EPA/ROD/R03-03/0242003

EPA Superfund

Record of Decision:

KANE & LOMBARD STREET DRUMSEPA ID: MDD980923783OU 02BALTIMORE, MD09/30/2003

RECORD OF DECISION KANE AND LOMBARD SUPERFUND SITE

OPERABLE UNIT TWO

DECLARATION Site Name and Location Kane and Lombard Superfund Site Baltimore, Baltimore County, Maryland CERCLIS ID number MDD980923783 Statement of Basis and Purpose This decision document presents the selected remedial action for Operable Unit Two ("OU2") at the Kane and Lombard Site ("Site") located in Baltimore, Baltimore County, Maryland. This remedial action was chosen in accordance with the requirements of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42 U.S.C. §§ 9601-9675, as amended ("CERCLA"), and, to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan ("NCP"), 40 C.F.R. Part 300. This decision document explains the factual and legal basis for selecting the remedial action for OU2 at this Site. The information supporting this decision is contained in the Administrative Record for this Site. The Maryland Department of the Environment ("MDE") concurs with the selected remedy. Assessment of the Site Pursuant to duly delegated authority, I hereby determine, pursuant to Section 106 of CERCLA, 42 U.S.C. § 9606, that actual or threatened releases of hazardous substances from OU2 of this Site, if not addressed by implementing the response action selected in this Record of Decision ("ROD"), may present an imminent and substantial endangerment to public health, welfare, or the environment. Description of the Remedy This is the second and final phase of remedial action at the Site. The first phase addressed a portion of the former landfill located south of Lombard Street. A multi-layer cap, slurry wall, and dewatering system were completed in August 1990. This phase will address the remainder of the landfill and all areas to which contamination from the landfill has migrated. This response action addresses threats through the treatment of ground water which contains a high concentration of hazardous substances and through institutional controls and a Soil Management Plan to address limited contamination in subsurface soils. The selected remedial action includes the following major components: ? installation of approximately eight wells to inject and recirculate organic carbon; ? Construction of subsurface vaults to contain required tanks and control systems; ? Installation of several additional ground water monitoring wells; ? Collection and evaluation of biogeochemical data and analytical data; ? Institutional controls to manage exposure to workers and prohibit residential development

of properties containing subsurface soil contamination;

? Institutional controls to prevent the use of contaminated ground water; and ? Preparation and implementation of a Soil Management Plan to establish health and safety

requirements for the excavation and disposal of contaminated subsurface soil should property owners elect to excavate such soil in the future.

The selected remedy will provide protection of human health and the environment by restoring contaminated ground water quality to meet or exceed both Federal and State drinking water requirements, prevent use of contaminated ground water until the ground water has been cleaned up, prevent residential use of property within OU2 with subsurface soil containing elevated antimony and/or lead, and ensure the proper excavation, handling, and disposal of such contaminated soils if excavation is undertaken. Statutory Determinations The selected remedial action is protective of human health and the environment, complies with all Federal and State requirements that are legally applicable or relevant and appropriate to the remedial action, is cost-effective, and utilizes permanent solutions and alternative treatment (or resource recovery) technologies to the maximum extent practicable. This remedy also satisfies the statutory preference for treatment as a principal element of the remedy (i.e., it reduces the toxicity, mobility, or volume of hazardous substances, pollutants, or contaminants as a principal element through treatment). The remedial action will result in hazardous substances, pollutants, or contaminants remaining on-Site above levels that allow unlimited use and unrestricted access. Therefore, an assessment of the Site will be conducted no less often than every five years after initiation of remedial action in accordance with Section 121(c) of CERCLA, 42 U.S.C. § 9621(c), to ensure that the remedy is, or will be, protective of human health and the environment. The following information is included in the Decision Summary section of this Record of Decision. Additional Information can be found in the Administrative Record file for this Site. ? Chemicals of concern and the concentration of the most prevalent volatile organic

compounds (page 9); ? Baseline risk represented by the chemicals of concern (page 11 and Tables 3 and 4);

? Example of cleanup levels to be established and the basis for these levels (page 22 and

Table 5); ? How source materials constituting principal threats are addressed (page 36);

? Current and future land use assumptions and current and potential future beneficial uses

of ground water used in the baseline risk assessment and ROD (page 11); ? Potential land and ground water use that will be available at the Site as a result of the

Selected Remedy (page 42); ? Estimated capital, annual operation and maintenance and total present worth cost of the

Selected Remedy (page 43 and Table 7); and Key factors that lead to selecting the remedy (page 37).

/s/ 9/30/03 Abraham Ferdas, Director Date Hazardous Site Cleanup Division Region III

KANE AND LOMBARD SUPERFUND SIT

OPERABLE UNIT # 2

BALTIMORE, MARYLAND

RECORD OF DECISION

KANE AND LOMBARD SUPERFUND SITE OPERABLE UNIT # 2 BALTIMORE, MARYLAND RECORD of DECISION

TABLE OF CONTENTS I. SITE NAME, LOCATION, AND DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . 1 II. SITE HISTORY AND ENFORCEMENT ACTIVITY. . . . . . . . . . . . . . . . . . . . . . . . 1 III. HIGHLIGHTS OF COMMUNITY PARTICIPATION. . . . . . . . . . . . . . . . . . . . . . . . 3 IV. SCOPE AND ROLE OF THE OPERABLE UNIT. . . . . . . . . . . . . . . . . . . . . . . . . 4 V. SITE CHARACTERISTICS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

A. Geographical, Topographical and Hydrogeological Features. . . . . . . . . . . . . 4 B. Human Health Conceptual Site Model . . . . . . . . . . . . . . . . . . . . . . . 7 C. Sampling Activities and Extent of Contamination . . . . . . . . . . . . . . . . . 8

VI. CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES. . . . . . . . . . . . . . . . . 11 VII. SUMMARY OF SITE RISKS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

A. Human Health Risk Assessment Summary. . . . . . . . . . . . . . . . . . . . . . . 11 B. Summary of Ecological Risk Assessment . . . . . . . . . . . . . . . . . . . . . . 16

VIII. REMEDIAL ACTION OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 IX. SUMMARY OF REMEDIAL ACTION ALTERNATIVES. . . . . . . . . . . . . . . . . . . . . . . 21 X. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES. . . . . . . . . . . . . . . . . . . 30 XI. PRINCIPAL THREAT WASTES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 XII. SELECTED REMEDY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 XIII. STATUTORY DETERMINATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 RESPONSIVENESS SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

FIGURES

Figure 1 Site Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 Figure 2 Operable Unit Two Site Plan . . . . . . . . . . . . . . . . . . . . . . . . . . 50 Figure 3 Surface Streams and Stormwater Drainage System. . . . . . . . . . . . . . . . . 51 Figure 4 Conceptual Site Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 Figure 5 Total Selected Volatile Organic Compounds in Ground Water . . . . . . . . . . . 53 Figure 6 Distribution of Iron in Ground Water. . . . . . . . . . . . . . . . . . . . . . 54 Figure 7 Distribution of Dissolved Manganese in Ground Water . . . . . . . . . . . . . . 55 Figure 8 Approximate Area of Elevated Metals in Soil. . . . . . . . . . . . . . . . . . 56 Figure 9 Surface Water, Sediment, and Soil Sampling Locations. . . . . . . . . . . . . . 57 Figure 10 Conceptual Design Schematic Enhanced Reductive Dechlorination System. . . . . . 58

TABLES Table 1 Chronology of Remedial Activities . . . . . . . . . . . . . . . . . . . . . . . 59 Table 2 Hazard Risk Summary - Human Health Risk Assessment. . . . . . . . . . . . . . . 62 Table 3 Summary of Potential Cancer Risks and Non-Cancer Hazards from Ground Water - Future On-Site Adult Resident . . . . . . . . . . . . . . . . . . . . . 63 Table 4 Summary of Potential Cancer Risks and Non-Cancer Hazards from Ground Water - Future On-Site Child Resident . . . . . . . . . . . . . . . . . . . . . 63 Table 5 Ground Water Statutory Requirements and Risk-Based Performance Standards (Example) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64 Table 6 Applicable or Relevant and Appropriate Requirements (ARARs) and Policies to be Considered (TBCs) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 Table 7 Projected Costs for Enhanced Reductive Dechlorination . . . . . . . . . . . . . 67

RECORD OF DECISION KANE AND LOMBARD SUPERFUND SITE

OPERABLE UNIT # 2

DECISION SUMMARY I. SITE NAME, LOCATION, AND DESCRIPTION The Kane and Lombard Superfund Site ("Site") consists of a former landfill located at and near the intersection of Kane and Lombard Streets in the Orangeville Subdivision of Baltimore County, Maryland (see Figure 1) and all areas to which wastes from the landfill have migrated. The Site is split into two operable units. Operable Unit No. 1 ("OU1") of the Site is an 8-acre portion of the former landfill located south of Lombard Street and adjacent to the Patterson High School. OU1 also includes shallow ground water in the first water-bearing zone beneath the 8-acre area. Wastes within OU1 were capped and contained with a slurry wall in 1990. The area is currently used as a golf driving range. A parking lot and cell tower are also located on the property. Operable Unit No. 2 ("OU2") of the Site consists of the remainder of the former landfill located immediately north of OU1 (see Figure 2) and the ground water that has been impacted by the wastes disposed in OU1 and OU2 (excluding the shallow ground water directly beneath OU1 described above). The contaminated ground water plume extends for approximately 6300 feet ("ft.") southeast from the edge of the landfill. OU2 includes the property located north of Lombard Street and west of Kane Street back to the drainage area located adjacent to the rail line. It includes land on which PICORP Inc., Baltimore ("PICORP") operates a shipping container repair business and also includes an undeveloped portion of the Roadway Express property to the west, a portion of the Conrail property to the north, and several smaller properties to the east of PICORP, including parcels occupied by Register Photo and CTI Trucking. II. SITE HISTORY AND ENFORCEMENT ACTIVITY Edward and Harriett Azrael and Albert and Cele Landay acquired much of the land which became the landfill from the Canton Company of Baltimore in 1962. Clearing, excavation, and dumping commenced north of what later became Bayview, and then Lombard Street between 1962 and 1964. At some point between 1964 and 1966 the dumping crossed what subsequently became Lombard Street into OU1 of the Site. Pits, drums, and areas of standing liquid were present in excavated areas on aerial photos dated 1964, 1968, and 1970. By 1971, much of the disturbed area had been filled and construction of Interstate 95 was underway. The filling activities may have been associated with construction of nearby roads. Fill materials may have included construction debris, domestic wastes, and industrial materials. Between 1971 and 1982, the excavated areas west, north, and east of OU1 had been filled and developed. In December 1980, the PICORP Baltimore Land Development Company acquired approximately 17 acres of the landfill area north of Lombard Street from the Azrael Landays. This land is currently leased to PICORP which operates a container storage business on the property. In or around November 1980, the State of Maryland discovered several hundred drums on the OU1 parcel. Following a series of unsuccessful attempts to compel action by the Site owners, the State requested assistance from EPA. EPA conducted a CERCLA removal action in which 1,163 drums and the upper six inches of soil from beneath the drums were removed from OU1 and disposed. Of the drums removed, 822 were classified as RCRA empty. Substances found in the remaining drums included benzene, ethylbenzene, toluene, xylenes, naphthalene, other

polynuclear aromatic hydrocarbons, phthalates, PCBs, cyanide and metals. Following removal of the drums and soil, OU1 was graded, a one to two foot layer of clay was installed, and the area was revegetated. The Site was proposed for inclusion on the National Priorities List ("NPL") in October 1984 and finalized on the NPL in June 1986. In 1985, EPA commenced a Remedial Investigation/Feasibility Study ("RJ/FS") at OU1 to ascertain the nature and extent of contamination at this location. On September 30, 1987, EPA issued a Record of Decision ("ROD") selecting remedial action for implementation at OU1. The selected remedial action primarily called for construction of a multi-layer cap and a slurry wall around the impacted area and dewatering of the first water-bearing zone contained within the wall via two extraction wells. The remediation was also to include removal of drums and hot spots identified during the RJ; however, the drums and hot spots were not located during construction activities and were therefore not removed. Construction activities were completed in August 1990. During implementation of the remedial action, most of the existing ground water monitoring wells was removed. Twenty-one monitoring wells and twelve gas vents were installed in conjunction with the containment system. Operation and maintenance of the OU1 remedial system is ongoing. Any water withdrawn from the extraction wells is discharged to the City of Baltimore sanitary sewer system following pre-treatment. The extraction system has not pumped water since 1997 because the waterbearing unit beneath OU1 has apparently been dewatered. On September 19, 1996, Harriet and Edward Azrael transferred ownership of OU1 to Someday, Inc. On February 18, 1998, pursuant to a prospective purchaser agreement with EPA, Double Eagle Enterprises acquired the property from Someday, Inc. and subsequently constructed a golf driving range on the property. That driving range is currently operated by Bayview Golf Center, Inc. In 2001, a cell tower was constructed over a portion of the parking lot for the driving range. Investigation of the OU2 area began in 1985 with a preliminary assessment of the PICORP property by the Maryland Waste Management Administration ("MDWMA"). On February 20, 1985, MDWMA identified miscellaneous debris, including wood, tires, construction debris and empty, crushed 55-gallon steel drums. MDWMA also reported identification of fourteen 55-gallon drums. Nine of the drums were empty and the remaining five reportedly contained waste oil. In 1990, the Maryland Department of the Environment ("MDE") commenced an RI/FS at OU2. This study was discontinued in 1993, when EPA and several parties associated with the Kane and Lombard Site entered into a consent order under which such parties were to perform an RI/FS at OU2. A summary of the chronology of major OU2 RI/FS events is provided in Table 1. The OU2 RI/FS was accepted in July 2002. III. HIGHLIGHTS OF COMMUNITY PARTICIPATION On December 20, 2002, pursuant to section 113(k)(2)(B) of CERCLA, 42 U.S.C. § 113(k)(2)(B), EPA released for public comment the Proposed Remedial Action Plan ("Proposed Plan") setting forth EPA's preferred alternative for OU2. The Proposed Plan was based on documents contained in the Administrative Record File for OU2. EPA made these documents available to the public in the EPA Administrative Record Room in Region III's Philadelphia office, and at the local information repository in the Enoch Pratt Free Library, Patterson Park Branch, Baltimore. A notice of availability of these documents was published in the Baltimore Sun on December 20, 2002. EPA and MDE held a public meeting on January 8, 2003 at Patterson High School on Kane Street in Baltimore. EPA opened a 30-day public comment period on December 20, 2002 to receive comments on EPA's preferred alternative and the other alternatives identified in the Proposed Plan. EPA extended the comment period an additional 30 days until February 21, 2003. Comments received during this public comment period, as well as EPA's response to such comments, are summarized in the Responsiveness Summary section of this ROD. A detailed discussion of the recent community activities is presented in Section X under the subheading "Community Acceptance." More detailed documentation on the information contained in this ROD may be found in the OU2 Administrative Record which contains the RI, FS, and other information used by EPA in the decision making process. EPA encourages the public to review the OU2 Administrative Record in order to gain a more comprehensive understanding of the operable unit and the activities that

