Re: GE-Pittsfield/Housatonic River SiteResource Trustees, with a copy to EPA, on November 18, 2014. In addition, specific invasive species inspections were conducted in the NRRE area

GE Corporate

• 159 Plastics Avenue Pittsfield, MA 01201 USA

Transmitted via Overnight Courier

October 2, 2015

Mr. Richard Fisher Office of Site Remediation and Restoration U.S . Environmental Protection Agency, Region I 5 Post Office Square - Suite I 00 (Mail Code OSRR07-01) Boston, MA 02109-3912

Re: GE-Pittsfield/Housatonic River Site East Street Area 2-South (GECD150) Summary of September 2015 Inspection Activities

Dear Mr. Fisher:

On September 3, 2015, the General Electric Company (GE) performed a post-remediation inspection at the East Street Area 2-South Removal Action Area (RAA). This RAA comprises the following five GE-owned averaging areas:

• Averaging Area 4A - 60s Complex;

• Averaging Area 4B - Former Gas Plant/Scrap Yard Area;

• Averaging Area 4C - City Recreational Area;

• Averaging Area 4D- 200-Foot Wide Industrial Averaging Strip; and

• Averaging Area 4E-Riparian Removal Zone.

Previous post-remediation inspections at East Street Area 2-South were performed semi-annually since December 2011. Summaries of these inspections were presented in prior letters to EPA. The most recent prior inspection was performed in May 2015, with the report on it submitted to EPA on June 10, 2015.

The September 2015 inspection was performed in accordance with the Post-Removal Site Control Plan (PRSC Plan) contained in GE's Final Completion Report for the East Street Area 2-South Removal Action (FCR). This inspection involved observations of the following: (a) the area where an engineered barrier was installed (in a portion of Averaging Area 4E); (b) the unpaved areas that were backfilled and restored; (c) the trees and shrubs that were installed in the fall of 2013 and the trees installed in the fall of 2014; ( d) the areas containing enhanced pavement (in portions of Averaging Area 4B); (e) the other areas that GE has elected to

Richard Fisher October 2, 2015

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maintain as paved; (f) the paved areas and former building foundations that have been covered with an appropriate soil cover or riprap; and (g) the Groundwater Recharge Pond.1 This inspection did not include the vegetation planted as part of natural resource restoration/enhancement (NRRE) measures.2

Figure 1 shows the areas/items subject to inspection at this RAA. Figures 2-1 and 2-2 present the Restoration Planting Plan for this RAA, including the trees/shrubs replanted in the fall of 2013 and the trees replanted in the fall of2014, which were subject to inspection in September 2015.

Summary of Observations During Inspection

The results of the September 2015 inspection are presented in the Inspection Summary and Checklist form in Attachment A. As indicated in that form, it was determined during the September 2015 inspection that all areas subject to inspection - i.e., the engineered barrier area, the unpaved backfilled/restored areas, the enhanced pavement areas, the other areas that GE has agreed to maintain as paved, the paved areas and former building foundations covered with a soil cover (or riprap), and the Groundwater Recharge Pond were in good condition. However, saplings were observed to be growing in and along the drainage swales in the engineered barrier area, on the former Building 63-X slab, and along the south side of Building 65.

In addition, tree/shrub counting and observation activities indicated that all of the trees and shrubs subject to inspection (a total of 33 plantings) were surviving and in good condition. Documentation of the tree/shrub observations is provided in Tables B-1 through B-14 in Attachment B and summarized in Table 1. No tree cages, guards, or stakes were present.

Maintenance/Repair Activities

Based on the September 2015 inspection, the following maintenance/repair activities were identified:

• Remove saplings observed to be growing in swales and along swale edges in the engineered barrier area; and

• Remove saplings observed to be growing on the former Building 63-X slab and along the south side of Building 65.

GE will complete these sapling removal activities this fall.

Schedule for Future Inspections

In the June 10, 2015 inspection report, GE proposed to modify the inspection frequencies at this RAA following the August/September 2015 inspection, so that the inspections of the engineered barriers and enhanced pavement areas would be performed annually and the inspections of the backfilled/restored areas,

1 Post-remediation inspections of Averaging Area 4C, the City Recreational Area, are conducted annually on a separate schedule. The most recent such inspection was conducted on September 2, 2015, with a report on it submitted to EPA on October 1, 2015.

