United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R06-86/011
Sept. 1986
4EPA
Superfund
Record of Decision
-------
TECHNICAL REPORT DATA
(Pleae mzd Instructions on the felltne IHI000t completing)
1. REPORT NO. 12. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R06-86/011
.. TITLE AND SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECIS ION September 8, 1986
Odessa Chromium II, TX 6, PERFORMING ORGANIZATION CODE
7. AUTHOR'S) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS 10. PROGRAM EL.EMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
U.S. Environmental Protection Ag e ncy Final ROD Report
401 M Street, S.W. 1., SPONSORING AGENCY CODE
washington, D.C. 20460 800/00
15. SUPPL.EMENTARY NOTES
16. A8STRACT
The Odessa Chromium II site consists of a series of chromium contaminated wells
within 200 acres of urban area located just outside the northwestern city limits of
Odessa, Ector County, TX. 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. Two potential sources of groundwater contamination at
the site have been identified~ 5329 Andrews Highway, and wooley Tool and Manufacturing
at 57th Street and Andrews Highway. Between 1950 and 1965, the 5329 Andrews Highway
site was occupied by Continental Products of TX, a prod~cer of a chromium containing
cooling water additive. Basin Radiator and Supply, commencing operations at this site
some time between 1965 and 1969, was investigated by the local Health Department in 1970
in response to a complaint of contaminated (5.5 mg/l chromium) well water on the
property to the south of the company. Wastewater analysis, at that time, did not
indicate the presence of chromium, but in 1978, a partially buried steel tank leaked a
cleaning vat solution containing 2.8 mg/l chromium. Wooley Tool and Manufacturing,
operating since about 1950 utilized chromates in their cooling water system until about
1976. This system, tied into one of 'the plant's water wells, could have inadvertently
back flushed into the well during occasional slow downs due to the absence of a check
(See Attached Sheet)
17. KEY WORDS AND DOCUMENT ANAL.YSIS
a. DESCRIPTORS b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Record of Decision
Odessa Chromium II, TX
Contaminated Media: gw
Key contaminants: chromium
18. DISTRIBUTION STATEMENT 19. SECURITY CL.ASS (This Rt!porT) 21. NO. OF PAGES
None 39
20. SECURITY CL.ASS (This pagt!) 22. PRICE
None
"
EPA 'o,m 2220-1 (R..... ~-77)
-------
EPA/ROD/R06-86/011
Odessa Chromium II, TX
16.
ABSTRACT (continued)
valve. Until about 1970, the plant also disposed of chromate contaminated
wastewater in an unlined pit. The primary contaminant of concern is
chromium.
The selected remedial action includes: extension of municipal water
service to the affected area of the site. This involves negotiations with
the city and local residents. The capital cost for this action is $476,570
-------
Record of Decision
Remedial Alternative Selection
SITE:
Odessa Chromium II, 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 II site.
o Odessa Chromium II Remedial Investigation Report (April 1986)
o Odessa Chromium II Alternative Water Supply Feasibility Study (June 1986)
o. Summary of Remedial Alternative Selection
o Responsiveness Summary
Description of Selected Remedy
o Negotiate agreements ~ith 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 Natioryal~Contingency Plan (40
CFR Part 300), I have determined that the selected remedy for the Odessa
Chromium II site is a cost-effective remedy and provides adequate protection
of public health, welfare and the environment. The State of Texas has
been consulted and agrees with the approved remedy (Attachment A). In
addition, the action will require future operation and maintenance of the
water distribution system.
I have also determined that the action being taken is appropriate when
balanced against the availability of Trust Fund monies for use at other
sites and is necessary to protect public health, welfare or the environment.
\~ '. 8 'liJ8G,
~I
CD,
Dick Whittington, P.E.
Regional Administrator
-------
t-
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
OPERABLE UNIT - ALTERNATE WATER SUPPLY
ODESSA CHROMIUM II
ODESSA, TEXAS
-------
TABLE OF CONTENTS
Site Location and Description ------------------------------------------ 1
Site History ----------------------------------------------------------- 1
Current Site Status ---------------------------------------------------- 2
Exposure Assessment ---------------------------------------------------- 4
Applicable or Relevant and Appropriate Requirements -------------------- 4
Community Relations ---------------------------------------------------- 6
Enforcement ------------------------------------------------------------ 6
Alternative Evaluation --------------------_:_-------------------------- 6
Recommended Alternative ----------------------------------------------- 10
-------
v
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
OPERABLE UNIT - ALTERNATIVE WATER SUPPLY
Odessa Chromium II
Odessa, Texas
September 1986
SITE LOCATION AND DESCRIPTION
The Odessa Chromium II Superfund site consists of a series of chromium
contaminated wells within 200 acres of urban area located immediately
west of the Andrews Highway just outside the northwestern city limits of
Odessa, Ector County, Texas (Figure 1-1). Based on the boundaries of
presently known chromium contamination in the groundwater of the Trinity
aquifer, the site area is bounded approximately by 57th Street on the
north, 50th Street on the south, Andrews Highway on the east and a line
which extends from Arthur Avenue north to 57th Street and south to 50th
Street (Figure 2-13). The site area is composed of a mixture of residential,
commercial and industrial facilities. Nearly every residence or commercial
facility is served by one or more water wells completed in the Trinity
aquifer which offers the only source of potable groundwater.
