1. COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
ONE WINTER STREET, BOSTON, MA 02108 617··292·5500
MITT ROMNEY STEPHEN R. PRITCHARD
Governor Secretary
KERRY HEALEY ROBERT W. GOLLEDGE, Jr
Lieutenant Governor Commissioner
MEMORANDUM
To: Steve Ellis, Actin~Regir, WRO
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From: Bob Golledge, Co er
Date: June 23, 2006 ·==- -..·--··---
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RE: Approval of Waiver Request, Northampton Landfill Application for Expansion,
Northampton, Massachusetts (Transmittal #s W016447 and W074719)
The City of Northampton has submitted a site assignment application to the Department for a
proposed lateral expansion of the existing municipal landfill. As part of the site assignment
application, the proponent is asking for a waiver from the siting criteria for Zone lis at 310 CMR
l6..40(3)(a)1, arrd Potentially Productive Aquifers (PPA) at 310 CMR 16A0(3)(a)l 0. The
specific regulatory requirements are as follows:
(3) Facility .Specific Site Suitability Criteria .
(a) Criteria for Landfill Facilities (Restricted Areasl. No site shall be determined to be
suitable or be assigned as a landfill facility where:
1 . any area of waste deposition would be within a Zone II area of an existing
public water supply well;
10.. any area o:fwaste deposition would be within a Potentially Productive
Aquifer unless:
a. the proponent demonstrates to the Department's satisfaction, based on
hydrogeological studies, that the designation ofthe ar·ea as a potentially
productive aquifer is incorrect;
b the proponent demonstrates to the Department's satisfaction, based on
hydrogeological studies, that the aquifer cannot now, nor in the reasonably
foreseeable futrue, be used as a public water supply due to existing
contamination ofthe aquifer; or
c the area has been excluded as a "Non-Potential Drinking Water Somce
Area" pursuant to 310 CMR 40.0932, or as otherwise defined at 310 CMR
40.0006: TheMassachusetts Contingency Plan.
The Site Assignment Regulations at 310 CMR 16 40( 6) govern the waiver pmcess
Ibis information is available in alternate format Call Donald M. Gomes, ADA Coordinator· at 61'7·556-1057, IDD Service -1-800-298-2207
MassDEP on the World Wide Web: http:l/www mass gov/dep
( ) Printed on Recycled Paper

2. Background
The City ofNmthampton commenced landfill operations at the Glendale Road site in the 1960's
(see Site Locus Map). The City of Easthampton permitted the Maloney Well through the
MassDEP Division of Water Supply in 1976. Throughout the 1990's the City ofNmthampton
received permits for lined expansions of the Nmthampton landfill at the existing site. The
landfill cunently accepts municipal solid waste from numerous communities in the region On
August 2, 2001 the Department, as part of the Source Water Assessment Program (SWAP),
approved a conceptual Zone II delineation for the Maloney Well in Easthampton that
encompasses both the existing Nmthampton Landfill and the proposed expansion Additionally,
a number of existing land uses in Easthampton are within the Zone II and pose a potential threat
to the well, including two closed Easthampton landfills which lie between the Nmthampton
Landfill and the well.
The Maloney Well is located within the Barnes Aquifer, a very extensive buried valley, sand and
gravel aquifer extending from the Westfield River in the south to Nmthampton The nmthem
pmtion of the Barnes Aquifer consists of three "lobes", the east and west lobes flowing north
toward the center of Easthampton and the nmthwest lobe flowing southeast toward the center of
Easthampton and then east/nmtheast toward the Maloney Well and the Connecticut River (see
Maloney Well Watershed map and Hydrogeologic Features map) The Northampton Landfill is
located in the nmthwest "lobe" The landfill is located approximately 16,000 feet west of the
Maloney Well, but approximately 22,000 feet along the groundwater flow path. The Maloney
Well is located down gradient of the confluence of the three lobes.
The Maloney Well is a free flowing artesian (confined), gravel developed well, installed in 1975 .
