United States
            Environmental Protection
            Agency
               Office of
               Emergency and
               Remedial Response
EPA/ROD/R10-89/019
September 1989
&EPA
Superfund
Record of
            Northside Landfill, WA

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•50272-101
 REPORT DOCUMENTATION
        PAGE
1. REPORT NO.
     EPA/ROD/R10-89/019
                                           3. Recipient'* AcceMlon No.
 4. Title and Subtitle
   SUPERFUND RECORD OF DECISION
   Northside Landfill, WA
   First  Remedial Action - Final
                                           5. Report Date
                                              09/30/89
  7. Author)*)
                                                                     8. Performing Organlz>tlon Rept No.
 9. Performing Organization Name and Addrew
                                                                     10. ProJecVTuk/WorfcUnHNo.
                                                                     11. Contnct(C) or Gr«nt(C) No.

                                                                     (C)

                                                                     (G)
 12. Sponsoring Organization Name and Addrew
   U.S.  Environmental Protection Agency
   401 M Street,.S.W.
   Washington, D.C.   20460
                                            13. Type of Report & Period Covered

                                                800/000
                                                                     14.
 15. Supplementary Note*
 16. Abstract (Limit: 200 word*)

   The 345-acre Northside Landfill  is in a mixed residential and agricultural area,  in the
 northwest corner of the  city of Spokane,  Spokane  County, Washington.  The  landfill has
 been used since  the 1930s  by the city of Spokane  and a variety of private  and public
 haulers for disposal of  residential and light  commercial refuse.   The landfill is
          into  four disposal units; a refuse unit,  a grease  skimmings unit,  an  old open
       unit and a  sewage  sludge unit.   Only the  refuse unit  is  active.  However, this  unit
     scheduled  to  close by 1992.  The western one-third of the  landfill lies over the
 large Spokane Valley-Rathdrum Prairie Aquifer  (SVRPA).  The SVRPA was designated as  a
 sole source of water supply for the Spokane-Coeur d'Alene  area by EPA in  1978.
 Investigations conducted in 1981 and 1983 indicated the presence of volatile organic
 compounds (VOCs)  beneath the site and in offsite  residential  wells located northwest of
 the landfill.  The city  immediately supplied the  19 affected  residences with bottled
 water and has since extended municipal water lines to the  area.  The primary contaminants
 of  concern affecting the ground water are VOCs  including PCE,  TCA, and TCE.  In
 addition, iron and lead  exceed the  secondary drinking water standards offsite.
 (Continued on next page).
  17. Document An*ly*l* a. Descriptor*
    Record of Decision - Northside Landfill,  WA
    First  Remedial  Action - Final
    Contaminated Media:  gw
    Key  Contaminants:  VOCs  (PCE,  TCA, TCE),  metals  (lead)

    b. Mentifien/Open-Ended Term*
    c. COSATI Reid/Group
  18. Availability Sutement
                             10. Security CU*» (Thl* Report)
                                    None
                                                      20. Security Clu* (Thi* Pige)
                                                         	None	
21. No. of Page*
    96
                                                                                 22. Price
 (See ANSI-Z38.18)
                                       SM Instruction* en /town*
                                                       OPTIONAL FORM 272 (4-77)
                                                       (Formerly NTIS-35)
                                                       Department of Commerce

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16.  Abstract (Continued)

EPA/ROD/R10-89/019
Northside Landfill, WA


The selected remedial action for this site includes immediate closing of the inactive
units of the landfill with final closing of the active portion by 1992; capping all
disposal units;  constructing an interim pumping and treatment facility for ground water
remediation until landfill closure effectively reduces contaminants to below the MCLs,
followed by offsite discharge of treated water into the Spokane River; ground water
monitoring; providing an alternate supply of drinking water to residences affected by the
contaminated ground water; implementing institutional controls to restrict site access,
protect the landfill cap, and prevent construction of domestic wells in the contaminated
plume; and controlling landfill gas emissions.  The estimated present worth cost of this
remedy is $41,500,000 to $51,500,000, which includes an annual O&M cost of $489,000 for
10 to 30 years!

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           RECORD OF DECISION,
          DECISION SUMMARY, AND
         RESPONSIVENESS SUMMARY
                    FOR

            FINAL REMEDIAL ACTION
      NORTHSIOE LANDFILL SUPERFUNO SITE
                  IE,
               SEPTEMBER 1989
UNITED STATES  ENVIRONMENTAL PROTECTION AGENCY
                  REGION 10
              1200 SIXTH AVENUE
            SEATTLE, WASHINGTON

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       RECORD OF DECISION
 REMEDIAL ALTERNATIVE SELECTION


      FINAL REHEDIAL ACTION
NORTHSIDE LANDFILL  SOPERFUND SITE
       SPOKANE,  WASHINGTON

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                               RECORD OF DECISION
                         REMEDIAL ALTERNATIVE SELECTION
SITE NAME AND LOCATION

Northside Landfill
Spokane, Washington

STATEMENT OF BASIS AND PURPOSE

     This decision document presents the selected remedial action for the
Northside (North) Landfill site In Spokane, Washington, developed in
accordance with CERCLA, as amended by SARA, and to the extent practicable, the
National Contingency Plan.  This decision is based on the administrative
record for the site, which is attached as Appendix B.

     The state of Washington "has been involved closely with this decision.
Although the state's comments on the Proposed Plan are incorporated into this
Record of Decision (ROD), EPA has not yet received the state's concurrence
letter.

ASSESSMENT OF THE SITE

     Actual  or threatened releases of hazardous substances from this site, if
not addressed by implementing the response action selected in this ROD, may
present an Imminent and substantial endangerment to public health, welfare, or
the environment.

DESCRIPTION OF THE SELECTED REMEDY

     The remedy documented by this ROD Is designed to protect public health
and the environment by preventing the consumption of groundwater which has
been contaminated by solvents from the landfill, and by reducing the migration
of those contaminants.  Major elements of the selected remedy include:

     0    requiring closure of the landfill  as soon as possible;

     0    capping the landfill after closure to minimize  entry of
          precipitation into the wastes;

     0    pumping and treating the contaminated groundwater to reduce the
          amount of contaminants entering the aquifer (this is a protective
          measure which will  operate until  the closure and capping actions
          prove effective in reducing aquifer contamination);

     0    monitoring groundwater around the landfill  and  downgradient from it
          to track changes in the extent  and nature of the contamination plume;

     0    providing an alternate supply of drinking water to those residents
          whose well  supply has become contaminated by the landfill;

     0    enacting administrative restrictions to protect the landfill cap,
          closed units, and monitoring wells from unauthorized access, and
          address construction of domestic wells in the contaminant plume; and

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          controlling landfill gas emissions (the city of Spokane is. '
          developing a separate Landfill Gas Management Report to address  this
          issue).

     For the purposes of selecting a remedy, the North Landfill site was
divided into five units.  Four of these units are areas of the landfill.   They
are the refuse, skimmings, old burn, and sewage sludge units; only the refuse
unit is currently In use.  The fifth unit is the aquifer beneath the site.
The selected remedy is the same (capping) for each portion of the landfill.
The cap will be designed to reduce landfill  leachate generation and thus
control future contamination of the groundwater beneath the site.  Part of the
site is still actively receiving refuse and  will continue to do so until
December 31, 1991.   Beginning In 1992, all  refuse will be diverted either to
a planned waste-to-energy facility, new units to be constructed at Northside,
or an alternate landfill site.  Closure of the non-active units may begin
after approval of the closure plan, with final  closure beginning in 1992 after
the existing refuse unit is no longer receiving wastes.

     The pump and .treatment remedial action  will actively control the source
of groundwater contamination leaving the landfill.   This will allow the
contamination to naturally attenuate and restore its usefulness.

DECLARATION

     The selected remedy is protective of human health and the environment,
attains federal and state requirements that  are applicable or relevant and
appropriate for this remedial action, and Is cost-effective.   This remedy
utilizes permanent solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable  for  this site.  However,
because treatment of the wastes at the site  was not found to be practicable,
this remedy does not satisfy the- statutory preference for treatment as a
principal  element of the remedy.  The size of the landfill  and the existing
state of technology rendered treatment and/or excavation not feasible for this
site.

     The selected remedy does not require placement of RCRA hazardous wastes
either on or offsite.   Therefore, the Land Disposal  Restrictions  do not apply.

     Because this remedy will result in hazardous substances  remaining on-site
above health-based levels, a review will be  conducted within  five years after
commencement of remedial action to ensure that  the  remedy continues., to provide
adequate protection of human health and the  environment.
    /Date                                    Reg 1ona1  Admi n1s trator
                                             Environmental  Protection Agency
                                             Region 10

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  DECISION SUHMARY
FINAL REHEDIAL ACTION


 NORTHSIDE LANDFILL
      IE,

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                                TABLE OF CONTENTS
                                                         Page
Decision Summary

     Site Location and Description                          1
     History of Site Operations                             6
     Site Investigations and Remedial Activities           .7
     Enforcement Activities                                 8
     Community Relations                                    9
     Site Characteristics                                  11
     Summary of Site Risks                                 16
     Description of Alternatives                           27
     Comparative Analysis of Alternatives                  35
     The Selected Remedy                                   52
     Statutory Determinations                              56
     Conclusion                                            60

Appendices

     A.  Responsiveness Summary                          A-l
                        •
     B.  Administrative Record Index                     B-1
                                       ii

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                                 LIST Of FIGURES
                                 LIST OF TABLES
1.   Vicinity Map:  Northside Landfill                           2
2.   Landfill Units                                              3
3.   Distribution of PERC:  June 1986                            5
4.   Distribution of PERC:  June 1988                           13
1.   Range of Contaminant Levels On and Offsite                 12
2.   Estimated Doses and Incremental Cancer Risks from          17
     Average Exposure Due to Use of an Offsite Well
3.   Estimated Doses and Incremental Cancer Risks from          18
     Exposure Due to Use of the Most Contaminated Offsite
     Wells
4.   Estimated Doses and Incremental Cancer Risks from          19
     Exposure Due to Use of the Most Contaminated Onsite
     Well
5.   Chemical-Specific ARARs and TBCs for Organic               32
     Contaminants Found at the North Landfill
6.   Summary of Alternative Evaluation Criteria                 36
7.   Cost Summary                                               48
                                       iii

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                                DECISION SUMMARY

                        SITE LOCATION AND DESCRIPTION


     The Norths ide Landfill, also known as the North Landfill, is located In
the northwest corner of the city of Spokane, In Spokane County, Washington.
The landfill covers 345 acres and 1s bounded by Nine Mile Road and the bluff
of Five Mile Prairie (Figure 1).  It is surrounded by a chain link fence, with
one main gate; structures near the gate include a gatehouse, truck weighing
station, two equipment storage areas,  and a caretaker's trailer.

     The landfill is located in a mixed residential  and undeveloped
agricultural area.  The Agency for Toxic Substances  Disease Registry review
found there are 20 homes with approximately 65 residents in the area of the
contaminated groundwater plume from the landfill.

     The Spokane Val ley-Rathdrum Prairie Aquifer (SVRPA) lies beneath
approximately the western one-third of the landfill.  This aquifer was
designated as a sole source of water supply for the  Spokane-Coeur d'Alene area
by the U.S. Environmental Protection Agency (EPA) in 1978, under  the 1974
Federal Safe Drinking Water Act (Public Law 93-523).  Highly permeable sands
and gravels deposited by glacial meltwater streams (gladofluvial deposits)
make up the majority of the aquifer, with subordinate lenses of clay and zones
of cobbles.  The remainder of the landfill is directly underlain  by
unsaturated glaciofluvial sands and gravels with less permeable glacial lake
deposits and basalt occurring at depth.

     The climate In the area Is semlarid, with 17.2  Inches average
precipitation at the Spokane Airport and about 15 inches at the landfill.
Most of the precipitation falls during winter as snow.   Average annual
snowfall at the airport Is 58 Inches.   Frost typically penetrates from 12 to
18 Inches Into the ground; however, during unusually cold  winters it may
penetrate 36 inches or more.

Identification of Landfill Units

     The Northslde Landfill site was divided into sections for evaluation in
the feasibility study.  The Identification of these  different areas  was based
on past disposal  practices and the nature and extent of contamination.   These
areas are referred to as* "Units" and were evaluated  on the basis  of the
different technologies that were applicable to each  unit.   The units are
(Figure 2):
     Refuse Unit
     Skimmings Unit
     Old Burn Unit
     Sewage Sludge Unit
     Aquifer Unit
Refuse Unit — The portion of the landfill  still  receiving solid waste (since
1962).  It measures 115 acres and had received  approximately 4,400,000 cubic
yards of waste as of December 1987.   Small  quantities of cleaning solvent
sludges are assumed to be interspersed throughout this waste.  Refuse enters
this unit at the current rate of 500-600 tons/day.

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                                NORTHWEST SPOKANE AREA
                            WASHINGTON
                  Contaminant Plume
Figure 1
Vicinity Map
Northside Landfil
7.
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luis'n
pilal


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3000     «MO    'JOOO

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                                                                         •  EXISTING GAS MONTOWNQ PROBE

                                                                         A  EXIsflNQGROUNDWATERMOMTOfllNQWEU.
                                                                             (WELL ELEVATION)
                                                                             SURVEY MONUMENT
                                                                            NOTES. SM Figuf • I -9 toe tot M «nd toil boring
                                                                                 locMont witiin tkmmjng mill
                                                                                                            11000.J
                                                                                 Aquttof um not trunm.

                                                                                 MW BandMW-R«Mf*convdMd togupcobM
                                                                             SLUDGE UNIT'"
                                                                               («ACRES)
                                                                    OLD BURN UNIT
                                                                      (38 ACRES)
                          REFUSE
                          (115 ACRES)
                                                                               •     I
                                                                          -!
UW-O (167571)
                       •  '* V & '  . -; \' •", V VA\NiL>^^
	^"^ww^^^^^+f^
                           VM    '  ' \ '    •  v—orsSf'V'
                                                                                                                       Flj-urc  2
                                                                                                                      LANUI ILL UNITS

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Skimmings Uni t—The portion of the landfill that received grease skimmings
from  the city's wastewater treatment plant from about 1972 until 1987.  The
disposal pit. area is approximately 3 acres in size; if the landfill area
between the pits is included in calculating the area, it increases to
9 acres.  For the purposes of cost calculations, the smaller area was used.
Using an average depth of 5 feet for skimming deposits, this area contains
about 24,000 cubic yards of skimmings.  The skimmings contain low
concentrations of tetrachloroethylene (PERC), trichloroethylene (TCE), and
1,1,1-trichloroethane (TCA), which are volatile organic compounds (VOCs).

Old Burn Unit—The landfill section in which refuse was subject to open
burning between 1930 and 1962.   It Is 38 acres In size, contains approximately
3 million cubic yards of ash, noncombustible material, and burned refuse and
is covered with several feet of soil  (some small areas of ash are exposed at
the road cuts).  The area has naturally revegetated with grasses and weeds.
Data presented in the Feasibility Study (FS) do not indicate the presence of
VOCs.

Sewage Sludge Unit—The section of the landfill  which received digested sludge
from the city's wastewater treatment plant from about 1972 until 1983.  It is
approximately 8 acres In size and 25 feet deep.   It Is covered with soil and
natural  vegetation.   Data in the FS indicate that volatile organics probably
would not leach from this area because a high percentage of the VOCs are
destroyed or volatilized In the wastewater treatment and sludge digestion
process.

Aquifer Unit - That portion of the Spokane-Valley Rathdrum Prairie Aquifer
(SVRPA)  that contains concentrations above detection limits of PERC that has
leached from the landfill into the groundwater.   Currently that limit is
defined by the 1 ug/1  concentration curve.  PERC has been detected further
away from the landfill than any other contaminant (see Figure 3).

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LEGEND
5 —— PERC ISOCONCENTRATION
      CONTOUR (pg'O
t—t— INFERRED ISOCONCENTRATION CONTOUR

   •  MONITORING WEU SAMPLED FOR PERC
      H JUNE 1986
 (   ) JUNE 1966 PERC CONCENTRATION Ipg/l)

   •    NOT DETECTED
                         J
               IMSirilliUllUN OK PCHC
               JUNC K»«l

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                          HISTORY OF SITE OPERATIONS


     The Northside Landfill site has been  used  since the  1930s by  the City of
Spokane and a variety of private and public haulers for disposal of
residential and light commercial refuse.   The City of Spokane has  a total
population of about  180,000, and the landfill serves some  suburban customers
as well.  It is one  of two publicly owned  landfills still  In operation  in
Spokane County.  Several other  landfills have been closed  In recent years;
three of these—Colbert, Greenacres, and M1ca—are also Superfund  sites.  Due
to closures, Northside is currently receiving almost 70 percent of the
county's nonrecycled waste (about 600 tons per  day).  The  city and county
together are planning to construct a waste-to-energy facility, to be
operational by late  1991, to alleviate the waste disposal  capacity problem.
After review of city records and an assessment of the solid waste stream, it
has been determined  by EPA and  the City of Spokane that industrial wastes have
not been sent to the Northside  Landfill and are, for the most part, handled by
other facilities located in the County.  There  are very few historical records
of waste quantities or type received at the landfill.  A waste stream analysis
was done by reviewing previous  studies of waste type and disposal practices of
all businesses in the city.

     The site became the city's primary refuse dump about  1931.   During the
1930s and Into the 1940s, the northeast portion of the site was  an open dump
where the refuse was burned.  A refuse incinerator was constructed in the
1940s, but open burning continued at the site until  at least the late 1950s.
For a number of years, the ash  from this municipal incinerator as well as
bottles, cans, and other noncombustlbles were the major components of the
waste deposited at the site.  Any refuse that did not burn was left uncovered.

     Between 1962 and 1973, landfill ing practices began in the central area of
the site.  This Involved placing the wastes on the existing grade and covering
them with earth scraped or dug  from nearby areas.  This refuse was not burned
and received periodic cover.

     The trench method of landfilllng began in 1973, adjacent to Nine Mile
Road.  The trench method of landfilling Involves digging deep trenches (as
much as 20 feet below existing  grade),  filling them with waste,  and then
covering this with dirt excavated from the trenches.

     Currently, cover material   Is excavated from ridges located  along the
north side of the site.- This material  is being used to cover new refuse and
to add lifts (step-like plateau areas)  on top of the older, lower,  western
portion of the landfill.  These lifts (about 20 feet thick) have contained the
refuse to a total  depth of about 125 feet.

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                 SITE INVESTIGATIONS AND REMEDIAL ACTIVITIES
     In 1981, the City of Spokane hired C^M Hill, an engineering firm, to
investigate the hydrogeology and water quality in the area of the site.
CH2M Hill  installed four onsite groundwater monitoring wells in the fall of
1982; samples taken from these wells indicated the presence of low
concentrations of volatile organic compounds (VOCs).  One year later, in
October 1983, Investigations revealed the presence of VOCs in off site
groundwater from samples taken from residential wells located northwest of the
landfill.   The dty Immediately supplied the 19 affected residences with
bottled water and approved the extension of municipal water lines to the
area.  All of the affected residences were located in the Pine Meadows housing
development just northwest of the city limits; all were connected to the city
water supply by November 1983.  Spokane representatives completed water line
connections to 16 additional residences in the Pine Meadows area in spring
1984.  The municipal system is now serving additional residential areas
northwest  of the landfill that are not being impacted by the contamination
plume.

     In the spring of 1985, the City of Spokane Installed nine additional
wells to monitor water quality at the site.   There are currently 10 offsite
and 11  onsite groundwater monitoring wells.   The remedial activities conducted
after this effort are described under enforcement activities In the next
section.

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                            ENFORCEMENT ACTIVITIES


     Contamination of the SVRPA was noted by the  late  1970s and was  traced  to
Northside Landfill, but no  enforcement actions were  taken at  that' time.   The
city applied for a solid waste disposal  permit in  1979 and the Spokane County
Health Department granted it, though  they recommended  stepped-up  groundwater
monitoring and measures to  keep hazardous waste out  of the landfill.  The only
recorded permit violation was in July 1988, when the health district notified
the city that gas levels at the landfill were too  high.

     On October 15, 1984, EPA proposed the Northside Landfill for  inclusion on
the National Priorities List (NPL).   In  March 1985,  EPA and the Washington
State Department of Ecology (Ecology) signed an agreement whereby  Ecology
assumed the lead responsibility for remedial actions at Northside.  The site
was formally listed on the  NPL on June 10, 1986 (51  Federal Register 21054).

     The City of Spokane is the sole  identified Potentially Responsible Party
(PRP) for Northside Landfill.  The city  was notified of its potential
liability by EPA in September 1985 and by the state of Washington  in January
1986.

     In February 1986, Ecology and the City of Spokane signed an agreement  .
authorizing the city to conduct the remedial investigation for the Northside
Landfi.ll site.  The agreement included conditions  that would bring the city
into compliance with federal regulations regarding investigations of hazardous
waste sites.  .The City of Spokane submitted a draft Remedial  Investigation
(RI) report in October 1986 to EPA, Ecology, the Washington Department of
Social  and Health Services, and the Spokane County Public Health District.
Based on that report, dry cleaning sludges and wastewater treatment plant
grease skimmings were identified as possible sources of chemical  contamination
in the landfill waste.  City representatives presented Information concerning
the investigation and related Issues at a public meeting on December 11,  1986.

     The city submitted a draft Feasibility Study  (FS) report in early 1987.
In this report, the city evaluated various alternatives for addressing
contamination problems in three areas:  contaminated refuse,  treatment plant
skimmings, and groundwater.

     After reviewing the draft FS, EPA and Ecology asked the  city to install
additional monitoring wells.  These wells were required to help characterize
the extent of the contamination plume in the aquifer.  The city and Ecology
were unable to come to an agreement on the proposed wells and Ecology
requested that EPA take the lead.   Subsequently EPA signed a  consent order
with the city on March 16,  1988, to complete the wells and undertake future
remedial  actions.   With the signing of this order, EPA became directly
responsible for overseeing activities at the site.

     Under the terms of the EPA-Spokane Consent Order, the city revised and
resubmitted the draft RI and FS documents in August 1988.   A  public meeting on
the results of the draft RI was held in September  1988; the public meeting on
the draft FS and proposed EPA recommended action (proposed plan) was held
March 15, 1989.  A public comment period was held on the RI/FS from March 1 to
March 31, 1989.

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                             COMMUNITY RELATIONS


     The specific requirements for public participation at Northside Landfill
under CERCLA, as amended by SARA, include releasing the RI/FS and proposed
plan to .the public.  This was done in February 1989.  Both documents were
placed in the administrative record and information repositories.  Notice of
the availability of these documents, plus notice of a public meeting on the
proposed plan and public comment period was published in the Spokesman-Review
on February 28, 1989.  A public comment period was held from March 1 to
March 31, 1989.  A public meeting was held on March 15, 1989, with
presentations given by EPA, Ecology and the City of Spokane.  Comments from
the public were taken and are summarized in the Responsiveness Summary portion
of this .document.

