United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-86/010
Sept. 1986
4EPA
Superfund
Record of Decision
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TECHNICAL REPORT DATA
(Please read InslnJctions on the revene before completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R06-86/010
4. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECIS ION September 8, 1986
Odessa Chromium I, TX S. PERFORMING ORGANIZATION CODE
7. AUTHOR IS) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Agency Final ROD ReDOrt
401 M Street, S.W. 14. SPONSORING AGENCY CODE
Washin~ton, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Odessa Chromium I site consists of a series of chromium contaminated wells withi~
300 acres of residential, commercial and industrial properties and facilities just
outside the northwestern city limits of Odessa, Ector County, TX. 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. Two potential
sources of groundwater contamination at the site have been identified: the 4318 Brazos
property, and Nipco at 2104 West 42and Street. Between 1972 and 1977 several chrome
plating operations functioned at the 4318 Brazos property. Waste water from the plating
operations and heavy metal contaminants are believed to. have been dumped directly onto
the ground on the northern side of the building and/or piped into storage tanks/drums
which frequently were allowed to overflow. An abandoned well on the site is suspected
of providing a direct pathway to the aquifer during periods of substantial disposal or
heavy rain. Nipco, also on the Odessa Chromium I site, is presently operating a metal
plating facility. In November 1983, the Texas Department of Water Resources (TDWR)
requested the EPA conduct a planned removal action to extend the city water lines to the
affected area. However, in June 1984, the TDWR notified EPA that the plan was not
feasible due to an Odessa city ordinance prohibiting the supply of water to customers
(See Attached Sheet)
17. KEY WORDS ANO OOCUMENT ANALYSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Odessa Chromium I, TX
Contaminated Media: gw
Key contaminants: chromium, heavy metals
18. DISTRI8UTION STATEMENT 19. SECURITY CLASS (Tllis R~po") 21. NO. OF PAGES
None 41
20. SECURITY CLASS (Tllis pagel 22. PRICE
None
EPA 'o,m 2220-1 (Ro.. ~-77)
-------
EPA/ROD/R06-86/010
Odessa Chromium I, TX
16.
ABSTRACT (continued)
outside the city limits. The primary contaminants of concern include
chromium and other heavy metals.
The selected remedial action includes negotiating agreements with the
city and consumers to extend the city water system, and construction of a
water distribution system. The estimated capital cost for this action is
$247,920 with annual O&M costs of $14,350.
-~..
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..
Record of Decision
Remedial Alternative Selection
SHE:
Odessa Chromium I, Odessa, Texas
Documents Reviewed
I am basing my decision on the following documents describing the analysis
of cost effectiveness of remedial alternatives (operable unit) for the
Odessa Chromium I site.
o Odessa Chromium I Remedial Investigation Report (April 1986)
o Odessa Chromium I Alternative Water Supply Feasibility Study (June 1986)
o Summary of Remedial Alternative Selection
o Responsiveness Summary
Description of Selected Remedy
o Negotiate agreements with city and consumers to extend city water system.
o Construct water distribution system.
Declaration
Consistent with the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980 (CERCLA) and the National Contingency Plan (40
CFR Part 300), I have determined that the selected remedy for the Odessa
Chromium I site is a cost-effective remedy and provides adequate protection
of public health, welfare and the environment. The State of.Texas has
been consulted and agrees with the approved remedy (Attachment A). In
addition, the action will requlre future operation and maintenance activities
to ensure the continued effectiveness of the remedy. These activities
will be considered part of the approved action and eligible for Trust
Fund monies for a period of 1 year.
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
sites and is necessary to protect public health, welfare or the environment.
~~/j~
CU~W
Dick Whittington, P.E.
Regional Administrator
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
OPERABLE UNIT - ALTERNATE WATER SUPPLY
ODESSA CHROMIUM 1
ODESSA, TEXAS
SEPTEMBER 1986
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TABLE OF CONTENTS
Site Location and Description ------------------------------------------ 1
Site History ----------------------------------------------------------- 1
Current Site Status ---------------------------------------------------- 2
Exposure Assessment ---------------------------------------------------- 6
Applicable or Relevant and Appropriate Requirements ---~---------------- 6
Community Relations ---------------------------------------------------- 7
Enforcement ------------------------------------------------------------ 7
~
Alternative Evaluation ------------------------------------------------- 8
Recommended Alternative ----------------------------------------------- 12
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
OPERABLE UNIT - ALTERNATIVE WATER SUPPLY
Odessa Chromium I
Odessa, Texas
September 1986
SITE LOCATION AND DESCRIPTION
The Odessa Chromium I Superfund site consists of a series of chromium
contaminated wells within 300 acres of residential, commercial, and
industrial properties and facilities immediately west of West County Road
just outside the northwestern city limits of Odessa, Ector County, Texas
(Figure 1-1). Based on the boundaries of th~ known chromium groundwater
contamination in the Trinity Aquifer, the affected area is bounded by 48th
Street to the north, West County Road to the east, 43rd Street to the
south, and one-half block west of Brazos to the west (Figure 2-11). The
site area is composed of a mixture of residential, commercial and industrial
facilities. Nearly every residence or commercial facility is served by
one or more water wells completed in the Trinity aquifer which offers the
only source of potable groundwater.
SITE HISTORY
Two potential sources of groundwater contamination at the site have been
identified. They are the past operations at the 4318 Brazos (Figure 2-11)
property and Nipco at 2104 West 42nd Street (Figu~e 2-11). The 4318 Brazos
site was first developed between 1954 and 1961. Several chrome plating
operations have functioned at the property between 1972 and 1977. Prior
to 1979 a water well at 4313 West County Road became contaminated by
chromium and was abandoned. In December 1979, the Texas Department of
Water Resources (TDWR) identified 4318 Brazos as a potential source of
chromium contamination. A water well and drums at the property were
contaminated with chromium. Although chromium is the contaminant of
greatest concern at the Odessa Chromium I site, other heavy metals have
~/ been found in soils at 4318 Brazos and 2104 West 42nd Street.
The site at 2104 West 42nd Street was first developed in 1954. Nipco is
presently operating a metal plating facility on the site. The Nipco
property was first identified as being a possible source of chromium
contamination in groundwater in 1978 when TDWR investigated a complaint
of chromium in a well at 38th Street and Rasco. In 1979 Nipco modified
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OIL WELL
SUPERFUND IMPACT SERVICE AREA
CHROMIUM CONTAMIN,~ TION PLUME
~RP. PROPERTY
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2
In November, 1983, TDWR requested the Environmental Protection Agency
(EPA) to conduct a "planned removal action" to extend the city water
lines to the affected area. In June 1984, TDWR notified EPA that the
proposed water system extension did not appear feasible due to the opposition
by residents to annexation by the city of Odessa. With the exception of
specially defined industrial areas, the city of Odessa is prohibited by
ordinance from supplying water to customers outside of the city limits.
