letter regarding summer 2014 re-vegetation … · 2014 re-vegetation monitoring report page 10 of...

• GE 159 Plastics Avenue Pittsfield, MA 01201 USA

September 5, 2014

Dean Tagliaferro EPA Project Coordinator US Environmental Protection Agency c/o Weston Solutions, Inc. 10 Lyman Street Pittsfield, MA 01201

Re: GE-Pittsfield /Housatonic River Site, Pittsfield, MA 1% Mile Reach (GECD820) Summer 2014 Re-Vegetation Monitoring Inspection

Dear Mr. Tagliaferro:

This letter report describes and presents the results of a vegetation inspection performed at the 1Yz Mile Reach of the Housatonic River (1 Yz Mile) . That inspection was conducted on August 5, 2014 by AMEC Environment & Infrastructure, Inc. (AMEC) on behalf of the General Electric Company (GE). It represents the second annual monitoring event of an additional three-year monitoring and maintenance program for the restored bank vegetation in the 1Yz Mile, as described in Section 11.1 of GE's 2012 Annual Monitoring Report on the 1 Yz Mile (submitted in January 2013 and conditionally approved by EPA on March 28, 2013) .

Background and Requirements

The vegetation inspections conducted in 2012 within the 1Yz Mile constituted the final year of the previously required five-year monitoring period for the riverbank (and, where relevant, non-bank) plantings in the 1Yz Mile . However, based on discussions with EPA, GE proposed in the 2012 Annual Monitoring Report to continue certain modified monitoring and maintenance activities relating to the vegetation in this reach for three additional years . As approved by EPA, that modified program requires the performance of one annual vegetation inspection (in July1) for three years through 2015, during which GE is to perform a qualitative assessment (through a meander survey) of the condition and/or presence of invasive species cover and tree cages along the banks of the 1 Yz Mile. No Maintenance Standard applies during these inspections; however, EPA and GE are to discuss potential corrective action for areas that appear to have a problem (e.g., significant coverage or expansion of invasive species, tree cages adversely affecting tree growth).

In addition to the restored vegetation inspection described above, GE was also required to inspect trees and shrubs planted within the last two years as follows:

• In Phase 1, the six grey dogwoods planted in fall 2012 on the steep bank on Parcell823-6 required inspection in 2013 and 2014. As provided in EPA's March 28, 2013

1 The 2014 annual inspection was performed in August due to scheduling constraints.

Corporate Environmental P(ogroms

Dean Tagliaferro September 5, 2014

conditional approval letter, these shrubs are subject to a Maintenance Standard of 80%

survival. If any of these shrubs need to be replaced, any new plantings will be subject to

a new two-year monitoring period of annual inspections.

• Also on Parcel 18-23-6, the additional shrubs and trees that were planted on the steep

bank in spring 2013 (6 New Jersey Teas and 3 eastern red cedars) were inspected

initially during the 2013 inspection and require inspection again in 2014 and 2015. As

provided in EPA's March 28, 2013 conditional approval letter, these plantings are also

subject to a Maintenance Standard of 80% survival. If any of these plantings need to be

replaced, any new plantings will be subject to a new two-year monitoring period of

annual inspections.

The additional three-year monitoring and maintenance program also requires GE to continue its

prior reach-wide Invasive Species Control Program, as well as a modified version of its Tree

Cage Maintenance Program, through 2015, at the end of which time GE is to make a proposal

to EPA regarding the need for continuing those programs further.

Summary of 20141nspection

The annual 2014 inspection was performed on August 5, 2014, and was attended by

representatives of GE and EPA. In accordance with the above requirements, this inspection

included: (a) a qualitative meander survey of the condition and/or presence of invasive species

cover and tree cages along the banks of the 1% Mile; (b) an inspection of the six grey dogwoods

planted in fall 2012 on the steep bank on Parcel 18-23-6; and (c) inspection of the 6 New Jersey

teas, 3 eastern red cedars, and herbaceous native seed mixture planted in 2013 on the steep

bank, also on Parcel 18-23-6.

Results of Inspection

The results of the August 5, 2014 inspection are summarized below. Representative

photographs taken during that inspection are provided in Attachment A.

The quantitative assessment of the 6 grey dogwoods planted in the fall of 2012, and the 6 New

Jersey Teas and 3 eastern red cedars planted in the spring of 2013 indicated that all of the

plantings are surviving and thus meeting the 80% Maintenance Standard. The table below

summarizes these findings:

No. PlantedTree/Shrub and Time of 2014 Observation

Percent

Species SurvivalPlanting

6Grey Dogwood 6 observed, all healthy 100%

Fall 2012 6

New Jersey Tea 6 observed, all healthy 100%Spring 2013

3Eastern Red Cedar 3 observed, all healthy 100%

Spring 2013

The inspection revealed further that Invasive Species Control Program continues to be

successful along the 1% Mile and that no adjustments to that program are necessary.

Dean Tagliaferro September 5, 2014 Page3

The phased tree cage removal along the 1 ~ Mile was also observed to be proceeding as planned and will continue subject to a few clarifications described below.

Schedule for Future Activities

The final inspection of the restored vegetation in the 1~ Mile will be conducted in accordance with the requirements in Section 11 .1 of the 2012 Annual Monitoring Report (except for the Tree Cage Maintenance Program, described below). The inspection will be conducted in the summer of 2015. The required inspection of the 6 grey dogwoods planted in the fall of 2012 on the steep bank on Parcel 18-23-6 was completed with the 2014 inspection. However, the 6 New Jersey teas and 3 eastern red cedars planted in the spring of 2013 on the steep bank will be inspected again in 2015.

