SITE: 6 £ - r W W Superfund Records Center

BREM: Z.f OTHER: 7fa

159 Plastics Avenue Pittsfield. MA 01201 USA

Transmitted via Electronic Mail and Overnight Delivery

May 1, 2013

Mr. Dave Dickerson U.S. Environmental Protection Agency 5 Post Office Square - Suite 100 Boston, MA 02109-3912

Re: GE-Pittsfield/Housatonic River Site Silver Lake Area (GECD600) Notification of Exceedance of Ambient Air PCB Notification and Action Levels

Dear Mr. Dickerson:

Pursuant to Section 10.1 of GE's Revised Scope of Work for Ambient Air PCB and Particulate Monitoring at Silver Lake Area (Appendix N to the Revised Final Removal Design/Removal Action Work Plan for Silver Lake Area), this letter provides written follow-up notification of an exceedance of the notification and action levels for PCB concentrations in ambient air at the Silver Lake Area, which occurred on April 24-25, 2013.

The results of the 24-hour PCB air monitoring event conducted on April 24-25, 2013 were received by GE in the afternoon of April 30, 2013. These results are summarized in the attached table, and the locations of the monitoring stations sampled during that event are illustrated on the attached figure. These results show an exceedance of the PCB action level (0.1 ug/m3) at Station SL-3 and an exceedance of the PCB notification level (0.05 ug/m3) at Stations SL-1 and SL-4 as well as a co-located monitor (SL-4CO). The three locations sampled during the April 24-25, 2013 monitoring event were all downwind of the debris removal activities being performed during that time period, as well as downwind from a debris staging area located near the Fourth Street outfall. It should be noted that there were no exceedances of the particulate matter notification level at any location.

Upon receipt of these PCB data, GE immediately ceased construction activities at the site (i.e., excavation, backfill placement, debris removal) and subsequently provided verbal notice to the U.S. Environmental Protection Agency (EPA), as required, as well as the Massachusetts Department of Environmental Protection (MDEP). Based on discussions with EPA and MDEP, GE proposes to implement the following additional engineering controls:

• Limit the amount of debris stockpiled at the staging area located near the Fourth Street outfall, and minimize the time before that debris is transported to Building 65. I f possible the material will be directly loaded from the debris scows into a transport truck for transport to Building 65. I f the material cannot be directly loaded into trucks from the scows (due to machine limitations), it will be off-loaded to the staging area and then loaded onto trucks shortly thereafter for transport to Building 65.

• Cover stockpiled debris with polyethylene at all times when the stockpile is not actively being unloaded or loaded.

CorpOfute Ef'^ironmentcl Pi "^rcr rs

Dave Dickerson May 1,2013 Page 2 of2

• Apply Rusmar AC-645 foam suppressant on the debris materials temporarily staged on the barge as it is being loaded at the various debris removal targets. Rusmar AC-645 is biodegradable and non-hazardous - see attached product data sheet and Material Safety Data Sheet (MSDS).

• Deploy an additional silt curtain/boom at the debris removal barge operation.

• Perform additional observations for evidence of sheen and/or debris surfacing outside of the silt curtain/boom system.

• Spray BioSolve® on the water surface, as needed based on visual observation of sheens around the debris removal barge operation. BioSolve® is biodegradable and non-hazardous - see attached MSDS.

GE proposes to resume backfill placement activities on May 1, and to resume excavation and debris removal activities on May 2. GE will conduct four additional back-to-back 24-hour PCB air monitoring events as excavation and debris removal activities are again initiated - one on May 2-3, one on May 3-4, one on May 6-7, and one on May 7-8. I f the data from any of these events show an exceedance of the PCB notification or action level, GE will report the results to EPA immediately upon receipt of the data and will follow the other steps specified in the Revised Scope of Work for air monitoring. Specifically, i f the data show an exceedance of the notification level, GE will discuss with EPA appropriate additional activities to undertake based on those results; and i f the data show an exceedance of the action level, GE will cease the ongoing excavation, debris removal, or other construction activities and will discuss with EPA appropriate response actions.

If the data from all of these additional events show no exceedances of the PCB notification level, GE will resume monthly PCB air monitoring in accordance with the Revised Scope of Work for air monitoring.

