SDMS DocID 240772GE Corporate Environmental Program;, General f'ecmc Company WO VJoodlawn Avenue....

GE Corporate Environmental Program;,General f'ecmc CompanyWO VJoodlawn Avenue. Pittslield. MA 0120'

Septembers, 1999

SDMS DocID 240772

Transmitted Via Federal Express

Mr. Richard CavagneroChief, Emergency Planning & Response BranchOffice of Site Remediation and RestorationU.S. Environmental Protection AgencyOne Congress Street, Suite 1100 - HBRBoston, Massachusetts 02203-2211

Re: Pittsfield/Housatonic River SiteOn-Plant Consolidation Areas -Supplemental Addendum to June 1999 Detailed Work Plan

Dear Mr. Cavagnero:

Enclosed is a revised Supplemental Addendum to the General Electric Company's DetailedWork Plan for On-Plant Consolidation Areas. This Supplemental Addendum replaces theSupplemental Addendum that was sent to you on August 25, 1999. It contains updated ARARstables for the On-Plant Consolidation Areas, which incorporate EPA's comments on prior versions.We would appreciate receiving EPA's formal approval of this Supplemental Addendum.

Sincerely,

Enclosure

cc: John Kilborn, Esq., EPATim Conway, Esq., EPABryan Olson, EPAMichael Nalipinski, EPARobert Bell, Esq. DEPAlan Weinberg, DEPBetsy Harper, Esq., MAAGCynthia Huber, Esq., DOJ

Andrew T. Silfer, P.E.Senior Technical Manager

Andrew Thomas, Jr., Esq., GEJohn Novotny, P.E., GEJames Nuss, P.E., L.S.P.,

Blasland, Bouck & Lee, Inc.Jeffrey Bernstein, Esq.,

Bernstein, Cushner & KimmelJames Bieke, Shea & Gardner

TABLE 1

ARARs for Hill 78 Consolidation Area

Regulation Citation Requirements Applicability/Appropriateness Determination Re Attainment

Federal ARARs

TSCA Regulations (PCBRemediation Waste)

40CFR761.61 Establishes cleanup options forPCB remediation waste,including PCB-contaminatedsoils. Options include risk-based approval by EPA. Partiesseeking risk-based approvalmust demonstrate that cleanupplan will not pose anunreasonable risk of injury tohealth or the environment.

Applicable to the extent Hill 78Consolidation Area containspreexisting materials with PCBs50 ppm.

Materials subject to this regulationwill not be added to Hill 78Consolidation Area. However, tothe extent this area alreadycontains TSCA-regulated wastes,this requirement will be attainedbased on EPA finding thatconstruction and use of thisConsolidation Area per Work Planwill not pose an unreasonable riskof injury to health or theenvironment.

TSCA Regulations(Decontamination)

40CFR761.79 Establishes decontaminationstandards and procedures forremoving PCBs from non-porous surfaces.

Applicable to decontamination ofequipment used in consolidationexcavation activities.

Will be attained in the event thatequipment used in Hill 78Consolidation Area requiresdecontamination for PCBs byimplementing equipment cleaningprocedures in accordance withSection 6.15 of Work Plan.

Clean Water Act NPDESRegulations (StormwaterDischarges)

40CFR122.26(c)(ii)(C)40CFR122.44(k)40CFR125.100-.104

Discharges of storm waterassociated with constructionactivities are required toimplement best managementpractices to control pollutants instormwater discharges duringand after construction activities.

Applicable to discharges ofstormwater.

Will be attained by implementingerosion and sedimentation controlsand stormwater managementmeasures in accordance withSections 4.7, 5.9, 6.11, and 6.13 ofWork Plan.

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TABLE 1



Federal ARARs (cont'd)

RCRA RegulationsHazardous WasteManagement/DisposalFacilities (LandfillOperation)

40 CFR 264.30 l(g)-O) Certain design and operatingstandards for hazardous wastelandfills, including requirementsto have run-on and run-offcontrol systems for 25-yearstorm, manage stormwatercontrol systems, and apply coverif landfill contains paniculatematter subject to wind dispersal.These standards do not includeliner and leachate collectionrequirements.

