Site History and Description

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.

Rest of River Investigation

The Rest of River includes the area downstream of the 1 ½-Mile Reach, from the Confluence of the East and West Branches into Connecticut. EPA conducted an investigation of the Rest of River, focused on the collection of information for and preparing the Human Health and Ecological Risk Assessments, and development of the numerical model of PCB fate and transport in the river. Both of the risk assessments and three aspects of the modeling effort were subject to formal Peer Review, with the Peer Review of the Modeling Framework conducted in April 2001, the Human Health Risk Assessment in November 2003, and the Ecological Risk Assessment in January 2004, the Model Calibration Peer Review in May 2004, and the final Modeling Validation Peer Review in June 2006. Following the completion of the risk assessments, GE prepared a Supplemental RCRA Facility Investigation Report which was approved in September 2003, and submitted an Interim Media Protection Goals proposal (approved in 2006). Following completion of EPA’s modeling study, GE prepared the Corrective Measures Study Proposal, which, with subsequent submittals, was ultimately approved in August 2007, and the Corrective Measures Study, which was submitted in March 2008. Following its review of the Corrective Measures Study, which includes GE’s recommended alternative, and with consideration of public comment received, EPA will select the cleanup alternative (corrective measure[s]) for the Rest of River and propose the preferred alternative for public comment. After EPA finalizes the cleanup alternative following public comment, GE and/or the public can appeal EPA's decision.

Numerous studies have been conducted since 1988 by different parties, including EPA and GE, which document PCB contamination in sediment, floodplain soil adjacent to the river, and biota. A summary of PCB concentrations that have been observed historically or were collected by EPA in recent years is provided below.

Sediment:

The range of maximum and average PCB concentrations in river sediment, prior to the ½-Mile and 1½-Mile remediation, were up to 54,000 ppm in the ½ Mile in the vicinity of the Building 68 spill (average after the Building 68 sediment removal = 54.8 ppm), up to 8,635 ppm in the next 1½ miles (average = 25 ppm), and up to 614 ppm (average = 21 ppm) in the surface sediment in the Rest of River from the confluence to Woods Pond. Additionally, in the Woods Pond area, up to 668 ppm (average = 31 ppm) are present in surficial sediment. PCBs have also been detected in river sediments further downstream, as far as impoundments in Connecticut. Figure 1 presents the sediment total PCB concentrations by river mile from the GE Facility to Long Island Sound.

Figure 1 - Sediment tPCB Concentrations by River Mile from the GE Facility to Long Island Sound

Notes:

1. All data are plotted at the approximate mid-point of each reach, and represent samples collected from the top 3 feet of the riverbed.
2. 97 sediment samples with a tPCB concentration above 400 mg/kg were not plotted.
3. Symbols represent significant features/names of reach boundaries:
   GE = General Electric facility; WPD = Woods Pond Dam; RPD = Rising Pond Dam; GFD = Great Falls Dam; CB = Cornwall Bridge; BBD = Bulls Bridge Dam; BD = Bleachery Dam; SD = Shepaug Dam; STD = Stevenson Dam; DD = Derby Dam.

Floodplain Soil:

The historical and recently collected data indicate that the floodplain soil PCB contamination (exceeding 1 ppm total PCB) falls within the extent of the river's 10-year floodplain above Woods Pond. The maximum concentration detected in surface floodplain soil above Woods Pond is 874 ppm, with an average of 17 ppm. PCBs are also found in the floodplain south of Woods Pond. The contamination of floodplain soils downstream from the facility resulted from the redistribution of PCBs by river flooding and associated sediment transport.

Biota:

Representative results from the biota data collection efforts conducted are summarized below.

Numerous fish collection efforts have been conducted on the river over the years. In September 1994, 19 individual whole fish were collected with an average PCB concentration of 76 mg/kg/ww (3,378 mg/kg/lipid), and in May 1995, 17 individual whole fish were collected with an average concentration of 112 mg/kg ww (5,258 mg/kg/lipid). EPA also conducted a large-scale fish tissue sampling program in 1998, and smaller-scale sampling events in 1999 and 2000. More than 1,000 fish tissue samples have been collected from individual fish and composite samples of fish. Species of fish sampled include yellow perch, pumpkinseed, bluegill, golden shiner, goldfish, white sucker, carp, largemouth bass, smallmouth bass, brown bullhead, yellow bullhead, and fallfish. The mean tPCB concentrations in whole fish, in Reaches 5 and 6, is presented in Figure 2.

