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SFUND RECORDS CTR78483

FINALOPERATIONS AND MAINTENANCE MANUAL

PESTICIDES/SOLVENTS LANDFILL CAPCASMALIA HAZARDOUS WASTE

MANAGEMENT FACILITYCASMALIA, CALIFORNIA

Prepared for

Casmalia Resources Site Steering Committee

April 13, 2000

Prepared by:

CSA021433Harding Lawson AssociatesEngineering and Environmental Services10265 Rockingham Drive, Suite 150Sacramento, CA 95827 - (916) 364-0793

CASMALIA SITE REMEDIATION PROJECTCorey Bertelsen

April 13, 2000 Project Manager

To: Dennis Geiser - EPAS.J.Chern - EPA

Subject: Final Operations and Maintenance ManualP/S Landfill Cap

In a letter dated January 6, 2000 the EPA provided the Casmalia Steering Committee (CSC)comments on a draft Operations and Maintenance (O&M) Manual for the P/S Landfill Cap theCSC had previously submitted to EPA on October 6, 1999. In that letter, EPA directed the CSCto modify the draft O&M Manual and resubmit it by February 4th, 2000 as a final document.

The CSC responded to EPA's January 6th letter and indicated we would not be able to meet theFebruary 4* deadline, but that we would be able to submit the document in late March or April.We also indicated in a January 8, 2000 letter and in subsequent telephone conversations withEPA that we expected to accommodate EPA's requests for many of the additional new figures inthe O&M Manual by direct and specific references to the figures we expected to include in the AsBuilt Drawing Report for the P/S Landfill Cap construction (which is referenced andincorporated in the O&M Manual) that we were planning on submitting to EPA in early March.

On January 27th, EPA directed the CSC to delay submittal of the As Built Report until some timelater this spring or summer after corrective actions had been completed.

We have attached a revised or Final P/S Landfill O&M Manual that addresses all of EPA'sJanuary 6th comments. The Final O&M Manual leaves some specific references to figures whichwill be included in the As Built Report blank to be filled in when that report is submitted. Wehave also attached a "response to comments" summary which indicates how the EPA commentswere incorporated and in a few instances notes those comments which were addressed in amanner different than stated in EPA's letter.

We will send out a limited number of addendum pages to the Final O&M Manual which fill inthe blanks on figure references when we submit the As Built Report for the cap.

Please contact me if you have any questions or comments,

regards,

Corey BertelsenCasmalia Project Coordinator

cc Jim Dragna - MDBEGlenn Anderson - TexacoMary Blevins - EPACaroline Rudulph - DTSCDan Niles - RWQCB CSA021473Mark Wuttig - CH2MHU1

FinalOperations and Maintenance ManualPesticides/Solvents Landfill CapCasmalia Hazardous Waste Management FacilityCasmalia, California

Prepared for


HLA Project No. 47588

flJUEmily J .̂. AnilersonStaff Engineer

fames P. Heiraerson, P.E.'Senior Engineer

April 13, 2000

Harding Lawson AssociatesEngineering and Environmental Services10265 Rockingham Drive, Suite 150Sacramento, CA 95827 - (916) 364-0793

CSA021474

CONTENTS

1.0 INTRODUCTION...............................^

1.1 Site Description, Access, and Boundaries......................................................................................!1.2 Site History......................................................................................................................................!1.3 Related Project Documents.............................................................................................................2

2.0 DESCRIPTION OF LANDFILL CAP......................................................................................................... 3

2.1 Final Cap Limits, Grading and Profile............................................................................................ 32.2 Toe Buttress.....................................................................................................................................32.3 Liquid Monitoring and Control Systems ....................................................................................... 42.4 Surface Drainage Control................................................................................................................42.5 Slope Protection and Erosion Control.............................................................................................42.6 Survey Monuments / Settlement Markers....................................................................................... 52.7 Temporary Irrigation System.......................................................................................................... 5

3.0 ROUTINE MONITORING AND MAINTENANCE PROCEDURES AND SCHEDULES...................... 6

3.1 Monitoring and Maintenance..........................................................................................................63.1.1 Monitoring Personnel...................................................................................................................... 7

3.1.1.1 Site Operations Manager......................................................................................73.1.1.2 Site Inspector........................................................................................................73.1.1.3 Site Engineer........................................................................................................7

3.1.2 Vegetation Monitoring, Maintenance and Repairs.........................................................................83.1.3 Erosion Control Monitoring, Maintenance and Repairs ................................................................8

3.1.4 Animal Intrusion Monitoring and Repairs........................................................................ 83.1.5 Drainage System Monitoring, Maintenance and Repairs.................................................83.1.6 Access Road Monitoring, Maintenance and Repairs........................................................93.1.7 Settlement Monitoring and Repairs...................................................................................93.1.8 Temporary Irrigation System Repair and Monitoring.................................................... 10

4.0 NON-ROUTINE MONITORING AND MAINTENANCE PROCEDURES AND SCHEDULES.......... 11

4.1 Non-Routine Monitoring and Emergency Response.................................................................... 114.2 Geosynthetic Repairs..................................................................................................................... 114.3 Slope Failure Repairs.................................................................................................................... 11

5.0 TRAFFIC RESTRICTIONS ON LANDFILL CAP................................................................................... 12

6.0 REFERENCES...........................................................................................................................................13

TABLES

1 Routine P/S Landfill Cap Maintenance and Inspection Schedule

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Contents

FIGURES

1 Site Location2 Current Site Layout3 Typical Cap Cross Section4 Cap Inspection Grid Map

APPENDIXES

A Applicable or Relevant and Appropriate RequirementsB Standard Operating Procedures

B.I SOP 104 Cover InspectionB.2 SOP 143 Access and Bench Road InspectionB.3 SOP 144 Surface Water Management System Inspection, Surveillance, and MaintenanceB.4 SOP 147 Vegetative Cover System InspectionB.5 SOP 148 SurveyingB.6 SOP 149 Access and Bench Road Maintenance and RepairB.7 SOP 150 Landfill Cover Maintenance and Repair

DISTRIBUTION

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LIST OF ACRONYMS AND ABBREVIATIONS

ARAR

ARE

CCR

CIWMB

CSC

CQA

CY

DISC

EPA

H:V

HLA

P/S

RWQCB

SOP

TOC

Applicable or Relevant and Appropriate Requirement

Air Resources Board, State of California

California Code of Regulations

California Integrated Waste Management Board


Construction Quality Assurance

Cubic Yards

Department of Toxic Substances Control

Environmental Protection Agency, Region IX

Horizontal:Vertical Slope

Harding Lawson Associates

Pesticides/Solvents

Regional Water Quality Control Board

Standard Operating Procedure

Top of Casing

CSA021477

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Harding Lawson Associates iv

1.0 INTRODUCTION

Harding Lawson Associates (HLA) has beenretained by the Casmalia Resources Site SteeringCommittee (CSC) to prepare a Operations andMaintenance (O&M) Manual for thePesticides/Solvents (P/S) Landfill Cap at CasmaliaHazardous Waste Management Facility (Site)located in northwestern Santa Barbara County,California.

The O&M Manual serves as the manual foroperating, maintaining, and repairing all of the P/SLandfill Cap, including the buttress which wasconstructed in the fall of 1998 and the actual capwhich was constructed in the summer and fall of1999. The O&M Manual includes a generaldescription of the facilities as constructed,outlines the operation requirements of the P/SLandfill Cap, defines the monitoring schedule andprocedures, defines routine maintenance work andschedules, and describes non-routine repair workthat may be required.

The O&M Manual was prepared to be consistentwith the Applicable or Relevant and AppropriateRequirements (ARARs) included as Appendix A,and to address requirements outlined for an O&MManual listed in Section 3.14 of the CasmaliaConsent Decree Statement of Work. The O&MManual is supported by Standard OperatingProcedures (SOPs) included as Appendix B, andseveral design, construction, work plan, andmaintenance documents included by reference inthis manual.

The O&M Manual is intended to be a "standalone" document. However, the reader shouldobtain and review the various landfill cap designand construction documents prior to beginningany non-routine work. Related project documentsare listed in this section and the referencessection.

The O&M Manual will be reviewed annually andupdated as necessary. The O&M Manual will bespecifically updated in the event additionalextraction wells are installed, changes are made tothe cover system or integral parts of the cap, or at

the request of the U.S. Environmental ProtectionAgency (EPA). Revisions to the O&M Manualwill be presented to the EPA in the form of a draftrevision and finalized after receiving EPAcomments. [ This O&M Manual containsincomplete references to information currentlybeing prepared for supporting documents. Thereferences will be resolved in subsequentrevisions after the supporting documents aresubmitted. ]

1.1 Site Description, Access, andBoundaries

The Site is located in northwestern Santa BarbaraCounty 1.6 miles northwest of the un-incorporatedvillage of Casmalia as illustrated in Figure 1. TheSite is a 252 acre parcel within a 4,645 acre parcelowned by Casmalia Resources and contains anumber of landfills and other features asillustrated in Figure 2. Most of the surroundingland is used for cattle grazing and is agriculturalpreserve. The grazing land abuts Vandenburg AirForce Base to the west, extends to Black Road tothe east, and to the community of Casmalia to thesouth.

The P/S Landfill cap and toe buttress occupiesapproximately 15 acres of the north center portionof the Site. The Borrow Area, north of the P/SLandfill, is approximately 4 acres and was used tosupply vegetative cover for the P/S Landfill cap.The P/S Landfill as-built topography is illustratedon Figure [ ] of the Construction QualityAssurance Report, Pesticides/Solvents LandfillClosure, Part II - P/S Landfill Cover (Part IICQA Report) by Geosyntec Consultants.

1.2 Site History

The Site is an inactive hazardous wastemanagement facility, which began operation in1972.

The Site accepted wastes for disposal until 1989,including pesticides, solvents, PCBs, metals,acids, caustics, cyanides, and oil field wastes. The


Harding Lawson AssociatesCSA021478

Introduction

Site includes a number of different wastemanagement units and at one time includedapproximately 43 ponds, 6 landfills, shallowinjection wells, waste disposal trenches, liquidtreatment facilities, and oil field spreading areas.

In 1989 under direction from the Regional WaterQuality Control Board (RWQCB), the Sitestopped accepting waste. The EPA had anEmergency Response Team maintain the Site from1992 to 1996. The Casmalia Resources SiteSteering Committee (CSC) is a group ofapproximately 52 companies who had used theSite to dispose of waste prior to 1989 and whobegan work on the Site under a Consent Decreelodged in 1996.

As required by the Casmalia Consent Decree, theCSC completed a design of a final cap and toebuttress for the P/S Landfill. The toe buttress wascompleted in October, 1998 and construction wasdocumented in the Final P/S Landfill Cap, Part 1Construction As Built Report by Foster Wheeler.Work on the P/S Landfill cap began in the summerof 1999 and was completed in early 2000.Construction was documented in two documentstitled Construction As-Built Report,Pesticides/Solvents Landfill Closure, Part II-P/S/Landfill Cover (Part II Construction As-BuiltReport) by Foster Wheeler and Part IICQAReport by Geosyntec.

1.3 Related Project Documents

As previously noted, the O&M Manual is intendedto be a "stand alone" document. However, thereader should review supporting documentsrelated to the landfill cap design, construction,construction inspection and ancillary sitefacilities. Supporting documents are listed below.The O&M Manual does not directly incorporate:

all information from these reports but insteadreferences supporting documents when needed toensure that the user of this manual obtains theappropriate information in context.

The O&M Manual is complemented by thefollowing additional project documents:

• Casmalia Consent Decree

• Revised Final Construction Work Plan,Part 1 P/S Landfill Cap

• Final P/S Landfill Cap, Part 1Construction As Built Report

• Pesticides/Solvents Landfill Cap, FinalDesign Report, (Revision 2.1)

• Final Construction Work Plan, Part 2Pesticides/ Solvents Landfill Cap (Plans,Specifications, Construction QualityAssurance Plan and Contractor SiteHealth and Safety Plan included)

• Health and Safety Plan (addressesoperations and maintenance activities)

• Final Technical Memorandum, InterimCollection/Treatment/Disposal ofContaminated Liquids Component ofWork

• Routine Groundwater Monitoring Elementof Work - Work Plan, SAPP and QAPP

• Routine Site Maintenance Work Plan

CSA021479



2.0 DESCRIPTION OF LANDFILL CAP

Components of the landfill cap are described inthis section.

2.1 Final Cap Limits, Grading andProfile

Detailed documentation of the landfill final capdesign is included in the Final Design Report.The landfill cover is a RCRA-equivalent cap andis illustrated on Figure 3. A north-south crosssection of the cap is illustrated on Figure [ ] ofthe Part IICQA Report. The cap includes thefollowing components from bottom to top:

• subgrade soil• foundation layer• HOPE geomembrane• geocomposite drainage layer• first lift of vegetative cover layer• geonet biotic barrier• second lift of vegetative cover layer

The subgrade soil is composed of claystone fromformer pond bottoms excavated initially in 1989-1990 as part of on-site pond closure projects(Foster Wheeler, 1999c). The subgrade wasregraded and compacted to the slopes documentedin the Part IICQA Report. A two-foot thickfoundation layer was placed on top of thesubgrade. The foundation layer is made up of soilregraded within the landfill, excavated from pondbottoms and from the borrow area north of thelandfill. The foundation layer serves as a stablesurface for the overlying low permeability layer(geomembrane) and was constructed to attain amaximum hydraulic conductivity of 1 x 10"6 cm/s.The foundation layer was placed and compactedas documented in the Part II CQA Report. A 60mil thick high density polyethylene (HOPE)geomembrane, textured on both sides, wasinstalled on top of the foundation layer. Ageocomposite drainage layer was installed on topof the geomembrane. Two types of geocompositedrainage layer material were used. A high flowgeocomposite was used for the top deck whereslopes are generally flatter and a lower flowgeocomposite was used on the slopes of the

landfill. Geocomposites were placed asdocumented in Figure [ ] of the Part II CQAReport. A two-foot thick vegetative soil layer wasconstructed on top of the geocomposite drainagelayer in two separate lifts. A geonet biotic barrierwas installed at nominal 1 foot depth in the middleof the vegetative layer. The biotic barrier isdesigned to limit burrowing animals.

The cap extends over the full 15 acres of the P/SLandfill. The south limit of the landfill cap is tiedinto the toe buttress. The final grades of the P/SLandfill cap include: the top deck graded atapproximately 4-6%; side slopes graded at 3.5:1(horizontal to vertical); and slopes south of thebench roads graded at 2:1.

The cap was constructed with a temporarytermination along the east and west edges. Thetemporary termination consists of plywood placedon the geomembrane to assist with tie-in to futurecaps to be constructed on adjacent landfills. Thelocation of the temporary tie-ins is documented inFigure [ ] of the Part II CQA Report.

There are a number of benches and roads on theperimeter and interior of the landfill as illustratedon Figure [ ] of the Part II CQA Report. Theroads are surfaced with gravel to provide allweather access and minimize dust and erosion.Concrete v-ditches were constructed on the insideedge of the bench access roads and landfillperimeter. Arizona crossings are provided to allowvehicles access across drainage structures wherethe bench access roads meet the perimeter accessroad. Storm water runoff from the landfill isconveyed to existing storm water channelssoutheast of the P/S Landfill.

