yz (1yz yz · the september 2011 inspection also included observations of trees and shrubs planted...

Transmitted via Overnight Courier

October 21,2011

Mr. Dean Tagliaferro EP A Project Coordinator United States Environmental Protection Agency clo Weston Solutions, Inc. 10 Lyman Street Pittsfield, MA 01201

Re: GE-Pittsfield/Housatonic River Site

GE 159 Plastics Avenue Pittsfield, MA 01201 USA

Floodplain Residential and Non-Residential Properties Adjacent to 1 Yz Mile Reach of Housatonic River (GECD710 and GECD720) Summary of September 2011 Inspection Activities for the Group 4C Floodplain Properties

Dear Mr. Tagliaferro:

On September 21-23, 2011, the General Electric Company (GE) performed a post-remediation inspection of celiain Phase 4 propeliies located within the floodplain adjacent to the 1 Yz Mile Reach of the Housatonic River. As depicted on Figure 1, the Phase 4 properties within the floodplain adjacent to the 1 Yz Mile Reach are divided into three groups (Groups 4A, 4B, and 4C). As GE and EPA have agreed and as provided in EPA's Final PostRemoval Site Control Plan - I12-Mile Removal Reach (1Yz Mile PRSC Plan), inspections of Parcels 16-1-66 and 16-1-67 (Group 4B) have been completed, and Parcel 17-1-101 (in Group 4A) is and will continue to be inspected in accordance with the 1 Yz Mile PRSC Plan. Accordingly, this letter documents the results of the September 2011 inspection activities conducted at the remaining properties within Phase 4 - i.e., Group 4C. Group 4C consists of two residential propeliies (Parcels 16-1-102 and 16-1-105) and four non-residential properties (Parcels 16-1-62, 16-1-103, 16-1-104, and 16-1-106). Remediation activities at these properties were completed in summer 2006. Previous post-remediation inspections were performed semi-annually at these properties since September 2006. Summaries ofthese inspections were presented in prior letters to EPA. The most recent prior inspection of these properties was performed in May 2011, with the report on it dated June 24, 2011.

The September 2011 inspection was performed for areas that were backfilled and restored during the implementation of the remediation actions and included an assessment of the planted vegetation, as well as an assessment of the four non-residential properties for evidence of invasive species. It also included an evaluation of whether a severe tropical storm event that occurred in the area on August 28, 2011, causing flows on the Housatonic River to exceed a IS-minute peak flow of 3,500 cubic feet per second (cfs) at the United States Geological Survey (USGS) gaging station at Coltsville, Massachusetts, had caused any damage to those areas. The inspection of these areas at the two residential properties (Parcels 16-1-102 and 16-1-105) was performed in accordance with the Post-Removal Site Control requirements specified in the Final Completion Report for Removal Action for Housatonic River Floodplain - Current Residential Properties Adjacent to 112 Mile Reach (1 Yz Mile Residential Floodplain FCR), which was submitted to EPA on June 30, 2008 and approved by EPA on August 27, 2008. The inspection of the non-residential propeliies (Parcels 16-1-62, 16-1-103, 16-1-104, and 16-1-106), including the invasive species inspection, was performed in accordance with the Post-Removal Site Control requirements specified in the Final Completion Report for Removal Action for Housatonic River Floodplain -Non-Residential Properties (1 Yz Mile Non-Residential Floodplain FCR), which was submitted to EPA on April 6, 2010 and approved by EPA on May 17, 2010.

Corporate E!1VIronrnelltoi Programs

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Summary of Inspection Activities

Mr. Dean Tagliaferro October 21,2011

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The areas inspected during the September 2011 inspection are shown on Figure 2, which includes the areas subject to inspection as shown on Figure 11 from the 1 Yz Mile Residential Floodplain FCR and Figure 6 from the 1 Y2 Mile Non-Residential Floodplain FCR. The four Group 4C non-residential properties (Parcels 16-1-62, 16-1-103, 16-1-104, and 16-1-106) were inspected and evaluated jointly. As shown on Figure 2, the areas inspected at these properties included not only the remediated areas, but also the approximate areas where access roads and staging areas were used and areas that were otherwise disturbed during the remediation.

The September 2011 inspection included observations of the backfilled/restored areas at the Group 4C residential and non-residential floodplain properties, as well as the other disturbed areas shown on Figure 2. These observations focused on the following: (a) any areas where excessive settlement has occurred relative to the surrounding areas; (b) any drainage or growth problems; (c) any areas of erosion; and (d) other conditions that could affect the outcome of the completed remediation actions (for example, burrows, vehicle ruts, unauthorized uses of areas, etc.).1 Additionally, the propeliies were specifically evaluated to determine whether there was any evident damage from the above-referenced tropical storm.

The September 2011 inspection also included observations of trees and shrubs planted as pmi of restoration activities. Figure 3 contains the current restoration planting plan for the Group 4C properties as shown on Figure H-6 from the 1 Yz Mile Residential Floodplain FCR and Figure H-l of the 1 Yz Mile Residential Non-Floodplain FCR. Observations of these plantings included a stem count of planted trees/shrubs (quantity per species) in good health and a stem count of trees/shrubs that were dead or dying or showing evidence of stress or other potential problems. Additionally, each tree/shrub observed was measured to determine the approximate average height and range of heights of each species of tree/shrub within the Group 4C propeliies. In conjunction with the tree and shrub observations, GE also inspected tree cages, guards, and stakes (where present).

In addition to the tree/shrub observations, the September 2011 inspection included observations of revegetated areas at Parcels 16-1-62, 16-1-103, I6-l-104, and I6-1-106 for evidence of invasive species. These observations were used to evaluate if any of the invasive species listed in EPA's 1 Yz Mile PRSC Plan was present over more than 5% of a given restored area, which is the trigger for implementing invasive species control actions.

