FIRST FIVE-YEAR REVIEW REPORT FOR THE MANY DIVERSIFIED INTERESTS, INC. SUPERFUND SITE HOUSTON, HARRIS COUNTRY, TEXAS September 2012 PREPARED BY: United States Environmental Protection Agency Region 6 Dallas, Texas *669541* 669541 CONTENTS Section Page ATTACHMENTS ......................................................................................................................... ii LIST OF TABLES ..................................................................................................................................... iii LIST OF ACRONYMS ............................................................................................................................. iv LIST OF ACRONYMS (CONTINUED) .................................................................................................. v EXECUTIVE SUMMARY ........................................................................................................................ 1 1.0 INTRODUCTION.......................................................................................................................... 1 2.0 SITE CHRONOLOGY.................................................................................................................. 2 3.0 BACKGROUND ............................................................................................................................ 4 3.1 PHYSICAL CHARACTERISTICS.................................................................................... 5 3.2 LAND AND RESOURCE USE ......................................................................................... 5 3.3 HISTORY OF CONTAMINATION .................................................................................. 6 3.4 INITIAL RESPONSE ......................................................................................................... 7 3.5 BASIS FOR TAKING ACTION ........................................................................................ 9 4.0 REMEDIAL ACTIONS .............................................................................................................. 11 4.1 REMEDY SELECTION ................................................................................................... 11 4.2 REMEDY IMPLEMENTATION ..................................................................................... 12 4.3 OPERATION AND MAINTENANCE ............................................................................ 17 4.4 OPERATION AND MAINTENANCE COST ................................................................. 18 5.0 PROGRESS SINCE THE PREVIOUS FIVE-YEAR REVIEW ............................................. 18 6.0 FIRST FIVE-YEAR REVIEW PROCESS................................................................................ 18 6.1 ADMINISTRATIVE COMPONENTS ............................................................................ 18 6.2 COMMUNITY INVOLVEMENT ................................................................................... 19 6.3 DOCUMENT REVIEW ................................................................................................... 19 6.4 DATA REVIEW ............................................................................................................... 19 6.5 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENT REVIEW .. 22 6.5.1 Chemical-Specific Applicable or Relevant and Appropriate Requirements........ 23 6.5.2 Location-Specific Applicable or Relevant and Appropriate Requirements......... 23 6.5.3 Action-Specific Applicable or Relevant and Appropriate Requirements ............ 23 6.6 SITE INSPECTION .......................................................................................................... 24 6.7 SITE INTERVIEWS......................................................................................................... 25 7.0 TECHNICAL ASSESSMENT .................................................................................................... 26 7.1 QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION DOCUMENTS? ............................................................................................ 26 7.2 QUESTION B: ARE THE ASSUMPTIONS USED AT THE TIME OF REMEDY SELECTION STILL VALID? .......................................................................................... 27 7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY?.... 29 7.4 TECHNICAL ASSESSMENT SUMMARY .................................................................... 29 8.0 ISSUES .......................................................................................................................................... 29 9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS ...................................................... 30 10.0 PROTECTIVENESS STATEMENT ......................................................................................... 32 11.0 NEXT REVIEW ........................................................................................................................... 32 i ATTACHMENTS 1 2 3 4 5 6 7 8 9 10 Site Location Map and Site Layout Map Five Year Review Public Notice Documents Reviewed Data Tables and Graphs Plume Maps ARARs Site Inspection Checklist Site Inspection Photographs Interview Records De-Listed OU 1 Soils and Groundwater ii LIST OF TABLES Table Page 1 CHRONOLOGY OF SITE EVENTS ..................................................................................3 2 MONITORING WELL CLASSIFICATION AND USE .................................................16 3 LIST OF INTERVIEWEES ...............................................................................................25 4 RECOMMENDATIONS AND FOLLOW-UP ACTIONS ...............................................31 iii LIST OF ACRONYMS ACM AMP ARARs B(a)P bgs Can-Am CERCLA CFR COC yd3 EA ENTACT EPA FR FS ft HHRA HI in. ICs IEUBK LNAPL MCL MDI µg/dL µg/L mg/kg mg/kg-day mg/L MNA NCP NPL O&M OU PCL PCOR PMZ POC RA RAC RAO RD Asbestos-containing materials Attenuation Monitoring Points Applicable or Relevant and Appropriate Requirements Benzo(a)pyrene Below ground surface Can-Am Resource Group Comprehensive Environmental Response, Compensation, and Liability Act Code of Federal Regulations Chemical of Concern Cubic yard EA Engineering, Science, and Technology, Inc. ENTACT Environmental Services U.S. Environmental Protection Agency Federal Register Feasibility study Feet Human Health Risk Assessment Hazard indices Inches Institutional Controls Integrated Exposure Uptake Biokinetic Model Light non-aqueous phase liquid Maximum contaminant level Many Diversified Interests, Inc. Microgram(s) per deciliter Microgram(s) per liter Milligram(s) per kilograms Milligram(s) per kilograms per day Milligram(s) per liter Monitored natural attenuation National Oil and Hazardous Substances Pollution Contingency Plan National Priorities List Operation and maintenance Operating Unit Protective Concentration Level Preliminary Close Out Report Plume Management Zone Point of Compliance Remedial action Remedial Action Contract Remedial action objective Remedial design iv LIST OF ACRONYMS (CONTINUED) RI RfD ROD Site SJF SKA SWBZ TBC TCEQ TESCO TPH TRRP UST Remedial investigation Reference Dose Record of Decision Many Diversified Interests, Inc. Superfund Site San Jacinto Foundry SKA Consulting, L.P. Shallow Water Bearing Zone To Be Considered Texas Commission on Environmental Quality Texas Electric Steel Casting Company Total Petroleum Hydrocarbons Texas Risk Reduction Program Underground Storage Tank v EXECUTIVE SUMMARY The U.S. Environmental Protection Agency (EPA) Region 6 has conducted the first five-year review of the remedial action (RA) implemented at the Many Diversified Interests, Inc. (MDI) Superfund Site (Site) in Houston, Harris County, Texas. The purpose of a five-year review is to determine whether the remedy at a site remains protective of human health and the environment and to document the methods, findings, and conclusions of the five-year review process in a fiveyear review report. Five-year review reports identify issues found during each review, if any, and make recommendations to address the issues. This First Five-Year Review Report documents the results of the review for the MDI Superfund Site, which was conducted in accordance with EPA guidance (EPA 2001) on five-year reviews. The MDI Site occupies a 35-acre tract of land located at 3617 Baer Street in Houston, Harris County, Texas. The Site is located approximately 2 miles east of downtown Houston and 1 block south of Interstate Highway 10 in an area of mixed industrial and residential land use. This part of Houston is known as the “Fifth Ward.” In 1926, the Texas Electric Steel Casting Company (TESCO) began operations on-site as a metal casting foundry. The foundry expanded operations north of Baer Street and south of Gillespie Street during World War II. A second foundry facility was built on the eastern portion of the Site during the latter half of 1970. During the mid-1980s, the southern portion of the Site was leased to Can-Am Resource Group (CanAm). Can-Am conducted a spent catalyst recycling operation using an experimental process. In 1990, MDI bought the TESCO note from Texas Commerce Bank. TESCO ceased operations in February 1991, and MDI filed for Chapter 7 Bankruptcy in the U.S. Bankruptcy Court for the Southern District of Texas, Houston District on May 20, 1992. The EPA believed that the air emissions from the former foundry, which contained particles of lead, may have caused on-site (Operable Unit [OU] 1) and offsite (OUs 2 and 3) soils to become contaminated through the air deposition of these particles. Foundry practices may have also contributed to on-site lead contamination of the soils. The MDI Site is comprised of the three OUs. OU 1 included the on-site soils and groundwater. OU 2 was comprised of offsite residential yards and high-access areas, which included schools, ES-1 child daycare centers, playgrounds, and churches. OU 3 included residential crawlspaces and those residential areas not addressed under OU 2. The Record of Decision (ROD) for OU 1 was signed on July 30, 2004. The major components of the remedy selected in this ROD included: • Excavation and Treatment (solidification/stabilization, if necessary) of approximately 13,600 cubic yards (yd3) of soils with lead concentrations equal to or greater than 500 milligrams per kilogram (mg/kg) to a maximum depth of 1.5 feet (ft) below ground surface (bgs), and approximately 3,000 yd3 of soils stockpiled at the Site from a previous removal action will also be treated, if necessary. • Transportation and Disposal (at a permitted offsite waste disposal facility) of approximately 31,621 yd3 of debris (nonhazardous debris, foundry sand, and slag), the Asbestos-Containing Material in the on-site building and scattered throughout the Site, and an Underground Storage Tank in the vicinity of Monitoring Well (MW) 20. • Excavation and Disposal (at a permitted offsite waste disposal facility) of approximately 2,100 yd3 of soils contaminated with benzo(a)pyrene, or other organics, at the MW-3 location; light non-aqueous phase liquids (LNAPL) at the MW-11 location; and Total Petroleum Hydrocarbons at the MW-20 location. Soil cleanup levels for these isolated source areas will be determined during the remedial design (RD) and RA for the Selected Remedy. • Implementation of Monitored Natural Attenuation for the groundwater, which includes source removal and long-term monitoring for the groundwater to ensure that constituents above cleanup goals are naturally attenuating. • Implementation of Institutional Controls for both the soils and groundwater to prevent exposure to soil contamination above acceptable cleanup levels and to prevent exposure to contaminated groundwater in the shallow water-bearing zone. A developer/contractor or owner for the Site must agree to provide deed restrictions to the affected property, as appropriate or as allowed by law, that address the soil and groundwater. On May 26, 2006, the prospective purchaser for OU 1, Clinton Gregg Investments, Ltd., signed an “Agreed Order on Consent and Covenant Not to Sue” (Agreed Order). In this Agreed Order, Clinton Gregg Investments, Ltd. agreed to implement the remedy identified in the ROD. The RD was developed by ENTACT Environmental Services on behalf of Clinton Gregg Investments, Ltd. The RA began on February 12, 2007, and was completed and approved by the EPA on December 12, 2008. The ROD for OU 2 of the MDI Site was signed on September 23, 2005. This ROD stated that all residential property yards and high-access areas (for which EPA received site access) with lead ES-2 concentrations above 500 mg/kg were addressed by removal actions. The EPA believed that the removal actions had eliminated the existing and potential risk to human health and the environment so that no further action was necessary. The ROD for OU 3 of the MDI Site was signed on August 31, 2009. This ROD concluded that the selected remedy for OU 3 residential crawlspaces was “no action warranted” since the Baseline Human Health Risk Assessment (HHRA) concluded that current or potential future Site conditions pose no unacceptable risks to human health or the environment (Tetra Tech 2003b). This first five-year review includes the following components: (1) document review, (2) data review, (3) Applicable or Relevant and Appropriate Requirements (ARARs) review, (4) site inspection, and (5) interviews. Documents reviewed for this five-year review included the following: (1) Remedial Investigation and Feasibility Study Reports; (2) RODs; (3) Final RA Report; (4) Preliminary Close Out Report; and (5) Groundwater Monitoring Reports. This first five-year review focuses on the data obtained during routine groundwater monitoring events and operation and maintenance activities conducted during the 2007–2012 timeframe. Available data and Site inspection suggest the selected remedy is performing as intended, with the following issues identified: 1. Monitoring wells — Damage to monitoring wells MW-17 and MW-19 was observed during the site inspection. 2. Oral reference dose for manganese in groundwater has changed — The methodology used to derive the manganese oral reference dose (RfD) in the HHRA is not consistent with EPA’s current recommended methodology. The manganese oral RfD used in the HHRA was 0.047 milligrams per kilogram per day (mg/kg-day). The oral RfD identified in the EPA Regional Screening Levels user’s manual is 0.024 mg/kg-day (EPA 2011). 3. LNAPL in MW-20R — Measurable thicknesses (0.01 to 0.02 feet) of LNAPL were observed in MW-20R (Plume Management Zone 3) on January 27 and 30, 2012. Based on the issues identified, follow-up recommendations and actions for the MDI Site are listed on Table 4 (Recommendations and Follow-Up Actions) and include: 1. Monitoring wells — Damaged wells, MW-17 and MW-19, should be plugged and abandoned. ES-3 2. Oral reference dose for manganese in groundwater has changed — The noncarcinogenic risk for manganese in groundwater should be re-evaluated based on the current oral RfD to ensure that the remedy is protective of human health. 3. LNAPL in MW-20R — MW-20R should continue to be monitored for LNAPL. ES-4 Determinations Based on the information available during the first five-year review, the selected remedy for OU 1 (On-site Soils and Groundwater) of the Many Diversified Interests, Inc. Superfund Site appears to be perfonning as intended. The Site is protective of human health and the environment. Gt-~ ~~- {- /f? By: Pamela Phil~ U.S. EPA, Region 6 Acting Director, Superfund Division ES-5 Five-Year Review Summary Form SITE IDENTIFICATION Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID: TXD008083404 Region: 6 State: TX City/County: Houston/Harris County SITE STATUS NPL Status: Other. Site status is Final, with partial deletion of 8-acre, western portion of Operating Unit 1. Multiple OUs? Yes Has the site achieved construction completion? Yes REVIEW STATUS Lead agency: EPA Author name (Federal or State Project Manager): Rafael Casanova (Remedial Project Manager) Author affiliation: U.S. EPA Region 6 Review period: September - December 2011 Date of site inspection: November 3, 2011 Type of review: Statutory Review number: 1 Triggering action date: May 3, 2007 Due date (five years after triggering action date): May 3, 2012 SF-1 Five-Year Review Summary Form (continued) Issues/Recommendations OU(s) without Issues/Recommendations Identified in the Five-Year Review: OU 2 and OU 3 Issues and Recommendations Identified in the Five-Year Review: OU(s): OU 1 Issue Category: Monitoring Issue: Damage to monitoring wells MW-17 and MW-19 was observed during the site inspection. Recommendation: Damaged wells, MW-17 and MW-19, should be plugged and abandoned. Affect Current Protectiveness Affect Future Protectiveness Implementing Party Oversight Party Milestone Date No No Clinton Gregg Investments, Ltd. EPA Within 1 year of Final First FiveYear Review Report OU(s): OU 1 Issue Category: Remedy Performance Issue: The methodology used to derive the manganese oral reference dose (RfD) in the HHRA is not consistent with EPA’s current recommended methodology. The manganese oral RfD used in the HHRA was 0.047 mg/kg-day. The oral RfD identified in the EPA Regional Screening Levels user’s manual is 0.024 mg/kg-day (EPA 2011). Recommendation: The noncarcinogenic risk for manganese in ground water should be re-evaluated based on the current oral RfD to ensure that the remedy is protective of human health. Affect Current Protectiveness Affect Future Protectiveness Implementing Party Oversight Party Milestone Date No Yes Clinton Gregg Investments, Ltd. EPA Within 1 year of Final First FiveYear Review Report SF-2 OU(s): OU 1 Issue Category: Monitoring Issue: Measurable thicknesses (0.01 to 0.02 feet) of light non-aqueous phase liquids (LNAPL) were observed in MW-20R (Plume Management Zone 3) on January 27, 2012 and January 30, 2012. Recommendation: MW-20R should continue to be monitored for LNAPL. Affect Current Protectiveness Affect Future Protectiveness Implementing Party Oversight Party Milestone Date No No Clinton Gregg Investments, Ltd. EPA Within 1 year of Final First FiveYear Review Report Protectiveness Statement(s) Operable Unit: OU 1 Protectiveness Determination: Protective Addendum Due Date (if applicable): Protectiveness Statement: Based on the information available during the first five-year review, the selected remedy for OU 1 (On-Site Soils and Ground Water) of the Many Diversified Interests, Inc. Superfund Site appears to be performing as intended. The Site is protective of human health and the environment. Sitewide Protectiveness Statement (if applicable) Addendum Due Date (if applicable): Protectiveness Determination: Protective Protectiveness Statement: Based on the information available during the first five-year review, the selected remedy for OU 1 (On-Site Soils and Ground Water) of the Many Diversified Interests, Inc. Superfund