Superfund Record Of Decision Odessa Chromium Ii TX


           United States
           Environmental Protection
           Agency
Office of
Emergency and
Remedial Response
&EPA    Superfund
           Record of Decision:

           Odessa Chromium II, TX
EPA/ROD/R06-88/027
March 1968
                  BHVIRONWENTAI
                    PROTECTION
                     AGENCY

                        , TEXAS

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REPORT DOCUMENTATION , »• "EpORT NO- 2-
PAGE ; EPA/ROD/R06-88/027
4. Title and Subtitle
SUPERFUND RECORD OF DECISION
Odessa Chromium II, TX
Second Remedial Action - Final
7. Author(s)
9. Performing Organization Name and Address
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient's Accession No
5. Report Date
03/18/88
6.
8. Performing Organization Rept No
10. Proiect/Task/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
13. Type of Report & Period Covered
800/000
14.
IS. Supplementary Notes
16. Abstract (Limit: 200 words)
The Odessa Chromium II site consists of a series of chromium-contaminated wells
within 200 acres of residential, commercial, and industrial properties and facilities *
just outside the northwestern city limits of Odessa, Ector County, Texas. Nearly every
residence or commercial facility is served by one or more water wells completed in the
underlying Trinity Aquifer, which offers the only source of potable ground water. Two
separate contaminant plumes are bounded by the site: 5329 Andrews Highway, and
57th Street and Andrews Highway. In 1970, local health department authorities
investigated a complaint of contaminated (5.5 mg/1 chromium) well water on the property
to the south of 5329 Andrews Highway. At that time, wastewater analysis did not
indicate the presence of chromium despite the presence in 1978 of a cleaning vat
solution, stored in partially buried steel tanks, which contained 2.8 mg/1 of chromium.
One of the storage tanks was discovered leaking and the tanks were subsequently
iremoved. The facility at 57th Street and Andrews Highway has been in operation since
about 1950. Chromates were utilized in the cooling 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
(See Attached Sheet)
17. Document Analysts a Descriptors
Record of Decision
Odessa Chromium II, TX
Second Remedial Action - Final
:ontaminated Media: gw
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EPA/ROD/R06-88/027
Odessa Chromium II, TX
Second Remedial Action - Final

16. ABSTRACT (continued)

contaminated wastewater, including chromate wastes from the cooling water system, until
about 1977. The first operable unit, signed in September 1986, provided for the
extension of the city's water supply until final ground water remediation is complete.
Although chromium is the primary contaminant of concern to the ground water, other
inorganics have been found in the soil.

The selected remedial action for this site includes: ground water pump and treatment
using electrochemical techniques with reinjection into the Trinity Aquifer; and ground
water monitoring. A treatability study will be conducted during the system design phase
of the project to aid in designing an appropriate treatment system. The estimated
present worth cost for this remedial action is $3,618,000.
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Declaration for the Record of Decision

Site Name and Location

Odessa Chromium II, Near the Odessa city limits, Ector County, Texas.

Statement of Purpose

This decision document represents the selected remedial action for the
Odessa Chromium II site, developed in accordance with the Comprehensive
Environmental Response, Compensation, and Liability Act of 1930 (CERCLA) as
amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA),
and the National Contingency Plan (40 CFR Part 300).

Statement of Basis

This decision is based on the administrative record for the Odessa Chromium
II site. The attached index (Attachment A) identifies the items which
comprise the administrative record upon which the selection of a remedial
action is based.

Description of the Selected Remedy

This Record o' Decision for the Odessa Chromium II site requires the
following actions to address the chromium-contaminated groundwater:

o Extraction c* chrornjr-contaninated groundwater fron a perched water-
bearing zone end the Trinity Aquifer;

o Electrochemical treatment of groundwater which exceeds the Primary
Drinking Water Standard for chromium;

o Reinjection of treated groundwater into the Trinity Aquifer;

o Monitor site for a tninimjm of 30 years.

Declaration

The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable, or relevant
and appropriate, and is cost-effective. This remedy satisfies the
statutory preference for remedies that employ treatment which permanently
and significantly reduces the toxicity, mobility or volume of hazardous
substances as their principal element. Finally, this remedy utilizes
permanent solutions and alternative treatment technologies to the maximum
extent practicable.

The State of Texas has been consulted and agrees with the approved remedy.

3-18-88
-
DATE Robert E. Layton Jr., Lp.E
Regional Administrator
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Odessa Ch; J-JT, URI ^

Record of Decision Concurrences
The Odessa Cnromium II Record of Decision has been reviewed and I concur
Allyn M.' Davis, Director
Hazardous Waste Management Division
Jennett StoKes, Chief
Solid Waste S Emergency Response
Branch
Office of Regional Counsel
//.~
Carl E. Edlund, Chief
Superfund Program Branch
Hazardous Waste Management Division
Stanley G. Hitt, Chief
Texas Remedial Section
Superfund Program Branch
Hazardous Waste Management Division
Tjn?i-.e J. DeVos, Cnief
State Prog^-s Spct'on
Superfund Program Branch
Hazardous Waste Management Division
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TaM e of Contents
Page
1. Site Location and Description 1
o Site History 1
o Geology 2
o Remedial Investigation Results 3
o Potential Impact of Site 4
2. Enforcement 5
3. Community Relations History 5
4. Alternative Evaluation 5
o Evaluation Criteria 5
o Description of Alternatives 8
o Evaluation of Alternatives 11
5. Selected Remedy 14
o Rationale 14
o Operation and Maintenance 14
0 Future Actions 14
o Remedial Action Schedule 15
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ary of Rerced'a"! Alternatives Selection for
Odessa Chromium II; Operable Unit II
Odessa, Texas
I. SITE LOCATION AND DESCRIPTION

The Odessa Chromium II Supprfund Site consists of a series of chromium
contaminated wells within 200 acres of residential, commercial, and
industrial properties and facilities immediately west of the Andrews
Highway just outside the northwestern city limits of Odessa, Ector County,
Texas (Figure 1). Two separate contaminant plumes are present at the
site. Based on the boundaries of the known chromium groundwater contami-
nation in the Trinity Aquifer, the affected area is bounded by 57th Street
to the North, Andrews Highway to the East, 50th Street to the south, and
a line which extends from Washington Street, North to 57th and South to
50th Street. Nearly every residence or commercial facility is served
by one or more water wells completed in the Trinity Aquifer which offers
the only source of potable groundwater. Approximately 60 to 90 people
within the study area are served by wells contaminated with chromium
above the drinking water standard of 0.05 mg/1 .

Site History

From 1950 to 1965, cooling water additives which contained chromates were
produced at 5329 Andrews Highway. In November 1951, the well water at
the property located at 54tn Street and Andrews Highway was bright yellow
in color, presumably the result of chromium contamination.

Operation began at the 5329 Andrews Highway location site sometime between
1965 and 1969. Local Health Department authorities investigated a complaint
of contaminated (5.5 mg/1 chromium) well water on the property to the
south of 5329 Andrews Highway in 1970. At that time, analysis of wastewater
from 5329 Andrews Highway did not indicate the presence of chromium, but
in 1978 a cleaning vat solution, which was eventually stored in partially
buried steel tanks, contained 2.8 mg/1 of chromium. One of the storage
tanks was discovered to be leaking and the tanks were subsequently removed.