In September, 1984, the Odessa Chromium I 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
cooperative agreement with EPA for $530,000 on September 26, 1984, to
perform Forward Planning and Remedial Investigations/Feasibility Studies
(RI/FS) at the site. The RI began in August 1985 and a draft report was
submitted April 1986.
. t
..
In January 1986, EPA and the Texas Water Commission (TWC) decided to
produce a "Focused" Feasibility Study (FFS). The single purpose of the
FFS was to be the examination of possible alternative water supplies
which could provide potable water to the area(s) within the greater
Odessa Chromium I site where groundwater is contaminated or could reason-
. ably be expected to become contaminated by chromium within 24 months. While
the goal of EPA is to determine a plan for addressing the chromium
contamination in the groundwater, the FFS placed a portion of the full
feasibility study on a "fast tracked" schedule. By doing so, it opened
the possibility of expediting the supply of potable water to affected
residents without waiting for completion of the full FS. The FFS began
in March 1986, and a revised dr~ft report has been-submitted.
CURRENT SITE STATUS
Geology
The surficial soil in the site area is principally Amarillo loam.
Generally, it is a reddish-brown, fine sandy loam which ranges in depth
from 8 to 12 inches below grade. Below that, to depths varying from 18
to 24 inches, the red or chocolate-red subsoil grades from fine sandy
loam to sandy clay, gradually becoming heavier with depth. Pleistocene
windblown sand, playa deposits and alluvium deposits underlie the soil
section. Beneath the Pleistocene are Plio-Pleistocene caliche deposits.
Underlying the caliche are scattered erosional remnants of the Tertiary
Ogallala formation composed of gravels, sands, silts and clays. These
basal sediments occupy previously eroded drainage valleys and are not
present everywhere. Cementation of the sands is variable within the
Ogallala. This formation does not generally extend to depths below 75
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3
The Cretaceous Trinity formation. the main fresh water producing aquifer
in the area. underlies the Ogallala interval. It is composed of sands and
sandstones with minor amounts of siltstone. clay and gravel. Cementation
of the Trinity in the site area ranges in degree from moderate to heavy.
The aquitard beneath the Trinity formation is the Dockum Group of Triassic
age. locally known as IIredbeds.1I The upper unit. the Chinle Formation.
consists of up to 600 feet of red and reddish-brown clays and shales.
Groundwater
The major hydrologic units containing potable water in ~he site area are
the Ogallala formation at approximately 70 feet below the area and the
Trinity Sand at approximately 90 feet below the area (Figure 2-2). In
general. the Ogallala is hydrologically connected with the underlying
Trinity and has little or no saturated thickness. A few miles to the
southwest the Ogallala has been totally eroded and within the site area
is only a thin remnant containing little water. Groundwater occurs
beneath the site mainly in the Trinity Sand.
The hydraulic characteristics of the Ogallala are of greater importance
locally than the quantity of water present due to the fact that the
Ogallala may pot~ntially act as a medium through which contaminants may
. enter the underlying Trinity Aquifer. Barriers to vertical movement
exist in the Ogallala as discontinuous lenses of calcite or cemented
sandstone. These lenses were encountered in drilling at the site and
vary from less than 6 ~nches to several feet in thickness. Although no
perched water zones were encountered in drilling. these lenses could act
locally as a barrier to vertical migration of water.
~
. .
It was suspected prior to any deep borings being constructed. as part of the
site investigation. that a IIperchedll water table may exist beneath at
some portions of the site area. Although some thin clay and siltstone
layers and a well cemented sandstone layer were encountered above the
regional water table. no water was found to be IIperchedll on these potential
aquitards or confining beds. This indicates that there is fracturing
sufficient to enhance downward migration of groundwater present and/or
that the layers themselves are of limited areal extent and discontinuous.
Another influence on contamination movement
near the surface. ~hallow borings indicate
effective barrier to the downward migration
leaching of the soil.
Well Inventory
seems to be the caliche layer
that it acted as a relatively
of contamination caused by
An inventory of existing water wells in and around the previously identified
area of chromium contamination was conducted in September 1985. The .
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4
plume of chromium contamination. Over 200 wells were identified during
the inventory, of which more than 150 were sampled and analyzed, for
hexavalent chromium. The inventory covered an area extending in a radial
direction about ha1f-a-mi1e from the known areas of groundwater contamination.
Fifteen wells were found to be contaminated with chromium.
From the well inventory, several conclusions were drawn about the
contamination plume. The shape of the plume associated with 4318 Brazos
site has become more restricted as a result of information gained during
the well inventory. One of the wells to the east of 4318 Brazos which
previously had been contaminated did not show any detectable levels of
chromium during the inventory. Consequently, the south~rn portion of
the plume is confined solely to 4318 Brazos. The plume extends northward
and broadens further to the east. Based on the water level measurements
and corresponding gradient, the source area appears to be 4318 Brazos.
.
The well at 38th and Rasco previously identified as being contaminated, did
not show chromium in this recent survey. A well one block to the east,
at 3911 Brazos, was detected as having chromium concentrations well above
the drinking water standard. This was the only well identified in the
study area south of the main plume area to have any detectable chromium
concentrations. Based on inventory results, water from the well is not
. used for drinking water purposes and is too salty for human consumption.
The well provides water for washing and toilet purposes only at a
commercial establishment.
A new area of contamination consisting of five wells was identified on
the west perimeter of the well inventory study area. The chromium
contamination levels ranged from 0.02 to 0.21 mg/1. No readily obvious
source of the contamination was identified and,the Odessa Chromium I Site
RI/FS or FFS was not expanded to include this area. The five wells are
serving commercial establishments and ~re not being used for drinking
water purposes. Use of the water is limited to washing, toilet or industrial
use. .
Present and Projected Contamination Area
The estimated extent of chromium contamination in the Trinity aquifer is
shown in Figure 2-7. Historical levels of chromium concentrations measured
in area wells between 1978 and 1986 are presented in Table 2-4. As seen in
the figure, the plume extends northward from 4318 Brazos beyond 46th
Street. Samples collected from the newly installed monitoring wells have
confirmed the chromium contamination within the plume and also have aided
in the closer definition of the areal extent of the contamination.
The contamination beneath the 4318 Brazos site is heavily concentrated in
the upper portion of the Trinity. Waste water from the plating operations
is believed to have been dumped directly on to the ground on the northern
side of the building and/or piped into storage tanks/drums which frequently
were allowed to overflow. An abandoned well on the southeastern corner
of the building is suspected of providing a direct pathway to the aquifer
during periods of substantial disposal or heavy rains. Approximately 200
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5
downward migration of the contamination below 100 feet, no longer is
present and the contamination is free to dissipate throughout the entire
Trinity section.