In addition, GE will continue its current reach-wide Invasive Species Control Program through 2015.

The phased approach for tree cage removal will continue focusing efforts first on those cages requiring immediate attention, such as those requiring removal because of tree growth or because the cages are downed, damaged, etc. This phased removal will continue through 2015. The majority of tree cage removals will be either in the fall, after a frost, or in the early spring, as these time periods present the least hindrance from surrounding vegetation.

As discussed with EPA, the phased tree cage removal is subject to the following clarifications:

1. On Parcel 17-2-1, all cages in 2014 and 2015 will be inspected and maintained, including pruning as necessary. An assessment of the status of the cages will be made during the summer 2015 restored vegetation inspection.

2. On Parcel 17-3-1, cage removal will be limited to damaged cages affecting tree growth, and other cages will be left in place. An assessment of the status of the cages will be made during the summer 2015 restored vegetation inspection.

3. At Fred Garner Park between the walking path and the river, all cages in 2014 and 2015 will be inspected and maintained, including pruning as necessary. An assessment of the status of the cages will be made during the summer 2015 restored vegetation inspection.

4. On Parcels 18-24-1 and 18-24-101, cage removal will be limited to damaged cages affecting tree growth, and other cages will be left in place. An assessment of the status of the cages will be made during the summer 2015 restored vegetation inspection.

5. For the remainder of 2014, especially after the first frost, cage removal will focus on the riverbanks between the Elm Street Bridge and Pomeroy Avenue (excluding Parcels 17-2-1 and 17-3-1). In other areas, cage removal will focus on damaged cages and cages affecting tree growth.

Dean Tagliaferro September 5, 2014

Following completion of the 2015 inspection, GE will make a proposal regarding the need for and scope any future monitoring and maintenance activities for the restored vegetation in the 1%Mile.

If you have any questions about this report or would like to discuss it further, please contact me at 413-448-5910.

Sincerely yours,

Kevin G. Mooney Project Manager

Attachment

cc: John Kilborn , EPA Christopher Ferry, EPA (electronic copy) Michael Gorski, MA DEP (electronic copy) Eva Tor, MA DEP (electronic copy) John Ziegler, MA DEP (2 hard copies & 2 electronic copies) Karen Pelto, MA DEP Nancy E. Harper, MA AG Ken Munney, US F&W Susan Peterson, CT DEEP Linda Palmieri, Weston (2 hard copies & 2 electronic copies) Andrew Silfer, GE Roderic Mclaren, GE James Bieke, Sidley Austin lzabela Zapisek, WESTON Phil Perhamus, AMEC Pamela Brown for Public Information Repositories & GE Internal Repositories (4 hard copies and 4 electronic copies)

ATTACHMENT A

Photographs

2014 Re-Vegetation Monitoring Report Page 1 of 14

Phase 1

Lyman Street to Elm Street


Photo 1-1: Typical view of Phase 1 in August 2014 near upstream end, facing downstream towards the east shoreline.

Photo 1-2: Typical view of Phase 1 in August 2014 near approximate midpoint, facing downstream towards the east shoreline.


Photo 1-3: Typical view of Phase 1 in August 2014 near downstream end, facing downstream towards the east shoreline.

Photo 1-4: Typical view of Phase 1 in August 2014 near downstream end, facing downstream towards the west shoreline.


Photo 1-5: Example of one of the six New Jersey Teas planted in the spring of 2013 on Parcel I8-23-6.

Photo 1-6: Downstream end of Phase 1, viewed from the Elm Street Bridge, facing upstream..


Phase 2

Elm Street to Dawes Avenue


Photo 2-1: Upstream end of Phase 2, viewed from the Elm Street Bridge, facing downstream.

Photo 2-2: Downstream end of Phase 2, viewed from the Dawes Avenue Bridge, facing upstream.


Photo 2-3: Typical view of Phase 2 in August 2014 near the upstream end, facing downstream towards the east shoreline.

Photo 2-4: Typical view of Phase 2 in August 2014 near the downstream end, facing downstream.


Photo 2-5: Typical view of Phase 2 in August 2014 at the downstream end, facing upstream.


Phase 3

Dawes Avenue to Pomeroy Avenue


Photo 3-1: Typical view of Phase 3 in August 2014 near the downstream end, viewed from Planting Area 27, facing upstream towards the east shoreline.

Photo 3-2: Typical view of Phase 3 in August 2014 viewed from Planting Area 26, facing upstream towards the east shoreline.


Photo 3-3: Typical view of Phase 3 in August 2014, viewed from Planting Area 38 facing upstream towards the west shoreline.


Phase 4

Pomeroy Avenue to the Confluence


Photo 4-1: Upstream end of Phase 4, viewed from the Pomeroy Avenue Bridge, facing downstream.

Photo 4-2: Typical view of Phase 4 in August 2014, near the upstream end, facing downstream towards the east shoreline.


Photo 4-3: Typical view of Phase 4 in August 2014, viewed from Planting Area 40, facing downstream.

Photo 4-4: Additional view of Phase 4 in August 2014 from Planting Area 40, facing downstream.

letter regarding summer 2014 re-vegetation … · 2014 re-vegetation monitoring report page 10 of...

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