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Action Memorandum UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION Ill 1650 Arch street Philadelphia, Pennsylvania 19103-2029 SUBJECT: Request for Funding for a Removal Action at the Dwyer Property Groundwater Plume NPL Site in Elkton, Cecil County, MD FROM: Eugene Dennis, On-Scene Coordinate!' n n Eastern Response Branch (3HS31) (_,_, J ~ TO: Bonnie G. Gross, Associate Director Office of Preparedness and Response Hazardous Site Cleanup Division (3HS30) I. PURPOSE The purpose of this Action Memorandum is to request and document approval for a Removal Action to mitigate the release or threatened release of hazardous substances at the Dwyer Property Groundwater Plume NPL Site (Site) in Elkton, Cecil County, Maryland. The removal action is planned for a portion of the 73 -acre Dwyer Property. EPA conducted a Removal Site Evaluation (RSE) at the Site in accordance with Section 300.410 of the National Contingency Plan (NCP), and identified a release of hazardous substances, notably lead and arsenic, into the environment. Based upon information obtained from the RSE and a review of that information by the On-Scene Coordinator (OSC), a Removal Action is necessary to mitigate threats posed by the release and/or substantial threat of release of hazardous substances from the Site and to protect public health, welfare and/or the environment. Such actions will be coordinated with the Remedial Project Manager (RPM) and are recommended in advance of the completion of proposed remedial investigations and remedial actions that will ultimately address Site threats outside the acceptable risk range. To mitigate the threat, Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA) funding in the amount of$179,000 is requested of which $109,000 is from the Regional Allowance. II. SITE DESCRIPTION AND BACKGROUND A. Site Description The Site is located within the city of Elkton, Cecil County, Maryland, immediately northeast of the intersection of Maryland Route 545/Blue Ball Road and Maryland Route 279/Newark Avenue. The lateral extent of the Dwyer Property Groundwater Plume NPL Site AR300001 has not yet been determined, but currently it consists mainly of the Dwyer Property and some surrounding area. The total area of the proposed removal action is approximately 0.5 acres, situated within the 73-acre Dwyer Property. The geographical coordinates of the approximate center of the Dwyer Property are 39.613805 north latitude and -75.845940 west longitude. The majority of the Site is undeveloped, mostly forest land. Land use adjacent to the Site is undeveloped to the north; residential and commercial to the east; commercial, industrial, and agricultural to the south; and industrial to the west. Dogwood Run flows to the southwest along the western portion of the Site into Little Elk Creek. The Rudy Park Public Housing Project and associated recreational area (playground) are located adjacent to the southeast boundary of the Site. Maryland Route 279/Newark Ave. borders to the south, while Maryland Route 545/Blue Ball Road borders to the west. A Site layout map is shown in Figure 1. B. Site Background Based on elevated concentrations of trichloroethylene (TCE), trans-1 ,-2-dichloroethene (DCE) and tetrachloroethene (PCE) in the groundwater, and the proximity to the Rudy Park Public Housing Project, the EPA Region III Superfund Remedial Program requested assistance from the EPA Region III Removal Program. Of most concern was the potential for soil gas contaminated with volatile organic compounds (VOCs) to enter the homes at the Rudy Park Housing Project. From November 8 to November 11 , 20 11 the removal program, along with EPA START contractor personnel, performed a Removal Site Evaluation (RSE) at the Site. The RSE consisted of the following activities: the installation and sampling of five temporary groundwater monitoring wells; existing groundwater well sampling; the collection of nine residential well samples; surface soil sampling at the playground area within the Rudy Park Public Housing Project; and installation of temporary soil gas piezometers at the Rudy Park Public Housing Project. The residential well and Rudy Park sampling locations are identified in Figures 2 and 3, respectively. The results of the soil sampling discussed above did not reveal any VOCs above the applicable screening levels in any of the five temporary monitoring wells. Also, none of the nine residential well samples had concentrations above applicable EPA maximum contaminant levels promulgated pursuant to the Safe Drinking Water Act (MCLs) for VOCs, semi-volatile organic compounds (SVOCs), pesticides or polychlorinated biphenyls (PCBs). The results of the surface soil samples collected from the playground area did not exceed the Regional Screening Levels (RSLs) for VOCs, SVOCs, pesticides or PCBs. Finally, no VOCs were detected above the RSLs in the results of the soil gas samples collected from the Rudy Park Housing Project. The sampling results of the existing monitoring well indicated elevated concentrations of trichloroethene up to 11 ,000 parts per