HRS DOCUMENTATION RECORD – REVIEW COVER SHEET

Site Name: Sauer Dump 

 

EPA ID No.: MDD981038334 

 

Contact Persons 

Site Contact: Lorie Baker, Site Assessment Manager (3HS12)

 U.S. Environmental Protection Agency (EPA) Region 3 

 1650 Arch Street 

 Philadelphia, PA 19103-2029 

 (215) 814-3355 

 baker.lorie@epa.gov 

Pathways, Components, or Threats Not Scored

Ground Water Migration Pathway

The ground water pathway was not scored. The surface water pathway was sufficient to list the site.

Soil Exposure Pathway

The soil exposure pathway was not scored. The surface water pathway was sufficient to list the site.

Air Migration Pathway

The air migration pathway was not scored. The surface water pathway was sufficient to list the site. 

 
1

HRS DOCUMENTATION RECORD

Date Completed: June 30, 2010

Date Revised: March 2012 

Site Name: Sauer Dump

EPA Region: 3

Street Address of Site*: 4225 Lynhurst Road 

 Dundalk, Maryland 21222 

City, County and State: Dundalk, Baltimore County, Maryland 

General Location in the State: In the eastern portion of Maryland (shown on Figure 1 of this 

documentation record; Ref. 4) 

Topographic Map: Middle River, Maryland Quadrangle, 1969, photorevised 1985 

Latitude: 39.270267 N Longitude: 76.4527100 W 

 (Ref. 19; Ref. 35) 

* The street address, coordinates, and contaminant locations presented in this Hazard Ranking System 

(HRS) documentation record identify the general area in which the site is located. They represent one or 

more locations U.S. Environmental Protection Agency (EPA) considers to be part of the site based on the 

screening information EPA used to evaluate the site for National Priorities List (NPL) listing. EPA lists 

national priorities among the known "releases or threatened releases" of hazardous substances; thus, the 

focus is on the release, not precisely delineated boundaries. A site is defined as where a hazardous 

substance has been "deposited, stored, placed, or otherwise come to be located." Generally, HRS scoring 

and the subsequent listing of a release merely represent the initial determination that a certain area may 

need to be addressed under the Comprehensive Environmental Response, Compensation, and Liability 

Act. Accordingly, EPA contemplates that the preliminary description of property boundaries at the time 

of scoring will be refined as more information is developed as to where the contamination has come to be 

located. 

Scores

Ground Water Migration Pathway Not Scored 

Surface Water Migration Pathway 100.00 

Soil Exposure Pathway Not Scored 

Air Migration Pathway Not Scored

HRS Site Score 50.00 

 
2

WORKSHEET FOR COMPUTING HRS SITE SCORE

S pathway S2

 pathway 

Ground Water Migration Pathway Score (Sgw) NS NS

Surface Water Migration Pathway Score (Ssw) 100 10,000 

Soil Exposure Pathway Score (Ss) NS NS

Air Migration Score (Sa) NS NS

S2

gw + S2sw + S2s + S2a 10,000 

(S2

gw + S2sw + S2s + S2a)/4 2,500 

/ (S2

gw + S2sw + S2s + S2a)/4 50.00

Notes:

NS Not scored
3

TABLE 4-1 --SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

Factor Categories and Factors Maximum 

Value

Value Assigned

Watershed Evaluated: Back River

Drinking Water Threat

Likelihood of Release:

1. Observed Release 550 550

2. Potential to Release by Overland Flow:

2a. Containment 10

2b. Runoff 25

2c. Distance to Surface Water 25

2d. Potential to Release by Overland Flow [lines 2a(2b + 2c)] 500

3. Potential to Release by Flood:

3a. Containment (Flood) 10

3b. Flood Frequency 50

3c. Potential to Release by Flood (lines 3a x 3b) 500

4. Potential to Release (lines 2d + 3c, subject to a maximum of 500) 500

5. Likelihood of Release (higher of lines 1 and 4) 550 550

Waste Characteristics:

6. Toxicity/Persistence (a) 10000

7. Hazardous Waste Quantity (a) 100

8. Waste Characteristics 100 32

Targets:

9. Nearest Intake 50 0 

10. Population:

10a. Level I Concentrations (b) 

10b. Level II Concentrations (b) 

10c. Potential Contamination (b)

10d. Population (lines 10a + 10b + 10c) (b) 

11. Resources 5 0 

12. Targets (lines 9 + 10d + 11) (b) 0

Drinking Water Threat Score:

13. Drinking Water Threat Score [(lines 5x8x12)/82,500, subject to a max of 100] 100 0

Human Food Chain Threat

Likelihood of Release:

14. Likelihood of Release (same value as line 5) 550 550

Waste Characteristics:

15. Toxicity/Persistence/Bioaccumulation (a) 5 x 108

16. Hazardous Waste Quantity (a) 100

17. Waste Characteristics 1000 320

Targets:

18. Food Chain Individual 50 20

19. Population

19a. Level I Concentration (b) 

19b. Level II Concentration (b) 0

19c. Potential Human Food Chain Contamination (b) 0.00000033

19d. Population (lines 19a + 19b + 19c) (b) 0 

20. Targets (lines 18 + 19d) (b) 20.00000033

21. Human Food Chain Threat Score [(lines 14x17x20)/82500, subject to max of 100] 100 42.66 
4

TABLE 4-1 --SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

Factor Categories and Factors Maximum 

Value

Value Assigned

Watershed Evaluated: Back River

Environmental Threat

Likelihood of Release:

22. Likelihood of Release (same value as line 5) 550 550

Waste Characteristics:

23. Ecosystem Toxicity/Persistence/Bioaccumulation (a) 5 x 108

24. Hazardous Waste Quantity (a) 100

25. Waste Characteristics 1000 320

Targets:

26. Sensitive Environments

26a. Level I Concentrations (b)

26b. Level II Concentrations (b) 125

26c. Potential Contamination (b)

26d. Sensitive Environments (lines 26a + 26b + 26c) (b) 125

27. Targets (value from line 26d) (b) 125

Environmental Threat Score:

28. Environmental Threat Score [(lines 22x25x27)/82,500 subject to a max of 60] 60 60

Surface Water Overland/Flood Migration Component Score for a Watershed

29. Watershed Scorec (lines 13+21+28, subject to a max of 100} 100 100

30. Component Score (Ssw)

c (highest score from line 29 for all watersheds evaluated) 100 100

Notes:

a Maximum value applies to waste characteristics category

b Maximum value not applicable

c Do not round to nearest integer
5

REFERENCES

 

Please note that the number of pages listed for each reference indicates the number of pages included in 

the reference package for this Hazard Ranking System (HRS) document. Number of pages listed may or 

may not reflect the total number of pages contained in a complete copy of an original reference document. 

 

Reference

Number Description of Reference

1. U.S. Environmental Protection Agency (EPA). Hazardous Ranking System: Final Rule. 

Federal Register, Volume 55, No. 241. December 14, 1990. 138 pages. 

2. EPA. Superfund Chemical Data Matrix. Excerpt. 20 pages. January 28, 2004. A complete copy 

of SCDM is available at http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm. 

3. Maryland Waste Management Administration. June 1985. A Preliminary Assessment of Sauer 

Dump, Dundalk, Maryland. 42 pages.

4. Tetra Tech EM Inc. (Tetra Tech). Site Location Map Sauer Dump. June 3, 2010. 1 page. 

5. Halliburton NUS Corporation (formerly NUS Corporation). Expanded Site Inspection, Sauer 

Dump, Project No. 3739-16. ARCS III. March 1994. 633 pages.

6. NUS Corporation. Site Inspection of Sauer Dump. FIT 3. TDD No. F3-8505-33. July 3, 1986. 

213 pages. 

7. Halliburton NUS Corporation. ARCH III, Field Activities Plan, Sauer Dump, Dundalk, 

Baltimore County, Maryland. November 5, 1992. 17 pages. 

8. Tetra Tech. Sediment Sampling Location Map. October 27, 2010. 1 page. 

9. Parsons Brinckerhoff. Tidal Back River, Small Watershed Action Plan. Prepared for the 

Maryland Department of Environmental Protection and Resource Management. February 2010. 

337 pages. 

10. Maryland Department of the Environment (MDE). Memorandum Regarding Sauer Dump. From 

Rick Grills. To Frank Henderson. March 4, 1991. 1 page. 

11. EPA. Pollution Report (Polrep) Number 1 and Final, Sauer Dump Site. Prepared by Dennis 

Matlock. March 20, 1991. 2 pages.

12. Federal Emergency Management Agency (FEMA). F lood Insurance Rate Map. B altimore 

County Maryland, Panel 440 of 580. Map Number 2400100440F. Map Revised September 26, 

2008. 1 page. 

13. Tetra Tech. 15-Mile Target Distance Map. Sauer Dump. October 25, 2010. 1 page. 
6

14. Environmental Service and Technology Corporation (ENSAT). Remedial Investigation Sauer 

 Dump, MD-181 – 4225 Lynhurst Road, Baltimore, Baltimore County, Maryland. August 2005. 

 Volume I and Volume II, 1,651 pages. 

15. Tetra Tech. Sauer Dump Source 1 Location Map. October 27, 2010. 1 page. 

16. Halliburton NUS Corporation, ARCH III. Expanded Site Inspection of Sauer Dump, Logbook 

Nos. P022 and P023. Project No. 3738-1605. December 7, 8, and 9, 1992. 41 pages. 

 

17. Severn Trent Laboratories (STL). Analytical Report. Malcolm Pirnie Sauer Dump Site. Lot#: 

C7A130135. February 13, 2007. 2,771 pages. 

18. STL. Analytical Report. Malcolm Pirnie Sauer Dump Site. Lot#: C7A110281. January 19, 

2007. 724 pages. 

19. Tetra Tech. Project Note Regarding Latitude and Longitude of Source 1. Prepared by Alicia 

Shultz, HRS Specialist. December 14, 2010. 1 page. 

20. Agency for Toxic Substances and Disease Registry (ATSDR). Polychlorinated Biphenyl Health 

Statement. November 2000. 10 pages. 

21. EPA. Sauer Dump Site: Administrative Order for Removal Response Action. EPA Docket No. 

CERC-03-2006-0239DC. August 18, 2008. 27 pages. 

22. EPA. Using Qualified Data to Document an Observed Release and Observed Contamination. 

Directive 9285.7-14FS, PB94-963311, EPA \540\F-94\028. November 1996. 18 pages.

23. EPA. Action Memorandum – Request for Removal Action and Exemption from the $2 Million 

Statutory Limit at the Sauer Dump Site, Baltimore County, Baltimore, MD. August 3, 2007. 17 

pages.

24. Malcolm Pirnie. Field Sampling Plan. November 30, 2006. 69 pages. Appendix A, 80 pages. 

25. Malcolm Pirnie, Inc. Sauer Dump Site Dundalk, Baltimore County, Maryland – Response Action 

Plan – Revision 2 (Final). November 30, 2006. 59 pages. Appendix B, 6 pages. Appendix E, 

119 pages. 

26. Baltimore County, Maryland. Zoning Map for Sauer Dump. 4 pages. Undated. Accessed OnLine at: http://www.baltimorecountymd.gov/Agencies/myneighborhood/zoning.html. 

27. MDE. Letter Regarding Request for Information from MDE Sauer Dump file, Copy of October 

24, 1990 Analytical Data and Site Sketch Attached. From Louise Connelly, Public Information 

Officer. To Sandra Williams, blueskies environmental associates, inc. March 3, 2005. 14 pages. 

28. MDE. Letter Regarding Request for Information from MDE Sauer Dump file, Copy of April 4, 

1996 Analytical Data and Site Sketch Attached. From Louise Connelly, Public Information 

Officer. To Sandra Williams, blueskies environmental associates, inc. March 18, 2005. 48 

pages.
7

29. MDE. Sauer Dump Resampling Report MD-181. May 26, 2000. 33 pages. 

30. Genium Publishing Corporation. Guide to Environmental Analytical Methods, 3rd Edition. EPA. 

Contract Laboratory Program. Copyright 1996. Excerpt 4 pages. 

31. Malcolm Pirnie, Inc. Extent of Contamination Study (Revision 1.0) Former Sauer Dump and 

Salvage Yard. June 26, 2007. 192 pages. 

32. Critical Area Commission for the Chesapeake and Atlantic Coastal Bays. Preserving Our 

Precious Natural Resources. Accessed on June 28, 2010. 2 pages. 

33. Tetra Tech. Source 1 Sampling Locations. October 27, 2010. 1 page. 

34. Tetra Tech. Sauer Dump, Dundalk Maryland (Perimeter of Level II Wetland). February 16, 

2012. 1 page. 

35. U.S. Geological Survey (USGS). Middle River, Maryland Topographic Map. 1969. 

Photorevised 1985. 1 page. 

36. U.S. Fish and Wildlife Service (USFWS), Chesapeake Bay Program. Federally Listed 

Endangered and Threatened Species of Maryland. February 12, 2010. Available On-Line at: 

http://www.fws.gov/chesapeakebay/EndSppWeb/lists/specieslist-md.html. 4 pages. 

37. STL Pittsburg. Analytical Report. Project No. Sediment. Malcolm Pirnie Sauer Dump Site. Lot 

#: C7A110284. February 19, 2007. 1,995 pages. 

38. USFWS. Shortnose Sturgeon Species Profile. May 11, 1967. 1 page. 

39. National Oceanic and Atmospheric Administration (NOAA). Species Profile Shortnose 

Sturgeon. Undated. Available On-Line at: 

http://www.nmfs.noaa.gov/pr/species/fish/shortnosesturgeon.htm. 3 pages. 

40. STL Pittsburg. Analytical Report. Project No. Sediment. Malcolm Pirnie Sauer Dump Site. Lot 

#: C7A130138. February 19, 2007. 3,158 pages. 

41. Critical Area Commission for the Chesapeake and Atlantic Coastal Bays. Maryland Critical Area 

Frequently Asked Questions. Accessed on June 30, 2010. Available On-Line at: 

http://www.dnr.state.md.us/criticalarea/faq.html#1. 4 pages. 

42. EPA. Comprehensive Environmental Response Compensation and Liability Information System 

(CERCLIS) Query Results for Sauer Dump. Accessed On October 12, 2010. On-Line Address: 

http://oaspub.epa.gov/enviro/cerclis_web.report?pgm_sys_id=MDD981038334. 2 pages. 

43. Chesapeake Bay Foundation. Bay Area Facts. Accessed on October 13, 2010. On-Line 

Address: http://www.cbf.org/Page.aspx?pid=433. 2 pages. 

44. NOAA. Ecosystem Based Fisheries Managerment. Accessed October 13, 2010. On-Line 

Address: http://chesapeakebay.noaa.gov/ecosystem-based-management/ecosystem-basedfisheries-management. 1 page. 

45. NOAA. Blue Crab. Accessed on October 13, 2010. On-Line Address: 
8

http://chesapeakebay.noaa.gov/fish-facts/blue-crab. 3 pages. 

46. NOAA. Blue Crab. Accessed on October 13, 2010. On-Line Address: 

http://chesapeakebay.noaa.gov/fish-facts/oysters. 4 pages. 

47. EPA. Action Memorandum – Request for Removal Action and Exemption from the $2 Million 

Statutory Limit at the Sauer Dump Site, Baltimore County, Baltimore, MD. September 27, 2005. 

17 pages. 

48. Tetra Tech. Background Soil Sampling Location Map. June 29, 2010. 1 page. 

49. Maryland Department of Health and Mental Hygiene. Hazardous Waste Laboratory Organic and 

Inorganic Analysis Report Form for S-9. Various Dates. 3 pages. 

50. STL. Analytical Report. Malcolm Pirnie Sauer Dump Site. Lot#: C7A240133. February 6, 

2007. 800 pages. 

51. STL. Analytical Report. Malcolm Pirnie Sauer Dump Site. Lot#: C7A250145. February 19, 

2007. 1,599 pages. 

52. Tetra Tech. Adjusted Detection Limits. Prepared by Alicia Shultz, HRS Specialist. December 

13, 2010. 4 pages. 

53. Tetra Tech. 1992 Sediment Sampling Locations. October 27, 2010. 1 page. 

54. NOAA. Findings for Maryland Coastal Nonpoint Program. Undated. 19 pages. 

55. NOAA. Approval of Maryland Coastal Management Program. 52 pages. Undated. On-Line 

address: http://www.dnr.state.md.us/ccp/pdfs/NOAA_MDCMP.pdf. 

56. Maryland Chesapeake and Coastal Program, Department of Natural Resources. Electronic Mail 

from Joseph Abe, Coastal Policy and Project Review Specialist. To Alicia Shultz, Tetra Tech, 

HRS Specialist. October 25, 2010. 2 pages. 

57. ENSAT Corporation. Sampling and Analysis Plan For Sauer Dump 4225 Lynhurst Road, 

Dundalk, Baltimore City, Maryland, Control No. MD-181. December 4, 2001. 55 pages. 

58. EPA. Modifications Updating SOM01.1 to SOM01.2. October 5, 2006. 47 pages. (cited in 

Reference 52)

59. EPA. Introduction to Analytical Methods. Exhibit D – Analytical Methods. Undated. 133 

pages. (cited in Reference 52). 

60. United States Geological Survey. Map of Real-Time Streamflow. December 17, 2010. 1 page. 

61. EPA. Aerial Photographic Analysis and Wetland Analysis of Sauer Dump Study Area, Dundalk, 

Maryland. February 2012. 33 pages. 

