Point Street Apartments Construction FAQ, January 2016
Planning Magazine, August/September 2014
Entering the Cap Photo Series, August 2014
Updated Construction FAQ, June 2014
Construction FAQ, May 2014
Air Monitoring Fact Sheet, May 2014
The Baltimore Sun, February 2014
What is the date you will begin construction? Do the regulatory agencies have to approve your plans?
- We anticipate that construction will begin in spring of 2014. The regulatory agencies have to approve the detailed development plans before construction can begin.
Will the site’s construction protect the remedy and the containment system, and be safe for the community and environment?
- Yes. The administrative Consent Decree requires that any construction not jeopardize the integrity of the remedy. The Maryland Department of the Environment (MDE) and the U.S. Environmental Protection Agency (EPA) will review and approve the developer’s construction plans to make sure the construction is done in a way that protects the remedy. MDE and EPA are expected to participate in progress meetings and conduct site visits to monitor that construction is protective of the remedy.
What is the containment remedy for the former Baltimore Works site?
- In 1989, EPA, MDE and AlliedSignal (Allied Chemical’s successor company and Honeywell’s predecessor) entered into a Consent Decree to clean up the site. The consent decree required a remedy that permanently contained chromium contaminated soils and groundwater within the site, eliminated human and animal contact with the contamination, and prevented further contamination of surrounding soils, surface and groundwater. The project was completed the project in 1999.
How can the integrity of the containment system be maintained if you have to “pierce the cap” with pilings more than 1,000 times?
As at other projects, the piles at the Harbor Point site will be installed using proven methods that connect the cap geomembrane to the pile walls. Specifically, at the Harbor Point site, the existing geomembrane will be cut at the pile locations to create an opening in the geomembrane that is large enough to perform the necessary construction of the pile foundation without damaging the surrounding geomembrane. After installation of the piles, the geomembrane will be repaired and the repairs will be tested to confirm that the repaired geomembrane meets the installation standards.
There are several published studies of the integrity of synthetic membranes (i.e., geomembranes) that have been penetrated by pile foundations. For example, a study by Wright, S. E., and Fournier, M. (2013)* describes the successful installation of piles through an existing multi-layered cap, which includes a geomembrane layer.
The engineering firm responsible for the original design and oversight of the containment remedy, including the installation of the geomembrane, is part of the developer’s team, and will coordinate and oversee construction activities with the remedy so that the integrity of the liner is protected.
* Wright, S. E., & Fournier, M. (2013). Retrieved July 26, 2013, from Hull Wind 2 Landfill Post-Closure Use: http://www.mass.gov/dep/energy/hull2.pdf
Will construction of buildings strengthen or weaken the cap?
- The redevelopment will further strengthen the already strong containment system. For example, during redevelopment additional clean soil will be placed across the site, thereby thickening the protective cover. Impervious surfaces (concrete, steel and asphalt) used for buildings, roadways and plazas will be constructed and also will provide an additional barrier to the contaminated soils underneath the cap.
When you are driving piles and erecting buildings on the capped area will this activity weaken the hydraulic barrier, or slurry wall, and the containment remedy?
- No. The hydraulic barrier consists of a mixture of soil and a special sealing clay “bentonite.” The development work will enhance the longevity and effectiveness of the barrier by driving a steel sheet pile within the barrier. The sheet pile is to be installed along Wills and Dock Streets where development precludes future access for barrier repair. The steel sheet pile installation will be a permanent feature, adding redundancy to the barrier to prevent the flow of groundwater into or from the Harbor.
In case the development compromises the containment system do you have the required financial assurances? Does that meet the standards of the Resource Conservation Recovery Act for Corrective Action?
- Honeywell maintains financial assurances as required by Maryland regulations. In addition, the Consent Decree requires that Honeywell, in perpetuity continue to monitor, maintain, and repair the cap.
Health and Safety:
What is Chromium?
