Transmitted Via Overnight Courier · The approximate location of this item is shown (by reference to the corresponding letter and number on the inspection form) on Figure 3. Photographs

GE Corporate

159 Plastics Avenue Pittsfield, MA 01201 USA

Transmitted Via Overnight Courier

August 13, 2014

Mr. Richard Fisher (Mail Code OSRR07-1) U.S. Environmental Protection Agency 5 Post Office Square - Suite 100 Boston, Massachusetts 02114-2023

Re: GE-Pittsfield/Housatonic River Site Building 71 and Hill 78 On-Plant Consolidation Areas (GECD210 & GECD220) Summary of Unscheduled Inspection Activities in July 2014

Dear Mr. Fisher:

This letter describes and presents the results of inspection activities that were conducted on behalf of the General Electric Company (GE) at the Building 71 and Hill 78 On-Plant Consolidation Areas (OPCAs) in July 2014 apart from the regularly scheduled semi-annual inspections. This inspection was conducted in accordance with the requirements set forth in GE's Revised Post-Removal Site Control Plan for Hill 78 and Building 71 On-Plant Consolidation Areas (Revised PRSC Plan), which was submitted to the U.S. Environmental Protection Agency (EPA) on January 6, 2011, conditionally approved by EPA on June 2, 2011, and then revised and re-submitted in final form as Attachment H to GE's Final Completion Report - On-Plant Consolidation Areas on September 15, 2011. That plan requires that, in addition to the regularly scheduled semi-annual inspections, the OPCAs must be inspected following severe storm events to ensure that they have not sustained significant damage. For this purpose, a severe storm event includes a rain event with total precipitation exceeding 3 inches over a 24-hour period.

The inspection activities covered by this letter and actions taken or proposed in response to those activities are described below. OPCA components subject to inspection are shown on Figure 1, the tree planning plan for the OPCAs is shown on Figure 2, and maintenance/repair items identified during this inspection are shown on Figure 3. An inspection checklist is provided in Attachment A, and photographs taken during the inspection are provided in Attachment B.

Post-Storm Inspection Observations

On July 15, 2014, due to a rain event with total precipitation exceeding 3 inches over a 24-hour period on June 25, 2014, GE and EPA conducted an inspection of the Building 71 and Hill 78 OCPAs. This inspection included visual observations of the Building 71 and Hill 78 OPCAs to identify any damage to the final cover and associated components as a result of the rain event and to identify any items needing maintenance. The OPCA final cover areas were visually inspected to determine the presence of any of the following conditions:

Mr. Richard Fisher August 13, 2014

Page 2 of4

• Areas void of vegetation or exposed geosynthetic final cover components;

• Evidence of topsoil or other erosion;

• Evidence of sparse or stressed vegetation;

• Evidence of tree or shrub growth or other undesirable vegetative growth;

• Evidence of burrowing animals;

• Evidence of damage to the geosynthetic final cover components;

• Evidence of uneven surface settlement;

• Evidence of ponding water conditions;

• Evidence of excessive wheel rutting;

• Undesirable slope conditions (i.e., non-conducive to proper drainage);

• Adequacy of cover system drainage layer outlet pipes (8 locations);

• Evidence of soil movement or slope instability; and

• Evidence of unauthorized excavations.

In addition to inspecting the final cover for the conditions listed above, the July 15, 20 14 inspection included observations of the following associated components (including the specific items listed for each of these components in the attached inspection form for this inspection and shown on Figure 1):

• Paved site access roads (including the portion of the access road south of the Hill 78 OPCA which EPA has required, and GE has agreed, to be maintained as paved);

• The Building 71 and Hill 78 OPCA final cover access roads;

• Perimeter fencing and access gates;

• Surface water drainage system, including the North and South Stormwater Basins and the other drainage features listed in the attached inspection form and shown on Figure 1;

• Perimeter vegetation, including tree plantings; and

• Any significant erosion anywhere within the OPCA Removal Action Areas.1

The July 15, 2014 inspection also included an inspection of trees planted in the Perimeter Vegetated Area (shown on Figure 1) and other areas around the OPCAs, including the trees planted in April2010 as part of the Tree Planting Plan (as shown on Figure 2), to assess their survival, growth, and condition, and whether they are providing a visual barrier between the OPCAs and the surrounding community.2 In addition, the herbaceous vegetation planted in the Perimeter Vegetated Area was inspected for: (a) evidence of topsoil erosion or excessive soil erosion; (b) establishment and coverage of vegetation (e.g., bare or sparsely vegetated areas or stressed vegetation); and (c) any drainage or growth problems.