Site appears to be performing as intended. The Site is protective of human health and the environment. SF-3 1.0 INTRODUCTION The U.S. Environmental Protection Agency (EPA) Region 6 has conducted the first five-year review of the remedial action (RA) implemented at the Many Diversified Interests, Inc. (MDI) Superfund Site (Site) in Houston, Harris County, Texas. The purpose of a five-year review is to determine whether the remedy at a site remains protective of human health and the environment and to document the methods, findings, and conclusions of the five-year review process in a fiveyear review report. Five-year review reports identify issues found during each review, if any, and make recommendations to address the issues. This First Five-Year Review Report documents the results of the review for the MDI Site, conducted in accordance with EPA guidance (EPA 2001) on five-year reviews. The five-year review process is required by federal statute. The EPA must implement five-year reviews consistent with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). CERCLA Section 121(c), 42 U.S.C. § 9621(c), which states the following: “If the President selects a remedial action that results in any hazardous substances, pollutants, or contaminants remaining at the site, the President shall review such remedial action no less often than each five years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented.” NCP Section 300.430(f)(4)(ii) states the following: “If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency shall review such action no less often than every five years after the initiation of the selected remedial action.” Because hazardous substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and unrestricted exposure, a statutory five-year review is required. This is the first five-year review for the MDI Superfund Site. The period addressed by this five-year review extends from May 3, 2007, to December 2011. The triggering action for this review was the start of the RA, or actual physical on-site construction (asbestos abatement) for 1 Operable Unit (OU) 1, on May 3, 2007. The scheduled due date for the Final First Five-Year Review Report was May 3, 2012, five years from the start of on-site construction. The Second Five-Year Review shall be conducted no later than five years from the date of the Superfund Division Director’s signature of this First Five Year Review Report. This first five-year review was conducted from September through December 2011; its methods, findings, conclusions, and recommendations are documented in this report. The summary of issues and recommendations, and a summary of all required protectiveness determinations discussed in this report are presented in the Five-Year Review Summary Form, included before Section 1.0 of this report. This report documents the five-year review for the MDI Superfund Site by providing the following information: site chronology (Section 2.0), background information (Section 3.0), overview of the RAs (Section 4.0), progress since the previous five-year review (Section 5.0), discussion of the first five-year review process (Section 6.0), technical assessment of the Site (Section 7.0), institutional controls (Section 8.0), issues (Section 9.0), recommendations and follow-up activities (Section 10.0), protectiveness statement (Section 11.0), and discussion of the next review (Section 12.0). Attachment 1 provides the site location map and site layout map. Attachment 2 provides the affidavit and copy of the Five-Year Review Public Notice. Attachment 3 is a list of documents reviewed. Attachment 4 provides data tables. Attachment 5 contains plume maps. Attachment 6 contains Applicable or Relevant and Appropriate Requirements (ARARs) presented in the Record of Decision (ROD). Attachment 7 provides the Site Inspection Checklist. Attachment 8 provides the site inspection photographs. Attachment 9 provides the interview records. Attachment 10 provides the de-listed area of OU 1 soils and groundwater. 2.0 SITE CHRONOLOGY Table 1 presents a chronology of significant events for the MDI Site. Additional site summary information is available online at: http://www.epa.gov/earth1r6/6sf/pdffiles/0605008.pdf (EPA 2011). 2 TABLE 1 CHRONOLOGY OF SITE EVENTS Date 1926 1970 Mid-1980s 1988 1990 February 1991 March 1, 1991 May 20, 1992 June 1, 1992 March 1995 – January 1996 September 29, 1998 1998 and 1999 January 19, 1999 November 28, 2003 November 2003 and June 2005 Event TESCO began operations as a metal casting foundry. A second foundry facility was built on the eastern portion of the Site. The southern portion of the Site was leased to Can-Am. Can-Am conducted a spent catalyst recycling operation using an experimental process. Can-Am ceased operations and drums of spent catalyst from chemical plants that were abandoned on-site. MDI bought the TESCO note from the Texas Commerce Bank. TESCO ceased operations and MDI foreclosed the property. MDI reopened as the SJF and began operating. MDI filed for Chapter 7 Bankruptcy in the U.S. Bankruptcy Court for the Southern District of Texas, Houston District. SJF ceased operations. The on-site facilities were demolished as a salvage operation under the U.S. Bankruptcy Court for the Southern District. EPA proposed to add the MDI Site to the National Priority List of Superfund Sites. The potentially responsible parties for the Site performed an extensive drum removal action under EPA’s oversight. This action included cleanup of the abandoned Can-Am drums. In addition, TNRCC conducted a removal and restoration of 89 residential yards to the west of the MDI site. The Final National Priority Listing for the MDI Site was published. Tetra Tech performed a RI on OU 1and submitted RI Report to the EPA The EPA performed removal actions that addressed 59 residential areas to the east and north of the Site, including the Blanche Kelso Bruce Elementary School and the Fifth Ward Multi-Service Center. January 2004 Tetra Tech submitted FS Report for OU 1 to the EPA. 30 July 2004 The EPA issued the ROD for OU 1. July 2005 Tetra Tech submitted RI and FS reports for OU 2 to the EPA. 23 September 2005 The EPA issued the ROD for OU 2. February to April A third EPA removal action was performed at the Kelly Village Housing 2006 Authority Property. May 26, 2006 Clinton Gregg Investments, Ltd. signed “Agreed Order on Consent and Covenant Not to Sue.” Clinton Gregg Investments, Ltd. agreed to implement the remedy identified in the ROD for OU 1. June 1, 2006 EPA published a FR Notice that solicited public review and comment on the EPA’s agreement with the prospective purchaser. July 3, 2006 Public comment period ended. September 29, The “Agreed Order on Consent and Covenant Not to Sue” became final. 2006 3 Date February 2007 May 3, 2007 June 5, 2008 December 12, 2008 February 2009 April 2009 August 31, 2009 February 4, 2010 June 15, 2010 August 16, 2010 NOTES: Can-Am EA EPA FR FS MDI OU RA RI ROD SJF TESCO Tetra Tech TNRCC Event ENTACT Environmental Services began the RA on behalf on Clinton Gregg Investments, Ltd. Actual on-site physical construction (asbestos abatement) for OU 1 began. RA construction activities were completed. RA completion was approved by the EPA. EA performed RI on OU 3 and submitted report to EPA. The EPA performed a removal action for OU 3. The EPA issued the ROD for OU3 The contractor retained by the purchaser of the Site requested EPA to delete the soils of OU 1 and the 8-acre western portion of the groundwater in OU 1 from the National Priority List in order to facilitate redevelopment of the 35-acre Site. The FR Notices, announcing the proposed partial deletion of the Site, were published in the FR. The partial deletion became effective, since the EPA received no adverse comments from the public before the end of the public comment period. Can-Am Resource Group EA Engineering, Science, and Technology, Inc. U.S. Environmental Protection Agency Federal Register Feasibility Study Many Diversified Interests Operable Unit Remedial action Remedial investigation Record of Decision San Jacinto Foundry Texas Electric Steel Casting Company Tetra Tech EM, Inc. Texas Natural Resource Conservation Commission (now Texas Commission on Environmental Quality) 3.0 BACKGROUND This section discusses physical characteristics, land and resource use near the Site, history of Site contamination, initial response to the Site, and the basis for the response. 4 3.1 PHYSICAL CHARACTERISTICS The MDI Site, occupies a 35-acre tract of land located at 3617 Baer Street in Houston, Texas. The Site is located approximately 2 miles east of downtown Houston and 1 block south of Interstate Highway 10 in an area of mixed industrial and residential land use (Attachment 1, Figure 1). This part of Houston is known as the “Fifth Ward.” 3.2 LAND AND RESOURCE USE The MDI property is bounded by Hare Street to the north, National Vinegar Company and Press Street to the east, the former Texas & New Orleans railroad right-of-way to the south, and Bringhurst Street to the west. Residential areas are adjacent to the west and north sides of the Site. Industrial areas are adjacent to the south side of the Site. The Site includes the residential yards/crawlspaces and high-access areas surrounding the former foundry. High-access areas include residential yards or properties, schools, child day care centers, playgrounds, and churches that surround the fenced boundaries of the Site. The Site was divided into OUs to effectively manage the Site. The MDI Site is comprised of the following OUs: • OU 1 (On-site Soils and Groundwater) ― Fenced boundary of the former 36-acre foundry located at 3617 Baer Street in Houston, Texas. • OU 2 (Offsite Residential Yards and High-access Areas) ― Residential yards or properties and high-access areas that surround the east, west, and north fenced boundaries of the former foundry (OU 1), and located within the Modeled Air Deposition Area and East Blower Area (Study Area). High-access areas include schools, child daycare centers, playgrounds, and churches. • OU 3 (Residential Crawlspaces and those Residential Areas Not Addressed under OU 2) ― Residential crawlspaces, residential yards or properties, and high-access areas located within the Modeled Air Deposition Area and East Blower Area (Study Area) that were not addressed during previous RI activities and removal actions conducted for MDI. 5 3.3 HISTORY OF CONTAMINATION The Site was originally the Houston Brick Works brickyard. Blue clay found along the former Ingraham Gully, which crossed the center of the Site, was excavated and used for the manufacturing of bricks. Casting was done in a facility located east of Bringhurst Street, north of Gillespie Street, and south of Baer Street. At that time, the eastern portion of the facility contained several residences. In 1926, the Texas Electric Steel Casting Company (TESCO) began operations as a metal casting foundry. The TESCO foundry initially occupied the former Houston Brick Works facility. The foundry expanded operations north of Baer Street and south of Gillespie Street during World War II. A second foundry facility was built on the eastern portion of the site during the latter half of 1970. TESCO primarily manufactured specialty molded parts such as large wheels, tracks, and mining equipment. The process area consisted of two casting plants: Plant I produced large castings, while Plant II produced smaller castings. Both plants maintained separate sand systems, core ovens, mold makers, electric arc furnaces, pouring facilities, and cleaning, annealing, and heat-treating process areas. Various grades of steel, including high carbon, chrome molybdenum, high nickel, and stainless steel were cast at the TESCO facility. Scrap metal and iron were melted in the carbon arc furnaces, tested, corrected for the elements needed for the different grades of steel, and poured into molds. Molds and cores were constructed by mixing sand with flour binders. Some cores were made by mixing iron oxide with an oil-based material, and then hardened in core ovens. Cores and molds were treated with a water-based zircon flour and dye mixture to prevent the molten metal from eroding them. Castings were cleaned (by mechanical grinding, shot blasting, or sandblasting) and heat-treated. Heat-treating consisted of annealing followed by water or oil quenching. Final machining was 6 performed either on-site or at the customer’s shop, if needed. Some parts required x-ray inspection for certification. Larpen of Texas, Inc., another MDI/TESCO subsidiary, provided radiography services. During the mid-1980s, the southern portion of the Site was leased to Can-Am Resource Group (Can-Am). Can-Am conducted a spent catalyst recycling operation using an experimental process. Very little is known about operations at the Site during this time. Can-Am reportedly obtained between 2,000 and 4,000 drums of spent catalyst from chemical plants and refineries along the Houston Ship Channel. By 1988, Can-Am ceased operations and the drums of spent catalyst were abandoned on-site. In 1990, MDI bought the TESCO note from Texas Commerce Bank. TESCO ceased operations in February 1991, and MDI foreclosed on the property. MDI reopened as the San Jacinto Foundry (SJF) on March 1, 1991. SJF continued operations until about June 1, 1992. MDI filed for Chapter 7 Bankruptcy in the U.S. Bankruptcy Court for the Southern District of Texas, Houston District on May 20, 1992. The EPA believed that the air emissions from the former foundry, which contained particles of lead, may have caused on-site (OU 1) and offsite (OUs 2 and 3) soils to become contaminated through the air deposition of these particles. Foundry practices may have also contributed to onsite lead contamination of the soils. Other probable sources of lead contamination that may have impacted the on- and offsite soils may include lead-based paint and historical deposition from vehicular lead-based fuel emissions, among other possible sources. 3.4 INITIAL RESPONSE The on-site facilities were demolished as a salvage operation under order of the U.S. District Bankruptcy Court between March 1995 and January 1996. On September 29, 1998, the EPA proposed to add the MDI Site to the National Priorities List (NPL) of Superfund sites (Federal Register / Vol. 63, No. 188, Pages 51882 - 51888). The Final NPL listing for the MDI Site was 7 published on January 19, 1999 (Federal Register / Vol. 64, No. 11, Pages 2942 - 2949). In 1998 and 1999, the potentially responsible parties for the Site performed an extensive drum removal action under EPA’s oversight. This action included the cleanup of the abandoned Can-Am drums. In addition, the Texas Natural Resources Conservation Commission (currently the Texas Commission on Environmental Quality [TCEQ]), conducted a removal and restoration of 89 residential yards to the west of the MDI Site. The latter removal action was conducted to remove surface soil with lead concentrations that equaled or exceeded 500 milligrams per kilogram (mg/kg) to reduce the exposure of children and adults to lead. Tetra Tech EM Inc. (Tetra Tech) performed the initial remedial investigation (RI) at the MDI Site for the EPA during the first half of 2003 and submitted the RI Report for OU 1 in November 2003, followed by the Feasibility Study (FS) Report submitted in January 2004. Tetra Tech later submitted the RI and FS Reports for OU 2 in July 2005. EA Engineering, Science and Technology, Inc. (EA) submitted the RI Report for OU 3 in February 2009. No FS Report was required for OU 3 because based on the Human Health Risk Assessment (HHRA) for OU 3, the EPA concluded that no further action was required for OU 3 residential yards and that no action was warranted for OU 3 crawlspaces (EA 2009). The EPA issued RODs for OU 1 (On-site Soils and Groundwater), OU 2 (Offsite Residential Yards and High-access Areas), and OU 3 (Residential Crawlspaces and Those Residential Areas not Addressed under OU 2) of the MDI Site on July 30, 2004; September 23, 2005; and August 31, 2009; respectively. In November 2003 and June 2005, the EPA performed removal actions that addressed 59 residential areas in OU 2, located to the east and north of the Site, including the Blanche Kelso Bruce Elementary School and the Fifth Ward Multi-Service Center. These removal actions were conducted to remove surface soils with concentrations of lead that equaled or exceeded the 500 mg/kg action level to a maximum depth of 1.5 feet (ft) below ground surface (bgs). The purpose of these removal actions was to reduce the exposure of adults and children to lead. This contaminated soil was stockpiled and covered within the fenced property of the former foundry, and later disposed of at appropriate land disposal facilities in Conroe, Atascocita, and Alvin, Texas. 8 In February–April 2006 and April 2009, EPA removal actions were performed for OU 3 at the Kelly Village Housing Authority Property and six additional residential yards, respectively. Lead-contaminated soil was excavated from 9 grids within the multi-family housing unit from depths ranging from 6 inches (in.) to 2 ft bgs, depending on the depth of lead contamination as determined during the 2003 RI. During the removal operations, approximately 1,760 cubic yards (yd3) of lead-contaminated soil was excavated and disposed. On May 26, 2006, the prospective purchaser for OU 1, Clinton Gregg Investments, Ltd., signed an “Agreed Order on Consent and Covenant Not to Sue” (Agreed Order). The prospective purchaser agreed to implement the remedy identified in the ROD for OU 1(for On-site Soils and Groundwater). The EPA published a Federal Register (FR) Notice on June 1, 2006, soliciting public review and comment on the EPA’s agreement with the prospective purchaser. The public comment period ended on July 3, 2006. As requested by the public, the EPA held a public meeting on August 7, 2006, to discuss the EPA’s proposed decision not to sue the prospective purchaser. The Agreed Order became final on September 29, 2006. 