letter regarding summary of unscheduled inspection

Transmitted Via Overnight Courier

September 23,2011

Mr. Richard Fisher (Mail Code OSRR07-1) u.S. Environmental Protection Agency 5 Post Office Square - Suite 100 Boston, Massachusetts 02114-2023

Re: GE-PittsfieldlHousatonic River Site

GE 159 Plastics Avenue Pittsfield, MA 01201 USA

Building 71 and Hill 78 On-Plant Consolidation Areas (GECD210 & GECD220) Summary of Unscheduled Inspection Activities in Late August and Early September 2011

Dear Mr. Fisher:

This letter describes and presents the results of several inspection activities that were conducted on behalf of the General Electric Company (GE) at the Building 71 and Hill 78 On-Plant Consolidation Areas (OPCAs) in late August and early September 2011 apart from the regularly scheduled semi-annual inspections. These activities were conducted in accordance with the requirements set forth in GE's Revised Post-Removal Site Control Plan for Hill 78 and Building 71 On-Plant Consolidation Areas (Revised PRSC Plan), which was submitted to the U.S. Environmental Protection Agency (EPA) on January 6, 2011, conditionally approved by EPA on June 2, 2011, and then revised and re-submitted in final form as Attachment H to GE's Final Completion Report - On-Plant Consolidation Areas on September 15, 2011. That plan requires that, in addition to the regularly scheduled semi-annual inspections, the OPCAs must be inspected following severe storm events to ensure that they have not sustained significant damage. For this purpose, a severe storm event includes a storm event in which a IS-minute instantaneous peak of3,500 cubic feet per second (cfs) or greater is measured on the Housatonic River at the United States Geological Survey (USGS) gaging station at Coltsville, Massachusetts. In addition, for purposes of these OPCA inspections, a severe storm event also includes an earthquake or tornado, sustained winds in excess of 50 mph, or a rain event with total precipitation exceeding 3 inches over a 24-hour period.

The inspection activities covered by this letter and actions taken or proposed in response to those activities are described below. OPCA components subject to inspection are shown on Figure 1, the tree planning plan for the OPCAs is shown on Figure 2, and maintenance/repair items identified during these activities are shown on Figure 3. Pertinent inspection checklist forms are provided in Attachment A, and photographs taken during these inspection and repair activities are provided in Attachment B.

1. August 22, 2011 Observations

On August 22, 2011, following an intense rain event on the previous evening, GE and EPA conducted observations at the Hill 78 OPCA. Since this rain event did not meet the above-referenced criteria for a severe storm, it was not necessary to perform a formal inspection of the OPCAs. However, during these observations, GE and EPA identified an area of erosion of the soil cover on a portion of the Hill 78 OPCA, potentially caused by water flowing through woodchuck burrows (which were also observed). In addition, sand resulting from that erosion was observed in the bottom of a portion of the perimeter drainage ditch. The area of erosion, woodchuck burrow holes, and portion of the perimeter drainage ditch observed with sand are

Corporate Environmental Programs

Mr. Richard Fisher September 23,2011

of5

shown on Figure 3. On August 25, 2011, GE repaired the eroded area, including the woodchuck burrow holes. Photographs of the conditions observed on August 22 and the repairs of the eroded area and woodchuck burrow holes observed are provided as Photos #1 through #7 in Attachment B.

2. August 26, 2011 Post-Earthquake Inspection

On August 26,2011, due to an earthquake that occurred on August 23,2011, GE conducted an inspection of both of the OPCAs. This inspection included visual observations of the Building 71 and Hill 78 OPCAs to identify any damage to the fmal cover and associated components as a result of the earthquake and to identify any items needing maintenance. The OPCA final cover areas were visually inspected to determine the presence of any of the following conditions:

• Areas void of vegetation or exposed geosynthetic fmal cover components;

• Evidence of topsoil or other erosion;

• Evidence of sparse or stressed vegetation;

• Evidence of tree or shrub growth or other undesirable vegetative growth;

• Evidence of burrowing animals;

• Evidence of damage to the geosynthetic final cover components;

• Evidence of uneven surface settlement;

• Evidence of ponding water conditions;

• Evidence of excessive wheel rutting;

• Undesirable slope conditions (i.e., non-conducive to proper drainage);

• Adequacy of cover system drainage layer outlet pipes (8 locations);

• Evidence of soil movement or slope instability; and

• Evidence of unauthorized excavations.

