Explanation of Significant Differences
Northside Landfill Superfund Site
Spokane, Washington
October 21, 2009
U.S. Environmental Protection Agency, Region 10
Office of Environmental Cleanup
1200 6th Avenue, Suite 900
Seattle, WA 98101
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Explanation of Significant Differences
Northside Landfill Superfund Site
Spokane, Washington
I (approve)/(disapprove) this Explanation of Significant Differences:
\
(signature)
(date)
Lori Cohen, Acting Director
Office of Environmental Cleanup
1200 6th Ave, Suite 900
Seattle, WA 98101
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Site Background and Statement of Purpose
The Northside Landfill Superfund Site (Site WAD980511778) is located in the
northwest portion of the City of Spokane, in Spokane County, Washington (see
Figure 1). The Site was listed on the National Priorities List (NPL) in 1986. 49
Fed. Reg. 40320 (Oct. 15, 1984) and 51 Fed. Reg. 21054 (June 10, 1986).
Based on the third Five Year Review (September 2007), EPA has determined
that an Explanation of Significant Differences (ESD) is needed to document
several changes to the remedy selected in 1989. This ESD has been prepared
in accord with Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) Section 117(c), 42 U.S.C. § 9617(c), and the National
Contingency Plan (NCP), Sections 300.435(c)(2)(i) and 300.825(a)(2).
Site History, Contamination, and Selected Remedy
Following initial Site investigations, a Remedial Investigation and Feasibility
Study (RI/FS) was completed in 1988 which determined that releases to
groundwater warranted remediation to address risks to human health and the
environment. Groundwater contamination extended a quarter mile down gradient
of the landfill boundary. The contaminants of concern (COC) were identified as
volatile organic compounds (VOCs) related to disposal of dry cleaning solvents.
The landfill property (approximately 345 acres) is owned by the City of Spokane
(City) and includes an active municipal waste landfill operating under a permit on
approximately 15 acres, an older landfill, approximately 125 acres in size, which
was closed to disposal in 1991, and an infiltration basin for storm water runoff.
The older landfill and the contaminated groundwater were the focus of the
September 1989 Record of Decision (ROD).
Residential developments border the landfill on three sides. On the fourth side,
an arterial road separates the landfill from additional residential areas. All area
residents have been connected to the municipal water supply since 1984, when
initial Site investigations indicated VOC contamination in domestic wells down
gradient of the landfill. The risk assessment focused on exposure to
contaminated groundwater, within the landfill and within the down-gradient
plume, and estimated excess cancer risks ranging to 1 X 10"4.
Alternatives were evaluated that would achieve the remedial action objectives of
controlling the leaching of contaminants into the groundwater and reducing
health risks from contaminants in the groundwater.
The ROD documented selection of the following remedy:
• closing the landfill,
• capping the landfill waste units to reduce infiltration and contaminant
migration to groundwater,
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• pumping and treating the groundwater to prevent migration of
contaminated groundwater beyond the landfill boundary,
• monitoring the groundwater,
• providing alternative water to prevent exposure to contaminated
groundwater,
• enacting administrative restrictions to protect the cap, monitoring wells,
and pumping and treatment system, as well as to restrict the construction
of new wells and the use of existing wells in the contaminated plume, and
• controlling landfill gas emissions.
The remedy anticipated natural recovery of contaminated groundwater down-
gradient of the landfill boundary. The groundwater pumping and treatment was
to be used until the landfill cap demonstrated control of contamination sources.
Under a January 1991 CERCLA Consent Decree (CD), the City agreed to
implement the remedy, long-term monitoring, operation and maintenance, and
institutional controls (ICs). Civ. Act. No. CS-90-0462-JLQ (E.D. Wash.). The
institutional controls included recordation of the CD with the deeds for properties
within the Site, and for the City-owned landfill property, deed notices restricting
the use of groundwater and actions that could affect the integrity of the remedy,
as well as obligations on the City to notify EPA and the State of Washington if
property ownership changed.
The City achieved CERCLA Construction Completion in 1993. Groundwater
pumping began in 1993 and is ongoing. Pursuant to the ROD, groundwater
pumped from the Site was initially treated at a Publicly Owned Treatment Works
(POTW). The City came to view the high volumes of water as a strain on the
POTW, particularly as the contaminant concentrations were declining.
Consequently, since 2003, the City has treated water through passive air
stripping on Site, with discharge of the treated water in an infiltration basin on
City property adjacent to the landfill. Current data indicate that the plume has
decreased to the point where drinking water Maximum Contaminant Levels
(MCLs) are met most of the time at the landfill boundary and continuously in
down-gradient wells.
In 1997, a court order terminated the CD with the exception of certain ongoing
requirements on the City, such as performing Operation and Maintenance
(O&M), monitoring, and ICs, under oversight by the Washington Department of
Ecology (Ecology). Five Year Reviews have been required, as waste remains on
Site at levels that do not allow unrestricted use and unlimited exposure. In the
third Five Year Review (September 2007), EPA recommended that an ESD be
prepared to document the change in the location of water treatment and
discharge, further specify cleanup standards, clarify compliance boundaries, and
review the ICs.
EPA was lead agency overseeing the RI/FS and Remedial Design/Remedial
Action (RD/RA). EPA also selected the remedy and is responsible for five-year
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reviews. Ecology was the support agency during the RI/FS, concurred on the
ROD, and is now lead agency for oversight of O&M.
Basis for the ESD
In 2007, EPA completed the third Five Year Review for the Site (EPA September
2007). In keeping with EPA's growing emphasis on improved tracking of
institutional controls, the 2007 Five Year Review called for a detailed review of
the status of institutional controls at the Site. The 2007 Five Year Review also
identified certain post-ROD changes that had not been set forth in a formal
decision document, which taken together warranted an ESD.
As noted above, the 2007 Five Year Review recommended that an ESD be
issued to:
1. Clarify and document the federal drinking water standards as the
groundwater cleanup levels at this Site for tetrachloroethene and trans-
1,2-dichloroethene. Federal MCLs for protection of drinking water did not
exist for these two contaminants of concern at the time of the ROD.
2. Document the change in the groundwater treatment system from off-site to
on-site treatment and discharge.
3. Clarify that the groundwater point of compliance described in the ROD is
still the landfill boundary.
4. Document the new surface water point of compliance, given the
groundwater treatment system changes.
In addition, based on EPA review of the status of institutional controls (see
Appendix A), an ESD is needed to incorporate changes to the institutional
controls in the ROD. Institutional controls required by the ROD and CERCLA
enforcement documents have not been implemented.