Relevant and appropriate toconsolidation of waste to theextent Consolidation Area alreadycontains materials that constitutehazardous waste.

Will be attained.

RCRA Regulations forHazardous WasteManagement/DisposalFacilities (LandfillClosure and Post-ClosureCare)

40 CFR 264.11140 CFR 264.11740 CFR 264.310(a)40 CFR 264.310(b)(l)&(5)

Standards for closure and finalcover of hazardous wastelandfills. Also, requirements forpost-closure monitoring andmaintenance. Does not includeleachate collection and linerrequirements.

Relevant and appropriate forcapping and post-cappingmonitoring and maintenance ofConsolidation Area to the extent italready contains materials thatconstitute hazardous waste.

Will be attained. Final cover willmeet standards in 264.310(a) forcover design/construction. Post-closure monitoring andmaintenance will be conducted inaccordance with Sections 8 and 9of Work Plan and will meetrequirements of 264.310(b)(l) &(5).

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TABLE 1




RCRA Regulations forHazardous WasteManagement/DisposalFacilities (GroundwaterMonitoring andProtection)

40 CFR 264, Subpart F Regulated units must monitorgroundwater and comply withgroundwater protectionstandards; hazardousconstituents that exceedmaximum concentration levelsor alternative concentrationlevels must be removed ortreated.

Relevant and appropriate to theextent Consolidation Area alreadycontains materials that constitutehazardous waste.

Groundwater monitoring byupgradient and downgradientmonitoring wells will beconducted in accordance withAttachment B to August 12, 1999Addendum (and any additionaladdenda) to the Work Plan, asapproved or conditionallyapproved by EPA, and inconjunction with the groundwatermonitoring program to bedescribed in Statement of Workfor Removal Actions Outside theRiver (SOW). Criteria for furtherresponse actions to meetgroundwater protection standardswill be as set forth in above-referenced Addendum (and anyadditional addenda), as approvedor conditionally approved by EPA,and in the SOW. To the extentthese measures do not meet allrequirements in the citedregulations, EPA has determinedthat attainment is not practicable.

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TABLE 1



State ARARs

Will be attained, except thatrequirement to have run-on andrun-off control systems to control100-year storm will be attainedonly to the extent practicable.

Mass. Hazardous WasteManagement FacilityRegulations (LandfillOperation)

310CMR30.622(5)-(11) Certain design and operatingstandards for hazardous wastelandfills, including requirementsto have run-on and run-offcontrol systems for 100-yearstorm, manage stormwatercontrol systems, apply cover iflandfill contains particulatematter subject to wind dispersal,control migration of harmfulemissions, maintain accessroads, and use channelingdevices to prevent run-off thatcould interfere with naturaldrainage of adjacent lands.These standards do not includeliner and leachate collectionrequirements. ^^

Relevant and appropriate toconsolidation of waste to theextent Consolidation Area alreadycontains materials that constitutehazardous waste.

Mass. Hazardous WasteManagement FacilityRegulations (LandfillClosure and Post-ClosureCare)

310 CMR 30.582310 CMR 30.592310 CMR 30.633(1)310CMR30.633(2)(a)&(e)

Standards for closure and finalcover of hazardous wastelandfills. Also, requirements forpost-closure monitoring andmaintenance. Does not includeleachate collection and linerrequirements.

Relevant and appropriate to theextent Consolidation Area alreadycontains materials that constitutehazardous waste.

Will be attained. Final cover willmeet standards in 30.633(1) forcover design/construction. Post-closure monitoring andmaintenance will be conducted inaccordance with Sections 8 and 9of Work Plan and will meetrequirements of 30.633(2)(a) &(e).

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TABLE 1



State ARARS (cont'd)Mass. Hazardous WasteManagement FacilityRegulations(Groundwater Monitoringand Protection)

310 CMR 30.672 Regulated units must monitorgroundwater and comply withgroundwater protectionstandards; hazardousconstituents that exceedmaximum concentration levelsor alternative concentrationlevels in groundwater must beremoved or treated.

