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EPA Cleanups: GE-Pittsfield/Housatonic River Site

Site History and Description

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  Allendale School GE Plant Area
  Floodplain Properties Groundwater
  Former Filled Oxbows On-Plant Consolidation Areas
  Housatonic River ½ Mile Removal Rest of River
  Housatonic River 1½ Mile Silver Lake
  General  

Allendale School Area GE Plant Area Silver Lake 1 and 1/2 Mile Reach 1/2 Mile Removal Reach Former Filled Oxbow Areas 1 and 1/2 Mile EECA Reach Silver Lake Former Filled Oxbow Areas GE Plant Area Allendale School Area Former Filled Oxbow Areas Rest of River

Map of GE / Housatonic Site.

Site Map identifying distinct cleanup areas (PDF) (1 pg, 1 MB, About PDF)

Site Map of Groundwater Management Areas (PDF) (1 pg, 886 K, About PDF)

OVERVIEW

The Housatonic River flows from north of Pittsfield, MA to Long Island Sound and drains an area of approximately 1,950 square miles (500,000 hectares) in Massachusetts, New York, and Connecticut. The Housatonic River, its sediment, and associated floodplain are contaminated with polychlorinated biphenyls (PCBs) and other hazardous substances released from the General Electric Company (GE) facility located in Pittsfield, MA. The entire site, known as the General Electric/Housatonic River Site, consists of the 254-acre (103-hectare) GE manufacturing facility; the Housatonic River and associated riverbanks and floodplains from Pittsfield, MA, to Long Island Sound; former river oxbows that have been filled; neighboring commercial properties; Allendale School; Silver Lake; and other properties or areas that have become contaminated as a result of GE’s facility operations.

In September 1998, after years of scientific investigations and regulatory actions, a comprehensive agreement was reached between GE and various governmental entities, including the U.S. Environmental Protection Agency (EPA), the Massachusetts Department of Environmental Protection (MDEP), the U.S. Department of Justice (DOJ), the Connecticut Department of Environmental Protection (CTDEP), and the City of Pittsfield. The agreement provides for the investigation and cleanup of the Housatonic River and associated areas.

INTRODUCTION

The Housatonic River is located in a predominantly rural area of western Massachusetts, where farming was the main occupation from colonial settlement through the late 1800s. As with most rivers, the onset of the industrial revolution in the late 1800s brought manufacturing to the banks of the Housatonic River, in Pittsfield, MA. General Electric (GE) began its operations in Pittsfield in 1903. Three manufacturing divisions have operated at the GE facility (Transformer, Ordnance, and Plastics).

The 254-acre GE plant in Pittsfield has historically been the major handler of polychlorinated biphenyls (PCBs) in western Massachusetts, and is the only known source of PCBs found in the Housatonic River sediments and floodplain soils in Massachusetts. Although GE performed many functions at the Pittsfield facility throughout the years, the activities of the Transformer Division, including the construction and repair of electrical transformers using dielectric fluids, some of which contained PCBs (primarily Aroclors 1254 and 1260), were one likely significant source of PCB contamination. According to GE's reports, from 1932 through 1977, releases of PCBs reached the waste and storm water systems associated with the facility and were subsequently conveyed to the East Branch of the Housatonic River and to Silver Lake.

During the 1940s, efforts to straighten the Pittsfield reach of the Housatonic River by the City of Pittsfield and the U.S. Army Corps of Engineers (USACE) resulted in 11 former oxbows being isolated from the river channel. The oxbows were filled with material that was later discovered to contain PCBs and other hazardous substances.

A fish consumption advisory for the Housatonic River from Dalton, MA, to the Connecticut border was issued by the Massachusetts Department of Public Health (MADPH) in 1982 as a result of the PCB contamination in river sediment and fish tissue. The advisory was later amended to include frogs and turtles. The State of Connecticut also posted a fish consumption advisory for most of the Connecticut section of the river in 1977. In addition, in 1999, MADPH issued a waterfowl consumption advisory from Pittsfield to Great Barrington due to PCB concentrations in wood ducks and mallards collected by the Environmental Protection Agency (EPA) from the river.