3.5 BASIS FOR TAKING ACTION OU 1 The response action selected in the ROD for OU 1 was necessary to protect the public health or welfare or the environment from actual releases of hazardous substances into the environment. The response action was warranted because: a. The EPA's goal was to attempt to limit exposure to soil lead levels such that a typical child or group of similarly exposed children would have an estimated risk of no more than 5 percent of exceeding a 10 microgram per deciliter (µg/dL) blood-lead level. The data from the Site indicated that for a future resident child living on 8 of the 18 grids, the hypothetical neighborhood would have an estimated risk ranging from 5.73 to 20.24 percent of exceeding the 10µg/dL blood-lead level. b. The concentration of benzo(a)pyrene (B(a)P) in the shallow water bearing zone (SWBZ) exceeded 0.2 microgram per liter (µg/L), the federal Maximum Contaminant Level (MCL). Reduction of the B(a)P concentration in the groundwater, by source removal and MNA, to below the drinking water MCL would return the groundwater to beneficial use. The EPA believed that the probability of 1 in 1,000 (1.0 x 10-3) of an individual developing cancer due to dermal exposure of B(a)P while showering was overestimated due to the uncertainty in the calculation of the dermally absorbed dose from groundwater 9 and its input into the calculation of daily intake (Reasonable Maximum Exposure). Reduction of the B(a)P concentration in the drinking water to below the drinking water MCL would reduce the extremely conservative estimated cancer risk level of 1.0 x 10-3 to below the acceptable risk level of 1xl0-4. c. The Hazard Indices (HIs) of 2.2 and 44 (using Reasonable Maximum Exposure assumptions for potential beneficial use of groundwater) for manganese and molybdenum, respectively, were greater than an HI of 1, indicating the potential for adverse noncancer effects that could occur from ingestion of groundwater contaminated with manganese and molybdenum. Inorganic contamination in the groundwater is sporadic and the distribution of these metals is not suggestive of a point source release to the groundwater, but likely reflects dissolution of metallic debris that appears to have been included in the backfill materials of Ingraham Gully. Neither manganese nor molybdenum were detected in soils at concentrations greater than or equal to their respective screening levels. The lack of an association between elevated inorganic concentrations in groundwater and soils also suggests that the source of the contamination is likely localized. d. The Total Petroleum Hydrocarbons (TPH) in the northwest corner of the Site and the asbestos-contaminated material (ACM) scattered throughout the Site were considered principal threat wastes under a future residential exposure scenario and needed to be addressed. e. Institutional Controls (ICs) are needed to ensure that future residents are not exposed to concentrations of organics or metals in the soil and groundwater above acceptable healthbased levels. OU 2 All residential property yards and high access areas in OU 2 that had lead concentrations above 500 mg/kg were addressed by previous removal actions. A total of 148 properties were remediated. TCEQ conducted a removal of 89 properties during 1998 and 1999, and EPA conducted a removal of 59 properties in November 2003 and June 2005. EPA believed that the removal actions have eliminated the existing and potential risk to human health and the environment in OU 2, so that no further action was necessary. OU 3 By the time the ROD for OU 3 was issued, the EPA had performed another removal action at seven residential properties, in addition to ones already addressed in OU 2. The HHRA of the residential crawlspaces and residential property yards in OU 3 concluded that current or potential future Site conditions posed no unacceptable risk to human health or the environment (EPA 2009a). 10 4.0 REMEDIAL ACTIONS This section discusses the selected remedy, remedy implementation, and operations and maintenance (O&M) activities/costs. 4.1 REMEDY SELECTION The ROD for OU 1 was signed on July 30, 2004. The Remedial Action Objectives (RAOs) for OU 1 are (EPA 2004): • Remove the ACM that has been stockpiled on the Site and left in the existing building • Reduce the risk posed to residential receptors by lead concentrations in the soil equal to or greater than the cleanup goal for the Site (500 mg/kg) • Remove soil visibly contaminated with waste oil in the vicinity of MW-3 and MW-20 that is acting as a potential continuing source of groundwater contamination • Remove soil visibly contaminated with waste oil in the vicinity of MW-11 that has the potential to act as a source of groundwater contamination • Remediate groundwater in the northwest corner of the Site, at MW-20, and remove the free product associated with the Underground Storage Tank (UST) • Mitigate the threat posed by exposure to groundwater throughout the rest of the Site. The major components of the remedy selected included (EPA 2004): a) Excavation and treatment (solidification/stabilization, if necessary) of approximately 13,600 yd3 of soils with lead concentrations equal to or greater than 500 mg/kg to a maximum depth of 1.5 ft bgs, and approximately 3,000 yd3 of soils stockpiled at the Site from a previous removal action will also be treated, if necessary. Transportation and disposal (at a permitted offsite waste disposal facility) of the treated and untreated soils. b) Transportation and disposal (at a permitted offsite waste disposal facility) of approximately 31,621 yd3 of debris (nonhazardous debris, foundry sand, and slag), ACM in the on-site building and scattered throughout the Site, and the UST in the vicinity of MW-20. 11 c) Excavation and disposal (at a permitted offsite waste disposal facility) of approximately 2,100 yd3 of soils contaminated with B(a)P, or other organics, at the MW-3 location; light non-aqueous phase liquid (LNAPL) at the MW-11 location; and TPH at the MW-20 location. d) Implementation of monitored natural attenuation (MNA) for the groundwater, which included source removal and long-term monitoring for the groundwater to ensure that constituents above cleanup goals are naturally attenuating. e) Implementation of ICs for both the soils and groundwater to prevent exposure to soil contamination above acceptable cleanup levels and to prevent exposure to contaminated groundwater in the SWBZ. A developer/contractor or owner for the Site must agree to provide deed restrictions to the affected property, as appropriate or allowed by law, that address the soil and groundwater. The RODs for OU 2 and OU 3 were signed on September 23, 2005 and August 31, 2009, respectively. The EPA believed that the removal actions had eliminated the existing and potential risk to human health and the environment in OU 2 and OU 3, so that no further action was necessary. 4.2 REMEDY IMPLEMENTATION In an “Agreed Order on Consent and Covenant Not to Sue,” (Agreed Order) Clinton Gregg Investments, Ltd. agreed to implement the remedy identified in the 2004 ROD. The RD was conducted by ENTACT Environmental Services (ENTACT) on behalf of Clinton Gregg Investments, Ltd. The RA was initiated on February 12, 2007. The RA activities were completed on June 5, 2008. The RA was approved by the EPA on December 12, 2008. The major components of the RA included the following: • Demolition – The asbestos abatement of the two-story building and other on-site structuring was performed in May 2007. The entire building was demolished and the debris was hauled offsite. • Asbestos Management – In June 2007, various ACM debris piles located throughout the Site were gathered and segregated into stockpiles for waste classification prior to disposal. In July 2007, approximately 60 yd3 of ACM debris were hauled offsite and disposed of. 12 • Non-hazardous Debris – The management of the debris on-site was completed by collecting, segregating, downsizing, and then either recycling or disposing the debris. The estimated 31,621 yd3 of non-hazardous debris comprised of wood, metal, concrete, masonry, slags, ceramics, sands, trees, and non-commercial refuse. The segregation of the debris piles yielded special waste products such as batteries, tires, and asbestos; which were all managed as wastes and either recycled or disposed of in accordance with applicable requirements. The nonhazardous wood, masonry, slags, ceramics, and refuse were disposed as construction and demolition waste, whereas the concrete, metal, trees, and the special wastes were all recycled. • Special Wastes – The various types of special wastes located on-site that were removed and disposed consisted of an electrical transformer and the UST in the vicinity of MW-20. In September 2007, a second UST was found at the MDI Site near Lead Area 1 and contained approximately 220 gallons (gal) of gasoline impacted water. The fluids from this UST were disposed at Chemical Waste Management’s facility in Sulphur, Louisiana. The tank was excavated and recycled at Texas Port Recycling. The bag filter stockpiles on-site were wetted, excavated, and disposed at the Chemical Waste Management’s facility in Sulphur, Louisiana. • Surface Water Impoundments – Seventeen water impoundments were sampled and found to be suitable for discharge under the City of Houston Publicly Owned Treatment Works requirements. The settlement basin was decanted and the underlying sludge materials solidified to allow disposal with other TPH-impacted soils. Both surface ponds were filled using on-site soils. The only water requiring disposal was associated with water impoundment SW-WS6a, and SWWS6b, and the UST removals. • Lead Impacted Soil – The lead areas were re-sampled using 50-ft by 50-ft sampling grids. Grids found to exceed the screening level of 458 mg/kg were removed and disposed at Waste Management’s Atascocita and Conroe facilities in Texas; those found to be below the screening level required no further action. In several locations, the grid sampling advanced deeper than 18 in. to pursue lead contamination above the 458 mg/kg screening level for removal. • Source Removal – The source removals included MW-03, MW-11, MW-20, the removal related to the UST in the northwest corner of the Site, the removal related to UST 2, water impoundments WS6a and WS6b, and excavation of Lead Area 10. All material excavated from the sources was sampled, segregated into disposal classes for TPH-impacted soils, and disposed at Waste Management’s Atascocita and Conroe facilities in Texas. • Confirmation Sampling – Confirmation sampling was performed on-site to add to the data collected in 2003 regarding the entire Site’s soils. The confirmation sampling identified a total of four areas for removal; one area with PCB-impacted soils near the northwest corner location of the former transformer, and three areas with TPH-impacts. The TPH areas were located southwest of Lead Area 1 (CS02), in the eastern portion of Lead Area 7 (CS10), and north of Lead Area 10 13 (CS14). All material excavated from the confirmation sampling excavations was stockpiled and sampled before being disposed. • Monitoring Wells – MW-11 was plugged and abandoned after source removal. MW-03 and MW-20 were removed to accommodate source removal. They were replaced with MW-03R and MW-20R, respectively. All remaining monitoring wells were determined to be useful for future monitoring needs and were retained. MW-26 and MW-27 were new wells that were added to enhance the plume monitoring capability for MNA. The pre-final/final inspections were conducted on June 25, 2008. The EPA and ENTACT met on-site to perform a pre-final inspection of the Site. A visual inspection was conducted at each of the RA locations to verify proper execution, which included inspection of each monitoring well, lead and source removal excavation areas, foundry sand locations, water impoundments, concrete removal areas, and final site topography. The EPA determined that all of the soil remediation was properly executed and there were no outstanding problems. Therefore, an additional final inspection was not required. ENTACT performed the baseline and first two quarterly MNA sampling events, after which SKA Consulting, L.P. (SKA) was retained by Clinton Gregg Investments, Inc. to perform the remedial MNA activities. Three plume management zones (PMZs) were established (PMZ 1 through 3) in accordance with Texas Risk Reduction Program (TRRP) rules and regulations in order to manage groundwater contamination during MNA activities. PMZ 1 is designed to address manganese and molybdenum concentrations in shallow groundwater beneath the central portion of OU 1. PMZ 2 is designed to address B(a)P concentrations in shallow groundwater beneath the northeastern portion of OU 1. PMZ 3 is designed to address TPH in shallow groundwater beneath the northwestern portion of OU 1. The Agreed Order signed by Clinton Gregg Investments, Ltd stated that: (1) MNA would be applied as part of the selected remedy within PMZ 2 and PMZ 3 in the northeast and northwest corners of the Site, respectively; and (2) MNA will be discontinued when the concentration of B(a)P in the groundwater is less than 0.2 µg/L (the federal MCL), and TPH concentrations decline to less than 4.1 milligrams per liter (mg/L), the site-specific critical Protective Concentration Level (PCL). The Agreed Order also stated that PMZs would be implemented as part of the ICs at the Site, and would include the derivation of PCLs for PMZ 1. 14 While the three PMZs address specific chemicals of concern (COCs), the monitoring wells sampled for MNA (PMZ 2 and PMZ 3) have changed over time. The monitoring wells originally utilized for MNA were MW-1, MW-2, MW-3(R), MW-4, MW-13, MW-20(R), MW24, MW-25, MW-26, and MW-27. These monitoring wells were sampled in the baseline groundwater monitoring event of July 2008 and the first two quarterly monitoring events in October 2008 and January 2009. Currently, the monitoring well network for the three PMZs includes attenuation monitoring point (AMP) wells and point of compliance (POC) wells. The AMP wells are utilized to monitor concentrations of the COCs within the PMZs, and evaluate the effectiveness of the MNA processes in PMZs 2 and 3. The POC wells are utilized to demonstrate that the contaminant plume has not migrated laterally beyond the limits of the PMZ at concentrations above their respective TRRP Tier 1 Residential Groundwater Ingestion PCLs (TCEQ 2011). While POC wells were first designated in the January 2009 sampling event, monitoring wells utilized as POC wells for PMZ 1 and PMZ 2 have changed in subsequent monitoring events. Monitoring wells currently utilized as AMP and POC wells, were proposed in the ENTACT letter dated June 15, 2009, and were approved in the EPA Approval Letter dated September 2, 2009. Table 2 lists the COCs, AMP, and historic and current POC wells in each PMZ. The locations of each PMZ and their associated AMP and POC wells are depicted on Figure 2, in Attachment 1. 15 TABLE 2 MONITORING WELL CLASSIFICATION AND USE Plume Managemen t Zone (PMZ) 1 2 3 NOTES: 1 2 Protective Constituents Concentration of Level Concern (mg/L) EFFECTIVE DATE Manganese (Mn) 1.15 Molybdenum (Mo) 0.12 Benzo(a)pyrene (B(a)P) Total Petroleum Hydrocarbon s (TPH) 0.0002 4.1 Attenuation Monitoring Point (AMP) Wells* After 9/2/2009 MW-41, MW-8, MW-13, MW-23, MW-242 MW-41, MW-8, MW-13, MW-23, MW-242 MW-3R, MW-25 MW-1, MW-20R Point of Compliance (POC) Wells January After 2009 9/2/2009 MW-25, MW-28, MW-26 MW-29 MW-25, MW-26 MW-28, MW-29 MW-2, MW-25 MW-26, MW-27 MW-41, MW-242 MW-26, MW-27 MW-4 is an AMP well in PMZ 1 and POC well in PMZ 2 MW-24 is an AMP well in PMZ 1 and POC well in PMZ 2 mg/L = milligram(s) per liter On February 4, 2010, SKA, on behalf of Clinton Gregg Investments, Ltd., requested EPA to delete the soils of OU 1 and the 8-acre western portion of the groundwater in OU 1 from the NPL in order to facilitate redevelopment of the 35-acre Site. The FR Notices, announcing the proposed partial deletion of the Site, were published in the FR on June 15, 2010. These notices announced a 30-day public comment period which began on June 15, 2010, and ended on July 15, 2010. The partial deletion became effective on August 16, 2010. The de-listed areas are identified in Attachment 10. In January 2011, the EPA approved the plugging and abandonment of four wells (MW-05, MW10, MW-12, and MW-22) within the de-listed 8.8 acres of the Site, along with two damaged monitoring wells (MW-17 and MW-19). According to the draft MNA Report No. 7, Sixth 16 Quarterly Monitoring Event, Request to Implement Interim Groundwater Remedial Action Report, SKA anticipates the plugging and abandonment of these wells to take place during the first quarter of 2012 (SKA 2011). As required by the ROD for OU 1, a restrictive covenant (IC) stating the following was issued on May 19, 2010: 1) Exposure to the groundwater underlying the Affected Property for any purpose is prohibited until such time when all of the COCs no longer exceed their respective PCLs. The maintenance and monitoring described in Exhibit C of the Restrictive Covenant (TCEQ 2010) is required. Any modification of this restrictive covenant is prohibited without prior approval of TCEQ. 2) These restrictions shall be a covenant running with the land. 4.3 OPERATION AND MAINTENANCE The following activities were performed as part of the ongoing quarterly O&M inspections conducted concurrently with MNA activities: • Inspection of all monitoring wells for erosion of soils around foundation pads preventing stability and to ensure that proper drainage slopes are established to prevent surface runoff from entering the wells through the well casings. • Inspection of all monitoring well locking devices and all other well components to ensure proper functionality. MNA is being applied as the groundwater remedy within PMZ 2 and PMZ 3 in the northeast and northwest corners of the Site, respectively. Water quality at the POC in each of the PMZs must attain Tier 1 PCL in accordance with the TRRP in 30 Texas Administrative Code Chapter 350 (30 TAC 350). There have been seven groundwater monitoring events since the baseline groundwater sampling event in July 2008, and an additional sampling event in April 2009 to delineate PMZs. The latest sampling event was performed in January–February 2011. The results of the groundwater sampling events are discussed in Section 6.4, Data Review. 17 4.4 OPERATION AND MAINTENANCE COST The O&M costs from 2008 through 2011 were not provided during this first five year review. The estimated annual O&M costs in the ROD and Preliminary Close Out Report were $220,000. This cost estimate includes, but is not limited to: (1) O&M activities, (2) groundwater sampling and analysis, and (3) consulting and reporting activities. O&M activities are being conducted by the purchaser of the Site in a timely manner and as required by the Agreed Order on Consent for Remedial Design (RD)/RA. 5.0 PROGRESS SINCE THE PREVIOUS FIVE-YEAR REVIEW This is the first five-year review for the MDI Site. 6.0 FIRST FIVE-YEAR REVIEW PROCESS This section presents the process and findings of the first five-year review. Specifically, this section presents the findings of the document review, data review, ARAR review, site inspection, and interviews. 