Prohibition against creatingcondition of air pollution inconnection with dust generatingactivities.

Relevant and appropriate to theextent that Consolidation Areaalready contains materials thatconstitute hazardous waste.

Groundwater monitoring byupgradient and downgradientmonitoring wells will beconducted in accordance withAttachment B to the August 12,1999 Addendum (and anyadditional addenda) to the WorkPlan, as approved or conditionallyapproved by EPA, and inconjunction with the groundwatermonitoring program to bedescribed in the SOW. Criteria forfurther response actions to meetgroundwater protection standardswill be as set forth in above-referenced Addendum (and anyadditional addenda), as approvedor conditionally approved by EPA,and in the SOW. To the extentthese measures do not meet allrequirements in the citedregulation, EPA has determinedthat attainment is not practicable.

Mass. Air PollutionControl Requirements

310 CMR 7.09 Applicable to construction and sitealteration activities generatingdust.

Will be attained by implementingdust control measures and airmonitoring in accordance withSections 6.7 and 6.10 of WorkPlan and with the August 12, 1999Addendum (and any additionaladdenda) to the Work Plan, asapproved or conditionallyapproved by EPA.

F:\GE\ARAR\ARARl\Hill78chartwpd

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TABLE 2

ARARs for Building 71 Consolidation Areaand Potential Consolidation Area at New York Ave./Merrill Road


Federal ARARs

TSCA Regulations (PCBRemediation Waste)

40CFR761.61 Establishes disposal options for PCBremediation waste, including PCB-contaminated soils and sediments.Options include risk-based approval byEPA. Parties seeking risk-basedapproval must demonstrate that methodwill not pose an unreasonable risk ofinjury to health or the environment.

Applicable to disposal of PCBremediation waste, whichincludes soils and sediments atconcentrations > 50 ppm PCBsthat were contaminated prior toApril 18, 1978 and any PCBwaste contaminated after thatdate where the original sourcewas > 500 ppm beginning onApril 18, 1978, or > 50 ppmbeginning on July 2, 1979.

Will be attained based on EPAfinding that construction and useof these on-plant consolidationareas per Work Plan will not posean unreasonable risk of injury tohealth or the environment.

TSCA Regulations(Decontam ination)

40CFR761.79 Establishes decontamination standardsand procedures for removing PCBsfrom non-porous surfaces.

Applicable to decontaminationof equipment used inconsolidation activities.

Will be attained by implementingequipment cleaning procedures inaccordance with Section 6.15 ofWork Plan.

RCRA Regulations forHazardous WasteManagement/DisposalFacilities (Preparednessand Prevention)

40 CFR 264, Subpart C Various requirements for design andoperation of a hazardous waste facilityto minimize possibility of fire,explosion, or sudden release.

Relevant and appropriate toconsolidation of hazardouswaste (if any) in these on-plantconsolidation areas.

Will be attained. Operation of on-plant consolidation areas willcomply with Section 6.17 of WorkPlan and with the Health, Safety,and Contingency Plan that will beprepared by the contractor selectedto perform the project.

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TABLE 2




RCRA RegulationsHazardous WasteManagement/DisposalFacilities (General)

40 CFR 264.13-. 19 Various requirements relating to wasteanalysis, security, inspections,personnel training, precautions toprevent accidental ignition or reactionof wastes, location standards, andconstruction quality assuranceprogram.


Will be attained. On-plantconsolidation areas will beoperated in accordance withSection 6.2 and Appendix C ofWork Plan and with the Health,Safety, and Contingency Plan thatwill be prepared by contractorselected to perform the project.

RCRA RegulationsHazardous WasteManagement/DisposalFacilities (LandfillOperation)

40 CFR 264.30l(g)-(j) Certain design and operating standardsfor hazardous waste landfills, includingrequirements to have run-on and run-off control systems for 25-year storm,manage stormwater control systems,and apply cover if landfill containsparticulate matter subject to winddispersal. These standards do notinclude liner and leachate collectionrequirements.


Will be attained.

