White Paper Chromates PDF

White book
Monitoring of risk containment actions, site preparation and

remediation of the property located on Francisco I Street. Wood no.
30, Colonia Lechería, Tultitlán, State of Mexico
(Former Chromate Factory of Mexico)
GOVERNMENT
FEDERAL
www.semarnat.gob.mx Live better

Protecting the environment we build the foundations of a prosperous Mexico for you and your
family
SECRETARY OF ENVIRONMENT AND
NATURAL RESOURCES
WHITE BOOK
FOLLOW-UP OF RISK CONTAINMENT ACTIONS,
SITE PREPARATION AND PROPERTY REMEDIATION
LOCATED ON FRANCISCO I STREET. WOOD NO. 30, COLONY
DAIRY, TULTITLÁN, STATE OF MEXICO (EX FACTORY OF
CHROMATES FROM MEXICO)
GENERAL DIRECTORATE OF INTEGRAL MANAGEMENT OF MATERIALS AND

RISKY ACTIVITIES
10/31/2012
This White Paper chronologically describes the conceptual, legal, budgetary, administrative, operational and monitoring
actions of the project “Monitoring the Management of the successful case of Risk Containment Actions, Site Preparation and
Remediation of the property located in Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico (former
Cromatos de México factory)”
Index
Page
White book..............................................................................................................................1
SECRETARY OF ENVIRONMENT AND NATURAL RESOURCES...........................3
GENERAL DIRECTORATE OF INTEGRAL MANAGEMENT OF MATERIALS
AND RISKY ACTIVITIES 10/31/2012....................................................................3
Index.................................................................................................................................4
1 .- PRESENTATION..........................................................................................1
Eng. Eduardo Enrique González Hernández........................................................2
1.1. - NAME OF THE PROGRAM......................................................................3
1.2. - DOCUMENTED VALIDITY PERIOD......................................................3
1.3. - GEOGRAPHICAL LOCATION.................................................................3
I.5.- ADMINISTRATIVE UNIT............................................................................10
II .- LEGAL FOUNDATION AND OBJECTIVE OF THE WHITE PAPER. . .11
11.1. - LEGAL BASIS......................................................................................11
11.2. - PURPOSE OF THE WHITE PAPER....................................................11
III .- BACKGROUND......................................................................................11
V .1.- Internal Regulations of the Ministry of Environment and Natural
Resources................................................................................................................22
IV.2.- General Law for the Prevention and Comprehensive Management of Waste
(LGPGIR)...............................................................................................................22
IV.3.- Regulations of the LGPGIR.........................................................................24
VII .1.- National Development Plan (2007-2012)..............................................25
VIII .2.- Environment and Natural Resources Sector Program (2007-2012)......26
VI.- EXECUTIVE SYNTHESIS OF THE PROGRAM.........................................26
VII.1.- Work program.............................................................................................30
VII.2.- Budget and authorized spending schedule..................................................30
VII.3.9.- Terms of reference ^^^^^^^^^^^ ^^^^^^^-Economic of Chromium
Removal Technologies for remediation of the Cuautitlán Aquifer-^^^^^^^^^......50
VII.4.- Documentation supporting the application of the Resources......................53
VII.4.1.- Investment portfolios authorized by the SHCP and budget sufficiency. .53
VII.4.3.- Agreements and/or contracts concluded..................................................58
VII.4.4.- Records of the budget exercises carried out.............................................65
VII.4.5.- Investment Release Letters......................................................................69
VII .4.6.- Comparative table of the total authorized budget vs. exercised budget.
70
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5RQRNISO[U >2"5?.........................................................................................................71
2NRJMYMRJKL +MKLNOPIQL @! 2NRJMYMRJKL "\RNSOQL.................................71
Resources from the Biodiversity Fund for the concept of CONABIO Environmental
Remediations Authorized Budget Vs Exercised Budget...........................................72
Authorized budget item 33104 "Studies and consultancies"......................................73
IX .1.- Institutional Reports..............................................................................74
VIII.4.- Attention to observations...........................................................................80
VIII.5.- Actions carried out to correct or improve its execution.............................85
IX.1.- Compliance with the objectives and goals of the Program..........................88
IX.2.- Results obtained and benefits provided to the target population, in terms of
the works executed..................................................................................................89
X.- FINAL REPORT OF THE HEAD OF THE DGGIMAR................................93
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LXLUOI ,RSTRNbI1 (MXKOKXdU1 "JKIQL QR &efOSL`.................................94
GLOSSARY OF TERMS.......................................................................................97
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!"!#$%& (#)#*$+(%,&.....................................................................................................99
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....................................................................................................................................99
!"#$"%&$'& )" *")+, &*-+".%" / $"#0$!,! .&%0%$&1"!..............................................118
1%$",,%/0 *"0"$&2 1" *"3)%/0 %0)"*$&2 1" !&)"$%&2"3 4 &,)%A%1&1"3 $
%"3*#3&3................................................................................................................118
!"#$"%&$'& )" *")+, &*-+".%" / $"#0$!,! .&%0%$&1"!..............................................148
/%$",,%0- *"-"$&1 /" *".)%0- %-)"*$&1 /" !&)"$%&1". ? &,)%@%/&/". $
%".*#.&....................................................................................................................148
Cr CONTENT IN SOIL A 3.0M DEPTH...............................................................154
Cr CONTENT IN SOIL A 6.0M DEPTH....................................................................154
I.
II. REGULATORY FRAMEWORK APPLICABLE TO THE ACTIONS CARRIED OUT 23
DURING THE IMPLEMENTATION OF THE PROGRAM
IV.1.- Internal Regulations of the Secretariat of the Environment and 23 Natural Resources
IV.2.- General Law for the Prevention and Comprehensive Management of Waste 24
(LGPGIR)
White book..............................................................................................................................1
Index.................................................................................................................................4
1 .- PRESENTATION..........................................................................................1
11.1. - LEGAL BASIS......................................................................................11
III .- BACKGROUND......................................................................................11
Resources................................................................................................................22
(LGPGIR)...............................................................................................................22
VII.1.- Work program.............................................................................................30
70
5RQRNISO[U >2"5?.........................................................................................................71
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!"!#$%& (#)#*$+(%,&.....................................................................................................99
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/"0 3$"/%#......................................................................................................................99
/%$",,%1- *"-"$&0 /" *".)%1- %-)"*$&0 /" !&)"$%&0". 4 &,)%5%/&/". $%".*#.&.
....................................................................................................................................99
!"#$"%&$'& )" *")+, &*-+".%" / $"#0$!,! .&%0%$&1"!..............................................118
1%$",,%/0 *"0"$&2 1" *"3)%/0 %0)"*$&2 1" !&)"$%&2"3 4 &,)%A%1&1"3 $
%"3*#3&3................................................................................................................118
!"#$"%&$'& )" *")+, &*-+".%" / $"#0$!,! .&%0%$&1"!..............................................148
/%$",,%0- *"-"$&1 /" *".)%0- %-)"*$&1 /" !&)"$%&1". ? &,)%@%/&/". $
%".*#.&....................................................................................................................148
V
V II.3.1.- Executive project for “Actions for Containment
of the risk and Preparation of the site for the execution of the Remediation
Works 35 that are essential to reduce the risks to human health and the
environment, in the former Cromatos de México factory, located in the
Municipality of Tultitlán, State of Mexico".
V II.3.2.- Executive project for the “Risk containment actions and site preparation in
the demolition works of cell C1 and part of cell C2, of the property of the former
Cromatos de México de la Colonia factory Lechería, in the Municipality of Tultitlán,
State of Mexico.”
V II.3.3.- Executive project for the “Actions for Risk Containment and Preparation of
the Chromate Site for its 39 Remediation. Complementary Works on the Property and
in the remaining part of cell C2.”
V II.3.4.- Executive project for the “Engineering Works for the Remediation of the
contaminated soil on the property located at 41 Francisco I Street. Madero No. 30, in
the Lechería Colony, Tultitlán, State of Mexico.”
V II.3.5.- Project executive “Drilling of 12 wells
exploratory and extraction for the remediation of the 45 Cuautitlán-Pachuca aquifer
locally Contaminated by chromium, Tultitlán, State of Mexico.”
V II.3.6.- Terms of reference “Sampling work to update the magnitude of
contamination of the property located at 48 Francisco I Street. Madero No. 30,
Colonia Lechería, Tultitlán, State of Mexico” with an area of 35,344.13m 2 ”.
V II.3.7.- Terms of reference “Preparation of a study of
Environmental Risk Assessment (ERA) of the property located at 49 Francisco I
Street. Madero No. 30, Colonia Lechería, Tutitlán, State of Mexico.”
V II.3.8.- Terms of reference “Executive project of the works for the remediation of
contaminated soil on the property located 50 on Francisco I Street. Madero No. 30
Colonia Lechería, Tutltilán, State of Mexico.”
V II.3.9.- Terms of reference “Technical-Economic Evaluation of Chromium Removal
Technologies for remediation of the 52 Cuautitlán-Pachuca Aquifer”.
V II.3.10.- Technical Annex “Protection of four exploratory-extraction wells for the
remediation of the Cuautitlán-Pachuca Aquifer locally contaminated by chromium; 53
demolition-construction of perimeter sidewalks on the property located on Francisco I
Street. Madero No. 30 Colonia Lechería, Tultitlán, State of Mexico and preparation of
signs.
White book..............................................................................................................................1
Index.................................................................................................................................4
1 .- PRESENTATION..........................................................................................1
11.1. - LEGAL BASIS......................................................................................11
III .- BACKGROUND......................................................................................11
Resources................................................................................................................22
(LGPGIR)...............................................................................................................22
VII.1.- Work program.............................................................................................30
70
5RQRNISO[U >2"5?.........................................................................................................71
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!"!#$%& (#)#*$+(%,&.....................................................................................................99
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/"0 3$"/%#......................................................................................................................99
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....................................................................................................................................99
!"#$"%&$'& )" *")+, &*-+".%" / $"#0$!,! .&%0%$&1"!..............................................118
1%$",,%/0 *"0"$&2 1" *"3)%/0 %0)"*$&2 1" !&)"$%&2"3 4 &,)%A%1&1"3 $
%"3*#3&3................................................................................................................118
!"#$"%&$'& )" *")+, &*-+".%" / $"#0$!,! .&%0%$&1"!..............................................148
/%$",,%0- *"-"$&1 /" *".)%0- %-)"*$&1 /" !&)"$%&1". ? &,)%@%/&/". $
%".*#.&....................................................................................................................148
V
VII.4.5.- Investment Release Letters 72
VII .4.6.- Comparative table of the total authorized budget vs. 73 exercised
budget
White book..............................................................................................................................1
Index.................................................................................................................................4
1 .- PRESENTATION..........................................................................................1
11.1. - LEGAL BASIS......................................................................................11
III .- BACKGROUND......................................................................................11
Resources................................................................................................................22
(LGPGIR)...............................................................................................................22
VII.1.- Work program.............................................................................................30
70
5RQRNISO[U >2"5?.........................................................................................................71
!"#$"%&$'& )" *")+, &*-+".%" / $"#0$!,! .&%0%$&1"!................................................99
!"!#$%& (#)#*$+(%,&.....................................................................................................99
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/"0 3$"/%#......................................................................................................................99
/%$",,%1- *"-"$&0 /" *".)%1- %-)"*$&0 /" !&)"$%&0". 4 &,)%5%/&/". $%".*#.&.
....................................................................................................................................99
!"#$"%&$'& )" *")+, &*-+".%" / $"#0$!,! .&%0%$&1"!..............................................118
1%$",,%/0 *"0"$&2 1" *"3)%/0 %0)"*$&2 1" !&)"$%&2"3 4 &,)%A%1&1"3 $
%"3*#3&3................................................................................................................118
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/%$",,%0- *"-"$&1 /" *".)%0- %-)"*$&1 /" !&)"$%&1". ? &,)%@%/&/". $
%".*#.&....................................................................................................................148
V
V III.3.- Inspection visit to the execution of the works of the National Public Tender
00016057-002-11 "Drilling of 12 exploratory and extraction wells for the
remediation of the Cuautilán-Pachuca aquifer locally contaminated by
chromium, State of Tultitlán" and National Public Tender 00016057-003-11
^^^^^^^^^ ^^ ^^^^^vision for the drilling of 12 exploratory and extraction wells for
the remediation of the Cuautitlán-Pachuca aquifer locally contaminated by
chromium, State of Tultitlán.”
White book..............................................................................................................................1
Index.................................................................................................................................4
1 .- PRESENTATION..........................................................................................1
11.1. - LEGAL BASIS......................................................................................11
III .- BACKGROUND......................................................................................11
Resources................................................................................................................22
(LGPGIR)...............................................................................................................22
VII.1.- Work program.............................................................................................30
70
5RQRNISO[U >2"5?.........................................................................................................71
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!"!#$%& (#)#*$+(%,&.....................................................................................................99
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/"0 3$"/%#......................................................................................................................99
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....................................................................................................................................99
!"#$"%&$'& )" *")+, &*-+".%" / $"#0$!,! .&%0%$&1"!..............................................118
1%$",,%/0 *"0"$&2 1" *"3)%/0 %0)"*$&2 1" !&)"$%&2"3 4 &,)%A%1&1"3 $
%"3*#3&3................................................................................................................118
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%".*#.&....................................................................................................................148
property remediation
Photographic Memory 2.
Execution of risk containment actions and site preparation of the property located on
Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico (former
Cromatos factory)
Photographic Memory 3.
Remediation actions on the property located on Francisco I Street.
Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico (former Cromatos de
México factory)
APPENDIX 1
Copies of Administrative Support Documentation
Tabla Página
White book 1
SECRETARY OF ENVIRONMENT AND NATURAL RESOURCES 3
AND RISKY ACTIVITIES 10/31/2012 3
Index 4
1 .- PRESENTATION 1
Eng. Eduardo Enrique González Hernández 2
1.1. - NAME OF THE PROGRAM 3
1.2. - DOCUMENTED VALIDITY PERIOD 3
1.3. - GEOGRAPHICAL LOCATION 3
I.5.- ADMINISTRATIVE UNIT 10
II .- LEGAL FOUNDATION AND OBJECTIVE OF THE WHITE PAPER 11
11.1. - LEGAL BASIS 11
11.2. - PURPOSE OF THE WHITE PAPER 11
III .- BACKGROUND 11
Resources 22
(LGPGIR) 22
IV.3.- Regulations of the LGPGIR 24
VII .1.- National Development Plan (2007-2012) 25
VIII .2.- Environment and Natural Resources Sector Program (2007-2012) 26
VI.- EXECUTIVE SYNTHESIS OF THE PROGRAM 26
VII.1.- Work program 30
VII.2.- Budget and authorized spending schedule 30
Removal Technologies for remediation of the Cuautitlán Aquifer-^^^^^^^^^ 50
VII.4.- Documentation supporting the application of the Resources 53
VII.4.1.- Investment portfolios authorized by the SHCP and budget sufficiency 53
VII.4.3.- Agreements and/or contracts concluded 58
VII.4.4.- Records of the budget exercises carried out. 65
Tabla Página
VII.4.5.- Investment Release Letters. 69

70
5RQRNISO[U >2"5? 71
2NRJMYMRJKL +MKLNOPIQL @! 2NRJMYMRJKL "\RNSOQL 71
Remediations Authorized Budget Vs Exercised Budget 72
Authorized budget item 33104 "Studies and consultancies" 73
IX .1.- Institutional Reports. 74
VIII.4.- Attention to observations. 80
VIII.5.- Actions carried out to correct or improve its execution. 85
IX.1.- Compliance with the objectives and goals of the Program 88
the works executed. 89
X.- FINAL REPORT OF THE HEAD OF THE DGGIMAR 93
LXLUOI ,RSTRNbI1 (MXKOKXdU1 "JKIQL QR &efOSL` 94
GLOSSARY OF TERMS 97
!"#$"%&$'& )" *")+, &*-+".%" / $"#0$!,! .&%0%$&1"! 99
!"!#$%& (#)#*$+(%,& 99
&-)". /" 0&. &,,%#-". /" ,#-)"-,%1- /"0 $%".*#2 3$"3&$&$,%1- /"0 .%)%# 4 $"!"/%&,%1-
/"0 3$"/%# 99
/%$",,%1- *"-"$&0 /" *".)%1- %-)"*$&0 /" !&)"$%&0". 4 &,)%5%/&/". $%".*#.&.
99
!"#$"%&$'& )" *")+, &*-+".%" / $"#0$!,! .&%0%$&1"! 118
1%$",,%/0 *"0"$&2 1" *"3)%/0 %0)"*$&2 1" !&)"$%&2"3 4 &,)%A%1&1"3 $
%"3*#3&3 118
!"#$"%&$'& )" *")+, &*-+".%" / $"#0$!,! .&%0%$&1"! 148
Tabla Página
/%$",,%0- *"-"$&1 /" *".)%0- %-)"*$&1 /" !&)"$%&1". ? &,)%@%/&/". $

%".*#.&. 148
Cr CONTENT IN SOIL A 3.0M DEPTH 154
Cr CONTENT IN SOIL A 6.0M DEPTH 154
consultancies”
Table 9. Program of events of the National Public Tenders for the 57th first project
Table 10. Program of events of the National Public Tenders for the 59th second project
Table 11. Program of events of the National Public Tenders for 60
monitoring wells
Table 12. Program of events of the National Public Tenders for the 61 second project.
Table 13. Record of payments for the budget year made through 68
of the PEF
Table 14. Record of payments for the budget year made through 71 CONABIO
White Paper "Follow-up on risk containment actions, site preparation and remediation of the property located on the street
Francis I. Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico (former Cromatos de México factory)"
1 .- PRESENTATION
This White Paper is a public government document through which the General Directorate of
Comprehensive Management of Risky Materials and Activities (DGGIMAR), belonging to the
Undersecretariat of Management for Environmental Protection of the Ministry of Environment and
Natural Resources, records the actions undertaken and the results obtained from monitoring the
management of the successful case of risk containment actions, site preparation and remediation of
the property located on Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico
(former Cromatos de México factory).
The White Paper was authorized, through official letter No. UCGP/209/058/2012, of January 23, 2012,
signed by the Head of the Public Management Control Unit of the Secretariat of Public Function and
made known to the DGGIMAR by the Senior Official's Office, through job no. OM/500/0459, dated
February 22, 2012, in compliance with paragraph FOUR of the “Guidelines for the preparation and
integration of White Books and Documentary Reports”, published on October 10, 2011, in the Official
Gazette of the Federation.
The site known as “Cromatos de México” represented a problem of environmental contamination and
health damage with hexavalent chromium residues to the inhabitants of the Colonia Lechería and the
municipality of Tultitlán, State of Mexico for more than four decades. Hexavalent chromium is a toxic
substance for the population when they are exposed through inhalation, dermal contact or ingestion.
Its chronic toxic effects due to inhalation are irritation, ulcers and perforation of the nasal septum;
dermal contact are skin reactions, such as rashes, itching and redness. The carcinogenic effects of
hexavalent chromium over time and repeated exposure can result in the development of lung cancer.
During these four decades there was a great diversity of studies by different academic institutions,
international organizations and research centers that proposed to the competent authorities partial
solutions to the problem of “Cromatos de México”, without it being definitively resolved.
One of the alternative solutions developed was the construction of two confinement cells that
contained the toxic waste, which after a couple of years suffered fractures and collapse, causing the
toxic waste to be exposed again, causing contamination due to the effects of leaching. soil and aquifer
and
1
White Paper “Follow-up on risk containment actions, site preparation and remediation of the property located on the street
Francis I. Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico (former Cromatos de México factory)”
resurfacing damage to the population's health, resulting in the demand and pressure from society that
the problem persist and be resolved completely and definitively.
At the beginning of this Administration, the Secretariat developed, through the Environment and
Natural Resources Sector Program 2007-2012, a solution strategy for critical environmental liabilities
in Mexico, which included the “Cromatos de México” site. From this moment on, a master program
was initiated to solve the problem with the participation and coordination of the federal, state and
municipal authorities competent in the matter and an arduous task of administrative management for
the allocation of financial resources with the Secretariat. of Finance and Public Credit. The issuance of
legal instruments based on the Expropriation Law was necessary to make the definitive solution to the
problem of “Cromatos de México” a reality, for the benefit of the population that had been affected for
several decades.
The preparation of this White Paper integrates and describes in a chronological manner the
conceptual, legal, budgetary, administrative, operational and monitoring actions of the results obtained
during the period from 2007 to 2012 in its different stages, risk containment activities, preparation of
the site and remediation of the “Cromatos de México” property so that society is informed as part of
the obligation that SEMARNAT has in terms of accountability.
The investment programs and projects described in this White Paper for the management of the
successful case of risk containment actions, site preparation and remediation of the property located
on Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico (former Cromatos
de México factory), were carried out under the criteria of transparency, honesty, clarity, efficiency and
proper management of public resources.
Eng. Eduardo Enrique González Hernández

General Director of Comprehensive Management of Materials and Risky Activities
Undersecretariat of Management for Environmental Protection
Secretariat of Environment and Natural Resources
2
1.1. - NAME OF THE PROGRAM
“Follow-up on the management of the successful case of the Risk Containment Actions, site
preparation and remediation of the property located on Francisco I Street. Madero No. 30, Colonia
Lechería, Tultitlán, State of Mexico (former Cromatos de México factory).”
1.2. - DOCUMENTED VALIDITY PERIOD
January 1, 2007 to October 31, 2012.
1.3. - GEOGRAPHICAL LOCATION
The project is located on the property on Francisco I Street. Madero No. 30, Colonia Lechería,
2
Tultitlán, State of Mexico, known as “Cromatos de México”, in a total area of 35,344.13 m , whose
polygons and boundaries are shown in figure 1 and are described below:
Construction table of “area A”.
COURSE DISTANCE BOUNDARIES

Yes 71 958’49.87" AND 106.63 Morelos Street
N 16°22'28.38" AND 57.23 Reforma Street

N 72005’39.17" W 110.25 area B
Yes 1204441.24" W 57.23 Francisco Street. YO. Log

Surface "area A" 6,192.50 m 2
Source: Temporary occupation decree, November 30, 2006. Official diary.
Construction table “area B”.

Yes 72005’39.17" AND 110.25 area A
N 16°22'28.38" AND 96.59 Reforma Street

N 16°22'28.38" AND 5.61 area 3 a
N 75°08'12.15" W 7.60 area C

Yes 17059’55.09" W 15.76 area C
N 71 °30'45.65" W 8.55 area C

Yes 16941’34.76" W 4.35 area C
N 72009’54.36" W 21.30 area C

Yes 18°36'53.00" W 2.17 area C
N 72053’28.32" W 80.26 area 1
Yes 11 946’21 .29" W 33.65 Francisco Street. YO. Log
3
Yes 11 °33'22.32" W 27.76 Francisco Street. YO. Log
Yes 06°36'34.93" W 17.71 Francisco Street. YO. Log

Surface "area B" 9,377.27 m 2
Construction table “area C”.

Yes 72009’54.36" AND 21.30 area B
N 16941’34.76" AND 4.35 area B
Yes 71 °30'45.65" AND 8.55 area B

N 17059’55.09" AND 15.76 area B
Yes 75°08'12.15" AND 7.60 area B

Yes 75°56'38.54" AND 102.98 area 3 a
N 13°26'55.22" AND 18.42 area D

N 13°19'25.54" AND 50.84 area D
Yes 76013’33.97" AND 14.98 area D
N 08°05'39.91" AND 53.17 area 1

N 76°24'28.86" W 110.04 area 1
Yes 1405418.31" W 69.20 area 1

N 75°02'21.21" W 44.77 area 1
Yes 14°15'09.38" W 61.28 area 1

Yes 75°06'51.29" AND 5.72 area 1
Yes 13°43'24.85" W 9.37 area 1

Surface "area C" 15,948.93 m 2
4
Construction table “area 1”. Spaces between cells and surrounding properties.

Yes 72053’28.32" AND 80.26 area B
N 14°38'36.12" AND 11.54 area B and C
N 75°06'51.29" W 5.72 area 3b

N 14°15'09.38" AND 61.28 area C
Yes 75°02'21.21" AND 44.77 area C

N 1405418.31" AND 69.20 area C
Yes 76°24'28.86" AND 110.04 area C

Yes 08°05'39.91" W 53.17 area C
Yes 79°40'51.72" AND 4.51 area D
N 08°12'41.27" AND 58.30 private property

N 75°11'41.08" W 63.86 private property
Yes 1494406.82" W 2.19 private property
Yes 14°56'24.83" W 65.98 private property

Yes 14°44'12.06" W 72.19 private property

Yes 11 946’21 .29" W 5.17 private property

Surface "area 1" 2,260.32 m 2
Construction chart of “premise 3”.

