RELEASE ABATEMENT MEASURE PLAN, ELECTRIC POWER RESEARCH INSTITUTE (EPRI… · 2020-03-14 · release abatement measure plan rtn 1-14205 electric power research institute lenox, massachusetts

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RELEASE ABATEMENT MEASURE PLAN

RTN 1-14205

ELECTRIC POWER RESEARCH INSTITUTE LENOX, MASSACHUSETTS

April 11,2002

Prepared for:

GENERAL ELECTRIC COMPANY SCHENECTADY, NEW YORK

Prepared by:

URS CORPORATION 646 PLANK ROAD, SUITE. 202 CLIFTON PARK, NY 12065

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URS

April 11, 2002

Department of Environmental Protection Western Regional Office Bureau of Waste Site Cleanup 436 Dwight Street, 5th Floor Springfield, Massachusetts 01103

RE: Vault Area Release Abatement Measure Plan Electric Power Research Institute 115 East New Lenox Road Lenox, Massachusetts RTN 1-14205

Dear Sir or Madam:

On behalf of our client, General Electric Power Systems (GEPS), URS Corporation (URS) submits one copy of the Vault Area Release Abatement Measure Plan (RAM Plan), dated April 11, 2002 as required by Massachusetts Contingency Plan (MCP) regulations (310 CMR 40.0000). The appropriate fee, established in 310 CMR 4.00, has been sent to the DEP Lock Box.

Any questions may be directed to Mr. Edward Jamison of GEPS at (518) 385-7979.

Very truly yours, URS Corporation

Eriko Fujita Project Manager

Don Porterfield, P.E. Manager - Clifton Park

cc: Edward F. Jamison, GEPS Kevin Mooney, GE CEP Kimberly McMorrow, Esq. - Wilson, Sonsini, Goodrich & Rosati Thomas P. Woodard, LSP - URS Corporation Thomas J. Nunno, P.E., LSP - Roux Associates

URS Corporation 646 Plank Road, Suite 202 Clifton Park, NV 12065 Tel 518 688 0015 GE-EPRI/Apnl 11, 2002 Fax 5186880022 1 91-28171712/L605 lldep doc

Massachusetts Department of Environmental Protectio BWSC-106 Bureau of Waste Site Cleanup

RELEASE & UTILITY-RELATED ABATEMENT Release Tracking MEASURE (RAM & URAM) TRANSMITTAL FORM

1 4 2 0 5 ] Pursuant to 310 CMR 40.0444 - 0446 and 310 CMR 40.0462 - 0465 (Subpart D)

A. SITE LOCATION:

Site Name: Rlppt-.rig PQWPT- R^gparnh

Street: 11S reaat-- NP»W T.pnnv Rnad Legation Aid: Formp-rTy 1000. NPW T.pnnx Rnad

CityfTown: T.pnnx ZIP 01340-2216

| | Check here if a Tier Classification Submittal has been provided to DEP for this Release Tracking Number.

Related Release Tracking Numbers That This RAM or URAM

B. THIS FORM IS BEING USED TO: (check all that apply)

! Submit a RAM Plan (complete Sections A, B. C, D, E, F, J, K, L and M).

D Check here it this RAM Plan Is an update or modification ot a previously approved written RAM Date Submitted: Plan. | | Submit a RAM Status Report (complete Sections A, B, C, E, J, K, L and M).

| | Submit a RAM Completion Statement (complete Sections A, B, C, D, E, G, J, K, L and M).

| | Confirm or Provide URAM Notification (complete Sections A, B, H, K, L and M).

| | Submit a URAM Status Report (complete Sections A, B, C, E, J, K, L and M).

| | Submit a URAM Completion Statement (complete Sections A, B, C, D, E, I, J, K, L and M).

You must attach all supporting documentation required for each use of form Indicated, Including copies of any Legal Notices and Notices to Public Officials required by 310 CMR 40.1400.

C. SITE CONDITIONS:

] Check here if the source of the Release or Threat of Release is known.

If yes, check all sources that apply: | | LIST | | Pipe/Hose/Line | | AST | | Drums | | Transformer Boat

0] otner sPecifyQJ Tanker Truck [~1 Vehicle Siihaii-rf anp vaiill-.q

Identify Media and Receptors Affected: (check all that I I Air I I Groundwater I 1 Surface Water I I Sediments C7I Soil =r,r,lw\ '-' '-' '-' '-' L5U

[J Wetlands Q Storm Drain D Private Well Q Public Water Supply Q Zone 2 [^] Residence

j—| acnoo r—| Unknown other Specify: ___

Identify Release and/or Threat of Release Conditions at Site: (check all that apply)

| | 2 and 72 Hour Reporting Condition(s) f^jT) 120 Day Reporting Condition(s) Other Condition(s)

Describe

D

RAMs may be conducted concurrently with an IRA only with written DEP approval URAMs may not be conducted if any 2 or 72 Hour conditions exist at the site.

unionnatea Identify Oils and Hazardous Materials Released: (check all that Oils | | Heavy Metals QrJwantc

| | Others Specify:

D. DESCRIPTION OF RESPONSE ACTIONS: (check all that apply)

D uepioymem 01 Aosoroant or uoruainmem | | Assessment and/or Monitoring Only Matarialc 21 Excavation of Contaminated Soils | | Temporary Covers or Caps

| | Re-use, Recycling or Treatment | | Btoremediation

O On Site 0 Off Site Est. Vol.:_ cubic yards [ [ Soil Vapor Extraction

Describe: | | Structure Venting System

D Kroouci or INAM_ Store ^ On Site Off Site Est. Vol.: _ _________ cubic yards Rorrtworv SECTION D IS CONTINUED ON THE NEXT PAGE.

Revised 2/24/95 Supersedes Forms BWSC-007, 008, 009 and 010 (in part) Page 1 of 4 Do Not Alter This Form

Massachusetts Department of Environmental Protection BWSC-106 Bureau of Waste Site Cleanup

RELEASE & UTILITY-RELATED ABATEMENT Release Tracking MEASURE (RAM & URAM) TRANSMITTAL FORM Pursuant to 310 CMR 40.0444 - 0446 and 310 CMR 40.0462 - 0465 (Subpart D)

D. DESCRIPTION OF RESPONSE ACTIONS (continued): varounowaier ireatment

QH Landfill Q Cover O Disposal EsL Vol.: 15_ . cubic yards I—I

] Removal of Drums, Tanks or Containers | | Air Sparging

Describe: .qiibstirfar-P Vanlt-.n | | Temporary Water Supplies

Removal of Other Contaminated Media | | Temporary Evacuation or Relocation of Residents

Specify Type and [ | Fencing and Sign Posting

Other Response Actions Describe

See 310 CMR 40.0442 for limitations on the scope and type of RAMs. See 310 CMR 40.0464 for performance standards for URAMs.

| | Check here if this RAM or URAM Involves the use of Innovative Technologies. DEP is interested in using this information to aid in creating an Innovative Technologies Clearinghouse.

Describe

E. TRANSPORT OF REMEDIATION WASTE: (If Remediation Waste has been sent to an off-site facility, answer the following

Name of

Town and State:.

Quantity of Remediation Waste Transported to

F. RAM PLAN:

| | Check here if this RAM Plan received previous oral approval from DEP as a continuation of a Limited Removal Action (LRA).

Date of Oral

| | If a RAM Compliance Fee is required, check here to certify that the fee has been submitted. You MUST attach a photocopy of the payment. See 310 CMR 40.0444(2) to learn when a fee is not required.

| | Check here If the RAM Plan is proposed for a Transition Site. If this is the case, you may need to attach an LSP Evaluation Opinion prior to undertaking the RAM, if not previously provided. See 310 CMR 40.0600 for further information about Transition Sites.

G. RAM COMPLETION STATEMENT:

If a RAM Compliance Fee is required in connection with submission of the RAM Completion Statement, check here to certify that the fee has been submitted. You MUST attach a photocopy of the payment. You owe this fee when submitting a RAM Completion Statement if you received oral approval of a RAM that continued an LRA, and have NOT previously submitted a RAM Plan and accompanying fee.

If any Remediation Waste will be stored, treated, managed, recycled or reused at the site following submission of the RAM Completion Statement, you must submit a Phase IV Remedy Implementation Plan, along with the appropriate transmlttal form, as an attachment to the

RAM Completion Statement.

H. URAM NOTIFICATION:

Identify Location Type: (check all that apply) Q Public Right of Way \^\ Utility Easement Private Property

Identify Utility Type: (check all that | | ^^^Jane \ I Water Natural Gas

| | Telephone | | Steam Lines | | Telecommunications | | Electric | | Other Specify: I—I onecK nere n you proviaea utr wnn previous oral nouncaiion 01 mis Date of O al

[~~| Check here if the property owner was NOT contacted prior to initiation of the URAM. If this is the case, you must attach an explanation of why the owner was not contacted, including the date and time when contact ultimately occurred. Check here if this URAM will occur In connection with the construction of new public utilities. If this is the case, document the nature

I and extent of encountered contamination, the scope and expense of necessary mitigation and the benefits amd limitations of project alternatives.