- Chromium is a mineral found in rocks, animals, plants and soil. It is also found in byproducts of some types of manufacturing, such as leather tanning, certain steel manufacturing operations, and chrome ore processing. Generally, chromium exists in two forms: trivalent chromium and hexavalent chromium. Hexavalent chromium is predominantly man made and it is present in the environment at much lower levels than trivalent chromium.
How does the exposure to either type of chromium affect my health?
Every person needs small amounts of trivalent chromium for proper health. Trivalent chromium is an essential dietary nutrient. It helps the body activate insulin and regulate blood sugar and is found in most fresh foods and drinking water. Dietary sources rich in chromium include breads, cereals, spices, fresh vegetables, meats and fish. Other significant sources of chromium are mineral supplements, brewer’s yeast and beer.
At certain levels, exposure to hexavalent chromium can affect people’s health. Most human studies focus on how hexavalent chromium affects people who work with chrome or chrome byproducts because these people are at a greater risk of experiencing adverse health effects.
Studies that compare the health of people who live near sites that contain hexavalent chromium with people who don’t have found no statistically significant differences in the health of the two groups.
If the health risks are minimal why do workers remediating chrome-contaminated sites wear protective clothing? Will they for this construction?
- Workers in such circumstances might come in contact with chromium either in the air, soil or groundwater. OSHA standards apply to worksites like these and are designed to protect workers’ health and safety under real-life workplace conditions. During the Harbor Point construction, workers will not have to wear protective clothing.
How might I be exposed to chromium?
- You can be exposed to chromium by breathing air, drinking water or eating foods that contain chromium, or through skin contact with chromium. We are all exposed to small amounts of chromium every day in urban environments.
Will the presence of chromium at the site affect my health?
- For a chemical to pose a significant risk to health, exposure to the chemical must occur. The exposure must be for a significant period of time and in a quantity that has been identified as high enough to result in possible health effects. Because any chromium at the site will be contained and monitored, no exposure is anticipated.
Where can I get more information on chromium?
Here are links to several websites that provide additional information on chromium. These sites address both workplace exposure and exposure from living on or near land that contains chromium:
How will contaminated soil and water be handled at the site?
- Limited amounts of contaminated material (soil, concrete and asphalt) will be directly loaded into lined, roll-off boxes for off-site disposal at an approved, permitted facility. The limited amount of storm water that may come into contact with contaminated material will be collected and temporarily stored in double-wall portable tanks, tested and properly disposed according to the test results.
Why does the air in Baltimore have hexavalent chromium? Is it coming from the site? If not then where is it coming from?
- No. The chromium in the air is not related to the former Baltimore Works site. It is not coming from the site. In an urban environment like Baltimore or other large cities, there may be numerous sources of airborne chromium. Chromium, for example, can be found in steel used in construction, automobiles, and industry. For many years, chromium was used as a wood preservative. According to the federal government’s Agency for Toxic Substances and Disease Registry in 2007 there were 137 industrial facilities in Maryland that used chromium in some way. The chromium at the former Baltimore Works site has been contained.
How will you ensure the safety of the community during construction?
- Our top priority is ensuring the health and safety of workers and nearby communities in and around Harbor Point. All work is being done under the supervision of government regulators and employs science-driven and proven solutions to protect public health. The EPA and MDE will review construction progress activities, air monitoring data, and control measures in place to protect the community.
How will dust be controlled?
- Controlling dust is an important construction performance criterion. Measures to be used to control dust at the site will include water misting to maintain soil moisture to prevent dust generation and to prevent dust transport during excavation. In addition, areas where the underlying soils are exposed will be limited in size and covered without delay. Geotextile fabric and gravel cover soil will be placed over exposed soils to prevent worker contact and reduce potential airborne dust.
How will air monitoring be done?