In addition to inspecting the fmal cover for the conditions listed above, the August 26, 2011 inspection included observations of the following associated components (including the specific items listed for each of these components in the attached inspection form for this inspection 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 fmal cover access roads;

• Perimeter fencing and access gates;

• Surface water drainage system, including the North and South Stormwater Basins and the other drainage features listed in the attached inspection form and shown on Figure 1;

• The leachate handling system;

• Perimeter vegetation, including tree plantings; and

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

Mr. Richard Fisher September 23, 2011

of5

The August 26, 2011 inspection also included an inspection of trees planted in the Perimeter Vegetated Area (shown on Figure 1) and other areas around the OPCAs, including the trees planted in April 2010 as part of the Tree Planting Plan (as shown on Figure 2), to assess their survival, growth, and condition, and whether they are providing a visual barrier between the OPCAs and the surrounding community.l In addition, the herbaceous vegetation planted in the Perimeter Vegetated Area was inspected for: (a) evidence of topsoil erosion or excessive soil erosion; (b) establishment and coverage of vegetation (e.g., bare or sparsely vegetated areas or stressed vegetation); and (c) any drainage or growth problems.

The results of the August 26, 2011 inspection were recorded on the form in Attachment A that was completed for that inspection. In general, this inspection indicated that the final cover areas and other components of the OPCAs were in good overall condition. As shown in Section II and summarized in Section ill of the inspection form, a few items were noted for follow-up maintenance or monitoring. These ifems were: (a) the observation of two additional woodchuck burrow holes in the Hill 78 OPCA cover; (b) the continued observation of sand (including additional sand) in the bottom of a portion of the perimeter drainage ditch; and (c) the observation that the same 12 trees that had been identified as stressed in the prior regular inspection in May 2011 (as reported in GE's letter of June 22,2011 on that inspection) continue to be stressed. The approximate locations of these items are shown (by reference to the corresponding letter and number on the inspection form) on Figure 3. Photographs taken during this inspection are included as Photos #8 through #11 in Attachment B.

Following this inspection, the sand was removed from the perimeter drainage ditch on September 6 and the burrow holes were repaired on September 12, as noted in Section N of the inspection form for this inspection. The stressed trees will be monitored again during the regularly scheduled fall 2011 inspection (in late September 2011), and any necessary follow-up activities will be identified during that inspection and performed this fall.

3. September 12,2011 Post-Storm Inspection

An additional inspection of both OPCAs was conducted on September 12, 2011 due to a severe tropical storm that occurred in the area on August 28, 2011, causing flows on the Housatonic River to exceed a 15-minute peak flow of 3,500 cfs at the USGS gaging station at Coltsville. This inspection was performed to evaluate whether the storm event had caused any damage to the OPCAs.2 During this inspection, the OPCA fmal cover areas were visually inspected to determine the presence of any of the same conditions listed for the fmal cover areas in Section 2 above. In addition, visual observations were made of the paved site access roads, the OPCA final cover access roads, the surface water drainage system (including the North and South Stormwater Basins and the other drainage features listed in the inspection form and shown on Figure 1), and any other significant erosion.

I In accordance with Section 3.1.4 of the final Revised PRSC Plan, if any of the trees planted in April 2010 are observed to be dead or dying during the initial two-year inspection period, GE is required to plant replacement trees of the same or similar species and size as those originally planted. If any of the trees established prior to April 2010 are observed to be dead or dying during that period, GE is to evaluate whether such lost trees are adversely affecting the visual barrier between the OPCAs and the surrounding community, and make a proposal as to whether those trees need to be replaced to maintain the visual barrier.

2 Prior to this inspection, the vegetation at both OPCAs had been mowed, resulting in increased visibility of conditions at the OPCAs.