2 The NRRE vegetation, which was planted in Averaging Area 4E and a portion of Averaging Area 4B, is subject to separate inspections in accordance with the Restoration Project Monitoring and Maintenance Plan in the FCR. The most recent regular NRRE inspection was conducted on August 28, 2014, with a report on it submitted to the Natural Resource Trustees, with a copy to EPA, on November 18, 2014. In addition, specific invasive species inspections were conducted in the NRRE area in May, June, and August 2015, focusing on Cypress spurge; a report on the May and June inspections was submitted on June 30, 2015 and an e-mail summarizing the August inspection was submitted on September 24, 2015.

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areas that GE has elected to maintain as paved, the paved areas and former building foundations covered with a soil cover (or riprap), and the Groundwater Recharge Pond would be performed biennially. Based on further review and consideration, GE now proposes the following modifications to the inspection frequencies:

• Since the inspections have shown that the engineered barrier and enhanced pavement are in good overall condition, the inspections of the engineered barrier area and enhanced pavement areas will be revised from semi-annual to annual (in August or September), with the next scheduled inspection in August or September 2016.

• The Other Ground-Covering Feature Area, consisting of the paved areas that GE has agreed to maintain as paved and the paved areas and former building foundations covered with a soil cover (or riprap), will continue to be inspected on an annual basis (in August or September), with the next scheduled inspection in August or September 2016. They will also be inspected after severe storms (as defined in the PRSC Plan).

• The trees planted in the fall 2014 will be inspected again in May and in August or September 2016.3

• Since the inspections have consistently shown for several years that the unpaved areas that were backfilled and restored, as well as the Groundwater Recharge Pond, are in good condition, with no need for maintenance or repairs, the regularly scheduled inspections of the unpaved backfilled/restored areas (apart from the restored vegetation) and the Groundwater Recharge Pond will be discontinued. However, those areas will be inspected after severe storms (as defined in the PRSC Plan).

Future inspections will utilize the Inspection Summary and Checklist form provided in the PRSC Plan included in the FCR. Within 30 days following each inspection, an inspection report will be prepared and submitted to EPA.

We would appreciate EPA's approval of the proposed revisions to the inspection frequencies, as outlined above. In the meantime, please call me if you have any comments or questions.

Sincerely,

Richard W. Gates Senior Project Manager - Environmental Remediation

Attachments

3 The September 2015 inspection was the last required inspection of the trees and shrubs planted in 2013. Consistent with prior inspections, the future inspections of the trees planted in 2014 will include the inspection of the trees planted in that year along the riverbank ofthe Upper Yi-Mile Reach (Area 9 on Figure 2-1 ).

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cc: Dean Tagliaferro, EPA John Kilborn, EPA* Christopher Ferry, ASRC Primus (electronic copy) Michael Gorski, MassDEP (electronic copy) Eva Tor, MassDEP (electronic copy of cover letter)* John Ziegler, MassDEP (electronic copy) Robert Leitch, USACE (electronic copy) Karen Pelto, MassDEP* Kenneth Munney, USFWS Scott Campbell, Avatar Environmental (2 hard copies+ electronic copy) Nancy E. Harper, MA AG* Nate Joyner, City of Pittsfield (electronic copy) Corydon Thurston, Executive Director, PEDA (electronic copy) James Gagnon, O'Reilly, Talbot & Okun (electronic copy) Barbara Landau, Noble, Wickersham & Heart (electronic copy of cover letter)* Roderic McLaren, GE* James Nuss, ARCADIS James Bieke, Sidley Austin Richard Nasman, Berkshire Gas Co.* Jack Yablonsky, Berkshire Gas Co.* Public Information Repositories GE Internal Repository

(* cover letter only)

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Table 1

Table 1: Results of Tree/Shrub Observations in East Street Area 2 South – September 2015

Planting Area

Species

Subject to Inspection in September

2015

Observed in Good Health

Observed Dead/

Stressed 1

Avg Height

(ft.)

Range of Heights

(ft.)

