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Home My WebLink AboutMiscellaneous - Sweet Heart Cup-Phase III 256JANE SWIFT Governor COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION Metropolitan Bostan —Northeast Regional Office yy� BOB DUMND Secretary MAR 0 6 1002 LAUREN A. LISS �� Commissioner \P_ SW �-C Inc. odd North Andover, 01845 Attn. RE: BWP — NORTH ANDOVER axon-ON1 Eli D911►I► lroI W N F."Vorm Chapters 21C, §5 and 111 §§142A -N 310 CMR 30.000, 310 CMR 6.00-8.00 MAD000636258 SQG-Hazardous Waste LQG-Waste Oil AQCR 121 Plant ID #393 MAG250012 SWNIIN Facility #344155 File No: NON -NE -02-9026-27 ENCLOSED IS AN IMPORTANT NOTICE. FAILURE TO TAKE ADEQUATE ACTION IN RESPONSE TO THIS NOTICE COULD RESULT IN SERIOUS LEGAL CONSEQUENCES. Dear Mr. Department personnel have ob erve that o uary 14, 2002, activity occurred at Sweetheart Cup Co., Inc., 351 Holt ad, North Andove Massachusetts in noncompliance with one or more laws, regulations, orders, lice s, permits, or rovals enforced by the Department. Enclosed is a Notice of Noncompliance which describes (1) the activity referred to above, (2) the requirements violated, (3) the action the Department now wants you to take, and (4) the deadline for taking such action. An administrative penalty may be assessed for every day from now on that you are in noncompliance with the requirements described in this Notice of Noncompliance. This information is available in alternate format by calling our ADA Coordinator at (617) 574-6872. 205A Lowell St. Wilmington, MA 01887 . Phone (978) 661-7600 . Fax (978) 661-7615 . TTD# (978) 661-7679 0 Printed on Recycled Paper Sweetheart Cup Co., Inc. Page 2 Notwithstanding this Notice of Noncompliance, the Department reserves the right to exercise the full extent of its legal authority in order to obtain full compliance with all applicable requirements, including, but not limited to, criminal prosecution, civil action including court -imposed civil penalties, or administrative penalties assessed by the Department. SOURCE REDUCTION OPPORTUNITIES You may be able to cut environmentally driven costs and possibly reduce the regulatory requirements and fees applied to your firm if you eliminate or reduce the use of toxic materials or the generation of wastes (referred to as "source reduction"). As a result, you may save money, and improve quality and productivity. Moreover, tracking annual usage of toxic substance and other inputs, if you are not already doing so, may lead to identification of additional source reduction opportunities. For further information on source reduction of toxics and other waste you may contact: * the Office of Technical Assistance (617-727-3260) for free, confidential technical assistance including on-site assessments, financial evaluations, and other resources. * DEP's Toxics Use Reduction Implementation Team (617-292-5870) for guidance material on TUR planning. * the Toxics Use Reduction Institute (978-934-3262) for courses for certified Toxics Use Reduction Planners. Should you have any questions relative to this matter, contact David LaBrode of this office at the letterhead address or_by-calling-(97$Y661-7632. Ve truly yours, Edward awlowsk � "'"' Chief, Compliance and Enforcement Bureau of Waste Prevention EJP/DPIJsk Certified Mail cc: Fire Dept., 124 Main St., No. Andover, MA 01845 Board of Health, 24 Charles Street, No. Andover, MA 01845 OTA, 251 Causeway Street, Suite 900, Boston, MA 02114-2136 Attn: Richard Bizzozero NERO - LaBrode Sweetheart Cup Co., Inc. Notice Of Noncompliance Page —1 - NAME OF ENTITY IN NONCOMPLIANCE: Sweetheart Cup Co., Inc. LOCATION WHERE NONCOMPLIANCE OCCURRED OR WAS OBSERVED: 351 Holt Road, North Andover, Massachusetts DATE WHEN NONCOMPLIANCE WAS OBSERVED: January 14, 2002 DESCRIPTION OF NONCOMPLIANCE AND OF THE REQUIREMENTS NOT COMPLIED WITH. Personnel from the Department conducted a compliance inspection at Sweetheart Cup Co., Inc. The following are the observed violations: (1) 310 CMR 7.02(3)f. A. " A review of the facility's FINAL APPROVAL No. MBR -01 -IND -008 revealed Sweetheart Cup Co., Inc. was not complying with the following provisos: D. GENERAL CONDITIONS 6. That Sweetheart shall continue to investigate the feasibility of implementing alternative technologies or reformulated raw material inputs which will lead to the decrease of _ overall emissions from the subject facility to the environment (air emissions, solvent waste, etc.). The subject facility shall, as needed, seek assistance from outside sources such as suppliers, vendors, and the Office of Technical Assistance (telephone No. 617-727-3260). 7. That Sweetheart shall maintain an Environmental Logbook, or equivalent record keeping system, which shall document all activities associated with environmental issues and overall emissions changes at the facility.. The facility shall record information such as the results of federal, state, or local environmental inspections; maintenance or corrective actions related to pollution control equipment (filter changes, etc.); and measures taken to lower overall emissions to the environment (air, solvent waste, hazardous waste, etc.) This logbook, or equivalent, shall be made available to the Department personnel upon request. Separate logbooks, or equivalents, can be maintained for the Standard Operating and Maintenance actions, if necessary. (2) By the actions outlined above Sweetheart is in noncompliance with: 310 CMR 7.02(3)(f) which states: "Other than as provided in 310 CMR 7.02(2)(c), no person shall operate a facility approved under 310 CMR 7.02 except in compliance with any plan approval issued to the facility. A plan approval does not negate the responsibility of the facility owner or operator to comply with any other applicable requirements of the Department." Sweetheart Cup Co., Inc. Notice Of Noncompliance Page —2- (1) 310 CMR 30.351(4)(c): The hazardous waste accumulation area, Printing Room, was being managed in violation of the "satellite accumulation" requirements in that more than one container of hazardous waste (waste ink/solvent) was observed for the same waste stream. The regulation requires that ... for each specific point of generation, only one container may be used at any one time. The maximum capacity of said container shall be as follows: 1. 