Although the two miles downstream from the facility have historically been channelized, the river's course is relatively unaffected (with the exception of the numerous dams downstream) in areas south of Pittsfield. The approximately 10 miles of river from the confluence of the East and West Branches of the Housatonic to the headwaters of Woods Pond in Lenox are bordered by extensive floodplains (up to 3,000 feet wide), range from 45 to 100 feet in width, and have a meandering pattern with numerous oxbows and backwaters. Woods Pond, a shallow 56-acre impoundment, was formed by the construction of a dam in the late 1800s.

The land uses/ownership of the floodplain properties include private and residential, agricultural, recreational (such as canoeing, fishing, and hunting), wildlife management areas and parks.

REGULATORY FRAMEWORK AND CURRENT STATUS

The GE/Housatonic River site has been subject to regulatory investigations dating back to the early 1980s. For several years, these investigations were consolidated under the following regulatory mechanisms: two Administrative Consent Orders (ACOs) with the Massachusetts Department of Environmental Protection (MADEP) and a Corrective Action Permit with EPA under the Hazardous and Solid Waste Amendments to the Resource Conservation and Recovery Act (RCRA).

In 1991, EPA issued a RCRA Corrective Action Permit to the GE Pittsfield facility. Following an appeal and subsequent modification, the permit became effective in 1994. The permit included the 254-acre facility, some former filled oxbows, Silver Lake, the Housatonic River and its floodplain and adjacent wetlands, and all sediments contaminated by PCBs originating from the GE facility.

In addition to the permit, the two ACOs between GE and MADEP became effective in 1990 and included those areas defined in the permit as well as three additional study areas. Under the ACO, GE has performed several investigations and short-term cleanups.

EPA proposed the Site to the Superfund National Priorities List in September of 1997. The federal and state government agencies and GE entered into negotiations late in 1997 in an attempt to reach a comprehensive settlement which included remediation, redevelopment, and restoration components.

In September 1998, representatives of the federal and state government agencies, GE, the City of Pittsfield, and the Pittsfield Economic Development Authority reached a tentative agreement in principle relating to GE's Pittsfield facility, other contaminated areas in Pittsfield, and the Housatonic River. This agreement was translated into a Consent Decree, lodged with the federal court on October 7, 1999, and approved by the court on October 27, 2000. The agreement provides for, among other things, the cleanup of the GE plant facility, cleanup and restoration of the former oxbows, cleanup and restoration of Silver Lake, cleanup of Allendale School, environmental restoration of the Housatonic River and floodplain, compensation for natural resource damages, and government recovery of past and future response costs. Entry of the agreement also makes possible large-scale redevelopment of the GE facility, for which GE is funding approximately $45 million. Below is a description of the different areas that are subject to cleanup.

The Housatonic River

The Housatonic River cleanup is divided into three segments, the first ½ mile adjacent to the facility, the next 1½ miles downstream to the confluence of the East and West Branches, and the Rest of River downstream of the Confluence.

Upper ½-Mile Reach Removal Action - The first ½ mile of the portion of the Housatonic River subject to remediation is located in a densely populated area near the center of Pittsfield. The area is primarily commercial/industrial, although there is one recreational property abutting the River. A portion of GE's 254-acre property abuts the River to the north, and several commercial/industrial properties, a playground, and additional GE property abut the River to the south. The entire ½-mile section of the River was channelized by the city and the USACE in the 1940s and, as a result, there are relatively steep banks and minimal floodplain in this area. Five of the former oxbows discussed above are present in this stretch of the River. Many of the historical discharges to the Housatonic River were likely to have occurred within this ½ mile.

Remediation in the first ½ mile consisted of two separate cleanups. In December 1996, EPA issued GE a Unilateral Order to remove highly contaminated sediments and bank soils in the area adjacent to Building 68. As a result, in 1997 and 1998 GE excavated and disposed of 5,000 cubic yards of heavily contaminated sediments (average PCB concentration of approximately 1,534 ppm) from a 550-foot section of the river, and 2,230 cubic yards of heavily contaminated bank soils (average PCB concentration in surficial soils of 720 ppm and average concentration in subsurface soils of 5,896 ppm) from a 170-foot stretch of the riverbank. Sediment removal activities were performed "in the dry;" that is, by installing sheetpile into the river and diverting the flow of the river around the sheetpile, dewatering small sections, and removing the sediments with standard excavating equipment located on top of the riverbank.