have and will been conducted there. The OU2 Administrative Record has been placed in the Enoch Pratt Free Library, Patterson Park Branch, located at 158 N. Linwood Avenue in Baltimore, Maryland (410) 396-9068). A copy of the OU2 Administrative Record is also available at the EPA Region UJ Office located at 1650 Arch Street in Philadelphia, Pennsylvania. To review the OU2 Administrative Record at EPA's Philadelphia office, contact Ms. Anna Butch, Administrative Record Coordinator, at (215) 814-3157. The OU2 Administrative Record can also be accessed on the web at www.epa.gov/arweb. Copies of this ROD are available for public review in these information repositories. IV. SCOPE AND ROLE OF OPERABLE UNIT The Kane and Lombard Site consist of two operable units. OU1 includes a portion of the former landfill located south of Lombard Street. EPA selected the remedy for OU1 in a ROD signed on September 30, 1987. Construction of the multi-layer cap, slurry wall, and dewatering system at OU1 was completed in August 1990. The second operable unit, OU2, the subject of this ROD, includes the remainder of the landfill and all areas to which contamination from the landfill has migrated. OU2 consists primarily of impacted ground water in an aquifer beneath the Site. Ingestion of water extracted from this aquifer poses a potential future risk to human health. OU2 additionally includes isolated locations of soil contamination that present future risks to human health. This ROD addresses these risks and presents the final response action for this Site. V. SITE CHARACTERISTICS A. Geographical, Topographical, and Hydrogeological Features The area west of Kane Street and north of Lombard Street is primarily urban industrial properties. A limited portion of the area contains vegetated swales and culverts. PICORP occupies most of the OU2 area to the north of Lombard Street. Smaller portions of OU2 extend onto an undeveloped portion of the Roadway Express ("Roadway") property to the west, a portion of the Conrail property to the north, and several smaller properties to the east of PICORP, including parcels owned by Register Photo and CTI Trucking. Permanent structures within OU2 consist of a PICORP office and maintenance building, the Register Photo building, and two small buildings on the CTI Trucking property. In addition, there are typically 1,500 to 2,500 shipping containers on the PICORP property at any given time. Several abandoned underground storage tanks are located on the PICORP property but were not investigated by EPA. It should be noted that the underground storage tanks located on the PICORP property were not the subject of the OU2 RI/FS and their removal was not considered as a component of any of the remedial alternatives considered. Remediation of the underground storage tanks is proceeding under the jurisdiction of MDE. Other significant structures include sidewalks and utilities along Kane and Lombard Streets and the treatment system, cap, and slurry wall associated with the OU1 remedial action. OU2 is generally bordered by a railyard to the north, North Point Boulevard to the northeast, Patterson High School to the south, recreational fields and Kane Street to the east, and the Roadway trucking terminal to the west. The remainder of OU2 includes the area impacted as a result of ground water contamination. This area extends to the southeast and is currently bounded by a monitoring well network which extends for approximately 6,300 ft. Numerous structures including various businesses and residences are present on the surface above the area of ground water contamination; interstate 95 and Eastern Avenue are two of the major roads that are present above a portion of the ground water plume. Surface water resources consist of wetlands, wetland buffer areas, floodplains, streams, and the stormwater drainage system. Approximately four acres of wetland habitats were delineated within the Phase n Baseline Ecological Assessment ("BEA") area. The sole palustrine wetland type identified was 1.5 acres of palustrine emergent wetlands adjacent to the northern slope and the western side of the PICORP facility and adjacent to the west side of the OU1 area. The remaining 2.5 acres of wetlands identified include four riverine wetland types associated with Herring Run, riverine intermittent streambed, riverine lower perennial unconsolidated bottom

permanent, riverine lower perennial beach/bar intermittently seasonal, and riverine lower perennial beach/bar intermittently flooded. OU2 is located outside of the boundaries of the 100-year floodplain. Herring Run is a perennial stream located approximately one-third of a mile north of OU2. The Herring Run channel is approximately 60 feet wide, two to three feet deep, and has a sand and gravel substrate with occurrences of clay. The present channel of Herring Run was created by a state and county channelization project prior to 1972. The original path of Herring Run, prior to channelization, consisted of a series of channels winding through the Quad Avenue area. The OU2 investigation also identified one possible perennial stream channeled underground by the stormwater drainage system and two unnamed intermittent streams (see Figure 3). Herring Run and all its tributaries upstream of the Interstate 95 bridge are designated by the State as recreational trout waters. This use designation includes cold or warm waters that have the potential for, or are capable of, holding or supporting adult trout for put-and-take fishing and managed as a special fishery by periodic stocking and seasonal catching. As shown in Figure 3, runoff from the Site generally drains to the east with some drainage to the west. Runoff from the eastern portion of the Site is controlled by a swale lined with riprap and is channeled into an underground stormwater drainage pipe in the northeast comer of the Site. The storm-water drainage pipe channels the runoff to the north under Lombard Street and then under the PICORP facility. Runoff from the western portion of the Site flows west into the adjacent wetlands. Runoff flowing into these wetlands is channeled through a drainage swale to the north across Lombard Street and then to the east along the northern side of the PICORP facility. The eastern and western runoff flow paths from the Site connect at a point on the northern side of the PICORP facility in a depression which functions as a catch basin. From this catch basin, the stormwater drains north under the Conrail Yard via a single underground stormwater pipe, and then flows to the northeast terminating at Herring Run. In summary, drainage from the OU1 area and areas to the south of OU2 is controlled primarily by a system of underground stormwater drainage pipes. This system drains to the north through underground pipelines and culverts terminating at a single point on Herring Run. OU2 is located in the Atlantic Coastal Plain Physiographic Province, near the Fall Line that separates the Coastal Plain from the Piedmont Plateau. The Coastal Plain consists of Cretaceous Age and younger sediments that form a series of wedge-shaped formations that dip and thicken to the southeast. Precambrian Age crystalline bedrock unconformably underlies these sediments. The bedrock consists primarily of granite, schist, gabbro, diorite, gneiss, and marble. In many areas the upper portions of the bedrock have decomposed to saprolite, a clayey material that retains many of the structural features of the parent rock. The depth to bedrock at the Site is unknown, though it is expected to be 140 to 300 feet below grade in OU2. Bedrock is typically not developed as a ground water supply where it is overlain by a significant water-bearing unit. Ground water occurs in three separate zones within OU2. The first water-bearing zone consists of shallow, perched, ground water near the base of the fill layer, approximately 4 to 26 feet below grade, and is limited in areal extent. In 1990 a multi-layer cap and a slurry wall were installed at OU1 which was designed to restrict ground water flow in the first water bearing zone. The slurry wall was constructed through waste materials and two ground water extraction wells were installed near the northeast corner of OU1. Twenty-one monitoring wells were installed by May 1990. Most are paired wells inside and outside the slurry wall to monitor the effectiveness of the slurry wall. Two extraction wells were pumped to dewater the surficial aquifer and reduce hydrostatic head inside the slurry wall. No water has been pumped since 1997 due to the low water level in the extraction wells, which suggests that the first water- bearing zone inside the slurry wall may be partially dewatered. In OU2, the Arundel clay separates the first and second water- bearing zones. In the immediate vicinity of the Site, the top surface of the Arundel Formation generally mimics the land surface and is thinnest just northeast of the Site. Evidence of channel gravel deposits were identified during the drilling of well 4-M, suggesting that the thinning of the Arundel Formation represents a possible erosional surface from an ancient stream which may have flowed toward the northeast. The ancient stream may have breached the Arundel Formation providing a

pathway for contaminants to migrate from the first to second water-bearing zone. Locally, the Arundel Formation ranges from 0 to 82 feet thick. The second water-bearing zone occurs in the upper portion of the Patuxent Formation which consists of predominantly fine sand and silty clay though discontinuous lenses of gravel and silty clay are common. The Patuxent Formation is of continental origin, characterized as fluvial sedimentation that occurred primarily in a braided-stream environment. The upper Patuxent aquifer in OU2 is thinnest in the vicinity of OU1. West of the Site and east of Interstate 95 the upper Patuxent aquifer thickens to greater than 70 feet. The Patuxent Formation has been extensively developed as a source of both public and industrial ground water supplies in the vicinity of Baltimore. Locally, the Patuxent Formation has been divided into an upper and lower aquifer separated by a silky slay middle acquitard which appears to extend across OU2, separating the - second and third water-bearing zones. The third water-bearing zone occurs in the lower Patuxent Formation. The lower Patuxent aquifer was not fully penetrated during the OU2 RI/FS; therefore, the thickness of the lower Patuxent aquifer at OU2 has not been confirmed. This unit is separated from the second water-bearing zone by a silty clay layer that is believed to be continuous across OU1. Four monitoring wells (11W-145, 5D, 6D, and 7D) are screened within the third water-bearing zone. The bottom of the screened intervals for the four deep wells range from 140 to 160 feet below grade. Static water levels in the deep wells are approximately 50-70 feet above the top of the sand unit first encountered below the aquitard in the Patuxent Formation indicating that this unit is confined. Except for the property located above the down gradient plume of contaminated ground water, OU2 is located in an industrial area of Baltimore. The contaminated ground water migrates down gradient from OU1 and OU2, passing below I-95 and migrating below an area containing residential, commercial, and industrial properties. Land use for this highly developed urban area in Baltimore is likely to remain the same in the future. There are few, if any, undeveloped properties, and the residential areas consist primarily of row houses that are located in a stable, long-standing neighborhood. The surrounding land use is mixed industrial/commercial and residential. Potential off- landfill receptors that were evaluated include residents located downwind of OU2 who may be exposed to Site-related contaminants via inhalation of ambient air, and trespassers who may come into contact with soils in the surface drainage area located at the northern property boundary of OU2. Potential future exposure to ground water used as a potable water supply was also evaluated. This exposure pathway is unlikely to be complete in the immediate future because of a prohibition on installing potable water supply wells within the City of Baltimore. B. Human Health Conceptual Site Model A Conceptual Site Model was developed to identify which human exposure pathways were complete or could be potentially complete in the future. The following discussion identifies complete pathways for potential on-site and off-site receptors as depicted in Figure 4, the Site Conceptual Model. Trespassers may be exposed to contaminants in surface water, sediment and soil via incidental ingestion and dermal contact. Exposure via inhalation of fugitive dust was considered insignificant as compared to the direct exposure pathways. Construction workers may be exposed to contaminants in surface and subsurface soil during excavation activities via incidental ingestion, dermal contact and inhalation of fugitive dust and volatile organic contaminants ("VOCs"). Depth to ground water within OU- 2 is approximately 50 feet below the ground surface, therefore construction workers are not expected to come into contact with contaminated ground water during excavation activities. Industrial workers may be exposed to vapors from contaminated soil and ground water via migration to indoor air. Soil gas data were collected to evaluate this combined pathway. Industrial workers are not exposed to potentially contaminated surface soils because the majority of the former landfill is covered with six to eight inches of a bentonite mixture. Other areas within OU2 are covered with concrete, pavement, and roadways.

Off-site residents may be exposed to contaminants in soil via inhalation of fugitive dusts and VOCs in soil via the inhalation of soil gas that migrates from the Site. The migration of soil gas to off-site residential receptors was not evaluated quantitatively because the risks for on-site receptors (i.e., industrial workers) exposed to soil gas vapors were several orders of magnitude below EPA's target upper-bound lifetime cancer risk range. Although residential exposures are typically greater than industrial exposures, the difference in exposure is far less than an order of magnitude. Future hypothetical exposure to ground water via ingestion and dermal contact and inhalation of VOCs during showering was also evaluated. It should be noted that the use of ground water as a potable water supply is prohibited in the City of Baltimore. C. Sampling Activities and Extent of Contamination OU2 has been investigated using soil gas sampling, soil borings, and wells. Samples were also collected from the surface water, sediments, and/or surface soils from the intermittent stream channels, drainage basin, wetlands area, and storm water drainage pathway. Nine soil borings were drilled prior to 1997 to characterize the geology and distribution of VOCs in the unsaturated zone and, at most locations, down to the base of the second water- bearing unit (i.e., the upper Patuxent Formation). A focused investigation was conducted in 1997 to try to identify areas that could potentially serve as ongoing sources of ground water contamination. Three phases of soil gas sampling identified areas of elevated VOC concentrations and sampling of four additional soil borings in the vadose zone identified zones of unsaturated soil with elevated VOC concentrations. Levels of VOCs in unsaturated soil range from 0.001 to 880 mg/Kg. Beyond a sheen noted in two borings, nonaqueous phase liquids were not observed in the soil. Of the forty-three OU2 wells, thirty wells have been drilled well south of the landfill proper to investigate and characterize downgradient ground water quality. Ground water has been impacted by contaminants to a distance of approximately 6,300 feet downgradient (southeast) of the landfill. The three most common VOCs detected in ground water from all wells over the last ten years are trichloroethene ("TCE"), cis-l, 2-dichloroethene ("cis-DCE"), and vinyl chloride ("VC"). Although individually variable, the sum of these constituents consistently accounts for 95 percent of all VOCs in ground water in virtually every well; based on data since 1995 (an exception is 1998 data which contained anomalous levels of acetone, a common lab contaminant). The two wells with the highest total selected VOC concentrations (cis-DCE, TCE and VC) have been Wells 12-M and 17-MB. Well 12-M is located near the southeastern boundary of OU- 2 and well 17-MB is located approximately 500 feet southeast of OU-2 (see Figure 5). Historical maximum concentrations of TCE, cis-DCE and VC are 3,400 ug/L, 24,000 ug/L, and 4,300 ug/L, respectively, from well 17-MB. Monitoring data from 1998 to 2001 reveals that concentration of VOCs in water from 12-M and 17-MB has declined significantly. The contaminant mass in the northern third of the plume (north of Baltimore St.) has been greatly reduced, and the area of the "core" of the plume (>10,000 ug/L total selected VOCs), has apparently been reduced by approximately one-third in size from 1998 to 2001. The most recent ground water sampling event, conducted in May 2001, shows that the highest concentrations of VOCs in ground water were detected in the middle area of the plume in the vicinity of Wells 20-M and 23-M. Total selected VOC concentrations in this portion of the plume are above 10,000 ug/L. No apparent widespread or significant changes have occurred in concentrations of VOCs in ground water from wells in the southern portion of the plume (south of Eastern Avenue) for the period of data collection. Additional data are necessary to establish long-term trends in water quality. As illustrated on Figure 5, a VOC ground water plume in the second water-bearing unit, the Upper Patuxent Formation, currently extends approximately 6,300 feet downgradient of OU1. An area of elevated metals concentrations, consisting primarily of dissolved iron and manganese, roughly coincides with the shape of the VOC plume (see Figures 6 and 7). The dissolved iron and manganese are likely metabolic by-products of anaerobic respiration processes identified throughout the majority of the plume. Thallium was slightly elevated in several isolated areas. It is not certain that thallium is a Site-related problem because there is no obvious spatial pattern or trend to the locations

where it was detected. Detections of thallium have appeared only slightly above the level observed in the samples collected from background well 15M. The monitoring wells are located along the entire ground water flow pathway, from the source, through the central area of the plume and extending to the downgradient edge. Ground water flow within the second water-bearing zone is to the southeast and moves at an average linear velocity of approximately 0.36 ft/day, or 131 ft/year. Site-related constituents present in the ground water would be expected to move at slower rates, given the effects of adsorption and other processes. A comprehensive review of the ground water VOC data and the biogeochemical data was performed to evaluate various fate and transport phenomena affecting the concentrations of select VOCs, mainly TCE, cis-DCE, and VC. The presence of biological degradation products from TCE (cis-DCE, VC, ethene, and ethane) confirms that reductive dechlorination is actively occurring in- situ. A range of indicator parameters were analyzed during recent sampling events to define the biogeochemical environment and evaluate the potential for intrinsic bioremediation. Biogeochemical parameters show that the subsurface environment in the core of the plume is characterized by a reducing environment and is conducive to reductive dechlorination. Nine exploratory soil borings were installed during the OU-2 investigation to evaluate subsurface soils. Surface soil samples were not collected because surface soils predominantly consist of non- native cover materials (i.e., pavement, sidewalks) installed as part of the development of the property into a commercial and industrial area. In addition, a partial cover of six to eight inches of a bentonite/soil mixture was constructed over the majority of the former landfill area. Subsurface soil samples identified a limited area with elevated metals located immediately north of the intersection between Kane and Lombard Streets (see Figure 8). The area of contaminated subsurface soil is located approximately 400 feet north of the intersection between Kane and Lombard Streets, extending from Kane Street (and possibly beneath the Street) to the northwest. The trend of lead contaminated subsurface soils was detected in four soil borings at concentrations ranging from 322 to 25,700 ppm. The central portion of this area contains elevated antimony at 364 ppm, though it was only detected at a level of concern at one location (Exploratory Boring #12). Residual VOCs were detected in the same area during the Phase I and Phase n Soil Gas Assessment which evaluated thirty locations. The VOCs in the subsurface soil may continue to contribute limited contamination to the ground water, though natural processes, including biodegradation, would reduce the concentration of VOCs in the soil. Declining concentrations of contamination in ground water near the source area provides initial evidence that such processes may already be occurring. The results of the ecological assessment indicate that potential impacts to soil, sediment, and surface water are localized within the drainage swale located north of the PICORP property and are not ecologically significant. VI. CURRENT AND POTENTIAL FUTURE LAND AND RESOURCE USES The Patuxent Formation, a regional aquifer, has been extensively developed as a source of industrial ground water in the Baltimore area. Pumpage from the Patuxent Formation in the Baltimore area began around 1850 and increased to more than 35 million gallons per day ("MOD") in the early 1940s. After 1945, pumpage gradually decreased to less than 5 MGD in 2000. Current pumpage is exclusively used for non-potable purposes. The closest downgradient user is Federal (Red Star) Yeast, approximately 2 miles to the south and screened in the lower Patuxent Formation. Residences and other users of potable water in the area of the downgradient plume use public water supplied by the Baltimore City water system. The Baltimore City water system has ample supplies for at least the next 25 years. It is projected that in the year 2025, their total system capacity will be more than twice the projected demand. The Department of Public Works does not have any plans to use ground water as a source of potable water since the current surface water supplies more than adequately meet the demands on the potable water supply