62. Tetra Tech Inc. Wetland Delineation Report, Sauer Dump Site, Baltimore County, Maryland. 

February 2012. 56 pages. 
9

63. Maryland Department of Natural Resources. Email Regarding Back River Fishing and Fish 

Consumption Inquiry. From Martin L. Gary, Assistant Director/Fisheries Ecologist, Maryland 

Department of Natural Resources Fisheries Service. To Alicia Shultz, Tetra Tech, HRS 

Specialist. January 27, 2012. 1 page. 
10

ACRONYMS AND ABBREVIATIONS

μg/kg Microgram per kilogram

μg/L Microgram per liter

ASTM American Society for Testing and Materials

ATSDR Agency for Toxic Substances and Disease Registry

BCHD Baltimore County Health Department 

bgs Below ground surface 

BPFV Bioacccumulation Potential Factor Value

CLP Contract Laboratory Program

COC Chain-of-Custody 

COMAR Code of Maryland Regulations 

EPA U.S. Environmental Protection Agency 

ERRP Environmental Restoration and Redevelopment Program 

ESI Expanded Site Inspection 

FIT Field Investigation Team

FSP Field Sampling Plan

ft Feet

ft2

 Square feet

HRS Hazard Ranking System

HWQ Hazardous Waste Quantity

MWMA Maryland Waste Management Administration

MD HSWMA Maryland Hazardous and Solid Waste Management Administration

MDE Maryland Department of the Environment 

MWMA Maryland Waste Management Administration

 mg/kg Milligram per kilogram

 NLP National Priorities List

 NOAA National Oceanic and Atmospheric Administration

 NS Not scored

PA Preliminary Assessment

PAH Polyaromatic hydrocarbon 

PCB Polychlorinated biphenyl 

PPE Probable point of entry

QA/QC Quality Assurance and Quality Control

QAPP Quality Assurance Project Plan

RAP Remedial Action Plan

RI Remedial Investigation

SCDM Superfund Chemical Data Matrix 

SI Site Inspection

SQL Sample Quantitation Limit

SOP Standard Operating Procedure 

SOW Statement of Work

SVOC Semivolatile organic compounds 

TAL Target Analyte List

TCL Target Compound List 

TDL Target Distance Limit

TP Test Pit

USACE US Army Corps of Engineers 

VOC Volatile organic compound 
11

INTRODUCTION

The Sauer Dump site is located at 4225 Lynhurst Road in Dundalk, Baltimore County, Maryland (Ref. 4; 

Ref. 14, pp. 9, 96; Ref. 42, p. 1; and Figure 1 of this documentation record). Sauer Dump is bordered by 

a cove of Back River and tidal wetlands to the south, and non-tidal wetland areas to the southwest, 

northwest, and southeast. A pond is present in the non-tidal wetland area on the northwest portion of the 

property (Ref. 14, pp. 9, 10; Ref. 15; Ref. 31, pp. 8, 74; and Figure 2 of this documentation record). 

Residential properties border Sauer Dump to the northeast, east, and southeast. Undeveloped land 

borders Sauer Dump to the southwest, west, and northwest (Ref. 25, p. 10; Ref. 14, p. 10; and Figure 2 of 

this documentation record). 

The Sauer Dump is an inactive, privately owned, unpermitted, former dump. While in operation, 

hazardous substances were improperly stored and disposed of at the Sauer Dump from the 1960s to the 

1980s (Ref. 14, pp. 3, 9). In 2007, Sauer Dump was used for vehicle maintenance and storage, and 

sportsmen hunted duck on the property in the fall. All-terrain vehicles were used on the property, causing 

erosion and exposing contaminated soils (Ref. 23, p. 7).

Reference documentation identifies Sauer Dump as a 2.48-acre property on land Parcel 425. However, 

descriptions of the dump operations indicate that dumping activities extended onto adjacent parcels and 

the contamination resulting from operations migrated beyond Parcel 425 (Ref. 14, pp. 9, 96; Ref. 21, p. 4; 

Ref. 31, pp. 8, 23, 28 to 31, 74; Ref. 47, p. 3). Analytical data from samples collected from Sauer Dump 

indicate that contamination from the dump has spread to adjacent properties via vehicle traffic or other 

transport mechanisms (Ref. 31, pp. 23, 30). Therefore, the area of the Sauer Dump is more than 2.48 

acres. The exact dimension of Sauer Dump cannot be determined from data currently available. 

In the middle to late 1950s, Sauer Dump was owned by William Lusk (Ref. 3, p. 20). According to 

historic records, Sauer Dump was bought by the late Frederick Sauer from Irene Sessa in approximately 

1963. Historic records do not indicate when Irene Sessa bought the property or how she used it (Ref. 6, p. 

9). In December 1992, Fred Sauer (the son of the late Frederick Sauer) and the Beachwood Development 

Corporation owned the property (Ref. 7, p. 1). On January 16, 1997, Sauer Dump was acquired by the 

Wittstadt Hunting Club, Inc. (Ref. 14, p. 10). As of 2006, Sauer Dump was still owned by Wittstadt 

Hunting Club, Inc. (Ref. 25, p. 10). 

A 2012 aerial photographs analysis showed that in 1938 the Sauer Dump area was undeveloped woodland 

and emergent herbaceous wetland. By 1957 Lynhurst Road was in place and single family houses had 

been constructed along the road. Fill deposits had been placed into the wetland during the construction of 

a peninsula located east of the Sauer Dump. These fill deposits were visible in 1954 and 1957. By 1964 

the filling of the peninsula appeared complete. Filling activity was also evident at the northeast edge of 

the Sauer Dump area extending southwest from parcels 503, 464, and 295. Filling/dumping continued 

near the northeast edge of the Sauer Dump area through 1969. By 1971 dumping activity had extended 

into the central portion the Sauer Dump area, formerly occupied by wetland as late as 1964. By 1973 

dumping operations at the Sauer Dump area had expanded to areas south of parcel 295 and to the west of 

parcel 137. By 1986 the accumulations of dumped material at the Sauer Dump area appeared to have 

reached their largest extent. Piles of debris, fill, probable solid waste, numerous containers, trailers, 

trucks, a crane, and derelict vehicles were noted. Dumping continued through 1990 and 1992. By 1995 

dumping at the Sauer Dump area appeared to have ceased and revegetation in the central portion of the 

Sauer Dump was evident (Ref. 61, pp. 1, 2, 10, 11). 

Frederick Sauer owned Sauer Dump when primary filling activities occurred (Ref. 6, p. 9). Records do 

not indicate whether the same fill material was used on Sauer Dump and the adjacent properties. The 

source of the fill material and the persons responsible for filling the areas has not been identified. 

 

 

 

 

 

 

 

 

 

 

 

Parcel 425 

Approximate limit of

fill material (Source 1) 

Parcel 503 

Parcel 574 Parcel 46

Parcel 2

4

95 

Parcel 137 

Approximate Location of Dump = 

Maryland 

Lynhurst Rd. 

Source: Reference 14, page 96 

Legend

Approximate Limit of Fill Material (Source 1)

Surrounding Parcel 

Parcel 425 

0 65 130 

Feet 

DUNDALK, BALT

SAUER DUMP

IMORE COUNTY, MARYLAND 

FIGURE 2

SAUER DUMP SOURCE 1 LOCATION MAP
 

Map created on October 27, 2010 by TDD No. E33-030-10-05-002

Collin Horace, Tetra Tech EM Inc.
 EPA Contract No. EP-S3-05-02 

260 
14

According to interviews with neighbors of Sauer Dump, a flatbed tractor trailer disposed of numerous 55-

gallon drums at the dump in the mid-1970s. The drums were leaking and contained an oily liquid 

substance. Information gathered in another interview indicated that Mr. Sauer operated a waste hauling 

business at the dump from the late 1960s to the mid-1980s and disposed of hauled waste including paint 

and creosote wastes (Ref. 47, p. 5). 

Wastes observed at Sauer Dump during site investigations include drums, storage tanks, salvage items 

(such as scrap metal), empty tanks and drums, abandoned trucks, tractor/truck trailers, open roll-off 

containers, heavy construction equipment, and junked cars. Charred areas, burned paint waste, a wood 

chip mound, and sections of large-diameter circular concrete conduit have also been observed, and oil 

spill areas have been observed on site and in wetland areas adjacent to the property. Studies conducted at 

Sauer Dump between 1985 and 1999 indicate that concentrations of semivolatile organic compounds 

(SVOC), metals, polychlorinated biphenyls (PCB), and pesticides found in the soil and sediment exceed 

various risk-based screening levels (Ref. 10; Ref. 11, p. 1; Ref. 14, p. 3). 

The primary source identified at Sauer Dump is a landfill (Source 1). The source is classified as a landfill 

because the source was created when wastes were filled into the wetlands on the property (Ref. 3, pp. 1, 

22; Ref. 61, pp. 1, 2). Evidence shows contaminated soil outside the area estimated to have been filled

and identified as Source 1. However, an area of contaminated soil has not been documented because of 

the lack of background samples collected during investigations conducted at Sauer Dump (Ref. 14, pp. 9, 

96; Ref. 21, p. 4; Ref. 31, pp. 8, 23, 28 to 31, 74; Ref. 47, p. 3). The precise boundaries of the landfill 

cannot be identified because existing data do not sufficiently delineate the aerial extent of the landfill and 

contamination. The extent of Source 1 (fill area) has been estimated based on the topography of the area, 

information gathered during subsurface investigations, and an onsite survey (Ref. 15; Ref. 14, pp. 13, 96, 

109, 110). The dashed line on in Figure 2, Reference 14, page 96 identifies the approximate limits of the 

fill and the original elevation of the site based on an onsite survey (Ref. 14, p. 96). Subsurface 

investigations conducted at Sauer Dump identified waste material such as metal, rubber, batteries, 

electrical parts, and other fill material throughout the subsurface soils of the dump (Ref. 14, pp. 13, 14). 

The primary hazardous substances associated with Source 1 are lead and PCBs (Ref. 31, pp. 28 to 31). 

Source 1 is located in the flood plain of the Back River and is subject to flooding and erosion during 

severe weather events (hurricanes, tropical storms, heavy rain) (Ref. 23, p. 7; Ref. 12). A wetland 

surrounds Source 1 along its eastern, southern, and western boundaries. The wetland receives surface 

water runoff from Source 1. Sediment samples collected from the wetland contain PCBs and lead at 

concentrations meeting the criteria for an observed release to surface water and actual contamination of a 

wetland (Ref. 31, pp. 32, 33, 80; Ref. 34; and Section 4.1.4.3 of this documentation record). The wetland 

discharges to Back River, which in turn flows to the Chesapeake Bay (Ref. 34; Ref. 13). The Back River 

and Chesapeake Bay are fisheries (Ref. 9, pp. 32, 65, 66; Ref. 63). Targets evaluated include the 

wetlands on the eastern, southern, and western boundaries of Source 1 and fisheries associated with Back 

River and Chesapeake Bay. 

According to the Baltimore County Department of Permits and Development Management, Sauer Dump 

is zoned as a Resource Conservation Critical Area (Ref. 26) under the Critical Area Act. In 1984, the 

Maryland General Assembly resolved to reverse the deterioration of Chesapeake Bay’s environment by 

enacting the Chesapeake Bay Protection Act. In 2002, the Act was amended to include the Atlantic 

Coastal Bays. The Act required the 16 counties, Baltimore City, and 44 municipalities surrounding the 

Chesapeake and Atlantic Coastal Bays to implement a land use and resource management program 

designed to mitigate the damaging impact of water pollution and loss of natural habitat, while also 

accommodating the jurisdiction’s future growth. The Critical Area Act recognizes that the land 

immediately surrounding the Bays and their tributaries has the greatest potential to affect water quality 

and wildlife habitat and thus designated all lands within 1,000 feet of tidal waters or adjacent tidal 

wetlands as the “Critical Area” (Ref. 41, p.1). 
15

Previous investigations conducted at the property are summarized in the section below. 

Summary of Investigations at the Sauer Dump Site

On November 8, 1954, the Baltimore County Health Department (BCHD) performed an inspection on 

Mr. Lusk’s property (Sauer Dump) because of complaints by adjacent property owners of floating debris 

on Back River. According to BCHD, the property consisted of marshland (wetland) fronting the Back 

River that was being filled with material consisting mainly of plasterboard and “other waste materials of 

an inert nature” (Ref. 3, p. 22). A number of areas on Sauer Dump had been raised to several feet above 

normal water levels because of dumping operations. Adjacent property owners complained about floating 

debris that consisted of paper that had separated from plasterboard when it was immersed in water. Mr. 

Lusk was near completion of filling operations and was planning to cover the area with earth and building 

materials. No action was taken against Mr. Lusk (Ref. 3, p. 22). 

On April 4, 1984, BCHD conducted an inspection of Sauer Dump in response to a request for an 

evaluation by a proposed developer (Ref. 3, p. 1). A large quantity of debris was observed during the 

inspection, including auto parts, empty drums, wood, and plastic products. On April 12, 1984, BCHD 

ordered Mr. Sauer to clean up Sauer Dump within 60 days as a result of this inspection, citing violations 

of the County Code (Ref. 3, p. 20). 

During a follow-up inspection on May 4, 1984, BCHD found that the Sauer Dump had accepted no 

additional waste since the April 1984 inspection. On June 8, 1984, BCHD examined the property and 

found that little progress had been made in cleaning up the property (Ref. 3, p. 21). 

During an inspection of Sauer Dump on October 2, 1984, BCHD found that 60 to 70 percent of the 

cleanup had been completed. On January 24, 1985, the Maryland Waste Management Administration 

(MWMA), accompanied by BCHD, conducted a preliminary assessment (PA) of Sauer Dump. 

Approximately 70 percent of the original debris had been removed from the property. A small quantity (5 

to 10 cubic yards) of refuse had been brought onto the property since the October 1984 inspection (Ref. 3, 

p. 21). The following wastes were observed on site: paper, lumber, scrap metal, demolition debris, old 

empty trailers, junked cars, a couple of cranes and dozers, and about 10 to 12 empty and rusted drums. 

No evidence of hazardous materials or water contamination problems was observed (Ref. 3, p. 2). The 

PA report states that the owner had no records of the waste types and quantities disposed of at Sauer 

Dump (Ref. 3, p. 4). MWMA and BCHD observed two burn areas on the property: an approximately 30- 

by 30-foot area of charred debris and ashes on the southern border of the property and an empty, rusted 

roll-off truck box that was used for burning paint off scrap metal. The PA report states that Sauer Dump 

had been used to store approximately 250 empty drums, which were removed in summer 1984 (Ref. 3, 

pp. 2, 6).

On June 27, 1985, EPA Region 3's Field Investigation Team (FIT), accompanied by representatives from

EPA, MWMA, and BCHD, conducted a site inspection (SI) of the Sauer Dump (Ref. 6, p. 26-27). During 

the June 1985 SI, the following wastes were observed on site: large piles of construction debris (concrete, 

wire, plaster, rebar, and wood); large, empty storage tanks; several empty trucks and trailers; metal scrap; 

an open-ended dumpster that served as a burn area; and a former burn area covered with wood chips (Ref. 

6, p. 6 and 72). Analytical results from on-site surface soil, subsurface soil, and sediment samples 

collected as part of the SI revealed PCB concentrations up to 267.899 milligrams per kilogram (mg/kg). 

An on-site surface water sample revealed PCB concentrations at 29.9 micrograms per liter (μg/L) (Ref. 6, 

p. 60). Various polyaromatic hydrocarbons (PAH) and phthalates were detected in on-site surface soil, 

subsurface soil, surface water, and sediment samples (Ref. 6, p. 57).
16

Maryland Department of the Environment (MDE) collected additional samples at Sauer Dump on 

October 24, 1990. Analytical results revealed PCBs at 110 mg/kg and 62 mg/kg in soils adjacent to the 

on-site tidal channel (Ref. 27, pp. 1, 13 and 14). On March 1, 1991, MDE and U.S. Environmental 

Protection Agency (EPA) Region 3 completed a removal assessment of Sauer Dump in response to the 

elevated levels of PCBs detected in on-site soils (Ref. 10; Ref. 11). The following observations were 

recorded during the removal assessment (Ref. 11):

• Three empty storage tanks with a capacity of up to approximately 2,000 gallons 

• Approximately 50 empty and rusted 55-gallon steel drums

• Several pieces of heavy equipment in various stages of decay (cranes, roll-off boxes, and box 

trailers)

• An area currently utilized for welding operations 

• Evidence of on-going fill and grading operations using construction and metal debris (Ref. 11) 

After discussing Sauer Dump with EPA’s removal section, EPA’s site assessment section made plans to 

conduct an expanded site inspection (ESI); therefore, a removal action was not deemed necessary at the 

time (Ref. 11, p. 2). 

In December 1992, EPA Region 3 contractors conducted an ESI of the Sauer Dump (Ref. 5, p. 6). 

Samples were collected from on-site surface soils, surface water, and sediment. Surface water and 

sediment samples were also collected from the Back River (Ref. 5, p. 22). Analytical results of on-site 

surface soil samples revealed elevated levels of Aroclor 1254 (up to 150 mg/kg) and phenol (up to 21 

mg/kg); the PAH naphthalene (up to 20 mg/kg); and several other PAHs and metals including arsenic, 

chromium, lead, manganese, and nickel. Analytical results of on-site sediment samples revealed elevated 

levels of Aroclor 1254; several metals including chromium, lead, and nickel; and several PAHs. Results 

from on-site surface water samples revealed elevated levels of metals (Ref. 5, pp. 29, 56, 60, 61, and 93). 

On April 4, 1996, MDE personnel collected six soil and five sediment and surface water samples from 

Sauer Dump (Ref. 28, p. 2). The PCB Aroclor 1254 was reported at a maximum concentration of 44 

mg/kg in one soil sample, and at a maximum concentration of 0.3 mg/kg in two sediment samples 

collected in the wetlands located adjacent to the Back River (Ref. 28, pp. 2 and 37). 

In late 1999, MDE collected soil, sediment, ground water, and surface water samples from Sauer Dump 

(Ref. 29). Elevated levels of inorganics were detected in soil and sediment samples collected throughout 

the entire property. Elevated concentrations of semivolatile organic compounds (SVOC) in the soil 

(benzo-a-pyrene up to 7,323 micrograms per kilogram [μg/kg]) were detected predominately in the 

southern portion of the property. The PCB Aroclor 1254 was detected at elevated levels (ranging from 

0.7 to 84 mg/kg) in the majority of soil samples collected throughout the property. PCB concentrations 

reported in sediment samples collected from Sauer Dump ranged from 0.4 to 14.4 mg/kg (Ref. 29, p. 3).

In 2001, an environmental consultant to MDE was tasked under MDE’s Environmental Restoration and 

Redevelopment Program (ERRP) to perform an RI of Sauer Dump (Ref. 14, p. 3). The field investigation 

portion of the RI was performed to fill data gaps left from the available reports (Ref. 14, p. 3). During the 

RI, the property was observed to be heavily overgrown with vegetation and exhibited irregular 

topography. At the time that the 2001 RI was conducted, the property continued to serve as a storage area 

for large items owned by various Sauer family members, including boats, vehicles, and large construction 

equipment. Scrap metal, domestic refuse, and construction debris remained throughout the property and 

in some adjacent areas off site (Ref. 14, p. 12). 

During the RI field investigations conducted in 2001 to 2002, subsurface soil samples were collected from

nine test pits excavated at the property, five ground water monitoring wells were installed and sampled, 
17

and five soil borings were advanced and sampled. In addition, a topographical survey and wetland 

delineation was conducted for Sauer Dump and immediately surrounding land (Ref. 14, pp. 12, 13, 16). 

As observed during test pit excavation, the fill at Sauer Dump consisted of wood, plastic, metal, rubber, 

brick, sand, black sand/soil, concrete and concrete castings, asphalt, ash, electrical transformer parts, 

paint/paint containers, batteries, crushed drums, railroad ties, styrofoam, and a white/gray powdery 

substance (Ref. 14, p. 3). 

