Global Operations, Environment, Health Safety · Global Operations, Environment, Health & Safety . 159 Plastics Avenue Pittsfield, MA 01201 . December 6, 2016 . Ms. Karen Pelto

Global Operations, Environment, Health & Safety

159 Plastics Avenue Pittsfield, MA 01201

December 6, 2016

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) Revised Report on Spring 2016 Inspection of Natural Resource Restoration/Enhancement

Measures

Dear Ms. Pelto:

On May 26 and 27, 2016, the General Electric Company (GE) performed the spring 2016 inspection of the natural resource restoration/enhancement (NRRE) measures at the Silver Lake Area Removal Action Area (RAA). That inspection was performed in accordance with the applicable requirements of the Restoration Project Monitoring and Maintenance (RPMM) Plan included in GE's Final Completion Report (FCR) for the Silver Lake Area Removal Action, which was submitted to the U.S. Environmental Protection Agency (EPA) on May 20, 2015 and approved by EPA on June 22, 2015. In accordance with those requirements, the May 26 and 27, 2016 inspection focused on the following restoration activities conducted at this RAA: (1) the cap placed over the shrub-scrub island; and (2) the plantings installed as part of NRRE measures. The locations of these remediation components are shown on Figure 1 (along with other aspects of the remediation and restoration that are subject to separate inspections).

GE's most recent prior inspection of the NRRE measures at this RAA had been performed in August 2015, with a revised trip report on it submitted to the natural resource trustees (Trustees), through the Lead Administrative Trustee (LAT) on March 2, 2016. That revised report incorporated comments provided by the Trustees on March 1, 2016 on the original trip report, which was submitted on October 15, 2015. A summary of all 2015 monitoring activities was also included in GE's 2015 Annual Monitoring Report, which was submitted on March 16, 2016 and conditionally approved by EPA on May 6, 2016. At EPA's request, an Addendum to the 2015 Annual Monitoring Report (consisting of two revised tables) was submitted to EPA on May 12, 2016.

GE submitted a trip report on the spring 2016 NRRE inspection to the Trustees on July 29, 2016. The Trustees provided comments on that report to GE by letter dated November 30, 2016, and requested that GE submit a revised version of that report addressing their comments. In response, GE has revised the July 29, 2016 report, and is submitting this revised report on the spring 2016 NRRE inspection. In the meantime, GE performed the summer 2016 NRRE inspection on September 8-9, 2016, and will be submitting a separate report on that inspection. 1

The inspections of non-NRRE components of the remediation at the Silver Lake Area have been performed and reported to EPA separately. The spring non-NRRE inspection was performed on May 26-27, 2016, with a report on it submitted on June 26, 2016 and conditionally approved by EPA on July 29, 2016. The summer non-NRRE inspection was performed on September 8-9, 2016, with a report on it submitted on October 7, 2016. The monitoring of the sediment cap and sediment traps was performed on September 12-13 and October 17-18, 2016, and a report on those activities was submitted to EPA on November 7, 2016.

1

Karen Pelto December 6, 2016

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Pre-Inspection Activities

As noted in GE's 2015 Annual Monitoring Report, most of the repair, maintenance, and re-seeding activities identified during the summer NRRE 2015 inspection (as described in GE's March 2, 2016 trip report) were completed following that inspection.2 In addition, on May 23, 2016, GE initiated a treatment and pest control program for northern arrowwood and nannyberry viburnum shrubs to address the potential presence of viburnum leaf beetle. Further, the initial 2016 treatment for invasive vegetative species was performed on June 8 and 9, 2016,3 and a second and final treatment of the northern arrowwood and nannyberry viburnum shrubs to control the potential presence of viburnum leaf beetle was completed June 20, 2016 {both performed after the spring 2016 NRRE inspection).

Summary of Spring 2016 Inspection and Results

The May 26-27, 2016 NRRE inspection constituted the first of the 2016 semi-annual inspections of the shrub-scrub island cap and the NRRE plantings in accordance with the RPMM Plan in the FCR. The monitoring activities were performed by Michael Long and Gregg Rabasco of Arcadis (on GE's behalf). The monitoring event was also attended by David Dickerson of EPA and lzabela Zapisek of Avatar Environmental, Inc. (on EPA's behalf), and (on May 26 only) Robin McEwan of Stantec (on behalf of the Trustees). A certified arborist was also present (on May 27 only) to support the vegetation inspections. The completed NRRE inspection checklist, with attached forms and tables, is provided in Attachment A. The inspection activities and results are summarized below, along with proposed follow-up actions. The items requiring response and the proposed follow-up actions are also summarized in Table 1.

Shrub-Scrub Island Cap Inspection

In accordance with the RPMM Plan in the FCR, the spring inspection of the shrub-scrub island cap was performed in conjunction with the non-NRRE inspection of the shoreline armor system. The inspection of the shrub-scrub island cap consisted of visual observations to identify any areas where the cap may be eroding (e.g., in areas along the edge of water that do not have armor stone) or experiencing any other conditions that could jeopardize the performance of the cap.4

The results of the summer inspection of the shrub-scrub island cap are presented in the inspection checklist in Attachment A. As indicated in that checklist, there were no areas within the scrub-shrub island cap observed to have significant erosion or other conditions that could jeopardize the performance of the cap.

NRRE Vegetation Monitoring

In accordance with the RPMM Plan in the FCR, the spring 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., stem counts) of the plantings within the specific monitoring plots established within the NRRE areas. Personnel conducting the inspection were supported by a representative from The Haupt Tree Company, Inc. as the certified arborist. The certified arborist did not participate directly in the qualitative and quantitative assessments conducted on May 26, but conducted his evaluation and made recommendations on May 27. Selected photographs of the vegetation in the NRRE areas are provided in Attachment B. It

2 That report indicated that all remaining tree stakes had been removed. However, as noted below, some additional tree stakes were observed during the May 2016 inspection and were removed. 3 As discussed further below, additional treatments of invasive species were performed on June 23, July 27, August 31, September 22 and 23, and October 26, 2016.

4 On the days of the inspection (May 26 and 27, 2016), the mean flow in the Housatonic River was approximately 37 and 34 cubic feet per second (cfs), respectively, as measured at the U.S. Geological Survey (USGS) river gage in Coitsville. However, since the last inspection of shrub-scrub island cap on August 11 , 2015, there was a two-day highflow event (i.e., estimated flow greater than 440 cfs at the Coitsville gage). Specifically, the Coitsville gage reported daily mean flows greater than 440 cfs on February 25 and 26, 2016, including a maximum daily mean flow of 1,250 cfs on February 25, 2016.

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should be noted that the 2016 growing season was abnormally dry in western Massachusetts, which may have affected findings of this vegetation inspection.

