odessa chromium #2 (andrews highway)cooling water system until about 1976. this system, tied into...

ODESSA CHROMIUM #2 (ANDREWS HIGHWAY)

Site Information:

Site Name: ODESSA CHROMIUM #2 (ANDREWS HIGHWAY)Address: ODESSA, TX

EPA ID: TXD980697114EPA Region: 06

Record of Decision (ROD):

ROD Date: 09/08/1986Operable Unit: 01ROD ID: EPA/ROD/R06-86/011 Media: GROUNDWATER

Contaminant: CHROMIUM

Abstract: THE ODESSA CHROMIUM II SITE CONSISTS OF A SERIES OF

CHROMIUM CONTAMINATED WELLS WITHIN 200 ACRESOF URBAN AREA LOCATED JUST OUTSIDE THENORTHWESTERN CITY LIMITS OF ODESSA, ECTORCOUNTY, TX. THE SITE AREA IS COMPOSED OF AMIXTURE OF RESIDENTIAL, COMMERCIAL ANDINDUSTRIAL FACILITIES. NEARLY EVERY RESIDENCE ORCOMMERCIAL FACILITY IS SERVED BY ONE OR MOREWATER WELLS COMPLETED IN THE TRINITY AQUIFERWHICH OFFERS THE ONLY SOURCE OF POTABLEGROUNDWATER. TWO POTENTIAL SOURCES OFGROUNDWATER CONTAMINATION AT THE SITE HAVEHAVE BEEN IDENTIFIED; 5329 ANDREWS HIGHWAY, ANDWOOLEY TOOL AND MANUFACTURING AT 57TH STREETAND ANDREWS HIGHWAY. BETWEEN 1950 AND 1965, THE5329 ANDREWS HIGHWAY SITE WAS OCCUPIED BYCONTINENTAL PRODUCTS OF TX, A PRODUCER OF ACHROMIUM CONTAINING COOLING WATER ADDITIVE.BASIN RADIATOR AND SUPPLY, COMMENCINGOPERATIONS AT THIS SITE SOMETIME BETWEEN 1965 AND1969, WAS INVESTIGATED BY THE LOCAL HEALTHDEPARTMENT IN 1970 IN RESPONSE TO A COMPLAINT OFCONTAMINATED (5.5 MG/L CHROMIUM) WELL WATER ONTHE PROPERTY TO THE SOUTH OF THE COMPANY.

WASTEWATER ANALYSIS, AT THAT TIME, DID NOTINDICATE THE PRESENCE OF CHROMIUM, BUT IN 1978, APARTIALLY BURIED STEEL TANK LEAKED A CLEANINGVAT SOLUTION CONTAINING 2.8 MG/L CHROMIUM.WOOLEY TOOL AND MANUFACTURING, OPERATINGSINCE ABOUT 1950 UTILIZED CHROMATES IN THEIRCOOLING WATER SYSTEM UNTIL ABOUT 1976. THISSYSTEM, TIED INTO ONE OF THE PLANT'S WATER WELLS,COULD HAVE INADVERTENTLY BACK FLUSHED INTO THEWELL DURING OCCASIONAL SLOW DOWNS DUE TO THEABSENCE OF A CHECK VALVE. UNTIL ABOUT 1970, THEPLANT ALSO DISPOSED OF CHROMATE CONTAMINATEDWASTEWATER IN AN UNLINED PIT. THE PRIMARYCONTAMINANT OF CONCERN IS CHROMIUM.

THE SELECTED REMEDIAL ACTION INCLUDES;EXTENSION OF MUNICIPAL WATER SERVICE TO THEAFFECTED AREA OF THE SITE. THIS INVOLVESNEGOTIATIONS WITH THE CITY AND LOCAL RESIDENTS.THE CAPITAL COST FOR THIS ACTION IS $476,570 WITHANNUAL O&M COSTS OF $51,575 TO BE SPENT OVER A 15YEAR PERIOD.

Remedy: - NEGOTIATE AGREEMENTS WITH CITY AND CONSUMERS

TO EXTEND CITY WATER SYSTEM.- CONSTRUCT WATER DISTRIBUTION SYSTEM.

Text: Full-text ROD document follows on next page.

Text: ODESSA CHROMIUM II, ODESSA, TEXAS.

#DR DOCUMENTS REVIEWED

I AM BASING MY DECISION ON THE FOLLOWING DOCUMENTS DESCRIBING THE ANALYSIS OF COST EFFECTIVENESS OF REMEDIAL ALTERNATIVES (OPERABLE UNIT) FOR THE ODESSA CHROMIUM II SITE.

- ODESSA CHROMIUM II REMEDIAL INVESTIGATION REPORT (APRIL 1986)

- ODESSA CHROMIUM II ALTERNATIVE WATER SUPPLY FEASIBILITY STUDY (JUNE 1986)

- SUMMARY OF REMEDIAL ALTERNATIVE SELECTION1 Order number 940620-113550-ROD -001-001 page 565 set 4 with 66 of 66 items

- RESPONSIVENESS SUMMARY.

#DE DECLARATION

CONSISTENT WITH THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY ACT OF 1980 (CERCLA) AND THE NATIONAL CONTINGENCY PLAN (40 CFR PART 300), I HAVE DETERMINED THAT THE SELECTED REMEDY FOR THE ODESSA CHROMIUM II SITE IS A COST-EFFECTIVE REMEDY AND PROVIDES ADEQUATE PROTECTION OF PUBLIC HEALTH, WELFARE AND THE ENVIRONMENT. THE STATE OF TEXAS HAS BEEN CONSULTED AND AGREES WITH THE APPROVED REMEDY (ATTACHMENT A). IN ADDITION, THE ACTION WILL REQUIRE FUTURE OPERATION AND MAINTENANCE OF THE WATER DISTRIBUTION SYSTEM.

I HAVE ALSO DETERMINED THAT THE ACTION BEING TAKEN IS APPROPRIATE WHEN BALANCED AGAINST THE AVAILABILITY OF TRUST FUND MONIES FOR USE AT OTHER SITES AND IS NECESSARY TO PROTECT PUBLIC HEALTH, WELFARE OR THE ENVIRONMENT.

SEPTEMBER 8, 1986 DICK WHITTINGTON, P.E. DATE REGIONAL ADMINISTRATOR REGION VI.

SUMMARY OF REMEDIAL ALTERNATIVE SELECTION

OPERABLE UNIT - ALTERNATIVE WATER SUPPLY

ODESSA CHROMIUM II ODESSA, TEXAS

SEPTEMBER 1986

#SLD SITE LOCATION AND DESCRIPTION

THE ODESSA CHROMIUM II SUPERFUND SITE CONSISTS OF A SERIES OF CHROMIUM CONTAMINATED WELLS WITHIN 200 ACRES OF URBAN AREA LOCATED IMMEDIATELY WEST OF THE ANDREWS HIGHWAY JUST OUTSIDE THE NORTHWESTERN CITY LIMITS OF ODESSA, ECTOR COUNTY, TEXAS (FIGURE 1-1). BASED ON THE BOUNDARIES OF PRESENTLY KNOWN CHROMIUM CONTAMINATION IN THE GROUNDWATER OF THE TRINITY AQUIFER, THE SITE AREA IS BOUNDED APPROXIMATELY BY 57TH STREET ON THE NORTH, 50TH STREET ON THE SOUTH, ANDREWS HIGHWAY ON THE EAST AND A LINE WHICH EXTENDS FROM ARTHUR AVENUE NORTH TO 57TH STREET AND SOUTH TO 50TH STREET (FIGURE 2-13). THE SITE AREA IS COMPOSED OF A MIXTURE OF RESIDENTIAL, COMMERCIAL AND INDUSTRIAL FACILITIES. NEARLY EVERY RESIDENCE OR COMMERCIAL FACILITY IS SERVED BY ONE OR MORE WATER WELLS1 Order number 940620-113550-ROD -001-001 page 566 set 4 with 66 of 66 items

COMPLETED IN THE TRINITY AQUIFER WHICH OFFERS THE ONLY SOURCE OF POTABLE GROUNDWATER.

#SH SITE HISTORY

FROM 1950 TO 1965, CONTINENTAL PRODUCTS OF TEXAS (CONTINENTAL) PRODUCED COOLING WATER ADDITIVES WHICH CONTAINED CHROMATES AT 5329 ANDREWS HIGHWAY. MR. DALE MEYER HAS REPORTED THAT WHEN (IN NOVEMBER 1951) HE OCCUPIED THE PROPERTY LOCATED AT 54TH STREET AND ANDREWS HIGHWAY WHICH ADJOINED CONTINENTAL, HIS WELL WATER WAS BRIGHT YELLOW IN COLOR, PRESUMABLY THE RESULT OF CHROMIUM CONTAMINATION.

BASIN RADIATOR AND SUPPLY BEGAN OPERATION AT THE 5329 ANDREWS HIGHWAY LOCATION SITE SOMETIME BETWEEN 1965 AND 1969. LOCAL HEALTH DEPARTMENT AUTHORITIES, INVESTIGATED A COMPLAINT OF CONTAMINATED (5.5 MG/L CHROMIUM) WELL WATER ON THE PROPERTY TO THE SOUTH OF 5329 ANDREWS HIGHWAY IN 1970. AT THAT TIME, ANALYSIS OF WASTEWATER FROM BASIN RADIATOR DID NOT INDICATE THE PRESENCE OF CHROMIUM, BUT IN 1978 THEIR CLEANING VAT SOLUTION, WHICH WAS EVENTUALLY STORED IN PARTIALLY BURIED STEEL TANKS, CONTAINED 2.8 MG/L OF CHROMIUM. ONE OF THE STORAGE TANKS WAS DISCOVERED TO BE LEAKING AND THE TANKS WERE SUBSEQUENTLY REMOVED.

WOOLLEY TOOL AND MANUFACTURING HAS BEEN OPERATING AT 57TH STREET AND ANDREWS HIGHWAY SINCE ABOUT 1950. CHROMATES WERE UTILIZED IN THEIR COOLING WATER SYSTEM UNTIL ABOUT 1976. THIS SYSTEM WAS APPARENTLY TIED INTO ONE OF THE PLANT'S WATER WELLS AND DURING OCCASIONAL SLOW DOWNS, COOLING WATER COULD HAVE BEEN INADVERTENTLY BACK FLUSHED INTO THE WELL SINCE THERE WAS NO CHECK VALVE. THE PLANT ALSO UTILIZED AN UNLINED PIT FOR THE DISPOSAL OF CONTAMINATED WASTEWATER, INCLUDING CHROMATE WASTES FROM THE COOLING WATER SYSTEM, UNTIL ABOUT 1977.

IN LATE 1983, THE TEXAS WATER COMMISSION (TWC) SUBMITTED THE HAZARD RANKING PACKAGE TO THE ENVIRONMENTAL PROTECTION AGENCY (EPA) FOR THE ODESSA CHROMIUM II SITE. THE SITE WAS ADDED TO EPA'S NATIONAL PRIORITIES LIST IN 1984, THEREBY BECOMING A SUPERFUND SITE. THE STATE OF TEXAS ENTERED INTO COOPERATIVE AGREEMENT WITH EPA FOR $530,000 ON SEPTEMBER 26, 1984, TO PERFORM FORWARD PLANNING AND REMEDIAL INVESTIGATIONS/FEASIBILITY STUDIES (RI/FS) AT THE SITE. THE RI BEGAN IN AUGUST 1985 AND A DRAFT REPORT WAS SUBMITTED APRIL 1986.

IN JANUARY 1986, EPA AND THE TWC DECIDED TO PRODUCE A "FOCUSED" FEASIBILITY STUDY (FFS). THE SINGLE PURPOSE OF THE FFS WAS TO BE THE EXAMINATION OF POSSIBLE ALTERNATIVE WATER SUPPLIES WHICH COULD PROVIDE POTABLE WATER TO THE AREA(S) WITHIN THE GREATER ODESSA CHROMIUM II SITE WHERE GROUNDWATER IS CONTAMINATED OR COULD REASONABLY BE EXPECTED TO BECOME CONTAMINATED BY CHROMIUM WITHIN 24 MONTHS. WHILE THE GOAL OF THE EPA IS TO DETERMINE A PLAN FOR ADDRESSING THE CHROMIUM CONTAMINATION IN THE GROUNDWATER, THE FFS PLACED A PORTION OF THE FULL FEASIBILITY STUDY1 Order number 940620-113550-ROD -001-001 page 567 set 4 with 66 of 66 items

ON A "FAST TRACKED" SCHEDULE. BY DOING SO, IT OPENED THE POSSIBILITY OF EXPEDITING THE SUPPLY OF POTABLE WATER TO AFFECTED RESIDENTS WITHOUT WAITING FOR COMPLETION OF THE FULL FS. THE FFS BEGAN IN MARCH 1986, AND A REVISED DRAFT REPORT HAS BEEN SUBMITTED.

#CSS CURRENT SITE STATUS

GEOLOGY

THE SURFICIAL SOIL IN THE SITE AREA IS PRINCIPALLY AMARILLO LOAM. GENERALLY, IT IS A REDDISH-BROWN, FINE SANDY LOAM WHICH RANGES IN DEPTH FROM 8 TO 12 INCHES BELOW GRADE. BELOW THAT, TO DEPTHS VARYING FROM 18 TO 24 INCHES, THE RED OR CHOCOLATE-RED SUBSOIL GRADES FROM FINE SANDY LOAM TO SANDY CLAY, GRADUALLY BECOMING HEAVIER WITH DEPTH. PLEISTOCENE WINDBLOWN SAND, PLAYA DEPOSITS AND ALLUVIUM DEPOSITS UNDERLIE THE SOIL SECTION. BENEATH THE PLEISTOCENE ARE PLIO-PLEISTOCENE CALICHE DEPOSITS.

UNDERLYING THE CALICHE ARE SCATTERED EROSIONAL REMNANTS OF THE TERTIARY OGALLALA FORMATION COMPOSED OF GRAVELS, SANDS, SILTS AND CLAYS. THESE BASAL SEDIMENTS OCCUPY PREVIOUSLY ERODED DRAINAGE VALLEYS AND ARE NOT PRESENT EVERYWHERE. CEMENTATION OF THE SANDS IS VARIABLE WITHIN THE OGALLALA. THIS FORMATION DOES NOT GENERALLY EXTEND TO DEPTHS BELOW 75 FEET IN THE AREA.

THE CRETACEOUS TRINITY FORMATION, THE MAIN FRESH WATER PRODUCING AQUIFER IN THE AREA, UNDERLIES THE OGALLALA INTERVAL. IT IS COMPOSED OF SANDS AND SANDSTONES WITH MINOR AMOUNTS OF SILTSTONE, CLAY AND GRAVEL. CEMENTATION OF THE TRINITY IN THE SITE AREA RANGES IN DEGREE FROM MODERATE TO HEAVY. THE AQUITARD BENEATH THE TRINITY FORMATION IS THE DOCKUM GROUP OF TRIASSIC AGE, LOCALLY KNOWN AS "REDBEDS". THE UPPER

UNIT, THE CHINLE FORMATION, CONSISTS OF UP TO 600 FEET OF RED AND REDDISH-BROWN CLAYS AND SHALES.

GROUNDWATER

THE MAJOR HYDROLOGIC UNITS CONTAINING POTABLE WATER IN THE SITE AREA ARE THE OGALLALA FORMATION AT APPROXIMATELY 70 FEET BELOW THE AREA AND THE TRINITY SAND AT APPROXIMATELY 90 FEET BELOW THE AREA (FIGURE 2-2). IN GENERAL, THE OGALLALA IS HYDROLOGICALLY CONNECTED WITH THE UNDERLYING TRINITY AND HAS LITTLE OR NO SATURATED THICKNESS. A FEW MILES TO THE SOUTHWEST THE OGALLALA HAS BEEN TOTALLY ERODED AND WITHIN THE SITE AREA IS ONLY A THIN REMNANT CONTAINING LITTLE WATER. GROUNDWATER OCCURS BENEATH THE SITE MAINLY IN THE TRINITY SAND. THE HYDRAULIC CHARACTERISTICS OF THE OGALLALA ARE OF GREATER IMPORTANCE LOCALLY THAN THE QUANTITY OF WATER PRESENT DUE TO THE FACT THAT THE OGALLALA MAY POTENTIALLY ACT AS A MEDIUM THROUGH WHICH CONTAMINANTS MAY ENTER THE UNDERLYING TRINITY AQUIFER. BARRIERS TO VERTICAL MOVEMENT EXIST IN THE OGALLALA AS DISCONTINUOUS LENSES OF CALCITE OR CEMENTED SANDSTONE.1 Order number 940620-113550-ROD -001-001 page 568 set 4 with 66 of 66 items

THESE LENSES WERE ENCOUNTERED IN DRILLING AT THE SITE AND VARY FROM LESS THAN 6 INCHES TO SEVERAL FEET IN THICKNESS.

ANOTHER INFLUENCE ON CONTAMINATION MOVEMENT SEEMS TO BE THE CALICHE LAYER NEAR THE SURFACE. SHALLOW BORINGS INDICATE THAT IT ACTED AS A RELATIVELY EFFECTIVE BARRIER TO THE DOWNWARD MIGRATION OF CONTAMINATION CAUSED BY LEACHING OF THE SOIL.

WELL INVENTORY

AN INVENTORY OF EXISTING WATER WELLS IN AND AROUND THE PREVIOUSLY IDENTIFIED AREA OF CHROMIUM CONTAMINATION WAS CONDUCTED IN SEPTEMBER 1985. THE PRIMARY GOAL OF THIS WORK WAS TO CONFIRM AND REFINE THE BOUNDARIES OF THE PLUME OF CHROMIUM CONTAMINATION. OVER 400 WELLS WERE IDENTIFIED DURING THE INVENTORY, OF WHICH MORE THAN 300 WERE SAMPLED AND ANALYZED, FOR HEXAVALENT CHROMIUM. THE INVENTORY COVERED AN AREA EXTENDING IN A RADIAL DIRECTION ABOUT HALF-A-MILE BEYOND THE KNOWN AREAS OF GROUNDWATER CONTAMINATION. TWENTY WELLS WERE FOUND TO HAVE CHROMIUM IN THE WATER.

FROM THE WELL INVENTORY, SEVERAL CONCLUSIONS WERE DRAWN ABOUT THE CONTAMINATION PLUME. THE FIRST WAS THAT THERE WERE TWO POTENTIAL SOURCES OF THE CONTAMINATION RESULTING IN TWO PLUMES (INSTEAD OF THE PREVIOUS CONCEPT OF ONE). THE SECOND WAS THAT ANY INDIVIDUAL WELL COULD HAVE WIDE FLUCTUATIONS IN THE CHROMIUM CONCENTRATIONS OVER A PERIOD OF TIME. THIS WAS BASED ON COMPARISONS WITH THE RESULTS OF PREVIOUS TWC SAMPLING. AS A RESULT OF THESE FLUCTUATIONS, NO LOGICAL CONCENTRATION CONTOUR MAP COULD BE CONSTRUCTED. AS A RESULT, IT APPEARS THE CONTAMINATION ENTERS THE GROUNDWATER IN "PULSES" WHICH ARE EITHER NATURAL OR MAN INDUCED.

DEFINITION OF PRESENT AND PROJECTED CONTAMINATION AREA

THE ESTIMATED EXTENT OF CHROMIUM CONTAMINATION IN THE TRINITY AQUIFER IS SHOWN IN FIGURE 2-8. HISTORICAL LEVELS OF CHROMIUM CONCENTRATIONS MEASURED IN AREA WELLS BETWEEN 1970 AND 1986 ARE PRESENTED IN TABLE 2-4. THERE ARE TWO PLUMES, ONE WHICH APPEARS TO RADIATE OUTWARD FROM WOOLLEY TOOL (ANDREWS HIGHWAY AND 57TH STREET) AND ONE ORIENTED SOUTH-SOUTHWEST FROM BASIN RADIATOR (5329 ANDREWS HIGHWAY). SAMPLES COLLECTED OF WATER FROM THE NEWLY INSTALLED MONITOR WELLS HAVE REVEALED THREE ADDITIONAL AREAS OF CONTAMINATION WHICH HAD BEEN CONSIDERED CLEAN DURING THE DRILLING PROGRAM.

THE OCCURRENCE OF CHROMIUM CONTAMINATION AT OR ABOVE THE DRINKING WATER STANDARD IS MORE FREQUENT IN EXISTING WATER WELLS THAN IN NEWLY INSTALLED MONITOR WELLS. THIS IS PROBABLY DUE TO THE FACT THAT MANY OF THE EXISTING WELLS WERE NOT CASED THROUGH THE CONTAMINATION IN THE PERCHED WATER ZONE. THE PROBABLE MIGRATION OF CONTAMINANTS IN A SOUTHERLY DIRECTION IN THE PERCHED GROUNDWATER ZONE IS APPARENT WHEN THE HYDRAULIC GRADIENT IS CONSIDERED.1 Order number 940620-113550-ROD -001-001 page 569 set 4 with 66 of 66 items

OVER THE ENTIRE AREA MAKING UP THE ODESSA CHROMIUM II SITE, THE REGIONAL HYDRAULIC GRADIENT IN THE TRINITY IS TO THE SOUTHWEST WITH A SLOPE VARYING BETWEEN 10 AND 80 FEET PER MILE. CONTAMINATED WATER ENTERING THE TOP OF THE TRINITY AQUIFER SPREADS OUT HORIZONTALLY IN A SOUTHWESTERLY DIRECTION. VERTICALLY, IT CAN BE PRESUMED THAT THE CONTAMINANTS MOVE PROGRESSIVELY DEEPER WITH INCREASING DISTANCE FROM THE SOURCE IN THIS RELATIVELY HOMOGENEOUS AQUIFER.

AS SHOWN IN FIGURE 2-8, THERE APPEAR TO BE TWO DISTINCT PLUMES OF CHROMIUM CONTAMINATION IN THE TRINITY AQUIFER WITHIN THE SITE AREA. BASED ON THE START OF MANUFACTURING OR PROCESS OPERATIONS, FIRST REPORTS OF CONTAMINATION, AND HISTORICAL SAMPLING DATA (TWC RECORDS), IT IS POSSIBLE TO ESTIMATE CONTAMINANT MIGRATION RATES FOR BOTH PLUMES.

THE NORTHERN PLUME APPEARS TO RADIATE OUTWARD FROM WOOLLEY TOOL AND PRESENTLY SHOWS THE HIGHEST CONCENTRATIONS IN A HORSESHOE SHAPED HALO SOME 1,000 FEET WEST, SOUTHWEST, AND SOUTH OF THE ORIGINAL PLANT LOCATION. CONTAMINATION IN TRINITY WELLS ON THE WOOLLEY PROPERTY WAS FIRST CONFIRMED IN 1977. ASSUMING IT MAY HAVE BEEN PRESENT AS LONG AS 10 TO 20 YEARS BEFORE THIS DATE, IT CAN BE ESTIMATED THAT MIGRATION VELOCITY HAS AVERAGED BETWEEN 30 AND 50 FEET PER YEAR.

FOR THE SOUTHERN PLUME, WHICH IS INTERPRETED TO RADIATE OUTWARD FROM THE PROPERTY AT 5329 ANDREWS HIGHWAY, A SIMILAR CALCULATION CAN BE MADE. STARTING FROM THE FIRST REPORTS OF CONTAMINATED WATER MADE BY MR. MEYER IN 1951 AND THE START OF MANUFACTURING AT THE LOCATION UTILIZING CHROMIUM IN 1950, CONTAMINANTS HAVE HAD 36 YEARS TO ENTER THE TRINITY AQUIFER AND MIGRATE DOWNGRADIENT. BASED ON THESE DATA, AN AVERAGE MIGRATION VELOCITY OF SLIGHTLY OVER 30 FEET PER YEAR CAN BE ESTIMATED.

EXPOSURE ASSESSMENT/APPLICABLE OR RELEVANT AND APPROPRIATE FEDERAL

REQUIREMENTS

THE PUBLIC HEALTH EVALUATION PROCESS AS DESCRIBED IN THE EPA DRAFT SUPERFUND PUBLIC HEALTH EVALUATION MANUAL (DECEMBER 18, 1985) STATES THAT THE PROJECTED CONCENTRATION OF THE INDICATOR CHEMICALS AT THE EXPOSURE POINTS SHOULD BE COMPARED TO APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS. THE NATIONAL CONTINGENCY PLAN (NCP) DEFINES WHAT IS CONSIDERED POTENTIALLY "APPLICABLE OR RELEVANT AND APPROPRIATE"; THE FEDERALLY SET DRINKING WATER LIMITS ARE INCLUDED IN THE LIST. COMPARISON OF THE DATA COLLECTED IN THE RI TO HEALTH GUIDELINES AIDS IN DETERMINING WHETHER A REMEDIAL RESPONSE ACTION IS NECESSARY TO PROTECT THE PUBLIC HEALTH AND ENVIRONMENT.

FOR THE ODESSA CHROMIUM II SITE, THE RECEPTOR EXPOSURE POINTS ARE ASSUMED TO BE THE WATER SUPPLY WELLS, THE INDICATOR CHEMICAL IS CHROMIUM AND THE APPLICABLE OR RELEVANT REQUIREMENT IS THE FEDERAL DRINKING WATER STANDARD PROMULGATED UNDER THE SAFE DRINKING WATER ACT (SDWA).

1 Order number 940620-113550-ROD -001-001 page 570 set 4 with 66 of 66 items

DURING THE REMEDIAL INVESTIGATION, TWO CONTAMINANTS, ZINC AND CHROMIUM, WERE FOUND AT LEVELS ABOVE THE DETECTION LIMITS OF 0.05 AND 0.01 MG/L RESPECTIVELY IN THE EXISTING SUPPLY WELLS TESTED. ALL REPORTED VALUES FOR ZINC ARE BELOW THE EPA SECONDARY MAXIMUM CONTAMINANT LEVEL IN DRINKING WATER OF 5 MG/L. ZINC AT THESE CONCENTRATIONS IS NOT CONSIDERED A PUBLIC HEALTH CONCERN AND IS EXCLUDED FROM FURTHER CONSIDERATION IN THE EVALUATION PROCESS.

HOWEVER, REPORTED CHROMIUM CONCENTRATIONS MAY BE SIGNIFICANT FROM A PUBLIC HEALTH PERSPECTIVE. THIRTEEN OUT OF TWENTY CONTAMINATED WELLS SAMPLED DURING THE RI HAD CHROMIUM LEVELS AT OR ABOVE 0.05 MG/L (THE MAXIMUM CONCENTRATION LIMIT (MCL)). EIGHT OF THESE THIRTEEN WELLS HAD VALUES AT OR ABOVE 0.12 MG/L (THE PROPOSED RECOMMENDED MAXIMUM CONCENTRATION LIMIT (RMCL) FEDERAL REGISTER, NOV. 13, 1985). SEE TABLE 2-3 FOR DATA AND SUMMARY STATISTICS.

SINCE CHROMIUM HAS AN APPLICABLE RELEVANT, AND APPROPRIATE REQUIREMENT, I.E., THE EPA DRINKING WATER STANDARDS, THAT REQUIREMENT IS USED AS THE BASIS FOR THE TARGET CONCENTRATION. CONSEQUENTLY, THE PUBLIC HEALTH EVALUATION IS COMPLETE WHEN THE CONCENTRATION OF CHROMIUM IN THE WELLS IS COMPARED TO THE STANDARD.

