RESPONSE ACTION CONTRACT FOR 

REMEDIAL, ENFORCEMENT OVERSIGHT, AND 

NONTIME-CRITICAL REMOVAL ACTIVITIES 

IN REGION 6 

FEASIBILITY STUDY REPORT FOR OPERABLE UNIT 1 

MANY DIVERSIFIED INTERESTS SUPERFUND SITE 

HOUSTON, HARRIS COUNTY, TEXAS 

EPA ID NO. TXD008083404 

Prepared For: 

U.S. Environmental Protection Agency 

Region 6 

1445 Ross Avenue 

Dallas, Texas 75202-2733

Work Assignment No. : 107-RICO-06CN 

EPA Region : 6 

Date Prepared : January 5, 2004 

Contract No. : 68-W6-0037 

Prepared by : Tetra Tech EM Inc. 

Tetra Tech Project Manager : Luis Vega 

Telephone No. : (214) 740-2007 

EPA Work Assignment Manager : Gary Miller/Rafael Casanova 

Telephone No. : (214) 665-8318/(214) 665-7437 
CONTENTS

Section Page

ABBREVIATIONS AND ACRONYMS .................................................................................................... vi

EXECUTIVE SUMMARY .................................................................................................................... ES-1

1.0 INTRODUCTION ........................................................................................................................... 1

1.1 PURPOSE........................................................................................................................... 1

1.2 SITE BACKGROUND....................................................................................................... 2

1.2.1 Site Location and Description................................................................................ 2

1.2.2 Site History ............................................................................................................ 5

1.2.3 Previous Investigations.......................................................................................... 8

1.2.3.1 Soils.................................................................................................... 8

1.2.3.2 Ground Water..................................................................................... 8

1.2.3.3 Waste Material ................................................................................... 9

1.3 SITE CHARACTERISTICS............................................................................................... 9

1.3.1 Site Climate ......................................................................................................... 10

1.3.2 Site Geology ........................................................................................................ 10

1.3.2.1 Native Materials............................................................................... 10

1.3.2.2 Foundry Sands.................................................................................. 11

1.3.3 Site Hydrogeology ............................................................................................... 11

1.4 NATURE AND EXTENT OF CONTAMINATION ....................................................... 12

1.4.1 Distribution of Waste Materials........................................................................... 14

1.4.1.1 ACM................................................................................................. 14

1.4.1.2 Bag House Materials........................................................................ 14

1.4.1.3 Waste Samples ................................................................................. 15

1.4.1.4 Catalyst Material .............................................................................. 15

1.4.1.5 Foundry Sands.................................................................................. 15

1.4.1.6 Petroleum Hydrocarbons in Soils and Ground Water...................... 15

1.4.2 Distribution of Contaminants in Surface Water and Sediment............................ 16

1.4.3 Distribution of Contaminants in Soil................................................................... 18

1.4.4 Distribution of Contaminants in Ground Water................................................... 18

1.5 SUMMARY OF SITE RISKS.......................................................................................... 21

1.5.1 Human Health Risk Assessment Results............................................................. 21

1.5.2 Ecological Risk Assessment Results ................................................................... 22

2.0 REMEDIAL ACTION OBJECTIVES AND ARARS .................................................................. 23

2.1 REMEDIAL ACTION OBJECTIVES ............................................................................. 23

2.2 CONTAMINANTS OF POTENTIAL CONCERN ......................................................... 23

2.2.1 Human Health Contaminants of Potential Concern............................................. 24

2.2.2 Ecological Contaminants of Potential Concern ................................................... 24

i
CONTENTS (Continued) 

Section Page

2.3 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS ................ 24

2.3.1 Overview of ARARs............................................................................................ 24

2.3.2 Chemical-specific ARARs................................................................................... 26

2.3.2.1 Chemical-specific ARARs for Ground Water.................................. 26

2.3.2.2 Chemical-specific ARARs for Soil.................................................. 26

2.3.3 Location-specific ARARs.................................................................................... 27

2.3.4 Action-specific ARARs....................................................................................... 27

2.3.4.1 Institutional Controls........................................................................ 28

2.3.4.2 NAPL Mitigation.............................................................................. 28

2.3.4.3 Management of Remediation Wastes............................................... 32

2.3.4.4 On-site Treatment of Contaminated Soil.......................................... 34

2.3.4.5 Temporary Storage of Recovered NAPL......................................... 34

2.3.4.6 Ground Water Monitoring in Support of MNA Remedy ................. 35

2.3.4.7 Control of Air Emissions.................................................................. 35

2.3.5 To Be Considered ................................................................................................ 35

2.4 GENERAL RESPONSE ACTIONS................................................................................. 36

3.0 IDENTIFICATION OF TECHNOLOGIES .................................................................................. 37

3.1 TECHNOLOGY 1 – SOIL WASHING/LEACHING...................................................... 38

3.2 TECHNOLOGY 2 – SOLIDIFICATION/STABILIZATION ......................................... 38

3.3 TECHNOLOGY 3 – CONTAINMENT........................................................................... 39

3.4 TECHNOLOGY 4 – ON-SITE DISPOSAL..................................................................... 40

3.5 TECHNOLOGY 5 – OFF-SITE DISPOSAL................................................................... 40

3.6 TECHNOLOGY 6 – INSTITUTIONAL CONTROLS.................................................... 40

3.7 TECHNOLOGY 7 – MONITORED NATURAL ATTENUATION............................... 41

3.8 SCREENING OF TECHNOLOGIES............................................................................... 42

4.0 COMPARATIVE ANALYSIS OF ALTERNATIVES................................................................. 45

4.1 EVALUATION CRITERIA............................................................................................. 45

4.1.1 Threshold Criteria ................................................................................................ 53

4.1.2 Primary Balancing Criteria .................................................................................. 53

4.1.3 Modifying Criteria ............................................................................................... 54

4.2 INDIVIDUAL ANALYSIS OF ALTERNATIVES......................................................... 55

4.2.1 Alternative 1 – No Action.................................................................................... 55

4.2.1.1 Overall Protection of Human Health and the Environment ............. 56

4.2.1.2 Compliance with ARARs................................................................. 56

4.2.1.3 Long-term Effectiveness and Permanence ....................................... 56

4.2.1.4 Reduction in Toxicity, Mobility, and Volume Through Treatment . 57

4.2.1.5 Short-term Effectiveness.................................................................. 57

4.2.1.6 Implementability .............................................................................. 57

ii 
CONTENTS (Continued) 

Section Page

4.2.1.7 Cost .................................................................................................. 57

4.2.2 Alternative 2 – Solidification/Stabilization with On-site Disposal; Ground Water 

via MNA with ICs................................................................................................ 57

4.2.2.1 Overall Protection of Human Health and the Environment ............. 59

4.2.2.2 Compliance with ARARs................................................................. 59

4.2.2.3 Long-term Effectiveness and Permanence ....................................... 59

4.2.2.4 Reduction in Toxicity, Mobility, and Volume Through Treatment . 59

4.2.2.5 Short-term Effectiveness.................................................................. 59

4.2.2.6 Implementability .............................................................................. 60

4.2.2.7 Cost .................................................................................................. 60

4.2.3 Alternative 3 – Solidification/Stabilization and Off-site Disposal; Ground Water 

via MNA with ICs................................................................................................ 60

4.2.3.1 Overall Protection of Human Health and the Environment ............. 61

4.2.3.2 Compliance with ARARs................................................................. 61

4.2.3.3 Long-term Effectiveness and Permanence ....................................... 62

4.2.3.4 Reduction in Toxicity, Mobility, and Volume Through Treatment . 62

4.2.3.5 Short-term Effectiveness.................................................................. 62

4.2.3.6 Implementability .............................................................................. 62

4.2.3.7 Cost .................................................................................................. 63

4.2.4 Alternative 4 – Containment with ICs................................................................. 63

4.2.4.1 Overall Protection of Human Health and the Environment ............. 64

4.2.4.2 Compliance with ARARs................................................................. 64

4.2.4.3 Long-term Effectiveness and Permanence ....................................... 64

4.2.4.4 Reduction in Toxicity, Mobility, and Volume Through Treatment . 65

4.2.4.5 Short-term Effectiveness.................................................................. 65

4.2.4.6 Implementability .............................................................................. 65

4.2.4.7 Cost .................................................................................................. 65

4.2.5 Site Preparation Activities – Alternatives 2, 3, and 4 .......................................... 65

4.2.6 Alternative 5 – Solidification/Stabilization and Off-site Disposal of Soils in 

Unpaved Areas; Ground Water via MNA with ICs............................................. 68

4.2.6.1 Overall Protection of Human Health and the Environment ............. 71

4.2.6.2 Compliance with ARARs................................................................. 71

4.2.6.3 Long-term Effectiveness and Permanence ....................................... 71

4.2.6.4 Reduction in Toxicity, Mobility, and Volume Through Treatment . 72

4.2.6.5 Short-term Effectiveness.................................................................. 72

4.2.6.6 Implementability .............................................................................. 72

4.2.6.7 Cost .................................................................................................. 72

5.0 COMPARISON OF REMEDIAL ALTERNATIVES................................................................... 73

5.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT ...... 73

iii 
CONTENTS (Continued) 

Section Page

5.2 COMPLIANCE WITH ARARS....................................................................................... 73

5.3 LONG-TERM EFFECTIVENESS AND PERMANENCE ............................................. 73

5.4 REDUCTION IN TOXICITY, MOBILITY, AND VOLUME THROUGH 

TREATMENT .................................................................................................................. 82

5.5 SHORT-TERM EFFECTIVENESS ................................................................................. 82

5.6 IMPLEMENTABILITY ................................................................................................... 82

5.7 COST ................................................................................................................................ 83

5.8 SUMMARY...................................................................................................................... 83

6.0 REFERENCES .............................................................................................................................. 85

Appendix

A FATE AND TRANSPORT MODELING

B COST ESTIMATE DETAILS 

iv 
TABLES 

Table Page

1 ACTIVITY-SPECIFIC ARARS.................................................................................................... 29

2 EVALUATION OF REMEDIATION TECHNOLOGIES ........................................................... 43 

3 SUMMARY OF ARARS .............................................................................................................. 46 

4 COMPARISON OF REMEDIAL ALTERNATIVES AND REMEDIAL ACTION 

OBJECTIVES................................................................................................................................ 74 

5 COMPARISON OF REMEDIAL ALTERNATIVES................................................................... 77 

6 COST SUMMARY FOR REMEDIAL ALTERNATIVES ......................................................... 84 

FIGURES 

Figure Page

1 SITE LOCATION............................................................................................................................ 3 

2 SITE LAYOUT................................................................................................................................ 4 

3 APPROXIMATE LOCATION OF BOX CULVERT..................................................................... 6 

4 APPROXIMATE LOCATION OF BOX CULVERT DISCHARGE INTO BUFFALO 

BAYOU........................................................................................................................................... 7 

5 POTENTIOMETRIC SURFACE MAP ........................................................................................ 13 

6 LEAD CONCENTRATIONS IN SOIL EQUAL TO OR GREATER THAN 500 MG/KG, 

0.0 - 1.5 FEET ................................................................................................................................ 19 

7 PAHS IN GROUND WATER AT OR ABOVE SCREENING LEVELS.................................... 20 

8 SITE PREPARATION, ALTERNATIVES 2, 3, AND 4 .............................................................. 66 

9 SITE PREPARATION, ALTERNATIVE 5.................................................................................. 69 

v
ABBREVIATIONS AND ACRONYMS 

1,1-DCA 1,1-Dichloroethane 

μg/kg Microgram per kilogram

μg/L Microgram per liter 

ACM Asbestos-containing material 

AOC Area of contamination 

ARAR Applicable or Relevant and Appropriate Requirement 

bgs Below ground surface 

BTAG Biological Technical Advisory Group 

Can-Am Can-Am Resource Group 

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act 

CFR Code of Federal Regulations 

COPC Contaminant of potential concern 

CRA Conestoga-Rovers Associates Services

DO Dissolved oxygen 

EPA U.S. Environmental Protection Agency

ERAGS Ecological Risk Assessment Guidance for Superfund 

ESI Enercon Services, Inc. 

ESL Effects Screening Level 

f/cc Fiber/cubic centimeter 

FR Federal Register 

FS Feasibility study

FSP Field sampling plan 

ft/min Foot per minute 

ft2

 Square foot 

gpm Gallon per minute 

GRA General response action 

HASP Health and safety plan 

HHRA Human health risk assessment 

HI Hazard index 

HQ Hazard quotient 

IC Institutional control 

HRS Hazard Ranking System

LDR Land Disposal Restrictions

LNAPL Light nonaqueous-phase liquid 

MCL Maximum contaminant limit 

MCLG Maximum contaminant level goal 

MDI Many Diversified Interests 

mg/kg Milligram per kilogram

mg/L Milligram per liter 

MNA Monitored natural attenuation 

MSSL Medium-specific Screening Level 

MTR Minimum technology requirement 

NA Not applicable 

NAPL Nonaqueous-phase liquid 

NCP National Oil and Hazardous Substances Pollution Contingency Plan

ORP Oxidation-reduction potential 

vi 
ABBREVIATIONS AND ACRONYMS (Continued)

OU Operable unit 

PAH Polycyclic aromatic hydrocarbon 

PCB Polychlorinated biphenyl 

RA Remedial action 

RAC Response Action Contract 

RAO Remedial action objective 

RCRA Resource Conservation and Recovery Act 

RI Remedial investigation 

ROD Record of Decision 

SARA Superfund Amendments and Reauthorization Act of 1986 

SDWA Safe Drinking Water Act 

SJF San Jacinto Foundry 

SLERA Screening-level ecological risk assessment 

SVOC Semivolatile organic compound 

SWBZ Shallow water-bearing zone 

TAC Texas Administrative Code 

TBC To be considered 

TCEQ Texas Commission on Environmental Quality

TCLP Toxicity Characteristic Leaching Procedure 

TERA TERA, Inc. 

TESCO Texas Electric Steel Casting Company

Tetra Tech Tetra Tech EM Inc. 

TNRCC Texas Natural Resources Conservation Commission 

TSCA Toxic Substances Control Act

TXDOT Texas Department of Transportation 

USDA U.S. Department of Agriculture 

UST Underground storage tank 

UTS Universal Treatment Standards 

XRF X-ray fluorescence 

yd3 Cubic yard

 vii
EXECUTIVE SUMMARY 

This report presents the feasibility study (FS) for Operable Unit 1 (OU 1) soils and ground water at the 

Many Diversified Interests (MDI) Superfund site located in Houston, Texas, and has been prepared in 

accordance with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and the 

U.S. Environmental Protection Agency (EPA) “Guidance for Conducting Remedial Investigations and 

Feasibility Studies under the CERCLA [Comprehensive Environmental Response, Compensation, and 

Liability Act]” (EPA 1988). 

The purpose of the FS is to evaluate remedial alternatives for a contaminated site through a systematic 

approach that includes: (1) developing remedial action objectives (RAO); (2) identifying general 

response actions (GRA); (3) screening the GRAs; (4) combining these technologies into remedies; and 

(5) evaluating these remedies. These remedies were evaluated based on the following seven of EPA’s

nine criteria: (1) overall protection of human health and the environment; (2) compliance with Applicable 

or Relevant and Appropriate Requirements (ARAR); (3) long-term effectiveness; (4) reduction in 

toxicity, mobility, and volume through treatment; (5) short-term effectiveness; (6) implementability; and 

(7) cost. 

During the remedial investigation (RI), lead was detected at concentrations greater than or equal to its 

residential screening level in surface soils at OU 1 (Tetra Tech 2003b). The RI detailed the volume of 

soils at the site with lead concentrations equal to or greater than the EPA Region 6 Human Health 

Medium-specific Screening Level (MSSL; EPA 2003) for lead in residential soil of 400 milligrams per 

kilogram (mg/kg). This FS has been prepared using a cleanup level of 500 mg/kg that is consistent with 

the cleanup level used in the recent off-site removal actions. The total estimated volume of surface soil 

containing lead at concentrations equal to or greater than 500 mg/kg is approximately 14,000 cubic yards 

(yd3

). Given that the soils at the site are clayey in nature, an expansion factor of 1.43 has been used to 

evaluate the volume of soil to be treated or disposed of. This translates to a treatment or disposal volume 

of approximately 20,000 yd3

. 

Ground water in the shallow water-bearing zone (SWBZ) at the site has been shown to be impacted by 

low levels of organic and inorganic contamination. Benzene was the only volatile organic compound 

detected above its Maximum Contaminant Level (MCL) of 5 micrograms per liter (μg/L) within OU 1. 

Benzene was detected at a concentration of 5.1 μg/L in monitoring well MW-13; no other exceedances 

were detected. Semivolatile organic compounds (SVOC) in the form of polycyclic aromatic 

hydrocarbons (PAH) were detected at concentrations above applicable screening levels in monitoring 

ES-1 
wells MW-03, MW-07, MW-09, MW-13, and MW-16. Benzo(a)pyrene was the only SVOC detected at a 

concentration above its MCL of 0.2 μg/L. Lead was detected in ground water at concentrations above its 

MCL of 15 μg/L in monitoring wells MW-06 (19.4 μg/L) and MW-13 (115 μg/L). 

In addition to soil and ground water contamination, waste materials, including spent catalysts from

previous operations, asbestos-containing material (ACM), and large piles of construction debris also 

remain on site. These materials are also addressed in this FS. 

The RAOs for OU 1 are: 

• Remove the ACM that has been stockpiled on site and left in the existing building. 

• Reduce the risk posed to residential receptors by lead concentrations in the soil above the clean 

up goal for the site (500 mg/kg). 

• Remove soil visibly contaminated with waste oil-range petroleum hydrocarbons in the vicinity of 

MW-3 that is acting as a potential continuing source of ground water contamination. 

• Remove soil visibly contaminated with waste oil-range petroleum hydrocarbons in the vicinity of 

MW-11 that has the potential to act as a source of ground water contamination. 

• Remediate ground water in the northwest corner of the site and remove the free product 

associated with the underground storage tank (UST). 

• Mitigate the threat posed by exposure to ground water throughout the rest of the site. 

Based on the general response action review, four alternatives (as well as No Action as required by the 

National Contingency Plan) were evaluated. They are: 

Alternative 1 – No Action 

Alternative 2 – Soil Stabilization/Solidification with On-site Disposal; Ground Water via 

Monitored Natural Attenuation (MNA) with Institutional Controls (IC) 

Alternative 3 – Soil Stabilization/Solidification with Off-site Disposal; Ground Water via MNA 

with ICs 

Alternative 4 – Soil Containment; Ground Water via MNA with ICs 

Alternative 5 – Soil Stabilization/Solidification of Contaminated Soils in Unpaved Areas with 

Off-site Disposal; Ground Water via MNA with ICs 

 ES-2

Each of the remedies proposed include the removal and disposal of ACM site wide, as well as the 

removal and disposal of an existing UST and associated light nonaqueous-phase liquids (LNAPL) in the 

SWBZ near the northwest corner of the site. Soils with LNAPL in the northeast corner of the site near 

MW-3 will also be removed. For Alternatives 2, 3, and 4, waste materials (nonhazardous foundry sand 
and catalysts) that overlay contaminated soils will also be removed from the site. Because Alternative 5 

does not include the remediation of lead-contaminated soils beneath concrete at the site, any 

nonhazardous waste materials overlaying concrete are not being removed under this scenario. The cost 

estimates prepared as part of this FS (Appendix B) do not assume that all nonhazardous debris will be 

removed from the site. 

All four of the remedies evaluated will meet the RAOs set for the MDI site. Alternatives 2, 3, and 5 

include solidification and stabilization of the waste, which will result in a reduction in the leachability of 

the lead-contaminated soils. Alternative 4 does not reduce the leachability of the soils and will require the 

construction of a low permeability cell to contain the wastes. The leachability of contaminated soils left 

on site beneath concrete in Alternative 5 will not be reduced; however, the presence of concrete will 

inhibit the infiltration of surface water into these soils. For all alternatives, the selected ground water 

remedy is natural attenuation following the removal of the contaminant source. 

Each of the remedies will require the implementation of ICs to mitigate exposure to receptors. The ICs 

will likely take the form of deed notices that will identify the SWBZ as not being of drinking water 

quality. For Alternative 5, the IC (deed notice) will also state that, in the event that the concrete overlying 

contaminated soils is removed, the underlying contaminated soils will also require remediation. 

Engineering controls in the form of a soil cover (Alternative 2) or engineered cap (Alternative 4) will also 

be necessary to ensure that exposure to the contaminated soils does not occur. Additional engineering 

controls in the form of fencing and/or signs may also be required depending upon the ultimate 

redevelopment plan. 

Appendix B provides a detailed cost breakdown for each of these alternatives, and includes construction 

costs and long-term maintenance costs. The appropriate remedy for the site can be readily implemented 

with any one of these alternatives for similar costs depending upon the needs of the developer. 

 ES-3
1.0 INTRODUCTION 

This report presents the feasibility study (FS) for Operable Unit 1 (OU 1) at the Many Diversified 

Interests (MDI) Superfund site located in Houston, Texas. Tetra Tech EM Inc. (Tetra Tech) prepared this 

FS report for the U.S. Environmental Protection Agency (EPA) Region 6 as part of Work Assignment No. 

107-RICO-06CN under Response Action Contract (RAC) No. 68-W6-0037. 

This FS report was prepared in accordance with the National Oil and Hazardous Substances Pollution 

Contingency Plan (NCP) and the EPA “Guidance for Conducting Remedial Investigations and Feasibility 

Studies under the CERCLA [Comprehensive Environmental Response, Compensation, and Liability

Act]” (EPA 1988). 

OU 1 consists of on-site soils, waste materials, and ground water, while OU 2 consists of off-site 

residential areas. This report addresses OU 1 only; the remedial investigation (RI), FS, and human health

risk assessment (HHRA) reports for OU 2 are currently in progress and will be submitted under separate 

cover. For the purposes of this report, “on-site” refers to the area within the fenced boundaries of the 

former Texas Electric Casting Company (TESCO) foundry site. 

The RI identified elevated lead concentrations in surface soils (to a depth of 1.5 feet) as the primary

contaminant of potential concern (COPC) at the MDI site. Other COPCs include polycyclic aromatic 

hydrocarbons (PAH) in soil and ground water, as well as light nonaqueous-phase liquids (LNAPL) in 

water and waste oil in soils. At the same time, asbestos-containing material (ACM) was also identified in 

an existing building and a number of debris piles on site. The purpose of this FS report is to develop and 

perform a comparative analysis of alternative remedial actions (RA) to address inorganic and organic 

constituents at the site such that it may be developed for residential use. 

1.1 PURPOSE 

The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) RI/FS process 

is an iterative process that (1) characterizes threats to human health and the environment posed by

hazardous substances released at a site, and (2) evaluates potential remedial alternatives to mitigate those 

threats. The NCP states that appropriate remediation is defined as a cost-effective remedial alternative 

that effectively mitigates and minimizes threats to and provides adequate protection of public health, 

welfare, and the environment. Remedial alternatives evaluated in this FS report vary in cost and level of 

protection afforded to human health. The FS process of developing and evaluating remedial alternatives 

consists of the following steps: 

1 
• Develop remedial action objectives (RAO) that specify contaminants and media of concern, 

volume of each affected medium, and remediation goals. RAOs are developed based on 

Applicable or Relevant and Appropriate Requirements (ARAR), HHRA results (Tetra Tech 

2003d), and screening-level ecological risk assessment (SLERA) results (Tetra Tech 2003c). 

• Develop general response actions (GRA) that can be taken for each medium to satisfy RAOs. 

Consider containment, treatment, removal, or other actions singly or in combination in 

developing GRAs. 

• Identify and screen technologies for each GRA to eliminate technologies that technically

cannot be implemented or are not cost-effective. 

• Identify and screen process options for each technology. 

• Assemble retained process options into alternatives and screen the alternatives. 

• Conduct a detailed analysis of the remaining alternatives based on the criteria identified in the 

NCP at Title 40, Code of Federal Regulations (CFR) Part 300.430(e)(9). 

The purpose of this FS is to identify remedial alternatives that are appropriate for the MDI site, and screen

the alternatives based on of the following criteria: (1) overall protection of human health and the 

environment; (2) compliance with ARARs; (3) long-term effectiveness; (4) reduction in toxicity, 

mobility, and volume through treatment; (5) short-term effectiveness; (6) implementability, and (7) cost. 

1.2 SITE BACKGROUND 

The following sections provide site background information, including site location and description, 

ownership, history, and previous investigations. 

1.2.1 Site Location and Description 

The MDI site, located at 3617 Baer Street in Houston, Harris County, Texas, is an abandoned foundry 

facility located approximately 2 miles east of downtown Houston and approximately 1 block south of 

Interstate Highway 10 (Figure 1). This portion of Houston is referenced as “Fifth Ward” (TERA, Inc. 

[TERA] 1994; Texas Natural Resource Conservation Commission [TNRCC] 1996a). The MDI property

occupies approximately 36 acres in an area of mixed industrial and residential land 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 beyond the easement to the south; and Bringhurst 

Street to the west. Tracks of the former Texas and New Orleans Railroad previously paralleled the 

southern edge of the site. Figure 2 shows the current layout of the MDI site as well as all investigative 

samples collected during the RI. 

2 


Structures currently on site include concrete foundations from several demolished foundry buildings, 

several partially demolished buildings, a large melt transformer, several concrete structures formerly used 

as vats, as well as an underground storage tank (UST) that was apparently used to store waste oil. The 

foundry buildings were demolished in 1995 under order of a U.S. bankruptcy court (TNRCC 1996a). 

Other current significant site features include two on-site ponded areas (the north and south ponds), the 

former Can-Am Resource Group (Can-Am) drum storage areas, concrete and asphalt paved areas 

(including former streets and roadways), and a landfill. Other remnants at the site include numerous piles 

of demolition debris consisting mainly of brick, wood, refractory brick, and miscellaneous debris. A 10-

foot by 12-foot concrete box culvert is buried in the former Ingraham Gully and replaces the natural 

surface drainage previously provided by the gully (Figure 3). A Review of City of Houston plans 

indicates that the box culvert empties into Buffalo Bayou (Figure 4). 

1.2.2 Site History

The site was originally the Houston Brick Works brickyard (TNRCC 1996a). Blue-clay found along 

the former Ingraham Gully, which crossed the center of the site, was excavated and used for the 

manufacturing of bricks. In 1926, 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 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 (TNRCC 1996a). 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 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 site while TESCO was still a tenant. 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. district bankruptcy court 

between March 1995 and January 1996 (TNRCC 1996a). 

5 


1.2.3 Previous Investigations 

Previous on-site information regarding the nature and extent of contamination at the site is extremely

limited. The following discusses the assessment of soils, ground water, and waste material that was 

conducted at the site. 

1.2.3.1 Soils 

Very limited sampling of soils was performed by TNRCC (now Texas Commission on Environmental 

Quality [TCEQ]) as part of its screening site inspection (TNRCC 1996a; 1996b). Nine soil samples (SC1 through SC-9) were collected and analyzed for metals in the field with a Spectrace® 9000 field X-ray

fluorescence (XRF) analyzer. The results are summarized as follows: 

• Arsenic was detected in a soil sample collected near the former melt transformer in the 

northwest corner of the site at 2,340 milligrams per kilogram (mg/kg). 

• Lead was detected in samples collected from the north and south ponds at 535 and 1,840 

mg/kg, respectively.

• Chromium was detected in a sample from the south pond at a concentration of 426 mg/kg. 

• Molybdenum was detected in all of the samples at concentrations ranging from 28,700 to 

70,500 mg/kg.

Seven additional soil samples were collected and submitted to a fixed laboratory for chemical analysis for 

semivolatile organic compounds (SVOC). Pyrene was detected in samples collected near one of the plant 

buildings at 550 micrograms per kilogram (μg/kg); these buildings have since been demolished. Dieldrin 

was detected in a sample collected near the former melt transformer at an estimated concentration of 

26 μg/kg. No other organic contamination was noted. 

1.2.3.2 Ground Water 

TERA installed four monitoring wells at the site as part of a site assessment (TERA 1994). Two of the 

wells (B-1 and B-2) were located north of Hare Street, while the remaining two wells (B-3 and B-4) were 

located near the southern boundary of the site along the former course of Ingraham Gully. The locations 

of these wells cannot be determined from historical reports and could not be located in the field during RI 

activities. Whereas off-site wells B-1 and B-2 contained toluene, ethyl benzene, and total xylenes in the 

microgram per liter (μg/L) range, wells B-3 and B-4 contained what was thought to be diesel as free 

product and strong hydrocarbon odors. Oil and grease concentrations in these two temporary wells were

569 and 842 milligrams per liter (mg/L), respectively. Because only four wells were installed at locations 

8 
separated by more than 1⁄4 mile, no conclusions regarding widespread ground water contamination could 

be made. 

An internal TNRCC e-mail (TNRCC 1998) indicates that TNRCC installed and sampled 12 wells. 

Because no well logs are available and these wells could not be located in the field during RI activities, it 

is assumed that these were temporary wells. Four of the wells were reportedly installed on the west side 

of the former Ingraham Gully, with toluene and benzene being the only organic detects above sample 

quantitation limits. To the east of the former Ingraham Gully, toluene, xylenes, methylnapthalene, and 

naphthalene were detected at concentrations above quantitation limits. TNRCC concluded that the site 

was not impacted by widespread ground water contamination. 

1.2.3.3 Waste Material 

When the facility was abandoned, more that 4,000 drums remained on site. In 1999, Conestoga-Rovers 

Associates Services (CRA) performed a drum removal action (CRA 1999). Work assessing the waste 

material was focused on determining whether the materials in the drums were hazardous or nonhazardous. 

The drums were stockpiled in the following three main groupings: 

• North drum storage area northwest of the former foundry slab 

• South drum storage area southwest of the former foundry slab 

• Former foundry slab (1,118 drums) (former EPA drum-staging area) 

The drums located in the north and south drum storage areas consisted primarily of catalyst pellets used in 

the smelting process. The catalyst materials contained high concentrations of metals, including nickel, 

lead, copper and chromium. The drums located in the EPA staging area included the same catalyst 

materials, as well as flammable liquids and solids, caustic liquids, high pH solids, and Resource 

Conservation and Recovery Act (RCRA) K171 and K172 listed wastes (CRA 1999). An additional 

investigation conducted by Tetra Tech (2003a) revealed that catalyst material remaining on site (primarily

as scattered debris piles resulting from the deterioration of drums) after completion of the removal action 

was nonhazardous. 

1.3 SITE CHARACTERISTICS 

The following sections pertain to the characteristics of the MDI site only. A complete discussion of the 

geologic and hydrogeological setting is provided in the MDI RI for OU 1 (Tetra Tech 2003b).

9 
1.3.1 Site Climate 

The site’s proximity to Galveston Bay and the Gulf of Mexico affects the climate area, resulting in mild 

weather conditions and an average daily temperature of 70 °F. The average daily low temperature is 43.6 

°F during the month of January. The average daily high temperature is 92.8 °F occurring generally during 

August. The average total annual precipitation for Harris County is 46 inches, with recorded annual 

extremes of 92.6 inches in 1900 and 17.7 inches in 1917 (U.S. Department of Agriculture [USDA] 1976). 

The mean annual lake evaporation for the area is approximately 18 inches (Bomar 1983). 

Two principal wind regimes are present in the Texas Coastal Zone: southeasterly winds from March 

through November, and intermittent northerly winds from December through February. Prevailing winds 

in Harris County are from the south-southeast. The highest average wind speeds generally occur during 

April. The strongest seasonal winds in the area are produced by winter polar air masses arriving from

the north, producing wind speeds of 20 to 40 miles per hour over a time period of 12 to 36 hours 

(Bomar 1983). 

The most severe weather occurring in Harris County is produced by hurricanes and tornadoes. Only 20

miles from the Gulf of Mexico, the Harris County area has an estimated one in eight chance of being 

affected by direct landfall of a hurricane in any given year; historically, the area is struck by a tornado 

approximately every other year (Bomar 1983). 

1.3.2 Site Geology 

For the purpose of this investigation, subsurface conditions were only evaluated to a depth of 

approximately 28 feet below ground surface (bgs), or 2 feet below the base of the first water-bearing 

zone. Soils encountered are typically fine grained in nature, consisting primarily of low plasticity clays 

and silty fine sands. In addition to the native soils, foundry sands that were used to fill in Ingraham Gully

underlie the center of the site to depths in excess of 20 feet bgs. General descriptions of the soils 

encountered are described below. 

1.3.2.1 Native Materials 

The site is underlain by a sequence of alternating clays and sands that reflect deposition in a near-shore 

or estuarine environment. In general, the clays contain a significant silt fraction, and exhibit low 

plasticity. Sands are fine to medium grained, with varying amounts of silt. These sands are poorly

graded, in terms of grain size distribution, and are suggestive of deposition in slow moving water. 

Although many portions of the site are underlain with 2 to 3 feet of fill materials (typically foundry

10 
sands although on occasion clay) a generalized stratigraphic column (represented in feet) would be as 

follows: 

0-12 Dark Gray Clay (First Clay): with trace silt; exhibits low plasticity and is medium stiff 

to stiff, moist

12-16 Light Gray to Yellowish Brown Silt to Silty Sand (First Sand): fine-grained, poorly

graded, loose to medium dense, moist 

16-22 Light Gray Clay (Second Clay): varies between low and high plasticity, and is typically 

medium stiff to stiff, moist

22-26 Reddish Brown to Brown Sand (Shallow Water-Bearing Zone): fine to medium

grained, trace silt, poorly graded, loose to medium dense, saturated. This is the first water 

bearing unit beneath the site. 

26- ? Gray Clay (Basal Clay): low plasticity, stiff, moist. Geoprobe® borings and wells did 

not completely penetrate this unit. Consequently, its total thickness has not been 

determined. 

1.3.2.2 Foundry Sands 

The central portion of the site is underlain by between 5 and 20 feet of foundry sands that were placed 

around the box culvert that lines the former Ingraham Gully, as well as other naturally occurring drainage 

channels that cross the site. In general, the materials are classified as silty sands, with the silt and clay

fraction ranging between 9 and 49 percent, and are fine-grained, poorly graded, and loose. 

1.3.3 Site Hydrogeology 

Ground water flow at the MDI site is controlled by the interaction between the north pond, the foundry 

sands, and the native soils. For the purpose of this report, the shallow water-bearing zone (SWBZ) is 

defined as the water table aquifer that occurs in both the native materials and within the foundry sand fill 

materials. The SWBZ occurs within native soils in the eastern and western thirds of the site. The static 

water surface of the SWBZ is typically encountered at 16 to 18 feet bgs (within the second clay). The 

transmissive portion of the SWBZ is encountered between 22 and 26 feet bgs (below the second clay) and 

consists of silty sand to poorly graded fine sand. The native sands are breached in the center of the site 

where Ingraham Gully transected the site. Ingraham Gully has been lined with the 12-foot-wide by 10-

foot-long concrete box culvert described previously and backfilled with foundry sands. 

The saturated foundry sands are the first unit encountered under the central portion of the site. These 

foundry sands were used as backfill in Ingraham Gully and in general are dark gray to black, fine to 

11 
medium-grained, poorly graded, and contain little or no silt or clay fraction. Ground water within the 

foundry sands is typically encountered at depths ranging between 16 and 18 feet bgs. 

Detailed lithologic logging and stratigraphic analysis has revealed that at some locations, the foundry

sands are in contact with the transmissive native sands that comprise the SWBZ and there is no separation 

between these units. The relationship between the foundry sands and native sands is shown on cross 

sections A-A’ through F-F’ (see Figures 4 through 10 in the RI report for OU 1 [Tetra Tech 2003b]). 

Ground water in the SWBZ flows towards Ingraham Gully from both the west and east sides of the site 

(Figure 5), and then exits the site to the north. 

Near the MDI site, the regional ground water flow gradient in SWBZs is to the south, following old 

drainage paths to Buffalo Bayou; however, ground water flow in the SWBZ on site has been confirmed to 

flow off site to the north. Because of this, Tetra Tech investigated other factors that may have contributed 

to this localized reversal in flow direction, including off-site pumping or dewatering systems associated 

with construction activities along Interstate Highway 10. No such artificial factors were identified. It 

appears that the flow to the north may be a localized response to the cross-cutting contact of the native 

sands and foundry sands, as well as the additional ground water influx from the north pond. 

1.4 NATURE AND EXTENT OF CONTAMINATION 

During the RI, the following field activities were performed: 

• Collection of shallow soil samples at 169 grid locations

• Advancement and sampling of 72 Geoprobe® soil borings 

• Completion of 35 Geoprobe® soil borings as temporary monitoring wells and collection of 

ground water samples from these locations 

• Advancement and sampling of 56 judgmental soil borings to the top of the first water-bearing 

zone 

• Installation and sampling of 24 permanent monitoring wells 

• Performance of single-well pump tests at five locations and slug tests at six locations 

• Collection of eight sediment samples and one surface water sample

• Collection of 10 waste samples from pits or tanks, 6 samples of foundry sands, and 5 samples 

of bag house materials 

12 

The location of these samples is shown on Figure 2. These data collected during the RI for OU 1 are the 

basis for the following discussion of the nature and extent of contamination. 

1.4.1 Distribution of Waste Materials 

Waste materials evaluated at the site included ACM, bag house materials, waste oil, pit contents, foundry 

sands, and refinery and petrochemical catalysts. Each of these materials is described below. 

1.4.1.1 ACM 

In their asbestos survey conducted in November 2001, Tetra Tech’s subcontractor, Enercon Sevices, Inc. 

(ESI), concluded that all except 2 of the 24 samples collected within the existing building just south of 

Nance Street contained ACM (ESI 2003). These samples encompassed an area of more than 85,000 

square feet (ft2

). 

Since the facility structures have already been demolished, areas near former structures and debris piles 

that include insulators have been sampled for ACM. Eleven additional samples were collected from

debris piles containing suspected ACM (ESI 2003); analytical results indicated that some of the debris 

piles contain non-friable ACM. These additional debris piles consisted primarily of construction debris 

including brick, concrete, and wood. Figure 2 shows the location of these debris piles. 

1.4.1.2 Bag House Materials 

Five samples of bag house waste were collected from the locations shown on Figure 2. These samples 

were analyzed for total metals as well as for metals using the Toxicity Characteristic Leaching Procedure 

(TCLP). By assessing the ratios of the total metals in the bag house materials, it may be possible to 

determine whether metal concentrations measured in soils are attributable to emissions from old foundry 

stacks or another source. This assessment will be included in the RI report for OU 2. The TCLP metals 

analyses were used to assess whether these materials would be considered hazardous waste for disposal 

purposes. 

Lead in bag house sample 1 was detected at an estimated concentration of 24,000 mg/kg. This

concentration was on the higher end of the range estimated for the site-specific air dispersion model 

developed for the site. Lead and chromium in the TCLP sample collected from this location were 

detected at concentrations of 36.1 and 1.4 mg/L, respectively. The measured concentrations are high 

enough such that these materials are considered hazardous waste under RCRA (40 CFR Part 261.24), and 

would require treatment prior to disposal. Bag house sample 5 also failed the TCLP for cadmium, with a 

14 
detected concentration of 7.1 mg/L. The total volume of bag house filter materials is approximately 15 

cubic yards (yd3

). 

1.4.1.3 Waste Samples 

Ten waste samples (2 solids and 8 liquids) were collected during the RI. Three liquid waste samples 

(WS-01, WS-02, and WS-03) collected from wastewater in on-site pits contained polychlorinated 

biphenyls (PCB) at concentrations ranging from 1.2 to 3.7 μg/L. Waste sample WS-01 also contained 

1,1-dichloroethane (1,1-DCA) at a concentration of 3.8 μg/L, and estimated concentrations of 

ethylbenzene and xylenes of 1.2 and 5.0 μg/L, respectively. Chromium in this sample was measured at a 

concentration of 102 mg/L; this waste stream will have to be managed as hazardous waste. 

1.4.1.4 Catalyst Material 

During a site walkthrough with EPA (conducted as part of the original scoping of the RI), suspected 

catalyst materials were identified in the southwest corner of the facility. Tetra Tech collected samples of 

the catalyst material as well as materials that were later described as inert support media; these materials 

were analyzed to assess whether or not they were hazardous. None of the samples exceeded any of the 

TCLP regulatory thresholds; accordingly, the five samples collected were characterized as nonhazardous 

(Tetra Tech 2003a). 

1.4.1.5 Foundry Sands 

Twelve samples of the foundry sands were collected and analyzed for waste characterization purposes. 

Specifically, Tetra Tech was interested in determining whether these materials would need to be managed 

as hazardous waste in the event that the materials were excavated and were scheduled to be disposed of 

off site. TCLP metals analysis indicated that the foundry sands are nonhazardous and, if excavated, could 

be managed as solid waste. Foundry sands present in the subsurface below lead hot spots may require 

additional testing to ensure that these materials are also nonhazardous. 

1.4.1.6 Petroleum Hydrocarbons in Soils and Ground Water 

Whereas the primary contaminants at the site consist of metals in soils, waste oil in soils is also present. 

