FIVE-YEAR REVIEW REPORT FOR
F.T. ROSE DISPOSAL PIT SUPERFUND SITE
LANESBOROUGH, MA
Superfund Records Center
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Prepared by
U.S. Environmental Protection Agency
Region 1
BOSTON, MA
'antes T. Owens HI, Division Director Date
sdms docid 564572
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TABLE OF CONTENTS
EXECUTIVE SUMMARY: 1
I. INTRODUCTION 5
II. PROGRESS SINCE THE LAST FIVE YEAR REVIEW 8
III. FIVE YEAR REVIEW PROCESS 12
IV. TECHNICAL ASSESSMENT 17
V. ISSUES/RECOMMENDATIONS AND FOLLOW-UP ACTIONS 26
VI. PROTECTIVENESS STATEMENT 26
VII. NEXT REVIEW 26
FIGURES
Figure 1-1 Site Locus Plan
Figure 1-2 Site Plan
TABLES
Table 2-1: Protectiveness Determinations/Statements from the 2009 FYR
Table 2-2: Status of Site-wide Recommendations from the 2009 FYR
Table 2-3: Summary of Planned and/or Implemented ICs
Table 3-1: 1988 ROD Cleanup Goals and Potential Updates
Table 4-1: Comparison of 1988 and 2009 ROD-Specified Numerical, Chemical-Specific
ARARs and Criteria for Surface Water Chemicals of Concern
Table 4-2: Comparison of 1988 and 2009 ROD-Specified Numerical, Chemical-Specific
ARARs, and Criteria for Groundwater Chemicals of Concern with Current Standards
and Criteria
Table 4-3: Comparison of 1988, 2004, and 2009 Toxicity Values
APPENDICES
Appendix A: Existing Site Information and Site Chronology
Appendix B: Site Photos
Appendix C: Site Inspection Checklist
Appendix D: Interview Notes
Appendix E: O&M Tracking Sheet and Log Entry
Appendix F: Agreement between GE and the DCR
Appendix G: Annual GERE Inspection Checklist
Appendix H: Additional Figures for Reference
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LIST OF ACRONYMS
ARAR
Applicable or Relevant and Appropriate Requirement
CD
Consent Decree
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
COC
Chemicals of Concern
DCR
Massachusetts Department of Conservation and Recreation
DEP
Massachusetts Department of Environmental Protection
EPA
United States Environmental Protection Agency
FYR
Five-Year Review
GE
General Electric
GERE
Grant of Environmental Restriction and Easement
ICs
Institutional Controls
MCL
Maximum Contaminant Level
MCLG
Maximum Contaminant Level Goal
NCP
National Contingency Plan
NPL
National Priorities List
O&M
Operation and Maintenance
OSRR
Office of Site Remediation and Restoration
PCB
Polychlorinated biphenyl
PRP
Potentially Responsible Party
RAO
Remedial Action Objective
ROD
Record of Decision
RPM
Remedial Project Manager
TCE
Trichoroethene
VI
Vapor Intrusion
VOC
Volatile Organic Compound
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EXECUTIVE SUMMARY
The F. T. Rose Disposal Pit Superfund Site (the Site) is located on Balance Rock Road in
Lanesborough, Massachusetts, and is approximately one-half mile from the town of Pittsfield,
Massachusetts (Figure 1-1). The property was used for the disposal of waste oils and solvents
from General Electric Company (GE), the Settling Defendant, as early as the 1950s and possibly
later. The one and one-half acre disposal area occupies the northern section of what was at the
time an approximate 12.5-acre residential lot. The disposal area was formerly a trench where
waste oils and solvents were dumped. In December 2008, GE purchased the remaining 2.7 acres
of the Site and now owns the entire Site (approximately 12.5 acres), with the exception of the 5.7
acres where the eastern collection trench and several monitoring wells are located in Balance
Rock State Park (shown in Figure 1-2), which includes the former trench disposal area, and the
former Rose residence which occupied a small section with frontage along Balance Rock Road
(Figure 1-2). GE demolished the Rose residence located on the Site in July 2009.
Polychlorinated biphenyls (PCBs) in soils and groundwater and volatile organic compounds
(VOCs) in groundwater are the principal contaminants at the Site.
In September 1988, the U.S. Environmental Protection Agency (EPA) signed a Record of
Decision (ROD) for the Site. The selected remedy included both a source control and a
management of migration component, as well as institutional controls. In September 1988, GE
entered into a Consent Decree (CD) with EPA to perform the work required to implement the
selected remedy. The excavation and incineration of soil was initiated in July 1992 and
completed in July 1994. Treatment of contaminated groundwater is ongoing.
The source control component of the remedy consisted of the excavation and on-site incineration
of contaminated soil and sediments, primarily above the water table, with limited excavation in
the saturated zone to remove subsurface free product. A soil cover was then installed to prevent
any potential direct contact with the remaining PCBs in the saturated zone.
The management of migration component of the remedy consists of on-site treatment of the
groundwater in the overburden aquifer to drinking water standards, and removal of free product
from a bedrock well. Additionally, sediments and surface water in Rose's pond and the
subsequent restoration of the pond to its original wetlands character after its remediation was
conducted.
The institutional controls (IC) component of the remedy consisted of implementing a Grant of
Environmental Restriction and Easement (GERE), recorded in March 2010. The GERE restricts
the use of groundwater, prohibits excavation in the saturated zone, prohibits residential use; day
care, educational activity or use; community activity or use; agricultural activity or use; use as a
park; or any use that would interfere with the implementation of the remedy; and requires
maintenance of the soil cover and approval from EPA and the State prior to site development.
In addition, an agreement is in place between GE and the Massachusetts Department of
Conservation and Recreation (DCR) that allows the eastern trench and several monitoring wells
to be located on 5.7 acres of the adjacent Balance Rock Park property and allows GE access to
monitor and maintain the trench and the monitoring wells also located on Park property. The
manhole, ECT-MH and pump controls are protected by a chain-link fence surrounding the
manhole with an appropriate warning sign mounted on the fence.
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This agreement constitutes an IC component that ensures protection of this trench and wells, and
prohibits the use of groundwater from this portion of the Site. This IC component shall be
reaffirmed on an annual basis by a letter from GE to DCR (see Appendix F).
This is the fourth Five-Year Review (FYR) for the Site. The third FYR was completed in
September 2009, and that date was the trigger for this review. An initial FYR was conducted in
1999. The FYR is required because hazardous substances, pollutants, or contaminants remain at
the Site above levels that allow for unlimited use and unrestricted exposure.
This FYR concluded that the remedy is functioning as designed and continues to be protective of
human health and the environment since groundwater is not currently used, access to the disposal
area is fenced and the area is covered with topsoil and vegetation, and institutional controls have
been implemented that restricts residential, agricultural, and other designated uses of the Site,
utilization of groundwater, and any use that may interfere with the remedy. In order to provide
an IC to restrict groundwater use and any use that may interfere with the remedy on the portion
of the Site located on Balance Rock State Park property, GE shall be required to annually
reaffirm an agreement with DCR that establishes these restrictions.
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Five-Year Review Summary Form
SITE IDENTIFICATION
Site Name: Rose Disposal Pit
EPA ID:
MAD980524169
Region: 1
State: MA
City/County: Lanesborough/Berkshire County
Lead agency: EPA
[If "Other Federal Agency", enter Agency name]'. Click here to enter text.
Author name (Federal or State Project Manager): Richard Fisher
Author affiliation: U.S. EPA Region I
Review period: 1/30/2014 - 9/30/2014
Date of site inspection: 6/5/2014
Type of review: Statutory
Review number: 4
Triggering action date: 9/29/2009
Due date (fiveyears after triggering action date): 9/29/2014
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Five-Year Review Summary Form (continued)
Issues/Recommendations
OU(s) without Issues/Recommendations Identified in the Five-Year Review:
Sitewide
Sitewide Protectiveness Statement
Protectiveness Determination: Addendum Due Date (if applicable):
Protective Click here to enter a date.
Protectiveness Statement:
The remedy at the F. T. Rose Disposal Pit Superfund Site is protective of human health and the
environment because: access to the Site is restricted through fencing; surficial contamination
has been removed; soils in the saturated zone exceeding the PCB cleanup levels have a soil
cover in place to prevent dermal contact; the only residence on the site has been demolished;
and ICs are in place at the Site to prevent activities and uses that could present a risk. These
ICs include the restriction of: excavation into the disposal area; extraction and use of
groundwater; and uses such as residential, agricultural, and recreational. With the availability
of public water, the groundwater is not being used and ongoing treatment, management of
migration, and monitoring of contamination will continue until MCLs are met.
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I. INTRODUCTION
The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of
a remedy in order to determine if the remedy will continue to be protective of human health and
the environment. The methods, findings, and conclusions of reviews are documented in FYR
reports. In addition, FYR reports identify issues found during the review, if any, and document
recommendations to address them.
The U.S. Environmental Protection Agency (EPA) prepares FYRs pursuant to the
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section
121 and the National Contingency Plan (NCP). CERCLA 121, which state:
"If the President selects a remedial action that results in any hazardous substances,
pollutants, or contaminants remaining at the site, the President shall review such
remedial action no less often than each five years after the initiation of such remedial
action to assure that human health and the environment are being protected by the
remedial action being implemented. In addition, if upon such review it is the judgment of
the President that action is appropriate at such site in accordance with section [104] or
[106], the President shall take or require such action. The President shall report to the
Congress a list offacilities for which such review is required, the results of all such
reviews, and any actions taken as a result of such reviews. "
EPA interpreted this requirement further in the NCP; 40 Code of Federal Regulations (CFR)
Section 300.430(f)(4)(ii), which states:
"If a remedial action is selected that results in hazardous substances, pollutants, or
contaminants remaining at the site above levels that allow for unlimited use and
unrestricted exposure, the lead agency shall review such actions no less often than every
five years after the initiation of the selected remedial action."
EPA conducted a FYR on the remedy implemented at the F.T. Rose Disposal Pit Superfund Site
in Lanesborough, Berkshire County, MA. EPA is the lead agency for developing and
implementing the remedy for the Site. Massachusetts Department of Environmental Protection
(DEP), as the support agency representing the State of Massachusetts, has reviewed all
supporting documentation and provided input to EPA during the FYR process.
This is the fourth FYR for the F.T. Rose Disposal Pit Superfund Site. The triggering action for
this statutory review is the completion date of the previous FYR, September 2009. The FYR is
required because hazardous substances, pollutants, or contaminants remain at the site above
levels that allow for unlimited use and unrestricted exposure. The Site consists of one Operable
Unit, which is addressed in this FYR.
Appendix A of this FYR includes existing Site information and a table (Table 1) of the
chronological events that have taken place at the Site. Appendix B provides current photographs
of the Site.
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Figure 1-1 Site Locus Plan
LIRftS TOWieftAPHIC M*P
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pirrsiELD. Massachusetts 1 inch = ?/xx feet
NOFTH 1>M
FIGURE 1-1
LOCUS PLAN
F.T. HOSE DISPOSAL PUT SUPERFUND SOT
BALANCE ROCK ROAD
LANESaOROUGH, hiASSACHUSETTS
PROJECT; BOO 44.08
SEPTEMBER 20SB
ouwrwcle iownw<
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Figure 1-2 Site Plan
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II. PROGRESS SINCE THE LAST FIVE YEAR REVIEW
Table 2-1: Protectiveness Determinations/Statements from the 2009 FYR
ou#
Protectiveness
Determination
Protectiveness Statement
Sitewide
Protective
The remedy at the F. T. Rose Disposal Pit
Superfiind Site currently protects human health and
the environment because access to the disposal area
of the Site is restricted through fencing to prevent
excavation into the disposal area. With the
availability of public water, the groundwater is not
being used and ongoing management of migration
and groundwater monitoring will continue until
MCLs are met. In addition, soils in the saturated
zone exceeding the PCB cleanup levels have a soil
cover in place to prevent dermal contact and the
only residence on the Site has been demolished.
However, in order for the remedy to be protective in
the long term, institutional controls to prevent
groundwater use are required. Institutional controls
are also required for the disposal area to prevent
excavation in this area. These controls will also
prohibit residential use and require approval from
EPA and the State prior to any site development.
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Table 2-2: Status of Sitewide Recommendations from the 2009 FYR
Issue
Recommendations/
Follow-up Actions
Party
Responsible
Oversight
Agency
Original
Milestone
Date
Current
Status
Completion
Date
Although GE currently owns the
entire Site and maintains the
fencing and provides security,
legally enforceable Institutional
Controls are not yet in place.