THE WELLS WITH VALUES ABOVE THE MCL OF 0.05 MG/L ARE NOT SUITABLE FOR USE AS A LIFETIME DRINKING WATER SUPPLY AND AN ALTERNATE WATER SUPPLY IS INDICATED.

AS REQUIRED BY THE SDWA, EPA ACTED QUICKLY FOLLOWING THE PASSAGE OF THE SDWA IN PUBLISHING INTERIM PRIMARY DRINKING WATER REGULATIONS. REGULATIONS WERE ESTABLISHED FOR TEN INORGANIC CHEMICALS, SIX PESTICIDES AND TWO MICROBIOLOGICAL INDICATORS.

THE MAXIMUM CONTAMINANT LEVEL (MCL) FOR TOTAL CHROMIUM UNDER THE

NATIONAL INTERIM PRIMARY DRINKING WATER REGULATIONS WAS SET AT 0.05 MG/L IN 1977 AND WAS BASED ON THE 1962 PUBLIC HEALTH SERVICE LIMITS.

AS A SECOND STEP, EPA WAS REQUIRED TO PROPOSE AND PROMULGATE REVISED PRIMARY DRINKING WATER REGULATIONS. TO REVISE THE INTERIM PRIMARY DRINKING WATER REGULATIONS, THE AGENCY MUST FIRST PROPOSE AND PROMULGATE A RECOMMENDED MAXIMUM CONCENTRATION LIMIT, WHICH IS A NON-ENFORCEABLE HEALTH GOAL BASED ON THE PREMISE THAT "NO KNOWN OR ANTICIPATED ADVERSE EFFECTS ON THE HEALTH OF PERSONS WILL OCCUR AND WHICH ALLOWS AN ADEQUATE MARGIN OF SAFETY". (FEDERAL REGISTER, NOV. 13, 1985, P. 46937).

CHROMIUM IS CLASSIFIED IN EPA'S GUIDELINES FOR CARCINOGENIC RISK ASSESSMENT AS A CLASS A CARCINOGEN, BASED UPON POSITIVE INHALATION DATA FOR HEXAVALENT CHROMIUM IN HUMANS AND ANIMALS. THE CLASS A CATEGORY IS AT THE TOP OF THE SCALE, INDICATING THE GREATEST STRENGTH OF EVIDENCE SUGGESTING THE CHEMICAL'S CARCINOGENICITY.

THE EVIDENCE INDICATES, HOWEVER, THAT HEXAVALENT CHROMIUM IS1 Order number 940620-113550-ROD -001-001 page 571 set 4 with 66 of 66 items

CARCINOGENIC WHEN INHALED AS A FUME BUT NOT WHEN INGESTED. SINCE CHROMIUM HAS NOT BEEN SHOWN TO BE CARCINOGENIC THROUGH INGESTION EXPOSURE, EPA HAS RECENTLY PROPOSED A RMCL BASED ON CHRONIC TOXICITY DATA. A RMCL OF 0.12 MG/L IS PROPOSED FOR TOTAL CHROMIUM, I.E., CR III PLUS CR VI IN DRINKING WATER (FEDERAL REGISTER, NOV. 13, 1985).

THE THIRD STEP WILL BE FOR EPA TO PROPOSE A MCL AS CLOSE TO THE RMCL AS FEASIBLE. FEASIBLE IS DEFINED AS "WITH THE USE OF BEST TECHNOLOGY TREATMENT TECHNIQUES AND OTHER MEANS WHICH EPA FINDS ARE GENERALLY AVAILABLE (TAKING COST INTO CONSIDERATION)". THE NEW CHROMIUM MCL WILL PROBABLY BE PROPOSED BY EPA IN THE FALL OF 1986. SINCE THE RMCL IS A GOAL, THE MCL WILL MOST LIKELY BE SET AT OR ABOVE THE RMCL LIMIT OF 0.12 MG/L.

#CR COMMUNITY RELATIONS

THIS SECTION WILL BE COMPLETED AFTER THE PUBLIC COMMENT PERIOD. (SEE ATTACHMENT B).

#ENF ENFORCEMENT

THE GOAL OF THE EPA IS TO HAVE THOSE RESPONSIBLE FOR CONTAMINATION PERFORM THE CLEANUP OF THE SITE. THE AGENCY HAS IDENTIFIED AT LEAST TWO POTENTIALLY RESPONSIBLE PARTIES AT THE ODESSA II SITE. THESE PARTIES HAVE BEEN NOTIFIED THAT THEY MAY UNDERTAKE, OR PARTICIPATE IN, THE CHOSEN REMEDY. IF THEY DECLINE INVOLVEMENT IN THE REMEDIAL ACTION, EPA WILL PURSUE APPROPRIATE ENFORCEMENT ACTION.

#AE ALTERNATIVES EVALUATION

THE PRESENCE OF CHROMIUM IN WATER SUPPLY WELLS AT LEVELS ABOVE THE MAXIMUM CONTAMINANT LEVEL ESTABLISHED UNDER THE NATIONAL INTERIM PRIMARY DRINKING WATER REGULATIONS REPRESENTS A THREAT TO PRESENT AND FUTURE PUBLIC HEALTH AND WELFARE. A RESPONSE TO THE RELEASE OF CHROMIUM IN THE GROUNDWATER IS APPROPRIATE IN ACCORDANCE WITH THE NATIONAL CONTINGENCY PLAN (NCP), 40 CFR PART 300. THE RESPONSE ACTION TOWARD MITIGATING THE RELEASE OF CHROMIUM IS CURRENTLY UNDER STUDY IN ACCORDANCE WITH THE NCP, 40 CFR 300.68(D).

A DISCRETE PART OF AN ENTIRE ACTION THAT WILL DECREASE THE PATHWAY OF EXPOSURE IS KNOWN AS AN OPERABLE UNIT. AN OPERABLE UNIT, 40 CFR 300.68(C), MAY BE IMPLEMENTED BEFORE FINAL REMEDIAL ACTION IS SELECTED FOR A SITE. THE CLEANUP OF GROUNDWATER CONTAMINATION PLUMES IS SO TIME-CONSUMING THAT A NEED FOR ALTERNATIVE WATER SUPPLY IS OFTEN1 Order number 940620-113550-ROD -001-001 page 572 set 4 with 66 of 66 items

REQUIRED TO PROTECT PUBLIC HEALTH AND WELFARE UNTIL THE COMPLETION OF THE REMEDY. ALTERNATE WATER SUPPLIES CAN BE PROVIDED AS AN OPERABLE UNIT OF THE ENTIRE ACTION. TO SATISFY NCP REQUIREMENTS, INCLUDING THE REQUIREMENT THAT THE OPERABLE UNIT BE COST-EFFECTIVE AND CONSISTENT WITH A PERMANENT REMEDY, 40 CFR 300.68(C)(3), A FFS WAS COMPLETED FOR THE ODESSA CHROMIUM II SITE. THE PURPOSE OF THE FFS WAS TO DEVELOP AND EVALUATE ALTERNATIVE WATER SUPPLY OPTIONS IN TERMS OF COST, ACCEPTABLE ENGINEERING PRACTICES AND EFFECTIVENESS IN CONTRIBUTING TO THE PROTECTION OF PUBLIC HEALTH, WELFARE AND THE ENVIRONMENT.

THE FFS WAS WRITTEN IN ACCORDANCE WITH CURRENT EPA GUIDANCE, SPECIFICALLY "GUIDANCE DOCUMENT FOR PROVIDING ALTERNATIVE WATER SUPPLIES" (DRAFT) AND "GUIDANCE ON FEASIBILITY STUDIES UNDER CERCLA". SEVEN WATER SUPPLY OPTIONS WERE IDENTIFIED FOR EVALUATION IN THE FFS:

- NO ACTION (ALTERNATIVE I),

- DEVELOPMENT OF SURFACE WATER SUPPLY (ALTERNATIVE II),

- DEVELOPMENT OF AN OVERSIZED COMMUNITY STORAGE FACILITY TO COMPENSATE FOR LOSS OF EXISTING SYSTEM CAPACITY (ALTERNATIVE III),

- BLENDING THE CONTAMINATED PORTION OF THE WATER SUPPLY WITH UNCONTAMINATED WATER SUPPLIES TO REDUCE CONTAMINANTS TO SAFE LEVELS (ALTERNATIVE IV),

- REMOVAL OF CONTAMINANTS VIA TREATMENT (ALTERNATIVE V),

- DEVELOPMENT OF A NEW WATER WELL FIELD OUTSIDE THE AREA OF CONTAMINATION (ALTERNATIVE VI), OR

- CONNECTION WITH AN EXISTING MUNICIPAL OR PRIVATE SUPPLY (ALTERNATIVE VII).

THESE SEVEN ALTERNATIVES WERE SUBJECT TO AN INITIAL SCREENING PROCESS TO NARROW THE LIST OF POTENTIAL REMEDIAL ACTIONS FOR FURTHER DETAILED ANALYSIS (40 CFR 300.68(G)). THE THREE BROAD CRITERIA USED IN THE INITIAL SCREENING ARE COST, ACCEPTABLE ENGINEERING PRACTICES AND EFFECTIVENESS. A BRIEF DESCRIPTION OF THE ALTERNATIVES AND SUMMARY OF THE INITIAL SCREENING FOLLOWS.

NO ACTION (ALTERNATIVE I)

A NEW SOURCE OF POTABLE WATER WOULD NOT BE SUPPLIED TO THE AREA UNDER THIS ALTERNATIVE. THE THREAT TO THE PUBLIC HEALTH AND ENVIRONMENT WOULD REMAIN UNCHANGED SINCE THE AFFECTED PEOPLE WOULD CONTINUE TO HAVE THEIR HEALTH THREATENED DUE TO USE OF CHROMIUM CONTAMINATED WATER. THIS ALTERNATIVE FAILS THE INITIAL SCREENING CRITERIA OF EFFECTIVELY PROTECTING THE PUBLIC HEALTH AND WELFARE.1 Order number 940620-113550-ROD -001-001 page 573 set 4 with 66 of 66 items

DEVELOPMENT OF SURFACE WATER SUPPLY (ALTERNATIVE II)

THE DEVELOPMENT OF SURFACE WATER (RIVERS, STREAMS, LAKES, PONDS AND RESERVOIRS) WOULD BE CONSIDERED UNDER THIS ALTERNATIVE. THE POTENTIAL FOR DEVELOPING A NEW SURFACE WATER SUPPLY FROM STREAMS, LAKES OR RIVERS IS NONEXISTENT IN THE SITE DUE TO THE LACK OF A RELIABLE YEAR ROUND SOURCE. THE POSSIBILITY DOES EXIST OF PURCHASING WATER FROM THE COLORADO RIVER MUNICIPAL WATER DISTRICT WHICH MAINTAINS STORAGE RESERVOIRS ONE-HALF MILE SOUTH OF THE ODESSA CHROMIUM II SITE. THIS ALTERNATIVE WILL BE EXPENSIVE AND DIFFICULT TO ARRANGE BUT IS EFFECTIVE AND FEASIBLE. ALTERNATIVE II WAS SUBJECTED TO A MORE DETAILED ANALYSIS.

DEVELOPMENT OF AN OVERSIZE COMMUNITY STORAGE FACILITY (ALTERNATIVE III) AND BLENDING OF CONTAMINATED WATER WITH UNCONTAMINATED WATER (ALTERNATIVE IV)

BOTH THESE ALTERNATIVES HAVE TWO BASIC PREREQUISITES: A CENTRAL DISTRIBUTION SYSTEM AND AN EXISTING, LOW YIELD SUPPLY OF POTABLE WATER WHICH COULD BE PUMPED INTO A STORAGE FACILITY. NEITHER OF THE PREREQUISITES IS MET AT ODESSA CHROMIUM II AND BOTH ALTERNATIVES ARE ELIMINATED FROM FURTHER CONSIDERATION.

REMOVAL OF CONTAMINANTS VIA TREATMENT (ALTERNATIVE V)

A TREATMENT PROCESS TO REMOVE CHROMIUM FROM THE GROUNDWATER TO BRING THE WATER WITHIN THE DRINKING WATER STANDARDS IS CONSIDERED IN THIS ALTERNATIVE.

THIS CAN BE ACCOMPLISHED BY TREATMENT AT INDIVIDUAL WELLS OR AT A CENTRAL TREATMENT PLANT. THREE TREATMENT METHODS, PRECIPITATION, ION EXCHANGE AND REVERSE OSMOSIS, WERE CONSIDERED. PRECIPITATION AND

REVERSE OSMOSIS, WHILE CAPABLE OF REMOVING MOST OF THE CHROMIUM, WOULD NOT REDUCE THE CONCENTRATION BELOW THE DRINKING WATER STANDARD OF 0.05 MG/L. ONLY ION EXCHANGE IS A VIABLE TREATMENT PROCESS. INDIVIDUAL HOUSEHOLD ION EXCHANGE UNITS ARE COSTLY AND REQUIRE SENSITIVE WATER QUALITY CONTROL. A CENTRAL ION EXCHANGE SYSTEM OFFERS THE FEWEST NUMBER OF SERIOUS DRAWBACKS AND WAS CONSIDERED IN MORE DETAIL.

DEVELOPMENT OF A NEW WELL FIELD (ALTERNATIVE VI)

UNDER THIS ALTERNATIVE, A SUPPLY OF WATER COULD BE DEVELOPED BY DRILLING NEW WELLS AWAY FROM THE CONTAMINATED AREA AND BRINGING THE WATER TO THE AFFECTED AREA. DUE TO LAND USE RESTRICTIONS, OWNERSHIP RESTRICTIONS AND LOCATIONS OF POOR QUALITY WATER, ONLY THE AREA SOUTH OF YUKON ROAD AND EAST OF ECTOR AVENUE, 1.5 MILES NORTHEAST OF THE SITE, CAN BE CONSIDERED FOR A NEW WELL FIELD. THIS ALTERNATIVE WILL BE EXPENSIVE BUT IS FEASIBLE AND WAS CONSIDERED FOR FURTHER ANALYSIS.

CONNECTION WITH AN EXISTING MUNICIPAL WATER SUPPLY (ALTERNATIVE VII)1 Order number 940620-113550-ROD -001-001 page 574 set 4 with 66 of 66 items

THIS ALTERNATIVE WOULD CONSIST OF THE EXTENSION OF THE CITY OF ODESSA LINES BEYOND THE CITY LIMITS INTO THE AFFECTED AREAS. THE CITY OF ODESSA IS FORBIDDEN BY ORDINANCE FROM SUPPLYING WATER TO CUSTOMERS OUTSIDE THE CITY LIMITS. ANNEXATION OF AN AREA IS REQUIRED IN ORDER TO EXTEND WATER SERVICE BUT RESIDENTS OF THE AFFECTED AREA HAVE EXPRESSED OPPOSITION TO ANNEXATION. THE ALTERNATIVE DOES APPEAR FEASIBLE IN SPITE OF THIS PROBLEM AND WAS CONSIDERED FOR FURTHER ANALYSIS.

DETAILED ANALYSIS

THE PRELIMINARY SCREENING PROCESS HAS REDUCED THE SEVEN OPTIONS FOR ALTERNATIVE WATER SUPPLIES DOWN TO FOUR OPTIONS:

- DEVELOPMENT OF A SURFACE WATER SUPPLY (ALTERNATIVE II)

- REMOVAL OF CONTAMINANTS VIA TREATMENT (ALTERNATIVE V)

- DEVELOPMENT OF A NEW WELL FIELD (ALTERNATIVE VI)

- CONNECTION WITH AN EXISTING MUNICIPAL WATER SUPPLY SYSTEM (ALTERNATIVE VII).

THE PRELIMINARY SCREENING PROCESS HAS ALSO SHOWN THAT FOR ALTERNATIVE II AND ALTERNATIVE VI COST SAVINGS CAN BE REALIZED FOR BOTH BY COMBINING CERTAIN PORTIONS OF THE WATER SUPPLY SYSTEM FOR THE ODESSA CHROMIUM I AND II PROJECTS. FURTHER DISCUSSION WILL ADDRESS THIS CONDITION.

THE DETAILED ANALYSIS OF THE FINAL FOUR ALTERNATIVES FOLLOWS THE OUTLINE OF 40 CFR 300.68(H) WHICH REQUIRES AN EXTENSIVE EVALUATION OF THE POTENTIAL PLANS. THIS EVALUATION INCLUDES AN ENGINEERING ANALYSIS, ANALYSIS OF IMPLEMENTABILITY, COST ANALYSIS, ENVIRONMENTAL PROTECTION

ANALYSIS, PUBLIC HEALTH ANALYSIS AND REGULATORY/INSTITUTIONAL ANALYSIS. THE COST ANALYSIS IS SUMMARIZED IN TABLE 6-1. TABLE 6-2 GIVES THE AVERAGE RESIDENTIAL MONTHLY WATER BILL THAT CAN BE EXPECTED UNDER EACH PLAN. THE DETAILED ANALYSIS OF THE FOUR PLANS IS SUMMARIZED IN TABLE 6-3. IMPORTANT FINDINGS FROM THE DETAILED ANALYSIS OF EACH ALTERNATIVE FOLLOWS.

DEVELOPMENT OF SURFACE WATER SUPPLY (ALTERNATIVE II)

THE WATER SUPPLY OF THE COLORADO RIVER MUNICIPAL WATER DISTRICT (CRMWD) IS ADEQUATE, RELIABLE AND OF GOOD QUALITY. A WATER ASSOCIATION OR PRIVATE CORPORATION WILL BE NECESSARY TO OWN AND OPERATE THE TREATMENT SYSTEM AND DISTRIBUTION SYSTEM. THE TOTAL CAPITAL COST IS ESTIMATED AT $661,675 WITH ANNUAL OPERATION AND MAINTENANCE COST OF $114,400. THE PUBLIC HEALTH WILL BE WELL SERVED AND NO ADVERSE ENVIRONMENTAL IMPACTS WOULD TAKE PLACE DUE TO THIS ALTERNATIVE. THE CITY OF ODESSA HAS RIGHT OF FIRST REFUSAL WITH CRMWD THEREBY COMPLICATING NEGOTIATIONS FOR THE WATER.1 Order number 940620-113550-ROD -001-001 page 575 set 4 with 66 of 66 items

REMOVAL OF CONTAMINANTS VIA TREATMENT (ALTERNATIVE V)

A CENTRAL SYSTEM UTILIZING ION EXCHANGE WOULD REQUIRE AT LEAST NINE WATER WELLS PUMPING CONTAMINATED WATER FROM THE AFFECTED AREA TO THE SYSTEM. THE TREATMENT SYSTEM WOULD BE SOPHISTICATED AND REQUIRE TRAINED PERSONNEL WORKING FOR A WATER ASSOCIATION TO RUN AND MAINTAIN THE EQUIPMENT. THE CAPITAL COST ESTIMATE IS $1,471,885 WITH OPERATION AND MAINTENANCE COST ESTIMATED AT $360,700 ANNUALLY. A MAJOR NEGATIVE ASPECT IS THE REQUIREMENT OF THE NINE WATER WELLS PUMPING FROM THE CONTAMINATED AREA. THE CHARACTERISTICS OF THE AQUIFER WOULD DICTATE THAT THE WELLS BE SPREAD THROUGHOUT THE PLUME AREA CAUSING NINE PUMPING CENTERS WITH CORRESPONDING CONES OF DEPRESSION LEADING TO FURTHER MIGRATION OF THE CONTAMINANTS.

DEVELOPMENT OF A NEW WELL FIELD (ALTERNATIVE VI)

THE 100-ACRE TRACT ENVISIONED FOR THIS ALTERNATIVE REPORTEDLY CONTAINS ENOUGH GOOD QUALITY WATER TO MEET THE DEMAND OF THE ODESSA CHROMIUM II SITE. VALUABLE WATER RIGHTS WOULD NEED TO BE PURCHASED AND A TREATMENT/DISTRIBUTION SYSTEM CONSTRUCTED. THE ESTIMATED CAPITAL COST IS $3,676,800 WITH ANNUAL OPERATION AND MAINTENANCE COST OF $119,850. NO ADVERSE ENVIRONMENTAL IMPACTS WOULD OCCUR AND THE PUBLIC HEALTH WOULD BE WELL SERVED BY THIS ALTERNATIVE.

CONNECTION WITH AN EXISTING MUNICIPAL WATER SUPPLY (ALTERNATIVE VII)

THIS IS THE ONLY ALTERNATIVE WHICH CONSIDERS THE PURCHASE OF TREATED WATER RATHER THAN RAW WATER. THE CITY OF ODESSA HAS AN ADEQUATE SUPPLY OF GOOD QUALITY WATER WHICH MORE THAN MEETS PUBLIC HEALTH REQUIREMENTS. THE EXTENSION OF THE CITY WATER LINES IS SIMPLE AND INEXPENSIVE AT $476,570 IN CAPITAL COST WITH ANNUAL OPERATION AND MAINTENANCE COST OF

$51,575.

NO ADVERSE ENVIRONMENTAL IMPACTS WOULD OCCUR. THE CITY POLICY OF NONSERVICE TO AREAS OUTSIDE OF THE CITY LIMITS IS A MAJOR RESTRICTION BUT THE CITY OF ODESSA HAS INDICATED A WILLINGNESS IN THE FORM OF A MARCH 25, 1986, CITY RESOLUTION TO CONSIDER A SPECIAL EXTENSION OF CITY WATER TO THE SITE AREA.

#RA RECOMMENDED ALTERNATIVE

THE NATIONAL CONTINGENCY PLAN (40 CFR 300.68(I)) REQUIRES EPA TO SELECT THE COST-EFFECTIVE REMEDIAL ALTERNATIVE THAT EFFECTIVELY MITIGATES AND MINIMIZES THE THREAT TO AND PROVIDES ADEQUATE PROTECTION OF PUBLIC HEALTH AND WELFARE AND THE ENVIRONMENT. FURTHERMORE, THE SELECTED REMEDY MUST ATTAIN OR EXCEED APPLICABLE OR RELEVANT AND APPROPRIATE FEDERAL PUBLIC HEALTH AND ENVIRONMENTAL REQUIREMENTS THAT1 Order number 940620-113550-ROD -001-001 page 576 set 4 with 66 of 66 items

HAVE BEEN IDENTIFIED FOR THE SITE. THE FOUR ALTERNATIVES UNDER CONSIDERATION MEET THIS REQUIREMENT BY REDUCING THE CHROMIUM LEVELS BELOW THE MAXIMUM CONTAMINANT LEVEL OF 0.05 MG/L. EPA MUST SELECT FROM THE FOUR ALTERNATIVES THE PLAN WHICH IS COST-EFFECTIVE. EPA RECOMMENDS THAT ALTERNATIVE VII, CONNECTION WITH AN EXISTING MUNICIPAL WATER SUPPLY, BE SELECTED AS THE COST-EFFECTIVE ALTERNATIVE FOR THE ODESSA CHROMIUM II SITE. THIS ALTERNATIVE CONSISTS OF THE EXTENSION OF THE CITY OF ODESSA WATER LINES TO THE AFFECTED AREA AND SUBSEQUENT SUPPLY OF WATER FROM THE CITY. DETAILS ON THE WATER LINE EXTENSION ARE PROVIDED IN FIGURES 5-9 AND 5-10.

IN FIRST ANALYZING THE COST OF THE ALTERNATIVES, THE RECOMMENDED ALTERNATIVE IS CLEARLY THE ADVANTAGEOUS PLAN. THE NUMBERS IN TABLE 6-1 TRANSLATE INTO A CONSIDERABLE SAVINGS IF THE EXTENSION OF MUNICIPAL WATER SERVICE IS IMPLEMENTED OVER THE OTHER THREE ALTERNATIVES. A SAVINGS OF 150% TO 780% IS REALIZED BY THE RECOMMENDED ALTERNATIVE VII. THE PROPERTY OWNERS WILL ALSO HAVE MUCH LOWER WATER BILLS UNDER ALTERNATIVE VII.

IN TERMS OF EFFECTIVENESS, ALL THE PLANS MEET THE GOAL OF SUPPLYING WATER THAT WILL PROTECT THE PUBLIC HEALTH AND WELFARE. ONLY ALTERNATIVE VII SUPPLIES TREATED WATER WITHOUT THE NEED FOR CONSTRUCTION AND OPERATION OF A TREATMENT SYSTEM. THIS IS AN ADVANTAGE FOR THE EXTENSION OF MUNICIPAL WATER SERVICE.

INSTITUTIONAL DRAWBACKS ARE PRESENT IN ALL THE ALTERNATIVES. THE PURCHASE OF SURFACE WATER OR WATER RIGHTS IN ALTERNATIVES II AND VI WILL BE DIFFICULT. THE OPERATION OF A WATER ASSOCIATION AS CALLED FOR BY THE THREE REJECTED ALTERNATIVES WOULD BE A BURDEN TO THE PEOPLE IN THE AFFECTED AREA. THESE INSTITUTIONAL ISSUES ARE NOT PRESENT IN THE RECOMMENDED ALTERNATIVE, HOWEVER THE EXTENSION OF THE CITY'S WATER LINES WILL REQUIRE AN EXCEPTION TO THE RULES GOVERNING WATER SUPPLIED ACROSS

CITY LIMITS. THIS PROBLEM HAS SHOWN TO BE SOLVABLE DUE TO THE COOPERATIVE SPIRIT OF THE CITY OF ODESSA, GIVING ALTERNATIVE VII ANOTHER ADVANTAGE OVER THE OTHER PLANS.

IN SUMMARY, EPA RECOMMENDS THE EXTENSION OF MUNICIPAL WATER SERVICE TO THE AFFECTED AREA OF THE ODESSA CHROMIUM II SITE IS THE COST-EFFECTIVE REMEDY FOR THIS OPERABLE UNIT OF THE PROJECT. THE ESTIMATED TOTAL PRESENT VALUE COST IS $868,870 AND TIME OF IMPLEMENTATION IS 9-12 MONTHS.

#SCH SCHEDULE

THE SCHEDULE FOR THE DESIGN AND CONSTRUCTION OF THE ALTERNATE WATER SUPPLY AT THE ODESSA CHROMIUM II SITE IS CURRENTLY DEPENDENT UPON REAUTHORIZATION OF SUPERFUND. THE DESIGN PHASE OF THE PROJECT WILL BEGIN AS SOON AS FUNDING BECOMES AVAILABLE, EITHER THROUGH1 Order number 940620-113550-ROD -001-001 page 577 set 4 with 66 of 66 items

REAUTHORIZATION OR A CONTINUING RESOLUTION. WHEN FUNDING IS AVAILABLE, THE DESIGN AND CONSTRUCTION WILL TAKE APPROXIMATELY 12 MONTHS TO COMPLETE.

#TMA TABLES, MEMORANDA, ATTACHMENTS

ATTACHMENT A

TEXAS WATER COMMISSION

AUGUST 21, 1986

MR. DICK WHITTINGTON, P.E. REGIONAL ADMINISTRATOR U.S. ENVIRONMENTAL PROTECTION AGENCY REGION VI 1201 ELM STREET DALLAS, TEXAS 75270

ATTN: MR. PAUL SIEMINSKI

RE: ODESSA CHROMIUM I AND ODESSA CHROMIUM II SUPERFUND SITES

DEAR MR. WHITTINGTON:

THIS IS IN RESPONSE TO YOUR LETTER OF AUGUST 5, 1986 WHICH REQUESTS OUR COMMENTS AND/OR CONCURRENCE WITH REGARD TO THE PROPOSED REMEDY FOR PROVIDING AN ALTERNATIVE DRINKING WATER SUPPLY TO THE AFFECTED AREAS AT THE ODESSA CHROMIUM I AND II

SUPERFUND SITES. THE DRAFT SUMMARIES OF REMEDIAL ALTERNATIVES SELECTION RECOMMEND THAT CONNECTION WITH AN EXISTING MUNICIPAL WATER SUPPLY BE SELECTED AS THE COST EFFECTIVE ALTERNATIVE FOR THE TWO SITES. THIS ALTERNATIVE CONSISTS OF THE EXTENSION OF THE CITY OF ODESSA WATER LINES TO THE AFFECTED AREAS AND THE SUBSEQUENT SUPPLY OF WATER FROM THE CITY. A PUBLIC MEETING WAS HELD IN ODESSA ON AUGUST 13, 1986, TO DISCUSS THE VARIOUS METHODS OF PROVIDING AN ALTERNATIVE DRINKING WATER SUPPLY AND TO RECEIVE COMMENTS FROM THE PUBLIC.