     Community relations activities have maintained effective communication
between the citizens living near the landfill, the city and EPA.  Discussion
between the different groups for Information purposes and suggestions on the
project has been open.   The actions taken to satisfy the requirements of the
federal law have also provided a forum for citizen involvement in reaching the
remedial action decision.

     EPA's community relations activities at the  site Include the following:

     9    August 1987:   EPA and Its contractor, EBASCO, conducted community
          interviews to develop a community relations plan.

     0    November 1987:  EBASCO submitted to EPA the Community Relations Plan
          for the site.  The plan was distributed to the Information
          repositories  at the main Spokane Library and the Spokane Engineering
          Services Library.  The administrative record was placed in the
          Spokane Library.

          May 12, 1988:  EPA distributed a fact sheet to persons on the
          mailing list.  It explained the Consent Order between the City of
          Spokane and EPA for completing the Remedial  Investigation.

          July 1988:  EPA distributed a Revised Community Relations Plan which
          provided up-to-date information on the  site and future opportunities
          for public Involvement.

     0    September 1,  1968:  EPA distributed a fact sheet announcing a public
          meeting on the Remedial  Investigation.

     0    September 15, 1988:  EPA hosted an Informational  meeting for the
          public to explain results from the Remedial  Investigation.   Three
          members of the public attended.

     0    February 28,  1989:  EPA distributed the proposed plan fact sheet to
          the persons on the mailing list.   This  fact sheet outlined the RI/FS
          results; it also explained EPA's preferred plan and how It differed
          from that recommended in the FS.   The fact sheet also announced a
          public meeting on March 15, 1989,  and the dates of the public
          comment period.  A public notice describing the proposed plan and-
          the public meeting was placed in the Spokesman-Review.

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March 1. to March 31: . Public comment period on Proposed Plan.

March 12, 1989:  A  second notice for the public meeting held on
March 15 appeared in the Spokesman-Review.

March 15, 1989:  EPA held a public meeting to explain the RI/FS
results and the proposed plan.  About 30 people attended the
meeting; 10 citizens gave verbal comments.  A record of the meeting
Is part of the Responsiveness Summary, Appendix A.

May 2, 1989:  A fact sheet summarizing the public comments and EPA's
response was distributed to the persons on the mailing list.  Those
who commented during the comment period also received a copy of the
complete Responsiveness Summary.  Copies of the Responsiveness
Summary were placed In the Spokane Public Library and Spokane's
Engineering Services Library.
                             10

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                            . SITE CHARACTERISTICS

Hydroqeology

     The Northside Landfill, situated about one-half mi.le east of the Spokane
River, overlies a portion of the Spokane Valley-Rathdrum Prairie Aquifer
(SVRPA).  This aquifer was designated as a sole-source water supply for the
Spokane-Coeur d'Alene area by the EPA in 1978, under the 1974 Federal Safe
Drinking Water Act (Public Law 93-523).   Highly permeable sands and gravels
make up the majority of the aquifer, along with lenses of clay and zones of
cobbles and boulders.

     The installation of monitoring wells has confirmed that the refuse area
is primarily over the SVRPA although the aquifer boundary has not been
precisely defined.  The aquifer surface  is about 80 feet below the level of
Nine Mile Road and is over 200 feet thick at the deep monitoring well at the
northwest corner of the landfill.  Hydraulic measurements help to define the
aquifer as a large and very productive aquifer which has average linear flow
velocities from 25 to 30 feet per day under parts of the landfill.

Groundwater Contamination

     Volatile organic compounds and metals have been detected in the
groundwater beneath and northwest (downgradient) of the landfill.
Tetrachloroethylene (PERC) and trlchloroethylene (TCE) are present in the
aquifer both onsite and dffsite at levels that exceed the EPA's existing or
proposed Maximum Contaminant Levels (MCLs) for drinking water.   Iron,
manganese, and lead also exceed drinking water criteria in several wells.
Table 1 gives a range of groundwater contaminants found in and  around the
landfill since monitoring began In 1983.  The locations of the  wells is shown
on Figure 4.

     PERC and Iron are the only two contaminants consistently present in
offsite wells at concentrations In excess of any existing or proposed
standard.   PERC is listed as a Group 82  carcinogen (i.e., probable human
carcinogen based on evidence from experiments with animals).  In addition,  its
offsite concentrations were also higher  than concentrations  of  other compounds
and it has been recorded In the greatest number of wells.  Thus, PERC was
selected as the primary compound of concern for this site.

     Iron was found in concentrations above the Secondary Drinking Water
Criteria for taste and odor.  Because this does not present  a health or
environmental risk, Iron was not considered a contaminant of concern.

     Six other compounds In addition to  PERC that have known health effects
have been detected in offsite wells:  chloroform,  TCE,  1,1,1-trichloroethane
(TCA), 1,2-(trans)dichloroethylene, 1,1-dlchloroethane, and  vinyl chloride.
Of these six compounds, only TCE and TCA were detected frequently enough and
at concentrations sufficient to make predictions of concentrations at points
of exposure.  Therefore, TCE and TCA were also selected as compounds of
concern for the purpose of evaluating public health risks associated with this
site.  Vinyl chloride was detected once  in one offsite well  and two onsite
wells at detection limits.  Although vinyl chloride is an end product for
chlorinated solvents, its detection only once at the Northside  site is not
sufficient to select it as a contaminant of concern.
                                       11

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                                                           TABLE  1
                                                 RANGE OF CONTAMINANT  LEVELS
                                                       ON AND OFF-SITE
                                              Groundwater
N)
Organlcs (ug/1)

Chloroform
TCA
TCE
PERC
1,2-Transdichloroethylene
• ,1-Dkhloroethane
Vinyl Chloride
Methylene chloride
Acetone
Toluene
Benzene
Ethylbenzene
Xylenes (o & m)
                                    On-slte wells
                                ND -
                                NO -
                                ND -
                                ND -
                                ND -
                                ND -
                                ND -
<5
15
22
33
 2
22
 1
         ND
         ND
         ND
         ND
         ND
         ND
         ND
not tested
not tested
not tested
not tested
not tested
not tested
                                                      Off-site wells
 6
15
 9*
28
 6
 6
 1
<.01 -
ND -
.001 -
16.8 -
15.8 -
4.7 -
<.001 -
<.001 -
.8 -
6.5 -
<.002 -
<.002 -
18.02
.055
.399
160
109
17.8
<.010
<.005
66.5
48.4
1.97
.005
ND -
ND -
.001 -
41.6+
44.6+
7.0+
ND -
<.01 +
2.1 -
18 -
(.01 -
<.002 -
.37
.016
1.165



.043

64.8
44
.162
.004
                                                                          Soil
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
                                              Air
ND
ND
ND
not tested
ND
ND
ND
1.7 -
3 -
ND -
ND
ND
ND
                                                                                                5.7
                                                                                                6
                                                                                                 .6J
                                                          Gas
ND
ND -  .30
not tested
not tested
not tested
ND
ND - 1.1
ND    .3J
ND -  .8J
ND - 1
ND -  .6
ND - 1.3
ND -  .8
     Inorganics (tested for In groundwater only)(mg/l)

     Iron
     Lead
     Zinc
     Calcium
     Magnesium
     Sodium
     Copper
     Cyanide
     Chloride
     Sulfate
     Manganese
     Cadmium

     ND = none detected
     J =  estimated trace value
     *    one Inconsistent result of 22 (Masgal well); suspected sample bottle contamination
     +    only sampled for once, from a single well

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LEGEND
5——PERCISOCONCEN1RMION
       CONTOUR l^g/l)
T—T—INFERRED ISOCONCENTHATIONCONTOU
   •   MONITORING WELL SAMPLED FOR PERC
       IN JUNE 1988
 (   )  JUNE 1988 PERC CONCENTRATION Otg/l)
   *   NOT DETECTED
               Figure A
               OISIIUIIIIIION OF PERC
               JUNt I9H8

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      PERC,  ICE,  and  TCA  are  degreasers  or  solvents  that  have  been  used  for
 many years  In  a  number of  household  products,  dry  cleaning  agents,  and
 industrial  metal  cleaners.   The  feasibility  study  states  that cleaning  solvent
 sludges  from dry  cleaners  and  other  small  businesses  are  probably  the major
 source of these  compounds  in  the landfill  wastes.   Analyses of dry  cleaning
 sludges  from establishments  which  used  the landfill have  shown as much  as 2
 percent  PERC by  weight,  as well  as  lower concentrations  of  other VOCs.   It  has
 been calculated  that  about 300 tons  of  dry cleaning sludges were taken  to the
 site.

      The city  stopped accepting  dry  cleaning wastes at the  landfill  in  1983.
 This was after EPA began regulating  dry cleaning sludges  as a hazardous  waste
 In  1980.  Prior  to 1983  the  dry  cleaning wastes were  a part of the  normal
 waste stream and  were distributed  throughout the refuse  disposal areas.
 Available Information Indicates  that all of  the dry cleaners  in Spokane
 generate less  than 1000  kg/mo  of RCRA hazardous wastes and  are therefore
 classified  as  Smajl Quantity Generators, who are allowed  to dispose  small
 amounts of  hazardous  wastes  in landfills.  Any dry  cleaning wastes  that
 arrived prior  to  1962 would  have been subjected to  open  burning which would
 have reduced the  concentration of VOCs.  Those arriving  between 1962 and 1983
 are  in the  115 acre main landfill area  currently in use.

      Another source of VOCs  is the liquid  waste pits  located  In the  upper,
 eastern portion of the landfill.  These pits received grease  skimmings from
 the  wastewater treatment plant.  Skimmings have not been  dumped In  these pits
 since 1987.  Analyses of the skimmings  and the contaminated soils in the pits
 have shown  up  to  3,400 ug/kg PERC, 1,200 ug/kg TCA, and 6,800 ug/kg  TCE.

      Another type of  solid waste that was  disposed of at  the  site was digested
 sewage sludge from the City of Spokane  wastewater treatment plant.   Sewage
 sludge disposal began In 1977  when the  wastewater treatment plant converted to
 secondary treatment.  Until mid-1979, several disposal techniques were used,
 Including mixing  the  sewage  sludge with the Incoming solid waste, lagoon1ng,
 and  land spreading.   In  1979,  a  trench  disposal operation was  devised in the
 northeast portion of  the landfill.   It  consisted of a series  of 6-foot deep
 trenches in alternating directions on successive lifts.   Between 1978 and
 1980, an average of 305 cubic  yards  per day of digested sewage sludge,
 containing  at least 16 percent solids,  was deposited in the landfill.  The
 sludge was  stabilized with ferric chloride and lime at 13 and  46 percent,
 respectively, on a dry weight  basis.  In 1978 the pH of the sludge  ranged from
 10 to 11.   In late 1983.the sewage sludge disposal  operation  at the  landfill
 was  discontinued.  The sewage  sludge appears to contain small   amounts of
 contaminants.  Analyses of sewage sludge conducted  in 1987 and 1988 did  not
 detect any  PERC or TCE, although TCA and several  other VOCs were detected in
 some  samples.

Contami nant M1qratlon—Groundwater

     Since  November 1982, the  City of Spokane has conducted a  major
groundwater sampling program in  and  around the Northside  Landfill.   Currently,
 the  program consists of quarterly monitoring of 11  onsite and  11 offsite
monitoring wells and  13 domestic wells.   Figure 4 shows wells  that are sampled
on a regular basis.  The groundwater quality data collected by the  City  are
presented in the Supplemental  Remedial  Investigation Addendum  dated November
 1988.
                                       14

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     More than 500 groundwater samples from more than 75 wells have been
tested for organic and Inorganic contamination by the City of Spokane since
contamination of the SVRPA by VOCs was discovered in November 1982.  In
addition, nearly 300 groundwater samples from about 35 wells have been tested
for inorganic contamination.   Throughout this period, the concentrations of
contaminants, particularly for organic contaminants, in individual wells have
remained relatively constant.

     The RI/FS states that the area of the PERC contaminant plume has remained
relatively constant between 1983 and the present, indicating that the
concentration In the aquifer  has reached a dynamic equilibrium or "steady
state" condition.   Figures 3  and 4 give PERC concentration contours for June
1986 and June 1988, respectively.   The FS report Indicates that,  although PERC
is moving downgradient within the  aquifer, the concentration reduction
mechanisms of adsorption,  dispersion,  degradation,  and dilution balance the
landfill releases, which results in the observed stable contaminant
distribution.
                                       15

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                            SUMMARY OF SITE RISKS


     Persons who may use contaminated groundwater from  the  area  of  the
Northside Landfill as their only source of water were identified as  the
population at risk of adverse health effects.  The  primary  routes of exposure
to contaminants in groundwater are  ingestion,  inhalation of volatile
constituents, and dermal absorption.  Tetrachloroethylene,  (PERC),
trlchloroethylene 
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                                  TABLE 2
          ESTIMATED DOSES AND INCREMENTAL CANCER RISKS FROM
             AVERAGE EXPOSURE DUE TO USE OF AN OFFSITE WELL
TCE
     Concentration (ug/1)
     Risk

PERC

     Concentration (ug/1)
     Risk

Total Excess Risk
Oral



1
3 x 10-7



3
4 x 10-6

1  x 10-5
                                                 Inhalation
1
3 x 10-7
4 x 10-6
               Dermal
1
1  x 10-9
2 x 10-8
(Sum of  risks due to three
exposure  routes and both
chemicals)
                                   17

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                                                                          TABLE 3

                                                     ESTIMATED DOSES AND  INCREMENTAL CANCER RISKS FROM
                                                 EXPOSURE DUE TO USE OF THE MOST CONTAMINATED OFFSITE HELLS
oo
Pel low Well

TCE
Concentration (ug/1)
Risk
PERC
Concentration (ug/1)
Risk
Total Excess Risk

oral

5
2 x 10~6

2*8
4 x I0~5
8 x I(T5
Average Casq
inhalation

5
2 x NT6

28
4 x ID'5
(Sum of risks

dermal

5
1 X 10'5

28
2 x 1
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                                                                         TABLE 4

                                                    ESTIMATED DOSES AND INCREMENTAL CANCER RISKS FROM
                                                EXPOSURE DUE TO USE OF THE MOST CONTAMINATED ONSITE WELLS
VD
Well MH-M

TCE
Concentration (ug/1)
Risk
PERC
Concentration (ug/1)
Risk
Total Excess Risk

oral

13
4 x 1(T6

14'
2 x HT5
5 x IO'5
Average Case
inhalation

13
4 x l
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 contaminated onsite wells were  identified as monitoring wells MW-M and MW-T.
 At  the MW-M Well, the average concentrations of PERC,  TC£, and TCA are 14,  13,
 and 6 ug/1, respectively.  The  highest concentrations  of PERC, TCE, and TCA
 observed at this well are 26. 22, and 15 ug/1, respectively.  MW-T Well was
 sampled only once in June 1988.  The concentrations of PERC, TCE, and TCA
 detected in this well are 33, 4, and 18 ug/1, respectively.

     Four other organic compounds—chloroform, 1,2-transdichloroethylene,
 1,1-dichloroethane, and vinyl chloride—were detected  on a few occasions in
 less than 30% of the offsite wells.  Vinyl chloride, for example, was analyzed
 on only one occasion and was detected only in the Pel low, MW-M, and MW-T Wells
 at  1 ug/1.  Chloroform was sampled for regularly in each well, but was
 detected in only 3 wells, on one occasion in each well (maximum concentration
 = 6 ug/.l detected in the Costello Well. October 1987).  These chemicals were
 therefore not evaluated in the  risk assessment, because they were detected so
 infrequently and at very low concentrations relative to their toxicity (often
 near the detection limit of 1 ug/1).  However, because of the weight of
 evidence and cancer potency of  vinyl chloride and chloroform, the maximum
 likely additional cancer risks  due to exposure to these chemicals are
 discussed in the uncertainty section.

     Iron was the only inorganic compound detected in  offsite wells that
 exceeded drinking water standards.  The ambient water  quality criterion for
 iron (0.3 mg/1) Is based on taste, odor, and staining  properties.  This
 compound was not considered a contaminant of concern because there are no
 known health effects from ingestion of iron at the concentrations measured.

 Exposure Assessment

     The population at greatest risk of adverse health effects are those
 people who potentially use the  groundwater In the area of the Northside
 Landfill as their only source of drinking water.   The  primary routes of
 exposure to contaminants in groundwater are ingestion, Inhalation of volatile
 constituents, and dermal.absorption.

A. Exposure Point Concentrations

     As mentioned above, groundwater monitoring data from Appendix D of the
Supplemental RI Addendum were used to derive exposure  point concentrations.
Appendix D contains organic chemical concentration data for samples taken
during the period of September  1983 through June 1988  for onsite and offsite
wells.  Most wells were .sampled periodically during this period and so a time
 series of data is available for these wells.   Some wells were sampled only
once or very Infrequently during this period.

     A great number of analytical results are reported as below a detection
 limit of 1  mlcrogram per liter or as below an unspecified detection limit.
When calculating exposure point concentrations for PERC, TCE and TCA, these
 "non-detectable" results were treated in the following manner.  If a result
was reported as less than 1  microgram per liter,  then  it was assumed that the
concentration equals one-half of the detection limit,  i.e., 0.5 ug/1.  If a
result was reported as less than an unspecified detection limit, it was
assumed that the detection limit is 1 microgram per liter, and that the
concentration equals 0.5 ug/1.
                                       20

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1) Average Exposure Due to Use of Offsite Wells

     In this scenario, It was assumed that persons would be exposed  to
groundwater contaminants at a level equal to the arithmetic mean of  all  the
observations (N = 523) averaged over time for all of the offsite.wells
(total  = 61).  For PERC, TCE, and TCA, these concentrations are 3, 1, and
1  ug/1, respectively.

2) Exposure Due to Use of the Most Contaminated Offsite Well(s)

     For this scenario, for each of the three chemicals of concern,  the
offslte well which showed the highest average concentration was identified.
The average concentration at a well is defined as the arithmetic mean of the
time series of concentration data.

     For PERC, the Pel low Well showed the highest average concentration  (28
ug/1 based on 24 observations).   The average concentration of PERC at all
other offslte wells is less than 9 ug/1.

     For TCE as well, the Pel low Well showed the highest average concentration
(5 ug/1 based on 24 observations).  The average concentration of TCE at all
other offsite wells is less than 2 ug/1.

     For TCA, the Volkman Well showed the highest average concentration  (7
ug/1 based on 31 observations).   The average concentration of TCA at the
Pel low and Shaw Wells was 4 ug/1.  At all other offsite wells, the average
concentration of TCA Is less than 2 ug/1.

     The Pel low and Volkman Wells were therefore identified as the most
contaminated wells.  Risks associated with the exposure to groundwater
contaminants from the both these wells are evaluated assuming two levels of
exposure.  The first level is the average concentration at the wells.  These
concentrations are given In the paragraphs above.

     The second level considered is the highest concentration observed at the
wells.   At the Pellow Well, the highest observed concentrations of PERC, TCE,
and TCA are 38, 8, and 10 ug/1,  respectively.  At the Volkman Well, the
highest observed concentrations of TCE and TCA are 7 and 15 ug/1,
respectively.  PERC was assumed to be at a concentration of 0.5 ug/1, as it
was not detected in this well.

3) Exposure Due to Use Of the Most Contaminated Onsite Wells

     For this scenario, for each of the three chemicals of concern, the onsite
well which showed the highest average concentration was identified.  The
average concentration at a well  is defined as the arithmetic mean of the time
series  of concentration data.

     For PERC, the MW-T Well showed the highest average concentration (33 ug/1
based on 1 observation in June 1988).

     For TCE, the MW-M Well showed the highest average concentration (13 ug/1
based on 16 observations).

     For TCA, the MW-T Well showed the highest average concentration (18 ug/1
based on one observation in June 1988).
                                       21

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     The MW-M and MW-T Wells were therefore  identified as  the most
contaminated wells.  Risks associated with the exposure  to groundwater
contaminants from both these wells are evaluated assuming  two levels of
exposure.  The first level is the average concentration  at the wells.  These
concentrations are given  in the paragraphs above.

     The second level considered Is the highest concentration observed at  the
wells.  At the MW-M Well, the highest observed concentrations of PERC, TCE,
and TCA are 26, 22, and 15 ug/1, respectively.  At the MW-T Well, the only
observed concentrations of PERC, TCE, and TCA are 33, 4, and 18 ug/1,
respectively.

B. Calculation of Dose

     For each chemical  of concern, an average daily dose was calculated for
two routes of exposure, Ingestion and dermal  contact.  A dose from inhalation
of volatile organic compounds, such as the chemicals of concern, was not
calculated directly, as the various models for estimating  risks from
inhalation exposure have not been critically reviewed by the EPA, Region 10.
Therefore, in this risk assessment it was assumed that the  inhalation risks
are equal to (average case) or two times (upper-bound case) the risks from
ingestion of 2 liters of water per day, according to current EPA, Region 10
guidelines (USEPA, 1989a).

     The average daily dose (mg/kg/day) via ingestion was  calculated as
follows:

     dose - concentration of contaminant (mg/1) x intake rate (I/day) / 70 kg
     body weight

     For all  exposure scenarios, a person was assumed to ingest 2 liters  of
contaminated water every day for a lifetime.   Absorption was assumed to be
100* for all  chemicals.

     The average daily dose from dermal  absorption  of contaminants  while
bathing was calculated  as follows:

     dose = C x CF x Kp x SA x EF / 70 kg body weight

     where,

     C    = concentration of contaminant (mg/1)
     CF   « conversion  factor (10~3 l/cm^)
     Kp   - dermal permeability constant (cm/hr)
     SA   « body surface area contacted (cm2)
     EF   - frequency (hr/day)

     For all  the volatile contaminants,  a dermal  permeability constant of 8.4
x  10~4 cm/hr was used In the above equation (USEPA,  1989c).  The body
surface area exposed to water while bathing was assumed to be 18,000 cm2  for
the average adult (USEPA,  1989b).   For each exposure scenario,  a person was
assumed to bathe for a  duration and frequency equivalent to one-half hour
every day for a lifetime.
                                       22

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Toxlci ty Assessment

     Under current EPA guidelines, the likelihood of carcinogenic and
non-carcinogenic effects due to exposure to site chemicals are considered
separately.  Criteria for evaluating the potential of site chemicals to cause
these two types of adverse effects are described below.