The September 2011 inspection also included observations of properties/areas where the need for follow-up activities had been identified during the prior inspection in May 2011, as documented in GE's June 24, 2011 report on that inspection. The maintenance and repair activities identified in that repOli consisted of (a) removing tree cages from one dead maple and one dead box elder; (b) fertilizing a stressed box elder; and (c) spraying all nOlihern arrowwoods with insecticide in spring 2012. All of these activities had been performed prior to the September 2011 inspection except that the spraying of the northern arrowwoods will be conducted in spring 20l2?

1 The requirement to assess the effectiveness of erosion controls in areas where vegetation is not yet established was not applicable, since the vegetation has been established at these areas.

2 The June 24, 2011 report also stated that two red maples that had been planted in May 2010 were not located during the May 2011 inspection, and that those trees would be replaced if they were not located during the September 2011 inspection. However, as discussed further below (and based on discussions with EPA), even though these trees (and three others planted in May 2011) were not located during the September 2011 inspection, no replanting activities will be necessary since the total number of trees in that group (i.e., the original box elders together with red maples and eastern cottonwoods planted in May 2010 to replace dead or stressed box elders) exceeded the original planted quantity of trees in that group.

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Summary of Inspection Observations


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The results of the September 2011 inspection are included in an Inspection Summary and Checklist for each residential property subject to inspection and in a combined Inspection Summary and Checklist for Parcels 16-1-62, 16-1-103, 16-1-104, and I6-1-106. The forms used in this inspection were the forms included in the relevant Final Completion Reports. The completed inspection forms for the September 2011 inspection are provided in Attachment A. Documentation oftree/shrub observations is provided in Tables B-1 through B-9 in Attachment B. These tables list, for each species, the number of trees/shrubs observed, the height of each individual tree/shrub counted, the condition of each tree/shrub observed, and the condition of the associated tree cage, guard, or stake. Observations of the trees/shrubs in the vernal pool area on Parcel I6-1-106 are identified in the comment field in these tables.

The September 2011 inspection indicated that the backfilled/restored areas at the inspected properties were in good overall condition, that the herbaceous vegetation was growing as anticipated, and that there was no evident storm-related damage. With respect to the trees/shrubs, the 1 Y2 Mile Residential Non-Floodplain FCR provides that, for the Group 4C non-residential properties, the results of the tree/shrub observations will be used to evaluate whether the trees/shrubs are surviving at a frequency of 80% or greater of the planted quantity specified in the planting plan, except for the trees and shrub replanted in May 2010, which are subject to a 100% survival standard. The results of the tree/shrub observations and measuring activities at these combined propeliies are summarized in the following table: 3

Tree/Shrub Count Results Range Percent in

Planted Observed Observed

Average of Good

Percent per

in Good Dead/ Height

Heights Condition Survival Planting

Condition Stressed 2 (ft.)

(ft.) (%) 3 (%) 4

Species Plan 1

Maple 265 5 276 0/0 17.1 6- >25 >100 >100

Eastern Cottonwood 187 195 0/0 23.5 10- >25 >100 >100

Box Elder 41 0/0 10.3 4-25

Eastern Cottonwood 78 0/0 22.9 15- >25

(planted in May 2010) 6 181 >100 >100

Red Maple (planted In 76 0/0 13.2 10-20 6 May 2010)

N olihern Arrowwood 6 6 0/0 7.2 7-8 100 100

Winterberry Holly 5 5 0/0 5.8 5-7 100 100

Dogwood 10 8 0/0 6.6 5-8 80 80

Choke Cherry 4 6 0/0 6.2 4-10 >100 >100

Notes:

1. The quantity of each species listed in this column corresponds to the originally planted quantity identified on Figure 3 of this letter, which is based on Figurc H-6 from the nl, Mile Residential Floodplain FCR and Figure H-I of the 1 Y, Mile Residential Non-Floodplain FCR (updated with more recent plantings).

2. This column lists the number of dead trees/shrubs observed (if any) and then the number of trees/shrubs that were not dead but were considered "stressed."

3. This ~ol11mn shows the percentage of trees/shrubs that were in good condition relative to the originally planted quantity specified on Figure 3.

3 Although 3 of these trees are actually on residential Parcel 16-1-102, those trees are considered with the ones planted on the non-residential properties in the joint tree/shrub evaluations for the Group 4C properties.

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Notes (continued):


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4. This column shows the percentage of trees Ish rubs that were alive (including plants with identified problems) relative to the originally planted quantity specified on Figure 3.

5. Three ofthe maples planted within the Group 4C properties are on residential Parcel 16-1-102. The remaining maples were planted on non-residential parcels.

6. 79 eastern cottonwoods and 80 red maples were planted in May 2010 as replacements for dead and stressed box elders. These trees are included with the box elders and compared to the original planted quantity for the box elders since they were used as alternate species.

The results of the tree/shrub counting activities indicate that, of the seven categories of species planted at Group 4C (considering the replacement species for the box elders as pmi of the same category as the original box elders), six had a percent survival of 100% or greater and one had a percent survival of 80%, thus meeting the survival standard for those plantings. All of the plantings observed were in good condition with the exception of three eastern cottonwoods planted in May 2010 which were observed to be leaning.

For the trees/shrubs planted in May 2010, the one choke cherry shrub planted at that time was located and was in good condition, thus meeting the 100% survival standard for that planting. However, only 76 of the 80 red maples planted in May 2010 and only 78 of the 79 eastern cottonwoods planted in May 2010 were located during the September 2011 inspection. It is likely that these trees were present, but simply could not be identified as trees planted in May 2010, either because of limited visibility or because the tags fell off and the trees were counted as original maples/cottonwoods. In any case, GE and EPA have agreed that there is no need to replant these five trees, because the total number of trees in this group that were observed to be in good condition in September 2011 (195 trees, consisting of 41 original box elders plus the 76 red maples and 78 eastern cottonwoods that were planted in May 20 I 0 to replace dead or stressed box elders) exceeds the original planted quantity of trees in this group (181 box elders). Thus, the performance standard for this group of trees was met.