THE TEXAS WATER COMMISSION HAS NO OBJECTION TO EPA'S SELECTION OF THE PROPOSED REMEDY FOR PROVIDING A POTABLE WATER SUPPLY TO THE AFFECTED AREAS AT THE TWO SITES.

IF YOU HAVE ANY QUESTIONS, PLEASE HAVE YOUR STAFF CONTACT GREG TIPPLE OF OUR SUPERFUND SECTION AT 512/463-7798.


SINCERELY,

LARRY R. SOWARD EXECUTIVE DIRECTOR.

#RS

ATTACHMENT B

COMMUNITY RELATIONS RESPONSIVENESS SUMMARY ON POTENTIAL REMEDY MODIFICATION ODESSA CHROMIUM I & II, TEXAS

THIS COMMUNITY RELATIONS RESPONSIVENESS SUMMARY IS DIVIDED INTO THE FOLLOWING SECTIONS:

I. OVERVIEW - THIS SECTION DISCUSSES EPA'S PREFERRED ALTERNATIVE FOR REMEDIAL ACTION, AND LIKELY PUBLIC REACTION TO THIS ALTERNATIVE.

II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS - THIS SECTION PROVIDES A BRIEF HISTORY OF COMMUNITY INTEREST AND CONCERNS RAISED DURING REMEDIAL PLANNING ACTIVITIES THROUGH A FEASIBILITY STUDY AT THE ODESSA CHROMIUM I & II SITES.

III. SUMMARY OF MAJOR COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND THE EPA RESPONSES TO THE COMMENTS.

IV. REMAINING CONCERNS - THIS SECTION DESCRIBES REMAINING COMMUNITY CONCERNS THAT EPA AND THE PRPS SHOULD BE AWARE OF IN CONDUCTING THE REMEDIAL DESIGN AND REMEDIAL ACTION AT THE ODESSA CHROMIUM

I & II SITES.

I. OVERVIEW

IN THE PRESENTATION FOR THE PUBLIC MEETING ON AUGUST 13, 1986, THE EPA DISCUSSED THE ALTERNATIVES DEVELOPED FOR IMPLEMENTATION OF A CORRECTIVE ACTION WHICH ADDRESSES AN ALTERNATE WATER SUPPLY FOR THE ODESSA CHROMIUM I & II SITES AND ADJACENT AND NEARBY RESIDENTIAL PROPERTIES.

BASED ON THE REMEDIAL INVESTIGATION AND THE ANALYSES PERFORMED IN THE FEASIBILITY STUDY, THE EPA PROPOSED TO EXTEND THE CITY OF ODESSA'S WATER SUPPLY SYSTEM TO AFFECTED HOUSEHOLDS. THIS ALTERNATIVE, IF IMPLEMENTED, WOULD PROVIDE NEGOTIATED AGREEMENTS BETWEEN THE CITY OF ODESSA AND CONSUMERS FOR EXTENDING THE CITY WATER SYSTEM TO CURRENT WELL USERS AND FOR THE CONSTRUCTION OF A WATER DISTRIBUTION SYSTEM. COMMENTS FROM LOCAL OFFICIALS AND RESIDENTS FAVORED THIS OPTION, PROVIDED THAT THE IMPACTED AREA1 Order number 940620-113550-ROD -001-001 page 579 set 4 with 66 of 66 items

WOULD NOT BE ANNEXED TO THE CITY OF ODESSA NOW OR IN THE FUTURE.

THE COMMENTS ON THE FOUR ALTERNATIVES, ALONG WITH EPA'S RESPONSE TO EACH, ARE PRESENTED LATER IN THIS DOCUMENT.

AT THIS TIME, THE EPA HAS PRESENTED THE FINDINGS OF THE ALTERNATE WATER SUPPLY STUDY ONLY. THE OVERALL STUDY ON THE GROUNDWATER CONTAMINATION AT THE ODESSA SITES, INCLUDING REMEDIAL ALTERNATIVES, WILL BE COMPLETED LATER THIS YEAR, WITH PUBLIC COMMENT TO FOLLOW.

II. MAJOR CONCERNS AND ISSUES

ODESSA CHROMIUM I

COMMUNITY INTEREST, HISTORICALLY AT A LOW LEVEL, IN THE ODESSA CHROMIUM I SITE, DATES BACK TO NOVEMBER 8, 1978, WHEN THE OWNER OF A DOMESTIC WATER WELL REGISTERED A COMPLAINT WITH THE TEXAS DEPARTMENT OF WATER RESOURCES (TDWR) - NOW KNOWN AS THE TEXAS WATER COMMISSION (TWC). THIS LOCAL RESIDENT COMPLAINED THAT THERE WERE ODORS AND AN "OILY" FILM PRESENT IN THE WATER COMING FROM HIS WELL. IN 1979, A WATER WELL AT ANOTHER PARTICULAR RESIDENCE WAS INVESTIGATED AND FOUND TO BE HEAVILY CONTAMINATED WITH CHROMIUM.

ODESSA CHROMIUM II

A LOW LEVEL OF COMMUNITY INTEREST HAS ALSO EXISTED HISTORICALLY AT THE ODESSA CHROMIUM II SITE. PUBLIC AWARENESS FIRST SURFACED IN 1977, WHEN THE TDWR INVESTIGATED THE AREA AND FOUND HEAVY METALS IN THREE LOCAL WATER WELLS.

SEVERAL LOCAL INDUSTRIES WERE SUSPECTED AS POSSIBLE SOURCES OF

CONTAMINATION. THESE INDUSTRIES GENERATED CHROMIUM-CONTAMINATED WASTEWATER AS A RESULT OF METAL PLATING ACTIVITIES AND CLEANING RADIATORS.

BOTH THE ODESSA CHROMIUM I & II SITES WERE ADDED TO THE NATIONAL PRIORITIES LIST IN OCTOBER 1984. BOTH SITES ARE LOCATED OUTSIDE THE CITY LIMITS OF THE CITY OF ODESSA IN ECTOR COUNTY, TEXAS. THE APPROXIMATE POPULATION OF THE CITY IS 135,000 RESIDENTS. THE TWO SITES ARE SURROUNDED BY A FEW SMALL INDUSTRIAL BUSINESSES, SINGLE FAMILY RESIDENCES, A MOTEL, A CHURCH, A SMALL CITY PARK, AND SEVERAL MOBILE HOME COMMUNITIES. APPROXIMATELY 550 - 600 RESIDENTS ARE AFFECTED BY THE TWO SITES. THESE RESIDENTS ARE NOT SERVED BY THE CITY OF ODESSA MUNICIPAL WATER SYSTEM. THE VAST MAJORITY ARE ON BOTTLED WATER, AND, WHILE THEY DO NOT PARTICULARLY OBJECT TO BEING PUT ON THE CITY OF ODESSA WATER SYSTEM, THEY STRONGLY OBJECT TO ANNEXATION BY THE CITY AND THE SUBSEQUENT ENCUMBRANCE OF CITY TAXES AND FEES.


ACTIVITIES TO ELICIT INPUT AND ADDRESS CONCERNS

AFTER PREPARATION AND SUBMITTAL OF A HAZARD RANKING PACKAGE FOR EACH SITE, THE TDWR INITIATED COMMUNICATIONS WITH THE CITY OF ODESSA, IN ORDER TO DETERMINE THE BEST MEANS AVAILABLE TO PROVIDE AN UNCONTAMINATED SUPPLY OF DRINKING WATER TO THE RESIDENTS IN THE ODESSA CHROMIUM I AREA.

ON APRIL 25, 1984, DISCUSSIONS WERE HELD IN ODESSA WITH AFFECTED RESIDENTS IN THE ODESSA CHROMIUM I AREA TO DETERMINE THEIR FEELINGS AND WISHES WITH REGARD TO ANNEXATION. THE OVERWHELMING SENTIMENT OF RESIDENTS PRESENT AT THIS MEETING WAS AGAINST ANNEXATION.

ON-SITE DISCUSSIONS WERE HELD CONCERNING ODESSA CHROMIUM II ON OCTOBER 9-10, 1984. DURING THESE DISCUSSIONS THE RESIDENTS EXPRESSED THE FOLLOWING CONCERNS:

1. LOCAL HEALTH OFFICIALS WERE CONCERNED THAT THERE WERE NOT ANY LEGAL STANDARDS FOR DISALLOWING HEAVY METALS IN DRINKING WATER.

2. THE SAME HEALTH OFFICIALS WONDERED IF SOME OF THE RESIDENTS NEAR THE SITE WERE UNKNOWINGLY DRINKING CONTAMINATED WATER FROM SMALL WELLS THAT HAD NOT BEEN TESTED.

3. ONE RESIDENT WAS CONCERNED THAT WATER USED BY BOTH A CHURCH� AND A SMALL CITY PARK NEAR THE SITE MIGHT BE CONTAMINATED

ON JANUARY 10, 1985, A PUBLIC MEETING WAS HELD CONCERNING ODESSA CHROMIUM II. PRIMARY CONCERNS AT THIS MEETING FOCUSED ON THE AVAILABILITY OF A POTABLE DRINKING WATER SUPPLY. AT THAT TIME,

SOME RESIDENTS WHO WERE PROVIDING THEIR OWN BOTTLED WATER BECAUSE OF CONTAMINATION IN THEIR RESIDENCE WELLS, WERE INTERESTED IN THE POSSIBILITY OF EPA PROVIDING A BOTTLED WATER SUPPLY AS AN EMERGENCY MEASURE UNTIL A MORE PERMANENT REMEDY COULD BE STUDIED AND DETERMINED. AT THIS MEETING, THERE WERE ADDITIONAL RESIDENTS WHO HAD CONTAMINATED WATER WELLS AND WERE NOT ON BOTTLED WATER WHO WANTED EPA TO PROVIDE WATER.

SUBSEQUENT TO COMPLETION OF THE FEASIBILITY STUDY FOR AN ALTERNATE WATER SUPPLY, THE EPA HELD A PUBLIC MEETING IN THE ODESSA CITY COUNCIL CHAMBERS ON AUGUST 13, 1986. DURING THE PUBLIC MEETING, THE ENVIRONMENTAL PROTECTION AGENCY SUMMARIZED AND EXPLAINED THE RESULTS OF ALL PREVIOUS INVESTIGATIONS, WITH PARTICULAR EMPHASIS ON RESULTS FROM THE ALTERNATE WATER SUPPLY FEASIBILITY STUDY. THE EPA DESCRIBED THE VARIOUS CORRECTIVE MEASURES BEING CONSIDERED BY THE AGENCY FOR THE RESIDENTS AFFECTED BY THE SITES, AND OUTLINED OPPORTUNITIES FOR PUBLIC INVOLVEMENT. THE EPA EXPLAINED THAT THE GOAL OF THE EPA AT BOTH THE ODESSA CHROMIUM I AND II1 Order number 940620-113550-ROD -001-001 page 581 set 4 with 66 of 66 items

SITES IS TO IMPLEMENT A CORRECTIVE ACTION WHICH ADDRESSES THE GROUNDWATER CONTAMINATION. THE PROCESS LEADING TO THE GROUNDWATER CLEANUP IS TIME-CONSUMING; THEREFORE, TO PROTECT PUBLIC HEALTH UNTIL COMPLETION OF THE ENTIRE REMEDY, EPA DECIDED TO EXPLORE ALTERNATE WATER SUPPLY OPTIONS FOR THOSE PEOPLE IN THE AREA WITH CONTAMINATED WELLS.

EPA DISCUSSED ITS PROPOSED ALTERNATIVE, EXTENSION OF ODESSA'S WATER SUPPLY SYSTEM TO IMPACTED PERSONS, AT THE AUGUST 13 MEETING AND RECEIVED COMMENTS CONCERNING THIS ALTERNATIVE AND THE OTHERS CONSIDERED IN THE FEASIBILITY STUDY. THE OVERWHELMING SENTIMENT OF RESIDENTS AT THE MEETING WAS THEIR OPPOSITION TO ANNEXATION BY THE CITY OF ODESSA.

III. SUMMARY OF PUBLIC COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD AND AGENCY RESPONSES.

THE PUBLIC COMMENT PERIOD ON THE FOCUSED FEASIBILITY STUDY FOR THE ODESSA CHROMIUM I AND II SUPERFUND SITES OPENED ON JULY 30 AND CLOSED ON AUGUST 27, 1986. A PUBLIC MEETING WAS HELD ON AUGUST 13, 1986, IN ODESSA, TEXAS WITH APPROXIMATELY 40 PEOPLE IN ATTENDANCE; 8 PEOPLE SPOKE. REPRESENTATIVES FOR THE PRPS AT EACH SITE AND 7 LOCAL RESIDENTS SUBMITTED WRITTEN COMMENTS DURING THE COMMENT PERIOD. A SUMMARY OF THESE COMMENTS IS PROVIDED BELOW.

COMMENT #1

ONE PERSON ASKED THAT THE PROPOSED WATER SUPPLY SYSTEM BE EXTENDED TO INCLUDE GOLDER AVENUE (400 FEET WEST OF CURRENT PROPOSAL). THE EXTENSION WAS REQUESTED DUE TO HIGH LEVELS OF SALT IN THE RESIDENT'S WELLS.

EPA RESPONSE TO COMMENT #1

TEXAS WATER COMMISSION SUGGESTED, DURING THE PUBLIC MEETING, THAT THE COMMENTOR CONTACT THE TEXAS RAILROAD COMMISSION AS THEY HAVE THE REGULATORY JURISDICTION OF PRODUCTS WHICH RESULT FROM THE PRODUCTION OF OIL AND NATURAL GAS SUCH AS SALT WATER (I.E. SODIUM CHLORIDE).

EPA CANNOT CONSIDER EXTENDING THE WATER SUPPLY TO THIS AREA BECAUSE THERE IS NO EVIDENCE THAT THE MATERIAL FOUND IN THE COMMENTOR'S WELL IS HAZARDOUS NOR IS THE LOCATION OF THE INDIVIDUAL'S WELL WITHIN THE ALTERNATE WATER SUPPLY BOUNDARY.

COMMENT #2

WHAT ACTIONS WILL EPA PURSUE AGAINST THE COMPANIES RESPONSIBLE FOR THE CONTAMINATION?



EPA PREFERS THAT PARTIES RESPONSIBLE FOR CONTAMINATION OF SITE PERFORM THE CLEANUP. POTENTIALLY RESPONSIBLE PARTIES (PRPS) HAVE BEEN IDENTIFIED AT THE ODESSA CHROMIUM I AND THE ODESSA CHROMIUM II SITES. THESE PARTIES HAVE BEEN NOTIFIED THAT THEY MAY UNDERTAKE, OR PARTICIPATE IN, THE CHOSEN REMEDY. IF THEY DECLINE INVOLVEMENT IN THE REMEDIAL ACTION, EPA WILL PROCEED WITH THE IMPLEMENTATION OF THE REMEDY AND PURSUE APPROPRIATE ENFORCEMENT ACTION INCLUDING COST RECOVERY.

COMMENT #3

TWO WELLS LOCATED AT 5329 ANDREW HIGHWAY (ODESSA CHROMIUM II) SHOULD BE PLUGGED TO LIMIT THE VERTICAL MOVEMENT OF CONTAMINATION THROUGH THE WELL.


THE AGENCY WILL SOON COMPLETE AN OVERALL STUDY OF THE SITES TO EVALUATE ALTERNATIVES FOR REMEDIATING THE CHROMIUM CONTAMINATED GROUNDWATER. AFTER COMPLETION OF THIS STUDY, THE AGENCY MAY RECOMMEND PLUGGING OF THESE WELLS AS PART OF THE REMEDIAL ACTION TO BE TAKEN AT THE SITE. IN THE MEANTIME, THERE SHOULD NOT BE SIGNIFICANT ADDITIONAL ADVERSE EFFECTS ON THE QUALITY OF THE TRINITY AQUIFER FROM THESE WELLS. IN ADDITION, THE UNPLUGGED WELLS MAY BE OF FURTHER VALUE TO EPA IN DOCUMENTING THE NATURE OF THE INTERCONNECTION BETWEEN THE PERCHED AND REGIONAL AQUIFER.

COMMENT #4

THE CONCERN AT BOTH ODESSA CHROMIUM I AND II APPEARS ONLY TO BE

WITH THE POTABLE WATER. WHY THEN ARE THE PROPOSED ALTERNATIVES DESIGNED TO MEET THE TOTAL ANNUAL USAGE OF WATER WITHIN THE TWO AREAS?


THE AGENCY'S PRIMARY GOAL IS TO SUPPLY POTABLE WATER. EXTENDING THE CITY WATER LINES (WHICH IS THE MOST EFFECTIVE REMEDY) ALSO ALLOWS THESE RESIDENTS IMPACTED BY CHROMIUM CONTAMINATION THE OPPORTUNITY TO USE IT FOR THEIR TOTAL NEEDS. THE SECONDARY GOAL IS TO REDUCE THE RATE OF PLUME MIGRATION AND PREVENT OTHER AREAS FROM BECOMING CONTAMINATED.

COMMENT #5

THE COMMENTOR STATED THEIR CONCERNS REGARDING THE POSSIBLE HEALTH HAZARDS DUE TO CHROMIUM CONSUMPTION.



THE CENTER FOR DISEASE CONTROL HAS DETERMINED THROUGH STUDIES, THAT IN THE OCCUPATIONAL SETTING CHROMIUM DUST HAS BEEN FOUND TO BE A CARCINOGEN WHEN INHALED. HEALTH EFFECTS FROM CHROMIUM IN WATER SUPPLIES WERE EXTRAPOLATED FROM INFORMATION OBTAINED FROM THE OCCUPATIONAL STUDIES, AND FROM ANIMAL STUDIES WHERE THE ANIMALS WERE INDUCED WITH WATER CONTAINING ELEVATED LEVELS OF CHROMIUM. FROM THESE STUDIES THERE APPEARS TO BE INCREASED BODY BURDENS (I.E. LIVER, KIDNEY) FROM DRINKING CHROMIUM CONTAMINATED WATER. HOWEVER, THE STUDIES HAVE NOT CONFIRMED THAT CHROMIUM IS A CARCINOGEN WHEN INGESTED.

COMMENT #6

SINCE THE MAJORITY OF THE LOCAL RESIDENTS HAVE FOUND OTHER WAYS OF OBTAINING POTABLE WATER (I.E. BOTTLED WATER), WHY WOULD THIS CURRENT ARRANGEMENT NOT CONTINUE TO BE SATISFACTORY?


THE AGENCY DOES NOT KNOW EXACTLY WHAT PERCENTAGE OF HOUSEHOLDS ARE DRINKING BOTTLED WATER. AS LONG AS WELLS PROVIDE POTABLE WATER TO THE TAPS OF INDIVIDUAL HOUSEHOLDS, THERE IS AN UNACCEPTABLE RISK THAT PEOPLE WILL DRINK CONTAMINATED WATER.

SUPPLYING BOTTLED WATER, OVER A 15 YEAR DESIGN LIFE, WOULD BE LABOR AND COST INTENSIVE; THEREFORE, WAS NOT CONSIDERED A VIABLE ALTERNATIVE.

COMMENT #7

WILL THE PROPOSED ACTION BE THE FINAL CLEANUP AT THE SITE, IF NOT HOW IS THIS REMEDY CONSISTENT WITH A FINAL REMEDY?


THE CLEANUP OF CONTAMINATED GROUNDWATER PLUMES IS SO TIME-CONSUMING (10-15 YEARS) THAT A NEED FOR ALTERNATIVE WATER SUPPLY IS OFTEN REQUIRED TO PROTECT PUBLIC HEALTH AND WELFARE UNTIL THE COMPLETION OF THE REMEDY. THE EXTENSION OF THE MUNICIPAL WATER SUPPLY THROUGH THE IMPACTED AREAS OF ODESSA CHROMIUM I AND II IS NOT THE FINAL REMEDY AND WILL BECOME PART OF A MORE COMPREHENSIVE REMEDY AT A LATER DATE. A FINAL REMEDY WILL BE PROPOSED FOLLOWING THE COMPLETION OF THE FEASIBILITY STUDY (40 CFR 300.68 (I)(3)).

COMMENT #8

OBJECTIONS WERE RAISED TO THE PROVIDING ALTERNATE WATER TO COMMERCIAL FACILITIES WITHIN ODESSA CHROMIUM I STUDY AREA.1 Order number 940620-113550-ROD -001-001 page 584 set 4 with 66 of 66 items


THE ODESSA CHROMIUM I STUDY AREA IS COMPOSED OF 44 LOTS OF WHICH 23 ARE RESIDENTIAL AND 21 ARE BUSINESSES. THE MUNICIPAL WATER SYSTEM WILL BE EXTENDED THROUGHOUT THE IMPACTED AREA; HOWEVER, COMMERCIAL FACILITIES WILL NOT BE GIVEN THE OPPORTUNITY TO CONNECT WITH THE SYSTEM.

COMMENT #9

EPA SHOULD CONDUCT A DETAILED REVIEW OF THE REMOVAL OF CONTAMINANTS BY INDIVIDUAL ION EXCHANGE UNITS.


SUCH A REVIEW WAS CONSIDERED IN THE ALTERNATE WATER SUPPLY FEASIBILITY STUDY AND IT WAS FOUND TO BE COSTLY AND UNRELIABLE WHEN COMPARED WITH EXTENDING THE CITY'S WATER LINES.

COMMENT #10

WHY IS THE EPA PROPOSING TO USE EIGHT INCH WATER MAINS WHEN A SYSTEM OF THREE INCH MAINS WOULD MEET THE AREA'S NEEDS AT A SIGNIFICANT COST SAVINGS?


ALL PLANS AND SPECIFICATIONS FOR EXTENSION OF CITY WATER WOULD BE ESTABLISHED IN ACCORDANCE WITH THE CITY OF ODESSA STANDARDS AND REQUIREMENTS FOR STREET, ALLEY, WATER, SEWER AND DRAINAGE IMPROVEMENTS. THESE REGULATIONS BASICALLY SET FORTH POLICY AND

MINIMUM STANDARDS FOR ACCEPTABLE MATERIALS AND A MINIMUM STANDARD OF WORKMANSHIP FOR THE CONSTRUCTION OF WATER MAINS THAT ARE TO BE CONNECTED TO THE CITY OF ODESSA SYSTEM. FURTHER, TO INSURE THE INTEGRITY OF THE CITY OF ODESSA SYSTEM, STRICT COMPLIANCE WITH THE CITY'S PLUMBING CODE MUST BE MAINTAINED IN ALL CONNECTION AND ADHERENCE TO THE REGULATION REGARDING CROSS CONNECTIONS WILL BE REQUIRED. THE CITY WILL ASSUME ALL OPERATION AND MAINTENANCE COST ASSOCIATED WITH THE SYSTEM; THEREFORE, THE SPECIFICATIONS FOR THE ALTERNATIVE MUST FOLLOW EITHER CURRENTLY ACCEPTED CITY STANDARDS OR DEVELOPED THROUGH SUCCESSFUL NEGOTIATIONS WITH THE CITY COUNCIL.

COMMENT #11

NUMEROUS PEOPLE, WHILE IN FAVOR OF THE EXTENSION ON THE MUNICIPAL WATER SUPPLY, WERE CONCERNED ABOUT THE POSSIBILITY OF ANNEXATION.



THE CITY OF ODESSA MAINTAINS A POLICY OF NON SERVICE OF WATER OUTSIDE THE CORPORATE CITY LIMITS. AS A PART OF THIS STUDY, THE CITY COUNCIL OF THE CITY OF ODESSA WAS REQUESTED TO ADOPT A RESOLUTION INDICATING WILLINGNESS TO CONSIDER THE SPECIAL EXTENSION OF CITY WATER INTO THE ODESSA CHROMIUM I AND II SITES TO IMPROVE THE HEALTH, WELFARE, AND SAFETY OF CITIZENS IN THE AREAS CONTAMINATED WITH CHROMIUM. THE CITY PASSED SUCH A RESOLUTION ON MARCH 25, 1986.

IN RECENT YEARS, ANNEXATION BY THE CITY OF ODESSA HAS BEEN ON A VOLUNTARY BASIS ONLY. THE CONSTRUCTION OF THE DISTRIBUTION SYSTEM MAKES THE IMPACTED AREA NO MORE OR LESS SUBJECT TO ANNEXATION.

COMMENT #12

WHAT IS THE BASIS FOR THE PROPOSED CHROMIUM ACTION LEVEL?


THE FEDERALLY REGULATED PRIMARY DRINKING WATER STANDARD FOR CHROMIUM WAS SET AT .05 PPM IN 1977 BASED ON HEALTH EFFECT STUDIES. THAT REQUIREMENT IS USED AS THE BASIS FOR THE TARGET CONCENTRATION.

IV. REMAINING PUBLIC CONCERNS

THE RESIDENTS STRONGLY OBJECT TO ANNEXATION BY THE CITY OF ODESSA AND THE SUBSEQUENT ENCUMBRANCE OF CITY TAXES AND FEES.

TABLE 2-3

TOTAL CHROMIUM VALUES GT 0.05 MG/L (MCL)

REPORTED FOR EXISTING WATER SUPPLY WELLS SAMPLED DURING RI FOCUSED FEASIBILITY STUDY ODESSA CHROMIUM II SITE ODESSA, TEXAS

TOTAL CHROMIUM VALUE WELL NO USE (MG/L) NOTE(S)

E2070 (1) COMMERCIAL 0.07,0.50 -

E2178 COMMERCIAL 0.08,0.11,0.06 -

E2224 RESIDENTIAL 0.01 (2),0.05 -

E2226 TRAILER PARK 0.18,0.16 -


E2254 RESIDENTIAL 0.07,0.05 -



E2260 RESIDENTIAL 0.21,0.01 (2) -

E2261 RESIDENTIAL 0.01 (2),0.85 -

E2264 COMMERCIAL/ 0.10,0.10 - RESIDENTIAL

E2267 COMMERCIAL 3.3,3.2 ABANDONED

E2270 MOTEL 0.8,0.14,0.17 -

E2270A MOTEL 0.15,0.09 -

(1) SEE FIGURE 2-8 FOR WELL LOCATIONS (2) VALUE BELOW DRINKING WATER STANDARD OF 0.05 MG/L

SUMMARY STATISTICS: GT 0.05 MG/L N=26, X=0.48, SD = 0.88 RANGE = 0.05-3.3 MG/L GT 0.12 MG/L N=13, X=0.88, SD = 1.1 RANGE = 0.12-3.3 MG/L.