2.2 Toe Buttress

A toe buttress was constructed during October,1998 to enhance the stability of the landfill'ssouth slope. The toe butress was constructed withcompacted clay soil laterally around the entiresouthern edge of the landfill to a finished outboardslope of approximately 2.5:1. Construction of the



Description of Landfill Cap

toe buttress is documented in the Final P/SLandfill Cap, Part 1 Construction As Built Report.

2.3 Liquid Monitoring and ControlSystems

The P/S Landfill currently includes a liquidextraction well (called the Gallery Well) and twopiezometers located at the south side of thelandfill. The purpose of the two piezometers is tomeasure liquid levels in the landfill. The GalleryWell is used to extract liquids from the toe of theP/S Landfill and maintain an acceptable liquidlevel in the landfill. The location of the GalleryWell and piezometers are illustrated on Figure [] of the Part IICQA Report.

The Gallery Well is surrounded by a concrete padto stabilize the well monument and prevent liquidintrusion and protect it from vehicle traffic. TheGallery Well and piezometers operations andmaintenance are addressed in the Routine SiteMaintenance Work Plan and RoutineGroundwater Monitoring Element of Work by ICFKaiser.

A subsurface vertical clay barrier was constructedalong the toe of the landfill south slope hi 1980.Based on the Final Technical Memorandum,Interim Collection/Treatment/Disposal ofContaminated Liquids Component of Work by ICFKaiser and referenced informal as-built drawingssupplied to the CSC by Casmalia ResourcesPersonnel the subsurface clay barrier isapproximately 13 feet wide and 50 feet deep at it'sdeepest point. The barrier extends about 4 feetinto the unweathered claystone bedrock. The toebuttress was built over the clay barrier. TheGallery Well was installed on the upgradient sideof the clay barrier and buttress at the time of theirconstruction. The Gallery Well consists of anapproximately 6 foot diameter gravel filled pitwith an 11-inch casing (perforated throughout thelength of the well) in the center to allow pumpingof the contaminated liquids and groundwater. TheGallery Well extends approximately 78 feet belowTop of Casing (TOC) to 4 feet below theweathered claystone contact. A 1-Horsepowerpump set at approximately 74 feet from TOC

extracts liquids out of the well which are removedfrom site for disposal (HLA, 2000). A detaileddrawing of the Gallery Well is included as Figure[ ] in the Final Technical Memorandum,Interim Collection/Treatment/Disposal ofContaminated Liquids Component of Work by ICFKaiser..

The seismic analysis for the P/S Landfill Capdesign was completed assuming the liquid level atthe landfill toe of slopes will not exceed 34 feetfrom the TOC of the Gallery Well and liquidlevel in the landfill will be maintained assummarized in the Final Design Report. Theliquid levels will be maintained as stated in the inthe Routine Site Maintenance Work Plan andRoutine Groundwater Monitoring Element ofWork by ICF Kaiser

2.4 Surface Drainage Control

Surface water runoff sheet flows from the landfillto bench ditches (concrete v-ditches) constructedat the inside of each bench access road. Thebench ditches discharge into a perimeter channel(larger concrete v-ditch) at the landfill perimeter.The perimeter channel discharges at the southeastcorner of the P/S Landfill to a drainage ditch thatruns south to the RCF Pond.

Arizona crossings are provided to allow vehiclesaccess across drainage structures where the benchaccess roads meet the perimeter access road.Drainage structure construction details aredocumented in the Part II Construction As-BuiltReport and Part IICQA Report. The drainagecontrol systems were designed to function withoutfailure when subjected to a 24-hour ProbablyMaximum Precipitation (PMP) storm event.Drainage structure design details are included inthe Final Design Report.

2.5 Slope Protection and ErosionControl

Five transitional benches were constructed on thelandfill cap slopes to increase seismic stability andreduce erosion. Each bench includes a gravelaccess road and concrete lined v-ditch to convey



Description of Landfill Cap

surface water runoff away from the landfill.Traffic restrictions are discussed in Section 5.0.Access road design details are included in theFinal Design Report. P/S Landfill cap erosion isminimized by diverting surface water runoff fromadjacent areas in the concrete lined perimeterchannel.

Vegetation species were selected based on theirquick growth, long-term hardiness and fibrousroot systems that stabilize surface soils preventingerosion caused by wind and water. The seedselected for vegetation was also chosen to be salttolerant to allow continued irrigation from on siteponds which may contain higher total dissolvedsolids (TDS) levels.

2.6 Survey Monuments / SettlementMarkers

Three (3) permanent survey monuments arelocated around the P/S Landfill outside the landfilllimit. Fourteen (14) settlement markers are locatedwithin the landfill limit. Settlement markerlocations (including coordinates) are illustrated onFigure [ ] of the Part IICQA Report. The surveymonuments and settlement markers will beprotected and maintained. The survey monumentsand settlement monuments will be used forsettlement monitoring as described in SOP 148.

2.7 Temporary Irrigation System

The P/S Landfill cap includes a temporaryirrigation system that will be operated at leastthrough the first year after seeding (i.e. untilNovember, 2000). The temporary irrigationsystem will ultimately be removed from the cap toallow work on the surface such as cutting thegrass.

The temporary irrigation system details aredescribed in Section [ ] and illustrated in Figure [] of the Part II CQA Report. The system generallyconsists of the following components:

• supply pump located in the RCF Pond whichdelivers approximately 6,000-8,000 gallonsper hour of water to a 40,000 gallon tank

located at the top of Water Tank Hill (locatedjust immediately northwest of the P/S Landfilland approximately 80 feet higher than the topdeck).

• a supply pump located in an off site wellwhich delivers approximately 2,000-3,000gallons per hour of water to the 40,000 gallontank noted above.

• PVC pipe (1", 2", and 4" in diameter)distribution system that includes a branch onthe toe buttress, a branch to the Borrow area,and four main branches across the P/SLandfill cap. The distribution piping lays onthe surface of the landfill.

• Manual control valves located as illustrated inFigure [ ] of the Part II CQA Report

• over 800 sprinkler heads with a density ofover 35 sprinklers per acre.

The temporary irrigation system can deliver over0.15 inches of water per acre per day (or over80,000 gallons per day). The system is operated asneeded to maintain the vegetation. Water from theRCF Pond and the off site well is mixed at anapproximate ratio of 2:1 to limit salts during thefirst stages of germination. The seed used forvegetating the cap is salt resistant but at EPA'srequest irrigation water salt content will beminimized during germination.

CSA02J482



3.0 ROUTINE MONITORING AND MAINTENANCE PROCEDURES AND SCHEDULES

Objectives of the Operations and MaintenanceManual are to:

• minimize threat to public health and theenvironment;

• preserve the function and integrity of thefinal cover system;

• minimize infiltration of water into thelandfill;

• control drainage and erosion.

3.1 Monitoring and Maintenance

This section describes the anticipated routinemonitoring and maintenance procedures andmethods to be used at the landfill. The monitoringwill be performed according to the scheduleincluded in Table I. The monitoring schedule,responsible party, and Standard OperatingProcedures (included in Appendix B) are listed inTable 1. Monitoring personnel responsibilities andqualifications are described in Section 3.1.1.Surface inspections will be recorded using the CapInspection Grid Map included as Figure 4.

The cap and drainage system will be inspected forthe following parameters:

• evidence of slope instability or movement;

• differential settlement (or tensioncracking);

• erosion;

• burrowing animals;

• condition of all drainage systemcomponents;

• evidence of run-on damage;

• condition of vegetation (including anydiscoloration).

The cap and drainage system inspection willconsist of a complete walk of the cap and visualexamination of all cap areas and drainage systems.Damage (including cracks) to the cap or drainagesystem, if observed, will be documented andreported to the EPA, verbally within 24 hours andwritten within 48 hours. The damage will beevaluated in accordance with the appropriate SOPand any recommended repairs discussed with theEPA. Repairs will be scheduled as soon aspossible.

Upon completion of cap and drainage systeminspections, the inspector will prepare a reportdescribing the condition of the cap and drainagesystem. If the inspection indicates any repairs arerequired, the proposed repairs will be discussedwith EPA and a registered professional civilengineer will prepare the recommendations forany required maintenance and repair activities.

Inspection reports will be summarized in aquarterly report that will include:

• Cap Inspection Grid Map with notesidentifying any surface erosion or otherdefects on the landfill;

• estimate of rodent or animal populationson the landfill;

• estimate of condition of vegetative growthor cover and temporary irrigation system;

• verification that the storm water channelshave been cleared of debris;

• access road map identifying any roadmaintenance problems;

• appropriate color photographs and/orother details;

• documentation of repairs completedduring quarterly period.

The inspection reports will be kept onsite andcopies forwarded to the parties listed on thedistribution page of this manual. Damagerequiring repair will be documented in a repair

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Routine Monitoring and Maintenance Procedures and Schedules

report indicating the repair was completed, thedate the work was finished, and signatures ofappropriate personnel.

Any repair EPA determines is major will becompleted under the supervision of a registeredprofessional civil engineer. Repairs will becompleted in accordance with the originaldrawings, specifications, CQA Plan andmanufacturer's recommendations and repairprocedures included in the Final Design Report.

Maintenance of the Gallery Well and piezometerswill be conducted in accordance with the FinalRoutine Site Maintenance Work Plan and FinalRoutine Ground Water Monitoring Work Plan.Maintenance of the Gallery Well and piezometersincludes regular inspection of the exterior of thewells (piping, connections, concrete pad, flowmeters, and electrical connections and supply). Inaddition, the wells are periodically sounded toensure their integrity.

In addition to regular inspection reports asdiscussed above, annual reports will be preparedto summarize the quarterly reports and annualmonitoring activities listed in Table 1.

3.1.1 Monitoring Personnel

3.1.1.1 Site Operations Manager

The Site Operations Manager will be a party toprovide oversight of all operations andmaintenance activities at the P/S Landfill. Majorduties and responsibilities of the Site OperationsManager are:

• Review or preparation of repair plans andspecifications;

• Instruction of Site Inspectors) in inspectionrequirements and procedures;

• Scheduling inspection activities;

• Review and evaluate Operations andMaintenance Manual, SOPs, ARARs, and

reference documents as appropriate for theinspections and repairs performed;

Review and interpretation of all data andreports prepared by Site Inspectors);

Review and interpretation of all data andreports prepared by the Site Engineer.

3.1.1.2 Site Inspector

The Site Inspector will be a party to perform on-site inspections of the P/S Landfill cap under thesupervision and guidance of the Site OperationsManager. The Site Operations Manager mayperform the duties of the Site Inspector. Majorduties and responsibilities of the Site Inspectorare:

Accurately record all inspection data;

Review Operations and Maintenance Manual,SOPs, ARARs, and reference documents asappropriate for the inspections and repairsperformed;

Report observations and inspection results tothe Site Operations Manager.

3.1.1.3 Site Engineer

The Site Engineer will be a California registeredprofessional civil or geotechnical engineer toperform engineering evaluations when required insupport of operations and maintenance at the P/SLandfill cap. The Site Engineer will assist the SiteOperations Manager when an engineer is requiredfor specific operations and maintenance duties.The Site Operations Manager may perform theduties of the Site Engineer if properly licensed.Major duties and responsibilities of the SiteEngineer are:

• Perform inspections and evaluations;

• Review and evaluation of Operations andMaintenance Manual, SOPs, ARARs, andreference documents as appropriate for theinspections and repairs performed;

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• Review and evaluation of data and reportsprepared by Site Inspector(s);

• Report observations and inspection results tothe Site Operations Manager;

• Review and / or preparation of repair plansand specifications;

• Review and / or preparation of instructions forContractor and Site Inspector(s) for repair andinspection requirements and procedures.

3.1.2 Vegetation Monitoring,Maintenance and Repairs

The vegetative cover and irrigation system will beinspected, maintained, and repaired in accordancewith the schedule and Standard OperatingProcedures (SOPs) listed in Table 1 and includedin Appendix B. The entire landfill will be visuallyinspected quarterly by the Site Inspector. The SiteInspector will walk the entire cap and documentany indications of erosion, settlement, cracking,poor and/or discolored vegetation, and animalintrusion on the Cap Inspection Grid Map (Figure4).

Vegetation on the cap will be mowed annually tominimize the intrusion of deep roots from largerplants, to keep the area clear and visible to allowappropriate inspections, and for fire control. Atthe time of mowing, any seedlings or other deeprooted growth will be removed. Any holesresulting from the removal of seedlings will beinspected and repaired as needed in accordancewith SOPs 104 and 150.

Any areas of the cap that require revegetation willbe re-seeded using the broadcast seed mix listed inthe Construction Specifications. Temporaryirrigation will be supplied, as needed, until thevegetation is established (i.e. the grass has grownto at least 3 inches and covers 95% of theimpacted area).

3.1.3 Erosion Control Monitoring,Maintenance and Repairs

Surface erosion damage on the cap or borrow areawill be scheduled for repair at the time the defectis identified. Surface erosion damage includesareas eroded by storm water, wind, or excessiveirrigation Eroded areas will be removed usingshovels to expose the biotic barrier which will beremoved as necessary. The area will be gradedand compacted to match the surroundingtopography. The biotic barrier will be replacedand appropriately connected to the unaffectededges. The repair work will be performed byappropriately trained personnel in accordance withthe Final Design Report, SOP 150, and Healthand Safety Plan.

The P/S Landfill Cap will be surveyed accordingto the schedule listed in Table 1 to evaluate anysoil loss due to erosion or other causes (seeSection 3.1.6 of this O&M Manual). Thetopographic survey will be compared to theRecord Survey included as Figure [ ] in the PartIICQA Report to determine if soil loss hasoccurred.

3.1.4 Animal Intrusion Monitoring andRepairs

Burrowing animal intrusion damage will bescheduled for repair at the time the defect isidentified. Following removal of any animal,repairs will be completed as indicated in SOP 150.Depending on the extent of intrusion, anyimpacted biotic barrier or deeper intrusion into thegeosynthetics will be repaired in accordance withthe Final Design Report, and Health and SafetyPlan.

3.1.5 Drainage System Monitoring,Maintenance and Repairs

The drainage system will be cleared of debris,sediment, or other obstructions on an as-neededbasis.

The drainage system will be inspected accordingto the schedule listed in Table I for signs of

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cracking, settling, excessive vegetative growth,siltation, and other maintenance and repairconcerns as described in SOP 144. During theinspection the system will be cleaned of debriswith shovels or rakes as appropriate. Thedrainage system is designed such that the channelslie over the full RCRA equivalent cap. Minordamaged portions (small cracks) of the drainagesystem will be repaired using epoxy resins,asphaltic material, and silicones when appropriate.In the event the damage to the system is severeenough that replacement is required, the affectedsection will be demolished and removed. Thedrainage system section will then be replaced inaccordance with the Final Design Report.

3.1.6 Access Road Monitoring,Maintenance and Repairs

The access roads will be cleared of debris,vegetation and other obstructions on an as-neededbasis.

