Transmitted via Electronic Mail and Overnight Courier

March 25, 2011

Dean Tagliaferro EPA Project Coordinator c/o Weston Solutions, Inc, 10 Lyman Street Pittsfield, MA 01201

Re: GE-PittsfieldlHousatonic River Site East Street Area 2-North (GECD140)

GE 159 Plastics Avenue

Pittsfield, MA 01201

USA

Updated Proposal for Remaining Concrete Floor Slabs in and Adjacent to the 19s Complex

Dear Mr. Tagliaferro:

On December 21, 2006, the General Electric Company (GE) submitted to the U ,S, Environmental Protection Agency (EPA) a proposal regarding the remaining concrete floor slabs of buildings located in the East Street Area 2-North Removal Action Area (RAA) that had been or were scheduled to be demolished. These were Buildings 1,2,3, 3B, 4, 5, 6, 7, S/SE, 11, 15, 15A, 15B, 15W, 16116X, 17, 17C, and 19. All of these buildings except Buildings 3B and 7 were located within the western pOliion of this RAA, known as the former 19s Complex, which GE intends to transfer to the Pittsfield Economic Development Authority (PEDA) under the Definitive Economic Development Agreement. Buildings 3B and 7 were located just east of the 19s Complex in East Street Area 2-North and will not be transferred to PEDA. Since the time of that submittal, GE has completed the demolition of all the buildings listed above. Based on further discussions with PEDA and EPA, and in preparation for the transfer of the 19s Complex to PEDA, this letter presents GE's updated plan, in which PEDA joins, for addressing the remaining concrete floor slabs within the former 19s Complex, as well as those of Buildings 3B and 7. (In proposing this plan, GE reiterates its position that there is no basis in the CD to require such activities for building slabs, and it reserves the right to contest such requirements in the future.)

At the time of the December 21, 2006 submittal, PEDA's development plans for the 19s Complex were unknown. At the present time, PEDA's plans for redevelopment of the 19s Complex are still unknown. While PEDA is continuing discussions with potential tenants, a definitive plan is not currently available, nor will one likely be available prior to transfer.

Given this situation, GE cannot provide EPA with specific details regarding PEDA's future intended use of the remaining concrete floor slabs in the former 19s Complex. However, GE can advise EPA that the remaining concrete floor slabs at the former 19s Complex will be covered by new buildings, pavement, soil, or another appropriate surface cover, although the specific type of cover and the timing for installation of the cover are still uncertain at this point. In these circumstances, GE in coordination with PEDA has developed a revised plan for addressing the remaining concrete floor slabs at the former 19s Complex. In addition, GE has developed a plan for covering the remaining concrete floor slabs of Buildings 3B and 7, located outside of the former 19s Complex.

Corporate EnVironmental Progroms

Dean Tagliaferro March 25, 2011

Page 2 of 4

GE currently anticipates that a single Grant of Environmental Restriction and Easement (ERE) will be executed for the East Street Area 2-North RAA (except for the portion of Woodlawn Avenue within this RAA, which will be covered by a separate ERE), subject to subsequent amendment (including possible division into two EREs) following transfer of the former 19s Complex to PEDA. The remaining concrete floor slabs from the demolished buildings will be designated as the Slab Area in this ERE, as shown on Figure 1.1 However, different requirements will apply to the portions of the Slab Area in the former 19s Complex and the portions outside that complex, as described below.

For the Slab Area within the former 19s Complex, the following activities will be implemented:

• During the period prior to transfer of the 19s Complex to PEDA, GE, as current owner of this area, will continue to maintain the Slab Area as a controlled site, with continued implementation of institutional controls consisting of security measures and perimeter fencing. GE will document this obligation in the Final Completion RepOli for the East Street Area 2-North Removal Action (Final Completion Report).

• Following transfer, as PEDA has agreed, PEDA will continue to maintain appropriate institutional controls (e.g., ~ite security and other Post-Removal Site Control activities applicable to the area after transfer) at the Slab Area until complete and final development plans for the propeliy are known.

