BOOK: 18963 PAGE: 177
ENVIRONMENTAL COVENANT
SITE NAME:'Former GM Baltimore Assembly Plant Duke Realty GRANTOR/OWNER: Duke Baltimore LLC G~NTEE(S)/HOLDER(S): Maryland J;)epartment of the E~vironment; Duke Baltimore LLC
PROPERTY ADDRESS: 5975 Holabird Avenue, Baltimore, MD 21224-Sub Parcel B-1 (the "Property").
This Environmental Covenant is executed pursuant to the prqvisions of Subtitle 8, Title 1 of the Environment Article, Ann. Code of Md. (2013 Repl. Vol.). This Environmental Covenant subjects the Property identified in Paragraph l to the activity and/or use limitations in this document. This Environmental Covenant has been approved by the Maryland Department of the Environment ("Department" or "MDE") and the United States Environmental Protection Agency I ("EPA").
1. Property Affected. The property affected ("Property") by this Environmental Covenant is located in Baltimore City, Maryland.
The postal street address of the Property is: ·5975 Holabird Avenue, Baltimore, MD 21224.
The Land Records Deed Reference: Liber FMC 7313, Folio 272.
Tax Account Identification Number: 0326016874A00~
The latitude and longitude of the center of the Property affected by this Environmental Covenant is: N39.26982 W76.54537 (Datum: World Geodetic System 84).
The Property has been known by the following names: Sub Parcel B-1, the Former American Standard Property-Ward 26, Section I; Block 6874-A, Lots 2 & 3.
A complete metes and bounds description of the Property is attached to this Environmental Covenant as Exhibit A. A map of the Property is attached to this Environmental Covenant as Exhibit B.
2. Property Owner/Grantor. Duke Baltimore LLC is the owner ("Owner") of the Property and the Grantor·of this Environmental Covenant. The mailing address of the Owner is: Duke Baltimore LLC, c/o Duke Realty Corporation, 161 ·washington Street, Suite 1020, Conshohocken, PA 19428, Attn: Senior Vice President.
3. liolder(s)/Grantee(s). The Department and Owner. BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0177, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 178
Environmental Covenant Property: Former GM Baltimore Assembly Plant Duke Realty Deed Reference: Liber FMC 7313, Folio 272 Tax Accowu Identification Number: 0326016874A002
4. Regulaton; Program{s) Issuing Determination. The following regulatory program(s) is (are) responsible for having issued a determination requiring the use of this Environmental Covenant: ~ EPA Corrective Action Program under the Resource Conservation and Recovery Act MOE Programs It! Voluntary Clean~p' Program Controlled Hazardous Substance Enforcement Program Oil Control Program Solid Waste Program D Resource Management Program D Other Program within the Department: ______
On March 26, 2015, EPA issued a Final Decision and Response to Comments ("FDRTC") selecting the Final Remedy for the Former GM Baltimore Assembly Facility, loca~ed at 5975 Holabird Avenu~ in Baltimore, Maryland. The Final Remedy includes a requirement that the Activity 8!1~ Use Limitations described in paragraph 5, below, of this Environmental Covenant be imposed on the Property.
5. Activity & Use Limitations. The Property is subject to the following activity and use limitations, which the Owner and each subsequent owner of the Property shall abide by:
(a) The Property shall be restricted to commercial a~_d/or industrial purposes and shall not be used for residential purposes unless (i) it is demonstrated to the Department and EPA that such use will not pose a threat to human health or the environment or adversely affect or interfere with the Final Remedy; and (ii) the Department and EPA provide prior written approval for such use:
(b) Groundwater from the Property shall not be used for any purpose other than to conduct the operation, maintenance, and mo~it<;>ring activities required by the Department and/or EPA, unless (i) it is demonstrated to the Department and EPA that such use will not pose a threat to human health or the environment or adversely affect or interfere with the Final Remedy; and (ii) the Department and EPA provide written approval for s1:1ch use;
(c) No new wells shall be install~d on the Property unless (i) it is demonstrated to the Department and EPA that such wells are necessary to impl~ment the Final Remedy and; (ii) the Department and EPA provide prior written approval to install such wells;
(d) The Owner shall perform all activities at the Property in accordance with the Risk Management Plan (Exhibit C), dated September .2014, to maintain the integrity and protectiveness of the Final Re~edy unless (i) it is demonstrated to the Depat1ment and EP_A that such activity will not pose a threat to human health or the environment or_adve~sely affect or interfere with the Final Remedy; and (ii) the Department and EPA provide prior written approval for such use; and
Page 2 of 10 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0178, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. I BOOK: 18963 PAGE: 179
Environmental Covenant Property: Former GM Baltimore Assembly Plant Duke Realty Deed Reference: Liber FMC 7313, Folio 272 Tax Account ]4entification J:lumber: 03260/6874A002
(e) The Property s\lall not be used in any way that will pose a threat to human health or the environment or adversely affect or interfere with the integrity and protectiveness of the Final Remedy.
6. Notice of Limitations in Future Conveyances. Each instrument hereafter conveying any interest in the Property shall contain a riotice of the activity and use limitations set forth .in this Environmental Covenant and shall provide the recorded location of this Environmental Covenant.
7. Access b¥ the Department and EPA. In addition to any rights already possessed by the Department or EPA, this Environmental Covenant grants to the Department and EPA a right of access to the Property to implement or enforce this Environmental Covenant.
8. Recordation & Filing with Registry. The Owner shall record this Environmental Covenant in the Land Records of Baltimore City within 30 days of the later of the Department and EPA's execution and delivery of this Environmental Covenant and shall ·send proof of the recording to the Department and EPA within ·30 days of recordation. This Environmental Covenant shall be filed as soon as possible after execution in the Registry of Environmental Covenants maintained. by the Department. This Environmental Covenant may be found electronic.ally on the Department's website at:
.www.mdc.maryland;gov/:grograms/land/marylandbrownfieldvcp/pages/programs/landprograms/e rrp brownfields/ueca.aspx
9. Termination or Modification. This Environmental Covenant runs with the land unless terminated or modified in accordance with § 1-808 or § 1-809 of the Environment Article, Ann. Code of Md. (2013 Repl. Vol.). The rights and obligations set forth herein shall inure to and be bi~ding on the successors and assigns to this Environmental Covenant. The then-current owner agrees to provide EPA and the Department with written notice of the pendency of any proceeding that could lead to a foreclosure referred to in§ 1-808(a) (4) of the Environment Article, Anri. Code of Md. (2013 Rcpt. Vol.), within seven calendar days of the owner's becoming aware of the pendency of such proceeding. The then-current owner shall provide EPA and the Department written notice within 30 days after each conveyance of an interest in any portion of the Property. Such written notice shall include the name, address and telephone numbers of the transferee to whom such interest is conveyed.
10. EPA's Address. Communication_s with EPA. regarding this Environmental Covenant shall be sent to: Office of Remediation (3LC20), Land and Chemicals Division, U.S. Environmental Protection Agency, 1650 Arch Street, Philadelphia, PA 19103. ·
11. The Department's Address. Communications with the Department regarding this Environmental Covenant shall be sent to: Registry of Environmental Covenants, Maryland Department of the Environment, Land fyf~nagement Adminis~ration, Land Restoration Program, 1800 Washington Blvd., Baltimore, MD 21230.
Page 3 oflO BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0179, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 180
Environmental Covenant Property: Former GM Baltimore Assembly Plant Duke Realty Deed Reference: Liber FMC 7313, Folio 272 Tax Account Identification f':{umber: 0326016874A002
12. Administrative Record. The Administrative Record pertaining to the remedy selected United States Environmental Protection Agency, Region by EPA-, in the FDRTC is located. af the Ill, 1650 Arch Street, Philadelphia, PA 19103. In ad4ition, records pertaining to the remedy selected by EPA in the FDRTC are maintained by the Department at Registry of Environmental Covenants, Maryland Department of the Environment, Land Management Administration, Land Restoration Program, 1800 Washington Blvd., Baltimore, MD 21230.
13. Enforcement. This environmental covenant shall be enforced in accordance with § 1~ 810 of the Environment Article, Ann. Code of Md. (20i3 Repl. Vol.),
14. Compliance Reporting.
Within 21 days after written request by the Department or EPA, the then current owner of the Property shall submit, to the Department, EPA arid any Holder listed in Paragraph 3, written documentation stating whether or not the activity and use limitations set forth in Paragraph S of this Environmental Covenant are being abided by. In addition, within 21 days after any of the following events: a) transfe~ of title of the Property or ofany part of the Property affected by this Environmental Covenant, b) becoming aware of noncompliance with Paragraph 5, and c) an application for a permit or other approval for any building or site work that could affect contamination on any part of the Property, the then· current owner will send a report to the Department, EPA and any Holder. The report will state whether there is compliance with Paragraph S. If there is noncompHance, the report will state ·the actions that will be taken to assure compliance.
15. Severability.
The paragraphs of this Environment~l Covenant shall be severable and should any part hereof be declared invalid or unenforceable, the remainder shall continue in full force and effect between the parties.
Page4 oflO BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0180, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. L. BOOK: 18963 PAGE: 181
Environmental Covenant Property: Former GM Baltimore Assembly Plant Duke Realty Deed Reference: Liber FMC 7313, Folio 272 Tax Account Identification Number: 0326016874A002
IN WITNESS WHEREOF, the parties hereto have caused this Enviromnental Covenant to be executed and delivered as of the day and year first above written.
ACKNOWLEDGMENTS· by Grantor/Owner, any Grantec(s)/Holder(s), the Department and EPA, in the following form:
ATTEST:
Duke Baltimore LLC,
By: buke Realty Limited Partnership
By: Duke Realty Corporation
Grantor/Owner/Grantee/Holder Date: Nov, \6 2o_l~ By:\-.6=2~ N~:;. So.mull.L CY ~r--; Ml± Ti E.1uu2... v. P.
STATE: of= G£OR.G1A ~~ ) ) COUNTY OF G, u.., 10 n Qtt ) SS:
On this 10;~ day of N av WI b.u , 20~ before me, the undersigned officer, personally appeared.3_So.M1.,. ..1 t>~ ... 1c.-,,., who acknowledged hersel£'himselfto be the person whose name is subscribed to this environmental covenant, and acknowledged that s/he freely executed the same for the purposes therein contained.
In witness whereof, I hereunto set my hand and official seal.