Institutional Controls are required
to provide long-term protectiveness
Complete execution and recording of the GERE which
will implement institutional controls to prevent
groundwater use and excavation into the saturated zone
within the disposal area. Institutional controls will
include additional restrictions to prevent residential use
of the Site, require approval from EPA and the State
prior to Site development, and maintenance of the soil
cover at the Site. The GERE will include provisions for
inspection of the soil cover at the site as part of the site
inspection checklist to ensure no disturbance to the soil
cover in the disposal area. An institutional control is
also necessary on the Balance Rock Park property to
ensure the integrity of the eastern trench and associated
monitoring well located on that property.
PRP
EPA
September
2010
Complete
July 2014
While not an issue in the area
downgradient of the Site, VOCs
are currently present above current
vapor intrusion screening values in
the overburden groundwater within
and around the disposal area.
Because VOCs are generally not detected above vapor
intrusion screening levels at wells located further
downgradient or beyond the Site perimeter toward any
potential off-site receptor this potential pathway has
been determined to be currently incomplete. The
continuing groundwater monitoring is in place to assure
that groundwater with contamination above standards
is confined to the former disposal area on the Site, and
that this pathway remains incomplete.
PRP
EPA
N/A
Complete
June 2014
There have been changes to MCLs
and other health-based cleanup
standards and surface water quality
standards since the last five year
review.
Evaluate and issue, if necessary, a future decision
document to note change in MCLs, surface water
quality standards, and reasonably anticipated future
land use (no longer for residential purposes).
PRP
EPA
September
2010
Complete
May 2014
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The following statements provide follow-up commentary to the recommendations made in the last FYR.
Recommendation 1
• The Grant of Environmental Restriction and Easement (GERE) was recorded in March 2010.
The GERE restricts the use of groundwater, prohibits excavation in the saturated zone, prohibits
residential use; day care, educational activity or use; community activity or use; agricultural
activity or use; use as a park; or any use that would interfere with the implementation of the
remedy; and requires maintenance of the soil cover and approval from EPA and the State prior to
site development. The GERE requires GE to annually inspect the Site to ensure that the
provisions of the GERE are being met (see most recent annual inspection checklist in Appendix
G). In addition, an agreement (see Appendix F) is in place between GE and the DCR that
allows the eastern trench and several monitoring wells to be located on 5.7 acres of the adjacent
Balance Rock Park property and allows GE access to monitor and maintain the trench and the
monitoring wells also located on Park property as well as prohibits the use of groundwater from
this portion of the Park property. This IC component of the remedy shall be reaffirmed on an
annual basis by a letter from GE to DCR.
Recommendation 2
• GE has performed a VI assessment for ten monitoring events beginning with the Fall 2009 Semi-
Annual Report. The VI Screening levels were exceeded at three well locations (W-5, WCT-1,
MW-6) on the periphery of the source area, however, the remaining data indicates that the
contamination is not migrating beyond the interceptor trenches, and subsequently off site, in the
direction of potential receptors at these levels. The ongoing VI evaluation will be discontinued
because the potential vapor exposure pathway is considered incomplete based on other
monitoring well data and the location of potential receptors. ICs have been recorded at the Site
that prohibit uses that could allow potential vapor intrusion (VI) pathways to exist at the Site.
No contaminants have been detected migrating from the site at levels that could support a
potential VI pathway.
Recommendation 3
• Changes to the Maximum Contaminant Levels (MCLs) have been evaluated relative to
groundwater data from the Site resulting in no change in previous protectiveness determinations.
ICs have been recorded that prohibit future land use, rendering these protectiveness
determinations still appropriate, and so therefore, no future decision documents are necessary to
note changes in MCLs and surface water quality standards.
Remedy Implementation Activities
As described above in the section detailing activities in response to the previous FYR recommendations,
implementation of the IC component of the remedy was accomplished when the GERE was recorded in
March 2010. The GERE restricts certain uses and requires maintenance of the soil cover and approval
from EPA and the State prior to site development. An additional IC component implemented since the
last FYR is the structure of the agreement between GE and the DCR that allows GE to operate the
eastern trench and monitoring wells on the adjacent Balance Rock Park property and prohibits the use of
groundwater from this portion of the Park property. This protocol requires GE to annually reaffirm this
IC component of the remedy by letter to DCR.
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Table 2-3: Summary of Planned and/or Implemented ICs
Media, engineered
controls, and areas
that do not support
UU/UE based on
current conditions
ICs
Needed
ICs Called
for in the
Decision
Documents
Impacted
Parcel(s)
IC
Objective
Title of IC Instrument
Implemented and Date)
Soil and
Groundwater
Yes
Yes
Lots A & B
(128 & 126
Balance
Rock Rd.)
To prevent groundwater
use and excavation into
the saturated zone within
the disposal area, as well
as restrictions on certain
uses, including
residential, day care, and
agricultural.
Grant of Environmental
Restriction and
Easement, March 2010
Groundwater
Yes
No
Balance
Rock State
Park
To prevent groundwater
use at the portion of the
park that is impacted by
the Site and to ensure
PRP access.
The Sept 2009 letter
from DCR to GE stating
that groundwater supply
wells would not be used
at the park, and periodic
letters from GE to DCR
reaffirming this
agreement.
System Operation/Operation and Maintenance Activities
Routine Operation and Maintenance (O&M) is conducted and reported to EPA and DEP on a monthly
basis. A sample O&M Tracking Sheet attached to a recent monthly O&M report and a sample page from
the O&M log are attached in Appendix E to provide detail. Semi-annual groundwater monitoring is
conducted for continued evaluation of Site conditions and remedy effectiveness.
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III. FIVE YEAR REVIEW PROCESS
Administrative Components
The PRP was notified of the start of the five-year review on April 30, 2014. The Rose Disposal Pit
Superfund Site FYR was led by Richard Fisher of the U.S. EPA, Remedial Project Manager (RPM) for
the Site. Paul Craffey of the DEP assisted in the review as the representative for the support agency.
The review, which began on January 30, 2014 consisted of the following components:
• Community Involvement;
• Document Review;
• Data Review;
• Site Inspection; and
• Five-Year Review Report Development and Review.
Community Notification and Involvement
Activities to involve the community in the five-year review process started with a meeting in January
2014 between the RPM, EPA attorney, and EPA risk assessor for the Site. A press release was sent to
local newspapers, the Berkshire Eagle and the Pittsfield Gazette, on February 13, 2014 stating that a
FYR was in process, and inviting the public to submit any comments to the U.S. EPA. The results of the
review and the report will be made available at (a) the Site information repository located at the
Lanesborough Public Library, (b) on the EPA web site at www.epa.gov/regionl/superfund/sites/ftrose,
or (c) at EPA's OSRR Records and Information Center at (617) 918-1440.
Document Review
This FYR consisted of a review of relevant documents, including O&M records and groundwater and
surface water monitoring data for the most recent FYR period. Applicable groundwater cleanup standards,
as listed in the September 1988 Record of Decision (ROD), were also reviewed for updates. Additionally,
the surface water screening criteria for ecological risk evaluation were reviewed to determine if these
values should be updated.
Data Review
Summary:
Semi-annual groundwater data were collected from throughout, and adjacent to, the Site during the
period since the last FYR. A review of the data showed no contamination exceeding applicable cleanup
standards to be migrating off site. The data corroborated the PRP's assessment that a complete vapor
intrusion pathway to potential off-site receptors is not present. The data do show that contamination,
primarily in the source area, still exceeds cleanup standards. Surface water data were collected during
three sampling events since the last FYR from a nearby intermittent stream at a location downgradient
and outside the perimeter of the Site. The data showed no contamination above applicable standards at
this surface water sampling location. Groundwater Performance Standards were created in the ROD and
modified in the CD for 15 Volatile Organic Compounds (VOCs) and for total Polychlorinated Biphenyls
(PCBs) and are presented in Table 3-1.
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TABLE 3-1: 1988 ROD Cleanup Goals and Potential Updates
Compound'
1988 ROD
Performance
Standard1
ug/L
Source1
Current
Applicable
Standard
Source
ug/L
(PPb)
mg/L
(PPm)
1,1 -Dichloroethy lene
7
MCL
7
0.007
MCL
1,1,2-Trichloroethane
0.63
10"6 cancer risk
5
0.005
MCL
1,2-Dichlorobenzene
(o-Dichlorobenzene)
620
Proposed
MCLG
600
0.60
MCL
1,3-Dichlorobenzene
(/w-Dichlorobenzene)
620
Lifetime Health Advisory
600*
0.60
Lifetime Health
Advisory
1,4-Dichlorobenzene
(p-Dichlorobenzene)
75
MCL
75
0.075
MCL
Benzene
5
MCL
5
0.005
MCL
Chlorobenzene
300
Lifetime Health Advisory
100
0.10
MCL
Ethylbenzene
680
Proposed
MCLG
700
0.70
MCL
Methylene Chloride
5
10"6 cancer risk
5
0.005
MCL
Tetrachloroethylene
0.67
10'6 cancer risk
5
0.005
MCL
Toluene
2,000
Proposed
MCLG
1,000
1.0
MCL
trans-1,2-
dichloroethylene
70
Proposed
MCLG
100
0.10
MCL
Trichloroethylene
5
MCL
5
0.005
MCL
Xylenes (total)
440
Proposed
MCLG
10,000
10
MCL
Vinyl Chloride
2
MCL
2
0.002
MCL
PCBs
0.005
10"6 cancer risk
0.5
0.0005
MCL
1. From 1988 ROD, Table 5: Potential Chemical-Specific ARARs, Guidelines and Cleanup Goals for
Groundwater.
The values for 1,3-Dichlorobenzene (m-Dichlorobenzene) are based on data for 1,2-Dichlorobenzene (o-
Dichlorobenzene).
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Contaminant concentrations have declined significantly since the remedy was implemented in 1993 and
1994. VOC levels at most monitoring well locations have declined consistently from the peak levels in
the early 1990s. Statistical linear regression analysis shows a negative slope, indicative of a declining
trend at all of the eight semi-annual monitoring locations. This decline was statistically significant (95%
confidence level) at three locations (MW-6, MW-12A, ECT-1) during the 2012 and 2013 time
period. In the two most recent sampling events, VOCs still exceed the Performance Standards at
monitoring wells MW-6, MW-12A, W-5, WCT-1 and MW-10B. Trichoroethene (TCE) was the most
commonly observed VOC, exceeding the Performance Standard at each of these locations, with a
maximum detection of 0.89 ppm at MW-12A (located adjacent to the western collection trench) in
November 2013. This compound was followed by the two Performance Standard exceedances of vinyl
chloride (MW-6 and MW-12A) with a maximum detection of 0.32 ppm at MW-12A, and
tetrachloroethylene (MW-6 and MW-10B with a maximum detection of .0095 ppm at MW-10B. The
location of all these monitoring wells where a result exceeded a Performance Standard are in the vicinity
of the source area and the collection trenches. None of these monitoring wells are located beyond the
influence of the collection trenches and towards a potential receptor beyond the site perimeter.
PCB concentrations have also generally declined since source removal was completed; although the
patterns have been somewhat more erratic and less statistically robust, compared to VOC
concentrations. Linear regression analysis shows negative slopes, indicative of a declining trend at the
majority of the semi-annual monitoring locations. However, a declining trend at the 95% confidence
level was not established at any location. In the two most recent sampling events, PCBs only exceeded
the Performance Standard at a single location (MW-12A) with a concentration of 0.0083 ppm in
November 2013.
As discussed above, five monitoring wells (MW-6, MW-10B, MW-12A, W-5, WCT-1) still contain
constituents above the Performance Standard at the Site. However, all of these locations are located
relatively close to the former disposal area and occur in the upgradient areas of the property. Two
collection trenches operate at the Site, along with a treatment plant, to capture and remediate
contaminated groundwater. Perimeter monitoring locations at the downgradient edges of the Site
indicate that Performance Standards are consistently achieved for groundwater at the Site perimeter. A
vapor intrusion screening level was exceeded at MW-40B in May 2013 when an estimated value of 0.54
ppb of TCE was detected as compared to the EPA screening value of 0.52 ppb. Based on the
conservative nature of these screening levels and the fact that three other data points for this location are
either ND or substantially below the screening value, GE will be allowed to discontinue sampling this
well. It is expected that the existing groundwater controls and institutional controls will be adequate for
future compliance and that additional source removal/response actions are not necessary.
Since the Last FYR:
Since the last FYR was completed in September 2009, groundwater concentrations have typically
declined or stayed about the same at all monitoring wells. A few exceptions to this pattern occurred at
the locations listed below:
• MW-10B - total VOCs increased slightly in three consecutive sampling rounds following the
Spring 2012 sampling event. However, total VOCs in Spring 2014 (0.3543 ppm) are still less
than peak concentrations in 2006 and 2007 (0.404 - 0.446 ppm). This well is located
upgradient of the Eastern Collection Trench.