Due to elevated manganese concentrations, the well has not been used since November 1996
The City of Easthampton developed a new well (Nonotuck Well) to replace the Maloney Well
capacity.. The Maloney well is, however, maintained as an active well, allowing Easthampton
the flexibility to use the well on demand, as needed. Easthampton also uses several other wells
(Hendricks Street wellfield, Pines Well and Brooks Street Well) and these wells provide
adequate sources to allow the Maloney Well to be used only for active back-up
Proposal
The City ofNmthampton is pwposing to expand the Northampton landfill onto a parcel of land
adjacent to and nmth of the existing landfill operation (see Conceptual Grading Plan) The
expansion areas, designated as Phases 5 and 5B, were purchased by the City in 1988 for the
purpose of the expansion.. The proposed Phase 5 area is 15.6 acres and the pwposed Phase SB
area is 4J acres. The current permitted landfill is expected to run out of capacity at the end of
2007 or early 2008 The proposed expansion area, including the area of overlap onto the existing
landfill (an additional 9.5 acres) will provide an estimated gross volume (not including the
volume taken up by the liner and cap) of2,237,000 cubic yards, which will provide 21 years of
additional capacity at the cunent disposal rate.
The applicant is requesting a waiver ofthe requirements of310 CMR 1640(3)(a)l and 10, with
respect to the siting ofthe Phase 5 and 5B expansion areas in the Zone II of a public drinking
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3. water well and within a Potentially Productive Aquifer. The existing landfill is also located
within the Zone II and the PP A
The Department reviewed several documents submitted as part ofthe site assignment application
with regard to the waiver request, including:
• Northampton Landfill Sanitary Landfill Phase 5B, BWP SW 01 Site Suitability Report
Volume 1: Technical Report
• Northampton Landfill Sanitary Landfill Phase 5B, BWP SW 01 Site Suitability Report
Volume 2: Appendices
• Northampton Landfill Phase 5 Expansion Contaminant Transport Scope of Work
• Summary Report on Contaminant Transport Model, Northampton Sanitary Landfill Phase
5 Expansion Project
• Letter dated June 6, 2006 fiom Stantec to MassDEP: Northampton Sanitary Landfill-
Phase 5 Expansion, BWP SWOl Site Suitability Report Transmittal No . W016447-
Supplemental Information
• Letter dated June 12, 2006 from Stantec to MassDEP: Northampton Sanitary Landfill-
Phase 5/5B Expansion, BWP SWOl Site Suitability Report Transmittal No . W074719-
Supplemental Information
Criteria for Granting a Waiver
The Department has reviewed the waiver request submitted with the Site Assignment
Application based upon the waiver criteria established in the Site Assignment Regulations at 310
CMR 16.40(6).. Those regulations indicate that the Commissioner may waive a facility-specific
site suitability criterion when the Commissioner finds that strict compliance with the criterion
"would result in undue hardship and would not serve to minimize or avoid adverse impact."
The regulations indicate that the Commissioner can only grant a waiver upon a finding that it "is
necessary to accommodate an oveniding community, regional, or state public interest and the
granting of the waiver would not diminish the level ofprotection to public health a:rrd safety and
the environment"
In reviewing a waiver request, the regulations also include a number of factors for consideration:
• The availability of other suitable sites in the affected municipality or regional district;
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• Whether the site is in a prefened municipality as defined in M GL c.J 11, sl50A h;
• The minimum facility size required to reasonably meet essential waste ha:rrdling
activities;
• Whether the waiver will result in environmental benefits in excess of those that could be
achieved in the absence ofthe waiver;
• The extent to which the proposed facility is part of an integrated solid waste management
activity; and
• Whether the solid waste ma:rragement objectives ofthe proposed project could be
achieved in the absence of the waiver .