The observations of tree cages, guards, and stakes (where present) during this inspection indicated that all ofthose items were in good condition with the exception of tree cages on two eastern cottonwoods planted in May 2010 that need to be repaired.

As noted above, the September 2011 inspection included observations of revegetated areas at the non-residential floodplain propeJiies within Group 4C for evidence of any of the invasive species listed in EPA's 1 Yz Mile PRSC Plan. The inspection indicated that goutweed and garlic mustard continue to be present in several of the backfilled/restored areas, as noted during prior inspections. In addition, the following other invasive species were observed: purple loosestrife, common buckthorn, and border privet (which is considered likely invasive). None of these species was observed to be present in more than 5% of a given restored area. GE has implemented a treatment program (which began in fall 2008) to address the presence of goutweed (as well as other invasive species when observed) at a frequency similar to that used for the 1 Yz-Mile Reach. As recommended by the arborist, this treatment program will be continued and will include treatment of the invasive species observed during the September 2011 inspection. (As indicated above, the arborist has also recommended that the nOlihern arrowwoods be sprayed with insecticide again in spring 2012.)

MaintenanceiRepIanting Activities

Based on the September 2011 inspection, the following maintenance and repair activities were identified:

• Repair the three leaning eastern cottonwoods installed in May 2010;

• Repair tree cages on two eastern cottonwoods installed in May 2010;

• Spray nOlihern arrowwoods in spring 2012; and

• Continue with additional treatment applications for goutweed and other observed invasive species listed above on a frequency similar to that used for the 1 Yz-Mile Removal Reach, as recommended by the arborist.

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GE will repair the leaning trees and the damaged tree cages this fall. GE will notify EPA (via email) prior to performing any corrective actions to the plantings. As noted above, the northern arrowwoods will be sprayed again in spring 2012 and, as recommended by the arborist, GE will continue with the treatment program to address the presence of goutweed (as well as other invasive species when observed) at a frequency similar to that used for the 1 Yz-Mile Removal Reach.

Schedule for Future Inspections

Future inspections of the remediated Group 4C floodplain properties will be conducted in accordance with the applicable Post-Removal Site Control requirements specified in the relevant Final Completion Reports. The backfilled/restored areas will be inspected annually in August or September (subject to EPA approval of a different frequency), as well as after severe storms (defined as events causing a peak flow exceeding 3,500 cfs at the USGS gaginp station at Coltsville). The next such scheduled inspection will be conducted in August or September 2012.

The required five-year monitoring period for the revegetated areas has been completed, with the September 2011 inspection being the final scheduled inspection. Further, the September 2011 inspection constituted the last inspection of the trees and shrubs planted prior to May 2010. The trees and shrub planted in May 2010 will be inspected again in May and August or September 2012. In addition, based on discussions with EPA, to address the issue of the five trees planted in May 2010 that could not be located in September 2011, GE will inspect and count all the box elders in May and August or September 2012 (along with the trees/shrubs planted in May 2010), and will compare the total number of trees in that group (i.e., the box elders and the replacement red maples and eastern cottonwoods) to the total quantity of box elders planted in accordance with the planting plan (181), with a performance standard of 100%. Finally, GE will continue to inspect tree cages, guards, and stakes (where present) on all planted trees/shrubs during future annual inspections (in August or September) until such time as those items are removed.

The required 5-year monitoring period for invasive species inspection of the revegetated areas at the nonresidential floodplain properties has been completed, but as noted above, the invasive species treatment program will be continued at a frequency similar to that used for the 1 Yz Mile Reach.

Following each inspection, an inspection repmt will be prepared and submitted to EPA within 30 days of the completion of the inspection.

Please call me if you have any comments or questions.

Sincerely

Richard W. Gates Remediation Project Manager

Attachments

4 As noted in GE's May 11, 2011 repmi on the April 14, 2011 inspection of the vernal pool on Parcel 16-1-106, that inspection constituted the final inspection of the vernal pool and no further activities relating to the vernal pool are required.

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cc: Rose Howell, EPA (electronic copy) Holly Inglis, EPA John Kilborn, EPA* Robert Leitch, USACE Michael Gorski, MDEP* Eva Tor, MDEP* John Ziegler, MDEP (2 copies) Nancy E. Harper, MA AG* Karen Pelto, MDEP* Mayor James Ruberto, City ofPittsfield* Linda Palmieri, Weston (2 copies) Michael Carroll, GE* Rod McLaren, GE* James Nuss, ARCADIS James Bieke, Goodwin Procter Property Owner - Parcel 16-1-62 Property Owner - Parcel 16-1-102 Propeliy Owner - Parcel 16-1-103 Property Owner - Parcel 16-1-104 Propeliy Owner - Parcel 16-1-105 Propeliy Owner - Parcel 16-1-106 Public Information Repositories GE Internal Repository

* cover letter only

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Attachment A

Completed Inspection Checklists

I. GENERAL INFORMATION

Inspection Date: September 21 - 23, 2011Conducted By/Phone Number:Weather Conditions: Rainy/Partly Cloudy ~70°F Date of Last Inspection:

II. INSPECTION SUMMARY1.

- Confirmed

2.

- All areas in good condition.

3.

- Herbaceous vegetative cover is in good condition. - Note that 3 of the maples planted within the Group 4C floodplain properties are on residential Parcel I6-1-102.- All trees planted are in good condition.

4.

- None

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIES- None

PARCEL I6-1-102

INSPECTION SUMMARY AND CHECKLIST

HOUSATONIC RIVER (1.5-MILE REACH)RESIDENTIAL FLOODPLAIN PROPERTIES

ATTACH ADDITIONAL INFORMATION AS APPROPRIATE

Paolo Filippetti/(585) 385-0090

Confirm that Figure 6, 7, 8, 9, 10, or 11 (as they apply to the property being inspected) of the Final Completion Report for Removal Action for Housatonic River Floodplain - Current Residential Properties Adjacent to 1-1/2 Mile Reach (Final Completion Report) and the applicable as-built survey drawings included in Appendix B of that document have been reviewed.

