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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 6

1445 ROSS AVENUE, SUITE 1200

DALLAS, TX 75202-2733

MEMORANDUM

SUBJECT:

FROM:

TO:

THRU:

Amendment to the Action Memorandum at the High Access Areas of the Many

Diver$ifiecWnterestSxInc. Superfund Site, Houston, Harris County, Texas

Greg<6ry Fife, On-Scene Coordinator

Site Response Section (6SF-R2)

Myron O. Knudson, P.E., DirectOyf

Superfund Division (6SF)

Charles A. Gazda Chi

Response and Pre

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I. PURPOSE

This memorandum documents your verbal approval for a ceiling increase and an

amendment to the Removal Action pursuant to the Comprehensive Environmental Response,

Compensation and Liability Act (CERCLA), as amended, 42 U.S.C. §§9601 et seq.. at the High

Access Areas of the Many Diversified Interests, Inc. Superfund Site ("MDI" or "Site") located in

Houston, Harris County, Texas. The proposed amendment involves the excavation and

consolidation of contaminated soil in 33 additional High Access Areas (HAAs) of the Site.

II. SITE CONDITIONS AND BACKGROUND

CERCLIS # TX0002288082

Category of removal: Time Critical

Site ID # 06FE

161172

Internet Address (URL) - http://www.epa.aov/earth1 r6/

Recycled/Recyclable - Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)
MEMORANDUM

SUBJECT: Amendment to the Action Memorandum at the High Access Areas of the Many

Diversified Interests, Inc. Superfund Site, Houston, Harris County, Texas

FROM: Gregory Fife, On-Scene Coordinator

Site Response Section (6SF-R2)

TO: Myron O. Knudson, P.E., Director

Superfund Division (6SF)

THRU: Charles A. Gazda, Chief

Response and Prevention Branch (6SF-R)

I. PURPOSE

This memorandum documents your verbal approval for a ceiling increase and an

amendment to the Removal Action pursuant to the Comprehensive Environmental Response,

Compensation and Liability Act (CERCLA), as amended, 42 U.S.C. §§9601 et seq.. at the High

Access Areas of the Many Diversified Interests, Inc. Superfund Site ("MDF or "Site") located in

Houston, Harris County, Texas. The proposed amendment involves the excavation and

consolidation of contaminated soil in 33 additional High Access Areas (HAAs) of the Site.

H. SITE CONDITIONS AND BACKGROUND

CERCLIS # TXD008083404

Category of removal: Time Critical

SiteID#06CN

CONCURRENCE:

ETERSEN L BROYLES -CASANOVA SUTTICE NANN PEYCKE

6RC-S 6RC-S
A. Site Description

1. Removal site evaluation

See attached original Action Memorandum.

2. Physical location

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 east of

the intersection of Highway 59 and Interstate Highway 10. Attachment 2 has a topographic

layout of the Site. This portion of Houston is known as the "Fifth Ward." The MDI fenced

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. There are in excess of 10,000 people within a

mile of the Site, including several hundred children attending the local elementary school.

3. Site characteristics

There are approximately 59 High Access Areas at the Site with lead contamination

greater than the established 500 ppm action level. These HAAs include the Blance Kelso Bruce

Elementary School, the Fifth Ward Multi-purpose Community Center, a church, and residential

properties. The properties were prioritized based on lead levels and presence of children on the

property. Priority One comprises of properties above 500 ppm lead with children less than 6

years old residing in these properties. Priority Two comprises of properties above 1000 ppm lead

with no children residing in these properties. Priority Three comprises of properties with 500 -

1000 ppm lead with no children less than 6 years old residing in these properties.

EPA's Response Action Contractor, Tetra Tech EM, Inc., conducted sampling activities

and found lead contamination is soil in residential areas of the Site. The area investigated was

determined by air modeling and includes areas within the 400 ppm isopleth. The soil in all the

HAAs exceeds 500 ppm and is as high as 2779 ppm.

4. Releases or threatened release into the environment of a hazardous substance, pollutant

or contaminant

See attached original Action Memorandum

5. NPL status

See attached original Action Memorandum.
6. Maps, Pictures and other graphic representations

Attachment 1 Original Action Memorandum

Attachment 2 MDI Site Topographic Map

B. Other Actions to Date

1. Previous actions

See original Action Memorandum.