Qualitative Assessment

For the qualitative assessment, field personnel conducted a meander survey of the overall NRRE planting areas (shown on Figure 1) to observe overall conditions of the vegetation within those areas. During this qualitative assessment, as indicated in the checklist in Attachment A, no areas were noted with indications of significant damage from trespassing or herbivory. The majority of the grass along the walking path was observed to be generally well established. The areas of established grass included an area on the northeastern side of the lake within and to the east of monitoring plot 19-9-35-1 where re-seeding was performed in 2015, an area around a utility pole on Parcel 19-10-9 where erosion and sparse vegetation had been noted in 2015, and some minor, non-contiguous areas spread out in plots 19-9-35-3 and 19-9-35-4 that also had sparse cover during the summer 2015 monitoring event. However, sparse vegetation continued to be observed, as it was in 2015, on the eastern shore of the Fourth Street Outfall on Parcel 19-9-36 (Area 2 on Figure 1; Photo 1 in Attachment B). In addition, sparse vegetation was noted in the following areas: (a) in monitoring plot 19-10-9-2 near the guardrail (Area 1 on Figure 1; Photo 2 in Attachment B); (b) in monitoring plot 19-9-36-3 (Area 3 on Figure 1 ); (c) on Parcel 19-9-35 on the northeastern side of the lake within and to the east of monitoring plot 19-9-35-1 (on both the top of bank and on a portion of the bank face, where minor rilling was observed) and between monitoring plots 19-9-35-1 and -2 (Area 4 on Figure 1; Photo 3 in Attachment B); and (d) on the southeastern side of the lake within and south of monitoring plot 19-9-35-4 (Area 5 on Figure 1; Photo 4 in Attachment B).

It was determined that the areas identified with sparse vegetation at the top of bank on Parcel 19-9-35 would be re-seeded prior to the summer 2016 inspection, and that if sparse vegetation and rilling on the bank face area on Parcel 19-9-35 continue to be observed during the summer 2016 inspection, contingency actions will need to be taken to provide stabilization and herbaceous cover. For the other four areas around Silver Lake where sparse vegetation was observed, including the area on the eastern shore of the Fourth Street Outfall on Parcel 19-9-36, it was discussed in the field during the spring monitoring event that there was no indication of significant erosion or cause for immediate concern, and that the grass may continue to expand in these areas over the summer growing season. As such, no summer maintenance was recommended for these four areas. All five areas where herbaceous vegetative cover was noted as sparse were identified for re-evaluation during the summer 2016 NRRE inspection to determine if re-seeding or other maintenance may be necessary. Specifically, for the area on the eastern shore of the Fourth Street Outfall, it was determined that, if the summer 2016 monitoring continued to document poor establishment of vegetative cover, GE would place additional topsoil in this area and re-seed the area.5

For the planted trees and shrubs, the qualitative assessment indicated that the majority of the plantings appeared healthy. However, as indicated in the checklist in Attachment A, the EPA and Trustee representatives observed that certain of the 30 large trees planted along the eastern bank of Silver Lake in the 19-9-35 monitoring area would benefit from continued maintenance. In particular, they recommended that the maintenance program for the red oak trees and maple trees in that monitoring area, which had been initiated after the spring 2015 monitoring event, be continued through the remainder of the summer 2016, as appropriate. The general location of these trees is shown as Area 6 on Figure 1. As described in spring 2015 inspection report, that maintenance program includes regular watering as necessary based on existing soil conditions, pruning for sanitation and structure per 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. This program also includes a recommendation that none of these trees should be fertilized. The certified arborist for the spring 2016 inspection agreed that continuation of this maintenance program would be beneficial; and he also recommended weeding around these trees, conducting proper mulch management (including maintaining a mulch depth of no more than 2-3 inches and ensuring that the root crown is exposed and not covered with mulch or soil), and maintaining soil fertility. GE agreed to

5 GE's 2015 Annual Monitoring Report stated that this would be done if the spring 2016 inspection continued to show poor vegetative establishment. However, as explained in the text, it was discussed in the field that, since there was not an immediate erosion concern, such action was not necessary at that time and that the area would be re-evaluated during the summer 2016 inspection.

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continue the maintenance program for these trees in 2016 (as appropriate based on seasonal changes to weather), and to re-evaluate the status and health of these trees during the summer 2016 monitoring inspection.

As also indicated in the checklist in Attachment A, during this qualitative assessment, only one of the eight large black willow trees on the eastern bank of Silver Lake, outside of the monitoring plots, was observed to be alive. The apparent remnants of two dead black willows were observed, and the other five willows appeared to be missing, with no indication of what had happened to them. Additionally, the one remaining black willow on the eastern bank in monitoring area 19-9-35 and one black willow on the southwestern boundary of monitoring area 19-10-9 Uointly Area 7 on Figure 1) were observed to be exhibiting some signs of stress.6 The area of missing/dead willows and the stressed willows were slated for re-evaluation during the summer 2016 inspection.

Further, although all tree support stakes were believed to have been removed in 2015, it was observed during the qualitative assessment that some remaining tree stakes were present near the large ornamental trees along the eastern bank of Silver Lake. These tree stakes were removed and disposed of off-site.

As noted above, the first treatment of the northern arrowwood and nannyberry viburnum shrubs to control the potential presence of the viburnum leaf beetle occurred on May 23, 2016 immediately prior to the spring 2016 inspection, with the second and final treatment completed on June 20, 2016 (after the inspection). During the spring 2016 inspection, the northern arrowwood and nannyberry viburnum shrubs throughout the NRRE areas that had been observed with minor herbivory (defoliation) in 2015, suspected to have been caused by the viburnum leaf beetle, were re-evaluated . In spring 2016, only minor herbivory was observed on a few northern arrowwood and nannyberry viburnum shrubs on the northwestern shore of Silver Lake, possibly caused by the viburnum leaf beetle. It was determineq in the field that the damage was not significant enough to cause stress to the plants and that no additional treatment was needed. However, it was also determined that the status of the herbivory on these shrubs would be re-evaluated during the summer 2016 inspection.

In addition, qualitative observations were made of the areas around the periphery of the shrub-scrub island where topsoil and an herbaceous wetland species seed mix had been placed in the void spaces of the armor stone. These observations indicated that the topsoil placed in those void spaces and the herbaceous vegetation planted in that topsoil were generally well established. During the qualitative assessment, as indicated in the checklist in Attachment A, the obligate wetland plants (i.e., buttonbush and soft rush) on the shrub-scrub island were observed to be extremely stressed or dead (Area 8 on Figure 1; Photos 5 and 6 in Attachment B), which may have been due to inadequate wetland hydrology, exacerbated by the recent dry conditions. However, red-osier dogwood specimens were observed to be unaffected by the dryer conditions. The hydrology and vegetation on the shrub-scrub island were identified for re-evaluation during the summer 2016 inspection to assess the overall health of the vegetation and whether alternate species may be more appropriate if dryer conditions appear to be persistent.

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. Observed invasive species included coltsfoot, common buckthorn, cypress spurge, Japanese knotweed, multiflora rose, oriental bittersweet, phragmites (common reed), Russian olive (or Autumn olive), spotted knapweed, tatarian honeysuckle, and yellow iris. Percent coverage by invasive species within the designated monitoring plots and monitoring areas is described further under the quantitative assessment below.

In addition, the "cluster" plantings near the Fourth Street Outfall on the street side of the walking path, which had been observed by the Trustees to be overgrown with weeds in 2015, were again observed to have significant weeds during the spring 2016 monitoring event (Area 9 on Figure 1 ). These areas were weeded when the general invasive species control program was re-initiated in June 2016.

6 In addition to these black willows, the quantitative assessment discussed below showed one additional black willow, located in the 19-9-35-4 monitoring plot in the southeastern corner of the lake, to be alive but stressed.