1 The leachate handling system was not inspected during the July 15, 2014 post-storm inspection. In accordance with Section 3.1.4 of the final Revised PRSC Plan, if any of the trees are observed to be dead or

dying, GE is to evaluate whether such lost trees are adversely affecting the visual barrier between the OPCAs and the surrounding community, and make a proposal as to whether those trees need to be replaced to maintain the visual barrier.

G:\GE\GE_Pittsfield_CD_OPCAs\Reports and Prescntations\Inspections\Unscheduled\Summcr 20 l4\23814Il324LtrRpt.doc

2


Page 3 of 4

The results of the July 15, 2014 inspection were recorded on the inspection form in Attachment A In general, this inspection indicated that the final cover areas and other components of the OPCAs were in good overall condition. As shown in Section II and summarized in Section III of the inspection fonn, one item was noted for follow-up maintenance. This item was the observation of one woodchuck burrow hole in the Hill 78 OPCA cover. The approximate location of this item is shown (by reference to the corresponding letter and number on the inspection form) on Figure 3. Photographs taken during this inspection are included in Attachment B.

As noted in Section V of the inspection form for this inspection, it could not be confirmed that the Cypress spurge had been sprayed with Roundup in areas where it was observed in a prior inspection. GE will inspect this response action during the next regularly scheduled post-closure inspection.

As noted in Section N of the applicable inspection checklist form in Attachment A, the woodchuck burrow hole observed during this inspection should be filled, seeded, and mulched. In accordance with Section 3.1.6 of the final Revised PRSC Plan, GE will perform this corrective measure after being approved or deemed approved by EPA In the event that GE does not receive notice otherwise from EPA within 15 days after submission of this inspection report, these proposed measures will be deemed approved by EPA and will be conducted within 45 days from the submission of this report.

Schedule for Future Inspections

In accordance with the applicable requirements of the final Revised PRSC Plan, post-closure inspections of the Building 71 and Hill 78 OPCAs are to be performed twice per year to assess the integrity of the final cover and associated components. The next regularly scheduled post-closure inspection will be performed during August or September 2014. In addition, GE will continue to conduct OPCA inspections after severe storm events (as defined in the final Revised PRSC Plan). The inspections will continue until GE proposes, and EPA approves, a modification or termination of such inspections.

Future inspections will be conducted in accordance with the final Revised PRSC Plan. Following each such inspection, a report will be submitted to EPA within 30 days of the inspection, which will include a summary of the status of the maintenance activities identified during the prior inspection, a completed inspection checklist (using the form included in the final Revised PRSC Plan), and a proposal for any necessary repair or replacement activities. Those repair or replacement activities will be conducted within the time periods specified in Section 3.1.6 of the final Revised PRSC Plan.

Please call me if you have any comments or questions.

Sincerely,

~W.~/Slie Richard W. Gates Senior Project Manager- Environmental Remediation

Attachments

G:\GE\GE_Pittsfield_CD _OPCA:.\Rcports and Presentations\InspocliOns\Unscllcdulcd :.utmncr 2014\231)1411324LII'Rpt.doc


Page 4 of 4

cc: Dean Tagliaferro, EPA John Kilborn, EPA Christopher Ferry, ASRC Primus (electronic copy) Robert Leitch, USACE Michael Gorski, MDEP* Eva Tor, MDEP* John Ziegler, MDEP (2 copies) Linda Palmieri, Weston (2 copies) Nancy E. Harper, MA AG* Karen Pelto, MDEP Corydon L. Thurston, Executive Director, PEDA Doug Clark, Director, Pittsfield Dept. of Community Development (electronic copy) Gina Armstrong, Pittsfield Health Department Roderic McLaren, GE* Peter Wojcik, GE* James Nuss, ARCADIS James Bieke, Sidley Austin Public Information Repositories GE Internal Repository