.SITE HISTORY
From 1950 to 1965, Continental Products of Texas (Continental) produced
cooling water additives which contained chromates at 5329 Andrews Highway.
Mr. Dale Meyer has reported that when (in November 1951) he occupied the
property located at 54th Street and Andrews Highway which adjoined
Continental, his well water was bright yellow in color, presumably the
result of chromium contamination.
Basin Radiator and Supply began operation at the 5329 Andrews Highway
location site sometime between 1965 and 1969. Local Health Department
authorities, investigated a complaint of contaminated (5.5 mg/1 chromium)
well water on the property to the south of 5329 Andrews Highway in 1970.
At that time, analysis of wastewater from Basin Radiator did not indicate
the presence of chromium, but in 1978 their cleaning vat solution, which was
eventually stored in partially buried steel tanks, contained 2.8 mg/1 of
chromium. One of the storage tanks was discovered to be leaking and the
tanks were subsequently removed.
Woolley Tool and Manufacturing has been operating at 57th Street and
Andrews Highway since about 1950. Chromates were utilized in their
cooling water system until about 1976. This system was apparently tied
into one of the plant's water wells and during occasional slow downs,
cooling water could have been inadvertently back flushed into the well
since there was no check valve. The plant also utilized an unlined pit
for the disposal of contaminated wastewater, including chromate wastes
-------
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SITE LOCATION MAP
FOCUSED FEASIBILITY STUDY
ODESSA OiRON IUM JI SITE
ODESSA. TEXAS
'PREPARED FOR
TEXAS WATER COMMISSION
AUSTIN. TEXAS
APPROX SCALE
'18. IT CORPORATION
ALL COPYRIGHTS RESERVED
rn /HOWELL ENG.
-------
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SUPERFUND IMPACTED
SERVICE AREA
OfRDMIUM CONTAMINATION
PLUME
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SUPERFUND IMPACTED
SERVICE AREA
FOCUSED FUSIBILITY STUDY
ODESSA CHROMIUM U SITE
ODESSA, TEXAS
PREPARED FOA
TEXAS WATER COMMISSION
AUSTIN. TEXAS
-------
\
2
In late 1983, the Texas Water Commission (TWC) submitted the Hazard
Ranking Package to the Environmental Protection Agency (EPA) for the
Odessa Chromium II site. The site was added to EPAls National Priorities
List in 1984, thereby becoming a Superfund site. The State of Texas
entered into cooperative agreement with EPA for $530,000 on September 26,
1984, to perform Forward Planning and Remedial Investigations/Feasibility
Studies (RIfFS) at the site. The RI began in August 1985 and a draft
report was submitted April 1986.
In January 1986, EPA and the TWC decided to produce a "Focused" Feasibil ity
Study (FFS). The single purpose of the FFS was to be the examination of
possible alternative water supplies which could provide potable water to
the area(s) within the greater Odessa Chromium II site where groundwater
is contaminated or could reasonably be expected to become contaminated by
chromium within 24 months. While the goal of the EPA is to determine a
plan for addressing the chromium contamination in the groundwater, the
FFS placed a portion of the full feasibility study on a "fast tracked"
schedule. By doing so, it opened the possibility of expedi~ing the
supply of potable water to affected residents without waiting for completion
of the full FS. The FFS began in March 1986, and a revised draft report
has been submitted.
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 wit~ depth. Pleistocene
windblown sand, playa deposits and alluvium deposits underlie the soil
section. Beneath the Pleistocene are Plio-Pleistocene caliche deposits.
Underlying the caliche are scattered erosional remnants of the Tertiary
Ogallala formation composed of gravels, sands, silts and clays. These
basal sediments occupy previously eroded drainage valleys and are not
present everywhere. Cementation of the sands is variable within the
Ogallala. This formation does not generally extend to depths below 75
feet in the area.
The Cretaceous Trin~ty formation, the main fresh water producing aquifer
in the area, underlies the Ogallala interval. It is composed of sands and
sandstones with minor amounts of siltstone, clay and gravel. Cementation
of the Trinity in the site area ranges in degree from moderate to heavy.
The aquitard beneath the Trinity formation is the Dockum Group of Triassic
age, locally known as "redbeds.11 The upper unit, the Chinle Formation, .
consists of up to 600 feet of red and reddish-brown clays and shales.
Groundwater
The major hydrologic units containing potable water in the site area are
the Ogallala formation at approximately 70 feet below the area and the
Trinity Sand at approximately 90 feet below the area (Figure 2-2). In
-------
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(MA'NL Y SAND WITH VARYING
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CHI NLE FORMATION
(RED CLAYS WITH INTERSPERSED SANDS)
FIGURE 2-2
GENERALIZED STRATAGRAPHIC SECTION
FOCuS~D FEASIBILITY STUDY
ODESSA CHROMIUM II SITE
ODESSA TEXAS
PREPARED FOR
TEXAS WATER COMMISSION
AUSTIN, TEXAS
. '98' IT CORPORATION
ALL COPV~IGHTS RESERVED
--:--;-:-: ".-:-:: -:a
-------
3
Trinity and has littl~ or no saturated thickness. A few miles to the
southwest the Ogallala has been totally eroded and within the site area
is only a thin remnant containing little water. Groundwater occurs
beneath the site mainly in the Trinity Sand. The hydraulic characteristics
of the Ogallala are of greater importance locally than the quantity of
water present due to the fact that the Ogallala may potentially act as a
medium through which contaminants may enter the underlying Trinity Aquifer.
