Mill River _ CT River Levee Systems - Interim OM Review Memo_01-07-2021An Equal Opportunity Employer M/F/V/H
M E M O R A N D U M
To: David Veleta (Northampton, DPW)
Kris Baker (Northampton, DPW)
From: Thomas E. Jenkins, P.E. (GZA)
Rosalie T. Starvish, P.E. (GZA)
Nathaniel Y. Arai, P.E. (GZA)
Date: January 7, 2021
File No.: 01.0174343.00
Re: Task 5 Interim Operations and Maintenance Evaluation
Mill River Levee System
Connecticut River Levee System
Northampton, MA
In accordance with Task 5 of GZA’s proposal to the City dated July 19, 2019, the purpose of this
memorandum report is to present GZA’s evaluation of the Mill River Levee System and Connecticut
River Levee System operations and maintenance documentation, provided by the City, as required
by 44 CFR 65.10. GZA reviewed the operations documentation and compared that information to
the operational criteria as specified in 44 CFR 65.10 Part (c), including those pertaining to closures
and interior drainage systems. GZA reviewed the maintenance documentation and compared that
information to the maintenance criteria as specified in 44 CFR 65.10 Part (d). GZA’s findings and
recommendations are subject to the Limitations found in Appendix A.
GZA reviewed the following operations and maintenance documentation provided by the City:
1. Operation and Maintenance Manual for Flood Control Protection System, Northampton,
Massachusetts, Manual for the Operation and Maintenance of Dikes, Floodwalls, Pumping
Stations, Diversion Canal & Bridges, and Stop-Log Structures (“O&M Manual”, Northamp-
ton Department of Public Works, revised August 2018); and
2. City of Northampton Local Emergency Flood Plan (“Local Emergency Flood Plan”, North-
ampton Emergency Management Department, revised April 17, 2019).
The City of Northampton’s O&M Manual serves as the City’s official operation manual and mainte-
nance plan for both the Mill River Levee System and the Connecticut River Levee System in North-
ampton. This document provides a detailed description of the flood protection works, regulatory
considerations, and specific operational and maintenance procedures and requirements for the
dikes, floodwalls, utility penetrations, closure structures, bridges and diversion channel, and pump-
ing stations. The O&M Manual also provides a listing of record drawings of the levee systems and
other pertinent drawings and template inspection forms.
The Local Emergency Flood Plan is a component of the City’s emergency response planning docu-
mentation. This document describes flood monitoring and response actions associated with the
flood protection offered by the Mill River Levee System and Connecticut River Levee System in
Northampton and includes information pertaining to emergency coordination and the flood stages
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Connecticut River Levee System
Page | 2
triggering that coordination, procedures for levee monitoring, procedures for stop log installation, and inundation
mapping.
The Local Emergency Flood Plan is referenced in the O&M Manual but is not specifically included as an Appendix to
the O&M Manual. For a complete and comprehensive understanding of the operation and maintenance of the City’s
levee systems, both of these documents are required. GZA considered both documents while evaluating the operation
and maintenance criteria of 44 CFR 65.10 Part (c) and Part (d), respectively.
OPERATIONS DOCUMENTATION EVALUATION
Table 1, attached, summarizes the Operational Criteria listed in 44 CFR 65.10 Part (c) with a reference to the section
of the O&M Manual or Local Emergency Flood Plan wherein each operational criterion is satisfied. The Operational
Criteria are satisfied by the information contained in either the O&M Manual or the Local Emergency Flood Plan. Not
all of the criteria may be satisfied by reference to the O&M Manual solely. Therefore, the Local Emergency Flood Plan
must be considered as integral to the overall operations documentation required to meet the minimum requirements
of 44 CFR 65.10 Part (c).
MAINTENANCE DOCUMENTATION EVALUATION
Table 2, attached, summarizes the Maintenance Criteria listed in 44 CFR 65.10 Part (d) with a reference to the section
of the O&M Manual wherein each maintenance criterion is satisfied. As indicated by Table 2, the Maintenance Criteria
are satisfied by the information contained within the O&M Manual. While the Local Emergency Flood Plan was in-
cluded in GZA’s maintenance-related review, it does not appear to include any maintenance-specific information not
already incorporated within the O&M Manual.