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Finally, at the request of the Trustees, during the spring 2016 monitoring event, specific observation was made to assess the percent cover of bindweed at the western end of Parcel 19-9-36, although bindweed is not on the MIPAG list of invasive species. During this monitoring event, bindweed was not observed in a significant quantity in that area or elsewhere in the NRRE areas, and only minimal presence of other nonplanted species (e.g., Virginia creeper, black raspberry) was observed. It was determined that, during the summer 2016 monitoring event; the vigor and growth of the planted vegetation would be evaluated, in consultation with the Trustee representative, to assess whether management or maintenance actions may be required to address bindweed or other non-planted species (e.g., Virginia creeper, black raspberry) if observed to be hindering the growth of the planted vegetation.

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 approximately 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. These plots were described in the RPMM Plan 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 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

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

The locations of the monitoring plots are shown on Figure 1. The actual boundaries of the monitoring plots were re-established by survey in the field prior to the May 2016 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 RPMM Plan in the FCR, the numbers of live trees and shrubs counted in each monitoring plot were compared to the baseline numbers of trees and shrubs listed in Table 7-2 of the FCR to determine percent survival. However, as directed in the Trustees' March 1, 2016 comment letter, given the purpose of the quantitative assessment to assess the survival of planted trees and shrubs, no percent survival results are given as greater than 100%. The survival results from this quantitative assessment of the individual monitoring plots within each monitoring area were then averaged to estimate the percent survival of trees and shrubs (as applicable) in that monitoring area. Similarly, the percent coverage by native herbaceous species and percent coverage by invasive species in the monitoring plots were averaged to determine the areal coverage by native herbaceous species and percent coverage by invasive species for each of the four monitoring areas. The results for each monitoring area were then compared to the Performance Standards specified in the SOW and summarized in the RPMM Plan - namely, 80% survival for the planted trees and shrubs, 100% cover by native herbaceous species (outside the foliar coverage of the trees), and no greater than 5% cover by invasive species.

The results of the quantitative NRRE vegetation monitoring event are presented on the Form A-1 s 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 where trees had been planted. However, as shown on the

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Form A-1 s, there was a shortage of a total of 25 individual shrubs, on a species-specific basis, com pared to the baseline numbers. These consisted of the following :

• one red-osier dogwood and one no,:thern arrowwood in the 19-10-9-1 monitoring plot,

• two winterberry hollies and one nannyberry viburnum in the 19-9-36-1 monitoring plot,

• one red-osier dogwood, one winterberry holly, one northern arrowwood, and one nannyberry viburnum in the 19-9-36-2 monitoring plot,

• two northern arrowwoods and one speckled alder in the 19-9-36-3 monitoring plot,

• one choke cherry, two northern arrowwoods, and one serviceberry in the 19-9-36-4 monitoring plot, • seven buttonbushes in the SSl-2 monitoring plot,

• one black chokeberry in the 19-9-35-1 monitoring plot, and

• one red-osier dogwood in the 19-9-35-3 monitoring plot.

However, in several cases, the spring 2016 counts indicated greater numbers of shrubs than the baseline numbers. As a result, when looking at the overall number of shrubs in each monitoring plot without regard to species, there was a shortage of 19 shrubs (two in 19-10-9-1 , two in 19-9-36-1 , three in 19-9-26-2, two in 19-936-3, two in 19-9-36-4, seven in SSl-2, and one in 19-9-35-3), and some monitoring plots indicated an overall increase in shrubs (one extra in 19-10-9-2, one extra in SSl-1 , and one extra in 19-9-35-1 ).

The total quantities of live trees and shrubs observed in each monitoring plot and monitoring area during the summer monitoring event are summarized in Table A-2. As shown in Table A-2, when these quantities are compared to the baseline quantities, the average percent survival for the trees and/or shrubs in each monitoring area is well above the applicable Performance Standard of 80% survival. Thus, it was concluded that no replanting is necessary.

During the summer 2015 monitoring event, a total of one tree and five shrubs in the monitoring plots had been observed to be alive but stressed and were thus subject to re-evaluation in the spring. During the spring monitoring event, those plantings were still exhibiting signs of stress, and several other plantings in the monitoring plots were also exhibiting signs of stress, potentially due to the unusually dry conditions. As indicated on the attached Form A-1 s, 2 trees and 37 shrubs were observed to be stressed during the spring 2016 monitoring event. These were:

• four shrubs (one red osier dogwood, one winterberry holly, and two northern arrowwoods) in the 19-10-91 monitoring plot,

• one tree (black willow) and one shrub (northern arrowwood) in the 19-10-9-2 monitoring plot,

• three shrubs (one red osier dogwood, one winterberry holly, and one serviceberry) in the 19-9-36-1 monitoring plot,

• six shrubs (two winterberry hollies and four northern arrowwoods) in the 19-9-36-2 monitoring plot, • two shrubs (one winterberry holly and one serviceberry) in the 19-9-36-3 monitoring plot, • one shrub (red osier dogwood) in the 19-9-36-4 monitoring plot,

• three shrubs (buttonbushes) in the SSl-1 monitoring plot,

• nine shrubs (buttonbushes) in the SSl-2 monitoring plot,

• one shrub (winterberry holly) in the 19-9-35-1 monitoring plot,

• two shrubs (red-osier dogwoods) in the 19-9-35-3 monitoring plot, and

• one tree (black willow) and five shrubs (one red osier dogwood, two winterberry hollies, and two northern arrowwoods) in the 19-9-35-4 monitoring plot.

It was determined that no replanting was necessary for these trees and shrubs at the present time, and that these plantings would continue to be monitored for their condition and survival, including a re-evaluation of their status and health, during the summer 2016 NRRE monitoring event.

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Karen PeltoDecember 6, 2016

Page 7 of 8 The results of the quantitative assessment of percent cover by native herbaceous species, which are alsosummarized in Table A-2 in Attachment A, showed that the percent cover by native herbaceous species inthree of the four monitoring areas (areas 19-10-9, 19-9-36, and 19-9-35), based on the results from themonitoring plots within them, did not meet the Performance Standard of 100% ( outside the foliar cover of thetrees). Monitoring area 19-10-9 had one monitoring plot which exhibited less than 100% cover, 19-9-36 hadtwo monitoring plots with just less than 100% cover, and 19-9-35 had two monitoring plots with less than100% cover. The areas with sparse cover included four of the specific areas described above and shown onFigure 1 - the area in monitoring plot 19-10-9-2 near the guardrail (Area 1), the area in monitoring plot 19-936-3 (Area 3), the area on Parcel 19-9-35 on the northeastern side of the lake within monitoring plot 19-9-35-1(Area 4), and the area on the southeastern side of the lake within and south of monitoring plot Parcel 19-935-4 (Area 5).7 As indicated above, it was determined that the sparsely vegetated areas identified at the topof bank on Parcel 19-9-35 would be re-seeded, and that all areas where herbaceous vegetative cover wasnoted as sparse would be evaluated during the summer 2016 NRRE inspection to determine if re-seedingmay be necessary.

With respect to the coverage by invasive species, the results of the quantitative assessment of percent coverby such species showed that, with the exception of the shrub-scrub island monitoring plot SSl-2, all othermonitoring plots had at least one invasive species present. As shown in Attachment A, the invasive speciescover in one individual monitoring plot (19-9-36-1) exceeded 5%. After averaging the results from themonitoring plots, no monitoring area had an invasive species cover greater than the Performance Standardof 5% (Table A-2). As noted above, GE re-initiated its general invasive species control program in the SilverLake Area on June 8 and 9, 2016 (after performance of the spring 2016 monitoring event), and additionaltreatments were conducted on June 23, July 27, August 31 , September 22 and 23, and (after a hard frost)October 26, 2016. This program has included treatment of the invasive species in the monitoring plot withgreater than 5% cover, along with all other invasive species observed throughout the NRRE areas. The 2016invasive species treatments at the NRRE areas are listed by date in Table 2 along with the speciescontrolled and applications performed.

