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UNFTED STATES ENVIRONMENTAL PROTECTION AGENCYREGION III

841 Chestnut BuildingPhiladelphia, Pennsylvania 19107

SUBJECT: Five-year Review of the DATEKane and Lombard Superfund Site

FROM: Abraham Ferdas, Associate Divisionfor Superfund Programs

TO: Thomas C. Voltaggio, DirectorHazardous Waste Management Division

EPA has completed a statutory five-year review of the OperableUnit One (OU1) source control remedy at the Kane and LombardSuperfund site in Baltimore, Maryland. The OU1 remedy consistsof the following components: a soil-bentonite slurry wall andmultilayer RCRA cap; a ground water extraction system; a groundwater monitoring system; and institutional controls. This five-year review of the OU1 remedy included: a review of the ROD, thesite Maintenance and Management Manual, and maintenance andmonitoring reports; site inspections; and limited data gathering.

The major conclusions and recommendations presented in theattached Five-year Review Report are as follows: (1) the remedyremains effective in protecting human health and the environment;(2) the cap and slurry wall are functioning as designed; however,minor restoration of the topsoil and vegetative layers of the capis necessary in order to ensure that the containment system willremain intact; (3) the ground water extraction system hassubstantially dewatered the first water-bearing zone within theslurry wall boundaries; however, continued monitoring of thedewatering process is required to ensure that an inward hydraulicgradient will be timely established and maintained across theslurry wall; (4) institutional controls are in place; however,regular maintenance of the perimeter fence is required in orderto ensure that the controls remain effective; and (5) becausehazardous substances, remain at the site above levels that allowfor unlimited use and unrestricted exposure, another five-yearreview must be completed no later than April 30, 1999.

I recommend that you sign the attached Five-year Review Report.

FIVE-YEAR REVIEW REPORT

KANE AND LOMBARD SITE, OPERABLE UNIT ONE

BALTIMORE, MARYLAND

Prepared by:

Ecology and Environment, Inc.Contract No. 68-W8-0085

Work Assignment No. 85-33-3RB2

September 1993

For:

U. S. ENVIRONMENTAL PROTECTION AGENCYRegion III

Philadelphia, PA 19107

Revised by:

U. S. ENVIRONMENTAL PROTECTION AGENCYRegion III

April 1994

Thomas C. VoltHazardous Wast

Date^Division

S R 3 0 I 5 6 9

TABLE OF CONTENTS

Section Page

1 INTRODUCTION ....................................... 1

2 SITE BACKGROUND .................................... 3

3 REMEDIAL ACTION CONFORMANCE WITH THE ROD ........... 8

4 SITE VISIT AND EVALUATION OF REMEDY EFFECTIVENESS... 14

5 CONCLUSIONS AND RECOMMENDATIONS .................... 33

Appendices

A PHOTODOCUMENTATION

B GROUND WATER MONITORING WELL ELEVATION GRAPHS

C DISCHARGE PERMIT

D SUMMARY OF CONTAMINANTS FOUND AT THE KANE AND LOMBARD SITE

AR3UI570

LIST OF TABLES

Table Paae

4-1 Organic Vapor Analyzer Readings at Gas Ventsand Breathing Zone ................................... 17

4-2 Screened Interval in Ground WaterMonitoring Wells ..................................... 20

4-3 Static Water Level in Ground Water Monitoring WellsLocated at the Kane and Lombard Superfund Site ....... 21

4-4 Calculated Head Difference acrossSections of the Slurry Wall .......................... 22

4-5 Reduction in Ground Water Elevations betweenAugust of 1990 and July of 1993 ...................... 27

4-6 Extraction Well Effluent Flow Rate ................... 29

LIST OF FIGURES

Figure Page

3-1 Final Conditions Plan ................................ 10

4-1 Cross Section Showing Hydraulic Gradientacross the Slurry Wall ............................... 24

4-2 Cross Section Showing Hydraulic Gradientacross the Slurry Wall ............................... 25

HR3UI57

1.0 INTRODUCTION

PURPOSE

Under contract to the Environmental Protection Agency (EPA),

Ecology and Environment, Inc., (E & E) performed a five-year

review of Operable Unit One (OU1) at the Kane and Lombard site

located in Baltimore, Maryland (EPA ID No. MDD980923783). The

purpose of the five-year review was to evaluate whether the

response action remains protective of public health and the

environment.

SCOPE

The focus of this review is limited to OU1 at the Kane and

Lombard site. The objective of OU1 is threefold:

o To isolate and contain the wastes and contaminatedmedia of the upper water-bearing zone;

o To prevent clean water from entering the site via localground water recharge to the shallow saturated zone orinfiltration of precipitation into the subsurface; and

o To prevent the off-site migration of contaminants viathe flow of ground water from the on-site wastedisposal area.

BR3UI572

REVIEW COMPONENTS

The components of this review are as follows:

o A site history describing the events leading toimplementation of the remedial action and a briefoverview of the remedy;

o A summary of observations made during site visitsconducted on July 27, 1993, September 8, 1993, andMarch 8, 1994;

o An evaluation of the as-built OU1 remedy in order todetermine whether it continues to be effective inprotecting human health and the environment; and

o Conclusions and recommendations.

AR3UI573

2.0 SITE BACKGROUND

SITE DESCRIPTION

The Kane and Lombard site consists of approximately 10 acres

of land located in the Orangeville Subdivision of Baltimore,

Maryland. The site is southwest of the intersection of Kane

Street and Lombard Street, and is directly adjacent to Patterson

High School and public recreational facilities. Other nearby

properties are used for industrial and commercial purposes.

The site and the surrounding area are underlain by three

successive water-bearing zones. The first water-bearing zone has

been characterized as a Class III A aquifer since its extent is

not sufficient to provide adequate yield for domestic water

supplies. The underlying second and third water-bearing zones

have been characterized as Class II B and Class II A aquifers,

respectively.

The first water-bearing zone consists of fill material and

sandy silt and silty clay which is encountered between 10 and 40

feet below grade. A 25- to 80-foot-thick clay layer separates

the first and second water-bearing zones. The second water-

bearing zone consists of sandy silt and silty sand encountered

between 50 and 120 feet below grade. A layer of clay

approximately 20 feet thick separates the second and third water-

bearing zones. The third water-bearing zone consists of sand and

silty sand encountered at depths of 120 to 140 feet below grade.

The direction of ground water flow in the upper two zones

appears to be toward the northeast. The direction of ground

water flow in the third water-bearing zone is toward the

southeast. Seven domestic wells lie within a two-mile radius of

the site. Each of the seven domestic wells is located more than

one mile from the site. The City of Baltimore supplies drinking

water to the other area residents.

SITE HISTORY

The Kane and Lombard site is a portion of a former mixed

waste disposal area where dumping and burning took place from

approximately 1962 until 1984. Between 1962 and 1971, portions

of the site and adjacent properties were excavated and used for

solid and hazardous waste disposal. Between 1971 and 1984,

construction debris, household wastes, industrial wastes, and

hazardous materials were disposed of on the surface of the site.

Site conditions were brought to the attention of State of

Maryland officials in November of 1980, when stored drums were

observed on the Kane and Lombard site. In 1984, an EPA removal

action provided site security, removal and off-site disposal of

surface wastes (including 1,163 drums), and site stabilization

through regrading, capping, and revegetation. Ground water

sampling conducted by the State of Maryland, and subsequent

ground water and soil sampling conducted by EPA during and after

the removal action, demonstrated the presence of organic and

SR30I575

inorganic contaminants in both media. In particular, vinyl

chloride, trichloroethylene, benzene, chlorobenzene,

trans-1,2-dichloroethylene, dichlorobenzene, bis(2-ethylhexyl)-

phthalate, and other organic compounds were detected in ground

water; heavy metals, including cadmium, lead, selenium,

beryllium, mercury, chromium, and zinc were detected in site

soils.

Analytical data gathered by EPA and the State of Maryland in

1984 indicated the potential for off-site migration of

contaminants in ground water, and for direct contact with

hazardous substances in site soils. In addition, historical

aerial photographs suggested that hazardous materials remained

buried on-site. These factors triggered the addition of the site

to the National Priorities List (NPL) in October 1984.

Remedial activities were divided into two operable units.

The Remedial Investigation/Feasibility Study (RI/FS) for the

first operable unit (OU1) was conducted between October 1985 and

November 1987. Data collected during the OU1 RI verified

contamination of on-site soils, and on-site and off-site ground

water in the first and second water-bearing zones. Indicator

chemicals detected during the RI, and forming the basis of the

risk assessment, included bis(2-ethylhexyl)phthalate,

carcinogenic polynuclear aromatics (PNAs), polychlorinated

biphenyls (PCBs), toluene, and lead in soils; and benzene,

trans-1,2-dichloroethylene, trichloroethylene, vinyl chloride,

beryllium, cadmium, and nickel in ground water. The OU1 risk

3R30I576

assessment demonstrated that the site presented an

level of risk to human health and the environment.

EPA issued a Record of Decision (ROD) for OU1 in September

of 1987. In accordance with the ROD, further remedial action was

taken at the site to control releases of contaminants to ground

water and to eliminate the risk associated with direct contact

with contaminated soils.

The OU1 remedial action provided containment of the source

area and dewatering of the shallow saturated zone. The Operable

Unit Two (OU2) RI will address ground water contamination from an

area consisting of the Kane and Lombard site and additional land

immediately north of the site.

Specific remedial action tasks for OU1 included the

following:

o Clearing, grubbing, and preliminary grading in supportof the tasks listed below;

o Installation of a soil-bentonite slurry wall around theperimeter of the on-site waste disposal area in orderto prevent future off-site migration of contaminantsvia ground water transport;

o Installation of an impermeable cap (which meetsResource Conservation and Recovery Act [RCRA] SubtitleC specifications) over the on-site waste disposal areato prevent recharge of site ground water and to isolatewaste materials from potential human contact;

o Installation of two extraction wells in order todewater the portion of the first water-bearing zonelocated within the slurry wall boundaries

o Discharge of extracted ground water to the City ofBaltimore's Back River Wastewater Treatment Plant(WWTP);

o Installation of a gas venting system to collect andvent any gases generated below the impervious cap;

flR30!577

Installation of a ground water monitoring system ta3/assess the long-term effectiveness of the remedialaction;

Final grading of the site, including provisions forsurface water management and erosion control; and

Installation of a fence to limit site access.