Even if implemented, deed notices do not provide enforceable, effective long-
term control over land use at the Site. A restrictive covenant that is recorded on
the title of the property and that runs with the land in perpetuity is considered a
more reliable and effective, long-term control to meet the objectives of the
institutional controls: to protect the landfill cap, monitoring wells, and the pumping
and treatment system and to prevent exposure to contaminated groundwater
through restricting use (ROD page 55).
Description of Significant Differences
1) Cleanup Objectives for all Groundwater Contaminants of
Concern
This ESD clarifies and documents that MCLs are the selected cleanup level for
all contaminants of concern at the Site. Specifically, this clarifies groundwater
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cleanup levels for tetrachloroethylene and 1,2-(trans)dichloroethylene. [Note:
This ESD uses the term 1,2-(trans)dichloroethylene to refer to what is variously
called trans-1,2 dichloroethene, trans-1,2 DCE, or t-1,2 DCE. It also uses the
term tetrachloroethylene to refer to what is sometimes called tetrachloroethene,
PCE, orPERC.]
The risk assessment highlighted trichloroethylene (TCE) and 1,1,1-
trichloroethane (TCA) as the two contaminants most frequently detected, and
tetrachloroethylene and TCE as detected above the MCL on site and off site.
However, the ROD states, under "Groundwater Contamination" in the "Site
Characteristics" section, "Six other compounds in addition to PERC
[tetrachloroethylene] that have known health effects have been detected in off-
site wells: chloroform, TCE, 1,1,1-trichloroethane (TCA), 1,2-
(trans)dichloroethylene, 1,1-dichloroethane, and vinyl chloride." [ROD, p. 11 ].
These seven contaminants are also listed in Table 5 of the ROD as chemical-
specific Applicable or Relevant and Appropriate Requirements (ARARs) and
TBCs (To Be Considered), [ROD, p. 32],
At the time of the ROD, MCLs had been promulgated for chloroform (100 ug/l),
1,1,1 - trichloroethane (200 ug/l), trichloroethylene (5 ug/l), and vinyl chloride (2
ug/l), but MCLs had not been promulgated for the remaining three COCs:
tetrachloroethylene, 1,2-(trans)dichloroethylene, and 1,1-dichloroethane. The
final drinking water MCL rule was issued for tetrachloroethylene and 1,2-
(trans)dichloroethylene in 1991, following the ROD.
Subsequent references in the ROD to groundwater cleanup levels refer to MCLs
generally, rather than listing individual contaminants. [ROD, pp 53 and 54], This
ESD documents that the specific numeric standards that must be achieved at the
groundwater compliance boundary for tetrachloroethylene and 1,2-
(trans)dichloroethylene are the MCLs listed below:
1,2-(trans)dichloroethylene: 100 ug/L
tetrachloroethylene: 5 ug/L
In the future, if EPA issues a Safe Drinking Water Act MCL for 1,1-
dichloroethane, the MCL will be considered the cleanup level for this COC also.
The change is not expected to affect the cleanup, as testing of the extraction well
(PEW) from 2002 to 2006 has shown no detections of 1,1-dichloroethane, at a
detection limit of 0.5 ug/L, well below ecological and human health protective
levels.
2) Groundwater Treatment and Discharge Location
This ESD documents changes to the pumping and treatment system. In 2003,
following pilot testing, Ecology approved a change in the groundwater treatment
The change is hereby incorporated into the remedy for the Site. The ROD
included cleanup levels for treatment system discharges to the Spokane River.
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With the change in discharge location, ARARs for surface water discharge are
not applicable.
The ROD called for water extracted on site to be conveyed to the City of
Spokane POTW, where the water was treated and discharged in compliance with
the National Pollutant Discharge Elimination System (NPDES) permit for the
POTW. By 2003, the capping of old landfill areas had begun to reduce
groundwater COC concentrations, as anticipated in the ROD. To reduce the
demand on the POTW, the City began to seek alternative treatment for the
approximately 1 million gallons per day of groundwater extracted for the cleanup.
As observed in the second Five-Year Review report (September 2002), the City
proposed to use the on-site storm water collection system as an air stripping
system for extracted groundwater and to allow the treated water to infiltrate to
groundwater in an on-site infiltration pond. The water flows along a shallow,
lined ditch filled with cobbles to reduce erosive force. The ditch drops 80 feet in
elevation, and ends in an infiltration basin. The COC removal efficiency for this
method of treatment was tested by sampling at the point where the pumped
water flows from the pilot extraction well into the ditch and again where the ditch
flows into the infiltration basin. The removal efficiency for tetrachloroethylene
(PERC), which was present in the highest concentrations, was calculated at
approximately 80 percent. (See test results, Appendix B). Based on the
contaminant removal results, EPA and Ecology approved this change to the
remedy. The system is now fully operational, and the landfill groundwater
discharges on-site.
The 2002 Five Year Review described this potential change and included a
recommendation that if such a change was made, it should be documented in an
ESD.
3) Groundwater Point of Compliance
Cleanup levels for groundwater apply to the "aquifer unit." For each contaminant
of concern, these levels must be achieved at the point of compliance. At the time
the ROD was written, the down gradient landfill boundary and the landfill property
boundary were the same, and the ROD uses both terms to describe the
groundwater point of compliance. Subsequently, the City of Spokane acquired
additional property down gradient of the landfill for infiltration of surface water
and treated groundwater. This ESD clarifies that the groundwater point of
compliance is the down gradient side of the landfill itself, not of the additional
property. This is consistent with EPA policy (OSWER Directive 9283.1-33),
which calls for compliance with groundwater cleanup goals at the downgradient
edge of the waste management area (in this case, the landfill).
The ROD states that the point of compliance is the landfill boundary, with
performance monitoring to be located down gradient but beyond the zone of
influence of the extraction wells. For this reason, groundwater monitoring plans
for performance monitoring of the groundwater treatment have included
monitoring of wells along the landfill boundary and well MWWB, located further
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down gradient (see Figure 2). When groundwater extraction is discontinued, the
wells along the down-gradient edge of the landfill will continue to be monitored
for compliance.
4) Surface Water Point of Compliance
This ESD changes the surface water point of compliance from the point where
the POTW discharged to surface water (the Spokane River) to the location where
treated water enters the on-site infiltration area.
Based on treatment and discharge of groundwater off site, the ROD (Statutory
Determinations, ROD pp 56 - 59) cited the Clean Water Act (33 U.S.C § 1251 et
seq.) as an ARAR for surface water discharge. However, because water in the
infiltration area results from pumping and treatment of groundwater that is not
considered "waters of the United States," the Clean Water Act is not applicable to
the discharge. Even if Clean Water Act ARARs were applicable, State water
quality standards have not been promulgated for the COCs at the Site.