*cover letter only

G:\GE\GE_Pittsfield_CD_OPCAs\Reports and Presentations\Inspections\Unscheduled\Summer 20 14\2381411324LtrRpt.doc

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OPCA COMPONENTS SUBJECT TO POST-CLOSURE INSPECTION

GENERAL ELECTRIC COMPANY PITTSFIELD, MASSACHUSETTS

HILL 78 AND BUILDING 71 OPCAs

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TREE PLANTING AREA

NUMBER AND TYPE OF TREES TREE SPACING REQUIREMENTS HEIGHT (FT.) AT TIME OF

INSTALLATION

1 17 - NORWAY SPRUCE 10 FT. ON CENTER, 8 FT. OFF FENCE LINE TO CENTER OF TREE 4 - 5 FT.

2 7 - NORWAY SPRUCE a 10 FT. ON CENTER, 8 FT. OFF FENCE LINE TO CENTER OF TREE 4 - 5 FT.





7 7 - SUGAR MAPLES 8 FT. OFF FENCE LINE, SPACED BETWEEN EXISTING NORWAY SPRUCE 3 - 3 1/2 IN. CAL.

8 3 - RED MAPLES b 35 FT. (MIN.) OFF STEAM LINE 2 1/2 - 3 IN. CAL.

9 2 - SUGAR MAPLES, 3 - NORWAY SPRUCE

35 FT. (MIN.) OFF STEAM LINE, EVENLY SPACED

2 1/2 - 3 IN. CAL., 8 - 10 FT.

10 - - c - - - -

REPLANTED TREES

TREE PLANTING AREA

NUMBER AND TYPE OF TREES INSTALLATION DATE HEIGHT (FT.) AT TIME OF

INSTALLATION

3 - WHITE PINEa NOVEMBER 2011 7 FT.

1 - WHITE PINE NOVEMBER 2012 7 FT.

2 - WHITE PINE NOVEMBER 2011 8 FT.



FIGURE

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JULY 15, 2014 INSPECTION

FIGURE

3

Attachment A

Inspection Checklist

GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS BUILDING 71 AND HILL 78 ON-PLANT CONSOLIDATION AREAS (OPCAs)

INSPECTION FORM

I. Inspection Information

Inspection Date: Weather Conditions: Overcast, 75° F

Inspection Area: Building 71 OPCA/Hill 78 OPCAs and Select Ancillary Site Components

Performed by: Gregg Rabasco (ARCADIS) Phone Number: (413) 822-1184 E-mail address: [email protected]

Thomas Czelusniak (Weston Solutions, Inc.)

Time Arrived: 9:00 AM Time Departed: 12:00 PM

Date of Prior Inspection:

Check to confirm that Figure 2 of the Revised Post-Removal Site Control Plan (including revisions to that figure) was reviewed in the field during the inspection: ___X___

July 15, 2014

May 15, 2014

II. Observations

A. Site Access Road

1. Is there excessive cracking, potholes, visible fissures, or spalling?

2. Are the subbase materials exposed in an unsatisfactory manner?

3. Is there evidence of depressions and/or surface water ponding?

4. Is there evidence of excessive rutting?

B. Final Cover Access Road

1. Is there excessive erosion or rutting of road surface?

2. Is there undesirable vegetative growth?

C. Site Security

1. Are the access gates and locks in operating condition?

2. Is the perimeter fence in satisfactory condition (i.e., in proper position, adequately secured to fence posts, etc.)?

3. Are the posted signs on the perimeter fence securely attached to fence and visible?

D. Final Cover System

1. Are there bare spots (void of vegetation) or areas of sparse vegetation?

2. Is there evidence of stressed vegetation?

3. Are there exposed geosynthetic cover components?

4. Is there evidence of topsoil erosion or other excessive erosion?

5. Is there evidence of tree or shrub growth or other undesirable vegetative growth?

6. Is there visible evidence of damage to the geosynthetic cover components?

7. Is there evidence of burrowing animals?

8. Is there evidence of uneven settlement?

9. Is there evidence of ponding water conditions?

10. Is there evidence of excessive wheel rutting?

11. Are the slopes adequate for surface water drainage?

12. Are the cover system drainage layer outlet pipes (anchor trench and final cover) at all fourteen locations visible and free of obstructions?