With the exception stated below, the person undertaking the URAM must provide the name and license number of an LSP engaged or employed in connection with the URAM:

LSP Name: LSP License Number:.

LSP information is not required if the URAM is limited to the excavation and/or handling of not rnore than 100 cubic yards of soil contaminated by Oil, or not more than 20 cubic yards of soil contaminated either by a Hazardous Material or a mixture of a Hazardous


I

I


RELEASE & UTILITY-RELATED ABATEMENT Release Tracking MEASURE (RAM & URAM) TRANSMITTAL FORM Pursuant to 310 CMR 40.0444 - 0446 and 310 CMR 40.0462- 0465 (Subpart D)

I. URAM COMPLETION STATEMENT:

| Check here if this URAM was limited to the excavation and/or handling of not more than 100 cubic yards of soil contaminated by Oil. or not more than 20 cubic yards of soil contaminated by either a Hazardous Material or a mixture of a Hazardous Material and Oil.

If any Remediation Waste will be stored, treated, managed, recycled or reused at the site following submission of the URAM Completion Statement, you must submit either a Release Abatement Measure (RAM) Plan or a Phase IV Remedy Implementation Plan, along with the

appropriate transmittal form, as an attachment to the URAM Completion Statement

J. LSP OPINION:

I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal. In my professional opinion and judgment based upon application of (I) the standard of care in 309 CMR 4.02(1), (ii) the applicable provisions of 309 CMR 4.02(2) and (3), and (iii) the provisions of 309 CMR 4.03(5), to the best of my knowledge, information and belief,

> if Section B of this form Indicates that a Release Abatement Measure Plan Is being submitted, the response actlon(s) that Is (are) the subject of this submittal (I) has (have) been developed in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, (II) Is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000 and (HI) complles(y) with the identified provisions of all orders, permits, and approvals identified In this submittal;

> if Section B of this form indicates that a Release Abatement Measure Status Report or a Utility-Related Abatement Measure Status Report is being submitted, the response action(s) that Is (are) the subject of this submittal (i) Is (are) being implemented in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response actlon(s) as sei forth in the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000 and (iii) complies(y) with the identified provisions of all orders, permits, and approvals Identified in this submittal;

> if Section B of this form indicates that a Release Abatement Measure Completion Statement or a Utility-Related Abatement Measure Completion Statement is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed and implemented in accordance with the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000, (ii) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M.G.L. c. 21E and 310 CMR 40.0000 and (iii) complies(y) with the identified provisions of all orders, permits, and approvals Identified in this submittal;

I am aware that significant penalties may result, Including, but not limited to, possible fines and imprisonment, if I submit information which I know to be false, inaccurate or materially incomplete.

| | Check here if the Response Action(s) on which this opinion is based, if any, are (were) subject to any order(s), permit(s) and/or approval(s) issued by DEP or EPA. If the box is checked, you MUST attach a statement identifying the applicable pro

LSP Name: Thomas P. Wnndard LSP #: 141Q Stamp:

Telephone: 207-879-7686

FAX: (optional) ?r)7-fl7q-7fif l THOMAS P. WfX-f.ARD

Signature:

Date: 2-,

An LSP Opinion Is not required for a Utility-Related Abatement Measure Notification.

An LSP Opinion Is not required for a URAM Completion Statement If the URAM Is limited to the excavation and/or handling of not more than 100 cubic yards of soil contaminated by Oil, or not more than 20 cubic yards of soil contaminated either by Hazardous Material or

a mixture of Hazardous Material and Oil.

K. PERSON UNDERTAKING RAM OR URAM:

Name of Qpnpral Kl pr!hri r Pnwpr Systems

Name of RdwarH .Tanri Title: F.HS af.i nn Manager

Street: One Rivpr 4^ ,_ Bnnm 237...

City/Town: _S State: NY ZIP Code: 1 3 ^ 4 5 - 0 0 0 0

Telephone: Ri R - T R 5 - 7 9 7 9 Ext.: FAX:

Check here if there has been a change in person undertaking the RAM or URAM.



RELEASE & UTILITY-RELATED ABATEMENT Release Tracking

MEASURE (RAM & URAM) TRANSMITTAL FORM Pursuant to 310 CMR 40.0444 - 0446 and 310 CMR 40.0462 - 0465 (Subpart D)

RELATIONSHIP TO SITE OF PERSON UNDERTAKING RAM or URAM: (check one)

] RP or PRP Specify: Q Owner Q Operator Q Generator Q Transporter Other RP or PRP: Former Owner

] Fiduciary, Secured Lender or Municipality with Exempt Status (as defined by M.G.L. c. 21E, s. 2)

] Agency or Public Utility on a Right of Way (as defined by M.G.L. c. 21E, a. 50))

~~j Any Other Person Undertaking RAM or URAM Specify

M. CERTIFICATION OF PERSON UNDERTAKING RAM OR URAM:

Jami gnn , attest under the pains and penalties of perjury (I) that I have personally examined and am familiar with the information contained In this submittal, Including any and all documents accompanying this transmittal form, (II) that, based on my inquiry of those Individuals Immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (ill) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal. I/the person or entity on whose behalf this submittal Is made am/Is aware that there are significant penalties, including, but not limited to, possible fines and Imprisonment, for willfully submitting false, Inaccurate, or incomplete information.

,60n«&()£rt£By: fl/Wn?S.^/ "•>_>js*— ') . V " '_; " ~> V\ '„•>£ p'ri/> y, Title: _EHS_

nature)

Rlent-.-rir! Pnwpr Date: (print name of person or entity recorded in Section K)

Enter address of person providing certification, if different from address recorded in Section

Street: _ __

City/Town: ___ State: ZIP Code:

Telephone: Ext.: FAX: (optional)

YOU MUST COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING

A REQUIRED DEADLINE.


TABLE OF CONTENTS

1.0 INTRODUCTION 1 2.0 PERSON ASSUMING RESPONSIBILITY FOR RAM 2 3.0 CURRENT SITE CONDITIONS 3 4.0 DESCRIPTION OF RELEASE 6 5.0 SURROUNDING RECEPTORS 10 6.0 RELEASE ABATEMENT MEASURE 11

6.1 OBJECTIVES 11 6.2 STRATEGY 11 6.3 SCOPE OF WORK 12

6.3.1 Task 1 -Notifications 13 6.3.2 Task 2 - Remove and Dispose Contents of Each Vault 13 6.3.3 Task 3 - Excavate and Dispose Selected Vaults and Surrounding Soil 14 6.3.4 Task 4-Restoration of the Area 15 6.3.5 Task 5 -Submit Response Action Outcome Statement 15

7.0 MANAGEMENT OF REMEDIATION WASTE 16 8.0 ENVIRONMENTAL MONITORING PLAN 17 9.0 SCHEDULE 18 10.0 SEAL AND SIGNATURE OF LSP 19

TABLES

Table 1 Summary of Extractable Petroleum Hydrocarbon Results - Soil Sample Table 2 Summary of Polychlorinated Biphenyl Results - Soil Samples Table 3 Summary of Extractable Petroleum Hydrocarbons Results - Water Samples Table 4 Summary of Polychlorinated Biphenyl Results - Water Samples

FIGURES

Figure 1 Site Location Figure 2 Site Map Figure 3 Vault Area Figure 4 Generalized Potentiometric Surface Map, January 17, 2001 Figure 5 Massachusetts GIS Site Scoring Map Figure 6 Vault Investigation

APPENDIX

Appendix A Release & Utility-Related Abatement Measure (RAM & URAM) Transmittal form (BWSC-106)

Appendix B Permit and WPA Form 5 - Order of Conditions Appendix C Boring Logs

GEPS-EPRI URS 91-28171712.007L6051R-rev.doc April 11,2002

1.0 INTRODUCTION

On behalf of GE Power Systems (GEPS), URS has prepared this Release Abatement Measure

Plan (RAM Plan) for submittal to the Massachusetts Department of Environmental Protection

(DEP). The RAM Plan summarizes how GEPS will decommission 13 out-of-service

underground vaults at the Electric Power Research Institute (EPRI) High Voltage Transmission

Research Center (HVTRC) in Lenox, Massachusetts. An original Release & Utility-Related

Abatement Measure Transmittal Form (BWSC-106) is included with this RAM Plan, and a copy

of the form is included in Appendix A.

