Attachment 1 YWR OandM Plan.pdf

5847 (7) CONESTOGA-ROVERS & ASSOCIATES

TABLE OF CONTENTS

Page

1.0 INTRODUCTION

1.1 BACKGROUND

1.2 SITE DESCRIPTION

1.3 REVISIONS TO THE OMMP

1.4 FILE MAINTENANCE

2.0 OPERATION AND MAINTENANCE PROGRAM

2.1 INTRODUCTION

2.2 ROUTINE INSPECTION AND MAINTENANCE

2.2.1 Inspection Schedule

2.2.2 Semi-Annual Inspection

2.2.3 Problem Identification and Corrective Action

2.3 MAINTENANCE

2.3.1 Grass Maintenance

2.3.2 Maintenance Shed

2.3.3 Surface Erosion/Washouts

2.3.4 Cover Settlement, Surface Cracking and

Miscellaneous Surface Failures

2.3.5 Groundwater Monitoring Wells

2.3.6 Fencing, Gates, Locks, Signs

2.4 POTENTIAL PROBLEMS

2.5 ROUTINE INSPECTION, MAINTENANCE AND

POTENTIAL PROBLEM REPORTING

3.0 MATERIAL SPECIFICATIONS AND PLACEMENT

3.1 GENERAL

3.2 VEGETATED SOIL COVER

3.2.1 General

3.2.2 Materials

3.2.3 Placement

3.3 MAINTENANCE SHED

3.4 GROUNDWATER MONITORING WELLS

3.4.1 General

3.5 PERIMETER FENCING AND SIGNAGE

3.5.1 General

3.5.2 Fencing

3.5.2.1 Materials

3.5.2.2 Installation

3.5.3 Perimeter Signs

3.5.3.1 Materials

3.5.3.2 Installation

TABLE OF CONTENTS

Page

4.0 LONG-TERM SITE MONITORING

4.1 GENERAL

4.2 GROUNDWATER MONITORING

4.2.1 Overview

4.2.2 Groundwater Monitoring Sampling and Analysis

4.3 MONOLITH PERFORMANCE VERIFICATION

4.3.1 General

4.3.2 Groundwater Monitoring

4.3.3 Treated Soil Mold Testing

4.4 QUALITY ASSURANCE/QUALITY CONTROL AND

PERSONNEL PROTECTION

4.5 LONG-TERM SITE MONITORING REPORTING

REQUIREMENTS

5.0 WASTE HANDLING PROCEDURES

5.1 GENERAL

5.2 POTENTIALLY PCB-CONTAINING WASTES

5.3 NON-CONTAMINATED WASTE

5.4 FINAL OMMP-RELATED WASTE REMOVAL

LIST OF FIGURES

FIGURE 1.1 SITE LOCATION RELATIVE TO BALDWIN

FIGURE 1.2 OPERATION, MAINTENANCE AND

MONITORING AREAS

FIGURE 2.1 INSPECTION SCHEDULE

FIGURE 2.2 INSPECTION LOG

FIGURE 2.3 MAINTENANCE RECORD LOG

FIGURE 3.1 VEGETATED SOIL COVER CROSS SECTION

FIGURE 3.2 TYPICAL EARTHEN BERM CROSS SECTION

NORTH AND WEST FACE

FIGURE 3.3 TYPICAL EARTHEN BERM CROSS SECTION

SOUTH AND EAST FACE

FIGURE 3.4 MONITORING WELL LOCATIONS

FIGURE 3.5 TYPICAL PERIMETER SIGN

LIST OF TABLES

TABLE 2.1 POTENTIAL PROBLEMS - VEGETATED SOIL COVER

TABLE 2.2 POTENTIAL PROBLEMS - GENERAL

TABLE 3.1 SEEDING MIXTURES

TABLE 4.1 LONG-TERM MONITORING SCHEDULE

LIST OF APPENDICES

APPENDIX A CONSENT DECREE

APPENDIX B MONOLITH AS-CONSTRUCTED DRAWINGS

APPENDIX C HEALTH AND SAFETY PLAN

APPENDIX D QUALITY ASSURANCE PROJECT PLAN

APPENDIX E WELL CONSTRUCTION LOGS

APPENDIX F TECHNICAL INFORMATION

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GLOSSARY OF TERMS

AMSL - Above Mean Sea Level AST - Aboveground Storage Tank ASTM - American Society for Testing and Materials BGS - Below Ground Surface BTOC - Below Top of Casing CD - Consent Decree - Civil Action Number 95-585-CIV-J-16 CERCLA - Comprehensive Environmental Response Compensation and

Liability Act CQAP - Construction Quality Assurance Plan CRA - Conestoga-Rovers & Associates DRMS - Defense Reutilization and Marketing Service FDEP - Florida Department of Environmental Protection FDOT - Florida Department of Transportation FS - Feasibility Study Group - Yellow Water Road PRP Group HASP - Health and Safety Plan IEA - IEA, Inc.

NTU - Nephelometric Turbidity Units O&M - Operation and Maintenance OMMP - Operation, Maintenance and Monitoring Plan OU-1 - Operable Unit One OU-1 RA WP - Operable Unit No. 1 Remedial Action Work Plan OU-2 - Operable Unit Two PCB - Polychlorinated Biphenyls PID - Photoionization Detector POC - Point of Compliance PPE - Personal Protective Equipment ppm - Parts per Million psi - Pounds per square inch QAPP - Quality Assurance Project Plan RA - Remedial Action RI - Remedial Investigation ROD - Record of Decision Site - Yellow Water Road Superfund Site, Baldwin, Florida SOP - Standard Operating Procedure SOW - Statement of Work TCLP - Toxicity Characteristic Leaching Procedure TSCA - Toxic Substance Control Act UCS - Unconfined Compressive Strength US ACOE - United States Army Corps of Engineers USEPA - United States Environmental Protection Agency WP - Work Plan µg/L - Micrograms per Liter

5847 (7) 1 CONESTOGA-ROVERS & ASSOCIATES

1.0 INTRODUCTION

1.1 BACKGROUND

On September 18, 1996, the Yellow Water Road PRP Group (Group) completed remedial construction activities at the Yellow Water Road Site (Site) located in Baldwin, Florida (see Figures 1.1 and 1.2). The final remedial action was conducted in accordance with a Consent Decree (presented without attachments as Appendix A) entered on October 11, 1995 (Civil Action No. 95-585-CIV-J-16). The Site was remediated to eliminate the potential for exposure to surficial soils and sediments containing PCBs in excess of 10 mg/kg.

