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FIVE-YEAR REVIEW REPORT FOR

KANE AND LOMBARD SITE BALTIMORE

BALTIMORE COUTY, MARYLAND

Prepared by

U.S. Environmental Agency Region 3

1650 Arch Street Philadelphia, PA 19103

Abraham Ferdas, Director Date: Hazardous Site Cleanup Division USEPA, Region 3

Table of Contents Continued

X. PROTECTIVENESS STATEMENT 21 XI. NEXT REVIEW 21 Tables Page 1. CHRONOLOGY OF SITE EVENTS 5 2. ANNUAL SYSTEM OPERATIONS/O&M COSTS 15 3. ISSUES 20 4. RECOMMENDATIONS AND FOLLOW-UP ACTIONS 21 Attachments 1. FlGURES 2. LIST OF DOCUMENTS REVlEWED 3. APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS 4. PHOTOGRAPHIC DOCUMENTATION LOG 5. SITE INSPECTION CHECKLIST

ACRONYMS AlVD ABBREYIATIO5S

AQC Administrative Order on Consent ARAR Applicable or relevant and appropriate requirements CD Consent Decree CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CFR Code of Federal Regulations COC Contaminant of concern COMAR Code of Maryland Regulations EPA U.S. Environmental Protection Agency ERDS Enhanced reductive dechlorination system FS Feasibility Study HA Hazard Assessmeat HHRA Human health risk assessment HLA Harding Lawson Associates LDR Land disposal restrictions MCL Maximum contaminant level MDE Maryland Department of the Environment MSL Mean sea level N'CP National Oil and Hazardous Substances Pollution Contingency Plan NPL National Priorities List O&M Operation and rnaintenance OU Operable Unit PRP Potentially responsible party RAO Remedial action objective RI Rernedial Iavestigatian ROD Record of Decision RPM Remedial Project Manager

EXECUTIVE SUMMMY

The Kana and Lombard site in Baltimore, Maryland, was divided into two operable units (OU): OU-1 and

OU-2.

The remedy at OU-1 included removal of staged drums left by response personnel following completion of a

removal action; construction of a subsurface slurry wall to contain contaminanted groundwater and prevent

clean groundwater from entering the waste area; construction of a multi-layer cap over the waste area to

prevent infiltration of precipitation and surface water into the waste area; and construction of a drainage

system to dewater the portion of the site under the cap.

The remedy for OU-2 has not been implemented as of the issuance of this report. The selected remedy

includes implementation of a soil management plan for the contaminated soil areas; implementation of an

enhanced reduction chlorination system to reduce contamination in the second and third water bearing zones;

and institutional controls to prohibit residential development within the soil management plan area and

restrict groundwater use until performance standards for the remedy have been met.

This five-year review found that the remedy for OU-1 was constructed in accordance with the Record of

Decision (ROD). The remedy for OU-2 has not been implemented, but the remedy is still applicable and

relevant and is expected to be protective.

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FIVE-YEAR REVIEW SUMMARY FORM

SITE IDENTIFICATION

Site Name: Kane and Lombard Site

EPA ID: MDD980923783

Region: 3 State: MD City/ County: Baltimore/Baltimore

SITE STATUS

NPL status: _X_ Final ___ Deleted ___ Other (specify)

Remediation status (choose all that apply): _X_ Under Construction _X_ Operating ___ Complete

Multiple OUs ? _X_Yes ___No Construction Complete Date: 6 / 91 for OU-1, OU-2 Not Started

Has site been put into reuse? _X_ Yes ___No

REVIEW STATUS

Lead Agency: _x_ EPA ___ State ___ Tribe ___ Other Federal Agency

Author name: Christopher Corbett

Author Title: Remedial Project Manager Author affiliation: U.S. EPA Region 3

Review Period: 7/26/2004 to 11/15/2004

Date(s) of site inspection: 7/26/2004 and 9/20/2004 and 4/6/2005

Type of review: _x_ Post SARA ___ Pre SARA ___ NPL- Removal only ___ Non- NPL Remedial Action Site ___NPL State/ Trib-lead ___ Regional Discretion

Review Number: ___ 1 (first) ___ 2 (second) _x_3 (third) ___ Other (specify)

Triggering Action: ___ Actual RA On- Site Construction at OU #___ ___ Actual RA Start at OU # ___ ___ Construction Completion _x_ Previous Five- Year Review Report ___ Other (specify) ___________________________________________________________________

Triggering action date (from WasteLAN): 5/4/2000

Due date (five years after triggering action date): 5/4/2005

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FIVE-YEAR REVIEW SUMMARY FORM (Continued)

Issues:

Because of the uncertainty surrounding the well 89-07 and 89-08 in OU-1, a drawdown pump test should be

performed to verify that the slurry wall is protective.

Recommendations and Follow-up Actions:

The drawdown pump test for wells 89-07 and 89-08 in OU-1 should be performed as soon as cleanup

activities for OU-2 have started, in accordance with the agreement between EPA and the potentially

responsible parties (PRPs).

Protectiveness Statement(s):

The components of the remedy constructed as part of the OU-1 ROD remain protective of human health and

the environment; however, because the remedy for OU-2 is not complete, the overall remedy for the site is

not considered protective of human health and the environment at this time.

Long-term Protectiveness:

Long- term protectiveness of the remedial action at OU-2 will be verified when the remedy for OU-2 is in

place and sufficient data have been generated to ensure that groundwater cleanup goals are achieved.

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Kane and Lombard Site

Baltimore, Maryland

Third Five-Year Review Report

I. INTRODUCTION

The purpose of the five-year review is to determine whether the remedy at the site is protective of human

health and the environment. The methods, findings, and conclusions of reviews are documented in Five-Year

Review reports. In addition, Five-Year Review reports identify issues found during the review, if any, and

identify recommendations to address them.

