NOTE: The following Maintenance Plan template has been slightly revised to follow the structure for Maintenance Plan Attachment D found in Form 4400-202, Case Closure – GIS Registry. References to the closure form are in italics, and are just reminders. (April, 2014) This maintenance plan example template may be used to begin developing an actual plan at straightforward sites that have only certain post-closure features. It is best suited for sites where the items requiring maintenance are on one property.
Sites that are more complex or contain different features should not use this template. Additional guidance on the content of Operation and Maintenance Plans can be found in Guidance for Cover Systems as Soil Performance Standard Remedies (RR 709). Please refer to publication RR-981 (Appendix 5 of RR-606), for guidelines related to developing a maintenance plan for vapor barriers and systems related to the vapor intrusion pathway.
This example template can be used to begin developing an actual maintenance plan at a simple site that:
Can be closed with contaminated soil remaining that contains contaminants exceeding NR 720 RCLs and the soil presents a direct contact and/or migration to groundwater pathway threat;
Uses a soil performance standard cover or barrier to address the direct contact and/or migration to groundwater pathway(s);
Uses a cover or barrier that is pavement and/or a building(s); and
Can be closed with natural attenuation addressing the groundwater pathway where contaminated soil remains that can leach contaminants into groundwater. Often a cover or barrier is a necessary part of the overall remedial approach to assure natural attenuation continues successfully after closure, because it provides some level of infiltration reduction that should not be changed. These maintenance plans should be developed to assure that occurs after closure is granted.
Has one or more monitoring wells which will be kept after closure, for continued monitoring (by either the RP, property owner, or by another RP). Under s. NR 716.13 (14), Wis. Adm. Code, inspections are required annually, to verify the competency of the well labels, lock and seal, and to evaluate whether the well is providing a conduit for contamination to the subsurface. (See page 6).
In some cases, DNR may request the signature of the property owner, to acknowledge the responsibility for maintenance of a remedy. This is generally limited to the situation where someone other than the responsible party is maintaining a cap or engineered control.
For some helpful hints about maintenance plan preparation see the DNR publication called Improve Your Closure Request: Maintenance Plans and Maps (RR-983).
This document contains information about certain state statutes and administrative rules but does not necessarily include all of the details found in the statutes and rules. Readers should consult the actual language of the statutes and rules to answer specific questions.
The Wisconsin Department of Natural Resources provides equal opportunity in its employment, programs, services, and functions under an Affirmative Action Plan. If you have any questions, please write to Equal Opportunity Office, Department of Interior, Washington, D.C. 20240.
This publication is available in alternative format upon request. Please call 608-267-3543 for more information.
COVER or BARRIER MAINTENANCE PLAN
(to be included in Form 4400-202, as Attachment D) [ DATE]
Property Located at:
[DNR BRRTS/Activity #], FID # (if known)
[LEGAL DESCRIPTION] [TAX /Parcel Identification Number)
This document is the Maintenance Plan for a insert type of cover/barrier/system at the above-referenced property in accordance with the requirements of s. NR 724.13 (2), Wis. Adm. Code. The maintenance activities relate to the existing insert type of cover/barrier/system which addresses or occupies the area over the contaminated groundwater plume or soil.
More site-specific information about this property/site may be found in:
The case file in the DNR Region office
At http://dnr.wi.gov/topic/Brownfields/wrrd.html, which includes:
BRRTS on the Web (DNR’s internet based data base of contaminated sites)for the link to a PDF for site-specific information at the time of closure and on continuing obligations;
RR Sites Map for a map view of the site, and
The DNR project manager for insert name of county County.
