FINALSITE MANAGEMENT PLAN

FORREMEDIAL INVESTIGATION AND FEASIBILITY STUDY

MANY DIVERSIFIED INTERESTS, INC.HOUSTON, HARRIS COUNTY, TEXAS

EPAJDNo.: TXD008083404

Prepared for

U.S. Environmental Protection Agency Region 61445 Ross Avenue

Dallas, Texas 75202-2733

Work Assignment No.EPA RegionDate PreparedContract No.Prepared ByTetra Tech Project ManagerTelephoneEPA Work Assignment ManagerTelephone ''

107-RICO-06CN6August 29, 200268-W6-0037Tetra Tech EM Inc.Candy Friday(713)520-7667Stacey Bennett(214)665-6729

917234

017789

CONTENTS

Section Page

ACRONYMS AND ABBREVIATIONS.................................................................................................... iii

1.0 INTRODUCTION......................................™

2.0 BACKGROUND..............................................................................................................................1

3.0 SECURITY OBJECTIVES..............................................................................................................5

4.0 SECURITY MEASURES................................................................................................................5

4.1 FENCES..............................................................................................................................64.2 SITE ACCESS CONTROLS..............................................................................................^4.3 SIGNS .................................................................................................................................64.4 NOTIFICATION.................................................................................................................?

5.0 SUPPORT AREAS ..........................................................................................................................7

5.1 GENERAL SITE SUPPORT AREA...................................................................................75.2 LIMITED ACCESS SITE SUPPORT AREA.....................................................................7

6.0 RESTRICTED ZONES....................................................................................................................8

6.1 CONTAMINATION REDUCTION ZONE........................................................................86.2 EXCLUSION ZONE...........................................................................................................8

6.2.1 Entry.......................................................................................................................86.2.2 Exit ........................................................................................................................86.2.3 Emergency Exit ......................................................................................................96.2.4 Zone Boundaries.....................................................................................................9

7.0 VISITORS........................................................................................................................................9

8.0 EMERGENCY ACTIONS .............................................................................................................10

9.0 EMERGENCY ADDRESS LIST...................................................................................................10

10.0 REFERENCES...............................................................................................................................^

017790

FIGURES

Figure

1 SITE LOCATION MAP...................................................................................................................2

2 SITE LAYOUT MAP.......................................................................................................................3

017791

ACRONYMS AND ABBREVIATIONS

ACM Asbestos-containing materialCan-Am Can-Am Resources Group, Inc.CRZ Contamination reduction zoneEDS Equipment decontamination stationEPA U.S. Environmental Protection AgencyHASP Health and safety planMDI Many Diversified Interests, Inc.PDS Personnel decontamination stationRI/FS Remedial investigation/feasibility studySHSO Site health and safety officerS JF San Jacinto FoundrySMP Site management planTESCO Texas Electrical Steel Casting CompanyTetra Tech Tetra Tech EM Inc.TNRCC Texas Natural Resource Conservation Commission

in

017792

1.0 INTRODUCTION

Tetra Tech EM Inc. (Tetra Tech), received Work Assignment No. 107-RICO-06CN, from the

U.S. Environmental Protection Agency (EPA), under Response Action Contract No. 68-W6-0037. The

initial work assignment form was signed by the EPA contracting officer on April 5, 2002, and

acknowledged by Tetra Tech on April 15, 2002. Under this work assignment, Tetra Tech is authorized to

perform a remedial investigation and feasibility study (RI/FS) for the Many Diversified Interests, Inc.

(MDI) site, located in Houston, Texas. Tetra Tech prepared this site management plan (SMP) in

accordance with the objectives of the work assignment form. The purpose of the SMP is to provide the

guidelines for handling access, security, contingency procedures, and management responsibilities.

The primary purposes of site security controls are to establish the hazardous area perimeter, reduce

contaminant transport into clean areas, prevent access or exposure to hazardous materials by unauthorized

persons, and protect materials and equipment.

The MDI site will include three separate work zones. Site work zones will include (1) site support areas,

(2) contamination reduction zones (CRZ), and (3) exclusion zones. This plan will discuss entry and exit

procedures to and from these zones.

The contractor (Tetra Tech) is ultimately responsible for the security of the sampling equipment, vehicles,

and other on-site equipment.

