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Transmitted Via Overnight Courier October 9, 20I4 Mr. Richard Fisher (Mail Code OSRR07-I) U.S. Environmental Protection Agency 5 Post Office Square - Suite 100 Boston, Massachusetts 021I4-2023 Re: GE-Pittsfield/Housatonic River Site GE Corporate 159 Plastics Avenue Pittsfield, MA 01201 USA Building 71 and Hi1178 On-Plant Consolidation Areas (GECD210 & GECD220) Summary of September 2014 Post-Closure Inspection Activities Dear Mr. Fisher: On September IO, 20I4, the General Electric Company (GE) performed a post-closure inspection of the Building 7I and Hill 78 On-Plant Consolidation Areas (OPCAs). The inspection was conducted in accordance with the requirements specified in the final Revised Post-Removal Site Control (PRSC) Plan, which was included as Appendix H of the Final Completion Report- On-Plant Consolidation Areas (Final Completion Report). That Final Completion Report was submitted to the U.S. Environmental Protection Agency (EPA) on September I5, 20Il and approved by EPA on September 26, 20Il. Previous post-closure inspections were performed semi-annually since September 2006 for the Building 7I OPCA and since May 2008 for the Hill 78 OPCAs. Summaries of those inspections were presented in prior letters to EPA. The most recent previous inspection was performed on May I5, 20I4, with a report documenting that inspection submitted to EPA on June 13, 20I4. This letter documents the results of the September I 0, 20 I4 post-closure inspection of the Building 7I and Hill 78 OPCAs. That inspection included visual observations of the areas and items shown on Figure I (which is the same as Figure 2 from the final Revised PRSC Plan, as revised in GE's December 20, 201I Cover Slope Repair Summary report). Provided below is a description of those inspection activities and the results of the inspection, including items identified as requiring maintenance or other response actions. The inspection activities, results, and identified response actions are also described in the Post-Closure Inspection Form provided in Attachment A (which is the same as the revised form included in GE's above-referenced Cover Slope Repair Summary report). Inspection Activities In accordance with the final Revised PRSC Plan, the September 20I4 post-closure inspection consisted of visual observations of the Building 7I and Hill 78 OPCAs final cover and surrounding areas to determine the overall condition of the final cover and other OPCA components, as well as items needing maintenance. The Building 7I and Hill 78 OPCAs final cover areas were visually inspected to determine the presence of any of the cover-related conditions identified on the attached Inspection Form that could affect the overall integrity of the final cover. In summary, the covers were inspected for: (a) evidence of topsoil erosion; (b) establishment and coverage of vegetation (e.g., bare or sparsely vegetated areas or stressed vegetation); Corporate En>Jr<..mmental 'Jms

Transcript of Transmitted Via Overnight Courier

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Transmitted Via Overnight Courier

October 9, 20I4

Mr. Richard Fisher (Mail Code OSRR07-I) U.S. Environmental Protection Agency 5 Post Office Square - Suite 100 Boston, Massachusetts 021I4-2023

Re: GE-Pittsfield/Housatonic River Site

GE Corporate

159 Plastics Avenue Pittsfield, MA 01201

USA

Building 71 and Hi1178 On-Plant Consolidation Areas (GECD210 & GECD220) Summary of September 2014 Post-Closure Inspection Activities

Dear Mr. Fisher:

On September IO, 20I4, the General Electric Company (GE) performed a post-closure inspection of the Building 7I and Hill 78 On-Plant Consolidation Areas (OPCAs). The inspection was conducted in accordance with the requirements specified in the final Revised Post-Removal Site Control (PRSC) Plan, which was included as Appendix H of the Final Completion Report- On-Plant Consolidation Areas (Final Completion Report). That Final Completion Report was submitted to the U.S. Environmental Protection Agency (EPA) on September I5, 20Il and approved by EPA on September 26, 20Il.

