TABLE OF CONTENTS

1.1 General

In accordance with the Lemon Lane Landfill Statement of Work, Viacom Inc. (formerly known as CBS Corporation and before that Westinghouse Electric Corporation) has prepared this Inspection and Maintenance Plan (IMP). The IMP describes the activities to be performed to insure the integrity of the RCRA Subtitle C Cap and that the supporting features are maintained at Lemon Lane Landfill. Viacom will conduct the periodic inspections, perform the maintenance of the cap and also maintain the associated features according to this Plan. Quarterly Inspection and Maintenance Reports will be provided to the participating government agencies, including the United States Environmental Protection Agency (EPA), Indiana Department of Environmental Management (IDEM), City of Bloomington and Monroe County. These agencies and Viacom are collectively known as the Consent Decree (CD) Parties.

1.2 Background

1.2.1. Site Description

Lemon Lane Landfill (LLL) is located on the northwest side of the city of Bloomington in Monroe County, Indiana, in the northeast quarter of Section 31, Township 9 North, Range 1 West. The landfill location is shown on the General Site Location Map in Figure 1.

The original landfill area covered approximately 10 acres. Lemon Lane road and a residential area along Lemon Lane bound the east side of the landfill. The CSX Railroad tracks border the southern edge of Lemon Lane Landfill. Directly south of the railroad tracks is Valhalla Cemetery. Two privately owned parcels of residential property bound the landfill on the north. Viacom owns the undeveloped land to the west of the landfill. The Indiana State Route 37 by-pass is approximately 900 feet northwest of the landfill entrance. The Griffin property borders the southern portion of the east fence line of Lemon Lane Landfill. This property was remediated during the Lemon Lane remediation.

Lemon Lane Landfill is situated in a broad shallow surface depression interpreted to be associated with a compound sinkhole. The compound sinkhole runs northeast to southwest and extends to the southwest of the Lemon Lane site beyond the CSX Railroad. The site is located near topographic divides between the headwaters of Clear Creek to the southeast, Stout's Creek to the northwest, and Griffy Creek to the northeast.

Mississippian age bedrock units underlie the landfill. The St. Louis Limestone of the Blue River Group underlies the overburden layer, and beneath this unit lies the Salem Limestone of the Sanders Group. The St. Louis Limestone has undergone weathering and solution channeling to create a karst terrain in and around the Lemon Lane. In particular, the karst characteristics produced the compound sinkhole system associated with the landfill site.

Topographic features identified in the vicinity of Lemon Lane Landfill include sinkholes, caves, three surface streams (Clear Creek, Stout's Creek and Griffy Creek) and associated tributaries, perennial and intermittent springs, and at least one sinking stream. A sinkhole pond, Sargent's Pond, is located northwest of the site. Sargent's Pond serves as the surface water drain for a majority of the site and the surrounding area. Springs identified in the area include Illinois Central Spring (ICS), Quarry, ICG-1, ICG-2, ICG-3, Packinghouse (PH) Road, PH Culvert, and Slaughterhouse Springs.

Recharge to the groundwater flow system below the landfill is believed to occur primarily through sinkholes and swallow holes typical of karst terrain. Groundwater is believed to flow primarily through solution-enlarged fractures and joints to the south and east of the site and eventually drain at a series of springs. The main drainage spring is Illinois Central located about 2500 feet to the south of the landfill.

1.2.2. Site History

Lemon Lane Landfill began operation as a refuse dump in 1933. The City of Bloomington operated the landfill from 1950 to 1964 as a municipal waste landfill. It was also used as a repository for industrial debris and waste. Electrical capacitors from Westinghouse's Bloomington manufacturing plant were deposited in Lemon Lane Landfill from 1958 to 1964 by contracted local waste haulers.

Landfill operations were typical of the period with the absence of controls and design features common to modern facilities. No liner or cover was used. Dumping was not controlled with regard to waste content or record keeping. Scavenging and burning were common daily practices. Local residents routinely scavenged capacitors on or from the site To ensure salvagers would not interfere with dump operations, items such as capacitors would be placed at the south and west edges of the landfill where scavenging activities would occur.

In 1987, interim removal and remedial measures were implemented to minimize any immediate threat to public health and the environment. Surface capacitors were removed and eroded slopes were graded and stabilized. Clean fill was placed over the landfill surface followed by a 36-mil Hypalon geomembrane cover. The interim cover was maintained by Viacom until 2000.