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• MW-12A -total VOCs increased slightly in Fall 2010 (1.763 ppm) and Fall 2013 (1.295
ppm). However, the concentrations decreased most recently in Spring 2014 (0.1922 ppm) and
are substantially less than peak concentrations (7-11.9 ppm) in the late 1980's. This well is
located immediately upgradient of the West Collection Trench.
• MW-7C - Unfiltered PCBs increased in Spring 2013 (0.00073 ppm) exceeding the Performance
Standard of 0.0005 ppm for the first time. This result appears anomalous and may have been
related to the presence of suspended particulate matter since filtered PCB sample results were
non-detect during the same sampling event. Two sampling rounds since the Spring 2013
sampling, along with eight prior sampling events, produced results which were all below the
Performance Standards for filtered and unfiltered PCBs.
In the previous FYR, supplemental sampling (typically conducted during the spring rounds) was
requested at wells MW-6CR, 7C, 10B and 10C. Since the prior FYR (September 2009), exceedances of
Performance Standards were observed at MW-7C (PCBs) on one occasion in May 2013 at a
concentration of 0.00073 ppm, and MW-10B (VOCs) during each sampling event, with a maximum
trichloroethene level of 0.31 ppm detected in May 2013 and a maximum tetrachlorothene level of .013
ppm was detected in November 2012. As such, supplemental spring sampling will continue for these
constituents at those two locations but will be suspended at MW-10C. Monitoring of MW-6CR will
continue in order to monitor the downgradient perimeter of the Site. Since the previous FYR, additional
groundwater samples were collected during three monitoring events at two monitoring wells (MW-40A
and 40B) located further downgradient of the Eastern Collection Trench, near Balance Rock Road.
Sampling at these two locations will be discontinued because these three sampling rounds confirmed
that the Site's Performance Standards were not exceeded at this perimeter area. It should be noted,
however, that the data for MW-40B showed a maximum TCE level of 0.54 ppb over three sampling
events, as compared to a screening level of 0.52 ppb. No structures are occupied in that direction within
proximity of the Site; the other two data points were below the screening number, and so monitoring
land use in this area should continue.
As mentioned previously, surface water data were collected during three sampling events since the last
FYR from a nearby intermittent stream at a location downgradient and off site. The sampling effort
detected no contamination above applicable standards.
The previous FYR requested that GE perform a VI evaluation to assure that this pathway remains
incomplete. GE has performed a VI assessment for ten monitoring events beginning with the Fall 2009
Semi-Annual Report. The VI Screening levels were exceeded at three well locations (W-5 and WCT-1,
located adjacent to the western collection trench, and MW-6 located on the periphery of the source area
upgradient of the eastern collection trench). The ongoing VI evaluation will be discontinued because the
potential vapor exposure pathway is considered incomplete based on other monitoring well data and the
location of potential receptors.
Site Inspection
The recent inspection of the Site associated with this FYR was conducted on June 5, 2014. In
attendance were Richard Fisher, U.S. EPA; Paul Craffey of the DEP, and Kevin Mooney of General
Electric. The purpose of the inspection was to assess the protectiveness of the remedy. Veolia Water is
currently under contract with GE to operate the treatment plant on Site. Veolia Water personnel
participated in the inspection and responded to questions regarding the O&M of the treatment plant.
Veolia personnel are available 24 hours/day, 7 days a week, and conduct daily inspections.
15
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The purpose of the inspection was to help assess the protectiveness of the remedy by observing the
condition of the site fence, the soil cover, the monitoring wells, the groundwater treatment plant, and the
wetland areas (where treatment plant discharge is located) within the Site boundary. Additionally, the
stream leading from the wetland area, the portion of the remedy (eastern collection trench and
monitoring wells), and the road into Balance Rock State Park located outside the Site boundary were
also inspected.
A Site Inspection Checklist Form was completed. This form included Site photographs and is included
as Appendix C. The Site appeared secure and well-maintained. The access road to Balance Rock State
Park was inspected in order to check for potential access routes toward the Site - none were observed.
No issues were observed with Site conditions, operations, security, vegetation, or documentation.
Interviews
Interviews were conducted as part of the FYR process primarily during June and the first two weeks of
July 2014 with parties potentially impacted by the Site, including the current landowner and PRP (GE),
the other regulatory agency (MADEP) primarily involved in Site activities, a neighbor, the Town
administrator, and the Regional Director of DCR which administers the adjacent Balance Rock State
Park. The purpose of the interviews were to document any perceived problems or successes with the
remedy that has been implemented to date. Interviews were conducted primarily during the week of
June 16,2014. Interviews are summarized below and interview notes and records are included in
Appendix D.
A telephone interview was conducted with the Town of Lanesborough Administrator, Paul Sieloff
Mr. Sieloff was not aware of any impacts from Site operations on the surrounding community, nor of
any resident complaints regarding the Site or its operations. He stated that the Town of Lanesborough
has not been routinely informed of the status of Site and the progress of Site cleanup. He stated that he
would like to be more informed only if there are issues involved.
A telephone interview was conducted with Mr. John Macht who owns properties both adjacent to, and
across the street from, the Site. Mr. Macht finds the Site well maintained, and Site operations to be
discreet. However, he stated that a berm constructed by GE has caused drainage problems on his parcel
adjacent to the.Site. This issue was raised during the previous FYR, and so EPA inspected the property
line and observed a rise in elevation of about 4 feet from Mr. Macht's property to the GE property but
did not observe a berm. GE representatives stated that a large berm was present in this location during
the incineration portion of the remedy but the berm was removed years ago after the incineration remedy
was completed - and that the rise in elevation is a result of site re-grading following completion of the
remedy. This concern was communicated again to GE.
A telephone interview was also conducted with Hank Sayers who, approximately 1-1/2 years ago,
purchased the Rick Newton gravel operation located at 20 Potter Mountain Rd. - behind the Site and
adjacent to Balance Rock State Park. He stated that he would like any groundwater data that is available
for the seven wells he stated are located on his property - although he was informed that they were only
used for groundwater elevation surveys. He also stated that he has had similar drainage issues as Mr.
Macht has described. He stated that the wells were unsecured and that he contacted GE regarding this,
and they have since secured them. He also stated that GE was not initially requesting access from him
prior to taking measurements at the monitoring wells, but they have since done so since he requested
that they do.
16
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Email correspondence supplemented by telephone interview and on-site discussions were conducted
with Paul Craffey, the RPM for MADEP. Based on reviewing monthly O&M reports, he stated that Site
O&M are running fine and that GE has been responsive to his questions. He suggested that monitoring
could be decreased, and that O&M reporting could be decreased from monthly to quarterly.
Email correspondence supplemented by a telephone interview and on-site discussions were conducted
with Kevin Mooney, the Project Manager for GE. He stated that no unexpected O&M difficulties and
no significant changes to O&M requirements or maintenance schedules have occurred since the previous
FYR. He stated that the remedy is functioning well, and that PCBs and VOCs continue to decrease. He
stated that the continuing non-detects at several groundwater sampling locations suggest that it may be
possible to discontinue sampling at several wells.
Email correspondence supplemented by a telephone interview were conducted with Robert Mellace,
Regional Director of DCR. Mr. Mellace stated that the Site has very little impact on the Park's
operations, and that the portion of the Site in the Park is located on a little used portion of the Park. He
stated that he has not heard of any issues, complaints, or incidents related to the Site, including evidence
of people going in the direction of the Site from the Park. Mr. Mellace stated that he was receptive to an
annual confirmation letter as an institutional control that reaffirms GE's access to operate the eastern
extraction trench and several monitoring wells on Park property, as well as the intent of DCR to not
extract groundwater from this area for use.
IV. TECHNICAL ASSESSMENT
Question A: Is the remedy functioning as intended by the decision documents?
Yes. The review of documents, data, Applicable or Relevant and Appropriate Requirements (ARARs),
and risk assumptions indicate that the remedy continues to be protective of human health and the
environment since groundwater is not currently used and access to the disposal area is fenced and the
area capped. Public water is available in the surrounding area. Groundwater extraction and treatment is
ongoing and continues to be needed, since groundwater contaminant concentrations still exceed
Performance Standards in some monitoring wells, primarily in and around the source area. The disposal
area is owned by GE and access is restricted.
The ICs identified in the ROD and as agreed upon by GE in the CD have been implemented to restrict
residential use of the Site, require approval from EPA and the State prior to site development, and to
protect the integrity of the soil cover. In addition, GE and DCR have entered into an agreement that
allows GE to access the monitoring well and the eastern collection trench and associated manhole
located in Balance Rock State Park for monitoring and maintenance activities while restricting public
access to same. This agreement also ensures that groundwater will not be extracted for consumption in
the area of this Park.
Although the cleanup levels continue to be exceeded in the disposal area, and are likely to do so for the
foreseeable future, the monitoring data indicates that the contamination has diminished, and is contained
within the disposal area where ICs are in place. Therefore, the remedial action continues to be effective.
17
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Question B: Are the exposure assumptions, toxicity data, cleanup levels, and Remedial Action
Objectives (RAOs) used at the time of the remedy section still valid?
Not entirely. Toxicity values, exposure assumptions, exposure pathways to be considered, and methods
of evaluating human health risk have all been updated since the time of the remedy selection. Potential
dermal contact with groundwater used as a household water source, inhalation of volatiles during
household water use, and the VI pathway were not evaluated in the Endangerment Assessment
supporting the ROD. However, these pathways are no longer of concern for on-site use since the
residential structure at the property has been demolished and the GERE prevents residential use and any
groundwater use at the Site. Also, for nearby off-site occupied residences, (a) potable groundwater use
is not necessary since they are on the municipal supply, and (b) a complete VI pathway does not exist
since VOCs have not been detected above VI screening levels at wells downgradient of the disposal
area. Monitoring for changes in land use or increasing trends in concentrations at wells that are included
in the semi-annual monitoring program can be used to ensure that this pathway remains incomplete.
Changes in Standards
The MCLs/Maximum Contaminant Level Goals (MCLGs) for several Contaminants of Concern (COCs)
have changed since the 1988 ROD. The following paragraphs, and Tables 3-1 and 4-2, summarize those
changes and the potential impact these changes may have on the protectiveness of the selected remedy for
the Site.
The current MCLs for several COCs are less stringent than the cleanup value identified in the 1988 ROD!
Because the new values are less stringent, it suggests that the Proposed Cleanup Goals identified for these
compounds in the 1988 ROD may provide for a level of public health protection that exceeds CERCLA
program expectations. These COCs include: 1,1,2-trichloroethane, ethylbenzene, tetrachloroethylene,
trans-1,2-dichloroethylene, xylenes and PCBs.
However, several COCs have current MCLs that are more stringent than the cleanup value identified in
the 1988 ROD. The 1988 ROD provides Cleanup Goals for 1,2-dichlorobenzene and toluene, based on
the proposed MCLGs, equal to 620 ppb and 2,000 ppb, respectively. The current MCLs for 1,2-
dichlorobenzene and toluene are 600 ppb and 1,000 ppb, respectively. However, these changes do not
affect the current protectiveness of the remedy at the Site because institutional controls are in place to
prevent use of the groundwater at locations where groundwater concentrations exceed these MCLs.
The 1988 Cleanup Goals for 1,3-dichlorobenzene and chlorobenzene were both based on a lifetime
health advisory. The current lifetime health advisory for 1,3-dichlorobenzene and the current MCL for
chlorobenzene are more stringent than the 1988 Cleanup Goal. The 1988 Cleanup Goal for 1,3-
dichlorobenzene (620 ppb) was based on the Lifetime Health Advisory; the current Lifetime Health
Advisory is 600 ppb. The 1988 Cleanup Goal for chlorobenzene (300 ppb) also was based on the
Lifetime Health Advisory; the current MCL is 100 ppb. Again, these changes do not affect the existing
protectiveness of the remedy at the Site because institutional controls are in place to prevent use of the
groundwater at locations where groundwater concentrations exceed these MCLs.
18
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Changes in Human Health Risk Assessment Methods
In 2014, EPA finalized a Directive to update standard default exposure factors and frequently asked
questions associated with these updates.
http://www.epa.gov/oswer/riskassessment/superfund_hh_exposure.htm (items # 22 and #23 of this web
link). Many of these exposure factors differ from those used in the risk assessment for the ROD. These
changes in general would result in a slight decrease of the risk estimates for most chemicals. Consistent
with information included in the 2009 FYR, changes in risk assessment methods since the 1988
Endangerment Assessment do not affect the remedy because of its reliance on institutional controls
which prevent the use of groundwater and prevent direct contact with contaminated soil. Further,
because residential use of the site will be restricted, use will be limited to commercial/industrial use with
EPA and Mass DEP approval in areas other than the disposal area. In addition, excavation of the
saturated zone within the disposal area is prohibited and the PCB cleanup level of 13 ppm remains
protective.