Each of these factors is discussed in greater detail with regard specifically to the Northampton
waiver r equt:st
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4. 1 . The availability of other suitable sites in the affected municipality or regional district
The Site Suitability Repmt, Volume 1 includes a detailed siting analysis, the intent of which was
to identify other suitable sites inN mthampton for a landfill that would meet all the siting criteria
for a suitably sized landfill capable of managing the amount of waste cunently disposed at the
Nmthampton LandfilL Because the landfill is owned by the City ofNmthampton, the analysis
only looks to identify other sites within Nmthampton. The results of this siting analysis indicate
that one area on the westem City line meets all the site suitability criteria . However, as indicated
in the analysis, this location is zoned residentialmral and it is anticipated that there would be
considerable opposition to siting a new landfill facility in that area because the area is
undisturbed forest surrounded by residences The proposed Phase 5 and 5B expansion is
proposed in a previously disturbed area that includes an old gravel pit adjacent to the existing
landfill, which has been operating in this area for approximately 40 years.. Therefore, the City is
of the opinion, and the Department concurs, that expansion of the existing facility is prefer able to
constructing a new facility in a "greenfield" location
On a regional basis, the Northampton Landfill pmvides valuable disposal capacity to numerous
other communities At least 44 communities deliver residential and commercial solid waste to
the Northampton landfill, .39 ofwhich have contractual agreements with the landfill 23 of those
communities sent all of their municipal solid waste to the Nmthampton Landfill in 2004.
If the Northampton Landfill were not to expand, this waste (47,631 tons in 2004) would need to
be diverted to the other regional solid waste disposal facilities in the area. These facilities (The
Pioneer Valley Resource Recovery Facility in Agawam, the S. Hadley landfill, the Chicopee
landfill and the Granby landfill) are all operating at 01 near their permitted capacity.
2.. Whether the site is in a prefeiTed municipality as defined in M.G.L. c.lll, sl50A1h
The Solid Waste Act of 198 7, which established M.GL. c .111, sl50A 1h, encouraged the
establishment of both regional solid waste disposal facilities and the siting of new facilities in
municipalities that were not already served by another solid waste disposal facility. Therefore,
site assigmnents are prefened in municipalities that are not already participating in a regional
refuse disposal district
This preference is not applicable to Nmthampton. The Nmthampton Landfill, which operates as
a regional facility, serving numerous other municipalities, is an existing landfill seeking an
expansion. It is not a new landfill being sited in a municipality with another landfill that already
serves that municipality
3. The minimum facility size reguired to reasonably meet essential waste handling activities
The proposed expansion will add new capacity at the existing landfill and will provide sufficient
new capacity to manage solid waste, at the cunently permitting capacity of 50,000 tons per year,
for another 21 years
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5. 4. Whether the waiver will result in enviwnmental benefits in excess of those that could be
achieved in the absence of the waiver
The existing Nmthampton Landfill is located in the Zone II of the Maloney Well and in a
Potentially Productive AquifeL The proposed landfill expansion will be more protective of
groundwater than the existing landfill because a more stringent and protective standard liner
design will be employed as a result of the recently revised solid waste management facility
regulations and additional mitigation measmes will be employed. The mitigation measmes will
improve protections fiom the existing landfill as well as provide further pwtections fm the
aquifer These mitigation measmes fall into two categmies: those that are directly related to the
construction and operation of the landfill; and those that will take place beyond the landfill In
both cases, these mitigation measures will enhance pwtection of the Maloney well and the
associated Zone II and Potentially Productive Aquifei In the absence of the waiver the
· -~ortharnpton Landfill will need to be closed and capped and it is unlikely that the mitigation
measmes would be implemented.
At the landfill, Nmtharilpton will be required to develop and obtain MassDEP approval of a
contingency plan for specific actions that will be taken in the event that significant leachate is
found in the secondary leachate collection system. The leachate collection system can function
as an "early warning" system of potential leaks in the primary liner Having a contingency plan
in place to address such a situation will allow for faster response by th!:> City should there be a
pwblem with the liner. In addition, the City will upgrade the enviwnmental monitming system
around the landfill by installing more monitming wells and set aside money in a MassDEP
approved financial assurance mechanism, that can be used for remediation should there ever be a
problem with the liner OJ leachate collection system
Outside of the landfill, Nmthampton will need to adopt land use protection zoning and non-
zoning controls for the N mthampton pmtion of the Maloney Well Zone II. These zoning and
non-zoning controls are designed to pwtect public drinking water supplies by limiting the types
of activities that can occur in a Zone II In addition, N mthampton will need to do further wmk to
ensure household hazardous wastes are not disposed in the landfill. This will reduce the amount
of potentially toxic materials disposed and promote better management, and in some cases
recycling, of such materials.