system. In addition, the Baltimore County code regulates public and private water supplies and prohibits the construction of new water supplies without the approval of the County when public water is available. All surface waters of the State are designated as Use I waters, which includes water contact recreation, fishing and the protection of aquatic life. No other surface waters within OU2 are provided additional protection, beyond Use I, under the State regulations. Herring Run and all of its tributaries above (i.e., upstream of) the Interstate 95 bridge are designated as Use IV waters, or recreational trout waters. This use or designation includes cold or warm waters that have the potential for, or are capable of, holding or supporting adult trout for put-and-take fishing and managed as a special fishery by periodic stocking and seasonal catching. Historically, lands within OU2 have been used primarily in an industrial and commercial capacity. The surrounding land use is mixed industrial and commercial. This land use is anticipated to remain industrial and commercial. The plume of contaminated ground water migrates southeast of the landfill past Interstate 95 and below a residential area mixed with some commercial and limited industrial properties. VII. SUMMARY OF SITE RISKS A. Human Health Risk Assessment Summary The baseline risk assessment estimates risks to human health in the absence of a response action. The baseline risk assessment provides the basis for taking action and identifies the contaminants and exposure pathways that need to be addressed by the remedial action. This section of the ROD summarizes the results of the baseline risk assessment for OU2. A conceptual model of the Site was developed to identify which human exposure pathways were complete or could be potentially complete in the future. The former landfill area is currently industrial and is surrounded by a mix of residential, commercial, and industrial properties. Based on the historical land-use and the nature of the surrounding area, it is likely that the land-use for the former landfill will remain industrial. Therefore current and future industrial workers present on the Site may be exposed to contaminants in environmental media at the Site. In addition, the potential for further industrial development within the operable unit exists, and construction workers may be potentially exposed during excavation activities. Potential receptors that were evaluated include residents located downwind of the former landfill area who may be exposed to Site-related contaminants via inhalation of ambient air, and trespassers who may come into contact with soils in the surface drainage area located at the northern edge of OU2. Future hypothetical exposure to ground water used as a potable water supply was also evaluated. This exposure pathway is unlikely to be complete in the foreseeable future because local laws restrict the installation of potable water supply wells where public water supplies exist. One of the first tasks of the Human Health Risk Assessment ("HHRA") was to evaluate the sample data collected at OU2 and determine the contaminants of potential concern ("COPCs"). After averaging duplicate sample concentrations, the maximum detected constituent concentrations in each medium were compared to USEPA Region III Risk-Based Concentrations ("RBCs"). Chemicals detected in ground water and surface water were compared to drinking water (i.e., tap water) RBCs. Chemicals detected in subsurface soil were compared to industrial RBCs. Chemicals detected in surface soil and sediments were compared to residential RBCs and chemicals detected in soil gas were compared to the ambient air RBCs. All constituents detected at concentrations greater than the RBCs were identified as COPCs. The following identifies the selected COPCs by medium: ? Ground water: 1,1,2-trichloroethane, 1,1-dichloroethene, 1,2-dichloroethene, acetone,

benzene, carbon tetrachloride, chlorobenzene, chloroform, cis-DCE, methylene chloride, tetrachloroethene, trans-l, 2-dichloroethene, TCE, VC, aluminum, antimony, arsenic, barium, cadmium, chromium, iron, lead, manganese, nickel, thallium, vanadium, and zinc.

? Subsurface Soil: antimony, arsenic, benzo(a) pyrene, dibenz(a, h) anthracene, iron, lead, manganese, thallium, TCE, and VC.

? Surface Water: acetone, aluminum, antimony, arsenic, chromium, dibromochloromethane,

iron, manganese, methylene chloride, nickel, and vanadium. ? Soil/Sediment: aluminum, antimony, Aroclor-1242, Aroclor-1260, arsenic, benzo(a)

anthracene, benzo a) pyrene, benzo(b) fluoranthene, chromium, copper, dibenz(a, h) anthracene, iron, manganese, 2-(2-methyl-4-chlorophenoxy) propionic acid (MCPP), thallium, and vanadium.

? Soil Gas: 1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene, benzene, and TCE.

Exposure Assessment The risk assessment evaluated both reasonable maximum exposure ("RME") and central tendency exposure scenarios. Complete or potentially complete exposure pathways and receptors identified at OU2 of the Site include the following: ? Trespassers may be exposed to COPCs in surface water, sediment, and soil along the

northern boundary via incidental ingestion and dermal contact. Although the trespasser may also be exposed to soil and sediment via inhalation of fugitive dust and volatiles, this exposure was considered to be insignificant as compared with the direct exposure pathways.

? Construction workers may be exposed to COPCs in surface and subsurface soil during

excavation activities via incidental ingestion, dermal contact, and inhalation of fugitive dusts and volatiles. The depth to ground water within OU2 is approximately 50 feet below ground surface. Therefore, construction workers would not be expected to come in contact with ground water during excavation activities at the Site.

? Industrial workers may be exposed to vapors from the soil and ground water via migration

to indoor air. To evaluate this pathway, soil gas data were collected and used in the risk assessment. The soil gas data represent the cumulative vapor release from soil and ground water. The industrial workers are not exposed to potentially contaminated surface soils because the former landfill is covered with six to eight inches of a bentonite mixture.

? Off-Site residents may be exposed to COPCs in soil via inhalation of fugitive dusts.

Off-Site residents may also be exposed to volatile COPCs in soil via the inhalation of soil gas that migrates from the Site. The migration of soil gas to off-Site residential receptors was not evaluated quantitatively in the risk assessment because the risks for on-Site receptors (i.e., industrial workers) exposed to soil gas vapors were several orders of magnitude below EPA's target upper-bound lifetime cancer risk range. Although residential exposures are typically greater than industrial exposures (i.e., residential exposure may be up to four times greater than industrial exposure) the difference in exposure is far less than an order of magnitude. In addition, off-Site exposures to airborne contaminants would be much less significant than on-Site exposures due to atmospheric dispersion as soil gas emanating from the Site is carried downwind.

? Although use of the ground water as a potable water supply is prohibited in the City of

Baltimore, EPA required an evaluation of future hypothetical adult and child residential exposure to ground water. Future hypothetical exposure to ground water via ingestion, and dermal contact and inhalation of volatiles while showering, were evaluated.

Toxicity Assessment The human toxicity assessment was performed in order to identify numerical toxicity criteria with which to assess human health exposures. For non-cancer health effects, chemical-specific Reference Doses ("RfDs") were compiled. Chronic RfDs were used to assess long-term exposures ranging from 7 years to a lifetime. Subchronic RfDs were used to evaluate the potential for adverse health effects associated with exposure to constituents over a period of 2 weeks to 7 years. Subchronic RfDs were used to evaluate the short-term construction worker hazards.

Although the exposure duration for children was less than seven years, chronic RfDs were conservatively used. For cancer endpoints, chemical-specific cancer slope factors (SFs) were compiled. Whenever possible, route-specific toxicity values were used. However, toxicity values for dermal exposures have not yet been developed by EPA; therefore, the oral toxicity values and the gastrointestinal absorption efficiency were used to derive adjusted toxicity values (adjusted to the absorbed dose) for use in assessing dermal exposure. Contaminants of Concern ("COCs") COCs were identified for each media of concern (ground water and subsurface soil). A contaminant was considered a human-health COC if it contributed an excess lifetime cancer risk greater than 1 x 10"* or a Hazard Index ("HI") greater than one under RME assumptions. The following constituents were determined to be COCs in ground water: 1,1,2-trichloroethane, 1,1- dichloroethene, 1,2-dichloroethene, acetone, benzene, carbon tetrachloride, chloroform, cis-DCE, methylene chloride, tetrachloroethene, TCE, VC, iron, manganese, and thallium. Constituents present in soil do not pose a cumulative excess lifetime cancer risk of greater than 1 x 10"*. However, antimony exhibited a HI of greater than one based on the results of contamination detected in Exploratory Boring #12. The potential risks associated with elevated lead concentrations in the subsurface soil from the same area (see Figure 8) were shown to pose a potentially unacceptable risk to construction workers using EPA's Adult Lead Model. Therefore, lead and antimony have been identified as COCs in subsurface soils. Risk Characterization Using the human exposure and toxicity information, potential human health risks for each COC and selected exposure pathway were evaluated. Upper-bound excess lifetime cancer risks and non-cancer hazards were quantified, in addition, cumulative risks and hazard indices were estimated by summing the upper-bound excess lifetime cancer risks or hazards across exposure pathways for individual receptors. Table 2 summarizes the estimated hazards and risks for each of the receptors evaluated in the HHRA. The risks and hazards shown below are cumulative for the RME scenario, summed across all COCs, all media, and all exposure routes. The following sections discuss the exposure scenarios that exhibited either a hazard index greater than one or an estimated upper-bound excess cancer risk above 1 x 1CT6. Non-Cancer Hazards Under the current land-use conditions, only the construction worker exposed to soil resulted in a hazard index greater than one (1). The hazard indices for all other current receptors (i.e., trespassers, industrial workers, and off-Site residents) were all less than 1. For the construction worker, under the RME scenario, the combined hazard index was 4, primarily due to exposure to antimony, which was detected in the soil at 364 ppm at one location. When the hazard index was segregated by target organ, the HI was greater than one (HI = 2) for effects to the whole body and blood due primarily to antimony. The HI is less than one for all other target organs. Lead was detected in four soil borings at concentrations ranging from 322 to 25,700 ppm. The potential risks associated with elevated lead concentrations in the subsurface soil were shown to pose a potentially unacceptable risk to construction workers. Therefore, lead and antimony in subsurface soils are addressed as chemicals of concern. Under the hypothetical future residential exposure to ground water scenario, the hazard indices for both adult and child residents exceeded one for all exposure pathways (i.e., ingestion, dermal, and inhalation). However, these are theoretical hazard indices for an exposure pathway that is very unlikely to be complete in the future due to the prohibition of ground water use as a potable water supply within the City of Baltimore and Baltimore County. The primary risk drivers in the ground water are the chlorinated solvents including cis-DCE, TCE, and VC. Several inorganic contaminants, including iron, manganese, and thallium also result in a combined HI value greater than 1.

Cancer Risk Under the current land- use conditions, the total excess lifetime upper-bound risk estimates for the trespasser, industrial worker, and off-Site resident are all less than the USEPA target risk range (1 x 10"* to 1 x 10" 6). The total excess lifetime upper- bound risk estimate for the construction worker (7 x 10" 6) is within the USEPA target risk range. The total excess lifetime upper-bound risk estimate for the trespasser was 1 x 10" 6. Under the hypothetical future residential exposure to ground water scenarios, the total excess lifetime upper-bound risk estimates for both adult and child residents (9 x 10' 1 and 8 x 10"', respectively) significantly exceed the USEPA target risk range. However, these are risks for an exposure pathway that is very unlikely to be complete in the future due to the prohibition of ground water use as a potable water supply within the City of Baltimore and Baltimore County. The primary risk drivers are the chlorinated organic contaminants in ground water (i.e., VC; TCE; tetrachloroethene; and 1,1-dichloroethene). Tables 3 and 4 provide the risk estimates for on-site adult and children residents, respectively, for the significant routes of exposure and a summary of the concentration range and carcinogenic risk for the COCs detected in ground water. These risk estimates are based on a reasonable maximum exposure and were developed by taking into account various conservative assumptions. B. Summary of Ecological Risk Assessment A Screening Level Ecological Risk Assessment ("SLERA") was developed for OU2 to provide a general indication of the potential for ecological risk (or lack thereof). The SLERA was developed using information gathered during the Phase I and Phase n Baseline Ecological Assessments. During the Phase I Baseline Ecological Assessment, all habitats potentially impacted by the operable unit were identified. A 52- acre Ecological Assessment Area ("EAA") was defined as the area that could potentially be impacted by constituents from OU2 (see Figure 9). The Phase n Baseline Ecological Assessment included a site reconnaissance of upland and man-made habitats and a formal delineation of wetland habitats within the EAA. The area encompassing the EAA is dominated by urban industrialized areas (e.g., roads, pavement, buildings) and a recreational facility including baseball fields that are not well suited as habitats or foraging areas for most wildlife. Less than 5 percent of the EAA consists of vegetated areas (e.g., trees and vegetated drainage basins/swales) that might potentially be utilized to a significant extent by wildlife species. Based on the limited size and quality of the available foraging habitat, and the traffic noise associated with I-95 and the adjacent roadways and industrial sites (e.g., PICORP), it is unlikely that higher trophic level species (such as hawks or owls) utilize the EAA to a significant degree for nesting or foraging (none were observed during field work activities). Site utilization by many species would also be limited by the high netting that surrounds the golf driving range at OU1 and the wire fences that are around the perimeter of most of the properties in the EAA. In addition, the potential habitats within the EAA are often separated from one another by roadways, railroad tracks, buildings, and parking areas that limit their usefulness and desirability to many species. Based on these considerations, the most likely inhabitants of the EAA are urban rodents, such as rats and mice that are common residents of highly disturbed industrial habitats. Squirrels and rabbits are also likely to live in the area. If present, these species may act as prey for raptors and omnivorous mammals (e.g., foxes and raccoons) that also might use the EAA. A records search of rare, threatened, or endangered plants or animals that may have been reported within the EAA was conducted. There was no record of federal or state rare, threatened, or endangered plants or animals existing or utilizing the habitat within the EAA. In addition, field reconnaissance did not identify any habitat within the EAA considered to be suited to support rare, threatened, or endangered species populations. Based on this information, threatened and endangered species were not included as an assessment endpoint in the SLERA. Exposure pathways were identified based on the source/mechanism of constituent release, the medium (or media) of constituent transport, the point of potential contact by the receptor organism, and the route of exposure at the contact point (e.g., ingestion, inhalation, dermal

contact, and water contact). Incomplete exposure pathways were excluded from quantitative evaluation in the SLERA. Most of the EAA is paved, covered by buildings, or has a clay and/or soil/bentonite cover. Therefore, exposure to contaminants via surface soils is not a complete exposure pathway throughout most of the operable unit. Receptor exposure is limited to direct contact with surface soil and sediment in the drainage swales north and west of the PICORP property. Although the extent and quality of available habitat is low, potential risks associated with the terrestrial exposure pathways were evaluated in these areas. Contaminated ground water migrating from the Site increases with depth as it migrates to the south and east, opposite the direction of Herring Run, and does not appear to impact the swale or surface water. Shallow ground water is discontinuous as evidenced by dry conditions in two shallow wells, the lack of saturated soil observed during the installation of soil borings, and the lack of historical documentation of seeps. Previous disposal practices may have affected Herring Run in the past, especially during the years of active disposal. Historically, contaminants may have migrated in surface water from the Site and ultimately entered Herring Run. If contaminants had entered Herring Run from the Site (there are no data to support or refute this), such contaminants would likely have been co-mingled with contaminants from other sources and migrated to distant downgradient sediments, some of which have since been disturbed by dredging activities. As a result, the ecological assessment of Herring Run was only evaluated qualitatively in the ecological risk assessment. Based on the Site ecological conceptual model, the following assessment endpoints were included in the evaluation: survival, growth, and reproductive ability of avian and terrestrial wildlife within the EAA; survival and growth of plants within wooded areas and "wetland" habitats in the EAA; and survival, growth, and reproductive ability of aquatic wildlife in the "wetland" habitats in the EAA. Hazard quotients ("HQs"), the measurement endpoints, were used for estimating risk in the SLERA. The HQs were calculated as the unit less ratio of chemical concentrations in exposure media (i.e., soil, sediment, surface water) to ecotoxicological screening benchmarks considered protective of either plants or wildlife. A hazard quotient equal to or greater than one indicates the potential for adverse effects on ecological receptors. HQs were developed for the three assessment endpoints evaluated in the SLERA. Screening values used in the evaluation were those of the USEPA Region HI Biological Technical Assistance Group. The maximum detected concentrations of several constituents (e.g., metals, PAHs, pesticides, and PCBs) were greater than their ecological screening levels, resulting in HQs greater than 1. The elevated concentrations were usually associated with samples collected at locations in the drainage swales and stormwater retention basins on the north side of the PICORP property. These locations receive runoff from the railroad yard just to the north and/or the PICORP property to the south. Because of the potential influence of the railroad yard, risk estimates for locations in the drainage swales may not be attributable solely to constituents originating from OU2. The levels of COPCs present in some samples suggest that exposure levels are potentially sufficient to cause effects on sensitive receptor species. However, given the limited extent of the COPCs, the vegetated nature of the EAA, the background levels of metals, and features of the available habitat, the likelihood of adverse effects on plants and wildlife in the EAA is extremely low. This conclusion takes into consideration the following factors: ? Only a small fraction of the EAA contains COPCs in exposure media that are potentially

accessible to wildlife (soil, sediment, surface water). These vegetated areas are not unique to the EAA and are common in the surrounding urban areas; therefore, they are unlikely to serve as the sole habitat for most wildlife in the area.