Previous post-closure inspections were performed semi-annually since September 2006 for the Building 7I OPCA and since May 2008 for the Hill 78 OPCAs. Summaries of those inspections were presented in prior letters to EPA. The most recent previous inspection was performed on May I5, 20I4, with a report documenting that inspection submitted to EPA on June 13, 20I4.

This letter documents the results of the September I 0, 20 I4 post-closure inspection of the Building 7I and Hill 78 OPCAs. That inspection included visual observations of the areas and items shown on Figure I (which is the same as Figure 2 from the final Revised PRSC Plan, as revised in GE's December 20, 201I Cover Slope Repair Summary report). Provided below is a description of those inspection activities and the results of the inspection, including items identified as requiring maintenance or other response actions. The inspection activities, results, and identified response actions are also described in the Post-Closure Inspection Form provided in Attachment A (which is the same as the revised form included in GE's above-referenced Cover Slope Repair Summary report).

Inspection Activities

In accordance with the final Revised PRSC Plan, the September 20I4 post-closure inspection consisted of visual observations of the Building 7I and Hill 78 OPCAs final cover and surrounding areas to determine the overall condition of the final cover and other OPCA components, as well as items needing maintenance. The Building 7I and Hill 78 OPCAs final cover areas were visually inspected to determine the presence of any of the cover-related conditions identified on the attached Inspection Form that could affect the overall integrity of the final cover. In summary, the covers were inspected for: (a) evidence of topsoil erosion; (b) establishment and coverage of vegetation (e.g., bare or sparsely vegetated areas or stressed vegetation);

Corporate En>Jr<..mmental Prcg~ 'Jms

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(c) any areas of uneven settlement relative to the surrounding areas; (d) evidence of damage to the geosynthetic cover components (i.e., geosynthetic drainage composite [GDC], flexible membrane liner [FML], and/or geosynthetic clay layer [GCL]); (e) obstructions/blockages of cover system drainage layer outlet pipes; (f) overall integrity of the cover system (e.g., evidence of excessive erosion, soil movement or slope instability, animal burrows, vehicle ruts, tree/shrub or other undesirable vegetative growth, surface water ponding, inadequate surface water drainage, exposed geosynthetic cover components, unauthorized excavations); and (g) other conditions that could jeopardize the integrity of the final cover systems or the performance of the OPCAs as designed (e.g., unauthorized excavations or use of the OPCA final cover areas).

In addition to inspecting the final cover, the post-closure inspection included observations of the following OPCA components (including the specific items listed for each of these components in the attached Inspection Form and shown on Figure 1):

• Paved site access roads (including the portion of the access road south of the Hill 78 OPCA which EPA has required, and GE has agreed, to be maintained as paved);

• The Building 71 and Hill 78 OPCA final cover access roads;

• The OPCA surface water drainage system, including the North and South Stormwater Basins and the other drainage components described in Section 3 .1.2 of the Revised PRSC Plan, as well as the six new final cover drain pipes installed as part of the slope repair activities in November 2011 - all as listed in the attached Inspection Form and shown on Figure 1;

• The leachate handling system (including the components listed in the attached Inspection Form);

• Perimeter fencing and access gates; and

• Any significant erosion anywhere within the OPCA Removal Action Areas.

The required two-year inspection period for the herbaceous vegetation and the trees originally planted, as well as those trees planted in April 2010 and November 2011 in the Perimeter Vegetated Area and other areas around the OPCAs was previously completed. However, the September 2014 inspection included an inspection of the tree planted in November 2012, as shown on the revised Tree Planting Plan provided as Figure 2, to assess its survival, growth, and condition, and whether it is providing a visual barrier between the OPCAs and the surrounding community. In addition, the trees in the Perimeter Vegetated Area and other areas around the OPCAs for which the two-year inspection period had been completed were inspected during the September 2014 inspection (as part of the OPCA Ancillary Components inspections) to ensure that the areas are properly maintained and free from dead or dying vegetation and to ensure that the trees are continuing to provide a visual barrier between the OPCAs and the surrounding community, as provided in the final Revised PRSC Plan.