Changes in Toxicity
Table 4-3 summarizes changes in toxicity factors that have occurred since the 1988 Endangerment
Assessment. This table presents toxicity factors used in the 1988 Endangerment Assessment, those in
effect during the 2009 FYR and those currently in use in 2014. Changes in toxicity values between
2009 and 2014 are bolded in this table. Changes in toxicity factors do not affect the protectiveness of
the remedy at the Site because institutional controls are in place to prevent use of the groundwater as a
domestic water supply on the Site.
Changes in Exposure Pathways
As documented in the 2009 FYR, the exposure assumptions and pathways used at the time of the remedy
selection have been updated. Potential dermal contact with groundwater used as a household water source
and inhalation of volatiles during household water use were not evaluated in the Endangerment
Assessment supporting the ROD. However, these pathways presently are not a concern for on-site use
since the residential structure at the property has been demolished and institutional controls prevent future
residential use and any groundwater use at the site.
The VI pathway was not evaluated in the 1988 Endangerment Assessment. Since the last FYR, GE has
evaluated this potential pathway by monitoring certain wells based on their downgradient location and
checking their data against EPA screening values. The data indicates that contamination exceeding EPA
screening values is generally confined to the Site. The data for one location, MW-40B, indicated a TCE
level of 0.54 ppb as compared to a screening level of 0.52 ppb. However, based on the conservative
nature of these screening levels, and the fact that three other data points for this location are either not
detected or fall substantially below the screening value, GE will be allowed to discontinue sampling this
well. It is expected that the existing groundwater controls and institutional controls will be adequate for
future compliance and that additional source removal/response actions are not necessary. Additionally,
the ongoing groundwater monitoring program coupled with observations of changes to land use in the
area would indicate changing conditions that would suggest otherwise.
19
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New Contaminants and/or Contaminant Sources
While no new contaminant sources have been identified since startup of the remedy, GE evaluated for the
presence of 1,4-dioxane since the last FYR because it has been co-located with 1,1,1-TCA, a contaminant
found on site. Groundwater samples from wells MW-2A, -6A, -6B, -6CR, -7C, -8A, -8B, -10B, -IOC, -
14A, -14B, -40A, -40B were analyzed for 1,4-dioxane. None of the sampling results exceeded the
groundwater screening concentration (0.67 ppb) which is based on an excess cancer risk of 1E-06.
Changes in Ecological Risk Assessment Methods:
A surface water screening criteria evaluation as part of this FYR determined that the ecological surface
water screening benchmarks included in the 2009 FYR needed to be updated with screening values
commonly used in EPA Region 1 ecological risk evaluations. Table 4-1 provides the updated surface
water screening criteria.
The findings from the evaluation of the surface water screening benchmarks in the 2009 FYR included:
• The 1996 US EPA Ecotox Thresholds (ET) are no longer commonly used as a source for surface
water benchmarks.
• The benchmarks in the 2009 FYR for ethylbenzene, tetrachloroethylene, toluene,
trichloroethylene, chlorobenzene, methylene chloride, naphthalene and 1,1,2-trichloroethane may
underestimate ecological risk from surface water at the Site due to elevated benchmarks
compared to the commonly used benchmarks at EPA Region 1.
• EPA Region 5 provides benchmarks for vinyl chloride and 2,4-dimethylphenol, whereas the
2009 FYR did not provide benchmarks for these two chemicals.
• Chloroethane, 1,4-dioxane, and Aroclor 1254 were not included in the 2009 list of screening
values but have been included in the last three rounds of surface water analysis.
The most recent rounds of surface water sampling at the Site took place on November 15, 2012, May 7,
2013, and December 3, 2013. These samples were collected as confirmation samples to verify that
contaminant levels detected in Site surface water did not exceed the screening criteria. Previously,
surface water was evaluated by using groundwater data (from 2008) and diluting by a factor of 10 to
account for groundwater discharge to surface water. These values were then compared to selected water
quality criteria. The 2012/2013 surface water samples were collected from the culvert outfall running
under Balance Rock Road. Chemical analyses resulted in all non-detects (NDs), except for cis-1,2-
dichloroethylene and 1,4-dioxane. However, these two detected values, as well as all the NDs, fell
below the older and more recent sets of surface water screening benchmarks, indicating that the ongoing
remedial activities are protective of the local aquatic resources. The benchmarks have been updated to
ensure that future surface water screenings will rely on the most-current values. Those benchmarks are
included in the last column of Table 4-1.
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Table 4-1
Comparison of 1988 and 2009 ROD-Specified Numerical, Chemical-Specific ARARs and
Criteria for Surface Water Chemicals of ConcernA
F.T. Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts
Water Quality Criteria0
Aquatic Life - Chronic
Chemical
1988
(jig/L)
2004
(Hg/L)
2004
Source
2009
(Hg/L)
' 2009
Source E
2014
(Hg/L)
2014
Source F
COCs B
t-1,2-Dichloroethylene
na
590
scv
590
SCV
970
EPA 2003
Ethylbenzene
na
290
ET Tier 11
290
ET Tier II
7.3
EPA 2008
PCBs
0.014
0.014
AWQC
0.014
AWQC
0.014
AWQC
T etrachloroethylene
840
120
ET Tier II
120
ET Tier II
98
EPA 2008
Toluene
na
130
ET Tier II
130
ET Tier II
9.8
EPA 2008
Trichloroethylene
21,900
350
ET Tier II
350
ET Tier II
47
EPA 2008
Vinyl chloride
na
na
na
na
na
930
EPA 2003
Other Site Contaminants c
Benzene
NI
46
ET Tier II
46
ET Tier II
130
EPA 2008
Carbon Disulfide
NI
0.92
SCV
0.92
SCV
15
EPA 2003
Chlorobenzene
NI
130
ET Tier II
130
ET Tier II
64
EPA 2008
o-Dichlorobenzene
NI
14
ET Tier II
14
ET Tier II
14
EPA 2008
p-Dichlorobenzene
760
15
ET Tier II
15
ET Tier II
15
EPA 2008
m-Dichlorobenzene
NI
71
ET Tier II
71
ET Tier II
71
EPA 2008
1,2-Dichloroethane
NI
910
SCV
910
SCV
910
EPA 2003
1,1-Dichloroethylene
NI
25
SCV
25
SCV
65
EPA 2003
cis-1,2-Dichloroethylene
NI
590
SCV
590
SCV
590
SCV
2,4-Dimethylphenol
NI
na
na
na
na
100
EPA 2003
Methylene chloride
NI
2200
SCV
2200
SCV
940
EPA 2003
Naphthalene
NI
24
ET Tier II
24
ET Tier II
13
EPA 2003
1,2,4T richlorobenzene
NI
110
ET Tier II
110
ET Tier II
110
EPA 2008
1,1,2-Trichloroethane
9400
1200
ET Tier II
1200
SCV
500
EPA 2003
Xylenes
NI
13
SCV
13
SCV
67*
EPA 2008
Acetone
NI
ND
ND
1500
SCV
1700
EPA 2003
Chemicals included in the most recent sample analysis
Chloroethane
—
—
—
—
--
NA
—
1,4-Dioxane
—
—
--
—
—
2200
EPA 2003
Aroclor 1254
--
--
--
--
--
0.014
EPAR4
Notes:
* The benchmark shown is for m-xyleneA
A PCBs are COCs in sediment. As in 1988, there are currently no human health screening benchmarks or criteria available for evaluating PCBs. Sets of
ecological screening benchmarks for PCBs which were not available in 1988 include NOAA ERLs and ERMs (Long et al., 1995; Long and Morgan,
1991) and Ontario Ministry of Environment and Energy LELs and SELs (Pasaud et al., 1993) PCB concentrations in sediment samples collected are
compared to these benchmarks in Section 7.2.2.
B Chemicals of concern were drawn from the 1988 Record of Decision.
c Other chemicals detected as site contaminants, but not selected as Chemicals of Concern.
D US Environmental Protection Agency Water Quality Criteria or Lowest Observed Effects Levels
E 2009 ecological screening benchmarks:
1) USEPA Ambient Water Quality Criteria (AWQC) (USEPA, 2002)
2) USEPA Ecotox Thresholds (ET) for Surface Water (USEPA, 1996)
3) Secondary Chronic Values (SCVs) for aquatic biota developed by Oak Ridge National Laboratory (Suter and Tsao, 1996).
F Current ecological screening benchmarks:
1) AWQC- US EPA Ambient Water Quality Criteria (AWQC) (US EPA, 2009).
21
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2) EPA 2008 - Procedures for the Derivation of Equilibrium Partitioning Sediment Benchmarks (ESBs) for the Protection of Benthic Organisms:
Compendium of Tier 2 Values for non-ionic Organics. EPA/600/R-02/016. March 2008.
3) EPA 2003- US EPA Region 5 RCRA Ecological Screening Levels, August 22,2003.
4) EPA Region 4. Ecological Risk Assessment Bulletins Supplement to RAGS, Table 1 (chronic screening values)
5) SCV- Secondary Chronic Values (SCV) for aquatic biota developed by Oak Ridge National Laboratory (Suter and Taso, 1996).
NA = Not Available
NI = Not identified in the 1988 ROD
ND = Non-Detect
22
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Table 4-2
Comparison of 1988 and 2014 ROD-Specified Numerical, Chemical-Specific ARARs, and Criteria for Groundwater
Chemicals of ConcernA with Current Standards and Criteria
F.T. Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts
Compound1
1988 ROD
Performance
Standard1
ug/L
Source1
Current
Applicable
Standard
ug/L
Source
1,1 -Dichloroethylene
7
MCL
7
MCL
1,1,2-Trichloroethane
0.63
10"6 cancer risk
5
MCL
1,2-Dichlorobenzene
(o-Dichlorobenzene)
620
Proposed
MCLG
600
MCL
1,3-Dichlorobenzene
(m-Dichlorobenzene)
620
Lifetime Health Advisory
600*
Lifetime Health
Advisory
1,4-Dichlorobenzene
(p-Dichlorobenzene)
75
MCL
75
MCL
Benzene
5
MCL
5
MCL
Chlorobenzene
300
Lifetime Health Advisory
100
MCL
Ethylbenzene
680
Proposed
MCLG
700
MCL
Methylene Chloride
5
10"6 cancer risk
5
MCL
Tetrachloroethylene
0.67
10'6 cancer risk
5
MCL
Toluene
2,000
Proposed
MCLG
1,000
MCL
trans-1,2-
dichloroethylene
70
Proposed
MCLG
100
MCL
Trichloroethylene
5
MCL
5
MCL
Xylenes (total)
440
Proposed
MCLG
10,000
MCL
Vinyl Chloride
2
MCL
2
MCL
PCBs
0.005
10"6 cancer risk
0.5
MCL
1. From 1988 ROD, Table 5: Potential Chemical-Specific ARARs, Guidelines and Cleanup Goals for
Groundwater.
*The values for 1,3-Dichlorobenzene (m-Dichlorobenzene) are based on data for 1,2-Dichlorobenzene (o-
Dichlorobenzene).
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Table 4-3
Comparison of 1988, and 2009, and 2014 Toxicity Values
F.T. Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts
Oral Reference Dose (RfD)
(mg/kg-d)
Oral Cancer Slope Factor
(mg/kg-d)-l
Compound1
1988
2009
2014
2014
Source
1988
2009
2014
2014
Source
1,1 -Dichloroethylene
NI
0.05
0.05
IRIS
NI
N/A
N/A
N/A
1,1,2-Trichloroethane
NI
0.004
0.004
IRIS
NI
0.057
0.057
IRIS
1,2-Dichlorobenzene
(o-Dichlorobenzene)
NI
0.09
0.09
IRIS
NI
N/A
N/A
N/A
1,3-Dichlorobenzene
(m-Dichlorobenzene)
NI
N/A
N/A
N/A
NI
N/A
N/A
N/A
1,4-Dichlorobenzene
(p-Dichlorobenzene)
NI
0.07
0.07
ATSDR
NI
0.0054
0.0054
CAL EPA
Benzene
NI
0.004
0.004
IRIS
NI
0.055
0.055
IRIS
Chlorobenzene
NI
0.02
0.02
IRIS
NI
N/A
N/A
N/A
Ethylbenzene
0.1
0.1
0.1
IRIS
N/A
0.011
0.011
CAL EPA
Methylene Chloride
NI
0.06
0.006
IRIS
NI
0.0075
0.002
IRIS
T etrachloroethylene
0.02
0.01
0.006
IRIS
0.051
0.54
0.0021
IRIS
Toluene
0.3
0.08
0.08
IRIS
N/A
N/A
N/A
N/A
trans-1,2-
dichloroethylene
0.01
0.02
0.02
IRIS
N/A
N/A
N/A
N/A
Trichloroethylene
0.0074
N/A
0.0005
IRIS
0.011
0.013
0.046
IRIS
Xylenes (total)
NI
0.2
0.2
IRIS
NI
N/A
N/A
N/A
Vinyl Chloride
0.013
0.003
0.003
IRIS
2.3
1.5
0.72
IRIS
PCBs
N/A
0.00002
0.00002
IRIS
4.34
2
2
IRIS
1. COCs included in the 1988 ROD, Table 5: Potential Chemical-Specific ARARs, Guidelines and Cleanup Goals for
Groundwater.