G:lGEIGB _ Pittsfielc,-CD 3)PCAs\ReportJ and Pn:sen1ations\lnspectionsIUnscbeduled\2471111324L1rRpt.ckx:

Mr. Richard Fisher September 23,2011

of5

The results of the September 12, 2011 inspection were recorded on the form in Attachment A that was completed for that inspection. This inspection again indicated that the final cover areas and other inspected components of the OPCAs were in good overall condition; but it identified a number of items for follow-up maintenance, as shown in Section II and summarized in Section ill of the inspection form for this inspection. These items were: (a) four additional woodchuck burrow holes, one on the Hill 78 OPCA and three on the Building 71 OPCA; (b) two bare spots (approximately 3 feet by 3 feet each) in the Hill 78 OPCA cover; (c) two limited areas of soil erosion/movement and uneven settlement of the soil cover, one on the Hill 78 OPCA and one on the border between the OPCAs; (d) additional sand in the bottom of portions of the perimeter drainage ditch as a result of the soil erosion; and (e) minor damage to a culvert pipe beneath the Building 71 OPCA access road, apparently caused by mowing equipment.3 The approximate locations of these items are also shown (by reference to the corresponding letter and number on the inspection form) on Figure 3. Photographs taken during this inspection are included as Photos #12 through #15 in Attachment B.

As noted in Section N of the applicable inspection checklist form in Attachment A, the four woodchuck burrow holes observed during this inspection were filled, seeded, and mulched on the same day as the inspection. To address the remaining conditions observed during this inspection, GE proposes to perform the following corrective measures: (a) re-seed and mulch the two bare spots in the Hill 78 OPCA cover; (b) repair the two limited areas of erosion/uneven settlement of the soil cover through soil replacement and reseeding; (c) remove the sand in the bottom of portions of the perimeter drainage ditch; and (d) repair the damaged culvert pipe under the Building 71 OPCA access road. In accordance with Section 3.1.6 of the final Revised PRSC Plan, GE will perform these corrective measures after they are approved-or deemed approved by EPA. In the event that GE does not receive notice otherwise from EPA within 15 days after submission of this inspection report, these proposed measures will be deemed approved by EPA and will be conducted within 45 days from the submission of this report. In addition, GE will discuss with EPA additional measures to improve drainage at the OPCAs and, based on those discussions, will propose such measures to EPA shortly in a separate submission.

4. Schedule for Future Inspections

In accordance with the applicable requirements of the fmal Revised PRSC Plan, post-closure inspections of the Building 71 and Hill 78 OPCAs are to be performed twice per year to assess the integrity of the final cover and associated components. The next regularly scheduled post-closure inspection will be performed during the last week of September 2011. In addition, GE will continue to conduct OPCA inspections after severe storm events (as defined in the final Revised PRSC Plan). The inspections will continue until GE proposes, and EPA approves, a modification or termination of such inspections.

Future 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, a completed inspection checklist (using the form included in the fmal Revised PRSC Plan), and a proposal for any necessary repair or replacement activities. Those repair or replacement activities will be conducted within the time periods specified in Section 3.1.6 of the final Revised PRSC Plan.

3 Based on further review, the above description of the items identified in this inspection as requiring maintenance has been slightly revised from the initial description of the results of this inspection in Section 2.1 of the final Revised PRSC Plan submitted on September 15,2011.

Please call me if you have any comments or questions.

Sincerely,

'Prdl'\(A~ LtV. ~G\.it$ / It:CryC3J

Richard W. Gates Remediation Project Manager

Attachments

cc: Dean Tagliaferro, EPA John Kilborn, EPA Holly Inglis, EPA Rose Howell, EPA Robert Leitch, USACE Michael Gorski, MDEP* Eva Tor, MDEP* John Ziegler, MDEP (2 copies) Linda Palmieri, Weston (2 copies) Nancy E. Harper, MA AG*

Karen Pelto, MDEP

Mr. Richard Fisher September 23, 2011

of5

Corydon L. Thurston, Executive Director, PEDA Mayor James Ruberto, City of Pittsfield Michael Carroll, GE* Roderic McLaren, GE* James Nuss, ARCADIS James Bieke, Goodwin Procter Public Information Repositories GE Internal Repository

*cover letter only

Figures

OPCA COMPONENTS SUBJECT TOPOST-CLOSURE INSPECTION

CIT

Y:

SY

RA

CU

SE

DIV

/GR

OU

P:

EN

VC

AD

DB

:L

.F

OR

AK

ER

,E

.K

RA

HM

ER

,S

.B

ELL

PIC

:P

.K

EA

NE

YP

M:

W.

RA

NK

INT

M:

P.