Sediments, soils and rock at 4318 Brazos show contamination from the
surface to approximately 10 feet and again at around 53 feet. This
indicates that waste fluids generated by the activities there and containing
chromium and other heavy metals were spilled on the surface. The contamination
then entered the soils through a septic tank drain field, traveled laterally
along the upper surface of the shallow caliche layer. downward through
fractures in the caliche, or through the abandoned open 'well bore on the
property, to the Ogallala Formation and ultimately to the Trinity Aquifer.
In addition to these contaminant pathways. it is possible that heavy metal
contamination spilled on the surface was carried by surface water runoff
into the abandoned open well bore on the property, and then, to the zone at
around. 50 feet. .
~
Over the entire area of the Odesssa Chromium I site, the regional groundwater
gradient in the Trinity is to the north and northeast at between 10 and
15 feet per mile. Contaminated water entering the top of the Trinity
aquifer spreads out horizontally in a northerly direction. Vertically,
. it can be presumed that the contaminants are initially "perched" in the
upper portion of the Trinity until the hard streak at about 100 feet
disappears. The contaminants then move progressively deeper with increasing
distance from the source in this relatively homogenous aquifer.
As shown in Figure 2-7, there appears to be one major plume of chromium
contamination in the Trinity within the site area.- Based on the start of
manufacturing or process operations, and historical sampling data (TWC
records). it is possible to estimate contaminant migration rates for this
plume.
The northern extent of the contamination is beyond 46th Street, more than
1100 feet beyond the source area. Considering that the plating operations
began disposing of wastewater at the 4318 Brazos location, beginning between
14 and 25 years ago. the average velocity of the contaminant migration
can be estimated at between 45 and 80 feet per year.
Using values obtained from a pumping test performed during the RI,
calculated migration velocities for Trinity water range from 50 to 100
feet per year. Empirically derived rates for contaminant migration within
the Trinity appear to be reasonably similar. A conservative projection of
100 feet per year has been used for estimating the maximum extent of
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6
EXPOSURE ASSESSMENT/APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
The public health evaluation process as described in the EPA Draft
Superfund Public Health Evaluation Manual (December 18, 1985) states that
the projected concentration of the indicator chemicals at the exposure
points should be compared to applicable or relevant and appropriate require-
ments. The National Contingency Plan (NCP) defines what is considered
potentially "applicable or relevant and appropriate"; the federally set
drinking water limits are included in the list. Comparison of the data
collected in the RI to health guidelines aids in determining whether
a remedial response action is necessary to protect the public health and
environment.
For the Odessa Chromium I site, the receptor exposure points are assumed
to be the water supply wells. The indicator chemical is chromium and the
applicable or relevant requirement is the Federal Drinking Water Standard
promulgated under the Safe Drinking Water Act (SDWA).
During the Remedial Investigation, two contaminants, zinc and chromium,
were found at levels above the detection limits of 0.05 and 0.01 mg/1
respectively in the existing supply wells tested. All reported values
for zinc are below the EPA secondary maximum contaminant level in drinking
water of 5 mg/1. Zinc at these concentrations is not considered a public
. health concern and is excluded from further consideration in the evaluation
process.
However, reported chromium concentrations may be significant from a public
health perspective. Twelve out of fifteen contaminated wells sampled
during the RI had chromium levels at or above 0.05 mg/1 [the maximum
concentration limit (MCL)]. Ntne of these twelve ~ells had values at or
above 0.12 mg/1 [the proposed Recommended Maximum Concentration Limit
(RMCL) Federal Register, Nov. 13, 1985], although two were abandoned. See
Table 2-3 for data and summary statistics.
Since chromium has an applicable relevant and appropriate requirement,
i.e., the EPA Drinking Water Standards, that requirement is used as the
basis for the target concentration. Consequently, the public health
evaluation is complete when the concentration of chromium in the wells is
compared to the standard.
The wells with values above the MCL of 0.05 mg/l are not suitable for use
as a lifetime drinking water supply and an alternate water supply is
indicated.
As required by the SDWA, EPA acted quickly following the passage of the
SDWA in publishing Interim Primary Drinking Water Regulations. Regulations
were established for ten inorganic chemicals, six pesticides and two
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, ,
\
DEPTH ( FEET)
o
20
40
60
80
100
120
140
#
LAND SURFACE
SOIL, WINDBLOWN SAND, ALLUVIUM
.
.
CALI CHE
~
~
-------
~
~
SAND AND GRAVEL, OGALLALA
-----------------
\] ,GROUND WATER
(-60' TO 85')
'WE="
TRINITY SAND
(MAtNL Y SAND WITH VARYING
DEGR.EES OF:...,CEMENTATION)
CHINLE FORMATION
(RED CLAYS WITH INTERSPERSED SANDS) .
FIGURE 2-2
GENERALIZED STRATAGRAPHIC SECTION
FOCUSED FEASIBILITY STUDY
ODESSA CHROMIUM 1 SITE
ODESSA TEXAS
PREPARED FOR
TEXAS WATER COMMISSION
AUSTIN. TEXAS
rn /R&A/HOWELL
. '884 IT CORPORATION
ALL COPVRIG...TS RE SERVED
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. -
tilL! 2-3
TOTAL CHJ.C»aOM .~s >0.05 II:/L (MCL)
UPOlnD rOl ElISTlJiG WAnl SUPPLY _loLS
SAMPLED IKJI.1.MG I.I
rOaJSXD PUSIIILITr ImDY
ODESSA CD.CIaOM 1 SID
ODISSA. YIUS
TOTAL
WELL NO. USE CHROMIUM rtrUE NOTE(S)
(IDg!l)
11046(2) ColIIDercial 0.07.0.07.0.06
11115 ColIDDercial 0.07.0.04(3) Outside of Itudy area
11085(2) Commercial 5.1,4.7
11086 (2) Commercial 14.0,13.6
11086A(2) ColIDDercial 1.4, 2.9
11090(2) Commercial 0.6,1.1
11092(2) Commercial 3.4,2.9
11093(2) Commercial 0.39 Abandoned
11094(2) CoIIDercial 1.9
11117 CoIIDDercial 0.21,0.16 Outside of 8tudy area
11154 Colllllerc1al 0.55,0.55
EXlOO(2) CoIIDDercial 1.1 Abandoned
Summary Statistics:
>0.05 mg/l ~21. 1-2.61 .g/1, SD-3.92 .g/1, range -0.05-14.0 .g/1
>0.12 81/1 "16, X-3.21 81/1, SD-4.14 81/1, range - 0.12-14.0 81/1
1. Mil1grams per liter.
2. Shown on Pigure 2-7.
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4415 V. (bunt, Rd. <0.01 <0.01
Pr-1092 Speam8ft I8dlator, 4411 V. OJunty Rd. (4) <0.02 3.4 2.9
£-1093 Mldes8a Rut , Bolt, 4407 v. (hunty Rd. (4) 0.39
Pr-1094(3) eu.t.. Eleetde, 4405 V. (bunt, Rd. (4) 1 :,(6)
&-1095 Henry amter, 2101 V. 44th(4) <0.02 <0.01 <0.01
Sun Rental, 4301 Brazoa(4) I
£-1096 <0.02 <0.01 ,
Frl097 BiB State Bit Servlee, 4313 V.