Waterfowl samples were collected by EPA from the vicinity of Woods Pond in August and September of 1998. Two species were collected, wood ducks and mallards, including both adults and immature birds, for a total of 25 birds from the river and 20 from a reference area. The birds collected on the river were primarily summer residents (based upon ongoing observations by project biologists and on the development of the immature birds), while the reference area birds were believed to have been transients (for the same reasons). Concentrations of PCBs in breast tissue (skin on) from river birds averaged 7.1 mg/kg ww (648 mg/kg lipid) and in liver tissue averaged 10.6 mg/kg ww (262 mg/kg lipid). Maximum concentrations were 19.4 (3700 mg/kg lipid) and 38.6 (985 mg/kg lipid), respectively.

Allendale School Property

The Allendale School Property is located to the north of the GE facility across the Tyler Street Extension, and is bordered on the other three sides by residential areas. The school building occupies approximately 40,000 square feet within a property of approximately 12 acres in size. In 1991, a 2-foot soil cap (with geotextile) was placed over much of the playground area by GE. In 1998, some soil outside the existing cap was found to contain PCBs exceeding 2 ppm and was removed by GE.

In July 1999, GE, pursuant to the Consent Decree, commenced a removal action for the Allendale School Property pursuant to an Action Memorandum issued by EPA on July 12, 1999. The removal action was conducted from July through November 1999 and consisted of the removal and disposal of approximately 41,700 cubic yards of material. GE's restoration activities included backilling, placement of topsoil and grass sod, reassembly of an existing playset, installation of a soccer field, installation of two baseball fields, construction of a walking track, and installation of a paracourse system. Restoration also included planting new shrubs and trees.

On February 18, 2000, GE submitted a Final Completion Report for the Allendale School Removal Action. EPA approved the Final Completion Report and issued a Certificate of Completion on July 17, 2000.

In December 2005, EPA initiated air sampling for PCBs at two locations on the school property, with samples coordinated to run concurrently with perimeter air sampling being conducted by GE at the OPCAs. EPA's air monitoring data is posted this web page.

In December 2007 and January 2008, GE conducted supplemental removal activities in a wetland located in the southeastern corner of the school property. This removal was based on new data collected by EPA. Approximately 1,700 cubic yards of soil were removed and transported to the Hill 78 OPCA, and the area was backfilled with clean soil and restored. The 1,700 cubic yards of material combined with the 41,300 cubic yards of material excavated and removed in 1999 results in a total of 43,000 cubic yards of material removed from the school property pursuant to the Consent Decree.

As a result of the cleanup under the Consent Decree, there are no use or soil handling restrictions on the school property. GE has completed their post-removal site control activities in 2000 and has no further inspection or maintenance requirements.

EPA continues to conduct periodic air sampling at the Allendale School property.

Silver Lake Sediment and Bank Soil

Silver Lake is located immediately to the west of and across Silver Lake Boulevard and includes the lake and its banks. Silver Lake has a surface area of approximately 26 acres and a maximum water depth of about 30 feet. It receives storm water contributions from several municipal outfalls, a portion of the PEDA property (via NPDES-permitted outfalls), and a number of non-GE-owned properties (both commercial and residential). Silver Lake is hydraulically connected to the Housatonic River by a 48-inch diameter concrete conduit located near the intersection of Fenn Street and East Street. This conduit conveys intermittent discharge from Silver Lake and storm water runoff from Fenn Street and East Street to the Housatonic River.

The Consent Decree requires that GE dredge 400 cyds of "hot spot" sediment adjacent to one of the historic GE outfalls, clean up contaminated bank soil, and place a cap on the entire bottom of the lake. Bench-Scale Testing and a 1-acre Pilot Study of capping techniques were completed in 2006. Sampling of bank soil will be completed in 2008. Full-scale capping of the Lake is expected to begin in 2011, along with associated bank soil removal.

Former Oxbow Areas

During the late 1930s and early 1940s, a portion of the Housatonic River in Pittsfield was rechannelized by the City (with the help of the Army Corps of Engineers) to straighten that stretch of the river for flood control purposes. The rechannelization process isolated former bends in the old river channel, creating a number of oxbows. These ponded or swampy oxbow areas were subsequently backfilled with various materials, including some industrial wastes from GE. A total of 11 former oxbow areas were identified near the GE facility in Pittsfield. One of the 11 former oxbows, Former Oxbow H, is located within the GE Plant Area, in the East Street Area 2 - South Removal Action Area (RAA). The other 10 Former Oxbows are located within the five RAAs described below.