6.1 ADMINISTRATIVE COMPONENTS This five-year review was led by Mr. Rafael Casanova, EPA Remedial Project Manager. TCEQ, SKA, and EA personnel assisted in the review process. The TCEQ representative is Mr. Phillip Winsor of the Superfund Section Remediation Division. SKA’s team members included Ms. Janet R. Meaux and Mr. Scott K. Leafe. EA’s team members included Mr. Stan Wallace, Mr. Luis Vega, and Ms. Reshma Hooda. In August 2011, the review team established the review schedule, which included the following components: • Document review 18 • • • • 6.2 Data review ARARs review Site inspection Interviews. COMMUNITY INVOLVEMENT A public notice announcing the initiation of the first five-year review was published in three local newspapers, including the Houston Chronicle on September 29, 2011, African-American News & Issues on October 3–9, 2011, and Semana News on October 2–8, 2011. A copy of this public notice in English and Spanish is included in Attachment 2. Upon signature, a copy of the First Five-Year Review Report will be available online at http://www.epa.gov/superfund/cleanup/postconstruction/5yr.htm and at the following information repositories: (1) EPA Region 6, 1445 Ross Avenue, Dallas, Texas 75202; (2) Blanche Kelso Bruce, Music Magnet Elementary School, 510 Jensen, Houston, Texas 77020; and (3) Phillis Wheatley High School Library, 4900 Market Street, Houston, Texas 77020. 6.3 DOCUMENT REVIEW The five-year review included a review of relevant decision documents, implementation documents, remedy performance documents, O&M documents, and legal documents. The review included: (1) RI and FS Reports, (2) RODs, (3) Final RA Report, (4) Preliminary Close Out Report, and (5) Groundwater Monitoring Reports. Complete references for all the documents reviewed are provided in Attachment 3. 6.4 DATA REVIEW The purpose of groundwater monitoring is to: (1) monitor plume behavior, and (2) ensure remediation goals are met for the groundwater. Seven groundwater monitoring events were conducted by contractors retained by Clinton Gregg Investments, Ltd. from October 2008 through February 2011. The baseline sampling event to which the results of the quarterly events 19 are compared was performed in July 2008. The PCLs for manganese, molybdenum, and TPH were used as cleanup criteria when evaluating groundwater data. The PCLs originate from the TRRP rule in 30 TAC Chapter 350 for Tier I. The PCL for B(a)P is its MCL. The PCLs for the individual contaminants are presented in Data Table 1, in Attachment 4. Samples collected as part of these groundwater monitoring events were analyzed for manganese, molybdenum, B(a)P, and TPH. The samples were also analyzed for natural attenuation parameters, including methane, total iron, nitrate, sulfate, alkalinity, biological oxygen demand, carbon dioxide, chemical oxygen demand, ammonia, sulfide, and total organic carbon. Phospholipid fatty acid analysis, which provides an understanding of the nature and quantity of microbes present in groundwater, was performed on select groundwater samples collected from July 2008 through February 2010. Data Table 1 in Attachment 4 summarizes the groundwater COC data for all the sampling events. Graphs of groundwater concentrations over time are included in Attachment 5. Microbial biomass analysis was performed on groundwater samples during the baseline sampling event in July 2008. The microbial biomass is a measure of the amount of microbes present in a sample and can be evaluated to indicate the potential for bioremediation. Based on ENTACT’s Baseline Groundwater Monitoring Report dated September 11, 2008, the following benchmarks were used to evaluate the microbial biomass present in the groundwater samples: • • • Low: 103 to 104 cells/mL Moderate: 105 to 106 cells/mL High: 107 to 108 cells/mL The microbial biomass results for AMP and POC monitoring wells in PMZ 2 and PMZ 3 ranged from an average of 1.29 x 104 cells/mL in PMZ 3 POC well MW-26 to 3.02 x 105 cells/mL in PMZ 2 AMP well MW-03R. The results indicated low to moderate microbial biomass levels in PMZ 2 and PMZ 3 wells. The evaluation of the natural attenuation processes at the Site was achieved by evaluating the possible three lines of evidence defined in the Statement of Work included in the Agreed Order (Attachment 3 of the Agreed Order). The three lines of evidence are: 20 • Historical groundwater data that show a trend of decreasing contaminant mass and/or concentration over time • Trends in geochemical parameters that are indicative of the occurrence of natural attenuation processes • Microbial data that demonstrates degradation is occurring. PMZ 1 The ROD for OU 1 states that MNA for molybdenum and manganese is not warranted and therefore, PMZ 1 is exempt from the requirement of proving the occurrence of MNA. Furthermore, e-mail correspondence between the EPA and SKA, which is included in Appendix 6 of the Draft Request to Implement Interim Groundwater Remedial Action Report, confirms this exemption, while stating that monitoring for PMZ 1 is required until the cleanup levels are reached for the B(a)P and TPH in PMZs 2 and 3. Hence, the only remedy applicable to PMZ 1 was the implementation of ICs. AMP well MW-4 had concentrations of manganese above the PCL of 1.15 mg/L during the last four monitoring events and concentrations of molybdenum above the PCL of 0.12 mg/L during three of the last eight monitoring events. The molybdenum concentrations in AMP well MW-8 exceeded the PCL during two of five monitoring events and in AMP well MW-23 exceeded the PCL during four of five monitoring events. The molybdenum concentrations in AMP wells MW-13 and MW-24 have always exceeded the PCL. Lead concentrations were measured during the March–April 2009 monitoring event. Lead concentrations exceeded the MCL of 0.015 mg/L in AMP well MW-13. The manganese and molybdenum concentrations in POC wells MW-28 and MW-29 have been consistently below their respective PCLs since installation of the wells in the first quarter of 2010. PMZ 2 B(a)P has not been detected in the AMP well MW-25. B(a)P was detected above the PCL of 0.0002 mg/L in AMP well MW-3R in July 2008 and February 2010. The B(a)P concentrations 21 decreased to below the PCL in MW-3R for the three subsequent sampling events. B(a)P has not been detected in POC wells MW-4 and MW-24. PMZ 3 TPH has not been detected in AMP well MW-1. One PCL exceedance occurred in June 2010 in AMP well MW-20R. TPH concentrations have been below the PCL in the two subsequent events in this well. However, LNAPL was observed in MW-20R on January 27, 2012, during a site-wide gauging event. The thickness in the well on that day was 0.01 ft. MW-20R was gauged again on January 30, 2012 and the thickness of LNAPL was 0.02 ft. A clear bailer was used to determine the color of the LNAPL, which was light brown. The lead concentration in AMP wells MW-1 and MW-20R during the March–April 2009 monitoring event exceeded the MCL of 0.015 mg/L. Lead has not been monitored since this event. TPH has not been detected in either POC well, MW-26 or MW-27. Plume Behavior Constituent concentration maps from each sampling event subsequent to the soil RA are depicted on the 8 Plume Maps provided by SKA, located in Attachment 5. The maps reflect concentrations and exceedances of constituents from each sampled monitoring well. 6.5 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENT REVIEW As part of this five-year review, ARARs identified in the RODs were reviewed to determine if any newly promulgated or modified requirements of federal and state environmental laws have significantly changed the protectiveness of the remedies implemented. The ROD divided ARARs pertaining to remedial activities for the Site into chemical-, location-, and action-specific categories. Attachment 6 provides a summary table for Site ARARs as presented in the RODs, along with comments and analysis resulting from the review. 22 6.5.1 Chemical-Specific Applicable or Relevant and Appropriate Requirements Chemical-specific ARARs are usually health- or risk-based numerical values or methodologies used to determine acceptable concentrations of chemicals that may be found in or discharged to the environment. The chemical-specific ARARs specified in the ROD were the MCL for B(a)P of 0.2 μg/L, and the TRRP Rule for lead in soil of 500 mg/kg. Additionally, soil concentration requirements associated with the corrective action and the management of wastes from UST releases in 30 TAC 334 Subchapter D and 30 TAC 334.55 were also listed under chemicalspecific ARARs. The current MCL for B(a)P is still 0.2 μg/L and the current Texas Risk Reduction Rule for lead in soil is still 500 mg/kg. 6.5.2 Location-Specific Applicable or Relevant and Appropriate Requirements Location-specific ARARs restrict actions or contaminant concentrations in certain environmentally-sensitive areas. Examples of areas regulated under various federal regulations include floodplains, wetlands, and locations where endangered species or historically significant cultural resources are present. None of the four location-specific ARARs identified were applicable to the Site. No changes to the location-specific ARARs were identified during this review and they still are not applicable to the Site. 6.5.3 Action-Specific Applicable or Relevant and Appropriate Requirements Action-specific ARARs are usually technology- or activity-based requirements or limitations on actions or conditions involving specific substances. These requirements are triggered by the particular remedial activities that are selected to accomplish the remedy. Remedial construction is complete and the RA is ongoing; therefore, the action-specific ARARs are still applicable. No changes to this regulation or other action-specific ARARs were identified during this review. 23 6.6 SITE INSPECTION A site inspection was conducted on November 3, 2011, to assess Site conditions and the effectiveness of measures employed to protect human health and the environment. Attendees included: Mr. Rafael Casanova (EPA), Ms. Janet R. Meaux (SKA), Mr. Luis Vega (EA), and Ms. Reshma Hooda (EA). The Site Inspection Checklist is provided in Attachment 7. The site inspection photographs are provided in Attachment 8. No significant issues were identified regarding the backfilled and resurfaced area of OU 1, including the two surface water ponds. The majority of the Site is covered in vegetation that is properly maintained for access to monitoring wells during sampling events. The asphalt paved roads within the gated OU 1 area allow for vehicle accessibility to all parts of the Site. A drum was present near MW-02. SKA stated that this drum was used during groundwater sampling events and would be properly disposed of after the upcoming sampling event before the end of 2011. There were signs of dumping at MDI. Five-gallon paint buckets and soil and trash piles were present on-site near the Gillespie Street gate. A pile of roof shingles was present near the Hare Street front gate. Photographs 30, 31, 40, 49, and 50, in Attachment 8 present the dumped items. The fencing around the Site is compromised in three specific locations on the west end the Site, as identified in Photographs 32, 34, and 35. All other fencing around the Site was intact and functional. The gate was locked at the time of the inspection and according to SKA it remains locked at all times. Signs warning against trespassing and identifying the Site Identification Number are visibly-posted on the fence. Two such signs were found lying on the ground within the fenced area of OU 1 and need to be reinstalled along the fence. No activities were observed that would indicate any violations of the restrictive covenant implemented to prevent human exposure to contaminated groundwater. All but two of the monitoring wells were in good condition. MW-17 and MW-19 were damaged and are scheduled 24 to be plugged and abandoned early next year. MW-29, located outside of the fenced site area across Hare Street, was missing its well vault lid. SKA was informed of the missing part and will address the matter. 6.7 SITE INTERVIEWS In accordance with the requirements of the five-year review process, the EPA conducted interviews to gain additional information about Site status. The EPA identified key individuals to be interviewed. Table 3 lists the individuals that were invited to complete interview records for the first five-year review. TABLE 3 LIST OF INTERVIEWEES Name Rafael Casanova Scott Leafe John Jennings Phillip Winsor Title/Position Remedial Project Manager President/Managing Partner Project Manager for Frank M. Liu Superfund Section Remediation Division Organization EPA SKA Consulting, L.P. Clinton Gregg Investments, Ltd. TCEQ Date of Interview November 3, 2011 November 11, 2011 November 1, 2011 November 21, 2011 Overall, the responses that were received did not express concerns regarding past or ongoing activities at the Site. Mr. Scott Leafe and Mr. John Jennings acknowledged the damaged fencing and dumping that were noted during the Site inspection. Additionally, Mr. John Jennings indicated that some storm drain covers were stolen from OU 1. The interviewees agreed that the general impression of the work conducted at the Site during this review period was positive and that they were well informed about the Site’s activities and progress. No comments, suggestions, or recommendations were provided in the questionnaire responses. Mr. Scott Leafe noted that a “request to reduce the sampling frequency and number of wells sampled has recently been submitted to EPA as part of the Groundwater Response Action remedial objectives.” No other complaints, adverse comments, or changes in state or 25 federal environmental standards were noted. Received responses and answers to the interview questions are provided in Attachment 9. 7.0 TECHNICAL ASSESSMENT EPA guidance indicates that to assess the protectiveness of a remedy, three questions (Questions A, B, and C) shall be answered. 7.1 QUESTION A: IS THE REMEDY FUNCTIONING AS INTENDED BY THE DECISION DOCUMENTS? The results of the site inspection and review of the ARARs and site data indicate that the remedy is functioning as intended by the ROD. There are no indicators of potential remedy problems. Remedial construction activities related to the soil remedy were completed in 2008. After removal of wastes, soil, a UST, and debris that were sources of contamination, the Site was backfilled with clean imported soil and seeded to establish a vegetative cover. The Site fencing around OU 1 is compromised in a few locations; but because the soil cover and vegetation present on the Site are maintained in good condition, the damaged fencing is not expected to reduce the protectiveness of the remedy. The soil remedy continues to be protective. Inspection and maintenance of the soil remedy in place were coupled with quarterly groundwater monitoring events, which are required as part of the groundwater remedy. Monitoring of the groundwater is being performed as stated in the ROD and the Agreed Order. A restrictive covenant placed on the groundwater serves as an IC to prevent exposure to contaminated groundwater. The restrictive covenant was issued on May 19, 2010, and is still in effect. There was no evidence of any violations of this restrictive covenant observed during the site visit. The groundwater remedy continues to be protective. Reducing the groundwater monitoring frequency is a possible opportunity for system optimization. On October 31, 2011, SKA submitted a request to approve that all actions to 26 implement the Interim Groundwater Remedial Action have been completed, which is an intermediate goal of the Remedial Action MNA Program. As per the Agreed Order, Clinton Gregg Investments, Ltd. will be allowed to reduce groundwater monitoring to a semiannual or annual basis upon the EPA’s determination that the contaminant levels are stable or decreasing. Full redevelopment of the Site can begin when the EPA certifies the Interim Groundwater Remedial Actions are complete. 7.2 QUESTION B: ARE THE ASSUMPTIONS USED AT THE TIME OF REMEDY SELECTION STILL VALID? Changes in Standards and To Be Considered As the remedial work has been completed, most ARARs and requirements To Be Considered (TBCs) for soil contamination cited in the ROD for OU 1 have been met. The ARAR that still must be met at this time and that has been evaluated includes the National Primary Drinking Water Standards for polycyclic aromatic hydrocarbons (40 CFR Part 141) from which the cleanup level for B(a)P was derived. The ARAR/TBC review for this Site is included in Attachment 3. There have been no changes in these ARARs and there are no new standards or TBCs affecting the protectiveness of the remedy. Changes in Exposure Pathways, Toxicity, and Other Contaminant Characteristics Exposure pathways identified for the Site and specified in the ROD are exposure to the COC lead in on-site soil through ingestion for a future on-site child, and exposure to COCs in the SWBZ through ingestion and dermal exposure routes for the future on-site resident child and adult. No changes in land use and new contaminants or contaminant sources have been identified for the Site. The risk posed to a future on-site child was determined using the Integrated Exposure Uptake Biokinetic Model (IEUBK) methodology. There have been no changes to this methodology. The toxicity factors used for B(a)P and molybdenum in groundwater during the HHRA have not changed. The methodology used to derive the manganese oral reference dose (RfD) in the HHRA is not consistent with EPA’s current recommended methodology. The manganese oral RfD used in the 27 HHRA was 0.047 milligram per kilogram per day (mg/kg-day). The oral RfD identified in the EPA Regional Screening Levels table for tap water is 0.024 mg/kg-day. Progress Towards Remedial Action Objectives According to the ROD, the RAO for the Site were to: (1) remove the ACM that had been stockpiled on the Site and left in the existing building; (2) reduce the risk posed to residential receptors by lead concentrations in the soil equal to or greater than the cleanup goal for the Site (500 mg/kg); (3) remove soil visibly contaminated with waste oil in the vicinity of MW-3 and MW-20 that was acting as a potential continuing source of groundwater contamination; (4) remove soil visibly contaminated with waste oil in the vicinity of MW-11 that had the potential to act as a source of groundwater contamination; (5) remediate groundwater in the northwest corner of the Site, at MW-20, and remove the free product associated with the UST; and (6) mitigate the threat posed by exposure to groundwater throughout rest of the Site. All the RAOs associated with contaminated soil and the UST were addressed during the remedial construction activities, which were completed in December 2008. The threat posed by exposure to groundwater is mitigated by the implementation of a restrictive covenant that prohibits activities that can lead to exposure to contaminated groundwater. The RAO that is still being addressed requires the remediation of groundwater on the northwest corner of the Site. MNA was selected to address the groundwater contamination in PMZs 2 and 3 and is currently being implemented. The Draft Request to Implement Interim Groundwater Remediation Action has been submitted to the EPA (SKA 2011). This report states that all actions to implement the Interim Groundwater Remedial Action have been completed, which is an intermediate goal of the RA MNA Program. Full redevelopment of the Site can begin when EPA certifies that the Interim Groundwater Remedial Actions are complete and approves this request. 