Yes 71 °53'12.02" AND 25.95 Morelos Street
N 12°26'54.39" AND 67.57 private property

N 71 941’44.43" W 20.59 private property
Yes 16°59'38.31" W 67.32 Reforma Street

"Plot 3" surface 1,565.11 m 2
5
Figure 1.- Polygons of the property of the former Cromatos de México factory.
I.4.- MAIN TECHNICAL CHARACTERISTICS
To carry out the actions of the project “Monitoring the Management of the successful case of the Risk
Containment Actions, Site Preparation and Remediation of the property located on Francisco I Street.
Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico (former Cromatos de México factory)”,
SEMARNAT, through the Legal Affairs Coordinating Unit, proceeded to carry out an exhaustive legal
analysis to prepare the legal instrument that would allow it to carry out the actions of remediation
necessary to reduce the risks to health and the environment, given that it was a site that had owners,
however they were not the cause of the existing contamination, which is why they could not be
responsible for the removal of the hazardous waste and property remediation.
Therefore, based on what is stated in article 73, third paragraph of the General Law for the Prevention
and Comprehensive Management of Waste and 153 of its Regulations, the case of contamination of
Cromatos de México merited the intervention of the Federation and by
Consequently, the declaration of remediation of the property had to be issued through the instruments
indicated in the Expropriation Law through the corresponding Decrees published in the Official Gazette
of the Federation, first the Temporary Occupation Decree on November 30, 2006 and subsequently
the Expropriation Decree on December 17, 2011.
6
In accordance with the above, the remediation of the Cromatos de México property was a cause of
public utility in accordance with the provisions of article 1, sections V, VII, X and XII. The cause of
public utility was accredited based on the studies carried out, which demonstrated that the severity of
the site's contamination generated an environmental emergency based on multiple factors, including
the toxicity of the hazardous material or waste involved; the imminent danger of immediate and
irreversible damage to the environmental environment; the volume of contaminants involved; the
extent damaged by the contaminant and the receptors of the contaminants that were biological
(protected species, ecosystems) or non-biological (soil and water) natural resources, and even human
beings.
On the property, it was estimated that approximately seventy-five thousand tons of waste
contaminated with chromium were confined, coming from the activity of the aforementioned company,
whose chemical properties, the deficiency in its compaction, and confinement caused the chromium to
emerge to the surface through cause of fissures and subsidence, dispersing again to the environment
and leaching to deep strata of the soil, subsoil and causing contamination of water wells near the
plant. In this regard, it was estimated that approximately five tons of hexavalent chromium leached
annually.
The program of ^ Follow-up to the Management of the successful case of the Risk Containment
Actions, Site Preparation and Remediation of the property located on Francisco I Street. Madero No.
30, Colonia Lechería, Tultitlán, State of Mexico (former Cromatos de México factory)”, was structured
based on historical studies of the property in the year 2 0 04 3 such as: characterization,
environmental risk and character studies geophysical or geo-hydrological that were contracted jointly
between SEMARNAT and the German Cooperation Agency the ^Deutsche Gesellschaft für
Internationale Zusammenarbeit (GIZ)^, whose studies were carried out by the consortium Rietzler &
Heidrich GmbH (R&H)/GEO4 GmbH ( GEO4) of Oberbrunn of the Bavarian Ministry of the
Environment, the studies revealed that hexavalent chromium, considered highly toxic, existed on the
property in an approximate quantity of one hundred thousand cubic meters and a probable impact
radius of thirty-four thousand square meters.
Due to the above, it was necessary to develop the first project of the Program in 2007, whose name
was covered by the Temporary Occupation Agreement ^^^^^^^^^^ ^^^^ ^^ risk containment and site
preparation for carrying out remediation works that are essential to reduce risks to human health and
the environment, in the former Cromatos de México factory, located in the Municipality of Tultitlán,
State of Mexico (Demolition and final disposal of the ruins of the former factory). Which consisted of
removal of remaining solid waste; chemical analysis of the site's remaining solid waste; demolition of
structures, excavation, loading, transportation, treatment of hazardous waste and final disposal
services from areas A and B to an authorized hazardous waste confinement outside the State of
7
Mexico.
Subsequently, in 2008, the second project called ^^^^^^^^^ ^^ risk containment and site preparation
was carried out in the demolition works of Cell C1 and part of Cell C2, of the property. the former
Cromatos de México factory in the Lechería neighborhood, in the Municipality of Tultitlán, State of
Mexico", which consisted of the demolition of the perimeter wall of cell C1 and partial of C2,
excavation, loading, transportation, treatment and final disposal of toxic waste up to a total of 22,000
tons, as well as a temporary protection system for open surfaces.
In 2010, the third project was carried out called ^^^^^^^^^ ^^^^ ^^^^^^^^^^ ^^^ risk and preparation of
the Cromatos site for remediation: complementary works on the property and in the rear part^^^^^ ^^
^^ ^^^^^ ^^^, which consisted of demolition of reinforced concrete of the perimeter walls; excavation to
remove material contained in cell C2; acquisition, supply, authorization, maintenance, placement of
1.0 mm thick canvas to cover the surface discovered after excavation, filling and compaction of the
excavated areas, loading, transportation and final disposal of hazardous waste in a confinement
authorized by SEMARNAT .
At the end of these three investment projects, it was necessary to update the characterization and
evaluation studies of the environmental risk on the property, in order to know the degree of
contamination in the soil and subsoil, after the risk containment actions and count with the technical-
scientific elements necessary to prepare the executive project of the engineering works for the
corresponding remediation actions. These pre-investment programs developed were:
• “Sampling work to update the magnitude of contamination of the property located on

Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico with an area of
35,344.13 m 2 ^^
8
• “Development of a study Environmental Risk Assessment (ERA) of the property

located on Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán, State
Mexico".
• "Executive Project of engineering works for remediation ground

contaminated in the property located on Francisco I Street. Madero No. 30 Cologne
Lechería, Tultitlán, State of Mexico.”
The result of these studies gave rise to the last three investment projects for the period 2011-2012, the
fourth project called “Engineering Works for the remediation of contaminated soil on the property
located on Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán State of Mexico”, which
consisted of the demolition of concrete elements; excavation, loading, transportation and final disposal
of soil contaminated with hexavalent chromium; filling and compacting clean material in excavated
areas; supply and formation of hydraulic layer; impregnation irrigation based on asphalt emulsion in
the excavated areas; manufacturing of emulsified flexible asphalt pavement; supply and placement of
hollow block; manufacturing of castles with an apparent finish in the perimeter area of the entire
property; manufacturing of overhangs and fencing chains in the perimeter area of the entire property;
supply and manufacture of foundation footing for the perimeter wall of the property and supply and
installation of ironwork doors.
The fifth project called “Drilling of 12 exploratory wells and extraction for the remediation of the
Cuautitlán-Pachuca aquifer, locally contaminated by chromium, in Tultitlán, State of Mexico”, for this
project it is worth clarifying that its original scope was modified from 12 to 9 wells. The executive
project for the 12 drilling wells was technically designed by specialized CONAGUA personnel based
on a geological model that was built with lithological information from the Pachuca - Cuautitlán region
in existing studies in the bibliography at a national and international level, as well as on the information
obtained from the drilling of drinking water wells in the 60 's , 70 's and 80 's , so it was a preliminary
geological model to develop the volumes of work necessary for the preparation of the bidding rules.
Likewise, it was stated in the bidding rules that the final design of the wells would be determined by
the results of drilling four points in different locations to determine the correct lithology and geology of
the drilling wells. The results showed a geological model very different from the original projected by
CONAGUA, with the rock zone fractured up to 90% of the projected lengths, which would cause
losses of drilling mud fluids from the first lithological layers.
This new scenario involved recalculating the work on the length and extension of drilling of the wells
and thickness of the counter-instrument pipe in accordance with the different morphological and
lithological zones of the subsoil found to prevent the pipe from collapsing due to the pressures
exerted.
9
White Paper "Follow-up on risk containment actions, site preparation and remediation of the property located on $% street
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Given the need for the work itself and its functionality, it was necessary to reduce the scope of the
originally planned well construction, with the understanding that the total number of wells and their
cost would be a function of the final design determined by the geology and lithology of the well itself.
each defined site, where the financial adjustments were made to achieve compliance with the
objective focused on the infrastructure necessary for the remediation of the aquifer.
Based on the aforementioned situations, the project concluded with the construction of 9 exploratory
and extraction wells in four sites, 3 of 300 meters, 2 of 160 meters, 2 of 200 meters and 2 of 105
meters. The nucleation of each site was carried out, determining the geology and lithological
characterization and the behavior and concentration of hexavalent chromium in the soil, subsoil, the
1
intermediate zone between soil and aquifer called vadose zone and the aquifer. The wells were
gauged to determine the parameters of the hydraulic dynamics of the aquifer and the concentrations of
hexavalent chromium. Geophysical records and modeling of the gauging results were carried out.
The sixth and last project called ^Protection of four exploratory-extraction wells for the remediation of
the Cuautitlán-Pachuca Aquifer locally contaminated by chromium; demolition-construction of
contaminated sidewalks on the property located on Francisco I Street. Madero No. 30 Colonia
Lechería, Tultitlán, State of Mexico perimeters and preparation of signs^.
In summary, the Program for monitoring risk containment actions, site preparation and remediation of
(former Cromatos de México factory), six investment projects and three pre-investment programs in
Public Works were executed, to solve a problem of more than four decades of a liability environment
contaminated with hexavalent chromium, which caused serious damage to health and the
environment.
Complementary to the monitoring well drilling project, advice was requested through the Law on
Acquisitions, Leases and Public Sector Services (LAASSP),
D Vadose Zone.- It is the one found between the surface of the soil or subsoil and the aquifer, in which the pore space is only
partially filled with water and circulating horizontally.
for the technical-economic evaluation of Chromium removal technologies for the remediation of the
locally contaminated Cuautitlán-Pachuca aquifer.
Based on the technical-economic evaluation carried out from pilot and laboratory scale studies to
select the best technology or treatment train for the removal of chromium as a remediation method of
the Cuautitlán-Pachuca aquifer, complemented with the executive project of a plant treatment on a
real scale.
I.5.- ADMINISTRATIVE UNIT
The Administrative Unit in charge of the program was the General Directorate of Comprehensive
1
0
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Management of Risky Materials and Activities belonging to the Undersecretariat of Management for
Environmental Protection of the Secretariat of Environment and Natural Resources.
II .- LEGAL FOUNDATION AND OBJECTIVE OF THE WHITE PAPER
11.1. - LEGAL BASIS
Guidelines for the preparation and integration of White Papers and Documentary Reports, published in
the Official Gazette of the Federation on October 10, 2011.
11.2. - PURPOSE OF THE WHITE PAPER
Leave public documentary evidence of the actions undertaken and the results obtained from the
management of the successful case of risk containment actions, site preparation and remediation of
(former Cromatos de México factory), describing in a chronological manner the conceptual, legal,
budgetary, administrative, operational and monitoring actions, as well as the results obtained by the
program in the period of the January 1, 2007 to October 31, 2012.
III .- BACKGROUND
The company Cromatos de México was established in 1958 and operated until September 20, 1978 2 ,
20 years of operation and pollution of the air, soil and water, given the prevailing economic model of
the 50's, 60's and 70's was a beneficiary of the mechanisms of promoting industrial development, as
demonstrated in the particular Declaration that exempts Cromatos de México, SA de CV from taxes. In
the manufacture of
AndTechnical Report of the Historical Study of the site of the former Cromatos de México SA de CV factory, page. 2 Rocha
Jiménez María, GTZ-SEMARNAT.
sodium bichromate decreed by the Ministry of Finance and Public Credit, published in the Official
Gazette of the Federation on October 8, 1970.
The economic model of growth prevailing during the 1950s to 1970s did not consider that this
industrialization would have long-term effects due to the byproducts and generation of unwanted
pollutants in industrial processes, which caused them to be emitted into the air. soil and water, as well
as waste generated, abandoned or deposited without the slightest awareness of the negative impacts
on the environment.
3
For this reason, in 1975 the municipality of Tultitlán already had approximately 93 industrial plants in
the northern and western part of the municipality and with a growth of the urban area in the southern
part and to the east. At that time, the company Cromatos de México, SA de CV, in the Lechería
neighborhood, already had a large environmental liability for the generation of hazardous waste with
1
1
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4
hexavalent chromium (approximately 75,000 tons ) and various effects on the health of the
population of the Colony. due to exposure through inhalation of hexavalent chromium particles,
contamination of the soil and aquifer due to discharge and leachate of contaminants from the
production process.
The company Cromatos de México produced sodium bichromate (Na 2 Cr 2 O 7 ·2H 2 O) for use in
tanneries and leather tanning, as well as potassium bichromate (K 2 CrO 4 ) for the match industry. In
the same way, it generated byproducts, such as Sodium Sulfate (Na 2 SO 4 ), Aluminum Sulfate (Al 2
(SO 4 ) 3 ) and Aluminum Hydroxide Al(OH) 3 , as well as emissions of pollutants into the atmosphere.
from the calcination ovens, discharge of wastewater from the chromate liquor sedimentation vats and
residues from the ovens called slags or pellets and residues of chromium salts (hexavalent) from the
sedimentation processes of the raw chromate liquor .
The production processes of the company Cromatos de México were inefficient and with very poor
performance in some stages, given the way of producing and the technology of the equipment used,
which caused negative impacts on the environment through the generation of polluting emissions. the
atmosphere from its combustion equipment, wastewater discharge into bodies of water and infiltration
5
into the soil for a period of 16 years, through absorption wells and generation of hazardous
3
hexavalent chromium waste of approximately 85,000 m that were sent to the plant patios
1 30 years after the closure of Cromatos de México “60 thousand tons of waste still poison us” s/p, Castro Díaz José at the
Ecological Day, UNAM.
F Chromatos de México toxic grave, s/p Ma. Eugenia Pérez, diav.com.mx/archivo/2006/octubre/htm/cromatos_mexico.htm -
G In-situ confinement of toxic solid waste from the former company Cromatos de México, page. 2, Secretariat of Health and
for storage and
Assistance, Undersecretary of Environmental Improvement/Subdirectorate of Engineering, 1982 -
disposal on the ground in an area of 16,574 m 2 without any type of safety measure 6 , resulting in
inadequate handling , which through leaching significantly contaminated the subsoil and surface
and/or underground aquifers. It was also known through historical research that a large amount of
waste with chromium or foundry slag was used as fill in multiple streets and depressions 7 .
This predatory panorama and ecological genocide and damage to the health of the population was a
social detonator so that, through the "La Reforma" school in 1972, complaints were initiated by the
society of parents of the “La Reforma” school, which was chaired by Mrs. Manuela Ríos de Salmerón
and Sonia F. Rojas de Oceguera, fearful of the risks and damages caused by the improper handling
and disposal of hexavalent chromium waste close to the walls of the La Reforma school, sending the
first official complaint to the Undersecretariat for Environmental Improvement of the Ministry of Health
and Assistance related to the contamination of the Cromatos de México company.
This beginning of the society of parents of the “La Reforma” school, championed the case of Cromatos
de México as its social struggle, since its student population was the one that suffered for decades the
health damage caused by the negative impacts of the company Cromatos de México coming from the
company's polluting emissions, both into the atmosphere, and from the discharge of water with
1
2
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chromium into the canals and surrounding surfaces and generation of chromium dust from the waste
produced.
Based on the complaint, the Ministry of Health and Assistance intervenes to establish guidelines and
prevent it from continuing to contaminate the aquifers and soil, as well as to try to use safety measures
for the toxic solid waste discovered that represented a public health danger. The concern of the social
community increased, as they observed that domestic animals died after drinking yellow water that
was concentrated in puddles after a while.
In the year 1975, again the society of parents of the “La Reforma” school took up the case of
contamination and damage to health, requesting the Coordinated Health Services in the State of
Mexico from the Ministry of Health and Assistance, which carried out an inspection visit verifying the
existence of chrome contamination in walls of
HIn-situ confinement of toxic solid waste from the former company Cromatos de México, page. 2, Secretariat of Health and
Assistance, Undersecretary of Environmental Improvement/Subdirectorate of Engineering, 1982 -1
the construction, on the street and the existence of yellow puddles adjacent to the Cromatos de
México plant.
Based on the previous ruling, the parents' society of the “La Reforma” school insisted by presenting a
new letter to the acting Governor of the State of Mexico, Dr. Jorge Jimenez Cantú, so that he could
issue the corresponding instructions and provide a solution to the problem. the problem of
contamination and damage to the health of the population, whose matter was turned over to Dr.
Gustavo Baz Díaz Lombardo, Head of the Coordinated Public Health Services, who instructs a series
of regulations to the company to reduce the contamination that was caused to air, water and soil.
On the other hand, in 1976, the parent society of the “La Reforma” school focused on scientifically
substantiating the damage to health caused by the company, Cromatos de México, due to the
emission and inadequate management of yellow dust. that was contaminating the school, requested
the National Industrial Development Laboratories (LANFI) to analyze the yellow dust present in the
school and its surroundings. LANFI points out in its report No. 76-1322 called “Technical Report on the
work carried out to determine the toxicity of the yellow dust with which the federal urban school “La
Reforma” is contaminated, in the Lechería neighborhood, Tultitlán State of Mexico”, which as a result
of its analyzes There is the presence of chromium contamination in water and soil, with specialized
publications pointing out the great toxicity of chromium compounds, especially chromium in the form of
chromates, di-chromates and chromic acid, in the majority of articles published in that period indicate a
high incidence of cancer in people exposed to the absorption of chromium and chromates through the
alimentary tract and/or lungs. The cancer was located in the lungs, liver and kidneys. In addition, acute
1 Technical Report of the Historical Study of the site of the former Cromatos de México SA de CV factory, page. 9 Rocha
Jiménez María, GTZ-SEMARNAT -
1
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toxic effects such as skin ulcerations, pharyngitis, bronchitis occur, and in case of prolonged and
continuous absorption through the nose, it is reported to perforate the nasal septum.
LANFI ends up concluding that the problem of chromate contamination in the “La Reforma” school is
considered serious in scope, so an immediate solution must be sought. Likewise, it recommends
investigating the degree of contamination existing in the entire region of influence of the Cromatos de
México factory, in order to take, where appropriate, appropriate measures to protect the health of all
the inhabitants of said region.
In parallel to the report issued by LANFI, the Parents' Society of the “La Reforma” school (July 1976)
obtained a certificate from Dr. José Medina Santana, surgeon, who declared the damages to the
school's workers. Cromatos de México plant that was attended for 6 years, among the symptoms
found, perforation of the nasal septum, ulcer-type perforations were identified where some reached the
bone system, presenting intense pain and fever. Regarding respiratory problems, they were identified:
laryngitis, pharyngitis, tonsillitis and even bronchitis. In the previous medical certificate, it is concluded
that a more in-depth study must be carried out, since the yellow powders or substances emitted by
Cromatos de México, not only harm the organism, but also organic life in general, since there is no
growth. of vegetables throughout the affected locality.
In that same year, 1976, the complaints made began to appear in the most widely circulated
newspapers, giving great coverage to the current problem of contamination by the Cromatos de
México company through cartoons and denunciatory articles.
In 1977, with all the social pressure from the society of parents of the “La Reforma” school and the
press questioning the actions of the competent authorities, the Undersecretariat for Environmental
Improvement of the Ministry of Health and Assistance (SSA) ), carries out an inspection of the
Cromatos de México plant, which coincides with the temporary closure imposed by the Coordinated
Health Services of the State of Mexico for non-compliance with the regulations established in the visits
carried out in 1976, both institutions They jointly determine the company's recurring violations
regarding environmental pollution and without any proposal for compliance and pollution control by the
Cromatos de México company.
During that same year, toxicological and eco-toxicological studies and investigations on chromium
contamination in the population and vegetation of the affected area of influence in Colonia Lechería
continued, by Dr. Rafael Villalobos Pietrini, Dr. Irma Rosas and collaborators members of the National
Autonomous University of Mexico (UNAM), with three important works called “Biological Effects of
Chromium”; “Quantification of chromium in soil and plants from an area contaminated by residual
chromium of industrial origin” and “Determination of chromium in two non-occupationally exposed
human populations.” The results of these studies determined that the population of the Lechería
colony had been exposed and affected by residual chromium contamination and in vegetables the
1
4
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maximum concentration was detected in the leaves due to air contamination.
It should be noted that the press closely followed the studies carried out by the UNAM, potentiating the
social and health problem for the population. During the following months, inspection visits continued
by the Coordinated Health Services of the State of Mexico to monitor the regulations established in the
administrative procedures of the previous visits to the Cromatos de México company, without any
progress being made on the final disposal of the chrome-containing waste deposited in the yards and
land surrounding the company, and without much progress in implementing waste control equipment.
emissions to the atmosphere.
In June 1978, given the new studies carried out by the UNAM and the actions of the Coordinated
Health Services of the State of Mexico and the reopening of operations of the Cromatos de México
factory, the school's parents' society ^^ ^ ^^^^^^^^ sent a letter again to the Undersecretariat for
Environmental Improvement (SMA), through which it requests the intervention of the SMA to
definitively resolve the problem of environmental pollution, given that the company Cromatos of
Mexico restarted operations, worsening the situation of the inhabitants of the Lechería neighborhood,
since the dust was spread again and nosebleeds continued in inhabitants of the colony, as
demonstrated by studies carried out by the UNAM.
In the same way, the press pressure on the case continued, denouncing that the company had
initiated a dismissal of incurable employees. It was not until September 1978, when the definitive
closure of the Cromatos de México plant was declared. of the Coordinated Health Services of the
State of Mexico for repeated non-compliance with the measures established to control pollution
caused to the air, water and soil and inadequate management of toxic solid waste with chromium.
At the end of 1978, the company Cromatos de México declared bankruptcy, by agreement of the
Special Board of the Local Conciliation and Arbitration Board, the precautionary seizure of the assets
was ordered and they were registered in the Public Property Registry.
By the beginning of 1979, the board ordered the dismantling and definitive seizure of the assets of the
company Cromatos de México, S. TO. and the public auction of the land was held. The public auction
left the largest environmental liability in history without anyone responsible for its remediation, to which
the Coordinated Public Health Services of the State of Mexico presented several options on January
31, 1979, which were discarded for various undocumented reasons. , leaving a large environmental
liability that would be known as one of the black chapters of Mexico in terms of contamination from
contaminated sites.
Once the definitive closure of the company was decreed and the assets of the Cromatos de México
company were auctioned, in 1979, the problem persisted and the matter became a large
environmental liability of the abandoned waste and the property in possession of a private property
that was acquired by auction, rejecting through legal means responsibility in the matter.
1
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The press closely followed the abandonment and risk posed by chrome waste.
In 1981, the Undersecretary of Environmental Improvement, the Directorate of Social Promotion of the
Secretariat of Education, Culture and Social Welfare of the State of Mexico and the Secretariat of
Urban Development and Public Works of the State of Mexico coordinated with the other agencies to
resolve the situation of the problem of abandoned waste 8 .
The result of this work established the scope of the problem, determining that the inadequate deposit
2 3
of chromium waste was located in an area of 16,574 m with a volume of 85,000 m of chromium
waste that represented a weight of 120,000 tons 9 .
10
Once the problem is defined, three alternative solutions are proposed , of which the most accepted
was Confinement in Place, because it presented the greatest advantages and was the most
economical in relation to the other proposals. The investment cost of the work was $35,000,000.00,
the chrome waste would be isolated from the action of wind and rain and at the end of the work a
surface area of 16,574 m 2 could be available, which the State government would determine its use.
Agreements were established for the participation of government agencies for the construction of the
work, in which the Undersecretary of Environmental Improvement assumes technical responsibility
and would contribute the amount of $12 million pesos for the execution of the work, the General
Directorate of Works Public of the Government of the State of Mexico, would carry the technical
responsibility for the execution of the work, providing the necessary personnel and equipment. The
supply of clay was provided by the municipality of Tultitlán and the supply of asphalt concrete by the
Government of Federal District 11 .
In 1983, it is reported that the perimeter wall, the extension of the waste, the compaction and the final
coating have been completed, so the Undersecretary of Ecology Alicia Bárcenas terminates the work
and declares the solution to the problem definitively. .
JMonitoring and Evaluation Study of the Cromatos de México industrial cemetery in Tultitlán, State of Mexico, p. 78, Institute of
Geography-Faculty of Chemistry of UNAM, 1985.
K In-situ confinement of toxic solid waste from the former company Cromatos de México, page. 4, Undersecretary of
Environmental Improvement/General Directorate of Water Sanitation/Subdirectorate of Engineering, 1982.
D2 In-situ confinement of toxic solid waste from the former company Cromatos de México, page. 8, Undersecretary of
Environmental Improvement/General Directorate of Water Sanitation/Subdirectorate of Engineering, 1982
DD In-situ confinement of toxic solid waste from the former company Cromatos de México, page. 14, Undersecretary of
Environmental Improvement/General Directorate of Water Sanitation/Subdirectorate of Engineering, 1982
A month after the inauguration of the confinement, it already showed cracks and fissures, so the
Applied Research Center for Industrial Development (CINADI) carried out a series of studies that
included topography, soil mechanics, waste volumes, analysis stability and resistance of confinement,
chemical analysis of waste and soil under confinement, and analysis of water flow and contaminants
1
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under confinement.
In 1985, the Secretariat of Urban Development and Ecology (SEDUE) contracted the National
Autonomous University of Mexico so that, in a coordinated manner, the Institute of Geography and the
Faculty of Chemistry carried out a Monitoring and Evaluation Study of the industrial cemetery of
Cromatos de México in Tultitlán, State of Mexico, which was led by M. in C. Margarita Gutiérrez Ruíz
and collaborators. This study consisted of taking soil and water samples and geophysical monitoring,
which concluded in 1986.
During the period from 1986 to 1990, the chrome waste confinement received maintenance for
fractures and fissures, as well as resurfacing for deformations on the surface due to settlements that it
still presented, by the Government of the State of Mexico. , after this date its monitoring and
maintenance was left to be abandoned by the competent authorities.
The next study by environmental authorities was carried out in 1999, after almost ten years of
abandonment of the company's industrial center and the confinement of chrome waste.
The chromium rose to the surface, becoming evident and dispersing through the fissures or cracks
and deformations of the surface of the confinement, increasing the risk of exposure to the toxic and at
the same time leaching into the soil and subsoil. On the other hand, the chromium began to damage
the concrete structures of the ruins of the hull of what was the process plant.
Due to the above, the Federal Attorney for Environmental Protection (PROFEPA) within the framework
of the National Program for Sites Contaminated with Hazardous Waste contracted a Site
Characterization study of “Cromatos de México”, located in Tultitlán, State of Mexico through the
company Especialistas Ambientales, SA de CV, the study focused on soil and water sampling,
analyzing hexavalent chromium and total chromium in different areas.
The results showed that high concentrations of hexavalent chromium ranging from 469.5 to 1950
mg/kg were found in the surroundings, inside the plant and in the adjacent land from 599 to 63,400
mg/kg; In the sewage canal located 200 meters from the property, the concentrations found in soil in
this area for hexavalent chromium were 0.757 to 16.9 mg/Kg.
The leachates are moving in a south to north direction and are concentrated towards the eastern limit
of the confinement cells. The leachates are stagnant in the upper part of the soil, since the
impermeability of the cells has not allowed their migration to deeper strata, the concentrations of
hexavalent chromium found were 147 to 246 mg/Kg.
Based on the results obtained from the study, in 2000, the Federal Environmental Protection Agency
(PROFEPA) made the decision to declare the land of the defunct Cromatos de México company as
“environmental contingency zone 12. ”
On May 15, 2002, in a joint statement from the Ministry of Environment and Natural Resources
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(SEMARNAT) and the Bavarian State Ministry of Environment, Health and Consumer Protection, the
two authorities agreed to mutual collaboration on environmental matters through of the German
Cooperation Agency GTZ.
For the year 2003, Mrs. Manuela Ríos de Salmerón, in coordination with the Deputy Professor
Santiago Cortés Sandoval, held a workshop forum on the pollution problem of the company Cromatos
de México, with the purpose of exposing and analyzing approaches and alternatives that would allow
the development of strategies to resolve the causes, effects and reactions that affect human health in
the Lechería region 13 .
By February 2004, the Technical Coordination Table was installed, made up of authorities from the
Ministry of Environment and Natural Resources, the National Water Commission, the Ministry of the
Environment of the Government of the State of Mexico, complemented by researchers from the
National Autonomous University of Mexico and members of the German Technical Cooperation
Agency (GTZ) and other public and private institutions.
FROM Cromatos de México toxic grave, diav.com.mx/archivo/2006/octubre/htm/cromatos_mexico.htm, María Eugenia Pérez,