The U: S. Environmental Protection Agency (EPA) is preparing this Five- Year Review report pursuant to

the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) §121 and the

National Contingency Plan (NCP). CERCLA §121 states:

If the President selects a remedial action that results in any hazardous substances, pollutants, or

contaminants remaining at the site, the President shall review such remedial action no less often than

each five years after the initiation of such remedial action to assure that human health and the

environment are being protected by the remedial action being implemented. In addition, if upon such

review it is the judgement of the President that action is appropriate at such site in accordance with

section [104] or [106], the President shall take or require such action. The President shall report to

congress a list of facilities for which such review is required, the results of all such reviews, and any

actions taken as a result of such reviews.

EPA interpreted this requirement further in the NCP; 40 CFR §300.430(f)(4)(ii) states:

If a remedial action is selected that results in hazardous substances, pollutants, or contaminants

remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead

agency shall review such action no less than every five years after the initiation of the selected

remedial action.

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EPA Region 3 conducted the five- year review of the remedy implemented at the Kane and Lombard site in

Baltimore, Maryland. This review for the entire site was conducted by the Remedial Project Manager (RPM)

from July 2004 to April 2005. This report documents the results of the review.

This third five- year review for the Kane and Lombard site was initiated on July 26, 2004, and completed on

April 15, 2005. The triggering action for this review was the second five-year review completed on May 4,

2000. This third five-year review is required because hazardous substances, pollutants, or contaminants

remain at the site above levels that allow unlimited site use or unrestricted exposure.

This five-year review report discusses the site chronology, background, remedial actions, progress since the

last five-year review, the five-year review process, technical assessment, issues, recommendations and

follow-up actions, the protectiveness statement, and the next review. This report also includes five

attachments. Attachment 1 provides the report figures, Attachment 2 includes a list of documents reviewed,

and Attachment 3 provides a table of applicable or relevant and appropriate requirements (ARARs).

Attachment 4 provides the photographic documentation log, and Attachment 5 provides a copy of the site

inspection checklist.

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II. SITE CHRONOLOGY

Table 1 below presents the major events for the Kane and Lombard site.

TABLE 1 CHRONOLOGY OF SITE EVENTS

Event Date

Uncontrolled on-site dumping and burning of solid and hazardous waste 1962 - 1984

State of Maryland discovered several hundred drums on site 11/1980

The State of Maryland negotiates with the site owners to perform a cleanup of the site.

11/1980 - 8/1983

U.S. Environmental Protection Agency (EPA) assessed the site and performed a removal action which removed surface contamination (drums and contaminated soil and water), constructed security fencing, and installed a soil layer to restore and stabilize the site.

5/1984 - 6/1984

Site proposed for inclusion in EPA's National Priorities List (NPL) 10/1984

Site listed on EPA NPL 6/1986

EPA completed a combined Remedial Investigation/Feasibility Study (RI/FS) of the site

9/1987

The Record of Decision (ROD) for selecting the remedy for Operable Unit (OU-1) was signed.

9/1987

Remedial actions at OU-1 occurred, including removal of additional staged drums left by response personnel during removal activities, construction of a subsurface slurry wall to contain contaminated shallow groundwater and prevent clean groundwater from entering the waste area beneath the parcel, construction of a multi-layer cap over the waste area to prevent infiltration of precipitation and the surface water into the waste area, and construction of a drainage system to dewater the portion of the site below the cap

9/1987 - 8/1991

EPA issued an Administrative Order on Consent (AOC) for an RI/FS of OU-2 7/1993

EPA completed the first five-year review of the site 4/1994

EPA issued a Consent Decree with the PRPs concerning Operation and Maintenance (O&M) of OU-1

11/1995

EPA issued a Unilateral AOC to the site owners to restrict site uses that would disturb the integrity of the multi-layered cap

3/1997

EPA completed the second five-year review of the site 5/2000

A cell telephone tower was constructed at the edge of the parking lot of OU-1 2001

EPA issued a combined RJ/FS for OU-2 9/2003

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Event Date

The ROD for selecting the remedy for OU-2 was signed 9/2003

III. BACKGROUND

Physical Characteristics

The Kane and Lombard site consists of a former landfill located near the intersection of Kane and Lombard

Streets in the Orangeville subdivision in the southeast quarter of Baltimore, Maryland, and all areas to which

wastes or contamination from the landfill have migrated. The site consists of two OUs: OU-l is immediately

south of Lombard Street and OU-2 is the remainder of the landfill to the north (see Figures in Attachment 1).

OU-l includes a 9.7-acre parcel of land that contains a landfill covered with a multi-layer cap which is

enclosed with a slurry wall and is currently operating as a golf driving range, miniature golf course, and a

taxi cab dispatching facility. Also located on-site is a parking lot and cell telephone tower. According to the

ROD, OU-l includes shallow groundwater beneath the parcel. OU-l is southwest of the intersection of Kane

and Lombard Streets directly adjacent to Patterson High School to the east and south, a Roadway trucking

terminal and the drainage area for OU-2 to the west, and Lombard Street to the north, Interstate Route 95 lies

approximately 700 feet east of OU-l.

OU-2 occupies about 40 acres and consists of the remainder of a former landfill located immediately north

and northeast of OU-l, as well as the groundwater impacted by the waste disposed of in OU-l and OU-2

(except for the shallow groundwater directly below OU-l). OU-2 includes the property north of Lombard

Street and northwest of Kane Street. The property extends on the northwestern boundary to the drainage area

adjacent to a Conrail rail line. The soil area of contamination in OU-2 contains Picorp, a sea-land trailer

repair facility; Register Photo (now vacant); and a CTI trucking facility. The contaminated groundwater

plume extends approximately 6,300 feet southeast from the edge of the landfill.

Site Topography and Geology

Site topography and geology information presented in this section is based on information obtained from the

remedial investigation (RI)/feasibility study (FS) report for OU-2. Land surface across both OUs of the site

ranges from 95 feet above mean sea level (MSL) in the southwestern comer of OU-1 to approximately 40

feet above MSL near the northern edge of OU-2. The land surface generally slopes to the northeast, although

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there are steep embankments that slope to the west along the western border of the OU-1 landfill cap. The

OU-1 cap area is generally at a higher elevation than adjoining properties to the north, east, and west.