- Perimeter air monitoring stations will be located at the property boundary, adjacent to nearby facilities, including the marina to the west and Living Classrooms to the north; condominiums to the east and Morgan Stanley to the southeast. Air will be monitored 24 hours a day, seven days a week at these fixed perimeter locations. Additionally, work zone air monitoring stations will be operated during work hours when the soil beneath the cap may be exposed, and located immediately upwind and downwind of exposed soil during excavation and loading. Work zone stations will be adjusted daily according to wind direction. The work zone stations will monitor the air at the work zones before it reaches the site perimeter thereby creating a buffer between the work zone and the site perimeter. In addition to measuring dust at the perimeter and work zone stations, air samples also will be collected and analyzed for total particulates and hexavalent chromium concentrations.
In the event that the real-time dust concentration in the work zone exceeds the dust alarm level, response actions will be taken immediately to first identify and then correct any activity possibly contributing to the elevated dust readings. Perimeter air monitoring stations will be actively observed during any response to elevated dust levels. Should the dust readings remain at or above the dust alarm level after one hour of signaling, all potential dust generating activities will be stopped. Work will not resume until any activity possibly contributing to elevated dust readings have been corrected and the dust readings are continuously below the dust alarm level for 15 minutes after stopping work.
How will the community know if air monitoring criteria are exceeded?
- Should the dust alarm level be exceeded, an event log will be prepared, including the activities performed in response to elevated dust readings, and will be posted on Harbor Point’s website.
How will the community be informed about the air monitoring results?
- Results will be posted on Harbor Point’s website.
What is the containment remedy for the former Baltimore Works site?
- In 1989, the U.S. Environmental Protection Agency (EPA), the Maryland Department of the Environment (MDE) and AlliedSignal (Allied Chemical’s successor company and Honeywell’s predecessor) entered into a Consent Decree to clean up the site. The consent decree required a remedy that permanently contained chromium contaminated soils and groundwater within the site, eliminated human and animal contact with the contamination, and prevented further contamination of surrounding soils, surface and groundwater. Honeywell completed the project in 1999.
Why didn’t regulators require all hexavalent chromium be removed at the Harbor Point site?
- During the 1980s, a range of alternative remedies were evaluated including removing the chromium. The decision for the containment remedy was based in part on the technical difficulties associated with excavation of a site almost surrounded by water and the decision by federal and state regulators that a containment remedy would protect health and the environment and allow for redevelopment.
Have techniques today improved to the point where you could safely remove the chromium?
- The remedy on this site was finalized in 1992. Each site has a remedy that is particular to that site. While some remedial techniques improve over time, the technical challenges associated with excavation at the Inner Harbor site were the result of site conditions, and those challenges would still be present today. Once implemented, remedies are evaluated periodically to make sure they are safe and effective. The data for this site shows that this remedy is protecting human health and the environment.
Does the remedy for this site meet the requirements spelled out in the Consent Decree? Will it meet those requirements as the Harbor Point project continues?
- Current data demonstrate that the site is meeting the environmental benchmarks established in the Consent Decree to demonstrate that it is protective of human health and the environment. EPA and MDE are reviewing construction plans to make sure that this protectiveness is not jeopardized by redevelopment.
Please explain why chromium was taken off the list of contaminants that cause problems for the Harbor?
Twelve years after work was completed to prevent chromium at the Inner Harbor site from affecting the environment, 100% of the more than 4,400 samples drawn from the waters of the harbor meet criteria for chrome levels set out in the Consent Decree that was signed in 1989 by EPA, MDE, and Honeywell.
The Clean Water Act requires states to assess what chemicals are affecting the use of a water body and to establish something known as Total Maximum Daily Loads (TMDLs) for those substances that are affecting a particular water body. In the 1990s and early 2000s, MDE identified numerous different pollutants that it believed affected the Inner Harbor, including fecal coliform bacteria , total chromium, zinc, lead, and polychlorinated biphenyls (PCBs), and nutrients, which can impact biological communities.