2006.
D1 Report Toxic Cemetery of Cromatos de México Lechería Region, Municipality of Tultitlán, State of Mexico/ 45 years of
damage to the Environment, page. 23, Federal Deputy Professor Santiago Cortés Sandoval, 2004 -
One of the results of this coordination table was the preparation of a Master Remediation Plan, which
included geo-electrical, geological and geophysical surveys, the topographic survey of a map to
determine the existing wells in a five-hectare perimeter.2 .
The total conception of the investigation for the remediation master plan, prepared in June 2002 jointly
by SEMARNAT and the German Technical Cooperation Agency (GTZ), was finalized with a request
for funding from the Rietzler & Heidrich GmbH (R&H) consortium. /GEO4 GmbH (GEO4), addressed
to the Bavarian Ministry of the Environment in April 2004.
The concept included 4 phases or stages:
The first phase (“Stage I”) consisted of an in-depth historical study of the site, which was carried out
between August and September 2004 by SEMARNAT under the direction of M. in I. María Rocha
Jimenez and Eng. Wilberth Raúl Alfaro Rejón coordinated by the German Technical Cooperation
Agency (GTZ). On November 15, 2004, the complete results were presented to the Bavarian
consortium (ARGE R&H/GEO 4) by SEMARNAT.
As a second step, between November and December 2004, the ARGE R&H/GEO 4 carried out a site
orientation investigation (“Stage IIA”), using, among other methods, soil analysis by area, reaching
depths of up to 10 meters. low ground level (mbnt), geophysical investigations with drilling probes and
2Report Toxic Cemetery of Cromatos de México Lechería Region, Municipality of Tultitlán, State of Mexico/ 45 years of
damage to the Environment, page. 23, Federal Deputy Professor Santiago Cortés Sandoval, 2004.
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groundwater sampling in nearby drinking and multi-use water wells. The results of this “IIA” phase
were summarized and evaluated in an interim report. As a consequence of this report, adaptations are
established in the concept and research measures to be carried out in the following stages.
Starting in August 2004, within the framework of a first joint project, the Ministry of the Environment
and Natural Resources (SEMARNAT) and the Free State of Bavaria through the “Transfer of Water
Technologies” (TTW) project promoted research and the development of a comprehensive cleanup
concept for the CROMATOS contaminated site.
The third step (“Stage IIB”), consisting of a detailed investigation of the soil and groundwater, was
carried out between March and November 2005 by the consortium (ARGE R&H/GEO 4) coordinated
by the German Technical Cooperation Agency ( GTZ). During this stage, R & H carried out soil
analysis up to 35 meters deep, as well as the exploration of probable hanging aquifers. The GEO 4
company also carried out complementary measurements of the drilling and groundwater.
The results showed that area "C", where the confinement cells were located, were the ones where the
highest concentrations of hexavalent chromium were found with depths of up to 35 meters, area "B"
presented problems of high concentration of hexavalent chromium up to depths. of 6 meters and area
“C” the present contamination of hexavalent chromium was superficial up to 0.3 meters.
The areas monitored outside the Cromatos de México property, such as the “La Reforma” school and
streets surrounding the Colonia Lechería, did not present any type of hexavalent chromium
contamination.
For its part, SEMARNAT, in April 2006, carried out complementary drilling up to 30 meters deep
15
around the macro-cell . These drillings were carried out with the objective of collecting data from the
construction site in order to plan measures for securing, stabilizing and reopening the macro-
confinement cell.
As a last step, between November 2005 and March 2006, several sanitation tests and trials were
carried out by immobilizing contaminants within the soil.
With the results of all the investigations and within the framework of the “study of alternatives”
(preparatory to Stage III), the R&H company specifies and develops the comprehensive concept for
the isolation and sanitation of the “CROMATOS” site, called “Case of the remediation of the Cromatos
de México environmental liability in Tultitlán State of Mexico, Orientation and Detail Characterization
and Alternative Studies.
Recommending, on this basis, the prompt start of planning and execution of sustainable sanitation of
the contaminated site.
In November 2007, the Board of Directors of the Chamber of Deputies of the honorable Congress of
the Union, issued official letter number DGPL 60-II-5-1152, signed by deputies Ruth Zavaleta Salgado
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and Antonio Xavier López Adame, President and Secretary, respectively, through which they informed
Mr. Francisco Ramírez Acuña, Secretary of the Interior, about the point of agreement approved in the
session held on November 6 of the current year, through which the Chamber of Deputies respectfully
urges the Ministry of Finance and Public Credit of the federal Executive Branch so that, within the
scope of its powers and in coordination with the Secretariat of Environment and Natural Resources, it
assigns the federal budget resources necessary to clean up
------------------------------------------
Instead of building a deep monitoring well.
comprehensive the area where the company Cromatos de México, SA was located, in the municipality
of Tultitlán, State of Mexico, considered one of the sites in the country with the highest degree of
contamination by hazardous waste.
In the same document, the Chamber of Deputies also makes a respectful request that the National
Water Commission, based on the powers conferred upon it by law, proceed to clean up, as a priority,
the water tables in the area where it was located. the company Cromatos de México, in Tultitlán, State
of Mexico, in accordance with the technical and budgetary guidelines that that same entity determines.
On December 19, 2007, SEMARNAT responded to the previous point of agreement to Mr. Armando
Salinas Torre, Undersecretary of Legislative Liaison Secretariat of the Interior, to which a summary is
presented:
This Secretariat is fully willing to coordinate with the Secretariat of Finance and Public Credit so that,
once the necessary federal budgetary resources have been assigned, they are invested in the
comprehensive sanitation of the site, in accordance with the master remediation plan, which consists
of the treatment and final disposal of the waste and definitive solution to the case. To this end, as a
first action, a technical work committee has been established made up of personnel from the different
instances of this Secretariat with powers in the matter to analyze the different alternatives for the
treatment and comprehensive solution of the site, in order to select the most appropriate alternative.
viable to carry it out.
SEMARNAT also states that of the budgetary resources authorized to this sector annually, it has
reallocated and allocated, in accordance with applicable regulations, the greatest possible amount for
the remediation of this site. During the first phase of the remediation of this place in 2007, the
federation has invested 14 million pesos to carry out the demolition and final disposal works of the
buildings and structures that were part of the former factory.
However, SEMARNAT has continuously managed with the SHCP the authorization of that agency so
that, in fiscal year 2008, a budget increase is carried out for the General Directorate of Comprehensive
Management of Materials and Risky Activities of this Secretariat to continue with the comprehensive
sanitation of the site in question, in accordance with the project that that area is developing. In
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response, the SHCP confirmed to SEMARNAT its willingness to budgetarily support the allocation of
additional resources for this project up to the amount and conditions required.
SEMARNAT, through the Senior Official's Office, the Undersecretariat of Management for
Environmental Protection and the SHCP, designed the most convenient budgetary and legal
mechanism for the development of the comprehensive environmental remediation project for the site,
with the understanding that it will be a project medium-term to long-term investment that must be
monitored for at least 3 and up to 10 years.
Once the design of the comprehensive remediation project for the site was completed, which occurred
in the first quarter of 2008, and the procedures began before the SHCP for the budget increase for the
remediation of the property occupied by Cromatos de México, during the years 2008, 2009, 2010,
2011 and 2012.
IV .- REGULATORY FRAMEWORK APPLICABLE TO THE ACTIONS CARRIED OUT

DURING THE IMPLEMENTATION OF THE PROGRAM
V .1.- Internal Regulations of the Ministry of Environment and Natural Resources
In accordance with Article 28, the General Directorate of Comprehensive Management of Risky
Materials and Activities has the following powers regarding the remediation of contaminated soils and
sites in accordance with sections I, III, IV, VII, VIII, XXI, XXV and XXVI:
I .- Apply the general policy on hazardous materials, substances and waste, the
remediation of sites contaminated by them and highly risky activities, as well as participating
in their formulation with the competent administrative units of the Secretariat;
III .- Coordinate with federal entities and municipalities to formulate and execute
remediation programs in sites contaminated with hazardous waste that are abandoned or
whose owner or holder is unknown in accordance with the applicable legal provisions;
IV .- Assist with the administrative units and competent deconcentrated bodies of the Secretariat, in
the promotion before the governments of the federal and municipal entities, of the local
institutional strengthening in matters of environmental risk assessment generated by the
management of hazardous waste and its reduction in the source, as well as for the attention
of contaminated sites and the carrying out of risky activities at the local level;
VII .- Develop technical criteria for the prevention and control of pollution of the
soil for hazardous materials and waste;
VIII .- Propose to the Undersecretariat of Management for Environmental Protection, the projects
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declaration of remediation of contaminated sites in those cases in which the intervention of

the Federation is warranted, as well as the corresponding justifying studies;
XXI .- Evaluate the actions for the remediation of contaminated sites that are proposed in the
respective programs, and determine the appropriate remediation actions;
XXV .- Participate with the competent administrative units in the development and application of the
National Program for the Prevention and Comprehensive Management of Waste and the
Remediation of Contaminated Sites;
XXVI .- Prepare, in coordination with administrative units and decentralized bodies, inventories of
hazardous waste and sites contaminated with them;
(LGPGIR)
Second Title, Distribution of powers and coordination, powers of the three levels of government and
coordination between agencies.
Article 7.- Powers of the Federation:
YO.- Formulate, conduct and evaluate the national waste policy as well as
develop the National Program for the Prevention and Comprehensive Management of Waste
and the Remediation of Sites Contaminated with it, within the framework of the National
Democratic Planning System, established in article 25 of the Political Constitution of the
United Mexican States;
XX.- Design and promote mechanisms and voluntary actions aimed at preventing and minimizing the
generation of waste, as well as the contamination of sites;
Title Five, Comprehensive management of hazardous waste, Chapter V “Responsibility regarding

contamination and remediation of sites.”
Article 72.- In the case of contamination of sites with dangerous materials or waste, due to a fortuitous
event or force majeure, the competent authorities will impose the necessary emergency measures to
deal with the contingency, in order not to put health or the environment at risk. atmosphere.
Article 73.- In the case of abandonment of sites contaminated with hazardous waste or in which the
owner or possessor of the property is unknown, the Secretariat, in coordination with the federal entities
and the municipalities, may formulate and execute remediation programs, with the purpose that the
necessary actions are carried out for its recovery and reestablishment and, if possible, its
incorporation into production processes.
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The Secretariat will be empowered to make effective the guarantees that have been granted by those
responsible who have abandoned the site. In those cases in which the contamination of the site
warrants the intervention of the Federation, the head of the Federal Executive may issue the
declaration of remediation of contaminated sites. For this purpose, it will previously prepare the studies
that justify them.
The declarations must be published in the Official Gazette of the Federation and will be registered in
the corresponding Public Property Registry and will express:
^ The delimitation of the site that is subject to remediation, specifying surface area, location
and boundaries;
^ The actions necessary to remedy the site, in accordance with what is established in this
Law;
^ The conditions and restrictions to which the site will be subject, the uses of the land, the
use, as well as the performance of any work or activity;
^ The guidelines for the preparation and execution of the corresponding remediation program,
as well as the participation in said activities of owners, possessors, social and private
organizations, local governments and other interested persons, and
^ The deadlines for the execution of the respective remediation program.
Once the remediation program of the contaminated site is completed, the corresponding annotation in
the Public Property Registry will be canceled.
IV.3.- Regulations of the LGPGIR

Chapter II, Remediation Programs.
Article 132.- Remediation programs will be formulated when a site is contaminated as a result of an
emergency or when there is an environmental liability.
An emergency exists, for the purposes of this Chapter, when the contamination of the site derives from
a circumstance or event, unwanted or unexpected, that occurs suddenly and that results in the
uncontrolled release, fire or explosion of one or more hazardous materials or hazardous waste. that
affect human health or the environment, immediately.
Environmental liabilities are considered to be those sites contaminated by the release of hazardous
materials or waste, which were not remediated in a timely manner to prevent the dispersion of
contaminants, but which imply a remediation obligation.
This definition includes pollution generated by an emergency that has effects on the environment.
Article 133.- In the preparation of the remediation program, the interested party may determine the
remediation actions that will be integrated into the corresponding proposal, based on what is
established in the applicable official Mexican standards or, if these do not exist, the levels of
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remediation that are determined based on the environmental risk assessment study carried out.
Article 134.- The remediation programs, as appropriate, are integrated with:
I. Characterization studies;
II. Environmental risk assessment studies;
III. historical research, and
IV. Remediation proposals.
The remediation programs will be prepared based on the characterization study and, where
appropriate, the environmental risk assessment. Historical investigations will also be considered in the
development of remediation programs for environmental liabilities.
The purpose of these investigations will be to establish the activities causing the environmental
damage carried out at the contaminated site, the events that led to the contamination of the soil,
subsoil and aquifers, the geohydrological conditions that prevailed at the site, based on documentary
information. , as well as the list of those who have been possessors and the uses that the property or
properties have had in which the contaminated site is located.
CHAPTER IV, Declarations of Remediation
Article 152.- The formulation and execution of the remediation programs indicated in article 73 of the
Law may be carried out in coordination by the Secretariat and the competent local authorities.
The coordination referred to in the previous paragraph may be carried out through agreements in
which the participation of each of the authorities of the three levels of government and the human,
financial and material resources that each of them will contribute are defined.
The remediation program will be annexed to the coordination agreement and will be registered by the
local authorities in the public registry of the corresponding property.
Article 153.- In cases in which, in the opinion of the Secretariat, the intervention of the Federation is
necessary in the remediation of an abandoned site contaminated with hazardous waste and after the
corresponding justifying study, it will prepare and propose to the Head of the Federal Executive the
declaration to referred to in article 73 of the Law.
When the state or municipal authorities request the issuance of the remediation declaration, they will
prepare the respective supporting technical studies at their own expense and present them to the
Secretariat for evaluation.
IV .4.- DECREE of Temporary Occupation of an area of 35,344.13 square meters located on

Francisco I Street. Madero number 30, Colonia Lechería, in the Municipality of Tultitlán, State of
Mexico, published in the Official Gazette of the Federation, on November 30, 2006 and February 1,
2007.
V .5.- DECREE by which the area of 35,344.13 m2, located on Francisco I street, is
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expropriated . Madero number 30, Lechería neighborhood, in the Municipality of Tultitlán, State of
Mexico, published in the Official Gazette of the Federation on December 17, 2010.
VI .- LINKAGE OF THE PROGRAM WITH THE PND (2007-2012) AND PSMAYRN (2007)
2012)
VII .1.- National Development Plan (2007-2012)
The program “Monitoring risk containment actions, site preparation and remediation of the property
located on Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico (former
Cromatos de México factory)”, is linked to the National Development Plan (2007-2012) through the
guiding axis of “Environmental Justice”, in its objective 12. Reduce the environmental impact of waste
and in its Strategy 12.4 Promote the remediation of soils in contaminated sites.
For the effective remediation of contaminated sites, it will be necessary to develop the national
inventory of contaminated sites and carry out actions for their remediation, in order to prevent and
reduce risks to health and the environment using the best available technologies. The necessary
resources must be managed for coordinated work with states and municipalities.
VIII .2.- Environment and Natural Resources Sector Program (2007-2012)
Cromatos de México factory)”, is linked to the Sectoral Program of Environment and Natural
Resources (2007-2012), through the axis of Pollution Prevention and Control , in Objective 3.
“Consolidate the regulatory framework and apply policies to prevent, reduce and control pollution,
carry out comprehensive waste management and remediate contaminated sites to guarantee
adequate quality of air, water and soil”; Strategy 3. “Have comprehensive and transversal
management that is efficient and effective for the remediation of contaminated sites.”
Lines of action:
• Develop the Systematized Information System on the Inventory of Contaminated Sites in the
country (SISCO).
• Prepare the National Remediation Program for Contaminated Sites.
• Develop training and management programs regarding the remediation of contaminated sites
to increase the capacity to respond to national problems, along with efficiency and
effectiveness, and establish citizen and sector consultation systems to ensure decision-
making.
• Consolidate the legal framework so that the necessary instruments are established for the
prevention, management, remediation and reuse of contaminated sites and that allows the
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use of the relevant economic instruments to prevent contamination and promote its
remediation.
VI.- EXECUTIVE SYNTHESIS OF THE PROGRAM
The background to the program “Follow-up of risk containment actions, site preparation and
remediation of the property located on Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán,
State of Mexico (former Cromatos de México factory)”, come from the work carried out by the
Technical Coordination table that brought together all
the interested authorities of the three levels of government (Municipality, State and Federation), made
up of the Undersecretary of Management for Environmental Protection and the Federal Attorney for
Environmental Protection, of SEMARNAT; the Secretariat of Ecology of the Government of the State
of Mexico, the City Council of Tultitlán, the Delegation of SEMARNAT in the State of Mexico, the
College of Geological Engineers of Mexico, the General Secretariat of Government and Health of the
State of Mexico, and the German Agency for Technical Cooperation (GTZ).
Cromatos de México factory)”, continued its work in a coordinated manner between SEMARNAT and
the German Cooperation Agency GIZ in the period 2004-2006, who through the consulting firms of
Bavarian engineering companies Dr. Rietzler & Heidrich GmbH (R&H) of Nuremberg and GEO4
GmbH (GEO4) of Oberbrunn, the comprehensive concept for the isolation and sanitation of the
“CROMATOS” site was developed, presenting the results in the report called “ CROMATOS de
México SA de CV ", in Tultitlán, State of Mexico, Characterization of orientation and detail,
Study of Alternatives", before the staff of SEMARNAT, of the Government of the State of Mexico, of
the Municipality of Tultitlán. The total investment amount of the project was 260 thousand euros, the
financing was distributed as follows:
• Promotion of the BStMUGV (State of Bavaria): 60% (156 thousand euros)

• Contribution from SEMARNAT (Mexico): 25% (65 thousand euros)
• Contribution from R&H/GEO4 (State of Bavaria): 15% (39 thousand euros)
The report by Dr. Rietzler & Heidrich GmbH (R&H) was the initial basis for the planning of the projects
in the years 2007 to 2010 under the Temporary Occupation Decree and later studies were updated
in the period 2011, for the planning and execution of soil and subsoil remediation works that were
carried out during the period of 2011 2012 under the Expropriation Decree.
It should be noted that for the first project that was carried out in the year 2007-2008, it was executed
under the protection of the General Collaboration Agreement between the Government of the State of
Mexico and SEMARNAT signed on December 21, 2001 and modified on January 30. of 2004.
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Table 1. “Studies (E) and Projects (P) carried out in the period 2007-2012”.
Guy Project or Study Name Description Year
Disposal of remaining waste; Chemical analysis;

“Actions to contain the risk and prepare the site for demolition of the structures of the ruined
carrying out the remediation works that are essential to industrial center and concrete structures of the
reduce the risks to human health and the environment, property; dismantling of blacksmith shops;
Q 2007-2008
in the former Cromatos de México factory, located in excavation of contaminated areas; treatment of
the Municipality of Tultitlán, State of Mexico (Demolition the demolished material and part of the
and final disposal of the ruins of the former factory).” contaminated soil, as well as its final disposal in
confinement authorized by SEMARNAT.
“Risk containment actions and site preparation in the

demolition works of Cell C1 and part of Cell C2, of the Demolition of reinforced concrete of the
property of the former Cromatos de México factory in perimeter walls; extraction to remove material
the Lechería neighborhood, in the Municipality of contained in cell C1; placement of 1 mm thick
Q Tultitlán, State of Mexico” . tarp to cover bare surface; filling and compacting 2008
uncovered areas with clean material of subgrade
quality and loading, transportation and final
disposal at an authorized site.
“Actions to contain the risk and prepare the Cromatos

site for remediation: complementary works on the Demolition of reinforced concrete of the
property and in the remaining part of cell C2.” perimeter walls; extraction to remove material
contained in cell C2; placement of 1 mm thick
tarp to cover bare surface; filling and compacting
Q 2010
bare areas with clean subgrade quality material;
placement of cyclonic mesh and loading,
transportation and final disposal in an authorized
site.
“Sampling work to update the magnitude of

contamination of the property located on Francisco I Complementary characterization work (sampling
Street. Madero No. 30, Colonia Lechería, Tultitlán, and analysis), for taking 123 samples (11
State of Mexico" with an area of 35,344.13 m2." superficial and 112 from vertical wells), analysis
of the hexavalent chromium parameter,
preparation of three-dimensional concentration
AN
modeling plans in 2011
D
horizontal and vertical perspective in order to
obtain the update of the area and volume of
contaminated soil and subsoil up to 20 meters
deep that allow analyzing the degree of advance
or migration of the contaminant in the soil.
“Preparation of an Environmental Risk Assessment

(ERA) study of the property located on Francisco I Identify the risks to health and the environment
Street. Madero No. 30, Colonia Lechería, Tultitlán, arising from contamination of the soil and
AN State of Mexico.” subsoil, once the risk containment work has been
2011
D completed; as well as the proposal of criteria for
its cleaning and viable technologies based on the
acceptable risk.
“Executive project of the works for the remediation of

contaminated soil on the property located on Francisco Based on the results obtained from the
I Street. Madero No. 30 Colonia Lechería, Tultitlán, Environmental Risk Characterization and Study
State of Mexico.” projects, develop the set of plans and documents
AN that make up the engineering projects, the
2011
D catalog of concepts, as well as the descriptions
and sufficient information to execute the
engineering works to soil and subsoil
remediation.
AN “Technical-Economic Evaluation of Technology

Carry out the technical and economic evaluation 2011
D Technologies
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Guy Project or Study Name Description Year

Chromium removal for remediation of the Cuautitlán- from pilot-scale studies on site and in the
Pachuca Aquifer". laboratory to select the best technology or
treatment train for chromium removal as a
remediation method for the Cuautitlán-Pachuca
aquifer. Develop the executive project of a 10 L/s
treatment plant to remove chromium from the
water of the Cuautitlán-Pachuca aquifer and
determine the transport parameters of chromium
in the subsoil that serve as input data for a
hydrological mathematical model for the
simulation of various remediation scenarios.
^Drilling of 9 exploratory wells and extraction for the

remediation of the Cuautitlán-Pachuca aquifer, locally Build nine wells of
contaminated by chromium, in Tultitlán, State of exploration/extraction in order to begin
Mexico^. preparations for the implementation of a
pumping-treatment system necessary to remedy
the Cuautitlán-Pachuca aquifer, locally
contaminated in the Lechería area, municipality
of Tultitlán, State of Mexico. The wells have the
purpose of obtaining more accurate knowledge
Q about the extent of the contaminant stain in the 2011-2012
horizontal and vertical planes; Particularly, it is
desired to know if the contaminant has migrated
to depths greater than 200 m. The wells will help
define the subsurface stratigraphy, the hydraulic
properties of the aquifer at those depths, and the
groundwater flow system. As a result of this
project, the most contaminated horizons will be
identified.
“Engineering works for the remediation of contaminated

soil on the property located on Francisco I Street. Carry out engineering works for the remediation
Madero No. 30, in Colonia Lechería, Tultitlán, State of of the site, through excavation, loading,
Mexico.” transportation and final disposal of soil
contaminated with hexavalent chromium; filling
and compacting excavated areas with material;
Q 2011-2012
placement of geomembrane in the excavated
areas; placement of asphalt layer in the total
area of the site, construction of foundations and
footings for placement of the perimeter wall and
tubular steel doors.
Q “Protection of four exploratory-extraction wells for the 2012

remediation of the Cuautitlán-Pachuca Aquifer locally Construction of 4 protective boxes in 4
contaminated by chromium; demolition-construction of exploratory/extraction wells; demolition of
contaminated sidewalks on the property located on sidewalks with an estimated volume of 55 m 3 of
Francisco I Street. Madero No. 30 Colonia Lechería, concrete from the perimeter areas external to the
Tultitlán, State of Mexico perimeters and preparation of boundary walls of the property; Carrying out the
signs” transport service in cargo trucks, of an
approximate volume of 55 m 3 of debris
measured on a bench; as a product of the
demolition of the sidewalks, to the site authorized
by the municipality; Construction and restoration
of sidewalks in an estimated area of 520 m 2 ,
with concrete to be used, located in the perimeter
areas external to the delimiting walls of the
referred property and final design, preparation
and placement of 5 vertical signs of 1m wide x
1.50m thick. height of galvanized sheet with
restrictive, preventive and informative signs.
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VII.- ACTIONS TAKEN
VII.1.- Work program
The project “Follow-up of risk containment actions, site preparation and remediation of the property
Cromatos de México factory)”, since the beginning of its activities in 2007, it was part of one of the
components of the Annual Work Program of the Environment and Natural Resources Sector during
the period from 2007 to 2012, which has been part of the monitoring and evaluation of the goals and
indicators established in the Sectoral Program in question. The specific goal to which the project
reports is number 34.
Table 2. Alignment with the Sectoral program.
STRATEGY 3 HAVE A COMPREHENSIVE AND CROSS-CUTTING MANAGEMENT THAT IS EFFICIENT AND

EFFECTIVE FOR THE REMEDIATION OF CONTAMINATED SITES
LINE OF ACTION DEVELOP TRAINING AND MANAGEMENT PROGRAMS REGARDING THE REMEDIATION OF
CONTAMINATED SITES TO INCREASE THE CAPACITY TO RESPONSE TO NATIONAL
PROBLEMS, ALONG WITH EFFICIENCY AND EFFECTIVENESS, AND ESTABLISH CITIZEN AND SECTOR
CONSULTATION SYSTEMS TO ENSURE DECISION MAKING
Table 3. Goal and indicators of the PSMAyRN (2007-2012).
GOAL 34 SUPPORT THE MANAGEMENT AND FOLLOW UP THE REMEDIATION ACTIONS OF SEVEN
CONTAMINATED SITES CONSIDERED AS ENVIRONMENTAL LIABILITIES
RESPONSIBLE UNDERSECRETARY OF MANAGEMENT FOR ENVIRONMENTAL PROTECTION/GENERAL

DIRECTORATE OF COMPREHENSIVE MANAGEMENT OF RISKY MATERIALS AND ACTIVITIES.
It should be noted that the project “Follow-up of risk containment actions, site preparation and
remediation of the property located on Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán,
State of Mexico (former Cromatos de México factory)” was considered a critical site and a red light due
to the impact on the environment and health, the complexity and magnitude of which required a multi-
year work effort.
The main activities were:
• Support to administrative and financial management.
• Support and monitoring of the awarding processes of projects and studies

made.
• Monitoring and supervision of remediation actions.
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VII.2.- Budget and authorized spending schedule
For the project “Follow-up of risk containment actions, site preparation and remediation of the property
Cromatos de México factory)”, the existing financial mechanisms in the legal framework were used
since the formalization of coordination agreements with the Government of the State of Mexico, the
accessibility of resources to through the Biodiversity Fund in the concept of Environmental
Remediations of the National Commission for the Knowledge and Use of Biodiversity (CONABIO) and
budget authorized to SEMARNAT itself in the concept of remediations of contaminated sites.
Table 4. Authorized Annual Budget.
Guy Project or Study Name Instrument used Year Authorized Budget
Agreement General of
“Actions to contain the risk and prepare the site Collaboration between the
for carrying out the remediation works that are Government of the State of Mexico
essential to reduce the risks to human health and and SEMARNAT signed on
Q the environment, in the former Cromatos de December 21, 2001 and modified 2007 $25,000,000.0016
México factory, located in the Municipality of on January 30, 2004.
Tultitlán, State of Mexico (Demolition and final
disposal of the ruins of the former factory).”
Federation Expenditure Budget.