Please contact me i f you have any questions.

Sincerely yours,

Richard W. Gates Remediation Project Manager

Attachments

cc: Dean Tagliaferro, EPA Holly Inglis, EPA Tim Conway, EPA* Rose Howell, EPA (electronic copy) Robert Leitch, USACE (electronic copy) Linda Palmieri, Weston Solutions (2 hard

copies + electronic copy) John Ziegler, MDEP (2 hard copies +

electronic copy) Michael Gorski, MDEP (electronic copy) Eva Tor, MDEP (electronic copy) Mayor Daniel Bianchi, City of Pittsfield*

Corydon Thurston, Executive Director, PEDA Rod McLaren, GE* Andrew Silfer, GE James Bieke, Sidley Austin LLP Mark Gravelding, ARCADIS Todd Cridge, ARCADIS Public Information Repositories GE Internal Repositories

* without attachments

V\arc3dis-us.com\OfficeDala\Syracuse-NY\CiE\GE_Silver_Lakc\Reports and Presentations\2013-04-0] air 1'CB e,\ceedance\0991311214_SL air ecxecd lerier.doc

AMBIENT AIR PCB DATA RECEIVED APRIL 30, 2013

PCB AMBIENT AIR CONCENTRATIONS SILVER LAKE

GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS

Sampling Event Period

Field Blank (ug/PUF)

SL-1

(ug/m5)

SL-3 (ug/m3)

SL-4

(ug/m3)

SL-4CO (colocated)

(ug/m3)

Background BK-5

(ug/m3)

04/24/13-04/25/13 ND (<0.10) 0.06151 0.10431 0.07871 0.07981 0.0017

Notification Level 0.05 0.05 005 005 0.05 0.05

Action Level 0.10 0.10 0.10 0.10 0 10 0 10

Notes: ND - Non-Detect 1. Represents an exceedance of the notification level. 2. Represents an exceedance of the action level.

G:\GE\GE_Silver_Lake\Repor1s and Presentations\2013-04-01 air PCB exceedance\

0991311214_April 2013 PCB Results - Silver Lake xlsx Page 1 of 1 5/1/2013

Monitoring Location SL-3

Air Monitoring Locations for PCB Event April 24-25, 2013

LEGEND:

REMOVAL ACTION AREA BOUNDARY

APPROXIMATE PROPERTY LINE

•.»>-. PROPERTY ID

— SURFACE ELEVATION (1-FT CONTOUR)

EDGE OF BUSHES

GUARDRAIL

WIRE FENCE

CHAIN LINK FENCE

DECIDUOUS TREE

CONIFEROUS TREE

OVERHEAD WIRES

<fy> UTILITY POLE

» SIGN

PAVED AREAS

- — MEAN WATER ELEV. (975.9) (APPROX.)

1 - FOOT REMOVAL

2 - FOOT REMOVAL

3 - FOOT REMOVAL

5 - FOOT REMOVAL

6 - FOOT REMOVAL

7 - FOOT REMOVAL

8 - FOOT REMOVAL

9 - FOOT REMOVAL

11-FOOT REMOVAL

3-FOOT REMOVAL

15—FOOT REMOVAL

PROPOSED AIR MONITORING LOCATION

GRAPHIC SCALE

BASE MAP INFORMATION ADJACENT TO SILVER LAKE MODIFIED FROM ELECTRONIC FILE OF SURVEY PERFORMED BY HILL ENGINEERS, ARCHITECTS AND PLANNERS IN 2006 AND 2008. OTHER BASE MAP INFORMATION PHOTOGRAMMETRICALLY MAPPED FROM APRIL 1990 AERIAL PHOTOGRAPHS.

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

REMOVAL ACTION AREA BOUNDARY AT WATER EDGE IS REPRESENTED BY THE APPROXIMATE MEAN WATER SURFACE ELEVATION (975.9).

AIR MONITORING LOCATIONS ARE APPROXIMATE. ACTUAL LOCATIONS TO BE DETERMINED IN THE FIELD BY BERKSHIRE ENVIRONMENTAL CONSULTANTS. INC.