DISCUSSION AND RECOMMENDATIONS
OFFICIALLY ADOPTED OPERATION MANUAL AND MAINTENANCE PLAN
Per 44 CFR 65.10 Parts (c) and (d), levee certification requires that FEMA be provided a copy of the levee system
owner’s officially adopted operation manual and maintenance plan. The currently-available documentation requires
that two (2) separate documents must be reviewed in tandem in order to satisfy all Part (c) and Part (d) criteria. To
avoid confusion and reduce the risk for future misunderstandings, GZA recommends that the City have one (1) singular
comprehensive document that can be submitted to FEMA in support of levee system certification. It appears this can
be easily accomplished by clearly and formally incorporating the Local Emergency Flood Plan into the O&M Manual as
an appendix. Implementing this recommendation will make it more clear that the Local Emergency Flood Plan is an
integral component of the City’s overall operations documentation for the Mill River Levee System and the Connecticut
River Levee System.
DATUM
The O&M Manual and Local Emergency Flood Plan reference elevations to the National Geodetic Vertical Datum of
1929 (NGVD29). Many of the updated documents pertaining to the Mill River Levee System and Connecticut River
Levee System are or will be referenced to the North American Vertical Datum of 1988 (NAVD88), including the recent
“As-built” survey documents, documents related to future levee certification, and the upcoming updated FEMA Flood
Insurance Study (FIS) and Flood Insurance Rate Maps (FIRMs). Although not required to satisfy the operational and
maintenance criteria of 44 CFR 65.10 Parts (c) and (d), GZA recommends that the City update the O&M Manual and
January 7, 2021
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Connecticut River Levee System
Page | 3
Local Emergency Flood Plan to include elevations referenced to NAVD88. Consistency in the datum between docu-
ments would serve to minimize the risk for confusion by end users gathering information from multiple sources for the
purposes of executing maintenance repairs and responding to flood emergencies. Datum conversions should be pro-
vided in each document for ease of reference throughout.
FLOOD WARNING SYSTEM
The operational criterion as follows is listed in both 44 CFR 65.10 Part (c) (1) (i) for closures and 44 CFR 65.10 Part (c)
(2) (i) for interior drainage systems:
“Documentation of the flood warning system, under the jurisdiction of Federal, State, or
community officials, that will be used to trigger emergency operation activities.”
Section 3.4 of the O&M Manual references advanced flood warnings provided by the National Weather Service (NWS)
for Connecticut River gage "NHMM3". The Local Emergency Flood Plan also indicates that current and predicted flood
elevation data for the Connecticut River may be obtained from the NWS gage named “Connecticut River at Northamp-
ton”, and that flood elevation and discharge data for the Mill River is available from the USGS gage No. 01171500
(although the USGS does not provide hydrologic predictions for water levels). The Local Emergency Flood Plan provides
general direction to “…review the flood elevations and actions that are required for both the Connecticut River and
Mill River flooding and monitor the weather forecasts, the NWS, and USGS gages for flooding information”. Section 2
of the Local Emergency Flood Plan identifies specific flood stages (on the Connecticut River as referenced to NWS flood
stages) as triggers for specific actions to operate the Hockanum Road pumping station and West Street pumping sta-
tion. The Local Emergency Flood Plan also references an alarm that sounds and provides automatic notification to the
DPW Flood Control Operator when the Connecticut River reaches elevation 105 ft NGVD29. In GZA’s opinion, the flood
warning system used by the City of Northampton is documented sufficiently to satisfy the applicable operational crite-
rion; however, GZA recommends that the City consider updating the O&M Manual and/or Local Emergency Flood Plan
to detail the specific procedures to be taken by City personnel in monitoring river levels and flood forecasts, such as
frequency and timing for review of weather/flood forecasts and gage data. As part of this update, we recommend
providing web links for the NWS Connecticut River gage, USGS Mill River gage, and other websites referenced as part
of river level and forecast monitoring, and updating those links regularly. Emphasis should be added to note datums
to avoid confusion or error.
