Global Operations,Environment,Health &Safety · Ms. Karen Pelto September 8, 2016 Page 2 of 9 . of a minimum of two feet depending on the nature and quality of soil) to minimize the

Global Operations, Environment, Health & Safety

159 Plastics Avenue Pittsfield, MA 01201

Transmitted via Overnight Courier

September 8, 2016

Ms. Karen Pelto Lead Administrative Trustee Bureau of Waste Site Cleanup Massachusetts Department of Environmental Protection One Winter Street, 8th Floor Boston, Massachusetts 02108

Re: GE-Pittsfield/Housatonic River Site Unkamet Brook Area (GECD170) Completion of Installation of Restoration Work Report

Dear Ms. Pelto:

This Completion of Installation of Restoration Work Report is submitted by the General Electric Company (GE), pursuant to Paragraph 120 of the Consent Decree (CD) for the GE-Pittsfield/Housatonic River Site, to summarize the natural resource restoration/enhancement (NRR/E) measures installed at the Unkamet Brook Area Removal Action Area (RAA) under the CD. This letter report describes the Performance Standards and other requirements applicable to the installation of NRR/E measures at the Unkamet Brook Area, the NRR/E measures installed by GE, and the monitoring and maintenance activities for those measures.

I. Performance Standards and Other Requirements for Installation of NRR/E Measures at Unkamet Brook Area

Section 118.d.(i) of the CD and Sections 4 and 7 of Technical Attachment I to the associated Statement of Work for Removal Actions Outside the River (SOW) set forth the Performance Standards and other requirements for the implementation of a number of NRR/E activities in the Unkamet Brook Area, which were in addition to the remediation activities specified in the CD and SOW. The required NRR/E activities were described in Attachment I to the SOW and in GE’s Revised Final Removal Design/Removal Action Work Plan for Unkamet Brook Area-Remainder (Revised Final Work Plan for Remainder Area) submitted in April 2014 and conditionally approved by the U.S. Environmental Protection Agency (EPA) on May 21, 2014. As provided in those documents, the Performance Standards and requirements for installation of NRR/E measures at this RAA included the following:

• Removal of the existing stands of phragmites (an invasive plant species) in portions of the undeveloped wetland area east of Unkamet Brook, including removal of the surface soil to a depth of approximately one foot below the shallow groundwater as determined in May (total excavation depth

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Ms. Karen Pelto September 8, 2016

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of a minimum of two feet depending on the nature and quality of soil) to minimize the possibility for natural reestablishment of phragmites in this area, followed by allowing for redevelopment of the wetland community through natural succession;

• Following the installation of a vegetative landfill cap over the unpaved (eastern) portion of the former interior landfill, planting of an herbaceous native grassland community on the surface of the cap so as not to interfere with the integrity of the cap;

• Following the re-routing of Unkamet Brook from its then-current channel to its approximate original channel east of the former interior landfill, planting of an herbaceous native grassland community on the western side of the re-routed brook channel (between that channel and the eastern side of the landfill cap), as well as in any areas east of the re-routed brook channel that are disturbed by the rerouting activities; and

• Installation of bluebird boxes along the edge of the former interior landfill adjacent to the wetlands – i.e., between the eastern edge of the former interior landfill and the re-routed brook channel.

GE’s Revised Final Work Plan for Remainder Area specified that the areas designated for planting of an herbaceous native grassland community would be seeded with a specified mixture of native warm-season grass and wildflower species.1 Further details regarding the NRR/E measures for the Unkamet Brook Area were provided in GE’s Supplemental Information Package (SIP) for the Unkamet Brook Area Removal Action (September 14, 2014), an Addendum to that SIP (December 12, 2014), a Second Addendum to the SIP (April 3, 2015), and revised technical drawings (July 17, 2016, November 6, 2015, January 19, 2016, and March 10, 2016).

In addition to these NRR/E measures, Paragraphs 55 and 123.b of the CD require GE to execute and record a Conservation Easement and Restriction (CER) on approximately 10 acres of wetlands east of the former interior landfill. GE has prepared a draft of that CER, which is currently under review by EPA and the relevant state agencies. However, the execution and recordation of that CER are not part of the installation of NRR/E measures to be covered by the Completion of Installation of Restoration Work Report required by Paragraph 120 of the CD, and thus would not delay the determination by the natural resource trustees (Trustees) under that provision that the NRR/E measures have been installed in accordance with the CD requirements.