Petroleum hydrocarbons as a nonaqueous-phase liquid (NAPL) were found in the MW-3 soil boring in

the northeast corner of the site and the MW-11 soil boring in the southwest corner of the site. At the 

MW-3 location, this NAPL is acting as a continuing source of ground water contamination. At the MW11 location, the NAPL is a potential source, although ground water has yet to be impacted. 

15 
In MW-20, LNAPL was detected floating on ground water. This is thought to be associated with the 

deterioration of the existing UST in the northwest corner of the site. 

1.4.2 Distribution of Contaminants in Surface Water and Sediment 

Surface water on the site is confined to the south pond. One surface water sample was collected and used 

to assess risks to ecological receptors that are posed by the site. Surface water COPCs were selected for 

the MDI SLERA by screening against surface water ecological screening toxicity values for direct 

contact, along with a consideration of bioaccumulation potential (Tetra Tech 2003c). 

The following SLERA COPCs (based on the maximum detected on-site concentration, and the most 

conservative [lowest] community-level ecological screening benchmarks) were identified based on the 

following rationale: 

• The only maximum detected concentration that met or exceeded an ecological benchmark 

was manganese. Maximum total and dissolved concentrations of manganese exceeded the 

TCEQ ecological benchmark (Tetra Tech 2003c). 

• Although maximum dissolved concentrations were below ecological benchmarks (chronic 

surface water quality standards) for surface water, five metals (cadmium, copper, lead, nickel, 

and selenium) were retained in a second screening step as tentative ecological COPCs to 

evaluate bioaccumulation and the indirect exposures via the food chain. Thus, a separate 

screening of the maximum detected surface water concentrations was conducted for 

protection of piscivorous wildlife (i.e., mammals and birds who eat fish) using the lowest no 

observed adverse effect level for piscivores, as detailed in Section 4.1 of the SLERA (Tetra 

Tech 2003c). Based on this assessment, only one chemical (selenium) exceeded the “no 

effect”-based benchmark protective of a mammalian and avian piscivore. However, the 

maximum selenium concentration did not exceed the lowest observed adverse effect level of 

selenium, protective of both piscivorous mammals and birds. Therefore, the maximum

selenium level detected in the south pond does not warrant any further investigation. 

The SLERA (Tetra Tech 2003c) established that all contaminants except manganese were below 

screening levels. No ecological risk due to the south pond surface water is indicated because of the lack 

of habitat afforded at the MDI site and its imminent property transfer and redevelopment for residential 

reuse. No further investigation or assessment of the south pond surface water is necessary. 

Eight sediment samples were collected from the north and south ponds, as shown on Figure 2. Samples 

SD-1 through SD-4 were collected from the north pond, while samples SD-5 through SD-8 were collected 

from the south pond. These samples were used to assess risks to ecological receptors that are posed by

the site. A complete discussion of these results and implications may be found in the SLERA (Tetra Tech 

2003c). 

16 
The “sediment” samples collected from the north pond (a moist depression that does not afford 

standing-water habitat for true aquatic receptors such as sediment invertebrates, fish, or piscivorous 

animals) were essentially soil samples. A terrestrial evaluation was conducted for this area and the 

upland soil area; both are discussed in the SLERA. 

The south pond (although a manmade borrow pit) was conservatively screened in the SLERA for 

protection of sediment-dwelling organisms, although actual presence of a benthic community is 

hypothetical, given the substrate (foundry sand and rubble). However, given the apparently perennial 

cover of water in this small 0.05-acre pool, the screen was conducted for the benthos, as per EPA and 

TCEQ Ecological Risk Assessment Guidance for Superfund (ERAGS) (Tetra Tech 2003c). The 

following SLERA COPCs (based on the maximum detected on-site concentration, and the most

conservative [lowest] community-level ecological screening benchmarks) were identified based on the 

following rationale: 

• Although below screening levels, mercury was retained as an ecological COPC due to its 

sediment bioaccumulation potential. In addition, although there was no ecological 

benchmark available, selenium was also retained as a COPC for the same reason. 

• Cadmium, copper, lead, nickel, and zinc were retained as ecological COPCs as they were 

above screening levels as well as being potential threats to the on-site food chain due to their 

bioaccumulative nature. 

• The maxima of four PAHs (benzo(a)anthracene, benzo(a)pyrene, chrysene, and pyrene), 

phenanthrene, and five metals (antimony, arsenic, chromium, manganese, and silver) also 

exceeded ecological screening levels and were retained as COPCs. 

The majority of the contaminants detected at MDI were not selected as ecological COPCs for south pond 

sediments, based on the rationale presented in the SLERA (Tetra Tech 2003c). None of the 

aforementioned bioaccumulative inorganics identified in the sediment of the south pond had readily 

available wildlife screening values protective of food-chain exposures; therefore, the bioaccumulative 

south pond inorganics identified in the SLERA as ecological COPCs could require potential further 

assessment. However, this assessment was not performed at the SLERA stage, given the findings of the 

SLERA (Tetra Tech 2003c). For this reason, and in consultation with the Biological Technical Advisory

Group (BTAG), no desktop food-chain modeling or exposure point concentration calculations were 

completed at the SLERA stage. If, on the other hand, the south pond will remain or be retained in its 

current state, risk managers should consider whether further evaluation of south pond sediment is 

warranted. 

17 
1.4.3 Distribution of Contaminants in Soil 

Lead was detected at concentrations above its screening level in surface soils at OU 1. The RI detailed 

the volume of soils at the site with lead concentrations equal to or greater than the EPA Region 6 Human 

Health Medium-specific Screening Level (MSSL; EPA 2003) for lead in residential soil of 400 mg/kg. 

This FS has been prepared using a cleanup level of 500 mg/kg that is consistent with the cleanup level 

used in the recent off-site removal actions. Figure 6 presents the distribution of lead in surface soil at OU 

1 with a concentration equal to or greater than 500 mg/kg. The total estimated volume of surface soil 

containing lead at concentrations equal to or greater than 500 mg/kg is nearly 14,000 cubic yards (yd3

). 

Given that the soils at the site are clayey in nature, an expansion factor of 1.3 has been used to evaluate 

the volume of soil to be treated or disposed of. This translates to a treatment or disposal volume of 

approximately 20,000 yd3

. 

1.4.4 Distribution of Contaminants in Ground Water 

Ground water at the site has been shown to be impacted by low levels of organic and inorganic 

contamination, and may be summarized as follows: 

• Benzene was the only volatile organic compound detected above its MCL of 5 μg/L within 

OU 1. Benzene was detected at a concentration of 5.1 μg/L in monitoring well MW-13; no

other exceedances were detected. 

• SVOCs in the form of PAHs were detected in concentrations above applicable screening 

levels in monitoring wells MW-03, MW-07, MW-09, MW-13, and MW-16. Benzo(a)pyrene 

was the only SVOC detected at a concentration above its MCL of 0.2 μg/L. Benzo(a)pyrene 

was detected in wells MW-03, MW-07, MW-16 at concentrations of 0.619, 0.084, and 0.063

μg/L, respectively. The PAHs that exceeded EPA Region 6 MSSLs were 3,3-dichorobenzene 

and atrazine (MW-13); acetophenone (MW-09 and MW-13); benzo(a)anthracene (MW-03 

and MW-07); and benzo(b)fluoranthene, dibenzo(a,h)anthracene, dibenzofuran, naphthalene, 

and pentachlorophenol (MW-03) (Figure 7). 

• Lead was detected in ground water at concentrations above its MCL of 15 μg/L in monitoring 

wells MW-06 (19.4 μg/L) and MW-13 (115 μg/L). 

• Arsenic was detected in 23 of 24 monitoring wells at concentrations ranging from 1.1 μg/L 

(MW-17) to 29.4 μg/L (MW-04). While all detected concentrations were above the EPA 

Region 6 MSSL of 0.045 μg/L, only four wells (MW-03 [20 μg/L], MW-04 [29.4 μg/L], 

MW-15 [16.6 μg/L], and MW-16 [16.2 μg/L]) had arsenic concentrations above the MCL of 

10 μg/L. The arsenic appears to be potentially emanating from an off-site source to the east. 

Consequently, arsenic will not be addressed in the FS. 

• Molybdenum was detected in 23 of 24 wells at concentrations ranging from 1.7 to 

13,900 μg/L. Although there is no MCL established for molybdenum, the maximum

concentration detected is more than an order of magnitude greater than the EPA Region 6 

MSSL for tap water (180 μg/L).

18 
5

42

562

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2160

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1209

2969

11-24-03O:\MDI\OnSite\Projects\grtthan500pb_0-1.5.mxdHPBL

LegendL

eadConcentrationsinSoil

equaltoorgreaterthan

500mg/kg

SiteBoundary

Railroad

SubdivisionBoundary

Street

Fence

MainContourInterval

(1footseparatesintervals)

Intermediary

ContourInterval

PavedArea

Building

075150300

Feet

MDISUPERFUNDSITE

HOUSTON,TEXAS

BY:

TetraTechEMInc.

PREPAREDFOR:

FIGURE6

LEADCONCENTRATIONSINSOILEQUAL

TOORGREATERTHAN500mg/kg

0.0-1.5FEET

DebrisArea

*Leadconcentrationsposted

areinmg/kg

Notes:

GridSamplingLocation

JudgmentalSamplingLocation
28

35

30 25

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FIGURE 7

PAHS IN GROUND WATER

AT OR ABOVE SCREENING LEVELS

MDI SUPERFUND SITE

HOUSTON, TEXAS

11-25-03 B:\MDI\mw_tw_maps\Figure 7 pah_results FS.mxd hp bl

0 75 150

Feet

BENZO (a) ANTHRACENE 2

BENZO (a) PYRENE 0.619

BENZO (b) FLUORANTHENE 0.885

DIBENZO (a,h) ANTHRACENE 0.102

DIBENZOFURAN 74

NAPHTHALENE 120

PENTACHLOROPHENOL 0.73 LJ

MW-03

Notes:

26 27 28 28 27 26 25 24 23 22 21 21 22 23

24

NANCE STREET

BR NI GHURST STREET

BAER STREET

HARE STREET

GILLESPIE

STREET

CLINE STREET

PRESS STREET

4. Does not include bis(2-ethylhexyl)

phthalate, a common laboratory

contaminant

5. Benzo(a)pyrene exceeded Federal

Maximum Contaminant Level (MCL);

all other compounds listed in excess of

EPA Region 6 Tap Water Standards

1. Results are posted in μg/L

2. NONE = No PAHs detected at

concentrations above their respective

screening levels

3. Qualifiers:

J = Estimated value

L = Reported concentration is

below contract-required

detection limit

NONE

MW-12

NONE

MW-24

NONE

MW-24D

NONE

MW-23

NONE

MW-16D

BENZO (a) PYRENE 0.084

DIBENZO (a,h) ANTHRACENE 0.02

MW-07

ACETOPHENONE 2.1

MW-09

3,3-DICHLOROBENZIDINE 69

ACETOPHENONE 1.7

ATRAZINE 0.48

MW-13

BENZO(a)PYRENE 0.0633

MW-16

NONE

MW-20

NONE

MW-01

NONE

MW-21

NONE

MW-18

NONE

MW-05

NONE

MW-11

NONE

MW-22

NONE

MW-10

NONE

MW-10D

NONE

MW-14

NONE

MW-19

NONE

MW-17

NONE

MW-02

NONE

MW-04

NONE

MW-15

NONE

MW-06

NONE

MW-08

Concentration exceeds EPA

Region 6 tap water standard

Concentration exceeds

Federal MCL

BY:

Tetra Tech EM Inc.

Legend

Site Boundary

Railroad

Monitoring Well Location

Subdivision Boundary

Street

Fence

Main Contour Interval

(1 foot separates intervals)

Intermediary

Contour Interval

PREPARED FOR:

MW-13

MW-07

MW-09

Approximate Extent of

Foundry Sands
• Petroleum hydrocarbons as NAPL were identified in ground water monitoring well MW-20 

with a thickness of approximately 0.5 inch. It has been estimated that a NAPL plume may be 

as much as 140 feet long and 30 feet wide. The NAPL has also been addressed in Section 

1.4.1.5 

1.5 SUMMARY OF SITE RISKS 

Risks posed to both human and ecological receptors were addressed in the HHRA (Tetra Tech 2003d) and 

the SLERA (Tetra Tech 2003c) reports for OU 1, respectively. These potential risks are summarized in 

the following sections. 

1.5.1 Human Health Risk Assessment Results 

As described in the HHRA (Tetra Tech 2003d), cancer risks and noncancer hazard indices (HI) were

within target levels (i.e., cancer risks below 10-4 and a noncancer HI less than or equal to 1) for the current 

trespasser/visitor and a future residential adult and future industrial worker. The noncancer HIs for the 

future child resident exceeded the target HI threshold of 1. Exposure to elevated concentrations of iron 

across the site resulted in HIs greater than 1 for a future child resident. An HI of 1.8 was estimated for the 

future child resident based on exposure to soil in the northwest corner of the site. Iron (with a hazard 

quotient [HQ] of 1.3) contributed the majority of the HI associated with the northwest corner of the site. 

An HI of 3.8 was estimated for the future child resident based on exposure to soil across the remainder of 

the site. Iron was again the major contributor to the HI for the future child resident with an HQ of 1.9. 

As detailed in the HHRA for OU 1 (Tetra Tech 2003d), while iron concentrations at several locations 

across the site exceeded the EPA Region 6 MSSL residential soil value for iron (23,000 mg/kg), the 

estimated iron intake from on-site soil was below the concentration determined to be minimally toxic. 

With regards to the potential on-site future resident child, excluding iron, all other HQs and target organ 

HIs were below the threshold of 1. 

Inhalation of volatile chemicals in indoor air via the subsurface migration pathway was evaluated for the 

future residents and future industrial worker. For the adult receptors, all cancer risks and noncancer 

hazards were within or below target levels. For the future child receptor, isopropylbenzene contributed to 

an HI of 2.4. Isopropylbenzene was only detected in 4 of 27 ground water samples; the maximum 

detected concentration was used to determine the risk and hazard estimates. The maximum concentration 

may not be a reasonable approximation of exposure concentrations and the noncancer hazard may be 

overestimated. Isopropylbenzene is not believed to be related to past foundry operations or catalyst 

storage activities at the site. 

The shallow water-bearing zone is not a source of potable water. Residents near the site receive potable 

21 
water from the City of Houston public water supply. Cancer risks and noncancer hazards for the future 

residents and industrial workers were estimated in the HHRA assuming ground water is used for domestic 

purposes. Cancer risks and noncancer hazards exceeded target levels (i.e., cancer risks of 10-4 and 

noncancer HI less than or equal to 1); however, future use of ground water in the SWBZ is not 

anticipated. 

1.5.2 Ecological Risk Assessment Results 

During ecological conceptual site model development in the SLERA (Tetra Tech 2003c), it was 

forecasted that the most potentially significant ecological concern at this site is the transportation of 

bioaccumulative potential COPCs to Buffalo Bayou and the subsequent uptake of those contaminants 

through the food chain. However, the RI found that these and other ecological exposure pathways are 

incomplete due to (1) a lack of on-site habitat, because the site is presently characterized by disturbed 

ground, and because future site redevelopment (including preparation of parklands, if any) will require 

further disturbance and surface preparation that will eliminate any terrestrial habitat; (2) a lack of off-site 

migration of subsurface contamination (i.e., ground water) toward areas with habitat; and (3) imminent 

residential redevelopment plans. Thus, it is apparent that the site poses little ecological risk and the 

ecological risk assessment process may be concluded. If it is determined that the future land use (i.e., 

imminent human redevelopment) is not implemented in a timely fashion, a further ecological risk 

assessment may be necessary for the COPCs identified in the SLERA. 

22 
2.0 REMEDIAL ACTION OBJECTIVES AND ARARS 

The following subsections discuss the RAOs, COPCs, ARARs, and GRAs for MDI OU 1. 

2.1 REMEDIAL ACTION OBJECTIVES

In this section, RAOs are developed for the MDI site. RAOs identify site-specific COPCs, media of 

concern, potential exposure pathways, and remediation goals, which are derived from the risk assessment 

findings and the evaluation of potential ARARs. A summary of the risk assessment findings was 

presented in Section 1.5. The RAOs for OU 1 are: 

• Remove the ACM that has been stockpiled on site and left in the existing building. 

• Reduce the risk posed to residential receptors by lead concentrations in the soil above the 

cleanup goal for the site (500 mg/kg). 

• Remove soil visibly contaminated with waste oil-range petroleum hydrocarbons in the vicinity of 

MW-3 that is acting as a potential continuing source of ground water contamination. 

• Remove soil visibly contaminated with waste oil-range petroleum hydrocarbons in the 

vicinity of MW-11 that has the potential to act as a source of ground water contamination. 

• Remediate ground water in the northwest corner of the site to MCLs, and remove the free 

product associated with the UST. 

• Mitigate the threat posed by exposure to ground water throughout the rest of the site. 

The cleanup goal for lead in soils at the site has been set at 500 mg/kg, which is protective of human 

health based on Integrated Exposure Uptake Biokinetic (IEUBK) modeling of actual data collected from

other EPA Region 6 Superfund lead sites, namely Tar Creek Superfund Site (EPA 1997b) and Delatte 

Metals Superfund Site (EPA 2000c). With the exception of the No Action Alternative, all soils with lead 

concentrations equal to or greater than 500 mg/kg will be excavated from their current locations and 

addressed via one of the active remedies outlined herein. 

2.2 CONTAMINANTS OF POTENTIAL CONCERN 

COPCs were identified based on the findings of the HHRA and SLERA performed by Tetra Tech in 

conjunction with the RI for OU 1. The COPCs for the MDI site were detected in OU 1 soil, sediment, 

waste materials, surface water, and ground water. 

23 
2.2.1 Human Health Contaminants of Potential Concern

Based on the results of the HHRA (Tetra Tech 2003d), the primary inorganic COPC for OU 1 soils was 

lead. In addition, carcinogenic polycyclic aromatic hydrocarbons (PAH)–primarily benzo(a)pyrene–were 

the primary organic COPCs for OU 1 ground water. The potential use of ground water in the SWBZ 

resulted in estimated cancer risks that were greater than the upper bound of the target risk range. 

2.2.2 Ecological Contaminants of Potential Concern 

The SLERA did not identify ecological COPCs (Tetra Tech 2003c). This was due in larger part to Tetra 

Tech’s understanding that the site is expected to be redeveloped residentially in the very near future. 

Because of this, terrestrial habitat will not exist once development is completed.

2.3 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS 

CERCLA, as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), and its 

implementing regulation, the NCP at 40 CFR Part 300, require that CERCLA RAs achieve ARARs 

established under federal and state environmental laws and regulations that address wastes, pollutants, 

contaminants, RAs, location, or other circumstances at a CERCLA site. CERCLA also provides six 

ARAR waivers that may be invoked under specific circumstances. In addition to ARARs, EPA and the 

states may, as appropriate, identify other advisories, criteria, or guidance to be considered (TBC) for a 

particular release. 

2.3.1 Overview of ARARs 

According to Section 300.5 of the NCP, “applicable requirements” means those cleanup standards, 

standards of control, and other substantive requirements, criteria, or limitations promulgated under federal 

environmental or state environmental or facility siting laws that specifically address a hazardous 

substance, pollutant, contaminant, RA, location, or other circumstance found at a CERCLA site. 

According to EPA’s ARAR guidance “CERCLA Compliance with Other Laws Manual,” in order for a 

requirement to be applicable it must (1) be substantive as opposed to administrative, (2) be promulgated 

through a federal rulemaking procedure or for state standards it must be of general applicability and 

legally enforceable, and (3) its jurisdictional prerequisites must be satisfied by the circumstances at the 

CERCLA site. 

24 
Section 300.5 of the NCP defines “relevant and appropriate requirements” to mean those cleanup 

standards, standards of control, and other substantive requirements, criteria, or limitations promulgated 

under federal environmental or state environmental or facility siting laws that, while not “applicable” to a 

hazardous substance, pollutant, contaminant, RA, location, or other circumstance found at a CERCLA 

site, address problems sufficiently similar to those encountered at the CERCLA site that their use is well 

suited to the particular site. 

Identification of ARARs is a site-specific determination and involves a two-part analysis: first, a 

determination of whether a given requirement is applicable; then, if it is not applicable, a determination of 

whether it is relevant and appropriate. A requirement is deemed applicable if the specific terms of the law 

or regulation directly address the chemical of concern, RA, or site location. If the jurisdictional 

prerequisites of the law or regulation are not met, a legal requirement may nonetheless be relevant and 

appropriate if the site’s circumstances are sufficiently similar to circumstances in which the law otherwise 

applies and it is well-suited to the conditions of the site. 

An evaluation of the relevance and appropriateness of a requirement is site specific, and must be based on 

best professional judgment. A requirement may be relevant, but not appropriate, for the specific site. In 

40 CFR Part 300.400(g)(2), the NCP lists factors to consider in evaluating relevance and appropriateness. 

Only requirements that are determined to be both relevant and appropriate must be followed. Portions of 

a requirement may be relevant and appropriate even if a requirement in its entirety is not (EPA 1988). A 

requirement must be substantive in order to constitute an ARAR for activities conducted on site. 

Procedural or administrative requirements such as permits and reporting are not ARARs. 

The preliminary identification of ARARs involves considering a number of site-specific factors, including

potential RAs, compounds at the site, physical characteristics of the site, and site location. A requirement 

is applicable if it specifically addresses or regulates the hazardous substance, pollutant, contaminant, 

action being taken, or other circumstances at the site. To assess whether a particular requirement would 

be legally applicable, it is necessary to evaluate specific jurisdictional prerequisites of the statute or 

regulation. All pertinent jurisdictional prerequisites must be met for the requirement to be applicable. 

Jurisdictional prerequisites include: 

• Who, as specified by the regulation, is subject to its authority. 

• The types of substances and activities listed as falling under the authority of the regulation. 

• The time period for which the regulation is in effect. 

• The types of activities the regulation requires, limits, or prohibits. 

25 
• If jurisdictional requirements are met, the requirement is applicable. If not, the next step is to 

consider whether the requirement is relevant and appropriate (EPA 1988). 

ARARs identified for RAs are based on the chemicals present, the location of the site, and possible RAs 

for the site. The following sections present the chemical-, location-, and action-specific state and federal 

ARARs that may be pertinent to the MDI site. These ARARs are discussed again in Section 3 as they

relate to specific potential RAs. 

2.3.2 Chemical-specific ARARs 

The releases at the MDI site have impacted both the soil and ground water media as confirmed during the 

RI. Chemical-specific federal ARARs and TBCs for the potential contaminants at the MDI site are 

identified below for ground water and soil, respectively. ARARs have not been developed for sediment 

and surface water. While the SLERA (Tetra Tech 2003c) identified potential impacts to ecological 

receptors over time, it was agreed that because the property is scheduled to be redeveloped for residential 

use, the ecological habitat would no longer exist. 

2.3.2.1 Chemical-specific ARARs for Ground Water 

The identification of ground water ARARs and TBCs is based on the assumption that ground water has a 

beneficial use. 

National Primary Drinking Water Standards. These standards establish acceptable levels for drinking 

water. MCLs, non-zero maximum contaminant level goals (MCLG), and action levels (40 CFR Part 141) 

under the Safe Drinking Water Act (SDWA) are relevant and appropriate requirements for ground water 

used for drinking, or ground water that may be a future source for potable water. If a chemical has both 

an MCL and a non-zero MCLG, the more stringent number is used. Other organic compounds may be 

present in the ground water at the site, and the lower of the MCL or non-zero MCLG would be the ARAR 

for any other organic compounds detected in ground water. 

2.3.2.2 Chemical-specific ARARs for Soil 

Few federal standards have been promulgated for contaminants in soil. Most screening and cleanup 

standards for soil are developed using EPA’s risk assessment and preliminary remediation goals 

processes. 

Toxic Substances Control Act (TSCA). TSCA and its implementing regulations found at 40 CFR Part 

761 might be relevant and appropriate to the cleanup of PCB-contaminated wastewater at the MDI site as 

26 
described in Section 1.4.1.3. 40 CFR Part 761.50(a)(3) prohibits the discharge of water containing PCBs 

to a treatment works or to navigable waters unless the PCB concentration is less than 3 ug/L, unless the 

discharge is in accordance with a PCB discharge limit included in a permit issued under Section 307(b) of 

the Clean Water Act. 

2.3.3 Location-specific ARARs

Location-specific ARARs restricts the concentration of hazardous substances or the conduct of activities 

due to characteristics of the site or its immediate environment. For example, location of the site or 

proposed RA in a flood plain, wetlands, historic place, or sensitive ecosystem may trigger locationspecific ARARs. Any RA that would affect these special locations must comply with the associated 

regulations. 

• Ground Water Restoration. The State of Texas Rules, Ground Water Protection Act (Texas 

Water Code, Chapter 26, Subchapter J, 401 through 406), is a location-specific ARAR. It is 

applicable, because the site’s underlying ground water is affected. This rule requires ground 

water to be restored, if feasible. 

• Construction Permits. Proper permits for construction in rights-of-way will be required, and 

the city, county, or Texas Department of Transportation (TXDOT) may require roadway

crossing agreements. 

• Floodplain or Wetland Environments. 40 CFR Part 6 Appendix sets forth EPA policy for 

carrying out the provisions of Executive Orders 11988 (Floodplain Management) and 11990 

(Protection of Wetlands) and are potential location-specific ARARs. The site is not located 

within a floodplain and there are no wetlands near the site that would be impacted by cleanup 

actions at the site. 

• The Endangered Species Act, the National Historic Preservation Act, and the Archaeological 

and Historic Preservation Act also are potential ARARs that were considered. The MDI site

is not located in an area affected by these acts. 

2.3.4 Action-specific ARARs 

Action-specific ARARs are technology- or activity-based requirements or limitations for RAs. These 

requirements are triggered by the particular remedial activities conducted at the site and suggest how a 

selected remedial alternative should be achieved. These action-specific requirements do not in 

themselves determine the remedial alternative; rather, they indicate how a selected alternative must be 

conducted. Action-specific ARARs have been identified for the following actions that may be included in 

the remedial alternatives for the site. 

Table 1 summarizes the ARARs pertaining to the main elements of each of the remedial alternatives (soil 

washing, solidification and stabilization, containment, and monitored natural attenuation [MNA]). 

27 
Several of the remedial alternatives have several of these elements in common, including excavation and 

waste disposal requirements. Where these elements are common to several alternatives, they are listed in 

the table once. 

The technologies being considered for contaminated ground water (excluding NAPLs) are no action and 

MNA, which have no associated action-specific ARARs. 

2.3.4.1 Institutional Controls 

There are no Federal ARARs for ICs. The NCP allows the use of ICs to supplement engineering controls 

as appropriate for short- and long-term site management to prevent or limit exposure to site-related 

contamination (NCP Section 300.430 [a][1][iii][D]). ICs may be required in order to prevent future use 

of contaminated ground water or exposure to contaminated soils, depending upon the remedy selected. 

State regulations that are potential action-specific ARARs regarding ICs are codified in Title 30, Texas 

Administrative Code (TAC) Part 350.111 (f). These regulations provide authority for the TCEQ to have a 

“deed notice” placed as an IC. 

2.3.4.2 NAPL Mitigation 

LNAPL is present in monitoring well MW-20 and has been identified in mobile and residual phases at grid 

locations P-10 and D-5, and soil borings MW-3 and MW-11. It appears that the LNAPL is primarily diesel 

and waste oil range petroleum hydrocarbons. There are federal and state regulations for the removal of free 

product released from USTs, codified at 40 CFR Part 280.64 and 30 TAC 334.79, respectively. Wastes 

from the UST may fall under the Petroleum Exclusion under CERCLA. Because of this state regulations 

are applicable, while the federal regulations under 40 CFR Part 280 are considered relevant and appropriate. 

The following regulations are potential action-specific ARARs: 

• 40 CFR Part 280.12 – defines free product as a regulated substance present as a NAPL (for 

example, liquid not dissolved in water). 

• 40 CFR Part 280.64 – requires removal of free product to the maximum extent practicable. 

• 40 CFR Part 280.64(a) – requires that the removal of free product be conducted in a manner 

that minimizes the spread of contamination into previously uncontaminated zones by using

techniques appropriate to the hydrogeologic conditions at the site. 

• 40 CFR Part 280.64(b) – requires the use of abatement of free product migration as a 

minimum objective for the design of the free product removal system. 

28 
TABLE 1 

ACTIVITY-SPECIFIC ARARS 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

Technology Element Regulation Applicabl

Asbestos Removal Asbestos Removal 

and Disposal 

40 CFR 61 Subpart M designates National Emission Standards for asbestos as defined as a hazardous air pollutant. X

30 TAC 111.145 – Control of Air Pollution From Visible Emissions And Particulate Matter X Air Emissions 

30 TAC 106.533 – Permit-by-Rule for Air Emissions During Remedial Activities X

Soil Excavation 

Erosion Control TPDES Construction General Permit, Permit No. TXR150000 X

40 CFR Part 280 – Technical Standards and Corrective Action for Owners and Operators of Underground Storage Tanks 30 TAC 334.85 discusses requirements for the management of wastes from UST releases. X

UST/NAPL Removal UST/NAPL 

Removal 

30 TAC 334.55 discusses permanent removal form service of abandoned USTs. X

Soil Washing Staging 40 CFR 264.554 – Staging Piles 

Temporary Units 40 CFR 264.553 – Temporary Units 

Waste Management On-site Management 

of Hazardous and Nonhazardous Waste 

40 CFR Part 262 – Standards Applicable to Generators of Hazardous Waste X

40 CFR Part 300.440 – Procedures for planning and implementing off-site response actions X40 CFR Part 261 – Identification and Listing of Hazardous Waste X

Nonhazardous Waste Disposal 

Off-site Disposal 

30 TAC 330 – Municipal Solid Waste 

29
TABLE 1 (Continued) 

ACTIVITY-SPECIFIC ARARS 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

Technology Element Regulation Applicabl

40 CFR Part 261 – Identification and Listing of Hazardous Waste X40 CFR Part 268 – Land Disposal Restrictions X40 CFR Part 300.440 – Procedures for Planning and Implementing Off-site Response Actions X40 CFR Part 761– Disposal of PCBs X30 TAC 335.61 through 335.70 – Standards Applicable to Generators of Hazardous Waste X

Hazardous Waste Disposal 

Off-site Disposal 

30 TAC 335.431 – Land Disposal Restrictions X

49 CFR Parts 171 and 172 – Hazardous Material Table, Special Provisions, Hazardous Materials Communication, EmergencyResponse Information and Training Requirements 

X

Hazardous Waste Disposal 

Hazardous Material Transportation 

30 TAC 350.36 – Relocation of Soils Containing Chemicals of Concern for Reuse Purposes 

Solidification and Staging 40 CFR Part 264.554 – Staging Piles Stabilization Temporary Units 40 CFR Part 264.553 – Temporary Units 

40 CFR Part 141– National Primary Drinking Water Standards X40 CFR Part 300.440 – Procedures for Planning and Implementing Off-site Response Actions XEPA Region 6 Human Health Medium-specific Screening Levels 

Monitored Natural Attenuation 

Ground Water Monitoring 

30 TAC 350.33(f) – Institutional Controls 

30
TABLE 1 (Continued) 

ACTIVITY-SPECIFIC ARARS 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

Notes: ARAR Applicable or Relevant and Appropriate Requirement RCRA Resource Conservation and Recovery Act TAC Texas Administrative CodeTBC To be considered CFR Code of Federal RegulationsTPDES Texas Pollutant Discharge Elimination System EPA U.S. Environmental Protection AgencyUST Underground storage tank

31
The Texas UST regulations contained in 30 TAC 334(d) are essentially identical to the federal regulations 

contained in 40 CFR Part 280.64. Additional regulations set forth in 30 TAC 350.33(f)(4)(E)(i-iv) 

require the achievement of performance criteria for NAPLs and are potential state ARARs. 

2.3.4.3 Management of Remediation Wastes 

The following regulations are potential action-specific ARARs regarding management of remediation 

wastes. 

Soil Excavation 

Soil cuttings/waste and water generated in the course of excavating soils, installing sheet piling, and 

installing monitoring wells are subject to the hazardous waste determination requirements to determine 

whether such wastes would be classified as hazardous (30 TAC 335.504). Soil excavation activities will 

occur within a discrete boundary identified as the area of contamination (AOC). As long as the material 

remains inside the AOC, it is not newly generated and will not be subject to hazardous waste generator, 

treatment, or other waste management requirements. Should the material be moved outside the AOC, the 

substantive requirements for managing hazardous waste (including land disposal restrictions) would be 

applicable. 

Off-site Disposal 

The regulations implementing the land disposal restrictions (LDR), including applicable LDR treatment 

standards at 30 TAC 335.431 are also ARARs for the off-site disposal of hazardous waste. Standards for 

waste characterization and standards for generators of hazardous waste with respect to reporting and 

manifesting when transporting hazardous waste may be found in 30 TAC 335.61 through 335.70. 

• The MDI site contains a large volume of nonhazardous debris and demolition wastes that will be 

removed and disposed of off site prior to redevelopment. The nonhazardous waste will need to 

be classified and disposed of in accordance with the applicable regulations at 30 TAC 330. 

• Off-site disposal of CERCLA waste (including investigation-derived waste/purge water) will 

need to comply with EPA’s Off-site Rule (40 CFR Part 300.440) and with all current federal 

and state regulations for transport of waste to the receiving facility.

• The regulations under the Hazardous Materials Transportation Law (49 U.S. Code §§ 5101-

5127) govern the transport of hazardous materials. 49 CFR Parts 171-172 are applicable to 

the off-site transport of wastes from the MDI site. 30 TAC 350.36 codifies additional 

requirements pertaining to the relocation of soils containing chemicals of concern for reuse 

purposes and may be a potential state action-specific ARAR. 

• 40 CFR Part 61, Subpart M regulates the identification, handling, and disposal of ACM and is 

applicable to the off-site disposal of the ACM wastes from the MDI site. 

32 
• Wastewater in pits at the MDI site contains PCBs. TSCA and its implementing regulations 

found at 40 CFR Part 761 might be applicable to the disposal of PCB-contaminated 

wastewater at the MDI site. Under TSCA, water containing more than 3 μg/L of PCBs may

not be disposed of in a publicly-owned treatment works. 40 CFR Part 761.60 provides for the 

disposal of PCB-containing liquids depending on the concentration of PCBs in the liquid. 

Soil Washing and Soil Stabilization/Solidification

The hazardous waste regulations for corrective action are relevant and appropriate to the on-site treatment 

of contaminated soil. Potential federal action-specific ARARs for on-site treatment of contaminated soils 

are contained in 40 CFR Part 264.554, which allows relief from LDRs for temporary storage (less than 2 

years) of remediation waste on contiguous property. Physical operations such as mixing, sieving, 

blending, etc. that are intended to prepare wastes for subsequent management or treatment are allowed to 

occur in staging piles, regardless of whether it technically meets the RCRA definition of treatment. 

Under 40 CFR Part 264.554, the following regulations are potential action-specific ARARs: 

• 40 CFR Part 264.554(d)(1) – requires the standards and design criteria to facilitate a reliable, 

effective, and protective remedy; prevent or minimize releases of hazardous wastes and 

hazardous constituents into the environment; and minimize or adequately control cross-media 

transfer as necessary to protect human health and the environment. It also requires that the 

remedy not operate for more than 2 years except when granted an operating term extension. 

• 40 CFR Part 264.554(d)(2) – requires consideration of the following factors when setting 

standards and design criteria: length of time the pile will be in operation, volumes of wastes 

planned for storage in the pile, physical and chemical characteristics of the wastes to be stored 

in the unit, potential for releases from the unit, hydrogeological and other relevant 

environmental conditions at the facility that may influence the migration of any potential 

releases, and potential for human and environmental exposure to potential releases from the 

unit. 

• 40 CFR Part 264.554(g) – placing hazardous remediation wastes into a staging pile does not 

constitute land disposal of hazardous wastes or create a unit that is subject to the minimum

technological requirements of RCRA 3004(o). 

• 40 CFR Part 264.554(h) – allows a staging pile to operate for up to 2 years. 

• 40 CFR Part 264.554(i) – allows a 180-day extension of the 2-year operating term. 

• 40 CFR Part 264.554(j) – requires closure of the staging pile within 180 days after operating 

term by removing or decontaminating all remediation waste, contaminated containment 

system components, structures and equipment contaminated with waste and leachate, and any 

contaminated subsoils. 

• State air pollution regulations under 30 TAC 106.533 may be applicable to potential air 

emissions from the treatment of soil. These permit-by-rule regulations address potential air 

emissions during remediation activities and establish allowable emissions for specific 

contaminants. 

33 
Backfilling at Site with Treated Soil 

Successful treatment of the hazardous soils will consist of addressing the LDR treatment standards and 

elimination of the hazardous toxicity characteristic. Having achieved both, the material will no longer be 

subject to RCRA hazardous waste requirements during subsequent management of the treated soils either 

on or off site. In the event that the treated soil is returned to the site, it will be managed in a manner that 

precludes direct contact by receptors. This may be accomplished by using a soil cover, or possibly by 

burial under roadways. ICs such as deed notices as described in 30 TAC 350.111(f) will also be required. 

Depending upon the ultimate disposition of the waste, engineering controls such as fencing and signs may

also be necessary. 

Temporary Storage of NAPL 

Potential action-specific ARARs for the temporary storage of recovered NAPL are contained in 40 CFR 

Part 280. Because it has not been determined that the NAPL meets the definition of a RCRA hazardous 

waste, these regulations may not be applicable until a final determination is made. However, using the 

relevant and appropriate criteria listed in 40 CFR Part 300.400(g)(2), it has been determined that these 

regulations are relevant and appropriate. Potential state action-specific ARARs are codified in 30 TAC 

334.85, which discusses requirements for the management of wastes from UST releases. 

2.3.4.4 On-site Treatment of Contaminated Soil 

Potential federal action-specific ARARs for on-site treatment of contaminated soils are contained in 40 

CFR Part 264.554, which allows relief from LDRs for temporary storage (less than 2 years) of 

remediation waste on contiguous property. Physical operations such as mixing, sizing, blending, etc. that 

are intended to prepare wastes for subsequent management or treatment are allowed to occur in staging 

piles, regardless of whether it technically meets the RCRA definition of treatment. The regulations found 

in 40 CFR Part 264.554 as described previously also apply.

2.3.4.5 Temporary Storage of Recovered NAPL 

Potential action-specific ARARs for the temporary storage of recovered NAPL are contained in 40 CFR 

Part 280. Because it has not been determined that the NAPL meets the definition of a RCRA hazardous 

waste, these regulations may not be applicable until a final determination is made. However, using the 

relevant and appropriate criteria listed in 40 CFR Part 300.400(g)(2), it has been determined that these 

regulations are relevant and appropriate. Potential state action-specific ARARs are codified in 30 TAC 

334.85, which discusses requirements for the management of wastes from UST releases. 

34 
2.3.4.6 Ground Water Monitoring in Support of MNA Remedy 

• RCRA ground water monitoring requirements found in 40 CFR Part 264 may be relevant and 

appropriate for the MNA remedy if hazardous constituents in ground water are similar or 

identical to RCRA waste. 

2.3.4.7 Control of Air Emissions 

The following regulations are potential action-specific ARARs regarding treatment and control of air 

emissions related primarily to asbestos RAs: 

• 30 TAC 111.145 regulates air pollution from visible sources and particulate matter. 

• Occupational Safety and Health Administration regulation 29 CFR Part 1910.1001 requiring 

worker protection measures for engineering controls, worker training, labeling, bagging of 

waste, and respiratory protection with a permissible exposure level of 0.2 fiber/cubic 

centimeter (f/cc). 29 CFR Part 1926.58 requires worker protection measures for all 

construction work involving asbestos, including demolition and renovations and requires 

respiratory protection with a permissible exposure level of 0.2 f/cc. 

• U.S. Department of Transportation regulation 49 CFR Parts 171 and 172 regulates the 

transportation of asbestos-containing waste material and requires waste containment and 

shipping documentation. 

• The Texas Asbestos Health Protection Act codified in Chapter 1954 of the Texas 

Occupations Code requires specific regulations relating to asbestos abatement. 

• TCEQ has established Effects Screening Levels (ESL) for asbestos with a short-term

exposure level of 0.03 microgram per cubic meter. 

2.3.5 To Be Considered 

In addition to ARARs, the preamble to the NCP provides agency advisories, criteria, or other “TBC 

guidance in helping to determine what is protective at a site or how to carry out certain actions or 

requirements” (55 Federal Register 8666, 8745, dated March 9, 1990). The preamble to the NCP states, 

however, that provisions in the TBC category “should not be required as cleanup standards because they

are, by definition, generally neither promulgated nor enforceable, so they do not have the same status 

under CERCLA as do ARARs.” 

EPA Region 6 MSSLs (EPA 2003) for tap water are TBCs for those compounds detected that do not have 

promulgated federal standards for ground water. The medium-specific levels have been developed at the 

10-6 risk level. This corresponds to the point of departure level for establishing preliminary remediation 

goals. 