In January 2003, the Agency for Toxic Substances and Disease Registry (ATSDR) concluded that lead 

and PCBs detected in surface soil samples at Sauer Dump was a public health hazard for a nearby 

residents, and that PCBs detected in subsurface soil samples were a potential public health hazard if 

contaminated soils were exposed during gardening or construction activities involving digging or 

trenching (Ref. 21, p. 6). 

In December 2005, EPA issued an Administrative Order for Removal to the Sauer Dump mandating that 

property owners place a fence around the property to restrict access, install a temporary cover system over

contaminated areas to mitigate erosion of surface soils, and protect the shoreline from erosion. As a result 

of the 2005 Order, a chain-link fence now restricts public access to the majority of Sauer Dump, plastic 

nylon-reinforced polyethylene sheeting covers a small area of Sauer Dump disturbed during remedial 

investigations, and shoreline erosion structures such as coconut fiber logs have been installed to prevent 

erosion (Ref. 21, p. 7; Ref. 31, p. 12). 

In January 2007, a contractor to MDE conducted an extent of contamination study of Sauer Dump that 

included surface and subsurface soil, sediment, and surface water sampling. A total of 32 surface soil, 

and 9 subsurface soil samples were collected. The surface soil samples were analyzed for lead and PCBs. 

The subsurface soil samples were collected from 2 to 3 feet below ground surface (bgs) and were 

analyzed for PCBs, lead, volatile organic compounds (VOC), and SVOCs. Aroclor 1260 was the most 

commonly detected PCB compound, identified in 25 of the 32 surface soil samples and 8 of the 9 

subsurface soil samples. Lead was detected in all of the surface and subsurface soil samples. The highest 

concentrations of PCBs (up to 7.7 mg/kg in surface soil and 1.6 mg/kg in subsurface soil) and lead (up to 

2,720 mg/kg in surface soil and 13,100 mg/kg in subsurface soil) were observed in soil samples collected 

from the hot spots (areas with historically high lead and PCB concentrations) on Sauer Dump. Low 

concentrations of VOCs and SVOCs were detected in several of the subsurface soil samples (Ref. 31, pp. 

14 to 16, 22 to 25, and 65 to 68). 

A total of nine sediment samples were collected from Sauer Dump as part of the 2007 extent of 

contamination study, including seven from the wetlands, one from the pond area, and one from Back 

River. The sediment samples were collected from the top 6 inches of sediment below the organic 

buildup. The sediment samples were analyzed for lead and PCBs by EPA Methods 8082 (total PCBs) 

and 1668 (PCB homologues) (Ref. 31, pp. 24, 25, and 80). Lead and PCBs were detected in the wetland 

surrounding the pond on the northern portion of Sauer Dump (Wetland #1) and in the wetland that 

surrounds the eastern, southern, and western portions of Sauer Dump (Wetland #2) (Ref. 31, pp. 25, 69, 

80). Total PCBs and lead in Wetland #1 were detected at concentrations up to 0.33412 mg/kg and 47.01 

mg/kg, respectively. Total PCBs and lead in Wetland #2 were detected at concentrations up to 38.7 

mg/kg and 4,800 mg/kg, respectively (Ref. 31, pp. 25 and 69). 

Two surface water samples were collected from the shoreline of Back River. The samples were collected 

soon after the peak of high tide. Filtered and unfiltered samples were collected and analyzed for lead and 

PCBs. PCBs were not detected in the unfiltered and filtered samples when analyzed using EPA Method 

8082; however, PCBs were detected at low concentrations in both types of samples when analyzed with

EPA Method 1668, which screens for all 209 PCB congeners. Lead was detected in one filtered and both 

unfiltered samples (Ref. 31, pp. 14 to 16, 35, 22-25, 70; Ref. 25, p. 37).
18

Five ground water wells were installed in January 2007. In February 2007, samples were collected from 

the five wells and analyzed for PCBs and total and dissolved lead. PCBs were detected in only the 

unfiltered samples from MW-4 when analyzed using EPA Method 8082, which tests for seven of the 209 

possible PCB congeners. When the samples were analyzed using EPA Method 1668, which screens for 

all 209 PCB congeners, PCBs were detected in both the filtered and unfiltered samples from all five 

wells. Lead was detected in three of the unfiltered samples (Ref. 31, pp. 16, 18, 26, 27, 71, 72; Ref. 25, p. 

37).

Investigations conducted at the Sauer Dump identified an area of PCB and lead contamination in Source 1 

waste that released lead and PCBs to wetlands located along the eastern, southern, and western borders of 

Source 1 and adjacent to the Back River, as documented in this HRS documentation record. 
SD-Waste Characteristics

19

 

SOURCE DESCRIPTION

 

2.2 Source Characterization

 

Source Number: 1 

Source Description: Landfill

Source Type: Landfill 

Source 1 is a landfill created when wastes were filled into wetland (marshland) adjacent to the Back River 

(Ref. 3, p. 1; Ref. 61, pp. 1, 2). During investigations conducted in Source 1, wood, plastic, metal, 

rubber, brick, sand, black sand/soil, concrete and concrete castings, asphalt, ash, electrical transformer 

parts, paint/paint containers, batteries, crushed drums, railroad ties, styrofoam, and a white/gray powdery 

substance were observed in the subsurface soil (Ref. 14, pp. 3, 26, 126 to 149). This waste material is 

referred to as fill in reference documentation. Test pits in Source 1 identified fill from the surface to 

below the water table (Ref. 14, pp. 13, 14). Subsurface soil borings in Source 1 revealed the presence of 

wood, plastic, metal, wire, rubber, brick, sand, rock fragments/gravel, glass, concrete, asphalt, ceramic 

tile, mattress pieces, and paper in fill found in Source 1 (Ref. 14, pp. 14, 126 to 149; Ref. 31, pp. 93 to 

103). 

Source 1 is estimated to cover at least 2.48 acres, which is the area of Parcel 425 on which the fill is 

located (Ref. 15; Ref. 14, pp. 9, 96). The area of the fill has been estimated from elevations on Sauer 

Dump and is shown in Reference 15. 

Source 1 was used during the 1960s through 1980s as an unpermitted landfill/dump (Ref. 3, p. 1; Ref. 14, 

p. 9). During operations, hazardous wastes were improperly stored and disposed in this area (Ref. 14, p. 

9). The oldest evidence supporting the use of Source 1 as a landfill is photographs and an inspection 

report dated 1954. The 1954 inspection report stated that the land being filled consisted of wetland

(marshland) fronting the Back River (Ref. 3, p. 1). An aerial photograph from 1964 shows Sauer Dump 

as emergent herbaceous wetland (marshland) with filling/dumping evident at the northeast edge of the 

Sauer Dump area. The unfilled emergent herbaceous wetland (marshland) is shown in a 1938 aerial 

photograph (Ref. 61, pp. iii, 10, 11, 16, 17). Filling/dumping had reached the central portion of the Sauer 

Dump by 1971, and it reached its largest extent by 1986 (Ref. 61, pp. iii, 18, 19, 22, 23). 

No records of the sources, types, and quantities of wastes disposed in Source 1 have been identified (Ref. 

3, p. 4). Wastes potentially containing hazardous substances observed on the surface of Source 1 include 

large piles of construction debris (concrete, wire, plaster, rebar, and wood); large, empty storage tanks; 

railroad ties; several empty trucks and trailers; scrap metal; an open-ended dumpster that served as a burn 

area; drums; and a former burn area covered with wood chips (Ref. 3, pp. 2, 3, 5, 6, and 8; Ref. 5, p. 24; 

Ref. 6, p. 72; Ref. 10, p. 1; Ref. 11). Refuse possibly containing hazardous substances has been observed 

throughout Sauer Dump and on the surface of Source 1 (Ref. 6, p. 10; Ref. 11). Approximately 250 

empty drums were disposed of and removed from Sauer Dump in 1984 (Ref. 3, pp. 3, 6). Because the 

contents and handling of these drums while they were on-site are not known, the drums represent a 

possible source of contamination (Ref. 3, p. 5). The source of the waste materials is not provided in site 

documentation (Ref. 6, p. 24; Ref. 11). 
SD-Waste Characteristics

20

Source Location:

Source 1 is located at 4225 Lynhurst Road in the Dundalk, Baltimore County, Maryland (Ref. 15). Based 

on figures prepared during on-site surface and subsurface investigations at Sauer Dump, the extent of the 

Source 1 (landfill) is estimated based on raised elevations indicating that the area has been filled, as 

shown in Reference 15. The outline of Parcel 425 is provided on Reference 15 showing that the landfill 

extends beyond the Parcel 425. Source 1 is bordered by a cove of the Back River and tidal wetlands to 

the south, and by non-tidal wetland areas to west, northwest, and east. A pond is present in the non-tidal 

wetland area northwest of Source 1 (Ref. 31, pp. 8, 11, 74; Ref. 15; Ref. 33; Ref. 34). The locations of 

Source 1 waste samples showing concentrations of lead and PCBs are shown in Reference 33. 

Containment: 

Release to ground water: The ground water pathway was not scored. 

Release via overland migration and/or flood:

Release to surface water: Source 1 is located adjacent to Back River. Tidal and non-tidal wetlands are 

located along the eastern, southern, western, and northwestern boundaries of Source 1 (Ref. 14, p. 3; Ref. 

15; Ref. 34; Ref. 62, pp. 8, 9, 17). As described in this section, contamination has been documented at

Source 1. There is no evidence that a maintained, engineered cover or functioning and maintained run-on 

control system and runoff management system is in place at Source 1. There is also no documentation 

supporting that containment at Source 1 was designed, constructed, operated, and maintained to prevent a 

washout of hazardous substances by a flood. For these reasons, a containment factor value of 10 was 

assigned to the source (Ref. 1, Table 4-2; Ref. 3, p. 15). 

Gas release to air: The air migration pathway was not scored.

Particulate release to air: The air migration pathway was not scored.
SD-Waste Characteristics

21

2.4 WASTE CHARACTERISTICS

2.4.1 Hazardous Substances

Numerous source sampling investigations have been conducted to characterize Source 1. The results of 

these investigations document the presence of contamination in the surface (0 to 2 feet bgs) and 

subsurface (2 feet or greater bgs) of Source 1 (Ref. 14, pp. 3, 4, 11-12, and 18-19). 

The samples collected from Source 1 have been described as surface soil, subsurface soil, and fill material 

in reference documentation. Because Source 1 includes a filled marsh (landfill), all samples collected 

from Source 1 landfill are considered waste samples. The surface and subsurface samples collected from 

Source 1 represent material used to fill the marsh or landfill wastes and do not represent native soil. 

Therefore, no background sample is needed to document background concentrations of hazardous 

substances. However, to document that lead and PCBs are not present at high concentrations or 

ubiquitous in the area of Source 1, background levels of lead and PCBs thought to be outside the 

immediate influence of Source 1 have been provided. The background sample results presented in this 

HRS documentation record are used to document lead and PCB concentrations in the area of Source 1 and 

are not necessarily the same matrix (fill) as the Source 1 landfill samples. The background sample results 

are not provided to document observed contamination (Ref. 1, Table 2-3 and Section 5.0.1). 

To determine lead and PCB concentrations in the area of Source 1, soil sampling locations for each 

investigation conducted at Sauer Dump were reviewed and potential sampling locations outside the 

influence of the area thought to be Source 1 were identified. A summary of those sampling locations are 

provided in the Background Lead and PCB Concentrations Section of this documentation record. 

Samples located outside the influence of areas thought to be Source 1 were collected in 1992, 1999, and 

2007. The locations are provided in References 33 and 48 and are identified as background locations. 

The concentrations of lead and PCB detected in the background samples are provided to identify 

concentrations of lead and PCB in the area surrounding Source 1 and are not provided to document 

observed contamination (Ref. 1, Table 2-3; Section 5.0.1). Lead and PCBs have been determined to be 

the primary contaminants of concern (COC) at the Sauer Dump, and are the only hazardous substances 

included in this HRS documentation (Ref. 31, p. 38). However, numerous other hazardous substances 

including SOVs, VOCs, and metals other than lead may be associated with Sauer Dump (Ref. 14, pp. 11, 

12). 

The full extent of Source 1 has not been documented. 

BACKGROUND LEAD AND PCB CONCENTRATIONS

1992 Background Soil Sample - ESI

 

During the ESI conducted by EPA Region 3 contractors in 1992, a background soil sample (S-12) was 

collected from the junction of Lynhurst Road and Morse Lane. The soil collected for the sample was dark 

brown, sandy clay loam (Ref. 5, pp. 17, 21, 22; Ref. 48). The laboratory data validation report for the 

sample is provided in Section 3 of Reference 5. The soil sample was analyzed through EPA’s Contract 

Laboratory Program (CLP) and was analyzed using the CLP statement of work (SOW) for inorganics and 

organics (Ref. 5, pp. 17, 85, 141, 142). Reference 16, pages 16 and 17, provides the logbook notes taken 

during sample collection. The location of S-12 is shown on Reference 5, Figure 2, page 22, and 

Reference 48. The sampling location is northeast of Source 1. Concentrations of lead and PCBs detected 

in S-12 are summarized in Table 1.
SD-Waste Characteristics

22

TABLE 1

1992 SOIL SAMPLE CONCENTRATIONS

Sample ID Sample 

Type Date

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(mg/kg)

Detection 

Limit* 

(mg/kg) Reference

S-12

(CHH43)

(MCGX41)

Soil 12/08/1992 Lead 53.2 0.6 5, pp. 29, 345; 

16, pp. 17, 18 

Aroclor 

1242

0.047 U 0.033 5, pp. 61, 536; 

16, pp. 17, 18

Aroclor 

1248

0.047 U 0.033 5, pp. 536; 16, 

pp. 17, 18

Aroclor 

1254 

0.047 U 0.033 5, pp. 61, 536; 

16, pp. 17, 18 

Aroclor 

1260 

0.047 U 0.033 5, pp. 61, 536; 

16, pp. 17, 18 

Note:

All concentrations have been converted to mg/kg. 

* The detection limits are contract-required quantitation limits for organic compounds and contract-required detection 

limits for inorganic compounds (Ref. 5, pp. 345, 536; Ref. 30). 

mg/kg Milligram per kilogram

U Not detected. The associated number indicates approximate sample concentration necessary to be detected (Ref. 5, p.

26). 

 
SD-Waste Characteristics

23

1999 Background Soil Sample

In 1999, MDE collected a background soil sample (S-9) north of the Sauer Dump (Ref. 29, pp. 3, 8, 13, 

15). Concentrations of lead and PCBs detected in the sample are summarized in the Table 2. S-9 was 

sent to the Maryland Department of Health and Mental Hygiene (Ref. 49). PCBs were analyzed using 

EPA Method 625 (Ref. 49, p. 1). The inorganic analytical method was not specified in reference 

documentation (Ref. 49, p. 3). The location of S-9 is shown in Figure 3, page 8, of Reference 29, and 

Reference 48. The analytical method and date of sample collection is not specified in available 

documentation (Ref. 29, pp. 3, 13, 15). A description of the soil sample is not provided in reference 

documentation. 

TABLE 2

1999 BACKGROUND SOIL CONCENTRATIONS

Sample ID Sample 

Type Date

Hazardous 

Substance

Hazardous 

Substance 

Concentration 

(mg/kg)

Detection 

Limit*

(mg/kg) Reference

S-9 Soil 1999 Lead 47.9 mg/kg 0.6 29, p. 13; 

49, p. 3 

Aroclor 

1242 

U 0.033 29, p. 15 ; 

49, p. 1 

Aroclor 

1248 

U 0.033 29, p. 15 ; 

49, p. 1 

Aroclor 

1254

U 0.033 29, p. 15 ; 

49, p. 1

Aroclor 

1260

U 0.033 29, p. 15 ; 

49, p. 1

Note:

All concentrations have been converted to mg/kg. 

* The detection limits are contract-required quantitation limits for organic compounds and contract-required detection 

limits for inorganic compounds (Ref. 49, p. 1Ref. 30).

mg/kg Milligram per kilogram

U Not detected above the detection limit (Ref. 5, p. 26). 
SD-Waste Characteristics

24

2007 Background Soil Samples

During the 2007 extent of contamination study conducted by an MDE environmental contractor, 10 soil 

samples (DG-SS31, DG-SS32, DG-SS25, DG-SS26, DG-SS27, DG-SB02, DGSB03, DG-SB04, DGSB05, and DG-SB06) were collected to evaluate whether the eastern extent of the lead and PCB hot-spot 

area identified on the Sauer Dump property overlapped onto Parcel 137 located east of Parcel 425, and the 

fill area of Source 1 (Ref. 15; Ref. 31, p. 28, Figure 7, p. 79, and Figure 10, p. 82). The sampling 

locations and concentrations of lead and PCBs detected in the samples are shown on Figure 7, page 79 

and Figure 10, page 82 of Reference 31. The analytical results from five surface soil samples (DG-SS19, 

DG-SS20, DG-SS21, DG-SS22, and DG-SS23) are used to document background concentrations of lead 

and PCBs. These sampling locations were selected because they are located in the vicinity of Source 1 

but are located outside the probable fill area of Source 1, based on the approximate fill boundaries of 

Source 1, and are not likely to have been impacted by Sauer Dump (Ref. 15; Ref. 31, Figure 10, p. 82). 

Parcel 137 is referred to as the Lusk property in Reference 14 and the location is shown in Reference 14, 

Volume 2, page 119. The Lusk property is east of Parcel 425 and Source 1. Aerial photographs show 

that the Lusk property, as well as Sauer Dump, was created by fill. Sauer Dump was an emergent 

herbaceous wetland prior to being filled (Ref. 14, pp. 10, 119; Ref. 61, pp. iii, 1, 2, 10, 11). Analytical 

results from soil samples collected from the Lusk property show lead and PCBs concentrations in the fill 

surrounding Source 1. 

The surface soil samples were analyzed for lead in accordance with EPA Method 6010B, and PCBs in 

accordance with EPA Method 8082 as stipulated in the EPA-approved remedial action plan (RAP) (Ref. 

25) and addendums. Subsurface soil samples were analyzed for lead in accordance with EPA Method 

6010B, PCBs in accordance with EPA Method 8082, VOCs in accordance with EPA Method 8260B, and 

SVOCs in accordance with EPA Method 8270C as stipulated in the EPA-approved RAP and addendums. 

Surface and subsurface soil samples were homogenized after collection by first removing rocks or organic 

matter and then using the coning and quartering method (American Society for Testing and Materials 

[ASTM] C702-80) (Ref. 31, p. 15; Ref. 17, p. 13). The chain-of-custody records for the background 

samples are presented in Reference 17, page 16. The data validation is provided in Reference 31, 

Appendix B, page 104. The data review was performed in accordance with the procedures specified in 

Appendix E, Quality Assurance Project Plan of the Response Action Plan – Revision 2 (Final) (Ref. 25); 

EPA Functional Guideline documents for Organic (1999) and Inorganic Data Review (2002); EPA

Region III Modifications to National Functional Guidelines for Organic Data Review (September 1994); 

and quality assurance and control parameters set by the project laboratories (Ref. 17; Ref. 31, pp. 22, 

105).