II. NRR/E Measures Installed or Implemented by GE

GE initiated the remediation/restoration activities in the portion of the Unkamet Brook Area north of Merrill Road in December 2014 in accordance with an EPA conditional approval letter for the SIP dated November

1 The Revised Final Work Plan for Remainder Area also provided that, at EPA’s request, GE had agreed to: (a) add a silty-sand mixture and the same herbaceous seed mixture into the void spaces of the riprap in certain bank areas along the re-routed brook and along the restored portions of the brook that were not re-routed; and (b) plant a variety of trees and shrubs along the eastern side of the re-routed brook channel (later modified to be the western side by agreement of EPA and GE). However, these activities were not part of the NRR/E measures for the Unkamet Brook Area.



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21, 2014. GE then continued and performed the remediation and restoration activities in that portion of the RAA through June 2016. These included the installation/implementation of the required NRR/E measures at this RAA to satisfy the applicable NRR/E Performance Standards and requirements. (No NRR/E measures are required in the portion of the Unkamet Brook Area south of Merrill Road). This section describes the installation/implementation of the NRR/E measures. The locations of those measures are shown on Figure 1. That figure also provides the final delineation of the Restoration Area at the Unkamet Brook Area, as required by Paragraph 122 of the CD.

Phragmites Removal

In accordance with the applicable NRR/E Performance Standards and requirements, GE conducted removal of the phragmites and associated shallow soil in two areas east of Unkamet Brook – a larger stand of phragmites in the wetlands area just south of Dalton Avenue (which was more extensive than the approximate 2-acre phragmites area referenced in Attachment I to the SOW) and a smaller phragmites stand located in the vicinity of the northernmost portion of the former interior landfill (excluding the portion within the former landfill itself), both shown on Figure 1. Prior to the removal of these phragmites stands, those stands were treated with herbicide on multiple occasions. The removal activities in the larger phragmites area were conducted between December 2014 and May 2015, and the removal activities in the smaller phragmites area were conducted in April and May 2015.

In accordance with the SOW and the Revised Final Work Plan for Remainder Area, GE excavated the surface and near-surface soil and associated phragmites in the phragmites removal areas shown on Figure 1 to a depth of approximately one foot below shallow groundwater, as determined during the month of May, or a minimum of two feet, whichever was greater.2 The excavated phragmites and soil were temporarily stockpiled on GE property along the embankment for Dalton Avenue within areas subject to future excavation or in properly constructed stockpiles in the parking lot over the western side of the former interior landfill. Subsequently, those materials were transported off-site for disposal. Since a portion of these materials from the smaller phragmites area had been shown to contain PCB concentrations at or above 50 parts per million (ppm), they were considered subject to the disposal requirements of EPA’s regulations under the Toxic Substances Control Act (TSCA), and thus were transported to an authorized TSCA disposal facility. Since the remaining materials from that area and the materials from the larger phragmites removal area had been shown to contain PCB concentrations less than 50 ppm, they were considered non-TSCA materials and were transported to an appropriate non-TSCA landfill.

The phragmites removal areas were not backfilled, except in three small portions. First, the northern portion of the larger phragmites area located adjacent to Dalton Avenue was backfilled with clean, imported topsoil to provide bank stabilization for the roadway embankment, and the surface was seeded with a Massachusetts Department of Transportation slope mix. Second, the portion of the smaller phragmites

The phragmites within the former interior landfill itself were addressed as part of the landfill cap installation activities. Those phragmites were treated prior to removal, the above-grade portions of those phragmites plants were removed, and the landfill cap was then installed over them, thus preventing light from promoting the growth of the subsurface plant material and thereby curtailing growth through the liner. The subsurface portions of these phragmites plants were not removed because that would have required excavation within the former landfill, which was not required under the CD and SOW.


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removal area through which the re-routed brook channel was directed, as shown on Figure 1, was backfilled with silty sand covered with a layer of stone riprap, as in the remainder of the re-routed brook. Third, the southernmost portion of the smaller phragmites area between the re-routed brook channel and the former interior landfill was backfilled with clean, imported topsoil and then seeded as part of the NRR/E planting of an herbaceous native grassland community on the western side of the re-routed brook channel, as shown on Figure 1 and described further below. In the remaining portions of the phragmites removal areas, no backfilling, planting, or seeding was performed, since Attachment I to the SOW provides that, following the phragmites removal activities, GE is to allow for re-development of the wetland community in these areas through natural succession.