Water discharged to the infiltration area complies with MCLs for the contaminants
of concern, and available screening levels for ecological protection indicate that
levels of these contaminants that are protective of human health are, for the most
part, more stringent than screening levels used in ecological risk assessment.
Where this is not the case, as with chloroform and 1,1,1 -TCA, monitoring at the
extraction well indicates that groundwater pumped from the Site is below
ecological screening levels and MCLs. See Table 1.
This ESD does not modify the following ROD language regarding discharge of
treated water. "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." (See Statutory Determinations, pp 56-59 of the ROD).
5) Institutional Controls
The Selected Remedy in the ROD (page 55) states "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." More specific requirements were set forth in the Consent
Decree entered by the City, Washington State and EPA in 1991. The Consent
Decree requirements for institutional controls were preserved in the 1997 Court
Order terminating the Consent Decree. This ESD does not change the above
requirements of the ROD or the Court Order. Rather, it adds clarity as to the
objectives of needed institutional controls, and provides additional specificity on
the types of controls that are being relied on to achieve these objectives.
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As noted above, the 2007 Five Year Review recommended an in-depth review of
the status of institutional controls. EPA completed the review and prepared a
memo dated June 2008 (Appendix A) that found that the required institutional
controls had not been implemented. Although the City still owns the landfill
property, which is fenced, deed notices and restrictions required by the CD were
not recorded for City-owned property, and no mechanisms were in place that
ensured continued access to off-site monitoring wells.
Governmental controls required by Chapter 173-304 of the Washington
Administrative Code, Minimum Functional Standards for Solid Waste Handling,
will apply for a 30-year period following closure of the permitted landfill.
The landfill cover and groundwater collection and treatment have greatly reduced
the extent of contamination beyond the landfill. To ensure long term
protectiveness, however, lasting, and enforceable institutional controls that run
with the land are needed in case existing controls expire or are eliminated or
changed.
Thus, the following language is hereby incorporated into the Selected Remedy
section on Institutional Controls:
The specific objectives of the Institutional Controls are to:
1. prohibit activity on the landfill property that could damage or disturb the
integrity or maintenance of the landfill cap or any other component of
any containment system, pump and treat system, gas collection
system, or the function of the landfill monitoring system, or otherwise
result in the release or exposure to the environment of any hazardous
substances beneath the cap without prior written approval from
Ecology;
2. ensure that current and future owners of the landfill property maintain
the cap, including the minimum 12-inch cover of topsoil and the
minimum 18-inches of granular cover material;
3. prohibit access to groundwater on the landfill property unless
groundwater removal is part of monitoring activities established in a
plan approved by EPA and Ecology
4. ensure that EPA and Ecology are notified at least 60 days in advance
of any conveyance of the property,
5. ensure that any conveyance of any interest in the landfill property,
current and future owners provides for these Institutional Controls to
continue,
6. restrict leases to uses and activities consistent with these Institutional
Controls and notify all lessees of the restrictions on the use of the
landfill property, and
7. provide for EPA and Ecology access to the landfill property to inspect
and evaluate the remedial action.
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The landfill property, which is the area to which these Institutional Controls shall
apply, is defined as the property shown on Figure 3 (including tax parcel
numbers: 26223.0004, 26223.0016, 26262.0021, 26262.0033, 26275.0029,
26275.0030, 26281.0029).
The restrictions are needed in perpetuity, unless a demonstration is made that
contaminants are no longer present at levels that could pose an unacceptable
risk to human health or the environment through direct pathways (such as dermal
contact, ingestion, or inhalation of contaminants in the landfill), or through the
groundwater pathway (releases to groundwater followed by exposure, though
ingestion, inhalation, or other pathways).
The preferred and anticipated means to implement these Institutional Controls is
through a covenant under the Uniform Environmental Covenants Act (UECA).
The covenant would be signed by EPA, Ecology, and the City of Spokane, and it
would be enforceable by both EPA and Ecology. The requirements are expected
to be implemented within a year of this ESD.
Support Agency Comments
The Washington Department of Ecology concurs with this ESD (Appendix C).
Statutory Determinations
The selected remedy, as modified by this ESD, is protective of human health and
the environment and continues to meet ARARs. This ESD satisfies the
requirements of CERCLA Section 121, 42 U.S.C. § 9621.
Public Participation
The public participation requirements set out in NCP Section 300.435(c)(2)(i)
have been met. Public notice of this ESD is being placed in the Spokesman
Review, a local newspaper of general circulation in the vicinity of the Site. The
ESD and supporting documentation have been added to the Administrative
Record for this Site. The Administrative Record is available for public review at
the following location(s):
Spokane Public Library EPA Region 10 Records Center
906 West Main Street 1200 6th Avenue
Spokane, WA 99201 Seattle, WA 98101
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Figure 1: Site Location
Figure source:
City of Spokane
report, "Northside
Landfill Groundwater
Monitoring Plan
Revision 2, March
2007." Report
prepared by
CH2MHill.
FIGURE 1-1
Vicinity Map
Northside Landfill
March 2007
CH2IWIHILL
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26262.01
¦WiBagife
,~.S1bS#?P
VV A v.:
:vV.6fa:F4ort'6r,
W.Tiffrjnv Avh'
Northside Landfill
Superfund Site
Legend
Tax Parcels of Interest
Tax Parcel 10 Number
' '" " Roads
Note: The City of Spokane is the current
property owner for all parcels of interest.
Aerial photo provided by: Google Maps
Imagery - Digital Globe, NAVTEQ 2008.
Tax lot information provided by Spokane
County GIS.
Modified By Booz Allen Hamilton.
Booz | Allen | Hamilton March 13,
2008
Figure 3:
Northside Landfill Tax Parcels
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Table 1 - Chemical-Specific ARARS from the 1989 ROD compared to Aquatic Ecological Screening
Levels (in ijg/L)
Max
CWA HH
CWA
CWA
Risk-based
or
MCL
Fish and
CWA HH
Acute
Chronic
HH screening
ESL
MCL
D/La
Goal
Water
Fish Only
Toxicity
Toxicity
levels
PERC
111
5
5.4
0
0.8
8.85
5,280
illflllllilOIffl
TCE
21
5
.5
-
m-mmm
80.7
45,000
SISSli
1,1,1-TCA
11
200
.5U
-
18400
1,030,000
II :i-1111111111:!