A Statement of Work (SOW) was agreed to by all the Consent Decree parties on May 15,2000 and set forth the requirements for implementation of the site closure. The SOW required the removal of specific "hot spot" volumes containing PCB contamination and the subsequent sampling of the remaining surfaces after hot spot material removal to verify that the clean criteria was met.

Viacom prepared a Remedial Design/Remedial Action Work Plan (WP) for the Lemon Lane Landfill that met the requirements of the SOW. The anal WP was issued on May 17, 2000, with hot spot removal starting immediately after WP approval.

The SOW also required that a RCRA Subtitle C cap be constructed over the waste material that remained on site. The cap was described generally in the May 17 WP (30% design) as required by the SOW. A final cap design report was prepared and issued by Viacom on October 18, 2000, which describes the details of the cap installation. This report also includes drawings and detailed specifications for the anal RCRA Subtitle C cap materials and construction. The cap construction was completed in November 2000. A final report for the remediation and closure of Lemon Lane Landfill was prepared by Viacom and describes the remediation activities and the RCRA cap installation. The report was sent to the CD parties in March 2001 for review and approval. It includes documentation and as-built drawings for the site. A photograph of the completed site that highlights the major features is included in Figure 2.

1.3 Description of Site Closure

1.3.1 RCRA Subtitle C Cap

As part of the site closure, hotspot material was removed from the site and the remaining waste material was consolidated within the new landfill footprint. The original landfill footprint was reduced from approximately 10 acres to a RCRA capped area of 5.3 acres. Material that remained on site for consolidation was placed within the new limits of consolidation (LOO) in controlled lifts. Each lift of consolidation material was compacted to minimize post-construction settlement and achieve a firm surface for the RCRA cap. The surface of the waste material was graded to facilitate positive drainage away from the cap system. The final waste surface was inspected for objects that could potentially damage the geosynthetics. When encountered, such material was removed and buried within the waste at an appropriate depth. Following compaction of the waste material, a cushion soil layer was placed and compacted above the waste surface to provide a uniform 12 inch bedding layer. This bedding layer served as the subgrade for the RCRA cap components.

The RCRA Subtitle C compliant cap installed over the consolidated waste is a multi-layer design and meets the requirements of 40 CFR Part 264.300. The RCRA cap components consists of (starting at the upper most surface): 6 inches of topsoil, 18 inches of clean non-plastic granular fill, a geocomposite drainage layer, a minimum of 40 mil LLDPE geomembrane liner, and geosynthetic clay layer (GCL) equivalent to at least a 2 foot compacted clay barrier. These various layers are shown in Figure 3, which is an aerial photograph of the site during construction.

The soils above the geocomposite support vegetation and provide protection for the geosynthetic components of the cap. The geocomposite drainage media consists of an HOPE drainage grid sandwiched between two layers of non-woven geotextile fabric. The geocomposite was placed over the entire cap and extended into the drainage features around the perimeter of the LOC. The function of the composite material is to collect surface water that percolates through the vegetative support zone soils. The drainage material extends into the riprap that lines the perimeter channels and also through the bench between the retention pond and the LOC on the west. Water collected in the geocomposite material drains into the channel or the retention pond. Below the geocomposite is the geomembrane and the GCL. These two components form a water impermeable barrier to protect the remaining landfill waste from surface water.

Six piezometers were installed at selected locations within the final limits of the geomembrane liner. The piezometers were installed to monitor for the presence and level of groundwater below the waste or backfill material. Penetration seals through the geomembrane were fabricated at each of the piezometer locations to form a boot. At each location a penetration seal was fabricated using the geomembrane material. The boot was extrusion-welded to the geomembrane at the base of the piezometer pipe. At the top of the pipe a neoprene gasket material was placed between the boot and the riser pipe and two stainless steel hose clamps were used to clamp the boot to the pipe. This same booting procedure was also used around the utility pole located between the LOC and the western perimeter channel. Photographs of the boots around the piezometer and the utility pole are included in Appendix A.

The locations of the piezometers are shown on the attached Figure 4. This figure also depicts the surface and subsurface features associated with the cap system.

1.3.2 Surface and Subsurface Water Controls

Two major components were installed to control water associated with the RCRA cap. A perimeter channel was constructed around the cap to collect subsurface and surface water. A subsurface drainage media (geocomposite) was installed above the geomebrane and extends into the perimeter channel.