Lombard. Street, which is located north of OU-1, is generally at a lower elevation than the rest of the site.

The Kane and Lombard site is underlain by crystalline rocks and unconsolidated deposits of late Precambrian

to early Paleozoic age (630 to 435 million years ago) and of the Cretaceous age (138 to 63 million years

ago). Recent (10,000 years ago to present) artificial fill is located over the older materials at an average

thickness of 10 to 20 feet and a maximum observed thickness of up to 63 feet. The crystalline rocks are

gabbros, pyroxenites, and metamorphic assemblages of the Baltimore Gabbronic Complex. These rocks are

not exposed at the site, but outcrops occur north and west of the site in the Piedmont Physiographic Province.

The bedrock surface dips approximately southeast and was not encountered during well installations and

exploratory borings advanced at the site.

The unconsolidated deposits are represented by three distinct formations of the Potomac Group (in ascending

stratigraphic order): Patuxent, Arundel, and Patapsco. In general, the Patuxent and Patapsco Formations

consist of sand with subordinate amounts of silt and clay, and the Arundel Formation consists of clay. The

contacts between the formations are conformable and gradational. All units appear to thicken, down dip,

toward the southeast.

The Patuxent formation unconformably overlies bedrock and generally appears to decrease in grain size from

bottom to top. In borings advanced within the Kane and Lombard groundwater study area, the bottom of the

Patuxent formation was not identified; therefore, the thickness of the unit is unknown. Harding Lawson

Associates (HLA) reported a silty clay unit in all 25 borings advanced into the Patuxent formation at the site

at thicknesses ranging from 17.5 feet at well 5-D to 39 feet at well 6-D (located on the athletic fields of

Patterson High School); however, regional geologic investigations indicate that the silty clay unit is laterally

discontinuous.

The Arundel Formation crops out at the site where not concealed by artificial fill. Reportedly, the Arundel

Formation is laterally discontinuous. Based on the existence of coarser (e.g., sand) Pleistocene (2 million to

10,000 years ago) deposits and cut-and-fill stratigraphy in borings advanced into the Arundel Formation in

the vicinity of monitoring well 4-M (located in the athletic fields of Patterson High School), the clay unit

may be locally absent. If the Arundel Formation is absent, the Patapsco Formation may directly overlie the

Patuxent Formation.

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The Patapsco Formation is similar in lithology to the Patuxent Formation. The formation crops out to the

southeast and was not reported in exploratory borings advanced at the site. However, HLA reported the

presence of the Patapsco Formation in exploratory borings 10-M, 11-M, EB-6, and EB-7 (located east of

Kane Street within the OU-2 groundwater area).

Three distinct aquifers and two aquitards have been identified in OU-2. The Patuxent Formation contains the

confined upper and lower Patuxent aquifers. The silty clay unit is the aquitard that separates the two Patuxent

aquifers at the site. The lower Patuxent aquifer is the lowermost waterbearing unit and unconformably

overlies bedrock. In exploratory borings advanced within OU-2, the bottom of the Patuxent Formation was

not identified; therefore, the thickness of the unit is unknown. Reportedly, four borings were advanced into

the "lower" Patuxent Formation at depths from 8 to 34 feet below the silty clay aquitard. Pump tests

conducted in the lower Patuxent aquifer at several locations approximately 3 miles southwest of the OU-2

groundwater. area produced hydraulic conductivity estimates ranging from 1.7 to 22.6 feet per day.

Groundwater flow through the lowermost aquitard, the silty clay unit in the middle portion of the Patuxent

Formation, is probably vertical. No known hydraulic tests specific to this unit have been conducted.

Regionally the upper Patuxent aquifer is bound at the top by the overlying Arundel aquitard and the bottom

by the underlying silty clay unit of the middle portion of the Patuxent Formation. Pump tests conducted in

the study area produced estimates for hydraulic conductivity ranging from 0.33 to 2.46 feet per day. In

addition, storativity estimates indicate a semi- confined to confined environment for the upper Patuxent

aquifer.

Groundwater flow in the uppermost aquitard, the Arundel Formation, is primarily vertical. Pump tests

conducted in the OU-2 groundwater area produced estimates for hydraulic conductivity in this unit ranging

from 3.1 x 10-5 to 4.3 x 10-4 feet per day.

The uppermost aquifer is the Patapsco Formation, which crops out east of the site. The Patapsco aquifer is

unconfined in the study area. Estimates of hydraulic conductivity in the Patapsco aquifer from sites located

several miles south of the study area are 36 to 90 feet per day.

Land and Resource Use

Use of the site prior to 1962 has not been verified. The site was used as a landfill between 1962 and 1984.

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Current uses for areas surrounding the site are residential, recreational, commercial, and industrial. The site

is within 0.25 mile from the John Hopkins Bayview Medical Center. Residential properties are located

within 0.33 mile southeast of OU-1. OU-1 is used for both recreational and commercial purposes. OU-2 is

used for both commercial and industrial purposes. The groundwater aquifer underlying the site is currently

not used as a drinking water source.

History of Contamination

Dumping and burning of waste began at OU-1 in the early 1960s and continued until the early 1980s.

Uncontrolled filling and waste disposal occurred in both OU-1 and OU-2 throughout this period.

Initial Response

In May 1984, EPA removed over 1,000 drums or drum fragments and contaminated soil from the OU-1 area,

installed security fencing, and installed a soil layer to restore and stabilize the OU. The site was proposed for

inclusion on EPA's National Priorities List (NPL) in October of 1984 and included on the NPL in June 1986.