Barriers to vertical movement exist in the Ogallala as discontinuous
lenses of calcite or cemented sandstone. These lenses were encountered
in drilling at the site and vary from less than 6 inches to several feet
in thickness.
Another influence on contamination movement seems to be the caliche layer
near the surface. Shallow borings indicate that it acted as a relatively
effective barrier to the downward migration of contamination caused by
leaching of the soil.
Well Inventory
An inventory of existing water wells in and around the previously identified
area of chromium contamination was conducted in September 1985. The
primary goal of this work was to confirm and refine the boundaries of the
plume of chromium contamination. Over 400 wells were identified during
the inventory. of which more than 300 were sampled and analyzed. for
. hexavalent chromium. The inventory covered an area extending in a radial
direction about half-a-mile beyond the known areas of groundwater contamination.
Twenty wells were found to have chromium in the water.
From the well inventory. several conclusions were drawn about the
contamination plume. The first was that there were two potential sources
of the contamination resulting in two plumes (inst~ad of the previous
concept of one). The second was that any indiv1dual well could have wide
fluctuations in the chromium concentrations over a period of time. This
was based on comparisons with the results of previous TWC sampling. As a
result of these fluctuations. no logical concentration contour map could
be constructed. As a result. it appears the contamination enters the
groundwater in "pulses" which are either natural or man induced.
Definition of Present and Projected Contamination Area
The estimated extent of chromium contamination in the Trinity aquifer is
shown in Figure 2-8. Historical levels of chromium concentrations measured
in area wells between 1970 and 1986 are presented in Table 2-4. There
are two plumes. one which appears to radiate outward from Woolley Tool
(Andrews Highway and 57th Street) and one oriented south-southwest from
Basin Radiator (5329 Andrews Highway). Samples collected of water from the
. newly installed monitor wells have revealed three additional areas of
contamination which had been considered clean during the drilling program.
The occurrence of chromium contamination at or above the drinking water
standard is more frequent in existing water wells than in newly installed
-------
I
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LEGEND
PRe 'J£CTElJ Pl.U4£
BOUNOARY
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EXISTING WATtII wnL
LOCATION (sa NOTE 21
MOlliTaI WUL LOCATION
WITH HIGHEST RECOROEO
CHROMIU" CONCENTRAT~
DURING REMEDIAL
INVESTIGATION
1101£' (I, A_OXI..ATt L.DCATIDN
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-------
,TAILI 2-4
ItS'l'OUCAL UCOID 0,. CIIImmJII ~dTlOWS
POCUS~D FEASIBILItY STUDT
OD~SSA CHlflllmt II sin
~SSA. ~
Totd OIrOlli_. 81/1
.11 10. tocaUn 5/70( I) "77( I) U/77( I) 2/7'( I) 1'79(1) 10/80(1) 6183(1) 1/84(1) "85 11/85 1l!!
£-2066 D. a. I18nel1. 5721 Andren 1IIr7. <0.02 <0.01
!-2068 BPI. 5701 Andren 1IIr7. <0.01
£-2069 Iud Crah_. 206 W. 57th St. 0.05 0.01 0.d3
!-2070 Odea.. racker. 210 W. 57th St. 0.07 0.05
".
£-2071 ODnai. llaetrea. 214 W. 57th St. <0.02 <0.01
!-2124 Bovard 8oatr11ht Inc. ~.02 0.01
5700 Andr_. 1IIr7.
£-2126 lIo8c:o tat.l.. 5600 "'dren "'r.Y. <0.02 <0.01
!-2128 toT DrUUD,. 5704 Andr__~. <0.02 <0.01
1-2156 L , L Mlchin.. 213 v. 57th St. <0.02 <0.01
!-21561 Texa. CD88ere.. 211 W. 57th St. 0.02 <0.01
£-2172 Darrell 'ea.bl.. 314 W. 54th St. <0.02 <0.01
£-2173 I. Link. ]08 V. 54th St. <0.02 <0.01
£-2175 a. K. W.dh88. '06 W. '4th St. 0.01 <0.01
!-2176 ... C. ""ore. 5403 "'ren Rwy. <0.02 <0.02 <0.01
£-2177 J . a tnda.tri... 0.58 <0.02 <0.01
5405 Andren Iwy. 0.06
1-2118 80...... ODn.t.. 5407 .clr... 1IwJ. 0.22 0.11
1-2179 IDol I., 1bol. 5621 Amdre88 Rwy. 0.41 2.7
!-2179A Voolle, Tool. 5621 Andrew. Ihry. 0.07 0.20
1-21791 Ibolle, 1bol. 5621 Ancfre88 Rwy. 0.06 0.04(2) 0.27
!-2186 Sant. 'e. 5400 Andre- Hwy. <0.01
-------
0'
v'
TABLI 2-4
IIISTOJICAL UCOItD or .CHROMIUM COIfCElmlAnows
(Contln.ed)
Total 011'081._. 11111
11811 11o. Locatf.01I 5/70( I) "n( I) 12/77( I) 2I79( I) 1979(1) 10/1l0( I) 6183(1) 1/84 (I) ""' 11/'" i/86
1-211111 Tea.co. 5500 Andr... IIIry. <0.01 ~d.ol
ilIA '-deo Indu.trle.. <0.02 0.05 I.