FLOOD WARNING TIME
There are operational criteria listed in 44 CFR 65.10 Part (c) (1) (i) for closures and 44 CFR 65.10 Part (c) (2) (i) for
interior drainage systems which relate to flood warning time, as follows:
(1) For closures:
“Demonstration that sufficient flood warning time exists for the completed operation of
all closure structures, including necessary sealing, before floodwaters reach the base
of the closure”; and
(2) For interior drainage systems:
“Demonstration that sufficient flood warning time exists to permit activation of mecha-
nized portions of the drainage system.”
January 7, 2021
File No. 01.0174343.00
O&M Evaluation Memorandum
Mill River Levee System
Connecticut River Levee System
Page | 4
Section 7.3 of the O&M Manual provides estimated minimum times for installing stop-logs at the City’s three closure
structures at MassDOT Railroad, U.S. Highway No. 5, and West Street. Section 7, Stop Log Installation Procedures of
the Local Emergency Flood Plan provides CT River water surface elevations (stages) at which stop log installation is to
commence at each of the three closure structures, as follows (elevations per NGVD29 datum):
West Street Stop Log Structure
Sill Elevation: 131.4 feet
Deploy at: 124 feet [CT River stage, per NWS gage “Connecticut River at Northampton”]
Estimated minimum time for installing stop-logs = 6 hours
Route 5/Pleasant Street Stop Log Structure
Sill Elevation: 124.1 feet
Deploy at: 120 feet [CT River stage, per NWS gage “Connecticut River at Northampton”]
Estimated minimum time for installing stop-logs = 5 hours
Pan Am/ MassDOT/ Amtrak Stop Log Structure
Sill Elevation: 125.0 feet
Deploy at: 120 feet [CT River stage, per NWS gage “Connecticut River at Northampton”]
Estimated minimum time for installing stop-logs = 5 hours
Warning times are implied by the river stages that trigger stop log installation, as compared to the sill elevations and
the estimated minimum times required for installation, as described in the O&M Manual and the Local Emergency
Flood Plan. Upon initial review, it appears that sufficient flood warning time is available to deploy the one closure
structure in the Mill River levee system and the two closures in the Connecticut River levee system, based on an intui-
tive understanding of the likely rate of rise of the Connecticut River during flood conditions. Notwithstanding, GZA
recommends that the City consider updating the O&M Manual and/or Local Emergency Flood Plan to include additional
information regarding the relationships between river stage, likely rate of rise, and warning times. The likelihood that
multiple crews may or may not be available should also be discussed, considering that deployment of both Connecticut
River levee system closures is triggered by the same river stage (i.e., 120 feet).
Section 2, Local Emergency Flood Plan provides CT River water surface elevations at which pumping is initiated at the
Hockanum Road pumping station (CT River elevation 105.5 to 106) and at the West Street pumping station (CT River
elevation 120 ft). The invert of the gravity outlet at the Hockanum Road pumping station is at elevation 98.5. Water
rising to elevation 106 is contained within the small basin and bed of the Old Mill River channel on the land side of the
pumping station. According to the September 1983 report, Hydrologic Review and Analysis of Interior Drainage Facili-
ties, “The pumps are presently activated when stages exceed 105 to 106 in order to provide hydraulic gradient in the
old river channel for upstream drainage” (New England Division Corps of Engineers). It is anticipated that the City will
have more than sufficient flood warning time for the preparation of pumping activities at the Hockanum Road pumping
station. At the West Street pumping station, the gravity outlet to the Mill River is at elevation 123.0±. The threshold
for activation of the West Street pumping station, CT River elevation 120, is eight feet higher than flood stage. At CT
River elevation 120, DPW readies the West Street pumping station and examines the flap valve on the gravity outlet
pipe to verify that it is closed. Pumping is initiated when stormwater accumulates in the outlet pipe such that it reaches
the diversion level in the terminal manhole and is diverted to the pumping station. It is anticipated that the City will
have more than sufficient flood warning time for the preparation of pumping activities at the West Street pumping
station.
