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1 Consent Decree Exhibit C Site conditions, surface materials that could be available for direct contact to Site users must meet direct contact cleanup levels. 3.3.3 Nature and Extent of Contamination The Everett Landfill/Tire Fire Site does have buried refuse, tire ash, and potentially contaminated sediments that could be hazardous if directly contacted. These materials must be isolated from direct contact with Site users who are not trained in health and safety requirements for contaminated material. The interim and independent cleanup actions, completed in 1995 and 1998, buried the tire ash, debris and sediments/spoils from the East Ditch, and refuse material under a minimum two -foot cap of clean soil. This soil cap is vegetated with grass and maintained by the City. This remedy prevents direct contact with buried refuse, East Ditch spoils and tire ash, and facilitates the prevention of erosion. Additionally, in order to prevent unauthorized access, a secured fence has been installed around the unused portions of the Site to prevent penetration of the site cover by untrained personnel. 3.4 SURFACE WATER EXPOSURE PATHWAY The surface water pathway also describes conditions relative to sediment in drainage ditches. 3.4.1 Surface Water ARARs Potential ARARs for the Everett Landfill/Tire Fire Site are described in an attachment CAP-1. ARARs specific to the surface water exposure pathway are listed below. • Water Quality Standards for the Surface Waters of the State of Washington, Section 90.48 RCW; Section 173-201 A WAC • Federally Promulgated Water Standards, 40 CFR 131 • Clean Water Act, NPDES Permit Program, 33 USC 1251; 40 CFR 123; Section 90.48 RCW; Section 173-220 WAC • City of Everett Drainage Ordinance 3.4.2 Cleanup Standards The groundwater cleanup levels described in Section 3.2.2 are applicable to surface water as well. The Snohomish River is the receiving water body for surface water runoff from the Everett Landfill/Tire Fire Site. MTCA Method A cleanup levels for residential soils [WAC 173-340-740(2)(a)] are cleanup standards for sediment in the perimeter ditches. These ditches are accessible beyond the landfill boundary fence. Sediments in the ditch are evaluated based on a direct contact pathway risk. The principal receiving water body is the Snohomish River. The point of compliance for surface water is where the drainage discharge from the landfill discharges into the outlet to the Snohomish River. The compliance point, surface water drainage features and previous sampling locations are shown on Figure 3-3. FINAL - March 2001 3-6 Everett Landfill Tire Fire Site Cleanup Action Plan 1 1 1 11 1 1 1 1 1 1 1 1 �Ll [1 1 1 1 1