The access roads will be inspected according tothe schedule listed in Table 1 for signs of settling,excessive vegetative growth, cracking, rutting, andother maintenance and repair concerns. Duringthe inspection the roads will be cleaned of debriswith and vegetative growth by mowing, trimmingor weeding as appropriate. Access road gradingand gravel surfacing will be maintained for all-weather access. Access road repairs will be madeas necessary in accordance with the Final DesignReport and SOP 149.

3.1.7 Settlement Monitoring andRepairs

Settlement of the landfill may occur fromconsolidation of fill under surcharge, andconsolidation due to decomposition of the organicmatter within the fill.

Fourteen (14) survey settlement markers arelocated on the landfill. Three permanent surveymonuments are maintained outside the P/SLandfill limit in locations not subject tosettlement. Survey monument and settlement

marker locations are listed on Figure [ ]of thePart IICQA Report.

Survey monuments and settlement markers will beprotected and maintained. The monuments andmarkers are generally located in areas away fromany traffic. In the event any work is performed inthe vicinity of a monument or marker, the locationwill be appropriately marked to prevent damage.Survey monuments and settlement markers will beinspected for damage during each cap anddrainage system inspection. If damage occurs tothe survey monuments or settlement markers,repair or replacement will be scheduled and themonuments will be resurveyed to obtain theelevations and horizontal coordinates. Surveymonument and settlement marker coordinates areincluded in Table [ ] of the Part II CQA Report.

The final closure record survey, included asFigure [ ] in the Part II CQA Report, will serveas the base map for settlement estimates. Asurvey will be conducted annually to recordmovement of the landfill settlement markers. Anew topographic map of the landfill will beproduced every four years. From thesetopographic maps, iso-settlement maps will beproduced to illustrate changes in elevation ascompared to the base map. The iso-settlementmaps will be included in the quarterly report forthe quarter in which it was produced.

The settlement marker and topographic surveyswill be maintained on site and submitted to theEPA in a report which will include:

• settlement monument data• copies of the topographic map• comparison of current survey to past

surveys• analysis of the survey data and proposed

action items if required

As a part of the monthly inspections and annualsurveys the P/S Landfill Cap will be inspected forsigns of depressions or subsidence which mayresult in ponding of storm water. Depressions thatare capable of retaining water will be reported asan area in need of repair. The extent of the

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depression will be discussed with EPA and adetermination made at that time whether thedepression can be locally filled, re-graded orwhether more significant repairs are required.

3.1.8 Temporary Irrigation SystemRepair and Monitoring

The temporary irrigation system will be inspecteddaily to ensure it is operational and in goodworking order. An irrigation system inspectionwill be conducted on a weekly basis. Componentsof the system that are not operational will berepaired or replaced as needed.

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4.0 NON-ROUTINE MONITORING AND MAINTENANCE PROCEDURES AND SCHEDULES

4.1 Non-Routine Monitoring andEmergency Response

The landfill cap will be inspected as soon as it isaccessible following the events listed below:

• Significant rainfall (i.e. more than 1 inch ofprecipitation in 24 hours);

• Earthquakes exceeding 5.0 in magnitudeoccurring within a 100 mile radius;

• Blockage or overflowing of the drainagesystem;

• Vandalism;• Fire;• Explosion.

If the damage presents an immediate hazard,repairs or temporary controls will be initiatedimmediately. Repair work will be completed inaccordance with the Final Design Report andunder the supervision of a registered professionalcivil engineer.

4.2 Geosynthetic Repairs

Geosynthetic repairs will be completed afterconsultation with the Site Engineer and EPA.Qualified installers will perform geosyntheticmaterial repairs. The affected area will beexposed using shovels and damaged geosyntheticmaterials will be removed. Replacementgeosynthetic materials will comply with theoriginal plans and specifications. Repair workwill be completed in accordance with the FinalDesign Report. Geosynthetic material repairs willbe performed under CQA supervision inaccordance with the Final Design Report.

4.3 Slope Failure Repairs

In the event that a slope failure (or any slopedeformation either local or site wide) is observedthe repair work will be completed only afterconsultation with the Site Engineer and EPA.Although the P/S Landfill cap was designed tominimize deformation, it is necessary to evaluatethe failures before construction repairs are

commenced. In the event of a waste containmentfailure, the affected area will be temporarilycovered to minimize threat to public health andthe environment while the evaluation iscompleted.

In the event of a slope failure or repair, a reportdocumenting the problem, recommended repair,procedures, and repair activities will be preparedand submitted to the parties listed on thedistribution page of this manual.

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5.0 TRAFFIC RESTRICTIONS ON LANDFILL CAP

The P/S Landfill cap includes perimeter roads andfive bench roads that traverse the cap and allowaccess for inspection, maintenance and repairequipment. The road locations are illustrated inFigure [ ] of the Part IICQA Report.

Traffic on the access roads will be limited tomaintenance or construction traffic specific to theP/S Landfill and will be minimized. Traffic flowon the roads (unless otherwise approved by theSite Operation Manager) will be as illustrated onFigure [ ] of the Part II CQA Report. Trafficflow will be one-way to ensure safety, reduce roadmaintenance, and keep vehicles out of the Vditches. The Arizona crossings are designed tohandle vehicle traffic.

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6.0 REFERENCES

Foster Wheeler Environmental Corporation,1998a. Revised Final Construction Work Plan,Part I P/S Landfill Cap, September 17.

Foster Wheeler Environmental Corporation,1998b. Final P/S Landfill Cap, Part IConstruction As Built Report, October 28.

Foster Wheeler Environmental Corporation,1999a. Construction Health and Safety Report,June 8.

Foster Wheeler Environmental Corporation,1999b. Final Construction Work Plan Part 2Pesticides/Solvents Landfill Cap, July 8.

Foster Wheeler Environmental Corporation,1999c. Pesticides/Solvents Landfill Cap, FinalDesign Report (Revision 2.1), July 14.

Foster Wheeler Environmental Corporation, 2000.Construction As-Built Report, Pesticides/SolventsLandfill Closure, Part II- P/S Landfill Cover [notcompleted - expected completion date Spring2000]

Geosyntec Consultants, 2000. ConstructionQuality Assurance Report, Pesticides/ SolventsLandfill Closure, Part II- P/S Landfill Cover [not completed - expected completion date Spring2000].

Harding Lawson Associates, 1999. Health andSafety Plan, My.

Harding Lawson Associates, 2000. QuarterlyProgress Report, Short-TermCollection/Treatment/Disposal of ContaminatedLiquids Component of Work, October 1, 1999 toDecember 31, 1999, January 13.

ICF Kaiser, 1997. Routine Site MaintenanceWork Plan, Casmalia Hazardous WasteManagement Facility, August.

ICF Kaiser, 1998a. Routine GroundwaterMonitoring Element of Work - Work Plan, SAPPandQAPP, Januarys.

ICF Kaiser, 1998b. Final TechnicalMemorandum, InterimCollection/Treatment/Disposal of ContaminatedLiquids Component of Work, May 7.

CSA021490



TABLES

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TABLES

CSA021492

Table 1Routine P/S Landfill Cap Maintenance and Inspection Schedule

P/S LF Cap Feature/Activity Frequency

RCRA Cap SystemInspection MonthlySettlement Marker Survey AnnuallyTopo Survey AnnuallyRepair As Required

LandscapingInspection QuarterlyRepair As required

Access (Perimeter and Bench) RoadsInspection MonthlyRepair As required

Toe ButtressInspection MonthlyTopo Survey AnnuallyRepair As required

Stormwater Drainage Features

Inspection MonthlyRepair As Required

Temporary Irrigation System

Inspection WeeklyRepair As Required

Responsible Party SOP

Site Operations Manager 104Site Operations Manager 148Site Operations Manager 148Manufacturer or qualified 150installer

Site Operations Manager 147S ite Operations Manager 150

Site Operations Manager 143Site Operations Manager 149

Site Operations Manager 143Site Operations Manager 148Site Operations Manager 149

Site Operations Manager 104Site Operations Manager 149

Site Operations ManagerSite Operations Manager


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Page 1 of 1

FIGURES

a-

FIGURES

CSA021495

SOURCE: U.S. DEPARTMENT OF THE INTERIOR,GEOLOGICAL SURVEY. CASMALIA QUADRANGLE 7.5MINUTE SERIES (TOPOGRAPHIC) 1982

CSA021496HARDING LAWSON ASSOCIATESEnQine^rino endEnvironmental 3 e r v i -': ? "10265 Roci-inqham Q'lve. Ouit*? 1^0

(016) 364-0703

SITE LOCATIONCASMALIA RESOURCESHAZARDOUS WASTE MANAGEMENT FACILITYSANTA BARBARA COUNTY, CALIFORNIA

FIGURE

DRAWN FILE MAME

JPH_____47588002.DWGPROJECT NUMBER

47588APPROVED DATE

9/99

P/S Landfill Waste LimitSite Boundary

oin

IO

o

Treatment Plants & Control Building

100,000-gallon ConcreteLiquids Storage Structura

PCT-C TRENCH

LEGEND

PCT-A TRENCH

Site Access Road

N

LANDFILL BOUNDARIES

PERIMETER SOURCE CONTROL TRENCH (PSCT)

PLUME CAPTURE COLLECTION TRENCH (PCT)

Guard Shack

PCT-B TRENCH

HARDING LAWSON ASSOCIATESEngineering andEnvironmental Services10265 Rockmgham Drive, Suite 150Socromento, California 95827(916) 3c4-0793

CURRENT SITE LAYOUTCASMALIA RESOURCESHAZARDOUS WASTE MANAGEMENT FACILITYSANTA BARBARA COUNTY, CALIFORNIA

DRAWN

JPHFILE NAME

47588001.DWGPROJECT NUMBER

47588APPROVED DATE

4/00REVISED

24"

QCO

to

oor

EXISTINGAND POND

BOTTOMS (WASTE)

BIOTIC BARRIER:'(GEONET)

DRAINAGE LAYER:DOUBLE-SIDED GEOCOMPOSITE(8 OZ/SY GEOTEXTILE/GEONET/7 OZ/SY GEOTEXTILE)

BARRIER LAYER:(60 MIL DOUBLE-SIDEDTEXTURED HOPEGEOMEMBRANE)

COHARDING LAWSON ASSOCIATESEngineering ondEnvironmental Services10265 Rockinghom Drive. Suite 150Sacramento. California 95827(916) 364-0793

TYPICAL CAP CROSS SECTIONCASMALIA RESOURCESHAZARDOUS WASTE MANAGEMENT FACILITYSANTA BARBARA COUNTY, CALIFORNIA

FIGURE:

DRAWN

JPHFILE NAME

47588004.DWGPROJECT NUMBER

47588APPROVED DATE

4/OQREVISED

NON

CNO

00O

HARDING LAWSON ASSOCIATESEngineering andEnvironmental Services10265 RocWnghom Drive, Suite 150Sacramento. California 95827(916) 364-0793

DRAWN

FGHFILE NAME

47588013.DWG

CAP INSPECTION GRID MAPCASMALIA RESOURCESHAZARDOUS WASTE MANAGEMENT FACILITYSANTA BARBARA COUNTY, CALIFORNIA

FIGURE

PROJECT NUMBER47588

APPROVED DATE4/00

REVISED DATE

TJ13mzgx

CSA021500

APPENDIX A

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

CSA021501

APPENDIX A

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

The Operations and Maintenance staff will comply with applicable or relevant and appropriaterequirements (ARARs) as defined in this section during P/S Landfill cap operations and maintenance.Operations and maintenance ARARs include: Department of Toxic Substances Control (DTSC) laws;and requirements of the Central Coast Regional Water Quality Control Board (RWQCB), and StateWater Resources Control Board (SWRCB).

The Operations and Maintenance staff will comply with the action-specific ARARs:

• SBAPCD Rules 3 02, 3 03 and 3 04;• Cal/OSHA regulations at 8 California Code of Regulations (CCR) § 5192;• Landfill closure construction requirements at 22 CCR § 66265.310(a);• Hazardous waste generator regulations at 22 CCR § 66262.10-66262.47;• Environmental air monitoring requirements at 22 CCR § 66265.710 - 714;• General Standards for Interim Status Facilities at 22 CCR, §66265.14, - §66265.17 and §66265.19;• SWRCB precipitation and drainage control regulations at 23 CCR § 2546;• Fish and Game Code Section 3005;• Fish and Game Code Section 2080;• Fish and Game Code Section 5650; and• US Fish and Wildlife Endangered Species Act of 1973 16 U.S.C. 1531-1544.

A summary of the P/S Landfill Cap operations and maintenance ARARs is presented in the followingtable.

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SUMMARY OF THE P/S LANDFILL CAP OPERATIONS AND MAINTENANCE ARARS

Standard/Requirement Citation Description ARAR? CommentsEvaluatedCalifornia Hazardous Waste Control Act / DTSC Regulations• General Inspection

• Landfill Post-Closure Care

• Environmental Airand Soil Monitoring

22CCR§66265.15

22CCR§§ 66265.3 10(b)and(e)

22CCR§§ 66265.710 -66265.714

Provides standards for facility inspection for malfunctionsand deterioration. Requires development andimplementation of a written schedule for inspectingequipment in order to prevent, detect, or respond toenvironmental or human health hazards.

Provides requirements for post-closure care of landfills.

Provides for environmental monitoring during the activelife and post-closure period at landfills where hazardouswastes will remain after closure. Provides thatenvironmental monitoring requirements shall be waived ifit is demonstrated that wastes are not migrating from thesite.

Yes (RA)

Yes

Yes(RA)

The SOW provides that site inspection is to beaddressed as part of the Routine Site Maintenanceelement of work. However, additional siteinspection measures may be required duringconstruction of the P/S Landfill cap. Accordingly,§ 66265. 15(a) -(c) is included as an ARAR in theFinal Part 2 P/S Landfill Cap Construction WorkPlan (CWP). Requirements for air monitoring areincluded in Section 4.1 of the CWP. Section 4.1discusses the monitoring and mitigation forpotential air releases. Requirements for surfacewater monitoring are included in Section 4.2 ofthe CWP. Section 4.2 discusses the monitoringand mitigation plans in the event that surfacewater or liquids are encountered. Requirementsfor erosion control and monitoring are included inSection 4.3 of the CWP.The post-closure care requirements in Section66265.3 10(b) and (e) will be included as anARAR in an interim O&M plan to be prepared inconnection with the P/S landfill cap constructioncomponent of work. Additionally, the RI/FSResponse Action element of work will addressfinal response actions and long-term O&M of theSite and post-closure care requirements will beevaluated as potential ARARs for that element ofwork.

ooo>oK)

OU)


Harding Lawson Associates A-2

Citation DescriptionStandard/RequirementEvaluatedClean Water Act / California Water Code / SWRCB Regulations / RWQCB

ARAR'. Comments

• Closure and Post-ClosureMaintenance Plans

23CCR§§2597(a)(6)

Section 2597 (aX6) requires closure and post-closuremaintenance plans to include a description of the leachatecontrol features and procedures at closed units, to theextent that such features and procedures differ from thosedescribed in the design report and operations plan preparedunder § 2596.________________________

Yes The interim O&M plan will consider, and includea description of, the existing leachate controlsystem.