“Risk containment actions and site preparation in
the demolition works of Cell C1 and part of Cell
Q C2, of the property of the former Cromatos de 2008 $ 92,900,000.00
México factory in the Lechería neighborhood, in
the Municipality of Tultitlán, State of Mexico” .
Federation Expenditure Budget

“Actions to contain the risk and prepare the
Cromatos site for remediation: complementary
Q 2009 $192,898,331.00
works on the property and in the remaining part
of cell C2.”

“Actions to contain the risk and prepare the
Cromatos site for remediation: complementary
Q 2010 $115,870,615.00
works on the property and in the remaining part
of cell C2.”
AN “Sampling work to update the magnitude of the Biodiversity Fund resources for the
2011 $1,500,000.00
D contamination of the property concept
Resources contributed through the Biodiversity Fund for the concept of Environmental Remediations of the National Commission for the
Knowledge and Use of Biodiversity (CONABIO) for $14,000,000.00 and Resources contributed through the Technical Committee of the
Metropolitan Environmental Trust for $11,000,000.00.
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Guy Project or Study Name Instrument used Year Authorized Budget
located on Francisco I Street. Madero No. 30, of Environmental Remediations of

Colonia Lechería, Tultitlán, State of Mexico" with the Commission.
an area of 35,344.13 m2."
Resources from the Biodiversity

“Preparation of an Environmental Risk Fund for the Commission's
AN Assessment (ERA) study of the property located Environmental Remediation 2011 $1,400,000.00
D on Francisco I Street. Madero No. 30, Colonia concept.
Resources from the Biodiversity

“Executive project of the works for the Fund for the Commission's
AN remediation of contaminated soil on the property Environmental Remediation 2011 $600,000.00
D located on Francisco I Street. Madero No. 30 concept.
Colonia Lechería, Tultitlán, State of Mexico.”

"Assessment Technical-Economic of
AN
Chromium Removal Technologies for 2011 $6,000,000.00
D
remediation of the Cuautitlán-Pachuca Aquifer.
“Drilling of 12 exploratory wells and extraction for Federation Expenditure Budget

the remediation of the Cuautitlán-Pachuca
Q 2011 $40,000,000.00
aquifer, locally contaminated by chromium, in
Tultitlán, State of Mexico.”

“Engineering works for the remediation of
contaminated soil on the property located on
Q 2011 $85,774,975.34
Francisco I Street. Madero No. 30, in Colonia

“Engineering works for the remediation of
contaminated soil on the property located on
Q 2012 $85,408,443.46
Francisco I Street. Madero No. 30, in Colonia
“Protection of four exploratory-extraction wells for Resources from the Biodiversity

the remediation of the Cuautitlán-Pachuca Fund for the Commission's
Aquifer locally contaminated by chromium; Environmental Remediation
demolition-construction of contaminated concept.
Q 2012 $300,000.00
sidewalks on the property located on Francisco I
Street. Madero No. 30 Colonia Lechería,
Tultitlán, State of Mexico perimeters and
preparation of signs”
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VII.3.- Integration of executive projects
VII.3.1.- Executive project for the “Actions for Risk Containment and Preparation of the
site for carrying out the Remediation Works that are essential to reduce the
risks to human health and the environment, in the ex-factory of Cromatos de
México, located in the Municipality of Tultitlán, State of Mexico.”
The objective of the project.- Actions to contain the risk and prepare the site for carrying out the
remediation works that are essential to reduce the risks to human health and the environment in the
former Cromatos de México factory, for which It requires the demolition of the buildings and facilities of
the former factory, excavation of contaminated soils that represent a risk of exposure to the population,
their transportation, treatment and final disposal in an authorized hazardous waste confinement and
the preparation of the site for the carrying out remediation actions in the former “Cromatos de México”
factory located in the municipality of Tultitlán, State of Mexico. All of the above with strict industrial
safety and environmental protection measures.
Works to be executed .
• Demolish the hull of the former “Cromatos de México” factory (slabs, buildings, walls,
cisterns, etc.) and excavate the contaminated soils, with strict industrial safety and
environmental protection measures in order to prevent the emission of dusts and particles
and the dispersion of contaminants, guaranteeing the health and safety of the population,
workers and the protection of the environment,
• Transport all contaminated demolition and excavation products to an Authorized Controlled

Hazardous Waste Confinement.
• Treatment of hazardous waste to reduce Cr(VI) to Cr(III), and Disposal of treated waste in a
controlled confinement cell.
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The executive project was integrated as follows :
No. Document
1 General and Specific Project Specifications
1.1
Overview of demolition and excavation of contaminated soils
1.2 Disposal of remaining solid waste
1.3 Chemical analysis of the solid waste remaining on the site
1.4 Trace, demarcation and referencing
1.5 Disassembly of blacksmithing and others
1.6 Dismantling of cyclonic mesh on the perimeter of the property, its storage
and subsequent reinstallation
1.7 Closed comprehensive system for control and recovery of polluting dusts,
operation and maintenance
1.8 Extractor with integrated dust retention and collection
1.9 Powder storage system
1.10 Assembly and disassembly of the integral closed powder system in areas
other than the original assembly
1.11 Supply, installation and operation of water sprinkler system
1.12 Demolition of structures
1.13 Excavation of contaminated soil
1.14 Supply, placement, filling, shaping and compaction of clean material for filling
in area A
1.15 Enabling the waste loading and unloading area
1.16 Protection of material from demolition and excavation
1.17 Personal protection equipment
1.18 Filling of cisterns and sumps
1.19 Soil sampling and analysis of the excavation pits in area A
1.20 Hazardous waste treatment
1.21 Final disposal service in authorized controlled confinement
1.22 Repair of streets and restoration of services if necessary
No. Document
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1.23 Staff training
1.24 Cleaning the site once the work has been completed
1.25 Repair of streets and restoration of services if necessary
2 Catalog of concepts
3 Executive Project Plans
Plan No. 1 General plan, delimitation of areas
Plan No. 2 Toxic waste excavation sequence
Plan No. 3 Wall demolition sequence
Plan No. 4 Cyclonic mesh fence.
Plan No. 4r Landfill plan for property “A” and demolition of the floor for property “B”
4 Contingency, industrial safety and environmental protection plan
VII.3.2.- Executive project for “Risk containment actions and site preparation in the
demolition works of cell C1 and part of cell C2, on the property of the former
Cromatos de México factory in Colonia Lechería, in the Municipality of
The objective of the project.- Carry out the demolition of the walls of cell C1 (4.2 m height) and part of
cell C2 (3.0 m height) of the confinement area, extraction of the toxic waste that exists in the
confinement includes the extraction, transportation and treatment of hazardous waste, as well as its
final disposal in an authorized controlled confinement for the amount of 22,000 tons. All these actions
will be carried out using a high safety standard in order to prevent the dispersion of contaminants,
guaranteeing the health and safety of workers, the population and the protection of the environment,
through appropriate systems.
Works to be executed . Demolition of C1 and extraction of hazardous waste and part of C2 for the
amount of 22,000 tons.
• Trace and leveling of cell C1 and part of Cell C2 to quantify volumes.

^ Demolition of perimeter retaining wall built with reinforced hydraulic concrete.
^ Extraction of the cell residue.
^ Transportation of 22,000 tons of contaminated demolition and extraction products to an

Authorized Controlled Hazardous Waste Confinement.
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^ Treatment of hazardous waste to reduce Cr(VI) to Cr(III).
^ Disposal of treated waste in a controlled confinement cell.
^ Disposal of solid waste generated by workers during the development of the work.
^ Temporary protection of bare surface.
No. Document
EP-01 Layout and leveling for the demolition of cell C1 and part of cell C2
EP-02 Demolition of reinforced concrete of the perimeter walls with a maximum

height of 4.5 meters from the natural terrain, variable width, sectioning or
fragmenting into manageable sections for removal and subsequent
transportation
EP-03 Extraction for removal of material contained in cell C1 or C2 in any type of

material and consistency, at any height.
EP-04 Acquisition, supply, installation, maintenance, placement and transportation

within the work of 1 mm thick canvas, to cover surface discovered after
excavation
EP-05 Protective layer of 30 cm average thickness, constructed with subgrade

quality bench material, compacted to a minimum of
80% according to AASHTO standard test
EP-06 Truck loading of material product of demolition and/or extraction

contaminated with chrome vi from the work area
EP-07
Transportation by truck of material from demolition and/or extraction
contaminated with chromium VI from the work area to the treatment site
EP-08 Treatment of hazardous waste from material resulting from demolition and/or
extraction contaminated with chromium VI from the work area
EP-08 Final disposal service in authorized controlled confinement
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No. Document
EP-09 Construction of hydraulic base of 30 cm compact thickness, per unit of

finished work
Recovery of the existing pavement with a thickness of 25 cm, loading,

EP-10
transportation and unloading on property “A” of Cromatos
EP-11 Compact 30cm thick hydraulic base construction
EP-12
Supply and laying of TMA hot mix asphalt 3/4, thickness 10.00 cm,
EP-13 Supply and placement of 2.5 m PVC-coated cyclone mesh. total height, with
2 1/2" diameter galvanized 16 gauge pipe post and 1 1/2" diameter
galvanized 16 gauge pipe crossbars with top finial (sword) through barbed
wire
Plan No. 4 Cyclonic mesh fence.
4 Contingency, industrial safety and environmental protection plan
VII.3.3.- Executive project for “Actions for Risk Containment and Preparation of the
Chromate Site for Remediation. Complementary Works on the Property and in
the remaining part of cell C2.”
The objective of the project.- Carry out the demolition of the remaining walls of the perimeter of cell C2
(3.0 m high) of the confinement area, excavation of the hazardous (toxic) waste that exists inside the
cell, demolition of floor in property “B” and excavation to a variable depth in the floor demolition area,
extraction of the material, protection of the exposed surface with a 1.0 mm thick canvas and a 30 cm
layer of clayey silt material and filling the property "TO"; transportation and final disposal of hazardous
waste. All these actions will be carried out using a high safety standard in order to prevent the
dispersion of contaminants, guaranteeing the health and safety of the
________________________________________________________________________________
workers, the population and the protection of the environment, through appropriate systems.
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Works to be executed .
a) Trace and level in cell C2 to quantify volumes.

b) Demolition of perimeter retaining wall made of reinforced hydraulic concrete.
c) Excavation of cell production residue.
d) Landfill “A”.
e) Demolition of floor in Premises “B”.
f) Unloading in temporary storage area or vehicle for transportation.
g) Temporary protection of exposed surface.
h) Transportation and final disposal of demolished and excavated hazardous waste, which can
be subcontracted with one or more authorized companies.
No. Document
EP-01 Stroke and Leveling
EP-02 Demolition of retaining walls
EP-03 Excavations of material contained in the cell and natural terrain
EP-04 Bare surface protection
EP-05 Loading into vehicles to transport waste
EP-06 Cyclonic mesh placement
EP-07 Loading and transfer to authorized confinement
EP-08 Final disposal service in authorized controlled confinement
2 Memories of calculation
2.1 Layout and leveling for the demolition of cell “C2”
2.2 Demolition of reinforced concrete of the perimeter walls with a maximum

height of 3.0 meters, on the floor of cell “C1”
2.3 Excavation to remove material contained in cell “C2”
2.4 Placing 1 mm thick tarpaulin on exposed areas
3
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No. Document
2.5 30cm thick filling
2.6 Loading of the excavated hexavalent chromium material into a truck.
2.7 Cyclonic mesh placement
2.8 Layout and leveling of property “A”
2.9 Filling excavation with subgrade quality bench material
2.10 Demolition of reinforced concrete floor slab in “C1”
2.11 Truck transport of hexavalent chromium
2.12 Final disposal service in authorized confinement
Plan No. 4 cyclonic mesh fence
5 Guidelines for the Contingency Plan
6 Guidelines for the Industrial Safety Plan
VII.3.4.- Executive project for the “Engineering Works for the Remediation of the
contaminated soil on the property located on Francisco I Madero Street No.
30, in Colonia Lechería, Tultitlán, State of Mexico”
The objective of the project - Carry out engineering works for the remediation of the site in order to
close or prevent the routes of exposure through inhalation, dermal contact and ingestion through soil
contaminated with hexavalent chromium to vulnerable receptors in the area of influence. of the
property located on Francisco I Madero Street No. 30, in Colonia Lechería, Tultitlán, State of Mexico.
As well as preventing the leaching of hexavalent chromium in the saturated zone of the soil towards
the aquifer.
Work to be executed
a) Layout and leveling of the work areas “B”, “C1”, “C2” and “Plot 3” establishing axes and
3
8
references.
b) Demolition of reinforced concrete elements in areas “B”, “C1” and “C2” in accordance with
what is indicated in the “Concrete demolition plan”.
c) Excavation to remove material contaminated with hexavalent chromium in areas “B”, “C1” and
“C2” in accordance with what is indicated in the “General Excavation Plan”.
d) Excavation of material in the “C2” area to a depth of 30 centimeters to compensate for the
filling in other areas of the same property.
e) Loading and hauling of material from the demolition and/or excavation of material
contaminated with hexavalent chromium from areas “B”, “C1” and “C2” to an authorized final
disposal site for hazardous waste.
f) Loading and hauling of debris material from the property called “3” to an authorized site of the
municipality.
g) Final disposal of the material or soil contaminated with hexavalent chromium in an authorized
hazardous waste site.
h) Placement of polyethylene geo-membrane in the excavated areas “B”, “C1” and “C2”.
i) Filling and compaction with bench material in the excavated areas “B”, “C1” and “C2”.
j) Supply and formation of hydraulic base layer in the excavated areas “B”, “C1” and “C2”.
k) Impregnation irrigation based on asphalt emulsion in the excavated areas “B”, “C1” and “C2”.
l) Manufacture of emulsified flexible asphalt pavement in the excavated areas “B”, “C1” and
“C2”.
m) Dismantling of the cyclonic mesh of the property located on Francisco I Madero Street No. 30,
in Colonia Lechería, Tultitlán, State of Mexico.
n) Supply and placement of hollow block with a section of 20x20x40 centimeters in the perimeter
area of the entire property located on Francisco I Madero Street No. 30, in Colonia Lechería,
Tultitlán, State of Mexico.
o) Manufacture of castles with an apparent finish in the perimeter area of the entire property
located on Francisco I Madero Street No. 30, in Colonia Lechería, Tultitlán, State of Mexico.
p) Manufacture of clearance gates and fencing chains in the perimeter area of the entire property
located on Francisco I Madero Street No. 30, in Colonia Lechería, Tultitlán, State of Mexico.
q) Supply and manufacturing of foundation footing for the perimeter wall of the property located
on Francisco I Madero Street No. 30, in Colonia Lechería, Tultitlán, State of Mexico.
r) Supply and placement of blacksmith doors on the property located on Francisco I Madero
Street No. 30, in Colonia Lechería, Tultitlán, State of Mexico.
No. Document
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EP-01 Stroke and Leveling
EP-02 Demolition of Concrete Elements
EP-03 Excavations
EP-04 Loading and Hauling
EP-05 Geo-membrane
EP-06 Filling and Compaction Material
EP-07 Transport to Authorized Confinement
EP-08 Final Disposition to Confinement
EP-09 Concrete Hollow Block Wall
EP-10 Doors and Blacksmithing
EP-11 Asphalt Binder
EP-12 Chains and Castles
EP-13 Pavement Structure Material
2 Work Volume Generator Sheets
2.1 Line and Leveling, area “B”, “C1” and “C2”
2.2 Demolition of armed elements in area “B”, “C1” and “C2”
2.3 Excavations in area “B”, “C1” and “C2”
2.4 Truck loading in area “B”, “C1” and “C2”
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No. Document
2.5 Geo-membrane in area “B”, “C1” and “C2”
2.6 Filling of material in area “B”, “C1” and “C2”
2.7 Supply and placement of blocks throughout the perimeter of the property
2.8 Blacksmith shop in area “A”, “B”, “C” and property “3”
2.9 Castles throughout the periphery of the property
2.10 Dalas throughout the periphery of the property
2.11 Zapata throughout the periphery of the property
2.12 Dismantling of mesh area “A”, “B” and “C”
2.13 Hydraulic base layer in area “A”, “B”, “C” and property “3”
2.15 Impregnation irrigation in area “A”, “B”, “C” and property “3”
2.16 asphalt pavement
2.17 Excavation with material recovery in “C2”
2.18 Loading and hauling on property “3”
2.19 Filling in property “3”
2.20 Hazardous waste transportation
2.21 Final disposal of hazardous waste
Topographic-01 Topographic plan with contour lines
Areas-02 General area plan
Demolition-03 Concrete demolition plan
Smithy-04 Blacksmith Plan
Mesh-05 Cyclone mesh plane
Est-Walls-06 Structural plans for foundations and walls
Details Wall-07 Structural plans for foundations and walls
Walls-08 Structural plans for foundations and walls
No. Document
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Excavation-13 General excavation plan
Filling P3-14 General plan of property “3”
Excavation C1/1-15 General plan of area “C1”
Pavement-28 Pavement plan
5 Guidelines for the Contingency Plan
6 Guidelines for the Industrial Safety Plan
VII.3.5.- Executive project “Drilling of 12 exploratory and extraction wells for the
remediation of the Cuautitlán-Pachuca aquifer locally contaminated by
chromium, Tultitlán, State of Mexico.”
The objective of the project.- Initiate the remediation of the locally contaminated Cuautitlán-Pachuca
aquifer in the Lechería area, municipality of Tultitlán, State of Mexico in its phase 1, consisting of the
conditioning of a pump-treatment system (SBT) through of the construction of twelve
exploration/extraction wells.
Works to be executed . 12 exploration/extraction wells will be built at four different sites. At each site
three wells will be located at different depths: ~130, ~200 and ~300 m. The order of drilling at each of
the sites is: first the ~130 m deep well, secondly the ~200 m deep well, and finally the ~300 m deep
well. In this way, 4 wells will be drilled with depths of around 130 m, 4 wells of 200 m and 4 wells of
300 m, with a total drilling length of approximately 2,520 m. Each well will be drilled to an exploratory
diameter of 31.12 cm (12 1/4”) with extensions to diameters of 31.12 cm (12 1/4”) to 63.50 cm (24”)
and 31.12 cm (12 1/4”) to 37.47 cm (14 3/4”), with core recovery at a diameter of 7.46 cm (2 15/16”) or
similar, placing 45.72 cm (18”) and 30.48 cm (12”) casing pipes. Additionally, the wells will be gauged
using a 15.24 cm (6”) pump.
• 4 wells around 130 m deep.

17
During the execution of the works, the scope was 9 wells, due to the change in the geological model found, the budget having to be
adjusted to the authorized one .
4
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^ 4 wells of the order of 200 m deep.
^ 4 wells of the order of 300 m deep.
^ Conventional core will be cut and recovered in each well.
No. Document
1 General and specific technical specifications
EP-01 Drilling rig movement up to a distance of 15 km
EP-02 Installation and dismantling of drilling equipment
EP-03 Drilling crew working in orderly operations
EP-04 Excavation and filling of sludge pits
EP-05 Exploration well driver
EP-06
Drilling mud and transportation and disposal of muds and cuttings material
EP-07 Transportation of water in pipe tank trucks, first kilometer and subsequent
kilometers to the first
EP-08 Well drilling
EP-09 Geophysical well logs
EP-10 Drilling expansion
EP-11 Continuous core cutting and recovery
EP-12 Placement of steel pipe for ademe
EP-13 PVC pipe laying
EP-14 Pipe cementing with drilling equipment
EP-15 Placement of gravel filter for well
EP-16 Well treatment with clay disperser
EP-17 Movement of pneumatic units
EP-18 Transportation of cement, bentonite, biodegradable and similar
EP-19 Development and capacity or pumping test
EP-20 cement plug
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No. Document
EP-21 Protective box
EP-22 Well video recording
EP-23 Border leveling
EP-24 Core transfer and analysis interpretation
EP-25 Groundwater Chemical Sampling and Analysis
EP-26 Preparation and delivery of final report
2 Memories of calculation
2.1
Movement of drilling equipment up to a distance of 15 km, with capacity up
to 450 meters deep, installation and dismantling
2.2 Excavation and filling of mud pits, using benthic mud or biodegradable mud
or air, water and foam as drilling fluids
2.3 Well drilling and expansions
2.4 Conventional core cutting and recovery
2.5 electrical logs
2.6 Pipe cementing with drilling equipment
2.7 Placement of gravel filter for well
2.8 Development and calibration or pumping test, with a 6” diameter pump
2.9 Pipe laying
2.10 Well video recording
2.11 Proposal completion sketch of each well
Plane-01 Proposed completion sketch plan for each well
VII.3.6.- Terms of reference “Sampling work to update the magnitude of contamination

of the property located on Francisco I Street. Madero No. 30, Colonia
Lechería, Tultitlán, State of Mexico" with an area of 35,344.13 m 2 ^^
Objective of the study.- Develop complementary characterization work (sampling and analysis) of the
property located on Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico, to
update the area and volume of contaminated soil and subsoil, once the work to contain the risk and
4
4
prepare the site for remediation consisting of the removal of the main source of contamination
(hazardous waste with hexavalent chromium in cells C1 and C2 and the ruins of the former factory).
Work to be executed :
^ Review, evaluation and systematization of all existing information in the General Directorate of
Comprehensive Management of Risky Materials and Activities (DGGIMAR) from the
sampling and environmental studies carried out previously.
^ Sampling activities on property A, B and C.
^ Analytical determinations of hexavalent chromium.
^ Construction of an information model to estimate the magnitude of pollution.
^ Preparation of iso-concentration plans for Hexavalent Chromium.
^ Dimension of the contaminated area and volume of soil and subsoil.
^ Integration of the final Characterization Report.
The terms of reference were integrated as follows :
No. Document
1 Technical specifications
1.1 Review and evaluation of information from existing sampling and

environmental studies
1.2 Sampling activities on property A, B and C
1.3 Analytical determinations of contaminants
1.4 Preparation of hexavalent chromium iso-concentration plans
No. Document
1.5 Dimension of the contaminated area and volume of soil and subsoil
1.6 Integration of the final characterization report
2 Forms of measurement of study concepts for payment purposes
3
Description of the procedure and program for the execution of services
4 Personal protection equipment.
5 Work schedule
6 Expected products
4
5
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VII.3.7.- Terms of reference ^^^^^^^^^^^^ ^^ ^^ Environmental Risk Assessment

(ERA) study of the property located on Francisco I Street. Madero No. 30,
Colonia Lechería, Tultitlán, State of Mexico.”
Objective of the study.- Identify the risks to health and the environment arising from contamination of
the soil, subsoil and aquifer of the property located on Francisco I Street. Madero No. 30, Colonia
Lechería, Tultitlán, State of Mexico, once the risk containment work was completed; as well as the
proposal of criteria for its cleaning and viable technologies based on the acceptable risk.
^ Compilation and systematization of all existing information in the General Directorate of

Comprehensive Management of Risky Materials and Activities (DGGIMAR) from
environmental sampling and studies.
^ Toxicometry of contaminants (Hexavalent chromium).
^ Exhibition evaluation.
^ Estimation of risk to the environment and health.
^ Cleaning criteria based on acceptable risk.
^ Viable remediation technologies based on acceptable risk.
^ Integration of the documentary series.
4
6
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No. Document
1.1 Compilation of information from existing sampling and environmental

studies
1.2 Toxicometry of priority pollutants
1.3 Exposure assessment
1.4 Estimation of risk to the environment and health
1.5 Cleaning criteria based on associated risks
1.6 Viable technologies based on associated risks
1.7 Integration of the documentary series
2 Description of the procedure and program for the execution of

services.
3 Work schedule
4 Expected products
VII.3.8.- Terms of reference “Executive project of the works for the remediation of
contaminated soil on the property located on Francisco I Street. Madero No.
30 Colonia Lechería, Tultitlán, State of Mexico.”
Objective of the study.- Carry out the Executive Project for the demolition of reinforced concrete slabs
and cisterns on properties B and C, excavation of the soils contaminated with hexavalent chromium on
properties B and C, transportation (of the contaminated soils and slabs). of concrete) off-site for final
disposal in controlled confinement. The project includes the filling of the excavated areas with a multi-
barrier system consisting of: capillary barrier in order to break the capillarity that due to the effects of
humidity would allow the rise of dissolved hexavalent chromium to the surface, a geo-textile mesh to
prevent the quality filler material from migrating towards the capillary barrier and could open veins for
the rise of dissolved chromium, fill with quality clean material, a sprinkle of asphalt emulsion as a
secondary vertical migration barrier, and at the surface level a barrier of asphalt concrete to seal the
ground; On edges and slopes, an isolation geo-membrane should be considered. All these actions
must be carried out using a high safety standard in order to prevent the dispersion of contaminants,
guaranteeing the health and safety of workers, the population and the protection of the environment,
through appropriate systems for minimizing dust generation. .
4
7
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^ Topographic Survey of area B and C1.
^ Design and detailed engineering of the demolition of the concrete slabs and cisterns buried in
properties B and C.
^ Detailed design and engineering of the excavation of the contaminated soil of properties B
and C from the level of the natural terrain (NTN) to a depth of 2.0 m in property B and 2.5 in
property C, including filling with the multi system -barriers.
^ Detailed design and engineering of the construction of the perimeter fence.
^ Specifications for the transportation and final disposal of contaminated soils and demolition
products.
^ Determination of the volumes of work of the included concepts.
^ Catalog of work concepts.
^ Construction budget.
^ Work program.
No. Document
1.1 Topographic survey area B and C1
1.2 Calculation and detailed engineering report on the demolition of the

concrete slabs and cisterns buried in properties B and C
1.3 Calculation and detailed engineering report on the excavation of the

contaminated soil of properties B and C from the level of the natural
terrain (NTN) to a depth of 2.0 m in property B and 2.5 in property C,
including filling with the system multi-barriers.
1.4 Calculation and detailed engineering report for the construction of the
perimeter fence on property A, property 3 and part of properties B
and C.
1.5 Specifications for the transportation and final disposal of soils
No. Document
contaminated and demolition products
1.6 Catalog of work concepts
1.7 Work budget
1.8 Job program
4
8
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2
Forms of measurement of service concepts for payment purposes
3 Description of the procedure and program for the execution of services
4 Personal protection equipment
5 Work schedule
6 Expected products
VII.3.9.- Terms of reference ^^^^^^^^^^^ ^^^^^^^-Economic of Chromium Removal

