UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION III
STATEMENT OF BASIS
FORMER GENERAL MOTORS CORPORATION
BALTIMORE ASSEMBLY PLANT
AREAS A, B-2, B-4, C-l AND D
2122 BROENING HIGHWAY
BALTIMORE, MARYLAND
EPA ID NO. MDD003091972

CONCURRENCES

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TABLE OF CONTENTS

SECTION	PAGE

I.	Introduction		2

II.	Facility Background	3

III.	Summary of the Environmental History	5

IV.	Media Cleanup Objectives	13

V.	Summary of EPA's Proposed Remedy	14

VI.	Evaluation of EPA's Proposed Decision			18

VII.	Environmental Indicators		19

VIII.	Financial Assurance	19

IX.	Public Participation	20

I.	Introduction

The United States Environmental Protection Agency, Region 3 ("EPA") has prepared this
Statement of Basis ("SB") to solicit public comment on its proposed remedy for Areas A and D
and Sub-parcels B-2, B-4 and C-l at the Former General Motors Corporation ("GM") Baltimore
Assembly Plant Facility (the "Facility" or "Site") located at 2122 Broening Highway in
Baltimore, Maryland. At a later time, EPA will be soliciting comments on a proposed remedy
for the remaining portions of the Facility in a separate SB which will also be subject to 30-day
public comment period. Each Area and Sub-parcel addressed in this SB is described in Section
II, below, and EPA's proposed remedy for each of these areas and sub-parcels is described in
detail in Section V, below. This SB highlights key information relied upon by EPA in proposing
each remedy.

The Facility is subject to EPA's Corrective Action Program under the Solid Waste
Disposal Act, as amended, commonly referred to as the Resource Conservation and Recovery
Act ("RCRA"), 42 U.S.C. Sections 6901 et seq. The Corrective Action Program requires that
facilities subject to certain provisions of RCRA investigate and address releases of hazardous
waste and hazardous constituents, usually in the form of soil or groundwater contamination, that
have occurred at or from their property.

EPA is providing a 30-day public comment period on this SB. EPA may modify its
proposed remedy based on comments received during this period. After evaluating the public's
comments, EPA will announce its selection of a final remedy for each Area and Sub-parcel
addressed in this SB in a Final Decision and Response to Comments (Final Decision). The Final
Decision will address all significant comments received. If, on the basis of such comments or

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other relevant information, significant changes are proposed to be made to the corrective
measures identified by EPA in this SB, EPA may seek additional public comments.

This SB summarizes information that can be found in greater detail in the Administrative
Record ("AR") for the Facility. The AR is available for public review at the EPA Region III
office, the address of which is provided in Section IX, below. In addition, information about the
Corrective Action Program, as well as a fact sheet for the Facility can be found by navigating
http:/ / www, epa. go v/ree3 wcmd/correctiveaction.htm.

II. Facility Background

The Facility is located at 2122 Broening Highway in Baltimore, Maryland. The
approximate 182-acre Site is bordered by Holabird Avenue and residential land to the north;
Broening Highway to the east; Keith Avenue and Norfolk Southern Railroad to the south; and,
Norfolk Southern Railroad yard and other commercial properties to the west. The Facility is
zoned for industrial use.

The Facility primarily housed GM automobile assembly operations from 1936 to 2005.
GM's operations consisted of four major production departments: Body, Paint, Trim, and
Chassis. Each department consisted of a main conveyor line supported by sub-assembly
operations contributing to the assembly of a complete vehicle.

Duke Baltimore LLC ("Duke") purchased the Facility from GM in January 2006. Duke
subsequently demolished all existing buildings and structures and is currently redeveloping the
Site to include over 2,500,000 square feet of commercial and industrial buildings to be used for
bulk distribution, light manufacturing, and research and development. To date, over 450,000
square feet of commercial and industrial buildings have been constructed.

On February 22, 2006, Duke entered into a Facility Lead Agreement ("FLA") with EPA
to address RCRA corrective action at the entire Facility. Duke also assessed the Facility under
the Maryland Department of the Environment's Voluntary Cleanup Program ("VCP") in order to
obtain a Certificate of Completion ("COC") under the VCP. For purposes of redevelopment, the
Facility has been divided into four areas designated as Area A, Area B, Area C, and Area D,
respectively. With this SB, EPA is proposing remedies for Areas A and D; two parcels of Area
B, designated as Sub-parcels B-2 and B-4; and, a parcel of Area C, designated as Sub-parcel C-l.
A map identifying the location of the site, in addition to a site plan depicting the location of each
Area and Sub-parcel is attached hereto as Figures 1 and 2, respectively.

Below is a description of the historical use and current condition of Areas A and D, and
Sub-parcels B-2, B-4 and C-l.

Area A — Former Anchor Motor Freight Facility - Ward 26, Section 1, Block 6871-C, Lot 1

Area A covers approximately 35.35 acres in the northernmost portion of the Facility.
Originally, Area A was part of Fort Holabird and was owned and operated by the Department of
Defense to house military personnel. GM acquired Area A in 1972 and leased it to Anchor

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Motor Freight ("AMF") which provided trucking services to GM for distribution of GM vehicles.
The southern half of Area A was used for truck parking and the northern half was used for truck
refueling, maintenance and repair. Two former underground storage tank ("UST") farms and a
fueling area were located on the northern half of Area A, which were replaced by an
aboveground storage tank ("AST") farm and a new fueling area. Structures present on the
northern half of Area A included a truck maintenance/office building and a truck wash building.
Since Duke purchased the Facility, both buildings have been demolished and all USTs and ASTs
in Area A have been removed. Area A is currently vacant and undeveloped. The current address
for Area A is 6000 Holabird Avenue, Baltimore, MD 21224.

Sub-parcels B-2 and B-4 - Former American Standard Property - Ward 26, Section 1, Block
6874-A, Lots 2 &3

Sub-parcels B-2 and B-4 are located within Area B. Area B covers approximately 52.43
acres and is located to the north of GM's former Main Assembly Building (i.e., Area C). In
1971, GM acquired Area B from American Standard, formerly known as the American Radiator
and Standard Sanitary Corporation. American Standard manufactured bathroom fixtures, such as
sinks and bathtubs, and operated an iron sand-form foundry, enamel application shop, cleaning
houses, machine shop, acetylene generation house, oil storage and distribution facilities, USTs,
ASTs, warehouses, and office space at the Facility. All American Standard buildings were
demolished in 1974, except for a warehouse which GM subsequently used for tire storage.

Sub-parcel B-2 encompasses approximately 8.02 acres in the southeast portion of Area B
and was mainly used by GM as an access driveway into the former Main Assembly Building; a
parking area (North Employee Parking Lot); temporary office/construction trailer storage, and a
guard shack with an attached aerial walkway into the Main Assembly Building. Following
closure of the Facility, these structures were demolished and/or removed. Duke redeveloped
Sub-parcel B-2 which now includes the newly constructed Building 118A (also referred to as
Building B-2). The address for Sub-parcel B-2 is 5901 Holabird Avenue, Baltimore, MD 21224.

Sub-parcel B-4 encompasses 18.03 acres in the western portion of Area B and was mainly
used by GM as a parking area for new vehicles awaiting shipment/distribution. As part of its
redevelopment activities, Duke constructed Building 342 (also referred to as Building B-4) on
Sub-parcel B-4. The address for Sub-parcel B-4 is 5003 Holabird Avenue, Baltimore, MD
21224.

Sub-Parcel C-l — Former GM Main Assembly Plant - Ward 26, Section 1, Block 6874-A, Lot 4

Sub-parcel C-l is located within Area C. The Area C property covers approximately
81.33 acres. It consisted mainly of GM's Former Main Assembly Building. The oldest portions
of the Main Assembly Plant building were constructed on vacant land in 1934. The building
originally consisted of two plants, the Fisher Body Plant to the south and the Chevrolet Assembly
Plant to the north. The two plants were consolidated into the Main Assembly Building and were
gradually expanded north to the CSX railroad tracks and west to Quail Street between 1960 and
1982. Due to its size, Area C was divided into two investigative areas, Area C-l and Area C-2,
for the RCRA Facility Investigation ("RFI") conducted by Duke. Subsequent to the completion

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of the RFI, Duke further subdivided Area C-l and created Sub-parcel C-l for purposes of
redevelopment. EPA's proposed remedy is for Sub-parcel C-l. For clarity, a figure depicting
Sub-parcel C-l is attached to this document as Figure 3.

Sub-parcel C-l covers approximately 13.41 acres and is located within the northwest
portion of Area C-l. Area C-1 included the following structures that were peripheral to the
former Main Assembly Building: Power House, Pump House, Driveaway Building, Storage
Building (formerly called the Weld Destruct Building) for unspecified materials, Central
Wastewater Treatment Plant (WWTP), UST and AST Tank Farms, Training Facility, and Sealer
Building. These structures were all of slab-on-grade, brick and concrete block construction.
Subsequent to Duke acquiring the Facility, all of the buildings in Area C-l were demolished.
Sub-parcel C-l was purchased by Merchant Quail Properties, LLC from Duke in June 2008 and
is currently operated as a refrigerated warehouse. The address for Sub-parcel C-l is 4851
Holabird Avenue, Baltimore, MD 21224.

AreaD - Former Fort Holabird Property - Ward 26, Section 1, Block 6920, Lot 1

Area D covers approximately 20 acres and is bounded to the north by CSX Railroad; to
the south by Keith Avenue; to the east by Colgate Creek and FILA sportsware facility; and, to the
west by Broening Highway. Fort Holabird occupied Area D until 1979 and on-site structures
included the No. 2 Boiler Plant, Post Engineer Yard, offices, the Army Intelligence School, a
small gymnasium, storage buildings, and barracks. All former Fort Holabird structures were
demolished in 1971 by the Department of Defense. When GM acquired the land in 1979, the
basements of these buildings had already been filled with building debris, and the area was
subsequently paved and converted to GM's former East Employee Parking Lot. The Maryland
Port Authority, an agency of the State of Maryland, purchased Area D from Duke in December
2008. The Maryland Port Authority is currently using Area D for port-related activities such as
security checkpoint, trailer storage, and shipping container repair. The newly assigned address
for Area D is 2001 Broening Highway, Baltimore, MD 21224.