-------
--- - .
RtSTORICAL mxJRD or OIROMIUt ~nONS
(Continued)
V!LL NO. tOCAnON 11/78(1) 12/79( t) 1-3/8:J( t) H/8:J( I) 09/85(2) 11/85(2) 2-3/86(2)
£-1154 Anco Battery, 3911 Brezo. 0.55 0.55
£-1164 Pallier O:Jntracting, 3800 1tasco <0.02(7) <0.02 <0.01
5-1165 Bretts Tral1er Paft, 2153 W. 39th <0.02 <0.01
£-1174 (bBpres80r OMIponents, 2605 W. 42nc1 0.02
..
5-1175 'tUn 1Iest Oilfield Services, 2700 W. 40th <0.01
£-1176
-------
48 ,n. oi;) I. -
. "\ 0 ['1048 N
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PROJECTED PLUME EI04S
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NOTI ' (II ,,'PII01t'IilATI
LOCATION
43 rd.
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01.1101 ::» 0 UIITIIIG WELL
\ .D ('10" 0 + IIOIIITOII .E~L
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-------
---
.
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WELL 1ft). LOCAnOW 11/78(1) 12/79( I) 1-3/83( t) 5-6/83(1) 09/85(2) 11185(2) 2-3/86(2)
Ex-IOO(3) 4318 IJruo8(4) 190.0 4.~ 1.1
PJt-l0l(3) 4316 1Ir'azo8(4) 0.27 0.1
-------
\
7
The Maximum Contaminant Level (MCL) for total chromium under the National
Interim Primary Drinking Water Regulations was set at 0.05 mg/1 in 1977
and was based on the 1962 Public Health Service limits.
As a second step, EPA was required to propose and promulgate Revised
Primary Drinking Water Regulations. To revise the Interim Primary Drinking
Water Regulations, the Agency must first propose and promulgate a
recommended maximum concentration limit, which is a non-enforceable health
goal based on the premise that "no known or anticipated adverse effects
on the health of persons will occur and which allows an adequate margin
of safety". (Federal Register, Nov. 13, 1985, p. 46937).
Chromium is classified in EPAls Guideline~ for Carcinogenic Risk Assessment
as a Class A carcinogen, based upon positive inhalation data for hexavalent
chromium in humans and animals. The Class A category is at the top of
the scale, indicating the greatest strength of evidence suggesting the
chemical IS carcinogenicity.
The evidence indicates, however, that hexavalent chromium is carcinogenic
when inhaled as a fume but not when ingested. Since chromium has not
been shown to be carcinogenic through ingestion exposure, EPA has recently
proposed a RMCL based on chronic toxicity data. A RMCL of 0.12 mg/1 is
proposed for total chromium, i.e., Cr III plus Cr VI in drinking water
(Federal Register, Nov. 13, 1985). '
The third step will be for EPA to propose a MCL as close to the RMCL as
feasible. Feasible is defined as "with the use of best technology treatment
techniques and other means which EPA finds are generally available (taking
cost into consideration)". The new chromium MCL will probably be proposed
by EPA in the fall of 1986. Stnce the RMCL is a goal, the MCL will most
likely be set at or above the RMCL limit of 0.12 mg/1.
COMMUNITY RELATIONS
This section will be completed after the public comment period.
Attachment B).
(See
ENFORCEMENT
-t
,-''I,;;
The goal of the EPA is to have those parties responsible for contamination
of the site perform the cleanup of the site. The Agency has identified
at least five potentially responsible parties at the Odessa Chromium I
site. These parties have been notified that they may undertake, or
participate in, the chosen remedy. If they decline involvement in the
-------
8
ALTERNATIVES EVALUATION
The presence of chromium in water supply wells at levels above the maximum
contaminant level established under the National Interim Primary Drinking
Water Regulations represents a threat to present and future public health
and welfare. A response to the release of chromium in the groundwater is
appropriate in accordance with the National Contingency Plan (NCP), 40 CFR
Part 300. The response action toward mitigating the release of chromium
is currently under study in accordance with the NCP, 40 CFR 300.68(d).
A discrete part of an entire action that will decrease the pathway of
exposure is known as an operable unit. An operable unit, 40 CFR 300.68(c),
may be implemented before final remedial action is selected for a site.
The cleanup of groundwater contamination plumes is so time-consuming
that a need for alternative water supply is often required to protect
public health and welfare until the completion of the remedy. Alternate
water supplies can be provided as an operable unit of the entire action.
To satisfy NCP requirements, including the requirement that the operable
unit be cost-effective and consistent with"a permanent remedy, 40 CFR
300.68(c)(3), a FFS was completed for the Odessa Chromium I site. The
purpose of the FFS was to develop and evaluate alternative water supply
- options in terms of cost, acceptable engineering practices and effectiveness
in contributing to the protection of public health, welfare and .the
environment.
The FFS was written in accordance with current- EPA guidance,
"Guidance Document for Providing Alternative Water Supplies"
"Guidance on Feasibility Studies under CERCLA". Seven water
options were identified for evaluation in the PFS:
specifically
(Draft) and
supply
o No Action (Alternative I),
o Development of surface water supply (Alternative II)~
o Development of an oversized community storage facility
to compensate for loss of existing system capacity
(Alternative III),
o Blending the contaminated portion of the water supply
with uncontaminated water supplies to reduce contaminants
to safe levels (Alternative IV),
o Removal of contaminants via treatment (Alternative V),
o Development of a new water well field outside the area
of contamination (Alternative VI), or
o Connection with an existing municipal or private supply
-------
9
These seven alternatives were subjected to an initial screening process
to narrow the list of potential remedial actions for further detailed
analysis (40 CFR 300.68(g)). The three broad criteria used in the initial
screening are cost, acceptable engineering practices and effectiveness. .
A brief description of the alternatives and summary of the initial screening
follows.
No Action (Alternative I)
A new source of potable water would not be supplied to the area under
this alternative. The threat to the public health and environment would
remain unchanged since the affected people would continue to have their
health threatened due to use of chromium contaminated water. This alternative
fails the initial screening criteria of effectively protecting the public
health and welfare.
Development of Surface Water Supply (Alternative II)
The development of surface water (rivers, streams, lakes, ponds and.
reservoirs) would be considered under this alternative. The potential for
developing a new surface water supply from streams, lakes or rivers is
. nonexistent in the site due to the lack of a reliable year round source.