? The EAA habitat is dominated by urban industrialized areas (e.g., roads, pavement,

buildings) and a recreational facility that are not well suited to most wildlife species as habitats or foraging areas. This greatly limits the extent (duration, magnitude, and area) of potential exposure for most wildlife species.

? When they occurred, excedances of BTAG screening levels for a particular constituent were

usually limited to just one or two samples (locations), indicating a very limited

potential for exposure at hazardous levels, even if soil or sediment contact, or ingestion, does occur.

? Many of the HQ values greater than one are for metals and other constituents that are

present at concentrations near or below soil background levels for the eastern region of Maryland.

? Surface contamination at OU1 was previously addressed (i.e., drums removed/Site capped)

to preclude further release/transport of COPCs. Therefore, levels of COPCs measured in 1994 in the stormwater drainage areas of OU2 should represent the worst case possible for assessing potential current or future risk to wildlife in the area.

The sample locations within the EAA with hazard quotients greater than one were almost exclusively in the drainage swale and stormwater retention basin north of the PICORP property. Because of the large railroad yard immediately to the north and the presence of over 1,000 large shipping containers on the adjacent PICORP property, utilization of this area by wildlife is likely to be limited and restricted primarily to highly urbanized species such as rats, mice, and raccoons. The likelihood of impacts on wildlife is further minimized because of the presence of numerous fences, roadways (including I-95), and buildings within OU2 that may restrict habitat availability and desirability for some species. The presence of the large railroad yard to the north of the operable unit may also limit the access of terrestrial wildlife from that direction including those that use the Herring Run corridor and riparian habitat. The ecological risk assessment indicates that under the current conditions, potential impacts from soil, sediment, and surface water are localized within the drainage swale north of the PICORP property and are not ecologically significant for the assessment endpoints evaluated. Based on the above-described information, EPA determines that ecological risk from releases at OU2 are negligible and that such risk does not, by itself, give rise to a need for remediation. VIII. REMEDIAL ACTION OBJECTIVES The human health risk assessment identifies the COCs in subsurface soil within OU2 and in ground water as warranting attention. Specifically, soil sampling identified an area of elevated metal concentrations located between the PICORP and Register Photo buildings as shown on Figure 8. Ground water sampling identified the presence of organic and inorganic contamination that extends approximately 6,300 feet hydraulically downgradient of the landfill. The remedial action objectives focus on these subsurface soil* and ground water. The remedial action objectives do not address surface water, surface soil/sediment, and soil gas because these media do not pose an unacceptable risk to human health or the environment from Site-related contaminants. Surface soils are not a focus of the remedial action objectives because surface soils consist predominantly of non-native cover materials applied during the development of commercial and industrial land use. A partial cover consisting of 6 to 8 inches of a bentonite/soil mixture was constructed over the majority of the PICORP property. Surface soils were evaluated indirectly through sampling soils that were transported via surface water runoff and deposited in drainage ditches. The relatively low concentrations of constituents detected in these washed out surface soils resulted in the determination that these soils do not pose an unacceptable risk. Surface soils within OU2 do not warrant remedial action. The remedial action objectives are intended to be specific to the affected media, but sufficiently broad so as not to overly restrict the potential remedial technologies available. The remedial action objectives are the following: ? Manage exposure to contaminated subsurface soils in OU2.

? Mitigate exposure by eliminating the potential to utilize ground water containing COCs as

a potable water source.

? Eliminate, stabilize, or minimize the further migration of the ground water contaminant

plume. ? Reduce the concentration of COCs in ground water to a cumulative cancer risk no greater

than 1 x 1 0" 4 and HI no greater than 1. The remedial action objective to reduce the concentration of COCs in ground water to "1 in 10,000" as the limit for cancer risk as opposed to a more stringent standard such as "1 in 1,000,000" is because of the extensive duration required for the ground water cleanup (i.e, approximately 75 years) and the uncertainties associated with reaching a more stringent standard within a reasonable period of time. It is also noted that the plume is located beneath an industrial and highly developed residential urban area in the City of Baltimore. Residents use municipal water supplied by distant surface water reservoirs as their source of drinking water. There are no plans to use the ground water as a source for drinking water. Managing exposure to contaminated subsurface soils in OU2 will address the direct contact threat presented by soils with elevated lead and antimony. Mitigating exposure by eliminating the potential to utilize ground water containing COCs as a source of potable water will address the risks associated with potential future use of contaminated ground water. As outlined in the National Oil and Hazardous Substances Pollution Contingency Plan ("NCP"), EPA expects to return usable ground water to its beneficial use wherever practicable within a timeframe that is reasonable given the particular circumstances of the site. When restoration of ground water to beneficial uses is not practicable, EPA expects to prevent further migration of the plume, prevent exposure to the contaminated ground water, and evaluate further risk reduction. In the present case, these goals are addressed by reducing the concentration of COCs in ground water; ensuring that exposure to contaminated ground water is minimized; and eliminating, stabilizing, or minimizing the further migration of contaminated ground water. IX. SUMMARY OF REMEDIAL ACTION ALTERNATIVES The remedial action alternatives were assembled from the technology process options deemed potentially usable and retained for further consideration based upon a detailed evaluation. EPA and MDE considered various technologies to further minimize the release of VOCs from the soil, comparing the environmental benefit of such technologies to the disruption to traffic in the area and the direct impact on existing businesses. Soil vapor extraction ("SVE") was retained after the initial screening but was not included in the following alternatives based primarily upon the results of fate and transport modeling. The model findings indicate that the application of SVE would not result in an appreciable difference in the size or shape of the VOC plume in ground water or in the timeframe required to complete the remedy for OU2. EPA and MDE decided not to further evaluate such technologies because the residual VOC contamination in soil does not pose a risk to construction workers and its removal would not significantly shorten the time to clean up ground water. Natural processes, including biodegradation, will reduce the concentration of VOCs in soil. Declining concentrations of contamination in ground water near the source area provides initial evidence that such processes may already be occurring. The soil and ground water technology process options retained after the screening evaluation were assembled into remedial alternatives. With the exception of the No Action alternative, which must be carried through for comparison, the remaining alternatives were included based on their ability to address each of the Remedial Action Objectives. The alternatives are: ? Alternative 1 - No Action

? Alternative 2 - Monitored Natural Attenuation and Institutional Controls

? Alternative 3 - Ground Water Containment/Removal with Treatment (Pump-and-Treat) and

Institutional Controls ? Alternative 4 - Enhanced Reductive Dechlorination and Institutional Controls

Alternative 1 - No Action

Under this alternative, no further remedial action would be undertaken. The no-action alternative would not manage exposure to subsurface soils nor would it provide a means of reducing the concentration of COCs in ground water; ensure that exposure to contaminated ground water is minimized; or eliminate, stabilize, or minimize the further migration of contaminated ground water. The NCP requires that the No Action alternative be evaluated to establish a baseline for comparison with other options. Under current conditions, natural processes would continue to allow the migration of contamination. While it is expected that some level of biodegradation would continue to occur, such biodegradation could not be confirmed in the absence of monitoring. This alternative would not provide the controls necessary to protect people from coming into contact with Site- related contaminants. There are no costs associated with the No Action Alternative. Alternative 2 - Monitored Natural Attenuation and Institutional Controls Monitored Natural Attenuation ("MNA") includes the physical, chemical, and biological processes that act, without human intervention, to reduce the mass, toxicity, mobility, volume, or concentration of contaminants in ground water, hi addition to biodegradation, these processes include dispersion, dilution, sorption, volatilization, and chemical or biological stabilization, transformation, or destruction of contaminants. Of these mechanisms, biodegradation represents the most significant mechanism for decreasing ground water contamination at OU2 to acceptable levels. Development of cleanup levels for the ground water begins by considering the minimum statutory cleanup levels required by law. The law requires that the cleanup levels shall be the more stringent of non-zero Federal Maximum Contaminant Level Goals ("MCLGs"), Federal Maximum Contaminant Levels, ("MCLs"), and State MCLs. These levels may need to be adjusted downward (i.e., more stringent) in order to ensure that the cumulative effect of contamination in ground water will not result in a cancer risk greater than 1 in 10,000 or a Hazard Index greater than 1. Cleanup below the background level for any contamination is generally not required. Table 5 lists the hazardous substances determined to be COCs in ground water and the non-zero MCLG, Federal MCL, and State MCL for each contaminant, where available. Protection of public health — by ensuring that the cumulative effect of contamination in ground water will not result in a cancer risk greater than 1 in 10,000 or a Hazard Index greater than 1- may be achieved by reducing the level of contaminants in the ground water in a potentially infinite number of variations. At a minimum, the reductions must meet the more stringent of the MCLG, Federal MCL and State MCL. But meeting this standard may not be sufficient to attain protectiveness. Further reductions in one or more contaminants may be required to reach this performance standard. The last column in Table 5 provides an example of a set of ground water cleanup standards that will meet the performance standard of reducing the cancer risk to below 1 in 10,000 and the Hazard Index below 1. Given the potentially infinite number of combinations that may satisfy both the non-zero MCLG/Federal MCL/State MCL stringency requirement and the ground water performance standard, numerical cleanup levels for each contaminant identified in Table 5, as well as for methylene chloride, iron, and manganese (the concentrations of which must also be reduced to attain the performance standard) would be developed during remedial design. A model was used to determine the overall net effect of MNA on the contaminated ground water. The model predicted that it may take more than 75 years to achieve the MCL for TCE, though the concentration would be greatly reduced from the current level. Though the quality of ground water would be significantly improved after 75 years, MNA would not meet the Performance Standard identified in Table 5 until some point beyond 75 years. Modeling results also predict that it will not eliminate, stabilize, or minimize the further spread of contamination in the ground water, though the expected increase in the size of the contaminant plume is considered relatively slight. Several additional wells would be required to monitor contamination near the edge of the ground water contaminant plume. Data would be collected from approximately 15 monitoring wells to evaluate the effectiveness of the cleanup. It is anticipated that the specific wells sampled

during each event could vary from event to event depending on the results of previous sampling events. Ground water data would be collected to monitor reductions in volume and/or toxicity and, additionally, to determine if the VOCs are spreading beyond their current known boundaries. Samples would also be analyzed to monitor the level of iron and manganese, which are expected to decrease over time. The presence of iron and manganese is likely associated with the biodegradation of the chlorinated compounds and the reducing conditions currently present in the aquifer. It is also likely that, as the attenuation of the biodegradation activity occurs and the aquifer returns to its normal oxidation level, the concentrations of iron and manganese will return to background levels. However, additional data collection is necessary to further support this conclusion. Thallium would also be monitored even though it was only detected in a few isolated areas at very low levels. Samples would be collected quarterly in the first three years, semi-annually in the fourth and fifth years, and annually thereafter throughout the remainder of the cleanup. All wells would be sampled to establish baseline conditions and annual reports would be prepared to monitor and evaluate progress. An additional regulatory review of Site conditions would be conducted every five years after initiation of remedial action. Alternatives 2 through 4 incorporate the use of institutional controls to manage and mitigate exposure to impacted soil and ground water within OU2. Each of these alternatives also includes development and implementation of a Soil Management Plan to establish procedures for excavation of areas containing contaminated subsurface soils. The following description and analysis of the Soil Management Plan and institutional controls applies to Alternatives 2, 3, and 4. Soil Management Plan Preliminary cleanup goals were developed for lead and antimony in subsurface soil to protect construction workers from direct contact with contaminated soil. Soils exceeding 182 parts per million (ppm) of antimony and 1,442 ppm of lead were determined to potentially cause adverse health effects in humans. Subsurface soil samples identified a limited area with elevated lead and antimony located immediately north of the intersection between Kane and Lombard Streets (see Figure 8). Contaminated soil is located beneath approximately 300 feet of Kane Street immediately north of the intersection of Kane and Lombard Streets and in the subsurface soil sampled from the adjacent industrial properties listed below:

Regester Photo 50 Kane Street Baltimore, MD 21224;

Commercial Transportation Inc. 320 North Point Boulevard Baltimore, MD 21224; and

PICORP Inc. 6508 E. Lombard Street Baltimore, MD 21224.

These properties (including the contaminated area beneath Kane Street) will be referred to collectively as the "Soil Management Plan Area" or "SMP Area." Excavating subsurface soils at these locations could cause additional releases of hazardous substances into the environment and could adversely impact human health and welfare. Accordingly, a Soil Management Plan would be developed that would: ? Summarize the nature and extent of the COCs within the SMP Area, including their

characteristics and vertical and lateral extent. Several additional boreholes may be required to confirm the nature and extent of contamination.

? Describe minimum qualifications and training of persons (including contractors) who may

excavate soils within the SMP Area.

? Detail proper practices for excavation, handling and disposal of contaminated soil from the SMP Area and the associated health and safety protection requirements.

Implementation of a Soil Management Plan would meet the cleanup objective of managing exposure to contaminated subsurface soils at OU2 and would protect on-Site workers from inadvertent contact with contaminated soil. Institutional Controls Institutional controls would be implemented to (1) prohibit residential use upon, and restrict excavation within, the SMP Area, and (2) prevent use of contaminated ground water. The SMP Area is located immediately north of the intersection between Kane and Lombard Streets and is approximately 600 feet long by 400 feet wide (see Figure 8). The area requiring an institutional controls for ground water extends for approximately 6300 feet southeast of the Site and is approximately 2500 feet wide (see Figure 5). With respect to restricting activities in the SMP Area, the institutional controls would: ? Prohibit residential use within the SMP Area;

? Require that any excavation within the SMP Area be conducted in accordance with the EPA

approved Soil Management Plan. With respect to the ground water-related controls, EPA notes that there is a formal permitting process in place with authority and responsibility assigned to MDWMA and the Water Supply Program of MDE and to the local health departments. In addition, there are local prohibitions on the installation of domestic wells within areas served by public water. These prohibitions are monitored and enforced by the City of Baltimore Environmental Health Services and the Baltimore County Department of Environmental Protection and Resources Management through a formal well permitting process. Well permits will not be issued for potable wells in the City of Baltimore and Baltimore County where public water supplies are available, which encompasses OU2 and the surrounding areas. Industrial use of ground water similarly requires a permit from the City or County, depending on the jurisdiction, and MDE must also issue a Water Appropriation Permit. When contamination is present, the City of Baltimore Department of Health requires data and works closely with MDE to evaluate the effects of contamination on a case-by-case basis, similarly, in Baltimore County, the Department of Environmental Protection and Resources Management works closely with MDE and maintains a database of contaminated sites to identify locations where well permits may not be granted. The current regulations and permitting system establish the necessary mechanism to restrict ground water use in the area of contamination during the cleanup, thereby meeting the objective of eliminating potential use of contaminated ground water. Thus, adequate institutional controls presently exist through programs that are already in place and are managed by the State and local governments. The present worth cost to implement, operate, and maintain Alternative 2 is:

Total Capital Cost: $ 390,000 Total Annual Cost: $ 350,000 Total Present Worth Annual Cost: $ 1,337,000 Total Present Worth Capital and Annual Cost: $ 1,727,000

Alternative 3 - Ground Water Containment/Removal with Treatment (Pump-and-Treat),

Soil Management Plan, and Institutional Controls Under Alternative 3, ground water cleanup would be accomplished using a ground water containment and recovery system, also known as a pump-and-treat system. This alternative also includes a Soil Management Plan, Institutional Controls, and ground water monitoring as previously described.