Summary of Follow-up Actions

The items identified during the spring 2016 NRRE inspection as requiring response actions and theproposed follow-up actions are summarized in Table 1.8 As previously mentioned, several of those actionswere previously implemented - namely: (1) removal of the remaining tree support stakes from the large treeson the eastern bank; (2) treatment of northern arrowwood and nannyberry viburnum shrubs for the potentialpresence of viburnum leaf beetle; (3) weeding of the clusters near the Fourth Street Outfall; and (4) reinitiation and continuation of the general invasive species control program (as described in the March 2,2016 report) in this RAA.9

The remaining identified follow-up actions consist of re-seeding of the top-of-bank areas noted in monitoringarea 19-9-35 (slated to be conducted prior to the summer 2016 NRRE inspection), continuation of themaintenance program for certain large trees on the eastern bank, and re-evaluations of various areas orplantings during the summer 2016 NRRE inspection. Additionally, the qualitative portion of the summer

7 The other monitoring plot that had less than 100% cover - plot 19-9-36-4 (in monitoring area 19-9-36), which had 99%cover (Table A-2) - had some minor, non-contiguous areas of sparse coverage spread throughout the plot. It wasexpected that the existing herbaceous vegetation would continue to spread naturally to cover those areas. As such, nore-seeding was found to be necessary in that plot. 8 The RPMM Plan in the FCR provides that GE will implement any corrective actions identified during an NRREinspection within 90 days of the inspection date or 30 days of the Trustees' approval of the proposal (whichever is later),unless otherwise agreed to by the Trustees. In this case, however, given the need for prompt action, some of theidentified follow-up activities were conducted or initiated (or scheduled for performance) prior to that time, as described inthe text.

9 At the end of 2016, GE will evaluate the need for appropriate modifications to this invasive species control programand will propose any such modifications to the Trustees. However, as stated in the RPMM Plan, it is anticipated that thisprogram will continue in the NRRE areas through the final year of the seven-year NRRE monitoring program (i.e.,through 2020).

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Karen PeltoDecember 6, 2016

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2016 monitoring event was to include an assessment of the apparent vigor and growth of planted vegetationto evaluate whether management or maintenance actions may be required to address bindweed or othernon-planted species if observed to be hindering the growth of the planted vegetation. It should be kept inmind, when re-evaluating the health and growth of plantings and herbaceous vegetation during the summer2016 inspection, that western Massachusetts experienced abnormally dry condit ions in 2016, which mayhave affected the growth of vegetation in the area and thus need to be considered when identifying potential maintenance and contingency actions.

Future NRRE Inspections

As provided in the RPMM Plan, the next NRRE inspection at the Silver Lake Area was scheduled to beconducted in the summer of 2016, and was in fact conducted on September 8 and 9, 2016. That inspectionconstituted the second semi-annual 2016 inspection of the shrub-scrub island cap and the NRRE plantings,as well as the annual 2016 inspection of the walking path and benches; and a report on that inspection willbe submitted separately to the Trustees. All future NRRE inspections at the Silver Lake Area will beconducted in accordance with the RPMM Plan in the FCR. 10 Reports will be submitted on these monitoringevents to the Trustees and will include completed inspection checklists using the forms provided in the FCR.

If you have any questions regarding the information presented in this letter, please contact Kevin Mooney( 413-448-591 O; kevin [email protected] ), as I will be retiring at the end of this year.

Sincerely,

c/{))W--rU ~ IF,,,Richard W . GatesSenior Project Manager - Environmental Remediation

Attachments

cc: Dean Tagliaferro, EPA GE Internal RepositoriesDave Dickerson, EPA * electronic copy onlyTim Conway, EPA (without attachments)*Chris Ferry, ASRC Primus*Scott Campbell, Avatar* (plus 2 hard copies)lzabella Zapisek, Avatar*Robert Leitch, USACE*Michael Gorski, MDEP* John Ziegler, MDEP*Eva Tor, MDEP (without attachments)*Nancy E. Harper, MA AG (without attachments)*Robin McEwan, Stantec* 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 & Heart*James Gagnon, O'Reilly, Talbot & Okun*Andrew Silfer, GE*Kevin Mooney, GE*Rod McLaren, GE (without attachments)*Mark Gravelding, Todd Cridge, and Lauren Putnam, Arcadis*James Bieke, Sidley Austin LLPPublic Information Repositories

10 The inspections of the non-NRRE components of the remediation at the Silver Lake Area are performed separately inaccordance with the Post-Removal Site Control Plan in the FCR, with separate reports submitted to EPA.

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TABLES

Table 1 Summary of NRRE Areas/Items Requiring Response and of Follow-Up Actions, Based on Spring 2016 NRRE Inspection

Silver Lake Area General Electric Company – Pittsfield, Massachusetts

Area/Item Identified Description Completed Follow-upAction in Spring 2016 Additional Follow-up Action Identified

Areas 1 through 5: Sparse grass cover was observed in a few areas, and None. Re-seed sparsely covered areas at the top of bank Sparse Herbaceous the 100% Performance Standard for coverage by native in monitoring area I9-9-35 (prior to the summer Vegetative Cover herbaceous species was not met in three monitoring

areas (I9-10-9, I9-9-36, and I9-9-35). The sparsely vegetated areas included: • an area near the guardrail within monitoring plot I9

10-9-2 (Area 1),

2016 NRRE inspection).

Re-evaluate all identified sparely vegetated areas during the summer 2016 NRRE vegetation inspection to determine the need for re-seeding or additional erosion control measures.

• an area on the eastern shore of the Fourth Street Outfall on Parcel I9-9-36 (Area 2),

• a minor area in monitoring plot I9-9-36-3 (Area 3) • areas on Parcel I9-9-35 within and east of monitoring

plot I9-9-35-1 (including top of bank and part of bank face) and between monitoring plots I9-9-35-1 and -2 (Area 4), and

• an area on the southeastern side of the lake south of monitoring plot I9-9-35-4 (Area 5).

If the bank face area on Parcel I9-9-35 continues to show sparse vegetation and minor rills, conduct actions to provide stabilization and herbaceous cover.

If the area on the eastern shore of the Fourth Street Outfall on Parcel I9-9-36 continues to show poor establishment of vegetative cover in the summer 2016 inspection, place additional topsoil and reseed that area.

Area 6: The EPA and Trustee representatives observed that None. Continue maintenance program for these large Large Red Oak and these trees would benefit from continuation of the trees, including watering on a regular basis (based Maple Trees along maintenance program initiated after spring 2015 on soil conditions), pruning back as necessary to Eastern Bank of Silver inspection. The certified arborist for the spring 2016 tree portions with stronger growth, and mulching as Lake in the I9-9-35 inspection agreed that continuation of this maintenance appropriate. Monitoring Area program would be beneficial; and he also recommended

weeding around these trees, conducting proper mulch management (as described in the text), and maintaining soil fertility.

Re-evaluate during the summer 2016 NRRE inspection.