Soil Backfill and Other Restored Areas (Note any physical changes since last inspection; note evidence of any of the following: excessive settlement, soil erosion, drainage problems, burrows, vehicle ruts, unauthorized excavations, unauthorized uses of areas, etc.)

Vegetation Area (Note any physical changes since last inspection; note general condition of vegetative cover [e.g., evidence of stressed/sparse cover], other landscaping items [trees, shrubs, etc.] planted during restoration activities, tree guards, tree cages, and tree stakes; for Parcels I7-2-20, I7-2-44, I7-3-6, and I7-3-7, monitor the grass/herbaceous cover for evidence of stress until such time as the cover is adequately established and growing as anticipated; review the applicable restoration planting plan included in Appendix H of the Final Completion Report [for Phase 3, the trees/shrubs subject to inspection are listed on Table H-1 of Appendix H] and determine the percent survivorship of planted trees and shrubs subject to inspection; and measure and record the size of all trees and shrubs subject to inspection.)

Other Observations (Confirm that repair/maintenance measures identified during prior inspection have been performed; note any other general observations, including parcel-specific restoration activities.)

May 25 and 26, 2011

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- Confirmed

2.


3.

- Herbaceous vegetative cover is in good condition (no trees/shrubs planted).

4.

- None

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIES- None




Vegetation Area (Note any physical changes since last inspection; note general condition of vegetative cover [e.g., evidence of stressed/sparse cover], other landscaping items [trees, shrubs, etc.] planted during restoration activities, tree guards, tree cages, and tree stakes; for Parcels I7-2-20, I7-2-44, I7-3-6, and I7-3-7, monitor the grass/herbaceous cover for evidence of stress until such time as the cover is adequately established and growing as anticipated; review the applicable restoration planting plan included in Appendix H of the Final Completion Report [for Phase 3, the trees/shrubs subject to inspection are listed on Table H-1 of Appendix H] and determine the percent survivorship of planted trees and shrubs subject to inspection; and measure and record the size of all trees and shrubs subject to inspection.)


Confirm that Figure 6, 7, 8, 9, 10, or 11 (as they apply to the property being inspected) of the Final Completion Report for Removal Action for Housatonic River Floodplain - Current Residential Properties Adjacent to 1-1/2 Mile Reach (Final Completion Report) and the applicable as-built survey drawings included in Appendix B of that document have been reviewed.

May 25 and 26, 2011


RESIDENTIAL FLOODPLAIN PROPERTIESHOUSATONIC RIVER (1.5-MILE REACH)

PARCEL I6-1-105

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- Confirmed

2.


3.

-- Tree/shrub observations are listed in Tables B-1 through B-9.- Four maples installed in May 2010 were not located.- One eastern cottonwood installed in May 2010 was not located.- Three eastern cottonwoods installed in May 2010 were observed to be leaning.- All other trees/shrubs are in good condition.- Tree cages, guards, and stakes (where present) observed to be in good condition with the exception of tree cages on two eastern cottonwoods

installed in May 2010 that need to be repaired.

4.

- The following invasive species were observed: goutweed ( Aegopodium podagria ), garlic mustard (Alliaria petiolata ), purple loosestrife (Lythrum salicaria ), common buckthorn ( Rhamnus cathartica ), and border privet (Ligustrum obtusifolium; which is considered likely invasive).

- None of these species were observed to be present in >5% of a given restored area.

5.

- NA (monitoring of vernal pool was previously completed)

6.

- Tree cages had been removed from one dead maple and one dead box elder. - Stressed box elder had been fertilized. - Treatment applications on a frequency similar to that used for the 1½-Mile Removal Reach had been implemented to address the presence of goutweed

and other invasive species (when observed).-


HOUSATONIC RIVER (1.5-MILE REACH)NON-RESIDENTIAL FLOODPLAIN PROPERTIES

PARCELS I6-1-62, I6-1-103, I6-1-104, AND I6-1-106

Confirm that Figure 6 of the Final Completion Report for Removal Action for Housatonic River Floodplain - Non-Residential Properties (Final Completion Report) and the as-built survey drawings for the Group 4C floodplain properties included in Appendix B of that document have been reviewed in the field during the inspection.


Vegetation Areas (On a semi-annual basis [in May and August/September], note any physical changes since last inspection; note general condition of vegetative cover [e.g., evidence of stressed/sparse cover], other landscaping items [trees, shrubs, etc.] planted during restoration activities, tree guards, tree cages, and tree stakes; review the restoration planting plan included in Appendix H [Figure H-1] of the Final Completion Report and determine the percent survivorship [per species] of the trees/shrubs subject to inspection [for this purpose, the four Group 4C non-residential properties will be evaluated as one area in determining compliance with the survival standard of 80% or, for trees/shrubs replanted in 2010 or beyond, the survival standard of 100%]; and measure and record the size of all trees and shrubs subject to inspection.)

Vernal Pool at Parcel I6-1-106 (On an annual basis [in April or May], photograph the condition of the vernal pool and document [via the Obligate Species Method, as defined by the Massachusetts Division of Fisheries & Wildlife's Natural Heritage & Endangered Species Program [NHESP] in its Guidelines for the Certification of Vernal Pool Habitat (March 2009; attached)] acceptable breeding evidence for those vertebrate and invertebrate species that rely on vernal pools for all or a portion of their life cycle and are unable to successfully complete their life cycle without vernal pools.)



May 25 and 26, 2011

Presence of Invasive Species (On an annual basis [in August or September], note any evidence of those invasive species listed in EPA's Post-Removal Site Control Plan for the 1-1/2 Mile Reach [with any revisions; see attached list] and any other invasive species identified by the arborist; note the percentage of revegetated areas occupied by invasive species and list the species that are present.)

Tall nettle (Urtica procera ), a native species, and ferns were observed to be filling in the areas where goutweed had been treated.

Herbaceous vegetative cover is in good condition.