Surface soil samples were collected from under the vegetative mat with a disposable trowel in accordance 

with Standard Operating Procedure (SOP) 2 in Appendix A of the Field Sampling Plan (FSP) (Ref. 24, p. 

11; Ref. 31, p. 15). Samples consisted of a three-point composite of soil collected from approximately 0 

to 6 inches bgs, placed on a disposable aluminum tray, and homogenized (Ref. 31, p. 15). 

PCB and lead concentrations detected in the background soil samples collected from Parcel 137 are 

summarized in Table 3 of this documentation record. Background sampling locations are shown in 

Reference 33. 
SD-Waste Characteristics

25

TABLE 3

2007 BACKGROUND SOIL CONCENTRATIONS

Sample ID DG-SS19-0

Sample Type Soil

Sample Date 01/11/2007

Hazardous 

Substance

Hazardous Substance 

Concentration (mg/kg)

Sample Quantitation 

Limit* (mg/kg)

Reference

Lead 114 J 0.18 31, pp. 66, 82; 17, pp. 73, 768

Aroclor 1242 <0.037 U 0.037 31, pp. 66, 82; 17, p. 41

Aroclor 1248 <0.037 U 0.037 31, pp. 66, 82; 17, p. 41

Aroclor 1254 <0.037 U 0.037 31, pp. 66, 82; 17, p. 41

Aroclor 1260 0.041 0.037 31, pp. 66, 82; 17, p. 41

Sample ID DG-SS20-0

Sample Type Soil

Sample Date 01/11/2007

Hazardous 

Substance

Hazardous Substance 

Concentration (mg/kg)

Sample Quantitation 

Limit * (mg/kg)

Reference

Lead 130 J 0.21 31, pp. 66, 82; 17, pp. 74, 768

Aroclor 1242 <0.043 U 0.043 31, pp. 66, 82; 17, p. 42

Aroclor 1248 <0.043 U 0.043 31, pp. 66, 82; 17, p. 42

Aroclor 1254 <0.043 U 0.043 31, pp. 66, 82; 17, p. 42

Aroclor 1260 0.036 J 0.043 31, pp. 66, 82; 17, p. 42

Sample ID DG-SS21-0

Sample Type Soil

Sample Date 01/11/2007

Hazardous 

Substance

Hazardous Substance 

Concentration (mg/kg)

Sample Quantitation

Limit* (mg/kg)

Reference

Lead 324 J 0.27 31, pp. 66, 82; 17, pp. 75, 768

Aroclor 1242 <0.056 U 0.056 31, pp. 66, 82; 17, p. 43

Aroclor 1248 <0.056 U 0.056 31, pp. 66, 82; 17, p. 43

Aroclor 1254 <0.056 U 0.056 31, pp. 66, 82; 17, p. 43

Aroclor 1260 0.26 0.056 31, pp. 66, 82; 17, p. 43
SD-Waste Characteristics

26

TABLE 3 (Continued)

2007 BACKGROUND SOIL CONCENTRATIONS

(Continued)

Sample ID DG-SS22-0

Sample Type Soil

Sample Date 01/11/2007

Hazardous 

Substance

Hazardous Substance 

Concentration (mg/kg)

Sample 

Quantitation Limit* 

(mg/kg)

Reference

Lead 140 J 0.54 31, pp. 66, 82; 17, pp. 76, 768

Aroclor 1242 <0.059 U 0.059 31, pp. 66, 82; 17, p. 44

Aroclor 1248 <0.059 U 0.059 31, pp. 66, 82; 17, p. 44

Aroclor 1254 <0.059 U 0.059 31, pp. 66, 82; 17, p. 44

Aroclor 1260 0.14 0.059 31, pp. 66, 82; 17, p. 44

Sample ID DG-SS23-0

Sample Type Soil

Sample Date 01/11/2007

Hazardous 

Substance

Hazardous Substance 

Concentration (mg/kg)

Sample 

Quantitation Limit* 

(mg/kg)

Reference

Lead 205 J 0.48 31, pp. 66, 82; 17, pp. 77, 768

Aroclor 1242 <0.053 U 0.053 31, pp. 66, 82; 17, p. 45

Aroclor 1248 <0.053 U 0.053 31, pp. 66, 82; 17, p. 45

Aroclor 1254 0.051 J 0.053 31, pp. 66, 82; 17, p. 45

Aroclor 1260 0.12 0.053 31, pp. 66, 82; 17, p. 45

Notes:

All concentrations have been converted to mg/kg. 

* As documented in Reference 52, the reporting limits provided in Reference 17 are equivalent to the sample quantitation 

limits. Reference 52 calculates the sample quantitation limits for several samples results in Reference 17. As 

documented in Reference 52, the sample quantitation limits are equal to the reporting limits. Therefore, the reporting 

limits are equivalent to the sample quantitation limit. The non sample specific method detection limit for lead is 0.30 

mg/kg and for PCBs is 0.033 mg/kg (Ref. 17, pp. 60, 84). 

J The reported value is an estimate (Ref. 17, pp. 5, 45). 

mg/kg Milligram per kilogram

SS Surface soil

U Analyte not detected (reporting limit presented) 
SD-Waste Characteristics

27

LEAD AND PCB BACKGROUND CONCENTRATIONS

The highest background lead and PCB concentrations are summarized in Table 4. These concentrations 

represent concentrations of lead and PCB in the area of Source 1 and are not used to establish observed 

contamination. The concentrations are included to provide evidence that the lead and PCB concentrations 

in Source 1 samples are higher than the concentrations found in the area of the source.

TABLE 4

HIGHEST LEAD AND PCB BACKGROUND CONCENTRATIONS

Sample 

Identification

Hazardous 

Substance

Hazardous 

Substance 

Concentration Reference

DG-SS21-0

(2007) 

Lead 324 J mg/kg See Tables 1 through 

3 of this 

documentation record

All background

samples

Aroclor 1242 <0.059 See Tables 1 through 

3 of this 

documentation record

All background

samples

Aroclor 1248 <0.059 See Tables 1 through 

3 of this 

documentation record

All background

samples

Aroclor 1254 <0.059 See Tables 1 through 

3 of this 

documentation record

DG-SS21-0 Aroclor 1260 0.26 mg/kg See Tables 1 through 

3 of this 

documentation record

Notes:

All concentrations have been converted to mg/kg. 

J Estimated concentration

mg/kg Milligrams per kilogram
SD-Waste Characteristics

28

SOURCE 1 SAMPLES

Source 1 landfill samples were collected during numerous investigations, including investigations 

conducted in December 2001, June 2002, and January 2007. Analytical results from the landfill samples 

collected during these investigations are used to characterize Source 1. The landfill sample analytical 

results from these investigations document concentrations of lead and PCBs above background lead and 

PCB levels. The sections below describe the landfill sampling activities and locations, and summarize 

constituent concentrations detected in the landfill samples. Source 1 sampling locations are shown in 

Reference 33. 

The samples collected from Source 1 have been described as surface soil, subsurface soil, and fill material 

in reference documentation. Because Source 1 includes a filled marsh (landfill), all samples collected 

from Source 1 (landfill) are considered waste samples. Although reference documentation text describes 

the samples as surface and subsurface soil, all samples collected from Source 1 are considered waste 

samples. The surface and subsurface samples collected from Source 1 represent material used to fill the 

marsh or landfill wastes, and do not represent native soil. Therefore, no background sample is needed to 

document background concentrations of hazardous substances. However, to document that lead and 

PCBs are not present at high concentrations or ubiquitous in the area of Source 1, background 

concentrations of lead and PCBs have been provided in Table 4 of this documentation record. The 

background samples presented in this HRS documentation record are used to document lead and PCB 

concentrations in the area of Source 1 and are not necessarily the same matrix (fill) as the landfill 

samples.

December 2001 - Source 1 Samples 

On December 12, 2001, five surface samples were collected from Source 1 by a MDE environmental 

consultant. Samples were collected from a depth of 4 to 5 inches bgs from locations within Source 1. 

Surface sampling locations were chosen to evaluate two areas of Source 1 where prior sampling did not 

appear to have been performed. The samples were submitted for analysis to Envirosystems, Inc., in 

Columbia, Maryland. The samples were analyzed for the following constituents: VOCs using EPA 

Method 8260; SVOCs using EPA Method 8070; total metals using EPA Methods 200 series and 335.3; 

and pesticides and PCBs using EPA Method 8081/8082. All sampling was conducted according to sitespecific quality assurance and quality control (QA/QC) guidelines (Ref. 14, pp. 13, 97, 202, 206). The 

sampling and analysis plan for the sampling event is provided as Reference 57. The surface samples were 

collected within the fill area of Source 1 and are therefore considered waste samples (Ref. 15; Ref. 14, p. 

97). 

On December 11 and 12, 2001, a backhoe was used to excavate nine test pits on site to either the water 

table or to native soil. The test pit locations were chosen to evaluate features at Sauer Dump that 

indicated the potential presence of hazardous substances. Features were observed on aerial photographs, 

identified during earlier investigations, and/or depicted on topographic maps of Source 1. The depths of 

the test pits ranged between 3.5 and 11.5 feet bgs. Miscellaneous debris including wood, plastic, metal, 

rubber, brick, sand, blank sand/soil, concrete/concrete castings, asphalt, ash, electrical parts, paint/paint 

containers, batteries, crushed drums, railroad ties, styrofoam, and a white/gray powdery substance was 

observed in all of the test pits. The fill was observed to extend below the water table in seven of the nine 

test pits. Subsurface samples were collected from depths ranging from 3.5 to 11.5 feet bgs (Ref. 14, pp. 

13 to 14).
SD-Waste Characteristics

29

Between December 19 and 20, 2001, well borings were advanced to depths between 9.5 to 14 feet below 

the water table. Miscellaneous debris (wood, plastic, metal, wire, rubber, brick, sand, rock 

fragments/gravel, glass, concrete, asphalt, ceramic tile, mattress pieces, and paper) in the soil was 

observed in all of the well borings. The fill was observed to extend below the water table in four of the 

five well borings. Samples were collected from near the top of the area of native soil because of poor 

sample recovery; the amount of fill recovered from the borings was not adequate for laboratory analysis. 

The subsurface samples were collected from depths ranging between 8 and 15 feet bgs (Ref. 14, p. 14). 

Available descriptions of the source samples are summarized in Table 5. Source sampling locations are 

shown in Reference 33 and in Reference 14, Figure 3, page 97. The lead and PCB concentrations 

detected in the Source 1 samples are summarized in Table 6. 

TABLE 5

DESCRIPTION OF 2001 SOURCE 1 SAMPLES 

Sample 

Identification

(depth)

Date

Sampled

Sample 

Type 

Sample Depth

(below ground 

surface)

Sample 

Description Reference

SS-1 12/12/2001 Waste 4 to 5 inches None 14, pp. 13, 37, 97

SS-3 12/12/2001 Waste 4 to 5 inches None 14, pp. 13, 37, 97

SS-5 12/12/2001 Waste 4 to 5 inches None 14, pp. 13, 37, 97

TP-1 (3.5) 12/11/2001 Waste 3.5 feet Fill 14, pp. 13, 14, 

44, 97, 127

TP-2 (4) 12/11/2001 Waste 4 feet Fill 14, pp. 13, 14, 

44, 97, 128

TP-3 (6.75) 12/11/2001 Waste 6.75 feet Fill 14, pp. 13, 14, 

44, 97,129

TP-6 (7.5) 12/12/2001 

Waste

7.5 feet 

Fill, white gray 

powdery 

substance

14, pp. 13, 14, 

44, 97, 134 

TP-7 (5) 12/11/2001 Waste 5 feet Fill, black sand 14, pp. 13, 14, 

44, 97, 135

TP-9 (10) 12/11/2001 Waste 10 feet Fill 14, pp. 13, 14, 

44, 97, 140

MW-1 

(8-12 feet) 12/20/2001 Waste 8-12 feet 

Organic silt 

with clay and 

organic matter, 

clay

14, pp. 14, 50, 

97, 142 

MW-4 

(11-12 feet) 12/19/2001 

Waste

11-12 feet 

Clay silt, 

organic 

fragments

14, pp. 14, 50, 

97, 146 

Notes:

MW Monitoring well

SS Surface soils 

TP Test pit
SD-Waste Characteristics

30

TABLE 6

2001 SOURCE 1 SAMPLES – LEAD AND PCB CONCENTRATIONS

Sample 

Identification

(inches below 

grade unless 

otherwise noted)

Hazardous 

Substance

Concentration 

(mg/kg) Q 

Sample 

Quantitation

Limits*

(mg/kg)

(Ref. 52, p. 1)

Date Reference

Polychlorinated Biphenyls

SS-1 Aroclor 1254 1.9 D 0.34 12/12/2001 14, pp. 38, 371, 394

SS-3 Aroclor 1254 4.8 D 0.20 12/12/2001 14, pp. 38, 373, 394

SS-5 Aroclor 1260 0.85 0.042 12/12/2001 14, pp. 38, 376, 394

TP-1 (3.5) Aroclor 1254 72 D 4.6 12/11/2001 14, pp. 44, 355, 393

TP-1 (3.5) Aroclor 1260 43 D 4.6 12/11/2001 14, pp. 44, 355, 393

TP-2 (4) Aroclor 1254 84 D 2.7 12/11/2001 14, pp. 44, 357, 393

TP-3 (6.75) Aroclor 1254 800 D 24 12/11/2001 14, pp. 44, 359, 393

TP-6 (7.5) Aroclor 1242 8.8 D 0.85 12/12/2001 14, pp. 44, 365, 393

TP-6 (7.5) Aroclor 1248 9.1 D 0.85 12/12/2001 14, pp. 44, 365, 393

TP-7 (5) Aroclor 1248 1.3 D 0.081 12/12/2001 14, pp. 44, 364, 393

TP-9 (10) Aroclor 1254 3.7 D 0.29 12/11/2001 14, pp. 44, 369, 393

MW-1 (8-12 feet) Aroclor 1254 0.60 0.097 12/20/2001 14, pp. 50, 489, 523

MW-4 (11 to 12 

feet) 

Aroclor 1242 0.19 0.047 12/19/2001 14, pp. 50, 492, 523 

Metals

Sample 

Identification

Hazardous 

Substance

Concentration 

(mg/kg) Q 

Sample 

Quantitation

Limit* 

(mg/kg)

(Ref. 52, p. 1)

Date Reference

TP-1 (3.5) Lead 3,000 mg/kg 14.49 12/11/2001 14, pp. 43, 381, 393

TP-2 (4 feet) Lead 4,100 mg/kg 15.87 12/11/2001 14, pp. 43, 382, 393

TP-4 (11.5) Lead 940 mg/kg 12.50 12/11/2001 14, pp. 43, 383, 393

Notes:

All concentrations have been converted to mg/kg. 

* The sample quantitation limits are provided in Reference 52. 

mg/kg Milligrams per kilogram

D Sample diluted and reanalyzed

MW Monitoring well

Q Analytical data qualifier

SS Surface soil

TP Test pit
SD-Waste Characteristics

31

December 2001 - Source 1 Samples (Continued)

Lead concentrations detected in samples collected from Source 1 in 2001 ranged from 940 to 4,100 

mg/kg, which are concentrations significantly higher than the highest background lead level of 324 mg/kg 

(Tables 4 and 6 of this documentation record). PCBs were detected in every test pit and monitoring well 

subsurface soil sample at concentrations above background PCB levels (Ref. 14, pp. 43-44; Tables 4 and 

6 of this documentation record). PCBs are not naturally; therefore, elevated concentrations detected 

below the ground surface are attributed to an underground source of PCB, such as the waste deposited at 

Sauer Dump (Ref. 20, p. 1). 

June 2002 - Grid Sampling - Source 1 Samples 

In June 2002, additional investigations were conducted at the Sauer Dump to further identify and 

delineate areas with PCB concentrations exceeding 100 mg/kg (Ref. 14, p. 17). Two sampling grids were 

established on Source 1 at the location of two known PCB hot spots (Ref. 15; Ref. 14, Figure 7, p. 101). 

The locations of the grids are shown on Figure 7, page 101, of Reference 14. A grid interval of 3 meters 

was chosen for each sampling grid. The first grid was centered over test pit (TP)-1 and included nine 

sampling points. The dimensions of the grid were 6 meters by 6 meters. The four corners of the grid 

were surveyed. The second grid was arranged to include TP-2 and TP-3 where previous analytical results 

indicated total PCB concentrations of 84 and 800 mg/kg, respectively. The second grid was expanded to 

include areas where analytical results from samples collected during previous investigations (S-2 

collected in 1990, S-2 collected in 1999, S-3/10 collected in 1999, and S-9 collected in 1992) indicated 

total PCB concentrations of 110, 85, 81, and 150 mg/kg, respectively. The dimensions of the second grid 

were 42 meters by 18 meters and included 105 sampling points. The four corners and two mid-points of 

this grid were surveyed (Ref. 14, p. 18). 

Test pits were chosen as the means for collecting both surface and subsurface samples from Source 1. 

The test pits provided increased visual access to the subsurface material. Between June 5 and 11, 2002, a 

total of 114 test pits were excavated using backhoes to the depth of the water table (2 to 10 feet bgs). One 

composite surface sample was collected from each test pit between the depths of 0 to 2 feet. One 

composite subsurface sample was collected from depths between 2 and 4 feet in test pits where the depth 

to ground water exceeded 2 feet. A second subsurface sample was composited from each test pit between 

the depths of 4 feet and in test pits where the depth to ground water exceeded 4 feet (Ref. 14, p. 18). 

A transformer-like object was encountered at sampling location G-6 and an off-white oily fluid was 

observed leaking from the object. Samples of the fluid and fill/soil immediately under the object were 

collected. This sample appears to be sample G-6 (4-5 feet), which contains 33,000 mg/kg of Aroclor 

1254 (Ref. 14, pp. 18, 70, 719). (The Form I for the sample G-6 [4-5 feet] could not be found in 

Reference 14.) During the June 2002 sampling event, a total of 285 fill samples and one fluid sample 

were collected (Ref. 14, p. 18). The samples were screened using an immunoassay screening analysis. 

Based on the results of the screening, 30 samples were selected for PCB analysis by Envirosystems using 

EPA Method 8082 (Ref. 14, p. 19). The PCB analytical results from these samples are summarized in 

Table 7. The concentrations in Table 7 are significantly above the background PCB concentrations listed 

in Table 4 of this documentation record. An illustration of the sampling grid showing the sampling 

locations is provided in Reference 14, Figure 16, page 110, and summarized in Reference 33. 