Percent in Good Health (%) 2

Percent Survival

(%) 3

1

Quaking Aspen

7 7 0/0 5.7 4 - 8 100 100

Cottonwood 1 1 0/0 5.0 - 100 100

Silky Dogwood

1 1 0/0 6.0 - 100 100

Black Cherry 1 1 0/0 5.0 - 100 100

American Elm

1 1 0/0 7.0 - 100 100

8 Cottonwood 1 1 0/0 5.0 - 100 100

9

Box Elder 3 3 0/0 5.0 4 - 6 100 100

Cottonwood 4 4 0/0 5.3 3 - 7 100 100

Red-osier Dogwood

1 1 0/0 2.0 - 100 100

Silky Dogwood

1 1 0/0 5.0 - 100 100

Black Willow 1 1 0/0 7.0 -- 100 100

11 Quaking Aspen

7 7 0/0 6.6 4 - 10 100 100

Infill Area

Box Elder 2 2 0/0 2.5 2 - 3 100 100

Black Cherry 2 2 0/0 4.5 4 - 5 100 100

Notes:

1. This column lists the number of dead trees/shrubs observed and then the number of trees/shrubs that were not dead but were stressed.

2. This column shows the percentage of trees/shrubs inspected that were in good condition relative to the total quantity inspected.

3. This column shows the percentage of trees/shrubs that were alive (including stressed plants) relative to the total quantity inspected.

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DETAIL A

GENERAL ELECTRIC COMPANY

PITTSFIELD, MASSACHUSETTS

EAST STREET AREA 2-SOUTH

4A

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PITTSFIELD, MASSACHUSETTS


RESTORATION PLANTING PLAN

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ORIGINALLY PLANTED

REPLANTED TREES/SHRUBS

TREES/SHRUBS

PLANTING

TREE/SHRUB SPECIES

AREA ID

HEIGHT

2012 2014

ORIGINALLY PLANTED

SPECIFICATION REQUIRED SUPPLEMENTAL


TREES/SHRUBS

(FT) OCTOBER OCTOBER

PLANTING

TREE/SHRUB SPECIES

HEIGHT

2012 2013 2014

AREA ID


(FT) OCTOBER NOVEMBER OCTOBER

ORIGINALLY PLANTED


TREES/SHRUBS

PLANTING

TREE/SHRUB SPECIES

HEIGHT

2012 2013 2014

AREA ID


(FT) OCTOBER NOVEMBER NOVEMBER OCTOBER

GENERAL ELECTRIC COMPANY PITTSFIELD, MASSACHUSETTS


RESTORATION PLANTING PLAN TABLES

FIGURE

2-2

Attachment A

Completed Inspection Checklist

INSPECTION SUMMARY AND CHECKLIST


I. GENERAL INFORMATION

Inspection Date: 9/3/2015 Conducted By/Phone Number: Gregg Rabasco / 413-822-1184 Weather Conditions: Sunny, 75-80 Date of Last Inspection: 5/12/2015

NA inspection performed on September 10, 2014.)

X Check here to confirm that Figures 6 and 7 of the Final Completion Report for the East Street Area 2-South Removal Action and the as-built survey drawings provided in Appendix D of that document have been reviewed in the field during the inspection.

Check here to confirm that the Post-Removal Site Control activities for the City Recreational Area have been performed (if necessary). (Most recent

A. Vegetated Portion of Engineered Barrier Area (Note any physical changes since last inspection, including evidence of the following conditions that would affect the integrity of the barrier components: topsoil erosion, bare or sparsely vegetated areas, deficiencies in the soil layer overlying the synthetic cover components [e.g., excessive erosion, surface water ponding, depressions, exposed synthetic cover components, vehicle ruts, or other abnormalities], damage to synthetic cover components, uneven settlement relative to surrounding areas, or other conditions that could jeopardize the integrity of the barrier [e.g., animal burrows, unauthorized excavation, etc.].) All areas in good condition.

II. INSPECTION SUMMARY 1. Engineered Barrier Area

-

Engineered Barrier Access Road (Note any physical changes since last inspection, including: excessive cracking, fissures, spalling, or potholes; evidence of uneven settlement, depressions, surface water ponding, excessive rutting, or exposed sub-base or exposed sub-grade materials; presence of nuisance vegetation [weeds]; damage to synthetic cover components; or other conditions that could jeopardize the integrity of the barrier.)

B.