Basis for Taking Action

Hazardous substances have been released at the site that may have impacted the environment and

surrounding community. Hazardous substances in each medium are listed below:

Groundwater

1,1,2-Trichloroethane 1,1-Dichloroethene 1,2-Dichloroethane Acetone Benzene Carbon tetrachloride Chlorobenzene Chloroform cis-1,2-Dichloroethene Methylene chloride Tetrachloroethene Trichloroethene trans-1,2-Dichloroethene Vinyl chloride Aluminum Antimony Arsenic Barium Cadmium Chromium Iron Lead Manganese Nickel Thallium Vanadium Zinc

Subsurface Soil Benzo(a) pyrene Dibenz(a, h) anthracene Trichloroethene Vinyl chloride Antimony Arsenic Iron Lead Manganese Thallium

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Soil Gas 1,2,4-Trimethylbenzene 1,3,5-Trimethylbenzene Benzene Trichloroethene

Surface Water

Acetone Dibromochloromethane Methylene chloride Aluminum Antimony Arsenic Chromium Iron Manganese Nickel Vanadium

Sediment and Surface Soil

Acetone Benzo(a) anthracene Benzo(a) pyrene Benzo(b) fluoroanthene Dibenz(a, h) anthracene Aroclor 1242 Aroclorl260 Aluminum Antimony Arsenic Copper Iron Manganese Thallium 2-(2-methyl-4-chlorophenoxy)

propionic acid Vanadium

A human health risk assessment (HHRA) was performed for OU-2, and subsurface soil and groundwater

media were found to contain compounds at concentrations exceeding EPA's risk management criteria for the

average or the reasonable maximum exposure scenarios. Risks from exposure to subsurface soil were

significant for construction workers because of the presence of lead and antimony. Risks from residential

exposure to groundwater were significant because of the presence of cis-l, 2-dichloroethene; trichloroethene;

vinyl chloride; iron; manganese; and thallium. Groundwater is not presently used as a drinking water source

in Baltimore but may be used as such in the future.

A screening level ecological risk assessment was performed for OU-2. The assessment identified potential

contaminants of ecological concern, migration pathways, and exposure pathways. The potential for

endangered species to be present at the site is not significant, and the on- site wetlands are not of high value

because they are constructed swales and ditches. The ecological risk assessment found that because of the

limited area within the site that could be considered ecological habitat and because of the area's low quality,

the few areas of elevated contaminant concentrations were not believed to be ecologically significant.

IV. REMEDIAL ACTIONS

Remedy Selection

Separate remedies were selected for OU-1 and OU-2. The ROD for OU-1 was issued in September 1987, and

the ROD for OU-2 was issued in September 2003.

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The remedial action objectives (RAO) selected for OU-l are stated in the ROD as follows: (1) isolate and

contain the wastes and contaminated media of the upper waterbearing zone in OU-1; (2) prevent clean water

from entering this area through local groundwater recharge to the shallow saturated zone or infiltration of

precipitation into the subsurface; and (3) prevent the off-site migration of contaminants through the flow of

groundwater from this waste disposal area. Specific remedial action tasks to achieve these objectives are

summarized below.

• Conduct clearing, grubbing, and preliminary grading. • Install a soil-bentonite/slurry trench wall grounded in a confining clay layer around the

perimeter of the waste area. The purpose of the slurry wall is to isolate on-site wastes and contaminated soil from local groundwater, thereby preventing migration of contaminants off site.

• Install a multi-layer cap over this portion of the site to prevent recharge to site groundwater and

to isolate waste materials from potential human contact. • Install an extraction well system to dewater the first water-bearing zone at this portion of the

site located within the confining layer/slurry wall boundaries. Discharge removed water into a small, on-site pre-treatment system and then into the Baltimore City's sewage treatment system.

• Install a gas venting system to collect and transfer the gases from below the impervious cap. • Install a groundwater monitoring system to assess long-term effectiveness of the remedial

design and construction. • Implement final grading of this portion of the site, including provisions for surface water

management and erosion control.

The RAOs selected for OU-2 are stated in the ROD as follows: (1) manage exposure to contaminated

subsurface soils in OU-2; (2) mitigate exposure by eliminating the potential to utilize groundwater

containing contaminants of concern (COC) as a potable water source; (3) eliminate, stabilize, or minimize

the further migration of the groundwater contaminant plume; and (4) reduce the concentration of COCs in

groundwater to result in a cumulative cancer risk no greater than 1 x 10-4 and a hazard index (HI) no greater

than 1. Specific remedial action tasks to achieve these objectives are summarized below.

• Facilitate the injection of organic carbon materials into contaminated groundwater at OU-2 by installing approximately eight injection wells in the core of the plume near Eastern Avenue.

• Reduce contaminants in groundwater to acceptable levels through use of an enhanced reductive

dechlorination system (ERDS) that shall include, but not be limited to, the injection of organic carbon materials into the groundwater at OU-2.

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• Evaluate the progress of the ERDS in achieving the performance standards by monitoring the size and location of the contaminant plume using a network of monitoring wells.

• Develop and implement a soil management plan to reduce risks at the locations within OU-2 that

contain elevated lead and antimony concentrations in soils. • Implement institutional controls to prohibit residential development at the soil management plan area

and restrict the use of groundwater until the performance standards for groundwater have been attained.

Remedy Implementation

The remedy for OU-1 was started in September 1987, and the construction of the slurry wall, multi-layer

cap, and dewatering system was completed in August 1991. No water has been pumped from the first

waterbearing zone inside the slurry wall of OU-1 since 1997.

The remedy for OU-2 has not been implemented as of this time, but will consist of the installation of wells to

inject and recirculate organic carbon; construction of subsurface vaults to contain the required tanks and

control systems; installation of several additional groundwater monitoring wells; collection and evaluation of

biochemical data and analytical data; institutional controls to manage exposure to workers and prohibit

residential development of properties containing surface soil contamination; institutional controls to prevent

the use of contaminated groundwater; and preparation and implementation of a soil management plan to

establish health and safety requirements for the excavation and disposal of contaminated subsurface soil if

property owners elect to excavate such soil in the future.

