Transmitted via Electronic Mail and Certified Mail

January 9, 2015

Mr. John Ziegler Bureau of Waste Site Cleanup Department of Environmental Protection 436 Dwight Street Springfield, MA 011 03

Re: GE-Pittsfield/Housatonic River Site East Street Area 1-North (GECD130)

GE Corporate

159 Plastics Avenue Pittsfreld. MA 01201 USA

Grant of Environmental Restriction and Easement- Post-Work Notification Southside Recovery System - Pipeline Replacement

Dear Mr. Ziegler:

ln a letter dated August 18, 2014, the General Electric Company (GE) provided advance notice to the Massachusetts Department of Environmental Protection (DEP) regarding a planned " permitted activity" as set forth in the Grant of Environmental Restriction and Easement (the Grant) for East Street Area !-North within the GE-Pittsfield/Housatonic River Site. The permitted activity, conducted within Tax Parcel Nos. J I 0-8-1, J 10-8-2, Jl 0-8-3, Jl 0-8-4, Jl 0-8-5 , and J I 0-8-6, involved soil excavation to support: ( 1) the removal and replacement of an existing 2-inch diameter steel pipeline, and (2) the connection of a new section of pipe to the remaining pipeline for continued conveyance of groundwater pumped from the Southside Recovery System. This work was conducted within the Open SoiiNegetated Area of the site, pursuant to Subparagraph 4.D (surface and/or subsurface excavation for Utility Work) of the Grant.

The work was initiated on September 9, 2014 and conducted in the manner as described in GE' s August 18, 2014 letter. The uppermost one foot of soil was excavated, stockpiled separate from the deeper soil excavations. The approximate location of the completed excavation is shown of Figure 1. Final excavation dimensions were approximately 20 feet long, 5 feet wide, and 6 feet deep, equating to approximately 25 cubic yards of excavated material. This work was also performed in conjunction with a separate notification provided to U.S. Environmental Protection Agency (USEPA) and DEP on July 17, 2014 related to an excavation within East Street Area 1-South (GEACO 1 00). Together, both excavations were required to replace an approximately one-hundred sixty ( 160) foot section of 2-inch diameter groundwater recovery pipeline. The pipeline section was replaced with new 2-inch diameter High Density Polyethylene (HDPE).

Corporott En-.mor1mentol Proqroms

J. Ziegler January 9, 20 15

Page 2 of2

Following the installation of the new 2-inch diameter HOPE piping, the excavation was backfilled. Based on the field conditions and groundwater elevations, much of the soil excavated from below 5 feet was saturated. It was determined in the field that all excavated soil, including the top one-foot of material, would be temporarily stockpiled at the GE plant site for sampling, analysis, and offsite disposal. Imported clean soil was used to backfill the entire excavation. In addition, no soil that was excavated from below one foot was used as backfill within the top foot. The surface was restored to meet surrounding ground surface elevations as needed. The site work was completed on September II, 2014.

Waste materials generated during the work included approximately 25 cubic yards of soil and asphalt/concrete. Prior to disposal, the waste materials were sampled and analyzed for total PCBs as well as Toxicity Characteristic Leaching Procedure Volatile Organic Compounds, Semi-Volatile Organic Compounds and inorganics. Based on review of the analytical data, the waste materials were transported to the Greentree Landfill (Advanced Disposal) located in Kersey, PA for disposal (disposal confirmation was provided by the Greentree Landfill on December 9, 20 14). The waste material sampling data and disposal documents are provided in Attachment A.

The Grant requires that, following the completion of such a permitted activity, the Grantor (GE) must provide written notice that the planned work was completed, using Exhibit G, the "Post-Work Notification Form for Property with ERE Grant." A copy of the completed Exhibit G is provided in Attachment A.

Should there be any questions or comments, or if additional information is needed, please contact me at 413-448-5909.

Richard Gates Senior Project Manager Global Operations - Environment, Health and Safety

Attachment

cc: Richard Fisher, USEPA Michael Backunas, DEP Rod McLaren, GE Matthew Calacone, GE Shannon Reilly, General Dynamics Chris Ferry, ASRC Primus (electronic) James Bieke, Sidley Austin James Nuss, ARCADIS GE Environmental Library

G :\GE\GE_Pittsfield_CD_ESA_1_North\Correspondenee\Post~Notification-Pipe'ID071511324Pipe Replace.docx

SOUTHSIDE RECOVERY SYSTEM - PIPELINE REPLACEMENT

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GENERAL ELECTRIC COMPANYPITTSFIELD, MASSACHUSETTS

EAST STREET AREA 1 - NORTH

1

Attachment A

EXHIBIT G

POST-WORK NOTIFICATION FORM FOR PROPERTY WITH ERE GRANT

Type of work:

(check all that apply)

I. General Information

_Surface (top foot) excavation of greater than five (5) cubic feet and less than or equal to ten (I 0) cubic yards (per Grant Paragraph 4.A)