Investigation and remediation activities have been completed at all five of these RAAs. Remediation activities were initiated in September 2003 and were completed in June 2009. For the five RAAs, a total of 48,705 cubic yards of soil were removed, 355,850 square feet (approximately 8.2 acres) of engineered barriers were installed, and 598 drums of waste were transported off-site for disposal. Approximately 6,015 cubic yards of the excavated soil was disposed of in the Hill 78 On-Plant Consolidation Area, approximately 35,940 cubic yards of soil was disposed of in the Building 71 On-Plant Consolidation Area and the remaining 6,750 cubic yards of soil was disposed of at licensed off-site disposal facilities. In addition, the demolition debris from two buildings was placed in the Building 71 On-Plant Consolidation Area.

GE has submitted Final Completion Reports for all five of these RAAs. EPA has approved all Final Completion Reports and has issued Certificates of Completion for all five RAAs. GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities, as required by the Final Completion Reports.

Former Oxbow Areas A and C

This Removal Action Area (RAA) occupies approximately 8 acres on seven privately-owned parcels, beginning approximately 250 ft downstream of the Lyman Street bridge, and includes two former bends in the river channel, Oxbows A and C, that were filled as described above. Former Oxbow Area A occupies a large open field along the south side of the Housatonic River, north of Elm Street and Newell Street. The majority of this area is undeveloped and covered with grass and low brush, although commercial businesses occupy a portion of the parcels containing the former Oxbow Area A. Former Oxbow Area C is located immediately northeast of Former Oxbow Area A, along the south side of the Housatonic River, near the end of Day Street. This area consists mostly of an undeveloped field surrounded by trees and brush. The Former Oxbow Areas A&C RAA does not include the banks of the Housatonic River. The banks of the river along this RAA are included in the 1½-Mile Reach Removal Action.

GE sampled this RAA in accordance with the Consent Decree and EPA-approved Pre-Design Investigation Work Plans. GE submitted Conceptual and Final Removal Design/Removal Action Work Plans and a series of addendums, revisions, and supplements from January 2005 through October 2006.

The remediation approved by EPA in the aforementioned Work Plans, and conducted by GE at this RAA, primarily consisted of the removal and proper disposal of 5,985 cubic yards of soil, and the backfilling and restoration of the affected areas. These activities were primarily conducted between July and November 2006. In May 2008, GE submitted a Final Completion Report and certified that all actions required by the Consent Decree (excluding Post-Removal Site Control Activities) were completed and that the soil-related Performance Standards were attained. On May 21, 2008, Massachusetts DEP sent a letter to EPA concurring that GE completed all actions required by the Consent Decree (excluding Post-Removal Site Control Activities). On June 3, 2008, EPA issued GE a Certificate of Completion for the Former Oxbows A & C RAA and transmitted the Certificate of Completion to GE, along with an approval letter for GE's Final Completion Report.

GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities, as required by the Final Completion Report.

Lyman Street Area

This Removal Action Area (RAA) occupies approximately 17.5 acres and generally bounded by the Housatonic River banks to the south, the East Street Area 2-South RAA to the east, East Street and several commercial properties to the north, and Cove Street to the west. Lyman Street bisects the RAA into two areas. The portion of the RAA east of Lyman Street consists of the GE-owned former Lyman Street parking lot, which was historically paved, and an undeveloped parcel owned by Western Massachusetts Electric Company that has high tension electricity transmission lines. Former Oxbow Area D underlies the GE-owned former parking lot and Former Oxbow Area E is located within the Western Massachusetts Electric Company property. The portion of the RAA located west of Lyman Street consists of recreational and commercial properties and is where Former Oxbow Area B is located.

The Lyman Street RAA does not include the banks of the Housatonic River. The banks of the river east of Lyman Street are included in the Upper ½-Mile Reach Removal Action and the banks of the River west of Lyman Street are included in the 1½ Mile Reach Removal Action.

GE sampled this RAA in accordance with the Consent Decree and EPA-approved Pre-Design Investigation Work Plans. GE submitted a Conceptual Removal Design/Removal Action Work Plan in March 2004, a supplement to the Conceptual Removal Design/Removal Action Work Plan in January 2005, an Addendum to the Conceptual Removal Design/Removal Action Work Plan in May 2005, a Final Removal Design/Removal Action Work Plan in September 2005 and an Addendum to the Final Removal Design/Removal Action Work Plan in April 2006. EPA conditionally approved all of these Work Plans.