35 
The Texas Risk Reduction Program Rule (30 TAC 350) is also a TBC. The HHRA was used to evaluate 

the risks posed by site COPCs and may also be used to establish appropriate cleanup levels for

contaminants in soil (Tetra Tech 2003d). 

2.4 GENERAL RESPONSE ACTIONS 

GRAs are medium-specific actions capable of achieving the RAOs. GRAs for remediation at 

conventional Superfund sites may include actions such as treatment, containment, separation, extraction, 

disposal, collection, ICs, or a combination of these and other general actions. EPA presumptive remedy

guidance establishes treatment and/or containment of contaminated media as the GRA for metals-in-soils 

sites (EPA 1999). Treatment can be combined with other appropriate general actions to accomplish the 

RAOs. To accomplish the RAO for ground water, the migration of the contaminants may be monitored to 

assess off-site migration or natural attenuation. Consequently, GRAs may include treatment, 

containment, reduction/separation, disposal, extraction, monitoring, and ICs. 

36 
3.0 IDENTIFICATION OF TECHNOLOGIES 

EPA developed presumptive remedies based on information acquired from evaluating and remediating 

certain categories of sites with similar contaminants to accelerate cleanups at Superfund sites. 

“Presumptive remedies are preferred technologies or response actions for sites with similar 

characteristics” (EPA 1999). EPA has developed presumptive remedies for metals-in-soils sites and 

presumptive response strategy and ex situ treatment technologies for contaminated ground water. The use 

of presumptive remedies is expected to expedite the remedy selection process by limiting the available 

alternatives considered for the FS. The presumptive remedies advance the FS process directly to the 

detailed analysis of alternatives (EPA 1999). 

The presumptive remedies for sites where metals-in-soils sites are principal threats are 

reclamation/recovery or immobilization. The presumptive remedy for low-level threat wastes found at 

metals-in-soils sites is containment. In keeping with EPA’s goal of resource conservation, EPA’s 

preferred treatment technology for metals-in-soil sites is reclamation/recovery (EPA 1999). As requested 

by EPA, excavation and disposal will also be considered. The presumptive remedies for treating ground 

water contaminated with metals include chemical precipitation, ion exchange/adsorption, and 

electrochemical methods (EPA 1999). 

Potential technologies have been developed for treatment, containment, or disposal of contaminated soil 

and for recovery/treatment or monitoring of contaminated ground water. The NCP requires development 

of a range of alternatives that address principal threats posed by the site, but that vary in the degree of 

treatment employed and the quantities and characteristics of untreated wastes that must be managed. The 

technologies to be evaluated are: 

• Technology 1 – Soil Washing/Leaching 

• Technology 2 – Solidification/Stabilization 

• Technology 3 – Containment 

• Technology 4 – On-site Disposal 

• Technology 5 – Off-site Disposal 

• Technology 6 – ICs 

• Technology 7 – MNA 

37
Although ICs have been listed as a technology that should be evaluated on its own merit, successful 

implementation of several of the remedies detailed in later sections will require incorporation and 

implementation of ICs. 

3.1 TECHNOLOGY 1 – SOIL WASHING/LEACHING 

Soil washing is an ex situ remediation technology that uses physical separation and aqueous-based 

separation to reduce contaminant concentrations. Soil washing does not detoxify or significantly alter the 

contaminant. The technology transfers the contaminant from the soil into the washing fluid or

concentrates the contaminant into a smaller mass for subsequent treatment (EPA 1999). The process 

involves (1) excavation of the contaminated soil, (2) mechanical screening to remove oversized materials, 

(3) separation processes to generate coarse-and fine-grained fractions, (4) treatment of those fractions 

(soil washing), and (5) management of the generated residuals. It is a separation and volume reduction 

process that is used typically in conjunction with other technologies (EPA 1999). 

Soils equal to or greater than action levels will be excavated and stockpiled for treatment. Contaminants 

tend to bind chemically and physically to clay and silt particles. The silt and clay, in turn, tend to attach 

physically to sand and gravel. Clay and silt particles and surficial contaminants are first separated from

the sand and gravel through an abrasive scouring and scrubbing action in a step that uses wash water. The 

soil is then separated from the spent washing fluid, which carries some of the contaminants. The 

recovered soil consists of a clean, coarse fraction (sand and gravel) and a contaminated fine fraction (silt 

and clay). After successful testing, the washed soil is returned to the site. The bulk of the contaminants 

are contained in the aqueous phase and in the contaminated fines. These materials would undergo 

stabilization/solidification, and be disposed of off site. Because of the fine-grained nature of the 

sediments at the MDI site, this technology would not be cost-effective. Consequently, it is not being 

retained for further analysis. 

3.2 TECHNOLOGY 2 – SOLIDIFICATION/STABILIZATION 

This technology entails excavating and immobilizing the contaminants present in the surface and 

subsurface soils. Solidification/stabilization technology will be used to process the contaminated soil. 

The stabilization process is beneficial and will achieve the desired elimination of the hazardous toxicity

characteristic by eliminating or otherwise significantly mitigating the mobility of the lead within the 

excavated soils. Typical stabilization reagents are cement kiln dust, proprietary agents, cement, fly ash, 

blast furnace slag, and bitumen. The reagents are selected based on soil characteristics and the metal 

contaminants present. Once the on-site contaminated soils are mixed with the stabilization reagents, the 

soils will be disposed of on site or off site, with the location dictated by redevelopment plans. 

38
Soils equal to or greater than action levels will be excavated and stockpiled for treatment. The soils will 

be staged in the northwest corner of the site, where the contractor will perform soil stabilization. The 

waste soil will be stabilized such that resultant metals concentrations are below TCLP requirements set in 

40 CFR Part 261.24 and LDR requirements set forth in 40 CFR Part 268.34(e)(1). 

3.3 TECHNOLOGY 3 – CONTAINMENT 

This technology consists of containment of metals-in-soils wastes along with vertical or horizontal 

barriers. These remedial technologies can provide sustained isolation of contaminants and can prevent 

mobilization of soluble compounds over long periods of time. They also reduce surface water infiltration, 

control odor and gas emissions, provide a stable surface over wastes, limit direct contact, and improve 

aesthetics. Containment may also restrict the future uses of the site. ICs are generally used in 

conjunction with containment to further limit the potential for unintended access to the waste materials 

(EPA 1999). 

Horizontal barriers or caps minimize the infiltration of water through the contaminated media as well as 

exposure to potential receptors. Vertical barriers minimize the movement of contaminated ground water 

off site or limit the flow of uncontaminated ground water on site. Common vertical barriers include slurry

walls in excavated trenches, grout curtains formed by injecting grout into soil borings, and sheet pile 

walls. For the MDI site, sheet piling is appropriate, given the shallow depth to the top of the aquitard 

beneath the SWBZ (less than 30 feet bgs). 

The high ground water table and transmissive nature of sediments, especially near the north pond would 

require a pressure relief system (ground water extraction system) to be installed if vertical barriers are 

installed to prevent mounding of the shallow ground water. 

An on-site cell would need to be constructed over low-permeability native soils, and not the foundry sand 

fill materials. For planning purposes, it has been assumed that the cell will extend to 3 feet bgs, and be 

completed approximately 3 feet above ground surface. It is anticipated that a cell with such vertical 

dimensions will cover a footprint of approximately 300 feet by 300 feet. Depending upon the ultimate 

redevelopment plan, possible locations include the southwest corner of the site and along the eastern 

fence line west of the National Vinegar facility. Implementation of this technology will also require the 

implementation of ICs in order to be protective. 

Much of the contaminated soil at the site is overlain by 12 to 18 inches of concrete. This concrete acts as 

an effective barrier to infiltration. Given the low solubility of the concrete, the soils beneath the concrete 

do not pose a significant risk as long as the concrete is not disturbed. In the event that contaminated soils 

39
are left in place beneath the concrete, an IC would be required to ensure that these soils remain 

undisturbed, and that any removal of the concrete would trigger additional cleanup requirements. 

3.4 TECHNOLOGY 4 – ON-SITE DISPOSAL 

Soils will be treated in accordance to alternative treatment standards as described in 40 CFR Part 268.49 

(c)(1)(C). Treated soils may be left on site in the event that contaminant levels no longer constitute a 

characteristically hazardous waste as defined in 40 CFR Part 261.24 and meet the LDRs set in 40 CFR 

Part 268.34(e)(1). Because the soils will retain their original total lead concentrations, the treated soils 

must be returned to the site in a manner that will mitigate direct exposure to residential receptors. This 

may include placement under roadways or in an area underlain with low-permeability soils, and then 

covered with a clean fill soil cover. Excavated areas on site will be backfilled with clean fill that has been 

brought on site from an off-site source. Ground water monitoring will be performed with this alternative 

to monitor the migration of contamination in the ground water. Implementation of this technology will 

also require the implementation of ICs in order to be protective. 

3.5 TECHNOLOGY 5 – OFF-SITE DISPOSAL 

Soils will be treated in accordance with alternative treatment standards as described in 40 CFR Part 

268.49 (c)(1)(C), with resultant concentrations below levels that would result in classification as a 

hazardous waste for toxicity established in 40 CFR Part 261.24. Since soils at MDI were only hazardous 

per toxicity and will be treated below the TCLP limit for definition as a hazardous waste, they may be 

disposed of in a Subtitle D landfill. Prior to disposal at a Subtitle D landfill, the soils will be sampled and 

analyzed to ensure that hazardous constituents are not present at concentrations above their respective 

Universal Treatment Standards (UTS), as listed in 40 CFR Part 268.48. 

Excavated areas on site will be backfilled with clean fill that has been brought on site from an off-site 

source. Ground water monitoring will be performed with this alternative to monitor the migration of 

contamination in the ground water. Implementation of this technology will also require the 

implementation of ICs in order to be protective. 

3.6 TECHNOLOGY 6 – INSTITUTIONAL CONTROLS 

ICs are non-engineered instruments such as administrative and/or legal controls that minimize the 

potential for human exposure to contamination by limiting land or resource use. They are meant to 

supplement engineering controls and may be a necessary component of the completed remedy (EPA 

2000b). ICs may be required to mitigate the risk associated with exposure to ground water and treated 

40
soils, if left on site. Of the four types of ICs (governmental controls, proprietary controls, enforcement 

and permit tools with IC components, and informational devices), informational devices are most likely

appropriate for the site. An example of an informational device is a deed notice. As defined in 30 TAC 

350.4(a)(22) a deed notice is: 

An instrument filed in the real property records of the county where the affected property is 

located that is intended to provide to owners, prospective buyers, and others notice and 

information regarding, but which does not, by itself, restrict use of the affected property.

The State of Texas would be responsible for the implementation and enforcement of ICs (EPA 2000b)

and has the authority to do so under 30 TAC 350.33(f). In addition to deed notices, engineering controls 

such as soil covers, fencing, and signs, may also be required to eliminate or minimize the potential for 

direct exposure to contaminants. 

3.7 TECHNOLOGY 7 – MONITORED NATURAL ATTENUATION 

Natural attenuation is defined in the NCP as “biodegradation, dispersion, dilution, and adsorption” of 

contaminants in ground water. Natural attenuation differs from the “No Action” Alternative because 

natural attenuation has a monitoring component and is expected to attain cleanup levels in a reasonable 

timeframe. Natural attenuation may be an appropriate remedial approach for portions of the contaminant 

plume when combined with other remedial measures needed to control and/or remediate source areas. 

Permanence monitoring should be performed with natural attenuation to assure natural attenuation is 

occurring, and ICs should be implemented with natural attenuation to ensure that contaminated ground 

water is not used before protective concentrations are achieved (EPA 1999). 

In order to assess the viability of MNA as a remedial technology at the MDI site, limited ground water 

modeling was performed using existing data from the RI (Appendix A). The screening-level model 

BIOSCREEN Version 1.4 (EPA 1997a) was used to assess the migration of the PAHs, benzo(a)pyrene, 

and dibenzo(a,h)anthracene from the MDI site via the ground water pathway. 

The BIOSCREEN simulation results that show concentrations of benzo(a)pyrene and 

dibenzo(a,h)anthracene continue to pose a risk for very short distances beyond the source area after both 

30 years and 100 years. The concentrations of these COPCs decrease sharply with distance from the 

source areas, which is consistent with the current distribution of these constituents within the SWBZ 

(note, no PAHs have been detected in downgradient monitoring well MW-02). This suggests that the 

PAHs present at MW-03 are primarily sorbed onto the porous media with only limited partitioning of the 

contaminants into ground water occurring at the site. 

41
Based on field data, both hydrological and chemical, and reasonable estimates of variables of fate and 

transport of benzo(a)pyrene and dibenzo(a,h)anthracene in the SWBZ, a threat of contamination much 

beyond the source area is not likely to occur. The action of monitoring the shallow aquifer for 

benzo(a)pyrene and dibenzo(a,h)anthracene that could originate from the PAH source remaining in the 

shallow soil or the SWBZ, with no other action on the solute plume, should be sufficiently protective of 

the ground water resource outside the source area at MW-03 and off site. Implementation of this 

technology will also require the implementation of ICs in order to be protective. 

3.8 SCREENING OF TECHNOLOGIES

The previously listed technologies were screened in terms of general effectiveness, implementability and 

relative cost based on site conditions. This screening is summarized in Table 2. Of the technologies 

screened, only soil washing was deemed inappropriate for the MDI site. Use of this technology results in 

washing of the coarse fraction of the sediments, with contaminants confined to the finer grained materials. 

Unfortunately, at the MDI site, with the exception of localized sandy fill materials, the surface deposits at 

MDI are primarily fine grained, consisting of silts and clays. Because of this, the technology is likely to 

be ineffective.

42
TABLE 2 

EVALUATION OF REMEDIATION TECHNOLOGIES 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

General 

Response 

Action 1

Remedial 

Technology 

Type Process Option 

Media 

Addressed Effectiveness Implementability 

Physical Separation 

Soil Washing Soil May not be able to achieve

RAOs using this technology; has an unknown removal efficiency; reduces toxicity of the waste. 

Not technically feasible; soicontain more than 60 percenfines; equipment and resourreadily available 

Treatment 

Solidification/Stabilization(Immobilization)

Solidification/Stabilization

Soil Able to achieve RAOs using 

this technology; reduces waste mobility; minimizes short-termimpacts; affords long-termprotection.

Simple technology with highthroughput; equipment andresources readily available 

On-site Disposal Soil returned to

site and placed in either a containment cell with low permeability cover or beneath a roadway to mitigate exposure.

Soil Able to achieve RAOs in 

conjunction with treatment; treatment will result in removal of RCRA hazardous waste characteristic; treated soil may be used as fill material on site. 

Simple technology with highthroughput; equipment andresources readily available 

Disposal 

Off-site Disposal RCRA Subtitle D 

Landfill 

Soil Able to achieve RAOs in 

conjunction with treatment; reduces the volume of waste; minimizes residual risk; affords long-term protection. 

Simple technology with highthroughput; equipment andresources readily available 

43
TABLE 2 (Continued) 

EVALUATION OF REMEDIATION TECHNOLOGIES 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

General 

Response 

Action 1

Remedial 

Technology 

Type Process Option 

Media 

Addressed Effectiveness Implementability 

Containment Physical 

Containment/Capping 

Soil/Clay Cap/Concrete 3

Soil andGroundWater 

Able to achieve RAOs using this technology in conjunctionwith treatment; reduces waste mobility; minimizes short-termimpacts; affords long-termprotection.

Simple technology; implementation time is relatively short; equipmentand resources readily availab

Monitored Natural Attenuation

Ground Water Monitoring

Ground Water Monitoring

GroundWater 

Provides a measure of natural degradation processes; does not meet RAOs without implementation of institutional controls. 

Simple technology requiringroutine ground water samplifor standard chemical analyt

Institutional Controls

Not Applicable 2 Deed Notice Soil and 

GroundWater 

Provides a measure of short and long-term protection; restricts site access; provides warning. 

Simple technology; rapid implementation; equipmentand resources readily availab

Notes: 1 Several of the general response actions listed in column 1 must be combined in order for a particular remedy to meet remedial action ob

disposal, and monitored natural attenuation will all require the implementation of institutional controls in the form of deed notices to enor contaminated soil is minimized. 

2 An institutional control is not a remedial technology. It is used in conjunction with a remedial technology to minimize exposure to a co

3 In the event that contaminated soils beneath concrete are left in place (Alternative 5), the existing concrete will serve as a cap and can m

RAO Remedial action objective RCRA Resource Conservation and Recovery Act 

44
4.0 COMPARATIVE ANALYSIS OF ALTERNATIVES 

 Alternatives were developed to address the RAOs within an acceptable time frame. These alternatives 

were formulated so that the resulting site will be useful for residential purposes. As well, the range 

includes alternatives that, to the maximum extent feasible, minimize the need for long-term management. 

The No Action Alternative has been retained as a baseline for comparison, as required by the NCP. 

Technologies identified in the presumptive remedy guidance were detailed in Section 3. The remaining 

soil and ground water technologies (along with No Action as required by the NCP) have been combined 

in the following remedial alternatives: 

Alternative 1 – No Action 

Alternative 2 – Soil Stabilization/Solidification with On-site Disposal; Ground Water via MNA with ICs 

Alternative 3 – Soil Stabilization/Solidification with Off-site Disposal; Ground Water via MNA with ICs 

Alternative 4 – Soil Containment; Ground Water via MNA with ICs 

Alternative 5- Solidification/Stabilization and Off-site Disposal of Soils in Unpaved Areas; Ground 

Water via MNA with ICs 

Each of these alternatives is detailed in the following sections. Costs associated with implementing each 

of these alternatives have been developed and included as Appendix B of this FS report. One of the key

elements in preparing the FS report is evaluating how each of the alternatives will comply with ARARs. 

This evaluation has been summarized in Table 3. 

4.1 EVALUATION CRITERIA 

This section presents the criteria used to evaluate the potentially applicable remedial technologies and 

summarizes those technologies that satisfied the criteria. NCP and SARA provide basic criteria for 

screening technologies. These criteria are effectiveness, implementability, and cost. Using the elements 

of the effectiveness criterion, each technology is evaluated and compared among similar technologies. 

Alternatives that provide significantly less effectiveness than other more promising technologies are 

eliminated.

45 
TABLE 3 

SUMMARY OF ARARS 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

ALTERNATIVE 

1 2 3 4 

ARAR 

No

Action 

Solidification/

Stabilization with 

On-site Disposal; 

Ground Water via

MNA with Institutional 

Controls 

Solidification/

Stabilization with 

Off-site Disposal; 

Ground Water via

MNA with Institutional 

Controls 

Containment with 

Institutional Controls 

Solidifi

Off-s

Unpaved 

MNA w

Chemical-Specific ARARs for Soils 

Lead: 30 TAC 350.– Texas Risk Reduction Rule(TBC) -- 

Residual leadconcentrations in soils outside of disposal areato be below 500 mg/kg 

Residual leadconcentrations in soils tobe below 500 mg/kg 

Soils to be stabilized tominimize migration 

Residual lto be beloareas. 

NAPL/PAHs: 30 TAC 334Subchapter D discusses requirements for correctiveaction and the managementof wastes from USTreleases 30 TAC 334.55 discusses permanent removal formservice of abandoned USTs (Non-CERCLA) 

-- 

NAPL to be removed from site during excavation; UST on site was not properly abandoned, and must be removed. 

NAPL removed fromsite during excavation;UST on site was not properly abandoned, and must be removed. 

NAPL to be removed fromsite during excavation;UST on site was not properly abandoned, and must be removed. 

NAPL to during exnot properemoved. 

Chemical-Specific ARARs for Ground Water 

40 CFR Part 141 – National Primary Drinking Water Standards for PAHs (Relevant and Appropriate) 

-- 

PAHs below MCLs; water quality measured at former waste location and downgradient toassess MNA. 

PAHs below MCLs; water quality measured at former waste location and downgradient toassess MNA. 

PAHs below MCLs; water quality measured at former waste location and downgradient to assessMNA. 

PAHs belmeasured and down

46
TABLE 3 (Continued) 

SUMMARY OF ARARS 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

ALTERNATIVE 

1 2 3 4 

ARAR 

Location-Specific ARARs 

40 CFR Part 6 – Floodplainor Wetland Environments(Applicable) 

-- 

NA at MDI site; site is not within floodplain orwetlands. 

NA at MDI site; site is not within floodplain orwetlands. 

NA at MDI site; site is notwithin floodplain or wetlands. 

NA at MDfloodplain 

 Endangered Species Act(Applicable) --

NA at MDI site; noendangered species present

NA at MDI site; noendangered species present

NA at MDI site; noendangered species present

NA at MDspecies pr

 National Historic Preservation Act (Applicable) 

-- 

NA at MDI site; nohistoric structures present

NA at MDI site; nohistoric structures present

NA at MDI site; nohistoric structures present

NA at MDpresent.

Archaeological and Historic Preservation Act (Applicable) 

-- 

NA at MDI site; noarcheological or historic relics identified

NA at MDI site; noarcheological or historic relics identified

NA at MDI site; noarcheological or historic relics identified

NA at MDhistoric re

Activity-Specific ARARs 

40 CFR Part 61, Subpart M, designates NationalEmission Standards for asbestos and establishes procedures for asbestosemission control during demolition and renovationactivities. (Applicable) 

-- 

Will meet via proper emission controls, suchas wetting and leak-tightwrapping, asappropriate, during removal activities. 

Will meet via proper emission controls, suchas wetting and leak-tightwrapping, as appropriate, during removalactivities. 

Will meet via proper emission controls, such aswetting and leak-tightwrapping, as appropriate, during removal activities. 

Will meet controls, stight wrapremoval a

No

Action 

Solidification/

Stabilization with 

On-site Disposal; 

Ground Water via

MNA with Institutional 

Controls 

Solidification/

Stabilization with 

Off-site Disposal; 

Ground Water via

MNA with Institutional 

Controls 

Containment with 

Institutional Controls 

Solidifi

Off-s

Unpaved 

MNA w

47
TABLE 3 (Continued) 

SUMMARY OF ARARS 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

ALTERNATIVE 

1 2 3 4 

ARAR 

Activity-Specific ARARs (Continued) 

40 CFR Part 261 – Identification and Listing of Hazardous Waste -- 

Wastes for on-site disposal to be tested using TCLP prior todisposal

Wastes for off-site disposal to be tested using TCLP prior todisposal

NA Wastes fo

tested usin

40 CFR Part 262 – Standards Applicable toGenerators of HazardousWaste (Applicable) 

-- 

NA RCRA standards for the 

identification and manifesting of hazardouswastes to be followed, if required. 

NA RCRA sta

and manifto be follo

40 CFR Part 264.554 –Staging Piles (Relevant and Appropriate) -- 

Staging piles will bedelineated, managed,and closed in accordance with the substantive requirements. 

Staging piles will bedelineated, managed, and closed in accordancewith the substantive requirements. 

NA Staging pi

managed, with the s

40 CFR Part 268 – LandDisposal Restrictions (See each alternative for ARAR determination) 

-- 

Relevant and appropriate for the testing ofstabilized wastes to be disposed of on site. 

Applicable for off-site disposal of wastes to be tested via TCLP prior to disposal; disposal at a permitted landfill. 

NA Applicabl

wastes to disposal; dlandfill. 

40 CFR Part 280, 30 TAC 334. Subtitles C and D 

--

This cleanup will address UST wastes in accordance with Federal and State requirements. 

This cleanup will address UST wastes in accordance with Federal and State requirements. 

This cleanup will address UST wastes in accordance with Federal and State requirements. 

This cleanwastes in and State 

No

Action 

Solidification/

Stabilization with 

On-site Disposal; 

Ground Water via

MNA with Institutional 

Controls 

Solidification/

Stabilization with 

Off-site Disposal; 

Ground Water via

MNA with Institutional 

Controls 

Containment with 

Institutional Controls 

Solidifi

Off-s

Unpaved 

MNA w

48
TABLE 3 (Continued) 

SUMMARY OF ARARS 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

ALTERNATIVE 

1 2 3 4 

ARAR 

Activity-Specific ARARs (Continued) 

40 CFR Part 300 Section400 – Procedures forPlanning and Implementing Off-site Response Actions(Applicable) 

-- 

CERCLA wastes will bedisposed of off site atfacilities in compliance with off-site rule provisions. 

CERCLA wastes will bedisposed of off site atfacilities in compliance with off-site rule provisions. 

CERCLA wastes will bedisposed of off site atfacilities in compliance with off-site rule provisions. 

CERCLA off site at with off-s

40 CFR Part 761.60 –Disposal Requirements–PCBs (Applicable) 

-- 

Wastewater containing PCBs to be disposed ofat a permitted facility. 

Wastewater containing PCBs to be disposed ofat a permitted facility. 

Wastewater containing PCBs to be disposed of ata permitted facility. 

Wastewatdisposed o

49 CFR Parts 171 and 172 – USDOT Regulations forTransport of Hazardous Materials (Applicable) 

-- 

Hazardous materials to be transported off site will be labeled and placarded according to the regulations; contractors to provide proper documentation. 

Hazardous materials to be transported off site will be labeled and placarded according to the regulations; contractors to provide proper documentation. 

Hazardous materials to be transported off site will belabeled and placarded according to the regulations; contractors toprovide properdocumentation.

Hazardouoff site wiaccording contractordocument

30 TAC 111.145 – Visible and Particulate Emission Standards (Applicable) 

-- 

Will meet visible emission standard using fugitive dust controls, such as wetting, and will confirm compliance viaair monitoring duringexcavation activities. 

Will meet visible emission standard using fugitive dust controls, such as wetting, and will confirm compliance viaair monitoring duringexcavation activities. 

Will meet visible emissionstandard using fugitive dust controls, such as wetting, and will confirmcompliance via air monitoring during excavation activities. 

Will meet using fugiwetting, avia air moactivities. 

No

Action 

Solidification/

Stabilization with 

On-site Disposal; 

Ground Water via

MNA with Institutional 

Controls 

Solidification/

Stabilization with 

Off-site Disposal; 

Ground Water via

MNA with Institutional 

Controls 

Containment with 

Institutional Controls 

Solidifi

Off-s

Unpaved 

MNA w

49
TABLE 3 (Continued) 

SUMMARY OF ARARS 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

ALTERNATIVE 

1 2 3 4 

ARAR 

Activity-Specific ARARs (Continued) 

30 TAC 106.533 – Permitby Rule for Air Emissions during Remedial Activities (Applicable) 

-- 

Will employ fugitive dust controls and meetapplicable standards for specific contaminants, as appropriate; compliance will be confirmed via air monitoring during excavation activities. 

Will employ fugitive dust controls and meetapplicable standards for specific contaminants, as appropriate; compliance will be confirmed via air monitoring during excavation activities. 

Will employ fugitive dust controls and meetapplicable standards for specific contaminants, as appropriate; compliance will be confirmed via air monitoring during excavation activities. 

Will empland meet specific cocompliancmonitorinactivities. 

TPDES ConstructionGeneral Permit, Permit No.TXR150000(Applicable) 

-- 

Substantive provisionswill be met throughimplementation ofconstruction runoffcontrols. 

Substantive provisionswill be met throughimplementation ofconstruction runoffcontrols. 

Substantive provisionswill be met throughimplementation ofconstruction runoffcontrols. 

Substantivthrough imconstructi

30 TAC 335R, Waste Classification – Establishes procedures for testing andclassifying waste for disposal(Applicable) 

-- 

Wastes to be disposed ofoff site will be tested andclassified for off-site disposal according toState requirements. 

Wastes to be disposed ofoff site will be tested andclassified for off-site disposal according toState requirements. 

Wastes to be disposed ofoff site will be tested andclassified for off-site disposal according to State requirements. 

Wastes to be tested adisposal arequireme

30 TAC 335.61 through 70– Standards for Generatorsof Hazardous Waste (Applicable) 

-- 

Will meet as detailed inRCRA 40 CFR.

Will meet as detailed inRCRA 40 CFR.

NA Will meet 

CFR. 

No

Action 

Solidification/

Stabilization with 

On-site Disposal; 

Ground Water via

MNA with Institutional 

Controls 

Solidification/

Stabilization with 

Off-site Disposal; 

Ground Water via

MNA with Institutional 

Controls 

Containment with 

Institutional Controls 

Solidifi

Off-s

Unpaved 

MNA w

50
TABLE 3 (Continued) 

SUMMARY OF ARARS 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

ALTERNATIVE 

1 2 3 4 

ARAR 

Activity-Specific ARARs (Continued) 

30 TAC 335.431 – Industrial Solid Waste andMunicipal Hazardous Waste, Subchapter O, LandDisposal Restrictions (Applicable) 

-- 

Will meet as detailed inRCRA 40 CFR.

Will meet as detailed inRCRA 40 CFR.

Will meet as detailed inRCRA 40 CFR.

Will meet CFR. 

30 TAC 350.36 – Relocation of Soils Containing Chemicals of Concern for Reuse Purposes (TBC) 

-- 

Wastes to be disposed ofon site will be tested andclassified for disposal according to State requirements. 

NA NA NA

No

Action 

Solidification/

Stabilization with 

On-site Disposal; 

Ground Water via

MNA with Institutional 

Controls 

Solidification/

Stabilization with 

Off-site Disposal; 

Ground Water via

MNA with Institutional 

Controls 

Containment with 

Institutional Controls 

Solidifi

Off-s

Unpaved 

MNA w

51
TABLE 3 (Continued) 

SUMMARY OF ARARS 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

Notes: ARAR Applicable or Relevant and Appropriate RequirementCERCLA Comprehensive Environmental Response Compensation and Liability Act CFR Code of Federal RegulationsMCL Maximum Contaminant LimitMDI Many Diversified Interests mg/kg Milligram per kilogramMNA Monitored natural attenuationNA Not applicable NAPL Nonaqueous-phase liquid PAH Polycyclic aromatic hydrocarbon PCB Polychlorinated biphenyl RCRA Resource Conservation and Recovery Act TAC Texas Administrative Code TBC To be considered TCLP Toxicity Characteristic Leaching Procedure TPDES Texas Pollutant Discharge Elimination System USDOT U.S. Department of Transportation UST Underground storage tank

52
According to the statutory requirements that guide the evaluation of remedial alternatives in an FS, a RA 

must achieve the following objectives: 

• Protect human health and the environment 

• Attain ARARs or define criteria for invoking a waiver 

• Be cost effective 

• Use permanent solutions to the maximum extent practicable. 

EPA has established nine evaluation criteria to address these statutory requirements for CERCLA. The 

criteria can be classified into the categories of threshold criteria, primary balancing criteria, and 

modifying criteria. Section 5 evaluates each potential RA alternative. The evaluation is based on seven 

of the nine criteria. Modifying criteria (state or support agency acceptance and community acceptance) 

will be evaluated after the public comment period on the FS and proposed plan and prior to the 

finalization of the Record of Decision (ROD). The evaluation criteria categories and nine evaluation 

criteria are presented below. (Note: only eight are listed because state or support agency acceptance and 

community acceptance are discussed together.) 

4.1.1 Threshold Criteria 

These threshold criteria are requirements that each alternative must achieve to be eligible for selection as 

a permanent remedy: 

• Overall Protection of Human Health and the Environment – The overall protection of 

human health and the environment is evaluated for each alternative on the basis of the 

alternative’s ability to reduce the risk of exposure to contaminants from potential exposure 

pathways through engineering or ICs. Each alternative also is examined to determine 

whether it creates unacceptable short-term risks to human health.

• Compliance with ARARs – This criterion evaluates each alternative’s compliance with 

location-specific, chemical-specific, and action-specific ARARs. It also evaluates the 

potential for a waiver. These ARARs were identified and screened for relevance to the site in 

Section 2.1. Table 3 summarizes the ARARs that have been evaluated for this FS, and briefly 

states how the ARAR will be complied with. 

4.1.2 Primary Balancing Criteria 

These primary balancing criteria are factors that identify key tradeoffs among alternatives: 

• Long-term Effectiveness and Permanence – Long-term effectiveness and permanence are 

evaluated for each alternative on the basis of the magnitude of residual risk and the adequacy

and reliability of controls used to manage remaining waste after response objectives have 

53 
been achieved. Alternatives that offer long-term effectiveness and permanence halt, or 

otherwise mitigate, any potential for off-site contaminant transport and minimize the need for 

future engineering controls. 

• Short-term Effectiveness – The evaluation of alternatives for short-term effectiveness takes

into account protection of remedial workers, members of the community, and the 

environment during implementation of the RA and the time required to achieve cleanup 

goals. In this FS, schedule estimate durations are based on projected availability of materials 

and labor and may have to be updated at the time of remediation. Estimated durations are 

also are based on good weather, the ability to create and receive adequate and authorized 

access, and the availability of required utilities. All time estimates assume that the selected 

remedial design, including construction drawings, has been approved and that all negotiations

with contractors have been concluded. 

• Reduction of Mobility, Toxicity, or Volume through Treatment – The statutory

preference is to select a RA that employs treatment to reduce the mobility, toxicity, or volume 

of hazardous substances. The degree to which alternatives employ recycling or treatment is 

assessed, including how treatment is used to address the principal threats posed by the site. 

• Implementability – Each alternative is evaluated with respect to the technical and 

administrative feasibility of implementing the alternatives as well as the availability of 

necessary equipment and services. This criterion includes such items as the ability to obtain 

services, capacities, equipment, and specialists necessary to construct components of the 

alternative; the ability to operate and monitor the permanence and effectiveness of the 

technologies; and the ability to obtain necessary approvals from other agencies. 

• Cost – Accuracy of present worth costs is +50/-30 percent, in accordance with EPA guidance 

(EPA 1988; 2000). Detailed cost estimates are derived from current information, including

vendor quotes, conventional cost-estimating guides (R.S. Means Company, Inc. [Means]

2002a; 2002b), and costs associated with similar projects. The actual cost of the project will 

depend on labor and material costs, site conditions, competitive market conditions, the final 

project scope, and the implementation schedule at the time the remedial activities are 

initiated. In estimating the present worth cost, a discount rate of 7 percent is used, and 

inflation is taken to be 3 percent. Present worth costs for these items are based on 30 years of 

operation, the maximum time period allowed by EPA guidance. Presented costs are rounded 

to two significant figures. 

4.1.3 Modifying Criteria 

This modifying criteria must be considered during remedy selection: 

• State or Support Agency Acceptance and Community Acceptance –The preferred 

alternative should be acceptable to state and support agencies. Also, the concerns of the 

community should be considered when selecting a remedy. The evaluation of these two 

criteria will be based on comments on the FS report and the proposed plan received during 

the public comment period and will be addressed in the Responsiveness Summary of the 

ROD. 

54 
4.2 INDIVIDUAL ANALYSIS OF ALTERNATIVES

A total of five alternatives have been retained: 

Alternative 1 – No Action 

Alternative 2 – Soil Stabilization/Solidification with On-site Disposal; Ground Water via MNA with ICs 

Alternative 3 – Soil Stabilization/Solidification with Off-site Disposal; Ground Water via MNA with ICs 

Alternative 4 – Soil Containment; Ground Water via MNA with ICs 

Alternative 5 – Solidification/Stabilization and Off-site Disposal of Soils in Unpaved Areas; Ground 

Water via MNA with ICs 

Each of these alternatives is detailed in the following sections. Alternatives 2 through 5 all require 

significant site preparation. For Alternatives 2, 3, and 4, the site preparation activities are identical; 

consequently, site preparation activities for all three of these alternatives are presented in Section 4.2.5 to 

avoid redundancy. Alternative 5 requires very different site preparation activities; consequently, site 

preparation activities for this alternative are discussed in Section 4.2.6. 

4.2.1 Alternative 1 – No Action 

The No Action Alternative, which is required by the NCP (NCP 300.430 [e][6]), is the baseline 

alternative against which the effectiveness of all other remedial alternatives are judged. Under the No 

Action Alternative, no RAs will be conducted at the MDI site. No further attempts will be made, beyond 

those already implemented, to control access to the site or other contaminated areas. Uncontrolled 

surface water runoff will continue to flow from the site. Principal threat wastes will continue to be a 

source for ground water and surface water contamination. No attempts will be made to monitor or control 

ground water contaminant migration from the MDI site. 

55 
4.2.1.1 Overall Protection of Human Health and the Environment 

The No Action Alternative will not be protective of human health under current-use scenarios. The 

HHRA for OU 1 (Section 1.5.1; Tetra Tech 2003d) determined that contaminated soil, sediment, and 

ground water pose both current and future risks to off-site residents. RAs that address surface 

contamination at the site are not a component of the No Action Alternative. Therefore, the No Action 

Alternative will not be protective of current or future receptors. 

Alternative 1 will not be protective of the environment. Conditions leading to existing soil, sediment, and 

ground water contamination will not be addressed under this alternative. 

4.2.1.2 Compliance with ARARs

This alternative will not comply with the ARARs for the MDI site described in Section 2.1. 

4.2.1.3 Long-term Effectiveness and Permanence 

The magnitude of risks at the MDI site is likely to remain the same under the No Action Alternative. 

Under this alternative, the site will be subjected to adverse environmental conditions without the benefit 

of contaminant treatment, immobilization, containment, or disposal. Continued or increased migration of 

contaminated ground water can result in deterioration of off-site ground water quality if waste materials 

acting as a continuing source of ground water contamination are not addressed. Continued surface-water 

runoff will further contribute to off-site soil, sediment, and surface-water contamination. 

Under the No Action Alternative, ground water from the site will migrate predominately to the northnorthwest. Surface water will continue to leave the site along natural and improved drainage pathways. 

Human consumption of ground water contaminated by the materials on site may be possible, although 

unlikely, given the depth of the uppermost Class 1 aquifer of approximately 500 feet. 

Because contaminated soil and ground water will remain at the site, a review of the effectiveness and 

protectiveness of the No Action Alternative every 5 years over a 30-year period will be required by

SARA. 

56 
4.2.1.4 Reduction in Toxicity, Mobility, and Volume Through Treatment 

The No Action Alternative does not include a treatment component. Any reduction in mobility, toxicity, 

or volume of contaminated media will occur through natural processes such as biodegradation, 

adsorption, attenuation, and dilution. 

4.2.1.5 Short-term Effectiveness 

Implementation of the No Action Alternative at the MDI site presents short-term risks to nearby residents, 

primarily from inhalation of airborne particulates. Potential risks to human health under a residential 

land-use scenario were evaluated in Section 1.5.1. The No Action Alternative can be implemented 

immediately. Because no RAs are included, no schedule of completion is included. 

4.2.1.6 Implementability 

The No Action Alternative can be readily implemented and will not hinder the implementation of RAs in 

the future. No equipment or services are required for the No Action Alternative. 

4.2.1.7 Cost 

The total cost for the No Action Alternative is $100,000. The total cost includes no capital costs. 

Operating costs are based on a review of site conditions every 5 years over a 30-year period. No other 

operation and maintenance costs will be included. 

4.2.2 Alternative 2 – Solidification/Stabilization with On-site Disposal; Ground Water via 

MNA with ICs 

Under this alternative, soils above action levels are excavated and treated on site through stabilization 

techniques. Under EPA’s AOC policy (first articulated in the final NCP rule, March 8, 1990 Federal 

Register), discrete areas of generally dispersed contamination can be considered a “RCRA unit” (usually

a landfill). Because an AOC is considered a “RCRA land-based unit,” contaminated soils may be 

consolidated and/or treated within the AOC without triggering RCRA LDRs or RCRA minimum 

technology requirements (MTR). The soils will be treated with amendment such that the lead 

concentrations as measured with TCLP will be below the 5.0 mg/L hazardous waste toxicity characteristic 

and below the alternative LDR requirement of 40 CFR Part 268 (i.e., a 90-percent reduction in initial 

concentration and a final concentration less than the LDR requirement of 5 mg/L). Once this is 

accomplished, the soil will be left on site. 

57 
While the stabilization process will result in the soils having a lower leachability, and thus render it 

nonhazardous, it will not lower the total lead concentrations. Because of this, the soil will be placed in 

areas such that residential exposure does not occur. The ultimate disposition may be in a containment cell 

that is underlain by low-permeability soils and overlain by a 2-foot soil cover, or possibly as use as road 

base under asphalt whereby access is also mitigated. In the event that these soils are placed under a soil 

cover, the soil cover will need to be evaluated and maintained on a regular, scheduled basis. 

The minimal ground water contamination on site will be remediated with MNA following source 

removal. Finally, ICs will be implemented to ensure that ground water from the SWBZ beneath the site is 

not used as a source of drinking water. 

Although the lead in soils is the primary driver of risk at the MDI site, debris and waste material left on 

site will have to be addressed. Because of the magnitude of the site preparation activities, they are 

discussed separately in Section 4.2.5 of this FS report. After site preparation has been completed, soils 

with lead concentrations equal to or greater than 500 mg/kg will be excavated and transported to the 

staging area. The base of the excavation will be verified through the use of a field XRF detector. Figure 

6 shows the location of soils to be excavated. Figure 8 shows the location of concrete and debris piles to 

be removed. 