System Operations/Operation and Maintenance

Operation and maintenance (O&M) for OU-1 has been and will be provided by the settling parties AT&T

Technologies, Inc.; Baltimore Gas and Electric Company, Browning-Ferris Inc., and General Motors

Corporation under the 1995 Consent Decree WN-89-2898 entered November 11, 1995 between these parties,

the United States, and the State of Maryland.

The maintenance program detailed in the settlement with the above parties requires monthly monitoring of

the OU-1 parcel, which is performed by the settling parties contractor HLA, now MACTEC. The O&M work

plan for OU-1 is dated November 14, 1995, and was revised on February 11, 1997. Once a month, MACTEC

inspects the site and submits a report that includes (1) a description of the actions taken toward achieving

compliance with the Consent Decree (CD) during the previous month, (2) a description of all work plans and

other deliverables required by the CD completed and submitted in the previous month, (3) a description of all

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actions scheduled for the next month, (4) identification of all minor and major repairs, and (5) identification

of all modifications to the work plan or schedule. In addition to the monthly reports, MACTEC also submits

a quarterly progress report.

Several maintenance activities occurred since the last five- year review. Activities of note are summarized

below.

In August 2002 and again in April 2004, wind storms broke off 75-100 foot tall utility poles used to hold the netting surrounding the eastern and southern boundaries of the driving range. The poles are depicted in photographs No. 11 and 12 in the Photographic Documentation Log presented in Attachment 4. These poles are located outside the cap area, and it was determined the broken poles did not disturb the cap integrity. On both occasions, the poles were repaired following each incident.

The gas vents located on the cap are sometimes broken by golf balls from driving range activities.

Protective outer casings have been installed around several of the gas vents, and some vents have been reduced in size to prevent damage by golf balls.

Several areas where the vegetative cover on the cap was disturbed were noted in the monthly

progress reports. The reports for the following months noted these areas were subsequently re-seeded.

In May 2002, a fire destroyed the office trailer of the driving range and a new trailer was brought in to replace the previous trailer. The foundation was constructed in the same manner consistent with the foundation of the previous trailer, which did not impact the cap integrity.

The monitoring of OU-1 will continue at the current rate until November 2010. At that time, the potentially

responsible parties (PRP) are eligible to petition EPA for reduced monitoring.

There is no O&M program in place at this time for OU-2 because the remedial action has not started yet.

Table 2 below summarizes the annual systems operations/O&M costs for OU-1.

TABLE 2 ANNUAL SYSTEM OPERATIONS/O&M COSTS

Dates

From To Total Costs Rounded to the Nearest $1,000

1/1/2000 12/31/2000 $39,000.00

1/1/2001 12/31/2001 $37,000.00

1/1/2002 12/31/2002 $45,000.00

1/1/2003 12/31/2003 $43,000.00

1/1/2004 *12/31/2004 $43,000.00

* Estimated to end of current year

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V. PROGRESS SINCE LAST FIVE- YEAR REVIEW

Protectiveness Statements from Last Five-Year Review

The protectiveness statements from the May 2000 Five-Year Review read as follows:

"The components of the remedy which were constructed as part of the OU-l ROD remain protective of human health and the environment. However, since the Remedial investigation at OU-2 is ongoing, the remedy for the Site is not considered protective of human health and the environment at this time."

Status of Recommendations and Follow-up Actions from Last Five-Year Review

The recommendations from the last review are as follows:

"The remedy is in conformance with the ROD, however due to the uncertainty surrounding the well 7 and 8 grouping, a draw down pump test should be performed to make certain that the slurry wall does in fact remain protective in this portion of the Site [OU-l]. Since all permits are in place to discharge into the City of Baltimore public sewage system and the on-site PRP contractors will have the capability of performing the test during the remedial action. It is recommended the draw down test be performed shortly after the mobilization of the OU-2 Remedial Action.” “In addition, the minor items noted during the November 15, 1999 Site inspection should be corrected as follows:

Along the south side of the Site, the grass cover area near the large poles for the netting that encloses the driving range needs to be reseeded.

The pumping system used to dewater the pump vault on the north side of the Site [OU-1]

needs to be repaired to ensure that it removes the standing water which periodically collects in the vault.”

Follow-up actions from the last five-year review are as follows:

The drawdown pump test for wells 89-07 and 89-08 have not been completed because the mobilization of the

OU-2 remedial action has not occurred as of this time. MACTEC continues to reseed bare spots in the

vegetative cover, repair mechanical or electrical problems associated with the extraction wells and pre-

treatment system, monitor well levels, sample wells annually, and document the activities in monthly and

quarterly reports to EPA.

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Results of Implemented Actions

The vegetative cover continues to need reseeding. The repairs to both the gas vents, extraction wells

(including pumps), and the pretreatment system at OU-1 are performed during the monthly site inspections.

These actions prevent the protectiveness of the OU-1 remedy from being impacted.

Status of Any Other Prior Issues

The drawdown pump test, for wells 89-07 and 89-08, needs to be completed.

VI. FTVE-YEAR REVIEW PROCESS

Administrative Components

Members of the settling parties and Maryland Department of the Environment (MDE) were notified of the

initiation of the five-year review on July 2, 2004. The Kane and Lombard site five-year review team was

lead by Christopher Corbett, the EPA Remedial Project Manager (RPM) for the Kane and Lombard site.

Vance Evans, EPA Region III, acted as the community involvement coordinator for the Kane and Lombard

site. Kim LeMaster of the MDE represented the State of Maryland. Other parties participating in the review

were MACTEC representative Vincent Wroniewicz and Tetra Tech EM Inc. representatives Marian Murphy

and Michael Wilson, P.E.

Community Notification and Involvement

An announcement of the Five Year Review was placed was placed in the Baltimore Sun newspaper on

March 1, 2005. The public was invited to summit written comments about the ongoing cleanup. A point-of-

contact, phone number and Email address were also provided in the announcement. No written comments or

requests for additional information were submitted by the public or any elected officials.