PCBs were identified to be present at the Site during a Remedial Investigation and Feasibility Study (RI/FS). Pursuant to Paragraph XVI, Item 55.a. of the Consent Decree, the Operation, Maintenance and Monitoring Plan (OMMP) presented herein has been prepared to guide post-construction activities.

The operation and maintenance (O&M) program for the Site is designed to ensure that the integrity of the vegetative soil cover, underlying monolith structure, groundwater monitoring wells and miscellaneous items constructed or installed during implementation of the remedial action for Operable Unit 1 (OU-1, soils) and non-Contingent Operable Unit 2 (OU-2, groundwater) is maintained as required by the Consent Decree. The long-term monitoring program detailed herein was developed to ensure that the long-term monitoring activities required by the Consent Decree and Statement of Works (SOWs) attached to the Consent Decree are met and that the long-term performance standards for the remedial action are attained throughout the design life of this remedy.

The OMMP specifically addresses four major areas of concern with regard to post-construction activities. These areas are:

i) vegetative soil covered areas;

ii) site security;

iii) long-term monolith performance verification; and

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iv) long-term monitoring of the non-Contingent OU-2 (groundwater) remedy.

In addition, and pursuant to the OU-1 Remedial Action Work Plan, a schedule and discussion of future monolith and groundwater sampling events is presented herein.

Maintenance requirements for the Site include periodic inspections, scheduled maintenance, unscheduled maintenance and formal record keeping related to these activities. The periodic inspection requirements are detailed in Section 2.0. The procedures for implementing unscheduled maintenance are also presented and discussed in Section 2.0.

A copy of the as-constructed drawings for the monolith and overlying vegetative cover are presented in Appendix B to assist the reviewer and personnel implementing this OMMP.

1.2 SITE DESCRIPTION

As of September 17, 1996, the date of the remedial construction Pre-certification inspection of the Site, the Site was restored to its pre-construction condition with the exception of the newly constructed monolith.

Areas within and exterior to the former Operational Area (the area surrounded by chain link fencing) where soil excavation had occurred, were confirmed to contain no residual PCB contamination above the 10 mg/kg cleanup objective established for OU-1 (soils). Following excavation, these areas were backfilled with clean imported sand fill overlain by a 2-inch thick topsoil cover and rehabilitated with a vegetative layer to match surrounding conditions at the Site.

Areas utilized for the staging of materials, equipment, trailers, etc., were restored in a similar fashion and reseeded to promote vegetative growth. Fencelines, comprised of wood posts and barbed wire, were replaced along the northern and western property lines. Groundwater monitoring wells (twenty in total), installed during previous Site investigative activities or during the remedial

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construction period, currently exist at the Site. Eighteen of these monitoring wells will be sampled as part of the long-term groundwater monitoring program.

Within the fenced area, a mound measuring approximately eight feet in height at the highest point and covering an area of approximately 1.3 acres, identifies the location of the monolith structure. The mounded area consists of sod over a 12-inch thick topsoil layer, which is then underlain by cured cementatious material (treated soil). A permanent equipment decontamination pad was constructed at the eastern entrance to the fenced area and is adjoined by an aluminum maintenance shed and polyethylene tank. The maintenance shed houses molded samples of treated soil material and monitoring well sampling equipment and sundry supplies. Warning signs are placed along the perimeter of the fenced area to notify visitors of the presence of the treated soil material.

1.3 REVISIONS TO THE OMMP

Over the course of implementation of the O&M Program, revisions to the OMMP and tables and figures incorporated therein may be required. Such revisions shall be addressed by addendum to this OMMP.

Periodically this OMMP and its revisions will be reviewed by the Group or its delegate and all revisions incorporated into the OMMP. The frequency of integration of revisions to the manual shall be determined based upon Site-specific needs, as and when they arise. Such revisions shall be added as an addendum to this OMMP only if approved in a final form by the United States Environmental Protection Agency (USEPA).

1.4 FILE MAINTENANCE

In accordance with Paragraph XXXV, Item 145 of the Consent Decree, the Group must make available to USEPA and/or its representatives all records and documents which pertain to the implementation of remedial construction, post construction monitoring and maintenance of the

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Site for a period of at least six years after USEPA has certified completion of the Work (pursuant to Paragraph XVI, Item 55.b. of the Consent Decree) or until the thirty-sixth anniversary of the effective date of the Consent Decree, whichever is earlier. These documents include, but are not limited to, results of all sampling and tests, construction administrative records and Site maintenance records.

These documents shall be kept and maintained at a location to be designated by the Group. All document access shall be controlled through the Group.

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2.0 OPERATION AND MAINTENANCE PROGRAM

2.1 INTRODUCTION

A successful O & M program for the Site vegetative soil cover is dependent upon thorough semi-annual inspections of the Site. Failure to effectively identify problem areas limits the effectiveness of many of the remaining related measures contained within the O & M program. The primary intent of the semi-annual inspections is to identify and repair areas where the integrity of the OU-1 or OU-2 remedy has been compromised or has the potential of being compromised from weathering or other wear and tear artifacts.

In addition to natural deterioration of the vegetative soil cover, other on-going monitoring or maintenance activities may affect the integrity of the vegetative soil cover. Any work which may involve potential penetration of the vegetative soil cover (i.e. repairs) must first be approved by USEPA and must adhere to the protocols specified in the Health and Safety Plan (HASP) for the Site, previously presented in Appendix D of the USEPA-approved document entitled, "OU-1 Remedial Action Work Plan, Yellow Water Road Site, Baldwin, Florida"(OU-1 RA WP), herein included as Appendix C.

2.2 ROUTINE INSPECTION AND MAINTENANCE

2.2.1 Inspection Schedule

Inspections of the Site initially will be performed on a semi-annual basis (i.e. spring and fall) according to the schedule provided in Figure 2.1 and Table 4.1. Specific recommendations regarding alteration to the inspection frequency i.e. annual, may be made to USEPA at such time as to correspond with changes to the groundwater monitoring frequency. Every effort will be made to have consistent inspections by trained personnel who are familiar with the Site layout and RA.

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2.2.2 Semi-Annual Inspection

A complete and thorough Site inspection initially will be performed on a semi-annual basis (i.e. spring and fall). The semi-annual inspections shall consist of a complete Site walk of all access roads, perimeter security fence, monitoring well locations and the covered monolith. In addition, any woody vegetation observed to be present on the monolith's vegetative cover will be uprooted by hand and removed from the monolith during each semi-annual inspection.

