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Fourth Five-Year Review Report Five-Year Review Report Fourth Five-Year Review Report for Marshall Landfill Site Boulder County, Colorado August, 2011 PREPARED BY: u.s. Environmental Protection Agency, Region 8 Denver, Colorado Approved by: Date: Assistant Regional Administrator Office of Ecosystems Protection and Remediation U.S. Environmental Protection Agency, Region 8 [This page intentionally left blank.] Five-Year Review Report Table of Contents List of Acronyms ............................................................................................................................. i Executive Summary ....................................................................................................................... iii Five-Year Review Summary Form ................................................................................................. v 1.0 Introduction .......................................................................................................................... 1 2.0 Site Chronology ................................................................................................................... 2 3.0 Background .......................................................................................................................... 3 3.1 Location and Setting......................................................................................................... 3 3.2 Site History ....................................................................................................................... 4 4.0 Remedial Actions .................................................................................................................... 5 4.1 Remedy Selection ............................................................................................................. 6 4.2 Remedy Implementation .................................................................................................. 7 4.3 Remedy Operation and Maintenance ............................................................................... 8 5.0 Progress since the Last Review............................................................................................ 8 6.0. Five-Year Review Process ................................................................................................... 9 6.1 Administrative Components .......................................................................................... 9 6.1.1 Community Involvement ........................................................................................ 10 6.1.2 Document Review ................................................................................................. 10 6.1.3 Data Review ........................................................................................................... 10 6.1.4 Site Inspection ........................................................................................................ 12 6.1.5 Interested Party Interviews ..................................................................................... 13 7.0 Technical Assessment ........................................................................................................ 14 7.1 Question A...................................................................................................................... 14 7.2 Question B ...................................................................................................................... 15 7.3 Question C ...................................................................................................................... 16 7.4 Technical Assessment Summary ................................................................................ 16 8.0 Issues .................................................................................................................................. 16 9.0 Recommendations and Follow-up Actions ........................................................................ 17 10.0 Protectiveness Statement ................................................................................................... 18 11.0 Next Review....................................................................................................................... 19 Tables Table 1 – Chronology of Site Events Table 2 – Actions Taken Since the Last Five-Year Review Table 3 – Issues Identified Table 4 – Recommendations and Follow-up Actions Figures Figure 1 – Site Location Figure 2 – Water Quality Monitoring Locations Appendix Appendix A – List of Documents Reviewed Appendix B – Site Surface and Ground Water Performance Standards Appendix C – Photo Log of Site Conditions List of Acronyms ARAR Applicable or Relevant and Appropriate Requirements BFI Browning-Ferris Industries CD Consent Decree CDPHE Colorado Department of Public Health and Environment CERCLA Comprehensive Environmental Response, Compensation and Liability Act CFR Code of Federal Regulations EPA United States Environmental Protection Agency ESD Explanation of Significant Difference IC Institutional Controls IR Information Repository LGAC Liquid-phase granular activated carbon MOM Monitoring, Operations and Maintenance NCP National Contingency Plan NPL National Priorities List O&M Operation and Maintenance OU Operable Unit PCE Perchloroethene POC Point of Compliance PRP Potentially Responsible Party RAO Remedial Action Objectives RI/FS Remedial Investigation/Feasibility Study ROD Record of Decision RPM Remedial Project Manager TCE Trichloroethene TDS Total Dissolved Solids VGAC Vapor-phase granular activated carbon VOC Volatile Organic Compounds i [This page intentionally left blank.] ii Executive Summary The United States Environmental Protection Agency (EPA) Region 8 has conducted the fourth five-year review of the remedial actions implemented at the Marshall Landfill Site (Site) in Boulder County, Colorado. The purpose of the five-year review is to determine whether the remedy at the Site is protective of human health and the environment. Because hazardous substances, pollutants or contaminants remain in place at the Site above levels that allow for unlimited use and unrestricted exposure, five-year reviews are required. The trigger action for this review is completion of the third five-year review in September 2006. The Site is located in southeastern Boulder County, approximately one mile east of the town of Marshall and consists of two adjacent landfills, each comprising approximately 80 acres. Together the two landfills, totaling 160 acres, comprise one operable unit (OU1). The Marshall Landfill, in the northern portion of the Site, began operating in 1965, when the Richland Company, under contract with Boulder County, began a solid waste composting and disposal operation at the Site. In 1974, use of the Marshall Landfill was discontinued when Urban Waste Resources, along with Mesa Sand and Gravel, opened the Boulder Landfill to the immediate south, this southern portion of the landfill closed in January 1992. Landfill operations companies changed ownership multiple times by successive corporate acquisition. Republic Services, Inc is the current successor of landfill operations and is a responsible party in conjunction with the City of Boulder. Throughout the period of landfill operations, the land has been owned by The Cowdrey Corporation. Several sources of contamination were identified during the Remedial Investigation/Feasibility Study (RI/FS), which was conducted in 1986. These included areas of saturated refuse, trenches used for waste disposal, small undefined areas where organic solvents were disposed, and two unlined leachate lagoons. Onsite groundwater within the shallow alluvial aquifer was found to be contaminated with volatile organic compounds, heavy metals, chloride, nitrate and sulfate. Flow in the shallow aquifer is generally to the north and northwest and then east along Cowdrey Drainage. No contamination was identified in the deeper bedrock aquifer within the Laramie and Fox Hills Formations. No contamination was detected in surface waters leaving the Site during the RI. However, after completion of the RI, 1, 1 -dichlorethane was detected at 5 micrograms per liter (µg/L) in surface water from the Cowdrey Drainage. The following Remedial Action Objectives (RAO) for the Marshall Landfill Site were developed in the Feasibility Study and Record of Decision (ROD; September 26, 1986): • Assure that all surface water discharge from the landfills does not adversely impact the current or planned future beneficial uses of the surface waters in this area or any other waters that it may contact; • Control the generation of contaminated groundwater at the Site; iii • Assure that any offsite contaminated groundwater originating at the Site does not adversely impact possible beneficial uses of groundwaters in this area or any other surface waters and groundwaters it may contact; and • Eliminate or control impacts resulting from leachate seepage in the landfills. The Site remedy included a groundwater collection and treatment system, landfill improvements, and environmental monitoring programs. The remedy was considered operational in 1993. The collection and treatment system was placed on a stand-by mode in November 2004 after influent to the treatment system consistently met the discharge requirements for the main contaminants of concern. While specific onsite and non-point of compliance monitoring wells have exhibited low level exceedances, the downgradient offsite point of compliance (EPA-18) has consistently met established groundwater
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