Area 7: Of the 8 black willow trees planted on the eastern bank None. Re-evaluate during the summer 2016 NRRE Large Black Willow Trees in monitoring area I9-9-35, outside of the monitoring

plots, 2 were observed to be dead and 5 appeared to be missing. The remaining black willow in that area and one black willow on the southwestern boundary of monitoring area I9-10-9 (outside of the monitoring plot) were observed to be alive but exhibiting some signs of stress.

inspection.

G:\GE\PRJ\GE_Silver_Lake\Reports and Presentations\2016-12 spring NRRE-REV\2041611214_SL_Spr NRRE Table 1.docx Page 1 of 4




Area 8: Dry Areas Around Shrub-Scrub Island with Stressed Vegetation

Although vegetation in the SSI-1 and SSI-2 monitoring plots was observed to be in generally good condition, the obligate wetland plants (i.e., buttonbush and soft rush) on the shrub-scrub island were observed to be extremely stressed or dead, which may have been due to inadequate wetland hydrology, exacerbated by the recent dry conditions. Red-osier dogwoods were observed to be unaffected by the dryer conditions.

None. Re-evaluate the hydrology and vegetation on the shrub-scrub island during the summer 2016 NRRE inspection to determine whether alternate species may be more appropriate if dryer conditions in this area appear to be persistent.

Area 9: Weed Growth Within “Cluster” Plantings

The “cluster” plantings near the Fourth Street Outfall, on the street side of the walking path, which had been noted in the Trustees’ March 1, 2016 letter to be overgrown with weeds in 2015, were again observed to have significant weeds.

“Clusters” were weeded on one occasion in spring 2016 (completed June 9, 2016).

None.

Herbivory on Certain Shrubs

Some minor herbivory was observed on a few northern arrowwood and nannyberry viburnum shrubs on the northwestern shore, suspected to have been caused by the viburnum leaf beetle. Although observed, the damage was not significant enough to cause stress to the plants.

Performed treatments of northern arrowwood and nannyberry viburnum shrubs to control potential presence of viburnum leaf beetle on May 23 and June 20, 2016.

Re-evaluate affected shrubs during the summer 2016 NRRE inspection.

If significant herbivory is observed, the affected northern arrowwood and/or nannyberry viburnum will be flagged should further treatment be determined appropriate.





Stressed Trees and Two trees and 37 shrubs in the monitoring plots were None. Re-evaluate status and health of these plantings Shrubs in Various observed to be alive but stressed, including: during the summer 2016 NRRE inspection for Monitoring Plots • four shrubs (one red osier dogwood, one winterberry

holly, and two northern arrowwoods) in the I9-10-9-1 monitoring plot,

• one tree (black willow) and one shrub (northern arrowwood) in the I9-10-9-2 monitoring plot,

• three shrubs (one red osier dogwood, one winterberry holly, and one serviceberry) in the I9-936-1 monitoring plot,

• six shrubs (two winterberry hollies and four northern arrowwoods) in the I9-9-36-2 monitoring plot,

• two shrubs (one winterberry holly and one serviceberry) in the I9-9-36-3 monitoring plot,

• one shrub (red osier dogwood) in the I9-9-36-4 monitoring plot,

• three shrubs (buttonbushes) in the SSI-1 monitoring plot,

• nine shrubs (buttonbushes) in the SSI-2 monitoring plot,

• one shrub (winterberry holly) in the I9-9-35-1 monitoring plot,

• two shrubs (red-osier dogwoods) in the I9-9-35-3 monitoring plot, and

• one tree (black willow) and five shrubs (one red osier dogwood, two winterberry hollies, and two northern arrowwoods) in the I9-9-35-4 monitoring plot.

condition and survival.

Invasive Species Invasive species were observed in most monitoring plots, and one monitoring plot (but no monitoring areas) had invasive species coverage greater than the Performance Standard of 5%.

Treated invasive species as part of GE’s invasive species control program (first treatment conducted on June 8 & 9, 2016).

Continue to treat invasive species as part of GE’s ongoing invasive species control program (as described in the revised summer 2015 NRRE inspection report). Re-evaluate presence of invasive species during the summer 2016 NRRE vegetation inspection. Re-evaluate general invasive species control program at the end of the 2016 season and propose any modifications.





Additional Invasive Species Noted by Trustees (Bindweed)

The Trustees’ March 1, 2016 letter indicated that bindweed, an invasive species not listed by MIPAG, was observed at the western end of Parcel I9-9-36. However, during the spring 2016 NRRE inspection, bindweed was not observed in a significant quantity in that area or elsewhere in the NRRE areas, and only minimal presence of other non-planted species (e.g., Virginia creeper, black raspberry) was observed.

None. No specific follow-up actions; however during the summer 2016 NRRE inspection, the planted vegetation will be evaluated, in consultation with the Trustees, to assess whether management or maintenance actions may be required to address bindweed or other non-planted species (e.g., Virginia creeper, black raspberry) if observed to be hindering the growth of the planted vegetation.

Tree Stakes Some remaining tree support stakes were observed near the large ornamental trees along the eastern bank.

During spring 2016 monitoring event, all remaining tree stakes were removed and disposed of off-site.

None.


Table 2 Summary of 2016 Invasive Species Treatments


Date of Treatment Treatment1 / Species Controlled

June 8 Treated observed invasive plant species around Silver Lake, including: coltsfoot, large accumulations of Japanese knotweed, large accumulations of oriental bittersweet and phragmites, and yellow iris and multiflora rose as needed.

June 9 Hand-weeded certain planting beds on the southeast and northeast corners of Silver Lake, and cut down/back honeysuckle, buckthorn, and Russian (or Autumn) olive, as necessary.

June 23 Hand-weeded certain planting beds on the southeast and northeast corners of Silver Lake. Treated observed invasive plant species, including: coltsfoot, large accumulations of Japanese knotweed, large accumulations of oriental bittersweet and phragmites, and yellow iris, multiflora rose, honeysuckle, buckthorn, and Russian (or Autumn) olive as needed.

June 27 Treated observed invasive plant species, including: coltsfoot, large accumulations of Japanese knotweed, large accumulations of oriental bittersweet and phragmites, and yellow iris, multiflora rose, honeysuckle, buckthorn, and Russian (or Autumn) olive as needed.

August 31 Treated observed invasive plant species, including: purple loosestrife, coltsfoot, large accumulations of Japanese knotweed, large accumulations of oriental bittersweet and phragmites, and yellow iris, multiflora rose, honeysuckle, buckthorn, and Russian (or Autumn) olive as needed.

September 22 Hand-weeded certain planting beds along the walking path and removed spotted knapweed and mugwort as necessary. Treated observed invasive plant species, including: coltsfoot, large accumulations of Japanese knotweed, large accumulations of oriental bittersweet and phragmites, and yellow iris, multiflora rose, honeysuckle, buckthorn, and Russian (or Autumn) olive as needed.

September 23 Hand-weeded on the eastern side of Silver Lake, including bindweed, oriental bittersweet, and wild raspberry where such species were observed to be hindering the development of planted vegetation. Treated cypress spurge.

October 26 Performed post hard frost treatment of invasive species. Hand-pulled spotted knapweed. Treated observed invasive plant species around Silver Lake, including the coltsfoot, purple iris, mugwort and cypress spurge.

Notes: 1. All treatments performed with Rodeo.


