GE/Housatonic River Site in New England

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.

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.

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 work was completed in the Fall of 1999.

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 2009, along with associated bank soil removal.

Former Oxbow Areas

Former Oxbow Areas A and C

Former Oxbow Area A is approximately 5 acres in size and occupies a large open field on 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 oxbows. Former Oxbow Area C is approximately 2 acres in size and located immediately east 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. GE has completed the sampling as required in the Consent Decree and the Final Remedial Design/Remedial Action Work Plan was approved during 2006. The remedial action for this area was substantially completed in 2006. The final Consent Decree documentation designating this site as complete should be issued in 2008.

Lyman Street Area

This approximately 9-acre area is located immediately west of the East Street Area 2 - South area and is generally bounded by the Housatonic River to the south, East Street and several commercial/residential properties to the north, and Cove Street to the west. Approximately 3 acres of this area is composed of the GE-owned Lyman Street Parking Lot, which is paved. The remaining GE-owned portions of this area are partially paved and undeveloped. The non-GE-owned portions of this area consist of an undeveloped right of way for high tension electricity transmission lines (containing Former Oxbow Area E) and Former Oxbow Area B. Former Oxbow Area B is approximately 3 acres in size and located north of and across the Housatonic River from Former Oxbow Area C, west of Lyman Street, and immediately east of Cove Street. Nearly all of this former oxbow area is used for parking in support of local commercial businesses, although a building occupies a small portion of this area. The remaining portions are undeveloped. The Conceptual Remedial Design/Remedial Action report for this area is expected in 2004.

Newell Street Area I

This approximately 11-acre area is generally composed of 10 commercial/industrial properties and three recreational properties located along Newell Street. This area is bounded by the Housatonic River to the north, Newell Street to the south, the Hibbard School playground to the east (including the northwest corner of that playground within this area), and Ontario Street Extension and the GE-owned Newell Street Parking Lot to the west. The remedial action for this area was initiated in 2003 and substantially completed in 2006. The final Consent Decree documentation designating this site as complete should be issued in 2008.

Newell Street Area II

This approximately 8-acre area is located immediately west of Newell Street Area I and is generally bounded by the Housatonic River to the north, Newell Street and residential property to the south, and Sackett Street to the west. Approximately 3 acres of this area is composed of the GE-owned Newell Street Parking Lot, which is paved. The remaining GE-owned portions of this area are wooded. The non-GE-owned portions of this area consist of an undeveloped right of way for high tension electricity transmission lines, and undeveloped private property. The remedial action for this area was substantially completed in 2006. The final Consent Decree documentation designating this site as complete should be issued in 2008.

Former Oxbow Areas J and K

These areas are located approximately 2,500 feet upstream of the Newell Street bridge. Former Oxbow Area J measures approximately 4 acres in size, and is located on the north side of the Housatonic River near Fasce Place. Former Oxbow Area K occupies approximately 1 acre and is located on the south side of the Housatonic River across from Former Oxbow Area J near Ventura Avenue. While Former Oxbow Area K is undeveloped, Former Oxbow Area J is composed of residential property to the west and commercial property to the north along East Street. Remediation was conducted at the former Oxbow areas during 2006 and GE has submitted a draft Completion Report for the removal action.

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. This area includes the non-bank portions of approximately 35 residential properties along this reach, where such areas are located within the floodplain.

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, including Fred Garner Park. This area includes non-bank portions of approximately 11 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. Based on the results of sampling conducted by GE, EPA has agreed with GE that no additional action is required for the floodplain parcels between the Lyman and Dawes Street bridges. GE has initiated sampling of the flood plain properties between the Dawes and Pomeroy Street Bridges. This sampling is expected to be completed in 2004.

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.

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 GE Plant Area consists of approximately 250 acres including the following areas:

40s Complex

This approximately 9-acre area is located within the western portion of GE's Pittsfield facility and is generally bounded by Kellogg Street to the north, other areas of the GE facility to the south and east, and non-GE owned commercial/industrial areas to the west. The area is mostly paved (asphalt/concrete). Previously, Buildings 40-B, 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. Likewise, Buildings 42, 43, 43-A, and 44, which comprised much of eastern portion of the site, were demolished by May 2006. GE sampled the area as required in the Consent Decree and EPA has concurred with GE that no active remedial action is required in this area. GE is on target to complete minor activities related to building demolition activities in this area over the next two years. This 9-acre area of the facility is a component of the re-development agreement between GE and the City of Pittsfield.

30s Complex

This 15.75-acre area is located south of the 40s complex, and is generally bounded by Silver Lake Boulevard to the west, East Street to the south, and other areas of the GE facility to the south and east. The surface of this area is generally comprised of asphalt/concrete with some unpaved areas. GE has sampled as required in the Consent Decree and EPA has concurred with GE that no remedial action is required in this area. 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 of the facility is a component of the re-development agreement between GE and the City of Pittsfield and was transferred to PEDA on May 2, 2005.