GENERAL ELECTRIC COMPANY PITTSFIELD, MASSACHUSETTS

REVISED FINAL RD/RA WORK PLAN SILVER LAKE AREA

AIR MONITORING LOCATIONS

ft ARCADIS FIGURE

N-1

Superior performance through quality engineering, manufacturing and service

PRODUCT DATASHEET

LONG DURATION FOAM AC-645

GENERAL DESCRIPTION

AC-645 Long Duration Foam is a patented product which produces a thick, long-lasting,

viscous foam barrier for immediate control of dust, odors and volatile organic compounds

(VOCs). AC-645 is designed for use with Rusmar Pneumatic Foam Units.

AC-645 foam is recognized by the Environmental Protection Agency and the U.S. Army

Corps of Engineers as providing superior emission control for a period up to 17 hours.

AC-645 has been specified for use at Superfund and other hazardous waste sites across

the United States and Canada.

FEATURES

• Biodegradable

• Will not add to treatment costs

• No ambient temperature limitations

• Easy to use

• More effective than tarps

• Non-reactive

• Non-hazardous

• Safe for workers and the environment

• Requires only water dilution

• No clean up necessary

• Non-combustible

• Covers any contamination source

APPLICATIONS

The primary application for AC-645 is control of odors, VOCs and dust during active

excavation and for overnight coverage of contaminated soils at hazardous waste sites.

AC-645 can also be applied on top of liquid surfaces.

SPECIAL ODOR CONTROL PROBLEMS

The remediation of hazardous waste sites often includes excavation of soil contaminated

with odorous compounds. AC-645 has little or no odor itself, although a pleasant

wintergreen or vanilla scent can be added. It forms a barrier between contaminants

and the atmosphere and can be applied during active excavation to provide an immediate

and effective barrier to minimize odors. It is completely biodegradable and poses no

threat to workers, neighboring residents or ground water. AC-645 wi l l not add to

soil volume or treatment costs.

Page 1 of 2

RUSMAR INCORPORATED • 216 Garfield Avenue • West Chester, PA 19380 Toll Free: 1.800.SEE.FOAM • P: 610.436.43U • F: 610.436.8436 • www.rusmarinc.com

Superior performance through quality engineering, manufacturing and service

LONG DURATION FOAM AC-645 PRODUCT DATA SHEET

AC-645 can also be applied on top of trucks for emission control during transport of

materials such as contaminated soils or sewage sludge. Ammonia tests performed on

trucks containing sewage sludge resulted in a drop of concentration levels from

170 ppm prior to foaming down to 6 ppm after coverage with AC-645.

• Minimizes worker exposure

• Maintains fence-line odor and VOC emission limits

• Works on lagoon and pond closures

• Can be applied to near vertical or liquid surfaces

FUGITIVE DUST

At hazardous waste sites, fugitive dust can present a health hazard. AC-645 can be

applied on top of the dusty material to prevent any wind-borne emissions. There is no

need to mobilize equipment to immediately cover with soil or tarps. The Pneumatic

Foam Unit can be filled and placed at the site to be used at a moment's notice.

EMERGENCY SPILL CLEAN UP

In emergency spills, odor and VOC control is often difficult because of the terrain and

accident conditions. AC-645 Long Duration Foam can be applied to any shaped object,

as well as steep slopes, water, mud, snow and ice. It is non-flammable and

non-reactive - difficult spil l problems can be accommodated.

METHOD OF APPLICATION

AC-645 Long Duration Foam is supplied in either 450 pound (55 gal.) drums or by bulk

load (approximately 46,000 pounds). Bulk shipments can be stored outside in a Rusmar

Bulk Storage-Dilution System. The Bulk Storage and Dilution system is comprised of a

7000 gallon heated and stirred chemical storage tank and a microprocessor to accurately

dilute and transfer the chemical. AC-645 is designed to be applied with a Rusmar

Pneumatic Foam Unit. The Pneumatic Foam Units are available in a variety of sizes

to accommodate a range of site conditions and application needs.

