PRELIMINARY CLOSE OUT REPORT 

 MANY DIVERSIFIED INTERESTS, INC. 

 SUPERFUND SITE 

 HOUSTON, TEXAS 

TXD008083404

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 6 

 AUGUST 2009
CONCURRENCE PAGE

PRELIMINARY CLOSEOUT REPORT

MANY DIVERSIFIED INTERESTS, INC. SUPERFUND SITE

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Barbara Nann

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 1 

PRELIMINARY CLOSE OUT REPORT 

MANY DIVERSIFIED INTERESTS, INC. SUPERFUND SITE 

HOUSTON, HARRIS COUNTY, TEXAS 

I. INTRODUCTION

This Preliminary Close Out Report (PCOR) documents that the Environmental Protection 

Agency (EPA) and the Texas Commission on Environmental Quality (TCEQ) have completed, 

or have provided oversight for completion of, construction activities for all operable units of the 

Many Diversified Interests, Inc., Superfund Site (MDI Site), including Operable Unit 1 (OU 1 - 

Onsite Soils and Ground Water), Operable Unit 2 (OU 2 - Offsite Residential Yards and HighAccess Areas), and Operable Unit 3 (OU 3 - Residential Crawlspaces and Residential Areas Not 

Addressed under OU 2) in accordance with “Close Out Procedures for National Priorities List 

Sites” (OSWER Directive 9320.2-09A-P). 

The EPA conducted the pre-final and final construction inspection for OU 1 on June 25, 

2008, and determined that the Bona-Fide Prospective Purchasers (BFPP) completed the remedy 

for OU 1 in accordance with the Remedial Design (RD) plans and specifications, the RA 

Sampling and Analysis Plan (SAP), the RA Quality Assurance Project Plan (QAPP), and the 

Record of Decision (ROD) for OU 1. Several minor punch-list items were identified, which will 

be addressed as a part of the ongoing quarterly operation and maintenance (O&M) inspections. 

No final inspections were necessary for the remaining operable units because the RODs 

did not require any further construction activities. The remedy selected for OU 2 was “no 

further action”, and the remedy selected for OU 3 was “no action warranted” for the residential 

crawlspaces and “no further action” for the residential areas. The “no further action” remedies 

were based, in part, on the previously completed removal actions as described below. 

II. SUMMARY OF SITE CONDITIONS

Background

The Site is located in Houston, Texas (Harris County) and is also known as Texas 

Electric Steel Casting Company (TESCO). The National Superfund Database Identification 

Number is TXD008083404. The Site is divided into three operable units as follows: 

• OU 1 (Onsite Soils and Ground Water): OU 1 consists of ground water and the on-site 

soils located within the fenced boundary of the former 36-acre foundry located at 

3617 Baer Street in Houston, Texas; located approximately 2 miles east of 

downtown Houston and 1 block south of I-10 in an area of mixed industrial and 

residential land use known as the “Fifth Ward.” 

• 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 
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boundaries of the former foundry (OU 1). High-access areas include schools, 

child daycare centers, playgrounds, and churches. 

• OU 3 (Residential Crawlspaces and Residential Areas Not Addressed under OU 2): 

Residential crawlspaces, residential yards or properties, and high-access areas that 

surround the east, west, and north fenced boundaries of the former foundry and 

were not addressed during previous RI/FS activities and removal actions 

conducted for MDI. 

In 1926, TESCO began operations as a metal casting foundry. TESCO primarily 

manufactured specialty molded parts such as large wheels, tracks, and mining equipment. A 

second foundry was built on the eastern portion of the Site during the latter half of 1970. The 

process area consisted of the two casting plants. Plant I produced large castings, while Plant II 

produced smaller castings. Various grades of steel, including high carbon, chrome molybdenum, 

high nickel, and stainless steel were cast at the TESCO facility. 

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. Can-Am reportedly obtained between 2,000 and 4,000 drums of spent catalyst from 

chemical plants and refineries located along the Houston Ship Channel. By 1988, Can-Am 

ceased operations and the stored drums of spent catalyst were abandoned on the 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 on-site facilities were demolished as a salvage operation under 

order of the U.S. Bankruptcy Court between March 1995 and January 1996. 