Descriptions of the samples collected in 2002 are not provided in reference documentation. The samples 

are considered waste samples because the samples were collected from within the area of the fill (Source 

1) (Ref. 15; Ref. 33). 
SD-Waste Characteristics

32

TABLE 7

2002 SOURCE 1 SAMPLES

PCB CONCENTRATIONS

Sample 

Identification

(feet below grade)

Hazardous 

Substance

Concentration

(mg/kg) Q 

SQL(mg/kg)

(Ref. 52, pp. 

1, 2)

Date Reference

J-13 (0-2) Aroclor 1254 105 D 6.95 06/05/2002 14, pp. 678, 717

G-6 (4-7) Aroclor 1254 3,900 D 173.68 06/11/2002 14, pp. 679, 717

G-7 (4-6) Aroclor 1254 100 D 6.95 06/11/2002 14, pp. 680, 717

I-11 (2-4) Aroclor 1254 400 D 17.37 06/06/2002 14, pp. 681, 717

G-7 (2-4) Aroclor 1254 370 D 17.37 06/11/2002 14, pp. 682, 717

A-3 (2-3) Aroclor 1254 1.2 D 0.35 06/05/2002 14, pp. 683, 717

D-4 (0-2) Aroclor 1254 330 D 17.55 06/10/2002 14, pp. 684, 717

I-12 (0-2) Aroclor 1254 4,600 D 173.68 06/05/2002 14, pp. 685, 717

I-12 (2-4) Aroclor 1254 1,500 D 69.47 06/05/2002 14, pp. 686, 717

F-7 (4-6) Aroclor 1254 39 D 3.47 06/11/2002 14, pp. 687, 717

I-13 (2-4) Aroclor 1254 240 D 17.37 06/05/2002 14, pp. 688, 717

G-11 (0-2) Aroclor 1254 3.2 D 0.87 06/07/2002 14, pp. 689, 717

F-7 (0-2) Aroclor 1254 410 D 34.74 06/11/2002 14, pp. 690, 717

E-8II (0-2) Aroclor 1254 420 D 34.74 06/11/2002 14, pp. 691, 718

G-6 (0-2) Aroclor 1254 97 D 6.95 06/11/2002 14, pp. 692, 718

H-10 (0-2) Aroclor 1254 390 D 34.74 06/11/2002 14, pp. 693, 718

I-8 (0-2) Aroclor 1254 580 D 34.74 06/11/2002 14, pp. 694, 718

E-8II (2-4) Aroclor 1254 310 D 27.79 06/11/2002 14, pp. 695, 718

D-8 (2-4) Aroclor 1254 13 D 1.74 06/07/2002 14, pp. 696, 718

Notes:

All concentrations have been converted to mg/kg. 

D Sample diluted and reanalyzed

mg/kg Milligram per kilogram

SQL Sample quantitation limit
SD-Waste Characteristics

33

SOURCE SAMPLES (Continued)

January 2007 - Source 1 Samples 

During the 2007 extent of contamination study, 32 surface soil and nine subsurface soil samples were 

collected from January 8 through 24, 2007. The surface soil samples were analyzed for lead in 

accordance with EPA Method 6010B and PCBs in accordance with EPA Method 8082 as stipulated in the 

EPA-approved RAP (Ref. 25, pp. 37, 49; Ref. 31, pp. 14-15) and addendums. Subsurface soil samples 

were analyzed for lead in accordance with EPA Method 6010B, PCBs EPA Method 8082, VOCs in 

accordance with EPA Method 8260B, and SVOCs in accordance with EPA Method 8270C as stipulated 

in the RAP and addendums. Surface and subsurface samples were homogenized after collection by first 

removing rocks or organic matter and then using the coning and quartering method (ASTM method 

C702-80) (Ref. 31, pp. 14, 15). 

Surface samples were collected from under the vegetative mat with a disposable trowel in accordance 

with SOP 2 in Appendix A of the FSP (Ref. 24, Appendix A, p. 11). Samples included a three-point 

composite from approximately 0 to 6 inches bgs and were placed on disposable aluminum trays and 

homogenized (Ref. 31, p 15). 

Subsurface samples were collected by driving a 5-foot core sampler with a sledgehammer or by 

hydraulically driving the core sampler with a drill rig. The core was a 1.5-inch-diameter, hollow 

stainless-steel probe rod that contained a clean acetate sampling tube for collection of soil samples. The 

samples collected via drill rig were collected in accordance with SOP 4 in the FSP (Ref. 24, Appendix A, 

p. 31). The 2- to 3-foot sample interval was then placed on a disposable aluminum tray, homogenized, 

and then transferred to sample containers to be submitted for lead and PCB analysis (Ref. 31, p. 15). 

The chain-of-custody records for the samples are presented in Reference 17, page 15; Reference 18, page 

7; Reference 50, page 7; and Reference 51, pages 8 and 9. The data validation report is provided in 

Reference 31, Appendix B, page 104 (Ref. 31, p. 21). Source sampling locations are shown in Reference 

31, Figure 6, page 78, and Figure 7, page 79 and Reference 33. Descriptions of the surface samples are 

not provided in reference documentation. Table 8 provides descriptions of the subsurface samples. Table 

9 summarizes the concentrations of PCBs and lead detected in the source samples collected in 2007. 

TABLE 8

DESCRIPTION OF 2007 SOURCE 1 SAMPLES 

Sample 

Identification

Date

Sampled

Sample 

Type 

Sample 

Depth Sample Description Reference

DG-SB01-02 01/24/2007 Waste 2-3 Fill, silty clay, brick, crushed 

stone, concrete, twigs

31, pp. 22, 67, 

93

DG-SB02-02 01/24/2007 Waste 2-3 Fill, brick, crushed stone, 

concrete, plastic pieces

31, pp. 22, 67, 

94

DG-SB03-02 01/24/2007 Waste 2-3 Fill, rock fragments, brick, 

clayey silt, roots, sand

31, pp. 22, 67, 

95

DG-SB04-02 01/24/2007 Waste 2-3 Fill, brick, glass, crushed 

stone, concrete, silt, sand

31, pp. 22, 67, 

96 

 Notes: Sample depth is in feet below ground surface.

SB Soil boring
SD-Waste Characteristics

34

TABLE 9

2007 SOURCE 1 SAMPLES 

Sample 

Identification Hazardous 

Substance

Concentration 

(mg/kg)

SQL

(mg/kg)

(Ref. 52, pp. 3, 4)

Date Reference

Surface Samples

DG-SS01-0 Aroclor 1254 1.0 0.041 01/08/2007 31, pp. 65, 78; 18, 

pp. 6, 7, 14

DG-SS01-0 Aroclor 1260 0.62 0.041 01/08/2007 31, pp. 65, 78; 18, 

pp. 6, 7, 14

DG-SS02-0 Aroclor 1254 0.59 0.041 01/10/2007 31, pp. 65, 78; 17, 

pp. 14, 15, 32 

DG-SS02-0 Aroclor 1260 0.74 0.041 01/10/2007 31, pp. 65, 78; 17, 

pp. 14, 15, 32 

DG-SS03-0 Aroclor 1254 7.7 0.41 01/09/2007 31, pp. 65, 78; 18, 

p. 6, 7, 15

DG-SS04-0 Aroclor 1254 1.4 0.038 01/09/2007 31, pp. 65, 78; 18, 

pp. 6, 7, 16

DG-SS04-0 Aroclor 1260 0.720 0.038 01/09/2007 31, pp. 65, 78; 18, 

pp. 6, 7, 16

DG-SS05-0 Aroclor 1260 1.2 0.043 01/10/2007 31, pp. 65, 78; 17, 

pp. 14, 15, 33 

DG-SS06-0 Aroclor 1254 0.62 0.038 01/09/2007 31, pp. 65, 78; 18, 

p. 6, 7, 17 

DG-SS06-0 Aroclor 1260 0.38 0.038 01/09/2007 31, pp. 65, 78; 18, 

p. 6, 7, 17

DG-SS07-0 Aroclor 1254 0.72 0.044 01/09/2007 31, pp. 65, 78; 18, 

p. 6, 7, 18

DG-SS07-0 Aroclor 1260 0.36 0.044 01/09/2007 31, pp. 65, 78; 18, 

p. 6, 7, 18

DG-SS08-0 Aroclor 1254 0.65 0.051 01/09/2007 31, pp. 65, 78; 18, 

p. 6, 7, 19 

DG-SS08-0 Aroclor 1260 0.37 0.051 01/09/2007 31, pp. 65, 78; 18, 

p. 6, 7, 19 

DG-SS24-0 Lead 2,720 2.2 01/23/2007 31, pp. 66, 78; 50, 

p. 6, 7, 28, 790

DG-SS24-0 Aroclor 1254 48 4.85 01/23/2007 31, pp. 66, 78; 50, 

p. 6, 7, 13

Subsurface Samples

DG-SB01-2 Lead 626 0.7 01/24/2007 31, pp. 67, 79; 51, 

pp. 7, 8, 123, 1572

DG-SB01-2 Aroclor 1254 0.71 L 0.039 01/24/2007 31, pp. 67, 79; 51, 

pp. 7, 8, 104, 1572
SD-Waste Characteristics

35

TABLE 9 (Continued)

2007 SOURCE 1 SAMPLES 

Sample 

Identification

Hazardous 

Substance

Concentration 

(mg/kg)

SQL

(mg/kg)

(Ref. 52, 

pp. 3, 4)

Date Reference

Subsurface Samples

DG-SB01-2 Aroclor 1260 0.63 L 0.039 01/24/2007 31, pp. 67, 79; 51, 

pp. 7, 8, 104, 1572

DG-SB02-2 Lead 13,100 22.72 01/24/2007 31, pp. 67, 79; 51, 

pp. 7, 8, 124, 1572

DG-SB02-2 Aroclor 1254 1.6 0.050 01/24/2007 31, pp. 67, 79; 51, 

pp. 7, 8, 105, 1572 

DG-SB02-2 Aroclor 1260 0.64 0.050 01/24/2007 31, pp. 67, 79; 51, 

pp. 7, 8, 105, 1572 

DG-SB03-2 Lead 752 0.62 01/24/2007 31, pp. 67, 79; 51, 

pp. 7, 8, 125, 1572

DG-SB04-2 Lead 770 1 01/24/2007 31, pp. 67, 79; 51, 

pp. 7, 9, 126, 1572

DG-SB04-2 Aroclor 1254 0.35 0.057 01/24/2007 31, pp. 67, 79; 51, 

pp. 7, 9, 107, 1572

DG-SB04-2 Aroclor 1260 0.20 0.057 01/24/20070 31, pp. 67, 79; 51, 

pp. 7, 9, 107, 1572 

Notes:

All concentrations have been converted to mg/kg. 

 

mg/kg Milligrams per kilogram

L Estimated low

MDL Method diction limit

SQL Sample quantitation limit

SB Subsurface sample, sampling depth 2 to 3 feet below ground surface

SS Surface sample, sampling depth 0 to 6 inches below ground surface (Ref. 31, p. 15)

OTHER INVESTIGATIONS

Source 1 samples were collected during several previous investigations conducted at Sauer Dump. 

Analytical results from these investigations identify lead and PCBs in source samples. Analytical data are 

summarized in the sections below to provide additional evidence supporting the presence of lead and 

PCBs in Source 1. The data are not used to characterize Source 1. 

1986 SI Sample Results

 

Analytical results of samples collected by EPA Region 3’s FIT during an SI in 1985 provide evidence 

supporting that hazardous substances were disposed in Source 1. The sampling locations are shown on 

Figure 3 of Reference 6, page 73. Table 10 summarizes the hazardous substances detected at Source 1 

during the 1985 sampling event. All samples collected during the SI were sent to laboratories contracted 

under the CLP for target compound list (TCL) organics and target analyte list (TAL) inorganics analyses 

(Ref. 6, Section 6). 
SD – Waste Characteristics

36

TABLE 10

1986 SI SAMPLE RESULTS

Hazardous Substance Sample 

Identification

Concentration 

(mg/kg)

*CRQL

(mg/kg)

Reference

Polychlorinated biphenyls

Aroclor 1254 S-4 1.452 0.033 6, p. 6-1B 

S-5 4.557 0.033 6, p. 6-1B 

S-6 2.056 0.033 6, p. 6-1B

S-7 3.305 0.033 6, p. 6-1B 

Notes:

All concentrations have been converted to mg/kg. 

mg/kg Milligrams per kilogram 

*CRQL Contract-required quantitation limit (Ref. 30)

1992 ESI Sampling Results

 

During the 1992 ESI, soil samples were collected from the Sauer Dump property. The soil sampling 

locations are shown in Figure 2-1, p. 22 of Reference 5. Background soil sample S-12 was collected to 

establish background concentrations. Aroclor 1254 was detected in soil samples S-6 at 0.320 mg/kg, S-8 

at 39 mg/kg, S-9 at 150 mg/kg, S-10 at 1.1 mg/kg, and S-11 at 0.480 mg/kg. Aroclor 1254 was not 

detected in the background soil sample S-12 (Ref. 5, pp. 21, 22, Section 3.0, p. 61; Ref. 30). The soil 

samples were sent to laboratories contracted under EPA’s CLP for TCL organics and TAL inorganics 

analyses (Ref. 5, p. 85). 

During this investigation, the contractor observed large quantities of debris on the ground surface 

including scrap metal, concrete piping, broken concrete and asphalt, railroad ties, treated lumber, wire, 

and cable; 12 rusty 55-gallon drums in various locations; a sulfide-type odor at various locations; and an 

oily sheen on surface water (Ref. 5, p. 24). 
SD – Waste Characteristics

37

1999 MDE Sample Results

In late 1999, MDE collected eight surface soil samples, one background surface soil sample, and two

subsurface soil samples from Sauer Dump (Ref. 29, pp. 3, 8, 9, 13). The sampling locations are shown on 

Figures 3, 4, and 5, pp. 8, 9, and 10, of Reference 29. The samples were sent to a CLP laboratory for 

VOC, SVOC, pesticides/PCB, and inorganics analyses (Ref. 29, pp. 12 to 20). Tables 11 and 12 

summarize the hazardous substances detected at Source 1 during this sampling event. To identify 

concentrations significantly above background levels, the soil concentrations detected were compared to 

the concentrations detected in background soil sample S-9 (Ref. 29, p. 8). 

TABLE 11

1999 SOIL SAMPLE PCB ANALYTICAL RESULTS 

Hazardous Substance Sample 

Identification

Concentration

(mg/kg)

CRQL

(mg/kg)

Reference

Polychlorinated biphenyls

Aroclor 1254 S-1 25.94 0.033 29, p. 15 

S-2 84.78 0.033 29, p. 15 

S-4 16.60 0.033 29, p. 15 

S-5 13.20 0.033 29, p. 15 

S-8 0.700 0.033 29, p. 15 

S-10 32.00 0.033 29, p. 15 

S-11 17.70 0.033 29, p. 15 

S-12 7.90 0.033 29, p. 15 

Aroclor 1260 S-11 11.13 0.033 29, p. 15

Notes:

All concentrations have been converted to mg/kg. 

CRQL Contract-required quantitation limit (Ref. 30, p. 3) 

mg/kg Milligrams per kilogram

S Soil
SD – Waste Characteristics

38

TABLE 12

1999 SOIL SAMPLE LEAD ANALYTICAL RESULTS 

Hazardous 

Substance

Evidence Concentration 

(mg/kg)

Background 

Concentration 

(mg/kg)

(S-9)

CRDL

(Ref. 30, p. 2) 

(mg/kg)

Reference

Metals

Lead

S-1 1,409 47.9 0.6 29, p. 13 

S-2 5,944 47.9 0.6 29, p. 13 

S-3 2,232 47.9 0.6 29, p. 13 

S-4 1,407 47.9 0.6 29, p. 13 

S-11 831 47.9 0.6 29, p. 13 

S-12 2,283 47.9 0.6 29, p. 13 

Notes:

CRDL Contract-required detection limit

mg/kg Milligrams per kilogram

S Surface soil

2004 and 2005 Remedial Investigation 

As part of the remedial investigation/feasibility study (RI/FS), soil sampling activities were conducted in 

January 2004 (Ref. 14, pp. 19, 21) and March 2005 (Ref. 14, p. 20) at the Sauer Dump property. 

Analytical results from these sampling events were not used to characterize Source 1 because the 

laboratory data reports for these investigations could not be located to be used as a reference for this 

documentation record. 
SD – Hazardous Waste Quantity 

39

2.4.2 Hazardous Waste Quantity

2.4.2.1.1 Hazardous Constituent Quantity

Hazardous Substance Constituent Quantity 

(pounds)

Reference

The information available is not sufficient to adequately support the evaluation of the hazardous 

constituent quantity for Source No. 1. 

Sum (pounds): Unknown 

Hazardous Constituent Quantity Value (C): Not available

2.4.2.1.2 Hazardous Wastestream Quantity

Hazardous Substance Quantity (pounds) Reference

The information available is not sufficient to adequately support the evaluation of the hazardous 

wastestream quantity for Source No. 1. 

Sum (pounds): Unknown 

Hazardous Wastestream Quantity Value (W): Not available

2.4.2.1.3 Volume

The information available is not sufficient to adequately support the evaluation of the volume for Source 

No. 1. 

Dimension of source (yd3

 or gallons): Unknown 

Volume Assigned Volume: Not available

2.4.2.1.4 Area

As documented in Tables 6, 7, and 9 of this documentation record, analytical results of samples collected 

from Source 1 revealed the presence of lead and PCBs. Source 1 is estimated to cover at least 2.48 acres, 

which is the area of Parcel 425 on which the fill is located (Ref. 15; Ref. 14, pp. 9, 96). The area of the 

fill has been estimated from elevations on Sauer Dump and is shown in Reference 15. Therefore, the area 

of Source 1 is estimated to be at least 2.48 acres, or 108,028.8 ft2

. The source type is ‘Landfill’, so the 

area value is divided by 3,400 to obtain the assigned value, as shown below (Ref. 1, p. 51591, Table 2-5). 

Dimension of source (ft2

): 108,028.8 

Area (A) Assigned Value: 108,028.8/3,400 = 31.77 

2.4.2.1.5 Calculation of a Source Hazardous Waste Quantity (HWQ) Value

The source area HWQ for Source 1 is assigned a value of 31.77 (Ref. 1, Section 2.4.2.1.5). 

 
Summary of Sources Evaluated

40

 

SUMMARY OF SOURCES EVALUATED

Source

No.