Page 2 of 2

RUSMAR INCORPORATED • 216 Garfield Avenue • West Chester, PA 19380

Toll Free: 1.800.SEE.FOAM • P: 610.436.4314 * F: 610.436.8436 • www.rusmarinc.com

Superior performance through quality engineering, manufacturing and service

MATERIAL SAFETY DATA SHEET

LONG DURATION FOAM AC

SECTION I: GENERAL INFORMATION

• Manufacturers Name: RUSMAR INCORPORATED

• Manufacturer's Address: 216 Garfield Avenue • West Chester, PA 19380

• Manufacturer's Phone No.: 610-436-4314

• Chemical Family: Aqueous anionic surfactant mixture

• Trade Name: RUSMAR AC-645

SECTION II: HAZARDOUS INGREDIENTS

• Paints, Preservatives, and Solvents - None

• Alloys and Metallic Coatings - None

• Hazardous Mixtures and Other Materials - None

SECTION III: PHYSICAL DATA

• Boiling Point: 100° C • Specific Gravity: 1.01 to 1.06

• Vapor Pressure: 25mm Hg at 25° C • % Volatile, By Volume: None

• Vapor Density (Air = 1): N/A • Evaporation Rate: N/A

• Water Solubility: Complete

• Appearance/Odor: Translucent, white, milk-like, odorless, viscous liquid

SECTION IV: FIRE AND EXPLOSION HAZARD DATA

• Flash Point (Method): Nonflammable

• Flammable Limits: N/A

• Extinguishing Media: N/A

• Special Fire Fighting Procedures: None

• Unusual Fire and/or Explosion Hazards: None

SECTION V: HEALTH HAZARD DATA

• Threshold Limit Value: Not Determined

• Effects of Overexposure: This material is not expected to present an inhalation

or ingestion hazard. It may cause an eye or skin irritation upon direct contact.

• Emergency and First Aid Procedures: Wash thoroughly with clean water

Page 1 of 2

RUSMAR INCORPORATED • 216 Garfield Avenue • West Chester, PA 19380

Toll Free: 1.800.SEE.FOAM • P: 610.436.4314 • F: 610.436.8436 • www.rusmarinc.com

Superior performance through quality engineering, manufacturing and service

MATERIAL SAFETY DATA SHEET

imXJ INvJ DURATION FOAM AC-645

SECTION VI: REACTIVITY DATA

• Material is stable

• No material incompatibility

• Hazardous Decomposition Products: Low levels of sulfur oxides on exposure to

high temperatures (concentrate). Foam is non-combustible.

• Polymerization will not occur

SECTION VII: SPILL OR LEAK PROCEDURES

• Steps to be taken in case material is released or spilled: If spilled indoors on a

hard surface, the spill area may be slippery and should be thoroughly washed with

water. Contain spill and absorb material with dirt or other appropriate absorbent.

• Waste Disposal Method: This material is completely biodegradable and can be

disposed of in a sanitary landfill according to local regulations.

SECTION VIII: SPECIAL PROTECTION INFORMATION

• Respiratory Protection: None required for normal operations

• Ventilation: No special requirements

• Protective Gloves: Not required, but recommended

• Eye Protection: Not required, but recommended

• Other Protective Equipment: None

SECTION IX: SPECIAL PRECAUTIONS

• Storing/Handling Precautions: Avoid excessive heat. Material wil l freeze,

but thawing wil l not cause changes in the product.

• Other Precautions: None

Page 2 of 2

RUSMAR INCORPORATED • 216 Garfield Avenue • West Chester, PA 19380 Toll Free: 1.800.SEE.FOAM • P: 610.436.4314 • F: 610.436.8436 • www.rusmarinc.com

MATERIAL SAFETY DATA SHEET THE BIOSOLVE COMPANY

329 Massachusetts Avenue Lexington, Massachusetts 02420 USA

Phone: +1 (781) 482-7900 Fax: +1 (781) 482-7909 Emergency Phone-24 Hours: +1 (800) 225-3909

Ref. No.: Date:

2001 7/26/2010

E-Mail: info@biosolve.com Web Site: www.biosolve.com

SECTION I - IDENTITY

Name: CAS #: Formula: Chemical Family: HMIS Code: HMIS Key:

BioSolve® 138757-63-8 Proprietary Water Based, Biodegradable, Wetting Agents & Surfactants Health 1, Fire 0, Reactivity 0 4 = Extreme, 3 = High, 2 = Moderate, 1 = Slight, 0 = Insignificant

SECTION II - HAZARDOUS INGREDIENTS

Massachusetts Right to Know Law or 29 C.F.R. (Code of Federal Regulations) 1910.1000 require listing of hazardous ingredients.