• The ERE for East Street Area 2-NOlih will include a provision that the Grantor shall maintain those institutional controls for the Slab Area until such time as the Grantor covers the slabs and/or removes uncovered pOliions of the slabs, as described below.

• At the time that complete and final development plans are known, GE and PEDA will provide a joint submittal to the Massachusetts Depmiment of Environmental Protection (MDEP) that provides information as to how the remaining slabs within the Slab Area will be covered and how such cover(s) will address potential direct contact risks - except to the extent that the Grantor plans to permanently remove all or a portion of the slabs. Following approval of such a cover plan by MDEP, PEDA will construct the cover, in coordination with GE, in accordance with the approved plan; and it will submit as-built information to MDEP documenting how the slabs were covered. GE's above-mentioned obligations will be documented in the Final Completion RepOli.

• The ERE will include provisions requiring that, for this Slab Area, the Grantor must: (a) submit a cover plan for the slabs to MDEP for approval prior to placing any such cover; (b) implement any removal of all or a pOliion of the slabs in accordance with provisions set forth in the ERE and attached Soil Management Protocol; (c) after completion of a cover and/or the removal of any uncovered pOliions of the slabs, submit as-built plans to MDEP (after which, if such plans are found to be acceptable, Grantor may remove the institutional controls); and (d) following installation of a cover, maintain the cover(s) as shown on the as-built plans.

I The Slab Area represents the remaining concrete tloor slabs/foundations located within the footprints of the former buildings demolished by GE between 2002 and 2010. It should be noted that, although GE's December 21, 2006 proposal included reference to former Buildings 8/8E, there is no discernible concrete slab area associated with these former structures, and thus the area of those former buildings are not part of the Slab Area.

G:\GE\GE_Pittsficld_CD _ESA_2_Nol1h\Corrcspondcncc\SJabArca\OS11 J I I 324Ltr.doc

Dean Tagliaferro March 25, 2011

Page 3 of 4

Since the portion of the Slab Area outside of the former 19s Complex (i.e., the remaining floor slabs of Buildings 3B and 7) will not be transferred to PEDA and thus will not be affected by PEDA's future development plans, GE has developed a specific plan for addressing these slabs at the present time. Although several potential approaches are suitable for addressing such remaining building slabs, including installation of either a soil cover or an asphalt cover, GE has elected to install an asphalt cover system over these slabs based on consideration of several factors associated with these particular slabs? Specifically, GE proposes to undertake the following activities:

• GE will pave over the remaining slabs of former Buildings 3B and 7 with approximately 3 inches of asphalt. The cover plan for the former Building 7 slab is presented on Figure 2. Note that since a portion of the remaining slab of Building 7 is located several feet above grade, additional features will be installed along the perimeter of this slab, where necessary, to ensure that the asphalt pavement along the edges is held in place and does not erode over time. Specifically, GE anticipates that an asphalt edging restraint (or similar device) will be installed along the southern and eastern edge of the upper slab area, and additional soil will be placed along the northern edge of the upper slab area, to hold the asphalt in place (as illustrated on Figure 2).

• These asphalt covers will initially be subject to inspection and maintenance activities in accordance with the Post-Removal Site Control requirements described in GE's Modified Post-Removal Site Control Plan (dated October 31, 2007, as conditionally approved by EPA on November 15, 2007, and subsequently modified further by a revised Figure E-l, submitted to EPA on December 5, 2008) relating to Other-Ground Covering Feature Areas that GE has elected to maintain as paved. These activities will ensure that the cover is maintained. Similar requirements will be incorporated into the Final Completion Report; and following submission and EPA approval of that report, the inspection and maintenance of this portion of the Slab Area will be performed in accordance with the applicable Post-Removal Site Control requirements set forth in that report.

• The ERE for East Street Area 2-North will include a requirement to maintain the above-described asphalt covers.

In the event that there is any inconsistency between the above provisions and the provisions of the final ERE, the applicable ERE will control.

Please feel free to contact me at (413) 448-5902 with any questions or comments.