Document Review

The five-year review consisted of review of relevant documents, including the RODs for OU-1 and OU-2,

the O&M records for OU-1, the previous five-year reviews, and the RI/FS for OU-1 and OU-2 (see

Attachment 2). Also reviewed were ARARs for groundwater cleanup as listed in the ROD for OU-2 (see

Attachment 3).

Data Review

16

The data in the OU-1 and OU-2 RI/ FS reports were reviewed as well as the data provided by MACTEC in

its monthly and quarterly progress reports. Both groundwater monitoring data and analytical results for

shallow groundwater sampling at OU-l were reviewed.

Eight sets of paired wells are located in the shallow aquifer surrounding the cap of OU-l. One well in each

pair is located inside the slurry wall and the other outside the slurry wall. Of the eight paired wells, five

located inside the cap have been dry since 1997. The extraction wells have not pumped any leachate from

inside the cap since 1997. The water level between all well pairings, except well pairs 89-07 and 89-08, have

had a greater than 1 foot difference from 1997 to the present. There should be at least a one-foot difference

between the water level elevations at each well pair to ensure the slurry wall is functioning properly.

The CD requires the PRP to monitor three sets of the paired wells on a yearly basis; however, all three of the

inside wells for these pairs have remained dry since 1997 and there are no data to compare the concentrations

of contaminants inside and outside the slurry wall for OU-1.

Site Inspection

The site inspection was performed on July 26, 2004, and supplemental inspections were performed on

September 20,2004 and April 6, 2005. Present at the July 26, 2004 inspection were Christopher Corbett, the

EPA RPM; Kim LeMaster of MDE; Marian Murphy of Tetra Tech EM Inc.; and Vincent Wroniewicz of

MACTEC. Present for the supplemental site visit on September 20,2004, were Marian Murphy and Michael

Wilson of Tetra Tech EM Inc. and Christian Hjembo, the MACTEC employee performing the monthly site

inspection. Christopher Corbett performed the second supplemental inspection on April 6, 2005. Attachment

5 provides a site inspection checklist.

Interviews

Interviews were not conducted due to the lack of public interest.

VII. TECHNICAL ASSESSMENT

Question A: Is the remedy functioning as intended by the decision documents?

The review of documents, ARARs, risk assumptions, and the results of the site inspection indicates that the

remedy is functioning as intended by the OU-1 ROD. The stabilization and capping of site soils in OU-1 has

met the ARARs and achieved the remedial objectives of minimizing the migration of contaminants to surface

17

water and shallow groundwater under OU-1, and prevented direct contact with or ingestion of contaminants

in OU-1 soil. Small areas with no vegetative cover were discovered during the site inspection at OU-1;

however, the soil has not eroded in these areas, and the areas are scheduled for reseeding in October and

November 2004. The fencing around OU-1 is intact, and personnel are present onsite 24 hours a day, 7 days

a week.

The remedy for OU-2 has not been started as of this time.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of

the remedy selection still valid?

No changes in the physical conditions of OU-1 that would affect the protectiveness of the remedy were

observed during the review.

Changes in Standards to Be Considered:

There are no changes in standards that need to be considered.

Changes in Exposure Pathways, Toxicity. and Other Contaminant Characteristics:

No changes in exposure pathways or contaminant characteristics have occurred since the last five-year

review.

Question C: Has any other information come to light that could call into question the protectiveness of the

remedy?

No ecological targets were identified at the site during the baseline risk assessment, and none were identified

during the current five-year review. No weather-related events have affected the protectiveness of the

remedy at OU-1.

Technical Assessment Summary

Based on the data reviewed, the site inspection, and the interviews, the remedy for OU-1 is functioning as

intended by the ROD. No changes in the physical conditions of OU-l that would affect the protectiveness of

the remedy were observed.

18

VIII. ISSUES

Table 3 below summarized the issues discovered during the current five-year review.

TABLE 3 ISSUES

Issue Currently Affects Protectiveness?

(Y/N)

Affects Future Protectiveness?

(Y/N)

The drawdown pump test for wells 89-07 and 89-08 has not been completed because the mobilization of the OU-2 remedial action has not occurred as of this time. Comparison of water level data in this well pair from the January 17, 2001, and September 20, 2004, site visits does not indicate any conclusive trend; therefore, no further conclusions can be made until the drawdown pump test is performed and the drawdown data examined along with water level data.

Y Y

IX. RECOMMENDATIONS AND FOLLOW-UP ACTIONS

Table 4 below presents the recommendations and follow-up actions for the site.

TABLE 4 RECOMMENDATIONS AND FOLLOW- UP ACTIONS

Affects Protectiveness?

(Y/N) Issue

Recommendations/ Follow-UP Actions

Party Responsible

Oversight Agency Milestone Current Future

Implement OU-2

Conduct activities described in the OU-2 ROD.

PRP EPA EPA to determine

Y Y

Integrity of slurry wall around OU-1

Complete drawdown pump tests for wells 89-07 and 89-08

PRP EPA EPA to determine

Y Y

19

X. PROTECTIVENESS STATEMENT

The components of the remedy constructed as part of the OU-1 record of decision (ROD) remain protective

of human health and the environment; however, because, the remedy for OU-2 is not complete, the overall

remedy for the site is not considered protective of human health and the environment at this time.

Long- term protectiveness of the remedial action at OU-2 will be verified when the remedy is in place and

sufficient data have been generated to ensure that groundwater cleanup goals are achieved.

XI. NEXT REVIEW

The next five-year review for the Kane and Lombard site is required five years from the date of this review.