NI - Not identified in the 1988 ROD because 1988 Endangerment Assessment was performed on 7 indicator compounds
only.
N/A - Not Applicable
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Expected Progress Towards Meeting RAOs
The RAOs set in the ROD were as follows:
• Prevent exposure to contaminated soils and groundwater;
• Protect uncontaminated groundwater and surface water for current and future use; and
• Restore contaminated soils and groundwater for future use.
The remedy is progressing as expected and the RAOs are being attained. The source control remedial
activities, groundwater collection system, and groundwater extraction system have reduced the release
of contaminants from the disposal area to groundwater, surface water, sediments, soils, and air. The
source control remedial activities, fencing, and institutional controls to disallow certain uses and
activities are preventing potential direct human contact with contaminated soils in the source area. The
provision of the public water supply system to the Site and nearby homes has reduced potential
exposures to contaminated groundwater. The remediation of Rose Pond and declining contaminant
concentrations in stream sediments and groundwater potentially contributing to surface water have
reduced potential exposures to environmental receptors.
Contaminated groundwater migrating from the disposal area is captured by the groundwater extraction
trench collection system. Groundwater concentrations at and beyond the disposal area continue to
exceed drinking water standards (MCLs) and VI screening levels; however, concentrations of VOCs in
Site groundwater have generally decreased since the groundwater treatment system was implemented.
Wells on the periphery of the Site do not exceed vapor intrusion screening levels or MCLs thus
indicating that contamination in excess of these levels is not migrating off site. The ongoing
groundwater monitoring program should be adequate to insure that this remains the case. PCB
concentrations in groundwater have been somewhat variable over time, but show a generally declining
trend. Evaluation of potential groundwater contribution to surface water in streams and wetlands
through comparison of surface water data to chronic water quality criteria protective of aquatic life
indicates that potential risks to aquatic life are negligible.
Question C: Has any other information come to light that could call into question the protectiveness of
the remedy?
No new information has come to light that calls into question the protectiveness of the remedy.
Technical Assessment Summary
Based on the aforementioned, the remedy has progressed as expected in that contamination has been
reduced Site wide, and only remains above Performance Standards in the disposal area where it is
contained, and addressed by way of institutional controls.
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V. ISSUES/RECOMMENDATIONS AND FOLLOW-UP ACTIONS
There are no issues at this time that require a specific follow-up action over and above the ongoing
O&M program.
Protectiveness Statement:
The remedy at the F. T. Rose Disposal Pit Superfund Site is protective of human health and the
environment because: access to the Site is restricted through fencing; surficial contamination
has been removed; soils in the saturated zone exceeding the PCB cleanup levels have a soil
cover in place to prevent dermal contact; the only residence on the site has been demolished;
and ICs are in place at the Site to prevent activities and uses that could present a risk. These
ICs include the restriction of: excavation into the disposal area; extraction and use of
groundwater; and uses such as residential, agricultural, and recreational. With the availability
of public water, the groundwater is not being used and ongoing treatment, management of
migration, and monitoring of contamination will continue until MCLs are met.
The next five-year review report for the F.T. Rose Disposal Pit Superfund Site is required five years
from the completion date of this review.
VI. PROTECTIVENESS STATEMENT
Protectiveness Determination:
Protective
Addendum Due Date (if applicable):
Click here to enter a date.
VII. NEXT REVIEW
26
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APPENDIX A
Existing Site Information and Site Chronology
27
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Physical Characteristics, Land Use, and History of Contamination
The Site is located on Balance Rock Road in Lanesborough, Massachusetts, and is approximately one
half mile from the city of Pittsfield, Massachusetts. The Rose property was used for the disposal of
waste oils and solvents, containing PCBs and VOCs, from GE during the 1950s and possibly later
resulting in contamination of soil and groundwater. The 1.5-acre disposal area occupies the northern
section of what was at the time a 12.5-acre residential lot. The disposal area was formerly a trench into
which the waste oils and solvents were dumped. GE now owns the entire Site including the former
trench disposal area and the former Rose residence property, which was demolished by GE in July 2009,
with ICs instituted prohibiting future residential use. The property encompassing the Site is bounded on
the north and northeast by the deciduous forest of Balance Rock State Park, on the east and southeast by
cropland and pasture, on the west by mixed forest, and on the southwest by a residential area. A small
wetland exists west of the disposal area and a larger forested wetland exists to the southeast of the
property on the southern side of Balance Rock Road. A small man-made pond (formerly Rose's pond,
restored as a wetland) is located approximately 200 feet south of the disposal area. The former disposal
area is located on a small hill north of the former Rose residential structure. The areal extent of the
former disposal area is approximately 200 feet by 350 feet and the depth of contaminated soil varies
between 10 and 30 feet.
The institutional controls (IC) component of the remedy consisted of the implementation of a Grant of
Environmental Restriction and Easement (GERE) which is a deed restriction on the Site parcels that
prevents groundwater use and excavation into the saturated zone within the disposal area, as well as
restricts certain uses, including residential, day care, and agricultural, as well as an agreement by DCR
to not extract groundwater from the portion of the site on Balance Rock State Park.
Initial Response
A number of site investigations and remedial activities were carried out on the Site beginning in 1980.
Preliminary assessment, site inspection, and field investigation were performed by.EPA between 1980
and 1982. Subsequent Site activities were conducted by GE. Permanent potable water was provided to
the Rose residence by connecting to the Lanesborough Municipal Water System. EPA issued GE an
Administrative Order under Section 106(a) of CERCLA in May 1984. In compliance with this Order,
GE erected site fencing and posting, covered contaminated soil with a polyethylene film, installed a
recovery well to capture a localized free oil layer, and connected other private properties to the
Lanesborough Municipal Water System.
EPA signed the ROD for the Site was in September 1988. The RAOs listed in the ROD are as follows:
• Prevent exposure to contaminated soils and groundwater
• Protect uncontaminated groundwater and surface water for current and future use
• Restore contaminated soils and groundwater for future use
CERCLA Remedy Implementation
The remedial design/remedial action activities were performed by the potentially responsible party, GE.
GE entered into a CD with EPA in September 1988 to perform the remediation. The selected remedy
for the Site, as identified in the ROD, consisted of the following components:
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• Excavation and on-site incineration of approximately 15,000 cubic yards of contaminated soil
and sediment, with excavation of soil exceeding concentrations of 13 ppm for PCBs to the water
table in the disposal area, and limited excavation in the saturated zone to remove the subsurface
free product portion of the disposal area. Addition of a soil cover to prevent any direct contact
with the remaining PCBs in the saturated zone. The site excavation and incineration started in
July 1992 and was completed in July 1994.
• Active restoration of the shallow overburden aquifer contaminated with VOCs using on-site
treatment involving air stripping and carbon adsorption, removal of DNAPL and installation of a
bedrock well in the vicinity of the free product area to prohibit migration into the fractured rock,
groundwater treatment to reduce contaminant levels to drinking water standards or other
appropriate guidelines set forth in the ROD as given below, and treatment of sediments and
surface water in Rose's pond and restoration of the pond to its original wetlands character after
remediation. Treatment of contaminated groundwater began in 1993, is ongoing, and has
reduced contamination such that contamination in excess of Performance Standards is contained
within the disposal area where ICs are in place.
• Implementation of institutional controls to prevent groundwater use and excavation into the
saturated zone within the disposal area, as well as to allow GE access to a portion of Balance
Rock State Park in order to maintain a groundwater extraction well and several monitoring wells,
and to ensure that groundwater will not be extracted and used at the Park without first consulting
DEP and EPA. A GERE was recorded for the GE-owned site parcels in March 2010 which
prohibits the activities specified in the ROD, as well as various uses, including day care,
agricultural, and residential use. The institutional control for the portion of Balance Rock State
Park consists of a written agreement between GE and DCR that began in 2004, and shall be
reaffirmed on an annual basis by letter from GE.
Basis for Taking Action
PCBs and VOCs, are the principal contaminants of concern in site soil and groundwater, respectively.
Geraghty & Miller (G&M, 1988) performed an Endangerment Assessment to estimate potential adverse
effects to human health and the environment from exposure to contamination at the Site. The Baseline
Public Health Risk Assessment found that dermal contact with and ingestion of soils contaminated with
PCBs posed an unacceptable lifetime maximum cancer risk for future residents. The future ingestion of
drinking water from within the disposal area was also associated with unacceptable cancer and non-
cancer risk based on the presence of PCBs, tetrachloroethene, and vinyl chloride in groundwater.
Human recreational exposures to sediments and surface water were estimated to be within or below
regulatory criteria. The Baseline Environmental Risk Assessment concluded that contaminant
concentrations in surface water were below USEPA National Ambient Water Quality Criteria
(NAWQC), and ingestion of surface water did not pose a risk to white-tailed deer. However, the report
generally indicated that contaminants in all media, including sediment, posed some risks to
environmental receptors.
Soil and Sediment. PCBs are the principal contaminant in the soil and sediment, but investigations at
the Site have reported both PCBs and VOCs in the soil. PCB soil concentrations in the disposal area
varied considerably, with maximum recorded concentrations of 53,000 parts per million (ppm) and
440,000 ppm in the eastern and western portions of the disposal area, respectively. Other portions of the
disposal area had concentrations that were considerably lower. The average soil concentrations ranged
from 500 ppm to 1,000 ppm. EPA established a PCB cleanup level of 13 ppm in soil to be protective of
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human health, assuming future residential use and soil exposure via dermal contact and ingestion. If a
cleanup level of 13 ppm PCBs were used today, it would be more akin to a cleanup level for
commercial/industrial use. The reason is that 13 ppm is protective for this type of use because it falls
within EPA's acceptable excess cancer risk range of 1 x 10"4 to 1 x 10"6. However, since the reasonably
anticipated future land use is no longer residential, and the site is now deed restricted from residential
use, this cleanup level can be considered protective.
Groundwater. VOCs are the principal contaminants in the groundwater on the Site, and previous
investigations at the Site have reported both PCBs and VOCs in the groundwater. Two plumes of VOCs
are present at the Site. Concentrations of a number of VOCs are above their associated (MCLs, or other
identified cleanup standards. Dense non-aqueous phase liquid (DNAPL) was also present, and
continues to be recovered at the Site. The potential for vapor intrusion from VOCs in groundwater has
been evaluated and the pathway has been determined to be incomplete. Future site development must
also consider a potential vapor pathway before any future building occurs at the site, since vapor
intrusion screening levels are currently exceeded within the disposal area at the site. The site
institutional control requires approval from EPA and the State before the site can be developed.
System Operation/Operation and Maintenance
An updated Operation and Maintenance Manual for the Groundwater Treatment Facility (BBL, 2004a)
was prepared by Blasland, Bouck & Lee (BBL). Planned or actual cost information is not made
available to EPA by GE. During weekly inspections of the groundwater treatment plant, a security
inspection which includes a fence perimeter inspection and a visual inspection of trespasser or
disturbance activity is conducted. An annual inspection is conducted and reported each year as required
by the GERE to ensure integrity of the soil cover (see completed annual inspection checklist in
Appendices).
Plant Scheduled Operations. The treatment plant is operated automatically 24 hours per day, seven
days per week with an on-site control system. The control system is capable of shutting the plant down
in the event of a component failure. This system appears to be functioning properly. If the treatment
plant shuts down due to a component failure, an auto-dialer will page a plant operator and give one of
twelve preset alarm codes which indicates the reason for the shutdown. Treatment plant operators are
on-call 24 hours per day, and can respond to an alarm immediately to repair and restart the groundwater
treatment plant. Currently, the groundwater treatment plant is operating at a monthly average flow of
approximately 30 gallons per minute (gpm) and has the capacity to treat at 70 gpm. Treated water is
discharged to the nearby wetlands, just west of the Site.