Installation of Grassland Community on Surface of Vegetative Landfill Cap

As part of the required remediation, a two-foot-thick landfill cap was constructed over the unpaved (eastern) portion of the former interior landfill in accordance with requirements and specifications approved by EPA. The landfill cap area includes a relocated 30-inch sanitary sewer main under the cap and a gravel-covered access road on the surface of the cap. Following construction, the surface of the cap (excluding the access road) was seeded with a warm-season grass and wildflower mixture that differed somewhat from the example mixture given in the Revised Final Work Plan for Remainder Area (due, at least in part, to availability) and was approved by EPA via electronic mail on July 28, 2015. That mixture consisted of the following native warm-season grass and wildflower species: Virginia wild rye (Elymus virginicus), common milkweed (Asclepias syriaca), New England aster (Aster novae-angliae), golden alexanders (Zizia aurea), creeping red fescue (Festuca rubra), switch grass (Panicum virgatum), little bluestem (Schizachyrium scoparium), big bluestem (Andropogon gerardii), indian grass (Scorghastrum nutans), partridge pea (Chamaecrista fasciculate), deer tongue (Panicum clandestinum), ox eye sunflower (Heliopsis helianthoides), blue vervain (Verbana hastate), upland bentgrass (Agrostis perennans), flat topped/umbrella aster (Aster umbellatus), purple Joe Pye weed (Eupatorium purpureum), early goldenrod (Solidago juncea), and spotted Joe Pye weed (Eupatorium maculatum). This mixture is expected to develop into a native grassland community that can provide habitat for a variety of small mammals and birds without interfering with the integrity of the landfill cap. In addition, to ensure soil stability and prevent erosion, a nurse crop of annual rye-grass (Lolium temulentum) was added to the seed mixture. The grassland seed mixture was installed at an application rate of 30 pounds per acre, with an additional 10 pounds per acre of annual rye-grass to a maximum depth of ¼ inch. Subsequent to seeding, a paper mulch layer between ¼-and ½-inch thick was installed. The landfill cap area in which this grassland community was installed is shown on Figure 1.

Installation of Grassland Community West of Re-Routed Brook Channel

As part of the required remediation, an approximate 600-foot section of Unkamet Brook was re-routed around the eastern edge of the former interior landfill, as shown on Figure 1. Following the re-routing of the brook, the area between the eastern side of the landfill cap and the western side of the re-routed brook was restored with clean, imported topsoil and seeded with the same seed mixture described above. Again, to ensure soil stability and prevent erosion, a nurse crop of annual rye-grass was added to the seed mixture. The grassland seed mixture was installed at an application rate of 30 pounds per acre, with an



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additional 10 pounds per acre of annual rye-grass to a maximum depth of ¼ inch. Subsequent to seeding, a paper mulch layer between ¼- and ½-inch thick was installed. This area is also shown on Figure 1.3

As noted above, Attachment I to the SOW and the Revised Final Work Plan for Remainder Area also provided that GE would plant a similar herbaceous native grassland community (or other appropriate vegetation in inundated areas) in any areas east of the re-routed brook channel that are disturbed by the rerouting activities. However, the re-routing activities did not cause a disturbance of any such areas east of the re-routed channel, so no herbaceous planting was necessary there.

Installation of Bluebird Boxes

Following the re-routing of the brook channel and the installation of the vegetative landfill cap over the eastern side of the former interior landfill, four bluebird boxes were installed along the edge of the former interior landfill adjacent to the wetlands – i.e., between the eastern edge of the former interior landfill and the re-routed brook channel. The locations of these bluebird boxes are shown on Figure 1.

III. Monitoring and Maintenance of NRR/E Measures

The CD and SOW require monitoring and maintenance of the NRR/E measures installed at the Unkamet Brook Area. Specifically, Paragraph 119 of the CD requires the preparation of a Restoration Project Monitoring and Maintenance Plan for the NRR/E measures. The Performance Standards and other requirements for such monitoring and maintenance are set forth in Section 8 of Attachment I to the SOW. In satisfaction of those requirements (as well as the separate requirements for Post-Removal Site Control activities), GE submitted a Post-Removal Site Control Plan/Restoration Project Monitoring and Maintenance Plan (PRSCP/RPMMP) to EPA and the Trustees on August 19, 2016, and that plan was conditionally approved by EPA on September 6, 2016. That plan includes (in Section 3) a description of the monitoring and maintenance activities to be conducted for the NRR/E measures implemented at the Unkamet Brook Area.