Technologies for remediation of the Cuautitlán Aquifer-^^^^^^^^^
Objective of the study.- Based on the technical and economic evaluation carried out from pilot and
laboratory scale studies, select the best technology or treatment train for chromium removal as a
remediation method of the Cuautitlán-Pachuca aquifer located in Tultitlán, State from Mexico. As well
as developing the executive project of a full-scale treatment plant to remove chromium from the water
of the Cuautitlán-Pachuca aquifer.
^ Analysis of the water quality of the test well and two surrounding wells to determine the
parameters established by NOM-127-SSA1 and other parameters of importance for the
treatment.
^ Evaluation of the effectiveness of four processes for chromium removal on a laboratory scale
and obtaining optimal conditions for their treatment.
^ Technical and economic evaluation of two technologies or treatment trains studied on a pilot
scale on site, and selection of the most suitable option for full-scale treatment.
4
9
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^ Executive project of a chromium removal plant for a flow rate of 10 L/s that treats water from the
Cuautitlán-Pachuca aquifer.
No. Document
1 Methodology
1.1 Aquifer water characterization
1.2 Selection of technologies for study in the laboratory
1.3 Laboratory scale tests
1.4 Selection of technologies for study on a pilot scale
1.5 Pilot studies
1.6 Technical-economic analysis of the technologies studied on a pilot scale
1.7 Executive design of a full-scale chromium removal plant
1.8 Final report
2 Schedule for the execution of activities or actions
3 Description of the procedure and program for the execution of services
5 Expected products
6 Payment calendar
VII.3.10.- Technical Annex “Protection of four exploratory-extraction wells for the

remediation of the Cuautitlán-Pachuca Aquifer locally contaminated by
chromium; demolition-construction of sidewalks on the property located on
Francisco I Street. Madero No. 30 Colonia Lechería, Tultitlán, State of Mexico
perimeters and preparation of signs”
Objective.- Complete the final finishing works of 4 exploration/extraction wells located on property C-2
on Francisco I Madero Street No. 30, in Colonia Lechería, Tultitlán, State of Mexico, to remedy the
Cuautitlán-Pachuca aquifer, locally contaminated in the Lechería area, as well as the execution of
urban harmonization and aesthetic restoration actions through the construction and restitution of
garrisons and perimeter sidewalks to the aforementioned site, contributing to the delimitation of the
property, the safety and health of surrounding pedestrians and thus contributing to the conclusion of
risk containment and remediation actions at the site of the Former Cromatos de México Factory.
5
0
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^ Construction of 4 protective boxes in 4 exploratory/extraction wells located on property C-2 on

Calle Francisco I Madero No. 30, in Colonia Lechería, Tultitlán, State of Mexico, for the
remediation of the locally contaminated Cuautitlán-Pachuca aquifer.
^ Carry out the demolition of the sidewalks with an estimated volume of 55 m3 of concrete from
the perimeter areas external to the delimiting walls of the property located on Francisco I
Madero Street No. 30, in Colonia Lechería, Tultitlán, State of Mexico and property No. 3
adjacent to the referred one.
^ Carrying out the transport service in cargo trucks, of an approximate volume of 55 m3 of debris
measured on a bench; as a product of the demolition of the sidewalks, to the site authorized
by the municipality.
^ Construction and restoration of sidewalks in an estimated area of 520 m2, with concrete to be
used, located in the perimeter areas external to the delimiting walls of the property on
Francisco I Madero Street No. 30, in Colonia Lechería, Tultitlán, State of Mexico and property
No. 3 adjacent to the referred one.
^ Final design, preparation and placement of 5 vertical signs of 1m wide x 1.50m high made of
galvanized sheet with restrictive, preventive and informative signs to be installed on the 5
access doors of the property on Francisco I Madero Street No. 30, in Colonia Lechería,
Tultitlán, State of Mexico and property No. 3 adjacent to the referred one.
The technical annex was integrated as follows :
No. Document
1 General and specific specifications
1.1 Well protection
1.2 Demolition of simple concrete elements of sidewalks
1.3 Loading, truck transportation, unloading and service at a site authorized by

the municipality
1.4 Construction work of perimeter sidewalks
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No. Document
1.5 Construction of Signs
3 Work Schedule
5 General location plan for sidewalks to be demolished and built
VII.4.- Documentation supporting the application of the Resources
VII.4.1.- Investment portfolios authorized by the SHCP and budget sufficiency
The execution of the projects of the program “Follow-up of risk containment actions, site preparation
and remediation of the property located on Francisco I Street. Madero No. 30, Colonia Lechería,
Tultitlán, State of Mexico (former Cromatos de México factory)”, were carried out in accordance with
the provisions of the Law of Public Works and Services Related Thereto, authorizing the investment
portfolios by the Secretariat of the Treasury and Public Credit, when the resources came from the
Expenditure Budget of the Federation.
Table 5 . Authorized investment portfolios
Wallet Key Name PPI Type Validity Investment amount
“Risk containment actions and site

preparation in the demolition works of
Cell C1 and part of Cell C2, of the
Other investment October 2008-
08167100001 property of the former Cromatos de $ 92,900,000.00
projects December 2009
México factory in the Lechería
neighborhood, in the Municipality of
Tultitlán, State of Mexico” .
“Actions to contain the risk and

Social
prepare the Cromatos site for
Infrastructure January-December
08167100001 remediation: complementary works on $192,898,331.00
Investment 2009
the property and in the remaining part
Project
of cell C2.”
5
2
Wallet Key Name PPI Type Validity Investment amount
October 2008-
“Actions to contain the risk and December 2010
prepare the Cromatos site for
Other investment
08167100001 remediation: complementary works on $115,870,615.00
projects
the property and in the remaining part
of cell C2.”
Works for the remediation of

contaminated soil and infrastructure of 2011: $125,774,475.00
monitoring/extraction wells for the
Other investment October 2011 to July 2012: $85,408,443.00
1116710001 remediation of the underlying aquifer
projects 2012.
on the property located on Francisco I Total: $211,183,418.00
Street. Madero No. 30, Colonia
Lechería, Tultitlán, State of Mexico.
Table 6 . CONABIO budget sufficiency reports
Office No. Name Investment amount
“Actions to contain the risk and prepare the site for carrying out the
remediation works that are essential to reduce the risks to human health
CA.of150/2006 dated
and the environment, in the former Cromatos de México factory, located in $14,000,000.00
July 4, 2006
the Municipality of Tultitlán, State of Mexico (Demolition and final disposal
of the ruins of the former factory).”
“Sampling work to update the magnitude of the contamination of the

property located on Francisco I Street. Madero No. 30, Colonia Lechería,
Tultitlán, State of Mexico" with an area of 35,344.13 m2."
CA-Of.050/2011 dated “Preparation of an Environmental Risk Assessment (ERA) study of the

$3,500,000.00
February 9, 2011. property located on Francisco I Street. Madero No. 30, Colonia Lechería,
“Executive project of the works for the remediation of contaminated soil on

the property located on Francisco I Street. Madero No. 30 Colonia
CA.Of.192/2012 dated
June 7, 2012 “Protection of four exploratory-extraction wells for the remediation of the
Cuautitlán-Pachuca Aquifer locally contaminated by chromium; demolition-
construction of contaminated sidewalks on the property located on $300,000.00
Francisco I Street. Madero No. 30 Colonia Lechería, Tultitlán, State of
Mexico perimeters and preparation of signs”
Table 7 . Budget sufficiency reports from the Government of the State of Mexico
“Actions to contain the risk and prepare the site for carrying out the
remediation works that are essential to reduce the risks to human health
212AA00000/176/2007
and the environment, in the former Cromatos de México factory, located $11,000,000.00
dated June 4, 2007
in the Municipality of Tultitlán, State of Mexico (Demolition and final
disposal of the ruins of the former factory).”
Table 8 . Budget sufficiency for item “33104 Studies and consultancies”

5
3
511.2/1137 dated “Technical-Economic Evaluation of Chromium Removal Technologies for

$6,000,000.00
May 12, 2012 remediation of the Cuautitlán-Pachuca Aquifer.”
VII.4.2- Public tenders
On September 18, 2007, the bases of the calls for National Public Bidding Nos. were published in the
Official Gazette of the Federation through the Compra-net System of the Ministry of Public Function.
00016057-033-07 “Actions for Risk Containment and Site Preparation for carrying out
Remediation Works that are essential to reduce risks to human health and the environment, in
the former Cromatos de México factory, located in the Municipality of Tultitlán, State of
Mexico” and; 00016057-032-07 “Supervision of Actions for Risk Containment and Site
Preparation for carrying out Remediation Works that are essential to reduce risks to human
health and the environment, in the former Cromatos factory of Mexico, located in the
Municipality of Tultitlán, State of Mexico . ” The program of events for the aforementioned tenders
is shown in table 9.
Table 9 . Program of events of the National Public Tenders for the first
project.
Event
National Public Tender National Public Tender
00016057-032-07 00016057-033-07
25-09-2007 25-09-2007
Visit to the work site
Clarification meeting 26-09-2007 27-09-2007
03-09-2007 04-09-2007
Presentation of proposals
Act of Failure 18-09-2007 18-09-2007
For the project “Risk containment actions and site preparation in the demolition works of cell
C1 and part of cell C2, on the property of the former Cromatos de México factory in Colonia
Lechería, in the Municipality of Tultitlán, Mexico state" . It was granted through the exception
procedure to public bidding, through the direct award procedure, based on articles 4, section II, 27
section III, 41 and 42 sections I and II of the Law of Public Works and Related Services with the same,
and approved in the first Extraordinary Session of the SEMARNAT Works Committee, held on October
29, 2008.
On March 10, 2009, the call for National Public Tender No. is published in the Official Gazette of the
Federation. 0016057-002-09 for the works “Actions to contain the risk and prepare the Cromatos
site for remediation: complementary works on the property and in the remaining part of cell
5
4
C2” , from the clarification meeting it was apparent that the process It would not be easy, since it
requested the response of 103 questions from the bidders (mostly of a technical nature, as well as of a
legal and administrative nature), all of which had been answered.
On July 15, 2009, the Internal Control Body (OIC) of SEMARNAT, issues the resolution to the acts of
non-conformity presented by the company SDS, which resolves the nullity of bidding bases No.
0016057-002-09 based on article 87, section I of the Law of Public Works and Services Related
Thereto, because they are flawed because they leave the bidders uncertain regarding the actual term
to execute all of the works. works and as a consequence to shape their proposals.
On June 3, 2010, the bases of the calls for National Public Bidding Nos. were published in the Official
Gazette of the Federation through the Compra-net System of the Ministry of Public Function.
00016057-03-10 “Actions to Contain the Risk and Prepare the Chromate Site for Remediation.
Complementary Works on the Property and in the remaining part of cell C2” and 00016057-004
10 “Services for Supervision of Actions for Risk Containment and Preparation of the Chromate
Site for Remediation: Complementary Works on the Property and in the remaining part of cell
C2” . The program of events for the aforementioned tenders is shown in table 10.
Table 10. Program of events of the National Public Tenders for the second
project.
Event
National Public Tender 00016057 National Public Tender
003-10 00016057-004-10
11-06-2010 11-06-2010
Visit to the work site.
Clarification meeting. 14-06-2010 14-06-2010
Presentation of the 22-06-2010 22-06-2010

proposals.
Act of Failure. 29-06-2010 29-06-2010
On June 28, 2011, the bases of the calls for National Public Bidding Nos. were published in the Official
Gazette of the Federation through the Compra-net System of the Ministry of Public Function.
00016057-002-11 “ Drilling of 12 exploratory and extraction wells for the remediation of the
Cuautitlán-Pachuca aquifer locally contaminated by chromium, Tultitlán, State of Mexico” and
00016057-003-11 “Supervision services for the drilling of 12 wells exploratory and extraction
for the remediation of the Cuautitlán-Pachuca aquifer locally contaminated by chromium,
Tultitlán, State of Mexico.” The program of events for the aforementioned tenders is shown in table
5
5
11.
5
6
Table 11. Program of events of the National Public Tenders for the wells of
monitoring.
Event
National Public Tender LO- 016000997- National Public Tender LO-
N13-2011 016000997-N14-2011
04-07-2011 04-07-2011
Second Clarification 07-07-201

Meeting
Presentation of the 15-07-2011 15-07-2011

proposals.
22-07-2011 18-07-2011
First Deferral of ruling act
Second Deferral of ruling 22-07-2011

act
Act of Failure. 26-07-2011 26-07-2011
On September 27, 2011, the bases of the calls for National Public Bidding Nos. were published in the
Official Gazette of the Federation through the Compra-net System of the Ministry of Public Function.
LO-016000997-N13-2011, "Engineering Works for the Remediation of the contaminated soil on
the property located on Francisco I Madero Street No. 30, in Colonia Lechería, Tultitlán, State
of Mexico" and LO- 016000997-N14-2011, “Supervision services for engineering works for the
remediation of contaminated soil on the property located on Francisco I Street. Madero No. 30,
Colonia Lechería, Tultitlán, State of Mexico" . The program of events for the aforementioned
tenders is shown in table 12.
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7
Table 12. Program of events of the National Public Tenders for the second
project.
Event National Public Tender LO-016000997- N13- National Public Tender LO- 016000997-
2011 N14-2011
03-10-2011 03-10-2011
12-10-2011 12-10-2011
Presentation of the proposals.
Act of Failure. 14-10-2011 14-10-2011
VII.4.3.- Agreements and/or contracts concluded
The contracts entered into for the project “Follow-up of risk containment actions, site preparation
and remediation of the property located on Francisco I Street. Madero No. 30, Colonia
Lechería, Tultitlán, State of Mexico (former Cromatos de México factory)”, were carried out in
accordance with the procedures indicated in article 27 of the Law of Public Works and Services
Related Thereto, as well as the provisions in article 1 of the Law on Acquisitions, Leasing and
Services of the Federal Public Administration.
5
8
White Paper "Follow-up on risk containment actions, site preparation and remediation of the property located at $% Francisco street, - Madero No. 30, 4+$+#)% Dairy, Tultitlán, State
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No. Contract and Dates of modifying Contract amount (VAT

Award Process Project's name Description Awarded Company
validity agreements included)
National Public Tender DGRMIS- DAC- ^ Disposal of Remaining Solid Waste. Modifying agreement for Industrial Waste $ 23,242,650.01
No.00016057-033-07 OP- 022/07 “Actions for Risk ^ Chemical analysis of the waste existing on the site. time dated January 13, Multiquim, SA de CV
Containment and ^ Outline, demarcation and referencing. 2008.
Valid from Preparation of the site for ^ Demolition of Structures.
November 29, carrying out the Remediation ^ Excavations. Modifying agreement for
2007 to August Works that turn out ^ Supply, placement, filling, shaping and compaction of clean time dated June 13, 2008.
30, 2008. essential for material for filling in area “A”. Additional agreement for
reduce the risks to human ^ Soil sampling and analysis of the excavation pits in the area time dated July 8, 2008.
health and the environment, and protection of excavation material in area “A”.
in the former Cromatos de ^ Loading and transfer to authorized confinement.
México factory, located in the
Municipality of Tultitlán, State
of Mexico”
National Public Tender DGRMIS- DAC- ^ Control andcheck of materials, equipment and Modifying agreement for Fuerte Consulting $ 1,827,00.65
00016057-032-07 OP- 023/07 “Supervision of the facilities. time dated May 15, 2008. Engineers, SA de CV
Actions for the ^ Control andcheck of security measures,
Valid from August Risk Containment and training and protection of workers. Time-modifying agreement
31, 2007 to Preparation of the site for ^ Control and verification of the progress of works and collateral dated July 29, 2008.
September 15, carrying out the Remediation activities.
2008. Additional agreement for
Works that turn out ^ Printed and electronic tracking and recording of works amount and time dated
essential for programs on Grant diagrams. July 29, 2008.
reduce the risks to human ^ Sign and validate the activities in the construction log when
health and the environment, each of the specifications are met.
in the former Cromatos de ^ Be the technical link between the awarded company and the
México factory, located in the other agencies involved and authorized.
Municipality of Tultitlán, State
of Mexico”
Direct award “Risk containment actions ^ Demolition of the perimeter wall of Cell C1 and partial of Cell were not carried out Industrial Waste $ 66,414,809.69
DGRMIS- DAC- and site preparation in the C2. Multiquim, SA de CV
DGGIMAR- OP- demolition works of cell C1 ^ Excavation, loading, transportation, treatment and disposal of
015/08 and part of cell C2, on the toxic waste, up to a total of 22,000 tons.
property of the former ^ Temporary protection of bare surface.
Valid from Cromatos de México factory
November 3 to in the Lechería
December 31, neighborhood, in the
2008. Municipality of Tultitlán, State
of Mexico”
5
9
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Invitation to at least three ^ Construction Control. were not carried out Fuerte Consulting $ 757,502.59
people “Supervision of risk Engineers, SA de CV
^ Cost and budget control.
DGRMIS- DAC- containment actions and site
^ Time control.
DGGIMAR- OP- preparation in the demolition
015/08 works of cell C1 and part of ^ Quality control.
cell C2, of the property of the ^ Information and execution period.
Valid from former Cromatos de México
November 6 to factory in the Lechería
December 31, neighborhood, in the
2008. Municipality of Tultitlán State
from Mexico"
National Public Tender Modifying agreement for Construction and $ 110,294,760.02

00016057-03-10 the amount of 23.22% Services Prisma, SA de
"Actions for ^ Demolition of the remaining walls of the perimeter of cell C2 of dated September 7,
DGRMIS- DAC- Risk Containment and the confinement area. 2010. CV
DGGIMAR- OP- Chromate Site Preparation ^ Excavation of the hazardous waste that exists inside the cell.
001/2010 for Remediation. Plays • Demolition of floor on property “B” and excavation to a
variable depth in the floor demolition area.
Valid from July 1 Complementary on the
^ Extraction of the material, protection of the exposed surface
to December 25, Property and in the
with canvas and a layer of clay material.
2010. remaining part of the cell • Filling of property “A”.
C2” • Transportation and disposal of hazardous waste
National Public Tender ^ Construction Control. were not carried out Comprehensive $ 3,615,162.15
00016057-004-10 “Services for Supervision of ^ Cost and budget control. Maritime Consulting, SA
DGRMIS- DAC- Actions for Risk Containment ^ Time control. de CV
DGGIMAR- OP- and Preparation of the ^ Quality control.
001/2010 Chromate Site for ^ Information and execution period.
Valid from July 1 Remediation: Plays
to December 25, Complementary on the
2010. Property and in the
remaining part of cell C2”
Invitation to at least three were not carried out Autonomous University $ 1,448,435.50
people “Sampling work to update the ^ Compilation and analysis of information from existing sampling of Nuevo León
DGRMIS- DAC- magnitude of the and environmental studies.
SEMARNAT-DAC-OP- DGGIMAR- contamination of the property ^ Sampling activities on property A, B and C.
002/2011 0016/2011 located on Francisco I Street. ^ Analytical determinations of contaminants.
Valid from May Madero No. 30, Colonia ^ Preparation of hexavalent chromium iso-concentration plans.
28 to August 15, Lechería, State of Mexico, ^ Dimension of the area and volume of the contaminated soil
2011. with an area of 35,344.13 m 2
and subsoil.
^^ ^ Final sampling report.
6
0
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Invitation to at least three “Environmental Risk were not carried out Autonomous University $1,366,995.75
^ Compilation and systematization of all existing information
people DGRMIS- DAC- Assessment Study of the of Coahuila
from environmental sampling and studies.
DGGIMAR- property located on
SEMARNAT-DAC-OP- ^ Toxicometry of contaminants (Hexavalent chromium).
0019/2011 Francisco I Street. Madero
003/2011 ^ Exhibition evaluation.
No. 30, Colonia Lechería,
Valid from May State of Mexico. ^ Estimation of risk to the environment and health.
28 to August 15, ^ Cleaning criteria based on associated risks.
2011. ^ Viable technologies based on associated risks.
^ Integration of the final report
Invitation to at least three DGRMIS- DAC- “Executive project of the were not carried out Comprehensive $573,048.12
people DGGIMAR- works for the remediation of ^ Topographic Survey of area B and C1. Maritime Consulting, SA
006/2011 the contaminated soil of the ^ Design and detailed engineering of the demolition of the de CV
SEMARNAT-DAC-OP- property located on concrete slabs and cisterns buried in properties B and C.
004/2011 Valid from June Francisco I Street. Madero ^ Detailed design and engineering of the excavation of the
28 to August 15, No. 30, Colonia Lechería, contaminated soil of properties B and C from the level of the
2011. State of Mexico. natural terrain (NTN) to a depth of 2.0 m in property B and
2.5 in property C, includes filling with the multi system -
barriers
^ Design and detailed engineering of the construction of the
perimeter fence
^ Specifications for the transportation and final disposal of
contaminated soils and demolition products.
^ Determination of the volumes of work of the included
concepts.
^ Catalog of work concepts.
^ Construction budget.
^ Work program
Article 1, fourth paragraph of DGRMIS- DAC- “Technical-Economic ^ Analysis of the water quality of the test well and two were not carried out Mexican Institute of $6,000.000.00
the Law on Acquisitions, DGGIMAR- Evaluation of Water
surrounding wells in accordance with the 2000 Modification
Leases and Public No.015/2011 “Chromium removal Technology/SEMARNAT
of NOM 127 SSA1-1994 and other important parameters for
Administration Services technologies for remediation
Valid from June 1 of the Cuautitlán-Pachuca the treatment.-
Federal ^ Selection of technologies for study in the laboratory.
to December 31, aquifer”
2011. ^ Laboratory scale tests.
^ On-site pilot study, two technologies.
^ Technical and economic evaluation of the two technologies.
^ Preparation of the executive project.
^ Determination of transport parameters.
^ Final report.
6
1
White Paper "Follow-up on risk containment actions, site preparation and remediation of the property located on Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán, State
of Mexico (former Cromatos de México factory)"

National Public Tender DGRMIS- DAC- “Drilling of 12 exploratory • Modifying agreement for SEGEOMEX $37,567,340.81
00016057-002-11 DGGIMAR- OP- and extraction wells for the a period dated EXPLORATION AND
001/2011 remediation of the Construction of 12 exploration/extraction wells in four differentDecember 9, 2011. LABORATORIES S. DE
Cuautitlán-Pachuca aquifer
Valid from August locally contaminated by
•
sites. At each site three wells will be located at different depths: Modifying agreement for RL DE CV/ING.
ALFONSO GONZALEZ
~130, ~200 and ~300 m. The drilling order at each of the sites is: the amount of 2.98%
1, 2011 to chromium, State of Mexico. first the ~130 m deep well, secondly the ~200 m deep well, and dated January 28, AGUILERA
January 28, finally the ~300 m deep well. In this way, 4 wells will be drilled 2012.
2012. with depths of around 130 m, 4 wells of 200 m and 4 wells of
300 m, with a total drilling length of approximately 2,520 m. Each
well will be drilled to an exploratory diameter of 31.12 cm (12
1/4”) with extensions to diameters of 31.12 cm (12 1/4”) to 63.50
cm (24”) and 31.12 cm (12 1/4”) to 37.47 cm (14 3/4”), with core
recovery at a diameter of 7.46 cm (2 15/16”) or similar, placing
45.72 cm (18”) and 30.48 cm (12”) casing pipes. Additionally, the
wells will be gauged using a 15.24 cm (6”) pump.
National Public Tender • Work control. • Modifying agreement for CONSTRUCTION AND $ 1,888,175.55
a period dated
00016057-003-11
DGRMIS- DAC-
“Supervision work for the • Cost and budget control. December 9, 2011. SUPERVISION OF SAN
DGGIMAR- OP-
drilling of 12 exploratory and
extraction wells for the
• Time control. LUIS, SA DE CV
002/2011 Valid
remediation of the • QA.
from August 1,
2011 to January
Cuautitlán-Pachuca aquifer • Information and execution period.
locally contaminated by
28, 2012.
chromium, State of Tultitlán.
6
2
White Paper "Follow-up on risk containment actions, site preparation and remediation of the property located on Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán, State
of Mexico (former Cromatos de México factory)"