5402 Andrew. Hwy.
-------
TULI 2-4
RtStOatCAL It!COU 0' CHROMIUM COMC!1ft'ItATIORS
(Continued)
Tot.l CIIrOllt18. .,/1
.11 Mo. Loc:.UOft 5/70(1) 9/77(1) 12/77(1) 2/79(1) 1979( I) 10/80(1) 6183(1) 1/84(1) .!l!! !!l!! 1!!!
1-2261 !ta8.n PD-. 201 w. 54th St. <0.03 <0.02 <0.02 <0.01
£-2264 081. lIe;.r. 54th' ADdrews IIIIy. 0.14 0.04 0.11 0.1 0.1
1-2265 Del. lleyer. 54t" I Andren 1Iwy. <0.02 0.02 . ,
-------
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FOCUSED FEASIBILITY STUDY
ODESSA CHROMIUM ][ SITE
- ODESSA, TEXAS
PREPARED FOR
TEXAS WATER COMMISION
AUSTIN. TEXAS
'"
: t '88. IT CORPORATION
: ALL COPYRIGHTS RESERVED
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PROPOSED WATER MAIN
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FOCUSED I'EASllIllITY STUDY
ODESSA CHROMIUM D SIT[
OCESSA, TEUS
PA£PARED FOR
TEXAS WATER COMMIS'SION
AUSTIN, TEXAS
[I] /HOWEll ENG.j
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4
wells were not cased through the contamination in the perched water zone.
The probable migration of contaminants in a southerly direction in the
perched groundwater zone is apparent when the hydraulic gradient is
considered.
Over the entire area making up the Odessa Chromium II site, the regional
hydraulic gradient in the Trinity is to the southwest with a slope varying
between 10 and 80 feet per mile. Contaminated water entering the top of
the Trinity aquifer spreads out horizontally in a southwesterly direction.
Vertically, it can be presumed that the contaminants move progressively
deeper with increasing distance from the source in this relatively
homogenous aquifer.
As shown in Figure 2-8, there appear to be two distinct plumes of chromium
contamination in the Trinity aquifer within the site area. Based on the
start of manufacturing or process operations, first reports of contamination,
and historical sampling data (TWC records), it is possible to estimate
contaminant migration rates for both plumes.
The northern plume appears to radiate outward from Woolley Tool and
presently shows the highest concentrations in a horseshoe shaped halo
some 1,000 feet west, southwest, and south of the original plant location.
Contamination in Trinity wells on the Woolley property was first confirmed
- in- 1977. Assuming it may have been present as long as 10 to 20 years
before this date, it can be estimated that migration velocity has averaged
between 30 and 50 feet per year. .
For the southern plume, which is interpreted to radiate outward from the
property at 5329 Andrews Highway, a similar calculation can be made.
Starting from the first reports of contaminated water made by Mr. Meyer
in 1951 and the start of manufacturing at the location utilizing chromium
in 1950, contaminants have had 36 years to enter the Trinity aquifer and
migrate downgradient. Based on these data, an average migration velocity
of slightly over 30 feet per year can be estimated.
EXPOSURE ASSESSMENT/APPLICABLE OR RELEVANT AND APPROPRIATE FEDERAL REQUIREMENTS
The public health evaluation process as described in the EPA Draft
Superfund Public Health Evaluation Manual (December 18,1985) states that
the projected concentration of the indicator chemicals at the exposure
points should be compared to applicable or relevant and appropriate 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
envi ronment.
For the Odessa Chromium II site, the receptor exposure points are assumed
to be the water supply wells, the indicator chemical is chromium and the
applicable or relevant requirement is the Federal Drinking Water Standard
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5
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 pUblc
health perspective. Thirteen out of twenty contaminated wells sampled
during the RI had chromium levels at or above 0.05 mg/1 [the maximum
concentration limit (MCL)]. Eight of these thirteen wells had values at
or above 0.12 mg/1 [the proposed recommended maximum concentration limit
(RMCL) Federal Register, Nov. 13, 1985]. See Table 2-3 for data and
summary statistics.
Since chromium has an applicable relevant, and appropriate requirement,
'i.e., the EPA Drinking Water Standards, that requirement is used as the
basis for the target concentration. Consequently, the public health
evaluation is complete when the concentration of chromium in the wells is
compared to the standard.
The wells with values above the MCL of 0.05 mg/1 are not suitable for use
as a lifetime drinking water supply and an alternate water supply is
indicated.
As required by the SDWA, EPA acted quickly following the passage of the
SDWA in publishing Interim Primary Drinking Water Regulations. Regulations
were established for ten inorganic chemicals, six pesticides and two
microbiological indicators.
