GE Corporate

• 159 Plost1cs Avenue Pittsfield, MA 01201 USA

Transmitted via Overnight Courier

October 19, 2015

Ms. Karen Pelto Case Manager Bureau of Waste Site Cleanup Massachusetts Department of Environmental Protection One Winter Street, 81h Floor Boston, Massachusetts 02108

Re: GE-Pittsfield/Housatonic River Site Lyman Street Area (GECD430) Summary of August 2015 Inspection of Natural Resource Restoration/Enhancement

Measures

Dear Ms. Pelto:

On August 5, 2015 , the General Electric Company (GE) performed the ninth and final inspection of natural resource restoration/enhancement (NRRE) measures installed at the Lyman Street Area. This letter provides some background information on these measures and presents the results of the August 5, 2015 inspection .

Background

The NRRE measures required to be installed at the Lyman Street Area were specified in the Consent Decree (CD) for the GE-Pittsfield/Housatonic River Site and associated Statement of Work for Removal Actions Outside the River (SOW), as supplemented by a number of subsequent submissions, which were conditionally approved by the U.S. Environmental Protection Agency (EPA). As shown on Figure 1, the areas subject to NRRE measures are the southern portion of Parcel 19-8-1 (the former GE Lyman Street parking lot area) and the unpaved area in the northern portion of Parcel 19-8-1. The NRRE measures installed in these areas consisted of: (a) the planting of an herbaceous native grassland community on the surface of the vegetative engineered barrier at the Lyman Street parking lot area (excluding the paved access road), as well as in the unpaved area of the northern portion of Parcel 19-8-1 (as shown on Figure I), using a mixture of native grass and wi Idflower species; and (b) the installation of a bluebird box along the edge of the Lyman Street parking lot area adjacent to the Housatonic River. (In accordance with a request from the Natural Resource Trustees [Trustees] in a letter dated March 7, 2006, GE did not place stumps and rock piles within the NRRE area.)

During an inspection in July 2008, the Trustees determined that the installation of the restoration work had been completed in accordance with the applicable CD requirements and Performance Standards. The Trustees issued a Certification of Completion of Installation of Restoration Work to GE on September 2, 2008.

Ms. Karen Pelto October 19, 2015

Page 2of3

Since this area was re-seeded in 2008, it was agreed that, following an initial inspection in 2008, the monitoring schedule would include two visits in each of 2009, 2010, and 2011 , one in 2013, and one in 2015; and this schedule was incorporated into Post-Removal Site Control Plan in the Final Completion Report for the Lyman Street Area Removal Action (Final Completion Report), which was submitted to EPA on August 27, 2009 and approved by EPA on September 14, 2009. GE conducted monitoring visits in June and July 2009, June and August 2010, May and July 2011 , and July 2013; and it submitted reports on those inspections to the Trustees on July I and August 20, 2009, July 8 and September 23, 2010, June 22 and August 12, 2011, and August 23, 2013, respectively.

Summary of Inspection Activities and Observations

The August 2015 inspection was conducted in accordance with Attachment I to the SOW and the Post­Removal Site Control requirements specified in the Final Completion Report. Inspection activities consisted of a field inspection and survey of the planting areas to: (a) verify areal coverage by herbaceous species; (b) determine any instances of trespassing or herbivory; (c) assess the apparent vigor of the vegetation; and ( d) inspect for the presence of invasive species. Representatives of EPA and the Trustees were present at this inspection. The requ ired three-year monitoring period for the bluebird box was completed with the July 2011 inspection.

To document the results of the August 2015 inspection, GE completed an NRRE Inspection Checklist and collected photographic documentation of the conditions of the NRRE areas. Copies of the completed checklist and the photographs are provided as attachments.

Under Attachment I to the SOW, the percent coverage Performance Standard for the NRRE area is 100%. As noted in the attached Inspection Check I ist, the August 2015 inspection indicated that the NRRE area exhibited approximately 100% herbaceous groundcover. This was true both for the former GE parking lot area and for the unpaved area in the northern portion of Parcel 19-8-1 . Further, during that inspection, no significant signs of herbivory or stress were observed in the plant communities.

