GE Corporate 159 01201 USA Transmitted Via Overnight Deliverywith evidence of sparse vegetative ground cover, six burning bush shrubs on Parcel I9-9-27 that appeared to be stressed,

Transmitted Via Overnight Delivery

March 4. 2015

Mr. Dave Dickerson Office of Site Remediat ion and Restoration U.S. Environmental Protection Agency. Region I 5 Post Office Square - Suite 100 Boston. MA 02109-3912

GE Corporate

159 Plast1cs Avenue Pittsfield, MA 01201 USA

Re: GE-Pittsfield/Housatonic River Site- Silver Lake Area IGECD600) 2014 Annual Monitoring Report

Dear Mr. Dickerson:

Enclosed is GE's Annual Monitoring Report for 2014 for the Silver Lake Area. This report has been prepared at EPA's request to describe and present the results of the post-construction monitoring activities and follow-up response actions performed in 2014 at the Silver Lake Area.

Please contact Andy Silfer or me with any questions or comments regarding the enclosed report.

Sincerely yours.

7?/J ;2· Richard W. Gate0'-/fb{' Senior Project Manager - Environmental Remediation Global Operations - Environment. Health and Safety

Enclosure

cc: Dean Tagliaferro. EPA (hard copy and electronic copy) Tim Conway. EPA !electronic copy) Chris Ferry. ASRC Primus (electronic copy) Scott Campbell. Avatar (2 hard copies+ electronic copy) Robert Leitch. USACE (electronic copy) Michael Gorski. MossDEP (cover letter + CD) John Ziegler. MassDEP (cover letter + CD) Eva Tor. MDEP (electronic copy of cover letter only) Nancy E. Harper. MA AG (cover letter only) Nate Joyner. Pittsfield Dept. of Community Development (electronic copy) James McGrath. Pittsfield Dept. of Parks and Recreation (electronic copy) Corydon Thurston. Executive Director. PEDA (electronic copy) James Gagnon. O'Reilly, Talbot & Okun (electronic copy) Barbara Landau. Noble & Wickersham (electronic copy) Andrew Silfer. GE (electronic copy) Rod Mclaren. GE (electronic copy) Todd Cridge. ARCADIS (electronic copy) Mark Gravelding. ARCADIS Lauren Putnam. ARCADIS (electronic copy) James Bieke. Sidley Austin LLP GE Internal Repository

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General Electric Company Pittsfield, Massachusetts

2014 Annual Monitoring Report

Silver Lake Area

March 2015

2014 Annual Monitoring Report Silver Lake Area

Prepared for:

General Electric Company

Prepared by:

ARCADIS of New York, Inc. 6723 Towpath Road Syracuse New York 13214-0066 Tel 315.446.9120 Fax 315.449.0017

Our Ref.:

B0040152

Date:

March 2015

Table of Contents

1. Introduction 1

2. 2014 Non-Natural Resource Restoration/Enhancement (NRRE) Post-Remediation Inspections 3

2.1 Initial Inspection in May 2014 and Follow-up Activities 3

2.2 Second Inspection in September 2014 and Follow-up Activities 4

3. NRRE Installation Inspection/Meeting and 2014 NRRE Inspections 6

3.1 Initial NRRE Inspections in May 2014 and Follow-up Activities 6

3.2 Second NRRE Inspection in September 2014 and Follow-up Activities 8

4. Cap System Monitoring and Maintenance 10

4.1 Cap Thickness Monitoring and Follow-up Activities 10

4.2 Isolation Layer Monitoring 11

4.3 Evaluation of PCB Deposition on Cap Surface 12

4.4 Sediment Trap Monitoring 13

5. Surface Water Sampling 14

6. Inspection of Properties Subject to Grants of Environmental Restrictions and Easements (EREs) or to Conditional Solutions 15

6.1 ERE Inspections 15

6.2 Conditional Solution Inspections 15

7. Future Activities 17

Tables

2-1 Baseline Quantities of Restored Vegetation in the Non-Natural Resource Restoration/Enhancement Areas

3-1 Baseline Quantities of Restored Vegetation in the Natural Resource Restoration/Enhancement Areas

4-1 Cap Thickness Data for Year 1 (2014) Post-Construction Sampling

4-2 PCB Data for Year 1 (2014) Post-Construction Sampling and Immediate Post-Construction Results

5-1 Surface Water Monitoring Summary

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Table of Contents

Figure

1-1 Long-Term Inspection Areas/Items and Monitoring Locations

Appendices

A Previously Submitted Reports from 2014 Inspection/Monitoring Activities

B Surface Water Monitoring Data Validation Report

C Surface Water Monitoring – EPA Split Sampling Results

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1. Introduction

Pursuant to the requirements set forth in the October 2000 Consent Decree (CD) for the GE-Pittsfield/Housatonic River Site (the Site) and the accompanying Statement of Work for Removal Actions Outside the River (SOW), the General Electric Company (GE) implemented a Removal Action at the Silver Lake Area Removal Action Area (RAA) between July 2012 and December 2013. The Removal Action implemented at the Silver Lake Area included removal of some sediments, installation of a sediment cap and associated shoreline armor layer, removal/replacement of soil in certain areas on the banks and adjacent areas, and restoration of the excavated areas, as well as the implementation of certain natural resource restoration/enhancement (NRRE) measures in various areas around the lake. The CD and SOW require various post-construction monitoring and maintenance activities for the completed Removal Action and the NRRE measures. In accordance with Section 3.7 of the SOW, GE developed and submitted a Post-Removal Site Control Plan/Restoration Project Monitoring and Maintenance Plan (PRSCP/RPMMP) as Appendix I to its August 2011 Revised Final Removal Design/Removal Action Work Plan for Silver Lake Area (Revised Final Work Plan), which was conditionally approved by the U.S. Environmental Protection Agency (EPA) by letter dated August 25, 2011.

The 2011 PRSCP/RPMMP described the future inspection, monitoring, maintenance, and repair activities to be conducted by GE at this RAA. Specifically, these activities include: (1) inspection, monitoring, and maintenance activities, to be conducted as part of Post-Removal Site Control activities pursuant to Attachments K and J of the SOW, for the sediment cap and shoreline armor systems and for the backfilled, restored, and re-vegetated areas of the banks and other areas adjacent to the lake (other than the NRRE areas); (2) monitoring and maintenance activities, to be performed pursuant to Attachment I of the SOW, for the NRRE measures installed at the Silver Lake Area; and (3) periodic inspections, to be performed pursuant to the CD and Appendix Q of the CD, at the non-residential, non-GE-owned properties with Grants of Environmental Restrictions and Easements (EREs) and properties at which Conditional Solutions have been implemented.1 In addition, Paragraph 88.a of the CD required the performance of a Pre-Certification Inspection of the Silver Lake Area following the completion of all remediation activities, and Paragraph 120 of the CD required the performance of an NRRE installation inspection and meeting following the installation of all NRRE measures.

Given the large number and diverse nature of the areas and items that are subject to monitoring and maintenance activities at the Silver Lake Area, EPA requested that GE submit annual reports to detail all of the inspection, monitoring, and maintenance activities that

1 The requirements of the 2011 PRSCP/RPMMP will be replaced with those specified in the revised PRSCP/RPMMP contained in GE’s Final Completion Report (FCR) for the Silver Lake Area Removal Action following GE’s submission and EPA’s approval of that FCR. See Section 7 below.

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occurred within the RAA over the course of a given year. This 2014 Annual Monitoring Report has been prepared to summarize all of the Post-Removal Site Control and NRRE monitoring and maintenance activities performed during 2014 at the Silver Lake Area. Specifically, this report summarizes the inspection, monitoring, maintenance, repair, and replanting activities conducted at the Silver Lake Area during 2014 for the following components of the program:

• Inspection and maintenance of the non-NRRE components of the remediation, including backfilled/restored areas adjacent to Silver Lake, non-NRRE plantings, and the shoreline armor system (but excluding the sediment cap, discussed separately below);

• Monitoring and maintenance of the NRRE plantings and other measures;

• Sediment cap system monitoring;

• Surface water sampling;

• ERE inspection activities; and

• Conditional Solution inspection activities.

Figure 1-1 illustrates the areas/items that were monitored in 2014. To avoid unnecessary duplication, the reports on the individual monitoring events performed in 2014 are attached and are incorporated by reference herein.



2. 2014 Non-Natural Resource Restoration/Enhancement (NRRE) Post-Remediation Inspections

The approved 2011 PRSCP/RPMMP required the performance of an initial inspection of the backfilled/restored areas that were subject to soil removal and replacement activities or were otherwise disturbed by the remediation, to be conducted shortly after completion of the final restoration activities. It also required semi-annual inspections of these areas for the first year after construction (with annual inspections thereafter), semi-annual inspections of the planted non-NRRE vegetation in these areas for the first two years after planting, and semi-annual inspections of the shoreline armor system for five years after construction. Although the final restoration activities were completed in December 2013, GE and EPA agreed that the initial post-remediation inspection would be postponed due to weather conditions and would be combined with the first semi-annual inspection of the above-mentioned areas in spring 2014.

2.1 Initial Inspection in May 2014 and Follow-up Activities

GE conducted the combined initial post-remediation inspection and first semi-annual inspection on May 27, 2014, with representatives of EPA and the Massachusetts Department of Environmental Protection (MDEP) also in attendance. (That inspection, together with the NRRE inspections on May 27-29, 2014, discussed in Section 3.1 below, also constituted the Pre-Certification of the Silver Lake Area in accordance with Paragraph 88.a of the CD.) A report on the May 27 non-NRRE inspection was submitted to EPA on June 25, 2015, and was conditionally approved by EPA by letter dated July 21, 2014. A copy of the June 25, 2014 report is included in Appendix A.

In accordance with the 2011 PRSCP/RPMMP, this inspection included visual observations of the backfilled/restored areas and other disturbed areas for the following: (a) evidence of erosion; (b) the effectiveness of erosion controls in areas where vegetation was not established; (c) evidence of depressions and/or surface water ponding; (d) any areas where excessive settlement had occurred relative to the surrounding areas; (e) any drainage or growth problems; (f) any stressed or sparse cover; and (g) other conditions that could jeopardize the performance of the completed remediation actions. The 2014 inspection identified nine areas with evidence of erosion, depressions, drainage or growth problems, and/or stressed or sparse cover, as described in GE’s June 25, 2014 report.

In addition, this inspection included observations of the vegetation planted in the backfilled/restored areas outside of the NRRE areas to assess the establishment, coverage, and condition of the vegetation; and it included observations of the trees and shrubs planted in those areas as part of restoration activities to assess the number and condition of those plantings. As described in GE’s June 25, 2014 report, this inspection identified three areas with evidence of sparse vegetative ground cover, six burning bush shrubs on Parcel I9-9-27 that appeared to be stressed, and six other stressed or dead shrubs, three of which were



excess to the number required to be planted. It also identified the total quantities of healthy trees and shrubs. It noted that, while all parcels in the non-NRRE areas except Parcels I9-10-8 and I9-9-9 had at least one invasive species present, invasive species cover did not exceed 5% of the ground cover at any parcel. EPA’s conditional approval letter of July 21, 2014 directed GE to prune and water the six stressed shrubs on Parcel I9-9-27 and to replace the three non-excess dead shrubs (red-osier dogwoods). Based on GE’s report and that EPA letter, since this inspection was the initial inspection of planted trees and shrubs, the total quantities of healthy trees and shrubs counted during this inspection, together with the six stressed shrubs on Parcel I9-9-27 and the three non-excess dead red-osier dogwoods noted by EPA, were identified as the baseline numbers of plantings for percent survival calculations in subsequent monitoring events. These baseline quantities are shown in Table 2-1.

Finally, the May 27, 2014 inspection included visual observations of the shoreline armor system to assess the effects, if any, of any shoreline wave and/or wind action on that system, including the presence of any significant erosion (e.g., slope failure, ruts, gullies, washouts, or sloughing). No areas within the shoreline armor system were noted with significant erosion. However, it was observed that some geotextile installed within the channel to the outfall from Silver Lake to the Housatonic River was exposed, and GE proposed to cover that area with additional riprap, which EPA approved in its July 21, 2014 conditional approval letter.

Subsequent to this inspection, some displacement/erosion of armor stone, with exposed geotextile, was observed in the channel of the Fourth Street outfall, and additional stone movement was observed near Outfalls SL-OF-28, -29, and -31. GE submitted to EPA a plan for the repair of the armor stone in these areas on August 20, 2015, and EPA conditionally approved that plan on August 21, 2014.

Several of the identified repair/maintenance activities were conducted on August 22, 2014. These included soil replacement, re-grading, re-seeding, and/or placement of additional riprap in the areas identified during the May 2014 inspection, as well as the pruning and watering of the six stressed shrubs on Parcel I9-9-27.

2.2 Second Inspection in September 2014 and Follow-up Activities

GE conducted the second semi-annual inspection of the backfilled/restored areas, non-NRRE plantings, and shoreline armor system on September 4, 2014; and a report on that inspection was submitted to EPA on October 3, 2014. A copy of the October 3, 2014 report is included in Appendix A.

That inspection noted the repair/maintenance activities that had been performed based on observations made during the May 2014 inspection, and identified seven additional locations within the backfilled/restored areas with evidence of erosion, depressions, drainage or growth



problems, and/or stressed or sparse cover, as described in GE’s October 3, 2014 report. In addition, with respect to the planted non-NRRE vegetation, that inspection noted the following:

• While the three non-excess red-osier dogwoods that had been observed to be dead in May 2014 and that EPA had directed GE to replace had not yet been replaced, the quantity of red-osier dogwoods on each of those parcels met or exceeded the baseline quantity, and thus no additional red-osier dogwoods needed to be planted.

• The six stressed burning bush shrubs on Parcel I9-9-27 that had been stressed were no longer stressed.

• The ground vegetation was adequately established in the non-NRRE areas except in one area where re-seeding was needed.

• Comparison of the numbers of trees and shrubs counted in September 2014 to the baseline numbers revealed a shortage of a total of 15 shrubs (on four properties) which required replanting.

• Parcels in the non-NRRE areas except Parcel I9-10-8 had at least one invasive species present, but again invasive species cover did not exceed 5% of the ground cover at any parcel.

With respect to the shoreline armor system, the September 4, 2014 inspection showed no areas of significant erosion (as defined above), but continued to show the displacement of armor stone, with exposed geotextile, in the channel of the Fourth Street outfall (which had not yet been repaired), and also showed several other areas of exposed geotextile, possibly due to settlement and/or repositioning of the armor stone, as described in GE’s October 3, 2014 report.

The repair, maintenance, and replanting activities identified based on this inspection were performed between September 30 and October 20, 2014. These included replacement of soil or riprap and/or re-seeding in areas with minor erosion or settlement or sparse cover, replanting of the 15 shrubs identified as dead or missing, replacement of armor stone in areas of exposed geotextile, and repair of the displaced armor stone in the channel of the Fourth Street outfall. GE also continued its ongoing invasive species control program to address the invasive species identified.



3. NRRE Installation Inspection/Meeting and 2014 NRRE Inspections

The NRRE installation activities performed by GE at the Silver Lake Area were documented in GE’s revised Completion of Installation of Restoration Work (CIRW) Report, which was submitted to the Natural Resource Trustees (Trustees) on May 23, 2014 and approved by the Trustees on September 3, 2014. Those activities included creation of a shallow-water shelf along the shoreline of the lake, installation of a number of plantings on the “shrub-scrub island” near the discharge outfall and on the banks of the northern and eastern sides of the lake, and construction of a walking path and benches on the northern and eastern sides of the lake. A copy of GE’s May 23, 2014 revised CIRW Report is included in Appendix A.

Under Paragraph 120 of the CD, an NRRE installation inspection/meeting was required to be held after submission of that report to assess whether the NRRE measures had been installed in accordance with the applicable Performance Standards and other requirements of the CD. In addition, the 2011 PRSCP/RPMMP, as modified by the revised CIRW Report, required that GE perform periodic inspections of the plantings installed in NRRE areas (including semi-annual inspections for the first three years after planting) and annual inspections of the walking path and benches for a three-year period. EPA, GE, and the Trustees agreed that the NRRE installation inspection/meeting for the Silver Lake Area could be combined with the first of the 2014 semi-annual inspections of the NRRE plantings.2

3.1 Initial NRRE Inspections in May 2014 and Follow-up Activities

The combined inspections representing the NRRE installation inspection/meeting and the first of the 2014 semi-annual inspections of the NRRE plantings were held on May 27-29, 2014. These inspections were attended by representatives of GE and EPA and, on behalf of the Trustees, by an MDEP representative on May 27 and by a U.S. Fish and Wildlife Service representative on May 28-29.3 A report on these combined inspections was submitted to the Trustees on July 19, 2014. The Trustees conditionally approved that report by letter dated September 3, 2014 and requested that GE submit a revised report on these inspections. GE submitted that revised report on October 2, 2014. A copy of the October 2, 2014 report is included in Appendix A.

2 The gravel habitat layer placed on the shallow-water shoreline shelf was previously monitored in 2012-13 following installation to confirm that the shallow-water shelf/gravel habitat layer was three inches thick at that time. As discussed and shown in the revised CIRW Report (in Appendix A), the final monitoring confirmed that that layer met or exceeded the three-inch Performance Standard for thickness. As a result, no further inspections of this NRRE feature were required in 2014.

3 Representatives of the City of Pittsfield and the Pittsfield Economic Development Authority were also invited, and City representatives were present for a portion of the May 29 inspection activities.



As discussed in that revised report, during the May 2014 NRRE installation inspection/meeting, it was concluded that the NRRE measures at the Silver Lake Area had been installed in accordance with the applicable Performance Standards and other requirements of the CD, with the exception that the voids in the lower portion of the armor stone above the mean water surface elevation (WSE) line of 975.9 feet around the perimeter of the shrub-scrub island had not been filled with topsoil and seeded with a wetland seed mix.4

These combined inspections also included monitoring of the NRRE plantings that were installed at the Silver Lake Area. This monitoring was conducted for certain specified monitoring areas, as well as designated monitoring plots within them (to be used for quantitative monitoring purposes), that were established around the northern and eastern sides of the lake, as specified in the revised CIRW Report. These monitoring areas (which are coextensive with the three tax parcels that comprise the NRRE areas [i.e., Parcels I9-10-9, I9-9-36, and I9-9-35] plus the shrub-scrub island) and the monitoring plots within them are described below and shown on Figure 1-1.5 During this inspection, a stem count was completed for all NRRE plantings that were installed at the Silver Lake Area. A table summarizing the results of this stem count (organized by the monitoring areas) was included in the October 2, 2014 report for informational purposes. In addition, a stem count was made of all live trees and shrubs planted in the monitoring plots (no dead trees or shrubs were observed in any of those plots) to serve as the baseline numbers of plantings for future percent survival calculations. Those baseline quantities are listed, by monitoring plot, in Table 3-1.

In accordance with the PRSCP/RPMMP as modified by the revised CIRW Report, the initial semi-annual inspection of the NRRE plantings on May 27-29, 2014 included both a qualitative field inspection (meander survey) of the NRRE areas where vegetation was installed, and a quantitative assessment of the vegetation within the monitoring plots. As described in the revised inspection report on October 2, 2014, this inspection noted the following with respect to the NRRE vegetation:

• Sparse grass cover was observed in a number of areas (including several areas above the top of bank near the walking path), resulting in failure to meet the applicable Performance Standard of 100% coverage by native herbaceous species (outside the

4 As noted in the October 2, 2014 report, the voids in the armor stone at higher elevations were filled with topsoil and seeded; however, the fill/seeding did not extend all the way down to the WSE line of 975.9 feet (as provided in the Revised Final Work Plan), likely due to above-average water elevations in the lake at the time of installation, which prevented filling at the lower elevations.

5 As described in the revised CIRW Report, the quantitative results from the monitoring plots within each monitoring area are combined to evaluate achievement of the applicable vegetation Performance Standards in each of the four monitoring areas.



foliar coverage of the trees) in any monitoring area. However, the majority of these sparsely vegetated areas appeared to have been recently hydroseeded and re-seeding was not considered necessary.

• As noted above, no dead trees or shrubs were observed, and the live trees and shrubs in the monitoring plots were counted to serve as a baseline for future percent survival calculations.

• Buttonbush plantings on the shrub-scrub island exhibited delayed development and were identified for re-evaluation in the next inspection.

• Six red oak trees along the eastern bank of Silver Lake appeared to be stressed and were identified for pruning and watering on a regular basis.

• Invasive species were observed in several areas, but invasive species cover was less than the applicable Performance Standard of 5% in all monitoring areas except one (area I9-10-9). All invasive species were slated for treatment as part of GE’s ongoing invasive species control program.

Subsequent to this inspection, the majority of the identified maintenance activities were performed, including pruning and watering of the six red oak trees and continuation of invasive species treatment. However, the placement of topsoil and an herbaceous wetland seed mix in the void spaces in the lower portion of the armor stone around the periphery of the shrub-scrub island was not performed. Instead, based on a recommendation from its planting consultant, GE proposed to postpone this filling/seeding activity until the spring 2015 growing season to improve the likelihood of establishment, and promote the growth, of the herbaceous wetland species.

3.2 Second NRRE Inspection in September 2014 and Follow-up Activities

On September 4, 2014, GE conducted the second of the 2014 semi-annual inspections of the NRRE plantings, along with the annual 2014 inspection of the walking path and benches. The planting inspection again included a qualitative meander survey and a quantitative assessment of the vegetation within the monitoring plots. A report on this inspection was submitted to the Trustees on October 31, 2014, and a copy of such report is included in Appendix A. As described in that report, this inspection noted the following:

• Sparse grass cover was observed in a narrow area along the lake-side of the walking path on the north side of the lake and on a nearby portion of the bank where an invasive species had been cut and treated, and re-seeding was recommended in those areas.



• Sparse grass cover was also observed in a number of other areas, resulting in failure to meet the 100% Performance Standard for native herbaceous species cover in all monitoring areas except the shrub-scrub island. However, it was determined that those other sparsely vegetated areas would likely continue to increase in vegetative cover and that re-seeding was unnecessary.

• Several shrubs along the walking path on Parcel I9-9-36 had been mowed down by the City of Pittsfield during lawn maintenance activities, and EPA requested that GE replace eight of those shrubs.

• Based on comparison of the quantities of live trees and shrubs counted in each monitoring plot to the baseline quantities observed in May 2014 (shown in Table 3-1), the average percent survival for the trees and/or shrubs in each monitoring area was well above the applicable Performance Standard of 80% survival.

• Eight shrubs were observed to be stressed but alive and were identified for continued monitoring.

• The buttonbush plantings on the shrub-scrub island that had exhibited delayed development in May 2014 were observed to be healthy and growing as anticipated.

• The six red oaks on the eastern bank of the lake that had appeared to be stressed in May 2014 were showing improved leaf development, but were identified for continued watering and pruning.

• Invasive species were again observed in several areas, but their coverage in each monitoring area (based on the results from the monitoring plots within them) was less than the 5% Performance Standard.

• No damage to the walking path or benches was identified and those features were observed to be functioning as intended.

At EPA’s request, the vegetation-related maintenance and replanting activities identified during this inspection – including pruning/watering of the trees on the eastern bank, scarifying and re-seeding the sparsely vegetated areas on the northern bank, replanting the eight shrubs that were mowed down, and treatment of invasive species – were conducted during other restoration activities performed from September 30 through October 20, 2014. However, the placement of topsoil and an herbaceous wetland species seed mix in the voids in the lower portion of the armor stone around the periphery of the shrub-scrub island was deferred until the spring of 2015.



4. Cap System Monitoring and Maintenance

In accordance with Attachment K of the SOW and the PRSCP/RPMMP contained in Appendix I of the Revised Final Work Plan, the post-construction monitoring program for the sediment cap installed in Silver Lake in 2013 consists of several elements: (a) monitoring to assess cap thickness and integrity; (b) sampling of the isolation layer to assess migration of polychlorinated biphenyls (PCBs), if any, from the underlying sediment; (c) evaluation of the isolation layer samples to evaluate PCB deposition on the surface of the cap; and (d) monitoring of sediment traps to evaluate sediment deposition of the surface of the cap. GE performed the 2014 cap inspections and collection of cap material cores on October 15-17 and 20, 2014, with a follow-up inspection using divers on November 10, 2014. A report on these monitoring activities was submitted to EPA on December 29, 2014, and was conditionally approved by EPA in a letter dated January 22, 2015. A copy of the December 29 report is included in Appendix A.6 EPA conditionally approved that trip report in a letter dated January 22, 2015.

The cap system monitoring program included collection of cores at 21 locations, visual inspection by an underwater video camera and/or divers, and processing of 10 of the collected cores for PCB analysis. As described in the December 29, 2014 report, the sediment traps installed in the lake in December 2013 after cap construction could not be located. The performance and results of the 2014 cap monitoring are summarized below.

4.1 Cap Thickness Monitoring and Follow-up Activities

In accordance with Attachment K to the SOW, the cap monitoring program requires that cap material cores be collected annually for five years to assess the in-place cap thickness at the 21 locations shown on Figure 1-1.7 If these periodic inspections of cap thickness and integrity indicate that the design standards for the cap have not been achieved and maintained, GE is required to evaluate and propose to EPA appropriate corrective measures to achieve those design standards, and must implement such measures upon approval by EPA.

GE conducted the first of these monitoring events to assess cap thickness and integrity in October 2014. Cap material cores were collected at the 21 locations shown on Figure 1-1, and the thickness of the cap material in the cores was measured. Those thickness measurements are presented in Table 4-1. Additionally, an underwater video camera was used in an effort to make a visual assessment of the cap surface, but the resulting video images provided only limited information. As a result, a supplemental inspection was

6 Note that, to avoid duplication, the video provided as Attachment A to the December 29, 2014 report is not re-attached to this document. 7 These locations are situated outside the near-shore areas in which the armor stone layer was placed. The monitoring of the shoreline armor stone layer was discussed in Section 2.



conducted on November 10, 2014, using divers to perform a visual inspection of the cap surface in the vicinity of the core collection locations and to obtain additional video images of the cap surface.

As described in the December 29, 2014 report, the results of this monitoring event indicated that the design standards for the cap thickness and integrity had generally been maintained. During the supplemental inspection conducted on November 10, 2014, the divers did not observe any signs of cap failure or compromise, and the surface of the cap appeared to be of a consistent nature, without significant signs of depressions and/or holes. The thickness measurements associated with the collected cores (presented in Table 4-1) indicated that the cap thickness met or exceeded the design thickness Performance Standard of 14 inches in areas outside the shoreline armor system, except at one location. At that one location (SL-CAP-01), the measured thickness of contiguous cap material was observed to be 12 inches (although some cap material was also observed in that core at a depth of 15 to 20 inches). As a result, GE proposed to add at least two inches of additional cap material in an area around that location.

In EPA’s January 22, 2015 conditional approval letter for that report, EPA directed GE to submit a proposal for additional cap thickness testing in the vicinity of location SL-CAP-01 so as to bound the area of the cap that is less than 14 inches thick and thus to determine the horizontal extent of the additional cap material placement. In response, in a letter dated February 3, 2015, GE proposed an additional cap thickness testing program, consisting of borings, to determine the extent of the cap area that is less than 14 inches thick. That proposal was conditionally approved by EPA in a letter dated March 2, 2015. The performance and results of that program, along with subsequent response actions, will be described to EPA in forthcoming letters to be submitted in the coming months. This information will also be summarized in the next report on the cap system monitoring program.

4.2 Isolation Layer Monitoring

The cap monitoring program also requires that, during the first-year (2014) and fifth-year (2018) post-construction cap monitoring events, ten of the cap material cores collected for assessing cap thickness, identified on Figure 1-1, are to be subject to PCB analysis. Cores from these locations are to be sectioned into three intervals, as measured relative to the interface between the cap material and the underlying sediment layer, and analyzed for PCBs. The results are to be compared to the PCB data from samples collected from the cap immediately after construction to help assess the extent of any PCB migration through the cap. If the results of this sampling indicate that the isolation layer is not performing in general accordance with the predictions on which the cap design was based in terms of effectively controlling migration of PCBs from the underlying sediments through that layer into the surface water of the lake, GE is required to evaluate appropriate corrective measures, submit



the results of that evaluation to EPA for approval along with a proposal for any appropriate corrective measures, and implement such measures, if any, upon EPA approval.

To satisfy these requirements, ten of the cap material cores collected in October 2014 (as shown on Figure 1-1) were sectioned into the three required intervals for PCB analysis. The results were presented in GE’s December 29, 2014 cap monitoring report dated December 29, 2014. Table 4-2 summarizes the validated PCB data from this 2014 post-construction sampling event, along with the results from the immediate post-construction monitoring at the same locations for comparison. GE’s report noted that, since there had been only two rounds of sampling of the final cap material approximately one year apart, it was too early to perform a meaningful assessment of the performance of the cap over time. Nevertheless, GE performed an assessment of the results to the extent practicable, and concluded that the results provided no indication that the isolation layer is failing to perform in accordance with the predictions on which the cap design was based in terms of effectively limiting the migration of PCBs from the underlying sediments through that layer into the surface water of the lake. Accordingly, no further response actions were proposed. That assessment was approved through EPA’s January 22, 2015 conditional approval letter for the cap monitoring report.

4.3 Evaluation of PCB Deposition on Cap Surface

The cap monitoring program further requires that the PCB analytical results from the above-referenced samples collected during the first-year and fifth-year post-construction monitoring events be reviewed to assess the presence and extent of PCB deposition on the surface of the cap, as opposed to the migration of PCBs through the cap from the underlying sediments. If the results indicate the presence of PCBs as a result of deposition on the surface of the cap, GE is required to attempt to identify potential sources of those PCBs. To the extent practicable, attempts are to be made to determine whether the PCBs are attributable to sources other than erosion or surface runoff from the banks or currently known discharges of PCBs into the lake from National Pollutant Discharge Elimination System [NPDES]-permitted or other outfalls. If the surface PCBs can be attributed to such other sources and those sources are located within property owned by GE, GE is required to evaluate potential source control measures and submit a report on that evaluation to EPA for review and approval, along with a recommendation for any appropriate source control measures. Otherwise, no further response actions are required to address the deposition of PCBs on the surface of the cap (except as otherwise provided in the CD).

In accordance with these requirements, the PCB analytical results from the top one-inch layer of the 10 cap material cores collected in October 2014 were reviewed to assess the presence and extent of PCB deposition on the surface of the cap. The results of this evaluation were also presented to EPA in GE’s December 29, 2014 cap monitoring report. As noted in that report, the analytical results from the top one-inch interval samples indicated the presence of some PCBs on the surface of the cap (1.22 parts per million [ppm] at one location, with the



remainder below 1 ppm) that are likely a result of deposition, but there did not appear to be an identifiable potential source or sources of those PCBs, and there was no apparent pattern or relationship between the detections and particular types of locations. Since the PCBs on the surface of the cap could not be attributed to any identifiable sources other than erosion or surface runoff from the banks or currently known discharges of PCBs into the lake from the NPDES-permitted outfall or other outfalls, no source control measures or other further response actions were proposed to address the deposition of PCBs on the surface of the cap. That assessment was approved through EPA’s January 22, 2015 conditional approval letter for the cap monitoring report.

4.4 Sediment Trap Monitoring

GE was also required, for a two-year period after cap construction, to assess sedimentation on the cap surface through monitoring of five sediment traps installed in Silver Lake in December 2013 after cap construction. In accordance with this requirement, GE attempted during the October 2014 cap monitoring event to locate and retrieve the sediment traps, but the traps could not be found. Divers were then used in the November 2014 supplemental inspection to attempt to locate the sediment traps, but again the traps could not be located. As a result, as described in its December 29, 2014 report, GE rebuilt the sediment traps and installed them at the same five locations shown on Figure 1-1, using divers, on December 18-19, 2014. In light of this replacement, GE restarted the sediment trap monitoring program and will retrieve those traps (if located) once annually in 2015 and 2016.



5. Surface Water Sampling

Following the completion of cap and armor layer placement activities in Silver Lake, GE resumed routine water column sampling at the Silver Lake outfall (location shown on Figure 1-1) as part of its Housatonic River monthly water column monitoring program. Specifically, under this program, monthly water column samples are collected at the Silver Lake outfall to the Housatonic River (known as Location 4A in that program) and analyzed for PCBs (including filtered analysis for 10 of the 12 months) and total suspended solids (TSS). Field data such as temperature, conductivity, and pH are also collected for each event. In addition, for each event, the flow in the river is reported from data collected at the U.S. Geological Survey (USGS) River Gage Station No. 01197000 on the East Branch of the Housatonic River in Coltsville, MA. Precipitation data are also compiled from daily National Oceanic and Atmospheric Administration’s National Weather Service (NOAA/NWS) data reported for the Pittsfield, MA airport for monitoring events with turbidity reading results greater than 5 nephelometric turbidity units (NTUs).

During 2014, 12 monthly surface water monitoring events were conducted. The results associated with GE’s 2014 surface water monitoring at the Silver Lake outfall to the river are summarized in Table 5-1. As shown there, PCBs were detected in 11 of those 12 monthly sampling events (all but January 28, 2014) with results ranging from non-detect to an estimated concentration of 0.129 parts per billion (ppb). TSS results across the entire water column data set ranged from 1.2 to 9.1 ppm.

The data in Table 5-1 have been validated in accordance with GE’s 2013 Field Sampling Plan/Quality Assurance Project Plan, and an associated data validation report is included in Appendix B.

In addition, EPA collected and arranged for the analysis of split water column samples collected during certain of the monthly surface water monitoring events. The analytical results for these split samples were provided by EPA and are summarized in Appendix C.



6. Inspection of Properties Subject to Grants of Environmental Restrictions and Easements (EREs) or to Conditional Solutions

In accordance with the CD, EREs have been executed and recorded at a number of properties in the Silver Lake Area. At other properties, Conditional Solutions have been implemented in accordance with the provisions of the CD. The CD and the PRSCP/RPMMP require GE to conduct annual inspections of such properties that are not owned by GE or the Commonwealth of Massachusetts.

6.1 ERE Inspections

The non-GE-owned properties at the Silver Lake Area that are subject to EREs consist of: (a) portions of two privately owned properties (Parcels I9-9-32 and I9-9-33) within this RAA, on which EREs were recorded in January 2014; (b) former GE property on the eastern bank of Silver Lake (Parcel I9-9-35), which was subsequently transferred to Pittsfield Economic Development Authority (PEDA), and on which an ERE was recorded on March 31, 2014; and (c) PEDA property on the northern bank of the lake (Parcels I9-10-9 and I9-9-36), on which an ERE was recorded on April 4, 2014. For these properties/areas, annual inspections are required under Paragraph 57 and Appendix Q of the CD and the 2011 PRSCP/RPMMP to assess compliance with the applicable EREs, as well as any visual evidence of certain other activities (e.g., certain types of excavation, construction, demolition, soil disturbance, erosion, etc.,) during the preceding year. These annual inspections include both a document review and a visual site inspection.

For each of the above-listed properties/areas, GE initiated the annual ERE inspections in November 2014 in accordance with the 2011 PRSCP/RPMMP, and a report on those initial inspections was submitted to MDEP and EPA on December 17, 2014. A copy of that report is included in Appendix A. As indicated in that report, these inspections revealed no new ERE-related documentation and no visual evidence of any activities or uses that are potentially contrary to the restrictions in the EREs or any of the other activities that require identification at the Restricted Areas of these properties (as defined in the EREs) since recordation of the EREs.

6.2 Conditional Solution Inspections

Conditional Solutions under the CD have been implemented at several non-residential properties within the Silver Lake Area – Parcels I9-9-201 and I9-9-17, Parcels I9-9-21 & -22, Parcel I9-9-25, and Parcel I9-9-34. On February 6, 2014, GE sent letters to the owners of these properties notifying them that a Conditional Solution had been implemented at the portions of their properties within the Silver Lake RAA. For these properties/areas, annual inspections are required under Paragraphs 36 and 38 and Appendix Q of the CD and the 2011 PRSCP/RPMMP to determine whether there has been a change in ownership and to



evaluate whether is visual evidence of any change in activities and uses that would be potentially inconsistent with the land use for which the Conditional Solution was implemented, or of certain other activities involving soil excavation or disturbance. These inspections include both a document review and a visual site inspection.

For the above-listed properties at which Conditional Solutions have been implemented at this RAA, GE conducted the first annual Conditional Solution inspections in November 2014, and a report on those inspections was submitted to EPA and MDEP on December 17, 2014. A copy of that report is included in Appendix A. As indicated in that report, these inspections showed no changes in ownership of any of these properties and no visual evidence of any changes in activities or uses that require identification at the subject portions of these properties since implementation of the Conditional Solutions.



7. Future Activities

GE will continue with post-construction monitoring activities at the Silver Lake Area in accordance with applicable requirements. Those activities will include future monitoring of: (a) backfilled/restored areas adjacent to Silver Lake; (b) non-NRRE plantings; (c) the shoreline armor system; (d) NRRE plantings and other NRRE measures; (e) the sediment cap system; (f) the surface water at the outfall from Silver Lake to the Housatonic River; (g) the non-GE properties/areas subject to EREs; and (h) the properties/areas subject to Conditional Solutions. The applicable requirements and procedures for the future long-term monitoring at the Silver Lake Area, including reporting requirements, will be specified in the revised PRSCP/RPMMP to be included in the forthcoming Final Completion Report for the Silver Lake Area Removal Action.


Tables

3/4/2015G:\GE\GE_Silver_Lake\Reports and Presentations\2015-03 2014 Annual Report\Tables\0481511214_Table 2-1.xlsx Page 1 of 1

Species Quantity to be MonitoredI9-10-8Red-Osier Dogwood 112Northern Arrowwood 29Winterberry Holly 28Parcel Total 169I9-9-1Red-Osier Dogwood 42Northern Arrowwood 11Winterberry Holly 11Parcel Total 64I9-9-9Red-Osier Dogwood 16Northern Arrowwood 4Winterberry Holly 4Parcel Total 24I9-9-201Red-Osier Dogwood 62Northern Arrowwood 14Winterberry Holly 14Parcel Total 90I9-9-17Red-Osier Dogwood 34Northern Arrowwood 9Winterberry Holly 9Parcel Total 52I9-9-18, I9-9-19Red Maple 1Red-Osier Dogwood 27Northern Arrowwood 5Winterberry Holly 7Parcel Total 40I9-9-21, I9-9-22, I9-9-23Red-Osier Dogwood 55Northern Arrowwood 11Winterberry Holly 12Parcel Total 78I9-9-24Red-Osier Dogwood 18Northern Arrowwood 4Winterberry Holly 5Parcel Total 27I9-9-25, I9-9-26Red-Osier Dogwood 24Northern Arrowwood 5Winterberry Holly 7Parcel Total 36I9-9-27Red-Osier Dogwood 13Northern Arrowwood 3Winterberry Holly 4Arborvitae 5Red Oak 1Burning Bush 6Parcel Total 32I9-9-28Red-Osier Dogwood 16Northern Arrowwood 5Winterberry Holly 4Fraser Fir 2Burning Bush 3Parcel Total 30I9-9-29Red-Osier Dogwood 12Northern Arrowwood 3Winterberry Holly 3Arborvitae 11Privet 21Parcel Total 50I9-9-34Red-Osier Dogwood 64Northern Arrowwood 55Winterberry Holly 15Parcel Total 134

TOTALS 826

TABLE 2-1BASELINE QUANTITIES OF RESTORED VEGETATION IN THE NON-NATURAL RESOURCE

RESTORATION/ENHANCEMENT AREAS

2014 ANNUAL MONITORING REPORT FOR THE SILVER LAKE AREAGENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS

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Baseline on Monitoring Conducted May 27-29, 2014

Approximate DimensionsAverage Length

Average Width Area Total Total

Area Plot No. (ft) (ft) (ft2) BW SiM EC SuM RO RM Trees ROD SD WH CC NA NV SB BCB PW SA BB Shrubs

I9-10-9-1 65 11 730 0 0 0 0 0 0 0 20 0 4 0 5 0 0 0 0 0 0 29

I9-10-9-2 60 29 1,886 2 2 0 0 0 0 4 19 0 5 0 5 0 0 0 0 0 0 29

I9-9-36-1 59 41 2,322 0 0 0 0 0 0 0 26 2 10 3 9 1 2 2 0 0 0 55

I9-9-36-2 57 45 2,491 0 0 0 0 0 0 0 25 2 10 0 9 1 2 0 1 2 0 52

I9-9-36-3 61 33 1,878 0 0 0 0 0 0 0 23 1 8 2 7 0 1 0 2 2 0 46

I9-9-36-4 60 29 1,928 0 0 0 0 0 0 0 17 2 6 3 6 3 2 4 0 0 0 43

SSI-1 25 20 500 0 0 0 0 0 0 0 34 0 0 0 0 0 0 0 0 0 3 37

SSI-2 25 20 500 0 0 0 0 0 0 0 24 0 0 0 0 0 0 0 0 0 16 40

I9-9-35-1 59 51 2,965 0 0 0 0 0 0 0 17 2 5 1 5 2 1 3 1 1 0 38

I9-9-35-2 63 28 1,777 0 0 0 3 3 0 6 15 0 0 0 0 0 0 0 0 0 0 15

I9-9-35-3 59 34 2,172 0 0 0 2 2 1 5 15 0 0 0 0 0 0 0 0 0 0 15

I9-9-35-4 61 27 1,453 2 0 1 0 0 0 3 5 0 4 0 4 0 0 0 0 0 0 13

Species LegendBW = black willow ROD = red-osier dogwood SB = serviceberrySiM = silver maple SD = silky dogwood BCB = black chokeberryEC = eastern cottonwood WH = winterberry holly PW = pussy-willowSuM = sugar maple CC = choke cherry SA = speckled alderRO = red oak NA = northern arrowwood BB = buttonbushRM = red maple NV = nannyberry viburnum

I9-10-9 Area

I9-9-36 Area

Shrub-Scrub Island Area

I9-9-35 Area

Number of Trees Number of Shrubs

TABLE 3-1BASELINE QUANTITIES OF PLANTINGS IN NATURAL RESOURCE RESTORATION/ENHANCEMENT MONITORING PLOTS



Approximate Water Depth

Approximate Cap Thickness

(ft) (inches)SL-CAP-01-YR1 2 10/16/2014 8.9 12SL-CAP-02-YR1 10/20/2014 17.4 16.5SL-CAP-03-YR1 10/20/2014 9.1 15SL-CAP-04-YR1 10/16/2014 20 16SL-CAP-05-YR1 10/20/2014 18.2 15SL-CAP-06-YR1 10/17/2014 6.6 20SL-CAP-07-YR1 10/20/2014 11.6 14.5SL-CAP-08-YR1 10/17/2014 19.4 16SL-CAP-09-YR1 10/20/2014 24.1 17.5SL-CAP-10-YR1 10/17/2014 19.5 15SL-CAP-11-YR1 10/20/2014 6.6 14.5SL-CAP-12-YR1 10/17/2014 7.2 18.5SL-CAP-13-YR1 10/20/2014 24.4 18.5SL-CAP-14-YR1 10/17/2014 26.2 27SL-CAP-15-YR1 10/20/2014 24.6 19SL-CAP-16-YR1 10/17/2014 13.5 17SL-CAP-17-YR1 10/20/2014 4.8 14.5SL-CAP-18-YR1 10/20/2014 21.1 20SL-CAP-19-YR1 10/17/2014 7.0 15SL-CAP-20-YR1 10/17/2014 23 16SL-CAP-21-YR1 10/20/2014 9.8 21.5

TABLE 4-1CAP THICKNESS DATA FOR YEAR 1 (2014) POST-CONSTRUCTION SAMPLING


Core ID

Sample/Measurement

Date

Notes: 1. The TOP interval represents the top inch of material collected, including approximately 0.0'' to 0.5'' of deposited material, depending on the location.2. For SL-CAP-01-YR1, cap material was observed from 0-12'' and then again from 15-20'' (17'' total of cap material observed), with native material observed in between from 12-15''.3. Cores were collected by ARCADIS on and samples were processed by ARCADIS. Locations targeted for core collection were located approximately five feet north of the original during-construction core location or five feet north of the furthest-north during-construction coring location, whichever was further north, to reduce the potential for collecting a core from a previously-sampled location. 4. TOP, REM, and Mixing sample intervals were submitted to Pace Analytical Services for analysis of PCBs.

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Depth Date Aroclor-1016,Year 1

Post-ConstructionImmediate Post-

ConstructionSample ID (Inches) Interval Collected -1232, -1242 Aroclor-1221 Aroclor-1248 Aroclor-1254 Aroclor-1260 Total PCBs Total PCBs

SL-CAP-01-YR1 0-1 TOP 10/16/2014 ND(0.063) 0.20 J ND(0.063) ND(0.063) 0.053 J 0.253 J ND(0.059)1-10 REM 10/16/2014 ND(0.062) 0.044 J ND(0.062) ND(0.062) ND(0.062) 0.044 J 0.64

10-12 Mixing 10/16/2014 ND(0.062) 1.7 J 1.2 J 0.63 0.81 4.34 J 51.8SL-CAP-04-YR1 0-1 TOP 10/16/2014 ND(0.11) ND(0.11) 0.18 J 0.11 J 0.12 0.41 J ND(0.066)

1-14 REM 10/16/2014 ND(0.075) ND(0.075) ND(0.075) ND(0.075) ND(0.075) ND(0.075) ND(0.069)14-16 Mixing 10/16/2014 ND(0.072) 0.14 J 0.082 J ND(0.072) 0.047 J 0.269 J 0.294

SL-CAP-06-YR1 0-1 TOP 10/17/2014 ND(0.077) ND(0.077) ND(0.077) ND(0.077) ND(0.077) ND(0.077) 0.050 J1-18 REM 10/17/2014 ND(0.066) ND(0.066) ND(0.066) ND(0.066) ND(0.066) ND(0.066) 0.081

18-20 Mixing 10/17/2014 ND(0.068) J 0.38 J 0.20 J 0.063 J 0.11 J 0.753 J 3.93SL-CAP-08-YR1 0-1 TOP 10/17/2014 ND(0.10) ND(0.10) 0.17 J 0.10 J 0.095 J 0.365 J ND(0.063)

1-14 REM 10/17/2014 ND(0.070) ND(0.070) ND(0.070) 0.050 J ND(0.070) 0.050 J ND(0.069)14-16 Mixing 10/17/2014 ND(0.076) 0.18 J 0.16 J 0.059 J 0.054 J 0.453 J 0.154

SL-CAP-10-YR1 0-1 TOP 10/17/2014 ND(0.099) ND(0.099) ND(0.099) ND(0.099) ND(0.099) ND(0.099) ND(0.074)1-13 REM 10/17/2014 ND(0.082) ND(0.082) ND(0.082) ND(0.082) ND(0.082) ND(0.082) ND(0.069)

13-15 Mixing 10/17/2014 ND(0.070) 0.061 J ND(0.070) ND(0.070) ND(0.070) 0.061 J 0.314SL-CAP-12-YR1 0-1 TOP 10/17/2014 ND(0.065) ND(0.065) 0.042 J 0.040 J ND(0.065) 0.082 J ND(0.058)

1-16.5 REM 10/17/2014 ND(0.061) ND(0.061) 0.047 J ND(0.061) ND(0.061) 0.047 J 0.73416.5-18.5 Mixing 10/17/2014 ND(0.068) 0.42 J 0.086 0.047 J ND(0.068) 0.553 J 2.06

SL-CAP-14-YR1 0-1 TOP 10/17/2014 ND(0.14) ND(0.14) 0.49 0.34 0.39 1.22 0.041 J1-25 REM 10/17/2014 ND(0.094) ND(0.094) ND(0.094) ND(0.094) ND(0.094) ND(0.094) 0.043 J

25-27 Mixing 10/17/2014 ND(0.065) J ND(0.065) J 0.099 0.084 ND(0.065) J 0.183 J 1.1SL-CAP-16-YR1 0-1 TOP 10/17/2014 ND(0.086) ND(0.086) 0.25 0.16 0.16 0.57 ND(0.064)

1-15 REM 10/17/2014 ND(0.062) ND(0.062) ND(0.062) ND(0.062) ND(0.062) ND(0.062) ND(0.061)15-17 Mixing 10/17/2014 ND(0.060) J ND(0.060) J 0.084 0.041 J 0.044 J 0.169 J 6.39


13-15 Mixing 10/17/2014 ND(0.063) 0.091 J 0.58 0.5 0.26 1.43 J 1.63SL-CAP-20-YR1 0-1 TOP 10/17/2014 ND(0.083) ND(0.083) 0.080 J 0.055 J ND(0.083) 0.135 J 0.025 J

1-14 REM 10/17/2014 ND(0.074) ND(0.074) ND(0.074) ND(0.074) ND(0.074) ND(0.074) ND(0.067)14-16 Mixing 10/17/2014 ND(0.069) J ND(0.069) J ND(0.069) J ND(0.069) J ND(0.069) J ND(0.069) J 0.747

Notes:

GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS(Results are presented in dry weight parts per million)

TABLE 4-2PCB DATA FOR YEAR 1 (2014) POST-CONSTRUCTION SAMPLING AND IMMEDIATE POST-CONSTRUCTION RESULTS

2014 ANNUAL MONITORING REPORT FOR THE SILVER LAKE AREA

1. Samples were collected by ARCADIS and submitted to Pace Analytical Services Inc. for analysis of PCBs.2. Year 1 samples have been validated as per Field Sampling Plan/Quality Assurance Project Plan (FSP/QAPP), General Electric Company, Pittsfield, Massachusetts, ARCADIS (revised on July 2 , 2013 and approved by EPA on July 23, 2013).3. ND - Analyte was not detected. The number in parentheses is the associated reporting limit.