Inspections performed will be recorded on the Site Inspection Log (Figure 2.2). Any maintenance performed as a result of the semi-annual inspections will be recorded in the Maintenance Record Log and kept on file at the designated file maintenance location. Figure 2.3 presents a typical Maintenance Record Log.

2.2.3 Problem Identification and Corrective Action

Should any problem be identified during the semi-annual inspections, the Site inspector shall refer to the corresponding item in Section 2.4 for a detailed description and appropriate corrective action. An additional heading marked "other" has been added to the Inspection Log to be used if unforeseen problems or concerns are identified by the Site inspector. If the inspector is in doubt about the impact of a specific item, the item will be recorded in the inspection log and the Group and USEPA notified so that appropriate measures may be taken.

2.3 MAINTENANCE

Required maintenance identified by the semi-annual inspections will be initiated as soon as possible, subject to the Force Majeure provisions provided by Paragraph XXVI of the Consent Decree. Maintenance items may include, but are not limited to, the following:

5847 (7) 7 CONESTOGA-ROVERS & ASSOCIATES

i) repair of surficial erosion and sloughing along the perimeter slopes of the monolith area;

ii) repair of areas of settlement or subsidence within the monolith area;

iii) repair of cover damage caused by burrowing wildlife, presence of deep-rooted weeds, or other foreign vegetation;

iv) repair or replacement of damaged groundwater monitoring wells or protective posts; and

v) repair or replacement of fencing, signs and locks.

Following inspection activities and identification of maintenance items, implementation of the recommended maintenance items will be scheduled through the Group or its delegate to be performed as soon as possible to quickly ameliorate the identified problem. Unforeseen problems identified by the inspection activities will be recorded and communicated to the USEPA and the Group. Further discussion of some of the routine maintenance activities summarized above is provided by the following.

2.3.1 Grass Maintenance

An important maintenance activity to be performed on the Site vegetative cover is periodic fertilizing and application of weed control.

Maintaining well rooted vegetation will limit the growth of deep-rooted plants, broad leaf and noxious weeds that may impact the integrity of the topsoil cover.

Approximately three acres of vegetative soil cover is designated to be inspected and maintained periodically. The vegetative cover will not be cut but will be allowed to grow to maturity. Washouts occurring, if any, on vegetative soil cover areas shall be repaired in accordance with this OMMP.

To ensure development and maintenance of a substantial root base, commercial fertilizer may be applied as necessary.

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During the semi-annual inspections, the Site will be visually inspected for noxious and deep rooting broad leaf weeds. Heavy weed growth may require the application of commercial, ready mixed herbicides to reduce weed growth. Weed control may be performed on affected areas by application of commercially available USEPA-registered herbicides in accordance with the labeling requirements. Application of weed control chemicals, if necessary, will be performed by a licensed and/or certified applicator. In addition, any woody vegetation observed to be present on the monolith's vegetative cover will be uprooted by hand and removed from the monolith during each semi-annual inspection.

2.3.2 Maintenance Shed

A maintenance shed is located within the confines of the former Operational Area and is located adjacent to the on-Site equipment decontamination pad. The maintenance shed houses treated soil samples (molds) collected during the construction of the monolith, as well as groundwater monitoring equipment and supplies.

The maintenance shed will be inspected during all periodic Site inspection rounds for signs of damage due to tampering, vandalism, weathering or aging. Repairs to the maintenance shed including replacement, if necessary, will be made promptly after identification of any deficiencies.

2.3.3 Surface Erosion/Washouts

The vegetative soil cover will be inspected on a semi-annual basis to identify areas of surface erosions/washouts. As identified by these inspections, surface erosions/washouts will be routinely repaired to prevent enlargement of the impacted area(s). All soil cover repairs will be performed as discussed in the appropriate subsections of Section 3.0.

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2.3.4 Cover Settlement, Surface Cracking and

Miscellaneous Surface Failures

The vegetative soil cover will be inspected on a semi-annual basis to identify areas of soil cover settlement, surface cracking, deep-rooted vegetation (i.e. palm tree saplings), burrowing animals and other surface failures or intrusions. Maintenance items identified through the Site inspections will be scheduled for repair as appropriate and maintained as discussed in the appropriate subsections of Section 3.0.

2.3.5 Groundwater Monitoring Wells

All groundwater monitoring wells at the Site will be visually inspected during the semi-annual inspection to identify any damage to the monitoring wells, protective outer casings or protective posts. Any damage, signs of tampering or vandalism of the groundwater monitoring wells will be recorded on the Inspection Log and reported to the USEPA and the Group so that appropriate repair measures can be implemented. All monitoring well repair work will be performed as discussed in Section 3.0.

2.3.6 Fencing, Gates, Locks, Signs

The security fence surrounding the monolith, related gates, locks and warning signs will be inspected during the semi-annual inspection to identify any areas of breaching and/or vandalism. Areas identified will be reported to the USEPA and Group so that appropriate repair activities may be scheduled. Site and monitoring well keys will be maintained as discussed in Section 3.5.1. All repair work will be performed as discussed in Section 3.0.

2.4 POTENTIAL PROBLEMS

This section summarizes the potential problems which may be identified during the semi-annual Site inspections. The appropriate corrective

5847 (7) 10 CONESTOGA-ROVERS & ASSOCIATES

actions to be taken are respectively identified. The specific areas of concern addressed in this section are as follows:

i) Vegetated Soil Cover (Table 2.1);

ii) General (Table 2.2), which includes:

a) perimeter fence;

b) signs;

c) monitoring wells; and

d) other miscellaneous items.

2.5 ROUTINE INSPECTION, MAINTENANCE AND POTENTIAL

PROBLEM REPORTING

During the course of implementing this OMMP, copies of the completed Site Inspection Logs and Maintenance Record Logs, as discussed herein, will be submitted to USEPA, FDEP, and DRMS within 30 calendar days of completion of the work task. In the event that an unanticipated repair and/or maintenance item is identified during the routine inspection, this will be duly noted by the Logs and appropriate corrective action(s) recommended by the transmittal cover letter addressed to USEPA, FDEP, and DRMS.

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3.0 MATERIAL SPECIFICATIONS AND PLACEMENT

3.1 GENERAL

The intent of this Material Specifications and Placement section is to present a brief discussion of the items constructed at the Site during the OU-1 and non-Contingent OU-2 RA. This information may provide a valuable guide in the event that repairs to the constructed remedy are necessary.

