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Immediate Response Action Completion Report Oxbow Area C General Electric Company Pittsfield, Massachusetts December 1997 J -J -,J iO BBL BLASLAND, BOUCK & LEE, INC. e ngineers & scient i sts

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  • Immediate ResponseAction Completion ReportOxbow Area C

    General Electric CompanyPittsfield, Massachusetts

    December 1997

    J

    -J-,JiO

    BBLBLASLAND, BOUCK & LEE, INC.e ngineers & scient i sts

  • T E C H N I C A L R E P O R T

    Immediate Response Action Completion Report Oxbow Area C

    General Electric Company Pittsfield, Massachusetts

    December 1997

    BLAS1AND. BOUCK & LEE. INC.. engineers A scientists'

    6723 Towpath Road, P.O. Box 66 Syracuse, New York, 13214-0066 (315)446-9120

  • Table of Contents

    Section 1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

    1.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1 1 .2 Site Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

    Section 2. Description of Work Completed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1

    2.1 General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.2 Description of Initial IRA Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 2.3 Description of IRA Removal Action and Planting Activities . . . . . . . . . . . 2-2

    2.3.1 Mobilization and Site Preparation . . . . . . . . . . . . . . . . . . . . . . . . . 2-3 2.3.2 Soil Removal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4 2.3.3 Air Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4 2.3.4 Site Restoration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4

    Section 3. Findings and Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1

    Section 4. Management of Remediation Wastes . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1

    Section 5. Future Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-1

    Figures

    1 IRA Plan and Soil PCB Analytical Results

    Attachment

    1 Photographic Log 2 TCLP Waste Profile Results 3 Air Monitoring Report 4 As-Built Topographic Survey 5 Waste Manifests and Certificates of Disposal

    BLASLAND. BOUCK & LEE. INC. 9Wi550.wPo.-i2/3i/97 engineers & scientists

  • 1. Introduction 1.1 General

    This Immediate Response Action (IRA) Completion Report provides a summary of completed IRA activities at the Oxbow Area C in Pittsfield, Massachusetts in accordance with 310 CMR 40.0427. This summary describes the work performed by the General Electric Company (GE) between October 1995 and October 1997. Section 1 of this IRA Completion report provides an introduction and site description, Section 2 provides a description of the IRA activities, and Section 3 provides a discussion of potential future activities.

    On October 31, 1997, Maxymillian Technologies, Inc. (MTI) completed an IRA on behalf of the General Electric Company (GE) for Oxbow Area C (RTN 1-1 1095) in Pittsfield, Massachusetts. The Oxbow Area C site is depicted on Figure 1 . (While the figure also shows adjacent properties, this report is limited to the Oxbow Area C site; the adjacent properties are being addressed separately.)

    Based on the detection of polychlorinated biphenyls (PCBs) in surficial soils at concentrations greater than 10 ppm and within 500 feet of a residence, a potential imminent hazard was identified at this site under 310 CMR 40.032 l(2)(b) of the Massachusetts Contingency Plan (MCP). GE notified the Massachusetts Department of Environmental Protection (MDEP) in October 1995 regarding this potential imminent hazard. This notification resulted in the performance of a series of IRA-related activities at the site. These activities included additional soil sampling and analysis to delineate the presence of PCBs in surficial soils, the installation of perimeter fencing around the affected area of the site, and the posting of warning signs at the site. These activities comprised the initial IRA activities proposed by GE for the site. However, in a letter from the MDEP dated April 30, 1997, the MDEP identified several additional IRAs to be performed involving a combination of soil removal and revegetation/enhanced vegetation. A supplemental IRA Plan was subsequently developed and submitted to the MDEP on May 27, 1997. The supplemental IRA Plan proposed various IRA activities including removal of surficial soil exceeding 30 parts per million (ppm) PCBs from open grassy portions of the site, removal of surficial soil exceeding 50 ppm PCBs from vegetated portions of the site, and planting enhanced vegetation in vegetated areas of the site that exceed 30 ppm PCBs. (As this site falls into a recreational use scenario, GE evaluated this site for IRA purposes using the MDEP's previously established Short-Term Measure (STM) trigger levels of 30 ppm for recreational use areas; however, GE does not accept that level as indicative of an actual imminent hazard.) In addition, the supplemental IRA Plan identified various data gaps and information needs including: performance of additional soil sampling, development of a planting plan, and performance of a wetlands evaluation. These additional activities were performed in June and July 1997, and the finalized scope of IRA removal action and planting activities was submitted to the MDEP as part of the Notice of Intent (NOI) submittal prepared pursuant to the Wetlands Protection Act (310 CMR 10.00). Figure 1 provides a summary of the analytical data collected at this site, as well as the finalized scope of IRA removal action and planting activities. Verbal approval to perform the activities proposed in the NOI was received from the MDEP in July 1997. GE performed the IRA removal action and planting activities between September 22, 1997 and October 31, 1997.

    1.2 Site Description

    The Oxbow Area C site is located at the terminus of Day Street adjacent to a residential area along the Housatonic River (Figure 1). The site generally slopes toward the river and is composed of an open, grassed area an area vegetated with thick brush and trees. The Housatonic River is located to the north of the site, various residences on Hathaway Street and Day Street are located to the east and south of the site (within 500 feet from the site), a wooded area including walking trails and an intermittent tributary to the Housatonic River is located to the west of the site.

    ________________________________BUVSLAND. BOUCK & LEE, INC.________________________________ 94271550. WPD.. 12/31/97 engineers A scientists 1-1

  • The site is wholly located within the 100-year floodplain of the Housatonic River as well as within the 100-foot buffer zone. A wetland assessment performed for the site (and submitted with the NOI) indicated that the portion of the site subject to removal actions, was a typical floodplain and did not contain jurisdictional wetland areas.

    The Tax Parcel ID for the site is 18-23-6, and the property is owned by a private citizen (Ermino S. Barbalunga, Jr.). An access agreement was granted by Mr. Barbalunga for GE to access the property for the purpose of undertaking the IRAs.

    BL>\SLAND. BOUCK & LEE. INC. 9427I550.WPD-I2/3I/97 engineers & scientists 1-2

  • 2. Description of Work Completed _________ 2.1 General

    This section presents a description of IRA activities performed at the site between October 1995 and October 1997. Section 2.2 presents a description of initial IRA activities conducted between October 1995 and July 1997 that included performing soil sampling, posting warning signs, and installing a perimeter fence. Section 2.3 presents a description of the IRA activities conducted in September and October, 1997 that included removing certain surficial soils and planting enhanced vegetation. Figure 1 provides a summary of results from the PCB sampling efforts, the location of the perimeter fence, and an identification of the areas subject to surficial soil removal and enhanced vegetation planting. A photographic log of project activities is provided in Attachment 1.

    2.2 Description of Initial IRA Activities

    On October 16, 1995 GE provided notification to the MDEP of a potential imminent hazard at Oxbow C due to the presence of PCBs in surficial soils at concentrations greater than 10 ppm and within 500 feet of a residence. On October 24, 1995 GE received a Notice of Responsibility (NOR) letter from MDEP that required various IRAs and assigned a Release Tracking Number (RTN) to the Oxbow C location. The IRAs required by MDEP included posting signs, collection of additional surficial samples (0- to 6-inch depth), fencing the area, mailing "PCB Question and Answer" documents, and the provision of property ownership details to MDEP.

    On October 27, 1995 written permission was received from the owner to install warning signs for 90 days. The eight additional surficial samples were taken by Blasland, Bouck & Lee (BBL) on November 9, 1995. On November 29, 1995 GE submitted a Release Notification Form (RNF) and the required property owner information to MDEP. In a December 1 1, 1995 letter GE requested a meeting with the owner to discuss installation of the fencing.

    On December 14, 1995 representatives of GE met with the property owner and discussed fencing and surficial soil removal as IRA alternatives. The property owner indicated that he was not interested in fencing or surficial removal and rather would prefer that his property be remediated so that it could be used for light industrial development. On January 12, 1996 GE sent an IRA Status Report to MDEP and also sent a letter to the owner requesting another meeting to discuss possible alternatives for his property under the Massachusetts Contingency Plan (MCP). In this letter an indefinite extension for the maintenance of signs was also requested. There was no response from the owner to these requests.

    On or about March 1 5, 1996 MDEP requested that GE prepare and submit an IRA plan for the site. That document was prepared and sent to MDEP on March 20, 1996. In April and May of 1996 GE attempted to contact the owner on several occasions to discuss the required IRAs. As a result of discussions between GE and MDEP, MDEP indicated that additional sampling would be required to further delineate potential contamination before any removal/capping activities could be undertaken. In response, GE submitted a new sampling plan (surficial samples) on June 7, 1996, and it was verbally approved by MDEP on June 14, 1996. A meeting was held with representatives of GE and the property owner on June 18, 1996 to discuss the need for additional sampling and capping of the Oxbow C area. On June 21, 1996 GE received a letter from the owner granting GE access to the Oxbow C area for additional sampling and excavation/removal of surficial soils.

    On June 28, 1996 BBL collected 10 additional soil samples. Based on the results of this sampling, GE sent a proposal to the MDEP on August 1, 1996 for additional sampling (14 surficial samples). On August 13, 1996 GE received verbal approval from MDEP to proceed with the proposed sampling. This next round of samples was collected by BBL on August 26, 1996.