The facility at 57th Street and Andrews Highway has been in operation
since about 1950. Chromates were utilized in the cooling 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 September, 1984, the Odessa Chromium II Site was added to the
National Priorities List (sites which appear to present a significant
risk to public health or the environment). The State of Texas entered
into a Cooperative Agreement with the Environmental Protection Agency
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ODESSA CHROMIUM H
SITE
SITE LOCATION MAP
REMEDIAL INVESTIGATION
ODESSA CHROMIUM Z SITE
ODESSA,TEXA3

PREPARED FOR

TEXAS WATER COMMISSION
AUSTIN, TEXAS
/HOWELL ENG.
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(EPA) on September 26, 1984, to perform a Remedial Investigation (RI),
Focused Feasibility Study (FFS) for Operable Unit I and a Feasibility
Study (FS) for Operable Unit II. The total funds awarded to the State
for these studies was $851,059. The RI field work (soil, groundwater,
air and sediment sampling) began in August 1935 and a draft report was
submitted April 1985.

In January 1935, the EPA and the TWC initiated the FFS for Operable Unit I.
The single purpose of the FFS was to examine 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. The extension of the Odessa City water system was the remedy
selected on September 8, 1986. The design of this system was completed
in Decenber 193?. The construction phase of the water supply project is
scheduled for completion by December 1983. The extension of the city's
water lines is intended to provide potable water to those persons residing
within the two-year anticipated impacted area until the remediation of
the contaminated grojndtvater is complete.

Further fieldwork (soil sampling) was'conducted in November 1986, and a
final RI report was accepted by Tu'C and EPA on June 5, 1987. A final
Draft FS report was submitted in Decenber 1937. This FS report provides
a comparison of the potential remedial alternatives.

Geology

The surficial soil in the site area is principally Amarillo loam.
Generally, it is fine sandy loam which ranges in depth from 8 to 10
inches. Below that, to depths from IS to 24 inches, the subsoil is
fine sandy loam to sanay clay. Pleistocene windblown sand, clay
deposits and alluvium deposits underlie the soil section. Beneath'
the Pleistocene are 25 to 35 feet of caliche deposits which can be
relatively impermeable in local areas.

Underlying the caliche are scattered erosional remnants of the Ogallala
formation composed of gravels, sands, silts and clays. This formation
does not generally extend to depths below 75 feet in the area.

The Trinity formation, the main fresh water producing aquifer in the
area, underlies the Ogallala interval. The thickness of this formation
ranged from 55 to 70 feet. It is composed of sands and sandstones
with minor amounts of siltstone, clay and gravel. Beneath the Trinity
Formation is the Dockum Group of Triassic age which serves as an effective
aquiclude. The upper unit of the Dockum Group, the Chinee Formation,
consists of up to 600 feet of clays and shales which prevents downward
migration of contaminants.

The hydrologic units containing potable water in the site area are the
Ogallala formation at approximately 70 feet below the area and the Trinity
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sand at approximately 90 feet below the site (Figure 2). In general,
the the Ogall al a is hydro! oglcally connected with the underlying
Trinity and has little or no saturated thickness. The Ogal 1 a contains
a thin zone of perched groundwater immediately above the Trinity in
the northeastern portion of the site. A few miles to the southwest
the Ogall al a 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. Groundwater within this unit
moves in a southwest direction at 100-150 feet per year.

Remedial Investigation Results

During the RI for the Odessa Chromium II site, samples were collected
from soil, groundwater, and air to determine the nature and extent of
contamination. The primary emphasis for analytical testing was
placed on determining the presence of chromium. Chromium testing was
conducted for the shallow and deep soil borings and from water samples
collected from the inventory and monitor wells. Additional chemical
testing for zinc, copper, nickel and lead was performed for selected
samples. Table 1 shows the maximum level detected for each of these
contaminants for each media sampled during the RI.

Analytical results of the soil samples collected from the site indicate
that elevated levels of chromium are present at 5329 Andrews Highway and
at the 57th Street and Adrews H-ghway the Wooley Tool property. The
contamination is generally limited to the upper 8 feet of soil with
levels up to 720 ppm total chromium. The estimated volume of chromium
contaminated soil exceeding near background conditions (50 ppm total
chronium) is 3,010 yd^. The chromium present in the soil is pre-
dominately (95-99%) in the trivalent state. Trivalent chromium
adsorbs well to soil and therefore does not leach out. This is
confirmed by the EP Toxicity results (Table 2). EP Toxicity levels
less than 5 mg/1 for total chromium are considered acceptable by EPA.

Over 400 existing wells were identified within a one-half radius
of the site, of which more than 300 were sampled and analyzed for
total and hexavalent chromium. Of the wells sampled, 13 were found
to exceed the Federally regulated drinking water standard for chromium
of .05 mg/1. In addition, 12 wells were installed within the Trinity
aquifer and 8 wells were installed in the perched zone during the
remedial investigation. Seven of these wells contained chromium
levels which were at or above the drinking water standard. Figure 3
depicts the estimated area! extent of chromium contamination 1n the
Trinity aquifer. Contamination levels are highest in the perched
zone above the Trinity aquifer (9.9 mg/1) with levels up to 3.3 mg/1
within the Trinity aquifer below the 5329 Andrews Highway property.
There are two plumes, one which appears to radiate outward from
Andrews Highway and 57th Street in a southwesterly 4 direction and
one oriented south-southwest of the 5329 Andrews Highway. An
estimated 200,000,000 gallons of groundwater exceed the current
Primary Drinking Water Standard for chromium of 0.05 mg/1.
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FIGURE 2

GENERALIZED. STRATAGRAPHIC SECTION
REMEDIAL INVESTIGATION
ODESSA CHROMIUM U SfTE
ODESSA. TEXAS
PREPARED FOR

TEXAS WATER COMMISSION
AUSTIN, TEXAS
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TABLE 1
SUMMARY OF SAMPLING

Media
Groundwater

Soil

Sediment

Compound
Chromium

Zinc

Chromium
Zinc
Copper
Lead
Nickel
Chromium
Zinc
Copper
Lead
(1)
Maximum Concentration
9.9 mg/1 (perched)
3.3 mg/1 (Trinity)
0.06 mg/1 (perched)
1.8 mg/1 (Trinity)
(2)
720 ppm (15.4 ppm)
408 ppm
1100 ppm
2200 ppm
67 ppm
80 ppm
816 ppm
1000 ppm
930 ppm

(3)
Average Value
1.66 mg/1
0.33 mg/1
0.06 mg/1
0.28 mg/1

126 ppm
71 ppm
123 ppm
358 ppm
32 ppm
63 ppm
507 ppm
572 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.
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TABLE 2
LEACH TEST RESULTS
Soil
Sample
B-204

B-209

B-217

B-219
Total Chromium (ppm)

380

430

327

324
EP Toxicity (mg/1)*

<0.2

0.2

<0.2
* Limit for EP Toxicity is 5.0 mg/1 for total chromium
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Surface sediment samples were collected at three locations from the
6329 Andrews Highway property. The samples contained up to 80 ppm
chromium. The detection of chromium in the sediment indicates surface
runoff may have resulted in transporting contamination off-site.