28 7.3 QUESTION C: HAS ANY OTHER INFORMATION COME TO LIGHT THAT COULD CALL INTO QUESTION THE PROTECTIVENESS OF THE REMEDY? No information has come to light as part of this first five-year review for the Site that would call into question the protectiveness of the site remedy. 7.4 TECHNICAL ASSESSMENT SUMMARY After documents and data were reviewed, and the site inspection and interviews were completed, it appears that the remedy is functioning as intended by the ROD (EPA 2004). There have been no changes in the physical conditions of the Site that would affect the protectiveness of the remedy. The ARARs for soil contamination cited in the ROD have been met. There has been no change to the standardized risk assessment methodology (IEUBK) for lead that could affect the protectiveness of the remedy. With the exception of the oral RfD for manganese, there have been no changes in the toxicity factors for the COC that were used in the baseline risk assessment. The protectiveness of the current remedy needs to be evaluated with respect to manganese in groundwater. 8.0 ISSUES Based on this first five-year review, it appears that the remedy at the MDI Superfund Site has been implemented as planned and is functioning in accordance with the requirements stated in the ROD (EPA 2004). No major deficiencies or concerns with the remedy or monitoring procedures were identified for the Site. During this first five-year review, the following issues are noted: 1. Monitoring wells — Damage to monitoring wells MW-17 and MW-19 was observed during the site inspection. 29 2. Oral reference dose for manganese in groundwater has changed — The methodology used to derive the manganese oral RfD in the HHRA is not consistent with EPA’s current recommended methodology. The manganese oral RfD used in the HHRA was 0.047 mg/kg-day. The oral RfD identified in the EPA Regional Screening Levels user’s manual is 0.024 mg/kg-day (EPA 2011). 3. LNAPL in MW-20R — Measurable thicknesses (0.01 to 0.02 ft) of LNAPL were observed in MW-20R (PMZ 3) on January 27 and 30, 2012. 9.0 RECOMMENDATIONS AND FOLLOW-UP ACTIONS Table 4 presents the recommendations and follow-up actions associated with the Site that were identified during the first five-year review. 30 TABLE 4 RECOMMENDATIONS AND FOLLOW-UP ACTIONS Issue Monitoring Wells Oral Reference Dose for Manganese in Groundwater Has Changed Light NonAqueous Phase Liquids in MW20R Recommendations and Follow-Up Actions Damaged wells MW-17 and MW-19 should be plugged and abandoned. Party Oversight Milestone Responsible Agency Date Clinton Within 1 year Gregg of Final First EPA Investments, Five-Year Ltd. Review Report The noncarcinogenic risk for manganese in groundwater was determined using an oral RfD of 0.047 mg/kg/day. The current oral RfD for the noncarcinogenic risk for Clinton manganese in groundwater is 0.024 Gregg mg/kg/day, according to the EPA Region Investment, Screen Level Tables (EPA 2011). The Ltd. noncarcinogenic risk for manganese in groundwater should be reevaluated to ensure that the remedy is protective of human health. MW-20R should continue to be Clinton monitored for LNAPL. Gregg Investment, Ltd. 31 Follow-Up Actions: Affects Remedy Protectiveness (Yes/No) ShortLongTerm Term No No EPA Within 1 year of Final First Five-Year Review Report No Yes EPA Within 1 year of Final First Five-Year Review Report No No 10.0 PROTECTIVENESS STATEMENT Based on the information available during the first five-year review, the selected remedy for OU 1 (On-site Soils and Groundwater) of the Many Diversified Interests, Inc. Superfund Site appears to be performing as intended. The Site is protective of human health and the environment. 11.0 NEXT REVIEW The MDI Superfund Site requires ongoing five-year reviews. The next, or Second Five-Year Review, shall be conducted no later than five years from the date of the Superfund Division Director’s signature of this First Five-Year Review Report. 32 Attachment 1 Site Location Map and Site Layout Map Jensen Dr ³ Lyons Ave Lyons Ave 0 Waco St £ ¤ 59 1,000 Feet ¨ § ¦ ve sA S t M a r k e t ¦ ¨ § 10 G r e g g Lockwood Dr on Ly Gregg St Elysian St 10 S t S t W a c o G r e e n S t M o s e s S t P r o v i d e n c e S t B u c k ¨ § ¦ 10 H a r e S t S t ¦ ¨ § 10 Legend: h R d P r e s s S t i r s S t S t H S t B r i n g h u r s t C a g e B a e r S t c N a n c e Subject Property Boundary G i ll es p ie S t C l i n e C l i n e S t S t T & N O R R S t C l i n t o n r ck w oo dD u f f a l o Je n Lo se nD r B Hirsch Rd 59 n Dr jschwertz Mckee St Clinton Dr £ ¤ Clin to D r EA-Dallas S t Texas ¨ § ¦ Austin 10 Fr an kli n B St Na v iga ti o n Bl Five-Year Review Many Diversified Interests, Inc. Superfund Site Operable Unit 1 3617 Baer Street Houston, Harris County, Texas vd St rk o Y a ¨ § ¦ ¨ § ¦ 45 Houston San Antonio Site Location 35 y o u Corpus Christi Gu lf of Me xico Figure 1 Site Location Map r:\federal\epa\rac ii\0076-mdi 5yr\mdi_gis\mxd\5yr_fig01_siteloc.mxd M e l v a 2011-12-01 B a r o n ) MW-29 Ó S t T T T T T T T T T T T T T T T & MW-21 A T T T T T T ) MW-26 Ó T T T T T T AMW-25 T T T T T T T & MW-02 A T T T T T T T T T T ) MW-24 Ó T 0 T PMZ 3 T T T T T T T T T H a r e T T T AMW-01 MW-20R ) MW-27 A Ó T T T T T T T T T T T T T T T T T T T T S t PMZ 1 Monitoring Well Location A Attenuation Monitoring Point Well Location ) Ó T T T T T T Point of Compliance Well Location T Chain-Link Fence T T T & MW-15 A & A P r e s s T T Broken fence & MW-14 A Subject Property Boundary T T T AMW-13 T T T T B r i n g h u r s t T T T Legend: T & MW-12 A T T T T Pile of roof shingles & MW-18 A T T T T T T T T TT T T T AMW-03R ) MW-04 Ó T S t N a n c e S t Feet T ) MW-28 Ó B a e r 150 T PMZ 2 ³ Plume Management Zone T T T T T Note: MW-04 and MW-24 are denoted as Point of Compliance Wells for PMZ 2 but are also utilized as Attenuation Monitoring Point Wells for PMZ 1. T MW-11 T T T T & Missing A T T Soil pile T T T T MW-17 & Damaged A T Damaged fence, easily bent over T & MW-22 A jschwertz T T T T & MW-06 A T T T T T T T T & MW-07 A T T T T T T T T T T S t T C l i n e T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T T Houston, Harris County, Texas T T Five-Year Review Many Diversified Interests, Inc. Superfund Site Operable Unit 1 3617 Baer Street T T S t & MW-09 A T T A MW-08 T T & MW-10 A T B a r o n S t C l i n e r:\federal\epa\rac ii\0076-mdi 5yr\mdi_gis\mxd\5yr_figxx.mxd Gillespie St EA-Dallas T T Pile of trash T & N O R R Figure 2 Site Layout Map 2011-12-06 T T & MW-16 A T T AMW-23 T Paint buckets T MW-19 & Damaged A T T T S t & MW-05 A Attachment 2 Five-Year Review Public Notice PUBLISHER'S AFFIDAVIT THE STATE OF TEXAS COUNTY OF HARRIS Before me, the undersigned, notary Public, this day personally came LISA M. SMITH who, after being duly sworn, according to laYI , say that she is the MANAGING EDITOR of AFRICAN ...AMERICAN NEWS&/SSUES a weekly newspaper published at 6130 Wheatley St. in said City of Houston, County of Harris and State of Texas, and that the advertisement was published I de~ivered in said paper. AFRICAN-AMERICAN NEWS&ISSUES Volume 16 Number 36 Oct. 03, to 09, 2011 Public Notice Many Diversified Interests, Inc. Superfund Site Ad Size: 1/2 page ost: $2835.00 ~e - ' )v(~ liaM.Smith, Managing Editor Subscribed and Sworn before me this Notary Public, Harris Coun~J, Texas __Q_ day of Oct., 2011 . ·- .·;Business · Texas • October 3-9, 2011 :·:"fY:'i\ Afrlc8.CD~ News&lssue~.. Read us online! www.aframnews.com ~ MANY DIVERSIFIED INTERESTS, INC. SUPERFUND SITE PUBLIC NOTICE U.S. Environmental Protection Agency Region 6 First Five-Year Review of Site Remedy September 2011 The U.S. Environmental Protection Agency Region 6 (EPA) has begun the first Five-Year Review of the remedy for the Many Diversified Interests, Inc. (MDI) Superfund Site. The review will confmn if the remedy performed is still protecting human health and the environment. The site is located in Houston, Harris County, Texas. Once completed, the results of the Five-Year Review will be made available to the public at the following information repositories: Blanche Kelso Bruce Music Magnet Elementary School 510 Jensen Houston, Texas 77020 and Phillis Wheatley High School Library 4900 Market Street Houston, Texas 77020 Information about the MDI Superfund Site -is also ·available on the internet at: http· I/www.epa. ~ov/re~ion6/6sf/pdffiles/060500&.pdf For more information about the Site, contact: Rafael A. Casanova, P.G., EPA Remedial Project Manager (214) 665-7437 or 1-800-533-3508 (toll free) or by e-mail at casanova.rafael(a).epa. gov All media inquiries should be directed to the EPA Press Office at (214) 665-2200. Acres Homes Chamber for Business and Economic Development, Inc. Investing in our Future, One Youth at a Time grams. Under the direction of Executive Office Manager, Mrs. Jacquie LaFleur, a plan ofaction HOUSTON- Developing involving seveml educational youth leadership skills 1Dday and leadership programs that will help to inspire youth leaden> will begin in October 2011. oftomonow. The .Acres Homes Each one ofthe educational Chamber for Business and and leadelship programs will Economic Development, Inc. serve as a key component for bas initiated the development the building blocks to gaining and implementation ofa series knowledge and experience ofyouth educational initiafor successful involvement in tive programs geared towards leadership roles of scholastic teaching, guiding, equipping, and community mgaoizations. and developing our future comOur first educational and munity and business leaders. leadership initiative is the Studenls in 9th -12th grades ''Youth Leadership Training" from .Acres Homes and North program that is designed to HoustonAreaHigbSchools equip students with individual have been petitioned for their and community leadership involvement in these proskills, as well as participate in By: Kevin Malonson that has been a vital part ofthe individual and group commuAcres nity service projects within the Home Acres Home and North Houston commucommunities. nity for Kevin Malonson, originally the past from the Acres Homes comKevin Malonsoa 5 years munity is pursuing a Masters and bas ofArts in Behaviornl Science serviced (concentiatioo. in Public Service over 275 youth in the Acres Leadership) at the University Home and North Houston ofHouston Clear Lake, will communities. be assisting with the Youth This year our Math & Leadership Training program as Science youth education initiaa project focus for his degree. tive made posstble through the The Youth Leadership Training partnership ofthe Acres Home program_is a yearlong commitChamber for Bus.iness and ment that will affoni students Economic Development, Inc., the opportunity to develop an Rice University, and Reliant undetslanding of their community and implement a plan of Enetgy. Students will be involved in a action acconling to their desired eight-month program designed interests. to enhance 1heir Science, Our second initiative proTechnology, Engineering, and gram is the ..Changing the Face Math knowledge. Students will ofMath & Science Program" use 1heir skills to research and create group projects, interact with other students, area high school teachers, college professors and graduate students ftom. n:uYor universities, as well as corporate partners. Studenls will also have the opportunity to find out about innovative and exciting careers in the areas ofmath, science, and technology. In addition, a three week "Summer Entrepreneurial" program, scheduled for July 2012, also through The Acres Homes Chamber for Business and Economic Development, Inc., will be comprised of three business modules which will allow high school students to gain hands on experience with starting and rurming a small business enterprise. As a reminder to area students in 3rd -12th grades, the Acres Homes Chamber for Business and Economic Development, Inc., in par1ner- ship with Project One Focus, otfels FREE "After-Sdlool Thtoring" on Mondays and Wednesdays between the homs of4 and 7pm, as well as "College Readiness" romes designed to beUer prepare our students for college. The site for all progmms and tutoring is the Acres Homes Chamber for Business and Economic Development, Inc., Beulah Ann Shepherd BWkting located at 6112 Wheatley Street, Houston, TX 77091. ()pportJmities for enhancing and advancing the lives of our yoUth are being offered at little or no cost to recipients. Area youths are strongly encouraged to get involved in your schools and communities to make a difi'erence. Registration and applications are currently being rux:epted, For more information or to receive an application for one of our programs, please contact us at 713-692-7161. HOU-7 . - ·- - ·-- ··- -- - - - - - --------- - -.. - - -· - - - -· -- - - ·-- - -··- · - - -- ·- -·-"· ·- ---- - - - Page 1 25080005 EA ENGINEERING,SCIENCE, AND Sep 29 2011 AFFIDAVIT OF PUBLICATION STATE OF TEXAS: COUNTY OF HARRIS: Before me, the undersigned authority, a Notary Public in and for the State of Texas, on this day personally appeared, the Newspaper Representative at the HOUSTON CHRONICLE, a daily newspaper published in Harris County, Texas and generally circulated in the Counties of: HARRIS, TRINTY, WALKER, GRIMES, POLK, SAN JACINTO, WASHINGTON, MONTGOMERY, LIBERTY, AUSTIN, WALLER, CHAMBERS, COLORADO, BRAZORIA, FORT BEND, GALVESTON, WHARTON, JACKSON, and MATAGORDA and that the publication, of which the annexed herein, or attached to, is a true and correct copy, was published to-wit: EA ENGINEERING,SCIENCE, AND 25080005 RAN A LEGAIJ NOTICE SIZE BEING: 4 X 4.50 I (18.0I) 7476622'6 q-29-11 NEWSPAPER REPRESENTATIVE Notary Publi c in and for the State of Te 25080005 EA ENGINEERING,SCIENCE, AND Sep 29 2011 Page2 Hou~tQ}) _:;;h_ron~cie ·-· LA.:..>IhEO::. -.)~'1 e.osr--4,.~~ MANY DIVERSIFIED INTERESTS, INC. SUPERFUND SITE ~· ~ ·~ PUBLIC NOTICE g ~ :; U.S. Environmental Protection Agency Region 6 \~ o~'4f First Five-Year Review of Site Remedy -.~.. PRo~c September 2011 .,~ ~ The U.S. Environmental Protection Agency Region 6 (EPA) has begun the first Five-Year Review of the remedy for the Many Diversified Interests, Inc. (MDI) Superfund Site. The review will confirm if the remedy performed is still protecting human health and the environment. The site is located in Houston, Harris County, Texas. Once completed, the results of the FiveYear Review will be made available to the public at the following information repositories: Blanche Kelso Bruce Music Magnet Elementary School 510Jensen Houston, Texas 77020 and Phillis Wheatley High School Library 4900 Market Street Houston, Texas 77020 Information about the MDI Superfund Site is also available on the internet at: http:/ /www.epa.gov/region6/6sf/pdffiles/ 0605008.pdf For more information about the Site, contact: Rafael A ..Casanova, P.G., EPA Remedial Proiect Manager (214) 665-7437 or 1-800-533-3508 (toll free) or by e-mail at casanova.rafael@epa.gov All media inquiries should be directed to theE PA Press Office at (214) 665-2200. . cat-e:a, ~c:U.U · ·~tn~ · prop~e.m UWlJ.!:I!f ocp~.....,~...........,......... ... .....- ··-- · ·- "' ' . - .. .h¥. escalated -.aQ'd li~ ~not asking questions and occu~ · So~th ~sian. stores because ·~ty in ~e_ ~rea. .:. · ·.:·: ·. : Th$ · TeXas Fbrest ;ser· · · r~cejved en6ugb .attention pying employees. · ~ of the higher gold cotrtent . . . One of the inspirations ·vtc.e said ~ thiS .we~k ;that from law enf~r~·nt, de_.. · lleana Miclese,tt theJ( fuund fu a majority ofitems fur thieves is the· ease of the wjidfire darig&f wou19 . sP.i~e~h~sartii .artestsiil. :.crlirs . into ·._·a h~. ac~J. ·Jtt)lk;e' . .yolleri _-·. , ,·.: ·,.·, ft:om· individuals need . ~o ave~e . ·temperatl¢e~ , are. of New __·._corijirig.fo,~dlie@•. Con.~an~i · < $tore '_gvyilers say' -t~ey · registet·the. 'Seller's infor" pr.eWetl llein"-:',· l~us:.sto-p:i;.fe~l'ing·the1Jt1~Y - · p\.u'c~ers q<)· not foJio~ ·been ·.huge in' Bast 'fexa$;.:·, .- tl,l~!hld s1tqps !P'e::!' ...__ ··· ,, ·· ·fificl~~~:·t,l? ':~ _· ou~ ~Pt; gtte~ttl'• r-o1' th¢sto.tes or : ~hat :Pril~i~, ~~rmg easy· ·where w,ore th~ !OQ;OOO • ljoo~• . the ()wper s~~ei~;!r~~~~sJ:; .·- -~~~~~~4~~~-J.i.·.- ~;~~~h:~~~~~~o~-~~~--,- !;~0y:";l:~:;.~~~;.._· ~~:r· :~:rt~;e$;~~~~¥;~~~r~~i against lour ~opJe: inves• conu~enttin 'th"case.r:citinf · '' }'TQ'f$ ·- ~ - a ~~ty t;lu,~-·' < . _ · . ·_ ·. -__ ' : · ~ ·. start of:Wlldf'lie Seasonla.•;t\;: tigatGrs ·$ay_!P.~de· of£ with ' .uiJritP~Jpyes·tiO~£,;~!}.~:~~~~:: ·:~~1~~-~i~t~~-~;!~?·~jtk~~Q,~--.{~~~/.: _:~~ve~ber: . -~- <' :---,.:. .. __. _ EWSlll SEMAN Affidavit of Publication 6601 Tarnef Dr. Suite 200 • Houston, Tx 77079 P. 713-774-4652 • F.713-774-4666 www .semananews.com Before me, the undersigned authority, on this day, personally appeared Rafael Duenas of Semana Newspaper, a weekly newspaper of general circulation, published at Houstoq, / 1 Harris County, Texas, who deposes and says that the public / notice, as per copy··a ached, was published in the regular issue{s) of October 2, i 2011. / 5ign ed: __,,__--+-"""'"7""'i~-__,_ Subscribed and sworn to {or affirmed) before me on this ..\ WfBeJ Cl~ 2011 by day of GQ..:\et)e(' proved to me in the basis of satisfactory evidence to be the person who appeared before me. Notary Public in and for County of Harris, Texas MICHELLE IRENE TOUVER MY COMMISSION EXPIRES February 27, 2014 My commission expires: 2 -21- l nr~~ Ll MAIY DIVERSIFIED IITE.ITI, IIC. JI11D .PERF- : ,. _.. _:{~·-·.. . ,,._ . .. _ .·..· -- ·.. MIHCIOPMicO · ·-" ·. ~_. :..::· _·~ ; :';;>.'"t··. . :::. ~?.- }.:,;. \_:. _. "···~Agag~Ja do Prott cc16n·AllltlellbJI tieiOI iliad" Unldis~ kt16111' _ -: _,· ?' . :~;:;:t::--~~- ·· ·., Ptlllllfa:IJVJI!ilfa Cine• ~ del• lleJJUIOIPiti ~~ Sft11 ::):::::.·: · J - ·,, ;>·n:._Y>-.-~->:.; Iepll~~1, ;,:··_'~<::• _;_ ·._ • - . - ~: ia ilegip~·~._de la Ase.n~a de Pte~:e~cioo A$hto~tal d.t,JoJ· . Jn~~-~" del sftto ~nd "' MPitam&Un'~ · · ~ JJai.,i,:(EPA~hl i'!i~tadD k ~ ltvP.. ! {;iDeO.\ d~le _ea1at~~4elil~~ · .·:.~ .._ .· '~• AAtlp. de _lot/r.e.me:d'iol }'tril el SJdo Supettund - cleM~nr .. btt}tJtwww.~p/repm6/~~I'*'SOOS.pdf .·:·:·. :~ . _.-I>ivertllij!d.lt1tete~tt~lnc. (~I).La~n~#~tt-'··.·. ·: <... . Y:. ·. ·. - t,'(···· :>: .:•·.~:\ •.. ·- · '~"'· :· ·· ·._._.·. ··. -':'_·~-.· - · ~ rtm•que •tl'Ufl~on en~ a\\~- ~n~ -P#a may«~accrcaielsttto, .fav«de·ce~~ · lasalud d~her humanq y ehnedto ambjente. Ehltto seencuen- -. ..., ..· -- -'. "- ~ .. · · : tra en Hoilifo.n. m el Condaao de Harris, en Tew: Una Vez ·_ Rafael A. casanova, P;G. condulda, ~o~l'~mltado• de 1a· Rmll6n a ·CJn¢o A4oB estann : dbpotiiblelpara elpt's~ico en }o•_.dgu~tet rtpofitotios 4e info~i6n: - .. -: ':- · ;.:. - ·.·_ · · ·-·· · · · · ·· .. : _ · ·· . Toda-4 1M .0~ deinfc~j>or ·patwdetoS~~ dt: ·· ·. comunkuiO,n. debeil\.q ~er dirtgida.4 ala <>&ana de Prmn de · . . .