This section of the present report provides a summary of those monitoring and maintenance activities. Following the Trustees’ approval of those activities (as set forth in the PRSCP/RPMMP and summarized herein), the specified requirements will govern the NRR/E monitoring and maintenance activities at this RAA until such time as they are superseded by the comparable requirements presented in the Final Completion Report (FCR) for the Unkamet Brook Area Removal Action. These activities will be conducted under the oversight of the Trustees. The approximate locations of the NRR/E areas subject to inspection

As stated in the Revised Final Work Plan for Remainder Area, GE had agreed that, as part of the non-NRR/E restoration activities, it would plant a variety of trees and shrubs along the eastern side of the re-routed brook channel. However, following remediation, GE and EPA agreed that, due to the lack of remediation-related impacts east of the re-routed brook channel, those trees and shrubs would be planted in the area west of the re-routed channel and east of the landfill cap – i.e., the same area where the herbaceous grassland community was installed as an NRR/E measure. Approximately 400 trees and shrubs were planted in that area. However, those trees and shrubs are not part of the NRR/E measures in this RAA; and in fact, under another agreement between GE and EPA, those trees and shrubs are not subject to subsequent monitoring and maintenance requirements except for those in a sub-area that has been determined to contain 98 trees and shrubs.


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are illustrated on Figure 1. As noted above, that figure provides the final delineation of the Restoration Area at the Unkamet Brook Area, as required by Paragraph 122 of the CD.

Periodic Inspections

Consistent with Attachment I to the SOW, the phragmites removal areas shown on Figure 1 will be inspected initially in the summer of 2016 and will thereafter be inspected twice a year (in May or June and July or August) for the next three years after completion of the removals (i.e., in 2017, 2018, and 2019), and once per year (in July or August) in each of the fifth year (2021) and the seventh year (2023) after such completion. These inspections will consist of visual observations to determine whether phragmites have returned to these areas. If phragmites have returned to cover greater than 5% of either removal area, the phragmites will be treated with herbicide.

The native herbaceous vegetation planted as part of the NRR/E measures on top of the vegetative landfill cap at the former interior landfill and between the eastern side of that cap and the western side of the rerouted brook will be periodically inspected at the frequencies specified in Attachment I to the SOW. Specifically, the monitoring program for this vegetation will be initiated in the summer of 2016, and will thereafter consist of two visits during each of the next three years after planting (i.e., 2017, 2018, and 2019), one visit during the fifth year after planting (2021), and one visit during the seventh year after planting (2023). In each of the years with semi-annual monitoring, visits will be conducted in the late spring after the first leaf flush (May or June) and in the summer (July or August) to assess survival of the herbaceous vegetation. The single visit in the fifth year and seventh year after planting will be conducted in the summer (July or August).

Each monitoring event for the herbaceous grassland vegetation will consist of a field inspection and meander survey of the herbaceous planting areas described above and shown on Figure 1. Estimates of groundcover by herbaceous species will be made to verify areal coverage. Any areas of bare/sparse vegetation or indications of damage from trespassing or herbivory will be noted, and the apparent vigor of the herbaceous vegetation will be assessed. The herbaceous planting areas will also be inspected for the presence of invasive species. Invasive species of concern will consist of those listed in Table 1 and any other plant species listed by the Massachusetts Invasive Plant Advisory Group (MIPAG) as “invasive,” “likely invasive,” or “potentially invasive.” GE will ensure that no greater than 5% of either of the two NRR/E herbaceous planting areas identified above is covered with invasive species. In addition, any volunteer trees or shrubs that are observed within a 10-foot strip adjacent to the northern and eastern boundaries of the vegetative landfill cap will be identified for removal.4

Observations will also be made of the banks of the re-routed brook that are above water for the presence and estimated coverage of these invasive species. GE will ensure that no greater than 5% of the area encompassed by those banks is covered with invasive species.