Data Qualifiers:J - Indicates that the associated numerical value is an estimated concentration.


Sample IDSample

LocationDate

CollectedAroclor-1016,-1232 (ppb)

Aroclor-1221 (ppb)

Aroclor-1242 (ppb)

Aroclor-1248 (ppb)

Aroclor-1254 (ppb)

Aroclor-1260 (ppb)

Total PCBs(ppb)

Total SuspendedSolids (ppm)

Conductivity (mS/cm)

pH (Standard Units)

Sample Depth(ft)

Turbidity (ntu)

WaterTemperature (°C)

01/28/14 Unfiltered ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J) 1.7 0.723 7.85 0.36 6 2.40 50

02/20/14 Unfiltered ND(0.022 J) 0.038 J ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J) 0.038 J 1.2 0.797 7.23 0.20 3 1.67 56

Unfiltered ND(0.022 J) 0.044 J ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J) 0.044 JFiltered ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J)

Unfiltered ND(0.0055 J) 0.041 J 0.014 J ND(0.0055 J) 0.0081 J ND(0.0055 J) 0.0631 JFiltered ND(0.0055 J) 0.022 J ND(0.0055 J) ND(0.0055 J) ND(0.0055 J) ND(0.0055 J) 0.022 J


Unfiltered ND(0.0055 J) 0.044 J ND(0.0055 J) 0.03 J 0.016 J 0.007 J 0.097 JFiltered ND(0.0055 J) 0.042 J 0.013 J ND(0.0055 J) ND(0.0055 J) ND(0.0055 J) 0.055 J


Unfiltered ND(0.0055 J) 0.066 J ND(0.0055 J) 0.035 J 0.019 J 0.0089 J 0.129 JFiltered ND(0.0055 J) 0.035 J 0.012 J ND(0.0055 J) ND(0.0055 J) ND(0.0055 J) 0.047 J

Unfiltered ND(0.0055 J) 0.056 J ND(0.0055 J) 0.025 J ND(0.0055 J) ND(0.0055 J) 0.081 JFiltered ND(0.0055 J) ND(0.033 J) ND(0.0055 J) 0.0068 J ND(0.0055 J) ND(0.0055 J) 0.0068 J

Unfiltered ND(0.0055 J) 0.045 J ND(0.0055 J) 0.017 J ND(0.0055 J) ND(0.0055 J) 0.062 JFiltered ND(0.0055 J) 0.03 J ND(0.0055 J) 0.0034 J ND(0.0055 J) ND(0.006 J) 0.0334 J

Unfiltered ND(0.0055 J) 0.046 J ND(0.0055 J) 0.019 J ND(0.0055 J) ND(0.0055 J) 0.065 JFiltered ND(0.0055 J) 0.025 J 0.0076 J ND(0.0055 J) ND(0.0055 J) ND(0.0055 J) 0.0326 J

Unfiltered ND(0.0055 J) 0.039 J ND(0.0055 J) 0.0069 J ND(0.0055 J) ND(0.0055 J) 0.0459 JFiltered ND(0.0055 J) 0.021 J 0.0035 J ND(0.0055 J) ND(0.0055 J) ND(0.0055 J) 0.0245 J

Notes:1. Flow indicated in cubic feet per second (cfs) as recorded upstream at the U.S. Geological Survey (USGS) River Gage Station No. 01197000 on the East Branch of the Housatonic River in Coltsville, MA.2. On 01/28/14, turbidity was greater than 5 NTU, no rainfall was recorded during the 24 hour period prior to sample collection.3. On 03/27/14, turbidity was greater than 5 NTU, no rainfall was recorded during the 24 hour period prior to sample collection.4. On 04/24/14, turbidity was greater than 5 NTU, less than 0.05 inches of rainfall were recorded during the 24 hour period prior to sample collection.5. On 06/26/14, turbidity was greater than 5 NTU, about four inches of rainfall were recorded during the 24 hour period prior to sample collection.

7. Samples were collected by ARCADIS, and submitted to Pace Analytical Services for analysis.8. ND - Analyte was not detected. The number in parentheses is the associated reporting limit.9. J - Indicates an estimated value.10. NA - Analyte was not analyzed / Parameter was not recorded.

03/27/14

TABLE 5-1SURFACE WATER MONITORING RESULTS


Parameter

7 J

8.4

5.1

9.1

12/16/14

11/19/14

10/30/14

09/25/14

08/27/14

07/22/14

06/26/14

05/21/14

04/24/14

2.2

3.7

4.0

3.8

7.4

102

0.806 7.20 0.45 3 1.88 149

0.810 NA 0.80 4 4.88

22

0.812 6.84 0.40 4 11.28 146

0.754 7.59 0.40 3 18.37

40

0.660 8.54 1.3 2 25.33 36

0.657 8.84 0.40 5 26.53

970

0.890 8.53 0.40 3 19.31

0.695 8.39 1.1 9 24.24

0.45 7 11.06 84

84

6. Sampling method involved the collection of a grab sample at the location, representative of 50 percent of the total river width at 50 percent of the total river depth.

Flow (cfs)1

Outfall to the Housatonic

RiverLOCATION-4A

Field MeasurementsConventional ParametersUnfiltered or Filtered

PCB

595.2461.37.890.7744.2

0.938 7.60

Figure

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SL-CAP-6

SL-CAP-7

SL-CAP-8

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SL-CAP-13

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SL-CAP-16

SL-CAP-20

SL-CAP-18

SL-CAP-17

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I9-9-36-3

I9-9-36-1

I9-9-36-4

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I9-9-36-2

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LONG-TERM INSPECTION AREAS/ITEMS

AND MONITORING LOCATIONS

GENERAL ELECTRIC COMPANYPITTSFIELD, MASSACHUSETTS

2014 ANNUAL MONITORING REPORT

FOR SILVER LAKE AREA

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Appendices

Appendix A

Previously Submitted Reports from 2014 Inspection/Monitoring Activities

Table of Contents

Appendix A

• May 23, 2014 SL Revised Completion of Installation of Restoration Work Report

• June 25, 2014 SL Initial Post-Remediation Inspection and Spring 2014 Inspection of Shoreline Armor System, Backfilled/Restored Areas Adjacent to Silver Lake, and Non-Natural Resource Restoration/Enhancement Plantings

• October 2, 2014 SL Natural Resource Restoration/Enhancement (NRRE) Installation Inspection and Spring 2014 Inspection of NRRE Plantings – Revised Report

• October 3, 2014 SL Summer 2014 Inspection of Shoreline Armor System, Backfilled/Restored Areas Adjacent to Silver Lake, and Non-Natural Resource Restoration/Enhancement Plantings

• October 31, 2014 SL Summer 2014 Inspection of Natural Resource Restoration/Enhancement Measures

• December 17, 2014 SL Summary of 2014 Annual ERE Inspection Activities

• December 17, 2014 SL Summary of 2014 Conditional Solution Inspection Activities

• December 29, 2014 SL 2014 Monitoring of Cap Thickness and Integrity, Cap Isolation Layer, Deposition on Cap, and Sediment Collection Traps

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May 23, 2014 SL Revised Completion of Installation of Restoration Work Report

Transmitted via Overnight Courier

May 23, 2014

Ms. Karen Pelto Lead Administrative Trustee Bureau of Waste Site Cleanup Massachusetts Department of Environmental Protection One Winter Street, 8th Floor Boston, Massachusetts 02108

Re: GE-Pittsfield/Housatonic River Site Silver Lake Area (GECD600)

Andrew T. Silfer

GE 319 Great Oaks Blvd. Albany, NY 12203

T 518 862 2703 F 518 862 2731 andrew .silfer@corporate .ge .com

Revised Completion oflnstallation of Restoration Work Report

Dear Ms. Pelto:

On February 3, 2014, the General Electric Company (GE) submitted a Completion of Installation of Restoration Work Report, pursuant to Paragraph 120 of the Consent Decree (CD) for the GEPittsfield/Housatonic River Site, to summarize the natural resource restoration/enhancement (NRRE) measures installed at the Silver Lake Area Removal Action Area (RAA) under the CD. On March 14, 2014, the U.S. Environmental Protection Agency (EPA) provided GE with comments on that report; and on April 1, 2014, you sent GE a letter, on behalf of the natural resource trustees (Trustees) for this Site, with comments on the report. In response to those comments and subsequent discussions among GE, EPA, and the Trustees, GE has revised the report and is submitting this revised Completion of Installation of Restoration Work Report. This revised report describes the Performance Standards and other requirements applicable to the installation of NRRE measures at the Silver Lake Area, the NRRE measures installed by GE, and the monitoring and maintenance activities for those measures.

I. Performance Standards and Other Requirements for Installation of NRRE Measures at Silver Lake

Section 118.c of the CD and Sections 6 and 7 of Technical Attachment I to the associated Statement of Work for Removal Actions Outside the River (SOW) set forth the Performance Standards and other requirements for the implementation of a number of NRRE activities in and around Silver Lake (Figure 1). These NRRE activities were described in detail in Attachment I to the SOW, as modified by the Eighth Modification to the CD (approved by the Court on June 23, 2008). As provided in those documents, these Performance Standards and requirements generally included the following:

• Creation of a shallow-water shelf along the shorelines of the lake to provide an improved habitat for aquatic species, with this shelf to consist of a stone armoring layer with a three-inch layer of gravel and sand over the armoring stone to facilitate fish usage;

Ms. Karen Pelto May 23, 2014

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• Funding of activities in the amount of $75,000 to be performed by the Trustees for restoration work related to fish removal in Silver Lake;

• Capping the shrub-scrub "island" or peninsula near the discharge outfall and, following installation of the cap, planting of appropriate wetlands vegetative species on the surface of the cap;

• Construction of a walking path and picnic areas on non-privately owned areas along the eastern and northern sides of the lake; and

• Planting of a line of trees along the banks on the non-privately owned recreational areas on the eastern and northern sides of the lake, with an understory community of shrubs in patches, and planting of herbaceous species on the remaining banks where response actions are conducted.

As described in the August 2011 Revised Final Removal Design/Removal Action Work Plan for Silver Lake Area (Revised Final Work Plan), it was subsequently agreed among GE, EPA, and the Trustees that certain modifications were to be made to these standards, including the installation of park benches in lieu of picnic areas along the walking path and some changes in the configuration and species of the shrubs and trees to be planted on the eastern and northern sides ofthe lake.

The design details associated with the NRRE features at the Silver Lake Area, including a planting plan for the NRRE areas, were provided in the Revised Final Work Plan.1 The design was conditionally approved by EPA in a letter to GE dated August 25, 2011. Subsequently, the parties executed the Eleventh Modification to the CD (approved by the Court on September 13, 2012), which set forth certain modifications to the CD's Performance Standards for natural resource plantings around Silver Lake to modifY their height and placement to minimize impairment of solar power generation at a solar power generation facility across Silver Lake Boulevard. Further, in September 2013, during installation of NRRE measures on the northern and eastern sides of the lake, EPA and the City of Pittsfield proposed a revised tree/shrub planting plan to GE. Based on this plan, GE submitted a revised planting proposal to EPA in October 2013, and it was approved by EPA after consultation with the Trustees.

It should also be noted that, in order for the walking path and plantings on the recreational areas on the northern and eastern banks of the Lake to be located on non-privately owned land, the Pittsfield Economic Development Authority (PEDA) acquired the property on the northern bank of the Lake through a deed dated June 11, 2012 (recorded in the Berkshire Middle District Registry of Deeds in Book 4975, Page 87) and an order of taking dated November 8, 2012 (recorded in that Registry of Deeds in Book 5073, Page 239); and it acquired the property on the eastern bank of the Lake, previously owned by GE, by deed dated April 30, 2014 (recorded in the Registry of Deeds on May 8, 2014 in Book 53 73, Page 184 ). PEDA subsequently granted an easement on these properties to the City of Pittsfield (by agreement recorded on May 23,2014 in Book 5380, Page 318) for use and maintenance ofthe walking path and associated structures.

II. NRRE Measures Installed by GE

As discussed above, the Revised Final Work Plan, including the NRRE measures proposed for Silver Lake, was conditionally approved by EPA in a letter to GE dated August 25, 2011. The EPA-approved Removal Action was subsequently performed by GE between July 2012 and December 2013. To satisfY

1 The Revised Final Work Plan also provided that GE would place large woody debris (LWD) at certain selected locations on the shallow-water shelf along the shorelines, as necessary to replace any such debris that was removed to facilitate the remediation. Further details regarding the placement of L WD were provided in GE's Revised Supplemental Information Package, submitted in May 2012. The placement ofLWD, however, was not part ofthe NRRE measures for the Silver Lake Area.

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the above-described Performance Standards and requirements, GE conducted the activities described below for the areas subject to NRRE measures at the Silver Lake Area. Figure 1 shows the approximate locations of these features.2

Shallow-Water Shoreline Shelf I Gravel Habitat Layer

Following the prescribed removal of certain soil/sediment materials and placement of the armor stone layer around the perimeter of Silver Lake, an approximate three-inch layer of gravel and sand (i.e., a gravel habitat layer) was placed over the armor stone. The near-shore area where this gravel habitat layer was placed consists of the underwater extent of the armor stone layer in areas where an approximate minimum four-inch water depth could be maintained following placement. This approximate three-inch gravel habitat layer consists of processed sand and gravel with a material diameter of two inches or less, with approximately 80-96% of materials exhibiting a diameter of less than one inch and 3-15% of the materials having a diameter less than 0.003 inch. Note that this grain size distribution reflects an agreement between GE and EPA during construction that, due to material availability, the acceptable gradation range for the gravel habitat material could be expanded slightly from that proposed in the Revised Final Work Plan. Specifically, the gradation results for representative samples collected from material proposed for use as the gravel habitat layer were submitted to EPA on December 19, 2012; and EPA replied on December 20, 2012 that this material was acceptable for use as gravel habitat layer material.3

In accordance with the Revised Final Work Plan, the gravel habitat layer placed on the shallow-water shoreline shelf was monitored approximately one month after the placement of such materials (or, for certain areas where the material was placed in late 2012 prior to the freezing of Silver Lake, after the 2013 spring thaw) to confirm that the shallow-water shelf/gravel habitat layer was three inches thick at that time. As the near-shore restoration was completed in phases, monitoring of the gravel habitat layer was performed on a number of occasions during construction, with results provided to EPA after each event. This monitoring was conducted through probing activities in areas between designated transects. The approximate locations of the transects between which the probing was performed are illustrated on Figure 1. In certain locations, where the initial monitoring indicated that the material placed did not meet the three-inch requirement, additional material was placed, and final monitoring was subsequently performed. A summary of the results of the final post-placement monitoring events is provided in attached Table 1. As indicated in that table, final monitoring confirmed that the shallow-water shelf/gravel habitat layer was three inches or more thick one month or more after the completion of final placement in each area. Accordingly, the Performance Standard for this NRRE feature was met or exceeded.

Shrub-Scrub Island

Foljowing cutting of vegetation (at the ground surface) and removal of such vegetation and other debris from the shrub-scrub island, a non-woven geotextile fabric and overlying 18-inch cap were placed over the extent of the shrub-scrub island, with armor stone placed around the perimeter. The Revised Final Work Plan stated that this cap would be composed of two separate layers - an approximate 10-inch

2 GE paid the required $75,000 to the Trustees shortly after the Court's entry of the CD. The allocation of this money was specified in the Eighth CD Modification (approved by the Court on June 23, 2008), which changed the allocation of the $75,000 paid to the Trustees so that all of those funds were to be devoted to the removal of a portion of the existing contaminated fish community. 3 It should also be noted that, although not part of the NRRE measures, L WD was placed in selected locations on this shallow-water shelf.

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isolation layer of cap material covered by an eight-inch layer of topsoil. However, GE demonstrated in a submission to EPA on November 6, 2012 that the material previously approved for use as near-shore cap material met the specifications for both the isolation layer and the topsoil layer, and it thus proposed to use that single type of material for the full 18-inch layer of material placed over the shrub-scrub island. EPA approved this proposal on November 14, 2012; and the capping was subsequently performed, followed by placement of armor stone around the perimeter of the island.

Once the 18-inch layer of material was installed over the shrub-scrub island, the area was planted with a mixture of red-osier dogwood and buttonbush shrubs. A total of approximately 1,320 red-osier dogwoods were planted mainly in the drier area of the island (i.e., the area with higher elevation along the perimeter of the island), while approximately 285 buttonbush shrubs were planted in the middle of the island in areas of lower elevation (i.e., the more wet areas). A grass seed mix of herbaceous wetland species (i.e., New England Wetmix), which included species such as American manna grass, fringed sedge, fox sedge, lurid sedge, spotted joe-pye-weed, green bulrush, hop sedge, boneset, wool grass, bristly/cosmos sedge, blue vervain, and blunt broom sedge, was planted in the section of the island in which the shrubs were planted.

As specified in Attachment I of the SOW, for those areas of the shrub-scrub island where installed armoring is present above the mean water surface elevation of 975.9 feet National Geodetic Vertical Datum of 1929 (NGVD29), the exposed voids in the stone were filled with topsoil and seeded with the mixture of herbaceous wetland species discussed above. The periphery of the island was planted with an emergent mixture of a total of approximately 300 each of soft-stem bulrush, soft rush, and blue-flag iris.

Walking Path and Benches

Following the performance of soil removal activities, and as part of the associated restoration of the banks, a walking path was built in the recreational areas around the eastern and northern sides of the lake along the approximate top of bank in general alignment with the adjacent Silver Lake Boulevard. Construction of the walking path consisted of the following (from bottom to top): placement of a woven textile fabric; installation of approximately 11 inches of a crushed stone subbase; and installation of a finished paved surface consisting of a three-inch layer of porous bituminous asphalt. The walking path was constructed such that the finished surface is pitched away from the lake, thus minimizing the potential for direct runoff to the lake.

During the course of walking path construction, nine viewshed locations immediately adjacent to the walking path on the northern and eastern sides of the path (i.e., between the walking path and Silver Lake Boulevard) were cleared, re-graded to a level grade, and finished with a concrete slab. Benches were subsequently installed at these locations.

Plantings in Recreational Areas on Northern and Eastern Banks

Following the performance of the soil removal and subgrade backfill activities in the recreational areas on the northern and eastern sides of the lake, the top six inches in areas subject to installation of NRRE plantings were backfilled with a six-inch layer of topsoil. As discussed above, during installation of NRRE measures in these the recreational areas, the tree/shrub planting plan was modified at the request of EPA and the City of Pittsfield. In accordance with the applicable requirements, including the modifications requested by EPA and the City, shrub and tree species were installed along these recreational areas in the arrangements described below. The general locations of the NRRE plantings are

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shown on Figure 1, and more detailed plans showing the plantings as installed are provided as Figures 2 and 3.4

• A single row of approximately 340 red-osier dogwoods was installed at the top of the armor stone layer from just east of the Fourth Street outfall to the approximate western edge of the shrub-scrub island (Figure 2) and from the approximate eastern edge of the shrub-scrub island to the southeastern terminus of the walking path (Figure 3). No red-osier dogwoods were installed within the areas identified as viewsheds associated with the nine bench locations.

• A double row of shrubs consisting of a bottom row of red-osier dogwoods and a top row containing a mixture of red-osier dogwoods, northern arrowwoods, and winterberry hollies (comprising a total of approximately 130 shrubs in both rows together) was installed at the top of the armor stone layer along the northwestern shore of the lake adjacent to Fourth Street (except for a narrow section where a single row was planted instead) (Figure 2).

• A single row of shrubs consisting of a mixture of approximately 40 each of red-osier dogwoods, northern arrowwoods, and winterberry hollies was installed at the top of the armor stone layer from the southeastern terminus of the walking path to the boundary with Tax Parcel I9-9-34 (Figure 3).

• Oblong patches of shrubs were planted on the southern side of the walking path between the Fourth Street outfall and the approximate western edge of the shrub-scrub island (Figure 2) and along a section of the northeastern corner of Silver Lake starting from the approximate eastern edge of the shrub-scrub island (Figure 3). Each patch includes approximately 16 plants consisting of an equal mix of red-osier dogwoods, northern arrowwoods, and winterberry hollies, with no more than six of one species per patch. In total, approximately 140 each of red-osier dogwoods, northern arrowwoods, and winterberry hollies were planted in these oblong patches. No oblong patches were installed within the areas identified as viewsheds associated with the nine bench locations.

• Clusters of trees and shrubs were planted in dense clumps on the northern and southern sides of the walking path in the same areas where the oblong patches of shrubs were installed (see above description and Figures 2 and 3). Each cluster, consisting of no more than approximately 10 plants, includes a random mix of species, depending on soil type- i.e., nannyberry viburnum, serviceberry, silky dogwood, black chokeberry, choke cherry in dry soil areas; and pussy-willow and speckled alder in moist soil areas.5 In total, approximately 35 each of the nannyberry viburnum, serviceberry, silky dogwood, black chokeberry, and choke cherry shrubs and approximately 15 each of the pussywillow and speckled alder trees were planted in the clusters. These clusters were planted in the following areas, but with gaps maintained in front of the bench locations to allow an unobstructed view ofthe lake:

o North of the walking path near the Fourth Street outfall (Figure 2);

o South of the walking path between the Fourth Street outfall and just to the east of the second bench to the east of the shrub-scrub island (Figures 2 and 3); and

4 For the following descriptions of the areas of installed plants, a clockwise direction around Silver Lake is assumed (see Figures 1, 2, and 3). 5 The dry soil areas were distinguished from the wet soil areas by the approximate elevation contour of 980.0 feet NGVD29.

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o North of the walking path in the area between the first two benches to the east ofthe shrub-scrub island (Figure 3).

• In addition to these shrubs and short trees, a single row of taller tree species was planted at the approximate top of bank along the northwestern end of the lake adjacent to Fourth Street and along the eastern end of the lake. Tree species planted included black willow, silver maple, sugar maple, red oak, red maple, and eastern cottonwood as follows:

o A total of eight trees including black willows, silver maples, and eastern cottonwoods were planted in the area extending from the boundary of the northern recreational area with Tax Parcels I9-l 0-1 0 and I9-1 0-8 clockwise around the shoreline of Silver Lake to the Fourth Street outfall (i.e., the area adjacent to Fourth Street) (Figure 2).

o A total of 30 trees including sugar maples, red oaks, and red maples were planted in the area extending from the northeastern corner of Silver Lake to the southeastern terminus of the walking path (Figure 3).

o A total of 14 trees including black willows and eastern cottonwoods were planted in the area extending from the southeastern terminus of the walking path to the boundary with Tax Parcel I9-9-34 (Figure 3).

Following the installation of the trees and shrubs, these areas were seeded with the appropriate herbaceous ground cover seed mix (i.e., New England Conservation/Wildlife Seed Mix in upland areas and the New England Wetmix in wetland areas),6 with the exception of the area between the walking path and Silver Lake Boulevard and an approximately three-foot wide strip along the lake side of the walking path, both of which were seeded with a stabilization seed mix approved by EPA in the field (which includes Kentucky bluegrass, Kentucky B 1 tall fescue, timothy, orchard grass, birdsfoot trefoil, and white clover).

III. Monitoring and Maintenance of NRRE Measures

The CD and SOW require monitoring and maintenance of the NRRE measures installed at the Silver Lake Area. Specifically, Paragraph 119 of the CD requires the preparation of a Restoration Project Monitoring and Maintenance Plan for NRRE measures. The Performance Standards and other requirements for such monitoring and maintenance were set forth in Section 8 of Attachment I to the SOW, EPA's December 17, 2009 conditional approval letter forGE's July 2, 2009 response to the Trustees' comments regarding NRRE measures for the Silver Lake banks, EPA's July 9, 2010 conditional approval letter for the January 2010 Final Removal Design/Removal Action Work Plan, and EPA's August 25, 2011 conditional approval letter for the August 20 II Revised Final Work Plan. In satisfaction of those requirements (as well as the separate requirements for Post-Removal Site Control activities), GE submitted a Post-Removal Site Control Plan/Restoration Project Monitoring and Maintenance Plan (PRSCPIRPMMP) as Appendix I of the Revised Final Work Plan. That plan included (in Section 3) a description of the monitoring and maintenance activities to be conducted for the NRRE measures installed at the Silver Lake Area. Subsequently, the applicable requirements for monitoring of the NRRE measures were modified in certain respects based on developments after EPA's approval of the Revised Final Work Plan, and the specific

6 The upland areas were distinguished from the wetland areas by the approximate elevation contour of 980.0 feet NGVD29. The New England Conservation/Wildlife Seed Mix mixture includes species such as Virginia wild rye, little bluestem, big bluestem, creeping red fescue, switch grass, partridge pea, deer tongue, Indian grass, common milkweed, and ox eye sunflower. The New England Wetmix is described above.

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requirements relating to the NRRE plantings have been further refined and supplemented through recent discussions among GE, the Trustees, and EPA stemming from review of the initial version of this Completion of Installation of Restoration Work Report

This section of the revised report provides a summary of the updated monitoring and maintenance requirements for the NRRE measures. Following the Trustees' approval, the requirements set forth in this section will govern the NRRE monitoring and maintenance activities at this RAA until such time as they are superseded by the comparable requirements presented in the Final Completion Report (FCR) for the Silver Lake Area Removal Action. These activities will be conducted under the oversight of the Trustees. The approximate locations of the NRRE areas subject to inspection are illustrated on Figure 1.

Periodic Inspections

As discussed in Section II above, the gravel habitat layer placed on the shallow-water shoreline shelf was monitored approximately one month or more after the placement of such materials to confirm that the shallow-water shelf/gravel habitat layer was at least three inches thick. As further discussed in that section and shown in Table 1, the final monitoring confirmed that the shallow-water shelf/gravel habitat layer was three inches or more thick one month or more after the completion of final placement in each area, thus meeting or exceeding the applicable Performance Standard. Accordingly, no further inspections of this NRRE feature are required.

For the NRRE plantings on the shrub-scrub island and on the northern and eastern sides of the lake, GE will conduct periodic inspections of those plantings. This monitoring program will consist of two visits during each of the first three years after planting, one visit during the fifth year after planting, and one visit during the seventh year after planting. In each of the first three years after planting, visits will be conducted in the late spring after the first leaf flush (May or June) and in the summer (July or August) to assess plant survival. The single visit in the fifth year and seventh year will be conducted in the summer (July/August). GE will provide EPA, MDEP, and the Trustees with a minimum 14-day notification prior to conducting any inspections ofthese NRRE areas.

Based on discussions with the Trustees and EPA, each of these monitoring visits will consist of both a qualitative field inspection of the NRRE areas where plantings were installed and a quantitative assessment (i.e., counts) of the plantings within specific monitoring plots established within the NRRE areas, as described further below. Personnel conducting the inspection will be supported by a certified arborist.

For the qualitative assessment, field personnel will conduct a meander survey of the overall NRRE planting areas. The meander survey will involve traversing the areas on foot to observe overall conditions within the NRRE planting areas. This qualitative assessment will note within the NRRE areas any indications of damage from trespassing or herbivory and/or the presence of invasive species, as listed in Table 2 (or any others listed by the Massachusetts Invasive Plant Advisory Group [MIPAG] as "invasive," "likely invasive," or "potentially invasive").

During each monitoring event, the certified arborist will inspect the planted vegetation for apparent vigor and growth, using best professional judgment based on accepted restoration standards and familiarity with local planting conditions, and will make recommendations to GE and the Trustees in the event that he or she concludes that the vegetation on average is not growing at an acceptable rate. These inspections will include a visual assessment of the areas of the shrub-scrub island where topsoil was placed and herbaceous vegetation was seeded in the void spaces of the exposed armor stone above the elevation of 975.9 feet (as described in Section II above), to assess the growth and condition of that vegetation.

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The quantitative assessment will be conducted within designated monitoring plots established within four monitoring areas in the overall NRRE areas. The four monitoring areas will consist of three areas that are co-extensive with the three tax parcels that comprise the NRRE areas (i.e., Parcels I9-l 0-9, I9-9-36, and 19-9-35) plus the shrub-scrub island. Within each monitoring area, monitoring plots have been established based on the size and types of plantings in each area, as follows:

• Parcel 19-10-9 Area - two monitoring plots, each approximately 60 feet long, bounded by Fourth Street on the northwest and the lake on the southeast, with one plot including the row of four trees on the furthest northeastern side of the parcel;

• Parcel 19-9-35 Area (excluding the overlap with the shrub-scrub island area)- four monitoring plots, each approximately 60 feet long, in the area between the lake and Silver Lake Boulevard;

• Parcel I9-9-36 Area (excluding the overlap with the shrub-scrub island area)- four monitoring plots, each approximately 60 feet long, bounded by Silver Lake Boulevard on the north and the lake on the south; and

• Shrub-Scrub Island Area - two monitoring plots, each approximately 500 square feet, one on each peninsula.

These monitoring areas and the anticipated locations of the monitoring plots are shown on Figure 4. The actual boundaries of the monitoring plots will be established in the field during the installation inspection and meeting (discussed below in Section IV), and information specific to each plot (i.e., size, baseline stem counts [by species]) will be provided in the FCR for the Silver Lake Area Removal Action.

For the quantitative assessment, field personnel will conduct the following activities within each designated monitoring plot: (a) perform a stem count of planted trees and shrubs to identifY live and dead plantings (as well as any stressed plantings); (b) estimate the areal extent of groundcover by native herbaceous species; and (c) determine the presence of, and estimate percent coverage by, invasive species, as listed in Table 2 (or any others listed by the MIPAG as "invasive," "likely invasive," or "potentially invasive"). Based on this quantitative assessment, the number of live and dead trees and shrubs in each monitoring plot will be determined, and the survival results for the monitoring plots within each monitoring area will be averaged to calculate the percent survival of trees and shrubs (as applicable) in that monitoring area. Similarly, the results for areal coverage by native herbaceous species and by invasive species in the monitoring plots within each monitoring area will be combined to determine the areal coverage by native herbaceous species and the percent coverage by invasive species in that area.

In addition, GE will conduct the inspections of the walking path and benches on a yearly basis for three years after installation. These inspections will include visual observations of these features to assess their presence, integrity, condition (e.g., cracked or missing bench pieces, pavement cracks/heaves), and ability to function as intended. Any issues will be identified in GE's reports on the inspections (as described in the Reporting section below). Following this three-year period, any necessary inspections of the walking path and bench will be the responsibility of PEDA (as the property owner) or the City (as easement holder).

The inspections of the NRRE areas and measures will utilize an inspection checklist and associated field form and summary tables. Interim versions of the checklist and associated field form and summary tables are provided as Exhibit A; the final checklist, associated field form, and summary tables will be provided in the FCR for this Removal Action.

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Maintenance and Repair Activities

Ms. Karen Pelto May 23, 20I4

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Based on the results of the NRRE inspection activities described above, maintenance and repair activities will be performed where necessary as described below.

For any monitoring area where the results of the quantitative tree/shrub assessment show an average survival rate for trees or shrubs of less than 80% of the original planting, the dead trees or shrubs in excess of20% of that planting will be replaced. In addition, as directed by EPA in its December I7, 2009 conditional approval letter regarding the bank NRRE measures, if two or more adjacent trees are found to have died during the monitoring period, GE will replant the required species as necessary to avoid the situation of such adjacent dead trees. If trees and/or shrubs are replanted, GE will equip the replanted trees and shrubs with a tag identifying the species of tree or shrub, the installation date, and the size at the time of installation. Further, in the event that the assessment shows a loss of plantings or growth failure over an area of 1,14 acre or more, GE will replant that area, and will restart the timing for monitoring and inspections of that area once actions to replant the lost vegetation have been completed. However, GE will not be required to replant an area if the loss of vegetation or growth failure is caused solely by the actions of a third party, excluding GE contractors.

For any monitoring area where the results of the quantitative assessment of areal herbaceous coverage show less than I 00% areal coverage by native herbaceous species (outside the foliar coverage of the trees), the planting area(s) showing bare ground will be re-seeded with the same seed mix used for the original seeding in that area (or an approved equivalent seed mix). In the event that the results show any monitoring area with greater than 5% coverage by invasive species (as listed in Table 2 or any others listed by the MIPAG as "invasive," "likely invasive," or "potentially invasive"), the invasive species will be treated with an appropriate herbicide.

Additionally, in the event that the quantitative or qualitative assessment of the planting areas indicates the need for other maintenance activities, such as additional fertilization or watering, placement of additional topsoil and re-seeding, and/or implementation of measures to reduce herbivory, such activities will be

7 performed as necessary.

In addition to the above-described response actions, GE will implement a general invasive species control program for these NRRE areas, focusing on the invasive species listed in Table 2, as well as any others listed by the MIPAG as "invasive," "likely invasive," or "potentially invasive." This program will include a walking survey prior to new growth in the spring, focused on noting the location of encroaching invasive plants normally hidden by late season heavy or tall herbaceous growth. Starting in the spring and continuing through the fall, these re-vegetated and shoreline areas will be inspected for invasive species periodically, depending on rainfall and seasonal growth patterns, and treatment of such species will be applied as necessary during those inspections. At the end of the second year of the program (i.e., in 20 15), GE will evaluate the need for appropriate modifications to this program and will propose any such modifications to the Trustees. However, it is anticipated that the invasive species control program for these NRRE areas will continue through the final year of the seven-year NRRE monitoring program (described above).

7 In evaluating the herbaceous vegetation planted in the void spaces of the exposed armor stone on the shrub-scrub island, GE will take into account the extent to which the armor stone itself prevents coverage by herbaceous vegetation, and additional topsoil and/or seeding will be placed as necessary in the event that the vegetation is not growing as anticipated in those void spaces.

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Ms. Karen Pelto May 23, 2014 Page 10 of 11

If the inspections of the walking path and benches installed on the northern and eastern sides of Silver Lake indicate any deficiency in those features (e.g., missing components, cracked or missing bench pieces, pavement cracks/heaves, excessive erosion, etc.), GE will describe those deficiencies in its report. For the first two years after the installation of these items (i.e., in 2014 and 2015), GE will perform any necessary maintenance and repair activities for the walking path and benches, even though ownership of the properties has been (or soon will be) transferred to PEDA. Thereafter, GE will provide notification of any deficiencies in those features to PEDA (as owner) and the City (as easement holder); and the maintenance of the walking path and benches will be the responsibility ofPEDA or the City.

Proposed corrective measures identified during the performance of the periodic inspections (or otherwise identified by GE) will be included in the report for the applicable inspection, as discussed below.

Reporting

Following performance of each NRRE inspection, an event-specific report on each of the above-described inspections will be prepared and submitted, summarizing the results of the inspection and any maintenance activities performed or identified. The report wiii be prepared using field notes and other information collected during each of the monitoring visits, and will include a copy of the completed inspection checklist and associated forms and tables (see interim versions attached as Exhibit A) and photographic documentation of the conditions at the relevant NRRE areas. The report will also document any maintenance activities performed since submittal of the previous inspection report. Such a report will be submitted to the Trustees within 90 days of the inspection (although an effort will be made to submit the report within 30 days ofthe inspection), with copies to EPA, MDEP, PEDA, and the City.

If corrective measures are required based on the observations made during the periodic inspections (or otherwise identified by GE), such corrective measures will be proposed in the respective event-specific report, and will be subject to approval by the Trustees. Following such approval, any corrective actions for which GE is responsible will be conducted within 90 days of the inspection date or 30 days of the Trustees' approval of the proposal included in the event-specific report (whichever is later), unless otherwise agreed to by the Trustees. The maintenance, repair, or replanting activity performed will be documented in the next NRRE inspection report.

IV. Final Restoration Installation Inspection

Paragraph 120 of the CD provides that, after GE submits the Completion of Installation of Restoration Work Report, GE will schedule an installation inspection and meeting, to be attended by GE, EPA, and the Trustees and to be followed by the Trustees' determination of whether the installation of the restoration work has been completed in accordance with the applicable requirements and Performance Standards of the CD. I will contact you to arrange a time for that inspection and meeting. In addition to reviewing the installed NRRE measures, we plan at this meeting/inspection to conduct a stem count of all plantings installed in the NRRE areas and specifically those in the proposed monitoring plots. In the meantime, please call me at (518) 862-2703 if you have questions or comments concerning this revised report.

Sincerely yours,

;i~ ~~~~ Andrew T. Silfer, P.E. GE Project Coordinator

G:\GE\GE _Stiver _Lakc\Rcports and Presentations\20 14 Completion of Jnstallalion of Restoration Work ReportwREV\1 071411214 _ SL CIR WR~Rev 5·23 .doc

Attachments:

Ms. Karen Pelto May 23, 2014 Page 11 of 11

Table 1- Final Post-Placement Monitoring Results- Shallow-Water Shelf/Gravel Habitat Layer Table 2- Invasive Species of Concern Figure 1- Installed Natural Resource Restoration/Enhancement Features Figure 2- Installed Natural Resource Restoration/Enhancement Features- North Shore Figure 3- Installed Natural Resource Restoration/Enhancement Features- East Shore Figure 4- Monitoring Areas and Anticipated Monitoring Plots for NRRE Trees and Shrubs Exhibit A- Interim Checklist for Inspection ofNRRE Measures and Associated Forms

cc: Dave Dickerson, EPA Dean Tagliaferro, EPA Tim Conway, EPA (electronic copy) Chris Ferry, ASRC Primus (electronic copy) Linda Palmieri, Weston (2 hard copies+ electronic copy) Robert Leitch, USACE (electronic copy) Michael Gorski, MDEP (electronic copy) Eva Tor, MDEP (electronic copy) John Ziegler (2 hard copies+ electronic copy) Nancy E. Harper, MA AG* Kenneth Munney, USFWS Ken Finkelstein, NOAA (electronic copy) Doug Clark, Director, Pittsfield Dept. of Community Development James McGrath, Pittsfield Dept. ofParks and Recreation Corydon Thurston, Executive Director, PEDA Barbara Landau, Noble & Wickersham (electronic copy) James Gagnon, O'Reilly, Talbot & Okun (electronic copy) Susan Peterson, CDEP (electronic copy) Richard Gates, GE Kevin Mooney, GE Rod McLaren, GE* Mark Gravelding, ARCADIS Todd Cridge, ARCADIS James Bieke, Sidley Austin LLP Public Information Repositories GE Internal Repositories

* cover letter only

G·\GE\GE _Silver _Lake\Reports and Presentations\20 14 Completion of Installation of Restoration 'Work Report-REV\ 1071411214 _ SL CJR WR-Rev 5-23 .doc

Tables

5/23/2014G:\GE\GE_Silver_Lake\Reports and Presentations\2014 Completion of Installation of Restoration Work Report-REV\1071411214_Table 1 GravelHabitatProbingLog.xls Page 1 of 1

Area Probed1 Adjacent ParcelDate of Final Monitoring

Number ofProbing

Locations

Overall Area Meets Performance Standard

(Yes or No)?Between Transects 37 & 38 I9-9-34 12/10/2012 4 YesBetween Transects 38 & 39 I9-9-34 12/10/2012 4 YesBetween Transects 39 & 40 I9-9-34 12/10/2012 8 Yes

Between Transects 61 & 63 I9-9-1,Esther Terrace 12/19/2012 21 Yes

Between Transects 2 & 3 2 RA-1 4/11/2013 6 YesBetween Transects 3 & 4 RA-1 7/12/2013 3 5 Yes

Between Transects 42 & 43 2I9-9-31,I9-9-32 4/11/2013 3 Yes

Between Transects 43 & 44 2I9-9-30,I9-9-31 4/11/2013 5 Yes

Between Transects 44 & 45 2 I9-9-30 4/11/2013 5 YesBetween Transects 55 & 57 2 I9-9-201 4/11/2013 11 Yes

Between Transects 9 & 11 RA-2 7/12/2013 3 10 YesBetween Transects 11 & 12 2 RA-2 4/11/2013 7 YesBetween Transects 12 & 13 2 RA-2 4/11/2013 6 Yes

Between Transects 13 & 15 RA-2,RA-3 7/12/2013 3 10 Yes

Between Transects 18 & 19 RA-3 7/12/2013 5 YesBetween Transects 28 & 29 RA-4 7/12/2013 5 YesBetween Transects 33 & 34 RA-4 7/26/2013 5 Yes

Between Transects 1 & 2 2 RA-1 4/11/2013 7 Yes

3. At these locations, following an initial monitoring event on 4/11/2013, additional material was placed and final monitoring was subsequently performed on 7/12/2013 as indicated.

TABLE 1FINAL POST-PLACEMENT MONITORING RESULTS - SHALLOW-WATER SHELF/GRAVEL HABITAT LAYER

SILVER LAKE AREAGENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS

2. Gravel Habitat Layer material at this location was placed prior to Silver Lake freezing, and the area was not monitored until the spring thaw (greater than one month after placement).

Notes:1. Probing of the Gravel Habitat Layer was performed by a representative of ARCADIS, and was observed by EPA and/or its oversight contractor.

5/23/2014G:\GE\GE_Silver_Lake\Reports and Presentations\2014 Completion of Installation of Restoration Work Report-REV\1071411214_Table 2 - InvasiveSpecies.xls Page 1 of 1

Common Name Scientific NameAmur honeysuckle Lonicera maackii

Autumn olive Elaeagnus umbellataBlack locust Robinia pseudoacacia

Black swallow-wort Cynanchum louiseaeColtsfoot Tussilago farfara

Common barberry Berberis vulgarisCommon buckthorn Rhamnus cathartica

Cypress spurge Euphorbia cyparissiasGarlic mustard Alliaria petiolata

Glossy buckthorn Rhamnus frangulaGoutweed or Bishop's Weed Aegopodium podagria

Japanese barberry Berberis thunbergiiJapanese honeysuckle Lonicera japonica

Japanese knotweed Polygonum cuspidatumMorrow's honeysuckle Lonicera morrowiiMorrow's X Tatarian Lonicera xbella

Multiflora rose Rosa mutifloraNorway maple Acer platanoides

Oriental bittersweet Celastrus orbiculataPhragmites, Reed grass Phragmites australis

Porcelain berry Ampelopsis brevipedunculataPurple loosestrife Lythrum salicaria

Russian olive Elaeagnus angustifoliaSpotted knapweed Centaurea biebersteinii

Tartarian honeysuckle Lonicera tartaricaYellow iris Iris pseudacorus

Notes:

Weatherbee, P.B., P. Somers, T. Simmons. 1998. A Guide to Invasive Plants in Massachusetts. The Massachusetts Biodiversity Initiative. MassWildlife.

GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS

TABLE 2INVASIVE SPECIES OF CONCERN

SILVER LAKE AREA

1. In addition to the listed species, any plant species listed by the Massachusetts Invasive Plant Advisory Group as "Invasive," "Likely Invasive," or "Potentially Invasive" is subject to the invasive species inspection and control activities described for the above list.

2. Reference:

Figures

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INSTALLED NATURAL RESOURCE

RESTORATION/ENHANCEMENT

FEATURES


SILVER LAKE AREA

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FEATURES - NORTH SHORE


SILVER LAKE AREA

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19-9-201

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LEGEND:

APPROXIMATE WATER LINE (NOVEMBER 2013)

PROPERTY BOUNDARY

PROPERTY ID

BENCH (NOT TO SCALE)

ROW OF PLANTINGS

OBLONG PATCH OF PLANTINGS

CLUS11ER OF PLANTINGS

DECIDUOUS TREE

NRRE PLANTING AREA

APPROXIMATE EXTENT OF SHORELINE ARMOR SYS11EM (INCLUDING OUTFALL PROTECTION)

APPROXIMATE EXTENT OF NRRE SHALLOW-WATER SHELF

SINGLE ROW OF TREES PLANTED IN AREA ADJACENT TO FO\JRTl-1 STREET. SPECIES INCLUDE A MIXTURE OF BLACK \\ILLOWS, SILVER MAPLES, AND EASTERN COTTONWOODS. FOR A TOTAL OF EIGHT TREES

NOTES:

1.

2.

3.

4.

BASE MAP INFORMATION ADJACENT TO SILVER LAKE MODIFIED FROM ELECTRONIC FILE OF SURVEY PERFORMED BY HILL ENGINEERS, ARCHITECTS AND PLANNERS IN 20D6 AND 2008, AND UPDATED BASED ON NOVEMBER 2013 AS-BUILT SURVEY. OTHER BASE MAP INFORMATION PHOTOGRAMMETRICALLY MAPPED FROM APRIL 1990 AERIAL PHOTOGRAPHS

ALL LOCATIONS ARE APPROXIMATE AND ALL PHYSICAL FEATURES MAY NOT BE SHOWN.

THE APPROXIMA11E UNDERWATER EXTENT OF THE SHORELINE ARMOR SYSTEM AND NRRE SHALLOW-WATER SHELF ARE FROM ELECTRONIC FILE OF SURVEY PERFORMED BY SEVENSON ENVIRONMENTAL SERVICES, INC. DURING CONSTRUCTION FROM SUMMER 2012 THROUGH SUM MER 2013.

THE DRY SOIL AREAS WERE DISTINGUISHED FROM THE WET SOIL AREAS BY 11-IE APPROXIMATE ELEVATION CONTOUR OF 980.0 FEET NGV029.

40' 80'

GRAPHIC SCALE

FOURTH STREET OUTFALL

SIL'-!'R LAKE BOULEVARD

DOUBLE ROW (DR SINGLE ROW IN NARROW AREAS) OF SHRUBS PLANTED IN AREA ADJACENT TO FOURTH STREET. SPECIES INCLUDE A MIXTURE OF RED-OSIER DOGWOODS, NORTHERN ARROWWOODS, AND WINTERBERRY HOLLIES.