In the absence of a waiver, the Nmthampton Landfill will run out of capacity at cuuent filling
rates in 200 7 or 2008. At that time, the landfill would be closed and capped, and all the
municipalities that cunently use the landfill would need to seek altemative waste disposal
options These mmicipalities would need to haul their solid waste to other solid waste facilities
that are farther away than the Northampton Landfill, resulting in mme truck traffic and
substantially longer haul distances with a consequent increase in air pollution .
5. The extent to which the pwposed facilitY..i§. part of an integrated solid waste management
activity
The Northampton Landfill operates as part of an integrated solid waste management activity
Through a Memorandum of Understanding (MOU) with .39 communities, it has established
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6. requirements fen dive1ting Iecyclable materials and household hazmdous wastes from the
landfill In addition, the Landfill, w01king with regional waste management 01ganizations such
as the Hilltown Resomce Management Cooperative, the Franklin County Solid Waste
Management District and the Springfield Mateiials Recycling Facility Advis01y Bomd, has
wo1ked to reduce the aiTiount and toxicity of wastes disposed at the landfill
The MOU gumantees access to the landfill fen the communities fo1 a pe1iod of five yems as well
as establishing a ceiling tipping fee that can be I educed but not exceeded The MOU se1ves the
goal of integ~ated waste management by establishing restJictions and conditions fo1 use of the
landfill for disposal MOU communities must, fo1 example, ag~ee to establish, maintain and/01
regularly pmticipate in dive1sion prog~ams for unacceptable wastes and recyclable wastes to
keep them out of the landfilL The MOU requires all member communities to establish a
mandatory recycling ordinance and have access to at least one household hazmdous waste
collection each yem. A summmy of mate1ials Iecycling access by community is provided in the
site assignment application. F01 example, through regional coopemtion, the City and member
communities have reciprocal household hazmdous waste collections, allowing residents of one
community access to collection events in other communities.. Seveml othe1 exaiTiples of
promotion ofintegmted waste management se1ving to maximize recycling and dive1sion of toxic
mate1ials fiom the landfill are presented in Appendix K of the site assignment application. All of
these actions se1ve to reduce the volume and toxicity of solid waste that must be disposed in the
landfill and maximize the volume of solid waste 1ecycled 01 dive1ted to more approp1iate
disposal options
6. Whether the solid waste management objectives of the proposed project could be achieved in
the absence of the waiver
In the absence of the waive!, the existing peimitted area of the N01thaiTipton Landfill will Iun out
of capacity in 2007 or 2008 At that time N01thampton and the communities that cunently use
the landfill for disposal of then non-recyclable waste mateiials will need to seek other disposal
options . Given the lack of sufficient disposal capacity in Massachusetts and the fact that most •
other facilities me already opemting at 01 nem then pe1mitted capacity . In addition, if the
landfill cannot expand, the prograiTis put in place as a 1esult of the MOU and cooperation aiTiong
the 1egional solid waste management distJicts (that has resulted in a high Iecycling mte and
diversion of toxic mate1ials in these communities) could diminish as each community is 1equired
to find a new solid waste management option with other disposal facilities
By granting a waive! f01 the expansion of the N orthaiTipton landfill, the landfill will gain
significant new capacity fo1 management of solid waste for the City and the othe1 municipalities
that dispose of solid waste at the landfill, providing approximately 21 years of additional
disposal capacity at the cuuently pe1mitted tonnage limit of 50,000 tons pe1 yem . The City also
Iemains committed to continuing to work with its municipal customeis to maximize somce
I eduction and recycling
Decision
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7. I have reviewed the waiver request submitted by the City ofNorthampton and hereby grant a
waiver that will allow the expansion of theN orthampton Landfill in the Zone II of the Maloney
Well and the Potentially Productive Aquifer. I find that strict compliance with the criterion
would result in undue hardship and would not serve to minimize or avoid adverse impact I also
find that the combination of land use controls, monitoring measmes and continued removal of
taxies fiom the waste stream will ensme that the Maloney Well can be used as a public water
supply in the futme . Moreover, the granting of the waiver is necessary to accommodate an
oveniding community, regional and state public interest and will not diminish the level of
protection to public health, safety and the environment for the following reasons:
• The contaminant transport model demonstrates that a release of contaminants fiom the
landfill would be below cmrent detection limits at the welL The Northampton Landfill
contaminant transport model indicates that even under the worst-case scenario, where
contaminants are released to the groundwater in leachate, the concentrations of those
contaminants would be diluted to levels below cmrent detection limits for Drinking
Water Program analytical methods The model results indicate no measmable net impact
at the welL As groundwater flows, the Northampton Landfill is approximately 22,000
feet from the well.