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RESULTS OF SPRING 2016 INSPECTION OF NRRE MEASURES

GENERAL ELECTRIC COMPANY

PITTSFIELD, MASSACHUSETTS

SILVER LAKE AREA

FIGURE

1

ATTACHMENT A

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

SILVER LAKE AREA GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS

I. GENERAL INFORMATION

Inspection Date: May 26-27, 2016 Conducted By/Phone Number: Mike Long, Gregg Rabasco Weather Conditions: Sun, mid 70s to low 80s

II. INSPECTION SUMMARY 1. Vegetation - Qualitative Meander Survey

A. Restored Trees and Shrubs (Note any physical changes since 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; note any evidence of damage from trespassing or herbivory.)

- Majority of plantings looked healthy. Two trees and 37 shrubs were observed to be stressed within the monitoring plots (see attached forms). - The EPA and Trustee representatives observed that the large red oak and maple trees along the eastern bank of Silver Lake could benefit from

continued maintenance, as previously recommended by the arborist during the spring 2015 inspection. The certified arborist for the spring 2016 inspection agreed that continuation of this maintenance program would be beneficial; and he also recommended weeding around these trees, conducting proper mulch management (including maintaining a mulch depth of no more than 2-3 inches and ensuring that the root crown is exposed and not covered with mulch or soil), and maintaining soil fertility.

- Only one of the eight large black willow trees on the eastern bank of Silver Lake, outside of the monitoring plots, was observed to be alive. The apparent remnants of two dead black willows were observed, and the other five willows appeared to be missing, with no indication of what had happened to them.

- The one remaining large black willow on the eastern bank in monitoring area I9-9-35 and one black willow on the southwestern boundary of monitoring area I9-10-9 were observed to be alive, but exhibiting some signs of stress.

- Some evidence of very minor herbivory was observed on northern arrowwood and nannyberry viburnum shrubs along the northwestern shore, likely due to the viburnum leaf beetle; however, it was not considered significant enough to cause stress to plants.

- In areas around the shrub-scrub island, the obligate wetland plantings were observed to be stressed or dead, which may have been due to inadequate wetland hydrology, exacerbated by the recent dry conditions. The red-osier dogwoods were not affected.

B. Herbaceous Vegetation (Note evidence of areas of bare/sparse vegetation; note any damage from trespassing or herbivory; note any physical changes

since last inspection. Also note the presence and condition of the topsoil placed in the void spaces of the armor stone around the periphery of the shrub-

scrub island above the water surface elevation and the condition and growth of the vegetation planted in that topsoil.)

- There was no evidence of significant damage from trespassing or herbivory. - Vegetative cover was generally well established except in five areas of sparse vegetation: (1) near the guardrail in monitoring plot I9-10-9-2; (2) on the

eastern shore of the Fourth Street Outfall on Parcel I9-9-36; (3) in monitoring plot I9-9-36-3; (4) on Parcel I9-9-35 within and to the east of monitoring plot I9-9-35-1 (on both the top of bank and on a portion of the bank face, where minor rilling was observed) and between monitoring plots I9-9-35-1 and -2; and (5) on the southeastern side of the lake within and south of monitoring I9-9-35-4.

- Herbaceous vegetation percent coverage within the specified monitoring plots is shown on the attached forms and tables. As shown there, the cover in five individual monitoring plots was less than 100%. After averaging the results from the monitoring plots, three monitoring areas had cover less than the Performance Standard of 100%.

- Topsoil and herbaceous vegetation placed in the void spaces of the armor stone around the periphery of the shrub-scrub island were generally well established and stable.

C. 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 Tatarian honeysuckle [hybrid], Multiflora rose, Norway maple, Oriental

bittersweet, Phragmites - common reed, Porcelain berry, Purple loosestrife, Russian olive, Spotted knapweed, Tatarian honeysuckle, Yellow iris, or any

other plant species listed by the Massachusetts Invasive Plant Advisory Group as “Invasive,” “Likely Invasive,” or “Potentially Invasive”.)

- Invasive species were observed within the NRRE areas. Observed invasive species included coltsfoot, common buckthorn, cypress spurge, Japanese knotweed, multiflora rose, oriental bittersweet, phragmites (common reed), Russian olive (or Autumn olive), spotted knapweed, tatarian honeysuckle, and yellow iris, all of which were observed in small concentrations in the NRRE areas.

- Invasive species percent coverage within the specified monitoring plots is shown on the attached forms and tables. As shown there, the invasive species cover in one individual monitoring plot exceeded 5%. After averaging the results from the monitoring plots, no monitoring areas had invasive species cover greater than the Performance Standard of 5%.

12/5/2016 G:\GE\PRJ\GE_Silver_Lake\Reports and Presentations\2016-12 spring NRRE-REV\2041611214_Spring NRRE Attachment A.xls Page 1 of 2

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


2. 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].)

3. Shrub-Scrub Island Cap (Note any areas of the shrub-scrub island cap where the cap may be eroding [e.g., in areas along the edge of water that do not

have armor stone] and any other conditions that could jeopardize the performance of the cap.)

- No areas of erosion or other conditions that could jeopardize the performance of the cap were observed.

4. 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.)

- Most of the repair, maintenance, and re-seeding items identified during the summer 2015 inspection had been performed, as described in the 2015 Annual Monitoring Report.

- The northern arrowwood and nannyberry viburnum shrubs had been treated on one occasion prior to the inspection to control the potential presence of viburnum leaf beetle.

- The “cluster” plantings near the Fourth Street Outfall on the street side of the walking path, which had been observed by the Trustees to be overgrown with weeds in 2015, were again observed to have significant weeds.

- In the area at the western end of Parcel I9-9-36, where bindweed had been observed by the Trustees in 2015, bindweed was not observed in a significant quantity in that area or elsewhere in the NRRE areas, and only minimal presence of other non-planted species (e.g., Virginia creeper, black raspberry) was observed.

- Some remaining tree support stakes were observed near the large trees on the trees on the eastern bank of Silver Lake and were removed during the May 2016 inspection and disposed of off-site.

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIES - Initiate the general invasive vegetative species control program for 2016 (initiated with the first treatment on June 8-9, 2016). - Conduct hand weeding of the weeds in the cluster plantings near the Fourth Street Outfall (performed during the re-initiation of the invasive species

control program in June 2016). - Conduct the second (and final) treatment of northern arrowwood and nannyberry viburnum shrubs to address the potential presence of viburnum leaf

beetle (completed on June 20, 2016). - Re-seed the areas of sparse vegetation at the top of bank on Parcel I9-9-35, and re-evaluate those areas, as well as the area of sparse vegetation

and rilling on the bank face area on Parcel I9-9-35, during the summer 2016 inspection to assess the need for contingency actions to provide stabilization and herbaceous cover.

- Continue monitoring the other areas where sparse vegetative cover was noted during the May 2016 inspection, with re-evaluation during the summer 2016 inspection.

- Continue the maintenance program for the large red oak and maple trees on the eastern bank of Silver Lake, with re-evaluation during the summer 2016 inspection.

- Re-evaluate the health of the one remaining black willow on the eastern bank in monitoring area I9-9-35, as well as one stressed black willow on the southwestern boundary of monitoring area I9-10-9, during the summer 2016 inspection.