The remedial design was initiated in February of 1988 and

completed in April of 1989. In September of 1989, the State

Superfund Contract was finalized between EPA and the Maryland

Department of the Environment. Fund-lead remedial action began

in February of 1990. EPA accepted construction of the OU1

remedial action as substantially complete in August of 1990.

flR30!578

3.0 REMEDIAL ACTION CONFORHANCE WITH THE ROD

The OU1 remedial action consists of four basic elements:

o Containment of wastes and contaminated soil and groundwater in the first water-bearing zone;

o Dewatering of the first water-bearing zone;

o Discharge of contaminated ground water extracted fromthe first water-bearing zone to the Baltimore City BackRiver WWTP; and

o Restriction of site access and use.

The as-built remedy conforms with the requirements of the

ROD. The actions completed to meet these requirements are

described in the following sections.

3.1 CONTAINMENT

The following activities were completed in order to contain

the wastes and contaminated media at the site:

o A 3- to 5-foot-wide soil-bentonite slurry wall with amaximum permeability of 10~7 centimeters per second(cm/sec) was installed around the perimeter of the on-site waste disposal area.

o The bottom of the slurry wall was keyed a minimum of 5feet into the 25- to 80-foot-thick clay stratum thatunderlies the first water-bearing zone, as documentedin EA Engineering, Science, and Technology, Inc.'s as-built slurry wall profile drawings (April 1991). Thevertical hydraulic conductivity of the underlying claylayer typically ranges from 1CT7 to 10~8 cm/sec, asdocumented in the OU1 RI Report (1987).

flR3GI579

A RCRA Subtitle C landfill cap was installed over theslurry wall and the area enclosed by the slurry wall.The cap, from the bottom up, consists of a gascollection layer, a compacted clay layer with a minimumdepth of 2 feet and a maximum permeability of 10~7cm/sec, a flexible membrane liner, a geosyntheticdrainage net, geotextile, a minimum of 2 feet of coversoil and topsoil, and a vegetative layer. Storm watercontrol structures are also included in the cap.

Twenty-one ground water monitoring wells were installedon-site. Sixteen of these wells are located in pairedclusters that bracket the slurry wall on each of itsfour sides. Two additional wells are screened in thefirst water-bearing zone within the boundaries of theslurry wall. One well is screened in the first water-bearing zone at a background location just south of theslurry wall containment structure. Two wells arescreened in the second water-bearing zone just north ofthe slurry wall containment structure. The purpose ofthe monitoring well network is to: (1) monitor theperformance of the slurry wall; (2) monitor theeffectiveness of the multilayer cap in preventing theinfiltration of surface water and precipitation intothe on-site waste disposal area; and (3) monitor theprogress of the dewatering of the first water-bearingzone.

3.2 DEWATERING OF THE FIRST WATER-BEARING ZONE

The dewatering system consists of the following elements:

o Two ground water extraction wells are screened in thefirst water-bearing zone within the slurry wall (seeFigure 3-1). Extraction well no. 1 (EW-1) is locatedin the northeast corner of the site and has a totaldepth of 35.6 feet. Extraction well no. 2 (EW-2) islocated in the north west corner of the site and has atotal depth of 29.4 feet. Both wells are constructedof 8-inch diameter, schedule 5 stainless steel with awall thickness of 0.24 inch.

o Each extraction well is equipped with a stainless steelsubmersible 1/3 horsepower pump with a flow range of 5to 14 gallons per minute (gpm). The operation of eachpump is automatically controlled by two water levelprobes that switch the pump on or off. The extractionwell discharge piping consists of 1.25-inch flexiblepolyethylene inside the well housing, and 1.25-inch

(5R30I580

—— to auktiucuM («-o' . j -«-I j 1C CUUIUI

~* __4——S-MMiu '

FINAL CONDITIONS PLAN FIGURE 3-1

schedule 80 PVC piping which leads from the extractionwell to the meter vault.

A concrete meter vault houses a 1.25-inch PVC forcemain pipe, a 2-inch force main pipe, two 1.25-inch PVCball valves, one 1.25-inch PVC back-pressure valve, two1.25-inch globe valves, two 1.25-inch ball checkvalves, two 1.25-inch pressure gauges, one 1.25-inchpaddlewheel flow sensor, and one 2-inch ball valve.

A collection manhole, which accepts the flow from themeter vault and directs it to the Baltimore Citysanitary sewer system, allows effluent samples to beobtained for analysis.

The metering of the discharge is accomplished by a flowsensor which is located in the meter vault and a flowtotalizer which is located in the incoming electricalservices and metering cabinet.1

3.3 DISPOSAL OF EXTRACTED GROUND WATER

Extracted ground water that meets the discharge standards

established pursuant to Section 27d of Article 25 of the

Baltimore City Code, as amended by Ordinance 129 of 1984, may be

discharged through the Baltimore City sanitary sewer system to

the Back River WWTP. A copy of the wastewater discharge permit

held by EPA between August of 1991 and August of 1992 is

contained in Appendix C. The permit requires sampling and

analysis of the extraction well effluent in order to demonstrate

1 A strip chart recorder, designed to provide a continuousrecord of the rate of effluent flow through the metering vault, islocated in the incoming electrical services and metering cabinet,adjacent to the flow totalizer. Because the actual rate ofeffluent flow is substantially lower than the flow rate anticipatedduring the design phase, the strip chart recorder has not provenuseful in measuring and recording flow rates. However, an averagedaily effluent flow rate can be determined by dividing thedifference in two readings obtained from the flow totalizer by thenumber of days that elapsed between the readings.

11

compliance with the discharge limits. A sample collected from

EW-2 in July of 1990 was found to contain chlorobenzene at a

concentration that exceeded the discharge limit (2.13 milligrams

per liter [mg/L]) for total toxic organics (TTO). Based on this

finding, continuous discharge of effluent from the site to the

Back River WWTP was not permitted until March of 1991, when the

City of Baltimore Department of Public Works granted interim

approval for the temporary discharge of the effluent from EW-l.

In August of 1991, the City issued a permit to EPA for continuous

discharge of the EW-l effluent. The City modified the discharge

permit in August of 1992, to allow continuous discharge of the

combined effluent from EW-l and EW-2. In November of 1992, after

chlorobenzene was detected in ground water samples from both

extraction wells at levels up to 4.7 mg/L, the City imposed a

temporary suspension of permit privileges.

In August of 1993, EPA installed an effluent pretreatment

system consisting of two air sparging tanks and a vapor phase

carbon adsorption unit at the site. The system is designed to

reduce the concentration of chlorobenzene in the effluent to a

level that is acceptable for discharge to the Back River WWTP.

The City of Baltimore Department of Public Works granted interim

approval for the temporary discharge of effluent from both EW-l

and EW-2 to the Back River WWTP, in order to allow samples of the

treated effluent to be collected and analyzed. Since the

pretreatment system was installed, however, the volume and rate

of discharge of the extraction well effluent has not been

12

SR30I583

sufficient to allow the system to be evaluated under the design

conditions.2

3.4 SITE ACCESS AND USE RESTRICTIONS

A perimeter security fence equipped with two locking gates

controls access to the site. In addition, EPA issued an

Administrative Order to the site owners in October of 1992. The

Order restricts uses of the site that would interfere with the

operation or disturb the integrity of the OU1 remedy and ensures

access for EPA, the State of Maryland, and their authorized

representatives. A copy of the Order was recorded with the Land

Record Office of Baltimore City on November 10, 1992.

2 The rate of effluent discharge has substantially decreasedsince the effluent pretreatment system was installed, and thevolume of ground water discharged from the extraction wells has notbeen sufficient to fill the air sparging tanks. As a result,effluent has remained in the air sparging tanks for a period oftime which exceeds the designed holding time, and it has not beenpossible to verify the effectiveness of the pretreatment system inremoving chlorobenzene from the effluent under the designconditions. Once the volume of effluent in the air sparging tanksis sufficient to overflow the tanks, samples will be collected andanalyzed in order to confirm the effectiveness of the system giventhe current rate of discharge.

13

4.0 SITE VISIT AND EVALUATION OF REMEDY EFFECTIVENESS

4.1 SITE VISIT

EPA's contractor, E & E conducted a site visit on July 27,

1993. The purpose of the site visit was to: (1) assess the

current site conditions; (2) obtain ground water level

measurements at the monitoring wells; and (3) collect organic

vapor analyzer (OVA) readings at the gas vents.

E & E conducted a second site visit on September 8, 1993, in

order to observe and document the operation of an effluent

pretreatment system that had been installed at the site in August

of 1993. Observations made during each of the site visits are

presented below.

During the first site visit, the following observations were

made:

o The gravel access road that leads from Lombard Streetto the on-site maintenance parking area containeddepressed areas lacking rip-rap stone. Grass and weedswere growing through areas of the stone.

o The concrete decontamination (decon) pad and curbscontained cracks. A part of the decon pad curb wassheared off.

o The meter vault contained approximately 1 to 2 inchesof water. This water appeared to be rain water whichmay have entered the vault through the vault hatch.There was no evidence of a leak in any of the pipes,valves, gauges, etc., located in the meter vault.

o The manhole containing the interceptor pipe to theBaltimore City sanitary sewer system and the outletsfrom the extraction wells and the decon pad was dry.