A. Criteria for Non-Carcinogenic Effects

     The acceptable dally Intake for chronic exposure (ADI) Is an estimate of
the highest human Intake of a chemical,  expressed as mg/kg/day, that does not
cause adverse effects when exposure is long-term (lifetime).  ADI values are
based on animal or human toxlcity studies from which a no-observed-adverse-
effect level  (NOAEL) is experimentally determined.  The NOAEL is the highest
dose at which there was no statistically or biologically significant adverse
effect observed.  The ADI Is derived by dividing the NOAEL from the selected
study by an uncertainty factor.  The uncertainty factor consists of multiples
of 10 to account for specific areas of uncertainty in the available data.   For
example a total uncertainty factor of 1,000 may be used to account for; use of
a subchronic  (short-term) study (10), for extrapolation from animals to humans
(10), and for protection of sensitive human populations (10).

     When the EPA completes verification of the chronic toxlcity of a specific
chemical, it  establishes a "reference dose" or RfD.   If the RfD for a chemical
has been established, then the RfD is used as  the ADI for evaluating long-term
non-carcinogenic risks at the site.

     The dose calculated from the exposure assessment 1s compared to the RfD
to determine  whether adverse effects might occur.  If predicted exposure
concentrations are below the level of the RfD, no adverse health effects are
expected according to current EPA guidelines.

     The oral RfDs for PERC and TCA are  0.01  and 0.09 mg/kg/day,  respectively,
each calculated with an-uncertainty factor of  1,000  (USEPA, 1988).   The RfD
for PERC 1s based on observations of liver toxicity  In mice.  Including
increased liver weight/body weight ratios,  changes in liver enzyme  levels,  and
necrosis (death of liver tissue).  Increases  in liver and kidney weight/body
weight ratios have been observed in rats, also.  The RfD for TCA is based  on
fatty changes in the liver and Increased liver weights in guinea pigs exposed
via inhalation.  Non-carcinogenic health effects of  TCE are similar to  those
of PERC and TCA; however, an oral RfD for TCE  is not currently available and
therefore not evaluated .here.

     RfDs for dermal absorption have not yet  been determined by the EPA.
However, for  volatile organic compounds,  such  as the chemicals of concern  at
the Northslde Landfill, current EPA policy is  to use the oral  RfD In
calculating the hazard index for dermal  exposure.  The hazard  index is  the
ratio between route-specific calculated  dose  and the RfD.  Ratios exceeding
unity (one) indicate doses that exceed the acceptable levels;  ratios less  than
one are not expected to cause adverse health  effects.  One of the assumptions
in using an oral RfD is that 100% of the chemical was absorbed via the  route
investigated  In the study that was used  to derive the oral RfD.  This is a
reasonable assumption for a dermal RfD for the chemicals of concern at  this
site.
                                       23

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      As  noted  previously,  risks  from  inhalation  exposure  were  not  calculated
 directly,  but  assumed  to  be  equal  to  (average  case)  or  two  times  (upper-bound
 case)  the  risks  from  ingestion of  2 liters  of  water  per day, according  to EPA
 guidelines  (USEPA,  1989a).

 B.  Criteria for  Carcinogenic  Effects

      The EPA uses a welght-of-evidence  system  to convey how likely a  chemical
 is  to be a  human carcinogen,  based on epldemiological studies,  animal  studies,
 and other  supportive data.   The  classification system of  the EPA for
 characterization of the overall  weight  of evidence for carclnogenlcity
 includes:  Group A- Human  Carcinogen; Group B- Probable Human Carcinogen;
 Group C- Possible Human Carcinogen; Group D- Not Classifiable as to Human
 Careino'genicity; and Group E- Evidence  of Non-Cardnogenicity for  Humans.
 Group  B  Is  subdivided  into two groups:  Group  Bl- limited human evidence  for
 carcinogenicity; and Group 82- sufficient data in animals,  but  inadequate  or
 no  evidence in humans.

      TCA Is currently  in Group D, not classifiable as to  human
 carcinogenidty, and therefore was not  evaluated for carcinogenic  risks.   PERC
 and TCE are currently  classified as probable human carcinogens  by  the EPA,
.Group  82.  However, the status of these compounds and their respective  cancer
 potency factors  Is now under review.

      For PERC, the review  concerns whether  this  chemical  Is most appropriately
 classified  1n Group 82 or C.  Evidence  of liver  tumors (in  both sexes of mice
 by  two routes of administration), leukemia  in rats, and renal carcinomas  in
 male  rats, along with  supportive metabolic  considerations,  provide  a basis for
 classifying PERC In Group  82.  However, mutagenicity data have  In  general  been
 negative or Inconclusive.  Furthermore, the relevance of mouse  liver tumors to
 human  cancer risk 1s still in question.  PERC would therefore be classified as
 Group  C, possible human carcinogen, if one  accepts the weighting of the animal
 evidence to be limited.

      For chemicals with carcinogenic effects, EPA calculates the cancer risk
 associated with  a given dose by multiplying the  dose from a given  route of
 exposure by a cancer potency factor or  potency slope.  The  EPA derives  potency
 factors from the upper 95^ confidence limit of the slope of the extrapolated
 dose-response curve, which shows the relationship between a given  dose  and the
 associated tumor incidence.  As a result, the predicted cancer risk is  an
 upper-bound estimate of the potential  risk  associated with exposure.
                        •

      The present oral cancer potency factors for  PERC and TCE are  5.1  x 10~2
 and 1.1 x 10-2,  respectively (USEPA, 1988).  There are no cancer potency
 factors for dermal absorption. However, for volatile organic compounds, such
 as  the chemicals of concern, current EPA policy  Is to use the oral  potency
 slope  in calculating cancer risk from dermal exposure.

 Risk Characterization

 A.  Carcinogenic  Risks

     Estimates of carcinogenic risks for the three exposure scenarios
 considered are presented in Tables 2,  3, and 4.   These risks are the estimated
 lifetime incremental upper-bound risks of developing cancer as a result of
                                       24

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 being  exposed to PERC and  TCE under  the  assumed  conditions.   The  risks
 associated with exposure to each  chemical via oral,  inhalation,  and dermal
 exposures routes are given.  Also, total excess  risk  values  are  shown  for
 each scenario.  Total excess risk values are calculated  by adding the  risks
 due to exposure to both chemicals by all three exposure  routes.

     Table 2 shows the estimated  cancer  risks based on an average exposure
 to PERC and TCE due to use of an offsite well.   The total excess  risk  is  9
 x 10~6 for this scenario.  This number represents an  increased risk of
 contracting cancer of nine chances In one million for a  person exposed  for
 70 years.

     Estimated cancer risks based on exposure to PERC and TCE due to use  of
 the most contaminated offsite wells  (the Pel low and Volkman  Wells)  Is shown
 in Table 3.  For each of these wells, exposure to the average and maximum
 concentrations of each chemical  observed at the well was considered
 (average and upper-bound cases,  respectively).  For the  Pel low Well, total
 excess risks are estimated to be 8 x 10~5 and 2 x 10~4 assuming
 exposure to average and maximum concentrations, respectively.  For  the
 Volkman Well, total excess risks are estimated to be 2 x 10~6 and 9 x
 10~6 assuming exposure to average and maximum concentrations,
 respectively.

     Table 4 shows the estimated cancer risks based on exposure to  PERC and.
 TCE due to use of the most contaminated onsite wells (the MW-M and  MW-T
 Wells).  For Well  MW-M, the same two levels of exposure  were considered as
 for the offslte wells.  Total  excess risks are estimated to  be 5  x  10~5
 and 1  x 10~* assuming exposure to average and maximum concentrations,
 respectively.  For the MW-T Well, the total  excess risk  is 1  x 10~4 for
 both the average and upper-bound exposure calculations,  based on  the single
 available observation.

 B. Non-Carcinogenic Risks

     Non-carcinogenic risks are  presented as a hazard index which  is the
 ratio  between the route-specific calculated dose and the RfO.  Ratios
 exceeding unity (one) indicate doses that exceed the acceptable level;
 ratios less than one are not expected to cause adverse health effects.

     Based on the highest observed concentrations of PERC and TCA,  the
 Pellow and MW-T Wells were the offsite and onsite wells,  respectively,
 found  to pose the greatest risk  of non-carcinogenic effects.   The estimated
 doses of each chemical, based on  the maximum observed concentration, and
 the corresponding hazard index are presented below for the Pellow and MW-T
 Wells.

 Pellow Well                PERC                      TCA
                           (mg/kg/day)              (mg/kg/day)

Oral  Dose                  1.1  x 10~3               2.9  x 10~4
 Inhalation Dose            2.2 x 10~3               5.7  x 10~4
 Dermal  Dose                4.1  x 10'6               1.1  x ICr6
 Total Dose (A)             3.3 x 10~3               8.6  x ICr4
 RfD (B)                    1.0 x  ID'2               9.0  x 10~2
 Hazard Index (A/B)         0.30                      0.01
                                     25

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 MW-T  Wei1         .          PERC                      TCA
                            (mg/kg/day)               (mg/kg/day)

 Oral  Dose                   9.4 x  10~4                5.1  x  I0~4
 Inhalation Dose             1.9 x  10~3                1.0  x  10~3
 Dermal Dose                 3.6 x  10~6                1.9  x  10-6
 Total Dose (A)              2.8 x  10~3                1.5  x  10-3
 RfD , based on the highest observed
 concentration (6 ug/1) and an oral  cancer potency  slope of 0.0061
 (USEPA,  1988).   Because these chemicals are degradation products  of the
other chlorinated organrcs,  vinyl chloride and chloroform levels could rise
 and pose risks greater than  the above estimates.

D. Conclusions

      In  conclusion, the total incremental increase in cancer risk for the
average  exposure scenario is 9 x 10~6.  For exposure to one of the
offslte  wells with the highest average concentration of carcinogens, cancer
risks range from 2 x 10~6 to 1 x 10~4.  Estimated  cancer risks from
exposure to groundwater from the most contaminated onsite wells range from
5 x 10~5 to 1  x  10~4.  These scenarios are based on the assumption that
 the population at risk is using groundwater near the Northside Landfill as
 the only source of drinking  water over an entire lifetime (70 years).
Non-carcinogenic health effects are not expected from exposure to PERC and
TCA at the present level of  contamination in onsite and offsite wells.
                                     26

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                       DESCRIPTION OF ALTERNATIVES


     The goal of the remedial actions is to prevent, reduce, or control the
contaminants leaving the landfill and entering the groundwater. •
Technically applicable technologies were identified in the FS for each of
the units.  Most of the remedial actions that passed the screening process
for one of the landfill solid waste units (refuse, skimmings, old burn, or
sewage sludge) passed for all of the other three.  The aquifer unit
includes different technologies that deal with the migration of the
contaminants In groundwater and not the material In the refuse.  The
description of the treatment alternatives is divided Into those for the
landfill units and those for the aquifer unit.

Landfil'l Units

     Remediation of the landfill units must control, as far as possible,
the leaching of contaminants into the groundwater.  This may be done by
either:

     a)   capping the landfill  to eliminate leaching;
     b)   diverting stormwater  so that it does not generate leachate;  or
     c)   excavating the landfill and removing the contaminated waste.

If it proves impracticable to control leachate,  administrative restrictions
may be enacted to reduce exposure to contaminants.  Another alternative
considered Is to take no action.

a)   Capping.  The cap system would consist of multiple layers,  including
     topsoil, soil  cover, drainage layers,  and bedding/protection  layers,
     in conjunction with a low  permeability,  barrier layer to control
     infiltration.   Around the  perimeter of the  cap,  collection  ditches
     would be Installed to intercept stormwater  runoff and convey  it to
     appropriate points of discharge.  Three  different types  of cap systems
     were considered:   synthetic membrane,  synthetic membrane and  clay, and
     sol1/bentonite.

     The cap would utilize proven technologies.   Its main advantage is that
     it restricts the amount of leachate that can enter the aquifer unit by
     reducing the infiltration  of precipitation  into the landfill.
     Precipitation is the principal  source  of leachate generation  for  the
     landfill because It. is located above the Identified groundwater
     tables.   Therefore,  if precipitation,  run-on, and any lateral  flows
     from the hillside can be kept from entering the waste, the  health and
     environmental  hazards associated with  leachate generation and
     contamination of the aquifer unit would  be  significantly reduced.

     Disadvantages of capping include the waste  of concern remaining
     onsite,  the potential  for  the cap to leak and generate additional
     leachate,  and the magnitude of grading and  covering 345 acres of
     land.   Leakage of the cap  is a concern because of the potential for
     future leachate generation.  The design  and Installation of the cap
     would need to be carefully done, and a maintenance program would  be
     necessary to reduce the risk of leaks  developing  in the system over
                                     27

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     time.  Environmental impacts of the cap installation are considered
     temporary because the existing surface topography would not change
     significantly and vegetation would be reestablished.

     Capping, of course, presupposes the closure of the landfill.  Three of
     the units—old burn, sewage sludge, and skimmings—are no longer in use
     and could be capped at any time, but the refuse unit currently is
     scheduled to remain In use until December 31, 1991, when the
     waste-to-energy treatment system becomes operational.   Any refuse taken
     to the Northside site after December 31, 1991, will be required to be
     placed into a new disposal unit which meets the state's Minimum
     Functional Standards (MFS) requirements.

     ARARs

     The closure and capping alternative include action-specific applicable or
     relevant and appropriate requirements (ARARs).  The primary ARAR is the
     Washington State Minimum Functional Standards for Performance (MFS) (WAC
     173-304-460).  The MFS are applicable to landfills that Institute closure
     after November 27, 1989.  The Northside Landfill  will  be operating beyond
     1989.

     The MFS Include requirements for the final  cover, groundwater monitoring,
     landfill gas monitoring and control, runoff and leachate control, a
     closure plan, and a closure cost estimate.

     The wastes in the landfill are not currently classified as hazardous
     wastes under RCRA because the only sources  identified  are small  quantity
     generators.  Since closure and capping do not include  the placement of
     RCRA hazardous wastes,  those RCRA regulations would not apply.

     There are no chemical-specific or location-specific ARARs identified for
     this alternative.

b)   Surface Hater Diversion and Collection Systems.   These systems  are
     designed to divert and collect stormwater runoff  and keep it from
     infiltrating the landfilled wastes, thereby reducing the potential  for
     leachate generation.  The diversion and collection systems  would  consist
     of ditches, culverts,  and pipelines that collect  runoff from flow
     concentration areas and convey it to an appropriate point of discharge.
     The ditches would be lined to ensure that infiltration would be  minimized.
                        »
     This alternative's chief advantages are that it would  consistently  help
     reduce leachate-generating precipitation from entering the  landfill, and
     it is low in cost.  The disadvantage is that it does not address
     infiltration by precipitation that falls within the landfill  boundaries.

     In the final  analysis  of alternatives, surface water diversion  is not
     considered a separate  alternative, but rather a component of capping,  and
     is included as part of that alternative.

c)   Excavation and Offsite Disposal.  One additional  remedy passed  screening
     for the Skimmings Unit only.   It was rejected for the  refuse unit because
     of high cost and EPA preference for onsite. remedies (the old burn and -
     sewage sludge units have low contaminant levels and disproportionately
                                       28

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     higher costs)..  .This alternative entails total  removal of grease
     skimmings (though, not any contaminated soil) which would then be disposed
     of offsite at a permitted hazardous waste landfill.  As this is an
     offsite activity,  such disposal  must comply with all applicable hazardous
     and solid waste disposal  requirements.  These include RCRA and the state
     Dangerous Waste and solid waste  regulations.

d)   Excavation and  Onstte Treatment.  Treatment onsite is either through land
     treatment or incineration.   Land treatment is described as biological
     treatment of the waste done onsite but not in-situ.  This meets EPA's
     preference for  onsite treatment.

     The chief advantages of this alternative are its permanent elimination of
     one potential  contaminant source,  its  elimination of the health hazard
     for this area of the site,  and  the fact that it restores the area for
     possible future use.  No administrative restrictions would be necessary
     after excavation and treatment  were completed.

     Disadvantages of this alternative  include health and safety impacts
     associated with excavation, environmental  concerns (e.g.,  worker exposure
     to contaminants during excavation  and  treatment), demonstrated
     effectiveness,  and cost.

     ARARs

     Several  action-specific ARARs are  identified for excavation and treatment
     alternatives evaluated for  the  Skimmings Unit area within the landfill.

     The skimmings originated from the  city's wastewater treatment plant  and
     are not RCRA hazardous wastes or state dangerous wastes either by
     definition or by characteristic.

     Any contaminated soils not  excavated can be treated as a non-disturbed
     solid waste unit (not hazardous) and capped according to applicable
     regulations.

     Excavation of the  skimmings could  also be expected to result in the
     release of some quantity of volatile organics.   There are  currently  no
     standards for PERC emissions, so any requirements would be determined by
     risk assessments which are  not ARARs,  but are "to be considered" in
     design of the remedial action.
                        9
     Excavation and  onsite treatment  of the skimmings includes  two treatment
     options.  Both  options Include  the excavation of the grease skimmings
     followed by treatment and placement back onsite.   Land treatment of  the
     skimmings has no applicable regulations.   However, the disposal  of any
     hazardous wastes generated  as a  result of the treatment process would be
     required to meet the RCRA disposal  requirements,  which would be
     applicable to this new waste's  disposal.

     The Incineration of the skimmings  has  relevant  and appropriate RCRA
     requirements for the operation  and disposal  of  the waste streams.
     Although the incoming waste is  not RCRA regulated, the RCRA ash and  air
     emissions requirements for  Incineration would be relevant and appropriate
     because of the  PERC concentrations in  the waste.
                                       29

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      There were no chemical-specific or  location-specific ARARs  identified for
      the excavation alternatives.

      For the excavation with off site disposal alternative.,  the RCRA hazardous
      waste regulations are not applicable because the skimmings  are not a RCRA
      waste.  However, offsite activities, such as disposal, will be regulated
      by applicable laws and regulations, and are not subject  to  ARAR
      analysis.  For example, the transportation and packaging of the skimmings
      as a hazardous solid waste because of the PERC content Is regulated by
      the U.S. Department of Transportation.

d)    Administrative Restrictions.  This would involve restricting land use
      with respect to future onslte excavation and construction.

      The chief advantages of this alternative are its low cost and ease of
      implementation.   Public health would be protected by reducing exposure to
      the contaminants at the site.

      The primary disadvantage is that administrative restrictions would not be
      effective in eliminating or reducing public health concerns offsite.
      Infiltration would not be reduced nor surface water or groundwater flow
      controlled; thus the leachate would continue to be produced.  The MFS,
      which 1s an ARAR and requires landfill  capping, would not be met.

e)    No Action.   The  landfill  would be left in its current condition without
      any remedial  action being taken.  There would be no cost, but public
      health would not be protected.   ARARs would not be met.

Aquifer Unit

      For this unit, the remedial  objective 1s to reduce health risks from  the
contaminants In  the groundwater.   Alternatives include:

     a)   extracting  and treating the contaminated water;
     b)   monitoring;
     c)   administrative restrictions;
     d)   providing an alternate water supply;  and
     e)   no action.

a)   Collection  Hells. Treatment,  and Discharge.   The purpose  of the
     extraction  and treatment system is to reduce and control  the release  of
     contaminants  into tfie  aquifer downgradient from the landfill.   The
     aquifer unit  alternative includes  six variations using two extraction
     options for the  contaminated groundwater and three  treatment levels  for
     each extraction  design.

     The two extraction (pump)  options  are extracting the  entire contaminated
     plume  (total  plume capture)  and extracting only a portion of the
     contaminated  plume (partial  plume  capture).   The total  plume capture.
     system uses extraction wells  across the entire  width  of the contaminated
     plume  and would  be designed  to extract  groundwater with any amount of
     contamination for treatment.   This would include pumping  large  volumes  of
     groundwater that  is currently contaminated at levels  below the  protective
     requirements. The partial  capture system would extract only that
     groundwater that  is contaminated at concentrations  greater than existing
                                       30

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standards.  This would reduce the amount of water that would need  to  be  •
pumped and subsequently the volume that would be treated.

The difference between the two capture options, besides  the amount of
water pumped, is the amount of control over the release  of contaminants
downgradient from the system.  This would have an impact on the time
needed for recovery of the contaminated plume downgradient.  Both options
would control releases downgradient of the extraction system so that  they
would meet drinking water ARARs and protectiveness requirements in the
aquifer.  The design of the extraction system will determine where the
actual extraction wells will be located.

The. extracted contaminated groundwater would then be treated or
discharged into the city's wastewater treatment plant for treatment and
then discharged into the Spokane River.  Three levels of treatment have
been Identified in the FS, which are:  no treatment, treatment to
drinking water levels and Ambient Water Quality Criteria (AWQC) levels,
or treatment to background levels.

All of the pump and treat alternatives would also require groundwater
monitoring, administrative restrictions, and an alternative drinking
water supply.  There would be minimal environmental  Impact during well
construction and few anticipated health or safety concerns for the
surrounding community.

ARARs.

The ARARS are essentially the same for the two extraction alternatives.
The major regulations that contribute to the list of potential
chemical-specific ARARs are the Clean Water Act (CWA),  the Safe Drinking
Water Act (SDWA), and the Water Quality Standards for the State of
Washington (WAC-173-201) (90.48 RCW).  The acts are  under the
jurisdiction of and are enforced by the Washington State Department of
Health Services, the Washington State Department of  Ecology (Ecology),
and EPA.

The SDWA Maximum Contaminant Level (MCL) standards are  enforceable
standards that are applicable to surface water or groundwater  that can be
classified as a source or potential  source of drinking  water.   The MCLs
are applicable to any action that affects the concentration of
contaminants in groundwater which is  a source of drinking water, such as
the SVRPA.

The discharge of extracted water to the Spokane River is considered to be
offsite and is therefore not subject  to ARARS analysis.   Compliance with
the applicable laws, regulations, and permit requirements is necessary.
Some discussion of the discharge requirements is Included since treatment
may be done onsite.