 There were frequent Texas Clean Air Act compliance inspections and complaint 

investigations conducted at the former foundry from January 1982 through October 1991. 

Violations documented during this period primarily involved visible emissions of particulate 

matter from the stacks and vents of the facility's baghouses. 

Land use surrounding the MDI property is a mixture of residential and industrial. 

Residential areas are located adjacent to the former foundry. There are an estimated 942 housing 

units and approximately 2,756 people within 1/2 mile of the site. Blanche Kelso Bruce (Bruce) 

Elementary School was formerly located adjacent to and west of the former foundry; it has since 

been reconstructed at a new location further west of the site. Residential land use is the 

reasonably anticipated future land use for the MDI Site. There are no drinking water wells 

completed into the shallow water bearing zone underlying the MDI Site. Additionally, this 

ground water is not currently being used as a potable source of water by the residents living near 

the Site, who receive their potable water from the City of Houston water supply. 

 Lead is the chemical of concern in soil at the MDI Site. There are multiple potential 

sources for the lead, including lead released to soil as a result of airborne particulate 
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deposition from former foundry processes, lead-based paint on area homes, and tail pipe 

emissions from vehicles. The EPA's goal at lead sites is to attempt to limit exposure to soil 

lead levels such that exposed children would have an estimated risk of no more than 5% of 

exceeding a 10 μg/dL blood-lead level. Prior to the removal of the lead impacted soil, the 

results of the Integrated Exposure Uptake Biokinetic (IEUBK) Model showed that the 

percentage exceeding the 10 μg/dL blood-lead level reached as high as 20.24% in one area of 

OU 1. 

For ground water, the chemicals of concern include benzo (a) pyrene, manganese, 

molybdenum, and petroleum hydrocarbons. The organic contamination is primarily a result of 

releases associated with a waste oil underground storage tank in the northwest corner of the Site 

and possible disposal of oily materials in the northeast corner of the Site. The inorganic ground 

water contamination resulted from infiltration and leaching to the water bearing zone of soil 

contaminated as a result of foundry operations. The risk assessment showed a cumulative excess 

carcinogenic risk from ground water of 1.0 x 10-3, which exceeds the acceptable risk range of 

10-4 to 10-6. 

On September 29, 1998, 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 published on January 19, 1999 (Federal Register / Vol. 64, No. 

11, Pages 2942 - 2949). 

Removal Actions

 In 1998, the Texas Natural Resources Conservation Commission (TNRCC, now known 

as TCEQ) submitted a memorandum to the EPA requesting approval for a Time Critical 

Removal Action at the MDI Site for removal and off-site disposal of lead contaminated soil from 

residential properties near the former foundry. This removal action was conducted to remove 

surface soil to a maximum depth of 1.5 feet below ground surface (bgs) with concentrations of 

lead that equaled or exceeded 500 mg/kg (the residential cleanup level) for 89 residential 

properties mainly located to the north and west of the former foundry. This removal action 

reduced the exposure of adults and children to lead. Following each removal, TNRCC 

conducted confirmation sampling to ensure that lead-contaminated soils did not extend below the 

18-inch bgs excavation depth. Approximately 12,025 tons of soil were removed, characterized, 

and disposed of at permitted landfills, with some of the soils being taken to a hazardous waste 

landfill, and some of the soils taken to a Subtitle D landfill. 

 In 1998 and 1999, the potentially responsible parties (PRPs) for OU 1 performed an 

extensive drum removal action with the EPA's oversight. Over 4,000 drums, containing spent 

refinery and petrochemical catalysts from the Can-Am operation, and visibly contaminated soils, 

were removed from OU 1 of the Site. 