3.2 VEGETATED SOIL COVER

3.2.1 General

The typical vegetated soil cover for the monolith area consists of a 12-inch thick topsoil layer overlying a solidified/stabilized soil mass of approximately 8-feet in thickness. On the sloped perimeter of the monolith, the 12-inch topsoil layer is underlain by imported clean (less than 1 mg/kg total PCB concentration) fill consisting of locally available materials. A typical cross-section of the soil cover and underlying monolith is presented in Figure 3.1.

A typical cross-section of the north and west earthen berm structure and of the south and east earthen berm structure are presented in Figures 3.2 and 3.3, respectively.

3.2.2 Materials

All imported, clean fill used for backfill on Site is contaminant-free (less than 1 mg/kg total PCB concentration) sand conforming to the Unified Soil Classification System designations of SW, SP, SM or SC. Sand used for O & M activities must be tested for total PCBs prior to its use on Site in accordance with the Quality Assurance Project Plan (QAPP) for the Site, previously presented in Appendix H of the OU-1 RA WP, herein presented as Appendix D.

5847 (7) 12 CONESTOGA-ROVERS & ASSOCIATES

Replacement topsoil, if required, must be a loamy mixture free of roots, sticks, weeds, brush, stones, litter and waste products. It must contain not less than 12% or more than 50% clay, and not less than 1% or more than 10% organic matter. Prior to its use on Site, topsoil must be tested for total PCBs, particle size, moisture content, organic content and pH in accordance with the Construction Quality Assurance Plan (CQAP) and QAPP for the Site, presented in Appendices F and H of the OU-1 RA WP. Topsoil must also conform to Florida Department of Transportation (FDOT) Standards for Road and Bridge Construction, 1996 or any subsequent relevant amendments thereto.

The seed mixture must be as specified in Table 3.1.

3.2.3 Placement

The sand, as necessary to repair washouts, must be placed in layers of a thickness that will allow adequate compaction (sand) but not exceeding 6-inches in thickness. Each layer must be compacted to 98% standard Proctor density (pursuant to ASTM D698) prior to placement of subsequent layers.

The topsoil must be placed to provide a minimum of 12-inches rolled thickness and placed in lifts not to exceed 6-inches in thickness.

Topsoil may be fertilized uniformly over areas to be seeded in accordance with the applicable rates listed in Table 3.1. Repaired areas which are subject to erosion should be mulched or blanketed with erosion mat or jute netting to optimize seed germination and growth.

3.3 MAINTENANCE SHED

A maintenance shed has been constructed to house treated soil samples and monitoring well sampling equipment.

The maintenance shed shall be inspected for damage and functionality at each quarterly sampling event. Minor repairs will be made as required.

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3.4 GROUNDWATER MONITORING WELLS

3.4.1 General

A total of 20 groundwater monitoring wells, installed during the past remedial investigation, remain at the Site. In accordance with the non-Contingent OU-2 SOW attached to the Consent Decree, 18 of the 20 groundwater monitoring wells will be used for long-term groundwater monitoring. Of the 20 groundwater monitoring wells, nine were installed in the Upper Water Table Unit, nine were installed in the Lower Water Table Unit and two were installed in the Limestone Water Table Unit beneath the Site. Well construction logs for each of the groundwater monitoring wells at the Site are provided in Appendix E. Locations of all monitoring wells are identified in Figure 3.4.

During the performance of the semi-annual Site inspection events, all monitoring wells will be inspected for signs of damage, tampering or vandalism. Should minor damage be observed, repair work will be scheduled and performed as soon as possible. Should major damage (i.e. bent well casing) be observed, the USEPA and the Group's technical representative will be notified immediately. All observations will be recorded on the Inspection Log.

During the performance of the semi-annual inspection events, all on-Site equipment will be inspected for signs of damage, tampering or vandalism. Should minor damage be observed, repair work will be scheduled and performed as soon as practicable. Maintenance items for field equipment will be performed in accordance with the manufacturer's recommendations.

In the event that a monitoring well requires replacement, the monitoring well construction and installation procedures discussed in Section 2 of the USEPA-approved Supplemental Groundwater Investigation WP, dated January 1991, and all subsequent amendments, will be followed. In addition, USEPA will be notified, in writing, prior to commencement of any major repair or replacement work on the groundwater monitoring wells, to obtain approval.

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Technical information for the bladder pumps and air compressor is included in Appendix F.

3.5 PERIMETER FENCING AND SIGNAGE

3.5.1 General

Site security consists of an 8-foot high, 2-inch mesh chain link fence encompassing the perimeter of the former Operational Area of the Site.

The monolith is located within this fenced area. Swinging gates are located along the eastern fence line at the northeast corner and along the western fence line near the northwest corner of the monolith and are equipped with keyed padlocks. Keys for all Site padlocks will be maintained by the Project Coordinator or his/her delegate. The top rail of the fence is bordered with three tiers of barbed wire. The integrity of the Site fencing and gates will be maintained in good operating condition to ensure adequate Site security.

Perimeter warning signs are placed along the perimeter fence lines at a maximum spacing of 100 feet.

3.5.2 Fencing

3.5.2.1 Materials

The chain link used for fencing repairs will be two-inch mesh fabricated from nine-gage wire, 96 inches high; ASTM A392, Class II zinc coated or ASTM A491, aluminum coated steel.

Replacement fasteners will be metal bands or nine-gage steel wire galvanized in accordance with ASTM A641 Class III coating or aluminum.

Replacement line posts will be a nominal 2-5/8 inch O.D., Schedule 40 galvanized steel pipe weighing 3.65 pounds per foot.

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Replacement end and corner posts will be Schedule 40 galvanized steel pipe, 2-7/8 inch O.D., 5.79 pounds per lineal foot. The fence braces will be as follows:

- horizontal braces of 1-5/8 inch O.D. Schedule 40 galvanized steel pipe, connected corner to corner, and gate posts with suitable metal connections;

- horizontal braces at midpoint of fabric;

- diagonal brace rod from end of horizontal brace back to end, corner and gate posts, complete with turnbuckle; and

- bottom tension wire, 7-gage galvanized or aluminum coated steel.

Replacement top rails will be 1-5/8 inch O.D. Schedule 40 galvanized steel pipe with suitable metal connectors.

Replacement fencing will be fitted with three tiers of barbed wire.

Replacement gate posts will be 4-inch Schedule 40 galvanized steel pipe, 2'-8" higher than the height of the fence fabric.