_ Surface (top foot) excavation of any volume (per Grant Paragraph 4.8)

_Subsurface (deeper than top foot) excavation often (I 0) cubic yards or less (per Grant Paragraph 4.C)

_x_ Surface or subsurface excavation for Utility Work (per Grant Paragraph 4.D)

_ Emergency excavation (per Grant Paragraph 8)

Property Address: East Street (near southwest comer of former Building 69 footprint) Tax Parcel ID: J I 0-8-6

II. Description of Excavation Activities

Start date of excavation/soil disturbance: September 9, 2014

End date of excavation/soil disturbance: September II, 2014

Amount of soil excavated or moved: 25 cubic yards

Any soil or other excavated material moved out of the Restricted Area? _x_ Yes No

Excavation dimensions (approximate length x width x depth, in feet): _ ____..2..,0'-'ft'-".~x!..-"-5-"'ft,_ . .!!.x...!:6'-'ft'-"."---

Description of project (attach extra sheets, if necessary): Removal and replacement of an approximately 160-foot­long segment of existing 2-inch diameter steel pipeline with a segment of new HOPE piping, which connects the Southside Recovery System to a manhole north of the Northside Caisson.

Final disposition of soil: (attach bills of lading and certificates of disposals, if applicable): Excavated soil was set aside for sampling, analysis and offsite disposal. Imported clean soil was used to backfill the entire excavation. Disposal document is attached.

Attach a plan (e.g., a copy of the Plan of Restricted Area) unless previously submitted - or if boundaries of the any of the restricted areas have changed, a revised Plan of Restricted Area (if previously submitted, identifY date submitted - showing:

(I) location of excavation(s) within the property (2) direction (3) major site features (e.g., roads, buildings, edges of pavement/barriers, locations of utilities if known)

Attach photographs of work area prior to work, during work and post-restoration work, if available (optional).

Was soil sampling and analysis conducted? _x_ Yes _No (available data from nearby areas was reviewed)

If Yes, attach analytical results and show sampling locations (and indicate depths) on an attached plan.

Were the Health and Safety Protocol and/or the Soil Management Protocol (as defined in the ERE Grant), if applicable, followed? (check each that applies1

) _x Health and Safety Protocol was followed _x Soil Management Protocol was followed _Not Applicable

III. Additional Information for Emergency Excavation.

If work was conducted as an Emergency Excavation (see Paragraph 8 ("Emergency Excavation ") of the ERE Grant):

(I) Attach an opinion and completion report prepared by an appropriately trained and licensed professional (including copy of written plan for restoration).

(2) Date and time property owner first obtained knowledge of the emergency:-~-=---------(3) Date and time property owner provided oral notification of the emergency to DEP: ______ _

IV. Signature

Two signatures are required (except for excavations pursuant to Grant Paragraph 4.A or the last paragraph of Grant Paragraph 8, for which only the owner or person conducting the work must sign). The property owner, or person conducting the work if other than the property owner, and the Licensed Site Professional who has overseen the work (where required) must each complete and sign the statement, below.

Owner or person conducting the work if other than the property owner:

I, Richard W. Gates , to the best of my knowledge and belief, state that the material information contained in this submittal is true, accurate and complete.

By: Rkh><d V:·, Gotos -~ ~ rJ Signature: fic~t( /JW N arne/Title'-: _ _ S"'"e""'n"'i""'o.._r .:...P.:..;ro,_.j"""ec""'t'--'M"'-=a.:..:.n,.ag="e'"'"r_,G""'l'""o""'b.::.ai:...O"'""'p""er=-=a:..:;ti'""o..:..:n,._s _-_,E,..,n.:...v'"'"i,_,ro.,.n'""m'""e""'n.:..:.t,_, :....:Hc:;e:;al:..:;th:..:-::.a:.:..nd,__,Sc:a.:.::fe:.:.ty.._

Organization: General Electric Company

Address: ___ ...... ! ""'-5 9~P-'-"Ia,_st'""ic,s'--'A-'-v'-'e::!!ne!:!u"="e,c...!Pc...!itt'""s"-'fi_,_,Je,_,l d:oJ.,--'-M'-"A,_,__,0'--'-1.=.2_,_0 _,__I

Te I ephone #: ---'(.2.4 .!...=13'-'-) 244"-'8"---5"-'9'-"0L9 _

Relationship to site: ---'0""--'-'w'""n""e.._r _ _

Licensed Site Professional:

I, ----'<.!=""--'-'-'-1~-'--'-'='----' to the best of my knowledge and belief, state that the material information contained in this submittal true, a curate and complete.