13. Is there evidence of soil movement or slope instability (e.g., cracks in the soil cover running parallel to the slope or soil sloughing)?

14. Is there evidence of unauthorized excavations?

E.

1.

b.

c.

d. e.

2. Does established vegetation in the OPCA mid-slope swales and perimeter drainage ditches provide adequate erosion protection?

3.

F. Leachate Handling System NOT INSPECTED

1. Is the leachate collection/pump manhole (wet well) in satisfactory condition?

2.

3. Are the pumps on the wet well in operating condition?

4. Have the float levels on the wet well been tested?

5. Are the float levels on the wet well in operating condition?

6. Is the high-level alarm on the wet well functional?

7. Is the leak detection alarm on the wet well functional?

8. Are the leachate transfer pipes in satisfactory condition?

9. Are the leachate holding tanks in satisfactory condition?

10. Is the high-level alarm on each leachate holding tank functional?

11. Is the leak detection alarm on each leachate holding tank functional?

12. Has the auto dialer warning system for the two holding tanks and the wet well been tested?

13. Is the auto dialer warning system in operating condition?

The full length of the eastern riprap swale located south of the Hill 78 OPCA, the associated detention basin, and the opening for the culvert conveying stormwater under old Merrill Road?

The entire length of the OPCA mid-slope drainage swales and perimeter drainage ditches, including inlets and outlets for the seven drainage culverts associated with these drainage swales and perimeter drainage ditches?

The riprap surrounding the stormwater manhole at the northwest corner of the Hill 78 OPCA?

Have the pumps on the wet well been tested?

Surface Water Drainage System (Including all features/components conveying stormwater from the vicinity of the OPCAs through culvert under old Merrill Road)

Are the following elements of the surface water drainage system visible and free of excessive sediment, debris buildup, blockages, and damage:

The outlet of the south stormwater basin, the outlet of the pipe that conveys water from that basin to the drainage ditch, and the full length of the drainage ditch that discharges into the eastern riprap swale located south of the Hill 78 OPCA?

Are there bare spots (i.e., areas void of vegetation) or excessive erosion on stormwater basin berm slopes?

a.

The outlet of the drain from the General Dynamics parking lot that conveys stormwater to the north stormwater basin and the outlet (i.e., riprap forebay and concrete manhole) from that basin?

Column A

No

No

No

No

No

No

Yes

Yes

Yes

No

No

No

No

No

No

No

No

No

No

Yes

Yes

No

No

Yes

Yes

Yes

No

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Column B

Yes

Yes

Yes

Yes

Yes

Yes

No

No

No

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

No

Yes

Yes

No

No

No

Yes

No

No

No

No

No

No

No

No

No

No

No

No

No

No

No

No

Page 1 of 2

G:\GE\GE_Pittsfield_CD_OPCAs\Reports and Presentations\Inspections\Unscheduled\Summer 2014\ 2381411324AttaACklst.xlsx

GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS BUILDING 71 AND HILL 78 ON-PLANT CONSOLIDATION AREAS (OPCAs)

INSPECTION FORM

G. Perimeter Vegetation and Tree Plantings

1. Are there bare spots (void of vegetation) or areas of sparse vegetation in the Perimeter Vegetated Area? No Yes

2. Is there evidence of stressed vegetation in the Perimeter Vegetated Area? No Yes

3. Is there evidence of topsoil erosion or other excessive erosion in the Perimeter Vegetated Area? No Yes

4. Is there any evidence of drainage problems in the Perimeter Vegetated Area? No Yes

5.