Replacement gates will be double swing, consisting of two eight-foot wide by six-foot high sections. The gate frame will be constructed of 2-inch O.D. Schedule 40 steel pipe of all welded construction. The gate will be fitted with three tiers of barbed wire.

Fence post concrete footings will be 12-inches in diameter for line posts, 18-inches in diameter for end, corner and gate posts and will extend 6-inches below the bottom of the post.

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3.5.2.2 Installation

Replacement posts will be set a maximum of 10'-0" center to center. Line posts will be set 30-inches into the ground; gate and corner posts shall be set 42-inches into the ground. All line, corner and gate posts will be anchored in concrete as discussed above.

Each end, corner and gate post will be braced with one horizontal brace installed with diagonal brace rod and turnbuckle. The diagonal brace rod will be attached to the end, corner or gate post at bottom of fabric.

Where the fence line crosses drainage swales or other uneven areas, fabric bottom extensions will be placed to close openings to within three inches of final grade.

3.5.3 Perimeter Signs

3.5.3.1 Materials

Sign posts shall be 8-feet long steel U-channel sign posts made of high tensile steel, with prepunched 3/8-inch holes on 1-inch centers.

Replacement signs will be made of aluminum or steel. Signs will conform to the requirements for warning signs specified in Fla. Admin.

Code Ann. R. 62-736 and will be worded as follows: "WARNING! DO NOT

DISTURB SOIL! HAZARDOUS WASTE COVER. DANGEROUS MATERIAL

MAY BE PRESENT BELOW GROUND SURFACE. FOR INFORMATION

CONTACT USEPA REGION IV AT (404)562-8898". Typical sign dimensions and wording are detailed on Figure 3.5.

3.5.3.2 Installation

Replacement signs will be placed on sign posts 24-inches inside of the existing fence line to minimize vandalism of the signs. The signs will be spaced at a maximum spacing of 100 feet plus one at each Site access gate.

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The posts will be set at least 30-inches into firm ground. In unconsolidated ground, sign posts will be set in concrete. Signs will be fastened to the sign posts with 5/16" x 2 1/2" double washered, galvanized hex bolts and positioned so that the bottom of the sign is at least 44-inches above the existing ground surface.

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4.0 LONG-TERM SITE MONITORING

4.1 GENERAL

Post construction monitoring programs will include groundwater and monolith performance verification sampling as well as the semi-annual inspection events. The frequency and duration of the long-term monitoring program will be in accordance with the Consent Decree and all related attachments thereto.

All monitoring activities will be performed in accordance with the QAPP presented in Appendix H of the OU-1 RA WP, herein presented as Appendix D. Any changes in monitoring activities from those specified in the QAPP must be formally approved by USEPA. The monitoring event schedule is presented in Table 4.1. The intent of the following discussion on long-term Site monitoring is to familiarize the user of this OMMP with the program.

4.2 GROUNDWATER MONITORING

4.2.1 Overview

A long-term groundwater monitoring plan commenced in August, 1996 and will continue in accordance with the Consent Decree requirements. Samples will be collected in eight quarterly rounds during 1997 and 1998 from locations identified on Figure 3.4 and analyzed for total PCBs.

Following the completion of the eight quarterly rounds of groundwater sampling, a change in the frequency of sampling to semi-annual rounds for three years may be proposed to USEPA. Moreover, following completion of USEPA's five year review of the Site, the frequency of groundwater sampling may decline to annually. However, if the performance standards specified by the Consent Decree are met for OU-2 (i.e. the groundwater monitoring program will continue until PCB concentrations in all monitoring wells sampled are confirmed, through monitoring, to be less than 0.5 micrograms per liter (µg/L) in at least one sampling round) at any point during the long-term groundwater monitoring

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program, OU-2 groundwater monitoring, with the concurrence of the USEPA, may be terminated at that time.

If PCB concentration levels greater than 0.5 µg/L are confirmed, through consecutive sampling rounds, to be present in groundwater monitoring wells 10A, 10B, 12A, 12B, 13A or 13B (the point of compliance wells), the terms of the Contingent OU-2 SOW, attached to the Consent Decree may be implemented if required by USEPA. The Contingent OU-2 SOW would be implemented by the Settling Defendants during the 30-year period of post-remedial construction monitoring or by the settling Federal Agencies after the Settling Defendants' 30-year monitoring period, or if required, until cessation of the Consent Decree, whichever is earlier.

4.2.2 Groundwater Monitoring Sampling and Analysis

Groundwater samples shall be collected and analyzed in accordance with Sections 3.0 and 4.0 of the USEPA-approved Supplemental Groundwater Investigation Work Plan, and the QAPP attached as Appendix D.

The only modifications to these sampling protocols are that measuring groundwater turbidity as a field parameter will be added and that dissolved PCB samples will not be collected.

The procedures used to collect the groundwater samples are as follows:

� a new pair of nitrile gloves will be used to sample each monitoring well;

� prior to sampling, a minimum of three well volumes will be purged from each monitoring well using the dedicated bladder pump;

� field measurements of pH, conductivity, temperature and turbidity will be measured following the removal of each standing well volume;

� purging will be continued until a turbidity level of 5 NTU is attained or stabilization of the field parameters is achieved;

� blind duplicate samples will be collected at a minimum frequency of one in ten investigative samples;

� matrix spike/matrix spike duplicate (MS/MSD) samples will be collected at a frequency of one per twenty investigative samples;

5847 (7) 20 CONESTOGA-ROVERS & ASSOCIATES

� laboratory-supplied sample containers will be filled directly from the bladder pump discharge tube;

� collected samples will be labeled with a unique sample identification number and placed on ice in a cushioned shipment cooler; and

� samples will be shipped via overnight courier on a daily basis, under chain-of custody protocols, to the project laboratory.

Collected groundwater samples will be sent to the project analytical laboratory for analyses.

4.3 MONOLITH PERFORMANCE VERIFICATION

4.3.1 General

During the 30-year period of post remedial construction monitoring or until cessation of the Consent Decree, whichever is earlier, the Consent Decree requires that long-term monolith performance verification monitoring be conducted to verify that the integrity of the monolith is not compromised over time, due to the effects of weathering or other factors, and to ensure that the performance standards continue to be maintained. A discussion of all long-term monolith performance verification monitoring will be included in periodic progress report submissions to the USEPA.

A system of shallow and deep groundwater monitoring wells exists at the Site for the purposes of monitoring groundwater conditions.