- Re-evaluate the hydrology and vegetation on the shrub-scrub island during the summer 2016 inspection. - Re-evaluate any damage to northern arrowwood and nannyberry viburnum shrubs due to herbivory during the summer 2016 inspection. - Continue monitoring the two trees and 37 shrubs identified as stressed in the monitoring plots during the May 2016 inspection, with

re-evaluation during the summer 2016 inspection. - Continue to treat invasive species as part of GE’s general invasive species control program and re-evaluate the presence of invasive species

during the summer 2016 inspection. - Continue to evaluate, in consultation with the Trustees, whether management or maintenance actions may be required to address bindweed or other

non-planted species (e.g., Virginia creeper, black raspberry) if observed to be hindering the growth of planted vegetation.

ATTACH ADDITIONAL INFORMATION AS APPROPRIATE


FORM A-1 NATURAL RESOURCE RESTORATION/ENHANCEMENT QUANTITATIVE VEGETATION MONITORING FIELD FORM

SILVER LAKE AREA GENERAL ELECTRIC COMPANY – PITTSFIELD, MASSACHUSETTS

Inspection Date: May 26-27, 2016 Conducted By/Observer(s): Mike Long, Gregg Rabasco of ARCADIS, Dave Dickerson of EPA, Izabela Zapisek of Avatar Environmental, Robin McEwan of Stantec Weather Conditions: Sunny, mid 70 degrees to low 80 degrees

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 18 1 -1

Silver maple 0 0 0 NA Silkydogwood 0 0 0 NA

Eastern cottonwood 0 0 0 NA Winterberry

Holly 4 3 1 Same

Sugar maple 0 0 0 NA Choke cherry 0 0 0 NA

Red oak 0 0 0 NA Northern arrowwood 5 2 2 -1

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 0 0 0 NA Total 29 23 4 -2

Total Live Trees: _______________0_____________ Total Live Shrubs: ____________27_____________

Were two or more adjacent trees observed to be dead (Y/N) (applicable only to the 30 large trees on the eastern bank of Silver Lake): NA .

Herbaceous Cover (%): Invasive Plant Cover (%):

100% <5%

. .

Page 1 of 12





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 1 1 Same Red-osier dogwood 19 20 0 +1

Silver maple 2 2 0 Same Silkydogwood 0 0 0 NA


Holly 5 5 0 Same


Red oak 0 0 0 NA Northern arrowwood 5 4 1 Same






Buttonbush 0 0 0 NA

Total 4 3 1 Same Total 29 29 1 +1

Total Live Trees: ___________4________________ Total Live Shrubs: ___________30______________



95% <5%

. .

Page 2 of 12






Stem Count:


# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline

Black willow 0 0 0 NA Red-osier dogwood 26 26 1 +1

Silver maple 0 0 0 NA Silkydogwood 2 2 0 Same


Holly 10 7 1 -2

Sugar maple 0 0 0 NA Choke cherry 3 3 0 Same


Red maple 0 0 0 NA Nannyberry viburnum 1 0 0 -1

Serviceberry 2 1 1 Same

Black chokeberry 2 2 0 Same



Buttonbush 0 0 0 NA

Total 0 0 0 NA Total 55 50 3 -2

Total Live Trees: ___________0_________________ Total Live Shrubs: ____________53______________



100% 10%

. .

Page 3 of 12






Stem Count:


# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline




Holly 10 7 2 -1



Red maple 0 0 0 NA Nannyberry viburnum 1 0 0 -1



Pussy-willow 1 2 0 +1

Speckled alder 2 2 0 Same

Buttonbush 0 0 0 NA

Total 0 0 0 NA Total 52 43 6 -3

Total Live Trees: _______________0_____________ Total Live Shrubs: ____________49_____________



100% <5%

. .

Page 4 of 12






Stem Count:


# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline

Black willow 0 0 0 NA Red-osier dogwood 23 23 0 Same



Holly 8 7 1 Same




Serviceberry 1 1 1 +1


Pussy-willow 2 2 0 Same

Speckled alder 2 1 0 -1

Buttonbush 0 0 0 NA

Total 0 0 0 NA Total 46 42 2 -2

Total Live Trees: _____________0______________ Total Live Shrubs: _______________44___________



98% <5%

. .

Page 5 of 12






Stem Count:


# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline




Holly 6 6 0 Same

Sugar maple 0 0 0 NA Choke cherry 3 2 0 -1


Red maple 0 0 0 NA Nannyberry viburnum 3 3 0 Same

Serviceberry 2 1 0 -1

Black chokeberry 4 4 0 Same



Buttonbush 0 0 0 NA

Total 0 0 0 NA Total 43 40 1 -2

Total Live Trees: _______________0_____________ Total Live Shrubs: ______________41____________



99% <5%

. .

Page 6 of 12




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




Holly 0 0 0 NA


Red oak 0 0 0 NA Northern arrowwood 0 0 0 NA






Buttonbush 3 0 3 Same

Total 0 0 0 NA Total 37 35 3 +1

Total Live Trees: _______________0_____________ Total Live Shrubs: _____________38_____________



100% <5%

. .

Page 7 of 12




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

Black willow 0 0 0 NA Red-osier dogwood 24 24 0 Same



Holly 0 0 0 NA


Red oak 0 0 0 NA Northern arrowwood 0 0 0 NA






Buttonbush 16 0 9 -7

Total 0 0 0 NA Total 40 24 9 -7

Total Live Trees: _______________0_____________ Total Live Shrubs: ___________33_______________



100% 0%

. .

Page 8 of 12






Stem Count:


# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline




Holly 5 4 1 Same



Red maple 0 0 0 NA Nannyberry viburnum 2 2 0 Same


Black chokeberry 3 2 0 -1

Pussy-willow 1 1 0 Same

Speckled alder 1 1 0 Same

Buttonbush 0 0 0 NA

Total 0 0 0 NA Total 38 38 1 +1

Total Live Trees: _______________0_____________ Total Live Shrubs: ___________39_______________



90% (bank face) to 60% (top of bank) <5% .

.

Page 9 of 12




Monitoring Area: Monitoring Plot:

I9-9-35 Area I9-9-35-2

Approximate Size (sf): Approximate Size (sf):

42,400 1,780

_ _

Stem Count:


# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline

Black willow 0 0 0 NA

Red-osier dogwood 15 15 0 Same

Silver maple 0 0 0 NA

Silky dogwood 0 0 0 NA

Eastern cottonwood 0 0 0 NA

Winterberry Holly 0 0 0 NA

Sugar maple 3 3 0 Same

Choke cherry 0 0 0 NA

Red oak 21 2 0 Same

Northern arrowwood 0 0 0 NA

Red maple 12 1 0 Same

Nannyberry viburnum 0 0 0 NA





Buttonbush 0 0 0 NA

Total 6 6 0 Same Total 15 15 0 Same

Total Live Trees: ________6__________________ Total Live Shrubs: ____________15_____________

Were two or more adjacent trees observed to be dead (Y/N) (applicable only to the 30 large trees on the eastern bank of Silver Lake): N . Herbaceous Cover (%): 100% . Invasive Plant Cover (%): <5% .

1 Although the May 2014 stem count established that the baseline indicated that three red oaks and no red maples were planted in this monitoring plot, during the May 2015 and August 2015 inspection it was determined that two red oak and one red maple were planted. The “# planted” column has been amended based on these observations.2 See Note 1.