14

o The incoming electrical services and metering cabinetwhich houses the main circuit breakers, flow totalizer,strip chart recorder, and keys to the meter vault andcollection manhole, is equipped with a lock. The stripchart recorder was not operating.3

o The drainage ditch on the eastern side of the siteshowed some signs of deterioration. The upper slope ofthe eastern bank of the drainage ditch contained barrenareas marked by some erosion over a 50- to 60-footstretch.

o Several hundred drums of drill cuttings, welldevelopment water, and used personal protectiveequipment (OU2 RI/FS investigation-derived waste) werestaged south of the capped waste disposal area, nearthe southern boundary of the site.

o The perimeter fence had several deficiencies, includinggaps of up to 4 or 5 inches between the bottom of thefence and the ground, hardware that had fallen apart,and approximately 15 locations where the fence fabricwas not connected to the posts.

o Sparse or barren areas occurred over limited sectionsof the vegetative cover.

During the second site visit, the following observations

were made:

o A pretreatment system, consisting of two air spargingtanks and a vapor phase carbon adsorption canister, hadbeen installed in the meter vault. The extractionwells and pretreatment system were operating uponarrival at the site. During the visit, the groundwater extraction system was taken off-line becauseambient dust had created fouling problems in the aircompressor that serves the air sparging tanks. Atpresent, there is no convenient means of access to thecarbon canister. An additional hatch is to beinstalled in the meter vault to ensure accessibilityfor maintenance.

3 The City of Baltimore Department of Public Works no longerrequires operation of the strip chart recorder.

15

«R30I58U

o All drums of investigation-derived waste noted duringthe initial site visit had been removed and the stagingarea (located at a site entrance gate in the southeastcorner of the perimeter fence) had been reseeded.

Photographs further documenting the current condition at the

site are attached as Appendix A.

Prior to entering the site during the first visit, the OVA

was calibrated and a background reading was taken approximately

50 feet east of the site entrance gate next to the ball park.

The OVA measured a background reading of 0.4 ppm. Background

organic vapor levels were also measured at the site entrance

gate. Organic vapor concentrations measured at the gas vents are

presented in Table 4-1.

High OVA readings obtained at the gas vents are not

consistent with the comparatively low levels of volatile organic

compounds detected in the ground water of the first water-bearing

zone. In addition, organic vapors were not detected above

background levels at the on-site monitoring wells, with the

exception of monitoring well 89-02. The OVA reading at

monitoring well 89-02 returned to the background level reading

after the well was ventilated for several minutes. These

observations suggest that the water table is not the source of

the organic vapors that were detected at the gas vents. The OVA

readings obtained at the gas vents may indicate that methane gas

is being generated from the on-site wastes.

On March 8, 1994, EPA and the Maryland Department of the

Environment conducted an additional site visit. The following

16

Table 4-1

ORGANIC VAPOR ANALYZER READINGS AT GAS VENTS AND BREATHING ZONEDURING JULY 27, 1993 SITE VISIT

Concentration Above Backaroundfppml

Gas Vent Number Vent Outlet Breathing Zone

VI >1,000 0V2 >1,000 0V3 90 0V4 70 0V5 >1,000 0V6 60 0V7 400 0V8 28 0V 9 8 0V10 4 0VII 700 0V12 500 0

17

&R3UI586

conditions were observed which had not been noted during the two

site visits conducted in 1993:

o The air compressor component of the effluentpretreatment system was housed in an aluminumenclosure, and was operating. Operation of thecompressor is controlled by a timer.

o Sections of fence along the southern and westernboundary of the site had been cut with shears. Theresulting openings in the fence are sufficiently largeto allow persons to enter the site.

o Field mouse burrows originated at the base of, andextended beneath the concrete pads which support theextraction well pump control cabinets.

o An erosion gully extends along a portion of thesouthern boundary of the site and has created a gap ofapproximately 12 inches between the ground and thebottom of the gate in the southeastern corner of thesecurity fence.

4.2 EVALUATION OF SOURCE CONTROL MEASURES

4.2.1 Containment Structures

The overall containment system has been installed in

conformance with the requirements of the ROD and, despite a lack

of regular maintenance, appears to be in good condition.

RCRA Cap

Maintenance of the RCRA multilayer cap has not been

regularly performed. However, observed deficiencies were limited

to the vegetative and topsoil layers and have not affected the

cover soil, the lateral drainage layer, the flexible membrane

liner, or any of the underlying layers of the cap. The cap

continues to be effective in preventing infiltration of surface

water and precipitation into the on-site waste disposal area.

18

JUI587

Soil-bentonite Slurry Wall

The soil-bentonite slurry wall is a subsurface lateral

containment system that circumscribes the on-site waste disposal

area. Eight pairs of monitoring wells are screened in the first

water-bearing zone along the slurry wall. One well in each pair

is located immediately inside the slurry wall and the other well

is located immediately outside the slurry wall. The monitoring

wells in each well pair are screened at the same depth interval

with respect to mean sea level (Table 4-2).

The effectiveness of the slurry wall is evaluated based on

the difference in ground water elevations between the wells in

each well pair. As long as the hydraulic gradient across the

slurry wall exceeds the natural gradient, it may be assumed that

the slurry wall is intact. Historical data for the site suggests

that the natural ground water gradient of the potentiometric

surface in the shallow aquifer is 0.05. Individual wells in the

well pairs that bracket the slurry wall are generally separated

by 20 feet. Therefore, a head difference significantly greater

than one foot between the wells in each cluster is an indication

that the slurry wall is functioning normally.

Ground water elevations obtained from the site monitoring

wells from August of 1990 through July of 1993 are presented in

Table 4-3. The calculated head differences across the slurry

wall are presented in Table 4-4. As shown in the table, the head

difference across the slurry wall exceeded one foot at most of

the measurement points during each of the monitoring events.

19

flR30!588

Table 4-2

SCREENED INTERVAL IN GROUND WATER MONITORING WELLS

Monitoring Well Number Screened Interval (ft. MSL4)

89-02 57.2 - 43.789-03 57.5 - 41.5

89-04 61.1 - 47.689-06 62.6 - 49.1

89-07 67.3 - 49.389-08 65.2 - 47.2

89-09 76.8 - 70.889-10 76.3 - 69.8

89-11 72.7 - 67.789-12 71.8 - 66.8

89-13 65.4 - 60.489-14 62.8 - 57.8

89-15 61.0 - 56.089-16 59.9 - 54.9

89-17 56.0 - 39.089-18 53.8 - 37.3

4Well construction data provided by the OU1 constructioncontractor was amended based on survey data collected by theState's contractor, Dynamac Corporation, in 1991 for the OU2 RI/FS.

20

HR30I589

Table 4-3

STATIC WATER LEVEL (ft MSL) FOR GROUND WATER MONITORING WELLSLOCATED AT THE KANE AND LOMBARD SUPERFUND SITE

Water Levels5

Well No.

89-01

89-02

89-03

89-04

89-05

89-06

89-07

89-08

89-09

89-10

89-11

89-12

89-13

89-14

89-15

89-16

89-17

89-18

89-19

89-20

89-21

August 1990

5.98

49.48

54.39

53.47

8.25

54.50

61.65

58.01

71.85

73.68

70.35

76.27

68.18

72.77

63.98

57.28

53.77

42.39

Dry

58.34

78.46

11-27-90

5.99

49.16

54.72

52.89

8.09

53.37

61.18

57.95

71.11

72.90

69.95

75.00

66.73

71.17

60.45

55.43

53.94

40.63

Dry

58.23

78.30

2-27-91

6.16

48.37

54.49

52.30

8.42

54.59

60.42

57.95

70.91

74.38

68.74

78.21

66.37

72.32

58.74

55.73

53.55

40.76

Dry

57.81

83.03

5-30-91

6.55

49.69

51.05

52.10

8.61

53.11

60.00

58.01

70.85

73.59

68.34

77.92

67.19

73.24

58.58

55.79

49.87

39.38

Dry

57.38

79.62

11-21-91

5.90

45.58

50.00

52.23

6.57

53.41

59.84

57.69

70.98

67.8S7

68.01

74.14

65.62

70.94

58.77

55.43

49.25

40.17

Dry

57.02

75.97

2-13-92

5.37

45.68

49.34

51.28

7.10

53.11

59.41

57.65

70.85

72.48

Dry75.19

64.80

71.37

57.46

Dry47.67

41.12

Dry

56.36

77.45

7-27-93

NA6

44.93

45.45

50.90

NA6

53.37

58.20

56.85

Dry

72.28

Dry

75.92

65.55

NA6

57.21

56.38

45.37

39.84

Dry

NA6

NA6

5 These elevations have been adjusted based on survey data submitted by Dynamac Corporation in1991. The elevations marked inside the wells are different from the elevations used to calculate ground waterlevels here.

6 Water levels were not obtained for wells tapping the second water-bearing zone, for well 89-14 (thecompression cap could not be removed), or for wells 89-20 and 89-21.

7 This data point is not consistent with other data points for well 89-10 and is questionable.

21

A R 3 0 I 5 9 0

Table 4-4

CALCULATED HEAD DIFFERENCE ACROSS SECTIONS OF THE SLURRY WALL8

Well Pair89-03/89-02

89-06/89-04

89-07/89-08

89-09/89-10

89-11/89-12

89-13/89-14

89-15/89-16

89-17/89-18

August 90

+ 4.91

+ 1.03

+ 3.64

- 1.83

-5.92

-4.59

+ 6.70

+ 11.38

11-27-90

+ 5.56

+ 0.48

+ 3.23

-1.79

-5.05

-4.44

+ 5.02

+ 13.31

2-27-91

+ 6.12

+ 2.29

+ 2.47

-3.47

-9.47

-5.95

+ 3.01

+ 12.79

5-30-91

+ 1.36

+ 1.01

+ 1.99

-2.74

-9.58

-6.05

+ 2.79

+ 10.49

11-21-91

+ 4.42

+ 1.18

+ 2.15

+ 3.10*

-6.13

-5.32

+ 3.34

+ 9.08

2-13-92

+ 3.66

+ 1.83

+ 1.76

- 1.63

- 7.510

-6.57

+ 2.610

+ 6.55

7-27-93

+ 0.53

+ 2.47

+ 1.35

- 1.510

- 7.910

NA"

+ 0.83

+ 5.53

8 A "+" indicates an outward gradient; a "-" indicates an inward gradient.

* This value is based on questionable data. See Table 4-3.10 One well in the pair was dry. The calculated head difference is the difference between the ground water

elevation in the well which was not dry, and the elevation of the bottom of the screen of the dry well.11 A head difference could not be calculated because data for one well was not available.