Several of these monitoring wells are located within the confines of the former Operational Area (MW-6A, MW-6B, MW-6C and MW-11A). In addition, during the course of the OU-1 RA, a total of ninety-four (94) molds of the treated soil material were prepared and are stored on Site within the on-Site storage shed.

Both the shallow groundwater monitoring wells and the molded soil samples are required for successfully implementing the long-term monolith performance verification program as discussed in the following subsections.

5847 (7) 21 CONESTOGA-ROVERS & ASSOCIATES

4.3.2 Groundwater Monitoring

To ensure that the constructed monolith continues to retain PCBs in an immobile form, groundwater samples will be collected from the shallow groundwater monitoring wells located within the former Operational Area and directly beneath the constructed monolith (MW-6A and MW-11A).

Performance verification monolith samples will be collected on an annual basis and analyzed for total PCBs. Should PCB concentrations in groundwater samples collected from MW-6A and MW-11A be identified to exceed 0.5 µg/L, one additional round of groundwater samples will be collected from these monitoring wells to confirm the results of the initial round. In addition, a round of groundwater samples will be collected from Point of Compliance groundwater monitoring wells MW-12A and MW-13A during the confirmatory round to evaluate the potential for migration of PCBs beyond the former Operational Area.

4.3.3 Treated Soil Mold Testing

Should groundwater monitoring at MW-6A and MW-11A identify that a confirmatory round of sampling be required, as discussed above, during collection of the confirmatory round, one of the monolith samples (molds) will be taken from the on-Site storage shed and sent to the project analytical laboratory for Toxicity Characteristic Leaching Procedure (TCLP) PCB analysis. In addition, one mold will be sent to the project geotechnical laboratory for UCS analysis. The results from the testing of the molds, in conjunction with the analytical data for the groundwater samples, will be utilized in assessing long-term monolith performance.

At the conclusion of the 30-year period of post remedial construction monitoring or cessation of the Consent Decree, whichever is earlier, any remaining molds will be disposed of in conjunction with any remaining Site OMMP-related waste material as discussed in Section 5.4.

5847 (7) 22 CONESTOGA-ROVERS & ASSOCIATES

4.4 QUALITY ASSURANCE/QUALITY CONTROL AND

PERSONNEL PROTECTION

To ensure a high degree of quality for analytical data generated from the long-term monitoring events involving sample collection (groundwater and monolith samples), detailed and systematic procedures for sample collection, transport and analysis will be followed. These procedures are discussed in the Quality Assurance Project Plan, presented in Appendix D.

In addition, to provide Site personnel with appropriate protection from potential exposure to Site-related contaminants during sample collection events, personnel will follow the health and safety protocols established in the HASP, presented in Appendix C.

4.5 LONG-TERM SITE MONITORING REPORTING REQUIREMENTS

The analytical data results for all long-term groundwater and monolith performance verification sampling, as discussed herein, will be summarized and submitted to USEPA, FDEP, and DRMS within 30 calendar days following completion of the quality assurance/quality control validation of the final analytical data.

5847 (7) 23 CONESTOGA-ROVERS & ASSOCIATES

5.0 WASTE HANDLING PROCEDURES

5.1 GENERAL

During the performance of this OMMP, potentially PCB-containing solid and liquid waste materials, consisting of monitoring well purge water, decontamination washwater, sediment, spent personnel protective equipment and miscellaneous refuse, may be generated. In addition, non-contaminated waste materials may be generated.

5.2 POTENTIALLY PCB-CONTAINING WASTES

Solid and liquid waste materials potentially containing PCBs will be segregated and stored in 55-gallon steel drums, or other appropriate containers. The drums will be labeled and temporarily stored within a designated storage area near the decontamination pad at the Site in accordance with local, State and Federal requirements. The waste material will be sampled and profiled to be disposed of at an off-Site disposal/treatment facility permitted to handle such wastes. It is envisioned that only a small quantity of potentially PCB-containing waste materials will be generated annually. Therefore, shipments of such waste to off-Site disposal facilities will be scheduled to coincide with the performance of the semi-annual Site inspections.

Monitoring well purge waters will be stored in 55-gallon capacity steel drums, or other appropriate containers and temporarily stored on Site pending final disposition. Final disposition of the stored purge waters will be in accordance with local, State and Federal requirements.

5.3 NON-CONTAMINATED WASTE

During the performance of the OMMP, miscellaneous non-contaminated waste may be generated. Miscellaneous non-contaminated waste will be consolidated and placed in plastic garbage bags and the garbage

5847 (7) 24 CONESTOGA-ROVERS & ASSOCIATES

bags placed within the on-Site storage area. If left outside, the garbage bags will be placed into 55-gallon capacity steel drums, or other appropriate container, labeled (to identify contents as being non-contaminated) and sealed.

Non-contaminated waste will be removed from the Site on a periodic basis and disposed of as sanitary refuse.

5.4 FINAL OMMP-RELATED WASTE REMOVAL

Following cessation of the Settling Defendant's obligations regarding implementation of this OMMP, the Settling Defendants will ensure waste materials related to long-term monitoring (i.e. any remaining molds, purge waters, PPE, or sanitary refuse related to Site maintenance) will be removed and disposed in accordance with local, State and Federal requirements.

0 1/4

CRA

1/2 mile

•'11,,ldwin

\ I.

!'I.I >1111)1\ '· \ , )

5847( 7) NOV. 12, 96 REV.O ( C)

REBAR

D

32234

BASE SOURCE: STREET ATLAS USA, 1995

figure 1. 1

SITE LOCATION

RELATIVE TO BALDWIN

YELLOW WATER ROAD SITE

Baldwin, Florida

( , I

CAA

DENSE

WOODS

LEGEND

DENSE

WOODS

*MW-1.3A

*MW-1.38

V

MW-7A • UPPER SAND UNIT MONITORING WELL LOCATION AND IDENTIFIER

MW-78 .. LOWER SAND UNIT MONITORING WELL LOCATION AND IDENTIFIER

MW-7C • LIMESTONE UNIT MONITORING WELL LOCATION AND IDENTIFIER

* POINT OF COMPLIANCE WELL

MONOLITH

MAINTENANCE AREA

5847 (7) NOV 13/96(C) REV.O (P-23)

DENSE

WOODS

rv 1w,11

DENSE

WOODS

u

DENSE

WOODS

DENSE

WOODS

0 100 200ft f-> p figure 1.2

OPERATION, MAINTENANCE AND MONITORING AREAS

YELLOW WATER ROAD SITE

p

ACTIVITY FREQUENCY

INSPECT VEGETATED SOIL COVER/MONOLITH

1 SEMI-ANNUAL

INSPECT SITE SECURl1Y SEMI-ANNUAL

INSPECT MONITORING WELLS SEMI-ANNUAL

INSPECT VEGETATED COVER FOR WEEDS SEMI-ANNUAL

INSPECT MAINTENANCE SHED SEMI-ANNUAL

NOTE:

1 FOR AREAS TO INSPECT AND ITEMS TO INSPECT, REFER TO

THE INSPECTION LOG.

