## PRELIMINARY CLOSE OUT REPORT

MANY DIVERSIFIED INTERESTS, INC.

SUPERFUND SITE HOUSTON, TEXAS

TXD00808340 4

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 6

AUGUST 2009CONCURRENCE PAGE

PRELIMINARY CLOSEOUT REPORT

MANY DIVERSIFIED INTERESTS, INC. SUPERFUND SITE

# ~A,~ / Rafael Abrego 

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Carlos Sanchez

Section Chief, Arkansasrrcxas Section

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Depuy Associate Director, Remedial Brunch

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Associate Director, Remedial Bran'll

Barbara Nann

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Date1 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 mi nor 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). Th e 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 fenced2 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 catalys t recycling operation using an experimental process. Can-Am reportedly obtained betw een 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 Cour t 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 primar ily 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 particulate3 

### 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 belo w 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 the4 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 stockpile d 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 Petroleum5 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 risksposed 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 of6 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 recove red 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 decontamin ated, 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 w ith 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 contaminated7 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.8 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 th e 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 EvaluationSummary 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 Surve yor (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 R ecord 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 problem s; and the pre-final inspection can serve as the final site inspection. Specifically, those items requiring inspection and repairs are listed9 below as punch list items, as follows:

• Inspect all monitoring wells for erosion of soils around foundation pads preventingstability 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

1 st 5-Year Review May 2012 EPA

V. SUMMARY OF REMEDIATION COSTSTask 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.

Date Samuel Colcman, P.E., Directo
Superfund Division (6SF)

10