2. Current actions

The EPA is currently performing an RI/FS at the Site. The purpose of the RI/FS is to

determine the nature and extent of contamination and to gather sufficient information about the

Site to support an informed risk management decision regarding which remedy is the most

appropriate for the Site. The EPA began remedial sampling activities at the Site in January 2003.

Removal Action currently being done at the site began on July 15, 2003. Following your

verbal approval of the ceiling increase and amended actions on September 8, 2003 , EPA began

work on the additional properties. Removal Action at most of Priority One and Priority Two

properties are complete. Removal Action is currently being done in Priority Three properties.

C. State and Local Authorities' Roles

1. State and local actions to date

See original Action Memorandum.

2. Potential for continued State/local response

See original Action Memorandum.

III. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT, AND

STATUTORY AND REGULATORY AUTHORITIES

A. Threats to Public Health or Welfare

The current conditions at the site meet the following factors which indicate that the site is

a threat to the public health, welfare and the environment and a removal action is appropriate
under §300.415(b)(2) of the National Contingency Plan. Any or all of these factors may be

present at a site yet any one of these factors may determine the appropriateness of a removal

action.

1. Exposure to Human Populations, Animals or the Food Chain, NCP Section

300.415 (b)(2)(i)

See original Action Memorandum.

2. Contaminants in Soil; NCP Section 300.415 (b)(2)(iv)

The soils in the HAAs exceed the action levels established to protect the human

population. Lead was found in concentrations up to 1,899 ppm. The soil at the Blance Kelso

Bruce Elementary School, the Fifth Ward Multi-purpose Community Center, a church, and

residential properties have lead contamination in soil exceeding the response action level.

3. Weather Conditions That May Cause Hazardous Substances or Pollutants or

Contaminants to Migrate or be Released. NCP Section 300.415 (b)(2)(v)

See original Action Memorandum.

4. Availability of Other Mechanisms, NCP Section 300.415 (b)(2)(vii)

See original Action Memorandum.

B. Threats to the Environment

See original Action Memorandum.

V. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances, pollutants or contaminants from

this Site, if not addressed by implementing the response action in this amendment, may present

an imminent and substantial endangerment to the public health, welfare, or the environment.
VI. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Proposed Action Description

See original Action Memorandum.

2. Contribution to remedial performance

See original Action Memorandum.

3. Description of alternative technologies

See original Action Memorandum.

4. Applicable or relevant and appropriate requirements

See original Action Memorandum.

5. Project schedule

The duration of activities is expected to be an additional two months (5 months total),

depending upon weather conditions and scheduling, and the availability of disposal contractors

and others.

B. Estimated Costs

Extramural Costs

Cleanup Contractor $850,000

START $600,000

Previous Costs $353,457.26

TOTAL, EXTRAMURAL COSTS $1,803,457.26
VII. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED

OR NOT TAKEN

See original Action Memorandum.

VIII. OUTSTANDING POLICY ISSUES

See original Action Memorandum.

IX. ENFORCEMENT

Also see original Action Memorandum.

(Direct Cost) + (Other Direct) + (42.14% of Total Direct {Indirect Cost}) = Estimated

EPA Cost for a Removal Action

($1,803,457.26) + ($180,346) + (42.14% x 1,983,803.26) = $2,819,777.95

Also see original Action Memorandum.

X. RECOMMENDATION

This decision document represents the selected removal action for the HAAs of the MDI

Superfund Site located in Houston, Harris County, Texas developed in accordance with

CERCLA as amended, and not inconsistent with the NCP. This also documents your verbal

approval for the ceiling increase and the amended action on September 8, 2003 This decision is

based on the Administrative Record for the Site.

Conditions at the Site meet the criteria as defined by 40 CFR Section 300.415(b)(2) of the

NCP for a removal. The total project ceiling will be $1,803,457.26.