The CWA Ambient Water Quality Criteria (AWQC) are designed to protect
aquatic life and human health.  The state of Washington  adopts the AWQC
by reference Into their water quality standards, so the  AWQC are
requirements for surface water discharges.  Table 5 presents
chemical-specific potential ARARs for water.  The table  is arranged by
chemical compound.
                                  31

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                                                         TABLE 5
                             CHEMICAL-SPECIFIC ARARS AND TBCS  FOR ORGANIC  CONTAMINANTS
                                               FOUND  AT THE NORTH LANDFILL
                                                                    Clean Water Act
N>
Safe Drinking
Water Act
Compound
Chloroform
1 , 1-Dichloroe thane
1 , 2- (Trans) Dich loroethy lene
Tetrach loroethy lene
1,1, 1-Trichloroe thane
Tr ich loroethy lene
Vinyl Chloride
MCL
iooa
-
-
-
200
5
2
MCLG
-
-
-
oe
-
-
0
Consumption of
Acute Chronic
Toxicity Toxicity
28,900b l,240b
- '
ll,600b
5,280b 450b
-
45,000b
-
Pish and
Water
0.19
0.94°
0.33d
0.8
18,400
2.7
2.0
Fish
Only
15.7
243C
1.85d
8.85
1,030,000
80.7
525
Reference-
Dose Da.scd
Criteria
350
4,500
350
10
1,000
260
46f (J3f)
           All  units in pg/1.
             Criterion for total trihalomethanes  (sum of chloroform, bromodichloromethane, dibromochloromethane,
             and bromoform).
             Lowest observed effect level.
           CCriterion for chlorinated ethanes based on toxicity of 1,2-dichloroethane.
             Criterion for dichloroethylenes based  on carcinogenicity of 1,1-dichloroethylene.
           GProposed October 1986.
             Longer term Health Advisory for adult  and 10 kg child is the 46 and 13 pg/1, respectively.  Lifetime
             Health Advisory not calculated.

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     Minimum treatment of the' extracted groundwater with ultimate discharge  to
     the Spokane River must comply with Ambient Water Quality Criteria
     (AWQCXsee Table 5).  The quality of the untreated groundwater would not
     be expected to satisfy the AWQC for fresh water due to VOC
     concentrations.  An NPDES permit would have to be obtained from Ecology
     prior to initiating the discharge.  Discharges to the river will be
     required to comply with the phosphorus discharge limits established for
     the Spokane River.  The alternative would also have to be analyzed for
     its effect on fish, wildlife, and habitat in and around the Spokane River
     as required by the Fish and Wildlife Coordination Act.  No other
     location-specific natural  resource ARARs were identified.

     The extracted groundwater wi11  be treated to meet drinking water
     standards for metals and volatile organic compounds or meet NPOES and
     AWQC requirements, whichever is more stringent,  prior to discharge to the
     Spokane River.  There would be  some level of contamination remaining in
     the treated water discharged to the Spokane River.

     The cost for the extraction and treatment alternatives would be moderate
     to high, depending on the number of wells and the specific treatment
     process selected.

b>   Monitoring.  The existing groundwater monitoring system would continue to
     be used until  the long-term monitoring plan is developed and approved by
     EPA.   This existing system consists of wells both on- and offsite which
     were Installed at various  depths to indicate the level of contamination.

     Monitoring would be low In cost and easily implemented,  since it could  '
     largely utilize an existing system which could be supplemented if the
     existing wells are determined to be inadequate.   It would provide a means
     for measuring the effectiveness of other response actions.   However,  it
     would not In Itself protect public health.

     Groundwater monitoring for the  purpose of early  detection of contaminants
     beyond the existing plume  area  does not satisfy  ARARs  because the
     existing groundwater contaminant levels would continue to exceed drinking
     water MCLs within the plume.

c)   Administrative Restrictions.  Under this alternative,  the city would
     prevent the installation of well: in the contaminated  portion of the
     aquifer.  Though all affected residences are now connected to the city
     water system,  there" are currently no regulations to make future
     residences connect with this  system or prevent existing  contaminated
     wells from being used.

     This  alternative would protect  public health by  limiting exposure to
     contaminated groundwater;  it would be low in cost to Implement.  It would
     not reduce contamination,  and ensuring compliance could  be difficult.

     Administrative restrictions to  prevent use of the contaminated
     groundwater in the area of the  plume do not satisfy ARARs because
     groundwater contaminant levels  would continue to exceed  drinking water
     MCLs  for decades.
                                       33

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d)   Alternative Hater Supply.  All new residences in the area of
     contamination would be connected with the municipal water system, as
     existing residences .already are.  It would be technically feasible since
     there are nearby water lines, though some new service laterals might have
     to be constructed.  Public health would be protected and cost would be
     low, but the groundwater would remain contaminated.  There were no
     environmental receptors of the contaminated groundwater identified in the
     FS.

     An alternate source of drinking water for residents located In the local
     area of the contaminated plume does not satisfy ARARs.   Groundwater
     contaminant levels would continue to exceed drinking water MCLs until
     natural recovery reduces the contaminants below the MCLs.   This
     alternative would help in the Interim to protect public health, but
     contamination would not be reduced to MCLs; therefore,  It would not
     satisfy ARARs.

e)   No Action.   No remedial measures would be implemented,  beyond those
     already in  place (I.e., providing alternative water to  existing
     residences).  There would be no cost, no change in the  level  of
     protection  of public health, and no reduction of contamination in the
     aquifer. Water quality and Safe Drinking Water Act ARARs  would not be
     met.
                                       34

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                   COMPARATIVE ANALYSIS OF ALTERNATIVES


     CERCLA guidance (U.S. EPA 1988) requires that each  remedial  alternative
 be evaluated according to specific criteria.  The purpose of  the  evaluation  is
 to identify the advantages and disadvantages of each alternative, and  thereby
 guide  selection of the remedy offering the most effective and feasible  means
 of achieving the stated cleanup objective.  Hhlle the nine CERCLA evaluation
 criteria are all Important, they are weighted differently In  the
 decisionmaklng process depending on whether they describe a required level of
 performance (threshold criteria), technical advantages and disadvantages
 (primary balancing criteria), or overall evaluation by non-EPA reviewers  that
 may affect an EPA decision (modifying criteria).

     EPA evaluated the four landfill units together because, they all had
 similar technologies that passed the screening step.  The evaluation of the
 aquifer unit follows because it has different possible technologies than  the
 landfill units.  The nine evaluation criteria are:

     Threshold criteria

     1.   Overall protection of human health and the environment
     2.   Compliance with ARARs

     Primary balancing criteria

     3.   Long-term effectiveness and permanence
     4.   Reduction of toxicity,  mobility, or volume
     5.   Short-term effectiveness
     6.   Implementabi1ity
     7.   Cost

     Modifying criteria

     8.   State acceptance
     9.   Community acceptance

Table 6 provides a summary of the alternative evaluation criteria.

Threshold Criteria

     The remedial alternatives were first evaluated in relation to the
threshold criteria:  overall  protection of human health and the environment
and compliance with ARARs.  The  threshold criteria must be met by the
candidate alternatives for "further consideration as remedies for the ROD.

1.   Overall Protection of Human Health and the Environment

     This criteria addresses whether or not remedial action provides adequate
protection or describes the mechanisms for controlling risk for the different
exposure pathways.
                                       35

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                                                                 TABLE 6

                                                SUMMARY OF ALTERNATIVE EVALUATION CRITERIA
Remedial
Alternative
Protection
of Health
and Environment
Compliance
with ARARs
Long Term
Effectiveness
and Permanence
Short Term
Effectiveness
                                                                                                                       Imolementabili tv
LANDFILL UNITS

  Capping
0  Moderate to
highly effective
reduction of long-
term health risks.
                   0  Not effective
                   for short term
                   reduction of
                   contamination
                   entering the aquifer.
Applicable
state and federal
ARARs; can be
designed to meet
Requirements.
30+ yrs. useful life;
Reduces effect of
source on aquifer;
Requires O&M
Contains the
source & reduces
some exposure
routes.
Proven technology;
1 yr. to construct;
substantial grading
of steep slopes.
  Excavation
     Off Site
     Disposal
Highly effective,
removes a source
of contamination;
possible short term
risks to workers.
ARARs apply to
all 3 options.
ARARs can be mat
by proper design.
Effective source
removal; residual in
soils will leach
Effective source
removal; residuals
remain in soil.
Proven technology;
takes 4-6 mos. to
excavate and
transport.
     On-site
     Treatment
Highly effective,
long term &
permanent but slow
to implement;
possible short term
risk to workers.
                          Effectiveness
                          unknown; residuals
                          may exist which
                          can leach.
                          Effectiveness
                          unknown;  requires
                          treatability
                          studies.
                                                                                                                       Innovative
                                                                                                                       technology;
                                                                                                                       requires
                                                                                                                       treatability
                                                                                                                       studies  &  may
                                                                                                                       take  10  yrs.
                                                                                                                       to  implement.

-------
                                                             TABLE 6 (cont'd)

                                                SUMMARY OF ALTERNATIVE EVALUATION CRITERIA
                                                                                                    Page 2
Remedial
Alternative
Protection
of Health
and Environment
Compliance
with ARARs
Long Term
Effectiveness
and Permanence
Short Term
Effectiveness
                                                                                                    Imolementabilitv
     On-Site
     Incineration
  Administrative
    Restrictions
  No Action
Highly effective
& permanent treat-
ment; Possible short
term risk from air
emissions.
Low protection for
exposure; no
protection to
groundwater.

No reduction in
risk.
Any new requirements
must be constant
with other laws
and regulations.

Currently does
not meet ARARs.
                          Effective removal;
                          residuals will
                          remain to leach.
Permanent remedy.
None
                         Effective removal;
                         residuals in soil
                         remain.
Effective
reduction to human
risk.
None
                         Innovative
                         technology;
                         nay require
                         demonstration;
                         1 yr. to
                         implement.
No 1 imitations.
                                                  None
AQUIFER UNIT
  Pumping &
    Treatment
Highly effective
in permanently
reducing health &
environmental risks.
Applicable state
& federal ARARs.
Treatment can be
designed to meet
discharge ARAK
criteria.
Highly effective in
controlling off-site
migration. Useful life
20+ yrs.  Requires
O&M.
Highly effective
in controlling
downgradient migration
Proven technology;
2 yrs. to design
and construct.'

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                                                             TABLE 6 (cont'd)

                                                SUMMARY OF ALTERNATIVE EVALUATION CRITERIA
                                                                                                   Page 3
Remedial
Alternative
Protection
of Health
and Environment
Compliance
with ARARs
Long Term
Effectiveness
and Permanence
Short Term
Effectiveness
Imolementabil itv
  Administrative
  •  Restrictions
  Groundwater
    Monitoring
  Alternative
    Water Supply
  No Action
Moderately effective
preventing future
from construction
of new wells.       •
No protection.
Highly effective
for short term
and possible long
term;  Reduces use
of contaminated
aquifer.

No protection.
Any new
requirements must
be consistent with
existing ones.
Meets ARARs.
Permanent remedy.
Municipal water
system currently
meets ARARs.
Currently does
not meet ARARs.
Can be maintained
for long term;
Requires sampling
and analysis.
Useful life is 50*
yrs.  Highly
effective system.
Not effective;
no reduction
in risk.
Reduces exposure
to contaminated
aquifer.
Only measures
contamination;
no protection.
Highly effective
at reducing
health risks.
No limitations.
No additional
protection to use
of groundwater.
Proven technology;
system in place.
Proven technology;
system in place.
None

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 Landfill Units

     The most effective alternative for the landfill would be capping
     (incorporating a surface water collection system, as discussed
     previously).  All of the landfill units include a capping alternative.
     These alternatives would take take about a year to implement and  the
     effectiveness would show decreases in concentrations of compounds  in  the
     aquifer 5 to 10 years after completion.  Capping Is a containment
     technology because It controls the mobility of the contaminants through
     the waste material.

     Under this remedy the wastes would remain onslte, but the potential for
     future leaching of contaminants Into the groundwater would be reduced.
     Since leachate is considered the main source of groundwater contaminants,
     the prevention or reduction of leachate should result in gradual recovery
     of the groundwater.  Since groundwater is the main exposure pathway for
     the site's contaminants, any alternative reducing groundwater
     contamination would substantially reduce the risk to public health.
     Although effects on non-human biota have not been studied at this site,
     presumably they too would be less at risk.   The actual  construction of
     the cap would have some environmental impact, but it would be minimized
     and temporary.

     The most protective alternative evaluated for the Skimmings Unit, a small
     section of the landfill, would be excavation and treatment.
     Implementation would result in all contaminated wastes  being either
     removed or rendered substantially less hazardous, thus  reducing the
     threat to public health.  However, this alternative would have more
     adverse effects on the environment during construction  (e.g., noise,
     possible air exposure to contaminants) than  any of the  other alternatives.

     Excavation and onslte land treatment or onsite Incineration both are very
     protective since there is a reduction In the amount of  contaminants after
     the cleanup goals are met.   During the treatment processes  and during
     excavation there would be slight, unquantlfiable increases  in short-term
     risk because of discharges of VOCs to the air during excavation,
     incineration and land treatment.

     Administrative restrictions such as not allowing drinking water wells in
     the contaminated plume would limit exposure  to contaminants, but would
     not reduce actual contamination,  and so this alternative receives a low
     rating In terms of public health and environmental  protection.

     The no action alternative reduces neither the level  of  contamination nor
     public exposure to contaminants,  and thus does not protect public
     health.   The current environmental impact would continue.

Aquifer Unit

     The total  plume capture alternative described In the FS would pump and
     treat the entire contaminated plume at the  boundary of  the landfill, thus
     reducing the risk from any groundwater use  downgradient.  The partial
     plume capture alternative as described in the FS would  pump and treat the
     contamination that is above MCLs  at the landfill  boundary and reduce the

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     concentration of contaminants of concern to below drinking water
     standards.  Under, both capture options the groundwater  leaving the
     landfill would meet the MCLs for the aquifer.  This would reduce the
     risks downgradient from the landfill and eventually allow full use of  the
     aquifer again.  The treatment facilities described in the FS.for both  of
     these alternatives would produce air emissions from the volatile organic
     compounds removed from the groundwater.  The exposure to these air
     emissions would be below health based criteria because concentrations  are
     expected to be below detection limits at exposure points.  Discharge of
     treated groundwater to the Spokane River would increase the amount of
     measurable compounds reaching the river.  Treatment will reduce the
     discharge concentrations to meet health based and receiving water quality
     standards.

     Administrative restrictions would restrict future well drilling and
     existing well usage In the area of the contamination plume and thus
     reduce the potential for consumption of contaminated water.   This would
     provide limited human health protection, and no protection to the
     environment.

     An alternative water supply would also limit (but not eliminate)  human
     exposure to contaminated groundwater, and would not protect the
     environment.

     Groundwater monitoring would not in itself protect public health  or the
     environment, though It would provide evidence of future.changes in health
     risk from the groundwater.
 •                   *
     The no action alternative would involve no technical  or administrative
     remedial action.   There would be no protection of human health or the
     environment.

2.    Compliance with ARARs

     The purpose of this analysis Is to identify applicable or relevant and
appropriate requirements (ARARs) that may be major components of  the remedial
actions and to evaluate the alternatives for compliance with the  ARARs and
those criteria to be considered (TBCs) in the evaluation,  such as certain
health  based risk assessments to help determine what is protective.

Landfill Units
                         9
     Excavation of the skimmings from the Skimmings Unit could be expected to
     result In the release of some quantity of volatile organics.   Although
     the concentration would be expected to be low, risk assessments for VOCs
     should be consulted.  The offsite disposal  portion of this alternative is
     not subject to ARARs evaluation.

     The excavation and onsite land treatment alternative shares  the above
     requirements relating to the excavation of the wastes.  However,  no -ARARs
     have been identified for this alternative because the skimmings are not
     considered a hazardous or dangerous waste and no hazardous waste
     by-products are expected.   Land treatment has some "to be considered"
     state guidance for the skimmings wastes which will require that
     monitoring be incorporated to ensure the protection of underlying
                                       40

-------
     groundwater. .State laws require control or collection of surface .water  .
     runoff will be needed to prevent offsite migration of contaminants.   The
     release of volatile organic compounds will be enhanced by land
     treatment.  This emission source will need to be evaluated as "to be
     considered" with respect to air pollution source criteria or risk
     analyses.

     Incineration of the skimmings includes some special ARARs for the
     Skimmings Unit.  The RCRA requirements would be relevant and appropriate
     for incineration, due to the concentration of PERC in the waste.  The
     requirements relating to the excavation of the wastes and the containment
     of site run-off are similar to offsite disposal  and onsite treatment.
     The onsite incinerator would be required to comply with RCRA hazardous
     waste incineration requirements for hazardous or dangerous waste.  These
     include emissions monitoring and control, wastewater treatment,  and
     disposal  of ash and solids from the emission control and wastewater
     treatment processes.

     Capping the landfill has the same ARAR analysis  for all  landfill units.
     The wastes in the landfill have not been classified as hazardous or
     dangerous wastes; therefore, the primary ARAR will  be the Washington
     State Minimum Functional Standards for Performance (MFSMWAC
     173-304-460).  The MFS will  be applicable to existing facilities that
     institute closure after November 27, 1989.  The  projected operating life
     of the Northside Landfill is beyond 1989.  The MFS Include requirements
     for the final cover, groundwater monitoring, landfill gas monitoring and
     control,  surface water, runoff and leachate control, a closure plan, and
     closure cost estimate.  RCRA is a relevant and appropriate requirement
     for post-closure monitoring.

     The requirement for a cap with 2 feet of 1 x 10~6 cm/sec or  lower
     hydraulic conductivity material  or equivalent will  be met by all three
     types of cap.  The requirements also include control of upgradlent
     surface water runoff entering the site,  diversion of offsite surface
     water, collection of surface water onsite, and minimum slope criteria.
     These alternatives, in conjunction with a gas collection and control
     program (being prepared by the City of Spokane), and a closure plan and
     cost estimate,  satisfy the MFS requirements.

     Administrative restrictions  placed on the site would not satisfy the MFS
     requirements for landfill closure which requires other specific  actions.
     The No Action alternative does not satisfy the MFS requirements  for
     landfills.

     The offsite disposal of any  wastes will  have to  meet all  substantive and
     procedural requirements of federal, state, and local regulations.  In
     addition  to disposal requirements, this alternative would also have to
     satisfy transportation and handling requirements.
Aquifer Unit
     Solvents collected from the treatment of the extracted groundwater in any
     tanks,  surface impoundments, or treatment residue would have to meet
     applicable hazardous or dangerous waste requirements (WAC 173-303) for
     disposal based on the VOC content.
                                       41

-------
     The groundwater monitoring alternative for  the purpose of  early detection
     of contaminant migration in the groundwater does not  satisfy ARARs
     because groundwater contaminant levels would continue to exceed drinking
     water MCLs for an extended period of time.  The same  is true for  the
     administrative restrictions, alternate water supply,  and no action
     alternatives.

     The groundwater extraction and treatment system for both total plume
     capture and partial plume capture have to meet similar laws and
     regulations.  The discharge of the treated groundwater has to meet the
     requirements of the AWQC or MCLs.  As the discharge 1s offsite, NPOES
     permit requirements for the point source discharge would have to be met
     before discharging to the Spokane River.  The discharge would also have
     to be analyzed for its effects on fish, wildlife,  and habitat in and
     around the river as required by the Fish and Wildlife Coordination Act.

Primary Balancing Criteria

     Once an alternative satisfies the threshold criteria, five primary
balancing criteria are used to evaluate other aspects of the potential
remedies.  Each alternative is evaluated by each of the balancing criteria.
One alternative will  not necessarily receive the highest evaluation for every
balancing criterion.   The balancing criteria evaluation will  be used in
refining the selection of candidate alternatives for the site.   The five
primary balancing criteria are:   long-term effectiveness and permanence;
reduction of toxicity, mobility, or volume through treatment; short-term
effectiveness;  implementabi1ity; and cost.

3.  Long-Term Effectiveness and Permanence

     This Is the ability of a remedial  alternative to provide protection and
reduce risks to health or the environment long after the cleanup goals  have
been met.

Landfill Units

     The excavation and disposal alternative is only feasible for the
     Skimmings  Unit,  a small  area within the landfill.   Removal  to an offsite
     treatment  and disposal facility is the most effective long-term remedy
     because It removes all of the contamination from the unit,  although it
     does transfer the risks  from this material  to the  disposal  facility.
     Excavation and onsVte treatment is nearly as permanent because it can
     reduce toxicity of the waste.   Both of these alternatives  remove the
     contamination from the site or treat it to reduce  the toxicity.  Once the
     soils are  treated to'the cleanup goals there would be no need for
     long-term  maintenance.

     Capping the landfill  units  Is the next most effective and  permanent
     remedial  alternative.   Three variations of cap design were evaluated and
     all three  designs meet the  minimum requirements for a landfill  cap.
     Stormwater collection and diversion systems and runoff controls are
     included  in the cap design; all providing a physical barrier that will
     reduce Infiltration to the  refuse.
                                       42

-------
     The projected life span of.the cap is 30 years or more.  Maintenance  is
     required to maintain the integrity of the cap and srormwater diversion
     systems.

     Although capping is containment and not treatment, it reduces
     infiltration through the refuse thereby reducing the amount of leachate
     produced.  This reduces the amount of contaminants entering the
     groundwater aquifer.

     Implementation of administrative restrictions could not be considered
     permanent because It can only restrict human access to contaminated
     groundwater and cannot prohibit it entirely.  Their long-term
     effectiveness depends on successful  enforcement.

     The no action alternative does not provide  any long-term protection of
     public health or the environment.   Contaminants would continue to leach
     into the aquifer; if the source strength does not remain constant, the
     contamination plume could expand.
Aquifer Unit
     The total  plume capture option is  a pump  and treat system designed to
     capture the entire contaminated plume  as  It leaves the landfill  area by
     use of extraction wells.   The system would  be designed to significantly
     reduce the. contaminants in the aquifer at the landfill boundary.  By
     reducing the source of the contaminants to  the offsite. plume the
     contaminated groundwater would naturally  attenuate to drinking water
     levels.  The treatment of the contaminated  water can be handled by
     different technologies.  The treatment system can be very, effective in
     reducing the contaminant levels in the discharge to background levels,
     drinking water levels or ambient water quality levels.  Each treatment
     alternative provides a degree of treatment  but only with proper operation
     and maintenance of the system.  Pump and  treat systems described in the
     FS have a design Itfe of 20 years.

     The partial plume capture pump and treat  alternative provides a system
     similar to the full  system but is  designed  to extract only the most
     heavily contaminated portion of the plume.   This system would allow
     contamination less than the drinking water  standard to continue to pass
     offsite.  The aquifer would take longer to  attenuate and the cleanup
     level  would be the drinking water  criteria.   Discharges to the river from
     the treatment unit.would be designed to meet the discharge ARARs for the
     Spokane River, similar to the total  capture system.  This system would
     also have a 20 years design life.

     The alternative water supply system provides immediate protection for
     human  health.  However, alternate  water does not permantly reduce the
     contamination in or entering the aquifer.   The water system would require
     normal maintenance.

     Administrative restriction can be  put  in  place to prevent the drilling of
     new drinking water wells In or near the contaminated plume.  This would
     reduce the potential for consumption of contaminated water but would not
     permantly reduce the contaminant .levels or  migration of the pollutants.
                                       43

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 4.   Reduction of  Toxiclty. Mobil rty. or- Volume

      This  criteria  is  an evaluation of the effectiveness of  the  treatment
 technologies that passed the  screening -step.  Several  technologies  are
 applicable to the skimmings area part of  the  landfill  and others  are  evaluated
 for  the aquifer unit.