The Maximum Contaminant Level (MCL) for total chromium under the National
Interim Primary Drinking Water Regulations was set at 0.05 mg/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 m~t first propose and promulgate a
recommended maximum concentration limit, which 1s 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 Guidelines for Carcinogenic Risk Assessment
as a Class A carcinogen, based upon positive inhalation data for hexavalent
chromium in humans and animals. The Class A category is at the top of
the scale, indicating the greatest strength of evidence suggesting the
chemical IS carcinogenicity.
The evidence indicates, however, that hexavalent chromium is carcinogenic
when inhaled as a fume but not when ingested. Since chromium has not
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~ABLE 2-3
TOTAL CHROMIUM VALUES >0.05 w';/L (IICL)
UPOI.TED rOR EXISTING VATEI. SUPPLY WELLS
SAKP LED DUB.ING J.I
rocuSED FEASIBILITY STUDt
ODESSA CIiIlOKIUK II SITE
.. ODESSA. TEXAS
TOTAL
CHROMIUM VALUE
WELL NO. USE (MG/L) NOTE(S)
E20700) Commercial 0.07,0.05
E2178 Commercial 0.08,0.11,0.06
E2224 Residential 0.01(2),0.05
£2226 Traller Park 0.18,0.16
E2254 iesl1denUal 0.07,0.05
E2258 Residential 0.3,0.21
£2259 Residential 0.87,1.7
£2260 1lesidential 0.21,0.01(2)
. - £2261 Residential 0.01(2),0.85
E2264 Commerciall 0.10,0.10
Residential
£2267 Commercial 3.3,3.2 Abandoned
E2270 Motel 0.8,0.14,0.17
£2270A Motel 0.15,0.09
...
1. See Figure 2-8 for veIl locations.
2. Value below drinking vater 8tandard of 0.05 .g/l.
Summary Statistics:
>0.05 mg/l N-26, X-O.48, SD . 0.88 range. 0.05-3.3 .g/l
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,
6
proposed a RMCL based on chronic toxicity data. A RMCL of 0.12 mg/l is
proposed for total chromium, i.e., Cr III plus Cr VI in drinking water
(Federal Register, Nov. 13, 1985).
The third step will be for EPA to propose a MCL as close to the RMCL as
feasible. Feasible is defined as "with the use of best technology treatment
techniques and other means which EPA finds are generally available (taking
cost into consideration)". The new chromium MCL will probably be proposed
by EPA in the fall of 1986. Since the RMCL is a goal, the MCL will most
likely be set at or above the RMCL limit of 0.12 mg/l.
COMMUNITY RELATIONS
This section will be completed after the public comment period.
Attachment B).
(See
ENFORCEMENT
The goal of the EPA is to have those responsible for contamination perform
the cleanup of the site. The Agency has identified at least two potentially
responsible parties at the Odessa II site. These parties have been
no~ified that they may undertake, or participate in, the chosen remedy.
. If they decline involvement in the remedial action, EPA will pursue
appropriate enforcement action.
ALTERNATIVES EVALUATIO~
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 II site. The
purpose of the FFS was to develop and evaluate alternative water supply
options in terms of cost, acceptable engineering practices and effectiveness
in contributing to the protection of public health, welfare and the
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\
7
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 FFS:
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
(Alternative VII).
These seven alternatives were subject to an initial screening process
to narrow the list of potential remedial actions for further detailed
analysis (40 CFR 300.68(g)). The three broad criteria used in the initial
screening are cost, acceptable engineering practices and effectiveness.
A brief description of the alternatives and summary of the initial screening
follows.
No Action (Alternative It
.
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 lIt
'The development of surface water (rivers, streams, lakes, ponds and
reservoirs) would be considered under this alternative. The potential for
developing a new surface water supply from streams, lakes or rivers is
nonexistent in the site due to the lack of a reliable year round source.
The possibility does exist of purchasing water from the Colorado River
Municipal Water District which maintains storage reservoirs one-half mile
south of the Odessa Chromium II site. This alternative will be expensive and
difficult to arrange but is effective and feasible. Alternative II was
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8
Both these alternatives have two basic prerequisites: a central distribution
system and an existing, low yield supply of potable water which could be
pumped into a storage facility. Neither of the prerequisites is met at
Odessa Chromium II and both alternatives are eliminated from further
consideration.
Removal of Contaminants via Treatment (Alternative V)
A treatment process to remove chromium from the groundwater to bring the
water within the drinking water standards is considered in this alternative.
This can be accomplished by treatment at individual wells or at a central
treatment plant. Three treatment methods, precipitation, ion exchange and
reverse osmosis, were considered. Precipitation and reverse osmosis,
while capable of removing most of the chromium, would not reduce the
concentration below the drinking water standard of 0.05 mg/l; Only ion
exchange is a viable treatment process. Individual household ion exchange
units are costly and require sensitive water quality control. A central
ion exchange system offers the fewest number of serious drawbacks and was
considered in more detail.