Signature:

Organization: _ _,A~R~C<!.A.!..!D~I~S~U~S,_, !!.ln!.'::c.:..... __

1 See note 3 in Section V ("Notes About the Use of this Form"), below.

2

Address: 6723 Towpath Road, Syracuse, NY 13214

Telephone #: (315) 671 -9230

Relationship to site: Licensed Site Professional

V. Notes About the Use of this Form

(I) This form is due no later than thirty (30) days after completion of the permitted activities and uses under Paragraph 4 ("Permitted Activities and Uses") of the ERE Grant. For emergency excavations pursuant to Paragraph 8 of the ERE Grant ("Emergency Excavation"), verbal notification is required as soon as possible but no more than two hours after learning of the emergency, and this form is for the post-emergency excavation notice and is due within ten (I 0) days after completion of the necessary restoration in accordance with Paragraph 8 of the ERE Grant.

(2) Separate, 15 days' advance written notice is required for Utility Work excavation activity, pursuant to Paragraph 4.0 ("Surface and/or Subsurface Excavation for Utility Work") of the ERE Grant.

(3) The Health and Safety Protocol and the Soil Management Protocol do not apply to the Permitted Activities and Uses set forth in Paragraph 4.A ("Surface Excavation ofTen ( 10) Cubic Yards or Less") of the ERE Grant. These protocols also do not apply to the Permitted Activities and Uses set forth in Paragraph 4.B ("Surface Excavation of any Volume") of the ERE Grant, except for off-Property disposal, to which Paragraph 9 of the Soil Management Protocol applies.

VI. Where to Submit this Form

Submit this completed form, via certified mail, to: MA Department of Environmental Protection Bureau of Waste Site Cleanup, Special Projects 436 Dwight Street Springfield, Massachusetts 0 II 03 (Attn.: GE Housatonic Removal Action Project Manager)

Submit a copy of this form, via certified mail, to: U.S. Environmental Protection Agency Office of Site Remediation and Restoration 5 Post Office Square, Suite I 00 Boston, Massachusetts 02109-3912 (Attn.: GE-Pittsfield!Housatonic River Site

3

Sample ID: Soil 2Date Collected: 9/22/2014

ppm ND(0.328)ppm ND(0.328)ppm ND(0.328)ppm ND(0.328)ppm ND(0.328)ppm ND(0.328)ppm 0.554ppm 0.554

ug/L ND(10)ug/L ND(10)ug/L ND(10)ug/L ND(250)ug/L ND(10)ug/L ND(10)ug/L ND(10)ug/L ND(10)ug/L ND(10)ug/L ND(10)ug/L ND(10)

mg/L ND(0.05)mg/L ND(0.05)mg/L ND(0.05)mg/L ND(0.05)mg/L ND(0.05)mg/L ND(0.05)mg/L ND(0.05)mg/L ND(0.05)mg/L ND(0.05)mg/L ND(0.05)mg/L ND(0.05)mg/L ND(0.05)

mg/L ND(0.1)mg/L 0.606mg/L 0.0227 Bmg/L 0.005 Bmg/L 0.136mg/L ND(0.0003)mg/L 0.101 Bmg/L 0.0028 B

Cadmium

Units

1,1-Dichloroethene

Aroclor-1260Aroclor-1254Aroclor-1248Aroclor-1242Aroclor-1232Aroclor-1221Aroclor-1016

Arsenic

PyridinePentachlorophenolNitrobenzeneHexachloroethane

TCLP Inorganics

SilverSeleniumMercuryLeadChromium

Parameter

2,4,5-Trichlorophenol1,4-Dichlorobenzene

HexachlorobutadieneHexachlorobenzene3- & 4- Methylphenol2-Methylphenol2,4-Dinitrotoluene2,4,6-Trichlorophenol

Barium

Vinyl chlorideTrichloroetheneTetrachloroetheneChloroformChlorobenzene

TCLP SVOCs

TCLP VOCs

PCBs

TABLE 1WASTE MATERIAL SAMPLING RESULTS

EAST STREET AREA 1 - NORTHGENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS

Carbon tetrachlorideBenzene2-Butanone1,4-Dichlorobenzene1,2-Dichloroethane

Total PCBs

G:\GE\GE_Pittsfield_CD_ESA_1_North\Correspondence\Post-Notification-Pipe\0071511324Tbl.xlsx

Page 1 of 2

1/9/2015

TABLE 1WASTE MATERIAL SAMPLING RESULTS

EAST STREET AREA 1 - NORTHGENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS

1.

2.3.4.5.

Notes:

ND - Analyte was not detected. The number in parentheses is the associated detection limit.

Samples were collected by General Electric Company subcontractors and submitted to SGS Environmental Services, Inc. for analysis of Polychlorinated Biphenyls and Volatile Organic Compounds, Semi-Volatile Organic Compounds, and Inorganics using the Toxic Characteristic Leaching Procedure.

B - Analyte was also detected in the associated method blank at a concentration above the reporting limit.

Data Qualifiers:

mg/L - milligrams per liter.ug/L - micrograms per liter.ppm - parts per million.

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