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Documents related to this site are located in the Administrative Record at:
EPA Superfund Records Center
Denver, CO
303-312-6473
1-800-227-8917 ext 6473
For questions or comments on the Lowry Landfill Site, contact:
Bonnie Lavelle
US EPA Remedial Project
Manager
Phone: (303) 312-6579
Fax: (303) 312-7151
lavelle.bonita@epa.gov
John Dalton
US EPA Community Involvement Coordinator
(303) 312-6633
or
Lee Pivonka
State Project Manager
(303) 692-3453
(888) 569-1831 ext 3453 toll-free
Marilyn Null
State Community Involvement Coordinator
(303) 692-3304
(888) 569-1831 ext 3304 toll-free
The Lowry Landfill is located immediately northeast of the intersection of Quincy Avenue and Gun Club Road in Aurora, Colorado, in Arapahoe County, approximately 15 miles southeast of downtown Denver. The Site consists of approximately 480 acres, where an estimated 138 million gallons of liquid industrial waste were disposed. The Denver Arapahoe Disposal Site (DADS), an operating municipal solid waste landfill northeast of the intersection of Gun Club Road and East Hampden Avenue, forms the northern boundary of the Site.

Graphic/Photo courtesy of the City and County of Denver and Waste Management
Lowry Landfill is owned and operated by the City and County of Denver. From 1965 to 1980, liquid industrial wastes were co-disposed of with solid industrial and municipal wastes in approximately 78 unlined pits over approximately 200 acres of the 480-acre site. From 1980 through 1990, Waste Management of Colorado, Inc. continued municipal solid waste disposal for Denver. By the late 1980s, ten million tires had accumulated on site.
The site was placed on the National Priorities List in September 1984. The US Environmental Protection Agency conducted the Phase I Remedial Investigation from late-1984 to mid-1986. The investigation found contamination in groundwater, surface water, soils and sediments. The primary contaminants of concern are volatile organic compounds. To address contamination in each of the areas of concern, EPA divided the site into six operable units (OUs):
OU 1: Shallow Groundwater and Subsurface Liquids
OU 2: Landfill Solids
OU 3: Landfill Gas
OU 4: Soils
OU 5: Surface Water and Sediments
OU 6: Deep Groundwater

Graphic/Photo courtesy of the City and County of
Denver and Waste Management
In 1984, Denver constructed an underground barrier wall (North Boundary Barrier Wall) and water treatment system (Old Water Treatment Plant) at the landfill to collect the shallow groundwater and remove organic chemicals. From 1985 through 2000, shallow groundwater collected from the North Boundary Barrier Wall was treated with a combination of air stripping and carbon adsorption. The treated water was returned to the groundwater system in an infiltration trench located north of the North Boundary Barrier Wall. From 1989 to 1991, 120 million pounds of tires (10 million tires) at the site were shredded and placed in an onsite monofill, for later reuse. Subsequently, these tire chips were shipped offsite to a cement kiln for energy recovery purposes.
Record of Decision (ROD)
In March 1994 the EPA and
Colorado Department of Public Health and Environment signed the Record of
Decision outlining the remedial action for the site. The containment remedy
involved installing underground barrier walls
(slurry walls) and groundwater collection systems on the site; constructing of
a new water treatment plant to treat the highly contaminated groundwater;
excavating three accessible waste pits which were under the old tire piles;
and collecting and flare-burning landfill gas. Over the years, the remedy
has been modified to take into account new technologies and new information.
Landfill Gas
A landfill gas extraction and treatment (enclosed flare) system was constructed
in the summer of 1996 and has been operating since January 1997. Landfill
gases from the Denver Arapahoe Disposal Site Section 31 were combined with Lowry
Landfill gases to allow for more efficient continuous operation of the flare
treatment system. The combined landfill gas from the Denver Arapahoe
Disposal Site and Lowry Landfill is now used as fuel for internal combustion
engines to generate electricity.
Wetlands
A replacement wetlands was constructed in April 1997. Floods damaged the
constructed wetlands during the summers of 1997 and 1998. Repairs to the
constructed wetlands were completed in April 1999.
Underground Barrier Walls
In May 1998, the underground barrier walls (slurry walls), located on the south
side of the Site, the southern half of the east side of the Site and the
southern half of the west side of the Site, were completed. The first
generation of performance and compliance monitoring wells were installed in
April 1998. The groundwater extraction trench at the toe of the landfill
(North Toe Extraction System) was constructed in December 1997, but was not
operational until November 2002.
In 1998, a pipeline was constructed to take treated effluent to the Metro Wastewater Reclamation District's Publicly Owned Treatment Works. The New Water Treatment Plant was completed in March 2000 and started receiving groundwater from the North Boundary Barrier Wall and other smaller groundwater extraction operations at the Site at that time. The new water treatment plant started accepting groundwater from the North Toe Extraction System in November 2002.