TABLE 6-1 COST COMPARISON OF ALTERNATIVES FOCUSED FEASIBILITY STUDY ODESSA CHROMIUM II SITE ODESSA, TEXAS

O&M PRESENT ALTERNATIVE CAPITAL COSTS O&M (1) VALUE (2) NET PV (3)

II SURFACE WATER $ 675,725 $158,950 $1,209,000 $1,884,725

IIA COMBINED SURFACE WATER 661,675 114,400 870,150 1,231,825

V ION EXCHANGE 1,471,885 360,700 2,743,500 4,215,385

VI NEW WELL FIELD 3,770,340 155,000 1,178,950 4,949,290

VIA COMBINED NEW WELL FIELD 3,676,800 119,850 911,600 4,588,400

VII MUNICIPAL WATER 476,570 51,575 (4) 392,300 868,8701 Order number 940620-113550-ROD -001-001 page 587 set 4 with 66 of 66 items

NOTES: (1) O&M = OPERATIONS AND MAINTENANCE (2) PRESENT VALUE, BASED ON 15 YEARS, 10% DISCOUNT RATE AND 0% INFLATION, FOR O&M (3) NET PV IS TOTAL OF CAPITAL COSTS AND PRESENT VALUE OF O&M (4) O&M COSTS ASSUMED EQUAL TO THE ANNUAL TOTAL OF MONTHLY WATER BILLS PAID BY PROPERTY OWNERS IN THE IMPACTED AREA.

TABLE 6-2 COST PER THOUSAND GALLON COMPARISON OF ALTERNATIVES FOCUSED FEASIBILITY STUDY ODESSA CHROMIUM II SITE ODESSA, TEXAS

AVERAGE RESIDENTIAL MONTHLY ALTERNATIVE COST ($)/THOUSAND GALLONS (1) WATER BILL (2)

II SURFACE WATER 7.19 107.81

IIA COMBINED 6.54 (3) 98.13 SURFACE WATER

V ION EXCHANGE 16.31 244.65

VI NEW WELL FIELD 7.01 105.13

VIA COMBINED 6.44 (3) 96.67 NEW WELL FIELD

VII MUNICIPAL WATER 7.70/1.35 (4) 37.88

NOTE: (1) COSTS ARE ANNUAL O&M COSTS AND ANNUAL WATER CONSUMPTION IN THOUSANDS OF GALLONS (2) BASED ON FIFTEEN THOUSAND GALLONS (3) BASED ON COMBINING WATER CONSUMPTION FOR BOTH ODESSA I AND ODESSA II AND O&M COSTS FOR ODESSA I AND ODESSA II SINCE RESIDENTS WOULD BE PART OF THE SAME WATER ASSOCIATION (4) FOR FIRST TWO THOUSAND GALLONS, $7.70 AND $1.35 PER THOUSAND GALLONS OF REMAINING PORTION, PLUS A 50% SURCHARGE.�

ODESSA CHROMIUM #2 (ANDREWS HIGHWAY)

Site Information:

Site Name: ODESSA CHROMIUM #2 (ANDREWS HIGHWAY)Address: ODESSA, TX

EPA ID: TXD980697114EPA Region: 06

Record of Decision (ROD):

ROD Date: 03/18/1988Operable Unit: 02ROD ID: EPA/ROD/R06-88/027 Media: GROUNDWATER

Contaminant: CHROMIUM

Abstract: THE ODESSA CHROMIUM II SITE CONSISTS OF A SERIES OF

CHROMIUM-CONTAMINATED WELLS WITHIN 200 ACRESOF RESIDENTIAL, COMMERCIAL, AND INDUSTRIALPROPERTIES AND FACILITIES JUST OUTSIDE THENORTHWESTERN CITY LIMITS OF ODESSA, ECTORCOUNTY, TEXAS. NEARLY EVERY RESIDENCE ORCOMMERCIAL FACILITY IS SERVED BY ONE OR MOREWATER WELLS COMPLETED IN THE UNDERLYINGTRINITY AQUIFER, WHICH OFFERS THE ONLY SOURCE OFPOTABLE GROUND WATER. TWO SEPARATECONTAMINANT PLUMES ARE BOUNDED BY THE SITE; 5329ANDREWS HIGHWAY, AND 57TH STREET AND ANDREWSHIGHWAY. IN 1970, LOCAL HEALTH DEPARTMENTAUTHORITIES INVESTIGATED A COMPLAINT OFCONTAMINATED (5.5 MG/L CHROMIUM) WELL WATER ONTHE PROPERTY TO THE SOUTH OF 5329 ANDREWSHIGHWAY. AT THAT TIME, WASTEWATER ANALYSIS DIDNOT INDICATE THE PRESENCE OF CHROMIUM DESPITETHE PRESENCE IN 1978 OF A CLEANING VAT SOLUTION,STORED IN PARTIALLY BURIED STEEL TANKS, WHICHCONTAINED 2.8 MG/L OF CHROMIUM. ONE OF THESTORAGE TANKS WAS DISCOVERED LEAKING AND THETANKS WERE SUBSEQUENTLY REMOVED. THE FACILITYAT 57TH STREET AND ANDREWS HIGHWAY HAS BEEN IN

OPERATION SINCE ABOUT 1950. CHROMATES WEREUTILIZED IN THE COOLING SYSTEM UNTIL ABOUT 1976.THIS SYSTEM WAS APPARENTLY TIED INTO ONE OF THEPLANT'S WATER WELLS AND DURING OCCASIONAL SLOWDOWNS, COOLING WATER COULD HAVE BEENINADVERTENTLY BACK FLUSHED INTO THE WELL SINCETHERE WAS NO CHECK VALVE. THE PLANT ALSOUTILIZED AN UNLINED PIT FOR THE DISPOSAL OFCONTAMINATED WASTEWATER, INCLUDING CHROMATEWASTES FROM THE COOLING WATER SYSTEM, UNTILABOUT 1977. THE FIRST OPERABLE UNIT, SIGNED INSEPTEMBER 1986, PROVIDED FOR THE EXTENSION OF THECITY'S WATER SUPPLY UNTIL FINAL GROUND WATERREMEDIATION IS COMPLETE. ALTHOUGH CHROMIUM ISTHE PRIMARY CONTAMINANT OF CONCERN TO THEGROUND WATER, OTHER INORGANICS HAVE BEENFOUND IN THE SOIL.

THE SELECTED REMEDIAL ACTION FOR THIS SITEINCLUDES; GROUND WATER PUMP AND TREATMENTUSING ELECTROCHEMICAL TECHNIQUES WITHREINJECTION INTO THE TRINITY AQUIFER; AND GROUNDWATER MONITORING. A TREATABILITY STUDY WILL BECONDUCTED DURING THE SYSTEM DESIGN PHASE OF THEPROJECT TO AID IN DESIGNING AN APPROPRIATETREATMENT SYSTEM. THE ESTIMATED PRESENT WORTHCOST FOR THIS REMEDIAL ACTION IS $3,618,000.

Remedy: THIS RECORD OF DECISION FOR THE ODESSA CHROMIUM

II SITE REQUIRES THE FOLLOWING ACTIONS TO ADDRESSTHE CHROMIUM-CONTAMINATED GROUNDWATER;- EXTRACTION OF CHROMIUM-CONTAMINATEDGROUNDWATER FROM A PERCHED WATER-BEARINGZONE AND THE TRINITY AQUIFER;- ELECTROCHEMICAL TREATMENT OF GROUNDWATERWHICH EXCEEDS THE PRIMARY DRINKING WATERSTANDARD FOR CHROMIUM;- REINJECTION OF TREATED GROUNDWATER INTO THETRINITY AQUIFER;- MONITOR SITE FOR A MINIMUM OF 30 YEARS.

Text: Full-text ROD document follows on next page.

Text:

- RESIDENTS IN TRAILERS AND HOMES UTILIZING CONTAMINATED GROUNDWATER,

- EMPLOYEES OF BUSINESSES UTILIZING CONTAMINATED GROUNDWATER, AND

- WORKERS OR TRESPASSERS AT THE 5329 ANDREWS HIGHWAY.

IN ORDER TO EVALUATE WHAT ENDANGERMENT, IF ANY, IS CURRENTLY CREATED BY THE SITE, CHROMIUM LEVELS WERE COMPARED WITH EXISTING STANDARDS OR1 Order number 940620-113550-ROD -001-001 page 1109 set 4 with 66 of 66 items

RISK ESTIMATES WERE DEVELOPED FOR POTENTIAL EXPOSURE SCENARIOS WHICH HAVE NO HEALTH BASED STANDARDS. IF A STANDARD EXISTS, THE CHROMIUM LEVEL WAS COMPARED WITH THE STANDARD IN ORDER TO DETERMINE WHETHER A REMEDIAL RESPONSE ACTION IS NECESSARY TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT. IF NO APPLICABLE OR RELEVANT AND APPROPRIATE STANDARD EXISTS, A TARGET CONCENTRATION OR CLEANUP LEVEL WAS DEVELOPED WHICH WOULD ATTAIN A 10-6 (ONE IN ONE MILLION) TO 10-5 (TEN IN ONE MILLION) LIFETIME CANCER RISK LEVEL.

SINCE CHROMIUM HAS AN APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENT FOR GROUNDWATER, THE EPA PRIMARY DRINKING WATER STANDARD, THAT REQUIREMENT WAS USED AS THE BASIS FOR THE TARGET CONCENTRATION. WELLS WITH VALUES ABOVE THE DRINKING WATER STANDARD ARE NOT SUITABLE FOR USE AS A LIFETIME DRINKING WATER SUPPLY. THE CURRENT DRINKING WATER STANDARD OF .05 MG/L CHROMIUM IS EXCEEDED BY NUMEROUS WELLS THROUGHOUT THE SITE. THIS STANDARD IS UNDER REVIEW AND MAY BE REVISED. SHOULD THE STANDARD BE REVISED PRIOR TO THE INITIATION OF THE DESIGN OF THE SELECTED TREATMENT REMEDY, THE REVISED STANDARD WILL BECOME THE APPROPRIATE LEVEL OF REMEDIATION.

NEITHER INGESTION OF CONTAMINATED SOILS NOR INHALATION OF CONTAMINATED DUST PARTICLES POSE A SIGNIFICANT THREAT TO HUMAN HEALTH. INGESTION OF THE CHROMIUM PRESENT IN THE SOIL IS 0.35% OF THE ORAL CHRONIC ACCEPTABILITY DAILY INTAKE FOR CHROMIUM. THE RISK ASSOCIATED WITH THE INHALATION OF DUST PARTICLES FROM THE SITE APPROACHES A 10-6 (ONE IN ONE MILLION) RISK LEVEL; THEREFORE, SOIL REMEDIATION IS NOT CONSIDERED NECESSARY.

RESULTS OF THE ASSESSMENT INDICATE THAT REMEDIAL ACTION IS REQUIRED TO REDUCE THE POTENTIAL FOR PUBLIC HEALTH EXPOSURE THROUGH THE CONSUMPTION OF CONTAMINATED GROUNDWATER ONLY. THE AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY (ATSDR) HAS SUPPORTED THIS INTERPRETATION OF THE RISK ASSESSMENT (ATTACHMENT B).

#ENF

II. ENFORCEMENT

THE GOAL OF THE EPA IS TO HAVE THOSE PARTIES RESPONSIBLE FOR CONTAMINATION OF THE SITE PERFORM THE CLEANUP. THE AGENCY HAS IDENTIFIED SEVERAL POTENTIALLY RESPONSIBLE PARTIES AT THE ODESSA CHROMIUM II SITE. THESE PARTIES HAVE BEEN NOTIFIED THAT THEY MAY UNDERTAKE, OR PARTICIPATE IN, THE CHOSEN REMEDY. IF THEY DECLINE INVOLVEMENT IN THE REMEDIAL ACTION, EPA WILL PURSUE APPROPRIATE ENFORCEMENT ACTION.

#CR III. COMMUNITY RELATIONS HISTORY


SEE ATTACHMENT C.

#AE IV. ALTERNATIVES EVALUATION

EVALUATION CRITERIA

SECTION 121(A) THROUGH (F) OF THE SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT CONTAINS FACTORS WHICH EPA MUST CONSIDER IN SELECTING A REMEDY FOR A SUPERFUND SITE. THESE FACTORS, AS WELL AS OTHER CRITERIA USED DURING THE EVALUATION OF ALTERNATIVES, ARE DISCUSSED BELOW:

1. CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS (ARARS)

IN DETERMINING APPROPRIATE REMEDIAL ACTIONS AT SUPERFUND SITES, CONSIDERATION MUST BE GIVEN TO THE REQUIREMENTS OF OTHER FEDERAL AND STATE ENVIRONMENTAL LAWS. PRIMARY CONSIDERATION IS GIVEN TO ATTAINING APPLICABLE OR RELEVANT AND APPROPRIATE FEDERAL AND STATE PUBLIC HEALTH AND ENVIRONMENTAL REGULATIONS AND STANDARDS. REQUIREMENTS UNDER FEDERAL AND STATE LAWS THAT SPECIFICALLY ADDRESS THE CIRCUMSTANCE AT A SUPERFUND SITE ARE CONSIDERED APPLICABLE. RELEVANT AND APPROPRIATE REQUIREMENTS, WHILE NOT APPLICABLE TO A SUPERFUND SITE, ADDRESS SITUATIONS WHICH ARE SUFFICIENTLY SIMILAR TO A SITE. THE COMPLIANCE OF EACH REMEDIAL ACTION WITH ENVIRONMENTAL LAWS IS PROVIDED IN TABLE 3.

2. REDUCTION OF TOXICITY, MOBILITY OR VOLUME

THE DEGREE TO WHICH ALTERNATIVES EMPLOY TREATMENT THAT REDUCES TOXICITY, MOBILITY, OR VOLUME MUST ALSO BE ASSESSED. RELEVANT FACTORS ARE:

- THE TREATMENT PROCESSES THE REMEDIES EMPLOY AND MATERIALS TO BE TREATED.

- THE AMOUNT OF HAZARDOUS MATERIALS THAT WILL BE DESTROYED OR TREATED;

- THE DEGREE OF EXPECTED REDUCTION IN TOXICITY, MOBILITY, OR VOLUME;

- THE DEGREE TO WHICH THE TREATMENT IS IRREVERSIBLE;

- THE RESIDUALS THAT WILL REMAIN FOLLOWING TREATMENT, CONSIDERING THE PERSISTENCE, TOXICITY, MOBILITY, AND PROPENSITY FOR BIOACCUMULATION OF SUCH HAZARDOUS SUBSTANCES1 Order number 940620-113550-ROD -001-001 page 1111 set 4 with 66 of 66 items

AND THEIR CONSTITUENTS.

EPA IS ALSO DIRECTED BY SARA TO GIVE PREFERENCE TO REMEDIAL ACTIONS THAT UTILIZE TREATMENT TO REMOVE CONTAMINANTS FROM THE ENVIRONMENT. OFF-SITE TRANSPORT AND DISPOSAL WITHOUT TREATMENT IS THE LEAST PREFERRED OPTION WHERE PRACTICABLE TREATMENT TECHNOLOGIES ARE AVAILABLE.

3. SHORT-TERM EFFECTIVENESS

THE SHORT-TERM EFFECTIVENESS OF ALTERNATIVES MUST BE ASSESSED; CONSIDERING APPROPRIATE FACTORS AMONG THE FOLLOWING:

- MAGNITUDE OF REDUCTION OF EXISTING RISKS;

- SHORT TERM RISKS THAT MIGHT BE POSED TO THE COMMUNITY, WORKERS, OR THE ENVIRONMENT DURING IMPLEMENTATION OF AN ALTERNATIVE INCLUDING POTENTIAL THREATS TO HUMAN HEALTH AND THE ENVIRONMENT ASSOCIATED WITH TRANSPORTATION, AND REDISPOSAL OR CONTAINMENT OF TREATMENT RESIDUALS;

- TIME UNTIL FULL PROTECTION IS ACHIEVED.

4. LONG-TERM EFFECTIVENESS AND PERMANENCE

ALTERNATIVES ARE ASSESSED FOR THE LONG-TERM EFFECTIVENESS AND PERMANENCE THEY AFFORD ALONG WITH THE DEGREE OF CERTAINTY THAT THE REMEDY WILL PROVE SUCCESSFUL. FACTORS CONSIDERED ARE:

- MAGNITUDE OF RESIDUAL RISKS IN TERMS OF AMOUNTS AND CONCENTRATIONS OF WASTE REMAINING FOLLOWING IMPLEMENTATION OF A REMEDIAL ACTION, CONSIDERING THE PERSISTENCE, TOXICITY, MOBILITY, AND PROPENSITY TO BIOACCUMULATE OF SUCH HAZARDOUS SUBSTANCES AND THEIR CONSTITUENTS;

- TYPE AND DEGREE OF LONG-TERM MANAGEMENT REQUIRED, INCLUDING MONITORING AND OPERATION AND MAINTENANCE;

- LONG-TERM RELIABILITY OF THE ENGINEERING AND INSTITUTIONAL CONTROLS, INCLUDING UNCERTAINTIES ASSOCIATED WITH LAND DISPOSAL OF UNTREATED WASTES AND RESIDUALS;

- POTENTIAL NEED FOR REPLACEMENT OF THE REMEDY.

5. IMPLEMENTABILITY

THE EASE OR DIFFICULTY OF IMPLEMENTING THE ALTERNATIVES ARE ASSESSED BY CONSIDERING THE FOLLOWING TYPES OF FACTORS:1 Order number 940620-113550-ROD -001-001 page 1112 set 4 with 66 of 66 items

- DEGREE OF DIFFICULTY ASSOCIATED WITH CONSTRUCTING THE TECHNOLOGY;

- EXPECTED OPERATIONAL RELIABILITY OF THE TECHNOLOGIES;

- NEED TO COORDINATE WITH AND OBTAIN NECESSARY APPROVALS AND PERMITS FROM OTHER OFFICES AND AGENCIES;

- AVAILABILITY OF NECESSARY EQUIPMENT AND SPECIALISTS;

- AVAILABLE CAPACITY AND LOCATION OF NEEDED TREATMENT, STORAGE, AND DISPOSAL SERVICES.

6. COST

THE TYPES OF COSTS THAT SHOULD BE ASSESSED INCLUDE THE FOLLOWING:

- CAPITAL COST;

- OPERATIONAL AND MAINTENANCE COSTS;

- NET PRESENT VALUE OF CAPITAL AND O&M COSTS;

- POTENTIAL FUTURE REMEDIAL ACTION COSTS.

7. COMMUNITY ACCEPTANCE

THIS ASSESSMENT SHOULD LOOK AT:

- COMPONENTS OF THE ALTERNATIVES WHICH THE COMMUNITY SUPPORTS;

- FEATURES OF THE ALTERNATIVES ABOUT WHICH THE COMMUNITY HAS RESERVATIONS;

- ELEMENTS OF THE ALTERNATIVES WHICH THE COMMUNITY STRONGLY OPPOSES.

8. STATE ACCEPTANCE

EVALUATION FACTORS INCLUDE ASSESSMENTS OF:

- COMPONENTS OF THE ALTERNATIVES WHICH THE STATE SUPPORTS;

- FEATURES OF THE ALTERNATIVES ABOUT WHICH THE STATE HAS RESERVATIONS;

- ELEMENTS OF THE ALTERNATIVES UNDER CONSIDERATION THAT THE1 Order number 940620-113550-ROD -001-001 page 1113 set 4 with 66 of 66 items

STATE STRONGLY OPPOSES.

9. OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

FOLLOWING THE ANALYSIS OF THE REMEDIAL OPTIONS AGAINST INDIVIDUAL EVALUATION CRITERIA, THE ALTERNATIVES ARE ASSESSED FROM THE STANDPOINT OF WHETHER THEY PROVIDE ADEQUATE PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT CONSIDERING THE MULTIPLE CRITERIA.

DESCRIPTION OF ALTERNATIVES

IN CONFORMANCE WITH THE NATIONAL CONTINGENCY PLAN, INITIAL REMEDIAL APPROACHES WERE SCREENED TO DETERMINE WHICH MIGHT BE APPROPRIATE FOR THIS SITE. (SEE THE FEASIBILITY STUDY FOR DETAILS OF THIS EVALUATION). FROM THESE POSSIBLE REMEDIES, SIX ALTERNATIVES WERE CHOSEN FOR MORE DETAILED EVALUATION AND COMPARISON WITH THE REMEDY SELECTION CRITERIA OUTLINED ABOVE. EACH IS SUMMARIZED BELOW:

ALTERNATIVE 1, NO ACTION - THIS REMEDY INVOLVES PRIMARILY THE PLUGGING OF SEVERAL MONITOR WELLS USED DURING THE REMEDIAL INVESTIGATION. NINE EXISTING WELLS AND FIVE NEW WELLS WILL BE UTILIZED FOR AN ANNUAL MONITORING PROGRAM. THIS ALTERNATIVE DOES NOT PREVENT FUTURE MIGRATION OF CHROMIUM AND DOES NOT CLEAN UP THE EXISTING CONTAMINATION. IN ORDER TO PREVENT POTENTIAL EXPOSURE THROUGH FUTURE CONSUMPTION OF CONTAMINATED GROUNDWATER, THE ALTERNATIVE WATER SUPPLY SYSTEM WOULD REQUIRE CONTINUED EXTENSION AS THE PLUME MIGRATED BEYOND THE PRESENT SITE BOUNDARY. THE ASSOCIATED PRESENT WORTH COST ($294,000) OF THIS ALTERNATIVE IS FOR CONSTRUCTING NEW WELLS AND AN ANNUAL MONITORING PROGRAM.

ALTERNATIVE 2, CONTAINMENT WALL - THIS ALTERNATIVE IS COMPRISED OF INSTALLING OVERLAPPING 2-3 FOOT THICK GROUT COLUMNS WITHIN THE TRINITY AQUIFER. THE COLUMNS WILL BE SPACED 3 FEET APART AND EXTENDED TO THE CLAY LAYER UNDERLYING THE CONTAMINATED ZONE THUS CREATING A BARRIER WALL AROUND THE CONTAMINATED GROUNDWATER. THE

BARRIER WOULD LIMIT THE MIGRATION OF THE PLUME. IN ADDITION, THIRTEEN OF THE WELLS INSTALLED DURING THE REMEDIAL INVESTIGATION WILL BE PLUGGED.

ALTHOUGH THE CONTAINMENT WALL WOULD BE LOCATED IN AREAS WHICH WOULD MINIMIZE THE DISRUPTION OF PAVED STREETS AND PROPERTY, THE ENTIRE PLUME WHICH EXCEED 0.05 MG/L TOTAL CHROMIUM WOULD BE EFFECTIVELY CONTAINED BY THE 3 FOOT THICK WALL. THE LENGTH OF THE BARRIER WALL WILL BE APPROXIMATELY 8,600 FEET. RECOVERY WELLS WOULD BE INSTALLED TO REMOVE WATER FROM THE INTERIOR OF THE CONTAINMENT WALL SO THAT THE INTERIOR WATER LEVEL IS LOWER THAN THE SURROUNDING AQUIFER. THE INWARD GRADIENT WOULD REDUCE THE POTENTIAL FOR CONTAMINANTS TO MIGRATE BEYOND THE WALL. CONSTRUCTION IS EXPECTED TO LAST 6 YEARS IN ORDER TO COMPLETE THE CONTAINMENT WALL. THE ESTIMATED PRESENT WORTH1 Order number 940620-113550-ROD -001-001 page 1114 set 4 with 66 of 66 items

COST FOR THIS ALTERNATIVE IS $39,971,000, INCLUDING 30 YEARS OF MONITORING.

ALL FOUR OF THE REMAINING ALTERNATIVES REQUIRE PLUGGING OF THREE WELLS INSTALLED DURING THE REMEDIAL INVESTIGATION SO AS NOT TO CREATE A PATHWAY FOR ADDITIONAL CONTAMINATION OF THE GROUNDWATER. GROUNDWATER WILL BE MONITORED USING REMAINING EXISTING WELLS. IN ADDITION, A WELL FIELD OR SHAFT/BORING SYSTEM WILL BE INSTALLED IN ORDER TO REMOVE CONTAMINATED GROUNDWATER FROM THE PERCHED ZONE. THE WELL FIELD WOULD REQUIRE UP TO 640 EXTRACTION WELLS BE INSTALLED. THE DURATION OF DRILLING WOULD LAST ONE AND A HALF YEARS WITH ESTIMATED 5 YEAR PRESENT WORTH COST OF $7,412,000 AND $2,786,000, FOR THE 10 YEAR OPTION. THE SHAFT/BORING OPTION WILL CONSIST OF INSTALLING FIVE SHAFTS EACH 10 FEET IN DIAMETER, FOLLOWED BY DRILLING HORIZONTAL BORINGS TO ACT AS COLLECTION DRAINS. EACH SHAFT/BORING IS EXPECTED TO TAKE 5 MONTHS TO COMPLETE. IT MAY BE POSSIBLE TO COMPLETE DRILLING THESE WELLS WITHIN 2 YEARS. THE PRESENT WORTH COST OF THE 5 YEARS OPTION IS ESTIMATED AT $5,042,000 AND $4,762,000 FOR THE 10 YEAR OPTION. THESE COSTS MUST BE ADDED TO THE COST ESTIMATES FOR THE REMAINING ALTERNATIVES.

ALTERNATIVE 3, ION EXCHANGE - A CENTRAL ION EXCHANGE SYSTEM WOULD BE USED TO REDUCE THE HEXAVALENT CHROMIUM TO LEVELS AT OR BELOW THE MCL ENFORCED DURING THE INITIATION OF SYSTEM DESIGN. SINCE AN ION EXCHANGE SYSTEM IS RELATIVELY SIMPLE TO OPERATE, THE OPERATOR'S TIME CAN BE SUBSTANTIALLY REDUCED BY AUTOMATING THE CENTRAL UNIT. INDIVIDUAL UNITS WOULD BE LABOR INTENSIVE SINCE, FOR PROPER REMEDIATION, AN OPERATOR WOULD HAVE TO CONSTANTLY MONITOR THE PERFORMANCE OF EACH UNIT. LOW VOLUMES OF SODIUM CHROMATE WILL BE GENERATED DURING THE TREATMENT PROCESS, THUS REQUIRING DISPOSAL AT A PERMITTED, OFF-SITE DISPOSAL FACILITY. TREATED GROUNDWATER WILL BE INJECTED INTO THE AQUIFER AT A LOCATION UPGRADIENT FROM THE CONTAMINATED PLUME. IN ORDER TO REMEDIATE THE GROUNDWATER WITHIN 10 YEARS, SIXTEEN EXTRACTION WELLS PUMPING AT 1-5 GPM AND ELEVEN INJECTION WELLS AT 1.5-6 GPM ARE REQUIRED. SIXTEEN EXTRACTION WELLS (1-10 GPM) AND ELEVEN INJECTION WELLS (3-12 GPM) ARE REQUIRED TO

TREAT THE GROUNDWATER WITHIN 5 YEARS. CONSTRUCTION OF THE SYSTEM IS EXPECTED TO LAST UP TO 5 MONTHS, PLUS TWO YEARS ARE REQUIRED TO INSTALL THE WELL SYSTEM FOR REMOVING WATER FROM THE PERCHED ZONE. THE TWO SYSTEMS MAY BE INSTALLED CONCURRENTLY. THE PRESENT WORTH COST OF TREATING THE GROUNDWATER FOR 10 YEARS IS $4,349,000. IF THE GROUNDWATER IS TREATED FOR 5 YEARS, THE COST IS $4,051,000. THE ANNUAL OPERATION AND MAINTENANCE COST ARE INCLUDED IN THE IMPLEMENTATION COST.