As soils are being excavated, solidification/stabilization will be performed. Depending upon the final 

contractor selected, stabilization will be accomplished through the use of either a pug mill or earthmoving equipment. Lead concentrations in the amended soils will be verified via sampling and analysis 

for TCLP metal concentrations. Soils will be stockpiled until sample results are returned confirming that 

lead concentrations are below regulatory standards. The successfully treated soil will then be placed on 

site in a manner to preclude residential exposure. This may include placement under roadways, or in an 

area that is underlain by low-permeability soils, and then covered with clean fill materials. 

MNA effectiveness will be evaluated via ground water monitoring. A replacement well for existing well 

MW-3 will be installed along with two new cross-gradient wells, one upgradient well, and one 

downgradient well (five wells total). MW-3 will be removed when the contaminated soils are excavated. 

A replacement well will be required to collect baseline water quality data from the former source region 

as part of the MNA evaluation. 

Ground water samples will be collected from the five new wells and existing well MW-2 and analyzed on 

an annual basis for PAHs, anions and cations, and general chemistry parameters. Field measurements 

will be made of oxidation/reduction potential (ORP), dissolved oxygen (DO), temperature, specific 

conductance, and pH. On a quarterly basis, samples will be collected from MW-2, the new downgradient 

58 
well and the MW-3 replacement well. Samples will be analyzed for the compounds and water quality

parameters previously listed. At the same time, water levels will be measured in all existing monitoring 

wells across site on a quarterly basis. 

4.2.2.1 Overall Protection of Human Health and the Environment 

Alternative 2 provides both short-term and long-term protection by immobilizing contaminants in a fixed 

mass; consequently, it will reduce the potential for further contamination of the ground water. Alternative 

2 will also reduce potential risks associated with inhalation, dermal contact, and ingestion of 

contaminated soil. While contaminated soil is processed, measures will be required to protect site 

workers and nearby residents from exposure to contaminated materials and fugitive emissions. 

Implementation of a ground water monitoring program will monitor the long-term effect of the remedial 

activities. 

4.2.2.2 Compliance with ARARs

The solidification/stabilization and on-site landfilling processes will be designed and operated to comply

with all federal and state ARARs concerning hazardous waste treatment facilities and air emissions. 

Table 3 summarizes the ARARs for all four alternatives being evaluated, and shows how they will be 

complied with. 

4.2.2.3 Long-term Effectiveness and Permanence 

If properly implemented, treatment by solidification/stabilization will effectively immobilize soil 

contaminants. The stabilized soils will be backfilled on site. Continued ground water monitoring will 

assess the long-term effectiveness. Because this RA alternative effectively reduces the mobility of the 

contaminants, it reduces risks associated with further contamination of the subsurface and ground water. 

Consequently, it provides long-term protection of future site users and nearby residents. 

4.2.2.4 Reduction in Toxicity, Mobility, and Volume Through Treatment 

Alternative 2 will significantly reduce the mobility of the contaminants by chemically binding and 

stabilizing them. This alternative does not reduce the volume or toxicity of contaminants. 

Implementation of this remedy will increase the volume of contaminated soil. 

4.2.2.5 Short-term Effectiveness 

Because solidification/stabilization is a full-scale technology, it addresses site contaminants in a relatively

short period of time. This alternative will pose short-term risks to site workers involved in handling and 

59 
processing the contaminated soil. Potential risks to workers include dermal contact and inhalation, as 

well as risks associated with the use of heavy equipment. These on-site risks will be mitigated by

implementing a project-specific health and safety plan (HASP) to minimize exposure as well as by

performing remedial tasks following best management practices. Nearby residents also might be at risk 

due to inhalation of fugitive emissions. These risks will be mitigated through dust suppression 

techniques. 

4.2.2.6 Implementability 

This is a full-scale technology; it has been used successfully at other Superfund sites to treat similar metal 

contaminants in soil. Implementation requires relatively simple process equipment that is easy to 

construct and operate. Operation of the solidification/stabilization process equipment will require 

engineering measures to control air emissions, fugitive dust, runoff, erosion, and sedimentation. 

4.2.2.7 Cost 

The cost to fully implement Alternative 2 is about $4.8 million. Of these costs, about $2.2 million are 

fixed costs associated with site preparation tasks that are detailed in Section 4.2.5. 

4.2.3 Alternative 3 – Solidification/Stabilization and Off-site Disposal; Ground Water via 

MNA with ICs 

Under this alternative, soils above action levels are excavated and treated on site through stabilization 

techniques. The soils will be treated with amendment such that the lead concentrations as measured with 

TCLP will be below the 5.0 mg/L concentration that would classify it as a hazardous waste. At that 

concentration, it would likewise be below the alternative treatment standard LDR requirement of 7.5 

mg/L. Once this is accomplished, the soil will be disposed of at a Subtitle D landfill. The minimal 

ground water contamination on site will be remediated with MNA following source removal. Finally, ICs 

will be implemented to ensure that ground water from the SWBZ beneath the site is not used as a source 

of drinking water. 

Prior to treatment of soil, the contractor will perform the site preparation activities listed in Section 4.2.5. 

After site preparation has been completed, soils with lead concentrations equal to or greater than 500 

mg/kg will be excavated and transported to the staging area. Figure 6 shows the location of soils to be 

excavated. The base of the excavation will be verified using a field XRF detector. After the 

subcontractor has verified that the base of the contaminated zone has been removed, the excavations will 

be backfilled with clean imported fill. 

60 
As soils are being excavated, soil stabilization will be performed. Depending upon the final contractor 

selected, stabilization will be accomplished through the use of either a pug mill or earth-moving 

equipment. Lead concentrations in the amended soils will be verified via sampling and analysis for TCLP 

metal concentrations. Soils will be stockpiled until sample results are returned confirming that lead 

concentrations are below regulatory standards. The successfully treated soil will then be shipped off site 

for disposal at a Subtitle D landfill. 

MNA effectiveness will be evaluated via ground water monitoring. A replacement well for existing well 

MW-3 will be installed along with two new cross-gradient wells, one upgradient well, and one 

downgradient well (five wells total). MW-3 will be removed when the contaminated soils are excavated. 

A replacement well will be required to collect baseline water quality data from the former source region 

as part of the MNA evaluation. 

Ground water samples will be collected from the five new wells and existing well MW-2 and analyzed on 

an annual basis for PAHs, anions and cations, and general chemistry parameters. Field measurements 

will be made of ORP, DO, temperature, specific conductance, and pH. On a quarterly basis, samples will 

be collected from MW-2, the new downgradient well, and the MW-3 replacement well. Samples will be 

analyzed for the compounds and water quality parameters previously listed. At the same time, water 

levels will be measured in all existing monitoring wells across the site on a quarterly basis. 

4.2.3.1 Overall Protection of Human Health and the Environment 

Alternative 3 will provide both short-term and long-term protection of future users of the site and nearby

residents by eliminating exposure to the contaminants in the surface and subsurface soils. Consequently, 

it will reduce the potential for further contamination of the ground water. It will also reduce potential 

risks associated with inhalation, dermal contact, and ingestion of contaminated soil. While contaminated 

soil is processed, measures will be required to protect site workers and nearby residents from exposure to 

contaminated materials and fugitive emissions. A ground water monitoring program will be implemented 

to monitor the long-term effect of the remedial activities. 

4.2.3.2 Compliance with ARARs

The solidification/stabilization and off-site landfilling processes will be designed and operated to comply

with all federal and state ARARs concerning hazardous waste treatment facilities and air emissions. 

Table 3 summarizes the ARARs for all four alternatives being evaluated, and shows how they will be 

complied with. 

61 
4.2.3.3 Long-term Effectiveness and Permanence

The contaminated soils will be permanently removed from the site by off-site landfilling. Clean fill 

material will be used to backfill the excavation. Because this remedial alternative removes the 

contaminants from the site, it eliminates risks associated with direct contact with, or migration of, 

contaminants. Consequently, it provides long-term protection of future site users and nearby residents. 

4.2.3.4 Reduction in Toxicity, Mobility, and Volume Through Treatment 

Stabilization and solidification will reduce the toxicity of the waste materials to levels acceptable for 

landfilling. While this treatment will reduce the mobility, risks are reduced because the materials are 

removed from the site. 

4.2.3.5 Short-term Effectiveness 

Excavation and off-site landfilling of soils will address site contaminants in a relatively short period of 

time. This alternative involves potential short-term risks that result from handling contaminated soils 

while excavating and loading soils. The short-term risks include dermal contact with contaminated soils, 

inhalation of vapors and dust, and dangers associated with operating material-handling and processing 

equipment and loading activities. These on-site risks will be mitigated by implementing a project-specific 

HASP to minimize exposure as well as by performing remedial tasks following best management 

practices. Other risks involve those associated with the increased truck traffic. These will be mitigated 

through the development and implementation of a site traffic plan. Nearby residents also might be at risk 

due to inhalation of fugitive emissions. These risks will be mitigated through air monitoring and dust 

suppression techniques. 

4.2.3.6 Implementability 

Alternative 3 is a full-scale technology, and numerous vendors offer excavation equipment, 

transportation, and landfill capacity near this site. This alternative has been used extensively at many

other Superfund sites to successfully dispose of soil containing similar metals contaminants. Standard 

verification sampling procedures will be in place to monitor the effectiveness of this alternative. 

Authorizations to implement this alternative include standard regulatory compliance requirements and 

vendor authorizations. No formal permits are required to implement this remedy. Implementation of 

engineering measures to control air emissions, fugitive dust, runoff, erosion, and sedimentation may be 

required during site excavation and restoration activities. Consideration should be given to increased 

truck traffic and the increased potential for accidents and accelerated wear of local roads. 

62 
This remedy would be implemented easily at the MDI site. Workers would require minimal training, and

equipment would be readily available. Implementation would require many trips to the landfill. This 

increase in truck traffic could heighten chances of accidents and accelerate wear of local roads. 

4.2.3.7 Cost 

The costs to fully implement Alternative 3 is about $6.0 million. Of these costs, about $2.2 million are 

fixed costs associated with site preparation tasks that are detailed in Section 4.2.5. Costs for Alternative 3 

exceed the costs for Alternative 2 by $1.4 million. These reflect the additional costs of off-site disposal as 

opposed to leaving the treated materials on site. 

4.2.4 Alternative 4 – Containment with ICs 

Under this alternative, on-site waste materials would be consolidated in a single AOC and capped in 

place. Under EPA’s AOC policy (first articulated in the final NCP rule, March 8, 1990 Federal Register), 

discrete areas of generally dispersed contamination can be considered a “RCRA unit” (usually a landfill). 

Because an AOC is considered a “RCRA land-based unit,” contaminated soils may be consolidated 

and/or treated within the AOC without triggering RCRA LDRs or RCRA MTRs. 

Prior to consolidation activities, the contractor will perform the site preparation activities listed in Section 

4.2.5. After these site preparation tasks have been completed, the soils consolidation area will be 

prepared by excavating it to a depth of approximately 2 feet. Soils with lead concentrations equal to or 

greater than 500 mg/kg will be excavated and transported to the consolidation area. Figure 6 shows the 

location of soils to be excavated. The base of the excavation will be verified using a field XRF detector. 

After the subcontractor has verified that the base of the contaminated zone has been removed, the 

excavations will be backfilled with clean imported fill. 

The excavated soils will be placed in the consolidation area with approximate dimensions of 300 feet by

300 feet in 1-foot lifts and compacted. Following consolidation of all waste materials, the consolidation 

pile will be covered with a clay cap. The cap thickness will be determined during the remedial design, 

and may include a topsoil component, depending upon the ultimate plan for site development. Cap 

maintenance requirements will also be addressed in the remedial design documentation. Engineering 

controls in the form of fencing and signs will be placed around the cell. MTRs do not apply to the 

disposal area. Furthermore, given that lead is highly immobile, sheet piling will not be required. 

Implementation of an AOC as the remedy does not require the installation of a leachate collection system. 

However, ground water monitoring will be performed at four new monitoring wells (1 upgradient and 3 

downgradient of the consolidation area). 

63 
MNA effectiveness will be evaluated via ground water monitoring. A replacement well for existing well 

MW-3 will be installed along with two new cross-gradient wells, one upgradient well, and one 

downgradient well (five wells total). MW-3 will be removed when the contaminated soils are excavated. 

A replacement well will be required to collect baseline water quality data from the former source region 

as part of the MNA evaluation. 

Ground water samples will be collected from the five new wells and existing well MW-2 and analyzed on 

an annual basis for PAHs, anions and cations, and general chemistry parameters. Field measurements 

will be made of ORP, DO, temperature, specific conductance, and pH. On a quarterly basis, samples will 

be collected from MW-2, the new downgradient well, and the MW-3 replacement well. Samples will be 

analyzed for the compounds previously listed. At the same time, water levels will be measured in all 

existing monitoring wells across the site on a quarterly basis. Finally, ICs will be implemented to ensure 

that ground water from the SWBZ beneath the site is not used as a source of drinking water. 

4.2.4.1 Overall Protection of Human Health and the Environment 

Alternative 4 will provide both short-term and long-term protection of future users of the site and nearby

residents by eliminating exposure to the contaminants in the surface and subsurface soils. Consequently, 

it will reduce the potential for further contamination of the ground water. It will also reduce potential 

risks associated with inhalation, dermal contact, and ingestion of contaminated soil. While contaminated 

soil is processed, measures will be required to protect site workers and nearby residents from exposure to 

contaminated materials and fugitive emissions. Implementation of a ground water monitoring program

will monitor the long-term effect of the remedial activities. 

4.2.4.2 Compliance with ARARs

The excavation and consolidation processes will be designed and operated to comply with all federal and 

state ARARs concerning hazardous waste treatment facilities and air emissions. Table 3 summarizes the 

ARARs for all four alternatives being evaluated, and shows how they will be complied with. 

4.2.4.3 Long-term Effectiveness and Permanence 

If properly implemented, consolidation and containment will significantly decrease the potential of the 

contaminants leaching into ground water. Construction of a clay cap will mitigate the potential exposure 

to human receptors. Continued ground water monitoring will assess the long-term effectiveness. 

64 
4.2.4.4 Reduction in Toxicity, Mobility, and Volume Through Treatment 

This alternative does not reduce the volume or toxicity of contaminants. Lead in general is not a mobile 

contaminant. By capping these soils, the possibility of contaminating ground water with leachate is 

mitigated. 

4.2.4.5 Short-term Effectiveness 

Excavation and consolidation of soils will address site contaminants in a relatively short period of time. 

This alternative involves potential short-term risks that result from handling contaminated soils during 

excavation and consolidation activities. The short-term risks include dermal contact with contaminated 

soils, inhalation of vapors and dust, and dangers associated with operating material-handling and 

processing equipment and loading activities. These on-site risks will be mitigated by implementing a 

project-specific HASP to minimize exposure as well as by performing remedial tasks following best 

management practices. Nearby residents also might be at risk due to inhalation of fugitive emissions. 

These risks will be mitigated through air monitoring and dust suppression techniques. 

4.2.4.6 Implementability 

This is a full-scale technology; it has been used successfully at other Superfund sites to treat similar metal 

contaminants in soil. Implementation requires relatively simple process equipment that is easy to 

construct and operate. Operation of the earth-moving equipment will require engineering measures to 

control air emissions, fugitive dust, runoff, erosion, and sedimentation. 

4.2.4.7 Cost 

The cost to fully implement Alternative 4 is about $4.2 million. Of these costs, $2.2 million are fixed 

costs associated with site preparation tasks that are performed regardless of the remedial alternative 

selected. These costs are detailed in Section 4.2.5. 

4.2.5 Site Preparation Activities – Alternatives 2, 3, and 4 

Site preparation activities will require a significant level of effort given the amount of waste material and 

debris left on site. These activities will be performed regardless of remedial alternative selected. Site 

preparation activities associated with Alternatives 2, 3, and 4 include the following (Figure 8): 

• Clearing and grubbing of trees and vegetation on site will be performed. 

65 

• Runoff controls will be installed. 

• Temporary field offices will be installed. 

• Wallboard and mastic containing ACM in the existing building will be removed from the 

building and stockpiled. 

• The existing building may be demolished, depending upon redevelopment plans. 

• Approximately 4,400 yd3

 of ACM debris and 85,000 ft2 of wallboard and mastic will be 

disposed of appropriately.

• Nonhazardous catalyst will be removed from the site and disposed of appropriately. 

• The existing PCB-contaminated melt transformer in the northwest corner of the site will be 

removed. 

• Nonhazardous waste piles in areas to be remediated will be moved to a staging area for future 

disposal. 

• Approximately 6,100 yd3

 of debris overlying soils to be addressed will be disposed of at a 

Subtitle D landfill. 

• Approximately 7,500 yd3 of concrete and asphalt overlying soils to be addressed will be 

removed and stockpiled. 

• Approximately 3,400 gallons of wastewater containing PCBs will be pumped and disposed of 

off site. 

• Approximately 5,600 gallons of waste oil in the aboveground vat west of the north pond (RI 

sample location WS-6) will be sampled, characterized, and disposed of appropriately.

• The monitoring wells in the areas to be remediated (MW-3, MW-11 MW-14, MW-15, 

MW-20, and MW-22) will be plugged and abandoned. 

• Approximately 1,850 yd 3 of soil with NAPL in the vicinity of MW-03 and MW-11 will be 

excavated and disposed of at a Subtitle D landfill that can accept soils contaminated with 

petroleum hydrocarbons. At the MW-3 location, clean overburden will be excavated to a 

depth of 15 feet bgs and stockpiled on site. Contaminated soil from 15 to 25 feet bgs will be 

removed. At the MW-11 location, clean overburden will be excavated to a depth of 5 feet 

bgs. Contaminated soil from 5 to 15 feet bgs will be removed. 

• The UST in the northwest corner of the site will be pumped and removed, with approximately

4,000 gallons of petroleum-containing liquids to be removed from the site. 

The costs to perform these tasks is approximately $2.2 million and are presented in greater detail in 

Appendix B of this report. 

67 
4.2.6 Alternative 5 – Solidification/Stabilization and Off-site Disposal of Soils in Unpaved Areas; 

Ground Water via MNA with ICs 

Under this alternative, no action would be taken on shallow soils that are overlain by the concrete pad in 

the southwest corner of the site. Active remediation will only occur in those portions of the site that are 

identified on Figure 9. 

Soils above action levels that are not beneath concrete are excavated and treated on site through 

stabilization techniques. The soils will be treated with amendment such that the lead concentrations as 

measured with TCLP will be below the 5.0 mg/L concentration that would classify it as a hazardous 

waste. Likewise, the concentrations would be below the alternative treatment standard LDR requirement 

of 7.5 mg/L. Once this is accomplished, the soil will be disposed of at a Subtitle D landfill. Ground 

water contamination on site will be remediated with MNA following source removal. Finally, ICs will be 

implemented to ensure that ground water from the SWBZ beneath the site is not used as a source of 

drinking water. 

Prior to consolidation activities, the contractor will perform the following site preparation activities: 

• Clear and grub trees and vegetation on site. 

• Install runoff controls. 

• Install temporary field offices. 

• Remove wallboard and mastic containing ACM from the existing building and stockpile it. 

• Demolish the existing building, depending upon redevelopment plans. 

• Properly dispose of approximately 4,400 yd3

 of ACM debris and 85,000 ft2 of wallboard and 

mastic. 

• Remove and properly dispose of nonhazardous catalyst. 

• Remove the existing PCB-contaminated melt transformer in the northwest corner of the site. 

68 

• Remove and stockpile approximately 600 yd3 of concrete and asphalt overlying soils with 

NAPL. 

• Pump and dispose of off-site approximately 3,400 gallons of wastewater containing PCBs. 

• Decontaminate the pits that housed the PCB-containing wastewater and properly dispose of 

the decontamination water. 

• Plug and abandon the monitoring wells in the areas to be remediated (MW-3, MW-11, and 

MW-20). 

• Excavate approximately 1,850 yd 3 of soil with NAPL in the vicinity of MW-3 and MW-11

and dispose of it at a Subtitle D landfill that can accept soils contaminated with petroleum

hydrocarbons. At the MW-3 location, excavate clean overburden to a depth of 15 feet bgs, 

stockpile it on site, and remove contaminated soil from 15 to 25 feet bgs. At the MW-11 

location, excavate clean overburden to a depth of 5 feet bgs and remove contaminated soil 

from 5 to 15 feet bgs. 

• Sample, characterize, and properly dispose of approximately 5,600 gallons of waste oil in the 

aboveground vat west of the north pond (RI sample location WS-6). 

• Pump approximately 4,000 gallons of petroleum-containing liquids and remove the UST in 

the northwest corner of the site. 

Soils with lead concentrations equal to or greater than 500 mg/kg that are not beneath concrete will be 

excavated and transported to the treatment area. Figure 9 shows the location of soils to be excavated. 

The base of the excavation will be verified using a field XRF detector. After the subcontractor has 

verified that the base of the contaminated zone has been removed, the excavations will be backfilled with 

clean imported fill. As soils are being excavated, soil stabilization will be performed. Depending upon 

the final contractor selected, stabilization will be accomplished through the use of either a pug mill or 

earth-moving equipment. Lead concentrations in the amended soils will be verified via sampling and 

analysis for TCLP metal concentrations. Soils will be stockpiled until sample results are returned 

confirming that lead concentrations are below regulatory standards. The successfully treated soil will 

then be shipped off site for disposal at a Subtitle D landfill. 

Lead-contaminated soils that are overlain by concrete will be left in place. As part of this remedy, an IC 

in the form of a deed notice will be prepared for the site. The deed notice will identify the contaminated 

soils and indicate that, in the event that the concrete pavement is removed, these soils will need to be 

remediated. 

MNA effectiveness will be evaluated via ground water monitoring. A replacement well for existing well 

MW-3 will be installed along with two new cross-gradient wells, one upgradient well, and one 

70 
downgradient well (five wells total). MW-3 will be removed when the contaminated soils are excavated. 

A replacement well will be required to collect baseline water quality data from the former source region 

as part of the MNA evaluation. 

Ground water samples will be collected from the five new wells and existing well MW-2 and analyzed on 

an annual basis for PAHs, anions and cations, and general chemistry parameters. Field measurements 

will be made of ORP, DO, temperature, specific conductance, and pH. On a quarterly basis, samples will 

be collected from MW-2, the new downgradient well, and the MW-3 replacement well. Samples will be 

analyzed for the compounds previously listed. At the same time, water levels will be measured in all 

existing monitoring wells across the site on a quarterly basis. Finally, ICs will be implemented to ensure 

that ground water from the SWBZ beneath the site is not used as a source of drinking water. 

4.2.6.1 Overall Protection of Human Health and the Environment 

Alternative 5 will provide both short-term and long-term protection of future users of the site and nearby

residents by eliminating exposure to the contaminants in the surface and subsurface soils. Consequently, 

it will reduce the potential for further contamination of the ground water. It will also reduce potential 

risks associated with inhalation, dermal contact, and ingestion of contaminated soil. While contaminated 

soil is processed, measures will be required to protect site workers and nearby residents from exposure to 

contaminated materials and fugitive emissions. Implementation of a ground water monitoring program

will monitor the long-term effect of the remedial activities. 

4.2.6.2 Compliance with ARARs

The excavation and consolidation processes will be designed and operated to comply with all federal and 

state ARARs concerning hazardous waste treatment facilities and air emissions. Table 3 summarizes the 

ARARs for all alternatives being evaluated, and shows how they will be complied with. 

4.2.6.3 Long-term Effectiveness and Permanence 

The contaminated soils in unpaved areas will be permanently removed from the site by off-site 

landfilling. Clean fill material will be used to backfill the excavation. Because this remedial alternative 

removes the contaminants from the site, it eliminates risks associated with direct contact with, or 

migration of, contaminants. Consequently, it provides long-term protection of future site users and 

nearby residents. This remedy will require ICs in the form of deed notices to ensure that ground water 

from the SWBZ beneath the site is not used as a source of drinking water, and that, in the event that the 

71 
concrete pavement overlying contaminated soils is removed, these soils will be remediated and achieve 

RAOs. 

4.2.6.4 Reduction in Toxicity, Mobility, and Volume Through Treatment 

This alternative does not reduce the volume or toxicity of contaminants. Lead in general is not a mobile 

contaminant. By capping these soils, the possibility of contaminating ground water with leachate is 

mitigated. 

4.2.6.5 Short-term Effectiveness 

Excavation and consolidation of soils will address site contaminants in a relatively short period of time. 

This alternative involves potential short-term risks that result from handling contaminated soils during 

excavation and consolidation activities. The short-term risks include dermal contact with contaminated 

soils, inhalation of vapors and dust, and dangers associated with operating material-handling and 

processing equipment and loading activities. These on-site risks will be mitigated by implementing a 

project-specific HASP to minimize exposure as well as by performing remedial tasks following best 

management practices. Nearby residents also might be at risk due to inhalation of fugitive emissions. 

These risks will be mitigated through air monitoring and dust suppression techniques. 

4.2.6.6 Implementability 

This is a full-scale technology; it has been used successfully at other Superfund sites to treat similar metal 

contaminants in soil. Implementation requires relatively simple process equipment that is easy to 

construct and operate. Operation of the earth-moving equipment will require engineering measures to 

control air emissions, fugitive dust, runoff, erosion, and sedimentation. 

4.2.6.7 Cost 

The cost to fully implement Alternative 5 is about $3.3 million. Of these costs, $1.5 million are costs 

associated with site preparation tasks that are performed regardless of the remedial alternative selected. 

72 
5.0 COMPARISON OF REMEDIAL ALTERNATIVES 

Based on the initial screening of technologies and evaluation of alternatives, five remedial alternatives 

have been taken through the FS. Table 4 summarizes how each alternative complies with the RAOs. 

Table 5 summarizes how these alternatives comply with the evaluation criteria. 

5.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT 

Alternative 1 (No Action) is not protective of the environment. Alternatives 2, 3, 4, and 5 are all 

protective of the environment. Whereas Alternatives 2, 3, and 4 treat all contaminated media with a 

single remedial technology, Alternative 5 combines an active technology in the unpaved areas with a 

containment technology for the contaminated soils located beneath concrete. Alternatives 2, 3, and 5–

solidification/stabilization with on-site (Alternative 2) and off-site (Alternatives 3 and 5) disposal–will 

provide both short-term and long-term protection of future users of the site and nearby residents by

stabilizing the wastes and reducing its ability to leach contaminants. Following the solidification/ 

stabilization process, the treated soils are no longer hazardous. MNA will ensure that ground water 

contamination has not migrated off site. Alternatives 4 and 5 (Containment and MNA) are also 

protective. Although the wastes have not been “treated” by consolidating and capping, the risk associated 

with receptor contact with the contaminated surface soils will be mitigated, and the potential for surface 

water to infiltrate through and contaminated ground water is minimized. MNA will be used similarly to 

Alternatives 2 and 3. 

5.2 COMPLIANCE WITH ARARS 

Alternative 1 does not comply with ARARs. The remaining alternatives will comply with all ARARs 

though the use of standard engineering and waste management techniques as well as through the 

implementation of a site-specific HASP. 

5.3 LONG-TERM EFFECTIVENESS AND PERMANENCE 

 73

Alternative 1 does not provide long-term effectiveness and permanence. Alternatives 2 and 3 provide 

long-term effectiveness and permanence through the stabilization process, which will render the soil 

nonhazardous. In the case of Alternative 3 (solidification/stabilization with off-site disposal) long-term

permanence is guaranteed by the removal of all contaminated materials from the site. If properly 

implemented, consolidation and containment will significantly decrease the potential of leaching from the 

contaminants into ground water. Construction of a clay cap (Alternative 4) will mitigate the potential 

exposure to human receptors. For Alternative 5, long-term effectiveness and permanence is provided in

the unpaved areas through the stabilization process, which will render the soil nonhazardous. 
TABLE 4 

COMPARISON OF REMEDIAL ALTERNATIVES WITH REMEDIAL ACTION OBJECTIVES

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

Alternative Remove ACM 

Reduce Risk to 

Residential Receptors by 

Lead Concentrations in 

Soil Greater than 

Cleanup Level 

Remove Free Product in 

Soils in Vicinity of MW-3 

Remove Free Product in 

Soils in Vicinity of 

MW-11 

Remediate 

Water in N

Corner of 

Remove Fre

Associated 

1 No Action The ACM would not be

removed. 

The risk from lead in soilwould not be reduced. 

The free product would not be removed and the potential continuing source of ground watercontamination would remain. 

The free product would not be removed and the potential continuing source of ground watercontamination would remain. 

The UST wouremoved and twater contamiwould not be a

2 Soil Excavation

and Solidification/Stabilization withOn-site Disposal; Ground Water via MNA andInstitutionalControls 

The existing on-site building will be demolished andwallboard and masticwith ACM will be stockpiled; ACM debris, wallboard, and mastic will be disposed of appropriately. 

The risk will be reducedby excavating soil withlead concentrations equalto or greater than 500 mg/kg, treating the soil bysolidification/stabilization,and then consolidating it inan on-site area that will mitigate direct exposure to receptors; this may includeplacement under futureroads or in consolidation areas; engineering and institutional controls willbe implemented to prevent exposure to the treated soil. 

Contaminated soil in the vicinity of MW-3 will be excavated and disposed of off site. 

Contaminated soil in the vicinity of MW-11 will be excavated and disposed of off site. 

The UST will Soil containing will be excavadisposed of ofterm monitorinverify that MNeffective. 

74
TABLE 4 

COMPARISON OF REMEDIAL ALTERNATIVES WITH REMEDIAL ACTION OBJECTIVES

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

Alternative Remove ACM 

Reduce Risk to 

Residential Receptors by 

Lead Concentrations in 

Soil Greater than 

Cleanup Level 

Remove Free Product in 

Soils in Vicinity of MW-3 

Remove Free Product in 

Soils in Vicinity of 

MW-11 

Remediate 

Water in N

Corner of 

Remove Fre

Associated 

3 Soil Excavation

and Solidification/Stabilization withOff-site Disposal; Ground Water via MNA and Institutional Controls 

The existing on-site building will be demolished andwallboard and masticwith ACM will be stockpiled; ACM debris, wallboard, and mastic will be disposed of appropriately. 

The risk from soil will bereduced by removing soil with lead concentrationsequal to or greater than 500 mg/kg, treating the soil by solidification/ stabilization, and thendisposing of it off site. 

Contaminated soil in the vicinity of MW-3 will be excavated and disposed of off site. 

Contaminated soil in the vicinity of MW-11 will be excavated and disposed of off site. 

The UST will Soil containing will be excavadisposed of ofterm monitorinverify that MNeffective. 

4 Containment via

Capping with InstitutionalControls 

The existing on-site building will be demolished andwallboard and masticwith ACM will be stockpiled; ACM debris, wallboard, and mastic will be disposed of appropriately. 

The risk will be reducedby removing soil with lead concentrations equal to orgreater than 500 mg/kg, consolidating the soil in an on-site area underlain bylow-permeability native soils to minimize risks associated with leaching toground water, and thencapping the soil to prevent exposure; engineering and institutional controls willbe implemented to prevent exposure to the soil. 

Contaminated soil in the vicinity of MW-3 will be excavated and disposed of off site. 

Contaminated soil in the vicinity of MW-11 will be excavated and disposed of off site. 

The UST will Soil containing will be excavadisposed of ofterm monitorinverify that MNeffective. 

75
TABLE 4 

COMPARISON OF REMEDIAL ALTERNATIVES WITH REMEDIAL ACTION OBJECTIVES

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

Alternative Remove ACM 

Reduce Risk to 

Residential Receptors by 

Lead Concentrations in 

Soil Greater than 

Cleanup Level 

Remove Free Product in 

Soils in Vicinity of MW-3 

Remove Free Product in 

Soils in Vicinity of 

MW-11 

Remediate 

Water in N

Corner of 

Remove Fre

Associated 

5 Solidification/

Stabilization andOff-site Disposal of Soils inUnpaved Areas; Ground Water via MNA with InstitutionalControls 

The existing on-site building will be demolished andwallboard and masticwith ACM will be stockpiled; ACM debris, wallboard, and mastic will be disposed of appropriately. 

The risk from soil will bereduced by removing soil in unpaved areas with lead concentrations equal to orgreater than 500 mg/kg, treating the soil bysolidification/ stabilization, and thendisposing of it off site. The risk to residential receptors of soilsunderneath concrete is mitigated by the presenceof the concrete. In the event the concrete isremoved, these soils willalso require remediation. 

Contaminated soil in the vicinity of MW-3 will be excavated and disposed of off site. 

Contaminated soil in the vicinity of MW-11 will be excavated and disposed of off site. 

The UST will Soil containing will be excavadisposed of ofterm monitorinverify that MNeffective. 

Notes: ACM Asbestos-containing material LNAPL Light nonaqueous-phase liquid mg/kg Milligram per kilogramMNA Monitored natural attenuationUST Underground storage tank

76
TABLE 5 

COMPARISON OF REMEDIAL ALTERNATIVES 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

Alternative 

Overall Protection of 

Human Health and the 

Environment 

Compliance with

ARARs 

Long-term 

Effectiveness and

Permanence

Reduction in Toxicity, 

Mobility and Volume Short-term Effectiveness 

1 No Action NA This alternative 

would not complywith ARARs.

NA NA NA 

2 Soil Excavation

and Solidification/Stabilization with On-siteDisposal; Ground Water via MNA andInstitutionalControls 

Alternative 2 provides bothshort-term and long-term protection by immobilizingcontaminants in a stabilizedmatrix. It will reduce thepotential for further contamination of the ground water. It will also reduce potential risks associated with inhalation, dermal contact, and ingestion of contaminated soil. Whilecontaminated soil is processed, measures will be required to protect site workers and nearbyresidents from exposure to contaminated materials and fugitive emissions. Implementation of a ground water monitoring program will monitor the long-termeffectiveness of the remedial activities. 

This alternative would comply with all ARARs that have beendeveloped for the MDI site.

Solidification/stabilization willeffectivelyimmobilize soilcontaminants. The stabilized soils will be backfilled on site. Ground water monitoring will assess the long-term effectiveness.Because thisalternativeeffectively reduces the mobility of thecontaminants, it reduces risks associated withfurther contamination ofthe subsurface and ground water.Consequently, it provides long-term protection of future site users and nearby residents. 

This alternative significantly reduces the mobility of thecontaminants bychemically binding and encapsulating them. This alternative does not reduce the volume or toxicity of contaminants. Implementation of this remedy may increase thevolume of contaminated soil. 

Alternative 2 addresses site contaminants in a relativelyshort period of time, and will pose short-term risks to siteworkers involved in handlingand processing the contaminated soil. Potential risks to workers includedermal contact, inhalation, and risks associated with heavy equipment. On-site risks will be mitigated byimplementing a projectspecific HASP to minimize exposure as well as by using best management practices. Nearby residents also might be at risk due to inhalation of fugitive emissions. Risks will be mitigated through airmonitoring and dust suppression techniques. 

77 
TABLE 5 (Continued) 

COMPARISON OF REMEDIAL ALTERNATIVES 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

Alternative 

Overall Protection of 

Human Health and the 

Environment 

Compliance with

ARARs 

Long-term 

Effectiveness and

Permanence

Reduction in Toxicity, 

Mobility and Volume Short-term Effectiveness 

3 Soil Excavation

and Solidification/Stabilization with Off-site Disposal; Ground Water via MNA andInstitutionalControls 

Alternative 3 will provideboth short-term and longterm protection of future users of the site and nearbyresidents by eliminating exposure to the contaminants in the surfaceand subsurface soils. It willreduce the potential forfurther contamination of the ground water. It will alsoreduce potential risks associated with inhalation,dermal contact, and ingestion of contaminatedsoil. While contaminatedsoil is processed, measureswill be required to protectsite workers and nearbyresidents from exposure to contaminated materials and fugitive emissions. Implementation of a ground water monitoring program will monitor the long-termeffectiveness of the remedial activities. 

This alternative would comply with all ARARs that have beendeveloped for the MDI site.

The contaminatedsoils will bepermanently removed from the site by off-site landfilling. Cleanfill material will be used to backfill the excavations.Because thisremedial alternative removes the contaminants fromthe site, iteliminates risks associated withdirect contact with,or migration of, contaminants. Consequently, it provides long-term protection of future site users and nearby residents. 

Stabilization andsolidification will reducethe toxicity of the waste materials to levels acceptable for landfilling. While this treatment will reduce themobility, risks are also eliminated because thematerials are removed from the site. 

Excavation and off-site landfilling will address site contaminants in a relativelyshort period of time. This alternative involves potential short-term risks that resultfrom handling contaminated soils while excavating andloading soils. The short-termrisks include dermal contact with contaminated soils,inhalation of vapors and dust, and dangers associated with operating material-handling and processing equipment and loading activities. Onsite risks will be mitigated byimplementing a projectspecific HASP to minimize exposure as well as byperforming remedial tasks following best management practices. Other risksinvolve those associated withthe increased truck traffic.These will be mitigated through the development andimplementation of a site traffic plan. Nearbyresidents also might be at risk due to inhalation of fugitive emissions. These risks will be mitigatedthrough air monitoring and dust suppression techniques.

78 
TABLE 5 (Continued) 

COMPARISON OF REMEDIAL ALTERNATIVES 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

Alternative 

Overall Protection of 

Human Health and the 

Environment 

Compliance with

ARARs 

Long-term 

Effectiveness and

Permanence

Reduction in Toxicity, 

Mobility and Volume Short-term Effectiveness 

4 Containment via

Capping with InstitutionalControls 

Alternative 4 will provideboth short-term and longterm protection of future users of the site and nearbyresidents by mitigating exposure to the contaminants in the surfaceand subsurface soils. It willreduce the potential forfurther contamination of the ground water. It will alsoreduce potential risks associated with inhalation,dermal contact, and ingestion of contaminatedsoil. While contaminatedsoil is processed, measureswill be required to protectsite workers and nearbyresidents from exposure to contaminated materials and fugitive emissions. Implementation of a ground water monitoring program will monitor the long-termeffectiveness of the remedial activities. 

This alternative would comply with all ARARs that have beendeveloped for the MDI site.

Consolidation and containment will significantlydecrease the potential of leaching from the contaminants intoground water.Construction of a clay cap willmitigate the potential exposure to human receptors. Continued ground water monitoringwill assess the longterm effectiveness.Consequently, it provides long-term protection of future site users and nearby residents. 

Little or no reduction in toxicity or contaminant mass other than natural attenuation mechanisms;mobility of contaminants greatly reduced bycontainment barriers. 

Construction activitydisturbance and risk would be minimal compared to allactive remedies other than no action; implementation of theremedy would be complete in several months followed by 2 years of monitoring to verify compatibility with ground water chemistry.

79 
TABLE 5 (Continued) 

COMPARISON OF REMEDIAL ALTERNATIVES 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

Alternative 

Overall Protection of 

Human Health and the 

Environment 

Compliance with

ARARs 

Long-term 

Effectiveness and

Permanence

Reduction in Toxicity, 

Mobility and Volume Short-term Effectiveness 

5 Solidification/

Stabilization andOff-site Disposal of Soils inUnpaved Areas; Ground Water via MNA with InstitutionalControls 

Alternative 5 will provideboth short-term and longterm protection of future users of the site and nearbyresidents by eliminating exposure to the contaminants in the surfaceand subsurface soils. It willreduce the potential forfurther contamination of the ground water. It will alsoreduce potential risks associated with inhalation,dermal contact, and ingestion of contaminatedsoil. While contaminatedsoil is processed, measureswill be required to protectsite workers and nearbyresidents from exposure to contaminated materials and fugitive emissions. Implementation of a ground water monitoring program will monitor the long-termeffectiveness of the remedial activities. 

This alternative would comply with all ARARs that have beendeveloped for the MDI site.

Contaminated soilsin unpaved areas will be permanently removed from the site by off-site landfilling. Cleanfill material will be used to backfill the excavations.Because thisremedial alternative removes the contaminants fromthe site, iteliminates risks associated withdirect contact with,or migration of, contaminants. Consequently, it provides long-term protection of future site users and nearby residents. The long-term effectiveness in paved areas is maintained provided that the concrete is not disturbed. The concrete provides a barrier to human exposure and the concrete will inhibit 

In unpaved areas, stabilization andsolidification will reducethe toxicity of the waste materials to levels acceptable for landfilling. While this treatment will reduce themobility, risks are also eliminated because thematerials are removed from the site. 

Excavation and off-site landfilling will address site contaminants in a relativelyshort period of time. This alternative involves potential short-term risks that resultfrom handling contaminated soils while excavating andloading soils. The short-termrisks include dermal contact with contaminated soils,inhalation of vapors and dust, and dangers associated with operating material-handling and processing equipment and loading activities. Onsite risks will be mitigated byimplementing a projectspecific HASP to minimize exposure as well as byperforming remedial tasks following best management practices. Other risksinvolve those associated withthe increased truck traffic.These will be mitigated through the development andimplementation of a site traffic plan. Nearbyresidents also might be at risk due to inhalation of fugitive emissions. These risks will be mitigatedthrough air monitoring and dust suppression techniques.