The groundwater treatment plant is defined as an Industrial Grade 2 waste water treatment plant by 257
CMR 2.00. As such, the plant is required to be managed, operated, and maintained by a licensed
wastewater treatment plant operator holding a current minimum rating of Industrial Grade 2. In
compliance with this regulation, the operators of the plant all hold a minimum of an Industrial Grade 4
license.
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Daily inspections axe performed by a treatment plant operator as detailed in the Site O&M Manual
(BBL, 2004c), where any maintenance issues are noted in the plant logbook and maintenance is
scheduled. Numerous checks are performed on each routine facility inspection including:
• General facility condition
• Data collection from gauges
• Off-gas heating unit check
• Acid/caustic supply check
• Check of pressure drop across liquid phase granular activated carbon (GAC) units
• Check for bacterial build-up on air stripper tower
• Check of effluent drains
Other maintenance activities are scheduled less frequently, including checking the emergency equipment
(monthly), below-grade hydraulic structures (quarterly), lighting protection system (every six months),
and electrical systems (annually).
Manual operations are also conducted during daily inspections and may include:
• Backwashing the carbon beds
• Change out of vapor phase and/or liquid phase carbon
• Air stripper acid washing
• Replacement stripper packing material
• Cleaning the intake of influent pump
• Cleaning of retention pumps
• Clean out of accumulated sludge
All O&M activities at the Site are documented and recorded in the monthly O&M status reports in
accordance with Section XI of the CD. This reporting includes the analytical data for samples that are
collected as part of O&M to examine the efficiency of the treatment processes and to ensure that treated
water does not exceed Performance Standards.
The treatment plant has recently been operating continually, with no unscheduled interruptions
(although it has been operated on backup power on one occasion during the past year). The plant
operation is temporarily suspended for scheduled maintenance such as carbon bed backwash, carbon
change out, and air stripping tower acid washing. Several monthly O&M progress reports for this FYR
period were reviewed. No instances of O&M issues were noted.
Dense Non Aqueous Phase Liquid (DNAPL) Collection at the West Collection Trench. Shortly
after the groundwater treatment system was first put into operation, a significant quantity of DNAPL
was unexpectedly drawn into the west collection manhole. From there, the DNAPL flowed through the
entire treatment system, forcing the treatment plant to shut down, and requiring the entire treatment
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system to be decontaminated. In order to prevent this event from reoccurring, GE installed a pneumatic
pump in a well (stand pipe) within the west collection manhole. The well is monitored weekly, and any
accumulations over 6 inches is removed. Any DNAPL is removed at the start of each month. For the
past couple years, GE has typically collected 5 gallons or less per month (for 2013 through June 2014, a
high of 5.5 gallons was removed). The DNAPL is transported off- site under hazardous waste manifest
by a licensed hazardous waste hauler.
Discharge Location. Treated effluent from the treatment plant is discharged though a dispersal system
located in the vicinity of monitoring well MW-24A into a wetland west of the Site. The wetland,
classified as a palustrine forested/emergent wetland, is dominated by eastern hemlock (Tsuga
canadensis) and red maple (Acer rubrum). The wetland substrate appears to be an organic muck.
Historically, there has been no observable flow in this area of the wetland. The wetland also receives
Site groundwater.
Downstream of the wetland is an area referred to as the pond (Rose's pond), although since remediation,
the manmade pond no longer functions as an open-water habitat. This area is now a wetland dominated
by grasses with some limited cattail (Typha sp.) interspersed around the previously-existing pond
shoreline. A narrow stream channel develops downgradient of the pond due to the surface gradient.
The stream depth is shallow and substrate is composed of sand and cobble. The stream is culverted as it
flows in a southerly direction underneath Balance Rock Road where it is heavily vegetated. The stream
flow appears to be intermittent as surface water is not always obvious in this heavily-vegetated channel.
Surface water samples have been collected from this location since the last FYR. The stream continues
south of Balance Rock Road to an eventual discharge in Pontoosuc Lake.
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Table 1:
Chronology of Site Events
F.T. Rose Disposal Pit Superfund Site
Lanesborough, Massachusetts
Event
Date
A local contractor (who owned the property at that time) used a trench
on the property for disposal of waste oils and solvents from GE.
1950s
Mr. and Mrs. Rose purchased the property.
1978
Preliminary assessment, site inspection, and field investigation
performed by EPA.
1980-1982
GE provided a permanent potable water supply for the Rose household
by connecting the residence to the Lanesborough Municipal Water
System.
August 1983
EPA issued GE an Administrative Order under Section 106(a) of
CERCLA.
May 1984
GE erected site fencing and posting, covered contaminated soil with a
polyethylene film, installed a recovery well to capture a localized free
oil layer, and provided permanent potable water to private properties in
the area by connecting to the Lanesborough Municipal Water System.
1984
Remedial Investigations performed by Geraghty & Miller for GE.
1984-1987
Blasland & Bouck conducts Feasibility Study for GE.
1986-1988
Endangerment Assessment Report prepared by Geraghty & Miller for
GE.
June 1988
EPA signs ROD. Selected remedy includes both source control and
management of migration components.
September 1988
GE enters into a CD with EPA to perform the work detailed in the ROD.
September 1988
GE purchases the 9.7 acre portion of the Site from the Rose family.
November 10, 1989
Approximately 51,200 tons of PCB-contaminated soil are excavated
from the disposal area and incinerated. Two trenches are constructed to
intercept contaminated groundwater plumes. Water in collection
trenches is treated using air stripping and carbon adsorption. Sediment
in Rose's pond is excavated and the pond is restored to its original
wetland habitat.
July 1992 to July
1994
A groundwater monitoring program and treatment of contaminated
groundwater is ongoing.
1993 to present
First FYR report issued by EPA for the Site.
September 1999
Second FYR report issued by EPA for the Site.
September 2004
GE purchases 2.7-acre Rose residential property, adjacent to south side
of the Site.
December 2008
GE demolishes former Rose residence
July 2009
Third FYR report issued by EPA for the Site.
September 2009
GERE recorded.
March 2010
Fourth FYR report issued by EPA for the Site.
September 2014
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APPENDIX B
Site Photos
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Photo No. 1: Front entrance to the Site from Balance Rock Rd. June 5, 2014
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Photo No. 2: View of the front of the Site from Balance Rock Rd
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Photo No. 3: View of the residential parcels across Balance Rock Rd. from the Site, June 5, 2014
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-N
Photo No. 4: View of the front of the groundwater treatment plant. June 5, 2014
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Photo No. 5: The groundwater treatment plant, primarily consisting of carbon adsorption unit
June 5, 2014
39
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/I
Photo No, 6: The extraction well at the western collection trench and the effluent discharge pipe,
June 5, 2014
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Photo No. 7: Rear of the treatment plant, including air stripping tower. June 5, 2014
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Photo No. 10: Manhole at the eastern collection trench in Balance Rock State Park. June 5,2014
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APPENDIX C
Site Inspection Checklist
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Site Inspection Checklist
I. SITE INFORMATION
Site name: F.T. Rose Disposal Pit Superfimd Site
Date of inspection: June 5, 2014
Location and Region: Lanesborough, MA, Region 1
EPA ID: MAD980524169
Agency, office, or company leading the five-year
review: EPA
Weather/temperature:
Remedy Includes: (Check all that apply)
~ Landfill cover/containment
0 Access controls
0 Institutional controls
0 Groundwater pump and treatment
~ Surface water collection and treatment
0 Other DNAPL trench collection
~ Monitored natural attenuation
0 Groundwater containment
~ Vertical barrier walls
Attachments: ~ Inspection team roster attached
~ Site map attached
II. INTERVIEWS (Check all that apply)
1. O&M site manager.
Kevin Moonev
Project Manager
Name Title
Interviewed 0 at site ~ at office 0 by phone Phone no. 413-448-5910
Problems, suggestions; ~ Report attached
June 5. 2014
Date
2. O&M staff
Sean Covle
Operator
_ Name Title
Interviewed 0 at site ~ at office ~ by phone Phone no.
Problems, suggestions; ~ Report attached
June 5. 2014
Date
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3.
Local regulatory authorities and response agencies (i.e., State and Tribal offices, emergency response
office, police department, office of public health or environmental health, zoning office, recorder of
deeds, or other city and county offices, etc.) Fill in all that apply.
Aeencv Massachusetts Department of Environmental Protection
Contact Paul Craffev NPL Site Manager
06/05/14 617-292-5591
Name Title
Problems; suggestions; ~ Report attached
Date Phone no.
Agency
Contact
Name Title
Problems; suggestions; ~ Report attached
Date Phone no.
Agency
Contact
Name Title
Problems; suggestions; ~ Report attached
Date Phone no.
Agency
Contact
Name Title
Problems; suggestions; ~ Report attached
Date Phone no.
4.
Other interviews (optional) ~ Report attached.
III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply)
1.
O&M Documents
0 O&M manual 0 Readily available 0 Up to date ~ N/A
0 As-built drawings 0 Readily available 0 Up to date ~ N/A
0 Maintenance logs 0 Readily available 0 Up to date ~ N/A
Remarks
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2.
Site-Specific Health and Safety Plan 0Readily available
~ Contingency plan/emergency response plan ~ Readily available
Remarks
0 Up to date
~ Up to date
~ N/A
~ N/A
3.
O&M and OSHA Training Records 0 Readily available
Remarks
0 Up to date
~ N/A
4.
Permits and Service Agreements
~ Air discharge permit ~ Readily available
~ Effluent discharge ~ Readily available
~ Waste disposal, POTW 0 Readily available
~ Other permits RCRA Part B ~ Readily available
~ Up to date
~ Up to date
0 Up to date
~ Up to date
~ N/A
~ N/A
~ N/A
~ N/A
Remarks: RCRA permit is for the GE facility (not the Rose site in particular). Wastes from Rose (spent
carbon, DNAPL) are stored at GE facility prior to off-site disposal at Model City or Port Arthur, TX
facilities.
5.
Gas Generation Records ~ Readily available ~ Up to date EI N/A
Remarks
6.
Settlement Monument Records ~ Readily available
Remarks
~ Up to date
0 N/A
7.
Groundwater Monitoring Records 0 Readily available 0 Up to date ~ N/A
Remarks: The 2009 through 20014 Groundwater Semi-Annual Monitoring Reports were reviewed
throughout the FYR period.
8.
Leachate Extraction Records ~ Readily available
Remarks
~ Up to date
0 N/A
9.
Discharge Compliance Records
Air 0 Readily available
0 Water (effluent) 0 Readily available
Remarks
Monthly O&M Reports and Semi-Annual Monitoring
Reports
0 Up to date
0 Up to date
~ N/A
~ N/A
10.
Daily Access/Security Logs 0 Readily available
0 Up to date
~ N/A
IV. O&M COSTS
1.
O&M Organization
~ State in-house ~ Contractor for State
~ PRP in-house 0 Contractor for PRP
~ Federal Facility in-house ~ Contractor for Federal Facility
~
Other
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2. O&M Cost Records
~ Readily available ~ Up to date
~ Funding mechanism/agreement in place
Original O&M cost estimate ~ Breakdown attached
NOTE: O&M costs are not available because PRP prefers not to disclose this information.
Total annual cost by year for review period if available
From
To
~
Breakdown
attached
From
Date
To
Date
Total cost
~
Breakdown
attached
From
Date
To
Date
Total cost
~
Breakdown
attached
From
Date
To
Date
Total cost
~
Breakdown
attached
From
Date
To
Date
Total cost
~
Breakdown
attached
Date
Date
Total cost
3. Unanticipated or Unusually High O&M Costs During Review Period
Describe costs and reasons: NA - PRP prefers not to disclose or discuss O&M costs.
V. ACCESS AND INSTITUTIONAL CONTROLS 0 Applicable ~ N/A
A. Fencing
1. 0 Acceptable Condition 0 Location shown on site map 0 Gates secured ~ N/A
Remarks
B. Other Access Restrictions
1. Signs and other security measures ~ Location shown on site map ~ N/A
Remarks: Signage is in good condition and appears to be up to
date.
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C. Institutional Controls (ICs)
1. Implementation and enforcement
Site conditions imply ICs not properly implemented ~ Yes 0 No ~ N/A
Site conditions imply ICs not being fully enforced ~ Yes 0No ~ N/A
Type of monitoring (e.g., self-reporting, drive by)
Frequency GERE inspection conducted annually. PRP has a daily presence at the
site.
Responsible party/agency GE monitors pursuant to GERE, the lead agency for enforcing this is MADEP.
Contact
Name Title Date Phone no.