    BLASLAND. BOUCK & LEE, INC. 9WI550.WPD- afliw engineers & scientists 2-1

  • Based on the results of the August 26, 1997 sampling, GE met with MDEP on October 17, 1996 at the Oxbow C site to review additional sampling alternatives. On October 22, 1996, a proposal for additional sampling was sent to MDEP (22 surficial samples). On October 31,1996 MDEP verbally requested changes to the sampling proposal. Appropriate changes (sample locations) were made to the sampling proposal and it was again sent to MDEP on November 1, 1996. On November 7, 1996 verbal approval was received from MDEP to proceed with the sampling as proposed. On November 27, 1996 BBL collected 22 additional surficial samples.

    On January 2, 1997 MDEP verbally requested that GE submit an additional sampling plan and an IRA proposal for installation of a fence. The sampling plan (10 locations) and proposed fence location were submitted with the January 13,1997 status report. The sampling plan was conditionally approved by the MDEP in a letter dated March 7, 1997 that requested the collection of eight additional surficial soil samples. This sampling (18 samples total) was performed by BBL on March 28 and April 4, 1997.

    In accordance with an April 30, 1997 MDEP letter providing conditional approval of GE's January 13, 1997 IRA Plan, GE incorporated MDEP comments and prepared a revised IRA Plan, involving (depending on the concentration of PCBs) several measures to remove and/or restrict access to the existing surficial soils. Additional details regarding the proposed scope of activities is contained in GE's revised IRA Plan dated May 27, 1997. One component of that IRA Plan involved the collection of additional soil samples to better delineate and characterize the areas potentially subject to the remedial measures. Such sampling was performed on June 13, 1997 and included the collection of 31 additional surficial soil samples with analysis for PCBs. These sample locations, generally collected within a 25-foot grid pattern, were selected to address several remaining data needs and to facilitate design and implementation of the subsequent IRA. Following this sampling activity, three additional delineation surficial soil samples were collected and analyzed for PCBs on June 23, 1997. In addition, one composite sample (consisting of grab samples from five locations) was collected and analyzed for toxicity characteristics using the Toxicity Characteristic Leachate Procedure (TCLP). This composite sample was collected to assist in determining appropriate disposition options for the materials expected to be removed from the site as part of the IRA. The results of the TCLP sampling (Attachment 2) indicated that the soil was subject to Toxic Substances Control Act (TSCA) disposal requirements only.

    Finally, during the week of May 12, 1997, GE installed approximately 700 feet of chain link fence around the portion of the site shown on Figure 1. This activity, which also involved the posting of warning signs, was completed as part of GE's original IRA Plan proposal. The location of this fence was based on the results of surface soil sampling and analysis and was designed to restrict access to surficial soils within the site containing PCBs at concentrations greater than 30 ppm.

    2.3 Description of IRA Removal Action and Planting Activities

    The proposed IRA removal action and planting activities were described in the May 27, 1997 IRA Plan and were subsequently modified and submitted to the MDEP as part of the NOI. The IRA Plan was verbally approved by the MDEP in July 1997, and the Pittsfield Conservation Commission (PCC) issued an Order of Conditions to be followed during implementation of the project. The overall components of this portion of IRA are shown on Figure 1 and involved activities to further minimize the potential for contact with PCBs present in the surficial soils.

    As shown on Figure 1, surficial soils (i.e., top 6 inches) were identified for removal from the grassy portions within the newly fenced area. Approximately 130 cubic yards of soil from an area of approximately 7,200 square feet were identified for removal from this area.

    ________________________________BLASLAND. BOUCK & LEE. INC.________________________________ 94271550.WPO- 12/31m engineers & scientists 2-2

  • In addition, those surface soils exceeding approximately 50 ppm and located in other (i.e., vegetated) portions of the fenced area were identified for removal. Figure 1 identifies the approximate areas and limits of surficial soils subject to removal. Approximately 160 cubic yards of soil from an area of approximately 8,400 square feet was identified for removal from this area.

    Those areas that were not subject to soil removal but contained PCBs in surficial soils at concentrations exceeding the trigger level of 30 ppm were subject to the planting of additional vegetation. As shown on Figure 1, GE identified four areas within which the existing surface vegetation would be enhanced through the planting of various brush, shrubs, trees, etc. The areas targeted for enhanced vegetation were based on the available surficial soil PCB data, with the general intent of enhancing the vegetative cover already present in those areas where PCB concentrations in surficial soils exceeded 30 ppm PCBs.

    The IRA removal action and planting activities are further described below and include, mobilization and site preparation, surficial soil removal, air monitoring, and site restoration.

    2.3.1 Mobilization and Site Preparation

    Prior to implementing the IRA, as required, GE provided 48-hour notice to the MDEP and PCC. In addition, the PCC was provided with written verification certifying that all material to be removed from the site would be disposed in a legal manner and that the disposal location would be the Chemical Waste Management (CWM) facility located in Model City, New York.

    Initial site activities were performed on September 22,1997 and involved the establishment of appropriate erosion control measures consisting of the installation of silt fencing and hay bales along the west, north, and east sides of the fenced area, to limit the potential for off-site migration of PCB-containing materials. In addition, silt fencing and hay bales were installed along the west side of the access road location. The erosion control materials were maintained and repaired as required for the duration of the project.

    The access road was then installed on September 26, 1997, from the end of Day Street to the fenced area. The access road was installed to limit the potential for disturbance of the underlying soils as well as to provide a clean and stable surface for transportation vehicles. The access road was constructed by placing a geotextile followed by 4 to 6 inches of 1 '/2-inch stone.

    Prior to the performance of site clearing, an identification of the tree and shrub vegetation species and density was performed in the areas to be cleared. However, GE does not intend to replant the trees and shrubs at this time, in order to accommodate the potential for future work at this site. The PCC Order of Conditions is valid for a period of three years, if additional response actions are not performed within this three-year period, the trees and bushes will be replanted.

    Site clearing activities were initiated on September 29, 1997. Site clearing involved the removal of brush and small-diameter trees. Several large-diameter trees (> 10-inch diameter) located within excavation areas were not removed. To the extent possible, clearing of vegetation was limited to the areas subject to soil removal; however, some minimal clearing was also performed to provide access for excavation equipment to the northern and western portions of the site. The cleared brush and trees were chipped on site and the wood chips were spread within the open grassed area that was to be excavated. The wood chips were spread in this location to provide a clean surface for the transportation vehicles to be staged while loading. The wood chips were subsequently removed and transported off site for disposal with the soils from that area.

    ________________________________BLASLAND. BOUCK & LEE. INC.________________________________ 94271550.WPO- iMi/9? engineers & scientists 2-3

  • 1

    2.3.2 Soil Removal

    Soil removal activities were initiated on October 3, 1997 and were completed on October 15, 1997. Excavation was performed using backhoes and a front-end loader. Hand excavation was also performed as necessary around large trees that remained in the excavation area. In addition, several large pieces of concrete debris that were present at the surface were picked up, brushed off, and replaced onto the surface following placement of backfill. Approximately 6 inches of soil was removed from the open, grassed area (approximately 7,200 sq ft) and approximately 6 inches of soil was removed from the vegetated area (approximately 8,400 sq ft). In total, 330 cy of soil was removed and disposed. This amount was slightly more than the estimated amount to be removed (290 cy) due to the need to over-excavate in certain areas where concrete debris was encountered.

    During excavation activities, care was taken to prevent the contamination of areas not subject to excavation. This was accomplished by working the excavation from the perimeter fence toward the center, and not allowing equipment to track through disturbed areas onto undisturbed areas. Initially, the excavated materials were stockpiled within the open, grassed area in a location that was subject to excavation. The soil stockpile was covered with plastic when not actively being used. The soil stockpile was subsequently loaded into transportation vehicles for off-site disposal. The soil materials beneath the stockpile and in the truck loading area were then direct-loaded into the transportation vehicles.

    2.3.3 Air Monitoring

    Air monitoring was performed during excavation and backfill activities to evaluate and control (if necessary) the potential for worker and community exposure to the constituents of interests. Air monitoring was performed using an MIE data RAM paniculate monitor for six sampling events. Average concentrations ranged from 0.019 mg/m3 to 0.065 mg/m3. The average particulate level did not exceed the notification of 0.070 mg/m3 on any of the sampling days. An unusually high particulate level was recorded on the first day of monitoring; however, it was determined that the remediation contractor had operated equipment in close proximity to the monitor causing it to malfunction. This problem was corrected and valid readings were obtained for the remainder of the project. Attachment 3 provides the air monitoring report for this project.

    2.3.4 Site Restoration

    In accordance with the IRA Plan, the areas subject to excavation were backfilled with clean, off-site borrow. A geotextile was initially placed at the base of the excavation, then the backfill was placed and a bulldozer was used for grading. Backfilling and attendant grading were performed to restore the excavation area to the pre-excavation elevation. An as-built topographic survey was performed to verify the restored elevation (Attachment 4). As shown by this survey, the excavated areas were restored to the pre-excavation elevations; therefore, there is no change in the flood storage capacity. Backfilling activities were completed on October 16, 1997

    The off-site borrow consisted of an equal mixture of clean sand and topsoil that was free of roots, plants, debris, and similar deleterious materials. The backfill source was a MTI stockpile, located at Tamarack Road in Pittsfield, Massachusetts. This backfill source has been tested previously for use on other GE projects and has been demonstrated to be clean.