80 
TABLE 5 (Continued) 

COMPARISON OF REMEDIAL ALTERNATIVES 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

Alternative 

Overall Protection of 

Human Health and the 

Environment 

Compliance with

ARARs 

Long-term 

Effectiveness and

Permanence

Reduction in Toxicity, 

Mobility and Volume Short-term Effectiveness 

5 Solidification/

Stabilization andOff-site Disposal of Soils inUnpaved Areas; Ground Water via MNA with InstitutionalControls (Continued) 

infiltration ofground water. Inthe event that the concrete is disturbed, these soils will also require cleanup. 

Notes: ARAR Applicable or Relevant and Appropriate Requirement HASP Health and safety plan NA Not applicable MDI Many Diversified Interests MNA Monitored natural attenuation 

81 
Contaminated soils left beneath concrete will have a low potential for leaching to ground water providing 

the concrete remains in place. Continued ground water monitoring for Alternatives 2, 3, 4, and 5 will 

assess the long-term effectiveness of the selected remedy. Consequently, these alternatives provide longterm protection of future site users and nearby residents. 

5.4 REDUCTION IN TOXICITY, MOBILITY, AND VOLUME THROUGH TREATMENT 

Alternative 1 does not reduce the toxicity, mobility, or volume of the waste materials other than minor 

decreases in concentrations associated with MNA in ground water, although this will not be monitored. 

Alternatives 2 and 3 both reduce the toxicity and mobility of the contaminants, although the technologies 

employed will increase the volume of waste to be managed. Alternative 4 does not reduce the toxicity or 

volume of contaminants. Lead in general is not a mobile contaminant. By capping these soils, the 

possibility of contaminating ground water with leachate is mitigated. Alternative 5 will reduce the 

toxicity and mobility of the contaminants in unpaved areas, although the technologies employed will 

increase the volume of waste to be managed. The toxicity and volume of waste underneath the concrete 

is not reduced using Alternative 5, although the concrete will mitigate the infiltration of surface water and

the associated leaching to ground water. PAH concentrations in ground water may decrease as a result of 

MNA. 

5.5 SHORT-TERM EFFECTIVENESS 

Alternative 1 does not provide short-term effectiveness. Risks to nearby residents associated with 

inhalation of fugitive emissions will remain. Alternatives 2, 3, 4, and 5 will address site contaminants in 

a relatively short period of time. These alternatives involve potential short-term risks that result from

handling contaminated soils during excavation and consolidation activities. The short-term risks include 

dermal contact with contaminated soils, inhalation of vapors and dust, and dangers associated with 

operating material-handling and processing equipment and loading activities. These on-site risks will be 

mitigated by implementing a project-specific HASP to minimize exposure as well as by performing 

remedial tasks following best management practices. Nearby residents also might be at risk due to 

inhalation of fugitive emissions. These risks will be mitigated through air monitoring and dust 

suppression techniques. 

5.6 IMPLEMENTABILITY

Alternative 1 is easily implemented, and does not require any actions other than 5-year reviews. All four 

alternatives with RAs are easily implemented. Each of these is a full-scale technology, and has been used 

successfully at other Superfund sites to treat similar metal contaminants in soil. Implementation requires 

82 
relatively simple process equipment that is easy to construct and operate. Operation of the earth-moving 

equipment will require engineering measures to control air emissions, fugitive dust, runoff, erosion, and 

sedimentation. 

Although Alternatives 2, 3, 4, and 5 are all easily implemented, Alternative 4 may be the most difficult 

from a public acceptance perspective. In this instance, the site will be required to be designated as an 

AOC in the ROD. Consequently, although this does not pose any additional risks, there is a possibility

that public perception may make redevelopment more difficult. Alternative 5 would be the easiest to 

implement, although it may be more challenging from a site redevelopment perspective. 

5.7 COST 

Costs associated with each of the remedial alternatives are summarized in Table 6 and detailed in 

Appendix B. Alternative 3 is the most expensive, followed by Alternatives 2, 4, 5, and 1. Alternative 1 

has very minimal costs in that no RAs will be performed. Costs for Alternatives 2 and 3 differ as a result 

of the disposal option being employed. Alternative 5 costs are the lowest of the full-scale RAs because 

contaminated soil is being left on site beneath the concrete. 

5.8 SUMMARY 

A total of five remedial alternatives were fully evaluated during the FS. The No Action Alternative was 

evaluated as required by the NCP. Alternatives 2, 3, 4, and 5 would all meet RAOs set for the site and 

comply with ARARs. 

83 
84 

TABLE 6 

COST SUMMARY FOR REMEDIAL ALTERNATIVES 

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1 

Alternative Fixed Costs 1 Remedy Costs 2 O&M 3 Total 

(1) 

No Action 

None None $100,000 $100,000 

(2) 

Solidification/Stabilization 

with On-site Disposal and 

MNA 

$2,200,000 $2,300,000 $300,000 $4,800,000 

(3) 

Solidification/Stabilization 

with Off-site Disposal and 

MNA 

$2,200,000 $3,500,000 $300,000 $6,000,000 

(4) 

Containment with MNA 

$2,200,000 $1,800,000 $300,000 $4,300,000 

(5) 

Solidification/Stabilization 

of Soils in Unpaved Areas 

with Off-site Disposal and 

MNA 

$1,500,000 $1,500,000 $300,000 $3,300,000 

Notes: 

1 Fixed costs include site preparation, demolition, mobilization/demobilization, and LNAPL removal costs 

associated with Alternatives 2, 3, 4, and 5. 

2 Remedy costs include those costs to address lead contamination in soils as well as capital costs for a 

ground water monitoring network. 

3 O&M costs including ground water monitoring for MNA and five-year reviews. 

MNA Monitored natural attenuation 

LNAPL Light nonaqueous-phase liquid 

O&M Operation and maintenance 
6.0 REFERENCES 

Bomar, George W. 1983. “Texas Weather.” University of Texas Press. Austin, TX. 

Conestoga-Rovers Associates Services. 1999. “Drum Removal Action Final Report Many Diversified 

Interests Site, Houston Texas.” Prepared for the U.S. Environmental Protection Agency, Region 

6, Dallas, Texas. Reference ID 25986-16. December. 

Domenico, P.A. 1987. “An Analytical Model for Multidimensional Transport of Decaying Contaminant 

Species.” Journal of Hydrology. Volume 91. Pages 49-58. 

Enercon Services, Inc. 2003. “Asbestos Survey Report Many Diversified Interests Site, 3617 Baer Street 

Houston, Texas.” February 28. 

R.S. Means Company, Inc. (Means). 2002a. Environmental Remediation Cost Data–Unit Price, 

ECHOS–Environmental Cost Handling Options and Solutions. 8th Annual Edition. Kingston, 

MA. 

Means. 2002b. Heavy Construction Cost Data. 16th Annual Edition. Kingston, MA. 

TERA, Inc. 1994. “Report of Certain Site Investigation, 3617 Baer St.” Prepared For Paramount 

International Steel, Inc. 

Tetra Tech. 2003a. “Technical Memorandum–Evaluation of Suspected Catalyst Materials, Many

Diversified Interests Superfund Site.” January 31. 

Tetra Tech. 2003b. “Remedial Investigation Report For Operable Unit 1, Many Diversified Interests 

Superfund Site.” November 28. 

Tetra Tech. 2003c. “Screening-level Ecological Risk Assessment for Operable Unit 1, Remedial 

Investigation and Feasibility Study, Many Diversified Interests Superfund Site.” November 28. 

Tetra Tech. 2003d. “Human Health Risk Assessment for Operable Unit 1, Remedial Investigation and 

Feasibility Study, Many Diversified Interests Superfund Site.” December 1. 

Texas Natural Resource Conservation Commission (TNRCC). 1996a. “Screening Site Inspection 

Report, Volume I of III, MDI Site, Houston, Texas TXD008083404.” TNRCC Region 12–

Region Superfund Staff. July. 

TNRCC. 1996b. Many Diversified Interests, Inc. Notification of the Potential of Imminent Danger to 

the General Public from Hazardous Substances Found During the SSI Site Visit Conducted at this 

Site. Fax Transmittal from Stennie Meadours, Pollution Cleanup Division, Emergency Response 

and Assessment Section, TNRCC, to Charlie Gazda and Regan Broyles, EPA Region 6, 

Emergency Response Branch. February 12. 

TNRCC. 1998. E-mail from Johnny Kennedy to RTPMainhub.Interent Regarding Installation of 12 

Temporary Monitoring Wells at the MDI Site. May 8. 

U.S. Department of Agriculture. 1976. Soil Survey of Harris County, Texas. August. 

85 
U.S. Environmental Protection Agency (EPA). 1988. “Guidance for Conducting Remedial 

Investigations and Feasibility Studies Under CERCLA.” EPA/540/G-89/004. Office of 

Emergency and Remedial Response. Washington, D.C. October. 

EPA. 1997a. “BIOSCREEN Natural Attenuation Decision Support System Version 1.4.” EPA 600-R97-87. 

EPA. 1997b. “Record of Decision, Residential Areas, Operable Unit 2, Tar Creek Superfund Site, 

Ottawa County, Oklahoma.” EPA Region 6. August.

EPA. 1998. “Management of Remediation Waste Under RCRA.” EPA 530-F-98-026. Office of Solid 

Waste and Emergency Response (OSWER). Washington, D.C. October. 

EPA. 1999. “Presumptive Remedy for Metals-in-Soil Sites.” EPA 540-F-98-054. OSWER. 

Washington, D.C. September. 

EPA. 2000a. “A Guide to Developing and Documenting Cost Estimates During the Feasibility Study.” 

EPA 540-R-00-002. OSWER. Washington, D.C. (In conjunction with the U.S. Army Corps of 

Engineers, Omaha, NE). July. 

EPA. 2000b. “Institutional Controls: A Site Manager’s Guide to Identifying, Evaluating and Selecting 

Institutional Controls at Superfund and RCRA Corrective Action Cleanups.” EPA 540-F-00-005. 

OSWER. Washington, D.C. September. 

EPA. 2000c. “Record of Decision, Delatte Metals Superfund Site, Ponchatoula/Tangipahoa Parish, 

Louisiana.” EPA Region 6. September. 

EPA. 2003. “EPA Region 6 Human Health Medium-Specific Screening Levels.” December. Available 

on the Internet at http://www.epa.gov/earth1r6/6pd/rcra_c/pd-n/screen.htm

86 
APPENDIX A 

FATE AND TRANSPORT MODELING 

(19 Pages) 
APPENDIX A 

FATE AND TRANSPORT MODELING 

The screening-level model BIOSCREEN Version 1.4 (U.S. Environmental Protection Agency [EPA} 

1997) was used to assess the migration of the polycyclic aromatic hydrocarbons (PAH) benzo(a)pyrene 

and dibenzo(a,h)anthracene from the Many Diversified Interests (MDI) Superfund site via the ground 

water pathway in support of a monitored natural attenuation of ground water element in the feasibility

study (FS) report. The following sections present a brief description of the BIOSCREEN model, 

assumptions applied to the individual site models, a simplified conceptual model of the MDI site, and 

simulation results for the BIOSCREEN modeling. 

A1. MODEL DESCRIPTION

BIOSCREEN is a screening model that simulates remediation by natural attenuation of dissolved 

hydrocarbons in ground water. The software, programmed in the Microsoft Excel spreadsheet 

environment and based on the Domenico analytical solute transport model (Domenico 1987), has the 

ability to simulate one-dimensional advection, three-dimensional dispersion, linear adsorption, and 

biotransformation by both aerobic and anaerobic reactions. Dissolved solvent degradation is assumed to 

follow a sequential, first-order decay process in terms of viable alternative remediation strategies or 

through an instantaneous reaction. BIOSCREEN Version 1.4 allows for rate constant estimation through 

calibration of the model to site-specific field data or from literature values. 

At MDI, appreciable PAH concentrations were detected at the source location (MW-03) though not in the 

nearby downgradient wells (MW-02 and MW-24). As such, calibration of decay rates was not possible. 

Furthermore, reasonable published half-lives or decay constants for the degradation of benzo(a)pyrene 

and dibenzo(a,h)anthracene were not identified. Because of this, a conservative approach was taken for 

this modeling project by applying no degradation of contaminants within the dissolved-phase plume or 

source area throughout the simulation periods. Modeled PAH concentrations were allowed to decrease as 

a result of dilution or sorption onto sediments. Predictive simulations were conducted to estimate future 

plume behavior after both 30 years and 100 years using a combination of site-specific data obtained as 

part of the MDI remedial investigation (RI) for Operable Unit (OU) 1 (Tetra Tech 2003b) and published 

chemical properties for benzo(a)pyrene and dibenzo(a,h)anthracene. 

A-1 
A2. MODEL ASSUMPTIONS 

The following primary assumptions were applied to the BIOSCREEN modeling for the MDI site: 

1. The ground water plume length is estimated to be approximately half the distance between the

source at MW-03 and MW-02, the nearest downgradient well. As stated previously, none of the 

PAHs were present at detectable concentrations in this downgradient well. The plume is assumed 

to be 150 feet long (Figure A-1). 

2. Retardation factors for benzo(a)pyrene and dibenzo(a,h)anthracene of 46782 and 28189.6, 

respectively, were applied. 

3. Observation wells selected for the model simulations are located along the centerline of flow 

from the source. 

4. Contaminant concentrations at wells MW-03 and MW-02 using water quality data from the MDI 

RI represent the true plume concentration at those points. 

5. Aquifer porosity is limited to intergranular pores. Fractures have not been reported in the shallow 

water-bearing zone (SWBZ), and fracture flow is not considered to be representative of site 

conditions. 

6. The principal direction of flow is northwest near monitoring well MW-03 and the hydraulic 

gradient in the area is 0.0067 foot/foot. 

7. The fraction of organic carbon (foc) of 0.002 for a ground water sample collected from MW-03 

was used. 

8. A ground water flow velocity of approximately 236 feet per year (ft/yr) is assumed to be 

representative of the site and is based on the geometric mean hydraulic conductivity for the native 

sands of the SWBZ the observed hydraulic gradient between MW-03 and MW-02, and the 

average measured effective porosity of 0.2 (20 percent). 

9. A maximum concentration of dibenzo(a,h)anthracene of 0.000102 milligrams per liter (mg/L) is 

used as the source concentration in water (observed concentration at MW-03). 

10. A maximum concentration of benzo(a)pyrene of 0.000619 mg/L is used as the source 

concentration in water (observed concentration at MW-03). 

11. No degradation of PAHs occurs during the simulation period. 

A3. LOCAL CONCEPTUAL MODEL 

A conceptual site model (CSM) was developed for the entire MDI site as part of the RI for OU 1 (Tetra 

Tech 2003b). The CSM details conditions whereby ground water flow in the SWBZ is controlled by the 

interaction between the north pond, the foundry sands, and the native sediments. The SWBZ occurs 

A-2 
0

40

4

0

40

4

0 40

40

4

5

45

40

4

0

40

40

40

40

40

4

0

40

40

40

40

45

4

0

4

0

P10

BENZO(a)ANTHRACENE2

BENZO(a)PYRENE0.619

MW-03

23

24

PRESS STREET

PotentiometricSurface

LegendS

iteBoundary

Railroad

MonitoringWellLocation

SubdivisionBoundary

Street

Fence

MainContourInterval

(1footseparatesintervals)

Intermediary

ContourInterval

ApproximateExtentof

FoundrySands

FIGUREA-1

FATEANDTRANSPORT

MODELING

MDISUPERFUNDSITE

HOUSTON,TEXAS

BY:

TetraTechEMInc.

PREPAREDFOR:

Note:

1.Resultsarepostedinμg/L

050100

Feet

AreaModeled

10.22.03 b:\mdi\onsite\projects\Figure A-1 model area.mxd hp bl

BENZO(a)PYRENE<0.02

DIBENZO(a)ANTHRACENE<0.02

MW-02

GeoprobeLocation
within native sediments in the eastern and western thirds of the site. The static water surface of the 

SWBZ is typically encountered 16 to 18 feet bgs. The transmissive portion of the SWBZ is encountered 

between 22 and 26 feet bgs and consists of silty sand to poorly graded fine sand. The native sands are 

breached in the center of the site where Ingraham Gully transected the site. Ingraham Gully has been 

lined with the 12-foot-wide by 10-foot-long concrete box culvert described previously and backfilled with 

foundry sands. 

Contamination of the SWBZ is for the most part very localized, with sporadic detection of organic and 

inorganic contaminants associated with the fill materials that were placed within the Ingraham Gully

backfill. Site conditions near MW-3 are somewhat different. Here the backfill materials within the 

former Ingraham Gully do not extend to the top of the SWBZ. Furthermore, whereas the backfill 

materials across the site are typically fine sands, at the MW-03 location these materials are much finer 

grained. Additionally, while most other releases appear to be related to sporadic releases within the 

sands, at the MW-03 and nearby random grid boring location P-10, a significant volume of waste oil was 

disposed of in the sediments resulting in the presence of free product that has acted as a continuing source 

of ground water contamination. 

A4. MODEL SIMULATION RESULTS

Individual BIOSCREEN model simulations were run for benzo(a)pyrene and dibenzo(a,h)anthracene 

using the local CSM and assumptions described above. A summary of the input parameters applied to the 

individual model runs are presented in Table A-1. The results are summarized below for the individual 

models developed for the MDI site FS. The simulation results for benzo(a)pyrene are presented first 

followed by a summary of the dibenzo(a,h)anthracene simulation results. The associated model output 

files and associated concentration plots for benzo(a)pyrene and dibenzo(a,h)anthracene are presented in 

Attachments 1 and 2, respectively.

Benzo(a)pyrene Simulation Results 

As previously described, both 30-year and 100-year simulations were conducted to evaluate the fate and 

transport of benzo(a)pyrene at the MDI site. A ground water seepage velocity of 235.7 ft/yr was 

calculated using the geometric mean of hydraulic conductivity estimates from the MDI RI aquifer tests in 

the SWBZ (native sand) (Tetra Tech 2003b), a hydraulic gradient measured in 2003 between MW-03 and 

MW-02 (0.0067 foot per foot [ft/ft]), and an effective porosity value of 0.20. A retardation coefficient of 

46,782 was calculated for benzo(a)pyrene using foc content (0.2 percent), total porosity (0.39), and bulk 

A-4 
TABLE A-1 

PARAMETERS USED IN BIOSCREEN MODEL SIMULATIONS

MDI SUPERFUND SITE, HOUSTON, TEXAS 

OPERABLE UNIT 1

Parameter Value Value Source Comment 

Pore Velocity 237.5 feet/ year Calculated

Using RI aquifer test data (RI

Report), measured gradient, 

and effective porosity 

Longitudinal Dispersivity 15 feet 1/10 of model plume length See Calc Alpha x 

(Alpha y/Alpha x) 0.1 Typical value - - 

(Alpha z/Alpha x) 0 No vertical dispersion 

Source assumed to fully 

penetrate the SWBZ 

Benzo(a)pyrene Retardation 

Coefficient 46,782 Used field foc, ρb, n data, and Koc values from the literature 

SWBZ native sand (from

Table 25 of RI Report) 

Dibenzo(a,h)anthracene

Retardation Coefficient 28,189.6 Used field foc, ρb, n data, and Koc values from the literature 

SWBZ native sand (from

Table 25 of RI Report) 

Benzo(a)pyrene

Decay Rate 

0/year Assumed no decay - - 

Dibenzo(a,h)anthracene Decay 

Rate 0/year Assumed no decay - - 

Simulation Periods 30 years and 

100 years - - - - 

Modeled Area Width 25 feet - - - - 

Modeled Area Length 50 feet - - - - 

Benzo(a)pyrene Source 

Concentration 

0.619 

microgram/ 

liter 

Observed 2003 data Concentration at MW-03 

Dibenzo(a,h)anthracene Source 

Concentration 

0.102 

microgram/ 

liter 

Observed 2003 data Concentration at MW-03 

Notes: 

foc Fraction of organic carbon 

FS Feasibility study 

Koc Octanol-carbon partition coefficient 

n Total porosity 

ρb Bulk density 

RI Remedial investigation (references RI Report for Operable Unit 1 [Tetra Tech 2003b])

SWBZ Shallow water-bearing zone 

A-5 
density (1.66 kilograms per liter [kg/L]) data obtained from geotechnical samples collected from the 

SWBZ during the MDI RI. The individual input parameters applied to the benzo(a)pyrene model are 

presented in Table A-1. 

The 30-year model simulation results for benzo(a)pyrene are presented in Attachment 1A. The estimated 

extent of benzo(a)pyrene above detectable levels (i.e., 0.02 microgram per liter [:g/L]) is approximately 5 

feet downgradient of the source. The 100-year model simulation results for benzo(a)pyrene are 

summarized in Attachment 1B. These results also show very limited transport of benzo(a)pyrene from

the source at MW-03. The estimated extent of benzo(a)pyrene above detectable levels after 100 years is 

approximately 10 feet downgradient of the source. 

Dibenzo(a,h)anthracene Simulation Results 

Both 30-year and 100-year simulations were also conducted for dibenzo(a,h)anthracene at the MDI site. 

The ground water seepage velocity applied in the benzo(a)pyrene simulations was also used in these 

simulations. A retardation coefficient of 28,189.6 was calculated for dibenzo(a,h)anthracene using foc

content (0.2 percent), total porosity (0.39), and bulk density (1.66 kg/L) data obtained from geotechnical 

samples collected from the SWBZ during the MDI RI. The individual input parameters applied to the 

dibenzo(a,h)anthracene model are presented in Table A-1. 

The 30-year model simulation results for dibenzo(a,h)anthracene are summarized in Attachment 2A. 

After 30 years, the estimated extent of dibenzo(a,h)anthracene above detectable levels (i.e., 0.02 :g/L) is 

approximately 5 feet downgradient of the source. The 100-year model simulation results for 

dibenzo(a,h)anthracene are summarized in Attachment 2B. After 100 years, the estimated extent of 

benzo(a)pyrene above detectable levels is approximately 10 feet downgradient of the source. 

A5. SUMMARY AND CONCLUSIONS 

The BIOSCREEN simulation results show detectable concentrations of benzo(a)pyrene and 

dibenzo(a,h)anthracene for very short distances beyond the source area after both 30 years and 100 years. 

The concentrations of these contaminants of potential concern (COPC) decrease sharply with distance 

from the source areas, which is consistent with the current distribution of these constituents within the 

SWBZ (note, no PAHs have been detected in downgradient monitoring well MW-02). This suggests that 

the PAHs present at MW-03 are primarily sorbed onto the porous media with only limited partitioning of 

the COPCs into ground water occurring at the site. This is supported by the high distribution coefficients 

A-6 
associated with benzo(a)pyrene (10,991)and dibenzo(a,h)anthracene (6,623). The limited transport of 

benzo(a)pyrene and dibenzo(a,h)anthracene simulated in the models is related to the high retardation 

coefficients of these compounds (46,782 and 28,189.6, respectively). 

Based on field data, both hydrological and chemical, and reasonable estimates of variables of fate and 

transport of benzo(a)pyrene and dibenzo(a,h)anthracene in the SWBZ, a threat of contamination much 

beyond the source area is not likely to occur. The action of monitoring the SWBZ for benzo(a)pyrene and 

dibenzo(a,h)anthracene that could originate from the PAH source remaining in the shallow soil or the 

SWBZ with no other action on the solute plume should be sufficiently protective of the ground water 

resource outside the source area at MW-03 and off site. 

In order to better constrain the uncertainties associated with the individual models, it is recommended that 

additional water quality data be collected at the MDI site. Additional benzo(a)pyrene and 

dibenzo(a,h)anthracene concentration data is essential to constraining the concentration trends of these 

two compounds within the SWBZ. Additional water level monitoring will also help better define ground 

water flow directions and rates. As additional data are collected over time, the models should be updated 

to reflect current data and the predicted simulations refined. Although there are currently limitations and 

uncertainty with the individual models, they are considered useful in understanding the site and 

evaluating monitored natural attenuation as a remedial alternative.

A-7 
ATTACHMENT 1A 

30-YEAR MODEL SIMULATION FOR BENZO(A)PYRENE

(Two Pages) 
BIOSCREEN Natural Attenuation Decision Support Syste

m MDI Site Data Input Instruct

Air Force Center for Environmental Excellence Version 1.4 Benzo(a)pyrene 115 1. 

Run Name 2. 

1. HYDROGEOLOGY 5. GENERAL 0.02 

Seepage Velocity* Vs 235.7 (ft/yr) Modeled Area Length* 50 (ft) 

or Modeled Area Width* 25 (ft) Variable* D

Hydraulic Conductivity

K 6.8E-03 (cm/sec) Simulation Time* 30 (yr) 20 Va

Hydraulic Gradient i 0.0067 (ft/ft) (Porosity

n 0.2 (-) 6. SOURCE DATA 

Source Thickness in Sat.Zone* 4.5 (ft)

2. DISPERSION Source Zones:Longitudinal Dispersivity* alpha x 15.0 (ft) Width* (ft) Conc. (mg/L)*

Transverse Dispersivity* alpha y 1.5 (ft) 10 0.00015 1

Vertical Dispersivity* alpha z 0.0 (ft) 10 0.00031

or 50 0.000619

Estimated Plume Length Lp 150 (ft) 10 0.00031

10 0.00015

3. ADSORPTION Source Halflife (see Help):Retardation Factor*

R 46782.0 (-) >1000 >1000 (yr) View of Plum

or Inst. React. 1st Order

Soil Bulk Density rho 1.66 (kg/l) Soluble Mass 100000 (Kg) Observed Centerline Concen

Partition Coefficient Koc 5495409 (L/kg) In Source NAPL, Soil If No Data Leave 

FractionOrganicCarbon foc 2.0E-3 (-) 7. FIELD DATA FOR COMPARISON

Concentration (mg/L) 0.0006190 

4. BIODEGRADATION Dist. from Source (ft) 0 5 10 15 20 25 30 1st Order Decay Coeff* lambda 0.0E+0 (per yr)

or 8. CHOOSE TYPE OF OUTPUT TO SEE:

Solute Half-Life t-half (year)or Instantaneous Reaction ModelDelta Oxygen* DO 0 (mg/L)Delta Nitrate* NO3 0 (mg/L)

Observed Ferrous Iron* Fe2+ 0 (mg/L)Delta Sulfate* SO4 0 (mg/L)Observed Methane* CH4 0 (mg/L)

Vertical Plane Source: Loand Input Concentrations for Zones 1, 2, and 3

View Output

 Pas

View Output Res

Dispers

RUN 

CENTERLINE RUN ARRAY Help 

L

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oror oror

12345

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or
DISSOLVED HYDROCARBON CONCENTRATION ALONG PLUME CENTERLINE (m

Distance from Source (ft)

TYPE OF MODEL 0 5 10 15 20 25 30 35 40 

No Degradation 0.0006190 0.0000071 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 

1st Order Decay 0.0006190 0.0000071 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 

Inst. Reaction 0.0006190 0.0000071 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 

Field Data from Site 0.0006190 

Time:

30 Years Next Timestep

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Re

Benzo(a)pyrene @ 30yrs

0.00000000.00010000.00020000.00030000.00040000.00050000.00060000.0007000

0 10 20 30 40 

Distance From Source (ft)

Concentration

 (mg/L)

1st Order Deca

y Instantaneous Reactio

n No De

gradatio

n Field Data from Sit

e

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put
ATTACHMENT 1B 

100-YEAR MODEL SIMULATION FOR BENZO(A)PYRENE 

(Two Pages)
BIOSCREEN Natural Attenuation Decision Support Syste

m MDI Site Data Input Instruct

Air Force Center for Environmental Excellence Version 1.4 Benzo(a)pyrene 115 1. 

Run Name 2. 

1. HYDROGEOLOGY 5. GENERAL 0.02 

Seepage Velocity* Vs 235.7 (ft/yr) Modeled Area Length* 50 (ft) 

or Modeled Area Width* 25 (ft) Variable* D

Hydraulic Conductivity

K 6.8E-03 (cm/sec) Simulation Time* 100 (yr) 20 Va

Hydraulic Gradient i 0.0067 (ft/ft) (Porosity

n 0.2 (-) 6. SOURCE DATA 

Source Thickness in Sat.Zone* 4.5 (ft)

2. DISPERSION Source Zones:Longitudinal Dispersivity* alpha x 15.0 (ft) Width* (ft) Conc. (mg/L)*

Transverse Dispersivity* alpha y 1.5 (ft) 10 0.00015 1

Vertical Dispersivity* alpha z 0.0 (ft) 10 0.00031

or 50 0.000619

Estimated Plume Length Lp 150 (ft) 10 0.00031

10 0.00015

3. ADSORPTION Source Halflife (see Help):Retardation Factor*

R 46782.0 (-) >1000 >1000 (yr) View of Plum

or Inst. React. 1st Order

Soil Bulk Density rho 1.66 (kg/l) Soluble Mass 100000 (Kg) Observed Centerline Concen

Partition Coefficient Koc 5495409 (L/kg) In Source NAPL, Soil If No Data Leave 

FractionOrganicCarbon foc 2.0E-3 (-) 7. FIELD DATA FOR COMPARISON

Concentration (mg/L) 0.0006190 

4. BIODEGRADATION Dist. from Source (ft) 0 5 10 15 20 25 30 1st Order Decay Coeff* lambda 0.0E+0 (per yr)

or 8. CHOOSE TYPE OF OUTPUT TO SEE:

Solute Half-Life t-half (year)or Instantaneous Reaction ModelDelta Oxygen* DO 0 (mg/L)Delta Nitrate* NO3 0 (mg/L)

Observed Ferrous Iron* Fe2+ 0 (mg/L)Delta Sulfate* SO4 0 (mg/L)Observed Methane* CH4 0 (mg/L)

Vertical Plane Source: Loand Input Concentrations for Zones 1, 2, and 3

View Output

 Pas

View Output Res

Dispers

RUN 

CENTERLINE RUN ARRAY Help 

L

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12345

or

or
DISSOLVED HYDROCARBON CONCENTRATION ALONG PLUME CENTERLINE (m

Distance from Source (ft)

TYPE OF MODEL 0 5 10 15 20 25 30 35 40 

No Degradation 0.0006190 0.0000766 0.0000045 0.0000001 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 

1st Order Decay 0.0006190 0.0000766 0.0000045 0.0000001 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 

Inst. Reaction 0.0006190 0.0000766 0.0000045 0.0000001 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 

Field Data from Site 0.0006190 

Time:

100 Years Next Timestep

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Animation

Re

Benzo(a)pyrene @ 100yrs

0.00000000.00010000.00020000.00030000.00040000.00050000.00060000.0007000

0 10 20 30 40 

Distance From Source (ft)

Concentration

 (mg/L)

1st Order Deca

y Instantaneous Reactio

n No De

gradatio

n Field Data from Sit

e

Return to 

In

put
ATTACHMENT 2A 

30-YEAR MODEL SIMULATION FOR DIBENZO(A,H)ANTHRACENE

(Two Pages) 
BIOSCREEN Natural Attenuation Decision Support Syste

m MDI Site Data Input Instruct

Air Force Center for Environmental Excellence Version 1.4 Dibenzo(a,h)anthracene 115 1. 

Run Name 2. 

1. HYDROGEOLOGY 5. GENERAL 0.02 

Seepage Velocity* Vs 235.7 (ft/yr) Modeled Area Length* 50 (ft) 

or Modeled Area Width* 25 (ft) Variable* D

Hydraulic Conductivity

K 6.8E-03 (cm/sec) Simulation Time* 30 (yr) 20 Va

Hydraulic Gradient i 0.0067 (ft/ft) (Porosity

n 0.2 (-) 6. SOURCE DATA 

Source Thickness in Sat.Zone* 4.5 (ft)

2. DISPERSION Source Zones:Longitudinal Dispersivity* alpha x 15.0 (ft) Width* (ft) Conc. (mg/L)*

Transverse Dispersivity* alpha y 1.5 (ft) 10 0.000025 1

Vertical Dispersivity* alpha z 0.0 (ft) 10 0.00005

or 50 0.000102

Estimated Plume Length Lp 150 (ft) 10 0.00005

10 0.000025

3. ADSORPTION Source Halflife (see Help):Retardation Factor*

R 28189.6 (-) >1000 >1000 (yr) View of Plum

or Inst. React. 1st Order

Soil Bulk Density rho 1.66 (kg/l) Soluble Mass 100000 (Kg) Observed Centerline Concen

Partition Coefficient Koc 3311311 (L/kg) In Source NAPL, Soil If No Data Leave 

FractionOrganicCarbon foc 2.0E-3 (-) 7. FIELD DATA FOR COMPARISON

Concentration (mg/L) 0.0001020 

4. BIODEGRADATION Dist. from Source (ft) 0 5 10 15 20 25 30 1st Order Decay Coeff* lambda 0.0E+0 (per yr)

or 8. CHOOSE TYPE OF OUTPUT TO SEE:

Solute Half-Life t-half (year)or Instantaneous Reaction ModelDelta Oxygen* DO 0 (mg/L)Delta Nitrate* NO3 0 (mg/L)

Observed Ferrous Iron* Fe2+ 0 (mg/L)Delta Sulfate* SO4 0 (mg/L)Observed Methane* CH4 0 (mg/L)

Vertical Plane Source: Loand Input Concentrations for Zones 1, 2, and 3

View Output

 Pas

View Output Res

Dispers

RUN 

CENTERLINE RUN ARRAY Help 

L

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or
DISSOLVED HYDROCARBON CONCENTRATION ALONG PLUME CENTERLINE (m

Distance from Source (ft)

TYPE OF MODEL 0 5 10 15 20 25 30 35 40 

No Degradation 0.0001020 0.0000043 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 

1st Order Decay 0.0001020 0.0000043 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 

Inst. Reaction 0.0001020 0.0000043 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 

Field Data from Site 0.0001020 

Time:

30 Years Next Timestep

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Animation

Re

Dibenzo(a,h)anthracene @ 30yrs

0.00000000.00002000.00004000.00006000.00008000.00010000.0001200

0 10 20 30 40 

Distance From Source (ft)

Concentration

 (mg/L)

1st Order Deca

y Instantaneous Reactio

n No De

gradatio

n Field Data from Sit

e

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put
ATTACHMENT 2B 

100-YEAR MODEL SIMULATION FOR DIBENZO(A,H)ANTHRACENE 

(Two Pages)
BIOSCREEN Natural Attenuation Decision Support Syste

m MDI Site Data Input Instruct

Air Force Center for Environmental Excellence Version 1.4 Dibenzo(a,h)anthracene 115 1. 

Run Name 2. 

1. HYDROGEOLOGY 5. GENERAL 0.02 

Seepage Velocity* Vs 235.7 (ft/yr) Modeled Area Length* 50 (ft) 

or Modeled Area Width* 25 (ft) Variable* D

Hydraulic Conductivity

K 6.8E-03 (cm/sec) Simulation Time* 100 (yr) 20 Va

Hydraulic Gradient i 0.0067 (ft/ft) (Porosity

n 0.2 (-) 6. SOURCE DATA 

Source Thickness in Sat.Zone* 4.5 (ft)

2. DISPERSION Source Zones:Longitudinal Dispersivity* alpha x 15.0 (ft) Width* (ft) Conc. (mg/L)*

Transverse Dispersivity* alpha y 1.5 (ft) 10 0.000025 1

Vertical Dispersivity* alpha z 0.0 (ft) 10 0.00005

or 50 0.000102

Estimated Plume Length Lp 150 (ft) 10 0.00005

10 0.000025

3. ADSORPTION Source Halflife (see Help):Retardation Factor*

R 28189.6 (-) >1000 >1000 (yr) View of Plum

or Inst. React. 1st Order

Soil Bulk Density rho 1.66 (kg/l) Soluble Mass 100000 (Kg) Observed Centerline Concen

Partition Coefficient Koc 3311311 (L/kg) In Source NAPL, Soil If No Data Leave 

FractionOrganicCarbon foc 2.0E-3 (-) 7. FIELD DATA FOR COMPARISON

Concentration (mg/L) 0.0001020 

4. BIODEGRADATION Dist. from Source (ft) 0 5 10 15 20 25 30 1st Order Decay Coeff* lambda 0.0E+0 (per yr)

or 8. CHOOSE TYPE OF OUTPUT TO SEE:

Solute Half-Life t-half (year)or Instantaneous Reaction ModelDelta Oxygen* DO 0 (mg/L)Delta Nitrate* NO3 0 (mg/L)

Observed Ferrous Iron* Fe2+ 0 (mg/L)Delta Sulfate* SO4 0 (mg/L)Observed Methane* CH4 0 (mg/L)

Vertical Plane Source: Loand Input Concentrations for Zones 1, 2, and 3

View Output

 Pas

View Output Res

Dispers

RUN 

CENTERLINE RUN ARRAY Help 

L

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12345

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or
DISSOLVED HYDROCARBON CONCENTRATION ALONG PLUME CENTERLINE (m

Distance from Source (ft)

TYPE OF MODEL 0 5 10 15 20 25 30 35 40 

No Degradation 0.0001020 0.0000207 0.0000034 0.0000002 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 

1st Order Decay 0.0001020 0.0000207 0.0000034 0.0000002 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 

Inst. Reaction 0.0001020 0.0000207 0.0000034 0.0000002 0.0000000 0.0000000 0.0000000 0.0000000 0.0000000 

Field Data from Site 0.0001020 

Time:

100 Years Next Timestep

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Re

Dibenzo(a,h)anthracene @ 100yrs

0.00000000.00002000.00004000.00006000.00008000.00010000.0001200

0 10 20 30 40 

Distance From Source (ft)

Concentration

 (mg/L)

1st Order Deca

y Instantaneous Reactio

n No De

gradatio

n Field Data from Sit

e

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APPENDIX B 

COST ESTIMATE DETAILS 

(31 Pages) 
Target Media Capital Cost ($)

Lifetime O&M 

Cost ($)

Post-remediation 

Monitoring Cost 

($) Total Cost ($)

Remediati

Frame (m

Soil $4,369,135 $40,947 $0 $4,410,082 6 

Deep Soil/Ground Water Contamination $118,161 $0 $263,933 $382,094 1 

$4,487,296 $40,947 $263,933 $4,792,177 7 

Note:

O&M Operation and maintenance

Component

Excavation and Off-site Disposal with MNAExcavation and Solidification/StabilizationMonitored Natural Attenuation (MNA)

ALTERNATIVE 2

SOLIDIFICATION/STABILIZATION WITH ON-SITE DISPOSAL AND MNA

TOTAL REMEDIAL COST SUMMARY

MDI SUPERFUND SITE OPERABLE UNIT 1

Page 1
ALTERNATIVE 2

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 2 - Solidification/Stabilization with On-site Disposal and Monitored Natural Attenuation

Construction 

time: 6 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material Opinion

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

REMEDIAL ACTION (RA) TOTAL CAPITAL COST $4,369,135

Construction Activities $3,386,926

Site Work $185,344 $207,867 $2,550,470 $2,943,682

Temporary Facilities $0 $0 $258,645 $258,645

1 lump sum $0.00 $0 $0.00 $0 $11,465 $11,465 $11,465

1 lump sum $0.00 $0 $0.00 $0 $2,399 $2,399 $2,399

1 lump sum $0.00 $0 $0.00 $0 $8,011 $8,011 $8,011

6 per month $0.00 $0 $0.00 $0 $21,418 $128,509 $128,509

1 lump sum $0.00 $0 $0.00 $0 $32,553 $32,553 $32,553

6 per month $0.00 $0 $0.00 $0 $10,618 $63,708 $63,708

6 ea $0.00 $0 $0.00 $0 $2,000.00 $12,000 $12,000

$143,163 $166,522 $1,411,041 $1,720,727

$6 $10 $8,039 $8,054

2-cy loader (ECHOS 17 02 0415) 30 cy $0.20 $6 $0.32 $10 $0.00 $0 $16

Hazardous debris disposal (estimate from vendor) 30 cy $0.00 $0 $0.00 $0 $108.10 $3,243 $3,243

Hazardous debris transportation (20 cy per load)(estimate from 

vendor) 2 loads $0.00 $0 $0.00 $0 $2,398 $4,796 $4,796

$44,528 $34,840 $99,093 $178,460

2-cy Loader (nonhazardous debris load only) (ECHOS 17 02

0415) 6,500 cy $0.20 $1,300 $0.32 $2,080 $0.00 $0 $3,380

Nonhazardous debris disposal (estimate from vendor) 6,500 cy $0.00 $0 $0.00 $0 $6.62 $43,030 $43,030

Nonhazardous debris transportation (20 cy per load)(estimate 

from vendor) 325 loads $0.00 $0 $0.00 $0 $172.50 $56,063 $56,063

Clearing and grubbing; medium brush with average grub and som

trees; clearing (ECHOS 17 01 0106) 36 acres $275 $9,885 $417 $15,012 $0.00 $0 $24,897

Machine-load spoils; 2-mile haul to dump (ECHOS 02110 2000) 36 acres $926 $33,343 $493 $17,748 $0.00 $0 $51,091

ACM Removal and Disposal $0 $0 $249,165 $249,165

ACM oversight contractor (estimate from vendor) 1 ea $0.00 $0 $0.00 $0 $19,165 $19,165 $19,165