(Form 4400-202, Attachment D, Part D1. – brief description of the type, depth and location of residual contamination, description of the system/cover/barrier to be maintained, and its location on the site, maintenance activities, and contact information.) Description of Contamination Soil contaminated by describe the type of contaminants, e.g., petroleum, metals, chlorinateds, etc.[ is located at a depth of ____ feet at describe location, including locations beyond the source property. Groundwater contaminated by describe the type of contaminants is located at a depth of insert depth of contamination. The extent of the soil [and groundwater] contamination is shown on the attached [map(s)] [drawings(s)] label multiple attachments as afigures or maps 1, 2, 3, etc..
Description of the [Cover/Barrier] to be Maintained The [Cover/Barrier/Cap] consists of describe materials, thicknesses of layers. It is located describe location, including on any properties other than the source property as shown on the attached [map(s)] [drawings(s)] label multiple attachments as figures or maps 1, 2, 3, etc.
[For engineered features: A copy of the engineering specifications for the cover system, or describe the feature is attached.]
Cover/Building/Slab/Barrier Purpose The insert type of cover/barrier/building over the contaminated [groundwater plume] [or soil] serve as a barrier to prevent direct human contact with residual soil contamination that might otherwise pose a threat to human health. Use the following sentence if applicable. The cover/barrier also acts as a partial infiltration barrier to minimize future soil-to-groundwater contamination migration that would violate the groundwater standards in ch. NR 140, Wisconsin Administrative Code. Based on the current use of the property, insert current use (e.g. commercial, industrial), the barrier should function as intended unless disturbed.
Annual Inspection The insert type of cover/barrier overlying the [contaminated groundwater plume] [or soil] and as depicted in [Figure insert figure number] will be inspected once a year, normally in the spring after all snow and ice is gone, for deterioration, cracks and other potential problems that can cause [additional infiltration into] [or exposure to] underlying soils. The inspections will be performed by the property owner or their designated representative. The inspections will be performed to evaluate damage due to settling, exposure to the weather, wear from traffic, increasing age and other factors. Any area where soils have become or are likely to become exposed [[and] where infiltration from the surface will not be effectively minimized] will be documented.
A log of the inspections and any repairs will be maintained by the property owner and is included as D.4, Form 4400-305, Continuing Obligations Inspection and Maintenance Log. The log will include recommendations for necessary repair of any areas where underlying soils are exposed and where infiltration from the surface will not be effectively minimized. Once repairs are completed, they will be documented in the inspection log. A copy of the maintenance plan and inspection log will be kept at the site; or, if there is no acceptable place (for example, no building is present) to keep it at the site, at the address of the property owner and available for submittal or inspection by Wisconsin Department of Natural Resources (DNR) representatives upon their request.
[Note: The DNR may, in some instances, require in the case closure letter that the inspection log be submitted at least annually after every inspection. If the case closure letter requires that, then add the following sentence to the paragraph above: A copy of the inspection log must be submitted electronically to the DNR after every inspection, at least annually.]
(Form 4400-202, Attachment D, Part D1. – Description of Maintenance Actions required for maximizing effectiveness of the cover/barrier/engineered control, feature or other action for which maintenance is required.) If problems are noted during the annual inspections or at any other time during the year, repairs will be scheduled as soon as practical. Repairs can include patching and filling or larger resurfacing or construction operations. In the event that necessary maintenance activities expose the underlying soil, the owner must inform maintenance workers of the direct contact exposure hazard and provide them with appropriate personal protection equipment (PPE). The owner must also sample any soil that is excavated from the site prior to disposal to ascertain if contamination remains. The soil must be treated, stored and disposed of by the owner in accordance with applicable local, state and federal law.
In the event the insert type of cover/barrier overlying the [contaminated groundwater plume] [or soil] are removed or replaced, the replacement barrier must be equally impervious. Any replacement barrier will be subject to the same maintenance and inspection guidelines as outlined in this Maintenance Plan unless indicated otherwise by the DNR or its successor.
The property owner, in order to maintain the integrity of the insert type of cover/barrier [insert type of cover/cap], will maintain a copy of this Maintenance Plan at the site; or, if there is no acceptable place to keep it at the site (for example, no building is present), at the address of the property owner and make it available to all interested parties (i.e. on-site employees, contractors, future property owners, etc.) for viewing.