55 gallons if the hazardous waste being accumulated is hazardous waste identified or otherwise described in 310 CMR 30.120 through 30.135; or 2. one quart if the hazardous waste being accumulated is acutely hazardous waste listed or otherwise described in 310 CMR 30.136. (2) 310 CMR 30.340(4)(e), (refers to 30.682): On the inspection date, two containers located in the Printing Room, used for the satellite accumulation of hazardous waste (waste ink/solvent) were observed in violation of labeling and marking requirements. The regulation requires... Throughout the period of storage, the side of each container of hazardous waste shall be clearly labeled and marked in a manner which identifies, in words, the hazardous waste(s) being stored in the container (e.g., acetone, toluene), and the hazard(s) associated with the waste (e.g., ignitable). Each container shall also be marked with the words "Hazardous Waste". (3) 310 CMR 30.253(5)(a); (refers to 30.340(4)(c)): On the inspection date, Sweetheart was found to be managing a waste. oil accumulation area, Maintenance Area in violation of -the "satellite accumulation" requirements, specifically, more than one . container of waste oil was observed in the area. The regulation requires ... For each specific point of generation, only one container may be used at any one time. The maximum capacity of said container shall be as follows: 55 gallons if the hazardous waste being accumulated is hazardous waste identified or otherwise described in 310 CMR 30.120 through 30.135; or 2. one quart if the hazardous waste being accumulated is acutely hazardous waste listed or otherwise described in 310 CMR 30.136. (4) 310 CMR 30.253(5)(a), (refers to 30.340(4)(e), (refers to 30.682)): On the inspection date, two 55 -gallon containers used for the satellite accumulation of waste oil, located in the Maintenance Area were observed in violation of labeling and marking requirements. The regulation requires... Throughout the period of storage, the side of each container of waste oil shall be clearly labeled and marked in a manner which identifies, in words, the hazardous waste(s) being. stored in the container (e.g., waste oil), and the hazard(s) associated with the waste (e.g., toxic). Each container shall also be marked with the words "Hazardous Waste". � A ` Sweetheart Cup Co., Inc. Notice Of Noncompliance Page –3- (1) and (2) Effective immediately upon receipt of this Notice, Sweetheart shall begin keeping on-site records in accordance with the provisos referenced above. Within thirty (30) days of receipt of this Notice, this Office must be in receipt of a copy of the facility's record keeping as follows: 6. records of any and all progress Sweetheart has made to reduce the overall emissions from the facility as outlined in Proviso 6. This includes contacting outside sources or the Office of Technical Assistance. 7. a copy of the Logbook Sweetheart will keep as outlined in Proviso 7. (1) and (3) Immediately upon receipt of this Notice, limit satellite accumulation to one container per waste stream. Within thirty (30) days of your receipt of this Notice, this office must be in receipt of written confirmation that this has been done and will continue to be done. (2) and (4) Immediately upon receipt of this Notice, mark all tanks and containers accumulating hazardous waste, in accordance_ with the above referenced regulation. Within thirty (30) days of your receipt of this Notice, this office must be in receipt of written confirmation that --this has been dome,—arid-will continue to be done. DATE:Q rG 4 y,Z Edward I Pawlowski Chief, Compliance and Enforcement B au 4 Waste Prevention � V - °4. David P. LaBrode Environmental Analyst 0 ARGEO PAUL CELLUCCI Governor JANE SWIFT Lieutenant Governor COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION Metropolitan Boston — Northeast Regional Office Mr. Larry Gumb Sweetheart Cup Company, Inc. ` 30 Innerbelt Road Somerville, MA 02143 0419 MhIN OF PJC i!"ri / BOARD GF HE ,,L I CSR 12 2001 Dear Mr. Gumb: BOB DURAND Secretary LAUREN A. LISS MAR _ 7 2001 Commissioner NORTH ANDOVER — Metropolitan Boston/Northeast Region 310 CMR 7.02 Non -major Comprehensive Plan Application Transmittal No. 118375 Application No. MBR -0I -IND -008 FINAL APPROVAL EMISSIONS RESTRICTION The Metropolitan Boston/N he`ast Region of the Department of Environmental Protection, Bureau of Waste Prevention, has reviewed your request for the proposed installation of a plastic and styrofoam plate, cup and lid production facility at 351 Holt Road, North Andover, Massachusetts. An administrative and technical review of your non -major Comprehensive Plan Application (nmCPA) commenced on March 2, 2001. The submittal bears the seal and signature of Mr. Robert D. Edelman, Massachusetts P.E. No. 38744. This review of the submitted information by Department engineers indicates that the proposed production lines at Sweetheart Cup Company, Inc. (Sweetheart) will result in volatile organic compounds (VOC) and hazardous air pollutants (HAP) emissions from the facility. The Department has determined that your application is administratively and technically complete and that the described processes are in conformance with current air pollution control engineering practices, and hereby grants FINAL APPROVAL for your proposal, as submitted, with the conditions listed below. Please review the entire Final Approval carefully, as it stipulates the particular conditions with which the facility owner/operator must comply in order for the facility to be operated in compliance with the Regulations. Failure to comply with this Final Approval will constitute a violation of the Regulations and can result in the revocation of the Final Approval. This information is available in alternate format by calling our ADA Coordinator at (617) 574-6872. 205A Lowell St. Wilmington, MA 01887 . Phone (978) 661-7600. Fax (978) 661-7615 . TTD# (978) 661-7679 0 Printed on Recycled Paper M" Sweetheart Cup Company, Inc. Transmittal No. 118375 Page 2 of 7 A. FACILITY DESCRIPTION Sweetheart manufactures plastic and styrofoam plates, cups and lids. The subject facility will perform both production and printing activities. Production will occur on either solid sheet thermoforming lines or on styrenic foam production lines. The production equipment configuration will include two recrystallizer lines (REC-1 and REC-2), three repelletizing lines (R-1, R-2 and R-3), three foam lines (F-4, F-5, and F-6), nine solid sheet thermoforming lines (S-7, S-8, S-9, S-10, S-11, S-13, S-14, S-15 and S- 16), and fourteen printing lines (P-1 through P-14). PRODUCTION AREA The solid sheet thermoforming lines will utilize virgin resin and/or repelletized resin (polystyrene, polypropylene, polyethylene or APET) which will be melted and extruded through a die lip under pressure to form solid sheets. The sheets will then be thermoformed into the desired s: apes such as plates and cups. The foam lines also will convert granular resin into a continuous sheet through an extruder. Prior to passing through the die, a blowing agent (HFC -152a) will be introduced into the melt stream. When the sheet exits the die, the dissolved blowing agent will vaporize and expand, causing the plastic to foam. The sheet will then be thermoformed into the desired product. Pursuant to Title VI of the Clean Air Act Amendments of 1990, United