ACM removal and disposal (estimate from contractor) 1 ea $0.00 $0 $0.00 $0 $230,000 $230,000 $230,000

$0 $0 $7,970 $7,970

Hazardous water removal (WS-1)(estimate from vendor) 3 hours $0.00 $0 $0.00 $0 $80.50 $242 $242

Hazardous water disposal (WS-1)(estimate from vendor) 400 gal $0.00 $0 $0.00 $0 $0.86 $345 $345

Petroleum water removal (WS-6 and UST)(estimate from vendor) 6 hours $0.00 $0 $0.00 $0 $80.50 $483 $483

Petroleum water disposal (WS-6 and UST)(estimate from vendor) 10,000 gal $0.00 $0 $0.00 $0 $0.35 $3,450 $3,450

Other water removal (WS-2, 3, 5, 7, and 8)(estimate from vendor) 12 hours $0.00 $0 $0.00 $0 $80.50 $966 $966

Other water disposal (WS-2, 3, 5, 7, and 8)(estimate from vendor) 12,000 gal $0.00 $0 $0.00 $0 $0.21 $2,484 $2,484

Building Demolition and Disposal $12,394 $9,863 $139,018 $161,275

Multi-level, masonry, nonexplosive building demolition (ECHOS 17 

02 0103) 178,000 cf $0.06 $10,680 $0.04 $7,120 $0.00 $0 $17,800

2-cy Loader (load only, 30% expansion) (ECHOS 17 02 0415) 8,570 cy $0.20 $1,714 $0.32 $2,743 $0.00 $0 $4,457

Building debris transportation (18 cy per load)(estimate from 

vendor) 477 loads $0.00 $0 $0.00 $0 $172.50 $82,283 $82,283

Building debris disposal (nonhazardous debris)(estimate from 

vendor) 8,570 cy $0.00 $0 $0.00 $0 $6.62 $56,736 $56,736

Concrete Demolition and Disposal $1,950 $3,120 $522,459 $527,529

Concrete demolition (recent EPA Region 6 RA) 7,500 cy $0.00 $0 $0.00 $0 $38.64 $289,800 $289,800

2-cy Loader (load only, 30% expansion)(ECHOS 17 02 0415) 9,750 cy $0.20 $1,950 $0.32 $3,120 $0.00 $0 $5,070

Concrete transportation (20 tons per load, 2 tons per cy)(estimate

from vendor) 975 loads $0.00 $0 $0.00 $0 $172.50 $168,188 $168,188

Concrete disposal (estimate from vendor) 9,750 cy $0.00 $0 $0.00 $0 $6.61 $64,472 $64,472

$4 $6 $1,676 $1,686

Solidification/stabilization (recent EPA Region 6 RA) 30 ton $0.00 $0 $0.00 $0 $14.28 $428 $428

2-cy Loader (load only, 30% expansion)(ECHOS 17 02 0415) 20 cy $0.20 $4 $0.32 $6 $0.00 $0 $10

Transportation (estimate from vendor) 2 loads $0.00 $0 $0.00 $0 $172.50 $345 $345

Disposal (Class I) 20 cy $0.00 $0 $0.00 $0 $46.29 $903 $903

Project sign (recent EPA Region 6 RA)

Support facilities (office trailers, storage trailers, utilities, outdoor 

lighting, meteorological station)(recent EPA Region 6 RA)

Security (24 hours per day, 7 days per week)(recent EPA Region 6 

RA)

Install and maintain storm water control measures (recent EPA Region 

6 RA)

TECHNOLOGY LOCATION: MEDIA:

Excavation and Solidification/Stabilization MDI Soil

Nonhazardous Debris Removal and Disposal

Decontamination pad (recent EPA Region 6 RA)

Install temporary electrical service (recent EPA Region 6 RA)

Plug and abandon existing monitoring wells (24 feet deep)(based on 

previous work in EPA Region 6)

Bag House Material Disposal

Demolition and Debris Removal

Hazardous Debris Removal and Disposal

Water Removal and Disposal

Excavation and On-site Disposal

Page 1 of 4
ALTERNATIVE 2

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 2 - Solidification/Stabilization with On-site Disposal and Monitored Natural Attenuation

Construction 

time: 6 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material Opinion

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

Excavation and Solidification/Stabilization MDI Soil

UST Removal $1,932 $3,569 $9,852 $15,353

Remove steel/fiberglass UST: 2,001 - 5,000 gallon capacity 

(ECHOS 33 10 9505) 1 ea $910 $910 $3,285 $3,285 $0.00 $0 $4,195

Excavation and stockpiling of contaminated soil (recent EPA 

Region 6 RA) 90 cy $0.00 $0 $0.00 $0 $18.08 $1,627 $1,627

2-cy Loader (load only, 43% expansion)(ECHOS 17 02 0415) 129 cy $0.20 $26 $0.32 $41 $0.00 $0 $67

UST soil transportation (18 cy per load)(estimate from vendor) 8 loads $0.00 $0 $0.00 $0 $172.50 $1,380 $1,380

Soil disposal (Class 1)(estimate from vendor) 129 cy $0.00 $0 $0.00 $0 $46.29 $5,957 $5,957

Clean soil borrow, common earth (39% compaction) (M 02315 

200 4060) 125 cy 0.49 $61 0.39 $49 $7.10 $888 $998

Fill, spread dumped material, by dozer, no compaction (M 02315 

505 0010) 125 cy 0.47 $59 $1.14 $143 $0.00 $0 $201

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 passes (M 

02315 300 5720) 125 cy 0.18 $23 $0.41 $51 $0.00 $0 $74

Compaction testing, 1 nuclear per 5000 sf per 9-inch compacted 

lift (ASTM 2922 M 01450 500 4735) 16 ea 53.36 $854 $0.00 $0 $0.00 $0 $854

LNAPL Impacted Soil Removal $82,349 $115,115 $356,477 $553,941

Steel sheeting; install, pull, and salvage; to 40 feet (MW-3

Area)(ECHOS 17 03 0904) 8400 sf 3.67 $30,828 $4.93 $41,412 $3.39 $28,510 $100,750

Steel sheeting; install, pull, and salvage; to 25 feet (MW-11 and

MW-20 Areas)(ECHOS 17 03 0903) 14160 sf 3.14 $44,462 $4.21 $59,614 $2.74 $38,829 $142,905

Excavation and stockpiling of overburden soil (recent EPA Region 

6 RA) 3,465 cy $0.00 $0 $0.00 $0 $18.08 $62,647 $62,647

Excavation and stockpiling of contaminated soil (recent EPA 

Region 6 RA) 2,100 cy $0.00 $0 $0.00 $0 $18.08 $37,968 $37,968

2-cy Loader (load only, 43% expansion)(ECHOS 17 02 0415) 3,003 cy $0.20 $601 $0.32 $961 $0.00 $0 $1,562

Contaminated soil transportation (18 cy per load)(estimate from 

vendor) 167 loads $0.00 $0 $0.00 $0 $172.50 $28,808 $28,808

Soil disposal (Class 1)(estimate from vendor) 3,003 cy $0.00 $0 $0.00 $0 $46.29 $139,001 $139,001

Clean soil borrow, common earth (39% compaction) (M 02315 

200 4060) 2919 cy 0.49 $1,430 0.39 $1,138 $7.10 $20,715 $23,283

Fill, spread dumped material, by dozer, no compaction (M 02315 

505 0010) 7735 cy 0.47 $3,636 $1.14 $8,818 $0.00 $0 $12,454

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 passes (M 

02315 300 5720) 7735 cy 0.18 $1,392 $0.41 $3,171 $0.00 $0 $4,564

Compaction testing, 1 nuclear per 5000 sf per 9-inch compacted 

lift (ASTM 2922 M 01450 500 4735) 0 ea 53.36 $0 $0.00 $0 $0.00 $0 $0

PCB Transformer Disposal $0 $0 $17,293 $17,293

Transportation (separate trips for fluid and transformer)(estimate 

from vendor) 2 ea $0.00 $0 $0.00 $0 $2,990 $5,980 $5,980

Incineration of PCB-contaminated oil (estimate from vendor) 16,395 lb $0.00 $0 $0.00 $0 $0.69 $11,313 $11,313

Excavation and Treatment $0 $0 $601,460 $601,460

13,600 cy $0.00 $0 $0.00 $0 $18.08 $245,888 $245,888

20,400 ton $0.00 $0 $0.00 $0 $14.28 $291,312 $291,312

4,500 ton $0.00 $0 $0.00 $0 $14.28 $64,260 $64,260

Backfill and Compaction $42,181 $41,345 $279,324 $362,851

18,904 cy $0.49 $9,263 $0.31 $5,860 $7.09 $134,029 $149,153

18,904 cy $0.79 $14,934 $1.26 $23,819 $0.00 $0 $38,753

18,904 cy $0.18 $3,391 $0.32 $5,971 $0.00 $0 $9,362

55 ea $53.35 $2,934 $0.00 $0 $0.00 $0 $2,934

16,600 cy $0.49 $8,134 $0.31 $5,146 $7.09 $117,694 $130,974

1,280 ft $1.84 $2,355 $0.00 $0 $20.86 $26,701 $29,056

1,280 ft $0.81 $1,037 $0.38 $486 $0.24 $307 $1,830

1 ea $133.10 $133 $62.11 $62 $592.88 $593 $788

Sampling and Analysis $0 $0 $135,342 $135,342

Treated Soil Sampling

TCLP (RCRA metals)(recent EPA Region 6 RA) 50 ea $0.00 $0.00 $0.00 $0.00 $322.00 $16,100 $16,100

Total lead (recent EPA Region 6 RA) 97 ea $0.00 $0.00 $0.00 $0.00 $95.45 $9,259 $9,259

Clean soil borrow, common earth (M 02315 200 4060)

Backfill, spread fill, from stockpile w/ front-end loader (M 02315 505 

0170)

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 passes (M 02315 

300 5720)

Compaction testing, nuclear method (ASTM D2922); 1 per 5,000 sf 

per 9-inch loose lift (M 01450 500 4735)

6' Galvanized Chain-link Fence (ECHOS 18 04 0107)

Galvanized Barbed Wire, 3-Strand (ECHOS 0.19 04 0111)

6' Swing Gate, 12' Double (ECHOS 18 04 0117)

Excavation and stockpiling of lead contaminated soil (recent EPA 

Region 6 RA)

Unclassified fill, 6-inch lifts, on-site; includes spreading and 

compaction (ECHOS 17 03 0422)

Solidification/stabilization (recent EPA Region 6 RA)

Solidification/stabilization of off-property soil (recent EPA Region 6 

RA)

Excavation Confirmation Sampling (1 per 2,500 sf plus 10% QA/QC)

Excavation and On-site Disposal

Page 2 of 4
ALTERNATIVE 2

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 2 - Solidification/Stabilization with On-site Disposal and Monitored Natural Attenuation

Construction 

time: 6 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material Opinion

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

Excavation and Solidification/Stabilization MDI Soil

XRF Sampling (field sampling for lead)

XRF rental (recent EPA Region 6 RA) 6 month $0.00 $0.00 $0.00 $0.00 $4,418.30 $26,510 $26,510

1 ea $0.00 $0.00 $0.00 $0.00 $1,640 $1,640 $1,640

Air Monitoring

6 month $0.00 $0.00 $0.00 $0.00 $5,359.00 $32,154 $32,154

720 ea $0.00 $0.00 $0.00 $0.00 $69.00 $49,680 $49,680

Mobilization and Demobilization $307,902

10% $307,902

System Contingency $338,693

10% of Total Construction Activities $338,693

Professional/Technical Services $643,516

8% $270,954

5% $169,346

6% $203,216

OPERATION AND MAINTENANCE (O&M) O&M COST (per 5 year review interval) $17,167

Monitoring, Sampling, Testing, and Analysis 1 lump sum $0 $0 $0 $0

Post-Remediation Site Monitoring

Geoprobe 0 lump sum $10,000 $0 $5,000 $0 $0 $0 $0

Field Work Labor 0 lump sum $15,000 $0 $0 $0 $0 $0 $0

0 lump sum $15,000 $0 $0 $0 $0 $0 $0

System O&M $0 $0 $0 $0

1 ea $14,000 $14,000 $0 $0 $0.00 $0 $14,000

$3,167

LIFETIME O&M (Net Present Value) $40,947

Years of Operation 30

Discount Factor 7%

TOTAL COST (CAPITAL COST + LIFETIME O&M)

Assumptions: 

1 2002 RS Means values increased to account for inflation 2.25%

2 Working condition is Safety Level: D (Labor productivity: 75% ; Equipment productivity: 95% )

3 Soil profile sampling will be conducted at the frequency of: 1 sample for every: 500 cy of contaminated soil plus 10% QA/QC

4 Cost index for zip code 770 88% (not applicable for costs derived from vendor quotes).

5 Costs are loaded with an overhead and profit factor: 15%

6 No net present value calculation is presented for alternative with an estimated remediation timeframe that is less than 1 year.

7 No dewatering costs included.

8 Treated soil and compaction volumes include 3,000 cy from off-property excavations currently stockpiled on property.

9 Debris volume only includes removal of debris overlying areas to be excavated.

10 Concrete volume only includes demolition and disposal of concrete over areas to be excavated.

5 year review (Previous Region 6 work assignments)

$4,410,082

of Total Costs of Site Work and Sampling & Analysis

Remedial Design (Percentage of capital costs)(Exhibit 5-8 from EPA 

2000)

Data Analysis/Analytical

Cap and fence maintenance (10% of installed cost per 5 

XRF supplies (cups, mylar, oven, bowls)(recent EPA Region 6 RA)

Equipment rental (low-flow air samplers, calibrator, dust monitor, 

calibration gas, and sound meter)(recent EPA Region 6 RA)

Air sample analysis (lead and total particulates; 4 samples per 

day)(recent EPA Region 6 RA)

Project Management (Percentage of capital costs)(Exhibit 5-8 from 

EPA 2000)

Construction Management (Percentage of capital costs)(Exhibit 5-8 

from EPA 2000)

Excavation and On-site Disposal

Page 3 of 4
ALTERNATIVE 2

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 2 - Solidification/Stabilization with On-site Disposal and Monitored Natural Attenuation

Construction 

time: 6 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material Opinion

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

Excavation and Solidification/Stabilization MDI Soil

Estimated Volume of Excavation:

Total

Estimated total volume of contaminated soil : 13,600 0 0 13,600 cf

Average soil swelling factor: 43%

Average soil density: 1.5 tons/cy

In-place Loose

13,600 19,448 cy 20,400 tons

39%

18,904

Notes:

ACM Asbestos-containing material

ASTM American Society of Testing and Materials

cf Cubic foot

cy Cubic yard

ECHOS Environmental Cost Handling Options and Solutions (RS Means 2002a)

EPA U.S. Environmental Protection Agency

gal Gallon

lb Pound

LNAPL Light nonaqueous-phase liquid

MW Monitoring well

PCB Polychlorinated biphenyl

QA/QC Quality assurance/quality control

RCRA Resource Conservation and Recovery Act

sf Square feet

TCLP Toxicity Characteristic Leaching Procedure

UST Underground storage tank

WS Waste sample

XRF X-ray fluoresence

References: 

1) RS Means. 2002b. Heavy Construction Cost Data. 16th Annual Edition.

2) RS Means. 2002a. Environmental Remediation Cost Data, Unit Price. 8th Annual Edition

3) EPA. 2000. A Guide to Developing and Documenting Cost Estimates During the Feasibility Study.

Estimated total volume of replacement soil

Replacement soil compaction factor

Estimated total volume of excavated soil :

Excavation and On-site Disposal

Page 4 of 4
ALTERNATIVE 2

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 2 - Solidification/Stabilization and On-site Disposal and Monitored Natural Attenuation 

Construction 

TIme: 1 months

Operation 

TIme:

30.0

years

Post 

Remediation 

Monitoring

30.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material Opinion

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

REMEDIAL ACTION TOTAL CAPITAL COST $118,161

Initial Site Characterization $75,502

6 ea $0.00 $0 $0.00 $0 $3,450 $20,700 $20,700

48 well $286 $13,733 $142.39 $6,835 $15.08 $724 $21,292

48 ea

48 sample $0 $0 $0 $0 $233.80 $11,222 $11,222

48 sample $0 $0 $0 $0 $51.73 $2,483 $2,483

48 sample $0 $0 $0 $0 $71.18 $3,416 $3,416

Ferrous iron (ECHOS 33 02 1678) 48 sample $0 $0 $0 $0 $96.42 $4,628 $4,628

Dissolved manganese (ECHOS 33 02 1644) 48 sample $0 $0 $0 $0 $71.18 $3,416 $3,416

Nitrate (ECHOS 33 02 1661) 48 sample $0 $0 $0 $0 $36.70 $1,762 $1,762

Sulfate (ECHOS 33 02 1667) 48 sample $0 $0 $0 $0 $19.40 $931 $931

Dissolved oxygen (ECHOS 33 02 1663) 48 sample $0 $0 $0 $0 $28.76 $1,381 $1,381

1 lump sum $4,271 $4,271 $0 $0 $0 $0 $4,271

Contingency $7,550

10% of total construction activities $7,550

Professional/Technical Services $35,109

20% $15,100

10% $7,550

15% $12,458

MNA Monitoring (Annually) $21,269

Monitoring, Sampling, Testing, and Analysis 12 months $3,433 $1,709 $7,330 $12,472

8 well $286 $2,289 $142.39 $1,139 $15.08 $121 $3,549

4 well $286 $1,144 $142.39 $570 $15.08 $60 $1,774

12 ea

12 sample $0 $0 $0 $0 $228.65 $2,744 $2,744

12 sample $0 $0 $0 $0 $50.59 $607 $607

12 sample $0 $0 $0 $0 $69.61 $835 $835

Ferrous iron (ECHOS 33 02 1678) 12 sample $0 $0 $0 $0 $94.30 $1,132 $1,132

Dissolved manganese (ECHOS 33 02 1644) 12 sample $0 $0 $0 $0 $69.61 $835 $835

Nitrate (ECHOS 33 02 1661) 12 sample $0 $0 $0 $0 $35.89 $431 $431

Sulfate (ECHOS 33 02 1667) 12 sample $0 $0 $0 $0 $18.98 $228 $228

Dissolved oxygen (ECHOS 33 02 1663) 12 sample $0 $0 $0 $0 $28.13 $338 $338

Contingency $1,247

10% $1,247

Professional/Technical Services 12 months $0.00 $0.00 $0.00 $7,550

Sample wells (4 wells sampled annually)(RS 

Means 33 02 0401, 33 02 0402; Total Safety)

Polynuclear aromatic hydrocarbons 

(3510C)(ECHOS 33 02 2134)

Ground water fate and transport modeling 

(ECHOS 33 02 0419)

Remedial Design (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Project Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Construction Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Sample wells (2 wells sampled quarterly)(RS 

Means 33 02 0401, 33 02 0402; Total Safety)

Lab analysis 

of Total Monitoring, Sampling, Testing, and 

Analysis

Lead (ECHOS 33 02 2143)

Iron (ECHOS 33 02 1644)

MEDIA:

MDI

Monitored Natural Attenuation (MNA)

TECHNOLOGY LOCATION:

Deep Soil/Ground 

Water Contamination

Iron (ECHOS 33 02 1644)

Sample wells (6 wells sampled quarterly for 2 

years)(RS Means 33 02 0401, 33 02 0402; Total 

Safety)

Lab analysis 

Installation, completion, and development of 

additional monitor wells to 18 feet bgs (recent 

RAC work in Region 6)

Polynuclear aromatic hydrocarbons 

(3510C)(ECHOS 33 02 2134)

Lead (ECHOS 33 02 2143)

Monitored Natural Attenuation

Page 1 of 2
ALTERNATIVE 2

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 2 - Solidification/Stabilization and On-site Disposal and Monitored Natural Attenuation 

Construction 

TIme: 1 months

Operation 

TIme:

30.0

years

Post 

Remediation 

Monitoring

30.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material Opinion

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

MEDIA:

MDI

Monitored Natural Attenuation (MNA)

TECHNOLOGY LOCATION:

Deep Soil/Ground 

Water Contamination

10% $7,550

LIFETIME MONITORING COST (Present Value) $263,933

Years of Operation 30

Discount Factor 7.0%

TOTAL COST (CAPITAL COST + LIFETIME OPERATING COST)

Assumptions: 

1 2002 RS Means values increased to account for inflation 2.25%

2 Working condition is Safety Level: D (Labor productivity: 75% ; Equipment productivity: 95% )

3 Cost index for zip code 770 88% (not applicable for costs derived from vendor quotes).

4 Costs are loaded with an overhead and profit factor: 15%

5 No net present value calculation is presented for alternative with an estimated remediation timeframe that is less than 1 year.

Notes:

bgs Below ground surface

ECHOS Environmental Cost Handling Options and Solutions (RS Means 2002a)

EPA U.S. Environmental Protection Agency

RAC Response Action Contract

References: 

1) RS Means. 2002b. Heavy Construction Cost Data. 16th Annual Edition.

2) RS Means. 2002a. Environmental Remediation Cost Data, Unit Price. 8th Annual Edition

3) EPA. 2000. A Guide to Developing and Documenting Cost Estimates During the Feasibility Study.

$382,094

Project Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Monitored Natural Attenuation

Page 2 of 2
APPENDIX B-1 

ALTERNATIVE 2–SOLIDIFICATION/STABILIZATION WITH ON-SITE DISPOSAL; 

GROUND WATER VIA MNA WITH ICS 

(Seven Pages) 
Target Media Capital Cost ($)

Lifetime O&M 

Cost ($)

Post-remediation 

Monitoring Cost 

($) Total Cost ($)

Remediati

Frame (m

Soil $5,425,699 $0 $0 $5,425,699 6 

Deep Soil/Ground Water Contamination $118,161 $0 $298,679 $416,840 1 

$5,543,860 $0 $298,679 $5,842,539 7 

Note:

O&M Operation and maintenance

Component

Excavation and Off-site Disposal with MNAExcavation, Solidification/Stabilization, and Off-site DisposalMonitored Natural Attenuation (MNA)

ALTERNATIVE 3

EXCAVATION AND OFF-SITE DISPOSAL WITH MNA

TOTAL REMEDIAL COST SUMMARY

MDI SUPERFUND SITE OPERABLE UNIT 1

Page 1
ALTERNATIVE 3

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 3 - Solidification/Stabilization and Off-site Disposal Construction 

time: 6 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

REMEDIAL ACTION (RA) TOTAL CAPITAL COST $5,425,699

Construction Activities $4,553,325

Site Work $173,685 $202,173 $2,405,175 $2,781,033

Temporary Facilities $0 $0 $258,645 $258,645

1 lump sum $0.00 $0 $0.00 $0 $11,465 $11,465 $11,465

1 lump sum $0.00 $0 $0.00 $0 $2,399 $2,399 $2,399

1 lump sum $0.00 $0 $0.00 $0 $8,011 $8,011 $8,011

6 per month $0.00 $0 $0.00 $0 $21,418 $128,509 $128,509

1 lump sum $0.00 $0 $0.00 $0 $32,553 $32,553 $32,553

6 per month $0.00 $0 $0.00 $0 $10,618 $63,708 $63,708

6 ea $0.00 $0 $0.00 $0 $2,000.00 $12,000 $12,000

$173,685 $202,173 $2,146,531 $2,522,389

$6 $10 $8,039 $8,054

2-cy Loader (ECHOS 17 02 0415) 30 cy $0.20 $6 $0.32 $10 $0.00 $0 $16

Hazardous debris disposal (estimate from vendor) 30 cy $0.00 $0 $0.00 $0 $108.10 $3,243 $3,243

Hazardous debris transportation (20 cy per 

load)(estimate from vendor) 2 loads $0.00 $0 $0.00 $0 $2,398 $4,796 $4,796

$44,528 $34,840 $99,093 $178,460

2-cy Loader (nonhazardous debris load only)(ECHOS 

17 02 0415) 6,500 cy $0.20 $1,300 $0.32 $2,080 $0.00 $0 $3,380

Nonhazardous debris disposal (estimate from vendor) 6,500 cy $0.00 $0 $0.00 $0 $6.62 $43,030 $43,030

Nonhazardous debris transportation (20 cy per 

load)(estimate from vendor) 325 loads $0.00 $0 $0.00 $0 $172.50 $56,063 $56,063

Clearing and grubbing; medium brush with average 

grub and some trees, clearing (ECHOS 17 01 0106) 36 acres $275 $9,885 $417 $15,012 $0.00 $0 $24,897

Machine-load spoils; 2-mile haul to dump (ECHOS 

02110 2000) 36 acres $926 $33,343 $493 $17,748 $0.00 $0 $51,091

ACM Removal and Disposal $0 $0 $249,165 $249,165

ACM oversight contractor (estimate from vendor) 1 ea $0.00 $0 $0.00 $0 $19,165 $19,165 $19,165

ACM removal and disposal (estimate from contractor) 1 ea $0.00 $0 $0.00 $0 $230,000 $230,000 $230,000

$0 $0 $7,970 $7,970

Hazardous water removal (WS-1)(estimate from vendor) 3 hours $0.00 $0 $0.00 $0 $80.50 $242 $242

Hazardous water disposal (WS-1)(estimate from 

vendor) 400 gal $0.00 $0 $0.00 $0 $0.86 $345 $345

Petroleum water removal (WS-6 and UST)(estimate 

from vendor) 6 hours $0.00 $0 $0.00 $0 $80.50 $483 $483

Petroleum water disposal (WS-6 and UST)(estimate 

from vendor) 10,000 gal $0.00 $0 $0.00 $0 $0.35 $3,450 $3,450

Other water removal (WS-2, 3, 5, 7, and 8)(estimate 

from vendor) 12 hours $0.00 $0 $0.00 $0 $80.50 $966 $966

Other water disposal (WS-2, 3, 5, 7, and 8)(estimate 

from vendor) 12,000 gal $0.00 $0 $0.00 $0 $0.21 $2,484 $2,484

Building Demolition and Disposal $12,394 $9,863 $139,018 $161,275

Multi-level, masonry, nonexplosive building demolition 

(ECHOS 17 02 0103) 178,000 cf $0.06 $10,680 $0.04 $7,120 $0.00 $0 $17,800

2-cy Loader (load only, 30% expansion)(ECHOS 17 02 

0415) 8,570 cy $0.20 $1,714 $0.32 $2,743 $0.00 $0 $4,457

Building debris transportation (18 cy per load)(estimate 

from vendor) 477 loads $0.00 $0 $0.00 $0 $172.50 $82,283 $82,283

Building debris disposal (nonhazardous 

debris)(estimate from vendor) 8,570 cy $0.00 $0 $0.00 $0 $6.62 $56,736 $56,736

Concrete Demolition and Disposal $1,950 $3,120 $522,459 $527,529

Concrete demolition (recent EPA Region 6 RA) 7,500 cy $0.00 $0 $0.00 $0 $38.64 $289,800 $289,800

2-cy Loader (load only, 30% expansion)(ECHOS 17 02 

0415) 9,750 cy $0.20 $1,950 $0.32 $3,120 $0.00 $0 $5,070

Concrete transportation (20 tons per load, 2 tons per 

cy)(estimate from vendor) 975 loads $0.00 $0 $0.00 $0 $172.50 $168,188 $168,188

Concrete disposal (estimate from vendor) 9,750 cy $0.00 $0 $0.00 $0 $6.61 $64,472 $64,472

$4 $6 $1,676 $1,686

Project sign (recent EPA Region 6 RA)

Support facilities (Office trailers, storage trailers, utilities, 

outdoor lighting, meteorological station)(recent EPA Region 

6 RA)

Security (24 hours per day, 7 days per week)(recent EPA 

Region 6 RA)

Install and maintain storm water control measures (recent 

EPA Region 6 RA)

Hazardous Debris Removal and Disposal

TECHNOLOGY LOCATION: MEDIA:

MDI Excavation, Solidification/Stabilization, and Off-site 

Disposal Soil

Nonhazardous Debris Removal and Disposal

Decontamination pad (recent EPA Region 6 RA)

Install temporary electrical service (recent EPA Region 6 

RA)

Plug and abandon existing monitoring wells (24 feet 

deep)(based on previous work in EPA Region 6)

Bag House Material Disposal

Demolition and Debris Removal

Water Removal and Disposal

Excavation and Off-site Disposal

Page 1 of 4
ALTERNATIVE 3

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 3 - Solidification/Stabilization and Off-site Disposal Construction 

time: 6 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

MDI Excavation, Solidification/Stabilization, and Off-site 

Disposal Soil

Solidification/stabilization (recent EPA Region 6 RA) 30 ton $0.00 $0 $0.00 $0 $14.28 $428 $428

2-cy Loader (load only, 30% expansion)(ECHOS 17 02 

0415) 20 cy $0.20 $4 $0.32 $6 $0.00 $0 $10

Transportation (estimate from vendor) 2 loads $0.00 $0 $0.00 $0 $172.50 $345 $345

Disposal (Class I) 20 cy $0.00 $0 $0.00 $0 $46.29 $903 $903

UST Removal $1,932 $3,569 $9,852 $15,353

Remove steel/fiberglass UST: 2,001 - 5,000 gallon 

capacity (ECHOS 33 10 9505) 1 ea $910 $910 $3,285 $3,285 $0.00 $0 $4,195

Excavation and stockpiling of contaminated soil (recent 

EPA Region 6 RA) 90 cy $0.00 $0 $0.00 $0 $18.08 $1,627 $1,627

2-cy Loader (load only, 43% expansion)(ECHOS 17 02 

0415) 129 cy $0.20 $26 $0.32 $41 $0.00 $0 $67

UST soil transportation (18 cy per load)(estimate from 

vendor) 8 loads $0.00 $0 $0.00 $0 $172.50 $1,380 $1,380

Soil disposal (Class 1)(estimate from vendor) 129 cy $0.00 $0 $0.00 $0 $46.29 $5,957 $5,957

Clean soil borrow, common earth (39% compaction)(M 

02315 200 4060) 125 cy 0.49 $61 0.39 $49 $7.10 $888 $998

Fill, spread dumped material, by dozer, no compaction 

(M 02315 505 0010) 125 cy 0.47 $59 $1.14 $143 $0.00 $0 $201

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 

passes (M 02315 300 5720) 125 cy 0.18 $23 $0.41 $51 $0.00 $0 $74

Compaction testing, 1 nuclear per 5000 sf per 9-inch 

compacted lift (ASTM 2922 M 01450 500 4735) 16 ea 53.36 $854 $0.00 $0 $0.00 $0 $854

LNAPL Impacted Soil Removal $82,349 $115,115 $356,477 $553,941

Steel sheeting; install, pull, and salvage; to 40 feet 

(MW-3 Area)(ECHOS 17 03 0904) 8400 sf 3.67 $30,828 $4.93 $41,412 $3.39 $28,510 $100,750

Steel sheeting; install, pull, and salvage; to 25 feet 

(MW-11 and MW-20 Areas)(ECHOS 17 03 0903) 14160 sf 3.14 $44,462 $4.21 $59,614 $2.74 $38,829 $142,905

Excavation and stockpiling of overburden soil (recent 

EPA Region 6 RA) 3,465 cy $0.00 $0 $0.00 $0 $18.08 $62,647 $62,647

Excavation and stockpiling of contaminated soil (recent 

EPA Region 6 RA) 2,100 cy $0.00 $0 $0.00 $0 $18.08 $37,968 $37,968

2-cy Loader (load only, 43% expansion)(ECHOS 17 02 

0415) 3,003 cy $0.20 $601 $0.32 $961 $0.00 $0 $1,562

Contaminated soil transportation (18 cy per 

load)(estimate from vendor) 167 loads $0.00 $0 $0.00 $0 $172.50 $28,808 $28,808

Soil disposal (Class 1)(estimate from vendor) 3,003 cy $0.00 $0 $0.00 $0 $46.29 $139,001 $139,001

Clean soil borrow, common earth (39% compaction)(M 

02315 200 4060) 2919 cy 0.49 $1,430 0.39 $1,138 $7.10 $20,715 $23,283

Fill; spread dumped material, by dozer; no compaction 

(M 02315 505 0010) 7735 cy 0.47 $3,636 $1.14 $8,818 $0.00 $0 $12,454

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 

passes (M 02315 300 5720) 7735 cy 0.18 $1,392 $0.41 $3,171 $0.00 $0 $4,564

Compaction testing, 1 nuclear per 5000 sf per 9-inch 

compacted lift (ASTM 2922 M 01450 500 4735) 0 ea 53.36 $0 $0.00 $0 $0.00 $0 $0

PCB Transformer Disposal $0 $0 $17,293 $17,293

Transportation (separate trips for fluid and 

transformer)(estimate from vendor) 2 ea $0.00 $0 $0.00 $0 $2,990 $5,980 $5,980

Incineration of PCB-contaminated oil (estimate from 

vendor) 16,395 lb $0.00 $0 $0.00 $0 $0.69 $11,313 $11,313

Excavation and Treatment $0 $0 $601,460 $601,460

13,600 cy $0.00 $0 $0.00 $0 $18.08 $245,888 $245,888

20,400 ton $0.00 $0 $0.00 $0 $14.28 $291,312 $291,312

4,500 ton $0.00 $0 $0.00 $0 $14.28 $64,260 $64,260

Backfill and Compaction $30,522 $35,651 $134,029 $200,202

18,904 cy $0.49 $9,263 $0.31 $5,860 $7.09 $134,029 $149,153

18,904 cy $0.79 $14,934 $1.26 $23,819 $0.00 $0 $38,753

18,904 cy $0.18 $3,391 $0.32 $5,971 $0.00 $0 $9,362

55 ea $53.35 $2,934 $0.00 $0 $0.00 $0 $2,934

Solidification/stabilization (recent EPA Region 6 RA)

Backfill, spread fill, from stockpile w/ front-end loader (M 

02315 505 0170)

Excavation and stockpiling of lead-contaminated soil (recent 

EPA Region 6 RA)

Compaction testing, nuclear method (ASTM D2922); 1 per 

5,000 sf per 9-inch loose lift (M 01450 500 4735)

Clean soil borrow, common earth (M 02315 200 4060)

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 passes 

(M 02315 300 5720)

Solidification/stabilization of off-property soil (recent EPA 

Region 6 RA)

Excavation and Off-site Disposal

Page 2 of 4
ALTERNATIVE 3

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 3 - Solidification/Stabilization and Off-site Disposal Construction 

time: 6 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

MDI Excavation, Solidification/Stabilization, and Off-site 

Disposal Soil

Off-site Disposal $11,632 $7,359 $1,326,321 $1,345,312

Soil Disposal (On-property Soil) $9,530 $6,029 $1,086,625 $1,102,183

19,448 cy $0.49 $9,530 $0.31 $6,029 $0.00 $0 $15,558

1,080 loads $0.00 $0 $0.00 $0 $172.50 $186,377 $186,377

19,448 cy $0.00 $0 $0.00 $0 $46.29 $900,248 $900,248

Soil Disposal (Off-property Soil) $2,102 $1,330 $239,697 $243,129

4,290 cy $0.49 $2,102 $0.31 $1,330 $0.00 $0 $3,432

238 loads $0.00 $0 $0.00 $0 $172.50 $41,113 $41,113

4,290 cy $0.00 $0 $0.00 $0 $46.29 $198,584 $198,584

Sampling and Analysis $0 $0 $135,342 $135,342

Profile Analysis for Soil Disposal

TCLP (RCRA metals)(recent EPA Region 6 RA) 50 ea $0.00 $0.00 $0.00 $0.00 $322.00 $16,100 $16,100

Total lead (recent EPA Region 6 RA) 97 ea $0.00 $0.00 $0.00 $0.00 $95.45 $9,259 $9,259

XRF Sampling (field sampling for lead)

XRF rental (recent EPA Region 6 RA) 6 month $0.00 $0.00 $0.00 $0.00 $4,418.30 $26,510 $26,510

1 ea $0.00 $0.00 $0.00 $0.00 $1,640 $1,640 $1,640

Air Monitoring

6 month $0.00 $0.00 $0.00 $0.00 $5,359.00 $32,154 $32,154

720 ea $0.00 $0.00 $0.00 $0.00 $69.00 $49,680 $49,680

Mobilization and Demobilization $291,638

10% $291,638

System Contingency $455,332

10% of Total Construction Activities $455,332

Professional/Technical Services $609,522

8% $256,641

5% $160,401

6% $192,481

OPERATION AND MAINTENANCE (O&M) ANNUAL O&M COST $0

Monitoring, Sampling, Testing, and Analysis 1 lump sum $0 $0 $0 $0

Post Remediation Site Monitoring

Geoprobe 0 lump sum $10,000 $0 $5,000 $0 $0 $0 $0

Field Work Labor 0 lump sum $15,000 $0 $0 $0 $0 $0 $0

0 lump sum $15,000 $0 $0 $0 $0 $0 $0

System O&M $0 $0 $0 $0

LIFETIME O&M (Net Present Value) $0

Years of Operation 0

Discount Factor 7%

TOTAL COST (CAPITAL COST + LIFETIME O&M)

Assumptions: 

Loading common earth, front-end loader, wheel mtd, 1.5 cy 

(M 02315 200 4060)

Treated soil transportation (BFI Landfill, 18 cy per load)

Soil disposal (Class I)

$5,425,699

of Total Costs of Site Work and Sampling & Analysis

Remedial Design (Percentage of capital costs excluding offsite disposal)(Exhibit 5-8 from EPA 2000)

Data Analysis/Analytical (TPH, BTEX)

Treated soil transportation (BFI Landfill, 18 cy per load)

Loading common earth, front-end loader, wheel mtd, 1.5 cy 

(M 02315 200 4060)

Soil disposal (Class I)

Excavation Confirmation Sampling (1 per 2,500 sf plus 10% 

QA/QC)

XRF supplies (cups, mylar, oven, bowls)(recent EPA 

Region 6 RA)

Equipment rental (low-flow air samplers, calibrator, dust 

monitor, calibration gas, and sound meter)(recent EPA 

Region 6 RA)

Air sample analysis (lead and total particulates; 4 samples 

per day)(recent EPA Region 6 RA)

Project Management (Percentage of capital costs excluding 

off-site disposal)(Exhibit 5-8 from EPA 2000)

Construction Management (Percentage of capital costs 

excluding off-site disposal)(Exhibit 5-8 from EPA 2000)

Excavation and Off-site Disposal

Page 3 of 4
ALTERNATIVE 3

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 3 - Solidification/Stabilization and Off-site Disposal Construction 

time: 6 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

MDI Excavation, Solidification/Stabilization, and Off-site 

Disposal Soil

1 2002 RS Means values increased to account for inflation 2.25%

2 Working condition is Safety Level: D (Labor productivity: 75% ; Equipment productivity: 95% )

3 Soil profile sampling will be conducted at the frequency of: 1 sample for every: 500 cy of contaminated soil plus 10% QA/QC

4 Cost index for zip code 770 88% (not applicable for costs derived from vendor quotes).

5 Costs are loaded with an overhead and profit factor: 15%

6 No net present value calculation is presented for alternative with an estimated remediation timeframe that is less than 1 year.

7 No dewatering costs included.

8 Treated soil and disposal volumes include 3,000 cy from off-property excavations currently stockpiled on property.

9 Debris volume only includes removal of debris overlying areas to be excavated.

10 Concrete volume only includes demolition of concrete overlying areas to be excavated.

Estimated Volume of Excavation:

Total

Estimated total volume of contaminated soil : 13,600 0 0 13,600 cf

Average soil swelling factor: 43%

Average soil density: 1.5 tons/cy

In-place Loose

13,600 19,448 cy 20,400 tons

39%

18,904

Notes:

ACM Asbestos-containing material

ASTM American Society of Testing and Materials

BTEX Benzene, toluene, ethylbenzene, and xylenes

cf Cubic foot

cy Cubic yard

ECHOS Environmental Cost Handling Options and Solutions (RS Means 2002a)

EPA U.S. Environmental Protection Agency

gal Gallon

lb Pound

LNAPL Light nonaqueous-phase liquid

MW Monitoring well

PCB Polychlorinated biphenyl

QA/QC Quality assurance/quality control

RCRA Resource Conservation and Recovery Act

sf Square feet

TCLP Toxicity Characteristic Leaching Procedure

TPH Total petroleum hydrocarbons

UST Underground storage tank

WS Waste sample

XRF X-ray fluoresence

References: 

1) RS Means. 2002b. Heavy Construction Cost Data. 16th Annual Edition.

2) RS Means. 2002a. Environmental Remediation Cost Data, Unit Price. 8th Annual Edition

3) EPA. 2000. A Guide to Developing and Documenting Cost Estimates During the Feasibility Study.