BA

TT

EN

TR

:E

.B

RE

ME

RLY

R:O

N=

*;O

FF

=*R

EF

*G

:\G

E\E

NV

CA

D\S

YR

AC

US

E\A

CT

\C\B

00

30

90

8\0

000\0

0001\D

WG

\30908G

02.D

WG

LA

YO

UT

:1

SA

VE

D:

9/1

5/2

01

14:4

3P

MA

CA

DV

ER

:1

8.0

S(L

MS

TE

CH

)P

AG

ES

ET

UP

:--

--P

LO

TS

TY

LE

TA

BLE

:P

LT

FU

LL

.CT

BP

LO

TT

ED

:9

/15

/20

11

4:4

4P

MB

Y:

KR

AH

ME

R,

ER

IC

FIGURE

GENERAL ELECTRIC COMPANYPITTSFIELD, MASSACHUSETTS

HILL 78 AND BUILDING 71 OPCAs

1

D7

D7

D7

G5

D1

G5G5

8-26-11

9-12-11

9-12-11

8-26-119-12-11

9-12-11

D7

D4, D8, D13, H1

UNSCHEDULED INSPECTIONS - LATEAUGUST AND EARLY SEPTEMBER 2011

IMA

GE

S:

XR

EF

S:

30908X

01

CIT

Y: S

YR

AC

US

E N

Y D

IV/G

RO

UP

: E

NV

CA

D D

B: K

. S

AR

TO

RI, L

. F

OR

AK

ER

, E

. K

RA

HM

ER

P

IC: P

. K

EA

NE

Y P

M: W

. R

AN

KIN

T

M: P

. B

AT

TE

N T

R: G

. B

ISH

OP

LY

R: O

N=

*; O

FF

=*R

EF

*R

:\E

NV

CA

D\S

YR

AC

US

E\A

CT

\C\B

0030908\0

000\0

0001\D

WG

\30908G

03.d

wg

LA

YO

UT

: 3S

AV

ED

: 9/2

3/2

011 1

:27 P

MA

CA

DV

ER

: 18.0

S (

LM

S T

EC

H)

PA

GE

SE

TU

P:

----

PLO

TS

TY

LE

TA

BLE

: P

LT

FU

LL.C

TB

PLO

TT

ED

: 9/2

3/2

011 2

:27 P

MB

Y:

PO

SE

NA

UE

R, LIS

A

FIGURE

GENERAL ELECTRIC COMPANYPITTSFIELD, MASSACHUSETTS

HILL 78 AND BUILDING 71 OPCAs

3

Attachment A

Inspection Checklists

I. Inspection InformationInspection Date: 8/26/2011 (Friday) Weather Conditions: Partly Cloudy / 60-70oF

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

Performed by: Robert Papallo (ARCADIS) and Phone Number: (413) 281-0704 E-mail address: [email protected] Coyle (Veolia Water)

Observed by:

Time Arrived: Time Departed: 8/26/2011 14:00

Date of Prior Inspection: 5/24/2011 (Tuesday)

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 at all eight 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

8/26/2011 9:00

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

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 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?

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?

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?

Yes 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

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

Have the pumps on the wet well been tested?

G:\GE\GE_Pittsfield_CD_OPCAs\Reports and Presentations\Inspections\Unscheduled\2471111324AttaA_Insp Form-R_8-26-11.xls

Page 1 of 2


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.

D7. Animal burrow holes were noted at two locations at the Hill 78 OPCA.E1c. The Mid-slope swale was repaired (on August 25,2011) but sand remains at the bottom of the surrounding drainage ditch.G5. The same trees identified as stressed during the May 2011 inspection were observed as stressed during the August 26, 2011 inspection.

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

D7. The two animal burrow holes were filled, seeded, and mulched on September 12, 2011. Burrowing animals will continue to be removed from the OPCAs and the burrow holes filled with topsoil, seeded and mulched, as needed.

E1c. Sand was removed from the bottom of the drainage ditch on September 6, 2011.G5. Stressed trees will be further monitored during the September 2011 inspection. Follow-up activities will be addressed following that inspection.

NA

NAVI. Other Observations

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

Yes

Yes

NoAre 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)? No


Page 2 of 2

I. Inspection InformationInspection Date: 9/12/2011 (Monday) Weather Conditions: Partly Cloudy / 70-75oF

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

Performed by: Gregg Rabasco (ARCADIS) Phone Number: (413) 822-1844 E-mail address: [email protected]

Observed by: Mike Argue (Weston Solutions Inc.)