Ow£to1—>iy>O


Harding Lawson Associates A-3

APPENDIX B

•oo

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APPENDIX B

STANDARD OPERATING PROCEDURES

CSA021506

SOP 104 Cover Inspection

SOP 104

COVER INSPECTION

1.0 GENERAL

1. The landfill cover (cap) consists of: (1) vegetation; (2) a 2-ft thick vegetative cover layer; (3)a geonet biotic barrier buried between the two vegetative cover soil lifts; (4) a geocompositedrainage layer; (5) a 60-mil thick textured HDPE geomembrane; and (6) a 2-ft thickfoundation layer. The primary functions of the cover include: (1) isolate waste material; (2)protect waste from intrusion; (3) promote vegetative growth; and (4) limit infiltration. Inorder to perform these functions, the cover should remain intact, free of major cracking,erosion and surface depressions. This SOP includes the procedures to inspect the cover,obtain data to guide maintenance, and plan for repairs.

2.0 SCOPE

1. The task covered by this SOP is visual inspection of the landfill cover.

3.0 TASK DESCRIPTION

1. If at any time the staff observes a condition of cover distress or damage, they willimmediately report the observation to the Site Operations Manager.

2. A visual inspection of the landfill cover will be performed and documented by the SiteInspector at the frequency specified in the Final Operations and Maintenance Manual andwhen distress or damage is observed.

3. The following items are needed for a visual inspection:• A copy of the landfill map• Landfill Cover Inspection form (Form SOP 104-1)• Survey stakes• Clipboard• Pen with black ink• Binoculars• Camera with color print film ^F CSA021507

4. Inspection observations are recorded on Form SOP 104-1. The following are guidelines forconditions to be observed and recorded:

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• Note and quantify eroded areas.• Note and quantify landfill cover soil conditions such as sloughing, sliding (presence of

headscarps and/or toe bulging).• Note and quantify cracks, fissures, or other features that may potentially allow surface

water infiltration.• Note and quantify areas of subsidence, depressions, or topography where ponding may

occur.• Note and quantify burrowing animal intusion damage• Note the state of surface water management facilities, failure or malfunction of which

could impact cover performance.• Document (locate) areas where cover deficiencies are observed.

5. In addition to regular visual inspections, the landfill cover will be inspected following theevents listed below:• Significant rainfall (i.e. more than I inch of precipitation in 24 hours). Note in particular

erosion, areas of slumping.• Earthquakes exceeding 5.0 magnitude within a 100 mile radius. Note in particular cracks,

deformation, or zones of actual or incipient slope instability• Failure of the surface water management system. Note in particular erosion, wet or

saturated cover soils, ponding, or areas where there is a potential for increasedinfiltration.

• Fire• Explosion

4.0 ACTIONS SUBSEQUENT TO OBSERVATIONS AND INSPECTIONS

1. In cases where an observation by a staff member or a formal inspection establish a deficiencythat is considered an immediate hazard, steps should be taken to implement repair.

2- Inspections pursuant to Section 3.0 and as recorded on Form SOP 104-1 will be consideredby the Site Operations Manager, who will issue instructions for ongoing maintenance orrepair.

3. Recommendations for further actions resulting from cover inspection will be implemented inaccordance with the appropriate following SOPs:• SOP 144 - Surface Water Management System, Inspection, Surveillance and

Maintenance Activities

• SOP 149 - Access and Bench Road Maintenance and Repair. CSA021508

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• SOP 150 - Landfill Cover Maintenance and Repair.

4. If observations or inspections indicate a failure to meet Performance Standards, thenotification procedures defined in the Casmalia Consent Decree will be implemented.

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FORM SOP 104-1LANDFILL COVER INSPECTION

Inspector: ______________________ Date: __________ Time:Climatic Conditions: __________________________

OBSERVATION TYPE AND DETAILED DESCRIPTION:

LOCATION OF OBSERVATION (Shown on map):

ACTION TAKEN:

REMARKS:

Signatures

Site Inspector Date

Site Operations Manager Date

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SOP 143ACCESS AND BENCH ROAD INSPECTION

SOP 143

ACCESS AND BENCH ROAD INSPECTION

1.0 GENERAL

1. The access roads and the bench roads provide all-weather access to the landfill. Roads overthe landfill include aggregate surface course over the landfill cap. Adjacent to access andbench roads are surface water management system components, such as concrete lined V-ditches, Arizona crossings and culverts.

2.0 SCOPE

1. The tasks covered by this SOP are:• Visual inspection of the roads.• Identification of conditions that impede road use, safety, or cap performance.


2. If at any time the staff observes a deficiency, damage or unsafe condition on an access orbench road, they will immediately report the observation to the Site Operations Manager.

3. A visual inspection of the access and bench roads will be performed and documented by theSite Inspector at the frequency specified in the Final Operations and Maintenance Manualand when damage is observed.

4. The following items are needed for a visual inspection:• Copy of the access road system map• Copy of the Access & Bench Road Inspection Form (Form SOP 143-1)• Pen with black ink• Clipboard• Survey stakes

• Camera with color print film

5. Inspection observations are recorded on Form SOP 143-1. The following are guidelines forconditions to be observed and recorded:• Adverse grade (visually noted, checked with hand level)• Cracking CSA021511

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^^ • Localized depressions• Sloughing• Excessive erosion of bench surface• Loss or deterioration of surfacing• Debris (soil or vegetation) from upgradient slope• Damaged or missing road signs• Impeded functionality of drainage structures (see SOP 144)• Deformation of the upgradient or downgradient slope that affects road use (see SOP 104)

6. Visual observations that may indicate damage to the landfill cap should be noted on Form143-1. These include:• Extensive cracking• Depressions• Deep erosion• Adjacent slope instability• Exposure of a geotextile material or absence of granular road base material.

t^ Such observations should be evaluated by the Site Operations Manager who will establish theneed for additional observations, including but not limited to:• Test pits• Test trenches• Borings• Settlement or deformation measurements

7. In addition to monthly inspections, the access and bench roads will be inspected after thefollowing:• Significant rainfall (i.e. more than 1 inch of precipitation in 24 hours). Note in particular

erosion.• Earthquakes exceeding 5.0 magnitude within a 100 mile radius. Note in particular cracks,

deformation, or zones of actual or incipient slope instability.• Failure of the surface water management system. Note in particular erosion, wet or

saturated soils, ponding, or areas where there is a potential for increased infiltration.• Vandalism within the Site• Fire

^ * Explosion_____________________________________CSAQ21512

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4.0 ACTIONS SUBSEQUENT TO OBSERVATIONS AND INSPECTIONS

1. In cases where an observation by a staff member or a formal inspection establishes adeficiency that is considered an immediate hazard, the necessary steps should be taken toimplement repair.

2. Inspections recorded on Form SOP 143-1 will be reviewed by Site Operations Manager, whowill issues plans and instructions for ongoing maintenance or repair.

3. Recommendations for further actions resulting from access and bench road inspection will becompleted in accordance with the appropriate following SOPs:• SOP 144 - Surface Water Management System Inspection, Surveillance, and

Maintenance

• SOP 149 - Access and Bench Road Maintenance and Repair.• SOP 150 - Landfill Cover Maintenance and Repair.


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FORM SOP 143-1

ACCESS & BENCH ROAD INSPECTION FORM

Inspector: Date: Time:Climatic Conditions

ROAD/LOCATION NORMAL ABNORMAL STATION DESCRIPTION

Signatures

Site Inspector

Site Operations Manager

Date

Date

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SOP 144SURFACE WATER MANAGEMENT SYSTEM

INSPECTION, SURVEILLANCE, AND MAINTENANCE ACTIVITIES

SOP 144

SURFACE WATER MANAGEMENT SYSTEMINSPECTION, SURVEILLANCE, AND MAINTENANCE ACTIVITIES

1.0 GENERAL

1. The Surface Water Management (SWM) system includes a series of concrete v-ditches on thebenches and around the perimeter, Arizona crossings, and culverts (corrugated metal pipe)which currently drain to the Y-Drainage then into the RCF Pond.

2.0 SURFACE WATER CONTROL

1. The SWM system provides surface water drainage, to control and minimize infiltration anderosion of the landfill cap. A description of the system is included in the Operations andMaintenance Manual.

2.1 INSPECTIONS

2.1.1 REQUIRED MATERIALS

1. Prior to performing the visual inspection, the following items are needed:• A copy of the Surface Water Management Inspection Form (Form SOP 144-1)• Pen with black ink• Notepad• Updated copy of the Storm Water Pollution Prevention Plan (SWPPP) Drainage and

Erosion Control Drawing• Measuring tape• Grade check hand level• 2" x 2" x 6' lumber (or equivalent measuring rod)• Mirror• Flashlight

• Camera with color print film

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______________________INSPECTION, SURVEILLANCE, AND MAINTENANCE ACTIVITIES

2.1.2 GENERAL QUARTERLY INSPECTIONS

1. Regular visual inspections of the SWM system will be undertaken at the intervals specified inthe Operations and Maintenance Manual and when damage is observed. Such inspectionsmay be done as part of regular visual inspections of the cover in compliance with SOP 104.

2. An annual survey of the storm water/erosion control system will be conducted in August todetermine needed repairs prior to the winter rainy season. Such survey may be coordinatedwith topographic surveys completed in compliance with SOP 148.

2.1.3 ANNUAL INSPECTION PROCEDURES

1. Sloping and Grading• Check the Top Deck slope• Check the longitudinal slope of access and bench roads• Check the cross slope of access and bench roads• Inspect and record any ponding over the landfill refuse footprint.

2. Ditches and Arizona Crossings• Check the longitudinal (flowline) slope• Inspect integrity of structures• Check for debris and other drainage obstructions

3. Culverts (Corrugated Metal Pipes)• Check for debris or vegetation at inlet and outlet• Inspect pipe for silt buildup or other blockage• Check integrity of pipe• Measure invert slope of pipe or culvert

4. Bench and Access Roads• Refer to SOP 143 for cover inspection and maintenance activities for the bench and

access roads• Survey lines and grades of bench and access roads• Measure the transverse slope of road• Inspect for areas of settlement or ponding

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______________________INSPECTION, SURVEILLANCE, AND MAINTENANCE ACTIVITIES

2.2 SURVEILLANCE

1. In the event of heavy precipitation resulting in one (1) inch or more of rainfall within 24hours, a site surveillance inspection will proceed immediately following the storm event.Surveillance activities consist of the following:

• Inspect for runoff inundation• Identify gully washes, washouts, or overtopping of drainage system• Identify areas of ponding• Inspect inlets for debris and clogging• If needed, implement maintenance as defined in Section 2.3

2.3 MAINTENANCE

2.3.1 GENERAL MAINTENANCE PROCEDURES

1. The purpose of the SWM program is to provide labor, equipment, materials, and supervisionnecessary to achieve the operational objectives, to the extent practical.

2. Maintenance activities include, but are not limited to, the following:• Mitigate infiltration of surface water into the landfill• Correct subsidence or cracking of cap to the extent practicable• Mitigate areas of significant erosion, overtopping or washouts as soon as possible• Maintain the integrity of the cap, SWM collection and conveyance structures, and on-site

facilities and systems from effects of storm water runoff• Maintain site grading to prevent ponding and excess storm water percolation into the soil

cover• Avoid offsite runoff inundation

Any breakdown and subsequent repair of the SWM system will be documented on theSWM System Breakdown and Repairs Form (Form SOP 144-2) and reported to the SiteOperations Manager immediately.

2.3.2 MAINTENANCE PROCEDURES FOR SWM COMPONENTS

1. Slopes and Grading• Procedures for the inspection and maintenance of the landfill cover are described in

SOPs 104,147 and 1502. Ditches and Arizona Crossings CSA021517



________________________INSPECTION, SURVEILLANCE, AND MAINTENANCE ACTIVITIES

• Concrete ditch repairs will be proposed by the Site Engineer after careful analysis ofdamage and executed after EPA review.

3. Culverts (Pipes)• Eliminate silt buildup greater than 2 inches by hydroblastmg pipe or by passing a pig

through the pipe to remove the silt• Maintain slope as specified in the Part 2 Construction As-Built Report• Remove and replace anchors and joints as necessary• Remove and replace pipe as necessary

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SOP 144__________________SURFACE WATER MANAGEMENT SYSTEM BREAKDOWN AND REPAIRS

FORM SOP 144-1SURFACE WATER MANAGEMENT SYSTEM INSPECTION FORM

Inspector: _______________________ Date: __________ Time: _______Climatic Conditions: ________________________________________

OBSERVATION TYPE AND DETAILED DESCRIPTION:

LOCATION OF OBSERVATION (Shown on map):

ACTION TAKEN:

REMARKS:

Signatures

Site Inspector Date


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SOP 144SURFACE WATER MANAGEMENT SYSTEM BREAKDOWN AND REPAIRS

FORM SOP 144-2SURFACE WATER MANAGEMENT SYSTEM

BREAKDOWN AND REPAIRS FORMInspector: _______________________ Date: _________ Time:Climatic Conditions: _____________________________

DEFFICIENCY TYPE AND DETAILED DESCRIPTION:

LOCATION OF REPAIR ACTIVITY(Shown on map):

REPAIR ACTION TAKEN:

REMARKS:

Signatures

Site Inspector Date


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SOP 147Vegetative Cover system Inspection

SOP 147

VEGETATIVE COVER SYSTEMINSPECTION

1.0 GENERAL

1. The vegetative cover system provides erosion control, and visual enhancement across thelandfill slopes and top deck. The vegetative cover selected to provide these results iscomprised of California native plants listed in the Construction Specifications. Theindividual plant species selected possess certain characteristics necessary to provide forsatisfactory performance of the cover system and will remain as an integral component of thecover.

2. Once established the vegetative cover will appear similar to local natural open space areas.The visible portions of the site will appear green soon after the first rain and will fade tobrown during the dry season.

3. The vegetative cover system is designed to be a non-irrigated landscape. The vegetativecover should be allowed to evolve under natural conditions and requires inspection andmaintenance.

2.0 SCOPE

1. This SOP describes inspection of the vegetation on the cover and other areas of the landfill.


1. The vegetation will be visually inspected at the intervals listed in the Operations andMaintenance Manual and when damage is observed. The frequency of inspection andmaintenance may be varied by the Site Operations Manager to respond to seasonal variationsin precipitation and vegetation establishment and growth.

2. The following items are necessary for the inspection:• a copy of the landscape planting plans• copy of the Vegetation Inspection Form (Form SOP 147-1)

• Camera and color print filmCSA021521

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/"*""*•• 3. Record observations, including the following, on Form SOP 147-1:• Weed and fire control - Observe growth of nuisance weeds and plant materials in late

winter. Determine if unsuitable plants pose a threat to the cover. Observe growth ofvegetation and mow annually in accordance with SOP 150 when vegetation starts to turnbrown to reduce fire hazard.

• Reseeding - Determine areas that require reseeding in summer.• Rodent control - Evaluate visible signs of burrowing rodents during routine inspections

around the site.

4.0 ACTIONS SUBSEQUENT TOOBSERVATIONS AND INSPECTIONS

1. In cases where an observation by a staff member or a formal inspection establishes adeficiency in the vegetation that could be repaired by immediate action, such action will betaken in discussion with the Site Operations Manager.