Finally, the inspection included an evaluation of whether the items that had been identified for maintenance or repair during the prior inspection in May 2014 had been completed.

Inspection Results

The results of the September 2014 post-closure inspection were recorded on the Post-Closure Inspection Form in Attachment A. The approximate locations of the items identified as requiring response actions are shown (by reference to the corresponding letter and number on the Inspection Form) on Figure 3. Photographs taken during the inspection are provided in Attachment B.

G ,QEIGE_Pittsfield __ CD _OPCA;\Reports and Presentationsllnspections\Fall 2014 Post-Closure lnspection\20714 I 12 14_0PCA LtrRpt.doc

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In general the September 2014 post-closure inspection indicated that the final cover areas of the Building 71 and Hill 78 OPCAs, as well as the other components of the OPCAs, are in good overall condition, although woodchuck burrow holes were observed in six locations at the Hill 78 and Building 71 OPCAs (see Photos # 15 and # 16 in Attachment B). Also, an area of soil sloughing was observed on a portion of the mid-slope swale at the Hill 78 OPCA and sand build-up was observed in the perimeter ditch downgradient of the soil sloughing. The September 2014 inspection also identified the presence of recently treated Cypress spurge, an invasive species, in a few areas, mainly along the western sideslope at the Hill 78 OPCA (within the natural resource restoration/enhancement [NRRE] area) (see Photos #13 and #14 in Attachment B). None of the trees inspected in the Perimeter Vegetated Area or other areas around the OPCAs were observed to be dead, dying, or stressed.

It was also detennined that the maintenance/repair activities identified during the prior inspection in May 2014, as set forth in GE's June 13, 2014 inspection report, had been completed. These included: (a) removing the burrowing animals and repairing the burrow holes by filling those holes with topsoil and conducting seeding and mulching; and (b) spraying the Cypress spurge on the Hill 78 OPCA (within the NRRE area) with Roundup.

In summary, as indicated in Sections II and Section III of the Inspection Form, the September 2014 inspection identified the following items (shown on Figure 3) for response actions: (1) the woodchuck burrow holes in six locations at the Hill 78 OPCA; (2) the presence of recently treated Cypress spurge on the Hill 78 OPCA; (3) the soil sloughing condition on the Hill 78 OPCA; and (4) the build-up of sand in the Hill 78 perimeter ditch.

Response Actions

The response actions for the above items are listed in Section IV of the attached Inspection Form. The burrowing animals will be removed from the OPCAs and the burrow holes filled with topsoil, seeded, and mulched, as needed. To address the recently treated Cypress spurge observed during this inspection, GE will mulch and seed the treated areas and monitor for additional Cypress spurge on the Hill 78 OPCA (within the NRRE area). In response to the soil sloughing condition, GE has proposed to reconstruct a portion of the mid-slope swale as described in an electronic-mail message to EPA on September 22, 2014. Additionally, GE will remove the build-up of sand within the perimeter ditch.

GE plans to proceed with these activities if it does not receive notice otherwise from EPA within 15 days after submission of this letter.

Schedule for Future Inspections

In accordance with the applicable requirements of the final Revised PRSC Plan, post-closure inspections of the Building 71 and Hill 78 OPCAs will be performed twice per year to assess the integrity of the final cover system, the associated surface water drainage and leachate management systems, and certain ancillary components. In addition, inspections of the final cover system and these other components will be conducted after severe storm events (as defined in Section 5.1 of the final Revised PRSC Plan). The next scheduled post-closure inspection will be performed in May 2015.