 Landfill Units

      The excavation and offsite disposal  of the  skimmings would  eliminate
      approximately 23,500 cubic yards of  source  material.  This  reduction  is
      calculated to represent  about 10 percent of the PERC loading to  the
      aquifer.  Excavation and onsite land treatment or onsite  incineration  are
      both  technologies that can also be applied  to the skimmings.   Both would
      reduce the PERC to near  detection limits in the excavated waste.  But
      like  the offsite  disposal option, any contaminants in the soil beneath
      the area would continue  to migrate.

      Capping the  landfill units Is source control because it significantly
      reduces the amount of water that passes through the waste units.  Water
      passing through refuse generates the leachate that moves  the contaminants
      into  the underlying aquifer.  However, capping is not considered a
      treatment technology.

      Neither administrative restrictions nor the no action alternative would
      treat the contamination; toxicity, mobility, and volume of the
      contamination would be unaffected.

Aquifer Unit

      Extraction of contaminated groundwater (pumping) and subsequent treatment
     options would reduce the concentration of contaminants migrating
     downgradlent of the extraction wells.  The reduction of the concentration
     of contaminants effectively reduces the toxidty and volume of
      contaminants in the groundwater.   The mobility of the contaminants is
     controlled upgradient of the well  by the zone of influence created by the
     pumping drawdown action.

     The effect on the plume by the total  plume capture or the partial plume
     capture alternative would be similar.  It would take longer under the
     partial  plume alternative to achieve the same results.
                         •
     None of the remaining alternatives—monitoring, administrative
     restrictions, alternative water supply,  or no action—would reduce
     toxidty,  mobility or volume of the contaminants in the aquifer.

5.  Short-Term Effectiveness

     The short-term effectiveness of each alternative addressed impacts during
the time of Implementation.   This period normally lasts from one to five years
and includes  construction,  start up and operation until the cleanup goals are
reached.
                                       44

-------
Landfill Units
                                                                        4
     The short term effects from capping the landfill would immediately reduce
     the risk of contact with contaminated soils or wastes and would reduce
     the escape of VOCs.  There could be some risk to workers' health during
     construction of the cap.

     Excavation of the skimmings with onsite land treatment or incineration
     would not be effective in the short term,  as there would be risks to
     workers from construction and from the operation of the treatment systems
     themselves.

     Institutional controls would not protect human health, as people may
     continue to use existing wells in the area of contamination.  The no
     action alternative would have the same result.

Aquifer Unit

     Under the treatment alternative, groundwater would be pumped and treated
     and discharged to the Spokane River.   This alternative would in effect
     control the offsite migration of contaminants past the landfill
     boundary.  It would not, however, pull existing downgradlent
     contamination back to the landfill.

     The water discharged to the Spokane River  can be treated to meet
     applicable offslte requirements.  The short-term impacts of this
     alternative is construction.  Workers need adequate protection from the
     volatile organlcs during well  construction and operation of any treatment
     process that will release VOCs.   There should not be any short-term
     Impacts to the community other than construction.

     The alternative water supply limits consumption of contaminated
     groundwater but does not reduce  contamination.  Since the municipal
     alternative water supply system  is already in place, no new construction
     should be required, therefore, no short-term effects to health or the
     environment.

     Institutional controls would restrict the  use of groundwater but would
     not improve the groundwater quality.   No construction would be required.
     No action provides no short-term protection to health or the environment.

6.  Implementabi1ity

     The implementabillty of a remedial  alternative considers  the technical
and administrative feasibility of actually constructing the alternative to
make It work.

Landfill Units

     No action has, as expected, the  highest level of implementabillty.  There
     Is no construction required and  no time consideration, but this
     alternative does  not meet ARARs.

     Institutional controls or administrative restrictions would be nearly as
     easy to Implement since they do  not involve construction.  Some of the
                                       45

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     restrictions need not be put into effect until the landfill is.closed;
     others can be done earlier:  The time required to implement the
     restrictions depends on the length of time required to prepare and pass
     local ordinances, file deed notations, or take other administrative
     actions.  However, administrative restrictions by themselves do not meet
     ARARs.

     All the landfill  cap options use proven technology and would therefore be
     the most implementable; construction time is estimated at 8 months to 1
     year.  Certain site conditions—steep grades in some areas, variable
     weather—might have an impact on construction (some areas would probably
     require regrading).  To cap the refuse unit, the landfill can  no longer
     be receiving wastes.  Capping the other units may occur sooner because
     they are no longer receiving refuse.  Capping would use conventional
     construction equipment.

     Of the skimmings  excavation alternatives,  offsite disposal  would be the
     simplest to implement.  Conventional excavation equipment could be used
     for the skimmings area, though special containers or transportation
     methods might be  necessary for the actual  removal.   Onsite  Incineration
     would be the next easiest to implement,  though material handling and
     mobilizing and Incinerator might present problems.   Onsite  land treatment
     would require finding a suitable site (possibly the skimmings  unit area),
     and tests to determine the volatilization/treatment rate.  The tests
     usually require about 3 years of treatability studies.   Full-scale
     implementation might take 5-10 years, in addition to the  3-year land
     treatment demonstration which also reduces  its implementabi11ty.

Aquifer Unit

     There are no implementation requirements for the  no action  alternative.

     Institutional  controls and restrictions, and alternative  water could  take
     a  year to coordinate among the different agencies.   There are  no known
     limitations and no construction requirements identified for these
     actions.  A permanent alternative water  supply is already in place, and
     only limited construction to new homes and  normal  maintenance  will  be
     required in the future.

     The groundwater monitoring alternative could utilize  the  existing
     monitoring well  system supplemented  with new wells  as  needed.   There  are
     no known construction or permit limitations  for this  alternative.   A
     monitoring program is ongoing so there would be no  time lag in
     implementing it.

     Aquifer conditions at the site are technically feasible for a  pump and
     treat system.   Construction of extraction wells is  possible with
     treatment and  finally discharge to the Spokane River.   All  pump and treat
     options must meet groundwater withdrawal, treatment plant emission, and
     point source discharge requirements.  There  are no  major  problems
     anticipated which would affect implementation of any  treatment
     alternatives.  Construction of the pump and  treatment  system will  take
     about two years.
                                       46

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7.  Project Costs

     Present worth costs are used to evaluate and compare the cost of each
     alternative.  Present worth consists of the sum of  the  initial capital
     costs and the discounted annual operation and maintenance  (O&M) costs.
     Table 7 gives a summary of costs for each of the units  as  detailed  in  the
     Feasibility Study.

Landfill Units

     The no action alternative would cost nothing and therefore be the least
     expensive.  Administrative restrictions have no present worth costs since
     the costs are administrative such as passing ordinances.

     Costs for capping depend on the type of cap chosen.  The costs for  the
     landfill units are estimated in Table 7.  For the refuse unit (the
     largest and most costly one) a membrane and clay cap would cost an,
     estimated $29 million, while a membrane or sol1/bentonite  cap would cost
     $22 million.                                -     -

     The costs for excavation alternatives for the skimmings unit are about $2
     million for onslte land treatment,  $12 million  for offsite disposal, and
     $22 million for onslte Incineration.  In comparison, the cost of capping
     the skimmings unit would be $530,000-$720,000.

Aquifer Unit

     The no action alternative for this  unit would have no construction
     costs.  Institutional  controls similar to those for the landfill  units
     would have only administrative costs.

     An alternative water supply, which  already exists,  has  an estimated cost
     of $200,000.  The estimated costs for the aquifer alternatives are
     presented in Table 7.

     Groundwater monitoring costs are estimated as $320,000  for a 30 year
     period.

     Collection and treatment costs range from $3.6  million  to $87 million,
     depending on the level of treatment and whether plume capture is  partial
     or total.  Partial .plume capture is as protective to human health  and the
     environment and Is cheaper to implement than the total  capture system.

Modifying Criteria

     The modifying criteria are used in  the final evaluation of remedial
alternatives.  The two modifying criteria are state  and community acceptance.
For both of these elements, the factors  considered in the evaluation are the
elements of the alternative which are supported,  the elements of the
alternative which are not supported, and the elements of the alternative that
have strong opposition.

8.  State Acceptance

     Washington State Department of Ecology (Ecology) has been  closely
involved with the development and review of the Remedial Investigation and
                                       47

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                                                 TABLE 7
                          OLD  BURN AND SEWAGE SLUDGE UNITS COST SUMMARY

Engineering and
Drslgn
Construct Ion
feral Ulna. «* Uo«l
S«rvlc*i During
Construction
Initial Cost
Subtotal
Annual OM
n of out
Projact m

•U
Haitorana
and
Clai Cap
720,000
7.200.000
3(0,000
MO, 000
• ,900.000
19,000
140,000
»,000,000

BIB
Soil and
Btntonlta
1)0.000
S.200.000
260.000
410.000
6. 400,000
IS, 000
140.000
6.SOO.OOO
Old Bum Unit
BIC
Hcafcran*
510,000
5, 100,000
260,000
410,000
6,100.000
15,000
140,000
6.400.000
. Senao* Sludo* Onlt
B] Bl UU
Hcabrana
Und 0«« Ha and
BestftcUon* >ctloo Clay Cap
140.000
1,400,000
70,000
110,000
1,700,000
J.OOO
2B.OOO*
1,600,000
U1B
Soil and
Bcnlonll*
110,000
1,100,000
&6.000
90,000
1.400,000
3.000
18,000*
1,400,000
01C
Ha*>rana
110.000
1.100,000
S7.000
91,000
1,400,000
3,000
21,000*
1,400.000
Ul Ul
Und Ufa No
Restrictions Action
..
-.
-.
—
..
, —
—
—
Praacnt worth baaad on M r«ara at 10 parccnt net discount.

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                                                                  TABLE 7  (cont'd)
                                          REFUSE  AND  SKIMMINGS  UNITS  COST  SUMMARY



Engineering and
Design

Construct Ion
Permitting and
Legal
Service* During
Construction
*J Initial Cost
Subtotal
Annual MM
IV of OUt
Project m

RIA
Neebrane
and
Clar Cap
1,100,000

11,000,000

1.200,000

1.1100,000
18,000,009
110,000
1. 000.000
19,000.000

•IB
Soil and
Bentooll*
C*£ 	

1,100,000

17,000,000

•50.000

1,400.000
n.ooo.ono
110,000
1,000.000
11.000,000
Refuse On It
RIC

Neafcrane
Cap

1,700,000
*
16,700,000

•40,000

1,100,000
11,000,000
110.000
1.000.000
. 11,000,000
SklMlngs Onlt
111 M SI*
Of 1 site
Land Use No RCRA
Restrictions Action Landfill

980.000

9,BOo,nnn

490,000

780,000
12,000.000
..
o*
11,000,000
SIB

Ons Ite
Tre«t»rnt.
ioo.ooo

1,500,000

74.OOO

120,000
1,900.000
16,000
I60.000b
1,000.000
SIC

Onslle
Inclneial Inn

970,000

I9.oon.ooo

1,400,000

970,000
jj.nm.ono
0
0*
22,000.000
S2A
Heetirane
•nd
Clar Cap
58,000

580,000

29.000

46,000
710,000
1.000
9,000*
720,000
S2B
Soil and
Bent on Ite
_C«E_
42,000

420,000

21,000

14,000
570,000
1.000
9,000*
5)0,000
S2C

Hnriian*
__£•£_
42,000

420,000-

21,000

11,000
5 10,000
1,000
9,000*
5)0.000
SI 54

Un.l llsr Ho
Rf.tr |< I Inns Action



••

."

--
.-
--
--
-.
'present eorth based on M rears at 10 percent net discount.

bPresent worth based on 10 fears at 10 percent net discount.

Note:  Refuse unit cap costs are based on 115 acres and do not Include allowances for Methane gas control.

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                                                                      TABLE 7  (cont'd)
                                                         AQUIFER UNIT COST  SUMMARY
AIA
Discharge
to Spokana
P01M
Engineering and
Design NF
Construction
Permitting and
U,al
Services During
Construction
Initial Cost
Subtotal
in
O
Annual GUI
PW of 01 h
Project PM
Mr Imllcviles alternative not
a
A1BI

HlnUw
Treat »ent

500.000
4,700,000
*
110,000

170.000

5.100.000
700. 000
l.win.ooo*
6.BOO.OOO
feasible.

AIB1
Treatment
to Drinking
Hater Stds.

570,000
4.800.000

140.000

190,000

5,800,000
110,000
l.OOO.OOO*
7,600,000

A1B1
Treatment
to Hon-
deqradatlon
1,100,000
46.000.000

920,000

1 , 700,000

51,000,000
4,OOO,OOO
14,000.000*
B7.OUO.OOO

A2A
Discharge
to Spokane
POTH

49,000
150,000

11,000

10,000

iio.oon
420,000
1,600,000*
1.900,000

A2BI

HlnlHim
Treatment
210.000
2,000,000

98,000

78,000

2,400,000
140,000
1.200.0(10*
l.AOO.OOO

A7B7
Treatment
to Drinking
Hater Stds.

170,000
1.100,000

110.000

91,000

l.HOO.OOO
160,000
1,. 100 ,000*
4,100,0(0

A7B1
Treatment
to Non-
deqradat Ion
740.000
15,000.000

100,000

1,200.000

17,OOO,OOO
1,100,000
ll.OOO.OOO*
28,000,000

Al

Groundvater
Honltorlng
--
--

--

--

14,000
120,000
120,000

 Tiesriit wn|t.h ba^ed on 10 years at 10 percent net discount.

Not*:  Tim  *'l lna(*J protect m tolnl  for altrmate A4 our. |>io»l) l>r the client.
                                                                                                                                                A4         A5
                                                                                                                                             Alternative
                                                                                                                                               W^ler        Mo
                                                                                                                                             	i^I'l'Jl	   Action
                                                                                                                                              2(1(1,ono

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Feasibility Study processes.  Ecology commented on the RI/FS and worked  with
EPA on the proposed plan.  The comments from the state were an  important
factor in EPA's decision to recommend an alternative that differed from  the
recommendation in the Feasibility Study.  The state strongly favors  pump and
treatment of the contaminated groundwater plume as an interim measure  until
contamination coming from the landfill is reduced to acceptable levels.
Although EPA has been working closely with Ecology to ensure that this ROD
Includes the state's comments, EPA, has not yet received the state's
concurrence letter.

9.  Community Acceptance

     The results of the public comment period and the discussion during  the
RI/FS public meeting indicate that the residents who live near or have been
affected by contamination from the Norths1de Landfill  support the proposed
plan with Its interim pump and treatment system.  The community desires  a
remedy which would begin treating the contamination as soon as possible.  The
City of Spokane (the PRP) recommended that pump and treat only be Implemented
if contaminant levels In the plume were not lowered by the other closure
actions, specifically the cap.  The community recognizes that none of  the
alternatives, except for the pump and treatment system,  will be Implementable
until the landfill closes.  The pump and treatment system provides a
protection mechanism which Is not contingent on landfill  closure.

     The differences between the city's and EPA's recommended remedial actions
were highlighted in the proposed plan fact sheet and at the public meeting.
The resident community supported the EPA interim pump and treatment system
because It actually reduces the contamination In the aquifer, rather than
relying solely on natural attenuation.  It was  estimated that it would take
between five to ten years after the cap was in  place before the natural
attenuation process would be noticed In the aquifer.   The pump and treat
system can be Implemented in about 2 years.

     Closure of the landfill  with a cap, periodic monitoring, and other  state
landfill  closure actions were considered by all  parties  to be necessary  parts
of the remedial  action.  Individual concerns about cost and institutional
controls (administrative requirements) were responded to in the attached
Responsiveness Summary.

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                             THE SELECTED REMEDY


. Description

      The selected remedy for the Northside Landfill Superfund site consists of
 the following elements:

           Closing the landfill
      0    Capping the landfill  waste units
      0    Pumping and treatment of groundwater
      *    Monitoring the groundwater
      0    Providing alternative water
      ."•    Enacting administrative restrictions
      0    Controlling landfill  gas emissions

 Closing the Landfill

      As soon as possible, the landfill  shall be closed to stop the flow of
 incoming refuse.  The only disposal  area currently in use has been designated
 as the Refuse Unit.

      An alternative disposal  facility has been planned by the city as part of
 a regional  waste-to-energy project.   The schedule for the new incinerator
 facility is for operation to begin In late 1991.   The start up of the new
 waste-to-energy facility will  allow  Northside Landfill to be closed.

      In the event that the new  disposal  facility  is not available by
 January 1,  1992, all Incoming refuse to  Northside after that date will  be
 required to be disposed in new  landfill  units that meet the State Minimum
 Functional  Standards (MFS) for  operating landfills.  The MFS requirements
 Include lined units with leachate controls.   The  new units would  allow  closure
 of all  the  old units.

 Capping the Landfill

      The landfill  must be capped as  soon as  practicable.   A draft closure
 plan, .evaluating the phased closure  of all  landfill units and including a
 conceptual  design for the cap,  will  be developed  consistent with  ARARs.   If
 phased  capping is feasible, the closure  plan will  include a schedule  for the
 phased  implementation.   Construction of  the  cap must start consistent with
 state  MFS deadlines.

     All  of the cap designs in  the feasibility study meet the MFS
 requirements.   The cap functions to  contain  the refuse units and  to provide a
 barrier to  reduce infiltration  into  the  wastes, thereby reducing  groundwater
 contaminant loadings.  The feasibility study suggests  this is the most
 important remedial action for  the long-term  control of groundwater
 contaminants  from the landfill.

     Although capping is a general requirement for the landfill,  certain waste
 units  may not be contributing  to the contamination problems.  If  adequate data
 can be  obtained to demonstrate  that  an area  is not contributing  to any  of the
 existing problem conditions,  a  variance  (waiver)  for the capping  requirement
 may be  obtained for that particular  unit.  At the Northside Landfill, the
 capping variance may apply to an area designated  as the Old Burn  Unit.
                                        52

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     The Old Burn Unit was the original area of the landfill which allowed
open burning.  This area was closed in about 1960 and contains refuse that  has
been partially burned. .Therefore, the waste in this unit may be
characteristically different from any-of the other waste units.  Additional
study will have to demonstrate that contaminants of concern are not migrating
from this waste unit before the city applies for a capping variance for this
area.

Pumping and Treatment of Groundwater

     The construction of an Interim extraction well system (pumping) and a
subsequent treatment facility for the extracted groundwater 1s necessary to
begin controls on the release of contaminants beyond the landfill  boundary.
Contaminated groundwater Is the major route of exposure for human health and
the environment.   The installation of a pumping and treatment system is
designed to serve these functions:

     1.   Establish a system which will control the migration of contaminants
          downgradient from the landfill.   The system must effectively control
          the concentration for the contaminants of concern so that the
          groundwater downgradient from the point of compliance meets ARARs;
          e.g., the Maximum Contaminant Levels (MCLs)  of the Safe  Drinking
          Water Act.  The point of compliance Is the landfill  property
          boundary with performance monitoring to be located downgradient but
          beyond  the zone of influence of  the extraction wells.

     2.   Treatment of the extracted groundwater.   The treatment facility for
          the extracted contaminated groundwater will  have to reduce the
          levels  of all contaminants to required levels prior to discharge to
          the Spokane River.   If the discharge from this facility  1s through
          the sewage treatment plant,  the  pretreatment requirements will also
          have to be met.  The river discharge Is  considered offsite and,
          therefore, must meet all federal, state,  and local  requirements such
          as obtaining an NPDES permit.

          Any air emissions from the treatment facility will  have  to meet
          emission requirements.   Design of the treatment facility will  also
          need to consider published risk  assessments  for VOC releases.

     The pumping  and treatment system Is considered an interim measure to
control contamination migrating from the landfill  until  such time  as other
remedial actions, principally the cap, have demonstrated their effectiveness
at reducing the groundwater contamination.   The pumping and treatment can be
discontinued when one year of groundwater  monitoring indicates that
groundwater does  not exceed the MCLs at the point of compliance for the
contaminants of concern,  without running the pump and  treat system.  The
pumping and treatment system cannot be dismantled for  an additional five years
after monitoring  indicates it can be discontinued.

     The contaminated groundwater plume that is downgradient from the landfill
boundary will not be extracted and treated and will be mitigated through
natural attenuation (flushing action).

     The EPA review of the FS report recommended that  an interim pumping and
treatment system be designed and constructed so that the groundwater meets
                                       53

-------
 standards at the point of compliance.  The decision  to  include pump  and  treat
 as a remedial action is an addition to the recommendation  in  the  city  prepared
 Feasibi11ty Study.  The rationale used to arrive at  this recommendation  is
 summarized below:

     1.   The landfill cap cannot be completed until  1992  after  the  existing
          refuse units are closed.

     2.   The effectiveness of the cap in reducing the  contaminant loadings to
          the aquifer has a lag time from 5 to 10 years (FS estimate)  before
          the aquifer will show lower levels of contaminants.

     3.   Once the cap is effective in reducing the  contaminant  loadings (5-10
          years), it will take additional time for the  contaminant levels to
          fall below the drinking water MCL levels.

     4.   The citizens supported the EPA recommended pumping and  treatment
          system because it will get the cleanup started and not  further delay
          aquifer protection.

     5.   The Installation of the pumping and treatment system will  start
          groundwater remediation which could otherwise be delayed If  closure
          and capping schedules slip due to delays in the  startup of the
          waste-to-energy disposal facility.

     6.   The active system will also allow time for further, definitive
          studies on the Old Burn Unit, which may not be contributing  to to
          the groundwater contamination problems and could therefore receive
          an MFS variance.  A change In the closure  requirements for this area
          could result In a cost savings for capping.

     The pumping and treatment system described above Is similar to the
feasibility study alternative Identified as partial plume capture.  The
partial plume capture pump and treat system was not recommended by the city.

     EPA's conclusion is that the interim pumping and treatment system could
provide positive remedial action on a faster schedule, with more control, meet
the needs for treatment where practical, and be more protective of human
health and the environment without disproportionately higher costs.  As soon
as other remedial measures,  specifically the cap, become effective in
consistently lowering the contaminant levels to below MCLs at the point of
compliance, then the pumping system can be evaluated for shutdown.