Estimated total volume of replacement soil

Replacement soil compaction factor

Estimated total volume of excavated soil :

Excavation and Off-site Disposal

Page 4 of 4
ALTERNATIVE 3

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 3 - Solidification/Stabilization and Off-site Disposal and Monitored Natural Attenuation 

Construction 

TIme: 1 months

Operation 

TIme:

30.0

years

Post 

Remediation 

Monitoring

30.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

REMEDIAL ACTION TOTAL CAPITAL COST $118,161

Initial Site Characterization $75,502

6 ea $0.00 $0 $0.00 $0 $3,450 $20,700 $20,700

48 well $286 $13,733 $142.39 $6,835 $15.08 $724 $21,292

48 ea

48 sample $0 $0 $0 $0 $233.80 $11,222 $11,222

48 sample $0 $0 $0 $0 $51.73 $2,483 $2,483

48 sample $0 $0 $0 $0 $71.18 $3,416 $3,416

Ferrous iron (ECHOS 33 02 1678) 48 sample $0 $0 $0 $0 $96.42 $4,628 $4,628

Dissolved manganese (ECHOS 33 02 1644) 48 sample $0 $0 $0 $0 $71.18 $3,416 $3,416

Nitrate (ECHOS 33 02 1661) 48 sample $0 $0 $0 $0 $36.70 $1,762 $1,762

Sulfate (ECHOS 33 02 1667) 48 sample $0 $0 $0 $0 $19.40 $931 $931

Dissolved oxygen (ECHOS 33 02 1663) 48 sample $0 $0 $0 $0 $28.76 $1,381 $1,381

1 lump sum $4,271 $4,271 $0 $0 $0 $0 $4,271

Contingency $7,550

10% of total construction activities $7,550

Professional/Technical Services $35,109

20% $15,100

10% $7,550

15% $12,458

MNA Monitoring (Annually) $24,069

Iron (ECHOS 33 02 1644)

Sample wells (6 wells sampled quarterly for 2 

years)(RS Means 33 02 0401, 33 02 0402; Total 

Safety)

Lab analysis 

Installation, completion, and development of 

additional monitor wells to 18 feet bgs (Recent 

RAC work in Region 6)

Polynuclear aromatic hydrocarbons 

(3510C)(ECHOS 33 02 2134)

Lead (ECHOS 33 02 2143)

MEDIA:

MDI

Monitored Natural Attenuation (MNA)

TECHNOLOGY LOCATION:

Deep Soil/Ground 

Water Contamination

Ground water fate and transport modeling 

(ECHOS 33 02 0419)

Remedial Design (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Project Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Construction Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Monitored Natural Attenuation

Page 1 of 2
ALTERNATIVE 3

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 3 - Solidification/Stabilization and Off-site Disposal and Monitored Natural Attenuation 

Construction 

TIme: 1 months

Operation 

TIme:

30.0

years

Post 

Remediation 

Monitoring

30.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

MEDIA:

MDI

Monitored Natural Attenuation (MNA)

TECHNOLOGY LOCATION:

Deep Soil/Ground 

Water Contamination

Monitoring, Sampling, Testing, and Analysis 12 months $3,433 $1,709 $7,330 $12,472

8 well $286 $2,289 $142.39 $1,139 $15.08 $121 $3,549

4 well $286 $1,144 $142.39 $570 $15.08 $60 $1,774

12 ea

12 sample $0 $0 $0 $0 $228.65 $2,744 $2,744

12 sample $0 $0 $0 $0 $50.59 $607 $607

12 sample $0 $0 $0 $0 $69.61 $835 $835

Ferrous iron (ECHOS 33 02 1678) 12 sample $0 $0 $0 $0 $94.30 $1,132 $1,132

Dissolved manganese (ECHOS 33 02 1644) 12 sample $0 $0 $0 $0 $69.61 $835 $835

Nitrate (ECHOS 33 02 1661) 12 sample $0 $0 $0 $0 $35.89 $431 $431

Sulfate (ECHOS 33 02 1667) 12 sample $0 $0 $0 $0 $18.98 $228 $228

Dissolved oxygen (ECHOS 33 02 1663) 12 sample $0 $0 $0 $0 $28.13 $338 $338

Contingency $1,247

10% $1,247

Professional/Technical Services 12 months $2,800 $0 $0 $10,350

10% $7,550

0.2 per year 14000 $2,800 $0.00 $0 $0 $0 $2,800

LIFETIME MONITORING COST (Present Value) $298,679

Years of Operation 30

Discount Factor 7.0%

TOTAL COST (CAPITAL COST + LIFETIME OPERATING COST)

Assumptions: 

1 2002 RS Means values increased to account for inflation 2.25%

2 Working condition is Safety Level: D (Labor productivity: 75% ; Equipment productivity: 95% )

3 Cost index for zip code 770 88% (not applicable for costs derived from vendor quotes).

4 Costs are loaded with an overhead and profit factor: 15%

5 No net present value calculation is presented for alternative with an estimated remediation timeframe that is less than 1 year.

Notes:

bgs Below ground surface

ECHOS Environmental Cost Handling Options and Solutions (RS Means 2002a)

EPA U.S. Environmental Protection Agency

RAC Response Action Contract

References: 

1) RS Means. 2002b. Heavy Construction Cost Data. 16th Annual Edition.

2) RS Means. 2002a. Environmental Remediation Cost Data, Unit Price. 8th Annual Edition

3) EPA. 2000. A Guide to Developing and Documenting Cost Estimates During the Feasibility Study.

$416,840

of Total Monitoring, Sampling, Testing, and 

Analysis

Project Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Lead (ECHOS 33 02 2143)

Iron (ECHOS 33 02 1644)

5 year review (Previous Region 6 work;1/5 of cost 

included annually)

Sample wells (4 wells sampled annually)(RS 

Means 33 02 0401, 33 02 0402; Total Safety)

Polynuclear aromatic hydrocarbons 

(3510C)(ECHOS 33 02 2134)

Sample wells (2 wells sampled quarterly)(RS 

Means 33 02 0401, 33 02 0402; Total Safety)

Lab analysis 

Monitored Natural Attenuation

Page 2 of 2
APPENDIX B-2 

ALTERNATIVE 3–SOLIDIFICATION/STABILIZATION AND OFF-SITE DISPOSAL; 

GROUND WATER VIA MNA WITH ICS 

(Seven Pages) 
Target Media Capital Cost ($)

Lifetime O&M 

Cost ($)

Post-remediation 

Monitoring Cost 

($) Total Cost ($)

Remediati

Frame (m

Soil $5,425,699 $0 $0 $5,425,699 6 

Deep Soil/Ground Water Contamination $118,161 $0 $298,679 $416,840 1 

$5,543,860 $0 $298,679 $5,842,539 7 

Note:

O&M Operation and maintenance

Component

Excavation and Off-site Disposal with MNAExcavation, Solidification/Stabilization, and Off-site DisposalMonitored Natural Attenuation (MNA)

ALTERNATIVE 3

EXCAVATION AND OFF-SITE DISPOSAL WITH MNA

TOTAL REMEDIAL COST SUMMARY

MDI SUPERFUND SITE OPERABLE UNIT 1

Page 1
ALTERNATIVE 3

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 3 - Solidification/Stabilization and Off-site Disposal Construction 

time: 6 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

REMEDIAL ACTION (RA) TOTAL CAPITAL COST $5,425,699

Construction Activities $4,553,325

Site Work $173,685 $202,173 $2,405,175 $2,781,033

Temporary Facilities $0 $0 $258,645 $258,645

1 lump sum $0.00 $0 $0.00 $0 $11,465 $11,465 $11,465

1 lump sum $0.00 $0 $0.00 $0 $2,399 $2,399 $2,399

1 lump sum $0.00 $0 $0.00 $0 $8,011 $8,011 $8,011

6 per month $0.00 $0 $0.00 $0 $21,418 $128,509 $128,509

1 lump sum $0.00 $0 $0.00 $0 $32,553 $32,553 $32,553

6 per month $0.00 $0 $0.00 $0 $10,618 $63,708 $63,708

6 ea $0.00 $0 $0.00 $0 $2,000.00 $12,000 $12,000

$173,685 $202,173 $2,146,531 $2,522,389

$6 $10 $8,039 $8,054

2-cy Loader (ECHOS 17 02 0415) 30 cy $0.20 $6 $0.32 $10 $0.00 $0 $16

Hazardous debris disposal (estimate from vendor) 30 cy $0.00 $0 $0.00 $0 $108.10 $3,243 $3,243

Hazardous debris transportation (20 cy per 

load)(estimate from vendor) 2 loads $0.00 $0 $0.00 $0 $2,398 $4,796 $4,796

$44,528 $34,840 $99,093 $178,460

2-cy Loader (nonhazardous debris load only)(ECHOS 

17 02 0415) 6,500 cy $0.20 $1,300 $0.32 $2,080 $0.00 $0 $3,380

Nonhazardous debris disposal (estimate from vendor) 6,500 cy $0.00 $0 $0.00 $0 $6.62 $43,030 $43,030

Nonhazardous debris transportation (20 cy per 

load)(estimate from vendor) 325 loads $0.00 $0 $0.00 $0 $172.50 $56,063 $56,063

Clearing and grubbing; medium brush with average 

grub and some trees, clearing (ECHOS 17 01 0106) 36 acres $275 $9,885 $417 $15,012 $0.00 $0 $24,897

Machine-load spoils; 2-mile haul to dump (ECHOS 

02110 2000) 36 acres $926 $33,343 $493 $17,748 $0.00 $0 $51,091

ACM Removal and Disposal $0 $0 $249,165 $249,165

ACM oversight contractor (estimate from vendor) 1 ea $0.00 $0 $0.00 $0 $19,165 $19,165 $19,165

ACM removal and disposal (estimate from contractor) 1 ea $0.00 $0 $0.00 $0 $230,000 $230,000 $230,000

$0 $0 $7,970 $7,970

Hazardous water removal (WS-1)(estimate from vendor) 3 hours $0.00 $0 $0.00 $0 $80.50 $242 $242

Hazardous water disposal (WS-1)(estimate from 

vendor) 400 gal $0.00 $0 $0.00 $0 $0.86 $345 $345

Petroleum water removal (WS-6 and UST)(estimate 

from vendor) 6 hours $0.00 $0 $0.00 $0 $80.50 $483 $483

Petroleum water disposal (WS-6 and UST)(estimate 

from vendor) 10,000 gal $0.00 $0 $0.00 $0 $0.35 $3,450 $3,450

Other water removal (WS-2, 3, 5, 7, and 8)(estimate 

from vendor) 12 hours $0.00 $0 $0.00 $0 $80.50 $966 $966

Other water disposal (WS-2, 3, 5, 7, and 8)(estimate 

from vendor) 12,000 gal $0.00 $0 $0.00 $0 $0.21 $2,484 $2,484

Building Demolition and Disposal $12,394 $9,863 $139,018 $161,275

Multi-level, masonry, nonexplosive building demolition 

(ECHOS 17 02 0103) 178,000 cf $0.06 $10,680 $0.04 $7,120 $0.00 $0 $17,800

2-cy Loader (load only, 30% expansion)(ECHOS 17 02 

0415) 8,570 cy $0.20 $1,714 $0.32 $2,743 $0.00 $0 $4,457

Building debris transportation (18 cy per load)(estimate 

from vendor) 477 loads $0.00 $0 $0.00 $0 $172.50 $82,283 $82,283

Building debris disposal (nonhazardous 

debris)(estimate from vendor) 8,570 cy $0.00 $0 $0.00 $0 $6.62 $56,736 $56,736

Concrete Demolition and Disposal $1,950 $3,120 $522,459 $527,529

Concrete demolition (recent EPA Region 6 RA) 7,500 cy $0.00 $0 $0.00 $0 $38.64 $289,800 $289,800

2-cy Loader (load only, 30% expansion)(ECHOS 17 02 

0415) 9,750 cy $0.20 $1,950 $0.32 $3,120 $0.00 $0 $5,070

Concrete transportation (20 tons per load, 2 tons per 

cy)(estimate from vendor) 975 loads $0.00 $0 $0.00 $0 $172.50 $168,188 $168,188

Concrete disposal (estimate from vendor) 9,750 cy $0.00 $0 $0.00 $0 $6.61 $64,472 $64,472

$4 $6 $1,676 $1,686

Project sign (recent EPA Region 6 RA)

Support facilities (Office trailers, storage trailers, utilities, 

outdoor lighting, meteorological station)(recent EPA Region 

6 RA)

Security (24 hours per day, 7 days per week)(recent EPA 

Region 6 RA)

Install and maintain storm water control measures (recent 

EPA Region 6 RA)

Hazardous Debris Removal and Disposal

TECHNOLOGY LOCATION: MEDIA:

MDI Excavation, Solidification/Stabilization, and Off-site 

Disposal Soil

Nonhazardous Debris Removal and Disposal

Decontamination pad (recent EPA Region 6 RA)

Install temporary electrical service (recent EPA Region 6 

RA)

Plug and abandon existing monitoring wells (24 feet 

deep)(based on previous work in EPA Region 6)

Bag House Material Disposal

Demolition and Debris Removal

Water Removal and Disposal

Excavation and Off-site Disposal

Page 1 of 4
ALTERNATIVE 3

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 3 - Solidification/Stabilization and Off-site Disposal Construction 

time: 6 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

MDI Excavation, Solidification/Stabilization, and Off-site 

Disposal Soil

Solidification/stabilization (recent EPA Region 6 RA) 30 ton $0.00 $0 $0.00 $0 $14.28 $428 $428

2-cy Loader (load only, 30% expansion)(ECHOS 17 02 

0415) 20 cy $0.20 $4 $0.32 $6 $0.00 $0 $10

Transportation (estimate from vendor) 2 loads $0.00 $0 $0.00 $0 $172.50 $345 $345

Disposal (Class I) 20 cy $0.00 $0 $0.00 $0 $46.29 $903 $903

UST Removal $1,932 $3,569 $9,852 $15,353

Remove steel/fiberglass UST: 2,001 - 5,000 gallon 

capacity (ECHOS 33 10 9505) 1 ea $910 $910 $3,285 $3,285 $0.00 $0 $4,195

Excavation and stockpiling of contaminated soil (recent 

EPA Region 6 RA) 90 cy $0.00 $0 $0.00 $0 $18.08 $1,627 $1,627

2-cy Loader (load only, 43% expansion)(ECHOS 17 02 

0415) 129 cy $0.20 $26 $0.32 $41 $0.00 $0 $67

UST soil transportation (18 cy per load)(estimate from 

vendor) 8 loads $0.00 $0 $0.00 $0 $172.50 $1,380 $1,380

Soil disposal (Class 1)(estimate from vendor) 129 cy $0.00 $0 $0.00 $0 $46.29 $5,957 $5,957

Clean soil borrow, common earth (39% compaction)(M 

02315 200 4060) 125 cy 0.49 $61 0.39 $49 $7.10 $888 $998

Fill, spread dumped material, by dozer, no compaction 

(M 02315 505 0010) 125 cy 0.47 $59 $1.14 $143 $0.00 $0 $201

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 

passes (M 02315 300 5720) 125 cy 0.18 $23 $0.41 $51 $0.00 $0 $74

Compaction testing, 1 nuclear per 5000 sf per 9-inch 

compacted lift (ASTM 2922 M 01450 500 4735) 16 ea 53.36 $854 $0.00 $0 $0.00 $0 $854

LNAPL Impacted Soil Removal $82,349 $115,115 $356,477 $553,941

Steel sheeting; install, pull, and salvage; to 40 feet 

(MW-3 Area)(ECHOS 17 03 0904) 8400 sf 3.67 $30,828 $4.93 $41,412 $3.39 $28,510 $100,750

Steel sheeting; install, pull, and salvage; to 25 feet 

(MW-11 and MW-20 Areas)(ECHOS 17 03 0903) 14160 sf 3.14 $44,462 $4.21 $59,614 $2.74 $38,829 $142,905

Excavation and stockpiling of overburden soil (recent 

EPA Region 6 RA) 3,465 cy $0.00 $0 $0.00 $0 $18.08 $62,647 $62,647

Excavation and stockpiling of contaminated soil (recent 

EPA Region 6 RA) 2,100 cy $0.00 $0 $0.00 $0 $18.08 $37,968 $37,968

2-cy Loader (load only, 43% expansion)(ECHOS 17 02 

0415) 3,003 cy $0.20 $601 $0.32 $961 $0.00 $0 $1,562

Contaminated soil transportation (18 cy per 

load)(estimate from vendor) 167 loads $0.00 $0 $0.00 $0 $172.50 $28,808 $28,808

Soil disposal (Class 1)(estimate from vendor) 3,003 cy $0.00 $0 $0.00 $0 $46.29 $139,001 $139,001

Clean soil borrow, common earth (39% compaction)(M 

02315 200 4060) 2919 cy 0.49 $1,430 0.39 $1,138 $7.10 $20,715 $23,283

Fill; spread dumped material, by dozer; no compaction 

(M 02315 505 0010) 7735 cy 0.47 $3,636 $1.14 $8,818 $0.00 $0 $12,454

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 

passes (M 02315 300 5720) 7735 cy 0.18 $1,392 $0.41 $3,171 $0.00 $0 $4,564

Compaction testing, 1 nuclear per 5000 sf per 9-inch 

compacted lift (ASTM 2922 M 01450 500 4735) 0 ea 53.36 $0 $0.00 $0 $0.00 $0 $0

PCB Transformer Disposal $0 $0 $17,293 $17,293

Transportation (separate trips for fluid and 

transformer)(estimate from vendor) 2 ea $0.00 $0 $0.00 $0 $2,990 $5,980 $5,980

Incineration of PCB-contaminated oil (estimate from 

vendor) 16,395 lb $0.00 $0 $0.00 $0 $0.69 $11,313 $11,313

Excavation and Treatment $0 $0 $601,460 $601,460

13,600 cy $0.00 $0 $0.00 $0 $18.08 $245,888 $245,888

20,400 ton $0.00 $0 $0.00 $0 $14.28 $291,312 $291,312

4,500 ton $0.00 $0 $0.00 $0 $14.28 $64,260 $64,260

Backfill and Compaction $30,522 $35,651 $134,029 $200,202

18,904 cy $0.49 $9,263 $0.31 $5,860 $7.09 $134,029 $149,153

18,904 cy $0.79 $14,934 $1.26 $23,819 $0.00 $0 $38,753

18,904 cy $0.18 $3,391 $0.32 $5,971 $0.00 $0 $9,362

55 ea $53.35 $2,934 $0.00 $0 $0.00 $0 $2,934

Solidification/stabilization (recent EPA Region 6 RA)

Backfill, spread fill, from stockpile w/ front-end loader (M 

02315 505 0170)

Excavation and stockpiling of lead-contaminated soil (recent 

EPA Region 6 RA)

Compaction testing, nuclear method (ASTM D2922); 1 per 

5,000 sf per 9-inch loose lift (M 01450 500 4735)

Clean soil borrow, common earth (M 02315 200 4060)

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 passes 

(M 02315 300 5720)

Solidification/stabilization of off-property soil (recent EPA 

Region 6 RA)

Excavation and Off-site Disposal

Page 2 of 4
ALTERNATIVE 3

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 3 - Solidification/Stabilization and Off-site Disposal Construction 

time: 6 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

MDI Excavation, Solidification/Stabilization, and Off-site 

Disposal Soil

Off-site Disposal $11,632 $7,359 $1,326,321 $1,345,312

Soil Disposal (On-property Soil) $9,530 $6,029 $1,086,625 $1,102,183

19,448 cy $0.49 $9,530 $0.31 $6,029 $0.00 $0 $15,558

1,080 loads $0.00 $0 $0.00 $0 $172.50 $186,377 $186,377

19,448 cy $0.00 $0 $0.00 $0 $46.29 $900,248 $900,248

Soil Disposal (Off-property Soil) $2,102 $1,330 $239,697 $243,129

4,290 cy $0.49 $2,102 $0.31 $1,330 $0.00 $0 $3,432

238 loads $0.00 $0 $0.00 $0 $172.50 $41,113 $41,113

4,290 cy $0.00 $0 $0.00 $0 $46.29 $198,584 $198,584

Sampling and Analysis $0 $0 $135,342 $135,342

Profile Analysis for Soil Disposal

TCLP (RCRA metals)(recent EPA Region 6 RA) 50 ea $0.00 $0.00 $0.00 $0.00 $322.00 $16,100 $16,100

Total lead (recent EPA Region 6 RA) 97 ea $0.00 $0.00 $0.00 $0.00 $95.45 $9,259 $9,259

XRF Sampling (field sampling for lead)

XRF rental (recent EPA Region 6 RA) 6 month $0.00 $0.00 $0.00 $0.00 $4,418.30 $26,510 $26,510

1 ea $0.00 $0.00 $0.00 $0.00 $1,640 $1,640 $1,640

Air Monitoring

6 month $0.00 $0.00 $0.00 $0.00 $5,359.00 $32,154 $32,154

720 ea $0.00 $0.00 $0.00 $0.00 $69.00 $49,680 $49,680

Mobilization and Demobilization $291,638

10% $291,638

System Contingency $455,332

10% of Total Construction Activities $455,332

Professional/Technical Services $609,522

8% $256,641

5% $160,401

6% $192,481

OPERATION AND MAINTENANCE (O&M) ANNUAL O&M COST $0

Monitoring, Sampling, Testing, and Analysis 1 lump sum $0 $0 $0 $0

Post Remediation Site Monitoring

Geoprobe 0 lump sum $10,000 $0 $5,000 $0 $0 $0 $0

Field Work Labor 0 lump sum $15,000 $0 $0 $0 $0 $0 $0

0 lump sum $15,000 $0 $0 $0 $0 $0 $0

System O&M $0 $0 $0 $0

LIFETIME O&M (Net Present Value) $0

Years of Operation 0

Discount Factor 7%

TOTAL COST (CAPITAL COST + LIFETIME O&M)

Assumptions: 

Loading common earth, front-end loader, wheel mtd, 1.5 cy 

(M 02315 200 4060)

Treated soil transportation (BFI Landfill, 18 cy per load)

Soil disposal (Class I)

$5,425,699

of Total Costs of Site Work and Sampling & Analysis

Remedial Design (Percentage of capital costs excluding offsite disposal)(Exhibit 5-8 from EPA 2000)

Data Analysis/Analytical (TPH, BTEX)

Treated soil transportation (BFI Landfill, 18 cy per load)

Loading common earth, front-end loader, wheel mtd, 1.5 cy 

(M 02315 200 4060)

Soil disposal (Class I)

Excavation Confirmation Sampling (1 per 2,500 sf plus 10% 

QA/QC)

XRF supplies (cups, mylar, oven, bowls)(recent EPA 

Region 6 RA)

Equipment rental (low-flow air samplers, calibrator, dust 

monitor, calibration gas, and sound meter)(recent EPA 

Region 6 RA)

Air sample analysis (lead and total particulates; 4 samples 

per day)(recent EPA Region 6 RA)

Project Management (Percentage of capital costs excluding 

off-site disposal)(Exhibit 5-8 from EPA 2000)

Construction Management (Percentage of capital costs 

excluding off-site disposal)(Exhibit 5-8 from EPA 2000)

Excavation and Off-site Disposal

Page 3 of 4
ALTERNATIVE 3

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 3 - Solidification/Stabilization and Off-site Disposal Construction 

time: 6 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

MDI Excavation, Solidification/Stabilization, and Off-site 

Disposal Soil

1 2002 RS Means values increased to account for inflation 2.25%

2 Working condition is Safety Level: D (Labor productivity: 75% ; Equipment productivity: 95% )

3 Soil profile sampling will be conducted at the frequency of: 1 sample for every: 500 cy of contaminated soil plus 10% QA/QC

4 Cost index for zip code 770 88% (not applicable for costs derived from vendor quotes).

5 Costs are loaded with an overhead and profit factor: 15%

6 No net present value calculation is presented for alternative with an estimated remediation timeframe that is less than 1 year.

7 No dewatering costs included.

8 Treated soil and disposal volumes include 3,000 cy from off-property excavations currently stockpiled on property.

9 Debris volume only includes removal of debris overlying areas to be excavated.

10 Concrete volume only includes demolition of concrete overlying areas to be excavated.

Estimated Volume of Excavation:

Total

Estimated total volume of contaminated soil : 13,600 0 0 13,600 cf

Average soil swelling factor: 43%

Average soil density: 1.5 tons/cy

In-place Loose

13,600 19,448 cy 20,400 tons

39%

18,904

Notes:

ACM Asbestos-containing material

ASTM American Society of Testing and Materials

BTEX Benzene, toluene, ethylbenzene, and xylenes

cf Cubic foot

cy Cubic yard

ECHOS Environmental Cost Handling Options and Solutions (RS Means 2002a)

EPA U.S. Environmental Protection Agency

gal Gallon

lb Pound

LNAPL Light nonaqueous-phase liquid

MW Monitoring well

PCB Polychlorinated biphenyl

QA/QC Quality assurance/quality control

RCRA Resource Conservation and Recovery Act

sf Square feet

TCLP Toxicity Characteristic Leaching Procedure

TPH Total petroleum hydrocarbons

UST Underground storage tank

WS Waste sample

XRF X-ray fluoresence

References: 

1) RS Means. 2002b. Heavy Construction Cost Data. 16th Annual Edition.

2) RS Means. 2002a. Environmental Remediation Cost Data, Unit Price. 8th Annual Edition

3) EPA. 2000. A Guide to Developing and Documenting Cost Estimates During the Feasibility Study.

Estimated total volume of replacement soil

Replacement soil compaction factor

Estimated total volume of excavated soil :

Excavation and Off-site Disposal

Page 4 of 4
ALTERNATIVE 3

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 3 - Solidification/Stabilization and Off-site Disposal and Monitored Natural Attenuation 

Construction 

TIme: 1 months

Operation 

TIme:

30.0

years

Post 

Remediation 

Monitoring

30.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

REMEDIAL ACTION TOTAL CAPITAL COST $118,161

Initial Site Characterization $75,502

6 ea $0.00 $0 $0.00 $0 $3,450 $20,700 $20,700

48 well $286 $13,733 $142.39 $6,835 $15.08 $724 $21,292

48 ea

48 sample $0 $0 $0 $0 $233.80 $11,222 $11,222

48 sample $0 $0 $0 $0 $51.73 $2,483 $2,483

48 sample $0 $0 $0 $0 $71.18 $3,416 $3,416

Ferrous iron (ECHOS 33 02 1678) 48 sample $0 $0 $0 $0 $96.42 $4,628 $4,628

Dissolved manganese (ECHOS 33 02 1644) 48 sample $0 $0 $0 $0 $71.18 $3,416 $3,416

Nitrate (ECHOS 33 02 1661) 48 sample $0 $0 $0 $0 $36.70 $1,762 $1,762

Sulfate (ECHOS 33 02 1667) 48 sample $0 $0 $0 $0 $19.40 $931 $931

Dissolved oxygen (ECHOS 33 02 1663) 48 sample $0 $0 $0 $0 $28.76 $1,381 $1,381

1 lump sum $4,271 $4,271 $0 $0 $0 $0 $4,271

Contingency $7,550

10% of total construction activities $7,550

Professional/Technical Services $35,109

20% $15,100

10% $7,550

15% $12,458

MNA Monitoring (Annually) $24,069

Iron (ECHOS 33 02 1644)

Sample wells (6 wells sampled quarterly for 2 

years)(RS Means 33 02 0401, 33 02 0402; Total 

Safety)

Lab analysis 

Installation, completion, and development of 

additional monitor wells to 18 feet bgs (Recent 

RAC work in Region 6)

Polynuclear aromatic hydrocarbons 

(3510C)(ECHOS 33 02 2134)

Lead (ECHOS 33 02 2143)

MEDIA:

MDI

Monitored Natural Attenuation (MNA)

TECHNOLOGY LOCATION:

Deep Soil/Ground 

Water Contamination

Ground water fate and transport modeling 

(ECHOS 33 02 0419)

Remedial Design (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Project Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Construction Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Monitored Natural Attenuation

Page 1 of 2
ALTERNATIVE 3

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 3 - Solidification/Stabilization and Off-site Disposal and Monitored Natural Attenuation 

Construction 

TIme: 1 months

Operation 

TIme:

30.0

years

Post 

Remediation 

Monitoring

30.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

MEDIA:

MDI

Monitored Natural Attenuation (MNA)

TECHNOLOGY LOCATION:

Deep Soil/Ground 

Water Contamination

Monitoring, Sampling, Testing, and Analysis 12 months $3,433 $1,709 $7,330 $12,472

8 well $286 $2,289 $142.39 $1,139 $15.08 $121 $3,549

4 well $286 $1,144 $142.39 $570 $15.08 $60 $1,774

12 ea

12 sample $0 $0 $0 $0 $228.65 $2,744 $2,744

12 sample $0 $0 $0 $0 $50.59 $607 $607

12 sample $0 $0 $0 $0 $69.61 $835 $835

Ferrous iron (ECHOS 33 02 1678) 12 sample $0 $0 $0 $0 $94.30 $1,132 $1,132

Dissolved manganese (ECHOS 33 02 1644) 12 sample $0 $0 $0 $0 $69.61 $835 $835

Nitrate (ECHOS 33 02 1661) 12 sample $0 $0 $0 $0 $35.89 $431 $431

Sulfate (ECHOS 33 02 1667) 12 sample $0 $0 $0 $0 $18.98 $228 $228

Dissolved oxygen (ECHOS 33 02 1663) 12 sample $0 $0 $0 $0 $28.13 $338 $338

Contingency $1,247

10% $1,247

Professional/Technical Services 12 months $2,800 $0 $0 $10,350

10% $7,550

0.2 per year 14000 $2,800 $0.00 $0 $0 $0 $2,800

LIFETIME MONITORING COST (Present Value) $298,679

Years of Operation 30

Discount Factor 7.0%

TOTAL COST (CAPITAL COST + LIFETIME OPERATING COST)

Assumptions: 

1 2002 RS Means values increased to account for inflation 2.25%

2 Working condition is Safety Level: D (Labor productivity: 75% ; Equipment productivity: 95% )

3 Cost index for zip code 770 88% (not applicable for costs derived from vendor quotes).

4 Costs are loaded with an overhead and profit factor: 15%

5 No net present value calculation is presented for alternative with an estimated remediation timeframe that is less than 1 year.

Notes:

bgs Below ground surface

ECHOS Environmental Cost Handling Options and Solutions (RS Means 2002a)

EPA U.S. Environmental Protection Agency

RAC Response Action Contract

References: 

1) RS Means. 2002b. Heavy Construction Cost Data. 16th Annual Edition.

2) RS Means. 2002a. Environmental Remediation Cost Data, Unit Price. 8th Annual Edition

3) EPA. 2000. A Guide to Developing and Documenting Cost Estimates During the Feasibility Study.

$416,840

of Total Monitoring, Sampling, Testing, and 

Analysis

Project Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Lead (ECHOS 33 02 2143)

Iron (ECHOS 33 02 1644)

5 year review (Previous Region 6 work;1/5 of cost 

included annually)

Sample wells (4 wells sampled annually)(RS 

Means 33 02 0401, 33 02 0402; Total Safety)

Polynuclear aromatic hydrocarbons 

(3510C)(ECHOS 33 02 2134)

Sample wells (2 wells sampled quarterly)(RS 

Means 33 02 0401, 33 02 0402; Total Safety)

Lab analysis 

Monitored Natural Attenuation

Page 2 of 2
APPENDIX B-3 

ALTERNATIVE 4–CONTAINMENT VIA CAPPING WITH ICS 

(Seven Pages) 
Target Media Capital Cost ($)

Lifetime O&M 

Cost ($)

Post-remediation 

Monitoring Cost 

($) Total Cost ($)

Rem

Fra

Soil $3,825,922 $77,397 $0 $3,903,319 

Deep Soil/Ground Water Contamination $118,161 $0 $263,933 $382,094 

$3,944,083 $77,397 $263,933 $4,285,413 

Note:

O&M Operation and maintenance

Component

Excavation and Off-site Disposal with MNAExcavation, Consolidation, and CappingMonitored Natural Attenuation (MNA)

ALTERNATIVE 4

CONTAINMENT AND INSTITUTIONAL CONTROLS

TOTAL REMEDIAL COST SUMMARY

MDI SUPERFUND SITE OPERABLE UNIT 1

Page 1
ALTERNATIVE 4

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 4 - Containment and Institutional Controls and Monitored Natural Attenuation

Construction 

time: 6 months

Operation 

time: 30.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material Opinion

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

REMEDIAL ACTION (RA) TOTAL CAPITAL COST $3,825,922

Construction Activities $2,965,831

Site Work $214,689 $219,867 $2,153,252 $2,587,808

Temporary Facilities $0 $0 $246,645 $258,645

1 lump sum $0.00 $0 $0.00 $0 $11,465 $11,465 $11,465

1 lump sum $0.00 $0 $0.00 $0 $2,399 $2,399 $2,399

1 lump sum $0.00 $0 $0.00 $0 $8,011 $8,011 $8,011

6 per month $0.00 $0 $0.00 $0 $21,418 $128,509 $128,509

1 lump sum $0.00 $0 $0.00 $0 $32,553 $32,553 $32,553

6 per month $0.00 $0 $0.00 $0 $10,618 $63,708 $63,708

6 ea $0.00 $0 $0.00 $0 $2,000.00 $12,000 $12,000

$143,163 $166,522 $1,411,041 $1,720,727

$6 $10 $8,039 $8,054

2-cy Loader (ECHOS 17 02 0415) 30 cy $0.20 $6 $0.32 $10 $0.00 $0 $16

Hazardous debris disposal (estimate from vendor) 30 cy $0.00 $0 $0.00 $0 $108.10 $3,243 $3,243

Hazardous debris transportation (20 cy per 

load)(estimate from vendor) 2 loads $0.00 $0 $0.00 $0 $2,398 $4,796 $4,796

$44,528 $34,840 $99,093 $178,460

2-cy Loader (nonhazardous debris load only)(ECHOS

17 02 0415) 6,500 cy $0.20 $1,300 $0.32 $2,080 $0.00 $0 $3,380

Nonhazardous debris disposal (estimate from vendor) 6,500 cy $0.00 $0 $0.00 $0 $6.62 $43,030 $43,030

Nonhazardous debris transportation (20 cy per 

load)(estimate from vendor) 325 loads $0.00 $0 $0.00 $0 $172.50 $56,063 $56,063

Clearing and grubbing; medium brush with average 

grub and some trees; clearing (ECHOS 17 01 0106) 36 acres $275 $9,885 $417 $15,012 $0.00 $0 $24,897

Machine-load spoils; 2-mile haul to dump (ECHOS 

02110 2000) 36 acres $926 $33,343 $493 $17,748 $0.00 $0 $51,091

ACM Removal and Disposal $0 $0 $249,165 $249,165

ACM oversight contractor (estimate from vendor) 1 ea $0.00 $0 $0.00 $0 $19,165 $19,165 $19,165

ACM removal and disposal (estimate from contractor) 1 ea $0.00 $0 $0.00 $0 $230,000 $230,000 $230,000

$0 $0 $7,970 $7,970

Hazardous water removal (WS-1)(estimate from 

vendor) 3 hours $0.00 $0 $0.00 $0 $80.50 $242 $242

Hazardous water disposal (WS-1)(estimate from 

vendor) 400 gal $0.00 $0 $0.00 $0 $0.86 $345 $345

Petroleum water removal (WS-6 and UST)(estimate

from vendor) 6 hours $0.00 $0 $0.00 $0 $80.50 $483 $483

Petroleum water disposal (WS-6 and UST)(estimate

from vendor) 10,000 gal $0.00 $0 $0.00 $0 $0.35 $3,450 $3,450

Other water removal (WS-2, 3, 5, 7, and 8)(estimate

from vendor) 12 hours $0.00 $0 $0.00 $0 $80.50 $966 $966

Other water disposal (WS-2, 3, 5, 7, and 8)(estimate

from vendor) 12,000 gal $0.00 $0 $0.00 $0 $0.21 $2,484 $2,484

Building Demolition and Disposal $12,394 $9,863 $139,018 $161,275

Multi-level, masonry, nonexplosive building demolition 

(ECHOS 17 02 0103) 178,000 cf $0.06 $10,680 $0.04 $7,120 $0.00 $0 $17,800

2-cy Loader (load only, 30% expansion)(ECHOS 17 

02 0415) 8,570 cy $0.20 $1,714 $0.32 $2,743 $0.00 $0 $4,457

Building debris transportation (18 cy per 

load)(estimate from vendor) 477 loads $0.00 $0 $0.00 $0 $172.50 $82,283 $82,283

Building debris disposal (nonhazardous 

debris)(estimate from vendor) 8,570 cy $0.00 $0 $0.00 $0 $6.62 $56,736 $56,736

Nonhazardous Debris Removal and 

Decontamination pad (recent EPA Region 6 RA)

Install temporary electrical service (recent EPA Region 6

RA)

Project sign (recent EPA Region 6 RA)

Support facilities (office trailers, storage trailers, utilities, 

outdoor lighting, meteorological station)(recent EPA Region

6 RA)

Security (24 hours per day, 7 days per week)(recent EPA 

Region 6 RA)

Install and maintain storm water control measures (recent 

EPA Region 6 RA)

TECHNOLOGY LOCATION: MEDIA:

Excavation, Consolidation, and Capping Soil MDI

Plug and abandon existing monitoring wells (24 feet 

deep)(based on previous work in EPA Region 6)

Demolition and Debris Removal

Hazardous Debris Removal and Disposal

Water Removal and Disposal

Excavation and On-site Containment

Page 1 of 4
ALTERNATIVE 4

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 4 - Containment and Institutional Controls and Monitored Natural Attenuation

Construction 

time: 6 months

Operation 

time: 30.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material Opinion

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

Excavation, Consolidation, and Capping Soil MDI

Concrete Demolition and Disposal $1,950 $3,120 $522,459 $527,529

Concrete demolition (recent EPA Region 6 RA) 7,500 cy $0.00 $0 $0.00 $0 $38.64 $289,800 $289,800

2-cy Loader (load only, 30% expansion)(ECHOS 17 

02 0415) 9,750 cy $0.20 $1,950 $0.32 $3,120 $0.00 $0 $5,070

Concrete transportation (20 tons per load, 2 tons per 

cy)(estimate from vendor) 975 loads $0.00 $0 $0.00 $0 $172.50 $168,188 $168,188

Concrete disposal (estimate from vendor) 9,750 cy $0.00 $0 $0.00 $0 $6.61 $64,472 $64,472

$4 $6 $1,676 $1,686

Solidification/stabilization (recent EPA Region 6 RA) 30 ton $0.00 $0 $0.00 $0 $14.28 $428 $428

2-cy Loader (load only, 30% expansion)(ECHOS 17 

02 0415) 20 cy $0.20 $4 $0.32 $6 $0.00 $0 $10

Transportation (estimate from vendor) 2 loads $0.00 $0 $0.00 $0 $172.50 $345 $345

Disposal (Class I) 20 cy $0.00 $0 $0.00 $0 $46.29 $903 $903

UST Removal $1,932 $3,569 $9,852 $15,353

Remove steel/fiberglass UST: 2,001 - 5,000 gallon 

capacity (ECHOS 33 10 9505) 1 ea $910 $910 $3,285 $3,285 $0.00 $0 $4,195

Excavation and stockpiling of contaminated soil 

(recent EPA Region 6 RA) 90 cy $0.00 $0 $0.00 $0 $18.08 $1,627 $1,627

2-cy Loader (load only, 43% expansion)(ECHOS 17 

02 0415) 129 cy $0.20 $26 $0.32 $41 $0.00 $0 $67

UST soil transportation (18 cy per load)(estimate from 

vendor) 8 loads $0.00 $0 $0.00 $0 $172.50 $1,380 $1,380

Soil disposal (Class 1)(estimate from vendor) 129 cy $0.00 $0 $0.00 $0 $46.29 $5,957 $5,957

Clean soil borrow, common earth (39% compaction) 

(M 02315 200 4060) 125 cy 0.49 $61 0.39 $49 $7.10 $888 $998

Fill, spread dumped material, by dozer, no compaction 

(M 02315 505 0010) 125 cy 0.47 $59 $1.14 $143 $0.00 $0 $201

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 

passes (M 02315 300 5720) 125 cy 0.18 $23 $0.41 $51 $0.00 $0 $74

Compaction testing, 1 nuclear per 5000 sf per 9-inch 

compacted lift (ASTM 2922)(M 01450 500 4735) 16 ea 53.36 $854 $0.00 $0 $0.00 $0 $854

LNAPL Impacted Soil Removal $82,349 $115,115 $356,477 $553,941

Steel sheeting; install, pull, and salvage; to 40 fee

(MW-3 Area)(ECHOS 17 03 0904) 8400 sf 3.67 $30,828 $4.93 $41,412 $3.39 $28,510 $100,750

Steel sheeting; install, pull, and salvage: to 25 feet 

(MW-11 and MW-20 Areas)(ECHOS 17 03 0903) 14160 sf 3.14 $44,462 $4.21 $59,614 $2.74 $38,829 $142,905