2. Inspections pursuant to Section 3.0 and as recorded on Form SOP 147-1 will be reviewed bythe Site Operations Manager, who will issue plans and instructions for ongoing vegetationmaintenance or replacement.

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INSPECTOR:

FORM SOP 147-1VEGETATION INSPECTION FORM

_________DATE AND TIME: ______

AREA LOCATION: GENERAL SOIL MOISTURE:

CLIMATIC CONDITIONS:

GENERALAPPEARANCE

MAINTENANCEREQUIRED

COMMENTS

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SOP 148SURVEYING

SOP 148

SURVEYING

1.0 INTRODUCTION

1.1 GENERAL1. Surveying will be performed at the landfill for one or more of the following reasons:

• Settlement and deformation monitoring at the settlement markers• Settlement and deformation monitoring of the entire landfill• Settlement and deformation monitoring at specific areas• Planning, execution and recording maintenance and repairsIn order to monitor and quantify the settlement and deformation of the landfill, surveys andtopographic mapping will be completed according to the schedule presented in theOperations and Maintenance Manual. The surveying and mapping data will also be used toplan execute and record maintenance and repair, if needed.


2.1 SETTLEMENT AND DEFORMATION MONITORING AT THE SETTLEMENTMARKERS1. Settlement markers will be surveyed at the intervals specified in the Operations and

Maintenance Manuals.

2. The work will be performed under the supervision of a Registered Land Surveyor.

3. The survey data will be presented in tabular form and compared to historical data of the samepoints. Settlement and deformation estimates will be provided in tabular form with ananalysis of the historical comparison prepared by the Site Engineer.

2.2 SETTLEMENT AND DEFORMATION MONITORING OF THE ENTIRELANDFILL1. The entire landfill will be surveyed at the intervals specified in the Operations and

Maintenance Manual.


3. The survey and mapping will be completed in order to produce a topographic map with 2 footcontour interval at the same scale as the Final Record Survey presented in the Part 2 CQAReport. Isosettlement maps will be prepared by comparing the survey to historical surveys.


CSA021524

SOP 148______________________________________________________________SURVEYING

Settlement and deformation will be analyzed and reported by the Site Engineer. The analysiswill include identification and repair recommendations for:

• Changes in settlement marker positions• depressions or areas where ponding could occur• areas where the grade is less than the minimum amount for proper drainage.

• zones of excessive deformation• incipient instability• subsidence zones

2.3 SETTLEMENT AND DEFORMATION MONITORING OF SPECIFIC AREAS1. Specific areas of landfill will be surveyed to confirm and delineate settlement and/or

deformation noted during site inspections.


3. The survey and mapping will be completed in order to produce a topographic map with 2 footcontour interval at the same scale as the Final Record Survey presented in the Part 2 CQAReport. Analysis and repair recommendations will be completed for the specific areaaccording to the same procedure noted for the entire landfill.

2.4 ACTIONS SUBSEQUENT TO TOPOGRAPHY EXAMINATION1. In cases where an observation by a staff member or a formal inspection establish a deficiency

that is considered an immediate hazard, steps should be taken to implement repair.

2. Observations as recorded on Form SOP 148-1 will be reviewed by the Site OperationsManager, who will issues plans and instructions for maintenance or repair.

3. Recommendations for further actions resulting from examination of surveying and mappingwill be completed in accordance with the appropriate SOPs.


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SOP 148

FORM SOP 148-1

LANDFILL TOPOGRAPHY EXAMINATION RECORD

Inspector: ______________________ Date: __________ Time:Climatic Conditions: __________________________________


LOCATION OF OBSERVED DEFFICIENCY (Shown on map):

REPAIR ACTION TO BE TAKEN:

REMARKS:

Signatures

Site Inspector Date


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SOP 149Access and Bench Road Maintenance and Repair

SOP 149

ACCESS AND BENCH ROADMAINTENANCE AND REPAIR

1.0 GENERAL

1. The perimeter access road and bench roads provide all-weather access to the landfill. Surfacewater management system components, such as concrete lined V-ditches, Arizona crossingsand culverts (corrugated metal pipe) are constructed adjacent to the access roads.

2.0 SCOPE

1. The tasks covered by this SOP are:• Maintenance of the access and bench roads: maintenance includes ongoing, routine, or

regular activities necessary to keep the roads in a safe and functional state and protect thecap that is incorporated in the bench roads.

• Repair of the access and bench roads: repair includes area specific work that may berequired from time to time to restore or improve the state or functioning of the roads andthe cap.

3.0 TASK PERFORMANCE

1. Maintenance or repair of the access and bench roads is undertaken as established pursuant toobservations, inspections, or monitoring in accordance with one or more of the following:• SOP 104 - Cover Inspection• SOP 143 - Access and Bench Road Inspection• SOP 144 -Surface Water Management System Inspection, Surveillance, and Maintenance

Activities• SOP 147 - Vegetative Cover System Inspection• SOP 148 - Surveying• SOP 150 - Landfill Cover Maintenance and Repair

2. The Site Operations Manager will review inspection observations and monitoring data, andwill establish the need for and extent of maintenance and repair. The Site OperationsManager may consult with necessary specialists to compile repair plans or instructions.Repairs will be completed in accordance with the plans or instructions issued by the SiteOperations Manager.

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3. To the extent practical, maintenance and repair should be undertaken to maintain or restorethe as-built conditions documented in the Part 2 Construction As-Built Report.

4.0 GUIDELINES FOR REPAIR AND MAINTENANCE

1. The following guidelines apply to maintenance or repair that involves minor cracks:• Remove portions of road at affected area to competent material.• The road section will be reconstructed using materials and methods consistent with the

original construction.• Geotextile will be repaired by placing a geotextile sheet with a minimum 24 in. overlap.

2. The conditions requiring repair of access and bench roads may include:• Cracks• Surface depressions• Erosion channels• Adverse bench road grades that impact drainage

3. Cracks:• Cracks will inspected by the Site Engineer. The Site Engineer will evaluate cracking and

recommend repair and maintenance actions to the Site Operations Manager. Minorcracks (less than Vi inch wide) will be repaired in accordance with the standard of practicefor the Santa Barabara County Road Department. Major cracks (greater than 1A inch wideand with vertical displacement across the crack) may be indicative of slopedeformation/sliding and will be first evaluated by the Site Engineer prior to implementingrepair. The repair may include removal and recompaction of a relatively large section of 'the bench/access roads to stabilize the area.

4. Surface Depressions:• Localized minor surface depressions, less than 1 foot deep, will be repaired by backfilling

with the compacted road subgrade/base course material. Prior to replacement andrecompaction, the area of the depression will be cleaned and excavated so that placementof material can occur in at least one full lift without feathering at the edges.

• Large surface depressions, greater than 1-foot deep and extending over a length greaterthan 50 feet, will be evaluated by the Site Engineer to determine if the landfill coverbelow the road subgrade has been impacted. A backhoe test pit will be excavated at thedeepest part of the depression, geotextile removed and the landfill cover inspected todetermine evidence of excessive cracking or saturation by ponding. If the barrier layerhas been impacted, repair of the depression will include excavation of the area to thebottom of the landfill cover, and replacement of the cover components in accordance withSOP 150. If the landfill cover is found to be intact and at the proper slope, repair of the

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CSA021528


depression area will include backfilling and compaction of road subgrade and surfacecourse.

At the completion of repairs, a survey of the repaired area will be performed and recorded inas-built drawings.

5. Erosion Channels• Erosion channels penetrating only the road surface and base materials will be repaired by

removal of base material from the channel sides and bottom to competent materialsurface, and replacing with compacted fill materials of corresponding material type. Thebackfilling and compaction will be performed in maximum 6-inch thick layers usinghand-held plate compactors.

• Deep erosion channels extending to the geotextile and / or landfill cover, will be repairedby excavation and replacement of the different layers of materials used in the originalbench road section. The landfill cover, if affected, will be repaired in accordance withSOP 150. Geotextile replaced will be overlapped with existing geotextile by at least 24inches.

6. Adverse Bench Road Grades:• The grade will be restored by placement of additional subgrade material and replacement

of road surfacing material over reconstructed areas7. Maintenance and repair of the access and bench roads will be documented on Form SOP 149-

1 or 149-2.

8. Notification of the EPA of start and finish of major repair activities (i.e. those necessary torestore compliance with Performance Standards will be implemented in accordance with theCasmalia Consent Decree).

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CSA021529


FORM SOP 149-1

ACCESS AND BENCH ROAD REPAIR RECORD





REMARKS:

Signatures

Site Inspector Date


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FORM SOP 149-2

ACCESS & BENCH ROAD REPAIR FORM

Inspector: Date: Time:Climatic Conditions:ROAD/LOCATION STATION DESCRIPTION OF REPAIR

Signatures

Site Inspector Date


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CSA021531Harding Lawson Associates

SOP 150Landfill Cover Maintenance and Repair

SOP 150

LANDFILL COVERMAINTENANCE AND REPAIR

1.0 GENERAL

1. The landfill cover (cap) consists of (1) vegetation, (2) a 2-ft thick vegetative cover layer (3) ageonet biotic barrier; (4) a geocomposite drainage layer; (5) a 60-mil thick textured HDPEgeomembrane; and (6) a 2-ft thick foundation layer. The functions of the cover include butare not limited to: (1) isolate waste material; (2) protect waste from intrusion; (3) promotevegetative growth; and (4) limit infiltration. These functions are best achieved when thecover is intact, free of major cracks , erosion and surface depressions that could causeponding. This SOP sets out the procedures to maintain and repair the cover.

2.0 SCOPE

1. The tasks covered by this SOP are:• Maintenance of the cover: maintenance includes ongoing, routine, or regular activities

necessary to keep the cover in a functional state.• Repair of the cover: repair includes area specific work that may be required to restore or

improve the state or functional components of the cover.

3.0 TASK PERFORMANCE

1. Maintenance or repair of the landfill cover is undertaken as established pursuant toobservations, inspections, or monitoring in accordance with one or more of the following:• SOP 104 - Cover Inspection• SOP 143 - Access and Bench Road Inspection• SOP 144 - Surface Water Management System Inspection, Surveillance, and

Maintenance Activities• SOP 147 - Vegetative Cover System Inspection• SOP 148 - Surveying• SOP 149 - Access and Bench Road Maintenance and Repair

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2. The Site Operations Manager will review inspection observations and monitoring data, andwill establish the need for and extent of maintenance and repair. The Site OperationsManager may consult with necessary specialists to compile repair plans or instructions.Repairs will be completed in accordance with the plans and/or instructions issued by the SiteOperations Manager, as approved by the EPA.

3. The Part 2 Construction As-Built and CQA reports document the initial constructedcondition of the cover. To the extent practical, maintenance and repair should be undertakento maintain or restore the as-built conditions.

4.0 GUIDELINES FOR MAINTENANCE AND REPAIR

1. The conditions requiring repair of cover on the side slopes and top deck may include:• Vertical and near-vertical cracks• Surface depressions• Erosion gullies• Sloughing/slope failures

The repair procedures will be as follows:

2. Vertical and Near-Vertical Cracks:• For minor cracks (less than 1/2-in. wide) the first response may be to apply a small

quantity of water to the cracked area and use rubber-tired equipment to squeeze the covermaterial into the cracks. Should the cracks not heal with this method, excavate about a 2-to 3-ft wide area centered on the crack to the depth of cracking and replace with covermaterial, moisture-conditioned and compacted with hand-operated equipment. Restorevegetation following repair.

• Major cracks greater than 1/2-in. wide and with vertical displacement across the crack, inparticular on the side slopes along the contours, may be indicative of slopedeformation/sliding and will be evaluated by the Site Engineer prior to implementingrepair. The repair may involve excavation of large areas of the cover material, possibly tothe full depth of the cover. The area affected will be excavated making sure that theupper part of the slope showing cracks is excavated first to minimize potential for slopefailure. The excavated area will be backfilled with cover material in 6-in. thick lifts,moisture-conditioned and compacted in accordance with the Construction Specifications.Following compaction the area will be promptly seeded to help establish vegetation.

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3. Surface Depressions:• Surface depressions on the top deck and side slopes will be repaired by backfilling with

cover material. Prior to backfilling, the area of the depression will be cleared ofvegetation and scarified to a minimum depth of 6 in., and the material moisture-conditioned and compacted in accordance with the Construction Specifications. If thedepression is relatively shallow, the area of the depression will be cleared of vegetationand excavated enough such that the placement of material can occur in at least one fulllift without feathering at the edges.

Following repair of the depressions, the area will be revegetated as soon as practicable.

4. Erosion Channels:• Prior to repair of erosion channels, the walls and bottom of the channels will be cleared of

vegetation, deleterious materials and loose soil and laying back the slope at 1:1 intocompetent material. The excavated channels will be backfilled with cover material,placed, moisture-conditioned and compacted in 6-in. thick layers in accordance with theConstruction Specifications.

• Following backfilling, the area will be revegetated as soon as practicable.• If the timely repair of the erosion gullies is not feasible due to continuing wet weather,

temporary backfilling of erosion channels may be performed to minimize potential forenlargement of channels. Such temporary backfilling may be performed using coarserockfill. The rockfill will, however, be removed prior to performing permanentbackfilling with cover material.

5. Sloughing/Slope Features:• Should sloughing of the cover occur due to saturation from rains, irrigation line or surface

water facility failure, the damaged cover will be removed to the competent materialsurface.

• Should sloughing result in creation of a headscarp on the slope along the contour, it maybe indicative of slope failure. The remedial grading may include removal andreplacement of a relatively large area of the slope.

6. The following guidelines apply where vegetation enhancement or replacement is required:• Weed and fire control - where growth of undesirable plants occurs, evaluate the situation

and determine the level of control required prior to implementing weed removal. Severalweed control and removal methods are available. The selection of a preferred method isdependent upon the level of nuisance. Shrubs with deep root systems that havenaturalized in shallow soil areas require hand removal before the roots cause damage tothe cover. To reduce fire risks, any areas of all grass, such as the top deck, can bemechanically "mowed" to reduce the amount of fuel.

• Reseeding - where vegetation is lacking, evaluate the implementation methods availablefor optimum field results, such as mechanical application or hand application.Mechanical applications should be completed for large areas (±2 acres) and when more

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CSA021534


than one step is necessary. Hand applications should occur in small areas where a hand-held spreader is better suited.

• Rodent control - Where burrowing activities pose a threat to the cover, determine theoptimum method of removal prior to implementation. A licensed pest control advisormay be required if excessive rodent populations exist.

7. Mowing of the vegetation will be conducted annually, if required to reduce the amount offuel. The vegetation will be mowed when it starts to dry and fade to brown. To reduce thespread of fire a water truck and driver will follow the mowing operation.

8. Maintenance and repair of the cover will be documented on Form SOP 150-1.

9. Notification of the EPA of start and finish of major repair activities (i.e. those necessary torestore compliance with Performance Standards) will be completed as specified in theCasmalia Consent Decree.