    The backfilled areas were hydro seeded on October 16, 1997. On October 24, 1997 the four areas to receive enhanced vegetation were planted. Per the IRA Plan, the four areas (1,100 sq ft area) were planted with a total of 80, 1-gallon-size plants (40 rosa rugosa and 40 rosa multiflord). Final site restoration activities were performed on October 29-31, 1997. These activities included:

    _________________________________BLASLAND. BOUCK & LEE, INC._________________________________ 9«71550WPO-12/31/97 engineers 4 scientists 2-4

  • removal of the access road materials; seeding and mulching of the access road area; removal of erosion control materials (with the exception of silt fence located along the west, north, and east sides of the site that will remain in-place until vegetation has sufficiently re-established; and removal of the perimeter fence.

    BLASLAND. BOUCK & LEE. INC. 9427iS50.wPo.-i2/3i/97 engineers & scientists 2-5

  • 3. Findings and Conclusions This IRA Completion Report describes the work performed by GE between October 1995 and October 1997 at the Oxbow C area site (RTN 1-11095) located in Pittsfield, Massachusetts. The IRA activities involved establishing access restrictions, posting warning signs, performing several sampling events to delineate the extent of impacted surface materials, removing impacted surficial soils, and planting enhanced vegetation. From the performance of this IRA, GE has achieved the overall objective of reducing the MDEP-asserted imminent hazard and the potential for human exposure to PCBs present in surface (0- to 6-inch depth) soils. A summary of the findings and conclusions for each portion of the IRA is presented below.

    Access Restrictions

    In an effort to limit the potential for off-site receptors to contact the PCB-containing soils at the site, a perimeter fence was installed surrounding the site and warning signs were installed. These measures were effective in their intended use. The perimeter fence and warning signs were maintained throughout the duration of IRA activities and upon the completion of these activities were removed.

    IRA Sampling

    IRA sampling activities related to delineating the extent of soil containing PCBs at concentrations greater than 30 and 50 ppm. These activities involved an iterative sampling and analysis approach. Sampling of surficial soils were performed on seven occasions between November 1995 and June 1997, resulting in the collection of 106 surficial soil samples for PCB analysis. The results of these sampling activities were used to develop the finalized IRA Plan, as submitted with the NOI.

    IRA Removal Action and Planting Activities

    The results of the surficial sampling results were used to estimate the extent of open, grassed area with PCBs greater than 30 ppm, and the extent of vegetated area with PCBs greater than 50 ppm. Utilizing this information approximately 6 inches of soil with PCBs greater than 30 ppm was removed from the open, grassed area (approximately 7,200 sq ft), and approximately 6 inches of soil with PCBs greater than 50 ppm was removed from the vegetated area (approximately 8,400 sq ft). In total, 330 cy of surficial soil was removed.

    The results of the surficial sampling were also used to estimate the extent of vegetated areas with PCBs greater than 30 ppm. Utilizing this information, approximately 1,100 sq. ft. of area was planted with 80 rose bushes to further enhance the vegetative barrier already present in that area.

    The combination of the above measures have provided a reduction in the potential for human exposure to PCBs present in the soils at the site.

    BLASLAND. BOUCK & LEE. INC. 9«7i550.wro-i2fli/97 engineers & scienlists 3-1

  • 4. Management of Remediation Wastes_______ The excavated materials were loaded into end-dump truck trailers for over-the-road transportation to the disposal facility. During the loading process, plastic sheeting was placed in the loading area to prevent contamination of the loading area. All truck trailers were lined with polyethylene sheeting prior to loading and tarped prior to departure from the site. A total of 17 tucks were loaded with a total of 378 tons of material for disposal as TSCA material at the CWM facility located in Model City, New York. Used personal protective equipment (PPE), polyethylene sheeting, and waste materials generated during the removal activities were also disposed with the soil. Attachment 5 provides copies of the executed waste manifests and the completed certificates of disposal for the soil.

    The soil that was removed during the planting of enhanced vegetation, was placed into two 55-galIon drums and transported to the GE facility for disposal as non-hazardous PCB-containing material at an appropriate disposal facility.

    Excavation equipment that had contacted PCB-containing material was subject to a cleaning consisting of a high-pressure water wash and visual inspection, prior to handling of clean backfill and prior to leaving the site. The cleaning liquids were added to the soil stockpile and disposed with the soil. The final cleaning of the excavator bucket was performed at the GE Building 12Y cleaning facility.

    As the stone used for the access road did not contact PCB-containing material, the stone was transported to the GE Building 9B area, and stockpiled to be re-used by GE. The geotextile for the access road was removed and transported to GE's Building 12 facility and placed into a roll-off for disposal as non-hazardous PCB-containing material, at an appropriate disposal facility.

    The hay bales used for erosion control were spread around the site as mulch. The silt fence located along the access road was removed and transported to GE's Building 12 facility and placed into a roll-off for disposal as nonhazardous PCB-containing material, at an appropriate disposal facility.

    The fence posts for the perimeter fence were cut off at grade and then driven below grade. The posts were then transported to GE's Building 12 facility and placed into a roll-off for salvage as scrap metal. The fence fabric, toprail, and gate were transported to the GE Building 9B area to be salvaged for re-use.

    BIASLAND, BOUCK & LEE. INC. 9427i5w.wro~iMi/97 engineers i. scientists 4-1

  • 5. Future Activities With respect to future MCP-related activities at the site, GE intends to comply with the appropriate provisions of the MCP and the need for further evaluation and/or remedial response actions.

    Additionally, GE will perform quarterly inspections of the site until such time that the vegetation has adequately re-established. Any repairs due to erosion or plant mortality will be performed immediately upon identification. The results of the quarterly inspections, as well as a description of any repairs, will provided to the MDEP within two weeks from completion of the inspections. Finally, as noted previously, GE does not at this time intend to replant the trees and shrubs that were cleared to facilitate excavation, in order to accommodate the potential for future work at this site. However, if additional response actions are not performed within the three-year period which the PCC Order of Conditions is valid, the trees and bushes will be replanted.

    BLASLAND. BOUCK & LEE. INC. 91271550.wro- 12/31/97 engineers & scientists 5-1

  • B L A S L A N D . BOUCK & L E E , INC. » n g l n « e r t i t t c l o n t l t t t

    Figures

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    BLASL-AND. BOUCK & L E E . INC. » n 'g 'i n t » r s A s c i e n t i s t !

    Attachment 1 Photographic Log

  • /7

    AREA PRIOR TO EXCAVATION

    AIR MONITOR

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    EXCAVATION OF SIX INCHES

    LOADING SOIL FOR SHIPMENT

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    SOIL REPLACEMENT

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    AREA PRIOR TO SEEDING

  • B L A S L A N D , B O U C K & L E E , INC. onglnoors A s c i e n t i s t s

    Attachment 2 TCLP Waste Profile Results

  • Adirondack Lrvofivoial ijccv«;t.-s me-.

    Eiptr Itnca l« tha s oJutlaa 314 North Pearl Street • Albany, New York 12207 • 800-8484983 • (518) 4344946 • Fax (SIS) 4340891

    CLIENT: General Electric Company Date Sampled: 06/23/97 CLIENT'S SAMPLE ID: OX-FC-Cl Date sample received: 06/24/97 AES sample #: 970624 DOl Samples taken toy: BBL Location: "C" Area Sample

    MATRIX: Soil composite

    PARAMETER PERFORMED METHOD RESULT UNITS MOTEBK RE!

    TCLP Extraction (ZHE) EPA-1311 Complete AP-BJ-4S 06/25/97

    Benzene - TCLP Extract EPA-8240

  • L.C.L.

    Adirondack It tk» solvHon

    314 North Pearl Street • Albany, New York 12207 • 800-8484983 • (518) 4344546 • Fax (518) 4344S91

    CLIENT: General Electric Company CLIENT'S SAMPLE ID: QX-FC-Ci AES sample f: 970624 D01 Samples taken by: BBL

    continued:

    Pentachlorophenol-TCLP Extract

    2,4,5-Trichlorophenol-TCLP Ext

    2,4,6-Trichlorophenol-TCLP Ext

    Arsenic-TCLP Extract

    Barium-TCLP Extract

    Cadnium-TCLP Extract

    Chromium-TCLP Extract

    Lead-TCLP Extract

    Mercury-TCLP Extract

    Selenium-TCLP Extract

    Sllver-TCLP Extraction

    Date Sampled: 06/23/97 Date sample received: 06/24/97

    Location: "C" Area Sample composite

  • BLASLAND, BOUCK & L E E , INC. e n g i n e e r s A i c I o n t I ) t t

    Attachment 3 Air Monitoring Report

  • AMBIENT AIR MONITORING FOR PARTICULATES

    DAY STREET REMEDIAL ACTION SITE

    GENERAL ELECTRIC COMPANY PITTSFIELD, MA

    Prepared by

    Berkshire Environmental Consultants, Inc. 152 North Street, Suite 250

    Pittsfield, Massachusetts 01201

    November 1997

  • Table of Contents

    Project Summary

    1.0 Introduction 1

    2.0 Project Description 2

    3.0 Analytical Results 4

    4.0 Quality Assurance/Quality Control 6

    5.0 Problems and Disruptions 7

    APPENDICE

    Appendix A

  • PROJECT SUMMARY

    Berkshire Environmental Consultants, Inc. has completed an ambient air monitoring program for particulates at the General Electric Company's Day Street remedial action site. The purpose of the" sampling was to monitor changes in ambient air concentrations during the course of remediation activities. - •

    The particulate sampling program consisted of six sampling events at the Day Street site. Sampling was performed October 6-10, 1997 and concluded on October 16, 1997. The sampling period varied with the length of time of the remediation activities.