States Environmental Protection Agency (USEPA) regulates compounds such as HFC -152a. For the record, in a letter dated September 25, 1992, the USEPA conducted risk assessments for HFC -152a and determined it "created no occupational exposure concerns, it is not an ozone depleter nor a significant global warming substance." The repelletizing lines will take scrap portions of polymer and reform pellets that can be reprocessed with virgin resin. The Una-Dyn recrystallizers will take scrap portions of polymer formed from APET resin and will recrystallize the polymer into pellets for re- use. Resins used for plastic container production will be stored in silos prior to usage. Inks will be stored in a separate storage area. Solvents will be stored in a dedicated hazardous materials storage area. PRINTING AREA The printing area.will consist of fourteen (14) printing lines, an offset printing press and two (2) plate makers. The fourteen printing lines will use ultraviolet cured inks to print labels on plastic containers, cups, and lids. The VOC content of printing inks will be less than 1.0 percent by weight. Each of the fourteen lines will vent its exhaust to a common stack. The sheetfed, offset printing press and the two plate makers will be used to print small volumes of material such as Sweetheart's newsletter and internal forms. Sweetheart Cup Company, Inc Transmittal No. 118375 Page 3 of 7 B. FACILITY EMISSIONS The VOC emitted from the thermoforming lines will be monomers, which can be released when the polymer resin/sheet is heated. This will occur in two locations along the thermoforming production line: at the extruder and at the oven immediately before product formation. Sweetheart will use primarily APET resin for the production of plastic plates and cups on the thermoforming lines. The APET resin does not emit VOC when melted into a sheet or when heated prior to thermoforming. The nine solid sheet thermoforming lines, three foam thermoforming lines, three repelletizing lines and fourteen printing lines will be connected to an 36" American Air Filter Rotoclone Model AAF Type W, or equivalent, rated at 34,000 actual cubic feet (acfm) at 70 degrees F. The rotoclone air filter will be used to remove particulates (including condensibles) at a removal. efficiency of 99 percent by weight (See Special Condition No. 5). The total particulate emissions generated from these production lines will be 3,105 pounds per year before controls and 31.1 pounds per year after controls. The facility -wide emission caps contained herein shall encompass all process emissions of VOC/HAP from the proposed production lines, based on a 12 -month rolling cap, as well as a monthly cap. Records of VOC/HAP emissions shall be kept on a monthly basis to ensure compliance with each emission cap. Table I below specifies the monthly and 12 -month rolling period facility -wide emission caps of VOC and HAP. TABLE I Monthly and 12 Month Rolling Period Facility -wide Emission Caps Pollutant 12 -Month Rolling Period Monthly Emission Caps Emission Caps (Tons) (Tons) VOC* 17.50 8.0 HAP** 6.0 3.0 Table I Notes: * VOC = volatile organic compounds **HAP = Hazardous air pollutants C. SPECIAL CONDITIONS 1. That Sweetheart shall notify this Office, in writing, attention Bureau of Waste Prevention Permit Chief, when the installation of the proposed production lines is complete and they are ready for continuous operation, within fourteen days thereof. a Sweetheart Cup Company, Inc. Transmittal No. 118375 Page 4 of 7 2. That Sweetheart shall insure that the VOC content of the printing inks used at the subject facility shall be less than 1.0 percent by weight. 3. That Sweetheart shall not exceed the monthly and 12 -month rolling period facility -wide emission caps for VOC/HAP contained in Table I above. 4. That Sweetheart shall maintain adequate records on site to document compliance with the requirements as stated in Special Condition Nos. 2 and 3 above. Said records shall be made available to Department personnel upon request, and shall be kept on site for a minimum of five years. Sweetheart shall submit a report documenting the actual emissions of VOC/HAP for the previous calendar year to this office, attention Bureau of Waste Prevention Permit Chief. (See attached Annual Report Form and On-site Record-keeping Form for an example of the preferred reporting format.) This report shall be submitted on or before January 31 st of each following year. Sweetheart shall include in this report any equipment modifications (such as moving equipment for increased production efficiency, changing solvents, or changing exhaust configurations), and relocations of equipment. In addition, these modifications, and relocations shall be reflected in the Source Registration/Emissions Statement form submitted to the Department. 5. That Sweetheart shall ensure that the subject rotoclone control device shall operate at a minimum particulate removal efficiency of 99 percent by weight; and that it shall be operated at all times that the production lines associated with it are operated. 6. That the ability of the rotoclone control device to maintain the emission rate at or below the required level must be demonstrated when and if, in the opinion of the Department, such is deemed necessary. Every hooded pick-up point leading to the rotoclone shall have a minimum of 200 feet per minute face velocity. 7. That Sweetheart shall submit an excess emissions report to this Office within ten (10) days after determining that any of the monthly or rolling twelve-month facility -wide emission caps have been exceeded. Said report shall include a description of the exceedance(s) and the steps to be taken to prevent further exceedance(s). 8. That Sweetheart shall obtain prior written Approval from the Department in accordance with the applicable requirements of Regulation 310 CMR 7.02 for any proposed modifications or new equipment installations which will increase the facility -wide potential emissions by one (1.0) ton or more per calendar year. 9. That Sweetheart shall meet the following criteria: a. cleaning solutions shall be transported and stored in tightly covered containers; b. cleaning rags used in conjunction with the cleaning solutions shall be placed, when not in use, in tightly covered containers and collected for proper disposal or recycle, and; c. the VOC content of the printing inks used by Sweetheart shall not exceed 1.0 percent by weight. Sweetheart Cup Company, Inc. Transmittal No: 118375 ,Page 5 of 7 D. GENERAL CONDITIONS 1. That should any nuisance condition(s) be generated by the operation of this facility, then appropriate steps shall immediately be taken by Sweetheart to abate the nuisance condition(s). 