CSA021535

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FORM SOP 150-1

LANDFILL COVER REPAIR RECORD





REMARKS:

Signatures

Site Inspector - Date


CSA021536L:\40000\47588\WP\SOP\SOP150 Harding Lawson AssociatesApril 13, 2000 - Revision 0

DISTRIBUTION


April 13, 2000

Copy No. Q

Copies 1-2: Mr. Corey BertelsenCBCI5866 Pebble Beach WaySan Luis Obispo, California 93401

Copies 3-5: Mr. S. J. ChemUnited States Environmental Protection Agency - Region 975 Hawthorne StreetSan Francisco, California 94105-3901

Copy 6: Ms. Caroline G. RudolphCalifornia Environmental Protection AgencyDepartment of Toxic Substances ControlSite Mitigation (HQ-27)301 Capitol Mall, 3rd FloorP.O. Box 806Sacramento, California 95812-0806

Copy 7: Mr. Dan NilesCalifornia Regional Water Quality Control Board - Central CoastRegion81 Higuera Street, Suite 200San Luis Obispo, California 93401-5427

Copy 8: Ms. Mary Ann ScottSanta Barbara County1226 Anacapa Street, 2nd FloorSanta Barbara, CA 93101

Copy 9: Mr. Michael MartinCalifornia Department of Fish and Game530 East Montecito Street Room 104Santa Barbara, CA 93103

CSA021537

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DISTRIBUTION(Continued)


April 13,2000

Copy 10:

Copy 11:

Copy 12:

Copy 13:

Copy 14:

Mr. Glenn R. AndersonTexacoEHS DivisionPost Office Box 77562255 North Ontario Street, Suite 130Burbank, California 91519-7756

Mr. Jim DragnaMcCutchen, Doyle, Brown & Enersen, LLP355 South Grand Avenue, Suite 4400Los Angeles, California 90071-1560

Mr. Bill FellerCasmalia LandfillP.O. Box 208Casmalia, California 93429

HLA Project File

HLA Reports Only File

Quality Control Reviewer

David A. Pelser, P.E., DEEPrincipal Engineer

CSA021538

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CSC's Response to EPA's Comments on Draft P/SLandfill Cap O&M Manual

GENERAL COMMENTSGl) Provide Missing Information: Key information necessary for successful operation

and maintenance (O&M) of the P/S Landfill cover system is missing. The followinginformation shall be included in the final O&M Manual:

Complete surface drainage information (e.g., information on bench road culverts,Arizona crossings, etc. is missing).

Response:The revised O&M Manual now includes additional text and figures describing thestorm water drainage system of the P/S Cap.

• Maximum allowable landfill liquid level (assumed in the design for stability analysis)and use of the Gallery Well to maintain appropriate landfill levels.

Response:The revised O&M Manual includes a description of the liquid level that was assumed

for stability calculations.

• Irrigation system, including appropriate discussions on the salient features of theirrigation system, including its purpose, operation, inspection, maintenance, andrepair.

Response:The revised O&M Manual includes a section describing the irrigation system whichincludes all of the information listed above.

• Description of the foundation layer as having a maximum hydraulic conductivity of 1x 10-6 cm/sec.

Response:The revised O&M Manual incorporates this change.

CSA021434Attachment A: General Comments on the Draft Operation and Maintenance Manual Pesticides/Solvents

Landfill Cap for the Casmalia Resources Hazardous Waste Management FacilityJanuary 6, 2000Page 1 of 19

• Toe Buttress, including appropriate discussions on toe buttress construction, salientfeatures, and its inspection, maintenance, and repair.

Response:The revised O&M Manual now includes a section, which describes the toe buttressand construction. The toe buttress has been incorporated into the discussions oninspection and maintenance.

• Gallery Well Pad Inspection, including appropriate discussions on the salient featuresof the gallery well pad, including its purpose, operation, inspection, maintenance, andrepair.

Response:The revised O&M Manual now includes a section on the Gallery Well whichaddresses all of the items listed above.

G2) Intrusive earth work: The O&M Manual shall be revised to include in all relevantsections that all proposed earth work that involves the breaching of any of thegeomaterials be immediately reported to the appropriate regulatory agencies, andapproval of the proposed work be obtained prior to the commencement of the work.

Response:The revised O&M Manual now includes specific language that incorporates thisrequirement.

G3) Cover System Crack Monitoring: The O&M Manual needs to include themonitoring and repairs of cover cracking. The document shall be revised to includethe monitoring a repair protocol for addressing the development of surface cracks.

Response:The revised O&M Manual incorporates new text which addresses monitoring andrepairing surface cracks.

G4) Soil Erosion Reporting: The O&M Manual does not include provisions for themonitoring, approximate quantification, and reporting of soil loss from the cover.The O&M Manual shall be revised to include the protocol for assessing and reportingsoil erosion loss.

Response:The revised O&M Manual includes provisions for monitoring soil loss.



G5) Cover System Damage Assessment and Reporting: The O&M Manual shall berevised to clearly state that all damage to the cover system be immediately verballyreported to the EPA within 24 hours and reported in writing within 48 hours.Damages include but are not limited to erosion that daylights any of the geomaterials,loss of excessive cap soils (evident from siltation in drainage channels and fromobservations of the cap), large-scale surface depressions, extensive cracks, anylocalized failure of surface water drainage system, seismically-induced damage, andany similarly important adverse events and conditions. The O&M Manual shall alsoinclude the protocol for assessing the extend of cover system damage and outline thereporting and approval process for proposed repair work. The O&M Manual shallalso state that repair work plans shall require agency approval prior to thecommencement of work.

Response:The revised O&M Manual incorporates these requirements.

G6) Regrading: Appendix C repeatedly refers to regrading as a means of eliminatingsurface depressions. A depression may be due to rodents (likely small and localizeddepression), or to differential settlement (much larger scale). A larger-scaledepression in the surface vegetative layer most likely also means a depression in thegeomembrane and geocomposite, which must be eliminated to avoid ponding on topof the geomembrane. Unless the depression can be shown to be limited to thevegetative layer, depressions cannot be simply repaired by backfilling or regrading.

The O&M Manual shall be revised to include: i) protocol for reporting the occurrenceof depressions in the cover to EPA, ii) the assessment of the depressions, and iii)protocol for preparation and submittal of repair plans needed to restore the affectedarea to its prior and complete functionality.

Response:The revised O&M Manual incorporates new language which addresses the protocol

for monitoring, reporting, and repairing surface depressions.

G7) Grid Map: The O&M Manual discusses (Section 3.1.1) inspection of the landfill ona grid map. The O&M Manual shall include a grid map for various inspection.

Response:The revised O&M Manual includes a copy of the grid map used for cap inspections.

G8) Accurately Cite Reference Documents: There are several inconsistent titles todocuments cited in the O&M Manual. References to existing documents shall beverified for the correct title, source, and date.



Response:The revised O&M Manual was checked by a technical writer to minimize anyinconsistencies or incorrect references.

G9) Update Incorrect or Dated Information: The draft O&M Manual presentsincorrect or dated information regarding the P/S Landfill and cover system.. TheCSC shall review the draft report for consistency with the final design and incorporatethe as-built configuration of the cap, drainage, and erosion controls.

Response:The revised O&M Manual was updated to reflect as built conditions of the P/SLandfill Cap and checked by a technical -writer.

G10) Scope of Manual: The O&M Manual shall clearly identify that it is intended forboth the Part 1 and Part 2 of the Pesticides/Solvents landfill construction activities.

Response:The revised O&M Manual identifies that it is intended to cover the entire P/S LandfillCap.

Gil) Provide for Future Updating of O&M Plan: A section shall be included in thefinal O&M Manual providing the protocol for updating the manual. Specifically, theO&M Manual shall be updated, as appropriate, when baseline landfill conditionschange. Examples of this are: i) potential modification of irrigation system, ii)potential modification of the Gallery Well extraction system., and iii) the installationof additional liquids extraction systems.

Response:The revised O&M Manual includes a section which provides for updating of themanual as appropriate.

G12) Acronyms: Include the Department of Toxic and Substances Control (DTSC) withthe list of Acronyms and Abbreviations.

Response:The revised O&M Manual incorporates this request.

G13) Correct Editorial Deficiencies: There are numerous grammatical errors,inconsistencies, and missing information within the document. The final O&MManual shall be carefully revised by technical staff and finally reviewed and edited bya technical editor. Example deficiencies found in the draft O&M Manual include:

Attachment A: General Comments on the Draft Operation and Maintenance Manual Pesticides/SolventsLandfill Cap for the Casmalia Resources Hazardous Waste Management Facility

January 6, 2000Page 4 of 19

CSA021437

• Grammar and sentence structure is often poor, with run-on sentences, etc.

• All tables, figures, and appendices shall be referenced from the main text and theirorder in the document shall be consistent with their initial reference. This is currentlynot done.

• Some of the Standard Operating Procedures (SOPs) are referenced in the applicablemanual sections, and some are not. All SOPs shall be consistently referenced.

• A standard syntax must be used for referencing source documents: The currentmethodology is inconsistent and incomplete.

• Inconsistent abbreviation syntax is used throughout the document.

Response:The revised O&M Manual was checked by a technical writer to minimize anyeditorial deficiencies. The technical writer specifically addressed all of the issueslisted above.

G14) Report Distribution: Distribution of various reports shall include the state andcounty agencies (i.e., DTSC, RWQCB, California Department of Fish and Game,Santa Barbara County, etc.).

Response:The revised O&M Manual will be distributed to the above agencies.

G15) Personnel Qualifications: The qualifications of various personnel identified in theO&M Manual shall be included (such as the inspector, on-site personnel, and siteoperations manager).

Response:The revised O&M Manual specifically identifies the personnel which will beperforming the site inspections and the qualifications of the personnel required toperform maintenance or engineer repairs. We have not included resumes of on sitepersonnel as they will change over time.

G16) Signature by Professional Engineer: The final O&M Manual shall be signed andstamped by a qualified California certified professional civil engineer (P.E.).

Response:The Final O&M Manual will be signed and stamped by a registered civil engineer.

Attachment A: General Comments on the Draft Operation and Maintenance Manual Pesticides/SolventsLandfill Cap for the Casmalia Resources Hazardous Waste Management Facility


CSA021438

G17) Cover Irrigation System: The draft O&M Manual includes no discussion regardinginspection, maintenance and repair of the cover system irrigation system. The finalO&M Manual shall include a detailed discussion of the cover system irrigationsystem, that includes, piping layout, water source, pumping specifications, shutoffvalve locations, etc.

Response:The revised O&M Manual includes a section which describes in detail the temporaryirrigation system installed for the cap. As provided by the cap constructionspecifications, that irrigation system will likely be removed after next summer.




SPECIFIC COMMENTS

SI) Title Page:

• The correct title of the document shall include the letter "s" after each of the words,"Pesticide" and "Solvent." This shall be changed on the title page, and any otherplace in the document where this occurs.

Response:Completed as requested.

52) List of Acronyms and Abbreviations, Page IV:

• There are inconsistencies with acronym definitions in this section and throughout thedocument. The document needs to be reviewed for consistency and verification ofacronyms and abbreviations.

• See General Comment G12.


53) Section 1.0, Page 1:

• The correct name of the landfill includes pesticide and solvent to be plural. Thisneeds to be verified throughout the document and globally changed to"Pesticides/Solvents".


• Third paragraph. The reference to the Casmalia Consent Decree Statement of Workregarding requirements for an O&M Manual is "Section 3.14" (not Section 3.1.3).


CSA021440Attachment B: Specific Comments on the Draft Operation and Maintenance Manual Pesticides/Solvents

Landfill Cap for the Casmalia Resources Hazardous Waste Management FacilityJanuary 6, 2000Page 7 of40

• The fourth paragraph, the first sentence is unclear and needs to be revised forclarification.



• Figures 1 and 2 are to be cited in this section. Also, figure citations and numberingshall be consistent with their initial introductions in the manual, (e.g., Figure 1 shallbe cited before Figure 2, etc.).


55) Section 1.2, Pages 2 and 3:

• For consistency, the site history section from the P/S Landfill cap design documentsneed to be inserted into the O&M Manual.

Response:The revised O&M Manual incorporates the Final Design as a reference document.We have identified the pages in the design document where the site history can be

found.

56) Section 1.2, Page 2, Paragraph 3:

• The word "closed" in reference to a hazardous waste site has specific regulatorymeaning and is inappropriately used. The reference to the Casmalia site shall bechanged to "inactive".



• The entire agency name shall be spelled-out at first mention (i.e., Regional WaterQuality Control Board and Environmental Protection Agency).


Attachment B: Specific Comments on the Draft Operation and Maintenance Manual Pesticides/SolventsLandfill Cap for the Casmalia Resources Hazardous Waste Management Facility

January 6, 2000Page 8 of40

CSA021441


• "Part I Construction As Built Report" is the incorrect title of the document. Afterconstruction of the toe buttress, two reports were prepared ([1] Construction QualityAssurance Report, Pesticides/Solvents Landfill Closure, Part I - Toe ButtressExpansion and [2] Casmalia P/S Landfill Part I Construction Report) to document thePart I construction. The titles of these documents and other documents referencedthroughout the report shall be verified and corrected


• The P/S Landfill cap is still under construction and will most likely continuethroughout this winter. In addition, as discussed some areas and components of thecover systems will need reconstruction which will be performed in the Spring of2000. The correct construction period shall be indicated in the document.



• The first sentence of this section is unclear and needs to be revised for clarification.The sentence is too long and ambiguous. As written, the "reader" is responsible forimplementing the actions of the O&M Manual.


• A standard syntax shall be used for referencing: Title (Author, Date). The currentmethodology is inconsistent and incomplete.

Response:Completed as requested (see general comments).

• "Part I Construction As Built Report" is the incorrect title of the document. Afterconstruction of the toe buttress, two reports were prepared ([1] Construction QualityAssurance Report, Pesticides/Solvents Landfill Closure, Part I - Toe ButtressExpansion and [2] Casmalia P/S Landfill Part I Construction Report) to document thePart I construction. The correct titles of the documents shall be verified. Thereferences shall be properly documented to include the author and date of report.


January 6, 2000Page 9 of40

CSA021442


• The document, "Pesticides/Solvents (P/S) Landfill Cap Final Design Report, Revision2.1" (GeoSyntec Consultants, Inc., July 14, 1999) is incorrectly cited. At a minimum,"Revision 2.1" shall be added for clarification.


• Reference to Standard Operating Procedures and Applicable or Relevant andAppropriate Requirements is unclear. The appropriate appendices within the O&MManual shall be cited for clarity.

Response:The revised O&M Manual includes appropriate references to SOPs or ARARs whencited.


• In the second sentence, remove "basically". The cover system design also shall bereferenced as a "RCRA equivalent cap".


511) Section 2.1, Page 4, Second Bullet:

• The foundation layer also serves the purpose as a low permeability layer. Thisreference as well as the permeability specifications shall be described in thedocument.



• There are three final design reports. The Final Design Report version, date, and authorshall be referenced.




CSA021443

• A north-south longitudinal cross section through the P/S Landfill needs to be added asa new figure. The cross-section shall show key information necessary for successfuloperation and maintenance of the landfill.

Response:A cross section was added as requested.

• The foundation layer is a critical component of the final cap. The description of thefinal cap shall also include a description of the maximum permeability of the material(lxlO-6cm/s).


• Verify correct title of Part I Construction as-built report.


• The words "screened, amended," shall be deleted from the description of thefoundation layer. This material was not screened or amended.


• The wording "60 mil high" shall be changed to "60-mil thick."