    The ambient particulate samples were collected using a MIE dataRAM particulate monitor. Readings were taken in real-time by the monitor and were downloaded to a computer and analyzed. The dataRAM has a measurement range of 0.001 to 400 mg/m3.

    Average concentrations ranged from 0.019 mg/m3 to 0.065 mg/m3 at the Day Street site. Wind direction fluctuated, but the predominate wind directions were westerly.

  • Ambient Air Monitoring tor Particulates General Electric Company

    Day Street Remedial Action Site November 1997

    Page 1 of 7

    1.0 INTRODUCTION

    Berkshire Environmental Consultants, Inc. was retained by General Electric Company (GE) to conduct ambient air sampling for particulates at the Day Street remedial action site in Pittsfield, Massachusetts. The purpose of the sampling was to monitor changes in ambient air paniculate concentrations during the course of remediation activities.

    Paniculate ambient monitoring was performed October 6-10, 1997 and concluded on October 16, 1997. Meteorological data from an on-site weather station were collected concurrently with the ambient paniculate sampling. All field work, sample collection, recordkeeping and sample analysis were completed by Berkshire Environmental Consultants, Inc.

    This final report presents a summary of all analytical results, sampling activities, quality assurance/quality control objectives, and a summary of meteorological data, as well as a discussion of problems and disruptions related to the sampling program.

  • Ambient Air Monitoring for Particulars General Electric Company

    Day Street Remedial Action Site November 1997

    Pane 2 or' 7

    2.0 PROJECT DESCRIPTION

    2.1 SITE DESCRIPTION

    The Day Street site is a fenced-off parcel of land on the south bank of the Housatonic River, just west of the GE Pittsfield plant. The site is lightly wooded. A residential lot abuts the east edge of the parcel. A site map is included as Figure A.

    2.2 SAMPLING PROGRAM

    The particulate sampling program consisted of six sampling events which averaged 8.6 hours in duration. The dates of the sampling were October 6, 1997 through October 10, 1997 and October 16, 1997. The samples were collected using a MIE dataRAM Real-Time particulate monitor. The dataRAM uses a passive sampling technique and light scattering photometer to determine particulate concentrations. The dataRAM has a measurement range of 0.001 to 400 mg/m3. Particulate data were taken once a minute and were logged by the instrument. The data were averaged and recorded for each sample day. The sampler was mounted on a fence in the southeast corner of the parcel adjacent to the private residence.

    2.3 METEOROLOGICAL MONITORING

    Meteorological data from the Climatronics Electronic Weather Station (EWS) operated at the GE facility in Pittsfield, Massachusetts were obtained and included with the sampling results. The EWS has been operating continuously since 1991 at the GE facility in the East Street Area 2 providing data to support GE activities. The EWS measures many different meteorological variables, but for this project, only the wind speed was needed. The siting of the meteorological station was established with the approval of the Massachusetts Department of Environmental Protection.

  • Ambient Air Monitor ing for Particulates General Electric Company

    Day Street Remedial Action Site November 1997

    • ., Page 4 of ~?

    3.0 ANALYTICAL RESULTS

    3.1 METEOROLOGICAL DATA

    Data from the EWS were summarized and tabulated for each of the sampling days. Table 1 summarizes the wind direction for each sampling day. During the sampling days, the wind direction fluctuated but was predominantly westerly.

    3.2 AMBIENT PARTICULATE CONCENTRATIONS

    The average concentrations of total particulates from the samples taken between October 6, 1997 and October 16, 1997 are contained in Table 1.

    The lowest average paniculate concentration occurred on October 7, 1997 at 0.019 mg/m3. This was also the day which had the most variation in wind direction. The highest average particulate concentration occurred on October 16, 1997 at 0.065 mg/m3. The average particulate concentration over the length of the project was 0.045 mg/m3. The average particulate concentration did not exceed the established project notification level of 0.070 mg/m3 on any of the sampling days.

  • Ambient Air Monitoring for Particulars General Electric Company

    Day Street Remedial Action Site November 1997

    Page 5 of 7

    TABLE 1 AMBIENT AIR PARTICULATE DATA FOR DAY STREET REMEDIATION

    Date AverageConcentration

    (mg/m3)

    Average Period (Hours:Min)

    Predominant Wind Direction

    10/6/97 NA NA NA

    10/7/97 0.019 9:36 NNW, SSE, S

    10/8/97 0.025 8:52 ssw 10/9/97 0.054 9:22 ssw 10/10/97 0.062 7:18 WNW, W

    10/16/97 0.065 8:06 NNW

    Notification Level 0.070

  • Ambient Air Monitoring for Participates General Electric Company

    Day Street Remedial Action Site November 1997

    Page 6 of ~

    4.0 QUALITY ASSURANCE/QUALITY CONTROL

    The following objectives were used as guidelines to assure quality in the design and implementation of the monitoring program.

    The MIE dataRAM monitor was operated in accordance with the manufacturer's procedures.

    All phases of the sampling program were adequately documented. Documentation was maintained to ensure the validity of sample collection and data averaging.

    General Electric Company was kept informed of sampling activity.

    Field quality control procedures were followed.

  • Ambient Air Monitoring tor Participates General Electric Company

    Day Street Remedial Action Site November 199"

    Page 7 of "

    5.0 PROBLEMS AND DISRUPTIONS

    On October 6, 1997, Berkshire Environmental Consultants, Inc. began the paniculate monitoring project. When the lead technician checked on the monitor at mid-day, he discovered an unusually high paniculate level. It was determined that the remediation firm at the site had run heavy equipment in proximity to the monitor, likely increasing the optical background of the instrument and producing high readings.

    Berkshire Environmental Consultants, Inc. recalibrated the instrument and received valid paniculate concentrations for the rest of the project. A memo was sent to GE employees and a copy of that memo is included as Appendix A.

  • APPENDIX A

    BEC, INC. MEMO, PARTICULATE MONITORING AT DAY STREET OCTOBER 7, 1997

  • \ Berkshire Environmental Consultants, Inc.

    152 N o r t h Street • S u i t e 250 • P i t t s f i e l d , MA 01101 • ( 4 1 3 ) 443-0130 • Fax ( 4 1 3 ) 4 4 3 - 1 2 9 7

    .... ^ •

    Memorandum

    To: Dick Gates Ross Clark

    From: uns/P Maura Hawkins 1

    Date: October 7, 1997

    Subject: Particulate Monitoring at Day Street

    Dick/Ross

    This memo is a follow-up to EEC, Inc. discussions and investigation yesterday regarding particulate levels at the Day Street remedial action site. As I discussed with you yesterday, when EEC, Inc. checked the particulate monitor (MIE MiniRam) midday yesterday (10/6/97), the display indicated a relatively high average particulate reading for the day of 70 ug/m3. At the same time, John Bordeau, lead technician with EEC, observed that heavy equipment had operated within a few feet of the instrument. John Bordeau spoke with the Maxymillian worker on site who indicated that Maxymillian was working in another part of the site in the early morning, but had moved to the location immediately adjacent to the monitor in late morning. The Maxymillian worker further indicated that he had observed earlier in the day instantaneous readings on the monitor of greater than 150 ug/m3.

    I reported this condition to you at approximately 2:00 pm. From my discussions with you, I understand that Ross Clark of GE went to the site shortly thereafter and stopped all site work. He verified the particulate reading before and after work stoppage and found that the reading had not changed significantly (approximately 70 ug/m3). At your request, John Bordeau and Ross Clark went to the site to investigate the situation. This site visit occurred at approximately 3:30 pm.

    After inspecting the site and the operation of the instrument, BEC, Inc. has concluded that the instrument was not operating properly after 10:00 am on 10/6/97. We based this conclusion on the following: (1) when the instrument was removed from the field, the instantaneous reading did not go below 70 ug/m3, (2) the downloaded data from the instrument indicate a significant increase in the recorded particulate concentration (>250 ug/m3) at 10:00 am. (3) prior to 10:00 am the average reading was 50 ug/m3, (4) after

    1

  • 10:30 am the particulate concentration never returned to a reading below 70 ug/m3), and (5) -heavy equipment with a significant particulate exhaust had operated immediately adjacent to the instrument. It is likely that the excessively high paniculate concentrations caused an increase in the optical background of the instrument producing false high readings.

    The instrument was calibrated prior to being place in the field and was operating properly prior to 10:00 am. After removing the instrument from the field, EEC cleaned and recalibrated the instrument. It is working properly. In the future, EEC will coordinate more closely with GE and Maxymillian where the site activity is taking place so that we can place the monitor where it will provide representative exposure data for potential off-site receptors data, but be out of range of the immediate influence of equipment exhaust on the site.

    If you have any questions, please do not hesitate to call me or John Bordeau at any time.

  • B L A S L A N D . B O U C K & L E E , INC. n g I n o o r s &

    Attachment 4 As-Built Topographic Survey

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    FIELD MEASUREMENTS MADE SEPTEMBER 29 - OCTOBER 15, 1997

    COORDINATE SYSTEM BASED ON DATA PROVIDED BY BLASLAND BOUCK & LEE

    NEW SE£O

    SANDY TOPSOIL

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    PITTSFIELD, MASSACHUSETTS SCALE 1"=20' REVISIONS IY DATt

    DATE 11/13/97 DR'N. RO CKD. BP

    AP'VD.