III. Summary of Environmental History

In May 2006, Duke submitted to EPA and MDE a Phase I Environmental Site
Assessment ("Phase I") which identified those areas at the Facility requiring further investigation
under a RCRA Facility Investigation Work Plan ("RFI Work Plan"). Areas requiring additional
investigation were designated as Recognized Environmental Conditions ("RECs") or Areas of
Interest ("AOIs").

In August 2006, EPA and MDE approved Duke's RFI Work Plan which summarized
historical data and proposed additional investigative activities for the RECs and AOIs located in
Areas A, B, C, and D. Duke completed the investigative activities outlined in the RFI Work Plan
between August and November 2006. The results of the investigations for Area A are
summarized in an EPA and MDE-approved April 2007 RCRA Facility Investigation/Phase II
Environmental Site Assessment and Focused Corrective Measures Study (Revision 1.0) Report
("RFI/Phase II Report"). The results of the investigations for Area B are summarized in an EPA
and MDE-approved March 2007 RFI/Phase II Report. The results of the investigations for Area

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C are summarized in an EPA and MDE-approved June 2007 RFI/Phase II Report. The results of
the investigation for Area D are summarized in an EPA and MDE-approved July 2007 RFI/Phase
II Report.

A. Summary of Environmental Investigations and RFI/Phase II Reports
1. Soil Investigation

Facility soils were analyzed for a total of 176 chemicals, including volatile organic
compounds ("VOCs"), semi-volatile organic compounds ("SVOCs"), polycyclic aromatic
hydrocarbons ("PAHs"), polychlorinated biphenyls ("PCBs"), and metals. The soil analytical
results were screened by Duke for chemicals of potential concern ("COPCs") using the lower of
U.S. EPA Region 3 Risk Based Concentrations ("RBCs") table (April 11, 2006) and MDE Non-
Residential Cleanup Levels. The RBCs for industrial soil and the MDE Non-Residential
Cleanup Levels were selected for screening purposes based on the existing and future land use of
the Facility as industrial and/or commercial.

a.	Area A

A total of sixty-nine (69) chemicals were detected in soils at Area A; however, only three
(3) of those chemicals were detected at concentrations exceeding their respective RBCs and/or
MDE Non-Residential Soil Cleanup values. Those three (3) chemicals were classified as COPCs
and evaluated for a direct contact with soil exposure pathway. For a summary of chemicals,
including COPCs, detected in soils at Area A, please refer to Table 2-2 (presented in the Human
Health Risk Assessment ("HHRA") provided as Appendix A of the RFI/Phase II Report for Area
A) included as Attachment 1 to this SB.

b.	Area B

A total of sixty-nine (69) chemicals were detected in soils at Area B; however, only
eleven (11) of those chemicals were detected at concentrations exceeding their respective RBCs
and/or MDE Non-Residential Soil Cleanup values and, therefore, classified as COPCs. Each of
the eleven (11) COPCs were evaluated for exposure based on a direct contact with soils pathway
as discussed in Section III.A.3, below. For a summary of chemicals, including COPCs, detected
in soil for Area B, please refer to Table 2-1 (presented in the HHRA provided as Appendix A of
the RFI/Phase II Report for Area B) included as Attachment 2 to this SB.

c.	Area C. Sub-parcel C-l

There were no COPCs identified in soils at Sub-parcel C-l.

d.	AreaD

A total of thirty-two (32) chemicals were detected in soils at Area D; however, only three
(3) of those chemicals were detected at concentrations exceeding RBCs or MDE Non-Residential
Soil Cleanup values and, therefore, classified as COPCs. Each COPC was evaluated for

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exposure based on a direct contact with soils pathway as discussed in Section III.A.3, below. For
a summary of chemicals, including COPCs, detected in soil for Area D, please refer to Table 2-2
(presented in Appendix A - Human Health Risk Assessment for Area D) included as Attachment
3 to this SB.

2. Groundwater Investigation

Duke has installed 36 groundwater monitoring wells across the Site and, for purposes of
investigation, has divided the groundwater into three major zones - the shallow water-bearing
zone, the deep water-bearing zone, and the bottom of the deep water-bearing zone.

Shallow groundwater under the Facility is contained in the Patapsco Aquifer. Across the
Facility, shallow groundwater ranges from approximately 0.5 to 16 feet below ground surface
and generally flows in an overall southeasterly direction toward Colgate Creek. Colgate Creek, a
tidally-influenced tributary of the Patapsco River, is the closest body of water located
approximately 200 feet southeast of Area D. The Patapsco Aquifer contains chloride
contamination resulting from salt water intrusion, in addition to industrial contamination
resulting from historic industrial operations in the region.

Groundwater in the deep water-bearing zone beneath the Facility is contained in the
Patuxent Aquifer. Groundwater in this zone underlying the eastern portion of the Facility flows
east, towards Colgate Creek with an average gradient of 0.0024 feet/foot, while groundwater in
the deep water-bearing zone at the western portion of the Facility flows south, towards Keith
Avenue with a hydraulic gradient of 0.005 feet/foot. Groundwater flow at the bottom of the deep
zone is to the south-southwest, which is similar to the flow in the top of the deep zone for the
same area of the Facility. As with the Patapsco Aquifer, the Patuxent aquifer is contaminated
with chloride and industrial contaminants.

The Facility and surrounding area are serviced with potable water from the Baltimore
City public water supply system. Baltimore City requires connection to the public water supply
system where such a system is available. Baltimore City uses surface water from local rivers,
and does not use groundwater, as its source of potable water. Furthermore, as part of the EPA
and MDE-approved June 2007 RFI/Phase II Report, Duke identified no potable wells within one
mile of the Facility.

Groundwater beneath the Facility was analyzed for a total of 176 chemicals including
VOCs, SVOCs, PAHs, PCBs, and metals. Although the Facility is located within an area where
groundwater is not used, and will not be used in the foreseeable future as a source for drinking
water, concentrations of COPCs in groundwater were screened against drinking water criteria.
For each COPC, the lower value between the U.S. EPA Region 3 Tap Water RBC (April 11,
2006) or the Maximum Contaminant Levels ("MCLs") promulgated at 40 C.F.R. Part 141
pursuant to Section 1412 of the Safe Drinking Water Act, 42 U.S.C. Section 300g-l, was
selected as the screening criterion for groundwater. In some cases, neither an RBC nor a MCL
was available for a detected chemical, and, as a result, detections of these chemicals were
evaluated via the selection of a surrogate screening concentration. For example, the RBC for
isopropylbenzene was used as a screening concentration for rc-propylbenzene, jr?-isopropyltoluene

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and sec-butylbenzene. In addition, the chemicals identified as COPCs were screened against
their respective U.S. EPA groundwater-to-indoor air screening criterion to evaluate the potential
for volatile emissions to migrate to indoor air (i.e., vapor intrusion).

a.	Area A

A total of fifty-one (51) chemicals were detected in groundwater in Area A. Of the
detected chemicals, fifteen (15) chemicals were identified as COPCs with respect to the
screening criteria. One VOC was detected at a concentration exceeding both its potable use and
U.S. EPA groundwater-to-indoor screening criteria, and six (6) VOCs were each detected at a
maximum concentration above their respective drinking water screening level. Most of the
VOCs were detected in water samples taken from perched water in the area of the former tank
pits. For a summary of chemicals, including COPCs, detected in groundwater for Area A, please
refer to Table 2-4 (presented in the HHRA provided as Appendix A of the RFI/Phase II Report
for Area A) included as Attachment 4 to this SB.

b.	Area B

A total of fifty-two (52) chemicals were detected in groundwater in Area B. Of the
detected chemicals, twenty-one (21) chemicals were identified as COPCs with respect to the
screening criteria. Seventeen (17) chemicals were detected at concentrations above their
respective RBC and/or MCL. In addition, the maximum concentrations of 3 COPCs exceeded
their respective RBC and/or MCL as well as their U.S. EPA groundwater-to-indoor air screening
criterion. Lead was also detected at a concentration above its RBC and/or MCL. For a summary
of chemicals, including COPCs, detected in groundwater for Area B, please refer to Table 2-2
(presented in the HHRA provided as Appendix A of the RFI/Phase II Report for Area B),
included as Attachment 5 to this SB.

c.	Area C. Sub-parcel C-l

There were no COPCs identified in the groundwater below Sub-parcel C-l.

d.	AreaD

A total of thirty-six (36) chemicals were detected in groundwater in Area D. Of the
detected chemicals, nine (9) chemicals were identified as COPCs in groundwater in Area D. In
addition to the chemicals identified as COPCs for the evaluation of direct contact exposures, all
VOCs detected in groundwater at Area D were identified as COPCs for evaluation of the
potential for volatile emissions to migrate to indoor air (i.e., vapor intrusion). For a summary of
chemicals detected in groundwater for Area D, including COPCs, please refer to Table 2-4
(presented in the HHRA provided as Appendix A of the RFI/Phase II Report for Area D)
included as Attachment 6 to this SB.

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3. Human Health Risk Assessment and Evaluation of Exposure
Pathways

A Human Health Risk Assessment ("HHRA") was completed for Areas A, B, C and D to
determine whether site-related contaminants pose an unacceptable risk to human health assuming
industrial and/or commercial use of the Facility. The HHRA did not include an evaluation for
residential use because the reasonably anticipated land use for the entire Facility is industrial
and/or commercial. The exposure pathways assessed include VOC emissions from soil to indoor
air; VOC emissions from groundwater to indoor air; direct contact with soil; and, direct contact
with groundwater (construction/excavation workers only). The reference location of the HHRA
report for each redevelopment Area is as follows:

Area A - Appendix A of the April 2007 RFI/Phase II Report for Area A.

Area B - Appendix A of the March 2007 RFI/Phase II Report for Area B.

Area C - Appendix A of the June 2007 RFI/Phase II Report for Area C.

Area D - Appendix A of the July 2007 RFI/Phase II Report for Area D.

a. Area A

1)	Soil to Indoor Air Pathway

Three (3) COPCs, methylcyclohexane, 1,2,4-trimethylbenzene and 1,3,5-
trimethyllbenzene, were detected in soils at Area A at concentrations which posed a potential
unacceptable human health risk based on the soil to indoor air pathway. Please refer to Section
III.B.l., below, for a summary of remedial activities that were conducted in Area A to address
those soils that posed a potential unacceptable human health risk.

2)	Groundwater to Indoor Air Pathway

None of the seven (7) VOCs detected in groundwater samples collected from Area A
were detected at a concentration that would pose a potential unacceptable human health risk
based on the groundwater to indoor air pathway.