20

ATTACHMENT 1

FIGURES

(Two Pages)

21

ATTACHMENT 2

LIST OF DOCUMENTS REVIEWED

(One Page)

22

LIST OF DOCUMENTS REVIEWED

Arcadis “Final Feasibility Study for Operable Unit 2, Kane and Lombard Site, Baltimore, Maryland,” July 12, 2002. Arcadis “Final Remedial Investigation Report for Operable Unit 2, Kane and Lombard, Baltimore,

Maryland,” July 25, 2002. Ecology and Environment, Inc. “Five-Year Review Report, Kane & Lombard Site, Baltimore, Maryland,

Operable Unit One,” April 13, 1994. Harding Lawson Associates “Final Work Plan, Remedial Investigation Feasibility Study, Kane and Lombard

Site, Operable Unit 2, Baltimore, Maryland,” March 1991. Harding Lawson Associates “Final Technological Memorandum, Phase H Baseline Ecological Assessment,

Baltimore, Maryland,” August 23, 1995. Harding Lawson Associates “Operations and Maintenance Plan for the Kane and Lombard Superfund Site,

Baltimore, Maryland,” November 11, 1995. MACTEC (formerly Harding Lawson and Associates) Various “Monthly Progress Reports, United States v.

Edward Azrael, et al. (No, WN-89-2898), Kane and Lombard Superfund Site, Operable Unit 1, Baltimore, Maryland,” November 1999 to April 2004.

U.S. Environmental Protection Agency (EPA) “Record of Decision, Kane and Lombard Superfund Site,

Operable Unit 1, Baltimore, Maryland,” September 30, 1987. EPA “Five-Year Review Report, Kane & Lombard Site, Baltimore, Maryland,” May 4, 2000. EPA “Record of Decision, Kane and Lombard Site, Operable Unit 2, Baltimore, Maryland,”

September 30, 2003. Roy F. Weston “Remedial Investigation Report for Kane and Lombard Site, Baltimore,

Maryland,” May 1987. Weston “Final Feasibility Report for the Kane and Lombard Site, Baltimore, Maryland,”

November 11, 1987.

23

ATTACHMENT 3

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

(Eight Pages)

ATTACHMENT 3

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

Media ARAR Status Authority Requirement Synopsis

Soil groundwater, air

EPA Region III “Risked-Based Concentrations (RBC) Tables”

To Be Considered

Federal Advisory

Provides chemical-specific concentrations corresponding to fixed levels of risk (i.e., a hazard quotient or a lifetime cancer risk of 1 x 10-6, whichever occurs at a lower concentration) in water, air, and soil

Soil EPA “Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities” (OSWER Directives 9355.4-12 and 9200.4-27)

To Be Considered

Federal Guidance

Establishes screening levels for lead in soil

Soil “Clarification of USEPA Revised Interim Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities” (OSWER Directive 9355.2)

To Be Considered

Federal Guidance

Establishes cleanup levels for lead in soil

Soil EPA Region III biological technical assessment group (BTAG) screening levels

To Be Considered

Federal Guidance

Region III ecologically based screening levels for remediation sites

ATTACHMENT 3

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (Continued)


Groundwater Federal - SDWA - maximum contaminant levels (MCLs) (40 CFR, Parts 141.11-141.16 and 141.50-141.63) and nonzero maximum contaminant level goals (MCLGs) Relevant

Relevant and Appropriate

Federal Regulatory Requirement

Standard MCLs have been adopted as enforceable standards for public drinking water systems; MCLGs are non-enforceable levels for such systems

Groundwater EPA Office of Drinking Water and Health Advisories (HAs)

To Be Considered

Federal Advisory

Health advisories are developed from estimated risk from consumption of contaminated drinking water, considering non-carcinogenic effects only; health advisories are considered for contaminants in groundwater that may be used for drinking water

Groundwater RCRA - Groundwater Monitoring (40 CFR 265.91)



Requirements of a groundwater monitoring system

Air Clean Air Act (C AA) National Emission Standards for Hazardous Air Pollutants (40 CFR 61)



Sets emission standards for designated hazardous pollutants

Air CAA-National Ambient Air Quality Standards (40 CFR 50)



Federal agencies required to determine if site is located in a non- attainment zone for ozone; sites within non- attainment areas must consider ozone attainment status in designing remediation systems

ATTACHMENT 3



Air CAA (40 CFR 50,60, and 61) Relevant and Appropriate


Engineering controls required to reduce fugitive dust emissions during remedial activities, including continuous application of dust suppressants before, during, and after excavation

Groundwater National Secondary Drinking Water Standards (40 CFR 143)

To Be Considered

Federal Advisory

Welfare-based standards established to protect aesthetic quality of public water supplies (secondary MCLs)

Air Air OSWER Directive 9355.0-28 To Be Considered


Applies to control of air emissions from air strippers at Superfund sites; generally considered suitable for other vented extraction techniques, including soil vapor extraction

Air 40 CFR 264 Subpart AA Applicable Federal Regulatory Requirement

Provides air emission standards for process vents associated with hazardous waste treatment

Air 40 CFR 264 Subpart BB Relevant and Appropriate


This regulation sets air emissions standards for equipment leaks associated with hazardous waste treatment equipment

Air National Primary and Secondary Ambient Air Quality Standards (40 CFR 50)



Lists appropriate engineering controls required to reduce emissions associated with excavation and transportation

Surface Water Clean Water Act (33 USC 1314), EPA Office of Water, Federal Ambient Water Quality Criteria

To Be Considered

Federal Criteria, Advisories, and Guidances

Criteria for protection of freshwater and marine aquatic life been developed for 95 carcinogenic and non-carcinogenic compounds; standards also would apply to any storm water or applied water that flows from a regulated unit of the land surface

ATTACHMENT 3



Groundwater Maryland Water Pollution Control Regulations, Groundwater Quality Standards (COMAR 26.04.01)


State Regulatory Requirement

Set concentration limits for hazardous constituents in groundwater and general requirements for solid waste management units

Groundwater Maryland Drinking Water Standards (COMAR 26.04.01)



Maryland has adopted Federal MCLs

Air Maryland State Adopted National Ambient Air Quality Standards and Guidelines (COMAR 26.11.04)