22

S R 3 0 I 5 9

However, the head difference was less than or approximately equal

to one foot in approximately 15 percent of the measurements.

If a head difference less than one foot is observed between

the wells in a well cluster, further analysis of the ground water

level data is necessary in order to evaluate the performance of

the slurry wall. When this condition is encountered, the trends

in the water levels in the paired wells must be examined in order

to determine whether the apparent equilibration is a result of

similar or opposing trends in water-level fluctuation.

Equilibration due to similar trends with different rates may be

due to a random confluence of factors not related to slurry wall

failure, whereas equilibration due to opposing and converging

trends (e.g., an interior well increases in head elevation while

its companion loses, and the hydraulic gradient across the slurry

wall decreases) is a sign of possible slurry wall failure.

Opposing and diverging trends may indicate normal lowering of the

water table within the slurry wall.

The ground water elevations obtained from each well between

August 1990 and July 1993 were plotted in order to evaluate the

trends in the ground water elevations (Appendix B). Water level

trends in those well pairs where a head difference of one foot or

less occurred were examined. The water level trends present no

evidence of slurry wall failure.

Figures 4-1 and 4-2 are generalized cross-sections showing

ranges in water levels measured in six of the slurry wall

monitoring wells. The figures illustrate that hydraulic

23

SR30I592

80 —i

2/27/91 *— ,.11/27/90 ^ s

7/27/93 % s

PUJ

2OP<UJLJ

70 —

60 —

:otzciVJ )

50 —J

11/27/902/27/91

-̂S7/27/B3

SUPERFUND SITE

ARUNDEL CLAY

c'

11/27/90

2/27/81

\

7/27/93 S- -g7/27/93

, 11/27/90

+ WATER LEVEL BELOW BOTTOM OF WELL

CROSS SECTION SHOWING HYDRAULIC GRADIENT ACROSS SLURRY WALL FIGURE 4-1

80 —,

PUJ

o

I

70 —

n! eo —I

50 —I

SUPERFUND SITE

ARUNDEL CLAY

d

89-02

c'

CROSS SECTION SHOWING HYDRAULIC GRADIENT ACROSS SLURRY WALL FIGURE 4-2

gradients across the slurry wall are significantly greater than

the background hydraulic gradient, and that the slurry wall is

functioning as designed. Figure 4-1 also shows that the water

level in monitoring well 89-03, which is located inside the

downgradient portion of the slurry wall, did not change

significantly between November of 1990 and February of 1991.

Significant reductions in water level were observed in monitoring

well 89-03 only after continuous pumping of nearby EW-1 was

initiated in March of 1991. This data further supports the

conclusion that the slurry wall is functioning as designed.

4.2.2 Ground Water Extraction

All of the components of the ground water extraction system

were in place and showed no sign of leakage, wear, or

deterioration upon visual inspection. The only noticeable

concern was the presence of 2 to 3 inches of standing water in

the valve box.

Substantial dewatering of the first water-bearing zone has

occurred as evidenced by the lowering of the water table within

boundaries of the slurry wall between August of 1990 and July of

1993, when the last ground water level measurements were

obtained. At each well pair, except pairs 89-04/89-06 and 89-

08/89-10, the reduction in ground water elevation inside the

slurry wall was significantly greater than the reduction in the

ground water elevation outside the slurry wall (Table 4-5). Well

pair 89-04/89-06 is located along the northern portion of the

26

f l R 3 U I 5 9 5

Table 4-5

REDUCTION IN GROUND WATER ELEVATIONBETWEEN AUGUST OF 1990 AND JULY OF 1993

Well No. Well Location12 Change in Elevation (ft)

89-03 I - 8.489-02 E - 4.5

89-06 I - 1.289-04 E - 2.5

89-07 I - 3.489-08 E - 1.0

89-09 I - 0.989-10 E - 1.5

89-11 I - 2.489-12 E - 0.3

89-13 I - 2.789-14 E - 1.4

89-15 I - 7.089-16 E - 1.9

89-17 I - 8.689-18 E - 2.4

12 Position of monitoring well with respect to the slurrywall. E = external; I = internal.

27

3R3UI596

slurry wall, and well pair 89-09/89-10 is located in the

southwest corner of the slurry wall. The apparent reduced rate

of dewatering within the slurry wall in these areas of the site

may be attributed to specific conditions. The relatively small

decrease in the ground water elevation inside the slurry wall at

monitoring well 89-06 may be ascribed to the extended period of

inoperation of EW-2. The ground water level in monitoring well

89-09 dropped below the bottom of the well screen between

February of 1992 and July of 1993. Although no further reduction

in ground water elevation can be measured in monitoring well 89-

09, it was anticipated during remedial design that a remnant

ponded area would be present along the interior of the southwest

portion of the slurry wall, based on the inferred topography of

the subsurface clay (Final Design Analysis Report, EA

Engineering, Science, and Technology, Inc., 1989). In

conclusion, the overall lowering of the water table inside the

slurry wall, as compared to outside the slurry wall, demonstrates

the effectiveness of the ground water extraction system (see

Figures 4-1 and 4-2).

The volume of ground water extracted from within the

boundaries of the slurry wall has been significantly less than

anticipated during the remedial design. Table 4-6 presents the

volumetric ground water extraction data obtained between December

of 1990 and October of 1992. As shown in the table, the average

daily extraction rate varied from a high of 336 gallons per day

(gpd) between April and June of 1992 to a low of 106 gpd between

28

AR3UI597

Table 4-6

KANE AND LOMBARD SITE, OU1EXTRACTION WELL AVERAGE DAILY EFFLUENT FLOW RATE

Date

12/19/90

12/20/91

12/24/91

2/5/92

4/29/92

6/11/92

10/21/92

Volume13

(gallons^

18,851

208,538

209,488

222,370

248,847

263,298

277,194

Change inVolume

18,851

189,687

950

12,882

26,477

14,451

13,896

Days ofPumping

NA"

NA16

4

43

84

43

131

Average Rowfepd)

NA15

NA15

238

300

315

336

106

13 Total volume of extraction well effluent discharged to wastewater treatment plant (flow totalizerreadout).

14 Effluent was not continuously pumped from the extraction wells between the start-up date and 12/19/90.The number of days of pump operation is not known.

15 The average daily flow rate cannot be calculated because the number of days of pump operation is notknown.

16 Effluent was not continuously pumped from the extraction wells between 12/19/90 and 12/20/91.Therefore, the average daily flow rate cannot be calculated.

29

f l R 3 U ! 5 9 8

June and October of 1992. The rate of extraction has further

declined since October of 1992, as noted in section 3.3 of this

report. In order to evaluate possible reasons for the current

low rate of effluent discharge, EPA obtained ground water level

measurements from EW-1 and EW-2 in October of 1993. The ground

water elevation in each well was found to have fallen below the

elevation of the pump-on switch located inside each extraction

well (but not below the level of the pump-off switch). A

subsequent measurement obtained from EW-2 in March of 1994 showed

that the water level had risen two feet, to the level of the

pump-on switch, and indicates that ground water within the

boundaries of the slurry wall is continuing to enter the zone of

influence of the extraction wells.

30

AR3GI599

4.2.3 Ground Water Discharge

Requirements for the discharge of extraction well effluent

from the Kane and Lombard site, through the Baltimore City

sanitary sewerage system, and to the Back River WWTP are outlined

in Wastewater Discharge Permit No. 4-08695. The permit

establishes discharge limitations (maximum daily concentrations),

as well as metering and sampling requirements, pursuant to

Section 27d of Article 25 of the Baltimore City Code, as amended

by Ordinance 129 of 1984.

A summary of contaminants found at the Kane and Lombard site

since July of 1990 is contained in Appendix D. This summary was

provided in spreadsheet form by the State of Maryland and was

updated with the ground water analytical results submitted by

EPA. The summary shows that the discharge of effluent from the

extraction wells was in compliance with the Discharge Permit

until August of 1992. The chlorobenzene concentration in

effluent discharged from EW-1 (4.1 mg/L) and EW-2 (4.7 mg/L) in

August of 1992 was found to exceed the 2.13 mg/L discharge limit

for TTO. Based on these findings, the Kane and Lombard ground

water extraction system was taken off-line, and an effluent

pretreatment system was installed, as noted above. However, the

volume of ground water pumped from the extraction wells since the

pretreatment system was installed has not been sufficient to

allow the system to be evaluated. As long as the RCRA cap

continues to prevent the infiltration of precipitation and the

slurry wall continues to impede the migration of ground water

31

AR30I6QO

onto the site, the volume of water that enters the extraction

wells will be small and the rate of effluent discharge will be

low. EPA and MDE are continuing to coordinate efforts with the

City of Baltimore Department of Public Works in order to ensure

that any future discharge of effluent to the Back River WWTP

complies with discharge limits.

32

flR30!60

5. CONCLUSIONS AND RECOHHENDATIONS

The general conclusion derived from this five-year review of

the Kane and Lombard site is that the remedial action has

provided source control and reduced the risk of direct contact

with contaminated soils. Therefore, the remedy as spelled out in

the ROD remains effective in protecting human health and the

environment.

The following conclusions were drawn based on the

observations at the site and review of available information:

o The remedy is operating and functioning as designed.

o The landfill cap system is intact and its vegetativecover shows negligible wear. The cap continues toprevent infiltration of surface water into the wasteand contaminated soil, and to isolate the waste fromhuman contact.

o The soil-bentonite slurry wall is functioning asdesigned.

o Wastes and contaminated soil and ground water in thefirst water-bearing zone within the slurry wall havebeen effectively contained.

o The ground water extraction system is operational andfunctional and the first water-bearing zone has beensubstantially dewatered within the boundaries of theslurry wall. However, an outward hydraulic gradientcontinues to exist along the northwestern, northern andeastern portions of the wall. The rate of ground waterextraction is expected to continue to decrease as thedewatering process continues.

o The ground water monitoring wells are in goodcondition.

