9 1 7 5 G u i l f o r d R o a d • S u i t e 3 1 0 • C o l u m b i a , M D 2 1 0 4 6 v o i c e : ( 4 1 0 ) 2 9 0 – 7 7 7 5 • f a x : ( 4 1 0 ) 2 9 0 – 7 7 7 6 • w w w . a r m g r o u p . n e t

May 8, 2020

Ms. Barbara Brown Project Coordinator Maryland Department of the Environment 1800 Washington Boulevard Baltimore, MD 21230

Re: AST Characterization Work Plan Area B: Parcel B19

Tradepoint Atlantic Sparrows Point, MD 21219

Dear Ms. Brown:

ARM Group LLC (ARM), on behalf of EnviroAnalytics Group, LLC (EAG), completed a Phase II Investigation of Parcel B19 (the Site) in May 2017. The findings of this investigation were summarized in the Phase II Investigation Report for Parcel B19 (Revision 0 dated April 9, 2018), which was approved by Maryland Department of the Environment (MDE) via email on September 26, 2018. Parcel B19 is located within Area B of the Tradepoint Atlantic (TPA) property located in Sparrows Point, Maryland. The location of the Site in relation to the rest of the TPA property is provided on Figure 1.

Four large aboveground storage tanks (ATSs) previously occupied the southwest portion the Site. These tanks were intact during the completion of preceding groundwater investigation activities associated with the Area B Groundwater Phase II Investigation and soil investigation activities associated with the Parcel B19 Phase II Investigation. The locations of the historical ASTs are shown on Figure 2 (the ASTs are still visible on recent aerial imagery). Now that these ASTs have been removed, the MDE has requested that supplemental investigation work be conducted to evaluate the possibility of subsurface contamination associated with these historical ASTs.

Proposed Field Methods

Pursuant to MDE direction, supplemental soil and groundwater characterization is proposed to be completed at the locations shown on Figure 2. Two soil borings and one temporary groundwater sample collection point (piezometer) will be installed within the footprint of each of the two larger former ASTs. One soil boring and one piezometer will be installed in the center of each of the two smaller AST footprints. Soil and groundwater sampling plan summary tables are included as Attachment 1.

ARM Project 20010219 2 May 8, 2020

A R M G r o u p L L C

Recently, significant surface water ponding has been observed in the footprints of the smaller ASTs. If ponding prevents soil sampling within the smaller AST footprints, MDE has stated that the prior Phase II Investigation data in this area will suffice. Groundwater sampling will still be required, and the proposed piezometer locations will be shifted as necessary. The MDE will be notified of any observation of non-aqueous phase liquid (NAPL) in soils or groundwater, and NAPL will be delineated in accordance with standard methods.

Soil samples will be screened and analyzed in accordance with procedures referenced in the Quality Assurance Project Plan (QAPP) Worksheet 21 – Field SOPs (Standard Operating Procedures), SOP No. 009 – Sub-Surface Soil Sampling. Soil samples will be analyzed for SVOCs, TAL-Metals, Oil & Grease, TPH-DRO, TPH-GRO, hexavalent chromium, and cyanide. Samples with a sustained photoionization detector (PID) reading of greater than 10 ppm will also be analyzed for VOCs. The soil sample collected from the shallow interval (0 to 1 foot) will be analyzed for PCBs.

Groundwater samples are proposed to be collected from piezometers within the former AST footprints. The groundwater samples will be collected in accordance with procedures referenced in the QAPP Worksheet 21 – Field SOPs, SOP No. 006 – Groundwater Sampling. All groundwater samples will be analyzed for VOCs, SVOCs, TAL-Metals (dissolved only), Oil & Grease, TPH-DRO, TPH-GRO, hexavalent chromium (dissolved only), and total cyanide.

Pace Analytical Services, Inc. (PACE) of Greensburg, Pennsylvania will provide the analytical services for this project. Analytical methods, sample containers, preservatives, and holding times for the sample analyses are listed in the QAPP Worksheet 19 & 30 – Sample Containers, Preservation, and Holding Times.

After sampling has been concluded at a location, all down-hole equipment will be decontaminated according to procedures referenced in the QAPP. All field investigation procedures will be conducted in accordance with the property-wide Health and Safety Plan (HASP). All investigation derived waste (IDW) will be appropriately managed and stored in accordance with the requirements of the QAPP.

Reporting

Once characterization activities have been completed, a Characterization Report will be prepared to document the completed field activities. The report will include a brief description of the field methods, soil boring and piezometer construction logs displaying the geologic information, and a summary of the analytical results. The results will also be incorporated into Screening Level Risk Assessments (SLRAs) within Response and Development Work Plans (RADWPs) for future development in this area, as applicable. More investigation into the extent of the contamination at the former ASTs may be necessary pending the results of the field activities or per the request of EAG, TPA, or the MDE.