Sets primary standard for particulate matter at 50 ug/m3 for the annual arithmetic mean and 150 ug/m3 for the 24- hour average, with an expected exceedance equal to or less than once per year

Air Maryland State Air Pollution Episode System (COMAR 26.11.05)



Establishes air pollution episode criteria for pollutant levels of particulate matter, that if allowed to accumulate in any area of the state, would threaten public health

Air Maryland State General Emissions Standards (COMAR 26.11.06)



Sets general emission standards, prohibitions, and restrictions on visible emissions, particulate matter, volatile organic compounds, nuisances, and odors

Air Maryland Toxic Air Pollution Rules (COMAR 26.11.15)



Establishes standards for ambient air quality to protect public health and welfare; also establishes special screening levels (SSLs) and acceptable ambient levels (AALs) for Class I and Class II toxics; SSL and AAL criteria used to evaluate ambient air quality impacts of a single premises

ATTACHMENT 3



Surface Water Maryland Water Pollution Control Regulations, Toxic Substances Water Quality Criteria for Surface Waters (COMAR 26.08.02)



State of Maryland has promulgated surface water quality standards and use classifications for surface Waters; these standards may also be considered for contaminants in groundwater that discharges to surface water; standards also apply to any storm water or applied water that flows from a regulated unit to the land surface

Non-media specific

RCRA-Land Disposal Restrictions (LDR) (40 CFR 268.43)



Establishes restrictions for burial of wastes and hazardous materials; listed and characteristic hazardous waste required to meet best demonstrated available technology (BDAT) treatment standards

Non-media specific

RCRA-Identification and Listing of Hazardous Waste (CFR 40261)

Applicable Federal Regulatory Requirement

Provides guidance for classifying wastes as hazardous under RCRA

Non-media specific

National Pretreatment Standards (40 CFR 403)



Sets standards to control pollutants that pass through or interfere with the treatment process in publicly owned treatment works or that may contaminate sewage sludge

Non-media specific

National Pollutant Discharge Elimination System (40 CFR 122-125)



Permitting required for pollutant discharge from any point source into U.S. waters

Non-media specific

Occupational Safety and Health Administration (29 CFR 1910)


Specify the 8-hour, time-weighted average concentration a worker can be exposed to for various organic compounds and training requirements for these workers

ATTACHMENT 3



Non-media specific

Occupational Safety and Health Administration (29 CFR 1926)


Specify the type of safety equipment and procedures to be followed during site remediation; safety measures, such as personal protective equipment, required to protect workers engaged in on- site work during implementation of remedial actions

Non-media specific

U.S. Department of Transportation Rules for Transportation of Hazardous Materials (49 CFR 107,171.1-172.558)


Provides requirements for transportation of hazardous waste

Non-media specific

Underground Injection Control (40 CFR 144)


Provides requirements for underground injection control

Non-media specific

U.S. Army Corps of Engineers Nationwide Permit Program

To Be Considered


Prohibits any activity that adversely affects a wetland if a practicable alternative is available that has less effect

Non-media specific

Executive Order 11990: Protection of Wetlands (40 CFR 6, Appendix A)

To Be Considered


Federal agencies required to minimize the destruction, loss, or degradation of wetlands and to preserve and enhance the natural and beneficial values of wetlands

Non-media specific

Maryland Air Quality Standards (COMAR 26.11)



Outlines restrictions and requirements for construction and remedial activities that emit matter into the ambient air; restrictions for air emissions from treatment technologies and nuisance and odor control required

ATTACHMENT 3



Non-media specific

Maryland Disposal of Controlled and Hazardous Substances (COMAR26.13)



Establishes hazardous waste identification, manifesting, transport, record keeping, and reporting requirements and outlines LDRs

Non-media specific

Maryland Storm Water Management Regulations (COMAR 26.17.02)



Establishes design criteria for storm water control from construction activities, such as maintained pre-development runoff characteristics and reduction of stream channel erosion, sedimentation, and pollution

Non-media specific

Maryland Erosion and Sediment Control Regulations (COMAR 26.17.01)



Erosion and sediment control plan must be approved by the Maryland Department of the Environment for a disturbed area greater than 5,000 square feet or 100 cubic yards

Non-media specific

Underground Injection Control (COMAR 26.08.07.01)

To Be Considered


Provides requirements for underground injection control.

Non-media specific

Maryland Water Pollution Control Regulations, Storm Water Control Systems (COMAR 26.08.04)



Discharges of treated groundwater must meet state treatment requirements, and permit required to construct injection wells

Non-media specific

Maryland Occupational, Industrial, and Residential Hazards (COMAR 26.02)



Provides limits on maximum allowable levels of noise at site boundaries during remediation work to protect the health, general welfare, and property of the people of the State

ATTACHMENT 3



Non-media specific

Well Construction (COMAR 26.04.04)



Provides specifications for monitoring well construction and abandonment

Non-media specific

Board of Well Drillers (COMAR 26.05.01)



Provides licensing requirements for persons drilling, installing, and abandoning wells in the State

Non-media specific

Waterworks and Waste System Operators (COMAR 26.06.01)



Provides certification requirements for persons operating a treatment facility for contaminated surface water and groundwater

Non-media specific

Maryland Water Appropriation and Use (COMAR 26. 17.06)



Addresses the conservation and protection of water resources of the State

Non-media specific

Maryland Wetlands Regulation (COMAR 26.23 and COMAR 26: 24)

To Be Considered


Outlines authorized uses of and prohibited activities in non-tidal and tidal wetlands

Non-media specific

Chesapeake Bay Commission (Annotated Code of Maryland, Natural Resources Article, Title 9.302)

To Be Considered


Outlines bay-wide policy for the protection of tidal and non-tidal wetlands

ATTACHMENT 4

PHOTOGRAPHIC DOCUMENTATION LOG (Eight Pages)

five-year review report for kane and lombard site ... · last five-year review, the five-year...

Documents