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TABLE 2




RCRA Regulations forHazardous WasteManagement/DisposalFacilities (LandfillClosure and Post-ClosureCare)

40 CFR 264.11140CFR264.11740 CFR 264.310(a)40 CFR 264.310(b)(l)&(5)

Standards for closure and final cover ofhazardous waste landfills. Also,requirements for post-closuremonitoring and maintenance. Does notinclude leachate collection and linerrequirements.

Relevant and appropriate toclosure and post-closure care ofthese on-plant consolidationareas.

Will be attained. Final covers willmeet standards in 264.310(a) forcover design/construction. Post-closure monitoring andmaintenance will be conducted inaccordance with Sections 8 and 9of Work Plan and will meetrequirements of 264.310(b)(l) &(5). Although not required by theARAR, GE will install a liner andleachate collection system at theseconsolidation areas as described inthe Work Plan.

RCRA Hazardous WasteRegulations (Storage ofHazardous Waste)

40 CFR 264, Subparts Iand J40 CFR 262.34(a)

Subparts I and J of Part 264 identifydesign, operating, monitoring, closure,and post-closure care requirements forlong-term storage of RCRA hazardouswaste in containers and tank systems,respectively. However, 262.34(a)allows accumulation of RCRAhazardous wastes for up to 90 days incontainers or tanks provided generatorcomplies with requirements ofSubparts I and J of Part 265 forcontainers and tanks.

Relevant and appropriate tostorage of leachate collectedprior to treatment, to the extentthat leachate is a hazardouswaste.

Will be attained. Leachatecollected may be storedtemporarily for 90 days or less intanker trucks that will meet thestandards for up to 90-dayaccumulation in containers.Alternatively, leachate will bestored in containers or tanks thatwill meet requirements for long-term storage.

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TABLE 2




RCRA Regulations forHazardous WasteManagement/DisposalFacilities (GroundwaterMonitoring andProtection)

40 CFR 264, Subpart F Regulated units must monitorgroundwater and comply withgroundwater protection standards;hazardous constituents that exceedmaximum concentration levels oralternative concentration levels ingroundwater must be removed ortreated.


Groundwater monitoring byupgradient and downgradientmonitoring wells will beconducted in accordance withAttachment B to the August 12,1999 Addendum (and anyadditional addenda) to the WorkPlan, as approved or conditionallyapproved by EPA, and inconjunction with the groundwatermonitoring program to bedescribed in Statement of Workfor Removal Actions Outside theRiver (SOW). Criteria for furtherresponse actions to meetgroundwater protection standardswill be as set forth in above-referenced Addendum (and anyadditional addenda), as approvedor conditionally approved by EPA,and in the SOW. To the extentthese measures do not meet allrequirements in the citedregulations, EPA has determinedthat attainment is not practicable.

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TABLE 2




Clean Water Act NPDESRegulations (StormwaterDischarges)

40CFR122.26(c)(ii)(C)40CFR 122.44(k)40CFR 125.1 00-. 104

Discharges of stormwater associatedwith construction activities arerequired to implement bestmanagement practices to controlpollutants in stormwater dischargesduring and after construction activities.

Applicable to discharges ofstormwater.

Will be attained by implementingerosion and sedimentation controlsand stormwater managementmeasures in accordance withSections 4.7, 5.9, 6.1 1, and 6.13 ofWork Plan.

State ARARs

Mass. Hazardous WasteManagement FacilityRegulations (General)

310 CMR 30.513-30.516 Various requirements relating to wasteanalysis, security, inspections, andpersonnel training.

Relevant and appropriate toconsolidation of hazardouswaste in these on-plantconsolidation areas.

Will be attained. On-plantconsolidation areas will beoperated in accordance withSection 6.2 of Work Plan and theHealth, Safety, and ContingencyPlan that will be prepared by thecontractor selected to perform theproject.

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TABLE 2



State ARARs (cont'd)Will be attained, except thatrequirement to have run-on andrun-off control systems to control100-year storm will be attainedonly to the extent practicable.