33

f l R 3 U I 6 0 2

o The gas venting system is operational and functional.

o Perimeter fencing is in place. However, tampering hascompromised the effectiveness of the fence.

o Deed restrictions are in place and are protective.

Recommendations for the site are listed below. Identifiedmaintenance measures should be implemented immediately in orderto adeguately control site access and use.

o The site security fence should be repaired in order toensure that site access is restricted. Necessaryrepairs include: replacement of damaged fence fabric;repair/replacement of post connectors and anchormechanisms; re-attachment of fence fabric wherenecessary; removal of any fallen trees/limbs from thefence; and installation of additional fencing and/oradditional filling and grading in areas where thebottom of the fence is above the existing grade.Deficiencies in the fence and erosion rills or animalburrows under the fence should be repaired within twodays of discovery.

o Barren areas on the cap should be reseeded.

o Eroded areas of the drainage ditch should be filled andreseeded.

o The perimeter fence and cover should be inspected on aquarterly basis, at a minimum. Repairs should bepromptly executed.

o Ground water level trends in the monitoring wells whichbracket the slurry wall should continue to bemonitored. In the event that the water levels withinthe slurry wall cease to decline before an inwardhydraulic gradient is achieved at each of themonitoring points, consideration should be given toreconfiguring the existing ground water extractionsystem (e.g., adjusting operation of the pumps,installing additional extraction wells, etc.).

o Past disposal activities at the Kane and Lombard siteand an area immediately north of the site (the OU2"Study Area") have resulted in releases of hazardoussubstances to the ground water of the second water-bearing zone, and may have impacted nearby ecologicalzones. The nature and extent of contaminationresulting from releases from the Study Area arecurrently being evaluated as part of the OU2 RI/FS. If

34

AR30I603

contaminants identified during the OU2 RI are found topresent an unacceptable risk to human health or theenvironment, response actions should be taken to reduceor eliminate those risks.

Since hazardous substances remain on-site at levelswhich will not allow for unrestricted use and unlimitedaccess, the effectiveness of the remedy should bereassessed within five years.

35

flR30!60U

APPENDIX A

PHOTODOCUMENTATION

A R 3 U I 6 0 5

EPA REGION IIISUPERFUND DOCUMENT MANAGEMENT SYSTEM

DOC ID #PAGE#

IMAGERY COVER SHEETUNSCANNABLE ITEM

Contact the CERCLA Records Center to view this document.

SITE NAME

£gSECTION/BOX/FOLDER O q . 45______6-OIO

REPORT OR DOCUMENT TITLE A-^WCi_Ah^B C_ ._C:C4/'h^^

(,Cgagr EMS

DATE OF DOCUMENT

DESCRIPTION OF IMAGERY

NUMBER AND TYPE OF IMAGERY ITEM(S) i*7.

APPENDIX B

GROUNDWATER ELEVATION GRAPHS

A R 3 G I 6 I 5

I/)

o§u

'•*-<

GOCD

cnen

Kane &c Lombard — Groundwater E evctionsMonitoring Wells 89-02 and 89-03

56

55 h

54

53

52

51

50

49

48

47

46

45

44Aug 90 Nov 90 Feb 91 May 91 Nov 91 Feb 92 July 93

Date

D 89-03 (inside) + 8^-02 (outside)

Static Water Level (ft MSL)

pIn

cnroLn

D

00IDIO

CID

IDO

O<IDO

n>crUD

ODr-t-

-J- CD S.QX

CO LDID -1

IO-P*

'cT 2c or-t- <-•C/)_ *•CL ID

~nfDtrt£>to

c_c_

^<LD

01OJ

"T

cnen

Q13CD

O3aQ

OD

To O* c§ D°- Q.00 <-

T $i Qen

CD

mCD<Q

o'D00

0)>4)_J

CO COCD

oo

Kane <Sc Lombard — Groundwater ElevationsMonitoring Wells 89-07 and 89-08

62

61

60

59

58

57

56Aug 90 Nov 90 Feb 91 May 91 Nov 91 Feb 92 July 93

Date

D 89-07 (inside) + 89-08 (outside)

0)_J

0)-*-*o

y'•+-•O

— (/)

=0COCD

Kane & Lombard — Groundwater Elevations79

78 h

77

76

75

74

73

72

71

70

69

68Aug 90

Monitoring Wells 89-11 and 89-12

Nov 90 Feb 91 May 91 Nov 91 Feb 92

Date

July 93

D 89-11 (inside) + 89-12 (outside)

(/I

Q)•fo£y

'-*-jo-*jt/)

COCD

roCD

74

73

72

71

70

69

68

67

66

65

64

Kane & Lombard — Groundwater ElevationsMonitoring Wells 89-13 and 89-14

Aug 90

NA

Nov 90 Feb 91 May 91 Nov 91 Feb 92 July 93

Date

D 89-13 (inside) + 89-14 (outside)

I/)5

4)>0)_J

o-t-1

t/1

COCD

ro

Kane & Lombard — Groundwater ElevationsMonitoring Wells 89-15 and 89-16

65

64 h

63

62

61

60

59

58

57

56

55Aug 90 Nov 90 Feb 91 May 91 Nov 91

Date

Dry

Feb 92

D 89-15 (inside) + 89-16 (outside)

July 93

l/l

0)

o•*-*I/)

CD

roro

Kane & Lombard — Groundwater ElevationsMonitoring Wells 89-17 and 89-18

55

54 h

53

52

51

50

49

48

47

46

45

44

43

42

41

40

39Aug 90

-&

Nov 90 Feb 91 May 91 Nov 91 Feb 92 July 93

Date

D 89-17 (inside) + 89-18 (outside)

APPENDIX C

DISCHARGE PERMIT

SR30I623

WASTBWATBR DISCHARGE PERMIT

Permit Number: 4-08695

Effective Date: 08/31/91

Expiration Date: 08/31/92

Pursuant to the provisions of Article 25, Sections 1-27,of the Baltimore City Code, Baltimore City hereinafterreferred to as the "city" hereby authorizes

The Environmental Protection Agency

Location at

Kane and Lombard StreetsBaltimore City 21224

To Discharge From

The Kane and Lombard SuperfundSite groundwater collection

and pumping system

To

The Back River Wastewater Treatment Plant

in accordance with the following special and generalconditions.

AR30I62U

ATTACHMENT ADISCHARGE CONDITIONS

The following conditions shall apply to the discharge of allwastewater to the sanitary sewerage system until such time asthis Wastewater Discharge Permit is amended or revoked.

1. Be advised that the discharge of non-residentialwastewater to the sanitary sewer without a WastewaterDischarge Permit may result in a minimum fine of $250.00 foreach day of violation, as stated in Section, 11, Paragraph Bof Article 25 of the Baltimore City Code.

2. Discharge shall originate from Extraction Well #1 (seeattached diagram). Extraction Well #2 (see attached diagram)shall not be discharged without written consent from thePollution Control Section. If Well #2 is allowed todischarge, a permit modification will be required.

3. All changes in business location, industrial process,quantity or quality of discharge, or in chemical storageprocedures shall be reported to the Pollution Control Sectionof the Bureau of Water and Waste Water. The Permittee isresponsible for notifying the Pollution Control Section ofany substantial change in the volume or character ofpollutants in the facility's discharge. Advance notice isrequested for anticipated facility expansions, productionincreases, and process modifications which could result inthe change of the quantity or quality of dischargedpollutants. Modifications may be made to the permit tospecify and limit any pollutants not previously limited, orto delete pollutants which may no longer be discharged.

4. As per Article 25, section 8.g. (2), "Inspection andsampling of every facility that is involved directly orindirectly with the discharge of wastewater to the City'swastewater system may be made by the Director of PublicWorks." Therefore, the City may at any time inspect existingplumbing systems or industrial pretreatment facilities andrequire such modifications as are deemed necessary.

5. Wastewater discharge shall strictly conform to Article 25of the Baltimore City Code or to such Federal or Stateregulations as are more stringent. Specific prohibitions per40 CFR 403.5 include the following:

a) Pollutants which create a fire or explosion hazardin the POTW, including, but not limited to, wastestreamswith a closed cup flashpoint of less than 140 degreesFahrenheit or 60 degrees Centigrade using the testmethods specified in 40 CFR 261,21;

b) Pollutants which will cause corrosive structuraldamage to the POTW;

_2_ UR30I625.

c) Solid or viscous pollutants in amounts which willcause obstruction to the flow in the POTW resultingin interference;

d) Any pollutant released in a discharge at a flow rateand/or pollutant concentration which will causeinterference with the POTW;

e) Heat in amounts which will inhibit biologicalactivity in the POTW resulting in interference;

f) Petroleum oil, non-biodegradable cutting oil, orproducts of mineral oil origin in amounts that willcause interference or pass-through; and

g) Pollutants which result in the presence of toxicgases, vapors, or fumes within the POTW in a quantitythat may cause acute worker health and safety problems.

6. Prohibition of dilution/excessive dischargeThe permittee shall not increase the use of potable wateror, in ay way, attempt to dilute a discharge as a partialor complete substitute for adequate treatment to achievecompliance with the limitations contained in this permit.

7. Spent or spilled materials may not be discharged to thesanitary sewer without treatment, when applicable.

8. A log must be kept of all disposal(s) indicatingmaterial(s), date(s), volurae(s), disposal method(s), andwaste hauler(s), if applicable. A copy of this log and allwaste manifests are to be made available for review by thePollution Control Section at all times.9. Specific reference is made to the following sections ofBaltimore City Code Article 25:

—Section 7(a.) which concerns the discharges ofprohibited or restricted pollutants.

—Section 7(c.) which concerns the minimum recordsretention time of three years.