    TITLE AS-BUILT EXCAVATION PLAN NO. 18-23-6 GE-1020-1

  • 4i

    BLASLAND. BOUCK & L E E . INC. 9 n g I n » 9 i i & i c l u n t l i t i

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    • N Y G 079S2K4 WASTE MANIFEST P.O. Box 12820, Albany, New York 12212

    ,yp, or print. Oo not ttapte. («*v. 3/97)

    UNIFORM HAZARDOUS 1. Generator's US EPA No. Monifnt Doc. No 2. Fog* 1 of wiinin n^o f̂y boio Im9 WASTE MANIFEST 1 is not required by F*d*ral Law.

    3.Generator's Norn* and Mailing Address CF NVG0798264

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  • Waste Management, Inc.

    CWM Chemical Servicat. Inc. Phona 718/754-8231 1550 Burner fld. P.O. Box 200 Modal City, N. Y. 14107

    Federal EPA ID: NYD049836679

    GE COMPANY ATTN: AIMEE COLE MAD002084093 100 WOODLAWN AVE PITTSFIELD MA 01201-4327

    CERTIFICATE OF DISPOSAL

    CWM Chemical Services, Inc. has received waste material from GE COMPANY on 10/15/97 as described on Hazardous Waste Manifest number NYG0798264 Sequence number 01. CWM Chemical Services, Inc., hereby certifies that the above described material was landfilled in accordance with the 40 CFR part 761 as it pertains to the land disposal of polychlorinated biphenyl contaminated materials. Profile Number: CG5136 CWM Tracking ID: 8147603701

    CWM Unit #: 1*0 Disposal Date: 10/16/97

    Under civil and criminal penalties of law for the making or submission of false or fraudulent statements or representations (18 U.S.C 1001 and 15 U.S.C. 2615) I certify that the information contained in or accompanying this document is true accurate and complete. As to the identified section(s) of this document for which I cannot personally verify truth and accuracy, I certify as the company official having supervisory responsibility for the persons who, acting under my direct instructions, made the verification that this information is true accurate and complete.

    J ILJ/'ANI CKERBOCKER For questions please call TECHNICAL MANAGER our Customer Service Dept. Certificate # 96991 at (800) 843-3604 10/16/97

  • NYG 0798354

    Please type or print. Do not staple.

    UNIFORM HAZARDOUS WASTE MANIFEST .

    1. Generator's US EPA No.

    3.Generotor-s Nome and Mailing Address

    ATTSl A, COtt - • 4. Generator's Telephone Number (U3

    9. Designated Facility Nome and SHeAddrect

    HAZARDOUS WASTE MANIFEST P.O. Box 12820, Albany, New York 12212

    (*ev. 3/97)

    Manifest Dot No 2. Page) of Information within heavy bold line a not required by Federal law.

    NYG0798354 VOOfiLAIiS ATI

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    15. Special Handling Instructions and Ad < IX 3 ef csmncirt or DISPOSAL //-

    Wcrk Ord«r *t 397050 16. GENERATOrs CERTIFICATION: I hereby declare mat me contort* of this < nm t̂f ora ful̂ otrf occufotrty dMcribirenniant; O* if I am o unoH gm^otor, I havo mad* a good forth effort to minimize my wasto and select thepertwtatoirwrKiBementmetrtodmrtaovoitabletenieondthotlccaotferd. - - .- - - • si:,. PrirrteaVTyped Nome »-j MO. i.

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    20. Facility Owner or Operator. Certmcotion of receipt of hmordom motoriob covered by thioonifost encept as noted in Bern 19. •3 Mo. - " D a y Yeor

    ..w.?:c .if . j -.'. ••; ... - i. >-' —5

    COPY 5- Generator - Mailed by TSD Facility

  • vy „

    Waste Management, Inc. «

    CWM Chwnical S«rvic»s. Inc. Phon« 718/754-8231 1550 Balmtr Hd. P.O. Box 200 ModalCity.N.Y. 14107

    Federal EPA ID: NYD049836679

    GE COMPANY ATTN: AIMEE COLE MAD002084093 100 WOODLAWN AVE PITTSFIELD MA 01201-4327

    CERTIFICATE OF DISPOSAL

    CWM Chemical Services, Inc. has received waste material from GE COMPANY on 10/16/97 as described on Hazardous Waste Manifest number NYG0798354 Sequence number 01. CWM Chemical Services, Inc., hereby certifies that the above described material was landfilled in accordance with the 40 CFR part 761 as it pertains to the land disposal of polychlorinated biphenyl contaminated materials. Profile Number: CG5136 CWM Tracking ID: 8147611301

    CWM Unit #: 1*0 Disposal Date: 10/16/97

    Under civil and criminal penalties of law for the making or submission of false or fraudulent statements or representations (18 U.S.C 1001 and 15 U.S.C. 2615) I certify that the information contained in or accompanying this document is true accurate and complete. As to the identified section(s) of this document for which I cannot personally verify truth and accuracy, I certify as the company official having supervisory responsibility for the persons who, acting under my direct instructions, made the verification that this information is true accurate and complete.

    K N I C K E R B O C K E R : F o r questions please call TECHNICAL MANAGER our Customer Service Dept. Certificate # 97155 at (800) 843-3604 10/17/97

  • WASTEMANIFEST 12820, Albany, New York 12212

    1. Generator's US EPA [Manifest Dec No. 2. Page 1 of Information within heavy bold line WASTE MANIFEST * |A |8 |» )0 |2 [** |» | |0 |» |3 fcflffd ̂ ' 1 by rooo^ol Low, •,

    3.Generator's Name and Mailing Address

    NYG0798345 ATT3: A. C3LX 100 itCOQUMffi AVX 8. Generator's ID 413 494-J534 ?XTTSFiri», 81 01201 ST*

    . 5. Transporter 1 (Company Nan 6. US EPA ID Number C StotoTmmporter'slD

    D. Transporter's Telephone ( 7 Transporter 2 (Company Name) 8. US EPA10 Number E. Stoto Transporter's ID

    ) 9. Facility Nome and Site Address G. Start* Facility ID . - : • . _ • - - - - -« f n-. = sin?awv id* we,

    1069. 10. US EPA ID Numbw HOTEL CI7T XT, 14107 71* 7J4-S131

    US DOT DMcnptran (Induding Proper Shipping Nam«, Haiard Clou and ID Number) 12. ContaiMn 13. U. Unit NutniMf Q W»/Vol I. Waste No.

    0 0 1 p t EPA ti n STATE

    EPA

    STATE

    e. EPA

    STATE I EPA

    1 STATE

    K. Handling Codfjjg Wastes Utod AJ

    15.Oat of $«nrlc« Cat»j M. 0? DISPOSAL MOUISUtD Ordar ft 397050 E3E1CWCT OWTACT: a««CO-424

    C!€XCOTCf «ZST€9» «OXOK f 171 1 o. GENERATOR'S CERTIFICATION: I hereby declare mat the contents of this consignment ore Mly and accurately described above by proper snipping name and or* classified, pocked, marked and labeled, and are in a> respects in proper condition for transport by highway according to applicable international and notional government regulations and state lows and regulation*. • • ' If I am a targe quantity generator, I certify that I have a program in plan to reduce the volume and toxicity of to the degree I have determined to be economicaly practicable and that I have selected the practicable method of treatment, storage, or dUposol currently available to me which mini the present and future threat to human health and the environment; OR if I am a smaU generator, I have mode a good faith effort to minimise my waste and select I thebestwe»toriicOToaememmetr^tr^iscr«oilobletomeondmotlconomxd. • •-- . - --•- . - .. >. .

    Signature Mo. Day 1

    17. Nam» ^ \ Signature/ Mo. . Day Year i :

    ! Ui \.L£OJ^ i mi » it; 19 17^̂ •s»̂ Mê B»jê BB ŝs»B ŝssssssss»»Biss»ss»isss»»B ŝ»BBjs«s»M

    18. Tri I of Receipt of Materials i Prmted/lyped Nome Signature Mo. Day Year •v.;-;v . Vb

    I I I I I I 19. Dis

    20. Facility Owner or Operator: Certification of receipt of haiordous materials covered by this manifest encept as noted in Item 19. Printed/Typed Name Signature Mo. Day s

    8 e

    COPY 5- Generator - Mailed by TSD Facility

  • \

    Waste Management, Inc.

    CWM Chemicel Services. Inc. Phone 718/754-8231 1550 Balmer Rd. P.O. Box 200 Model City. N. Y. 14107

    Federal EPA ID: NYD049836679

    GE COMPANY ATTN: AIMEE COLE HAD002084093 100 WOODLAWN AVE PITTSFIELD MA 01201-4327

    CERTIFICATE OF DISPOSAL

    CWM Chemical Services, Inc. has received waste material from GE COMPANY on 10/16/97 as described on Hazardous Waste Manifest number NYG0798345 Sequence number 01. CWM Chemical Services, Inc., hereby certifies that the above described material was landfilled in accordance with the 40 CFR part 761 as it pertains to the land disposal of polychlorinated biphenyl contaminated materials. Profile Number: CG5136 CWM Tracking ID: 8147609901

    CWM Unit #: 1*0 Disposal Date: 10/16/97

    Under civil and criminal penalties of law for the making or submission of false or fraudulent statements or representations (18 U.S.C 1001 and 15 U.S.C. 2615) I certify that the information contained in or accompanying this document is true accurate and complete. As to the identified section (s) of this document for which I cannot personally verify truth and accuracy, I certify as the company official having supervisory responsibility for the persons who, acting under my direct instructions, made the verification that this information is true accurate and complete.