Groundwater and landfill gas from the site are routinely treated, tested and discharged to the Publicly Owned Treatment Works. Since groundwater is effectively removed from the Site, a potable water line was installed in 1998 to provide water necessary to augment the aquifer water removed through groundwater extraction. This potable water is polished with granular activated carbon to remove trihalomethanes, and this water is recharged to the shallow groundwater aquifer through the trench located immediately north of the North Boundary Barrier Wall.
Former Tire Piles
In September 1998, excavation started on waste pits in the Former Tire Pile Area
and construction was started on a treatment cell for contaminated material
removed from the waste pits. Excavation of the middle waste pit was
completed in April 1999. The remainder of the former tire pile area waste
pit remedy (north and south waste pits) was re-evaluated due to difficult
excavating conditions and fugitive air emissions control issues. A
relatively innovative in-place heating and contaminant extraction process was
tested on the South pit, which resulted in removal of approximately one-half of
the contamination. The North and South Former Tire Pile Area Waste Pit
remedy is now focused on more conventional methods involving pumping of floating
and sinking free product. Floating free product, comprised primarily of
organic compounds (e.g., gasoline) tends to be less dense than water and
accumulated and floats on the water table as Light Non-Aqueous Phase Liquid (LNAPL).
In contrast, Dense Non-Aqueous Phase Liquid (DNAPL) tends to be more dense than
water. DNAPL tends to accumulate and sink. Unless an appreciable
proportion of LNAPL and DNAPL are removed from contact with groundwater, these
liquids will likely result in ongoing contamination of groundwater.
Landfill Cover
The North Face Landfill cover was completed in September 1999. During the
first Five-Year Review in 2001, surface depressions due to settling on top of
the landfill mass were found. These were filled with clean fill and the
cover was regraded in 2002. In March 2004, the Potentially Responsible
Parties (PRPs) developed an Engineering Design and Operations Plan proposing a
relatively proactive approach that, if and when implemented, should effectively
compensate for ongoing settling and minimize the need for future backfilling and
regrading operations.
Asbestos Monofills
The oldest inactive asbestos monofill is located on the east side of the main
landfill mass. The second inactive asbestos monofill is located in the
northwest corner of the Site and as of February 2008, the active asbestos
monofill is located in the west central portion of the Site. The active
asbestos monofill is nearing capacity. Approval has been given for the
development of a fourth asbestos disposal area in the northeast portion of the
Site and construction will likely start on this new cell in 2009 or 2010.
The liquid industrial wastes at the site include sewage sludge, metal plating wastes, petroleum-derived products, pesticides and industrial solvents. Small amounts of radioactive materials have also been detected in the waste pits, sediments, groundwater and soils. This is likely due to a combination of naturally-occurring radionuclides, along with hospital wastes and other household or commercially-related low-level radioactive materials historically disposed in the landfill (e.g., lantern mantles and smoke detectors). More than 50 chemicals of concern have been identified through the risk assessment process. These include, but are not limited to, volatile organic compounds (e.g., vinyl chloride, 1,2-dichloroethane, 1,1-dichloroethylene), semi-volatile organic compounds (e.g., 1,4-dioxane), polynuclear aromatic hydrocarbons (e.g., benzo(a)anthracene), and metals (e.g., arsenic and lead).
Groundwater, surface water, soils and sediments onsite are contaminated. Current health risks from the site are limited because access to the Site is restricted and offsite groundwater used as drinking water is not contaminated by wastes from the Site. The heavily contaminated onsite shallow groundwater is not used as a drinking water source. Because of the large volume of liquid waste destined to remain onsite as part of the containment remedy, it will be necessary to maintain on-going diligent operation of the containment systems. Groundwater and landfill gas monitoring will be necessary to ensure the remedy remains effective.
September 2001
EPA completed the first Five-Year Review for the Lowry Landfill Superfund
Site on September 28,
2001. This Review identified several follow-up actions. While many containment remedy components required by the Record of
Decision are working as intended (e.g., surface water removal action and the
landfill gas extraction and treatment system), the first Five-Year Review Report
identified several groundwater containment remedy issues where questions of effectiveness
remained. Based on the first Five-Year Review recommendations, the EPA
required the Potentially Responsible Parties to develop and execute several work
plans designed to evaluate the conditions at several areas and take necessary
actions to resolve problems identified. After EPA approved the work plans,
additional work was started.
Offsite groundwater contamination has been identified at two locations. The first is associated with the MW38 channel sand located north of the west side of the Site. Onsite pumping and treatment of the MW38 plume resulted in effective containment at the regulatory boundary, also know as the Point of Compliance. The second offsite plume is located north of the Site. Offsite groundwater investigations, conducted from 2005 through 2007, delineated a shallow offsite groundwater plume containing the contaminant 1,4-dioxane above the State standard of 6.1 micrograms per liter. The plume extends approximately 2.5 miles north of the Site.