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HOUSATONIC RIVER (1.5-MILE REACH)NON-RESIDENTIAL FLOODPLAIN PROPERTIES

PARCELS I6-1-62, I6-1-103, I6-1-104, AND I6-1-106

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIES- Repair the three leaning eastern cottonwoods installed in May 2010.- Repair tree cages on two eastern cottonwoods installed in May 2010.- Spray northern arrowwoods in spring 2012 in an effort to prevent further mortality. - Continue with additional treatment applications for goutweed and other observed invasive species listed above on a frequency similar to that used for the

1½-Mile Removal Reach, as recommended by the arborist. - Continue to inspect all planted box elders in May and August or September 2012 (along with the trees/shrubs planted in May 2010).


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Attachment B

Summary of Tree/Shrub Observations

Tree Condition of TreeCondition of Tree Cage, Guard, and

Stakes (where present) Comments1 22 Good Good None2 17 Good Good None3 17 Good Good None4 16 Good Good None5 21 Good Good None6 > 25 Good Good None7 22 Good Good None8 12 Good Good None9 17 Good Good None10 15 Good Good None11 10 Good Good None12 17 Good Good None13 21 Good Good None14 11 Good Good None15 20 Good Good None16 18 Good Good None17 13 Good Good None18 19 Good Good None19 13 Good Good None20 17 Good Good None21 25 Good Good None22 18 Good Good None23 25 Good Good None24 25 Good Good None25 17 Good Good None26 17 Good Good None27 17 Good Good None28 15 Good Good None29 14 Good Good None30 15 Good Good None31 16 Good Good None32 16 Good Good None33 17 Good Good None34 17 Good Good None35 14 Good Good None36 13 Good Good None37 13 Good Good None38 18 Good Good None39 24 Good Good None40 20 Good Good None41 18 Good Good None42 13 Good Good None43 16 Good Good None44 15 Good Good None45 14 Good Good None46 16 Good Good None47 17 Good Good None48 13 Good Good None49 17 Good Good None50 14 Good Good None51 18 Good Good None52 16 Good Good None53 18 Good Good None54 17 Good Good None55 18 Good Good None56 14 Good Good None57 15 Good Good None58 16 Good Good None

Height (ft.)

TABLE B-1SUMMARY OF TREE/SHRUB OBSERVATIONS - SILVER MAPLE, RED MAPLE, SUGAR MAPLE

SUMMARY OF SEPTEMBER 2011 INSPECTION ACTIVITIES FOR THE GROUP 4C FLOODPLAIN PROPERTIESGENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS

(Acer saccharinum, Acer rubrum, Acer saccharum )

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Stakes (where present) CommentsHeight (ft.)




59 13 Good Good None60 20 Good Good None61 15 Good Good None62 19 Good Good None63 19 Good Good None64 23 Good Good None65 16 Good Good None66 14 Good Good None67 21 Good Good None68 16 Good Good None69 16 Good Good None70 21 Good Good None71 14 Good Good None72 21 Good Good None73 20 Good Good None74 22 Good Good None75 21 Good Good None76 25 Good Good None77 > 25 Good Good None78 20 Good Good None79 > 25 Good Good None80 15 Good Good None81 > 25 Good Good None82 24 Good Good None83 18 Good Good None84 15 Good Good None85 12 Good Good None86 12 Good Good None87 15 Good Good None88 19 Good Good None89 22 Good Good None90 15 Good Good None91 17 Good Good None92 18 Good Good None93 18 Good Good None94 16 Good Good None95 18 Good Good None96 21 Good Good None97 25 Good Good None98 24 Good Good None99 15 Good Good None100 14 Good Good None101 14 Good Good None102 18 Good Good None103 17 Good Good None104 16 Good Good None105 14 Good Good None106 17 Good Good None107 15 Good Good None108 17 Good Good None109 14 Good Good None110 23 Good Good None111 18 Good Good None112 19 Good Good None113 22 Good Good None114 21 Good Good None115 17 Good Good None116 17 Good Good None







117 21 Good Good None118 23 Good Good None119 18 Good Good None120 17 Good Good None121 15 Good Good None122 18 Good Good None123 16 Good Good None124 13 Good Good None125 17 Good Good None126 21 Good Good None127 24 Good Good None128 21 Good Good None129 15 Good Good None130 18 Good Good None131 25 Good Good None132 19 Good Good None133 19 Good Good None134 19 Good Good None135 21 Good Good None136 25 Good Good None137 > 25 Good Good None138 17 Good Good None139 21 Good Good None140 15 Good Good None141 16 Good Good None142 > 25 Good Good None143 20 Good Good None144 13 Good Good None145 18 Good Good None146 13 Good Good None147 10 Good Good None148 10 Good Good None149 18 Good Good None150 12 Good Good None151 13 Good Good None152 9 Good Good None153 11 Good Good None154 15 Good Good None155 13 Good Good None156 11 Good Good None157 10 Good Good None158 24 Good Good None159 19 Good Good None160 12 Good Good None161 15 Good Good None162 16 Good Good None163 18 Good Good None164 12 Good Good None165 16 Good Good None166 14 Good Good None167 20 Good Good None168 13 Good Good None169 11 Good Good None170 10 Good Good None171 24 Good Good None







172 13 Good Good None173 15 Good Good None174 15 Good Good None175 14 Good Good None176 14 Good Good None177 16 Good Good None178 6 Good Good None179 12 Good Good None180 17 Good Good None181 16 Good Good None182 13 Good Good None183 13 Good Good None184 11 Good Good None185 16 Good Good None186 14 Good Good None187 14 Good Good None188 13 Good Good None189 24 Good Good None190 12 Good Good None191 21 Good Good None192 12 Good Good None193 14 Good Good None194 16 Good Good None195 22 Good Good None196 13 Good Good None197 13 Good Good None198 11 Good Good None199 16 Good Good None200 13 Good Good None201 14 Good Good None202 9 Good Good None203 16 Good Good None204 16 Good Good None205 22 Good Good None206 12 Good Good None207 11 Good Good None208 12 Good Good None209 14 Good Good None210 18 Good Good None211 18 Good Good None212 21 Good Good None213 18 Good Good None214 21 Good Good None215 13 Good Good None216 12 Good Good None217 15 Good Good None218 12 Good Good None219 17 Good Good None220 22 Good Good None221 > 19 Good Good None222 16 Good Good None223 25 Good Good None224 14 Good Good None225 21 Good Good None226 23 Good Good None227 15 Good Good None228 12 Good Good None