Air monitoring was conducted during drilling activities at the site.
Based on the sample results, air quality at the site has not been
significantly degraded as a result of the surface contamination present
at the site. However, any future excavating of contaminated soil,
especially during windy conditions, might pose a health risk to workers
or nearby residents.

Potential Impact of SUe on Human Health and the Environment

The contaminant of greatest concern at the site (chromium) was chosen
from the compounds detected based on its widespread distribution
throughout the contaminated groundwater plume as well as its relative
toxicity and concentration. A risk assessment was conducted based
on the chromium concentration found at the site, assuming no remedial
action would be conducted. The first step in the risk assessment
required the identification of potential receptors. Target receptors
identified in the assessment include:

o Residents in trailers and homes utilizing contaminated
groundwater,

o Employees of businesses utilizing contaminated groundwater, and

o 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 or
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 1 eve!.

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/1
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.
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5

Neither ingsstion of contaminated soils nor inhalation of contaminated
dust perticles 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 con-
sidered necessary.

Results of the assessment indicate that remedial action is required to
reduce the potential for public health exposure through the consumption
of contain noted groundwater only. The Agency for Toxic Substances and
Disease Registry (ATSDR) has supported this interpretation of the risk
assessment (Attachment B).

II. ENFORCEMENT

The goal of the EPA is to have those parties responsible for contami-
nation 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.

III. COMMUNITY RELATIONS HISTORY

Sea Attachment C.

IV. ALTERNATIVES EVALUATION
Evaluation Criteria

Section 121(a) through (f) of the Superfund Aneni-nents and Reauthoriz-
ation 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.
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6

2. Reduction of Toxicity, Mobility or Volume

The degree to which alternatives employ treatment that reduces
toxicity, mobility, or vol ume must al so be assessed. Relevant
factors are:

o the treatment processes the remedies employ and materials
to be treated.

o the amount of hazardous materials that will be destroyed or
treated;

o the degree of expected reduction in toxicity, mobility, or
volume;

o the degree to which the treatment is irreversible;

o the residuals that will remain following treatment, consider-
ing the persistence, toxicity, mobility, and propensity
for bioaccumulation of such hazardous substances and
their constituents.

EPA is also directec by SARA to give preference to remedial
actions that utilize treatment to remove contaminants from
the env'-'ronnent. Off-s;te 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 bp assessed;
considering appropriate factors a'Tiong the following:

o magnitude of reduction of existing risks;

o 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;

o time until full protection-is achieved.

4. Long-term Effectiveness and Permanence

Alternatives are asspssed for the long-term effectiveness and
permanence they afford along with the degree of certainty that
the remedy will prove successful. Factors considered are:
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o magnitude of residual risks in terms of amounts and con-
centrations of waste remaining following implementation of a
remedial action, considering thp persistence, toxicity,
mobility, and propensity to bioaccumul ate of such hazardous
substances and their constituents;

o type and degree of long-term management required, including
monitoring and operation and maintenance;

o long-term reliability of the engineering and institutional
controls, including uncertainties associated with land
disposal of untreated wastes and residuals;

o potential need for replacement of the remedy.

5. Imp!ementabil ity

The ease or difficulty of implementing the alternatives are
assessed by considering the following types of factors:

o degree of difficulty associated with constructing the
techno!ogy;

o expected operational reliability of the technologies;

o need to coordinate with and obtain necessary approvals and
permits from other offices and agencies;

o availability of necessary equipment and specialists;

o available capacity and location of needed treatment, storage,
and disposal services.

6. Cost

The types of costs that should be assessed include the following:

o capital cost;

o operational and maintenance costs;

o net present value of capital and O&M costs;

o potential future remedial action costs.

7. Community Acceptance

This assessment should look at:

o components of the alternatives which the community supports;
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o features of the alternatives about which the community has
reservations;

o elements of the alternatives which the community strongly
opposes.

8. State Acceptance

Evaluation factors include assessments of:

o components of the alternatives which the State supports;

o features of the alternatives about which the State has reserv-
ations;

o elements of the alternatives under consideration that the
State strongly opposes.

9. Overall Protection of Human Health and the Environment

Following the analysis of the remedial options against indi-
vidual evaluation criteria, the alternatives are assessed
from the standpoint of whether they provide adequate protection
of hjman health an? the environment considering the multiple
criter:a.

Description of Alternatives

In cnnformance with the National Contingency Plan, initial remedial
approaches wepe screened to determine which might be appropriate for
this site. (S»t 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 plugg-
ing 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 con-
structing 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
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day layer underlying the contaminated zone thus creating a barrier wall
around the contaminated groundwater. The barrier would limit the migra-
tion 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/1 total chromium would would be effectively
contained by the 3 foot thick wall. The length of the barrier wall
will he 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 worth 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/coring 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 year with estimated 5 year present worth cost of $7,412,000
ancl 52,786,000, 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
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 hexaval ent 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
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10

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 remedial action has been
completed, the groundwater concentration could be at or below 0.05
mg/1 . 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/1 rather than the
current MCL of 0.05 mg/1. The purpose for developing a treatment
alternative which does not remediate the yroundwater to the current
drinking water standard was to provide the relative cost difference
in treating the groundwater should the MCL be revised prior to design-
ing 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.
-------
11
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.

o 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. Compl ies with ARARs

Compliance wit^ ARA3s 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/1 Ion Exchange alterna-
tives (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 W;11 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 raten " + " 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
-------
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-------
alternate water supply, there would continue to exist a potential
for consumption of contaminated groundwater should the water
supply system fail.

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
fron the ion exchange units 'nay pose a short term threat to human
health and the environment should an accidental spill occur during
transport to a disposal fa:ility.

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 ground-
water 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 question-
able. Alternative 4, Chemical Treatment, effectively reduces the
level of chronium 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 chronium above the respective clean-up criteria is
removed without effecting the secondary quality (taste, odor and
color) of the groundwater.

5. Implenentability

The No Action Alternative is relatively is easy to implement since
it involves installing neu 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 Altern-
ative 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. Cost

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.
-------
13

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/1) greater than the current MCL (0.05 mg/1) 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 55,042,000 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 commur.-ty 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

Thp StatP 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 of 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
-------
14

above the respective action level will remain in the groundwater
following remedial action.

V. SELECTED REMEDY Electrochemical Treatment

Rational e

Based on the information available to evaluate the six remedial options
against these nine criteria, EPA has concluded that Alternative 5, Electro-
chemical 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 current MCL
or the MCL promulgated prior to design.

The shaft/boring well systerr, w4ll be used to withdraw groundwater from
the perched zone. Althojgh the construction of this system will take
no longer than the well field option, two years versus one and one-half
years, the shaft/coring 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.

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.