Monitoring the Groundwater

     A groundwater monitoring plan for long-term monitoring of the aquifer,
domestic water supply wells, contaminant plume, and performance of the
extraction well  system must be submitted for approval as a part of the
remedial  design.  Until  the long-term monitoring plan is approved by EPA, the
City of Spokane is currently conducting quarterly monitoring of the existing
monitoring wells and the 11  established domestic residential wells.  The
long-term monitoring program may require construction of new monitoring wells.
                                       54

-------
Providing Alternative Water    •

     The City of Spokane has continued to provide a source of potable water  to
those residences whose domestic wells have been contaminated or become
contaminated above drinking water standards by the Northside Landfill.   The
alternative water source must continue until the aquifer contamination  is
reduced to the cleanup levels.

     Any private wells currently in use that are adversely impacted by  any of
the remedial actions may be eligible for supplemental  alternative water.  The
pump and treat system may alter the usefulness of several wells, requiring
their replacement or alternative supplies.  The city Is currently providing
alternative water by extending the municipal water supply system.   This  system
Is currently meeting the requirements for potable, domestic use water.

Enacting Administrative Restrictions

     Administrative restrictions or institutional  controls need to be enacted
which will protect the landfill cap, monitoring wells, and the pumping and
treatment system.  Restrictions should be placed on the construction of  new
wells and the use of existing wells In the contaminated plume.   These actions
must be part of the planning for Implementation of the remedial  action.

Controlling Landfill Gas Emissions

     The gas emissions from the landfill  have to be actively controlled  to
prevent offslte migration according to MFS requirements.  This  action must be
integrated into the closure plan and capping actions.
                                       55

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                          STATUTORY DETERiMINATIONS


     The selected remedy meets statutory requirements of Section  121 of
CERCLA, as amended by SARA, and to the extent practicable,  the National
Contingency 'Plan.  The evaluation criteria are discussed below:

Protection of Human Health and the Environment

     The selected remedy will protect human health and the  environment by
reducing the amount of contamination 1n the groundwater, reducing the exposure
routes by capping the landfill, and providing alternative water.  The major
exposure route Is ingestion of contaminated groundwater, with several minor
secondary routes through air and direct contact.

     The remedy reduces the exposure to contaminated groundwater during both
the short term and the long term.  Short-term controls include:

     1.   Alternative water supplies to those with contaminated wells;

     2.   Construction of a pumping and treatment system to reduce
          contamination levels to drinking water standards  and control offsUe
          migration; and

     3.   Placing a cap over the refuse units.

Short-term exposure will  be reduced by preventing direct contact and
uncontrolled air emissions.  Long-term control is provided  by the cap, which
reduces the leachate loading Into the aquifer by controlling the source.
Administrative restrictions will  be effective in keeping the long-term
exposure low by protecting the cap and monitoring wells system and controlling
use of .wells 1n the contaminated portions of the aquifer, until the aquifer
remediation Is complete.

     The pumping and treatment system will  be designed to reduce the toxicity,
and volume of the contaminants in the groundwater.   Nearby residents affected
by contaminated groundwater, or by the action of the pumping and treatment
system, will receive alternative water supplies.  The City of Spokane has
extended its municipal  water system into the area and is supplying potable
water to those residences which have contamination in excess of MCLs in their
wells.
                       m
     No exposure problems are expected during construction of any of the
remedial  actions.  Workers and residences can be protected by compliance with
adequate health and safety- plans and health and safety monitoring.  None of
the activities proposed involves direct contact with acute hazards.


Attainment of ARARs
     The selected remedial action also meets all applicable or relevant and
appropriate requirements (ARARs) that have been identified.  No waiver of any
ARAR is being invoked for the selected remedy.  The major ARARs are briefly
described below.
                                       56

-------
     The  laws  and regulations'of  concern  Include  but  are  not limited to the
following:

     1.    Resource Conservation and  Recovery Act  (RCRA; 42  U.S.C.  §6901),  RCRA
          regulations  (40  CFR  261-280), Washington  State  Dangerous Waste
          Regulations  (WAC 173-303 and 70.105  RCW), and Washington State
          Minimal  Functional Standards for Solid  Waste Handling  (WAC 173-304
          and  70.95 RCW).

          Landfill  closure requirements of RCRA and Washington State Dangerous
          Waste  Regulations will  be  attained by Installation of  the  landfill
          cap  to minimize  leachate production, and operation of  the
          groundwater  extraction  wells to remove  contaminated groundwater.
          The  selected remedy  prevents further spread of  groundwater
          contamination.   Closure of the Northside  Landfill  to State Minimum
          Functional Standards will  be evaluated  to ensure  consistency  with
          RCRA landfill  closure standards.

          The  technology applicable  for the landfill must meet the Washington
          state  standards  for  ongoing landfill operations,  closure,  capping,
          leachate  containment, and  methane control.  A variance for disposal
          in a lined unit  with leachate treatment is scheduled to  be issued,
          allowing  disposal in the existing refuse unit until December  31,
          1991.   Other substantive MFS requirements must  still be  met.

     2.    Rules  and Regulations of the State Board of Health Regarding  Public
          Water  Systems  (WAC 248-54).

          The  alternative  drinking water supply currently in use is  a
          municipal  system which  is  in conformance with these regulations.

     3.    Model  Toxics Control Act (Initiative 97).

          This is  the  state's  operative hazardous waste cleanup  law.
          Regulations  under this  law are pending  promulgation.

     4.    Safe Drinking  Water  Act (42 USC 300), and Primary  Drinking Water
          Standards (40  CFR 141).

         Groundwater  will  meet MCLs, the appropriate health-based standards,
          as the  contaminated  plume  is extracted  and leachate generation is
         minimized.   The  selected remedy will prevent exposing  the  public  to
          contaminated drinking water by monitoring residential wells and
          connecting an  alternative  supply when conditions  require it.
          Therefore, by  monitoring,  providing an  alternate  drinking  water
          supply,  and  restricting groundwater use, until  the aquifer no longer
         exceeds  drinking water  levels in the area, the  selected  remedy will
         meet the  requirements of these regulations.

     5.   Clean Air Act  (72 USC 7401).

          If an  airstripping system  is used, concentrations  of contaminants in
          the  airstripper  emissions  will be required to meet the requirements
         of the  Clean Air Act.   Flares for the methane gas  extraction  system
         must also meet the requirements of the  Clean Air  Act.
                                      57

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     6.   Clean Water Act (33-USC  1251).  .

          The selected remedy treats the extracted water to meet MCLs,
          health-based standards, or Water Quality Criteria prior  to
          discharge, whichever is  lower.  Therefore, there will be no adverse
          impact .on surface waters resulting from discharge of treated
          groundwater, and requirements of these regulations will  be attained.

     Offsite Regulations

          There are actions which will occur offsite which require compliance
          with all laws and regulations.  Such actions include storm drainage
          and discharge of treated water to the Spokane River.  These
          discharges will be subject to the National Pollution Discharge
          Elimination System (NPDES) effluent limits, pursuant to  NPDES (40
          CFR 122), NPDES Permit Program (WAC 173-220), and Water  Pollution
          Control Act (RCW 90-48), as a minimum.

Cost Effectiveness

     The cost effectiveness of each remedial  alternative was evaluated.
Closing and capping the landfill  according to the State ARAR (Minimum
Functional Standards) represents the most expensive part of the selected
remedial action, approximately $30 million.  However, this remedy also
represents the least expensive way to provide long-term source control.  The
excavation and disposal  and/or treatment of certain landfill waste units did
not represent a significant cost benefit over capping.

     The construction of a partial plume extraction and treatment system for
mitigation of groundwater contamination 1s the best technical  solution for
treating contaminants in the groundwater for  these specific site conditions.
The partial  plume system is as equally protective as the total  plume capture
systems at substantially lower cost.

     The specific cap material and the groundwater treatment system are not
specified to allow for analysis during the design phase.   The  costs of the
pumping and treatment system may vary greatly depending on how the system is
designed to meet the performance criteria.

Utilization of Permanent Solutions and Alternative Treatment Technologies

     Alternative treatment technologies were  generally  considered unfeasible
for the refuse area of the landfill, because  of the size of the source (345
acres containing over 5 million cubic yards of waste materials).   Many of the
other alternative technologies are not yet proven for municipal landfill
leachate and were estimated to be more expensive for the same  level of
treatment achieved by less costly alternatives.

     Permanent treatment, along with alternative or resource recovery
technologies,  was Included in the initial  screening of  remedial action
technologies.   Several  treatment technologies passed the initial  screening for
the Skimmings  Unit (a small  part of the landfill).   Based on the cost
effectiveness  analysis,  these treatment technologies were not selected.  The
costs for alternative treatment technologies  for the skimmings area were
considered disproportionately high compared to the cap, which was determined
to be protective of human health and the environment.
                                       58

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     Treatment was selected to mitigate the groundwater contamination
problems.  Treatment of the extracted water will be designed to reduce the
contaminant loading and prevent their re-entry Into either the groundwater or
Into the surface water discharge.   The final  treatment technology has not been
specified but will be selected from those conceptually identified in the FS
during the design phase based on performance  criteria.

Land Disposal  Restrictions

     The selected remedy does not  require placement of RCRA hazardous wastes
either on or offslte.  Therefore,  the Land Disposal Restrictions do not apply.

Preference for Treatment as a Principal  Element

     Treatment is the selected remedy to mitigate the aquifer contamination.
Ingestion of the contaminated water is considered the primary route of human
exposure.

     Treatment technologies were evaluated for the landfill  source but were
not selected.   Several  factors make treatment  unfeasible  or  too expensive for
the landfill  units:

     1.    The  size and  volume of the  landfill  wastes would make excavation  and
          treatment  difficult, expensive,  and  possibly hazardous  to workers
          onsite.

     2.    Alternative treatment technologies for effective onsite  treatment  of
          landfill wastes  are still experimental  for the  contaminants of
          concern.  The costs  were  significantly and disproportionately higher
          for  the reduction in risk.

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                                  CONCLUSION

     An extensive evaluation of the Northside Landfill site has resulted in
the identification of the problem (chlorinated organic, industrial solvents)
and proposed solutions.  The exposure to the community has been controlled in
the interim with the installation of the municipal water supply.  The costs of
the remedial actions are mostly for the closure and capping of the landfill
which are required under state law.

     The selected remedy 1s expected to control  the migration of contaminants
offsite, to reduce the contaminant loading rate to the environment, and to
protect public health and the environment.  The result of the remedial actions
will  be to return the contaminated part of the aquifer back to its
availability as a drinking water supply, to safely contain the material
disposed of at the Northside Landfill,  and fully comply with ARARs.

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          APPENDICES
      RECORD OF DECISION
      NXTHSIDE LANDFILL
           IE,
Appendix A:  Responsiveness Summary

Appendix B:  Administrative Record Index

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                                                            Appendix A


                NORTHSIDE LANDFILL RESPONSIVENESS SUMMARY
Overview
     Northslde (North) Landfill  is an operating municipal  solid waste facility
in Spokane, Washington.  The site is located on a 345 acre parcel  between Nine
Mile Road and the bluff of Five  Mile Prairie.

     In 1981, the City of Spokane began an Investigation which identified
contaminated groundwater migrating off site and contaminated drinking water
wells In the area.  In 1983, Spokane extended city water to those  homes with
contaminated wells and later to  the entire area northwest  of the landfill.

     In October 1984,  the Northside Landfill  was added to  the National
Priorities List (NPL)  because of contamination of groundwater.  The NPL is  a
list of hazardous waste sites across the nation designated for study, and if
necessary, cleanup under the Federal Superfund Program.

     As owner and operator of the landfill, the City of Spokane was identified
as a potentially responsible party (PRP) and considered liable for
Investigation and cleanup costs.  In 1986 Spokane began work on the Remedial
Investigation/Feasibility Study  (RI/FS) which 1s a comprehensive study of site
conditions, hazards,  possible exposure pathways, and cleanup alternatives.
Initially, the Washington Department of Ecology (Ecology)  was responsible for
overseeing the work at this site.

     In order to identify community concerns  about the site,  community
interviews were conducted in August 1987.  Based on those  Interviews, a
Community Relations Plan was developed which  was published in November  1987.

     On March 16, 1988, the U.S. Environmental  Protection  Agency (EPA)  and
Spokane signed an agreement called a Consent  Order to complete the RI/FS  and
oversight of the work  returned to EPA.   Shortly after that the Community
Relations Plan was was revised by EPA to reflect new information.   The  final
RI/FS report was made  available  for public review in March 1989.

     EPA's preferred  alternative,which was presented in  the  proposed  plan fact
sheet,  dated February  28, 1989,  is different  from the recommended  plan  in the
Feasibility Study prepared by Spokane.   The difference is  that EPA's  preferred
alternative calls for  Installation of a treatment system which pumps  and
treats  contaminated groundwater  as part of the initial  remedy, whereas  Spokane
preferred additional monitoring  prior to installing a pump and treat  system.

     This document Includes a summary of comments and concerns raised during
the comment period held from March 1 to March 31, 1989,  and  a brief
description of community background and Involvement.

     The comments received from  citizens generally support EPA's preferred
alternative.  Some concerns were expressed about how the construction of  the
pump and treat system  will affect the community, the cost  of the system,  and
the health risks.  Spokane and other local officials expressed their  belief
that immediate pump and treat will not be a cost-effective use of  public  funds.
                                      A-l

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Background on Community Involvement and Concerns

     The community living next to the landfill has been active sines 1976 and
in 1981 formed the Pinemeadows Homeowners Association to work on closing the
Northside Landfill.

     The community interviews conducted by EPA in 1987, revealed the following
community concerns about the Northside Landfill:

          Citizens are concerned that the aquifer will never be cleaned up.

          Citizens were also concerned about the  operation of the landfill;
          problems Included Illegal  dumping, odors,  failure of the buffer
          zone, and  landfill height.

          Homeowners who received alternative water  supplies from the city
          expressed  concern that the  costs will Increase making it
          unaffordable to irrigate their property.

          Citizens were also concerned that the landfill cleanup may have
          adverse economic impacts on their property values.  They were also
          concerned  that garbage rates will Increase.

Summary of Comments Received

     Comments and questions raised during the Northside Landfill  public
comment period on the proposed plan  are summarized below and are grouped by
category.   EPA received 23 letters from the public during the comment period.

     As part of comment period,  a public meeting  was held on March 15,  1989,
at the Spokane City  Council Chambers.   About SO people attended this meeting
and 10 people gave public comment.  The meeting consisted of a presentation by
EPA,  and D^M Hill (Spokane's contractors), followed by a question and
answer period.

     Questions Included the timing for installing the  pump and treatment
system,  the cost, the cap, and health concerns.  Copies of the transcript are
available  at the Spokane Public  Library, Downtown Branch,  and the  City  of
Spokane Engineering  Services Library  in the Municipal  Building.


                           RESPONSIVENESS SUMMARY

Preferred Alternative

     The following reflects the  citizens'  or agencies'  comments which support
EPA's preferred alternative for  cleanup of Northside Landfill.  In addition,
eight citizens wrote letters of  support with no comments or concerns expressed.
                                      A-2

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 1.   The Washington Department of Ecology favors immediate pump and treat as one of
 the first  measures at the site as it provides an interim solution to controlling
 contamination until the cap becomes effective and the landfill is closed.

 Response:  Support for  the proposed pump and  treat option is  noted.

 2.   One citizen spoke in favor of the preferred plan and urged more stringent
 administrative restrictions.
                                    -<

 Response:  Administrative  restrictions or institutional  controls are designed
 to protect public  health and  the environment  and must  also  protect any
 remedial action.   Restrictions  to protect the pump and treat  systems will be
 required.  A typical  administrative restriction would  be  to prohibit the use
 of any private well  which  would  reduce the effectiveness  of the barrier wells
 placed as part of  the pump and  treat system.  Other possible  administrative
 restrictions that will  be  evaluated are whether the construction of  new wells
 in the contaminated  plume,  or reuse of wells already in the plume,  can be
 allowed.  After the  cap  is  in place, use of the landfill  property  will  need to
 be restricted to protect the  integrity of the cap.

 3.   Several citizens wrote to support the proposed alternative but did not want any
 more disruption to their lives with more pollution, noise or undue construction.  The
 concern was that the pump and treat system be designed and installed where it will have
 the least  impact on the neighboring community.

 Response:  The construction plan will  not be ready for  some time;  however,
 impacts  on the community are  a part of the plan review.   Some  noise  and
 disruption during a  construction activity is expected,  but  efforts will  be
 made to  reduce its impact  on  the neighborhood.  Long term impacts,  such as
 noise or building  location, can  be  controlled during design and is an  element
 considered in the review and  approval  process.

 4.   A local attorney wrote to express support for pump and treat  because of Spokane's
 repeated  failures to comply with environmental regulations.

 Response:  The suggested failures of the City of Spokane  to comply with
 environmental regulations  Is  beyond the scope of evaluation for this study.
 We were  not aware of  any environmental regulations that Spokane was  violating
 by conducting the study phase of this  project.

 5.   Another citizen wrote to support the  preferred alternative because cost of pump
and treat in the future will be even more and would come on the heels of costs associated
with the incinerator.
                        m
 Response:  Costs for  construction have typically Increased  with time.   It
would be expected that  the  pump  and treat system would  cost more if
 construction 1s delayed.   The money for the closure and remedial actions  at
 Northslde will probably come from several  sources.  Cities  generally issue
                                       A-3

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revenue bonds for major construction projects.   Because  the  Incinerator Is to
replace some landfill operations In the city and  county,  some  of the revenue
obtained by selling the incinerator bonds is projected for use on Northside's
closure.  It is expected that the city will also  obtain  money  from other
sources.  EPA does not direct responsible parties  in  their choice of funding
mechanisms for Superfund work.

     The following comments were written to express disagreement with EPA's
preferred alternative for cleanup at Northside Landfill.

1.   City of Spokane doesn't agree with that part of the preferred alternative involving
the pump and treat system. They advocate that a five year monitoring period before
installing the pump and treat system would be more cost effective. The City of Spokane
believes undue secondary impacts will occur if pump and treat system goes into effect.
The construction of the towers and pump and treat system will be noisy, and unsightly.
Spokane is also concerned that air contamination and surface water contamination will
occur because of releases from the stripping towers and discharge from the treatment
Response:  The five year wait before Installing any pump and  treatment  system
is based on the assumption that the cap will have an Immediate  and  measurable
effect on reducing the amount of contamination reaching the aquifer.  If a
reduction In the concentration of contamination in the aquifer  would  not occur
within five years (3 years after capping), the pump and treat system  under the
City's proposal would still need to be installed.  By beginning the design and
implementation of the pump and treat system now, the system would be
operational earlier and may cost less depending on Inflation  and plume
migration.

     After the pump and treatment system is In operation, reduction of  the
contamination 1n the aquifer leaving the landfill can begin.  The pump  and
treat system can reduce the contaminant loading thereby reducing the  size and
concentration of the plume off-site.

     One of EPA's objectives is to permanently reduce the toxlcity, volume,
and mobility of the contamination.   Groundwater Is currently  being
contaminated by the landfill to levels above the drinking water  standards.
This is considered an adverse effect on the groundwater and other potential
receptors of the groundwater, and is prohibited under state and  federal
regulations.  Capping can reduce mobility, but only treatment will  permanently
extract the contaminants of concern from this site.  A second objective is to
restore drinking water aquifers that are affected.  The Spokane Valley
Rathdrum Prairie Aquifer Is a sole source drinking water aquifer.   Our
evaluation Indicates that there is a high probability that the  contaminated
portion of the aquifer can be restored to meet drinking water standards.

     Construction will create some temporary conditions such  as:  noise and
traffic, but proper planning can reduce any long term conditions to acceptable
levels.  Locations of above ground structures and the treatment  plant can be
placed In areas that reduce undesirable impacts.
                                       A-4

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     Air contamination will.occur  if.some  type  of air stripping is used to
treat the groundwater without any  secondary  adsorption system.   Other types of
treatment are possible.  With any  treatment  system,  any releases to the air
would have to be below any  health  based  standard  set for the contaminants of
concern.      .

     Discharges of surface  water from a  treatment system will  have to meet
water quality standards for its release.   Treatment  systems are available to
clean up the water to meet  health  and environmental  criteria.

     The purpose of pumping and treating the groundwater is to  reduce the
contamination leaving the landfill area, restoring the usefulness  of the
aquifer, and permanently reducing  the contaminants of concern.   The treatment
system and its dlscharge(s) are a  part of  the overall  permanent treatment
remedy for the site.  All parts of the treatment  system will  have  to meet
health based standards.

2.   Another citizen questioned the validity of  the cap because natural geologic
structures in the area will allow lateral movement of any water, still allowing water into
the site. This same citizen suggested we allow the natural forces to flush the
contaminants out of the site instead of capping and that the environmental impacts of
remedy could be worse than doing nothing. This citizen did suggest however that, if the
plume does not respond as he predicted, to begin implementing the pump and treat.

Response:  An evaluation of the lateral migration of water  from the Five Mile
Prairie entering the landfill  was  done as  part of the agency review of the
Feasibility Study.  The well logs  for the  locations  on the  bluff show quite
uniform material down to the first aquitard  layer.   The  clay aqultards were
found to be located at a lower elevation than the bottom of the refuse fill.
Therefore,  any horizontal movement of infiltration would be below  the level  of
the refuse.  If the groundwater does not move through the refuse,  1t will  only
contribute to the aquifer as flow  and would not contribute  to additional
contaminant loadings to the groundwater.

     Natural flushing action would allow contaminants  to enter  the environment
at an unacceptable rate.   This action could take decades because of the  size
of this landfill and the small  amount of rainfall which  generates  the
leachate.  Leachates would be generated for decades  rendering the  aquifer in
this area unusable.  Leachate leaving the  landfill totally  uncontrolled  is
contrary to current laws and regulations.

     Capping the landfill is considered to be a requirement of  the State under
the State Minimum Functional Standards for closure of a  landfill.   The
evaluation  in the Feasibfl ity Study suggests that capping is  the long term
solution to control the rate of contaminant release  into the  aquifer.
Currently that rate of contaminant release Is above  health  based
concentrations.
                                       A-5

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     Waiting before  installing  a pump and treat system would  only delay the
corrective action  needed  to provide direct controls to restore  the aquifer.
The  Feasibility Study  recommended installing the pump and  treat  system if
aquifer conditions didn't improve within five years.  .If,  the effects  of the
cap  did not demonstrate effectiveness during the five year period,  a pump and
treat system would be  required,  only adding to the delay in cleaning up the
aquifer.

3.   The Spokane County Health District recommends waiting until the cap has been in
place five years to determine if contamination was still stable or not growing.

Response:  See previous answer.

4.   Two state representatives wrote to express their concern for spending an additional
$4.1 million when health and environmental benefits were negligible.

Response:  The $4.1 .million cost estimate for the pump and treat  system
includes operation and maintenance  costs for 20 years.  With a pump  and treat
system in place, the containment of the  contamination may actually  present  a
cost savings in the overall  cleanup activities.  Also, If the cap  is as
effective as the City  represents,  the pump and treat system will  not need to
be operated for as long a  period of time.