The possibility does exist of purchasing water from the Colorado River
Municipal Water District which maintains storage reservoirs one-half mile
east of the Odessa Chromium I site. This alternative will be expensive and
difficult to arrange but is effective and feasible. Alternative II was
be subjected to a more detailed analysis.
Both these alternatives have two basic prerequisites: a central distribution
system and an existing, low yield supply of potable water which could be
pumped into a storage facility. Neither of the prerequisites is met at
Odessa Chromium I and both alternatives are eliminated from further
consideration.
Removal of Contaminants via Treatment (Alternative vt
A treatment process-to remove chromium from the groundwater to bring the
water within the drinking water standards is considered in this alternative.
This can be accomplished by treatment at individual wells or at a central
treatment plant. Three treatment methods, precipitation, ion exchange and
reverse osmosis, were considered. Precipitation and reverse osmosis,
while capable of removing most of the chromium, would not reduce the
concentration below the drinking water standard of 0.05 mg/l. Only ion
exchange is a viable treatment process. Individual household ion exchange
units are- costly and require sensitive water quality control. A central
ion exchange system offers the fewest number of serious drawbacks and was
-------
10
Development of a New Well Field (Alternative VI)
Under this alternative, a supply of water could be developed by drilling
new wells away from the contaminated area and bringing the water to the
affected area. Due to land use restrictions, ownership restrictions and
locations of poor quality water, only the area south of Yukon Road and
east of Ector Avenue, 3 miles east of the site, can be considered for a
new well field. This alternative will be expensive but is feasible and
is considered for further analysis.
.
Connection with an Existing Municipal Water Supply (Alternative VII)
This alternative would consist of the extension of the city of Odessa
lines beyond the city limits into the affected areas. The city of Odessa
is forbidden by ordinance from supplying water to customers outside the
city limits. Annexation of an area is required in order to extend water
service but residents of the affected area have expressed opposition to
annexation. The alternative does appear feasible in spite of this problem
and is considered for further analysis.
DETAILED ANALYSIS
The preliminary screening process has reduced the seven options for
alternative water supplies down to four options:
o Development of a surface water supply (Alternative II) .
o Removal of contaminants-via treatment (Alt~rnative V)
o Development of a new well field (Alternative VI)
o Connection with an existing municipal water supply system
(Alternative VII)
The preliminary screening process has also shown that for Alternative II
and Alternative VI cost savings can be realized for both by combining
certain portions of the water supply system for the Odessa Chromium I and
II projects. Further discussion will address this condition.
The detailed analysis of the final four alternatives follows the outline
of 40 CFR 300.68(h) which requires an extensive evaluation of the potential
plans. This evaluation includes an engineering analysis, analysis of
implementability, cost analysis, environmental protection analysis,
public health analysis and regulatory/institutional analysis. The cost
analysis is summarized in Table 6-1. Table 6-2 gives the average
residential monthly water bill that can be expected under each plan.
The detailed analysis of the four plans is summarized in Table 6-3.
-------
I .,
~AlLI 6-1
COST COKPnISOIi 0' ALTlMArIVIS
rocoSED FEASIBILITY STUDt
ODESSA CImOMItJM 1 SITE
ODISSA, IfUAS
O&M(l) 0 & K
ALTERNATIVE CAPITAL COSTS PRISENT VALtJE(2) MET PV(3)
11 Surface Water $ 404,500 $ 82,400 $ 626,750 $1,031,250
1Ia Combined
Surface Water 372,400 67,150 510,750 883 ,150
V Ion Exchange 852,900 302,750 2.302,750 3,155,650
VI New We 11 F1 eld 1,819,350 115,250 876,600 2,695,950
VIa Combined 1,759,250 59.000 448,750 2,208,000
Jew Well Field
VII Municipal Water 247,920 14,350(4) 109,150 357,070
IIotea:
(1) O&M - OperatioDs and Maintenance
(2) Prelent Value, based on 15 years, 10% di8count rate and 0% inflation,
for O&M.
(3) Net PV 1s total of capital costs and present value of O&M.
(4) 0 & M costs assumed equal to the annual total of aonthly vater bills
-------
.__....~
tilL! 6-2
COST .11 ftOtJSAHD GiLLON
CClfPAIlSON 0' &LtlUATIVIS
rocoSED PlASIIILIT! STUDY
ODESSA CBJ.OKlUK 1 SIft
ODISSA, ftU.S
AVERAGE
ALTERNATIVE COST ($)/THOUSAND GALLONS(1) IES~DENTlAL MO~LY
WATER BILL
11 Surface Water 14.62 219.27
l1a Combined 6.54(3) 98.13
Surface Water
V Ion Exchange 31.56 473.39
VI New Well Field 20.45 306.68
VIa Combined 6.44(3) 96.67
New Well Field .
VII Municipal Water 7.70/1.35(4) 37.88
lIote:
(1) Costs are annual O&M cOlts and annual water consumption in
~houlands of gallons.
(2' Based on fifteen thousand gallons.
(~) Based on combining water con.umption for both Odessa 1 and Odessa
11 and O&M costs for Odessa 1 and Odessa 11 .ince residents would
- be part of the .ame water a..ociation. . .
(4) For first two thousand lallous, $7.70 Iftt $1.35 per thousand
-------
.-
- .
TAILI 6-J .
ftaUnCAL/11Ift11'UT101fAL ClOMP".,,, or ALftUATlnS
POQI5p.n FPASHm.'n S11JtIf
OOY-55" CR"",,',," I SIT?
ODP.5SA. mAS
'IlOIAJILl
ALTE,,"ATIV!S punIc IlEALT1I aJIIC!,,"S nvIRO~"'AL CONC!MS TEcmetCAL COHCE,,"S ~tTr IIF.SPOHS! ODRC!,,"' ~II
Surfec:e Vater Ie ,roble81 .ntlclp.ted. Short ter. c:on.tructlon Sf.ple technolo~ In RIRh 8Ontbl, "ater bill Llabillt, rar continued
l.p8ct. treat..nt and connection and probl@8 or ror.lnl auppl, re.ta "Ith .
to preaent 8ource. and .alntalnlnl . "ater "ater a.aoclatlon.
aaaoclation.
"' 0"
Ion Z.cb.nle Tre.t8ent ""ntea.nce of f.dllt, Cont-Inant "h..e .., .. Pro.en tre.t8ellt tech- Wt.h 8Ontbl, ..t~ bill Llablllt, for .aln-
to In8ure tb.t cont88- unde.lr.bl, "Idened. nolo~ althou~h requlrea .nd .alntalnlnl a "ater talnlnR accept.hle
tnanta proper I, ~ .trlnlent operational a..oclatloll. Aleo. ,,111 "8ter qual It, r..alne
8O.ed. re.I... tr.at8ent continue to with a w.ter a..oc-
- i function In 10nl ter.' 18tlon.
lie" Vell 'lei. Peteattal concern. Short ter. conatructlon SI.ple tecbnolol' ror Wt.h 8Ontbl, ..ter bill Llabillt, for .alntald
.bout 10"1 ter. quail t, I.pact. obt81nlnl ..ter .uppl, and proble8 or for.lnl Inl vater au"ly re.atn
of Iround ..ter lource. and treat.ent. and .8lntalnlnl a .ater with. .ater
a.aodatton. a.80ctatlon.