ALTERNATIVE 4, CHEMICAL TREATMENT - THE CONTAMINATED GROUNDWATER WILL BE TREATED WITH SODIUM BISULFATE IN ORDER TO CHEMICALLY REDUCE THE HEXAVALENT CHROMIUM INTO A LESS MOBILE AND TOXIC FORM (TRIVALENT CHROMIUM). THE CHROMIUM WOULD THEN BE PRECIPITATED FROM THE GROUNDWATER IN THE FORM OF CHROMIC HYDROXIDE. WHEN THE REMEDIAL1 Order number 940620-113550-ROD -001-001 page 1115 set 4 with 66 of 66 items

ACTION HAS BEEN COMPLETED, THE GROUNDWATER CONCENTRATION COULD BE AT OR BELOW 0.05 MG/L. THE SAME NUMBER OF EXTRACTION/INJECTION WELLS PREVIOUSLY DISCUSSED IN ALTERNATIVE 3 ARE REQUIRED FOR THE CHEMICAL TREATMENT PROCESS. THEORETICALLY, THE SLUDGES (CHROMIC HYDROXIDE) PRECIPITATED FROM THE GROUNDWATER DURING THE TREATMENT PROCESS MAY BE CONSIDERED NON-HAZARDOUS; HOWEVER, LABORATORY TESTING OF THE SLUDGE WILL BE REQUIRED FOR VERIFICATION. SHOULD LABORATORY TESTING CONFIRM THE SLUDGE IS NON-HAZARDOUS, THE SLUDGE WILL BE DISPOSED OF AT A NON-HAZARDOUS DISPOSAL FACILITY; OTHERWISE, THE MATERIAL WILL REQUIRE STORAGE AT A PERMITTED FACILITY. THE ENTIRE TREATMENT SYSTEM COULD BE ERECTED INSIDE AN ENCLOSURE TO PREVENT TAMPERING OF THE EQUIPMENT. CONSTRUCTION OF THE TREATMENT SYSTEM IS EXPECTED TO LAST 5 MONTHS. THE 10 YEAR PRESENT WORTH COST IS $5,606,000 INCLUDING OPERATION AND MAINTENANCE. IF THE GROUNDWATER IS TREATED FOR 5 YEARS, THE COST IS $4,511,000.

ALTERNATIVE 5, ELECTROCHEMICAL TREATMENT - THIS SYSTEM IS SIMILAR TO THE CHEMICAL TREATMENT SYSTEM; HOWEVER, AN ELECTRIC CURRENT, RATHER THAN SODIUM BISULFITE, ALLOWS FOR THE REDUCTION OF CHROMIUM FROM THE HEXAVALENT STATE TO THE TRIVALENT STATE. THE VOLUME OF THE TREATMENT SLUDGE (FERRIC AND CHROMIC HYDROXIDE) PRECIPITATE BY THE ELECTROCHEMICAL PROCESS IS GREATER THAN THE VOLUME PRODUCED DURING THE CHEMICAL TREATMENT SYSTEM. THE SLUDGE THAT IS PRODUCED MAY BE NON-HAZARDOUS. THE NON-HAZARDOUS CHARACTERISTICS OF THIS SLUDGE CAN ONLY BE ASCERTAINED BY PERFORMING EXTRACTION PROCEDURES TOXICITY TEST ON THE SLUDGE DURING THE REMEDIAL ACTION. AS WITH ALTERNATIVE 4, THE RESULTS OF CHEMICAL TESTING WILL DETERMINE THE PROPER METHOD OF DISPOSAL OF THE TREATMENT SLUDGES. THE DURATION OF CONSTRUCTING THIS SYSTEM IS ESTIMATED AT 5 MONTHS. A COST OF $4,042,000 AND $3,618,000 HAS BEEN ESTIMATED FOR THE PRESENT WORTH COST OF THE 10 AND 5 YEAR OPTIONS, RESPECTIVELY.

ALTERNATIVE 6, ION EXCHANGE - THIS OPTION IS SIMILAR TO ALTERNATIVE 3; HOWEVER, THE LEVEL OF REMEDIATION WILL BE 0.12 MG/L RATHER THAN THE CURRENT MCL OF 0.05 MG/L. THE PURPOSE FOR DEVELOPING A TREATMENT ALTERNATIVE WHICH DOES NOT REMEDIATE THE GROUNDWATER TO THE CURRENT

DRINKING WATER STANDARD WAS TO PROVIDE THE RELATIVE COST DIFFERENCE IN TREATING THE GROUNDWATER SHOULD THE MCL BE REVISED PRIOR TO DESIGNING THE TREATMENT SYSTEM. THE PRESENT WORTH COST OF THE REMEDY IS $3,968,000 FOR THE 10 YEAR OPTION AND $3,686,000 FOR THE 5 YEAR OPTION, INCLUDING OPERATION AND MAINTENANCE COST.

EVALUATION OF ALTERNATIVES

THE DEGREE THAT THE SIX REMEDIAL ALTERNATIVES MEET THE NINE SELECTION CRITERIA IS CONTAINED IN TABLE 4. THE FOLLOWING VALUES WERE ASSIGNED TO COMPARE REMEDIAL SELECTION CRITERIA:

+ ALTERNATIVE WOULD EXCEED A CRITERION IN COMPARISON TO OTHER ALTERNATIVES.1 Order number 940620-113550-ROD -001-001 page 1116 set 4 with 66 of 66 items

0 ALTERNATIVE CAN BE DESIGNED TO MEET THE SELECTION CRITERION.

- IN COMPARISON TO OTHER REMEDIES, THESE ALTERNATIVES WOULD PRESENT THE MOST DIFFICULTY IN ACHIEVING A SELECTION CRITERION.

THE RATIONALE FOR THE RATINGS ASSIGNED TO THIS TABLE IS AS FOLLOWS:

1. COMPLIES WITH ARARS

COMPLIANCE WITH ARARS IS ACHIEVED BY ALTERNATIVES 3, 4 AND 5. THESE TREATMENT ALTERNATIVES ARE CAPABLE OF ATTAINING THE FEDERALLY REGULATED PRIMARY DRINKING WATER STANDARD FOR CHROMIUM. THE NO ACTION, CONTAINMENT WALL, AND THE 0.12 MG/L ION EXCHANGE ALTERNATIVES (1, 2, AND 6) DO NOT COMPLY WITH THE ARARS SINCE THESE OPTIONS DO NOT REMEDIATE THE CONTAMINATED GROUNDWATER TO THE PRESENT MCL.

2. REDUCES: MOBILITY, TOXICITY, AND VOLUME

A. NO ACTION WAS RATED "-" BECAUSE IT DOES NOTHING TO REDUCE ANY OF THESE PARAMETERS.

B. CONTAINMENT WALL RECEIVED A "+" FOR MOBILITY SINCE IT WOULD EFFECTIVELY REDUCE FURTHER MIGRATION OF THE CONTAMINANTS AS LONG AS THE WALL IS PROPERLY MAINTAINED. THE WALL WOULD NOT REDUCE THE TOXICITY OR VOLUME OF THE CONTAMINATED GROUNDWATER, THEREFORE THE PARAMETERS RECEIVED "-".

C. ION EXCHANGE, CHEMICAL TREATMENT, AND ELECTROCHEMICAL TREATMENT (ALTERNATIVES 3, 4, 5, AND 6) ALL WERE RATED "+" FOR REDUCTIONS IN MOBILITY AND TOXICITY. EACH OF THESE REMEDIES EITHER REMOVE HEXAVALENT CHROMIUM FROM THE GROUNDWATER OR REDUCE THE HEXAVALENT CHROMIUM TO TRIVALENT

CHROMIUM WHICH IS LESS MOBILE AND LESS TOXIC. ALTHOUGH THE TREATMENT ALTERNATIVES ARE CAPABLE OF REMOVING CHROMIUM FROM THE GROUNDWATER, ALTERNATIVES 3, 4, 5, AND 6 RECEIVED "0" FOR REDUCTION IN VOLUME SINCE THE REMOVAL OF CHROMIUM WOULD NOT REDUCE THE VOLUME OF THE CHROMIUM WASTE.

3. SHORT TERM EFFECTIVENESS

THE NO ACTION OPTION WAS RATED "-" SINCE, ALTHOUGH PROTECTION FROM SHORT TERM EXPOSURE THROUGH INGESTION WOULD BE PROVIDED BY THE ALTERNATE WATER SUPPLY, THERE WOULD CONTINUE TO EXIST A POTENTIAL FOR CONSUMPTION OF CONTAMINATED GROUNDWATER SHOULD THE WATER SUPPLY SYSTEM FAIL.1 Order number 940620-113550-ROD -001-001 page 1117 set 4 with 66 of 66 items

THE INHALATION RISKS ASSOCIATED WITH THE EXTENSIVE DRILLING REQUIRED FOR INSTALLING THE CONTAINMENT WALL RESULTED IN THE OPTION RECEIVING A "-". BOTH THE ION EXCHANGE ALTERNATIVES WERE RATED "0" WHEN COMPARED WITH THE CHEMICAL AND ELECTROCHEMICAL SYSTEMS WHICH RECEIVED "+" BECAUSE THE ION EXCHANGE UNITS PRODUCE A HAZARDOUS SLUDGE WHEREAS THE OTHER SYSTEMS RESULT IN A NON-HAZARDOUS TREATMENT SLUDGE. THE SLUDGE FROM THE ION EXCHANGE UNITS MAY POSE A SHORT TERM THREAT TO HUMAN HEALTH AND THE ENVIRONMENT SHOULD AN ACCIDENTAL SPILL OCCUR DURING TRANSPORT TO A DISPOSAL FACILITY.

4. LONG TERM EFFECTIVENESS AND PERMANENCE

SINCE CHROMIUM LEVELS WILL REMAIN ABOVE THE PRIMARY DRINKING WATER STANDARD, THE NO ACTION ALTERNATIVE WAS RATED "-". THE CONTAINMENT REMEDY WAS ASSIGNED A "0" BECAUSE, ALTHOUGH CONTAINED, THE GROUNDWATER INSIDE THE BARRIER REMAINS UNFIT FOR HUMAN CONSUMPTION. THE CONTAINMENT BARRIER ALSO HAS THE POTENTIAL OF A BREAKTHROUGH THUS ITS PERMANENCE RELATIVE TO THE TREATMENT REMEDIES IS QUESTIONABLE. ALTERNATIVE 4, CHEMICAL TREATMENT, EFFECTIVELY REDUCES THE LEVEL OF CHROMIUM IN THE GROUND WATER TO THE PRIMARY DRINKING WATER STANDARD; HOWEVER, THE SYSTEM WILL ALSO INCREASE THE LEVEL OF DISSOLVED SOLIDS IN THE GROUNDWATER. ALTHOUGH AN INCREASE IN DISSOLVED SOLIDS IS NOT A HEALTH THREAT, IT DOES EFFECT THE TASTE OF THE WATER; THEREFORE, THE ALTERNATIVE WAS RATED "0". ALL OF THE REMAINING TREATMENT ALTERNATIVES (3, 5 AND 6) RECEIVE A "+" SINCE ALL CHROMIUM ABOVE THE RESPECTIVE CLEAN-UP CRITERIA IS REMOVED WITHOUT EFFECTING THE SECONDARY QUALITY (TASTE, ODOR AND COLOR) OF THE GROUNDWATER.

5. IMPLEMENTABILITY

THE NO ACTION ALTERNATIVE IS RELATIVELY EASY TO IMPLEMENT

SINCE IT INVOLVES INSTALLING NEW MONITOR WELLS AND PLUGGING SOME EXISTING WELLS. THE CONTAINMENT WALL WILL BE VERY DIFFICULT TO IMPLEMENT DUE TO THE EXTENSIVE DRILLING REQUIRED TO INSTALL THE WALL. THE DURATION OF THE DRILLING ACTIVITIES IS ESTIMATED AT 4 YEARS; THEREFORE ALTERNATIVE 2 RECEIVED A "-" FOR IMPLEMENTABILITY. THE TREATMENT REMEDIES WERE ASSIGNED "0". THE TREATMENT TECHNOLOGIES CONSIDERED FOR THE SITE ARE NOT INNOVATIVE THEREFORE STANDARD SYSTEM DESIGN MAY BE USED. CONSTRUCTION AND OPERATION OF THESE SYSTEMS, WHILE NOT SIMPLE RELATIVE TO THE NO ACTION ALTERNATIVE, WOULD NOT BE AS DIFFICULT TO IMPLEMENT AS THE CONTAINMENT BARRIER OPTION.

6. COST1 Order number 940620-113550-ROD -001-001 page 1118 set 4 with 66 of 66 items

THE PRESENT WORTH COST OF EACH ALTERNATIVE INCLUDES CAPITAL COST, ANNUAL REMEDIATION OPERATION AND MAINTENANCE, ANNUAL POST CLOSURE OPERATION AND MAINTENANCE, 5-YEAR REVIEW COST, AND REPLACEMENT COST. ANNUAL REMEDIATION OPERATION AND MAINTENANCE COST AND REPLACEMENT COST WERE CALCULATED FOR THE DURATION OF THE 5 AND 10 YEAR TREATMENT REMEDY OR 30 YEARS FOR THE CONTAINMENT AND NO ACTION ALTERNATIVES. THE COST DIFFERENCE ASSOCIATED WITH A LEVEL OF REMEDIATION (0.12 MG/L) GREATER THAN THE CURRENT MCL (0.05 MG/L) IS $700,000 FOR THE 5-YEAR ION EXCHANGE OPTION AND $600,000 FOR THE 10 YEAR ION EXCHANGE OPTION. THE DIFFERENCE IN COST IS DUE TO THE NUMBER OF EXTRACTION WELLS AND RATE AT WHICH THESE WELLS PRODUCE. THE COST OF THE TREATMENT SYSTEM IS SIMILAR AT EITHER LEVEL OF REMEDIATION.

INCLUDED IN THE COST OF THE TREATMENT SYSTEMS ARE THE COST ASSOCIATED WITH THE PERCHED ZONE EXTRACTION WELLS USING THE SHAFT/BORING OPTION. IN ORDER TO EXTRACT THE CONTAMINATED GROUNDWATER FROM THE PERCHED ZONE WITHIN 5 YEARS USING THE WELL FIELD OPTION, 640 WELLS WOULD BE NECESSARY. THE PRESENT WORTH COST OF THIS SYSTEM IS $7,412,000 INCLUDING A REPLACEMENT COST OF $442,000. USING FIVE 10-FOOT DIAMETER SHAFTS WITH SEVERAL HORIZONTAL BORINGS FROM EACH SHAFT (SHAFT/BORING OPTION), THE 5 YEAR EXTRACTION OF GROUNDWATER WOULD COST $5,042,000 INCLUDING A REPLACEMENT COST OF $10,000. BOTH THE EXTRACTION WELL SYSTEMS HAVE LOWER 10 YEAR PRESENT VALUE COSTS; HOWEVER, THE VALUE OF THIS DIFFERENCE IS MINIMIZED DUE TO HIGHER TREATMENT SYSTEM COSTS FOR THE 10 YEAR REMEDIATION RELATIVE TO THE 5 YEAR REMEDIATION.

7. COMMUNITY ACCEPTANCE

THE COMMUNITY NEITHER ENDORSED NOR OPPOSED ANY OF THE REMEDIAL ACTIONS PRESENTED DURING THE PUBLIC MEETING. HOWEVER, IT IS UNLIKELY THE CITIZENS IMPACTED BY THE SITE

WOULD SUPPORT EITHER THE NO ACTION OR CONTAINMENT REMEDY SINCE THE CHROMIUM WOULD NOT BE REMOVED FROM THEIR ONLY SOURCE OF DRINKING WATER.

8. STATE ACCEPTANCE

THE STATE OF TEXAS (TEXAS WATER COMMISSION) HAS CONCURRED WITH THE TREATMENT OF THE CHROMIUM CONTAMINATED USING THE ELECTROCHEMICAL PROCESS.

9. OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

A RATING OF "-" WAS ASSIGNED TO THE NO ACTION ALTERNATIVE BECAUSE THIS OPTION DOES NOT PROVIDE FOR ANY REDUCTION OF1 Order number 940620-113550-ROD -001-001 page 1119 set 4 with 66 of 66 items

EXPOSURE TO CONTAMINATED GROUNDWATER. THE WATER WILL REMAIN CONTAMINATED AT LEVELS IN EXCESS OF THE DRINKING WATER CRITERIA. CONTAINING THE CONTAMINATED WATER, ALTERNATIVE 2, IS EFFECTIVE IN PROTECTING HUMAN HEALTH AND THE ENVIRONMENT AS LONG AS THE GROUT BARRIER IS PROPERLY MAINTAINED. ALTHOUGH UNLIKELY, BREAKTHROUGH OF THE WALL MAY OCCUR THUS RELEASING THE CONTAMINATED GROUNDWATER. DUE TO THE POTENTIAL INCREASED RISK CAUSED BY FAILURE OF THE BARRIER, ALTERNATIVE 2 RECEIVED A "0". THE TREATMENT OPTIONS RECEIVED THE HIGHEST RATING OF "+". THESE ALTERNATIVES ARE HIGHLY EFFECTIVE SINCE NO CHROMIUM ABOVE THE RESPECTIVE ACTION LEVEL WILL REMAIN IN THE GROUNDWATER FOLLOWING REMEDIAL ACTION.

#RA V. SELECTED REMEDY ELECTROCHEMICAL TREATMENT

RATIONALE

BASED ON THE INFORMATION AVAILABLE TO EVALUATE THE SIX REMEDIAL OPTIONS AGAINST THESE NINE CRITERIA. EPA HAS CONCLUDED THAT ALTERNATIVE 5, ELECTROCHEMICAL TREATMENT OF THE GROUNDWATER IN FIVE YEARS IS THE AGENCY'S PREFERRED ALTERNATIVE. A TREATMENT STUDY WILL BE CONDUCTED DURING THE SYSTEM DESIGN PHASE OF THE PROJECT. RESULTS OF THIS STUDY WILL AID IN DESIGNING AN APPROPRIATE TREATMENT SYSTEM. THE FIVE YEAR DURATION OPTION WILL BE USED RATHER THAN THE TEN YEAR OPTION DUE TO THE HIGH O&M COST ASSOCIATED WITH LONGER DURATION. THIS ALTERNATIVE WOULD BE PROTECTIVE OF HUMAN HEALTH AND THE ENVIRONMENT, ATTAIN ALL APPLICABLE OR RELEVANT AND APPROPRIATE FEDERAL AND STATE REQUIREMENTS, AND IS COST-EFFECTIVE. THIS OPTION WOULD ALSO SATISFY SARA'S PREFERENCE FOR REMEDIES WHICH EMPLOY TREATMENT, AS THEIR PRINCIPAL ELEMENT TO REDUCE TOXICITY, MOBILITY, OR VOLUME SINCE CHROMIUM LEVELS WOULD BE REDUCED TO THE CURRENT MCL OR THE MCL PROMULGATED PRIOR TO DESIGN.

THE SHAFT/BORING WELL SYSTEM WILL BE USED TO WITHDRAW GROUNDWATER

FROM THE PERCHED ZONE. ALTHOUGH THE CONSTRUCTION OF THIS SYSTEM WILL TAKE NO LONGER THAN THE WELL FIELD OPTION, TWO YEARS VERSUS ONE AND ONE-HALF YEARS, THE SHAFT/BORING OPTION WOULD BE MORE RELIABLE. A GREAT DEAL OF OPERATION AND MAINTENANCE WOULD BE NECESSARY TO ENSURE THE 640 WELLS, REQUIRED FOR THE WELL FIELD, ARE FUNCTIONING PROPERLY.

THE SITE WILL BE MONITORED FOR A PERIOD OF AT LEAST 30 YEARS (POST CLOSURE TIME PERIOD STIPULATED UNDER RCRA) TO ENSURE THAT NO SIGNIFICANT CONTAMINATION MIGRATE FROM THE SITE. IF, HOWEVER, FUTURE MIGRATION DOES OCCUR, APPROPRIATE REMEDIAL ACTIONS WILL BE EVALUATED.

#OM OPERATION AND MAINTENANCE (O&M)


SITE OPERATION AND MAINTENANCE WILL BE MINIMAL FOLLOWING REMEDIAL ACTION SINCE THE CHROMIUM LEVELS IN THE GROUNDWATER WILL BE BELOW THE DRINKING WATER STANDARD. WELLS WILL BE MONITORED ANNUALLY TO ENSURE CHROMIUM LEVELS REMAIN BELOW THE CLEAN-UP CRITERIA. THE STATE OF TEXAS WILL ASSUME RESPONSIBILITY FOR OPERATION AND MAINTENANCE OF THE SITE. EPA WILL PAY 90% OF THE COST DURING THE REMEDIATION PERIOD. FOLLOWING REMEDIATION, THE STATE OF TEXAS WILL CONDUCT ANNUAL MONITORING FOR AT LEAST THE REMAINING DURATION OF THE 30 YEAR MONITORING PERIOD.

#FA FUTURE ACTIONS

NO FUTURE ACTIONS ARE ANTICIPATED. THE ELECTROCHEMICAL TREATMENT ALTERNATIVE IS CONSIDERED PERMANENT. IF, HOWEVER, SIGNIFICANT UNFORESEEN OFFSITE MIGRATION OR CONTAMINATION OCCURS AS A RESULT OF THE SITE, MEASURES WILL BE IMPLEMENTED TO REMEDIATE THE SITUATION.

#SCH REMEDIAL ACTION SCHEDULE

APPROVE REMEDIAL ACTION (SIGN ROD) MARCH 1988

COMPLETE ENFORCEMENT NEGOTIATIONS JUNE 1988

AWARD COOPERATIVE AGREEMENT AMENDMENT AUGUST 1988 FOR DESIGN OF APPROVED REMEDY

START DESIGN OCTOBER 1988

COMPLETE DESIGN AUGUST 1989

AWARD REMEDIAL ACTION COOPERATIVE AGREEMENT AMENDMENT FOR CONSTRUCTION OF APPROVED REMEDY OCTOBER 1989

START CONSTRUCTION JANUARY 1990

COMPLETE CONSTRUCTION JANUARY 1992

COMPLETE GROUNDWATER TREATMENT JANUARY 1997.

#TMA TABLES, MEMORANDA, ATTACHMENTS

ATTACHMENT A

ADMINISTRATIVE RECORDS INDEX1 Order number 940620-113550-ROD -001-001 page 1121 set 4 with 66 of 66 items

JOB NAME: ODESSA CHROMIUM II

JOB NUMBER: T114

DOCUMENT DATE NO DATE SPECIFIED DOCUMENT TYPE NOTICE OF PUBLIC MEETING ORIGINATOR TEXAS DEPT. OF WATER RESOURCES ORIGINATOR - AFFILIATION RECIPIENT PUBLIC RECIPIENT - AFFILIATION DESCRIPTION 08/08/85 PUBLIC MEETING NOTICE NUMBER OF PAGES 1 DOCUMENT NUMBER 000001

DOCUMENT DATE NO DATE SPECIFIED DOCUMENT TYPE REPORT ORIGINATOR I.T. CORPORATION/HOWELL ENGINEERING ORIGINATOR - AFFILIATION CONTRACTOR TO U.S. E.P.A. RECIPIENT U.S. E.P.A. AND T.W.C. RECIPIENT - AFFILIATION DESCRIPTION PLAN FOR AN ALTERNATE POTABLE WATER SOURCE NUMBER OF PAGES 15 DOCUMENT NUMBER 000002

DOCUMENT DATE 09/06/77 DOCUMENT TYPE COMPLAINT & INVESTIGATION REPORTS ORIGINATOR HANK KRUSEKOPH ORIGINATOR - AFFILIATION RAILROAD COMMISSION OF TEXAS, MIDLAND RECIPIENT ROBERT BRADSHAW, SUPERVISOR RECIPIENT - AFFILIATION DISTRICT 10, TEXAS WATER QUALITY BOARD DESCRIPTION CONTAMINATION COMPLAINT AND INVESTIGATION REPORTS

NUMBER OF PAGES 29 DOCUMENT NUMBER 000003

DOCUMENT DATE 11/16/77 DOCUMENT TYPE MEMORANDUM ORIGINATOR ROBERT L. BRADSHAW, SUPERVISOR ORIGINATOR - AFFILIATION DISTRICT 10, TEXAS DEPT. OF WATER RESOURCES RECIPIENT GEORGE GREEN, P.E., CHIEF, FIELD SUPPORT RECIPIENT - AFFILIATION FIELD OPERATIONS, WATER SUPPLY DESCRIPTION COMPLAINT - WATER WELL CONTAMINATION - E.M. CASSITY NUMBER OF PAGES 191 Order number 940620-113550-ROD -001-001 page 1122 set 4 with 66 of 66 items

DOCUMENT NUMBER 000004

ADMINISTRATIVE RECORDS INDEX


JOB NUMBER: T114

DOCUMENT DATE 04/14/78 DOCUMENT TYPE MEMORANDUM ORIGINATOR JERRY L. PHILLIPS, R.S., DISTRICT 10 REPRESENTATIVE ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT DAN HAVELKA, CHIEF, FIELD SUPPORT SECTION RECIPIENT - AFFILIATION ENFORCEMENT AND FIELD OPERATIONS DIVISION DESCRIPTION E.M. CASSITY (DBA REDONDO MOTEL) COMPLAINT NUMBER OF PAGES 41 DOCUMENT NUMBER 000005

DOCUMENT DATE 05/25/79 DOCUMENT TYPE MEMORANDUM ORIGINATOR C.R. MIERTSCHIN, DIRECTOR, ENFORCEMENT & FIELD OPS. DIV. ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT C.R. BASKIN, DIRECTOR, DATA & ENGINEERING SVCS. RECIPIENT - AFFILIATION TEXAS DEPT. OF WATER RESOURCES DESCRIPTION GROUND WATER CONTAMINATION NUMBER OF PAGES 7 DOCUMENT NUMBER 000006

DOCUMENT DATE 07/16/79 DOCUMENT TYPE MEMORANDUM

ORIGINATOR JERRY PHILLIPS, FIELD REPRESENTATIVE, DISTRICT 10 ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT GEORGE E. GREEN, P.E. CHIEF, FIELD SUPPORT SECTION RECIPIENT - AFFILIATION TEXAS DEPT. OF WATER RESOURCES DESCRIPTION CASSITY COMPLAINT, PUMPING RESULTS NUMBER OF PAGES 26 DOCUMENT NUMBER 000007

DOCUMENT DATE 07/26/79 DOCUMENT TYPE MEMORANDUM ORIGINATOR GEORGE E. GREEN, P.E. CHIEF ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES1 Order number 940620-113550-ROD -001-001 page 1123 set 4 with 66 of 66 items

RECIPIENT BUCK STEINGRABER RECIPIENT - AFFILIATION SOLID WASTE AND UNDERGROUND INJECTION DIVISION DESCRIPTION GROUND WATER CONTAMINATION COMPLAINT 7/16/79 NUMBER OF PAGES 1 DOCUMENT NUMBER 000008



JOB NUMBER: T114

DOCUMENT DATE 04/07/81 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR C.R. MIERTSCHIN, DIRECTOR ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT BILLY MAXWELL RECIPIENT - AFFILIATION WOOLEY TOOL & MFG. DIVISION DESCRIPTION REQUEST TO PLUG WELLS AT WOOLEY TOOL NUMBER OF PAGES 2 DOCUMENT NUMBER 000009