CLUSTERS OF PLANTINGS PLANTED ON ROAD-SIDE OF WALKING PATH. EACH CLUSTER INCLUDES NO MORE THAN TEN PLANTS. SPECIES INCLUDE A RANDOM MIX OF NANNYBERRY VIBURNUM, SER~CEBERRY, SILKY DOGWOOD, BLACK CHOKEBERRY, AND CHOKE CHERRY (DUE TO BEING IN A DRY SOIL AREA).

SINGLE ROW OF RED-OSIER DOGWOOD PLAN11ED FROM JUST EAST OF FOURTH STREET OUTFALL TO 11-IE APPROXIMATE \\!ESTERN EDGE OF THE SHRUB-SCRUB ISLAND (EXCEPT \\!THIN AREAS IDENTIFIED AS VIEWSHEDS ASSOCIATED \liTH THE BENCH LOCATIONS).

Silver Lake

WALKING PATH

CLUS11ERS OF PLANTINGS PLANTED ON LAKEWARD SIDE OF THE WALKING PATH (EXCEPT WITHIN AREAS IDENTIFIED AS VIEWSHEDS ASSOCIATED \liTH THE BENCH LOCATIONS). EACH CLUS11ER INCLUDES NO MORE THAN TEN PLANTS CONSISTING OF A RANDOM MIX OF SPECIES DEPENDING ON SOIL TYPE (NANNYBERRY VIBURNUM, SERVICEBERRY, SILKY DOGWOOD, BLACK CHOKEBERRY, CHOKE CHERRY IN DRY SOIL AREAS; AND PUSSY-\\ILLOW AND SPECKLED ALDER IN MOIST SOIL AREAS).

OBLONG PATCHES OF PLANTINGS PLANTED ON LAKEWARD SIDE OF THE WALKING PATl-1 (EXCEPT \\!THIN AREAS IDENTIFIED AS VIEWSHEDS ASSOCIATED \liTH THE BENCH LOCATIONS). EACH PATCH INCLUDES APPROXIMATELY 16 PLANTS CONSISTING OF AN EQUAL MIX OF RED-OSIER DOGWOODS. NORTl-IERN ARROWWOODS, AND \\INTERBERRY HOLLIES, WITH NO MORE 11-IAN SIX OF ONE SPECIES PER PATCH.

~ARCADIS

CITY: SYRACUSE DIV/GROUP: ENVCAD DB: K. SARTORI L. FORAKER K. DAVIS LD: PIC: P. KEANEY PM: T. CRIDGE TM: L. PUTNAM LYR: ON=*;OFF=*REF*G:\GE\ENVCAD\SYRACUSE\ACT\N\B0040152\0002\00130\DWG\SLA\40152G01.dwg LAYOUT: 3 SAVED: 4/25/2014 7:40 AM ACADVER: 18.1S (LMS TECH) PAGESETUP: C-PD2B-PDF PLOTSTYLETABLE: PLTFULL.CTB PLOTTED: 4/25/2014 7:43 AM BY: GETTS, BRIAN

FIGURE

3

IMAGES:XREFS: 40152X20 40152X00 40152XDP


SILVER LAKE AREA



FEATURES - EAST SHORE

WALKING PATH

NRRE PLANTINGS ON THE SHRUB-SCRUB ISLAND INCLUDED RED-OSIER DOGWOOD (IN DRIER AREAS) AND BUTTONBUSH SHRUBS (IN AREAS OF LOIII:R ELEVATION), AS WELL AS A MIX OF HERBACEOUS WETLAND SPECIES

11-SI-J.S

/

\

/

I

I

\

/

OBLONG PATCHES OF PLANnNGS PLANTED ON LAKEWARD SIDE OF THE WALKING PATH (EXCEPT WITHIN AREAS IDENTIFIED AS VIEWSHEDS ASSOCIATED WITH THE BENCH LOCATIONS). EACH PATCH INCLUDES APPROXIMATELY 16 PLANTS CQNSSTING OF AN EQUAL MIX OF RED-OSER DOGWOODS, NORTHERN ARRDWWOODS, AND WINTERBERRY HOLLIES, WITH NO MORE THAN SIX OF ONE SPEaES PER PATCH.

SINGLE ROW OF REO-OSIER DOGWOOD PLANTED FROM THE APPROXIMATE EASTERN EDGE OF THE SHRUB-SCRUB ISLAND TO THE SOUTHEASTERN TERMINUS OF THE WALKING PATH (EXCEPT WITHIN AREAS IDENTIFIED AS V1EWSHEDS ASSOCIATED WITH THE BENCH LOCATIONS).

PEDA OUTFALL

Silver Lake

SINGLE ROW OF SHRUBS PLANTED FROM SOUTHEASTERN TERMINUS OF WALKING PATH TO THE BOUNDARY WITH TAX PARCEL 19-9-34. SPECIES INCLUDE A MIXnuRE OF REO-OSIER DOGWOODS, NORTHERN ARROWWOODS, AND WINTERBERRY HOLLIES.

SINGLE ROW OF TREES PLANTED IN AREA EXTENDING FROM THE SOUTHEASTERN TERMINUS OF THE WALKING PATH TO THE BOUNDARY WITH TAX PARCEL 19-9-34. SPECIES INCLUDE A MIXTURE OF BLACK WILLOW AND EASTERN COTTONWOOD, FOR A TOTAL OF 14 TREES.

CLUSTERS OF PLANTINGS PLANTED ON LAKEWARD SIDE OF THE WALKING PATH (EXCEPT WITHIN AREAS IDENTIFIED AS V1EWSHEOS ASSOCIATED 1\HH THE BENCH LOCATIONS). EACH CLUSTER INCLUDES NO MORE THAN TEN PLANTS CONSISTING OF A RANDOM MIX OF SPECIES DEPENDING ON SOIL TYPE (NANNYBERRY V1BURNUM, SERVICEBERRY, SILKY DOGWOOD, BLACK CHOKEBERRY, CHOKE CHERRY IN DRY SOIL AREAS, AND PUSSY-WILLOW AND SPECKLED ALDER IN MQST SQL AREAS).

CLUSTERS OF PLANTINGS PLANTED ON ROAD-SIDE OF WALKING PATH. EACH CLUSTER INCLUDES NO MORE THAN TEN PLANTS. SPEaES INCLUDE A RANDOM MIX OF NANNYBERRY V18URNUM, SERV1CEBERRY, SILKY DOGWOOD, BLACK CHQKEBERRY, AND CHOKE CHERRY (DUE TO BEING IN A DRY SOIL AREA).

NOTES:

SINGLE ROW OF TREES PLANTED IN AREA EXTENDING FROM NORTHEASTERN CORNER QF SILVER LAKE TO THE SOUTHEASTERN TERMINUS OF THE WALKING PATH. SPECIES INCLUDE A MIXTURE OF SUGAR MAPLE, RED OAK, AND RED MAPLE, FOR A TOTAL OF 30 TREES.

LEGEND:

_ _ _ _ _ _ APPROXIMATE WATER LINE (NDV1EMBER 2013)

19-9-201

(<7~ ~0!

@

0

PROPERTY BOUNDARY

PROPERTY 10

BENCH (NOT TO SCALE)

ROW OF PLANTINGS

OBLONG PATCH OF PLANTINGS

CLUSTER OF PLANTINGS

DECIDUOUS TREE

APPROXIMATE EXTENT OF SHRUB-SCRUB ISLAND

NRRE PLANTING AREA

APPROXIMATE EXTENT OF SHORELINE ARMOR SYSTEM (INCLUDING OUTFALL PROTECTION)

APPROXIMATE EXTENT OF NRRE SHALLOW-WATER SHELF

1. BASE MAP INFORMATION ADJACENT TO SILVER LAKE MODIFIED FROM ELECTRONIC FILE OF SURVEY PERFORMED BY HILL ENGINEERS. ARCHITECTS AND PLANNERS IN 2006 AND 2008, AND UPDATED BASED ON NOVEMBER 2013 AS-BUILT SURV1EY. OTHER BASE MAP INFffiMATION PHOTOGRAMMETRICALLY MAPPED FROM APRIL 1990 AERIAL PHOTOGRAPHS.

2 ALL LOCATIONS ARE APPROXIMATE AND ALL PHYSICAL FEATURES MAY NOT BE SHOWN.

3 THE APPROXIMATE UNDERWATER EXTENT OF THE SHffiELINE ARMOR SYSTEM AND NRRE SHALLOW-WATER SHELF ARE FROM ELECTRONIC FILE OF SURVEY PERFORMED BY SEVENSON ENV1RONMENTAL SERV1CES, INC. DURING CONSTRUCTION FROM SUMMER 2012 THROUGH SUMMER 2013.

4. THE DRY SOIL AREAS WIERE DISTINGUISHED FROM THE III:T SOIL AREAS BY THE APPROXIMATE ELEVATION CONTOUR OF 980.0 FEET NGVD29.

40' 80'

GRAPHIC SCALE

~ARCADIS

I9-10-9

AREA

I9-9-36

AREA

I9-9-35

AREA

SHRUB-SCRUB

ISLAND AREA

I9-9-35-2

I9-9-35-1

I9-9-35-3

I9-9-35-4

SSI-2

SSI-1

I9-9-36-3

I9-9-36-2

I9-9-36-1

I9-9-36-4

I9-10-9-2

I9-10-9-1

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MONITORING AREAS AND

ANTICIPATED MONITORING PLOTS

FOR NRRE TREES AND SHRUBS


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Exhibit A

5/23/2014G:\GE\GE_Silver_Lake\Reports and Presentations\2014 Completion of Installation of Restoration Work Report-REV\Exhibit A\1071411214_NRRE checklist and tables.xls Page 1 of 1

EXHIBIT AINTERIM CHECKLIST FOR INSPECTION OF NATURAL RESOURCE RESTORATION/ENHANCEMENT MEASURES


I. GENERAL INFORMATION

Inspection Date: Conducted By/Phone Number: Weather Conditions:

II. INSPECTION SUMMARY1. Vegetation - Qualitative Meander Survey

A.

B.

C.

2.

3.

4.

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIES

Indications of Damage from Trespassing or Herbivory (Note evidence of areas of bare/sparse vegetation; note any damage from trespassing or herbivory; note any physical changes since last inspection [or, for first inspection, since completion of the restoration].)

Presence of Invasive Species (Note the species present including the following: Amur honeysuckle, Autumn olive, Black locust, Black swallow-wort, Coltsfoot, Common barberry, Common buckthorn, Cyprus spurge, Garlic mustard, Glossy buckthorn, Goutweed or Bishop's weed, Japanese barberry, Japanese honeysuckle, Japanese knotweed, Morrow's honeysuckle, Morrow's X Tartarian honeysuckle [hybrid], Multiflora rose, Norway maple, Oriental bittersweet, Phragmites - Reed grass, Porcelain berry, Purple loosestrife, Russian olive, Spotted knapweed, Tartarian honeysuckle, Yellow iris, or any other plant species listed by the Massachusetts Invasive Plant Advisory Group as “Invasive,” “Likely Invasive,” or “Potentially Invasive”.)

Restored Trees and Shrubs (Note any physical changes since last inspection [or, for first inspection, since completion of the restoration]; note condition of trees and shrubs planted during restoration activities; note general condition of any tree guards, tree cages, and/or tree stakes, if present.)

Walking Path and Benches (Assess the presence, integrity, condition [e.g., cracked or missing bench pieces, pavement cracks/heaves], and ability to function as intended.) [Note: This requirement is applicable for three years after installation.]

Other Observations (Confirm that repair/maintenance activities identified during prior inspection, if any, have been performed; note any other general observations, including parcel-specific restoration activities.)

ATTACH ADDITIONAL INFORMATION AS APPROPRIATE

Vegetation - Quantitative Monitoring (Complete the attached field form [Form A-1] for each monitoring plot and then complete the attached summary tables [Tables A-1 and A-2].)

FORM A-1

NATURAL RESOURCE RESTORATION/ENHANCEMENT QUANTITATIVE VEGETATION MONITORING FIELD FORM

SILVER LAKE AREA GENERAL ELECTRIC COMPANY – PITTSFIELD, MASSACHUSETTS

Page ________ of __________

Inspection Date: __________________________________________________________________________________ Conducted By/Observer(s): _________________________________________________________________________ Weather Conditions: _______________________________________________________________________________ Monitoring Area: Approximate Size (sf): _ Monitoring Plot: Approximate Size (sf): _ Stem Count:

Trees # Alive & Healthy

# Alive, Stressed # Dead

Shrubs # Alive & Healthy


Black willow

Red-osier dogwood

Silver maple

Silky dogwood

Eastern cottonwood

Winterberry Holly

Sugar maple

Choke cherry

Red oak

Northern arrowwood

Red maple

Nannyberry viburnum

Serviceberry

Black chokeberry

Pussy-willow

Speckled alder

Buttonbush

Total Live Trees: _____________________________ Total Live Shrubs: _____________________________ Were two or more adjacent trees observed to be dead (Y/N):_______________ Herbaceous Cover (%): ___________________________ Invasive Plant Cover (%): __________________________


Date(s) of Monitoring:

DimensionsLength Width Area Total Total Herbaceous Invasive Plant

Area Plot No. (ft) (ft) (ft2) BW SiM EC SuM RO RM Trees ROD SD WH CC NA NV SB BCB PW SA BB Shrubs Cover (%) Cover (%)

I9-10-9-1

I9-10-9-2

I9-9-36-1

I9-9-36-2

I9-9-36-3

I9-9-36-4

SSI-1

SSI-2

I9-9-35-1

I9-9-35-2

I9-9-35-3

I9-9-35-4


Number of Shrubs

I9-10-9 Area

I9-9-36 Area


I9-9-35 Area

TABLE A-1SUMMARY OF MONITORING PLOT PLANTING COUNTS


Number of Trees


Date(s) of Monitoring:

Herbaceous Invasive PlantArea Plot No. # Planted # Alive % Survival > 80% Survival # Planted # Alive % Survival > 80% Survival Cover (%) Cover (%)

I9-10-9-1

I9-10-9-2

Average

I9-9-36-1

I9-9-36-2

I9-9-36-3

I9-9-36-4

Average

SSI-1

SSI-2

Average

I9-9-35-1

I9-9-35-2

I9-9-35-3

I9-9-35-4

Average

TABLE A-2SUMMARY OF QUANTITATIVE ASSESSMENT

I9-10-9

I9-9-36

Shrub-Scrub Island

I9-9-35

Trees Shrubs


June 25, 2014 SL Initial Post-Remediation Inspection and Spring 2014 Inspection of Shoreline Armor System, Backfilled/Restored Areas Adjacent to Silver Lake, and Non-Natural Resource Restoration/Enhancement Plantings

June 25, 2014

Mr. Dave Dickerson Office of Site Remediation and Restoration U.S. Environmental Protection Agency, Region I 5 Post Office Square- Suite 100 Boston, MA 02109-3912

Re: GE-Pittsfield/Housatonic River Site Silver Lake Area (GECDGOO)

GE 159 Plastics Avenue Pittsfield. MA 01201 USA

Initial Post-Remediation Inspection and Spring 2014 Inspection of Shoreline Armor System, Backfilled/Restored Areas Adjacent to Silver Lake, and Non-Natural Resource Restoration/Enhancement Plantings

Dear Mr. Dickerson:

Pursuant to the requirements set forth in the October 2000 Consent Decree (CD) for the GEPittsfield/Housatonic River Site (the Site) and the accompanying Statement of Work for Removal Actions Outside the River (SOW), the General Electric Company (GE) implemented a Removal Action at the Silver Lake Area Removal Action Area (RAA) between July 2012 and December 2013. The Removal Action implemented at the Silver Lake Area included removal of selected sediments, installation of a sediment cap and associated armor layer, and removal/replacement of soil in certain areas on the banks and otherwise adjacent to the lake to meet established Performance Standards, followed by restoration of those areas. In addition, as required by the CD, GE installed a number of natural resource restoration/ enhancement (NRRE) measures at the Silver Lake Area, and submitted a revised Completion of Installation of Restoration Work Report on those measures to the natural resource trustees (the Trustees) on May 23, 2014. The CD and SOW also require monitoring and maintenance of the both the NRRE measures and the non-NRRE measures installed at the Silver Lake Area following completion of the Removal Action. This letter summarizes the monitoring activities conducted for the non-NRRE measures in spring 2014. A separate letter will be submitted to the Trustees on the spring 2014 monitoring of the NRRE measures.

The Performance Standards and other requirements for post-construction monitoring and maintenance of the non-NRRE measures at the Silver Lake Area were set forth in Attachments J and K to the SOW. In satisfaction of those requirements (as well as the separate requirements for monitoring and maintenance of the NRRE measures), GE submitted a Post-Removal Site Control Plan/Restoration Project Monitoring and Maintenance Plan (PRSCP/RPMMP) as Appendix I of its August 2011 Revised Final Removal Design/Removal Action Work Plan for Silver Lake Area, which was conditionally approved by the U.S. Environmental Protection Agency (EPA) by letter dated August 25, 2011. That plan included (in Section 2) a description of the Post-Removal Site Control activities for the non-NRRE measures at the Silver Lake Area. 1

The PRSCP/RPMMP required GE to perform periodic inspections of the sediment cap and shoreline armor system installed in the lake, the backfilled/restored areas that were subject to soil removal and replacement activities or were otherwise disturbed by the remediation, and the plantings installed in the non-NRRE areas. Specifically, that plan required monitoring of the cap thickness and integrity annually

1 The requirements set forth in the PRSCP/RMMP will govern the post-construction monitoring and maintenance activities at the Silver Lake Area until such time as they are superseded by the comparable requirements presented in the Final Completion Report (FCR) for the Silver Lake Area Removal Action, as approved by EPA.

Corporate En dronment•JI Pr.;grom'

Dave Dickerson June 25, 2014

Page 2 of6

for the first five years after installation; monitoring of the cap isolation layer during the first and fifth year after construction; monitoring of the shoreline armor system semi-annually for five years after construction; inspection of the backfilled/restored areas adjacent to the lake and other disturbed areas shortly after construction, semi-annually for the first year after construction, and annually thereafter; and inspection of the non-NRRE plantings semi-annually (in May and August or September) for a two year period after planting. EPA subsequently agreed that the initial post-construction inspection of the backfilled/restored areas and other disturbed areas could be combined with the first semi-annual inspection of those areas.

On May 27, 2014, GE performed the initial post-remediation inspection of the non-NRRE measures at the Silver Lake Area. This inspection constituted the first of the 2014 semi-annual inspections of the shoreline armor system, the combined initial and first semi-annual inspection of the backfill/restored areas and other disturbed areas, and the first semi-annual inspection of the non-NRRE plantings. 2 The monitoring activities were performed by Mark Gravelding, Anthony Esposito, Robert Papallo, and/or Eric Ungberg of ARCADIS (on GE's behalf), and the monitoring event was also attended by Michael Argue of Weston Solutions, Inc. (on EPA's behalf) and Michael Backunas of the Massachusetts Department of Environmental Protection (MDEP). This letter summarizes that monitoring event and describes the findings.

Description and Results of Initial Post-Remediation Inspection and Spring 2014 Monitoring Event

This section describes and presents the results of the May 27, 2014 inspection for each of the nonNRRE components inspected; and, where warranted, it presents GE's plans for follow-up actions. The locations of the shoreline armor system, the backfilled/restored areas, and the non-NRRE planting areas that were inspected are shown on Figure 1.3 The inspection checklists are provided in Attachment A, and photographic logs of the inspection are provided in Attachments 8 and C (as described below).

Shoreline Armor System Monitoring

In accordance with the PRSCP/RPMMP, the May 2014 inspection of the shoreline armor system consisted of visual observations of that system to assess the effects, if any, of shoreline wave and/or wind action on the sediment cap/armor system along the shoreline. In this regard, we note that, on the day of the inspection, flow in the Housatonic River was approximately 87 cubic feet per second (cfs), as measured at the U.S. Geological Survey (USGS) river gage in Coltsville. However, since completion of construction in December 2014, there were multiple high-flow events (i.e., estimated flow greater than 440 cfs at the Coltsville gage). For example, the Coltsville gage reported daily average flows greater than 440 cfs on December 23, 2013 and January 12, March 30 through March 31, April 9, April 16, and May 1 and 2, 2014, including a maximum flow of 657 cfs on April 16, 2014.

The PRSCP/RPMMP provides that if this monitoring reveals significant erosion of the shoreline (e.g., slope failure, ruts, gullies, washouts, or sloughing), repair of the eroded areas will be conducted.

During the May 2014 inspection, no areas within the shoreline armor system were observed with significant erosion (as defined above). However, it was noted that some geotextile installed within the channel to the outfall from Silver Lake to the Housatonic River (Figure 1; Area 1) was exposed, as shown in Photograph 1 in Attachment B. While not specifically required by the PRSCP/RPMMP, additional riprap will be placed in this area to cover the exposed geotextile.

2 As discussed further below, the 2014 cap monitoring and the second of the 2014 inspections of the shoreline armor system, the backfilled/restored and disturbed area, and the non-NRRE planting will be conducted later this summer. 3 In addition to the areas shown on Figure 1, other areas that were disturbed and restored during the performance of the remediation (e.g., staging/access areas) were also inspected.

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Page 3 of 6

The completed inspection checklist documenting the May 2014 monitoring of the shoreline armor system is included as Attachment A-1 to this letter.4

Monitoring of Backfilled/Restored Areas Adjacent to the Lake and Other Disturbed Areas

In accordance with the PRSCP/RPMMP, the combined initial and first semi-annual inspection of the backfill/restored areas and other disturbed areas consisted of visual observations of those areas for the following: (a) evidence of erosion; (b) the effectiveness of erosion controls in areas where vegetation is not established; (c) evidence of depressions and/or surface water ponding; (d) any areas where excessive settlement has occurred relative to the surrounding areas; (e) any drainage or growth problems; (f) any stressed or sparse cover; and (g) other conditions that could jeopardize the performance of the completed remediation actions. The PRSCP/RPMMP provides that if this inspection reveals any problematic conditions, maintenance and/or repair activities will be conducted.

During the spring 2014 inspection, nine areas were noted with evidence of erosion, depressions, drainage or growth problems, and/or stressed or sparse cover. Descriptions of these areas, along with proposed area-specific corrective actions, are presented below and are summarized in Table 1, with photographs of these areas presented in Attachment B.

Area 2 - Area 2 is an area of minor erosion of surface soils east of the fence near the top of the bank on Parcel 19-9-9 (Figure 1; Attachment B, Photo 2). To reduce the potential for future erosion in this area, the soil will be replaced within the eroded area to restore the area to surrounding grades, and the area will be re-vegetated by seeding.

Area 3 - Area 3 is an area of minor erosion of surface soils east of the fence above the top of the bank on Parcel 19-9-9 (Figure 1; Attachment B, Photo 3). As in Area 2, to reduce the potential for future erosion in this area, the soil will be replaced within the eroded area to restore the area to surrounding grades, and the area will be re-vegetated by seeding.

Area 4 - Area 4 is an area with uneven grading and bare spots with sparse cover in the bank area near the fence on Parcel 19-10-8 (Figure 1; Attachment B, Photos 4 and 5). To address the sparse cover and reduce the potential for erosion in this area, the "high spots" in the uneven areas will be re-graded, and the area will be re-vegetated by seeding.

Area 5 - Area 5 is an area of minor erosion of surface soils, uneven grading, and bare spots with sparse cover in the bank area on Parcell9-10-8 (Figure 1; Attachment B, Photo 6). To address the sparse cover and reduce the potential for future erosion in this area, this area will be re-graded and re-vegetated by seeding.

Area 6- Area 6 is an area of minor settlement around certain guardrail posts on Parcels 19-9-35 and -36 (Figure 1; Attachment B, Photo 7). To address the depressions and reduce the potential for future surface water ponding or erosion in this area, additional soil will be placed within the depressed locations to restore those locations to surrounding grades, and those locations will be revegetated by seeding.

Area 7- Area 7 is an area of minor settlement and resulting exposure of an abandoned outfall pipe on Parcel 19-9-35 (Figure 1; Attachment B, Photo 8). To cover the exposed outfall, additional soil will be placed within the depressed area to restore the area approximately one foot above the abandoned outfall, and the area will be re-vegetated by seeding.

Area 8 - Area 8 is an area of minor erosion of surface soils under the fence on Parcel 19-9-30 (Figure 1; Attachment B, Photo 9). To reduce the potential for future erosion in this area, the soil will

4 Subsequent to the May 2014 inspection, some displacement/erosion of stone was observed in the channel of the Fourth Street outfall. This condition will be documented and addressed in the upcoming report on the summer 2014 inspection of the shoreline armor system inspection.

G:\GE\GE_ Silver_ Lake\Reports and Presentations\20 14..06 backfill, non~NRRE veg, fllllOr insp\1391411214 _ SL Spring Jnsp Letter Rpt.doc


Page 4 of6

be replaced within the eroded area to restore the area to surrounding grades, and the area will be re-vegetated by seeding.

Area 9- Area 9 is an area of minor erosion of surface soils on the east side of a drainage swale on Parcel 19-9-22 (Figure 1; Attachment B, Photo 1 0). To reduce the potential for future erosion in this area, additional riprap will be placed within the eroded area to restore the area to surrounding grades.

Area 10- Area 10 is an area of minor erosion of surface soils between the two drainage swales on Parcel 19-9-22 (Figure 1; Attachment B, Photo 11 ). To reduce the potential for future erosion in this area, the soil will be replaced within the eroded area to restore the area to surrounding grades, mulch will be placed, and the area will be re-vegetated by seeding.

The completed inspection checklist documenting the May 2014 inspection of backfilled/restored and other disturbed areas is included as Attachment A-2 to this letter.5

Non-NRRE Vegetation Monitoring

In accordance with the PRSCP/RPMMP, the vegetation planted in the backfilled/restored areas outside of the NRRE areas was inspected to assess the establishment, coverage, and condition of the vegetation, including any evidence of stressed or sparse cover, and to ensure that vegetation is growing as anticipated and providing the necessary erosion control. The inspection also included observations of the trees and shrubs planted as part of the restoration activities to assess the number and condition of those plantings, which were recorded. The average height of planted trees and shrubs sub!ect to inspection was measured (to the nearest foot) and recorded for a subset of the planted stock. The results of the non-NRRE vegetation inspection for each property are summarized in Table 2, with photographs of the vegetation at selected properties provided in Attachment C.

Since the May 2014 inspection was the initial inspection of the planted trees and shrubs, it was used to establish a baseline for subsequent determinations of percent survival (rather than for calculating percent survival at this time). As agreed with EPA's representative in the field, the total quantity of healthy trees and shrubs observed during the spring 2014 monitoring event, plus six burning bush shrubs on Parcel 19-9-27 that were observed to be stressed (as described below), will be used as the baseline number of plantings for percent survival calculations in subsequent monitoring events. Those plantings are listed in Table 3.

One area of stressed plantings was identified for further follow-up activities. This area, along with a proposed response, is described below and summarized in Table 1.

Area 11 - Area 11 contains six burning bush ornamental shrubs planted on Parcel 19-9-27 (at the owner's request) that were observed to be severely stressed, as indicated by the absence of leaves or live buds on the upper portions of the shrubs and the observation that many of the upper branches were dried out and dead (Figure 1; Attachment C, Photo 2). However, observation of live leaves on the lower portion of these shrubs indicated that the root system is still healthy and that these shrubs are likely to recover. The health of these shrubs will be re-evaluated later in the growing season (i.e., during the summer 2014 monitoring event). 7

5 Subsequent to the May 2014 inspection, erosion was observed near outfalls 28/29 and 31. These conditions will be documented and addressed in the upcoming report on the summer 2014 inspection of the backfilled/restored areas. 6 Note that the PRSCP/RPMMP called for the measurement of all trees and shrubs planted in the non-NRRE areas; however, it was determined in the field, with concurrence by EPA's representative, that the measurement of a subset of the total number of trees and shrubs would be sufficient due to the similarity in heights of the planted stock. 7 The other plantings listed in Table 2 as dead or stressed were not identified for follow-up actions and will not be included in the baseline number of plantings for percent survival calculations in later monitoring events.

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Page 5 of6

During the spring 2014 inspection, the ground vegetation was observed to be adequately established in the majority of the non-NRRE areas; however, three areas were noted with evidence of sparse cover. Descriptions of these areas, along with proposed area-specific responses, are presented below and are summarized in Table 1.

Areas 4 and 5- As noted above, Areas 4 and 5 on Parcel 19-10-8 contain bare spots with sparse cover (Figure 1; Attachment B, Photos 4, 5, and 6). This poor ground cover is likely due to the use of this property for extended access to other portions of the Silver Lake shoreline during restoration. As noted above, these areas will be re-graded and re-vegetated. This re-grading/re-vegetation will be performed as soon as practicable to enable the ground cover to become established this season.

Area 12- Area 12 consists of an area without established ground cover on Parcel 19-9-19, just west of the channel to the outfall from Silver Lake to the Housatonic River (Figure 1; Attachment C, Photo 6). This area appeared to have been recently seeded and mulched, and will be re-evaluated during the summer 2014 monitoring event.

With the exception of Parcels 19-10-8 and 19-9-9, all parcels in the non-NRRE areas observed during the spring 2014 monitoring event were noted as having at least one invasive species, but usually only a few individuals of such invasive species. Invasive species cover did not exceed 5% of the ground cover on any individual parcel. Observed invasive species included coltsfoot, yellow iris, buckthorn, oriental bittersweet, purple loosestrife, garlic mustard, Japanese knotweed, honeysuckle, Russian olive, and burning bush. These invasive species (except for the burning bush shrubs planted on Parcell9-9-27, as discussed above, as well as the burning bush shrubs planted on adjacent Parcel 19-9-28 at the owner's request) will be addressed as part of GE's ongoing invasive species control program for the restored and re-vegetated areas.

Additionally, during the inspection, tree cages, tree guards, and tree stakes (where present) were inspected and confirmed to be functioning to protect the trees from damage.

The completed inspection checklist documenting the May 2014 non-NRRE vegetation inspection is included as Attachment A-3 to this letter.

Future Activities

In accordance with the PRSCP/RPMMP, GE will implement the maintenance, repair, and re-vegetation activities identified above and summarized in Table 1 within 90 days of the inspection date (i.e., by August 25, 2014)- or sooner if practicable, assuming timely EPA approval- unless otherwise agreed to by EPA. The maintenance, repair, and re-vegetation activities performed will be documented in the summer 2014 inspection report.

This spring 2014 inspection fulfilled the requirements for the first post-construction monitoring event for the shoreline armoring system, the backfilled/restored areas, and the plantings in the non-NRRE plantings, as outlined in the PRSCP/RPMMP. GE will continue with the monitoring activities on the schedule specified in that plan, as described above (until replaced by the Post-Removal Site Control requirements specified in the FCR for the Silver Lake Area Removal Action). The next scheduled inspection of the shoreline armor system, the backfilled/restored and other disturbed areas, and the nonNRRE plantings will occur in late summer 2014 (August for the shoreline armor system and August or September for the backfilled/restored areas and non-NRRE plantings). 8 In addition, the first monitoring events for the cap thickness and the cap isolation layer will be performed in the late summer or fall of

8 In addition to the scheduled inspections, the shoreline armor system and the backfilled/restored and other disturbed areas will be inspected after severe storms, defined as storm events with a 15-minute instantaneous peak flow of 3,500 cfs or greater, as measured at the USGS river gage in Coltsville. The shoreline armor system will also be inspected after an excessive wind events, as determined in consultation with EPA.

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Page 6 of 6

2014. Reports will be submitted on all of these monitoring events and will include completed inspection checklists (if applicable).

Please contact me if you have any questions regarding the information presented in this letter.

Sincerely,

~~/{." Senior Project Manager- Environmental Remediation

Attachments

cc: Dean Tagliaferro, EPA Tim Conway, EPA** Chris Ferry, ASRC Primus** Linda Palmieri, Weston (2 hard copies)** Robert Leitch, USAGE** Michael Gorski, MDEP** John Ziegler, MDEP (2 hard copies)** Eva Tor, MDEP** Karen Pelto, MDEP** Nancy E. Harper, MA AG* Doug Clark, Director, Pittsfield Dept. of

Community Development** James McGrath, Pittsfield Dept. of Parks

and Recreation**

Corydon Thurston, Executive Director, PEDA ** Barbara Landau, Noble & Wickersham** James Gagnon, O'Reilly, Talbot & Okun** Rod Mclaren, GE* Kevin Mooney, GE Andrew Silfer, GE James Bieke, Sidley Austin LLP Mark Gravelding, ARCADIS Todd Cridge, ARCADIS** Public Information Repositories GE Internal Repositories

* without attachments ** electronic copy

G.\GE\GE_Silver_Lakd;Rcports and Prcscntations\2014-06 backfill. non-NRRE vcg., <~mor insp\1391411214_SL Spring lnsp Letter Rpt.doc

Tables

G:\GE\GE_Silver_Lake\Reports and Presentations\2014-06 backfill, non-NRRE veg, armor insp\1391411214_Table 1.xls Page 1 of 1

Area/Item Identified Description Proposed Follow-up Action1 - Armor System at the Outfall to the Housatonic River

Indication of exposed geotextile fabric Replace riprap to cover exposed fabric

2 - Backfilled/Restored Area onParcel I9-9-9

Indication of minor soil erosion near top of bank (east of fence)

Replace soil and re-seed


Indication of minor soil erosion above top of bank (east of fence)

Replace soil and re-seed


Indication of bare spots and uneven grade on bank near fence

Regrade high spots and re-seed


Indication of uneven grading, minor soil erosion, and bare spots on bank

Regrade erosion and re-seed

6 - Backfilled/Restored Area onParcel I9-9-35 and -36 (various locations)

Indication of minor soil settlement around guardrail posts

Replace soil in depressions around new posts and former posts, as needed


Indication of exposed abandoned outfall and bare spots

Add soil and re-seed


Indication of minor soil erosion under fence Replace soil and re-seed


Indication of soil erosion on east side of swale

Add riprap


Indication of minor soil erosion between swales

Replace soil, re-seed and place mulch

11 - Non-NRRE Plantings onParcel I9-9-27

Indication of stressed burning bushes Monitor during summer inspection

12 - Non-NRRE Plantings onParcel I9-9-19

Indication of unestablished ground cover Monitor during summer inspection

TABLE 1

INITIAL POST-REMEDIATION INSPECTION AND 2014 INSPECTION OF SHORELINE ARMOR SYSTEM, BACKFILLED/RESTORED AREAS ADJACENT TO SILVER LAKE, AND NON-NATURAL RESOURCE

RESTORATION/ENHANCEMENT PLANTINGS


SUMMARY OF ITEMS REQUIRING RESPONSE

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SpeciesQuantityObserved

Not Stressed or Dead

QuantityObservedStressed

QuantityObserved

Dead

Average Height (ft)1

Observed Percentage

Invasive SpeceisI9-10-8Red-Osier Dogwood 112 -- 1 2.9Northern Arrowwood 29 -- -- 3.1Winterberry Holly 28 -- -- 3.1I9-9-9Red-Osier Dogwood 16 -- -- 3.3Northern Arrowwood 4 -- -- 3.0Winterberry Holly 4 -- -- 3.7I9-9-1, I9-9-201Red-Osier Dogwood 104 -- 1 3.2Northern Arrowwood 25 1 -- 3.0Winterberry Holly 25 -- -- 3.0I9-9-17Red-Osier Dogwood 34 -- -- 3.0Northern Arrowwood 9 -- -- 2.9Winterberry Holly 9 -- -- 2.2Serviceberry 0 -- -- 2.2I9-9-18, I9-9-19Red Maple 1 -- -- 15.0Red-Osier Dogwood 27 -- -- 3.0Northern Arrowwood 5 -- -- 3.0Winterberry Holly 7 -- -- 2.2I9-9-21, I9-9-22, I9-9-23Red-Osier Dogwood 54 -- 1 2.8Northern Arrowwood 11 -- -- 2.9Winterberry Holly 12 -- -- 4.0I9-9-24Red-Osier Dogwood 18 -- -- 2.8Northern Arrowwood 4 -- -- 4.0Winterberry Holly 5 -- -- 3.3I9-9-25, I9-9-26Red-Osier Dogwood 24 -- -- 3.0Northern Arrowwood 5 -- -- 3.0Winterberry Holly 7 -- -- 4.0I9-9-27Red-Osier Dogwood 13 -- -- 3.0Northern Arrowwood 3 -- -- 3.0Winterberry Holly 4 -- -- 4.0Arborvitae 5 -- -- 10.0Red Oak 1 -- -- 18.0Burning Bush -- 6 -- 3.0I9-9-28Red-Osier Dogwood 16 -- -- 2.7Northern Arrowwood 5 -- -- 3.0Winterberry Holly 4 -- -- 4.0Fraser Fir 2 -- -- 10.0Burning Bush 3 -- -- 2.0I9-9-29Red-Osier Dogwood 12 -- -- 2.5Northern Arrowwood 3 -- -- 3.0Winterberry Holly 3 -- -- 3.5Arborvitae 11 -- -- 10.0Privet 21 -- -- 4.0I9-9-34Red-Osier Dogwood 62 -- 2 2.8Northern Arrowwood 55 -- -- 3.2Winterberry Holly 15 -- -- 3.6

TOTALS 817 7 5

<5%

<5%

<5%

<5%

<5%

<5%

<5%

<5%

<5%

1. Average heights were based on a measured subset of all observed plantings.

<5%

Notes:

<5%

<5%

TABLE 2SUMMARY OF RESTORED VEGETATION INSPECTED IN

NON-NATURAL RESOURCE RESTORATION/ENHANCEMENT AREAS


INITIAL POST-REMEDIATION INSPECTION AND 2014 INSPECTION OF SHORELINE ARMOR SYSTEM, BACKFILLED/RESTORED AREAS ADJACENT TO SILVER LAKE, AND NON-NATURAL RESOURCE

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Species Quantity to be Monitored

I9-10-8Red-Osier Dogwood 112Northern Arrowwood 29Winterberry Holly 28I9-9-9Red-Osier Dogwood 16Northern Arrowwood 4Winterberry Holly 4I9-9-1, I9-9-201Red-Osier Dogwood 104Northern Arrowwood 25Winterberry Holly 25I9-9-17Red-Osier Dogwood 34Northern Arrowwood 9Winterberry Holly 9I9-9-18, I9-9-19Red Maple 1Red-Osier Dogwood 27Northern Arrowwood 5Winterberry Holly 7I9-9-21, I9-9-22, I9-9-23Red-Osier Dogwood 54Northern Arrowwood 11Winterberry Holly 12I9-9-24Red-Osier Dogwood 18Northern Arrowwood 4Winterberry Holly 5I9-9-25, I9-9-26Red-Osier Dogwood 24Northern Arrowwood 5Winterberry Holly 7I9-9-27Red-Osier Dogwood 13Northern Arrowwood 3Winterberry Holly 4Arborvitae 5Red Oak 1Burning Bush 6I9-9-28Red-Osier Dogwood 16Northern Arrowwood 5Winterberry Holly 4Fraser Fir 2Burning Bush 3I9-9-29Red-Osier Dogwood 12Northern Arrowwood 3Winterberry Holly 3Arborvitae 11Privet 21I9-9-34Red-Osier Dogwood 62Northern Arrowwood 55Winterberry Holly 15

TOTAL 823

TABLE 3SUMMARY OF VEGETATION INSTALLED IN NON-NATURAL RESOURCE RESTORATION/ENHANCEMENT AREAS

TO BE MONITORED DURING FUTURE MONITORING EVENTSINITIAL POST-REMEDIATION INSPECTION AND 2014 INSPECTION OF SHORELINE ARMOR SYSTEM,

BACKFILLED/RESTORED AREAS ADJACENT TO SILVER LAKE, AND NON-NATURAL RESOURCE RESTORATION/ENHANCEMENT PLANTINGS


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AND SPRING 2014 INSPECTION OF SHORELINE ARMOR

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Attachment A

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ATTACHMENT A-1INTERIM CHECKLIST FOR VISUAL INSPECTION OF SHORELINE ARMORING



Inspection Date: 27-May-14Conducted By: Mark Gravelding, Robert PapalloWeather Conditions: Sunny, 70s-80s

II. INSPECTION SUMMARY1.

2.

No significant erosion of the shoreline noted. One area with exposed geotextile noted near the channel to the outfall to the Housatonic River.

3.

Not applicable.

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIESPlace riprap to cover geotextile.

Preliminary Inspection Activities (Confirm that Figure I-1 of the Revised Final Removal Design/Removal Action Work Plan for Silver Lake Area and the technical drawings provided in Appendix D of that document have been reviewed in the field during the inspection. )

Shoreline Armoring (Note any physical changes since completion of the restoration; note evidence of significant erosion of the shoreline [e.g., slope failure, ruts, gullies, washouts, or sloughing], and if any erosion is observed, evaluate whether there are any eroded soils remaining in the lake; note other conditions that could jeopardize the performance of the completed remediation actions.)



of that draft – were reviewed in the field.

In lieu of the specified figure and drawings, more recent figure/drawings – namely Figure 8-1 of the April 2014 draft of the FinalCompletion Report for Silver Lake Area Removal Action and the as-built drawings of the shoreline armor system provided in Appendix F


ATTACHMENT A-2INTERIM CHECKLIST FOR VISUAL INSPECTION OF RESTORED AREAS ADJACENT TO LAKE

INSPECTION OF BACKFILLED/RESTORED AREAS



Inspection Date: 27-May-14Conducted By: Mark Gravelding, Robert PapalloWeather Conditions: Sunny, 70s-80s


2.

Minor soil erosion on Parcels I9-9-9, I9-10-8, I9-9-30, I9-9-22.Bare spots/sparse cover on Parcels I9-10-8.Uneven grading on Parcels I9-10-8.Minor settlement around guardrail posts on I9-9-35 and I9-9-36.Exposure of abandoned outfall pipe on Parcel I9-9-35.

3.

Not applicable.

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIESReplace or place soil, riprap, and/or seed and mulch. Regrade as necessary prior to revegetation.



Backfilled/Restored Areas (Note any physical changes since completion of the restoration; note evidence of any of the following: soil or gravel erosion, effectiveness of erosion controls in areas where vegetation is not established, depressions or surface water ponding, excessive settlement, drainage or growth problems, stressed or sparse cover, other conditions that could jeopardize the performance of the completed remediation actions, etc.. If any conditions are present, note the Parcel Number where such conditions are observed.)


Report for Silver Lake Area Removal Action and the as-built drawings provided in Appendix F of that draft – were reviewed in the field.In lieu of the specified figure and drawings, more recent figure/drawings – namely Figure 8-1 of the April 2014 draft of the Final Completion



INSPECTION OF VEGETATION AT AREAS OTHER THAN NATURAL RESOURCE RESTORATION/ENHANCEMENT AREAS



Inspection Date: 27-May-14Conducted By: Anthony Esposito Weather Conditions: Sunny, 70s-80s


2.

The majority of the restored areas supported adequate ground cover. However, less than expected ground cover was observedon Parcel I9-10-8. Parcel I9-9-19 did not have established ground cover, but appeared to have been recently seeded and mulched.Observed trees and shrubs were counted, and a subset of shrub heights was measured. The results are presented in Table 2of the letter report on the inspection. Six burning bush shrubs planted on Parcel I9-9-27 were severely stressed, but showed signs of re-sprouting at the bottom of the plant.

3.

Invasive species were observed on all non-NRRE parcels, except Parcels I9-9-9 and I9-10-8. Observed species included Buckthorn,Coltsfoot, Garlic Mustard, Honeysuckle, Japanese Knotweed, Oriental Bittersweet, Purple Loosestrife, Russian Olive, Yellow Iris, and burning bush.No invasive species cover exceeded 5% of the ground cover on any of the parcels.

4.

Not applicable

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIESPerform re-grading, seeding and mulching in sparsely covered areas at Parcel I9-10-8.

Monitor the ground cover on Parcel I9-9-19 during the summer 2014 inspection.Monitor the burning bush shrubs on Parcel I9-9-27 during the summer 2014 inspection.Continue the invasive species control program (except for the burning bush shrubs planted on Parcels I9-9-27 and I9-9-28).


Vegetation in Non-NRRE Areas (Note any physical changes since completion of the restoration; note the establishment, coverage, and general condition of vegetative cover [e.g., evidence of stressed/sparse cover], verify that vegetation is growing as anticipated and providing the necessary erosion control, assess survival and condition of other landscaping items [trees, shrubs, etc.] planted during restoration activities, tree guards, tree cages, and tree stakes; and measure and record the size of all trees and shrubs subject to inspection, including information regarding the number, height, and condition of the trees and shrubs subject to inspection. If any conditions are present, note the Parcel Number where such conditions are observed.)

Presence of Invasive Species (Note percentage of area occupied by invasive species; note the species present including the following: Amur honeysuckle, Autumn olive, Black locust, Black swallow-wort, Coltsfoot, Common barberry, Common buckthorn, Cyprus spurge, Garlic mustard, Glossy buckthorn, Goutweed or Bishop's weed, Japanese barberry, Japanese honeysuckle, Japanese knotweed, Morrow's honeysuckle, Morrow's X Tartarian honeysuckle [hybrid], Multiflora rose, Norway maple, Oriental bittersweet, Phragmites - Reed grass, Porcelain berry, Purple loosestrife, Russian olive, Spotted knapweed, Tartarian honeysuckle, Yellow iris, or any other plant species listed by the Massachusetts Invasive Plant Advisory Group as “Invasive,” “Likely Invasive,” or “Potentially Invasive” . If any conditions are present, note the Parcel Number where such conditions are observed.)



in the field.

In lieu of the specified figure and drawings, more recent figure/drawings – namely Figure 8-1 of the April 2014 draft of the FinalCompletion Report for Silver Lake Area Removal Action and the as-built drawings provided in Appendix F of that draft – were reviewed

Attachment B

ATTACHMENT B PHOTOGRAPHIC LOG OF ITEMS REQUIRING RESPONSE INITIAL POST-REMEDIATION INSPECTION AND SPRING 2014 INSPECTION OF SHORELINE ARMOR SYSTEM, BACKFILLED/RESTORED AREAS ADJACENT TO SILVER LAKE, AND NON-NATURAL RESOURCE RESTORATION/ENHANCEMENT PLANTINGS SILVER LAKE AREA GENERAL ELECTRIC COMPANY – PITTSFIELD, MASSACHUSETTS

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Photograph 1: Outfall to the Housatonic River; Indication of exposed geotextile fabric (Area 1)

Photograph 2: Parcel I9-9-9; Indication of minor soil erosion near top of bank (east of fence) (Area 2)



Photograph 3: Parcel I9-9-9; Indication of minor soil erosion above top of bank (east of fence) (Area 3)

Photograph 4: Parcel I9-10-8; Indication of bare spots and uneven grade on bank near fence (Area 4)



Photograph 5: Parcel I9-10-8; Indication of bare spots and uneven grade on bank near fence (Area 4)

Photograph 6: Parcel I9-10-8; Indication of uneven grading, minor soil erosion, and bare spots on bank (Area 5)



Photograph 7: Parcel I9-9-35 and -36; Indication of settlement around guardrail posts (various locations) (Area 6)

Photograph 8: Parcel I9-9-35; Indication of exposed abandoned outfall and bare spots (Area 7)



Photograph 9: Parcel I9-9-30; Indication of minor soil erosion under fence (Area 8)

Photograph 10: Parcel I9-9-22; Indication of soil erosion on east side of swale (Area 9)



Photograph 11: Parcel I9-9-22; Indication of minor soil erosion between swales (Area 10)

Attachment C

ATTACHMENT C PHOTOGRAPHIC LOG OF NON-NATURAL RESOURCE RESTORATION/ENHANCEMENT PLANTINGS INITIAL POST-REMEDIATION INSPECTION AND SPRING 2014 INSPECTION OF SHORELINE ARMOR SYSTEM, BACKFILLED/RESTORED AREAS ADJACENT TO SILVER LAKE, AND NON-NATURAL RESOURCE RESTORATION/ENHANCEMENT PLANTINGS SILVER LAKE AREA GENERAL ELECTRIC COMPANY – PITTSFIELD, MASSACHUSETTS

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Photograph 1: Parcel I9-9-27; View of plantings and shoreline, looking west from east end.