Mass. Hazardous WasteManagement FacilityRegulations (LandfillOperation)

310CMR30.622(5)-(11) Certain design and operating standardsfor hazardous waste landfills, includingrequirements to have run-on and run-off control systems for 100-year storm,manage stormwater control systems,apply cover if landfill containsparticipate matter subject to winddispersal, control migration of harmfulemissions, maintain access roads, anduse channeling devices to prevent run-off that could interfere with naturaldrainage of adjacent lands. Thesestandards do not include liner andleachate collection requirements.


Mass. Hazardous WasteManagement FacilityRegulations(Ignition/Reaction)

310 CMR 30.560 Various requirements relating toprecautions to prevent accidentalignition or reaction of wastes.


Will be attained. On-plantconsolidation areas will beoperated in accordance with theHealth, Safety, and ContingencyPlan that will be prepared by thecontractor selected to perform theproject.

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TABLE 2



State ARARs (cont'd)Mass. Hazardous WasteManagement FacilityRegulations (LandfillClosure and Post-ClosureCare)

310 CMR 30.582310 CMR 30.592310 CMR 30.633(1)310CMR30.633(2)(a)&(e)

Standards for closure and final cover ofhazardous waste landfills. Also,requirements for post-closuremonitoring and maintenance. Does notinclude leachate collection and linerrequirements.


Will be attained. Final covers willmeet standards in 30.633(1) forcover design and construction.Post-closure monitoring andmaintenance will be conducted inaccordance with Sections 8 and 9of Work Plan and will meetrequirements of 30.633(2)(a) &(e). Although not required by theARAR, GE will install a liner andleachate collection system at theseconsolidation areas as described inthe Work Plan.

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TABLE 2



State ARARs (cont'd)Mass. Hazardous WasteManagement FacilityRegulations (GroundwaterMonitoring andProtection)

310 CMR 30.672 Regulated units must monitorgroundwater and comply withgroundwater protection standards;hazardous constituents that exceedmaximum concentration levels oralternative concentration levels ingroundwater must be removed ortreated.


Groundwater monitoring byupgradient and downgradientmonitoring wells will beconducted in accordance withAttachment B to the August 12,1999 Addendum (and anyadditional addenda) to the WorkPlan, as approved or conditionallyapproved by EPA, and inconjunction with the groundwatermonitoring program to bedescribed in SOW. Criteria forfurther response actions to meetgroundwater protection standardswill be as set forth in above-referenced Addendum (and anyadditional addenda) to the WorkPlan, as approved or conditionallyapproved by EPA, and in theSOW. To the extent thesemeasures do not meet allrequirements in the citedregulation, EPA has determinedthat attainment is not practicable.

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TABLE 2



State ARARs (cont'd)

Mass. Hazardous WasteRegulations (Storage ofHazardous Waste)

310 CMR 30.680, 30.690310 CMR 30.340

30.680 and 30.690 identifyrequirements for long-term storage ofRCRA hazardous waste in containersand tank systems, respectively, that aresimilar to federal RCRA storagerequirements identified above. 30.340allows on-site accumulation ofhazardous waste by generator for up to90 days in containers and tanksprovided that generator complies withcertain container and tank standards,and is also similar to federal RCRAstorage requirements identified above.

Relevant and appropriate toaccumulation and storage ofleachate prior to treatment, tothe extent that leachate isconsidered a hazardous waste.

See discussion of federal RCRAHazardous Waste Regulations(Storage of Hazardous Waste)above.

Mass. Air PollutionControl Requirements

310 CMR 7.09 Prohibition against creating conditionof air pollution in connection withdust-generating activities.

Applicable to construction andsite alteration activitiesgenerating dust.

Will be attained by implementingdust control measures and airmonitoring in accordance withSections 6.7 and 6.10 of WorkPlan and with the August 12, 1999Addendum (and any additionaladdenda) to the Work Plan, asapproved or conditionallyapproved by EPA.

F:\GE\ARAR\ARARl\Building71 chart.wpd

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SDMS DocID 240772GE Corporate Environmental Program;, General f'ecmc Company WO VJoodlawn Avenue....

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