2. That Sweetheart may implement formulation changes (chemical substitution), equipment changes, and/or relocations of equipment within the facility without requiring a modification to this Final Approval, provided that the emission caps contained in Table I and the VOC content of the printing inks contained in Special Condition No. 2 above are not exceeded. 3. That Sweetheart shall accurately report the facility's air emissions on Source Registration/Ernission Statement forms as required by Regulation 310 CMR 7.12. 4. That Sweetheart shall perform compliance emissions testing using methods approved by the Department, and the United States Environmental Protection Agency, on any or all of the emission points described in this Final Approval, if and when the Department deems such as necessary. 5. That the visible emissions from this facility shall not exceed five (5) percent opacity, except for a period, or aggregate period, of two minutes within any one hour when the visible emissions may have an opacity greater than (5) percent, but no more than ten (10) percent. At no time shall visible emissions from this facility exceed 10 percent opacity. 6. That Sweetheart shall continue to investigate the feasibility of implementing alternative technologies or reformulated raw material inputs which will lead to the decrease of overall emissions from the subject facility to the environment (air emissions, solvent waste etc.). The subject facility shall, as needed, seek assistance from outside sources such as suppliers, vendors, or the Office of Technical Assistance, which is located at the Executive Office of Environmental Affairs, 100 Cambridge Street, Boston, Massachusetts, (Telephone No. 617-727-3260). 7. That Sweetheart shall maintain an Environmental Logbook, or equivalent recordkeeping system, which shall document all activities associated with environmental issues and overall emissions changes at the facility. The facility shall record information such as the results of federal, state, or local environmental inspections; maintenance or corrective actions related to pollution control equipment (filter changes, etc.); and measures taken to lower overall emissions to the environment (air, solvent waste, hazardous waste etc.). This Logbook, or equivalent, shall be made available to Department personnel upon request. Separate logbooks, or equivalents, can be maintained for Standard Operating and Maintenance actions, if necessary. 8. That Sweetheart shall submit an annual report to this office, attention Bureau of Waste Prevention, Permit Chief, by January 31 st of each following year, summarizing its progress towards decreasing overall emissions to the environment. This report shall discuss alternative technologies or reformulated materials, which have been or will be o Sweetheart Cup Company, Inc. Transmittal No. 118375 Page 6 of 7 implemented at the subject facility. 9. Sweetheart shall allow Department personnel access to the plant site, buildings, and all pertinent records at all times for the purpose of making inspections and surveys, collecting samples, obtaining data, and reviewing records. 10. This Final Approval consists of the application materials and this Approval letter. If conflicting information is found between these two documents, then the requirements of this Approval letter shall take precedence over the documentation in the application materials. 11. Please be advised that this Final Approval does not negate the responsibility of Sweetheart to comply with this or any other applicable federal, state, or local regulations now or in the future. Nor does this Final Approval imply compliance with this or any other applicable federal, state, or local regulations now or in the future. 12. The Department has determined that the filing of an Environmental Notification Form (ENF) with the Secretary of Environmental Affairs, for air quality control purposes, was not required prior to this action by the Department. Notwithstanding this determination, the Massachusetts Environmental Policy Act (MEPA) and Regulation 310 CMR 11.00, Section 11.03, provide certain "Fail-safe Provisions" which allow the Secretary to require the filing of an ENF and/or an Environmental Impact Report at a later time. 13. Failure to comply with any of the above stated conditions will constitute a violation of the "Regulations", and can result in the revocation of the Approval granted herein to operate the described facility. The Department may also revoke this Approval if the construction work is not begun within two years from the date of issuance of this Approval, or if the construction work is suspended for one year or more. APPEAL PROCESS This Plan Approval is an action of the Department. If you are aggrieved by this action, you may request an adjudicatory hearing. A request for a hearing must be made in writing and postmarked within twenty-one (21) days of the date you received this Plan Approval. Under 310 CMR 1.01(6)(b), the request must state clearly and concisely the facts, which are the grounds for the request, and the relief sought. Additionally, the request must state why the plan Approval is not consistent with applicable laws and regulations. The hearing request along with a valid check payable to the Commonwealth of Massachusetts in the amount of one hundred dollars ($100.00) must be mailed to: Commonwealth of Massachusetts Department of Environmental Protection P.O. Box 4062 Boston, MA 02211 The request will be dismissed if the filing fee is not paid, unless the appellant is Sweetheart Cup Company, Inc. Transmittal No. 118375 Page 7 of 7 exempt or granted a waiver as described below. cc: The filing fee is not required if the appellant is a city or town (or municipal agency), county, or district of the Commonwealth of Massachusetts, or a municipal housing authority. The Department may waive the adjudicatory hearing -filing fee for a person who shows that paying the fee will create an undue financial hardship. A person seeking a waiver must file, together with the hearing request as provide above, an affidavit setting forth the facts believed to support the claim of undue financial hardship. Should you have any questions concerning this matter, please do not hesitate to contact Mr. Mun Wong of (978) 661-7600. Mun Wong Environmental Engineer Bureau of Waste Prevention Board of Health, Town Building, North Andover, MA 01845 Fire Headquarters, 124 Main Street, North Andover, MA 01845 DEP/BOSTON, ATTN: Y. Tian, Business Compliance, 7th Floor DEP/NERO, ATTN: T. Parks, M. Hancock, M. Wong Mabbett & Asociates, Inc., 5 Alfred Circle, Bedford, MA 01730-2346 ATTN: Harry Wahra Sincerely, JANE SWIFT Governor COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPART24ENT OF ENVIRONMENTAL PROTECTION Metropolitan Boston — Northeast Regional Office Sweetheart Cup, Inc. 351 Holt Road North Andover, MA 01845 Attn: Robert Jones Dear Mr. Jones: $U� BOB DUR,AND - - Secretary 1 7 