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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                                      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

      <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

-------
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

-------
                                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.

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            ATTACHMENT C
COMMUNITY RELATIONS/PUBLIC COMMENTS

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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.

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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?

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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.

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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.

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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

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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

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                                                                        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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