APPROVED fyiX I UW^ W -} DATE

Attachments
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 6

1445 ROSS AVENUE, SUITE 1200

DALLAS, TX 75202-2733

r 0

MEMORANDUM

SUBJECT:

FROM:

TO:

THRU:

Request for a Removal Action and Waiver to the Twelve Month Statutory Limit

at the High Access Areas of the Many Diversified Interests, Inc. Superfund Site,

Houston, Harris County, Texas

Rafael Abrego Casnova, Remedial Project Manager

Stacey Bennett, Remedial Project Manager '

Gregory Fife, On-Scene Coordinato£2 (%U^

Site Response Section (6SF-R2) /

Myron O. Knudson, P.E., Director

Superfund Division (6SF)

-fr"Charles A. Gazda, Chief 0 (wlfaQ

Response and Prevention Branch (6SF-R)

L PURPOSE

This memorandum requests approval for a Removal Action pursuant to the

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as

amended, 42 U.S.C. §§9601 et seq., at the High Access Areas of the Many Diversified Interests,

Inc. Superfund Site ("MDI" or "Site") located in Houston, Harris County, Texas. The proposed

action involves the excavation and consolidation of contaminated soil in High Access Areas

(HAAs) of the Site.

This action meets the criteria for initiating a removal action under the National

Contingency Plan (NCP), 40 CFR §300.415. This action is expected to require less than $2

million to complete. Previous actions took place from November 2, 1998 to September 30, 1999.

Hence, the actions proposed in this memorandum will exceed the 12 month lapse time from the

date of the initial response. The Action Memorandum for the previous actions taken is in

Attachment 1.

Internet Address (URL) - http://www.epa.gov/earth1 r6/

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II. SITE CONDITIONS AND BACKGROUND

CERCLIS #1X0002288082

Category of removal: Time Critical

Site ID # 06FE

A. Site Description

1. Removal site evaluation

In 1926, the Texas Electric Steel Casting Company (TESCO) began operations as a metal

casting foundry. TESCO primarily manufactured specialty molded parts such as large wheels,

tracks, and mining equipment. The process area consisted of casting plants. Both plants

maintained separate sand systems, core ovens, mold makes, electric arc furnaces, pouring

facilities, and cleaning, annealing and heat treating process areas.

During the mid-1980s, the southern portion of the Site was leased to Can-Am Resource

Group (Can-Am). Can-Am conducted a spent catalyst recycling Operation using an experimental

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

chemical plants and refineries along the Houston Ship Channel. Byl988, Can-Am ceased

operations and abandoned the drums of spent catalyst on the Site.

In 1990, MDI bought the TESCO note form the Texas Commerce Bank. TESCO ceased

operations in February 1991, and MDI foreclosed on the property. MDI reopened as the San

Jacinto Foundry (SJF) on March 1, 1991. SJF continued operations until about June 1, 1992.

MDI filed for Chapter 7 Bankruptcy in the U.S. Bankruptcy Court for the Southern District of

Texas on May 1992. The on-site facilities were demolished as a salvage operation under order of

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

In 1998 and 1999, the Potentially Responsible Parties removed over 5,000 drums

containing waste materials, with EPA's oversight. The TCEQ conducted a removal and

restoration of 89 residential yards to the west and north of the MDI facility. The removal action

was conducted to remove surface soil with concentrations of lead that equaled or exceeded 500

parts per million (ppm) to reduce the exposure to lead.

2. Physical location

The MDI Site, located at 3.617 Baer Street in Houston, Harris County, Texas is an

abandoned foundry facility located approximately 2 miles east of downtown Houston and east of

the intersection of Highway 59 and Interstate Highway 10. Attachment 2 has a topographic

layout of the Site. This portion of Houston is known as the "Fifth Ward." The MDI fenced

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. There are in excess of 10,000 people within a

mile of the Site, including several hundred children attending the local elementary school.

3. Site characteristics

There are approximately 33 High Access Areas at the Site with lead contamination

greater than the established 500 ppm action level. These HAAs include the Blance Kelso Bruce

Elementary School, the Fifth Ward Multi-purpose Community Center, a church, and

approximately 30 residential properties. The school is located one block west of the MDI Site.

Attachment 3 has the layout of the elementary school.