A perimeter channel was constructed beyond the LOC. After excavation the channels were lined with a non-woven geotextile. The geomembrane lining from the cap was extended through the bottom of the channel and anchored at the outside perimeter of the channel. The surface of the geomebrane in the channel was covered with a layer of non-woven geotextile prior to placing the rip rap in the channel. The perimeter channels were constructed as presented in the Golder Final Gap Design Report. Surface run-on and run-off water has been directed to the perimeter channel. Water collected in the geocomposite component of the RCRA cap enters the channel below the rip rap. The high point of the channel is located along the east side of the site. Water flows from that point around the south or north perimeter channels adjacent to the landfill to the retention pond located on the southwest corner of the site. The final as-built configuration of the surface water controls is shown on Figure 4.

1.3.3 Retention Pond and Subsurface Drainage

Water collected in the perimeter channel is directed to the retention pond that is located at the southwest corner of the site. The retention pond is designed to retain approximately 82% of a 10 year, 24 hour storm. The retention pond was excavated into the native clay at this location. Construction of the pond is similar to the perimeter channels. Once excavated, the bottom of the pond was first covered with non-woven geotextile, then seamed geomebrane and then another layer of non-woven geotextile. The geosynthetics are covered by rip rap down the center and vegetative cover soil over the remainder of the bottom and side slopes. The geomebrane was placed in an anchor trench that was located on a benched surface above the water level along the south and west perimeter of the pond. The purpose of placing the geosynthetics over the clay bottom was to limit the possibility of standing water eventually piping into the soil.

A drainage structure at the north end of the pond controls the release of water out of the pond. A 24 inch concrete reinforced pipe carries water from the drainage structure in the retention pond to an outlet at the south edge of Sargent's Pond. An outlet structure was constructed to minimize erosion at the end of the pipe and to direct the water to Sargent's The structure consisted of a flared end to the 24 inch concrete pipe, a Reno mattress and rip rap. A photograph of the retention pond drainage structure and the outlet to Sargent's Pond are included in Appendix A.

1.3.4 Surface Drainage Outside of Perimeter Channels

Prior to the remediation activities, during heavy rains, water ponded on Lemon Lane road at the northeast corner of the site. After remediation, as part of the final grading beyond the perimeter channel, a swale was cut from the road to the perimeter channel. The swale was lined with 20 mil PVC and covered with rip rap. In a portion of the swale sufficient rip rap was added to allow the swale to be crossed by mowing equipment and light weight maintenance vehicle.

1.3.5 Site Restoration

All surfaces disturbed during excavation and construction were graded and covered with topsoil as well as the cap surface. Once the surface of the topsoil was prepared, the soil was covered with hydromulch that contained seed and fertilizer. A seed mixture of 80% fescue and 20% rye was used with a fertilizer mix of 18-24-12. The application rate per acre was as follows:

The mulch was composed of 100% wood fiber. The tackifier provided a bonding agent to hold the wood fibers together. The polymer works in conjunction with the tackifier to improve bonding of the tackifier. The polymer also helps to hold moisture to promote seed growth by releasing the moisture as needed. The polymer will also continue to re-absorb and release moisture for several years, thus further supporting vegetation.

Because the completion of the cap and seeding occurred beyond the typical growing season, additional erosion control techniques were employed. A biodegradable erosion mat was placed over slopes that were over 10% or in areas where storm water might concentrate These areas can be seen in the photograph of Figure 2 as the green surfaces along the perimeter channels and retention pond. To help minimize erosion and the carryover of sediment into the perimeter channels, sediment control fence was installed. The fence can be seen in Figure 2 as a thin black line around the perimeter of the erosion mat and the edge of the perimeter channels. The fence will be removed once vegetation is established over a majority of the surface.

1.3.6 Security Fence

(Following paragraph describes the fence that will be installed at the location described. The fence installation will be done during the spring of 2001.) A 6 foot high chain link fence with three strands of barbed wire across the top secures the perimeter of the site. The bottom edge of the fence includes an aluminized tension wire to anchor the lower portion of the fence. The security fence generally encompasses the outside edge of the perimeter channels, the retention pond, Sargent's Pond and established service areas to the west of the capped area. Equipment gates are located on the northwest across the access road leading from Vernal Pike and on the east directly across from Gray Street. A smaller access gate for personnel and equipment is located at the southwest corner of the~fence line. The gates are secured using a chain and keyed lock. The fence line and gate locations are shown on Figure 4.