    ' K N I C K E R B O C K E R ; F o r questions please call TECHNICAL MANAGER our Customer Service Dept. Certificate # 97144 at (800) 843-3604 10/17/97 _,'

  • NKG 0798273 HAZARDOUS WASTE MANIFEST •. •>:...'-• -".•c-o •* . '«•; _• 'j ••-:r-j.- ' P.O. Box 12820, Albany, N«w York 12212

    ; .X . - • - s .'i.:'••..• w •'.•us-*.-••-r-Please type or print. Do not staple. '"(UeV.3/97)

    UNIFORM HAZARDOUS 1. Generator's US EPA No. ntifost 2. Page 1 of Information within heavy bold line WASTE MANIFEST « net requited by Federal Low. , -

    3.Generator's Name and I

    "•»NYG 0798273.:•,-ATTeU A* CBLZ 8. GeneratorUrlO su/niK- C 4. Generator's TeWxn. Number f*» j9»-233* rTTTtfULP, iU w_"i «*>ins.T -jitter. . -l :rcv--.b 5. Tronsporter t (Compam 6. USEPAIDNumbor

    D. Tremporter'»Jelephonrt7 7 Tromportor ? {Company Nome) 4-. ,u , USEPAIONumber E. State Tromporter's ID

    f., Tromporter'* Telephone < 9. Oeiignoted FocOHy Nome and Site Addrew G. Stule ruuTityTO

    • UOB li eaoinreit ' f Mr? HJR5' rsc,'" ' CITT 8T. 14107

    11. US DOT Description {Induing Proper Shipping Nome, Hazard Clan and 10 Number) A 9;.lC'c'i I. VttnteNo.

    SIATE fl U Q /

    i i Additional Destripri K. Handling Cod* ?CB SOIL - CCS13*

    15. Special Handling Inrtnicticn* and Additional Information

    Cat 8T BXSPOSAt. fork teder

    this consignment are fully and accurately described above by proper shipping name and am dossmed, pocked, marked and labeled, and are in oH respeds in praper condition for hoftsport by higrr̂ oaen^ notional government regutations and stole laws and regulations. - '•* •" -''••> • ' • ' - - < - ^ »I am a large quantity generator, I certify mat I have a program in place to reduce the vafcnw aiid tc«icity of wa^ generated to to to be eeo«>mico'VProclicobtojo nt9 ond fhot t con ofloni. •• j l yyr«=i* s»»3~^c i•»••*.^ -;"''* •.—*:•*-or ".„•"• -'j.-.. "gv. •«"-"•

    20. facility Owner or Operator 6nlitotion of receipt of HoaaidoM rnateriab covered* by tret manifest except as noted in Hem 19. ^ «nro;.r : •Year

    COPY 5- Generator - Mailed by TSD Facility

  • Waste Management, Inc.

    CWM Clwnical Strvicw. Inc. Phon« 710/754-8231 1650 B«lm»r fld. P.O. Box 200 Model City. N. Y. 14107

    Federal EPA ID: NYD049836679

    GE COMPANY ATTN: AIMEE COLE MAD002084093 100 WOODLAWN AVE PITTSFIELD MA 01201-4327

    CERTIFICATE OF DISPOSAL

    CWM Chemical Services, Inc. has received waste material from GE COMPANY on 10/15/97 as described on Hazardous Waste Manifest number NYG0798273 Sequence number 01. CWM Chemical Services, Inc., hereby certifies that the above described material was landfilled in accordance with the 40 CFR part 761 as it pertains to the land disposal of polychlorinated biphenyl contaminated materials. Profile Number: CG5136 CWM Tracking ID: 8147597401

    CWM Unit #: 1*0 Disposal Date: 10/16/97

    Under civil and criminal penalties of law for the making or submission of f alse.or fraudulent statements or representations (18 U.S.C 1001 and 15 U.S.C. 2615) I certify that the information contained in or accompanying this document is true accurate and complete. As to the identified section(s) of this document for which I cannot personally verify truth and accuracy, I certify as the company official having supervisory responsibility for the persons who, acting under my direct instructions, made the verification that this information is true accurate and complete.

    KNICKERBOCKER For questions please call TECHNICAL MANAGER our Customer Service Dept. Certificate # 96937 at (800) 843-3604 10/16/97

  • N Y G 0 7 9 8 3 0 9 HAZARD3O5 WKsTEMANIFEST P.O. Box 12820, Albany, New York 12212

    Please type or print. Do not staple. (IUv.3/97)

    UNIFORM HAZARDOUS 1. GwMrator'i US EPA No. Information within heavy bold (in* WASTE MANIFEST it not required by Federal Law.

    Ami: A. COLE 100PirnrtttBi

    in 5. TransperMr 1 ( I

    7 Transporter 2 (Company Nom) j- .

    11. US DOT DMcription (Induding Proper Shipping Name. Hazard Clou and 10 Number)

    I1

    IS. Special Handling Instructions and Additional mformati. Out oi Service D»t** /Q-f~

    NYG0798309

    C State Transporter's 10 fy 0. Transporter's E. State Transporter's IO

    G/ State Facifity IO «boc njjib svteuw? » e-.s «

    H. FodlityT*pnon.<

    12. Containers Number lypo

    Of BISTOUL Berk Order I* 397047 - oretcocr COHTACT* i-«w-434-̂ »a ^ • com ii?r

    16. GINEKATOrS CEITIFICATION; I h»i»oy d^om that th» contonti of KM comignm ît or» My and uaucot»ly dMcrib»d obovo by prop^ shipping nan* and am da**ifi«d, padnd, moriMd and lob»Ud, and am in all recfwdt in propw condition for tromport by highway according to opplkobU intwnationol and

    and ttato law* and ngutatiom. If I am a faro* quantity gorwrator, I cartify that I haw a program in plan to roducatho voium* and toncHy of watta OMwratad to In* dtgroa I howl datarminod to bo economically pnxneabfe and that I havo nUcUd mt procticobU method of treatment, storage, or daoosal currently availoble to me which minimaai the present and future throat to human health and the emwiriteiil, OR if I am o smoB generator, I havo mode a good faith effort to minimize my waste and select the best waste management method that is oveitofcJe to me and that I con afford.

    II b H H/ I5J7 Ma. Day ' Y«or

    fir. sec:.' «•: i" " .̂"^ --'-. -n: T f II 19. Dbcr̂ »r

  • '•'I

    ® Waste Management, Inc. CWM Chtmical S«rvict§. Inc. Phont 716/754-8231 1550 B«lm«r Rd. P.O. Box 200 Modal City. N. Y. 14107

    Federal EPA ID: NYD049836679

    GE COMPANY ATTN: AIMEE COLE MAD002084093 100 WOODLAWN AVE PITTSFIELD MA 01201-4327

    CERTIFICATE OF DISPOSAL

    CWM Chemical Services, Inc. has received waste material from GE COMPANY on 10/15/97 as described on Hazardous Waste Manifest number NYG0798309 Sequence number 01. CWM Chemical Services, Inc., hereby certifies that the above described material was landfilled in accordance with the 40 CFR part 761 as it pertains to the land disposal of polychlorinated biphenyl contaminated materials. Profile Number: CG5136 CWM Tracking ID: 8147597501

    CWM Unit #: 1*0 Disposal Date: 10/16/97

    Under civil and criminal penalties of law for the making or submission of false or fraudulent statements or representations (18 U.S.C 1001 and 15 U.S.C. 2615) I certify that the information contained in or accompanying this document is true accurate and complete. As to the identified section (s) of this document for which I cannot personally verify truth and accuracy, I certify as the company official having supervisory responsibility for the persons who, acting under my direct instructions, made the verification that this information is true accurate and complete.

    J I L Z T K N I C K E R B O C K E R ' • For questions please call TECHNICAL MANAGER our Customer Service Dept. Certificate # 96938 at (800) 843-3604 10/16/97

  • HYG 0798282 HAZARDOUS WWSTtfMANIFEST P.O. Box 12820, Albany, New York 1221 2

    • - . • i a, : TIOV . '-COO'Sl̂ l . r̂ ,».. _Please typo or print. Do net staple. -

    : 3/97)

    UNIFORM HAZARDOUS 1. Generator's US EPA No. Monirest Doe. No. 2. Pogo 1 of IHfO^H^OrH nthin neovy bold l>ie WASTE MANIFEST is not required by Federal Low.

    S.Generotor's Nome and Mailing Address

    trnu A. COL: ". *"!„••*

    c& 169 WOTUWi NYG0798282

    8. Generator's ID CM 4. S. Transporter 1 (Company Name) o. US E>A 10 NomlMT C. Stat* TramporMr's 10

    f » , 0. TransporMr's

    i 7 TranspOf1*r2 (Company NonW) _ :,. , -. 18. US EPAIO Nombw v-cts? vr •: .