"Development of a New Well Field (Alternative Vlt
Under this alternative, a supply of water could be developed by drilling
new wells away from the contaminated area and bringing the water to the
affected area. Due to land use restrictions, ownership restrictions and
locations of poor quality water, only the area south of Yukon Road and
east of Ector Avenue, 1.5 miles "northeast of the si~e, can be considered
for a new well field. This alternative will be expensive but is feasible
and was considered for further analysis.
Connection with an Existing Municipal Water Supply (Alternative Vllt
This alternative would consist of the extension of the city of Odessa
lines beyond the city limits into the affected areas. The city of Odessa
is forbidden by ordinance from supplying water to customers outside the
city limits. Annexation of an area is required in order to extend water
service but residents of the affected area have expressed opposition to
annexation. The alternative does appear feasible in spite of this problem
and was considered for further analysis.
DETAILED ANALYSIS
The preliminary screening process has reduced the seven options for
alternative water supplies down to four options:
o Development of "a surface water supply (Alternative II)
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,
9
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.
Important findings from the detailed analysis of each alternative follows.
Development of Surface Water Supply (Alternative lIt
The water supply of the Colorado River Municipal Water District (CRMWD)
is' adequate, reliable and of good quality. A water association or private
'corporation will be necessary to own and operate the treatment system and
distribution system. The total capital cost is estimated at $661,675
with annual operation and maintenance cost of $114,400. The public health
will be well served and no adverse environmental impacts would take place
due to this alternative. The city of Odessa has right of first refusal
with CRMWD thereby complicating negotiations fo~ t~e water.
Removal of Contaminants via Treatment (Alternative V)
A central system utilizing ion exchange would require at least nine
water wells pumping contaminated water from the affected area to the
system. The treatment system would be sophisticated and require trained
personnel working for a water association to run and maintain the equipment.
The capital cost estimate is $1,471,885 with operation and maintenance cost
estimated at $360,700 annually. A major negative aspect is the requirement
of the nine water wells pumping from the contaminated area. The character-
istics of the aquifer would dictate that the wells be spread throughout
the plume area causing nine pumping centers with corresponding cones
of depression leading to further migration of the contaminants.
Development of a New Well Field (Alternative VI)
The 100-acre tract envisioned for this alternative reportedly contains
enough good quality water to meet the demand of the Odessa Chromium II
site. Valuable water rights would need to be purchased and a treatment/
distribution system constructed. The estimated capital cost is $3,676,800
with annual operation and maintenance cost of $119,850. No adverse environ-
mental impacts would occur and the public health would be well served by.
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\
10
Connection with an Existing Municipal Water Supply (Alternative VII)
This is the only alternative which considers the purchase of treated
water rather than raw water. The city of Odessa has an adequate supply
of good quality water which more than meets public health requirements.
The extension of the city water lines is simple and inexpensive at $476,570
in capital cost with annual operation and maintenance cost of $51,575.
No adverse environmental impacts would occur. The city policy of 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
the site area.
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 II site. This alternative consists
of the extension of the city of Odessa water lines to the affected area
and subsequent supply of water -from the city. 'Detai 1 s on the water 1 i ne
extension are provided in figures 5-9 and 5-10.
In first analyzing the cost of the alternatives, the recommended alternative
is clearly the advantageous plan. The numbers in Table 6-1 translate
into a considerable savings if the extension of municipal water service
is implemented over the other three alternatives. A savings of 150% to
780% is realized by the~recomme~ed Alternative VII. The property owners
will also have much lower water bills under Alternative VII.
In terms of effectiveness, all the plans meet the goal of supplying water
that will protect the public health and welfare. Only Alternative VII
supplies treated water without the need for construction and operation of
a treatment system. This is an advantage for the extension of municipal
water service.
. Institutional drawbacks are present in all the alternatives. The purchase.
of surface water or water rights in Alternatives II and VI will be difficult.
The operation of a water association as called for by the three rejected
alternatives would be a burden to the people in the affected area. These
institutional issues are not present in the recommended alternative, however
the extension of the city's Water lines will require an exception to the
rules governing water supplied across city limits. This problem has
shown to be solvable due to the cooperative spirit of the city of Odessa,
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TABLE 6-1
: COST COMPAnSON OF ALTERNATIVES
rOCUSED FEASIBILITY STUDY
ODESSA CBIlOKIUM 11 SIrE
ODESSA, t'EI.AS
O&M(I) O&K NET PV(3)
ALTERNATIVE CAPITAL COSTS PRESENT VALUE(2)
11 Surface Water $ 675,725 $158,950 $1,209,000 $1,884,725
l1a Combined
Surface Water 661,675 114,400 870,150 1,231,825
V Ion Exchange 1 ,471 ,885 360,700 2,743,500 4,215,385
VI New Well Field 3,770,340 155,000 1,178,950 4,949,290
VIa Combined
New Well Field 3,676,800 119,850 911,600 4,588,400
UTI Municipal Water 476,570 51,575(4) 392,300 868,870
Notes:
(1) O&H . Operations and Maintenance
(2) Present Value, based on 15 years, 10% di8count rate and 0% inflation,
for O&M.
(3) Net PV is total of capital costs and present value of O&M.
(4) O&H costs assumed equal to the annual total of .onthly vater bills
paid by property owners in the impacted area.
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.