 In January 2003, the EPA began the Remedial Investigation and Feasibility Study 

(RI/FS) for OUs 1 and 2. The primary objective of the soil sampling in OU 2 was to evaluate the 
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distribution of lead in soils downwind of the MDI Site. This was accomplished by first modeling 

the predicted area of impact from the Site, and then collecting samples from this area. Any 

impact from blowers reported to have operated on the east side of the Site may not have been 

fully accounted for in the air dispersion model; therefore, properties east of Press Street were 

also sampled. The EPA identified 59 residential areas, including high access areas, with lead 

concentrations equal to or greater than 500 mg/kg. Although the cleanup goal was set at 500 

mg/kg, the practical cleanup level was set at 463 mg/kg. This lower, more conservative level 

took into account the average relative standard deviation (SD) for the X-Ray Fluorescence 

(XRF) instrument of 37 mg/kg. In 2003 and in 2005, removal actions were completed at 59 

residential properties and high access areas to remove surface soil with concentrations of lead 

equaling or exceeding the 500 mg/kg action level, to a maximum depth of 1.5 feet bgs. 

Confirmation sampling was conducted to ensure that lead-contaminated soils did not extend 

below the bottom of the excavation. The contaminated soil removed from the residential 

properties, approximately 5,150 tons, 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 as a part of the remediation of OU 1. 

 In April 2006 and 2009, the EPA completed OU 3 removal actions at the northeastern 

portion of the Kelly Village Housing Complex and six (6) additional residential yards of the 

MDI Site, respectively, to remove surface soil with concentrations of lead that equaled or 

exceeded the cleanup goal of 500 mg/kg. EPA conducted confirmation sampling to ensure that 

lead-contaminated soils did not extend below the 18-inch bgs excavation depth. These and the 

previous removal actions addressed all of the residential areas that could have been affected by 

the air emissions of particulates containing lead from the former foundry, and for which the EPA 

was granted access for sampling. 

Remedy Selection

 The EPA, with the concurrence of the State of Texas, signed the ROD for OU 1 on July 

30, 2004. The components of the selected remedy for OU 1 include: 

• 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 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 off-site waste disposal facility) of the treated and untreated soils; 

• Transportation and Disposal (at a permitted off-site waste disposal facility) of 

approximately 31,621 yd3 of debris (nonhazardous debris, foundry sand, and slag), the 

Asbestos-Containing Material in the onsite 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 off-site waste disposal facility) of approximately 

2,100 yd3 of soils contaminated with benzo(a)pyrene, or other organics, at the MW-3 

location; light nonaqueous-phase liquids at the MW-11 location; and Total Petroleum 
 5 

Hydrocarbons at the MW-20 location. Soil cleanup levels for these isolated source areas 

will be determined during the remedial design and remedial action for the Selected 

Remedy; 

• Implementation of Monitored Natural Attenuation for the ground water, which includes 

source removal and Long-Term Monitoring for the ground water to ensure that 

constituents above cleanup goals are naturally attenuating; and 

• Implementation of Institutional Controls for both the soils and ground water to prevent 

exposure to soil contamination above acceptable cleanup levels and to prevent exposure 

to contaminated ground water 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 ground water. 

 The Remedial Design Report for OU 1 was completed on July 17, 2007. The remedial 

action for OU 1 was performed by the BFPP (Clinton Gregg Investments, L.P.) in accordance 

with an Administrative Order-on-Consent (AOC) for Remedial Design and Remedial Action 

entered on September 29, 2006. The institutional controls for OU 1 are currently being prepared 

by the BFPP, with EPA oversight, to prevent exposure to ground water contamination at the site. 

 Institutional controls are unnecessary for the OU 1 soils because the remedial action removed all 

areas of soil contamination in OU 1 that did not allow for unlimited use and unrestricted 

exposure. 

 The EPA, with the concurrence of the State of Texas, signed the ROD for OU 2 (Offsite 

Residential Yards and High-Access Areas) on September 23, 2005. The selected remedy for OU 

2 was no further action because previous removal actions had addressed unacceptable risks 

posed by the site contaminants. The remedy for OU 2 resulted in no contaminants remaining onsite above levels that allow for unlimited use and unrestricted exposure. Therefore, neither 

institutional controls nor five-year reviews are required for OU 2. 