(Namif n;,;:;, public typewritte11 or pri11ted) Notary Public , , , , , , , , , , , ,,, .. k NIAR,L'-,,, ...... f-''": ...... ,,i, ,, ,:' .·~OTA,91-'•.'V ,., ... , - , - My commission expires: ---'-'--l,l"""'oc....~-'-'\1-2..!"-o"'--'--17.,__ ___ •- •: EXPIRES : : • : : GEORGIA : : ~ : Jan. 9, 2017 : : ~~-- ,c:, •• .: Page 5 of 10 -:.,~;:, .usuS,. ·:-<...l...... ,,;vtv1:'-ii-,,,,,. ..co\)~,,, ,,,,, BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0181, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 182
Environmental Covenant Property: Former GM Baltimore Assembly Plant Duke Realty Deed Reference: Liber .FMC 7313, Folio 272 Tax Account Identification Number: 0326016874A002
APPROVED by Maryland Department of the Environment Land Management Administration, Agency and Holder/Grantee
By: --,.~~~~...!...::....~~ Hilary Miller Director Land Management Administration Maryland Department of the Environment
STATE OF MARYLAND ) ) COUNTY OF BALTIMORE ) SS:
On this.£}]!'day of ~ ;';\; , 20 .!.'], before me, the undersigned, personally appeared Hilary Miller, own to e (or satisfacto . y oven) to be the person whose name is subscribed to the within in e nd acknowledg d that e executed the same for the purposes therein contained.
(Name of notary public typewritten------or printed) \'UL'-~~ L. '(\\W"' otary Public
'sionexpires: ·~ \7 1~\J 1lais is to certify that the within instrument Approved for form and legal sufficiency WU prepared under the supervision of the undersigned, an attorney duly admitted to 1~YA practice before the Court of Appeals of This k..L day of)t()ILUr~ , 20t]_ Maryland.
Maryland~~ Assistant Attorney General
Page 6 oflO BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0182, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 183 Environmental Covenant Property: Former GM Baltimore Assembly Plant Duke Realty Deed Reference: Liber FMC 7313, Folio 272 Tax Account Identification Number: 0326016874A002
APPROVED, by United States Environmental Protection Agency, Region III
Date:~ 20J]_ By: ~;;LU· i,s~ Catherine A. Libertz Acting Director Land and Chemicals Division United States Environmental Protection Agency Region III
COMMONWEALTH OF PENNSYLVANIA ) ) COUNTY OF PHILADELPHIA ) SS:
On this_o<._ In witness whereof, I hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL PATRICIA J. SCHWENKE, Notary Public City of PhDadelphia, Phna. County Mv Commission Expires August 14, 2018 (Name of notary pulie typewritten or printed) Notary Public My commission expires: 4r I~ JOf?, ------Page 7 of 10 ------BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0183, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 184 Environmental Covenant Property: Former GM Baltimore Assembly Plant Duke Realty Deed Reference: Liber FMC 7313, Folio 272 Tax Account Identification Number: 0326016874A002 EXHIBIT A Complete Metes and Bounds Description of the Property Page 8 oflO BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0184, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 185 Area B - Sub-parcel B-1 Provided by Bowman Consulting- 913114 DESCRIPTION PART OF LOT3 PROPERTY OF DUKE BALTIMORE LLC WARl)26, SECTION 01, :BLOCK 6874A BEING a parcel of land lying on Holabird Avenue in Ba_ltinicfre City, Maryland and being part of those lands granted and conveyed from General Motors Corporation to Duke Baltimore LLC by Deed dated January 25, 2006 an~ recorded among the Land Records of Baltimore, Maryland in Liber 7313 at Folio 272, said property also being part of Lot 3 as shown on a plat of subdivision dated January 18, 2008 entitled "Subdivision Plan- Duke Properties- Brocning Highway and Holabird Avenue" recorded 1 \ among the af?resaid ~.,and Records as Plat ~umber _FMC 4005, and all being more particularly described ;r \ as follows, with bearings referenced to Baltimore City Datum: \o~ / . / BEGINNING at a point on the southern right-of-way line ofHolabird Avenue (a variable width public street) distant No11h 87°21' 12" East, 2365.51 feet from a capped iron rod found at the intersection of the southernmost side of Holabird Avenue with the eastemmost side of the CSX Corporation right-of-way at the beginning point of Parcel 2 of Tract II of those lands granted and conveyed in the abovementioned deed recorded in Liber 7313 at Folio 272, also being.. the northwesternmost. corner of Lot 2 as shown on the above-referenced plat, thence from said point of beginning leaving the southernmost right-of-way line or"Holabird Avenue and running with part or°the easternmost side of Lot 3 as shown on said plat the .- following three (3) courses and distances, as now surveyed: .... I. South 04°12'32" East, 241 .43 feet to a point 0.79 feet north ofa pipe found, thence 2. South 00°34 '32" East, 99.43 feet to a point, thence 3. South 04°12'32" East, 157.78 feet to a point, thence leaving the easternmost side of Lot 3 and running so as to cross said lot the following course and distance: 4. South 87°13'2 I" West, 6~3.44 feet to a point on the common line between Lot 3 and Lot 2A as shown on the above-referenced plat, thence running with and binding on part of said westernmost lot line the following course and distance: 5. North 02°46'38" West, 492.97 feet to a point on the abovemcntioned southern right-of-way line of Holabird Avenue, ~hence running with ~nd binding on part of said right-of-way line the follow_ing four courses and distances: 6. North 87° 11 '42" East, 241.42 feet to a point, thence 7. 36.30 feet along the arc of a curve to the left having a radius of 24 7.1 S feet and an interior angle of08°24'54" with a chord bearing No11h 82°59' 14" East, 36.27 feet to a point of reverse curvature, thence 8. 33.9S feet along the arc of a curve to the right having a radius of 231.22 feet and an interior angic of08°24'49" with a chord bearing No11h 82°59' 11 '' East, 33.92 feet to a point, thence 9. North 87° 11 '42" East, 365.87 feet to the place of beginning; containing 337,850 square feet or 7. 7560 acres of land, more or less. P:IS4a3; SS0I I lolal>ird Avcnuc\5483-01-999 (SUR)\Survcy\Documcnts\DF.SCRIPTIONS\l)IJSCRfPTION PART OF LOT 3.docx BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0185, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 186 Environmental Covenant Property: Former GM Baltimore Assembly Plant Duke Realty Deed Reference: Liber FMC 7313, Folio 272 Tax Account ldent~fication Number: 0326016874A002 EXHIBITB Map of the Property Page 9 of 10 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0186, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0187, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. I I I__ I , '\, '--. I l I l J' I I ______) - - / ',~'-~ l_ ____~ _L L___ ,_c ------__ J,,J::i:f____LI ,t,.L'---~~~--_, u ~ ""------'- £b ../i''"2"°Q& ~ ~47'5 •~ l -= __ _. ...a,--,F------HOLABIROAVENUE -..,"'"'5114·59'2' .._-"182"5B'' 9 _,.,,,..,,,, ___ ~,::=-~-,;~fr' --=---r-~~=:65d6 ---1110_·.. .., ~~?;,.•4s~=~;~~-~ ~ _r _ ~- - .,n7 40.os { 1>";251 22 1 l I n. n n -? c9'~ B·.31 • · ~ s2·sa·1 I z q-----''----''---'L..--- CH=17,2<'e, · -,, ~.s"'33.s 8 \- ~ ~ I II :g " s 4- l <, ...... J BOOK: 18963 PAGE: 188 Environmental Covenant Property: Former GM Baltimore Assembly Plant Duke Realty Deed Reference: Liber FMC 7313, Folio 272 Tax Account Identification Number: 0326016874A002 EXHHIBITC Risk Management Plan **L&B 5766887vl/1044S.000 I Page 10 oflO BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0188, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 189 RISK MANAGEMENT PLAN FOR: AREA B - SUB-PARCEL B-1 CHESAPEAKE COMMERCE CENTER (FORMER GENERAL MOTORS BALTIMORE ASSEMBLY PLANT) LOCATED AT: 5975 HOLABIRD AVENUE BALTIMORE, MARYLAND 21224 PREPARED FOR: DUKE BALTIMORE, LLC 111 S. CALVERT STREET, SUITE 1805 BALTIMORE, MD 21202 PREPARED BY: HULL & ASSOCIATES, INC. 300 BUSINESS PARK DRIVE, SUITE 320 PITTSBURGH, PENNSYLVANIA 15205 SEPTEMBER 2014 ~! HULL BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0189, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. L BOOK: 18963 PAGE: 190 TABLE OF CONTENTS PAGE 1.0 INTRODUCTION ...... 1 ll Background ...... 1 11 Historical Assessment Activities ...... 1 1.2.1 Phase I and II Assessments ...... 1 1.2.2 Remedial Action/Corrective Measures Implementation and Certification Reporting ...... 4 1.2.3 Summary of Post-Remedy Hazards and Risks ...... 6 Ll Purpose of the Risk Management Plan ...... 6 2.0 SUMMARY OF POTENTIAL HEALTH RISKS ASSOCIATED WITH COPCs ...... 8 .f.:.1 General ...... 8 2.2 Chemical Hazards ...... 8 2.2.1 Metals ...... 9 2.2.2 Polynuclear Aromatic Hydrocarbons (PAHs) ...... 10 3.0 RISK MANAGEMENT PROVISIONS ...... 12 ll Provisions for Implementation of the RMP ...... 12 3.2 RMP Implementation for Soil ...... 12 3.3 RMP Implementation-for Groundwater ...... 12 3.4 Management of Impacted Environmental Media ...... 13 3.4.1 Soil ...... 13 3.4.1.1 Reuse of Soils within Landscaped Areas ...... 13 3.4.1.2 Reuse of Soils below Hardscape ...... 13 3.4.1.3 Management of Vegetation within Landscaped Areas ...... 13 3.4.1.4 Disposal of Soil at an Off-Site Facility ...... 14 3.4.2 Groundwater ...... 15 4.0 MAINTENANCE OF REMEDY ...... 16 .1.,1 General ...... 16 4.2 Engineering Control Maintenance Requirements ...... 16 HULL & ASSOCIATES, INC. SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA OUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0190, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 191 TABLE OF CONTENTS CONTINUED PAGE 6.0 COMMUNICATIONS, RESPONSIBLE PARTIES, DOCUMENT CONTROL AND REPORTING ...... 17 .§.:.1 Communications and Notification Provisions ...... 17 5.1.1 Site Workers ...... 17 5.1.2 Tenants/Lessees ...... 17 5.1.3 Emergency Response ...... 17 5.2 .Responsible Parties ...... 17 5.3 Reporting ...... 18 5.4 Document Control ...... 19 6.0 REFERENCES ...... 20 LIST OF TABLES Table 1 Required Components of International Standards Organization ISO 14001 Environmental Management Systems LIST OF FIGURES Figure 1 Site Location Map Figure 2 Area B Sub-Parcel Boundaries Figure 3 As-Built Site Plan for Sub-parcel B-1 Figure 4 Typical Detail for Landscape Area (Small Trees and Shrubs) Figure 5 Typical Detail for Large Tree Plantings Figure 6 Summary of RMP Communication and Reporting Lines Figure 6A - General RMP Notification and Implementation Flow Chart Figure 6B - RMP Reporting Flow Chart LIST OF APPENDICES Appendix A Worker Acknowledgement Forms Appendix B NIOSH Contact Information and Example Chemical Data Appendix C Inspection Documentation Form Appendix D Notification of Modification/Repair of Engineering Control HULL & ASSOCIATES, INC. ii SEPTEMBER 2014 PITTSBURGH. PENNSYLVANIA OUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0191, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. L_ BOOK: 18963 PAGE: 192 TABLE OF CONTENTS CONTINUED LIST OF ACRONYMS ATSDR Agency for Toxic Substances Diseases Registry CAP Corrective Action Plan CMI Corrective Measures Implementation CMS Corrective Measures Study coc Certificate of Completion COPC Chemical of Potential Concern . EMMDL Environmental Media Management Decision Level ESA Environmental Site Assessment Facility Former GM Baitimore Assembly Plant Plan FSP Field. Sampling. . GM General Motors Corporation HASP Health and Safety Plan HAZWOPER Hazardous Waste Operations and Emergency Response Standard HI Hazard Index IRM Interim Remedial Measure MOE Maryland Department of the Environment mg/kg Milligrams per Kilogram NIOSH National Institute for Occupational Safety and Health O&M Operation and Maintenance OSHA Occupational Safety and Health Administration PAHs Polynuclear Aromatic Hydrocarbons PPE Personal Protective Equipment QAPP Quality Assurance Project Plan RAP Response Action Plan RCRA Resource Conservation and Recovery Act REC Recognized Emi1ronmental Condition RFI RCRA Facility Investigation RMP Risk Management Plan TCLP Toxicity Characteristic Leaching Procedure µg/L Micrograms per Liter U.S. EPA United States Environmental Protection Agency VCP Voluntary Cleanup Program voes Volatile Organic Compounds HULL & ASSOCIATES, INC. iii ·sePTEMBER 2014 PITTSBURGH, PENNSYLVANIA . OUK110. 