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1 Consent Decree Exhibit C materials during construction is contained on -site or directed to the leachate collection system. Development surfaces, such as pavement and landscaping, will meet or exceed the performance of the existing two -foot minimum soil cover in preventing surface water contact with refuse. The stormwater management requirements ensure future development does not create new conditions that could cause exceedance of cleanup standards. The proposed cleanup action for surface water is effective long-term. Its requirements are practical and employ standard practices for controlling environmental impacts to surface water from development. It provides extra precautions suitable to development on a landfill. The inspection, maintenance, and compliance monitoring requirements ensure long-term reliability. Contingency plans are available if monitoring indicates cleanup levels are being exceeded. Short-term effectiveness is also achieved by the proposed cleanup action for surface water. Cleanup standards have already been met by sources from on -site. Potential off -site sources contributing to cleanup level exceedances would be identified and appropriate responses initiated. Construction practices ensure surface water cleanup levels are not exceeded as a result of future development construction. The proposed cleanup action for surface water does not permanently remove the source of potential contamination (landfilled materials). But it does permanently isolate landfilled materials from contact with surface water through the use of existing and future development covers and lined or piped stormwater drainage ways. It also provides for inspection, maintenance, compliance monitoring, and contingency plans to ensure the controls remain effective over time. The proposed cleanup action for surface water is readily implemented. It applies standard surface water management practices that are well understood and included routinely with development. Additionally, the surface water controls typically associated with landfills and commonly practiced are applied. The proposed cleanup action for surface water is not substantial and disproportionate to the incremental increase in protection provided. There are no known community concerns the proposed cleanup action does not meet. The alternative "Excavate and Remove Landfilled Materials" was rejected. Because this alternative was evaluated for multiple pathways, please see Section 7.9 for justification. 7.8.2 Provide for a reasonable restoration time frame The proposed cleanup action for surface water can be implemented immediately upon approval and thus meets the reasonable restoration time frame criteria. 7.8.3 Consider Public Concerns Raised during Public Comment on the Draft Cleanup Action Plan Public concerns are unknown at this time. The public has not had an opportunity to comment on the draft cleanup action plan as of this date. Evaluation of the alternatives against this criterion can be done after such comments are received. FINAL - March 2001 7-8 Everett Landfill Tire Fire Site Cleanup Action Plan 1 1 1 1 1 L 17 u 1 1 1 1 U r 1 1 L