• This section needs to also include a description of the minimum, maximum, andtypical grades over typical grade areas.


S13) Section 2.1, Page 5, Paragraph 1:

• A sentence needs to be added stating that the east and west cap limits are temporary.

Response:



CSA021444

Completed as requested.


• The title of the construction report shall be corrected and references to the reportsadded.


515) Section 2.3, Pages 5 and 6:

• The liquid level in the landfill shall be maintained at or below the liquid levelassumed for the gross landfill stability analysis performed during the design process.Liquids extraction from the Gallery Well will play a key role in maintainingmaximum allowable landfill liquid levels. The maximum allowable landfill liquidlevel and how it will be maintained is currently not addressed in the document. Asection shall be added describing this information and addressing this issue.



• Add the word "currently" before the word "includes" in the first sentence.


SIT) Section 2.3, Page 5, Paragraph 5:

• EPA is aware of no design or construction documents relating to the installation andconfiguration of the subsurface clay barrier. The description in the document shall beappropriately qualified.


S18) Section 2.3, Page 6, Paragraph 0:

• Descriptions of the liquid monitoring and controls systems are essential for the O&MPlan as well as identifying the location of the Gallery Well and piezometers. The



CSA021445

location of the liquid extraction well and piezometers on Figure 3 are not clear andmust be verified. A new figure shall be added showing the Gallery Well constructionand its liquids extraction system (pumps, piping, controls, etc.). The statement madethat the well and piezometers are located within the waste footprint shall beconfirmed and clarified.

Response:A section has been added describing the Gallery Well and piezometer locations.

• It is unclear what "5-6" defines in the third sentence.

Response:This description has been clarified.

• The reported completion depth of the Gallery Well is 80 feet, not 75 feet. In additionthe casing length has been extended as part of the construction work. The currentcorrect depth of the well from the TOC shall be referenced. In addition, define theterm "TOC".


• The acronym "HP" in the last sentence of the last paragraph shall be defined.

Response:HP has been defined as Horse Power.

S19) Section 2.4, Page 6:

• The description of the surface drainage control is incomplete. In addition to thefacilities described, there are other structures that assist in conveying storm water tothe RCF pond. For example, additional facilities include the 18-inch diameter CMPculverts at each bench road and perimeter road intersection as well as concreteArizona crossings. Some locations of the Arizona crossings also have 3-inch highsplash walls to prevent storm water from overtopping the perimeter road thusreducing erosion of the side slope. This section shall be expanded to include allelements of the P/S Landfill Cap storm water management system.

Response:The description of the surface water system has been expanded to include as built

features.



CSA021446

• Drainage structure locations shall be referenced to Figure 3. Figure 3 shall also showcorrect locations of all drainage controls.



• Text discusses six transitional benches to .reduce the flow velocity. The text shall berevised to the fact that the Pesticides/Solvents landfill cap will have only fivetransitional benches to reduce the flow velocity.


• The description of the landfill slopes shall be expanded to include a description of theminimum slope, maximum slope, and typical grades over unique grade areas of thelandfill cap.


• The slope configurations were used in the slope erosion calculations. It is unclearhow the landfill slopes were limited to reduce flow velocity. Because HLA are notthe designers, HLA shall cite the appropriate design reports when making statementsabout the design.

Response:The revised O&M Manual cites reports as required.


• A figure shall be added and referenced in this section that provides the constructionand design details for the settlement markers.

• The surveyed in coordinates and elevations of the settlement markers and thepermanent survey monuments shall be included in the document.

Response:The revisions include references to the requested information.



CSA021447

Response:The coordinates of the settlement markers is included in the revised O&M Manual.

• The text shall also state that the permanent survey monuments are located outside thelimits of P/S Landfill waste.

Response:The text states three markers are located outside the landfill limits.

522) New Section 2.7, Cover Irrigation System:

• A new section shall be added that fully describes the cover irrigation system. Thissection shall include, piping layout, water source, pumping specifications, shutoffvalve locations, etc. As well as references to appropriate figures and tables.

Response:Completed as requested (see response to general comments).


• The primary objective of the O&M Manual is to preserve the function and integrity ofthe final cover system. This needs to be added.


524) Section 3.1, Pages 8 thru 10:

• The section on Monitoring and Maintenance shall be revised to address the following:

• The SOPs shall be referenced to Appendix C.

Response:Cqrrected.

• No references to the appropriate Site Safety and Health Plan were provided in Table1, as stated. This shall be corrected


• Surface tension cracking in the vegetative surface is also and indication of cap failure



CSA021448

and cover system movement and slippage. This shall be included as an inspectionparameter.


• Discoloration of the vegetation is also an indication of cracking or failure of the finalcap and shall be included as an inspection parameter.


• Visible signs of slope instability and movement (both local and global movement)shall be included in the bulleted list of inspection parameters.


• Drainage ditches are not the only drainage structures on the landfill. Monitoring andmaintenance of the CMP culverts and Arizona crossings shall also be addressed.


• Color photo documentation of all inspections shall be performed. Appropriatephotographs shall be included in inspection reports.

Response:Color photos are identified in the revised O&M Manual.

• The quarterly inspection reports shall also include, in addition to the listed items, thedescription of repairs completed in the quarterly period, and the listing and schedulingof pending repairs.


• The document states "D If any damage to the cap or drainage system is observed, itseffect on the integrity of the cap system will be evaluated, and repairs scheduledaccordingly". The O&M Manual shall:

i) define the damage to the cap and the drainage system,



CSA021449

ii) identify how the integrity of the cap system will be evaluated; and,

iii) when the repairs will be scheduled.


• The document states "DUpon completion of cap and drainage system inspections, theinspector will prepare a report...". The O & M Manual shall identify that theinspector who prepares the Report shall be a civil engineer who is a P.E.


• The document states "DThe inspection reports will be kept onsite and a copyforwarded to the EPAD". A copy of the inspection report shall also be sent to thestate and county agencies (see General Comment No G14).

Response:The CSC is happy to submit inspection reports to any agency EPA directs us to.

• The document states "D Major repairs will be completed under the supervision of alicensed civil engineerD". The report shall define "major repairs". Subjectiveassessment of the difference between major and minor repairs shall be avoided. Alisting of examples of each repair type is needed.

Response:We will agree with EPA at the time of any damage what work is major and what workmay be considered minor. The revised O&M Manual does not attempt to define thisbut indicates EPA will make that determination.

• The O&M Manual shall include a brief summary of the monitoring and maintenancedetails for the Gallery Well and the piezometers.


• Inspection and maintenance of the cover irrigation system shall also be addressed.The section shall be revised to provide full documentation for the inspection of theirrigation system.


January 6,2000Page 17 of 40

CSA021450

Response:Completed as requested (see response to general comments).

S25) Section 3.1.1, Page 10:

• The word "natural" shall be deleted from the first sentence in the second paragraph.


• A statement shall be added requiring that all cuttings resulting from mowing activitiesshall be removed from the landfill cover.

Response:We have not incorporated this request as the cuttings from mowing will contributeorganics (mulch), moisture retention and seeds to the soil -which are important tolong term viability of the vegetation. The CSC does not understand -why EPA would•want to remove the cuttings.

• A statement shall be added that describes how holes remaining from removedseedlings and deep-rooted growth will be repaired.

Response:A statement was added as requested.

• Surface cracking and discoloration of the vegetation are also indications of failure ofthe final cap and shall be included in the vegetative monitoring procedures.


• A definition of "established " vegetation shall be provided.

Response:A description of established was added as requested.

• The O & M Manual shall define "on site personnel". See also General Comment NoG15.

Response:See our response to general comment 15.



CSA021451

526) Section 3.1.2, Pages 10 and 11:

• Additional detail is required describing the type of surface erosion damage that willrequire repair.


• There are three versions of the Final Design Report. References shall be provided forthe Final Design Report and the SOPs.


527) Section 3.1.3, Page 11:

• All geosynthetic repair SOPs shall be included and appropriately referenced.

Response:Geosynthetic repair SOPs are referenced to the Final Design Report in the reviseddocument.

528) Section 3.1.4, Page 11:

• "Siltation" shall be added as an inspection parameter.


• It is inappropriate to state that "it is not necessary to repair all cracks orimperfection(s) in the channels." Drainage channels are points of concentrated flow.Therefore they present a significant infiltration risk if they are cracked. Bestmanagement practices require that the drainage channels be maintained in their as-designed state. This statement shall be deleted or modified. In addition, all erosionareas that begin to undercut any portion of the drainage channels shall be repairedimmediately.

Response:All drainage channels are underlined with geosynthetic and geocomposite. Thechannels do not serve as a hydraulic barrier, but are intended only to eliminateerosion in these concentrated flow areas. The revised O&M Manual notes significantcracks should be repaired. Minor cracking should be expected in these structures and



CSA021452

poses little risk of erosion.

529) Section 3.1.5, Page 12:

• Cracking is also an indication of failure in the final cap and shall be included in theinspection procedures.


• Rutting shall be included in the list of inspection items.


• Quarterly inspections are not acceptable. As discussed in Specific Comment S34 atiered inspection schedule is required for the cover system. This section shall berevised to reflect the changes mandated for Table 1 as outlined in Specific CommentS34.

Response:The CSC has proposed a monthly inspection schedule for the cap in the revised O&Mmanual.

• All repair requirements outlined in the Final Design Report shall be incorporated intothe text of the final document.


530) Section 3.1.6, Pages 12 and 13:

• The document shall be revised to state that the permanent survey monuments arelocated outside the limits of waste.


• The document shall describe how survey monuments and settlement monuments willbe protected and maintained.

Response:



CSA02I453

Completed as requested.

• The surveyed in coordinates and elevations of the settlement markers and thepermanent survey monuments shall be included in the document.


• Iso-settlement maps shall be included as part of the report submittal for settlementmonitoring.

Response:This requirement has been added.

• The settlement monitoring discussion shall include the proposed accuracy of thesurvey.

«


• The schedule for landfill settlement monitoring shall be as follows: i) quarterly fromnow until a period of one (1) year after EPA's acceptance of the construction report,ii) semi-annually for the next five years, and iii) annually thereafter.

Response:The revised O&M Manual lists the settlement monitoring requirement as annual.

531) New Section 3.1.7, Cover Irrigation System:

• A new section shall be added that fully describes the maintenance of the coverirrigation system.

Response:See response to previous general and specific comments.


• The landfill cover system shall be inspected as soon as possible and no later than 24hours after an event listed in this section. The text is to be revised accordingly.




CSA021454

• The term "Major earthquakes" is ambiguous. The cover system shall be inspectedafter any seismic event greater than 5.0 in magnitude occurring within 100 milesearthquake of the site.


• The text shall be revised to provide more detail as to what constitutes a "failure of thedrainage system."

Response:Additional text was added as requested.


• Manufacturer's Repair and Procedures and Recommendations are included inAppendix A. This section shall be revised to reference this Appendix.


• All repair SOPs from the Final Design Report shall be attached to the O&M Manualand appropriately referenced. The CSC shall check to see that the correct SOPs areincluded in the manual and that they are consistent with the design documents.

Response:The Final Design Report -will be incorporated as a reference document into therevised O&M Manual. The SOPs have been checked to ensure consistency.

• Repair and/or replacement of any geosynthetic component of the final cover systemshall include all applicable quality control and quality assurance actions. The finalO&M Manual shall provide a discussion on the QA/QC requirements and protocols.



• This section shall be revised to address Specific Comment S23. The documentationshall be expanded to define what constitutes a "slope failure." Surficial sloughs, aswell as deep-seated failures, will trigger a maintenance response.



CSA021455


• All slope and cover system failures shall require investigation and a written reportshall be submitted to the agencies for review. Prior to the commencement ofpermanent repair work approval from EPA is required. The language in this sectionshall be revised accordingly.


• See General Comment G5 regarding agency notification.

• In the event of waste containment failure, the affected area "shall" be temporarilycovered. The last sentence in this section is to be revised accordingly.


S35) Section 5.0, Page 16:

• Section 5.0 shall be revised to state that the only routine vehicle traffic allowed on thePesticides/Solvents Landfill cap are those vehicles specifically associated with themonitoring and maintenance of the Pesticides/Solvents Landfill cap.


• The section shall be revised to clearly state that vehicle traffic is not allowed on anyof the landfill drainage ditches.




CSA021456


TABLES

S36) Table 1, Routine P/S Landfill Cap Maintenance and Inspection Schedule:

• Inspection of the landfill cap on a quarterly basis is inadequate, considering the factthat no established vegetation is in place as the rainy season begins and site-specificerosion experience from other areas of the site is available. A tiered inspectionschedule for the cover system is required as follows:

i) From now until June 30, 2000: all features of the newly placed cap, thevegetation, the roads, the toe buttress, and the drainage system be inspectedbi-weekly with no more than 14 days passing between each inspection.

ii) Starting from July 1, 2000 to a period of one (1) year after EPA's acceptanceof the construction completion report, or June 30, 2001, all features of the cap,including the vegetation, the roads, the toe buttress, and the drainage systemshall be inspected monthly. For the monthly inspections no more than 30 daysare to pass between inspections. After 1 year the inspection schedule shall bereviewed by EPA and adjusted as appropriate.

Response:The revised O&M Manual proposes a monthly inspection period for the items notedabove.

iii) Settlement monitoring shall occur quarterly from now to a period of one (1)year after EPA's acceptance of the construction completion report, or June 30,2001, semi-annually for the next 5 years after then, and then annuallythereafter.

Response:The revised O&M manual proposes an annual settlement monitoring throughout.

• This table is incomplete. References to the Site Safety and Health Plan were notprovided. Also, time frames (i.e., month or season) for inspections and monitoringshall be included in the schedule.

Response:



CSA021457

The revised O&M Manual no longer refers to the Site Safety and Health Plan in thetext or table. We have not identified timeframes (i.e. the month or season) an annualinspection will be complete but anticipate that most annual surveys will be completein the summer -when the cap is most accessible.

• The words "or qualified installer" are in the incorrect column.

Response:Corrected as requested.

• Inspection of the irrigation system shall be included in the table. The system beinginstalled by the CSC is a manual system that requires an operator to both turn on andoff the irrigation lines. Any blowout of a line has the potential for causing seriouserosion damage. The irrigation system therefore shall be continuously monitored andthe lines visually inspected and walked at a minimum 2x per day while the system isin operation.

Response:Inspection of the irrigation is included in the table. The table notes at least a dailywalk is required when the system is operating.

537) New Table 2, Non-Routine P/S Landfill Cap Maintenance and InspectionSchedule:

• A new table that outlines the non-routine inspection and monitoring schedule asoutlined in Section 4.0 and that conforms to Specific Comment S30 and is required.

Response:Comment S30 refers to settlement markers and therefore no new Table 2 wasprepared. We have modified the text to state that non-routine maintenance will bedone in accordance with the procedures and SOPs included in the O&M Manual.

538) New Table 3, Agency Reporting Requirements:

• A new table that outlines the landfill cover system monitoring reporting requirementsis needed. The table shall address General Comments G3, G4, G5, G6 and G14 andSpecific Comments S23, and S32 and Section 3.1.

Response:The existing tables and text have been modified to address all of the comments listedabove.