Health Risks

1.   The City of Spokane states health risks at the site are minimal and the preferred
plan cannot be supported on the basis of protection of human health.

Response:  The risk analysis indicates that the health risks are  low if
organisms are  not exposed  to the contaminated aquifer.  EPA prefers  making
contaminated water safe to use again,  which 1s protective of human health and
the environment.  The  alternative  water  supplied by the City protects  human
receptors but  alternative  water  1s  considered a temporary measure to protect
public health, and does not correct the  problem.

2.   The Director of Spokane's Water and Hydroelectric Services wrote to say that "no
citizens living within the plume are using that water for household use." therefore, health
risks are low and the pump and treat system is unnecessary.

Response:  See previous answer.

3.   A citizen requested more information on long term health effects.

Response:  EPA's risk  analysis determined that both long and short term health
risks were very low.   The  Federal  Department of Health and  Human Services -
Agency for Toxic Substances and  Disease  Registry (ATSDR)  also did not
recommend any  long term health studies based on their Health Assessment of  the
site.  Local,  state and federal  health agencies can Initiate health  studies  at
any time together or independently, but  based upon the very low exposure
potential for  area residents at  or  near  the site,  they are  not now
recommending such a follow up.
                                       A-6

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 4.    A representative of Citizens for a Clean Environment wondered if bonds were
 being posted to protect the public health and welfare (uncertain if she meant at Northside
 or in relation to incinerator).

 Response:   EPA's  Superfund  Program  is.required to work with the PRP to protect
 the public  health  and  the environment.   This normally does not require that
 special bonds be  posted  to  protect  public health.  EPA will provide oversight
 on the remedial action work to  ensure that it complies with the laws  and
 approved plans.   If  conditions  change that require a change in the remedial
 action, this  will  be Immediately  evaluated.   Both EPA and the City have
 mechanisms  In place  to deal  with  emergencies and/or unanticipated changes  in a
 project.

 5.    A citizen supports delaying installation of pump/treat because risk is to low.

 Response:   The alternate  water  system that is in place is for the protection
 of human health.   However,  alternate water is not considered a permanent
 solution to the cause  of  the problem and it  Is not the only factor
 considered.   Currently there are  no administrative restrictions to prevent a
 new well from being  installed  in  the contaminated plume or protecting a well
 already in  use from  an unexpected plume shift.  Using a new well in the plume
 area  would  add a  level of risk  to those using the contaminated water.  Also
 see answers to Question  1 of this section.

 Cost

 1.   The City of Spokane states that the cost of pump and treat adds undue burden on
 taxpayers and is an unnecessary cost in conjunction with capping.

 Response:   The pump  and  treat system Is a cost for mitigating groundwater
 pollution problems originating  from the Northside Landfill.   The costs in the
 Feasibility Study  are  estimated costs  based  on projected remedial  actions.
 The cost of the pump and  treat  system is a part of the total  cost.  If the
 capping actions turn out  to be  adequately protective of the environment,  then
 the interim pump and treat  system can  be shut down.   If the pump and treat
 system contains the  plume,  It may save  citizens money 1n that they could  use
 their wells again  instead of purchasing water from the city.

 2.   A citizen asked how much of taxpayers money has been spent on the site to date.

 Response:  EPA has spent  an  estimated  $120,000 and the City of Spokane's  costs
 are estimated at $1 million.  Ecology has also expended costs at this site in
 excess of $13,000.   The .city of Spokane has  been doing the actual  field work.,
 such as installing the monitoring wells.  EPA's and  Ecology's costs are for
oversight of Spokane's work.  Money spent by EPA is  from the  federal
 Superfund. "The money  In  the Fund comes from taxes on chemical  manufacturing
 industries and federal  tax  sources.
                                       A-7

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3.   Another citizen questioned how the closure will affect garbage rates in the city.

Response:  EPA has  ho  way  of knowing  whether garbage rates will be affected  by
the  landfill closure.  Any such  decision  will  have to be made by  the city of
Spokane.

4.   What will be the actual  costs — are  all costs discounted to present costs?

Response:  Final costs cannot  be  calculated  until  final  design plans are
approved.  The Feasibility Study  includes cost estimates for the  various
alternatives.  These cost  estimates are further refined by projecting
operation and maintenance  costs over  the  next  20 to 30 years.  The projections
are  estimates for what It  will cost as  money Is required In the future.  These
projected future costs include Interest,  Inflation, and  other economic
factors.  Rather than  use  future  dollar costs  for  these  estimates, all future
costs use today's dollars  or present  worth.  The cost estimate for the
preferred plan is approximately $35 million.

5.   The City of Spokane Water and Hydroelectric Services Director wrote to say EPA
is requiring City to do- expensive cleanup on a "relatively minor" problem.

Response:  Sites which are placed on  the  National  Priorities List (NPL), are
known to present some  type of  threat  to public health or the environment and
are  not considered  minor problems by  EPA.  The state requirement to properly
close a landfill, thereby  controlling environmental releases applies to
Northslde and other landfills  In  the  state.  The actions necessary to
undertake these tasks  are  required of Spokane  whether or not the landfill  Is a
Superfund site.  The cost  of just the required cap for this closure is
estimated to be $25 million and represents about 80% of  the cost of the
proposed remedial action.   The decision to implement a pump and treat system
to mitigate a pollution problem and begin to restore a valuable drinking water
aquifer Is an Important aspect of'the final  site closure and remediation.

Environmental Risks

1.   The City of Spokane does not believe other environmental receptors are exposed or
will be exposed in the future,  therefore, pump and treat is not necessary because risks
don't exist.

Response:  Since the Installation of  the  municipal  water supply,  no specific
environmental receptors have been Identified.   However,  the environmental
risks are not the only factors In evaluating a remedial  action.   (See answer
on Page 6, Health Risks, Question 1).
                                       A-8

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Public Participation

1 .    A citizen expressed.concern that being expected to respond to the Feasibility Study
was unreasonable because it was too technical.  The commentor requested assistance on
this and future projects.

Response:  EPA has attempted to  keep  the  community actively involved in the
evaluation process through  fact  sheets  and informational  meetings because of
our concern over  the complexity  of this  study and the Superfund process.  In
addition, under the Superfund  Program,  Technical Assistance Grants (TAG)
recently became available to groups effected by Superfund sites.   For each
site  on the NPL a TAG of up to $50,000  1s  available for use by community
groups to hire a  technical  advisor to help them understand  the Superfund
process and to aid them  in  commenting on  technical  documents relating to the
site.   •

      An information package on applying for a Technical Assistance Grant is
available at the Spokane Public  Library,  Downtown Branch, as well as the City
of Spokane Engineering Services  Library  in the Municipal  Building.   You can
also  contact EPA's Technical Assistance Grants Coordinator, Dwlght Davis,  in
Seattle at (206) 442-0603.

      EPA and Ecology have conducted many  activities throughout the project in
order to keep the community Informed.  A  11st of these activities can be found
on page 12 of this document.

Landfill Gas

1.   A citizen suggested pumping the gas out of the landfill which should take care of
the volatile organics that are contaminating the groundwater.

Response:  The landfill will generate methane gas for a long time as the
biological degradation continues.  Controls for the collection and treatment
of the methane will  provide conduits  for  the other  volatile gasses  to escape
the landfill.  Vapor extraction  was considered In the Feasibility Study
evaluation and reviews, and it was determined that  very little reduction in
the pollutant loadings could be  accomplished in this manner.   Vapor extraction
will  occur as a passive part of  the gas control  system and  is  expected  to help
control  off-site migration.  The  landfill  cap will  also be  designed to  reduce
the movement of volatiles into the soils.

Other
                         m
1.   Will the pump/treat system reduce well yields in areas outside the plume?

Response:  The Spokane Valley  Rathdrum Prairie Aquifer is a very  productive
aquifer,  therefore,  reduction  In  well yields Is not expected.   The conceptual
design in the Feasibility Study  uses  pumping rates  that probably  would  not
                                       A-9

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have any reduced  yield  effect on any private wells.  A  few  private  wells may
have pumping  restrictions  placed on them to prevent  their reducing  the
efficiency of the operation of the pump and treat system, but  these wells
would have, to be  located  close to the extraction system and  currently are no
used.
2.   Several citizens have concerns over the water rates and volume of water received
since they haven't been able to use their wells, have had to purchase city water, and the
volume of provided water has been less than they want. They are concerned that after
their contract expires they will have to pay more for city water then it would cost them
to use their own wells. They believe the water problem isn't theirs so they shouldn't be
penalized. What can be done to help them continue to receive water at a reasonable rate
until they can use their wells again.

Response:  A purpose of  the remediation effort is to restore the  usefulness  of
the  aquifer that  has been Impacted.   If this  takes longer than the  remaining
five years of contracted water. It Is  up to the city to negotiate another
agreement.  Alternative  water  is  Included In  the remedy because some  private
supplies  have been adversely  Impacted  by the  groundwater contamination.
Pumping  Is designed  to restore  the aquifer for all  uses.  Once restored  then
homeowners can evaluate  the best  system for their water supply.

3.   A citizen from Citizens for Clean Air asked;  Will the same problems occur at the
ash landfill for the incinerator? Also, what is being done to recycle or reprocess items in
the waste stream to prevent further pollution?  She also asked: How is this affecting
property values; Are bonds  being posted to cover periodic testing of incinerator for 50  -
75 pollutants? Would a plastic cap really work when gophers  abound  in the area?

Response:  The design  of a  new  ash landfill will  be required to follow state
solid waste regulations  which have been established to control  all
environmental Impacts.   Recycling 1s an Issue beyond the design of  corrective
actions at the Northside Landfill.

     The  Feasibility Study  did  not address the Impact on property .values since
this Is not part of  the  Superfund remedial  action.   After the remedial actions
have been taken,  then  the county  may evaluate property values if there are
long term Impacts on them.

     The  Northside Landfill  1s  not a part of  the incinerator project.  This
effort Is to close this  landfill  and use other alternatives for solid waste
management.  If any ash  from the  Incinerator  does get disposed of at Northside
Landfill, it will have to be in an area that  meets  all the new requirements
for disposing that kind  of  waste.

     The  use of a plastic membrane as  part of the landfill  cap will have to  be
designed  to withstand  the effects of the local environment.  Membrane caps
have been used effectively  In many different  situations Including areas where
burrowing animals live.
                                       A-10

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4.   Another citizen wrote that the proposed Incinerator should be moved downwind of
Spokane, not upwind as scheduled.

Response:  The  location  of  the  incinerator is beyond the scope of this
project.  This  comment has  been  directed to the city/county waste energy
office.

5.   How long will the cap last?

Response:  The  cap  will  be  designed  as  a permanent closure action.  For cost
projections a 30 year period  Is  utilized.  The integrity of the cap will
require  periodic evaluation and  will  require annual  maintenance.   Most
projections for remedies do not  extend  beyond 30 years, but if the design is
proper,  the cap will remain effective beyond the 30 year design period.

6.   A citizen asked, what government body is responsible for making Northside Landfill
a Superfund site, and how do the problems at the site compare to a privately owned
landfill. She also asked if the problems at Northside were increased by government
negligence or inaction.

Response:  The U.S. Environmental  Protection Agency is the agency responsible
for designating Superfund sites  and  placed the Northside Landfill on the
National Priorities List.   This  designation 1s applicable to sites whether
they are publicly or privately owned.

     There are certain kinds of  environmental  problems associated with
landfills regardless of ownership.   The impact of a particular problem such as
leachate may be a greater problem  at  one site when compared to another because
of specific site conditions.

     EPA does not believe that government actions have contributed to the
problems at the landfill.   Activities to date have been focused on identifying
the problems.  Actions will now  begin to focus on remedies to those  problems.

7.   How much garbage is being dumped at  the site?

Response:  The dty has estimated  the average amount of refuse dumped per day
is 500-600 tons.

8.   Homes between the plume boundaries and the Spokane River are still on private
wells. These homes should receive public water to reduce any risks of exposure that could
occur.
                        »
Response:  All of the homes that are  near the plume  or that may be impacted by
the plume have access to alternate water.  If the plume should shift
additional areas may need to be  supplied; however, pumping should reduce this
risk.  There 1s no  reason to supply municipal  water  to residences that are not
impacted by the site.  Well monitoring  will  determine if any changes occur in
the size or location of the plume.
                                       A-ll

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                     COMMUNITY RELATIONS ACTIVITIES AT
                             NORTHSIDE LANDFILL


     Community relations  activities  conducted  at  the  Northside  Landfill  to
date have  included:                    '             .     .

          March 1985 —  Ecology took lead responsibility  for  site  including
          community  relations.

          August 1987 —  Community interviews  were  done by  EPA  and  the
          contractor for  Draft  Revised Community  Relations  Plan.

          November  1987 —  Draft Revised  Community  Relations  plan  submitted to
       .   EPA  by the contractor.

          May  12,  1988 — Fact  Sheet was  distributed  announcing a  consent
          order between  EPA and Spokane  to complete the Remedial Investigation.

          September  1, 1988 —  An EPA Fact Sheet  was  distributed announcing a
          public meeting  on RI  results and to  provide a written overview of
          results.

          September  15,  1988 — EPA  held  Public Information Meeting on RI
          results.   Three people attended.

          February 28, 1989 —  EPA distributed a  Fact Sheet on  proposed plan
          and  announced public  meeting on  March 15, 1989.

          February 28, 2989 —  EPA put a  paid  advertisement In  Spokesman
          Review on  public  meeting.

          March 15,  1989  — EPA held a public  meeting on  the  proposed plan.
          Approximately 45  people attended and 10 people  gave oral comments.
          A  transcript of this  meeting Is  available at the Spokane Public
          Library and the Engineering Services Library In City  Hall.

          March 1-31,  1989 — Public comment period held on proposed plan.
          EPA  received 23 letters during  the public comment period.
                                     A-12

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                                         Appendix B
U.S. ENVIRONMENTAL PROTECTION AGENCY
              REGION  10
          1200 Sixth  Avenue
     Seattle, Washington   98101
     ADMINISTRATIVE RECORD INDEX

                 for

         NORTHSIDE LANDFILL

         Spokane,  Washington
            July  6,  1989
                B-l

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INDEX TO MINIM SI RAT IVE  RECORD FOR NORTHSIOE LANDFILL
                                                                                                                                          ..LJLUJ^^hU
Jj	Preliminary Assessment Report

00000001.      Preliminary
              assessment report

00000002.      Preliminary
              assessment report

00000003.      Preliminary
              assessment report
00000001.
Preliminary
assessment report
UOUOUOOb.     Preliminary
              assessment report
                       Preliminary assessment form
                       Tentative disposition form
                       Preliminary assessment summary
Preliminary site inspection report
                       Disposition  lorm
                                              5/80        2       Neil Thompson, EPA
                                              7/80        I       Neil Thompson. EPA
                                              8/22/84     5       EPA
1/18/85    37       Thomas A. Tobin, Ecology ft    John Osborn.EPA
                    Environment

4/2/85      2       Robert Kiev, EPA
^.	Site Investigation Reports
0000000(<.
Site investigation
rpports
00000007.     Site investigation
              reports

00000008.     Site investigation
              reports

0000000').     Site investigation
              reports
Site inspection report
                        Hazardous  waste  sites  evaluation of
                        t)3)l-cleanup  repuirements

                        Potential  hazardous  waste  site
                        inspection, memo

                        Sample analysis  review
                                                                                    5/6/80      8       Jim Hileman.  EPA
                                                                                    8/1/80      2       J.  C.  Willman,  EPA
                                              8/1/80      4        James  Hileman,  EPA
                                              8/8/80
                    C. Wilson
                                                                            CM
                                                                            PO
                                                  John Barich
 3.  NPL  Listing and Comments

 00000010.      National  Priorities    The Site Itself,  physical  data and
               listing  and  comments   maps
 Q0c.#	       f i 1 e	Type/Description	
                                                                      4/3/84      6       James Maurn, Jim Oberland,
                                                                                          both authors
                                                                      Date    tf Pages       Author/Organization      Addressee/Organ! zat i on

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00000011.     National Priorities
              listing and comments

00000070.     NPl Iisi ing and
              Comments

00000080.     NI'L Listing and
              comments
OOUOU082.     NI'L  listing  and
              comments
 00000083.     HPL listing  and
r             comments
Letter re proposed action on Northside        8/16/84     2
Landfill

Summary of comments and response              No date     4
Letter re request for removal  of the          11/20/84    3
Northside Landfill  from the proposed
national priorities list

Federal Register, Vol. 49, No. 200.           10/15/84   :n
pp. 40320-40352.   Proposed Rule,
NPL listing

Federal Register, Vo. 51, No.  Ill,            6/10/86    45
pp. 21054-21098.   NPl Listing.
final rule and proposed rule
                                                                  Kathy H. Davidson, EPA
                                                                                                                                     Ken  Bock,  WA Planning &
                                                                                                                                     Community  At fairs Agency
                                                                  Terry  L. Novak, City of
                                                                  Spokane, C.  Scott  Parrish.  EPA
                                                                  lerry  L.  Novak,  City  of
                                                                  Spokane
                                                                  EPA
                                                                  EPA
                                                                                                                                     Russ Wyer,  EPA
 4,.	Slale/PRP Cooperative  Agreements
 0000001.?.      State/PRP  Cooperative  Agreement  between  WA  Dept.  of
               Agreements '            Ecology  and  City of Spokane,

 nnOOOO(!X.'     State/PRP  Cooperative  Agreement  hetween  City  of  Spokane
               Agreements             and WOOE related to CH2H Hill
                                      Landfill Monitoring Study
                                              2/11/86
                                              3/14/86
                                                         lOp.
                                                                                                       Terry L.  Novak,  City of
                                                                                                       Spokane

                                                                                                       Marilyn 3.  Montgomery
                                                                                                       City of Spokane
                                                                                                                                     John D. Littler, WA St.
                                                                                                                                     Dept. of Ecology

                                                                                                                                     Frank Gardner
                                                                                                                                     WDOE
5.  Mult-Site Cooperative  Agreements
00000013.     Hulli-site coopera-
              tive agreements

00000014.     Multi-site coopera-
              t ive agreements
      	;..[ iie	
00000015.     Multi-site coopera-
              tive agreements
                                      Letter re proposed  action on Northside
                                      landfill
                                              8/16/84
                                                                                    10/22/84    11
                                                                  Kathy M.  Davidson,  EPA
                                                                  WDOE
                                                                                                                                     Ken Bock,  WA Planning &
                                                                                                                                     Community  Affairs  Agency

                                                                                                                                     EPA
Federal Assistance Application Form
with "project narrative statements,  budget
breakdown,  forward planning activities,  letter from Attorney General  Office regarding Cooperative Agreement  between US
EPA and Stale
                                               !YDe/Desctiotion
                                      Letter regarding cooperative agreement
                                      between US EPA and Stale
                                              Date    tt Pages
                                              2/27/85     4
                                                                    Author/Organization      Addressee/Organization
                                                                  Charles B.  Roe and Charles    Andrea Beatty  Riniker,
                                                                  K. Oowtliwrtile. Office oF      DOE
                                                                  the Attorne-y General

-------
 OOOOOOUi.      Multi-site coopera-    Letter will* attached amendment;  Federal        3/11/85    15       Lynda  Brothers.  WOOE
               live agreements
                       Assistance Application; project
                       narrative statement
 00000017.      Multi-site coopera-    Letter regarding finalization of
 00000016.
 00000010.
               t ive  agreements
Multi-site coopera-
tive agreements

Multi-site coopera-
tive agreements
statements of work for the Northside
and Greenacres 1-andfills

Memo re Superfund cooperative agreement
No. V-000283-01

Letter with attached amendments;
Federal assistance application form;
statement of work; agreement between
WDOE and City of Spokane
'00000020.
 OOUOUOiM.
Multi-site coopera-    Amendment to cooperative agreement
live agreements        No. V-000283-01
Multi-site coopera-
tive agreements
Statement of work, cost detail
 0.   Work  Plans/Assionments/Amendments
 00000022.
 000000^.
 00000025.
 OOOOOOB9.
 00000000
 uoomui'i i,
Work plans and
assignments

Work plans and
assignments

Work plans and
assignments

Work Plans and
assignments

Work Plans and
assignments
Work Plans and
assignments
Groundwater quality studies—
background and study approach

Forward planning report


Feasibility study work plans, drafts


feasibility study work plan
comments on feasibility
study work plan

	Type/Description
Draft CH2M Hill
Site Safety Plan
                                                                     4/16/85     2       Dan Sw'enson. WDOE
No date     3
8/2/88
                                                                                                                       Ernesla Barnes,  EPA
                                                                                                Neil  Thompson,  EPA
12/31/85    2       Kathryn M. Davidson, EPA      Oddvar K.  Aurdal,  EPA
                                                                                    1/16/86    16       John D.  Littler.  WDOE
WDOE
2/11/83     3       City of Spokane
3/85       38       Colder Associates
No date    13       City of Spokane
6/30/88    12       CH2H Hill
Dave Kargho
WDOE
                                                  Ernest Barnes. EPA
                                              2/21/86     2       Kathryn M.  Davidson,  EPA      Arv Aurdal.  EPA
                              WDOE
                              EPA
                              City of Spokane
Neil Thompson
EPA
Date    ti Pages       Author/Organization      Addressee/Organization
3/88       17 p     CH2MHill                      City of  Spokane

-------
Remedial invesliu.ation
00000021).

00000027.

0000002R.

00000029.

00000088.

[00000089.

00000090.

00000091.

00000092 ,


00000093.