As noted above, for the herbaceous vegetation planted in the Perimeter Vegetated Area and the trees originally planted, and those planted in April 2010 as part of the Tree Planting Plan, in the Perimeter Vegetated Area and other areas around the OPCAs, the required two-year inspection period to ensure survival and growth was completed with the September 2012 inspection. Similarly, the two year monitoring period for the trees planted in November 2011 was completed with the September 2013 inspection and the two year monitoring period for the tree planted in November 2012 has been completed with the September G:\GEIGE_pittsfield_CD _OPCAs\Reports and Presentationsllnspections\Fall2014 Post-Closure Jnspection\2071411214_0PCA LtrRpt.doc

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2014 inspection. In addition, the trees in the Perimeter Vegetated Area and other areas around the OPCAs for which the two-year inspection period has been completed will continue to be inspected (as part of the OPCA Ancillary Components inspections) to keep the areas free from dead or dying vegetation and to ensure that the trees are continuing to provide a visual barrier between the OPCAs and the surrounding community, as provided in the final Revised PRSC Plan.

Future post-closure inspections will be conducted in accordance with the final Revised PRSC Plan. Following each such inspection, a report will be submitted to EPA within 30 days of the inspection, which will include a summary of the status of the maintenance activities identified during the prior inspection (if applicable) and will also include a completed inspection checklist (using the form set out in the final Revised PRSC Plan, as revised in the Cover Slope Repair Summary report) and a proposal for any necessary repair or replacement activities.

Please call me if you have any comments or questions.

Sincerely yours,

r-KmVu)Jul. --~~ . . &lJ lSke

Richard W. Gates Senior Project Manager- Environmental Remediation

Attachments

cc: Dean Tagliaferro, EPA John Kilborn, EPA Christopher Ferry, ASRC Primus (electronic copy) Robert Leitch, USACE Michael Gorski, MassDEP* Eva Tor, MassDEP* John Ziegler, MassDEP (2 copies+ electronic copy) Scott Campbell, Avatar Environmental (2 copies) Nancy E. Harper, MA AG* Karen Pelto, MassDEP Corydon L. Thurston, Executive Director, PEDA Nate Joyner, City of Pittsfield Gina Armstrong, Pittsfield Health Department Roderic McLaren, GE* Peter Wojcik, GE* James Nuss, ARCADIS James Bieke, Sidley Austin Public Information Repositories GE Internal Repository

*cover letter only

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Figures

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OPCA COMPONENTS SUBJECT TO

POST-CLOSURE INSPECTION

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ITEMS SUBJECT TO INSPECTION UNDER OPCA POST -REMOVAL SITE CONTROL PLAN:

ACCESS ROAD

PORTION OF ACCESS ROAD SPEaFICALLY REQUIRED BY EPA TO BE MAINTAINED AS PAVED

PERIMETER VEGETATED AREA

~RIPRAP

---FM--- LEACHATlE COLLECTION FORCE MAIN

"- " -"- " - MID-SLOPE SWALE/PERIMETER DRAINAGE DITCH

DRAINAGE CULVERT (2 OPENINGS)

ANCHOR TRENCH DRI'JNAGE PIPES (2 6-INCH DIAMETER OUTLET PIPES AT EACH LOCATION) -

--x--x-- SECURITY FENCE

NOTES:

FINAL COVER DRI'JN PIPE (1 6-INCH DIAMETER OUTLET PIPE AT EACH LOCATION)

1. IN ADDITION TO THE ITEMS LISTED i'JBOVE. ALL ITEMS HIGHLIGHTED IN ORANGE ARE SUBJECT TO INSPECTION UNDER THIS PRSC PLAN.

2. ALL TlREES THAT COMPRISE THE V1SUAL BARRIER AROUND THE PERIPHERY OF THE OPCAS INCLUDING THE TREES SHOWN ON FIGURE 3 OF THIS REV1SED PLAN ARE ALSO SUBJECT TO INSPECTION.