All areas in good condition.-

C. Surface Water Diversions and Perimeter Drainage System Discharge Locations(Verify the proper function and integrity of these structures and evaluate whether drainage through or discharges from the outlets are causing erosion; inspect drainage swales and discharge locations for the accumulation of solids (if excessive, attempt to identify the source of the accumulated solids); evaluate whether there has been significant movement of riprap or reduction in riprap thickness that threatens the integrity of these structures or results in the erosion of underlying soils or sediment or the exposure of underlying geotextile fabric; also inspect drainage swales for the presence of tree saplings.) Saplings observed to be growing in swales and along swale edges.-

A. Backfilled/Restored Areas (Note any physical changes since last inspection, including evidence of topsoil or gravel erosion, effectiveness of erosion controls [in areas, if any, where vegetation is not established], depressions, surface water ponding/drainage problems, excessive settlement, burrows, vehicle ruts, and unauthorized excavations.)

All other areas in good condition.

All areas in good condition.

-

-

2. Open Soil/Vegetated Area

Vegetation (Note any physical changes since last inspection, including general condition of vegetative cover [e.g., evidence of stressed/sparse cover], trees/shrubs planted during the restoration activities, and tree guards/cages/stakes [where present]. Determine the percent survivorship of planted trees/shrubs, and measure and record the size of all trees and shrubs subject to inspection.)

B.

- Tree/shrub observations are included in Tables B-1 through B-14 (Planting Areas 1, 8, 9, 11, and Infill Area). All tree/shrubs were observed to be in good condition. No tree cages, guards, or stakes were installed.-

Enhanced Pavement Area (Note any physical changes since last inspection, including evidence of excessive cracking, fissures, spalling, rutting, exposed sub-base or exposed sub-grade materials, potholes, heaving, uneven settlement, presence of nuisance vegetation (weeds); depressions or surface water ponding/drainage problems; excessive settlement relative to the surrounding areas; or other conditions that could jeopardize the performance of the enhanced pavement, as designed.)

3.

- All areas in good condition.

Paved Areas to be Maintained by GE (Note any physical changes since last inspection, including: (1) in all such areas, evidence of excessive cracking, fissures, spalling, rutting, potholes, heaving, uneven settlement, exposed sub-grade or sub-base materials, or the presence of nuisance vegetation (weeds); and (2) in areas that were subject to remediation activities, excessive settlement relative to the surrounding areas, any drainage problems, and other conditions that could jeopardize the performance of the completed remediation.)

A.

All areas in good condition.

4. Other Ground-Covering Feature Area

-

B. Paved Areas and Foundation Slabs of Former (Demolished) Buildings Covered with Soil and Grass (or Riprap on a Portion of the Former Building 66 Slab) (Note any physical changes since last inspection, including: evidence of soil erosion; effectiveness of erosion controls [in areas, if any, where vegetation is not established]; the establishment, coverage, and condition of the vegetation planted on the soil cover [during the two-year vegetation inspection period]; evidence of depressions, surface water ponding, excessive settlement relative to surrounding areas, and/or drainage or growth problems; evidence of gaps in the riprap placed on a portion of the former Building 66 slab; or other conditions that could jeopardize the soil cover [e.g., animal borrows, unauthorized excavation, etc.].) Saplings observed to be growing on the former Building 63-X slab and along the south side of Building 65. All other areas in good condition.-

-

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INSPECTION SUMMARY AND CHECKLIST


II. INSPECTION SUMMARY (continued) 5. Groundwater Recharge Pond Area (Note any evidence, since last inspection, of disturbance, filling, or active drawdown of the water in the pond or other

interference with the pond’s function of providing hydraulic control of non-aqueous-phase liquid.) All areas in good condition.-

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

None-

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIES Remove saplings observed to be growing in swales and along swale edges.-

- Remove saplings observed to be growing on the former Building 63-X slab and along the south side of Building 65.