CRA

5847 (7) NOV 15/96(C) REV.O (C-16)

figure 2.1

INSPECTION SCHEDULE

Baldwin, Florido

Inspector:

Areas:

Inspect

Vegetated Soil Cover /Monolith

Monitoring Wells

Site Security Fence

Maintenance Shed

CRA

5847( 7) SEPT. 23, 9

INSPECTION LOG (SEMI-ANNUAL)

Date:

Perimeter security fence, vegetated soil cover/monolith and associated slopes, and groundwater monitoring wells.

Inspect for

Erosion/Washouts Exposed Areas Weed Growth Tree Growth Distressed Vegetation Ponding Animal Holes/Burrows Debris on Site Other

Integrity of Bollards Integrity of Casings Tampering, Vandalism Security of Locks Other

Integrity of Fence Integrity of Gates Security of Locks Placement and

Integrity of Signs Other

Integrity of Structure Tampering, Vandalism Security of Locks Other

REV.O(C)

Location Action Required Comments

Yes No Yes No Yes No Yes No Yes No Yes No

Yes No Yes No

Yes No Yes No Yes No Yes No

Yes No Yes No Yes No

Yes No

Yes No Yes No Yes No figure 2.2

INSPECTION LOG

YELLOW WATER . ROAD SITE

Baldwin, Aorida

MAINTENANCE RECORD LOG

DATE MAINTENANCE PERFORMED

CRA

5847 /7) OCT 03/96 /C) REV. 0 (C-17)

PERFORMED BY COMMENTS

figure 2.3

MAINTENANCE RECORD LOG

I �r-uq;.,.�, ���xx1

12"

VARIES

MONOLITH

/c:n, InlFIFn STABILIZED CONTAMINATED SOIL) v··--·-·· -�

VARIES

CRA

.till];; ON FLAT AREAS (PREVIOUSLY EXCAVATED AND BACKFILLED), USE MINIMUM 2-INCHES OF TOPSOIL COVER.

figure 3.1

VEGETATED SOIL COVER CROSS SECTION

YELLOW WATER ROAD SITE

5847 (7) SEPT 20/96(C) REV. 0 (D-11)

CRA

'" !, -., _,,,p,: I .._, "' 1 1 ./' � •-;_,, �� A,11: �� •� ,.� ,L. -�--, 7

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12" VEGITATIVE SOIL COVER

(TOPSOIL, SEED AND MULCH)

FENCE

. ' > ,�, -, ,r' � 01 ,.-.,.rl\ ,, 11-,,,, �- ,_,,,,·��-.._;�wYx '�Ir_;;, �', . ,,-__1,.., ;.; ·'< _,,J'_ �L.., '/':\1. :r.t�/ /;• -� ··... . 2.5

'-- 1

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. ''Ff.-' 1/i,.,.:, � -,-,; ,:,,_,, ::. , , 1�s, !.t1/' '' , i--:;;; ;_<::,: _: .. ', .. ·.\,._':. ·,,.,; , ... ··'·: :. ; __ ,.·. ·.

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BERM WITH CLEAN COMMON

FILL COMPACTED TO 98%

OF MAXIMUM DRY DENSITY

(ASTM D 698)

.:J£;s�:'.:Z;;�:�,['.;: t,;-. \::' >.}):) :•t: {{ :: !}�':}\\ {· f j(\ i •.· .. • ·•·•·. · · · _\,_� ?, .. ''rl y,,, ,,_, ;;;_v'l\z ,·., ... ,;. ·.··•· ... •,-- .. ·c:· ··:· .. -.·--: .. -· ..... --

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··.1·'.

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. ! 1 \ ... .._. ' "' k.

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.,, �-1-...,. .. .!::. - •

<«(%%%"</�%%"</'>%%«(%<$' 7·. '<<:<%%"</'>"</%"<1«���,<(/

EXISTING SUBGRADE BACKFILLED

AND GRADED TO EXCEED HIGH

SURFACE WATER LEVEL OF THE AREA

I I I I I I I I I I I I I I

NOTE: CLEAN COMMON FILL CONSISTS OF

WELL GRADED SANDS {SW), POORLY

GRADED SANDS (SP), SILTY SANDS (SM),

OR CLAYEY SANDS (SC) FREE OF

UNSUITABLE MATERIAL AND CONTAINING

LESS THAN 1 ppm PCBs figure 3.2

TYPICAL EARTHEN BERM CROSS SECTION

NORTH AND WEST FACE

YELLOW WATER ROAD SITE

Baldwin, Aorida

5847 (7) SEPT 20/96(C) REV. 0 (D-12)

FENCE

; l . ----/ I :_, ', /, r.:

< � '�- :,, '(./' � \�,:/;, -, (',,,! I� '-;::,;- \ ,/ )_

• ' 1 � ;,-';I '"!'::\1,. �,) > ��\?2,...,__

I 1'i' VEGETATIVE SOIL COVER

11\ !_,,)';- .

T' ,�, ·,, �

':'r- , -1,•:-c. (TOPSOIL SEED AND MULCH)

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/1 i'it1 ",;'/ _1 ,� - '<-;� <f".. / -,.__Co-. 1, >-C,.. BERM WITH CLEAN COMMON

,\;_�. "� ·1 ,-::::;_ 1:,, c' (i:;� �f ,.1 ;,:-::- / ;; . ·, / FILL COMPACTED TO 98% ·_ '.