N/F PITTSFIELD GENERATING

COMPANY FACILITY BASIN OUTLET PIPE

PARKING LOT FOR BUILDINGS OP-1 AND

OP-2 IN THE GENERAL DYNAMICS FACILITY

NOTES:

LEGEND:

- - - - BOUNDARY OF BUILDING 71 AND HILL 78 ON-PLANT CONSOLIDATION AREA REMOVAL ACTION AREAS

@ DRAIN MANHOLE

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--o--o-- STORM SEWER (DRAINAGE) LINE

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--- _,=---- INDEX CONTOUR LINE

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------ LIMIT OF FINAL COVER

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SANITARY MANHOLE FOR REROUTED PIPELINE

DRAIN MA NHOLE FOR REROUTED PIPELINE

FLOW DIRECTION FROM NORTH OR SOUTH STORMWATER BASINS TO THE DETENTION BASIN

1. BASEMAP INFORMATION BASED ON FIELD SURVEY INFORMATION OBTAINED FROM SK DESIGN GROUP, INC. ON OCTOBER 6, 2006, DECEMBER 11, 2006, JANUARY 30, 2008, APRIL 15, 2009, MAY 15, 2009 AND AUGUST 24, 2010. ADDITIONAL BASEMAP INFORMATION BASED ON "EXISTING ~TE PLAN" PREPARED BY ARCADIS BBL, DA TlED APRIL 2007.

2. SEWER RELOCATION FEATURES AND FIELD SURVEY TOPOGRAPHY ARE BASED ON FIELD SURVEY INFORMATION OBTAINED FROM SK DESIGN GROUP, INC. ON APRIL 15, 2009.

3. ELEVATIONS SHOWN ARE REFERENCED TO NATIONAL GEODETIC VERTICAL DATUM (NGVD 1929).

4. HORIZONTAL DATUM IS REFERENCED TO THE MASSACHUSETTS STATE PLANE COORDINATE SYSTEM (NAD 1927).

5. CONTOUR INTERVAL EQUALS I FOOT.

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GRAPHIC SCALE

~ARCADIS

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TREE PLANTING

AREA

NUMBER AND TYPE OF

TREES

TREE SPACING REQUIREMENTS

HEIGHT (FT.) AT TIME OF

INSTALLATION

1 17 - NORWAY SPRUCE

10 FT. ON CENTER, 8 FT. OFF FENCE LINE

TO CENTER OF TREE

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2 7 - NORWAY SPRUCE

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TO CENTER OF TREE

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3 13 - NORWAY SPRUCE

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4 - 5 FT.

4 4 - NORWAY SPRUCE

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4 - 5 FT.

5 10 - NORWAY SPRUCE

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4 - 5 FT.

6 5 - NORWAY SPRUCE

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7 7 - SUGAR MAPLES

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TREE PLANTING

AREA

NUMBER AND TYPE

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INSTALLATION DATE

HEIGHT (FT.) AT TIME OF

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3 - WHITE PINE

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1 - WHITE PINE NOVEMBER 2012 7 FT.

2 - WHITE PINE NOVEMBER 2011 8 FT.

TREE PLANTING PLAN

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LEGEND:

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@ DRAIN MANHOlE

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----- LIMIT CF CONSCLDATED MATERIALS

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e DMH DRAIN MANHOlE FOR REROU1ED PIPELINE

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..... FLOW PAlH FR<lN STORIIIWATER BASIN TO DETENliON BASIN

- ··-··-··-··-··-··-··-··- DRAINAGE DITCH

INSPECllON OBSERVATION ITEW

NOTES:

1. BASEMAP INFORNATION BASED ON FlELD SURVEY INFORMATION OBTAINED FROM SIC DESIGN GROUP, INC. ON OCTOBER S. 21l0S. DECB.IBER 11, 2008, JANUARY JO. 2:(1011, APRIL 15, 2008, MAY 15, 2009 AND AUGUST 24. 2010. AJ>DITIONAL BASEMAP INFORMAllON BASED ON "EXISTINC SITE PLAN" PREPARED BY ARCAiliS Bill, DATED APRIL 2007.

2. SE'IIIER REL.OCA TlON FEATURES AND FIELD SURVEY TOPOGRAPHY ARE BASED ON FIELD SURVEY INFORNA llON OBTAI NED FR<lN SIC DESIGN GROUP, INC. ON APRIL 15, 2009.