Since that listing, a significant amount of scientific research and data regarding the toxicity of chromium in water bodies has emerged. Many of the important studies were conducted by Johns Hopkins University’s Center for Contaminant Transport, Fate, and Remediation. Others were conducted by the EPA and MDE. That scientific research demonstrated that the chromium present in the Inner Harbor is present in a trivalent (rather than hexavalent) form, and that trivalent chromium in sediments is generally non-toxic. MDE’s Water Quality Analysis showed that the harbor is not impaired by chromium. MDE submitted that Water Quality Analysis to EPA for final determination on whether the harbor will no longer be listed as impaired by chromium. The harbor would remain listed as impaired by other pollutants.
What is the cap made of and how does the containment system protect the public and the environment?
- The Harbor Point property is protected by a stone embankment constructed around the three sides that border the Patapsco River. The stone embankment supports the three- foot-wide slurry trench barrier that extends as much as 90 feet deep to seal the site at the bedrock surface. The three-foot thick multi-media cap includes a capillary break layer that prevents water from rising up to the impermeable cap above. The multimedia cap has a synthetic clay layer, a geomembrane layer, a drainage layer, and a clean layer of sand and gravel. The cap prevents storm water infiltration and surface release of chromium.
What is the lifespan of the cap?
- The useful life of a multi-component cover system in the protected, low temperature (i.e., approximately 60 degrees Fahrenheit) setting of the Harbor Point will be 500 to 1,000 years, or more, based on studies performed by the EPA , U.S. National Research Council (NRC, 2007), and independent researchers (Koerner et al., 2002 and 2011). The critical component of the cover system is a geomembrane, which at the Baltimore site is made of low-density polyethylene.
What is the life expectancy of the liner system / the geomembrane?
- The geoembrane significantly exceeds the expected life of the proposed development. Deterioration of the geomembrane is not expected to occur during the life of the development. Moreover, the building basement slab that will overlie the cover system protects the cover system and is another barrier (in addition to the geomembrane) between contaminated soils and the building occupants.
Is there heaving at the Harbor Point site that threatens the cap?
- No. In general, heaving may occur when very large volumes of pure chromium residue are disposed of in an area with a fluctuating water table, or other source of water. The former Baltimore Works site was a production facility. Only minor quantities of residue are documented to have been present at the site, however the site was not used for disposal of large quantities of chrome residue. There has been no heaving associated with the Baltimore site. The site is monitored and there has been no change in the elevation of the cap in 13 years.
Why is this remedy different from what Honeywell did in Jersey City years ago when a federal judge ordered Honeywell to excavate chromium residue?
Honeywell has been working under the supervision and at the direction of state regulators, and in some cases the federal court, to remediate chrome sites in New Jersey by excavating, capping, or in some cases treating. Each site has specific conditions and end uses requiring different remedial approaches.
In Jersey City, the original Mutual Chemical plant site was successfully capped and has been the home of a Home Depot store for many years. The lawsuit focused on the site across the street, the former 34-acre Roosevelt Drive-in site, where the chromium residue was deposited. The court required excavation of the site because the large volumes of chromium residue deposited there exhibited significant heaving. The remediated property is now part of a 100-acre site that has both approved excavation and containment remedies (in areas that are not subject to heaving). At another chrome site in the immediate area, Honeywell successfully completed a remediation that included both capping and excavation.
What were crews working on at the Harbor Point site - this work was videotaped - the night or early morning of June 19, 2013?
- Between 10 p.m. and 12 a.m. on June 17th, minor parking lot repairs were completed on the asphalt lot adjacent to the Morgan Stanley office building. This work was done at night after cars parked in the lot had left. The repair entailed milling the final course of asphalt in a small section and replacing it with new asphalt paving. This was done just north of the Thames Street Wharf building to the east of the multimedia cap, and north of the capillary break that Thames Street Wharf was built upon. These types of minor repairs do not require any special equipment or controls, and the workers were not wearing any kind of protective gear. Coincidentally, we were conducting air monitoring at that time for background levels and there was no increase in dust levels during the time this occurred.