Pump-and-treat has been one of the most widely used ground water cleanup technologies since the early to mid-1980s. Ground water recovery would be accomplished using approximately six pumping wells located in the area of highest ground water contamination (near Eastern Avenue). Recovered ground water would be treated in two newly built treatment buildings prior to discharge. Two separate but similar treatment buildings would be required due to the large area with high levels of ground water contamination and to minimize the amount of subsurface piping through the densely populated area. It is anticipated that installing extensive subsurface piping may significantly disrupt traffic, residents, and businesses in this active community. Each of the two treatment systems would be designed to treat 200 gallons per minute. This figure provides for excess capacity of approximately 50 gallons per minute above currently anticipated treatment needs; such capacity could accommodate, for example, additional pumping wells, if determined to be necessary. Each treatment system would consist of in Unit IU ICUUCc metals, an air stripper to remove the majority of VOCs, a granular activated carbon polishing system to further reduce VOCs, and an air emissions treatment system to restrict the release of VOCs into the air. Ground water would be treated, piped to the Baltimore County storm water system along Eastern Avenue, and ultimately discharged to the Back River, a tributary to the Chesapeake Bay. Routine system operation and maintenance would be conducted on an ongoing basis. Air emissions and treated ground water would be sampled on a monthly basis and analyzed for VOCs. Reports summarizing the system operation, maintenance, and monitoring activities would be prepared quarterly. A monitoring program would be required to evaluate the progress in meeting the numerical performance standards developed during the remedial design (see discussion in Alternative 2). Reports summarizing the progress of the ground water cleanup would be prepared on a quarterly basis for the first three years, semi-annually during the fourth and fifth years, and then on an annual basis for the remainder of the monitoring period. In addition, a regulatory review of Site conditions would be conducted by EPA every five years after initiation of remedial action. Pumping would contain a large part of the plume and cause contaminant concentration to decline at individual points within the plume over a period of time. It is estimated that it would take 30 to 75 years to reduce ground water contamination to MCLs. Data indicates that the most significant decreases in contaminant concentration would occur during the initial years of pumping. Pumping over time would decrease the width of the contaminant plume. After 30 years, the concentration of VOCs would be dramatically reduced, but there would still be an area of VOC contaminated ground water that would extend about 2,000 feet southeast of Eastern Avenue. Modeling predicts that MCLs would be met between 30-75 years after commencement of the pumping/treating. During this time, it is expected that use of ground water within the area of concern would continue to be restricted as discussed above in Alternative 2. The model also indicates that some limited contamination outside of the capture area could continue to migrate for the first ten years, though this could be prevented with additional pumping wells not included in this evaluation. Pumping and treating ground water is anticipated to reduce the concentration of contaminants in ground water to acceptable (drinking water) levels and could eliminate, stabilize, or minimize the further spread of contamination in ground water, thereby meeting these two cleanup objectives. Sampling ground water and evaluating the data would be used to determine progress in meeting these two objectives. The following is the present worth cost to implement, operate, and maintain Alternative 3:

Total Capital Cost: $ 6,264,600 Total Annual Cost: $ 1,252,600 Total Present Worth Annual Cost: $ 14,455,400 Total Present Worth Capital and Annual Cost: $ 20,720,000

Alternative 4 - Enhanced Reductive Dechlorination, Soil Management Plan,

and Institutional Controls

Alternative 4 relies on naturally occurring processes and existing indigenous microbes to break down the VOCs in ground water and residual VOCs that remain in the subsurface. Known as Enhanced Reductive Dechlorination, or ERD, this approach consists of introducing an organic carbon source, such as diluted molasses, to ground water to accelerate the natural destruction of the VOCs. Iron and manganese should decrease to background levels as the VOCs are eliminated and conditions within the aquifer return to their natural state. This alternative also includes the Soil Management Plan, Institutional Controls, and ground water monitoring as described in Alternative 2. The ERD system would consist of approximately eight wells to inject and recirculate the organic carbon, although the exact number and location would be decided during the design phase. The carbon would act as a nutrient source for the existing microbes. The microbes would flourish with the added nutrients and increase in both number and activity, accelerating the natural degradation process. It is anticipated that each injection well would have a feed system consisting of a subsurface vault containing a 750 gallon tank for the carbon; a 2,500 gallon mixing tank; and a control system. Transport modeling indicates that the system would have to operate for approximately 15 years to significantly reduce contaminants in ground water. It may take an additional 60 years for all of the VOCs to be reduced to the Ground Water Performance Standards (i.e., the cumulative effect of contamination in the ground water will not result in a cancer risk greater than 1 in 10,000 or a Hazard Index greater than 1.) The actual configuration of equipment will be determined during the remedial design. An advantage of ERD utilizing organic carbon substrates is the ability to directly treat mass that is adsorbed to the subsurface soil matrix. In general, any remedial technology for ground water is limited by the rate of desorption of the COC mass to the dissolved phase. More traditional ground water treatment technologies rely on physical flushing of this mass from the aquifer, which requires multiple pore volumes of the aquifer to be removed over decades, often with only a small percent of the total mass removed. The ability of ERD technology to facilitate treatment of adsorbed mass is due to several factors: ? In a carbon-rich aqueous environment, hydrophobic constituents will tend to partition

from the soil matrix into the aqueous environment; ? A flourishing microbial community produces natural surfactants (consisting of

carbohydrates and lipids) which aid in desorbing mass from the soil matrix; and ? Fermentative conditions created in the subsurface via ERD produce low concentrations of

alcohols which can have a co-solvency effect, making mass accessible to the microbial population for treatment.

Biogeochemical data would be collected to evaluate progress in meeting numerical performance standards developed for each contaminant and additional samples would be collected to determine if the VOCs are spreading beyond their current known boundaries. Samples would also be analyzed to monitor the level of iron and manganese, which are expected to decrease over time. Thallium would be monitored even though it was only detected in a few isolated areas at very low levels. The location of samples collected could change from event to event depending on results from previous sampling events. Samples would be collected quarterly in the first three years, semi-annually in the fourth and fifth years, and annually thereafter throughout the remainder of the cleanup. All wells would be sampled prior to implementing the remedy to establish baseline conditions immediately prior to the start of the ground water cleanup. The injection of organic carbon is anticipated to reduce the concentration of contaminants in ground water to acceptable (drinking water) levels and to eliminate, stabilize, or minimize the further spread of contamination in ground water, thereby meeting these two cleanup objectives. Sampling ground water and evaluating the data would be used to determine progress in meeting these two objectives.

EPA currently estimates that it would take up to 75 years to meet the Ground Water Performance Standards, though significant reductions in contamination are expected in the short-term. However, future advances in the application of the ERD technology may significantly decrease the amount of time it takes to achieve the Ground Water Performance Standards. Annual reports would be prepared to monitor and evaluate progress. An additional regulatory review of Site conditions would be conducted every five years after initiation of remedial action. The present worth cost to implement, operate, and maintain this remedy is:

Total Capital Cost: $ 3,454,700 Total Annual Cost: $ 480,000 Total Present Worth Annual Cost: $ 3,890,300 Total Present Worth Capital and Annual Cost: $ 7,345,000'

1 The cost to implement this alternative is approximately 18% greater than the cost provided in the Proposed Plan. The cost estimate in the Proposed Plan was based on the Feasibility Study which did not account for additional monitoring requirements. X. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES Criteria Used To Compare Cleanup Alternatives The remedial alternatives summarized in this Record of Decision for OU2 have been evaluated against the nine decision criteria set forth in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (see 40 C.F.R. § 300.430(e)(9)). These nine criteria are organized into three categories-threshold criteria, primary balancing criteria, and modifying criteria. Threshold criteria must be satisfied in order for an alternative to be eligible for selection. Primary balancing criteria are used to weight major trade-offs between alternatives. Modifying criteria are formally taken into account after public comment has been received. The criteria, as well as the evaluation of each alternative against such criteria, are set forth below: Threshold Criteria 1. Overall Protectiveness of Human Health and the Environment addresses whether a remedy

provides adequate protection of human health and the environment from unacceptable risks posed by hazardous substances or pollutants or contaminants and describes how risks are eliminated, reduced, or controlled through treatment, engineering controls, or institutional controls.

2. Compliance with Applicable or Relevant and Appropriate Requirements ("ARARs") addresses

whether a remedy will meet all of the applicable, or relevant and appropriate requirements of Federal and State environmental statutes and regulations and/or whether there are grounds for invoking a waiver.

Primary Balancing Criteria: 3. Lone-Term Effectiveness refers to the ability of a remedy to maintain reliable protection

of human health and the environment over time once cleanup goals are achieved. 4. Reduction of Toxicity, Mobility, or Volume Through Treatment addresses the degree to

which treatment will be used to reduce the toxicity, mobility, or volume of the contaminants causing site risks.

5. Short-Term Effectiveness addresses the period of time needed to achieve protection and

any adverse impacts on human health and the environment that may be posed during the construction and implementation period until cleanup goals are achieved.

6. Implementability addresses the technical and administrative feasibility of a remedy,

including the availability of materials and services needed to implement a particular option.

7. Cost includes estimated capital and operation and maintenance costs. Costs are evaluated

on a present worth basis. Modifying Criteria: 8. State Acceptance indicates whether the State concurs with, opposes, or has no comment on

the remedy. 9. Community Acceptance considers whether the community agrees with the remedy. Overall Protection of Human Health and the Environment The No Action alternative would not provide adequate protection of human health and the environment. The No Action alternative was developed as a baseline for comparison against the other alternatives. The No Action alternative does not eliminate or control the current risks to construction workers exposed to contaminated subsurface soils. In addition, the No Action alternative lacks the necessary monitoring included under the other alternatives to evaluate the effectiveness of the ground water cleanup. It also lacks the institutional controls required to ensure that existing restrictions on future ground water use remain in effect. The No Action alternative will not be discussed further in the nine criteria analysis because it does not satisfy the threshold criteria of providing overall protection to human health and the environment." The combination of institutional controls and the Soil Management Plan in the remaining alternatives will protect workers from elevated lead and antimony in subsurface soils within the SMP Area of OU2 and prevent exposure to contaminated ground water. Alternative 4 (Enhanced Reductive Dechlorination) and Alternative 3 (Pump-and-Treat) offer protection of human health and the environment through treatment. Pumping would contain a large part of the plume and would reduce the concentration of contaminants over time. Alternative 4 would stabilize the plume and increase the rate of degradation. Both Alternatives 3 and 4 meet all of the remedial action objectives. Additional data is required to confirm the effectiveness of Alternative 2 (Monitored Natural Attenuation). Additional data is also required to confirm plume stability. EPA has determined that because additional data is required to determine the effectiveness of Alternative 2 and to confirm plume stability, it is unable to determine if this alternative is protective of human health and the environment. As a result, Alternative 2 will not be discussed further in the nine criteria analysis because it may not satisfy the threshold criteria of providing overall protection to human health and the environment. Compliance with ARARs Any cleanup alternative selected by EPA must comply with all applicable or relevant and appropriate federal and state environmental requirements or provide the basis upon which such requirement(s) can be waived. Applicable requirements are those substantive environmental standards, requirements, criteria, or limitations promulgated under federal or state law that are legally applicable to the remedial action to be implemented at the site. Relevant and appropriate requirements, while not being directly applicable, address problems or situations sufficiently similar to those encountered at the site that their use is well-suited to the particular circumstance. Both of the remaining alternatives will meet their respective ARARs. Table 6 identifies and summarizes the ARARs and Policies To Be Considered (TBCs) for the remaining alternatives. The requirements are applicable or relevant and appropriate to both alternatives unless otherwise noted. Long-Term Effectiveness and Permanence

Alternative 3 (Pumping and Treating) would provide an effective long-term solution to Site- related ground water contamination by physically removing and treating contaminants. However, this goal would not be accomplished very efficiently because large amounts of water would need to be physically removed from the aquifer, and a significant amount of energy consumed, to achieve a relatively small amount of contaminant removal. Long-term concerns include the potential for the movement of VOCs adhered to the subsurface material into the ground water after the pumping has ceased. Contaminants sorbed to aquifer material could serve as a continual source of dissolved phase contamination. Alternative 4 (Enhanced Reductive Dechlorination) would destroy the VOCs in the ground water and VOCs adhering to subsurface material at the injection locations and in down gradient areas. The most significant decreases in contamination would occur during the initial years of active ERD. The implementation of ERD would expedite natural degradation processes. However, it would take many years to achieve the Ground Water Performance Standards (i.e., the cumulative effect of contamination in the ground water will not result in a cancer risk greater than 1 in 10,000 or a Hazard Index greater than 1.) As more refined and innovative approaches to the use of ERD are developed in the future--most notably methodologies for carbon delivery-—this alternative could reach the Ground Water Performance Standards faster than currently anticipated. Reduction of Toxicity, Mobility, or Volume Through Treatment Alternative 4 (Enhanced Reductive Dechlorination) would result in the quickest initial reduction in contaminant concentrations, although Alternative 3 (Pump and Treat) could remove more of the contaminant mass in 30 years. As shown through the model simulations, ERD would limit the growth of the area of contaminated ground water. ERD would permanently destroy the VOCs dissolved in the ground water and the VOCs adhering to the subsurface material at the injection locations and in down gradient areas. As a result, the growth of the plume would be limited by the permanent destruction of the VOCs, thereby reducing the mobility and volume of contaminants in the plume. Alternative 3 would reduce the volume of contaminants in ground water and would change mobility by controlling ground water flow. Toxicity would also be reduced as concentrations drop over time. Treatment would involve the transfer of contaminants from the ground water to the air and into the Granular Activated Carbon in the treatment plants. The contaminants would ultimately be destroyed at an off-site location when the Granular Activated Carbon is regenerated so it can be used again. VOCs can be removed from the Granular Activated Carbon by steam or a similar heat source. The collected VOCs can then be subsequently treated and destroyed by another process such as thermal oxidation. Short-Term Effectiveness Restrictions on ground water use are already in place in the form of City and County ground water permitting systems. The institutional controls intended to control risks presented by contaminated subsurface soils can be implemented early in the remedial action. Alternative 3 (Pump and Treat) would present risks associated with the construction of the treatment plants and wells. Potential exposure to workers and residents could occur from leaks or spills since contaminated ground water would be brought above- ground for treatment. In the short-term, this alternative would control the direction of ground water flow but would not achieve dramatic changes in ground water quality. Short-term benefits of this alternative are somewhat limited since it would take several years to see significant mass removal of the contaminants. In addition, Alternative 3 could change the ground water geochemistry and/or the availability of species important to the natural degradation processes, which could have a detrimental effect on the natural attenuation processes. Alternative 4, Enhanced Reductive Dechlorination, would enhance the natural degradation process. The population of microbes would flourish with the added nutrients and increase in both number and activity, accelerating the natural degradation of the chlorinated organic contaminants. Injecting nutrients for the microbes in the subsurface would increase the rate of degradation, with the most significant decreases in contamination occurring in the initial years of ERD when nutrients are injected into the subsurface. As a result, Alternative 4 would

provide the quickest initial reduction in contaminant concentration of the remaining alternatives. Implementabilitv Alternative 4 (Enhanced Reductive Dechlorination) requires the installation of a few monitoring wells and approximately eight injection points. Each injection point consists of an injection well and the equipment needed to store and inject the nutrients. Acquiring access for these additional wells and equipment may be challenging in this densely populated area. Implementation of Alternative 3 (Pump-and-Treat) would be significantly more difficult and disruptive to the community than Alternative 4 because of the need to obtain access for wells, subsurface piping, and treatment systems. Disruption to existing land uses could be significant due to the size and quantity of the treatment equipment and the length of subsurface piping to transmit the water from the pumping wells to the treatment plants and from the treatment plants to the discharge point. Installation of the subsurface piping would likely require the temporary partial closure of streets and re-routing of traffic in the highly commercialized area of Eastern Avenue. This alternative would also require long-term access for the construction and operation of two treatment facilities, the six pumping wells and related equipment and several monitoring wells. Implementation of Alternative 3 would significantly disrupt area businesses, residents, and traffic in this densely populated community. Additional challenges associated with Pump-and-Treat relate to permitting and siting the treatment systems in a residential area. Relatively large volumes of contaminated water would have to be conveyed beneath public streets and private properties to the above-ground treatment facilities. Potential risks from exposure to contaminated ground water extracted from the subsurface would have to be managed due to the potential for accidental spills, leaks, and similar uncontrolled releases. Pumping and treating would also create a waste stream of contaminated carbon that would require thermal treatment prior to regeneration and solid wastes from the treatment to decrease metals. ERD, in contrast, would treat the contaminated ground water in-situ, well below the surface, using natural organic material as a nutrient source for the naturally occurring microbes. Cost The estimated cost for Alternative 4, Enhanced Reductive Dechlorination, is $3,454,700 in capital cost and $480,000 for annual operation and maintenance. The total present worth cost is $7,345,000. The estimated cost for Alternative 3 (Pump and Treat) is $6,264,600 in capital cost and 51,252,600 for annual operation and maintenance. The total present worth cost is $20,720,000. Direct capital costs include costs of construction, equipment, land and site development, building and services, and waste disposal. Indirect capital costs include engineering expenses, legal fees, license or permit costs, start-up costs, and contingency allowances. Annual O&M costs include labor and material; chemicals, energy, and fuel; administrative costs and purchased services; monitoring costs; cost for periodic Site review (every five years); and insurance and taxes. For cost estimation purposes, a period of 30 years has been used for O&M. In reality, maintenance of a site with waste left in place would be expected to continue beyond this period. The actual cost for each alternative is expected to be in a range from 50 percent higher than the costs estimated to 30 percent lower than the costs estimated. A 5.5 % discount rate was used in present worth calculations in accordance with EPA guidance. Detailed costs estimates, including assumptions used, are provided in the Administrative Record. State Acceptance The State of Maryland supports the selection of Alternative 4: Enhanced Reductive Dechlorination, Soil Management Plan, and Institutional Controls.