 The EPA, with the concurrence of the State of Texas, signed the ROD for OU 3 

(Residential Crawlspaces and Residential Areas Not Addressed under OU 2) on August 31, 

2009. The Selected Remedy for the OU 3 residential crawlspaces is no action warranted 

because the Baseline Human Health Risk Assessment concluded that current or potential future 

Site conditions pose no unacceptable risks to human health or to the environment. The Selected 

Remedy for OU 3 residential areas is no further action because the previous removal actions 

have eliminated the existing and potential risks to human health and the environment. The 

remedy for OU 3 resulted in no contaminants remaining on-site above levels that allow for 

unlimited use and unrestricted exposure. Therefore, neither institutional controls nor five-year 

reviews are required for OU 3. 

Remedial Construction Activities

 An asbestos survey of the office building and numerous debris piles was performed in 

February 2007. Regulated ACM were identified in the building, on the roof, and in the debris 

piles. The office building was demolished in June 2007 immediately after the abatement of 
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ACM materials from the building. A concrete building, a storage building constructed of metal 

containers, and a masonry building were also demolished. The debris located on OU 1 included 

approximately 31,600 cubic yards of material, including non-hazardous debris (wood, metal, 

concrete, masonry, sands, trees, ceramics, and refuse) foundry sand, slag, and asbestos 

containing material. Beginning in June 2007, the debris was collected, segregated, and either 

recycled or disposed of. 

 From July through September 2007, an electrical transformer and two underground 

storage tanks (UST) were removed. The transformer (installed in the 1920s) was found to 

contain no residual liquids and was removed whole with disposal by a whole-transformer 

disposal service. One of the USTs contained cutting oil, which was recovered directly into the 

disposer’s transport tanker using a vacuum, and disposed at Waste Management’s Atascocita 

facility. The tank was excavated whole, downsized, and recycled. The surrounding soils from 

the UST were sampled and excavated as part of source removal for MW-20. 

 The fluids from the second UST were recovered and pumped directly into four 55-gallon 

drums, and disposed of at Chemical Waste Management’s Sulphur, Louisiana facility. The tank 

was excavated whole, the exterior decontaminated, downsized, and recycled at Texas Port 

Recycling. The surrounding soils from this UST were sampled and found to contain levels of 

benzo (a) pyrene higher than the removal criteria, requiring excavation. The soil was transported 

and disposed as total petroleum hydrocarbon (TPH) impacted soil. 

 Various water impoundments were located throughout OU 1. Seventeen water 

impoundments were sampled and all were found suitable for discharge under the City of 

Houston’s publicly owned treatment works (POTW) requirements. Water from the settlement 

basin was emptied and the underlying sludge material was solidified to allow disposal with the 

other TPH-impacted soils. Both of the surface ponds were filled using onsite soils. 

 Beginning in August 2007, the lead impacted soil at OU 1 was excavated and removed 

for disposal at appropriate landfill facilities. A total of 34,146 tons of lead contaminated soils 

were removed and disposed of. Several areas of soil contaminated with organic materials were 

also excavated and removed. After sidewall sampling established that the removal was 

complete, the areas were backfilled. In the MW-03 location, the excavation uncovered a 

disconnected sewer line, which was re-installed with the assistance of the City of Houston, and 

the area backfilled. At the MW-20 location, the source was found to involve the UST, Lead 

Area 1, and the entire area surrounding MW-20. All material excavated was sampled and 

segregated into disposal classes for TPH impacted soils. A total of 11,944 tons of TPH 

contaminated soils were removed and disposed of. 

 In February 2008, additional sampling was performed to identify any remaining areas of 

TPH or PCB contamination. This sampling identified four areas for removal, of which one 

contained PCB contamination and three contained TPH contamination. These contaminated 

soils were excavated and disposed of at appropriate landfill facilities between March and June 

2008. Excavation continued until confirmation sampling confirmed that all soil contaminated 
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above the removal criteria was removed. A total of 1,346 tons of TPH contaminated soils, and 

36 tons of PCB contaminated soils, were removed and disposed of. 