Future Actions
No future actions are anticipated. The Electrochemical treatment
alternative is considered permanent. If, however, significant unfore-
seen offsite migration or contamination occurs as a result of the
site, measures will be implemented to remediate the situation.
-------
15
Remedial Action Schedule

Approve Remedial Action (sign ROD)

Complete Enforcement Negotiations

Award Cooperative Agreement Amendment
for Design of Approved Remedy

Start Design

Complete Design

Award Remedial Action Cooperative
Agreement Amendment for Construction
of Approved Remedy

Start Construction

Complete Construction

Complete Groundwater Treatment
March 1988

June 1988

August 1988

October 1988

August 1989

October 1989

January 1990

January 1992

January 1997
-------
ATTACHMENT A
ADMINISTRATIVE RECORD INDEX
-------
•IMSIRATIVE RECORDS INDEX
Job Name:

Job Nunber:
Odes:;a L'
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
No date specified
Notice of public meeting
Texas Dept. of Water Resources

Public

08/08/85 Public Meeting notice
1
000001
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
No date specified
Report
I.T. Corporation/Howell Engineering
Contractor to U.S. E.P.A.
U.S. E.P.A. and T.W.C.

Plan for an Alternate Potable Water Source
15
000002
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
09/06/77
Complaint 4 Investigation Reports
Hank Krusekoph
Railroad Commission of Texas, Midland
Robert Bradshaw, Supervisor
District 10, Texas Water Quality Board
Contamination Complaint and Investigation Reports
29
000003
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description

Number of Pages
Document Nunber
11/16/77
Memorandum
Robert L. Bradshaw, Supervisor
District 10, Texas Dept. of Water Resources
George Green, P.E., Chief, Field Support
Field Operations, Water Supply
Complaint - Water Well Contamination - E.M.
Cassity
19
OOUOOU
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Nunber:
Odessa Chrcmitn II

T11JJ
Document Date
Document Type
Originator

Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Docunent Nunber
OV1V78
Memorandun
Jerry L. Phillips, R.S., District 10
Representative
Texas Dept. of Water Resources
Dan Havelka, Chief, Field Support Section
Enforcement and Field Operations Division
E.M. Cassity (dba Redondo Motel) Complaint
U1
000005
Document Date
Document Type
Originator

Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
05/25/79
Memorandum
C.R. Miertschin, Director, Enforcement & Field
Ops. Div.
Texas Dept. of Water Resources
C.R. Baskin, Director, Data & Engineering Svcs.
Texas Dept. of Water Resources
Ground Water Contamination
7
000006
Document Date
Document Type
Originator
Originator - Affiliation
Recipient

Recipient - Affiliation
Description
Number of Pages
Document Nunber
07/16/79
Memorandum
Jerry Phillips, Field Representative, District 10
Texas Dept. of Water Resources
George E. Green, P.E. Chief, Field Support
Section
Texas Dept. of Water Resources
Cassity Complaint, Pumping Results
26
000007
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
07/26/79
Memorandum
George E. Green, P.E. Chief
Texas Dept. of Water Resources
Buck Steingraber
Solid Waste and Underground Injection Division
Ground Water Contamination Complaint 7/16/79
1
000008
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Number:
Odessa ChrotTiiun II

T11H
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
OV07/81
Correspondence
C.R. Miertschin, Director
Texas Dept. of Water Resources
Billy Maxwell
Wooley Tool & Mfg. Division
Request to plug wells at Wooley Tool
2
000009
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
06/21/83
QAPP Report
U.S. E.P.A.

U.S. E.P.A.

Quality Assurance Project Plan
146
000010
Document Date
Document Type
Originator-
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
02/23/84
Correspondence
William F. Lockey, District Supervisor
Texas Dept. of Water Resources
Gerald Fugitt
Resident of Odessa, Texas
Chromium contamination of ground water
1
000011
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
02/23/84
Correspondence
William F. Lockey, District Supervisor
Texas Dept. of Water Resources
Mr. Hooton
Resident of Odessa, Texas
Chromium contamination of ground water
1
OOU012
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Number:
Odessa Chrcrniiin II

TVU
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Docunent Number
02/23/84
Correspondence
William F. Lockey, District 10 Supervisor
Texas Dept. of Water Resources
Dorothy Bell
Resident of Odessa, Texas
Chromium contamination of ground water
1
000013
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
02/23/84
Correspondence
William F. Lockey, District 10 Supervisor
Texas Dept. of Water Resources
Mr.. Dale Meyer
Dale Meyer Trucking Co.
Chromium contamination of ground water
1
00001U
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number
02/23/54
Correspondence
William F. Lockey, District 10 Supervisor
Texas Dept. of Water Resources
Mr. Bowden
Bcwden Construction Co., Inc.
Chromium contamination of ground water
1
000015
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number
02/23/84
Correspondence
William F. Lockey, District 10 Supervisor
Texas Dept. of Water Resources
Mr. Garland Sorrell
Resident of Odessa, Texas
Chrcmiun contamination of ground water
1
000016
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Nunber:
Odessa Chrqniun II

T114
Document Date
Document Type
Originator

Originator - Affiliation
Recipient

Recipient - Affiliation
Description

Number of Pages
Document Nunber
03/06/84
Memorandum
Joan A. Middleton, Environmental Quality
Specialist
Texas Dept. of Water Resources
Gary D. Schroeder, Chief, S.W. and Spill
Response
Texas Dept of Water Resources
Andrews Highway SuperFund Site - Ground
Water Sampling
13
000017
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
03/19/84
Correspondence
William F. Lockey, District 10 Supervisor
Texas Dept. of Water Resources
Mr. Admire
Resident of Odessa, Texas
Selenium contamination of ground water
1
000018
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
01/06/84
Correspondence and ground water analysis
William F. Lockey, District 10 Supervisor
Texas Dept. of Water Resources
Mr. Gerald Fugitt
Resident of Odessa, Texas
Chromium contamination of ground water
2
000019
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
01/04/85
Correspondence and ground water analysis
William F. Lockey, District 10 Supervisor
Texas Dept. of Water Resources
Lee C. Moore, Inc.
Resident of Odessa, Texas
Ground water contamination
2
000020
-------
Job Name:

Job Nunber:
Odessa Chraninn II
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number
02/27/85
Presentation materials/copies of slides
I.T. Corporation

Texas Dept. of Water Resources

Odessa Chronitrn I and II
26
000021
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description

Ninber of Pages
Document Nunber
04/19/85
Presentation materials - Odessa Chromium I, II
I.T. Corporation
Meeting with U.S. E.P.A. and Texas Dept.
of Water Resources
26
000022
Document Date
Document Type
Originator

Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
06/18/85
Memo and CRP - Odessa Chromium I, II Sites
William W. Colbert, SW and Spill Response
Section
Texas Dept. of Water Resources
Carlene Chambers
U.S. E.P.A.
Memo and CRP - Odessa I, II sites
23
000023
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
07/05/85
Quality Assurance Project Plan - Rev. 1
I.T. Corporation

Texas Dept. of Water Resources

Site Investigation and Feasibility Studies
82
00002*1
-------
RECORDS
Job Name:

Job Number:
Odessa Chrcrniun II

Tim
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nur.ber
07/17/85
Memorandum
Ernest W. Heyer, Q.A. Officer
Texas Dept. of Water Resources
Bryan W. Dixon
Texas Dept. of Water Resources
Re: QAPP for Odessa Chromium I, II sites
2
000025
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
08/02/85
Memorandum
Matt Tokheim, Engineering Technician III
Texas Dept. of Water Resources
Greg Tipple
Texas Dept. of Water Resources
Current use of contaminated water wells
2
000026
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
08/22/85
Memo
Carlene L. Chambers, Project Officer
U.S. E.P.A.
Bryan W. Dixon, Chief
Texas Dept. of Water Resources
Sampling plan objectives
3
000027
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number
08/23/85
Memorandum
Bryan W. Dixon
Texas Dept. of Water Resources
Al Husak, Project Manager
I.T. Corporation
Partial approval of sampling plan
2
000028
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Nunber:
Odessa Chraniun II

Tim
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number
08/26/85
Correspondence
Bryan W. Dixon
Texas Dept. of Water Resources
NET Systems, Inc.