Community Acceptance A thirty-day public comment period on EPA's Proposed Plan for OU2 of the Kane and Lombard Superfund Site began on December 20, 2002. An advertisement announcing issuance of the Proposed Plan and a public meeting to discuss the Plan was placed in the Baltimore Sun. The public meeting was held on January 8, 2003 at Patterson High School located at 100 Kane Street in Baltimore. The meeting was attended by two members of a local community association, a representative from PICORP, EPA and State officials, a representative from Congressman Cardin's office, and the technical consultant that prepared the RI/FS for several responsible parties. Approximately one thousand Fact Sheets were distributed immediately prior to and following the public meeting. One thousand five hundred Fact Sheets were distributed by Patterson High School students several weeks after the public meeting. A second community association submitted a letter expressing concern about the duration and notification of the comment period. The letter also raised concerns regarding the integrity of EPA's preferred alternative and requested additional information regarding the proposed cleanup strategy (i.e., injecting nutrients). In response, EPA discussed technical and administrative concerns, extended the comment period an additional thirty days and provided the community association with technical information regarding enhanced reductive dechlorination and a copy of the Proposed Plan. EPA provided a summary of the Site history, the findings from the RI/FS, and EPA's preferred alternative during the community association's meeting on March 25, 2003, which was attended by approximately forty citizens and local officials. All of the questions and concerns raised by the community were addressed during the public meeting and the meeting with the second community association. All attendees appeared to agree with EPA's preferred alternative, though some initial concerns were raised about the process which utilizes microbes to reduce contaminants. None of the citizens objected to EPA's preferred alternative nor did they recommend an alternative approach. In addition, EPA has not received any additional written or verbal correspondence. The community appears to fully support EPA's findings and preferred alternative. EPA coordinated with both community associations regarding a Technical Assistance Grant (“TAG") and attended a meeting on February 11, 2003 to discuss the TAG with members of the community. The residents are aware of the availability of a TAG but are currently not pursuing this option. Responses addressing the written comments received during the comment period are summarized in the Responsiveness Summary section of this ROD. A copy of the transcript of the public meeting is included in the Administrative Record. XI. PRINCIPAL THREAT WASTES The NCP establishes an expectation that EPA will use treatment to address the principal threats posed by a site wherever practicable (NCP § 300.430 (a)(l)(iii)(A)). The "principal threat" concept is applied to the characterization of "source materials" at a Superfund site. A source material is material that includes or contains hazardous substances, pollutants or contaminants that act as a reservoir for migration of contamination to ground water, surface water or air, or acts as a source for direct exposure. Contaminated ground water generally is not considered to be a source material. EPA does not consider the wastes at OU2 of the Kane and Lombard Site to be "principal threat" wastes. XII. SELECTED REMEDY Following consideration of the requirements of CERCLA, a detailed analysis of the alternatives using the nine criteria set forth in the NCP, and careful review of public comments, EPA has selected Alternative 4: Enhanced Reductive Dechlorination, Soil Management Plan, and Institutional Controls for implementation at OU2 of the Kane and Lombard Site.

Summary of the Rationale for the Selected Remedy An advantage of ERD utilizing organic carbon substrates over traditional pump and treat technology is the ability to directly treat mass that is absorbed to the subsurface soil matrix. In general, any remedial technology for ground water is limited by the rate of desorption of the COC mass to the dissolved phase. Pump and treat technologies rely on physical flushing of this mass from the aquifer, which requires multiple pore volumes of the aquifer to be removed over decades, often with only a small percent of the total mass removed. The ability of the ERD technology to facilitate treatment of adsorbed mass is due to several factors: ? In a carbon-rich aqueous environment, hydrophobic constituents will tend to partition

from the soil matrix into the aqueous environment; ? A flourishing microbial community produces natural surfactants (consisting of

carbohydrates and lipids) which aid in desorbing mass from the soil matrix; and ? Fermentative conditions created in the subsurface via ERD produce low concentrations of

alcohols which can have a co-solvency effect, making mass accessible to the microbial population for treatment.

A disadvantage of the pump-and-treat system is the installation and maintenance of the piping to transfer water to and from the treatment systems which would disrupt traffic flow in the area, potentially impacting the residential and business communities. A second disadvantage of the pump-and-treat alternative is the potential for releases of contaminated water brought to the surface for treatment. In addition, the pump-and-treat alternative will create a waste stream which must be managed, and it is over three times as expensive as the selected alternative. ERD treats the contaminated water in-situ, using a natural nutrient source to remediate ground water without the threat of releases of contamination. As more refined and innovative approaches to the use of ERD are developed in the future, most notably methodologies for carbon delivery, the ERD alternative could reach the Ground Water Performance Standards faster than currently anticipated. Based on available information, EPA believes the selected alternative meets the threshold criteria and provides the best balance of tradeoffs among the other alternatives with respect to the balancing and modifying criteria. Description of the Selected Remedy and Performance Standards The selected remedy shall provide for Enhanced Reductive Dechlorination of the ground water impacted by the Kane and Lombard Site, a Soil Management Plan, and Institutional Controls to reduce risks presented by OU2 of the Site to acceptable levels, as further described below. The following are the key components of the selected remedy as well as the Performance Standards associated with such components: 1. Facilitate the injection of organic carbon materials into contaminated ground water at

OU2 by installing approximately eight (8) injection wells in the core of the plume near Eastern Avenue.

(a) The exact number, placement, and configuration of the injection wells will be

determined during remedial design. Additional injection wells may be required if the VOCs are found to be spreading beyond their current known boundaries.

(b) Each injection well shall have a feed system consisting of a subsurface vault

containing a 750 gallon tank for the carbon; a 2,500 gallon mixing tank; and a control system. The actual capacity and configuration of equipment will be determined during the remedial design.

(c) Dispose of wastes generated during well installation off- site in accordance with

RCRA and other Federal laws. Wastes shall be tested to determine whether they are hazardous wastes under RCRA.

(d) Identify the variability of hydraulic conductivities and vertical extent of

contamination in the subsurface through interval-specific aquifer testing. Information gathered throughout the OU2 RI/FS indicates that the Upper Patuxent Formation will be the zone targeted for injection. Depending on the results of the aquifer testing, injections could be designed via single well recirculation systems or by recirculating ground water and carbon reagent between wells so as to ensure mixing of the carbon reagent throughout the entire treatment area and depth interval. The results of the aquifer testing will be used to refine the transport model and conduct additional modeling.

2. Reduce contaminants in ground water to acceptable levels, as defined below, through use

of an Enhanced Reductive Dechlorination System ("ERDS") which shall include, but not be limited to, the injection, using the injection wells described above, of organic carbon materials into the ground water at OU2.

(a) Prior to full-scale implementation of a remedial system, pilot testing may be

conducted to identify full-scale design criteria. Pilot testing would include installation of at least one pair of injection wells, installation and operation of a pilot injection system, and preparation of an evaluation report. Such pilot testing will be performed if EPA determines that such pilot testing will expedite the remedial action.

(b) Reduce the cumulative effect of contamination in ground water at OU2 to below a 1

in 10,000 cancer risk and below a Hazard Index of 1 through the operation of the ERDS. This Performance Standard will be achieved by reducing the concentration of the contaminant identified in Table 5 as well as methylene chloride, iron and manganese to numerical cleanup levels that are developed during remedial design. At a minimum, the lowest of the Federal non-zero MCLG, Federal MCL, or Maryland MCL ("ARAR Target") shall be met for each contaminant identified in Table 5. If the cumulative effect of contamination remaining in ground water at OU2 (including the contaminants identified in Table 5 and methylene chloride, iron and manganese) will result in a cancer risk greater than 1 in 10,000 or a Hazard Index greater than 1, then the ARAR Target for one or more of the contaminants identified in Table 5 must be lowered (i.e., made more stringent) to attain this Performance Standard and/or the numerical cleanup standards developed for methylene chloride, iron and manganese must be similarly lowered. Full-scale operation of the ERDS shall continue for fifteen years or as otherwise determined by EPA2. Monitoring of ground water and the preparation of annual reports shall be conducted as discussed below throughout the operation of the ERDS and until the Performance Standards for ground water have been continuously attained for a period of no less than three years.

2 EPA currently expects that 15 years of injection will provide sufficient organic carbon to enable attainment of the Ground Water Performance Standards within 75 years. Injection beyond 15 years may be required if data indicate that the Ground Water Performance Standards will not be attained within the 75 year time frame. 3. Evaluate the progress of the ERDS in reaching the Performance Standards by monitoring the

size and location of the contaminant plume using a network of monitoring wells.

(a) New monitoring wells shall be added to the existing wells as needed to provide sufficient information to accomplish the above-stated goals. The exact number and placement of monitoring wells will be determined during the remedial design.

(b) Establish baseline conditions of the ground water no later than sixty (60) days

before the first injection of organic carbon material into the ground water by collecting samples from each monitoring well and analyzing such samples for, at a minimum, the contaminants identified in Table 5 and iron, manganese and methylene chloride.

(c) Monitor the performance of the ERDS by collecting and analyzing ground water samples. Beginning after commencement of the first injection of organic carbon material into the ground water and until the Performance Standards for ground water cleanup have been continuously attained for a period of no less than three years, samples will be collected no less than quarterly in the first three years, semi-annually in the fourth and fifth years, and annually thereafter throughout the remainder of the cleanup and analyzed for the above-described contaminants. The process for determining the number of wells to be sampled in each event will be developed during remedial design.

(d) Annual reports shall be prepared which shall describe, among other things, the

progress of the ERDS in reaching the Performance Standards and the size and location of the contaminant plume.

(e) Evaluate the effectiveness of the treatment system through the collection of

biogeochemical data. The biogeochemical data will be used to determine if additional nutrients should be injected beyond the fifteen years currently anticipated (see footnote 2).

4. A Soil Management Plan shall be developed and implemented to reduce risks at the

locations within OU2 of the Site which contain elevated lead and antimony in soils.

(a) Subsurface soil samples identified a limited area with elevated lead and antimony located immediately north of the intersection between Kane and Lombard Streets (see Figure 8). Contaminated soil is located in the following areas/ properties at OU2:

(i) Beneath approximately 300 feet of Kane Street immediately north of the

intersection with Lombard Street (ii) Regester Photo

50 Kane Street Baltimore, MD 21224

(iii) Commercial Transportation Inc.

320 North Point Boulevard Baltimore, MD 21224

(iv) PICORP Inc.

6508 E. Lombard Street Baltimore, MD 21224

These areas/properties are collectively referred to as the SMP Area.

(b) A Soil Management Plan shall be developed which shall:

(i) Summarize the horizontal and vertical extent of soil exceeding 1442 ppm of lead and 182 ppm of antimony within the SMP Area.

(ii) Describe the minimum qualifications and training of persons (including

contractors) who may excavate soils within the SMP Area. (iii) Detail proper practices including, but not limited to, health and safety

protection requirements, for excavation within the SMP Area as well as for handling and disposing of contaminated soil excavated from the SMP Area.

(iv) Establish a process for annual coordination with all owners of property

within the SMP Area to ensure their understanding of the requirements of the SMP and to discuss any planned activities that may disturb or otherwise result in an encounter with subsurface soils within the SMP Area.

(v) Establish procedures for notifying, at a minimum, EPA and MDE when actual or

planned activities within the SMP Area result or are anticipated to result in an encounter with contaminated subsurface soils.

5. Institutional controls shall be implemented to prohibit residential development at the

SMP Area (as defined on Page 24), require implementation of the Soil Management Plan, and restrict the use of ground water until the Performance Standards for ground water have been attained.

(a) Prevent residential development on each parcel within the SMP Area through the use

of institutional controls. (b) Institutional controls shall be established to require implementation of the EPA-

approved Soil Management Plan on each parcel within the SMP Area. Such controls shall remain in effect on each such parcel until sampling on such parcel shows that no contamination is present above 1442 ppm of lead or 182 ppm of antimony.

(c) Adequate institutional controls in the form of State and local restrictions on use

of ground water in the area impacted by OU2 (depicted by the outermost boundary of the plume in Figure 5) of the Site currently exist to restrict the use of contaminated ground water. These institutional controls shall be monitored to ensure they continue to restrict use of the contaminated ground water until the Performance Standards for ground water have been attained.

Summary of the Estimated Remedy Costs The estimated cost of implementing Alternative 4 is $3,454,700 in capital cost and $480,000 for annual operation and maintenance. The total present worth cost is $7,345,000. See Table 7 for the major capital and annual O&M costs associated with the selected remedy. Expected Outcome of the Selected Remedy The selected remedy will reduce, to acceptable levels, risks to human health presented by OU2 of the Kane and Lombard Site by reducing contaminants in ground water and managing the risks associated with the elevated lead and antimony in subsurface soils and contaminants in the ground water prior to cleanup. Such risk reductions will be accomplished through treatment (ERD) of contaminated ground water, institutional controls restricting use of ground water, and institutional controls restricting use of properties containing contaminated soils. EPA expects that, following implementation of the selected remedy, ground water that has been impacted by the Site will be restored to drinking water standards. However, it is anticipated that this process may take approximately seventy-five years to achieve using currently available methods for introducing the carbon source into the aquifer. Use restrictions on such ground water are part of the selected remedy and will be in place until the ground water cleanup standards are attained. Use of the SMP Area will be limited to prevent residential use of the area and ensure that appropriate precautions are taken if and when contaminated subsurface soils are excavated. XIII. STATUTORY DETERMINATIONS Section 121 of CERCLA requires that selected remedies be protective of human health and the environment, comply with ARARs, be cost effective, and use permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable. Additionally, CERCLA includes a preference for remedies that use treatment to significantly and permanently reduce the volume, toxicity, or mobility of hazardous wastes as their principal element. The following sections discuss how the selected remedy for OU2 at the Kane and Lombard Site meets these statutory requirements. Protection of Human Health and the Environment The selected remedy will provide protection of human health and the environment by restoring contaminated ground water quality to meet or exceed both federal and state drinking water requirements, prevent use of contaminated ground water until the ground water has been cleaned up, prevent residential use of property within OU2 with subsurface soil containing elevated antimony and/or lead, and ensure the proper excavation, handling, and disposal of such contaminated soils if excavation is undertaken.