Munldp.l Vater Wo probl... eatlclp.te. Short tlr. con.tractlon '1.,11 tecbnolOI1 re- . Omeera ..er potnttal Clt, to ,r..lde _ter
l.pact. quire connection to for Inne.aUon. luppl,.
..I.tlnl Clt, -ter
.8In8.
..
-------
11
D~velopment of Surface Water Supply (Alternative II)
The water supply of the Colorado River Municipal Water District is
(CRMWD) adequate, reliable and of good quality. A water association or
private corporation will be necessary to own and operate the treatment
system and distribution system. The total capital cost is estimated at
$372,400 with annual operation and maintenance cost of $67,150. The
public health will be well served and no adverse environmental impacts
would take place due to this alternative. The city of Odessa has right
of first refusal with CRMWD thereby complicating negotiations for the
water.
Removal of Contaminants via Treatment (Alternative V)
A central system utilizing ion exchange would require at least three
water wells pumping contaminated water from the affected area to the
system. The treatment system would be sophisticated and require trained
personnel working for a water association to run and maintain the equipment.
The capital cost estimate is $852,900 with operation and maintenance cost
estimated at $302,750 annually. A major negative aspect is the requirement
of the three water wells pumping from the contaminated area. The character-
. istics of the aquifer would dictate that the wells be spread throughout
the plume area causing three pumping centers with corresponding cones of
depression leading to further migration of the contaminants.
Development of a New Well Field (Alternative Vl~
The 100-acre tract envisioned (or this alternative,_reportedly contains
enough good quality water to meet the demand of. the Odessa Chromium I
site. Valuable water rights would need to be purchased and a treatment/
distribution system constructed. The estimated capital cost is $1,759,250
with annual operation and maintenance cost of $59,000. No adverse environ-
mental impacts would occur and the public health would be well served by
this alternative.
Connection with an Existing Municipal Water Supply (Alternative VII)
This is the only alternative which considers the purchase of treated
water rather than raw water. The city of Odessa has an adequate supply
of good quality water which more than meets public health requirements.
The extension of the city water lines is simple and inexpensive at $247,92U
in capital cost with annual operation and maintenance cost of $14,350.
No adverse environmental impacts would occur. The city policy of non-
service to areas outside of the city limits is a major restriction but
the city of Odessa has indicated a willingness in the form of a March 25,
1986, city resolution to consider a special extension of city water to
-------
12
RECOMMENDED ALTERNATIVE
The National Contingency Plan [40 CFR 300.68(i)] requires EPA to select
the cost-effective remedial alternative that effectively mitigates and
minimizes the threat to and provides adequate protection of public health
and welfare and the environment. Furthermore, the selected remedy must
attain or exceed applicable or relevant and appropriate Federal public
health and environmental requirements that have been identified for the
site. The four alternatives under consideration meet this requirement by
reducing the chromium levels below the maximum contaminant level of 0.05
mg/l. EPA must select from the four alternatives the plan which is
cost-effective. EPA recommends that Alternative VII, Connection with an
Existing Municipal Water Supply, be selected as the cost-effective alternative
for the Odessa Chromium I site. This alternative consists of the extension
of the city of Odessa water lines to the affected area and subsequent
supply of water from the city. Details on the water line extension are
provided in Figures 5-9 and 5-10.
In first analyzing the cost of the alternatives, the recommended
alternative is clearly the advantageous plan. The numbers in Table 6-1
translate into considerable savings if the extension of municipal water
service is implemented over the other three alternatives. A savings of
150% to 780% is realized by Alternative VII. The property owners will
also have much lower water bills under Alternative VII.
In terms of effectiven~s, all the plans meet the goal of supplying water
that will protect the public health and welfare. Only Alternative VII
supplies treated water without the need for constr~ction and operation of
a treatment system. This is an advantage for the extension of municipal
water service. .
Institutional drawbacks are present in all the alternatives. The purchase
of surface water or water rights in Alternative II and VI will be difficult.
The operation of a water association as called for by the three other
alternatives would be a burden to the people in the affected area. These
institutional issues are not present in the recommended alternative, however
the extension of the city.s water lines will require an exception to the
rules governing water supply across city limits. This problem has shown
to be solvable due to the cooperative spirit of the city of Odessa,
giving Alternative ~II another advantage over the other plans.
In summary, EPA recommends the extension of municipal water service to
the affected area of the Odessa Chromium I site as the cost-effective
remedy for this operable unit of the project. The estimated cost is
$357,070 and time of implementation is 9-12 months.
-------
-<>
e.
L.!NE
-
,
~\. -4.
..-.-.-.-.-.-
24.
, IIIIJ:'
.
4 .
-'
..
CIf
~
Q.
RAZOS
-
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I
I
.
C/J
-4
. ROAD
I,.
[
-'1
..
A
-
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AvE.
fit
:-f
,"
'...
. WEST.
.COUNTY .
-.1:::-.-.-.-.-.-.-.-.
6.
LINE
=r
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LINE
I ....
I
FIGURE 5-1}
PROPOSED 'NATE'
nl~Tnl""TI'HJ ~
..
-------
.
J
STREET
PROPOSE
..
3/". TAP
MIWETER - per CITY of OOEsSA
STANDARDS
SE"VICE LINE
(3/". Minimum)
MOBlL.E HOME
or
RESIDENCE
CONNECT °TO EXISTING HOUSE
SERVICE LINE
~CONNECT HOUSE FROM
WELL SYSTEM
EXIST ING
WATER WELL
FIGU RE 5-10
TYPI CAL
PROPOSED WATER SERVICE
CONNECTIONS
FOCUSED FEASIBIL.ITY STUOY
ODESSA CHROMIUM r SITE
ODESSA, TEXAS
PREPAREO FOR
TEXAS WATER COMMISION
AUSTIN, TEXAS
'" 0
IR&A/HOWELL
'9R4 IT CORPOIUTIQN
-------
13
Schedule
The schedule for the design and construction of the alternate water supply
at the Odessa Chromium I site is currently dependent upon reauthorization of
Superfund. The design phase of the project will begin as soon as
funding becomes available, either through reauthorization or a continuing
resolution. When funding is available, the design and construction
-------
-~
.'
ATTACHMENT A
-------
TEXAS WATER COMMISSION
Paul Hopkins, Chairman
Ralph Roming, Commissioner
John O. Houchins, Commissioner
;;..:. . i:T:?:D
'. .".~~".""'J't..