January 7, 2021
File No. 01.0174343.00
O&M Evaluation Memorandum
Mill River Levee System
Connecticut River Levee System
Page | 5
MANUAL BACKUP FOR AUTOMATIC SYSTEMS
The operational criterion listed in 44 CFR 65.10 Part (c) (2) (iii) for interior drainage systems requires:
“Provision for manual backup for the activation of automatic systems.”
It does not appear that operation of the Connecticut River Levee System or Mill River Levee System depends on any
automatic systems; nonetheless, the operations documentation refers to the alarm that sounds and provides auto-
matic notification to the DPW Flood Control Operator when the Connecticut River reaches elevation 105 ft NGVD29. It
is GZA’s understanding that the DPW does not rely solely on this alarm for notification of flood conditions, and that
proactive monitoring of weather forecasts, the NWS “Connecticut River at Northampton” gage and forecasts, and the
USGS Mill River gage for flooding information is performed manually by DPW personnel (see discussion above regard-
ing the flood warning system). However, no additional information about the alarm is provided in the O&M Manual or
Local Emergency Flood Plan. GZA recommends that the City consider updating the O&M Manual and/or Local Emer-
gency Flood Plan to provide information about how the alarm operates and is maintained, tested, and/or calibrated.
The City should also consider specifying what would occur if the alarm were to fail, and if and how additional redun-
dancy should be provided.
CONCLUSION
In GZA’s opinion, the City’s O&M Manual (with the Local Emergency Flood Plan incorporated as an appendix, as rec-
ommended by GZA) provides suitable operations and maintenance documentation to satisfy the criteria of 44 CFR
65.10 Part (c) and Part (d) for the Mill River Levee System and for the Connecticut River Levee System. Notwithstand-
ing, GZA’s review did identify aspects of the operations and maintenance documentation that could be improved upon,
as detailed in this memorandum.
Attachments:
Table 1 – Operations Evaluation
Table 2 – Maintenance Evaluation
Appendix A – Limitations
\\GZANOR\Jobs\170,000-179,999\174343\174343-00.CLB\Memos\O&M Review\Mill River _ CT River Levee Systems - OM Review Memo_01-07-2021.docx
Proactive by Design
TABLES
OPERATIONS EVALUATION
Mill River Levee System, Northampton, MA
Connecticut River Levee System, Northampton, MA
TABLE 1: OPERATION PLANS AND CRITERIA: 44 CFR 65.10 Part (c)
Regulatory Reference Operational Criterion
Operational
Criterion Satisfied?
(Yes /No /Not
Applicable)Plan Reference Comments
44 CFR 65.10 Part (c)
Adopted Operation Manual
All closure devices or mechanical systems for internal drainage, whether
manual or automatic, must be operated in accordance with an officially
adopted operation manual, a copy of which must be provided to FEMA by
the operator when levee or drainage system recognition is being sought or
when the manual for a previously recognized system is revised in any
manner.
Yes, provided that an
"officially adopted
operation manual" is
provided to FEMA.N/A
Operation of the Northampton Flood Control System is described in the "Operation and Maintenance Manual for Flood Control
Protection System Northampton, Massachusetts; Manual for the Operation and Maintenance of Dikes, Floodwalls, Pumping
Stations, Diversion Canal & Bridges, and Stop-Log Structures", Original by the U.S. Army Corps of Engineers, April 1945, as revised
by the City of Northampton, August 2018 (O&M Manual ). Additional operational information about flood stages triggering
emergency operations and stop log installation is included in "City of Northampton Local Emergency Flood Plan", City of
Northampton Emergency Management Department, revised April 17, 2019 (Local Emergency Flood Plan ). To avoid confusion and
reduce the risk for future misunderstandings, GZA recommends that the City have one (1) singular comprehensive document that
can be submitted to FEMA in support of levee system certification. It appears this can be easily accomplished by clearly and
formally incorporating the Local Emergency Flood Plan into the O&M Manual as an appendix.