The remediation activities for this RAA were conducted in two phases. GE performed the remediation and restoration activities at the properties west of Lyman Street between August and September 2006. This included the removal and proper disposal of 3,260 cubic yards of soil, and the backfilling and restoration of the affected areas. GE performed the remediation and restoration activities at the properties east of Lyman Street primarily between May and November 2007. Final restoration activities were completed on June 13, 2008. Remediation activities east of Lyman Street included the removal and proper disposal of 830 cubic yards of soil, the installation of 133,260 square feet of a vegetated engineered barrier, and the backfilling and restoration of the affected areas. For the entire RAA, GE removed and properly disposed of 4,090 cubic yards of soil and installed 133,260 square feet of a vegetated engineered barrier.

In August 2009, GE submitted a Final Completion Report and certified that all actions required by the Consent Decree (excluding Post-Removal Site Control Activities) were completed and that the soil-related Performance Standards were attained. On September 10, 2009, Massachusetts DEP sent a letter to EPA concurring that GE completed all actions required by the Consent Decree (excluding Post-Removal Site Control Activities). On September 14, 2009, EPA issued GE a Certificate of Completion for the Lyman Street Area RAA and transmitted the Certificate of Completion to GE, along with an approval letter for GE's Final Completion Report.

GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities, as required by the Final Completion Report.

Newell Street Area II

This Removal Action Area (RAA) occupies approximately 8 acres and is generally bounded by the Housatonic River to the north, Newell Street and residential properties to the south, Sackett Street to the west, and the Newell Street Area I RAA to the east. The RAA consists of land that included Former Oxbows F and G and low-lying areas associated with the Housatonic River that were filled as described above. Approximately 3 acres of this RAA is composed of the GE-owned former Newell Street Parking Lot, which was historically paved, and is where Former Oxbow G is located. The remaining GE-owned portions of this RAA are undeveloped. The non-GE-owned portions of this RAA consist of a City-owned parcel where a stormwater drain is located, two undeveloped parcels owned by the Western Massachusetts Electric Company that has high-tension electricity transmission lines (and is where Former Oxbow F is located), one other undeveloped property, and portions of undeveloped Vermont and Ontario Streets. The Newell Street Area II RAA does not include the banks of the Housatonic River. The banks of the river along this RAA are included in the Upper ½-Mile Reach Removal Action.

GE sampled this RAA in accordance with the Consent Decree and EPA-approved Pre-Design Investigation Work Plans and supplements. GE submitted Conceptual and Final Removal Design/Removal Action Work Plans and a series of addendums, revisions, and supplements from July 2004 through April 2009, all of which EPA conditionally approved.

The original Work Plan documents called for soil removal and installation of a vegetative engineered barrier; however, due to the discovery of buried drums and capacitors during soil excavation activities, additional investigations and removal activities were conducted during which discernible containers and associated soil were excavated. Remedial activities for the RAA were initiated in July 2005 and were substantially completed in June 2006. Minor remediation activities were also performed on the undeveloped portions of Ontario and Vermont Streets in June 2009. A total of 155,750 square feet of engineered barrier was installed and 21,865 cubic yards of soil was removed, including 17,750 cubic yards generated pursuant to the original Work Plans and 4,115 cubic yards generated during the supplemental container removal activities. Additionally, 461 overpack drums were transported off site for disposal, including 89 with liquid-filled drums and 372 with intact capacitors that contained liquids.

In October 2009, GE submitted a Final Completion Report and certified that all actions required by the Consent Decree (excluding Post-Removal Site Control Activities) were completed and that the soil-related Performance Standards were attained. On November 18, 2009, Massachusetts DEP sent a letter to EPA concurring that GE completed all actions required by the Consent Decree (excluding Post-Removal Site Control Activities). On November 23, 2009, EPA issued GE a Certificate of Completion for the Newell Street Area II RAA and transmitted the Certificate of Completion to GE, along with an approval letter for GE's Final Completion Report.

GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities, as required by the Final Completion Report.

Newell Street Area I

This Removal Action Area (RAA) occupies approximately 11 acres on ten commercial/industrial properties and three recreational properties located along Newell Street. The RAA consists of land that includes Former Oxbow I and low-lying areas associated with the Housatonic River that were filled as described above. The RAA is generally bounded by the Housatonic River to the north, Newell Street to the south, the Hibbard School playground to the east (also known as the Lakewood Playground, note that the northwest corner of that playground falls within this RAA), and Ontario Street Extension and the GE-owned former Newell Street Parking Lot (Newell Street Area II) to the west. The Newell Street Area I RAA does not include the banks of the Housatonic River. The banks of the river along this RAA are included in the Upper ½-Mile Reach Removal Action.