DOCUMENT DATE 06/21/83 DOCUMENT TYPE QAPP REPORT ORIGINATOR U.S. E.P.A. ORIGINATOR - AFFILIATION RECIPIENT U.S. E.P.A. RECIPIENT - AFFILIATION DESCRIPTION QUALITY ASSURANCE PROJECT PLAN NUMBER OF PAGES 146 DOCUMENT NUMBER 000010

DOCUMENT DATE 02/23/84 DOCUMENT TYPE CORRESPONDENCE

ORIGINATOR WILLIAM F. LOCKEY, DISTRICT SUPERVISOR ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT GERALD FUGITT RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION CHROMIUM CONTAMINATION OF GROUND WATER NUMBER OF PAGES 1 DOCUMENT NUMBER 000011

DOCUMENT DATE 02/23/84 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR WILLIAM F. LOCKEY, DISTRICT SUPERVISOR1 Order number 940620-113550-ROD -001-001 page 1124 set 4 with 66 of 66 items

ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT MR. HOOTON RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION CHROMIUM CONTAMINATION OF GROUND WATER NUMBER OF PAGES 1 DOCUMENT NUMBER 000012



JOB NUMBER: T114

DOCUMENT DATE 02/23/84 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR WILLIAM F. LOCKEY, DISTRICT 10 SUPERVISOR ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT DOROTHY BELL RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION CHROMIUM CONTAMINATION OF GROUND WATER NUMBER OF PAGES 1 DOCUMENT NUMBER 000013

DOCUMENT DATE 02/23/84 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR WILLIAM F. LOCKEY, DISTRICT 10 SUPERVISOR ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT MR. DALE MEYER RECIPIENT - AFFILIATION DALE MEYER TRUCKING CO. DESCRIPTION CHROMIUM CONTAMINATION OF GROUND WATER NUMBER OF PAGES 1


DOCUMENT DATE 02/23/84 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR WILLIAM F. LOCKEY, DISTRICT 10 SUPERVISOR ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT MR. BOWDEN RECIPIENT - AFFILIATION BOWDEN CONSTRUCTION CO., INC. DESCRIPTION CHROMIUM CONTAMINATION OF GROUND WATER NUMBER OF PAGES 1 DOCUMENT NUMBER 000015


DOCUMENT DATE 02/23/84 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR WILLIAM F. LOCKEY, DISTRICT 10 SUPERVISOR ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT MR. GARLAND SORRELL RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION CHROMIUM CONTAMINATION OF GROUND WATER NUMBER OF PAGES 1 DOCUMENT NUMBER 000016



JOB NUMBER: T114

DOCUMENT DATE 03/06/84 DOCUMENT TYPE MEMORANDUM ORIGINATOR JOAN A. MIDDLETON, ENVIRONMENTAL QUALITY SPECIALIST ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT GARY D. SCHROEDER, CHIEF, S.W. AND SPILL RESPONSE RECIPIENT - AFFILIATION TEXAS DEPT OF WATER RESOURCES DESCRIPTION ANDREWS HIGHWAY SUPERFUND SITE - GROUND WATER SAMPLING NUMBER OF PAGES 13 DOCUMENT NUMBER 000017

DOCUMENT DATE 03/19/84 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR WILLIAM F. LOCKEY, DISTRICT 10 SUPERVISOR ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES

RECIPIENT MR. ADMIRE RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION SELENIUM CONTAMINATION OF GROUND WATER NUMBER OF PAGES 1 DOCUMENT NUMBER 000018

DOCUMENT DATE 04/06/84 DOCUMENT TYPE CORRESPONDENCE AND GROUND WATER ANALYSIS ORIGINATOR WILLIAM F. LOCKEY, DISTRICT 10 SUPERVISOR ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT MR. GERALD FUGITT1 Order number 940620-113550-ROD -001-001 page 1126 set 4 with 66 of 66 items

RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION CHROMIUM CONTAMINATION OF GROUND WATER NUMBER OF PAGES 2 DOCUMENT NUMBER 000019

DOCUMENT DATE 01/04/85 DOCUMENT TYPE CORRESPONDENCE AND GROUND WATER ANALYSIS ORIGINATOR WILLIAM F. LOCKEY, DISTRICT 10 SUPERVISOR ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT LEE C. MOORE, INC. RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION GROUND WATER CONTAMINATION NUMBER OF PAGES 2 DOCUMENT NUMBER 000020



JOB NUMBER: T114

DOCUMENT DATE 02/27/85 DOCUMENT TYPE PRESENTATION MATERIALS/COPIES OF SLIDES ORIGINATOR I.T. CORPORATION ORIGINATOR - AFFILIATION RECIPIENT TEXAS DEPT. OF WATER RESOURCES RECIPIENT - AFFILIATION DESCRIPTION ODESSA CHROMIUM I AND II NUMBER OF PAGES 26 DOCUMENT NUMBER 000021

DOCUMENT DATE 04/19/85

DOCUMENT TYPE PRESENTATION MATERIALS - ODESSA CHROMIUM I, II ORIGINATOR I.T. CORPORATION ORIGINATOR - AFFILIATION RECIPIENT RECIPIENT - AFFILIATION DESCRIPTION MEETING WITH U.S. E.P.A. AND TEXAS DEPT. OF WATER RESOURCES NUMBER OF PAGES 26 DOCUMENT NUMBER 000022

DOCUMENT DATE 06/18/85 DOCUMENT TYPE MEMO AND CRP - ODESSA CHROMIUM I, II SITES1 Order number 940620-113550-ROD -001-001 page 1127 set 4 with 66 of 66 items

ORIGINATOR WILLIAM W. COLBERT, SW AND SPILL RESPONSE SECTION ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT CARLENE CHAMBERS RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION MEMO AND CRP - ODESSA I, II SITES NUMBER OF PAGES 23 DOCUMENT NUMBER 000023

DOCUMENT DATE 07/05/85 DOCUMENT TYPE QUALITY ASSURANCE PROJECT PLAN - REV. 1 ORIGINATOR I.T. CORPORATION ORIGINATOR - AFFILIATION RECIPIENT TEXAS DEPT. OF WATER RESOURCES RECIPIENT - AFFILIATION DESCRIPTION SITE INVESTIGATION AND FEASIBILITY STUDIES NUMBER OF PAGES 82 DOCUMENT NUMBER 000024



JOB NUMBER: T114

DOCUMENT DATE 07/17/85 DOCUMENT TYPE MEMORANDUM ORIGINATOR ERNEST W. HEYER, Q.A. OFFICER ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT BRYAN W. DIXON RECIPIENT - AFFILIATION TEXAS DEPT. OF WATER RESOURCES DESCRIPTION RE: QAPP FOR ODESSA CHROMIUM I, II SITES NUMBER OF PAGES 2


DOCUMENT DATE 08/02/85 DOCUMENT TYPE MEMORANDUM ORIGINATOR MATT TOKHEIM, ENGINEERING TECHNICIAN III ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS DEPT. OF WATER RESOURCES DESCRIPTION CURRENT USE OF CONTAMINATED WATER WELLS NUMBER OF PAGES 2 DOCUMENT NUMBER 000026


DOCUMENT DATE 08/22/85 DOCUMENT TYPE MEMO ORIGINATOR CARLENE L. CHAMBERS, PROJECT OFFICER ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT BRYAN W. DIXON, CHIEF RECIPIENT - AFFILIATION TEXAS DEPT. OF WATER RESOURCES DESCRIPTION SAMPLING PLAN OBJECTIVES NUMBER OF PAGES 3 DOCUMENT NUMBER 000027

DOCUMENT DATE 08/23/85 DOCUMENT TYPE MEMORANDUM ORIGINATOR BRYAN W. DIXON ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT AL HUSAK, PROJECT MANAGER RECIPIENT - AFFILIATION I.T. CORPORATION DESCRIPTION PARTIAL APPROVAL OF SAMPLING PLAN NUMBER OF PAGES 2 DOCUMENT NUMBER 000028



JOB NUMBER: T114

DOCUMENT DATE 08/26/85 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR BRYAN W. DIXON ORIGINATOR - AFFILIATION TEXAS DEPT. OF WATER RESOURCES RECIPIENT NDT SYSTEMS, INC. RECIPIENT - AFFILIATION DESCRIPTION ACCESS AGREEMENT - ODESSA II SUPERFUND SITE NUMBER OF PAGES 11 DOCUMENT NUMBER 000029

DOCUMENT DATE 09/11/85 DOCUMENT TYPE MEMO AND REPORT ORIGINATOR D.O. PRATT, ATTORNEY ORIGINATOR - AFFILIATION GANDY MICHENER SWINDLE WHITAKER & PRATT RECIPIENT LOU BARINKA RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION MEMO AND FINAL CLOSURE REPORT NUMBER OF PAGES 114 DOCUMENT NUMBER 000030

DOCUMENT DATE 09/23/85 DOCUMENT TYPE MEMORANDUM1 Order number 940620-113550-ROD -001-001 page 1129 set 4 with 66 of 66 items

ORIGINATOR MATT TOKHEIM, ENGINEERING TECHNICIAN III ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT BILL BROWN, H & SW DIVISION RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION FOLLOW-UP REPORT ON GROUND WATER CONTAMINATION NUMBER OF PAGES 27 DOCUMENT NUMBER 000031

DOCUMENT DATE 10/01/85 DOCUMENT TYPE TRANSMITTAL - TABLES OF CONTAMINATED WATER WELLS ORIGINATOR ALAN D. HUSAK, MGR. OF ENGINEERING ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION WELL INVENTORY SURVEY NUMBER OF PAGES 24 DOCUMENT NUMBER 000032



JOB NUMBER: T114

DOCUMENT DATE 10/03/85 DOCUMENT TYPE TRANSMITTAL - TABLES OF UNCONTAMINATED WATER WELLS ORIGINATOR ROBERT S. NEWTON, PROJECT COORDINATOR ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION UNCONTAMINATED WELL INVENTORY SURVEY


DOCUMENT DATE 10/14/85 DOCUMENT TYPE TRANSMITTAL LETTER ORIGINATOR ROBERT S. NEWTON, PROJECT COORDINATOR ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION PROPERTY LOCATIONS FOR MONITOR WELLS NUMBER OF PAGES 8 DOCUMENT NUMBER 000034


DOCUMENT DATE 10/22/85 DOCUMENT TYPE TRANSMITTAL LETTER ORIGINATOR ROBERT S. NEWTON, PROJECT COORDINATOR ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION LETTER OF CLARIFICATION - QAPP NUMBER OF PAGES 5 DOCUMENT NUMBER 000035

DOCUMENT DATE 11/85 DOCUMENT TYPE REPORT ORIGINATOR I.T./ERT ORIGINATOR - AFFILIATION RECIPIENT U.S. E.P.A. RECIPIENT - AFFILIATION DESCRIPTION WELL INVENTORY RI NUMBER OF PAGES 36 DOCUMENT NUMBER 000036



JOB NUMBER: T114

DOCUMENT DATE 11/08/85 DOCUMENT TYPE MAILING LIST AND WATER WELL SAMPLING RESULTS ORIGINATOR CHARLES R. FAULDS, P.E., CHIEF, SUPERFUND SECTION ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT WELL OWNERS RECIPIENT - AFFILIATION ONLY THOSE WELL OWNERS WITH MULTIPLE WELLS

DESCRIPTION ANALYTICAL RESULTS: NO CHROMIUM DETECTED NUMBER OF PAGES 20 DOCUMENT NUMBER 000037

DOCUMENT DATE 11/08/85 DOCUMENT TYPE MAILING LIST AND WATER WELL SAMPLING RESULTS ORIGINATOR CHARLES R. FAULDS, P.E., CHIEF, SUPERFUND SECTION ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT WELL OWNERS RECIPIENT - AFFILIATION ONLY THOSE WELL OWNERS WITH SINGLE WELL1 Order number 940620-113550-ROD -001-001 page 1131 set 4 with 66 of 66 items

DESCRIPTION ANALYTICAL RESULTS: NO CHROMIUM DETECTED NUMBER OF PAGES 20 DOCUMENT NUMBER 000038

DOCUMENT DATE 11/14/85 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR CHARLES R. FAULDS, P.E., CHIEF, SUPERFUND SECTION ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT MR. DANNY WILLIE RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION WATER WELL SAMPLING RESULTS NUMBER OF PAGES 2 DOCUMENT NUMBER 000039

DOCUMENT DATE 11/14/85 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR CHARLES R. FAULDS, P.E., CHIEF, SUPERFUND SECTION ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT MR. VERNON DUGGANS RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION WATER WELL SAMPLING RESULTS NUMBER OF PAGES 2 DOCUMENT NUMBER 000040



JOB NUMBER: T114

DOCUMENT DATE 11/14/85 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR CHARLES R. FAULDS, P.E., CHIEF,

SUPERFUND SECTION ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT MS. DOROTHY BELL RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION WATER WELL SAMPLING RESULTS NUMBER OF PAGES 2 DOCUMENT NUMBER 000041

DOCUMENT DATE 11/14/85 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR CHARLES R. FAULDS, P.E., CHIEF, SUPERFUND SECTION ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT MR. DALE MEYER1 Order number 940620-113550-ROD -001-001 page 1132 set 4 with 66 of 66 items

RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION WATER WELL SAMPLING RESULTS NUMBER OF PAGES 2 DOCUMENT NUMBER 000042

DOCUMENT DATE 11/14/85 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR CHARLES R. FAULDS, P.E., CHIEF, SUPERFUND SECTION ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT MR. BURL GRAHAM RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION WATER WELL SAMPLING RESULTS NUMBER OF PAGES 2 DOCUMENT NUMBER 000043

DOCUMENT DATE 11/14/85 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR CHARLES R. FAULDS, P.E., CHIEF, SUPERFUND SECTION ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT MR. HOWARD BOATRIGHT RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION WATER WELL SAMPLING RESULTS NUMBER OF PAGES 2 DOCUMENT NUMBER 000044



JOB NUMBER: T114

DOCUMENT DATE 11/14/85 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR CHARLES R. FAULDS, P.E., CHIEF,

SUPERFUND SECTION ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT MR. RAMESH WADHWA RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION WATER WELL SAMPLING RESULTS NUMBER OF PAGES DOCUMENT NUMBER 000045

DOCUMENT DATE 11/14/85 DOCUMENT TYPE CORRESPONDENCE AND COMMENTS ORIGINATOR CARLENE L. CHAMBERS, PROJECT OFFICER ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT CHARLES R. FAULDS, P.E., CHIEF, SUPERFUND SECTION1 Order number 940620-113550-ROD -001-001 page 1133 set 4 with 66 of 66 items

RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION CONDITIONAL APPROVAL OF QAPP NUMBER OF PAGES 2 DOCUMENT NUMBER 000046

DOCUMENT DATE 11/15/85 DOCUMENT TYPE MEMO AND COMMENTS ORIGINATOR ROBERT S. NEWTON, PROJECT COORDINATOR ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT CHARLES R. FAULDS, P.E., CHIEF, SUPERFUND SECTION RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION RESPONSE TO COMMENTS ON SAMPLING PLAN (TWC) NUMBER OF PAGES 53 DOCUMENT NUMBER 000047

DOCUMENT DATE 11/15/85 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR CHARLES R. FAULDS, P.E., CHIEF, SUPERFUND SECTION ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT HENRY RODRIGUEZ RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION WATER WELL SAMPLING RESULTS NUMBER OF PAGES 2 DOCUMENT NUMBER 000048



JOB NUMBER: T114


DOCUMENT TYPE CORRESPONDENCE ORIGINATOR CHARLES R. FAULDS, P.E., CHIEF, SUPERFUND SECTION ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT MR. TRUMAN FOX RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION WATER WELL SAMPLING RESULTS NUMBER OF PAGES 2 DOCUMENT NUMBER 000049

DOCUMENT DATE 11/15/85 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR CHARLES R. FAULDS, P.E., CHIEF, SUPERFUND SECTION1 Order number 940620-113550-ROD -001-001 page 1134 set 4 with 66 of 66 items

ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT MR. STAN STUCKS RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TEXAS DESCRIPTION WATER WELL SAMPLING RESULTS NUMBER OF PAGES 2 DOCUMENT NUMBER 000050

DOCUMENT DATE 11/15/85 DOCUMENT TYPE REPORT ORIGINATOR I.T. CORPORATION ORIGINATOR - AFFILIATION RECIPIENT TEXAS WATER COMMISSION RECIPIENT - AFFILIATION DESCRIPTION HEALTH AND SAFETY PLAN REV. 1 NUMBER OF PAGES 63 DOCUMENT NUMBER 000051

DOCUMENT DATE 11/21/85 DOCUMENT TYPE MEMORANDUM ORIGINATOR STEPHEN MARGOLIS, PH.D. ORIGINATOR - AFFILIATION ATSDR RECIPIENT MR. CARL HICKAM, PUBLIC HEALTH ADVISOR RECIPIENT - AFFILIATION U.S. E.P.A. REGION VI DESCRIPTION HEALTH ASSESSMENT - ODESSA CHROMIUM I AND II NUMBER OF PAGES 2 DOCUMENT NUMBER 000052



JOB NUMBER: T114


DOCUMENT TYPE MEMORANDUM ORIGINATOR STEVE MUSE, GEOLOGIST ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT CARLENE CHAMBERS, PROJECT OFFICER RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION FIELD AUDIT OF MONITOR WELL DRILLING NUMBER OF PAGES 1 DOCUMENT NUMBER 000053

DOCUMENT DATE 01/16/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR GREG TIPPLE ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT BONNIE J. DEVOS, CHIEF, STATE1 Order number 940620-113550-ROD -001-001 page 1135 set 4 with 66 of 66 items

PROGRAMS SECTION RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION DISPOSAL/STORAGE OF INVESTIGATED SUBSTANCES NUMBER OF PAGES 3 DOCUMENT NUMBER 000054

DOCUMENT DATE 01/21/86 DOCUMENT TYPE RECORD OF COMMUNICATION ORIGINATOR STEVE MUSE, GEOLOGIST ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT FILE RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION USE OF CONTAMINATED WATER FOR DRINKING NUMBER OF PAGES 2 DOCUMENT NUMBER 000055

DOCUMENT DATE 01/31/86 DOCUMENT TYPE MEMORANDUM ORIGINATOR BONNIE J. DEVOS, CHIEF, STATE PROGRAMS SECTION ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION DISPOSAL PLAN FOR CERCLA GENERATED WASTES NUMBER OF PAGES 1 DOCUMENT NUMBER 000056



JOB NUMBER: T114

DOCUMENT DATE 03/10/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR ROBERT S. NEWTON, PROJECT COORDINATOR ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION WATER WELLS AT ELM TRAILER COURT NUMBER OF PAGES 1 DOCUMENT NUMBER 000057

DOCUMENT DATE 03/11/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR LARRY R. SOWARD, EXECUTIVE DIRECTOR1 Order number 940620-113550-ROD -001-001 page 1136 set 4 with 66 of 66 items

ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT MR. JOHN HARRISON, CITY MANAGER RECIPIENT - AFFILIATION CITY OF ODESSA, TEXAS DESCRIPTION STATUS OF INVESTIGATIONS AT ODESSA CHROMIUM I AND II NUMBER OF PAGES 3 DOCUMENT NUMBER 000058

DOCUMENT DATE 03/20/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR L. B. GRIFFITH, P.E. ORIGINATOR - AFFILIATION TEXAS DEPARTMENT OF HEALTH RECIPIENT HONORABLE JOHN MINOR RECIPIENT - AFFILIATION MAYOR OF ODESSA, TEXAS DESCRIPTION SOLID WASTE - ECTOR COUNTY NUMBER OF PAGES 1 DOCUMENT NUMBER 000059

DOCUMENT DATE 03/25/86 DOCUMENT TYPE RESOLUTION ORIGINATOR JOHN B. MINOR, MAYOR ORIGINATOR - AFFILIATION ODESSA, TEXAS, CITY COUNCIL RECIPIENT CITY COUNCIL RECIPIENT - AFFILIATION ODESSA, TEXAS DESCRIPTION AGREEMENT TO CONSIDER EXTENSION OF CITY WATER SERVICES, ETC. NUMBER OF PAGES 1 DOCUMENT NUMBER 000060



JOB NUMBER: T114

DOCUMENT DATE 04/86

DOCUMENT TYPE DRAFT REPORT ORIGINATOR I.T./HOWELL ENG. ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT U.S. E.P.A. RECIPIENT - AFFILIATION DESCRIPTION REMEDIAL INVESTIGATION - VOLUME I NUMBER OF PAGES 150 DOCUMENT NUMBER 000061

DOCUMENT DATE 04/86 DOCUMENT TYPE DRAFT REPORT ORIGINATOR I.T./HOWELL ENG. ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT U.S. E.P.A.1 Order number 940620-113550-ROD -001-001 page 1137 set 4 with 66 of 66 items

RECIPIENT - AFFILIATION DESCRIPTION REMEDIAL INVESTIGATION - VOLUME II NUMBER OF PAGES 282 DOCUMENT NUMBER 000062

DOCUMENT DATE 04/21/86 DOCUMENT TYPE TRANSMITTAL LETTER ORIGINATOR ROBERT S. NEWTON, PROJECT COORDINATOR ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION ITEM 5, REV. 2: QAPP NUMBER OF PAGES 11 DOCUMENT NUMBER 000063

DOCUMENT DATE 05/16/86 DOCUMENT TYPE MEMORANDUM ORIGINATOR OSCAR CABRA ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT CARL EDLUND RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION CHROMIUM STANDARD INQUIRY NUMBER OF PAGES 1 DOCUMENT NUMBER 000064



JOB NUMBER: T114

DOCUMENT DATE 05/28/86 DOCUMENT TYPE TRANSMITTAL AND TEST RESULTS ORIGINATOR BOB MONK ORIGINATOR - AFFILIATION I.T. CORPORATION

RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION LEACH TEST RESULTS NUMBER OF PAGES 6 DOCUMENT NUMBER 000065

DOCUMENT DATE 06/86 DOCUMENT TYPE DRAFT REPORT, REV. 1 ORIGINATOR I.T./HOWELL ENG. ORIGINATOR - AFFILIATION RECIPIENT U.S. E.P.A. RECIPIENT - AFFILIATION DESCRIPTION FOCUSED FEASIBILITY STUDY DRAFT REPORT, REV. 11 Order number 940620-113550-ROD -001-001 page 1138 set 4 with 66 of 66 items


DOCUMENT DATE 06/13/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR GREG TIPPLE ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT BILL LOCKEY RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION DELIVERY OF LETTERS TO AFFECTED INDIVIDUALS NUMBER OF PAGES 3 DOCUMENT NUMBER 000067

DOCUMENT DATE 06/18/86 DOCUMENT TYPE MEMO AND CONTAMINATED WELL INVENTORY SHEETS ORIGINATOR ROBERT S. NEWTON ORIGINATOR - AFFILIATION I. T. CORPORATION RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION MEMO AND 9/85 WELL INVENTORY DATA SHEETS NUMBER OF PAGES 53 DOCUMENT NUMBER 000068



JOB NUMBER: T114

DOCUMENT DATE 06/18/86 DOCUMENT TYPE MEMO AND LAB INFORMATION ORIGINATOR ROBERT S. NEWTON ORIGINATOR - AFFILIATION I.T. CORPORATION

RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION LAB INFORMATION ODESSA CHROMIUM I, II NUMBER OF PAGES 7 DOCUMENT NUMBER 000069

DOCUMENT DATE 07/21/86 DOCUMENT TYPE MEMORANDUM ORIGINATOR STAN HITT ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT BONNIE J. DEVOS RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION COMMENTS ON ODESSA CHROMIUM I, II -1 Order number 940620-113550-ROD -001-001 page 1139 set 4 with 66 of 66 items

FFS NUMBER OF PAGES 2 DOCUMENT NUMBER 000070

DOCUMENT DATE 08/86 DOCUMENT TYPE FINAL REPORT ORIGINATOR I.T./HOWELL ENG. ORIGINATOR - AFFILIATION RECIPIENT U.S. E.P.A. RECIPIENT - AFFILIATION DESCRIPTION FOCUSED FEASIBILITY STUDY - FINAL REPORT NUMBER OF PAGES 247 DOCUMENT NUMBER 000071

DOCUMENT DATE 08/13/86 DOCUMENT TYPE TRANSCRIPT ORIGINATOR INTERNATIONAL LITIGATION SERVICES, INC. ORIGINATOR - AFFILIATION RECIPIENT U.S. E.P.A. RECIPIENT - AFFILIATION DESCRIPTION 08/13/86 - PUBLIC MEETING NUMBER OF PAGES 67 DOCUMENT NUMBER 000072



JOB NUMBER: T114

DOCUMENT DATE 08/20/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR J. H. GRIFFIN ORIGINATOR - AFFILIATION RESIDENT OF ODESSA, TEXAS

RECIPIENT CARL E. EDLUND RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION LETTER AND ANALYSIS OF WELL WATER AT RESIDENCE NUMBER OF PAGES 2 DOCUMENT NUMBER 000073

DOCUMENT DATE 08/21/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR LARRY R. SOWARD, EXECUTIVE DIRECTOR ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT DICK WHITTINGTON RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION NO OBJECTION TO E.P.A.'S SELECTION1 Order number 940620-113550-ROD -001-001 page 1140 set 4 with 66 of 66 items

OF PROPOSED REMEDY NUMBER OF PAGES 1 DOCUMENT NUMBER 000074

DOCUMENT DATE 08/21/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR GREG TIPPLE ORIGINATOR - AFFILIATION TX WATER COMMISSION RECIPIENT MRS. DALE MEYER RECIPIENT - AFFILIATION RESIDENT OF ODESSA, TX DESCRIPTION GUIDELINES FOR PLUGGING OF WELLS NUMBER OF PAGES 3 DOCUMENT NUMBER 000075

DOCUMENT DATE 08/25/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR MR. AND MRS. CARL OVERTON ORIGINATOR - AFFILIATION RESIDENTS OF ODESSA, TX RECIPIENT U.S. E.P.A. RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION OPPOSITION TO ANNEXATION INTO CITY LIMITS NUMBER OF PAGES 1 DOCUMENT NUMBER 000076



JOB NUMBER: T114

DOCUMENT DATE 08/25/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR MRS. TRUMAN FOX ORIGINATOR - AFFILIATION RESIDENT OF ODESSA, TX RECIPIENT U.S. E.P.A.

RECIPIENT - AFFILIATION DESCRIPTION OPPOSITION TO ANNEXATION INTO CITY LIMITS NUMBER OF PAGES 1 DOCUMENT NUMBER 000077

DOCUMENT DATE 08/27/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR DALE MEYER ORIGINATOR - AFFILIATION RESIDENT/BUSINESSMAN OF ODESSA, TEXAS RECIPIENT MR. BILL LOCKEY RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION PROTEST OF PROPOSED REMEDIAL1 Order number 940620-113550-ROD -001-001 page 1141 set 4 with 66 of 66 items

ALTERNATIVES ANALYSIS NUMBER OF PAGES 1 DOCUMENT NUMBER 000078

DOCUMENT DATE 08/27/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR THOMAS TAYLOR ORIGINATOR - AFFILIATION RESIDENT OF ODESSA, TEXAS RECIPIENT MR. BILL LOCKEY RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION PROTEST OF ANNEXATION INTO CITY LIMITS NUMBER OF PAGES 1 DOCUMENT NUMBER 000079

DOCUMENT DATE 08/27/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR RICHARD H. FULLER ORIGINATOR - AFFILIATION ERM - SOUTHWEST, INC. RECIPIENT DIANA HINDS RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION COMMENTS ON THE ODESSA CHROMIUM II - FFS NUMBER OF PAGES 8 DOCUMENT NUMBER 000080



JOB NUMBER: T114

DOCUMENT DATE 08/29/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR JAMES L. TURNER ORIGINATOR - AFFILIATION U.S. E.P.A.