ALTERNATIVE
II
Surface Water
Ila .Combined
Surface Water
V
VI
Ion Exchange
New Well Field
VIa' Combined
New Well Field
VII
Note:
Municipal Water
TABLE 6-2
COST PER THOUSAND GALLOR
COMP ARISON OF ALTERNATIVES
POQJSED FEASIBILITY STUDY
ODESSA ClmOKIOK II SITE
ODESSA. '1'EUS
COST ($)!THOUSAND CALLONS(l)
7.19
6.54(3)
AVERAGE
RESIDENTIAL MONIHLY
WATER BILL( )
107.81
.98.13
16.31 244.65
7.01 105.13
6.44(3) 96.67
7.70/1.35(4) 37.88
(1) Costs are annual O&M costs and annual vater consumption in
thousands of gallons. .
(2) Based on fifteen thousand gallons.
(3) Based on combining water consumption for both Ode..a 1 and Odessa
II and O&M costs for Odessa I and Odessa II .ince residents would
be part of the .ame vater association.
(4) For firlt tvo thousaDd lalloDs, $7.70 and $1.35 per thou.and
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e
t'A1t8 ...,
TlC8lCAJ./talJ.IVTJ.OIIAL ~AII- or AL18IIIA1'nIS
POaJSKD ru.C;nll.lft S1UDt
OD!SS& alWOMIIM 11 51T1
ODKSSA, 1'I!IAS
'ROIABLI
ALftUAnnS PUlLIC IllALTli COIICIDI IWYtlOllMElft'AL CORC!M5 ftCRlftCAL COWCEU5 COMMUlfIn U:SPO"SI COIfCIIRS O1'R!R r ;1
udac. Vat.1' Wo '1'0'1... anticipated. SltOt't ten conatt'Uctloa 51.,le techaolO11 In RI,h 8Oftthl, water 'Ill Lla'lllt, for contloued
I.,act. tre.t8ent and connect loa and ,robl.. of fomtftl auppl, reat. .Ith a I .;
to pre.ent aource. and ..Intalnl", . ..ter ..ter a..oelatlon.
a..oclatlon.
D8 bcha",. ~eat8ent Malnteaanc. 0' 'aclllt, CDnt881na"t ,18e -, be '~en tre.~"t tech- BI.h 8Oftthl, wat.r 'Ill Llablllt, lor .al.. !
to la.ure that coat..- undealrabl, -14en8d. nolol1 altho~h requlrel .nd ..Intalnl", a water talnln. acceptable
laantl ,roper 1, 1'8- .trln.eat operational a..oclatlon. Allo, -111 vater quallt, re.elna
lIO.e4. re.I... tre.t.ent caetlnue to vlth . vater ...oc-
lunctlon In Ion. tamt I.tlon.
- Llabillt, lor ..Intel.l
!!W _11 '1.1. Potantlal eoac.rae Ihort ten coaatractlon 51.,1. tech_loIY lor BI.h 8Oftthl, ..t.r .111
about 10D1 tem quallt, I.,act. obtalnlas ..ter aappl, eod probl.. 01 forwlftll In. vater luppl, r..al~.
of ,round vater .oarc.. aod treat_nt. and .alntalnln. a ..tel' -Ith a -tel' I
, ...oclatlon. a.loclatlon.
. laldpal Vlier We probl... antlcl,ated Short ten con.tractlon 51.,1. technoloIJ 1'8- ODncen o.er potaatlal Clt, to pr,"14. wat..
t.,act. quire connection to for anne.atlon. luppl,.
e.t.tln, Clt, .ater
.aln..
,.
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11
In summary, EPA recommends the extension of municipal water service to
the affected area of the Odessa Chromium II site is the cost-effective
remedy for this operable unit of the project. The estimated total present
value cost is $868,870 and time of implementation is 9-12 months.
Schedule
The schedule for the design and construction of the alternate water supply
at the Odessa Chromium II site is currently dependent upon reauthorization
of Superfund. The design phase of the project will begin as soon as
funding becomes available, either through reauthorization or a continuing
resolution. When funding is available, the design and construction
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TEXAS WATER COMMISSION
Paul Hopkins, Chairman
Ralph Roming, Commissioner
John O. Houchins, Commissioner
" . U"'-n
r..:'. :.i ~ .-.i.J
'. .... '''..,.,.. J ,.-
Ltr~ i'S~~'ard:' Executive Director
. .- ; ~;ry ,..;t, Ii~ni!, Cilge{ Clerk
James K. Rourke, Jr., General Counsel
.: I:" :-;,', LI'Jn f'D J.. ~ICH
~-I.u.\' "- J:"~I\
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
Odessa Chromium I and
Odessa Chromium II Superfund Sites
Dear Mr. Whittington:
Re:
This is in response to your letter of August 5, 1986 which
requests our comments and/or concurrence with regard to the
proposed remedy for providing an alternative drinking water
supply to the affected areas at the Odessa Chromium I and II
Superfund Sites. The draft Summaries of Remedial
Alternatives Selection recommend that connection with an
existing municipal water supply be selected as the cost
effective alternative for the two sites. This alternative
consists of the extension of the City of Odessa water lines
to the affected areas and the subsequent supply of water
from the City. A public meeting was held in Odessa on
August 13, 1986, to discuss the various methods of providing
an alternative drinking water supply and to receive comments
from the public." .-'''''
The Texas Water Commission has no objection to EPA's
selection of the proposed remedy for providing a potable
water supply to the affected areas at the two sites.