The location of the EPRI site is shown on Figure 1, and a generalized site map showing the

buildings and features on the property is included as Figure 2. The vault area is shown on Figure

3. The underground vaults are reported to have been used historically at the site for the

research/development and evaluation of various types of electrical equipment (apparently

including transformers). In November 2000, samples of the materials present in all 13 vaults

were collected and submitted for laboratory analysis. The laboratory analytical data indicated

the presence of polychlorinated biphenyls (PCBs) and extractable petroleum hydrocarbons

(EPH) compounds at concentrations that exceeded Reportable Concentrations (RCS-2). On

January 28, 2001, GEPS was notified of these exceedances by EPRI's legal counsel. On May 5,

2001 GEPS submitted the Release Notification Form (RNF) to the DEP regarding the vault

findings. The RTN 1-14205 was assigned to the release associated with the vaults by DEP in its

Notice of Responsibility letter dated December 13, 2001. The vaults are not associated with the

original release notification (RTN 1-1083) provided to the DEP in relation to a former kerosene

release. There are no other RTNs associated with the EPRI site.

This RAM Plan includes the required elements set forth in 310 CMR 40.0444. This RAM Plan is

being submitted prior to Tier Classification of the site. The appropriate fee established in 310

CMR 4.00 has been sent to the DEP Lock Box concurrently with this RAM Plan. GEPS will not

implement this RAM Plan until the DEP has issued a written approval of the RAM Plan, or the

DEP does not issue written approval or denial of the RAM Plan within 21 days of its receipt, in

which approval shall be presumed.

GEPS-EPRI 1 URS 91-28171712.00/L6051R-rev.doc April 11,2002

2.0 PERSON ASSUMING RESPONSIBILITY FOR RAM

The person assuming responsibility for the RAM on behalf of GEPS is:

Mr. Edward F. Jamison, P.G. GE Power Systems One River Road Building 43, Room 237 Schenectady, NY 12345 (518)385-7979 EHS Project Manager - Remediation

Mr. Jamison is a project manager for investigative and remedial projects at GEPS sites in the

United States and abroad.


3.0 CURRENT SITE CONDITIONS

This section describes the current site conditions including the location, site features, nearby

natural resource areas, and geology and hydrogeology.

Site Location and Features

The EPRI property is at 115 East New Lenox Road in Berkshire County, in Lenox,

Massachusetts. A small area at the northern end of the property lies within the corporate

boundary of Pittsfield, Massachusetts. The property comprises about 33 acres and is

approximately seven miles north of the Massachusetts Turnpike. The Universal Transverse

Mercator coordinates of the EPRI site are 4,695,576.7 meters north and 64,514.6 meters east.

The latitude and longitude of the EPRI site are N 42° 24' 3.6" and W 73° 14' 3.4". The location

of the EPRI property is illustrated in Figure 1.

EPRI HVTRC conducts research on high voltage electrical transmission equipment at the site.

In 1958, GEPS acquired the property and built the HVTRC. In 1985, GEPS gifted the property

to EPRI. GEPS continued to operate the facility for EPRI, until late 1994. The site was operated

by J.A. Jones Power Delivery Inc., of Charlotte, North Carolina, from January 1995 to December

1998, when EPRI assumed operational responsibilities. Currently, the HVTRC tests insulator

performance, flashover prevention, corona phenomena, and electrical and magnetic fields.

Historically, tests on transformers were conducted in the vaults.

Figure 2 is a generalized site map of the EPRI property east of the Housatonic River. As shown

in Figure 2, EPRI's property includes six buildings: the headquarters building, the UHV Building

(also known as the salt fog contamination chamber), the EHV Building (also known as the aging

chamber), a garage, a storage building, and the EPRI office building. As shown in Figures 2 and

3, the vaults are west of the EHV Building and adjacent to an ox-bow of the Housatonic River.

The property is listed as Parcel No. 1 in the Lenox Tax Assessor's Map 34. The property is

zoned residential 20-30-40. Properties adjacent to the site are zoned agricultural, residential, or


State Wildlife Management area. Potable water is supplied to the EPRI site from the City of

Pittsfield. Domestic sewage is collected in a septic tank that drains to an onsite leach field.

Access to EPRI's property is restricted by a chain-link fence topped with barbed wire. The

entrance to the site is an access road on East New Lenox Road. Access to the vault area is via an

existing road on EPRI's property near the northwest fence line. Therefore, the potential for

unauthorized access to the site is low. Soil categories S-2 and S-3 are appropriate for the site.

Topography

The topography of the site east of the Housatonic River slopes gently westward, from elevations

of approximately 985 to 950 feet above the National Geodetic Vertical Datum (NGVD). The

highest elevation near the site is the summit of Sykes Mountain, approximately one mile east-

northeast of the site. The elevation of Sykes Mountain is approximately 1,700 feet NGVD. The

vault area is at an elevation of approximately 953 feet msl and is within a relatively level area

adjacent to the ox-bow of the Housatonic River.

Geology and Hydrogeology

The overburden deposits at the EPRI site are comprised of glacio-fluvial sediments of the

Housatonic River valley, consisting of poorly sorted, fine- to coarse-grained silts and sands, with

a trace of gravel.

According to the United States Geological Survey's Bedrock Geological Map of Massachusetts

(1983), the bedrock underlying the site is the Dalton Formation, a Cambrian muscovite

microcline quartzite and feldspathic quartzite, and the overlying Stockbridge Formation, a

quartzose calcite and dolomite marble (Zen, 1983). The steep topography east of the site marks

where large-scale Taconic-aged faulting thrust the Proterozoic Tyringham Gneiss and the

Cambrian Cheshire Quartzite over the younger Dalton Formation that underlies the site (Zen,

1983). The depth to bedrock beneath the site is uncertain. Bedrock has not been encountered in

drilling conducted to date at the site.

GEPS-EPRI 4 URS 91-28171712.007L6051R-rev.doc April 11,2002

At present, there are 12 groundwater monitoring wells at the EPRI property (associated primarily

with RTN 1-1083). The locations of the wells are shown on Figure 4, which is a potentiometric

contour map for overburden groundwater at EPRI's property on January 17, 2001. As shown,

the nearest groundwater monitoring wells to the vault area are wells MW-8 and MW-4.

Groundwater beneath EPRI's property, east of the Housatonic River flows toward the southwest.

The groundwater under the EPRI site is classified as category GW-2 and GW-3 within the

Massachusetts Contingency Plan (MCP) regulations regarding risk characterization. Category

GW-2 groundwater represents a potential source of vapors of oil or hazardous material to indoor

air. Category GW-3 groundwater represents a potential source of discharge to surface water.

Natural Resource Areas

As shown in Figures 1 and 2, the Housatonic River flows along the western border of the EPRI

property. As shown on Figure 3, the vault area is within a Bordering Vegetative Wetland

(BVW). Much of the property and the vault area are within the 100-year floodplain of the

Housatonic River. Four oxbows of the river are within 500 feet of the site. The river is not

considered a Class A surface water body. An unnamed stream flows westward from Sykes

Mountain and passes approximately 500 feet from the site.

The DEP Bureau of Waste Site Cleanup Geographic Information Systems Site Scoring Map

(GIS Map) of the EPRI property is included as Figure 5. As shown on Figure 5, there are no

approved Zone II Interim Wellhead Protection Areas or public surface water supply areas within

one-half mile of the site. There are two protected open space areas within one-half mile of the

site. These areas appear to be associated with the Housatonic River Valley State Wildlife

Management Area shown on Figure 1. The first area is approximately 0.2 miles north of the site.

The second area appears to border the southwestern portion of the site. The southern part of

EPRI's property includes fresh water wetlands, as well as, National Heritage and Endangered

Species Program (NHESP) Wetlands Habitat. Finally, the adjacent Housatonic River is a fish

habitat area.


4.0 DESCRIPTION OF RELEASE

Thirteen unused concrete vaults are the subject of this RAM Plan. The location of the vaults is

shown in Figure 3. The series of vaults are located along an approximate north-to-south trend

adjacent to an oxbow of the Housatonic River in the northwest area of the EPRI property. Vault

1 (V-l) (located at the south end) is a 6 feet by 12 feet by 7 feet deep rectangular shaped concrete

vault with a solid bottom. The remaining vaults (V-2 through V-l3) are 3 feet diameter by 6 feet

deep cylindrically-shaped concrete vaults. The nature of the construction of the 12 cylindrically-

shaped vaults is not fully understood, but investigations performed to date suggests that the bases

of some of the cylindrically-shaped vaults is not solid concrete, but rather is gravel. All 13

vaults have removable metal grate covers.