Access Agreement - Odessa II SuperFund Site
11
000029
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nur.ber of Pages
Document Nunber
09/11/85
Memo and report
D.O. Pratt, Attorney
Candy Michener Swindle Whitaker & Pratt
Lou Barinka
U.S. E.P.A.
Memo and Final Closure Report
114
000030
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description

Nunber of Pages
Document Nunber
09/23/85
Memorandum
Matt Tokheim, Engineering Technician III
Texas Water Commission
Bill Brown, H 4 SW Division
Texas Water Commission
Follow-up report on ground water
contamination
27
000031
Document Date
Document Type
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
10/01/85
Transmittal - Tables of Contaminated
Water Wells
Originator Alan D. Husak, Mgr. of Engineering
I.T. Corporation
Greg Tipple
Texas Water Commission
Well Inventory Survey
24
000032
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Nunber:
Odessa Chrcmiiri II

T11H
Docunent Date
Document Type

Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
10/03/85
Transmittal - Tables of Uncontaminated
Water Wells
Robert S. Newton, Project Coordinator
I.T. Corporation
Greg Tipple
Texas Water Commission
Uncontaminated Well Inventory Survey
29
000033
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
10/1V85
Transnittal letter
Robert S. Newton, Project Coordinator
I.T. Corporation
Greg Tipple
Texas Water Commission
Property locations for Monitor Wells
8
00003^
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
10/22/85
Transr.ittal letter
Robert S. Newton, Project Coordinator
I.T. Corporation
Greg Tipple
Texas Water Commission
Letter of Clarification - QAPP
5
000035
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
11/85
Report
I.T./ERT

U.S. E.P.A.

Well Inventory RI
36
000036
-------
ADMINISTRATIVE RECOK.SJj.
Job Name:

Job Number:
Odessa Chromium II

THU
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
11/08/85
Hailing list and water well sampling results
Charles R. Faulds, P.E., Chief, SuperFund Section
Texas Water Commission
Well owners
Only those well owners with multiple wells
Analytical results: No chromium detected
20
000037
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
11/08/85
Mailing list and water well sampling results
Charles R. Faulds, P.E., Chief, SuperFund Section
Texas Water Commission
Well owners
Only those well owners with single well
Analytical Results: No chromium detected
20
000038
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
11/1V85
Correspondence
Charles R. Faulds, P.E., Chief, SuperFund Section
Texas Water Commission
Mr. Danny Willie
Resident of Odessa, Texas
Water Well Sampling Results
2
000039
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
11/1V85
Correspondence
Charles R. Faulds, P.E., Chief, SuperFund Section
Texas Water Commission
Mr. Vernon Duggans
Resident of Odessa, Texas
Water Well Sampling Results
2
000040
-------
Job Name:

Job Number:
Odessa Chraniir: II
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
11/1V85
Correspondence
Charles R. Faulds, P.E., Chief, SuperFund Section
Texas Water Commission
Ms. Dorothy Bell
Resident of Odessa, Texas
Water Well Sampling Results
2
OOU041
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nurber of Pages
Document Nunber
11/1V85
Correspondence
Charles R. Faulds, P.E., Chief, SuperFund Section
Texas Water Commission
Mr. Dale Meyer
Resident of Odessa, Texas
Water Well Sampling Results
2
OOU042
1V1V85
Correspondence
Charles R. Faulds, P.E., Chief,
Texas Water Commission
Mr. Burl Graham
Resident of Odessa, Texas
Water Well Sampling Results
2
OOOOU3
SuperFund Section
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
11/1V85
Correspondence
Charles R. Faulds, P.E., Chief, SuperFund Section
Texas Water Commission
Mr. Howard Boatright
Resident of Odessa, Texas
Water Well Sampling Results
2
ooocw
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Number:
Odessa Chrctniun II

nut
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number
11/1V85
Correspondence
Charles R. Faulds, P.E., Chief, SuperFund Section
Texas Water Commission
Mr. Ramesh Wadhwa
Resident of Odessa, Texas
Water Well Sampling Results
OOOOU5
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
11/1V85
Correspondence and comments
Carlene L. Chambers, Project Officer
U.S. E.P.A.
Charles R. Faulds, P.E., Chief, SuperFund Section
Texas Water Commission
Conditional approval of QAPP
2
000016
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
11/15/85
Memo and comments
Robert S. Newton, Project Coordinator
I.T. Corporation
Charles R. Faulds, P.E., Chief, SuperFund Section
Texas Water Commission
Response to comments on Sampling Plan (TWO
53
000017
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
11/15/85
Correspondence
Charles R. Faulds, P.E., Chief, SuperFund Section
Texas Water Commission
Henry Rodriguez
Resident of Odessa, Texas
Water Well Sampling Results
2
0000MB
-------
ADMINISTRATIVE RECORDS TNHTY
Job Name:

Job Number:
Odessa Chrcrr.iuTi II
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
11/15/85
Correspondence
Charles R. Faulds, P.E., Chief, SuperFund Section
Texas Water Commission
Mr. Truman Fox
Resident of Odessa, Texas
Water Well Sampling Results
2
000049
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
11/15/85
Correspondence
Charles R. Faulds, P.E., Chief, SuperFund Section
Texas Water Commission
Mr. Stan Stucks
Resident of Odessa, Texas
Water Well Sampling Results
2
000050
11/15/85
Report
I.T. Corporation

Texas Water Commission

Health and Safety Plan Rev. 1
63
000051
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
11/21/85
Memorandum
Stephen Margolis, Ph.D.
ATSDR
Mr. Carl Hickam, Public Health Advisor
U.S. E.P.A. Region VI
Health Assessment • Odessa Chrcroiun I and II
2
000052
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Number:
Odessa Chromium II

T114
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nimber
11/26/85
Memorandum
Steve Muse, Geologist
U.S. E.P.A.
Carlene Chambers, Project Officer
U.S. E.P.A.
Field Audit of Monitor Well Drilling
1
000053
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nimber
01/16/86
Correspondence
Greg Tipple
Texas Water Commission
Bonnie J. DeVos, Chief, State Programs Section
U.S. E.P.A.
Disposal/Storage of Investigated Substances
3
00005U
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nimber of Pages
Document Number
01/21/86
Record of Communication
Steve Muse, Geologist
U.S. E.P.A.
File
U.S. E.P.A.
Use of contaminated water for drinking
2
000055
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nimber of Pages
Document Nunber
01/31/86
Memorandum
Bonnie J. DeVos, Chief, State Programs Section
U.S. E.P.A.
Greg Tipple
Texas Water Commission
Disposal Plan for CERCLA Generated Wastes
1
000056
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Nunber:
Odessa Chrcrr.iun II

Till
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
03/10/86
Correspondence
Robert S. Newton, Project Coordinator
I.T. Corporation
Greg Tipple
Texas Water Commission
Water Wells at Elm Trailer Court
1
000057
Document Date
Docinent Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description

Nunber of Pages
Document Nunber
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
03/11/86
Correspondence
Larry R. Soward, Executive Director
Texas Water Commission
Mr. John Harrison, City Manager
City of Odessa, Texas
Status of Investigations at Odessa Chronlun I
and II
3
000058
03/20/86
Correspondence
L. B. Griffith, P.E.
Texas Department of Health
Honorable John Minor
Mayor of Odessa, Texas
Solid Waste - Ector County
1
000059
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description

Number of Pages
Document Nunber
03/25/86
Resolution
John B. Minor, Mayor
Odessa, Texas, City Council
City Council
Odessa, Texas
Agreement to consider extension of city water
services, etc.
1
000060
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Number:
Odessa Chranium II

T11M
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
OV86
Draft Report
I.T./Howell Eng.
I.T. Corporation
U.S. E.P.A.