44 CFR 65.10 Part (c)
Jurisdiction
All operations must be under the jurisdiction of a Federal or State agency,
an agency created by Federal or State law, or an agency of a community
participating in the NFIP.Yes
O&M Manual,
Section 3.1, page 8
Operation of the Northampton Flood Control System is under the jurisdiction of the Northampton Department of Public Works,
125 Locust Street, Northampton, Massachusetts. The O&M Manual states that the City has agreed to maintain and operate the
completed flood control works in accordance with "Flood Control Regulations - Maintenance and Operation of Flood Control
Works" as approved by the Acting Secretary of the Army on August 9, 1944 and published in the Federal Register on August 17,
1944. The City of Northampton participates in the NFIP.
44 CFR 65.10 Part (c) (1) (i)
Flood Warning System
Documentation of the flood warning system, under the jurisdiction of
Federal, State, or community officials, that will be used to trigger
emergency operation activities.Yes
O&M Manual,
Section 3.4, page 11;
Local Emergency
Flood Plan, Section 2
Section 3.4 of the O&M Manual references advanced flood warnings provided by the National Weather Service (NWS) for
Connecticut River gage "NHMM3". The Local Emergency Flood Plan also indicates that current and predicted flood elevation data
for the Connecticut River may be obtained from the NWS gage named “Connecticut River at Northampton”, and that flood
elevation and discharge data for the Mill River is available from the USGS gage No. 01171500 (although the USGS does not provide
hydrologic predictions for water levels). The Local Emergency Flood Plan provides general direction to “…review the flood
elevations and actions that are required for both the Connecticut River and Mill River flooding and monitor the weather forecasts,
the NWS, and USGS gages for flooding information”. Section 2 of the Local Emergency Flood Plan identifies specific flood stages
(on the Connecticut River as referenced to NWS flood stages) as triggers for specific actions to operate the Hockanum Road
pumping station and West Street pumping station. The Local Emergency Flood Plan also references an alarm that sounds and
provides automatic notification to the DPW Flood Control Operator when the Connecticut River reaches elevation 105 ft NGVD29.
44 CFR 65.10 Part (c) (1) (i)
Flood Warning Time
Demonstration that sufficient flood warning time exists for the completed
operation of all closure structures, including necessary sealing, before
floodwaters reach the base of the closure.Yes
O&M Manual,
Section 7.3, page 26;
Local Emergency
Flood Plan, Section 7
Section 7.3 of O&M Manual states: "Erection of each movable closure shall be started in sufficient time to permit completion
before flood waters reach the top of the structure sill. Information regarding the proper method of erecting each individual
closure structure, together with an estimate of the time required by an experienced crew to complete its erection will be given in
the Operation and Maintenance Manual which will be furnished local interests upon completion of the project". O&M Manual ,
Section 7.3 provides estimated minimum time for installing stop-logs at MassDOT Railroad, U.S. Highway No. 5, and West Street.
Also in O&M Manual , Section 7.3: "Detailed procedures, plans, an equipment list, and personnel required is included in the Local
Emergency Flood Plan". Section 7, Stop Log Installation Procedures of the Local Emergency Flood Plan provides CT River water
surface elevation at which stop log installation shall be deployed at each of the three closure structures.
44 CFR 65.10 Part (c) (1) (ii)
Responsibilities
A formal plan of operation including specific actions and assignments of
responsibility by individual name or title.Yes
Local Emergency
Flood Plan, Section 2
Section 2, Flood Stages and Emergency Coordination of the Local Emergency Flood Plan provides responsibilities by title for
actions required to operate the flood control system at flood stages on the Connecticut River from Low Stage to Major Flood
Stage. Includes stages at which closure structures should be readied and fully installed.
44 CFR 65.10 Part (c) (1) (iii)
Testing & Training
Provisions for periodic operation, at not less than one-year intervals, of the
closure structure for testing and training purposes.Yes
O&M Manual,
Section 7.1, page 25 "…a trial installation of the emergency closure shall be made at least once each year".