On November 29, 2000, EPRI's consultant, Roux Associates (Roux), evaluated the

environmental condition of the vault contents. Roux sampled solid media (e.g., soil) present in

the 13 vaults and collected water samples from four of the vaults. A total of 14 solid samples

and five water samples were analyzed for polychlorinated biphenyl (PCB) via EPA Method 8082

and extractable petroleum hydrocarbon (EPH) compounds via MADEP Method 98-1. On

January 28, 2001, GEPS received a copy of a letter report prepared by Roux from EPRI's legal

counsel summarizing the results of sampling activities. The analytical data for the soil samples

are summarized in Tables 1 and 2. The soil sampling results indicated the presence of EPH

compounds in some soil samples at relatively low concentrations, with detections above

applicable Massachusetts Contingency Plan (MCP) Reportable Concentrations in only a couple

instances (Table 1). The soil sampling results showed the presence of PCBs in some of the

vaults at concentrations above applicable MCP Reportable Concentrations RCS-2 (Table 2). The

analytical results for the water samples are summarized in Table 3 and 4. These results

document the absence of PCBs in water samples and show the presence of EPH compounds in

only two samples below MCP Reportable Concentrations.

On February 22, 2001, on GEPS's behalf, URS conducted an inspection of the vaults to

investigate whether the vaults appeared to have solid (e.g., concrete, etc.,) bases. The inspection

suggested that the 12 cylindrical vaults have solid cross members across a portion of their bases;


however, other areas within the vaults did not appear to be solid. The base of the one rectangular

vault appeared to be concrete.

On May 5, 2001, GEPS submitted a Release Notification Form (RNF) to the DEP regarding the

vault findings reported by Roux. The DEP assigned RTN 1-14205 to the vault area in its Notice

of Responsibility letter to GEPS, dated December 13, 2001.

Following review and approval by EPRI, GEPS finalized a vault investigation work plan, dated

May 11, 2001. The objective of the work plan was to gather additional data to further evaluate

subsurface conditions near the vaults in order to develop a plan to close the vaults. The first task

of the work plan was to conduct a wetland survey to evaluate if the vaults were located within a

wetland or wetland buffer zone. On June 11, 2001, Beaver Brook Environmental Consultants,

LLC conducted the wetland survey, which confirmed that the vaults are within a bordering

vegetative wetland (BVW). The delineation of the BVW is shown on Figure 3.

In order to proceed with the vault investigation on behalf of GEPS, URS filed a Notice of Intent

(NOI) application package with the Lenox Conservation Commission (LCC) on October 18,

2001. On November 1, 2001, the LCC approved the NOI application at a public meeting, and on

November 26, 2001 the LCC issued permit number 198-186 (provided by DEP) and an Order of

Conditions to GEPS. A copy of the permit and Order of Conditions is provided in Appendix B.

December 2001 Investigation

On December 7, 2001, immediately following receipt of the permit and Order of Conditions,

URS conducted an investigation to evaluate subsurface conditions near the vaults. Seven soil

borings (SB-113 through SB-119) were advanced to depths of 8 to 12 feet below ground surface

(bgs) using a Geoprobe. The soil boring locations are shown on Figure 6. The boring logs are

provided in Appendix C. A 4- to 5-foot thick layer of gray silty sand, which overlies a one-foot

thick gravel layer, was encountered coincident with the total depth of the vaults at the soil

borings advanced between the vaults (SB-113 through SB-116). A fine to coarse sand was


generally encountered beneath the gravel. The gravel layer was thin or absent at soil borings SB

117 through SB-119, which were advanced approximately one-foot on either side of the vaults.

URS collected eight soil samples for laboratory analysis from the seven soil borings advanced

adjacent to the vaults. The soil samples were analyzed for PCBs (EPA Method 8082) and EPH

compounds (MADEP Method 98-1). A grain size analysis was also conducted on the material

collected from 0 to 4 feet bgs from boring SB-117 and it was determined to be sandy silt with

trace clay. The analytical results from these soil borings are presented in Tables 1 and 2. The

analytical data indicates that EPH compounds were not detected above MCP Method 1 S-2 Soil

and GW-2/GW-3 Standards in any of the seven soil samples. PCBs were encountered above the

Method 1 risk standards at SB-114 between Vaults V-3 and V-4. PCBs were not detected above

the Method 1 risk standards at the other five borings.

As part of the December 7, 2001 field investigation, URS conducted additional probing to assess

whether the vaults have solid or soft bases. The solid bottom at vault V-l was measured at 6.8

feet bgs. However, observations suggested that the cylindrically-shaped vaults do not have solid

bottoms. Based on the data from these soil samples, GEPS has elected to advance additional soil

borings to further characterize the condition of soil surrounding the vaults. This information will

be used to determine the appropriate degree and extent of the corrective action efforts during

implementation of the RAM Plan.

March 2002 Investigation

The scope of the additional characterization work included the advancement of 23 soil borings to

a minimum depth of 14 feet bgs between and within the Vaults V-2 through V-l3 to complete

the characterization of the materials in the vault area. The objective of the borings was to

delineate the extent of impacted materials in the vault area and develop sufficient data about

subsurface conditions to be able to evaluate potential risks.

On March 27 and 28, 2002, the 23 soil borings were advanced using a Geoprobe. The soil

boring locations are shown on Figure 6. Soil boring SB-121 was advanced at former boring

GEPS-EPRI 8 URS 91-28171712.007L6051R-rev.doc April 11, 2002

location SB-114 to confirm the December 2001 analytical results and delineate the depth of

impacted materials. Soil borings SB-120 through SB-128 were advanced between the vaults.

Soil borings VSB-2 through VSB-13 were advanced within vaults V-2 through V-13. Because

Vault V-l has a concrete bottom at approximately 6.8 feet bgs, a soil boring was not advanced

within Vault V-l. The boring logs are provided in Appendix C

Soil samples were collected from beneath the horizon of the gravel layer that was previously

encountered within and between certain vaults. Based on observations made by URS in

February 2001 and the soil borings advanced in the vault area in December 2001, the gravel

layer within and between the vaults is at a depth of approximately 5.5 to 7 feet bgs. The soil

samples from directly beneath the gravel layer were collected between 7 to 10 feet bgs at 22 of

the 23 soil borings. The soil sample from soil boring VSB-2 was collected from 10 to 12 feet

bgs, because the gravel layer at Vault V-2 extended to 10 feet bgs. Two additional soil samples

each boring were collected (e.g., 10 to 12 feet bgs, and 12 to 14 feet bgs) and archived for

possible analysis.

The soil samples collected from beneath the gravel layer from each boring were analyzed for

PCBs (Method 8082). Selected soil samples were also analyzed for EPH compounds (MADEP

98-1). The analytical results from these soil borings are presented in Tables 1 and 2. PCBs were

not detected above 2 mg/kg in the 24 soil samples collected in March 2002. EPH compounds

were not detected above laboratory detection limits in the seven soil samples collected in March

2002. Based on the results of these soil samples, no additional soil samples were analyzed.

GEPS-EPRI 9 URS 91-28171712.007L6051R-rev.doc April 11, 2002

5.0 SURROUNDING RECEPTORS

Potential human receptors at the EPRI site who may come into contact with the potentially-

impacted soils within and near the vaults include the adult employees and trespassers. However,

the vaults are subsurface structures with heavy covers, so the potential for access to the contents

and surrounding soils is extremely limited. Potential offsite human receptors, such as the

residents of abutting properties and workers, are even more unlikely to ingest, inhale, or contact

the vaults contents and potentially impacted subsurface soils.

Receptors that may be affected by potentially contaminated water include humans and

environmental receptors such as benthic and aquatic organisms in the Housatonic River. There

are no public or private water supply wells near the EPRI site.

GEPS-EPRJ 10 URS 91-28171712.00/L6051R-rev.doc April 11,2002

6.0 RELEASE ABATEMENT MEASURE

This section provides the objective, strategy, and scope of work for this RAM Plan.

6.1 OBJECTIVES

The objective of the Vault RAM is to:

Remove, if appropriate based on risk, and properly dispose of the contents and contaminated soil

near the vaults to mitigate any significant risk posed to human health or the environment.

6.2 STRATEGY

The strategy for addressing the vaults relies on using analytical data from the characterization

work to guide the degree and extent of any removal/excavation during implementation of the

RAM Plan. The characterization work, which was conducted prior to implementing the RAM,

includes the advancement of soil borings and collection of soil samples for laboratory analysis.

The analytical results from the various phases of investigation provide a detailed environmental

quality database documenting the degree and extent of compounds of concern in the subsurface

surrounding the vaults. These data will be used to develop the nature and scope for any

excavation/removal activities to be performed to address any excess risk posed by the

compounds of concern. Specifically, these data will be used to determine the corrective action

approach and the vertical/lateral extent of any soil excavation. The degree of any excavation will

extend to sufficient degree to ensure that any impact surpassing the cleanup criteria will be

removed to mitigate any excess risk. This approach, which essentially involved the collection of

characterization samples, which are equivalent to post-excavation samples, prior to the actual

soil removal effort, has been developed to facilitate the following:

• Lessens the overall amount of physical disturbance in the vault area, which is in a wetland

area.