-
1,000
Chloroform
1.8
100
.5U
-
0.19
15.7
28,900
1,240
iiii:iii§ill§i:3i0!!i
1,1 -DCA
47
-
.5U
-
0.94
liiiiiiiiiiiiiiii!
-
4,500
t-1,2-DCE
970
100
.5U
0.33
WiMSismBS.
11,600
-
350
VC
930
2
.5U
0
2.0
525
-
-
46
ESL: EPA Region 3:
Ecological Screening Leve
: Freshwater Screening Benchmarks
(http://www.epa.gov/reg3hscd/risk/eco/btag/sbv/fw/screenbench.htm)
aMaximum detection or (if undetected) detection limit, from 2002 - 2006 sampling from the extraction well (PEW).
D/L: detection limit
CWA: Clean Water Act
HH: Human Health
U: not detected at indicated detection limit
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Table 2 - Recommendations of the 2007 Five Year Review
Recommendation/ Follow-Up
Action
Party
Responsible
Oversight
Agency
Mile-
stone
Date
Affects
Protectiveness?
(Y/N)
Current
Future
Clarify and document MCLs as
groundwater cleanup levels for
PCE and t-1,2-DCE in the ESD.
EPA
Region 10
EPA
Dec
2007
No
No
Document changes to pumping
and treatment system in the ESD.
EPA
Region 10
EPA
Dec
2007
No
No
Clarify the groundwater point of
compliance in the ESD.
EPA
, Region 10
EPA
Dec
2007
No
No
Revise the surface water point of
compliance and any related
monitoring changes in the ESD.
EPA
Region 10
EPA
Dec
2007
No
No
Evaluate future groundwater data
in light of vapor intrusion
pathway, and consider additional
assessment if groundwater
concentrations rise.
EPA
Region 10 "
EPA
Dec
2007
No
No
Conduct in-depth survey of ICs to
assess long-term protectiveness.
EPA
Region 10,
Ecology
EPA
Dec
2007
No
Yes
Initiate suspension of pumping
and treatment for evaluation,
including appropriate data
gathering.
City of
Spokane
EPA,
Ecology
Sep
2008
No
No
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Appendix A: Review of Institutional Controls (dated June 20, 2008)
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^eosr^ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
£ £% b REGION 10
l^jgl 1200 Sixth Avenue, Suite 900
, Seattle, Washington 98101-3140
Reply To: ECL-113
MEMORANDUM
Subject: Review of Institutional Controls at Northside Landfill, Spokane County
From: Ellen Hale, RPM
Alexander Fidis, Site Attorney
Through: Howard Orlean, Unit Manager
To: Site File, Northside Landfill Superfund Site
CC: William Fees, Washington Department of Ecology
Scott Windsor, City of Spokane Solid Waste Management
The September 2007 Five Year Review of the remedy at Northside Landfill Superfund
Site recommended a more detailed review of the status of institutional controls (ICs) (see
"Evaluation of Institutional Controls" in Appendix H of the Five Year Review). This
memorandum reports on EPA's subsequent inquiry into whether the ICs were
implemented as required by the Record of Decisions (ROD), Consent Decree (CD) and
other related enforcement documents, and whether the ICs properly implemented are
consistent with more recent EPA practices.
Appendix H of the Five Year Review (FYR) states:
While this review supports a determination that the existing ICs, in combination with
engineering controls, are currently effective in accomplishing the goals identified in the
ROD, further work is necessary to determine whether the existing ICs will be effective in
the long term. At a minimum, the following is recommended:
• A review of the operating permit for the landfill and the MFS to determine
the nature and duration of state-required ICs
• A review of the Institutional Controls Plan (referenced in the CD Scope of
Work)
• A title search for the City's landfill property to review encumbrances and
verify that deed notices are still in place
• A review of the need for access to monitoring wells on private properties,
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including coordination with Ecology regarding existing conveyance
notification requirements, whether they are being complied with, and
whether they are necessary (paragraph 55 of CD).
• A review of nearby homes with monitoring wells for compliance with
conveyance notification.
• Zoning documents for the landfill property
• An evaluation of the effectiveness of the "start card" system
• Clarification of the Spokane County Health District role in ICs
It may be appropriate to include in the proposed ESD an update of ROD ICs, to address
specifics of duration, extent, implementation procedures, mapping, and reporting
requirements.
In following up on these recommendations, EPA has, to date, performed the following
actions:
• tasked contractors to perform a limited title search for the Northside Landfill
property,
• obtained from the city a copy of the operating permit for the landfill,
• requested but never obtained the Institutional Controls Plan referenced in the CD
because it could not be located,
• reviewed language in the Minimum Functional Standards regarding post-closure
requirement for landfills,
• reviewed city zoning maps for the area that includes the landfill,
• contacted Department of Ecology and Department of Health staff regarding the
specifics of the "start card" process,
• met several times with City of Spokane legal and technical representatives to
discuss
o ROD and CD language regarding access to downgradient wells for
groundwater monitoring,
o Start card process
o Status of permit, landfill closure plans, etc.
In addition, the site attorney, Alex Fidis, reviewed the adequacy of existing ICs in terms
of their enforceability. Our conclusions follow.
Proprietary Controls
The IC requirements of the ROD (1989), as further specified in the 1991 CD, paragraphs
29 and 55, and the February 2, 1997 Order terminating the CD set forth a number of
proprietary controls that were not implemented. The title search revealed that no deed
notices were established, no copy of the CD had been recorded, and no restrictions were
put in place to limit the future use of the landfill property to protect the integrity of the
remedy
Governmental Controls
State Regulatory Standards for Landfills: The Minimum Functional Standards (WAC
173-304) and Criteria for Municipal Solid Waste Landfills (WAC 173-351) include post-
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3
closure, recordation and land use requirements similar to those required as ICs by the CD.
Both sets of regulations apply to Northside because it was a functioning landfill when
both became effective.
Post-Closure: Post-closure requirements include maintenance of the cover, maintenance
and operation of the leachate collection system and gas monitoring system, and
monitoring of the groundwater. Two post-closure periods apply to municipal landfills.
WAC 173-304-407(7)(a) requires a post-closure plan that addresses "facility maintenance
and monitoring activities for at least a twenty year period or until the site becomes
stabilized . . . and monitoring of ground water, surface water, and gases can be safely
discontinued." The second, found at WAC 173-351-500(2), requires a thirty-year period
of monitoring and care for the cap and the closure systems. Both periods can be increased
(by the jurisdictional health department) if necessary to protect human health and the
environment. However, both also contemplate a time - thirty years or so after closure -
when regulatory requirements that ensure the protectiveness of the landfill closure will no
longer apply.