Compliance with Applicable or Relevant and Appropriate Requirements The selected remedy will comply with all Federal and State requirements, standards, criteria, and limitations that are applicable or relevant and appropriate, as required by section 121(c) of CERCLA, 42 U.S.C. § 962l(c). Such requirements, standards, criteria and limitations are identified in Table 6 of this ROD. Cost Effectiveness Section 300.430(f)(l)(ii)(D) of the NCP, 40 C.F.R. § 300.430(f)(l)(ii)(D), requires EPA to evaluate cost-effectiveness by comparing all the alternatives meeting the threshold criteria- protection of human health and the environment and compliance with ARARs-against long-term effectiveness and permanence; reduction of toxicity, mobility or volume through treatment; and short-term effectiveness (collectively referred to as "overall effectiveness"). The NCP further states that overall effectiveness is then compared to cost to ensure that the remedy is cost effective and that a remedy is cost effective it its costs are proportional to its overall effectiveness. EPA concludes, following an evaluation of these criteria, that the selected remedy is cost-effective in providing overall protection in proportion to costs and meets all other requirements of CERCLA. The estimated present value of the selected remedial action is $7,345,000. Utilization of Permanent Solutions and Alternative Treatment Technologies to the Maximum Extent Practicable The selected remedy utilizes permanent solutions and alternative treatment technologies to the maximum extent practicable through the use of Enhanced Reductive Dechlorination. ERD technology consists of introducing organic carbon, such as diluted molasses, to ground water to accelerate the destruction of VOCs using naturally occurring processes and existing indigenous microbes. These microbes break down the VOCs in ground water and residual VOCs that remain in the subsurface. Iron and manganese should decrease to background levels as the VOCs are eliminated. Preference for Treatment as a Principal Element The selected remedy satisfies the statutory preference for treatment as a principal element in that the remedy requires the treatment of contaminated ground water in-situ by enhancing the natural breakdown of contaminants by the indigenous microbial population. Five Year Review Requirements Section 121(c) of CERCLA and section 300.430(f)(4)(ii) of the NCP require review of the remedy if the remedy results in hazardous substances, pollutants, or contaminants remaining on-site above levels that allow for unlimited use and unrestricted exposure, and specify that such review shall be conducted no less often than every five years after initiation of the remedial action. Because hazardous substances will remain at OU2 of the Kane and Lombard Site, the review described by section 121(c) of CERCLA and section 300.430(f)(4)(ii) of the NCP will be conducted no less often than every five years after initiation of the remedial action. Documentation of Significant Changes The Proposed Plan for OU2 of the Kane and Lombard Site was released for public comment on December 20, 2002. The Proposed Plan identified as EPA's preferred alternative the alternative that is selected in this ROD for implementation at OU2 of the Site. The remedy selected in this ROD involves no significant changes to the preferred alternative identified in the Proposed Plan. However, as noted in the discussion of Alternative 4, the cost to implement Alternative 4 is 18 % greater than the cost provided in the Proposed Plan. The cost estimate in the Proposed Plan did not account for additional monitoring required by EPA.

RESPONSIVENESS SUMMARY

KANE AND LOMBARD SITE

OPERABLE UNIT NO. 2

BALTIMORE, MARYLAND A thirty-day public comment period on EPA's Proposed Plan for OU2 of the Kane and Lombard Superfund Site began on December 20, 2002. A public meeting was held on January 8, 2003 and was attended by two members of a local community association, a representative from PICORP, Inc., Baltimore ("PICORP"), EPA and State officials, a representative from Congressman Cardin's office, and the technical consultant that prepared the RI/FS for several potentially responsible parties ("PRPs"). A second community association submitted a letter expressing concern about the duration and notification of the comment period. The letter also raised concerns regarding the integrity of EPA's preferred alternative and requested additional information regarding the proposed cleanup strategy (i.e., injecting nutrients). In response, EPA contacted the president of the community association and discussed technical and administrative concerns. In addition, EPA extended the comment period an additional thirty days and provided the community association with technical information regarding enhanced reductive dechlorination and a copy of the Proposed Plan. Furthermore, EPA provided a summary of the site history, the findings from the RI/FS, and EPA's preferred alternative during the community association's meeting on March 25, 2003, which was attended by approximately forty citizens and local officials. EPA answered all verbal questions presented during the public meeting. A copy of the transcript of the public meeting is included in the Administrative Record supporting this ROD. EPA also answered all of the questions during the meeting with the second civic association on March 25th. The attendees of both meetings agreed with EPA's preferred alternative, though some initial concerns were raised about the enhanced reductive dechlorination process. None of the citizens objected to EPA's preferred alternative nor did they recommend an alternative approach. The community appears to fully support EPA's findings and selected alternative. The purpose of this document is to provide EPA's response to the written comments submitted during the comment period. Comments were submitted by the contractor representing several PRPs, the current owner of one of the affected properties, and the second community association prior to the March 25, 2003 meeting attended by EPA. SUMMARY OF COMMENTS AND EPA RESPONSES Ground Water Monitoring Question/Comment: There is significant value to establishing a continuous, long-term record from select ground water monitoring wells in order to establish a solid time-series at key locations. A likely scenario is that the majority of wells would be sampled consistently and a few wells at different locations may be sampled periodically. Response: EPA agrees and has incorporated this approach into the monitoring requirements of the selected remedy. Question/Comment: Semi-annual sampling (as opposed to quarterly sampling) in "year three" (the third year of sampling following the implementation of the remedial action) is more than adequate for establishing long-term COC concentration trends.

Response: EPA disagrees that quarterly sampling is not necessary in "year three." Three years of quarterly sampling is necessary to begin establishing long-term trends. Sampling of ground water has not been conducted since May 2001. Comprehensive sampling will hot likely occur until the remedial design. Cost Estimate for Enhanced Reductive Dechlorination, Soil Management Plan, and Institutional Controls Question/Comment: The cost estimate provided in the Proposed Plan reflects the cost estimate in the Feasibility Study which is slightly lower than the revised cost estimate. Response: EPA agrees and has adjusted the cost estimate accordingly. The modified cost estimate in the Record of Decision for the Total Present Worth Capital and Annual Cost for the Enhanced Reductive Dechlorination, Soil Management Plan, and Institutional Controls (Alternative 4) is $7,345,000. Soil Management Plan Question/Comment: The Proposed Plan states that the Soil Management Plan ("SMP") would be compiled to define the extent of lead and antimony in subsurface soil. The purpose of the SMP is to identify soil management protocols for handling and disposing contaminated soil. Delineation of metals and VOCs in the immediate area of the proposed work prior to excavation might be warranted if existing information is not sufficient to plan for health and safety procedures and soil handling and disposal options. Given the planned institutional controls, there is no reason for further general delineation of COCs. Response: EPA agrees that the purpose of the SMP is to identify soil management protocols for handling and disposing contaminated subsurface soil if the areas are disturbed. It is important to note that it is necessary to identify the boundaries of contaminated subsurface soil to ensure all contaminated soil is included in me area managed by the SMP. One approach is to require institutional controls over a broad area to ensure all contaminated subsurface soil is addressed by the SMP. However, EPA prefers to limit the area affected by the SMP, thereby minimizing the extent of institutional controls, and not place institutional controls on property that does not contain contaminated subsurface soil. As a result, several additional samples may be required to further define the boundaries of contaminated subsurface soil and refine the area affected by the SMP. Question/Comment: PICORP requests an opportunity to review the SMP and to provide input during its development. Response: EPA intends to provide PICORP and all owners of property affected by the SMP an opportunity to review the plan and provide input during its development. Question/Comment: There will likely be additional costs incurred by property owners/operators in performing activities on their properties that are subject to the provisions of the Soil Management Plan. Will the additional costs be the responsibility of the PRPs? Response: The rights of property owners/operators to seek reimbursement of such additional costs from the PRPs are not affected by this ROD. Question/Comment: PICORP is unclear whether the SMP will apply to actions involving their underground storage tanks ("USTs"). PICORP specifically requests that USEPA (in concert with MDE) provide guidance regarding the disposition of the USTs that reconciles the requirements of MDE and USEPA's remedy for OU2. More specifically, PICORP requests permission to permanently abandon the USTs in place and to receive notice from MDE and USEPA that in doing so its actions will not: 1) result in unacceptable risks to its workers (or those hired by PICORP), and 2) that its actions would not result in any additional liabilities for Site issues unrelated to USTs. Response: Several abandoned underground storage tanks are located on the PICORP property but were not investigated by EPA as part of the OU2 RI/FS. The removal of the USTs was not considered as a component of any of the remedial alternatives considered. Remediation of the USTs, if necessary, must be coordinated directly with MDE, the lead agency for remediation of

the USTs. In addition, PICORP must perform this remediation in accordance with the SMP if the USTs are located within the SMP area. EPA will assist MDE if the UST cleanup is performed prior to the preparation of the SMP. Question/Comment: A community association expressed concern about the duration and notification of the comment period. They also raised concerns regarding the integrity of EPA's preferred alternative and requested additional information regarding the proposed cleanup strategy (i.e., injecting nutrients). The community association also raised concerns about the potential discharge of contaminated ground water into Back River. Response: Contaminated ground water will not migrate into Back River because contamination in ground water has migrated downward into the second water-bearing zone to depths exceeding 200 feet, below any zones that would discharge into Back River. Ground water monitoring will determine if the plume has reached steady-state conditions and will document the extent of ground water contamination throughout the cleanup. EPA extended the comment period an additional thirty days and provided the community association with technical information regarding enhanced reductive dechlorination and a copy of the Proposed Plan. EPA provided a summary of the Site history, the findings from the RI/FS, and EPA's preferred alternative during the community association's meeting on March 25, 2003. All of the questions and concerns raised by the community were addressed during the meeting with the community association. All attendees agreed with EPA's preferred alternative, though some initial concerns were raised about the process which utilizes microbes to reduce contaminants. None of the citizens objected to EPA's preferred alternative nor did they recommend an alternative approach.

MAP SOURCE OLORME. MARYb*NO DELAWARE

'•-' ,• ^r ••}A* :H M.TIMOKE - ! J / *°M A R Y L V N D " '

STUDY AREA•V ,iv

G&M

SITE LOCATION MAP

COCD

00O

51I OWC DATE 5 - 2 9 - 0 3 |PF*JCI NO UOOOO565 OOl 015 , FH.E NO £PA~3 I SCALE ' - iOO : CHECKED -

\ \ —

FINAL ORArr TECHNICAL MEMOPA^JDUM PHASE ti BASELINE ECOLOGICAL A ^ S E ^ c w e r

SURFACE STREAMS ANDSTORMWATER DRAINAGE SYSTEM MAP

ANE i LOMBARD OU-2 5-UEOlAL 'N1. t S'IGATION •BAL'iWORE M

oo

CDCOcc.

52

UJ

Ul/l

<JJ_x.oz

oz

Ito

I)tr

a; a> c-- <_) 3

oQ.XLlJ

o t:> = g

o - —(U C

oT3

00

S c

ce

o ^i 5i

a:o

>

53

COo

CPCO

54

_1\O»

J_

zo

if JNC

ENTR

ATIO

N™

g/L

)

-j<o2

^ BI

OG

EOC

HE

03

aUJ

IKO<_>i*?

cc0u.

O0CN

>-

2O

auJC_)X ^^^sUJ \X 0*— —

5^

| ^O

llM L

§ K § 5O uj . ui Ja: a t^ -^ 0- UJ l/>(/I uj I-T _)I/I UJ UJ < —'

Q UJ

55

56

A R 3 0 U U 8 6ON jltjl

57

[OICOAJT S-J9-OI IPOXIMO M0000529000I HO: CTISK-I | SCAU. 1.300 |CXCKCr>:

SOUWCl C"» Or 9*4

SOURCE HNAL DRATt TECHNICAL

ARCADISG&M

CD §i*ttMc ;5g==^ 5yr-; . *tn>*»—— - • • —— — - • • —— MIlMflllLNT SlftCAM /-*.

(A) UNNMCO MTtKMirrD«T JT1

(B) UNNAUCD NTEMurntMT ST1

—— <vo« omcno. EA^3 s 5u*i*« LOCATBH

MEMORANDUM PHASE II 8ASEUNE ECOLOGICAL ASSESSMENT MbA MARCH 17 1995

SURFACE WATER, SEDIMENT,AND SOIL SAMPLING LOCATIONS

KANE * LOMBARD OU-2 ECOLOGICAL RISK ASSESSMENTBALTIMORE. MARYLAND

ICA« 1

•CAM 2

FIGURE9 1 flR30H87

58

.Carbon SuMtntt20-M

LULU

I

APPROXIMATE HORIZONTAL SCALE: 1 INCH « 200 FEET

ARCADIS G&M

- CONCEPTUAL DESIGN SCHEMATICENHANCE REDUCTIVE DECHLORINATION

(ERD) SYSTEMKJ+fl L0***«l CXW fEASIOLTPr STUDY

BALTIMORE.

FMUHC

10

— oo _

U P r ^

~ *

- O^ § I,

I Q " I "= "i>, — o H

" •= £ 5^ = C Q.

O w C O 3„ o 3 ooo- « ^ < y5

. 30O =

3f^ aft "*O *TV, ^sj Oj

O _><M 3

.= 2

Q

oo

a.LLJO

o

5

c —

(T30>

C ^

i/l O 0*.2 o.~** O) en

•^ C C«-» o 3

—• ro di.12 gi Q.(U in mE rtj __

> "Oaj p- ^-«f ^

^» QJ _j

O ^ Tl <U

•— £ c

igsl«C ^3 T3U O ^ QQ

1si2_W

"(3$vtMC

cuQ2

oos(Mo•ara^(NO

a)u..2

COu2o-Uca00

i_o"oLu

_l

U?QS

11>c

UJu

o(JCB

"t3>oEU>,oc&b-uu

^u

rem

ov

uh.catn

E•ooo

u

ff

3?2T3JCA

2tsc

LUQS

,0

-oc0

J"5(/I.SucaXuc

1

a.0o

V)u.5V

J5D.

1UCos

ooOs

oo"

o*> rsi TTP oo oo- Os Os

« so 'C

i | <

C

JD

Iino

00Os

00OS

oc3

6

ooOs

uJ3oO

OsOS

ooOSOS

OSOS

r-~uO

Oo

OS

O

-3 O^ i!a —2 =-rt C.~ O

rs (j

^ "5O y

51o f-U >s< -°~r "S1 So 55 §wi -~ -•

§ ^<-> X0 —

^ 82 «

11E < 0<!<lNQ _) -a

^33*uOU<f^tDO

a.

o

oou.53*c>,

=1C/5

^

o0

•80

i-s

nal r

evisi

ons

uZ

o_fl

2

* i2 <

I Io 5S a:

oD iO £*

uoa.

O^oSaj>oa:"O uo -

0O

O

DO

a.o

O [fU ^

O O

CD00or

rtJ

3Wl

vt o QJ.2 Q- -ti

•M C^ o

.2 cn Q.•O 'J3 3Ol i/l UO

E §ip

^ £ I iJ* E a;O jS ^ O

§ CN a, .1^ —L C ±i

U O V co

Des

crip

tion

i>I«h^

O

-55u

</top2"u

Initi

al ro

und

of da

ta c

olle

cted

by

HLA

to a

sses

s po

ssib

l.sin

ce R

I act

iviti

es w

ere

halte

d by

Dyn

amac

1o"

Q.