3)	Direct Contact with Soils Pathway

The HHRA concluded that no potential unacceptable human health risks are posed by
direct contact with soils in Area A by the three (3) potential receptor populations (i.e., on-site
worker, child and youth visitor/trespasser, and construction/excavation worker).

4)	Direct Contact with Groundwater Pathway

The quantitative evaluation for direct contact with groundwater in Area A by the
construction/excavation worker receptor population did not indicate a potential unacceptable
human health risk. No other potentially complete exposure pathways pertaining to Area A
groundwater exist. Based upon these results, groundwater in Area k is not considered a medium
of concern with respect to a direct contact pathway.

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b. Area B. Sub-parcels B-2 and B-4

1)	Soil to Indoor Air Pathway

Two (2) VOCs, tetrachloroethene and trichloroethene, were detected at concentrations
that exceeded their respective indoor air decision levels at soil sampling location HMW3. In
addition, the soil sample collected from sampling location 7B6 (0 feet to 2 feet below ground
surface) was determined to be a "hot spot" in accordance with MDE guidance in that it contained
concentrations of the following Polycyclic Aromatic Hydrocarbons ("PAHs"):
benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenz(a,h)anthracene, and
indeno(l,2,3-cd)pyrene. Please refer to Section III.B.2, below, for a summary of remedial
activities that have been taken to address those soils in Area B that posed a potential
unacceptable human health risk.

2)	Groundwater to Indoor Air Pathway

None of the twelve (12) VOCs that were detected in groundwater samples collected from
Area B were reported at a concentration which posed a potential unacceptable human health risk
based on the groundwater to indoor air pathway.

3)	Direct Contact with Soils Pathway

At several sampling locations, lead concentrations were detected above the U.S. EPA lead
cleanup level of 1,000 mg/kg for industrial properties. In addition, soils at two areas also
exhibited leachable concentrations of lead in excess of the Toxicity Characteristic Leaching
Procedure 1 ("TCLP") regulatory limit of 5 parts per million ("ppm"). Those two areas were
centered around sampling locations HSB-8 (0 feet to 2 feet below ground surface) and HSBB-13
(0 feet to 2 feet below ground surface). Any soil removed from those areas during
redevelopment activities must be managed as a hazardous waste under RCRA Subtitle C because
it exhibits the toxicity characteristic for lead under TCLP.

The HHRA concluded that exposure to lead in soil may pose a potential unacceptable
human health risk to the construction/excavation worker receptor population. Please refer to
Section III.B.2, below, for a summary of remedial actions that have been conducted to eliminate
potential exposure pathways to soils remaining in Area B by the on-site worker, child/youth
visitor and/or trespasser populations.

4)	Direct Contact with Groundwater Pathway

The HHRA concluded that exposure to multiple COPCs in groundwater may pose a
potential unacceptable risk to the construction/excavation worker receptor population. As a
result, in addition to required soil management activities described in Section III.B.2, below, an
EPA- and MDE-approved Risk Management Plan ("RMP") was implemented to address

1 EPA uses the Toxicity Characteristic Leaching Procedure (TCLP) to identify those wastes which might result in
contamination of groundwater if improperly managed. TCLP is designed to determine the mobility of both organic
and inorganic contaminants present in liquid, solid, and multiphasic wastes.

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potential unacceptable hazards posed by direct contact exposures to groundwater by the
construction/excavation worker receptor population.

c.	Area C. Sub-parcel C-l

As previously noted, no COPCs were identified in soils or groundwater for Sub-parcel C-
1. Therefore, it was concluded that the complete exposure pathways to soil and groundwater
within Sub-parcel C-l do not pose a potential unacceptable human health risk to the future
receptor populations evaluated by the HHRA.

d.	AreaD

1)	Soil to Indoor Air Pathway

No COPCs were detected in soils at concentrations that would pose a potential
unacceptable human health risk based on the soil to indoor air pathway.

2)	Groundwater to Indoor Air Pathway

No COPCs were detected in groundwater at concentrations that would pose a potential
unacceptable human health risk based on the groundwater to indoor air pathway.

3)	Direct Contact with Soils Pathway

No COPCs were detected in soils at concentrations that would pose a potential
unacceptable human health risk based on direct contact with soils in Area D for any of the
potential future receptor populations.

4)	Direct Contact with Groundwater Pathway

No COPCs were detected in groundwater at concentrations that would pose a potential
unacceptable human health risk to the construction/excavation worker receptor population from
direct contact exposures to groundwater.

B. Summary of Remedial Activities Completed

The following summarizes the remedial activities conducted at Areas A and D and Sub-
parcels B-2, B-4 and C-l at the Facility:

1. Area A

In accordance with an EPA and MDE-approved Response Action Plan for Area A ("Area
A RAP") dated July 26, 2007, Duke excavated soils in Area A that exceeded the soil to indoor air
risk-based levels. On October 3, 2007, EPA and MDE acknowledged that the confirmation
sampling results demonstrated that the excavation was complete and that contaminants in the
remaining soils were below their respective soil to indoor air risk-based levels.

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2. Sub-parcel B-2

In accordance with a Response Action Plan for Area B ("Area B RAP"), approved by
EPA and MDE on July 20, 2007, Duke conducted the following activities at Sub-Parcel B-2:

•	Constructed a 118,000 square foot building (Building 118A) and associated paved
parking areas and roadways, and covered green space areas with a minimum of
two feet of clean soil placed over a geotextile marker fabric, thereby eliminating
direct contact exposures to soil by the on-site worker, child and youth visitor.

•	Implemented an EPA and MDE Risk Management Plan ("RMP") to manage
potential direct contact exposures to future construction/excavation workers
during activities conducted after the initial redevelopment. The RMP includes
information about the Facility's environmental conditions, descriptions of
potential risks/hazards associated with soils and groundwater at the site,
documentation of areas with known impacted soil, and descriptions of procedures
required for soil characterization and management. The RMP serves as a record-
keeping device to document that future workers are notified of, and have
acknowledged, the Facility conditions so that appropriate actions can be
conducted. The RMP also provides information related to landscape maintenance
and tree management and the potential risks/hazards associated with soils below
the geotextile marker layer underlying green space areas.

•	Recorded a VCP Certificate of Completion with the City of Baltimore City Land
Records Office in the chain of title for the Facility property that notifies
prospective purchasers that on-Site use of groundwater is prohibited and land use
is restricted to commercial/industrial purposes throughout Area B.

3. Sub-parcel B-4

In accordance with a Response Action Plan for Area B ("Area B RAP"), approved by
EPA and MDE on July 20, 2007, Duke conducted the following activities at Sub-Parcel B-4:

•	Excavated and disposed of soils exhibiting the characteristic of toxicity for lead.
The excavation and disposal activities were completed in May 2007. The results
of confirmatory sampling were submitted to and approved by MDE and EPA.
Based on the confirmatory sampling results, the residual soils do not exhibit the
characteristic of toxicity for lead.

•	Constructed a 342,000 square foot building (Building 342) and associated paved
parking areas and roadways, and covered green space areas with a minimum of
two feet of clean soil placed over a geotextile marker fabric, thereby eliminating
direct contact exposures to soil by the on-site worker, child and youth visitor.

•	Implemented a RMP to manage potential direct contact exposures to future
construction/excavation workers during activities conducted after the initial
redevelopment. The RMP includes information about Facility's environmental
conditions, descriptions of potential risks/hazards associated with soils and
groundwater at the site, documentation of areas with known impacted soil, and
descriptions of procedures required for soil characterization and management.

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The RMP serves as a record-keeping device to document that future workers are
notified of, and have acknowledged, the Facility conditions so that appropriate
actions can be conducted. The RMP also provides information related to
landscape maintenance and tree management and the potential risks/hazards
associated with soils below the geotextile marker layer underlying green space
areas.

• Recorded a VCP Certificate of Completion with the City of Baltimore City Land
Records Office in the chain of title for the Facility property that notifies
prospective purchasers that on-Site use of groundwater is prohibited and land use
is restricted to commercial/industrial purposes throughout Area B.

4.	Sub-parcel C-l

In March 2008, EPA and MDE approved a Response Action Plan for Area C ("Area C
RAP"). Based on the findings presented in the Area C RAP, EPA and MDE determined that no
active remedial activities are required for soil or groundwater within the Sub-parcel C-l.

5.	AreaD

Based on the findings of the EPA and MDE-approved July 2007 RFI/Phase II for Area D,
no active remediation activities were required in Area D.

IV. Media Cleanup Objectives

EPA has identified the following Corrective Action Objectives for soils and groundwater
at the Facility:

A.	Soils

The Corrective Action Objective for soils is to contain the hazardous wastes and
hazardous constituents that remain in place in Areas A and Sub-parcels B-2, B-4 and C-l and
control human and environmental exposure to those hazardous wastes and hazardous
constituents.

B.	Groundwater

EPA's Corrective Action Objectives are to prevent human exposure to contaminants in
the groundwater and to demonstrate that any contaminant plume does not impact nearby surface
water. EPA and MDE discussed groundwater cleanup objectives during the Facility-wide
investigation, taking into consideration that the Patapsco and Patuxent Aquifers have background
conditions that render them unsuitable as a potable source of water. Both the Patapsco Aquifer
(shallow water-bearing zone) and Patuxent Aquifer (deep water-bearing zone) are contaminated
with chloride as a result of salt water intrusion, in addition to industrial contamination from
historical industrial operations in the region. Therefore, the Facility and surrounding area are
serviced with potable water from the Baltimore City public water supply system. Thus, EPA and
MDE concluded that the maximum beneficial use of groundwater at the Facility was as base flow
recharge to Colgate Creek. This determination is supported by data gathered from the thirty-six

13


-------
(36) monitoring wells at the Facility. Such data was used to model groundwater flow beneath the
facility; to demonstrate that the groundwater plume ultimately discharges to Colgate Creek; and,
that concentrations of contaminants are below levels of concern for surface water quality.

V. Summary of Proposed Remedy

A.	Introduction

EPA's proposed remedy is comprised of components which address Areas A and D and
Sub-parcels B-2, B-4 and C-l, and consists of a combination of engineering controls ("ECs") and
institutional controls ("ICs"). ECs are engineered measures, such as caps, fences, treatment
systems, etc., designed to minimize the potential for human exposure to contamination by either
limiting contact with contaminated areas or controlling migration of contamination through
environmental media. ICs are non-engineered instruments such as administrative and/or legal
controls that minimize the potential for human exposure to contamination and/or protect the
integrity of the remedy by limiting land or resource use.