The second phase of the cleanup consisted of further bank soil and sediment excavation throughout the first ½ mile. This action began in October 1999. Excluding the areas remediated during the Building 68 cleanup, the average surficial (0-1 foot depth) sediment PCB concentration was 54.8 ppm and average concentration of PCBs in the top 3 feet of riverbank soil was 56 ppm. Sediment excavation was performed in a manner similar to the Building 68 remediation. Sheetpile was driven into the middle of the river channel and the flow was diverted to one side. Sections of the river were then dewatered and the "dry" sediments removed by conventional equipment (e.g., backhoes, cranes, etc.). Sediment removal occurred wherever there was surficial contamination (approximately 75% of the area) and proceeded to a maximum depth of 2 ½ feet. Construction sampling results indicated that contamination will remain below 2 ½ feet and, therefore, restoration of the riverbed consisted of the placement of a cap containing a silty-sand sorptive layer, covered by an armored layer to return the riverbed to its original elevation and as a substrate for restoration. The ½-Mile remediation and restoration was completed in September 2002. Approximately 11,800 cubic yards of sediment and 6,400 cubic yards of bank soils were removed.

GE is currently performing all required post-removal site control inspection, monitoring and maintenance activities.

1½-Mile Reach EE/CA and Removal Action - The next 1½ miles of the river are located in an area with residential, commercial, industrial and undeveloped/recreational properties. In all, there are approximately 40 residential properties located within or adjacent to the floodplain. Approximately 1,500 feet of this reach was channelized by the city and the USACE in the 1940s and three former oxbows are within this stretch of the river. In the first mile, the riverbanks are generally steep and the floodplain narrow. In the last ½ mile, the riverbanks are relatively low, resulting in a broad floodplain. The 1½-Mile Reach ends at the confluence of the East and West Branches of the Housatonic River.

The average concentration of PCBs in the surficial sediments (0 to1 foot depth) was 21 ppm and the average concentration of PCBs in sediments at all depths was 29 ppm. For the riverbanks, the average concentration of PCBs in the top foot was approximately 23 ppm and the average concentration of PCBs in the top 3 feet was 40 ppm.

EPA initiated the cleanup of the sediment and riverbanks in this 1½-Mile Reach under the Consent Decree in October 2002. GE has agreed to reimburse EPA as part of a cost-sharing arrangement. As an example of how the cost-sharing agreement works, if the selected cleanup alternative costs a total of $85 million, GE will pay about $50 million and EPA will pay about $35 million (see the Consent Decree language under "Cleanup Agreements" for more details). EPA completed excavation activities in March of 2006 and substantially completed the restoration activities by the end of 2006. EPA employed a combination of the "dry excavation" technique used by GE and discussed above and a gravity-fed bypass system. The bypass system consisted of a temporary dam (which was installed approximately 1,400 feet downstream from the Lyman Street Bridge) that diverted the river flow into two 54-inch movable HDPE pipes. The pipes were placed along one side of the river channel while the riverbed sediment and riverbank soil on the other side were removed and backfilled. The pipes were then moved to the remediated side of the river and the process was repeated. Additional sections of pipe were added to the two 54-inch pipe extending the system as the removal and restoration progressed downstream.

In total, approximately 91,700 cubic yards (CY) of contaminated sediment and riverbank material was removed and disposed of as part of the 1½-Mile Reach Removal Action. Approximately 7,000 CY of this material was impacted by non-aqueous phase liquids (NAPL). 50,750 CY of the contaminated material was disposed of in GE's On-Plant Consolidation Areas and the remainder of the contaminated material, including all of the NAPL-impacted material, was disposed of at licensed off-site disposal facilities.

In June of 2007, EPA sampled river sediment, benthic invertebrates, and fish from three locations in the 1½-Mile Reach. Sediment and benthic invertebrate tissue were analyzed for PCBs, and the individual fauna in the invertebrate and fish samples were identified and enumerated. The results were compared to samples collected at the same locations in 2000, prior to the start of remediation.

Sediment PCB concentrations in 2007 were reduced from the pre-remediation concentrations by approximately 99%, indicating that the initial remediation was successful. The decrease in sediment PCB contamination was reflected in the 99.5% decrease in benthic invertebrate tissue PCB concentrations. Benthic invertebrate populations showed an increase in diversity, abundance, and biomass at all locations post remediation, with a marked increase in pollution-intolerant species. The results of the fish sampling indicated the presence of a diverse and abundant post-remediation fish population in keeping with the expected fish community composition, with noticeably greater fish presence in the vicinity of stone structures provided as part of habitat restoration in the river channel.