1.3.7 Natural Gas Line Installation

Paralleling the old perimeter fence along the south and a portion of the east was a natural gas pipeline buried some three to five feet deep. Prior to hot spot excavation activities, the gas company abandoned the portion of the pipe that was within the old fence line of the landfill. The abandoned pipe was removed during the excavation removing the PCB contaminated materials. After the area was verified to be clean and backfilled with clean soil, the gas company's installation contractor returned to install a new section of gas line and re-connect the line. The new location closely follows the location of the original line. The location of the new gas line was surveyed and is shown on Figure 4. The new fence line is located so that access to the gas line for future maintenance is outside the controlled area associated with the landfill and drainage features.

1.3.8 Permanent Survey Benchmarks

Permanent survey benchmarks were established as survey control points by Smith Neubecker & Associates, Inc. (SNA) at locations outside the cap at the Lemon Lane site. A table included on Figure 5 provides the northing, easting and elevation for each control point. These control points can be used to establish coordinate and elevation control for the purpose of future cap monitoring activities.

The benchmarks are typically associated with monitoring well physical features (top edge of pipe casings or concrete surfaces). Care must be taken to preserve these points when working on monitoring wells.

2.1 Vegetative Layer and Access Roads

2.1.1 Description

The cap was shaped and contoured to insure that surface water runs off the surface and does not pond across the cap. Once the grass is established it will insure that erosion is minimized and controlled. The landfill cap was seeded with a fescue and rye grass mixture. Fescue is a perennial type of grass, which grows consistently from year to year with proper maintenance. The fescue will require periodic mowing. Water that drains from the cap is collected in the rip rap lined perimeter channels. The perimeter channels drain to the retention pond. The soil bottom of the retention pond was seeded as well as the disturbed areas beyond the cap.

The main access road was constructed using crushed limestone aggregate. Larger aggregate was used for the base and smaller aggregate on top as a traffic surface. The access road surface has been shaped and sloped to drain. A small gravel parking and service area is located adjacent to the western perimeter channel south of Sargent's Pond Perimeter channel crossings were installed to accommodate vehicle traffic for inspection and maintenance activities. A picture of one of the northwest crossings is contained in Appendix A. The eastern crossing adjacent to Lemon Lane Road is of similar construction.

2.1.2 Maintenance

The establishment of the grass cover may require isolated reseeding during the first two or three years of growth to assure that a long term grass surface is adequately established. As time goes on, areas may need to be re-seeded due to maintenance, vehicle traffic or extreme weather conditions. If reseeding is required, the fescue should be applied at a rate of 220 pounds per acre. Depending on the time of year, an annual rye may be mixed with the seed application at a rate of about 20 pounds per acre. In areas of limited growth, the topsoil may require analysis to determine nutrient value and acidity Several samples are to be taken as required across the area of concern and composited to obtain a representative sample. Soil analysis can be obtained through the local County Extension Office. Amendments to the soil will be added based on the analytical results of the sample. The seed and any required fertilizer can be included in a hydromulch mixture. The vendor of the hydromulch can provide a recommendation of the rate of application of the hydromulch Prior to application of the seed the surface of the topsoil may need to be prepared to provide an adequate base to accept the seed. Preparation of the surface may include scarification of the top several inches of soil or a layer of topsoil may need to be applied In areas where severe erosion has occurred or where water flow is concentrated, placement of erosion mat should be considered to aid in stabilizing the soils until grass can be established

Fescue was chosen for the low maintenance characteristics; however, periodical mowing will be required. All the grass surfaces will be mowed inside the final fence line and immediately outside the fence perimeter. A mower width, approximately 4 to 6 feet, will be cut around the fence on the outside. Grass cover height should be maintained between 12 to 18 inches. The grass-mowing season usually begins in late April or early May after the last frost and continues through the summer until late September or early October after the first frost. Mowing will be limited during extremely hot dry weather. It is anticipated that mowing will typically be done twice a year. The precautions for this maintenance are outlined below.

A hand held gas powered weed cutter can be used along the fence line, at the edges of the piezometer concrete pads, along the edge of the perimeter channel and for vegetation growing in the channel or retention pond Care is to be exercised when operating power equipment on the uneven rip rap surface of the perimeter channel. An application of herbicide can be used to further control vegetation growth at the fence line and in the channel. A herbicide such as Roundup or an equivalent glyphosate based material will be used. This is a systemic non-selective herbicide that has no residual effect and is non-restricted. Being non-selective, this type of herbicide will kill any vegetation that comes in contact with the initial application. All applicable state regulations related to the storage, handling and use of this type of herbicide are to be followed. Herbicides are not to be sprayed over standing water that may have accumulated in the perimeter channels or in the retention pond.