General
Closures
Page 1 of 2
TABLE 1: OPERATION PLANS AND CRITERIA: 44 CFR 65.10 Part (c)
Regulatory Reference Operational Criterion
Operational
Criterion Satisfied?
(Yes /No /Not
Applicable)Plan Reference Comments
44 CFR 65.10 Part (c) (2) (i)
Flood Warning System
Documentation of the flood warning system, under the jurisdiction of
Federal, State, or community officials, that will be used to trigger
emergency operation activities.Yes
O&M Manual,
Section 3.4, page 11;
Local Emergency
Flood Plan, Sections 1
& 2
Section 3.4 of the O&M Manual references advanced flood warnings provided by the National Weather Service (NWS) for
Connecticut River gage "NHMM3". The Local Emergency Flood Plan also indicates that current and predicted flood elevation data
for the Connecticut River may be obtained from the NWS gage named “Connecticut River at Northampton”, and that flood
elevation and discharge data for the Mill River is available from the USGS gage No. 01171500 (although the USGS does not provide
hydrologic predictions for water levels). The Local Emergency Flood Plan provides general direction to “…review the flood
elevations and actions that are required for both the Connecticut River and Mill River flooding and monitor the weather forecasts,
the NWS, and USGS gages for flooding information”. Section 2 of the Local Emergency Flood Plan identifies specific flood stages
(on the Connecticut River as referenced to NWS flood stages) as triggers for specific actions to operate the Hockanum Road
pumping station and West Street pumping station. The Local Emergency Flood Plan also references an alarm that sounds and
provides automatic notification to the DPW Flood Control Operator when the Connecticut River reaches elevation 105 ft NGVD29.
44 CFR 65.10 Part (c) (2) (i)
Flood Warning Time
Demonstration that sufficient flood warning time exists to permit activation
of mechanized portions of the drainage system.Yes
Local Emergency
Flood Plan, Section 2
Section 2, Local Emergency Flood Plan provides CT River water surface elevation at which pumping is initiated at the Hockanum
Road pumping station (CT River elevation 105.5 to 106), and at the West Street pumping station (CT River elevation 120 ft).
44 CFR 65.10 Part (c) (2) (ii)
Responsibilities
A formal plan of operation including specific actions and assignments of
responsibility by individual name or title.Yes
Local Emergency
Flood Plan, Section 2
Section 2, Local Emergency Flood Plan provides responsibilities by title for actions required to operate the flood control system at
flood stages on the Connecticut River from Low Stage to Major Flood Stage. Includes stages at which pumping is initiated.
Applicable to both the Connecticut River Levee System and Mill River Levee System.
44 CFR 65.10 Part (c) (2) (iii)
Automatic Systems
Provision for manual backup for the activation of automatic systems.N/A
O&M Manual,
Sections 9.1 & 9.3;
Local Emergency
Flood Plan, Section 2
It does not appear that operation of the Connecticut River Levee System or Mill River Levee System depends on any automatic
systems; nonetheless, the operations documentation refers to the alarm that sounds and provides automatic notification to the
DPW Flood Control Operator when the Connecticut River reaches elevation 105 ft NGVD29. At the Hockanum Pumping Station,
the gravity conduit sluice gate and wet sump sluice gate are operated electrically with push-buttons or manually using control
levers (O&M Manual, Section 9.3, page 42).
At the Hockanum P.S., manual hoists are present for the movable trash racks on the intake to gravity conduit and entrance to 48-
inch propeller pump room (O&M Manual , Section 9.1, page 31).
44 CFR 65.10 Part (c) (2) (iv)
Testing & Training
Provisions for periodic inspection of interior drainage systems and periodic
operation of any mechanized portions for testing and training purposes.Yes
O&M Manual,
Section 9.2, page 32
O&M Manual , Section 9.2: "Pumping plants shall be inspected by the superintendent at intervals not to exceed 30 days during
flood seasons and 90 days during off-flood seasons to insure that all equipment is in order for instant use….All equipment,
including switch gear, transformers, motors, pumps, valves, and gates shall be trial operated and checked at least once every 90
days."