B.	Area A

EPA's proposed remedy for Area A consists of the compliance with and maintenance of
land and resource restrictions. EPA is proposing that the ICs for Area A contain the following
land and resource restrictions:

1)	Area A shall be restricted to commercial and/or industrial purposes and shall not be used
for residential purposes unless it is demonstrated to MDE, in consultation with EPA, that
such use will not pose a threat to human health or the environment or adversely affect or
interfere with the selected remedy and MDE, in consultation with EPA, provides prior
written approval for such use;

2)	Groundwater from Area A shall not be used for any purpose other than to conduct the
operation, maintenance, and monitoring activities required by MDE and/or EPA, unless it
is demonstrated to MDE, in consultation with EPA, that such use will not pose a threat to
human health or the environment or adversely affect or interfere with the selected remedy
and MDE, in consultation with EPA, provides prior written approval for such use; and,

3)	The property owner shall evaluate compliance with the ICs implemented for Area A on a
biennial basis and provide a report documenting the findings of the evaluation to EPA
and MDE.

C.	Sub-parcel B-2

EPA's proposed remedy for Sub-parcel B-2 consists of the inspection, operation and
maintenance of the already constructed ECs, which include:

1) The concrete slab associated with Building 118 A;

14


-------
2)	Paved parking areas and roadways associated with Building 118A; and,

3)	The two feet of clean soil placed over a geotextile marker fabric in green space areas.

These ECs provide cover and eliminate direct contact with contaminated soils. The
inspection, operation and maintenance of the already constructed ECs are already required by the
EPA- and MDE-approved RMP. EPA's proposed remedy requires compliance with the RMP.
In addition, EPA's proposed remedy for Sub-parcel B-2 also includes the compliance with and
maintenance of land or resource restrictions.

EPA proposes that compliance with the RMP and compliance with and maintenance of
land or resource restrictions at Sup-parcel B-2 be implemented through enforceable IC(s) to
include the following elements:

1)	Sub-parcel B-2 shall be restricted to commercial and/or industrial purposes and not be
used for residential purposes unless it is demonstrated to MDE, in consultation with EPA,
that such use will not pose a threat to human health or the environment or adversely affect
or interfere with the selected remedy and MDE, in consultation with EPA, provides prior
written approval for such use;

2)	Groundwater from Sub-parcel B-2 shall not be used for any purpose other than to conduct
the operation, maintenance, and monitoring activities required by MDE and/or EPA,
unless it is demonstrated to MDE, in consultation with EPA, that such use will not pose a
threat to human health or the environment or adversely affect or interfere with the
selected remedy and MDE, in consultation with EPA, provides prior written approval for
such use;

3)	The property owner shall perform all activities at Sub-parcel B-2 in accordance with the
RMP to maintain the integrity and protectiveness of the selected remedy unless it is
demonstrated to MDE, in consultation with EPA, that such activity will not pose a threat
to human health or the environment or adversely affect or interfere with the selected
remedy and MDE, in consultation with EPA, provides prior written approval for such use.
The RMP shall be deemed to be incorporated into the IC and be made an enforceable part
thereof; and,

The property owner shall evaluate compliance with ICs implemented for Sub-Parcel B-2
on a biennial basis and provide a report documenting the findings of the evaluation to
EPA and MDE.

D. Sub-parcel B-4

EPA's proposed remedy for Sub-parcel B-4 consists of the inspection, operation and
maintenance of the already constructed ECs, which include:

1) The concrete slab associated with Building 342;

15


-------
2) Paved parking areas and roadways associated with Building 342; and,

3) The two feet of clean soil placed over a geotextile marker fabric in green space areas.

These ECs provide cover and eliminate direct contact with contaminated soils. The
inspection, operation and maintenance of the already constructed ECs are already required by the
EPA and MDE- approved RMP. EPA's proposed remedy requires compliance with the RMP. In
addition, EPA's proposed remedy for Sub-parcel B-4 also includes the compliance with and
maintenance of land or resource restrictions.

EPA proposes that compliance with the RMP and compliance with and maintenance of
land or resource restrictions at Sup-parcel B-4 be implemented through enforceable ICs to
include the following elements:

1)	Sub-parcel B-4 shall be restricted to commercial and/or industrial purposes and not be
used for residential purposes unless it is demonstrated to MDE, in consultation with EPA,
that such use will not pose a threat to human health or the environment or adversely affect
or interfere with the selected remedy and MDE, in consultation with EPA, provides prior
written approval for such use;

2)	Groundwater from Sub-parcel B-4 shall not be used for any purpose other than to conduct
the operation and maintenance and monitoring activities required by MDE and/or EPA,
unless it is demonstrated to MDE, in consultation with EPA, that such use will not pose a
threat to human health or the environment or adversely affect or interfere with the
selected remedy and MDE, in consultation with EPA, provides prior written approval for
such use;

3)	The property owner shall perform all activities at Sub-parcel B-4 in accordance with the
RMP to maintain the integrity and protectiveness of the selected remedy unless it is
demonstrated to MDE, in consultation with EPA, that such activity will not pose a threat
to human health or the environment or adversely affect or interfere with the selected
remedy and MDE, in consultation with EPA, provides prior written approval for such use.
The RMP shall be deemed to be incorporated into the IC and be made an enforceable part
thereof; and,

4)	The property owner shall evaluate compliance with institutional controls implemented for
Sub-Parcel B-4 on a biennial basis and provide a report documenting the findings of the
evaluation to EPA and MDE.

E. Sub-parcel C-l

EPA's proposed remedy for Sub-parcel C-l consists of the compliance with and
maintenance of land and resource use restrictions to be implemented through enforceable ICs.
The ICs for Sub-parcel C-l will contain the following elements:

1) Sub-parcel C-l shall be restricted to commercial and/or industrial purposes and shall not

16


-------
be used for residential purposes unless it is demonstrated to MDE, in consultation with
EPA, that such use will not pose a threat to human health or the environment or adversely
affect or interfere with the selected remedy and MDE, in consultation with EPA, provides
prior written approval for such use;

2)	Groundwater from Sub-parcel C-l shall not be used for any purpose other than to conduct
the operation and maintenance and monitoring activities required by MDE and/or EPA,
unless it is demonstrated to MDE, in consultation with EPA, that such use will not pose a
threat to human health or the environment or adversely affect or interfere with the
selected remedy and MDE, in consultation with EPA, provides prior written approval for
such use; and,

3)	The property owner shall evaluate compliance with ICs implemented for Sub-Parcel C-l
on a biennial basis and provide a report documenting the findings of the evaluation to
EPA and MDE.

Sampling results from the Facility-wide investigation demonstrate that Sub-parcel C-l
has no COPCs above EPA Region 3 industrial standards. Therefore, ECs are not proposed for
Sub-parcel C-l.

F. Area D

EPA's proposed remedy for Area D consists of the compliance with and maintenance of
land and resource use restrictions to be implemented through enforceable IC(s). The IC(s) for
Area D will contain the following elements:

1)	Area D shall be restricted to commercial and/or industrial purposes and shall not be used
for residential purposes unless it is demonstrated to MDE, in consultation with EPA, that
such use will not pose a threat to human health or the environment or adversely affect or
interfere with the selected remedy and MDE, in consultation with EPA, provides prior
written approval for such use;

2)	Groundwater from Area D shall not be used for any purpose other than to conduct the
operation and maintenance and monitoring activities required by MDE and/or EPA,
unless it is demonstrated to MDE, in consultation with EPA, that such use will not pose a
threat to human health or the environment or adversely affect or interfere with the
selected remedy and MDE, in consultation with EPA, provides prior written approval for
such use; and,

3)	The property owner shall evaluate compliance with institutional controls implemented for
Area D on a biennial basis and provide a report documenting the findings of the
evaluation to EPA and MDE.

Sampling results from the Facility-wide investigation demonstrate that Area D has no
COPCs above EPA Region 3 industrial standards. Therefore, ECs are not proposed for Area D.

17


-------
G. Implementation

EPA proposes to implement the final remedy for Areas A and D and Sub-parcels B-2, B-4
and C-l through enforceable ICs such as a permit, order and/or an Environmental Covenant
pursuant to the Maryland Uniform Environmental Covenants Act, Maryland Environment Code,
Sections 1-801 to 1-815 ("UECA") to be recorded with the deed for the Facility property. Duke
will be required to provide a coordinate survey as well as a metes and bounds survey of Areas A
and D and Sub-parcels B-2, B-4 and C-l and the Facility boundary. For properties located
outside of the Facility boundary that are impacted by Facility-related contamination, EPA and/or
MDE will require that Duke use its best efforts to obtain an Environmental Covenant from any
such property owners.

If the Facility owner or subsequent owners fail to meet their obligations under the ICs or
if EPA and/or MDE, in its sole discretion, deems that additional ECs or land and/or resource
restrictions are necessary to protect human health or the environment, EPA and/or MDE has the
authority to require and enforce such additional ECs or land and/or groundwater use restrictions.

VI. Evaluation of EPA's Proposed Decision

This section provides a description of the criteria EPA uses to evaluate proposed
remedies under the Corrective Action Program. The criteria are applied in two phases. In the
first phase, EPA evaluates three criteria, known as Threshold Criteria. In the second phase, EPA
uses seven Balancing Criteria to select among alternative solutions, if more than one is proposed.
The Facility has demonstrated that the current conditions meet the Threshold Criteria established
by EPA. Because EPA is not selecting among alternatives, a complete evaluation of the
Balancing Criteria is not necessary.

The following is a summary of EPA's evaluation of the Threshold Criteria:

A. Protect Human Health and the Environment

EPA's proposed remedies for Areas A and D and Sub-parcels B-2, B-4, and C-l protect
human health and the environment by eliminating, reducing, or controlling potential
unacceptable risk through the implementation and maintenance of ECs and ICs.

ECs, including the building slab, paved parking areas, roadways, and clean cover, are
already in place at Sub-parcels B-2 and B-4 and have eliminated potential human exposure to
contaminated soils. Furthermore, to prevent any exposure to contaminated soil throughout Sub-
parcels B-2 and B-4 in the future, the property owner will be required to maintain the integrity of
the building slab and paved parking areas and roadways at all times.