Lar~ ''R.'S~~arli':' Executive Director
.... : ~;ry Jt.6n H'ani!, C+13ef Clerk
James K. Rourke, Jr., GeneraJ Counsel
':I:"::-:\":-L:'Jn ['='AlfCH
\.. - I ~_. I . ,- l \.-d\
Au~ust 21, 1986
Mr. Dick Whittington, P.E.
Regional Administrator
U. S. Environmental Protection
Region VI
1201 Elm Street
Dallas, Texas 75270
Agency
.'
.
,.
Attn:
Mr. Paul Sieminski
Re:
Odessa Chromium I and
Odessa Chromium II Superfund Sites
Dear Mr. Whittington:
This is in response to your letter of August 5, 1986 which
requests our comments and/or concurrence with regard to the
proposed remedy for providing an alternative drinking water
supply to the affected areas at the. Odessa Chromium I and II
Superfund Sites. The draft Summaries of Remedial
Alternatives Selection recommend that ~onnection with an
existing municipal water supply be selected as the cost
effective alternative for the two sites. This alternative
consists of the extension of the City of Odessa water lines
to the affected areas and the subsequent supply of water
from the City. A public meeting was held in OQessa on
August 13, 1986, to discuss the various methods of providing
an alternative drinking water supply and to receive comments
from the public.
The Texas Water Commission has no objection to EPA's
selection of the proposed remedy for providing a potable
water supply to the affected areas at the two sites.
If you have any questions, please have your staff contact
Greg Tipple of our Superfund Section at 512/463-7798.
Sincerely,
~f~
Larry R. Soward
Executive Director
-------
.
.
-------
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY ON POTENTIAL REMEDY MODIFICATION
ODESSA CHROMIUM I & II, TEXAS
This community relations responsiveness summary is divided into the following
sections:
1.
11.
111.
IV.
Overview - This section discusses [PAis preferred alte~native for
remedial action, and likely public reaction to this alternative.
Background on Community Involvement and Concerns - This section
provides a brief history of community interest and concerns
raised during remedial planning activities through a Feasibility
Study at the Odessa Chromium 1 & II sites. .
Summary of Major Comments Received During the Public Comment Period
and the EPA Responses to the Comments.
Remaining Concerns - This section describes remaining community
,concerns that EPA and the PRPs should be aware of in conducting
the remedial design and remedial action at the Odessa Chromium
-------
2
I.
OVERVIEW
In the presentation for the public meeting on August 13, 1986,
The EPA discussed the alternatives developed for implementation of
a corrective action which addresses an alternate water supply
for the Odessa Chromium I & II sites and adjacent and nearby
residential properties.
Based on the Remedial Investigation and the analyses performed in
the Feasibility Study, the EPA proposed to extend the city of
Odessa's water supply system to affected households. This alternative,
if implemented, would provide negotiated agreements between the
City of Odessa and consumers for extending the city.~ater system to
current well users and for the construction of a water distribution
system. Comments from local officials and residents favored this
option, provided that the impacted area would not be annexed to the
. City of Odessa now or in the future.
The. comments on the four alternatives, along with EPAls response
to each, are presented later in this document.
At this time, the EPA has presented the findings of the alternate water
supply study only. The overall study on the groundwater contamination
at the Odessa sites, including remedial alternatives, will be completed
later this year, with public comment to follow.
I I .
MAJOR CONCERNS AND ISSUES
Odessa Chromium I
Community interest, historically at a low le¥el, in the Odessa
Chromium I site, dates back to November 8, 1978, when the owner
of a domestic water well registered a complaint with the Texas
Department of Water Resources (TDWR) - now known as the Texas
Water Commission (TWC). This local resident complained that.
there were odors and an "oily" film present in the water coming
from his well. In 1979, a water well at another particular res-
idence was investigated and found to be heavily contaminated with
chromium.
Odessa Chromium II
A low level of community interest has also existed historically
at the Odessa Chromium II site. Public awareness first surfaced
in 1977, when the TDWR investigated the area and found heavy
metals in three local water wells.
Several local industries were suspected as possible sources of
contamination. These industries generated chromium-contaminated
wastewater as a'result of metal plating activities and cleaning
radiators.
Both the Odessa Chromium I & II sites were added to the National
-------
3
. the city limits of the City of Odessa in Ector County, Texas.
The approximate population of the city is 135,000 residents. The
two sites are surrounded by a few small industrial businesses,
single family residences, a motel, a church, a small city park,
and several mobile home communities. Approximately 550 - 600 residents
are affected by the two sites. These residents are not served by the
City of Odessa municipal water system. The vast majority are on
bottled water, and, while they do not particularly object to being
put on the City of Odessa water system, they strongly object to
annexation by the city and the subsequent encumbrance of city taxes
and fees.
.
.
ACTIVITIES TO ELICIT INPUT AND ADDRESS CONCERNS
After preparation and submittal of a hazard ranking package for
. each site, the TDWR initiated communications with the City of
Odessa, in order to determine the best means available to provide
an uncontaminated supply of drinking water to the residents in
the Odessa Chromium I area.
On April 25, 1984, discussions were held in Odessa with affected
residents in the Odessa Chromium I area to determine their
feelings and wishes with regard to annexation. The overwhelming
sentiment of residents present at this meeting was against
annexation.
On-site discussions were held concerning Odessa Chromium lIon
October 9-10, 1984. During these discussions the residents
expressed th~ following concerns:
"
Local health officials were concerned that there were
not any legal standards for disallowing heavy metals in
drinking water.
2. The same health officials wondered if some of the residents
near the site were unknowingly drinking contaminated water
from small wells that had not been tested.
1.
3.
One resident was concerned that water used by both a church
and a small city park near the site might be contaminated.
On January 10, 1985, a public meeting was held concerning Odessa
Chromium II. Primary concerns at this meeting focused on the
availability of a potable drinking water supply. At that time,
some residents who were providing their own bottled water because
of contamination in their residence wells, were interested in
the possibility of EPA providing a bottled water supply as an
emergency measure until a more permanent remedy could be studied
and determined. At this meeting, there were additional residents
who had contaminated water wells and were not on bottled water
who wanted EPA to provide water.
Subsequent to completion of the Feasibility Study for an alternate
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Council Chambers on August 13t 1986. During the public meetingt
the Environmental Protection Agency summarized and explained the
results of all previous investigationst with particular emphasis
on results from the alternate water supply Feasibility Study.
The EPA described the various corrective measures being considered
by the Agency for the residents affected by the sitest and
outlined opportunities for public involvement. The EPA explained
that the goal of the EPA at both the Odessa Chromium I and II
sites is to implement a corrective action which addresses the
groundwater contamination. The process leading to the groundwater
cleanup is time-consuming; therefore, to protect public health
until completion of the entire remedy, EPA decided to explore
alternate water supply options for those people in the area with
contaminated wells.