Remedial Investigation - Volune I
15u
000061
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nur.ber of Pages
Document Number
OM/86
Draft Report
I.T./Howell Eng.
I.T. Corporation
U.S.. E.P.A.

Remedial Investigation - Volune II
282
000062
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
01/21/86
Transmittal letter
Robert S. Newton, Project Coordinator
I.T. Corporation
Greg Tipple
Texas Water Commission
Item 5, Rev. 2: QAPP
11
000063
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
05/16/86
Memorandum
Oscar Cabra
U.S. E.P.A.
Carl Edlund
U.S. E.P.A.
Chromiun Standard Inquiry
1
00006H
-------
ADMINISTRATTVE RECOPDS INDEX
Job Name:

Job Nunber:
Odessa Chrcr.iur i i
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
05/28/86
Transmittal and test results
Bob Monk
I.T. Corporation
Greg Tipple
Texas Water Commission
Leach Test Results
6
000065
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
06/86
Draft Report, Rev. 1
I.T./Howell Eng.

U.S. E.P.A.

Focused Feasibility Study Draft Report, Rev. 1
2*5
00u06b
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
06/13/86
Correspondence
Greg Tipple
Texas Water Commission
Bill Lockey
Texas Water Commission
Delivery of letters to affected individuals
3
000067
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
06/18/86
Memo and Contaminated Well Inventory Sheets
Robert S. Newton
I. T. Corporation
Greg Tipple
Texas Water Commission
Memo and 9/85 Well Inventory Data Sheets
53
000068
-------
ADMINISTRATIVE RECORDS INDEX
Job K

Job Nmber:
T11H
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nir.ber
06/18/86
Memo and Lab Information
Robert S. Newton
I.T. Corporation
Greg Tipple
Texas Water Commission
Lab Information Odessa Chromium I, II
7
000069
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
07/21/86
Memorandum
Stan Hitt
U.S. E.P.A.
Bonnie J. DeVos
U.S. E.P.A.
Comments on Odessa Chromium I,II - FFS
2
000070
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/86
Final Report
I.T./Hcwell Eng.

U.S. E.P.A.

Focused Feasibility Study - Final Report
217
000071
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/13/86
Transcript
International Litigation Services, Inc.

U.S. E.P.A.

08/13/86 - Public Meeting
67
000072
-------
ADMINISTRATIVE P.E
Job Name:

Job Number:
Odessa C^raniur, II

T1U
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
08/20/86
Correspondence
J. H. Griffin
Resident of Odessa, Texas
Carl E. Edlund
U.S. E.P.A.
Letter and Analysis of Well Water at Residence
2
000073
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description

Nur.ber of Pages
Document Nur.ber
08/21/86
Correspondence
Larry R. Soward, Executive Director
Texas Water Commission
Dick Whittington
U.S. E.P.A.
No objection to E.P.A.'s selection of proposed
remedy
1
00007M
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number
08/21/86
Correspondence
Greg Tipple
Tx Water Commission
Mrs. Dale Meyer
Resident of Odessa, TX
Guidelines for plugging of wells
3
000075
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
08/25/86
Correspondence
Mr. and Mrs. Carl Overton
Residents of Odessa, TX
U.S. E.P.A.
Texas Water Commission
Opposition to annexation into city limits
1
000076
-------
A>.:.,-S.r...,rV£ RECORDS INDEX
Job Name:

Job Nucber:
-Odessa Chromium II

T1H1
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/25/86
Correspondence
Mrs. Truman Fox
.Resident of Odessa, TX
U.S. E.P.A.

Opposition to annexation into city limits
1
000077
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description

Number of Pages
Document Number
08/27/86
Correspondence
Dale Meyer
Resident/businessman of Odessa, Texas
Mr. Bill Lockey
Texas Water Commission
Protest of proposed renedial alternatives
analysis
1
000078
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
08/27/86
Correspondence
Thomas Taylor
Resident of Odessa, Texas
Mr. Bill Lockey
Texas Water Commission
Protest of annexation into city limits
1
000079
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
08/27/86
Correspondence
Richard H. Fuller
ERM - Southwest, Inc.
Diana Hinds
U.S. E.P.A.
Comments on the Odessa Chromium II - FFS
8
000080
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Number:
Odessa Ch ran inn II

T1U
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
08/29/86
Correspondence
James L. Turner
U.S. E.P.A.
Paul D. Evans, Liquidation Assistant
F.D.I.C.
Chromium Contamination at Bfi-.' Welding
2
000081
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/08/86
Report
Dick Whittington
U.S. E.P.A.
ROD - Remedial Alternative Selection
39
000082
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number
09/18/86
Correspondence and comments
Richard H. Fuller
ERM - Southwest, Inc.
Greg Tipple
Texas Water Commission
Re: Focused Feasibility Studies
16
OOuOBS
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/19/86
Transmittal letter
Robert S. Newton, Project Coordinator
I.T. Corporation
Greg Tipple
Texas Water Commission
Additional work tasks
13
000084
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Nirnber:
Odessa Chroniirn II

T11M
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/30/86
Correspondence
Robert S. Newton, Project Coordinator
I.T. Corporation
Greg Tipple
Texas Water Commission
Response to Comment on Pipe Sizing
2
000085
Document Date
Docunent Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
09/30/86
Correspondence
James B. Harris
Thompson & Knight, Attorneys
Allyn M. Davis
U.S. E.P.A.
Objections to E.P.A. Responsiveness Sumary
8
000086
Docunent Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number
10/10/86
Correspondence
Greg Tipple
Texas Water Commission
Bob Dickerson, Manager
Woolley Tool and Manu. Div.
Access Agreement
M
00008?
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
10/1V86
Correspondence
Greg Tipple
Texas Water Commission
J&R Industries

Monitor Well Access Agreement
3
000088
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Number:
Odessa Chromiun II

T11K
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
10/1V86
Correspondence
Greg Tipple
Texas Water Commission
Bowden Construction Co.

