THIS IS A REQUEST FOR ASSISTANCE FROM DOJ IN NEGOTIATING AN RD/RA CONSENT DECREE.
THE KANE AND LOMBARD SITE IS THE LOCATION OF A FORMER LAND FILLING BUSINESS THAT COMMENCED OPERATION IN THE EARLY 1960'S NEAR THE INTERSECTION OF KANE STREET AND NORTH POINT BOULEVARD IN BALTIMORE, MARYLAND. AT SOME POINT IN THE MID- TO LATE 1960'S, THE LANDFILL EXPANDED TO THE SOUTH BELOW WHAT LATER BECAME LOMBARD STREET. SUBSEQUENTLY, THE PARCELS COMPRISING THE LANDFILL NORTH OF LOMBARD STREET WERE SOLD AND DEVELOPED.
THE PORTION OF THE LANDFILL SOUTH OF LOMBARD STREET IS OPERABLE UNIT NO. 1 ( OU1 ) OF THE SITE. EPA ISSUED A RECORD OF DECISION SELECTING REMEDIAL ACTION FOR IMPLEMENTATION AT OU1 IN SEPTEMBER 1987. IN AGUUST 1989, EPA REFERRED CLAIMS AGAINST SEVERAL POTENTIALLY RESPONSIBLE PARTIES FOR COST RECOVERY AND IMPLEMENTATION FOR THE OU1 REMEDIAL ACTION. IN OCTOBER 1987, THE UNITED STATES FILES AN ACTION IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND AGAINST THESE PARTIES. THE STATE OF MARYLAND FILED ITS OWN COMPLAINT AGAINST THE SAME PARTIES. THE ANMED DEFENDANTS ADDED 17 THIRD-PARTY DEFENDANTS. EXTENSIVE DISCOVERY WAS TAKEN IN THE MATTER. A GLOBAL SETTLEMENT WAS REACHED WITH FOUR ORIGINAL DEFENDANTS AND SIXTEEN THIRD-PARTY DEFENDANTS IN 1995. THROUGH THIS GLOBAL SETTLEMENT EPA SECURED A PRIVATE-LEAD REMEDIAL ACTION AND SIGNIFICAN COST RECOVERY. IN ADDITION TO THE GLOBAL SETTLEMENT, THE UNITED STATES SECURED SETTLEMENTS WITH THE SITE OWNERS AND W