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Hazardous Waste Cleanup: W.R. Grace in Baltimore, Maryland

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Cleanup Status

Grace submitted the Corrective Measures Study (CMS) Report in February 2014.  The CMS was approved by EPA on June 23, 2014, with the stipulation that site specific conditions prevented groundwater restoration to MCLs and therefore EPA would propose a Final Remedy that included a Technical Impracticability for groundwater restoration. Based on the CMS results and the Administrative Record, the final remedy for the Facility was developed and was described in a Final Decision and Response to Comments that was issued on September 4, 2014.

The final remedy for the Facility consists of establishment of a TI zone for groundwater and long term monitoring and reporting of groundwater and offshore sediments and pore water. Additionally, the Facility is required to enforce Land and Groundwater use restrictions.  The Final Remedy is implemented through an Administrative Order On Consent signed September 25, 2015.

Cleanup History

In June 2002, EPA and W.R. Grace entered into a RCRA Administrative Order on Consent (AOC). The AOC required Grace to perform the following activities at the site: (1) complete an Environmental Indicator Assessment Report/Phase I RCRA Facility Investigation (RFI); (2) complete a more comprehensive Phase II RFI; (3) complete a RCRA CMS; and, (4) complete Interim Measures, if necessary.

Between 2001 and 2004, Grace completed several field investigations to determine groundwater flow beneath the site and to confirm that groundwater discharges to adjacent Curtis Bay and Curtis Creek. Investigations also included sampling of groundwater on the site, and sampling of sediment and surface water in Curtis Bay and Curtis Creek. In September 2004, based on the results of these investigations and a review of historical information, EPA determined that Current Human Exposures are Under Control at this facility. The determination for the Migration of Contaminated Groundwater Under Control was completed in the July 2005.

In the summer of 2006, and spring of 2007, Grace conducted further surface water, sediment, ground water, and soil investigations to further characterize the site. A comprehensive RFI Report was submitted to EPA in May 2008.

EPA approved the RCRA Facility Investigation (RFI) in  May 28, 2009, and subsequent Human Health Risk Assessment Report (HHRA) in  November 7, 2012, on December 19, 2012.  With the RFI approval EPA requested that a CMS be undertaken pursuant to the AOC. In March a meeting was held between Grace and EPA where a proposal to implement a voluntary focused excavations was proposed.  Subsequently EPA approved an extension of the CMS submittal allowing consideration of the impact of voluntary excavations to be incorporated into the CMS.

April 2013, Grace submitted the Voluntary Focused Soil Excavation Work Plan proposing soil removal at four areas including the Former Burn Pit Area and the areas surrounding historical boring locations SB-28, SB-29, and SB-12. The workplan presented the tasks required to excavate, dispose, and restore areas identified in the 2012 HHRA as exceeding risk to human health. The workplan was approved by EPA and excavation took place in 2013 and early 2014.

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Site Description

Interactive Map of W.R. Grace, Baltimore, MD


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The Grace Davison Curtis Bay Works facility is located in Baltimore, MD on the northwest end of a peninsula known as Marley's Neck. The site includes a 55-acre active manufacturing area and a 55-acre non-manufacturing area used primarily for on-site waste management. The site is bounded on the west by Curtis Creek, on the north by Curtis Bay, and on the south and east by other industrial facilities.

The Curtis Bay Works facility is the largest manufacturing site for W.R. Grace and has approximately 700 employees. Chemical operations at this site have been active since the early 1900's. Current manufacturing activities consist of 12 production facilities that manufacture four general product lines. These include fluid cracking catalyst, hydroprocessing catalyst, polyolefin catalyst, and silicas/adsorbents.

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Contaminants at this Facility

Based on W.R. Grace's groundwater and soil investigations conducted in the past several years, the detected concentrations above applicable screening levels include metals, such as arsenic, cadmium, and lead in the soil and both metal and a limited list of organic compounds in groundwater.

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Institutional and Engineering Controls at this Facility

Proposed Institutional Controls include:

  • All intrusive earth moving activities at the Facility, including excavation, drilling and construction activities, shall be conducted in compliance with the Facility specific health and safety protocols and an EPA-approved Soil Management Plan.
  • Access restricted through the use and maintenance of fencing and controlled access ( through a security gate). 
  • Groundwater at the Facility shall not be used for any purpose, including, but not limited to, use as a potable water source.

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Land Reuse Information at this Facility

The facility is under continued use.

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Site Responsibility at this Facility

RCRA Corrective Action activities at this facility are being conducted under the direction of the EPA Region 3 with assistance from Maryland DEP.

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