/755-2224 111341D orthampton Chief Municipal Official orthampton Board of Health homey Harley Sacks,31 Tnimbull Road,NOn lampton,Ma 01060 Imes Spencer,Omni Environmental Corp. ite Files,BWSC,WERO Since Richard M.Green Section Chief Site Management/Permits Bureau of Waste Site Cleanup /his information is available in alternate format by calling our ADA Coordinator at(611)571-6872. 436 Dwight Street•Springfield,Massachusetts 01103 (413)784-11f 9•700 N43)7464620•Telephone 1413)784-1100 Printed OMNI ENVIRONMENTAL CORPORATION Tel: (413) 256-0394 ,et Fax: (413)256-0690 \01002 www.omnienvir onmental.com as,Mayor :hampton treet in,MA 01060 ;sachusetts Contingency Plan Public Involvement ease Abatement Measure(RAM)Plan ease Tracking Number 1-11134 it Higgins: ).1403(3)(d) of the Massachusetts Contingency Plan (MCP, 1tC Re 0.00 0)Party or i a Responsible le Abatement (RMP RU') (RAM) is i Responsible Party (RP, notify the Chief Municipal Officer and Board of Health in unity where the subject property is located(and any other affected communities). .cept notification, on behalf of State Street Twenty Five, Inc., that a RAM is being ted at their site located at 25-31 State Street. Proposed RAM activities include the removal oil Underground Storage Tank,testing and possible removal of site soils and groundwater A copy of this RAM Plan can be made available to you and the public through DEP's Regional Office, located at 436 Dwight Street, Springfield (413-784-1100). It is essential ice Disposal Site Number 1-11134 when requesting this information. e of further assistance,please call me at(413)256-0394. Y• nvironnmental Corporation coo (7{- :. Spencer,P.E.,LSP to Northampton Board of Health,Town Hall,210 Main Street,Northampton,MA 01060 Joel Catalano, State Street Twenty-Five,Inc. (Included in RAM Plan) Saadi Motamedi,Massachusetts Department of Environmental Protection(Included in RAM Plan) ieadquarters:Re catch Park • 321 Wall Street • Princeton,NI 08510-1515 •Tel:(609)921-8821 • Fax:(609)921-8831 ,t Street t,MA 01002 oer 5,2000 aggins, mayor Northampton fin St. mpton,MA 01060 OMNI ENVIRONMENTAL CORPORATION Tel: (413)256-0394 Fax:(413)256-0690 www.omnienvironmental.com Massachusetts Contingency Plan Public Involvement Phase I Report and Tier It Classification Submittal Release Tracking Number 1-11134 viayor Higgins: .n 40.1403(3)(e)e of the Massachusetts Contingency Plan(MCP, 310 CMR 40.0000) requires that a Phase I - Initial t Investigation Report D DEP),, the Responsible ble Party or Potentially Responsible r(RP, R )Environmental ify th iefMunic Municipal DEPT, P where the (RP, pgP) notify the Chief Municipal Officer and Board of Health in the community ct property is located(and any other affected communities). e accept notification that a Phase IReport has been filed by the State Street Twenty-Five,Inc., relative eported historic release of Oil or Hazardous Materials(OHM) at 25-31 State Street. A copy of this e I Report can be made available to you and the public through DEP s Western Regional Office, ed at 434 Dwight Street, Springfield. It is essential to reference Release Tracking Number 1-11134 requesting this information. 1403(6)(b) please find enclosed with this letter a copy of iti onally,in accordance with 310 CMR 40. tier 11 Classification legal notice that will be published in the Hampshire Gazette within 7 days of the of submittal. can be of further assistance, please call me at(413)256-0394. cerely, i Environmental Corporation nes C. Spencer, nior Associate c: Tier IT Classification legal notice Peter McErlain,Health Agent Joel Catalano, State Street Twenty-Five,Inc MA DEP,WERO,BWSC gate Headquarters:Research Park • 321 Wall Street • Princeton,N)08540-1515 •Tel:(609)924-8821 •Fax:(609)924-8831 NOTICE OF AN INITIAL L SITE IN INVESTIGATION AND TIER 25-31 State St. Northampton, MA RTN 1-11134 rsuant to the Massachusetts Contingency Plan (310 CMR 40.0480), an Initial Site vestigation has been performed at the above referenced location. A release of oil and/or zardous materials has occurred at this location which is a disposal site pursuant to 310 (defined by .G L. c. 21E, Section 2). This site has been classified as TIER II, p det MR 40.0500. Response actions at this site will be conducted by State Street Twenty- ve, Inc., who has employed Licensed Site Professional (LSP) James C. Spencer of Omni nvironmental Corporation to manage 4s onse actions in accordance with the lassachusetts Contingency Plan(310 CMR ). R.G.L. c. 21E and the Massachusetts Contingency Plan provide additional opportunities br of and ites: 1)public The tChief Municipal lOfficer and Board of Health of the community in which disposal the iit is located will be ntified of major 10.1403 and 2) Upon rece pt of a petition from tensor and events pursuant to 310 more residents of the muniicipalN ty M which the disposal site is located, or of a municipality potentially affected by the disposal site, a plan for involving the public in decisions regarding response actions at the site will be prepared and implemented, pursuant to 310 CMR 40.1405. in obtain more information on ,this lease site and the Catalano,pSt terStreet oTwenty- involvement during its remediation, please Five, Inc. P. O. Box 180,Lenox Dale, MA nni Environmental )rporation 15, 2001 447 West Street, Suite 5 Amherst, Massachusetts 01002 Telephone 413-256-0394 Facsimile 413-256-0690 [iggins,mayor Northampton ain St. mpton,MA 01060 Massachusetts Contingency Plan Public Involvement Phase II Report and Response Action Outcome Statement Submittal Release Tracking Number 1-11134 vlayor Higgins: n 40.1403(3)(e) of the Massachusetts Contingency Plan(MCP, 310 CMR 40.0000) requires that a Phase 11-Comprehensive Site Report(Phase B Report)is filed with the Massachusetts Department ,ironmental Protection(MA DEP),the Responsible Patty or Potentially Responsible Party (RP,PRP) the Chief Municipal Officer and Board of Health in the community where the subject property is :d(and any other affected communities). Section 40.1403 3 requires the same for the filing of a onse Action Outcome Statement. to accept notification that a Phase 11 Report and a Response Action Outcome Statement have been by the H State Street 5 31 State Street Inc., A copy of these Reports historic release of be made available to you and the trials (OHM) c through DEP's Western Regional Office, located at 434 Dwight Street, Springfield. It is essential ference Release Tracking Number 1-11134 when requesting this information. tan be of further assistance,please call me at(413)256-0394. ;erely, mi Environmental Corporation C el ta7 es C. Spencer,P. LSP nior Associate Peter McErlain,Health Agent Joel Catalano, State Street Twenty-Five,Inc MA DEP,WERO,BWSC Customer-Focused Solutions