In 2008, EPA finalized an Interim Post-Removal Site Control (PRSC) Plan. In early 2008, GE assumed responsibility and is currently conducting all required post-removal site control activities (e.g., inspections, monitoring and maintenance activities) pursuant to the Interim PRSC Plan.

EPA anticipates issuing the Final 1½ Mile Reach Completion Report and a Final Post-Removal Site Control Plan in 2011.

GE Plant Site

The General Electric (GE) Plant Area encompasses approximately 324 acres and consists of 10 specific Removal Action Areas (RAAs) associated with the operation of GE's Transformer, Plastics and Ordnance Divisions at the site. These RAAs have been identified based on a number of considerations, including geographic location, prior regulatory definition and status, scope and timing of response actions, current and reasonably foreseeable land use, and nature and extent of contamination. The current remediation status of the 10 RAAs is as follows:

  • 8 RAAs. Remediation complete, Final Complete Report submitted and Certificate of Completion issued to GE.
  • 1 RAAs. Remediation substantially complete, Final Completion Report and Certificate of Completion pending.
  • 1 RAA. Remediation pending. Final Work Plan documents currently under review.

The 10 individual GE Plant Area RAAs are described below.

40s Complex - This RAA encompasses approximately 7 acres and is located within the western portion of GE facility. The area is generally bounded by Kellogg Street to the north, Woodlawn Avenue and other portions of the GE facility (East Street Area 2-North) to the east, railroad tracks (and a related easement by CSX, Inc.) to the south and non-GE owned commercial/industrial areas to the west. The area is mostly paved (asphalt/concrete). Prior to the lodging of the Consent Decree in 1999, Buildings 40-A, 41, and 41-A comprised much of the western portion of this area. These buildings were demolished in the early 1990s, although the subgrade portions of these buildings remain within this area. Buildings 42, 43, 43-A, and 44 comprised much of eastern portion of the area and Building 40-B was located in the central portion of this area. In 2004, GE demolished Building 40-B, and in 2005 and 2006, GE demolished Buildings 42, 43, 43-A, and 44. Approximately 19,000 cubic yards of concrete demolition debris from Buildings 42, 43, 43-A, and 44 was sampled determined to acceptable for re-use and therefore was crushed on site into a 3-inch minus aggregate. A portion of this crushed building debris was placed as structural wedges along the northern wall of the former Building 43 and eastern wall of former Building 42, to support Kellogg Street and Woodlawn Avenue, respectively. The remaining 15,000 cubic yards of crushed building debris was consolidated into an on-site stockpile located on the western portion of the RAA for potential use during re-development activities. Building debris not suitable for reuse was either transported off-site for disposal or was placed into the Hill 78 or Building 71 On-Plant Consolidation Area.

GE sampled the RAA as required in the Consent Decree and EPA has concurred with GE that no active remediation was required in this RAA. In 2009, GE performed additional actions in preparation for transferring the property to the Pittsfield Economic Development Agency (PEDA). These actions included pavement repairs and guardrail removal.

GE submitted a Final Completion Report on January 7, 2011 and EPA issued a Certificate of Completion to GE on January 24, 2011. This area is a component of the re-development agreement between GE and the City of Pittsfield and was transferred to PEDA on February 16, 2011.

PEDA and GE are currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities. The inspection, monitoring and maintenance requirements for PEDA and GE are detailed in the Final Completion report.

30s Complex - This 15.75-acre area is located south of the 40s Complex and CSX railroad tracks. The area is generally bounded by Silver Lake Boulevard to the west, East Street and other areas of the GE facility (East Street Area 2 – South) to the south and other area of the GE facility (20s Complex) to the east. The surface of this area was historically comprised of buildings, asphalt/concrete with some unpaved areas. GE sampled the RAA as required by the Consent Decree and EPA has concurred with GE that no active remediation is required in this area. GE also demolished numerous buildings at this RAA.