EPA is also proposing ICs to prohibit the use of groundwater for potable purposes or any
other use that could result in human exposure and restrict land use to commercial or industrial
purposes throughout Areas A and D and Sub-parcels B-2, B-4 and C-l. Additional ICs proposed
for Sub-parcels B-2 and B-4 also require the implementation of the EPA and MDE -approved
RMP to prevent future exposures to contaminated soil and/or groundwater within these sub-

18


-------
parcels.

B.	Achieve Media Cleanup Objectives

EPA's proposed remedies meet the media cleanup objectives based on assumptions
regarding current and reasonably anticipated land and water resource use(s). The remedy
proposed in this SB is based on the current and future anticipated land use at Areas A and D and
Sub-parcels B-2, B-4 and C-l as commercial or industrial. As such, industrial media cleanup
objectives were selected and the majority of Facility soils contain contaminant concentrations
that are below EPA's industrial soil RBCs. For those areas where contaminants remain in place
above EPA's industrial soil RBCs, ECs and ICs will be maintained and implemented to address
potential direct contact risks.

Although contaminants were detected in groundwater beneath Areas A and D, and Sub-
parcels B-2 and B-4 at concentrations above EPA Tap Water RBCs and/or MCLs, the entire
Facility and surrounding areas are serviced by the City of Baltimore municipal water supply.
Furthermore, MDE and City of Baltimore officials have indicated that the Bureau of Water and
Wastewater supplies water to the Facility and surrounding area, and that no potable use of
groundwater is occurring in the region. Even though the groundwater in the vicinity of the
Facility is not used, and will not be used in the foreseeable future, as a drinking water source,
EPA is proposing to require ICs, such as a permit, enforceable order and/or an environmental
covenant, as necessary, that will prohibit consumptive use of the groundwater.

C.	Remediating the Source of Releases

In all remedy decisions, EPA seeks to eliminate or reduce further releases of hazardous
wastes or hazardous constituents that may pose a threat to human health and the environment.
Duke removed the source of contaminants from the soil in Area A and Sub-parcel B-4, thereby,
eliminating, to the extent practicable, further releases of hazardous constituents from on-site soils
as well as the source of the groundwater contamination. In addition, the soil and groundwater
management procedures will require the proper removal and off-site disposal of contaminated
soils and/or groundwater that are disturbed during any construction/excavation activities
conducted on-Site in accordance with applicable state and federal laws and regulations, thereby
removing the source of contaminants from Facility soils as well as groundwater.

VII.	Environmental Indicators

Under the Government Performance and Results Act ("GPRA"), EPA has set national
goals to address RCRA corrective action facilities. Under GPRA, EPA evaluates two key
environmental clean-up indicators for each facility: (1) Current Human Exposures Under
Control, and (2) Migration of Contaminated Groundwater Under Control. The Facility met both
of these indicators on January 14,2010.

VIII.	Financial Assurance

EPA has evaluated whether financial assurance for corrective action is necessary to

19


-------
implement EPA's proposed remedy at the Facility. Given that EPA's proposed remedy does not
require any further engineering actions to remediate soil, groundwater or indoor air
contamination at this time and given that the costs of implementing institutional controls at the
Facility will be de minimis, EPA is proposing that no financial assurance be required.

Interested persons are invited to comment on EPA's proposed decision. The public
comment period will last thirty (30) calendar days from the date that notice is published in a local
newspaper. Comments may be submitted by mail, fax, e-mail, or phone to Ms. Jeanna R. Henry
at the address listed below.

A public meeting will be held upon request. Requests for a public meeting should be
made to Ms. Jeanna R. Henry at the address listed below. A meeting will not be scheduled
unless one is requested.

The Administrative Record contains all the information considered by EPA for the
proposed decision at this Facility. The Administrative Record is available at the following
locations]:

IX.

Public Participation

U.S. EPA Region III
1650 Arch Street
Philadelphia, PA 19103
Contact: Ms. Jeanna R. Henry (3LC30)
Phone: (215) 814-2820
Fax:(215) 814-3113
Email: henrv.ieannar@epa.gov

Date:

Abraham Ferdas, Director
Land and Chemicals Division
US EPA, Region III

20


-------
Figure 1

Site Location Map

Former General Motors Corporation
Baltimore Assembly Plant


-------
Maryland

Quadrangle Location

Legend

SSSite Boundary

HuU

associates, inc

4900 Parkway Drive	Phone: (513) 459-9677

Suite #100	Fax: (513) 459-9869

Mason, Ohio 45040	www.hullinc.com

©2006, Hull & Associates, inc.

Product* u»tng ArcGIS 8,0	

Phase I Environmental Site Assessment
Former General Motors Corporation
Baltimore Assembly Plant

Site Location Map

2122 Broening Highway
City of Baltimore, Maryland

May 2006

Project Number DUK030
Geodatabase DUK028 mdb
File Name
DUK033_02_Fig0l _SiteLocMap mxd

Figure

1


-------
Figure 2

Site Plan

Former General Motors Corporation
Baltimore Assembly Plant


-------

-------
Figure 3

Sub-parcel C-l

Former General Motors Corporation
Baltimore Assembly Plant


-------
[Holi6iftAv«TuF

Sub-Parcel B-1

Lub-Barcel'ls-S

Sub-Parcel B-3

tSubrf?arcelB.-2;

[SXiKRarcei!G5i

Legend

o Area A

W | Area b

C^Area C
QArea D

Area A: Area Graded and Prepared for Development

Sub-Parcels B-1 and B-3: Area Graded and Prepared for Development

Sub-Parcels B-2 and B-4: Redeveloped With Commercial/Industrial Buildings

Area C: Area Graded and Prepared for Development

Sub-Parcel C-1: Redeveloped With Refridgerated Warehouse Building

Area D: Area Used for Port-Related Activities

Notes:

The aerial photo was acquired through the Microsoft
Virtual Earth Aerial Photography web service. Aerial
photography date not provided. Current site conditions
have been changed since photo was taken.

Former GM Baltimore AasemWy Rant

Site Layout

2122 Broening Highway
Baltimore, Maryland

			


-------
Attachment 1

Table 2-2

Summary of Chemicals Detected in Total Soil in Area A

Site-Specific Human Health Risk Assessment for Area A
Former General Motors Corporation
Baltimore Assembly Plant


-------
SIT^PICIFIC HUMAN HEALTH RISK ASSESSMENT FOR AREA A (REV1580W 1.0
FORMER GENERAL MOTORS CORPORATION
BALTIMORE A5S£MSLV PLANT
2122 BROENINtt HIGHWAY, BALTIMORE. MARYLAND 21??4

TABLE 2-2

SUWMARV OF CHEMICALS DETECTED IN TOTAL SOIL





CASKW

ti&9fiKxr>
ftuSiM
CCWfflfe

Eftreffctfn
fcUtted

	Jn&gL

Mwittel Ol

NtPA#! M

taetftgfcrtfft*

Lb

MaKmufft

fr«mplingfMoiv8 of

t«k>

f&C-Klaitnfti
**i4

cows?

WW/»	 		"""	""""





Acetone



67641

18.2

0.003

36

124

28

HS6A9

Off-2.0

9.20E+04

N

Benzene



71432

2.6

0.001

27

124

22

9(3

10.0"-12.0

5.20E+01

N

2-Butanene (Methyl Ethyl Ketone)



7S933

2.3

0.0009

31

124

25

HSB5

6.0-8.0

6.13E+04

N

Safe on Bssutftde



75150

0.035

0.001

25

124

20

HSB3

10.0-1201

1.02E+04

N

Shioroform



67663

0.004

0.004

1

124

1

HSB3

2.0-4.0"

1.02E+03

N

5te-1.2-Dichloroethene

b

156592

0.002

0.002

1

124

1

SA2

0.0 - 2.0

8.20E+02

N

Sydohecane

e

110627

9.1

0.0048

11

65

17

911

7.51-8.5'

1.1E+06

N

1,2-OibfQffioelh»e (Bhvtene Di bromide)



106934

0.007

0.002

3

92

3

9(3

10.0-120

1.43E+00

N

1,1-Oichiefoethane



75343

0.001

0.001

2

124

2

M2

0.0 - 2.0

204E+O4

N

1,2-Otchlofo«thane



107062

0.15

0.001

7

124

6

9(3

10.0-120

3.14E+01

N

1,2-OtehlemGroDans



78875

0.004

0.001

3

124

2

9(3

10.0-12,0

4.21 E+01

N

Ethylbercene



100414

24.4

0.002

22

124

18

BSBA9

Off-2.0

1.02E+04

N

"WHecan#

d

110543

0.333

0.0303

2

16

13

HS8A11

14.0- 15.ff

1.1E+06

N

Isspropyfeenzene



86828

3.38

0.0068

11

107

10

KSBA9

O.ff - 2.ff

1.0E+O4

N

Melhyl Cvdohexane

c

1OSS72

26

0.004

14

65

22

8(1

7.5" - 9.5'

1.1E+06

N

4-Meihyt-2>Pentanone (Methyl Isebutyt Ketone)

e

108101

0.027

0.002

4

124

3

9H1

e.cr-e.o

6.13E+04

N

Methyl Tert Butyt Ether



1634044

0.018

0.018

1

107

1

8F2

14.0-16.0

7.15E+02

N

tas&ytene Chloride



75092

0.02

0.003

13

124

10

HSB6

6.CT - 8.0

3.82E+02

N

¦4-Propyfberszerie

f

103651

9.87

0.9056

6

42

14

HSBA9

Off-2.0

1.Q2E+04

N

Maehthalene



91203

5

1.4

4

65

6

9F2

20 - 4.ff

204E+03

N

P-teopropyttduene

f

89S76

5.41

0.00804

5

42

12

HSBA9

Off-2.0

1.02E+O4

N

Seo-Bu!yfbenzene

f

135968

2.86

0.00649

5

42

12

HSBA9

O ff - 2.0

1.Q2E+04

N

Tetraehlofoethene



127184

0.009

0.007

2

124

2

9A2

0.0 - 2.0

5.30E-KX)

N

Toluene



108883

17.8

0.0009

23

124

19

HSSA8

6.0-8.0

8.18E+03

N

rriehloroethene



79016

0.003

0.001

2

124

2

8A2

0.0 - 2.0

7.15E+00

N

Trieh&oreftuorem ethane (cfb-11)



75694

0.001

0.001

1

107

1

8A4

8.0-10.0

3.07E+O4

N

1.2,4-Trimethytbenzene

d

86638

88.6

Q.0Q725

9

42

21

HSBA8

O.ff - 2.0

5.11E+03

N

1.33>Trimethvtbenzene

d

108678

37.1

0.0047

6

42

14

HSBA8

O.ff-2.0"