701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0192, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 193 1.0 INTRODUCTION 1.1 Background Hull & Associates, Inc. (Hull), riri behalf of Duke Baltimore, LLC (Duke), condu_cted a RCRA Facility Investigation (RFl)/Phase II Environmental Site Assessment (Phase II) and Corrective Measures Study (CMS) for Area B of the Chesapeake Commerce Center (Facility). Chesapeake Coll)merce Center is also known as the Former General Motors (GM) Baltimore Assembly Plant and has been r~ferred to as such in previous reports. The Facility occupies approximately 182 acres of land located at 2122 Broening Highway in Baltimore\ Maryland. The Facility is industrial property that formerly housed automobil'? ~ssembly opera~ions from 1936 . . until plant closure on May 13, 2005. Area B Sub-parcel B-1 (the Site) consists of a 7.76-acre portion of the overall 52-acre Area B site located at 5975 Holabird Avenue. The locations of the Facility, Area Band Sub-parcel B-1 are shown on Figure 1. Duke purchased the Facility fro!11 GM in January 2006 and su~sequently performed assessment and remediation activities at the site in accordance with both federal and state regulatory programs. Duke concurrently met the requirements for the Resource Conservation and Recovery Act (RCRA) Corrective Action process, administered by the United States Environmental Protection Agency (U.S. EPA), and Maryland's Voluntary Cleanup Program (VCP), administered by the Maryland Department of the Environment (MOE). As such, all administrative and substantive elements of the RCRA Corrective Action and VCP were conducted under one integrated program. 1.2 Historical Assessment Activities 1.2.1 Phase I and II Assessments In M~y 200~, Hull conducted a Phase I Environmental Site Assessment (Phase I) for the Facilify. The Phase I identified Recognized Environmental Conditions (RECs) and potential Interim Remedial Measures (IRMs). In June 2006, Hull prepared a RCRA Facility Investigation/Phase II Environmental Site Assessment (RFI/Phase II) Work Plan which provided a summary of historical analytical data collected at the Facility, an initial understanding of the nature and extent of contamination, and scopes of work for conducting IRMs and further assessing the RECs. The RFI Work Plan was approved by U.S. EPA and MOE in August 2006. Quality assurance/quality control procedures to be used during implementation of the RFI Work HULL & ASSOCIATES, INC. SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA OUK110.701,0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0193, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. ------1 BOOK: 18963 PAGE: 194 Plan were described in a Quality Assurance Project Plan (QAPP) that was approved by U.S. EPA in June 2006. Hull conducted a RCRA Facility Investigation/Phase II Environmental Site Assessment (RFI/Phase II) between August and November 2006. In general, the purpose of the RFI/Phase II was to: 1. determine whether a release of hazardous waste/constituents had occurred at the RECs previously identified; 2. characterize the source(s) of releases and determine the nature and extent of constituents in environmental media to the extent necessary to support risk assessmen_t activities; 3. identify current and potential migration pathways, and potential human and environmental receptors under current and reasonably expected future land use; 4. assess potential risk to human health and the environment associated with releases of hazardous waste/constituents to the environment; and · 5. conclude whether final corrective measures IJYere necessary to mitigate unacceptable hazard or risk, if any, posed to human health and the environment under current and reasonably expected future land use. Field activities, sampling, and quality assurance/quality control activities were conducted consistent with the approved RFI/Phase II Work Plan and QAPP. RFI/Phase II investigation activities included soil boring installation, collection and laboratory analysis of soil samples, moni~oring well installation, collection and laboratory analysis of groundwater samples, test pit ir,stallation, and risk assessment. Based on the results obtained from RFI/Phase II activities, Hull conducted a risk assessment consistent with U.S. EPA guidelines such as the Risk Assessment Guidance for Superfund and Maryland Department of the Environment Voluntary Cleanup Program Guidance and ·in accordance with the Revised Risk Eval~ation Methodology: Comparison Matrix of Region Ill RCRA Corrective Action and Maryland Department of the Environment Voluntary Cleanup Programs (Hull, 2006) submitted to representatives of U.S. EPA and MOE via letter on April 28, 2006. The risk assessment was conducted to: 1. Determine the chemicals of potential concern (COPCs) for total soils (surface and subsurface) and groundwater; · HULL & ASSOCIATES, INC. 2 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA · OUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0194, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 195 2. Assess the complete and potentially complete exposure pathways via a quantitative or semi-q~antitative evaluation of hazard and/or risk; 3. Develop Environmental Media Management Decision Levels (EMMDLs) to aid in the redevelopment of the Site; 4. Quantify the potential exposures to identified receptor populations via the complete exposure pathways including direct contact with soil and groundwater; and 5. Estimate potential non-cancer hazards and cancer risks associated with direct contact exposures to soil and groundwater containing the COPCs for each identified receptor population, as appropriate. The risk assessment evaluated four receptor populations with respec~ to future commercial or industrial land use: on-site workers, child and youth visitors and construction/excavation workers. Complete and potentially complete exposure pathways include direct contact with soil, direct contact with groundwater (construction/excavation worker only), and indoor air (potential volatile emissions from soil and/or groundwater to indoor air). In addition, exposure pathways consistent with the maximum beneficial use of groundwater within the shallow and deep water bearing zones were evaluated. Groundwater concentrations of COPCs detected in the shallow aquifer within the area (i.e., Patapsco Formation) were evaluated with respect to surface water recharge and conservative modeled concentrations of COPCs in the deep aquifer within the area (i.e., Patuxent Formation) were evaluated with respect to groundwater use as industrial process water. Potable use of groundwater was not evaluated because the Facility and surrounding area are supplied with potable water from the City of Baltimore's public water supply system, and no potable use of groundwater is known within the region. Concentrations of volatile organic compounds (VOCs) and lead in soil and VOCs in groundwater were evaluated semi-quantitatively with respect to potentially complete vapor intrusion pathways and direct contact with soil containing lead via comparison to site-specific EMMDLs. The EMMOLs are numeric criteria used to make soi~ management decisions and site redevelopment decisions, if necessary, to preclude or mitigate future human exposures to environmental media containing concentrations of chemicals of potential concern. Based on the results of the risk assessment, soil management in several areas of concern in Area B was required due to lead concentrations in soil that exceed the chemical-specific EMMDL. Assessment of the distribution of lead exceeding the EMMDL is complicated given the heterogeneity of the fill materials across Area B and the apparent variability of lead distribution HULL & ASSOCIATES, INC. 3 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0195, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 196 within the fill (e.g., immediately adjacent borings display significantly different lead concentrations). In addition to areas of soil exceeding the EMMDL for lead, the risk assessment identified one limited area of soil with VOCs exceeding EMMDLs based on the potential for volatile emissions from soil to impact indoor air in future buildings, and another limited area of soil with benzo(a)pyrene at concentrations which exceed MOE hot spot criteria. Finally, two areas displayed Toxicity Characteristic Leaching Procedure (TCLP)-lead concentrations in excess of the TCLP-tead limit. It is import~nt to note that the TCLP-lead limit is designed to represent a maximum allowable limit that may be leached from a waste material under simulated landfill conditions for the purpose of waste characterization and does not represent an allowable concentration with respect to a human health endpoint Given that the approved Response Action Plan for Area B includes construction of engineering controls such as buildings, roads and parking areas over a majority of the area, and exposed areas (greenspaces) are to be covered with clean soils, exposures of the on-site worker and child and youth visitors receptor populations to potentially contaminated soil via direct contact will be precluded. Therefore, these incomplete exposure pathways were not evaluated in the risk assessment due to the implementation of the presumptive remedy. However, potential direct contact exposures to soil and groundwater by the construction/excavation worker during future intrusive activities were considered to be complete exposure pathways and were quantitatively evaluated. The quantitative evaluation for direct contact with soil by the construction/excavation worker receptor population, excluding lead, did not indicate unacceptable hazard or risk. The quantitative evaluation for direct contact with groundwater by the construction/excavation worker receptor population indicated unacceptable hazard and, therefore, risk management activities are necessary to address unacceptable hazard associated with this pathway. As discussed in subsequent sections, direct contact exposures to construction/excavation workers during initial site remediation and redevelopment activities were managed through a site-specific Health and Safety Plan (HASP). Potential direct contact exposures to future construction/excavation workers during activities conducted some time after the initial redevelopment (e.g., utility maintenance) will be managed through implementation of this Risk Management Plan. 1.2.2 Remedial Action/Corrective Measures Implementation and Certification Reporting In February 2007, Hull submitted the RCRA Facility Investigation I Phase II Environmental Site Assessment and Corrective Measures Study for Area B to U.S. EPA and MOE. Following HULL & ASSOCIATES, INC. 4 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA OUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0196, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 197 receipt of agency comments on the RFI/Phase II report for Area A, the Area B report was revised and resubmitted to MDE and U.S. EPA in March 2007. The revised report is entitled "RCRA Facility Investigation I .Phase II Environmental Site Assessment and Corrective Measures Study (Revision 1.0)" (the RFI/CMS Report). The CMS portion of the· RFI/CMS report, which was developed principally for U.S. EPA, identified potential remedial actions to address those Recognized Environmental Conditions (RECs) in Area B that exceed risk-based clean-up goals; In July 2007, a Response Action Plan (RAP) was developed to elaborate on components of the propo_sed rem~dy that were summarized in the RFI/CMS Report. The RAP was developed in coordination with site redevelopment plans and provided further detail on the remedial strategy first discussed in the RFI/CMS report. The RAP also address~d applicable CMI ~rovisions of the RCRA Corrective Action Plan ((CAP), U.S. EPA, 1994). The RAP was prepared for implementation over the entire 52-acre Area B site. Since approval of the RAP on July 27, 2007, Duke divided Area B into four sub-parcels (13-1, 13-2, 8-3 and 8-4). The outline of each sub-parcel is shown on Figure 2. Because RAP completion will be achieved in a progressive sequence, Duke submitted individual VCP applications for each of the four sub~ parcels so that an individual Certificate of Completion (COC) can be requested for each sub parcel as construction activities are completed. This RMP has been written to apply to Area B Sub-parcel 8-1. As described in the RAP, several_ remedial activities/corrective measures have been implemented during the course of redevelopment in order to me~t app!icable standards across Area 8. The remedial activities that were conducted specifically on Sub-parcel B-1 include the following: 1. Soils exceeding the TCLP-lead limit were excavated and disposed off-site at an approved treatment/disposal facility. 2. Direct contact exposures to soil by the on-site worker, child visitor and youth visitor have been precluded by the construction of engineering controls and piacement of clean cover soils. The engineering controls include buildings and associated parking areas and roadways. Greenspace· areas ·are covered with a minimum of two feet of clean soil cover placed over a geotextile marker fabric. 3. Direct contact exposures to construction/excavation workers during initial site remediation and redevelopment activities were m~naged t_hrough a site-specific Health and Safety Plan (HASP). Potential direct contact exposures to future construction/excavation workers during activities conducted some time after the initial redevelopment (e.g., utility maintenance) will be managed through implementation of this Risk Management Plan. HULL & ASSOCIA'rES, INC. 5 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA . DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0197, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 198 4. Institutional controls restricting the use of the Site to commercial/industrial land use will be implemented. Unrestricted residential land use, including single and multiple family dwellings, will be prohibited under the terms of this use restriction. 5. Institutional controls restricting the use of groundwater underlying the Property for any purpose will be implemented. ' Remediation and construction activities in Sub-parcel B-1 were completed in September 2014. Duke and Hull submitted a certification report for Sub-parcel 8-1 in September 2014. A site plan for Sub-parcel B-1 summarizing paved areas and greenspace areas is shown on Figure 3. 1.2.3 Summary of Post-Remedy Hazards and Risks Although the remedial activities described above preclude current exposures to environmental media containing COPCs above applicable standards, soil containing lead and/or PAHs in exceedance of applicable standards and impacted groundwater remain at Area B. It is possible that impacted soil may be encountered during intrusive activities that breach either the two-foot clean soil cover in greenspaces or extend below hardscape such as parking lots or building slabs. Therefore, risk management provIsIons may be required to protect construction/excavation workers from exposures to COPCs in soil at the Site via direct-contact during ·intrusive redevelopment or maintenance activities. Additionally, COPCs at concentrations above health~based direct contact standards may be contacted in the event that groundwater Is encountered during construction/excavation activities. Although exposures to groundwater via direct-contact, if they occur, are expected to be brief and intermittent. controlling these exposures through this RMP will add a further level of protection t~ fu~ure construction/excavation workers who may be exposed to groundwater via direct-contact. 1.3 Purpose of the Risk Management Plan This RMP _includes the elements required by the Environmental Management Systems lnternation.al Standard ISO 14001 outline as well as other supporting information related to the Site's environmental condition, descriptions of potential risks/hazards associated with soils at the Site, descriptions of procedures required for soil characterization and management, and other applicable information designed to inform future workers of Site conditions. This RMP will also serve as a record-keeping device to document that future workers are notified of, and have acknowledged, the Site conditions so that appropriate risk reduction actions can be conducted. HULL & ASSOCIATES, INC. 6 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0198, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. ----·------ BOOK: 18963 PAGE: 199 The RMP includes the final layout of buildings, utilities and greenspaces upon completion of the development. This RMP also describes the measures to be taken to effectively eliminate or reduce the potential hazard ~r risk posed to Site workers following the completion of remedial activities and redevelopment and provides descriptions of activities required to maintain the remedy components. The RMP may only be modified or terminated upon mutual agreement of the Owner and the Maryland Department of the Environment. A SU!llmary of the elements required by the ISO 140001 standards and a summary of the locations where each element has been addressed in the RMP is located in Table 1. HULL & ASSOCIATES, INC. 7 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA OUK110.701,0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0199, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 200 2.0 SUMMARY OF POTENTIAL HEALTH RISKS ASSOCIATED WITH COPCs 2.1 General As discussed in Section 1.2.3, it is possible that soil containing concentrations of COPCs that exceed worker safety standards may be encountered during intrusive activities. Impacted groundwater may also be encountered during subsurface activities that are conducted at depths below the water table. This section contains a discussion of the COPCs that exceed or significantly contribute to an exceedance of an applicable standard that may be encountered at the Site. The intent of this section is to include· a brief discussion of the nature, type, and concentration of each COPC in soil or groundwater and a few potential health effects that may be caused by exposure to elevated levels of each COPC. This RMP does not include a hazard analysis for each task that may be completed at the Site. The Contractor (i.e., the entity performing work which may require RMP implementation) must provide a HASP(s) for each site-specific task and phase of work which may result in the implementation of the provisions for the RMP. It is the responsibility of the Contractor to show proof of applicable training or licensing that may be required by federal, state or local laws and regulations including, but not limited to, Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) 40 hour training. Each worker will need to review this document and sign the worker acknowledgement form located in Appendix A of this document. 2.2 Chemical Hazards The routes of exposure thro~gh which hazardous chemicals may potentially be encountered during intrusive activities at the Site include: 1. inhalation of volatile or particulate emissions in ambient air; 2. dermal contact with and/or adsorption of contaminants contained in soil and/or groundwater; 3. ingestion of contaminants contained in soil and/or groundwater (such as may occur through poor personal hygiene and decontamination practices). HULL & ASSOCIATES, INC. 8 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0200, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. .. - ---·--·· ------ BOOK: 18963 PAGE: 201 A discussion of COPCs that exceed or significantly contribute to an exceedance of applicable standards that may be encountered at the Site and general chemical class descriptions and potential associated health impacts are discussed in Section 2.2.1 and Section 2.2.2, below. There are a variety· of sources regarding hazard information for specific chemicals in an occupational setting including National Institute for Occupational Safety and Health (NIOSH) Pocket Guide to Chemical Hazards and OSHA Occupational Health Guidelines for Chemical Hazards. Contact information for NIOSH and example chemical data available through NIOSH are included in Appendix B. It is the Contractor's responsibility to ensure that activities conducted at the Site do not result in exp~sure of the workers to levels of haz~rdous chemicals in exceedance of applicable federal, state, and local laws and regulations. 2.2.1 Metals As di~cusse~ in Section 1.2.1; soil containing lead at concentrations above 1,000 mg/kg is known to be located beneath engineering controls across Area B. However, due to the heterogeneity of the fill materials at the Site and the apparent variability of lead distribution within the ·fill (e.g., immediately adjacent borings display significantly different lead concentrations), the locations where workers could encounter lead through contact witli subsurface soil throughout Area B are not'known with absolute certainty and it is possible that intrusive activities may not encounter soils with elevated lead concentrations. Nonetheless, precautions should be taken to minimize or eliminate exposures to elevated levels of lead due to the potential for adverse health effects. According to the NIOSH f:>ocket Guide (2005) ~o chemical hazard, exposure to elevated levels of lead may cause weakness, lassitude (weakness, exhaustion), insomnia, facial pallor, anorexia, weight loss, malnutrition; constipation, abdominal pain, colic, anemia! gingival lead line, tremor, paralysis of the wrist and ankles, ~ncephalopathy, kidney disease, irritation of the eyes and hypotension. In addition to lead in soils, two additional metals are found in groundwater at concentrations exceeding health-based levels. Antimony and vanadium were·both detected in groundwater at concentrations that are driving an exceedance of the noncancer hazard goal (i.e., Hazard Index = 1). Antimony was detected in four of 16 groundwater samples (25% detection frequency) at concentrations ranging from 4.4 ug/L to 356 ug/L. Vanadium was detected in two of 13 groundwater samples (15% detection frequency) at concentrations ranging from 13.2 ug/L to 299 ug/L. It is important to note that these metals were detected in groundwater samples HULL & ASSOCIATES, INC. 9 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110. 