 Monitoring wells MW-03, MW-11, and MW-20 were plugged and abandoned in June 

2007. Removal of these wells facilitated the source removals at those locations. In February 

2008, MW-03R and MW-20R were installed to restore those locations, and new wells MW-26 

and MW-27 were installed to support continued MNA for the three PMZs at the MDI Site. 

 Dust emissions control was performed during the remedial action. Air monitoring, 

consisting of real-time handheld instrument monitoring for dust and organic vapors, 

meteorological monitoring, and integrated dust and particulate monitoring at the project 

perimeter, was conducted on all days when the project activities managed or disturbed the 

impacted soils. Throughout the project, no exceedances of air action limits occurred. In 

addition, volatile organic compound (VOC) and semi-volatile organic compound (SVOC) 

monitoring was conducted for the source removals at the UST, MW-03, MW-11, and MW-20. 

These samplers were operated only during the excavation and material management activities 

associated with those work activities. The VOC and SVOC monitoring did not indicate any 

exceedances due to these activities. 

No remedial construction activities were necessary for OU 2 and OU 3 because the 

RODs did not require any further construction. The remedy selected for OU 2 was “no further 

action”, and the remedy selected for OU 3 was “no action warranted” for the residential 

crawlspaces and “no further action” for the residential areas. The “no further action” remedies 

were based, in part, on the previously completed removal actions as described above. 

III. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE AND 

QUALITY CONTROL

 Construction quality assurance for OU 1 was performed by the EPA contractors who 

maintained a continuing onsite presence. EPA personnel were also onsite on a weekly basis 

(ranging from one to four days per week) during a majority of remedial activities to review 

construction progress and evaluate and review the results of the quality assurance and quality 

control activities. 

 The Remedial Design for OU 1 included a series of samples collected from Foundry 

Sands and identified lead impacted areas in OU 1 that were analyzed by on-site XRF instruments 

and offsite laboratory analysis. An XRF correlation study of the OU 1 material was performed, 

and reported as part of the “Remedial Design Data Evaluation Report”, dated July 17, 2007. The 

correlation study resulted in considering a field XRF screening value of 458 mg/kg to be 

equivalent to a laboratory analysis of 500 mg/kg for soil in OU 1. Screening in OU 1 was 

performed using an XRF to determine the extent of removal of lead impacted soils. The 

instrument was periodically calibrated to ensure accuracy and consistency. 
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 The OU 1 Remedial Design contained a determination of risk-based Tier-1 removal 

criteria for benzene, benzo(a)pyrene, and TPH. After calculating values from the Texas Risk 

Reduction Program (TRRP) Tier 1 Residential Tables, the lowest value for each compound’s 

selection of exposure pathways was used, providing for conservative removal criteria for the 

source removals. 

 Sampling was performed in accordance with the SAP and the QAPP. The certificates of 

analysis for laboratory sampling were generally provided throughout the project as part of either 

the Monthly Progress Report or the Monthly Air Monitoring Report. All Laboratory generated 

documentation was also furnished as Appendices to the “Remedial Action Data Evaluation 

Summary Report”. Throughout the conduct of sample collection and analysis, no nonconformances were experienced and no corrective actions were required. 

 The disposal and recycling facilities utilized waste profiles, waste shipping manifests, 

truck weight tickets, and material receipt invoices to document disposal in accordance with each 

facility’s applicable federal or state requirement. All lead soils, TPH soils, asbestos containing 

material, non-hazardous debris, TPH impacted water, transformers, UST, and bag filters utilized 

facility waste profile documents and waste manifests for shipment and disposal certificates. 

Materials such as concrete, metals, tires, batteries, clearing debris, and treated timbers were 

disposed as recycled materials; and each facility issued either delivery tickets or material receipt 

tickets as documentation of proper disposal in accordance with each facility’s applicable 

standards. These documents were provided as Appendices to the “Remedial Action Data 

Evaluation Summary Report”. 