44 CFR 65.10 Part (c) (2) (iv)
Annual Inspections
No more than one year shall elapse between either the inspections or the
operations.Yes
O&M Manual,
Section 9.2, page 32
O&M Manual , Section 9.2: "Pumping plants shall be inspected by the superintendent at intervals not to exceed 30 days during
flood seasons and 90 days during off-flood seasons to insure that all equipment is in order for instant use".
Review for compliance with 44 CFR 65.10 Part (c) was based on the following documents:
Operation and Maintenance Manual for Flood Control Protection System Northampton, Massachusetts; Manual for the Operation and Maintenance of Dikes, Floodwalls, Pumping Stations, Diversion Canal & Bridges, and Stop-Log Structures; Department of Public Works, City of
Northampton, August 2018
Interior Drainage Systems: storage areas, gravity outlets, pumping stations, or a combination thereof
City of Northampton Local Emergency Flood Plan; Northampton Emergency Management Department, revised April 17, 2019
Page 2 of 2
MAINTENANCE EVALUATION
Mill River Levee System, Northampton, MA
Connecticut River Levee System, Northampton, MA
TABLE 2: MAINTENANCE PLANS AND CRITERIA: 44 CFR 65.10 Part (d)
Regulatory Reference Maintenance Criterion
Operational
Criterion Satisfied?
(Yes /No /Not
Applicable)Plan Reference Comments
44 CFR 65.10 Part (d)
Adopted Maintenance Plan
Levee systems must be maintained in accordance with an officially adopted
maintenance plan, and a copy of this plan must be provided to FEMA by the
owner of the levee system when recognition is being sought or when the plan
for a previously recognized system is revised in any manner.
Yes, provided that an
"officially adopted
maintenance plan" is
provided to FEMA. N/A
Maintenance of the Northampton Flood Control System is described in the "Operation and Maintenance Manual for
Flood Control Protection System Northampton, Massachusetts; Manual for the Operation and Maintenance of Dikes,
Floodwalls, Pumping Stations, Diversion Canal & Bridges, and Stop-Log Structures", Original by the U.S. Army Corps of
Engineers, April 1945, as revised by the City of Northampton, August 2018 (O&M Manual ). To avoid confusion and
reduce the risk for future misunderstandings, GZA recommends that the City have one (1) singular comprehensive
document that can be submitted to FEMA in support of levee system certification. It appears this can be easily
accomplished by clearly and formally incorporating the Local Emergency Flood Plan into the O&M Manual as an
appendix.
44 CFR 65.10 Part (d)
Jurisdiction
All maintenance activities must be under the jurisdiction of a Federal or State
agency, an agency created by Federal or State law, or an agency of a
community participating in the NFIP that must assume ultimate responsibility
for maintenance.Yes
O&M Manual,
Section 3.1, page 8
Operation of the Northampton Flood Control System is under the jurisdiction of the Northampton Department of Public
Works, 125 Locust Street, Northampton, Massachusetts. The O&M Manual states that the City has agreed to maintain
and operate the completed flood control works in accordance with "Flood Control Regulations - Maintenance and
Operation of Flood Control Works" as approved by the Acting Secretary of the Army on August 9, 1944 and published in
the Federal Register on August 17, 1944. The City of Northampton participates in the NFIP.
44 CFR 65.10 Part (d)
Maintenance Procedure
This plan must document the formal procedure that ensures that the stabilty,
height, and overall integrity of the levee and its associated structures and
systems are maintained.Yes
O&M Manual,
Sections 4.2, 5.2,
6.2, 7.2, 8.2, 9.2
Maintenance of the dikes, floodwalls, utility penetrations, closure structures, bridges and diversion channel, and
pumping stations is outlined in the applicable sections in the O&M Manual .