In 2008, GE had initiated a program of treatment for the invasive species Japanese knotweed, which had been established prior to the initiation of remediation activities at the Lyman Street Area and had been observed within the NRRE area during prior inspections. That program was continued through 2014. During the August 2015 inspection, it was observed that the Japanese knotweed in the area had been treated and is under control. Although small shoots of Japanese knotweed were observed within the previously treated area in the northeastern portion of the NRRE area and on two adjacent properties (Parcels 19-8-8 and 19-8-9), the total percentage of area occupied by this species within the NRRE area was less than 1 %, which is well below the 5% Performance Standard for invasive species cover set forth in Attachment I to the SOW. In addition, the invasive species Cypress spurge and Coltsfoot, which had been successfully treated in conjunction with the Japanese knotweed treatment program, were not observed during the August 2015 inspection.

It was also noted that the groundhog that had been observed within the northern portion of the NRRE area during the prior (July 25, 2013) inspection had been trapped and removed prior to the August 2015 inspection.

Finally, it was noted that the NRRE areas are surrounded by a locked chain-link fence restricting trespasser access, and no signs of damage from trespassers were observed.

G·\GE\GE_Pittsf1dd_CO_Lyman_St\Jtcports and Pn:scnuoons\lru:pccuons'DS-15 NRRE\175151132.4LtrRpt docx

Ms. Karen Pelto October 19, 2015

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Future Activities

As noted above, GE had continued its program of invasive species treatment for the Japanese knotweed through 2014. Although additional treatment is not required since the coverage by this species is well below the Performance Standard, GE plans to conduct treatment for this species on one additional occasion in fall 2015 in an effort to eradicate this invasive species within the NRRE area.

As also noted above, the August 5, 2015 inspection constituted the final required inspection of the NRRE measures at the Lyman Street Area. Based on the condition of the NRRE area and the results of this final inspection, no further NRRE inspections are required. However, in accordance with the NRRE maintenance requirements in the Final Completion Report, GE will continue to mow the grass in the NRRE area once every year in September or October, and will remove any shrub or tree growth observed during those activities in the engineered barrier portion of the NRRE area.

Please call me if you have any comments or questions.

Sincerely,

~--tJ. ~/sµ~

Richard W. Gates Senior Project Manager - Environmental Remediation

Attachments

cc: Dean Tagliaferro, EPA Richard Fisher, EPA Tim Conway, EPA* Chris Ferry, ASRC Primus (electronic copy) Scott Campbell, Avatar (2 hard copies+ electronic copy) Michael Gorski, MassDEP (electronic copy) Eva Tor, MassDEP (electronic copy ofcover letter)* John Ziegler, MassDEP (electronic copy) Robin MacEwan, Stantec (electronic copy) Nate Joyner, City of Pittsfield (electronic copy) Nancy E. Harper, MA AG* Roderic McLaren, GE* James Nuss, ARCADIS James Bieke, Sidley Austin Public Information Repositories GE Internal Repositories

* without attachments

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GENERAL ELECTRIC COMPANY PITTSFIELD, MASSACHUSETTS

LYMAN STREET AREA

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NATURAL RESOURCE RESTORATION / ENHANCEMENT INSPECTION CHECKLIST

LYMAN STREET AREA REMOVAL ACTION

PARCEL I9-8-1 (UNPAVED NORTHERN PORTION AND VEGETATIVE ENGINEERED BARRIER OVER SOUTHERN PORTION)

I. GENERAL INFORMATION

Inspection Date: 08/05/15

Conducted By: Paolo Filippetti - (585) 662-4035

Weather Conditions: Mostly Sunny - 80 °F

Date of Last Inspection: 07/25/13

II. INSPECTION SUMMARY

1. Groundcover A. Estimated Groundcover (Note percentage of groundcover by herbaceous species; note evidence of areas of bare/sparse

vegetation; note any damage from trespassing or herbivory; note any physical changes since last inspection, etc.)

- Lyman Street parking lot area - approximately 100% total ground cover.

- Unpaved northern portion of parcel - approximately 100% total ground cover.