CSA02M58

539) New Table 4, Survey Locations of Cover System Terminations:

• A table listing the survey points for the cover system termination locations shall beincluded.

Response:The revised O&M Manual includes the Final Design Plan and the Construction AsBuilt Report as references. The location of cover system terminations are included inthese documents.

540) New Table 5, Survey Locations of Settlement Markers:

• A new table listing the survey locations and elevations of the settlement markers isrequired.

Response:The revised O&M Manual includes the Final Design Plan and the Construction AsBuilt Report as references. The location of cover system terminations are included inthese documents.

• See Specific Comments S21 and S29.

Response:See our previous response.



CSA021459


FIGURES

S41) Figure 2, Site Layout:

• The title of the figure shall be changed to reference "Current Site Layout".


• The perimeter of the constructed cap shall be shown, in addition to the currently-shown P/S Landfill outline.

Response:The waste limit is shown. Multiple lines will not be legible at this scale..

• Overlap of text occurs at Pond 18, pond A-5 and the RCF Pond and shall becorrected.


• Pond 13 is not identified.


• The definition of the PSCT and PCT systems is required.


• The boundaries of the P/S Landfill are inaccurate and shall be redrawn. The GalleryWell is within the P/S Landfill boundary.

Response:The \vaste limit is shown. Multiple lines will not be legible at this scale..



CSA021460

542) Figure 3, P/S Landfill Site Plan:

• This figure is outdated shall be revised with current information.

• The grading plan and benches depicted on Figure 3 have been revised and shall beupdated.

• Settlement and Monument Coordinate Schedule is incomplete and shall be completed.

• Locations of permanent survey monuments are difficult to identify. The symbols forthese monuments shall be legible and pronounced for easy identification.

• Settlement markers SM1 and SM2 are illegible and shall be clearly identified.

• Storm water management system shall be shown.

• Perimeter road/ditch from the west portion of the P/S Landfill ties into the existing Ydrainage structure. This is not indicated on Figure 3 and shall be corrected.

• Source and date of topographic map shall be provided for future reference.

• The limits of the cover system are hard to identify and shall be clearly defined.

• The facility boundary line cannot be distinguished from the fence line which is notidentified on the figure.

• The Gallery Well leachate extraction point is not identified.

• The landfill limit boundaries are inaccurate and shall be revised. See EPA's August18,1998 conditional approval letter.

• The subsurface barrier walls are not identified.

Response:The revised O&M Manual includes the As Built report as a reference document. Thisdocument includes a revised Figure 3 -which includes all of the information listedabove.

543) Figure 4, Typical Cap Cross Section:

• The thickness call out for the lower 12-inch thick lift of vegetative soil layer is in thewrong location.



CSA021461

• The hydraulic conductivity specification for the foundation layer shall be added.

Response:Included as requested.

544) Figure 5, Traffic Plan:

• The grading plan and benches depicted on Figure 5 have been revised and shall beupdated.

• See Specific-*Comment S41 regarding figure inaccuracies.

Response:The revised O&M Manual includes the As Built report as a reference document. Thisdocument includes a revised Figure 5 which includes all of the information listedabove.

545) New Figure - Cross Section through P/S Landfill:

• A new figure shall be added showing a north-south longitudinal cross section throughthe P/S Landfill. The cross section shall show key information necessary forsuccessful operation and maintenance of the landfill.

Response:The revised O&M Manual incorporates the Final Design Report and the As BuiltReport as references. These documents include the information and figure notedabove. To assist the reader, we have specifically identified in the O&M Manual wherethe figures can be found in the referenced document.

546) New Figure - Gallery Well and Associated Liquids Extraction System:

• A new figure shall be added showing the Gallery Well construction and its liquidsextraction system (pump, piping, controls, etc.).

Response:While we have included information in the text of the O&M Manual further definingthe Gallery Well, we have not included construction details of the well in the P/S CapO&M Manual. This information is available in other site documents andappropriately referenced in the O&M Manual.

547) New Figure - Bench and Road Details:



CSA021462

• A new figure showing the bench and road details shall be included and appropriatelyreferenced in the document.

Response:The revised O&M Manual incorporates the Final Design Report and the As BuiltReport as references. These documents include the information and figure notedabove. To assist the reader, we have specifically identified in the O&M Manualwhere the figures can be found in the referenced document.

548) New Figure - Boundaries of High- and Low-Flow Geocomposite Placement:

• A new figure showing the boundaries of the high- and low-flow geocomposite-covered areas shall be included.

Response:The revised O&M Manual incorporates the Final Design Report and the As BuiltReport as references. These documents include the information and figure notedabove. To assist the reader, we have specifically identified in the O&M Manual•where the figures can be found in the referenced document.

549) New Figures - Surface Water Drainage System:

• New figures detailing the surface water drainage system shall be provided. Thesefigures shall provide the drainage flow routes as well as as-built cross-sections of theditches, culverts and Arizona crossings.

Response:The revised O&M Manual incorporates the Final Design Report and the As BuiltReport as references. These documents include the information and figure notedabove. To assist the reader, we have specifically identified in the O&M Manualwhere the figures can be found in the referenced document.

550) New Figure - Settlement Marker Detail:

• A new figure showing the design and placement detail of the settlement markers shallbe provided.

Response:The revised O&M Manual incorporates the Final Design Report and the As BuiltReport as references. These documents include the information and figure notedabove. To assist the reader, we have specifically identified in the O&M Manual



CSA021463

where the figures can be found in the referenced document.

551) New Figures - Cover Termination Location and Detail:

• New figures shall be added that show the survey locations for the termination pointsof the cover system and cross-section details of both the permanent and temporaryterminations.

Response:The revised O&M Manual incorporates the Final Design Report and the As BuiltReportas references. These documents include the information and figure noted above. Toassistthe reader, we have specifically identified in the O&M Manual where the figures canbefound in the referenced document.

552) New Figure - Cover Irrigation System:

• A new figure showing the layout and location of the cover irrigation system shall beincluded. The figure shall identify the locations of the piping, sprinkler heads, checkvalves, shutoff valves, pumps, pump controls, and electrical connections. The figureshall also identify the material and equipment specifications for each component ofthe system. This includes but is not limited to, pipe sizing, pump sizing, sprinklerhead capacity, etc.

Response:The revised O&M Manual incorporates the Final Design Report and the As BuiltReportas references. These documents include the information and figure noted above. Toassistthe reader, we have specifically identified in the O&M Manual where the figures canbefound in the referenced document.



CSA021464


APPENDICES

553) Appendix A, Manufacturer's Repair Procedures and Recommendations:

• No reference to Appendix A has been made within the report.

• Appendix A contains photo-copied portions of GSE Lining Technology, Inc's (GSE)proprietary Quality Assurance Plan. Appendix A shall be enhanced by identifyinggeomaterials used during the construction of the P/S landfill cap, including their vitalcharacteristics. Further Appendix A has generic information from GSE that statesthey reserve the right to discontinue the use of the policies and procedures. Giventhat fact, it is not clear how GSE information will be useful for the project. Anintroduction to this appendix shall be provided that clearly describes how thisinformation shall be used.

Response:The revised O&M Manual incorporates the Final Design Report and the As BuiltReport as references. These documents include the information noted above. Toassist the reader, we have specifically identified in the O&M Manual where theinformation can be found in the referenced document.

554) Appendix B, Applicable or Relevant and Appropriate Requirements:

• This appendix is just a copy of the ARARs section form the design and constructiondocuments. The appendix shall be revised to only identify and address those ARARsrelating to cover system O&M.

Response:Modified as requested.

555) Appendix C, Standard Operating Procedures:

• Appendix C consists of SOPS that were clearly written for another landfill whosecover is a nionocover-type. Little or no effort has apparently been taken to conformor modify the lifted SOPS to fit the specific cover and site conditions at the CasmaliaSite. In numerous cases, the elements of the SOPS are incomplete, inaccurate, and



CSA021465

inapplicable to conditions and features at the Casmalia Site. Examples include, butnot limited to:

i) References to SOPS that are not included;

ii) References to non-existent features (monocover, racks and grates on dropinlets, risers, cylinders (?), firebreaks, etc.);

iii) Inappropriate repair guidelines (guidelines are intended for the repair of amonocover, not a multi-layer cover such as at Casmalia); and,

iv) missing SOPS, incomplete and missing references, etc.

Further, the monitoring inspection frequency identified in the SOPS are notcompatible with the schedule shown in the Table 1. Appendix C requires a completerevision so that it conforms to actual site conditions and to adhere to the general andspecific comments provided in this letter. EPA is providing the following SpecificComments S56 through S_so that Appendix C can be adequately re-written. Thesecomments are by no means all inclusive. Appendix C shall be re-written so thataddresses all of EPA's general and specific comments, this includes revising allchecklists and forms.

Response:The SOPs have been checked and revised as appropriate to ensure they are specific tothe P/S Landfill Cap.

S56) Appendix C, Standard Operating Procedures, General Comment:

• A tabulation, in numerical order, of all the SOPs included in Appendix C, shall beinserted at the beginning of this appendix.

Response:A list of the SOPs is included in the revised table of contents.

• Color photo documentation shall be added to the list of items needed for a visualinspection in all applicable SOPs.


• A data entry field shall be added to all forms for the description of the climaticconditions at the time of the of inspection.



CSA021466


557) Appendix C, SOP 104, Section 1.0, Page 1:

• "60mil" shall be changed to "60-mil thick".

• The final cover system for the P/S Landfill is not a "monocover "as stated in thissection.

• The list of functions of the final cover are incomplete. The stated functions shall beprefaced with the word "include". A complete list of the functions shall be provided.


558) Appendix C, SOP 104, Section 3.0, Pages 1 and 2:

• Fifth bullet on page 2, the word "monocover" shall be deleted.

• Third bullet, page 2, item 5, the word "monocover" shall be deleted.

• See General Comment G3, G4, G5, G15, and G17 and Specific Comments S23, S24,525. S26, S28, S29, S30, S31, S32, S33, S34, and S35.



• The acronym "SHERP" shall be defined.

• Many references are made to the "SHERP" as part of the O&M procedures. Thisdocument shall be included as an attachment to the SOP.

Response:Reference resolve.

• See General Comments G2, G3, G4, G5, and G6 and Specific Comments S24, S25,526. S28, S29, S30, S31, S32, S33, S34, and S35.



CSA021467

Response:See previous response to listed comments.

560) Appendix C, SOP 106:

• It does not appear that this SOP is applicable to the O&M of the P/S Landfill coversystem. It appears that many of the sections in this SOP are relevant to the overallRoutine Site Maintenance Plan. All non-relevant sections shall be removed from thefinal document.

Response:This SOP was removed

• Regarding use of herbicides. All herbicide selection and use at the Casmalia site shallrequire prior approval from EPA.

Response:Noted


• This SOP is incomplete. There is the potential for contaminated liquid seeps to occurat the Toe Buttress and through the cap it self. SOPs outlining the procedures foraddressing liquid seeps shall be included in the final O&M Manual. This will includeprocedures for characterizing the liquids as well as collecting the liquids so thatsurface water run-off does not become contaminated

Response:The procedures for dealing with seeps are defined in existing TWP and RSM WorkPlans for the site. These documents are referenced in the revised O&M Manual.


• As this is to be a stand alone document, all referenced documents and proceduresshall be included in the final O&M Manual SOPs

Response:All referenced SOPS are included in the revised O&M Manual.


• Item 5. It shall be defined how the "adverse grade" will be measured.



CSA021468

• See General Comments G2, G3, G4, G5, and G6 and Specific Comments S24, S26,S28, S29, S32 and S35.



• See General Comments G2, G3, G4, G5, and G6 and Specific Comments S24, S25,S26, S28, S29, S31, S32, S33, S34 , and S35.

Response:See previous response to listed comments,

565) Appendix C, SOP 144, Section 2.1.1, Page 1:

• Second bullet, only black ink shall be used (no blue).


566) Appendix C, SOP 144, Section 2.1.2, Pages 1 and 2:

• See General Comment G5 and Specific Comments S29, S30, S36, and S37.



• See General Comments G2, G3, G4, G5, and G6 and Specific Comments S24, S25,S26, S28, S29, S31, S32, S33, S34 , S35, S36, and S37.


• Top deck slopes are constructed with a minimum slope of 4%. Inspections shallverify that the minimum slope of the top deck is greater than 4%, not greater than 2%as written.

Response:



CSA021469

SOP revised to address comment.

• Revise the last bullet under Item 1 to read "Inspect any signs of ponding over thelandfill cover system."


• Transitional crossings at the bench and perimeter road intersections are also part ofthe P/S Landfill storm water management system. Some crossings include curbs tocontain storm water within the crossing. Inspection of the crossing structures was notincluded in the procedures. A complete review of the storm water managementsystem shall be performed and addressed in this section.

Response:The revised O&M Manual now includes references to inspecting all features of thestorm water system.


• See Specific Comment S3 2.

Response:See previous response to comment.

569) Appendix C, SOP 144, Section 2.3, Pages 3 thru 5:

• See General Comments G2, G3, G4, G5, and G6 and Specific Comments S23, S24,S25, S26, S28, S29, S30, S31, S32, S33, S34 , and S35.



• In the first bullet on Page 4, the wording "avoid offsite runoff inundation" isconfusing and shall be clarified. No storm water runoff is allowed to leave the formerRCRA facility boundary of the Casmalia Site unless the discharge complies with theprovisions of the National Pollution Discharge Elimination System (NPDES) permitthat was issued by the Regional Water Quality Control Board

Response:



CSA021470

The -wording has been clarified as requested.


• See Specific Comment S67 regards minimum top deck slope.

• Item 2 is incomplete. Slopes are not provided.

• See General Comments G2, G3, G4, G5, and G6 and Specific Comments S23, S24,525. S26, S28, S29, S30, S31, S32, S33, S34 , and S35.



• The Sentence in Item 1 is incomplete and shall be revised. An expanded discussionof the detention basins and storm water management shall be included in the finalO&M Manual.

Response:The sentence was revised to be complete.


• See General Comments G2, G3, G4, G5, and G6 and Specific Comments S24, S25,526. S28, S29, S31,832, S33, S34 , and S35.



• Item 1, It shall be clarified how a "deficiency" will be quantified. This shall be asspecific as possible to avoid subjective judgments.

Response:As noted in the revised O&M manual, the operator will notify EPA of the conditionsof the cap and request they make a determination regarding deficiency.



January 6,2000

CSA021471

• See General Comment G5 and Specific Comments S30, and S36.



• Item 4. The term CADD shall be defined.

Response:CADD has been defined in the revised O&M Manual.


• See General Comments G2, G5, and G6 and Specific Comments S24, S26, S28, S29,S32, S34 , and S35.



• Item 3, first bullet, the wording "Fill shall be properly moisture conditioned prior tocompaction" shall be inserted after the first sentence.

• Item 4, first bullet, a requirement for proper soil processing, moisture conditioning,and compaction for all backfill operations shall be added.

• Item 4, second bullet, last sentence, the words "and at the proper slope" shall beadded after the word "intact".



• See General Comments G2, G4, G5, G6 and G17 and Specific Comments S24, S25,S26, S27, S28, S29, S30, S31, S33, S34, S35, S53 and S54.



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