This product does not contain any hazardous ingredients as defined by CERCLA, Massachusetts Right to Know Law and California's Prop. 65.

DOT Class: Not Regulated/Non Hazardous

SECTION III - PHYSICAL - CHEMICAL CHARACTERISTICS

Boiling Point 265°F Specific Gravity 1.00+/-.01 Melting Point 32°F Vapor Pressure mm/Hg Not Applicable Surface Tension- 6% Solution

29.1 Dyne/cm at25°C Vapor Density Air = 1 Not Applicable

Reactivity with Water No Viscosity - Concentrate 490 Centipoise Evaporation Rate >1 as compared to Water Viscosity - 6% Solution 15 Centipoise Appearance Clear Liquid unless Dyed Solubility in Water Complete Odor Pleasant Fragrance Til 9.1+/-.3 Pounds per Gallon 8.38

SECTION IV - FIRE AND EXPLOSION DATA

Special Fire Fighting Procedures : None Unusual Fire and Explosion Hazards : None Solvent for Clean-Up : Water Flash Point : None

Flammable Limit Auto Ignite Temperature Fire Extinguisher Media

: None : None : Not Applicable

PAGE 1 OF 2

* Date:7/l/20i0 MSDS Ref. No. 2001 BioSolve'

SECTION V - SPECIAL PRECAUTIONS AND S P I L L / L E A K PROCEDURES

Precautions to be taken in Handling and Storage: Use good normal hygiene. Precautions to be taken in case of Spill or Leak -

Small spills, in an undiluted form, contain. Soak up with absorbent materials. Large spills, in an undiluted form, dike and contain. Remove with vacuum truck or pump to storage/salvage vessel. Soak up residue with absorbent materials.

Waste Disposal Procedures -Dispose in an approved disposal area or in a manner which complies with all local, provincial, and federal regulations.

SECTION VI - H E A L T H HAZARDS

Threshold Limit Values: Not applicable Signs and Symptoms of Over Exposure-

Acute : Moderate eye irritation. Skin: Causes redness, edema, drying of skin. Chronic: Pre-existing skin and eye disorders may be aggravated by contact with this product.

Medical Conditions Generally Aggravated by Exposure: Unknown Carcinogen: No Emergency First Aid Procedures -

Eyes: Flush thoroughly with water for 15 minutes. Get medical attention. Skin: Remove contaminated clothing. Wash exposed areas with soap and water.

Wash clothing before reuse. Get medical attention i f irritation develops. Ingestion: Get medical attention. Inhalation: None considered necessary.

SECTION VII - SPECIAL PROTECTION INFORMATION

Respiratory Protection : Not necessary Local Exhaust Required : No, except in confined space as required.

Ventilation : Normal Protective Clothing : Neoprene or other chemical Required resistant gloves, safety goggles

or chemical face shield. Wash clothing before reuse.

WHEN UTILIZED IN CONFINED SPACE OPERA TIONS, ADDITIONAL PPE MAYBE REQUIRED AS PER OSHA GUIDELINES.

SECTION VIII - PHYSICAL HAZARDS

Stability : Stable Incompatible Substances : None Known Polymerization : No Hazardous Decomposition Products : None Known

SECTION IX - TRANSPORT & STORAGE

DOT Class : Not Regulated/Non Hazardous Freeze Temperature : 28°F Storage : 35°F-120°F Freeze Harm : None (thaw & stir) Shelf Life : Unlimited Unopened

SECTION X - R E G U L A T O R Y INFORMATION

The Information on this Material Safety Data Sheet reflects the latest information and data that we have on hazards, properties, and handling of this product under the recommended conditions of use. Any use of this product or method of application, which is not described on the Product label or in this Material Safety Data Sheet, is the sole responsibility of the user. This Material Safety Data Sheet was prepared to comply with the OSHA Hazardous Communication Regulation and Massachusetts Right to Know Law.

PAGE 2 OF 2