National Public Tender No. LO- DGRMIS- DAC- “Engineering Works for the
• Ademdum of Contract PRISMA $157,704,232.10
016000997-N13- 2011 DGGIMAR- OP- Remediation of the No. DGRMIS-DAC- CONSTRUCTION AND
DGGIMAR-OP-
003/2011 contaminated soil on the 003/2011, dated SERVICES, SA DE CV
property located on November 4, 2011.
Valid from Francisco I Street. Madero
October 14, 2011 No. 30 in the Lechería • •
Layout and leveling of the work areas “B”, “C1”, “C2” and “Plot 3” Ademdum of Contract
to June 15, 2012. neighborhood, Tultitlán, Edo. establishing axes and references. No. DGRMIS-DAC-
From Mexico" • Demolition of reinforced concrete elements in areas “B”, “C1” and “C2” DGGIMAR-OP-
003/2011, dated
in accordance with what is indicated in the “Concrete demolition plan”
• Excavation to remove material contaminated with hexavalent chromium
November 14, 2011.
•
in areas “B”, “C1” and “C2” in accordance with what is indicated in the Modifying agreement for
“General Excavation Plan” the amount of 24.24%
• Excavation of material in the “C2” area to a depth of 30 centimeters to dated December 14,
2011.
compensate for the filling in other areas of the same property.
• Loading and hauling of material from the demolition and/or excavation of
material contaminated with hexavalent chromium from areas “B”, “C1”
and “C2” to an authorized final disposal site for hazardous waste.
• Loading and hauling of debris material from the property called “3” to an
authorized site of the municipality.
• Final disposal of the material or soil contaminated with hexavalent
chromium in an authorized hazardous waste site.
• Placement of polyethylene geo-membrane in the excavated areas “B”,
“C1” and “C2”.
• Filling and compaction with bench material in the excavated areas “B”,
“C1” and “C2”
• Supply and formation of hydraulic base layer in the excavated areas “B”,
“C1” and “C2”.
• Impregnation irrigation based on asphalt emulsion in the excavated
areas “B”, “C1” and “C2”.
• Manufacture of emulsified flexible asphalt pavement in the excavated
areas “B”, “C1” and “C2”.
• Dismantling of the cyclonic mesh of the property located on Francisco I
Madero Street No. 30, in Colonia Lechería, Tultitlán, State of Mexico.
• Supply and placement of hollow block with a section of 20x20x40
centimeters in the perimeter area of the entire property located on
Francisco I Madero Street No. 30, in Colonia Lechería, Tultitlán, State
of Mexico.
• Manufacture of castles with an apparent finish in the perimeter area of
the entire property located on Francisco I Madero Street No. 30, in
Colonia Lechería, Tultitlán, State of Mexico.
• Manufacture of clearance gates and fencing chains in the perimeter
area of the entire property located on Francisco I Madero Street No.
30, in Colonia Lechería, Tultitlán, State of Mexico.
• Supply and manufacturing of foundation footing for the perimeter wall of
the property located on Francisco I Madero Street No. 30, in Colonia
Lechería, Tultitlán, State of Mexico.
• Supply and placement of blacksmith doors on the property located on
Francisco I Madero Street No. 30, in Colonia Lechería, Tultitlán, State
of Mexico.
6
3
/" .=>)&+ ?"> @;A()&% /" 4(+B%:+* /" .=>)&+C^
Award Process Project's name Description

No. Contract and Date of modifying Contract Amount
validity agreements Awarded Company (VAT included)
^ Addendum to Contract
National Public Tender No. LO- DGRMIS- DAC- “Supervision of the ^ Construction Control. No. DGRMIS-DAC- INTEGRAL MARITIME $4,302,106.94
016000997-N14- 2011 DGGIMAR- OP- Engineering Works for the ^ Cost and budget control. DGGIMAR-OP- ADVICE, SA DE CV
003/2011 Remediation of the ^ Time control. 003/2011, dated
contaminated soil on the ^ Quality control. November 4, 2011.
Valid from property located on ^ Information and execution period. ^ Ademdum Of Contract
October 14, 2011 Francisco I Street. Madero
No. DGRMIS-DAC-
to July 28, 2012 No. 30 in the Lechería
DGGIMAR-OP-
neighborhood, Tultitlán, Edo. 003/2011, dated
From Mexico" November 14, 2011.
^ Modifying agreement for
amount and time of
16.6 and 16.4%
respectively dated May
10, 2012.
^ They were not carried

Direct award DGRMIS “Protection of four out PRISMA $242,385.89
Contract- exploratory-extraction wells CONSTRUCTION AND
DAC- DGGIMAR- for the remediation of the SERVICES, SA DE CV
OP-002/2012 Cuautitlán-Pachuca Aquifer ^ Construction of 4 protective boxes in 4 exploratory/extraction wells located on
locally contaminated by property C-2 on Calle Francisco I Madero No. 30, in Colonia Lechería,
Valid from July chromium; demolition- Tultitlán, State of Mexico, for the remediation of the locally contaminated
13 to August 2, construction of contaminated Cuautitlán-Pachuca aquifer.
2012 sidewalks on the property
located on Francisco I Street. ^ Carry out the demolition of the sidewalks with an estimated volume of 55 m3
Madero No. 30 Colonia of concrete from the perimeter areas external to the delimiting walls of the
Lechería, Tultitlán, State of property located on Francisco I Madero Street No. 30, in Colonia Lechería,
Mexico perimeters and Tultitlán, State of Mexico and property No. 3 adjacent to the referred one.
preparation of signs” ^ Carrying out the transport service in cargo trucks, of an approximate volume
of 55 m3 of debris measured on a bench; as a product of the demolition of
the sidewalks, to the site authorized by the municipality.
^ Construction and restoration of sidewalks in an estimated area of 520 m2,
with concrete to be used, located in the perimeter areas external to the
delimiting walls of the property on Francisco I Madero Street No. 30, in
Colonia Lechería, Tultitlán, State of Mexico and property No. 3 adjacent to
the referred one.
^ Final design, preparation and placement of 5 vertical signs measuring 1m
wide x 1.50m high made of galvanized sheet with restrictive, preventive
and informative signs to be installed on the 5 access doors of the property
on Francisco I Madero Street No. 30, in Colonia Lechería, Tultitlán, State
of Mexico and property No. 3 adjacent to the referred one.
6
4
White Paper "Follow-up on risk containment actions, site preparation r $% remediation of the property located on $% street
'(%#&)*&+ ,- .%/"(+ 0+- 123 4+$+#)% 5"&6"(7%3 89$:):$;#3 <*:%/ + /" .=>)&+ ?"> @;A()&% /" 4(+B%:+* /" .=>)&+C^
VII.4.4.- Records of the budget exercises carried out.
The present records on the budgetary exercise of the project ^^^^^^^^^^^^ ^ ^^^ risk containment
actions, site preparation and remediation of the property located on Francisco I Street. Madero
No. 30, Colonia Lechería, Tultitlán, State of Mexico (former Cromatos de México factory)”, were
carried out in accordance with the procedures indicated by the Ministry of Finance and Public Credit, as
well as what is indicated in the Budget and Fiscal Responsibility Law, whose data were obtained
through the DOF-intranet System of the Financial Operations Directorate of the General Directorate of
Programming and Budget of the Senior Office of SEMARNAT, the payment records are also indicated
through the authorized budget of CONABIO.
Table 13 . Record of payments for the budget year made through the PEF
Invoice CLC Beneficiary Code Name of Beneficiary Budget key Amount Payment date
11891 10285 RIM850614LJ2 2008 16 710 3902 0 007 R012 6108 3 1 $19,924,442.91
Industrial Waste
December 4, 2008.
Multiquim, SA de CV
12269 10733 FIC030822JM7 2008 16 710 3902 0 007 R012 6107 3 1 $227,250.77 December 11,
Fuerte Consulting 2008.
Engineers, SA de CV
13996 12066 RIM850614LJ2 2008 16 710 3902 0 007 R012 6108 3 1 $23,199,535.09 January 13, 2009.
Industrial Waste
Multiquim, SA de CV
14051 12186 RIM850614LJ2 2008 16 710 3902 0 007 R012 6108 3 1 $23,001,919.79
Industrial Waste
January 13, 2009.
Multiquim, SA de CV
14049 12209 FIC030822JM7 2008 16 710 3902 0 007 R012 6107 3 1 $236,479.15
Fuerte Consulting
January 29, 2009.
Engineers, SA de CV
14050 12212 FIC030822JM7 2008 16 710 3902 0 007 R012 6107 3 1 $131,739.60 January 29, 2009.
Fuerte Consulting
Engineers, SA de CV
14220 12338 FIC030822JM7 2008 16 710 3902 0 007 R012 6107 3 1 $131,739.57
Fuerte Consulting
January 29, 2009.
Engineers, SA de CV
5014 4215 CSP8905022S2 Construction and 2010 0 710 3902 0 007 K026 6108 3 1 $17,901,995.92
Services Prisma, SA de July 21, 2010.
CV
7037 5949 AIM0604056X2 Comprehensive 2010 0 710 3902 0 007 K026 6107 3 1 $620,616.82
September 20,
Maritime Consulting, SA
2010.
DE CV
September 20,
Services Prisma, SA de
2010.
CV
6
5
'(%#&)*&+ ,- .%/"(+ 0+- 123 4+$+#)% 5"&6"(7%3 89$:):$;#3 <*:%/ + /" .=>)&+ ?"> @;A()&% /" 4(+B%:+* /" .=>)&+C^
Name of
Invoice CLC Beneficiary Code Budget key Amount Payment date
Beneficiary
September 29,
2010.
DE CV
8105 7045 AIM0604056X2 Comprehensive 2010 0 710 3902 0 007 K026 6107 3 1 $620,616.82 October 25, 2010.
DE CV
Services Prisma, SA de October 25, 2010.
CV
November 18,
2010.
DE CV
9378 8083 CSP8905022S2 Construction and 2010 0 710 3902 0 007 K026 6108 3 1 $29,469,886.84 November 24,
Services Prisma, SA de 2010.
CV
10943 9336 AIM0604056X2 Comprehensive 2010 0 710 3902 0 007 K026 6107 3 1 $620,616.82 December 9, 2010.
DE CV
Services Prisma, SA de January 31, 2011.
CV
Maritime Consulting, SA May 25, 2011.
DE CV
91628 278 SEL090523I55 2011 16 710 3920 7 K13 62401 3 1 $7,295,557.27 August 31, 2011
Segeomex Exploración
y Laboratorios S de R.
L. CV
91631 277 CSS831105EP6 Construction and 2011 16 710 3920 0 7 K13 62903 3 1 $438,056.71 August 31, 2011
Supervision of San Luis,
SA de CV
102275 316 IMT01031BB3 20011 16 710 3920 7G3 33104 $1,165,800.00

Mexican Institute of September 27,
Water Technology 2011
111081 322 CSS831105EP6 Construction and 2011 16 710 3920 0 7 K13 62903 3 1 $348,557.21
September 30,
2011
SA de CV
122723 351 SEL090523I55 2011 16 710 3920 7 K13 62401 3 1 $1,317,662.30 October 21, 2011
L. CV
129433 363 SEL090523I55 2011 16 710 3920 7 K13 62401 3 1 $6,411,195.76 October 28, 2011
L. CV
129437 362 CSS831105EP6 Construction and 2011 16 710 3920 0 7 K13 62903 3 1 $348,557.21
Supervision of San Luis, October 28, 2011
SA de CV
143679 390 SEL090523I55 Segeomex 2011 16 710 3920 7 K13 62401 3 1 $6,560,969.00
Exploration and November 23, 2011
Laboratories S de R.
6
6
'(%#&)*&+ ,- .%/"(+ 0+- 123 4+$+#)% 5"&6"(7%3 89$:):$;#3 <*:%/ + /" .=>)&+ ?"> @;A()&% /" 4(+B%:+* /" .=>)&+C^
Name of
Invoice CLC Beneficiary Code Budget key Amount Payment date
Beneficiary
L. CV
143615 389 CSS831105EP6 Construction and 2011 16 710 3920 0 7 K13 62903 3 1 $348,557.21 November 23, 2011
SA de CV
142647 392 CSP8905022S2 Construction and 2011 16 710 3920 7 K13 62401 3 1 $38,081,373.41 November 25,
CV
142919 393 AIM0604056X2 Comprehensive 2011 16 710 3920 0 7 K13 62903 3 1 $1,106,651.30
November 25,
2011.
DE CV
153565 440 IMT011031BB3 Mexican Institute of 2011 16 710 3920 7G3 33104 $4,834,200.00
December 5, 2011
Water Technology
154411 442 CSP8905022S2 Construction and 2011 16 710 3920 7 K13 62401 3 1 $16,956,773.97
Services Prisma, SA de December 6, 2011.
CV
153361 441 AIM0604056X2 Comprehensive 2011 16 710 3920 0 7 K13 62903 3 1 $320,785.77 December 6, 2011.
DE CV
161998 469 SEL090523I55 2011 16 710 3920 7 K13 62401 3 1 $13,103,005.15 December 14, 2011
L. CV
167522 492 CSP8905022S2 Construction and 2011 16 710 3920 7 K13 62401 3 1 $27,834,517.80 December 22,
CV
161993 468 CSS831105EP6 Construction and 2011 16 710 3920 7 K13 62903 3 1 $348,557.21
December 14,
2011.
SA de CV
170729 510 SEL090523I55 2011 16 710 3920 7 K13 62401 3 1 $1,399,399.94 January 30,
2012
L. CV
170787 511 CSS831105EP6 Construction and 2011 16 710 3920 7 K13 62903 3 1 $348,557.21
Supervision of San Luis, January 31, 2011.
SA de CV
11096 29 CSP8905022S2 Construction and 2012 16 710 2160 7 K13 62401 3 1 $20,106,747.90 March 12, 2012.
CV
11097 30 CSP8905022S2 Construction and 2012 16 710 2160 7 K13 62401 3 1 $20,125,675.30 March 12, 2012.
CV

Maritime Consulting, SA March 12, 2012.
DE CV
Services Prisma, SA de March 29, 2012.
CV
18339 40 AIM0604056X2 Comprehensive 2012 16 710 3920 0 7 K13 62903 3 1 $320,785.77 March 29, 2012.
DE CV
6
7
'(%#&)*&+ ,- .%/"(+ 0+- 123 4+$+#)% 5"&6"(7%3 89$:):$;#3 <*:%/ + /" .=>)&+ ?"> @;A()&% /" 4(+B%:+* /" .=>)&+C^
Invoice CLC Beneficiary Code Name of Beneficiary Budget key Amount Payment date
Services Prisma, SA de April 27, 2012.
CV
29875 88 AIM0604056X2 Comprehensive 2012 16 710 3920 0 7 K13 62903 3 1 $320,785.77 April 27, 2012.
DE CV
Maritime Consulting, SA May 30, 2012
DE CV
44369 115 CSP8905022S2 Construction and 2012 16 710 2160 7 K13 62401 3 1 $7,459,477.96 May 30, 2012
CV
57155 134 AIM0604056X2 Comprehensive 2012 16 710 3920 0 7 K13 62903 3 1 $320,785.77 June 29, 2012
DE CV
61149 140 CSP8905022S2 Construction and 2012 16 710 2160 7 K13 62401 3 1 $13,450,090.40 July 10, 2012
CV
Maritime Consulting, SA July 27, 2012
DE CV
78934 209 AIM0604056X2 Comprehensive 2012 16 710 3920 0 7 K13 62903 3 1 $151,508.67 August 15, 2012
DE CV
Table 14 . Record of payments for the budget year made through CONABIO
Office No. Beneficiary name Project's name Amount Date
“Executive project of the works

for the remediation of
Comprehensive Maritime contaminated soil on the property
DGGIMAR.710/005883 $285,091.44 July 27, 2011
Consulting, SA de CV located on Francisco I Street.
Madero No. 30 Colonia Lechería,
“Preparation of an Environmental
Risk Assessment (ERA) study of
Autonomous University of the property located on Francisco August 15,
DGGIMAR.710/005450 $1,093,596.59
Coahuila I Street. Madero No. 30, Colonia 2011
Lechería, Tultitlán, State of
Mexico.”
“Sampling work to update the

magnitude of contamination of
the property located on Francisco
Autonomous University of Street August 15,
DGGIMAR.710/005451 $1,249,087.79
Nuevo León YO. Madero No. 30, Colonia 2011
Mexico" with an area of
35,344.13 m2."
DGGIMAR.710/005839 Autonomous university “Preparation of a Risk $273,399.17

Assessment study August 30,
6
8
Office No. Beneficiary name Project's name Amount Date

Coahuila Environmental (ERA) of the 2011
property located on Francisco I
Street. Madero No. 30, Colonia
Mexico.”
“Executive project of the works

for the remediation of
Comprehensive Maritime contaminated soil on the property August 30,
DGGIMAR.710/005840 $285,091.44
Consulting, SA de CV located on Francisco I Street. 2011
Madero No. 30 Colonia Lechería,
“Sampling work to update the

magnitude of contamination of
the property located on Francisco
Autonomous University of Street September 1,
DGGIMAR.710/005940 $199,347.71
Nuevo León YO. Madero No. 30, Colonia 2011
Mexico" with an area of
35,344.13 m2."
“Protection of four exploratory-

extraction wells for the
remediation of the Aquifer
Cuautitlán-Pachuca locally
contaminated by chromium;
Construction and Services demolition-construction of August 23,
DGGIMAR.710/006151 $242,385.89
Prisma, SA de CV contaminated sidewalks on the 2012
property located on Francisco I
Street. Madero No. 30 Colonia
“Mexico perimeters and
preparation of signs”
VII.4.5.- Investment Release Letters.
Based on articles 48 of the Federal Budget and Fiscal Responsibility Law (Law); 156, section II, 156 A
157 of the Regulations of the Law; as well as 34, section III of the Internal Regulations of SEMARNAT,
the General Directorate of Programming and Budget, issued the corresponding Investment Release
Letters (OLI) for the investment projects for the periods 2008-2012:
OLI authorization and date Amount (pesos) Wallet key
511.1/1853 of October 10, 2008 $92,900,000.00 08167100001
511.1/0289 of March 2, 2009 $192,898,330.58 08167100001
511.1/01604 of May 18, 2010 $115,870,615.00 08167100001
511.1/2454 of August 26, 2011 $125,774,975.00 11167100001
511.1/0613 of February 28, 2012 $88,396,924.00 11167100001
6
9
As mentioned in previous sheets, the source of financing for the execution of the projects and studies for the
“Follow-up of risk containment actions, site preparation and remediation of the property located on Francisco
I Street. Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico (former Cromatos de México factory)”,
comes from the Expenditure Budget of the Federation and Resources from the Biodiversity Fund for the
Commission's Environmental Remediation concept.
Comparative table of the total authorized budget vs. budget exercised in the Public Works
item with PEF resources
2008 2009 2010 2011 2012

Budget
Authorized* $92,900,000.00 $192,898,331.00 $115,870,615.00 $125,774,475.00 $85,408,443.00
Budget
Exercised $67,172,312.28 0 $113,909,922.17 $123,706,800.02 $75,652,891.23
Unexercised
resources $25,727,687.72 $192,898,331.00 $1,960,692.83 $2,067,674.98 $8,755,551.77
% Exercised 72.31 0.00 98.31 98.36 88.57
7
0
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QR "ZNRJLJ QR XI 5RQRNISO[U >2"5?
2NRJMYMRJKL +MKLNOPIQL @! 2NRJMYMRJKL "\RNSOQL
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EC81888188868
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E22J E22K E2D2 E2DD E2DE
■ V("*9M9"*:+ P9:+()Y%/+] UKE3K223222- UDKE3JKJ311D-2 UDDG3JI23HDG- UDEG3IIF3FIG-2 UJG3F2J3FF1-22
22 2
UDD13K2K3KEE-
■ V("*9M9"*:+ <X"(&)/+ UHI3DIE31DE-EJ 2 UDE13I2H3J22-2 UIH3HGE3JKD-
■ L"&9(*+* #+ "X"(&)/+* D E1
UEG3IEI3HJI-IE UDKE3JKJ311D-2 UD3KH23HKE-J1 UE32HI3HIF-KJ UJ3IGG3GGD-II
Comparative table of the total authorized budget vs budget exercised with
CONABIO resources
C88D C8AA C8AC
V("*9M9"*:+ P9:+()Y%/+ UEG32223222- U13G223222- U1223222-

22 22 22
V("*9M9"*:+ <X"(&)/+ UEF3IFJ3EEG-FD U131JJ3FIK-1I UEFE31JG-JK
L"&9(*+* #+ "X"(&)/+* UEGD3IIF-GK UDDD3G2E-H1 UGI3HDF-DD
\ <X"(&)/+ KJ-KK KH-JD J2-J2
7
1
Resources from the Biodiversity Fund for the concept of

CONABIO Environmental Remediations
Authorized Budget Vs Exercised Budget
$25,000,000.00
$20,000,000.00
N
o $15,000,000.00
$10,000,000.00
$5,000,000.00
$0.00
2007 2011 2012
Authorized Budget $25,000,000.00 $3,500,000.00 $300,000.00
Exercised Budget $24,748,225.41 $3,388,479.37 $242,385.89
Unexercised Resources $251,774.59 $111,502.63 $57,614.11
Comparative table of the total authorized budget vs budget exercised with

PEF resources in the area of Studies and Consulting
2011
Authorized Budget $6,000,000.00
Exercised Budget $6,000,000.00
Unexercised resources $0.00
% Exercised 100
7
2
Authorized budget item 33104 "Studies and consultancies"

Authorized Budget VS Exercised Budget
$6,000,000.00
$5,000,000.00
$4,000,000.00
$3,000,000.00
$2,000,000.00
$1,000,000.00
$0.00
2011
■ Authorized Budget $6,000,000.00
■ Exercised Budget $6,000,000.00
■ Unexercised resources $0.00
7
3
VIII . MONITORING AND CONTROL
IX .1.- Institutional Reports.
The SEMARNAT Work Reports record the activities carried out by the Unit in support of the
transition towards Sustainable Human Development, committed to the guidelines of the National
Development Plan 2007-2012, the Sectoral Program of Environment and Natural Resources 2007-
2012 and institutional and special programs of the sector. The document reports on the main results
achieved, particularly the goals contained in the Annual Work Program of the Sector during the 2007
period. 2012.
Institutional Report
The project of “Monitoring the risk containment actions, site

preparation and remediation of the property located on
Francisco I Street. Madero No. 30, Colonia Lechería, Tultitlán,
State of Mexico (former Cromatos de México factory)”, was
reported in point 5.4.2 Contaminated Sites of item 5.4 “Waste
and Hazardous Chemicals and Highly Risky Activities of section
5 of the Report “Agenda Grey, Monitoring, Prevention and
Remediation of Environmental Pollution”.
First Report 2007
7
4

reported in point 2.4.1 Remediation of Contaminated Sites of
item 2.4 “Have comprehensive and transversal management
that is efficient and effective for the remediation of contaminated
sites” of section 2 of the Report “Gray Agenda, Pollution
Prevention and Control”..
Second Report 2008

reported in point 2.4.1 Remediation of Contaminated Sites of
item 2.4 “Have comprehensive and transversal management
that is efficient and effective for the remediation of contaminated
sites” of section 2 of the Report “Gray Agenda, Pollution
Prevention and Control”
Third Report 2009
7
5

reported in point 2.4.1 Remediation of Contaminated Sites and
Environmental Liabilities of item 2.4 “Have comprehensive and
transversal management that is efficient and effective for the
remediation of contaminated sites” of section 2 of the Report
“Gray Agenda, Pollution Prevention and Control”
Fourth Report 2010 The project of “Monitoring the risk containment actions, site
“Gray Agenda, Pollution Prevention and Control”
Fifth Report 2011
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6

“Gray Agenda, Pollution Prevention and Control”.
Sixth Report 2012
7
7
VIII.2.- Resolution to the Nonconformity process No. I-04/2009, corresponding to the

National Public Tender No. 00016057-005-09 “Actions for Risk Containment and
Preparation of the Chromate Site for Remediation Stage 3: Works for the remaining
part of Cell C2”.
On April 13, 2009, C. Juan Ramón Barcala Núñez, in his capacity as legal representative of the
company Sistemas de Desarrollo Sustentable, SA de CV, promoted the disagreement against acts
derived from the second clarification meeting of the bases of National Public Tender No. 00016057-
005-09 “Actions for Risk Containment and Preparation of the Chromate Site for Remediation Stage 3:
Works for the remaining part of Cell C2”, which was admitted by the Internal Control Body at
SEMARNAT.
The disagreement presented essentially states that the Convener modified the payment method of
the tendered contract, since it admitted that the Administration pays in advance for the execution of
the works, thereby allowing it to finance the contractor, making the public bidding bases illegal in I
comment. It also points out that the inconsistency in the bases produces confusion and uncertainty
for the contestants regarding the execution period of the works, due to the fact that the clarification
meeting obscured its content, by interpreting an additional period to the execution period initially
indicated in the bases. tender, affecting the economic proposal.
On July 15, 2009, the Internal Control Body at SEMARNAT issues the resolution to the nonconformity
file I-04/2009, which states in its first resolution:
Based on article 87, section I of the Law on Public Works and Services Related
Thereto, THE NULLITY OF THE BASES “ACTIONS FOR RISK CONTAINMENT
AND PREPARATION OF THE CROMATES SITE FOR REMEDIATION IS
DECLARED STAGE 3: WORKS FOR THE REMAINING PART OF CELL C2" ,
and therefore the bidding process in accordance with what is stated in the Fourth
Considering Clause of this resolution, therefore the convener must submit within a
period of 10 business days from when the notification of this resolution, the
corresponding documents that reliably prove compliance with this resolution.
The Fourth Considering clause of the Resolution in question states:
Based on what is stated in the preceding recital, this authority warns that the bases for the
National Public Tender No. 00016057-005 09 “Actions for Risk Containment and Preparation
of the Chromates Site for Remediation Stage 3: Works for the remaining part of Cell C2”, as
the protester points out, are flawed, given that they leave a state of uncertainty to bidders
regarding the actual deadline to execute all of the work and, as a consequence, to form their
proposals.
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8
VIII.3.- Inspection visit to the execution of the works of the National Public Tender
00016057-002-11 “Drilling of 9 exploratory and extraction wells for the remediation of
the Cuautitlán-Pachuca aquifer locally contaminated by chromium, State of Tultitlán”
and National Public Tender 00016057-003-11 “Supervision work for the drilling of 9
exploratory and extraction wells for the remediation of the Cuautitlán-Pachuca aquifer
locally contaminated by chromium, State of Tultitlán.”
Through Official Letter No. 19/113/AI/CI-1066/2011 dated October 6, 2011, the Head of the Internal
Control Body (OIC) in SEMARNAT, Notifies the Head of the General Directorate of Comprehensive
Management of Risky Materials and Activities (DGGIMAR ), that an inspection visit will be carried out
in order to verify the actions carried out in the bidding, execution, control, supervision and payment
processes of the public works related to the “ Drilling of 9 exploratory and extraction wells for
remediation of the Cuautitlán-Pachuca aquifer locally contaminated by chromium, State of
Tultitlán” and inherent expenses for the year 2011. For which he appointed the CC. Luis
Ocaris Sosa, Deputy Director of Public Works Audit; Roberto Rodriguez Rodriguez, Jr.
Auditor. and Sergio Garcia Terrazas, Jr. Auditor.
On October 11, 2011, through official letter No. 16/AI-165/2011, C. Luis Ocaris Sosa,
requests from the Head of the DGGIMAR, the technical support documents that substantiate
the award that covers the works of the National Public Tender 00016057-002-11 “Drilling of
9 exploratory and extraction wells for the remediation of the Cuautitlán aquifer. Pachuca
locally contaminated by chromium, State of Tultitlán.” As well as the contract, catalog of
concepts, work programs, physical-financial progress, work log and list of estimates paid
under the contract, including the
surplus and extraordinary volumes and the authorization thereof in accordance with article
59 of the Law of Public Works and Services Related Thereto.
The DGGIMAR, through official letters Nos. DGGIMAR.710/007124 and