There are obstacles across the site which must be avoided during mowing operations. These obstacles include the following:

• Piezometers and the associated concrete pads that are located on the surface at six locations.
• Rip rap lined ditches for surface water control that are located around the perimeter of the cap surface.
• Retention pond slopes and soil lined bottom. Utility pole located near the perimeter channel along the west edge of the LOC
• Perimeter fence and gates

The piezometers extend above the surface of the concrete pads. Highly visible painted protective bollards have been installed around each of these devices. Movement of maintenance equipment on the pads is to be avoided. Mowing equipment is to maintain a safe distance from the fence or open gates. Heavy mowing equipment is to be kept away from the soil/rip rap interface at the edges of the perimeter channels. This interface could be damaged or the rip rap could be dislodge and pushed away from the edge. Caution should be taken when mowing steeper slopes, such as the slopes associated with the retention pond when the surface is soft or wet due to rain. This may damage vegetation or be unsafe for personnel and equipment operation. Also, the soil at the bottom of the retention pond, may remain wet longer than other surfaces on the site. Heavy mowing equipment should be used with caution on the pond soil surface to avoid creating ruts or damaging vegetation. The utility pole with the geomembrane boot is located at the edge of the bench just east of the retention pond. The pole and boot are shown in a picture included in Appendix A Only a small portion of the boot is exposed However, contact with the boot by mowing equipment is to be avoided. The operator must immediately report to the Viacom representative any damage that is caused by maintenance equipment to any of these components or other structures.

Damage to the utlity pole boot is to be reported immediately to the Viacom representative.

2.1.3 Inspection Plan

Routine inspection of the landfill cover and surrounding area provides indications of grass growth thickness and overall health. Key times for inspection will be early spring after the last frost and early fall. These two times offer the best opportunity to observe grass conditions and to implement repairs. In addition to the routine inspection, the mower equipment operator should observe the condition of the vegetation during the grass-growing 'season and provide some information, The mower operator is to be made aware that turf conditions are to be observed and reported.

As the cap cover is being inspected for grass growth, the fence line and the rip rap surface of the perimeter channel are to be observed to evaluate the extent of vegetation growth, Excessive grass growth, weeds or vines are to be recorded on the quarterly report, The Viacom representative can make a decision whether to cut or to spray the fence line and channel.

The road surfaces and berms will be inspected for erosion and signs of soft or deteriorating conditions. Routine inspection will be done quarterly, Besides routine inspection, deteriorating surfaces can become apparent when heavy maintenance equipment is operated or transported along these roads, Contractors that use these roads are to advise the Viacom representative immediately if any access road damage occurs.

2.2 Landfill Cover

Maintenance of the landfill cover consists of periodic inspection and repairs of the RCRA cover system due to erosion' burrowing animals, frost, etc. Also, differential settlement across the surface of the cover will be identified, monitored, evaluated and repaired as required. This section provides the basic instructions for inspection and repair of the cover and quality assurance procedures to ensure proper repair.

2.2.1 Description

The RCRA cover consists of 24 inches of cover soil placed over the synthetic geocomposite drainage layer, In general the cover soil consists of 6 inches of topsoil and 18 inches of cap cover soil, The specifications for each of these are contained in the Golder Final Cap Design Report dated October 18, 2000. The specification for topsoil is Section 02225 and the cap cover is Section 02224. Once construction of the cap system was~complete, the as-built surfaces of the landfill were surveyed The surface contours generated from that survey are shown in Figure 5, Survey Grid System and Cap Thickness Verification Data. This figure also presents surface data on a grid basis and contains a table that verifies the cover soil thickness. This data can be used to check cover thickness or surface variations that may be attributed to erosion or differential settlement. Some uniform settlement of the landfill is anticipated over time. Geonet drainage, layer failure or some differential settlement below the cap system could cause localized subsurface change and a subsequent change in elevation.

2.2.2 Maintenance

Several conditions can impact the landfill cover integrity. This section discusses the evaluation and maintenance to be implemented.

Burrowing animals present a special problem for ensuring the integrity of the landfill cover. Once a burrow has been located, it may be helpful to identify the animal species responsible. The offending animal(s) must be removed as quickly as possible to prevent further damage. It may be helpful to consult the U.S..Fish and Wildlife Service or other experts for recommended control or removal methods. After the animal has been removed, the burrow is to be inspected to determine if the underlying geonet has been damaged If the geonet is damaged, a sufficient area of the cover must be removed to repair this drainage layer. Following repairs, the soil is to be replaced to the original condition and seeded. The size of equipment to be used will depend on the size and nature of the repairs When operating maintenance equipment on the cap surface above the geocomposite layer, there must be a minimum of 12 inches of cover soil between the tracks or tires of the equipment and the geocomposite. The equipment must be low ground pressure type with a maximum of 5-psi contact pressure.