Photograph 2: Parcel I9-9-27; Indication of stressed burning bushes (Area 11).







Photograph 5: Parcel I9-9-21, 22, 23; View of plantings and shoreline, looking west from east end.

Photograph 6: Parcel I9-9-19; View of plantings and shoreline on west shore of Outlet, looking west. Indication of unestablished ground cover (Area 12).



Photograph 7: Parcel I9-9-18; View of plantings and shoreline, looking southwest from east end.

Photograph 8: Parcel I9-9-17; View of plantings and shoreline, looking northwest from east end.




Photograph 10: Parcel I9-9-9; View of Plantings and shoreline, looking southwest from east end.



Photograph 11: Parcel I9-9-1; View of restored lawn area, looking southeast from north end.

October 2, 2014 SL Natural Resource Restoration/ Enhancement (NRRE) Installation Inspection and Spring 2014 Inspection of NRRE Plantings – Revised Report

October 02, 2014

Ms. Karen Pelto Lead Administrative Trustee Bureau of Waste Site Cleanup Massachusetts Department of Environmental Protection One Winter Street, 8th Floor Boston, Massachusetts 02108


GE Corporate

159 Plastics Avenue Pittsfield, MA 01201 USA

Natural Resource Restoration/Enhancement (NRRE) Installation Inspection and Spring 2014 Inspection of NRRE Plantings- Revised Report

Dear Ms. Pelto:

Pursuant to the requirements set forth in the October 2000 Consent Decree (CD) for the GEPittsfield/Housatonic River Site (the Site) and the accompanying Statement of Work for Removal Actions Outside the River (SOW), the General Electric Company (GE) implemented a Removal Action at the Silver Lake Area Removal Action Area (RAA) between July 2012 and December 2013. The Removal Action implemented at the Silver Lake Area included removal of selected sediments, installation of a sediment cap and associated armor layer, and removal/replacement of soil in certain areas on the banks and otherwise adjacent to the lake to meet established Performance Standards, followed by restoration of those areas. In addition, as required by the CD, GE installed a number of natural resource restoration/enhancement (NRRE) measures at the Silver Lake Area, including creation of a shallowwater shelf along the shoreline of the lake, installation of a number of plantings on the shrub-scrub "island" near the discharge outfall and on the banks on the northern and eastern sides of the lake, and construction of a walking path and benches on the northern and eastern sides of the lake. Those NRRE measures were described in a Revised Completion of Installation of Restoration Work Report (Revised CIRW Report) which GE submitted to the natural resource trustees (the Trustees) on May 23, 2014 and was approved by the Trustees on September 3, 2014. The CD and SOW also require monitoring and maintenance of both the NRRE measures and the non-NRRE measures installed at the Silver Lake Area following completion of the Removal Action.

On July 18, 2014, GE submitted to the Trustees a letter report summarizing the spring monitoring activities conducted for the NRRE measures in late May 2014. (A separate letter was submitted to the U.S. Environmental Protection Agency (EPA) on June 25, 2014 describing the spring 2014 monitoring of the non-NRRE measures.) The Trustees conditionally approved GE's July 18 report by letter dated September 3, 2014, and requested that a revised letter report on the May NRRE inspections be submitted by November 4, 2014. GE has revised the July 18 letter report based on the Trustees' comments, and is submitting this revised letter report to summarize the NRRE installation inspection and spring 2014 inspection of NRRE plantings.

Paragraph 119 of the CD requires the preparation of a Restoration Project Monitoring and Maintenance Plan for NRRE measures. The Performance Standards and other requirements for such monitoring and maintenance were set forth in Section 8 of Attachment I to the SOW and subsequently modified in correspondence from EPA. In satisfaction of those requirements (as well as the separate requirements for Post-Removal Site Control activities for non-NRRE measures), GE submitted a Post-Removal Site Control Plan/Restoration Project Monitoring and Maintenance Plan (PRSCP/RPMMP) as Appendix I of

Corporate Eruu::Jnmentol ProqrsJrn"

Karen Pelto October 2, 2014

Page 2 of6

GE's August 2011 Revised Final Removal Design/Removal Action Work Plan for Silver Lake Area (Revised Final Work Plan), which was conditionally approved by EPA on August 25, 2011. That PRSCP/RPMMP included (in Section 3) a description of the monitoring and maintenance activities to be conducted for the NRRE measures installed at the Silver Lake Area.

Subsequently, the applicable requirements for monitoring of the NRRE measures were modified in certain respects based on developments after EPA's approval of the Revised Final Work Plan and discussions among GE, the Trustees, and EPA. The updated monitoring and maintenance requirements for the NRRE measures were summarized in the May 23, 2014 Revised CIRW Report.

Paragraph 120 of the CD requires that, after the submittal of a CIRW Report, an installation inspection/meeting be scheduled and attended by GE, EPA, and the Trustees. That inspection/meeting is to be followed by the Trustees' determination of whether the installation of the restoration work has been completed in accordance with the applicable requirements and Performance Standards of the CD. The PRSCP/RPMMP, as modified by the Revised CIRW Report, also requires GE to perform periodic inspections of the plantings installed in the NRRE areas as well as the walking path and benches. Specifically, it requires inspections of the NRRE plantings semi-annually (in May and August or September) for a three-year period after planting, once during the fifth year after planting, and once during the seventh year after planting; and it requires inspections of the walking path and benches annually for the first three years after installation. 1 For purposes of the inspections of the NRRE plantings, certain specified monitoring areas, as well as designated monitoring plots within those areas, were established around the northern and eastern sides of the lake in coordination with EPA and the Trustees.

EPA and the Trustees agreed that, for the Silver Lake Area, the NRRE installation inspection/meeting could be combined with the first semi-annual inspection of the NRRE plantings. The NRRE installation inspection/meeting was held on May 27, 2014; and on that day and the two following days (May 28 and 29), GE conducted the first of the 2014 semi-annual inspections of the NRRE plantings. 2 The monitoring activities were performed by Mark Gravelding (May 27 only), Anthony Esposito, and Eric Ungberg of ARCADIS (on GE's behalf). This monitoring event was also attended by Michael Argue of Weston Solutions, Inc. on EPA's behalf and by the following on behalf of the Trustees: Michael Backunas of the Massachusetts Department of Environmental Protection (MDEP) on May 27 and Kenneth Munney of the U.S. Fish and Wildlife Service on May 28 and 29. In addition, James McGrath and Robert Van Der Kar of the City of Pittsfield were present for portions of the M ay 29 monitorin g activities. This letter summarizes those inspection and monitoring activities and describes the findings.

Description and Results of NRRE Installation Inspection and Spring 2014 Monitoring Event

This section describes and presents the results of the May 27 through 29, 2014 inspections of the NRRE measures and, in particular, the NRRE vegetation; and, where warranted, it presents GE's plans for follow-up actions. The locations of the NRRE measures that were inspected, including the designated monitoring areas and monitoring plots for the NRRE plantings, are shown on Figure 1. A completed inspection checklist documenting the May 2014 NRRE inspection is included as Attachment A to this letter (using the checklist form attached to the Revised CIRW Report), and photographic logs of the inspection are provided in Attachment 8 (as described below).

1 As discussed in the Revised CIRW Report, the shallow-water shoreline shelf was previously monitored following installation, and no further inspections of this NRRE feature are required. 2 As discussed further below, the 2014 monitoring of the walking path and benches and the second of the 2014 inspections of the NRRE plantings were subsequently conducted on September 4, 2014. A report on those inspections will be submitted in the near future.

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NRRE Installation Inspection


Page 3 of6

On May 27 and 28, 2014, a stem count was completed for all NRRE trees and shrubs that were installed at the Silver Lake Area. A table summarizing the results of this stem count (organized by monitoring area) is provided in Table 1. This information is presented for informational purposes only, since, as provided in the Revised CIRW Report and discussed further below, the quantitative assessment of those plantings will be conducted within the more limited monitoring plots, and thus the number of trees and shrubs counted within those plots will serve as the baseline for percent survival calculations in future quantitative monitoring events.

In addition to the stem count, visual observations of the overall conditions of the NRRE installations were made and, where warranted, discussed in the field. This visual assessment indicated that there were some areas where topsoil and seeding that were required to have been placed in the exposed void spaces of the armor stone above the water surface elevation of 975.9 feet National Geodetic Vertical Datum of 1929 (NGVD29) around the perimeter of the shrub-scrub island had not been installed or was missing. Specifically, while the voids in the stone at higher elevations were observed to be filled with topsoil and seeded with a mixture of herbaceous wetland species, and this vegetation was growing as intended, the topsoil and seed mixture did not appear to fill the voids in the armor stone down to the apparent 975.9 foot elevation (Figure 1; Photos 1 and 2 of Attachment B). Based on discussions with EPA's representative that performed oversight during the Removal Action, the lack of coverage at lower elevations was due to above-average water surface elevations in Silver Lake at the time of installation. As a result, the lower portion of the armor stone around the periphery of the shrub-scrub island (i.e., between the vegetated armor stone and the approximate contour of 975.9 feet NGVD29) could not be filled with topsoil or seeded at the time of installation. Therefore, GE proposed to fill the voids in the armor stone around the periphery of the shrub-scrub island between the area already vegetated and the approximate 975.9 feet NGVD29 elevation contour with topsoil and seed containing a mixture of herbaceous wetland species to satisfy the requirement for this area. This area is identified as Area 1 on Table 2.

With the exception of the need for additional topsoil and seeding in the voids of the armor stone around the periphery of the shrub-scrub island, it was concluded that the other NRRE measures at the Silver Lake Area had been installed in accordance with the applicable Performance Standards and other requirements of the CD.

NRRE Vegetation Monitoring

In accordance with the PRSCP/RPMMP as modified in the Revised CIRW Report, the spring 2014 monitoring of the NRRE vegetation consisted of both a qualitative field inspection of the NRRE areas where plantings were installed and a quantitative assessment (i.e., counts) of the plantings within the specific monitoring plots established within the NRRE areas, as described further below. Personnel conducting the inspection were supported by Chris Frank of C.L. Frank & Company as the certified arborist.

Qualitative Assessment

For the qualitative assessment, field personnel conducted a meander survey of the overall NRRE planting areas to observe overall conditions of the vegetation within those areas. During this qualitative assessment, no areas were noted with indications of significant damage from trespassing or herbivory. However, a narrow pathway of sparse and worn-through vegetation was observed on the slope between the walking path and the lake along the north-central portion of the lake. The ground in this area was not completely bare, and it was noted that this area would be expected to continue to re-vegetate. As a result, re-seeding is not considered necessary at this time. Additionally, as discussed further below, some areas adjacent to the walkway were observed with sparse vegetation; however, it appeared that most of this area had recently been re-seeded.

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Page 4 of6

The presence of invasive species, as listed in Attachment C (or any others listed by the Massachusetts Invasive Plant Advisory Group [MIPAG] as "invasive," "likely invasive," or "potentially invasive"), was noted in some of the NRRE areas, but did not constitute a significant percentage of the established ground cover, as described further under the quantitative assessment below.

Quantitative Assessment

The quantitative assessment was conducted within designated monitoring plots established within four monitoring areas in the overall NRRE areas. The four monitoring areas consist of three areas that are co-extensive with the three tax parcels that comprise the NRRE areas (i.e., Parcels 19-10-9, 19-9-36, and 19-9-35) plus the shrub-scrub island. Within each monitoring area, monitoring plots were established based on the size and types of plantings in each area, as follows:


• Parcel 19-9-35 Area (excluding the overlap with the shrub-scrub island area) -four monitoring plots, each approximately 60 feet long, in the area between the lake and Silver Lake Boulevard;

• Parcel 19-9-36 Area (excluding the overlap with the shrub-scrub island area)- four monitoring plots, each approximately 60 feet long, bounded by Silver Lake Boulevard on the north and the lake on the south; and


The locations of the monitoring plots are shown on Figure 1. The actual boundaries of the monitoring plots were established by survey in the field prior to the installation inspection/meeting. Within each designated monitoring plot, field personnel: ( 1) performed a stem count of planted trees and shrubs to identify live and dead plantings (as well as any stressed plantings); (2) estimated the areal extent of groundcover by native herbaceous species; and (3) determined the presence of, and estimated percent coverage by, invasive species, as listed in Attachment C (or any others listed by the MIPAG as "invasive," "likely invasive," or "potentially invasive").

In accordance with the Revised CIRW Report, the results from the quantitative assessment of the individual monitoring plots were combined to estimate percent survival, percent coverage by native herbaceous species and percent coverage by invasive species for each of the four monitoring areas. Those results were then compared to the Performance Standards specified in the SOW and summarized in the Revised CIRW Report- namely, 80% survival for the planted trees and shrubs, 100% coverage by native herbaceous species (outside the foliar coverage of the trees}, and less than 5% coverage by invasive species

The results of the quantitative NRRE vegetation monitoring event are presented on the Form A-1s in Attachment A and summarized in Tables A-1 and A-2 in that attachment. As indicated in those forms, no dead trees or shrubs were observed in any of the monitoring plots. In this situation, and since the May 2014 inspection was the initial inspection of the quantity of planted trees and shrubs in each monitoring plot (i.e., the actual number and species of plantings in each plot had not been established prior to the inspection), the counts of live trees and shrubs in the monitoring plot will be used to establish a baseline number of plantings for percent survival calculations in subsequent monitoring events.

Two specific areas of plantings were identified during the spring 2014 NRRE vegetation inspection as warranting follow-up actions or close additional monitoring. These areas and recommended follow-up actions are discussed below and summarized in Table 2.

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Area 2 - Buttonbush Plantings on the Shrub-Scrub Island - The majority of the buttonbush shrubs on the shrub-scrub island exhibited very few leaves, and the leaves that were present were in early stages of development (Figure 1; Attachment B Photos 3 and 4). Upon inspection, the certified arborist determined that the plants were healthy, but exhibiting delayed development (buttonbush plants often leaf out later than the other shrub species planted on the island, such as red-osier dogwoods. As a result, no re-planting is proposed for Area 2 at this time. It was recommended that the status and health of the buttonbush shrubs be re-evaluated during the summer 2014 monitoring inspection.

Area 3 - Large Trees along Eastern Bank of Silver Lake- Six red oak trees in the 19-9-35 monitoring area, including one within the 19-9-35-2 monitoring plot and one within the 19-9-35-3 monitoring plot, were observed to be stressed with no, or very few, leaves present (Figure 1; Attachment B Photos 5 and 6). The certified arborist concluded that all six were alive, and recommended some pruning of dead and co-dominant branches to improve long-term form and structure. The arborist also recommended regular watering to keep the roots moist and encourage leaf development and longterm health. It was also recommended that the status and health of these red oak trees be reevaluated during the summer 2014 monitoring inspection.

Additionally, during the inspection, tree cages, tree guards, and tree stakes (where present) were inspected and were generally found to be functioning to protect the trees from damage. One sugar maple tree on Parcel 19-9-35, just north of the Pittsfield Economic Development Authority outfall, was observed not to be wrapped, and was proposed to be addressed as part of GE's tree cage maintenance program for the restored and re-vegetated areas.

As shown in Attachment A, based on the May 2014 inspection, the percent coverage by native herbaceous species in each monitoring area (based on the results from the monitoring plots within them) is below the Performance Standard of 100% (outside the foliar coverage of the trees). As indicated in Table 2, the areas with sparse grass cover included several areas above the top of bank near the walking path, as well as one area in the southeast corner of the lake. Most of the sparsely vegetated areas adjacent to the walking path appeared to have been recently re-seeded prior to the inspection (see Attachment B, Figures 7 and 8). It is anf1cipated that those and the other sparsely vegetated herbaceous areas will continue to re-vegetate. In these circumstances, it was concluded that additional re-seeding at this time is not necessary, and that the establishment of herbaceous cover in these areas be re-evaluated during the summer 2014 vegetation inspection.

With the exception of the shrub-scrub island monitoring plots SSI-1 and SSI-2 and monitoring plot 19-9-36-3, all other monitoring plots observed during the spring 2014 NRRE monitoring event were noted to have at least one invasive species present, but usually only a few individuals of such invasive species. Observed invasive species included autumn olive, coltsfoot, cypress spurge, garlic mustard, Japanese knotweed, multiflora rose, oriental bittersweet, purple loosestrife, and yellow iris. As shown in Attachment A, invasive species cover exceeded the Performance Standard of 5% in only one monitoring area (19-10-9), based on the invasive species present in one monitoring plot (19-10-9-1 at 5-10% cover). The invasive species observed in this monitoring plot, as well as throughout the NRRE area, were slated for treatment as part of GE's general invasive species control program for the restored and re-vegetated areas at the Silver Lake Area (as described in the Revised CIRW Report).

Post-Inspection and Future Activities

In accordance with the PRSCP/RPMMP, as modified by the Revised CIRW Report, GE has conducted the majority of the maintenance activities identified above and summarized in Table 2, and anticipates implementing the remainder of the maintenance activities within the next week. The maintenance activities performed will be documented in the summer 2014 inspection report.

This spring 2014 inspection fulfilled the requirements for the first post-construction monitoring event for the plantings in the NRRE area. GE has continued and will continue with the NRRE monitoring activities

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on the schedule specified in the PRSCP/RPMMP and the Revised CIRW Report until replaced by the NRRE monitoring requirements specified in the Final Completion Report for the Silver Lake Area Removal Action. The next scheduled inspection of the NRRE plantings, along with the first monitoring annual event for the walking path and benches, were performed on September 4, 2014, and a report on those activities will be submitted to the Trustees within the near future.


Sincerely,

3~/Por Senior Project Manager- Environmental Remediation

Attachments

cc: Dean Tagliaferro, EPA Tim Conway, EPA** Dave Dickerson, EPA Chris Ferry, ASRC Primus** Scott Campbell, Avatar (2 hard copies)** Robert Leitch, USACE** Michael Gorski, MDEP** John Ziegler, MDEP (2 hard copies)** Eva Tor, MDEP** Nancy E. Harper, MA AG* Kenneth Munney, USFWS** Susan Peterson, CT DEEP** Doug Clark, Director, Pittsfield Dept. of

Community Development** Nate Joyner, Pittsfield Dept. of Community

Development**

James McGrath, Pittsfield Dept. of Parks and Recreation**


* without attachments **electronic copy

0:\GE\GE_Silver_Lake\Reports and Presentations\2014-10 NRRE report- REV\2011411214_SL Spr NRRE Insp REV.doc

Tables

9/30/2014G:\GE\GE_Silver_Lake\Reports and Presentations\2014-10 NRRE report - REV\2011411214_Table 1 REV.xlsx Page 1 of 1

Dates of Inspection: May 27 and May 28, 2014

ApproximateMonitoring Area Total Total

Area (acres) BW SiM EC SuM RO RM Trees ROD SD WH CC NA NV SB BCB PW SA BB Shrubs

I9-10-9 Area 0.19 4 2 2 0 0 0 8 98 0 18 0 20 0 0 0 0 0 0 136

I9-9-36 Area 1.0 0 0 0 0 0 0 0 353 24 126 26 117 24 29 25 13 15 0 752

Shrub-Scrub Island Area 0.49 0 0 0 0 0 0 0 1,012 0 2 0 0 0 0 0 0 0 567 1,581

I9-9-35 Area 0.97 10 0 2 12 10 6 40 258 5 60 6 53 8 7 8 2 2 0 409

48 2,878Notes:


2. The information in this table is provided for informational purposes only. The baseline quantity of trees and shrubs for evaluation of percent survival in subsequent monitoring events will be established for the individual monitoring plots.

1. The number of trees and shrubs listed in this table includes all live trees and shrubs counted in each monitoring area. While two dead northern arrowwoods were observed in the I9-9-35 area, they are not listed since the total quantity of this species planted in that area was greater than the quantity required by the Trustee-approved planting plan.


TABLE 1RESULTS OF NRRE INSTALLATION INSPECTION STEM COUNTS

NATURAL RESOURCE RESTORATION/ENHANCEMENT INSTALLATION INSPECTION AND SPRING 2014 INSPECTION OF NATURAL RESOURCE RESTORATION/ENEHANCEMENT PLANTINGS

GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTSSILVER LAKE AREA

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Area/Item Identified Description Proposed Follow-up Action

1 - Perimeter of Shrub-Scrub Island

The voids in a portion of the armoring around the shrub-scrub island perimeter, down to the approximate 975.9 foot contour, were not filled with topsoil and seed during the Removal Action.

In the area between the existing vegetation and the approximate 975.9 foot contour, fill voids with topsoil and seed with wetland seed mix.

2 - Buttonbush Plantings on Shrub-Scrub Island

Buttonbush plantings on Shrub-Scrub Island appeared stressed, possibly due to late-leafing.

Re-evaluate during the summer 2014 monitoring inspection.

3 - Large Trees along Eastern Bank of Silver Lake

Six trees appeared to be stressed with few and/or poorly developed leaves.

Water the large trees on a regular basis. Prune off dead or co-dominant stems, as necessary. Re-evaluate during the summer 2014 inspection.

Herbaceous Vegetative Cover

Sparse grass cover was observed in a number of areas, resulting in failure to meet the 100% Performance Standard for coverage by native herbaceous species in any monitoring area. These sparsely covered areas included several areas above the top of bank near the walking path, as well as one area in the southeast corner of the lake. The majority of these areas appeared to have been recently hydroseeded and were showing signs of grass establishment. Re-seeding is not considered necessary at this time.

Re-evaluate during the summer 2014 vegetation inspection.

Invasive Species Invasive species observed in most monitoring plots, but less than 5% coverage except in monitoring plot I9-10-9-1, where coverage was 5% to 10%.

Treat invasive species as part of GE’s invasive species control program.

TABLE 2

NATURAL RESOURCE RESTORATION/ENHANCEMENT INSTALLATION INSPECTION AND SPRING 2014 INSPECTION OF NATURAL RESOURCE RESTORATION/ENHANCEMENT PLANTINGS



Figure

I9-10-9

AREA

I9-9-36

AREA

I9-9-35

AREA

SHRUB-SCRUB

ISLAND AREA

I9-9-35-2

I9-9-35-1

I9-9-35-3

I9-9-35-4

SSI-2

SSI-1

I9-9-36-3

I9-9-36-2

I9-9-36-1

I9-9-36-4

I9-10-9-2

I9-10-9-1

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RESULTS OF SPRING 2014 INSPECTION OF

NATURAL RESOURCE

RESTORATION/ENHANCEMENT MEASURES


SILVER LAKE AREA

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Attachment A

9/30/2014G:\GE\GE_Silver_Lake\Reports and Presentations\2014-10 NRRE report - REV\2011411214_Attachment A - Checklist A-1 and tables A-1 REV.xls Page 1 of 1

ATTACHMENT AINTERIM CHECKLIST FOR INSPECTION OF NATURAL RESOURCE RESTORATION/ENHANCEMENT MEASURES



Inspection Date: 5/27/2014 - 5/29/2014Conducted By: Anthony EspositoWeather Conditions: 65 degrees and overcast, slight drizzle


A.

Majority of plantings looked healthy. Six large ornamental trees on east side appeared stressed; with few leaves. Buttonbush on shrub-scrub island appeared stressed; however it was determined the shrub was likely late in leafing out.Grass areas along walkway exhibited sparse coverage but appeared to be recently re-seeded.Two dead shrubs, eight stressed shrubs, and one stressed tree were observed in addition to the stressed plants listed above.

B.

No herbivore damage observed.Narrow pathway of sparse and worn-through vegetation observed along northern shoreline between walking path and lake.

Indications of sparse vegetation were observed in several areas, including areas near the walking path (most of which appeared to have been recently re-seeded) and one area in the southeast corner of the lake. See attached forms and tables regarding percent

cover by native herbaceous species.C.

Cypress spurge, Coltsfoot, Garlic Mustard, Oriental Bittersweet, Yellow Iris, Japanese Knotweed, Multiflora Rose, Russian Olive, and Purple Loosestrife observed in small concentrations throughout NRRE Areas.

2.

3.

Not inspected during spring 2014 monitoring event; will be inspected in summer 2014.

4.

Not Applicable

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIESAround shrub-scrub island fill voids in armoring that are not already filled with topsoil and seed.Evaluate the status and health of large ornamental trees along the eastern portion of the NRRE Area during the summer inspection.

Evaluate the status and health of buttonbush planted on the shrub-scrub island during the summer inspection.Evaluate the status and percent coverage of the native herbaceous cover during the summer inspection.Treat invasive species as part of GE’s invasive species control program.Wrap sugar maple on Parcel I9-9-35, just north of PEDA outfall, as part of GE’s tree cage maintenance program.Prune and water the large trees along the eastern bank of Silver Lake.

Indications of Sparse Vegetation or Damage from Trespassing or Herbivory (Note evidence of areas of bare/sparse vegetation; note any damage from trespassing or herbivory; note any physical changes since completion of the restoration.)


Restored Trees and Shrubs (Note any physical changes since completion of the restoration; note condition of trees and shrubs planted during restoration activities; note general condition of any tree guards, tree cages, and/or tree stakes, if present.)





FORM A-1



Page ___1____ of ______12____

Inspection Date: ___May 28, 2014 ____________________________________________________________ Conducted By/Observer(s): Anthony Esposito and Eric Ungberg of ARCADIS, Michael Argue of Weston Solutions, Inc., Kenneth Munney of US Fish and Wildlife Services _________ Weather Conditions: ________65 degrees and overcast, slight drizzle_______________________________________ Monitoring Area: I9-10-9 Area Approximate Size (sf): 8,400 _ Monitoring Plot: I9-10-9-1 Approximate Size (sf): 730 _ Stem Count:





Black willow 0 0 0

Red-osier dogwood 18 2 0

Silver maple 0 0 0

Silky dogwood 0 0 0

Eastern cottonwood 0 0 0

Winterberry Holly 4 0 0

Sugar maple 0 0 0

Choke cherry 0 0 0

Red oak 0 0 0

Northern arrowwood 5 0 0

Red maple 0 0 0

Nannyberry viburnum 0 0 0

Serviceberry 0 0 0

Black chokeberry 0 0 0

Pussy-willow 0 0 0

Speckled alder 0 0 0

Buttonbush 0 0 0

Total Live Trees: _______________0_____________ Total Live Shrubs: ____________29_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________85%___________ Invasive Plant Cover (%): ___________5% - 10%__________

FORM A-1



Page ___2____ of ______12____

Inspection Date: ___May 28, 2014 ____________________________________________________________ Conducted By/Observer(s): Anthony Esposito and Eric Ungberg of ARCADIS, Michael Argue of Weston Solutions, Inc., Kenneth Munney of US Fish and Wildlife Service Weather Conditions: ________65 degrees and overcast, slight drizzle_______________________________________ Monitoring Area: I9-10-9 Area Approximate Size (sf): 8,400 _ Monitoring Plot: I9-10-9-2 Approximate Size (sf): 1,890 _ Stem Count:





Black willow 2 0 0


Silver maple 2 0 0

Silky dogwood 0 0 0



Sugar maple 0 0 0

Choke cherry 0 0 0

Red oak 0 0 0


Red maple 0 0 0


Serviceberry 0 0 0


Pussy-willow 0 0 0


Buttonbush 0 0 0

Total Live Trees: _______________4_____________ Total Live Shrubs: ____________29_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________65%___________ Invasive Plant Cover (%): ___________<5%__________

FORM A-1



Page ___3____ of ______12____

Inspection Date: ___May 28, 2014 ____________________________________________________________ Conducted By/Observer(s): Anthony Esposito and Eric Ungberg of ARCADIS, Michael Argue of Weston Solutions, Inc., Kenneth Munney of US Fish and Wildlife Services _________ Weather Conditions: ________65 degrees and overcast, slight drizzle_______________________________________ Monitoring Area: I9-9-36 Area Approximate Size (sf): 44,400 _ Monitoring Plot: I9-9-36-1 Approximate Size (sf): 2,320 _ Stem Count:





Black willow 0 0 0


Silver maple 0 0 0

Silky dogwood 2 0 0



Sugar maple 0 0 0

Choke cherry 3 0 0

Red oak 0 0 0


Red maple 0 0 0


Serviceberry 2 0 0


Pussy-willow 0 0 0


Buttonbush 0 0 0

Total Live Trees: _______________0_____________ Total Live Shrubs: ____________55_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): ____60% to 85% ___________ Invasive Plant Cover (%): ___________ 5%__________

FORM A-1



Page ___4____ of ______12____






Black willow 0 0 0


Silver maple 0 0 0

Silky dogwood 2 0 0



Sugar maple 0 0 0

Choke cherry 0 0 0

Red oak 0 0 0


Red maple 0 0 0


Serviceberry 2 0 0


Pussy-willow 1 0 0


Buttonbush 0 0 0

Total Live Trees: _______________0_____________ Total Live Shrubs: ____________52_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________60% to 95% ___________ Invasive Plant Cover (%): ___________ <1%_________

FORM A-1



Page ___5____ of ______12____






Black willow 0 0 0


Silver maple 0 0 0

Silky dogwood 1 0 0



Sugar maple 0 0 0

Choke cherry 2 0 0

Red oak 0 0 0


Red maple 0 0 0


Serviceberry 1 0 0


Pussy-willow 2 0 0


Buttonbush 0 0 0

Total Live Trees: _______________0_____________ Total Live Shrubs: ____________46_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________60% to 75% ___________ Invasive Plant Cover (%): ___________ 0%__________

FORM A-1



Page ___6____ of ______12____






Black willow 0 0 0


Silver maple 0 0 0

Silky dogwood 2 0 0



Sugar maple 0 0 0

Choke cherry 3 0 0

Red oak 0 0 0


Red maple 0 0 0


Serviceberry 2 0 0


Pussy-willow 0 0 0


Buttonbush 0 0 0

Total Live Trees: _______________0_____________ Total Live Shrubs: ____________43_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________70% to 75%___________ Invasive Plant Cover (%): ___________ <5%__________

FORM A-1



Page ___7____ of ______12____

Inspection Date: ___May 28 and 29, 2014 ____________________________________________________________ Conducted By/Observer(s): Anthony Esposito and Eric Ungberg of ARCADIS, Michael Argue of Weston Solutions, Inc., Kenneth Munney of US Fish and Wildlife Service, Chris Frank of C.L. Frank & Company (May 29 only), James McGrath and Robert Van Der Kar of the City of Pittsfield (May 29 only) Weather Conditions: ________65 degrees and overcast, slight drizzle_______________________________________ Monitoring Area: Shrub-Scrub Island Area Approximate Size (sf): 21,400 _ Monitoring Plot: SSI-1 Approximate Size (sf): 500 _ Stem Count:





Black willow 0 0 0


Silver maple 0 0 0

Silky dogwood 0 0 0



Sugar maple 0 0 0

Choke cherry 0 0 0

Red oak 0 0 0


Red maple 0 0 0


Serviceberry 0 0 0


Pussy-willow 0 0 0


Buttonbush 0 3 0

Total Live Trees: _______________0_____________ Total Live Shrubs: ____________37_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________85%___________ Invasive Plant Cover (%): ___________ 0%_____ ___

FORM A-1



Page ___8____ of ______12____

Inspection Date: ___May 28 and 29, 2014 ____________________________________________________________ Conducted By/Observer(s): Anthony Esposito and Eric Ungberg of ARCADIS, Michael Argue of Weston Solutions, Inc., Kenneth Munney of US Fish and Wildlife Service, Chris Frank of C.L. Frank & Company (May 29 only), James McGrath and Robert Van Der Kar of the City of Pittsfield (May 29 only) Weather Conditions: ________65 degrees and overcast, slight drizzle_______________________________________ Monitoring Area: Shrub-Scrub Island Area Approximate Size (sf): 21,400 _ Monitoring Plot: SSI-2 Approximate Size (sf): 500 _ Stem Count:





Black willow 0 0 0


Silver maple 0 0 0

Silky dogwood 0 0 0



Sugar maple 0 0 0

Choke cherry 0 0 0

Red oak 0 0 0


Red maple 0 0 0


Serviceberry 0 0 0


Pussy-willow 0 0 0


Buttonbush 0 16 0

Total Live Trees: _______________0_____________ Total Live Shrubs: ____________40_______________

Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________80%___________ Invasive Plant Cover (%): ___________ 0%_____ ___

FORM A-1



Page ___9____ of ______12____






Black willow 0 0 0


Silver maple 0 0 0

Silky dogwood 2 0 0



Sugar maple 0 0 0

Choke cherry 1 0 0

Red oak 0 0 0


Red maple 0 0 0


Serviceberry 1 0 0


Pussy-willow 1 0 0


Buttonbush 0 0 0

Total Live Trees: _______________0_____________ Total Live Shrubs: ____________38_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________40% to 60% ___________ Invasive Plant Cover (%): ___________ <5%__________

FORM A-1



Page ___10____ of ______12____

Inspection Date: ___May 28 and 29, 2014 ____________________________________________________________ Conducted By/Observer(s): Anthony Esposito and Eric Ungberg of ARCADIS, Michael Argue of Weston Solutions, Inc., Kenneth Munney of US Fish and Wildlife Service, Chris Frank of C.L. Frank & Company (May 29 only), James McGrath and Robert Van Der Kar of the City of Pittsfield (May 29 only) Weather Conditions: ________65 degrees and overcast, slight drizzle_______________________________________ Monitoring Area: I9-9-35 Area Approximate Size (sf): 42,400 _ Monitoring Plot: I9-9-35-2 Approximate Size (sf): 1,780 _ Stem Count:





Black willow 0 0 0


Silver maple 0 0 0

Silky dogwood 0 0 0



Sugar maple 3 0 0

Choke cherry 0 0 0

Red oak 2 1 0


Red maple 0 0 0


Serviceberry 0 0 0


Pussy-willow 0 0 0


Buttonbush 0 0 0

Total Live Trees: _______________6_____________ Total Live Shrubs: ____________15_______________

Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________65% to 70% ___________ Invasive Plant Cover (%): ___________ <5%__________

FORM A-1



Page ___11____ of ______12____






Black willow 0 0 0


Silver maple 0 0 0

Silky dogwood 0 0 0



Sugar maple 2 0 0

Choke cherry 0 0 0

Red oak 1 1 0


Red maple 1 0 0


Serviceberry 0 0 0


Pussy-willow 0 0 0


Buttonbush 0 0 0

Total Live Trees: _______________5_____________ Total Live Shrubs: ____________15_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________60% to 85% ___________ Invasive Plant Cover (%): ___________ 5% __________

FORM A-1



Page ___12____ of ______12____






Black willow 2 0 0


Silver maple 0 0 0

Silky dogwood 0 0 0



Sugar maple 0 0 0

Choke cherry 0 0 0

Red oak 0 0 0


Red maple 0 0 0


Serviceberry 0 0 0


Pussy-willow 0 0 0


Buttonbush 0 0 0

Total Live Trees: _______________3_____________ Total Live Shrubs: ____________13_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________35% to 55% ___________ Invasive Plant Cover (%): ___________ <5%__________

9/30/2014G:\GE\GE_Silver_Lake\Reports and Presentations\2014-10 NRRE report - REV\2011411214_Attachment A - Checklist A-1 and tables A-1 REV.xls Page 1 of 1

Dates of Monitoring: May 27 through May 29, 2014


Average Width Area Total Total Herbaceous Invasive Plant


I9-10-9-1 65 11 730 0 0 0 0 0 0 0 20 0 4 0 5 0 0 0 0 0 0 29 85% 5-10%

I9-10-9-2 60 29 1,886 2 2 0 0 0 0 4 19 0 5 0 5 0 0 0 0 0 0 29 65% <5%

I9-9-36-1 59 41 2,322 0 0 0 0 0 0 0 26 2 10 3 9 1 2 2 0 0 0 55 60-85% 5%

I9-9-36-2 57 45 2,491 0 0 0 0 0 0 0 25 2 10 0 9 1 2 0 1 2 0 52 60-95% <1%

I9-9-36-3 61 33 1,878 0 0 0 0 0 0 0 23 1 8 2 7 0 1 0 2 2 0 46 60-75% 0%

I9-9-36-4 60 29 1,928 0 0 0 0 0 0 0 17 2 6 3 6 3 2 4 0 0 0 43 70-75% <5%

SSI-1 25 20 500 0 0 0 0 0 0 0 34 0 0 0 0 0 0 0 0 0 3 37 85% 0%

SSI-2 25 20 500 0 0 0 0 0 0 0 24 0 0 0 0 0 0 0 0 0 16 40 80% 0%

I9-9-35-1 59 51 2,965 0 0 0 0 0 0 0 17 2 5 1 5 2 1 3 1 1 0 38 40-60% <5%

I9-9-35-2 63 28 1,777 0 0 0 3 3 0 6 15 0 0 0 0 0 0 0 0 0 0 15 65-70% <5%

I9-9-35-3 59 34 2,172 0 0 0 2 2 1 5 15 0 0 0 0 0 0 0 0 0 0 15 60-85% 5%

I9-9-35-4 61 27 1,453 2 0 1 0 0 0 3 5 0 4 0 4 0 0 0 0 0 0 13 35-55% <5%

Notes:


1. The number of trees and shrubs listed in this table includes all live trees and shrubs observed within each monitoring plot; no dead trees or shrubs were observed in the monitoring plots during the spring 2014 vegetation inspection.




I9-10-9 Area

I9-9-36 Area


I9-9-35 Area

TABLE A-2 SUMMARY OF QUANTITATIVE ASSESSMENT

SILVER LAKE AREA GENERAL ELECTRIC COMPANY – PITTSFIELD, MASSASCHUSETTS

Dates of Monitoring: May 27-29, 2014

Area Plot No. Trees Shrubs

Herbaceous Cover (%)

Invasive Plant

Cover (%) No.

Planted No.

Alive %

Survival > 80%

Survival No.

Planted No.

Alive %

Survival > 80%

Survival

I9-10-9 I9-10-9-1 0 0 NA -- 29 29 100% -- 85% 5-10% I9-10-9-2 4 4 100% -- 29 29 100% -- 65% < 5% Average -- -- 100% Yes -- -- 100% Yes < 100% > 5%

I9-9-36

I9-9-36-1 0 0 NA -- 55 55 100% -- 60-85% 5% I9-9-36-2 0 0 NA -- 52 52 100% -- 60-95% < 1% I9-9-36-3 0 0 NA -- 46 46 100% -- 60-75% 0% I9-9-36-4 0 0 NA -- 43 43 100% -- 70-75% < 5% Average -- -- NA NA -- -- 100% Yes < 100% < 5%

Shrub-Scrub Island

SSI-1 0 0 NA -- 37 37 100% -- 85% 0% SSI-2 0 0 NA -- 40 40 100% -- 80% 0%

Average -- -- NA NA -- -- 100% Yes < 100% 0%

I9-9-35

I9-9-35-1 0 0 NA -- 38 38 100% -- 40-60% < 5% I9-9-35-2 6 6 100% -- 15 15 100% -- 65-70% < 5% I9-9-35-3 5 5 100% -- 15 15 100% -- 60-85% < 1% I9-9-35-4 3 3 100% -- 13 13 100% -- 35-55% < 5% Average -- -- 100% Yes 20 -- 100% Yes < 100% < 5%

Notes: 1. Average percent survival of trees and shrubs is based on only those plots in which trees or shrubs were planted. 2. Averages not meeting the applicable Performance Standards are highlighted in yellow. 3. NA = Not applicable.

Attachment B

ATTACHMENT B PHOTOGRAPHIC LOG NATURAL RESOURCE RESTORATION/ENHANCEMENT INSTALLATION INSPECTION AND SPRING 2014 INSPECTION OF NATURAL RESOURCE RESTORATION/ENEHANCEMENT PLANTINGS SILVER LAKE AREA GENERAL ELECTRIC COMPANY – PITTSFIELD, MASSACHUSETTS

G:\GE\GE_Silver_Lake\Reports and Presentations\2014-10 NRRE report - REV\2011411214_Attachment B - NRRE Monitoring Photo Log REV.docx Page 1 of 5

Photograph 1: Area 1 – Southwest perimeter of eastern portion of the Shrub-Scrub Island looking northwest.

Photograph 2: Area 1 – Southern perimeter of eastern portion of the Shrub-Scrub Island looking east.



Photograph 3: Area 2 - Buttonbush plants on the Shrub-Scrub Island.

Photograph 4: Area 2 – Buttonbush plants on western portion of Shrub-Scrub Island looking west from center.



Photograph 5: Area 3 - One of the stressed trees in the I9-9-35 Area looking southwest.

Photograph 6: Area 3 - Trees in the I9-9-35 Area looking south.



Photograph 7: Recently hydroseeded area adjacent to walking path in western portion of NRRE Area looking northeast.

Photograph 8: Recently hydroseeded area adjacent to walkway in northeast portion of NRRE Area looking east.



Photograph 9: Northeast portion of in the I9-9-36 Area looking southeast.

Photograph 10: Northwest portion of the I9-9-36 Area, looking east.

Attachment C

9/30/2014G:\GE\GE_Silver_Lake\Reports and Presentations\2014-10 NRRE report - REV\2011411214_Attachment C - InvasiveSpecies REV.xls Page 1 of 1














Notes:

SILVER LAKE AREA



ATTACHMENT CINVASIVE SPECIES OF CONCERN


2. Reference:

October 3, 2014 SL Summer 2014 Inspection of Shoreline Armor System, Backfilled/Restored Areas Adjacent to Silver Lake, and Non-Natural Resource Restoration/Enhancement Plantings

October 3, 2014

Mr. Dave Dickerson Office of Site Remediation and Restoration U.S. Environmental Protection Agency, Region I 5 Post Office Square - Suite 100 Boston, MA 02109-3912


GE Corporate


Summer 2014 Inspection of Shoreline Armor System, Backfilled/Restored Areas Adjacent to Silver Lake, and Non-Natural Resource Restoration/Enhancement Plantings

Dear Mr. Dickerson:

Pursuant to the requirements set forth in the October 2000 Consent Decree (CD) for the GEPittsfield/Housatonic River Site (the Site) and the accompanying Statement of Work for Removal Actions Outside the River (SOW), the General Electric Company (GE) implemented a Removal Action at the Silver Lake Area Removal Action Area (RAA) between July 2012 and December 2013. The Removal Action implemented at the Silver Lake Area included removal of select sediments, installation of a sediment cap and associated armor layer, and removal/replacement of soil in certain areas on the banks and other areas adjacent to the lake to meet established Performance Standards, followed by restoration of those areas. In addition, as required by the CD, GE installed a number of natural resource restoration/enhancement (NRRE) measures at the Silver Lake Area. The CD and SOW require monitoring and maintenance of both the NRRE measures and the non-NRRE measures installed at the Silver Lake Area following completion of the Removal Action. GE conducted the summer 2014 monitoring activities for the non-NRRE measures on September 4, 2014. This letter summarizes those activities. (A separate letter will be submitted to the natural resource trustees [the Trustees] on the summer 2014 monitoring of the NRRE measures.)

The Performance Standards and other requirements for post-construction monitoring and maintenance of the non-NRRE measures at the Silver Lake Area were set forth in Attachments J and K to the SOW. In satisfaction of those requirements (as well as the separate requirements for monitoring and maintenance of the NRRE measures), GE submitted a Post-Removal Site Control Plan/Restoration Project Monitoring and Maintenance Plan (PRSCP/RPMMP) as Appendix I of its August 2011 Revised Final Removal Design/Removal Action Work Plan for Silver Lake Area, which was conditionally approved by the U.S. Environmental Protection Agency (EPA) by letter dated August 25, 2011. That plan included (in Section 2) a description of the Post-Removal Site Control activities for the non-NRRE measures at the Silver Lake Area. 1

The PRSCP/RPMMP required GE to perform periodic inspections of the sediment cap and shoreline armor system installed in the lake, the backfilled/restored areas that were subject to soil removal and replacement activities or were otherwise disturbed by the remediation, and the plantings installed in the non-NRRE areas. Specifically, that plan required monitoring of the cap thickness and integrity annually for the first five years after installation; monitoring of the cap isolation layer during the first and fifth year after construction; monitoring of the shoreline armor system semi-annually for five years after


Corp~,rate Envu Jnment:JI Pr:>grams

Dave Dickerson October 3, 2014

Page 2 of 8

construction; inspection of the backfilled/restored areas adjacent to the lake and other disturbed areas shortly after construction, semi-annually for the first year after construction, and annually thereafter; and inspection of the non-NRRE plantings semi-annually (in May and August or September) for a two year period after planting. The first monitoring event for the non-NRRE measures was performed in May 2014, and a letter summarizing those activities was submitted to the EPA on June 25, 2014, with conditional approval provided by EPA on July 21, 2014.

On September 4, 2014, GE performed the second of the 2014 semi-annual inspections of the shoreline armor system, the second semi-annual inspection of the backfill/restored areas and other disturbed areas, and the second semi-annual inspection of the non-NRRE plantings.2 The monitoring activities were performed by Gregg Rabasco, Anthony Esposito, and Margaret Miller of ARCADIS (on GE's behalf), and the monitoring event was also attended by Dave Dickerson of EPA, Michael Argue of Weston Solutions, Inc. (on EPA's behalf), and Kenneth Munney of the U.S. Fish and Wildlife Service. Personnel conducting the inspection were supported by Chris Frank of C.L. Frank & Company as a certified arborist. This letter summarizes the response actions performed since the May 2014 monitoring event, summarizes the summer 2014 monitoring event, and describes the findings from the summer monitoring event. The locations of the shoreline armor system, the backfilled/restored areas, and the non-NRRE planting areas that were inspected are shown on Figure 1.3 The inspection checklists for the September 2014 inspection are provided in Attachment A, and photographic logs of the inspection are provided in Attachments Band C (as described below).

Response Actions Performed Since Spring 2014 Monitoring Event

Based on the response actions proposed in the June 25, 2014 trip report documenting the spring 2014 monitoring event, as well as comments provided by EPA in its July 21, 2014 letter, the following activities have been completed at the Silver Lake Area since the May 2014 inspection.4

1. Replaced soil and re-seeded area of minor soil erosion near the top of bank (east of fence) on Parcell9-9-9 (Spring 2014 Area 2 on Figure 1).

2. Replaced soil and re-seeded area of minor soil erosion above the top of bank (east of fence) on Parcel 19-9-9 (Spring 2014 Area 3 on Figure 1 ).

3. Re-graded high spots and re-seeded area of bare spots and uneven grade on bank near fence on Parcell9-10-8 (Spring 2014 Area 4 on Figure 1).

4. Re-graded erosion and re-seeded area of with uneven grading, minor soil erosion, and bare spots on bank of Parcell9-10-8 (Spring 2014 Area 5 on Figure 1).