Source Name Source Hazardous

Waste Quantity 

Value

Source Containment Values

Ground

Water

Surface

Water

Air

Gas

Air

Particulate

1 Landfill 31.77 NS 10 NS NS

Notes:

NS Not Scored 

Total Source Hazardous Waste Quantity Value: 31.77 

 (Ref. 1, Section 2.4.2.2)
SWOF - Surface Water Overland Flow/Flood Migration Pathway 

41

4.0 SURFACE WATER MIGRATION PATHWAY

4.1 Overland/Flood Migration Component 

 

4.1.1.1 Definition of Hazardous Substance Migration Path for Overland/Flood Component

Prior to being filled with waste materials as part of landfill activities, the Sauer Dump area was 

undeveloped woodland and wetland containing a natural drainage channel. A finger of a natural 

drainageway trending northwest-southwest was present across the Sauer Dump area. This drainage 

system was occupied by an emergent herbaceous wetland that extended across the area and carried runoff 

from the area directly into the Back River (Ref. 61, pp. 1, 10, 11). A 2012 historical aerial photography 

study completed for the property documents landfilling of these wetlands (Ref. 61, p. iii). 

During the 1986 SI completed at Sauer Dump, EPA Region 3 observed wetlands flowing from east to 

west along the northern border of Source 1. This wetland area was located approximately 40 feet north of 

the former drum storage area, as described in Reference 6. A small pond was observed within these 

wetlands. The wetlands were observed to discharge directly into the Back River (Ref. 6, p. 9 and Figure 

2, p. 72). 

During the 1992 ESI, a wetland delineation was completed at Sauer Dump (Ref. 5, p. 74). The 

delineation was conducted using the Federal Manual for Identifying and Delineating Jurisdictional 

Wetlands, was verified using the 1987 U.S. Army Corps of Engineers’ (USACE) Wetland Delineation 

Manual and the delineated wetlands were determined to meet HRS requirements. Five palustrine and 

three estuarine wetlands were identified on Sauer Dump (Ref. 5, pp. 74 and 78). The wetlands were 

identified along the eastern, southern, western, and northwestern borders of Source 1 (Ref. 5, p. 78; Ref. 

8; Ref. 34). At the time of the 1992 wetland delineation, all of these wetlands were connected by 

drainage channels that were also identified as wetlands (Ref. 5, pp. 74 to 85). 

A second wetland delineation was performed on Sauer Dump in 2002. The information gathered during 

the 2002 delineation was consistent with the information found during the 1992 delineation. The 2002 

delineation documented the presence of two unconnected parcels of wetlands. Figure 5, page 99, of 

Reference 14 shows the two distinct wetland areas, the 25-foot buffer zone surrounding the non-tidal 

wetland areas, and the high water marks associated with the pond northwest of Source 1 and Back River 

located south of Source 1. The 2002 delineation identified Wetland #1 as a small isolated non-tidal 

wetland covering 0.7 acre surrounding a pond that is north of Source 1. Wetland #2 is identified as a 

larger wetland area covering 1.39 acres. Reference documentation divides Wetland #2 into three areas: 

the Southwest Finger, the Back River Shoreline Area, and the Southeast Finger. Wetland #2 is comprised 

of a tidal wetland area along the shoreline (below the high water mark) and non-tidal wetland areas in the 

Southwest Finger and the Southeast Finger (above the high water mark) (Ref. 14, p. 16 and Appendix E, 

p. 150). 

The 2002 wetland delineation was completed using the methodology contained in the revised 1987 

USACE’s Wetland Delineation Manual (subsequently referred to as 1987 Manual), and other related 

guidance documents and the delineated wetlands were determined to meet HRS requirements (Ref. 14, p. 

151). 

A third wetland delineation was performed at Sauer Dump in 2012 (Ref. 62, p. 1). The 2012 wetland 
SWOF - Surface Water Overland Flow/Flood Migration Pathway 

42

delineation was performed using the USACE 2010 Interim Regional Supplement to the Corps of 

Engineers Wetland Delineation Manual; Atlantic and Gulf Coastal Plain Region (Version 2.0) and the 

delineated wetlands were determined to meet HRS requirements (Ref. 62, pp. 6, 11). The results of this 

2012 delineation were generally consistent with and confirmed the results of the 2002 delineation, with 

slight adjustments to the boundaries of the wetlands that did not result in a change to HRS factor values

(Ref. 14, p. 163; Ref. 34; Ref. 62, pp. 1, 8 to 10, 17). The 2012 wetland delineation also inspected a 

fringe of the Wetland #1 wetlands adjacent to the pond to the northwest, identifying that the pond is 

actually hydrologically connected to the southwest finger by a jurisdictional depression/channel (62, p. 9, 

24).

Wetland #2 and much of Source 1 are located in a 100-year flood plain (Ref. 33; Ref. 34; Ref. 12). 

The hazardous substances migration pathway includes both the overland and in-water segments of the 

pathway along which hazardous substances would migrate from the source (Ref. 1, Section 4.1.1.1). 

Surface water runoff from Source 1 can flow either east, west, or south to Wetland #2, or north to 

Wetland #1 (Ref. 14, pp. 96, 99). The watershed at the Sauer Dump site includes sensitive environments 

(wetlands) and a human food chain fishery. While the 2012 wetland delineation has identified that 

Wetland #1 is hydrologically connected to Wetland #2, Wetland #1 is not evaluated for HRS scoring 

purposes as part of this HRS documentation record because it would not affect the site score. 

The probable point of entry (PPE) of the hazardous substances from Source 1 into surface waters is 

Wetland #2, adjacent to the eastern, southern, and western boundaries of Source 1 (Ref. 62, p. 17; Ref. 

33; Ref. 34). Surface water runoff from Source 1 follows the contours of the land and flows to Wetland 

#2. Maps showing the land contours are provided in Reference 14, pages 96 to 99, and 102 to 106 and 

Reference 15. Wetlands that are contiguous to a river (such as Wetland #2) are considered to be surface 

water (Ref. 1, Section 4.0.2). Runoff from Source 1 can enter Wetland #2 at any location. Because 

Wetland #2 surrounds the eastern, southern, and western boundaries of Source 1, the PPE is the entire 

boundary of Wetland #2 adjacent to Source 1 (Ref. 14, pp. 96 to 99, and 102 to 106; Ref. 34). 

The target distance limit (TDL) defines the maximum distance over which targets are evaluated. The 15-

mile TDL starts at the PPE of hazardous substances to surface water and includes areas 15 miles 

downstream from the most downstream PPE to surface water, and the distance between the most 

upstream and downstream PPE (Ref. 1, Section 4.1.1.2). The in-water segment of the surface water 

pathway TDL starts at the most upstream PPE from Source 1 to Wetland #2. As stated earlier, surface 

water runoff from Source 1 can enter Wetland #2 anywhere along the boundary of Source 1 and the 

wetland; Source 1 and the Wetland #2 are located adjacent to each other. There are two upstream PPEs 

into Wetland #2: one into the Southwest Finger of Wetland #2, labeled as PPE-1 in Reference 34, and one 

into the Southeast Finger of Wetland #2, labeled as PPE-2 in Reference 34. The distance from PPE-1 and 

PPE-2 to the Back River is approximately 630 feet and 320 feet, respectively. From Wetland #2, the 

Back River flows about 4.0 miles to the southeast and empties into the Chesapeake Bay. The remaining 

portion of the 15-mile surface water migration pathway (11 miles) is in the Chesapeake Bay (Ref. 13). 

The end of Back River is defined by the end the Tidal Back River watershed as shown in Reference 9, 

page 12, and is shown as line drawn between two land masses on Reference 13. 

The Back River and Chesapeake Bay are tidally influenced within the TDL (Ref. 9, pp. 12, 32, 302, 324). 

When defining the TDL of a water body, tides are considered (Ref. 1, Section 4.1.1.2). Data do not exist 

to document the potential tidal carry of hazardous substances in the Back River; therefore, only targets 

identified within the downstream portion of the TDL have been scored. A report estimated the Back 
SWOF - Surface Water Overland Flow/Flood Migration Pathway 

43

River tidal flow to be more than 4 miles upstream from Sauer Dump (Ref. 5, p. 15). Fisheries and 

sensitive environments located outside the area of actual contamination (Wetland #2) will not 

significantly increase the site score because these targets are not subject to actual contamination, and any 

potential target values would be lowered by the high dilution weight value for the Back River (Ref. 1, 

Table 4-13, Section 4.1.3.3.2.3, and Section 4.1.4.3.1.3). Water level monitoring of the Back River at 

Sauer Dump in May and June 2002 recorded a mixed tide with a maximum daily tide of approximately 

1.9 feet. The maximum recorded tidal fluctuation from the highest high tide to the lowest low tide was 

approximately 2.6 feet during the monitoring period (Ref. 14, p. 4). 

Table 13 presents the TDLs for the Sauer Dump property. 

TABLE 13

15-MILE TARGET DISTANCE LIMIT

Surface Water Body Distance Measured PPE-1 and PPE-2 Reference

Wetland #2 630 feet (PPE-1) and 320 feet (PPE-2) 13

Back River 350 feet to 4 mile 13

Chesapeake Bay 4 to 15 miles 13
SW - Observed Release

44

4.1.2.1 Likelihood of Release

4.1.2.1.1 Observed Release

Chemical Analysis - 2007 Sediment Sampling

Between January 9 and 11, 2007, environmental consultants to MDE collected nine sediment samples 

from wetlands surrounding Source 1 and the Back River. The sediment samples were analyzed for lead 

by EPA Method 6010B and PCBs by EPA Method 8082 and 1668a in accordance with the EPA-approved 

RAP and addendums. Samples were collected within the top 6 inches of sediment in accordance with 

SOP 6 in the FSP. The locations of the sediment samples are shown on Figure 8, page 80, of Reference 

31 (Ref. 24, p. 56; Ref. 25, Appendix E, p. 27; Ref. 31, pp. 15 to 16). Reference 8 provides background 

and release sediment sampling locations as well as the lead and PCB concentrations detected in the 

samples. 

Sediment samples were collected from beneath organic build-up or detritus material. Any decomposed 

organic material present at the sampling locations at time of sampling was included in the sample to

accurately represent the potential for this interval to be impacted by deposition and adsorption. Sediment 

samples were collected with a decontaminated stainless-steel, Wildco 2-inch liner-type, hand-corer 

sediment sampler. Samples were placed in aluminum trays and homogenized using the coning and 

quartering method. A flat-bottom boat was used to collect off-shore sediment samples (sample DGSD01-0.5). Sample DG-SD06-0.5 was collected with a disposable plastic trowel because the Wildco 

sampler was unable to retrieve a solid sediment sample (Ref. 31, p. 16).

Sediment samples were analyzed for PCBs using EPA Method 8082 and 1668B, and for lead using EPA 

Method 6010B (Ref. 31, p. 105). Sample results were subject to data review, which included an 

evaluation of the following: sample receipt temperatures, holding times, method blanks, laboratory 

control samples, matrix spike/matrix spike duplications, field duplicates, surrogates, instrument 

performance criteria, and calibration criteria. PCB homolog data, chromatograms, and raw data were also 

reviewed qualitatively (Ref. 31, pp. 21, 106). The data validation report is provided in Reference 31, 

Appendix B, page 104. 

The analytical data from the sediment samples was reviewed in accordance with the procedures specified 

in (1) the site-specific Quality Assurance Project Plan (QAPP) prepared by the environmental consultant, 

(2) EPA Functional Guideline documents for Organic and Inorganic Data Review, (3) EPA Region 3 

Modifications to National Functional Guidelines for Organic Data Review, and (4) quality assurance and 

control parameters set by the project laboratories (Ref. 31, p. 105). 

Background and release sediment sampling locations are shown in Reference 8. Table 14 summarizes the 

background sampling location and Table 15 presents PCB and lead concentrations detected in the 

background sample. Table 16 summarizes the release sampling locations and Table 17 presents PCB and 

lead concentrations detected in the release samples. As described in the paragraphs above, the sediment 

release and background samples are similar because the samples (1) were collected using the same 

procedures; (2) were collected within the same timeframe and, therefore, the same weather conditions 

(Tables 14 and 16 of this HRS documentation record); (3) were collected at locations with similar 

topography and land use (Ref. 8); (4) were analyzed using the same methods (Ref. 31, pp. 15, 16); and (5) 

were collected from similar surface water bodies (wetlands) (Ref. 8). The 2002 wetland delineation 

describes Wetland #2 sediments as silt with cobbles with organics, and Wetland #1 sediments as silt/clay 

and clay loam and organics with silt with a few cobbles (Ref. 14, pp. 152, 156, 158, 160, 162). Both 
SW - Observed Release

45

wetland soil types are expected to contain a large amount of organic matter. The 1992 wetland 

delineation describes the soil in Wetland #2 (identified as Wetlands 3 through 6 in 1992) as Tidal Marsh 

to Mattapex silt loam and mucky, made land and mucky, and Tidal Marsh very black and mucky (Ref. 5, 

pp. 82 to 84) and Wetland #1 (identified as Wetlands 1 and 2 in 1992) as Mattapex silt loam and Tidal 

Marsh/Mattapex silt loam (Ref. 5, p. 80 to 81). 

The 2007 sediment data from the Back River do not document a release to the Back River or actual 

contamination in the Back River. 
SW - Observed Release

46

2007 Background:

TABLE 14

2007 BACKGROUND WETLAND SEDIMENT SAMPLES - LOCATIONS

Sample 

Identification Sampling Location

Depth

(feet) Date Reference

DG-SD01-0.5 

Pond wetland area (Wetland #1) that 

borders the Source 1 to the 

northwest 

0.5 01/09/2007 Ref. 31, pp. 69, 80

Notes:

SD Sediment

TABLE 15

2007 BACKGROUND SEDIMENT CONCENTRATIONS

Sample 

Identification

Hazardous 

Substance

Concentration 

(mg/kg)

SQL

(mg/kg)

(Ref. 52, pp. 2, 4)

Reference

DG-SD01-0.5 Aroclor 1254 ND 0.048 Ref. 37, pp. 14, 

15, 23

DG-SD01-0.5 Aroclor 1260 ND 0.048 Ref. 37, pp. 14, 

15, 23

DG-SD01-0.5 Lead 7.5 0.23 Ref. 37, pp. 14, 

15, 34 

Notes:

All concentrations have been converted to mg/kg. 

MDL Method detection limit

mg/kg Milligram per kilogram

ND Not detected

SD Sediment

SQL Sample quantitation limit
SW - Observed Release

47

2007 Sediment Release Locations:

TABLE 16

2007 SEDIMENT SAMPLE RELEASE LOCATIONS (Wetland #2)

Sample ID Sampling Location

Depth

(feet) Date Reference

DG-SD03-0.5 

Wetland that borders Source 

1 to the west, southwest 

finger

0.5 01/10/2007 31, pp. 69, 80 

DG-SD04-0.5 Wetland that borders Source 

1 to the east, southeast finger 0.5 01/10/2007 31, pp. 69, 80 

DG-SD05-0.5 Wetland that borders Source 

1 to the east, southeast finger 0.5 01/10/2007 31, pp. 69, 80 

DG-SD06-0.5 

Wetland that borders Source 

1 to the southeast, southeast 

finger

0.5 01/10/2007 31, pp. 69, 80 

DG-SD07-0.5 

Wetland that borders Source 

1 to the southeast, southeast 

finger

0.5 01/11/2007 31, pp. 69, 80 

Notes:

SD Sediment
SW - Observed Release

48

TABLE 17

2007 RELEASE WETLAND #2 SEDIMENT SAMPLES

PCB AND LEAD CONCENTRATIONS

Sample 

Identification

Hazardous 

Substance

Concentration 

(mg/kg) Q 

SQL

(mg/kg)

(Ref. 52, 

pp. 2, 4)

Date Reference

DG-SD03-0.5 Lead 370 0.38 1/10/2007 37, pp. 15, 33

DG-SD03-0.5 PCBs

(Aroclor 1254) 0.91 0.079 1/10/2007 37, pp. 15, 25 

DG-SD03-0.5 PCBs

(Aroclor 1260) 1.4 0.079 1/10/2007 37, pp. 15, 25 

DG-SD04-0.5 PCBs

(Aroclor 1254) 3.3 0.39 1/10/2007 40, pp. 15, 31 

DG-SD05-0.5 PCBs

(Aroclor 1254) 0.580 0.092 1/10/2007 40, pp. 15, 30

DG-SD05-0.5 PCBs

(Aroclor 1260) 0.510 0.092 1/10/2007 40, pp. 15, 30 

DG-SD06-0.5 Lead 595 0.49 1/10/2007 40, pp. 15, 46

DG-SD06-0.5 PCBs

(Aroclor 1254) 15 L 1 1/10/2007 40, pp. 15, 32 

DG-SD07-0.5 Lead 150 0.36 1/11/2007 40, pp. 16, 48

DG-SD07-0.5 PCBs

(Aroclor 1254) 1.1 0.075 1/11/2007 40, pp. 16, 34 

Notes:

All concentrations have been converted to mg/kg. 

L Analyte is present; reported value may be biased low; actual value is expected to be higher (Ref. 31, pp. 21, 22, 69, 

123)

mg/kg Milligram per kilogram

PCB Polychlorinated biphenyl 

Q Data qualifier 

SD Sediment 

SQL Sample quantitation limit
SW - Observed Release

49

OTHER EVIDENCE OF RELEASES TO WETLAND (BACK RIVER)

1992 Sediment Sampling

Between December 7 and 9, 1992, EPA contractors collected 17 sediment and 16 aqueous samples from 

wetland areas located adjacent to Source 1 and from the Back River (Ref. 5, pp. 17, 86). Figure 2, page 

22, of Reference 5, shows the sediment sampling locations. The background sediment sampling locations 

for the 1992 sampling event were SD-29 for the Back River and SD-26 for wetlands (Ref. 5, pp. 19 

through 22, 78; Ref. 53). 

Table 18 summarizes the background sampling locations and Table 19 presents PCB and lead 

concentrations detected in the background samples. Background sampling locations are provided in 

Reference 5, page 22. Table 20 summarizes release sampling locations and Table 21 presents PCB and 

lead concentrations detected in the release samples. The locations of the 1992 sediment samples are 

shown in Reference 53. 

TABLE 18

1992 BACKGROUND SEDIMENT SAMPLING LOCATIONS

 

Sample 

Identification Sampling Location Depth Date Reference

SD-26 Northeastern tip of Wetland #2 Surface 12/08/1992 5, pp. 19, 22, 78; 

16., p. 35

SD-29 100 feet west of west tributary on 

Back River Surface 12/09/1992 5, pp. 19, 22, 78; 16, p. 40

Notes:

SD Sediment

TABLE 19

1992 BACKGROUND SEDIMENT CONCENTRATIONS

Sample 

Identification

Hazardous 

Substance

Concentration 

(mg/kg) Q 

Detection 

Limit*

(mg/kg)

Date Reference

Wetland Background

SD-26 

(MCGX05) Lead 68.3 0.6 12/8/1992 5, pp. 22, 27, 

323; 16, p. 35

SD-26 

(CHH05) PCBs 0.1 U 0.033 12/8/1992 5, pp. 22, 59, 

509; 16, p. 35

Back River Background

SD-29

(MCGX31) Lead 16.5 0.6 12/8/1992 5, pp. 22, 28, 335; 16, p. 40 

SD-29

(CHH33) PCBs 0.047 U 0.033 12/8/1992 5, pp. 22, 60, 523; 16, p. 40 
SW - Observed Release

50

Notes from Table 19: 

All concentrations have been converted to mg/kg. 