GE submitted a Final Completion Report on March 18, 2005 and EPA issued a Certificate of Completion to GE on March 28, 2005. This area is a component of the re-development agreement between GE and the City of Pittsfield and was transferred to PEDA on May 2, 2005.

PEDA has since conducted significant site development activities including the removal of a majority of the pavement and concrete surfaces, installation of new drain lines, re-grading, landscaping, and construction of a water quality basin. In 2010, PEDA granted a two-acre easement to Western Massachusetts Electric Company for the construction of solar panel array.

PEDA is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities.

20s Complex - This 10.21-acre area is located immediately east of the 30s Complex within the western portion of the GE facility. The area is generally bounded by East Street to the south and other areas of the GE facility to the north (East Street Area 2 – North) and to the east by (East Street Area 1- North). This area includes the portion of Woodlawn Avenue running from the CSX railroad tracks south to East Street. The RAA was historically comprised of buildings, asphalt/concrete with some unpaved areas. GE sampled the RAA as required by the Consent Decree and EPA has concurred with GE that no active remediation is required in this area. GE also demolished numerous buildings at this RAA.

GE submitted a Final Completion Report on March 18, 2005 and EPA issued a Certificate of Completion to GE on March 28, 2005. This area is a component of the re-development agreement between GE and the City of Pittsfield. A 9.25-acre portion of this area was transferred to PEDA on May 2, 2005. GE transferred the Woodlawn Avenue portion of this area (approximately one acre), along with northern portion of Woodlawn Avenue, to PEDA on December 16, 2011.

Since 2005, PEDA has conducted significant site development activities including the removal of a majority of the pavement and concrete surfaces, installation of new drain lines, re-grading of the property and repaving of Woodlawn Avenue.

PEDA is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities.

East Street Area 2 - South -This area encompasses approximately 50 acres of the western portion of the GE facility. It is generally bounded by East Street to the north, Newell Street to the east, the Housatonic River to the south, and the Lyman Street Area RAA to the west. The western portion of this area is comprised mostly of the 60s Complex, and is otherwise mostly paved. GE has demolished several buildings since 2002 and a vegetative cover was installed upon the foundation slabs of some of the buildings. The eastern portion of this area contains a former Housatonic River oxbow (Oxbow H) that was formed when the river meandered through this area. This area is currently characterized as mostly open grassy areas, with a relatively small wooded area located south of the former oxbow. GE's stormwater and groundwater treatment plants are located in this area. A 3.7 acre portion of this area adjacent to Newell Street and East Street was designated as a recreational area for the City of Pittsfield.

The portion of riverbank adjacent to this area was subject to the Upper ½-Mile Reach Removal Action. In addition, numerous source control measures were implemented between 1999 and 2002 in the riverbank area to address the presence of non-aqueous phase liquid (NAPL).

GE completed the required sampling in the future city recreational area and submitted a Removal Design/Removal Action Work Plan in December 2001 and an Addendum to the Removal Design/Removal Action Work Plan in April 2003. EPA conditionally approved these Work Plans in April 2003 and June 2003, respectively. From July 2003 through April 2004, in accordance with the EPA-approved Work Plans, GE performed the required remediation and restoration activities. The remediation activities consisted of the removal and proper disposal of approximately 501 cubic yards of soil. Restoration activities included the installation of a one-foot minimum soil cover in the recreational area, the placement of sod, the construction of a baseball field, the installation of a walking track, the installation of light towers, and the construction of a gravel access road and gravel parking lot.

GE submitted a Final Completion Report for the City Recreational Area on July 31, 2008, and EPA issued a Certificate of Completion to GE on August 27, 2008. GE agreed to lease the recreational area to the City for free and GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities.

GE subsequently completed the soil sampling for the remaining portions of East Street Area 2-South as required in the Consent Decree. GE submitted a Final Removal Design/Removal Action Work Plan in November 2009 and a Revised Final Removal Design/Removal Action Work Plan in April, 2010. EPA conditionally approved these Work Plans in February 2010 and May 2010, respectively. GE initiated remediation activities in July 2010. Proposed remediation activities include the removal and proper disposal of 20,000 cubic yards of material and the installation of approximately 4.8 acres of a vegetated engineered barrier. Remediation and restoration activities were substantially completed in November 2011.

GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities. GE is expected to submit a Final Completion Report to EPA in 2012.