5. Replaced soil in depressions around new posts and former posts, as needed, for the guardrail posts installed along Silver Lake Boulevard on Parcels 19-9-35 and -36 (Spring 2014 Area 6 on Figure 1 ).

6. Replaced soil and re-seeded area of exposed abandoned outfall and bare spots on Parcel 19-9-35 (Spring 2014 Area 7 on Figure 1 ).

7. Replaced soil and re-seeded area of minor soil erosion under fence on Parcel 19-9-30 (Spring 2014 Area 8 on Figure 1 ).

2 As discussed further below, the 2014 cap monitoring will be conducted later this fall. 3 In addition to the areas shown on Figure 1, other areas that were disturbed and restored during the performance of the remediation (e.g., staging/access areas) were also inspected. 4 The June 2014 inspection report also noted that some geotextile installed within the channel to the outfall from Silver Lake to the Housatonic River was exposed (identified as Area 1 in that report) and would be covered with additional riprap. That activity had not been performed by the time of the September inspection, but will be performed in connection with the other armor stone repairs in this area, as discussed below.

G:\GE\GE_ Silver _Lake\Reports and Presentations\20 14-10 backfill, non-NRRE veg, armor insp summer\20314 J 1214_SL Summer Insp.docx


Page 3 of 8

8. Placed additional riprap within the eroded area on the east side of a drainage swale on Parcel 19-9-22 (Spring 2014 Area 9 on Figure 1 ). In addition, placed some additional riprap (underlain with geotextile) along the edge of the upland parking lot to capture sheet flow before it hits the bare topsoil.

9. Replaced soil, re-seeded, and placed mulch in area of minor soil erosion between swales on Parcel 19-9-22 (Spring 2014 Area 10 on Figure 1). In addition, placed some additional riprap (underlain with geotextile) along the edge of the upland parking lot to capture sheet flow before it hits the bare topsoil.

10. Pruned and watered six stressed burning bush shrubs on Parcel 19-9-27 (Spring 2014 Area 11 on Figure 1 ).

Areas subject to re-seeding were scarified and seeded with an elevation-appropriate seed mix in accordance with the original restoration plan, raked-in, covered with straw mulch, and watered as appropriate. The above response actions were completed on August 22, 2014.

EPA's July 21, 2014 conditional approval letter for the June 2014 trip report indicated that GE should replace three non-excess red-osier dogwoods located on 19-9-21, -22, -23 and 19-9-34, which were observed to be dead in May 2014. Those replacement plantings had not been installed at the time of the September 4, 2014 inspection. However, the quantity of red-osier dogwoods observed on each of these parcels during the September 4 inspection met or exceeded the target quantity. Thus, no additional redosier dogwoods need to be planted on those parcels in response to the spring 2014 monitoring event.

Subsequent to the May 2014 inspection, some displacement/erosion of stone was observed in the channel of the Fourth Street Outfall. This area is identified as Area 6 on Figure 1 (Photo 12 in Attachment B). Additional stone movement was noted to have occurred near Outfalls 28/29 and 31, identified as Areas 3 and 4, respectively, on Figure 1 (Photos 6 and 7 in Attachment B). GE submitted to EPA on August 20, 2014 a plan for the repair of the armor stone in these areas, and EPA conditionally approved that plan on August 21, 2014. The approved construction/repair activities have been scheduled to be performed in the fall of 2014. These repair activities will be documented in the Annual Report to be submitted by GE to summarize all 2014 monitoring and maintenance activities at the Silver Lake Area.

Description and Results of Summer 2014 Monitoring Event

This section describes and presents the results of the September 4, 2014 inspection for each of the nonNRRE measures that were inspected; and, where warranted, it presents GE's plans for follow-up actions. Additional information is provided in attached Figure 1, Tables 1 and 2, the inspection checklists in Attachment A, and the photographic logs in Attachments B and C.

Shoreline Armor System Monitoring

In accordance with the PRSCP/RPMMP, the September 2014 inspection of the shoreline armor system consisted of visual observations of that system to assess the effects, if any, of shoreline wave and/or wind action on the sediment cap/armor system along the shoreline. In this regard, we note that, on the day of the inspection, flow in the Housatonic River was approximately 76 cubic feet per second (cfs), as measured at the U.S. Geological Survey (USGS) river gage in Coltsville. Since the last monitoring event in May 2014, no severe storm events (i.e., storm events in which a 15-minute instantaneous peak of 3,500 cfs or greater was observed at the Coltsville gage) or excessive wind events were observed, and thus no non-routine inspections were performed since the last regularly scheduled monitoring event performed in May 2014.

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The PRSCP/RPMMP provides that if this monitoring reveals significant erosion of the shoreline armor system (e.g., slope failure, ruts, gullies, washouts, or sloughing), repair of the eroded areas will be conducted.

During the September 2014 inspection, apart from the areas noted above associated with the Fourth Street Outfall and Outfalls 28/29 and 31, no additional areas within the shoreline armor system were observed with significant erosion (as defined above). However, it was observed in the field that some geotextile was exposed in several areas. Descriptions of these areas, along with proposed area-specific corrective actions are summarized in Table 1, with photographs of these areas presented in Attachment B. The approximate location of each these areas is illustrated on Figure 1.

Area 1 - Area 1 consists of small areas of exposed geotextile in the outlet to the Housatonic River (Photos 1 and 2 in Attachment B), possibly resulting from settlement and/or repositioning of the armor stone. This Area includes the area noted in the outlet during the May 2014 event, as response actions had not yet been completed in the outlet area prior to September 4. To protect these areas and mitigate the potential for additional exposed geotextile, additional armor stone will be placed in these areas.

Area 2 - Area 2 is an area of exposed geotextile on the west end of Parcel 19-9-201 (Photos 3 through 5 in Attachment B), possibly due to settlement and/or repositioning of the armor stone. To protect this area and mitigate the potential for additional exposed geotextile, additional armor stone will be placed in this area.

Area 11 - Area 11 is an area of exposed geotextile on Parcel 19-9-23 (Photo 14 in Attachment B), possibly due to settlement and/or repositioning of the armor stone. To protect this area and mitigate the potential for additional exposed geotextile, additional armor stone will be placed in this area.

The September 2014 inspection also noted the displacement and erosion of armor stone, with exposed geotextile, at the outfall protection system in the Fourth Street Outfall area, as had previously been observed following the May 2014 inspection. As indicated above, this area will be addressed in accordance with the already approved plan for the repair of the armor stone in the Fourth Street Outfall area.

The completed inspection checklist documenting the September 2014 monitoring of the shoreline armor system is included as Attachment A-1 to this letter.

Monitoring of Backfilled/Restored Areas Adjacent to the Lake and Other Disturbed Areas

In accordance with the PRSCP/RPMMP, the September 2014 inspection of the backfill/restored areas and other disturbed areas consisted of visual observations of those areas for the following: (a) evidence of erosion; (b) the effectiveness of erosion controls in areas where vegetation is not established; (c) evidence of depressions and/or surface water pending; (d) any areas where excessive settlement has occurred relative to the surrounding areas; (e) any drainage or growth problems; (f) any stressed or sparse cover; and (g) other conditions that could jeopardize the performance of the completed remediation actions. The PRSCP/RPMMP provides that if this inspection reveals any problematic conditions, maintenance and/or repair activities will be conducted.

During the summer 2014 inspection, certain areas were noted with evidence of erosion, depressions, drainage or growth problems, and/or stressed or sparse cover. Descriptions of these areas, along with proposed area-specific corrective actions, are presented below and are summarized in Table 1, with photographs of these areas presented in Attachment B. The approximate location of each area is illustrated on Figure 1.

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Area 5- Area 5 is an area of minor erosion of surface soils on Parcell9-1 0-9 (Photo 8 in Attachment B). To reduce the potential for future erosion in this area, the topsoil will be replaced within the eroded area to restore the area to surrounding grades, mulch will be placed, and the area will be revegetated by seeding.

Area 7- Area 7 is an area on Parcel19-9-36 with sparse cover where the invasive species Japanese knotweed had been cut and treated with herbicide (Photo 10 in Attachment B). To address the sparse cover and reduce the potential for erosion in this area, the area will be re-vegetated by seeding.

Area 8 - Area 8 is an area on Parcel 19-9-36 with bare spots and sparse cover in the area near the walking path between the fourth and fifth benches as counted from Fourth Street (Photo 11 in Attachment B). To address the sparse cover and reduce the potential for erosion in this area, the area will be re-vegetated by seeding.

Area 9 - Area 9 is an area where armor stone was displaced and geotextile was exposed near SLOF-17 on Parcel 19-9-36 (Photo 12 in Attachment B), possibly due to a high flow event. To reduce the potential for future erosion in this area, the armor stone will be replaced within the eroded area, and larger stones will be strategically placed within the area where geotextile was observed to be exposed, to act as a "splash block" and provide additional energy dissipation.

Area 10 - Area 10 is an area of erosion and exposed geotextile near SL-OF-06 on Parcel 19-9-35 (Photo 13 in Attachment B), possibly due to a high flow event. To reduce the potential for future erosion in this area, the armor stone will be replaced within the eroded area, and larger stones will be placed in specific locations/formations to provide additional energy dissipation.

Area 12- Area 12 is an area of minor settlement on Parcel 19-9-21 (Photo 15 in Attachment B). To address the depressions and reduce the potential for future surface water pending or erosion in this area, additional soil will be placed within the depressed location to restore the location to surrounding grade, and the location will be re-vegetated by seeding, as needed.

Area 13- Area 13 is an area of minor settlement on Parcell9-9-21 (Photo 16 in Attachment B). To address the depressions and reduce the potential for future surface water pending or erosion in this area, additional soil and/or riprap will be placed within the depressed location to restore thee location to surrounding grade.

The completed inspection checklist documenting the September 2014 inspection of backfilled/restored and other disturbed areas is included as Attachment A-2 to this letter.

Non-NRRE Vegetation Monitoring

In accordance with the PRSCP/RPMMP, the vegetation planted in the backfilled/restored areas outside of the NRRE areas was inspected to assess the establishment, coverage, and condition of the vegetation, including any evidence of stressed or sparse cover, and to ensure that vegetation is growing as anticipated and providing the necessary erosion control. The inspection also included monitoring of the trees and shrubs planted as part of the restoration activities to assess the number and condition of those plantings, which were recorded. The average height of planted trees and shrubs subject to inspection was measured (to the nearest foot) and recorded for a subset of the planted stock. 5 In addition, the PRSCP/RPMMP requires inspection of tree cages, tree guards, and tree stakes (where present) to ensure that these items are functioning to protect the trees from damage, and implementation of an invasive species control program. The results of the non-NRRE vegetation

5 Note that the PRSCP/RPMMP called for the measurement of all trees and shrubs planted in the non-NRRE areas; however, as during the spring 2014 inspection, it was determined in the field, with concurrence by EPA's representative, that the measurement of a subset of the total number of trees and shrubs would be sufficient due to the similarity in heights of the planted stock.

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inspection for each property are summarized below, and are included in Table 2, with photographs of the vegetation at selected properties provided in Attachment C.

During the summer 2014 inspection, the ground vegetation was observed to be adequately established in the non-NRRE areas except as noted above for Area 12 where re-seeding is proposed. 6

With the exception of Parcels 19-10-8, all parcels in the non-NRRE areas observed during the summer 2014 monitoring event were noted as having at least one invasive species, but usually only a few individuals of such invasive species. Invasive species cover did not exceed 5% of the ground cover on any individual parcel. Observed invasive species included coltsfoot, common buckthorn, Japanese knotweed, purple loosestrife, spotted knapweed, and yellow iris. These invasive species will be addressed as part of GE's ongoing invasive species control program for the restored and re-vegetated areas. 7

As specified in EPA's July 21, 2014 conditional approval letter for the May 2014 inspection, the total quantity of trees and shrubs observed durin~ the May 2014 monitoring event, including the non-excess plantings observed to be stressed or dead, was used as the baseline number of plantings for percent survival calculations. The baseline plantings for determinations of percent survival are listed in Table 2. Four properties were identified for further follow-up activities as the calculated percent survival for each property was determined to be less than 100%. These properties, along with proposed response actions, are described below and summarized in Table 1.

Parcell9-9-17- This property showed a shortage of four shrubs (three red-osier dogwoods and one winterbury holly) compared to the baseline quantity. To address this shortage, three additional redosier dogwoods and one additional winterberry holly will be planted during the fall 2014 planting season.

Parcel 19-9-201 -This property showed a shortage of six shrubs compared to the baseline quantity. These included two dead red-osier dogwoods and four missing red-osier dogwoods. To address this situation, the two dead red-osier dogwoods observed will be replaced and four additional red-osier dogwoods will be planted during the fall 2014 planting season.

Parcel 19-10-1 - This property showed a shortage of three red-osier dogwoods compared to the baseline quantity. To address this shortage, three additional red-osier dogwoods will be planted during the fall 2014 planting season.

Parcell9-9-34- This property showed a shortage of two winterbury hollies compared to the baseline quantity. To address this shortage, two additional winterberry hollies will be planted during the fall 2014 planting season.

In accordance with the PRSCP/RPMMP, the replanted shrubs will be equipped with a tag identifying the species of the shrub, the installation date, and the size at the time of installation. The monitoring duration for the replanted shrubs will be reset to two years after planting, terminating with an August or September inspection.

The June 2014 trip report noted that six burning bush shrubs on Parcel 19-9-27 had been observed in May 2014 to be stressed (Spring 2014 Area 11) and recommended re-evaluation of the health of those

6 The other areas discussed above with evidence of sparse vegetative cover (i.e., Areas 7 and 8) are located within the NRRE areas. 7 The invasive species control program for the Silver Lake Area does not apply to the burning bush shrubs planted on Parcel 19-9-27 or on adjacent 19-9-28. 8 In accordance with EPA's July 21, 2014 letter, the baseline number of plantings does not include dead/stressed plantings observed during the May 2014 inspection that constituted "excess" plantings compared to the number required to be planted (namely, the dead red-osier dogwood on Parcel 19-10-8, the dead red-osier dogwood on Parcell9-9-1 & -201, and the stressed Northern arrowwood on Parcell9-9-1 & -201.

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shrubs during the summer 2014 monitoring event. During the September 4, 2014 inspection, those burning bushes were observed to have recovered and were no longer stressed.

Additionally, during the September inspection, tree cages, tree guards, and tree stakes (where present) were inspected and confirmed to be functioning to protect the trees from damage.

The completed inspection checklist documenting the September 2014 non-NRRE vegetation inspection is included as Attachment A-3 to this letter.

Future Activities

In accordance with the PRSCP/RPMMP, GE will implement the maintenance, repair, and re-vegetation activities identified above and summarized in Table 1 within 90 days of the inspection date (i.e., by December 3, 2014)- or sooner if practicable, assuming timely EPA approval- unless otherwise agreed to by EPA The maintenance, repair, and re-vegetation activities performed will be documented in the Annual Report on 2014 monitoring and maintenance activities.

This summer 2014 inspection fulfilled the requirements for the second post-construction monitoring event for the shoreline armoring system, the backfilled/restored areas, and the plantings in the nonNRRE plantings, as outlined in the PRSCP/RPMMP. GE will continue with the monitoring activities on the schedule specified in that plan, as described above (until replaced by the Post-Removal Site Control requirements specified in the FCR for the Silver Lake Area Removal Action). The first monitoring events for the cap thickness and the cap isolation layer will be performed in the fall of 2014. The next scheduled inspection of the shoreline armor system and the non-NRRE plantings will occur in spring 2015 (May for the non-NRRE plantings) and the next scheduled inspection for the backfilled/restored and other disturbed areas will occur in summer 2015. 9 Reports will be submitted on all of these monitoring events and will include completed inspection checklists (if applicable).


Sincerely,

cl~ 9~~ /·1-v< Richard W. Gates Senior Project Manager- Environmental Remediation

Attachments

9 In addition to the scheduled inspections, the shoreline armor system and the backfilled/restored and other disturbed areas will be inspected after severe storms, defined as storm events with a 15-minute instantaneous peak flow of 3,500 cfs or greater, as measured at the USGS river gage in Coltsville. The shoreline armor system will also be inspected after any excessive wind event, as determined in consultation with EPA.

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cc: Dean Tagliaferro, EPA Tim Conway, EPA* Chris Ferry, ASRC Primus** Scott Campbell, Avatar (2 hard copies)** Robert Leitch, USAGE** Michael Gorski, MDEP** John Ziegler, MDEP (2 hard copies)** Eva Tor, MDEP** Karen Pelto, MDEP** Nancy E. Harper, MA AG* Nate Joyner, Pittsfield Dept. of Community

Development** James McGrath, Pittsfield Dept. of Parks

and Recreation**



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Tables

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Area/Item Identified Description Proposed Follow-up Action1 - Armor System at the Outfall to the Housatonic River

Indication of exposed geotextile fabric Replace armor stone to cover exposed fabric

2 - Armor System on Parcel I9-9-201 Indication of exposed geotextile fabric Replace armor stone to cover exposed fabric

3 - Backfilled/Restored Area on Parcel I9-10-8 (near SL-OF-31)

Indication of erosion and exposed geotextile fabric

Implement restoration design conditionally approved by EPA on August 21, 2014

4 - Backfilled/Restored Area on Parcel I9-10-9 (near SL-OF-28/-29)




Indication of minor soil erosion Replace with topsoil, re-seed, and place mulch

6 - Armor System at the Fourth Street Outfall Indication of erosion and exposed geotextile fabric



Indication of bare spots where invasive species control was implemented

Re-seed


Indication of bare spots with sparse cover Treat invasive species and re-seed



Replace armor stone to cover exposed fabric and strategically place large stone as "splash rock" to dissipate energy



Replace armor stone to cover exposed fabric and strategically place larger stones to dissipate energy

11 - Armor System on Parcel I9-9-23 Indication of exposed geotextile fabric Replace armor stone to cover exposed fabric


Indication of minor soil settlement Replace soil in depression and re-seed, as necessary


Indication of minor settlement Replace soil and/or armor stone in depression

Parcel I9-9-17 - Non-NRRE Vegetation Shortage of three red-osier dogwoods and one winterbury holly compared to the baseline

Plant three red-osier dogwoods and one winterberry holly

Parcel I9-9-201 - Non-NRRE Vegetation Two dead and four missing red-osier dogwoods compared to baseline

Plant six red-osier dogwoods

Parcel I9-10-8 - Non-NRRE Vegetation Shortage of three red-osier dogwoods compared to the baseline

Plant three red-osier dogwoods

Parcel I9-9-34 - Non-NRRE Vegetation Shortage of two winterbury hollies compared to the baseline

Plant two winterberry hollies

TABLE 1

SUMMER 2014 INSPECTION OF SHORELINE ARMOR SYSTEM, BACKFILLED/RESTORED AREAS ADJACENT TO SILVER LAKE, AND NON-NATURAL RESOURCE RESTORATION/ENHANCEMENT PLANTINGS



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Species Quantity to be Monitored

QuantityObserved

Not Stressed or Dead

QuantityObservedStressed

QuantityObserved

Dead

Percent Survival (%)

Average Height (ft)1

ObservedInvasiveSpecies

Approximate Invasive

Species CoverI9-10-8Red-Osier Dogwood 112 109 0 0 97 3.3Northern Arrowwood 29 29 0 0 100 3.0Winterberry Holly 28 28 0 0 100 4.4Parcel Total 169 166 0 0 98 --I9-9-1Red-Osier Dogwood 42 42 0 0 100 3.8Northern Arrowwood 11 11 0 0 100 3.0Winterberry Holly 11 11 0 0 100 4.0Parcel Total 64 64 0 0 100 --I9-9-9Red-Osier Dogwood 16 15 1 0 100 4.0Northern Arrowwood 4 4 0 0 100 2.8Winterberry Holly 4 4 0 0 100 3.8Parcel Total 24 23 1 0 100 --I9-9-201Red-Osier Dogwood 62 56 0 2 90 3.8Northern Arrowwood 14 14 0 0 100 2.8Winterberry Holly 14 14 0 0 100 3.1Parcel Total 90 84 0 2 93 --I9-9-17Red-Osier Dogwood 34 31 0 0 91 3.9Northern Arrowwood 9 9 0 0 100 2.8Winterberry Holly 9 8 0 0 89 2.9Parcel Total 52 48 0 0 92 --I9-9-18, I9-9-19Red Maple 1 1 0 0 100 12Red-Osier Dogwood 27 27 0 0 100 3.3Northern Arrowwood 5 5 0 0 100 3.0Winterberry Holly 7 7 0 0 100 2.9Parcel Total 40 40 0 0 100 --I9-9-21, I9-9-22, I9-9-23Red-Osier Dogwood 55 55 1 1 102 3.5Northern Arrowwood 11 11 0 0 100 3.1Winterberry Holly 12 12 0 0 100 4.6Parcel Total 78 78 1 1 101 --I9-9-24Red-Osier Dogwood 18 18 0 0 100 3.1Northern Arrowwood 4 4 0 0 100 3.3Winterberry Holly 5 5 0 0 100 4.4Parcel Total 27 27 0 0 100 --I9-9-25, I9-9-26Red-Osier Dogwood 24 23 1 0 100 3.3Northern Arrowwood 5 5 0 0 100 3.2Winterberry Holly 7 7 0 0 100 4.3Parcel Total 36 35 1 0 100 --I9-9-27Red-Osier Dogwood 13 13 0 0 100 3.2Northern Arrowwood 3 3 0 0 100 3.0Winterberry Holly 4 4 0 0 100 4.3Arborvitae 5 5 0 0 100 10Red Oak 1 1 0 0 100 18Burning Bush 6 6 0 0 100 3.0Parcel Total 32 32 0 0 100 --I9-9-28Red-Osier Dogwood 16 16 0 0 100 3.6Northern Arrowwood 5 5 0 0 100 3.0Winterberry Holly 4 4 0 0 100 4.8Fraser Fir 2 2 0 0 100 11Burning Bush 3 3 0 0 100 2.0Parcel Total 30 30 0 0 100 --I9-9-29Red-Osier Dogwood 12 12 0 0 100 3.5Northern Arrowwood 3 3 0 0 100 3.0Winterberry Holly 3 3 0 0 100 3.3Arborvitae 11 11 0 0 100 11Privet 21 21 0 0 100 3.7Parcel Total 50 50 0 0 100 --I9-9-34Red-Osier Dogwood 64 64 0 0 100 3.5Northern Arrowwood 55 55 0 0 100 3.2Winterberry Holly 15 13 0 0 87 4.5Parcel Total 134 132 0 0 99 --

TOTALS 826 809 3 3 98

Japanese knotweedPurple loosestrife < 5%

Japanese knotweed < 5%

Coltsfoot < 5%

Coltsfoot < 5%

ColtsfootPurple loosestrife < 5%

Coltsfoot < 5%

< 5%Purple loosestrifeJapanese knotweed

1. Average heights were based on a measured subset of all observed plantings.Notes:

Purple loosestrife < 5%

ColtsfootJapanese knotweed < 5%

TABLE 2SUMMARY OF RESTORED VEGETATION INSPECTED IN THE NON-NATURAL RESOURCE RESTORATION/ENHANCEMENT AREAS


SUMMER 2014 POST-REMEDIATION INSPECTION OF SHORELINE ARMOR SYSTEM, BACKFILLED/RESTORED AREASADJACENT TO SILVER LAKE, AND NON-NATURAL RESOURCE RESTORATION/ENHANCEMENT PLANTINGS

None

ColtsfootYellow iris

Coltsfoot

BuckthornPurple loosestrife

0

< 5%

< 5%

< 5%

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Attachment A

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ATTACHMENT A-1INTERIM CHECKLIST FOR VISUAL INSPECTION OF SHORELINE ARMORING



Inspection Date: 4-Sep-14Conducted By: Anthony Esposito, Maggie Miller, Gregg RabascoWeather Conditions: 75-80 degrees, Sunny


2.

No significant erosion of the shoreline noted. Erosion and exposed geotextile noted in area of Fourth Street Outfall.Several areas with exposed geotextile fabric were noted: an area in the outlet to the Housatonic River, an area at the west end of Parcel I9-9-201, and an area on Parcel I9-9-23.

3.

Repair/maintenance activities have been scheduled, but had not yet been performed at the time of the inspection.

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIESReplace armor stone to cover geotextile.

Implement armor stone repair plan for Fourth Street Outfall area, as approved by EPA on August 21, 2014.


Shoreline Armoring (Note any physical changes since last inspection; note evidence of significant erosion of the shoreline [e.g., slope failure, ruts, gullies, washouts, or sloughing], and if any erosion is observed, evaluate whether there are any eroded soils remaining in the lake; note other conditions that could jeopardize the performance of the completed remediation actions.)



of that draft – were reviewed in the field.

In lieu of the specified figure and drawings, more recent figure/drawings – namely Figure 8-1 of the April 2014 draft of the FinalCompletion Report for Silver Lake Area Removal Action and the as-built drawings of the shoreline armor system provided in Appendix F



INSPECTION OF BACKFILLED/RESTORED AREAS





2.

Minor settlement in areas on Parcel I9-9-21 (Areas 12 and 13).Minor soil erosion on Parcels I9-10-9 (Area 5).Bare spots/sparse cover near walking path between fourth/fifth benches from Fourth Street on Parcel I9-9-36 (Area 8).Bare spots/sparse cover on Parcel I9-9-36 where invasive species control program was implemented (Area 7).Erosion/exposed geotextile near SL-OF-28/-29, SL-OF-31, SL-OF-17, and SL-OF-06 (Areas 3, 4, 9, and 10, respectively).

3.

Repair/maintenance activities were performed in the following areas identified during the spring 2014 inspection: Areas 2, 3, 4, 5, 6, 7, 8, 9, 10, and 11. See report for specific repair/maintenance activities performed at each Area.

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIESReplace or place soil, riprap, and/or seed and mulch. Replace armor stone and strategically place larger stones to further dissipate energy.Implement restoration design for areas near SL-OF-31 and SL-OF-28/-29, as approved by EPA on August 21, 2014.



Backfilled/Restored Areas (Note any physical changes since the last inspection; note evidence of any of the following: soil or gravel erosion, effectiveness of erosion controls in areas where vegetation is not established, depressions or surface water ponding, excessive settlement, drainage or growth problems, stressed or sparse cover, other conditions that could jeopardize the performance of the completed remediation actions, etc.. If any conditions are present, note the Parcel Number where such conditions are observed.)


Report for Silver Lake Area Removal Action and the as-built drawings provided in Appendix F of that draft – were reviewed in the field.In lieu of the specified figure and drawings, more recent figure/drawings – namely Figure 8-1 of the April 2014 draft of the Final Completion



INSPECTION OF VEGETATION AT AREAS OTHER THAN NATURAL RESOURCE RESTORATION/ENHANCEMENT AREAS





2.

Ground cover in non-NRRE areas has adequately established except in area of minor settlement on Parcel J9-9-21 (Area 12 on Figure 1), as described in Attachment A-2.Previously stressed burning bushes on Parcel I9-9-27 have revived.Trees and shrubs on all inspected properties were alive and in good condition and met the criterion of 100% survival, with the exception of shortages on four properties compared to baseline quantities – namely, on Parcel I9-9-17, three missing red-osier dogwoods andone missing winterbury holly; on Parcel I9-9-201, two dead and four missing red-osier dogwoods; on Parcel I9-10-1, three missingred-osier dogwoods; and on Parcel I9-9-34, two missing winterbury hollies.

3.

Coltsfoot, Common buckthorn, Japanese knotweed, Purple loosestrife, Spotted knapweed, and Yellow iris observed. No invasive species constituted more than 5% cover in the non-NRRE areas.

4.

Burning bushes on Parcel I9-9-27 were pruned.Re-grading, seeding, and mulching was performed on Parcel I9-10-8.Areas requiring monitoring during the summer 2014 were specifically inspected.Invasive species control program was continued.

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIESContinue the invasive species control program (except for the burning bush shrubs planted on Parcels I9-9-27 and I9-9-28).

Plant three red-osier dogwoods and one winterberry holly on Parcel I9-9-17.Plant six red-osier dogwoods on Parcel I9-9-201.Plant three red-osier dogwoods on Parcel I9-10-8.Plant two winterberry hollies on Parcel I9-9-34.



Preliminary Inspection Activities (Confirm that Figure I-1 of the Revised Final Removal Design/Removal Action Work Plan for Silver Lake Area and the technical drawings provided in Appendix D of that document have been reviewed in the field during the inspection. )In lieu of the specified figure and drawings, more recent figure/drawings – namely Figure 8-1 of the April 2014 draft of the FinalCompletion Report for Silver Lake Area Removal Action and the as-built drawings provided in Appendix F of that draft – were reviewed in the field.

Vegetation in Non-NRRE Areas (Note any physical changes since the last inspection; note the establishment, coverage, and general condition of vegetative cover [e.g., evidence of stressed/sparse cover], verify that vegetation is growing as anticipated and providing the necessary erosion control, assess survival and condition of other landscaping items [trees, shrubs, etc.] planted during restoration activities, tree guards, tree cages, and tree stakes; and measure and record the size of all trees and shrubs subject to inspection, including information regarding the number, height, and condition of the trees and shrubs subject to inspection. If any conditions are present, note the Parcel Number where such conditions are observed.)

Presence of Invasive Species (Note percentage of area occupied by invasive species; note the species present including the following: Amur honeysuckle, Autumn olive, Black locust, Black swallow-wort, Coltsfoot, Common barberry, Common buckthorn, Cyprus spurge, Garlic mustard, Glossy buckthorn, Goutweed or Bishop's weed, Japanese barberry, Japanese honeysuckle, Japanese knotweed, Morrow's honeysuckle, Morrow's X Tartarian honeysuckle [hybrid], Multiflora rose, Norway maple, Oriental bittersweet, Phragmites - Reed grass, Porcelain berry, Purple loosestrife, Russian olive, Spotted knapweed, Tartarian honeysuckle, Yellow iris, or any other plant species listed by the Massachusetts Invasive Plant Advisory Group as “Invasive,” “Likely Invasive,” or “Potentially Invasive” . If any conditions are present, note the Parcel Number where such conditions are observed.)

Attachment B

ATTACHMENT B PHOTOGRAPHIC LOG OF ITEMS REQUIRING RESPONSE SUMMER 2014 INSPECTION OF SHORELINE ARMOR SYSTEM, BACKFILLED/RESTORED AREAS ADJACENT TO SILVER LAKE, AND NON-NATURAL RESOURCE RESTORATION/ENHANCEMENT PLANTINGS SILVER LAKE AREA GENERAL ELECTRIC COMPANY – PITTSFIELD, MASSACHUSETTS

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Photograph 3: Parcel I9-9-201; Indication of exposed geotextile fabric (Area 2)





Photograph 6: I9-10-8; Indication of erosion and exposed geotextile fabric (Area 3)



Photograph 7: Parcel I9-10-9; Indication of erosion and exposed geotextile fabric (Area 4)

Photograph 8: Parcel I9-10-9; Indication of minor soil erosion (Area 5)



Photograph 9: Fourth Street Outfall area; Indication of exposed geotextile fabric (Area 6)

Photograph 10: I9-9-36; Indication of bare soil with invasive species (Area 7)



Photograph 11: Parcel I9-9-36; Indication of bare spots with sparse cover (Area 8)








Photograph 15: Parcel I9-9-21; Indication of depression (Area 12)

Photograph 16: Parcel I9-9-21; Indication of depression (Area 13)

Attachment C

ATTACHMENT C PHOTOGRAPHIC LOG OF NON-NRRE VEGETATION SUMMER 2014 INSPECTION OF ARMOR SYSTEM, BACKFILLED/RESTORED AREAS ADJACENT TO SILVER LAKE, AND NON-NATURAL RESOURCE RESTORATION/ENHANCEMENT PLANTINGS SILVER LAKE AREA GENERAL ELECTRIC COMPANY – PITTSFIELD, MASSACHUSETTS

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Photograph 1: Parcel I9-9-34; View of plantings and shoreline, looking southwest from east end.

Photograph 2: View of plantings and shoreline along southern shore of Silver Lake, looking east.

ATTACHMENT C PHOTOGRAPHIC LOG OF NON-NRRE VEGETATION SUMMER 2014 INSPECTION OF ARMOR SYSTEM, BACKFILLED/RESTORED AREAS ADJACENT TO SILVER LAKE, AND NON-NATURAL RESOURCE RESTORATION/ENHANCEMENT PLANTINGS SILVER LAKE AREA GENERAL ELECTRIC COMPANY – PITTSFIELD, MASSACHUSETTS

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Photograph 3: Parcel I9-10-8; View of plantings and shoreline, looking south from north end.

October 31, 2014 SL Summer 2014 Inspection of Natural Resource Restoration/ Enhancement Measures

October 31, 2014

Ms. Karen Pelto Lead Administrative Trustee Bureau of Waste Site Cleanup Massachusetts Department of Environmental Protection One Winter Street, 81

h Floor Boston, Massachusetts 02108


GE Corporate

159 Plastics Avenue Pittsfield. MA 01201 USA

Summer 20141nspection of Natural Resource Restoration/Enhancement Measures

Dear Ms. Pelto:

Pursuant to the requirements set forth in the October 2000 Consent Decree (CD) for the GEPittsfield/Housatonic River Site (the Site) and the accompanying Statement of Work for Removal Actions Outside the River (SOW), the General Electric Company (GE) implemented a Removal Action at the Silver Lake Area Removal Action Area (RAA) between July 2012 and December 2013. The Removal Action implemented at the Silver Lake Area included removal of selected sediments, installation of a sediment cap and associated armor layer, and removal/replacement of soil in certain areas on the banks and otherwise adjacent to the lake to meet established Performance Standards, followed by restoration of those areas. In addition, as required by the CD, GE installed a number of natural resource restoration/enhancement (NRRE) measures at the Silver Lake Area, including creation of a shallowwater shelf along the shoreline of the lake, installation of a number of plantings on the shrub-scrub "island" near the discharge outfall and on the banks on the northern and eastern sides of the lake, and construction of a walking path and benches on the northern and eastern sides of the lake. Those NRRE measures were described in a Revised Completion of Installation of Restoration Work Report (Revised CIRW Report) which GE submitted to the natural resource trustees (the Trustees) on May 23, 2014 and was approved by the Trustees on September 3, 2014. 1 The CD and SOW also require monitoring and maintenance of both the NRRE measures and the non-NRRE measures installed at the Silver Lake Area following completion of the Removal Action.

Paragraph 119 of the CD requires the preparation of a Restoration Project Monitoring and Maintenance Plan for NRRE measures. The Performance Standards and other requirements for such monitoring and maintenance were set forth in Section 8 of Attachment I to the SOW and subsequently modified in correspondence from EPA. In satisfaction of those requirements (as well as the separate requirements for Post-Removal Site Control activities for non-NRRE measures), GE submitted a Post-Removal Site Control Plan/Restoration Project Monitoring and Maintenance Plan (PRSCP/RPMMP) as Appendix I of GE's August 2011 Revised Final Removal Design/Removal Action Work Plan for Silver Lake Area (Revised Final Work Plan), which was conditionally approved by EPA on August 25, 2011. That PRSCP/RPMMP included (in Section 3) a description of the monitoring and maintenance activities to be conducted for the NRRE measures installed at the Silver Lake Area.

1 Paragraph 120 of the CD requires that, after the submittal of a CIRW Report, an installation inspection/meeting be scheduled and attended by GE, EPA, and the Trustees. That inspection/meeting was held on May 27, 2014, and is to be followed by the Trustees' determination of whether the installation of the restoration work has been completed in accordance with the applicable requirements and Performance Standards of the CD.

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Page 2 of6

Subsequently, the applicable requirements for monitoring of the NRRE measures were modified in certain respects based on developments after EPA's approval of the Revised Final Work Plan and discussions among GE, the Trustees, and EPA. The updated monitoring and maintenance requirements for the NRRE measures were summarized in the May 23, 2014 Revised CIRW Report.

The PRSCP/RPMMP, as modified by the Revised CIRW Report, requires GE to perform periodic inspections of the plantings installed in the NRRE areas as well as the walking path and benches. Specifically, it requires inspections of the NRRE plantings semi-annually (in May and August or September) for a three-year period after planting, once during the fifth year after planting, and once during the seventh year after planting; and it requires inspections of the walking path and benches annually for the first three years after installation.2 For purposes of the inspections of the NRRE plantings, certain specified monitoring areas, as well as designated monitoring plots within those areas, were established around the northern and eastern sides of the lake in coordination with EPA and the Trustees.

GE conducted the first (spring) semi-annual inspection of the NRRE plantings on May 27-29, 2014 and submitted a report on it to the Trustees on July 19, 2014. The Trustees conditionally approved that report by letter dated September 3, 2014, and requested that GE submit a revised report on the May NRRE inspections. GE submitted that revised report on October 2, 2014.

In the meantime, GE conducted the second (summer) 2014 semi-annual inspection of the NRRE plantings, as well as the annual 2014 inspection of the walking path and benches, on September 4, 2014. The inspection activities were performed by Anthony Esposito, Gregg Rabasco, and Margaret Miller of ARCADIS (on GE's behalf). This monitoring event was also attended by Dave Dickerson of EPA, Michael Argue of Weston Solutions, Inc. (on EPA's behalf), and Kenneth Munney of the U.S. Fish and Wildlife Service (on behalf of the Trustees). This letter summarizes the response actions performed by GE since the spring 2014 inspection, the summer 2014 inspection activities, and the findings of that inspection.

Response Actions Performed Since Spring 2014 Monitoring Event

GE completed the majority of the maintenance activities identified in its report on the spring 2014 inspection prior to the summer inspection. Specifically, GE watered and pruned (as necessary) the large trees along the east bank of Silver Lake, which appeared to be stressed during the May inspection (identified as Area 3 in the spring inspection report); and it implemented treatment of invasive species in the NRRE area as part of its ongoing invasive species control program.

However, at the time of the summer inspection, the placement of topsoil and an herbaceous wetland seed mix in the void spaces in the lower portion of the armor stone around the periphery of the shrubscrub island between the area previously vegetated (during the Removal Action) and the approximate 975.9 feet National Geodetic Vertical Datum of 1929 (NGVD29) elevation contour- as proposed in the spring inspection report (Area 1 in that report) - had not yet been conducted. Since that time, based on a recommendation from its planting consultant, GE has requested approval from the Trustees and EPA to postpone this filling/seeding activity until the spring 2015 growing season to improve the likelihood of establishment, and promote the growth, of the herbaceous wetland species.

Description and Results of the Summer 2014 Monitoring Event

This section describes and presents the results of the September 4, 2014 inspection of the NRRE measures and, where warranted, presents GE's plans for follow-up actions. The locations of the NRRE measures that were inspected, including the designated monitoring areas and monitoring plots for the

2 As discussed in the Revised CIRW Report, the shallow-water shoreline shelf was previously monitored following installation, and no further inspections of this NRRE feature are required.

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NRRE plantings, are shown on Figure 1. A completed inspection checklist documenting the September 2014 NRRE inspection, along with the completed vegetation monitoring forms, are included in Attachment A to this letter, and photographic logs of the inspection are provided in Attachment B.

NRRE Vegetation Monitoring

In accordance with the PRSCP/RPMMP as modified in the Revised CIRW Report, the summer 2014 monitoring of the NRRE vegetation consisted of both a qualitative field inspection of the NRRE areas where plantings were installed and a quantitative assessment (i.e., counts) of the plantings within the specific monitoring plots established within the NRRE areas, as described further below. Personnel conducting the inspection were supported by Chris Frank of C.L. Frank & Company as the certified arborist.

Qualitative Assessment

For the qualitative assessment, field personnel conducted a meander survey of the overall NRRE planting areas to observe overall conditions of the vegetation within those areas. During this qualitative assessment, no areas were noted with indications of significant damage from trespassing or herbivory. The majority of the grass along the walking path, which had been re-seeded just prior to the spring inspection, was observed to be well-established. However, a narrow strip of sparse vegetation was still present along the lake-side of the walking path on the north-central side of the lake on Parcel 19-9-36, as well as on a nearby portion of the bank on the north shore of the lake where Japanese knotweed had been cut and treated as part of the invasive species control program. These areas are jointly identified as Area 4 on Figure 4 and shown on Photographs 1 and 2 in Attachment B. It is expected that the grass will continue to expand in this area over time; however, additional re-seeding was determined to be necessary, as further discussed below.

Additionally, it appeared that several shrubs along the walking path on Parcel 19-9-36 had been mowed down by the City of Pittsfield during lawn maintenance activities performed along the walking path after the May 2014 inspection (identified as Area 5 on Figure 1). Some of these shrubs were observed to be re-sprouting, but others were dead or missing. As provided in Attachment I to the SOW (p. 22) and the approved Revised CIRW Report, GE is not required to replant an area if the loss of vegetation is caused solely by the actions of a third party. However, EPA requested that GE replace eight of the shrubs that were either dead or missing. Three of these shru bs were located within the boundary of NRRE monitoring plots 19-9-36-1 (one winterberry holly and one nannyberry viburnum) and 19-9-36-3 (one northern arrowwood). As discussed below, even with those dead/missing shrubs, the percent survival for shrubs in the monitoring area that contains these plots still met the applicable Performance Standard of> 80% survival. Nevertheless, as requested by EPA, eight shrubs were replaced along the walking path in October 2014, as also discussed below.

The presence of invasive species, as listed in Attachment C (or any others listed by the Massachusetts Invasive Plant Advisory Group [MIPAG] as "invasive," "likely invasive," or "potentially invasive"), was noted in some of the NRRE areas, but covered less than 5% of the monitoring areas, as described further under the quantitative assessment below.

Quantitative Assessment

The quantitative assessment was conducted within designated monitoring plots established within four monitoring areas in the overall NRRE area. The four monitoring areas consist of three areas that are coextensive with the three tax parcels that comprise the NRRE areas (i.e., Parcels 19-10-9, 19-9-36, and 19-9-35) plus the shrub-scrub island. Within each monitoring area, monitoring plots were established based on the size and types of plantings in each area, as follows:


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• Parcel 19-9-35 Area (excluding the overlap with the shrub-scrub island area) -four monitoring plots, each approximately 60 feet long, in the area between the lake and Silver Lake Boulevard;

• Parcel 19-9-36 Area (excluding the overlap with the shrub-scrub island area)- four monitoring plots, each approximately 60 feet long, bounded by Silver Lake Boulevard on the north and the lake on the south; and


The locations of the monitoring plots are shown on Figure 1. The actual boundaries of the monitoring plots were established by survey in the field prior to the May 2014 inspection, with a repeat survey performed prior to the September 2014 inspection. Within each designated monitoring plot, field personnel: (1) performed a stem count of planted trees and shrubs to identify live and dead plantings (as well as any stressed plantings); (2) estimated the areal extent of groundcover by native herbaceous species; and (3) determined the presence of, and estimated percent coverage by, invasive species, as listed in Attachment C (or any others listed by the MIPAG as "invasive," "likely invasive," or "potentially invasive").

In accordance with the Revised CIRW Report, the results from the quantitative assessment of the individual monitoring plots were combined to estimate percent survival, percent coverage by native herbaceous species and percent coverage by invasive species for each of the four monitoring areas. Those results were then compared to the Performance Standards specified in the SOW and summarized in the Revised CIRW Report- namely, 80% survival for the planted trees and shrubs, 100% cover by native herbaceous species (outside the foliar coverage of the trees), and less than 5% cover by invasive species. To determine percent survival, the numbers of live trees and shrubs in each monitoring plot and area were compared to the numbers of trees and shrubs counted in that plot or area during the May 2014 monitoring event, which, as stated in the report on that event, constitute the baseline numbers of plantings for percent survival calculations.

The results of the quantitative NRRE vegetation monitoring event are presented on the Form A-1s and summarized in Tables A-1 and A-2 in Attachment A. As indicated on those forms, no dead or missing trees were observed in any of the monitoring plots. For shrubs, as discussed above, three shrubs that appeared to have mowed down by the City were observed to be dead or missing - two in the 19-9-36-1 monitoring plot (one winterberry holly and one nannyberry viburnum) and one in the 19-9-36-3 plot (one northern arrowwood) monitoring plot Uointly shown in Area 5 on Figure 1 ). As also shown on the Form A-1 s, there was a shortage of a few other specific shrub species in some monitoring plots compared to the baseline numbers, but in other cases the September 2014 counts indicated greater numbers of shrubs than the baseline numbers. The total quantities of live trees and shrubs observed in each monitoring plot and monitoring area during the September 2014 monitoring event are included in Table A-2, compared to the baseline quantities observed in May 2014. As shown in that table, the average percent survival for the trees and/or shrubs in each monitoring area is well above the applicable Performance Standard of 80% survival.

In addition, as further indicated on the Form A-1 s, seven shrubs in the 19-10-9-1 monitoring plot and one shrub in the 19-9-35-1 monitoring plot were observed to be stressed but alive. These eight shrubs will continue to be monitored for their condition and survival.

The two specific areas of plantings identified during the spring 2014 NRRE vegetation inspection as warranting follow-up actions or specific additional monitoring were revisited during the September inspection. The buttonbush plantings on the shrub-scrub island, which had exhibited delayed development during the spring inspection (identified as Area 2 during that inspection, as shown on Figure 1), were observed to be healthy and growing as anticipated during the summer 2014 inspection. In addition, the six red oak trees along the eastern bank of Silver Lake in the 19-9-35 monitoring area,

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which had been observed to be stressed during the spring inspection (identified as Area 3 during that inspection, as also shown on Figure 1 ), were observed to be showing improved leaf development and greater leaf presence (see Photograph 3 in Attachment B). However, the arborist recommended continued pruning and watering of those trees. Specifically, it was recommended that these trees be subject to regular watering as necessary based on existing soil conditions, pruning for sanitation and structure according to ANSI A300 (Part 1) Pruning Standards, removal of dead and weak wood one inch or larger, and general pruning to improve structure and favor a strong central leader where possible.

Additionally, during the inspection, tree cages, tree guards, and tree stakes (where present) were inspected and were generally found to be functioning as intended. One sugar maple tree on Parcell9-9-35, just north of the Pittsfield Economic Development Authority outfall, which had been observed to be unwrapped during the spring inspection, was observed to still be missing a tree wrap. This tree was identified to be addressed as part of GE's tree cage maintenance program for the restored and revegetated areas.

As shown in Attachment A, based on the September 2014 inspection, with the exception of the shrubscrub island area, the percent cover by native herbaceous species in all other monitoring areas (based on the results from the monitoring plots within them) is below the Performance Standard of 100% (outside the foliar cover of the trees). The areas with sparse cover included the above-mentioned grassed area along the lake-side of the walking path on the north side of the lake and the portion of the bank on the north shore of the lake where Japanese knotweed had been cut and treated Uointly Area 4). These two areas were identified for scarification and re-seeding during the fall growing season. It was concluded that the other sparsely vegetated herbaceous areas outside of those specific locations will likely continue to increase in vegetative cover so re-seeding is not necessary at this time.

With the exception of the shrub-scrub island monitoring plots SSI-1 and SSI-2 and monitoring plots 19-9-36-2 and 19-9-36-3, all other monitoring plots observed during the spring 2014 NRRE monitoring event were noted to have at least one invasive species present, but usually only a few individuals of such invasive species. Observed invasive species included autumn olive, coltsfoot, common buckthorn, cypress spurge, oriental bittersweet, phragmites, purple loosestrife, and yellow iris. As shown in Attachment A, the invasive species cover in each monitoring area (based on the results from the monitoring plots within them) is below the Performance Standard of 5%. The invasive species observed throughout the NRRE area will continue to be treated as part of GE's general invasive species control program for the restored and re-vegetated areas at the Silver Lake Area (as described in the Revised CIRW Report).