DGGIMAR.710/007125 dated October 17, 2011, complies with the information requested in
the notification letter of the inspection visit and the information in letter No. 16/AI-165/2011.
On October 26, 2011, the DGGIMAR sends official letter No. DGGIMAR.710/007377, to C.
Luis Ocaris Sosa, Deputy Director of Public Works Audit of the OIC at SEMARNAT, the
agreement modifying the Public Works Contract DGRMIS-DAC-DGGIMAR-OP- 001/2011.
On January 18, 2012, through Official Letter No. 16/AI-018/2012, the head of the Internal
Audit Area of the OIC in SEMARNAT, requests complementary information, consisting of the
bonds or guarantees granted to the construction and supervision contractors;
7
9
documentation supporting estimates from the contractor Segeomex Exploración y

Laboratorio, SA de CV; copy of the contract of the National Public Tender 00016057 003-11
“Supervision work for the drilling of 9 exploratory and extraction wells for the remediation of
the Cuautitlán-Pachuca aquifer locally contaminated by chromium, State of Tultitlán”;
estimates presented and supporting documentation by the contractor Construction and
Supervision San Luis, SA de CV, work log, update of the physical-financial progress of the
work and supervision and agreements or agreements signed for the modification of the
completion date of the work and modified work program. On January 26, 2012, the
DGGIMAR issued official letter No. 710/00752, through which the request for information
mentioned in the previous paragraph is resolved.
On February 7, 2012, through Official Letter No. 16/AI-032/2012, the head of the Internal
Audit Area of the OIC at SEMARNAT, requests information to continue with the inspection
visit process, consisting of Bonds or guarantees granted by the contractor Construction and
Supervision of San Luis, Anonymous Society of Variable Capital; supporting documentation
of the estimates presented with a date after the same from the contractor Construction and
Supervision of San Luis, SA de CV Through Official Letter No. DGGIMAR.710/001123 dated
February 13, 2012, the information request was resolved.
On March 13, 2012, the head of the Internal Audit Area of the OIC at SEMARNAT,
requested information to conclude the inspection visit initiated by official letter No.
19/113/AI/CI-1066/201, in a certified form corresponding to the closure of the work, minutes of
delivery-reception of the works, update of the physical-financial progress, list of executed, unexecuted
and extraordinary concepts, as well as the completion of the work in question. Through Official
Letter No. DGGIMAR.710/002369 dated March 23, 2012, the information request was
resolved.
On September 4, 2012, the Head of the Internal Control Body requested information from
this General Directorate regarding the last estimate paid, as well as the settlement payment
for the work, updating of the physical-financial progress of contracts Nos. DGRMIS-DAC-
DGGIMAR-OP-001/2011 and DGRMIS-DAC-DGGIMAR-OP-002/2011, as well as the
supporting documentation of the administrative procedures carried out to prepare the
resources to cover the last payment and termination of the contract. DGRMIS-DAC-
DGGIMAR-OP-001/2011. Through official letter No. DGGIMAR.710/006611 dated
September 7, 2012, the requested information was resolved.
8
0
VIII.4.- Attention to observations.
From the Disagreement Resolution process No. I-04/2009, the following facts were motivated and
substantiated:
Made Compliance Measures taken
Solve First
Notify interested parties of the nullity of Carry out a new bidding process for the
the bases for National Public Tender No. Corrective action.- The resolution was project “Actions for Risk Containment and
00016057-005-09 “Actions for Risk notified to the companies: Sistemas de Preparation of the Cromatos Site for
Containment and Preparation of the Desarrollo Sustentable, SA de CV, Remediation Stage 3: Works for the
Chromate Site for Remediation Stage 3: Constructora y Servicios Prisma, SA de remaining part of Cell C2”, for the year
Works for the remaining part of Cell C2” CV and to the company Residuos 2010, correcting the defects indicated in
and therefore the bidding process. Industriales Multiquim, SA de CV the resolution issued.
Preventive Action.- Review of the
bidding rules through the Public Works
Subcommittee, which is made up of the
area responsible for the work and the
area in charge of the process of
adjudication, as advisors the legal area of
SEMARNAT and the Internal Control
Body.
Considering Fourth
The bases of National Public Tender No. Corrective Action.- Each of the work Correction to the work concepts in the
00016057-005-09 “Actions for Risk concepts to be executed were analyzed Catalog of concepts, in the particular
Containment and Preparation of the in accordance with their particular specifications and in the work execution
Chromate Site for Remediation Stage 3: specifications, being defined in program, elements that make up the
Works accordance with the framework. project
8
1

for the remaining part of Cell C2”, are current legal framework regarding executive for the formation of the new call
found to be flawed, given that they leave hazardous waste, that the concept of bases to guarantee a single execution
the bidders in a state of uncertainty treating hexavalent chromium waste was time for the works, in accordance with
regarding the actual deadline to execute not necessary, since in accordance with article 45 section X of the Regulation of
all of the works and, as a consequence, the provisions of article 67, section II of the Law on Public Works and Services
to conform their proposals. the General Law for the Prevention and Related Thereto.
Comprehensive Management of Waste,
only Liquid and semi-solid waste will be
subjected to treatment to eliminate
moisture, neutralize or stabilize it and
achieve solidification.
Likewise, NOM-052-SEMARNAT- 2005,
in table 2 “Maximum limits for the toxic
constituents of the PEC extract”,
establishes total chromium as a toxic
inorganic constituent without
differentiating its chemical species
(trivalent and hexavalent), therefore
which
Technically, the treatment process was
not viable because the toxic hazard
characteristic of the waste persisted.
Preventive Action.- Review of each of
the concepts executed in accordance with
the work execution schedule and the
particular specifications, to corroborate
that the measurement units correspond to
completed work and the total time for the
execution of the work is met. the work.
Important technical-legal elements that support the facts of the nonconformity and that affect
the bases of the call.
The bases of National Public Tender No. The PCE annex “Proposal Evaluation
00016057-005-09 Criteria” and the PCA annex “Award
“Actions for Risk Containment and Criteria” were incorporated into the call
Preparation of the Chromate Site for bases in the Section: General Project
Remediation Stage 3: Works for the Corrective Action.- Given the Information. In accordance with what is
remaining part of Cell C2”, lack clear and characteristics, magnitude and stated in article 38 of the Law of Public
detailed procedures and criteria to complexity of the work, two sections were Works and Services Related Thereto; 36,
determine the solvency of the proposals included in the call bases: 37 and 37A of the LOPSRM Regulations
of the participating companies, due in force in 2010.
because the mechanism of points and The first of evaluation criteria for the
percentages was not indicated in proposals in accordance with the
accordance with the provisions of article provisions of article 38 of the Law of
38 of the Law of Public Works and Public Works and Services related to
Services Related Thereto. them (LOPSRM), 36 and 37 of the
LOPSRM Regulations in force in 2010.
The evaluation to determine the technical
solvency of the proposal will be that
which complies with all the requirements
of this call and that from the result of
points and percentages a minimum
acceptance result of 128 points of the
total of the items is obtained.
The economic evaluation will be in
accordance with a binary evaluation of
whether it complies or does not comply
with the indicated requirements.
8
2

in article 37 of the LOPSRM Regulations
in force as of 2010.
The second of award criteria based on
Article 37 A. of the RLOPSRM in force as
of 2010, based on the following terms:
• Price Criterion.
• Criterion related to Quality.
• Financing Criterion.
• Criterion related to Opportunity.
• Criterion related to National Content.
Preventive Action.- In accordance with
the sixth and seventh transitional articles
of the Law of Public Works and Services
Related Thereto, which establishes that
the guidelines for the evaluation of points
and percentages will be published by the
Secretariat of Public Function and that
the contracting procedures, which are in
process of the decree of modifications of
the LOPSRM, will continue to be
processed until their conclusion in
accordance with the provisions of the
LOPSRM, as applicable at the time of
their beginning.
Because in June 2010, these guidelines
had not been published, advice and
support was requested from the Head of
the Public Works Control and Audit Unit
of the Ministry of Public Function, to give
administrative and legal certainty to the
criteria. evaluation and awarding of
proposals.
The bases of National Public Tender No. The appropriate formats, modified or
00016057-005-09 “Actions for Risk Corrective Action .- Formats were those prepared to comply with the
Containment and Preparation of the reviewed and corrected and, where provisions of 37 of the LOPSRM
Chromate Site for Remediation Stage 3: appropriate, new formats were prepared Regulations, were incorporated into the
Works for the remaining part of Cell C2”, for the part of Section III “Proposal call bases in Section III “Proposal
in the formats established to prepare the Requirements” in Part III “Economic Part” Requirements” in Part III “Economic Part”.
complex economic proposal in its of the call bases. valid as of 2010.
structure and filling, causing certainty to
be obtained about the total cost of the Preventive Action.- Formats of the
economic proposal. economic part used by other agencies of
the federal public administration that carry
out public works tenders were reviewed
and consulted.
8
3
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From the inspection visit process No. 16/113/AI/CI-1066/2011, the results report was presented to the
General Directorate of Comprehensive Management of Materials and Risky Activities, on October 5,
2012, four observations were determined with their respective corrective and preventive measures:
Observation No. 01
From the analysis of the estimates paid Corrective action.- The DGGIMAR It is in the process of attention, since 45
and their generating numbers, it was must inform the reasons why it signed calendar days are counted from the
determined that there were excess the agreement dated January 28, 2012, date of notification.
payments in the amount of $939,287.60 which lacks motivation and justification
pesos, since the ordinary concepts in since of the seven concepts, only one
the modifying agreement signed on actually presented an increase in the
January 28, 2012, considered volumes volume of work, and must also make
greater than those actually executed. the necessary arrangements to allow
the refund of the amount of the excess
payments, as well as the financial costs
that are generated until the date of their
return by the contractor, sending to this
control body the documentation that
proves the recovery of the payment in
excess.
Preventive Action.- In the future, the
DGGIMAR must sign the modifying
agreements only in cases in which the
assumptions established in the first
paragraph of article 99 of the Law of
Public Works and Services Related
Thereto are proven.
Observation No. 02
From the analysis of the documentation Corrective Action.- That the It is in the process of attention, since 45
provided by the General Director of DGGIMAR must promptly provide the calendar days are counted from the
Comprehensive Management and justifications for not appropriating date of notification.
Risky Activities, in response to the $1,317,624.05, the amount pending
request for information number payment as of December 31, 2011
16/113/AI/CI-974/2012 dated corresponding to the sixth estimate
September 4, 2012, it was determined (settlement) of the DGRMIS-DAC-
that there is a debt of $ 1,317,624.05 DGGIMAR contract. - OP-001/2011, so
including VAT that corresponds to the that this control body has the elements
amount of the estimate 6 “settlement” that allow it to verify the impossibility of
of the works related to the “Drilling of complying with the provisions of articles
12 exploratory and extraction wells for 53, 54 of the Federal Budget and Fiscal
the remediation of the Cuautitlán- Responsibility Law and 120 of its
Pachuca aquifer locally contaminated Regulations. , and, where appropriate,
by chromium, Tultitlán, State of turn the matter over to the area of
Mexico", debt supported with invoice responsibilities for the appropriate legal
number 0384 dated February 28, 2012, purposes.
of which to date 154 days have passed
without said amount having been
covered to the construction company.
Preventive Action.- That in the future
the necessary actions are carried out to
comply with the provisions that regulate
the registration of liabilities.
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financial results derived from payment
obligations contracted for public works
that, as of December 31 of each year, are
duly
accounted for, accrued and
pending payment, in order to avoid the
recurrence of this observation.
Observation No. 03
Non-compliance with the provisions of It is in the process of attention, since 45

article 166 section III of the Regulations Corrective Action.- The DGGIMAR must calendar days are counted from the date
of the Law of Public Works and Services provide justification by the Work of notification.
Related Thereto. Residence, the Work Supervisor and the
Contractor as to why the Work Delivery-
Receipt Minutes and Completion Minutes
were carried out for the works that do not
correspond in its entirety to the elements
that are being received.
Preventive Action.- In the future, the
DGGIMAR must ensure that the
information contained in the minutes
corresponds to the elements it receives.
Observation No. 04
Corrective Action.- That the DGGIMAR It is in the process of attention, since 45
must provide as soon as possible through calendar days are counted from the date
From the analysis carried out on the documentary support that accredits the of notification.
payments made of the six estimates reasons why reports one through twelve
generated by the company Construction were received and processed as support
and Supervision of San Luis, SA de CV, for the estimates presented for payment,
under the contract DGRMIS-DAC- even without having the signature of
DGGIMAR- 002/2011 for the purpose of those responsible for its issuance in non-
“Supervision of the drilling works of 12 compliance with the provisions of the
exploratory and extraction wells for the Federal Budget and Fiscal Responsibility
remediation of the Cuautitlán-Pachuca Law.
aquifer locally Preventive Action.- That in the future the
contaminated by chrome, Tultitlán, State estimates that are authorized for payment
of Mexico" it was determined that these must be supported by the duly requested
are not duly justified and proven since the reports.
deliverables that support the general
information reports, control of estimates,
physical financial report of the work,
financial graphic report of the work,
photographic report and activity report are
not valid since they are not signed by the
personnel accredited for such purposes.
VIII.5.- Actions carried out to correct or improve its execution.
In November 2007, the Board of Directors of the Chamber of Deputies of the Honorable Congress of
the Union, issued official letter number DGPL 60-II-5-1152, signed by deputies Ruth Zavaleta
Salgado and Antonio Xavier López Adame, President and Secretary, respectively, through which they
informed Mr. Francisco Ramírez Acuña, Secretary of the Interior, about the point of agreement
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approved in the session held on November 6, 2007, which reads:
First . The Chamber of Deputies respectfully urges the Secretariat of Finance and Public Credit of the
federal Executive Branch so that, within the scope of its powers and in coordination with the
Secretariat of the Environment and Natural Resources, it allocates the federal budgetary resources
necessary to comprehensively clean up the the area where the company Cromatos de México, SA
was located, in the municipality of Tultitlán, State of Mexico, considered one of the sites in the country
with the highest degree of contamination by hazardous waste.
Second . The Chamber of Deputies respectfully urges that the National Water Commission, based on
the powers conferred upon it by law, proceed to clean up, as a priority, the groundwater in the area
where the company Cromatos de México was located. in Tultitlán, state of Mexico, in accordance with
the technical and budgetary guidelines determined by that same entity.
On December 19, 2007, through official letter No. 01332, issued by the Senior Official of
SEMARNAT, responded to the previous point of agreement to Mr. Armando Salinas Torre,
Undersecretary of Legislative Liaison Secretariat of the Interior, pointing out the following:
This Secretariat is fully willing to coordinate with the Secretariat of Finance and Public Credit
so that, once the necessary federal budgetary resources have been assigned, they are
invested in the comprehensive sanitation of the site, in accordance with the master
remediation plan, which consists of the treatment of waste and definitive solution to the case.
For this, as a first action , a working group has been established between the different
instances of this Secretariat with attribution in the matter to analyze the different
alternatives for the treatment and comprehensive solution of this site, in order to select the
most viable alternative to carry it out. .
Based on the above, SEMARNAT formalized the ^^^^^^ technical work to determine the actions
to be developed for the remediation of the soil and the aquifer of the Cromatos property^ , with
its first session in January 2008, whose presidency It was headed by the Head of the
Undersecretariat of Management for Environmental Protection and was made up of professional staff
experts in administrative, technical, financial, legal, control and monitoring matters, from the
Administrative Units of SEMARNAT, its Deconcentrated Bodies and Institutions. Academics. The
working group met once a month to review the progress of the risk containment projects, soil and
subsoil remediation, and aquifer remediation, with the aim of promptly correcting technical,
administrative-financial, and legal deviations. or, where appropriate, agree on decision-making for the
improvement of investment projects for the remediation of the soil and aquifer of the Cromatos
property, its structure was formed as follows:
Presidency
86
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Head of the Undersecretary of Management for Environmental Protection (SGPA).
Substitution of the presidency by the Head of the General Directorate of

Comprehensive Management of Materials and Risky Activities.
Administrative-Financial Areas
Senior Officer of SEMARNAT.
General Directorate of Material Resources, Real Estate and Services (DGRMIS).
General Directorate of Programming and Budget.
Deputy General Directorate of Institutional Strategies of the Senior Officer's Office.
Technical Areas
General Directorate of Comprehensive Management of Materials and Risky Activities of the

SGPA.
General Directorate of the National Center for Environmental Research and Training of the
National Institute of Ecology (INE).
Groundwater Management of the National Water Commission (CONAGUA).
PAI General Residence North Zone, of CONAGUA.
Mexican Institute of Water Technology (IMTA) of SEMARNAT.
Legal area
Legal Affairs Coordinating Unit (UCAJ) of SEMARNAT.
Control and monitoring areas
Internal Control Body at SEMARNAT.
Commissioner of the Secretariat of Public Function.
87
Invited Academic and International Cooperation Institutions
Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) of the Federal Government

of Germany.
Autonomous University of Nuevo León (UANL).
For the risk containment actions and the remediation of the soil and subsoil, the working
group held 56 work sessions, the last session for these activities being on August 15, 2012,
declaring the remediation of the site concluded, the presidency remains in charge of
CONAGUA to continue with the remediation actions of the Pachuca-Cuautitlán aquifer,
locally contaminated in Colonia de Lechería.
Figure 2. Structure and members of the Working Committee
SEMARN
AT
SECRETARY OF
ENVIRONMENT AND
NATURAL RESOURCES
A f ImtitutoNxion
IW 1A Imdarlaiamk
ltonspattilp
RN/7 i Federal Ministry of
DIVIL I Economic Cooperation

I and Development
fi I = Deutsche
Gesellschaft
'I A für Internationale AUTONOMOUS UNIVERSITY OF
NUEVO LBÓN
IX. RESULTS AND BENEFITS ACHIEVED
IX.1.- Compliance with the objectives and goals of the Program
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Cromatos de México factory)^, was one of the seven sites committed to goal 34 ( ^ Support the
management and monitor the remediation actions of seven contaminated sites considered as
environmental liabilities”) of the PSMAyRN 2007-2012.
Likewise, the program effectively complied with the regulations indicated in the Temporary
Occupation Agreement, which was the implementation of the actions, until the completion of the
preparation of the site and containment of the risk of the property located on Francisco I Street.
Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico (former Cromatos de México factory),
which are essential to reduce risks to human health and the environment. To subsequently formulate
the Remediation Program in accordance with the applicable legal provisions, containing among its
main elements, Characterization Studies, Environmental Risk Assessment Studies, Historical
Investigations and the Remediation Proposal.
Finally, it complied with what was ordered in the Expropriation Agreement , taking possession of
the property, in order to carry out the necessary measures to prevent the deterioration or destruction
of the natural elements and avoid damage to the health of the population, through the execution of
works aimed at the prevention, conservation, environmental protection and remediation of said
surface, as they are essential to reduce health risks. The remediation of the property was carried out
for the soil and subsoil and initiating in the vadose zone the necessary studies and infrastructure
(monitoring wells) in order for them to be an input for CONAGUA in the aquifer remediation activities.
Likewise, it should be noted that each of the projects, studies or consultancies established in the
Work Program complied with the provisions of the applicable laws, such as the General Law for the
Prevention and Comprehensive Management of Waste and its Regulations, the Law of Public Works
and Services Related Thereto and its Regulations and the Law on Acquisitions, Leases and Services
of the Public Sector and its Regulations.
IX.2.- Results obtained and benefits provided to the target population, in terms of the
works executed.
According to data obtained from the XII general Population and Housing Census of 2005 carried out
by INEGI, the total population of the Municipality of Tultitlán was 472,867 people, which makes the
municipality among the ten most populated municipalities in the State of Mexico, representing the
3.4% of the total population of the State of Mexico.
The division of the population by age groups in the municipality, as of 2005, was composed as
follows: from 0 to 4 years old, 43,968 inhabitants; from 5 to 14 years old, 89,519 inhabitants; 15 to 24
years old, 89,036 inhabitants; from 25 to 59 years old, 205,021 inhabitants; from 60 onwards 45,323
inhabitants. It is worth mentioning that the dairy area is an area with a high migratory flow from
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Central American countries and states in southern Mexico.
Since 1958, the company Cromatos de México was installed in the Lechería neighborhood,
municipality of Tultitlán and it was two decades, after 1970 to 1975, when the damage caused to the
population and workers by the levels of chrome contamination became apparent. .
The symptomatology of health damage that employees and people exposed to hexavalent chromium
presented for many years was perforation of the nasal septum, ulcer-like perforations that reach the
bone system, presenting intense pain and some with fever, additionally. They presented respiratory
problems such as: laryngitis, pharyngitis, tonsillitis and some even bronchitis, which at that time they
associated with exposure to the yellow dust that the company Cromatos de México emitted into the
atmosphere and concentrated in the form of waste in its surrounding yards and a At the “La Reforma”
school, on the other hand, the carcinogenic effects of chromium were unknown, and were not clearly
documented in the international toxicological literature.
This site was the most studied at the national level, the results of which supported the correct
decision-making by the government for its definitive closure in 1978. Likewise, the results of these
studies determined that the population of Colonia Lechería had been exposed and affected by
chromium contamination in water and soil, determining that chromium in the form of chromates, di-
chromates and chromic acid has great toxicity with incidence of cancer in people exposed to the
absorption of chromium and chromates through the alimentary tract and/or located in the lungs, liver
and kidneys, additionally produce acute toxic effects such as skin ulcerations, pharyngitis, bronchitis
and in case of prolonged absorption and continues through the nose, the nasal septum is perforated.
The government authorities continued working to provide a solution to the problem, in 1982, the
Undersecretary of Environmental Improvement through the General Directorate of Water Sanitation of
the Subdirectorate of Engineering prepared the project for the alternative of in situ confinement of
waste. of hexavalent chromium, with an investment of $12 million pesos for the execution of the work
through joint coordination work between the three levels of government.
The on-site disposal of hexavalent chromium waste was not a definitive solution, but rather a
palliative to the environmental and health problems of the Lechería neighborhood, since over time the
confinements presented cracks and fissures, so the Applied Research Center for Industrial
Development (CINADI), carried out a series of studies that include topography, soil mechanics, waste
volumes, analysis of stability and resistance of confinement, chemical analysis of waste and soil
under confinement, and flow analysis of water and contaminants below confinement. The results
demonstrated that the confinement will continue to leach indefinitely due to the formation of potholes,
cracks and the high permeability of the pavement that covers it.
After more than 25 years after the plant was closed and the hazardous waste confinement site with
90
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hexavalent chromium was abandoned, social pressure was growing because the chromium rose to
the surface, becoming evident and dispersing through fissures or cracks and deformations. from the
surface of the confinement causing and at the same time leaching into the soil and subsoil, on the
other hand, the chrome began to damage the concrete structures of the ruins of the hull of what was
the process plant.
The population demanded that approaches and alternatives be analyzed that would allow the
development of strategies to resolve the causes, effects and reactions that affect human health in the
Lechería region, since historically the impact on 68 residents and 22 deaths as a result had been
documented. of toxic dust. On the other hand, the legislative power exerted pressure on the solution
of the environmental problem and by approving a point of agreement in 2008, they urged the Ministry
of the Environment and Natural Resources to provide a solution to the problem through coordination.
with the Ministry of Finance and Public Credit to manage the necessary resources for the remediation
of the soil and subsoil and with CONAGUA for the remediation of the aquifer.
That the severity of the contamination of the site generated an environmental emergency based on
multiple factors, including the toxicity of the hazardous material or waste involved; the imminent
danger of immediate and irreversible damage to the environmental environment; the volume of
contaminants involved, the extent damaged by the contaminant, and the receptors of the
contaminants, which can be biological (protected species and ecosystems) or non-biological (soil and
water) natural resources, and even human beings.
For the above reasons, the ^^^^^^^^

^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^
^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ during the risk containment actions, site preparation
and remediation of the property located on Francisco I Street. Madero No. 30, Colonia Lechería,
Tultitlán, State of Mexico (former Cromatos de México factory)^, satisfactorily completed the site
preparation and risk containment actions, which were essential to reduce risks to human
health and the environment, and subsequently with soil and subsoil remediation actions, with
the aim of removing the source of hexavalent chromium contamination and definitively eliminating the
routes of exposure through inhalation, dermal contact and ingestion to vulnerable receptors, reducing
the risk index to an acceptable level that does not cause adverse effects to human health and the
natural elements existing in the Colonia Lechería area.
Approximately 472,867 inhabitants of the municipality of Tultitlán benefited from these actions, whose
vulnerable recipients, such as children, pregnant women and older adults, represent approximately
70% of the present population. To achieve this benefit it was necessary:
1. Demolition of 6,105.59 m 3 of concrete structures,

2. Excavation of 199,782.34 m 3 of chrome waste and contaminated soil,
91
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3. Filling with 68,745.45 m 3 of clean bench material,