212 LAUREN A. LISS MAY 15 2002 � Commissioner RE: BWP — NORTH ANDOVER COMPLIANCE with M.G.L. Chapters 21C & 111 §142A -N 310 CMR 6.00-7.00 310 CMR 30.00 NIAD000636258 SQG-Hazardous Waste LQG-Waste Oil AQCR 121 Plant ID #393 FMF Facility #344155 On January 14, 2002 Department personnel conducted a Comprehensive Compliance Inspection at 351 Holt Road, North Andover. The purpose of this inspection was to determine the compliance status of Sweetheart Plastics, Inc. with regard to the Massachusetts environmental regulations referenced above. On the inspection date, regulatory violations were observed. On March 6, 2002 a Notice of Noncompliance (File No. NON -NE -02-9026-27) was issued to Sweetheart Plastics, Inc. On April 29, 2002, Department personnel conducted a follow-up inspection. Based upon observations made during the follow-up facility inspection, and a review of company records, it has been determined that Sweetheart Plastics, Inc. had returned to compliance with the above referenced regulations as of the date of the follow-up inspection. This information is available in alternate format by calling our ADA Coordinator at (617) 574-6872. 205A Lowell St. Wilmington, MA 01887 . Phone (978) 661-7600 . Fax (978) 661-7615 . TTD# (978) 661-7679 Web Site: http:/A ww.Mass.Gov/DEP 0 Printed on Recycled Paper If you have any questions relative to environmental regulatory compliance at your facility, please -con-tact David P.LaBrode at the letterhead address or by calling (978) 661-7632. Very truly yours, Edward I Pawlowski David P. LaBrode Chief, Compliance and Enforcement Environmental An. Bureau of Waste Prevention EJP/DPIJsk cc: Fire Dept., 124 Main Street, North Andover, MA 01845 Board of Health, 24 Charles Street, North Andover, MA 01845 12/01/00 13:26 FAX 314 429 3137 CLAYCO CONST TO: Gregg Ernst Clayco Construction Company CC: Paul Merrill, Forum St Dave Junge, ForWrttudio uw* tender_ rum Studio ECT: SWEETHEART CUP / BOSTON PROJECT #5986-0 INTRODUCTION DATE: November 28, 2000 David Lewis lot CODES (21 001 CODE COMUMHE- iv Borman Circle Dr. St. Louis. Mi Som 93146-4136 314991-2633 phone 314-991-0614 fax ility to be located at 351 t dolt Road Sweetheart Cup Company has proposed a new manufacturing fac in North Andover, Massachusetts. The proposed facility will be used for the manufacture and distribution of disposable plash 1111 toai foodservice products. The project is located within the jurisdictional boundaries of the North Andover Building and Fire Departments. Massachusetts node requirements are mandatory throughout the state. Local jurisdictions may amend the codes if the state authority approves. The following codes will be applied to the project: • Massachusetts State Building Code (780 CMR), Sixth Edition • Massachusetts State Fire Prevention Regulations (527 CMR) • Massachusetts Electrical Code (527 CMR 12.00) • Massachusetts State Plumbing Code (248 CMR 2.00) Due to the type of storage arrangements expected within a project of this type, the following NFPA Standards will be applicable due to referencing by NFPA 13-1994, Installation of Sprinkler Systems: NFPA 231-1995, General Storage NFPA 231C-1995, Rack Storage of Materials Please note that the information contained in this analysis does not include handicapped accessibility provisions. The projects design team must include adequate provisions for handicapped accessibility in accordance with state and local codes. The proposed facility is an existing single -story factory and industrial building having an approximate gross area of 248,000 square feet. Current project planning calls for the demolition of existing interior walls and mezzanines and new construction to produce the proposed layout. An existing office area of approximately 14,700 square feet will remain. All existing process piping, equipment and duct work not needed will be removed. The existing building is located on a site such that all sides of the building have an exterior fire separation distance of greater than 50 feet. Under the unlimited area building provisions, the building may continue to use a Type 2C Unprotected Noncombustible construction classification. The Fire Protection and Life Safety Experts ■ Code Consubbon ■ Alarm Systems Design ■ Fire Sprinkler Design t Cl 1� 12/01/00 13:27 FAX 314 429 3137 CLAYCO CONST --- Gregg Ernst November 28, 2000 Page 2 CODE ABSTRACT All parenthetical references are from the Massachusetts State Building Code (780 CMR) unless otherwise noted. 1. Use Groups: F-1, Moderate -hazard Factory and Industrial (780 CMR 306.1) 8-1, Moderate -hazard Storage (780 CMR 311.2) B, Business (780 CMR 304.0) R002 CODEOOMMS, 1K- 1804 Bomlan Circle Dr. St. Louis, N%soufi 63146.4136 314-991-2633 phone 314991414 fax 2. Existing Construction Classification: Type 2C Unprotected noncombustible (780 CMR 603.1) NOTE: A majority of the existing mezzanines are of wood frame construction, which is not permitted in Type 2C construction. However, it appears from the selective Demolition Plan dated 9127100 that all of these mezzanines will be demolished as part of the proposed project. 3. Building Height and Area (780 CMR 507.0): Buildings of Use Group F-1, 8-1 and B of Type 2C construction which do not exceed one story or 85 feet in height are not limited in area provided that the building is equipped throughout with an automatic sprinkler system, and has a fire separation measured between the exterior walls of the building and all property lines of not less than 30 feet. EXCEPTION, The minimum fire separation distance of 30 feet does not apply to a wall facing another building on the same lot, provided that: 1) Such wall is constructed as a fire wall in accordance with 780 CMR 707.0. 2) The length of the fire wall does not exceed 25% of the total perimeter of the unlimited area building. 3) The adjacent building has a minimum fire separation distance of 30 feet on all sides, except for the side that faces the unlimited area building. 4) The adjacent building is equipped throughout with an automatic Sprinkler system in accordance with 780 CMR 906.2.1. 5) A building exceeding one story in height adjacent to the unlimited area building must not contain an occupancy in Use Group H-2 or H- 3. 4. Mixed Use Groups: Utilizing the provisions of 780 CMR 313.1.1 - Nonseparated Use Groups, fire separation assemblies between factory and industrial, warehouse and office areas are not required. 5. Specific Occupancy Areas (780 CMR 302.1.1): Boiler and furnace rooms and storage rooms in the office area greater than 100 square feet in area must be enclosed with smoke partitions. The smoke partitions must extend from the floor to underside of the floor or roof deck above. All doors must be self-closing. Doors must the Fin; Protection and Life Safety Experts ■ Code Consunatipn ■ Alarm Systems Design et Fire Sprinkler Dasign 12/01/00 13:27 FAX 314 429 3137 CLAYCO CONST _ IA003 Gregg Emst November 28, 2000 Page 3 not have air transfer openings and must not be undercut in excess of the clearance permitted in accordance with NFPA 80-1995, Fire Doors and Windows. 