Recordation and Land Use: As part of the general requirements applicable to all
landfills, WAC 173-304-405(6) requires that "maps and a statement of fact concerning
the location of the disposal site shall be recorded as part of the deed with the county
auditor not later than three months after closure." Further, WAC 173-35 l-500(l)(/')(ii)
requires recording notice on the deed to notify potential purchasers that the land has been
used as a landfill facility and that its use is restricted under subsection (2)(c)(iii), which
generally prohibits future uses of post-closure property that will disturb the integrity of
the final cover, liner or any components of the containment system or the functioning of
the monitoring system.
The regulatory provisions addressing post-closure, recordation and land use requirements
do not apply until landfill closure. Because the Northside Landfill property contains
disposal cells that are still actively used, it is not clear whether a closure plan has been
developed for the portion of the landfill that includes the Superfund site. In addition,
since the post-closure plans only apply for a specified, if variable, period following
closure, they are not permanent. And the WAC provisions do not appear to specify how
restrictions on land use will be established and enforced.
Other Location Restrictions'. WAC 173-351-140(1) states that "no new MSWLF unit or
lateral expansion active area shall be located closer than one thousand feet (three hundred
meters) to any drinking water supply well, in use and existing at the time of the purchase
of the property containing the active area unless the owner or operator can demonstrate
during the permit process of WAC 173-351-700 that the active area is no less than a
ninety-day hydraulic travel time to the nearest down-gradient drinking water supply well
in the first useable aquifer. The owner or operator must place the demonstration in the
application for a permit under WAC 173-351-700 and be issued a solid waste permit by
the jurisdictional health department." The criteria for MSWLF apply only to the siting of
new landfills, and not the drilling of new wells. As a result, the regulations may be useful
-------
4
in preventing new landfills from being sited within 1000 feet of existing wells, but they
do not appear to prevent the encroachment of new wells around existing landfills.
Well Drilling Regulatory Process: The applicable regulations that would prohibit the
drilling of a new well adjacent to a landfill are part of the Ecology Start Card Program
found generally at WAC 173-160. These regulations require a minimum setback of 1000
feet from the boundary of any landfill. WAC 173-160-171(3)(b)(vi). Although this
regulation purportedly would prevent well-drilling within 1000 feet of the Site, a
description of the program from Ecology reveals that, as applied, the Start Card program
may not be effective.
According to Bill Fees, the project lead for Washington Department of Ecology, the
following process is followed when the drilling of a new well is proposed:
"A notice of intent (NOI) is filed in Olympia. After three days, the applicant receives a
receipt acknowledging the NOI. There is no zoning overlay or any other system that tells
them not to allow a well to be drilled. Ecology puts the NOI into a database that is
reviewed by Spokane Regional Health District. The health district reviews notices to
assess compliance with their delegated responsibility. Their responsibility is to inspect
well seals, well site, and well decommissioning. The health district is required to do up
to 50 percent of the wells. So there is not a system in place to prevent someone from
drilling a well over the plume. Where I was mistaken is that the drillers around here are
knowledgeable about the landfill locations and are cautious about well locations. Sorry
if this complicates things any further. "
This process does not appear likely to ensure that wells are not located too close to
existing landfills. The method of enforcing the drilling requirements appears to be the
licensing of well contractors and operators set forth at WAC 173-162. These licensing
requirements generally require all contractors that drill wells to obtain a license. Failure
to comply with well drilling requirements may result in the suspension or revocation of a
contractor's license. WAC 173-162-025. These regulations state that only contractors are
subject to licensing and are silent as to whether individuals that do not drill wells for
money would be subject to the same licensing requirements.
The reference to "jurisdictional health department" indicates that it is DOH that issues the
permits and approves closure plans.
City Zoning: Section 17C. 190.350 of the City of Spokane's Municipal Code places
"waste-related uses" of property in the industrial land use category. Waste-related uses
are characterized by the receipt or disposal of solid or liquid wastes and include sanitary
landfills. Pursuant to the municipal code, all landfills must be zoned as industrial use.
However, the zoning map available on the City's website depicts the Northside Landfill
as zoned for residential use. Based on the zoning map alone, there is no indication that
the landfill or the zone of 1000 feet around the landfill, is set aside for industrial use. It is
possible that the map does not accurately reflect actual zoning. Still, absent an
unequivocal designation as industrial use, any zoning ambiguity raises concerns about
-------
5
incompatible uses and the possibility of well drilling within 1000 feet of the landfill
boundary.
Summary of IC Review
The City of Spokane has, to date, not implemented any permanent proprietary controls to
implement the institutional controls required by the ROD and CD. The landfill is
currently owned by and operated by the City in compliance with a permit that restricts
unauthorized access, cover disturbance or penetration, and well drilling. These
governmental controls, however, are neither prescriptive nor permanent and standing
alone may not be sufficient to ensure the integrity of the remedy or the protection of
human health and the environment. Even assuming the landfill post-closure plan
provided such assurances, the plans are written and applied to span a limited period of
approximately thirty years. Human exposure to contaminated drinking water off site is
unlikely, because the area is on the municipal water supply system. However, there are
few real constraints on drilling a well near the site, and use of such a well could affect the
hydrologic containment of contamination at the site, as well as potentially exposing
people to contaminated groundwater.
Conclusion The ESD should be used to impose ICs and they should be implemented as
required. At a minimum the ESD would require that the City implement the proprietary
ICs originally required in the CD. First, a copy of the CD must be filed and appended to
the title of each parcel affected by the remedial action. Second, the remaining proprietary
and information controls required by the CD should be implemented with the execution
of an environment covenant under the Uniform Environmental Covenant Act. The
covenant would, in perpetuity, provide notice to future landowners, require maintenance
of the cap and treatment systems, restrict use to protect the cap and remedy, restrict
access to or use of groundwater at the Site, allow EPA and Ecology access to the
remedial site, require notification and approval by EPA of any major construction at the
Site, and require notice to EPA prior to conveyance of any property interest at the Site.
The covenant would also grant EPA and Ecology the right to enforce its terms.