Excavation and stockpiling of overburden soil (recent 

EPA Region 6 RA) 3,465 cy $0.00 $0 $0.00 $0 $18.08 $62,647 $62,647

Excavation and stockpiling of contaminated soil 

(recent EPA Region 6 RA) 2,100 cy $0.00 $0 $0.00 $0 $18.08 $37,968 $37,968

2-cy Loader (load only, 43% expansion)(ECHOS 17 

02 0415) 3,003 cy $0.20 $601 $0.32 $961 $0.00 $0 $1,562

Contaminated soil transportation (18 cy per 

load)(estimate from vendor) 167 loads $0.00 $0 $0.00 $0 $172.50 $28,808 $28,808

Soil disposal (Class 1)(estimate from vendor) 3,003 cy $0.00 $0 $0.00 $0 $46.29 $139,001 $139,001

Clean soil borrow, common earth (39% compaction) 

(M 02315 200 4060) 2919 cy 0.49 $1,430 0.39 $1,138 $7.10 $20,715 $23,283

Fill, spread dumped material, by dozer, no compaction 

(M 02315 505 0010) 7735 cy 0.47 $3,636 $1.14 $8,818 $0.00 $0 $12,454

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 

passes (M 02315 300 5720) 7735 cy 0.18 $1,392 $0.41 $3,171 $0.00 $0 $4,564

Compaction testing, 1 nuclear per 5000 sf per 9-inch 

compacted lift (ASTM 2922)(M 01450 500 4735) 0 ea 53.36 $0 $0.00 $0 $0.00 $0 $0

PCB Transformer Disposal $0 $0 $17,293 $17,293

Transportation (separate trips for fluid and 

transformer)(estimate from vendor) 2 ea $0.00 $0 $0.00 $0 $2,990 $5,980 $5,980

Incineration of PCB-contaminated oil (estimate from 

vendor) 16,395 lb $0.00 $0 $0.00 $0 $0.69 $11,313 $11,313

Consolidation Area Preparation $0 $0 $245,888 $162,667

6,667 cy $7.32 $48,800 $4.88 $32,533 $10.13 $67,533 $148,867

4 ea $0.00 $0 $0.00 $0 $3,450 $13,800 $13,800

Bag House Material Disposal

Excavating, bulldozer, 75 HP, 300-foot haul, clay (M 02315 

410)

monitoring wells to 18 feet bgs (recent RAC work in EPA 

Region 6)

Excavation and On-site Containment

Page 2 of 4
ALTERNATIVE 4

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 4 - Containment and Institutional Controls and Monitored Natural Attenuation

Construction 

time: 6 months

Operation 

time: 30.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material Opinion

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

Excavation, Consolidation, and Capping Soil MDI

Excavation $0 $0 $245,888 $245,888

13,600 cy $0.00 $0 $0.00 $0 $18.08 $245,888 $245,888

Backfill and Compaction $22,726 $20,811 $156,345 $199,882

16,600 cy $0.49 $8,134 $0.31 $5,146 $7.09 $117,694 $130,974

1,667 cy $6.64 $11,067 $9.07 $15,117 $6.63 $11,050 $37,233

1,280 ft $1.84 $2,355 $0.00 $0 $20.86 $26,701 $29,056

1,280 ft $0.81 $1,037 $0.38 $486 $0.24 $307 $1,830

1 ea $133.10 $133 $62.11 $62 $592.88 $593 $788

Sampling and Analysis $0 $0 $119,242 $119,242

Total lead (recent EPA Region 6 RA) 97 ea $0.00 $0.00 $0.00 $0.00 $95.45 $9,259 $9,259

XRF Sampling (field sampling for lead)

XRF rental (recent EPA Region 6 RA) 6 month $0.00 $0.00 $0.00 $0.00 $4,418.30 $26,510 $26,510

1 ea $0.00 $0.00 $0.00 $0.00 $1,640 $1,640 $1,640

Air Monitoring

6 month $0.00 $0.00 $0.00 $0.00 $5,359.00 $32,154 $32,154

720 ea $0.00 $0.00 $0.00 $0.00 $69.00 $49,680 $49,680

Mobilization and Demobilization 1 lump sum $0 $0 $0 $258,781

10% $258,781

System Contingency $296,583

10% of Total Construction Activities $296,583

Professional/Technical Services $563,508

8% $237,266

5% $148,292

6% $177,950

OPERATION AND MAINTENANCE (O&M) ANNUAL O&M COST (Includes 1/5 of System O&M per year) $6,237

Monitoring, Sampling, Testing, and Analysis 1 lump sum $1,144 $570 $345 $2,059

Post-remediation Site Monitoring

4 well $286 $1,144 $142.39 $570 $15.08 $60 $1,774

4 sample $0 $0 $0 $0 $71.18 $285 $285

System O&M $14,000 $0 $0 $20,891

1 ea $14,000 $14,000 $0 $0 $0.00 $0 $14,000

Cap and fence maintenance (10% of installed $6,891

6' Galvanized Chain-link Fence (ECHOS 18 04 0107)

5 year review (Previous Region 6 work 

Sample Wells (4 wells sampled annually)(RS Means 33 02 

0401, 33 02 0402; Total Safety)

Data Analysis/Analytical, Lead (ECHOS 33 02 2143)

of Total Costs of Site Work and Sampling & Analysis

Remedial Design (Percentage of capital costs)(Exhibit 5-8 

from EPA 2000)

Excavation and stockpiling of lead-contaminated soil 

(recent EPA Region 6 RA)

Unclassified fill, 6-inch lifts, on-site; includes spreading and 

compaction (ECHOS 17 03 0422)

Capping of contaminated area/waste pile, clay, 10E-7, 6-

inch lifts, off-site, 2 inches thick (ECHOS 33 08 0507)

Excavation confirmation sampling (1 per 2,500 sf plus 10% 

QA/QC)

XRF supplies (cups, mylar, oven, bowls)(recent EPA 

Region 6 RA)

Equipment rental (low-flow air samplers, calibrator, dust 

monitor, calibration gas, and sound meter)(recent EPA 

Region 6 RA)

Air sample analysis (lead and total particulates, 4 samples 

per day)(recent EPA Region 6 RA)

Project Management (Percentage of capital costs)(Exhibit 

5-8 from EPA 2000)

Construction Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

6' Swing Gate, 12' Double (ECHOS 18 04 0117)

Galvanized Barbed Wire, 3-Strand (ECHOS 0.19 04 0111)

Excavation and On-site Containment

Page 3 of 4
ALTERNATIVE 4

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 4 - Containment and Institutional Controls and Monitored Natural Attenuation

Construction 

time: 6 months

Operation 

time: 30.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material Opinion

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

Excavation, Consolidation, and Capping Soil MDI

LIFETIME O&M (Net Present Value) $77,397

Years of Operation 30

Discount Factor 7%

TOTAL COST (CAPITAL COST + LIFETIME O&M)

Assumptions: 

1 2002 RS Means values increased to account for inflation 2.25%

2 Working condition is Safety Level: D (Labor productivity: 75% ; Equipment productivity: 95% )

3 Soil profile sampling will be conducted at the frequency of: 1 sample for every: 500 cy of contaminated soil plus 10% QA/QC

4 Cost index for zip code 770 88% (not applicable for costs derived from vendor quotes).

5 Costs are loaded with an overhead and profit factor: 15%

6 No net present value calculation is presented for alternative with an estimated remediation timeframe that is less than 1 year.

7 No dewatering costs included.

8 Treated soil and compaction volumes include 3,000 cy from off-property excavations currently stockpiled on property.

9 Debris volume only includes removal of debris overlying areas to be excavated.

10 Concrete volume only includes demolition and disposal of concrete over areas to be excavated.

Estimated Volume of Excavation:

Total

Estimated total volume of contaminated soil : 13,600 0 0 13,600 cf

Average soil swelling factor: 43%

Average soil density: 1.5 tons/cy

In-place Loose

13,600 19,448 cy 20,400 tons

39%

18,904

Notes:

ACM Asbestos-containing material

ASTM American Society of Testing and Materials

bgs Below ground surface

cf Cubic foot

cy Cubic yard

ECHOS Environmental Cost Handling Options and Solutions (RS Means 2002a)

EPA U.S. Environmental Protection Agency

gal Gallon

HP Horsepower

lb Pound

LNAPL Light nonaqueous-phase liquid

MW Monitoring well

PCB Polychlorinated biphenyl

QA/QC Quality assurance/quality control

RCRA Resource Conservation and Recovery Act

sf Square feet

TCLP Toxicity Characteristic Leaching Procedure

UST Underground storage tank

WS Waste sample

XRF X-ray fluoresence

References: 

1) RS Means. 2002b. Heavy Construction Cost Data. 16th Annual Edition.

2) RS Means. 2002a. Environmental Remediation Cost Data, Unit Price. 8th Annual Edition

3) EPA. 2000. A Guide to Developing and Documenting Cost Estimates During the Feasibility Study.

$3,903,319

Estimated total volume of replacement soil

Replacement soil compaction factor

Estimated total volume of excavated soil :

Excavation and On-site Containment

Page 4 of 4
ALTERNATIVE 4

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 4 - Containment and Institutional Controls and Monitored Natural Attenuation

Construction 

TIme: 1 months

Operation 

TIme: 30.0 years

Post 

Remediation 

Monitoring

30.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material Opinion

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

REMEDIAL ACTION TOTAL CAPITAL COST $118,161

Initial Site Characterization $75,502

6 ea $0.00 $0 $0.00 $0 $3,450 $20,700 $20,700

48 well $286 $13,733 $142.39 $6,835 $15.08 $724 $21,292

48 ea

48 sample $0 $0 $0 $0 $233.80 $11,222 $11,222

48 sample $0 $0 $0 $0 $51.73 $2,483 $2,483

48 sample $0 $0 $0 $0 $71.18 $3,416 $3,416

Ferrous iron (ECHOS 33 02 1678) 48 sample $0 $0 $0 $0 $96.42 $4,628 $4,628

Dissolved manganese (ECHOS 33 02 1644) 48 sample $0 $0 $0 $0 $71.18 $3,416 $3,416

Nitrate (ECHOS 33 02 1661) 48 sample $0 $0 $0 $0 $36.70 $1,762 $1,762

Sulfate (ECHOS 33 02 1667) 48 sample $0 $0 $0 $0 $19.40 $931 $931

Dissolved oxygen (ECHOS 33 02 1663) 48 sample $0 $0 $0 $0 $28.76 $1,381 $1,381

1 lump sum $4,271 $4,271 $0 $0 $0 $0 $4,271

Contingency $7,550

10% of total construction activities $7,550

Professional/Technical Services $35,109

20% $15,100

10% $7,550

15% $12,458

MNA Monitoring (Annually) $21,269

Monitoring, Sampling, Testing, and Analysis 12 months $3,433 $1,709 $7,330 $12,472

8 well $286 $2,289 $142.39 $1,139 $15.08 $121 $3,549

4 well $286 $1,144 $142.39 $570 $15.08 $60 $1,774

12 ea

12 sample $0 $0 $0 $0 $228.65 $2,744 $2,744

12 sample $0 $0 $0 $0 $50.59 $607 $607

12 sample $0 $0 $0 $0 $69.61 $835 $835

Ferrous iron (ECHOS 33 02 1678) 12 sample $0 $0 $0 $0 $94.30 $1,132 $1,132

Dissolved manganese (ECHOS 33 02 1644) 12 sample $0 $0 $0 $0 $69.61 $835 $835

Nitrate (ECHOS 33 02 1661) 12 sample $0 $0 $0 $0 $35.89 $431 $431

Sulfate (ECHOS 33 02 1667) 12 sample $0 $0 $0 $0 $18.98 $228 $228

Dissolved oxygen (ECHOS 33 02 1663) 12 sample $0 $0 $0 $0 $28.13 $338 $338

Contingency $1,247

10% $1,247

Professional/Technical Services 12 months $0.00 $0.00 $0.00 $7,550

10% $7,550

Sample wells (2 wells sampled quarterly)(RS Means 

33 02 0401, 33 02 0402; Total Safety)

Lab analysis 

Ground water fate and transport modeling (ECHOS 

33 02 0419)

Remedial Design (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Project Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Construction Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

of Total Monitoring, Sampling, Testing, and Analysis

Project Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Sample wells (4 wells sampled annually)(RS Means 

33 02 0401, 33 02 0402; Total Safety)

Polynuclear aromatic hydrocarbons 

(3510C)(ECHOS 33 02 2134)

Lead (ECHOS 33 02 2143)

Iron (ECHOS 33 02 1644)

MEDIA:

MDI

Monitored Natural Attenuation (MNA)

TECHNOLOGY LOCATION:

Deep Soil/Ground 

Water Contamination

Iron (ECHOS 33 02 1644)

Sample wells (6 wells sampled quarterly for 2 

years)(RS Means 33 02 0401, 33 02 0402; Total 

Safety)

Lab analysis 

Installation, completion, and development of 

additional monitoring wells to 18 feet bgs (recent 

RAC work in EPA Region 6)

Polynuclear aromatic hydrocarbons 

(3510C)(ECHOS 33 02 2134)

Lead (ECHOS 33 02 2143)

Monitored Natural Attenuation

Page 1 of 2
ALTERNATIVE 4

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 4 - Containment and Institutional Controls and Monitored Natural Attenuation

Construction 

TIme: 1 months

Operation 

TIme: 30.0 years

Post 

Remediation 

Monitoring

30.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material Opinion

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

MEDIA:

MDI

Monitored Natural Attenuation (MNA)

TECHNOLOGY LOCATION:

Deep Soil/Ground 

Water Contamination

LIFETIME MONITORING COST (Present Value) $263,933

Years of Operation 30

Discount Factor 7.0%

TOTAL COST (CAPITAL COST + LIFETIME OPERATING COST)

Assumptions: 

1 2002 RS Means values increased to account for inflation 2.25%

2 Working condition is Safety Level: D (Labor productivity: 75% ; Equipment productivity: 95% )

3 Cost index for zip code 770 88% (not applicable for costs derived from vendor quotes).

4 Costs are loaded with an overhead and profit factor: 15%

5 No net present value calculation is presented for alternative with an estimated remediation timeframe that is less than 1 year.

Notes:

bgs Below ground surface

ECHOS Environmental Cost Handling Options and Solutions (RS Means 2002a)

EPA U.S. Environmental Protection Agency

RAC Response Action Contract

References: 

1) RS Means. 2002b. Heavy Construction Cost Data. 16th Annual Edition.

2) RS Means. 2002a. Environmental Remediation Cost Data, Unit Price. 8th Annual Edition

3) EPA. 2000. A Guide to Developing and Documenting Cost Estimates During the Feasibility Study.

$382,094

Monitored Natural Attenuation

Page 2 of 2
APPENDIX B-4 

ALTERNATIVE 5–SOLIDIFICATION/STABILIZATION AND OFF-SITE DISPOSAL OF 

SOILS IN UNPAVED AREAS; GROUND WATER VIA MNA WITH ICS 

(Seven Pages) 
Target Media Capital Cost ($)

Lifetime O&M 

Cost ($)

Post-remediation 

Monitoring Cost 

($) Total Cost ($)

Remediati

Frame (m

Soil $2,903,330 $0 $0 $2,903,330 4 

Deep Soil/Ground Water Contamination $118,161 $0 $298,679 $416,840 1 

$3,021,491 $0 $298,679 $3,320,170 5 

Note:

O&M Operation and maintenance

ALTERNATIVE 5

EXCAVATION OF UNCAPPED SOIL AND OFF-SITE DISPOSAL WITH MNA

TOTAL REMEDIAL COST SUMMARY

MDI SUPERFUND SITE OPERABLE UNIT 1

Component

Excavation and Off-site Disposal with MNAExcavation of Uncapped Soil, Solidification/Stabilization, and Off-site DisposalMonitored Natural Attenuation (MNA)

Page 1
ALTERNATIVE 5

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 5 - Solidification/Stabilization of Uncapped Soil and Off-site Disposal with Monitored Natural Attenuation Construction 

time: 4 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

REMEDIAL ACTION (RA) TOTAL CAPITAL COST $2,903,330

Construction Activities $2,220,028

Site Work $150,072 $169,310 $1,210,852 $1,530,233

Temporary Facilities $0 $0 $190,572 $190,572

1 lump sum $0.00 $0 $0.00 $0 $11,465 $11,465 $11,465

1 lump sum $0.00 $0 $0.00 $0 $2,399 $2,399 $2,399

1 lump sum $0.00 $0 $0.00 $0 $8,011 $8,011 $8,011

4 per month $0.00 $0 $0.00 $0 $21,418 $85,673 $85,673

1 lump sum $0.00 $0 $0.00 $0 $32,553 $32,553 $32,553

4 per month $0.00 $0 $0.00 $0 $10,618 $42,472 $42,472

4 ea $0.00 $0 $0.00 $0 $2,000.00 $8,000 $8,000

$142,064 $162,742 $832,632 $1,137,438

$6 $10 $8,039 $8,054

2-cy Loader (ECHOS 17 02 0415) 30 cy $0.20 $6 $0.32 $10 $0.00 $0 $16

Hazardous debris disposal (estimate from vendor) 30 cy $0.00 $0 $0.00 $0 $108.10 $3,243 $3,243

Hazardous debris transportation (20 cy per 

load)(estimate from vendor) 2 loads $0.00 $0 $0.00 $0 $2,398 $4,796 $4,796

$43,228 $32,760 $0 $75,988

Clearing and grubbing; medium brush with average 

grub and some trees, clearing (ECHOS 17 01 0106) 36 acres $275 $9,885 $417 $15,012 $0.00 $0 $24,897

Machine-load spoils; 2-mile haul to dump (ECHOS 

02110 2000) 36 acres $926 $33,343 $493 $17,748 $0.00 $0 $51,091

ACM Removal and Disposal $0 $0 $249,165 $249,165

ACM oversight contractor (estimate from vendor) 1 ea $0.00 $0 $0.00 $0 $19,165 $19,165 $19,165

ACM removal and disposal (estimate from contractor) 1 ea $0.00 $0 $0.00 $0 $230,000 $230,000 $230,000

$1,995 $1,171 $9,315 $12,480

Hazardous water removal (WS-1)(estimate from vendor) 3 hours $0.00 $0 $0.00 $0 $80.50 $242 $242

Hazardous water disposal (WS-1)(estimate from 

vendor) 400 gal $0.00 $0 $0.00 $0 $0.86 $345 $345

Petroleum water removal (WS-6 and UST)(estimate 

from vendor) 6 hours $0.00 $0 $0.00 $0 $80.50 $483 $483

Petroleum water disposal (WS-6 and UST)(estimate 

from vendor) 10,000 gal $0.00 $0 $0.00 $0 $0.35 $3,450 $3,450

Other water removal (WS-2, 3, 5, 7, and 8)(estimate 

from vendor) 12 hours $0.00 $0 $0.00 $0 $80.50 $966 $966

Other water disposal (WS-2, 3, 5, 7, and 8)(estimate 

from vendor) 12,000 gal $0.00 $0 $0.00 $0 $0.21 $2,484 $2,484

Decontamination of pits by high pressure wash (WS-1, 

WS-2, and WS-3; ECHOS 33 17 0805) 1,084 sf $1.84 $1,995 $1.08 $1,171 $0.00 $0 $3,165

Decontamination water removal (WS-1, WS-2, and WS3)(estimate from vendor) 6 hours $0.00 $0 $0.00 $0 $80.50 $483 $483

Decontamination water disposal (WS-1, WS-2, & WS3)(estimate from vendor) 1,000 gal $0.00 $0 $0.00 $0 $0.86 $863 $863

$12,394 $9,863 $139,018 $161,275

Multi-level, masonry, nonexplosive building demolition 

(ECHOS 17 02 0103) 178,000 cf $0.06 $10,680 $0.04 $7,120 $0.00 $0 $17,800

2-cy Loader (load only, 30% expansion)(ECHOS 17 02 

0415) 8,570 cy $0.20 $1,714 $0.32 $2,743 $0.00 $0 $4,457

Building debris transportation (18 cy per load)(estimate 

from vendor) 477 loads $0.00 $0 $0.00 $0 $172.50 $82,283 $82,283

Building debris disposal (nonhazardous 

debris)(estimate from vendor) 8,570 cy $0.00 $0 $0.00 $0 $6.62 $56,736 $56,736

Plug and abandon existing monitoring wells (24 feet 

deep)(based on previous work in EPA Region 6)

Demolition, Debris & LNAPL Removal

TECHNOLOGY LOCATION: MEDIA:

MDI Excavation of Uncapped Soil, 

Solidification/Stabilization, and Off-site Disposal Soil

Nonhazardous Debris Removal and Disposal

Decontamination pad (recent EPA Region 6 RA)

Install temporary electrical service (recent EPA Region 6 

RA)

Hazardous Debris Removal and Disposal

Project sign (recent EPA Region 6 RA)

Support facilities (Office trailers, storage trailers, utilities, 

outdoor lighting, meteorological station)(recent EPA Region 

6 RA)

Security (24 hours per day, 7 days per week)(recent EPA 

Region 6 RA)

Install and maintain storm water control measures (recent 

EPA Region 6 RA)

Water Removal, Disposal, and Pit 

Decontamination

Building Demolition and Disposal (Not 

including ACM)

Excavation and Off-site Disposal of Uncapped Soil

Page 1 of 4
ALTERNATIVE 5

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 5 - Solidification/Stabilization of Uncapped Soil and Off-site Disposal with Monitored Natural Attenuation Construction 

time: 4 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

MDI Excavation of Uncapped Soil, 

Solidification/Stabilization, and Off-site Disposal Soil

Concrete Demolition and Disposal $156 $250 $41,797 $42,202

Concrete demolition (recent EPA Region 6 RA) 600 cy $0.00 $0 $0.00 $0 $38.64 $23,184 $23,184

2-cy Loader (load only, 30% expansion)(ECHOS 17 02 

0415) 780 cy $0.20 $156 $0.32 $250 $0.00 $0 $406

Concrete transportation (20 tons per load, 2 tons per 

cy)(estimate from vendor) 78 loads $0.00 $0 $0.00 $0 $172.50 $13,455 $13,455

Concrete disposal (estimate from vendor) 780 cy $0.00 $0 $0.00 $0 $6.61 $5,158 $5,158

$4 $6 $1,676 $1,686

Solidification/stabilization (recent EPA Region 6 RA) 30 ton $0.00 $0 $0.00 $0 $14.28 $428 $428

2-cy Loader (load only, 30% expansion)(ECHOS 17 02 

0415) 20 cy $0.20 $4 $0.32 $6 $0.00 $0 $10

Transportation (estimate from vendor) 2 loads $0.00 $0 $0.00 $0 $172.50 $345 $345

Disposal (Class I) 20 cy $0.00 $0 $0.00 $0 $46.29 $903 $903

UST Removal $1,932 $3,569 $9,852 $15,353

Remove steel/fiberglass UST: 2,001 - 5,000 gallon 

capacity (ECHOS 33 10 9505) 1 ea $910 $910 $3,285 $3,285 $0.00 $0 $4,195

Excavation and stockpiling of contaminated soil (recent 

EPA Region 6 RA) 90 cy $0.00 $0 $0.00 $0 $18.08 $1,627 $1,627

2-cy Loader (load only, 43% expansion)(ECHOS 17 02 

0415) 129 cy $0.20 $26 $0.32 $41 $0.00 $0 $67

UST soil transportation (18 cy per load)(estimate from 

vendor) 8 loads $0.00 $0 $0.00 $0 $172.50 $1,380 $1,380

Soil disposal (Class 1)(estimate from vendor) 129 cy $0.00 $0 $0.00 $0 $46.29 $5,957 $5,957

Clean soil borrow, common earth (39% compaction)(M 

02315 200 4060) 125 cy 0.49 $61 0.39 $49 $7.10 $888 $998

Fill, spread dumped material, by dozer, no compaction 

(M 02315 505 0010) 125 cy 0.47 $59 $1.14 $143 $0.00 $0 $201

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 

passes (M 02315 300 5720) 125 cy 0.18 $23 $0.41 $51 $0.00 $0 $74

Compaction testing, 1 nuclear per 5000 sf per 9-inch 

compacted lift (ASTM 2922 M 01450 500 4735) 16 ea 53.36 $854 $0.00 $0 $0.00 $0 $854

LNAPL Impacted Soil Removal $82,349 $115,115 $356,477 $553,941

Steel sheeting; install, pull, and salvage; to 40 feet 

(MW-3 Area)(ECHOS 17 03 0904) 8400 sf 3.67 $30,828 $4.93 $41,412 $3.39 $28,510 $100,750

Steel sheeting; install, pull, and salvage; to 25 feet 

(MW-11 and MW-20 Areas)(ECHOS 17 03 0903) 14160 sf 3.14 $44,462 $4.21 $59,614 $2.74 $38,829 $142,905

Excavation and stockpiling of overburden soil (recent 

EPA Region 6 RA) 3,465 cy $0.00 $0 $0.00 $0 $18.08 $62,647 $62,647

Excavation and stockpiling of contaminated soil (recent 

EPA Region 6 RA) 2,100 cy $0.00 $0 $0.00 $0 $18.08 $37,968 $37,968

2-cy Loader (load only, 43% expansion)(ECHOS 17 02 

0415) 3,003 cy $0.20 $601 $0.32 $961 $0.00 $0 $1,562

Contaminated soil transportation (18 cy per 

load)(estimate from vendor) 167 loads $0.00 $0 $0.00 $0 $172.50 $28,808 $28,808

Soil disposal (Class 1)(estimate from vendor) 3,003 cy $0.00 $0 $0.00 $0 $46.29 $139,001 $139,001

Clean soil borrow, common earth (39% compaction)(M 

02315 200 4060) 2919 cy 0.49 $1,430 0.39 $1,138 $7.10 $20,715 $23,283

Fill; spread dumped material, by dozer; no compaction 

(M 02315 505 0010) 7735 cy 0.47 $3,636 $1.14 $8,818 $0.00 $0 $12,454

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 

passes (M 02315 300 5720) 7735 cy 0.18 $1,392 $0.41 $3,171 $0.00 $0 $4,564

Compaction testing, 1 nuclear per 5000 sf per 9-inch 

compacted lift (ASTM 2922 M 01450 500 4735) 0 ea 53.36 $0 $0.00 $0 $0.00 $0 $0

PCB Transformer Disposal $0 $0 $17,293 $17,293

Transportation (separate trips for fluid and 

transformer)(estimate from vendor) 2 ea $0.00 $0 $0.00 $0 $2,990 $5,980 $5,980

Incineration of PCB-contaminated oil (estimate from 

vendor) 16,395 lb $0.00 $0 $0.00 $0 $0.69 $11,313 $11,313

Excavation and Treatment $0 $0 $163,010 $163,010

2,500 cy $0.00 $0 $0.00 $0 $18.08 $45,200 $45,200

3,750 ton $0.00 $0 $0.00 $0 $14.28 $53,550 $53,550

4,500 ton $0.00 $0 $0.00 $0 $14.28 $64,260 $64,260

Bag House Material Disposal

Excavation and stockpiling of lead-contaminated soil (recent 

EPA Region 6 RA)

Solidification/stabilization (recent EPA Region 6 RA)

Solidification/stabilization of off-property soil (recent EPA 

Region 6 RA)

Excavation and Off-site Disposal of Uncapped Soil

Page 2 of 4
ALTERNATIVE 5

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 5 - Solidification/Stabilization of Uncapped Soil and Off-site Disposal with Monitored Natural Attenuation Construction 

time: 4 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

MDI Excavation of Uncapped Soil, 

Solidification/Stabilization, and Off-site Disposal Soil

Backfill and Compaction $8,008 $6,568 $24,638 $39,213

3,475 cy $0.49 $1,703 $0.31 $1,077 $7.09 $24,638 $27,418

3,475 cy $0.79 $2,745 $1.26 $4,379 $0.00 $0 $7,124

3,475 cy $0.18 $626 $0.32 $1,112 $0.00 $0 $1,738

55 ea $53.35 $2,934 $0.00 $0 $0.00 $0 $2,934

Off-site Disposal $3,854 $2,438 $439,511 $445,803

Soil Disposal (On-property Soil) $1,752 $1,108 $199,814 $202,674

3,575 cy $0.49 $1,752 $0.31 $1,108 $0.00 $0 $2,860

199 loads $0.00 $0 $0.00 $0 $172.50 $34,328 $34,328

3,575 cy $0.00 $0 $0.00 $0 $46.29 $165,487 $165,487

Soil Disposal (Off-property Soil) $2,102 $1,330 $239,697 $243,129

4,290 cy $0.49 $2,102 $0.31 $1,330 $0.00 $0 $3,432

238 loads $0.00 $0 $0.00 $0 $172.50 $41,113 $41,113

4,290 cy $0.00 $0 $0.00 $0 $46.29 $198,584 $198,584

Sampling and Analysis $0 $0 $90,969 $90,969

Profile Analysis for Soil Disposal

TCLP (RCRA metals)(recent EPA Region 6 RA) 15 ea $0.00 $0.00 $0.00 $0.00 $322.00 $4,830 $4,830

Total lead (recent EPA Region 6 RA) 97 ea $0.00 $0.00 $0.00 $0.00 $95.45 $9,259 $9,259

XRF Sampling (field sampling for lead)

XRF rental (recent EPA Region 6 RA) 4 month $0.00 $0.00 $0.00 $0.00 $4,418 $17,673 $17,673

1 ea $0.00 $0.00 $0.00 $0.00 $1,640 $1,640 $1,640

Air Monitoring

4 month $0.00 $0.00 $0.00 $0.00 $5,359.00 $21,436 $21,436

480 ea $0.00 $0.00 $0.00 $0.00 $69.00 $33,120 $33,120

12 ea $0.00 $0.00 $0.00 $0.00 $250.92 $3,011 $3,011

Mobilization and Demobilization 1 lump sum $153,023

10% $153,023

System Contingency $222,003

10% of Total Construction Activities $222,003

Professional/Technical Services $461,299

12% $212,907

6% $106,454

8% $141,938

OPERATION AND MAINTENANCE (O&M) ANNUAL O&M COST $0

Monitoring, Sampling, Testing, and Analysis 1 lump sum $0 $0 $0 $0

Post Remediation Site Monitoring

Geoprobe 0 lump sum $10,000 $0 $5,000 $0 $0 $0 $0

Field Work Labor 0 lump sum $15,000 $0 $0 $0 $0 $0 $0

0 lump sum $15,000 $0 $0 $0 $0 $0 $0

System O&M $0 $0 $0 $0

Excavation Confirmation Sampling (1 per 2,500 sf plus 10% 

QA/QC)

XRF supplies (cups, mylar, oven, bowls)(recent EPA 

Region 6 RA)

Equipment rental (low-flow air samplers, calibrator, dust 

monitor, calibration gas, and sound meter)(recent EPA 

Region 6 RA)

Air sample analysis (lead and total particulates; 4 samples 

per day)(recent EPA Region 6 RA)

Project Management (Percentage of capital costs excluding 

off-site disposal)(Exhibit 5-8 from EPA 2000)

Treated soil transportation (BFI Landfill, 18 cy per load)

Loading common earth, front-end loader, wheel mtd, 1.5 cy 

(M 02315 200 4060)

Compaction testing, nuclear method (ASTM D2922); 1 per 

5,000 sf per 9-inch loose lift (M 01450 500 4735)

Clean soil borrow, common earth (M 02315 200 4060)

Compaction, sheepfoot wobbly wheel, 12-inch lift, 4 passes 

(M 02315 300 5720)

Pit Wall Sampling after Decontamination (1 sample per 10 

square meters, for PCB in WS-1, WS-2, & WS-3; ECHOS 33 02 

Soil disposal (Class I)

of Total Costs of Site Work and Sampling & Analysis

Remedial Design (Percentage of capital costs excluding offsite disposal)(Exhibit 5-8 from EPA 2000)

Data Analysis/Analytical (TPH, BTEX)

Loading common earth, front-end loader, wheel mtd, 1.5 cy 

(M 02315 200 4060)

Treated soil transportation (BFI Landfill, 18 cy per load)

Soil disposal (Class I)

Construction Management (Percentage of capital costs 

excluding off-site disposal)(Exhibit 5-8 from EPA 2000)

Backfill, spread fill, from stockpile w/ front-end loader (M 

02315 505 0170)

Excavation and Off-site Disposal of Uncapped Soil

Page 3 of 4
ALTERNATIVE 5

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 5 - Solidification/Stabilization of Uncapped Soil and Off-site Disposal with Monitored Natural Attenuation Construction 

time: 4 months

Operation 

time: 0.0 years

Post 

Remediation 

Monitoring

0.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

TECHNOLOGY LOCATION: MEDIA:

MDI Excavation of Uncapped Soil, 

Solidification/Stabilization, and Off-site Disposal Soil

LIFETIME O&M (Net Present Value) $0

Years of Operation 0

Discount Factor 7%

TOTAL COST (CAPITAL COST + LIFETIME O&M)

Assumptions: 

1 2002 RS Means values increased to account for inflation 2.25%

2 Working condition is Safety Level: D (Labor productivity: 75% ; Equipment productivity: 95% )

3 Soil profile sampling will be conducted at the frequency of: 1 sample for every: 500 cy of contaminated soil plus 10% QA/QC

4 Cost index for zip code 770 88% (not applicable for costs derived from vendor quotes).

5 Costs are loaded with an overhead and profit factor: 15%

6 No net present value calculation is presented for alternative with an estimated remediation timeframe that is less than 1 year.

7 No dewatering costs included.

8 Treated soil and disposal volumes include 3,000 cy from off-property excavations currently stockpiled on property.

9 Debris volume only includes removal of debris overlying areas to be excavated.

10 Concrete volume only includes demolition of concrete overlying areas to be excavated.

Estimated Volume of Excavation:

Total

Estimated total volume of contaminated soil : 2,500 0 0 2,500 cf

Average soil swelling factor: 43%

Average soil density: 1.5 tons/cy

In-place Loose

2,500 3,575 cy 3,750 tons

39%

3,475

Notes:

ACM Asbestos-containing material

ASTM American Society of Testing and Materials

BTEX Benzene, toluene, ethylbenzene, and xylenes

cf Cubic foot

cy Cubic yard

ECHOS Environmental Cost Handling Options and Solutions (RS Means 2002a)

EPA U.S. Environmental Protection Agency

gal Gallon

lb Pound

LNAPL Light nonaqueous-phase liquid

MW Monitoring well

PCB Polychlorinated biphenyl

QA/QC Quality assurance/quality control

RCRA Resource Conservation and Recovery Act

sf Square feet

TCLP Toxicity Characteristic Leaching Procedure

TPH Total petroleum hydrocarbons

UST Underground storage tank

WS Waste sample

XRF X-ray fluoresence

References: 

1) RS Means. 2002b. Heavy Construction Cost Data. 16th Annual Edition.

2) RS Means. 2002a. Environmental Remediation Cost Data, Unit Price. 8th Annual Edition

3) EPA. 2000. A Guide to Developing and Documenting Cost Estimates During the Feasibility Study.

Replacement soil compaction factor

Estimated total volume of excavated soil :

Estimated total volume of replacement soil

$2,903,330

Excavation and Off-site Disposal of Uncapped Soil

Page 4 of 4
ALTERNATIVE 5

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 5 - Solidification/Stabilization of Uncapped Soil and Off-site Disposal with Monitored Natural Attenuation 

Construction 

TIme: 1 months

Operation 

TIme:

30.0

years

Post 

Remediation 

Monitoring

30.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

REMEDIAL ACTION TOTAL CAPITAL COST $118,161

Initial Site Characterization $75,502

6 ea $0.00 $0 $0.00 $0 $3,450 $20,700 $20,700

48 well $286 $13,733 $142.39 $6,835 $15.08 $724 $21,292

48 ea

48 sample $0 $0 $0 $0 $233.80 $11,222 $11,222

48 sample $0 $0 $0 $0 $51.73 $2,483 $2,483

48 sample $0 $0 $0 $0 $71.18 $3,416 $3,416

Ferrous iron (ECHOS 33 02 1678) 48 sample $0 $0 $0 $0 $96.42 $4,628 $4,628

Dissolved manganese (ECHOS 33 02 1644) 48 sample $0 $0 $0 $0 $71.18 $3,416 $3,416

Nitrate (ECHOS 33 02 1661) 48 sample $0 $0 $0 $0 $36.70 $1,762 $1,762

Sulfate (ECHOS 33 02 1667) 48 sample $0 $0 $0 $0 $19.40 $931 $931

Dissolved oxygen (ECHOS 33 02 1663) 48 sample $0 $0 $0 $0 $28.76 $1,381 $1,381

1 lump sum $4,271 $4,271 $0 $0 $0 $0 $4,271

Contingency $7,550

10% of total construction activities $7,550

Professional/Technical Services $35,109

20% $15,100

10% $7,550

15% $12,458

MNA Monitoring (Annually) $24,069

Ground water fate and transport modeling 

(ECHOS 33 02 0419)

Remedial Design (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Project Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Construction Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

MEDIA:

MDI

Monitored Natural Attenuation (MNA)

TECHNOLOGY LOCATION:

Deep Soil/Ground 

Water Contamination

Iron (ECHOS 33 02 1644)

Sample wells (6 wells sampled quarterly for 2 

years)(RS Means 33 02 0401, 33 02 0402; Total 

Safety)

Lab analysis 

Installation, completion, and development of 

additional monitor wells to 18 feet bgs (Recent 

RAC work in Region 6)

Polynuclear aromatic hydrocarbons 

(3510C)(ECHOS 33 02 2134)

Lead (ECHOS 33 02 2143)

Monitored Natural Attenuation

Page 1 of 2
ALTERNATIVE 5

MDI SUPERFUND SITE OPERABLE UNIT 1

HOUSTON, TEXAS

Alternative 5 - Solidification/Stabilization of Uncapped Soil and Off-site Disposal with Monitored Natural Attenuation 

Construction 

TIme: 1 months

Operation 

TIme:

30.0

years

Post 

Remediation 

Monitoring

30.0 years

Quantity Quantity Labor Labor Equipment Equipment Material Material

Amount Unit Unit Cost Total Cost Unit Cost Total Cost Unit Cost Total Cost Total Cost

MEDIA:

MDI

Monitored Natural Attenuation (MNA)

TECHNOLOGY LOCATION:

Deep Soil/Ground 

Water Contamination

Monitoring, Sampling, Testing, and Analysis 12 months $3,433 $1,709 $7,330 $12,472

8 well $286 $2,289 $142.39 $1,139 $15.08 $121 $3,549

4 well $286 $1,144 $142.39 $570 $15.08 $60 $1,774

12 ea

12 sample $0 $0 $0 $0 $228.65 $2,744 $2,744

12 sample $0 $0 $0 $0 $50.59 $607 $607

12 sample $0 $0 $0 $0 $69.61 $835 $835

Ferrous iron (ECHOS 33 02 1678) 12 sample $0 $0 $0 $0 $94.30 $1,132 $1,132

Dissolved manganese (ECHOS 33 02 1644) 12 sample $0 $0 $0 $0 $69.61 $835 $835

Nitrate (ECHOS 33 02 1661) 12 sample $0 $0 $0 $0 $35.89 $431 $431

Sulfate (ECHOS 33 02 1667) 12 sample $0 $0 $0 $0 $18.98 $228 $228

Dissolved oxygen (ECHOS 33 02 1663) 12 sample $0 $0 $0 $0 $28.13 $338 $338

Contingency $1,247

10% $1,247

Professional/Technical Services 12 months $2,800 $0 $0 $10,350

10% $7,550

0.2 per year 14000 $2,800 $0.00 $0 $0 $0 $2,800

LIFETIME MONITORING COST (Present Value) $298,679

Years of Operation 30

Discount Factor 7.0%

TOTAL COST (CAPITAL COST + LIFETIME OPERATING COST)

Assumptions: 

1 2002 RS Means values increased to account for inflation 2.25%

2 Working condition is Safety Level: D (Labor productivity: 75% ; Equipment productivity: 95% )

3 Cost index for zip code 770 88% (not applicable for costs derived from vendor quotes).

4 Costs are loaded with an overhead and profit factor: 15%

5 No net present value calculation is presented for alternative with an estimated remediation timeframe that is less than 1 year.

Notes:

bgs Below ground surface

ECHOS Environmental Cost Handling Options and Solutions (RS Means 2002a)

EPA U.S. Environmental Protection Agency

RAC Response Action Contract

References: 

1) RS Means. 2002b. Heavy Construction Cost Data. 16th Annual Edition.

2) RS Means. 2002a. Environmental Remediation Cost Data, Unit Price. 8th Annual Edition

3) EPA. 2000. A Guide to Developing and Documenting Cost Estimates During the Feasibility Study.

Sample wells (4 wells sampled annually)(RS 

Means 33 02 0401, 33 02 0402; Total Safety)

Polynuclear aromatic hydrocarbons 

(3510C)(ECHOS 33 02 2134)

Sample wells (2 wells sampled quarterly)(RS 

Means 33 02 0401, 33 02 0402; Total Safety)

Lab analysis 

$416,840

of Total Monitoring, Sampling, Testing, and 

Analysis

Project Management (Percentage of capital 

costs)(Exhibit 5-8 from EPA 2000)

Lead (ECHOS 33 02 2143)

Iron (ECHOS 33 02 1644)

5 year review (Previous Region 6 work;1/5 of cost 

included annually)

Monitored Natural Attenuation

Page 2 of 2