billion (ppb). The EPA, in its RSE, recommended that this well be sampled periodically to monitor groundwater contamination levels. The Maryland Department of the Environment (MDE) concurred in this recommendation. During the RSE, three areas of concern were observed on the Site. One area consists of a Collapsed Building of uncertain purpose where small waste piles of unknown substances were scattered about the ground surface. The Collapsed Building Area is located in the southeastern 2 AR300002 portion of the Site, adjacent to the Rudy Park Housing Project. A second area of concern is the Abandoned Drum Area located in the northwestern portion of the Site, near Dogwood Run, where up to seven deteriorated 55 gallon drums were observed on the ground surface. The contents of the drums consist of solidified unknown substances. A third area of concern consists of a suspected Former Dump Area defined by a map provided by (MDE) personnel familiar with the Site. All three areas of concern are identified in Figure 4. On May 22, 2012, EPA START contractor personnel, EPA personnel and MDE personnel mobilized to the Site to conduct waste/soil sampling activities. During this time eleven waste samples (three waste samples and one duplicate from the Collapsed Building Area, and seven waste samples from the drum area) were collected. Of the three samples collected from the building area, the results of one sample (WA03, unknown red material and soil) contained arsenic at a concentration of 26,100 milligrams per kilogram (mg/kg). This same sample also contained benzene at a concentration above the RSL. Sample results from the drum area detected lead at concentrations of 20,800 mg/kg, 7,260 mg/kg, 87,700 mg/kg, 30,800 mg/kg, 916 mg/kg and 8,210 mg/kg in samples W A05 , WA06, WA08, W A09, WAl O and WAll, respectively. From November 26 to November 28, 2012, EPA START contractor personnel conducted geophysical investigation activities at the Site. The Area of Investigation (AOI) for these activities encompasses the Former Dump Area (see Figure 4). The activities performed during the investigation consisted of UXO surface avoidance to identify and mark surficial metallic objects and an electromagnetic (EM) survey on the subsurface. The results of these geophysical investigations indicated that UXO or ordnance was not identified on the ground surface within the AOL Numerous ferrous objects were identified, but all were related to trash and associated dumping. The EM survey results indicated that terrain conductivity measurements vary throughout the AOI, confirming the presence of metallic debris in the subsurface, varying soil types and moisture conditions. Twenty one discrete anomalies were detected in the AOI, which are most likely associated with scattered occurrences of shallow buried metal or metallic surface debris. On March 9, 2016, EPA START contractor personnel and EPA personnel conducted waste/soil sampling activities at the Site. MDE personnel were present and observed the activities. Honeywell International, Inc. (Honeywell) (the Potentially Responsible Party conducting the Site Remedial Investigation and Feasibility Study), and its contractors split samples from the locations where EPA collected samples. Samples were once again collected from the Collapsed Building Area and from the drum area. Of the ten samples EPA collected from the Collapsed Building Area, two samples (SS-007 and SS-008) contained arsenic at concentrations of 11 ,000 mg/kg and 39,000 mg/kg respectively. These concentrations are similar to the concentrations found in samples collected in the same general area during the 2012 sampling event. Sample results from the drum area detected lead at concentrations of 31 ,500 mg/kg, 7,050 mg/kg, 4,350 mg/kg and 3,400 mg/kg in samples SS-020, SS-018, SS-017 and SS- 019, respectively. The analytical results from the split samples collected by Honeywell's contractor were not available. 3 AR300003 C. Quantities and Types of Substances Present The RSE revealed elevated concentrations of arsenic and lead in waste materials and surface soil at the Site. Lead and arsenic are hazardous substances as defined in Section 101 ( 14) of the Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended (CERCLA), 42 U.S.C. § 9601(14) and are listed as such in 40 C.F.R. § 302.4. The concentrations of lead and arsenic in soils detected by EPA are significantly higher than EPA' s Removal Management Levels (RML) of 400 mg/kg and 68 mg/kg, respectively, for those contaminants. EPA estimates that, based on analytical results, there are approximately 300 cubic yards of contaminated soil and waste materials at the Site. D. State and Local Authorities EPA has been coordinating with the State regarding assessment activities and proposed actions at the Site. MDE indicated that they do not currently have the resources available to address contamination at the Site. No other State or local authorities have indicated the availability of resources to address the threat of release or to conduct a Removal Action in a timely manner at the Site.
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