The environmental covenant will only apply ICs within the boundaries of the landfill
property. To prevent the improper access or use of groundwater from off-Site sources,
EPA proposes a layered IC approach. The first layer would require the City to clearly
delineate the boundary of the landfill and to rezone the landfill and the area within 1000
feet to restrict access to groundwater. The second layer would rely on the existing Start
Card program to prevent contractors from drilling within the 1000 feet of the landfill
boundary. Another layer has already been established with the provision of municipal
water to area residents, thereby reducing the need for water wells. If, after further
evaluation, EPA believes that additional layers are necessary, it may consider additional
measures such as requiring the City to mail an annual notification to residents in the area
reminding them not to drill wells.
fnnwo On necyciea reaper
-------
Appendix B: Results of 2002 Pilot Tests
-------
"Fees, William J. (ECY)"
09/16/2008 04:31 PM
cc
bcc
Subject FW: fourth quarter 2001 ground water monitoring report
To Ellie Hale/R10/USEPA/US@EPA
NSLF
For your files.
Original Message
From: Fowler, Dean [mailto:DFowler0SpokaneCity.org]
Sent: Friday, January 04, 2002 4:29 PM
To: Fees, William J.; Bill Rickard; Lloyd Brewer; Monica Hairston; neil
thompson; Steve Holderby
Subject: fourth quarter 2001 ground water monitoring report NSLF
Preliminary results of diverting the Pew to the storm Basin look
favorable... three consecutive months with a 78% reduction in VOC's.
Next step will be to submit a request to Ecology to use this as a
permanent solution. The attached report shows analysis at the
compliance points below treatment levels. I predict that we may be
shutting down the PEW sometime this year, (with continued monitoring)
Dean Fowler, P.E.
Senior Engineer
City of Spokane, Solid Waste Management
1225 E. Marietta Avenue
Spokane WA 99207-2787
Phone: (509)625-7890
FAX: (509)625-7899
E-Mail: dfowler0spokanecity.org
«GWM4 thQTR2 001.xls»
GWM4thQTR2001.xls
-------
North Landfill Fourth Quarter 2001
IWELL 1
111
1-
<
Q
TIME
3
IDEPTH.(FT) I
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iTotal Alkalinitvl
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MW-208
10/08/01
10:15
RPS
73.34
85
30
56.66
534
7.47
206
206
<0.02
MW-BB
10/15/01
10:40
RPS
116.17
124
15
57.02
640
7.23
233
233
<0.02
MW-C
10/15/01
09:30
RPS
83.77
100
15
55.76
485
7.38
174
174
<0.02
P.E.W.
10/09/01
09:30
RPS
128.99
141
15
57.92
803
7.09
MW-E
10/02/01
11:45
RPS
55.17
105
60
55.40
427
7.48
0.07
MW-F
09/25/01
09:45
RPS
48.18
68
40
54.32
409
7.41
MW-G
09/24/01
09:25
RPS
67.64
80
30
55.04
421
7.35
MW-H
09/24/01
09:10
RPS
34.26
60
30
53.60
460
8.02
MW-I
09/26/01
09:40
RPS
63.62
80
30
54.50
463
7.78
MW-J
09/26/01
12:45
RPS
75.57
81
25
56.12
603
7.08
QC DUP
MW-J
09/26/01
12:45
RPS
81
25
QC DUP
MW-K
10/02/01
09:30
RPS
61.22
80
40
53.78
472
7.57
QC DUP
0.06
MW-K
10/02/01
09:30
RPS
80
40
QC DUP
0.07
MW-L
09/26/01
09:00
RPS
74.30
81
25
54.86
532
7.58
MW-M
10/09/01
08:50
RPS
127.63
140
15
58.82
997
6.83
QC DUP
MW-M
10/09/01
08:50
RPS
140
15
QC DUP
MW-N
09/25/01
11:35
RPS
47.53
124
60
56.12
491
7.49
QC DUP
MW-N
09/25/01
11:35
RPS
124
60
QC DUP
MW-P
09/24/01
09:00
RPS
67.19
113
40
55.04
402
7.62
MW-T
10/08/01
08:45
RPS
137.26
144
15
54.68
1007
6.92
QC DUP
463
463
<0.02
MW-T
10/08/01
08:45
RPS
144
15
QC DUP
474!
474
<0.02
MW-U
09/24/01
10:00
RPS
68.74
113
60
55.58
322
7.67
GRUVER
10/01/01
11:40
RPS
NA
NA
15
54.68
448
7.82
LINDSKOG
10/01/01
11:20
RPS
NA
NA
15
57.20
460
7.41
PELLOW
10/01/01
10:55
RPS
72.05
NA
15
57.20
635
7.26
QC DUP
PELLOW
10/01/01
10:55
RPS
NA
15
_
QC DUP
IWELL 1
COD
ICHLORIDE I
Ilab.cond I
Ifluoride I
Ihardness I
Initrate I
Initrite I
ISOLIDS (TDS) I
ISULPHATE I
Iorganic.carboN
uj
o
_i
<
X
6
z
<
o
a:
o
Idis.ai I
DlS.Sb I
MW-208
<5
13.4
393
<0.1
259
3.3
<0.1
331
27.7
<0.5
<0.001
MW-BB
<5
18.3
477
<0.1
319
3.6
<0.1
417
35.6
0.9
0.002
MW-C
<5
13.2
429
<0.1
237
3.0
<0.1
361
29.4
0.7
0.005
P.E.W.
<0.1
5.0
MW-E
<5
9.4
562
<0.01
224
2.9
<0.1
396
24.5
0.6
MW-F
MW-G
MW-H
MW-I
MW-J
MW-J
MW-K
<5
11.4
490
<0.01
3.7
<0.1
330
25.9
0.7
MW-K
<5
12.4
397
<0.01
3.9
<0.1
294
24.5
0.8
MW-L
MW-M
<0.01
5.0
MW-M
<0.01
5.0
MW-N
MW-N
MW-P
MW-T
<5
6.1
631
<0.1
547
8.6
<0.1
531
23.0
2.1
<0.001
MW-T
<5
7.2
1371 lab er
<0.1
540
8.7
<0.1
515
22.9
2.2
<0.001
MW-U
GRUVER
LINDSKOG
PELLOW
PELLOW
11/5/2009
Page 1 of 5
organics in ug/L, others in mg/L
-------
North Landfill Fourth Quarter 2001
IWELL 1
V)
<
ui
~
iDIS.Ba I
lDIS.Be I
iDIS.Cd I
iDIS.Cr I
iDIS.Co I
iDIS.Cu I
iDIS.Fe I
iDIS.Pb I
DIS.Mn I
iDIS.Ha I
iDIS.Ni I
lDIS.Se I
MW-208
0.006
0.07
<0.001
<0.001
0.003
<0.001
0.001
0.13
<0.001
0.002
<0.001
<0.001
MW-BB
0.001
0.047
<0.001
<0.001
0.004
<0.001
0.001
0.2
<0.001
>01
0.001
>01
MW-C
0.003
0.052
<0.001
<0.001
0.005
<0.001
0.002
0.15
<0.001
0.002
<0.001
>01
P.E.W.