Finally, GE will inspect the bluebird boxes installed along the edges of the former interior landfill adjacent to the wetlands (as shown on Figure 1) on an annual basis (in July or August) for three years after installation

4 Any volunteer trees and shrubs growing within or along the edges of the vegetative cap itself will be identified for removal during the non-NRR/E inspections of the vegetative landfill cap, as described in GE’s PRSCP/RPMMP,



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(i.e., in 2017, 2018, and 2019) to verify visually that those boxes have not been damaged, remain in good working condition, and remain in the correct locations.

Maintenance, Repair, and Replanting Activities

Based on the results of the NRR/E inspection activities described above, maintenance and repair activities will be performed as necessary.

In the phragmites removal areas, as noted above, if phragmites are found to have returned to cover greater than 5% of either removal area, the phragmites will be treated with herbicide.

Any herbaceous planting area within the NRR/E areas with less than 100% cover will be evaluated with Trustee input; and supplemental activities, such as additional seeding, fertilizing, watering, and/or measures to reduce herbivory, will be implemented as needed. In the event that a significant loss of herbaceous groundcover (greater than ¼ acre) is observed in a given area and such loss is not attributable solely to the actions of a third party, GE will reseed that area, and the time for monitoring of that area will be restarted following the reseeding activities. Where necessary, reseeding will be conducted using the same approved grassland species seed mixture that was originally used in the area, to the extent that the same species are available (unless the Trustees direct or approve use of a different mixture). GE will also ensure that no greater than 5% of either of the restored herbaceous planting areas or of the area encompassed by the banks of the re-routed brook that are above water is covered with invasive species. In the event that this criterion is exceeded, the invasive species will be treated or removed as appropriate.

In addition, to prevent tree and shrub growth within the vegetative portions of the landfill cap over the former interior landfill, GE will, on an annual basis in October, mow the grass in that area, as well as in the 10-foot strip adjacent to the northern and eastern boundaries of the landfill cap (to the extent practicable given access, moisture conditions, and any obstructions), and will remove any trees and/or shrubs observed within those areas (if not removed as part of the non-NRR/E maintenance activities).5

Finally, if any damage to a bluebird box is noted and that damage is sufficient to render the box uninhabitable by bluebirds, the box will be replaced.

In the event that coverage by phragmites or other invasive species is determined during an inspection to exceed the 5% action threshold in any evaluation area, thus requiring treatment or other response action, GE will so notify the Lead Administrative Trustee (LAT) by e-mail, with a copy to EPA, within 30 days after completion of the inspection; and the identified treatment/control actions will be conducted within the same growing season as the inspection, prior to the first killing frost of that season, unless otherwise approved by EPA or the Trustees. Other proposed corrective measures identified during the performance of the periodic inspections (or otherwise identified by GE) will be subject to approval by the Trustees. Following such approval, any such corrective actions to address identified deficiencies will be conducted

5 Mowing will not be conducted in the remainder of the grassland area on the western side of the re-routed Unkamet Brook channel where trees and shrubs have also been planted, so as to assist in promoting the natural growth of those trees and shrubs.


Ms. Karen Pelto September 8, 20 I 6

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within 90 days of the inspection date or 30 days of the Trustees' approval (whichever is later), unless otherwise agreed to by the Trustees.

Reporting

GE will prepare and submit to the Trustees an event-specific report on each inspection, summarizing the

results of the inspection and any maintenance activities performed or identified. The report will be prepared

using field notes and other infonnation collected during the monitoring visit, and will include copies of applicable figures and a completed version of the inspection checklist provided as Appendix A . The report

will also present photographic documentation of the conditions of the inspected NRR/E measures, and it

will document any maintenance or repair activities performed since submittal of the previous inspection report. It will include a description of the invasive species control activities performed since the prior report, including the dates of treatment, the species control led, and the controls used.

Each report will be submitted to the Trustees (through the LAT), with copies to EPA and the Massachusetts

Department of Environmental Protection (MDEP) Western Region, no later than 90 days following the

inspection, although an effort will be made to submit the report within a shorter time frame. Any maintenance, repair, or reseeding activity proposed in that report and subsequently performed will be documented in the next inspection report.

IV. Final Restoration Installation Inspection

Paragraph 120 of the CD provides that, after GE submits the Completion of Installation of Restoration

Work Report, GE will schedule an installation inspection and meeting, to be attended by GE, EPA, and the Trustees and to be followed by the Trustees' determination of whether the installation of the restoration

work has been completed in accordance with the applicable requirements and Performance Standards of

the CD. I will contact you to arrange a time for that inspection and meeting at the portion of the Unkamet Brook Area north ofMerril 1 Road. In the meantime, please call me at ( 413) 448-5909 ifyou have questions or comments concerning this report.