Sampling of this area was completed in accordance with the requirements of the Consent Decree and EPA-approved Pre-Design Investigation Work Plans and supplements. GE submitted Conceptual and Final Removal Design/Removal Action Work Plans from January 2002 to June 2004, all of which EPA conditionally approved.

The remediation approved by EPA in the aforementioned Work Plans, and conducted by GE at this RAA, primarily consisted of the removal and proper disposal of 14,810 cubic yards of soil and installation of 66,840 square feet of engineered barrier. Two buildings were on GE-owned parcels were demolished and the building demolition debris was disposed at the Building 71 On-Plant Consolidation Area. In addition, 137 drums of waste, including liquid fill drums and intact capacitors with liquid contents, were disposed of at licensed off-site disposal facilities. These activities were primarily conducted from September 2003 through June 2006. Minor remediation activities were also performed on one parcel from November 7 to November 9, 2007. In July 2008, GE submitted a Final Completion Report and certified that all actions required by the Consent Decree (excluding Post-Removal Site Control Activities) were completed and that the soil-related Performance Standards were attained. On August 21, 2008, Massachusetts DEP sent a letter to EPA concurring that GE completed all actions required by the Consent Decree (excluding Post-Removal Site Control Activities). On August 27, 2008, EPA issued GE a Certificate of Completion for the Newell Street Area I RAA and transmitted the Certificate of Completion to GE, along with an approval letter for GE's Final Completion Report.

GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities, as required by the Final Completion Report.

Former Oxbow Areas J and K

This Removal Action Area (RAA) is located approximately 2,500 feet upstream of the Newell Street bridge (which marks the upstream end of the Upper ½-Mile Reach). The Former Oxbow J component of the RAA is approximately 6 acres in size, and is located along the north side of the Housatonic River, south of East Street, and between Fasce Place and Commercial Street. Former Oxbow Area J is composed of both recreational and commercial properties. The Former Oxbow K component of the RAA encompasses approximately 2 acres and is located along the south side of the Housatonic River across from Former Oxbow Area J, near Ventura Avenue. Former Oxbow Area K consists of undeveloped recreational properties and one residential property (that consists of two tax ID parcels). Both the riverbank and non-riverbank portions of the affected parcels are included within this RAA.

GE sampled this RAA in accordance with the Consent Decree and EPA-approved Pre-Design Investigation Work Plans. GE submitted a Conceptual Removal Design/Removal Action Work Plan in March 2005, a Final Removal Design/Removal Action Work Plan in September 2005 and an Addendum to the Final Removal Design/Removal Action Work Plan in April 2006. EPA conditionally approved all of these Work Plans. Between July and November 2006, in accordance with the EPA-approved Work Plans, GE performed the required remediation and restoration activities, which included the removal and proper disposal of 1,955 cubic yards of soil.

In May, 2008, GE submitted a Final Completion Report and certified that all actions required by the Consent Decree (excluding Post-Removal Site Control Activities) were completed and that the soil-related Performance Standards were attained. On May 21, 2008, Massachusetts DEP sent a letter to EPA concurring that GE completed all actions required by the Consent Decree (excluding Post-Removal Site Control Activities). On June 3, 2008, EPA issued GE a Certificate of Completion for the Former Oxbows J & K RAA and transmitted the Certificate of Completion to GE, along with an approval letter for GE's Final Completion Report.

GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities, as required by the Final Completion Report.

Housatonic River Floodplain

Floodplain Current Residential Properties Adjacent to 1½-Mile Reach - Actual/Potential Lawns

The 1½-Mile Reach is defined by the Lyman Street bridge (upstream) and the confluence with the West Branch (downstream). This area includes the non-bank portions of approximately 37 residential properties along this reach, where such areas are located within the floodplain. The riverbank and river bottom portion of these properties are excluded from the RAA and were remediated pursuant to the 1½ Mile Reach Removal Action. GE conducted remediation and restoration activities at 27 of the 37 properties between June of 2005 and October 2007. This consisted of the removal and proper disposal of 10,810 cubic yards of soil. The remaining 10 properties did not require soil remediation to meet the residential Performance Standards.

In July 2008, GE submitted a Final Completion Report and certified that all actions required by the Consent Decree (excluding Post-Removal Site Control Activities) were completed and that the soil-related Performance Standards were attained. On August 27, 2008, EPA issued GE a Certificate of Completion for the Floodplain Current Residential Properties Adjacent to 1½-Mile Reach- Actual/Potential Lawns RAA and transmitted the Certificate of Completion to GE, along with an approval letter for GE's Final Completion Report.

GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities, as required by the Final Completion Report.

Floodplain Non-Residential Properties Adjacent to 1½-Mile Reach (Excluding Banks)

As noted above, the 1½-Mile Reach is defined by the Lyman Street bridge (upstream) and the confluence with the West Branch (downstream), including Fred Garner Park. This area includes non-bank portions of approximately 10 non-residential properties along this reach where such portions are located within the floodplain. Excluded from this area are those properties associated with the Former Oxbow Areas. In addition, the riverbank and river bottom portion of these properties are excluded from the RAA and were remediated pursuant to the 1½ Mile Reach Removal Action.

GE conducted remediation and restoration activities at six of the ten properties between May 2006 and October 2007. This consisted of the removal and properly disposed of 3,375 cubic yards of soil. The remaining four properties did not require soil remediation to meet the applicable Performance Standards.

In April 2010, GE submitted a Final Completion Report and certified that all actions required by the Consent Decree (excluding Post-Removal Site Control Activities) were completed and that the soil-related Performance Standards were attained. On May 17, 2010, EPA issued GE a Certificate of Completion for the Floodplain Non-Residential Properties Adjacent to 1½-Mile Reach (Excluding Banks) RAA and transmitted the Certificate of Completion to GE, along with an approval letter for GE's Final Completion Report.

GE is currently performing all required Post-Removal Site Control Activities, including inspection, monitoring and maintenance activities, as required by the Final Completion Report.

Floodplain Residential Properties Downstream of Confluence - Actual/Potential Lawns

This area begins at the confluence with the West Branch and extends downriver. This area includes, with some exceptions, residential properties located within the floodplain: approximately 12 residential properties between the confluence and Woods Pond Dam, and other residential properties downstream of Woods Pond Dam. Remediation of these properties is currently anticipated to be performed concurrent to Rest of River remediation activities, if any.

Floodplain Non-Residential Properties Downstream of Confluence

Non-residential floodplain properties downstream of the confluence are considered part of the Rest of River area of the site, and are discussed above under Rest of River Investigations.

GE Plant Site

The General Electric (GE) Plant Area encompasses approximately 320 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 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 retained ownership of the Woodlawn Avenue portion of this area, although it is anticipated that Woodlawn Avenue will be transferred to PEDA in the future.

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 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. The remediation is currently ongoing and is anticipated to be completed in spring or summer 2011.

East Street Area 2 - North

This area encompasses 50 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, 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 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, which is targeted to be transferred to PEDA, 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 825 cubic yards of soil. All of the soil removal was performed in the eastern portion of the RAA.

From 2005 through 2009, GE demolished all of the buildings on the 17-acre western portion of the RAA that is designated to be transferred to PEDA.

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 2011 and transfer of land to PEDA is expected in 2012.

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.  

Hill 78 Area - Remainder

This area encompasses approximately 30 acres 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 – South) to the west, and other areas of the GE facility (Unkamet Brook Area) to the east.  The area excludes the Hill 78 and Building 71 On-Plant Consolidation Areas (OPCAs) discussed below.   GE’s Building 78 and a co-generation facility are located within this RAA.   With the exception of paved roadways associated with Building 78 and the cogeneration facility, the remainder of the RAA is generally unpaved and partially tree-covered.

GE has completed the sampling as required in 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 November and December 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 940 cubic yards of soil. 

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 2011.

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 bordered to the east by the Building 71 OPCA.  The Hill 78 OPCA includes the former Hill 78 landfill, which was originally created in the early 1940s as an on-site disposal area for excavated soils generated within the GE facility.  A temporary cap consisting of a geotextile layer and either one foot of crushed stone or soil was installed on the Hill 78 landfill in 1991.  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 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 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 2011.

Building 71 On-Plant Consolidation Area (OPCA)

This approximately 5 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 materials from 2001 through 2009. (See below for more details on material placement requirements.) The area was filled to capacity and final capping was completed in 2006.

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 the Final RD/RA Work Plan for the Unkamet Brook - West area in June 2010. The Final RD/RA Work Plan for the Unkamet Brook - Remainder Area is scheduled for submittal in late 2010. Remediation is expected to begin in 2011 or 2012.

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 interim program for GMA-3. This groundwater monitoring around the OPCAs will continue until GE submits and EPA approves of a long-term monitoring program for the OPCAs and GMA-3.