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Consent Decree Exhibit C 7.6 JUSTIFICATION OF PROPOSED CLEANUP ACTION FOR DIRECT CONTACT 7.6.1 Permanent Solutions to the Maximum Extent Practicable Developed area covers, construction requirements and access controls isolate Site users, the surrounding community, and environmental receptors from direct contact with refuse materials. These measures ensure that construction workers coming in contact with exposed refuse will be appropriately health and safety trained. In this manner, the proposed cleanup action for direct contact meets the cleanup standards and is protective of human health and the environment. This cleanup action provides long-term effectiveness through reliance on institutional controls, compliance monitoring and maintenance of landfill cover. In a landfill setting, reliance on institutional controls for long-term effectiveness is an acceptable and proven alternative. The proposed cleanup action for direct contact includes construction requirements and institutional controls to control short-term risks from construction and maintenance activities. Construction requirements include construction performance monitoring in addition to physical requirements to ensure that performance standards are met. The proposed cleanup action for direct contact does not provide a permanent reduction in the toxicity, mobility or volume of the landfilled refuse. Isolation of landfilled refuse from environmental exposure pathways is a proven and acceptable alternative for municipal landfill facilities. Through developed area cover requirements and institutional controls, the proposed cleanup action for direct contact will increase the certainty of isolation of the refuse from uncontrolled direct contact. The proposed cleanup action for direct contact can be easily implemented during Site development activities. On -site disposal of refuse excavated during development is expected to be minimal. The same cover and grading requirements will apply to relocated refuse, thus isolating relocated refuse from environmental exposure pathways. The costs to implement this alternative will be contained within the development costs for the Site. These costs are not expected to make development of the Site impracticable. Costs for on -site disposal of excavated refuse are estimated to be $35/ton less expensive than for the other alternative that prohibits on -site relocation of excavated refuse. However, it is not possible at this time to estimate whether refuse will be excavated for development or what potential volume of excavated refuse may be included in development plans. Through institutional controls, construction requirements, construction performance monitoring and public access controls, the proposed cleanup action will address most anticipated public concerns regarding direct contact with, or exposure to landfilled materials. Because the proposed cleanup action for direct contact is not expected to cause the traffic and transportation impacts, nor create the potential risk of off -site contamination, that off -site disposal of excavated refuse would cause, the public may have fewer concerns with on -site relocation of excavated refuse. FINAL - March 2001 7-6 Everett Landfill Tire Fire Site Cleanup Action Plan 1