229 19 Good Good None230 24 Good Good None231 19 Good Good None232 23 Good Good None233 13 Good Good None234 23 Good Good None235 17 Good Good None236 16 Good Good None237 15 Good Good None238 14 Good Good None239 14 Good Good None240 16 Good Good None241 15 Good Good None242 15 Good Good None243 14 Good Good None244 17 Good Good None245 18 Good Good None246 19 Good Good None247 17 Good Good None248 17 Good Good None249 19 Good Good None250 17 Good Good None251 16 Good Good None252 19 Good Good None253 19 Good Good None254 21 Good Good None255 16 Good Good None256 20 Good Good None257 17 Good Good None258 17 Good Good None259 17 Good Good None260 19 Good Good None261 19 Good Good None262 16 Good Good None263 20 Good Good None264 20 Good Good None265 20 Good Good None266 24 Good Good None267 > 25 Good Good None268 23 Good Good None269 20 Good Good None270 22 Good Good None271 21 Good Good None272 14 Good Good None273 19 Good Good None274 15 Good Good Parcel I6-1-102 (residential)275 19 Good Good Parcel I6-1-102 (residential)276 10 Good Good Parcel I6-1-102 (residential)

Average Height (ft.): 17.1Height Range (ft.): 6 - >25Total Tree Count: 276

Note: For the tree >25 feet, the average was calculated using a value of 25 feet.



Stakes (where present) Comments1 16 Good Good None2 22 Good Good None3 14 Good Good None4 > 25 Good Good None5 > 25 Good Good None6 > 25 Good Good None7 > 25 Good Good None8 > 25 Good Good None9 > 25 Good Good None10 25 Good Good None11 17 Good Good None12 14 Good Good None13 > 25 Good Good None14 25 Good Good None15 > 25 Good Good None16 > 25 Good Good None17 > 25 Good Good None18 25 Good Good None19 > 25 Good Good None20 18 Good Good None21 18 Good Good None22 14 Good Good None23 15 Good Good None24 17 Good Good None25 16 Good Good None26 18 Good Good None27 > 25 Good Good None28 > 25 Good Good None29 > 25 Good Good None30 16 Good Good None31 > 25 Good Good None32 21 Good Good None33 24 Good Good None34 > 25 Good Good None35 > 25 Good Good None36 > 25 Good Good None37 > 25 Good Good None38 > 25 Good Good None39 > 25 Good Good None40 23 Good Good None41 > 25 Good Good None42 > 25 Good Good None43 > 25 Good Good None44 > 25 Good Good None45 > 25 Good Good None46 > 25 Good Good None47 > 25 Good Good None48 > 25 Good Good None49 > 25 Good Good None50 > 25 Good Good None51 > 25 Good Good None52 > 25 Good Good None53 > 25 Good Good None54 > 25 Good Good None55 > 25 Good Good None56 > 25 Good Good None57 > 25 Good Good None58 > 25 Good Good None59 > 25 Good Good None

TABLE B-2SUMMARY OF TREE/SHRUB OBSERVATIONS - EASTERN COTTONWOOD (Populus deltoides)


Height (ft.)

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Stakes (where present) Comments



Height (ft.)60 > 25 Good Good None61 > 25 Good Good None62 > 25 Good Good None63 > 25 Good Good None64 24 Good Good None65 > 25 Good Good None66 > 25 Good Good None67 > 25 Good Good None68 > 25 Good Good None69 > 25 Good Good None70 > 25 Good Good None71 > 25 Good Good None72 > 25 Good Good None73 > 25 Good Good None74 > 25 Good Good None75 > 25 Good Good None76 > 25 Good Good None77 > 25 Good Good None78 25 Good Good None79 > 25 Good Good None80 > 25 Good Good None81 > 25 Good Good None82 > 25 Good Good None83 > 25 Good Good None84 > 25 Good Good None85 > 25 Good Good None86 > 25 Good Good None87 > 25 Good Good None88 > 25 Good Good None89 > 25 Good Good None90 > 25 Good Good None91 > 25 Good Good None92 > 25 Good Good None93 > 25 Good Good None94 24 Good Good None95 > 25 Good Good None96 > 25 Good Good None97 > 25 Good Good None98 > 25 Good Good None99 > 25 Good Good None100 > 25 Good Good None101 > 25 Good Good None102 > 25 Good Good None103 > 25 Good Good None104 25 Good Good None105 > 25 Good Good None106 25 Good Good None107 23 Good Good None108 25 Good Good None109 25 Good Good None110 > 25 Good Good None111 25 Good Good None112 > 25 Good Good None113 > 25 Good Good None114 > 25 Good Good None115 > 25 Good Good None116 > 25 Good Good None117 > 25 Good Good None118 > 25 Good Good None






Height (ft.)119 > 25 Good Good None120 > 25 Good Good None121 > 25 Good Good None122 > 25 Good Good None123 > 25 Good Good None124 > 25 Good Good None125 23 Good Good None126 22 Good Good None127 25 Good Good None128 24 Good Good None129 25 Good Good None130 25 Good Good None131 > 25 Good Good None132 > 25 Good Good None133 > 25 Good Good None134 > 25 Good Good None135 > 25 Good Good None136 > 25 Good Good None137 > 25 Good Good None138 > 25 Good Good None139 > 25 Good Good None140 > 25 Good Good None141 > 25 Good Good None142 22 Good Good None143 23 Good Good None144 > 25 Good Good None145 > 25 Good Good None146 > 25 Good Good None147 > 25 Good Good None148 > 25 Good Good None149 > 25 Good Good None150 > 25 Good Good None151 > 25 Good Good None152 23 Good Good None153 18 Good Good None154 22 Good Good None155 12 Good Good None156 14 Good Good None157 20 Good Good None158 25 Good Good None159 24 Good Good None160 21 Good Good None161 10 Good Good None162 16 Good Good None163 18 Good Good None164 21 Good Good None165 23 Good Good None166 25 Good Good None167 23 Good Good None168 > 25 Good Good None169 > 25 Good Good None170 25 Good Good None171 > 25 Good Good None172 > 25 Good Good None173 24 Good Good None174 20 Good Good None175 24 Good Good None176 25 Good Good None177 > 25 Good Good None