5.11E+03

N

Xylenes. Total



1330207

112

0.001

25

124

20

HSBA9

Off-2.0

2.04E+O4

N

SVOCs







Aeenaphthene





37

6.TO

10

m

h

9F2	1	5TTT3	



	R	

fcoensehthvlene

9

208968

0.178

0.179

1

126

0.8

HS6A18 0.0 - 0.2

6.13E+03

N

Anthraoene



120127

0.51

0.082

7

126

6

SF2

20 - 4.0

3.07E+04

N

Benzo(AWithraeeie



56553

0.96

0.081

4

126

3

9F2

20-4.0

3.92E+00

N

Berao(A)Pvrene



50328

0.823

0.16



125

2

KSBA8

14.0-15.0

3.92E-01

Y

Benz0(B)Fiuerarithene



205992

1.13

0.13

4

125

3

HS6A8

14.0-15.0

3.92E+00

N

Benzo(G.H.!)Pervlene

h

191242

0.688

0.668

1

61

2

HSBA8

14.0-15.0'

3.07i+03

N

Benze
-------
aTftJPBCWC HUMAN HEMTW Rl$K ASSESSMENT FOR AREA A (RCVISON 1.0

FORMER GENERAL MOTORS CORPORATION
BALTIMORE ASSEMBLY PLANT
2122 BROEN3WS HIGHWAY, BALTIMORE. MARYLAND 312W

TA6LE 2*2

SUMMARY OPCHEMJCAL5 D E TEC TED M TOTAL SOIL

(JjWIMlW ("HfcWStf





tt-.'MKKKll

. ;$£*££»& ;
CLnali«eiY>«(i><
NtoymiuKh p&*tAutsswse\^ui^ as s^ffog^|^4- ^

HUH 4 ASSOCIATES. INC
MASON. OHK)

> ft) .?

APRil a00?
DUK036 500 00 JO


-------
Attachment 2

Table 2-1

Summary of Chemicals Detected in Total Soil in Area B

Site-Specific Human Health Risk Assessment for Area B
Former General Motors Corporation
Baltimore Assembly Plant


-------
«TE-SPECIFIC HUMAN HEALTH RISK ASSESSMENT FOR AREAS
FORMER GENERAL MOTORS CORPORATION
BALTIMORE ASSEMBLY PLANT
1122 BROENiNG HIGHWAY. BALTIMORE, MARYLAND 2^234

TAILS 2-1

SUMMARY OF CHEMICAL* DETECTED IN TOTAL SOIL

CSiwMSoi PstcninF Concern



CAS ttegbtry

Canr«-hM*tfocn

im-ta)

kUttboi 0)
Kephrtrt
Dote-tfc



Frequency T

Btff tk-nM)

Le&etton rt
tfaxsitum
Dvtertton

Sam pf fm» krtorv&i of
fficxinwm ttetaeti&tt

ret

Industrial

COPC?



















67641

0.11

0.001

35

104

34

7A1

0.0*- 2.0s

9.2E+04

N

Benzene



71432

0.008

0.0009

14

104

13

HMW1

13.0*-15.0*

5.2E+01

N

Brofrsocne^iane



74839

0.001

0.001



104

1

7A5

0.0" - 2.0*

1.4E+02

N

2-Butanone (Methyl Ethyl Ketone)



78933

0.02

0.001

30

104

29

7F1

0.0*-2.0*

6.1E+04

N

Carton Disulfide



75150

00139

0.001

26

104

25

HSBB3

0.5' - 2.0"

1.0E+04

N

Chlorobenzene



108907

0.91

0.001

5

104

5

HMW1

13.0*- 15.01

2.0E+O3

N

Cyciohexane

b

110827

0 16

0.013

2

62

3

7F1

14.0*- 16.0*

1.1E+06

N

Cis-1,2-Dichloroethene

c

156592

0.01

0.01

1

104

1

7F7

8.0*- 10.0

9.2E402

N

Trans-1,2-DsehSoroetftene



156605

0.0082

0.005

2

104

2

HMW3

5.0*-7.0*

2.0E403

N

Ethytbenzene



100414

0.068

0.002

6

104

6

HMW1

13.0* -15.0"

1.0E+04

N

2-Hexanone

d

591786

0.002

0.002

1

104

1

7I3

0.0 - 2.0*

6.1E+04

N

iodomethane

e

74884

0.00442

0.00442

1

34

3

HSBB12

10.0*-12.0*

1.4E+02

N

Isooroov! benzene (Cumenei



98828

14

0.07

2

96

2

7F1

14.0*- 16.0*

1.0E+O4

N

Methyl Cyciohexane

b

108872

7.3

0.006

3

62

5

7F1

14.0*. 16.0*

1.1E+06

N

Methylene Chloride



75092

0.1

0.0034

5

104

5

7B4

0.0*-20*

3.8E+02

N





91203

4.5

0.08

12

79

15

7C3

8.0*-10.0

2.0E4O3

N

Tetrachloreethene



127184

1.8

0.0034

8

104

8

HMW3

5.0-7.0*

5.3E+00

N

Toluene



108883

0.011

0.001

5

104

5

HMW1

13.0s- 15.0s

8.2E+03

N

1,1,1-Trichioroethane



71556

0.003

0.003

1

104

1

7F4

0.0-2.0

2.9E+04

N

Trichloroethene



79016

0.14

0.14

1

104

1

HMW3

5.0-7.0*

7.2E+00

N

Xylenes, Total



1330207

0.027

0.019

2

104

2

HMW2

15.0- 17.0*

2.0E+04

N

&v6£s



















83329

8

0.67$



m

-16

	^	

6.61 -

UtM

k

Acenaohthytene

t

208968

0.25

0.11

3

112

3

7B6, 7F1

0.0-2.0*

6.1E+03

N

Aoetephenone



98862

0.16

0.16

1

62

2

7F12

0.0"-2.0*

1.0E+04

N

Anthracene



120127

18

0.085

21

112

19

7B6

0.0*-2.0*

3.1E+04

N

ArecSor-1016



12674112

0.073

0.073

1

18

6

7F2

0.0-2.0*

4.1E+01

N

Aroclor-1242



53469219

0.17

0.17

1

18

6

7F1

0.0 - 2.0*

1.4E+O0

N

Arodor-1254



11097691

0.31

0.029

4

18

22

7F2

0.0* - 2.0*

1.4E+00

N

Aroder-1260



11096825

0.2

0.027

6

18

33

7D1

0.0*-2.0*

1.4E+00

N

BenzoCA^Anthracene



56553

52

0.089

32

112

29

7B6

0.0* - 2.0*

3.9E+00

Y

BenzoCAiPyrene



50328

48

0.089

34

112

30

7B6

0.0 - 2.0*

3.9E-01

Y

BenzofBiFtueranthene



205992

60

0.13

32

111

29

7B6

0.0*-2.0*

3.9E+00

Y

BenzofG.H.DPerylene

9

191242

1.4

0.46

3

33

9

HMW2

11.0- 13.0*

3.1E+03

N

Benzo(K)Fluoranthene



207089

32

0.11

28

111

25

7B6

0.0' - 2.0*

3.9E+01

N

Bis(2-EthylhexYl)Phthalate



117817

3.5

0.083

12

94

13

7F1

0.0' - 2.0*

2.0E+O2

N

Butyl benzyl phthalate



85687

4.8

0.089

12

94

13

7F1

0.0 - 2.0*

2.0E+04

N

Carbazofe



86748

7

0.081

11

70

16

7C3

8.0' -10.0s

1.4E+02

N

Chrysene



218019

46

0.11

34

112

30

7B6

0.0-2,0=

3.9E+02

N

di-n-Butvt phthalate



84742

0.8

0.088

7

95

7

7F12

0.0 - 2.0'

1.0E+04

N

Dibenz(A,H)AnthrBeene



53703

5.7

0.077

14

111

13

7B6

0.0 - 2.0

3.9E-01

Y

Dibenzofuran

h

L 132649

3.7

0.14

9

95

S

7C3

8.0-10.0

2.0E+O2

N

Methyl Phthalate



84662

0.23

0.099

6

95

6

7F11

4.0 - 5.0

8.2E+04

N

2,4-Dimethyfphenol



105679

5.8

5.8

1

95

1

7I4

0.0-2.0

2.0E+03

N

Fluoranthene



206440

110

0.091

41

112

37

7B6

0.0 - 2.0

4.1E+03

N





86737

8.4

0.076

17

112

15

7F1

0.0 - 2.0

4.1E+03

N

IndenoC 1.2.3-Cd)Pyrene



193395

15

0.078

26

111

23

7B6

0.0 - 2.0

3.9E+00

Y

2-Methylnaphthalene



91576

45

0.086

14

112

13

7F1

14.0-16.0

4.1E+02

N

4-Methylphenol



106445

0,26

0.095

2

62

3

7I4

0.0 - 2.0

5.1E+02

L N

Naphthalene



91203

4.5

0.08

12

112

11

7C3

8.0-10.0

2.0E+O3

N

HULL t ASSOCIATES, INC.
MASON. OHIO

1 of 2

JANUARY 2007

-------
SITE-SPECIFIC HUMAN HEALTH RISK ASSESSMENT FOR AREA B
FORMER GENERAL MOTORS CORPORATION
BALTIMORE ASSEMBLY PLANT
2122BROEWNG HIGHWAY, BALTIMORE. MARYLAND 21224

TABLE 2-1

SUMMARY OF CHEMICALS DETECTED IN TOTAL SOIL

T(H«r :4»~|\



CAS fli t

-	JSfflSffli—

C-

	

Kumtarttf
Reports!
Dw>etfc

Nd>rtb«i t*

FFKqfJMK) "t

Wft KfoftUOT

$afr>pfBuilttt*r*e vf
AbHrnum fctatbon (K
IXJB*

K6G*
. lAdu$trt&[

CWC?