East Street Area 2 - North - This area encompasses approximately 53.4 acres and is located within the western portion of the GE facility. This area is generally bounded by Tyler Street to the north, New York Avenue to the east, the City-owned portion of Woodlawn Avenue and the 40s Complex to the west, and CSX railroad tracks and Merrill Road to the south. The 20s Complex and East Street Area 1-North are located south of Merrill Road and the CSX railroad tracks. The eastern portion of the RAA is mostly covered with buildings and pavement, intermixed with several relatively small grassy areas, including a grassy area sloping down to New York Avenue. The western portion of the RAA, also referred to as the 19s Complex, was historically comprised of buildings and asphalt/concrete, with very little unpaved grass areas.

GE has completed the sampling as required in the Consent Decree. GE submitted the Final Removal Design/Removal Action Work Plan in August 2006 and an Addendum to the Final Removal Design/Removal Action Work Plan in May 2007. EPA conditionally approved these documents in January 2007 and August 2007, respectively. In 2008, in accordance with the EPA-approved Work Plans, GE performed the required remediation and restoration activities, which consisted of the removal and proper disposal of approximately 1,200 cubic yards of soil. All of the soil removal was performed in the eastern portion of the RAA.

From 2001 through 2010, GE demolished all of the buildings on the 16.6-acre western portion of the RAA (the 19s Complex) and repaired the building slabs and deteriorated pavement. In 2010, GE placed approximately 12,500 cubic yards of crushed demolition debris (brick and concrete) in the RAA to fill in vaults, subsurface areas in structural wedges along the embankments of Tyler Street and Woodlawn Avenue, and as general grading material. The 19s Complex is now predominately covered with slabs, pavement, the crushed building debris and small vegetated area.

GE transferred Woodlawn Avenue (both the north portion, which is part of East Street Area 2-North, and the south portion, which is part of the 20s Complex), to PEDA on December 16, 2011.

GE submitted a Final Completion Report to EPA on January 6, 2012, and EPA issued a Certificate of Completion to GE on January 19, 2012. GE subsequently transferred the 19s Complex to PEDA on February 7, 2012. This brings the total amount of land transferred to PEDA to approximately 52 acres.

GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities on the GE-owned eastern portion of the RAA. GE and PEDA are performing separate post-removal site control activities on the PEDA-owned parcels.

East Street Area 1 - North - This area encompasses 5 acres and is located immediately south of East Street Area 2 - North and east of the 20s Complex. This area, is generally bounded by CSX railroad tracks and Merrill Road to the north, Merrill Road to the and west, East Street to the south, and a non-GE owned commercial property to the east. This area is mostly unpaved and includes a commercial-use building, of which GE owns the western portion and a private entity owns the eastern portion. GE owns the land west of the building, where there is a NAPL containment/recovery system. CSX owns a small strip of land on the north side of the RAA between the building and the railroad tracks. GE has sampled this area as required by the Consent Decree and EPA has concurred with GE that no active remediation is required in this RAA.

GE submitted a Final Completion Report on September 27, 2005 and EPA issued a Certificate of Completion to GE on September 29, 2005. GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities.

In January and February 2012, GE demolished their portion of the commercial use building. Also during this time frame, the City of Pittsfield, which had previously condemned the western portion of the building, demolished the western portion of the building. There are no structures remaining at this RAA.

Hill 78 Area - Remainder - This area encompasses approximately 30 acres and is located in the central to eastern portion of the GE facility. The area is generally bounded by GE owned property that is not covered by the Consent Decree and Allendale School property to the north, Merrill Road to the south, New York Avenue and other areas of the GE facility (East Street Area 2 – North) to the west, and other areas of the GE facility (the General Dynamics portion of the Unkamet Brook Area) to the east. The area excludes the Hill 78 and Building 71 On-Plant Consolidation Areas (OPCAs) discussed below. Building 78 (GE's hazardous waste storage facility), Building 14E (electrical substations) and a co-generation facility are located within this RAA. With the exception of paved roadways associated with Building 78, Building 14E and the cogeneration facility, the remainder of the RAA is generally unpaved and partially tree-covered.