6. Fire Walls: Not required. 7. Exterior Walls (780 CMR 507.2): The minimum fire resistance rating of exterior walls of one-story buildings of unlimited area must W determined by the fire separation distance as specified below. FIRE SEPARATION DISTANCE FIRE RESISTANCE RATING 30 feet or greater but less than 50 feet 3 hours 50 feet or greater Not Required 8. Automatic Sprinkler Systems (780 CMR 906.0): a. Required throughout the project in accordance with the requirements for unlimited area buildings (780 CMR 507.1). b. Design standards: NFPA 13, NFPA 231, and NFPA 231C CODE COt�iUU M , W- 1804 Borman Circle Dr. St. Louis, Missouri 63146-4136 314.991-2633 phone 314-991.4614 tv C. Sprinkler alarms: Approved audible or visual alarm devices must be connected to every water sprinkler system. Such alarm devices must be activated by water flow and must be located in an approved location on the exterior of the building with an additional audible or visual alarm device installed within the building (780 CMR 906.5). EXCEPTION: Audible or visual alarm devices are not required on the exterior of buildings with sprinkler systems supervised by approved alarm monitoring services in accordance with 780 CMR 923.1. d. Supervision (780 CMR 923.0): All automatic fire suppression systems must be supervised by one of the following methods: 1) A UL listed or FM approved Central Station Service in accordance with NFPA 72-1996, National Fire Alarm Code. 2) Approved proprietary supervising station system in accordance with NFPA 72. 3) Approved remote station fire alarm system supervising station in accordance with NFPA 72. 4) Alarm signals to an approved Auxiliary Fire Alarm System in accordance with NFPA 72, with supervisory signals supervised by one or two above or at a constantly attended location approved by the local fire department, having personnel on duty trained to recognize the type of signal received and to take prescribed action. This is permitted to W a location different from that at which alarm signals are received. The fire Protection and Ute safety Evens ■ Code COASUitatiOn ■ Alarm Systems Design ■ file Sprinkler Design 12/01/00 13:27 FAX 314 429 3137 Gregg Ernst November 28, 2000 Page 4 CLAYCO CONST X1004 9. Standpipes and Hose Connections (780 CMR 914.0): Although fire department standpipes are not required by the building or fire codes. NFPA 231 and 231C require 1 -112 -inch hose lines to be available to cover all storage areas. Such hose lines may be supplied from: a. Outside hydrants. b. A separate piping system. C. Valved hose connections supplied from sprinkler risers upstream of all sprinkler control valves. d. Valved hose connections supplied from sprinkler systems serving adjacent zones. NOTE: There are existing 1-112-41nch valved hose connections, hose racks and hose in the existing warehouse area of the building. The hose connections are supplied from the overhead sprinkler system piping. 10. Fire Pumps (780 CMR 924.0): a. Design standard: NFPA 20-1996, Installation of Centrifugal Fire Pumps. CODE CONSIRTANIS, INC. 1804 Borman Circle Dr. St. Louis, Missouri 63146.4136 314-991-2833 phone 314-991-4614 tax b. Rooms: Fire pumps and all related equipment must be located in a dedicated room meeting the physical and environmental features of NFPA 20 and enclosed with not less than 2 -hours fire resistive construction. Fire pump rooms must have either direct access to the room from grade or access by a 2 -hour rated passageway and must be property secured from unauthorized entry. C. Emergency power. Not required for F-1. S-1 or B occupancies. 11. Portable Fire Extinguishers (780 CMR 920.0): a. Where required; 1) In all occupancies in Use Group B. 2) Throughout storage areas. Up to one-half of the required compliment of fire extinguishers may be omitted based upon the fixed 1 -112 -inch hose lines which are available to reach all portions of the storage area (NFPA 231, 5- 3.2). b. Design standard: NFPA 101994, Portable Fire Extinguishers. 12. Fire Hydrants: Fire hydrants should be located in accordance with ISO requirements such that all portions of the building exterior can be reached by 300 feet of hose attached to a hydrant. For windowless warehouses, NFPA 231 (Section A-5.4) recommends that hydrants be located in The Fire Protection and Life Safety Experts M Code Consultation ■ Alarm Systems Design ■ Fire Sprinkler Dasign 12/01/00 13:28 FAX 314 429 3137 CLAYCO CONST 0 005 Gregg Ernst November 28. 2000 Page 5 CM CONSULTANTS, INC. 1804 Borman Circle Or. the vicinity of building entrances. Private hydrants must be installed in accordance with NFPA St 6UIS, Missouri 24.1895, installation of Private Fire Service Mains (NEPA 231. 5-4). 314991-2633 phone 314-9914614 lax 13. Fire Lanes (527 CMR 10.03(10)): a. Designation: The head of the fire department may require and designate public or private fire lanes as deemed necessary for the efficient use of fire apparatus. b. Minimum wldth: 18 feet C. Obstructions: Designated fire lanes must be maintained free of obstructions and vehicles and must be marked in an approved manner. d. Exterior access (527 CMR 25.06): Access for fire apparatus must be provided on at least one side of every industrial type building, such access to be kept clear of all obstacles and hazardous materials as the head of the fire department may direct. 14. Fire Alarm Systems (780 CMR 917.0): Other than the single interior alarm outlined above for automatic sprinkler system waterflow, no automatic fire detection or alarm systems are required in distribution warehouse facilities. NOTE: The existing building is provided with manual fire alarm boxes and audible and visual occupant notification devices. It does not appear that the existing system complies with NEPA 72, National Fire Alarm Code or the Americans with Disabilities Act (ADA). 15. Mechanical Smoke Control System (780 CMR 921.0): Not required 16. Smoke and Heat Vents (780 CMR 922.0): Not required except when exit access travel distances are increased in accordance with 780 CMR 1006.5.1. NOTE: A portion of the existing building is protected with automatic smoke and heat vents. It does not appear that the existing vents comply with 780 CMR $22.0. In addition, curtain boards are not provided. 