@7865

0.1

0.1

1

95



7F5

0.0-2.0

2.4E+01

N

Phenanthrene



86018

75

0.087

42

112

38

7B6

0.0--2.0*

3.1E+04

N

Pvrene



129000

87

0.079

45

112

40

7B6

O.ff - 2.0*

3.1E+03

N

2,4,5-Trlchlorophenol



95954

1.1

1.1

1

95

1

7A6

13.0" - 15.0"

1.0E+04

N





















7440360

165

0.48

26

50

52

7A6

0.0?-2.0*

4.1E+01

Y

Arsenic



7440382

19.2

0.93

51

73

70

7A6

0.0 - 2.0*

1.9E+00

Y

Barium



7440393

889

2.2

72

73

99

HSBB13

0.5!-2.0i

2.0E+O4

N

Beryllium



7440417

3.1

3.1

1

39

3

162

7.0 - 9.0*

2.0E+02

N





7440439

39.6

0.29

21

73

29

7A6

O ff - 2.0*

5.1E+01

N

1

H

1

1

18540299

116

2.1

69

73

95

7A6

0.0-2.0

3.1E+02

N

cooait

h

7440484

14.2

0.2

39

39

100

7I4

0.0-2.0

2.0E+03

N

Copper



7440508

453

0.71

39

39

100

7A6

0.0-2.0

4.1E-KJ3

N

Lead

k

7439921

11,800

1.6

70

85

82

7A6

0.0-2.0

1.0E+03

Y

Manganese



7439965

2,670

2.4

39

39

100

7A6

0.0" - 2.0

2.0E+O3

Y

Mercury

1

7439976

0.81

0.0105

36

72

50

7A3

5.5'-7.5'

31E+01

N

Nickel



7440020

98.8

0.32

39

39

100

7I4

0.0- 2.0*

2.0E+03

N

Selenium



7782492

18.2

0.62

9

73

12

HSBB12

0.3"-2.0*

5.1E+02

N

Silver



7440224

10.2

0.43

24

73

33

7A6

0.0 - 2.0

5.1E+02

N

Thallium



7440280

11

0.67

5

39

13

7I4

2.51- 4.5*

7.2E+00

Y

Vanadium



7440622

43.6

1.5

39

39

100

7I3

0.(7 - 2.0*

1.0E+02

N

Zinc



7440666

3,330

3.9

39

39

100

7A6

0.0 -2.0s

3.1E+04

N

NOTES

B	^cconjersse with the RjsSe Evaluation Matrix {HM document DUK033 200 0034 ste}. all norcaremogenic Region HI R&Cs were reduced by a fades" of 10 to account for possible cumulative effects,

b	Hexane was seeded as a surrogate for this compound, however, the RSC for hexera was withdrawn from the RSC Table m October, 2005 This value is the adjusted RBC for Industrial sofi from the Aerii 2005 RBC Table

c	The ApnJ 2006 Region Id RSC for lotal 1,2-tfchioroethene was used as a surrogate for crs-1,2-dichloroethene

d	The April 2006 Regtorr 113 RSC for 2-feufcs^ene was used as a sjirogate for 2-fcexar*Qne

«	The AprS 2006 Regton in RBC for bromemethan# was used as a surrogate for lodomefhane

f	The April 2006 Regwn 111 RBC for acenapftthene was used as a surrogate for acen*>hthylene

9	The April 2006 Region m RBC 1or pynane was used as a surrogate for beru:o
-------
Attachment 3

Table 2-2

Summary of Chemicals Detected in Total Soil in Area D

Site-Specific Human Health Risk Assessment for Area D
Former General Motors Corporation
Baltimore Assembly Plant


-------
SITE-SPECIFIC HUMAN HEALTH RISK ASSESSMENT FOR AREA D
FORMER GENERAL MOTORS CORPORATION
BALTIMORE ASSEMBLY PLANT
2122 BROENING HIGHWAY, BALTIMORE. MARYLAND 21224

TABLE 2*2

SUMMARY Of CHEMICALS DETECTED M TOTAL SOIL

Cltoni* «zf



CAS Registry

fjSaximiim
Deteefed
Concenitstfett

imm

Minimum

Concentration
(<»aM

Brnnlwr of
Reported
Detects

Mumtmot
Sawptes

Frequency of

omstornm

fiftsJmum
Detecfimt

Sampling Interval of
Maximum Detection
(flb9S>

Soir

"

COFC

VOCs



















67641

0021

0.021

1

29

3

8B2

1.0* -2.5'

9.2E+04

N

2-Butanone



78933

002

0 001

7

29

24

8A1

5 0* -7 0

6.1E+04

N

Carbon Disulfide



75150

0002

0 002

1

29

3

8B1

2.5' -4.5'

1.0E+04

N

T richlorofluoromethane



75694

0001

0 001

1

29

3

8A1

50-7 0

3.1E+04

N























120127

0376

0376

1

29

3

HSBD2

0 0-2.0

sTe+04

N

Benzo(A)Anthracene



56553

1.71

0.486

2

29

7

HSBD2

0.0-2 0

3.9E+0O

N

Benzo(A)Pyrene



50328

1 38

0502

2

29

7

HSBD2

0.0-2.0

3.9E-01

Y

Benzo(B)Fluoranthene



205992

1 82

0693

3

29

10

HSBD2

0.0-2.0

3.9E+00

N

Benzo(G. H DPervtene

b

191242

0815

0815

1

21

5

HSBD2

Off-2 01

3.1E+03

N

Benzo(K)Ffuoranthene



207089

0599

0.599

1

29

3

HS8D2

0.0* - 2.0*

3.9E+01

N

Bis(2-EthyIhexyl)Phthalate



117817

0.15

0.15

1

29

3

8A1

1.0- -2.2

2.0E+02

N

Butyl Benzyl Phthalate



85687

1 21

0.554

2

29

7

HMW9A

0.5'-2.0

2.0E+04

N

Chrysene



218019

1.61

0.167

3

29

10

HSBD2

0 0-20

3.9E+02

N

Di-N-Butvl Phthalate



84742

0.394

0.083

6

29

21

HMW9A

0.5' -2.ff

1.0E+04

N

Fluoranthene



206440

3.39

0 199

6

29

21

HSBD2

Off-2.0'

4.1E+03

N

lndeno(1.2.3-cd)pyrene



193395

0.618

0.618

1

29

3

HSBD2

O ff-2.ff

3.9E+00

N

2-Methylnaphthalene



91576

01

0.1

1

29

3

8A1

5 0-70

4.1E+02

N

Phenanthrene

c

85018

1 98

0.145

6

29

21

HSBD2

O.ff -2.ff

3.1E+04

N

Pyrene



129000

327

0.216

5

29

17

HSBD2

O ff-2.ff

3.1E+03

N























7440382

148

1.1

16

29

55

HMW9A

0.5' - 2 ff

1.9E+00

Y

Barium



7440393

121

1.4

28

29

97

HMW11

6ff-8.ff

2.0E+04

N

Cfwornium

d

7440473

29.6

1

22

29

76

HMW11

6.0* - 8.01

3.1E+02

N

Cobalt

e

7440484

5.8

075

8

8

100

8B3

1.0" -2.5'

2.0E+03

N

Copper



7440508

55.6

42

8

8

100

8A1

5ff-7.ff

4.1E+03

N

Lead

t

7439921

113

2.6

14

29

48

HMW9A

0.5' -2.0

1.0E+03

N

Manganese



7439965

156

69

8

8

100

8B3

1.0" -2.5'

2.0E+03

N

Mercury

9

7439976

0.435

0.00966

14

29

48

HSBD1

Off -2 0*

31/10/0.12

Y

Nickel



7440020

132

0.38

8

8

100

8B3

7.ff -9.0*

2.0E+03

N

Silver



7440224

0,65

0.65

1

29

3

HMW11A

0.5' - 2.0*

5.1E+02

N

Thallium



7440280

0.72

0.72

1

8

13

8B3

7ff-9.ff

7.2E+00

N

Vanadium



7440622

27.5

1.3

8

8

100

8A1

Iff-2.2

1.0E+02

N

Zinc



7440666

42 3

10.1

7

8

88

8B3

7.0'- 9.0'

3.1E+04

N

MOTES:

a	In accordance wit' the Risk Evaluation Matrix (Hull document DUK033 200 0034 xis), all noncar&nogenic Region if] RBC.s were reduced by a factor of 10 to account for possible cymulatfve effects

b	The April 2006 Region Dl RBC for pyrerie was used as a surrogate forbenzo(g.h ,>}pery1ene

c	The April 2006 Region F1I RBC for anthracene was used as a surrogate for pheriartthrene

d	The Aprtf 2006 Region Hi RBC for chromium VI was used as a surrogate for chromium tots!

6	The RBC for cob*lt Withdrawn from the RBC TaWe m October, 2005. This value is the adjusted R8C for mdjstnat soil from the April 2005 RBC Tatts

f	Screenwg value is the MDE-recommerrded maximum average value for lead across the exposure unit

g	Mercury was evaluated wrth respect to the RBC for mercuric ehlonde, the RBC for methyimercury and the MDE Non-Residential Soff Cleanup va'ue for total mercury, respectively

HULL & ASSOCIATES. INC
MASON, OHIO

ton

JULY 2007
DUK039.200.0020


-------
Attachment 4

Table 2-4

Summary of Chemicals Detected in Groundwater in Area A

Site-Specific Human Health Risk Assessment for Area A
Former General Motors Corporation
Baltimore Assembly Plant


-------
SITE-SPECIFIC HUMAN HEALTH RISK ASSESSMENT FOR AREA A (REVISION 1 0}
FORMER GENERAL MOTORS CORPORATION BALTIMORE ASSEMBLY PLANT
2122 BR 0 EN IN G HIGHWAY BALTIMORE, MARYLAND 21224

TABLE 2-4

SUMMARY OF CHEMICALS DETECTED IN GROUNDWATER











Pctafef* Uba

ImtGor Air











Hftaiiimnn

Loctfimtr of tewrrtum

Seresrofig



" Must Conservative

Conwrvdttve





CAS (tegutiy



CcnceatrcboR-


-------
SITE-SPECIFIC HUMAN HEALTH RISK ASSESSMENT FOR AREA A (REVISION 1.0)
FORMER GENERAL MOTORS CORPORATION BALTIMORE ASSEMBLY PLANT
2122 BRQENING HIGHWAY, BALTIMORE, MARYLAND 21224

TABU 2-4

SUMMARY of CHEMICALS DETECTED M GROUNDWATER

vh«s»iK«! el Sciential *iun R8C*b«Mdon*

n«i-raneBf »ne A$rsf 2Q0S Report III RBC for methyl metftaoylate was used as a surrogatefor

f The U S. EPA target g'oyndwatet concer^/atjofs based w! mgra!*.*; of vc^abte emssfons from groundwater to indoor air for rrwtyigrsg was used as a surrogate for tots! Kylenas,.
g. The April 2006 Region til RBC for acenapfttheoe was used as a surraga® to aceoaphthytene
h The Aprt 2006 Region 111 RBC for pyren* was used as a surrogate for b««o{g,h ijpeiylene

i The RBCs for rtfeSMOfuran ami cob* vmm wftdrawn from the RBC Table in Ottober, 2005 The poteb* use *o««n
-------
Attachment 5
Table 2-2

Summary of Chemicals Detected in Groundwater in Area B

Site-Specific Human Health Risk Assessment for Area B
Former General Motors Corporation
Baltimore Assembly Plant


-------
SIT1-SPECIFIC HUMAN HEALTH RISK ASSESSMENT FOR AREA B
FORMER GENERAL MOTORS CORPORATION
BALTIMORE ASSEMBLY PLANT
2122 BROENINQ HIGHWAY, BALTIMORE, MARYLAND 21224

TABLE 2-2

SUMMARY Of CHEMICALS DETECTED M GROUNDWATER

Owntetf or Potential Concern



CAS Ri;qlsfey

Maximum
Concentration
lUB'U

Location o*
Maximum
Coneentratfen :

Potable Use
Screenfos
Lewf

Indoor Air
Screening
Levef

Most
Con-wvaHw
Stteesfog Level

Sxce^d ftfest

Conservative
S«e«nlnB t«vel?