GE has completed the sampling required by the Consent Decree. GE submitted the Final Removal Design/Removal Action Work Plan in June 2008 and an Addendum to the Final Removal Design/Removal Action Work Plan in September 2008. EPA conditionally approved these documents in August and October 2008, respectively. In addition, GE submitted plans to EPA to re-route sanitary and storm sewer pipelines outside the footprint of the OPCAs and through the Hill 78-Remainder RAA. EPA subsequently approved the re-routing plans. The storm drain construction and soil remediation was conducted in two phases: (1) relocation of the storm drains between October 2007 and June 2008, which included the necessary soil removal in the storm drain area to meet soil-based performance standards; and (2) in November and December 2008, the removal and restoration of soil in the remainder of the RAA. Additional restoration work was conducted in April 2010. In total, soil remediation consisted of the removal and proper disposal of approximately 1,240 cubic yards of soil.

GE submitted a Final Completion Report on August 31, 2011and EPA issued a Certificate of Completion to GE on September 6, 2011. GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities.

Hill 78 On-Plant Consolidation Area (OPCA) - This area encompasses approximately 6 acres and is located within the boundaries of the Hill 78-Remainder RAA. It is located in the northern portion of Hill 78-Remainder Area, and is surrounded on all sides by the Hill78-Remainder RAA, except for the east, where it is bordered by the Building 71 OPCA. The Hill 78 OPCA includes the former Hill 78 landfill, which was a 15-foot tall on-site disposal area that was historically used by GE for excavated soils, building demolition and construction debris, and other materials generated within the GE facility. In 1991, GE installed a temporary cap on the former landfill that consisted of a geotextile layer covered with either one foot of crushed stone or soil.

This area was designated in the Consent Decree as a consolidation area for certain materials excavated or otherwise removed as part of various Removal Actions and building demolition debris at the GE-Pittsfield/Housatonic River Site. This area received approximately 134,500 cubic yards of materials from 1999 through 2009. (See below for more details on material placement requirements.) The area was filled to capacity and final capping was completed in 2009.

GE submitted a Final Completion Report for the Hill 78 and Building 71 OPCAs on September 15, 2011and EPA issued a Certificate of Completion to GE on September 26, 2011. GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities.

Building 71 On-Plant Consolidation Area (OPCA) - This approximately 4.4 acre area is also located within the boundaries of the Hill 78- Remainder RAA. It is located immediately to the east of the Hill 78 OPCA. The co-generation facility is located directly to the south. This area was designated in the Consent Decree as a consolidation area for certain materials excavated or otherwise removed as part of various Removal Actions and building demolition activities at the GE-Pittsfield/Housatonic River Site. This area received approximately 110,500 cubic yards of materials from 2001 through 2006. (See below for more details on material placement requirements.) The area was filled to capacity and final capping was completed in 2006.

GE submitted a Final Completion Report for the Hill 78 and Building 71 OPCAs on September 15, 2011and EPA issued a Certificate of Completion to GE on September 26, 2011. GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities.

Pre-Construction actions and ancillary areas associated with the Hill 78 and Building 71 On-Plant Consolidation Areas (OPCAs) - The construction of the OPCAs was preceded by the demolition of Building 71, the demolition of a structure located along the western side of the Hill 78 OPCA, and the removal and/or abandonment of storm sewers associated with Building 71. Two stormwater basins were constructed to manage the flow of clean run-off water from the OPCAs. Approximately 60 cubic yards of soil with elevated PCBs were removed from the northern stormwater basin and placed in the Building 71 OPCA. Any other disturbed soil was used as backfill or in re-grading activities - no soil was transported off site for disposal.

In addition to the area associated with the placement of materials, the two stormwater basins encompass 1.1 acres and other support areas consist of 0.65 acre. Thus, the OPCA RAAs cover a total area of approximately 12.15 acres.

Hill 78 and Building 71 On-Plant Consolidation Areas (OPCAs) Placement Requirements - Certain materials generated during the performance of Removal Actions and building demolition debris were permanently consolidated at these two OPCAs. The materials generally included soils, sediments, and existing surface materials (e.g., asphalt, other debris) that were excavated or otherwise removed as part of the Removal Actions for each RAA and building demolition debris.

Specifically excluded from consolidation within the OPCAs were free liquids, free product, intact drums and capacitors, and other equipment that contains PCBs within its internal components, as well as asbestos-containing material required by applicable law to be removed from structures prior to demolition.