Time Arrived: Time Departed: 9/12/2011 16:00

Date of Prior Inspection:8/26/2011 (Friday)

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 Security NOT INSPECTED1. 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 Yes

9/12/2011 14:00


INSPECTION FORM

8. 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 at all eight 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 System NOT INSPECTED1. 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 riprap surrounding the stormwater manhole at the northwest corner of the Hill 78 OPCA?

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

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?

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?

Yes 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

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

Have the pumps on the wet well been tested?


Page 1 of 2


INSPECTION FORM

G. Perimeter Vegetation and Tree Plantings NOT INSPECTED1. 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.

D1. Two small bare spots (approximately 3 feet by 3 feet each) were observed in the Hill 78 OPCA cover.D4, D8, D13, H1. Two limited areas of soil erosion/movement and uneven settlement of the soil cover were observed (one on the Hill 78 OPCA and one on the border between the OPCAs).

D7. Four woodchuck burrow holes were observed (one on the Hill 78 OPCA and three on the Building 71 OPCA).E1c. Sand was observed in the bottom of a portion of the perimeter drainage ditch as a result of the above-referenced soil erosion.H2. Minor damage was observed to a culvert pipe beneath the Building 71 OPCA access road, apparently caused by mowing equipment.

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

D1. Upon EPA approval, the two small bare spots will be reseeded and mulched.D4, D8, D13, H1. Upon EPA approval, the two limited areas of soil erosion/movement and uneven settlement of the soil cover will be repaired by soil replacement and reseeding. In addition, after

discussions with EPA, GE will propose additional measures to improve drainage.D7. The four burrow holes were filled with topsoil, seeded and mulched on September 12, 2011. Burrowing animals will continue to be removed from the OPCAs and the burrow holes

filled with topsoil, seeded and mulched, as needed.E1c. Upon EPA approval, the sand will be removed from the bottom of the perimeter drainage ditch.H2. Upon EPA approval, the minor damage to the culvert pipe under the Building 71 access road will be repaired.

V. Prior Inspections

Yes

Yes

NoAre 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)? No

NA

NAVI. Other Observations

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


Page 2 of 2

Attachment B

Site Photographs

INSERT PHOTO HERE

Photo #1: Area observed on August 22, 2011 where water was flowing through woodchuck burrows.

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

INSERT PHOTO HERE

Photo #2: Woodchuck burrow hole observed on August 22, 2011.

G:\GE\GE_Pittsfield_CD_OPCAs\Reports and Presentations\Inspections\Unscheduled\2471111324PhotoLogs.xls

INSERT PHOTO HERE

Photo #3: Sand accumulation in the bottom of a portion of the perimeter drainage ditch, as observed on August 22, 2011.

Client: General Electric Company

INSERT PHOTO HERE

Photo #4: Sand accumulation in the bottom of a portion of the perimeter drainage ditch, as observed on August 22, 2011.

Project Name: Building 71 and Hill 78 OPCAsProject Location: Pittsfield, Massachusetts


INSERT PHOTO HERE

Photo #5: Repair of woodchuck burrow holes and erosion observed on August 22, 2011.


INSERT PHOTO HERE

Photo #6: Repair of erosion observed on August 22, 2011.


INSERT PHOTO HERE

Photo #7: Repair of erosion observed on August 22, 2011.


INSERT PHOTO HERE

Photo #8: Drainage feature observed in good condition on August 26, 2011.


INSERT PHOTO HERE

Photo #9: Drainage feature observed in good condition on August 26, 2011.


INSERT PHOTO HERE

Photo #10: Erosion observed on August 22, 2011 repaired, as observed on August 26, 2011.


INSERT PHOTO HERE

Photo #11: Vegetative cover in good condition on August 26, 2011.


Photo #12: Area of erosion of the soil cover on the Hill 78 OPCA, as observed on September 12, 2011.


INSERT PHOTO HERE

Photo #13: Sand in the bottom of a portion of the perimeter drainage ditch adjacent to the Hill 78 OPCA, as observed on September 12, 2011.


Photo #14: Area of erosion of the soil cover on the border between the OPCAs, as observed on September 12, 2011.


INSERT PHOTO HERE

Photo #15: Sand in the bottom of a portion of the perimeter drainage ditch adjacent to the border between the OPCAs, as observed on September 12, 2011.



letter regarding summary of unscheduled inspection

Documents