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1 <br />Consent Decree Exhibit C <br />1 <br />1 <br />1 <br />L� <br />1 <br />1 <br />1 <br />1 <br />1 <br />1 <br />1 <br />1 <br />1 <br />1 <br />1 <br />1 <br />EXCAVATE AND REMOVE LANDFILLED MATERIALS ALTERNATIVE <br />This alternative was evaluated in each of the four pathways. For the gas pathway, it was an <br />alternative to remedy existing conditions. For the remaining pathways, the alternative was <br />considered for future conditions. In all evaluations, the "Excavate and Remove Landfilled <br />Materials" alternative was rejected for the following reasons: <br />• The toxicity or volume of the excavated refuse would not be reduced through <br />removal; it would simply be transferred to another landfill setting. Isolation of <br />landfilled refuse from environmental exposure pathways is a proven and acceptable <br />alternative for municipal landfill facilities. <br />• Costs are substantial and disproportionate to any reduction in risk. The alternative is <br />estimated to cost $165 million. Even when costs for remedial alternatives for all <br />exposure pathways are considered in aggregate, this aggregate cost is far less <br />expensive than excavating and removing all landfilled materials. <br />• The "Excavate and Remove Landfilled Materials" alternative would also present <br />substantial short-term risks from exposure to solid waste and its constituents during <br />excavation and hauling, by increasing resuspension of groundwater contaminants, <br />by removing barriers to surface water infiltration, and through impacts to stormwater <br />runoff. Additional impacts to traffic and transportation would be incurred. <br />• For groundwater, it is not found to be a permanent solution to the maximum extent <br />practicable because continued operation of the leachate collection system through <br />construction, and downgradient monitoring after excavation would be required. <br />• The "Excavate and Remove Landfilled Materials" alternative is no more protective <br />than either of the other direct contact alternatives, and would result in greater direct <br />contact risks over the short-term. <br />• Public concerns may be raised about the environmental effectiveness of transporting <br />waste from one landfill setting to another at increased cost and increased community <br />impact, without achieving increased environmental protection at the Everett <br />Landfill/Tire Fire Site. <br />FINAL - March 2001 <br />7-9 Everett Landfill Tire Fire Site <br />Cleanup Action Plan <br />1 <br />