-1(1"-r' 1-,-,; -'-1" ,''1 , 1-v:- '�,'.-,-C:\'-� "!:<: '_:· ., ... -:.. OF MAXIMUM DRY DENSITY . < �---: LJ,1· : ,,/1 l j- / - , >i,... . '\ :, " 1 -1- (/� , [7

1' : ,::_:,: ; ·./,:-·. '. :-;-.:.:_- ·_-:.·. �Q<>@....._ 1 (ASTM D 698)

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. , /, .'· SOLIDIFIED/STABILIZED x'-'i� Y.r;(. \. \./1., -', · ·; _; ,:,_:::.·>_ . :.;:: __ } ;' _.,-_.'-i-.'.·:·;'.:\:-\ -".'.,!'Q;,6)9')::,,,,_ /\ .. ,-111<._; .. CONTAMINATED SOIL ,,1 ,.? • _I -;--'.., .,: . .-·.:, .. ' .. -:' .. _;..., :,-.;·'·.· .. ,'.··'•:.· . ._-:--•; ·._;_._ .: .. ·; ,··.. DEPTH TO BE

"'/;I' /._ I ' I ' •••�•••••••�• • ••••--.•• ••••••,,••••• ,•J.•••••I•••••

} •• / I . ' i . f' . ,, ·'"' �':) / ,, /', . ·. : :.•.';, , . ·" ....... · ... ·.··· , .. : -·;·I ; . ,_ .• ·_.·.-. ' ••.. , ... :., . DETERMINED

--CJ�; :�,•-i�\. � ;:�"7� �,\ ;f",:-rJrir:,\�-:\ \>·.t\-r:,i:::::'.)!:?/;,)·:·:�fi:':t/ ·.:i�-,: _,._·:-,,, __

IN FIELD

7Z"<%%�%%%%%«::�%'-<(-:ff.$" I '<"«%%%'-<(�'«��%%«' / /////{///////..,//..,///-//4:-(/4,(/// /, /, / /// / ,.:/ /, / / ,/ /, /

EXISTING SUBGRADE BACKFILLED

AND GRADED TO EXCEED HIGH

SURFACE WATER LEVEL OF THE AREA

1•-CJ" I • , I

(TYP)

4'-6"

CRA

NOTE: CLEAN COMMON FILL CONSISTS OF

WELL GRADED SANDS (SW), POORLY

GRADED SANDS (SP), SILTY SANDS (SM),

OR CLAYEY SANDS (SC) FREE OF

UNSUITABLE MATERIAL AND CONTAINING

LESS THAN 1 ppm PCBs

5847 (7) SEPT 27 /96(C) REV.O (D-15)

(TYP)

figure 3.3

TYPICAL EARTHEN BERM CROSS SECTION

SOUTH AND EAST FACE

DENSE

WOODS

DENSE

WOODS

*MW-13A

*MW-138

V

DENSE

WOODS

u

DENSE

WOODS

I

0 100 200ft p p

F

MW-

---- ■ MW-7 -__ _l&Y-9A1

MW-10 �p p p p

(f::: ----------------------=-==--------------=========�

CRA

MW-78

'"• MW-7A

f W-SC .. RMW 68 -11A1\RMW -6A

* MW-128 ,. ,. MW-BB

• c:::::::i=ie[

I r, 0 \tMW-8A

*MW -12Aj ½t--✓�-o

LEGEND

TV DISH

DENSE

WOODS

MW-7A • UPPER SAND UNIT MONITORING WELL LOCATION AND IDENTIFIER

MW-78 '" LOWER SAND UNIT MONITORING WELL LOCATION AND IDENTIFIER

MW-7C • LIMESTONE UNIT MONITORING WELL LOCATION AND IDENTIFIER

* POINT OF COMPLIANCE WELL

5847 (7) NOV 13/96(C) REV.O (P-24)

DENSE

WOODS

DENSE

WOODS

figure 3.4

EXISTING MONITORING WELL LOCATIONS

2'

-rf

8'-0"

CRA

5847 (7) NOV 12/96(C) REV.O (D-14)

>-� HEAVY WEJGHT POST 1·

24"

·1

2'

-6

' I

.,. MINIMUM l WARNING!

(SANS SERIF,

DO NOT DISTURB SOIL ! GOTHIC OR BLOCK

TYPICAL)

,. MINIMUM

l HAZARDOUS WASTE COVER I

DANGEROUS IA TERIAL 11A Y BE

PRESENT eaow GROUtl> SURFACE

,· MINIMUM l FOR INFORIA TION

CONTACT USEPA REGION IV

(404)582-8898

..!iQIL SPACING BElWEEN ANY 1WO LINES SHAU. BE AT LEAST

EQUAL TO THE HEIGHT OF THE UPPER 1WO LINES.

LETTERING SHALL BE RED ON WHfTE BACKGROUND.

SIGN SHAU. BE IN ACCORDANCE WITH MOST RECENT

ISSUE OF FLA.ADMIN.CODE ANN.R.62-736.

24" figure 3.5

TYPICAL PERIMETER SIGN

Baldwin, Rork/a

TABLE 2.1

POTENTIAL PROBLEMS

VEG ET A TED SOIL COVER

YELLOW WATER ROAD SITE

BALDWIN, FLORIDA

Erosion

Potential

Problems Concern

Wash out of grass, topsoil, or sand Typically on slopes. Immediate action should be taken to prevent further erosion and exposure of underlying monolith.

Exposed Monolith Areas Potential for erosion.

Puddles Settlement of original cover. Standing water.

Bare areas once dryed up.

Dead/Dying Grass As with exposed areas, potential for erosion.

Weeds/Bushes Deterioration of grasses. Potential penetration through cover if left unattended.

Animal Holes/Burrows Safety hazard. Potential for soil erosion. Exposure of underlying monolith.

Action 1

Recover washed out soil. This material may be used to restore the eroded area. Backfill with additional soil to original cover design thickness (12 inches thick) consistent with this OMMP. Reseed, fertilize and mulch if slope revegetation, erosion control mat or jute netting placement is recommended.

Loosen and till topsoil. Reseed and mulch as necessary.

Restoration should be performed as soon as feasible.

Till topsoil and grade. Add additional topsoil if necessary.

Check final elevation to ensure adequate drainage. Reseed and mulch. If ponding is minor, grading of topsoil should be sufficient. If significant ponding is present, additional soil may be required.

Till topsoil and reseed. Cover with erosion control mat or mulch.

Remove all bushes and tall weeds. Reseed as required.

Contact local animal control department regarding trapping and removal of persistent rodents. Seal all holes with common fill. Replace topsoil, seed and mulch.

Required actions will be initiated as soon as possible, subject to the Force Majeure provisions in Article XXVI of the Consent Decree.

CRA 58-17 (7)

Potential Problem

Locks Secure

Perimeter Fence

Warning Signs

Bollards (Protective Posts)

Monitoring Well Casings (inner and outer)

General…