Erosion is one of the most common problems that will impact the landfill cover. Typically erosion can be expected to occur at the bottom of long slopes, at the toe of the side slope of the soil cover and where water tends to concentrate due to the grading. Repairs need to be made immediately upon discovery of the erosion If weather does not permit immediate repairs, interim stabilization of eroding areas with geotextile mesh, silt fence or straw bales is important to allow time to implement more permanent measures. Permanent repairs of erosion may include re-grading to redirect water flow or adding soil to attain the original grade and covering with erosion mat after re-seeding.

An important component of the cap system is the geocomposite drainage layer. The function of the geocomposite drainage layer is to remove water that infiltrates through the overlying soil cover. There are a variety of mechanisms that may cause the drainage layer to fail. Types of failure mechanisms include differential settlement, deterioration of the synthetic materials and exceeding flow rates of the geonet. The failure may be manifested as a surface depression.

Determination as to whether a surface depression is due to differential settlement or drainage material failure can be made with the aid of the information on Figure 5 of this Plan. Elevations of the various cap components are listed in the table on Figure 5. The top of the cushion soil listed in the table is about the same elevation as the geocomposite for the purpose of this determination. Surveying the top of the soil cover or removing sound surveying the top of the geocomposite will provide elevation information to help determine the source of the depression. If there is a failure in the geocomposite, the elevation of the geocomposite should be close to the elevation of the cushion soil value in the table.

If damage to or deterioration of the geocomposite has caused the depression, a detailed evaluation must be conducted to determine the mechanism. Perimeter channels are to be inspected for any signs of sediment release that may have come through the geocomposite material, The extent of the damaged area of the geonet must be determined prior to repair. The cover soil composition may need to be adjusted in this localized area based on location and length of slope.

Based on the survey data, if there is a depression below the geosynthetic cap material, more frequent monitoring to determine the rate of change of the elevation will be required. The evaluation will include monitoring the change in elevation and determining if the horizontal extent of the depression changes. Based on obtaining more data on the rate of change, a plan can be prepared to further define the actions to be taken. The plan may include the following:

• Review of available subsurface data for the area below and around the depression including:
  • Review of boring logs.
  • Determine thickness and composition of waste.
  • Identify the depth and characteristics of bedrock,
• Observation of any change in sediment loading at the retention pond, Review any available geophysical investigation information for the area associated with the depression.
• Consider the use of geophysical investigation techniques to further evaluate subsurface conditions.
• Borings through the geosynthetic cap to evaluate the characteristics of the materials below the cap.

It should be pointed out that the locations of the piezometers could provide a reference for subsidence investigations, Sets of piezometers were installed along the compound sinkholes that have been identified at the subsurface of the site, At the southern sinkhole piezometer PZ-AS was installed at the deepest part of the fill-soil horizon and PZ-AD at the deepest bedrock location associated with this sinkhole, At the northern sinkhole PZ-BS is located at the deepest fill-soil horizon and PZ-BD is at the deepest bedrock location that has been identified with this sinkhole.

The implementation of any of the above evaluation actions will be predicated on establishing the rate of change of the depression size. Viacom will prepare a proposal outlining the steps for further evaluation in the event the change is significant. This proposal will be provided to the government representatives for review and discussion.

2.2.3 Inspection Plan

Visual inspection of the cover for burrowing animals consists of traversing the cover in an organized pattern to discover holes and/or mounds. The perimeter fence line must be inspected for holes and burrows. The condition of the three strands of barbed wire and the tension wire at the bottom of the fence must be noted. Visual inspection for burrowing animals, fence condition, erosion, and subsidence will be conducted quarterly.

When inspecting the surface for erosion, focus should be placed on the areas where water may converge or concentrate and points along slopes where water volume or velocity may increase Sediment accumulating in rip rap drainage ways is an indication of the severity and type of erosion that is occurring. The degree of sedimentation should be checked during each inspection and reported. Characteristics of the sediment are to be noted, such as color and type (i.e., gravel, sand, silt, clay). This may help to locate the source of the erosion if the source is not immediately obvious.