44 CFR 65.10 Part (d)
Responsibilities
At a minimum, maintenance plans shall specify the maintenance activities to
be performed, the frequency of their performance, and the person by name or
title responsible for their performance.Yes
O&M Manual,
Sections 4.2, 5.2,
6.2, 7.2, 8.2, 9.3
Maintenance of the dikes, floodwalls, utility penetrations, closure structures, bridges and diversion channel, and
pumping stations is outlined in the applicable sections in the O&M Manual . The maintenance activities and their
frequency are described. The O&M Manual indicates that the Superintendent is responsible for the performance of
maintenance activities.
Review for compliance with 44 CFR 65.10 Part (c) was based on the following documents:
General
Operation and Maintenance Manual for Flood Control Protection System Northampton, Massachusetts; Manual for the Operation and Maintenance of Dikes, Floodwalls, Pumping Stations, Diversion Canal & Bridges, and Stop-Log Structures; Department of Public Works, City
of Northampton, August 2018
City of Northampton Local Emergency Flood Plan; Northampton Emergency Management Department, revised April 17, 2019
Page 1 of 1
Proactive by Design
APPENDIX A
LIMITATIONS
LIMITATIONS
01.0174343.00 Operations and Maintenance Evaluations
Page | 1
January 2021
Proactive by Design
USE OF REPORT
1.GeoEnvironmental, Inc. (GZA) prepared this Report on behalf of, and for the exclusive use of the Client for the stated
purpose(s) and location(s) identified in the Report. Use of this Report, in whole or in part, at other locations, or for other
purposes, may lead to inappropriate conclusions and we do not accept any responsibility for the consequences of such
use(s). Further, reliance by any party not identified in the agreement, for any use, without our prior written permission,
shall be at that party’s sole risk, and without any liability to GZA.
STANDARD OF CARE
2.Our findings and conclusions are based on the work conducted as part of the Scope of Services set forth in the Report
and/or proposal, and reflect our professional judgment. These findings and conclusions must be considered not as
scientific or engineering certainties, but rather as our professional opinions concerning the limited data gathered and
reviewed during the course of our work. Conditions other than described in this Report may be found at the subject
location(s).
3.The interpretations and conclusions presented in the Report were based solely upon the services described therein, and
not on scientific tasks or procedures beyond the scope of the described services. The work described in this Report was
carried out in accordance with the agreed upon Terms and Conditions of Engagement.
4.GZA's evaluation was performed in accordance with generally accepted practices of qualified professionals performing
the same type of services at the same time, under similar conditions, at the same or a similar property. No warranty,
expressed or implied, is made. The findings are dependent on numerous assumptions and uncertainties inherent in the
review process. The findings are not an absolute characterization of operations and maintenance preparedness, but
rather serve to evaluate minimum standards of performance provided by the documentation reviewed.
RELIANCE ON INFORMATION FROM OTHERS
5.In conducting our work, GZA has relied upon certain information made available by public agencies, Client, and/or others.
GZA did not attempt to independently verify the accuracy or completeness of that information. Any inconsistencies in
this information which we have noted are discussed in the Report.
COMPLIANCE WITH CODES AND REGULATIONS
6.We used reasonable care in identifying and interpreting applicable codes and regulations necessary to execute our scope
of work. These codes and regulations are subject to various, and possibly contradictory, interpretations. Interpretations
with codes and regulations by other parties are beyond our control.
ADDITIONAL INFORMATION
7.In the event that the Client or others authorized to use this Report obtain information on conditions at the site(s) not
contained in this Report, such information shall be brought to GZA's attention forthwith. GZA will evaluate such
information and, on the basis of this evaluation, may modify the opinions stated in this Report.
ADDITIONAL SERVICES
8.GZA recommends that we be retained to provide services during any future investigations, design, implementation
activities, construction, and/or property development/ redevelopment at the Site(s). This will allow us the opportunity
to: i) observe conditions and compliance with our design concepts and opinions; ii) allow for changes in the event that
conditions are other than anticipated; iii) provide modifications to our design; and iv) assess the consequences of
changes in technologies and/or regulations.