2.0 BACKGROUND

The MDI site is a former foundry site that occupies approximately 36 acres in an area of mixed industrialand residential land use, approximately 2 miles east of downtown Houston, Texas, and 1/4 mile south of

Interstate Highway 10. The MDI site is located at 3617 Baer Street, Houston, Harris County, Texas. The

site is bound by Hare Street on the north side. The National Vinegar Company is located on the east side

of the site. MDI is bound on the south by the old Texas and New Orleans Railroad right-of-way and on the

west by Bringhurst Street. Baer and Gillespie Streets both terminate at the MDI property boundary.

Figure 1 provides a topographical site location map, and Figure 2 provides a site layout plan of the facility.

017793

0 1000 2000

SCALE IN FEET

SOURCE: MODIFIED FROM USGS, SETTEGAST,TEXAS QUADRANGLE, 1982

MANY DIVERSIFIED INTERESTS, INC.HOUSTON, TEXAS

FIGURE 1SITE LOCATION MAP

PREPARED FOR:

4»EPA T»M T«oh ai ho.

017794

INTERSTATE HIGHWAY-10 IS LOCATED 1 BLOCK NORTH OF THE SITE

APPROXIMATE LOCATIONFORMER INGRAHAM CULLY

TO BUFFALO BAYOU

SCHOOLPARKING LOT

PREVAILINGDIRECTION

GOODWILL MISSIONARYBAPTIST CHURCH

CONCRETE PADWASTE OIL

ASBESTOSDEBRIS

BLANCHE K. BRUCEELEMENTARY SCHOOL

EPASTAGING

AREA NATIONAL VINEGARCOMPANY

HL&PBRINGHURSTSUBSTATION

^ .——-V-—————£——GILLESPIE STREET (ABANDONED BY CITY OF HOUSTON)

in———————i——to———————A—————GILLESPIE STREET

MOLDINO'S AND CASTINGSON CONCRETE PADS

STOCKPILEDFOUNDRY SAND

STORMWATERGRATEPATTERN VAULT

AREA

MDJI PROPERW BOUNDARY

GREATER MT. OLIVEBAPTIST CHURCH

AREAS OF CONCERN: (AOC)m AOC-l. LABORATORIES AND CHEMICAL STORAGE AREASm AOC-2 TRANSFORMERS AND CAPACITORSITI AOC-3. DRUM STORAGE AREAS, COMPRESSOR STATIONS, WAREHOUSES, PAINT AREAS, MAINTENANCE, AND MECHANIC SHOPSFT! AOC-4. DUST COLLECTORS/BAGHOUSES, SHOT BLAST, AND DEBRIS PILESm AOC-5. QUENCH TANKS AND OIL PITSm AOC-6. STORAGE TANKS

m AOC-7. SLOWDOWN AREA

ITI AOC-8. COOLING TOWERSFT! AOC-9. FILL AREAriOl AOC-10. CORE SAND AND SLAGriTI AOC-11. CORE OVENS AND ASBESTOS AREAS1721 Aoc-i2. RADIATION SERVICE AREA03 AOC-13. PONDSSEE FIGURE 2 FOR AOC 9

0 100 200

SCALE IN FEET

MANY DIVERSIFIED INTERESTS, INC.HOUSTON, TEXAS

FIGURE 2SITE LAYOUT MAP

PREPARED FOR: BY:

&EPA Tetro Tech EM Inc.

017795

The estimated urban population near MDI is approximately 50,000. Residential areas are adjacent to the

east, west, and north sides of MDI. Blanche Kelso Bruce Elementary School is located adjacent to thewest side of MDI. Industrial areas are adjacent to the south side of MDI.

MDI is located in the Gulf Coastal Plain of Southeast Texas. Three major regional aquifers in Harris

County contain fresh to slightly saline waters. These include the Jasper, Chicot, and Evangeline Aquifers.Approximately 0.5 miles north of MDI is Buffalo Bayou, which becomes the Houston Ship Channel 3.1miles further downstream.

Steel casting operations began at the site in 1926 under the company name Texas Electric Steel Casting

Company (TESCO). Primary operations included manufacturing of specialty molds and casting specialty

steel parts. During the mid 1980s, a portion of the property was leased to Can-Am Resources Group, Inc.

(Can-Am). Can-Am developed an experimental process to recycle spent catalyst material. During this

time, it was reported that Can-Am purchased between 2,000 and 4,000 drums of spent catalyst material

from refineries and chemical plants along the Houston Ship Channel. The drums were stored on site until

1988, when Can-Am ceased recycling operations. These drums were left abandoned on site (Texas

Natural Resource Conservation Commission [TNRCC] 1996).