Walking Path and Benches

In accordance with the PRSCP/RPMMP and the Revised CIRW Report, the summer 2014 monitoring of the walking path and benches consisted of visual observations of these features to assess their presence, integrity, condition (e.g., cracked or missing bench pieces, pavement cracks/heaves), and ability to function as intended. No damage or other issues were identified during the September 4, 2014 inspection, and the walking path and benches were observed to be functioning as intended.

Post-Inspection and Future Activities

The areas and items identified during the summer NRRE inspection as requiring follow-up response actions are listed in Table 1. At EPA's e-mail request (with a copy to the Trustees), most of those activities - including pruning/watering of the trees in Area 2, scarifying and re-seeding the sparsely vegetated areas in Area 4, replanting the eight shrubs that were mowed down in Area 5, and treatment of invasive species - were conducted during other restoration activities performed at the Silver Lake Area from September 30 through October 20, 2014. As noted above, GE has proposed to postpone filling the voids in the armor stone around the periphery of the shrub-scrub island (between the area previously vegetated and the approximate 975.9 feet NGVD29 elevation contour) with topsoil and an herbaceous wetland species seed mix until the spring of 2015. The monitoring and maintenance/repair activities described in this letter will be summarized in the forthcoming 2014 Annual Monitoring Report to

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be submitted by GE to summarize the 2014 monitoring and maintenance activities at the Silver Lake Area.

The summer 2014 inspection fulfilled the requirements for the second post-construction monitoring event for the plantings in the NRRE area and the first post-construction monitoring event for the walking path and benches. GE will continue with the NRRE monitoring activities on the schedule specified in the PRSCP/RPMMP and the Revised CIRW Report until replaced by the NRRE monitoring requirements specified in the Final Completion Report for the Silver Lake Area Removal Action. The next scheduled inspection of the NRRE plantings is anticipated to be performed in the late spring of 2015 (May or June), while the next scheduled inspection of the walking path and benches is anticipated to be performed in the summer of 2015 (likely July or August).


Sincerely,

~~~"ffl~A~ \ \fv Richard W. Gates Senior Project Manager- Environmental Remediation

Attachments

cc: Dean Tagliaferro, EPA Tim Conway, EPA** Dave Dickerson, EPA Chris Ferry, ASRC Primus** Scott Campbell, Avatar (2 hard copies)** Robert Leitch, USACE** Michael Gorski, MDEP** John Ziegler, MDEP (2 hard copies)** Eva Tor, MDEP** Nancy E. Harper, MA AG* Kenneth Munney, USFWS** Susan Peterson, CT DEEP** Nate Joyner, Pittsfield Dept. of Community

Development**

James McGrath, Pittsfield Dept. of Parks and Recreation**

Corydon Thurston, Executive Director, PEDA** Barbara Landau, Noble & Wickersham** James Gagnon, O'Reilly, Talbot & Okun** Rod Mclaren, GE* Kevin Mooney, GE Andrew Silfer, GE James Bieke, Sidley Austin Mark Gravelding, ARCADIS Todd Cridge, ARCADIS** Public Information Repositories GE Internal Repositories


G \GE\GE_Sitver_Lake\Reports and Presentations\2014-1 0 NRRE summer inspection\225141 1 214_SL Summer NRRE Jnsp.doc

Table

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TABLE 1 SUMMARY OF ITEMS REQUIRING RESPONSE

SUMMER 2014 INSPECTION OF NATUAL RESOURCE RESTORATION/ENHANCEMENT MEASURES

SILVER LAKE AREA GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS

Area/Item Identified Description Follow-up Action

1 - Perimeter of Shrub-Scrub Island

The voids in a portion of the armor stone around the shrub-scrub island perimeter, down to the approximate 975.9 foot contour, were not filled with topsoil and seed.

In the area between the existing vegetation and the approximate 975.9 foot contour, fill voids with topsoil and seed with wetland seed mix. Proposed to be deferred until spring 2015.

3 - Large Trees along Eastern Bank of Silver Lake

Large ornamental trees along eastern bank were observed as stressed during the spring 2014 inspection. They showed improved leaf development in summer 2014 inspection; but arborist recommended continued maintenance.

Water the trees on a regular basis, as necessary based on soil conditions; prune them, as necessary, for sanitation and structure according to ANSI A300 (Part 1) Pruning Standards; remove dead and weak wood one inch or larger; and conduct general pruning to improve structure and favor a strong central leader where possible. These trees should not be fertilized.

4 – Sparse Herbaceous Cover

Sparse grass cover was observed in a narrow strip along the lake-side of the walking path on the north side of the lake on Parcel I9-9-36 and on a portion of the bank on the north shore of the lake where Japanese knotweed had been cut and treated as part of the invasive species control program.*

Scarify and re-seed these areas near the walking path.*

5 - Shrubs Mowed by City

Several shrubs along the walking path on Parcel I9-9-36 appeared to have been mowed down by the City of Pittsfield.

At EPA’s request, replace eight shrubs.

Other Stressed Shrubs

Seven shrubs in the I9-10-9-1 monitoring plot and one shrub in the I9-9-35-1 monitoring plot appeared to be stressed

Continue to monitor these shrubs.

Tree Cage Missing wrap on one sugar maple tree on Parcel I9-9-35, just north of the Pittsfield Economic Development Authority outfall.

Wrap tree as part of GE’s tree cage maintenance program.

Invasive Species Invasive species observed in most monitoring plots, but less than 5% coverage.

Treat invasive species as part of GE’s invasive species control program.

* In addition to Area 4, sparse grass cover was observed in a number of other areas, resulting in failure to meet the 100% Performance Standard for cover by native herbaceous species in all monitoring areas except the shrub-scrub island area. However, it was concluded that the other sparsely vegetated herbaceous areas outside of the two specific spots identified in Area 4 will likely continue to increase in vegetative cover so re-seeding is not necessary at this time.

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Attachment A

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ATTACHMENT AINTERIM CHECKLIST FOR INSPECTION OF NATURAL RESOURCE RESTORATION/ENHANCEMENT MEASURES



Inspection Date: 9/4/2014Conducted By: Anthony Esposito, Gregg Rabasco, Margaret MillerWeather Conditions: 75-80 degrees, sunny


A.

- Majority of plantings looked healthy. Several shrubs along walking path on Parcel I9-9-36 appeared to have been mowed down by the City; some appeared to be recovering while others were dead or missing. In addition, eight shrubs appeared to be stressed (see attached forms).- Buttonbush plantings on shrub-scrub island appeared to be healthy and growing as anticipated.- Large red oak trees along eastern bank of lake showed improved leaf development and greater leaf presence, but need continued watering and pruning.- One tree wrap on Parcel I9-9-35 (just north of PEDA outfall) was missing.

B.

- Grass areas seeded in the spring exhibited well-established cover, except for narrow strip of sparse vegetation alongthe lake-side of the walking path on the north-central side of the lake and nearby portion of the bank on the north

shore of the lake where the invasive species Japanese knotweed had been cut and treated (both on Parcel I9-9-36). - No herbivore damage observed.

C.

- Autumn olive, Coltsfoot, Common buckthorn, Cypress spurge, Oriental Bittersweet, Phragmites, Purple loosestrife, and Yellow Irisobserved in small concentrations throughout NRRE Areas.- Phragmites specifically noted on Shrub-Scrub Island outside of monitoring plots.

2.

3.

- Walking path and benches showed no signs of damage and were observed to be functioning as intended.

4.

- The large trees along the eastern bank of Silver Lake had been watered and pruned (as necessary).- Invasive species control program continued.- Areas identified for specific monitoring during the summer 2014 inspection were specifically inspected.- Voids in armor stone around perimeter of shrub scrub island that had not previously been filled and seeded had not yet been filled with topsoil and seeded.

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIES- In the voids in armor stone around perimeter of shrub scrub island that had not previously been filled and seeded, fill with topsoil and seed with herbaceous wetlands seed mix (proposed to be deferred until spring 2015). - Replace eight shrubs along the walking path that were mowed down by the City.- Prune and water the large red oak trees on the eastern bank of Silver Lake.

- Scarify and re-seed the sparsely vegetated area on the lake-side of the walking path on the north shore of the lake and the portion of the bank on the north shore where Japanese knotweed had been cut and treated.- Treat invasive species as part of GE’s invasive species control program, including phragmites on the shrub-scrub island.- Wrap sugar maple on Parcel I9-9-35, just north of PEDA outfall, as part of GE’s tree cage maintenance program.- Continue to monitor the seven stressed shrubs in plot I9-10-9-1 and the one stressed shrub in plot I9-9-35-1.

Indications of Sparse Vegetation or Damage from Trespassing or Herbivory (Note evidence of areas of bare/sparse vegetation; note any damage from trespassing or herbivory; note any physical changes since the last inspection.)


Restored Trees and Shrubs (Note any physical changes since the last inspection; note condition of trees and shrubs planted during restoration activities; note general condition of any tree guards, tree cages, and/or tree stakes, if present.)





FORM A-1



Page ___1____ of ______12____

Inspection Date: ___September 4, 2014 ____________________________________________________________ Conducted By/Observer(s): Anthony Esposito, Gregg Rabasco, and Margaret Miller of ARCADIS, Dave Dickerson of EPA, Michael Argue of Weston Solutions, Inc., Kenneth Munney of US Fish and Wildlife Services, Chris Frank of C.L. Frank & Co. _________ Weather Conditions: ________75-80 degrees, sunny _______________________________________ Monitoring Area: I9-10-9 Area Approximate Size (sf): 8,400 _ Monitoring Plot: I9-10-9-1 Approximate Size (sf): 730 _ Stem Count:

Trees # Planted (Baseline)

# Alive &

Healthy # Alive,

Stressed

Comparison of # Live Trees to Baseline Shrubs

# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed

Comparison of # Live

Shrubs to Baseline

Black willow 0 0 0 NA

Red-osier dogwood 20 17 2 -1

Silver maple 0 0 0 NA

Silky dogwood 0 0 0 NA

Eastern cottonwood 0 0 0 NA

Winterberry Holly 4 2 2 Same

Sugar maple 0 0 0 NA

Choke cherry 0 0 0 NA

Red oak 0 0 0 NA

Northern arrowwood 5 2 3 Same

Red maple 0 0 0 NA

Nannyberry viburnum 0 0 0 NA

Serviceberry

0 0 0 NA

Black chokeberry 0 0 0 NA

Pussy-willow

0 0 0 NA

Speckled alder 0 0 0 NA

Buttonbush

0 0 0 NA Total Live Trees: _______________0_____________ Total Live Shrubs: ____________28_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________95%___________ Invasive Plant Cover (%): ___________5%__________

FORM A-1



Page ___2____ of ______12____

Inspection Date: ___September 4, 2014 ____________________________________________________________ Conducted By/Observer(s): Anthony Esposito, Gregg Rabasco, and Margaret Miller of ARCADIS, Dave Dickerson of EPA, Michael Argue of Weston Solutions, Inc., Kenneth Munney of US Fish and Wildlife Services, Chris Frank of C.L. Frank & Co. _________ Weather Conditions: ________75-80 degrees, sunny _______________________________________ Monitoring Area: I9-10-9 Area Approximate Size (sf): 8,400 _ Monitoring Plot: I9-10-9-2 Approximate Size (sf): 1,890 _ Stem Count:


# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline

Black willow 2 2 0 Same

Red-osier dogwood 19 20 0 +1

Silver maple 2 2 0 Same






Red oak 0 0 0 NA


Red maple 0 0 0 NA


Serviceberry

0 0 0 NA


Pussy-willow

0 0 0 NA


Buttonbush

0 0 0 NA Total Live Trees: _______________4_____________ Total Live Shrubs: ____________30_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________85-90% (mulch impeding cover)___________ Invasive Plant Cover (%): ___________<5%__________

FORM A-1



Page ___3____ of ______12____



# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline




Silky dogwood 2 2 0 Same


Winterberry Holly 10 9 0 -1


Choke cherry 3 3 0 Same

Red oak 0 0 0 NA


Red maple 0 0 0 NA

Nannyberry viburnum 1 0 0 -1

Serviceberry

2 2 0 Same

Black chokeberry 2 2 0 Same

Pussy-willow

0 0 0 NA


Buttonbush

0 0 0 NA Total Live Trees: _______________0_____________ Total Live Shrubs: ____________56_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): ____90% ___________ Invasive Plant Cover (%): ___________ <5%__________

FORM A-1



Page ___4____ of ______12____



# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline


Red-osier dogwood 25 25 0 Same







Red oak 0 0 0 NA


Red maple 0 0 0 NA

Nannyberry viburnum 1 1 0 Same

Serviceberry

2 2 0 Same


Pussy-willow

1 1 0 Same

Speckled alder 2 2 0 Same

Buttonbush

0 0 0 NA Total Live Trees: _______________0_____________ Total Live Shrubs: ____________52_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________65% (top of bank) to 100% (bank face) ___________ Invasive Plant Cover (%): ___________ 0%_________

FORM A-1



Page ___5____ of ______12____



# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline









Red oak 0 0 0 NA

Northern arrowwood 7 4 0 -3

Red maple 0 0 0 NA


Serviceberry

1 2 0 +1


Pussy-willow

2 2 0 Same


Buttonbush

0 0 0 NA Total Live Trees: _______________0_____________ Total Live Shrubs: ____________44_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________90% ___________ Invasive Plant Cover (%): ___________ 0%__________

FORM A-1



Page ___6____ of ______12____



# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline






Winterberry Holly 6 5 0 -1



Red oak 0 0 0 NA


Red maple 0 0 0 NA


Serviceberry

2 2 0 Same

Black chokeberry 4 4 0 Same

Pussy-willow

0 0 0 NA


Buttonbush

0 0 0 NA Total Live Trees: _______________0_____________ Total Live Shrubs: ____________46_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________95%___________ Invasive Plant Cover (%): ___________ 5%__________

FORM A-1



Page ___7____ of ______12____

Inspection Date: ___September 4, 2014 ____________________________________________________________ Conducted By/Observer(s): Anthony Esposito, Gregg Rabasco, and Margaret Miller of ARCADIS, Dave Dickerson of EPA, Michael Argue of Weston Solutions, Inc., Kenneth Munney of US Fish and Wildlife Services, Chris Frank of C.L. Frank & Co. _________ Weather Conditions: ________75-80 degrees, sunny _______________________________________ Monitoring Area: Shrub-Scrub Island Area Approximate Size (sf): 21,400 _ Monitoring Plot: SSI-1 Approximate Size (sf): 500 _ Stem Count:


# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline






Winterberry Holly 0 0 0 NA



Red oak 0 0 0 NA

Northern arrowwood 0 0 0 NA

Red maple 0 0 0 NA


Serviceberry

0 0 0 NA


Pussy-willow

0 0 0 NA


Buttonbush

3 3 0 Same Total Live Trees: _______________0_____________ Total Live Shrubs: ____________36_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________100%___________ Invasive Plant Cover (%): ___________ 0%_____ ___

FORM A-1



Page ___8____ of ______12____

Inspection Date: ___September 4, 2014 ____________________________________________________________ Conducted By/Observer(s): Anthony Esposito, Gregg Rabasco, and Margaret Miller of ARCADIS, Dave Dickerson of EPA, Michael Argue of Weston Solutions, Inc., Kenneth Munney of US Fish and Wildlife Services, Chris Frank of C.L. Frank & Co. _________ Weather Conditions: ________75-80 degrees, sunny _______________________________________ Monitoring Area: Shrub-Scrub Island Area Approximate Size (sf): 21,400 _ Monitoring Plot: SSI-2 Approximate Size (sf): 500 _ Stem Count:


# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline









Red oak 0 0 0 NA


Red maple 0 0 0 NA


Serviceberry

0 0 0 NA


Pussy-willow

0 0 0 NA


Buttonbush

16 16 0 Same Total Live Trees: _______________0_____________ Total Live Shrubs: ____________41_______________

Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________100%___________ Invasive Plant Cover (%): ___________ 0%_____ ___

FORM A-1



Page ___9____ of ______12____



# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline




Silky dogwood 2 3 0 +1





Red oak 0 0 0 NA

Northern arrowwood 5 6 1 +2

Red maple 0 0 0 NA


Serviceberry

1 1 0 Same

Black chokeberry 3 2 0 -1

Pussy-willow

1 1 0 Same


Buttonbush

0 0 0 NA Total Live Trees: _______________0_____________ Total Live Shrubs: ____________40_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________90% ___________ Invasive Plant Cover (%): ___________ <5%__________

FORM A-1



Page ___10____ of ______12____



# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline







Sugar maple 3 3 0 Same


Red oak 3 3 0 Same


Red maple 0 0 0 NA


Serviceberry

0 0 0 NA


Pussy-willow

0 0 0 NA


Buttonbush

0 0 0 NA Total Live Trees: _______________6_____________ Total Live Shrubs: ____________15_______________

Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________95% ___________ Invasive Plant Cover (%): ___________ <5%__________

FORM A-1



Page ___11____ of ______12____



# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline







Sugar maple 2 2 0 Same


Red oak 2 2 0 Same


Red maple 1 1 0 Same


Serviceberry

0 0 0 NA


Pussy-willow

0 0 0 NA


Buttonbush

0 0 0 NA Total Live Trees: _______________5_____________ Total Live Shrubs: ____________15_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________95% ___________ Invasive Plant Cover (%): ___________ 5% __________

FORM A-1



Page ___12____ of ______12____



# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline

Black willow 2 2 0 Same




Eastern cottonwood 1 1 0 Same




Red oak 0 0 0 NA


Red maple 0 0 0 NA


Serviceberry

0 0 0 NA


Pussy-willow

0 0 0 NA


Buttonbush

0 0 0 NA Total Live Trees: _______________3_____________ Total Live Shrubs: ____________12_______________ Were two or more adjacent trees observed to be dead (Y/N):_____N_________ Herbaceous Cover (%): _____________95% ___________ Invasive Plant Cover (%): ___________ <5%__________

10/31/2014G:\GE\GE_Silver_Lake\Reports and Presentations\2014-10 NRRE summer inspection\2251411214_Attachment A - Checklist A-1 and tables A-1_10-29.xls Page 1 of 1

Date of Monitoring: September 4, 2014


Average Width Area Total Total Herbaceous Invasive Plant


I9-10-9-1 65 11 730 0 0 0 0 0 0 0 19 0 4 0 5 0 0 0 0 0 0 28 95% 5%

I9-10-9-2 60 29 1,886 2 2 0 0 0 0 4 20 0 5 0 5 0 0 0 0 0 0 30 85-90% <5%

I9-9-36-1 59 41 2,322 0 0 0 0 0 0 0 29 2 9 3 9 0 2 2 0 0 0 56 90% <5%

I9-9-36-2 57 45 2,491 0 0 0 0 0 0 0 25 2 10 0 9 1 2 0 1 2 0 52 65% (top of bank) to 100% (bank face) 0%

I9-9-36-3 61 33 1,878 0 0 0 0 0 0 0 23 1 8 2 4 0 2 0 2 2 0 44 90% 0%

I9-9-36-4 60 29 1,928 0 0 0 0 0 0 0 21 2 5 3 6 3 2 4 0 0 0 46 95% 5%

SSI-1 25 20 500 0 0 0 0 0 0 0 33 0 0 0 0 0 0 0 0 0 3 36 100% 0%

SSI-2 25 20 500 0 0 0 0 0 0 0 25 0 0 0 0 0 0 0 0 0 16 41 100% 0

I9-9-35-1 59 51 2,965 0 0 0 0 0 0 0 17 3 5 1 7 2 1 2 1 1 0 40 90% <5%

I9-9-35-2 63 28 1,777 0 0 0 3 3 0 6 15 0 0 0 0 0 0 0 0 0 0 15 95% <5%

I9-9-35-3 59 34 2,172 0 0 0 2 2 1 5 15 0 0 0 0 0 0 0 0 0 0 15 95% 5%

I9-9-35-4 61 27 1,453 2 0 1 0 0 0 3 4 0 4 0 4 0 0 0 0 0 0 12 95% <5%

Notes:


1. The number of trees and shrubs listed in this table includes all live trees and shrubs observed within each monitoring plot. No dead or missing trees were observed in any monitoring plot during the summer 2014 vegetation inspection. Dead or missing shrubs were observed in a number of monitoring plots, as shown on the Form A-1s. Percent survival is shown in Table A-2.




I9-10-9 Area

I9-9-36 Area


I9-9-35 Area

TABLE A-2 SUMMARY OF QUANTITATIVE ASSESSMENT

SILVER LAKE AREA GENERAL ELECTRIC COMPANY – PITTSFIELD, MASSASCHUSETTS

Dates of Monitoring: September 4, 2014

Area Plot No. Trees Shrubs

Herbaceous Cover (%)

Invasive Plant

Cover (%) No.

Planted No.

Alive % Survival > 80% Survival

No. Planted

No. Alive % Survival > 80%

Survival

I9-10-9 I9-10-9-1 0 0 NA -- 29 28 97% -- 95% 5% I9-10-9-2 4 4 10110100%000% -- 29 30 103% -- 85-90% < 5% Average -- -- 110100%%% YES -- -- 10100%0% YES <1< 100%00 > < 5%%

I9-9-36

I9-9-36-1 0 0 NA -- 55 56 102% -- 90% < 5% I9-9-36-2 0 0 NA -- 52 52 100% -- 65-100% 0% I9-9-36-3 0 0 NA -- 46 44 96% -- 90% 0% I9-9-36-4 0 0 NA -- 43 46 107% -- 95% 5% Average -- -- NA NA -- -- 101% YES < 1< 100%0% < < 5%5%

Shrub-Scrub Island

SSI-1 0 0 NA -- 37 36 97% -- 100% 0% SSI-2 0 0 NA -- 40 41 103% -- 100% 0%

Average -- -- NA NA -- -- 10100%0% YES < 100%0% 0 0%%

I9-9-35

I9-9-35-1 0 0 NA -- 38 40 105% -- 90% < 5% I9-9-35-2 6 6 1 100%0% -- 15 15 100% -- 95% < 5% I9-9-35-3 5 555 1 0100%00% -- 15 15 100% -- 95% 5% I9-9-35-4 3 3 1100%0% -- 13 12 92% -- 95% < 5% Average -- -- 10100%0% YES -- -- 099%% YES <0< 100%% < < 5%5%

Notes: 1. Average percent survival of trees and shrubs is based on only those plots in which trees or shrubs were planted. 2. Averages not meeting the applicable Performance Standards are highlighted in yellow. 3. NA = Not applicable.

Attachment B

ATTACHMENT B PHOTOGRAPHIC LOG SUMMER 2014 INSPECTION OF NATURAL RESOURCE RESTORATION/ENHANCEMENT PLANTINGS SILVER LAKE AREA GENERAL ELECTRIC COMPANY – PITTSFIELD, MASSACHUSETTS

G:\GE\GE_Silver_Lake\Reports and Presentations\2014-10 NRRE summer inspection\2251411214_Attachment B - Photo Log.docx Page 1 of 3

Photograph 1: Area of sparse, but established, grass cover along walkway on north end of lake, looking east.

Photograph 2: North bank area of sparse vegetation where Japanese Knotweed was treated and cut.



Photograph 3: Walking path and large trees of the eastern portion of the lake, looking north.

Photograph 4: Walking path and bank vegetation in northwest portion of lake, looking east.



Photograph 5: Western portion of shrub-scrub Island, looking southwest.

Photograph 6: Eastern portion of shrub-scrub Island, looking southeast.

Attachment C

10/31/2014G:\GE\GE_Silver_Lake\Reports and Presentations\2014-10 NRRE summer inspection\2251411214_Attachment C - InvasiveSpecies.xls Page 1 of 1














Notes:

SILVER LAKE AREA



ATTACHMENT CINVASIVE SPECIES OF CONCERN


2. Reference:

December 17, 2014 SL Summary of 2014 Annual ERE Inspection Activities

Transmitted via Overnight Courier or Electronic Delivery

December 17, 2014

Mr. Dave Dickerson Office of Site Remediation and Restoration U.S. Environmental Protection Agency, Region I 5 Post Office Square- Suite 100 Boston, MA 02109-3912

Re: GE-Pittsfield/Housatonic River Site Silver Lake Area (GECDGOO)

GE Corporate


Mr. Michael Gorski Regional Director Western Regional Office Department of Environmental Protection 436 Dwight Street Springfield, MA 01103

Summary of 2014 Annual ERE Inspection Activities

Dear Messrs. Dickerson and Gorski:

On November 18, 2014, the General Electric Company (GE) completed inspections of properties located within the Silver Lake Area in Pittsfield, Massachusetts at which Grants of Environmental Restrictions and Easements (EREs) have been executed and recorded under the Consent Decree (CD) for the GEPittsfield/Housatonic River Site. Pursuant to the CD and the accompanying Statement of Work for Removal Actions Outside the River (SOW), GE implemented a Removal Action at the Silver Lake Area between July 2012 and December 2013. EREs were executed and recorded in the Berkshire Middle District Registry of Deeds in 2014 for the following properties within the Silver Lake Area: (a) portions of Parcels 19-9-32 and 19-9-33, both of which are privately owned (EREs recorded on January 7, 2014 in Book 5322, Pages 103 and 70, respectively); (b) Parcell9-9-35, a former GE-owned property that is now owned by the Pittsfield Economic Development Authority (PEDA) (ERE recorded on March 31, 2014 in Book 5356, Page 255); and (c) Parcels 19-9-36 and 19-10-9, owned by PEDA (ERE that covers both parcels recorded on April4, 2014 in Book 5359, Page 1). Under Paragraph 57 of the CD, GE is required to perform an annual inspection of non-GE-owned properties subject to an ERE to assess compliance with the ERE. This letter presents the results of the first annual ERE inspection conducted by GE at Parcels 19-9-32, 19-9-33, 19-9-35, 19-9-36, and 19-10-9.

GE conducted these ERE inspections in accordance with the requirements of Appendix Q to the CD and the ERE inspection requirements in GE's Post-Removal Site Control Plan and Restoration Project Monitoring and Maintenance Plan (PRSCP/RPMMP) (Appendix I to GE's conditionally approved Revised Final Removal Design/Removal Action Work Plan for Silver Lake Area, dated August 2011 ), with an updated interim inspection checklist. Under those requirements, the annual ERE inspections are to consist of two components -a document review and a visual on-site inspection. The first component is to include review of several documents (as applicable) for each property- namely: (i) the ERE itself, (ii) the Plan of Restricted Area, (iii) documents describing the property, including a technical drawing showing surface grades, (iv) any conditional exceptions approved under the ERE (if known), (v) any recorded amendments to and/or releases from the ERE, and (vi) any Post-Work Notification Forms (Exhibit E or F to the ERE, depending on the ERE) available to GE. The second component is to consist of a visual inspection of the property (or pertinent portion) to determine whether there is visual evidence that any of the following have occurred since the last inspection (or, in this case, since recordation of the ERE):

Corporate Environmental Programs

Dave Dickerson and Michael Gorski December 17, 2014

Page 2 of 3

• Activities at or uses of the property that are potentially contrary to the restrictions stated in the ERE;

• Utility work or any building construction, modification, addition, and/or demolition;

• Soil excavations that involved more than 10 cubic yards of soil;

• Significant soil erosion; and

• Significant pavement construction, disturbance, and/or removal/excavation.

Following the inspection, GE is required to submit to the U.S. Environmental Protection Agency (EPA) and the Massachusetts Department of Environmental Protection (MDEP) a report that includes a summary of the findings of the ERE inspections, a description and the basis for the identification (based on the visual inspection in conjunction with the document review) of any instances of potential noncompliance with the EREs, and copies of a completed ERE Annual Inspection Checklist for each property.

As noted above, GE conducted the first annual ERE inspections of the above-listed properties in November 2014. The inspections of Parcels 19-9-32 and 19-9-33 focused only on the Restricted Area of the property under the ERE (including the bank). The inspections of each of the other properties focused on the entire property, since the entire property constitutes the Restricted Area. The results of these inspections were documented in an ERE Annual Inspection Checklist for each property (using an updated version of the interim checklist provided in the PRSC/RPMMP). Copies of the completed checklists are attached.

As indicated on the attached checklists, GE reviewed the ERE and Plan of Restricted Area for each property, as well as relevant post-remediation topographic as-built survey drawings developed for the forthcoming Final Completion Report (FCR) for the Silver Lake Area Removal Action, which depict current site features and topography. 1 The document review revealed no new ERE-related documentation for any of these properties since the recordation of the EREs.2 As also documented on the attached checklists, the visual inspections conducted on November 18, 2014 revealed no significant changes in the physical condition of the Restricted Areas of the properties and no evidence of any of the other abovelisted conditions since recordation of the EREs.

As required by the CD, these properties will continue to be inspected annually. Following GE's submittal and EPA's approval of the FCR for the Silver Lake Area Removal Action, those inspections will be conducted in accordance with the requirements specified in that FCR for ERE inspections, using the pertinent inspection checklist provided in the FCR. Following each such ERE inspection, an inspection report will be prepared and submitted to EPA and MDEP.

Please call me if you have any comments or questions.

Sincerely,

~~~~~ Richard W. Gates Senior Project Manager Global Operations - Environment, Health and Safety

Attachments

1 Each of the attached checklists refers to an attached post-remediation topographic drawing. However, to avoid duplication, three as-built topographic drawings that show all of the properties with EREs - designated Drawings CX105, CX106, and CX107- are attached after all of the checklists. 2 However, it was noted that, by an agreement recorded in the Registry of Deeds on May 23, 2014 in Book 5380, Page 318, PEDA granted an easement on Parcels 19-9-35, 19-9-36, and 19-10-9 to the City of Pittsfield (subject to the EREs) for use and maintenance of the walking path and associated structures constructed on those properties.

G:\GE\GE_ Silver_Lake\Reports and Presentations\20 14~12 ERE insp rpt\343l411324LtrRpt.doc

cc: Dean Tagliaferro, EPA Tim Conway, EPA* Chris Ferry, ASRC PrimusA Scott Campbell, Avatar (2 hard copies)A Robert Leitch, USACEA John Ziegler, MDEP (2 hard copies)A Eva Tor, MDEPA Nancy E. Harper, MA AG* Nate Joyner, Pittsfield Dept. of Community DevelopmentA James McGrath, Pittsfield Dept. of Parks and RecreationA Corydon Thurston, Executive Director, PEDAA James Gagnon. O'Reilly, Talbot & OkunA Barbara Landau, Noble & WickershamA Andrew Silfer, GE* Rod Mclaren, GE* Kevin Mooney, GEA Todd Cridge, ARCADISA Mark Gravelding, ARCADISA James Bieke, Sidley Austin LLP Property Owners - Parcels 19-9-32 and 19-9-33** GE Internal Repository

* cover letter only ** relevant attachment only

electronic copy A

G:\GE\GE_Silver_Lake\Reports and Presentations\2014~12 ERE insp rpt\343 J4Il324LtrRpt.doc


Page 3 of 3

INTERIM ERE ANNUAL INSPECTION CHECKLIST

SILVER LAKE AREA


Page 1 of 2

PARCEL I9-9-32 DOCUMENT REVIEW

Conducted By: Paolo Filippetti (ARCADIS) Phone Number: 585-662-4035 Representing: GE Review Start Date: November 10, 2014

1. X Check here to confirm that the Grant of Environmental Restriction and Easement (ERE) and associated survey

plan (i.e., Plan of Restricted Area or Plan of Property and Restricted Area) have been reviewed and are available on-site for review during the visual inspection.

2. X Check here to confirm that the attached post-remediation topographic drawing of this property (which has been developed for the Final Completion Report for Silver Lake Area Removal Action and which GE proposes to use for the comparison described in Item 7 on next page) has been reviewed and is available on-site for review during the visual inspection.

3. Are there any recorded amendments to or releases from the ERE, and/or any known conditional exceptions under the ERE, and/or any Post-Work Notification Forms submitted by the Grantor under the ERE of which the reviewing party has a copy, and/or any other documents in GE’s possession relevant to the ERE or the use of the property? X No ___ Yes – If yes, review those items for background informational purposes and list them below (along with the book and page reference in the Registry of Deeds where applicable). (Note that the document reviewer has no obligation to verify the accuracy or completeness of any of these documents, either as of the time they were prepared or as compared to the current conditions.)

5. Review Completed: November 18, 2014 VISUAL ON-SITE INSPECTION

Conducted By: Gregg Rabasco (ARCADIS) Representing: GE Inspection Start Date: November 18, 2014

1. List other individuals and their company/agency that were present during the visual on-site inspection.

Izabela Zapisek – Avatar Environmental / EPA

2. Is there any visual evidence of activities and uses at the Restricted Area of the property (as described in the ERE) since recordation of the ERE that are potentially contrary to the restrictions of the ERE?

X No ___ Yes – If yes, describe below.


SILVER LAKE AREA


Page 2 of 2

3. Is there any visual evidence of utility work or building construction, modification, addition, or demolition at the Restricted Area of the property since recordation of the ERE?

X No ___ Yes – If yes, describe below and show the location(s) of such activity on a plan.

4. Is there any visual evidence of soil excavation at the Restricted Area of the property that generated more than 10 cubic yards of soil since recordation of the ERE?


5. Is there any visual evidence of significant soil erosion at the Restricted Area of the property since recordation of the ERE?


6. Is there any visual evidence of significant pavement construction, disturbance, or excavations at the Restricted Area of the property since recordation of the ERE?


7. If any of the conditions listed in the response to Questions 3 through 6 appears likely to have altered the surface grade of the Restricted Area of the property, identify the approximate area/location(s) of such grade change on a plan and compare the new surface grade in such area(s) to the surface grade shown on the attached post-remediation topographic drawing (which has been developed for the Final Completion Report and which GE proposes to use for this comparison). 8. Inspection Completed: November 18, 2014


SILVER LAKE AREA


Page 1 of 2






3. Are there any recorded amendments to or releases from the ERE, and/or any known conditional exceptions under the ERE, and/or any Post-Work Notification Forms submitted by the Grantor under the ERE of which the reviewing party has a copy, and/or any other documents in GE’s possession relevant to the ERE or the use of the property? X No ___ Yes – If yes, review those items for background informational purposes and list them below (along with the book and page reference in the Registry of Deeds where applicable). (Note that the document reviewer has no obligation to verify the accuracy or completeness of any of these documents, either as of the time they were prepared or as compared to the current conditions.)








SILVER LAKE AREA


Page 2 of 2











SILVER LAKE AREA


Page 1 of 2






3. Are there any recorded amendments to or releases from the ERE, and/or any known conditional exceptions under the ERE, and/or any Post-Work Notification Forms submitted by the Grantor under the ERE of which the reviewing party has a copy, and/or any other documents in GE’s possession relevant to the ERE or the use of the property? X No ___ Yes – If yes, review those items for background informational purposes and list them below (along with the book and page reference in the Registry of Deeds where applicable). (Note that the document reviewer has no obligation to verify the accuracy or completeness of any of these documents, either as of the time they were prepared or as compared to the current conditions.) Note: On May 23, 2014, an agreement was recorded in the Berkshire Middle District Registry of Deeds in Book 5380, Page 318, under which the property owner, the Pittsfield Economic Development Authority, granted an easement on this property to the City of Pittsfield (subject to the ERE) for use and maintenance of the walking path and associated structures constructed on the property.








SILVER LAKE AREA


Page 2 of 2











SILVER LAKE AREA


Page 1 of 2

PARCELS I9-10-9 and I9-9-36 DOCUMENT REVIEW





3. Are there any recorded amendments to or releases from the ERE, and/or any known conditional exceptions under the ERE, and/or any Post-Work Notification Forms submitted by the Grantor under the ERE of which the reviewing party has a copy, and/or any other documents in GE’s possession relevant to the ERE or the use of the property? X No ___ Yes – If yes, review those items for background informational purposes and list them below (along with the book and page reference in the Registry of Deeds where applicable). (Note that the document reviewer has no obligation to verify the accuracy or completeness of any of these documents, either as of the time they were prepared or as compared to the current conditions.) Note: On May 23, 2014, an agreement was recorded in the Berkshire Middle District Registry of Deeds in Book 5380, Page 318, under which the property owner, the Pittsfield Economic Development Authority, granted an easement on this property to the City of Pittsfield (subject to the ERE) for use and maintenance of the walking path and associated structures constructed on the property.








SILVER LAKE AREA


Page 2 of 2










NEW CONCRETE SIDEWALK

,----coNNfoCTING TO FOURTH STREET SIDEWALK

NEW CONCRETE PADS WITH

--~--DETECTABLE WARNING. MAT.

RESTORED METAL G.UARD RAIL

INVERT OUT 8 11

PVC = 975.951±

FOURTJ.l STREET OUTFALL WIT!-! RESTORED STEEL PIPE RAILING ALONG TOP OF 1-!EAOWALL.

(FOR DRAWINGS CXIOS, CX!O~, $ CXI07)

GENERAL PLAN NOTES:

CLUSTER PLANTING.$ INSTALLED ON ROAD-SIDE OF WALKING. PAT!-! WITH A MIXTURE OF SPECIES INC!:.UDING: NANNYBERRY VIBURNUM, SERVICEBERRY, 51 LI<Y DOGWOOD 1 BLACK CHOKEBERRY $ CI-40KE l::.\\...Y~~ CI-4ERRY. ;;J

NEW CONCRETE PAD WITl-1 BENCJ.l. TYP.

1. THE AS-BUlL T SITE TOPOGRAPHIC SURVEY (WITHIN THE WORK LIMITS) WAS PERFORMED BY HILL-ENGINEERS, ARCHITECTS, PLANNERS, INC. BETWEEN JUNE-NOVEMBER 2013. NEW OR RESTORED SITI:O FEATURES (AS IDENTIFIED TO J.liLL) AT THE TIME OF TI-lE SURVEY ARE SJ.lOWN HEREON. FOR DRAWING CLARITY EXISTING SITE FEATURES, THAT WERE UNCI-IANGED BY CONSTRUCTION, ARE GENERALLY NOT SI-!OWN.

2. REFER TO SILVER LAKE PLANTING RESTORA1-ION TABLE IN Ti-llS APPENDIX FOR SPECIES ¢ QUANTITIES PLANTED ON BOTH TI-lE RECREATIONAL AREAS AND THE PRIVATE PARCELS AS PROVIDED BY TI-lE LANDSCAPING CONTRACTOR.

SINGLE ROW OF

DOGWOODS.

INVERT OUT 10 11

CMP = "118.5'±

CLUSTER PL~\NTINGS INSTALLED ON LAKEWARD SIDE OF WALKING PATI-I WITH A MIXTIJRE OF

..____ SPECIES INCLUDING: NANNYBERRY VIBURNUM, SERVICEBERF:Y, SILKY DOGWOOD, BI..ACK CHOKEBERRY, AND CHOKE CI-IERRY IN DRY SOIL AREAS, AND PUSSY-WILLOW AND SPECKLED Al.DER IN MOIST SOIL AREAS.

SILVER LAKE WATER ELEVATION "175."11±

(NOVEMBER 2013)

NEW BITUMINOUS 51 WIDE WALKING PAT!-!

INVERT OUT 12" CMP .. "17~.31 :!:

OBLONG PATCH PLANTINGS INSTALLED ON LAKEWARD SIDE OF WALKING PATJ.l WITH A MIXTURE OF SPECIES INCLUDING: RED-OSIER DOGWOODS, NORTHERN ARROWWOODS, AND WINTERBERRY !-lOLLY.

SINGLE ROW OF RED-OSIER DOGWOODS.

NEW

INLET

INVERT OUT 12 11

CMP = "17~.21±

4" I-lPPI~ INVERT·-~ OUT = "178.25'

NEW VERSA-LOK RETAINING WALL 1$ NEW FENCING

I SJ.lRUB-SCRUB

·~D

...___ INVERT OUT 8 11

1-lDPE ,. "178.2'±

NRRE PLANTINGS ON 5!-IRUB-SCRUB ISLAND INCLUDE RED-OSIER DOGWOOD (IN DRIER AREAS) AND BUTTONBUS!-1 5!-IRUElS (IN AREAS OF LOWER ELEVATION).

LEGEND (FOR DRAWINGS CXIOS, CXI061 ¢ CXI07)

®

83

----- -"176-- ---------'180-----

A v

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UTILITY POLE

GUY WIRE

SIGN

SANITARY MANHOLE

MONITORING WELL

CA TCJ.l BASIN

APPROXIMATE PROPERTY LINE

AS-BUlL T CONTOUR

EDGE OF GRAVEL

DENOTES ROW OF NEW PLANTINGS

EDGE OF BLACKTOP

VERSA-LOK RETAINING WALL

METAL GUARD RAIL

NEW CJ.IAIN LINK FENCE

UNDERGROUND STORM DRAIN

LIMIT ON NEW SEEDING

EDGE OF WATER

EDGE OF NEW PLANTINGS

STONE ARMOR

NEW BITUMINOUS

NEW OBLONG PATCJ.l OF PLANTINGS

NEW CLUSTER OF PLANTINGS

NEW DECIDUOUS TREE

NEW CONIFEROUS TREE

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RESTORED CHAIN LINK FENCING.

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NEW RIP RAP SWALE

SILVER LAKE WATER ELEVATION Gl7S."l'±

(NOVEMBER 2013)

DOUBLE ROW OF Sl-JRUBS WITI-1 A MIXTURE OF SPECIES

,---11\ICLIJDIING: RED-OSIER DOGWOOD, NORTHERN ARROWWOOD $ WINTEREIERRY HOLLY.

TRIPL.E ROW OF SHRUBS WITH A MIXTURE OF SPECIES

RED-OSIER DOGWOOD, NORTHERN ARROWWOOD $ WINTEREIERRY HOL.LY.

INVERT OUT IS" HOPE = "175.8':1: --

INVERT OUT IS" HDPE " "17l>.S':I:

EXt!:>TING BUSiiNESS SIGI>J

CLUSTER PLANTINGS INSTALLED ON LAKEWARD SIDE OF WALKING PATH WITH A MIXTURE OF SPECIES INCLUDING: NANNYBERRY VIBURNUM, SERVICEBERRY, SILKY DOGWOOD, Bt..ACK CHOKEBERRY,-~ AND CHOKE CI-IERR'r IN DRY SOIL AREAS, AND PUSSY-WILLOW AND SPECKLED ALDER IN MOIST SOIL AREAS.

OBLONG PATCH PLANTINGS INSTALLED ON LAKEWARD SIDE OF WALKING PATH WITH A MIXTURE OF. SPECIES INCLUDING: -------\ RED-OSIER DOGWOODS, NORTHERN ARROWWOODS, AND WINTEREIERRY HOLLY.

SINGLE ROW OF RED-OSIER _._... DOGWOODS.

SIJ-JGLE ROW OF TREES IN~>TALLED WITH A MIXTURE OF SPECIES INCLUDING: SUGAR --MAPLE1 RED OAK, AND RED MAPLE.

EXISTING STORMWATER BOX CULVERT FROM PEDA WATER QUALITY BASIN. NEW FENCING INSTALLED ALONG TOP OF OUTFALL AND WINGWALLS.

NEW BITUMINOUS S' WIDE WALKING PATH


NEW CONCRETE PAD FOR NEW BENCH.

NEW CONCRETE PAD WITH DETECTABLE WARNING MAT.

INVERT OUT 12" CMP = "178.8':1: -..___


r-COI~NE:CTI!NG TO PEDA SIDEWALK.

SINGLE ROV>I OF SHRUBS WITH A MIXTURE OF SPECIES INCLUDING: RED-OSIER DOGWOOD, NORTHERN ARROWWOOD $ WINTEREIERRY HOLL.Y.

INVERT OUT 10" RCP = "176.81 :1:

SINGLE ROW OF TREES INSTALLED WITH A MIXTURE OF

"'""t-- SPECIES INCL.UDING: BLACK

RESTORED METAL GUARD RAIL

WILLOW AND EASTERN COTTONWOOD.

EAST STREET (BITUMINOUS)

RESTORED CONCRETE SIDEWALK

CLUSTER PL.~N1.1N<;SI INSTALLED ON ROAD-SIDE OF WALKING PATH WITH A MIXTURE OF SPECIES INCLUDING: NANNY6ERRY VIBURNUM, SERVICEBERRY1 SILKY DOGWOOD, < BLACK CHOKEBERRY

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DOUBLE ROv-1 OF SHRUBS WITJ..l A MIXTURE OF SPECIES INCLUDING, RED-OSIER DOGV'IOOD, NORTI-lERN ARROWWOOD t WINTERBERRY !-lOLLY.

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SILVER LAKE WATER ELEVATION "175."1'±

(NOVEMBER 2013)

1"1-"1-20!

FOR PARCEL 1"1-"1-17, DOUBLE ROW OF SHRUBS WITI-l A MIXTURE OF SPECIES INCLUDING: RED-OSIER DOGWOOD, NORTHERN ARROV'IWOOD t SERVICEBERRY.

---

I

RESTORED CJ..lAIN LINK FENCING.

1"1-"1-17

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RIPRAP Sv-IALE.

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December 17, 2014 SL Summary of 2014 Conditional Solution Inspection Activities

Transmitted via Overnight Courier or Electronic Delivery

December 17, 2014

Mr. Dave Dickerson Office of Site Remediation and Restoration U.S. Environmental Protection Agency, Region I 5 Post Office Square - Suite 1 00 Boston, MA 02109-3912


GE Corporate


Mr. Michael Gorski Regional Director Western Regional Office Department of Environmental Protection 436 Dwight Street Springfield, MA 01103

Summary of 2014 Conditional Solution Inspection Activities

Dear Messrs. Dickerson and Gorski:

On November 18, 2014, the General Electric Company (GE) completed inspections of properties located within the Silver Lake Area in Pittsfield, Massachusetts at which Conditional Solutions have been implemented under the Consent Decree (CD) for the GE-Pittsfield/Housatonic River Site. Those properties are Parcels 19-9-201 and 19-9-17, Parcels 19-9-21 & -22, Parcel 19-9-25, and Parcel 19-9-34. GE sent letters to the owners of these properties on February 6, 2014, notifying them of the implementation of Conditional Solutions at their properties. For non-GE-owned properties at which a Conditional Solution has been implemented, the CD requires certain annual post-remediation review and inspection activities. The November 2014 inspections were conducted in accordance with Paragraphs 36 and 38 and Appendix Q of the CD and the Conditional Solution inspection requirements in GE's PostRemoval Site Control Plan and Restoration Project Monitoring and Maintenance Plan (PRSCP/RPMMP) (Appendix I to GE's conditionally approved Revised Final Removal Design/Removal Action Work Plan for Silver Lake Area, dated August 2011 ), with an updated interim inspection checklist. Under those requirements, a Conditional Solution inspection is to consist of two components -a document review and a visual on-site inspection.

In accordance with these requirements, GE reviewed the most recent property records from the Pittsfield Tax Assessor's Office, as well as the deed records at the Berkshire Middle District Registry of Deeds. In addition, GE reviewed the description of the Conditional Solutions for these properties in the letters to the property owners and the relevant post-remediation topographic as-built survey drawings developed for the forthcoming Final Completion Report (FCR) for the Silver Lake Area Removal Action, which depict current site features and topography.