    I I f -1 4E. Stat* TranspOfMr's IO

    Tronsportor's T«Uphon» ( 9. Addreu G. Stoto Facility ID

    ?!fc: ont .TT ,v ~io ;. .: ••• 6 3"t TSl:'. :;'• I" 155» M19Q «C». 10. US EPA ID Number

    CITT ST». HI Tl D " ' ~ '

    O

    11. US DOT Description (Including Proper Shipping Name, Haxord Class and ID Number)

    «« ? W2315. 11T

    12. Comainwi I

    0,0,1

    13. Total U. Unit Wt/Vol

    EPA

    STATEft

    v;

    EPA

    sure EPA

    STATE

    1 EPA

    STATE

    !'!_.*: i 15. S, l Hondfing Instructions and Additional InkMiinHiuu. of Service 2*t»r ~ff-297' or aisrosAL fO

    Berk Ord*r it 397«*7 - COITACIt 1* MET.

    16. GENEIATOrS CEITIHCATION: I lioraby dKlara mat Itw canlMits of this consignment or* fully and accurately described above by proper shipping name and are dassmed. packed, marked and labeled, and are in OH respects in proper condition for transport by highway according to applicable international and

    PVQtNQtlOM Oftfl SfQVel lOWft QftG WQUlOtlOflA*

    If I am o large quantity generator, I certify that I have a program in place to reduce .me volume and tenacity of waste generated to the degree I have determined to be economical practicable and that I have selected the pnxticobU method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment, OR if I am a small geiteiotor, I have made a good faith effort to minimise my waste and select

    i the best waste management method that is available to me and that I can afford. •--• "v.i • • • - • ' 1

    1 5 •-•jr. , ::'izafr,:si* 4-1 13WB. M- •'•'- ...-"-C" • .r.i •;;..--" • - ! • • i -I ;,| -»j" -i

    19. Di P-.-I -"»n--v--c - •.'.-• '"' •'..»! •' •:•.'.-,'•': "̂ TS'̂ '̂ CB r«'i.";"'-i 'r'.y. "'"t"

    20. Focilily Owner or Operator. Certification of receipt of r PrinteaVlyped Name

    olerials covered by rim manifest except as noted in Item 19. Signature Mo. Day ' '" Year

    '' .••J'f^3r«);-.

    7 COPY 5 Generator Mailed by TSD Facility

  • -.f Waste Management, Inc.

    CWM Chtmical S«rvic«s. Inc. Phone 710/754-8231 1550 8»lm»r Hd. P.O. Box 200 Mod* City. N. Y. 14107

    Federal EPA ID: NYD049836679

    GE COMPANY ATTN: AIMEE COLE HAD002084093 100 WOODLAWN AVE PITTSFIELD MA 01201-4327

    CERTIFICATE OF DISPOSAL

    CWM Chemical Services, Inc. has received waste material from GE COMPANY on 10/15/97 as described on Hazardous Waste Manifest number NYG0798282 Sequence number 01. CWM Chemical Services, Inc., hereby certifies that the above described material was landfilled in accordance with the 40 CFR part 761 as it pertains to the land disposal of polychlorinated biphenyl contaminated materials. v Profile Number: CG5136 CWM Tracking ID: 8147603101

    CWM Unit #: 1*0 Disposal Date: 10/16/97

    Under civil and criminal penalties of law for the making or submission of false or fraudulent statements or representations (18 U.S.C 1001 and 15 U.S.C. 2615) I certify that the information contained in or accompanying this document is true accurate and complete. As to the identified section(s) of this document for which I cannot personally verify truth and accuracy, I certify as the company official having supervisory responsibility for the persons who, acting under my direct instructions, made the verification that this information is true accurate and complete.

    For questions please call TECHNICAL MANAGER our Customer Service Dept. Certificate # 96985 at (800) 843-3604 10/16/97

  • I

    NYG 0798291 HAZARDOUS WASTE MANIFEST _, .„.„„ ... P.O. Box 12820, Albany, New York 12212 ^.,.S6(£,^ „,

    Please type or print. Do not staple. 3/97)

    UNIFORM HAZARDOUS 1. Generator's US EPA No. MonifMt Doc No. WASTE MANIFEST

    3.Generator's Name and Mailing Address

    ATT*: 4. C6LI

    5. Transporter 1 (Company Norn*)

    7 Transporter 2 (Company Name)

    9. Designated Facility Nome and She Address am CUBICAL utvicu. inc. 1 1OAB. ^

    10ML CtTt IT,. .14107

    •«» COW MT 100 VOODUtfB ATf - 253*

    i. US EPA ID Number

    EPA ID

    I I I I I I

    10. US EPA ID Nmbe O I O 4 I 9 I S I 3

    11. US DOT Dweriplion (Including Prop* Shipping Name, Hazard dan and ID Number)

    iI 1'••>s e ^*2*"O£~c2zz

    COPY 5- Generator - Mailed by TSO Facility

  • .

    Waste Management, Inc.

    CWM Chemical Services. Inc. Phone 716/754-8231 1550 Brtmtr Rd. P.O. Box 200 Model City. N. Y. 14107

    Federal EPA ID: NYD049836679

    GE COMPANY ATTN: AIMEE COLE MAD002084093 100 WOODLAWN AVE PITTSFIELD MA 01201-4327

    CERTIFICATE OF DISPOSAL

    CWM Chemical Services, Inc. has received waste material from GE COMPANY on 10/15/97 as described on Hazardous Waste Manifest number NYG0798291 Sequence number 01. CWM Chemical Services, Inc., hereby certifies that the above described material was landfilled in accordance with the 40 CFR part 761 as it pertains to the land disposal of polychlorinated biphenyl contaminated materials. Profile Number: CG5136 CWM Tracking ID: 8147602501

    CWM Unit #: 1*0 Disposal Date: 10/16/97

    Under civil and criminal penalties of law for the making or submission of false or fraudulent statements or representations (18 U.S.C 1001 and 15 U.S.C 2615) I certify that the information contained in or accompanying this document is true accurate and complete. As to the identified section(s) of this document for which I cannot personally verify truth and accuracy, I

    certify as the company official having supervisory responsibility for the persons who, acting under my direct instructions, made the verification that this information is true accurate and complete.

    I I C K E R B O C K E R ' F o r questions please call TECHNICAL MANAGER our Customer Service Dept. Certificate # 96979 at (800) 843-3604 10/16/97

  • N K G 0 7 9 8 1 8 3 P.O. Box 12820, Albany, New York 12212

    Please type or print. Do not staple. •• ••>"• '-• i|Rev.3/97)

    UNIFORM HAZARDOUS 1. Generator's US EPA No. iManifest Doc No. 2. Pogol of Infermalion within heavy bold HIM WASTE MANIFEST k> • ~ ~ it not required by Federal law. . . T;

    r's Nome ond Mailing Address •'*" " '"" •" "' " '•"'" CJ 0798183

    AT73J A, COSX . ,, 106 VOCDUV* AVf B. Generator's ID ijT-:iw - •" . ;_ . • i 4. G———'sTe^Nurn,.,,*" I**"2534 UTISFinfl. HA 012CI (•u^iun i8»:rc.-n-r5r- eVU if* s. 6. US EPA 10 Number C Stata Transporter's ̂ flf^f, f j g%

    Transporter's Telepnone"Jfr̂ 7 Transporter 2 (Company Name) .18. US EPA ID Number E. State Transporter's ID • - »--„••

    • J. ,.n 9. Oewo^aled FadMy Nome and Site Address G. Stale Facility ID •*" -•'< - "nfci OB CREfiaiL snrrcts nc. fii ri;!.vr:oB:.ii H s.-. r tiA ;3TOM

    .1530 £AL*!t2 1049. '" '"*" 10. US EPA 10 Number H. Facility Telephone ( J CXTt HI, 1410?

    11. US DOT Description (Including Proper Shipping Nome. Hazard Class and 10 Number) 12- Containers 14. Unit WlA'ol

    BXTSZCTLS EPA ru. OiOil Dit STATE 9 S 7

    EPA

    STATE 1 I EPA

    STATE I 1 EPA

    STATE l - i J. Addnionoi DoicnptiOfH ior AAotonon listod Aoow Wastes Listed Above ?CB son, - an 134 , , ,^___________i » i i rt ;a 15. Special Handling Instructions and Additional < U fCS, MsaacMuMCUi * tt*O2 ;.~

  • .

    Waste Management, Inc.

    CWM Chtminl Services. Inc. Phone 710/754-8231 1550 Belmer R

  • . 3/971

    01981-92

    . T W f c _, =53^̂ *.;;̂ ..,

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  • Waste Management, Inc.

    CWM Chemical Services, Inc. Phone 710/754-8231 ISSOBelmer Rd. P.O. Box 200 Model City, N. Y. 14107

    Federal EPA ID: NYD049836679

    GE COMPANY ATTN: AIMEE COLE MAD002084093 100 WOODLAWN AVE PITTSFIELD MA 01201-4327

    CERTIFICATE OF DISPOSAL

    CWM Chemical Services, Inc. has received waste material from GE COMPANY on 10/10/97 as described on Hazardous Waste Manifest number NYG0798192 Sequence number 01. CWM Chemical Services, Inc., hereby certifies that the above described material was landfilled in accordance with the 40 CFR part 761 as it pertains to the land disposal of polychlorinated biphenyl contaminated materials. Profile Number: CG5136 CWM Tracking ID: 8147574501

    CWM Unit #: 1*0 Disposal Date: 10/10/97

    Under civil and criminal penalties of law for the making or submission of false or fraudulent statements or representations (18 U.S.C 1001 and 15 U.S.C. 2615) I certify that the information contained in or accompanying this document is true accurate and complete. As to the identified section(s) of this document for which I cannot personally verify truth and accuracy, I certify as the company official having supervisory responsibility for the persons who, acting under my direct instructions, made the verification that this information is true accurate and complete.