EPA's Response Action Contractor, Tetra Tech EM, Inc., conducted sampling activities

and found lead contamination is soil in residential areas of the Site. The area investigated was

determined by air modeling and includes areas within the 400 ppm isopleth. The soil in all the

HAAs exceeds 500 ppm and is as high as 1899 ppm.

4. Releases or threatened release into the environment of a hazardous substance, pollutant

or contaminant

Lead is the primary contaminant of concern at the Site. Lead is a designated hazardous

substance as defined in Section 101(14) of CERCLA, 42 U.S.C.§9601(14), and 40 CFR §302.4.

Analytical data shows that lead at concentrations ranging from 511 to 1,899 ppm are present in

the soils (surface to 18 inches) at the Site. Lead is known to cause primarily neurological

damage in humans as the result of ingestion of the metal. Children are the most susceptible

group of people to the adverse effects of lead. Attachment 5 has the ToxFaQs for Lead.

5. NPL status

The "Final Rule" adding the Site to the National Priorities List was published in the

Federal Register on January 15, 1999. A Record of Decision, describing the chosen remedial

action, has not been issued for the Site; however, this proposed removal action will be consistent

with any subsequent remedial activities that may be taken at the Site.

6. Maps, Pictures and other graphic representations

Attachment 1 Previous Action Memorandum

Attachment 2 MDI Site Topographic Map

Attachment 3 Bruce Elementary School Layout

Attachment 4 Enforcement Attachment

Attachment 5 ToxFaQs for Lead
B. Other Actions to Date

1. Previous actions

In 1998 and 1999, the Potentially Responsible Parties removed over 5,000 drums

containing waste materials, with the EPA's oversight. The TCEQ completed a removal and

restoration in 1999 of 89 residential yards to the west and north of the Site. The removal action

was conducted to remove surface soil with concentrations of lead that equaled or exceeded 500

ppm to reduce the exposure to lead.

2. Current actions

i

The EPA is currently performing an RI/FS at the Site. The purpose of the RI/FS is to

determine the nature and extent of contamination and to gather sufficient information about the

Site to support an informed risk management decision regarding which remedy is the most

appropriate for the Site. The EPA began remedial sampling activities at the Site in January 2003.

C. State and Local Authorities' Roles

1. State and local actions to date

The State of Texas, through the TCEQ, was significantly involved in the previous

activities at the Site and continues to provided technical assistance during the RI/FS. The TCEQ

conducted a Preliminary Assessment in November 1995 and a Screening Site Inspection in

January 1996. Further, the TCEQ entered into a contract with EPA in March 31, 1999, to

conduct a Time-Critical Removal Action for the off-site portion of the Site under the State

Removal Pilot Program.

2. Potential for continued State/local response

The TCEQ will continue to provide technical assistance to the EPA during the RI/FS for

the Site. The Texas Department of Health is currently gathering data concerning the historical

and recent blood lead studies conducted at the Site and plans to provide information to the public

during the upcoming public meetings.

HI. THREATS TO PUBLIC HEALTH OR WELFARE OR THE ENVIRONMENT, AND

STATUTORY AND REGULATORY AUTHORITIES

A. Threats to Public Health or Welfare
The current conditions at the site meet the following factors which indicate that the site is

a threat to the public health, welfare and the environment and a removal action is appropriate

under §300.415(b)(2) of the National Contingency Plan. Any or all of these factors may be

present at a site yet any one of these factors may determine the appropriateness of a removal

action.

1. Exposure to Human Populations, Animals or the Food Chain, NCP Section

300.415 (b)(2)(i)

The soils in the HAAs of the Site contain lead concentrations that range from 511 to

1,899 ppm, based on recent data (additional data i being reviewed and validated). The EPA's

goal at lead sites is to attempt to limit exposure to soil lead levels such that a typical child or

group of similarly exposed children would have an estimated risk of no more than 5% of

exceeding a 10 |ig/dl blood lead level. The 500 ppm removal action level meets the 5%

benchmark, based on the experience gained from other lead sites in EPA Region 6. The Center

for Disease Control considers the 10 \ig/d\ blood lead level as elevated for young children. The

EPA believes that the lead in these soils is attributable to the historical foundry operations as well

as other possible sources. Exposure to animals and food chain receptors are not known at this

time. This information will be gathered during the ongoing RI/FS for the Site.