RECIPIENT PAUL D. EVANS, LIQUIDATION ASSISTANT RECIPIENT - AFFILIATION F.D.I.C. DESCRIPTION CHROMIUM CONTAMINATION AT B&W WELDING NUMBER OF PAGES 2 DOCUMENT NUMBER 000081

DOCUMENT DATE 09/08/86 DOCUMENT TYPE REPORT ORIGINATOR DICK WHITTINGTON ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT RECIPIENT - AFFILIATION DESCRIPTION ROD - REMEDIAL ALTERNATIVE SELECTION1 Order number 940620-113550-ROD -001-001 page 1142 set 4 with 66 of 66 items


DOCUMENT DATE 09/18/86 DOCUMENT TYPE CORRESPONDENCE AND COMMENTS ORIGINATOR RICHARD H. FULLER ORIGINATOR - AFFILIATION ERM - SOUTHWEST, INC. RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION RE: FOCUSED FEASIBILITY STUDIES NUMBER OF PAGES 16 DOCUMENT NUMBER 000083

DOCUMENT DATE 09/19/86 DOCUMENT TYPE TRANSMITTAL LETTER ORIGINATOR ROBERT S. NEWTON, PROJECT COORDINATOR ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION ADDITIONAL WORK TASKS NUMBER OF PAGES 13 DOCUMENT NUMBER 000084



JOB NUMBER: T114

DOCUMENT DATE 09/30/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR ROBERT S. NEWTON, PROJECT COORDINATOR ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT GREG TIPPLE

RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION RESPONSE TO COMMENT ON PIPE SIZING NUMBER OF PAGES 2 DOCUMENT NUMBER 000085

DOCUMENT DATE 09/30/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR JAMES B. HARRIS ORIGINATOR - AFFILIATION THOMPSON & KNIGHT, ATTORNEYS RECIPIENT ALLYN M. DAVIS RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION OBJECTIONS TO E.P.A. RESPONSIVENESS SUMMARY NUMBER OF PAGES 81 Order number 940620-113550-ROD -001-001 page 1143 set 4 with 66 of 66 items


DOCUMENT DATE 10/10/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR GREG TIPPLE ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT BOB DICKERSON, MANAGER RECIPIENT - AFFILIATION WOOLEY TOOL AND MANU. DIV. DESCRIPTION ACCESS AGREEMENT NUMBER OF PAGES 4 DOCUMENT NUMBER 000087

DOCUMENT DATE 10/14/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR GREG TIPPLE ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT J&R INDUSTRIES RECIPIENT - AFFILIATION DESCRIPTION MONITOR WELL ACCESS AGREEMENT NUMBER OF PAGES 3 DOCUMENT NUMBER 000088



JOB NUMBER: T114

DOCUMENT DATE 10/14/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR GREG TIPPLE ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT BOWDEN CONSTRUCTION CO. RECIPIENT - AFFILIATION DESCRIPTION MONITOR WELL ACCESS AGREEMENT NUMBER OF PAGES 5


DOCUMENT DATE 10/15/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR CARL E. EDLUND ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT JAMES B. HARRIS RECIPIENT - AFFILIATION THOMPSON & KNIGHT, ATTORNEYS DESCRIPTION RESPONSE TO 09/30/86 LETTER (ALSO ATTACHED) NUMBER OF PAGES 11 DOCUMENT NUMBER 000090

DOCUMENT DATE 10/15/861 Order number 940620-113550-ROD -001-001 page 1144 set 4 with 66 of 66 items

DOCUMENT TYPE CORRESPONDENCE ORIGINATOR STANLEY G. HITT ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT GERALD K. FUGITT RECIPIENT - AFFILIATION ATTORNEY DESCRIPTION CHROMIUM SOURCES NUMBER OF PAGES 4 DOCUMENT NUMBER 000091

DOCUMENT DATE 10/16/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR GREG TIPPLE ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT VERN FOREMAN RECIPIENT - AFFILIATION FOREMAN ELECTRIC CO. DESCRIPTION ACCESS AGREEMENT NUMBER OF PAGES 2 DOCUMENT NUMBER 000092



JOB NUMBER: T114

DOCUMENT DATE 10/16/86 DOCUMENT TYPE MEMORANDUM ORIGINATOR JEFFREY A. LYBARGER, M.D. ORIGINATOR - AFFILIATION ATSDR RECIPIENT CARL HICKAM, PUBLIC HEALTH ADVISOR RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION HEALTH ASSESSMENT CLARIFICATION NUMBER OF PAGES 2 DOCUMENT NUMBER 000093


DOCUMENT TYPE CORRESPONDENCE ORIGINATOR GREG TIPPLE ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT JERRY HUCKABY, PRESIDENT RECIPIENT - AFFILIATION BASIN RADIATOR & SUPPLY DESCRIPTION ACCESS AGREEMENT NUMBER OF PAGES 2 DOCUMENT NUMBER 000094

DOCUMENT DATE 10/23/86 DOCUMENT TYPE ADDENDUM TO SAMPLING PLAN REV. 2 ORIGINATOR ROBERT S. NEWTON ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT GREG TIPPLE1 Order number 940620-113550-ROD -001-001 page 1145 set 4 with 66 of 66 items

RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION SITE INVESTIGATION AND FEASIBILITY STUDIES NUMBER OF PAGES 3 DOCUMENT NUMBER 000095

DOCUMENT DATE 12/16/86 DOCUMENT TYPE MEMORANDUM ORIGINATOR JIM MCGUIRE ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT CARL HICKAM - ATSDR RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION ODESSA CHROMIUM I AND II SITES NUMBER OF PAGES 5 DOCUMENT NUMBER 000096



JOB NUMBER: T114

DOCUMENT DATE 12/22/86 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR GREG TIPPLE ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT DANNY PATEL, MANAGER, SUNDOWN MOTEL RECIPIENT - AFFILIATION ODESSA BUSINESSMAN DESCRIPTION WATER WELL CHROMIUM CONTAMINATION NUMBER OF PAGES 4 DOCUMENT NUMBER 000097

DOCUMENT DATE 12/31/86 DOCUMENT TYPE MEMORANDUM ORIGINATOR JIM MCGUIRE ORIGINATOR - AFFILIATION U.S. E.P.A.

RECIPIENT FILE RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION FS OBJECTIVES NUMBER OF PAGES 4 DOCUMENT NUMBER 000098

DOCUMENT DATE 01/21/87 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR GREG TIPPLE ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT ROBERT MONK, PROJECT COORDINATOR RECIPIENT - AFFILIATION I.T. CORPORATION DESCRIPTION WASTE CLASSIFICATION NUMBER OF PAGES 11 Order number 940620-113550-ROD -001-001 page 1146 set 4 with 66 of 66 items


DOCUMENT DATE 02/03/87 DOCUMENT TYPE MEMORANDUM ORIGINATOR STANLEY G. HITT ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION CLARIFY IMPACT OF S.A.R.A. NUMBER OF PAGES 2 DOCUMENT NUMBER 000100



JOB NUMBER: T114

DOCUMENT DATE 02/06/87 DOCUMENT TYPE MEMORANDUM ORIGINATOR CARL R. HICKAM ORIGINATOR - AFFILIATION ATSDR RECIPIENT JIM MCGUIRE RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION DRAFT INTERIM HEALTH ASSESSMENT NUMBER OF PAGES 2 DOCUMENT NUMBER 000101

DOCUMENT DATE 02/24/87 DOCUMENT TYPE MEMORANDUM ORIGINATOR JIM MCGUIRE ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT FILE RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION SCOPE OF WORK REVISIONS NUMBER OF PAGES 2


DOCUMENT DATE 02/24/87 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR ALAN D. HUSAK, PROJECT MANAGER ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION FINALIZATION OF OBJECTIVES AND CRITERIA NUMBER OF PAGES 3 DOCUMENT NUMBER 000103

DOCUMENT DATE 02/24/871 Order number 940620-113550-ROD -001-001 page 1147 set 4 with 66 of 66 items

DOCUMENT TYPE MEMORANDUM AND SCOPE OF WORK ORIGINATOR ALAN D. HUSAK, PROJECT MANAGER ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT GREG TIPPLE RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION IMPACT OF S.A.R.A. ON REMAINING PORTION FS NUMBER OF PAGES 19 DOCUMENT NUMBER 000104



JOB NUMBER: T114

DOCUMENT DATE 02/27/87 DOCUMENT TYPE MEMORANDUM AND ATTACHED SURVEY FORM ORIGINATOR BONNIE J. DEVOS ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT DAVID SORRELLS RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION I.T. SURVEY NUMBER OF PAGES 2 DOCUMENT NUMBER 000105

DOCUMENT DATE 03/27/87 DOCUMENT TYPE MEMORANDUM ORIGINATOR CARL S. HICKAM ORIGINATOR - AFFILIATION ATSDR RECIPIENT JIM MCGUIRE RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION HEALTH ASSESSMENT NUMBER OF PAGES 2 DOCUMENT NUMBER 000106

DOCUMENT DATE 04/24/87 DOCUMENT TYPE RECORD OF COMMUNICATION ORIGINATOR JIM MCGUIRE ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT ROBIE HIRT RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION REQUEST THAT TWC PRIORITIZE PROJECT NUMBER OF PAGES 1 DOCUMENT NUMBER 000107

DOCUMENT DATE 05/87 DOCUMENT TYPE SCOPE OF WORK ORIGINATOR TEXAS WATER COMMISSION ORIGINATOR - AFFILIATION1 Order number 940620-113550-ROD -001-001 page 1148 set 4 with 66 of 66 items

RECIPIENT I.T. CORPORATION RECIPIENT - AFFILIATION DESCRIPTION PRICE SUMMARY FORMAT FOR SUBAGREEMENTS NUMBER OF PAGES 7 DOCUMENT NUMBER 000108



JOB NUMBER: T114

DOCUMENT DATE 05/06/87 DOCUMENT TYPE CORRESPONDENCE AND LABORATORY SUMMARIES ORIGINATOR ROBERT G. MONK, PROJECT COORDINATOR ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT PATRICIA CURL RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION LAB INFORMATION AND ADDITIONAL WORK TASKS NUMBER OF PAGES 9 DOCUMENT NUMBER 000109

DOCUMENT DATE 05/06/87 DOCUMENT TYPE TRANSMITTAL ORIGINATOR ROBERT G. MONK, PROJECT COORDINATOR ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT PATRICIA CURL RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION FINAL SCOPE OF WORK REMAINING PORTION - FS NUMBER OF PAGES 12 DOCUMENT NUMBER 000110

DOCUMENT DATE 05/07/87 DOCUMENT TYPE REPORT ORIGINATOR ALAN D. HUSAK, PROJECT MANAGER ORIGINATOR - AFFILIATION I. T. CORPORATION RECIPIENT PATRICIA CURL RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION TECHNOLOGY SCREENING REMAINING PORTION - FS NUMBER OF PAGES 13 DOCUMENT NUMBER 000111

DOCUMENT DATE 05/18/87 DOCUMENT TYPE MEMORANDUM ORIGINATOR JIM MCGUIRE1 Order number 940620-113550-ROD -001-001 page 1149 set 4 with 66 of 66 items

ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT JIM STEED RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION CONDITIONAL APPROVAL OF SOW NUMBER OF PAGES 1 DOCUMENT NUMBER 000112



JOB NUMBER: T114

DOCUMENT DATE 05/22/87 DOCUMENT TYPE MEMORANDUM ORIGINATOR ALAN D. HUSAK ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT PATRICIA CURL RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION REMEDIAL ALTERNATIVES DEVELOPMENT NUMBER OF PAGES 3 DOCUMENT NUMBER 000113

DOCUMENT DATE 06/87 DOCUMENT TYPE FINAL REPORT ORIGINATOR I.T./HOWELL ENG. ORIGINATOR - AFFILIATION RECIPIENT U.S. E.P.A. RECIPIENT - AFFILIATION DESCRIPTION REMEDIAL INVESTIGATION - VOLUME I NUMBER OF PAGES 196 DOCUMENT NUMBER 000114

DOCUMENT DATE 06/87 DOCUMENT TYPE FINAL REPORT ORIGINATOR I.T./HOWELL ENG.

ORIGINATOR - AFFILIATION RECIPIENT U.S. E.P.A. RECIPIENT - AFFILIATION DESCRIPTION REMEDIAL INVESTIGATION - VOLUME I NUMBER OF PAGES 208 DOCUMENT NUMBER 000115

DOCUMENT DATE 06/87 DOCUMENT TYPE FINAL REPORT ORIGINATOR I.T./HOWELL ENG. ORIGINATOR - AFFILIATION RECIPIENT U.S. E.P.A. RECIPIENT - AFFILIATION DESCRIPTION REMEDIAL INVESTIGATION - VOLUME III1 Order number 940620-113550-ROD -001-001 page 1150 set 4 with 66 of 66 items




JOB NUMBER: T114

DOCUMENT DATE 06/25/87 DOCUMENT TYPE QUESTIONNAIRE ORIGINATOR U.S. E.P.A. ORIGINATOR - AFFILIATION RECIPIENT RESIDENTS OF SUPERFUND-IMPACTED AREA RECIPIENT - AFFILIATION DESCRIPTION SURVEY OF RESIDENCES/BUSINESSES IN SUPERFUND-IMPACTED AREAS NUMBER OF PAGES 93 DOCUMENT NUMBER 000117

DOCUMENT DATE 06/29/87 DOCUMENT TYPE RECORD OF COMMUNICATION ORIGINATOR MARK FITE/JIM MCGUIRE ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT I.T./HOWELL ENG. RECIPIENT - AFFILIATION DESCRIPTION DISCUSS RESULTS OF OWNER/TENANT SURVEY AND SOW FOR DESIGN OF WATER SYSTEM NUMBER OF PAGES 2 DOCUMENT NUMBER 000118

DOCUMENT DATE 07/07/87 DOCUMENT TYPE MEMO AND SOW REMAINING PORTION FS ORIGINATOR LARRY R. SOWARD, EXECUTIVE DIRECTOR ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION

RECIPIENT ALAN D. HUSAK, PROJECT MANAGER RECIPIENT - AFFILIATION I.T. CORPORATION DESCRIPTION NECESSARY CHANGES TO SOW NUMBER OF PAGES 24 DOCUMENT NUMBER 000119

DOCUMENT DATE 07/08/87 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR ROBERT G. MONK, PROJECT COORDINATOR ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT PATRICIA CURL RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION REMEDIAL ALTERNATIVES - REMAINING PORTION - FS1 Order number 940620-113550-ROD -001-001 page 1151 set 4 with 66 of 66 items




JOB NUMBER: T114

DOCUMENT DATE 07/17/87 DOCUMENT TYPE RECORD OF COMMUNICATION ORIGINATOR MARK FITE/JIM MCGUIRE/STAN HITT ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT I.T./HOWELL ENG. RECIPIENT - AFFILIATION DESCRIPTION ODESSA AWS REMEDIAL DESIGN AND SURVEY RESULTS NUMBER OF PAGES 1 DOCUMENT NUMBER 000121

DOCUMENT DATE 07/21/87 DOCUMENT TYPE SURVEY SUMMARY AND SITE SURVEY QUESTIONNAIRES ORIGINATOR ROBERT G. MONK, PROJECT COORDINATOR ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT JIM MCGUIRE RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION SURVEY SUMMARY AND SITE SURVEY QUESTIONNAIRES NUMBER OF PAGES 33 DOCUMENT NUMBER 000122

DOCUMENT DATE 07/24/87 DOCUMENT TYPE TRANSMITTAL MEMO AND WATER DESIGN SCOPE OF WORK ORIGINATOR ROBERT G. MONK, PROJECT COORDINATOR

ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT JIM STEED RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION SCOPE OF WORK - WATER SYSTEM DESIGN NUMBER OF PAGES 21 DOCUMENT NUMBER 000123

DOCUMENT DATE 07/31/87 DOCUMENT TYPE MEMORANDUM AND ATTACHMENTS ORIGINATOR CARL EDLUND ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT DAVID SORRELLS RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION SOW WATER DESIGN COSTS/SCHEDULE1 Order number 940620-113550-ROD -001-001 page 1152 set 4 with 66 of 66 items

EXCESSIVE NUMBER OF PAGES 13 DOCUMENT NUMBER 000124



JOB NUMBER: T114

DOCUMENT DATE 08/05/87 DOCUMENT TYPE MEMORANDUM AND ATTACHMENTS ORIGINATOR PATRICIA CURL ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT ROBERT G. MONK, PROJECT COORDINATOR RECIPIENT - AFFILIATION I.T. CORPORATION DESCRIPTION USE OF POTW INAPPROPRIATE NUMBER OF PAGES 9 DOCUMENT NUMBER 000125

DOCUMENT DATE 08/05/87 DOCUMENT TYPE COST BREAKDOWN ORIGINATOR I.T. CORPORATION ORIGINATOR - AFFILIATION RECIPIENT U.S. E.P.A. RECIPIENT - AFFILIATION DESCRIPTION COST BREAKDOWN ODESSA CHROMIUM I, II NUMBER OF PAGES 8 DOCUMENT NUMBER 000126

DOCUMENT DATE 08/14/87 DOCUMENT TYPE CORRESPONDENCE ORIGINATOR DAVID SORRELLS ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT CARL EDLUND RECIPIENT - AFFILIATION U.S. E.P.A.

DESCRIPTION REBUTTAL OF EDLUND'S 07/31/87 MEMO RE: EXCESSIVE COSTS NUMBER OF PAGES 2 DOCUMENT NUMBER 000127

DOCUMENT DATE 08/18/87 DOCUMENT TYPE CORRESPONDENCE AND ATTACHMENT ORIGINATOR ROBERT G. MONK, PROJECT COORDINATOR ORIGINATOR - AFFILIATION I.T. CORPORATION RECIPIENT JIM STEED RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION REV. 1, SOW ALTERNATE WATER SYSTEM DESIGN NUMBER OF PAGES 191 Order number 940620-113550-ROD -001-001 page 1153 set 4 with 66 of 66 items




JOB NUMBER: T114

DOCUMENT DATE 08/19/87 DOCUMENT TYPE RECORD OF COMMUNICATION ORIGINATOR JIM STEED/ALEX ONJANOW ORIGINATOR - AFFILIATION TEXAS WATER COMMISSION RECIPIENT JIM MCGUIRE RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION DISCUSS THE RD FOR PHASE 2 OF ODESSA AWS DESIGN NUMBER OF PAGES 2 DOCUMENT NUMBER 000129

DOCUMENT DATE 08/20/87 DOCUMENT TYPE RECORD OF COMMUNICATION ORIGINATOR BONNIE DEVOS ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT MARK FITE RECIPIENT - AFFILIATION U.S. E.P.A. DESCRIPTION PHASE 2 RD FOR ODESSA I AND II AWS NUMBER OF PAGES 1 DOCUMENT NUMBER 000130

DOCUMENT DATE 08/24/87 DOCUMENT TYPE RECORD OF COMMUNICATION ORIGINATOR MARK FITE ORIGINATOR - AFFILIATION U.S. E.P.A. RECIPIENT JIM STEED RECIPIENT - AFFILIATION TEXAS WATER COMMISSION DESCRIPTION ODESSA AWS PHASE 2 DESIGN

NUMBER OF PAGES 1 DOCUMENT NUMBER 000131.

ATTACHMENT B

ATSDR HEALTH ASSESSMENT

DEPARTMENT OF HEALTH & HUMAN SERVICES

MEMORANDUM

SUBJECT: HEALTH ASSESSMENT ODESSA CHROMIUM I & II (SI-87-084)1 Order number 940620-113550-ROD -001-001 page 1154 set 4 with 66 of 66 items

ODESSA, TEXAS

FROM: SENIOR PUBLIC HEALTH ADVISOR AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY REGIONAL OFFICE FOR HEALTH RESPONSE

TO: MR. JIM MCGUIRE TEXAS REMEDIAL SECTION (6H-ST)

DATE: MARCH 27, 1987

STATEMENT OF PROBLEM

THE ENVIRONMENTAL PROTECTION AGENCY (EPA), REGION VI OFFICE, HAS ASKED THE AGENCY FOR TOXIC SUBSTANCES AND DISEASE REGISTRY (ATSDR) TO REVIEW RECENT SOIL DATA FROM THE ODESSA CHROMIUM SITES AND TO RE-EVALUATE OUR EARLIER RECOMMENDATION THAT DIRECT CONTACT WITH THE SOIL BE LIMITED.

LIST OF DOCUMENTS REVIEWED

1. MEMORANDUM FROM JIM MCGUIRE, EPA REGION 6, TO CARL HICKAM, ATSDR, REGARDING ODESSA CHROMIUM I AND II SITES. DECEMBER 18, 1986.

2. DATA FROM REMEDIAL INVESTIGATION FOR ODESSA CHROMIUM I. FIGURES 4-2 AND 4-2A, TABLES 5-4 AND 5-4A, AND PAGES 5-3.

3. ATSDR FILE ON ODESSA CHROMIUM I AND II.

DISCUSSION

THE ODESSA CHROMIUM I AND II SITES CONSIST OF SEVERAL INDUSTRIAL PROPERTIES IN NORTHWEST ODESSA, TEXAS, THAT ARE CONTAMINATED WITH METAL PLATING WASTES. IN JUNE-JULY 1983 FOUR SOIL SAMPLES WERE COLLECTED AT THE ODESSA CHROMIUM I SITE THAT RANGED FROM 2,000 TO 20,000 PPM TOTAL CHROMIUM. THE SAMPLES WERE NOT TESTED FOR HEXAVALENT CHROMIUM. BASED ON THIS DATA, ATSDR RECOMMENDED THAT DIRECT CONTACT WITH THE

CONTAMINATED SOIL BE LIMITED.

PHASE II ANALYTICAL RESULTS FROM SOIL BORINGS AT FIVE OF THE PROPERTIES INVOLVED HAVE BEEN SENT TO ATSDR. THE TABLE BELOW SUMMARIZES THE TOTAL CHROMIUM DATA.

TOTAL SAMPLE NUMBER OF LOCATION CHROMIUM DEPTH SAMPLES (MG./KG.) (FT.)

4318 BRAZOS 1311 0-2.5 7 MERIDIAN OIL 367 0-2.5 10 BASIN RADIATOR 162 0-2 3 WOOLEY TOOL 178 0-2 21 Order number 940620-113550-ROD -001-001 page 1155 set 4 with 66 of 66 items

NDT/FOREMAN ELECTRIC 22 0-2 2.

IF THE TOTAL CHROMIUM LEVELS REPORTED FOR THE TOP SOIL BORING FRACTIONS� ARE REPRESENTATIVE OF THE MATERIAL AT THE SOIL SURFACE, THESE LEVELS D NOT POSE A SIGNIFICANT THREAT TO HUMAN HEALTH BY DIRECT CONTACT WITH, OR INGESTION OF, THE CONTAMINATED SOIL, EVEN IF ALL THE CHROMIUM WERE IN THE HEXAVALENT FORM.

EPA IS CURRENTLY INVESTIGATING THE AIRBORNE PATHWAY FOR THE METALS FOUND AT THE SITES. WE SUPPORT THIS EFFORT BECAUSE BOTH NICKEL AND HEXAVALENT CHROMIUM ARE CARCINOGENS VIA THE INHALATION EXPOSURE ROUTE.

EPA HAS PREVIOUSLY IDENTIFIED CHROMIUM CONTAMINATION OF DRINKING WATER WELLS AND IS PLANNING ACTION TO REMOVE THIS EXPOSURE.

RECOMMENDATIONS

1. DIRECT CONTACT WITH THE ON-SITE SOIL DOES NOT NEED TO BE LIMITED.

2. IN FUTURE SITUATIONS WHERE DIRECT CONTACT WITH SOIL IS A POTENTIAL HEALTH CONCERN, SAMPLES SHOULD BE TAKEN AT THE SURFACE, RATHER THAN FROM A BORING.

3. HEXAVALENT CHROMIUM DATA SHOULD BE USED IN THE EVALUATION OF THE AIRBORNE EXPOSURE PATHWAY, SINCE HEXAVALENT CHROMIUM IS A CARCINOGEN VIA INHALATION.

4. WHERE THE AVERAGE TOTAL CHROMIUM LEVELS IN SURFACE SOIL ARE GREATER THAN 3,000 MG./KG., AND SOIL INGESTION IS A POTENTIAL PATHWAY FOR HUMAN EXPOSURE, THE SAMPLES SHOULD BE ANALYZED FOR HEXAVALENT CHROMIUM.

WE HOPE THIS INFORMATION IS USEFUL TO YOU IN YOUR ENDEAVORS AT THIS SITE.

REVIEWER:

RALPH O'CONNER

CARL R. HICKAM, R.S.

#RS

ATTACHMENT C

COMMUNITY RELATIONS/PUBLIC COMMENTS

ODESSA CHROMIUM I AND ODESSA CHROMIUM II SITES1 Order number 940620-113550-ROD -001-001 page 1156 set 4 with 66 of 66 items

RESPONSIVENESS SUMMARY

THIS COMMUNITY RELATIONS RESPONSIVENESS SUMMARY IS DIVIDE INTO TWO SECTIONS:

SECTION I: BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERN.

THIS SECTION PROVIDES A BRIEF HISTORY OF COMMUNITY INTEREST AND CONCERN RAISED DURING THE REMEDIAL PLANNING ACTIVITIES AT THE ODESSA CHROMIUM I AND ODESSA CHROMIUM II SUPERFUND SITES.

SECTION II: SUMMARY OF MAJOR COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND THE EPA RESPONSES TO THE COMMENTS.

BOTH WRITTEN AND SPOKEN COMMENTS ARE CATEGORIZED BY TOPICS. EPA RESPONSES TO THESE RELEVANT MAJOR TOPICS ARE ALSO PRESENTED.

1. BACKGROUND ON COMMUNITY INVOLVEMENT

THE FINAL FEASIBILITY STUDY ON THE PROPOSED REMEDIAL ALTERNATIVES FOR THE GROUNDWATER WAS SUBMITTED TO THE EPA IN DECEMBER 1987. THE EPA ISSUED A NEWS RELEASE ON DECEMBER 24, 1987, ANNOUNCING THE AVAILABILITY OF THE FEASIBILITY STUDY AND EPA'S PREFERRED ALTERNATIVE AND INVITED PEOPLE TO AN "OPEN HOUSE" ON JANUARY 5, 1988. THE OPEN HOUSE, WHICH WAS HELD AT THE ODESSA CITY HALL, SERVED TO PRESENT THE ALTERNATIVES TO CITY OFFICIALS AND INTERESTED CITIZENS AND ANSWER THEIR QUESTIONS.

AN EPA PREPARED FACT SHEET WHICH DESCRIBED ALTERNATIVE CLEAN UP PLANS, ALONG WITH THE EPA PREFERRED REMEDY WAS MAILED TO THE INTERESTED AND AFFECTED PUBLIC ON JANUARY 4, 1988. THE FACT SHEET GAVE A BRIEF SITE HISTORY, DESCRIBED THE SUPERFUND PROCESS AND THE CLEANUP ALTERNATIVES, PROVIDED DETAILS ABOUT THE PUBLIC COMMENT PERIOD AND THE PUBLIC MEETING TO BE HELD ON JANUARY 21, 1988.