Monitor Well Access Agreement
5
OOU089
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
10/15/86
Correspondence
Carl E. Edlund
U.S. E.P.A.
James B. Harris
Thompson & Knight, Attorneys
Response to 09/30/86 letter (also attached)
11
000090
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Number
10/15/86
Correspondence
Stanley G. Hitt
U.S. E.P.A.
Gerold K. Fugit
Attorney
Chromium sources
4
000091
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
10/16/86
Correspondence
Greg Tipple
Texas Water Commission
Vern Foreman
Foreman Electric Co.
Access agreement
2
000092
-------
ADMINISTRATES RECORDS INDEX
Job Name:

Job Nunber:
Odessa Chrcmiun II

TVU
Document Date
Docunent Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Docunent Nunber
10/16/86
Memorandum
Jeffrey A. Lybarger, M.D.
ATSDR
Carl Hickam, Public Health Advisor
U.S. E.P.A.
Health Assessment Clarification
2
000093
Docunent Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Docunent Nunber
10/16/86
Correspondence
Greg Tipple
Texas Water Commission
Jerry Huckaby, President
Basin Radiator 4 Supply
Access agreement
2
00009^
Docunent Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Docunent Nunber
10/23/86
Addendun to Sampling Plan Rev. 2
Robert S. Newton
I.T. Corporation
Greg Tipple
Texas Water Commission
Site Investigation and Feasibility Studies
3
000095
Document Date
Docunent Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Docunent Nunber
12/16/86
Memorandum
Jim McGuire
U.S. E,P.A.
Carl Hickam - ATSDR
U.S. E.P.A.
Odessa Chrcmiun
5
000096
I and II Sites
-------
ADMIN'ISTP.ATIVE RECORDS INDEX
Job Name:

Job Nunber:
Odessa Chrar.iurr II

Tim
Docunent Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
12/22/86
Correspondence
Greg Tipple
Texas Water Commission
Danny Patel, Manager, Sundown Motel
Odessa businessman
Water Well Chromium Contamination
4
000097
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
12/31/86
Memorandum
Jim McGuire
U.S. E.P.A.
File
U.S. E.P.A.
FS Objectives
U
000098
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
01/21/87
Correspondence
Greg Tipple
Texas Water Commission
Robert Monk, Project Coordinator
I.T. Corporation
Waste classification
1
000099
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
02/03/87
Memorandum
Stanley G. Hitt
U.S. E.P.A.
Greg Tipple
Texas Water Connission
Clarify impact of S.A.R.A.
2
000100
-------
ADMINISTRATIVE RECORDS INDEX
Job Name: Odessa Chremion II

Job Nunber: T11M
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
02/06/87
Memorandum
Carl R. Hickam
ATSDR
Jim McCuire
U.S. E.P.A.
Draft Interim Health Assessment
2
000101
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
02/24/87
Memorandum
Jim McGuire
U.S. E.P.A.
File
U.S. E.P.A.
Scope of Work Revisions
2
000102
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
02/2V87
Correspondence
Alan D. Husak, Project Manager
I.T. Corporation
Greg Tipple
Texas Water Commission
Finalization of Objectives and Criteria
3
000103
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
02/2V87
Memorandum and Scope of Work
Alan D. Husak, Project Manager
I.T. Corporation
Greg Tipple
Texas Water Commission
Impact of S.A.R.A. on Remaining Portion FS
19
0001OM
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Number:
Odessa Chromiuri II

T1U
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
02/27/87
Memorandum and attached survey form
Bonnie J. DeVos
U.S. E.P.A.
David Sorrells
Texas Water Commission
I.T. Survey
2
000105
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
03/27/87
Memorandum
Carl S. Hickam
ATSDR
Jim MoGuire
U.S. E.P.A.
Health Assessment
2
000106
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
OV2U/87
Record of Communication
Jim McGuire
U.S. E.P.A.
Robie Hirt
U.S. E.P.A.
Request that TWC Prioritize Project
1
000107
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
05/87
Scope of Work
Texas Water Commission

I.T. Corporation

Price Susnary Format for Subagreanents
7
000108
-------
ADKINISTRATIVELRECORES INDEX
Job Name:

Job Nunber:
Odessa Ghrmiun II

T11H
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
05/06/87
Correspondence and laboratory summaries
Robert G. Monk, Project Coordinator
I.T. Corporation
Patricia Curl
Texas Water Commission
Lab Information and Additional Work Tasks
9
000109
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Nunber
05/06/87
Transmittal
Robert G. Monk, Project Coordinator
I.T. Corporation
Patricia Curl
Texas Water Commission
Final Scope of Work Remaining Portion - FS
12
oouiio
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nur.ber
05/07/87
Report
Alan D. Husak, Project Manager
I. T. Corporation
Patricia Curl
Texas Water Commission
Technology Screening Remaining Portion - FS
13
000111
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
05/18/87
Memorandum
Jim McGuire
U.S. E.P.A.
Jim Steed
Texas Water Commission
Conditional Approval of SOW
1
000112
-------
ADMIN'ISTRATTVF RECOR2S INDEX
Job Name:

Job Number:
Odessa Chrarivin II

T11U
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
05/22/87
Memorandum
Alan D. Husak
I.T. Corporation
Patricia Curl
Texas Water Commission
Remedial Alternatives development
3
000113
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
06/87
Final Report
I.T./Howell Eng.

U.S. E.P.A.

Remedial Investigation - Volume I
196
00011H
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
06/87
Final Report
I.T./Howell Eng.

U.S. E.P.A.

Remedial Investigation - Volume II
208
000115
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
06/87
Final Report
I.T./Howell Eng.

U.S. E.P.A.

Remedial Investigation - Volume III
267
000116
-------
.-::;r..., ;u.i;r. .COORDS INDEX
Job Name:

Job Number:
Odessa Chrcmius II

T1U
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description

Number of Pages
Document Nusber
06/25/87
Questionnaire
U.S. E.P.A.

Residents of SuperFund-impacted area

Survey of residences/businesses in
SuperFund-impacted areas
93
000117
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description

Number of Pages
Document Number
06/29/87
Record of Communication
Mark Fite/Jirc MoGuire
U.S. E.P.A.
I.T./Howell Eng.

Discuss results of owner/tenant survey and SOW
for design of water system
2
OOU118
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
07/07/87
Memo and SOW Remaining Portion FS
Larry R. Soward, Executive Director
Texas Water Commission
Alan D. Husak, Project Manager
I.T. Corporation
Necessary changes to SOW
24
000119
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Number of Pages
Document Number
07/08/87
Correspondence
Robert G. Monk, Project Coordinator
I.T. Corporation
Patricia Curl
Texas Water Commission
Remedial Alternatives - Remaining Portion - FS
6
000120
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Number:
Odessa Chrcriun II

T1U
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
07/17/87
Record of Communication
Mark Fite/Jim McGuire/Stan Hitt
U.S. E.P.A.
I.T./Howell Eng.