GEPS-EPRJ 11 URS 91-28171712.007L6051R-rev.doc April 11,2002

• Eliminates the need to keep the excavation area open pending receipt of analytical results

since post-excavation samples will not be collected. Thus, we will be able to backfill any

excavations after we reach the target excavation depths (which will be defined based on pre

excavation sampling results).

• Diminishes the risk of harm to onsite workers or potential trespassers from falling into an

open excavation.

• Diminishes the risk of harm to the local animal population from falling into an open

excavation.

• Lessens concern over potential flooding or collapse and undermining of the excavation area

in the wetland.

• Avoids potential problems associated with collecting representative post-excavation samples

recognizing that any excavations will extend below the water table.

• Diminishes the potential need to dewater the area during implementation of the RAM, which

could limit access to the available work area with the placement of temporary water holding

tanks nearby. This also reduces the potential of disturbing the wetland by trucks needed to

unload/load the holding tanks and other associated equipment (hoses).

• Less risk of transporting contamination downward from the impacted areas by dewatering.

As described in Section 4.0, prior to the implementation of the Vault RAM, an additional

investigation was conducted to complete the characterization of release from the vaults. The

additional investigation work was conducted on March 27 and 28, 2002. The results of this

additional investigation will be used, in conjunction with the currently available analytical data,

to define the extent of removal actions and serve to delineate the excavation during the Vault

RAM.

6.3 SCOPE OF WORK

The RAM will comprise these five tasks that URS and its subcontractors will implement on

GEPS' behalf:

Task 1 - Notifications;


Task 2 - Remove and Dispose the Contents of Each Vault;

Task 3 - Excavate and Dispose Selected Vaults and Surrounding Soil;

Task 4 - Restoration of the Area; and

Task 5 — Submit Response Action Outcome Statement.

6.3.1 Task 1 - Notifications

URS will provide notification that the Vault RAM will be implemented to the Chief Municipal

Officer, the Board of Health, and the Fire Department of the Town of Lenox. The written

notification will be submitted to these agencies immediately after the RAM Plan is filed with the

DEP, and the work will not commence until seven days after the notification is received by the

Town agencies. The Lenox Conservation Commission (LCC) will also be notified of the Vault

RAM implementation schedule. Note that the Order of Conditions, which was previously issued

by the LCC, covers the activities associated with this RAM.

6.3.2 Task 2 - Remove and Dispose Contents of Each Vault

Depending upon evaluation of the results of the findings of the investigations near the vaults, it

may be necessary to remove impacted materials from the vault area in accordance with Permit

198-186 and the Order of Conditions, issued by the LCC on November 26, 2001. Prior to the

start of field activities, the condition of the silt fence, which was installed in December 2001,

will be assessed. If the condition of the silt fence has deteriorated, it will be repaired or replaced.

Based on the investigation findings, the materials from within the vaults will be removed. A

vacuum truck will be used to remove the material from within each vault to the depth determined

from the soil boring/sampling program. The interior of each vault will be inspected. Based on

the inspections, GEPS may elect to collect samples, if appropriate, to evaluate whether treatment,

isolation, or removal of any vault is warranted. If the removal depth extends beyond the

accessibility of the vacuum truck, the vault and associated materials will be excavated (See

Task 3).


6.3.3 Task 3 - Excavate and Dispose Selected Vaults and Surrounding Soil

Depending upon evaluation of the findings of the results of the investigations near the vaults, it

may be necessary to excavate and remove vaults and surrounding soils to sufficiently remove

soil impacted with compounds at levels of concern. The analytical results for the soil samples

collected during the additional characterization work and the previously collected data will be

used to establish the degree and extent of any vault or soil removal during the RAM. Wastes

generated during any vault or soil removal efforts will be placed into rolloff container(s) or

vacuum truck that will be staged onsite pending waste-characterization analysis and off-site

disposal at a properly licensed facility.

The anticipated criteria that will be used to define removal areas and depths are:

• If soil data from a boring between vaults are averaged with other data from soil that will

remain in place and the average residual concentration is found to exceed risk-based MCP

criteria, then the vaults on either side (except for Vault V-l) of the soil boring and the

impacted soil will be removed.

• If soil data from a boring from between vaults are averaged with other data from soil that will

remain in place and the average residual concentration is found to be below risk-based MCP

criteria, then this area will be left in place.

• If soil data collected from beneath a vault area averaged with other data from soil that will

remain in place and the average residual concentration is found to exceed risk-based MCP

criteria, then the impacted soils (and likely the vault) will be removed.

• If soil data collected from beneath a vault are averaged with other data from soil that will

remain in place and the average residual concentration is found to be below risk-based MCP

criteria, then the vault will not be removed. However, the contents of the vaults will be

removed for off-site disposal.

Pending evaluation of the soil data, GEPS may elect to modify these criteria so long as the

modifications are consistent with the goals of the RAM Plan. Either Method 1 or a Method 3


risk criteria characterization will be performed to ensure the extent of remediation is adequate to

protect human health and the environment, per MCP regulations.

6.3.4 Task 4 - Restoration of the Area

Following completion of the corrective action effort, URS' subcontractor will backfill the

excavations and restore the area. Clean fill with similar physical parameters (e.g., silty sand) as

the native materials at the site will be used to fill the vaults and replace soil that is removed from

the work area to approximate original grades. The area will then be seeded with the wetland

seed mixture and mulched as provided in the NOI.

6.3.5 Task 5 -Submit Response Action Outcome Statement

When the objectives of the RAM Plan have been met and the remedial actions are completed,

GEPS will submit a Response Action Outcome Statement (RAO) to the DEP. The RAO will

include the elements set forth in 310 CMR 40.1000. The report will be submitted to the DEP

within 60 days of the completion of the RAM or within 120 days of obtaining oral, written, or

presumed approval of the RAM Plan by DEP, whichever is sooner.


7.0 MANAGEMENT OF REMEDIATION WASTE

The remediation waste will be managed in accordance with the provisions set forth in 310 CMR

40.0030. Any excavated soil, vault materials, and solid vault contents will be staged in a rolloff

container pending proper offsite disposal. Fluids that may be removed during the RAM will be

either disposed of via the vacuum truck or temporarily stored in drums or a holding tank pending

proper off-site disposal.

GEPS-EPRI 16 URS 91-28l7I712.00/L6051R-rev.doc April 11,2002

8.0 ENVIRONMENTAL MONITORING PLAN

Air monitoring will be performed during the implementation of the Vault RAM according to

URS's site-specific Health and Safety Plan (HSP). Action levels and contingencies for air

monitoring results in the work area that are above background levels will be established in the

HSP. In addition, the remediation contractor selected for the project will be required to develop

and implement their own Health and Safety Plan, which must be at least as stringent as URS's

HSP. Access to the work area will be strictly limited to necessary personnel, thus limiting

potential exposure. If dusty conditions occur, dust control measures, such as water sprays, will

be implemented.

GEPS-EPRI 17 URS 91-28171712.007L6051R-rev.doc April 11,2002

9.0 SCHEDULE

GEPS will not initiate the Vault RAM until the DEP has issued a written approval of the RAM

Plan, or after 21 days following the DEP receipt of the RAM Plan, in which case approval shall

be presumed. Therefore, GEPS anticipates that it will begin implementing the Vault RAM on or

about 21 days after it is submitted to the DEP.

GEPS plans the following schedule for implementation of this RAM.

Task Weeks after RAM Plan Submittal

Immediately Task 1 - Notifications

Task 2 - Remove and Dispose the Contents of each 3 to 4 Vault Task 3 - Excavate and Dispose Selected Vaults and 3 to 4 Surrounding Soil

3 to 4 Task 4- Restore the Area

4 (May 11,2002) Task 5 - Submit Response Action Outcome Statement


10.0 SEAL AND SIGNATURE OF LSP

The seal and signature of the LSP is provided in Section J of the original Release and Utility-

Related Statement Measure Transmittal Form (BWSC-106), which has been submitted to DEP

with this report. A copy of Form BWSC-106 is included in Appendix A.