Sincerely yours,

rn U.G,c~Cff Richard W. Gates

GE Project Coordinator for Unkamet Brook Area

Attachments

cc: Dean Tagliaferro, EPA

Dave Dickerson, EPA

John Kilborn, EPA (letter only) Christopher Ferry, ASRC Primus (CD)

Scott Campbell, Avatar (2 hard copies + CD)

G: GE GE f>imlidd CO l,nJ..amcl DrooJ.. _Area Repons and Prcsentatioos Comple11on of ln:>ta!lation ofRe~1or.:nioo \\'orl....2781611122_rpt.doc,


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John Ziegler, MassDEP (hard copy of letter + CD) Michael Gorski, MassDEP (hard copy of letter + CD) Eva Tor, MassDEP (letter by e-mail) Robert Leitch, USACE (CD) Nancy E. Harper, MA AG (letter only) Nate Joyner, Pittsfield Dept. of Community Development (CD) Steve Karvasy, GE-CSSO (hard copy + CD) Erin Cullen, GE Corporate Properties & Services (CD) Andrew Silfer, GE (letter only) Rod McLaren, GE (letter only) Matthew Calacone, GE (CD) James Bieke, Sidley Austin James Nuss, ARCADIS Corey Averill, ARCADIS Public Information Repositories GE Internal Repository


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GENERAL ELECTRIC COMPANY PITTSFIELD, MASSACHUSETTS

UNKAMET BROOK AREA COMPLETION OF INSTALLATION OF RESTORATION WORK REPORT

FIGURE

COMPLETED NRR/E MEASURES

1

Appendix A

Inspection Checklist for Natural Resource Restoration/Enhancement Measures

APPENDIX AINSPECTION CHECKLIST FOR NATURAL RESOURCE RESTORATION/ENHANCEMENT MEASURES

UNKAMET BROOK AREA

I. GENERAL INFORMATION

Inspection Date:

Conducted By/Phone Number:

Other Individuals Present (and Affiliation):

Weather Conditions:Date of Last Inspection:

Check here to confirm that Figure 6 and Table 1 of the Post-Removal Site Control Plan/Restoration Project Monitoring and Maintenance Plan for Unkamet Brook Area (PRCSP/RPMMP; August 2016) have been reviewed.

II. INSPECTION SUMMARY

1. Herbaceous Native Grassland Communities A. Estimated Groundcover (For the native herbaceous vegetation planted on top of the vegetative landfill cap at the former interior landfill and

planted between the eastern side of that cap and the western side of the re-routed brook, note for each of those areas: the percentage of groundcover by herbaceous species; any areas with bare/sparse vegetation; any evidence of damage from trespassing or herbivory; and the apparent vigor of the herbaceous vegetation. Also, note that any trees or shrubs growing within the a 10-foot strip adjacent to the northern and eastern boundaries of the vegetative landfill cap.)

B. Presence of Invasive Species (For each of the above-referenced areas planted with herbaceous vegetation, and for the banks of the re-routed portion of Unkamet Brook that are above water, note the presence of any of the invasive plant species listed in Table 1 of the PRSCP/RPMMP or any other plant species listed by the Massachusetts Invasive Plant Advisory Group as “invasive,” “likely invasive,” or “potentially invasive”; note the specific species observed and the general location(s) of the invasive species; and note the percentage of each such area occupied by invasive species.)

2. Phragmites Removal Areas (Note whether phragmites have returned to these areas since the last inspection [or, for the first inspection, since completion of restoration of these areas]; if so, note the percentage of each phragmites removal area occupied by phragmites.)

3. Bluebird Boxes (For the first three years after installation (2017, 2018, 2019), note any evidence of damage to the bluebird boxes since the last inspection [or, for the first inspection, since installation] and the extent of any damage, and verify that the boxes remain in the locations in which they were installed.)

4. Other Observations (Confirm that repair, maintenance, and/or replanting/reseeding activities identified during the prior inspection have been performed; note any other general observations.)

III. FOLLOW-UP MAINTENANCE AND REPAIR ACTIVITIES

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Global Operations,Environment,Health &Safety · Ms. Karen Pelto September 8, 2016 Page 2 of 9 . of a minimum of two feet depending on the nature and quality of soil) to minimize the