8. Feasibi
00000030.
0000094.
Uoi*
Remedial
investigation report
Remedial
investigation report
Rpmpdial
investigation report
Remedial
investigation report
Remedial
Investigation report
Work Plans and
assignments
work Plans and
assignments
Work Plans and
assignments
State/PRP Coopera-
tive Agreements

Remedial Investi-
gation Report
lily Study
Feasibility study
Feasibility study
File
Water well reports, with attached maps
and graphs
Suggested test wells and map

Suggested test wells

Remedial investigation with appendices

Supplemental RI Addendum

feasibility study work plan

comments on feasibility
study work plan
draft CH2M Hill

Agreement between City of Spokane
and WDOE related to CH2M Hill Landfill
Monitoring Study
RI Final Report


Public comment on feasibility study
Uraf.t Feasibility Study
Type/Description
5/18/77 15 Dept. of Conservation &
Development
10/83 2 Unknown

11/83 1 Unknown

10/86 119 CH2M Hill

7/88 95p CII2M Mill

6/30/88 12 CH2MHill

8/2/88 2 Dave Kargbo
HUOE
3/88 17p CH2MH111

3/14/86 (Op Marilyn J. Montgomery
City of Spokane

11/88 34bp CH2H Hill


6/87 241 CH2M Hill
8/15/88 294p CH2M Hill
Patp "j^es A"thpr/0rgani*ation
WDOE





City of Spokane

City of Spokane

City of Spokane

Neil Thompson
EPA
City of Spokane

Frank Gardner
WDOE

City of Spokane


City of Spokane
City of Spokane
Addressee/Organisation
000009'..      Feasibility  study






 00000128.      Feasibility Study
Feasibility Study North Landfill
Feasibility  study public hearing
11/88      330p     CH2M Hill
                                                                                      03/15/89     3p         UDOE
City of Spokane

-------
'I-. .t
                  ;  ._R_i/JL5.
00000031.      (orrespondence         Letter re remedial investigation report
              rp remedial  investi-
              gation feasibility study

00000032.      Correspondence re      Letter re applicable or relevant and
              remedial  investiga-    appropriate requirements
              lion feas'ibility study

00000090.      Rl/fS correspondence   North Landfill Supplemental RI/FS
                                     Monitoring Well MW-W Relocation

10.   Comments - Rl/FJ

00000097.      Comments  - RI/FS       Review of Northside Landfill Rl/FS -
r                                    Risk Assessment
                                                                                   6/28/85
00000098.      Cnmmpiits -RI/FS
                                     Comments on Draft FS
                                                                                   1/26/88     7p
                                                                                    7/10/87    2
                    Terry Novak, City of
                    Spokane
                                                                                   5/22/87      1       Neil Thompson, EPA
                    James S. Correll
                    Ch2M Hill
                    Dana Davoli/EHA
00000099.      Comments - RI/FS       Response to 8/11/87 letter
8/11/87    6p       Peter Kmet
                    WOOF.

9/25/87    35p      Phil Williams
                              Russ Wyer. EPA
                                                  Fred Gardner, WDOE
                              Neil Thompson
                              EPA
                              Neil Thompson
                              EPA

                              Phil Williams
                              City ol Spokane

                              Peter Kent
00000100.     (nmmpnts - RI/FS
00000101.     Comments - RI/FS
                                     Preliminary comments on CH2M Hill's
                                     RI/FS proposal
                                     List of Technical  items  to consider
                                     before completing  RI/FS
11/23/87   6p
OOOUOI03.     Comments - RI/FS       DOE comments on Northside FS

IJO£"	MJfi	      	Type/Description	

00(100)0-1.     Comments -RI/FS        Letter  containing comments on RI
11/30/87   2p
00000102.     Comments - RI/FS       Letter containing Northside RI comments       8/7/88     5
                                                                                   9/8/88     8p

                                                                                   Date    if  Pages

                                                                                    10/17/88    19
Marsha Beery
EPA
Marsha Beery
WOOE

Neil Thompson
City of Spokane

Dave Kargbo
WDOE
  Author/Organization

Neil Thompson
EPA
   Jerry Neal
   Lukins and Annis
   Washington Trust
   Financial Center

   Phil Williams,
   City of Spokane

   Phil Williams
   City of Spokane

   Neil Thompson
   EPA
Addressee/Organization

   Phil H. Williams
   City of Spokane
                                                                                                                                                                (0
00000105.     Comments - Rl/FS       DOE  comments on Northside RI
                                                                                    10/17/88    3p        Have Kargi>o
                                                  Neil Thompson

-------
File
                         Type/Description
/mthor/Orqaniiatlon     Addressee/Organ! latIon
~ - - , ,
00000106.
00000129
00000130
00000131
00000132
' 00000133
00000134
00000135
00000136
00000137
00000138
00000139
OOOOOHO
00000 HI
00000142
Comnents
Comnents
Comments
Comnents
Comments
Comments
Comnents
Comments
Comnents
Comments
Comnents
Comments
•Comments
Comments
Comnents
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
Northside Landfill RI/FS - Response
to Agency Comnents on FS
Comments on results of RI/FS
Comments on results of RI/FS
Comnents on results of RI/FS
Comments on results of RI/FS
Comnents on results of RI/FS
Comments on results of RI/FS
Comments on results of RI/FS
Comments on results of RI/FS
Comments on results of RI/FS
Comments on results of RI/FS
Comments on results of RI/FS
Comments on results of RI/FS
Comnents on results of RI/FS
Comments on results of RI/FS
| 	 yci^v ^_
12/16/88
03/08/89
03/13/89
03/H/89
03/15/89
03/17/89
03/20/89
03/21/89
03/27/89
03/27/89
03/28/89
03/28/89
03/29/89
03/29/89
03/29/89
?r r o*jc j
54p
1P
IP
1p
1p
1p
1p
1p
2p
1p
1P
3P
2p
2p
1p
Phil Wit I alms
City of Spokane
Dennis K. Kroll
Spokane County
Health District
Nancy Bowen
Jean Silver
UA State Representative
John G. Bjork
City of Spokane
Shirley Rector
UA State Representative
Eric Cut birth
Allan A. Bonney
Attorney at Law
Mr. and Mrs. James Kirk
John G. Bjork
City of Spokane
Mary F. and John T.
Uhalen
Anita S. Messex
Janel and T.W. Dudley
City of Spokane
Phil H. Williams
Environmental Programs
Jerry Rounsvllle
Nell Thompson
EPA
Nell Thompson
EPA
Neil Thompson
EPA
Nell Thompson
EPA
Nell Thompson
EPA
Nell Thompson
EPA
Nell Thompson
EPA
Nell Thompson
EPA
Nell Thompson
EPA
Nell Thompson
EPA
Neil Thompson
EPA
Nell Thompson
EPA
Nell Thompson
EPA
Nell Thompson
EPA
Neil Thompson
EPA

-------
Doc*
Hte
                                           Type/Description
00000 U 3
OOOOOK4
OOOOOU5
OOOOOU6
OOOOOU7
e OOOOOU8
00000 U9
00000150
00000151
00000152
00000153
Comments
Comments
Comments
Comments
Comments
Comments
Comments
Comments
Comments
Comments
Comments
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
- RI/FS
• RI/FS
- RI/FS
• RI/FS
Comments
Comments
Comments
Comments
Comments
Comments
Consents
Comments
Comments
Comments
Comments
on results
on results
on results
on results
on results
on results
on results
on results
on results
on results
on results
of
of
of
of
of
of
of
of
of
of
of
RI/FS
RI/FS
RI/FS
RI/FS
RI/FS
RI/FS
RI/FS
RI/FS
RI/FS
RI/FS
RI/FS
*"*»»
03/30/89
03/39/89
03/30/89
03/30/89
03/30/89
03/30/89
03/30/89
03/30/89
03/30/89
03/31/89
M/04/89
IP
IP
1p
1p
1P
1p
1P
IP
IP
*P
2p
                                                                         Date      » Pages      Author/Organ! lat \ on      Addressee/Organ! nt I on
                                                                                                                Margaret Minor


                                                                                                                Richard 0. Harris


                                                                                                                Mr. and Mrs. Paul Olson


                                                                                                                Marilyn Rider


                                                                                                                Bradford H. Baugh


                                                                                                                Thomas and Nettlt PelIon


                                                                                                                Veila N. Kenny


                                                                                                                Patrick S. Lanegan


                                                                                                                Ray E. Casselman


                                                                                                                Otto L. Shumscher

                                                                                                                   k
                                                                                                                Glenn and Marilee Neher
                                                                                                                         Nell Thompson
                                                                                                                         EPA

                                                                                                                         Neil Thompaon
                                                                                                                         EPA

                                                                                                                         Neil Thompaon
                                                                                                                         EPA

                                                                                                                         Nell Thompaon
                                                                                                                         EPA

                                                                                                                         Neil Thompaon
                                                                                                                         EPA

                                                                                                                         Nell Thompaon
                                                                                                                         EPA

                                                                                                                         Neil Thompaon
                                                                                                                         EPA

                                                                                                                         Nell Thompson
                                                                                                                         EPA

                                                                                                                         Neil Thompaon
                                                                                                                         EPA

                                                                                                                         Nell Thompaon
                                                                                                                         EPA

                                                                                                                         Nell Thompaon
                                                                                                                         EPA
CO
to

-------
11.   Sdnipl inu. Plans

U0000033.     Samp) ing plan


00000107.     Samp)ing plan


00000108.     Sampling plan
                       Groundwater sampling and analysis plan,
                       draft

                       Field Sampling Plan
                       North Landfill. City of Spokane. WA.

                       Draft Quality Assurance
                       Project Plan - Supplemental
                       RI North tandfill
                                                                                    11/86      45       City of  Spokane
                                                                                    3/88       62p      CH2H Hill
                                                                                    3/88       I5p      OtfMHill
•UOOOOIOS).     Sampling Plan           letter commenting on sampling plan            4/13/88    3p
                                                                                                       Dave Kargbo
                                                                                                       WUOE
                                                                                                                       Nell Thompson
                                                                                                                       EPA
\'£,	Permi 1 and Permit Application
00000015.
Permit and permit
Application
                       tetter regarding Norths ide landl ill
                       Permit Application; copy of sanitary
                       landfill permit application; addendum
 00000110.      Permit  and  permit      Amendment of Solid Waste
               Application            Disposal  Site Permit
                                                                                    3/29/79    15
                                                                     7/8/88     15p
James t. Haurn, WUOE
                                                                                                       Mary Q. Luther
                                                                                                       Spokane County
                                                                                                       Health District
John Anisetti,
County Health District
                                                                                                                       Phil Williams.
                                                                                                                       City of Spokane
                                                                                                                       HA
13. Reference Materials/Listing of Guidances

00000030.     Reference materials;   Guidances  Inr administrative  record;
              listing of guidance    actual guidance can be  found  at EPA
              File
                                             	Type/Description
00000 111
Reference materials    Guidance Memorandum
listing of guidance    on Use and Issuance of
                       Administrative Orders under Section
                       I06(al of CERCIA
                                                                     No date     2       Neil Thompson, EPA
                                                                     Date    It Pages       Author/Organization      Addressee/Organ! tat ion
                                                                     9/15/87    37p.     Lee M. Thomas
                                                                                         EPA
                                                                                                                                      Regional  Administrators
                                                                                                                                      Regions  I-X
 000001 li*      Heftrc'iice materials    delegation of Remedy
               listing of  guidance    Selection to Regions
                                                                     3/21/86    4p       J. Winston Porter
                                                                                                                                      Regional  Administrators

-------
DOUOOin      KHvrence materials


H,	Commun ity pcljitions

000000:<7,      Community relations


UOOOUOW.      Community relations


OOOOOOiW.      Community relations

00000040.      Community relations
                       ROD:Des Moines TCE, U                        7/86       48p
                       (used as Directive)
                       News release regarding Northside Landfill     10/7/85
                       Superfund designation

                       Letter with attached community                10/11/86
                       relations plan—first draft

                       News release re December 11 meeting           12/4/86

                       Public meeting notice                         12/11/86
                                                                  EPA
                                                                  Dennis Mine,  City of
                                                                  Spokane, Refuse Division

                                                                  George Cole,  Media West       Phil Williams, City
                                                                                                of Spokane

                                                                  City of Spokane

                                                                  Phil Williams, Spokane Office
                                                                  of Environmental Programs
000000-11.
00000008.
OOOOUIH.


000001 IS.


00000 IK,.

0000012r..
Community relations
              Community relations
Community relations
(laid
             File
Community relations


Community relations


Community relations

Community relations
Statement ol work re community relations
plan and implementation for the
Northside Superfund site

Procurement request order form re
community relations plan and implemen-
tation support for Northside Landfill;
work assignment form; statement of work

Memo re representative Stratton request
for information on the Spokane aquifer/
letter re test results from Community
against pollution (2/6/84)/attached
general information
	Type/Description	

Fact sheet - Environmental investigations
at the Northside Landfill

Revised Community Relations
Plan, Northside Landfill

Northside landfill Fact Sheet

Fact Sheet - Northside landfill
Proposed Plan
4/10/87     2
                                                                     6/19/87     6
2/6/84      4
Date    # Pages

5/12/88    2p


9/88       19p


9/1/88     2p

02/28/89   6p
J. Schwarz
                    Francis Chapman,  EPA
                                                                                                                                                               c
                                                                                                                                                               7
Glenn Grace, WDOE
Don Dubois, Joan Thomas
                                                                                           Author/Organization      Addressee/Organization
EPA


EPA


EPA

EPA

-------
OOOOOI2h.     Community relations    Fact Sheet -  Synopsis  of Northside             05/02/89    3p        EPA
                                     Land)ill Responsiveness Summary

00000127.     Community relations    Northside Landfill Responsiveness Summary      05/89       I2p       EPA
 .  Newspaper Clippings

 OUOOOOI'l.     Newspaper clippings

 00000015.     Newspaper clippings
Landfill lawsuit initiated

Toxic waste cleanup moving ahead;
But county, city balking on two sites
000000%.     Newspaper clippings    Garbage  a  nationwide  problem
T)0000017.     Npwspaper clippings     Finding  a  home  for garbage
 OOOOOO'IO.     Newspaper clippings    County,  city  officials  lean toward
                                      'mass  burn' system
 00000050.     Newspaper clippings     Where  will  your garbage go?

 00000051.     Newspaper clippings     City says plant won't  burn dollars


 OOOOOOW.     Newspaper clippings     Cities,  linns plant's  partners
 0000005:!.     Newspaper cl ippings

 00000051.     Newspaper clippings

 Din."		__..fi!e_	

 00000055.     Newspaper clippings
State  gets  cash  to probe  3  landfills

Northside pollution  felt  stabilized

	Type/Descript ion	

Underground pollution  Irom  fill not
spreading
8/18/78     1

11/18/81    I


3/17/85     I


3/17/85     2


V18/85     I
 000000-1').     Newspaper clippings     Plant  expensive,  but  so is  alternative        3/18/85     2
3/19/85     I


4/17/85     1

12/11/85    1

Date    tt Pages

12/12/86    I
Unknown

Jeff Sher, Spokesman-
Review

Ken Sands, Spokesman-
Review

Ken Sands, Spokesman-
Review

Ken Sands, Spokesman-
Review

Ken Sands, Spokesman-
Review
                                               3/18/85      1        The  Spokesman-Review

                                               3/19/85    •  2        Rick Bonino,,  Spokesman-
                                                                   Review
Ken Sands, Spokesman-
Review

The Post-Intelligencer

Jeff Sher, The Spokesman-
Review
  Author/Organization	

Rick Bonino, Spokesman-
 UOOOOOSd.      Newspaper  clippings     Municipalities sing requiem lor
                                               12/15/85     I        The  Spokesman-Review

-------
                                      landfills
OOOOUOb/.     1.al) reports and
              data
                        HSU  tests
                                               5/25/77-
                                               6/12/78
                     Unknown
00000058.     l.ab reports and
              data
0000005').
 Lab reports and
 dd I a
208 lab tests; Spokane Aquifer
Water Quality Study Chronological
Display

Extended monitoring data
                                                                       8/21/78
 2/4/79
                     Idaho Health and Welfare
                     Lab
                                                                                                        EPA  Lab
OOOOOObO.
 Lab reports and
 data
Water sample reports
 11/16/83    1
                                                                                                       W.  E.  Burkhardt.  ABC
                                                                                                       Laboratories,  Inc.
   Dept. of Public
   Utilities. Refuse Uiv.
UOIIflOOu I.
00000062.
 I cib reports and
 data

 Iah reports and
 data
Water sample reports
Water sample reports, Lab No.
1615-8.1
                                                                                    11/16/8:1    I
 11/17/83    2
                                                                                                       W.  E.  Burkhardt,  ABC
                                                                                                       Laboratories,  Inc.

                                                                                                       W.  E.  Burkhardt.  ABC
                                                                                                       Laboratories,  Inc.
   Oept. of Public
   Utilities, Refuse Div.

   Dept. of Public
   Utilities, Refuse Div.
00000063.
 Inb reports and
 data
Water sample report.  Lab No.
1655-83.
 11/21/83    1
                                                                                                        W.  E.  Burkhardt,  ABC
                                                                                                        Laboratories.  Inc.
   Dept. of Public
   Utilities, Refuse Div.
00000064.
 I ab. reports and
. flat a
00(100016.     I ab reports and
              data
Water sample reports, chain of custody         12/16/83    15
records, field reports.  Lab No.
1704-83

Water sample reports.  Lab No. !704-8<.        12/16/83     3
                     W. E. Burkhardt. ABC
                     Laboratories, Inc.,
                     George Maddox & Assocs.

                     W. E. Burkhardt, ABC
                     Laboratories, Inc.
                                                                                                                                      Dept.  of Public
                                                                                                                                      Utilities,  Refuse Div.
                                                                                                                                      Dennis Mine

                                                                                                                                      Dept.  of Public
                                                                                                                                      Utilities,  Refuse Div.
0000001.0.
 Lab reports and
 data
0000001.7.     I ab reports and
              (1.11.1
Water sample reports.  Lab No.  1744-84,
1748-84
	Iyfie/J)escriptiojL	

Water sample reports.  Lab No.  1781-84
 1/9/84      3
 1/16/84
_Dai£_   H Pages

 1/20/84     2
                                                                                                       W.  E. Burkhardt,  ABC
                                                                                                       Laboratories,  Inc.
                                                                                                         Author/Organization

                                                                                                       W.  E. Burkhardt,  ABC
                                                                                                       Laboratories,  Inc.
   Dept. of Public
   Utilities, Refuse Div.
Addressee/Organization

   Dept. of Public
   Utilities, Relus Div.
OOOIIOO(><).      I ah reports and
              rtnta
                                      Memorandum  regarding North  and  South
                                      Landfill water  samples;  attachments of
                                                                       3/8/84     20
                                                                   Hale Arnold.  Lab
                                                                   Supervisor
                                                   John Swanson, Director
                                                   of Public Utilities

-------
                                     water samples analysis and results
00000070.
00000071.
(10000072.
ouoooo/:<.
00000074.
(ah reports and
delta

lab reports and
data

I ah reports and
data

Lab reports and
data

tali reports and
data
Results of laboratory analyses of
South Landfill water samples

Northside Landfill residential well
samp!ing
                                                                                   6/20/84
                                                                                   8/84
Field report on residential well sampling.    8/15/84
chain of custody record, conductivity graphs
Hater sample report.  Lab No. 2376-84.
                                                                                   8/20/84
Results of gas well monitoring Southside      6/21/84
Landfill, Nor tits ide Landfill chain ol records,
residential well sampling, water testing
         Unknown
         Unknown
                                                                                              38       Joanne Ellison
 1        W. E. Burkhardt, ABC
         Laboratories

20        Joanne Ellison, Richard
         Schram, City ol Spokane,
         Refuse Div.
City of Spokane,
Refuse Division

Oept. of Public
Utilities
00000075.      Ldh reports and
              data
00000117.     lab Reports & Data
                       Memorandum re QA of organic samples Case
                       3184  lor Spokane Steel, Northside Landfill,
                       Southside Land!ill and Mica Landfill.
                       Attached organics analysis data sheets.

                       Northside Landfill Methane Gas Data
                                              12/18/84   10
U.-  HiscelIaneous Correspondence

00000076.      Correspondence -Misc.  LeLter regarding hazardous waste waiver
                                     request, Northside Land! ill

00000118.      Correspondence -Misc.  Notilication to prioritize Northside site

OQC.W	File	      	Type/Description	

OOUOOII')      Correspondence -Misc.  Request lor information on lOb order
                                              5/17/88    3p
                                                                     6/8/79      2


                                                                     12/7/87     Ip

                                                                     Date    ft Pages

                                                                     12/30/87    Ip
         Andrew Hafferty, Jim Farr.    John Osborn, EPA
         Ecology & Environment
         Rhys. A1 Sterling
         Spokane County Health
         District
Phil Williams
City of Spokane
                                                                  Edward M. Pickett, Spokane    Roger James, City
                                                                  County Health District        Utilities Director
                                                                  Carol Rushin
                                                                  EPA
                                                                    Author/Organization

                                                                  Marsha A. Beery  .
                                                                  WDOE
                                       Peter Kmet
                                       WDOE
                                    Addressee/Organ i zat ion

                                       Neil Thompson
                                       EPA
                                                                                                                                                               CQ

-------
 IB.  MisieIIdneous Memoranda

 000000/7.     Memoranda
                         Memoranda regarding phone conversation
                         with tynn Guy about groundwater contami-
                         nation from Northside.
                                                                                    H/15/83
                                                                  Rene Fuentes
00000078.
  Memoranda
Memorandum regarding status report - Pine
Meadows/Lowell Avenue water service
2/16/84
C. D. Robinson, Jr., City
of Spokane
 19.  Lnluicement - Administrative Orders

 00000120.     Enforcement - Admin     letter  regarding  calculation
              Ortlprs                  of costs  in Order on Consent
                                                                       .1/11/88    Ip       Neil E. Thompson
                                                                                           EPA
                                                                                                Phil Williams
                                                                                                City of Spokane
00000121.     fiiilurcenient - Admin
*             Orders
                         Order on Consent
                                              :»/!5/88
                    EPA
                              City of Spokane
Doc*	
00000122.
OOOUOI21.
,.£Ue	
  Enforcement - Admin
  Orders

  Enforcement - Admin
         Type/Description
Change of information on
Consent Order

Comments on EPA's
Consent Order
Date    tt Pages
3/16/88    1
4/12/88    2p
  Author/Organization
Irving B. Reed
City of Spokane
Dave Kargbo
WDOE
Addressee/Organization
   Neil Thompson
   EPA

   Neil Thompson
   EPA
 20.  Notice Letters and Responses
 00000081.
 0000008!).
  Notice tetters &
  Responses
  Nut ice tellers &
  Responses
Notice letter to state re proposed            8/16/84
Superfund projects
teller of notification re potential liab-     9/30/85
ility for federal actions at North;ide
tandfill
                    Kathryn M. Davidson,  EPA
                    Charles E. Findley,  EPA
                              Ken Bock, WA
                              Planning &
                              Community Affairs Agency

                              Terry Novak,
                              City of Spokane
 00000086.
 000(1008?.
  Notice tetters R
  Responses

  Notice tetters 6
  Responses
teller of noli f i.cation re potential liab--     1/10/86
ility on behalf of the State of WA

teller of notification re potential liab-     1/10/86
ility on behalf of the State of WA
                    Fred Gardner, WDOE
                    Fred Gardner,  WDOE
                              Terry Novak,
                              City of  Spokane

                              Dennis Hein,
                              Cily ol  Spokane
 tl.   lied I MI

-------
00000124.     Health Assessment      Health Assessment for North Landfill          5/25/88     I5p      ATSOR

                                                                                                                                                      sampling
LW:ct: 55081'
                                                                                                                                                             m

-------