17. High -Hazard Materials (780 CMR Tables 307.8(1) and 307.8(2)): The storage or use of high -hazard materials in quantities exceeding that shown below could subject the building to classification as a high -hazard occupancy and more restrictive levels of protection and construction: The Fire Protection end Lite $ably Experts ■ Code Consultation ■ Alarm Systems Design ■ Fire 5prinkror Design 12/01/00 13:28 FAX 314 429 3137 CLAYCO CONST Gregg Emst November 28, 2000 Page 6 MATERIAL STORAGE USE CLASSIFICATIONCLOSED SYSTEM OPE"i SYSTEM Combustible Liquids' 240 gal 240 gal 60 gal Class 11 Class 111-A 660 gal 880 gal 160 gal Flammable Liquids' 60 gal 60 gal 20 gal Class IA Class IB 120 gal 120 gal 30 gal Class IC 180 gal 240 gal' 180 gal 240 gal 40 pal 60981 Combination Corrosive Liquids 1,000 gal 10,000 lbs 1.000 gal 10.000 lbs 200 gal 2,000145 Flammable Gas Gaseous 2.000 F.J. 1,600 c.f. NIA Liquified 60 gal 60 gal N/A ' NFPA 3D-1998. Flammable and Combuslible Liquids Code may Contain additional and/or more restrictive requirements. z Not more than this individual exempt amounts for each of the flammable liquid classes. 121006 000E (OMUMM, INC. 1804 Borman Circle Dr. St. Louis, Missouri 63146.4136 314-9g1-2633 phone 314.991A614 tax NOTE: it is proposed to use a physical blowing agent (1,1-difluroethans) for the manufacture of expanded foam plastic products. The blowing agent is classified as a flammable gas (liquified). it is proposed to store the gas in an exterior storage tank. The Massachusetts State codes do not appear to address the outside storage of flammable compressed gas cylinders. We recommend that flammable compressed gas cylinders and tanks be located at least 25 feet away from Interior lot lines, public ways, exit discharges and unprotected exterior wall opening, in accordance with other national standards. There are no NFPA standards covering the storage and handling of blowing agents. The following information was obtained from FM Global Property Loss Prevention Data Sheet 7-24, Blowing Agents. 1. Where flammable physical blowing agents are used, exhaust ventilation for equipment and buildings should be designed to prevent explosive vapor -air mixtures from forming. Where it is not possible to prevent equipment from operating within the explosive range, such equipment should be of damage -limiting construction or be protected by an approved explosion protection system. 2. Where flammable physical blowing agents are used, the equipment should be suitable for Class I location. 3. All equipment used to handle, mix or transport flammable physical blowing agents should be electrostatically bonded and grounded. The Fire Protection and Life Safety Experts ■ Code Consultation • Alarm Systems Deslgn * fire Sprinlder Design 12/01/00 13:28 FAX 314 429 3197 CLAYCO CONST Gregg Emst November 28, 2000 Page 7 4. Storage and process areas containing blowing agents should be free of ignition sources such as open flames, smoking, spark producing tools, etc. 18. Storage of Idle Pallets (NFPA 231, 4-4): a. It is preferred that pallets be stored outside or in a detached building. b. For wood pallets or nonexpanded polyethylene solid deck pallets stored indoors, no special protection is required provided the following conditions are met: fill 007 Con> COM I.TM, INC, 1604 Borman Circle Or. SL Louis, Missouri 63146.4136 314-991-2633 phone 314-991-4614 fax 1) Pallet storage must be piled no higher than 6 feet. 2) Each pallet pile of not more than four stacks must be separated from other pallet plies by at least 8 feet of clear space or 25 feet of stored commodity. C. If idle pallet storage exceeds the conditions noted above, the special sprinkler design provisions contained in Table 4.4.1.2 of NFPA 231 must be provided. d. Plastic pallets (other than the nonexpanded polyethylene solid deck pallets covered above) stored without cut-off rooms from other storage areas must be protected as follows: 1) Pallet storage must be piled no higher than 4 feet. 2) The sprinkler system must employ 286'F rated sprinklers. 3) Each pallet pile of not more than two stacks must be separated from other pallet piles by at least 8 feet of clear space or 25 feet of stored commodity. 19_ Means of Egress: a. Occupant load (780 CMR Table 1008.1.2): Occupant loads are calculated based on the following occupant load factors: 1) Industrial areas: 1 person per 100 s.f. gross area 2) Warehouse areas: 1 person per 300 s.f. gross area 3) Office areas: 1 person per 100 s.f. gross area 4) Assembly (Dining) areas: 1 person per 15 s.f. net area b. Calculated occupant load: Although a final determination of the project's calculated occupant loads can only be accomplished upon a review of more detailed architectural plans, the gross building areas proposed would represent the following estimated occupant loads: The fire Protection and Life Safety Dcpeds ■ code Consultation • Alar Systems Design ■ Fire Sprinkler Design 12,401/00 13:28 FAX 314 429 3137 Gregg Ernst November 28, 2000 Page 8 ClAYC0 CONST �T USE AREA OCCUPANT OCCUPANT ($.f.) LOAD FACTOR LOAD (S.F.IOCC) warehouse 63,135 300 210 factoryrindustrial 179,000 100 1,790 office 6,365 100 64 TOTAL 2,064 (a 008 0043£ CIMUMi1S, WC. 1804 Borman Circle Or. St Louis, Missouri 63146-0136 314-991-2633 phone 314-991414tax NOTE: This calculated occupant load probably exceeds the proposed employee count within the facility. It is intended only as a means of providing conservative egress design, not as an accurate representation of actual building occupancy, C. Number of exits: 1) In industrial and business areas, at least two exits or exit access doors must be provided from all spaces where the occupant load exceeds 50 or where the travel distance from any point within the space to an exit or exit access door exceeds 75 feet (780 CMR Table 1017.2). 2) In storage areas, at least two exits or exit access doors must be provided from all spaces where the occupant load exceeds 30 or where the travel distance from any point within the space to an exit or exit access door exceeds 100 feet (780 CMR Table 1017.2). 3) Where the total building calculated occupant load exceeds 1,000, a minimum of four exits must be provided (780 CMR Table 1010.2). d. Egress width per occupant (780 CMR Table 1009.2): 1) Stairways: 0.20 inches clear width per person. 