GE also conducted a visual site inspection of the portion of each of the above-listed properties that is subject to a Conditional Solution (as described in the letters to the property owners) to evaluate whether there was visual evidence that any of the following had occurred at that portion of the property since implementation of the Conditional Solutions:

Corp<Aote En,"ll:,,nmentol Program',


Page 2 of 3

• Any change in activities or uses that would be potentially inconsistent with the land use for which the Conditional Solution was implemented;

• Installation of a new utility or repair or replacement of an existing utility that involved disturbance of soil;

• Any excavations, construction, or other activities or conditions that resulted in the disturbance of 10 cubic yards of soil or greater, regardless of depth; and/or

• Any alteration of the surface grade of the property, compared to that shown on the as-built survey drawings, as a result of any of the activities noted in the two preceding bullets (with any such alteration to be identified on a plan).

The results of the November 2014 inspection were documented in a Conditional Solution Annual Inspection Checklist for each property (using an updated version of the interim checklist provided in the PRSC/RPMMP). Copies of the completed checklists are attached.· As documented in these forms, the property record reviews indicated that there had been no change in ownership of any of these properties since implementation of the Conditional Solutions in February 2014, although the records do show that the City of Pittsfield recorded an instrument of taking of Parcel 19-9-201 on June 26, 2014 (in Book 5397, Page 245) for non-payment of taxes (which constitutes a lien against the property subject to redemption by payment of the taxes). Further, the inspection showed no visual evidence that any of the above-listed activities or conditions had occurred at any of the portions of these properties subject to Conditional Solutions since implementation of the Conditional Solutions.

As required by the CD, these properties will continue to be inspected annually. Following GE's submittal and EPA's approval of the FCR for the Silver Lake Area Removal Action, those inspections will be conducted in accordance with the requirements specified in that FCR for Conditional Solution inspections, using the pertinent inspection checklist provided in the FCR. Following each such Conditional Solution inspection, an inspection report will be prepared and submitted to EPA and the Massachusetts Department of Environmental Protection (MDEP).

Please call me if you have any comments or questions.

Sincerely

d'~·~/for Richard W. Gates Senior Project Manager Global Operations - Environment, Health and Safety

Attachments

• Each of those checklists refers to an attached post-remediation topographic drawing. However, to avoid duplication, the two as-built topographic drawings that show all of the Conditional Solution properties subject to inspection, designated Drawings CX 1 07 and CX 106, are attached after all of the checklists.

G:\GE\GE_Silver_Lake\Reports and Presentations\2014~12 Cond Sol insp rpt\342141 J324LtrRptdoc

cc: Dean Tagliaferro, EPA Tim Conway, EPA* Chris Ferry, ASRC PrimusA Scott Campbell, Avatar (2 hard copies)/\ Robert Leitch, USACEA John Ziegler, MDEP (2 hard copies)A Eva Tor, MDEPA Nancy E. Harper, MA AG* Nate Joyner, Pittsfield Dept. of Community Development/\ Corydon Thurston, Executive Director, PEDAA Andrew Silfer, GE* Rod Mclaren, GE* Kevin Mooney, GEA Todd Cridge, ARCADJSA Mark Gravelding, ARCADJSA James Bieke, Sidley Austin LLP Property Owners - above-listed Parcels** GE Internal Repository

* ** A

cover letter only relevant attachment only electronic copy

G:\GE\GE_Silver_Lake\Reports and Presentations\2014~12 Cond Sol insp rpt\34214ll324LtrRpt.doc


Page 3 of 3

INTERIM CONDITIONAL SOLUTION ANNUAL INSPECTION CHECKLIST

SILVER LAKE AREA


Page 1 of 2

PARCELS: I9-9-21 & I9-9-22 DOCUMENT REVIEW


1. X Check here to confirm that the description of the Conditional Solution for this property in the letter from GE to the

property owner dated February 6, 2014 and the attached post-remediation topographic drawing of this property (which has been developed for the Final Completion Report for Silver Lake Area Removal Action and which GE proposes to use for the comparison described in Item 5 on next page) have been reviewed and are available on-site for review during the visual inspection.

2. X Check here to confirm that the most recent property records from the Pittsfield Tax Assessor’s Office and the

property deed at the Berkshire Middle District Registry of Deeds for this property have been reviewed. 3. Has there been any change in ownership of this property?

X No __ Yes – If yes, list the new owner’s name and mailing address below and indicate whether a notice of the Conditional

Solution has been or will be sent to the new owner.


Conducted By: Gregg Rabasco Representing: GE Inspection Start Date: November 18, 2014



2. Is there any visual evidence of changes in activities and uses of the portion of the property subject to the Conditional Solution since implementation of the Conditional Solution that are potentially inconsistent with the land use for which the Conditional Solution was implemented?



SILVER LAKE AREA


Page 2 of 2

3. Is there any visual evidence of installation of a new utility or repair or replacement of an existing utility that involved disturbance of soil within the portion of the property subject to the Conditional Solution since implementation of the Conditional Solution?


4. Is there any visual evidence of excavations, construction, or other activities or conditions that resulted in the disturbance of 10 cubic yards of soil or greater, regardless of depth, within the portion of the property subject to the Conditional Solution since implementation of the Conditional Solution?


5. If any of the conditions listed in the response to Questions 3 and 4 appears likely to have altered the surface grade of the portion of the property subject to the Conditional Solution, identify the approximate area/location(s) of such grade change on a plan and compare the new surface grade in such area(s) to the surface grade shown on the attached post-remediation topographic drawing (which has been developed for the Final Completion Report and which GE proposes to use for this comparison). 6. Inspection Completed: November 18, 2014


SILVER LAKE AREA


Page 1 of 2

PARCEL: I9-9-25 DOCUMENT REVIEW















SILVER LAKE AREA


Page 2 of 2







SILVER LAKE AREA


Page 1 of 2

PARCEL: I9-9-34 DOCUMENT REVIEW















SILVER LAKE AREA


Page 2 of 2







SILVER LAKE AREA


Page 1 of 2

PARCELS: I9-9-201 & I9-9-17 DOCUMENT REVIEW







Solution has been or will be sent to the new owner. Note: An Instrument of Taking executed by the City of Pittsfield on June 17, 2014 for Parcel I9-9-201 for non- payment of taxes was recorded in the Berkshire Middle District Registry of Deeds on June 26, 2014 in Book 5397, Page 245. This does not transfer ownership, but constitutes a lien against the property subject to redemption by payment of the taxes.








SILVER LAKE AREA


Page 2 of 2






FIREl PIT

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RESTORED SECTION OF v-JOOD FEJ'>Ie:E -----

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December 29, 2014 SL 2014 Monitoring of Cap Thickness and Integrity, Cap Isolation Layer, Deposition on Cap, and Sediment Collection Traps

December 29, 2014

Mr. Dave Dickerson Office of Site Remediation and Restoration U.S. Environmental Protection Agency, Region I 5 Post Office Square - Suite 100 Boston, MA 02109-3912


GE Corporate


2014 Monitoring of Cap Thickness and Integrity, Cap Isolation Layer, Deposition on Cap, and Sediment Collection Traps

Dear Mr. Dickerson:

Pursuant to the requirements set forth in the October 2000 Consent Decree (CD) for the GEPittsfield/Housatonic River Site (the Site) and the accompanying Statement of Work for Removal Actions Outside the River (SOW), the General Electric Company (GE) implemented a Removal Action at the Silver Lake Area Removal Action Area (RAA) between July 2012 and December 2013. The Removal Action implemented at the Silver Lake Area included removal of select sediments, installation of a sediment cap and associated shoreline armor layer, removal/replacement of soil in certain areas on the banks and adjacent areas, and restoration of the excavated areas, as well as restoration/enhancement of other areas around the lake. The CD and SOW also require various post-construction monitoring and maintenance activities for the completed Removal Action. These include monitoring of the sediment cap. The cap monitoring program consists of several elements: (a) monitoring to assess cap thickness and integrity; (b) sampling of the isolation layer to assess migration of polychlorinated biphenyls (PCBs), if any, from the underlying sediments; (c) evaluation of the isolation layer samples to evaluate PCB deposition on the surface of the cap; and (d) monitoring of sediment traps to evaluate sediment deposition on the surface of the cap. The cap monitoring activities for the first year after construction were performed in the fall of 2014. This letter summarizes those activities.

The Performance Standards and other requirements for post-construction monitoring and maintenance of the Silver Lake sediment cap were set forth in Attachment K to the SOW. Consistent with those requirements, GE submitted a Post-Removal Site Control Plan/Restoration Project Monitoring and Maintenance Plan (PRSCP/RPMMP) as Appendix I of its August 2011 Revised Final Removal Design/Removal Action Work Plan for Silver Lake Area, which was conditionally approved by the U.S. Environmental Protection Agency (EPA) by letter dated August 25, 2011. That plan included (in Section 2.1) a description of the Post-Removal Site Control activities for the cap system at the Silver Lake Area. 1

The PRSCP/RPMMP required GE, among other things, to perform periodic monitoring of the sediment cap, including monitoring of the cap thickness and integrity annually for the first five years after installation; monitoring of the cap isolation layer and PCB deposition on the cap surface during the first and fifth year after construction; and monitoring of the sediment traps annually for a two-year period after installation at the completion of construction.


CorpcrVJte Errllronmenta! Progmrnc-G \GE1GE_Silver_Lake\Reports and Presentations\20 14-12 Cap LetteJ'.2651411214_SL Cap Mon Rpt.docx

Dave Dickerson December 29, 2014

Page 2 of6

GE performed the 2014 cap inspections and collection of cap material cores on October 15-17 and 20, 2014, with a follow-up inspection using divers on November 10, 2014. These monitoring activities were performed on GE's behalf by Gregg Rabasco and Thomas O'Rourke of ARCADIS, and the monitoring events were also attended on EPA's behalf by Michael Argue of Weston Solutions, Inc. (October 15-17 and 20) or lzabela Zapisek of Avatar Environmental (November 10). On November 10, the inspection was supported by Seaway Diving, Inc. as the diving team. The analytical results for the cap material cores were received and validated in November 2014. EPA agreed that GE could submit a combined report on the various cap monitoring activities performed in the fall of 2014. This letter report summarizes the performance and associated results of the 2014 cap monitoring events. Figure 1 illustrates the sediment core collection and sediment trap installation locations discussed herein.

Description and Results of 2014 Monitoring Events

This section describes and presents the results of the fall 2014 monitoring event for each of the cap system features that were monitored; and, where warranted, it presents GE's plans for follow-up actions. Additional information is provided in attached figures, tables, and other attachments.

The fall 2014 post-construction monitoring program for the cap system consisted of: (a) monitoring to assess cap thickness and integrity; (b) sampling of the isolation layer to assess PCB migration, if any, from the underlying sediments; and (c) evaluation of the isolation layer samples to evaluate deposition on the surface of the cap. Specifically, the program included collection of cores at 21 locations, visual inspection by an underwater video camera and/or divers, and processing of 10 of the collected cores for PCB analysis. As discussed below, the sediment traps installed in the lake in December 2013 after cap construction could not be located.

The applicable Performance Standards for the Silver Lake cap monitoring and evaluation, as set forth in Section 2.6 and Attachment K of the SOW, are as follows:

• If the monitoring indicates that the design standards for the thickness of the capping system are not maintained, GE must evaluate and propose to EPA appropriate corrective actions to achieve those design standards, and must implement such corrective actions upon approval by EPA.

• If the sampling of the isolation layer indicates that that layer is not performing in general accordance with the predictions on which the design was based in terms of controlling PCB migration from the underlying sediments into the surface water of the lake, GE must evaluate corrective actions, submit the results of such evaluation to EPA for approval, and implement such corrective actions (if any) upon approval by EPA. If the monitoring indicates that the capping system is continuing to achieve the design standards and is performing as generally predicted in terms of controlling PCB migration from the underlying sediments into the surface water of the lake, then no further response actions will be necessary for the isolation layer, except as otherwise required pursuant to Section XIX (Emergency Response) or Paragraphs 162, 163, 167, and/or 168 (re-openers) of the CD.

• GE must evaluate, to the extent practicable, whether deposited PCBs detected on the surface of the cap (as opposed to migration of PCBs through the cap from the underlying sediments) are attributable to sources other than erosion or surface runoff from the banks or currently known discharges of PCBs into the lake from National Pollutant Discharge Elimination System [NPDES]permitted or other outfalls. If the surface PCBs can be attributed to such other sources and those sources are located within property owned by GE, GE must evaluate potential source control measures and submit a report on that evaluation to EPA for review and approval, along with a recommendation for any appropriate source control measures. Otherwise, no further response actions are required to address the deposition of PCBs on the surface of the cap, except for any activities required by Attachment K to the SOW to address erosion or otherwise required by Section XIX or Paragraphs 162, 163, 167, and/or 168 of the CD.

The following sections describe the sediment monitoring activities conducted in the fall of 2014 and the evaluations performed to meet these Performance Standards.

G 1GE GE_ Sllver~ .. Lakc,Reports and Presentations 2014-12 Cap Letter\265 14 I 1214~SL Cap Mon Rpt docx

Monitoring to assess cap thickness and integrity


Page 3 of 6

On October 15 and 17, 2014, cap material cores were collected from 21 locations in Silver Lake (shown on Figure 1 ); and these cores were processed on October 16 and 20, 2014 in order to assess the inplace cap thickness. At each location, a representative core was collected by physically pushing a Lexan tube to the apparent bottom of the cap and just into the native sediment, and then brought to the surface.

To avoid specific locations that may have been previously sampled, each of the target locations for cap core collection during this first post-construction monitoring event was set approximately 5 feet away and in the north direction from the locations of the cores collected during construction (as determined by a Geographic Information System [GIS]). Once the cores were recovered and brought to the surface, the thickness of the cap material in each core was measured. Thickness of cap material in the corecollection tube was measured as the distance from the interface between the cap and underlying sediment to the approximate top of the cap material. Core collection locations are illustrated on Figure 1. Table 1 summarizes the cap thicknesses observed at each location.

During the sample collection event in October, a visual inspection of the surface of the cap in the vicinity of core collection locations was attempted using an underwater video camera. However, imagery captured by the underwater camera provided only limited information. As a result, divers were utilized on November 10 to perform a visual inspection of the surface of the cap in the vicinity of the core collection locations and to collect additional video to supplement the footage collected in October. A copy of the underwater video footage collected by the divers is provided on a digital video disc in Attachment A, and a summary of the observations is presented in Table 2.

The results of the cap thickness and integrity monitoring indicate that the design standards for the cap thickness and integrity have generally been maintained. The divers did not observe any signs of cap failure or compromise, and the surface of the cap appears to be of a consistent nature, without significant signs of depressions and/or holes. As shown in Table 1, with the exception of one location, the thickness measurements associated with the collected cores indicate that the cap thickness meets or exceeds the design thickness Performance Standard of 14 inches in areas outside the shoreline armor system. At location SL-CAP-01, the measured thickness of contiguous cap material was observed to be 12 inches (although some cap material was also observed in that core at a depth of 15 to 20 inches).

Based on these results, GE proposes to add at least two inches of additional cap material across approximately 100 feet of shoreline at location SL-CAP-01. Specifically, at least two inches of such material will be added in an area around that location that is anticipated to extend from the edge of the armor stone to approximately 50 feet into the lake and approximately 50 feet in each direction along the shoreline, as shown on Figure 1. This will entail the placement of a minimum of approximately 30 cubic yards of additional cap material. The proposed means and methods of placement of that additional cap material will be presented in a separate proposal to EPA Depending on the selected method of placement, the anticipated horizontal extent of additional cap placement may be modified. Any such proposed modification will be presented in the separate proposal.

Isolation layer monitoring to assess PCB migration through cap

During this first-year post-construction monitoring event, ten of the cap material cores collected for assessing cap thickness were also subject to PCB analysis. The ten locations selected for PCB analysis are illustrated on Figure 1. Cores from these locations were sectioned into three intervals, as measured relative to the interface between the cap material and the underlying sediment layer. These three intervals were the approximate two-inch mixing zone at the bottom of the core, the top one inch of the core (TOP layer), and the remaining portion of the core between those increments (REM layer). Processed samples from the mixing zone, REM, and TOP intervals of each core location were analyzed for PCBs. The protocol for core processing that was used during the 2014 event is summarized in Attachment B (and is expected to be used for processing cores during subsequent cap isolation layer

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monitoring events). The results of the analytical testing from these sampled intervals are presented in Table 3, along with the PCB results from the samples collected immediately after construction (in September-October 2013) at the same locations, to allow for a comparison to baseline chemical characteristics of the isolation layer and to help assess the extent of any PCB migration through the cap. The data validation report for the PCB results is provided in Attachment C, which concludes that 100% of the data are usable.

Since there have been only two rounds of sampling of the final cap material, conducted approximately a year apart collected, it is too early to perform a meaningful assessment of the performance of the cap over time. Nevertheless, the remainder of this section provides an assessment, to the extent practicable, of the performance of the cap and observations of potential changes in cap conditions.

As indicated in Table 3, the PCB results from the mixing zone interval ranged from not detected to 4.34 parts per million (ppm)., the results from the REM interval ranged from not detected to 0.05 ppm, and the results from the TOP interval range from not detected to 1.22 ppm. The average of the mixing zone interval results is 0.82 ppm, the average of the REM interval results is 0.04 ppm, and the average of the TOP interval results is 0.32 ppm. 2

PCB concentrations in the mixing layer samples decreased, on average, since the completion of cap installation, from an average of 6.84 ppm in 2013, with a maximum of 51.7 ppm at location SL-CAP-01, to an average of 0.82 ppm in 2014 with a maximum of 4.34 ppm at that same location. Nine of the ten locations sampled in 2014 had lower PCB concentrations than were observed in 2013. It is expected that there may be some variability in the mixing layer concentrations as it relies on a qualitative determination by the core processor of the location of the sediment/cap interface. Any trend cannot be discerned with only two data points.

Overall, the PCB concentrations in the cap material REM interval were lower in the recent samples than in the corresponding samples collected immediately after placement, indicating that migration of PCBs into the cap material has not occurred. PCBs were detected in fewer REM samples collected in 2014 (3, compared to 4 post-placement), with an average concentration of 0.04 ppm, compared to the average of 0.17 ppm associated with samples collected immediately after construction. Of the three REM samples with detectable PCBs in 2014, two (SL-CAP01-YR1 and SL-CAP12-YR1) had PCB concentrations more than an order of magnitude lower than those from one year before, and the third (SL-CAP08-YR 1) had an estimated PCB concentration (0.05 ppm) lower than the reporting limit in the corresponding postconstruction sample (0.069 ppm). In those three REM samples with detectable PCBs, the average PCB concentration decreased from 0.47 ppm to 0.04 ppm, indicating no gain of PCBs within the cap that would be expected if PCB migration were occurring.

PCB concentrations in the surface layer samples (TOP interval) incre ased, on average, since the completion of cap installation, from an average of 0.03 ppm in 2013 to an average of 0.32 ppm in 2014. However, the data suggest that those increases were likely due to deposition from an outside source (discussed further in the next section), not migration from the underlying sediments. Seven of the locations sampled in 2014 had higher surface sediment PCB concentrations than in 2013 or had detectable PCB concentrations where they were previously not detected. At four of those locations, PCBs were not detected in the underlying REM interval; and at the other three locations, the PCB concentrations in the REM interval (all estimated) were considerably lower than those in the TOP interval. Together, these data show no PCB concentration gradient that would suggest the migration of PCBs through the isolation layer of the cap.

Overall, the results presented in Table 3 provide no indication that the isolation layer is failing to perform in accordance with the predictions on which the cap design was based in terms of effectively limiting the migration of PCBs from the underlying sediments through that layer into the surface water of the lake.

2 To determine the average concentration, half of the reporting limit was assumed for non-detect results.

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However, it is clearly too early to draw any firm conclusions about the effectiveness of the isolation layer over time. In these circumstances, no response actions for the isolation layer are necessary at this time.

Evaluation of deposition on cap surface

The PCB analytical results from the above-referenced samples collected during the first-year monitoring event were also reviewed to assess the presence and extent of PCB deposition on the surface of the cap, as opposed to the migration of PCBs through the cap from the underlying sediments. The analytical results from the samples collected from the TOP interval indicate the presence of some PCBs on the surface of the cap that are likely a result of deposition. However, there does not appear to be an identifiable potential source or sources of those PCBs, and there is no apparent pattern or relationship between the detections and particular types of locations. For instance, of the seven locations with 2014 PCB detections in the surface, the location with the highest detection (1.22 ppm at SL-CAP-14-YR1) is located at a mid-lake location in deep water in the eastern part of the lake, the location with the next highest concentration (0.57 ppm at SL-CAP-16-YR1) is located immediately adjacent to a private parcel on the southern shore of the lake in a shallow-water steep-sloped area, and the location with the third highest concentration (estimated at 0.41 ppm at SL-CAP-04-YR 1) in the located in deep water in the western part of the lake.

In any case, the PCBs on the surface of the cap cannot be attributed to any identifiable sources other than erosion or surface runoff from the banks or currently known discharges of PCBs into the lake from the NPDES-permitted outfall or other outfalls. Since the surface PCBs cannot be attributed to such other sources, no source control measures are proposed, and no further response actions are necessary to address the deposition of PCBs on the surface of the cap.

Sediment traps

In addition to the above-described monitoring of the sediment cap, GE attempted to retrieve the sediment traps that were installed at five locations in the lake on December 2 and 3, 2013, after cap construction was complete. Those traps were installed to further assess potential sedimentation in Silver Lake. However, the sediment traps were not located during the core sampling and underwater video recording performed in October 2014 or during the November 2014 diver-assisted visual observations. It is not clear whether the traps were removed by outside parties, but GE was not able to locate them.

As a result, GE has rebuilt and reinstalled sediment traps at the same five target locations shown on Figure 1. The new sediment traps were built and installed in a similar fashion to those constructed in 2013, except that this time a subsurface buoy was utilized at each location to help keep the brightly colored lifting rope vertical for easier identification and future retrieval. Divers were utilized to install the traps, and the buoys are not accessible from the water surface. Traps were installed at locations 1 and 2 on December 18, 2014, and at the remainder of the locations on December 19, 2014. Having reinstalled the sediment traps, GE will restart the annual monitoring program for the sediment traps and extend that program for an additional year, with retrieval of the newly installed traps in 2015 and 2016. During each such event, the thickness of the sediment that settles in the traps will be measured; no analytical work will be conducted on that material.

Future Activities

GE will develop a proposal for the means and methods for the placement of supplemental cap material at location SL-CAP-01, and will submit it to EPA for review and approval within 30 days of receipt of EPA's approval of this letter.

The fall 2014 monitoring activities fulfilled the requirements outlined in the PRSCP/RPMMP for the first post-construction monitoring events for the cap thickness/integrity, the cap isolation layer, and PCB deposition on the cap surface. GE will continue with those monitoring activities on the schedule specified in that plan, as described above, unless and until replaced by the Post-Removal Site Control

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requirements specified in the Final Completion Report for the Silver Lake Area Removal Action. Further, as noted above, the sediment collection traps to be installed in 2014 will be monitored for two years (in 2015 and 2016).

The next scheduled inspection of the cap thickness/integrity and sediment collection traps will occur in summer 2015 (likely in August), and the next scheduled monitoring event for the cap isolation layer and PCB deposition on the cap surface will occur in the fifth year after construction (i.e., in 2018). Reports will be submitted on all of these monitoring events.


Sincerely,

cl~ {7~/foc Richard W. Gates Senior Project Manager Global Operations - Environment, Health and Safety

Attachments

cc: Dean Tagliaferro, EPA Tim Conway, EPA* Chris Ferry, ASRC Primus** Scott Campbell, Avatar (2 hard copies)** Robert Leitch, USAGE** Michael Gorski, MDEP** John Ziegler, MDEP (2 hard copies)** Eva Tor, MDEP** Karen Pelto, MDEP** Nancy E. Harper, MA AG* Nate Joyner, Pittsfield Dept. of Community

Development** James McGrath, Pittsfield Dept. of Parks

and Recreation**


* without attachments ** electronic copy

G IGE\GE_Siher _ Lake.Reports and Presentations.2014-12 Cap Lettel 2651411214_SL Cap Mon Rptdocx

Tables

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Approximate Water Depth

Approximate Cap Thickness

(ft) (inches) TOP 1

SL-CAP-01-YR1 2 10/16/2014 8.9 12 0 - 1 1 - 10 10 - 12SL-CAP-02-YR1 10/20/2014 17.4 16.5SL-CAP-03-YR1 10/20/2014 9.1 15SL-CAP-04-YR1 10/16/2014 20 16 0 - 1 1 - 14 14 - 16SL-CAP-05-YR1 10/20/2014 18.2 15SL-CAP-06-YR1 10/17/2014 6.6 20 0 - 1 1 - 18 18 - 20SL-CAP-07-YR1 10/20/2014 11.6 14.5SL-CAP-08-YR1 10/17/2014 19.4 16 0 - 1 1 - 14 14 - 16SL-CAP-09-YR1 10/20/2014 24.1 17.5SL-CAP-10-YR1 10/17/2014 19.5 15 0 - 1 1 - 13 13 - 15SL-CAP-11-YR1 10/20/2014 6.6 14.5SL-CAP-12-YR1 10/17/2014 7.2 18.5 0 - 1 1 - 16.5 16.5 - 18.5SL-CAP-13-YR1 10/20/2014 24.4 18.5SL-CAP-14-YR1 10/17/2014 26.2 27 0 - 1 1 - 25 25 - 27SL-CAP-15-YR1 10/20/2014 24.6 19SL-CAP-16-YR1 10/17/2014 13.5 17 0 - 1 1 - 15 15 - 17SL-CAP-17-YR1 10/20/2014 4.8 14.5SL-CAP-18-YR1 10/20/2014 21.1 20SL-CAP-19-YR1 10/17/2014 7.0 15 0 - 1 1 - 13 13 - 15SL-CAP-20-YR1 10/17/2014 23 16 0 - 1 1 - 14 14 - 16SL-CAP-21-YR1 10/20/2014 9.8 21.5

TABLE 1THICKNESS DATA FOR YEAR 1 (2014) POST-CONSTRUCTION SAMPLING AND IMMEDIATE POST-CONSTRUCTION SAMPLING

SILVER LAKEGENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS

NA

NA

NA

Core ID

Sample/Measurement

Date

Sample Intervals (inches)

REM Mixing

Notes: 1. The TOP interval represents the top inch of material collected, including approximately 0.0'' to 0.5'' of deposited material, depending on the location.2. For SL-CAP-01-YR1, cap material was observed from 0-12'' and then again from 15-20'' (17'' total of cap material observed), with native material observed in between from 12-15''.3. Cores were collected by ARCADIS on and samples were processed by ARCADIS. Locations targeted for core collection were located approximately five feet north of the original during-construction core location or five feet north of the furthest-north during-construction coring location, whichever was further north, to reduce the potential for collecting a core from a previously-sampled location. 4. TOP, REM, and Mixing sample intervals were submitted to Pace Analytical Services for analysis of PCBs.

NA

NA

NA

NA

NA

NA

NA

NA

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Video Title Location Comments1 SL-CAP-01 soft material on top, vegetation2 SL-CAP-02 top 2'' soft material, harder below, no vegetation3 NA Sevenson's during-construction sediment trap4 SL-CAP-03 top 1-2'' soft material, harder below, no vegetation5 SL-CAP-04 top 2'' soft material, harder below, little marine growth6 SL-CAP-06 top 2'' soft material, harder below, vegetation7 SL-CAP-05 top 3-4'' soft material, harder below, no vegetation8 SL-CAP-11 top 2'' soft material, harder below, no vegetation9 SL-CAP-10 top 2'' soft material, harder below, no vegetation10 NA searching for Sediment Trap 311 SL-CAP-09 top 2-3'' soft material, harder below, no vegetation12 SL-CAP-07 top 1'' soft material, harder below, minimal vegetation more predominant up the slope13 SL-CAP-08 top 3'' soft material, harder below, no vegetation14 SL-CAP-12 top 1'' soft material, harder below, minimal vegetation more predominant towards shore15 SL-CAP-13 top 3'' soft material, harder below, no vegetation16 SL-CAP-14 top 6-7'' soft material, hard below, plant life minimal to non-existent17 SL-CAP-15 top 4'' soft material, harder below, no vegetation18 SL-CAP-16 top 2'' soft material, harder below, no vegetation19 SL-CAP-21 top 2'' soft material, harder below, no vegetation20 SL-CAP-20 top 6'' soft material, harder below, no vegetation21 SL-CAP-19 top 1'' soft material, harder below, no vegetation22 SL-CAP-18 top 3'' soft material, harder below, no vegetation23 SL-CAP-17 top 2'' soft material, harder below, no vegetation


TABLE 2SUMMARY OF DIVER-ASSISTED VIDEO OBSERVATIONS FROM POST-CONSTRUCTION MONITORING

SILVER LAKE

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Depth Date Aroclor-1016,Year 1

Post-ConstructionImmediate Post-

ConstructionSample ID (Inches) Interval Collected -1232, -1242 Aroclor-1221 Aroclor-1248 Aroclor-1254 Aroclor-1260 Total PCBs Total PCBs

SL-CAP-01-YR1 0-1 TOP 10/16/2014 ND(0.063) 0.20 J ND(0.063) ND(0.063) 0.053 J 0.253 J ND(0.059)1-10 REM 10/16/2014 ND(0.062) 0.044 J ND(0.062) ND(0.062) ND(0.062) 0.044 J 0.64

10-12 Mixing 10/16/2014 ND(0.062) 1.7 J 1.2 J 0.63 0.81 4.34 J 51.8SL-CAP-04-YR1 0-1 TOP 10/16/2014 ND(0.11) ND(0.11) 0.18 J 0.11 J 0.12 0.41 J ND(0.066)

1-14 REM 10/16/2014 ND(0.075) ND(0.075) ND(0.075) ND(0.075) ND(0.075) ND(0.075) ND(0.069)14-16 Mixing 10/16/2014 ND(0.072) 0.14 J 0.082 J ND(0.072) 0.047 J 0.269 J 0.294

SL-CAP-06-YR1 0-1 TOP 10/17/2014 ND(0.077) ND(0.077) ND(0.077) ND(0.077) ND(0.077) ND(0.077) 0.050 J1-18 REM 10/17/2014 ND(0.066) ND(0.066) ND(0.066) ND(0.066) ND(0.066) ND(0.066) 0.081

18-20 Mixing 10/17/2014 ND(0.068) J 0.38 J 0.20 J 0.063 J 0.11 J 0.753 J 3.93SL-CAP-08-YR1 0-1 TOP 10/17/2014 ND(0.10) ND(0.10) 0.17 J 0.10 J 0.095 J 0.365 J ND(0.063)

1-14 REM 10/17/2014 ND(0.070) ND(0.070) ND(0.070) 0.050 J ND(0.070) 0.050 J ND(0.069)14-16 Mixing 10/17/2014 ND(0.076) 0.18 J 0.16 J 0.059 J 0.054 J 0.453 J 0.154


13-15 Mixing 10/17/2014 ND(0.070) 0.061 J ND(0.070) ND(0.070) ND(0.070) 0.061 J 0.314SL-CAP-12-YR1 0-1 TOP 10/17/2014 ND(0.065) ND(0.065) 0.042 J 0.040 J ND(0.065) 0.082 J ND(0.058)

1-16.5 REM 10/17/2014 ND(0.061) ND(0.061) 0.047 J ND(0.061) ND(0.061) 0.047 J 0.73416.5-18.5 Mixing 10/17/2014 ND(0.068) 0.42 J 0.086 0.047 J ND(0.068) 0.553 J 2.06

SL-CAP-14-YR1 0-1 TOP 10/17/2014 ND(0.14) ND(0.14) 0.49 0.34 0.39 1.22 0.041 J1-25 REM 10/17/2014 ND(0.094) ND(0.094) ND(0.094) ND(0.094) ND(0.094) ND(0.094) 0.043 J

25-27 Mixing 10/17/2014 ND(0.065) J ND(0.065) J 0.099 0.084 ND(0.065) J 0.183 J 1.1SL-CAP-16-YR1 0-1 TOP 10/17/2014 ND(0.086) ND(0.086) 0.25 0.16 0.16 0.57 ND(0.064)

1-15 REM 10/17/2014 ND(0.062) ND(0.062) ND(0.062) ND(0.062) ND(0.062) ND(0.062) ND(0.061)15-17 Mixing 10/17/2014 ND(0.060) J ND(0.060) J 0.084 0.041 J 0.044 J 0.169 J 6.39


13-15 Mixing 10/17/2014 ND(0.063) 0.091 J 0.58 0.5 0.26 1.43 J 1.63SL-CAP-20-YR1 0-1 TOP 10/17/2014 ND(0.083) ND(0.083) 0.080 J 0.055 J ND(0.083) 0.135 J 0.025 J

1-14 REM 10/17/2014 ND(0.074) ND(0.074) ND(0.074) ND(0.074) ND(0.074) ND(0.074) ND(0.067)14-16 Mixing 10/17/2014 ND(0.069) J ND(0.069) J ND(0.069) J ND(0.069) J ND(0.069) J ND(0.069) J 0.747

Notes:

GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS(Results are presented in dry weight parts per million)

TABLE 3PCB DATA FOR YEAR 1 (2014) POST-CONSTRUCTION SAMPLING AND IMMEDIATE POST-CONSTRUCTION RESULTS

SILVER LAKE

1. Samples were collected by ARCADIS and submitted to Pace Analytical Services Inc. for analysis of PCBs. 2. Year 1 samples have been validated as per Field Sampling Plan/Quality Assurance Project Plan (FSP/QAPP), General Electric Company, Pittsfield, Massachusetts, ARCADIS (revised on July 2 , 2013 and approved by EPA on July 23, 2013). 3. ND - Analyte was not detected. The number in parentheses is the associated reporting limit. Data Qualifiers: J - Indicates that the associated numerical value is an estimated concentration.

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Attachment A

(on DVD)

Attachment B

Attachment B Revised Core Processing Protocol for Post-construction Monitoring Events at the Silver Lake Area General Electric Company Pittsfield, Massachusetts • Step 1: Stand the cores vertically and allow time to settle.

• Step 2: Drill a hole just above the cap/water interface to drain off water. • Step 3: Cut Lexan tube slightly above the top of settled granular material (i.e., cap material or

deposited sediment material). Carefully remove any flakes or cuttings that may have fallen into the core.

• Step 4: Using a dedicated tool (e.g., a tongue depressor with a squared-off end, or similar) remove

the first inch (TOP) of cap material for PCB analysis. • Step 5: Place a cap on the top of the Lexan tube, lay the core horizontally and cut the tube length-

wise on opposite sides of the cylinder, and remove the top half of the core cylinder, and identify the native/cap interface.

• Step 6: Remove the contaminated native sediment for disposal.

• Step 7: Using a dedicated tool (e.g., a tongue depressor with a squared-off end, or similar) remove the bottom two inches (mixing zone) of material for PCB analysis.

• Step 8: Using a dedicated tool (e.g., a tongue depressor with a squared-off end, or similar) remove the remaining material (REM), being careful not to let the REM material come into contact with any residual contaminated native sediment that may be present on the inside wall of the cylinder for PCB analysis.

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Attachment C

Attachment C Silver Lake Year 1 (2014) Cap Sampling Data Validation Report General Electric Company Pittsfield, Massachusetts

1.0 General

This attachment summarizes the data validation review performed on behalf of the General Electric Company (GE) for samples collected from the Silver Lake cap in October 2014 as part of Year 1 Post-construction cap system monitoring activities performed at Silver Lake, located at the GE-Pittsfield/Housatonic River Site in Pittsfield, Massachusetts (the Site). The samples were analyzed for polychlorinated biphenyls (PCBs) by Pace Analytical of Schenectady, New York. Data validation was performed for 30 PCB samples.

2.0 Data Evaluation Procedures

This attachment outlines the applicable quality control criteria utilized during the data review process and any deviations from those criteria. The data review was conducted in accordance with the following documents:

• Field Sampling Plan/Quality Assurance Project Plan (FSP/QAPP), General Electric Company, Pittsfield, Massachusetts, ARCADIS (Revision 5 submitted by GE on July 2, 2013 and approved by EPA on July 23, 2013); and

• EPA Region I, EPA-New England Data Validation Functional Guidelines for Evaluating Environmental Analyses (July 1996, revised December 1996) (EPA Region I Guidelines).

The data were validated to Tier I and Tier II levels, as described below. Any deviations from the applicable quality control criteria utilized during the data review process are identified below. A tabulated summary of the Tier I/Tier II data review is presented in Table C-1. Each sample subject to evaluation is listed in Table C-1 to document that data review was performed. Samples that required data qualification are listed separately.

The following data qualifiers were used in this data evaluation:

J The compound was positively identified, but the associated numerical value is an estimated concentration. This qualifier is used when the data evaluation procedure identifies a deficiency in the data generation process. This qualifier is also used when a compound is detected at an estimated concentration less than the corresponding practical quantitation limit (PQL).

ND(PQL) The compound was analyzed for, but was not detected at the method detection limit. The sample PQL is presented in parentheses. Non-detect sample results are presented as ND(PQL) in this report for consistency with documents previously prepared for investigations conducted at the GE-Pittsfield/Housatonic River Site. 1

1 This project specific nomenclature differs from that in EPA guidance, which uses the qualifier U for non-detected compounds.

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ND(PQL) J The compound was not detected above the reported sample PQL, but the sample PQL is estimated and may or may not represent the actual level of quantitation. Non-detect sample results that required this qualification are presented as ND(PQL) J in this report for consistency with documents previously prepared for investigations conducted at the GE-Pittsfield/Housatonic River Site. 2

R Indicates that the previously reported detection limit or sample result has been rejected due to a major deficiency in the data generation procedure. The data should not be used for any qualitative or quantitative purpose.

3.0 Data Validation Procedures

Section 7.5 of the revised FSP/QAPP states that all analytical data will be validated to a Tier I level following the procedures presented in the EPA Region I Guidelines. The Tier I review consisted of a completeness evidence audit, as outlined in the EPA Region I CSF Completeness Evidence Audit Program (EPA Region I, July 31, 1991), to ensure that laboratory data and documentation were present. In the event that data packages were determined to be incomplete, the missing information was requested from the laboratory. Upon completion of the Tier I review, the data packages complied with the EPA Region I Tier I data completeness requirements.

All analytical results from the cap sampling activities described above were also subjected to a Tier II data review. The Tier II data review consisted of a review of data package summary forms for identification of quality assurance/quality control (QA/QC) deviations and qualification of the data according to the EPA Region I Guidelines. Additionally, field duplicates were examined for relative percent difference (RPD) compliance with the criteria specified in the FSP/QAPP. A tabulated summary of the samples subject to Tier I and Tier II data review is presented in the following table.

Summary of Samples Subjected to Tier I and Tier II Data Validation

Parameter Tier I Only Tier I &Tier II

Total Samples Duplicates Blanks Samples Duplicates Blanks

PCBs 0 0 0 30 0 0 30

Total 0 0 0 30 0 0 30

When qualification of the sample data was required, the sample results associated with a QA/QC parameter deviation were qualified in accordance with the procedures outlined in EPA Region I data validation guidance documents. When the data validation process identified several quality control deficiencies, the cumulative effect of the various deficiencies was employed in assigning the final data qualifier. A summary of the QA/QC parameter deviations that resulted in data qualification is presented in Section 4 below.

2 This project specific nomenclature differs from that in EPA guidance, which uses the qualifier UJ for non-detected compounds in this category.


4.0 Summary of QA/QC Parameter Deviations Requiring Data Qualification

This section provides a summary of the deviations from the applicable QA/QC criteria that resulted in qualification of results.

Aroclor identification criteria require that the Aroclor pattern resemble that of the pattern established throughout the analysis of the standards of the target Aroclors. Sample data that did not match Aroclor patterns that were established through the analysis of target Aroclor standards were tentatively identified and qualified as estimated (J). The PCB compounds that did not meet Aroclor identification criteria and the number of samples qualified due to those deviations are presented in the following table.

Compounds Qualified Due to Identification Deviations

Analysis Compounds Number of

Affected Samples Qualification

PCBs Aroclor-1221 13 J Aroclor-1248 10 J Total PCBs 11 J

Surrogate compounds are analyzed with every organic sample to aid in evaluation of the sample extraction efficiency. As specified in the FSP/QAPP, both of the PCB surrogate compounds must have a recovery within laboratory-specified control limits. Sample results less than control limits and greater than 10% were qualified as estimated (J or ND(PQL) J). A summary of the compounds affected by surrogate recovery exceedances and the number of samples qualified due to those deviations are presented in the following table.

Compounds Qualified Due to Surrogate Recovery Deviations

Analysis Compound Number of Affected Samples Qualification

PCBs Aroclor-1016 4 ND(PQL) J

Aroclor-1221 3 ND(PQL) J 1 J

Aroclor-1232 4 ND(PQL) J Aroclor-1242 4 ND(PQL) J

Aroclor-1248 3 J 1 ND(PQL) J



Total PCBs 3 J 1 ND(PQL) J

5.0 Overall Data Usability

This section summarizes the analytical data in terms of its completeness and usability. Data completeness is defined as the percentage of sample results that have been determined to be usable during the data validation process. The percent usability calculation included analyses evaluated under both the Tier I/II data validation reviews. Data usability is summarized in the following table.


Data Usability

Parameter Percent Usability Rejected Data

PCBs 100 None

The data package completeness, as determined from the Tier I data review, was used in combination with the data quality deviations identified during the Tier II data review to determine overall data quality. As specified in the FSP/QAPP, the overall precision, accuracy, representativeness, comparability, and completeness (PARCC) parameters determined from the Tier I and Tier II data reviews were used as indicators of overall data quality. These parameters were assessed through an evaluation of the results of the field and laboratory QA/QC sample analyses to provide a measure of compliance of the analytical data with the Data Quality Objectives (DQOs) specified in the FSP/QAPP. Therefore, the following sections present summaries of the PARCC parameters assessment with regard to the DQOs specified in the FSP/QAPP.

5.1 Precision

Precision measures the reproducibility of measurements under a given set of conditions. Specifically, it is a quantitative measure of the variability of a group of measurements compared to their average value. For this investigation, precision was defined as the RPD between duplicate sample results. The duplicate samples used to evaluate precision included MS/MSD samples and LCS/LCSD samples. None of the data required qualification due to MS/MSD RPD deviations or LCS/LCSD sample RPD deviations.

5.2 Accuracy

Accuracy measures the bias in an analytical system or the degree of agreement of a measurement with a known reference value. For this investigation, accuracy was defined as the percent recovery of QA/QC samples that were spiked with a known concentration of an analyte or compound of interest. The QA/QC samples used to evaluate analytical accuracy included instrument calibration, LCS/LCSD samples, MS/MSD samples, and surrogate compound recoveries. For this analytical program 13.3% of the data required qualification due to surrogate compound recovery deviations. None of the data required qualification due to instrument calibration deviations, LCS/LCSD recovery deviations, or MS/MSD recovery deviations.

5.3 Representativeness

Representativeness expresses the degree to which sample data accurately and precisely represents a characteristic of a population, parameter variations at a sampling point, or an environmental condition. Representativeness is a qualitative parameter, which is most concerned with the proper design of the sampling program. The representativeness criterion is best satisfied by making certain that sampling locations are selected properly and a sufficient number of samples are collected. This parameter has been addressed by collecting samples at locations specified in the EPA-approved work plans, and by following the procedures for sample collection/analyses that were described in the FSP/QAPP. Additionally, the analytical program used procedures consistent with EPA-approved analytical methodology. A QA/QC parameter that is an indicator of the representativeness of a sample is holding time. Holding time criteria are established to maintain the samples in a state that is representative of the in-situ field conditions before analysis. For this analytical data set, none of the data required qualification due to holding time deviations.


5.4 Comparability

Comparability is a qualitative parameter expressing the confidence with which one data set can be compared with another. This goal was achieved through the use of the standardized techniques for sample collection and analysis presented in the FSP/QAPP. Specifically, all of the samples collected in October 2014 were analyzed by EPA SW-846 Method 8082 for PCBs.

5.5 Completeness

Completeness is defined as the percentage of measurements that are judged to be valid or usable to meet the prescribed DQOs. The completeness criterion is essentially the same for all data uses -- the generation of a sufficient amount of valid data. The actual completeness of this analytical data set was 100%.