In February 1991, TESCO ceased operations. MDI foreclosed on the property, and on March 1, 1992, the

facility reopened as San Jacinto Foundry (SJF), a subsidiary of MDI. SJF operated the facility until about

June 1, 1992, when operations ceased and the site became inactive. On May 20, 1992, MDI filed for

Chapter 7 bankruptcy (TNRCC 1996).

Based on the former foundry s operations that began in 1926 and ended in the 1990s, the primary principal

pollutants at the MDI site include arsenic, chromium, cobalt, lead, copper, and nickel in the soil. TNRCC

identified a total of 86 residential properties that contained contaminated soils at levels that warranted a

cleanup action. From 1998 through May 1999, the TNRCC performed removal and restoration of these

86 residential yards, to prevent children and adults from being exposed to lead.

The majority of the facilities consisted of two green sand/air set foundries. The operation facilities were

demolished in 1995 under order of a U.S. Bankruptcy Court (TNRCC 1996). Current significant site

features include (1) various debris piles throughout the property, (2) two surface ponds, (3) a landfill, and

017796

(4) several large slabs of concrete and asphalt (TNRCC 1996).

While conducing a site reconnaissance visit on April 17, 2002, Tetra Tech made several observations.

There are numerous concrete- and asphalt-covered areas on site. Impervious surfaces cover approximately

60 percent of the site. Tetra Tech observed two quench oil tanks and one vat in the former Foundry

Building Area. Tetra Tech also observed suspect asbestos-containing material (ACM) boards stockpiled in

the Pattern Vault Area and a large transformer on the northwest corner of property. The property

contained a four-bay orange metal building, an old administrative building, and a partially destroyed

electrical building.

3.0 SECURITY OBJECTIVES

The objectives of implementing site security measures are as follows:

• Prevent and detect theft, sabotage, vandalism, and arson

• Prevent unauthorized people from entering the site and becoming injured

• Prevent unauthorized people from entering the site and removing equipment or hazardoussubstances

• Prevent unauthorized people from taking actions at the site that might exacerbate theenvironmental problem or interfere with the investigation

• Protect file information

• Avoid unauthorized dumping

4.0 SECURITY MEASURES

Security measures at the site may include fences, site access controls, signs, and police notification

procedures. Additionally, Tetra Teeh will subcontract the services of a local security agency to provide

security at the facility during off-duty hours, weekends, and holidays.

017797

4.1 FENCES

The 36-acre site is bound by a chain-link fence on the west, north, and east and by a low brick wall in part

along the southern property boundary. Access to the site can be gamed through locked gates on the west

side of the property where Baer and Gillespie Streets terminate at the MDI property boundary. However,

the metal chain-link fence is in poor condition, with several gaps in the fencing mesh, and the low brick

wall is crumbling in places; therefore, access is not restricted at this time (TNRCC 1996).

4.2 SITE ACCESS CONTROLS

At night and whenever work is not being performed on site, the facility gates will be locked. Storable

tools, instruments, and equipment will be collected at the end of the shift or work day, and stored in drums

or storage cabinets on site. All other equipment will be stored in the general support area. The site

manager will check the site on a regular basis.

Restricted access will be maintained at the main gate entrance, and the site manager or the site health and

safety officer (SHSO) will be responsible for controlling unauthorized entry during work hours. Should

persons attempt unauthorized site entry, the site manager will be responsible for taking appropriate action.

The site manager or SHSO will be responsible for logging in equipment, material, visitors to the site,

vehicles, trucks, and drill rigs arriving and departing the site. Security services will be subcontracted from

a local contractor for off-duty hours, weekends, and holidays. All visitors will be required to sign an entry

and exit log when entering and exiting the facility.

4.3 SIGNS

The site manager will post signs at the perimeter of the site at 500-foot intervals along the unfenced line.

The signs will indicate that a hazardous area is ahead and that unauthorized entry is prohibited. These

signs shall state: (1) DANGER, (2) UNAUTHORIZED PERSONNEL KEEP OUT, or (3) WARNING!

HAZARDOUS WORK AREA DO NOT ENTER WITHOUT AUTHORIZATION. Signs shall also be

be posted directing visitors to the authorized main entrance for check-in. All signs will be in English and

Spanish text.

017798

4.4 NOTIFICATION

The following local police, fire, and city management officials will be notified when field operations begin

at the site:

• Houston Police Department4300 Lyons Avenue, Houston, TX 77020(713)672-5890

• Houston Fire Department410 Bagby Street, Houston, TX 77002(713)247-5000

• City Management Personnel: TBD

5.0 SUPPORT AREAS

Support areas at the MDI site will include the general site support area and the limited access site support

area.