The drainage layer is located below 24 inches of cover soil. However, signs of potential problems associated with the drainage layer can occur at the surface and include:

• The presence of isolated depressions on the landfill surface
• The presence of ponded water or ice on the landfill surface
• Erosion of topsoil or general fill.
• Wash out of cover material and subsequent signs of the material accumulating locally in the perimeter channels.

As described in the previous section, depressions can also be caused by differential settlement of material below the landfill cap system.

Two steps will be taken to inspect for surface depressions. One will be a topographic survey of the cap surface and the other will be regular visual surface inspection The survey will measure the elevations at the survey points shown on Figure 5 of this plan The northings and castings for each survey point are listed in the table included on this drawing The elevations listed in this table are the elevation at the time the cap was completed. During the first year, some uniform settlement would be expected Also, through the first year some modifications may have been implemented to repair or improve construction As a result, a baseline survey will be conducted early in 2002. Biannual surveying will continue through 2010. These surveys will be compared to the baseline data from the 2002 survey. The surveyor will prepare a table after each survey that compares the data obtained to previous data. This data will be provided with the subsequent quarterly inspection and maintenance report. Based on the data obtained through 2010, a decision will be made at the ten-year review on the need for additional surveys.

In addition, local surveys will be conducted to update the information at points where grading was changed, material was added due to erosion or changes were made in drainage configurations.

The surface of the landfill will also be visually inspected quarterly. The inspector will traverse the site walking either in the east to west or north to south direction in parallel paths approximately 100 feet apart. The inspector will alternate direction for each inspection. In addition, the mower operator will have an opportunity to observe the cap conditions during regular mowing of the grass. At this time the operator will traverse all surfaces. The Viacom representative will make the mower operator aware of the type of conditions to lao.R for. Any poor quality grass areas, erosion or settlement will be obvious to the operator as the mower is driven over the landfill surface. The operator will advise the Viacom representative of the conditions observed and the approximate locations.

2.3 Surface Water Controls

It is important to maintain adequate surface water controls to convey excess surface water off of the site during major storm events. The proper operation and associated maintenance requirements of the surface water controls are a major part of the site operation and maintenance plan. If not properly maintained, flooding or erosion could damage the cap system.

2.3.1 Description

The perimeter channels are used to convey surface water away from the landfill. Also, the perimeter channels collect water associated with the geocomposite drainage media that is part of the cap system. Water from these channels is directed to the retention pond in the southwest where water is drained in a controlled manner to Sargent's Pond. The channels and the retention pond are shown on the drawing of Figure 4 and the picture contained on Figure 2. The channels are lined with geotextile, geomembrane and rip rap. The retention pond is also similarly lined. However, a portion on either side of the center is fined with soil instead of rip rap. The geosynthetic liner in the channels and the pond was installed to minimize the potential for water to pipe through the underlying soil in the karst subsurface. On the northwest and the east sides of the site perimeter channel crossings were installed to permit inspection and maintenance vehicles to have access to the cap. The crossings were constructed with reinforced concrete pipe (RCP) covered with limestone aggregate.

Water that collects in the retention pond is released at a controlled rate from the three holes at the base of the drainage structure located at the north end of the pond. There is a 36 inch X 48 inch steel grate on top to the structure that functions as an overflow. Water is carried from the structure through a 24 inch (RCP) to an outlet at Sargent's Pond. Rip rap located around the drainage structure in the pond helps to limit the impact of debris buildup on the capability of the structure to drain water in a controlled manner.

2.3.2 Maintenance

It is important that all the surface water controls associated with the site be maintained in good operating condition. These controls are necessary to convey excess surface water off the site during major storm events in a timely and controlled manner. Drainage ways will be kept clear of seedlings, debris and branches. Vegetation growing in the channels will be periodically cut down to maintain a clear flow path for water. Sediment that builds up above the level of the rip rap will be periodically removed. The piping that forms the perimeter channel.crossings must be kept clear of debris and sediment buildup. Care must be taken when performing any maintenance in the perimeter channel to avoid damaging the geomembrane lining located under the rip rap.

Bends in the perimeter channel that change water direction are subject to deterioration or erosion. If excess erosion is observed, an evaluation will be performed to determine if adjustment or extension of the existing drainage feature would help reduce erosion. As required, these areas may need to be modified by reshaping the curve or increasing the height of the outside berm. Also, signs of erosion beyond the drainage ways may indicate that the surface water controls have failed or were not designed or located properly. Rebuilding, modifications or extensions of the perimeter channel must take into account the lining in the channels and the 24 inch cover soil over the cap surface on top of the geocomposite. No excavation or Grading is to be done below the surface of the 24-inch protective soil covering on the cap.