2) Doors, ramps and Corridors: 0.15 inches clear width per person. e. Separation of exits (780 CMR 1006.4.1): Where two exits are required, each exit must be placed a distance apart equal to not less than one quarter the length of the overall diagonal dimension of the building or area to be served in buildings protected throughout with an automatic sprinkler system. Where three or more exits are required, at least two must be separated as outlined above. Exit discharge: 1) All exits must discharge directly at a public way or at a yard, court or open space of the required width and size to provide all occupants with a safe access to a public way (780 CMR 1006.3). The Fire PMectlon and Lite Safety Experts • Code Consultation ■ Alarm Systems Design ■ Fire Sptinklet Design 12'01/00 13:29 FAX 314 429 3137 CLAYCO CONST Gregg Ernst November 28, 2000 Page 9 2) Every required interior exit element which does not adjoin a public way must be directly connected to the pubic way or to an open court leading to the public way by an enclosed passageway at the level of exit discharge (780 CMR 1020.1). IA 009 CODE COIt1SuU MS, INC. 1 BM Borman Circle Dr. SL Louis, Missouri 63146.4136 314-991-2633 phone 314-991A614 tax 3) The clear width of an exit discharge passageway must not be less than the width required for the capacity of the exit stairways leading thereto and all required exit doorways opening into the passageway. Such passageway must have a minimum width of 44 inches and a minimum clear ceiling height of 8 feet (780 CMR 1020.4). g. Length of exit access travel: 1) In buildings of Use Groups F-1, S-1 and B protected throughout with an automatic sprinkler system. the maximum travel distance to an exit must not exceed 250 feet (780 CMR Table 1006.5). NOTE: it appears from the proposed building footprint that the facility can be designed to comply with the code's maximum permitted travel distance of 250 feet, although additional (new) exterior doorways are required. 2) In buildings of Use Groups F-1 and S-1 which are one-story in height and equipped throughout with an automatic sprinkler system, the exit access travel distance limitation of 250 feet may be increased to 400 feet based upon the installation of automatic smoke vents and curtain boards in accordance with Section 923.0 of the code (780 CMR 1006.5.1). Egress doors (780 CMR 1017.0); All means of egress doors must be of a side -swinging type. All doors must swing in the direction of egress travel when serving an occupant load of 60 or more persons. Exit signs and lights (780 CMR 1023.0): 1) in all buildings, rooms or spaces required to have more than one exit or exit access, all required means of egress must be indicated with an approved exit sign, and where necessary, supplemented by directional signs in the exit access routes indicating the direction and way of egress. 2) All exit signs must be illuminated at all times when the building is occupied. To assure continued illumination for duration of not less than 1 -hour in case of primary power loss, all exit signs must be connected to an emergency electrical system. Means of egress lighting (780 CMR 1024.0): 1) All means of egress must be equipped with artificial lighting facilities to provide the intensity of illumination of not less than one foot candle measured at the floor continuously during the time that conditions of occupancy within the building require that exits be available. 2) Means of egress lighting in all buildings, rooms or spaces required to have more than one exit or exit access must be connected to an emergency electrical system to assure continued illumination for a duration of not less than one hour in case of primary power loss. The Fire Pm1ecdon and Lite Satety Experts ■ Cnde Consunation ■ Alarm Systems Design ■ fire Sprinkler Design 121,01100 13:29 FAX 314 429 3137 CLAYCO CONST 16010 Gregg Ernst November 28, 2000 Page 10 20. Mezzanines (780 CMR 505.0): com caMUM, WID. 18M Dorman Circle Dr. SL Louis, Missouri 63146-4136 314.991-26M phone 314.991-4614 tax a. Area limitation: The aggregate area of a menanine within a room must not exceed one-third of the area of that room. The enclosed portions of rooms must not be included in a determination of the size of the room in which the mezzanine is located. NOTE: The existing building has several mezzanines that will be demolished. it appears from the preliminary layout that the total proposed mezzanine area will not exceed the maximum allowable area. b. Egress: 1) Each occupant of a storage mezzanine must have access to at least two independent means of egress when the occupant load of the mezzanine exceeds 30 or when the travel distance from the most remote area of the mezzanine exceeds 100 feet. 2) Each occupant of an industrial, office or assembly mezzanine must have access to at least two independent means of egress when the occupant load of the mezzanine exceeds 50 or when the travel distance from the most remote area of the mezzanine exceeds 75 feet. NOTE: The proposed Conference Room mezzanine has a calculated occupant load exceeding 50 occupants- As such, a second means of egress from the mezzanine will be required. At least one of the means of egress must be a 1 -hour enclosed exit stair discharging to the exterior, as outlined below. C. Openness: A mezzanine must be open and unobstructed to the room in which the mezzanine is located except for walls not more than 42 inches high, columns and posts. EXCEPTIONS: 1) Mezzanines or portions thereof are not required to be open to the room in which the mezzanine is located, provided that the occupant load of the aggregate enclosed spaces on the mezzanine does not exceed 10. 2) A mezzanine having two or more means of egress is not required to be open to the room in which the mezzanine is located, provided that at least one of the means of egress routes provides direct access to an exit from the mezzanine level. Q:XD59%D5986Vev-abs1rsctwpd The Fire Prolectlon and Life Safety Faperts ■ Code conaWtation f Alarm systems Design ■ Fire sprinkler Desion HORTM TOWN OF NORTH ANDOVER ° p PERMIT FOR PLUMBING * � r ,s'SACHUSE� This certifies that ......'�`:�?!..'. �fJ .•%'`� -• -`• •ff has permission to perform .....'... ...................... ..... .............. . r i plumbing in the buildings of .. r-. Iat .. �R.*. .. �**�- .............: . North Andover, Mass. Fee/,- ` �� fir, > ?y'�... . PLUMBIPIG;fNSPECTOR ✓ f Check # WHITE: Applicant CANARY: Building Dept. PINK: Treasurer MASSACHUSETTS UNIFORM APPLICATION FOR PERMIT TO DO PLUM ]WG (Type or print) NORTH ANDOVER, MASSACHUSETTS 3J` ' Date C•S-o i Building Location Aa Owners Name Swe e9r �y� Permit# h� ?o lv r -s l Amount Type of Occupancy S New Renovation Replacement Plans Submitted Yes No LJ FIXTURES r C (Print or type) dca-±—k�z Check one: Certificate Instn ling Company Name �1/m a�1 Corp: Addo�s O Q Partner. Ki n 0 - Business Telephohe — f FZ/Co. Name of.Licensed Plumber- Insurance lumber/ r Insurance Coverage: Indicate the of insurance coverage by checking the appropriate box: Liability insurance policy Other type of indemnity ❑ Bond ❑ Insurance `YVaiver. I, the undersigned, have been made aware that the licensee of this application does not have any one of the above three insurance Signature Owner Agent n I herby -;ertify that all of the details and information I have submitted (o entered) in above ap�p-l-iccation are true and accurate to the best o"my knowledge and that all plumbing work and installations rmed under P it for�tlisappl, tion will be in compliance with all pertinent provisions of the Massachus robing Coda d Chral Laws. FBy: igna o icen um er Type of Plumbing License Titley� City/Town icenseVTqum5er MasterJoumeyman r j APPROVED (OFFICE USE ONLY L._!