Page 10 of 12






Stem Count:


# Alive &

Healthy # Alive,

Stressed


# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed


Shrubs to Baseline




Holly 0 0 0 NA

Sugar maple 2 2 0 Same Choke cherry 0 0 0 NA

Red oak 2 2 0 Same Northern arrowwood 0 0 0 NA

Red maple 1 1 0 Same Nannyberry viburnum 0 0 0 NA





Buttonbush 0 0 0 NA

Total 5 5 0 Same Total 15 12 2 -1

Total Live Trees: ___________5________________ Total Live Shrubs: _____________14____________

Were two or more adjacent trees observed to be dead (Y/N) (applicable only to the 30 large trees on the eastern bank of Silver Lake): N .


100% <5%

. .

Page 11 of 12






Stem Count:


# Alive &

Healthy # Alive,

Stressed

Comparisonof # Live Trees to Baseline Shrubs

# Planted (Baseline

# Alive &

Healthy # Alive,

Stressed

Comparisonof # Live

Shrubs to Baseline

Black willow 2 1 1 Same Red-osier dogwood 5 4 1 Same


Eastern cottonwood 1 1 0 Same Winterberry

Holly 4 2 2 Same








Buttonbush 0 0 0 NA

Total 3 2 1 Same Total 13 8 5 Same

Total Live Trees: _________3_________________ Total Live Shrubs: ___________13_______________



90% <5%

. .

Page 12 of 12

TABLE A-1 SUMMARY OF MONITORING PLOT PLANTING COUNTS


Date(s) of Monitoring: May 26-27, 2016

Area Plot No.

Dimensions Number of Trees Number of Shrubs Herbaceous

Cover (%)

Invasive Plant

Cover (%)

Length

(ft)

Width

(ft)

Area

(ft2) BW SiM EC SuM RO RM

Total

Trees ROD SD WH CC NA NV SB BCB PW SA BB

Total

Shrubs

I9-10-9 Area I9-10-9-1 65 11 730 0 0 0 0 0 0 0 19 0 4 0 4 0 0 0 0 0 0 27 100% <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 95% <5%

I9-9-36 Area

I9-9-36-1 59 41 2,322 0 0 0 0 0 0 0 27 2 8 3 9 0 2 2 0 0 0 53 100% 10%

I9-9-36-2 57 45 2,491 0 0 0 0 0 0 0 24 2 9 0 8 0 2 0 2 2 0 49 100% <5%

I9-9-36-3 61 33 1,878 0 0 0 0 0 0 0 23 1 8 2 5 0 2 0 2 1 0 44 98% <5%

I9-9-36-4 60 29 1,928 0 0 0 0 0 0 0 19 2 6 2 4 3 1 4 0 0 0 41 99% >5%

Shrub-Scrub Island Area

SSI-1 25 20 500 0 0 0 0 0 0 0 35 0 0 0 0 0 0 0 0 0 3 38 100% <5%

SSI-2 25 20 500 0 0 0 0 0 0 0 24 0 0 0 0 0 0 0 0 0 9 33 100% 0%

I9-9-35 Area

I9-9-35-1 59 51 2,965 0 0 0 0 0 0 0 19 2 5 1 5 2 1 2 1 1 0 39 90% (bank face) to 60% (top of bank) <5%

I9-9-35-2 63 28 1,777 0 0 0 3 2 1 6 15 0 0 0 0 0 0 0 0 0 0 15 100% <5%

I9-9-35-3 59 34 2,172 0 0 0 2 2 1 5 14 0 0 0 0 0 0 0 0 0 0 14 100% <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 90% <5%

Species Legend BW = black willow ROD = red-osier dogwood SB = serviceberry SiM = silver maple SD = silky dogwood BCB = black chokeberry EC = eastern cottonwood WH = winterberry holly PW = pussy-willow SuM = sugar maple CC = choke cherry SA = speckled alder RO = red oak NA = northern arrowwood BB = buttonbush RM = red maple NV = nannyberry viburnum


TABLE A-2 SUMMARY OF QUANTITATIVE ASSESSMENT


Date(s) of Monitoring: May 26-27, 2016

Area Plot No. Trees Shrubs Herbaceous

Cover (%) Invasive Plant

Cover (%) # Planted # Alive % Survival > 80% Survival # Planted # Alive % Survival > 80% Survival

I9-10-9

I9-10-9-1 0 0 NA -- 29 27 93% -- 100% <5%

I9-10-9-2 4 4 100% -- 29 30 100% -- 95% <5%

Average -- -- 100% YES -- -- 97% YES <100% <5%

I9-9-36

I9-9-36-1 0 0 NA -- 55 53 96% -- 100% 10%

I9-9-36-2 0 0 NA -- 52 49 94% -- 100% <5%

I9-9-36-3 0 0 NA -- 46 44 96% -- 98% <5%

I9-9-36-4 0 0 NA -- 43 41 95% -- 99% <5%

Average -- -- NA NA -- -- 95% YES <100% <5%

Shrub-Scrub Island

SSI-1 0 0 NA -- 37 38 100% -- 100% <5%

SSI-2 0 0 NA -- 40 33 83% -- 100% 0%

Average -- -- NA NA -- -- 91% YES 100% <5%

I9-9-35

I9-9-35-1 0 0 NA -- 38 39 100% -- 60% to 90% <5%

I9-9-35-2 6 6 100% -- 15 15 100% -- 100% <5%

I9-9-35-3 5 5 100% -- 15 14 93% -- 100% <5%

I9-9-35-4 3 3 100% -- 13 13 100% -- 90% <5%

Average -- -- 100% YES -- -- 98% 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


Photo 1: Area of sparse grass cover on peninsula east of Fourth Street outfall (Area 2).

Photo 2: Area of sparse grass cover in monitoring plot I9-10-9-2 near guardrail (Area 1).

G:\GE\PRJ\GE_Silver_Lake\Reports and Presentations\2016-12 spring NRRE-REV\2041611214_Spring NRRE Attachment B.docx Page 1 of 3



Photo 3: Area of sparse grass cover at top of bank within monitoring plot I9-9-35-1 (Area 4).

Photo 4: Area of sparse grass cover within and south of I9-9-35-4 (Area 5).




Photo 5: Dry area around Shrub-Scrub Island with stressed shrubs (Area 8).

Photo 6: Dry area around Shrub-Scrub Island with stressed shrubs (Area 8).


ATTACHMENT C

ATTACHMENT C INVASIVE SPECIES OF CONCERN

SILVER LAKE AREAGENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS

Common Name Scientific Name Amur honeysuckle Lonicera maackii

Autumn olive Elaeagnus umbellata

Black locust Robinia pseudoacacia

Black swallow-wort Cynanchum louiseae

Coltsfoot Tussilago farfara

Common barberry Berberis vulgaris

Common buckthorn Rhamnus cathartica

Cypress spurge Euphorbia cyparissias

Garlic mustard Alliaria petiolata

Glossy buckthorn Rhamnus frangula

Goutweed or Bishop's Weed Aegopodium podagria

Japanese barberry Berberis thunbergii

Japanese honeysuckle Lonicera japonica

Japanese knotweed Polygonum cuspidatum

Morrow's honeysuckle Lonicera morrowii

Morrow's X Tatarian Lonicera xbella

Multiflora rose Rosa mutiflora

Norway maple Acer platanoides

Oriental bittersweet Celastrus orbiculata

Phragmites (common reed) Phragmites australis

Porcelain berry Ampelopsis brevipedunculata

Purple loosestrife Lythrum salicaria

Russian olive Elaeagnus angustifolia

Spotted knapweed Centaurea biebersteinii

Tartarian honeysuckle Lonicera tartarica

Yellow iris Iris pseudacorus

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

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