Reporting is up-to-date 0 Yes ~ No ~ N/A
Reports are verified by the lead agency 0 Yes ~ No ~ N/A
Specific requirements in deed or decision documents have been met 0 Yes DNo ~ N/A
Violations have been reported ~ Yes 0 No ~ N/A
Other problems or suggestions: ~ Report attached
2. Adequacy 0 ICs are adequate* ~ ICs are inadequate ~ N/A
Remarks:
D. General
1. Vandalism/trespassing ~ Location shown on site map 0 No vandalism evident
Remarks No evidence of trespassing or vandalism
noted
Land use changes on site 0N/A
Remarks No changes
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3. Land use changes off site 0N/A
Remarks No changes
VI. GENERAL SITE CONDITIONS
A. Roads 0 Applicable ~ N/A
1. 0 Location shown on site map E3 Roads adequate ~ N/A
Remarks
B. Other Site Conditions
Remarks: Site access is through the former Rose Property (currently owned by GE).
IX. GROUNDWATER/SURFACE WATER REMEDIES 0j Applicable ~ N/A
A. Groundwater Extraction Wells, Pumps, and Pipelines 0 Applicable ~ N/A
1. Pumps, Wellhead Plumbing, and Electrical
0 Good condition 0 All required wells properly operating ~ Needs Maintenance ~ N/A
Remarks
2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances
0 Good condition ~ Needs Maintenance
Remarks
3. Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks
B. Surface Water Collection Structures, Pumps, and Pipelines ~ Applicable 0 N/A
1. Collection Structures, Pumps, and Electrical
~ Good condition ~ Needs Maintenance
Remarks
2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances
~ Good condition ~ Needs Maintenance
Remarks
3. Spare Parts and Equipment
~ Readily available ~ Good condition ~ Requires upgrade ~ Needs to be provided
Remarks
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c.
Treatment System 0 Applicable ~ N/A
1.
Treatment Train (Check components that apply)
~ Metals removal ~ Oil/water separation ~ Bioremediation
0 Air stripping 0 Carbon adsorbers (both vapor and liquid phase carbon)
~ Filters
~ Additive (e.j?., chelation agent, flocculent)
~ Others
0 Good condition ~ Needs Maintenance
0 Sampling ports properly marked and functional
0 Sampling/maintenance log displayed and up to date
0 Equipment properly identified
0 Quantity of groundwater treated annually: 70 gpm max capacity, average approximately 29 gpm or 15
million gallons per year (2013).
~ Quantity of surface water treated annually 0 not applicable
Remarks
2.
Electrical Enclosures and Panels (properly rated and functional)
~ N/A 0 Good condition ~ Needs Maintenance
Remarks
3.
Tanks, Vaults, Storage Vessels
~ N/A 0 Good condition ~ Proper secondary containment ~ Needs Maintenance
Remarks
4.
Discharge Structure and Appurtenances
~ N/A 0 Good condition ~ Needs Maintenance
Remarks
5.
Treatment Building(s)
~ N/A W Good condition (esp. roof and doorways) ~ Needs repair
0 Chemicals and equipment properly stored
Remarks
6.
Monitoring Wells (pump and treatment remedy)
0 Properly secured/locked ~ Functioning 0 Routinely sampled ~ Good condition
~ All required wells located ~ Needs Maintenance ~ N/A
Remarks: Wells are routinely sampled with results presented in semi-annual monitoring reports.
D. Monitoring Data
1.
Monitoring Data
0 Is routinely submitted on time 0 Is of acceptable quality
2.
Monitoring data suggests:
0 Groundwater plume is effectively contained 0 Contaminant concentrations are declining
D.
Monitored Natural Attenuation
1.
Monitoring Wells (natural attenuation remedy)
~ Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition
~ All required wells located ~ Needs Maintenance 0 N/A
Remarks
X.
OTHER REMEDIES
If there are remedies applied at the site which are not covered above, attach an inspection sheet describing
the physical nature and condition of any facility associated with the remedy. An example would be soil
vapor extraction.
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XI. OVERALL OBSERVATIONS
A. Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume,
minimize infiltration and gas emission, etc.).
Soil remedy has been completed and groundwater is ongoing. Objective is to remediate groundwater to MCLs.
DNAPL presence continues near the Western Collection Trench, and VOCs still exceed Performance Standards at
several locations, suggesting the remedy will need to remain in operation for a longer period of time. However,
contaminant concentrations (VOCs) have generally been decreasing or stable. PCBs have also generally declined,
although not in such a statistically evident manner as for the VOCs. That being said, PCBs exceeded the
Performance Standard at only one location (MW-12A) in the last two sampling events. DNAPL recovery volume
peaked in 2011 (824 gallons) but has steadily declined to 54 gallons in 2013. Through May 2014, only 7 gallons
have been collected. The GWTP is in good condition. Institutional controls are fully implemented.
B. Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.
No issues noted. Plant is visited daily and is alarmed. Plant is automated in terms of process and daily visits are
sufficient to manage operations. Major routine maintenance items are changeout of carbon, acid washing of air
stripper packing, and replacement of packing.
C. Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised
in the future.
None noted.
PRP prefers not to disclose cost information.
D . Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
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APPENDIX D
Interview Notes
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INTERVIEW RECORD - COMMUNITY REPRESENTATIVES
Site Name: Rose Disposal Pit Superfund Site
EPA ID No.: MAD980524169
Subject: Fourth Five-Year Review (2014)
Time:
Date: July 8, 2014
Type: ^ Telephone O Visit Q Other
Location of Visit:
I I Incoming O Outgoing
Contact Made By:
Name: Richard Fisher
Title: RPM
Organization: EPA
Individual Contacted:
Name: John Macht
Title: Adjacent Resident
Organization:
Telephone No: 413-281 -9052 (cell)
Fax No:
E-Mail Address: jon@machtsolar.com
Street Address: 121 Balance Rock Road
City, State, Zip: Lanesborough, Massachusetts
Summary Of Conversation
Q What is your overall impression of the project?
A: He is not pleased with the existence of a berm that GE constructed adjacent to his property. He
feels it is not consistent with his understanding that GE restore the land to its previous condition.
He stated that the berm is not only visually problematic to him, but that its existence has caused
drainage issues on his property that leaves the ground frequently saturated such that he has had
to construct a significant drainage trench on his property. The soil berm is adjacent to his
property at 114/116 Balance Rock Road (across the street from his residence, at the former
restaurant location). He is pleased with GE's housekeeping of the property.
Q: What effects have site operations had on the surrounding community?
A: He said GE is discreet in conducting their activities, and that there is no disturbance caused by
their activities. He stated that GE has kept up appearances, and that the Site looks nice.
Q: Are you aware of any community concerns regarding the site or its operation and administration?
If so, please give details.
A: Not aware of any.
Q: Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or
emergency responses from local authorities? If so, please give details.
A: Not aware of any.
Q: Do you feel well informed about the site's activities and progress?
A: He stated that he has no real knowledge about the ongoing activities.
Q: Do you have any comments, suggestions, or recommendations regarding the site's management
or operation?
A: Removing soil berm in back of his property is his main issue.
55
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INTERVIEW RECORD - STATE AND LOCAL CONSIDERATIONS
Site Name: Rose Disposal Pit Superfund Site
EPA ID No.: MAD980524169
Subject: Fourth Five-Year Review (2014)
Time: 4:00 PM Date: June 12, 2014
Type: Telephone Visit Other - Written
Location of Visit: MassDEP, 1 Winter St., Boston, MA
Incoming Outgoing
Contact Made By:
Name: Richard Fisher
Title: Remedial Project Manager Organization: EPA
Individual Contacted:
Name: Paul Craffey
Title: NPL Site Manager
Organization: MADEP
Telephone No: 617-292-5591
Fax No: 617-292-5530
E-Mail Address: paul.craffev@.state.ma.us
Street Address: One Winter Street
City, State, Zip: Boston, Massachusetts 02108
Summary Of Conversation
Q: What is your overall impression of the project?
A: The site O&M is adequately performed. GE and their contractor are responsive to any questions.
Q: Have there been routine communications or activities (site visits, inspections, reporting activities,
etc.) conducted by your office regarding the site? If so, please give purpose and results.
A: Yes. Annual IC Inspection Reports, Monthly O&M Reports, and Semi Annual Monitoring Reports
are provided. A 5 Year Report Site Visit was done on June 5, 2014 by MassDEP and EPA. The
Reports and Site Visit has demonstrated that the site O&M is being done adequately.
Q: Have there been any complaints, violations, or other incidents related to the site requiring a
response by your office? If so, please give details of the events and results of the responses.
A: None to my knowledge.
Q: Do you feel well informed about the site's activities and progress?
A: Yes, GE and their contractor do a good job communicating to the MassDEP.
Q: Do you have any comments, suggestions, or recommendations regarding the site's management
or operation?
A: If possible, I would suggest that GE be allowed (if they want) to send quarterly O&M report, since
for the past several years there have been no problems with the site plant operations. Some of
the sampling could also be done quarterly, instead of monthly,
56
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INTERVIEW RECORD - STATE AND LOCAL CONSIDERATIONS
Site Name: Rose Disposal Pit Superfund Site
EPA ID No.: MAD980524169
Subject: Fourth Five-Year Review (2014)
Time:
Date: July 9, 2014
Type: ^ Telephone
Location of Visit:
Visit
Other •
Incoming Outgoing
Contact Made By:
Name: Richard Fisher
Title: Remedial Project Manager Organization: EPA
Individual Contacted:
Name: Paul Sieloff
Title: Town Administrator
Organization: Town of Lanesborough, MA
Telephone No: 413-442-1167
Fax No:
E-Mail Address: admlan@verizon.net
Street Address: 83 N. Main St.
City, State, Zip: Lanesborough, MA 01237
Summary Of Conversation
Q: What is your overall impression of the project?
A: Does not have enough information to make a judgment on the project.
Q: What effects have site operations had on the surrounding community?
A: Not aware of any resident complaints.
Q: Are you aware of any community concerns regarding the site or its operation and administration?
If so, please give details.
A: Not aware of any.
Q: Are you aware of any events, incidents, or activities at the site such as vandalism, trespassing, or
emergency responses from local authorities? If so, please give details.
A: Not aware of any.
Q: Do you feel well informed about the site's activities and progress?
A: The Town has not received a lot of information regarding the progress of the site.
Q: Do you have any comments, suggestions, or recommendations regarding the site's management
or operation?
A: If there are issues, would like to be informed about them.
57
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INTERVIEW RECORD - STATE AND LOCAL CONSIDERATIONS
Site Name: Rose Disposal Pit Superfund Site
EPA ID No.: MAD980524169
Subject: Fourth Five-Year Review (2014)
Time:
Date: July 14, 2014
Type: Telephone
Location of Visit:
Visit
Other - email and call
Incoming Outgoing
Contact Made By:
Name: Richard Fisher
Title: Remedial Project Manager Organization: EPA
Individual Contacted:
Name: Bob Mellace
Title: West Region Director
Organization: Mass DCR
Telephone No: 413-442-8928
Fax No:
E-Mail Address: robert.mellace@state.ma.us
Street Address: 740 South Street, P.O. Box 1433
City, State, Zip: Pittsfield, MA 01202
Summary Of Conversation
Q: What is your overall impression of the project?
A: It's had very little impact on DCR's operations at Balance Rock State Park. Nothing out of
the ordinary in the field. The project is located in a very unused portion of the park.
Q: Have there been routine communications or activities (site visits, inspections, reporting
activities, etc.) conducted by your office regarding the site? If so, please give purpose
and results.
A: No, I have not had any communications since 2009.
Q: Have there been any complaints, violations, or other incidents related to the site requiring
a response by your office? If so, please give details of the events and results of the
responses.
A: No
Q: Have you seen, or heard evidence of, people going in the direction of, or to the area,
where the groundwater extraction trench and monitoring wells operated by GE are
located?
A: No
Q: Do you feel well informed about the site's activities and progress?
A: I do not recall receiving any communications over the past five years.
Q: Do you have any comments, suggestions, or recommendations regarding the site's
management or operation?
A: No additional comments, there have been no issues related to the Rose Site over the past
five years.
58
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INTERVIEW RECORD - PRP REPRESENTATIVE
Site Name: Rose Disposal Pit Superfund Site
EPA ID No.: MAD980524169
Subject: Fourth Five-Year Review (2014)
Time:
Date: June 26, 2014
Type: Telephone
Location of Visit:
Visit
Other - email and call
Incoming Outgoing
Contact Made By:
Name: Richard Fisher
Title: Remedial Project Manager Organization: EPA
Individual Contacted:
Name: Kevin Mooney
Title: Project Manager
Organization: GE
Telephone No: 413-448-5910
Fax No:
E-Mail Address: kevin.mooney@ge.com
Street Address: 159 Plastics Ave
City, State, Zip: Pittsfield, MA 01201
Summary Of Conversation
Q: What is your overall impression of the project?