—Section 8 (c.) which concerns plans, complianceschedules and operating procedures.

Additional limitations and restrictions are provided inthe following attachments.

-3-

AR30I626

General Requirement*

A. PERMIT EFFECTIVE DATE

1. The effective date (date, of issue) is the date thepermit is validated by the office of the Director of Finance.

B. SAMPLING REQUIREMENTS

1. Self-Monitoring

(a) Self-monitoring reports are required to be basedupon data obtained through sampling and analyticaltechniques approved by the EPA and performed during theperiod covered by the report, of which data isrepresentative of conditions occurring during thereporting period.

(b) Analysis shall be conducted in accordance withapproved sampling and analytical methods as stated in 40CFR 136 and amendments thereto. If a pollutant is notincluded in 40 CFR 136, or a testing method is deemedinappropriate, alternative methods must be approved bythe regional administrator of the United StatesEnvironmental Protection Agency, Region III.

(c) The Pollution Control Section shall determine thefrequency of monitoring necessary to assess and assurecompliance by the Permittee with applicable PretreatmentStandards and Requirements.

(d) In accordance with 40 CFR Part 403.12(g), ifsampling performed by the Permittee indicates aviolation, the Permittee must notify the PollutionControl Section within 24 hours of becoming aware of theviolation. The Permittee must repeat the sampling andanalysis and submit the results of the repeat analysisto the Pollution Control Section within 30 days afterbecoming aware of the violation. If the PollutionControl Section performs sampling at the Permittedfacility between the time the Permittee performs itsinitial sampling and the time the Permittee receives theresults of this sampling, resampling is not required.

(e) Any monitoring of waste water which is performedmore frequently than required by this Permit should beincluded in the report prepared for the applicablemonitoring period.

C. Management Requirements

1. Duty to MitigateThe Permittee shall take all reasonable steps tominimize or correct any adverse impact resulting from

-4- RR301627

noncompliance with this permit, including suchaccelerated or additional monitoring as necessary todetermine the nature and impact of the noncomplyingdischarge.

2. Duty to ComplyThe Permittee shall comply with all conditions of thispermit. Failure to comply with the requirements of thispermit may be grounds for administrative action orenforcement proceedings including cessation ofdischarge, civil or criminal penalties, injuctive reliefand summary abatements.

3. Duty to Provide InformationThe Permittee shall furnish to the Pollution ControlSection, within a reasonable time, any information whichis requested to determine whether cause exists formodifying, revoking and reissuing, or terminating thispermit or to determine compliance with this permit. ThePermittee shall also furnish, upon request, to thePollution Control Section copies of records to be keptby this permit.4. Proper Disposal of Solids/SludgesThe Permittee shall dispose of any solids, sludges orother pollutants removed in the course of treatment inaccordance with Section 405 of the Clean Water Act andSubtitles C and D of the Resource Conversation andRecovery Act.

5. Upset ProvisionAn upset shall constitute an affirmative defense to anaction brought for noncompliance with PretreatmentStandards only if the permittee demonstrates, throughproperly signed, contemporaneous logs, or other relevantevidence, that:

a. an upset, occurred and that the permittee canidentify the specific cause(s) of the upset;b. the permitted facility was at the time beingoperated in a prudent and workman-like manner and incompliance with proper operation and maintenanceprocedures;c. the permittee submitted notification of the upsetwithin 24 hours of its occurrence, in accordance withthe reporting requirements as stated in this permit;d. the permittee submitted, within five days ofbecoming aware of the upset, documentation to supportand justify the upset; ande. the permittee complied with any remedial measuresrequired to minimize adverse impact.

-5-

flR3QI628

6. Maintenance and operation of pretreatment andcontrol facilities

The permittee shall at all times properly operate andmaintain all facilities and systems of treatment and control(and related appurtenances) which are installed or used bythe permittee to achieve compliance with the conditions ofthis permit. Proper operation and maintenance includes butis not limited to: effective performance, adequate funding,adequate operator staffing and trainingr and adequatelaboratory and process controls, including appropriatequality assurance procedures. This provision requires theoperation of back-up or auxiliary facilities or similarsystems only when necessary to comply with the conditions ofthis permit. Malfunctioning of leachate pumping, piping,metering, or related mechanical systems shall be grounds forcessation of discharge. Inspection and approval of repairsto system(s) by the Pollution Control Section is requiredbefore leachate discharge is permitted to resume.

7. Bypass of Flow Measurement Equipment(A) Bypass is prohibited unless it is unavoidable to prevent,loss of life, personal injury or severe property damage or nofeasible alternatives exist.(B) Notice of BypassIf a Permittee knows in advance of the need for a bypass, itshall submit prior notice to the Pollution Control Section,8201 Eastern Boulevard, Baltimore, Maryland 21224, ifpossible at least ten days before the date of the bypass.

8. (A) Within 15 minutes of any accident, negligence, orother occurrence that involves in excess of 50 gallons of anysubstance (raw material, intermediate, product, by-product,etc) which has or may enter the municipal sanitary seweragesystem, the Pollution Control Section and the Waste WaterTreatment Plant must be notified. Between the hours of 8:30am and 4:30 pra, the Pollution Control Section may be reachedat (301) 396-9695. During off hours and on holidays andweekends, contact the City Hall operator at (301) 396-3100and request that Pager #428 be activated. The telephonenumber for the Back River Waste Water Treatment Plant is(301) 396-9800.

(B) Authorization for notification must be given to non-management employees in cases where Permittee managementcannot be contacted so that notification can be made withinthe specified 15 minute time period.

(C) Samples of the material should be collected and retainedfor analysis by the Pollution Control Section.

(D) Within five days*of the incident, a written reportincluding the circumstance of the incident, the volume ofmaterial discharged or contained, a chronology of events fromthe time the incident is discovered until the disposal has

-6- flR3QI629

occurred, Material Safety Data Sheet for the compound,corrective measures and any other pertinent information mustbe supplied to the Pollution Control Section. (E) Anymaterial contained on the premises for future discharge mustbe approved for disposal to the sanitary sewer by thePollution Control Section.

D. Responsibilities

1. Permit ActionThis permit may be modified, revoked, and reissued, orterminated for good cause including, but not limited to,the following: a. to incorporate any new or revisedFederal, State, or local pretreatment standards orrequirements; b. material or substantial alterations oradditions to the discharger's operation which were notcovered in the effective, permit; c. a change in anycondition that requires either a temporary or permanentreduction or elimination of the authorized discharge; d.information indicating that the permittee's dischargeposes a threat to the collection and treatment system,POTW personnel or the receiving waters; e. violation ofany terms or conditions of this permit; f. obtainingthis permit by misrepresentation or failure to disclosefully all relevant facts; or g. upon request of thepermittee, provided such request does not create aviolation of any existing applicable requirements,standards, laws, or rules and regulations. The filingof a request by the permittee for a permit modification,revocation and reissuance, or termination, or anotification of planned changes or anticipatednoncompliance, does not stay any permit condition.

2. Transfer of Ownership or Control of FacilitiesThis permit is issued to a specific user for a specificoperation and is not assignable to another permittee ortransferable.

3. Confidential information/availability of reportsExcept for data determined to be confidential underSection 308 of the Clean Water Act, 33 U.S.C. 91318) andArticle 25 of the Baltimore City Code as amended byOrdinance 129 of 1984, all submitted data shall beavailable for public inspection at the offices of thePollution Control Section, the Maryland Department ofthe Environment, and the Regional Administrator of theEnvironmental Protection Agency.

4. Falsifying informationKnowingly making any false statement on any report orother document required by this permit or knowinglyrendering any monitoring device or method inaccurate,subjects the permittee to criminal law proceedings aswell as civil penalties and injunctive relief.

~7~ f l R 3 Q I 6 3 0

5. Signatory and Certification RequirementsAll applications, reports, or information submitted tothe Pollution Control Section shall be signed andcertified:

a. for a Federal, State, or local governmental entity:by the principal executive officer or director havingresponsibility for the overall operation of thedischarging facility; or

b. by a duly authorized representative if theauthorization is made in writing by a person describedabove. A duly authorized representative may be either anamed individual or any individual occupying a namedposition.

c. The following certification statement is to beincluded with any Permittee Periodic Compliance Report:"I certify under penalty of law the this document andall attachments were prepared under my direction orsupervision in accordance with a system designed toassure that qualified personnel properly gather andevaluate the information submitted. Based on my inquiryof the person or persons who manage the system, or thosepersons directly responsible for gathering theinformation, the information submitted is, to the bestof my knowledge and belief, true, accurate, andcomplete. I am aware that there are significantpenalties for submitting false information, includingthe possibility of fine and imprisonment for knowingviolations."

6. Severability clauseThe provisions of this permit are severable. If anyprovisions of this permit shall be held invalid for anyreasons, the remaining provisions shall remain in fullforce and effect. If the application of any provisionof this permit to any circumstance is held invalid, itsapplication to other circumstances shall not beaffected. -

7. Property rightsThe issuance of this permit does not convey any propertyrights in either real or personal property, or anyexclusive privileges nor does it authorize any injury toprivate property or any invasion of personal rights, norany infringement of Federal, State or local laws orregulations.8. Action on violationsThe issue or reissue of this permit does not constitutea decision by the Pollution Control Section not toproceed in an administrative, civil, or criminal action

- 8 ' f l R 3 U I 6 3 l

for any violations of laws or regulations occurringbefore the issue or reissue of this permit, nor a waiverof the Pollution Control Section's right to do so.

9. Reopener ClauseThis permit shall be modified, or alternately, revokedand reissued, to comply with any applicable effluentstandard or limitation issued or approved under Section301, 304, and 307 of the Clean Water Act if the effluentstandard or limitation so issued or approved: a.contains different conditions or is otherwise morestringent than any effluent limitation in the permit; orb. controls any pollutant not limited in the permit.The permit, as modified or reissued under thisparagraph, shall also contain any other requirement ofthe Act then applicable.