The retention pond southwest of the site must be kept free of debris such as branches and sediment buildup. Animal burrows or erosion in the pond bottom or sides must be repaired by adding cover soil and topsoil and then re-seeding. The retention pond outlet drain is covered by rip rap to limit the potential of the drain holes being blocked by debris and sediment. Debris and excess sediment that accumulate in the rip rap or on the steel grating must be removed. Any heavy brush or saplings growing in the bottom or sides of the pond are to be cut when pond water levels permit. Any erosion or disturbed rip rap at the outlet of the RCP pipe to Sargent's Pond must be repaired. The repair may include the evaluation of other erosion control options or improvements to the existing controls. During maintenance such as sediment removal, care must be taken not to damage the geomembrane lining under the rip rap and under the soil that covers the retention pond bottom.

2.3.3 Inspection Plan

All drainage way surfaces will be examined to insure that functionality is maintained. The inspection of these surfaces will be conducted to determine the following:

• There is no excessive accumulation of sediment above the rip rap.
• That debris such as large branches or other foreign material has not accumulated to obstruct flow.
• Rip rap is covering all surfaces as originally constructed. No rip rap has washed away leaving uncovered areas.
• No excessive erosion has occurred beyond the rip rap surfaces or on the sides of the perimeter channels opposite the landfill.
• The pond surfaces are free of excess vegetation that could impede water flow. All piping for the perimeter channel crossings are free of obstructions. Signs of excessive erosion beyond the perimeter channels. If geosynthetics are exposed no damage has occurred to these materials.

Inspections will be conducted on a quarterly basis. The channels and pond should also be inspected immediately following an excessively heavy or prolonged storm event. If damage has occurred during an unusually heavy storm event, repairs will be done in a timely fashion to minimize any further damage. Site conditions such as soil moisture or snow cover need to be considered when scheduling any repairs. The soil conditions will dictate when repairs can be conducted without further damage to the cap.

2.4 Site Security

General access to the cap and surface water control features immediately associated with the cap needs to be limited. A security fence will be the main method to limit access. The fence also provides a very visible identification of the area generally associated with the RCRA cap.

2.4.1 Description

A chain link fence with equipment and personnel gates secures the site as indicated in Figure 4. All gates will be padlocked closed except during inspections or maintenance. Personnel who temporarily leave the site are to lock the gates. Warning signs will be posted every 200 feet along the fence. Signs will state "Restricted Area Keep Out".

2.4.2 Maintenance

The fence and gates will be repaired as required. Gate locks will be lubricated as needed to insure proper operation. Gates are to be free swinging with spacing at the bottom limited to avoid the possibility of individuals slipping in beneath the gates. Gateposts are to be repaired if the gates become out of square due to damage or loss of tension on the posts.

2.4.3 Inspection Plan

The fence and gates will be inspected quarterly. The fence will be inspected for holes in the chain link, loose or missing barbed wire, holes in the soil surface directly below the fence and that warning signs are secure. Loss of tension on the fence or gatepost is to be reported. Gate alignment is to be checked and spacing below the fence is to be kept to a minimum. The mower equipment operator will also have an opportunity to observe the condition of the fence or gates in addition to the quarterly inspections.

Each quarter an inspection report for the site will be prepared. A copy of the report is shown in Appendix C. The individual that performs the inspection will be required to review this plan and complete the form based on the requirements of this plan. Once the inspection is complete, the inspector will review the report with the responsible Viacom representative. A copy of the report will become part of the project documentation held by Viacom. In addition, a copy will be sent to each of the CD parties within 30 days after completion of the inspection. Routine maintenance such as minor fence repairs, replacing locks, and minor road repair will be noted on the quarterly report.

When other than routine maintenance is required, the Viacom representative will prepare a separate reporters shown in Appendix D. This non-routine maintenance would include items such as repair of erosion where a survey would be required or where vandalism has occurred. In the event that an area is surveyed after repair, Figure 5 will be revised noting the specific area that was re-surveyed. A copy of this report will be provided to the parties within 30 days after completion of the repairs.

At the end of five years the overall plan and inspection records will be reviewed to determine if any modifications to this plan are appropriate. In the event this inspection and maintenance plan needs to be modified, Viacom will prepare a draft plan highlighting the proposed changes. The draft will be submitted to the parties for review and approval.