• Mitigation measmes or controls will provide greater protection for the Zone II and PP A
than cmrently exists . Mitigation measmes must be employed that will not only provide
further protection to the aquifer fiom the proposed expansion area, but will increase
protection of the aquifer from the existing landfill These mitigation measmes include
upgrading the environmental monitoring system at the landfill so as to better detect any
contaminants that may come from the landfill; establishing a remediation financial
assmance mechanism that could also be applied to remediation activities at the existing
landfill; implementing zoning and non-zoning controls for the Northampton portion of
the Zone II which will limit land uses and activities that could impair the Zone II; and
expanding household hazardous waste collections in the communities served by the
landfill, thereby reducing toxic materials fiom being disposed in the landfill
• The fail me ofleachate collection systems is low for a landfill with a double-composite
liner with a leak detection system. The likelihood of the worst-case scenario occuning is
very low given that the expansion area will be required to have a double-composite liner
with leak detection . Fmthermore, a site-specific "action leakage rate" will be developed
dming the permitting process that will require specific actions to be taken should leakage
above that rate occur through the primary liner. This serves as the fust level of
monitming of the performance ofthe landfill In addition, the landfill environmental
monitoring system will be upgraded.. This serves as the second level of monitoring of
the performance of the landfill.
• The Nmthampton Landfill is near capacity and there are few local options available
Without the waiver, the Nmthampton Landfill will soon run out of capacity and will
have to close This will require the City and the other municipalities that cunently
dispose of solid waste in the landfill to have to seek other disposal options. Closme of
the N mthampton Landfill will further reduce the available solid waste disposal options
and capacity in Massachusetts and will likely result in an increase in expmt of solid
waste to out of state facilities
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8. • Other potential sources of contamination lie closer to the well The Northampton
Landfill and the Maloney Well (the well for which the Zone II has been delineated) have
co-existed since 1976 . The recent Zone II delineation for the Maloney Well captmes an
existing condition which includes both the existing landfill area and the proposed
expansion area of the Northampton Landfill, two closed landfills in Easthampton, and
numerous other potential contaminant sources (i.e dry cleaners, cemeteries, gas stations,
etc.) which likely present a greater concern than the proposed landfill expansion because
these potential contaminant somces lie closer to the well than the Northampton Landfill .
• Mitigation measmes The City will be required to put in place several mitigation
measmes as a condition of the waiver. These measmes, discussed above, include:
o Leakage contingency plan
o Upgrade the enviromnental monitoring system
o Establish a remediation financial assmance mechanism
o Put in place zoning and non-zoning controls in the Northampton portion of the
Maloney Well zone II
o Expand household hazardous waste collections for those municipalities served by
the landfill
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9. --------
BASE MAP FROM USGS EASTHAMPTON AND
MT TOM QUADRANGL~
FIGURE 2-1
DEPARTMENT OF PUBLIC WORKS Project No. 9205015
SITE LOCUS Proj. Mgr. J.LAURILA
NORTHAMPTON LANDFILL AND Scale 1"~4000'
EASTHAMPTON MALONEY WELL
Northampton, Massachusetts Date JULY05
TeL {413)584-4776
"'ww.dufresne-hemy rom NORTHAMPTON MASSACHUSEHS A

10. 3000 6000 9000 Feet
Geogr.~plllc Data is from MassGIS ~ June 2006