ATTACHMENT B -

Reporting RequirementsAll analytical data must be reported quarterly, in writing,to the Pollution Control Section. These monitoring reportsmust include:

1) Initiation and collection times and dates for eachsample;

2) Exact sample collection location;

3) Flow meter or water meter readings coinciding with sampleinitiation and collection and total volume represented byeach sample;

4) Grab and composite designation. (Cyanides, volatileorganics, pH, and fats, oils & greases must be collected asgrab samples. Failure to do so or so indicate is a violationof the Self-Monitoring requirements.)

5) Analytical methods used for determining each parameter;

6) Dates and times analyses were performed;7} Identification of laboratory personnel performing eachanalysis;

8) The result of the analyses including the units in whicheach is expressed; and

9) The appropriate signature and certification. (See Part D5(c) of this Permit for the exact wording to be used.

Any data generated by a private independent laboratory mustbe sent directly from the laboratory to the Pollution Control

"9" SR30I632

Section, 8201 Eastern Boulevard, Baltimore, Maryland 21224.These reports must be received at that office no later than28 days following the end of the Calendar quarter. Failureto submit the required information by the deadline is aviolation of Section 8.a. of Article 25 of the Baltimore CityCode and will result in the assessment of civil penalties asprovided by Section 11.b. of said Article.

This permit and the authorization to discharge shall expireon midnight s/31/1992 * The Permittee shall not dischargeafter the date of expiration unless authorization is grantedby the Pollution Control Section. In order to receiveauthorization to discharge beyond the above date ofexpiration, the permittee shall request an extension ofpermit conditions no later than 30 days prior to the abovedate of expiration.

by authority of

RaljSh (X Cullison, IIIChiefEnvironmental Services Division

-10-

H R 3 0 I 6 3 3

INDUSTRY NUMBER ___________EPA KANE & LOMBARD ST SUPERFUND SITE

MONITORING SCHEDULE

SAMPLING LOCATION: N.E. corner of property at main entrance gate. Samplingvault is east of metering vault and adjacent to the main control panel forthe extraction wells and flow meter. See attached diagram. Sampling siteis indicated as "Sampling Vault."PROCESS DESCRIPTION: This superfund site is designed to encapsulate leachatewater and remove it via extraction well pumps. The leachate is meteredbefore it is discharged to the City's sanitary sewer and POTW.

Sampling is required for the following parameters at the indicated frequency:

PARAMETER

BOD

SUSPENDED SOLIDS

COD

TEMPERATURE

FATS, OILS, 6REASES

-~

ALJJJ PHENOLS

BASE/NEUTRALEXTRACT-ABLE ORGANICS

PESTICIDES/PCBS

VOLATILE ORGANICS

Cd

Cu

Cr

Pb

Hfl

Nis«Ag

ZD

COUP8 HRS

OSITE24 HRS

GRAB

X

X

X

X

X

X

X

X

X

X

X

X

4 DAYSDI

5 DAYSJRiTIO*7 DAYS 10 DAYS ONCE/W

FREQUENCYONCE MONTH ONCE QUARTER

Z

X

X

X

X

X

X

X

X

X

X

X

COMMENTS

"

11

VAHDYKE

^oglafflp"*SAV-Jte<

e?<^rcr _

DISCHARGE STANDARDS/LIMITATIONSREQUIRED BY

THE CITY OF BALTIMORESECTION 27d OF ARTICLE 25OF THE BALTIMORE CITY CODEAS AMENDED BY ORDINANCE 129OF 1984

LOCAL DISCHARGE LIMITS

Waste Constituent Group

Discharge Limitations

MAXIMUM DAILY CONCENTRATION(COMPOSITE SAMPLE)

I. Acids and Alkalies (pH Units) -- l

No person shall discharge or cause toto be discharged into any sanitarysewer:A. Acids with a pH value lower than 5.0 when measured directly from

the source wastestream or lower than 6.0 when measured afterdilution in the immediate public sewer.

B. Alkalies with a pH value higher than 12.0 when measured afterdilution in the immediate public sewer.

II. Heavy Metals

A. Cadmium (Cd)B. Chromium, Total (Cr)C. Lead (Pb)D. Mercury (Hg)E. Nickel (Ni)F. Zinc (Zn)G. Copper (Cu)H. Silver (Ag)

.216.896.810.012.82

17.856.591.2

mg/1mg/1mg/1mg/1mg/1mg/1mg/1mg/1

III. Total Toxic Organics a 2.13 mg/1 *

IV. ANY WASTESTREAM WITH A CLOSED CUP FLASHPOINT OFLESS THAN 140°F(60°C) is prohibited from discharge.

Based upon grab samplesTo include organic priority pollutants and non-priority pol-lutants determined to adversely affect the conveyance system,treatment plant, receiving waters or constitute a potentialhazard to humans exposed to the wastewater.

HR30I637

-Total-Toxic Organics

ActnaphthtntAcenapthytene (PAH)AeroleinAcrylonitrileAldrin

AnlhraetM

1.2 Bentanthractne (PAH)BenzeneBentidineBenzo (A) Pyrene (3,4-3cnzopyrene)

(PAH)3,4 Benxofluoranthent (PAH)Bfnxo (K) Fluoranthene (PAH) -1.12 B«nioperylen« (PAH)• ".,\ ..Bromoform (Tribromomethane)Bromomethant (Methyl Bromide)4-3romophenyl Phenly Ether

Carbon Tetnchloride(Tier achloro methane)

ChtordantC'nloro benzene (Monochlorobenxene)Chlorodibromomithant (Hilomethani)Chlorotthani (Monoehlorotthaat)CKlorotthyl Elher (Bis-2)1 Chloroethory Methane (Bis-2)2 Chlorotthyl Vinyl Ether4-Chloro-3-MethylphenolChloromethane (Mtthyl Chloride)Chloroform (Trtchloromethant) -2 ChJorophcnolChloroisopropyl Ether (Bis-2)2 Chloronaphthalen*4 Chloropheayl Phenyl Ethtr

Chryunt (PAH)

1.2 Diehlorobenttne-1.3 Dichlorobenient1.4 Dichlorobenzen*3,3 DichlorobenztdiniDiehlorocthane 1J,Dlchloroethue 1^1.1 Dichloroethylenc

**, DOT4,4 DOE4.4 000Dibtme (m4t) Aothracen* (PAK)

2M1trophtaoi

4,8-Dioitro-2.MethylphenolNItrovodiinethyUmia* HNitro«odIphenyUmin«-HNitro«odi-N-Proprlamtiw-MPCS 1242 .PCS 12S4 'PCS 1221PCBX232PC812UPCB1260PCS 1011PhenolPenUchlorophcnolPhtnanthrtiw (PAH)Bis (2 Ehtrl Hnyi) PhthaUu

.Diehlorobromomethane (Halomethanei)Dichloromtthant (Halomethanes)2,4-DichlorophenolDichloroprop^nt 1,2Diehloropropcne 1.3DitldrinDimethylphenol 2,4DicthylphthalateDime thy IphthaliUD'mitro toluene 2,4Dinitro toluene 2,62,4-DiaitrophenolDioxin (2.3,7.3-TCDD)Dtphenythydrizinc 1^Alpha EndosuUanBeta EndosulfwEndosuifin Suidt*EndrinEndrin AldehydeEthylbenzinePluorene (PAH)PluoranthentKepiUchlorHepuchlor EpoxideHexaehloroethantHtxachlorobcnzentHexachioroba udien*Hexachloroeydohexant (Lindmna)Hcxachlorocyclohtxant (Alpha)Hexichlorocyclohexant (Btta,)HexachloroeyelohtxaAi (DelU)HtxaehloroQreloptataditntIdrao (W-cd) Pyrtne.(PAH)Iwphoront

Naphthaline

Nitrobtmsnt

Di-N-Butyl PhthalauDl-K-OetyUPhthaUt*Pynn* (PAH)

TttrachlorotthantTetrachlorMthylea*

TolutniToxaphtn*1,2.4 Trichlorobvnxcn*Trichloretthan* UJ.THchloratthan* 1,1.2TnchtorocthylentTrichlorophcnol 2,4,8Viayl Chloride (Chlarathyltnc)

*• Total, • 0.01 .ppm

Butyl Buisyt Phthalau • ^ * uToxic Organics: the sunroation of all quantifiable values greater than

for.tjit abov* .listed toxic organics fl R 3 0 I 6 3 8

APPENDIX D

SUMMARY OF CONTAMINANTS FOUND AT THE KANE AND LOMBARD SITE.

AR30I639

SUMMARY OF CONTAMINANTS

POUND AT KANE AND LOMBARD OU-1 SINCE 7/90MVM 9/2/93

Concentration,HellNo . Clas* Contaminant

89-01 VOC Trichloroethylene89-01 VOC 1,2-Dichloroethylene (total)89-01 VOC Chlorobenzene89-01 BNA laophorone89-01 Metala Barium89-01 Metala Chromium

89-02 VOC Carbon diaulfide89-02 VOC Chlorobenzene89-02 VOC Xylene* (total)89-02 BNA 1,2-Dichlorobenzena89-02 BNA Bi*(2-Ethylhexyl)phth*late89-02 BNA Butyl benzyl phthalate89-02 BNA Di-n-butyl phthalate89-02 BNA Pyrene89-02 Metal* Arsenic89-02 Metal* Barium19-02 Metal* Cadmium89-02 Metala Chromium89-02 Metal* Lead

89-03 VOC Carbon DiculZide89-03 VOC Chlorobenzene89-03 VOC Toluene89-03 BNA Benzo(ghi)perylene89-03 BNA Butyl benzyl phthalate89-03 BNA IndenoU,2,3-cd)pyren«89-03 Metal* Araenic89-03 Metal* Barium89-03 Dl« Barium89-03 Metal* Cadmium89-03 Metal* Chromium89-03 Metal* Lead89-03 Metal* Selenium89-03 Metal* Silver89-03 Metal* Copper89-03 Metal* Zinc89-03 Dis* Zinc

Jul-90

17Q

13ND

ND

50

ND

ND4J

7

ND

130B

34

ND

HD

6

ISO

ND

20

200

ND

10

15

2950026

10

2100

--

ND

80

860

ND

ND

--

--..