* The detection limits are CRQLs and CRDLs (Ref. 30). 

mg/kg Milligram per kilogram

CRDL Contract-required detection limit

CRQL Contract-required quantitiation limit

PCB Polychlorinated biphenyl

Q Data qualifier

SD Sediment

U Not detected. The associated number indicates approximate sample concentration necessary to be detected (Ref. 5, p. 

26). 

TABLE 20

1992 RELEASE SEDIMENT SAMPLING LOCATIONS

Sample 

Identification Sampling Location Depth Date Reference

SD-1 Wetland #2 that borders property to 

east Surface 12/08/1992 5, pp. 19, 22;53; 16, pp. 24, 36 

SD-2 Wetland #2 that borders property to 

east Surface 12/08/1992 5, pp. 20, 22; 53; 16, pp. 20, 24, 38 

SD-4 

Small feeder tributary within 

Wetland #2 leading to cove, 

southeast corner of property

Surface 12/08/1992 5, pp. 20, 22; 53; 

16, pp. 20, 25, 38 

SD-15 Wetland #2 that borders property to 

west Surface 12/08/1992 5, pp. 19, 22; 53; 16, pp. 28, 36

SD-21 Wetland #2 that borders property to 

west Surface 12/08/1992 

5, pp. 21, 22; 53; 

16, pp. 12, 21, 33, 

39

SD-22 Wetland #2 that borders property to 

west Surface 12/08/1992 

5, pp. 21, 22; 53; 

16, pp. 12, 21, 33, 

39 

SD-24 Wetland #2 that borders property to 

west Surface 12/08/1992 5, pp. 19, 22; 53; 16, pp. 34, 37 

SD-25 Wetland #2 that borders the 

property to the north Surface 12/08/1992 5, pp. 20, 22; 53; 16, pp. 35, 38, 39

SD-27 Wetland #2, borders property to the 

east Surface 12/08/1992 5, pp. 19, 22; 53; 16, pp. 11, 35, 38 

Notes:

SD Sediment
SW - Observed Release

51

TABLE 21

1992 RELEASE SEDIMENT CONCENTRATIONS

Sample 

Identification

Hazardous 

Substance

Concentration 

(mg/kg) Q 

Detection 

Limit*

(mg/kg)

Reference

SD-1

(MCGX03)

Lead 716 0.6 5, pp. 27, 322 

SD-1

(CHH03)

PCBs 

(Aroclor 1254) 11 0.033 5, pp. 59, 508 

SD-2

(MCGX12)

Lead 436 0.6 5, pp. 27, 326 

SD-2

(CHH13)

PCB

(Aroclor 1254) 15 0.033 5, pp. 59, 513 

SD-4

(CHH15)

PCB

(Aroclor 1254) 0.28 0.033 5, pp. 59, 515 

SD-15

(MCGX07)

Lead 288 0.6 5, pp. 27, 324 

SD-21

(CHH23)

PCBs 

(Aroclor 1254) 0.22 0.033 5, pp. 60, 519 

SD-22

(MCGX24) Lead 394 0.6 5, pp. 28, 332 

SD-22

(CHH25)

PCBs 

(Aroclor 1260) 4.8 (0.48) J 0.033 5, pp. 60, 520 

SD-22

(CHH25)

PCBs

(Aroclor 1254)

3.1

(0.31) J 5, pp. 60, 520 

SD-24

(MCGX09)

Lead 839 0.6 5, pp. 27, 325 

SD-24

(CHH09)

PCBs 

(Aroclor 1260) 5.6 0.033 5, pp. 59, 511 

SD-25

(MCGX26) Lead 364 0.6 5, pp. 28, 333 

SD-25

(CHH27)

PCBs 

(Aroclor 1254) 0.14 0.033 5, pp. 60, 521 

SD-27

(MCGX28) Lead 1,060 0.6 5, pp. 28, 334

Notes:

 All concentrations have been converted to mg/kg. 

* The detection limits area CRQLs and CRDLs (Ref. 30). 

mg/kg Milligram per kilogram

CRDL Contract-required detection limit

CRQL Contract-required quantitation limit

J Indicates that the analyte was present, but the reported value may not be accurate or precise (Ref. 5, p. 26). 

The direction of bias of these J-qualified results is not known. Therefore, the J-qualified release value has 

been divided by PCB factor (10), making this data eligible for Hazard Ranking System evaluation (Ref. 22, 

pp. 2, 8, 16). The concentration in the parentheses is the adjusted concentration.

PCBs Polychlorinated biphenyls

Q Laboratory data qualifier
SW - Observed Release

52

1999 Sediment Sampling

In 1999, MDE conducted a site assessment of the Sauer Dump property. As part of the assessment, MDE 

collected sediment and surface water samples on September 29 and October 1, 1999. The sediment 

samples were analyzed for SVOCs, PCBs, and pesticides (Ref. 29, p. 3). The sampling locations are 

shown in Reference 29, pages 8 through 10. PCB and lead concentrations detected in the sediment 

samples are summarized in Table 22. 

TABLE 22 

1999 SEDIMENT PCB AND LEAD CONCENTRATIONS

Sample 

Identification

Hazardous 

Substance

Concentration

(mg/kg) Date Reference

SED-1 Lead 186 9/29/1999 29, pp. 12, 27

SED-1 PCBs 

(Aroclor 1254) 7.9 9/29/1999 29, pp. 15, 27

SED-2 Lead 26.5 9/29/1999 29, pp. 12, 27

SED-2 PCBs 

(Aroclor 1254) 14.4 9/29/1999 29, pp. 15, 27

SED-3 Lead 44.8 10/1/1999 29, pp. 12, 29

SED-4 Lead 32.4 10/1/1999 29, pp. 12, 29

SED-4 PCBs 

(Aroclor 1254) 2.1 10/1/1999 29, pp. 12, 29

SED-5 Lead 33.8 10/1/1999 29, pp. 12, 29

SED-6 Lead 42.7 10/1/1999 29, pp. 12, 29

SED-7 Lead 109 9/29/1999 29, pp. 12, 26

SED-7 PCBs 

(Aroclor 1254) 2.0 9/29/1999 29, pp. 15, 26

SED-8b

(background 

sample)

Lead 56.4 10/1/1999 29, pp. 12, 29

SED-8b

(background 

sample)

PCBs 

(Aroclor 1254) ND 10/1/1999 29, pp. 12, 29

SED-9

(dup of SED-2) Lead 182 9/29/1999 29, pp. 12, 27

SED-9

(dup of SED-2)

PCBs 

(Aroclor 1254) 2.0 9/29/1999 29, pp. 12, 15, 27

SED-10 PCBs 

(Aroclor 1254) 0.401 12/15/1999 29, pp. 15, 30, 31 

Notes:

 All concentrations have been converted to mg/kg. 

mg/kg Milligram per kilogram

PCB Polychlorinated biphenyl 

SED Sediment

ND None detected (Ref. 29, p. 15).
SW - Attribution

53

Attribution:

As documented in the sections below, lead and PCBs detected in Wetland #2 are attributable to Source 1 

because (1) Source 1 contains the same hazardous substances as Wetland #2, (2) Source 1 is not 

contained, (3) surface water runoff from Source 1 flows to Wetland #2, and (4) no other sources of lead 

and PCB drain to the wetland. 

Samples collected from the surface of Source 1 contained lead and PCBs. Runoff from Source 1 flows 

directly to Wetland #2 to which an observed release has been documented (Ref. 14, p. 16 and 99; Ref. 5, 

p. 4-5; Ref. 33; Ref. 34; Sections 2.4.1. and Section 4.1.1.1 and Tables 6, 7, 9, and 17 of this 

documentation record). Wetland #2 surrounds Source 1 along the eastern, southern, and western 

boundaries (Ref. 33). Other sources of contamination draining to Wetland #2 have not been identified. 

Other than Source 1, residential properties and undeveloped land drain to Wetland #2 (Ref. 25, p. 10; Ref. 

14, p. 10; Figure 2 of this documentation record). As Reference 33 shows, Wetland #2 is fairly isolated 

from contamination from sources other than Source 1. 

Wetland #2 serves as a sink for solids in runoff from Source 1. Because of the high organic content of the 

wetland, the wetland retards the transport of sediment, PCB, and lead. The tide has a limited range, two 

feet, further limiting the transport from the wetland (Ref. 31, p. 39). 

2001 Sediment Samples from Back River 

Nine sediment samples were collected from the Back River adjacent to Wetland #2 on December 18 and 

19, 2001 by MDE contractors. The sediment sampling locations within the Back River were arranged in 

a grid pattern to determine the distribution of contaminants parallel and perpendicular to the shoreline of 

the Back River. MDE used a sediment depositional pattern based on a 1974 aerial photograph and 

analytical results from previous sampling to determine the sediment sampling locations for the December 

2001 sampling event (Ref. 14, p. 15 and Figure 3, p. 97). The sampling locations are shown on Figure 3, 

page 97, of Reference 14. A description of the sampling event is described in the paragraphs below. The 

sediment samples collected from Back River indicate that the river is not contaminated with lead and PCB 

adjacent to Wetland #2 based on the low concentrations of lead and absence of PCB in the Back River 

sediments (Ref. 14, pp. 55, 56, 57, 58, 97). 

In December 2001, sampling personnel collected sediment samples from the Back River during times of 

higher tide by wading to each location. A shallow sediment sample and a deep sediment sample were 

collected from each sampling location. A 20-inch long, 2-inch-diameter sediment sampler with a Lexan 

liner, nosepiece, and core catcher was used to collect each sample. The depth to the base of the loose 

sediment was determined at each sampling location. When the depth interval was less than 30 inches, the 

depth interval was divided in half and samples were obtained from each half of the depth interval. When 

the depth interval exceeded 30 inches, a shallow sample was collected from the top 20 inches and a 

deeper sample was collected from the bottom 10 inches. The depth to the base of the loose sediment 

ranged from 7 inches to over 30 inches. Debris, such as concrete, blocks, logs, and tires, were observed 

in the sediment (Ref. 14, p. 15). 

The sediment samples were submitted for laboratory analysis to Phase Separation Science, Inc., in 

Baltimore, Maryland. The samples were analyzed for SVOCs using EPA Method 8070, total metals 

using EPA Method 200 series and Method 335.3, and pesticides and PCBs using EPA Method 

8081/8082. Duplicate samples were collected from SDMT-6 (0-4 inches) and SDMT-4 (20-30 inches). 

All sampling was conducted in accordance with QA/QC guidelines (Ref. 14, p. 15). 
SW - Attribution

54

A review of the 2001 Back River sediment sampling analytical results shows that lead and PCBs were 

detected at concentrations significantly lower than concentrations of lead and PCBs detected in Wetland 

#2. The lead and PCB concentrations were not significantly above the 2007 sediment background 

concentrations presented in Table 15 of this documentation record. Lead concentrations ranged from 8.4 

to 68 mg/kg. PCBs were not detected in the Back River sediment samples. Because the 2001 sediment 

samples were collected from the Back River immediately adjacent to Wetland #2, the analytical results 

provide evidence that the presence of lead and PCBs surrounding Source 1 (in Wetland #2) resulted from 

a release from Source 1 and not from another source within the Back River or from the Back River (Ref. 

14, pp. 55, 56, 57, 58, 97, 112). The concentrations of lead and PCB detected in the Back River 

sediments are illustrated in Figure 15, page 87 of Reference 31. 

Lead and PCB Concentration Trends

Additional evidence that the PCB contamination in Wetland #2 is from Source 1 is that the PCB 

concentrations in wetland sediment samples (DG-SD04, DG-SD05, and DG-SD06) collected directly 

downgradient of the hot spot area identified in Source 1 show decreasing levels of total PCBs the further 

the sediment sample is from the hot spot. The hot spot area is an area adjacent to Southeast Finger 

wetland where numerous source samples contained PCBs at concentrations exceeding 100 mg/kg. The 

wetland PCB sediment concentrations are detected at a maximum of 38.7 mg/kg. These results are 

consistent with historic levels of PCBs in sediment samples collected from the area, which have been

reported as high as 267 mg/kg. Sample DG-SD07, which was collected from a location further 

downgradient of the hot spot area, shows a much lower concentration of total PCBs at 1.1 mg/kg. Total 

PCBs were detected at even lower concentrations (0.067 mg/kg) near the mouth of the Southeast Finger 

(Wetland #2) in the Back River (see Figure 15, page 87, Reference 31) (Ref. 31, pp. 11, 25, 32, 40, 83). 

Further, PCB concentrations in sediment samples from Wetland #2 and the Back River show a decreasing 

trend from the wetland (north) towards the Back River (south); this data are consistent with historic 

sediment data from the Back River that have shown non-detect concentrations of PCB. This decreasing 

trend is shown on Figure 15, page 87, of Reference 31. The lead concentrations in Wetland #2 and the 

Back River follow the same trend (Ref. 31, pp. 34, 87). 

The trend in PCB and lead concentrations is further illustrated in the sediment samples collected from 

both the tidal and non-tidal wetlands. Figure 4, page 99, of Reference 14 identifies the location of the 

wetlands. Figure 4 shows a 25-foot buffer zone surroundings the non-tidal wetland areas and the high 

water marks associated with the tidal wetlands associated with the Back River, south of Source 1. Figure 

4 identifies Wetland #2 is a 1.39 acres divided into three areas: the Southwest Finger (non-tidal wetland), 

the Back River Shoreline Area (tidal wetland), and the Southeast Finger (non-tidal wetland). Wetland #2 

is comprised of a tidal wetland area along the shoreline (below the high water mark) and non-tidal 

wetland areas in the Southwest Finger and the Southeast Finger (above the high water mark) (Ref. 14, p. 

16 and Appendix E, p. 150). As shown in Reference 8, sediment samples collected from the Southwest 

and Southeast Fingers of the non-tidal wetland contain observed release concentrations of PCB and lead 

providing evidence that the PCB and lead contamination in both the tidal and non-tidal portions of the 

wetland are at least partially attributable to Source 1. 

Lead and PCB in Back River Surface Water Samples

Two surface water samples were collected from Back River in 2007 during the extent of contamination 
SW - Attribution

55

study. The surface water samples were collected soon after the peak of high tide. One filtered and one 

unfiltered surface water sample from each of the two locations were analyzed for lead and PCBs (Ref. 31, 

pp. 18, 19). No PCBs were found in the surface water samples. Low concentrations of lead, ranging 

from non-detect to 0.0302 mg/L, were detected in the surface water samples (Ref. 31, p. 70). This 

provides evidence that the source of lead and PCB is unlikely to be tidal water that floods portions of 

Wetland #2. 

Hazardous Substances Released:

PCBs (Aroclors 1242, 1248, 1254, 1260) 

Lead

Surface Water Observed Release Factor Value: 550
SW/Human Food Chain Threat – Toxicity/Persistence/Bioaccumulation

56

4.1.3.2 WASTE CHARACTERISTICS

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation

The combined toxicity, persistence, and bioaccumulation factor value is summarized in Table 23. 

TABLE 23

TOXICITY, PERSISTENCE, AND BIOACCUMULATION FACTOR VALUES

Hazardous 

Substances

Source 

No.

Toxicity 

Factor 

Value 

Persistence 

Factor 

Value

Bioaccumulation 

Value* 

Toxicity/

Persistence/

Bioaccumulation 

Factor Value 

(Ref. 1, 4-16) 

Ref. 2

Arcoclor-1242 

(polychlorinated 

biphenyl)

1 10,000 1 50,000 5x108 Page 

15 

Aroclor 1248

(polychlorinated 

biphenyl)

1 10,000 1 50,000 5×108 Page 

15 

Aroclor 1254

(polychlorinated 

biphenyl)

1 10,000 1 50,000 5×108 Page 

15 

Aroclor 1260

(polychlorinated 

biphenyl)

1 10,000 1 50,000 5×108 Page 

15 

Lead 1 10,000 1 5,000 5×107 Page 

13 

 * Back River is brackish; therefore, the higher of the freshwater or saltwater bioaccumulation value is 

assigned (Ref. 1, Section 4.1.3.2.1.3; Ref. 9, p. 32). 

The highest combined toxicity, persistence, and bioaccumulation factor value is for PCB, 5×108

. 

Toxicity/Persistence/Bioaccumulation Factor Value: 5×108

[Ref. 1, Table 4-16]
SW/Human Food Chain Threat – Waste Characteristics

57

4.1.3.2.2 Hazardous Waste Quantity

Source Number Source Hazardous Waste 

Quantity Value (Section 

2.4.2.1.5) 

Is source hazardous 

constituent quantity data 

complete? (yes/no)

1 31.77 No

Hazardous Waste Quantity Assigned Value: 100* 

[Ref. 1, Section 2.4.2.2] 

* Because the hazardous constituent quantity is not adequately determined and because targets 

in this pathway are subject to actual contamination, a hazardous waste quantity factor value 

of 100 is assigned (Ref. 1, Section 2.4.2.2; Section 4.1.4.3 of this documentation record). 
SW/Human Food Chain – Waste Characteristics

58

4.1.3.2.3 Waste Characteristics Factor Category Value

The waste characteristics factor value for the human food chain threat is calculated below, as specified in 

the HRS Final Rule (Ref. 1, Section 4.1.3.2.3): 

Toxicity/Persistence Factor Value = 10,000 

HWQ Factor Value = 100

Bioaccumulation Potential Factor Value (BPFV) = 5x104

Toxicity/Persistence Factor Value (10,000) × HWQ Value (100) = 1×106

1×106

 × BPFV (5x104) = Waste Characteristics Product (5x1010) (subject to maximum value of 1×1010) 

Waste Characteristics Factor Category Value (Ref. 1, Table 2-7) = 320 

Waste Characteristics Factor Category Value: 320

[Ref. 1, Table 2-7] 
SW/Human Food Chain Threat – Targets 

59

4.1.3.3 HUMAN FOOD CHAIN THREAT - TARGETS

Actual Human Food Chain Contamination

Actual contamination of a human food chain has not been documented. 

