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1 <br />1 <br />1 <br />Consent Decree Exhibit C <br />The proposed cleanup action for the direct contact pathway thus meets all the criteria to be <br />considered "permanent to the maximum extent practicable". <br />The alternative requiring off -site disposal of excavated refuse was rejected because off -site <br />disposal of excavated refuse would not significantly reduce the volume of contained refuse at <br />the Everett Landfill/Tire Fire Site, as the volume of refuse excavated during development is <br />expected to be minimal. The toxicity or volume of the refuse excavated for development would <br />not be reduced through off -site disposal, it would simply be transferred to another landfill setting. <br />Additionally, off -site disposal of excavated refuse would cause traffic and transportation impacts, <br />as well as potential risk of off -site contamination. Public concerns may be raised about the <br />environmental effectiveness of transporting waste from one landfill setting to another at <br />increased cost and increased community impact, without achieving increased environmental <br />protection at the Everett Landfill/Tire Fire Site. <br />The alternative "Excavate and Remove Landfilled Materials" was rejected. Because this <br />alternative was evaluated for multiple pathways, please see Section 7.9 for justification. <br />7.6.2 Provide for a reasonable restoration time frame <br />The proposed cleanup action for direct contact pathway protection would be implemented as <br />development occurs, associated with a reasonable restoration time frame. <br />7.6.3 Consider Public Concerns Raised during Public Comment on the Draft Cleanup <br />Action Plan <br />While the public has not yet had an opportunity to comment on a draft cleanup action plan, <br />anticipated public concerns regarding the alternatives include traffic and transportation impacts, <br />potential risk of contamination of areas off -site, and potential risks to nearby water ways. The <br />proposed cleanup action avoids these risks by allowing excavated refuse to be relocated within <br />the Everett Landfill/Tire Fire Site. The other direct contact alternatives would likely raise some <br />public concerns; however, public concerns are unknown at this time and evaluation of the <br />alternatives against this criterion can be done after such comments are received during the <br />comment period for the CAP. <br />7.7 CLEANUP ACTION ALTERNATIVES FOR SURFACE WATER <br />In addition to the proposed cleanup action for surface water, which includes construction <br />practices and stormwater management requirements, an additional alternative, excavate and <br />remove landfilled materials, was evaluated. <br />7.8 JUSTIFICATION OF PROPOSED CLEANUP ACTION FOR SURFACE WATER <br />7.8.1 Permanent Solutions to the Maximum Extent Practicable <br />The proposed cleanup action for surface water ensures continued overall protectiveness of <br />human health and the environment under developed conditions. Construction practices isolate <br />surface water from refuse. Any surface water contacting temporarily exposed landfilled <br />FINAL - March 2001 7-7 Everett Landfill Tire Fire Site <br />Cleanup Action Plan <br />1� I <br />