3. El£VA TIONS SHOlllt4 ARE REFEREHCED TO NA TlONAL GEODIETlC VERTICAL DATUM (N(M> 11129).

4. HORIZONTAL DATUM IS REFERENCED TO THE WASSACHUSETTS ST A 1E PLANE COORDINATE SYSTEM (NAD 1927).

5. CONTOUR INTERVAL ECUALS 1 FOOT.

1211' I

GENERAL ELECTRIC COMPANY PITISFIELD MASSACHUSETIS

HILL 78 AND BUILDING 71 OPCAs

SEPTEMBER 10, 20141NSPECTION

~ARCADIS FIGURE

3

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Attachment A

Post-Closure Inspection Form

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Page 1 of 2

I. Inspection InformationInspection Date: Weather Conditions: Partly cloudy, 70°F

Inspection Area: Building 71 OPCA/Hill 78 OPCAs and Select Ancillary Site Components

Performed by: Gregg Rabasco (ARCADIS) Phone Number: (413) 822-1184 E-mail address: [email protected] Coyle (Veolia Water)

Observed by: Izabela Zapisek (Weston Solutions, Inc.)

Time Arrived: 10:00 AM Time Departed: 1:00 PM

Date of Prior Inspection:

Check to confirm that Figure 2 of the Revised Post-Removal Site Control Plan (including revisions to that figure) was reviewed in the field during the inspection: __X____

II. Observations Column A Column B

A. Site Access Road1. Is there excessive cracking, potholes, visible fissures, or spalling? No Yes2. Are the subbase materials exposed in an unsatisfactory manner? No Yes3. Is there evidence of depressions and/or surface water ponding? No Yes4. Is there evidence of excessive rutting? No Yes

B. Final Cover Access Road1. Is there excessive erosion or rutting of road surface? No Yes2. Is there undesirable vegetative growth? No Yes

C. Site Security1. Are the access gates and locks in operating condition? Yes No2. Is the perimeter fence in satisfactory condition (i.e., in proper position, adequately secured to fence posts, etc.)? Yes No3. Are the posted signs on the perimeter fence securely attached to fence and visible? Yes No

D. Final Cover System1. Are there bare spots (void of vegetation) or areas of sparse vegetation? No Yes2. Is there evidence of stressed vegetation? No Yes3. Are there exposed geosynthetic cover components? No Yes4. Is there evidence of topsoil erosion or other excessive erosion? No Yes5. Is there evidence of tree or shrub growth or other undesirable vegetative growth? No Yes6. Is there visible evidence of damage to the geosynthetic cover components? No Yes7. Is there evidence of burrowing animals? No Yes8. Is there evidence of uneven settlement? No Yes9. Is there evidence of ponding water conditions? No Yes

10. Is there evidence of excessive wheel rutting? No Yes11. Are the slopes adequate for surface water drainage? Yes No12. Are the cover system drainage layer outlet pipes (anchor trench and final cover) at all fourteen locations visible and free of obstructions? Yes No13. Is there evidence of soil movement or slope instability (e.g., cracks in the soil cover running parallel to the slope or soil sloughing)? No Yes14. Is there evidence of unauthorized excavations? No Yes

E.1.

b.

c.Yes No

d. Yes Noe.

2. Does established vegetation in the OPCA mid-slope swales and perimeter drainage ditches provide adequate erosion protection? Yes No3. No Yes

F. Leachate Handling System1. Is the leachate collection/pump manhole (wet well) in satisfactory condition? Yes No2. Yes No3. Are the pumps on the wet well in operating condition? Yes No4. Have the float levels on the wet well been tested? Yes No5. Are the float levels on the wet well in operating condition? Yes No6. Is the high-level alarm on the wet well functional? Yes No7. Is the leak detection alarm on the wet well functional? Yes No8. Are the leachate transfer pipes in satisfactory condition? Yes No9. Are the leachate holding tanks in satisfactory condition? Yes No

10. Is the high-level alarm on each leachate holding tank functional? Yes No11. Is the leak detection alarm on each leachate holding tank functional? Yes No12. Has the auto dialer warning system for the two holding tanks and the wet well been tested? Yes No13. Is the auto dialer warning system in operating condition? Yes No

The full length of the eastern riprap swale located south of the Hill 78 OPCA, the associated detention basin, and the opening for the culvert conveying stormwater under old Merrill Road?