EPA discussed its proposed alternativet extension of Odessa's water
supply system to impacted personst at the August 13 meeting and
received comments concerning this alternative and the others considered
in the Feasibility Study. The overwhelming sentiment of residents at
the meeting was their opposition to annexation by the City of Odessa.
III. SUMMARY OF PUBLIC COMMENTS RECEIVED DURING PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES. .
The public comment period on the Focused Feasibility Study for the
Odessa Chromium I and II Superfund sites opened on July 30 and
closed on August 27, 1986. A public meeting was held on August 13,
1986, in Odessa, Texas with approximately 40 people in attendance;
8 people spoke. Representatives for the PRPs at each site and 7
local residents submitted written comments auring the comment
period. A summary of these comments is provided below.
Comment #1
One person asked that the proposed water supply system be extended
to include Golder Avenue (400 feet west of current proposal). The
extension was requeited du~.~o high levels of salt
in the resident's wells.
EPA Response to Comment #1
Texas Water Commission suggested, during the public meeting, that
the commentor contact the Texas Railroad Commission as they have the
regulatory jurisdiction of products which result from the production
of oil and natural gas such as salt water (i.e. sodium chloride).
EPA cannot consider extending the water supply to this area because
there is no evidence that the material found in the commentor's well
is hazardous nor is the location of the individual's well within the
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Comment #2
What actions will EPA pursue against the companies responsible for the
contamination?
EPA Response to Comment #2
EPA prefers that parties responsible for contamination of site
perform the cleanup. Potentially Responsible Parties (PRPs) have
been identified at the Odessa Chromium I and the Odessa Chromium II
sites. These parties have been notified that they may undertake,
or participate in, the chosen remedy. If they decline involvement
in the remedial action. EPA will proceed with the implementation of
the remedy and pursue appropriate enforcement action including cost
recovery.
Comment #3
Two wells located at 5329 Andrew Highway (Odessa Chromium II) should
be plugged to limit the vertical movement of contamination through
the well.
EPA Response to Comment #3
The Agency will soon complete an overall study of the sites to evaluate
alternatives for remediating the chromium contaminated groundwater.
After completion of this study. the Agency may recommend plugging
of these wells as part of the remedial action to be taken at the
site. In the meantime. there should not be significant additional
adverse effects on the quality of the Trinity Aquifer from these
wells. In addition. the unplugged wells may be of further value to
EPA in documenting the nature of the interconnection between the
perched and regional aquifer.
Comment #4
The concern at both Odessa Chromium I and II appears only to be with
the potable water. Why then are the proposed alternatives designed
to meet the total annual usage of water within the two areas?
EPA Response to Comment #4
The Agency's primary goal is to supply potable water. Extending
the city water lines (which is the most effective remedy) also allows
these residents impacted by chromium contamination the opportunity to use
it for their total needs. The secondary goal is to reduce the rate of
plume migration and prevent other areas from becoming contaminated.
Comment #5
The commentor stated their concerns regarding the possible health hazards
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EPA Response to Comment #5
The Center for Disease Control has determined through studies, that
in the occupational setting chromium dust has been found to be a
carcinogen when inhaled. Health effects from chromium in water
supplies were extrapolated from information obtained from the
occupational studies, and from animal studies where the animals were
induced with water containing elevated levels of chromium. From
these studies there appears to be increased body burdens (i.e.
liver, kidney) from drinking chromium contaminated water. However,
the studies have not confirmed that chromium is a carcinogen when
ingested.
Comment #6
Since the majority of the local residents have found other ways of
obtaining potable water (i.e. bottled water), why would this current
arrangement not continue to be satisfactory?
EPA Response to Comment #6
The Agency does not know exactly what percentage of households are
drinking bottled water. As long as wells provide potable water to the
taps of individual households, there is an unacceptable risk that people
will drink contamina~ed water.
Supplying bottled water, over a 15 year design life, would be labor
and cost intensive; therefore, was not consiQered a viable alternative.
Comment #7
Will the proposed action be the final cleanup at the site, if not
how is this remedy consistent with a final remedy?
EPA Response to Comment #7
The cleanup of contaminated groundwater plumes is so time-consuming (10-
15 years) that a need for alternative water supply is often required to
protect public h~alth and welfare until the completion of the remedy.
The extension of the municipal water supply through the impacted areas of
Odessa Chromium I and II is not the final remedy and will become part of a
more comprehensive remedy at a later date. A final remedy will be proposed
following the completion of the Feasibility Study (40 CFR 300.68 (i)(3))~
Comment #8
Objections were raised to the providing alternate water to commercial
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EPA Response to Comment #8
The Odessa Chromium. I study area is composed of 44 lots of which 23 are
residential and 21 are businesses. The municipal water system will be
extended throughout the impacted area; however, commercial facilities will
not be given the opportunity to connect with the system.
Comment #9
EPA should conduct a detailed review of the removal bf contaminants by
individual ion exchange units.
EPA Response to Comment #9
Such a review was considered in the alternate water supply feasibility
study and it was found to be costly and unreliable when compared
witA extending the city's water lines.
Comment #10
Why is the EPA proposing to use eight inch water mains when a system of
three inch mains would meet the area's needs at a significant cost savings?
EPA Response to Comment #10
All plans and specifications for extension of city water would be
established in accordance with the City of Odessa Standards and Require-
ments for Street, Alley, Water, Sewer and Drainage Improvements.
These regulations basically set forth policy' and minimum standards for
acceptable materials and a minimum standard of workmanship for the
construction of water mains that are to be connected to the City of
Odessa system. Further, to insure the integrity of the City of Odessa
system, strict compliance with the city's plumbing code must be maintained
in all connection and adherence to the regulation regarding cross
connections will be required. The city will assume all operation and
maintenance cost associated with the system; therefore, the specifications
for the alternative must follow either currently accepted city standards
or developed through successful negotiations with the City Council.
Comment #11
Numerous people, while in favor of the extension on the municipal
water supply, were concerned about the possibility of annexation.
EPA Response to Comment #11
The City of Odessa maintains a policy of non service of water outside
the corporate city limits. As a part of this study" the City Council
of the City of Odessa was requested to adopt a resolution indicating
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Odessa Chromium I and II sites to improve the health, welfare, and
safety of citizens in the areas contaminated with chromium. The
city passed such a resolution on March 25, 1986.
In recent years, annexation by the City of Odessa has been on a voluntary
basis only. The construction of the distribution system makes the impacted
area no more or less subject to annexation.
Comment #12
What is the basis for the proposed chromium action level?
.'
EPA Response to comment #12
. The federally regulated Primary Drinking Water Standard for chromium
was set at .05 ppm in 1977 based on healthJeffect studies. That
req~ire~ent is used as the basis for the target concentration.
IV.
Remaining Public Concerns
The residents strongly object to annexation by the City of Odessa
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