Height (ft.)178 > 25 Good Good None179 25 Good Good None180 25 Good Good None181 14 Good Good None182 20 Good Good None183 > 25 Good Good None184 18 Good Good Vernal Pool185 19 Good Good Vernal Pool186 15 Good Good Vernal Pool187 14 Good Good Vernal Pool188 > 25 Good Good Vernal Pool189 18 Good Good Vernal Pool190 17 Good Good Vernal Pool191 25 Good Good Vernal Pool192 21 Good Good Vernal Pool193 > 25 Good Good Vernal Pool194 25 Good Good Vernal Pool195 25 Good Good Vernal Pool


Note: For trees >25 feet, the average was calculated using a value of 25 feet.


Tree Height (ft.) Condition of TreeCondition of Tree Cage, Guard,

and Stakes (where present) Comments1 13 Good Good None2 4 Good Good None3 15 Good Good None4 10 Good Good None5 6 Good Good None6 15 Good Good None7 14 Good Good None8 7 Good Good None9 10 Good Good None10 20 Good Good None11 8 Good Good None12 6 Good Good None13 10 Good Good None14 11 Good Good None15 25 Good Good None16 22 Good Good None17 12 Good Good None18 15 Good Good None19 4 Good Good None20 20 Good Good None21 4 Good Good None22 19 Good Good None23 13 Good Good None24 12 Good Good None25 18 Good Good None26 9 Good Good None27 4 Good Good None28 6 Good Good None29 5 Good Good None30 5 Good Good None31 12 Good Good None32 10 Good Good None33 12 Good Good None34 6 Good Good None35 4 Good Good Vernal Pool36 4 Good Good Vernal Pool37 4 Good Good Vernal Pool38 10 Good Good Vernal Pool39 10 Good Good Vernal Pool40 5 Good Good Vernal Pool41 4 Good Good Vernal Pool

Average Height (ft.): 10.3Height Range (ft.): 4-25Total Tree Count: 41

TABLE B-3SUMMARY OF TREE/SHRUB OBSERVATIONS - BOX ELDER (Acer negundo)

GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTSSUMMARY OF SEPTEMBER 2011 INSPECTION ACTIVITIES FOR THE GROUP 4C FLOODPLAIN PROPERTIES

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Tree Condition of TreeCondition of Tree Cage, Guard,

and Stakes (where present) Comments1 18 Good Good Installed in May 20102 25 Good Good Installed in May 20103 > 25 Good Good Installed in May 20104 24 Good Good Installed in May 20105 24 Good Good Installed in May 20106 25 Good Good Installed in May 20107 25 Good Good Installed in May 20108 19 Good Good Installed in May 20109 21 Good Good Installed in May 201010 25 Good Good Installed in May 201011 22 Good Good Installed in May 201012 24 Good Good Installed in May 201013 18 Good Good Installed in May 201014 > 25 Good Good Installed in May 201015 24 Good Good Installed in May 201016 21 Good Good Installed in May 201017 21 Good Good Installed in May 201018 21 Good Good Installed in May 201019 24 Good Good Installed in May 201020 > 25 Good Good Installed in May 201021 > 25 Good Good Installed in May 201022 22 Good Good Installed in May 201023 > 25 Good Good Installed in May 201024 > 25 Good Good Installed in May 201025 25 Good Good Installed in May 201026 25 Good Good Installed in May 201027 24 Good Good Installed in May 201028 24 Good Good Installed in May 201029 24 Good Good Installed in May 201030 24 Good Good Installed in May 201031 23 Good Good Installed in May 201032 24 Good Good Installed in May 201033 21 Good Good Installed in May 201034 21 Good Good Installed in May 201035 25 Good Good Installed in May 201036 > 25 Good Good Installed in May 201037 24 Good Good Installed in May 201038 24 Good Good Installed in May 201039 24 Good Good Installed in May 201040 > 25 Good Good Installed in May 201041 > 25 Good Good Installed in May 201042 > 25 Good Good Installed in May 201043 25 Good Good Installed in May 201044 25 Good Good Installed in May 201045 24 Good Good Installed in May 201046 > 25 Good Good Installed in May 201047 > 25 Good Good Installed in May 201048 > 25 Good Good Installed in May 201049 24 Good Good Installed in May 201050 > 25 Good Good Installed in May 201051 25 Good Good Installed in May 201052 23 Good Good Installed in May 201053 20 Good Good Installed in May 2010; Tree Observed Leaning54 20 Good Good Installed in May 2010; Tree Observed Leaning55 > 25 Good Good Installed in May 201056 25 Good Cage Repair Required Installed in May 201057 24 Good Good Installed in May 201058 > 25 Good Good Installed in May 2010

Height (ft.)


GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS

INSTALLED IN MAY 2010 TO REPLACE BOX ELDERS

SUMMARY OF SEPTEMBER 2011 INSPECTION ACTIVITIES FOR THE GROUP 4C FLOODPLAIN PROPERTIES

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Tree Condition of TreeCondition of Tree Cage, Guard,

and Stakes (where present) CommentsHeight (ft.)