GEPS-EPRI 19 URS 91-28171712.00/L6051 R-rev.doc April 11, 2002

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TABLE 3 SUMMARY OF EXTRACTABLE PETROLEUM HYDROCARBON RESULTS

FROM VAULT WATER SAMPLES


MCP Groundwater Standard VI V2 Compound GW-1 11/29/00 11/29/00

C9-C18 Ahphatics 4000

TABLE 4 SUMMARY OF POLYCHLORINATED BIPHENYL RESULTS

FROM VAULT WATER SAMPLES


Compound

Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Total PCBs

MCP GW-1 Groundwater Standard

-------

0.5

VI 11/29/00

I ^

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0 250 500 750 1000

GRAPHIC SCALE (METERS)

QUADRANGLE LOCATION

FIGURE

1 SITE LOCATION MAP

NOTE CONTOUR INTERVAL = 6 METERS

EPRI SITE LENOX, MASSACHUSETTS

REFERENCE PITTSRELD EAST QUADRANGLE A998

THE CIRCLES DEPICTED ARE THE 1/2 MILE AND 1 MILE RADII FROM THE UHV BUILDING URS 646 PLANK ROAD SUITE 202 CLIFTON PARK, NEW YORK 12065

POWER PDLE

WETLAND DELINEATION LINE VAULT AREA

GENERAL ELECTRIC COMPANY Original includes color coding LENOX, MASSACHUSETTES

SOURCE! SITE PLAN PREPARED BY HILL ENGINEERS, ARCHITECTS, AND 46 I ANI ROAD SUML PLANNERS OF DALTON, MA DATED 06/15/01. I [| ION PARK NEW 0t

MA DEP - Bureau of Waste Site Cleanup SITE NAME: Site Scoring Map: 500 feet & 0.5 Mile Radii :PRI422404n 731403ewi Ib* rrtorTTUODfi thovn on tfui map [̂«L«^ol

• tta DMI jvajlatoit 21 tfw etas*

Site Location V^55^ a*1' "*> _»

MASSACHUSETTS GIS SITE SCORING MAP

EPRI SITE LENOX, MASSACHUSETTS

646 PLANK ROAD SUITE 202 URS CLIFTON PARK. NEW YORK 12065 Ftoedc Hns>«o.USS»««Stroa1>ri

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APPENDIX A

RELEASE & UTILITY-RELATED ABATEMENT MEASURE (RAM & URAM)

TRANSMITTAL FORM (BWSC-106)

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RELEASE & UTILITY-RELATED ABATEMENT Release Tracking MEASURE (RAM & URAM) TRANSMITTAL FORM

! 1 - 14205 Pursuant to 310 CMR 40 0444 - 0446 and 310 CMR 40 0462 - 0465 (Subpart D)

A. SITE LOCATION:

Site Name Electric Power .Research institute

Street 115. .East _New_Lenox_Raad _ - Location Aid .Formerly 1CLQQ New Lenox Road

City/Town T.pnny _ ZIP Q124Q-22UL

[ | Check here if a Tier Classification Submittal has been provided to DEP for this Release Tracking Number

Related Release Tracking Numbers That This RAM or URAM

B. THIS FORM IS BEING USED TO: (check all that apply)

) Submit a RAM Plan (complete Sections A, B, C. D. E, F, J, K. L and M)

I—I Check here it this RAM Plan is an update or modification ot a previously approved written RAM Date Submitt" Plan

| | Submit a RAM Status Report (complete Sections A, B, C. E, J, K, L and M)

| | Submit a RAM Completion Statement (complete Sections A, B, C, D, E, G, J, K, L and M)

(G Confirm or Provide URAM Notification (complete Sections A, B, H, K, L and M)

f ] Submit a URAM Status Report (complete Sections A, B, C, E, J. K, L and M)

| | Submit a URAM Completion Statement (complete Sections A, B, C, D, E, I, J. K, L and M)

You must attach all supporting documentation required for each use of form indicated, including copies of any Legal Notices and Notices to Public Officials required by 310 CMR 40.1400.

C. SITE CONDITIONS:

Uj Check here rf the source of the Release or Threat of Release is known

If yes, check all sources that apply | | UST Q] Pipe/Hose/Lme | | AST | | Drums F] Transformer J Boat

| | Tanker Truck {^} Vehicle ^J Other Specrfy Subsurface vaults

Identify Media and Receptors Affected (check all that I I Air I I Groundwater |~~1 Surface Water I I Sediments Lfl Soil ! L3LJ or,^U,\ ' ' ' ' ' ' '

Q Wetlands Q Storm Dram Q ™^0 D Private Well Q Public Water Supply Q| Zone 2 QJ Residence

G icnoo j—| Unknown r—j other Specrfy

Identify Release and/or Threat of Release Conditions at Site (check all that apply)

| | 2 and 72 Hour Reporting Condition(s) Qj 120 Day Reporting Condition(s) [_ ] Other Condition(s)

Descnbe

RAMs may be conducted concurrently with an IRA only with written DEP approval URAMs may not be conducted if any 2 or 72 Hour conditions exist at the site

Identify Oils and Hazardous Matenals Released (check all that j^j Oils [_ 1 ^™°""(tle° Heavy Metals

[~ ] Others Specify ._ _

D. DESCRIPTION OF RESPONSE ACTIONS: (check all that apply) uepioymem 01 Aosoroant or ^omainmem

[ | Assessment and/or Monitoring Only M atonalc

^f\ Excavation of Contaminated Soils I Temporary Covers or Caps

(~~| Re-use, Recycling or Treatment j Bioremediation

i ) On Site i Off Site Est Vol _ cubic yards [ J Soil Vapor Extraction

Describe _ [_ ] Structure Venting System

f j %™£™ NArL Store t j On Site Off Site Est Vol cubic yards

SECTION D IS CONTINUED ON THE NEXT PAGE.



RELEASE & UTILITY-RELATED ABATEMENT Release Tracking MEASURE (RAM& URAM) TRANSMITTAL FORM

| 1 14205 Pursuant to 310 CMR 40 0444 - 0446 and 310 CMR 40 0462 - 0465 (Subpart D)

D. DESCRIPTION OF RESPONSE ACTIONS (continued)

0] Landfill Cj Cover < j Disposal Est Vol _15 cubic yards G ijrounowaier ireatmeni


RELEASE & UTILITY-RELATED ABATEMENT Release Tracking MEASURE (RAM & URAM) TRANSMITTAL FORM Pursuant to 310 CMR 40 0444 - 0446 and 310 CMR 40 0462 - 0465 (Subpart D)

I. URAM COMPLETION STATEMENT:

| | Check here if this URAM was limited to the excavation and/or handling of not more than 100 cubic yards of soil contaminated by Oil or not more than 20 cubic yards of soil contaminated by either a Hazardous Material or a mixture of a Hazardous Matenal and Oil

If any Remediation Waste will be stored, treated, managed, recycled or reused at the site following submission of the URAM Completion Statement, you must submit either a Release Abatement Measure (RAM) Plan or a Phase IV Remedy Implementation Plan, along with the

appropriate transmittal form, as an attachment to the URAM Completion Statement

J. LSP OPINION:

I attest under the pains and penalties of perjury that I have personally examined and am familiar with this transmittal form, including any and all documents accompanying this submittal In my professional opinion and judgment based upon application of (i) the standard of care in 309 CMR 4 02(1), (u) the applicable provisions of 309 CMR 4 02(2) and (3) and (in) the provisions of 309 CMR 4 03(5) to the best of my knowledge, information and belief,

> if Section B of this form indicates that a Release Abatement Measure Plan is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed in accordance with the applicable provisions of M G L c 21E and 310 CMR 40 0000, (u) is (are) appropnate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M G L c 21E and 310 CMR 40 0000 and (in) complies(y) with the identified provisions of all orders, permits and approvals Identified in this submittal,

> if Section B of this form indicates that a Release Abatement Measure Status Report or a Utility-Related Abatement Measure Status Report is being submitted, the response action(s) that is (are) the subject of this submittal (i) is (are) being implemented in accordance with the applicable provisions o f M G L c 21E and 310 CMR 40 0000, (u) is (are) appropriate and reasonable to accomplish the purposes of such response action(s) as se forth in the applicable provisions of M G L c 21E and 310 CMR 40 0000 and (in) complies(y) with the identified provisions of all orders, permits and approvals Identified in this submittal,

> if Section B of this form indicates that a Release Abatement Measure Completion Statement or a Utility-Related Abatement Measure Completion Statement is being submitted, the response action(s) that is (are) the subject of this submittal (i) has (have) been developed and implemented in accordance with the applicable provisions of M G L c 21E and 310 CMR 40 0000, (ii) is (are) appropnate and reasonable to accomplish the purposes of such response action(s) as set forth in the applicable provisions of M G L c 21E and 310 CMR 40 0000 and (HI) complies(y) with the identified provisions of all orders, permits and approvals identified in this submittal

I am aware that significant penalties may result, including, but not limited to possible fines and impnsonment, if I submit information which I know to be false, inaccurate or matenally incomplete

| | Check here if the Response Action(s) on which this opinion is based if any, are (were) subject to any orderfsV permit(s) and/or approval(s) issued by DEP or EPA If the box is checked, you MUST attach a statement identifying the applicabl i pro1 * '"

LSP Name Thomas P Wondard Stamp

Telephone ?n7-R7Q-76f l f i

FAX (optional) ?n7- f l7Q- '

Signature

Date A r. An LSP Opinion Is not required for a Utility-Related Abatement Measure Notification.