ON JANUARY 21, 1988, AT 7:00 P.M. THE EPA AND THE TWC STAFF CONDUCTED A PUBLIC MEETING AT THE ODESSA CITY COUNCIL CHAMBER TO BRIEF THE CITIZENS ON THE STUDY FINDINGS, REVIEW THE ALTERNATIVES CONSIDERED; DESCRIBE THE EPA'S PREFERRED REMEDY, ANSWERED QUESTIONS, AND RECEIVED COMMENTS ON EPA'S PREFERRED REMEDY. TWENTY-ONE PEOPLE ATTENDED THIS MEETING.

THE PUBLIC COMMENT PERIOD BEGAN ON JANUARY 8, 1988, AND WAS TO END FEBRUARY 8, 1988. AN EXTENSION WAS REQUESTED AND GRANTED BY EPA WHICH EXTENDED THE COMMENT PERIOD UNTIL FEBRUARY 15, 1988.

SUMMARY OF PUBLIC COMMENTS RECEIVED DURING PUBLIC COMMENT PERIOD AND AGENCY RESPONSES1 Order number 940620-113550-ROD -001-001 page 1157 set 4 with 66 of 66 items

A SUMMARY OF THE COMMENTS PROVIDED DURING THE COMMENT PERIOD IS PROVIDED BELOW.

COMMENT #1

WHICH GROUNDWATER TREATMENT PROCESS COULD CAUSE AN INCREASE IN THE TOTAL DISSOLVED SOLIDS OF THE GROUNDWATER?


STUDIES CONDUCTED FOR THE CHEMICAL TREATMENT SYSTEM INDICATE AN INCREASE OF TOTAL DISSOLVED SOLIDS IN THE GROUNDWATER IS POSSIBLE AT BOTH THE ODESSA CHROMIUM I AND II SITES. THE AVERAGE INCREASE EXPERIENCED DURING THE TESTS AT BOTH SITES WAS 530 PPM. ALTHOUGH THIS INCREASE IN DISSOLVED SOLIDS IS NOT CONSIDERED A HEALTH THREAT, IT MAY EFFECT THE SECONDARY QUALITY OF THE GROUNDWATER (TASTE, ODOR, COLOR).

COMMENT #2

WHAT IS THE PROBABILITY THAT THE TREATMENT OF THE GROUNDWATER USING THE ELECTROCHEMICAL SYSTEM WILL BE COMPLETED WITHIN 5 YEARS OF SYSTEM START-UP (1996 FOR ODESSA I AND 1997 FOR ODESSA II)?


THE 5 YEAR COMPLETION DATE ARE ESTIMATES BASED ON PREVIOUS EXPERIENCE WITH THE ELECTROCHEMICAL TREATMENT SYSTEM. THE SCHEDULES ARE CONTINGENT UPON AVAILABLE FUNDING AS WELL AS MINIMAL DELAYS ASSOCIATED WITH THE DESIGN, CONSTRUCTION, AND OPERATION OF THE TREATMENT SYSTEM. THE SYSTEM WILL CONTINUE TO OPERATE UNTIL THE FEDERAL REGULATED DRINKING WATER STANDARD FOR CHROMIUM IS ATTAINED.

COMMENT #3

WILL THE ELECTROCHEMICAL TREATMENT OF THE CHROMIUM CONTAMINATED GROUNDWATER GENERATE A HAZARDOUS RESIDUE?


NO. DURING THE TREATMENT PROCESS, UP TO THIRTY-EIGHT (38) TONS OF TREATMENT RESIDUE WILL BE PRECIPITATED PER YEAR. THE RESIDUE WILL CONTAIN FERRIC HYDROXIDE AND CHROMIC HYDROXIDE. THE TREATMENT RESIDUE IS EXPECTED TO BE NONHAZARDOUS. LABORATORY TESTING OF THE MATERIAL WILL BE PERFORMED FOR VERIFICATION. SHOULD THE TESTING CONFIRM THE RESIDUE IS NONHAZARDOUS, IT MAY BE DISPOSED OF AT A NONHAZARDOUS INDUSTRIAL DISPOSAL FACILITY; OTHERWISE, THE MATERIAL WILL BE DISPOSED AS HAZARDOUS WASTE.


COMMENT #4

WILL THE ENVIRONMENTAL PROTECTION AGENCY BE CONDUCTING A CLEAN-UP ACTION FOR THE CHROMIUM CONTAMINATED SOILS AT THE SITES?


NO. THE REMEDIAL INVESTIGATION FOUND THAT THE SOILS CONTAIN TRIVALENT CHROMIUM RATHER THAN THE MORE TOXIC AND MOBILE HEXAVALENT FORM OF CHROMIUM NOW PRESENT IN THE GROUNDWATER. A SITE SPECIFIC RISK ASSESSMENT CONDUCTED DURING THE INVESTIGATION DETERMINED THE PRESENT LEVELS OF CHROMIUM IN THE SOIL WOULD NOT POSE A SIGNIFICANT HEALTH THREAT TO NEARBY RESIDENTS OR WORKERS. IN ADDITION, LEACH TESTS CONDUCTED DURING THE INVESTIGATION SHOWED THE CHROMIUM WAS TIGHTLY BOUND TO THE SOILS; THEREFORE, WOULD NOT CAUSE FURTHER DEGRADATION OF THE GROUNDWATER. SINCE THE CHROMIUM CONTAMINATED SOIL IS NEITHER A HEALTH THREAT NOR A POTENTIAL SOURCE OF CONTAMINANT MIGRATION, A REMEDIAL ACTION OF THE SOIL IS NOT NECESSARY TO PROTECT HUMAN HEALTH OR THE ENVIRONMENT.

COMMENT #5

THE MOST LOGICAL PLAN FOR RESOLVING THE PROBLEM AT THE ODESSA CHROMIUM II SITE WOULD BE TO PROVIDE THE AREA WITH CITY WATER AND TO TAKE NO FURTHER ACTION SINCE THE CHROMIUM IN THE GROUNDWATER WILL NATURALLY DILUTE TO BELOW DRINKING WATER STANDARDS WITHIN 5 TO 10 YEARS.


WE DISAGREE. BASED ON COMPUTER SIMULATIONS OF THE "NO ACTION" REMEDY, THE CHROMIUM PLUMES AT THE ODESSA II SITE ARE PREDICTED TO MIGRATE TO THE SOUTHWEST AT A RATE OF 0.1 TO 0.3 FEET PER DAY. THE SOUTHERN PLUME WILL MIGRATE AN ESTIMATED 600 FEET AND THE NORTHERN PLUME APPROXIMATELY 1,600 FEET WITHIN 15 YEARS. THE CHROMIUM CONCENTRATIONS WILL DISSIPATE AS THE PLUME EXPANDS GIVEN THERE ARE

NO MORE RELEASES TO THE GROUNDWATER; HOWEVER, WELLS WITHIN THE AREA ARE EXPECTED TO STILL HAVE CHROMIUM LEVELS ABOVE THE CURRENT FEDERAL DRINKING WATER STANDARD EVEN AFTER 15 YEARS OF NATURAL DILUTION.

IN ORDER TO PREVENT POTENTIAL EXPOSURE THROUGH FUTURE CONSUMPTION OF THE CONTAMINATED GROUNDWATER, A WATER SUPPLY SYSTEM WOULD REQUIRE CONTINUED EXTENSION AS THE PLUMES MIGRATE BEYOND THE CURRENT IMPACTED AREAS. PROTECTION CAN BE ACHIEVED ONLY IF ALL PERSONS WITHIN THE EXPANDING IMPACTED AREAS ELECT TO CONNECT WITH THE SYSTEM AND IF EFFECTIVE INSTITUTIONAL CONTROLS ARE IMPLEMENTED. SINCE CONNECTION WITH THE ALTERNATE WATER SUPPLY SYSTEM IS VOLUNTARY AND THE EFFECTIVENESS OF INSTITUTIONAL CONTROLS IS UNCERTAIN; PROTECTION OF HUMAN HEALTH CANNOT BE ASSURED. THE SELECTED ELECTROCHEMICAL TREATMENT SYSTEM WILL INSURE PROTECTION BY REDUCING THE CHROMIUM1 Order number 940620-113550-ROD -001-001 page 1159 set 4 with 66 of 66 items

PRESENT IN THE GROUNDWATER TO LEVELS BELOW THE FEDERALLY REGULATED DRINKING WATER STANDARD WITHIN A REASONABLE LENGTH OF TIME. IN ADDITION, THE SELECTED REMEDY SATISFIES THE STATUTORY PREFERENCE FOR REMEDIES THAT EMPLOY TREATMENT AS THEIR PRINCIPAL ELEMENT.

COMMENT #6

THE AGENCY'S FEASIBILITY STUDY FAILS TO CONSIDER AS AN ALTERNATIVE RECOMPLETING EXISTING WELLS DEEPER IN THE TRINITY AQUIFER AND TO ALLOW THE CONTAMINATED GROUNDWATER TO NATURALLY DILUTE.


AS STATED IN THE RESPONSE TO COMMENT #5, NATURAL DILUTION OF THE CHROMIUM PRESENT IN THE DRINKING WATER AQUIFER IS NOT AN ACCEPTABLE REMEDY DUE TO THE CONTINUED MIGRATION OF THE PLUMES AS WELL AS THE EXCESSIVE TIME REQUIRED FOR DILUTION TO ATTAIN THE DRINKING WATER STANDARD AND THE APPLICATION OF NECESSARY INSTITUTIONAL CONTROLS. EXTENDING THE WELLS TO THE BOTTOM OF THE TRINITY WAS NOT CONSIDERED AS AN ALTERNATE WATER SUPPLY SINCE STANDARD DRILLING PRACTICES FOR PRIVATE WELLS AT THE SITES APPARENTLY ALREADY INCLUDES PLACING THE WELL PUMP AT THE BOTTOM OF THE TRINITY. SINCE THE CONTAMINATED PRIVATE WELLS ARE CURRENTLY COMPLETED AT THE BOTTOM OF THE AQUIFER, INSTALLING ADDITIONAL WELLS WITHIN THE IMPACTED AREA WILL NOT PROVIDE AN IMPROVED SOURCE OF DRINKING WATER.

COMMENT #7

THE EPA FAILED TO ALLOW PUBLIC REVIEW OF THE REMEDIAL INVESTIGATION AND ADMINISTRATIVE RECORD AS REQUIRED BY THE NATIONAL CONTINGENCY PLAN (NCP) AND THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION AND LIABILITY ACT (CERCLA) AS AMENDED BY THE SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986.


EPA DISAGREES. THE AGENCY RELEASED THE FINAL REMEDIAL INVESTIGATION REPORTS (DATED APRIL 1987 FOR ODESSA I AND JUNE 1987 FOR ODESSA II), FINAL DRAFT FEASIBILITY STUDIES (BOTH DATED DECEMBER 1987), AND DRAFT SUMMARY OF REMEDIAL ALTERNATIVE SELECTION FOR PUBLIC COMMENT FOLLOWING A PRESS RELEASE ON JANUARY 4, 1988. THE REPORTS ARE LOCATED AT THE ECTOR COUNTY PUBLIC LIBRARY IN ODESSA, THE OFFICE OF THE PERMIAN BASIN REGIONAL PLANNING COMMISSION IN MIDLAND, THE TEXAS WATER COMMISSION IN AUSTIN AND THE ENVIRONMENTAL PROTECTION AGENCY IN DALLAS. AS REQUIRED BY THE NCP AND CERCLA, THESE REPORTS WERE OFFICIALLY OPEN FOR PUBLIC REVIEW FOR FIVE WEEKS. IN ADDITION, THE ADMINISTRATIVE RECORD COMPLETED IN JUNE 1987, HAS BEEN IN THE FOUR REPOSITORIES SINCE THIS PAST SUMMER AND IS CURRENTLY BEING UPDATED. THE UPDATE WILL INCLUDE COMMENTS REGARDING THE REMEDIAL ALTERNATIVES RECEIVED DURING THE COMMENT PERIOD.1 Order number 940620-113550-ROD -001-001 page 1160 set 4 with 66 of 66 items

COMMENT #8

THE AGENCY HAS OVERESTIMATED THE CURRENT AND FUTURE BOUNDARY AND VOLUME OF THE CHROMIUM PLUMES AT BOTH SITES.


EPA DISAGREES. THE PLUME BOUNDARY AND VOLUME OF CHROMIUM CONTAMINATED GROUNDWATER PRESENTED IN THE FEASIBILITY STUDY IS A CONSERVATIVE ESTIMATE BASED ON HISTORIC AND CURRENT CONTAMINANT LEVELS, THE CURRENT MAXIMUM CONTAMINANT LEVELS FOR CHROMIUM OF 0.05 MG/L AND COMPUTER MODELING. ATTEMPTS WERE MADE TO VERIFY THE HISTORICAL DATA WHEN POSSIBLE; HOWEVER, SEVERAL EXISTING WELLS HAD BEEN PLUGGED FOLLOWING PREVIOUS SAMPLING EVENTS THUS COLLECTION OF VERIFICATION SAMPLES WAS NOT POSSIBLE. THE USE OF ALL AVAILABLE DATA, INCLUDING HISTORICAL SAMPLING DATA, ENABLES THE AGENCY TO DEVELOP A WORST CASE ESTIMATE OF THE CURRENT EXTENT OF THE CHROMIUM PLUME. THE CURRENT VOLUME OF THE PLUMES WERE BASED ON USING AN AVERAGE SATURATED THICKNESS OF THE TRINITY OF 60 FEET WITH A SPECIFIC YIELD OF 12% AT ODESSA I AND 30% AT ODESSA II. THE FUTURE EXTENT OF THE PLUMES WERE SIMULATED BY TWO SEPARATE COMPUTER MODELS. THE MODELS SERVED TO DEMONSTRATE THE ESTIMATED MIGRATION OF THE PLUMES SHOULD NO REMEDIAL ACTION BE TAKEN AT THE SITES. SEVERAL CONSERVATIVE ASSUMPTIONS WERE USED AS INPUT DATA TO THE MODELS.

COMMENT #9

WHY IS THE EPA PROPOSING THE USE OF THE CURRENT MAXIMUM CONTAMINANT LEVEL (MCL) FOR CHROMIUM WHEN THE STANDARD IS BEING REVIEWED BY EPA'S OFFICE OF DRINKING WATER?


THE ORIGINAL MCL FOR CHROMIUM ESTABLISHED UNDER THE SAFE DRINKING WATER ACT WAS PROMULGATED AS 0.05 MG/L ON JUNE 24, 1977. IT WAS

ESTABLISHED TO PREVENT DERMAL AND TOXIC EFFECTS, PARTICULARLY IN THE HEXAVALENT FORM. AT THIS TIME, THIS IS STILL THE OFFICIAL EPA DRINKING WATER STANDARD; HOWEVER, THE STANDARD IS, AS STATED BY THE COMMENTOR, UNDER REVIEW AND MAY BE REVISED BY SEPTEMBER, 1988. SHOULD THE STANDARD BE REVISED PRIOR TO THE INITIATION OF THE DESIGN OF THE SELECTED TREATMENT REMEDY, THE REVISED STANDARD WILL BECOME THE APPROPRIATE LEVEL OF REMEDIATION. OTHERWISE, THE CURRENT FEDERALLY REGULATED DRINKING WATER STANDARD OF 0.05 MG/L WILL BE USED.

COMMENT #10

IS IT NECESSARY TO REDUCE THE CHROMIUM LEVELS IN THE GROUNDWATER WHEN THERE HAS BEEN NO INDICATION THAT THE INDIVIDUALS WHO RESIDE OR1 Order number 940620-113550-ROD -001-001 page 1161 set 4 with 66 of 66 items

WORK IN THE IMPACTED AREA HAVE BEEN ADVERSELY AFFECTED BY DRINKING CONTAMINATED WATER?


EPA DOES NOT WAIT UNTIL PEOPLE BECOME PHYSICALLY ILL FROM SUPERFUND SITES BEFORE ACTING TO ABATE POTENTIAL HEALTH THREATS. AS STATED IN THE PREVIOUS RESPONSE, THE ACTION IS BEING UNDERTAKEN TO REDUCE CHROMIUM TO THE FEDERAL DRINKING WATER STANDARD. THE STANDARD WAS NOT ARBITRARILY SET, BUT WAS BASED ON EXTENSIVE HEALTH BASED STUDIES. A DETAILED SITE SPECIFIC HEALTH EFFECTS STUDY WAS NOT NECESSARY SINCE A PROMULGATED DRINKING WATER STANDARD EXISTS. REGARDLESS OF AN ABSENCE OF DOCUMENTED ADVERSE HEALTH EFFECTS WITHIN THE IMPACTED AREA, THE CITIZENS WITHIN THE IMPACTED AREA DESERVE THE SAME QUALITY DRINKING WATER AS PUBLIC WATER SUPPLY USERS.

COMMENT #11

WILL THE ENTIRE BUILDING AT 4318 BRAZOS REQUIRE DISPOSAL AT A PERMITTED HAZARDOUS WASTE DISPOSAL FACILITY?


YES. THE LOWER PORTION OF THE BUILDING'S EXTERIOR IS VISUALLY CONTAMINATED BY CHROMIUM. THE CHROMIUM CONTAMINATION WAS VERIFIED BY TWO SCRAP SAMPLES COLLECTED DURING THE REMEDIAL INVESTIGATION. IT WOULD BE IMPRACTICAL TO ATTEMPT TO CLASSIFY PORTIONS OF THE BUILDING AS HAZARDOUS OR NONHAZARDOUS FOR DISPOSAL. SEPARATING CONTAMINATED BUILDING MATERIALS FROM NONHAZARDOUS BUILDING MATERIALS WOULD REQUIRE AN EXTENSIVE ANALYTICAL EFFORT.

COMMENT #12

THE PROPOSED LOCATIONS OF THE EXTRACTION AND INJECTION WELLS TO BE USED AS PART OF THE GROUNDWATER RECOVERY SYSTEM NEEDS TO BE REEVALUATED.


THE PROPOSED LOCATIONS OF THE WELLS AS PRESENTED IN THE FEASIBILITY STUDY ARE BASED ON A PRELIMINARY DESIGN. AN ESTIMATE OF THE NUMBER OF WELLS REQUIRED FOR THE RECOVERY SYSTEM WAS NECESSARY FOR DEVELOPING THE ESTIMATES COST OF THE REMEDIES. THE ACTUAL NUMBER AND LOCATION OF THESE WELLS WILL BE DETERMINED DURING THE DESIGN. ADDITIONAL HYDROGEOLOGIC CHARACTERIZATION (PERMEABILITY TESTING) IS NECESSARY IN ORDER TO DESIGN THE MOST EFFECTIVE RECOVERY SYSTEM FOR THE PERCHED ZONE OF GROUNDWATER AT THE ODESSA II SITE. DESIGN ACTIVITIES MAY ALSO INCLUDE THE USE OF ADDITIONAL COMPUTER MODELING TO REFINE THE ESTIMATED PLUME BOUNDARIES.


COMMENT #13

HAS THE SHAFT/BORING RECOVERY WELL SYSTEM THAT IS PROPOSED FOR USE AT THE ODESSA CHROMIUM II SITE EVER BEEN USED IN GROUNDWATER REMEDIATION?


THE SHAFT/BORING RECOVERY WELL SYSTEM DISCUSSED IN THE ODESSA CHROMIUM II FEASIBILITY STUDY IS ADAPTED FROM THE MINING INDUSTRY. ALTHOUGH A ROUTINE ACTIVITY AT MINING SITES, THE SHAFT/BORING TECHNIQUE WILL BE USED TO SERVE A DIFFERENT PURPOSE AT THE ODESSA II SITE THAN THAT FOR WHICH IT WAS DEVELOPED. THE SHAFTS WILL BE 10 FEET IN DIAMETER AND CONSIST OF 3 LEVELS OF HORIZONTAL BORINGS. THE SYSTEM IS REQUIRED DUE TO THE LOW PERMEABILITY OF THE PERCHED ZONE AT ODESSA II. IF TESTS CONDUCTED DURING DESIGN INDICATE THE PERMEABILITY OF THE PERCHED ZONE IS GREATER THAN CURRENTLY THOUGHT, THE RECOVERY WELL SYSTEM WILL BE MODIFIED ACCORDINGLY.

COMMENT #14

IF A HEALTH THREAT EXISTS AT THE SITE DUE TO CONSUMPTION OF CHROMIUM CONTAMINATED GROUNDWATER, WHY HAS THE TEXAS DEPARTMENT OF HEALTH NOT MADE ANY ATTEMPTS TO RESTRICT THE USAGE OF THE WATER?


FOLLOWING A SAMPLING OF EXISTING WELLS, THE TEXAS WATER COMMISSION (TWC) ISSUED NOTICES TO ALL PERSONS WHICH USE WELLS THAT CONTAINED CHROMIUM. THE LETTERS PROVIDED THE WELL USER WITH THE CHROMIUM LEVEL DETECTED DURING SAMPLING AND RECOMMENDED THE USER NOT CONSUME THE WATER FROM THE CONTAMINATED WELL. COPIES OF THE LETTERS WERE SUBMITTED TO LOCAL HEALTH AUTHORITIES AS WELL AS THE TEXAS DEPARTMENT OF HEALTH (TDH). SINCE THE TDH WAS AWARE NOTICE LETTERS HAD BEEN SENT TO THE CITIZENS, DISTRIBUTION OF SIMILAR LETTERS BY THE HEALTH DEPARTMENT WAS NOT NECESSARY.

COMMENT #15

DID THE MAGNETICALLY ACTIVATED ELECTROCHEMICAL REACTOR GET SCREENED FROM FURTHER CONSIDERATION IN THE FEASIBILITY STUDY BECAUSE THE UNITED STATES SALES OFFICE CLOSED?


BASED ON AN INITIAL SCREENING OF TECHNOLOGIES, THE MAGNETICALLY ACTIVATED ELECTROCHEMICAL REACTOR MAY BE CAPABLE OF REDUCING THE CHROMIUM IN THE GROUNDWATER TO LEVELS WHICH WOULD ATTAIN THE CURRENT DRINKING WATER STANDARD OF 0.05 MG/L. ALTHOUGH THE TECHNOLOGY APPEARS TO BE CAPABLE OF REMEDIATING THE GROUNDWATER, ACTIMAG1 Order number 940620-113550-ROD -001-001 page 1163 set 4 with 66 of 66 items

CORPORATION OF BONNE, FRANCE RECENTLY CLOSED THEIR ONLY OFFICE IN THE UNITED STATES. THE READY AVAILABILITY AND TECHNICAL SUPPORT OF THE SYSTEM ARE OVERSEAS, THEREFORE, ALL ASPECTS OF TESTING, DESIGNING, CONSTRUCTING, AND OPERATING THE SYSTEM WOULD BE DIFFICULT.

COMMENT #16

IN-SITU TREATMENT TECHNOLOGIES SHOULD HAVE BEEN CONSIDERED IN MORE DETAIL BY THE EPA DURING THE EVALUATION OF REMEDIAL TECHNOLOGIES.


IN-SITU TREATMENT TECHNOLOGIES WERE CONSIDERED; HOWEVER, TREATMENT OF GROUNDWATER AT THE SITES BY IN-SITU METHODS WERE REMOVED FROM FURTHER CONSIDERATION IN THE SCREENING PHASE OF THE FEASIBILITY STUDY. IN-SITU TREATMENT OF GROUNDWATER BY CHEMICAL MEANS WOULD BE EXTREMELY DIFFICULT TO PERFORM AND CONTROL. PRECIPITATION OF THE CHROMIUM OF THE GROUNDWATER REQUIRES CLOSE CONTROL OF PH AND CHEMICAL REAGENT CONCENTRATIONS. IN-SITU TREATMENT ON THIS SCALE HAS NOT BEEN DEMONSTRATED AND UNCERTAINTY IS EXTREMELY HIGH. ALTHOUGH THE AGENCY MAY SELECT INNOVATIVE TECHNOLOGIES (SARA 121 (B)(2)). THE REMEDY MUST BE PROTECTIVE OF HUMAN HEALTH AND THE ENVIRONMENT. DUE TO THE IMPORTANCE OF THE TRINITY AQUIFER (SOLE SOURCE DRINKING WATER AQUIFER) AND THE LACK OF PROVEN IMPLEMENTABILITY, RELIABILITY, AND EFFECTIVENESS ON THE SCALE REQUIRED FOR REMEDIATING THE ODESSA SITES, THE IN-SITU OPTION WAS NOT CONSIDERED FOR DETAILED ANALYSIS IN THE FEASIBILITY STUDY.

COMMENT #17

WILL THE AGENCY CONDUCT FURTHER TESTING OF THE ELECTROCHEMICAL TREATMENT SYSTEM PRIOR TO CONSTRUCTING THE SYSTEM AT THE ODESSA SITES?


PILOT SCALE TREATABILITY STUDIES MAY BE CONDUCTED DURING THE DESIGN PHASE OF THE PROJECT. BENCH SCALE STUDIES CONDUCTED ON THE ELECTROCHEMICAL TREATMENT SYSTEM DURING THE FEASIBILITY STUDY PROVIDED LABORATORY CONTROLLED INFORMATION ON THE TECHNOLOGY'S POTENTIAL EFFECTIVENESS. A PILOT SCALE STUDY MAY BE CONDUCTED TO EVALUATE, IN DETAIL, THE SYSTEM'S ABILITY TO REDUCE CHROMIUM LEVELS IN THE GROUNDWATER. THE RESULTS OF THE PILOT SCALE STUDY WILL ENABLE MODIFICATIONS TO THE SYSTEM PRIOR TO THE SYSTEM'S CONSTRUCTION, IF DEEMED NECESSARY.

TABLE 1

SUMMARY OF SAMPLING1 Order number 940620-113550-ROD -001-001 page 1164 set 4 with 66 of 66 items

MAXIMUM MEDIA COMPOUND CONCENTRATION (1) AVERAGE VALUE (3)

GROUNDWATER CHROMIUM 9.9 MG/L (PERCHED) 1.66 MG/L 3.3 MG/L (TRINITY) 0.33 MG/L ZINC 0.06 MG/L (PERCHED) 0.06 MG/L 1.8 MG/L (TRINITY) 0.28 MG/L

SOIL CHROMIUM 720 PPM (15.4 PPM) (2) 126 PPM ZINC 408 PPM 71 PPM COPPER 1100 PPM 123 PPM LEAD 2200 PPM 358 PPM NICKEL 67 PPM 32 PPM

SEDIMENT CHROMIUM 80 PPM 63 PPM ZINC 816 PPM 507 PPM COPPER 1000 PPM 572 PPM LEAD 930 PPM 578 PPM

AIR CHROMIUM 36 UG 19 UG

(1) CONCENTRATION PRESENTED REPRESENT TOTAL METAL VALUES

(2) VALUE IN PARENTHESIS IS FOR HEXAVALENT CHROMIUM

(3) AVERAGE VALUE OF THOSE CONTAMINANT LEVELS ABOVE THE DETECTION LIMITS.

TABLE 2

LEACH TEST RESULTS

SOIL SAMPLE TOTAL CHROMIUM (PPM) EP TOXICITY (MG/L) *

B-204 380 LT 0.2

B-209 410 LT 0.2

B-217 327 0.2

B-219 324 LT 0.2

* LIMIT FOR EP TOXICITY IS 5.0 MG/L FOR TOTAL CHROMIUM.

odessa chromium #2 (andrews highway)cooling water system until about 1976. this system, tied into...

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