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GE Building 71/Hill 78

On Plant Consolidation Areas

Monitoring Report

February 19, 2019

• Allendale School remediation - 1999 (w/minor
additional work in 2007/2008)
• Building 71 on-plant consolidation area
(OPCA) closed and capped in 2006
• Hill 78 OPCA closed and capped in 2009
• Long-term inspection, monitoring and
maintenance plan memorialized in GE’s 2011
Final Report

Monitoring Requirements
• OPCAs (GE Requirements)
– Physical integrity of cap system (including cover,
drainage and leachate components)
– Groundwater monitoring
– PCB Air Sampling
• Allendale School (EPA Conducting)
– PCB air sampling

Physical Integrity Monitoring
Inspections 2 x/yr (May & Oct), consisting of:
• Evidence of erosion of the soil cover
• Vegetation on the soil cover
• Tree plantings
• Uneven settlement
• Damage to the geosynthetic cap/liner components
• Obstructions/blockages of drainage layers and outlet
• Leachate handling and collection system
• Integrity of perimeter fencing
Integrity Monitoring Results
Repair items GE has performed in recent years:
• Repair erosion of top soil
• Install new drainage pipes
• Repair/replace drainage pipes
• Re-seed bare spots
• Re-pave access roads
• Tree replacement
• Repair woodchuck burrow holes
• Repair of leachate collection system tank monitoring

October 2018 Results
• Reseal/repair three fissures in asphalt on the
site access road (area of road shown in purple
in previous figure)
• 12 woodchuck burrow holes to be filled in.
• Beginning in 2019, GE increased the
inspection frequency for the leachate handling
system to monthly

PCB Air Monitoring
• GE conducts sampling at five locations 2x/yr
(July & September)
• EPA conducts sampling at two locations at
Allendale School concurrent to GE’s sampling
• Sampling to continue until GE requests, and
the Agencies concur, that sampling is no
longer necessary

PCB Ambient Air Sample Results
Allendale School
• EPA conducted sampling at Allendale School
2x/yr (July & Sept) since 2010
Samples collected by Avatar & analyzed by Test America
• Project-Specific action level set at 0.0500
micrograms/cubic meter
• In 2018, results were 0.0002 micrograms/
cubic meter at both locations
• From 2010 to the present, results ranged from
non-detect to 0.0013 micrograms/cubic meter

PCB Ambient Air Sample Results-
• GE conducted sampling rounds at the OPCA 2x/yr
since 2010
Performed by Berk Envir Consultants; analytical activities by Con-Test Analytical
• Project-Specific Action level set at 0.0500
micrograms/cubic meter
• Since 2010, results ranged from non-detect to
0.0051 micrograms/cubic meter
• In 2018, results ranged from non-detect to
0.0009 micrograms/cubic meter
Groundwater Monitoring
• Sample 12 wells that surround the OPCAs 2 x /yr
(spring & fall) for a minimum of 30 years
• Analyze samples for an extensive list of chemicals
including, volatile organic compounds, semi-
volatile organic compounds, metals and PCBs
• Currently sample 4 additional wells downgradient
of the OPCAs as part of GMA-4 program
• Monitor direction of groundwater flow

GW Monitoring Results
• Flow is south, towards the Housatonic River,
and away from Allendale School
• All but a few compound results are below
standards or benchmarks
• Fall 2018 Sampling (February 2019 Report) –
– Monitoring of PCE & TCE showed no significant
– All samples for PCBs were non-detect

Protection of Indoor Air From
Groundwater vapors (GW-2)
For groundwater located within 15 feet or less from the ground surface and
within 30 feet of an occupied building, groundwater quality must achieve:
a) the Method 1 GW-2 groundwater standards set forth in the MCP, as
b) alternative risk based GW-2 standards developed by GE and approved by
EPA as protective against unacceptable risks due to volatilization and
transport of chemicals from groundwater to the indoor air of nearby
occupied buildings; or
c) EPA’s November 8, 2010 conditional approval letter directed GE, going
forward, to compare the sampling data from all OPCA wells to the GW-2
standards as a benchmark, regardless of the depth to groundwater or
proximity to buildings.
Revised OPCA Post-Closure Groundwater Monitoring Plan,
September 2011 p. 5-6.

Comparison of Data to GW-2
Performance Standards/Benchmarks
• There are 3 wells where the GW-2 Performance Standard is
applicable: H78B-15, OPCA-MW-4, and OPCA MW-5R.
• In the spring and fall of 2018, there were no exceedances of
the GW-2 Performance Standards.
• In the fall of 2018, there were exceedances of GW-2
benchmarks in two wells, but these are not exceedances of
Performance Standards.
• Comparison to GW-2 benchmarks is important to monitor
trends and as can be used to evaluate risks to proposed new

Monitoring Wells near Allendale School
• There are three wells between Allendale School and the
• All three wells non-detect (ND) for PCE, TCE and PCBs in
Spring and Fall 2018.
• These wells have been sampled 2 times per year over the
last 12 to 18 years (25 to 37 times, one well was installed 12
years ago).
• There have not been any exceedances of GW-2 benchmarks
in any of these wells.
• For two of the wells, PCE and TCE have been ND in every
sampling round. In one well, PCE was detected once in 25

• Air data – Allendale School

• Air data – OPCAs


• Groundwater reports
• GE Inspection Reports
• EPA Approval Letters of Inspection Reports

• GE is conducting long-term monitoring and
maintenance program as required by Consent Decree
and GE’s Final Report
• Program overseen by Federal EPA and Mass DEP, with
support from Mass DPH
• When action items are identified, they are addressed
in a timely manner.


27,000 18,000

Protection of Indoor Air from
Groundwater Vapors (GW-2 levels)
“GW-2: Groundwater that is a potential source of
hazardous vapors to indoor air; groundwater shall be
classified as GW-2 if located within 30 feet of an existing
building or structure and the annual average depth to
groundwater is 15 feet or less. These locations shall be
GW-2 compliance points. Although none of the wells
included in this groundwater monitoring program fit in this
criteria, data from three wells . . . shall be used as a
benchmark against the GW-2 standards.”
OPCA Work Plan, August 1999, Annex 1 to Appendix E of the Consent Decree, p.3-2.

GW-3 Standard - Protection of
Surface Water
• GW-3 standards are designed to be protective of ecological
receptors in surface waters
• All 12 OPCA wells and the four GMA-4 wells were sampled in
the spring and fall of 2018. There were zero exceedances of
the GW-3 Standard for PCE and TCE.
• In fact, for these 16 wells, there has never been an
exceedance of the GW-3 standard for PCE or TCE. Therefore,
the data shows that groundwater around and down-gradient
of the OPCAs does not pose a threat to surface water for TCE
and PCE.
• In the Fall of 2018, two wells exceeded the GW-3 standard
for Cadmium