No

The entire length of the OPCA mid-slope drainage swales and perimeter drainage ditches, including inlets and outlets for the seven drainage culverts associated with these drainage swales and perimeter drainage ditches?

NoYes

Yes

The riprap surrounding the stormwater manhole at the northwest corner of the Hill 78 OPCA?

Have the pumps on the wet well been tested?

GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTSBUILDING 71 AND HILL 78 ON-PLANT CONSOLIDATION AREAS (OPCAs)

INSPECTION FORM

Surface Water Drainage System (Including all features/components conveying stormwater from the vicinity of the OPCAs through culvert under old Merrill Road)

September 10, 2014

May 15, 2014

Are the following elements of the surface water drainage system visible and free of excessive sediment, debris buildup, blockages, and damage:

The outlet of the south stormwater basin, the outlet of the pipe that conveys water from that basin to the drainage ditch, and the full length of the drainage ditch that discharges into the eastern riprap swale located south of the Hill 78 OPCA?

Are there bare spots (i.e., areas void of vegetation) or excessive erosion on stormwater basin berm slopes?

a.Yes No

The outlet of the drain from the General Dynamics parking lot that conveys stormwater to the north stormwater basin and the outlet (i.e., riprap forebay and concrete manhole) from that basin?

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GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTSBUILDING 71 AND HILL 78 ON-PLANT CONSOLIDATION AREAS (OPCAs)

INSPECTION FORM

G. Perimeter Vegetation and Tree Plantings1. Are there bare spots (void of vegetation) or areas of sparse vegetation in the Perimeter Vegetated Area? No Yes2. Is there evidence of stressed vegetation in the Perimeter Vegetated Area? No Yes3. Is there evidence of topsoil erosion or other excessive erosion in the Perimeter Vegetated Area? No Yes4. Is there any evidence of drainage problems in the Perimeter Vegetated Area? No Yes5.

6.

7. Is there evidence of undesirable vegetative growth affecting any of the planted trees around the OPCAs? No Yes8. Is there trash or debris in the Perimeter Vegetated Area or along the north side of Tyler Street Extension? No Yes

H. Other1. Was any significant erosion observed anywhere within the OPCA Removal Action Areas? No Yes2. Are there any additional conditions observed during the inspection that require attention? No Yes

III. Inspection ObservationsDescribe observations from Column B in Section II. Use additional pages if necessary.

D4 and D13: Observed soil sloughing condition on a portion of a mid-slope swale at the Hill 78 OPCA. D5: Observed areas of treated Cypress spurge, mainly along the western sideslope at the Hill 78 OPCA.D7: Observed five woodchuck burrows along the Hill 78 OPCA northern sideslope and one woodchuck burrow hole along the Hill 78 OPCA western sideslope E1c: Observed sand build-up in the perimeter drainage ditch in the southeast corner of the Hill 78 OPCA, downgradient of the soil sloughing described in Items D4 and D13.

IV. Inspection Response ActionsDescribe response actions to be conducted for each observation noted in Section III above. Use additional pages if necessary.

D4 and D13: A section of the mid-slope swale berm will be reconstructed as described in GE's September 22, 2014 e-mail to EPA. D5: Continue to monitor Cypress spurge areas and reseed and mulch the previously treated areas.D7: Trap and remove woodchucks. Fill, reseed and mulch burrow holes.E1c: Remove sand from perimeter drainage ditch in the southeast corner of the Hill 78 OPCA.