If you have any questions, please have your staff contact
Greg Tipple of our Superfund Section at 512/463-7798.
Sincerely,
~f~
Larry R. Soward
Executive Director
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,
COMMUNITY RELATIONS RESPONSIVENESS SUMMARY ON POTENTIAL REMEDY MODIFICATION
ODESSA CHROMIUM I & II, TEXAS
This community relations responsiveness summary is divided into the following
sections:
I.
Overview - This section discusses EPAts preferred alternative for
remedial action, and likely public reaction to this alternative.
~round on Community Involvement and Concerns - This section
provides a brief history of community interest and concerns
raised during remedial planning activities through a Feasibility
Study at the Odessa Chromium I & II sites.
II.
III. Summary of Major Comments Received During the Public Comment Period
and the EPA Responses to the Comments.
IV.
Remaining Concerns - This section describes remaining community
concerns that EPA and the PRPs should be aware of in conducting
the remedial design and remedial action at the Odessa Chromium
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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.water system to
current well users and for the construction of a water distribution
system. Comments from local officials and residents favored this
option, provided that the impacted area would not be annexed to the
City of Odessa now or in the future.
The comments on the four alternatives, along with EPA's response
to each, are presented later in this document.
At this time, the EPA has presented the findings of the alternate water
supply study only. The overall study on the groundwater contamination
at the Odessa sites, including remedial alternatives, will be completed
. later this year, with public comment to follow.
II.
MAJOR CONCERNS AND ISSUES
Odessa Chromium I
Community interest, historically at a low leyel, 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 (TQWR) - now known as the Texas
Water Commi ss ion (TWC'). Thi s local resident compl ai ned that
there were odors and an 'Ioily" fi 1 m present in the water comi ng
from his well. In 1979, a water well at another particular res-
idence was investigated and found to be heavily contaminated with
'chromi urn.
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 1n 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
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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 the following concerns:
1.
Local health officials were concerned~that there were
not any legal standards for disallowing heavy metals in
drinking water.
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.
2.
I .
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 13, 1986. During the public meeting,
the Environmental Protection Agency summarized and explained the
results of all previous investigations, with particular emphasis
on results from the alternate water supply Feasibility Study.
The EPA described the various corrective measures being considered
by the Agency for the residents affected by the sites, and
outlined opportunities for pUblic involvement. The EPA explained
that the goal of the EPA at both the Odessa Chromium I and 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 alternative, extension of Odessa's water
supply system to impacted persons, at the August 13 meeting and
received comments concerning this alternative and the others considered
in the Feasibility Study. The overwhelming sentiment of residents at
the meeting was their opposition to annexation by the City of Odessa.
III. SUMMARY OF PUBLIC COMMENTS RECEIVED DURING PUBLIC COMMENT
PERIOD AND AGENCY RESPONSES.
The public comment period on the Focused Feasibility Study for the
Odessa Chromium I and II Superfund sites opened on July 30 and
closed on August 27, 1986. A public meeting was held on August 13,
1986, in Odessa, Texas with approximately 40 people in attendance;
8 people spoke. Representatives for the PRPs at each site and 7
local residents submitted written comments during the comment
period. A summary of these comments is provided below.
Comment #1
One person asked that the proposed water supply system be extended
to include Golder Avenue (400 feet west of current proposal). The
extension was requested due to high levels of salt
in the resident's wells.
EPA Response to Comment #1
Texas Water Commission suggested, during the public meeting, that
the commentor contact the Texas Railroad Commission as they have the
regulatory jurisdiction of products which result from the production
of oil and natural gas such as salt water (i.e. sodium chloride).
EPA cannot consider extending the water supply to this area because
there is no evidence that the material found in the commentor's well
is hazardous nor is the location of the individual's well within the
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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 13
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.
COl1lTlent '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 contaminated water.
Supplying bottled water, over a 15 year design life, would be labor
and cost intensive; therefore, was not considered a viable alternative.
Comment #7
Will the proposed action be the final cleanup at the site, if not
how is this remedy consistent with a final remedy?
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 health and welfare until the completion .of the remedy.
The extension of the municipal water supply through the impacted areas of
Odessa Chromium I and II is not the final remedy and will become part of a
more comprehensive remedy at a later date. A final remedy will be proposed
following the completion of the Feasibility Study (40 CFR 300.68 (i)(3)).
Comment '8
Objections were raised to the providing alternate water to commercial
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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 of 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
with extending the city.s water lines.
Comment #10
. Why is the EPA proposing to use eight inch water mains when a system of
three inch mains would meet the area.s needs at a significant cost savings?
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 thr~ugh successful negotiations with the City Council.
Comment III
Numerous people, while in favor of the extension on the municipal
water supply, were concerned about the possibility of annexation.
EPA Response to Comment 111
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 health effect studies. That
requirement is used as the basis for the target concentration.
IV.
Remaining Public Concerns
The residents strongly object to annexation by the City of Odessa
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