· SlOJemen · _ • . . . a · Hotmon/J'au77ClO . y ·. . ·. ··. ·, -0 t~·S9Q-.S33·3SOS(Iin~;to)· · . ~ .o p~r torteb e~ cuanoYa.rafael@epa.gov ,,.. BJaru;he Ktllo Brute .. ., MUJJ' MagnetElmentary ~bool ·.. · '• Bilingiie ~ lng!b!s.paftoJ . . GerenUdel Proyeao:de~dela:EPA ·-. · -· :". ·' ' (ll_4) 66~74n' . . y :· ··•• '" ... . .. .· . . ... ·_ P.htlll$ Wheatley tfigh Scl10pl Library · · ., 49.fi0 ~~n:ket StfHtHQuaton, re,M 1702.0 laEPA. . . ;, . al(214:)~"2200. ~· ~· -~ -~·~! - ~' - r- ' AVALANCiii'IS -, .~ .· LLAUI ·.. SOUltTOLI'I5 · " .- ,_>li.MI! $UperUmpia,.2 para escoger~O>torbtanca: aut~matit{);e~u,P,ado, (d; a£, mil, . vqlaOltJI)iiStabl~. fla~ al_7l3~;,7070 flame al h8'88-69~~64 .· ..,, •: . .. . s•EtraiLV.Xuat~· : . .$5,tJ5 • EQUINOX l$t06 · LIME . auto~ttoo; 4 ciL,.64kniUlas, eraoomka,autornatico, equi~mdQ, cd,_v/.ahumados, at,:v/ajustable. Uarne.al713-.682-7070 il(t todo~.'~f.k~-llalJie a171J.;;7Bp;.3~38 GBANDCHEROIEI~ ··- _·lUME automatioo; eq!Jipado, Qlf at crocemf ' vqlante ajiiStable, flaiTieai713·68H070 ·GiWJD OIEIOIEI':M ·:'-' LLAME . a~tiro, equipado, cd, a(. <\ I \ \ MW-1# 1 'NN-1h 1 MOLYBDENUM PCLE ZONE l ~IW·1~ MVV-2# \ ~ \l I MW-19 ~ >< \ I MW·1# \ Ol :I: P'Z 77 I \ BAERSTREET zGl BENZO(A)PYRENE PCLE ZONE --- _j \ :xl VZ/71 GW Cert.. Rftiart\Sglo..!l.ig -........ ND liR£fS IJTIDED OCTOBER 2011 FIRST REVISION SECOND REVISION THIRD REVISION JOB NO: 39004-0003 I BCAlE: AS SHOWN DRAWN BY: CHECKED BY. APPROVED BY: JCS .II'S - JRM FIGURE 10 LEGEND SUBJECT PROPERTY BOUNDARY - -x-- x- ~ MW-21 10/07/08 Mn2.2ll TPH <0.19 J NANCE STREET 100008 SaP 0 .00014J J I\IW-27 I MW)- MW-20 10/07!08 F SaP <0.00008 Pb <0.0012 Mn 0..200 Mo0.00668 TPH <0.19 \PMZ3 I --~.~w~ -- _j Pb< I \ :r r zz :a I MW-19 \ zGl I MW-1# \ :0 POINT OF COMPLIANCE WELL LOCATION PLUME MANAGEMENT ZONE BOUNDARY j >< ~ \ MW-1~ \ 0) -$- J \ ~•w.o# MONITORING WELL LOCATION CHAIN-LINK FENCE "" \ BAER STREET ~ APf>R())(IMl£ SCH.£: 1··1!50' \ MW..Qk \ \ \ Mw-o# T&NORR ~. M/~ s~~a .... -~ )( x ~ SKACONSULTING, l.P. 1515WITTEROAO,SUITE150 HOUSTON, TEXAS noao Texas ReglS'.ered Eng;leemg Fum F.005009 Texas Registefed Geo5<:ience Fm1 50011 CONSTITUENT CONCENTRATION MAP I FIRST QUAR~~'!.';!o~~~~~RING EVENT MDI SUPERFUND SITE OPERABLE UNIT 1 3617 BAER STREET HOUSTON, HARRIS COUNTY, TEXAS I 11 Ql(lOMI BaP <0.00008 Pb <0.0012 Mn0.466 Mo0.0273 LEGEND SUBJECT PROPERTY BOUNDARY -+-$- -x- -x- -=-==-...,MW-21 ~ ~~~~ ] ~ TPH <0.47 MONITORING WELL LOCATION POINT OF COMPLIANCE WELL LOCATION CHAIN-LINK FENCE J "' ~,.,.,_ I\PMZ3 L NANCE STREET ~I W~ - ~IW·12 01120109 BaP <0.00008 Pb<0.0012 Mn0.975 'MO"i["i(i4 ~ \ MW-19 ~ \ z ~ ;!] m ~ \ \ \ MW·1# ~ MW-2# \ \ MW-1# \ \ \ \ MW-0~ I \ \ CUNESTREET \ \ 150 I bs-J APPROXIMATE SCIL£: 1"•150' \ MW-0~ - S SI< lj ~ I I~ BAERSTREET PMZ1 \ \ :;o z l l MW-19 -+ \ (ll \ \ ~ c ~ MW-1, + ~ ~ ~ \ MW·1 # \, \ • \ X \ MW-10 SKA, SUMMARY OF THE MARCH-APRIL 2009 GROUNDWATER MONITORING EVENT AT THE MDI SUPERFUND SITE, APRIL 21, 2009. 1 II CLINE STREET 0 MW-06 \ SOURCE: 1 \ \ \ NOTE: ·CONCENTRATIONS IN RED EXCEED APPLICABLE PCL LIMITS - MW-25 IS UTILIZED AS A POC WELL FOR PMZ 1 AND PMZ 2. • MW-26 IS UTILIZED AS A POC WELL FOR PMZ 1 AND 3. • MW-2 IS UTILIZED AS A POC WELL FOR PMZ 2. • MW-27 IS UTILIZED AS A POC WELL FOR PMZ 3. -TOTAL DISSOLVED CONCENTRATIONS ARE PROVIDED FOR MOLYBDENUM AND MANGANESE. ~ "'i ~uo:~~~~9~M.I I ~:'w:::ul;(~ A I X .,.., x 1515 WITTE ROAD, SUITE 150 HOUSTON, TEXAS 77080 CONSTITUENT CONCENTRATION MAP PROPOSED QUARTERLY MONITORING EVENT MARCH/APRIL 2009 MDI SUPERFUND SITE OPERABLE UNIT 1 3617 BAER STREET HOUSTON, HARRIS COUNTY, TEXAS DATE. 1 2 3 F1lE INfO: G:\2004\39004-oool\Owg\lnWim GW o.t. Rlllprart\fii1~ -~jC -Nb-XREtS-AfiA.CHED SKA CONSULTING, L.P . Texas Registered Engineering Firm F-005009 Texas Registered Geoscience Fim50011 T&NORR I I . . ,.,_ ~"'~ s MW-08 - 150 APPROXIMATE SCALE: 1"•150' \ \ 75 Lw-.•J OCTOBER 2011 FIRST REVISION SECOND REVISION THIRD REVISION JOB NO: 39004-0003 I SCAI.E: AS SHOWN DRAWN BY: CHECKED BY· APPROVED BY: JCS JFS JRM FIGURE 13 LEGEND SUBJECT PROPERTY BOUNDARY 02{15/10 BaP <0.00008 Mn 0.885 I 0.734 Mo 10'2/922 02110/10 Mn 0.227 I 0.201 00:00203JT0.00248 J \ MW-2 -$- POINT OF COMPLIANCE WELL LOCATI ON ~ L " \ \PMZ-3 -MW~ - ATTENUATION MONITORING POINT WELL LOCATION CHAIN-LINK FENCE PMZ-2 NANCE STREET MONITORING WELL LOCATION • - -x--x-MW-21 ~,..,.,.__-! + PLUME MANAGEMENT ZONE BOUNDARY " 1/ 7 / ' 7 ] " MW<>JR 17 7 7/1 V / 7 7] I BENZOtA)PYRENE PCLE ZONE MOLYBDENUM PCLE ZONE MANGANESE PCLE ZONE / ~ A _j ,----,~ \ I Mn o-:19770:137 Mo 0 432 I 0 .322 02/15/10 aaP< (/) \ MW-1~ \ BAERSTREET >< Mo0.116 10.109 GW C4ili.. ~\fi!l14..dllg ,.,, t sic: NO 8US ATW:HED SECOto'O ~SION JCS JFS TH>RD REiilS ION JRM FIGURE 14 LEG END SUBJECT PROPERTY BOUNDARY ~ OO!G811!l Baf'~lOOOOB Mn 0.748 / o.a04 Mo 3 56 / 3 67 06107110 Mn0.20310.176 Mo- 0.0071 J I 0.00164 J \ ft "~"- ''" ""'• 1 "" o\IW-26 06108/10 i"PH"< MOLYBDENUM PCLE ZONE 177721 MANGANESE PCLE ZONE Ii rl MW-1# PMZ-1 MW-19 l MW-1~ -+ \ 0 670'7710 Mn '0.36'71 0.386 IMo 0 152 I 0 162 1 \ \ \ \ 0 150 I CUNESTREET MW-0# MW-Ok S SI< PMZ-1 \ \ MW-19 -+ \ MW·1~ \ \ \ \ MW-1 # MOLYBDENUM PCLE ZONE V7 / 7 MANGANESE PCLE ZONE j b-.-J \ MW..Qs + 150 I sska \ , SKA CONSULTING, L.P. 1515 WITTE ROAD, SUITE 150 HOUSTON, TEXAS 77080 Texas Registered Engineering Arm F..Q05009 Texas Registered Geoscience Arm 50011 \ \ X 75 0 APPROXIMATE SCAL£: 1••150' \ \ ~m-1# CONSTITUENT CONCENTRATION MAP FIFTH QUARTERLY MONITORING EVENT OCTOBER 2010 x- - - MDI SUPERFUND SITE OPERABLE UNIT 1 3617 BAER STREET HOUSTON, HARRIS COUNTY, TEXAS I F1lE MQ: Gt~Ow!a\.i'liilriirft QV Cert.. fblpcwt\figl&..dllg r-z z u /1 CUNESTREET \ MW..Q~ X I X \ \ 1 1 I \ \ MW-2# POINT OF COMPLIANCE WELL LOCATION NOTE: -CONCENTRATIONS IN RED EXCEED APPLICABLE PCL LIMITS. - MW-4 AND MW-24 ARE UTILIZED AS A POC WELLS FOR PMZ 2 AND AMP WELLS FOR PMZ 1. - MW-28 AND MW-29 ARE UTILIZED AS A POC WELLS FOR PMZ 1. - MW-26 AND MW-27 ARE UTILIZED AS A POC WELLS FOR PMZ 3. l~ l~ l l l MW-1 # MW-1~ MW-1 # -$- 10/18/ 10 \ t.~w.os-+ ATTENUATION MONITORING POINT WELL LOCATION PLUME MANAGEMENT ZONE BOUNDARY BaP <0.000080 Mn 1.68/1 27 Mo O 123/ 0.103 \ BAERSTREET + Mno-:-460To.348 Mo 0 543 /0 520 \ MONITORING WELL LOCATION CHAIN-LINK FENCE PMZ-2 I ~ DATE: - - .s;c •·- ·-UN ·, FIRST --· rti:VI:ii 2 SECOND REVISION THIRD REVISION 3 NO liREFS AlW:HED OCToBER2011. rJasNci: 39004-0003 [-SCAlE. AS SHOWN J ORAWNBY: - - • , ... , -u ·-JCS 1 CHECKED BY. APPRCM:DBY JFS JFIM FIGURE: 16 LEGEND SUBJECT PROPERTY BOUNDARY 02/02/11 BaP <0.00008 Mn 0.245 I 0.240 Mo 577 /591 0 1131/11 Mn 0.178 I 0.172 o 0.00135 J I 0.00156 J --x--x-MW-21 ~I • L- \ NANCE STREET '\ I 1 -+MW-12 \ >< \i XI ; I~ MW-1# PMZ-1 \ MW-19 -+ \ MW-23 \ \ \ ~rN-1~ X I f NOTE: -CONCENTRATiONS IN RED EXCEED APPLICABLE PCL LIMITS. - MW-4 AND MW-24 ARE UTILIZED AS A POC WELLS FOR PMZ 2 AND AMP WEUS FOR PMZ 1. - MW-28 AND MW-29 ARE UTILIZED AS A POC WELLS FOR PMZ 1. - MW-26 AND MW-27 ARE UTILIZED AS A POC WELLS FOR PMZ 3. 0 X \ 75 ~ 150 I br-N SICAlE: ,._150' CUNESTREET \ X \ \ MW-1 # \ 1 MANGANESE PCLE ZONE I \ \ MW-2# 1/ /7 71 l l MW-1~ \ MW-1 # MOLYBDENUM PCLE ZONE _j \ MW-1~ \ u-.v.os- + rz=u/) 02/02/1 1 Mn 0 .17710.179 Mo 0 659 I 0 .330 \ BAERSTREET POINT OF COMPLIANCE WELL LOCATION PLUME MANAGEMENT ZONE BOUNDARY PMZ-3 ~IW~ - -$- AITENUATION MONITORING POINT WELL LOCATION CHAIN-LINK FENCE PMZ-2 MoM,. } MONITORING WELL LOCATION • "" \ + MW-Oh MW-Olt \ 01/3 1111 Mn 0.00330 I <0.00080 Mo 0.0758 I 0.0173 \ ,.,.&"'~ s. \ ~.~ \ \ SKA CONSULTJNG, L.P. 1515 WITTE ROAD, SUITE 150 HOUSTON, TEXAS 77080 Texas Registered Engineering Firm F-()()5009 Texas Registered Geoscience F'IITil 50011 CONSTITUENT CONCENTRATION MAP SfXTH QUARTERLY MONITORING EVENT -x----. MDI SUPERFUND SITE OPERABLE UNIT 1 361 7 BAER STREET HOUSTON, HARRIS COUNTY, TEXAS 17 Attachment 6 Applicable 0r Relevant and Appropriate Requirements (ARARs) SUMMARY OF ARARS REVIEW – MANY DIVERSIFIED INTERESTS SUPERFUND SITE FIVE YEAR REVIEW ARAR/TBC Citation or Reference Requirements Applicability Comments and Analysis Reference is current and the listed regulatory residual lead concentration remains at 500 mg/kg as of the issuance of this report. Reference is current and procedures employed at the site listed are consistent with those in the regulation. Texas Risk Reduction Rule Lead: 30 TAC 350. Residual lead concentrations in soils to be below 500 mg/kg. Management of Wastes from UST releases NAPL/PAHs: 30 TAC 334 Subchapter D and 30 TAC 334.55 Corrective action procedures and the management of wastes from UST releases and the permanent removal form service of abandoned USTs (Non-CERCLA). Applicable National Primary Drinking Water Standards for PAHs 40 CFR Part 141 PAHs below MCLs; water quality measured at former waste location and downgradient to assess MNA. Applicable Reference is current and the listed regulatory PAH (benzo (a) pyrene) concentration remains at 0.20 μg/L as of the issuance of this report. Floodplain or Wetland Environments Executive Order 11988 and 11990 NA at MDI Site; site is not within floodplain or wetlands. Not Applicable This regulation was determined to be not applicable in the remedial design. The remedial design listed 40 CFR Part 6 which is part of the National Environmental Policy Act evaluation process. The regulatory requirement for the protection of floodplains and wetlands is Executive Order 11988 and 11990 and has been added for reference. Endangered Species Act 16 USC 1531 50 CFR 402 NA at MDI Site; no endangered species present. Not Applicable This regulation was determined to be not applicable in the remedial design. The remedial design did not list a regulation. The regulatory requirement for the protection of endangered species is 16 USC 1531 (50 CFR 402) which has been added for reference. National Historic Preservation Act (16 USC 470) Section 106 et. Seq. 36 CFR 800 NA at MDI Site; no historic structures present. Not Applicable This regulation was determined to be not applicable in the remedial design. The remedial design did not list a regulation. The regulatory requirement for the protection of historic sites is (16 USC 470) Section 106 et. Seq. 36 CFR 800 which has been added for reference. National Emission Standards 40 CFR Part 61, Subpart M, designates National Emission Standards for asbestos as defined as a hazardous air pollutant. Emissions standards for asbestos and establishes procedures for asbestos emission control during demolition and renovation activities. Applicable Reference is current and procedures employed at the site listed are consistent with those in the regulation. Applicable SUMMARY OF ARARS REVIEW – MANY DIVERSIFIED INTERESTS SUPERFUND SITE FIVE YEAR REVIEW (CONTINUED) ARAR/TBC Citation or Reference Requirements Applicability Comments and Analysis 40 CFR Part 261 Wastes for offsite disposal to be tested using TCLP prior to disposal Applicable Reference is current and procedures employed at the site listed are consistent with those in the regulation. Standards Applicable to Generators of Hazardous Waste 40 CFR Part 262 and 30 TAC 335.61 through 70 RCRA and Texas standards for the identification and manifesting of hazardous wastes. Applicable Reference is current and procedures employed at the site listed are consistent with those in the regulation. Land Disposal Restrictions 40 CFR Part 268 Requirements for offsite disposal of wastes to be tested via TCLP prior to disposal at a permitted landfill. Applicable Reference is current and procedures employed at the site listed are consistent with those in the regulation. UST Removal 40 CFR Part 280, 30 TAC 334. Subtitles C and D Requirements for UST removal and the management and disposal of related wastes. Applicable Reference is current and procedures employed at the site listed are consistent with those in the regulation. Procedures for Planning and Implementing Offsite Response Actions 40 CFR Part 300 Section 400 CERCLA wastes will be disposed of off- site at facilities in compliance with off-site rule provisions. Applicable The current citation for this requirement is 40 CFR 300.440, however the requirements list under this reference are consistent with those employed at the site Disposal Requirements–PCBs 40 CFR Part 761.60 Wastewater containing PCBs to be disposed of at a permitted facility. Applicable Reference is current and procedures employed at the site listed are consistent with those in the regulation. USDOT Regulations for Transport of Hazardous Materials 49 CFR Parts 171 and 172 Applicable Reference is current and procedures employed at the site listed are consistent with those in the regulation. Visible and Particulate Emission Standards 30 TAC 111.145 Hazardous materials to be transported offsite will be labeled and placarded according to the regulations; contractors to provide proper documentation. Requirements for visible emission standard during construction. Applicable Reference is current and procedures employed at the site listed are consistent with those in the regulation. Permit by Rule for Air Emissions during Remedial Activities 30 TAC 106.533 Requirements for fugitive dust controls excavation. Applicable Reference is current and procedures employed at the site listed are consistent with those in the regulation. Identification and Listing of Hazardous Waste SUMMARY OF ARARS REVIEW – MANY DIVERSIFIED INTERESTS SUPERFUND SITE FIVE YEAR REVIEW (CONTINUED) ARAR/TBC Management for Erosion, Sediment and Stormwater Controls Citation or Reference TPDES Construction General Permit, Permit No. TXR150000 Requirements Applicability Comments and Analysis Substantive provisions will be met through implementation of construction runoff controls. Applicable Reference is current and procedures employed at the site listed are consistent with those in the regulation. Waste Classification – Establishes procedures for testing and classifying waste for disposal 30 TAC 335R Wastes to be disposed of offsite will be tested and classified for offsite disposal according to State requirements. Applicable Reference is current and procedures employed at the site listed are consistent with those in the regulation. Industrial Solid Waste and Municipal Hazardous Waste, Subchapter O, Land Disposal Restrictions 30 TAC 335.431 – Will meet as detailed in RCRA 40 CFR. Applicable Reference is current and procedures employed at the site listed are consistent with those in the regulation. Relocation of Soils Containing Chemicals of Concern for Reuse Purposes 30 TAC 350.36 Requirements for the reuse of COC impacted soil excavated from the Site. Not applicable This regulation was determined to be not applicable in the remedial design. Notes: ARAR CERCLA CFR COC MCL MDI Mg/kg MNA NA NAPL PAH Applicable or Relevant and Appropriate Requirement Comprehensive Environmental Response Compensation and Liability Act Code of Federal Regulations Chemical of Concern Maximum Contaminant Limit Many Diversified Interests, Inc. Milligram per kilogram Monitored natural attenuation Not applicable Non-aqueous phase liquid Polycyclic aromatic hydrocarbon PCB RCRA TAC TBC TCLP TPDES USDOT UST Polychlorinated biphenyl Resource Conservation and Recovery Act Texas Administrative Code To be considered Toxicity Characteristic Leaching Procedure Texas Pollutant Discharge Elimination System U.S. Department of Transportation Underground storage tank Attachment 7 Site Inspection Checklist FIVE-YEAR REVIEW SITE VISIT CHECKLIST I. SITE INFORMATION Site Name: Many Diversified Interests, Inc. Superfund Site Date of Inspection: November 3, 2011 Location and Region: Houston, Harris County, Texas; EPA ID: TXD008083404 EPA Region 6 Agency, office, or company leading the five-year review: EPA Region 6 Weather/temperature: Cool and partly cloudy/65 F Remedy Includes: (Check all that apply) Landfill cover/containment Access controls Institutional controls Groundwater pump and treatment Monitored Natural Attenuation Groundwater containment Vertical barrier walls Surface water collection and treatment Other: Excavate and offsite disposal, and backfill.___________________________________ Attachments: Inspection team roster attached Site map attached (See Attachment 1) II. INTERVIEWS (Check all that apply) 1. O&M Site Manager at site Interviewed: Problems, suggestions: 2. O&M Staff Interviewed: at site Problems, suggestions: Scott Leafe (SKA) Name President/Managing Partner November 11, 2011 Title Date at office by phone Report attached Janet Meaux Name Phone no. 713-266-6056 Project Manager Title at office by phone Report attached 1 November 3, 2011 Date Phone no. 713-266-6056 3. Local regulatory authorities and response agencies (i.e.; State and Tribal offices, emergency response office, police department, office of public health or environmental health, zoning office, recorder of deeds, or other city and county offices, etc.). Fill in all that apply. Agency TCEQ Contact Phillip Winsor Name Problems, suggestions: Agency Superfund Section/ Remediation Division Title Report attached November 21, 2011 Date 512-239-1054 Phone no. EPA Contact __ Rafael Casanova Remedial Project Manager November 3, 2011 Name Title Date Report attached Problems, suggestions: 214-665-7437 Phone no. Agency Contact Name Problems, suggestions: 4. Other interviews (optional): Title Report attached Date Reports attached to Five-Year Review Report John Jennings, Project Manager for Frank M. Liu of Clinton Gregg Investments, Ltd. 2 __________ Phone no. III. ON-SITE DOCUMENTS & RECORDS VERIFIED (Check all that apply) 1. O&M Documents O&M manual Readily available Up to date N/A As-built drawings Readily available Up to date N/A Maintenance logs Readily available Up to date N/A Remarks________________________________________________ ______ 2. Site-Specific Health and Safety Plan Readily available Up to date N/A Contingency plan/emergency response plan Readily available Up to date N/A Remarks_________________________________________________ ______ 3. O&M and OSHA Training Record Readily available Up to date N/A Remarks_________________________________________________ ______ 4. Permits and Service Agreements Air discharge permit Readily available Up to date N/A Effluent discharge Readily available Up to date N/A Waste disposal, POTW Readily available Up to date N/A Other permits______ Readily available Up to date N/A Remarks___________________________No onsite facility or building______ 5. Gas Generation Records Readily available Up to date N/A Remarks___________________________No onsite facility or building______ 6. Settlement Monument Records Readily available Up to date N/A Remarks___________________________No onsite facility or building______ 7. Groundwater Monitoring Records Readily available Up to date N/A Remarks________________________________________________________ 8. Leachate Extraction Records Readily available Up to date N/A Remarks___________________________No onsite facility or building______ 9. Discharge Compliance Records Air Readily available Up to date N/A Water (effluent) Readily available Up to date N/A Remarks___________________________No onsite facility or building______ 10. Daily Access/Security Logs Readily available Up to date Remarks___________________________No onsite facility or building______ 3 N/A IV. O&M COSTS 1. O&M Organization State in-house Contractor for State PRP in-house Contractor for PRP Federal Facility in-house Contractor for Federal Facility Other: Clinton Gregg Investments, Ltd. has retained a contractor (SKA Consulting, L.P.) to perform O&M activities, which include inspection and maintenance of the soil remedy and groundwater monitoring in accordance with the ground water remedy selected in the Record Of Decision for OU1. 