Back River is a fishery adjacent to wetlands surrounding Source 1 (Ref. 9, pp. 32, 65, 66, 73, 77, 

258, 274, 302, 304, and 324; Ref. 63). Back River is designated by Maryland Water Quality 

Standards for surface water (Code of Maryland Regulations [COMAR] 26.08.02.07) for the tidal 

waters as Use I – water-contact recreation, fishing, and protection of aquatic life and wildlife 

(Ref. 9, p. 274). Back River is also designated as Use II area – support of estuarine and marine 

aquatic life and shellfish harvesting – subcategories 1, 2, and 3, according to Maryland Water 

Quality Standards. As a subcategory 1 Migratory Fish Spawning and Nursery Migratory Area, 

Back River is a habitat for fish including striped bass, perch, shad, herring, and Shortnose 

Sturgeon during the late winter/spring spawning and nursery season. Back River consists of tidal 

freshwater and provides low-salinity habitats. This habitat zone is primarily found in the upper 

reaches of many Chesapeake Bay tidal rivers and creeks and the upper mainstem Chesapeake Bay

(Ref. 9, p. 65). 

As a subcategory 2 Shallow Water –Submerged Aquatic Vegetation Underwater Area, bay 

grasses and many fish and crab species depend on areas of Back River as a shallow-water habitat. 

Shallow waters consist of grass beds near the shoreline. As a subcategory 3 Open-Water Fish and 

Shellfish Water Area, Back River provides a surface water habitat for diverse populations of 

sportfish including striped bass, bluefish, mackerel, and seatrout; bait fish such as menhaden and 

silversides as well as the Shortnose Sturgeon. These species reside within tidal creeks, rivers, 

embayments, and the mainstem Chesapeake Bay year-round (Ref. 9, p. 65, 66, 324; Ref. 38; Ref. 

39). 

Analytical data from sediment samples collected from Wetland #2 document that an observed 

release of hazardous substances has occurred from the Source 1 to this wetland, which is part of 

the Back River. 

The Chesapeake Bay is located within the 15-mile TDL and is a major recreational and 

commercial fishery (Ref. 13; Ref. 44; Ref. 45; Ref. 46). 

4.1.3.3.1 Food Chain Individual 

As noted in Section 4.1.2.1.1 of this HRS documentation record, an observed release of 

hazardous substances having a bioaccumulation factor value of 500 or greater is documented in

wetlands of the Back River and a human food chain fishery is present within the TDL (Ref. 9, pp. 

32, 65, 66, 73, 77, 258, 274, 302, 304, 324; Ref. 63). The food chain individual factor is assigned 

a value of 20 (Ref. 1, Section 4.1.3.3.1). 

Food Chain Individual Factor Value: 20 (Ref. 1, Section 4.1.3.3.1) 

4.1.3.3.2 Population 

No fisheries subject to Level I or Level II concentrations have been documented because fishing 

has not been documented within the zone of contamination. Documentation regarding the 

amount of fish and crabs harvested from surface water bodies within the TDL has not been 
SW/Human Food Chain Threat – Targets 

60

identified. A Level I and II human food chain population value of 0 is assigned (Ref. 1, Section 

4.1.3.3.2).

Level I and II Human Food Chain Population Value: 0 

4.1.3.3.2.3 Potential Human Food Chain Contamination

Back River and Chesapeake Bay are both designated fisheries located within the 15-mile 

downstream TDL (Ref. 9, pp. 32, 65, 66, 73, 77, 258, 274, 302, 304, 324; Ref. 63). Production 

values for the Back River and the portion of the Chesapeake Bay within the 15-mile surface water 

TDL are not known. A value of greater than 0 is used to obtain an assigned human food chain 

population value of 0.03 from Table 4-18 of Reference 1. No flow rate gauging stations are 

located on the Back River as the river is considered a tidal water body (Ref. 9, pp. 18, 32; Ref. 

60). Therefore, to be conservative, the lowest dilution weighed value for a river in Table 4-13 of 

Reference 1 is assigned to Back River; the value is 0.00001. To obtain the potential human food 

chain value, the assigned human food chain value of 0.03 is multiplied by the dilution weight for 

a very large river (0.00001) (Ref. 1, Table 4-13) and divided by 10 giving a value of 0.00000003 

(Ref. 1, Section 4.1.3.3.2.3). The same calculations apply to the Chesapeake Bay. Using the 

dilution weight for coastal tidal water (0.0001) and a human food chain value of 0.03 and 

dividing by 10, a value of 0.0000003 is obtained for the Chesapeake Bay (Ref. 43, p. 1). The sum 

of the two values is 0.00000033 (Ref. 4.1.3.3.2.3). 

Potential Human Food Chain Contamination Factor Value = 0.00000033
SWOF/Environmental Threat – Toxicity/Persistence/Bioaccumulation

61

4.1.4 ENVIRONMENTAL THREAT

4.1.4.2 WASTE CHARACTERISTICS

4.1.4.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation

Table 24 presents the ecosystem toxicity/persistence factor values for hazardous substances detected in 

Source 1. 

TABLE 24

ECOSYSTEM TOXICITY AND PERSISTENCE FACTOR VALUE

Hazardous 

Substances

Source 

No.

Ecosystem 

Toxicity 

Factor 

Value*

Persistence 

Factor 

Value 

Ecosystem 

Toxicity/Persistence 

Factor Value (Ref. 1, 

Table 4-20) 

Reference 

2 

Polychlorinated 

biphenyl 

(Aroclors 1242, 

1248, 1254, 

1260)

1 10,000 1 10,000 Page 15

Lead 1 1,000 1 1,000 Page 13

Notes:

* Back River is brackish; therefore, the higher of the freshwater or saltwater ecosystem toxicity values is 

assigned (Ref. 1, Section 4.1.3.2.1.3; Ref. 9, p. 32; Ref. 14, pp. 151, 152; Ref. 5, pp. 74 to 83). 
SWOF/Environmental Threat – Toxicity/Persistence/Bioaccumulation

62

TABLE 25

ECOSYSTEM TOXICITY, PERSISTENCE, AND BIOACCUMULATION FACTOR VALUE

Hazardous 

Substances

Ecosystem 

Toxicity/Persistence 

Factor Value 

Ecosystem 

Bioaccumulation 

Factor Value* 

(Section 4.1.3.2.1.3)

Ecosystem Toxicity/ 

Persistence/ 

Bioaccumulation 

Factor Value (Ref. 

1, Table 4-21 

Reference 

2 

Polychlorinated 

biphenyl 

(Aroclors 1242, 

1248, 1254, 1260)

10,000 50,000 5×108 Page 15

Lead 1,000 50,000 5×107 Page 13

Notes:

* Back River is brackish; therefore, the higher of the freshwater or saltwater ecosystem bioaccumulation 

factor values is assigned (Ref. 1, Section 4.1.3.2.1.3; Ref. 9, p. 32; Ref. 14, pp. 151, 152; Ref. 5, pp. 74 to 

83).

The highest toxicity, persistence, and bioaccumulation factor value is for PCBs: 5×108

. 

Ecosystem Toxicity/Persistence/Bioaccumulation Factor Value: 5×108

(Ref. 1, Table 4-21) 
SWOF/Environmental Threat – Hazardous Waste Quantity

63

4.1.4.2.2 Hazardous Waste Quantity

Source Number Source Hazardous Waste 

Quantity Value (Section 

2.4.2.1.5) 

Is source hazardous 

constituent quantity data 

complete? (yes/no)

1 31.77 No 

HWQ Factor Value: 100* 

(Ref. 1, Section 2.4.2.2, p. 51591) 

* Because the hazardous constituent quantity is not adequately determined and because targets in 

this pathway are subject to actual contamination, a HWQ factor value of 100 is assigned 

(Reference 1, Section 2.4.2.2; Section 4.1.4.3 of this documentation record).
SWOF/Environmental Threat –Waste Characteristics

64

4.1.4.2.3 Waste Characteristics Factor Category Value

The waste characteristics factor category value is determined by taking the product of the highest 

ecosystem toxicity/persistence factor value (10,000) and the HWQ value (100), and multiplying the 

product by the highest ecosystem bioaccumulation factor value (50,000) (Ref. 1, Section 4.1.4.2.3). 

10,000 × 100 = 1 × 10

6 

Ecosystem toxicity/persistence factor value × hazardous waste quantity factor value: 1 × 10

6

1 × 106

 × 50,000 = 5 × 1010 

(Ecosystem toxicity/persistence × hazardous waste quantity) × ecosystem bioaccumulation potential 

factor value: 5 × 1010 (subject to maximum value of 1×1010) 

Waste Characteristics Factor Category Value: 320 (Ref. 1, Table 2-7)
SWOF/Environmental Threat –Targets

65

4.1.4.3 Environmental Threat-Targets

Level I Concentrations

No Level I concentrations of sensitive environments have been documented within the 15-mile 

downstream TDL. 

Most Distant Level II Sample

Actual environmental contamination has been documented in the wetlands of Back River, as discussed in 

Section 4.1.1.1 of this HRS documentation record. As presented in Table 17 of this HRS documentation 

record, sediment samples collected from Wetland #2 contained lead and PCBs at concentrations 

documenting an observed release to the wetland (surface water). The wetland area subject to actual 

contamination is shown in Reference 34. The area of these wetlands was delineated in 1992. The 1992 

wetland delineation used the National Wetlands Inventory mapping for preliminary identification of 

wetland areas. The wetlands were numbered Wetland Units 1 through 6 (Ref. 5, p. 74, 78). The wetlands 

within the area of actual contamination include Wetland Unit 3, a palustrine, emergent persistent saturated 

soil wetland (PEM1B) located southeast of Wetland Unit 2 (Ref. 5, p. 82); Wetland Unit 4, an intertidal 

estuarine emergent persistent irregularly flooded wetland (E2EM1P) located southeast of Wetland Unit 3 

and extending to the mudflats on the Back River (Ref. 5, p. 82); Wetland Unit 5, an intertidal estuarine 

emergent persistent regularly flooded wetland (E2EM1N); and Wetland Unit 6, an intertidal estuarine 

mud flat with regular flooding (E2FL3N) (Ref. 5, p. 83). The description of the wetlands identifies 

hydrophytic vegetation within Wetland Units 3, 4, and 5 and not within Unit 6 and hydric soils and the 

presence of wetland hydrology in each unit (Ref. 5, pp. 83, 84). However, a wetland delineation 

conducted in April 2002 identified phragmites and narrow-leaved cattail, both hydrophytes, as dominant 

species within Unit 6 (Ref. 14, pp. 151, 152; Ref. 5, pp. 83, 84). 

The 2002 wetland delineation identified two wetlands, Wetland #1 and #2. Wetland #2 includes the 1992 

Wetland Units 3 through 6. The 2002 wetland delineation identified hydric soils, wetland hydrology, and 

predominance of hydrophytic vegetation in Wetland #2, including the 1992 Wetland Unit 6 (Ref. 14, pp. 

151, 152). The locations of the wetlands are shown in Reference 5, Figure 4-1, page 78 and Reference 

14, Figure 5, page 99 and page 167. 

The 2012 wetland delineation was performed using the USACE 2010 Interim Regional Supplement to the 

Corps of Engineers Wetland Delineation Manual; Atlantic and Gulf Coastal Plain Region (Version 2.0)

and the delineated wetlands were determined to meet HRS requirements (Ref. 62, pp. 6, 11). The results 

of this 2012 delineation were generally consistent with and confirmed the results of the 2002 delineation, 

with slight adjustments to the boundaries of the wetlands (Ref. 14, p. 163; Ref. 34; Ref. 62, pp. 1, 8 to 10, 

17). The 2012 wetland delineation also inspected a fringe of the Wetland #1 wetlands adjacent to the 

pond to the northwest, identifying that the pond is actually hydrologically connected to the southwest 

finger by a jurisdictional depression/channel (62, p. 9, 24). 
SWOF/Environmental Threat –Targets

66

The sediment sampling locations documenting an observed release to surface water are listed below. 

TABLE 26 

LEVEL II RELEASE SAMPLES

Sample 

Identification

Sample 

Medium Sampling Location Reference

DG-SD03-0.5 Sediment Wetland that borders 

Source 1 to the west 31, pp. 69, 80 

DG-SD04-0.5 Sediment Wetland that borders 

Source 1 to the east 31, pp. 69, 80 

DG-SD05-0.5 Sediment Wetland that borders 

Source 1 to the east 31, pp. 69, 80 

DG-SD06-0.5 Sediment Wetland that borders 

Source 1 to the southeast 31, pp. 69, 80 

DG-SD07-0.5 Sediment Wetland that borders 

Source 1 to the southeast 31, pp. 69, 80 

According to the Baltimore County Department of Permits and Development Management, Sauer Dump 

is zoned as a Resource Conservation Critical Area (Ref. 26, pp. 1, 2; Ref. 41) under the Critical Area Act. 

In 1984, the Maryland General Assembly resolved to reverse the deterioration of the Chesapeake Bay’s 

environment by enacting the Chesapeake Bay Protection Act. In 2002, the Act was amended to include 

the Atlantic Coastal Bays. The Act required the 16 counties, Baltimore City, and 44 municipalities 

surrounding the Chesapeake and Atlantic Coastal Bays to implement a land use and resource management 

program designed to mitigate the damaging impact of water pollution and loss of natural habitat, while 

also accommodating the jurisdiction’s future growth. The Critical Area Act recognizes that the land 

immediately surrounding the Bays and their tributaries has the greatest potential to affect water quality 

and wildlife habitat and thus designated all lands within 1,000 feet of tidal waters or adjacent tidal 

wetlands as the “Critical Area” (Ref. 41, p.1; Ref. 54, pp. 17, 18). 

The Critical Area Act falls within the Maryland Coastal Nonpoint Pollution Control Program. National 

Oceanic and Atmospheric Administration (NOAA) and EPA approved the Coastal Nonpoint Pollution 

Control Program submitted by the State of Maryland pursuant to Section 6217(a) of the Coastal Zone Act 

Reauthorization Amendments of 1990 (Ref. 54, p. 1; Ref. 56). The Maryland Coastal Nonpoint Pollution 

Control Program is part of Maryland Water Pollution Control Laws within the Maryland Coastal 

Management Program, which has been approved by NOAA under the Coastal Zone Management Act 

(Ref. 55, pp. 3, 6; Ref. 56, p. 1). Maryland’s Critical Area’s program is the principal mechanism used by 

Maryland’s Coastal Program to designate areas for preservation and restoration. Areas of special 

significance within the coastal zone are identified and designated State Critical Areas. Three types of 

coastal areas are designated. Sauer Dumps falls within the resource protection area (Ref. 55, p. 22; Ref. 

26, pp. 1, 2). Resource protection areas consist of vegetated wetlands, upland natural areas, prime 

recreation areas, productive agricultural land, areas of historical and archeological importance, and 

aquatic resource areas (Ref. 55, p. 22). 

Source 1 lies within the area designated as the Chesapeake Bay Critical Area under Maryland's 

Chesapeake Bay Critical Area Protection Act. The purpose of Maryland's Chesapeake Bay Critical Area 

Protection Act is to protect the unique Chesapeake Bay ecosystem and its fisheries and other resources. 

Specifically, the portion of Source 1 located adjacent to Lynhurst Road is within a limited development 
SWOF/Environmental Threat –Targets

Sensitive Sensitive Environment Sensitive Reference Environment Value (Ref. 1, Tables 4- Environment Type 23 and 4-24) 

26, pp. 1, 2; 32; 54, p. Area identified 

Critical Area 1; 55, p. 22; 56 (see under Coastal Zone 100 

paragraphs above) Management Act

Wetland #2 34 Wetland 25 

67

area and the remainder of Source 1 is within a resource conservation area (the most protective and 

restrictive classification) (Ref. 26; Ref. 32). The Chesapeake Bay Critical Area Protection Program 

established, preserves, and maintains a 100-foot, naturally vegetated, forested buffer from the mean high 

water line of tidal waters or from the edge of tidal wetlands and tributary streams. This includes non-tidal 

wetlands (Ref. 32). The high water line on the Sauer Dump property is shown on Figure 4, page 99, of 

Reference 14. 

The Chesapeake Bay and its tributaries provide habitat, including spawning habitat, feeding area, and 

migratory pathways, for several species of anadromous fish, including the depleted striped bass, 

American hickory, gizzard shad, river herring (various species), and yellow and white perch. Shallow 

areas of streams are particularly important as spawning habitat. Critical spawning or feeding areas or 

migratory pathways are not known to exist within the study area of the Back River (Ref. 9, pp. 66, 114,). 

 

Sensitive environments associated with the Back River include areas known to be used as a habitat for 

federally endangered species. The Back River, a tributary to the Chesapeake Bay, provides habitat to the 

Shortnose Sturgeon (Acipenser brevirostrum). The Shortnose Sturgeon is a federally endangered species 

(Ref. 36, p. 2; Ref. 38; Ref. 39). Reference 38 shows the distribution of the Shortnose Sturgeon. 

Reference 39 provides a description of the habitat of the Shortnose Sturgeon. 

Wetlands surround Source 1 (Ref. 15; Ref. 33; Ref. 34). When the PPE to surface water is into a wetland, 

the wetland perimeter is used to determine the length of the wetland subject to Level II concentrations 

(Ref. 1, Section 4.1.4.3.1.2). While the 2012 wetland delineation has identified that Wetland #1 is 

hydrologically connected to Wetland #2, Wetland #1 is not evaluated for HRS scoring purposes as part of 

this HRS documentation record because it would not affect the site score. There are two PPEs from 

Source 1 into Wetland #2, the Level II wetland. PPE-1 is into the Southwest Finger of Wetland #2 at the 

north end, as shown in Reference 34. PPE-2 is into the Southeast Finger of Wetland #2 at the north end, 

as shown is Reference 34. To determine the perimeter of the Level II wetland in the Southwest and 

Southeast Fingers of Wetland #2, an arc is drawn from each PPE to the furthest downstream sediment 

sampling location documenting an observed release to the wetland. The arc drawn in the Southwest 

Finger is labeled Arc 1 on Reference 34. The arc is drawn from PPE-1 to sediment sampling location 

DG-SD03-0.5. The arc drawn in the southeast finger is labeled Arc 2 on Reference 34. The Arc 2 is 

drawn from PPE-2 to sediment sampling location DG-SD07-0.5. The perimeter of the Level II 

Southwest Finger is estimated to be 1,230 feet and the perimeter of the Level II Southeast Finger is 

estimated to be 1,041 feet. The sum of the two Level II wetlands is 2,271 feet (Ref. 34). A wetland 

assigned value of 25 is obtained from Reference 1, Table 4-24. Table 27 summarizes Level II sensitive 

environments in Back River Wetland #2. 

TABLE 27

LEVEL II SENSITIVE ENVIRONMENTS – BACK RIVER WETLAND #2
SWOF/Environmental Threat –Targets

68

The Level II concentration values are the sum of the sensitive environment values subject to Level II 

concentrations, or 125 (Ref. 1, Section 4.1.4.3.1.2). 

Level II Concentrations Factor Value: 125