VOCs









n-Butylbenzene

c

104518

15 3

HMW1

6.6E+01

2.6E+02

6.6E+01

N

see-Butvibertzene

c

135988

6.99

HMW1

6.6E+01

2.5E+02

6.6E+01

N

tert-Butytbenzene

c

98066

188

HMW1

6.6E+01

2.9E+02

6.6E+01

Y

Chlorobenzsne



108907

908

HMW1

9.0E+00

3.9E+02

9.0E+00

Y

cis-1,2-Dichloroethene



156592

16.2

HMW3

7.0E+01

2.1E+02

7.0E+01

N

trans-1,2-Dichlorosthene



156605

8.6

HMW3

1.2E+01

1.8E+02

1.2E+01

N

IsoproDVlbenzene (Cumene)



98828

18.8

HMW1

6.6E+01

8.4E+00

8.4E+00

Y

p-lsopropvltoluene

c

99876

1.06

HMW1

6.6E+01

8.4E+00

8.4E+00

N

n-Propylbenzene

e

103651

48.3

HMW1

6.6E+01

3.2E+02

6.6E+01

N

Tetraehloroethene



127184

114

HMW3

1.0E-01

1.1E+01

1.0E-01

Y

1,1.2-Triehloreethane



79005

085

HMW3

1.9E-01

4.1E+01

1.9E-01

Y

Trichtaroethene



79016

184

HMW3

2.6E-02

5.0E+00

2.6E-02

Y











Aeenaphthene



83329

325

HMW2

3.7E+01

NA

3.7E+01

N

Ace naphthalene

d

208968

002

HMW3

3.7E+01

NA

3.7E+01

N

Anthracene



120127

0.73

HMW1

1.8E+02

NA

1.8E+02

N

Bsnzo(A)Anthraeene



56553

014

HMW1

9.2E-02

NA

9.2E-02

Y

Benzo(B)Fluorantbene



205992

0.08

HMW2

9.2E-02

NA

9.2E-02

N

BenzofG, H. DPervtene

e

191242

0.06

HMW1

1.8E+01

NA

1.8E+01

N

Benzo(K)Fluoranthene



207089

0.04

HMW2

9.2E-01

NA

9.2E-01

N

Bis(2-Ethylhexvl)PhthaIate



117817

11.6

HMW2

4.8E+00

NA

4.8E+00

Y

Chrvsene



218019

0.11

HMW1

9.2E+00

NA

9.2E+00

N

Dibenzofuran

f

132649

251

HMW2

1 2E+00

NA

1.2E+00

Y

Fluoranthene



206440

0.17

HMW1

1.5E+02

NA

1.5E+02

N

Fluorene



86737

4.38

HMW1

2.4E+01

NA

2.4E+01

N

Naphthalene



91203

2.56

HMW2

6.5E-01

1.5E+02

6 5E-01

Y

Phenanthrene

9

85018

5.27

HMW1

1.8E+01

NA

1.8E+01

N

Pyrene



129000

056

HMW1

1.8E+01

NA

1.8E+01

N













Arsenic



7440382

12.7

HMW1

4.5E-02

NA

45E-02

Y

Barium



7440393

69.8

HMW1

7.3E+02

NA

7.3E+02

N

Selenium



7782492

8,98

HMW3

1.BE+01

NA

1.8E+01

N

NOTES:

a U S EPA Region HI single chemical Tap Water RBC {April XOS] or MCL, uvd on lowest of the two raiues HBCs tesed on a

nor ctnwr endpoint have been divided lay 10 to achieve target HQ of 0 \
bus EPA target groundwater concentration based on migration afvolati'e errissions from groundwater to indoor air (U S EPA. 2002)

c The screening levels for isopropyl benzene were used as a surrogate for n-feutylbenzene, n-propylbenzene, p-aoprDpyftoiuene sec-buty.be nzene and tert-butytoerzene
d The April 2008 Region HI RBC for acenaphttiene was used as a surrogate for aeenapMhyten*
e The April 2006 Region III RBC for pyrene was used as a surrogate for benzo{g,h.i)perylene

f The RBC for (Jtbenzofuran was withdrawn from the RBC Table in October, 20C5 This value is the adjusted RBC for tap water from the April 2005RBC Table
g The April 2006 Region III RBC for anthracene was used as a surrogate for phenanthrene

HULL® ASSOCIATES,
MASON, OHIO

INC

toll

JANUARY 2007
duk037.200.0020


-------
Attachment 6

Table 2-4

Summary of Chemicals Detected in Groundwater in Area D

Site-Specific Human Health Risk Assessment for Area D
Former General Motors Corporation
Baltimore Assembly Plant


-------
SITE-SPECIFIC HUMAN HEALTH RISK ASSESSMENT FOR AREA P
FORMER GENERAL MOTORS CORPORATION
BALTIMORE ASSEMBLY PLANT
2\U BROEN'NG HIGHWAY, BALTIMORE, MARYLAND 21724

TABLE ?-4

SUMMARY OF CHEMICALS DETECTED IN GROUNDWATER

Ptfcfina?



CAS R*g!itry

4WL«

h.r<* Af<<»
Sfcnnwn
Mlfe-WOft

PVitofcic Use
U«»%

wot)

UVljf

Wi)

Wow. C-ttrfetfVBGvc
fe.nwungLtv»)

ftau

tfcSipSHfl&Wi! :
¦Uvtfr









Acetone



67641

§

8B1

5.5E+02

2.2E+05

5.5E+02

N

Bereene



71432

18.1

MW27D

3.4E-01

1.4E+01

3.4E-01

Y

Carbon Disulfide



75150

1.75

HMW10

1.0E+02

5.6E+02

1.0E+02

N

Chlorobenzene



108907

0.79

MW27D

9.06+00

3.9E+02

9.0E+00

N

1,2-Dichloroethane



107062

1.67

MW27D

1.26-01

2.3E+01

1.2E-01

Y

^1-Diehloreethene



75354

2.24

MW27D

7.0E+00

1.9E+02

7.0E+00

N

Iseoroovibenzene fCumene)



96828

0.55

MW27D

6.6E+01

8.4E+00

8.4E+00

N

Methyl Tert-Butvi Ether



1634044

0.53

HMW11

2.6E+00

1.2E+05

2.6E+00

N

Xylenes, Total

d

1330207

3

8B3

2.1E+01

2.3E+04

2.1E+01

N

SvOCs





Acenaphthene





6.63

MMW16

3.7E+6i

NA

17S+4H

H

Aeenaphthyiene

e

208968

3

8B3

3.7E+01

NA

3.7E+01

N

Anthracene



120127

0.1

HMW11

18E+02

NA

1.86+02

N

Benzo(A) Anthracene



56553

0.07

MW27D

9.2E-02

NA

9.2E-02

N

Benzo(A)Pyrene



50328

0.1

MW27D

9.2E-03

NA

9.26-03

Y

BenzoCBlRuoranthene



205992

0.17

MW27D

9.2E-02

NA

9.26-02

Y

BenzotG.H.DPervlene

f

191242

0.09

MW27D

1.8E+01

NA

1.86+01

N

BenzodQFtuorantftene



207089

0.06

MW27D

9.2E-01

NA

9.26-01

N

Di-n-Butvtohthalate



84742

2

8A1.8B2

3.7E+02

NA

3.7E+02

N

Caproiadam



105602

77

8B1

1.8E+03

NA

1.86+03

N

Chrysene



218019

0.13

MW27D

9.2E+00

NA

9.2E+O0

N

Plueranthene



206440

0.34

MW27D

1.5E+02

NA

1.5E+02

N

Fluorene



86737

1

8B3

2.4E+01

NA

2.4E+01

N

indeno( 1,2.3-cdtovrerre



193395

0.07

MW27D

9.2E-02

NA

9.2E-02

N

2-Meth^naphthalene



91576

9

8B3

2.4E+00

3.3E+03

2.4E+00

Y

Naphthalene



91203

47

8B3

6.5E-01

1.5E+02

6.5E-01

Y

Phenanthrene

9

85018

1

8B3

1.8E+02

NA

1.8E+02

N

Pyrene



129000

0.26

MW27D

1.86+01

NA

1.8E+01

N

Metals





Arsenic



7440382

1.03

HSBD4

4.5E-02

NA

4.5E-02

Y

Barium



7440393

1,490

8B3

7.3E+02

NA

7.36+02

Y

Cobalt



7440484

12.1

8B1

7.3E+01

NA

7.3E+01

N

Copper



7440508

5.4

8B1

1.5E+02

NA

1.5E+02

N

Lead



7439921

2.7

8B2

1.5E+01

NA

1.5E+01

N

Manoanese



7439965

2,770

8A1

7.3E+01

NA

7.3E+01

Y

Nlcket



7440020

12.5

8B1

7.3E+01

NA

7.36+01

N

Selenium



7782492

5.2

861

1.8E+01

NA

1.8E+01

N

Zinc



7440666

15

8B1

1.1E+03

NA

1.1E+03

N

NOTES:

a Region l>) angle chemicai Tap Water RBC (Aprri 2006) or Ma, based or. Sowe* of the two values in scajrdtftce wih the ftsk

Eva^tion Matrix door air 
-------