4. Removal of 225 tons of contaminated water,
5. Removal of 228,300.55 tons of chrome waste and contaminated soil confined in two
authorized sites (Ramos Arizpe, Coahuila and Mina, Nuevo León),
6. Placement of 35,302.18 m 2 of asphalt concrete,
7. Construction of foundations, dalas and perimeter walls of 2,251.76 m 2 ,
8. Construction of 9 monitoring/extraction wells for the remediation of the aquifer locally
contaminated with chromium.
92
X.- FINAL REPORT OF THE HEAD OF THE DGGIMAR
Cromatos de México factory)”, to achieve the remediation of the site, it was integrated into 3
investment projects under the Temporary Occupation Agreement, 3 pre-investment programs, 3
projects investment and a technical advisory study under the Expropriation Decree, the total cost of
the investment was $415,578,630.48 during the period 2007-2012, the expenses incurred are
broken down in the table in Figure 3.
Figure 3. Total budget exercised for the period 2007-2012
9
3
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Regarding the volume of work carried out, the amount of 228,300.55 tons of waste and soil
contaminated with hexavalent chromium was sent to confinement to two sites authorized by
SEMARNAT, located in Mina, Nuevo León and Ramos Arizpe, Coahuila; Nine monitoring wells were
built, among others, the detailed results are shown in Figure 4, during the period 2007-2012.
Figure 4. Results obtained during the period 2007-2012
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94
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The site in relation to soil contamination where the confinement cells were located, known as area
C1 and C2, has been cleaned up with restrictions on use in said areas, since the routes and routes
of exposure have been canceled (for inhalation, ingestion and dermal contact) so:
^ The surrounding population is no longer able to inhale chromium dust because the works
carried out prevent the soil that is still contaminated with chromium below 6 meters deep
from being blown by the wind towards the population and the environment. from the colony.
^ The population is no longer able to come into dermal contact with soils contaminated with
chromium, because at the surface level any inappropriate deposits of chromium waste on
the property were eliminated, which were sent to a site authorized by SEMARNAT.
^ The population will not be able to ingest chromium waste or dust, because the engineering
works using a system of multilayer barriers do not allow chromium, which is found at depths
greater than 6 meters, to rise to the surface due to capillary action, since that a high-density
geo-membrane was placed at a depth of three meters and subsequently two layers of clay
compacted to 95% of the Proctor test and finally a sub-base and layer of asphalt concrete
on the surface, coupled with the fact that The sources of water supply to the population are
far from the locally contaminated aquifer.
These cleanup actions are concatenated with the definition of remediation established by the
LGPGIR as a set of measures to which contaminated sites are subjected to eliminate or reduce
contaminants to a safe level for health and the environment or prevent their dispersion in the
environment. environment without modifying them.
The other areas of the property, such as B, A and 3, have concentrations of less than 100 mg/kg of
Hexavalent Chromium, which places them in a type of residential use or as green or recreational
areas depending on whether the reuse of the material is decided. property.
In relation to the executed contracts mentioned above, they are administratively closed except for
contract No. DGRMIS-DAC-DGGIMAR-OP-001/2011, ^^^^^^^^^^^^ ^^ 9 exploratory and extraction
wells for the remediation of the Cuautitlán-Pachuca aquifer locally contaminated by chromium, State
of Mexico”, since payment of the settlement for the amount of $1,317,624.05 with VAT included is
pending, for which the matter is being addressed to seek the corresponding payment mechanism
indicated by the General Directorate of Programming and Budget.
Regarding the attention of the four observations determined in the report and records of findings of
the inspection visit 16/113/AI/CI-1066/2011 carried out, they are in the process of attention and will
be sent to the OIC to be resolved, since the report was notified to this General Directorate on
October 5, 2012, whose commitment date for attention is 45 calendar days from its notification.
Once the site has been cleaned in relation to the soil and subsoil, the process of transferring the
95
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property and access keys must begin between this General Directorate and the General Directorate
of Material Resources, Real Estate and Services of the SEMARNAT directly responsible for the
safeguards. estate.
Finally, it is worth mentioning that with the conclusion of this important stage of sanitation of the soil
and subsoil of the property, the first phase of the objective of the Expropriation Agreement,
published in the Official Gazette of the Federation, on December 17, 2010, is fulfilled. under a public
administrative management model designed ad hoc to the complexity and nature of the site, the
social conditions, the urban environment, the administrative management of resources, the
concurrence of human resources experts in the field and the contaminants present.
ING. EDUARDO ENRIQUE GONZÁLEZ HERNÁNDEZ

GENERAL DIRECTOR OF COMPREHENSIVE MANAGEMENT OF MATERIALS AND RISKY
ACTIVITIES
96
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GLOSSARY OF TERMS
C1.- Confinement cell 1
C2.- Confinement cell 2
CINADI.- Applied Research Center for Industrial Development
CONABIO.- National Commission for the Knowledge and Use of Biodiversity
CONAGUA.- National Water Commission
DGGIMAR.- General Directorate of Comprehensive Management of Materials and Risky Activities
DGPP.- General Directorate of Programming and Budget
DGRMIS.- General Directorate of Materials, Properties and Services
DOF.- Official Gazette of the Federation
GTZ/GIZ.- Gesellschaft für Internationale Zusammearbeit (German Cooperation Agency)
IMTA.- Mexican Institute of Water Technology
INE.- National Institute of Ecology
LAASSP.- Law on Acquisitions, Leases and Public Sector Services
LANFI.- National Industrial Development Laboratories
LFPRH.- Federal Budget and Fiscal Responsibility Law
LGPGIR.- General Law for the Prevention and Comprehensive Management of Waste
LOPSRM.- Law on Public Works and Services Related Thereto
NTN.- Natural Terrain Level
OIC.- Internal Control Body
OLI.- Investment Release Office
OM.- Senior Officer's Office
PCA.- Criteria for Awarding Proposals
PCE .- Proposal Evaluation Criteria
PEF.- Federation Expenditure Budget
PND.- National Development Plan
PROFEPA.- Federal Attorney for Environmental Protection
PSMAYRN.- Environment and Natural Resources Sector Program
________________________________________________________________________________
RH. - Rietzler & Heidrich GmbH
RLOPSRM. - Regulations of the Law of Public Works and Services Related Thereto
97
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SEDUE.- Secretariat of Urban Development and Ecology
SEMARNAT .- Secretariat of Environment and Natural Resources
SHCP .- Ministry of Finance and Public Credit
SBT.- System-Pumping-Treatment
SISCO.- Systematized Information System on the Inventory of Contaminated Sites
SGPA.- Undersecretariat of Management for Environmental Protection
SMA.- Undersecretariat for Environmental Improvement
SSA.- Secretariat of Health and Assistance
UANL.- Autonomous University of Nuevo León
UCAJ.- Legal Affairs Coordinating Unit
UNAM .- National Autonomous University of Mexico
98
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678798:97:
This document is a Photographic Memory that shows the situation of the property located on Francisco I
Street. Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico (Former Cromatos Factory of Mexico)
during its operation in the 1960s and before the execution of the projects to monitor risk containment
actions, site preparation and remediation of the property, to know the state of deterioration and degree of
environmental contamination that were causing an impact on the health of the population and the
environment.
99
PHOTO*GRAPHIC MEMORY OF THE OPERATION OF THE OPERATION
OF
THE CHROMATES FACTORY IN MEXICO IN THE 60'S
Photo of Cromatos de México during its operation in the 60's-view from the Reforma school
10
0
Photo of Cromatos de México during its operation in the 60's - waste disposal
hexavalent chromium
Photo of Cromatos de México during its operation in the 60's - effect at the school
Reforming with hexavalent chromium waste
10
1
Photo of Cromatos de México during its operation in the 60's-view from the school
Reform
Photo of Cromatos de México during its operation in the 60's-environmental impact to the soil and
water
10
2
Photo of Cromatos de México during its operation in the 60's-environmental impact to the soil and
water
Photo of Cromatos de México during its operation in the 60's - inadequate deposit
hexavalent chromium residue
10
3
!"#$% '%(%)*+',-% !"(#. /# 0!. !--,%"#. /# -%"(#"-,1"
/#0 *,#.)%2 3*#3!*!-,1" 4 *#5#/,!-,1" /#0 .,(,% /# 0! #$
'+6*,-! /# -*%5!(%.
Main access to the Cromatos land
10
4
Vacant land Area “A” seen towards southeast
Vacant land Area “B” view of the physical state of the industrial center
10
5
Vacant land Area “B” view of the physical state of the industrial center
10
6
Area “B” panoramic view of the industrial center to the south
Area “B” Hull of the old factory-view towards the north
10
7
Vacant land Area “B” Old factory center-view towards the south
Area “B” Smelting furnaces-view to the west
10
8
Area “B” Smelting furnaces-view to the east
Area “B” Foundry furnaces-walls with hexavalent chromium
10
9
^^^^ ^^^ Filtration plants-view towards the northwest
11
0
^^^^ ^^^ Support walls of separation vats and soil contaminated with Chromium.
^^^^ ^^^ Coverage of the small cemetery and side view from area B. .
11
1
Area “B” warehouse-view to the west
11
2
Area “B” Access to confinement cell “C2” - view towards the northwest
Area “C2” confinement cell “C2” - view of the northern part
11
3
Surface of Cell “C2” Hexavalent Chromium Confinement-view towards the southwest
Surface of Cell “C2” Hexavalent Chromium Confinement-view towards the northwest
11
4
Confinement wall, eastern side and northwestern corner
Surface of Cell "C1" Hexavalent Chromium Confinement-view towards the southeast
11
5
Surface of Cell “C1 and C2” maintenance to subsidence and fractures-view towards northwest
Area “A” Surface contamination due to the spread of hexavalent chromium through fissures and
cracks
of the confinement cells-view towards the east
11
6
Surface of Cell “C2” identification and characterization of confined waste-view toward the
northwest
Surface of Cell "C1" identification and characterization of confined waste-view towards the
south
11
7
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"-",.,,%/0 1" 2&3 &,,%#0"3 1" ,#0)"0,%/0 1"2 $%"3*# 4
5$"5&$&,%/0 1"2 5$"1%# .6%,&1# "0 2& ,&22" ($&0,%3,# %7
!&1"$# 0#7 89: ,#2#0%& 2",;"$<&: ).2)%)2+0: "3)&1# 1"
!=>%,# ?"> (+6$%,& 1" ,$#!&)#3 1" !=>%,#@
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8BCB9CD9BD
This document is a Photographic Memoir that shows the realization of the different projects that were
executed as part of the risk containment actions and preparation of the property located on Francisco I
Street. Madero No. 30, Colonia Lechería, Tultitlán, State of Mexico (Former Cromate Factory of Mexico) to
continue with the preparatory studies to achieve the cleanup of the site in accordance with the provisions
of the current legal framework.
11
8
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^^^^^^^^^ ^^^^ ^^ &#)'%)&-.) /%0 "-%12# $ !"%!3"3&-.) /%0 1-' -# !3"3 03

"%30-43&-.) /% 031 #5"31 /% "%6%/-3&-.) 78% "%180'%) -6!"%1&-) /-50%1 !
3"3 "%/8&-" 0#1 "-%12#1 3 03 1308/ 9863)3 $ 30 6%/-# 365-%)'%: %) 03 %;
<=>5"-&3 /% &"#63'#1 /% 6?;-&#: 85-&3/3 %) %0 68)I&I!IO /% TULTITLÁN,
STATE OF MEXICO"
Photo of Cromatos de México during the start of work on the demolition of the ruins of the industrial
center
11
9
Photo of Cromatos de México installation of machinery and equipment for the demolition of ruins of
the
industrial helmet
Photo of Cromatos de México installation of machinery, equipment and dust protection tents
for the demolition of ruins of the industrial center
12
0
Photo of Cromatos de México installation of machinery and equipment for the demolition of ruins of
the
industrial helmet
12
1
Photo of Cromatos de México installation and assembly of dust control equipment in tents for
demolition of ruins of the industrial center
12
2
Photo by Cromatos de México Demolition of ruins of the industrial center
12
3
Photo by Cromatos de México Loading of debris for final disposal
12
4
Photo by Cromatos de México Loading of debris for final disposal
12
5
Photo by Cromatos de México terms and works of project No. 1
12
6
PROJECT No. 2
RISK CONTAINMENT AND SITE PREPARATION ACTIONS IN THE DEMOLITION

WORKS OF CELL C1 AND PART OF CELL C2, OF THE PROPERTY OF THE FORMER
CROMADOS DE MEXICO FACTORY OF THE COLONIA LECHERÍA, IN THE
MUNICIPALITY OF TULTITLÁN, STATE OF MEXICO
Photo of Cromatos de México during the beginning of the demolition work of Cell "C1" and part of U
C2”
12
7
Photo of Cromatos de México Loading of hexavalent chromium waste deposited in the cell
Photo of Cromatos de México Loading of hexavalent chromium waste deposited in the cell
“C1”
12
8
Photo of Cromatos de México Loading of hexavalent chromium waste deposited in cell "C1"
Photo of Cromatos de México Loading of hexavalent chromium waste deposited in cell “C2”
12
9
Photo of Cromatos de México Temporary cover of the hexavalent chromium waste of the part
remnant of cell “C2”
Photo of Cromatos de México Temporary cover of the hexavalent chromium waste of the part
remnant of cell “C2”
13
0
!"#$%&'# )*+ ,
-&&.#)%/ !-"- &#)'%)&.0) 1%2 ".%/3# $ !"%!-"-&.0) 1%2 /.'.# 1% &"#4-'#/ !-"- /5
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Photo of Cromatos de México during the start of the work on the complementary works of the property and the
remaining part of the “C2”
13
1
13
2
Photo of Cromatos de México Loading of hexavalent chromium waste deposited in
the cell t
o
C
2
13
3
Photo of Cromatos de México removal of hexavalent chromium waste deposited in the
cell “C2"
to
C2
13
4
Photo of Cromatos de México removal of hexavalent chromium waste deposited in the
cell “C2"
13
5
13
6
Photo by Cromatos de México Demolition of walls of cell "C2"
13
7
Photo of Cromatos de México Covered with temporary protection of the “C2” cell
13
8
Photo of Cromatos de México Covered with temporary protection of the “C2” cell
13
9
Photo of Cromatos de México Work in Cell C1 (Demolition of concrete slab, loading,
transportation and final disposal)
14
0
14
1
Photo of Cromatos de México Area “C2” at the end of the risk containment actions and
site preparation
14
2
Photo of Cromatos de México Area “C1” at the end of the risk containment actions and
site preparation
14
3
Photo of Cromatos de México Area “B” at the end of the risk containment actions and
site preparation
14
4
Photo of Cromatos de México Area “A” at the end of the risk containment actions and
site preparation
14
5
Photo by Cromatos de México Visit of Secretary Juan Rafael Elvira Quezada to the former
Factory of
Chromates during the execution of the work
14
6
Photo by Cromatos de México Visit of Secretary Juan Rafael Elvira Quezada to the former Factory of
Chromates during the execution of the work
14
7
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($&-,%.,# %5 !&/"$# -#5 678 ,#1#-%& 1",9"$:&8 )31)%)1+-8
".)&/# /" !;<%,# ="< (+4$%,& /" ,$#!&)#. /" !;<%,#>
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6ABA7BC7AC
This document is a Photographic Memoir showing the realization of the different projects that were
executed as part of the remediation actions of the property located on Francisco I Street. Madero No.
30, Colonia Lechería, Tultitlán, State of Mexico (Former Cromate Factory of Mexico) with the purpose of
reusing the site according to the public utility decided by SEMARNAT.
14
8
!"#$%&' ^#)*+*,'" %! -$!"#)!' .*)* */#$*0&1*) 0* -*23&#$% %!
0* /'3#*-&3*/&43 %!0 .)!%&' $+&/*%' !3 0* /*00! 5)*3/&"/' &6
-*%!)' 3'6 789 /'0'3&* 0!/:!);*9 #$0#&#0<39 !"#*%' %! -=>&/'?
/'3 $3* "$.!)5&/&! %! 7@97AA6B7 - ^ C
Photo by Cromatos de México Sampling work to update the magnitude of the

contamination once risk containment actions have been completed
UANL
ALTONOMA UNIVERSITY OF NUEVOLEON ADDRESS
SAMPLING PLAN FOR THE CONTRACT
No. DGRMIS-DAC-DGGIMAR-01 6/2011
“SAMPLING WORK TO UPDATE THE

MAGNITUDE OF POLLUTION OF THE PROPERTY LOCATED
ON FRANCISCO I MADERO STREET No. 30. COLOGNE
DAIRY. MEXICO STATE"
SECRETARY OF ENVIRONMENT AND NATURAL RESOURCES
14
9
Photo of Cromatos de México Sampling work ^sample taking
Photo by Cromatos de México Sampling work ^ Geophysical profile of the soil at the point of
sampling
15
0
Photo of Cromatos de México Sampling work ^ identification and labeling of samples
Photo of Cromatos de México Sampling work ^ elaboration of chains of custody
15
1
Photo of Cromatos de México Sampling work ^conservation of samples
Photo Chromates- Surface level hexavalent chromium concentrations
15
2
Photo Chromates- Concentrations of hexavalent chromium at 0.3 meters depth
Cr CONTENT IN SOIL A
0.3M DEPTH
LEGEND
Cr content (mg/Kg) <280
HI280-510
■ 510-1000
mm 1000-2000
2000 - 3000
3000 - 4000
4000 - 5000
■ 5000 - 6000
6000 - 7000
7000 - 8000
8000 - 9000
m 9000 - 10000
M1 10000-11000
• Hole position | |
Property polygon
0 20 40 60 80 Meters
1.5M DEPTH
Cr content (mg/Kg) <

280 m 280 - 510 ■ 510 -
1000 mm 1000 - 2000
2000 - 3000 3000 - 4000
4000 - 5000 5000 - 6000
6000 - 7000 7000 - 8000
8000 - 9000 ■ ■ 9000 -
10000 mm 10000- 11000
• Hole position |
[ Property polygon
0 20 40 60 80 Meters
15
3
3.0M DEPTH
LEGEND
Cr content (mg/Kg) <280 m 280-510
■ 510-1000 m 1000-2000 ■ 2000 -
3000 3000 - 4000 4000 - 5000 | 5000 -
6000 6000 - 7000 7000 - 8000 8000 -
9000 m 9000 - 10000 mm 10000-
11000
• Drilling position | |
Property polygon
Photo Chromates-
Concentrations of hexavalent
0 20 40 60 80 Meters
chromium at 6.0 meters
depth
6.0M DEPTH
Cr content (mg/Kg) < 280 m 280-510 ■ 510- 1000 m 1000-2000 ■ 2000 - 3000 3000 - 4000 4000 - 5000 7" 5000 - 6000 6000 - 7000 7000 -
8000 8000 - 9000 m 9000 - 10000 Emm 10000 - 11000
• • Drilling
position | | Property polygon
0 20 40 60 80 Meters
15
4
15
5
Photo Cromatos- Hexavalent chromium concentration pen
15
6
(J AN L VIEW TOWARDS THE

NORTHWEST 2011 PRESUMED FOCUS OF POLLUTION THROUGH THE
OPERATION OF A Cr VI ABSORPTION WELL
Pl
<EDlo
Pf
^£Dlo
CONCENTRATION OF
Cr VI IN Mg/Kg
280.0
510.0
1000.0
u
WITH CUT IN SECTION OF THE POLLUTION 2000.0
FOCUS IN CRB-C9
VIEW TOWARDS THE

NORTHWEST
2011
CONCENTRATION OF
Cr VI IN Mg/Kg
POLLUTION BULB
WITH CUT IN MANTLE SECTION BETWEEN CRB-C12, CRB-14 AND CRB-C15
15
7
15
8
15
9
!"#$%&' ^!)*+$*,&-. #/,.&,*0!,'.-1&,* %! #!,.'+'23*" %!
4!1',&-. %! ,4'1' 5*4* 4!1!%&*,&-. %!+ *,$36!4' ,$*$#&#+7.0
5*,8$,*^
Photo by Cromatos de México- Chromium Removal Technologies for Remediation of the Cuautitlán-
Pachuca Aquifer
16
0
Chromium Removal Technologies for Remediation of the Cuautitlán-Pachuca Aquifer
Determination of physicochemical parameters and sampling of contaminated water
Chromium Removal Technologies for Cuautitlán-Pachuca Aquifer Remediation Testing

in semi-pilot plants in the laboratory
Figure 3.4. Semi-pilot plant for continuous testing with redox-assisted chemical coagulation, a)
Water containers (influent) and semi-pilot plant with the units of: rapid mixing, flocculation,
high-rate sedimentation and filtration; b) Pumps for dosing reagents, c) Flocculation unit with
three flocculation chambers; and d) High rate settler
16
1
pilot on site

pilot on site
16
2
Chromium Removal Technologies for Remediation of the Cuautitlán-Pachuca Aquifer
Final disposal of sludge from pilot tests on site
16
3
^^^^^^^^ ^!"#$%#&'()* ," -. !%/%0 "1!2%#&3%#(%0 4 "13#&''()* !&#& 2&
#"5",(&'()* ,"2 &'67$"#% '6&63(328*9!&':6'&; 2%'&25"*3" '%*3&5(*&,% !%#
'#%5%; "* 3623(32&*; "03&,% ," 5<1('%^
Photo by Cromatos de México- Monitoring drilling wells
16
4
Well Drilling_Well Drilling Site Location
Well Drilling_Nucleator Holes
16
5
Well Drilling_Nucleator Holes
Well drilling sample recovery and classification
16
6
16
7
16
8
Drilling wells in the northwestern part of the "C2"
16
9
Drilling of wells in the southern part of property “A”
17
0
Drilling wells in the garden and property "3"
Drilling of wells, welding of ademe and counterdeme and grooved pipes
17
1
Drilling of wells, geo-physical records and geo-positioning of wells
Well drilling, sludge disposal and equipment decontamination
17
2
Drilling wells recovery of geological sections
Well Capacity ^^^^
17
3
Well Capacity "4B"
Well Capacity "4C"
17
4
Well Capacity "5A"
Well Capacity "5B"
17
5
Capacity of Wells "4D and 4E”
17
6
Wells “5A", 5B and 5C"
17
7
!"#$%&'# ^#)"*+ ,% -./%.-%"0* !*"* 1* "%2%,-*&-3. ,%1 +4%1# &#.'*2-.*,# %.
%1 !"%,-# 4)-&*,# %. 1* &*11% 5"*.&-+&# -6 2*,%"# .#6 789 %. *1 &#1#.-*
1%&:%"0*9 '41'-'1;.9 %+'*,# ,% 2<=-&#^^
Photo of Cromatos de México- Works for the remediation of the soil and subsoil
17
8
Excavation to a depth of 2 meters
Debris removal and cleaning work on property "3"
17
9
18
0
Filling and compaction works on Site "3"
Excavation up to a depth of 6 meters
18
1
18
2
Compaction at a depth of 6 meters
Geo-membrane placement at a depth of 6 meters
18
3
Filling at 6 meter level
Compaction at 3 meter level
18
4
Filling and compaction at natural ground level
Asphalt irrigation and impregnation
18
5
18
6
Fence Construction
18
7
Photos of remediation completion
18
8
18
9
19
0
19
1
PROJECT ^PROTECTION OF FOUR EXPLORATORY-EXTRACTION WELLS FOR THE
REMEDIATION OF THE CUAUTITLÁN-PACHUCA AQUIFER LOCALLY
CONTAMINATED BY CHROMIUM; DEMOLITION-CONSTRUCTION OF
CONTAMINATED SIDEWALKS ON THE PROPERTY LOCATED ON FRANCISCO I
STREET. WOOD NO. 30 COLONIA LECHERÍA, TULTITLÁN, STATE OF MEXICO
PERIMETERS AND ELABORATION DESIGNATIONS".
Sidewalk Demolition
Sidewalk Construction
19
2
Construction of Well Protection of the C2 property
Preparation and placement of signs
19
3

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Monitoring of risk containment actions, site preparation and

www.semarnat.gob.mx Live better

GENERAL DIRECTORATE OF INTEGRAL MANAGEMENT OF MATERIALS AND

VII.4.5.- Investment Release Letters. 69

/%$",,%0- *"-"$&1 /" *".)%0- %-)"*$&1 /" !&)"$%&1". ? &,)%@%/&/". $

Eng. Eduardo Enrique González Hernández

1.1. - NAME OF THE PROGRAM

1.2. - DOCUMENTED VALIDITY PERIOD

January 1, 2007 to October 31, 2012.

1.3. - GEOGRAPHICAL LOCATION

Construction table of “area A”.

COURSE DISTANCE BOUNDARIES

N 16°22'28.38" AND 57.23 Reforma Street

Yes 1204441.24" W 57.23 Francisco Street. YO. Log

Source: Temporary occupation decree, November 30, 2006. Official diary.

Construction table “area B”.

COURSE DISTANCE BOUNDARIES

N 16°22'28.38" AND 96.59 Reforma Street

N 75°08'12.15" W 7.60 area C

N 71 °30'45.65" W 8.55 area C

N 72009’54.36" W 21.30 area C

Yes 11 946’21 .29" W 33.65 Francisco Street. YO. Log

COURSE DISTANCE BOUNDARIES

Yes 11 °33'22.32" W 27.76 Francisco Street. YO. Log

Yes 06°36'34.93" W 17.71 Francisco Street. YO. Log

Source: Temporary occupation decree, November 30, 2006. Official diary.

Construction table “area C”.

COURSE DISTANCE BOUNDARIES

N 16941’34.76" AND 4.35 area B

Yes 71 °30'45.65" AND 8.55 area B

Yes 75°08'12.15" AND 7.60 area B

N 13°26'55.22" AND 18.42 area D

N 08°05'39.91" AND 53.17 area 1

Yes 1405418.31" W 69.20 area 1

Yes 14°15'09.38" W 61.28 area 1

Yes 13°43'24.85" W 9.37 area 1

Source: Temporary occupation decree, November 30, 2006. Official diary.

COURSE DISTANCE BOUNDARIES

N 14°38'36.12" AND 11.54 area B and C

N 75°06'51.29" W 5.72 area 3b

Yes 75°02'21.21" AND 44.77 area C

Yes 76°24'28.86" AND 110.04 area C

N 08°12'41.27" AND 58.30 private property

Yes 14°56'24.83" W 65.98 private property

Yes 14°44'12.06" W 72.19 private property

Yes 11 946’21 .29" W 5.17 private property

Source: Temporary occupation decree, November 30, 2006. Official diary.

Construction chart of “premise 3”.

COURSE DISTANCE BOUNDARIES

N 12°26'54.39" AND 67.57 private property

Yes 16°59'38.31" W 67.32 Reforma Street

Source: Temporary occupation decree, November 30, 2006. Official diary.

I.4.- MAIN TECHNICAL CHARACTERISTICS

• “Sampling work to update the magnitude of contamination of the property located on

• “Development of a study Environmental Risk Assessment (ERA) of the property

• "Executive Project of engineering works for remediation ground

I.5.- ADMINISTRATIVE UNIT

/%$",,%0- "-"$&1 /" ".)%0- %-)"*$&1 /" !&)"$%&1". ? &,)%@%/&/". $