An LSP Opinion Is not required for a URAM Completion Statement If the URAM Is limited to the excavation and/or handling of not more than 100 cubic yards of soil contaminated by OH, or not more than 20 cubic yards of soil contaminated either by Hazardous Material or

a mixture of Hazardous Material and Oil.

K. PERSON UNDERTAKING RAM OR URAM:

Name of npnpral R1 ert-.ri r Pnwpr Systems

Name of F.dwarri .Tami Rnn Title RHH Remp.rii at".i nn

Street Onp Rivpr Road, Building 43, Rnnm 237

City/Town firhpnpcl-ady State MY ZIP Code 12345-0.QOO

Telephone ^1 B-^ f tg -7q7q Ext FAX

| | Check here if there has been a change in person undertaking the RAM or URAM

Revised 2/24/95 Supersedes Forms BWSC-007. 008, 009 and 010 (in part) Page 3 of 4 Do Not Alter This Form


RELEASE & UTILITY-RELATED ABATEMENT Release Tracking

MEASURE (RAM & URAM) TRANSMITTAL FORM r- , 1 142^5Pursuant to 31OCMR 40 0444 -0446 and 31OCMR 40 0462- 0465 (Subpart D) LL "L _ |

L. RELATIONSHIP TO SITE OF PERSON UNDERTAKING RAM or URAM: (check one)

^/\ RPorPRP Specify t'j* Owner O Operator' > Generator i~} Transporter Other RP or PRP Former Owner

| ] Fiduciary Secured Lender or Municipality with Exempt Status (as defined by M G L c 21E s 2)

Q] Agency or Public Utility on a Right of Way (as defined by M G L c 21E s 5(j))

I I Any Other Person Undertaking RAM or URAM Specify

M. CERTIFICATION OF PERSON UNDERTAKING RAM OR URAM:

.Tarrn .qnn_ , attest under the pains and penalties of perjury (I) that I have personally examined and am familiar with the information contained in this submittal, including any and all documents accompanying this transmittal form, (ii) that, based on my inquiry of those individuals immediately responsible for obtaining the information, the material information contained in this submittal is, to the best of my knowledge and belief, true, accurate and complete, and (in) that I am fully authorized to make this attestation on behalf of the entity legally responsible for this submittal I/the person or entity on whose behalf this submittal is made am/is aware that there are significant penalties, including, but not limited to, possible fines and impnsonment, for willfully submitting false inaccurate, or Incomplete information

ignature) L/

For_fieneraJ_ Elecriric Power Sysf.pms (print name of person or entity recorded in Section K)

Enter address of person providing certification, if different from address recorded in Section

Street ___

City/Town __ State _ ZIP Code

Telephone _ Ext _ FAX (optional)

YOU MUST COMPLETE ALL RELEVANT SECTIONS OF THIS FORM OR DEP MAY RETURN THE DOCUMENT AS INCOMPLETE. IF YOU SUBMIT AN INCOMPLETE FORM, YOU MAY BE PENALIZED FOR MISSING

A REQUIRED DEADLINE.

Revised 2/24/95 Supersedes Forms BWSC-007, 008. 009 and 010 (in part) Page 4 of 4 Do Wo( Alter This Form

APPENDIX B

PERMIT AND WPA FORM 5 - ORDER OF CONDITIONS

2 » '7'

COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENVIRONMENTAL PROTECTION WESTERN R E G I O N A L OFFICE

JANE SWIFT ' *' I BOB 1)1 HAM)

Governor " U \L 'KEN \ MSP

RE NOTIFICATION OF FILE NUMBER DATE November 19 2001

WETLANDS/ LENOX (city/town) The Department of Environmental Protection has received a Notice of Intent filed in accordance with the Wetlands Protection Act (M G L c.131, §40)'

APPLICANT URS CORPORATION_ OWNER; ELECTRIC POWER RESEARCH INSTITUTE INC

ADDRESS 646 PLANK ROAD. SUITE 202_ ADDRESS: 115 EAST NEW LENOX ROAD

CLIFTON PARK, NY 12065_ LENOX. MA 01 240

PROJECT LOCATION: 115 EAST NEW LENOX ROAD

IF CHECKED, THE FOLLOWING ITEM(S) APPLY TO THIS NOTICE OF INTENT:

A. X This project has been assigned the following file # 198-1886 :

Although a file # is being issued, please note the following: Materials and equipment shall be stored in a manner and

'tion, which will minimize the compaction of soils and the concentration of runoff. Refueling of vehicles shall be

in an area outside the "Buffer Zone". If a spill occurs, contaminated soils shall be removed according to guidelines

established by the DEP Division of Hazardous Waste. The proposed work sequence, schedule and timing should

be clearly understood by the Conservation Commission prior to permitting.

ISSUANCE OF A FILE NUMBER INDICATES ONLY COMPLETENESS OF SUBMITTAL, NOT APPROVAL OF APPLICATION

B. No File # will be assigned to this project until the following missing information is sent to this office, to meet the minimum submittal requirements in accordance with the Wetlands Protection Regulations at 310 CMR 10.00:

_copy(s) of a completed Notice of Intent (WPA Form 3 or WPA Form 4, whichever is applicable) and a copy of the Fee Transmittal Form, with-a copy of the check for the State's share of the Notice of Intent filing fee

copy(s) of plans, calculations, and other documentation necessary to completely describe the proposed work and mitigating measures to protect resource areas.

copy(s) of a 8 V4" by 11" section of the USGS topographic map of the area (a legible photocopy) showing the site

Two (2) copy(s) of plans showing compliance with Title 5 of the State Environmental Code, 310 CMR 15.00

Proof that a copy of your Notice of Intent has been mailed or hand delivered to the Natural Heritage and Endangered Species Program

COMMENTS: - See page 2 for additional information

This information is available in alternate formal by calling our ADA Coordinator at (617) 574-6872.

Other Regulatory Jurisdiction

C Application has been forwarded to Waterways Regulatory Program to determine if a Chapter 91 License is required

D 401 Water Quality Certification (314 CMR 9 00) may be required See below for further details

( ) Based upon the information submitted in and with your Notice of Intent a separate 401 Water Quality Certification application form is not required. Provided that the project meets the following conditions, summarized below from 310 CMR 9.03 and 9.04, and the conditions under the Corps of Engineers Programmatic General Permit for Massachusetts (PGP), the project qualifies for 401 Certification as certified under the PGP:

a) activities are conducted in compliance with MGL c 131, §40 (the Wetlands Protection Act) and the Final Order of Conditions permitting the activities does not result in the loss of more than 5.000 square feet cumulatively of bordering and isolated vegetated wetlands ana Land Under Water and/or the dredging of more than 1CG cubic yards of Land Under Water,

b) the Final Order of Conditions requires at least 1:1 replacement of Bordering Vegetated Wetlands pursuant to 310 CMR 1055(4)(b),

c) The project is not listed in 314 CMR 9 04 (1) through (11) including discharge of dredged or fill material to any Outstanding Resource Waters, any part of a subdivision unless deed restricted, so long as the discharge is not to an Outstanding Resource Water see 314 CMR 9 04 (3), and,

d) The project does not include activities exempt from MGL c 131, s40 (except for normal maintenance and improvement of land in agricultural or aquacultural use), discharge of dredged or fill material to an isolated vegetated wetland designated as rare and endangered species habitat, loss of any salt marsh, activities subject to an individual 404 permit

Information and a copy of the PGP can be obtained from the Corps of Engineers at 1-800-362-4367 If impacts to resource areas or project size increased beyond that described in the Notice of Intent or there are discrepancies therein, you must notify the Department and request a determination that the critena of 310 CMR 9 03 have been met before the activity may begin.

( ) Before the activity described in the Notice of Intent can commence, you must obtain a Water Quality Certification from this Regional Office. Please complete the enclosed 401 Water Quality Certification application form and file it with this Regional Office for Review. The applicant is advised to forward a copy of the application to the Army Corps of Engineers for review, at U.S Army Corps of Engineers, 696 Virginia Road, Concord, MA 01742-2751

( ) Your project involves dredging of greater than 100 cubic yards of Land Under Water. Please complete the enclosed 40 Water Quality Certification application form and submit to the Department of Environmental Protection, Wetlands and Waterways Program, One Winter Street, Boston, MA 02108. Call the Wetlands and Waterways Program at 617292-5695 with any questions. The applicant is advised to forward a copy of the application to Army Corps of Engineers for review, at U S. Army Corps of Engineers, 696 Virginia Road, Concord, MA 01742-2751.