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Sample Delivery Group No. Sample ID Date Collected Matrix

Validation Level Qualification Compound QA/QC Parameter Value Control Limits Qualified Result Notes

PCBs14100621_Rev00 SL-CAP-01-YR1 (0 - 1) 10/16/2014 Soil Tier II Yes Aroclor-1221 Aroclor 1221 tentatively identified - - 0.20 J

Total PCBs Aroclor 1221 tentatively identified - - 0.253 J14100621_Rev00 SL-CAP-01-YR1 (1 - 10) 10/16/2014 Soil Tier II Yes Aroclor-1221 Aroclor 1221 tentatively identified - - 0.044 J

Total PCBs Aroclor 1221 tentatively identified - - 0.044 J 14100621_Rev00 SL-CAP-01-YR1 (10 - 12) 10/16/2014 Soil Tier II Yes Aroclor-1221 Aroclor 1221 tentatively identified - - 1.7 J

Aroclor-1248 Aroclor 1248 tentatively identified - - 1.2 JTotal PCBs Aroclor 1221, 1248 tentatively identified - - 4.34 J

14100621_Rev00 SL-CAP-04-YR1 (0 - 1) 10/16/2014 Soil Tier II Yes Aroclor-1248 Aroclor 1248 tentatively identified - - 0.18 JTotal PCBs Aroclor 1248 tentatively identified - - 0.41 J

14100621_Rev00 SL-CAP-04-YR1 (1 - 14) 10/16/2014 Soil Tier II No14100621_Rev00 SL-CAP-04-YR1 (14 - 16) 10/16/2014 Soil Tier II Yes Aroclor-1221 Aroclor 1221 tentatively identified - - 0.14 J


14100621_Rev00 SL-CAP-06-YR1 (0 - 1) 10/17/2014 Soil Tier II No14100621_Rev00 SL-CAP-06-YR1 (1 - 18) 10/17/2014 Soil Tier II No14100621_Rev00 SL-CAP-06-YR1 (18 - 20) 10/17/2014 Soil Tier II Yes Aroclor-1016 Surrogate Recovery-TCMX 40.1% 60% to 140% ND(0.068) J

Aroclor-1221 Surrogate Recovery-TCMX 40.1% 60% to 140% 0.38 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.38 JAroclor-1232 Surrogate Recovery-TCMX 40.1% 60% to 140% ND(0.068) JAroclor-1242 Surrogate Recovery-TCMX 40.1% 60% to 140% ND(0.068) JAroclor-1248 Surrogate Recovery-TCMX 40.1% 60% to 140% 0.20 JAroclor-1248 Aroclor 1248 tentatively identified - - 0.20 JAroclor-1254 Surrogate Recovery-TCMX 40.1% 60% to 140% 0.063 JAroclor-1260 Surrogate Recovery-TCMX 40.1% 60% to 140% 0.11 JTotal PCBs Surrogate Recovery-TCMX 40.1% 60% to 140% 0.753 JTotal PCBs Aroclor 1221, 1248 tentatively identified - - 0.753 J

14100621_Rev00 SL-CAP-08-YR1 (0 - 1) 10/17/2014 Soil Tier II Yes Aroclor-1248 Aroclor 1248 tentatively identified - - 0.17 JTotal PCBs Aroclor 1248 tentatively identified - - 0.365 J

14100621_Rev00 SL-CAP-08-YR1 (1 - 14) 10/17/2014 Soil Tier II No14100621_Rev00 SL-CAP-08-YR1 (14 - 16) 10/17/2014 Soil Tier II Yes Aroclor-1221 Aroclor 1221 tentatively identified - - 0.18 J


14100622_Rev00 SL-CAP-10-YR1 (0 - 1) 10/17/2014 Soil Tier II No14100622_Rev00 SL-CAP-10-YR1 (1 - 13) 10/17/2014 Soil Tier II No14100622_Rev00 SL-CAP-10-YR1 (13 - 15) 10/17/2014 Soil Tier II Yes Aroclor-1221 Aroclor 1221 tentatively identified - - 0.061 J

Total PCBs Aroclor 1221 tentatively identified - - 0.061 J 14100622_Rev00 SL-CAP-12-YR1 (0 - 1) 10/17/2014 Soil Tier II No14100622_Rev00 SL-CAP-12-YR1 (1 - 16.5) 10/17/2014 Soil Tier II No14100622_Rev00 SL-CAP-12-YR1 (16.5 - 18.5) 10/17/2014 Soil Tier II Yes Aroclor-1221 Aroclor 1221 tentatively identified - - 0.42 J

Total PCBs Aroclor 1221 tentatively identified - - 0.553 J14100622_Rev00 SL-CAP-14-YR1 (0 - 1) 10/17/2014 Soil Tier II No14100622_Rev00 SL-CAP-14-YR1 (1 - 25) 10/17/2014 Soil Tier II No14100622_Rev00 SL-CAP-14-YR1 (25 - 27) 10/17/2014 Soil Tier II Yes Aroclor-1016 Surrogate Recovery-TCMX,DCB 27.1%, 30.9% 60% to 140% ND(0.065) J

Aroclor-1221 Surrogate Recovery-TCMX,DCB 27.1%, 30.9% 60% to 140% ND(0.065) JAroclor-1232 Surrogate Recovery-TCMX,DCB 27.1%, 30.9% 60% to 140% ND(0.065) JAroclor-1242 Surrogate Recovery-TCMX,DCB 27.1%, 30.9% 60% to 140% ND(0.065) JAroclor-1248 Surrogate Recovery-TCMX,DCB 27.1%, 30.9% 60% to 140% 0.099Aroclor-1254 Surrogate Recovery-TCMX,DCB 27.1%, 30.9% 60% to 140% 0.084Aroclor-1260 Surrogate Recovery-TCMX,DCB 27.1%, 30.9% 60% to 140% ND(0.065) JTotal PCBs Surrogate Recovery-TCMX,DCB 27.1%, 30.9% 60% to 140% 0.183 J

14100622_Rev00 SL-CAP-16-YR1 (0 - 1) 10/17/2014 Soil Tier II No14100622_Rev00 SL-CAP-16-YR1 (1 - 15) 10/17/2014 Soil Tier II No14100622_Rev00 SL-CAP-16-YR1 (15 - 17) 10/17/2014 Soil Tier II Yes Aroclor-1016 Surrogate Recovery-TCMX 58.2% 60% to 140% ND(0.060) J

Aroclor-1221 Surrogate Recovery-TCMX 58.2% 60% to 140% ND(0.060) JAroclor-1232 Surrogate Recovery-TCMX 58.2% 60% to 140% ND(0.060) JAroclor-1242 Surrogate Recovery-TCMX 58.2% 60% to 140% ND(0.060) JAroclor-1248 Surrogate Recovery-TCMX 58.2% 60% to 140% 0.084Aroclor-1254 Surrogate Recovery-TCMX 58.2% 60% to 140% 0.041 JAroclor-1260 Surrogate Recovery-TCMX 58.2% 60% to 140% 0.044 JTotal PCBs Surrogate Recovery-TCMX 58.2% 60% to 140% 0.169 J

14100622_Rev00 SL-CAP-19-YR1 (0 - 1) 10/17/2014 Soil Tier II No14100622_Rev00 SL-CAP-19-YR1 (1 - 13) 10/17/2014 Soil Tier II No14100622_Rev00 SL-CAP-19-YR1 (13 - 15) 10/17/2014 Soil Tier II Yes Aroclor-1221 Aroclor 1221 tentatively identified - - 0.091 J

Total PCBs Aroclor 1221 tentatively identified - - 1.43 J14100622_Rev00 SL-CAP-20-YR1 (0 - 1) 10/17/2014 Soil Tier II No14100622_Rev00 SL-CAP-20-YR1 (1 - 14) 10/17/2014 Soil Tier II No

(Results are presented in parts per million, ppm)

Table C-1Analytical Data Validation Summary

Silver LakeGeneral Electric Company - Pittsfield, Massachusetts

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Validation Level Qualification Compound QA/QC Parameter Value Control Limits Qualified Result Notes

(Results are presented in parts per million, ppm)

Table C-1Analytical Data Validation Summary

Silver LakeGeneral Electric Company - Pittsfield, Massachusetts

PCBs (continued)14100622_Rev00 SL-CAP-20-YR1 (14 - 16) 10/17/2014 Soil Tier II Yes Aroclor-1016 Surrogate Recovery-TCMX,DCB 35.8%, 35.2% 60% to 140% ND(0.069) J

Aroclor-1221 Surrogate Recovery-TCMX,DCB 35.8%, 35.2% 60% to 140% ND(0.069) JAroclor-1232 Surrogate Recovery-TCMX,DCB 35.8%, 35.2% 60% to 140% ND(0.069) JAroclor-1242 Surrogate Recovery-TCMX,DCB 35.8%, 35.2% 60% to 140% ND(0.069) JAroclor-1248 Surrogate Recovery-TCMX,DCB 35.8%, 35.2% 60% to 140% ND(0.069) JAroclor-1254 Surrogate Recovery-TCMX,DCB 35.8%, 35.2% 60% to 140% ND(0.069) JAroclor-1260 Surrogate Recovery-TCMX,DCB 35.8%, 35.2% 60% to 140% ND(0.069) JTotal PCBs Surrogate Recovery-TCMX,DCB 35.8%, 35.2% 60% to 140% ND(0.069) J

Appendix B

Surface Water Monitoring Data Validation Report

Appendix B Surface Water Monitoring Data Validation Report 2014 Surface Water Monitoring Program for Silver Lake Area General Electric Company Pittsfield, Massachusetts

1.0 General

This appendix summarizes the data validation review performed on behalf of the General Electric Company (GE) for surface water samples collected from January through December 2014 from the Silver Lake Area as part of sampling activities conducted for the GE Pittsfield/Housatonic River Site in Pittsfield, Massachusetts. The samples were analyzed for polychlorinated biphenyls (PCBs) and other constituents by Pace Analytical (formerly Northeast Analytical, Inc. (NEA)) of Schenectady, New York. Data validation was performed for 22 PCB samples and 12 total suspended solids (TSS) samples.

2.0 Data Evaluation Procedures

This appendix outlines the applicable quality control criteria utilized during the data review process and any deviations from those criteria. The data review was conducted in accordance with the following documents:

• Field Sampling Plan/Quality Assurance Project Plan (FSP/QAPP), General Electric Company, Pittsfield, Massachusetts, ARCADIS (Revision 5 submitted by GE on July 2, 2013 and approved by EPA on July 23, 2013); and

• EPA Region I, EPA-New England Data Validation Functional Guidelines for Evaluating Environmental Analyses (July 1996, revised December 1996) (EPA Region I Guidelines).

The data were validated to Tier I and Tier II levels, as described below. Any deviations from the applicable quality control criteria utilized during the data review process are identified below. A tabulated summary of the Tier I/Tier II data review is presented in Table B-1. Each sample subject to evaluation is listed in Table B-1 to document that data review was performed. Samples that required data qualification are listed separately.

The following data qualifiers were used in this data evaluation:

J The compound was positively identified, but the associated numerical value is an estimated concentration. This qualifier is used when the data evaluation procedure identifies a deficiency in the data generation process. This qualifier is also used when a compound is detected at an estimated concentration less than the corresponding practical quantitation limit (PQL).

ND(PQL) The compound was analyzed for, but was not detected at the method detection limit. The sample PQL is presented in parentheses. Non-detect sample results are presented as ND(PQL) in this report for consistency with documents previously prepared for investigations conducted at the GE-Pittsfield/Housatonic River Site. 1

1 This project specific nomenclature differs from that in EPA guidance, which uses the qualifier U for non-detected compounds.

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ND(PQL) J The compound was not detected above the reported sample PQL, but the sample PQL is estimated and may or may not represent the actual level of quantitation. Non-detect sample results that required this qualification are presented as ND(PQL) J in this report for consistency with documents previously prepared for investigations conducted at the GE-Pittsfield/Housatonic River Site. 2

3.0 Data Validation Procedures

Section 7.5 of the revised FSP/QAPP states that all analytical data will be validated to a Tier I level following the procedures presented in the EPA Region I Guidelines. The Tier I review consisted of a completeness evidence audit, as outlined in the EPA Region I CSF Completeness Evidence Audit Program (EPA Region I, July 31, 1991), to ensure that laboratory data and documentation were present. In the event that data packages were determined to be incomplete, the missing information was requested from the laboratory. Upon completion of the Tier I review, the data packages complied with the EPA Region I Tier I data completeness requirements.

All analytical results from the surface water sampling activities described above were also subjected to a Tier II data review. The Tier II data review consisted of a review of data package summary forms for identification of quality assurance/quality control (QA/QC) deviations and qualification of the data according to the EPA Region I Guidelines. Additionally, field duplicates were examined for relative percent difference (RPD) compliance with the criteria specified in the FSP/QAPP. A tabulated summary of the samples subject to Tier I and Tier II data review is presented in the following table.

Summary of Samples Subjected to Tier I and Tier II Data Validation

Parameter Tier I Only Tier I &Tier II

Total Samples Duplicates Blanks Samples Duplicates Blanks

PCBs 0 0 0 22 0 0 22

TSSs 0 0 0 12 0 0 12

Total 0 0 0 34 0 0 34

When qualification of the sample data was required, the sample results associated with a QA/QC parameter deviation were qualified in accordance with the procedures outlined in EPA Region I Guidelines. When the data validation process identified several quality control deficiencies, the cumulative effect of the various deficiencies was employed in assigning the final data qualifier. A summary of the QA/QC parameter deviations that resulted in data qualification is presented in Section 4 below.

4.0 Summary of QA/QC Parameter Deviations Requiring Data Qualification

This section provides a summary of the deviations from the applicable QA/QC criteria that resulted in qualification of results.

Aroclor identification criteria require that the Aroclor pattern resemble that of the pattern established throughout the analysis of the standards of the target Aroclors. Sample data that did not match Aroclor patterns that were established through the analysis of target Aroclor standards were tentatively identified and qualified as estimated (J). The PCB compounds that did not meet Aroclor identification criteria and the number of samples qualified due to those deviations are presented in the following table.

2 This project specific nomenclature differs from that in EPA guidance, which uses the qualifier UJ for non-detected compounds in this category. G:\GE\GE_Silver_Lake\Reports and Presentations\2015-03 2014 Annual Report\Appendix B\0481511214_2014 Silver Lake DV Rpt.doc Page 2 of 6

Compounds Qualified Due to Identification Deviations

Analysis Compounds Number of Affected Samples Qualification

PCBs Aroclor-1221 19 J Aroclor-1242 6 J Aroclor-1248 7 J Total PCBs 20 J

Surrogate compounds are analyzed with every organic sample to aid in evaluation of the sample extraction efficiency. As specified in the FSP/QAPP, both of the PCB surrogate compounds must have a recovery within laboratory-specified control limits. Sample results less than control limits and greater than 10% were qualified as estimated (J or ND(PQL) J). A summary of the compounds affected by surrogate recovery exceedances and the number of samples qualified due to those deviations are presented in the following table.

Compounds Qualified Due to Surrogate Recovery Deviations




Aroclor-1232 22 ND(PQL) J





Total PCBs 1 ND(PQL) J 21 J

Laboratory control sample/laboratory control sample duplicate (LCS/LCSD) analysis recovery criteria for PCBs be within 70% to 130%. The compounds that did not meet LCS/LCSD recovery criteria and the number of samples qualified due to those deviations are presented in the following table.


Compounds Qualified Due to LCS/LCSD Deviations

Analysis Compound Number of Affected Samples

Qualification



Aroclor-1232 3 ND(PQL) J Aroclor-1242 3 ND(PQL) J




Total PCBs 2 J 1 ND(PQL) J

Blank action levels for compounds/analytes detected in the blanks were calculated at five times the blank concentrations. Detected sample results that were below the blank action level were qualified as non-detect at the detected compound concentration (ND(DCC)), and the total PCB concentration was adjusted accordingly. The compounds detected in method/equipment blanks which resulted in qualification of sample data, along with the number of affected samples, are presented in the following table.

Compounds Qualified Due to Blank Deviations


PCBs Aroclor-1221 1 ND(DCC) Aroclor-1260 1 ND(DCC)

Total PCBs 2 Adjusted

Organic technical holding time criteria require that the samples be preserved at <6°C. Samples that were not <6°C at time of receipt resulted in qualification of sample data as estimated (J or ND(PQL) J). The compounds/analyte that exceeded the temperature limit and the number of samples qualified due to deviations are presented in the following table.

Compounds/Analyte Qualified Due to Temperature Deviations

Analysis Compound/Analyte Number of Affected Samples Qualification

PCBs Aroclor-1016 2 ND(PQL) J Aroclor-1221 2 J Aroclor-1232 2 ND(PQL) J


Aroclor-1248 1 ND(PQL) J


Aroclor-1260 2 ND(PQL) J Total PCBs 2 J


Compounds/Analyte Qualified Due to Temperature Deviations

Analysis Compound/Analyte Number of Affected Samples Qualification

Miscellaneous Total Suspended Solids 1 J

5.0 Overall Data Usability

This section summarizes the analytical data in terms of its completeness and usability. Data completeness is defined as the percentage of sample results that have been determined to be usable during the data validation process. The percent usability calculation included analyses evaluated under both the Tier I/II data validation reviews. The percent usability calculation also includes quality control samples (i.e., field/equipment blanks, trip blanks, and field duplicates) to aid in the evaluation of data usability. Data usability is summarized in the following table.

Data Usability Parameter Percent Usability Rejected Data

PCBs 100 None

TSS 100 None

The data package completeness, as determined from the Tier I data review, was used in combination with the data quality deviations identified during the Tier II data review to determine overall data quality. As specified in the FSP/QAPP, the overall precision, accuracy, representativeness, comparability, and completeness (PARCC) parameters determined from the Tier I and Tier II data reviews were used as indicators of overall data quality. These parameters were assessed through an evaluation of the results of the field and laboratory QA/QC sample analyses to provide a measure of compliance of the analytical data with the Data Quality Objectives (DQOs) specified in the FSP/QAPP. Therefore, the following sections present summaries of the PARCC parameters assessment with regard to the DQOs specified in the FSP/QAPP.

5.1 Precision

Precision measures the reproducibility of measurements under a given set of conditions. Specifically, it is a quantitative measure of the variability of a group of measurements compared to their average value. For this investigation, precision was defined as the RPD between duplicate sample results. The duplicate samples used to evaluate precision included LCS/LCSD samples. None of the data required qualification due to LCS/LCSD sample RPD deviations.

5.2 Accuracy

Accuracy measures the bias in an analytical system or the degree of agreement of a measurement with a known reference value. For this investigation, accuracy was defined as the percent recovery of QA/QC samples that were spiked with a known concentration of an analyte or compound of interest. The QA/QC samples used to evaluate analytical accuracy included instrument calibration, LCS/LCSD samples, and surrogate compound recoveries. For this analytical program, 12.8% of the data required qualification due to LCS/LCSD recovery deviations and 89.3% of the data required qualification due to surrogate compound recovery deviations. None of the data required qualification due to instrument calibration deviations.


5.3 Representativeness

Representativeness expresses the degree to which sample data accurately and precisely represents a characteristic of a population, parameter variations at a sampling point, or an environmental condition. Representativeness is a qualitative parameter, which is most concerned with the proper design of the sampling program. The representativeness criterion is best satisfied by making certain that sampling locations are selected properly and a sufficient number of samples are collected. This parameter has been addressed by collecting samples at locations specified in the EPA-approved work plans, and by following the procedures for sample collection/analyses that were described in the FSP/QAPP. Additionally, the analytical program used procedures consistent with EPA-approved analytical methodology. A QA/QC parameter that is an indicator of the representativeness of a sample is temperature. Temperature criteria are established to maintain the samples in a state that deters compound/analyte loss and/or degradation prior to analysis. For this analytical data set, 8.5% of the data required qualification due to temperature deviations.

5.4 Comparability

Comparability is a qualitative parameter expressing the confidence with which one data set can be compared with another. This goal was achieved through the use of the standardized techniques for sample collection and analysis presented in the FSP/QAPP. Specifically, all the surface water samples collected between January and December 2014 were analyzed by EPA SW-846 Method 8082 for PCBs and 2540D for TSSs.

5.5 Completeness

Completeness is defined as the percentage of measurements that are judged to be valid or usable to meet the prescribed DQOs. The completeness criterion is essentially the same for all data uses -- the generation of a sufficient amount of valid data. The actual completeness of this analytical data set was 100%.


3/4/2015G:\GE\GE_Silver_Lake\Reports and Presentations\2015-03 2014 Annual Report\Appendix B\0481511214_2014 Silver Lake DV table.xlsx Page 1 of 5

TABLE B-1ANALYTICAL DATA VALIDATION SUMMARY

GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS(Results are presented in parts per million, ppm)


Validation Level Qualification Compound QA/QC Parameter Value Control Limits Qualified Result

PCBs14010505 Rev00 LOCATION-4A 1/28/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery - DCB 40.6% 60% to 140% ND(0.000022) J

Aroclor-1221 Surrogate Recovery - DCB 40.6% 60% to 140% ND(0.000022) JAroclor-1232 Surrogate Recovery - DCB 40.6% 60% to 140% ND(0.000022) JAroclor-1242 Surrogate Recovery - DCB 40.6% 60% to 140% ND(0.000022) JAroclor-1248 Surrogate Recovery - DCB 40.6% 60% to 140% ND(0.000022) JAroclor-1254 Surrogate Recovery - DCB 40.6% 60% to 140% ND(0.000022) JAroclor-1260 Surrogate Recovery - DCB 40.6% 60% to 140% ND(0.000022) JTotal PCBs Surrogate Recovery - DCB 40.6% 60% to 140% ND(0.000022) J

14020427_Rev00 LOCATION-4A 2/20/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery - DCB 31.2% 60% to 140% ND(0.000022) JAroclor-1221 Surrogate Recovery - DCB 31.2% 60% to 140% 0.000038 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000038 JAroclor-1232 Surrogate Recovery - DCB 31.2% 60% to 140% ND(0.000022) JAroclor-1242 Surrogate Recovery - DCB 31.2% 60% to 140% ND(0.000022) JAroclor-1248 Surrogate Recovery - DCB 31.2% 60% to 140% ND(0.000022) JAroclor-1254 Surrogate Recovery - DCB 31.2% 60% to 140% ND(0.000022) JAroclor-1260 Surrogate Recovery - DCB 31.2% 60% to 140% ND(0.000022) JTotal PCBs Surrogate Recovery - DCB 31.2% 60% to 140% 0.000038 JTotal PCBs Aroclor 1221 tentatively identified - - 0.000038 J

14030528 Rev00 LOCATION-4A 3/27/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery - DCB 25.2% 60% to 140% ND(0.000022) JAroclor-1221 Surrogate Recovery - DCB 25.2% 60% to 140% 0.000044 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000044 JAroclor-1232 Surrogate Recovery - DCB 25.2% 60% to 140% ND(0.000022) JAroclor-1242 Surrogate Recovery - DCB 25.2% 60% to 140% ND(0.000022) JAroclor-1248 Surrogate Recovery - DCB 25.2% 60% to 140% ND(0.000022) JAroclor-1254 Surrogate Recovery - DCB 25.2% 60% to 140% ND(0.000022) JAroclor-1260 Surrogate Recovery - DCB 25.2% 60% to 140% ND(0.000022) JTotal PCBs Surrogate Recovery - DCB 25.2% 60% to 140% 0.000044 JTotal PCBs Aroclor 1221 tentatively identified - - 0.000044 J

14030528_Rev00 LOCATION-4A (Filtered) 3/27/2014 Water Tier II Yes Aroclor-1016 LCS %R 60.4% 70.0% to 130% ND(0.000022) JAroclor-1221 LCS %R 60.4% 70.0% to 130% ND(0.000022) JAroclor-1232 LCS %R 60.4% 70.0% to 130% ND(0.000022) JAroclor-1242 LCS %R 60.4% 70.0% to 130% ND(0.000022) JAroclor-1248 LCS %R 60.4% 70.0% to 130% ND(0.000022) JAroclor-1254 LCS %R 60.4% 70.0% to 130% ND(0.000022) JAroclor-1260 LCS %R 60.4% 70.0% to 130% ND(0.000022) JTotal PCBs LCS %R 60.4% 70.0% to 130% ND(0.000022) J

14040505 Rev00 LOCATION-4A 4/24/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery - DCB 29.9% 60% to 140% ND(0.0000055) JAroclor-1221 Surrogate Recovery - DCB 29.9% 60% to 140% 0.000041 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000041 JAroclor-1232 Surrogate Recovery - DCB 29.9% 60% to 140% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 29.9% 60% to 140% 0.000014 JAroclor-1242 Aroclor 1242 tentatively identified - - 0.000014 JAroclor-1248 Surrogate Recovery - DCB 29.9% 60% to 140% ND(0.0000055) JAroclor-1254 Surrogate Recovery - DCB 29.9% 60% to 140% 0.0000081 JAroclor-1260 Surrogate Recovery - DCB 29.9% 60% to 140% ND(0.0000055) JTotal PCBs Surrogate Recovery - DCB 29.9% 60% to 140% 0.0000631 JTotal PCBs Aroclor 1221, 1242 tentatively identified - - 0.0000631 J

2014 ANNUAL MONITORING REPORTSILVER LAKE AREA







PCBs (continued)14040505_Rev00 LOCATION-4A (Filtered) 4/24/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery - DCB 20.0% 60% to 140% ND(0.0000055) J

Aroclor-1221 Surrogate Recovery - DCB 20.0% 60% to 140% 0.000022 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000022 JAroclor-1232 Surrogate Recovery - DCB 20.0% 60% to 140% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 20.0% 60% to 140% ND(0.0000055) JAroclor-1248 Surrogate Recovery - DCB 20.0% 60% to 140% ND(0.0000055) JAroclor-1254 Surrogate Recovery - DCB 20.0% 60% to 140% ND(0.0000055) JAroclor-1260 Surrogate Recovery - DCB 20.0% 60% to 140% ND(0.0000055) JTotal PCBs Surrogate Recovery - DCB 20.0% 60% to 140% 0.000022 JTotal PCBs Aroclor 1221 tentatively identified - - 0.000022 J

14050559 Rev00 LOCATION-4A 5/21/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery - DCB 27.6% 60% to 140% ND(0.0000055) JAroclor-1221 Surrogate Recovery - DCB 27.6% 60% to 140% 0.000056 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000056 JAroclor-1232 Surrogate Recovery - DCB 27.6% 60% to 140% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 27.6% 60% to 140% 0.000018 JAroclor-1248 Surrogate Recovery - DCB 27.6% 60% to 140% ND(0.0000055) JAroclor-1254 Surrogate Recovery - DCB 27.6% 60% to 140% 0.0000056 JAroclor-1260 Surrogate Recovery - DCB 27.6% 60% to 140% ND(0.0000055) JTotal PCBs Surrogate Recovery - DCB 27.6% 60% to 140% 0.0000796 JTotal PCBs Aroclor 1221 tentatively identified - - 0.0000796 J

14050559_Rev00 LOCATION-4A (Filtered) 5/21/2014 Water Tier II Yes Aroclor-1016 LCS %R 68.0% 70.0% to 130% ND(0.0000055) JAroclor-1016 Surrogate Recovery - DCB 31.8% 60% to 140% ND(0.0000055) JAroclor-1221 LCS %R 68.0% 70.0% to 130% 0.000042 JAroclor-1221 Surrogate Recovery - DCB 31.8% 60% to 140% 0.000042 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000042 JAroclor-1232 LCS %R 68.0% 70.0% to 130% ND(0.0000055) JAroclor-1232 Surrogate Recovery - DCB 31.8% 60% to 140% ND(0.0000055) JAroclor-1242 LCS %R 68.0% 70.0% to 130% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 31.8% 60% to 140% ND(0.0000055) JAroclor-1248 LCS %R 68.0% 70.0% to 130% ND(0.0000055) JAroclor-1248 Surrogate Recovery - DCB 31.8% 60% to 140% ND(0.0000055) JAroclor-1254 LCS %R 68.0% 70.0% to 130% ND(0.0000055) JAroclor-1254 Surrogate Recovery - DCB 31.8% 60% to 140% ND(0.0000055) JAroclor-1260 LCS %R 68.0% 70.0% to 130% ND(0.0000055) JAroclor-1260 Surrogate Recovery - DCB 31.8% 60% to 140% ND(0.0000055) JTotal PCBs LCS %R 68.0% 70.0% to 130% 0.000042 JTotal PCBs Surrogate Recovery - DCB 31.8% 60% to 140% 0.000042 JTotal PCBs Aroclor 1221 tentatively identified - - 0.000042 J

14061011_Rev00 LOCATION-4A 6/26/2014 Water Tier II Yes Aroclor-1016 LCS %R 66.5% 70.0% to 130% ND(0.0000055) JAroclor-1016 Surrogate Recovery - DCB 32.1% 60% to 140% ND(0.0000055) JAroclor-1221 LCS %R 66.5% 70.0% to 130% 0.000044 JAroclor-1221 Surrogate Recovery - DCB 32.1% 60% to 140% 0.000044 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000044 JAroclor-1232 LCS %R 66.5% 70.0% to 130% ND(0.0000055) JAroclor-1232 Surrogate Recovery - DCB 32.1% 60% to 140% ND(0.0000055) JAroclor-1242 LCS %R 66.5% 70.0% to 130% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 32.1% 60% to 140% ND(0.0000055) JAroclor-1248 LCS %R 66.5% 70.0% to 130% 0.000030 JAroclor-1248 Surrogate Recovery - DCB 32.1% 60% to 140% 0.000030 JAroclor-1254 LCS %R 66.5% 70.0% to 130% 0.000016 JAroclor-1254 Surrogate Recovery - DCB 32.1% 60% to 140% 0.000016 JAroclor-1260 LCS %R 66.5% 70.0% to 130% 0.0000070 JAroclor-1260 Surrogate Recovery - DCB 32.1% 60% to 140% 0.0000070 JTotal PCBs LCS %R 66.5% 70.0% to 130% 0.000097 JTotal PCBs Surrogate Recovery - DCB 32.1% 60% to 140% 0.000097 JTotal PCBs Aroclor 1221 tentatively identified - - 0.000097 J








Aroclor-1221 Surrogate Recovery - DCB 35.7% 60% to 140% 0.000042 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000042 JAroclor-1232 Surrogate Recovery - DCB 35.7% 60% to 140% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 35.7% 60% to 140% 0.000013 JAroclor-1242 Aroclor 1242 tentatively identified - - 0.000013 JAroclor-1248 Surrogate Recovery - DCB 35.7% 60% to 140% ND(0.0000055) JAroclor-1254 Surrogate Recovery - DCB 35.7% 60% to 140% ND(0.0000055) JAroclor-1260 Surrogate Recovery - DCB 35.7% 60% to 140% ND(0.0000055) JTotal PCBs Surrogate Recovery - DCB 35.7% 60% to 140% 0.000055 JTotal PCBs Aroclor 1221, 1242 tentatively identified - - 0.000055 J

14070787_Rev00 LOCATION-4A 7/22/2014 Water Tier II Yes Aroclor-1016 Temperature Receipt 9.9 °C <6 °C ND(0.0000055) JAroclor-1016 Surrogate Recovery - DCB 28.9% 60% to 140% ND(0.0000055) JAroclor-1221 Temperature Receipt 9.9 °C <6 °C 0.000061 JAroclor-1221 Surrogate Recovery - DCB 28.9% 60% to 140% 0.000061 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000061 JAroclor-1232 Temperature Receipt 9.9 °C <6 °C ND(0.0000055) JAroclor-1232 Surrogate Recovery - DCB 28.9% 60% to 140% ND(0.0000055) JAroclor-1242 Temperature Receipt 9.9 °C <6 °C 0.000022 JAroclor-1242 Surrogate Recovery - DCB 28.9% 60% to 140% 0.000022 JAroclor-1242 Aroclor 1242 tentatively identified - - 0.000022 JAroclor-1248 Temperature Receipt 9.9 °C <6 °C ND(0.0000055) JAroclor-1248 Surrogate Recovery - DCB 28.9% 60% to 140% ND(0.0000055) JAroclor-1254 Temperature Receipt 9.9 °C <6 °C 0.000011 JAroclor-1254 Surrogate Recovery - DCB 28.9% 60% to 140% 0.000011 JAroclor-1260 Temperature Receipt 9.9 °C <6 °C ND(0.0000055) JAroclor-1260 Surrogate Recovery - DCB 28.9% 60% to 140% ND(0.0000055) JTotal PCBs Temperature Receipt 9.9 °C <6 °C 0.000094 JTotal PCBs Surrogate Recovery - DCB 28.9% 60% to 140% 0.000094 JTotal PCBs Aroclor 1221, 1242 tentatively identified - - 0.000094 J

14070787_Rev00 LOCATION-4A (Filtered) 7/22/2014 Water Tier II Yes Aroclor-1016 Temperature Receipt 9.9 °C <6 °C ND(0.0000055) JAroclor-1016 Surrogate Recovery - DCB 40.5% 60% to 140% ND(0.0000055) JAroclor-1221 Temperature Receipt 9.9 °C <6 °C 0.000025 JAroclor-1221 Surrogate Recovery - DCB 40.5% 60% to 140% 0.000025 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000025 JAroclor-1232 Temperature Receipt 9.9 °C <6 °C ND(0.0000055) JAroclor-1232 Surrogate Recovery - DCB 40.5% 60% to 140% ND(0.0000055) JAroclor-1242 Temperature Receipt 9.9 °C <6 °C ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 40.5% 60% to 140% ND(0.0000055) JAroclor-1248 Temperature Receipt 9.9 °C <6 °C ND(0.0000055) JAroclor-1248 Surrogate Recovery - DCB 40.5% 60% to 140% ND(0.0000055) JAroclor-1254 Temperature Receipt 9.9 °C <6 °C ND(0.0000055) JAroclor-1254 Surrogate Recovery - DCB 40.5% 60% to 140% ND(0.0000055) JAroclor-1260 Temperature Receipt 9.9 °C <6 °C ND(0.0000055) JAroclor-1260 Surrogate Recovery - DCB 40.5% 60% to 140% ND(0.0000055) JTotal PCBs Temperature Receipt 9.9 °C <6 °C 0.000025 JTotal PCBs Surrogate Recovery - DCB 40.5% 60% to 140% 0.000025 JTotal PCBs Aroclor 1221 tentatively identified - - 0.000025 J

14081662_Rev00 LOCATION-4A 8/27/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery - DCB 42.4% 60% to 140% ND(0.0000055) JAroclor-1221 Surrogate Recovery - DCB 42.4% 60% to 140% 0.000066 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000066 JAroclor-1232 Surrogate Recovery - DCB 42.4% 60% to 140% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 42.4% 60% to 140% ND(0.0000055) JAroclor-1248 Surrogate Recovery - DCB 42.4% 60% to 140% 0.000035 JAroclor-1248 Aroclor 1248 tentatively identified - - 0.000035 JAroclor-1254 Surrogate Recovery - DCB 42.4% 60% to 140% 0.000019 JAroclor-1260 Surrogate Recovery - DCB 42.4% 60% to 140% 0.0000089 JTotal PCBs Surrogate Recovery - DCB 42.4% 60% to 140% 0.000129 JTotal PCBs Aroclor 1221, 1248 tentatively identified - - 0.000129 J








Aroclor-1221 Surrogate Recovery - DCB 42.4% 60% to 140% 0.000035 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000035 JAroclor-1232 Surrogate Recovery - DCB 42.4% 60% to 140% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 42.4% 60% to 140% 0.000012 JAroclor-1242 Aroclor 1242 tentatively identified - - 0.000012 JAroclor-1248 Surrogate Recovery - DCB 42.4% 60% to 140% ND(0.0000055) JAroclor-1254 Surrogate Recovery - DCB 42.4% 60% to 140% ND(0.0000055) JAroclor-1260 Surrogate Recovery - DCB 42.4% 60% to 140% ND(0.0000055) JTotal PCBs Surrogate Recovery - DCB 42.4% 60% to 140% 0.000047 JTotal PCBs Aroclor 1221, 1242 tentatively identified - - 0.000047 J

14090897_Rev00 LOCATION-4A 9/25/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery -TCMX,DCB 56.8%, 40.3% 70.0% to 130% ND(0.0000055) JAroclor-1221 Surrogate Recovery -TCMX,DCB 56.8%, 40.3% 70.0% to 130% 0.000056 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000056 JAroclor-1232 Surrogate Recovery -TCMX,DCB 56.8%, 40.3% 70.0% to 130% ND(0.0000055) JAroclor-1242 Surrogate Recovery -TCMX,DCB 56.8%, 40.3% 70.0% to 130% ND(0.0000055) JAroclor-1248 Surrogate Recovery -TCMX,DCB 56.8%, 40.3% 70.0% to 130% 0.000025 JAroclor-1248 Aroclor 1248 tentatively identified - - 0.000025 JAroclor-1254 Surrogate Recovery -TCMX,DCB 56.8%, 40.3% 70.0% to 130% ND(0.0000055) JAroclor-1260 Surrogate Recovery -TCMX,DCB 56.8%, 40.3% 70.0% to 130% ND(0.0000055) JTotal PCBs Surrogate Recovery -TCMX,DCB 56.8%, 40.3% 70.0% to 130% 0.000081 JTotal PCBs Aroclor 1221, 1248 tentatively identified - - 0.000081 J

14090897 Rev00 LOCATION-4A (Filtered) 9/25/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery - DCB 43.3% 60% to 140% ND(0.0000055) JAroclor-1221 Surrogate Recovery - DCB 43.3% 60% to 140% ND(0.000033) JAroclor-1221 Equipment Blank - - ND(0.000033)Aroclor-1232 Surrogate Recovery - DCB 43.3% 60% to 140% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 43.3% 60% to 140% ND(0.0000055) JAroclor-1248 Surrogate Recovery - DCB 43.3% 60% to 140% 0.0000068 JAroclor-1248 Aroclor 1248 tentatively identified - - 0.0000068 JAroclor-1254 Surrogate Recovery - DCB 43.3% 60% to 140% ND(0.0000055) JAroclor-1260 Surrogate Recovery - DCB 43.3% 60% to 140% ND(0.0000055) JTotal PCBs Surrogate Recovery - DCB 43.3% 60% to 140% 0.0000068 JTotal PCBs Aroclor 1248 tentatively identified - - 0.0000068 JTotal PCBs Equipment Blank - - 0.0000068 J

14110008 Rev00 LOCATION-4A 10/30/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery -TCMX,DCB 50.5%, 27.3% 70.0% to 130% ND(0.0000055) JAroclor-1221 Surrogate Recovery -TCMX,DCB 50.5%, 27.3% 70.0% to 130% 0.000045 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000045 JAroclor-1232 Surrogate Recovery -TCMX,DCB 50.5%, 27.3% 70.0% to 130% ND(0.0000055) JAroclor-1242 Surrogate Recovery -TCMX,DCB 50.5%, 27.3% 70.0% to 130% ND(0.0000055) JAroclor-1248 Surrogate Recovery -TCMX,DCB 50.5%, 27.3% 70.0% to 130% 0.000017 JAroclor-1248 Aroclor 1248 tentatively identified - - 0.000017 JAroclor-1254 Surrogate Recovery -TCMX,DCB 50.5%, 27.3% 70.0% to 130% ND(0.0000055) JAroclor-1260 Surrogate Recovery -TCMX,DCB 50.5%, 27.3% 70.0% to 130% ND(0.0000055) JTotal PCBs Surrogate Recovery -TCMX,DCB 50.5%, 27.3% 70.0% to 130% 0.000062 JTotal PCBs Aroclor 1221, 1248 tentatively identified - - 0.000062 J

14110008_Rev00 LOCATION-4A (Filtered) 10/30/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery - DCB 54.6% 60% to 140% ND(0.0000055) JAroclor-1221 Surrogate Recovery - DCB 54.6% 60% to 140% 0.000030 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000030 JAroclor-1232 Surrogate Recovery - DCB 54.6% 60% to 140% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 54.6% 60% to 140% ND(0.0000055) JAroclor-1248 Surrogate Recovery - DCB 54.6% 60% to 140% 0.0000034 JAroclor-1248 Aroclor 1248 tentatively identified - - 0.0000034 JAroclor-1254 Surrogate Recovery - DCB 54.6% 60% to 140% ND(0.0000055) JAroclor-1260 Surrogate Recovery - DCB 54.6% 60% to 140% ND(0.0000060) JAroclor-1260 Method Blank - - ND(0.0000060)Total PCBs Surrogate Recovery - DCB 54.6% 60% to 140% 0.0000334 JTotal PCBs Aroclor 1221, 1248 tentatively identified - - 0.0000334 JTotal PCBs Method Blank - - 0.0000334 J







PCBs (continued)14110587_Rev00 LOCATION-4A 11/19/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery - DCB 16.0% 60% to 140% ND(0.0000055) J

Aroclor-1221 Surrogate Recovery - DCB 16.0% 60% to 140% 0.000046 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000046 JAroclor-1232 Surrogate Recovery - DCB 16.0% 60% to 140% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 16.0% 60% to 140% ND(0.0000055) JAroclor-1248 Surrogate Recovery - DCB 16.0% 60% to 140% 0.000019 JAroclor-1248 Aroclor 1248 tentatively identified - - 0.000019 JAroclor-1254 Surrogate Recovery - DCB 16.0% 60% to 140% ND(0.0000055) JAroclor-1260 Surrogate Recovery - DCB 16.0% 60% to 140% ND(0.0000055) JTotal PCBs Surrogate Recovery - DCB 16.0% 60% to 140% 0.000065 JTotal PCBs Aroclor 1221, 1248 tentatively identified - - 0.000065 J

14110587_Rev00 LOCATION-4A (Filtered) 11/19/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery - DCB 16.0% 60% to 140% ND(0.0000055) JAroclor-1221 Surrogate Recovery - DCB 16.0% 60% to 140% 0.000025 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000025 JAroclor-1232 Surrogate Recovery - DCB 16.0% 60% to 140% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 16.0% 60% to 140% 0.0000076 JAroclor-1242 Aroclor 1242 tentatively identified - - 0.0000076 JAroclor-1248 Surrogate Recovery - DCB 16.0% 60% to 140% ND(0.0000055) JAroclor-1254 Surrogate Recovery - DCB 16.0% 60% to 140% ND(0.0000055) JAroclor-1260 Surrogate Recovery - DCB 16.0% 60% to 140% ND(0.0000055) JTotal PCBs Surrogate Recovery - DCB 16.0% 60% to 140% 0.0000326 JTotal PCBs Aroclor 1221, 1242 tentatively identified - - 0.0000326 J

14120385_Rev00 LOCATION-4A 12/16/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery - DCB 27.0% 60% to 140% ND(0.0000055) JAroclor-1221 Surrogate Recovery - DCB 27.0% 60% to 140% 0.000039 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000039 JAroclor-1232 Surrogate Recovery - DCB 27.0% 60% to 140% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 27.0% 60% to 140% ND(0.0000055) JAroclor-1248 Surrogate Recovery - DCB 27.0% 60% to 140% 0.0000069 JAroclor-1248 Aroclor 1248 tentatively identified - - 0.0000069 JAroclor-1254 Surrogate Recovery - DCB 27.0% 60% to 140% ND(0.0000055) JAroclor-1260 Surrogate Recovery - DCB 27.0% 60% to 140% ND(0.0000055) JTotal PCBs Surrogate Recovery - DCB 27.0% 60% to 140% 0.0000459 JTotal PCBs Aroclor 1221, 1248 tentatively identified - - 0.0000459 J

14120385_Rev00 LOCATION-4A (Filtered) 12/16/2014 Water Tier II Yes Aroclor-1016 Surrogate Recovery - DCB 48.5% 60% to 140% ND(0.0000055) JAroclor-1221 Surrogate Recovery - DCB 48.5% 60% to 140% 0.000021 JAroclor-1221 Aroclor 1221 tentatively identified - - 0.000021 JAroclor-1232 Surrogate Recovery - DCB 48.5% 60% to 140% ND(0.0000055) JAroclor-1242 Surrogate Recovery - DCB 48.5% 60% to 140% 0.0000035 JAroclor-1242 Aroclor 1242 tentatively identified - - 0.0000035 JAroclor-1248 Surrogate Recovery - DCB 48.5% 60% to 140% ND(0.0000055) JAroclor-1254 Surrogate Recovery - DCB 48.5% 60% to 140% ND(0.0000055) JAroclor-1260 Surrogate Recovery - DCB 48.5% 60% to 140% ND(0.0000055) JTotal PCBs Surrogate Recovery - DCB 48.5% 60% to 140% 0.0000245 JTotal PCBs Aroclor 1221, 1242 tentatively identified - - 0.0000245 J

TSSs14010505_Rev00 LOCATION-4A 1/28/2014 Water Tier II No14020427_Rev00 LOCATION-4A 2/20/2014 Water Tier II No14030528_Rev00 LOCATION-4A 3/27/2014 Water Tier II No14040505_Rev00 LOCATION-4A 4/24/2014 Water Tier II No14050559_Rev00 LOCATION-4A 5/21/2014 Water Tier II No14061011_Rev00 LOCATION-4A 6/26/2014 Water Tier II No14070787_Rev00 LOCATION-4A 7/22/2014 Water Tier II Yes Total Suspended Solids Temperature Receipt 9.9 °C <6 °C 7.00 J14081662_Rev00 LOCATION-4A 8/27/2014 Water Tier II No14090897_Rev00 LOCATION-4A 9/25/2014 Water Tier II No14110008_Rev00 LOCATION-4A 10/30/2014 Water Tier II No14110587_Rev00 LOCATION-4A 11/19/2014 Water Tier II No14120385_Rev00 LOCATION-4A 12/16/2014 Water Tier II No

Appendix C

Surface Water Monitoring – EPA Split Sampling Results (Provided by EPA)

Lab Sample ID

Date

Collected

Sample

Results Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Total PCBs

Pace Location 4A 1/28/2014 Total ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J) ND(0.022 J)

Test America SL-SW000059-0-4J28 1/28/2014 Total ND (0.51) ND (0.51) ND (0.51) ND (0.51) ND (0.51) ND (0.51) ND (0.51) ND (0.51)

Pace Location 4A 4/24/2014 Total ND(0.0055 J) 0.041 J ND(0.0055 J) 0.014 J ND(0.0055 J) 0.0081 J ND(0.0055 J) 0.0631 J

Pace Location 4A 4/24/2014 Dissolved ND(0.0055 J) 0.022 J ND(0.0055 J) ND(0.0055 J) ND(0.0055 J) ND(0.0055 J) ND(0.0055 J) 0.022 J

Test America SL-SW000059-0-4A24 4/24/2014 Total ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01)

Test America SL-SW000059-0-4A24 4/24/2014 Dissolved ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01)

Pace Location 4A 7/22/2014 Total ND(0.0055 J) 0.061 J ND(0.0055 J) 0.022 J ND(0.0055 J) 0.011 J ND(0.0055 J) 0.094 J

Pace Location 4A 7/22/2014 Dissolved ND(0.0055 J) 0.025 J ND(0.0055 J) ND(0.0055 J) ND(0.0055 J) ND(0.0055 J) ND(0.0055 J) 0.025 J

Test America SL-SW000059-0-4L22 7/22/2014 Total ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01)

Test America SL-SW000059-0-4L22 7/22/2014 Dissolved ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01)

CLP Lab ASL01 7/22/2014 Total ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) 0.0041 J1

0.0041 J1

CLP Lab ASL02 7/22/2014 Dissolved ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) ND (0.01) 0.0012 J1

0.0012 J1

Pace Location 4A 8/27/2014 Total ND(0.0055 J) 0.066 J ND(0.0055 J) ND(0.0055 J) 0.035 J 0.019 J 0.0089 J 0.129 J

Pace Location 4A 8/27/2014 Dissolved ND(0.0055 J) 0.035 J ND(0.0055 J) 0.012 J ND(0.0055 J) ND(0.0055 J) ND(0.0055 J) 0.047 J

Test America SL-SW000059-0-4G27 8/27/2014 Total ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095)

Test America SL-SW000059-0-4G27 8/27/2014 Dissolved ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095)

CLP Lab ASL03 8/27/2014 Total ND (0.010) ND (0.010) ND (0.010) ND (0.010) ND (0.010) ND (0.010) ND (0.010) ND (0.010)

CLP Lab ASL04 8/27/2014 Dissolved ND (0.010) ND (0.010) ND (0.010) ND (0.010) ND (0.010) ND (0.010) ND (0.010) ND (0.010)

Pace Location 4A 10/30/2014 Total ND(0.0055 J) 0.045 J ND(0.0055 J) ND(0.0055 J) 0.017 J ND(0.0055 J) ND(0.0055 J) 0.062 J

Pace Location 4A 10/30/2014 Dissolved ND(0.0055 J) 0.03 J ND(0.0055 J) ND(0.0055 J) 0.0034 J ND(0.0055 J) ND(0.006 J) 0.0334 J

Test America SL-SW000059-0-4C30 10/30/2014 Total ND (0.0094) ND (0.0094) ND (0.0094) ND (0.0094) ND (0.0094) ND (0.0094) ND (0.0094) ND (0.0094)

Test America SL-SW000059-0-4C30 10/30/2014 Dissolved ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095)



Silver Lake* Surface Water Data - 2014 Split Sampling

GE-Pittsfield/Housatonic River - Pittsfield, MA

Results are in µg/L

Page 1 of 2

Lab Sample ID

Date

Collected

Sample

Results Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Total PCBs



Test America SL-SW000059-0-4N19 11/19/2014 Total ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095)

Test America SL-SW000059-0-4N19 11/19/2014 Dissolved ND (0.0098) ND (0.0098) ND (0.0098) ND (0.0098) ND (0.0098) ND (0.0098) ND (0.0098) ND (0.0098)

CLP Lab ASL07 11/19/2014 Total ND (0.00943) ND (0.00943) ND (0.00943) ND (0.00943) ND (0.00943) ND (0.00943) 0.0373 J2

0.0373 J2




Test America SL-SW000059-0-4D16 12/16/2014 Total ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) 0.0074 J3

ND (0.0095 UJ3) 0.0074 J

3

Test America SL-SW000059-0-4D16 12/16/2014 Dissolved ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095) ND (0.0095 UJ3) ND (0.0095 UJ

3)



Notes:

*Silver Lake samples collected from outlet channel of lake.

Tier II Data Validation was performed on the EPA (Test America and CLP Lab) split samples.

Detailed information regarding Data Validation for Pace Laboratory results can be found in Appendix B to this report.

ND (0.51) - Analyte was not detected. The value in parentheses is the associated reporting limit.

J - Indicates an estimated value.

J1 - Percent difference between results from each column were above criteria, therefore the positive results were estimated.

J2 - Laboratory control sample recovery above QC limits, therefore the positive results were estimated.

J3 - Continuing Calibration Verification (CCV) recovered above QC limits, therefore positive and non-detected results were estimated.

Page 2 of 2

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