701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0201, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. L BOOK: 18963 PAGE: 202 collected from soil borings and, therefore, suspended soil particles within the samples may result in an overestimate of the concentration of metals actually dissolved in groundwater. Although these COPCs were detected in limited locations across Area B, exposures to groundwater containing these COCs should be avoided. The NIOSH Pocket Guide (2005) riotes that exposure to antimony may result in irritation to the eyes, skin, nose, throat, and mouth, cough, dizziness, headache, nausea, v_omiting, diarrhea, stomach cramps, insomnia, anorexia, and/or the inability to smell properly. The NIOSH Pocket Guide (2005) includes potential health effects resulting from exposure to vanadium pentoxide dust or fumes (which are not likely to be the species pres_ent in groundwater at A~ea B) including irritation to the eyes and throat; green tongue, metallic taste, cough, fine rales (abnormal_ respiratory sounds characterized by fine crackles), wheezing, bronchitis, dyspnea (breathing difficulty), and/or eczema. 2.2.2 Polynuclear Aromatic Hydrocarbons (PAHs) According to the Agency for Toxic Substances _Disease Registry (ATSDR) public healt.h statement for PAHs (1995), PAHs are a group of chemicals that are formed during the incomplete burning ·of coal, oil, gas, wood, garbage, or other organic substances, such as tobacco and charbroiled meat. PAHs generally occur as single compound or complex mixtures of compounds including acenaphthene, acenaphthylene, anthracene, benzo(a)anthracene, be_nzo( a)pyrene, benzo( e)pyrene, benzo(b )fluoranthene, benzo(g, h, i)perylene, benzoU)fluor_anthene, benzo(k)fluoranthene, chry~ene, dibenz(a,h)anthracene, fluoranthene, fluorene, indeno(1,2,3-c,d)pyrene, phenanthrene and pyrene. PAHs usually occur naturally; however, not as the mixtures found in combustion products. Others are contained in asphalt used in road construction. They can also be found in substances such as crude· oil, coal, coal tar pitch, creosote, asphalt and roofing tar. As discussed in Section 1.2.1, soil collected from one sampling location (786) in sub-parcel B-3 was identified as a hot spot in accordance with MOE criteria. Constituents detected in the sample included benzo(a)pyrene, benzo(a}anthracene, benzo(b)fluoranthene, dibenz(ah)anthracene and indeno(1,2,3-cd)pyrene, however, the concentration of benzo(a)pyrene contributed most significantly to the exceedance of MDE hot spot criteria. Soil data collected during the RFI/Phase II indicates that benzo(a)pyrene was detected at a frequency of 30% a_cross Area B, at concentrations ranging from 0.089 mg/kg to 48 mg/kg. HULL & ASSOCIATES, INC. , 10 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110, 701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0202, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 203 However, it is important to note that elevated concentrations of benzo(a)pyrene were detected infrequently at Area B. Of the 112 soil samples analyzed for benzo(a)pyrene, three samples contained benzo(a)pyrene at a concentration greater than 1O mg/kg and the site-specific risk assessment conducted for Area B did not identify any unacceptable risk posed to construction/excavation workers by exposure to soil containing benzo(a)pyrene (excluding the hot spot described above). The NIOSH Pocket Guide (2005) publishes information on PAHs in the form of coal tar pitch volatiles. Health effects attributable to exposure to PAHs include dermatitis and bronchitis. Several PAHs, including benzo(a)pyrene have been identified by U.S. EPA as probable human carcinogens (U.S. EPA, 2007). HULL & ASSOCIATES, INC. 11 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA OUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0203, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 204 3.0 RISK MANAGEMENT PROVISIONS 3.1 Provisions for lmplementatlon of the RMP The RMP Is to be implemented whenever activities conducted at the Site may result in the exposure of workers to subsurface soils or groundwater that may contain COPCs in ~xceedance of applicable standards. 3.2 RMP Implementation for Soll MDE will be appropriately notifie~ in advance of conducting specific intrusive activities. Pursuant to the Certificate of Completion, notifications will be provided to the Chief, State Assessment and Remediation Division, Land Management Administration. 1 All personnel who may come in contact with soils currently located below two feet in depth within the landscaped areas_, or a.t any depth under the hardscape engineering controls, should take steps to minimize exposure by wearing appropriate personal protective equipment (PPE) such as gloves and practice good hygiene thereby minimizing the possibility of exposure through incidental ingestion or dermal contact. The supervisor(s) overseeing the work is responsible for implementing a HASP(s) that meets all federal, state and local laws and reg·u1atioi1s for each task that may result in exposure of workers to soil containing COPCs in exceedance of applicable standards. 3.3 RMP Implementation for Groundwater MDE will be appropriately notified in advance of conducting specific intrusive activities. Pursuant to the Certificate of Completion, notifications will be provided to the Chief, State Assessment and Remediation Division, Land Management Administration. The provisions for the management of potentially impacted groundwater will be applied to future intrusive activities which are conducted within the entire Area B parcel. All personne! who may come in contact with groundwater during intrusive activities are expected to minimize exposures to potentially impacted groundwater through the use of PPE and groundwater management activities. The supervisor(s) overseeing the work is responsible for implementing a HASP(s) that meets all 1 Notify MOE 30 days in advance of any planned intrusive activity that will breach an engineering control and/or will be conducted at a depth that will reach groundwater. For unplanned emergency excavation activities, notify MOE within 24 hours following initiation of the emergency. HULL & ASSOCIATES, INC. 12 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA . OUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0204, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 205 federal, state and local laws and regulations for each task that may result in exposure of workers to groundwater containing COPCs in exceedance of applicable standards. 3.4 Management of Impacted !=nvironmental Media In the event that potentially impacted environmental media is encountered, it will be necessary to manage the impacted material in a manner that does not compromise the integrity of the remedy. It is noted that the Division Chief of the Voluntary Cleanup Program will be appropriately notified in advance of conducting specific intrusive activities, as per the requirements of the Certificate of Completion issued by MOE. 3.4.1 Soil In order to ensure that the Site is returned to a condition that complies with applicable standards, potentially impacted soil encountered during intrusive activities shall be managed as described below: 3.4.1.1 Reuse of Soils within Landscaped Areas All soil excavated from the upper two feet of landscaped areas should be stockpiled separately from any soils excavated from a depth greater than two feet below ground surface. Soll that is stockpiled from the upper two feet of landscaped areas may be used at any depth at any locations on the Site. Soil that is currently located below the geotextile fabric (i.e., at depths greater than two feet bgs) must be replaced under an appropriate engineering control such as hardscape or clean soil cover underlain by geotextile marker fabric. 3.4.1.2 Reuse of Soils below Hardscape All soil that is currently located below hardscape such as building slab or a parking lot may be reused on-site as backfill below an appropriate engineering control such as hardscape or clean soil cover underlain by geotextile marker fabric. 3.4.1.3 Management of Vegetation within Landscaped Areas Duke is required by the City of Baltimore to plant over 2,000 trees on the overall 182- acre development (i.e., Facility-wide) as part of the City's reforestation efforts. The preferred landscaping method within Area 8 will be to limit plantings to trees with shallow root systems that will not penetrate the geotextile marker layer. However, a limited HULL & ASSOCIATES. INC. 13 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0205, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 206 number of larger trees with root systems that may extend below two feet bgs may ultimately be planted at the Site. For small trees or shrubs that are expected to have root balls contained within the upper two feet of soil above the geotextile fabric, all soil management should be conducted in accordance with the procedures for intrusive activities within landscaped areas detailed in Section 3.4.1. 1, above. The root ball of the tree or shrub should be placed in the planting hole at a depth above the geotextile fabric and the excavated area should be backfilled with a mixture of one-half parts approved soil and organic soil conditioner, as shown on Figure 4. In the event that a larger tree needs to be planted with a root ball that extends greater than two feet, all soil management must be conducted in accordance with intrusive activities that may result in contact with potentially impacted soil as described in Sections 3.4.1.1 and 3.4.1.2, above. The root ball of the tree or shrub should be placed in the planting hole and the planting hole should be backfilled with a mixture of one-half pc1rts approved soil and organic soil conditioner, as shown on Figure 5. In the event that a tree with roots that penetrate the geotextile fabric must be replaced in the future, it should be assumed that potentially impacted soil may be encountered below two feet bgs and that soil encountered at depth should be replaced at a depth greater than two feet. 3.4.1.4 Disposal of Soil at an Off-Site Facility Soils may be excavated and removed from the Site provided that they are properly characterized per applicable federal, state and local laws and regulations and in accordance with the requirements of the disposal facility. In the event excavated soils are stockpiled, surface water will be diverted from the piles and the stockpiles managed to prevent runoff and dust generation through the use of covers or other measures. All soils excavated from a depth greater than two feet will be placed on visqueen to insure that contamination (if present) will not impact the surface soils located on the Site. In addition, soil stockpiling activities, storm water control measures and dust control measures need to follow applicable federal, state and local laws and regulations. HULL & ASSOCIATES, INC. 14 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0206, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 207 3.4.2 Groundwater Intrusive activities may or may not encounter groundwater depending on the depth of the activities and variations in the depth to the water table across the Site. In the event that intrusive activities encounter groundwater that accui:nulates within property excavations, the