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1 <br />Consent Decree Exhibit C <br />5.0 Existing Conditions: Cleanup Action Alternatives <br />I <br />and Justification <br />1 <br />The following sections summarize the alternative cleanup actions for existing conditions that <br />were considered in the BFS, and describe the justification under MTCA for selecting the <br />proposed cleanup action described in Chapter 4.0. <br />For the groundwater and direct contact pathways, previously completed interim and <br />independent actions have met requirements for protection of human health and the environment <br />under existing conditions. The Interim Actions were previously approved by Ecology under the <br />1994 Enforcement Order. The proposed cleanup action, described in Chapter 4.0, consists of <br />maintaining conditions created by the interim and independent actions and instituting long-term <br />monitoring. For the groundwater pathway, continued operation and maintenance of the <br />leachate collection system is required, as well as long-term monitoring. The proposed cleanup <br />action for the direct contact pathway includes maintaining the minimum two -foot cover of clean <br />soil, positive drainage, and access controls to undeveloped portions of the Site. The remedies <br />for groundwater and direct contact under existing conditions are in place and need no <br />evaluation. No alternatives were considered. <br />Proposed cleanup actions for the gas and surface water pathways were selected from a list of <br />alternatives and evaluated according to MTCA [WAC 173-340-360(2) and (3)]. <br />WAC 173-340-360(2) specifies four threshold criteria that any cleanup action must satisfy. The <br />threshold criteria are: 1) protect human health and the environment, 2) comply with cleanup <br />standards, 3) comply with applicable state and federal laws, and 4) provide for compliance <br />monitoring. All evaluated alternatives for all pathways, whether for existing conditions or for <br />future conditions, meet the threshold criteria. <br />WAC 173-340-360(3) specifies three other criteria that any alternative meeting the threshold <br />requirements must also achieve. They are 1) use permanent solutions to the maximum extent <br />practicable, 2) provide for a reasonable restoration time frame, and 3) consider public concerns <br />raised during public comment on the draft cleanup action plan. <br />Ecology also recognizes that permanent solutions may not be practicable for all sites. A <br />determination that a cleanup action satisfies the requirement to use permanent solutions to the <br />maximum extent practicable is based upon consideration of a number of factors. The following <br />criteria are used to determine whether a cleanup action is "permanent to the maximum extent <br />practicable". [WAC 173-340-360(5)(d)]. <br />1. Overall protectiveness of human health and the environment <br />2. Long-term effectiveness <br />3. Short-term effectiveness <br />4. Permanent reduction of toxicity, mobility and volume of the hazardous substance <br />5. Ability to be implemented <br />6. Cleanup costs <br />7. The degree to which community concerns are addressed <br />FINAL - March 2001 5-1 Everett Landfill Tire Fire Site <br />Cleanup Action Plan <br />1 <br />