Odessa AWS Remedial Design and Survey results

000121
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber

Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
07/21/87
Survey Summary and Site Survey Questionnaires
Robert G. Monk, Project Coordinator
I.T. Corporation
Jim McGuire
U.S. E.P.A.
Survey Summary and Site Survey questionnaires
33
000122
07/2V87
Transmittal Memo and Water Design Scope of
Robert G. Monk, Project Coordinator
I.T. Corporation
Jim Steed
Texas Water Commission
Scope of Work - Water System Design
21
000123
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
07/31/87
Memorandum and attachments
Carl Edlund
U.S. E.P.A.
David Sorrel Is
Texas Water Commission
SOW water design costs/schedule excessive
13
000124
-------
ADMINISTRATIVE RECORDS INDEX
Job Name:

Job Number:
Odessa Chrcmiiin II

T11M
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
08/05/8?
Memorandum and attachments
Patricia Curl
.Texas Water Commission
Robert G. Monk, Project Coordinator
I.T. Corporation
Use of POTW inappropriate
9
000125
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nirnber
08/05/87
Cost breakdown
I.T. Corporation

U.S. E.P.A.

Cost breakdown Odessa Chromiun I, II
8
000126
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description

Nunber of Pages
Document Nunber
08/1V87
Correspondence
David Sorrells
Texas Water Commission
Carl Edlund
U.S. E.P.A.
Rebuttal of Edlund1 s 07/31/87 memo Re: Excessive
Costs
2
000127
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
08/18/87
Correspondence and attachment
Robert G. Monk, Project Coordinator
I.T. Corporation
Jim Steed
Texas Water Commission
Rev. 1, SOW Alternate Water System Design
19
000128
-------
ADMINISTRATIVE RECDRTK
Job Name:

Job Nunber:
Odessa Chrcrniun II

ITU
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
08/19/87
Record of Communication
Jim Steed/Alex Onjanow
Texas Water Commission
Jim McGuire
U.S. E.P.A.
Discuss the RD for Phase 2 of Odessa AWS Design
2
000129
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
08/20/87
Record of Communication
Bonnie DeVos
U.S. E.P.A.
Kark Fite
U.S. E.P.A.
Phase 2 RD for Odessa I and II AWS
1
000130
Document Date
Document Type
Originator
Originator - Affiliation
Recipient
Recipient - Affiliation
Description
Nunber of Pages
Document Nunber
08/2V87
Record of Communication
Mark Fite
U.S. E.P.A.
Jim Steed
Texas Water Commission
Odessa AWS Phase 2 Design
1
000131
-------
-------

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-------
ATTACHMENT B
ATSDR HEALTH ASSESSMENT
-------
DEPARTMENT OF HEALTH * HUMAN SERVICES put>l,c Health Service
Agency for Toxic Subttancet
and Disease Regiitry
Atlanta GA 30333
EMORANDUM

1UBJECT: Health Assessment
Odessa Chromium I & II (61-87-084)
Odessa, Texas

TOOM: Senior Public Health Advisor
Agency for Toxic Substances and Disease Registry
Regional Office for Health Response

?0: Mr. Jim McGuire
Texas Remedial Section (6H-ST)

>ATE: March 27, 1987
5TATEMEHT OF PROBLEM

Fhe Environmental Protection Agency (EPA), Region VI Office, has asked the
Vgency 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.

• 0
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.
Location

4318 Brazos
Meridian Oil
Basin Radiator
Wooley Tool
NDT/Foreman Electric
Total Sample Number of
Chromium Depth Samples
(mg./kg.) (Ft.)
1311 0-2.5 7
367 0-2.5 10
162 0-2 3
178- 0-2 2
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 do 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 fora.

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 identifies 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 »oil ia a potential health
concern, samples should be taken at the surface, rather than from a boring.

3. Bexavalent chromium data should be used in the evaluation of the airborne
exposure pathway, aince hexavalent chromium ia a carcinogen via inhalation.

4. Where the average total chromium levels in surface soil are greater than
3,000 mg./k*.. and soil ingestion ia 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'Connor
arlR. Hickam, R.S.
-------
ATTACHMENT C
COMMUNITY RELATIONS/PUBLIC COMMENTS
-------
Odessa Chromium I and
Odessa Chromium II Sites
Responsiveness Summary

This community relations responsiveness summary is divided 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 3 and Odessa Chromium II Superfund sites.

Section II: Summary of Major Consents Received during the Public Comment
Period and the EPA Responses to the Comments.

Beth 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, 1937, announcing the availability of the Feasibility
Study and EPA's preferred alternative and invited people to an "open house"
on January 5, 19B8. 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 witn 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 Supsrfund process and the cleanup alternatives,
provided details about the public comment period and the public meeting
to be held on January 21, 1938.

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 Responses

A summary of the comments provided during the comment period is provided
be!ow.
-------
Comment />!

Which groundwater treatment process could cause an increase in the total
dissolved solids of the groundwater?

EPA Response to Comment 11

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)?

EPA Response to Comment 12

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 13

Will the electrochemical treatment of the chromium contaminated groundwater
generate a hazardous residue?

EPA Response to Comment #3

No. During the treatment process, up to thrity-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?
-------
EPA Response to Comment 14

No. The remedial investigation found that the soils contain trivalent chromium
rather than the more toxic and mobile hexavalent form of chromium no* 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 15

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.

EPA Response to Comment 15

We disagree. Based on computer simjlations of the "no action" remedy, the
chronium 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 chronium 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 chromium 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.

EPA Response to Cogent ?6

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 bottor 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 drinkingwater.

Comment 17

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 1985.

EPA Response to Coronert *7

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 sunnier and is currently being updated. The update will
include comments regarding the remedial alternatives received during the
comment period.

Comment #8
The Agency has overestimated the current and future boundary and volume of
the chromium plumes at both sites.
-------
EPA Response to Comment 18

EPA disagrees. The plume boundary and volume of chromium contaminated ground
water 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/1 and computer modelling. Attempts were made
to verify the historical date when possible; however, several existing wells
had been plugged following previous sampling events thus collection of verifi
cation 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 wsre 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 E5A proposing the use of the current maximum contaminant level
(MCL) for cnron-ijn when the standard is being reviewed by EPA's Office
of Drinking Water?

EPA Response to Comment 19

The original M2L for chromium established under the Safe Drinking Water Act
was promulgated as 0.05 mg/1 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
19S8. 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/1 will be used.

Comment
Is it necessary to reduce the chromium levels in the groundwater when there
has been no indication that the individuals who reside or work in the impacted
area have been adversely affected by drinking contaminated water?

EPA Response to Comment 110

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 promul gated 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?

EPA Response to Comment 111

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 112

The proposed locations of the extraction and injection wells to be used as
part of the groundwater recovery system needs to be reevaluated.

EPA Response to Cement M2

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 modelling to refine the
estimated pluno bojndaries.

Comment 013

Has the shaft/boring recovery well system that is proposed for use at the
Odessa Chromium II site ever been used in groundwater remediation?

EPA Response to Comment 113

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
-------
ENVIRONMENTAL
7 PROTECTION
AGENCY
borings. The system is required due to the low perneabil ity of the perched
zone at Odessa II. If tests conducted during design indicate the permeabtJAULAS, TEXAS
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?

EPA Response to Comment 114

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 ths use** 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
Did the Magnetically Activated Electrochemical Reactor get screened from
further consideration in the Feasibility Study becajse the United States
sales office closed?

EPA Response to Comment 115

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/1 . Although ths technology appears to be capable of remediating
the groundwater, ACTIMAG 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 116

In-situ treatment technologies should have been considered in more detail by
the EPA during the evaluation of remedial technologies.

EPA Response to Comment 116

In-situ treatment technolgies 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.
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