2. Contaminants in Soil; NCP Section 300.415 (b)(2)(iv)

The soils in the HAAs exceed the action levels established to protect the human

population. Lead was found in concentrations up to 1,899 ppm. The soil at the Blance Kelso

Bruce Elementary School, the Fifth Ward Multi-purpose Community Center, a church, and

approximately 30 residential properties have lead contamination in soil exceeding the response

action level.

3. Weather Conditions That May Cause Hazardous Substances or Pollutants or

Contaminants to Migrate or be Released. NCP Section 300.415 (b)(2)(v)

The area is subject to hurricanes, flooding and other severe weather. The severe flooding

events could easily transport contaminated soil within the residential areas.

4. Availability of Other Mechanisms, NCP Section 300.415 (b)(2)(vii)

At this time, there are no other mechanisms available to respond to the evacuation of soil

contaminated with lead.

B. Threats to the Environment
The proposed action to be taken during this response is designed to address a public

health threat resulting from the contaminated soils within the residential areas of the Site. These

actions, although not specifically designed to do so, will significantly reduce or mitigate any

potential ecological threats.

IV. CRITERIA FOR AN EXEMPTION FROM STATUTORY LIMITS

Consistency Exemption

Section 104 (c)(l)(c) limits Fund financed removal action to under $2 million and twelve-months

in duration unless the Agency determines that continued response action are otherwise

appropriate and consistent with the remedial action to be takea The actions proposed in this

memorandum is expected to require less than $2 million to complete. Previous actions look

place from November 2, 1998 to September 30, 1999. Hence, the actions proposed in this

memorandum will exceed the 12 month lapse time from the date of the initial response. Also, the

actions proposed within this Action Memorandum are appropriate, consistent, and do not hinder

any additional conceivable future remedial actions to be taken. The Site was added to the NPL

on January 15, 1999. The actions proposed in this Action Memorandum will prevent direct

human contact with the contaminated soils. All surface and subsurface contaminated soils will

be excavated and will be stored on-site. If this Action Memorandum is approved, actions will be

taken to remove contaminated soil from the High Access Areas. All these action have been

closely coordinated with the Remedial Project Managers and are consistent with the planned

remedial action for the site.

V. ENDANGERMENT DETERMINATION

Actual or threatened releases of hazardous substances, pollutants or contaminants from

this Site, if not addressed by implementing the response action selected in this Action

Memorandum, may present an imminent and substantial endangerment to the public healtli,

welfare, or the environment.

VI. PROPOSED ACTIONS AND ESTIMATED COSTS

A. Proposed Actions

1. Proposed Action Description

The proposed action for the Site involves the removal of soils contaminated with lead

from the HAAs at the Site. Soil with lead contamination greater than 500 ppm will be excavated.

The areas will be backfilled to proper grade and sodded. The contaminated soil will be placed at

the MDI Site. Sidewalks, driveways, and other such structures will be replaced with comparable

structures according to local codes. Other items removed or damaged as a result of the removal

action will be replaced or compensation will be given in accordance with EPA policy at the
appraised value.

It is critical to conduct the action at the Blance Kelso Bruce Elementary School in July to

coincide with school closing. Other activities will be conducted to facilitate interaction with the

public.

2. Contribution to remedial performance

The proposed action is consistent with any future remedial response at this Site since the

response action constitutes contaminant removal.

3. Description of alternative technologies

There are no alternative technologies that could feasibly be applied.

<

4. Applicable or relevant and appropriate requirements

This removal action will be conducted to eliminate the actual or potential release of a

hazardous substance, pollutant, or contaminant to the environment, pursuant to CERCLA, 42

U.S.C. § 9601 et seq., and in a manner consistent with the National Contingency Plan, 40 CFR.