following management activities will be imp.lemented: 1. The Owner shall be notified of the accumulated water and any proposed management methods immediately. Work will not proceed in the area if standing water remains; 2. Water may be either (1) tested according to the procedures discussed under pre characterization (see Section 3.1.1), or (2) assumed to be contaminated and managed appropriately; 3. If groundwater exceeds applicable screening levels or is simply assumed to be contaminated, worker safety will be provided by provisions within the Health and Safety Plan associated with the work activity; 4. Water will be pumped from the area and containerized or disposed before work can proceed; 5. Water may be containerized within temporary .storage tanks onsite, pumped directly from excavations into a vacuum truck or other equipment and transported to an appropriate off-site disposal or treatment facility, or pumped directly to sanitary or storm sewers under appropriate permits and in accordance with local, state and federal rules and regulations; 6. Containerized water placed into"temporary onsite storage tanks will ultimately be disposed or treated off-site at an appropriate facility, or pumped directly to sanitary or storm sewers under appropriate permits and in accordance with local, state and federal rule's and regulations; 7. Daily logs will be maintained that will identify the quantity and origin of all water managed during intrusive activities; and 8. All water management, treatment, disposal, etc. shall be conducted in accordance with applicable local, state and federal rules and regulations. HULL & ASSOCIATES, INC; 15 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA OUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0207, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 208 4.0 MAINTENANCE OF REMEDY 4.1 General In general, applicable standards have been met at Area B through the implementation of institutional and engineering controls. The engineering controls (i.e., hardscape or clean cover soil) are passive remedies and, therefore, will not be subject to active operation requirements. A discussion of the requirements for maintenance of the engineering controls is located below. 4.2 Engineering Control Maintenance Requirements Engineering controls in the form of hardscape and clean cover soils will be maintained across the Site to prevent direct contact exposures to onsite receptor populations. The Owner will adopt appropriate inspection and maintenance procedures for the engineering controls into the facility Operations and Maintenance plans. Hardscape such as parking areas and concrete slabs will be inspected annually in the fall. Landscaping crews will inspect greenspace areas for exposed marker fabric during routine maintenance activities such as mulch application, grass cutting and tree pruning. Formal greenspace inspections will take place during the fall concurrent with the hardscape inspections. Pursuant to the RAP, the Owner will notify MOE of any necessary repairs to hardscape or greenspaces within ten business days of discovering the condition requiring repair. The Owner will submit written findings from the annual fall inspections to MOE within ten business days of conducting the visual inspections. The written findings will include observations of the cover and actions taken in its maintenance or modification and a new Site Plan showing cover modifications, if necessary. HULL & ASSOCIATES, INC. 16 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110,701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0208, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 209 5.0 COMMUNICATIONS, RESPONSIBLE PARTIES, DOCUMENT CONTROL AND REPORTING 5.1 Communications and Notification Provisions Flow charts describing the procedures for internal and external Gommunications with respect to the RMP are shown on Figure 6, Notify MOE 30 days in advance of any planned intrusive activity that will breach an engineering control and/or will be qonducted at a depth that will reach groundwater. For unpianned emergency excavation activities, notify MOE within 24 hours following initiation of the e~ergency. 5.1.1 Site Workers The Owner is responsible for providing this RMP to site workers, employees, and subcontractors that perform subsurface activities at the Site. The supervisor for those performing work that may result in the implementation of the RMP is responsible for providing an applicable HASP and ensuring that activities conducted within Area B do not result in exposure of workers to levels of hazardous chemicals in exceedance of applicable federal, state, and local laws and regulations. Workers performing activities that may result in RMP implementation are required to review this document and sign the worker acknowledgement form located in Appendix A. 6.1.2 Tenants/Lessees Tenants/Lessees are prohibited from making modifications to the property as a condition of the lease. 6.1.3 Emergency Response The Site and surrounding area are serviced by local fire, police and emergency medical services that can be reache~ ~Y phone via 911. Emergency response and contingency communication procedures will be outlined in the HASP associated with the intrusive activities. 5.2 Responsible Parties As discussed previously, the ·owner is responsible for ensuring that the RMP is implemented, as appropriate, and is responsible for maintenance of the document and supporting addenda, as needed. In addition, the Owner is respon~ible for ensuring that the annual inspection of ~he engineering controls is conducted and documented in accordance with the provisions located in HULL & ASSOCIATES, INC. 17 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA OUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0209, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 210 this RMP. The Owner may conduct internal audits and management review of this environmental management system at the Owner's discretion. The supervisor(s) overseeing the work is responsible for providing and implementing a HASP(s) for each site-specific task and phase of work which may result in the implementation of the provisions for the RMP. It is the supervisor's responsibility to ensure that activities conducted within Area B do not result in exposure of the workers to levels of hazardous chemicals in exceedance of applicable federal, state, and local laws and regulations. It is the responsibility of the supervisor to show proof of applicable training or licensing that may be r~q~ired by federal, state or local laws and regulations including, but not limited to, Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) 40 hour training. It is up to the discretion of the Owner to verify that all personnel conducting subsurface activiti~s on the Site meet the requirements of all applicable federal, state, and local laws and regulations. The RMP may only be modified or terminated upon mutual agreement of the Owner and the Maryland Department of the Environment. 6.3 Reporting Findings fro~ the annual fall inspections will be recorded on the Inspection Documentation Form located in Appendix C. The annual inspection form describes the results of the inspection (e.g., integrity of the engineering controls) and type and location of any required actions. The Owner will notify MOE of any necessary repairs identified during the annual inspection within ten business days of discovering a condition requiring the repair of an engineering control(s). The notification to MOE will be conducted using the Inspection Documentation Forni. The Owner will submit written findings from the annual inspections to MOE within ten business days of conducting the inspections. The written findings will be submitted to MOE as an attachment to a copy of the completed Inspection Documentation Form. In addition, the Owner will submit the Notification of Modification or Repair of Engineeri_ng Control Form in Appendix D, as well as any necessary supporting materials (e.g., amended site plan), to MDE upon completion of activities conducted to modify and/or repair an engineering control(s). Outside of the annual inspection process, the Owner will notify MOE of necessary repairs identified at any time within ten business days of discovering a condition requiring the repair of an engineering control (e.g., routine inspection of a greenspace area Identifies exposed geotextile marker fabric). In these instances, the Notification of Modification or Repair of HULL & ASSOCIATES, INC. 18 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110. 701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0210, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 211 Engineering Control Form in Appendix D, as well as any necessary supporting materials, will be submitted to MOE upon completion of activities conducted to maintain and/or modify an engineering control(s). The Owner will submit written findings from unplanned/emergency excavation activities to MDE within ten business days of completing the emergency excavation activities. 5.4 Document Control The Owner is responsible for maintaining a copy of this RMP at the facility and is responsible for making the document available upon request. Inspection documentation (i.e., the Inspection Documentation Form in Appendix C) will be retained for a minimum period of five (5) years. Records relating to the notification of workers who may conduct work at Area B (i.e., the Worker Acknowledgement form in Appendix A) or records relating to modification or repair of engineering controls (e.g., Notification of Repair or Modification of Engineering Control in Appendix D), including revised Site Plans will be appended to the RMP and will be retained in perpetuity. HULL & ASSOCIATES, INC. 19 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0211, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 212 6.0 REFER°L~NCES Agency for Toxic Substances Disease Registry. 1995. Public Health Statement for Polyaromatic Nuclear Hydrocarbons. Available on line at: http://www.atsdr.cdc.gov/toxprofiles/phs69.html. Hull & Associates, Inc., 2005, Health and Safety Plan for the Former General Motors Corporation Baltimore Assembly Plant, DUK030.200.0002, December 2005. Hull & Associates, Inc., 2006a, Revised Risk Evaluation Methodology: Comparison Matrix of Region Ill RCRA Corrective Action . and Maryland Department of the Environment Voluntary Cleanup Programs, DUK033.200.0034.xls, April 2006.· · · · Hull & Associates, Inc., 2006b, Phase I Environmental Site Assessment of Fonner General Motors Corporation Bawm·ore Assembly Plant, DUK033.200.0032, May 2006. · Hull & Associates, Inc., 2006c, Quality Assurance Project Plan for the RCRA Facility Investigation and Phase II Environmental Site Assessment, DUK030.200.0004, May 2006. Hull & Associates, Inc .