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Attachment B

Documentation of Tree/Shrub Observations

TABLE B-1 SUMMARY OF TREE/SHRUB OBSERVATIONS - PLANTING AREA: 1 - QUAKING ASPEN(POPULUS TREMULOIDES)

SUMMARY OF SEPTEMBER 2015 INSPECTION ACTIVITIES FOR EAST STREET AREA 2 - SOUTH GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS

Tree Height (ft.) Condition of Tree Condition of Tree Cage, Guard,

and Stakes (where present) Comments 1 5 Good NA Replanted 11/13 2 7 Good NA Replanted 11/13 3 5 Good NA Replanted 11/13 4 8 Good NA Replanted 11/13 5 4 Good NA Replanted 10/14 6 6 Good NA Replanted 10/14 7 5 Good NA Replanted 10/14

Average Height (ft.): 5.7 Height Range (ft.): 4- 8 Total Tree Count: 7

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TABLE B-2 SUMMARY OF TREE/SHRUB OBSERVATIONS - PLANTING AREA: 1 - COTTONWOOD (POPULUS DELTOIDES)



and Stakes (where present) Comments 1 5 Good NA Replanted 10/14

Average Height (ft.): 5.0 Height Range (ft.): --Total Tree Count: 1

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TABLE B-3 SUMMARY OF TREE/SHRUB OBSERVATIONS - PLANTING AREA: 1 - SILKY DOGWOOD (CORNUS AMOMUM)


Shrub Height (ft.) Condition of Shrub Condition of Tree Cage, Guard,


Average Height (ft.): 6.0 Height Range (ft.): --

Total Shrub Count: 1

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TABLE B-4 SUMMARY OF TREE/SHRUB OBSERVATIONS - PLANTING AREA: 1 - BLACK CHERRY (PRUNUS SEROTINA)





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TABLE B-5 SUMMARY OF TREE/SHRUB OBSERVATIONS - PLANTING AREA: 1 - AMERICAN ELM (ULMUS AMERICANA)





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TABLE B-7 SUMMARY OF TREE/SHRUB OBSERVATIONS - PLANTING AREA: 9 - BOX ELDER (ACER NEGUNDO)



and Stakes (where present) Comments 1 6 Good NA Replanted 11/13 2 5 Good NA Replanted 11/13 3 4 Good NA Replanted 10/14

Average Height (ft.): 5.0 Height Range (ft.): 4 - 6 Total Tree Count: 3

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and Stakes (where present) Comments 1 7 Good NA Replanted 11/13 2 5 Good NA Replanted 11/13 3 3 Good NA Replanted 11/13 4 6 Good NA Replanted 10/14


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TABLE B-9 SUMMARY OF TREE/SHRUB OBSERVATIONS - PLANTING AREA: 9 - RED OSIER DOGWOOD (CORNUS SERICEA)






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TABLE B-10 SUMMARY OF TREE/SHRUB OBSERVATIONS - PLANTING AREA: 9 - SILKY DOGWOOD (CORNUS AMOMUM)






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TABLE B-11 SUMMARY OF TREE/SHRUB OBSERVATIONS - PLANTING AREA: 9 - BLACK WILLOW(SALIX NIGRA)





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TABLE B-12 SUMMARY OF TREE/SHRUB OBSERVATIONS - PLANTING AREA: 11 - QUAKING ASPEN(POPULUS TREMULOIDES)



and Stakes (where present) Comments 1 7 Good NA Replanted 11/13 2 7 Good NA Replanted 11/13 3 7 Good NA Replanted 11/13 4 10 Good NA Replanted 11/13 5 5 Good NA Replanted 10/14 6 6 Good NA Replanted 10/14 7 4 Good NA Replanted 10/14


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TABLE B-13 SUMMARY OF TREE/SHRUB OBSERVATIONS - PLANTING AREA: INFILL AREA - BOX ELDER(ACER NEGUNDO)



and Stakes (where present) Comments 1 2 Good NA Replanted 11/13 2 3 Good NA Replanted 11/13


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TABLE B-14 SUMMARY OF TREE/SHRUB OBSERVATIONS - PLANTING AREA: INFILL AREA - BLACK CHERRY(PRUNUS SEROTINA)



and Stakes (where present) Comments 1 5 Good NA Replanted 11/13 2 4 Good NA Replanted 11/13

Average Height (ft.): 4.5 Height Range (ft.): 4-5 Total Tree Count: 2

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G:\GE\GE_Pittsfield_CD_ESA_2_South\Reports and Presentations\Inspections\09-15\ 1661511324TblsB-TreeShrubs.xls - Black Chery Infill Area 10/1/2015

Documents

Re: GE-Pittsfield/Housatonic River SiteResource Trustees, with a copy to EPA, on November 18, 2014. In addition, specific invasive species inspections were conducted in the NRRE area