For more information please contact: Timothy McKenna

cc: Conservation Commission

Property Owner as listed in Notice of Intent

Representative as listed in Notice of Intent

( ) Natural Heritage and Endangered Species Program

( ) U.S. Army Corps of Engineers

( ) DEP Waterways Regulation Program

( ) Other

DEP File Number Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands 198- I 86

Provided by DEP WPA Form 5- Order of Conditions Massachusetts Wetlands Protection Act M G L c 131, §40

A. General Information

Important When filling From

out forms on L e n o x the computer Conservation Commission use only the

This issuance if for (check one) tab key to move your

Q Order of Conditions cursor - do not use the return key D Amended Order of Conditions

To Applicant Property Owner (if different from applicant)

URS Corp on behalf of GF Power Systems F . P R T Name Name 646 Plank Road, Suite 202 1 1 5 E a s t N e w L e n o x R d . Mailing Address Mailing Address

C1 ^ f l -nn P a r k NY 1 906 S L e n o x MA 0 I 2 4 0 Crtyn"own State Zip Code City/Town State Zip Code

1 Project Location

I 15 East New Lenox Rd L e n o x MA Q I 2 4 0 Street Address City/Town

34 1 Assessors Map/Plat Number Parcel/Lot Number

2 Property recorded at the Registry of Deeds for

B e r k s h i r e M i d d l e D i s t r i c t County Book Page

Certrficate (if registered land)

3 Dates

10/ 18/200 1 I 1 / 2 6 / Q1 1 7 2 6 / O 1 Date Notice of Intent Filed Date Public Hearing Closed Date of Issuance

4 Final Approved Plans and Other Documents (attach additional plan references as needed)

Title Date

5 Final Plans and Documents Signed and Stamped by

Name

6 Total Fee

7 8 7 . 5 0 (from Appendix B Wetland Fee Transmrttal Form)

WPA Fom. 5 11 an

Massachusetts Department of Environmental Protection ' 9 8 I 8 f c Bureau of Resource Protection - Wetlands ~

WPA Form 5- Order of Conditions p^^v Massachusetts Wetlands Protection Act M.G.L. c. 131, §40

B. Findings

Findings pursuant to the Massachusetts Wetlands Protection Act

Following the review of the above-referenced Notice of Intent and based on the information provided in this application and presented at the public hearing, this Commission finds that the areas in which work is proposed is significant to the following interests of the Wetlands Protection Act Check all that apply

D Public Water Supply CD Land Containing Shellfish CH Prevention of Pollution

CH Private Water Supply O Fisheries D Protection of Wildlife Habitat

D Groundwater Supply n Storm Damage Prevention D Flood Control

Furthermore, this Commission hereby finds the project, as proposed, is (check one of the following boxes)

Approved subject to:

[7] the following conditions which are necessary, in accordance with the performance standards set forth in the wetlands regulations, to protect those interests checked above. This Commission orders that all work shall be performed in accordance with the Notice of Intent referenced above, the following General Conditions, and any other special conditions attached to this Order. To the extent that the following conditions modify or differ from the plans', specifications, or other proposals submitted with the Notice of Intent, these conditions shall control.

Denied because:

[~l the proposed work cannot be conditioned to meet the performance standards set forth in the wetland regulations to protect those interests checked above. Therefore, work on this project may not go forward unless and until a new Notice of Intent is submitted which provides measures which are adequate to protect these interests, and a final Order of Conditions is issued.

O the information submitted by the applicant is not sufficient to describe the site, the work, or the effect of the work on the interests identified in the Wetlands Protection Act. Therefore, work on this project may not go forward unless and until a revised Notice of Intent is submitted which provides sufficient information and includes measures which are adequate to protect the Act's interests, and a final Order of Conditions is issued. A description of the specific information which is lacking and why it is necessary is attached to this Order as per 310 CMR 10.05(6)(c).

General Conditions (only applicable to approved projects)

1. Failure to comply with all conditions stated herein, and with all related statutes and other regulatory measures, shall be deemed cause to revoke or modify this Order.

2. The Order does not grant any property rights or any exclusive privileges; it does not authorize any injury to private property or invasion of private rights.

3. This Order does not relieve the permittee or any other person of the necessity of complying with all other applicable federal, state, or local statutes, ordinances, bylaws, or regulations.

WPAFonnS P»g« 2

DEP Fie Number Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands 1 9 8 - 1 8 6

Provided by DEP WPA Form 5- Order of Conditions Massachusetts Wetlands Protection Act M.G.L. c. 131, §40

B. Findings (cont)

4 The work authorized hereunder shall be completed within three years from the date of this Order unless either of the following apply a the work is a maintenance dredging project as provided for in the Act, or b the time for completion has been extended to a specified date more than three years, but less

than five years, from the date of issuance If this Order is intended to be valid for more than three years, the extension date and the special circumstances warranting the extended time period are set forth as a special condition in this Order

5 This Order may be extended by the issuing authority for one or more penods of up to three years each upon application to the issuing authonty at least 30 days prior to the expiration date of the Order.

6 Any fill used in connection with this project shall be clean fill Any fill shall contain no trash, refuse, rubbish, or debris, including but not limited to lumber, bricks, plaster, wire, lath, paper, cardboard, pipe, tires, ashes, refrigerators, motor vehicles, or parts of any of the foregoing

7. This Order is not final until all administrative appeal periods from this Order have elapsed, or if such an appeal has been taken, until all proceedings before the Department have been completed.

8 No work shall be undertaken until the Order has become final and then has been recorded in the Registry of Deeds or the Land Court for the district in which the land is located, within the chain of title of the affected property. In the case of recorded land, the Final Order shall also be noted in the Registry's Grantor Index under the name of the owner of the land upon which "the proposed work is to be done In the case of the registered land, the Final Order shall ateo be noted on the Land Court Certificate of Title of the owner of the land upon which the proposed work is done The recording information shall be submitted to this Conservation Commission on the form at the end of this Order, which form must be stamped by the Registry of Deeds, prior to the commencement of work.

9 A sign shall be displayed at the site not less then two square feet or more than three square feet in size bearing the words,

"Massachusetts Department of Environmental Protection" [or, "MA DEP"]

"File Number 198- I 86

10. Where the Department of Environmental Protection is requested to issue a Superseding Order, the Conservation Commission shall be a party to all agency proceedings and hearings before DEP.

11. Upon completion of the work described herein, the applicant shall submit a Request for Certificate of Compliance (WPA Form 8A) to the Conservation Commission.

12. The work shall conform to the plans and special conditions referenced in this order.

13 Any change to the plans identified in Condition #12 above shall require the applicant to inquire of the Conservation Commission in writing whether the change is significant enough to require the filing of a new Notice of Intent.

14. The Agent or members of the Conservation Commission and the Department of Environmental Protection shall have the right to enter and inspect the area subject to this Order at reasonable hours to evaluate compliance with the conditions stated in this Order, and may require the submrttal of any data deemed necessary by the Conservation Commission or Department for that evaluation.

Massachusetts Department of Environmental Protection 'e Numb€r

Bureau of Resource Protection - Wetlands i 9 8 - 1 8 6 .

WPA Form 5 Order of Conditions prov.edbyoE Massachusetts Wetlands Protection Act M.G.L. c. 131, §40

B. Findings (cont)

15 This Order of Conditions shall apply to any successor in interest or successor in control of the property subject to this Order and to any contractor or other person performing work conditioned by this Order

16 Prior to the start of work, and if the project involves work adjacent to a Bordering Vegetated Wetland, the boundary of the wetland in the vicinity of the proposed work area shall be marked by wooden stakes or flagging Once in place, the wetland boundary markers shall be maintained until a Certificate of Compliance has been issued by the Conservation Commission

17 All sedimentation barriers shall be maintained in good repair until all disturbed areas have been fully stabilized with vegetation or other means At no time shall sediments be deposited in a wetland or water body During construction, the applicant or his/her designee shall inspect the erosion controls on a daily basis and shall remove accumulated sediments as needed The applicant shall immediately control any erosion problems that occur at the site and shall also immediately notify the Conservation Commission, which reserves the right to require additional erosion and/or damage prevention controls it may deem necessary. Sedimentation barriers shall serve as the limit of work unless another limit of work line has been approved by this Order.

Special Conditions (use additional paper, if necessary).

Materials and equipment shall be stored in a manner and l o c a t i which will minimize the comp a'C tion of -soils a-n d the concentration of runoff. Refueling of vehicles shall be in an area outside the Buffer Zone. If a spill occurs, contaminated soils shall be removed according to guidelines e stablished by the DEP Division of Hazardous Waste. T i h e proposed work sequence schedule and timing should be clearly understood by the Conservation Comm. prior to p e r m i t t i

Findings as to municipal bylaw or ordinance TRENCHED IN SILT FENCES TO BE US

Furthermore, the hereby finds (check one that applies): Conservation Commission

that the proposed work cannot be conditioned to meet the standards set forth in a munici