Sincerely,

~C~hfl1 Michael T . Carroll Manager, Pittsfield Remediation Programs

Attachments

2 The slab of former Building 3B is relatively small and is currently surrounded by asphalt pavement. The lower/southern slab of former Building 7 is within a paved area subject to frequent and heavy traffic associated with Building 100 operations, while the upper/northern slab of former Building 7 is elevated several feet above surrounding grade. Given these conditions, a soil cover would likely be more difficult to install and maintain than an asphalt cover.

G:\GE\GE_Piusficld_CD_ESA_2_North\CoITcspondcncc\SJabArca\08111 J 1324Ltr.doc

cc: J. Kilborn, EPA H. Inglis, EPA R. Howell, EPA J. Ziegler, MDEP (2 copies) M. Gorski, MDEP E. Tor, MDEP L. Palmieri, Weston (2 copies) Mayor J. Ruberto, City of Pittsfield W. Hines, Executive Director, PEDA B. Landau, Noble & Wickersham

G:\GE\GE_Pittsficld_ CD _ ESA_2_North\Corrcspondcnce\SJabArca\0811111324Ltr.doc

Dean Tagliaferro March 25, 2011

Page 4 of 4

J. Gagnon, O'Reilly, Talbot & Okun R. McLaren, GE R. Gates, GE J. Bieke, Goodwin Procter S. Gutter, Sidley Austin J. Nuss, ARCADIS M. Hassett, ARCADIS GE Internal Repositories Public Information Repositories

SLAB AREA

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FUTURE PROPERTY LINE (SEE NOTE 3)

-,--x- EXISTING FENCE LINE ,-------, I I FORMER BUILDING/STRUCTURE LOCATION 1 _______ 1 (SEE NOTE +)

17 BUILDING ID

[-.~_ .>_~~ SLAB AREA (CONCRETE ~AB/FOIJNDAllON)

NOTES:

1 BASE MAPPING FROM TOPOGRAPHIC SURVEY (DRAWING S2059W01) BY FORESIGHT LAND SURVEYORS DATED 2/9/05. BASE MAPPING WAS REV1SED 9/26/10 BASED ON A HILL DRA'MNG TITLED "OVERALL SITE PLAN " , DATED 7/12/2010, AT A SCALE OF'" = 40'

2. NOT ALL PHYSICAL FEATURES SHOWN.

3. THE FUlURE PROPERTY LINE SHOWS THE APPROXIMATE BOUNDARY BETWEEN THE FORMER 19s COMPLEX, WHICH IS EXPECTED TO BE TRANSFERRED TO PEDA, AND THE REMAINDER OF EAST STREET AREA 2-NORTH

f. THE LIMITS OF THE FORMER BUILDING LOCATIONS ARE APPROXIMATE AND GENERALLY REPRESENT THE FOOTPRINT OF THE ~ORE SIGNIFICANT ABOVE-GRADE STRUCTURES THAT HAVE BEEN DEMDLlSHED. AREAS OUTLINED AS FORMER BUILDINGS WHERE THE SLAB AREA IS NOT SHOWN WlTI1IN THE OUTLINE CONSIST OF, A) FORMER BUILDINGS WrlERE THE SLAB WAS REMOVED

(I.E., BUILDING JC), OR THERE IS NO DISCERNABLE CONCRETE SLAB PRESENT (I_E_. BUILDING B/BE); AND B) OVERHEAD STRUCTURES 'MTH NO SLAB AREA PRESENT BELOW THEM.

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~ARCADIS

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FIGURE

GENERAL ELECTRIC COMPANYPITTSFIELD, MASSACHUSETTS

2

PROPOSED 3-INCH ASPHALT LAYER

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1040

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Ilf! If! ;i! II; fl Ie I '* " f" " t" I Fe; f-c 0' 10' 20' 30' 40' so' 60' 70' 80' gO' 100' 110' 120' 130' 140' 150' 150' 170' DISTANCE IN FEET

" HORIZONTAL ~R'&'PHIC SC,&,LE IlERTlC,&,L GR'&'PHIC SC,&,LE

CROSS SECTION A·A'

+. LOCATIONS AND DIMENSIONS SHOWN ON CROSS SECTIONS ARE APPROXIMATE.