Nov-90

20027242J

100

ND

ND

34

ND

ND

10

NO

ND

ND

10

530ND

70760

HDHD

ND

HD

34HD

20

9600

--40

250

4200NDND-.

..

--

Feb-91 May-91

320

42

27

ND

8040

ND57

ND

ND

79

ND

ND

7

7

410

ND

120

440

ND

ND

ND

ND220ND

20

4900_.

90

4606200

ND

20

--..

--

Aug-91

310

44

21

ND

100

40

ND71

ND5J

7J

ND

ND

ND

20

2400

10

560

1500

ND

ND

ND

ND

120ND

10

4900

--

20

170

2700

20

20

--

—--

Hov-91

310

40

192J

110

70

3J

56

ND

ND

ND

21

41

3J

30

600070

1600

6400

6

IS

ND

ND

81NDND

310

—ND

SO

600

NDN»

—

—--

Feb-92 May- 92

..

--

--

--

--

--

..

—

-

--

--

--

--

--

--

--

--

--

--

ND

21

ND

ND

130

".a

350

50

ND

20

200

ND

ND

20

400

150

Aug-92

--

--

--

--

--

--

-_

—

—

--

--

--

--

~

--

--

--

--

--

--

--

--

--

--

----

—

--

--

----

--

--

--

--

—

f l R 3 0 ! 6 U O

SUMMARY OF CONTAMINANTS

FOUND AT KANB AND LOMBARD OU-1 SINCE 7/90MVM 9/2/93

No. Clas* Contaminant

Concentration,

Jul-90 Nov-90 Feb-91 May-91 Aug-91 Nov-91 Feb-92 May-92 Aug-92

89-04 VOC Chlorobenzene89-04 BNA 1,2-Dichlorobenzene89-04 BNA Bi«(2-Ethylhexyl)phthalate89-04 Metal* Barium89-04 Metal* Cadmium89-04 Metal* Chromium89-04 Metal* Lead

89-05 VOC 1,2-Dichloroethylentt (total)89-05 VOC Chlorobenzene89-05 VOC Trichloroethylene89-05 Metal* Barium89-05 Metal* Chromium

89-06 VOC . Chlorobenzene89-06 BNA Bi*(2-Ethylhexyl)phthalate89-06 BNA Butyl benzyl phthaltte89-06 PCS PCS -1242

89-06 Metal* Araenic89-06 Metal* Barium89-06 Metal* Chromium89-06 Metal* Lead89-06 Metal* Selenium

89-07 VOC l,2~Dichloro«thylen*i (total)89-07 VOC TrichloroetheiM89-07 BNA Diethyl phthalate89-07 BNA Bi*(2-Bthylhexyl) phthalate89-07 BNA laophoron*89-07 Met. la Barium89-07 Dia* Barium89-07 Metal* Lead89-07 Metal* Chromium89-07 Metal* Copper89-07 Di** Copper89-07 Metal* Nickel89-07 Dl«* Nickel89-07 Metal* Zinc89-07 Di** Zinc

310NDND

130

NDND

80

ND

ND

3J

120

ND

160

ND

ND7

10

470

140

560

6

72

29ND

7J

16

60

—

100HD---------_.

550. -. A — —

4

130020330

860

6

12

12

130

40

190

2J

2J

ND10

400

100

350

ND

..

—

"

—--

..

_.

--.-

".-

..

__

._

..

--

--

-----.

--

--

-.

--

..

--

--

..

—

--

---.

---.

—--

no38

4J

— ' HD

ND

60

10

ND30

380

210

750

740

2500

2500

--

----

----

--

--

--

--

--

--

"

_.

—

--

--

--

--

--

--

--

--

--

----,-

--

--

—

--

--

--

--

--

--

--

SUMMARY OF CONTAMINANTSPOUND AT KANE AMD LOMBARD OU-1 SINCE 7/90

MVM 9/2/93

Hell

No. Clasa Contaminant

Concentration,

Jul-90 Nov-90 Feb-91 May-91 Aug-91 Nov-91 Fcb-92 May-92 Aug-92

89-08 VOC 1,2'Dichloroethylene (total)89-08 Metala Barium89-08 Metal* chromiumS9-08 Metal* Lead

6210200

70

89-09 VOC Chloroform89-09 SNA Bi*(2-Bthylhexyl)phthalate89-09 Metal* Barium89-09 Metal* Chromium

76JB13030

89-10 BNA Bi*(2-Ethylhexyl)phthalate89-10 Metal* Barium89-10 Metala Chromium

ND13030

ND

100

ND

89-n SNA Bi*(2-Ethylhexyl)phthalata89-11 Metal* Barium

6J80

39-12 Metal* Barium 60

89-13 Metal* Barium89-13 Metal* Chromium

6030

89-14 Metal* Barium89-14 Metal* Chromium89-14 Metal* Lead

2001600

BO

89-15 VOC Acetone89-15 BNA 2-Butanon*89-15 BHA Bi*(2-Bthylh*xyl)phth«lac*89-15 BNA Di-n-butyl phthalat*89-15 BNA H-Nitro*odi-n-propyluanc89-15 BHA Phenol89-15 Metal* Barium

110230

1SJB9J

RD

7»

320

ND

HD

SJ

2J

5JND

89-16 BHA Bi*{2-Bthylb*xyl)pbthalAt<89-16 Metal* Barium89-16 Metal* Chromium

13B150

SO

f l R 3 0 ! 6 l 4 2

SUMMARY OP CONTAMINANTS

FOUND AT KANB AND LOMBARD OU-1 SINCE 7/90

Concentration, jig/L

MVM 9/2/93

HallNo . Claaa Contaminant

89-17 VOC Acetone89-17 Peat. Alpha BHC89-17 Peat. Delta BHC

89-17 Peat. Dieldrin89-17 Peat. Methoxychlor89-17 Metals Arsenic89-17 Metala Barium89-17 Metals Cadmium89-17 Metala Chromium89-17 Metala Lead89-17 Metala Silver

89-18 VOC Carbon diaulfide89-18 Peat. 4,4' -DDD89-18 Peat. 4,4'-DDB

J9-18 Peat. 4,4'-DDT89-18 Peat. Chlordana89-18 Metala AraeniC89-18 Metala Barium89-18 Metala Cadmium89-18 Metal* Chromium89-18 Metala Copper89-18 Metala Lead89-18 Metal* Mercury89-ie Metala Nickel.89-18 Metala Selenium89-18 Metal* Zinc

89-20 SNA Bia (2-Ethylhaxyl)phthalat«89-20 Metal* Araenie89-20 Metala Barium89-20 Metala Chromium

89-21 Matala Barium,69-21 Metal* Chromium89-21 Metala Lead

Jul-90

NDNDND

0.2

ND

10

130ND

ND

200

ND

NDHD

ND

ND

NDND

1600

110

1300

—4200

0.01

--50

--

HD9

27070

90

30ND

NOV-90

ND

0.070.26

0.2

ND

10

210

ND

HD

610

ND

10

ND

ND

ND

ND

20

250

30

130

--650ND--ND—

--

--.-

—

30015090

Feb-91 May-91

ND

ND

ND

ND

ND

10

160

10

30

610

ND

ND

0.36

0.1

0.14

1.97

10

140

40

120

—73

ND--

ND

--

3J

ND

180

20

160

110

ND

Aug-91 Nov-91

ND

ND

ND

ND

--ND

200

10

30

SOO

10

ND

ND

ND

ND

ND

10

430

90

410

--2100

ND

--10

--

..

----

--

110 70

20 ND

ND ND

Feb-92

10 JND

ND

ND

O.S

30

390

40

100

1600

10

ND

ND

ND

ND

ND

20

600

140

600

--2500

8

--ND

--

--

--

--

--

--

----

May- 92

--

------—--————

ND.

0.350.12

ND

ND

5

120

20

60

180

200

ND240

ND

2200

—

--

—

--

—

—

—

Aug-92

--

—

--

--

--

--

—

—

—

—

•-

—

--

—

--

--

--

--

--

--

--

—

—•

—

--

—

-~

-~

--

--

--

—

f l R 3 Q I 6 U 3

UNITED STATES ENVIRONMENTAL PROTECTION AGENCYREGION HI

841 Chestnut BuildingPhiladelphia. Pennsylvania 19107

SUBJECT: Five-year Review of the DATEKane and Lombard Superfund Site

FROM: Abraham Ferdas, Associate Division Dirfor Superfund Programs

TO: Thomas C. Voltaggio, DirectorHazardous Waste Management Division

EPA has completed a statutory five-year review of the OperableUnit One (OU1) source control remedy at the Kane and LombardSuperfund site in Baltimore, Maryland. The OU1 remedy consistsof the following components: a soil-bentonite slurry wall andmultilayer RCRA cap; a ground water extraction system; a groundwater monitoring system; and institutional controls. This five-year review of the OU1 remedy included: a review of the ROD, thesite Maintenance and Management Manual, and maintenance andmonitoring reports; site inspections; and limited data gathering.

The major conclusions and recommendations presented in theattached Five-year Review Report are as follows: (1) the remedyremains effective in protecting human health and the environment;(2) the cap and slurry wall are functioning as designed; however,minor restoration of the topsoil and vegetative layers of the capis necessary in order to ensure that the containment system willremain intact; (3) the ground water extraction system hassubstantially dewatered the first water-bearing zone within theslurry wall boundaries; however, continued monitoring of thedewatering process is required to ensure that an inward hydraulicgradient will be timely established and maintained across theslurry wall; (4) institutional controls are in place; however,regular maintenance of the perimeter fence is required in orderto ensure that the controls remain effective; and (5) becausehazardous substances, remain at the site above levels that allowfor unlimited use and unrestricted exposure, another five-yearreview must be completed no later than April 30, 1999.

I recommend that you sign the attached Five-year Review Report.

AR30I6I4U