A: It's running well. There is nothing out of the ordinary; no upsets.
Q: Is the remedy functioning as expected? How well is the remedy performing?
A: It's functioning as expected. We're seeing levels drop.
Q: What does the monitoring data show? Are there any trends that show contaminant levels are
decreasing?
A: Levels of PCBs and VOCs are decreasing; yes.
Q: Is there a continuous on-site O&M presence? If so, please describe staff and activities. If there is
not a continuous on-site presence, please describe staff and frequency of site inspections and
activities.
A: Yes. Veolia is available 24 hours a day, 7 days a week. Daily inspections are conducted.
Q: Have there been any significant changes in the O&M requirements, maintenance schedules, or
sampling routines since start-up or in the last five years? If so, do they affect the protectiveness or
effectiveness of the remedy? Please describe changes and impacts.
A: No, no in the last five years. The only prior change was from rental to permanent carbon units.
Q: Have there been unexpected O&M difficulties or costs at the site since start-up or in the last five
years? If so, please give details.
A: Not is the last five years. The only difficulty prior was when DNAPL entered the plant leading to a
temporary system shut-down for cleanup.
Q: Have there been opportunities to optimize O&M, or sampling efforts? Please describe changes
and results or desired cost savings or improved efficiency.
A: No. Sampling programs have remained the same. No system changes or replacements in the last
five years. There have been no technology changes.
Q: Do you have any comments, suggestions, or recommendations regarding the project?
A: No, everything in functioning properly. May be possible to reduce the number of monitoring points
because some wells continue to show non-detects.
59
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INTERVIEW RECORD - COMMUNITY REPRESENTATIVES
Site Name: Rose Disposal Pit Superfund Site
EPA ID No.: MAD980524169
Subject: Fourth Five-Year Review (2014)
Time:
Date: August 22, 2014
Type: £<] Telephone ~ Visit O Other
Location of Visit:
I I Incoming Q Outgoing
Contact Made By:
Name: Richard Fisher
Title: RPM
Organization: EPA
Individual Contacted:
Name: Hank Sayers
Title: Selectman and Adjacent
Resident
Organization:
Telephone No: 413-443-1635
Fax No:
E-Mail Address: hgsayers@aol.com
Street Address: 20 Potter Mountain Road
City, State, Zip: Lanesborough, Massachusetts
Summary Of Conversation
I called Mr. Sayers at the request of Mr. Macht. Mr. Sayers informed me that, approximately 1-1/2
years ago, he purchased the Rick Newton gravel operation located at 20 Potter Mountain Rd. - behind
the Site and adjacent to Balance Rock State Park. He stated that he would like any groundwater data
that is available for the seven wells he stated are located on his property - although he was informed
that they were only used for groundwater elevation surveys. He also stated that he has had similar
drainage issues as Mr. Macht has described - with excessive runoff coming from the GE site. He
inquired as to whether this should be of concern to him. I informed him that the contaminated soil
anywhere near the surface had been removed, and therefore runoff from the property does not present
a risk to him. He stated that the wells were unsecured and that he contacted GE regarding this, and
they have since secured them. He also stated that GE was not initially requesting access from him
prior to taking measurements at the monitoring wells, but they have since done so since he requested
that they do.
60
-------
APPENDIX E
O&M Tracking Sheet and Log Entry
61
-------
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APPENDIX F
IC Reaffirmation Letter from GE to DCR
64
-------
T3 Kirito teens
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Wsst Regien o&cstor
Massachusetts Department of Conservation and fftecreaSiocrt)
7&Q South Street, P© Box 1433
Ptllsr^fii, MA012Q3
He Bataifree Reck Stote Patrfc - General iEeetfk fnwIrammeffvtHJ ftennedllatfoji Activities
ED ear iXr. Kfiltece
H3ub General Elccfirie Gempany
-------
Plesee call me aft 413-44S-5tiQ ifysu hew erty1 quesScana about tfois (fnei&gf,
!
Attachments
ce TThemss ysRosa, MilesDCI
Peter ©OGsflrtfera, iPA
Mbti Killtanro, I PA
feharsfl ftsfosr,, fPA
Peui Craffeyv iKassBfF
Jane fe#cMhi, MeggpiP
:Affi«frew SCferp >SE
Red Mslsrem gi
Jam^i ifekj, SMfey Austin
-------
0 ARCADiS
-------
APPENDIX G
»
Annual GERE Inspection Checklist
68
-------
GE
ISSirtoaiinAwHwc
PtorwttLPW 01203
liKft
Pe&emiiEr 3,20 D 3
RMiard Fisher
Office of Site 8tciacdiaiik>t) and R-cstaratioai
EJJS. EiivinaiitiBti'ial Prra taction Aejjitey, Region J
5 POSl Office Square - Sisila 10$ (OSRRj(D7«01 }
Boston MA Q2M9-3912
(Jiasd •copy)
Peter PsCmnhre., Esq.
Ssnror EPA EnfarBsment taumsjel
U.St BovinicmeaiEal Protectiioo Agency, Regica D
5 Post Qfltec Spare - SuSte 10© {OES 4-3)
BasJoai, MA B2!14J^3#02
CBinrdi eopy)
Paul CraiFcy
Bmeaa of' WujSc Site Ctasnu^
MnsgoshoseOs - Ctept of lEnVimntnental Protection
Oos Winder Stscei, If* Fiktor
&MlQflrMA02Di£lj
{filetCfciEiii: copy 4ipl>)
J nog PathchiBd, Esq.
Ghfef Re^oisal Counsel
MjSi^^iuseiES - Depd of Envnronrncfrtal ProctciSao
413d Dwcghl S Creel
Sjirtngfield, MA QD J 01
(Rinrd eopy)
lit: iYT. Rose D&posal Pad Sa pcrlUndl Site - LuMsborattgfc,, MA
SuTmrmry of Annual GEESE ImpectkiB fpp flte Rose Site
Dear KCsssrsv Fishes PeCinrcbrc, ctJ Craflsy nrcd Ms, Rodbdhi3(fe
Qii IMflrtft-fEibcF 4r 201 J, nhe Geceral Etee5ri& Company flGfc") performed en inspection of the FX. R^sq
ISd^pusat Pfe StipcrfLindi $£c (Kosc Site) Lfi LimCsbiOTiush^ Ma^achc.5Et4s, pucsuant to treqiiiraiKenIS set
forth in a Grant ®f EnviranniBijlal ReslrtelSari 2nd Easement (GEPJB) eKecated !>)¦' GE Ihr this property on
March D2» accepted by the Massachusetts IDqsarteneot of Bn/vLranaicEffll PraKectcsiB OMassDEP) ib
Graatec «3i Mty 7,SAO ft, jmd jecorded m fee Berkshire IKktffhcra DlHttal RirgisSiy uf Peed* oa August 9,
2d Id (Book 141? Pag£ Id ajKordknoe wtih Exhibit D to She CIHRE, GE is respired to pSTfatto sai
annuall buqiiiuLJuai of diu ttu3c Site id assess CtenplEsnce wiflh die CERl, Tbts lerJcf pj££en*ls this resiilSs gf
tfr? feirtft nrniuial GEiJtE inspection conducted by GE She RjOSS Site.
GE ecu dieted this GERE inspection m accofdanjce wait the rti^ircrnutits set fbrtSi in Exhibit D to tfiic
OiER£. Urtder ikasc f&quiifCltiSJlCi, t£ffi annual GERE nnxpeetioo! 55 & csinsfet of two camytmetds. The
first sKinnpansjit b Ed octiHSt of a tbvktw at ssveral document = na3ie5y: (o) litis GERE iCseJT, (ii) $» Ptan
of Restricted Area (Exhibit C to the GEjRi^, (f ii) «n j' nol^S provided by GE to MaasDEiP jiinsnant 1o tbe
GERE, (dv) an^ reeraidgd omendrDen© to nndAjr releases fraisi tbe dERB^ (v) tft? inosl rcccni Fivc-Y^
AtuiioJ Rjbvcsw ftcpQft ca tbc p/fipCJly,, and (vl) sny Mlssr dscumejib in GE's posssssioai relevant lio tbe
GERE ar ifie ww af tba pfjipertj'. The S3:dnc3 cantpoiien.1 is Co coaisisl of a vi&ml bi^pectuHi nf the
jiTOperty to detEnmine whether there is visual eviiDerme Hbal gny of the folB&wlng bsve occi^recl since tbe
last inspection;
* Activities gt txr uses of tflie property tet ore pntenHnify eoirteaiy do Jbe ftsCfkiiaiis Ln die GERE",
• (MlLry vrfxrk or any buiidie^. constifDeiiaft, (t&otLiiiteaakin, sdiEtitipyi, nodiVtr denolElioit; and/or
*¦ Soil escav^feiris; (hnt isivolwd snor« Sinn JO cubic ya^ds oif sual.
•Tytz—t
-------
Messrs. Ptstaef, HJeCaBilEre, and Craffey nigd Ms, BotlithtliU
Dececobc? 3*2013
PagEf2 oF2
Ftdlowfiilg the inspsslfcon^ GE is ffequipod CO submit t& MasSlDMIP and tihe UJL EnvimnmeiTlRC Ffroteelian
Agency a if-port that ieditdss a siiaiaiaty tsfiSte fltidlr^ of the i raped ion^ a descrqjtj&n aay of a COiOpSttol GflBftE Annual tnspectioT!
Qieckililit nod eopSss cfrepres^rtintive phatopajfhs tafl®n ditfiitg die inaj^ctios (Enctptfing plietegrnp&s cf
eny of the atrovolistcd ^Editions* 5f pecseM).
As noted! abovB;, C3E caitdnrfb'tl She 20>13 anni£sl CKEJRE irapsclKin of the Rose Site fa November 2013.
GE determined £ha3 ca sew CERE^nelated dncumerrfciSion ihnct been gjeosratcd SuiGti Lhe (3I3R1E was
reeordted on August % 2011 A& a iresult, GB reviewed flhe cxislfajg (faciEiiccracitCT (£.&, GERE, Plan of
Hcstrftlcd Ascs* and the most KsentPive-Vcsif Aonual Review fttpart aalmiieiEdl in gep&nfter 2^)Q9>>
The visual] ira paction eraidhrcted an November 4, 2IJ13 revealed hmj. cbaiges ira the phjrafieal ©atMlciBait af
the property niul ma evi&snce of any of She other nbav&^listed Gsndkione since th& iu£l impec3ian, as
documented ld lbs attssliedl GERE Annua] DnspeetHsi Ghccklltst aod as gh&wn in the nBnshei
phcrto^fdgitiB,
Ptesse call imp if you have any ccanmKnls ikt questions.
Stnccfcly,
Yw%n id, 7$Wijy jSr^
Kevin G, Mooney
fl/HiBadcalikte Prttj&ct Manager
Attachments
cc: Evd Tor, MassDEP (dectemw copy)
Red lYi6lLajea* GE*
RicSiarii Gates, GE
Jtifci C got pa, SPECTRA
James Nora, ARCAP1S
Nick Saruth, ARCA0J5
James Btc&c, SStDcy Austin
0£ Interna!] Kepagitoiy
*eover kitar Qitfy
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Photo #1: Looking North from Balance Rock Road, toward the site.
£s ARCADIS
Cliem: Gererel Eectrc compar>
Protect Hame- F.T. Rose Dtepoea sne
Project Locaton ^nesacfpugh. Massachusetts
Q-aCSat rT fra— lMf Wi<. 111 Mri Pi a 11 at r h r r tm 1A
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Photo #5: Looking Northeast across the former disposal area.
Photo #6: Looking Northeast toward the eastern site gate.
CHent Genera Eecfrte company
Pro ect Mame: F.T. Rose Dtspcea Sfte
Proect ..cesser, ^eefrxciugr M3s&3ffiu&ess
(Z) ARCADIS
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Photo #7: Looking Northeast toward the ECT manhole (outside of fenoed area}
•OS
Photo #8: Looking South across the former disposal area.
Cttert Geisra Eedrte Ccmoanr
ProecE Harne: F.T. Rase aspced sm
Proe^ -ocaflcri ^restore, jqr r.tas&acnLKgs
a ARCADIS
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t* f jtemjim innm ar
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APPENDIX G -
Additional Figures and Tables for Reference
77
-------
-J
00
f.T. ROSE OlSraSM. PIT SUTWfUXD SITE
CROUNOWATTR ELEVATION CONTOURS
"A" ZONE - FALL 2013
LMCS3000UCH MASSACHUSETTS
attrt ||p*ic o;/w/h|| $t*x
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