2. O&M Cost Records Readily available Up to date Funding mechanism/agreement in place Other: O&M cost records were not provided during this five year review. Original O&M cost estimate $220,000 Breakdown attached Total annual cost by year for review period if available From__________ To__________ Date Date From__________ To__________ Date Date From__________ To__________ Date Date From__________ To__________ Date Date From__________ To__________ Date 3. Date __________________ Breakdown attached Total cost __________________ Breakdown attached Total cost __________________ Breakdown attached Total cost __________________ Breakdown attached Total cost __________________ Breakdown attached Total cost Unanticipated or Unusually High O&M Costs During Review Period Describe costs and reasons: _______N/A______________________________________________ _________________________________________________________________________________ _________________________________________________________________________________ _________________________________________________________________________________ V. ACCESS AND INSTITUTIONAL CONTROLS Applicable N/A A. Fencing 1. Fencing damaged Remarks: Location shown on site map (See Attachment 1) Gates secured N/A The chain linked fence is damaged/broken in three locations on the west end of the Site. B. Other Access Restrictions 4 1. Location shown on site map Signs and other security measures N/A Remarks: Identification/Warning Sign w/ contact numbers located on front of gated compound. Another Identification/Warning Sign found on the ground within the fenced area and needs to be reinstalled on the fence. C. Institutional Controls 1. Implementation and enforcement Site conditions imply ICs not properly implemented Yes No N/A Site conditions imply ICs not being fully enforced Yes No N/A Type of monitoring (e.g., self-reporting, drive by) Frequency Drive by inspection Every two weeks Responsible party/agency Clinton Gregg Investments, Inc./SKA Consulting, L.P. Contact John Jennings Name Project Manager for Frank M. Liu Title Contact Scott Leafe Name President/Managing Partner (SKA) Title 713-964-8182 Phone no. 713-266-6056 Phone no. Reporting is up-to-date Yes No N/A Reports are verified by the lead agency Yes No N/A Yes Specific requirements in deed or decision documents have been met Yes No No N/A ICs are inadequate N/A Violations have been reported N/A Report attached Other problems or suggestions: Soil ICs have not been implemented as specified in ROD. 2. Adequacy ICs are adequate Remarks: An IC, such as a deed notice, should be implemented for soil, as required by the ROD. D. General 1. Vandalism/trespassing Location shown on site map No vandalism evident Remarks: There is evidence of dumping onsite. Piles of trash, soil, wood construction debris, and roof shingles were observed during the Site inspection. 5-gallon bucks full of liquid (possibly rain water) were found disposed of onsite. 2. Land use changes onsite Remarks: 3. None Land use changes offsite Remarks: N/A N/A None VI. GENERAL SITE CONDITIONS A. Roads 1. Applicable Roads damaged Remarks: N/A Location shown on site map _______ 5 Roads adequate N/A B. Other Site Conditions Remarks: Vegetation (grass) on Site is maintained well. With the exception of onsite dumping and locations with damaged fencing, the Site is in good condition. Applicable VII. LANDFILL COVERS A. Landfill Surface 1. Settlement (Low spots) Location shown on site map N/A Settlement not evident Depth Areal extent Remarks: 2. Cracks Lengths Remarks: Location shown on site map Widths 3. Erosion Areal extent Remarks: Location shown on site map Holes Areal extent Remarks: Location shown on site map 4. Cracking not evident Depths Erosion not evident Depth Holes not evident Depth 5. Vegetative Cover Grass Cover properly established Trees/Shrubs (indicate size and locations on a diagram) Remarks: 6. Alternative Cover (armored rock, concrete, etc.) Remarks: 7. Bulges Areal extent Remarks: 8. Wet Areas/Water Damage Wet areas Ponding Seeps Soft subgrade Remarks: 9. No signs of stress N/A Location shown on site map Bulges not evident Depth Wet areas/water damage not evident Location shown on site map Location shown on site map Location shown on site map Location shown on site map Slope Instability Slides No evidence of slope instability Areal extent Remarks: Areal extent Areal extent Areal extent Areal extent Location shown on site map Applicable N/A B. Benches (Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in 6 order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.) Location shown on site map N/A or okay 1. Flows Bypass Bench Remarks: 2. Bench Breached Remarks: Location shown on site map N/A or okay 3. Bench Overtopped Remarks: Location shown on site map N/A or okay C. Letdown Channels Applicable N/A (Channel lined with erosion control mats, rip rap, grout bags, or gabions that descend down the steep side slope of the cover and will allow the runoff water collected by the benches to move off of the landfill cover without creating erosion gullies.) 1. Settlement Areal extent Remarks: Location shown on site map Depth No evidence of settlement 2. Material Degradation Material type Remarks: Location shown on site map Areal extent No evidence of degradation 3. Erosion Areal extent Remarks: Location shown on site map Depth No evidence of erosion 4. Undercutting Areal extent Remarks: Location shown on site map Depth No evidence of undercutting 5. Obstructions No obstructions Location shown on site map Type Areal extent Remarks: Size Excessive Vegetative Growth Type No evidence of excessive growth Vegetation in channels does not obstruct flow Location shown on site map Areal extent Remarks: D. Cover Penetrations Applicable N/A 1. Gas Vents Active Passive Properly secured/locked Functioning Routinely sampled Good condition Evidence of leakage at penetration Needs O&M N/A Remarks: 6. 2. 3. 4. Gas Monitoring Probes Properly secured/locked Functioning Evidence of leakage at penetration Remarks: Monitoring Wells (within surface area of landfill) Evidence of leakage at penetration Remarks: Leachate Extraction Wells Properly secured/locked Functioning 7 Routinely sampled Needs O&M Good condition N/A Needs O&M N/A Routinely sampled Good condition Evidence of leakage at penetration Needs O&M Remarks: 5. Settlement Monuments Located Routinely surveyed Remarks: E. Gas Collection and Treatment Applicable N/A N/A N/A 1. Gas Treatment Facilities Flaring Thermal destruction Collection for reuse Good condition Needs O&M Remarks: 2. Gas Collection Wells, Manifolds, and Piping Good condition Needs O&M Remarks: 3. Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings) Good condition Needs O&M N/A Remarks: F. Cover Drainage Layer Applicable N/A 1. Outlet Pipes Inspected Functioning N/A Remarks: 2. Outlet Rock Inspected Functioning N/A Remarks: G. Detention/Sedimentation Ponds Applicable 1. Siltation Areal extent N/A Siltation not evident Remarks: N/A Size Areal extent Erosion not evident Depth 2. Erosion N/A Remarks: 3. Outlet Works Remarks: Functioning N/A 4. Dam Remarks: Functioning N/A H. Retaining Walls 1. Deformations Horizontal displacement Rotational displacement Remarks: Applicable N/A Location shown on site map Deformation not evident Vertical displacement 2. Degradation Remarks: Location shown on site map I. 1. Perimeter Ditches/Off-Site Discharge Applicable Siltation Location shown on site map Depth Areal extent Remarks: 2. Vegetative Growth Vegetation does not impede flow Location shown on site map 8 Degradation not evident N/A Siltation not evident N/A Areal extent Remarks: Type 3. Erosion Areal extent Remarks: Location shown on site map Depth Erosion not evident 4. Discharge Structure Remarks: Functioning N/A 1. VIII. VERTICAL BARRIER WALLS Applicable Settlement Location shown on site map Areal extent Depth N/A Settlement not evident Remarks: . IX. GROUNDWATER/SURFACE WATER REMEDIES A. Groundwater Extraction Wells, Pumps, and Pipelines 1. Pumps, Wellhead Plumbing, and Electrical Good condition All required wells located Applicable Applicable Needs O&M N/A N/A N/A Remarks: 2. Extraction System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs O&M Remarks: 3. Spare Parts and Equipment Readily available Good condition Remarks: Requires upgrade B. Surface Water Collection Structures, Pumps, and Pipelines 1. Collection Structures, Pumps, and Electrical Good condition Needs O&M Remarks: Needs to be provided Applicable 2. Surface Water Collection System Pipelines, Valves, Valve Boxes, and Other Appurtenances Good condition Needs O&M Remarks: 3. Spare Parts and Equipment Readily available Good condition Remarks: Requires upgrade 9 N/A Needs to be provided Applicable N/A C. Treatment System 1. Treatment Train (Check components that apply) Metals removal Oil/water separation Air stripping Carbon absorbers Filters Additive (e.g., chelation agent, flocculent) Others Good condition Needs O&M Sampling ports properly marked and functional Sampling/maintenance log displayed and up to date Equipment properly identified Quantity of groundwater treated annually Bioremediation ________________________________ ___________________ Quantity of surface water treated annually Remarks: _________ 2. Electrical Enclosures and Panels (Properly rated and functional) N/A Good condition Needs O&M Remarks: ___________________________________________________________________________ 3. Tanks, Vaults, Storage Vessels N/A Good condition Remarks: 4. Discharge Structure and Appurtenances N/A Good condition Proper secondary containment Needs O&M Needs O&M Remarks: 5. Treatment Building(s) N/A Good condition (esp. roof and doorways) Chemicals and equipment properly stored Needs repair Remarks: 6. Monitoring Wells (Pump and treatment remedy) Properly secured/locked Functioning Routinely sampled All required wells located Needs O&M Remarks: Good condition N/A D. Monitoring Data Applicable N/A 1. Monitoring Data Is routinely submitted on time Is of acceptable quality: Quality of data is unknown 2. Monitoring Data Suggests: Groundwater plume is effectively contained Contaminant concentrations are declining D. Monitored Natural Attenuation 1. Applicable N/A Monitoring Wells (Pump and treatment remedy) Properly secured/locked Functioning Routinely sampled Good condition All required wells located Needs O&M N/A Remarks: Two damaged wells, MW-17 and MW-19, are scheduled to be plugged and abanadoned and are not required for monitoring purposes. X. OTHER REMEDIES If there are remedies applied at the site that are not covered above, attach an inspection sheet describing the physical nature and condition of any facility associated with the remedy. An example would be soil vapor 10 extraction. XI. OVERALL OBSERVATIONS A. Implementation of the Remedy Describe issues and observations relating to whether the remedy is effective and functioning as designed. Begin with a brief statement of what the remedy is to accomplish (i.e., to contain contaminant plume, minimize infiltration and gas emission, etc.). The construction activities related to the soil remedy identified in the ROD were complete and approved on December 12, 2008. The part of the soil remedy requiring an institutional control (IC) to prevent exposure to contaminated soils above acceptable levels is still incomplete. The groundwater remedy identified in the ROD is monitored natural attenuation and ICs. To support the evaluation of MNA, ground water sampling events are performed periodically and the appropriate parameters are analyzed. A restrictive covenant, filed on May 19, 2010, is in place to prevent exposure to contaminated groundwater. No violations of this restrictive covenant were observed during the Site inspection. B. Adequacy of O&M Good. The O&M consists of periodic inspections and maintenance of the soil remedy and the monitoring of ground water to demonstrate MNA. Both of these components of the O&M are being performed as identified in the ROD. C. Early Indicators of Potential Remedy Failure None. D. Opportunities for Optimization Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy. A reduction in the frequency of monitoring was requested by SKA Consulting, L.P. on behalf of Gregg Clinton Investments, Ltd. Implementation of this reduction in monitoring will reduce costs. 11 Attachment 8 Site Inspection Photographs First Five-Year Review Report Many Diversified Interests, Inc. Superfund Site _________________________________________________________________________________________________________December 2011 Photograph 1 November 3, 2011 Description: MW-02 facing northeast Photograph 2 November 3, 2011 Description: Investigative-Derived Waste (IDW) drum near MW-02 Photograph 3 November 3, 2011 Description: Close-up of IDW drum label Photograph 4 November 3, 2011 Description: MW-03R facing west Page 1 of 13 First Five-Year Review Report Many Diversified Interests, Inc. Superfund Site _________________________________________________________________________________________________________December 2011 Photograph 5 November 3, 2011 Description: View to west from MW-03R Photograph 7 November 3, 2011 Description: MW-24 facing north Photograph 6 November 3, 2011 Description: MW-25 facing north Photograph 8 November 3, 2011 Description: MW-26 facing north Page 2 of 13 First Five-Year Review Report Many Diversified Interests, Inc. Superfund Site _________________________________________________________________________________________________________December 2011 Photograph 9 November 3, 2011 Description: View to the east from MW-26 Photograph 10 November 3, 2011 Description: View to the southeast from MW-26 Photograph 11 November 3, 2011 Description: View to the south from MW-26 Photograph 12 November 3, 2011 Description: View to the southwest from MW-26 Page 3 of 13 First Five-Year Review Report Many Diversified Interests, Inc. Superfund Site _________________________________________________________________________________________________________December 2011 Photograph 13 November 3, 2011 Description: View to the west from MW-26 Photograph 15 November 3, 2011 Description: MW-04 facing west Photograph 14 November 3, 2011 Description: Former North Pond (view from MW-04) Photograph 16 November 3, 2011 Description: Former sump southwest of MW-25 Page 4 of 13 First Five-Year Review Report Many Diversified Interests, Inc. Superfund Site _________________________________________________________________________________________________________December 2011 Photograph 17 November 3, 2011 Description: MW-06 facing west Photograph 18 November 3, 2011 Description: MW-09 facing south Photograph 19 November 3, 2011 Description: View to west from MW-09 Photograph 20 November 3, 2011 Description: View to northwest from MW-26 Page 5 of 13 First Five-Year Review Report Many Diversified Interests, Inc. Superfund Site _________________________________________________________________________________________________________December 2011 Photograph 21 November 3, 2011 Description: MW-08 facing north Photograph 23 November 3, 2011 Description: MW-23 facing north Photograph 22 November 3, 2011 Description: MW-08 facing south Photograph 24 November 3, 2011 Description: MW-15 facing north Page 6 of 13 First Five-Year Review Report Many Diversified Interests, Inc. Superfund Site _________________________________________________________________________________________________________December 2011 Photograph 25 November 3, 2011 Description: MW-16 facing north Photograph 26 November 3, 2011 Description: MW-17 (damaged monitoring well) facing north Photograph 27 November 3, 2011 Description: MW-07 facing northwest Photograph 28 November 3, 2011 Description: MW-19 (damaged monitoring well) facing south Page 7 of 13 First Five-Year Review Report Many Diversified Interests, Inc. Superfund Site _________________________________________________________________________________________________________December 2011 Photograph 29 November 3, 2011 Description: MW-10 Photograph 30 November 3, 2011 Description: Paint buckets dumped onsite near Gillespie St gate Photograph 31 November 3, 2011 Description: Wood construction debris dumped onsite near Gillespie St. gate Photograph 32 November 3, 2011 Description: Damaged west gate at Gillespie St. Page 8 of 13 First Five-Year Review Report Many Diversified Interests, Inc. Superfund Site _________________________________________________________________________________________________________December 2011 Photograph 33 November 3, 2011 Description: MW-05 facing west Photograph 34 November 3, 2011 Description: Damaged west gate at Baer St. Photograph 35 November 3, 2011 Description: Damaged fence between Baer St. and Nance St. Photograph 36 November 3, 2011 Description: MW-12 facing northwest Page 9 of 13 First Five-Year Review Report Many Diversified Interests, Inc. Superfund Site _________________________________________________________________________________________________________December 2011 Photograph 37 November 3, 2011 Description: MW-22 facing south Photograph 39 November 3, 2011 Description: MW-13 facing east Photograph 38 November 3, 2011 Description: MW-14 facing west Photograph 40 November 3, 2011 Description: Roof shingles dumped onsite near Hare St. front gate Page 10 of 13 First Five-Year Review Report Many Diversified Interests, Inc. Superfund Site _________________________________________________________________________________________________________December 2011 Photograph 41 November 3, 2011 Description: MW-18 facing east Photograph 43 November 3, 2011 Description: MW-21 facing west Photograph 42 November 3, 2011 Description: MW-20R facing west Photograph 44 November 3, 2011 Description: MW-01 facing west Page 11 of 13 First Five-Year Review Report Many Diversified Interests, Inc. Superfund Site _________________________________________________________________________________________________________December 2011 Photograph 45 November 3, 2011 Description: MW-29 (missing well vault lid) Photograph 46 November 3, 2011 Description: MW-27 Photograph 47 November 3, 2011 Description: MW-28 Photograph 48 November 3, 2011 Description: Front gate facing south Page 12 of 13 First Five-Year Review Report Many Diversified Interests, Inc. Superfund Site _________________________________________________________________________________________________________December 2011 Photograph 49 November 3, 2011 Description: Soil piles dumped onsite near Gillespie St. gate Photograph 50 November 3, 2011 Description: Trash pile dumped onsite near Gillespie St. gate Photograph 51 November 3, 2011 Description: Site sign posted on fence Page 13 of 13 Attachment 9 Interview Records SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: 11/03/11 Contact Made By: Name: Rafael Casanova Title: Remedial Project Manager Organization: U.S. EPA Telephone No.: (214) 665-7437 E-Mail: Casanova.Rafael@ epa.gov Street Address: 1445 Ross Avenue, Suite 1200 City, State, Zip: Dallas, Texas 75202 Name: Stan Wallace Title: Project Manager Telephone No.: (972) 315-3922 E-Mail: swallace@eaest.com Street Address: 405 S. Highway 121, Building C, Suite 100 City, State, Zip: Lewisville, Texas 75067 Organization: EA Engineering, Science, and Technology, Inc. Individual Contacted: Name: Rafael Casanova Title: Remedial Project Manager Organization: U.S. EPA Telephone No.: (214) 665 7437 E-Mail Address: casanova.rafael@epa.gov Street Address:1445 Ross Avenue, Suite 1200 City, State, Zip: Dallas, Tx, 75202 Survey Questions The purpose of the five-year review is to evaluate the implementation and performance of the remedy, and to confirm that human health and the environment continue to be protected by the remedial actions that have been performed at the site. This interview is being conducted as a part of the first five-year review for the Many Diversified Interests, Inc. Superfund Site. The scope of the review is from June 2007 to present. 