GENERAL ELECTRIC COMPANY - PITTSFIELD, MASSACHUSETTS


SUMMARY OF SEPTEMBER 2011 INSPECTION ACTIVITIES FOR THE GROUP 4C FLOODPLAIN PROPERTIES

59 24 Good Good Installed in May 201060 24 Good Good Installed in May 201061 > 25 Good Cage Repair Required Installed in May 201062 24 Good Good Installed in May 201063 25 Good Good Installed in May 201064 25 Good Good Installed in May 201065 25 Good Good Installed in May 201066 24 Good Good Installed in May 201067 16 Good Good Installed in May 201068 18 Good Good Installed in May 201069 24 Good Good Installed in May 201070 23 Good Good Installed in May 201071 24 Good Good Installed in May 201072 15 Good Good Installed in May 2010; Tree Observed Leaning73 19 Good Good Installed in May 201074 16 Good Good Installed in May 201075 15 Good Good Installed in May 201076 20 Good Good Installed in May 201077 19 Good Good Installed in May 201078 15 Good Good Installed in May 2010


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and Stakes (where present) Comments1 10 Good Good Installed in May 20102 11 Good Good Installed in May 20103 13 Good Good Installed in May 20104 12 Good Good Installed in May 20105 13 Good Good Installed in May 20106 11 Good Good Installed in May 20107 13 Good Good Installed in May 20108 12 Good Good Installed in May 20109 13 Good Good Installed in May 201010 13 Good Good Installed in May 201011 11 Good Good Installed in May 201012 12 Good Good Installed in May 201013 14 Good Good Installed in May 201014 13 Good Good Installed in May 201015 13 Good Good Installed in May 201016 12 Good Good Installed in May 201017 12 Good Good Installed in May 201018 11 Good Good Installed in May 201019 10 Good Good Installed in May 201020 11 Good Good Installed in May 201021 12 Good Good Installed in May 201022 12 Good Good Installed in May 201023 12 Good Good Installed in May 201024 12 Good Good Installed in May 201025 11 Good Good Installed in May 201026 11 Good Good Installed in May 201027 12 Good Good Installed in May 201028 11 Good Good Installed in May 201029 13 Good Good Installed in May 201030 12 Good Good Installed in May 201031 11 Good Good Installed in May 201032 14 Good Good Installed in May 201033 13 Good Good Installed in May 201034 11 Good Good Installed in May 201035 14 Good Good Installed in May 201036 15 Good Good Installed in May 201037 15 Good Good Installed in May 201038 15 Good Good Installed in May 201039 14 Good Good Installed in May 201040 14 Good Good Installed in May 201041 13 Good Good Installed in May 201042 12 Good Good Installed in May 201043 12 Good Good Installed in May 201044 16 Good Good Installed in May 201045 14 Good Good Installed in May 201046 11 Good Good Installed in May 201047 20 Good Good Installed in May 201048 14 Good Good Installed in May 201049 15 Good Good Installed in May 201050 14 Good Good Installed in May 201051 14 Good Good Installed in May 201052 15 Good Good Installed in May 201053 15 Good Good Installed in May 201054 13 Good Good Installed in May 201055 13 Good Good Installed in May 201056 13 Good Good Installed in May 201057 14 Good Good Installed in May 201058 18 Good Good Installed in May 2010

TABLE B-5SUMMARY OF TREE/SHRUB OBSERVATIONS - RED MAPLE (Acer rubrum)



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and Stakes (where present) Comments

TABLE B-5SUMMARY OF TREE/SHRUB OBSERVATIONS - RED MAPLE (Acer rubrum)



59 16 Good Good Installed in May 201060 14 Good Good Installed in May 201061 15 Good Good Installed in May 201062 14 Good Good Installed in May 201063 16 Good Good Installed in May 201064 15 Good Good Installed in May 201065 16 Good Good Installed in May 201066 14 Good Good Installed in May 201067 16 Good Good Installed in May 201068 16 Good Good Installed in May 201069 15 Good Good Installed in May 201070 13 Good Good Installed in May 201071 14 Good Good Installed in May 201072 11 Good Good Vernal Pool, Installed in May 201073 10 Good Good Vernal Pool, Installed in May 201074 12 Good Good Vernal Pool, Installed in May 201075 12 Good Good Vernal Pool, Installed in May 201076 11 Good Good Vernal Pool, Installed in May 2010

Average Height (ft.): 13.2Height Range (ft.): 10-20Total Tree Count: 76

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Shrub Height (ft.) Condition of ShrubCondition of Tree Cage, Guard,

and Stakes (where present) Comments1 7 Good NA None2 8 Good NA None3 7 Good NA None4 7 Good NA None5 7 Good NA None6 7 Good NA None

Average Height (ft.): 7.2Height Range (ft.): 7-8

Total Shrub Count: 6

Note: There are no tree cages, guards, or stakes on these shrubs.

TABLE B-6SUMMARY OF TREE/SHRUB OBSERVATIONS - NORTHERN ARROWWOOD (Viburnum dentatum)


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and Stakes (where present) Comments1 5 Good Good None2 7 Good Good None3 5 Good Good None4 6 Good Good None5 6 Good Good None



TABLE B-7SUMMARY OF TREE/SHRUB OBSERVATIONS - WINTERBERRY HOLLY (Ilex verticullata)


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and Stakes (where present) Comments1 7 Good Good Vernal Pool2 6 Good Good Vernal Pool3 8 Good Good Vernal Pool4 7 Good Good Vernal Pool5 7 Good Good Vernal Pool6 5 Good Good Vernal Pool7 7 Good Good Vernal Pool8 6 Good Good Vernal Pool



TABLE B-8SUMMARY OF TREE/SHRUB OBSERVATIONS - DOGWOOD (Cornus sericea)


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and Stakes (where present) Comments1 10 Good Good Vernal Pool2 4 Good Good Vernal Pool3 4 Good Good Vernal Pool4 4 Good Good Vernal Pool, Installed in May 20105 9 Good Good Vernal Pool6 6 Good Good Vernal Pool



TABLE B-9SUMMARY OF TREE/SHRUB OBSERVATIONS - CHOKE CHERRY (Prunus virginiana)


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yz (1yz yz · the september 2011 inspection also included observations of trees and shrubs planted...

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