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Consent Decree Exhibit C 5.4 JUSTIFICATION OF PROPOSED CLEANUP ACTION FOR SURFACE WAT ER 5.4.1 Permanent Solutions to the Maximum Extent Practicable The surface water alternatives are dentical except for the addition of a SWPPP under the proposed cleanup action for surface water. Neither alternative proposes a new cleanup action beyond those already completed under previous interim and independent cleanup actions. Both alternatives are intended to maintain the integrity and effectiveness of the earlier corrective actions through monitoring, inspection and maintenance. Both alternatives take actions to determine the source of existing contamination and implement plans to address source control. Both alternatives provide overall protectiveness of human health and the environment. Both alternatives have long-term effectiveness. They include standard procedures implemented routinely in surface water management and landfill post -closure inspection and maintenance. The proposed cleanup action for surface water would be slightly more effective in the long-term since the inclusion of a SWPPP provides a management tool that would likely lead to more effective implementation and documentation. Each alternative is effective in the short-term in that they can be implemented immediately, require no new construction and create no new short-term risks. The proposed cleanup action for surface water would take slightly longer to implement completely due to the preparation of a SWPPP. Permanent reduction in the mobility and release of hazardous substances has been achieved through earlier interim and independent actions. The proposed cleanup action for surface water is slightly more effective since the SWPPP will assist in the reliable and continuous implementation of the cleanup actions. Both alternatives can be implemented readily. They use routine and accepted practices that are commonly applied in similar situations. Both alternatives have similar operations and maintenance costs that are appropriate to the incremental degree of protection achieved. Community concerns are unknown at this time. After public review and comment any concerns will be addressed. The proposed cleanup action for surface water thus meets all the criteria to be considered "permanent to the maximum extent practicable". The alternative that includes a SWPPP is selected because it provides an added benefit as a management tool with minimal additional cost. 5.4.2 Provide for a reasonable restoration time frame Cleanup has already occurred for this pathway under previous interim and independent cleanup actions including preventing leachate intrusion to East Ditch, cleaning up and preventing future leachate seeps, covering and grading the landfill surface, and removing contaminated sediment from the East Ditch. The inspection, maintenance and monitoring requirements of the proposed cleanup action for surface water will be implemented promptly upon approval. FINAL - March 2001 5-4 Everett Landfill Tire Fire Site Cleanup Action Plan 1 1 1 1 1 1 1 1 1 1 1 1 I 17 1 1 1