• 2006d, RCRA F~cl/ity Investigation Work Plan, DUK038.200.0038, June 2006. Hull & Associates, Inc., 2007a, RCRA Facility lnvesti~ation/Phase II Environmental Site Assessment and Corrective Measures Study (Reyisio_n 1.0), Area B - Fonner General Motors Corporation Baltimore Assembly Plant, DUK037.200.0008, March 2007. Hull & Associates, Inc., 2007b, Revised Response Action Plan (Revision 1.0) for Area B - Former General Motors Corporation Baltimore Assembly Plant, DUK036.200.0010, July 2007. Maryland Department of the Environment, Cleanup Stand_ards for Soil and Groundwater, Interim Final Guidance, August 2001. Maryland Department of the Environment, Voluntary Cleanup Program Guidance Document, March 2006. Maryland Department of the Environment, Voluntary Cleanup Program Response Action Plan Guidelines, March 17, 2006~ Nation~! Institute for Occupational Safety and Health (NIOSH) Po~ket Guide to Chemic?! Hazards. NIOSH Publication No. 2005-149. September 2005 Available online at: http://www.cdc.gov/niosh/npg/. U.S. EPA, Interim Final RCRA Facility Investigation (RF/) Guidance - Volumes I through IV, EPA/530/SW-89-031, May 1989. U.S. EPA. Integrated Risk Information System (IRIS). Available online at http://cfpub.epa.gov/ncea/iris/index.cfm, December 2007. HULL & ASSOCIATES, INC. 20 SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA . DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0212, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 213 TABLES HULL & ASSOCIATES, INC. SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0213, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0214, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. RISXltl:AHII.GEMENTPt.AMFORAREA.B•SU~.ulCEL&1 CHESAPEAKE COMMERCE CEN1'£R 1,'FOR-.S. GEN£RAL JIOTORS CORPORA.tKJN BALTIMOflEASSEllBL.Y P'LIJff ~ 915 HOUDD A.VENLE, 8A....11MORE,.MAR"R.AND 212:24 TAS.:..£.'I Jl:Ea.llR2D COMPONENTS OF INTERNAnlNAL STAN DAROS CflG.\HIZATlOMI lSO 14001 ENVTRDkMENT.A.L JUJfAGE.MEKT SVS'TclLS ,.llloO--...... ,._.,, ....,"""""""' ...... ,,,.,_, ______... -- ...... RM"lasoartol_,.,._ ~-----f~~5:mw~ _,.,__,_ -~ 11111 RMP n:li.oes ~ HSE tlemenll arc -.-s ~ l>meel die~ cdll'fe; (iln,!II IWCOl1ale 10lhl HA ~ 5C'M .,,O~ ~ ol dS KIMCDl.. lrd..dr:s a~ lO oor&..&al~nl PCi pq,,zniert --ba,n-ciy..th _,_...,. f"-- .., -~--_,., ... __... seu;,gand- HSE?dq ~--,_., ,_ ~-•DOerd-11.ls _____ ...., __ hed,b-lO lpeqcns i->'11'°'"'""-clt> ~oncllsr-~l>l"•Pl,l,k. ~ 11nt RM? cctt.a1nsa~or~ eaects as a ~d pot.Jnllfe:qxGSe:S l>COFCc lh81 may t,9,enco.,nwac, Stabtl 2.0•SLffllllllBl)'dPtelttl:alHeelh RlrtSl!tSIOC1lleCIIICJ'IOOPCS-atArea8 HSc""""' h~~...,~~echlles. n. :U.C? bas~ pnparect 1a 800Cl'd:llra wth tne Response Acio'LPlan as ,..,,.ewec,..,,ct~~~-- - 1.,-B d',Jauxl i..v,ardO,,_R_,, ..,_.,tm10o-clt,eEn,.-\ H.IU.'-~.IMC. olit.GUITZ,14 PfTT'S BOOK: 18963 PAGE: 215 FIGURES HULL & ASSOCIATES, INC. SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110. 701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0215, MSA_CE164_28120. Date available 03/23/2017. 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'. '. '. '. . . ;.t•II,; ;.t•II,; HOLABIRD HOLABIRD - -c':7··,---n-_ -c':7··,---n-_ '. '. Ii Ii . . l l u u ; a-..i, a-..i, ; ; _i _i 8' 8' .,..:.;J.L_J...._,:__t..-.,..._ .,..:.;J.L_J...._,:__t..-.,..._ ,h_ ,h_ i ' ' i ·, ·, --~ --~ l, l, -•' -•' C C H H .. .. _ _ :1 :1 . . _, _, ;;.' ;;.' i'E i'E ~1~,t ~1~,t [';, [';, 1' 1' ~"2,lt.22 ~"2,lt.22 r r ' ! : ; ; : ! j,-l>"24 j,-l>"24 i i • • L L - . 1·-li·_•'1n;·_;-q- ~;.ss:2_·511·, ~;.ss:2_·511·, - u~-';~~~~~: u~-';~~~~~: I I - • ·I ·I : - : l ' ; l l : j j .,~ .,~ I· I· t t 8 '•~ '•~ t t : : '-•-• '-•-• t sa;.-H sa;.-H '. '. 1· 1· 1· 1· ~;: ~;: 11"8"24'55" 11"8"24'55" _1:, _1:, -- AREA AREA ' ' t1n:i t1n:i l:'•l'f l:'•l'f .. .. 1· 1· ca/=247.15 ca/=247.15 I I l : __,;llTl~"W __,;llTl~"W ~-n-r~~t ~-n-r~~t I I : • • I I : : ,, ,, . . ' '.I '.I :1J,,,ilc1_,_trl.d11:1J :1J,,,ilc1_,_trl.d11:1J ' ( ( ' , , I I • - 1 1 , ,, ,, ··11d_r_ ··11d_r_ PAVED PAVED p p __ __ -- ~-•- ': ': n. n. ,. ,. l : : l AREA AREA ,. ,. ; : : ; I I ,,•J ,,•J , , l:: l:: -,'.·.) -,'.·.) .,_.,, .,_.,, 1· 1· ,..1.., ,..1.., U.. U.. ; ; 2 '=-=--=- !lf:ITTI !lf:ITTI ~rT(""""TI(7 ~rT(""""TI(7 G1!Eal G1!Eal EXISTING EXISTING S6740"47'W S6740"47'W /7 /7 BOWMAN BOWMAN ·1r·• ·1r·• ~' ~' \.JI \.JI ! ! - ( ( ( ( J J _\...;1, _\...;1, \. \. LEGEND. LEGEND. SY SY / / - ' ' l __ __ t t - i i ' ' ~ ~ ( ( ( ( ( ( ! ! i i , , \ \ I I I I _ _ i 1-. 1-. --629,00' --629,00' - . ~ ~ , , . . "' "' I I ; ~ ~ 1- ' ' 1_ 1_ D D D D SURVEY SURVEY ' ' ! 11 11 j j l l l l ~ ~ ~ ~ l I I } ' ' ; ' ' l \\ \\ \I \I I I i i 1 l l -\ -\ ~ ~ - - 20.°' 20.°' 4 4 -- M.AROI M.AROI ON ON 8ASED 8ASED NOTE: NOTE: l.A'IOOT l.A'IOOT ·OONSUlfflG, ·OONSUlfflG, BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0218, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 219 SMALL TREES OR SHRUBS +. _~DIG PLANTING HOLE TWICE THE + _;TT DIAMETER OF THE ROOT BALL· MINIMUM 2' ~ BACK FILL WITH MIXTURE 1/2 OF CLEAN APPROVED SOIL AND 1/2 ORGANIC COVER SOILS SOIL CONDITIONER, PULVERIZE OR CHOP SOIL TO REMOVE CLODS ANO CLUMPS. GEOTEXTILE-::KER 7 (FILTER FABRIC) TYPICAL DETAIL FOR LANDSCAPE AREA (SMALL TREES AND SHRUBS) NOT TO SCALE RISK MANAGEMENT PLAN FOR AREA B • SUB-PARCEL 8-1 CHESAPEAKE COMMERCE CENTER ( FORMER GM ASSEMBLY PLANT) FIGURE 4 ll HULL TYPICAL DETAIL FOR LANDSCAPE AREA SROWNFIELOS (SMALL TREES AND SHRUBS) SHAl,.E OIL & GA$ 6975 HOLABIRD AVE, WASTE MANAGEMENi ©2013 Hull & MOOClatos, Inc. BAL TIMOOE, MARYLAND 21224 0397 gaarAIU PRrl + _ DIG PLANTING HOLE TWICE THE + DIAMETER OF THE ROOT BALL· MINIMUM 2' BACK FILL WITH MIXTURE 1/2 OF CLEAN APPROVED SOIL ANO 1/2 ORGANIC COV~R SOILS SOIL CONDITIONER. PULVERIZE OR CHOP SOIL TO REMOVE CLODS ANO CLUMPS. GEOTEXTILE MARKER (FILTER FABRIC) TYPICAL DETAIL FOR LARGE TREE PLANTINGS NOT TO SCALE RISI< MANAGEMENT PLAN FOR AREA B • SUB-PARCEL B•1 CHSSAPaAKe COMMERCE CENTER ( FORMER OM A8$Eij8L Y PLANT) FIGURE 5 ll HULL TYPICAL DETAIL FOR BROWN FIELDS LARGE TREE PLANTINGS SIIALE OIL & GAS 6975 HOLA!l!RD AVE, ©2013 Hull 5 As,oci6t6a, Inc. BALTIMORE, MARYLAND 21224 WASTE MANAGEMENT 8397 E1er1ld Pnrkwoy Phone: (614) 793-6777 ...,....,.....,.....,___ ....;;,;.;.;,;~_,;;.;.;,;,.,;~;.;.;;;;.;.. ______~ l;NVlRONMENl'AL Sulla 200 r .. , (614) 783,8070 PROJECT NO,: DUK110 SUBMITTAL DATE: SEPT, 2014 ALTERNATIVE ENERGY Dublin, Ohlo 4301G w.i.w.hulltnc.CQII CAD DWG FILE: DUK110,200,0004 PLOT OATe: 9/3/14 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0220, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. ~ ~ O'I O'I CJ,, CJ,, 00 00 N N ~ ~ N N v:; v:; c:, c:, ...... ...... ~ ~ 0 0 0 0 2014 2014 DUK110.701.0007 DUK110.701.0007 SEPTEMBER SEPTEMBER of of of of form form workers workers Performing Performing PLANT) PLANT) provisions provisions of of implementation implementation Activities Activities RMP RMP RMP RMP implementation implementation Subcontractor Subcontractor Activities Activities of of training training of of l l B-1 B-1 LINES LINES acknowledgement acknowledgement for for Intrusive Intrusive Employees Employees properimplementation properimplementation proper proper ASSEMBLY ASSEMBLY proper proper results results j j workers workers worker worker 7 7 Intrusive Intrusive provisions provisions provisions provisions Reports Reports RMP RMP Supervises Supervises Signs Signs RMP RMP Ensures Ensures Notifies Notifies Conducts Conducts Supervisor Supervisor Performing Performing REPORTING REPORTING SUB-PARCEL SUB-PARCEL RMP RMP • • • • • • • • • • • • of of Subcontractor Subcontractor of of results results B B - of of AND AND GM-BALTIMORE GM-BALTIMORE supporting supporting AREA AREA activities activities Chief Chief completion completion and and reporting reporting Owner Owner personnel personnel implementation implementation to to Owner Owner OR OR FOR FOR and and VCP VCP RMP RMP Site Site proper proper intrusive intrusive FIGURES FIGURES {FORMER {FORMER Chart Chart Site Site RMP RMP proper proper MOE MOE PLAN PLAN provisions provisions Ensures Ensures Flow Flow Maintains Maintains provisions provisions documents documents COMMUNICATION COMMUNICATION Notifies Notifies RMP RMP Ensures Ensures Provides Provides performing performing of of CENTER CENTER • • • • of of form form • • • • • • RMP RMP OF OF workers workers Employees Employees provisions provisions Performing Performing of of implementation implementation Activities Activities MANAGEMENT MANAGEMENT RMP RMP implementation implementation RMP RMP Implementation Implementation Owner Owner implementation implementation COMMERCE COMMERCE Activities Activities of of training training of of r r L L acknowledgement acknowledgement RISK RISK l l Intrusive Intrusive Site Site and and proper proper SUMMARY SUMMARY proper proper Employees Employees proper proper results results for for workers workers \VOiker \VOiker Intrusive Intrusive provisions provisions provisions provisions Owner Owner Signs Signs RMP RMP Reports Reports RMP RMP Ensures Ensures Notifies Notifies SupeNises SupeNises Conducts Conducts Performing Performing CHESAPEAKE CHESAPEAKE Site Site Notification Notification • • • • • • • • • • • • Supervisor Supervisor RMP RMP General General - 6A 6A Figure Figure BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0221, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. N N O'I O'I ~ ~ N N v:; v:; N N 00 00 ~ ~ c:, c:, ...... CJ,, CJ,, 0 0 ~ ~ 0 0 2014 2014 DUK110.701.0007 DUK110.701.0007 to to SEPTEMBER SEPTEMBER RMP RMP area) area) during during to to or or of of MDE MDE repairs repairs to to on on completion completion to to Identified Identified exposed exposed personnel personnel engineering engineering form form repairs repairs identified identified according according days days repair repair of of greenspace greenspace (e.g., (e.g., of of recorded recorded Owner Owner in in n,ecessary n,ecessary Admin. Admin. Employees Employees Repair Repair Owner Owner ! ! repair repair ! ! ! ! control control of of Inspections Inspections repairs repairs PLANTI PLANTI records records days days appropriate appropriate Site Site provided provided Site Site necessary necessary modification/repair modification/repair fabric fabric business business the the Subcontractor Subcontractor MDE MDE ten ten form form activities activities inspection inspection Owner Owner ten ten be be and and requiring requiring Mgmnt Mgmnt Requiring Requiring Routine Routine Site Site B-1 B-1 provisions. provisions. Maintains Maintains Submits Submits engineering engineering within within modification/repair modification/repair Conducts Conducts Repair Repair control control will will LINES LINES conduct conduct Schedules Schedules Notifies Notifies within within geotextile geotextile routine routine Area Area • • • • Area Area ASSEMBLY ASSEMBLY Land Land • • • • • • • • • • Assessment Assessment SUB-PARCEL SUB-PARCEL REPORTING REPORTING Division, Division, notifications notifications B B - State State AND AND GM-BALTIMORE GM-BALTIMORE MDE MDE 6 6 AREA AREA Chief, Chief, FOR FOR inspection inspection inspection inspection the the Remediation Remediation NOTE: NOTE: FIGURE FIGURE (FORMER (FORMER Necessary Necessary PLAN PLAN annual annual records records COMMUNICATION COMMUNICATION Not Not on on CENTER CENTER of of of of RMP RMP results results Inspector Inspector form form and and and and RMP RMP Repairs Repairs days days OF OF • • ten ten to to the the ten ten form form completion completion MANAGEMENT MANAGEMENT Performing Performing within within engineering engineering hardscape hardscape activities activities within within COMMERCE COMMERCE and and of of of of according according conducting conducting MOE MOE RISK RISK inspection inspection MOE MOE Owner Owner of of SUMMARY SUMMARY OR OR Owner Owner to to Inspections Inspections ! ! submits submits Inspections Inspections to to areas areas reoords reoords inspection inspection Employees Employees Site Site days days Site Site Chart Chart annual annual scheduling scheduling form form results results inspections inspections completion completion Annual Annual on on of of Annual Annual Flow Flow ten ten necessary, necessary, Owner Owner CHESAPEAKE CHESAPEAKE provisions. provisions. Maintains Maintains control control repair repair If If modilicationfrepair modilicationfrepair Submits Submits written written inspection inspection business business Conducts Conducts annual annual Ensures Ensures greenspace greenspace annual annual form form MOE MOE repairs repairs of of Site Site within within • • • • • • • • • • recorded recorded using using control control personnel personnel notifies notifies Reporting Reporting repairs repairs form form Necessary Necessary days days necessary necessary activities activities Owner Owner RMP RMP - I I engineering engineering inspection inspection modification/repair modification/repair Repairs Repairs business business conduct conduct Repair Repair necessary necessary Site Site Appropriate Appropriate 6B 6B • • • • • • Figure Figure BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0222, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 223 APPENDIX A Worker Acknowledgement Forms HULL & ASSOCIATES, INC. SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110.701 .0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0223, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 224 WORKER ACKNOWLEDGEMENT OF RISK MANAGEMENT PLAN I HAVE READ AND FULLY UNDERSTAND THIS RISK MANAGEMENT PLAN AND AGREE TO COMPLY WITH ITS CONTENTS DURING THE COMPLETION OF THE TASKS OF THIS PROJECT. NAME HULL & ASSOCIATES, INC. SEPTEMBeR 2014 PITTSBURGH, PENNSYLVANIA DUK110. 