Prohibition of Activities and Notification of DNR Prior to Actions Affecting a Cover/Barrier The following activities are prohibited on any portion of the property where [pavement, a building foundation, soil cover, engineered cap or other barrier] is required as shown on the attached map, unless prior written approval has been obtained from the Wisconsin Department of Natural Resources: 1) removal of the existing barrier; 2) replacement with another barrier; 3) excavating or grading of the land surface; 4) filling on capped or paved areas; 5) plowing for agricultural cultivation; 6) construction or placement of a building or other structure; 7) use the following if the use of the property is commercial or industrial (non-residential) changing the use or occupancy of the property to a residential exposure setting, which may include certain uses, such as single or multiple family residences, a school, day care, senior center, hospital, or similar residential exposure settings; 8)use the following if the use of the property is a residential-type setting OTHER THAN single-family residential changing the use or occupancy of the property to single-family residential use; or 9)use the following if a vapor mitigation system is in use changing the construction of a building that has a vapor mitigation system in place.
If removal, replacement or other changes to a cover, or a building which is acting as a cover, are considered, the property owner will contact DNR at least 45 days before taking such an action, to determine whether further action may be necessary to protect human health, safety, or welfare or the environment, in accordance with s. NR 727.07, Wis. Adm. Code.
Amendment or Withdrawal of Maintenance Plan This Maintenance Plan can be amended or withdrawn by the property owner and its successors with the written approval of DNR.
(Form 4400-202, Attachment D, Part 1.) Contact Information, including the name, address and phone number of the individual or facility who will be conducting the maintenance.) [MONTH & YEAR]
Site Owner and Operator: [NAME]
(DNR may request signature of affected property owners, on a case-by-case basis)
Property Owner: [NAME]
(2) the location of the feature(s) that require(s) maintenance: on and off the source property;
(3) the extent of the structure or feature(s) to be maintained, in relation to other structures or features on the site;
(4) the extent and type of residual contamination; and
(5) all property boundaries. D. 3 Photographs of Cover/Barrier
Include one or more photographs documenting the condition and extent of the cover/barrier/building/slab at the time of the closure request. Pertinent features must be visible and discernible. Include a title on each photograph, which identifies the site name and location of the feature, and the date on which the photograph was taken. D.4Continuing Obligations Inspection and Maintenance Log Use DNR Fillable Form Form 4400-305
Monitoring Well Maintenance Plan Template D.1. Descriptions and Contact Information: (Form 4400-202, Attachment D, Part 1.)
Provide a description of which wells were kept/required for continued monitoring.
Provide a description of the well lock, well seal type/materials and condition at the time of closure. Reference the sampling plan.
Describe the maintenance activities which will be conducted.
Inspections are to be conducted on a yearly basis. Inspections are recommended in spring after snow and ice are gone. In accordance with s. NR 716.13 (14), Wis. Adm. Code, verify the integrity of the well labels, lock and seal. Determine whether the wells are providing a conduit to the subsurface.
Describe the actions to be taken if the well label is missing, the well lock is broken, or the well seal is no longer sealing the annular space from surface contamination.
Describe in which situations the well should be abandoned in accordance with s. NR 141, Wis. Adm. Code.
Identify where the maintenance plan and inspection report will be located.
Provide a location map showing the well location in relation to the property boundaries, buildings, etc. (The site location map from the Site Investigation Report should suffice.) Wells locations are required to be surveyed in accordance with s. NR 141.065 (2), Wis. Adm. Code.
D.3. Photograph of Monitoring Well:
Include one or more photographs documenting the condition and extent of the well lock and seal the time of the closure request. Pertinent features must be visible and discernible.
Include a title on each photograph, which identifies the site name and location of the feature, and the date on which the photograph was taken.
D.4. Continuing Obligations Inspection and Maintenance Log