Part 300, as required at 33 U.S.C. § 1321(c)(2) and 42 U.S.C. § 9605. Pursuant to 40 CFR Part

300.415(1), fund-financed removal actions under CERCLA § 104 and removal actions pursuant

to CERCLA § 106 shall, to the extent practicable considering the exigencies of the situation,

attain the applicable or relevant and appropriate requirements under Federal environmental law.

If consolidation and off-site disposal are the principal elements of this removal action,

RCRA waste analysis requirements found at 40 CFR §§ 261.20 and 261.30, RCRA manifesting

requirements found at 40 CFR § 262.20, and RCRA packaging and labeling requirements found

at 40 CFR § 262.30 are deemed to be appropriate requirements for this removal action.

Applicable RCRA requirements for landfill closure, 40 CFR § 264.Ill, Subpart G, may apply,

which specify a cap with a permeability less than or equal to the permeability of any bottom liner

or natural sub-soils present at the plant site. In addition, applicable specific closure requirements

which are provided for surface impoundments, 40 CFR § 264.228, Subpart K, and applicable

requirements for landfills, 40 CFR § 264.310, Subpart N may also apply. Post-closure and

monitoring requirements may be applicable, 40 CFR § 264.117(a)(l), as well as RCRA

requirements for location of a Transportation, Storage or Disposal facility in a 100-year flood

plain, 40 CFR § 264.18 and 40 CFR 6, Appendix A. The selected removal action does not

trigger placement under the RCRA Land Disposal Restrictions, since all waste will be moved

only within the area of contamination or RCRA unit, 55 Fed. Reg. 8760 (March 8, 1990).

Ambient air quality standards at 40 CFR 50 will be used, as applicable, to protect the quality of

air during the implementation of the action.
5. Project schedule

The duration of activities is expected to be three months, depending upon weather

conditions and scheduling, and the availability of disposal contractors and others. The response

at the school must be conducted in July and coordinated with the principal.

B. Estimated Costs

Extramural Costs

Cleanup Contractor $600,000

START $300,000

Previous Costs j...$353,457.26

TOTAL, EXTRAMURAL COSTS $1,253,457.26

VII. EXPECTED CHANGE IN THE SITUATION SHOULD ACTION BE DELAYED

OR NOT TAKEN

Should the actions described in this Action Memorandum be delayed or not taken, the

soils contaminated with lead will continue to contribute to the direct exposure of children and

adults. The soils in the HAAs of the Site contain lead concentrations that range from 511 to

1,899 ppm, based on recent data (additional data is being reviewed and validated).

VIII. OUTSTANDING POLICY ISSUES

There are no outstanding policy issues associated with this removal action or the Site.

IX. ENFORCEMENT

For administrative purposes, information concerning confidential enforcement strategy

for this site is contained in the Enforcement Confidential Attachment 4.

(Direct Cost) + (Other Direct) + (42.14% of Total Direct {Indirect Cost}) = Estimated

EPA Cost for a Removal Action

($1,253,457.26) + ($125,346) + (42.14% x 1,378,803.26) = $1,959,830.95

Direct costs include direct extramural costs and direct intramural costs. Indirect costs are

calculated based on an estimated indirect cost rate expressed as a percentage of site-specific
direct costs, consistent with the full cost accounting methodology effective October 2, 2002.

These estimates do not include pre-judgement interest, do not take into account other

enforcement costs, including Department of Justice costs, and may be adjusted during the course

of a removal action. The estimates are for illustrative purposes only, and their use is not intended

to create any rights for responsible parties. Neither the lack of a total cost estimate nor the

deviation of actual total costs from this estimate will affect the United States' right to cost

recovery.

X. RECOMMENDATION

This decision document represents the selected removal action for the HAAs of the MDI

Superfund Site located in Houston, Harris County, Texas developed in accordance with

CERCLA as amended, and not inconsistent with the NCP. This decision is based on the

Administrative Record for the Site.

Conditions at the Site meet the criteria as defined by 40 CFR Section 300.415(b)(2) of the

NCP for a removal, and I recommend your approval of the proposed removal action. The total

project ceiling will be $1,253,457.26.

APPROVED ^/"Tr^lS, /^^Kz^£S- DATE
SEQUATES TO 400 PPM LEAD IN SOIL

I