5.1 GENERAL SITE SUPPORT AREA

The uncontaminated general site support area or "clean zone" will be located at the preexisting area

designated for that activity during previous site removal actions. The area will be used for parking

vehicles, command post location and temporary offices, sanitation facilities, and receipt of deliveries.Upon arrival, personnel entering the general site support area will be directed to sign a site entry and exit

log. Personnel entering this area may include sampling personnel, other subcontractors, regulators, andauthorized visitors.

5.2 LIMITED ACCESS SITE SUPPORT AREA

The limited access site support area will be located on a boundary of the site near the CRZ. There will be

one controlled entry and exit point from the limited access site support area to the CRZ.

017799

6.0 RESTRICTED ZONES

The exclusion zone and the CRZ are collectively referred to as the restricted zones. These areas are

classified as restricted because they are known to be, or may potentially be, contaminated.

6.1 CONTAMINATION REDUCTION ZONE

The CRZ is the area of transition between the exclusion zone and the support zone. The CRZ includes thepersonnel decontamination station (PDS) and equipment decontamination station (EDS). Personnel mustenter and exit the exclusion zone through the PDS area. Before leaving the CRZ for demobilization,

equipment will be decontaminated in the EDS before it is moved to the limited access or general site

support area.

6.2 EXCLUSION ZONE

The exclusion zone is the contaminated area. The exclusion zone requires that certain procedures be

followed for zone entry, exit, emergency exit, and zone boundaries.

6.2.1 Entry

Entry to the exclusion zone will be made through the CRZ. Zones will be clearly separated and marked as

described in the health and safety plan (HASP) to ensure that no one unknowingly enters a zone.

6.2.2 Exit

Personnel and equipment'must^be decontaminated before exiting the exclusion zone. The PDS shall have1 : ' . •. - i'.1 ' " ;

facilities for a water or liquid irinse, and a~briish for personnel and equipment decontamination.

017800

6.2.3 Emergency Exit

The main entrance will be used as the emergency exit and will be kept clear of obstructions during all field

activities. The gate at the main exit will be kept unlocked during field activities and will be locked at the

end of each day by the site manager when all personnel have left the site. The site manager and SHSO will

have keys to the main gate.

6.2.4 Zone Boundaries

As work progresses, the exclusion zones may change or decrease in size; this determination shall be made

by the SHSO. Site personnel shall be informed of changes in the size and location of the exclusion zone.

7.0 VISITORS

The following procedures will be followed for all site visitors.

• Site personnel and visitors shall be required to log in at the main entrance.

• Visitors must be approved by the project manager, site manager, EPA, or state project

representative.

• Visitors shall park in the visitor's parking lot.

• Visitors will be required to read and sign the Tetra Tech HASP before entering the site.

• Each visitor will be required to wear visitor's identification, which will be provided at the

site support area.• Visitors will be informed about the applicable procedures and location of hard hats,

glasses, protective 61othirig, and boots, as well as procedures for entry. Visitors must wear

all required equipment when entering hazardous areas.;!

• In addition to'the above requirements, visitors must provide evidence of completion of

Occupational!Safety and Health Administration-approved 40-hour health and safetytraining before entering-hazardous areas.

• Visitors mustbe escorted at all times, except EPA and state employees and

representatives, who may proceed without escorts.

017801

8.0 EMERGENCY ACTIONS

The site manager will coordinate all local, state, and federal law enforcement activities at the site and will

coordinate with the State Highway Patrol and emergency units, fire department, and paramedics for on-site

emergencies. Smoke, fires, explosions, releases of air contaminants, flooding, and other emergency

conditions observed shall be reported to the site manager and, if necessary, to emergency agencies.

9.0 EMERGENCY ADDRESS LIST

Contact information for hospital services, ambulance service, law enforcement, and the local fire station is

listed in the HASP (Tetra Tech 2002).

10.0 REFERENCES

Tetra Tech EM Inc. 2002. Health and Safety Plan for Remedial Investigation and Feasibility Study, ManyDiversified Interests Site, Houston, Texas. May.

Texas Natural Resource Conservation Commission (TNRCC). 1996. Screening Site Inspection Report,Volume I of m, MDI Site. Houston, Texas. TXD008083404. TNRCC Region 12 - RegionSuperfund Staff. July.

U.S. Geological Survey (USGS). 1982. Settegast, Texas Quadrangle Map.

10

017802