1. What is your general impression of the work conducted at the site during this review period? The work meets the requirements of the EPA’s Record of Decision and the “Agreed Order on Consent for Remedial Design/Remedial Action” entered upon by the EPA and the purchaser of the Site. Page 1 of 5 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: 11/03/11 2. From your perspective, what effects have site operations had on the surrounding community? The cleanup of the Site has provided the purchaser with opportunities for the redevelopment of the Site for industrial/residential uses. Survey Questions (Continued) 3. During this review period, are you aware of any community concerns regarding the site or its operation and administration? No. If so, please provide details. 4. Are you aware of any events, incidents, or activities at the site during this review period, such as vandalism, trespassing, or emergency responses from local authorities? No. If so, please provide details. 5. Do you feel well informed about the site’s activities and progress? Yes. If not, please indicate how you would like to be informed about the site activities – for example, by e-mail, regular mail, fact sheets, meetings, etc. Page 2 of 5 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: 11/03/11 6. Do you have any comments, suggestions, or recommendations regarding the site’s management or operation? No. Survey Questions (Continued) 7. Have there been routine communications or activities (site visits, inspections, reporting activities, etc.) conducted by your office regarding the site? Yes. If so, please describe the purpose and results. This site inspection was performed as a part of the Five-Year Review process. 8. Have there been any complaints, violations, or other incidents related to the site that required a response by your office? No. If so, please summarize the events and results. 9. Are you aware of any problems or difficulties encountered which impacted the effectiveness of the remedial action or caused a change in operation and maintenance procedures? No. If so, please describe changes and impacts. Page 3 of 5 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: 11/03/11 10. Have there been any changes in state or federal environmental standards which may call into question the protectiveness or effectiveness of the remedial action? None that I am aware of. Survey Questions (Continued) 11. Do you know of opportunities to optimize the operation, maintenance, or sampling efforts at the site? No. Page 4 of 5 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: 11/03/11 Please add any other comments in the space below. This survey was filled as a result of my participation during the Five-Year Review site inspection and recent appointment as the EPA’s Remedial Project Manager for the Site. Page 5 of 5 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: NOll.. t 2ot/ Contact Made By: Name: Rafael Casanova Title: Remedial Project Manager Telephone No.: (214) 665-7437 E-Mail: Casanova.Rafael@ epa.gov Street Address: 1445 Ross Avenue, Suite 1200 City, State, Zip: Dallas, Texas 75202 Name: Stan Wallace Title: Project Manager Telephone No.: (972) 315-3922 E-Mail: swallace@eaest.com Street Address: 405 S. Highway 121, Building C, Suite 100 City, State, Zip: Lewisville, Texas 75067 Organization: U.S. EPA Organization: EA Engineering, Science, and Technology, Inc. Individual Contacted: Name: John Jennings ~,.L Title: p 1' y or Frank M. Liu Telephone No.: (713) 964-8182 E-Mail Address: Street Address: 1520 Oliver Street City, State, Zip: Houston, TX 77007 5 I:J;, ,,, I Organization: Lovett Comm. Survey Questions "' The purpose of the five-year review is to evaluate the implementation and performance of the remedy, and to confirm that human health and the environment continue to be protected by the remedial actions that have been performed at the site. This interview is being conducted as a part of the first five-year review for the Many Diversified Interests, Inc. Superfund Site. Should you choose to respond, please return your survey form to Stan Wallace at EA Engineering, Science, and Technology, Inc. via e-mail or U.S. Postal Service by 14 November 2011. The scope of the review is from June 2007 to present. 1. What is your general impression of the work conducted at the site during this review period? 5i!fiMS 2. 1o ~~ 7/J()/ZC>lJG,fo/ ~: flz.o~SSitJne I From your perspective, what effects have site operations had on the surrounding community? Ir H//-$ HAD lo•k., ~ No AoveasE L.r /36T7"t!:A ~ E-4fec7S Jf/IND rHe ~u"' c. EATA I,~ '1 C!Lti.Ane~. f'l..t"C.. Page 1 of4 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site N arne: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: Survey Questions (Continued) 3. During this review period, are you aware of any community concerns regarding the site or its operation and administration? If so, please provide details. 4. Are you aware of any events, incidents, or activities at the site during this review period, such as vandalism, trespassing, or emergency responses from local authorities? If so, please provide details. ;.Jo c17J&Ge/J~ /26-S,DD'I~~s. r/l,e Sf' A$$' n 0? /2emo"~f) 2'. llt'O {/1-E/U. //lA$!1 i)vMp4 &;~· Srrt ~r•An ~s 8£6--'t/ SoN£ VA,dAUS#I $tJMC Pt!!!'fnCt!S HAviS /;:tlllln c,..,E:/l.5 s.· I34~AI SftJL&n. 5. Do you feel well informed about the site's activities and progress? If not, please indicate how you would like to be informed about the site activities - for example, by e-mail, regular mail, fact sheets, meetings, etc. YEs 6. Do you have any comments, suggestions, or recommendations regarding the site's management or operation? Page 2 of4 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: Survey Questions (Continued) 7. Have there been routine communications or activities (site visits, inspections, reporting activities, etc.) conducted by your office regarding the site? If so, please describe the purpose and results. We f:to Br · '11-11£ s, rG /E'l6t'l.c., , ..,-uJO c.cJ e E1t- S 1?J , AJ :Spt5 c 7 ~ ~IE6 p ~,'""'s ~sre~'~ M"d Ftmc4- /2d?.A?,es /IZI£SpA ~.S r, 'TIZ/JSII (!. t. ($-/II?_. "p . 8. Have there been any complaints, violations, or other incidents related to the site that required a response by your office? If so, please summarize the events and results. 9. Are you aware of any problems or difficulties encountered which impacted the effectiveness of the remedial action or caused a change in operation and maintenance procedures? If so, please describe changes and impacts. 10. Have there been any changes in state or federal environmental standards which may call into question the protectiveness or effectiveness of the remedial action? Page 3 of4 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified I;nterests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: Survey Questions (Continued) 11. Do you know of opportunities to optimize the operation, maintenance, or sampling efforts at the site? No Please add any other comments in the space below. Page 4 of4 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: 11-11-11 Contact Made By: Name: Rafael Casanova Title: Remedial Project Manager Organization: U.S. EPA Telephone No.: (214) 665-7437 E-Mail: Casanova.Rafael@ epa.gov Street Address: 1445 Ross Avenue, Suite 1200 City, State, Zip: Dallas, Texas 75202 Name: Stan Wallace Title: Project Manager Telephone No.: (972) 315-3922 E-Mail: swallace@eaest.com Street Address: 405 S. Highway 121, Building C, Suite 100 City, State, Zip: Lewisville, Texas 75067 Organization: EA Engineering, Science, and Technology, Inc. Individual Contacted: Name: Scott Leafe Title: President/Managing Partner Organization: SKA Consulting, L.P. Telephone No.: (713) 266-6056 E-Mail Address: scott.leafe@skaconsulting.com Street Address: 1515 Witte Rd., St. 150 City, State, Zip: Houston, TX 77080 Survey Questions The purpose of the five-year review is to evaluate the implementation and performance of the remedy, and to confirm that human health and the environment continue to be protected by the remedial actions that have been performed at the site. This interview is being conducted as a part of the first five-year review for the Many Diversified Interests, Inc. Superfund Site. Should you choose to respond, please return your survey form to Stan Wallace at EA Engineering, Science, and Technology, Inc. via e-mail or U.S. Postal Service by 14 November 2011. The scope of the review is from June 2007 to present. 1. What is your general impression of the work conducted at the site during this review period? All work conducted during the past five years has effectively reduced or removed potential risks to human exposure and the environment. The work has been performed in a competent and professional manner and EPA has been providing effective and efficient oversight over the remedial processes. Page 1 of 5 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: 11-11-11 2. From your perspective, what effects have site operations had on the surrounding community? Remedial activities have resulted in the restoration of the site; a previously blighted parcel of land that was an eyesore and the source of community embarrassment. Survey Questions (Continued) 3. During this review period, are you aware of any community concerns regarding the site or its operation and administration? If so, please provide details. I am not aware of any. 4. Are you aware of any events, incidents, or activities at the site during this review period, such as vandalism, trespassing, or emergency responses from local authorities? If so, please provide details. I am aware of several incidents of portions of the exterior fencing being stolen and of one incident of illegal dumping of soil on a portion of the property. All of these incidents were reported to the local authorities and have been documented to EPA. 5. Do you feel well informed about the site’s activities and progress? If not, please indicate how you would like to be informed about the site activities – for example, by e-mail, regular mail, fact sheets, meetings, etc. Yes Page 2 of 5 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: 11-11-11 6. Do you have any comments, suggestions, or recommendations regarding the site’s management or operation? No additional comments. Survey Questions (Continued) 7. Have there been routine communications or activities (site visits, inspections, reporting activities, etc.) conducted by your office regarding the site? If so, please describe the purpose and results. Yes, routine inspections are conducted during scheduled groundwater sampling events which have been conducted at the property. Additional impromptu informal inspections are periodically performed to identifying incidents of vandalism to the exterior fencing. 8. Have there been any complaints, violations, or other incidents related to the site that required a response by your office? If so, please summarize the events and results. No. 9. Are you aware of any problems or difficulties encountered which impacted the effectiveness of the remedial action or caused a change in operation and maintenance procedures? If so, please describe changes and impacts. None known. Page 3 of 5 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: 11-11-11 10. Have there been any changes in state or federal environmental standards which may call into question the protectiveness or effectiveness of the remedial action? No. Survey Questions (Continued) 11. Do you know of opportunities to optimize the operation, maintenance, or sampling efforts at the site? A request to reduce the sampling frequency and number of well to be sampled has recently been submitted to EPA as part of the Groundwater Response Action remedial objectives. Implementation of these suggested changes will optimize the sampling efforts at the site. Page 4 of 5 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: 11-11-11 Please add any other comments in the space below. No additional comments. Page 5 of 5 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified h1terests, fuc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: ll ~d-v ·· 11 Contact Made By: Name: Rafael Casanova Title: Remedial Project Manager Telephone No.: (214) 665-7437 E-Mail: Casanova.Rafael@ epa.gov Street Address: 1445 Ross Avenue, Suite 1200 City, State, Zip: Dallas, Texas 75202 Name: Stan Wallace Title: Project Manager Telephone No.: (972) 315-3922 E-Mail: swallace@eaest.com Street Address: 405 S. Highway 121, Building C, Suite 100 City, State, Zip: Lewisville, Texas 75067 Organization: U.S. EPA Organization: EA Engineering, Science, and Technology, Inc. Individual Contacted: I Organization: Narne: Phillip Winsor Title: Telephone No.: (512) 239-1054 E-Mail Address: Street Address: 12100 Park 35 Circle City, State, Zip: Austin, TX 78753 TCEQ Survey Questions The purpose of the.five-year review is to evaluate the implementation and performance of the remedy, and to confirm that human health and the environment continue to be protected by the remedial actions that have been pe1:[ormed at the site. This interview is being conducted as a part ~f the first five-year review for the Many Diversified Interests, Inc. Superfimd Site. Should you choose to respond, please return your survey .form to Stan Wallace at EA Enginee1•ing, Science, and Technology, Inc. via e-mail or U.S. Postal Service by 14 November 2011. The scope qfthe review is from June 2007 to present. 1. What is your general impression of the work conducted at the site during this review period? Y.c-r-7 e~~l.c.-1~~ "vvdr 42~"'""~~..65t::, ""-'t I . 2. From your perspective, what effects have:e zerations had on the surrounding community? t -jf,t..fir-vzl W\, l"o.'A"- i tvtJf v. cid !U..SC:J 4. +I (:.0¥\,oc_.~ ·lJ.t~t Vu .e_.v-e__.. Are you aware of any events, incidents, or activities at the site during this review period, such as vandalism, trespassing, or emergency responses from local authorities? If so, please provide details. No 5. Do you feel well informed about the site's activities and progress? If not, please indicate how you would like to be informed about the site activities- for example, by e-mail, regular mail, fact sheets, meetings, etc. y &.'f. 6. Do you have any comments, suggestions, or recommendations regarding the site's management or operation? No Page 2 of 4 SUPERFUND FIVE-YEAR REVffiW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superfund Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: IJ-tJ.t··/( Survey Questions (Continued) 7. Have there been routine communications or activities (site visits, inspections, reporting activities, etc.) conducted by your office regarding tl1e site? If so, please describe the purpose and results. ";)<---$I fr'i.rof\.~.;(-i/y tl\,r·o'~-& f'~iD'II\- of107~ 8. Have there been any complaints, violations, or other incidents related to the site that required a response by your office? If so, please summarize the events and results. No 9. Are you aware of any problems or difficulties encountered which impacted the effectiveness of the remedial action or caused a change in operation and maintenance procedures? If so, please describe cMes and impacts. 0 10. Have there been any changes in state or federal environmental standards which may call into question the protectiveness or effectiveness of the remedial action? No Page 3 of 4 SUPERFUND FIVE-YEAR REVIEW SITE SURVEY Site Name: Many Diversified Interests, Inc. Superftmd Site EPA ID No.: TXD008083404 Location: Houston, Harris County, Texas 77020 Date: /(-_;!..,( ·-li Survey Questions (Continued) 11. Do you know of opportunities to optimize the operation, maintenance, or sampling efforts at the site? No Please add any other comments in the sp~r below. M0 6 J) I f f""1'1'1 J. C::,m.('/1<." !\. .5 c ....... Page 4 of 4 Attachment 10 De-Listed DU 1 Soils and Groundwater CAPR ON WORMS CAGE BAYOU CAPRON 8-ACRE GROUNDWATER UNIT 1 34 AMBOY GUNTER GUNTER 29 16 17 COKE COKE OU1 SOIL UNIT GILLESPIE 19 18 20 21 23 22 24 EDMUND EGAN CAGE 31 CLINE 32 13 14 15 NIMROD BAYOU GILLESPIE HARE SCHWEIKHARDT 2 3 BUCK 49 HARE 12 11 48 A SEPARATE FILE IS AVAILABLE THAT LISTS THE COORDINATES FOR THE NUMBERED LOCATIONS EMILE BAER 35 7 10 POLLARD NANCE BRINGHURST 36 38 EAST NANCE 6 45 9 PROVIDENCE PROVIDENCE PRESS HARE 8 NOTE: ACRES BUCK OU2 / OU3 BOUNDARY PROVIDENCE BUCK OU1 WEST 8-ACRE GROUNDWATER UNIT PARTIAL DELETION AREA OU1 SOIL UNIT SHARON PARTIAL DELETION AREA 47 T AS RST GHU RIN B ; AST ST 10-E UR E H ET NG CR OU2 / OU3 ;BRI 0 -1 ST EA 10-EASTEX 37 EAST MCLEARY KELLY VERNON WACO WAYNE GREGG GROVE 39 MARKET SONDICK E PROVIDENCE 40 45 46 S EA H Y-I RW F T OU1 BOUNDARY 10 MOSES ROADS FREEWAY 10 UPTON GREEN 41 42 ST EA STONEWALL 44 PANNELL ZARZANIA CAPRON BRINGHURST VERNON BENSON STONEWALL CAGE MARKET 43 10-E PRESS PANNELL GROVE BAYOU STONEWALL CO COORDINATE ;WA REFERENCE 10 A ST GRANGER CAGE ORANGE REFERENCE ORANGE ORANGE CLINE 25 CLINE 27 26 28 30 51 50 BARRON BARON BARON CLINTON MELVA 450 900 CAGE Feet 1,350 EMILE 225 Texas Registered Engineering Firm F-005009 Texas Registered Geoscience Firm 50011 MDI SUPERFUND SITE PARTIAL BILLY DELETION AREAS, SOILS AND 8-ACRE GROUNDWATER UNIT OF OU 1 HIRSCH 0 RICHARDSON SKA CONSULTING, L.P. 10260 WESTHEIMER, SUITE 605 HOUSTON TEXAS 77042 IDA STAPLES GROVE L PLAZA DEL SO JUDD BARON 33 3617 BAER STREET HOUSTON, HARRIS COUNTY, TEXAS Date: JANUARY 2010 DUN Job No.: N 39004-0004 Scale: AS SHOWN Figure: 1 ±