20s Complex

This approximately 12-acre area is located immediately east of the 30s Complex within the western portion of the GE facility, and is generally bounded by East Street to the south and other areas of the GE facility to the north and east. This area includes a portion of Woodlawn Avenue. Current conditions within this area are predominantly characterized by the existing asphalt parking areas. Previously, these areas were associated with the 20s Complex buildings which have been demolished. GE has sampled as required in the Consent Decree and EPA has concurred with GE that no remedial action is required in this area. GE submitted a Final Completion Report on March 18, 2005 and EPA issued a Certificate of Completion to GE on March 28, 2005. A 10.21-acre portion of this area of the facility is a component of the re-development agreement between GE and the City of Pittsfield and was transferred to PEDA on May 2, 2005. GE retained ownership of the Woodlawn Avenue portion of this area.

East Street Area 2 - South

This area comprises 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 to the west. The western portion of this area is comprised mostly of the 60s Complex, and is otherwise mostly paved. The eastern portion of this area contains a former Housatonic River oxbow that was formed when the river meandered through this area. This area is currently characterized as mostly open areas, with a relatively small wooded area located south of the former oxbow. GE has completed the sampling as required in the Consent Decree and are evaluating the data to determine if remedial actions will be necessary. Addendums to the Conceptual Remedial Design/Remedial Action are due to EPA in late 2007. The Final Remedial Design/Remedial Action Work Plan should be completed in 2008, so that remedial action can begin in late 2008 or early 2009.

East Street Area 2 - North

This approximately 50-acre area is also located within the western portion of the GE facility. It is currently covered mostly with buildings and pavement. However, several relatively small grassy areas are present within the eastern portion of this area. 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 Merrill Road, the 20s Complex, and East Street Area 1 to the south. GE has completed the sampling as required in the Consent Decree and the Final Remedial Design/Remedial Action Work Plan was submitted and approved during 2007. Remediation is scheduled to be conducted during the end of 2007.

East Street Area 1 - North

This approximately 5-acre area is located immediately south of East Street Area 2 - North and east of the 20s Complex. This area is mostly unpaved, and is generally bounded by Merrill Road to the north and west, East Street to the south, and a non-GE owned commercial area to the east. This area also includes the area currently occupied by a commercial-use building (of which GE owns a portion), and a relatively small unpaved GE-owned property south of East Street, which contains a NAPL containment/recovery system. GE has sampled this area as required by the Consent Decree and has evaluated remedial requirements. GE has proposed, and EPA has concurred that no remedial action will be required for this area. The final Consent Decree documentation designating this site as complete was issued in 2005.

Hill 78 Consolidation Area

This 6-acre area is currently filled to approximately 80% of its capacity. It is located near the center of the GE facility. This area 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 and was capped in 1991 with a geotextile layer and either one foot of crushed stone or soil. This area has been utilized as an on-plant consolidation area for certain materials excavated or otherwise removed as part of various Removal Actions at the Pittsfield/Housatonic River Site. Approximately 3 acres of the area have been capped and it is anticipated that remaining capacity will be filled and final capping will occur during 2008.

Building 71 Consolidation Area

This approximately 5-acre area is also located within the central portion of the GE facility. It is located immediately to the east of the Hill 78 Consolidation Area. With the exception of the Building 71, this area is unpaved and is generally bounded by paved parking areas to the north and east, by the Hill 78 Consolidation Area to the west, and U.S. Generating Company facilities to the south. This area has been utilized as an on-plant consolidation area for certain materials excavated or otherwise removed as part of various Removal Actions at the Pittsfield/Housatonic River Site. The area was filled to capacity and final capping was completed in 2006.

Hill 78 Area - Remainder

The remaining portion of the Hill 78 Area comprises approximately 60 acres of the GE facility. These areas are generally bounded by the Tyler Street Extension to the north, Merrill Road to the south, New York Avenue and other areas of the GE facility to the west, and other areas of the GE facility to the east. With the exception of paved roadways associated with Building 78, and the U.S. Generating Company's cogeneration facility, the remaining areas of the Hill 78 Area are generally open. GE has conducted sampling of this area per the Consent Decree requirements and will be developing a Conceptual Remedial Design/Remedial Action Work Plan for submittal in early 2008.

Unkamet Brook Area

This approximately 140-acre area consists of the eastern portion of the GE facility and 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 to the south.

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 for Remedial Design and Remedial Action, 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.

Sampling of this area per the requirements of the Consent Decree will be completed in 2008. A Conceptual Remedial Design/Remedial Action Work Plan for soil cleanup in the Unkamet Brook - West Area is expected in 2009. 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. The Conceptual Remedial Design/Remedial Action Work Plan is expected in 2009.

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.