6.

7. Is there evidence of undesirable vegetative growth affecting any of the planted trees around the OPCAs? No Yes

8. Is there trash or debris in the Perimeter Vegetated Area or along the north side of Tyler Street Extension? No Yes

H. Other

1. Was any significant erosion observed anywhere within the OPCA Removal Action Areas? No Yes

2. Are there any additional conditions observed during the inspection that require attention? No Yes

Yes

Yes

No

No

Are any dead or dying trees in the Perimeter Vegetated Area or any other area around the OPCAs adversely affecting the visual barrier between the OPCAs and the surrounding community?

Is there evidence that any trees planted in the Perimeter Vegetated Area or other areas around the OPCAs are dead, dying, or stressed (during applicable monitoring period)?

III. Inspection Observations

Describe observations from Column B in Section II. Use additional pages if necessary. D7. One woodchuck burrow hole was observed on the north toe of the Hill 78 OPCA.

IV. Inspection Response Actions

Describe response actions to be conducted for each observation noted in Section III above. Use additional pages if necessary. D7. Fill the burrow hole with topsoil, and seed and mulch, as necessary. Burrowing animals will continue to be removed from the OPCAs and the burrow holes filled with topsoil, seeded and

mulched, as needed.

1. The vegetation was too high to observe if the Cypress spurge had been sprayed with Roundup in areas where it was observed on the Hill 78 OPCA.

2. The burrowing animals continued to be removed from the OPCAs and the burrow holes were filled with topsoil, seeded and mulched, as needed.

Describe response actions conducted to address prior maintenance needs.

V. Prior Inspections

None

VI. Other Observations

Page 2 of 2

G:\GE\GE_Pittsfield_CD_OPCAs\Reports and Presentations\Inspections\Unscheduled\Summer 2014\ 2381411324AttaACklst.xlsx

Attachment B

Site Photographs

INSERT PHOTO HERE

INSERT PHOTO HERE

Client: General Electric Company

Project Location: Pittsfield, Massachusetts

Photo #1: View of the Building 71 and Hill 78 OPCA plateau (photo direction East).

Photo #2: View of the Building 71 OPCA (photo direction North).

Project Name: Building 71 and Hill 78 OPCAs

G:\GE\GE_Pittsfield_CD_OPCAs\Reports and Presentations\Inspections\Unscheduled\Summer 2014\ 2381411324AttaBPhotoLog.xlsx

INSERT PHOTO HERE

INSERT PHOTO HERE

Client: General Electric Company Project Name: Building 71 and Hill 78 OPCAs Project Location: Pittsfield, Massachusetts

Photo #3: View of the Building 71 OPCA and South Stormwater Basin (photo direction East).

Photo #4: View of the Building 71 OPCA (photo direction Southeast).


INSERT PHOTO HERE

INSERT PHOTO HERE


Photo #5: View of the North Stormwater Basin and Building 71 OPCA northern sideslope (photo direction East).

Photo #6: View of the Building 71 OPCA mid-slope swale forebay and the North Stormwater Basin (photo direction North).


INSERT PHOTO HERE

INSERT PHOTO HERE


Photo #7: View of the Hill 78 OPCA northern sideslope (photo direction East).

Photo #8: View of the Hill 78 OPCA western sideslope and access road (photo direction East).


INSERT PHOTO HERE

INSERT PHOTO HERE


Photo #9: View of the Hill 78 OPCA western sideslope (photo direction Southeast).

Photo #10: View of the Hill 78 OPCA eastern sideslope and Building 71 OPCA southern sideslope (photo direction North).


INSERT PHOTO HERE

INSERT PHOTO HERE


Photo #11: View of the Hill 78 OPCA plateau (photo direction Southeast).

Photo #12: View of the Hill 78 OPCA plateau (photo direction Northeast).


INSERT PHOTO HERE


Photo #13: W oodchuck burrow hole.


Documents

Transmitted Via Overnight Courier · The approximate location of this item is shown (by reference to the corresponding letter and number on the inspection form) on Figure 3. Photographs