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1 <br />Consent Decree Exhibit C <br />2. Method PQL, OR <br />3. Accepted background concentrations if higher than the lowest (most stringent) cleanup <br />level determined via #1, above. <br />Since the highest beneficial use of Site groundwater is proposed to be the protection of surface <br />water quality, the proposed point of compliance for the deep aquifer is located: <br />1. Downgradient of the landfill, between the landfill and the point of discharge into the <br />Snohomish River, <br />2. Outside the boundary of landfilled materials, <br />3. No further than 100' east of the most easterly existing railroad tracks, and <br />4. Within property able to be restricted by institutional controls under the Consent Decree <br />(property controlled by the City or BNSF). <br />Appropriate institutional controls prohibiting the withdrawal of groundwater for domestic water <br />supply are included to ensure that if existing regulations change, the restriction will remain with <br />the Site in perpetuity. <br />3.2.3 Nature and Extent of Groundwater Contamination <br />Groundwater samples collected from the Everett Landfill/Tire Fire Site indicate that water quality <br />in the deep aquifer is generally in compliance with cleanup standards. This condition is evident <br />in data from both the earlier and recent site investigations. Evaluation Monitoring as described <br />in the Compliance Monitoring and Contingency Plan (CMCP, attachment CAP-2) will utilize <br />consistent sampling procedures and an improved monitoring well network in order to confirm <br />conditions in the deep aquifer. Shallow aquifer data do not indicate that widespread <br />contamination exists in the leachate. See Tables 3-2 and 3-3 for contaminants detected in the <br />deep and shallow aquifers. Figure 3-2 shows the existing groundwater monitoring well network. <br />All groundwater data collected to date support the conclusion that there is a low risk of shallow <br />groundwater impacting the deep aquifer above the cleanup levels even at a significant distance <br />upgradient of the compliance point. Reasons for this conclusion are as follows: <br />• High natural organic content of shallow aquifer material, including significant <br />quantities of peat, enhances degradation of contaminants. <br />• Horizontal flow in the shallow aquifer is two to four orders of magnitude greater than <br />potential vertical flow through the aquitard. <br />• Low groundwater flow gradients and low permeability sediments present in both <br />aquifers allow time for chemical breakdown reactions to occur. <br />• The leachate collection trench, installed as an interim action under an Ecology <br />Enforcement Order, acts as a hydraulic barrier for the shallow aquifer preventing flow <br />of leachate to the east. <br />• The western one-third of the landfill overlies natural glacial silt and sand soil that are <br />not considered aquitard soils (i.e., the clayey silt or organic soil). Refuse has been <br />placed in this western one-third of the landfill and has generated leachate (based on <br />observed conditions during recent drilling). Monitoring Wells MW -2, -4, -10, and -15 <br />were completed in this part of the landfill where the aquitard is absent. Water quality <br />FINAL - March 2001 3-4 Everett Landfill Tire Fire Site <br />Cleanup Action Plan <br />r� <br />1 <br />1 <br />1 <br />1 <br />1 <br />1 <br />1 <br />1 <br />1 <br />1 <br />1 <br />L <br />1 <br />n <br />J' <br />1 <br />