MW-E
0.12
0.002
MW-F
MW-G
MW-H
MW-I
MW-J
MW-J
MW-K
0.13
0.003
MW-K
0.14
0.003
MW-L
MW-M
MW-M
MW-N
MW-N
MW-P
MW-T
0.002
0.049
<0.001
<0.001
0.005
<0.001
0.002
0.27
<0.01
<0.001
0.001
0.002
MW-T
0.002
0.051
<0.001
<0.001
0.003
<0.001
0.002
0.28
<0.01
<0.001
0.001
<0.001
MW-U
GRUVER
LINDSKOG
PELLOW
PELLOW
-I
-I
111
s
Ol
<
ui
~
Idis.ti I
Idis.v I
DlS.Zn I
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iBarium I
iBervlium I
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3
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Ichromium I
ICobalt I
MW-208
<0.001
<0.001
0.003
0.012
0.006
0.076
<0.001
51.5
0.003
MW-BB
<0.001
<0.001
0.003
0.01
0.001
0.045
<0.001
74.7
0.002
MW-C
<0.001
<0.001
0.002
0.014
0.003
0.054
<0.001
52.7
0.001
P.E.W.
<0.001
0.001
0.08
<0.001
0.002
MW-E
0.01
0.002
0.059
<0.001
56.7
0.001
MW-F
MW-G
MW-H
MW-I
MW-J
MW-J
MW-K
0.012
0.003
0.059
<0.001
58.7
0.001
MW-K
0.01
0.003
0.055
<0.001
57.6
0.001
MW-L
MW-M
0.002
0.09
<0.001
0.002
MW-M
0.002
0.098
<0.001
0.001
MW-N
MW-N
MW-P
MW-T
<0.001
<0.001
0.002
0.013
0.002
0.054
<0.001
123
0.005
MW-T
<0.001
<0.001
0.002
0.014
0.002
0.054
<0.001
120
0.003
MW-U
GRUVER
LINDSKOG
PELLOW
PELLOW
11/5/2009
Page 2 of 5
organics in ug/L, others in mg/L
-------
North Landfill Fourth Quarter 2001
-I
-I
111
s
0)
Q
Q
O
o
Iron
Lead
Maanesium I
iManaanese I
Mercury I
iNickel I
IPotassium I
ISelenium I
Isilver I
ISodium I
iThallium I
IVanadium I
MW-208
0.001
0.21
<0.001
31.7
0.003
<0.0002
4.3
<0.001
<0.001
6.6
MW-BB
<0.001
0.19
<0.001
32.1
<0.001
<0.0002
4.7
<0.001
<0.001
7.6
MW-C
0.001
0.23
<0.001
25.7
0.002
<0.0002
3.6
<0.001
<0.001
6.2
P.E.W.
0.001
<0.0002
0.001
<0.001
MW-E
<0.001
0.22
<0.001
20
0.004
<0.0002
3.3
<0.001
<0.001
MW-F
MW-G
MW-H
MW-I
MW-J
MW-J
MW-K
0.001
0.43
<0.001
22.3
0.003
<0.0002
3.4
0.001
<0.001
MW-K
0.001
0.36
<0.001
21.7
0.003
<0.0002
3.5
<0.001
<0.001
MW-L
MW-M
<0.001
<0.0002
MW-M
<0.001
<0.0002
MW-N
MW-N
MW-P
MW-T
0.002
0.28
<0.001
58.2
<0.001
0.0001
8.2
0.002
<0.001
6.6
MW-T
0.002
0.28
<0.001
58.3
<0.001
<0.0002
8
<0.001
<0.001
6.6
MW-U
GRUVER
LINDSKOG
PELLOW
PELLOW
WELL 1
ZINC
Itotal coliform I
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IChloroform 100ma/L I
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i
ketrachloroethene oerc I
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krans-1,2-dichloroethene I
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MW-208
0.012
<2
<2
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<2.5
<0.5
<0.5
MW-BB
0.008
<2
<2
<0.5
<0.5
<0.5
3.7
<0.5
<0.5
<0.5
<2.5
<0.5
0.5
MW-C
0.013
<2
<2
<0.5
<0.5
<0.5
0.5
<0.5
<0.5
<0.5
<2.5
<0.5
0.5
P.E.W.
<2
<2
<0.5
<0.5
<0.5
3.1
<0.5
<0.5
<0.5
<2.5
<0.5
<0.5
MW-E
0.01
<2
<2
<0.5
<0.5
<0.5
0.6
<0.5
<0.5
<0.3
MW-F
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.3
MW-G
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.3
MW-H
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.3
MW-I
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.3
MW-J
<0.5
<0.5
<0.5
2.9
<0.5
0.5
<0.3
MW-J
<0.5
<0.5
<0.5
2.8
<0.5
0.5
<0.3
MW-K
0.012
<2
<2
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.3
MW-K
0.01
<2
<2
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.3
MW-L
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.3
MW-M
4
<2
<0.5
<0.5
<0.5
5.5
<0.5
0.5
<0.3
MW-M
17
<2
<0.5
<0.5
<0.5
5.2
<0.5
0.6
<0.3
MW-N
<0.5
<0.5
<0.5
2.1
<0.5
0.5
<0.3
MW-N
<0.5
<0.5
<0.5
2.1
<0.5
0.5
<0.3
MW-P
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.3
MW-T
0.013
<2
<2
<0.5
<0.5
<0.5
4.9
<0.5
<0.5
<0.3
<2.5
<0.5
<0.5
MW-T
0.014
<2
<2
<0.5
<0.5
<0.5
4.7
<0.5
<0.5
<0.5
<2.5
<0.5
<0.5
MW-U
<0.5
<0.5
<0.5
0.6
<0.5
<0.5
<0.3
GRUVER
<0.5
<0.5
<0.5
0.6
<0.5
<0.5
<0.3
LINDSKOG
<0.5
<0.5
<0.5
0.5
<0.5
<0.5
<0.3
PELLOW
<0.5
<0.5
<0.5
4.7
<0.5
0.5
<0.3
PELLOW
<0.5
<0.5!
