Transmitted via Overnight Courier

December 2, 2010

Mr. Richard Fisher (Mail Code OSRR07-1) United States Environmental Protection Agency Office of Site Remediation and Restoration 5 Post Office Square - Suite 1 00 Boston, MA 02109-3912

Re: GE-Pittsfield/Housatonic River Site Newell Street Area II Removal Action Area (GECD450) Completion of Engineered Barrier Repair Activities

Dear Mr. Fisher:

GE 159 Plastics Avenue Pittsfield, MA 01201 USA

This letter provides notification to the United States Environmental Protection Agency (EPA) regarding completion of repair activities to the engineered barrier located within a portion of Parcel J9-23-8 at the above referenced site. As described in a letter from GE dated July 23, 2010 (as corrected in a letter from GE dated September 3, 2010), activities performed by Western Massachusetts Electric Company (WMECo) on July 16, 2010 caused a puncture in the engineered barrier on Parcel J9-23-8. Specifically, a surveyor assisting WMECo with tower demolition activities drove a survey marker through the geosynthetic components of the engineered barrier. The approximate location of the puncture is shown on Figure 1. This letter describes the activities performed by GE to repair the engineered barrier. Repair activities were completed by GE on September 28, 2010 and reseeding of the repaired area was completed on November 11, 2010. Further description of the repair activities is provided below.

Engineered Barrier Repair Activities

As mentioned above, GE performed repair activities in a portion of the engineered barrier on Parcel J9-23-8. Following removal of the soil cover material in the vicinity of the puncture, a portion of the geosynthetic drainage composite (GDC) was pulled back, exposing the damaged geomembrane liner. The surface of the liner immediately surrounding the puncture was cleaned. A piece of geomembrane having the same properties as the existing liner was sized to provide a minimum coverage of 12 inches beyond the outer-most edges of the puncture and was placed over the puncture and extrusion-welded to create an integral water-tight seam. The welded seam was vacuum box tested to verify that the weld is sufficient to resist leakage.

Once seaming and testing of the geomembrane liner was completed, the GDC was redeployed over the liner. The geonet component of the GDC was rejoined using connecting (ZIP) ties. Cuts in the geotextile component of the GDC which were necessary to access the underlying geomembrane liner were patched using non-woven geotextile having the same or similar properties as the existing geotextile material. Prior to installing the geotextile patch the surface of the GDC was cleaned and a piece of new geotextile was cut to provide a minimum of 12 inches of coverage beyond the outer-most edges of the existing geotextile cut. The geotextile patch was placed over the existing geotextile and heat-bonded along its full perimeter. Photographs of the repair activities conducted on September 28, 2010 are provided in Attachment A.

Corporate Environmental Programs

Richard Fisher December 2, 2010

Page 2 of2

Once the geotextile patching was completed, the previously removed soil cover material was backfilled and fine-graded consistent with pre-existing conditions. The backfilled area, as well as other site areas disturbed as a result of the repair work, were subsequently reseeded (with the seed mix approved by the Natural Resource Trustees for areas subject to Natural Resource Restoration/Enhancement activities) and mulched on November 11,2010.

All repair work, including patching and testing of the geomembrane liner, was conducted in accordance with the original project construction specifications.

Please call me if you have any comments or questions.

Sincerely

K ~d.t~r-J w. GQ+es. /ct;B

Richard W. Gates Remediation Project Manager

Attachments

cc: Dean Tagliaferro, EPA Tim Conway, EPA Holly Inglis, EPA Rose Howell, EPA* Linda Palmieri, Weston (2 copies) Michael Gorski, MDEP Eva Tor, MDEP* John Ziegler, MDEP (2 copies) Jane Rothchild, MDEP* Nancy E. Harper, MA AG* Mayor James Ruberto, City of Pittsfield* Barbara Landau, Noble & Wickersham* Michael Carroll, GE* Roderic McLaren, GE* James Nuss, ARCADIS James Bieke, Goodwin Procter Adam St. Martin, Northeast Utilities Charles Nicol, Northeast Utilities* John Burke, WMECo John Tulloch, WMECo Public Information Repositories GE Internal Repository

* cover letter only

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GENERAL ELECTRIC COMPANY PITTSFIELD, MASSACHUSETTSNEWELL STREET AREA II

SITE PLAN

1 FIGURE

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-·· -·· -·· -·· ....... ....... .---··

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HIGH TENSION TOWER SUBJECT TO DEMOLITION

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HIGH TENSION TOWER TO REMAIN -r--------

J9-23-13

NOTES:

··-

LEGEND

APPROXIMATE RAA BOUNDARY

-------- PARCEL BOUNDARY

--·------ EASEMENT

J9-23-12 PARCEL ID

--DH-- OVERHEAD v.lRES

TOP OF BANK

EDGE OF WATER

AREA ADDRESSED AS PART OF THE UPPER 1 /2-MILE REACH REMOVAL ACTION

~----~ ACCESS ROAD - PAVED I I PORTION OF ENGINEERED L. ____ __J_ BARRIER

~A VEGETATED ENGINEERED BARRIER LIMITS

1. BASE MAP MODIFIED FROM SURVEY BY HIUL ENGINEERS, ARCHITECTS &: PLANNERS, DATED 12/9/03. LIMITS OF HOUSATONIC RIVER ARE APPROXIMATE.

2. UTILITIES ARE SHOWN IN AN APPROXIMATE WAY ONLY AND ALL UTILITIES MAY NOT BE SHOWN.

50' 100'

GRAPHIC SCALE

ARCADIS

Attachment A

Photographs

INSERT PHOTO HERE

INSERT PHOTO HERE

Photo #1: View of the geosynthetics penetration.

Client: General Electric Company

Photo #2: Extrusion welding a patch of 60 mil flexible membrane liner (FML) over the penetration.

Project Name: Newell Street Area II Project Location: Pittsfield, Massachusetts

G:\GE\GE_Pittsfield_CD_Newell_St_Area_II\Correspondence\Liner\ 4131011324AttaA.xls

INSERT PHOTO HERE

INSERT PHOTO HERE

Photo #3: The completed FML patch over the penetration.

Client: General Electric Company Project Name: Newell Street Area II Project Location: Pittsfield, Massachusetts

Photo #4: Vacuum box testing the extrusion weld of the FML patch.

G:\GE\GE_Pittsfield_CD_Newell_St_Area_II\Correspondence\Liner\ 4131011324AttaA.xls

INSERT PHOTO HERE

INSERT PHOTO HERE

Photo #5: Zip tying the overlying geosynthetic drainage composite (GDC).

Client: General Electric Company

Project Location: Pittsfield, Massachusetts

Photo #6: Cleaning the area prior to placing a patch of geotextile over the zip tied GDC.

Project Name: Newell Street Area II

G:\GE\GE_Pittsfield_CD_Newell_St_Area_II\Correspondence\Liner\ 4131011324AttaA.xls

INSERT PHOTO HERE

INSERT PHOTO HERE

Photo #7: Installing the patch of geotextile over the penetration area.

Client: General Electric Company Project Name: Newell Street Area II Project Location: Pittsfield, Massachusetts

Photo #8: Completed GDC repair.

G:\GE\GE_Pittsfield_CD_Newell_St_Area_II\Correspondence\Liner\ 4131011324AttaA.xls