ARM Project 20010219 3 May 8, 2020

A R M G r o u p L L C

If you have questions regarding any information covered in this document, please feel free to contact ARM Group LLC at (410) 290-7775.

Respectfully Submitted, ARM Group LLC

Joshua M. Barna, G.I.T. Eric S. Magdar, P.G. Staff Geologist Vice President

FIGURES

Parcel B12

Parcel B11

Parcel B10Parcel B13

Parcel B20

Parcel B18

Parcel B9

Parcel B4 Parcel B5

Parcel B17Parcel B19

Parcel B3Parcel B2Parcel B1

Parcel B23

Parcel B15

Parcel B25Parcel B24

Parcel B8

Parcel B7

Parcel B14

Parcel B21Parcel B22

Parcel B16

Parcel B6Parcel A10

Parcel A3 Parcel A1Parcel A4

Parcel A6Parcel A16

Parcel A17Parcel A18

Parcel A2

Parcel A8

Parcel A15Parcel A12

Parcel A7

Parcel A11

Parcel A14

Parcel A5

Parcel A9

Site Boundary

Parcel Boundaries

Private Property

Tradepoint AtlanticArea A and Area B Parcels

EnviroAnalytics GroupBaltimore County, MD

1Figure

Tradepoint Atlantic

q 0 1,000 2,000500Feet

Parcel A13

March 4, 2020

Area B: Project 200102Area A: Project 200101

@A

@A

@A

@A

@A@A

@A

@A

@A

@A

@A

@A

@A

@A

@A

@A

@A

@A

@A

@A

@A

@A

@A

@A

@A

B19-047-SB/PZ

B19-048-SB/PZ

B19-045-SB

B19-046-SB/PZB19-043-SB/PZ

B19-044-SB

Parcel B5

Parcel B19

Parcel B3

MD iMAP, USDA

@A Proposed Soil Boring Location@A Proposed Soil Boring/Piezometer Location@A Previously Investigated Phase II Boring

Former ASTParcel Boundary

Parcel B19 Former AST InvestigationProposed Sample Locations 2Figure

April 30, 2020

qTradepoint Atlantic

ARM Project 20010219EnviroAnalytics GroupBaltimore County, MD

0 100 20050Feet

Parcel B5

ATTACHMENT 1

Parcel B19 AST Characterization Sampling Plan SummaryFormer Sparrows Point Steel Mill

Sparrows Point, Maryland

Source Area/ Description

REC & Finding/ SWMU/

AOC

Figure or Drawing of Reference

RationaleNumber of Locations

SampleLocations

Boring Depth Sample DepthAnalytical

Parameters: Soil Samples

Former ASTs Site VisitInvestigate potential impacts related to former aboveground storage tanks

(potential leaks or releases). 6

B19-043 through B19-048

Total depth of 20 feet or

groundwater.

0-1', 4-5', 9-10' bgs. 4-5' interval may be adjusted in the field

based on observations or field screening.

VOC^, SVOC, Metals, DRO/GRO,

O&G, PCBs (0-1')

Total: 6

VOCs - Volatile Organic Compounds (Target Compound List)^VOCs are only collected if the PID reading exceeds 10 ppmSVOCs - Semivolatile Organic Compounds (Target Compound List)Metals - (Target Analyte List plus Hexavalent Chromium and Cyanide)O&G - Oil and GreaseDRO/GRO - Diesel Range Organics/Gasoline Range OrganicsPCBs - Polychlorinated Biphenylsbgs - Below Ground Surface

Table 1 - Soil Sampling Summary

ARM Project No. 20010219 Page 1 of 1 April 30, 2020

Parcel B19 AST Characterization Sampling Plan SummaryFormer Sparrows Point Steel Mill

Sparrows Point, Maryland

Source Area/ Description

REC & Finding/ SWMU/

AOC

Figure or Drawing of Reference

Condition of Existing WellNumber of Locations

Sample Locations

Boring Depth Screen IntervalAnalytical Parameters: Groundwater Samples

Former ASTs Site Visit N/A 4

B19-043, B19-046 through B19-048

Total depth of 7 feet below water table.

7 feet below water table to 3 feetabove water table.

VOC, SVOC, Metals (dissolved),

Cyanide (total), O&G, DRO/GRO

Total: 4

Field measurements include pH, DO, ORP, conductivity, temperature. VOCs - Volatile Organic Compounds (Target Compound List) Metals analysis will include dissolved hexavalent chromium SVOCs - Semivolatile Organic Compounds (Target Compound List)

Metals - (Target Analyte List plus Hexavalent Chromium and Cyanide)O&G - Oil and GreaseDRO/GRO - Diesel Range Organics/Gasoline Range Organics

Table 2 - Groundwater Sampling Summary

ARM Project No. 20010219 Page 1 of 1 April 30, 2020