B. Presence of Invasive Species (Note percentage of area occupied by invasive species; note the species present including the following: Amur honeysuckle, Autumn olive, Black locust, Black swallow-wort, Coltsfoot, Common barberry, Common buckthorn, Cyprus spurge, Garlic mustard, Glossy buckthorn, Goutweed or Bishop's weed, Japanese barberry, Japanese honeysuckle, Japanese knotweed, Morrow's honeysuckle, Morrow's X Tartarian honeysuckle [hybrid], Multiflora rose, Norway maple, Oriental bittersweet, Phragmites - Reed grass, Porcelain berry, Purple loosestrife, Russian olive, Spotted knapweed, Tartarian honeysuckle, Yellow iris, or any other plant species listed by the Massachusetts Invasive Plant Advisory Group as “Invasive,” “Likely Invasive,” or “Potentially Invasive.”)

- Japanese knotweed is currently under control within the NRRE area. However, small shoots were observed within the previously

treated areas. Total percentage of area occupied by this species is less than 1%.

- The significant amounts of Japanese knotweed observed on neighboring parcels (Parcels I9-8-8 and I9-8-9) during the July 25,

2013 inspection, which are not subject to NRRE activities, have significantly decreased.

2. Bluebird box to be inspected on a yearly basis for 3 years. (Note any evidence of damage and the extent of damage such as the need to be replaced.)

- N/A - required inspections completed July 2011.

3. Other Observations (Confirm that repair/maintenance measures identified during prior inspection have been performed; note any other general observations, including parcel-specific restoration activities.

- Japanese knotweed treatment program was continued in fall 2013 and 2014.

- A groundhog had been trapped and removed from the NRRE area as a result of the July 25, 2013 inspection.

- NRRE areas had been mowed in 2013 and 2014.

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIES

- Perform one additional Japanese knotweed treatment for the minimal amount of Japanese knotweed observed within the NRRE

area.

- Continue to mow NRRE area annually in September or October.

- If tree and/or shrub growth is identified during mowing activities in the engineered barrier portion of the NRRE area, remove that growth.

ATTACH ADDITIONAL INFORMATION AS APPROPRIATE

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Photo #1: NRRE vegetative cover along access road. Photo taken from Site entrance.

Photo #2: NRRE vegetative cover. Photo taken from access road.

Client: General Electric Company Project Name: Lyman Street Project Location: Pittsfield, Massachusetts

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Photo #3: NRRE vegetative cover along the border between northern/southern portion.

Photo #4: NRRE vegetative cover in northern portion.

Client: General Electric Company Project Name: Lyman Street Project Location: Pittsfield, Massachusetts

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Client: General Electric Company Project Name: Lyman Street Project Location: Pittsfield, Massachusetts

Photo #5: NRRE vegetative cover in northern portion.

Photo #6: Small amount of Japanese knotweed found in northern portion of NRRE area.

G:\GE\GE_Pittsfield_CD_Lyman_St\Reports and Presentations\Inspections\08-15 NRRE\ 1751511324Photo Log.xls

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Client: General Electric Company Project Name: Lyman Street Project Location: Pittsfield, Massachusetts

Photo #7: NRRE vegetative cover in southern portion. Photo taken from border of northern/southern portions.

Photo #8: NRRE vegetative cover in northern portion. Photo taken from eastern portion of Parcel I9-8-1.

G:\GE\GE_Pittsfield_CD_Lyman_St\Reports and Presentations\Inspections\08-15 NRRE\ 1751511324Photo Log.xls

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Photo #9: NRRE vegetative cover in southern portion. Photo taken in a southwestern direction.

Photo #10: Areas treated for Japanese knotweed along border of Parcels I9-8-7 and I9-8-1.

Client: General Electric Company Project Name: Lyman Street Project Location: Pittsfield, Massachusetts

G:\GE\GE_Pittsfield_CD_Lyman_St\Reports and Presentations\Inspections\08-15 NRRE\ 1751511324Photo Log.xls

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Client: General Electric Company Project Name: Lyman Street Project Location: Pittsfield, Massachusetts

Photo #11: Areas treated for Japanese knotweed along border of Parcels I9-8-9 and I9-8-1.

G:\GE\GE_Pittsfield_CD_Lyman_St\Reports and Presentations\Inspections\08-15 NRRE\ 1751511324Photo Log.xls