 A Texas registered Professional Land Surveyor (PLS) was engaged to setup horizontal 

and vertical controls onsite referenced to the NAD83 State Plane coordinate system. Survey 

work to support the grid and grab sampling was performed using a GPS-based survey system to 

document locations and depths of sampling and excavation extents of impacted materials. 

Surveying for monitoring wells and final topography of the site was performed by the Texas 

registered PLS to provide coordinates and elevations for as-built drawings. 

 The EPA conducted the pre-final and final construction inspection for OU 1 on June 25, 

2008, and determined that the remedy was completed in accordance with the Remedial Design 

(RD) plans and specifications, the RA Sampling and Analysis Plan (SAP), the RA Quality 

Assurance Project Plan (QAPP), and the Record of Decision (ROD) for OU 1. EPA and 

ENTACT, the contractor for the BFPP, met onsite to perform a pre-final site inspection of OU 1. 

A visual inspection was conducted at each of the remedial action 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. It was determined that monitoring wells MW-5, MW-7, and MW-8 needed 

immediate repairs and all monitoring wells are to be re-inspected to ensure proper functioning 

and foundation stability. The EPA determined that all of the OU 1 soil remediation areas were 

properly remediated and have no outstanding problems; and the pre-final inspection can serve as 

the final site inspection. Specifically, those items requiring inspection and repairs are listed 
 9 

below as punch list items, as follows: 

• Inspect 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. 

• Inspect all monitoring well locking devices and all other well components to ensure 

proper functioning. 

 Both of these punch list items will be monitored as part of ongoing quarterly O&M 

inspections to be conducted concurrent with Monitored Natural Attenuation activities performed 

as part of the ground water remedial action. O&M inspections were completed in July 2008, 

October 2008, and January 2009. The well locks, pads, and other well components are in place 

and in an acceptable condition. 

 No final inspections were necessary for OU 2 and OU 3 because the RODs did not 

require any further construction activities. The remedy selected for OU 2 was “no further 

action”, and the remedy selected for OU 3 was “no action warranted” for the residential 

crawlspaces and “no further action” for the residential areas. The “no further action” remedies 

were based, in part, on the previously completed removal actions as described above. 

IV. ACTIVITIES AND SCHEDULE FOR SITE COMPLETION

The following activities remain for the MDI Site: 

Task Estimated Completion Responsibility

Conduct Quarterly O&M Inspections Quarterly BFPP 

Implement Institutional Controls August 2010 BFPP 

Final Close Out Report August 2010 EPA 

Delete MDI Site From NPL December 2010 EPA 

1st 5-Year Review May 2012 EPA 

V. SUMMARY OF REMEDIATION COSTS
Task Estimated Completion Responsibility

Delete MOl Site From NPL December 2010 EPA

lSI 5-Year Review May 2012 EPA

V. SUMMARY OF REMEDIATION COSTS

The estimated Iota I cost from the ROD for au I was $6,642,248. Of this total,

$6,421,784 was for capital costs, and $220,464 was for long term monitoring (30 years present

value with a 7% discount factor). This is an order-of-magnitude engineering cost estimate that is

expected to be within +50% to -30% of the actual project cost.

Although not all final quantities and associated costs have been completed, the BFPP's

capital and monitoring costs total $5,935,829 (as of August 2008) at the completion of the au I

dcmolition, removals, and installation of the ground water monitoring wells.

VI. FIVE-YEAR REVIEW

Hazardous substances will remain in the groundwater (OU I) at the MDI Superfund Site

above levels that allow for unlimited usc and unrestricted exposure after completion of the

remedial action. Pursuant to CERCLA section 121(c), 42 U.S.C. § 962 I(c), and as provided in

the current guidance on Five-Year Revicws: EPA 540-R-Ol-007, aSWER No. 9355.7-03B-P,

Comprehensive Five-Year Review Guidance, June 2001, EPA will conduct a statutory five-year

review for the au 1 ground water at the Sile. The first five year review will be completed by

May 2012, five years following initiation of remedial action construction activities.

Samuel Colcman, P.E., Directo Date

Superfund Division (6SF)

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