    JILKJKNICKERBOCKER For questions please call TECHNICAL MANAGER our Customer Service Dept. Certificate # 96615 at (800) 843-3604 10/13/97

  • NYG0798201 HAZARDOUS WASTE MANIFEST P.O. Box 12820, Albany New York 12212 ue»* ••:.

    Please type or print. Do not staple. -.i.~r. >J err-" "'"S* "(Hev. 3/97)

    UNIFORM HAZARDOUS 1. Generator's US EPA No. Manifest Doc. No. 2. Pogel of Infonnuliuo within heavy bold Ik WASTE MANIFEST is not required by Federal Low.

    3.Generator's Nome and Moiling Address

    NYG07982014TT*( A. COW 100 wtJGSLAtHI ATI B., Generator's IO

    413 494-2334 PCTTSmLD, W 01201 5. Transporter 1 (Company Norn*) 6. US EPA ID Number C State

    a transporter's Telephone 7 Transporter 2 (Company NORM) 8. US EPA10 Numbw E. StaM Tremportor's 10

    F. Tfompon f̂'» T»l«phon̂ ( 9. OwignaMdFaciUly Norn* and Site Addrau 0. StataFoeilnylO

    MtTICIS 1BC, .V3 pr. . ...... . - v-"-: i ,B41BE1 10. USEPAIDNumter H. FoeilHy T»Upooo« (seen, cm «, u»?

    11. USDOT OMoiplion (Induaing Propw Shipping Nom«, Haiard Oau and ID Numbor) 12. Containon

    0 99il

    I 1

    X Additional D* I forMatariab litlod Abo¥* ?C» SOB.- CC3136

    o „.:,^ : -.,s«in-*j, 2! A=3 2'J UA

    U. Unit Wt/Vbl I. Wo*»« No.

    EPA

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    STATE

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    STATE

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    STATE

    «-• -•» --•--I t D 15. i and Additional Mormatic ot

    r > ••* " .'ft 3§7044 fin ^ 16. GENERATOrSCCITIIilCATIONtlhw^dodaramatthoeontwilsofmiseoniignmwitaralu^ id above by proper shipping name

    irked and labeled, and are in all respects in proper condition for transport by highway according to applicable international and t >oyulalimn and state wtM and reQuhitiom. ^ . . _

    If I am a largo ajuanMy generator, I certify that I have a piogium in place to reduce the volume and toxkity of waste generated to the degreeThave determined to be ecanomicaiy practicable and that I have selected the practicable method of treatment, storage, or disposal currently available to me which minimises the present and future threat to human health and the environment; Oft if I am a smal generator, I have mode a good faith effort to minimite mywaste and select

    I oement method that is avoileble to me and mot I can afford. »j* .---•' ';--~J - " ; ~ - V -' ---0^0 -i.^ cr • - .-!> - ~*-rxn :i-i. .-~r Printed/Typed Name1

    of Receipt of Materials

    IB. Transporter 2 Acknowledgement of Receipt of Materiab Printed/Typed Name

    Indication Space - ~r~~

    20. Focaity Owner or Operator. (•/this manifest except as noted in Hem 19•8 S 8

    JjrfT^^yVV£

    COPY 5- Generator - Mailed by TSD Facility

  • Waste Management, Inc.

    CWM Chtmicil S«rvic«S. Inc. Phon« 716/754-8231 1550 BtlmerRd. P.O. Box 200 Mod«l City. N.Y. 14107

    Federal EPA ID: NYD049836679

    GE COMPANY ATTN: AIMEE COLE MAD002084093 100 WOODLAWN AVE PITTSFIELD MA 01201-4327

    CERTIFICATE OF DISPOSAL

    CWM Chemical Services, Inc. has received waste material from GE COMPANY on 10/10/97 as described on Hazardous Waste Manifest number NYG0798201 Sequence number 01. CWM Chemical Services, Inc., hereby certifies that the above described material was landfilled in accordance with the 40 CFR part 761 as it pertains to the land disposal of polychlorinated biphenyl contaminated materials. Profile Number: CG5136 CWM Tracking ID: 8147575901

    CWM Unit #: 1*0 Disposal Date: 10/10/97

    Under civil and criminal penalties of law for the making or submission of false or fraudulent statements or representations (18 U.S.C 1001 and 15 U.S.C. 2615) I certify that the information contained in or accompanying this document is true accurate and complete. As to the identified section(s) of this document for which I cannot personally verify truth and accuracy, I certify as the company official having supervisory responsibility for the persons who, acting under my direct instructions, made the verification that this information is true accurate and complete.

    KN1C For questions please call TECHNICAL MANAGER our Customer Service Dept. Certificate / 96625 at (800) 843-3604 10/13/97

  • NYG 0738165 HAZARDOUS WASTE MANIFEST RO. Box 12820, Albany, New York 12212

    Please type or print. Do not stool*." r. 3/97) UNIFORM HAZARDOUS 1. Generator'1 US EPA No. 2. Pagol of Information within heavy bold lino

    WASTE MANIFEST a not required by Federal Law. :r 3.Generator's Name and Mailing Address

    ATOM NYG0798165 B. Generator's ID

    4. f**-*"* rmmnat IT. 5. Transporter 1 (Company Nome) 6. US EPA ID Number C. SloieTramportor'siqVy fc-y

    D. Transporter's Telephone 7 Transporter 2 (Company Name) US EPAID Number E. State Tronsponer's ID

    F. Transporter's Telephone { tone ond She Address G. Slate Facility IO OB anwiCAt tn?ic£3 we. ^ w: .-rr.v -o oni.

    10. US EPA 10 Number H. Facility Telephone (seen, cirr si, J*ia? Ud uui LJvscnpnon (inctuoing rropvr trapping i e, nozard Class and ID Number) 12. Containers 14. Unit

    Number Type WI/VW I. Waste No. . pta.T&tottaAtEfl iXMBTCLS EPA f, BH2315, tii ;k „ :; ; STATE 1 C 3 7 ' EPA

    STATE £ ii EPA

    STATE I EPA 1 STATE

    § Additional Descriptions for Materiob listed Above Wastes Listed Above

    ?C8 SOIL * 03136 , , ——————————————————————I * ]_

    IS. Special Handing Instruct Additional Info t> 4AU4 Oat ef S«rrlc« or »tsi*ostt> IEQSUED tfork Order fs CO«TAC?r l-400-42*-t3CO

    wtr. Mr tBmnnteT USTOISE CTIW Im J6. GfNEIATOrsa«TinCAnON: I hereby declare that me content, of Ms coî ,iment o» My and accurately dejcrfred above ^ and are dassined. packed, marked and labeled, and are in ad respects in p dHion far transport by highway according to applicable international ond notional government regulations ond state lows ond reautotions. rf I am a large quantity generator, I certify mat I have a'program in ploxetoreduceJhe vcJimie and toiocity of waste generated to^ to be eeonamiceiy practicable and that I have selected the practicable method of treatment; storage, or disposal currently ovaBah present and future threat to human Heanh and the environment; OR if I am a small generator, I r«>ve mode a good faith effort to the bert waste management method that is available to me ond mot I eon afford. •••: -. x -.- ••- , : . :-,.-..;,....-v. .̂ ......:.fc ,.

    1 Printed/Typed Name Mo. -i- Day 17. Transporter 1 Ada of Receipt of Materials

    I

    18. of Receipt of Materials

    Signature

    II Mo. .. .Day

    - ..Year

    Printed/Typed Name sv.iari' v:'-;-ij.i -.*3»- -"in ''3ri.•_,.••

    Signature•tiy: :•• " I Mo. i r Day\ r Year i

    19. Ducfepancy mdnatran Span.

    1 20. Facility Owner or Operator. Certification of receipt of hazard red by this except as noted in Item 19. o::»i^- j:. .j.:-K..,.t»cA

    COPY 5- Generator - Mailed by TSD Facility

    7

  • Waste Management, Inc.

    CWM Chemical Services. Inc. Phone 710/754-8231 1550 Balmer Ad. P.O. Box 200 Model City, N. Y. 14107

    Federal EPA ID: NYD049836679

    GE COMPANY ATTN: AIMEE COLE MAD002084093 100 WOODLAWN AVE PITTSFIELD MA 01201-4327

    CERTIFICATE OF DISPOSAL

    CWM Chemical Services, Inc. has received waste material from GE COMPANY on 10/10/97 as described on Hazardous Waste Manifest number NYG0798165 Sequence number 01. CWM Chemical Services, Inc., hereby certifies that the above described material was landfilled in accordance with the 40 CFR part 761 as it pertains to the land disposal of polychlorinated biphenyl contaminated materials. Profile Number: CG5136 CWM Tracking ID: 8147570201

    CWM Unit #: 1*0 Disposal Date: 10/10/97

    Under civil and criminal penalties of law for the making or submission of false or fraudulent statements or representations (18 U.S.C 1001 and 15 U.S.C. 2615) I certify that the information contained in or accompanying this document is true accurate and complete. As to the identified section(s) of this document for which I cannot personally verify truth and accuracy, I certify as the company official having supervisory responsibility for the .persons who, acting under my direct instructions, made the verification that this information is true accurate and complete.

    Jiiat KNICKERBOCKER "" For questi