701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0224, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 225 APPENDIX B NIOSH Contact Information and Example Chemical Data HULL & ASSOCIATES, INC. SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0225, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. L BOOK: 18963 PAGE: 226 The National Institute for Occupational Safety and Health (NIOSH) can be located at the following: World Wide Web: http://www.cdc.gov/niosh/topics/chemical-safety/default.html Telephone: 1-800-CDC-INFO (1-800-232-4636) or Outside the U.S. 513-533~8328 Fax: 1-513-533-8328 The attached page is an example of the type of information available from NIOSH. This reference for vanadium is excerpted from the NIOSH Pocket Guide to Chemical Hazards (NPG). Sources other than the NPG are also available. Those can include the Agency for Toxic Substances and Disease Registry, Hazardous Materials Safety - Emergency Response Guidelines, and others. These can also be found through NIOSH at the following World Wide Web address: http://www.cdc.gov/niosh/topics/chemical-safety/default.html. HULL & ASSOCIATES, INC. SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0226, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. BOOK: 18963 PAGE: 227 CDC"' NIOSH Pocket Guide to Chemical Hazards - Vanadium dust Page 1 of 2 ~.Cen,ters for Disease Control and Prevention ~ CDC 24/7: S,ivlng Uv~. Protecting People."' Search the Pocket Guide ..._ ___..,.... ______.IN;Jlii Enter search terms separated by spaces. j _··--·_·· --~--"~~::~:~:~~~~:~:::__...... _. _v_a_n_a_d_i_um_d_u_st______I S~•non)11\.~ &. Trade N11mc~ Divanadium pentoxide dust, Vanadic anhydride dust, Vanadium oxide dust, Vanadium pentaoxide ~ust Other: synonyms vary depending upon the specific vana~um compound. CASNo, 1314-62-1 R1'l'.C$No. DOT Ill & (h1.i(f,; 2862 151 (htt11: uwwwagg~.ti;:,gc,~ L~i!f•S~•sur L3Lerg- ~2~50000 (Lniosh- gllll! &•:gLguigegage.asgx?guide-!Sll. cQ. rt~-;LYW256250.htmll (httg: lb~~.~c,ggi1LQ1hi;:tL!!i~l1.1in1~r.html) Fo~in11h1 V205 I Co11vc1·Alo11 1 m1.11 35 mg/m3 (as V) : See: vandust (LniQshLidlhLllilDQIISt,lllWll Exposure Limits McaRurcmcnt J\lcti;ods NIOSH 23.QQ.. ~ (lniosbLd~-;L2003-15.4Lgdfah3gg,cdO, 23Q!.~ N1os11 REI, *: C 0.05 mg V/m3 (15-minute] CL.nig~bLd~L2003-154tpdfstz3Q1.pdfl , 2.3.Qa.~ (*Note: The REL applies to all vanadium compounds except Vanadium metal and. £L11io:ihls!a1:,-;L2003-154LgdfsL7303,gdO, ~~ Vanadium carbide (see Ferrovanadium UnioshLdocs·t2003-154Lpdfshsg4,cdO. ™ ~ dust).] . (LniQsh£docsL2003-154Loof:iL!U!l~,1,2i;lQ ; OSHAID185 OSHA l'liL t Cllengamlxg,htmn : C 0.5 mg (httn:LLwww.osha.gQvldtsL5hcLwethQi!i;LinorganicLid185Lid185.htmll V:i0 5/m3 (resp) r!i1 (bU12;LLwww,i;:ge,g,QvLQtherLdisclaimer.html} See: NMAM UniQshLdocsL2003-154Ll or OSHA Methods (lit1u; l£www.osha.gQv ldt~~ltc/m~bgd5Li11de~.lltml) lfil (httg: LLW\~.cdc,ggi1LQ11lecldi:iela im~r.html) - . Pl~,·~icJtl lk~criptio11 Yellow-orange powder or dark-gray, odorless flakes dispcrs~d i!} air. Sol; MW: BP: 3182°F MLT: o mmHg (approx) NA o.8% IVP: 181.9 (Decomposes) 1~74°F 11 •~: I S11,G1·: NA um,: NA J.F,l.i NA 3.36 li11.I': I Non_combustible Solid, but may increase intensity of fire when in contact with combustible materials . . . 111~om11~tlhlllticR & ReactivitieR Lithium, chlorine trifluoride fo,-p11~1•r~, ~01111:~ inhalation, ingestion, skin and/or eye contact .. Symptoms initation eyes, skin, throat; green tongue, metallic taste, eczema; cough; fine rales, wheezing, bronchitis, dyspnea (breathing difficl!,lty) Tar/iet (~r~allH Eyes, skin, respiratory system Pcr/mnn\ Pr11h:cllo11/Sn11ltatio11 (Sec Rroti:i.:ti!l!l Hr~tAld (See 32roccdurcs (fi~taid,html)) ~d!i:!i (cc~m:ct,btmll) Eye: Irrigate immediately Skin: Prevent skin contact Skin: Soap wash promptly Eyes: Prevent eye contact Breathing: Respiratoty suppo1t Wash skin: When contaminated Swallow: Medical attention immediately Remove: When wet or contaminated Change: No recommendation BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0227, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. http://www.cdc.gov/niosh/npg/npgd0653. html 8/11/2014 BOOK: 18963 PAGE: 228 CDC - NIOSH Pocket Guide to Chemical Hazards - Vanadium dust Page 2 of 2 R•~~plr,;hu· R1•.t(11111n&lnd11tlons NIOSH (as V) .. Up to 0;5 mg/m3: . (APF"' 10) Any air-purifying respirator with an N100, Rl.oo, or P100 filter (including N100, Rloo, and P100 filtering facepicces) except quarter-mask respirators. Click here (pgintrod.html#nl'Ql for infonnation on selection ofN, R, or P filters.* (APF = 10) Any supplied-air respirator* Up to 1.25 mg/m3: . (APF"' 25) Any supplied-air respirator operated in a continuous-flow mode* (APF"' 25) Any powered, air-purifying respirator with a high-efficiency particulate filter.• Up to 2.5 mg/m:i: . . (APF = so) Any air-purifying, fu!Hacepiece respirator with an N100, R100, or P100 filter. Click here (pgintrod.html#nrol for infoimation on selection of N, R, or P filters. (APF = 50) Any powered, air~purifying respirator with a tight-fitting facepiece and a high-effi~iency particulate filter* (APF = 50) Any self-contained breathing apparatus with a full facepiece (APF"' 50) Any supplied-air respirator with a full faccpiccc Up to 35 mg/in:i: (APF = 2000) Any supplied-air respirator that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode Emergency or planned entry into unknown concentrations or IDLH conditions: (APF"" 101000) Any self-contained breathing apparatus that has a full facepiece and is operated in a pressure- demand or other positive-pressure mode · (.APF = 10,000) Any supplied-air respirator that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode in combination with an auxiliary self-contained positive-pressure breathing apparatus Escape: (APF = 50) Any air-purifying, full-facepiece respirator with an N100, R100, or Pl.Oo filter. Click here (pgjntrod.htnJl#uml for infonnation on selection of N, R, or P filters. Any appropriate esqape-type, self-contained breathing apparatus Impo1tant additional information aboutres1,irator selection (pgiritrod.html#mustread) See also: INTRODUCTION f/niosh/npgLngjntrod.htmn See MEDICAL TESTS: 0240 ({niosh/docs/2005• 110/nmedo240.htmU ______,...... ,..,_,. ____ .. ______Page last reviewed: April 4, 2011 l'~gc last u11dated: November 18, 2010 . Content source: Natlnno! ln~titute forOccu1>ational Safety and Hgalth CW.C:lHl Education nnd lnfonnaiion Oi,ision ------,----:---,------•"''""'"'~'·•··~-·--····--- Ccntcrs for Disease Control and Prevention 1600 Clifton Rd. Atlanta, GA 30333, USA 800-CDC-INFO (800-232-4636) '!TI: (888) 232"6348- Contact CDC-INFO I I I 8/11/2014 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0228, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. http://www.cdc.gov/niosh/npg/npgd0653 ;html BOOK: 18963 PAGE: 229 APPENDIX C Inspection Documentation HULL & ASSOCIATES, INC. SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0229, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. ------·-- -- BOOK: 18963 PAGE: 230 AREA B - SUB-PARCEL B-1 FACILITY INSPECTION . DOCUMENTATION FORM Required element for inspection: Action required? Yes No Integrity of hardscape areas (parking areas, concrete floors, etc.)? Exposed geotextile fabric in greenspace areas? Dead or dying trees in greenspace areas? .. Unauthorized m_odifications to hardscape areas (parking areas building slabs, etc.)? Type and location of needed action(s): Supporting Materials - list and attach supporting materials Note: At a minimum, a written summary of the a_nnual inspection is to be submitted along with this form to MOE within ten business days of conducting the visual inspections. The Owner will notify MDE of any necessary repairs within ten business days of discovering the condition requiring repair via this form. The Owner will submit written findings from the annual fall inspections (attached to a copy of this form) to MDE within ten business days of conducting the visual inspections. The Owner will submit the Notification of Repair or Modification of Engineering Control Form to MDE within ten business days of conducting any repair or modification. HULL & ASSOCIA1'ES, INC. SEPlEMBER 2014 PITTSBURGH, PENNSYLVANIA . DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0230, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. L r BOOK: 18963 PAGE: 231 APPENDIX D Notification of Modification or Repair of Engineering Control HULL & ASSOCIATES, INC. SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA OUK110. 701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0231, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. ....,,. BOOK: 18963 PAGE: 232 ' AREA B - SUB-PARCEL B-1 FACILITY NOTIFICATION OF REPAIR OR MODIFICATION OF ENGINEERING CONTROL FORM Date: Location of Repair or Modification: Detailed Description of Repair or Modification: Personnel involved in modification or repair: Supporting Materials - list and attach any necessary supporting materials (amended site plans, etc.) The Owner will notify MOE of any necessary repairs within ten business days of discovering the condition requiring repair. The Owner will submit this form to MDE within ten business days of conducting the modification or repair. HULL & ASSOCIATES, INC. SEPTEMBER 2014 PITTSBURGH, PENNSYLVANIA DUK110.701.0005 BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0232, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018. -air BOOK: 18963 PAGE: 233 ,, 3030 ', 80. .Ja ;.~ toa:'.l ·- t:0. - rn .. 8/Zi'.n 1 1. vi q J 1 q,{ ti l q ,3.J ow L H e 8 - t08iJJ Z92~LGL# S:1-· VZJ~) sr=~0 Lt0z1st1s0 ©Q.l"SE : 1_e.y:i1 00·0~ ~DJ24J.Jns - ~l G~I8~·~70H 5L65 : ;aa "'.)77 ':!~O~iil 7\-i::i ;1;,1nQ :,3WerJ '.j.lJE.jel_J-:1Q 00"SL aaj au~pJaaa~ 1ueuana31uo~1eJeLJaQ - )fl MAR 1 5 2017 CIRCUIT COURT FOR BALTIMORE: QITY ~ BALTIMORE CITY CIRCUIT COURT (Land Records) MB 18963, p. 0233, MSA_CE164_28120. Date available 03/23/2017. Printed 06/11/2018.