O

Tf§r '

CCL<

2

U-OCoOQ.

oV

a1

2:

Util

ity c

lear

ance

and

to e

valu

ate

(his

rem

ote

sens

ing

tec

durin

g th

e so

il in

vest

igat

ion

I—o"O4Uc3

O

•f§:o"uc3

y. <T3i 03 u

2 I^ 3

, O

Initi

al e

xplo

rato

ry b

orin

gs E

B-I,

EB-2

perfo

rmed

by

H,

stra

tigra

phy

and

iden

tify

the

seco

nd w

ater

-bea

ring

zone

Supe

rfund

Site

bou

ndar

ies

1— •O4OC

2,3.S

IN"01uc=3

oi

"= =

^ 3, "3

r- u

^ 5^ ^3• c^ <3"O qj

Inst

alla

tion

of fo

ur m

onito

ring

wel

l pai

rs (

5-S

/5-M

, 6-S

S/8-

M) t

o as

sess

whe

ther

sub

stanc

es d

etec

ted

at th

e Su

f

?— >

oo"

jj0

q.§;«-c~3~"

.•5Cna

t*.0</»

Oco

prev

ious

act

iviti

es h

ad m

igra

ted

offs

ite a

nd/o

r to

othe

r |Ar

ea

- o5 ^

8 £

a 3i. _o— c? s3^ ~

HLA

col

lect

ed s

even

soi

l, si

x se

dim

ent a

nd f

our

surfa

ctPI

CO

RP

pro

perty

and

the

stre

am c

hann

el a

long

the

nor

Stud

y Ar

ea.

o>o\^

_o§>

0

_ro\

t.ujo2uO

!/li/1

U ———(l/1 ;?^ 50 -,

^ >>— 350 C/D3 u

2 -c

Inst

alla

tion

of s

even

2nd

zon

e m

onito

ring

wel

ls,

9-M

il

exte

nt o

f sub

stan

ces

dete

cted

m th

e no

rther

n po

rtion

of i

o\

r--~b1JU

^0

1 1§;^>,3

-3O

"5

"y^•5^c

Rec

ords

sea

rch

and

field

rec

onna

issa

nce

to id

entif

y po

l :w

ithin

two

mile

s do

wng

radi

cnt o

f the

Stu

dy A

rea

r^

-.__ .

s-3

0

>0

§5vT"OJ

U-Oo

O

1 1S s- "2~ 5tfl ,(0

o ^~ o

Initi

al c

onst

ruct

ion

of n

umer

ical

gro

undw

ater

flo

w m

ooof

conf

irmat

ion

wel

l loc

atio

ns a

nd to

ser

ve a

s ba

sis fo

r ;m

odel

ing

CT»Os

,sf

C3

O

vO?:j ->%3

"3 "0 ~2"3 31/1 cfl7- tfl t)5 ^ §

— CJ ^^ = •"5, o. ?c 2i OO -3

Inst

alla

tion

of s

oil b

orin

gs E

B-3

thro

ugh

EB-7

alon

g do

north

ern

porti

on o

f Stu

dy A

rea

to d

evel

op d

etai

led

stra

tive

rtica

l pro

file

of c

ondi

tions

with

in th

e se

cond

wat

er-b

,:

-o1OJ

3003

O

•O

oj"0*

"3

—

.5

-C =

^ 'o$ u

^2 —M U

Gam

ma

logg

ing

thro

ugh

casin

g of

sele

cted

cx.

sim

g w

ell

geop

hysi

cal l

ogs

wer

e no

i ava

ilabl

e or

not

rec

orde

d at

1 1

asse

ss p

rese

nce

of fi

ne-g

rain

ed u

nits

r-

.-

2s0

oS~-,

3

a:ao

a.TS

rt

30O

o_oo

oCO

o

_oQ.x

_U

30

O

5

S

3o6"^5

C -3" <

5 o

• 5 s 0 2

".I 1

1 <— T3 CO 3 —

£ c/5 «T3 ._ ^

2 ° I2 = *

o 5r->& 5

ooo£30C

o

5C/)

oO

"5

Q15 cc 2I I

CDcn-a--3-CDCOCC.

T3

toC ^

in o K.£ Q..t;_-M O» «/

'"6 c c

— ITJ (D.2 C71 Q.•a ; ^(Jj tAI L/

S ^W ^^> "P

"5.2 E^ T 3 0

"o % c o§ rN 3 .12 ^ c +±U O ^ co

ytjUin

_tn —

* 5SO £

g i! f

,2>,jO

lir?

IU

1

o3o_oeoc

'C•o

o

Ifi S2 2c\ o\

o

U1

^o

5

s -s £4* I 3 §

^3 ~~" • 4jc 5 oa o>3 w) ^£ O

Is I =1u — _-S J 2 "g a° 2 § 5,-5c " 41 c .£0(0 _ C -

f I T | a

1 1 f o I^ ab p eg- = J 2 S= ! o -35I ? ^ 3 =2 ^ CQ 22

c7) S uj -£ E

r— r-(7i c^a* ov

-3 ~3 =2 ^

"3 c

- o £ o

i2o

1S-o

§-5

_3Q.

t..

|

•O

g

H

<o

o

C _Do E

I tS

J32

S S2 S2 2

C1* ON

— rs-C .cu us s

°oONCTv

-_OUu.o

o8o

S

_| cu

fc I§ </>•5 t ~ =S 5 o en5 Q. s" So

'r! O 4J Qa" •*"

^ Q. t/>- so

IS t I1% * *n d —LLJ 5 51 C/5

O

o

o

•o _>^

"o <C. (UO JD^ 3J5 (-

2 I § Io 5 •= —

ff i IO ^— OO 'O T3 -, ^

) 30c £o o

o o

c c2 o03 ^5

I Jo o"o "o

CDCO

62

Receptor

Table 2Hazard and Risk Summary

Human Healtn Risk Assessment

Exposure Medium Carcinogenic Hazard

Current Trespasser Surface WaterSurfaceSoil/Sediment

1 x 10-* 0.1

Current Construction Subsurface SoilWorker

7x 10-*

Current Off-SiteAdult Resident

SurfaceSoil/Sediment(Fugitive dust)

3 x 10-7 0.006

Current Off-Site Child SurfaceResident Soil/Sediment

(Fugitive dust)

Current Industrial Soil Gas (IndoorWorker Air)

2 x 1C'7

5x 10-'2

0.02

0.000001

Future On-Site Adult Ground waterResident

9x 10- 600

Future On-Site Child Ground waterResident

8x JO'1 2000

63Table 3

Summary of Potential Cancer Risks and Non-Cancer Hazards From GroundwaterFuture On-Site Adult Resident

Kane and Lombard Study Area, OU2, Baltimore, MD

Chemical of

Concern

1 , 1 2-Trichloroethane

1,1-Dichloroethena1,2-Dichloroethane

AcetoneBenzene

Carbon TetrachlorideChlorobenzeneChloroform

cis-1 ,2-Dichloroethene

Tetrachloroethene

Thallium

Trichloroethene

Vinyl Chloride

Range of ObservedConcentrations

(Min - Max)

(ug/L)

2 - 3

0.3-24

3 - 3

4 - 4200

4 - 7

5 - 6

14-32

0.4-20

2 - 18000

0.6- 140

7.9-7.9

0.4-13000

1 -1850

Cancer Risk

1 OE-05

35E-04

43E-06

-

74E-06

1 3E-05

-

6.9E-06

-

2.5E-04

-

8.0E-01

7.1E-02

Non-Cancer Hazard Quotient

Primary

Target Organ

Blood

Liver

N/A

Liver/Kidney

Blood

Liver

Liver

Liver

Blood

Liver

N/A

N/A

Liver

ExposureRoutes Total

58E-02 '

3 9E-02

3 2E-02

53E»00

2.4E-01

6.1E-01

35E-01

23E-00

6 1E»01

1 8E+00

1 6E+00

7 8E-01

4 1E+02

Table 4Summary of Potential Cancer Risks and Non-Cancer Hazards from Groundwater

Future On-Site Child ResidentKane and Lombard Study Area, OU2, Baltimore, MD

Chemical ofConcern

1,1,2-Trichloroethan*

1,1-Oichloroethene

1 ,2-Dichloroethan«

AcetoneBenzeneCarton TetrachlorideChlorobenzene

Chloroform

cis-1, 2-OichloroetheneTetrachloroetheneThallium

Trichloroethene

Vinyl Chloride

Range of ObservedConcentrations

(Min - Max)(ug/L)

2 - 8

0.3 - 24

3 - 3

4-4200

4 - 7

5 - 6

14-32

0.4 - 20

2 - 1 8000

0.6-140

f.9 - 7.9

04- 13000

1 - 1850

Cancer Risk

6.9E-06

23E-04

2.9E-06

-

49E-06

86E-06

-

4.7E-06

-

1 6E-04

-

67E-01

97E-02

Non-CancerPrimary

Target Organ

Blood

Liver

N/A

Liver/Kidney

Blood

Liver

Liver

Liver

Blood

Liver

N/A

N/A

Liver

HazardIndex

1 8E-01

2.3E-01

8.9E-02

1 4E+01

66E-01

1 6E+00

9 3E-01

6.5E+00

1 5E+02

4 3E-HDO

4.3E+00

1 8E*02

1 2E-03

64

TABLE 5

GROUND WATER STATUTORY REQUIREMENTS and RISK-BASEDPERFORMANCE STANDARDS (EXAMPLE)

Contaminant ofConcern

1,1,2-Trichloro-ethane

1,1-Dichloro-ethene

1 ,2-Dichloro-ethane

Acetone

Benzene

CarbonTetrachloride

Chlorobenzene

Chloroform

cis-1,2-Dichloroethene

Tetrachloro-ethene

Thallium

Trichloroethene

Vinyl Chloride

Federal Non-zeroMCL Goal

3

7

-

-

-

-

100

-

70

-

0.5

-

-

., ———————————Federal MCL

5

. 7

5

-

5

5

100

80

70

5

2

5

2

Maryland MCL

_2

7

5

-

5

5

-

-

70

5

2

5

2

Performance1

Standard(example)

0.5

0.04

0.4

100

0.6

0.5

9

1

70

0.9

0.5

0.6

0.4

All values are provided in micrograms per liter, also known as parts-per-billion.

' Values for iron, manganese, and methylene chloride - - for which neither MCLGs or MCLshave been developed - - used in the Performance Standard example were 900, 200, and 5 micrograms perliter, respectively.

2 "-" denotes there is no non-zero MCLG or Maryland MCL for this chemical.

65

Table 6Applicable or Relevant and Appropriate Requirements (ARARs)

and Policies To Be Considered (TBCs)[The substantive requireme..U of the following statutes/regulations are applicable unless otherwise noted.)

ARARorTBC

Federal MaximumContaminant Levels andNon-Zero MaximumContaminant Level Goals

Maryland MaximumContaminant Levels

Maryland Surface WaterQuality Protection Regs.

Maryland Water PollutionControl Regulations (Use I)

Maryland Water PollutionControl Regulations (Use I)

National Pollutant DischargeElimination System

Executive Order 11990(Protection of Wetlands);procedures on FloodplainManagement and WetlandsProtection

Maryland WaterManagement Regulations

Maryland Waterworks andWaste System Operators

Maryland Board of WellDrillers

Maryland Well ConstructionRegulations

Maryland Well ConstructionRegulations

Legal Citation40C.F.R. §§ 141.11 - 141.12,40C.F.R. §§ 141.50- 141.51,40C.F.R. §§ 141.61 - 141.62

COMAR26.04.01.06-.07

COMAR 26.08.02.01 - .03 (Use I)

COMAR 26.08.03.01 - .02 and .07

COMAR 26. 08. 04

40C.F.R. §§ 122- 125

40 C.F.R. Part 6, Appendix A

COMAR 26.17.02.05, .09, .10, and .1 1

COMAR 26.06.01

COMAR 26.05. 01

COMAR 26.04.04.07

COMAR 26.04.04. 10

Summary of RequirementFederal Drinking Water standards relevant andappropriate to the cleanup of ground water.

State Drinking Water standards relevant andappropriate to the cleanup of ground water.

Provides criteria for discharges to surface waters.(Pump & Treat Alternative only)

Provides discharge limitations.(Pump & Treat Alternative only)

Describes conditions to be included in a permit.(Pump & Treat Alternative only)

Standards for point source discharges to waters of theUnited States. (Pump & Treat Alternative only)

These regulations establish standards for determiningthe extent of mitigation where wetlands are impacted.The substantive requirements of these regulations willbe attained.

Requires management of stormwater.

Requirements for the operators of waterworks andwaste systems.

Requirements for well drillers.

Standards for the construction of wells.

Maintenance requirements for well owners.

AR30H95

66

Table 6 (continued)Applicable or Relevant and Appropriate Requirements (ARARs)

and Policies To Be Considered (TBCs)

Maryland Well ConstructionRegulations

Maryland Water Appropria-tion or Use Regulations

Maryland UndergroundInjection Control Program

Underground InjectionControl Program

Maryland Ambient AirQuality Standards andGuidelines

Maryland General EmissionStandards

Visible Emissions

Particulate

Volatile OrganicCompounds

Nuisance

Odors

Control of Air Emissionsfrom Air Strippers atSuperfund Ground WaterSites

COMAR26.04.04.il

COMAR 26. 17.06

COMAR 26.08.07

40C.F.R. Part 144

COMAR 26. 11. 04

COMAR 26. 11. 06.02

COMAR 26. 1 1 .06.03(B) (2)(a) and (D)(D-(4)

COMAR 26. 1 1 .06.06(B)( 1 )(b) and (C)(D-(3)

COMAR 26. 11. 06.08

COMAR 26. 11. 06.09

OSWER Directive 9355.0-28,June 15, 1989

Standards for the abandonment of wells.

Establishes criteria for persons appropriating or usingwater.

Maryland underground injection requirements.(ERD Alternative only)

Prohibits underground injection unless requirementsare met. (ERD Alternative only)

(Pump & Treat Alternative only)

Provides air quality standards, general emissionstandards and restrictions for air emissions fromarticles, machine, equipment, etc. capable ofgenerating, causing, or reducing emissions.

This policy guides the decision of whether additionalcontrols (beyond those required by statute orregulation) are needed for air strippers at ground watersites.

67

Table 7Projected Costs for Enhanced Reductive Oechlorlnation

Kane and Lombard OU-2, Balrtmore, MarylandPage 1 of 1

ITEM

I. ADMINISTRATIVE ACTIONS1 Accaaa AgrawiMfiV2 PxTTWBng

Subtotal:

II. GENERAL ACTONS/SITE PREPARATION1 MoMzalioiVDeinoMzitton2. Wri Straying

Subtotal:

III. ENHANCED REDUCTIVE OECHLORINATION1 Hydraufc Tmang2. Modelng3 PMTaattig4 RecrcuMton W«te and Feed Sy»t»m5. Monitoring Well8 Electrical Hookup7 Start-up md Teattng

SuMotat

IV. LONG-TERM MAINTENANCE. MONITORING & REVIEW1. System Operation md Martananc*2. System Monitoring and Reporting3. Groundwater Montonng & Reporting • Yaara 1 Itirougn 34. Qrounowater Montoring 4 Reporting - Year* 4 Inroogh MS. Fw»-Y»»f Rninm (•)

SuMoM:

SUBTOTAL (1. II. III. and IV)

V IMPLEMENTATION COSTS

t Conrtuclion Miraganwnt 12% of Syttwn SuMMri2. EngrMmg A Dcvgn 1 9S of SyMMn SuMMH3. Co«t Conw>a«ocy 3SH of CapM CaM4 OAMContfngwey 1 SH of O4M COM5 En wcnng, Admr»«r«t>on. i Ug«( SH of OAM OMte

Subtotal:

A. TOTAL CAPITAL COSTS (w* contngtnqr)B TOTAL ANNUAL COSTSC. TOTAL PRESENT WORTH OF ANNUAL COSTS (v««n ooottngancy. wlmn. i»9

TOTAL PRESENTT WORTH OF CAPITAL AND ANNUAL COSTS (A - C)

QUANTITY UNITS UNTT

COST

10 E*cn S20.0001 IS US 000

CAPITAL ANMUALCOST 0 4 U

COST

(200000US 000

1213 000 iO

1 LS 12QOOOt LS 15000

12000019000

VMOOO «0

1 LS MO 000t LS S3C 0001 LS t82S.OOOA Ead< JISSOOO4 Etch UJOOO« E*cn S12.SOO1 LS US 000

uoooouoooo

182JOOO

(930.000(140.000(75000(25 000

J1 915000 M

19 Ye«r»15 Y«ir«3 Yen

27 Ev*nB9 Yean

(90.000WO 000

1240000tMOOO190000

tO 14*3000

12.175000 V4M.OOO

(230.400UMOOOt78 1.300

$72.000124000

Jl 279700 Stt.OOO

«

(3.494.700(4*0000

o»»wrrAOWTH

COST ,-bl

to

to

to

(903400(401 900(447900(MO 000(249 SCO

13082.200

53082.200

(499300(193.100

(012.400

(3 874 MO

(7 129000

Total 1C • ERD PV(7,343.000

(a) - Reviews and reports of site conditions are required every 5 years under CERCLA because wastes will ^mam on site.(b) - Present-worth costs am calculated for 15 years of operation and 30 years of monitoring using 55% .merest: year 2002 dollarsLS - Lump Sum

Permitting would b« required for construction and mqlasses injectionHandling and disposal costs based on the IOW being classified as non-hazardous wasteAll well installation and sampling assumed to be conducted in Level D PPE

Revised 3-07-03