5. BELOW GRADE DEPll1S OF ASPHALT, CONCRETE WALLS, AND CONCRETE SLABS ARE INFERRED (NO SURVEY DATA AVAILABLE TO CONFIRM)

6. SPOT ELEVATION SHOWN ON BUILDING 7 IS APPROXI~ATE (NOT BASED ON SURVEY DTA).

7. BUILDING 7 CONSISTS OF AN UPPER LEVEL THAT IS GENERALLY ELEVATED ABOVE THE SURROUNDING PAVEMENT/ALLEYWAY ALONG THE SOUTH AND EAST SIDES. ll1ERE IS ALSO A LOWER LEVEL SLAB THAT IS GENERALLY AT GRADE 'MTH THE SURROUNDING P A VEt.1ENT /ALLEYWA Y.

8. a.,EAN IMPORTED FlLL 'MLL BE PLACED IN THE AREA BETWEEN THE FORMER BUILDING 7 SLAB AND THE EXISTING RETAINING WALL ADJACENT TO TYLER STREET. IMPORTED FILL WILL BE PLACED. AS NECESSARY. TO ESTABLISH A SUBGRADE ELEVATION APPROXIMATELY 6 INCHES BELOW THE TOP OF ll1E PROPOSED 3-INCH ASPHALT LAYER. THE REMAINING 6 INCHES IMLL BE FILLED WITH A VEGETATED TOPSOIL LAYER, THE SURFACE OF WHICH IS TO MATCH TH@SURFACE OF THE PROPOSED 3-INCH ASPHALT LAYER

9. AN ASPHALT EDGING RESTRAINT (ASPHALT EDGE ALUMINUM RESTRAINT MANUFACTURED BY PERMALOC, OR PROPOSED EQUIVALENT) IS TO BE INSTALLED ALONG THE EASTERN AND SOUTHERN EDGES OF THE UPPER SLAB AREA, AND IS TO HAVE A WALL HEIGHT OF AT LEAST .3 INCHES. THE RESTRAINT IS TO BE BOLTED TO THE EXISTING CONCRETE SLAB/FOUNDATION USING 0.75- TO 1-INCH RAMSET/HILTI NAILS IN ACCORDANCE WITH MANUFACTURER'S RECOM~ENDED INSTALLATION GUIDELINES. DEPENDING ON ll1E INTEGRITY OF THE EXISTING CONCRETE SLABjFOUNDATION, MODIFICATIONS TO THE ALIGN~ENT OF THE ASPHALT EDGING RESTRAINT AND/OR REPAIRS OF THE EXISTING CONCRETE SLAB/FOUNDATION MAY NEED TO BE MADE SO THAT THERE IS A SUITABLE SURFACE UFON WHICH TO FASTEN THE ASFHALT EDGING RESTRAINT. AN ALTERNATIVE ASPHALT EDGING RESTRAINT (ONE THAT FASTENS TO THE VERTICAL SIDEWALL OF THE UPPER SLAB AREA) MAY NEED TO BE UTILIZED ALONG CERTAIN SECTIONS OF THE PROPOSED ALIGNMENT IF THE CONDITION OF THE EXISTlNG CONCRETE SLAB/FOUNDATION DOES NOT ALLOW FOR PROPER INSTALLATION ALONG THE HORIZONTAL SURFACE.

10 WHERE NECESSARY, THE EXISTING SLAB IMLL BE SAWCUT AND THE NEW PAVEMENT SHALL BE INSTALLED IN SUCH A MANNER THAT ALLOWS FOR A SMOOTH TRANSITION FROM THE NEW PAVE~ENT TO ll1E EXISTING PAVEMENT

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GRAPHC SCALE

~ARCADIS

barcodetext: SDMS DocID 480382barcode: *480382*