February 2007
EPA's second Five-Year Review was completed on February 7, 2007. This
review evaluated all actions taken as a result of the first Five-Year
Review. The second Five-Year Review found that the remedy for all six
operable units is functioning as intended. The exposure assumptions,
toxicity data, performance standards and remedial action objectives used at the time of
the remedy selection were found to be valid. EPA found that the remedy for
all six operable units is protective of human health and the environment.
Three new issues were identified in the second Five-Year Review:
Due to unanticipated conditions experienced during initial excavation of the north Former Tire Pile Area waste pit, Denver and Waste Management developed a feasibility study to re-evaluate the Former Tire Pile Area Waste Pit Remedy for the North and South Former Tire Pile Area waste pits. The Former Tire Pile Area Feasibility Study was approved by the EPA on December 30, 2004. EPA prepared a Proposed Plan for the Former Tire Pile Area waste pits and EPA's preferred remedial alternative is currently being implemented. This remedy involves the direct extraction of floating and sinking free product (LNAPL and DNAPL) through vertical extraction wells in and immediately adjacent to the North and South Former Tire Pile Area waste pits. Extraction of product will continue at each extraction well until the floating product is less than six (6) inches thick and the sinking product is less than six (6) inches thick for a period of at least 30 days. Once this performance standard is met, the respective extraction wells will be abandoned. Several extraction wells have already met the performance metric and been abandoned.
In February 2005, the Groundwater Monitoring Plan was approved by EPA and initiated by the Potentially Responsible Parties. The Groundwater Monitoring Plan is designed to provide a single integrated groundwater compliance and effectiveness (performance) monitoring program that supercedes the multitude of pre-existing compliance and effectiveness monitoring plans for the Site. The overall objective of the compliance component of the groundwater monitoring program is to demonstrate that the remedy components collectively result in attainment of the performance standards for groundwater along the point of compliance. The focus of the Groundwater Monitoring Plan is on intrawell statistical analysis of water quality data collected from the groundwater compliance and performance network wells. An intrawell analysis typically evaluates water quality trends at multiple individual sampling points (or wells) through time. The Record of Decision for the site establishes performance standards for a number of chemicals that must be achieved in groundwater. Attainment of the performance standards at the point of compliance helps ensure the protection of human health. The Groundwater Monitoring Plan also establishes decision rules, based on the trends determined from statistical analysis, to determine when and where additional actions may be necessary.
Regarding the effectiveness monitoring program, the overarching objective of the containment features constructed and operated at the Site is to prevent groundwater from being transported from source areas beyond the point of compliance at levels above performance standards. Three remedy components have been implemented to achieve containment of contaminated groundwater at the Site:
The specific design objectives vary among the different containment features at the Site, but each feature ultimately provides a mechanism for hydraulic control with the overarching objective of preventing contaminants transported by groundwater from crossing the regulatory boundary, also called the Point of Compliance. For example, the slurry wall limits both clean groundwater inflow and contaminated groundwater outflow, whereas the North Boundary Barrier Wall collects groundwater to limit down gradient flow to the north beyond the area of groundwater containment created by groundwater extraction at the North Boundary Barrier Wall. As all of these systems are intended to provide hydraulic control, they have similar purposes and objectives; however, given the differences in hydraulic controls provided by each containment feature, the criteria applied to evaluate effectiveness are distinct and detailed in the February 2005 Groundwater Monitoring Plan.
In an ongoing effort to lower concentrations of 1,4-dioxane in offsite groundwater to or below the performance standard, EPA approved a North end (i.e., offsite) Work Plan for an initial response action in 2006. The focus of the offsite efforts are in Section 31 (Denver Arapahoe Disposal Site ), located immediately north of the Superfund site. Currently, groundwater extraction is occurring in three offsite areas:
An offsite pipeline was constructed in December 2007 to facilitate transport of extracted groundwater from these and possibly other offsite areas to the water treatment plant. EPA and the Colorado Department of Public Health and Environment are currently considering a proposal to amend the North End Work Plan for the initial response action to facilitate a more flexible approach targeted at accelerating removal of 1,4-dioxane mass from the offsite plume.
In July 2007, EPA also approved a North End Groundwater Monitoring Plan. This plan is focused on intrawell statistical analysis of 1,4-dioxane groundwater quality data in selected offsite monitoring wells, where the offsite 1,4-dioxane plume is located. The North End Groundwater Monitoring Plan is similar to the 2005 plan, except that it only involves performance monitoring wells (i.e., there are no offsite compliance wells). Data analysis, contemplated in the North End Groundwater Monitoring Plan, is identical to the 2005 onsite Groundwater Monitoring Plan.
Former Lowry Bombing and Gunnery Range project
3/08