Materials consolidated within the Hill 78 OPCA were limited to materials that contained less than 50 ppm PCBs, on average, and were not classified as a hazardous waste under regulations issued pursuant to the Resource Conservation and Recovery Act (RCRA). Materials that contained more than 50 ppm PCBs or were classified as a hazardous waste under regulations issued pursuant to RCRA were allowed to be consolidated at the Building 71 OPCA. The Building 71 Consolidation Area was constructed with a bottom liner and a leachate collection system.

The final cap at both of the OPCAs was a multilayered cap consisting of an impermeable high-density polyethelyne (HDPE) liner, a geosynthetic drainage composite layer, eighteen inches of sand, and six inches of top soil with a vegetative cover.

Unkamet Brook Area - This approximately 140 acre area consists of the eastern portion of the GE facility. The area is bounded by Dalton Avenue to the north, Plastics Avenue and the Hill 78 Area - Remainder to the west, Merrill Road to the south and to the east by railroad tracks. This area also contains commercial/recreational property located between Merrill Road and the Housatonic River.

The GE-owned portion of this area located west of Unkamet Brook is mostly paved and covered with large buildings. The GE-owned portion of this area east of Unkamet Brook, as well as much of the land between Merrill Road and the Housatonic River, is undeveloped (except for the area associated with Building OP-3 and the commercial area along Merrill Road). The Former Interior Landfill is located in the northern portion of the Unkamet Brook Area. Unkamet Brook currently bisects the landfill, with the western portion overlain by the former GE Plastics parking lot, and the eastern portion of the landfill extending into the wetland. Administratively, this area has been split into two portions, with Unkamet Brook - West consisting of the industrial portions of the Area, and Unkamet Brook - Remainder including the Former Interior Landfill, Unkamet Brook, and associated wetland. In the Unkamet Brook - Remainder Area, the Consent Decree requires that the Brook be rerouted around the landfill, the landfill capped, and contaminated sediment and floodplain soil removed.

Sampling of this area per the requirements of the Consent Decree has been completed. GE submitted a Final RD/RA Work Plan for the Unkamet Brook - West area in June 2010 and a Revised Final RD/RA Work Plan for the Unkamet Brook - West area in April 2011. EPA conditionally approved these work plans in February and July 2011, respectively. For Unkamet Brook Area-Remainder, GE submitted a Conceptual RD/RA Work Plan in March 2009, and Work Plan Addenda in January and August 2010. EPA has conditional approved these submittals. A Final RD/RA Work Plan for the entire Unkamet Brook Area RAA is scheduled for submittal in 2012. Remediation is expected to begin in 2012 or 2013.

Groundwater - Groundwater associated with some of the areas discussed above required investigation, containment, monitoring, and in some cases, product recovery. Five groundwater plumes had been identified: GMA-1 (215 acres of primarily GE and non-GE owned land); GMA-2 (9 acres in former Oxbow J and K area); GMA-3 (103 acres in Unkamet Brook Area); GMA-4 (80 acres of primarily GE-owned land including the Hill 78 Area); and GMA-5 (7 acres in former Oxbow A and C area). Groundwater is not used as a source of drinking water within any of the five GMAs. The primary concern is to prevent contaminated groundwater from adversely affecting surface water, e.g. Unkamet Brook, Housatonic River, and Silver Lake. The monitoring programs have also included the evaluation of groundwater to ensure that vapors emitting from the groundwater do not pose a risk to occupants of nearby buildings. Any non-aqueous phase liquids (NAPL or product) contained within the GMAs are also being monitored and/or removed. Under terms of the Consent Decree, GE was required to sample each of the GMAs quarterly over a two year period (baseline sampling). This baseline sampling has been completed at all five of the GMAs. Results of the baseline sampling are used to establish a long-term groundwater monitoring program in each of the GMAs. These monitoring programs are recommended by GE and approved by EPA and MADEP. This has been done at GMAs 2 and 5, which are currently being monitored under long-term monitoring programs. GMAs 1, 3, and 4 are being monitored under an interim program until remedial work for soils is complete in these areas. Once this remedial work is complete, a long-term monitoring program will be implemented at these remaining GMAs. Additionally, groundwater in the area of the OPCAs is monitored at 12 wells on a semi-annual basis as part of the Post-Removal Site Control Plan for the OPCAs.

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