- The Cypress spurge was sprayed with roundup in areas where It was observed on the Hill 78 OPCA. - The burrowing animals observed on the OPCAs were removed and the burrow holes were filled, topsoiled, seeded, and mulched.

None

Yes

Yes

No

VI. Other Observations

Describe response actions conducted to address prior maintenance needs.V. Prior Inspections

No

Are any dead or dying trees in the Perimeter Vegetated Area or any other area around the OPCAs adversely affecting the visual barrier between the OPCAs and the surrounding community?

Is there evidence that any trees planted in the Perimeter Vegetated Area or other areas around the OPCAs are dead, dying, or stressed (during applicable monitoring period)?

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Attachment B

Site Photographs

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Client: General Electric Company

Project Location: Pittsfield, Massachusetts

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Photo #1: View of the Building 71 and Hill 78 OPCA plateau (photo direction East).

Photo #2: View of the Building 71 OPCA (photo direction North).

Project Name: Building 71 and Hill 78 OPCAs

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Client: General Electric CompanyProject Name: Building 71 and Hill 78 OPCAsProject Location: Pittsfield, Massachusetts

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Photo #3: View of the Building 71 OPCA and South Stormwater Basin (photo direction East).

Photo #4: View of the Building 71 OPCA (photo direction Southeast).

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Client: General Electric CompanyProject Name: Building 71 and Hill 78 OPCAsProject Location: Pittsfield, Massachusetts

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Photo #5: View of the North Stormwater Basin and Building 71 OPCA northern sideslope (photo direction East).

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Photo #6: View of the Building 71 OPCA mid-slope swale down chute/forebay and the North Stormwater Basin (photo direction North).

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Client: General Electric CompanyProject Name: Building 71 and Hill 78 OPCAsProject Location: Pittsfield, Massachusetts

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Photo #7: View of the Hill 78 OPCA northern sideslope (photo direction East).

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Photo #8: View of the Hill 78 OPCA western sideslope and access road (photo direction East).

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Client: General Electric CompanyProject Name: Building 71 and Hill 78 OPCAsProject Location: Pittsfield, Massachusetts

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Photo #9: View of the Hill 78 OPCA western sideslope (photo direction Southeast).

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Photo #10: View of the Hill 78 OPCA eastern sideslope and Building 71 OPCA southern sideslope (photo direction North).

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Client: General Electric CompanyProject Name: Building 71 and Hill 78 OPCAsProject Location: Pittsfield, Massachusetts

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Photo #11: View of the Hill 78 OPCA plateau (photo direction Southeast).

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Photo #12: View of the Hill 78 OPCA plateau (photo direction Northeast).

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Client: General Electric CompanyProject Name: Building 71 and Hill 78 OPCAsProject Location: Pittsfield, Massachusetts

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Photo #13: Recently treated Cypress spurge.

Photo #14: Recently treated Cypress spurge.

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Client: General Electric CompanyProject Name: Building 71 and Hill 78 OPCAsProject Location: Pittsfield, Massachusetts

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Photo #15: Woodchuck burrow hole.

Photo #16: Woodchuck burrow hole.

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Client: General Electric CompanyProject Name: Building 71 and Hill 78 OPCAsProject Location: Pittsfield, Massachusetts

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Photo #17: Soil sloughing on the Hill 78 OPCA.

Photo #18: Soil sloughing on the Hill 78 OPCA.

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Client: General Electric CompanyProject Name: Building 71 and Hill 78 OPCAsProject Location: Pittsfield, Massachusetts

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Photo #19: Soil sloughing on the Hill 78 OPCA.

Photo #20: Sand build-up in the Hill 78 OPCA perimeter ditch.

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Client: General Electric CompanyProject Name: Building 71 and Hill 78 OPCAsProject Location: Pittsfield, Massachusetts

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Photo #21: Sand build-up in the Hill 78 OPCA perimeter ditch.