<0.5
4.8
<0.5
0.5
<0.3
11/5/2009
Page 3 of 5
organics in ug/L, others in mg/L
-------
North Landfill Fourth Quarter 2001
a>
e
£
(S
£
"3
c
(0
£
a>
ll ,4-dichlorobenzene
ll ,2-dichlorobenzene
CN
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ll .1,2-trichloroethane
0)
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E
£
o
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O
£
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o
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o
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u
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IWELL
ll ,2-dichloroethane
Ichloroethane
ll-1dichloroethene
£
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o
o
.£
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T3
Csl
(/)
O
0)
£
O
£
(S
X
0)
£
CSI
iBromo methane
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£
a>
E
o
o
£
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o
n
a>
E
o
o
£
O
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o
Ichloromethane
Idibromometvhane
a>
E
o
o
£
O
O
E
o
n
Idichloromethane
liodomethane
MW-208
<0.5
<0.5
<0.5
<0.5
<2.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
MW-BB
<0.5
<0.5
<0.5
<0.5
<2.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
MW-C
<0.5
<0.5
<0.5
<0.5
<2.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
P.E.W.
<0.5
<0.5
<0.5
<0.5
<2.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
MW-E
MW-F
MW-G
MW-H
MW-I
MW-J
MW-J
MW-K
MW-K
MW-L
MW-M
MW-M
MW-N
MW-N
MW-P
MW-T
<0.5
<0.5
<0.5
<0.5
<2.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
MW-T
<0.5
<0.5
<0.5
<0.5
<2.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
<0.5
MW-U
GRUVER
LINDSKOG
PELLOW
PELLOW
11/5/2009
Page 4 of 5
organics in ug/L, others in mg/L
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North Landfill Fourth Quarter 2001
MW-208
MW-BB
MW-C
P.E.W.
MW-E
MW-F
MW-G
MW-H
MW-I
MW-J
MW-J
MW-K
MW-K
MW-L
MW-M
MW-M
MW-N
MW-N
MW-P
MW-T
MW-T
MW-U
GRUVER
LINDSKOG
PELLOW
PELLOW
<0.5
<0.5 "
<0.5 "
<0.5 "
<0.5
<0.5 "
<0.5
~<05t
~<05T
<0.5 j
<0.5
<0.5
"'
-------
"Fees, William J. (ECY)"
09/16/2008 04:31 PM
cc
bcc
Subject FW: pew diversion samples-Northside Landfill
To Ellie Hale/R10/USEPA/US@EPA
Another one.
Original Message
From: Fowler, Dean [mailto:DFowler0SpokaneCity.org]
Sent: Tuesday, January 08, 2002 9:40 AM
To: Fees, William J.
Cc: 'neil thompson'; Holderby, Steve; Hairston, Monica
Subject: pew diversion samples-Northside Landfill
Bill, This attachment shows you the results of three consecutive months
of monitoring for the PEW diversion. This completes the pilot period of
operation. Do you suggest we meet to discuss the future operation of the
PEW? ...or I can send you a letter requesting a modification to our
treatment plan. With the better than expected results of the
pilot...the city will continue to operate the diversion through the
interim.
I look forward to hearing from you! !
«pew diversion samples . xls»
Dean Fowler, P.E.
Senior Engineer
City of Spokane, Solid Waste Management
1225 E. Marietta Avenue
Spokane WA 99207-2787
Phone: (509)625-7890
FAX: (509)625-7899
E-Mail: dfowler0spokanecity.org
pew diversion sannples.xls
-------
Northside Landfill PEW Diversion / Sample events
Tetrachloroethane (PPB)
10/10/01 11/8/2001 12/10/2001
Sample point
pew 4.8 / 4.3 5.0/4.8 4.2/3.8
basin 1.0/1.0 1.0/1.2 0.8/0.9
% reduction > 78% 78% 79%
well BB 3.4/3.7 4.1/3.9 4.2/4.0
Note: analysis for vinyl chloride, trichloroethylene, 1,1,1-trichloroethane,
l,2-(trans) dichloroethylene, 1,1-dichloroethane, and chloroform show
"non-detect" at all sample locations and events
Actual lab information available at request
Samples taken by Rolf Stratte / City of Spokane Solid Waste Management
-------
"Fees, William J. (ECY)" To Ellie Hale/R10/USEPA/US@EPA
^ cc "Rourke, Melissa (ATG)" ,
09/16/2009 11:09 AM "Hanson, Rich" , Alexander
Fidis/R10/USEPA/US@EPA
bcc
Subject nlfill5yrltr.doc
Ellie,
Attached is the authorizing letter to change the discharge from the POTW
to on-site treatment. I will continue to look for other documents and
send them along.
Regards,
Bill
<>
nlfill5yrltr.doc
-------
August 13, 2002
Mr. Dean Fowler
City of Spokane Solid Waste Management
1225 E. Marietta Avenue
Spokane, WA 99207-2787
Dear Mr. Fowler:
The Washington Department of Ecology (Ecology) has reviewed the submittal requesting
for the permanent diversion of extracted groundwater from the Perimeter Extraction Well
(PEW) into the stormwater ditches at the Northside Landfill. The pilot test results
indicate that the aeration provided in on-site storm water ditches reduces the
tetrachloroethylene (PERC) concentrations by 78 percent. Since the extracted
groundwater PERC concentrations are near the cleanup level of five parts per billion
(ppb), the aeration gives the necessary treatment. Based on our discussions with the
United States Environmental Protection Agency (EPA) during the five-year review
meeting of July 29, 2002, Ecology has the authority to approve this change in treatment
for the extracted groundwater. This letter will serve as formal approval for the permanent
diversion of the pumped groundwater from the PEW.
An additional request to phase the PEW shut down was included in the submittal. The
concept of a phased shut down would allow the City of Spokane to assess the efficacy of
intermittent PEW operation. Ecology supports this concept and will provide the
necessary review and discussion as appropriate for the final shut down of the PEW.
If you have any questions or comments on the enclosed information, please do not
hesitate to contact me at (509) 625-5190.
Sincerely,
William J. Fees, P.E.
Environmental Engineer
Toxics Cleanup Program
CC: Neil Thompson - EPA Region 10
-------
Appendix C: State Concurrence Letter
-------
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
PO Box 47600 • Olympia, WA 98504-7600 • 360-407-6000
711 for Washington Relay Service • Persons with a speech disability can call 877-833-6341
April 21, 2009
Ms. Ellie Hale
US EPA Region 10
1200 6th Avenue
Suite 900 M/S: ECL-115
Seattle, WA 98101
Dear Ms. Hale:
The Washington Department of Ecology (Ecology) has reviewed the Explanation of
Significant Differences (ESD) prepared by the U.S. Environmental Protection Agency for the
Northside Landfill Superfund Site located in Spokane, Washington. Ecology concurs with the
changes presented in the ESD.
James J. Pendowski, Manager
Toxics Cleanup Program
"€11^
o
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